Petition for Writ of Certiorari — Meghan Kelly, Petitioner v. Disciplinary Counsel Patricia B. Swartz, et al.

IN THE SUPREME COURT OF THE UNITED STATES

Number 23- 23-7372

Meghan M. Kelly, Petitioner

v.

Disciplinary Counsel Patricia B. Swartz, Disciplinary Counsel Kathleen M. Vavala; David A.

White, Chief Disciplinary Counsel, Office of Disciplinary Counsel, Board on Professional

Responsibility of the Supreme Court of the State of Delaware, Preliminary Investigatory

Committee, Attorney General Delaware

Appellant Plaintiff Meghan Kelly’s Application/Motion to Recuse the Honorable Justice

Jackson and to postpone conference date for the Writ of Certiorari for Third Circuit

pending a supplemental brief for EDPA appeal No. 23-7360

September 26, 2024

Meghan Kelly, Esquire

34012 Shawnee Drive

Dagsboro, DE 19939

Pro Se, not represented by

counsel

meghankellyesq@yahoo.com

US Supreme Court No 283696

i

QUESTION PRESENTED

I.

Whether the Court must recuse Justice Jackson since around or on September 1,

2024 she opined in public on her decision against me in two separate cases pending before her,

including this case and another case, Kelly v Swart et al, showing she cannot be fair on the issues

as to whether the disciplinary rules against federal judges and the proffered disciplinary rules and

proceedings against this court violate my right to a fair proceeding as applied and per se since the

courts are tempted to violate my Constitutional rights they are charged to uphold to prevent

professional harm to their own persons by unjust threats that are used to commandeer a no longer

free and impartial lower courts but threatened federal courts which jeopardize this highest court.

II.

Is it in the interest of justice to postpone a decision on this appeal beyond the

conference date 9/30/2024 given there are no business days before conference, and I timely filed

an application to recuse Justice Jackson which has not been filed as of 9/26/2024, and I am

denied a fair opportunity to be heard under the circumstances.

III.

Given the grave magnitude of the issues presented a court should decide,

including but not limited to: Whether the court the US Supreme Court call witnesses to prevent

due process violations occurring against me a party in a case by non-party person, Senator

Whitehouse, in the sister case Eastern District Court of Appeals Number 23-7360 to protect my

First Amendment right to petition fairly in accord with the 5th Amendment and to preserve the

impartiality of the courts to protect due process so this Court’s members do not favor outcomes

that reduce the threats to their seats, their family or their beneficial interests as opposed to

applying the impartial application of the law to the facts of each case, given the issue is unusual.

Trial courts usually call witnesses not appellate courts, but all courts must uphold due process

pg. ii

and the right to petition fairly in accord with US Amend I, V, not by threats or force by outsiders

made with intent to affect the outcome of the case.

IV.

Whether Meghan Kelly should be granted time to make new arguments in another

case, given I previously argued below the US Supreme Court should only be disciplined within

the purview of the Constitutional limits of 1. a case and controversy or 2. Impeachment. I now

contest the Constitutionality of impeachment and investigative powers, or at least the

Constitutional authority of Congress to threaten the Court unrestrained from affecting the

outcome of petitioner’s 1st Amendment right to petition fairly in accord with 5th Amendment

right to due process to prevent deprivation of my asserted right to fairly be heard without outside

threats of Congress to control the outcome on issues and cases which foreseeable prejudice my

case

V.

Whether the Court must in the interest of justice grant Meghan Kelly time to

examine and present the issues as to whether Congress’s power must be limited in terms of

impeachment and investigation so as not to violate her and other claimants rights to a fair

proceeding under US Amend I, V, by threatening judges to affect the outcome on live issues in

my cases unfairly or their wives, given Congress’s members in recent times has also threatened

parties David Weiss, Justices Alito and Thomas and their wives, a NY Judge by subpoenaing his

kid where all of our cases relate to suing a President or with regards to David Weiss his son

where Congress seeks to use that information for political reasons unrelated to the impartial

application to the rule of law in violation of Article I and III.

pg. iii

LIST OF PARTIES

All parties appear in the caption of the case on the cover page, albeit I am not sure

whether Patricia Swartz’s last name is correct. I do not know if she got married or

divorced and may need to amend this should it be remanded.

pg. iv

CASES DIRECTLY RELATING TO THIS CASE

Kelly v Swartz, et al, Delaware District Court No. 21-1490, and Third Circuit

Court of Appeals Matter No 21-3198. US Supreme Court filings Kelly v Swartz et al

22A747, Kelly v Swartz et al. 22-6783, Kelly v Swartz et al. 23A100, and 23-7372.

Kelly v Trump Chancery Court No. 2020-0809, Delaware Supreme Court No.

119-2021, US Supreme Court No. 22-5522

Kelly v Democrats and Delaware Department of Election, et. Al. Delaware

Chancery Court No 2020-0157.

The Original disciplinary case in Delaware Supreme Court matter No. 22-58 and

IMO Meghan Kelly Number 541 regarding to appointment of counsel where I was denied

copies or access to the filed pleadings. US Supreme Court application 22A476 Kelly v

DE Office of Disciplinary Counsel.

Reciprocal disciplinary case Eastern District of PA matter No 22-45, Third Circuit

Court of Appeals No. 22-3372, Supreme Court No.23-7360.

Reciprocal Disciplinary case I believe is stayed Delaware District Court No. 22341.

Reciprocal Case in the Third Circuit Court of Appeals 22-8037. Reciprocal

disciplinary case before the US Supreme Court Kelly v Third Circuit Court of Appeals

No. 22-6584 and application No. 22A478.

PA Supreme Court No 2913 DD3, US Supreme Court filing Kelly v Pennsylvania

Office of Disciplinary Counsel US Supreme Court Numbers 22A981, 22-7695

DC and the US Supreme Court have refrained from discipline, DC based on

jurisdiction.

pg. v

TABLE OF CONTENTS

Question presented……………………………………………………………………ii-iii

Parties……………………………………………………………………………………iv

Related Cases……………………………………………………………………………ix-v

Table of Contents………………………………………………………………………..vi.

