Petition for Writ of Certiorari — Palani Karupaiyan, Petitioner v. Lee Solomon, et al.
Supreme Court briefMay 16, 2023
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23°
I
i
P,JV
In The
SUPREME COURT OF THE UNITED
STATES
PALANI KARUPAIYAN, et al
Petitioners
v.
LEE SOLOMON, et al - Respondents
On Petition for a Writ of Certiorari
to the United States Court of Appeals
for the Third Circuit before judgment is
entered in that Court (23-1788)
PETITION FOR A WRIT OF
CERTIORARI
Palani Karupaiyan.
Pro se, Petitioner,
1326 W William St,
Room#2.
Philadelphia, PA 19132
212-470-2048(M)
filed
may 1 6 2023
1
I.
Questions Presented
Petitioner’s prayed reliefs were
i)
ii)
iii)
iv)
v)
vi)
National importance of having the US
Supreme Court decide or conflict with
USSC ruling, or importance of similarly
situated over millions of citizens or the first
impression is raised at USSC.
Petitioners’ property rights under 42USC§
1982 and Hindu Successive Act were denied
when USSC ruled in
Sullivan v. Little Hunting Park, Inc., 396
US 229-S.Ct 1969@237
“Section1982 f42 USC§19821 covers the
right "to inherit, purchase, lease, sell. hold,
and convey real and personal property."
Local Govts/Foreign
Govt
violating,
Parents rights (14th amendment) which were
ruled by USSC under Troxel v. Granville.
530 US 57 and Washington v. Glucksberg,
521 US 702, 720.
Local Govts illegally taken away Petitioners
property without Jury trial.
Local Govts illegally issued arrestfedl
warrant without Jury trial.
NJ Court violated the Indian Family Court
Order
Further/additionally Petitioner’s prayed over
30 reliefs were as Writ of Mandamus or Prohibition or
alternative so the questions were part of three test
condition requirement of the Writs.
l
11
II.
Parties to the Proceeding
Petitioners: Palani Karupaiyan, PP, RP,
Santhosh Subramaniyan
RESPONDENTS: L. NAGANDA, individually and in
his official capacity as Owner of Naga Law Firm;
NAGA LAW FIRM; J. RAMYA; P. JAYABALAN; J.
RANJEETHKUMAR; ARUL THIRUMURUGU;
ATLANTIC REALTY DEVELOPMENT CORP;
MIDDLESEX MANAGEMENT INC; OAK TREE
VILLAGE; DAVID HALPERN, individually and in
his official capacity as CEO, Owner of Atlantic
Realty Development Corp, Middlesex Management,
Oaktree Village; D&G TOWING; GLENN
STRAUBE, individually and in his official capacity
as owner of D&G Towing;
MARCIA SILVA, individually and in her official
capacity as Judge of the Superior Court, Middlesex
County, NJ; JUDGE CRAIG CORSON, individually
and in his official capacity as Judge of the Superior
Court, Middlesex County, NJ;
JERALD COUNCIL, individually and in his official
capacity as Judge of the Superior Court, Middlesex,
NJ;
STUART RABNER, individually and in his official
capacity as Chief Justice of Supreme Court of NJ;
JAYNEE LA VECCHIA, individually and in her
official capacity as Justice of Supreme Court of NJ;
BARRY T. ALBIN, individually and in his official
capacity as Justice of the Supreme Court of NJ;
ANNE M. PATTERSON, individually and in her
official capacity as Justice of the Supreme Court of
NJ;
FAUSTINO J. FERNANDEZ-VINA, individually and
in his official capacity as Justice of the Supreme
Ill
Court of NJ; LEE A. SOLOMON, individually and in
his official capacity as Justice of the Supreme Court
of NJ; WALTER F. TIMPONE, individually and in
his official capacity as Justice of the Supreme Court
of NJ;
ALLISON E. ACCURSO, individually and in her
official capacity as Judge of Appellate Division of NJ;
PATRICK DEALMEIDA, individually and in his
official capacity as Judge of the Appellate Division of
NJ;
JOSEPH L. YANNOTTI, INDIVIDUALLY and in his
official capacity as Judge of the Appellate Division of
NJ;
GLENN GRANT, individually and in his official
capacity as Administrative Director of the Courts of
the State of New Jersey;
COUNTY OF MIDDLESEX;
STATE OF NEW JERSEY; TOWNSHIP OF
EDISON,
Sam Joshi individually and in his official capacity as
Mayor of Edison Township of NJ , Rajesh Khullar,
Raman Khullar, Tania Khullar, Shalimar Group of
Restaurants
III.
Related Case(s)
USSC Docket 22-1100
Palani Karupaiyan v Township of Woodbridge et al.
(USCA-3rd Cir -22-2949)
IV
IV.
Table of Contents
I. Questions Presented...........
i
II.
Parties to the Proceeding
ii
III. Related Case(s)..................
hi
IV. Table of Contents.............
IV
V.
x
Table of Authorities
VI. Petition for Writ(s) of Certiorari .... 1
VII. Opinion(s)/orders/Judgment(s)
BELOW (from Dist Court/USCA3)............ 1
VIII. Jurisdiction...................................... 1
IX. Constitutional and Statutory
Provisions involved................................... 2
X.
Statement of the Case....................... 2
a)
At District Court Proceeding...................... 2
b)
At USCA 3rd Cir. Proceeding......................... 3
XI. Reasons for Granting the Writs the
Writ(s).......................................................... 3
a)
Grant Children Custody, Invalidated
Judgement of divorce-JOD (App2.17),
Invalidating Final Restraining Orders FROs
V
App2.1,11, and Validate Indian family Court
Order App2.26,28......................................................... 3
b)
Issue an order to Indian Supreme Court to
DISMISS AND CLOSE THE DOCKET IS OJASWA
PATHAK vs. UNION OF INDIA, Dkt#
W.P.(C)No.250/2019................................................. 4
c) Writ against NJ for......................................... 6
1.
Order that NJ govt/Local Govt(s) and Chief
Justice of NJ Supreme Court should not
appoint/Promote NJ Supreme Court justice, NJ
appellate Court Judge, and Administrative
Director of the Courts of NJ Courts, any judicial
officers including Municipal Judges, and appoint
22 NJ Supreme Court Justices thru Collegium
Process. And Invalidate the NJ Supreme Court
justices/NJ appellate Judges who were
appointed/ promoted by NJ govt/NJ Supreme
Court Chief justice................................................... 6
2.
LEFT BLNK.................................................. 9
3.
Shared Children Custody and NJ should
not violate Parents disability in grating children
Custody..................................................................... 9
4.
Acceptable form(s) of Child Support and
Save the child support money to Child need.......9
5.
i) Family Properties inheritance to
Children, ii) No lawyer fee from family
properties, Disclose/open-to-public family Ct
lawyer fee...............................................................
10
6.
NJ family Court records should not be
under seal and No Property matter/financial
matter disclosure discussed in Family Court. ..11
d)
Writ against NJ Judicial authorities. ... 12
VI
7.
i) NJ Judicial Authorities involve in family
case should get mental fitness certificate yearly,
ii) NJ Judicial authorities’ Yearly Financial
disclosure Statement to be Open to public. iii)
NJ Judicial Authorities to file timesheet for every
15 minutes of their duty.................................. 12
8.
Order NJ S.Ct to provide a copy of
Ramya’s Response brief................................. ,13
9.
NJ S.Ct should not hire proxy peoples
India file case in Indian S.Ct to strike down the
Indian family law based on Petitioner Indian
family Court..................................................... 13
10. Left blank............................................... 14
E)
AGAINST NJ.............................................................
14
11. i) Trial by Juries in family Courts, ii)
Strike down lawless family Court and create
Civil family law iii) Equal rights to men in
family Court..................................................... 14
12. Consolidate the NJ family Court (lawless,
kangaroo Court), NJ Law division civil Court
15
and Landlord/Tenant Court.