Appendix………………………………………………………………………………..vii

Table of Authorities…………………………………………………………………vii-viii

Statement of Case .………………………………………………………………………..1-2

Argument………………………………………………………………………………….2-15

Conclusion………………………………………………………………………………..15

pg. vi

APPENDIX

Exhibit 1.

Article, Justice Ketanji Brown Jackson says she's open to an 'enforceable'

Supreme Court ethics code, “A binding code of ethics is pretty standard for judges, and so I

guess the question is 'Is the Supreme Court any different?'" Justice Ketanji Brown Jackson said

in a CBS News interview. By Alexandra Marquez………………………..1-15

TABLE OF CITATIONS

Books and other references

Amos 5:15…………………………………………………………………………………..10

Federalist 10…………………………………………………………………………………15

Federalist 78……………………………………………………………………………...10-11

Isaiah 14……………………………………………………………………………………..13

Jeremiah 31……………………………………………………………………………………13

John 2:16……………………………………………………………………………………...12

Matthew 23:23………………………………………………………………………………..10

The origins of "Justice must be seen to be done"", Bar and Bench - Indian Legal news. Retrieved

11 September

2023……………………………………………………………………………………….….13

Sirach 8:14……………………………………………………………………………………13

CASES

Blassingame v. Trump, 87 F.4th 1 (D.C. Cir. 2023)………………………………………..12

Caperton v. A.T. Massey Coal Co., 556 U.S. 868, (2009)………………………………….14

Clinton v. Jones, 520 U.S. 681 (1997)………………………………………………………11

Fischer v. United States 64 F. 4th 329 (2024)………………………………………………..9

In re Murchison, 349 U.S. 133, (1955)………………………………………………….13-14

Nixon v. Fitzgerald, 457 U.S. 731, 755-56 (1982)……………………………………….…12

Marbury v Madison, 5 US 137 (1803)………………………………………………………12

R v Sussex Justices, ex parte McCarthy, [1924] 1 KB 256, [1923] All ER 233, Datar, Arvind (18

April

2020)………………………………………………………………………………………….13

Salazar v. Buono, 559 U.S. 700, 130 S. Ct. 1803, 176 L. Ed. 2d 634 (2010)…………………9

Snyder v. United 603 U.S. ___ (2024)………………………………………………………..9

Trump v US, USSC Case No. 939…………………………………………………………9-15

Trump v. Vance, 591 U.S. 786, (2020…………………………………………………….…12

.

Williams v. Pennsylvania, 579 U.S. 1, (2016)………………………………..14

CONSTITUTION

US Const. Amend I…………………………………………………………………1-15

pg. vii

US Const. Amend V………………………………………………………………...1-15

US Const Amend. IV………………………………………………………………..1-15

US Const. Amend. VI……………………………………………………………….1-15

US Const Amend XIII………………………………………………………………1-15

US Amend. XIV……………………………………………………………………..1-15

US Art I………………………………………………………………………………1-15

US Art III…………………………………………………………………………….1-15

Executive orders sought to find unconstitutional in Kelly v Trump establishing gov religion

E.O. 13798……………………………………………………………………………9

Ex. Or. No. 13198, Jan. 29, 2001, as amended by Ex. Or. 14015, Feb. 14, 2021……9

Ex. Or. No. 13199, Jan. 29, 2001, as revoked by Ex. Or No. 13831, May 3, 2018….9

Ex. Or. No. 13279, December 12, 2002, as amended by Exec. Or. No. 13559, November 17,

2010…………………………………………………………………………………..9

Ex. Or. No. 13559 Nov. 17, 2010……………….……………………………………9

Ex Or. No. 13831, May 3, 2018....................................................................................9

Ex. Or. No. 14015, Feb. 14, 2021…………………………………………………….9

Statutes:

28 USC 201………………………………………………………………………….9

28 USC 666………………………………………………………………………….9

42 U.S.C. ch. 21B § 2000bb, et al. Religious Freedom Restoration Act…………….9

US Supreme Court Rules

Rules 18…………………………………………………………………..1

Rule 21……………………………………………………………………2

Rule 25……………………………………………………………………1

Rule 33.2………………………………………………………………….2

pg. viii

I.

STATEMENT OF CASE

I, Meghan Kelly, Esq., pro se pursuant to Rules 18 and 25, US Amend (“Am”) I, V rights

(“rt(s)”) to Equal Protections (“EP”) to petition (“pet”), with fair opportunity to be heard

pursuant to US Am I, V, and any other law respectfully move this Court (“ct”) for leave to file

this application based on intervening circumstances of a substantial or controlling effect of the

outcome of my case not previously available that give rise to new and different legal issues and

arguments I was not able to proffer before in this and another case pending before appeal, the

Eastern District of PA case Number No. 23-7360. Justice Jackson gave an advisory opinion

against claims in this case and the sister case, showing she cannot render a fair decision. In

addition Senator Whitehouse unfairly violates my right to Due Process and a fair proceeding by

recent attacks against the Supreme Court, Justice Thomas’s and Justice Alito’s wives to affect

the outcome of ripe issues I preserve in my case requiring time to see if I can call them before the

USSC in the other case under case law such as jury misconduct or other due process grounds

which would allow the USSC to limit Congress within the purview of the constitutional limit to

protect my rights, and preserve separation of powers. Pursuant to my rights to petition fairly

under US Amend I, V, I respectfully request this Ct recuse Justice Jackson in this matter based

on her rendering a decision on issues on my case against me outside of this Article III Court

showing she cannot be fair herein, and I respectfully seek time to file a supplemental brief since

poverty and limited resources have caused a substantial burden upon my access to the courts. I

do not willingly relinquish my rts including the deprivation of my license to practice law but for

my exercise of fundamental rts not limited to my right to petition to defend them, especially my

religious belief in Jesus Christ. Given the magnitude of the issues including protecting the rt to

pet in accordance with DP before an impartial and fair not threatened forum for both public and

1

private petitions this Court must allow me time to discern how to ask it to please save itself and

the rule of law that founded, maintains and sustains these United States. The pet coupled with

DP is the source of the Ct’s power to uphold the rule of law. This ct hurts itself by degrading its

own authority by depriving both public and private people, including me as applied the right to

petition fairly in accordance with our democratic republic created with the passage of the bill of

rights into a more just fair union of states than a republic. In incorporate herein in its entirety the

petition for IFP and pet for writ of Cert. in No 23-7360 as if restated herein.