13. i) No gun carrying Police involve in family
matter, ii) No arrest to the people who need
medical treatment, iii) no township police
16
overtime
14. Wipeout the FROs/arrest/jailing records. 17
15. 15 is left blank........................................... 18
16. Deduct 20% from NJ Law makers to pay
the Petitioners loss............................................. 18
17. Move the Middlesex County’s Court and
Childsupport probation employees in to NJ
payroll.................................................................. 18
Vll
18. Order to cut 80% of federal funds to NJ
and its Local govt.............................................. 19
f) Writ(s) against Middlesex County, NJ..... 20
19. Middlesex County NJ to pay $42 million
dollar for collecting child support illegally....... 20
g)
Against all Individual
defendants/respondents................................... 21
20. i) Jailing L. Naganda, P. Jayabalan; J.
Ranjeeth Kumar, Arul Thirumurugu, David
Halpern, Marcia Silva, Craig Corson, Jerald
Council, Stuart Rabner, Jaynee la Vecchia,
Barry t. Albin, Anne m. Patterson, Faustino j.
Fernandez-Vina, Lee a. Solomon, Walter f.
Timpone, Glenn Grant, Allison e. Accurso,
Patrick Dealmeida, Joseph 1. Yannotti for 25
years AND ii) protection/restraining order
against these Individuals and iii) Remove NJ
S.Ct Justices, NJ appellate/family Court Judges
defending the Petitioner and iii) Invalidate all
the orders signed by these NJ judicial
21
authorities
h)
Writs against the Landlord respondents
22
21. Money Relief to Children by Landlord.... 22
22. Landlord to pay $100 million to Petitioner
22
for leasing inhabitability apartments......
23. Order that assign the ownership of
Landlord any and all business including Atlantic
reality, ownership of any and all rental
apartments, Landlord Halpern’s ownership
building to the Petitioners.........................
23
i) Writs against Lower Federal Courts......25
Vlll
24. Order lower Court (Dist Court) to run the
case as combined civil and criminal case when
remanded
25
25. Petitioner pray USSC that it should vacate
the Sua sponte dismissal of complaint............. 25
26. Appoint i) Guardian ad litem and/or pro
bono attorney..................................................... 26
j)
Additional..............................................i...... 29
27. Order for each respondents to pay the
Petitioner(s) for each count of discrimination,
wrongdoings, injuries and so on....................... 29
28. Order the Local Govts and NJ Judicial
Authorities to pay as per the exhibits attached to
30
the Minor Petitioner marriage expense..
29. Petitioner(s) pray Order that each
defendant to pay for Petitioners’ effort, pain and
suffering, expenses, litigation cost or pain and
suffering by litigation.
31
k)
Writs against Landlord respondents (ii) 32
30. Order the Landlord Atlantic to pay the
Petitioners Karupaiyan, RP and PP for violating
Conjugal/cohabiting rights.
32
31. Order the landlord to pay $250 per day for
32
illegally towing the camping Eurovan
32. Order the each NJ Judicial authorities, NJ
and Middlesex county respondents to pay $50
million for Children Education and marriage
33
expense
33. Order Ranjeeth to pay $600 million dollar
to the petitioner Karupaiyan
33
IX
34. Order to i) NJ that NJ should
standardized the NJ’s Municipal Mayors and
councilmen's salary........................................... 34
35. Order that NJ Judicial authorities
respondents and Naga to pay $60 million per
months violating petitioners conjugal/cohabiting
rights...............................................................
34
36. Order NJ govt/Middlesex County, NJ
Judicial authorities and Landlord to pay
following money for false arrest/false jailing. ...34
37. Order that permanent protection order
against Khullars and Owner of Shalimar..... 35
38. Order that United States should enact
United States family....................................... 36
39. Prose based additional relief(s)............ 36
XII.
CONCLUSION
37
X
V.
Table of Authorities
Cases
320 U.S. 796, 64 S.Ct. 263, 88 L.Ed. 480 (1943).
3
Babb v. Secretary. dept. Of veterans affairs. 992 F. 3d
1193 - USCA11- 2021....................................
6
Babb v. Wilkie. 140 S. Ct. 1168- Sup. Ct 2020
6
Bavron v. Trudeau. 702 F.2d 43, 45 (2d Cir. 1983)..26
Beck v. Beck, 432 A. 2d 63 - NJ: Supreme.............. 3
Bethel School District No. 403 Et Al. V. Fraser, A
Minor, et al. 478 U.S. 675 (1986)...................... 26
Board Of Education Of The Westside Community
Schools (Disk 66) et al. V. Mergens, By And
Through Her Next Friend, Mergens, Et. 496 U.S.
226 (1990),.............................................................. 27
Bovadiian v. Cigna Companies. 973 F. Supp. 500 Dist. Court, D. New Jersey 1997.......................... 31
CJLG v. Barr, 923 F. 3d 622 - Court of Appeals, 9th
28
Circuit 2019
Cohen v. Office Depot. Inc.. 184 F. 3d 1292 - Court of
Appeals, 11th Circuit 1999.................................... 25
Crooker v. United States Dep't of Justice, 632 F.2d
916, 921 (1st Cir. 1980))......................................... 31
Cunningham. 664 F.2d at 387 n. 4............ ............. 31
DeBold, 735 at 1043.................................................. 31
Hanna v. Plumer. 380 US 460,470- Supreme Court
25
1965
Hobby Lobby Stores. Inc, v. Sebelius. 568 US 1401 Supreme Court 2012................................................ 1
XI
Hodge v. Police Officers. 802 F. 2d 58 - Court of
Appeals, 2nd Circuit 1986...................................
26
Hohn v. United States. 524 US 236 - Supreme Court
1998.................................................................................. 1
In re Gault. 387 U.S. 1, 36-37, 87S.Ct. 1428, 18*632
L.Ed.2d 527 (1967)..................................................... 28
Jacob WINKELMAN, a minor, by and through his
parents and legal guardians. Jeff and Sandee
WINKELMAN. et al.. v. PARMA CITY SCHOOL
DISTRICT. 550 U.S. 516- 127 S.Ct. 1994 (2007).27
KARUPAIYAN v. SIANO | 53 A.3d 662 (2012)...... 20
Maclin v. Freake, 650 F. 2d 885 - Court of Appeals.
7th Circuit 1981........................................................... 26
Montgomery v. Pinchak. 294 F. 3d 492 - USCA, 3rd
Cir. 2002
26
OJASWA PATHAK vs. UNION OF INDIA. Dkt#
W.P.(C) No. 000250 - / 2019
4, 6, 14
Osei-Afrive v. The Medical College of Pennsylvania.
937F.2d 876 (3d Cir. 1991)
26, 28
Robidoux v. Rosengren. 638 F. 3d 1177 - Court of
Appeals, 9th Cir 2011.............................................. 28
Rosado v. Wyman. 397 U. S. 397, 403, n. 3 (1970) ....1
Salahuddin u. Cuomo. 861 F. 2d 40 - Court of
Appeals, 2nd Circuit 1988......................................... 25
Spindel v. Soindel. 283 F. Supp. 797 - Dist. Court,
ED New Yorkl968...................................................... 3
Sullivan v. Little Hunting Park. Inc.. 396 US 229 Supreme Court 1969
i, 10
Tabron v. Grace. 6 F. 3d 147 - Court of Appeals, 3rd
Circuit 1993
26
Xll
Title VII................................................................
24
Troxel v. Granville. 530 U.S. 57 (2000)............ i, 36
Troxel u. Granville, 530 U.S. 57 (U.S. 2000)....
28
Washington v. Glucksberg. 521 U. S. 702, 720..
i
Washington v. Glucksberg. 521 U.S. 702 (1997)
28
Statutes
28 U. S. C. § 1651
28 U.S.C. § 1654 .,
1
26
42U.S.C § 1982..
i
42 US Code § 1982
10
All Writs Act.........
1
Constitutional Provisions
14th amendment...............
28
Article VI. Paragraph 2....
7
1
VI.
Petition for Writ(s) of Certiorari
Petitioner respectfully prays that a Writ of
Certiorari issue to review the opinion/judgment/
orders of US Dist Court for NJ (23-cv-844-SDW) below
and USCA3 opinion/orders on 23-1788
VII.
Opinion(s)/orders/Judgment(s)
BELOW (from Dist Court/USCA3)
1. US Dist. Court for NJ WHEREAS OPINION
03/6/2023 (ECF-5) App.04
2. Dist. Court For NJ’s Sua Sponte WHEREAS ORDER
dismiss the complaint 3/6/2023 (ECF-6) App.14
3. Dist. Court’s Order Grating forma pauperism for
Appeal granted 03/23/2023, ECF-10. App.14
4. US Dist Court’s opinion and order for denying
motion for reconsideration ECF-18. 19 05/11/2023.
App.15,17.
Hon. Susan D. Wigenton USD J; Hon. James B.
Clark, USMJ
5. USCA3’s Osei Order. 05/5/2023 App.18. (Vacated 05/
10/2023).
VIII.
Jurisdiction
In Hohn v. United States. 524.US.236-S.Ct
1998<&258(“Rosado v. Wyman. 397.US.397,403,
n.3(1970)(a Court always has jurisdiction to
determine its jurisdiction)).
Hohn@264(“We can issue a common-law writ of
certiorari under the All Writs Act. 28 USC§1651)
Hobby Lobby Stores. Inc, v. Sebelius. 568 US 1401 —
S.Ct 2012@643
The only source of authority for this Court to issue an
injunction is the All Writs Act, 28 USC.§1651(a) and
Following a final judgment, they [Petitioner] may, if
necessary, file a petition for a writ of certiorari in this
Court.
1
2
Petitioner filed timely Notice of Petition for Writ of
Mandamus [3/20/23] App.01 and further amended it
on 05/09/2023, 05/11/2023. App.2-3.
The appeal is Docketed [23-1788] and pending
with USCA3.
US Supreme Court has Jurisdiction under
S.Ct. RULE 11 and 28 USC§2101(E).
IX.
Constitutional and Statutory
Provisions involved
Fed.R.Civ.P. 8(a)(2) and (3), 8(f), 12(e), 17, 54(c)
1st 4th, 5th, 8th, 14th amendment
Article VI. Paragraph 2. Constitution
42 USC§1982,1983,1988
Hindu Marriage Act, 1955-Amended
Hindu Succession Act, 1956 -Amended
Indian family Court order (App2.26.28)
Indian penal codes.
Comparative Approaches of Supreme Courts of the
World’s Largest and Oldest Democracies
-By Justice Hon. Stephen Breyer of US Supreme
Court, Chief Justice Hon. NV Ramana of Indian
Supreme Court, and William M Treanor, Dean of
Georgetown University Law Centre Dated: April 11,
2022
The NJ Law against Discrimination (NJLAD) and
more
X.
Statement of the Case
a) At District Court Proceeding
Plaintiffs filed forma pauperis and civil action against
Respondents. Plaintiff requested civil action to be
combined with Criminal action. Charges were
ranging from bicycles thief to NJ Chief Justice
3
violating civil, parental and constitutional rights and
so on.
Before serving the complaint, Dist Court entered
(Sua Sponte). WHEREAS OPINION AND ORDER
to dismiss the complaint with prejudice [3/6/2023]
App.4,14
Plaintiff filed Notice of Petition for mandamus
r3/20/20231App.0f
b) At USCA 3rd Cir. Proceeding
On 05/5/2023, USCA3 issued Osei order. App App.18.
05/9/2023 USCA issued Stay order App.20, next days
vacated. Dkt#5, Dkt#ll.
Final order/Judgment from USCA3 is pending.
XI.
Reasons for Granting the Writs the
Writ(s)
a) Grant Children Custody, Invalidated
Judgement of divorce-JOD (App2JL7),
Invalidating Final Restraining Orders
FROs App2.1.11. and Validate Indian
family Court Order App2.26.28.
Test-2. 1) Petitioner have best interest of
Evaluation.(App2.43,44), Respondent Ramya hold
the custody/FROs/JoD by Fraud-on-Court/Judicial
fraud.(App2.9,10)
Test-3. DBeck v. Beck. 432 A. 2d 63 - NJ: S.Ct
1981,@499, Children’s best interest is polestar for
grating children custody
2)Spindel v. Snindel.283F. Supp.797 - D.Ct,
EDNY1968@811
..For what the judgment was rendered is not essential.
It is that it was obtained by fraud, and hence unjust to
hold and use, and, because it is, the Court has
jurisdiction." 78 F.@835 320 US 796, 64 S.Ct. 263, 88
L.Ed. 480 (1943).
4
So Petitioners pray this Court should invalidate JOD
and FROs granted by NJ, and validating Indian
family Court reconciliation order App2.24.26. Grand
the child custody to Petitioner until Ramya should
appear in the Indian family Court.
b) Issue an order to Indian Supreme Court
TO DISMISS AND
CLOSE
THE DOCKET IS
O JASWA PATHAK vs. UNION OF INDIA,
Dkt# W.P.(C)No.250/2019
Test-2. When this Petitioner filed US Dist Court case
in Newark, NJ, docket under this petitioner request
to review, NJ Supreme Court justices and landlord
respondents hired proxy peoples India to file case in
India Supreme Court to strike down the section of
Indian Family law based on the Indian family Court
reconciliation order Ann2.24 was granted to this
petitioner.
The docket in Indian Supreme Court OJASWA
PATHAK vs. UNION OF INDIA. Dkt#W.P.(C)No.
250/2019.
When Pathak is active, not closed, petitioners’ case in
US Federal Court delayed, petitioner is suffering
more than 7 years which is inhuman loss, damage,
injury to the petitioners.
The NJ S.Ct activity is uncivilized.
Test-3. NJ S.Ct doing above such, the case is delayed
unnecessarily. Three times NJ S.Ct pressured Indian
S.Ct, here case is delayed 3 years. Totally the
Petitioners suffered which no human Being should
suffer in civilized society and wasting time in the US
federal Court. So this prayer should be granted.
Striking down the Indian family law in-part against
the order Petitioner got from India is not going to be
5
nullify the order past 10 years. Approx. 10 years ago,
one India lady got reconciliation order from India
which is not going to be null now. She might have two
more kids now. Who is going to step in their home and
tell husband and wife get out and live separate.
Petitioner have gave a Indian family Court petition in
English translated as they needed so they knew what
is going to be out come. They are corrupt and forever
corrupt. Only truth and justice should survive.
When OJASWA PATHAK is not closed and
kept on wasting time of Federal Court, this Court
issue order to Indian S.Ct to dismiss and close the
docket in Indian S.Ct
In the past, there was a scam in Indian parliament
question for cash. When the matter went to Indian
supreme Court which warned the Member of
parliament due to proxy activiy on the parliament.
Same/Similar situation in the Pathak case, these
proxy peoples were hired by this case respondents
including NJ judicial authorities.
These respondents hire the people around the
petitioner to talk over the phone and records the phone
call. Lot of people called petitioner and threaten to
withdraw district Court complaint. Few weeks ago,
one of petitioner’s past co-worker[609-787-5056/732242-2882] called that these NJ, Judges respondents
were ready to pay $200k, if he allowed this petitioner
to have sex with his wife. These respondents have
multiple to . defend the petitioner so they hire proxy
people to delay the case. Another instant, namely
Khan[848-234-8217] wanted the petitioner to contract
marry his wife for her green card. He said that This
idea and petitioner phone number was given by
landlord respondents, (obstruction-of-justice, where
all prayer tobe granted)
Especialy the proxy Pathak. is-to delay this
case, wasting time of US-federal Courts.