II.

ARGUMENT

Meghan M. Kelly, pro se, pursuant to her 1st Amendment right to petition fairly in accord

with the 5th Amendment declares and avers as follows to move this Honorable Court to please

recuse the Honorable Justice Jackson from partaking in the determination to grant writ of

certiorari, and any other matter in this case since she cannot do so fairly:

Per the attached article I incorporate herein as reference Justice Jackson spoke in an

interview after submission of my petitions for writ of certiorari. She gave her judicial opinion on

an issue in my cases showing she will reject my arguments unfairly since they are before her and

under her review now, which violates my right to petition fairly under US Amend I, V, by a

judge who does not even care to consider my arguments in violation of due process before

rejecting or accepting my petitions for writ of certiorari in cases, Numbers 22-7360, 23-7372.

I am so distraught Judge Jackson is giving an advisory opinion unfairly on an issue in my

case. It violates my right to a fair instead of a fixed proceeding ruling against me. Per the

attached news article, titled, Justice Ketanji Brown Jackson says she's open to an 'enforceable'

Supreme Court ethics code…, Justice Jackson stated,

“Supreme Court Justice Ketanji Brown Jackson said she is open to proposals to

implement an "enforceable code" of ethics for justices and lamented the court's

presidential immunity decision in an interview that aired Sunday.

2

"A binding code of ethics is pretty standard for judges, and so I guess the question

is 'Is the Supreme Court any different?'"

Jackson asked in an interview on "CBS News Sunday Morning" about her new

memoir, adding, "I guess I have not seen a persuasive reason as to why the [Supreme]

Court is different than the other courts."

In two cases before Justice Jackson and the United States Supreme pending for a

determination 9/30/24, I proffered reasons why Disciplinary proceedings against members of the

US Supreme Court violate my right to a fair proceeding as applied before a biased forum biased

towards evading punishment by adhering to regulatory requirements instead of the impartial

application of the Constitution to the rule of law. In my application to Justice Alito in one of

those two cases, 23A144. I indicated and repeat herein:

“16. Justice Alito recently spoke in the news indicating the US Supreme Court

may not be regulated. While I agree with Justice Alito, I think the better way to place a

check on the other two branches is within the Supreme Court’s power in cases and

controversies. Art III.

17.

Two of my cases that may be rejected or accepted before this Court Kelly

v Swartz et al and this case relate to the question as to whether the United Supreme Court

and judges in general should be corrected within the purview of the Constitution limits of

1) cases and controversies and 2) impeachment without waiver of their 5th Amendment

right against self-incrimination by self-regulation or congressional or third party

regulations that make them partial to those who control their seats instead of the impartial

application of the constitutional protections to the rule of law, which violates the 5th

Amendment Equal Protections component as applied to me a party of one with unique

religious beliefs in impartiality and against attorney and judicial regulation I outlined

Constitutional arguments in the case below and in the civil rights case.

18.

It is more effective for the court to let their opinions speak for themselves

than to allow judges, even Supreme Court justices to give into temptations of the fickle

fads to present mere advisory opinions of whoever buys the spot light by defending the

court against regulations in public or by the press. My cases should be used for the court

to save itself or not. Let the opinions speak for themselves.

19.

The courts are the only branch that safeguard individuals and individual

liberty from being sacrificed by the mob under the vote or otherwise

20.

Protecting the impartiality of the courts from the temptation to be partial

towards regulations as opposed to the impartial application of the Constitutional law

violates the 5th Amendment Equal protections Clause towards claimants like myself as

applied to me as a party of one in both Federal/State Judicial and Lawyer Disability or

disciplinary proceedings should be extended to the US Supreme Court to prevent the end

of life-time limits and to prevent regulation. I seek to extend this based on my unique

religious beliefs on required impartiality and justice in the courts as a party of one.

3

21.

Safeguarding the impartiality of the courts means correcting the courts

when they violate the laws to serve their own personal interests as the Delaware Supreme

Court violated my First Amendment rights when I filed petitions regarding the courts’

own procedural due process violations and violations of my First Amendment private

rights to petition, religious belief, exercise of belief, and association via the 14th

Amendment when it sealed the attached documents hereto to cover up its own

misconduct. 3DI 46-Ex B, C, D.

22.

I have Constitutional arguments contesting the Constitutionality of

disciplinary proceedings and certain Delaware Disciplinary rules based on my unique

religious beliefs that may give me standing to extend the same to my opposition of

regulating Federal judges outside the purview of Constitutional limits, including but not

limited to arguments contained in motions on the record. I reserve leave to make

additional Constitutional arguments against the Disciplinary proceedings and rules. 3DI43-8 through 3DI 43-10.

23.

On the record below in this case and the civil rights case I moved to recuse

Judge Phipps and Scirica per the attached motions and amended Motion and caveats I

attach hereto and incorporate herein. (3DI-43 attached hereto as Petitioner Meghan Kelly

moves this Court to recuse Four Judges, Judge Hardiman, Judge Phipps, Judge Honorable

Montgomery-Reeves, and Judge Scirica.) (3DI-44 See, Petitioner Meghan Kelly motion

for a caveat to her Motion for this Court to recuse Judge Scirica and Motion for Judge

Scirica for judicial consideration of drafting laws to prevent non-lawyers and non-judges

from practicing law or taking the place of people judges without government authority.