6
For any and all reasons stated above, petitioners
pray this Court issue an order to Indian Supreme
Court to dismiss and close the is OJASWA PATHAK
vs. UNION OF INDIA. Dkt#WP(C)No 250/2019.
c) WRIT AGAINST NJ FOR
1. Order that NJ govt/Local Govt(s) and Chief
Justice of NJ Supreme Court should not
appoint/Promote NJ Supreme Court justice,
NJ
appellate
Court
Judge,
and
Administrative Director of the Courts of NJ
Courts, any judicial officers including
Municipal Judges, and appoint 22 NJ
Supreme Court Justices thru Collesium
Process. And Invalidate the NJ Supreme
Court justices/NJ appellate Judges who were
appointed/ promoted by NJ govt/NJ Supreme
Court Chief justice.
Test-2. When the case/related case under
subjudiced, NJ S.Ct Chief Justice appointed/
promoted the NJ S.Ct justice, NJ appellate Court
Judges, Administrative director of the Courts of NJ
Courts.
Also When the case/related case is under
subjudiced NJ govt appointed Fabiana PierreLouis as NJ S.Ct Justice and NJ appointed NJ
S.Ct justices Wainer Apter and Douglas
Fasciale. These appointment/promotions
violated the ruling by age, gender (Title VII), in
Babb v. Wilkie. 140 S.Ct. 1168 - S.Ct 2020 and
Babb v. Secretary, dept. Of veterans affairs. 992 F.
3d 1193 -USCA11- 2021
Test-3. Under said Supremacy Clause this Court
has power to enforce the federal law and rules and
ruling.
7
Article VI, Para-2 Constitution (Supremacy
Clause). It establishes that the federal constitution,
and federal law generally, take precedence over
state laws, and even state constitutions.
In Comparative Approaches of Supreme Courts
of the World's Largest and Oldest Democracies, by
Justice Stephen Breyer of USSC, CJI NY
Ramana,(4/11/2022), CJI said that Judge
promoting Judge is not true democracy.
In fact Judge or Govt prom ote /appoint Judge is not
true democracy.
Notably, historically, NJ Lawmaker appoint
relatives, friends as NJ S.Ct’s Justices personal
gain. Recently close to 100 Judges were forced to
resign who are relatives/friend to NJ Lawmaker
and because their retirement account had
disproportionate money.
Petitioner(s) prays an order that NJ
Govt/Local Govts/NJ chief Justice should not
appoint/promote Justice/Judge to NJ S.Ct, NJ
appellate Court, Admin. Director of NJ Court,
Municipal Judges including any Judicial officers
and these position should be appointed by
Collegium Process as CJI said
“Collegium process to appoint Judges most
democratic”
“On judicial appointments, CJI Ramana said that
although the government is a key stakeholder, when
the collegium reiterates its decision to appoint a
candidate, the government has no choice but to
comply with it”
‘Cannot get more democratic than this [Collegium
process]”
United States should have common Collegium to
appoint all its State’s Apex/S.Ct, Appellate Court
justices/Judges.
8
This Court should invalidated the all
appointment/promotion of NJ S.Ct Justice/
appellate Court Judges by NJ Govt and NJ chief
justice. Functioning of NJ S.Ct Justice, Appellate
Court justice should be independence of politician
said
which
violated
by
above
is
appointment/promotion. So collegium process is
needed in appointing i)Trial Judges, ii)
Appellant Court Judges, iii)NJ S.Ct Justices
iv) or any judicial officers including NJ
Municipal Judges. When Chief Justice of NJ S.Ct
retired or become vacant one of the associate
justice of NJ S.Ct should be promoted to NJ S.Ct
Chief Justice.
When NJ S.Ct’s associated justice retire/vacant,
NJ appellate Judges or Appellate Judges from
sister states should appoint them as NJ S.Ct
Justice thru Collegium process.
so Petitioner pray this Court for order to appoint
22 justices thru Collesium Process.
Petitioner pray this Court that This Court
should invalidate the NJ S.Ct / NJ appellate
Judges appointed/promoted by NJ govt/NJ Chief
justice including Fabiana Pierre-Louis, Justice
Wainer Apter, and Douglas Fasciale since this
case/related case was filed/subjudiced.
This Court should order that NJ S.Ct justice
should retire at age 70 or five years of service with
NJ S.Ct whichever comes 1st
There 20 states in United States have Judicial
Nominating Commissions/ Assisted Commission
which similar or subset of Collegium process for
appointing States’ S.Ct justices.
Judge/justice should not promote/appoint another
Judge is not democracy by Hon. CJI Ramana’s
opinion. These NJ appellate Court Judges should
be appointed thru Collegium process.
9
Thru Collegium process, Appointing NJ S.Ct
justices, NJ appellate Court Judges, any judicial
officer including Municipal Judges should not
violated the ruling of Babb v. Wilkie, 140 S. Ct.
1168 -2020 and Babb v. SECRETARY. DEPT. OF
VETERANS AFFAIRS. 992 F. 3d 1193 - Court of
Appeals, 11th Circuit 2021.
Accordingly as above, State of NJ should make
changes/amendment to NJ Constitution.
Order that Edison Twp Mayor Appointed
Municipal Judge Dipti Vaid Dedhia is invalid.
2. LEFT BLNK
3. Shared Children Custody and NJ should not
violate Parents disability in grating children
Custody.
Test-2. Ramya hold Children custody because she
does not got work so will not be able to pay child
support, because I was going to work, fake FRO order
was entered against me to order the child support.
Further continues bill the child support, Judicial
fraud consolidation order filed obstruct my justice.
Millions of time, NJ judicial authorities did these
wrongdoings against millions of family and
Violated the 14th amendment parental rights.
Test-3. Denying Share Custody, denying custody due
to disability is continuously violated the Parental
rights 14th amendment. Also bring down the Family
Court Corruption/fraud. When the Petitioner spine
injured in car accident, unable to work for 18 months,
parental rights were not violated, 2 year old child
home eviction, breath cold air, had chest pain.
4. Acceptable form(s) of Child Support and
Save the child support money to Child need.
Test-2. In NJ family Courts Child support money and
IRS income tax, Disability income/SSA, title vi-d, and
Unemployment withhold due to Childsupport. These
money(s) were become benefit of Family Court lawyer
10
and NJ Judicial Authorities upto NJ S.Ct. For the
reasons, NJ judicial authorities and family Court
attorney focus to rob the above said money.
Test-3. Saving the Child support money, IRS income
tax, Disability income/SSA, title vi-d, and
Unemployment withhold due to Childsupport in
Children Saving should be used for Children college
education and bring down the family Court
corruption/fraud. Children are protect by SNAP,
When Petitioner spine injure on help was available to
his kids.
5. i) Family Properties inheritance to Children,
ii) No lawyer fee from family properties,
Disclose/open-to-public family Ct lawyer fee.
Test-2. NJ judicial authorizes and family Court
lawyer focus to find the Family properties, in the
name of Family lawyer fee, rob the family properties
and family saving for kids education, share up to NJ
S.Ct justices. To rob the family properties and kids
form
any
of
saving,
educational
fraud/corruption/bribe the NJ judicial authorities and
lawyers do.
Test-3. Moving/Saving the family properties to
Children
inheritance
and
above
prayer
wrongdoing/fraud/bribe/corruption in the NJ family
Court should go down.
The above wrongdoing of NJ judicial
authorities, family Court lawyers were violation in 42
US Code § 1982 - Property rights of Citizens.
In Sullivan v. Little Huntine Park. Inc.. 396
US 229 - Sup. Ct 1969®237
“Section 1982 covers the right "to inherit, purchase,
lease, sell, hold, and convey real and personal
property."