(3D-49, not attached 3DI-50, not attached, Motion for reagument on denial of recusal and

required affidavit.)

20.

In the motions I alerted the Court below I seek to move the Court to not

only declare certain Delawar Disciplinary Rules and the proceedings unconstitutional, but

also argued against regulating federal judges including the US Supreme Court. My main

arguments for recusing Judge Scirica relate to the fact I seek to move the court to declare

judicial federal rules he drafts and attorney rules unconstitutional, and the state rules

which mirror the rules he chairs unconstitutional. I placed affidavits on the record from

my civil rights case in the case below to show I have continuously objected to regulating

the US supreme Court or ending life time appointments during good behavior. 3DI-58,

not attached hereto as too voluminous.

21.

I believe the courts are being set up to fall by those who entice the judges

with attacks. I have particular concern that Justice Kavanaugh is specifically in danger.

83 complaints against him were published on the 10th Circuit’s web site. Should

regulations be compelled upon this court the same as those forced upon lawyers and state

judges, ex post facto Constitutional arguments would likely not apply to character of

judges. They do not apply in other disciplinary proceeding. All of those 83 arguments

will likely be used against Justice Kavanaugh and regulations will be used to control a no

longer free or impartial court. I believe all of the Supreme Court justices are schemed to

fall. Once the head is cut off the body, the District and Appellate courts will fall too.

(Not attached 3DI-)

22.

I believe the courts are in danger. That means we are all in danger since

the court is the only branch that protects individual liberties and individuals from being

sacrificed to the apparent majority’s whims of the majority through the vote.

4

23.

My cases may allow the courts to prevent the danger with particular

flexibility in this case to come up with a solution since there is no opposing counsel. The

Appellant is the Eastern District Court of PA in name only. This Court may disagree

with some of my arguments including my arguments against federal judges politicking,

but you may use the fact you disagree to create law binding on all of us including

Congress. This case gives you the authority within the law not mere ever changing fickle

public opinion or perception to preserve these United States.

24.

While I seek to preserve the courts to preserve the rule of law, I require

time to narrow my voluminous claims and asserted rights in this case. I need time to

figure it out, and may need the court to use this very case to prevent regulation of the US

Supreme Court to sustain the rule of law from schemed lawlessness down the line. I

should not forgo my own claims merely to argue how to preserve the courts by

preventing judicial regulation.

25.

I do not seek to cause the danger to the courts by seeking to sue the

members of the Delaware Supreme Court, and the arms of the Delaware Supreme Court

in my civil rights case, nor do I seek to destroy the courts when I petition against

mistakes or misconduct. Instead, I seek to uphold the integrity of the courts by requiring

they uphold Constitutionally asserted rights to uphold the rule of law from schemed

overthrow.

26.

“Congress, the Executive, and the Judiciary all have a duty to support and

defend the Constitution.” Salazar v. Buono, 559 U.S. 700, 130 S. Ct. 1803, 176 L. Ed. 2d

634 (2010)

27.

Attorneys must be permitted to petition the courts to safeguard the

Constitutional rule of law by breach of even the judiciary within the purview of the

Constitution of 1. Cases and controversies such as mine or 2. Impeachment without

retaliation for upholding the rule of law.

28.

I have to ask you what you may not want to do to please allow lawyers to

correct the three branches of government within cases or controversies without reprisal

for exercising the First Amendment right to petition. Otherwise, how may this Court give

an opinion on regulating the US Supreme Court, federal courts and attorneys if they will

not hear attorneys, including me, petitioning the court to do so on Constitutional grounds.

29.

Judges must not give into temptations to be controlled by those who entice

their desires for security by attacks by presenting advisory opinions in the news that will

likely be twisted to be used against them. Please allow opinions to speak for themselves

with binding authority upon the other two branches.

30.

I need time to ask you to exercise your authority to draft such an opinion.

I am scared I may run out of stamps and money to petition only to allow the courts to be

eliminated down the line. I ran for office in 2018 since out of state title companies

practiced law without a license and messed up the chain of deeds and took advantage of

my esteemed deceased colleague Dick Goll, Esq . I learned there is a real plan to

eliminate people judges and people staff by unelected lobbyists who control the other

ignorant or indifferent branches. We need your help to save the world by saving your

own seats the correct way lawfully. That means I must argue judges must be corrected

by lawyers in court at times to safeguard the impartial application of the rule of law that

we all respect from degeneration.

5

31.

Per the Motion to reopen the case below, not attached hereto, the courts

retaliated against me for petitioning against judicial mistakes including placing pleadings

in another case not only on my civil rights case but another pro se claimant’s medical

records on my Eastern District of PA case too. I have unique standing to argue the courts

must be corrected within the purview of the Constitutional requirements of cases and

controversies like mine to preserve not destroy the courts.

32.

Since I petitioned the Court against judicial mistakes or misconduct in this

case and the civil rights case, argued against judicial regulation, seek to sue the Delaware

Supreme Court members my two cases may be used to determine and limit correction of

the US Supreme Court and inferior courts to the purview of the Constitution.

33.

There really are lobbyists who seek to eliminate the courts to eliminate the

rule of law that restrains businesses and entities from enslaving, killing, stealing or

destroying life, health or liberty under the guise of the common good. See, Exhibit A and

B for example. The digital economy is a mere transitionary step in a far more sinister

plan. Upon information and belief, economic conditions will worsen by intentional

design to allow Central banks and banks to recoup real estate, cars and property upon

default of loans, and the new carbon credit debt scheme. Once entities the government

owes recoup resources, the entities who control most resources will control governments

to eliminate the governments by eliminating the rule of law down the line.

34.

I need time not only to ask you to save my liberty, licenses, life and

potential eternal life from temptations, I also need time to ask you to save the rule of law

by saving the courts without waiving my arguments to save myself.

Wherefore, I pray this Court grants this application.”