These respondents did same wrong doings against this
Petitioner caused unmatchable, unsubstitutable
damages.
11
6. NJ family Court records should not be under
seal and No Property matter/financial
matter disclosure discussed in Family Court.
Test-2. Under inheritance, Section 1982, Sullivan, all
these properties (moving/non-moving) are moved to
the children from begin of the family case.
Now the family properties, financial matter
disclosure matter are filed from the beginning of the
case is to aid the Attorney(s)/family Court Judges to
focus the billing and sharing upto NJ S.Ct justices.
What is the need of sealing the family Court docket?
When the property/wealth are move to children as
inheritance, no privacy violation. People divorced
status is not privacy violation. Under seal is to protect
the how the fraud/corruption by the family Court
Judges/lawyers. When Amazon CEO Jeff got divorce,
both party discuss in the media that how much wealth
they obtained. Why should the poor people divorce
under seal?
Test-3. Property/Wealth does nothing in the two
individual’s divorce when the children involved.
Moving the property/wealth to children do not injury
to the family case party(s) and wealth is with their
loved children who can use the wealth to their
educational need (example). Most importantly take
out the ill eyes of Family Court Judges/ NJ Judicial
Authorities, and family Court lawyers. NJ judicial
authorities wrongdoings against this Petitioners
because their ill eye focused the Petitioners $400k
home in India. See they octopus hand go other side of
the earth. Granting These prayers should bring the
corruption in Nj family Court to down.
12
d) Writ against NJ Judicial authorities.
7. i) NJ Judicial Authorities involve in family
case should get mental fitness certificate
yearly.
ii) NJ Judicial authorities’ Yearly Financial
disclosure Statement to be Open to public.
iii) NJ Judicial Authorities to file timesheet
for every 15 minutes of their duty.
Test-2: Routinely, habitually NJ judicial authorities
ordered/compelled the parents for psychiatric
evaluation for granting children visitation/custody,
share the money from psychiatric billing parents.
Recently in NJ, One Psychiatric was ordered to file
affidavit that she should not renew her license in NJ
for sharing money with NJ judicial.
Nj Judicial authorities paid from public money,
corruption free should be prefix to Judicial authority.
Few Months ago, closed to 100 Nj Judges from trial
Court to NJ appellate Court forced to resign due to
disappropriate money saved in their retirement
account thru corruption/bribery.
Nj judicial authorities paid from public money and
public wanted to know what to they do and how their
time is used. Sitting in the public office, doing
corruption, why they need to be paid from the public
money. Timesheet should have what they do every 15
minutes. Paid by public money so public should know
what respondents do.
Test-3. NJ judicial authorities’ irreparable damages,
inhuman decision to the NJ family’s and the children
with their psychological illness. Getting psychological
fitness should not cost them either because health
insurance is already provided to them by NJ govt. So
Parental rights and children’s rights under equal
protection clause were protected.
NJ judicial authorities should be prefix from
corruption/bribery. NJ Judicial authorities’ yearly
13
financial disclosure Statement to be Open to public
bring the prefix corruption to them. They were paid
thru public money, public should know they were
corruption from at first. Same reason, public should
know what they do every 15 minutes by their
timesheet. Petitioner worked many govt officer where
15 minutes tasked timesheet is must.
8. Order NJ S.Ct to provide a copy of Ramya’s
Response brief.
Test-2. Naga, the attorney for Ramya already
disqualified. NJ judicial authorities and Naga filed
response brief without Ramya’s knowledge. This brief
has crime against the Petitioner, his family. Legally
Petitioner entitled what other party filing. Multiple
time Petitioner requested the Nj S.Ct thru motion and
verbally which was denied. Based on the Ramya’s
proxy briefing, Petitioner certification with Nj S.Ct
denied and Petitioner and his family, children are
suffering, injured till today. This is clear abuse of
discretion/usurpation of judicial power.
Test-3. Petitioner is entitled to get justice from the
injustice provided by NJ S.Ct from the Ramya’s proxy
Briefing. The crime in the Ramya’s proxy filing is jail
able crime.
9. NJ S.Ct should not hire proxy peoples India
file case in Indian S.Ct to strike down the
Indian family law based on Petitioner Indian
family Court.
Test-2. NJ Judges, After entering FRO for fake dv
case, Judicial fraud consolidation, separating the
Petitioner and his family and children, violating the
14th amendment, parental right, violated the
Petitioner cohabitation of family, sexual rights of
Petitioner, dishonoring Indian family Court, hired
proxy people to file case in Indian S.Ct to strike down
the Indian family act on which Petitioner got family
reconciliation order.
14
Docket is OJASWA PATHAK vs. UNION OF
INDIA. Dkt#W.P.(C)No.250/2019
Test-3. NJ S.Ct doing above such, the case is delayed
unnecessarily. Three times NJ S.Ct pressured in
Indian S.Ct, here the case is delayed 3 years. Totally
the Petitioners suffered which no human Being
should suffer in civilized society and wasting time in
the US federal Court. So this prayer should be
granted. Striking down the Indian family law in-part
against the order Petitioner got from India is not
going to be nullify the order past 10 years. Approx. 10
years ago, one India lady got reconciliation order from
India which is not going to be null now. She might
have two more kids now. Who is going to step in their
home and tell husband and wife get out and live
separate. Petitioner have gave a Indian family Court
petition in English translated as they needed so they
knew what is going to be out come. They are corrupt
and forever corrupt. Only truth and justice should
survive.
When OJASWA PATHAK is not closed and
kept on wasting time of Federal Court, this Court
issue order to Indian S.Ct to dismiss and close the
docket in Indian S.Ct
10. Left blank
e) AGAINST NJ
11. i) Trial by Juries in family Courts, ii) Strike
down lawless family Court and create Civil
family law iii) Equal rights to men in family
Court
Test-2. Without any law and without Jury, NJ family
After
Court run and ordered to the parties.
Consolidation order was found to fraud, this
Petitioner requested Jury(s) appointment which was
denied. NJ family Court Judges and attorney(s)
15
involve any fraud/corruption/bribe to make money
thru billing and share the money up NJ S.Ct justices.
Without Jury, domestic violence cases, divorce cases,
child support orders, child custody orders, before
issuing bench warrant and jailing matter of child
support/spouse support were decided which violated
the fair justice, due process guaranteed by
constitution.
Because of No law to run the family Court, above said
wrongdoings /corruption/ Bribery were happening in
the NJ family Court which ultimately violated the
constitutional rights.
Because Im Black man from India, Restraining order
were issued for the purpose of billing child support
money, which violated the parental rights 14th
amendment.
Test-3.
The
above
said
family
Court
action/wrongdoings were violating constitutional
rights including due process. At Either parties
demand Juries need to be available to protect the
constitutional rights.
Any trial Court should be under Law. Running NJ
family Court without law, it is kangaroo Court by Nj
politician and their relative/friend are Judges to rob
the families and their saving for their kids’ education.
Nj family Court issuing restraining order because a
party is men violate the fair justice constitutional
rights and 14th amendment parental rights. Without
Jury deciding family Court orders were for purpose of
corruption benefit of NJ law mater and NJ Judicial
authorities.
12. Consolidate the NJ family Court (lawless,
kangaroo Court), NJ Law division civil Court
and Landlord/Tenant Court.
Test-2. Minor Petitioner PP born from Little Rock,
AR where one civil Court, under one roof have trial
16
for Civil matter and family matter. For the purpose of
Black money transaction Naga, Jayapalan, Ranjeeth
filed the fake domestic violence case and no
jurisdictional divorce case. When the Petitioner
requested the NJ family Court to add Ranjeeth,
Jayabalan as defendant to the case which was denied.
Civil matter need to be put together to avoid
piecemeal litigation.
Even After lease expired, landlord filed complaint
with Landlord/Tenant Court and got Judgement
against this Petitioner by alleging that defendant did
not pay rent, reported to rental history. Illegally The
landlord towed Champing van, I was not able to get
justice over 7 years. When all type of Court
consolidated, all dispute can be put together without
piecemeal litigation.
Test-3. The fake domestic violence case is decided in
10 days by law for billing childsupport money. This
case over 7 years waiting for justice. In car accident,
Petitioner had spine injury which still pain, home
went eviction, heating was not affordable, Minor PP
breath cold air had chest pain when he was 2 years
old. Still today Petitioner did not got compensation for
spine injury. These 3 type of Courts are running
separate to deny justice to layman, corrupt minded
people to be benefitted. In Civil case, every claim
against every party need to be put together and tried.
13. i) No gun carrying Police involve in family
matter, ii) No arrest to the people who need
medical treatment, iii) no township police
overtime.
Test-2. The county or township police came to my
home with gun for enforcing childsupport which is for
billing purpose. When the Petitioner had spine injury
by car accident, unable to work 18 months, home was
under eviction, heating was not affordable, 2 years old
minor Petitioner PP got chest pain by breathed cold
17
air. No police with gun went to car insurance company
get the loss of Petitioners. Police coming to home,
cross firing should endanger innocent neighbor as
well.
The county jail the ill/sick/disabled people and
provide treatment when they are in the custody by
county expense. County’s tax payers do not need to
take care of the sick people treatment.
Township police come to collect the childsupport on
their over time. When police station is opened for 24
hour, why should the police need to work overtime. In
Edison twp, NJ 3 police reported overtime, never
appeared on the private construction business and
collected over million dollars. When township needed
additional police resource, State trooper should fill
the needed.
Test-3. The family Court Judge rob the parents in the
name of childsupport. Police with gun help robbing
Judge, innocent parent goes to jail. This is not the
police duty. County tax payer is not responsible for
disabled/ill people medical treatment. Police over
NJ MVC/DMV is not
time lead to corruption,
protected by private security and local police overtime
protect the private business. All for the keep the
corruption purpose.
14.Wipeout the FROs/arrest/jailing records.
Test-2. The charges against Petitioner were a)
Petitioner told his wife go to work, do not involve
black money transaction, do not take the children to
daytime parties which endanger the children, did not
bring the India family home money for the benefit of
NJ Judicial authorities,
Test-3. For the above reason, FROs were entered
against Petitioner, Arrested/jailed for multiple times,
family value is defamed in USA and India. Anyone
using/ abusing these records is crime. Those records
should not be accessible/available to anyone.
18
15.15 is left blank
16. Deduct 20% from NJ Law makers to pay the
Petitioners loss.
Test-2. NJ trial/family Court/appellate Judges, NJ
S.Ct Judge were appointed by NJ law makers because
of Judges were relative/friend to them. So the corrupt
Judges do corruption/fraud to benefit to them and the
lawmakers. For the Petitioners’ loss, NJ law maker’s
wrongdoing
contributed.
Few
month back
approximately 100 NJ Judges were forced to resign
from duty because they were relative/friend to NJ
lawmaker so appointed as Judge and their retirement
account had money in disappropriate amount.
Test-3 NJ law maker wrongdoing were one of the
reason for the Petitioners damages/suffering. Detect
20% of NJ lawmakers’, who served since 1995, any
and all compensation including salary, pension, and
govt benefit for paying Petitioners’ loss. Future
judicial corruption should be avoided.
17. Move the Middlesex County’s Court and
Childsupport probation employees in to NJ
payroll.
Test-2. These Child support employees work for
collecting child support to benefit of judicial
corruption, family Court Judges benefit. When the
shared custody is granted, these employees are not
required at all.
In this case, Middlesex county Court employees
involved in the Fraud-on-the Court or judicial fraud
consolidation order for the purpose of NJ Judicial
authorities and NJ lawmaker. NJ Judicial authorities
and NJ lawmaker have relative/friend relationship by
appointing NJ Judicial authorities.
Test-3. Shared children custody is granted,
these employees are not needed. County tax payer do
not need to pay childsupport collection effort or
corrupt Judge’s pocket filled by child support.
19
Enforcing state law so state should pay these
employees salary.
Fraud/judicial fraud on the county Court, for
the benefit of NJ judicial and NJ law makers,
Middlesex county tax payer should NOT be
responsible for the fraud or any wrongdoing. Moving
Middlesex county’s Court and childsupport probation
employees should bring the corruption in the NJ
judiciary and NJ govt. Unnecessarily County tax
payer do not need to be responsible for the Court
employees wrong.
18. Order to cut 80% of federal funds to NJ and
its Local govt.
Test-2. In the corruption, NJ is in the top 3 and
competing Louisiana and
Illinois when the NJ responsible were highly
educated than any part of
the earth. The number/density of Doctors, Engineers,
Scientists in NJ per square miles more than any part
of earth including Japan. At the time of 2008
recession Petitioner went to Audi dealer Edison NJ
for buying baby car seat, then the peoples (Indians)
were standing on the queue to buy Audi cars when
everybody in US worry about housing bubble.
Test-3. Because of more money available, more
corruption, more crime were done by NJ judicial
authorities and NJ and its local govt officials.
Fittest should survive. People are rich so they get fit
to survive, themselves. Instead of Federal funds
spend in NJ which cause more corruption, those
federal fund should be used in under developed
area/regions of US to promote the needy people. So
Petitioner pray this Court to cut 80% of federal
fund/aid to NJ and its local govts.
20
f) Writ(s) against Middlesex County, NJ
19.Middlesex County NJ to pay $42 million
dollar for collecting child support illegally
Test-2. Middlesex family Court entered the FRO for
fake domestic violence case. Middlesex County Court
employees involved fraud on the Court/judicial fraud
consolidation order and collected childsupport over
$42 thousand dollars based on fraud consolidation
order for the benefit of NJ judicial authorities.
In the KARUPAIYAN v. SIANO | 53 A.3d 662 (2012),
Petitioner had spine injury and unable to work 18
months, Petitioner is only income holder to family,
Middlesex county did not take any effort to get
support to the children who suffered home eviction,
heating not affordable, breathed cold air, suffered
chest pain. In fact, Middlesex sheriff should went
with gun to Car insurance Company collected the loss
of the Petitioners from car accident injury which is hit
and run, a proxy appeared to testify with knowledge
of attorney and trial Judge.
Test-3. This pattern of colleting childsupport
happened millions of cases. Nobody can question this
corruption because this corrupt money is shared upto
NJ S.Ct justice. Partially I paid childsupport thru
credit card which I paid 29% interest. The prayer is
reasonable to any unbiased persons. Petitioner pray
this Court to order the defendants including
Middlesex County to pay 29% Cumulative interest, so
the respondent will not delay the case.
21
g) Against
all
defendants/respondents.
Individual
20. i) Jailing L. Naganda, P. Jayabalan; J.
Ranjeeth Kumar, Arul Thirumurugu, David
Halpern, Marcia Silva, Craig Corson, Jerald
Council, Stuart Rabner, Jaynee la Vecchia,
Barry t. Albin, Anne m. Patterson, Faustino j.
Fernandez-Vina, Lee a. Solomon, Walter f.
Timpone, Glenn Grant, Allison e. Accurso,
Patrick Dealmeida, Joseph 1. Yannotti for 25
years AND ii) protection/restraining order
against these Individuals and iii) Remove NJ
S.Ct Justices, NJ appellate/family Court
Judges defending the Petitioner and iii)
Invalidate all the orders signed by these NJ
judicial authorities.
Test-2. Petitioner is head of the family decide
what is good for the family. Because I told my wife to
work, do not involve black money transaction against
govt of India, and because I cleaned the lease expired
apartment which was forced by landlord for their
illegal benefit, the Petitioners went thru inhuman
suffering which no one should go thru in civilized
society, and still continuing. These Respondents
filed/involved/caused the FROs/Fraud consolidation
to the Petitioners which continue to be yet.