I assert my Constitutional rights, including my First Amendment right to petition fairly

before the US Supreme Court in accord with Due Process under the 5th Amendment. Thus, I

must request the court recuse the Honorable Justice Jackson in my case since she cannot fairly

hear the matters in either Kelly v Swartz or in the Kelly v Eastern District Court of PA since she

stated on TV to the entire world “"I guess I have not seen a persuasive reason as to why the

[Supreme] Court is different than the other courts." Meaning she has not read my arguments

against disciplinary proceedings against the US Supreme Court or she unfairly makes her

judicial determination while denying me a fair opportunity to be heard in my cases

pending before the US Supreme Court now.

I oppose any judicial discipline outside of the purview of the Constitutional limits of 1.

Cases and controversies and 1. Impeachments. I reserved this issue in both cases, and in fact

6

argued that failure to recuse Judge Scirica based on my constitutional arguments against

disciplinary procedures against the US Supreme Court and federal judges was the reason why he

should be recused. I seek to dissect the rules he works on as the chair of the committee on

Federal judicial disciplinary procedures.

I intend to file a supplemental brief in the Third Circuit Appeal of Kelly v Eastern

District Court of PA No. 23-7360 to alter my arguments to limit Congress’s powers to impeach

and subpoena so as not to violate my First Amendment right to petition fairly as applied, or

Article I and Article III separation of powers. I request time by this court to allow me to do so

please. In the alternative, I allow the Ct to rule on this issue should I be without means to file a

supplemental brief to prevent manifest injustice.

I also request time because on or about September 18, 2024 I filed a timely application to

recuse Justice Jackson with the Honorable Justice Alito with a blank application on top which

was not docketed by this court. Today is September 26, 2024. There is only one business day

left prior to conference and it is not filed. There bis not enough time for Justice Alito or the

Court to consider my concerns fairly. I did not sit on this case. I contacted the court and

indicated concerns that delays in docketing were deprivations of my right to petition fairly.

So, I pray this Court postpones conference to allow me the opportunity to petition in the

other case to grant me a fair opportunity to petition before vitiation of my rights and the

possibility of 6 new law suits against me should the Court not grant relief.

Poverty creates a substantial obstacle to my access to the courts and I have limited means

to research as I desire. I need to try. I believe there is a scheme to eliminate the rule of law and

the courts. Please let me try to ask the courts to save itself. I fight for an opportunity to be heard.

Should the court reject it, and problems arise, I allow it to reopen my Eastern District Court case

7

without me ex parte to save itself. I think outside the norms and may be able to persuade this

court should I be granted a fair opportunity to try please.

To provide background on how Congressmen violate my right to DP is they seek to force

by threat to commandeer the court to enact Judicial disciplinary rules to control its no longer

independent and impartial forum. The powers of gov are to preserve the Const liberties of the

people, not to be misused by the force to eliminate them as Sen Whitehouse seeks to do.

In my petitions in multiple cases, including this case I previously averred

attorney/judicial disciplinary rules impede on my right to a fair and impartial forum to a

threatened bullied court partial towards those who abuse impeachment power to control no

longer free and independent Supreme Court justices. I previously asked this court to limit USSC

correction within the purview of the Constitutional limits of 1. A case and controversy under Art

III a 2. Impeachment, without waiver so as not to vitiate my right to a fair and impartial forum

under the 5th Am. I now must ask the Court to consider limiting the scope of Congress’s power

to call witnesses, threaten or to impeach the Court too for failure to recuse in Trump v US No

939 or otherwise so as not to foreseeably affect the outcome of not only Trump v US but my case

to diminish my right to petition with fair opportunity to be heard on the issue of whether judicial

disciplinary rules violate my right to due process. It is for claimants to assert or waive rights

including the right to a fair proceeding not political partial non-parties like Whitehouse.

However, I am having a difficult time of coming up with a legal authority for this Court

to call in Senator Whitehouse as a witness to prevent or consider due process violations in my

case, and to limit him and other Congress members from abusing their power to affect the

outcome of issues in my case. I understand I may make legal arguments in this civil rights case

but the other case also at conference on 9/30/2024 may allow the members of this court to

8

question the Congress people who seek to attack it and my right to petition fairly in a threatened

court to save the right to a fair proceeding by safeguarding the impartiality of the courts by

government threats that violate my rights to petition and due process as applied. Plus, it is ripe

when it violates due process before the court I am petitioning before. There is something special

about giving a wrongly attacked person a means for relief too. I see wrongs that must be righted,

and the petition is the correct means to do so. FRE 604 and other legal authority may help the

USSC call in non-party witnesses to prevent fraud, obstruction, intimidation of judges to affect

the outcome of my cases.

The issues are complicated since I desire this court to subpoena Senator Whitehouse to

limit his and other law makers Congressional power so as not to continue to impede upon my

right to petition fairly on the same issues he seeks to force the Court to rule on by threat towards

members of the courts, their wives or parties. Whitehouse threatened sanctions against judges

and congress has threatened their wives to affect the outcome of a Trump case, and in my case,

he commandeers the court to rule against me on issues in my two cases pending before this court.

Congressman Jordan subpoenaed a NY Judge’s kid to affect the outcome of a Trump case.

Congress subpoenaed a party in a President Biden’s son Robert Biden’s case to affect the

outcome of a case to use against President Biden in favor of President Trump. State agents

attacked me and removed and concealed my pleadings and evidence in my favor to influence the

outcome of a case where I sued President Trump and sought to substitute current President Biden

for the same or similar conduct that substantially burdens my free exercise of religion by the

establishment of government religion in violation of US Am. I and the RFRA.

In recent cases Congress appears to abuse its power to violate the rights of other

claimants to petition fairly in matters of national importance relating to President Trump.

9

1

Congress has threatened and bullied the court joined in by executive backing by Biden which

affects my right to petition before an impartial not threatened, or defensive or unduly retaliatory

forum. I should not be unfairly punished for asserting my rights to petition fairly because outside

threats are occurring against the forum court with a pending decision on my case, the USSC.