They involved in the endangerment/attempted to
murder of the Petitioners. App2.73.74.
These
individual forever endanger the Petitioner, Minor
children, Ramya and continue endanger the forever.
Test-3. Obvious Circumstances, still Petitioners
are separated, co-habiting, parental rights is violated.
Cause the Petitioner to be arrested/jailed multiple
times. Jailing these Individual respondents for 25
year and issuing Permanent restraining /protection
22
order against these Individual is must to protect the
Petitioner, his minor children, and Ramya.
h) Writs against the Landlord
RESPONDENTS
21. Money Relief to Children by Landlord
Test-2. Petitioner rented apartment in Dallas, TX
before Lease expiring with this landlord, Oak tree
village, Edison NJ, which owned by Atlantic Reality.
Landlord
got
under
table
money
from
Jayapalan/Naga and allow them to occupy the
apartment. Landlord told the Petitioner to clean the
lease expired apartment which get the FRO against
Petitioner(s), family, children were separated.
Petitioner unable to tell Ramya to go work for kids
Marriage expense which is unlimited to Indian
family.
Test-3. Children separated from father/parents
for 7 years is unacceptable for anyone in the civilized
society. Childhood is gone, unmatchable loss. Also
landlord filed false affidavit with Dist Court that
Atlantic reality is not owner of Oak tree apartment,
but negotiated with Edison Township for tax evasion
as owner of the properties and failed to appear as the
Court ordered for settlement conference. This Court
should order landlord defendants to pay 100 million
dollar for each Minor child Petitioner’s marriage
children.
of
expense
/Educational
22.Landlord to pay $100 million to Petitioner
for leasing inhabitability apartments.
Test-2. Landlord (Atlantic) leased roof leaking
apartment to the Petitioner. Not only was the
Petitioner’s living unit leaking. Whole apartment
complex was roof leaking. Landlord owe continues 4
apartment complex Edison, NJ, all of them roof
23
leaking. Whenever renter request fix the roof or delay
payment until fix the roof, Landlord file eviction to
harass the Talents which is easy since
Landlord/Tenants Courts are corrupt with them.
Every apartment complex owned by Atlantic roof
leaking, same business model. Previous owner sold
the apartment to Atlantic with when time to replace
the roof, Atlantic purchased at cheap rate and do not
want fix the expensive roof fix since Atlantic have
relation with Tenant/landlord Court Judge corrupt
relation to evict and collect money.
Test-3 Due to leased roof leaking apartment,
Petitioner head/scalp got virus infection and
prolonged head ache for years. Petitioner got
prescription to heal the viral infection. Viral infection
got many years to heal. Same/similar prayer is in
attached Exhibits.
One of Co-worker when I worked in NY city who lived
in Atlantic reality’s apartment, said she had 2 years
old kids who suffered by leaky roof. Whenever she
request to fix the roof, she was told that call 3rd party
Middlesex management who is the contractor to fix
the roof.
23. Order that assign the ownership of Landlord
any and all business including Atlantic
reality, ownership of any and all rental
apartments, Landlord Halpern’s ownership
building to the Petitioners.
Test-2. In the Petitioner vision, more 70 apartment
complex owned by Atlantic reality, on all complex
roofs were leaking. Roofing is expensive fix. Any
tenant/renter request to fix the roof, landlord answer
should be that roof fix is giving to 3rd party contract
(Middlesex management) so call the 3rd party.
Middlesex management is again owned by
landlord/Atlantic/Halpern. Any renter refused/delay
the rent due to roof leaking, the landlord file eviction,
24
over charge the renter and share the money with
Landlord/tenant Court Judge. In this case, Petitioner
timely gave notice and timely moved out, lease
expired, the landlord filed eviction in the
landlord/tenant Court by paying corruption to Judge,
robbed me closed to $9,000, listed me in rental history
so unable to rent apartment so the Petitioner and his
disabled sister age close 70 was suffering without
home and slept in the car.
In the main holding business, Atlantic reality
employee only 13 employees from his relative to get
out of Title VII claims. Other Business, Middlesex
management employees all illegal Latin America
peoples so paid low salary illegally or do not even pay
salary for tax evasion. Since the employees were
unfairly paid, for survival they rob the renters who
are mostly/90% Indian who have lot of gold jewel, in
home.
Test-3. Landlord filed false declaration with
Dist Court that landlord is only investor, no interest
in the Apartment complex. In an official meeting with
Edison, NJ’s Mayer/council man /politician, Mr.
Halpern stated that he is owner of the apartment
building, he wanted tax benefit for the apartment
buildings.
Petitioner prays this Court for order the ownership of
all apartments, Real Estates, moving/non-moving
properties owned by Atlantic reality, Middlesex
Management, and Mr. Halpern and his family to the
Petitioner. Petitioner will run the business in nonprofitable way and pay all the taxes landlord evaded
against Federal, NJ local govt.
When the Dist Court ordered the landlord to appear
for settlement conference, landlord failed to appear.
Contempt of Court. This prayer should be granted as
punitive damages
25
In Cohen v. Office Depot. Inc.. 184 F. 3d 1292 Court of Appeals, 11th Circuit 1999®1298-1299
“It is true that Rule 54(c) tempers the effect of Rule
8(a)(3) somewhat by stating that, except in the case of
default judgments, "every final judgment shall grant
the relief to which the party in whose favor it is
rendered is entitled, even if the party has not
demanded such relief in the party's pleadings."
‘®Hanna v. Plumer.380 US460,470-S.Ct 1965@1143.
Likewise, in this case, because *1299 Rule8(a)(3)
allows a plaintiff to request in her initial complaint all
the relief she seeks, it says "implicitly, but with
unmistakable clarity" that a plaintiff is not required
to wait until a later stage of the litigation to include a
prayer for punitive damages, nor is she required to
proffer evidence or obtain leave of Court before doing
so
i) Writs against Lower Federal Courts
24. Order lower Court (Dist Court) to run the
case as combined civil and criminal case
when remanded.
Test-2. Fraud on Court, judicial fraud, obstruction of
justice, robbed the Petitioner in the name of child
support, involved black money transaction against
govts and so on were crime(s), violated the Indian
family Court orders. Filed and entered FROs for fake
domestic violence case, false arrests, false jailing.
Test-3. The above crimes are eligible to attach with
civil case, run as combined civil and criminal case so
this Court should grant the prayer.
25. Petitioner pray USSC that it should vacate
the Sua sponte dismissal of complaint.
Test-2. By Sua sponte, Dist Court dismissed the
complaint (ECF-6).App.l3
Test-3. In Salahuddin v. Cuomo. 861 F. 2d 40 USCA2,1988 @43( “this Court [USCA2] has
26
repeatedly cautioned against Sua Sponte dismissals of
pro se civil rights complaints prior to requiring the
defendants to answer. See.Bavron v. Trudeau. 702
F.2d 43,45 (USCA2,1983)). This case, no defendant
answered or appeared. This Court should vacate the
sua sponte Dismissal of the complaint and remand
the case back to Dist Court for further proceeding.
Order denying reconsideration should be vacated
App.17.
26.Appoint i) Guardian ad litem and/or pro
bono attorney
Test-2. Petitioners requested the Lower Court(s) to
appoint guardian ad litem and/or probono attorney.
For this request, regularly the lower Court denied
these requests based on 28 USC§ 1654; OseP-Afriye v.
The Medical College of Penn..vania. 937 F.2d
876(USCA3,1991)
Test-3. In Montgomery v. Pinchak. 294 F. 3d 492 USCA, 3rd Cir. 2002@502(‘Montgomery was not a
sophisticated "iailhouse lawyer"). Tahron v. Grace. 6
F. 3d 147 - Court of Appeals, 3rd Circuit 1993® 156157(77ie plaintiff's ability to present his or her case is,
of course, a significant factor that must be considered
in determining whether to appoint counsel. See Hodge.