Can the US Supreme Court call witnesses to prevent due process violations occurring

against me a party in a case by non-party person, Senator Whitehouse, to protect my First

Amendment right to petition fairly in accord with the 5th Amendment and to preserve the

impartiality of the courts to protect due process. So this Court’s members do not favor outcomes

that reduce the threats to their seats, their family or their beneficial interests as opposed to

applying the impartial application of the law to the facts of each case. I need time to make an

argument this court should be allowed to call Whitehouse even sua sponte without me so long as

opposing counsel may question him too.

I ask this court to please postpone a decision on this appeal beyond the conference date

9/30/2024 given the grave magnitude of the issues presented a court should decide, and

petitioners should be afforded to argue in an actual case and controversy before an impartial

forum. It should not be decided by the other two branches by force and threat which eliminates

freedom by commandeering the only branch that protects our freedoms form both private and

public entities. The issue is unique since trial courts usually call witnesses, but DE Chief District

Court Judge Justice Colm F Connelly called non-party witnesses to prevent fraud on the court in

DE Attorney Jimmy Chong’s case. So, this court may be able to do so too. The issue is unusual.

I do not have access to legal resources beyond google at this time. I do not even have access to a

1

In recent cases this Court reduced the power of state and US Attorney Generals from prosecuting gov officials

under 18 USC Sections 201 and 666. In Kelly v Trump I cited these very two statutes as a tool AG’s may use ti

prevent the overthrow. June 26, 2024, the U.S. Supreme Court held 6-3 in Snyder v. United States that a federal

statute, 18 U.S.C. § 666(a)(1)(B), does not criminalize “gratuities” to state and local officials

10

phone to call the law library, but it is necessary for the court to discern to preserve the rule of law

that sustains these United States from a schemed overthrow. I need a fair opportunity to petition

please. US Amend I, V.

I face loss of 1st Am rights and other irreparable injury if I am not afforded an

opportunity to fairly supplement my case.2 The reciprocal case arises based on DE Sup Ct’s

malicious intent to cover up its own misconduct in inciting attacks against me to cause me to

forgo Kelly v Trump in violation of my rt to pet fairly and in retaliation against me for my

private exercise of petitioning to sue former President Donald J. Trump under the Religious

Freedom Restoration Act, and the 1st Am Free exercise and establishment clause provisions to

alleviate a substantial burden his establishment of gov religion by a course of conduct and certain

executive orders caused upon my free exercise of religious belief. I am punished in this case for

suing Trump based on viewpoint of speech by petitioning to restrain a President’s conduct within

the purview of the Constitutional (“Const”) and statutory limits, where the President is unfairly

deemed above the law by immunity and the people a President harms, including me as a party of

one, are rendered below the law’s protection. US Am I, V, IV.3

There really is a scheme to overthrow the gov. The Ct recently errantly removed the

authority of the AGs to protect the entire government, and vitiated my rts as applied in a series of

2

As a Christian I believe business greed unrestrained by the just rule of law or love written on our hearts is

lawlessness leading to loss of eternal life on judgment day should people not be made clean of being the darkness.

As a Christian “Justice in the courts” is a command by God. Citing Amos 5:15. Jesus Christ says “justice, mercy and

faithfulness are more important laws.” Matthew 23:23. If God says protecting the rule of law by protecting the only

forum that may grant it as opposed to the mark of lawlessness called the mark of the beast by ruling by temptations,

threats like naughty Alexander Hamilton’s federalist 78, or economic force, than it is important to me. Hamilton is

wrong. Hamilton said a lie when he said the courts are the weakest branch. Fed 78. Laws saved my eternal life, and

should the courts grant just decrees this court may save lives, eternal lives and the government from dissolution for a

time of lawlessness harming humanity and misleading many to hell. These are my religious beliefs not meant to

offend but meant to express the dire situation. I believe the world is in. We need you to be the hero. I need a fair

opportunity to ask please.

3

Clinton v. Jones, 520 U.S. 681 (1997) (“Doctrine of separation of powers does not require federal courts to stay all

private actions against President of the United States until he leaves office. U.S.C.A. Const. Art. 3, § 1 et seq.”)

11

cases. By removing those with power to enforce the rule of law petitioners, including their

advocates US Attorney Generals and special counsel’s authority access to the courts the ct

removes its own authority and the rule of law. I seek to supplement the record to amend my

arguments based on new threats to the rule of law that occurred after filing my brief, but require

means and time.

On 7/1/24, this Ct held inter alias the Pres. is “absolutely immune” from criminal

prosecution for conduct in his official capacity in violation of EP by affording government

unchecked deference.4 This ct ruled other conduct is presumed immune.5 The Ct further held the

Pres powers stem from the Const or an act from Congress, while failing to note the Pres is

limited by both the Const and acts of Congress, especially criminal laws drafted to protect

4

The Ct also erred in Nixon v. Fitzgerald, 457 U.S. 731, 755-56 (1982)(“In view of special nature of president of the

United States's constitutional office and functions, president has absolute immunity from damages liability for acts

within “outer perimeter” of his official responsibility.”). The Ct was wrong at Id. At 56-57 (“rule of absolute

immunity for the President will not leave the Nation without sufficient protection against misconduct on the part of

the Chief Executive.38 There remains the constitutional remedy of impeachment.39 In addition, there are formal and

informal checks on Presidential action that do not apply with equal force to other executive officials. The President

is subjected to constant scrutiny by the press. Vigilant oversight by Congress also may serve to deter Presidential

abuses of office, as well as to make credible the threat of impeachment.40 Other incentives to avoid misconduct may

include a desire to earn reelection, the need to maintain prestige as an element of Presidential influence, and a

President's traditional concern for his historical stature.” This Ct was further wrong at Id. at 757. (“The existence of

alternative remedies and deterrents establishes that absolute immunity will not place the President “above the

law.”41 For the President, as for judges and prosecutors, absolute immunity merely precludes a particular

private remedy for alleged misconduct in order to advance compelling public ends.”). DC Ct is wrong in

Blassingame v. Trump, 87 F.4th 1 (D.C. Cir. 2023)(“President's actions do not fall beyond outer perimeter of official

responsibility merely because they are unlawful or taken for forbidden purpose; rather, President's official immunity

insulates all of his official actions from civil damages liability, regardless of their legality or his motives.”). DC Ct is

also wrong in Carroll v. Trump, 88 F.4th 418, 422 (2d Cir. 2023)(“ Presidential immunity is a defense that stems

from “the President's unique office, rooted in the constitutional tradition of the separation of powers and supported

by our history,” and entitles the President to “absolute ... immunity from damages liability for acts within the outer

perimeter of his official responsibilities.”) Immunity is unconst removing Const checks on an unbalanced branch.

5

But see, Trump v. Vance, 591 U.S. 786, (2020) (“In contrast to a king, who is born to power and can “do no

wrong,” the President of the United States is “of the people” and subject to the law.”) Marbury v Madison, 5 US 137

(1803) (“The very essence of civil liberty certainly consists in the right of every individual to claim the protection of

the laws, whenever he receives an injury. One of the first duties of government is to afford that protection. In Great

Britain the king himself is sued in the respectful form of a petition, and he never fails to comply with the judgment

of his court. In the 3d vol. of his Commentaries, p. 23. Blackstone states two cases in which a remedy is afforded by

mere operation of law. In all other cases," he says, "it is a general and indisputable rule, that where there is a legal

right, there is also a legal remedy by suit, or action at law, whenever that right is invaded.")

12

fundamental rts of the people the 1st Am rt to petition and fair oppty to be heard before vitiation

of Const rts and other liberties, not limited to a fair proceeding, the right to vote, to discern who

is the President as a matter of law, not as a matter of mob lawless reign or threat of violence.

This Ct granted what is not the Ct’s to give the removal of Const checks that balance a Pres’s

authority within the purview of Const limits. Pres is unconst given a sword to execute the law

and a shield to defeat Const challenges brought by 1. the lawmakers in criminal statutes enacted

to protect the people’s rt to pet, vote, and other Const rts, 2. ct’s check upon the Pres for

violation of criminal laws that appear to violate the citizen’s fundamental rts and others

safeguards, the AG’s check to safeguard victim’s of a Pres’s criminal violation of Const liberties,

the AG’s check to prosecute without bias against the citizens and favoritism toward the

government, specifically the Pres, and my right to petition to defend my religious exercise of

belief in Jesus Christ without persecution incited by a Pres. Trump.

The shield which limits the Pres’s authority is meant to safeguard the people not to make

one person above the law in violation of EP and clear precedent. This Ct has made Trump not

only above a king but above God, by teaching the world he is his own judge on alleged official

conduct unrestrained by the law to protect other people’s Constitutional legal fundamental rts or

authority, including other individuals besides the Pres the AG are charged to protect or defend.6

In re Murchison, 349 U.S. 133, (1955) (“No man can be a judge in his own case, and no man is permitted to try

cases where he has an interest in the outcome.”); See, https://en.wikipedia.org/wiki/Nemo_iudex_in_causa_sua

“Nemo judex in causa sua (also written as nemo [est] judex in sua causa, in propria causa, in re sua or in parte sua)

is a Latin legal authority that translates as "no one is judge in their own case". Originating from Roman law, it was

crystallized into a phrase by Edward Coke in the 17th century and is now widely regarded as a fundamental tenet of

natural justice and constitutionalism. Vermeule 2012, p. 386. (Other Cit omitted Wickepedia) “It states that no one

can judge a case in which they have an interest. In some jurisdictions, the principle is strictly enforced to avoid any

appearance of bias, even when there is none: as Lord Chief Justice Hewart laid down in Rex v. Sussex Justices,

"Justice must not only be done, but must also be seen to be done"” Id. R v Sussex Justices, ex parte McCarthy,

[1924] 1 KB 256, [1923] All ER 233, Datar, Arvind (18 April 2020). "The origins of "Justice must be seen to be

done"". Bar and Bench - Indian Legal news. Retrieved 11 September 2023.

See, Isaiah 14 to see how the Ct has made a Pres like the devil to be his own Judge and God, reflecting the image of

lawlessness leading to hell if unrestrained by the just rule of law by the courts or written in the hearts of men in the

form of love per Jeremiah 31. See, Sirach 8:14 (“Contend not at law with a judge, for he will settle it according to

6

13

While I think the law should be equally applied to discern preemption under Art II under certain

circumstances, it is not warranted here. An extension of current case law should discern whether

Due process is violated by granting Trump authority to be his own judge unrestrained by the

courts, unconstitutionally depriving petitioners of the 1st Am rt to pet before vitiation of

Constitutional rts or other claims.

It is for the ct to consider whether the Pres violates DP by being his own judge given his

personal interest in the outcome of 939, and other criminal cases, including winning elections as

a candidate in light of multiple criminal cases where the courts should discern treason, high

crimes and misdemeanors and whether a President should be on the ballot, not the one alleged to

commit crimes, the Pres or a partial unfair biased horse and pony political forum the congress

and where the people, me as applied, are deprived of the rt to pet fairly in accord with DP or

other Const rt7 I disagree with Trump v. Norma Anderson, where this Ct held it doesn’t matter if

states found Trump committed treason and high crimes, they must keep him on the ballots and

Trump is above the impartial rule of law and the provisions under Section 3 of the 14th Am. This

Ct errantly made Trump free to entice congressmen to prevent impeachment for crimes and

treasons through encouraging him to rule by temptations, lusts, by helping agendas in a horse

and pony forum congress unrestrained by the just rule of law by the false assertion of this Court

his whim.” causing lawless lusts and great injustice). Allowing Pres to be his own judge grants partiality to self not

the impartial application of the constitution to the rule of law to protect the lives and liberty of all, not merely of one

person with absolute discretion and a license to commit crime.

7

Williams v. Pennsylvania, 579 U.S. 1, (2016) (“Due process guarantees an absence of actual bias on the part of a

judge.” U.S.C.A. Const.Amend. 14.); Id at 8–9, (2016) Citing Murchison, 349 U.S., at 136–137, (“This objective

risk of bias is reflected in the due process maxim that “no man can *9 be a judge in his own case and no man is

permitted to try cases where he has an interest **1906 in the outcome.” Id., at 136, 75 S.Ct. 623.); Caperton v. A.T.

Massey Coal Co., 556 U.S. 868, (2009) (“In deciding whether probability of actual bias on part of judge is too high

to be constitutionally tolerable, court's inquiry is objective one, that asks not whether judge is actually, subjectively

biased, but whether average judge in judge's position is likely to be neutral, or whether there is unconstitutional

potential for bias.”) Id. (“There is serious risk of actual bias, based on objective and reasonable perceptions, when

person with personal stake in particular case had significant and disproportionate influence in placing judge on case

by raising funds or by directing judge's election campaign when case was pending or imminent.”)

14

that immunity is the law, meaning like the devil the President is lawless unrestrained by anyone

in his official conduct unlimited by other preempting Constitutional provisions. 8

While the ct has the power of saying what the rule of law is, I and other petitioners,

including my opponent have the Const legal authority under US Am I, V or IX in an Art III case

or Controversy to argue and persuade the Ct as to what the Const as rule of law is, especially

when the Court is mistaken, and where its decision was based on protecting its personal interest

from attacks. These rts should not be infringed upon by the government through the US Supreme

Cts’ errant decisions or by gov. attacks against petitioners, witnesses, judges or their family to

affect the outcome in cases.

When the Ct gets it wrong, it may be corrected through the petition. In order to uphold

the fair administration of justice the ct must allow petitions even against the ct to correct errors

and mistakes and to preserve the rule of law and equal Protections for all not some, including

Trump who is rendered above the law by immunity. Wrongs cannot be righted when petitions

are obstructed and fair opportunity to be heard are denied. Injustice is the law when the USSC

says immunity or denial of 1st Amendment rights including the petition is now the law. The rule

of law is degraded when the rt to pet fairly are denied. US Amend I, V.

CONCLUSION: Wherefore a pray this Ct grants this motion.

Federalist 10 “No man is allowed to be a judge in his own cause, because his interest would certainly bias his

judgment, and, not improbably, corrupt his integrity. With equal, nay with greater reason, a body of men are unfit to

be both judges and parties at the same time; yet what are many of the most important acts of legislation, but so many

judicial determinations, not indeed concerning the rights of single persons, but concerning the rights of large bodies

of citizens? And what are the different classes of legislators but advocates and parties to the causes which they

determine? Is a law proposed concerning private debts? It is a question to which the creditors are parties on one side

and the debtors on the other. Justice ought to hold the balance between them.” When courts balance Constitutional

authority and restraints it must uphold the express purpose this Country was founded to protect life and liberty not to

sacrifice it for the mark of the beast, lawless lusts leading to hell including avoidance of costs, material gain,

convenience, comforts, positions, power and other vain desires if not restrained or repented of.

Federalist 80 “No man ought certainly to be a judge in his own cause, or in any cause in respect to which he has the

least interest or bias. This principle has no inconsiderable weight in designating the federal courts as the proper

tribunals for the determination of controversies between different States and their citizens.”)

8

15

SUPREME COURT

Justice Ketanji Brown Jackson says she's open to an 'enforceable' Supreme

Court ethics code

“A binding code of ethics is pretty standard for judges, and so I guess the question is 'Is the Supreme Court any different?'" Justice Ketanji

Brown Jackson said in a CBS News interview.

Get more news

on

Sept. 1, 2024, 11:48 AM EDT

By Alexandra Marquez

Supreme Court Justice Ketanji Brown Jackson said she is open to proposals to implement an "enforceable code" of ethics for

justices and lamented the court's presidential immunity decision in an interview that aired Sunday.

"A binding code of ethics is pretty standard for judges, and so I guess the question is 'Is the Supreme Court any different?'"

Jackson asked in an interview on "CBS News Sunday Morning" about her new memoir, adding, "I guess I have not seen a

persuasive reason as to why the [Supreme] Court is different than the other courts."

The issue of ethics on the Supreme Court has entered the public sphere in recent years as stories have emerged about

justices' not disclosing certain lavish gifts on their ethics disclosure forms.

For example, Justice Clarence Thomas accepted lavish gifts and trips from GOP megadonor Harlan Crow. None of them were

officially disclosed before ProPublica's reporting about on the trips and Crow last year.

Asked directly about the trips, Jackson said she was "not going to comment on other justices' interpretations of the rules or

what they're doing."

President Joe Biden proposed a slate of reforms this summer, including a call for Congress to make the Supreme Court

subject to an enforceable code, including the same disclosure rules for gifts, financial dealings and political activities other

federal judges face.

While the proposal included an enforceable ethics code for the court, Jackson declined to say whether she supported a

specific proposal on the table.

"I am considering supporting it as a general matter. I'm not going to get into commenting on particular policy proposals, but

from my perspective, I don't have any problem with an enforceable code," Jackson said.

She also spoke about a recent case in front of the Supreme Court regarding presidential immunity for official acts in office.

The court ruled in July that former President Donald Trump has immunity for some of his conduct as president in his federal

election interference case but may not for other actions.

Jackson dissented in that case, writing that the decision “breaks new and dangerous ground.” She told CBS News on Sunday

that she was "concerned about a system that appeared to provide immunity for one individual under one set of

circumstances when we had a criminal justice system that had ordinarily treated everyone the same."

Asked whether she was prepared to potentially decide the outcome of the presidential election or settle any potential

disputes related to it, Jackson laughed, saying she is "as prepared as anyone can be."

"I think there are legal issues that arise out of the political process, and so the Supreme Court has to be prepared to respond

if that should be necessary," she added.

Alexandra Marquez

Alexandra Marquez is a politics reporter for NBC News.