802 F.2d at 61; Maclin. 650 F.2d at 888). In this case,
Petitioner is homeless, live here and there, cars, an
towed away. Suffering from spine injury.
Bethel School District No403 et al. v. Fraser. A
Minor, et al. 478 US 675(1986) (minor is party and
his father was appointed as Guardian ad litem.
See@FRASER680. The father brought the action in
the Dist Court for FIRST AMENDMENT constitutional
violation. Board Of Education Of The Westside
Community Schools (Dist. 66) et al. V. Mergens. By
And Through Her Next Friend. Mergens. Et. 496 US
1 On 05/10/2023 USCA3 vacated.
27
226(1990),@233 (Respondents, by and through their
parents as next friends, then brought this suit in the
United States District Court for the District of
for
Nebraska
Constitutional
violation.
ANKENBRANDT, as next friend and mother of L.R.,
et al. v. RICHARDS et al 504 US689(1992) (mother is
party and claimed as next friend to her minor
daughter for tort claim.
In Jacob WINKELMAN, a minor, by and through
his parents and legal guardians, Jeff and Sandee
WINKELMAN. et al„ v. PARMA CITY SCHOOL
DISTRICT. 550 US 516-127 S.Ct. 1994(2007),
In Winkelman, Parents on their own behalf and on
behalf of Jacob, filed a complaint in the United States
District Court for the Northern Dist of Ohio, later
their appeal, without the aid of an attorney,
When the USSC examined “The question is
whether parents, either on their own behalf or as
representatives of the child, may proceed in Court
unrepresented by counsel though they are not trained
or licensed as attorneys”
And USSC ruled that (Winkelman@200 7)
The Court of Appeals erred when it dismissed the
Winkelmans' appeal for lack of counsel.
It is beyond dispute that the relationship between a
parent and child is sufficient to support a legally
cognizable interest [in the education of one's child!: In
this case. Constitutional rights of appellant
Karupaivan’s Children.
Winkelman@2008
"party aggrieved" means "[a] party entitled to a
remedy; esp., a party whose personal, pecuniary, or
property rights have been adversely affected by
another person's actions or by a Court's decree or
judgment" ante, at 2003-2004.
“rights and remedies are parents properly viewed as
"parties aggrieved," capable of filing their own cases
28
in federal Court. They [Parents] are "parties
aggrieved" when those rights are infringed, and may
accordingly proceed pro se when seeking to
vindicate them”
Winkelman@2011 “They will have the same remedy as
all parents who sue to vindicate their children's rights:
the power to bring suit. I agree with the Court that they
may proceed pro se with respect to the first two claims”
In this case, Appellant Karupaiyan not
only guardians of their children's rights,
Appellant
Karupaiyan
himself
real
party/plaintiff for his claims which is unlike Osei;
Afrive. USCA3’s ruling against this case Appellant
father.
In this case Prose father parental rights under
14th amendment, Washington v. Glucksberg. 521 U.S.
702 (1997). Troxel v. Granville. 530 U.S. 57 (U.S.
2000J.
Children has right on the Reverse of Parental rights,
14th amendment Equal Protection Clause.
1)
Rule 17(c) Robidoux v. Rosengren. 638 F. 3d
1177 - Court of Appeals, 9th Cir 2011@1182 “District
Courts have a special duty, derived from Federal Rule
of Civil Procedure 17(c), to safeguard the interests of
litigants who are minors. Rule 17(c) provides, in
relevant part, that a district Court "must appoint a
guardian ad litem or issue another appropriate order
2)
CJLG v. Barr. 923 F. 3d 622-Court of Appeals,
9th Circuit 2019,@632 “children have due process
rights to appointed counsel. See, e.g., In re Gault. 387
U.S.l, 36-37,87 S.Ct.1428,
18 *632 L.Ed.2d
527(1967)”
Under undivided Hindu family act, Court should
appoint Petitioner Palani Karupaiyan (Head of
family) as guardian ad litem to Santhosh
29
j) Additional
27. Order for each respondents to pay the
for
each
Petitioner(s)
count
of
discrimination, wrongdoings, injuries and so
on.
Test-2. There are over 100 count of wrong doing did
by the respondents. There respondents involved
uncivilized crime, wrongdoing, fraud on the Court,
judicial fraud. Wrong against elected govt including
crime like money laundering, contempt of Court,
dishonor the Court order, violated the many
constitutional rights, federal statues, and violated
cohabitation, sexual rights of Petitioner. Parental
rights 14th amendment
Test-3. The above wrongdoings are uncivilized to
judicial decision makers. The suffering to the
Petitioners were continuously happening till today.
The respondents involved fraud on the Court, judicial
fraud, obstruction of justice, dishonored the Court
order, contempt of Court and so on which were serious
wrongdoing. The respondents killed the childhood of
my children in front of my eyes for 7 years. The
compensation money prayed against the respondents
were to punish them seriously so they will not repeat
their wrong. In NJ millions of families were robbed by
NJ judicial authorities, local govt official by fraud
family/trial Courts. So Petitioner pray the money
reliefs from the respondents as in the Exhibit-28.
Exhibit-29. Exhibit-30, and Exhibit-31. Because I
filed US Dist Court case, they attempted to murder
the Petitioner, cause spine injury which I suffer till
today. App2.73.74.
30
28. Order the Local Govts and NJ Judicial
Authorities to pay as per the exhibits
attached to the Minor Petitioner marriage
expense.
Test-2. When the Petitioner told Ramya, petitioner
wife to go work for the children marriage expense
which is no limit for Indian social culture, NJ judicial
authorities issued FROs against Petitioner, further
involved in Judicial Fraud consolidation, shared the
billing child support money up to NJ S.Ct Justices.
Middlesex cnty employees’ involved Fraud
consolidation order caused the FROs to be un
appealable, permanent. Landlord, Atlantic reality is
the original, start of the problem which caused the
FROs. Because FROs un-appealable, permanent
which cause the Petitioner unable to tell Ramya to go
work until now.
Test-3. Petitioner is head of the family of
undivided Indian family. When the head of the family
decide what is good for the family, nobody stands
against it which is crime. Of course, even USA, why
should anyone involve against family financial
income and best interest of the children education.
Even in NJ jurisdiction, anyone tell the spouse go to
work for kids need how NJ judicial authorities involve
against that family best interest. In NJ jurisdiction,
divorce,
$45
ruled
that
$250
they
marriage/remarriage license is available for
unlimited sex which either Indian S.Ct justices or
their family member or this Petitioner would agree.
Marriage expense is no limit for Indian families.
Prays for each defendant to pay $3 million per head
of the respondent of local govt, NJ judicial authorities
to each minor children. All money petitioner able to
spent. Spending is economy,
31
29.Petitioner(s) pray Order that each defendant
to pay for Petitioners’ effort, pain and
suffering, expenses, litigation cost or pain
and suffering by litigation.
Test-2. Over 7 years the litigation is going on. Lot of
effort to draft the pleading. Lot of painful effort to
draft with spine injuries. Because I dedicated time to
draft the pleasing I was not able to physical activity
to bring down the blood sugar went up. Now both leg,
foot are numbing. Im afraid kidney should be
permanent damage. Due to Situs inversus the born
defect, adapting body parts is not possible either.
Test-3. The defendant hired someone to
attempted murder the Petitioner. The attack to the
Petitioner was deadly, injured the pain. With the pain
in the spine, Petitioner drafted all pleading. Pray
USSC to order them $5 million dollar each defendant
should pay for the time and effort, pain and suffering.
In the painful situation, appointing attorney also
denied. Or this prayer should be paid in pain and
suffering. When I tried to find attorney and unable to
find since Im poor and not able to pay down payment
to the attorney. Lower Court denied pro bono attorney
as well. Also I have claim against the NJ S.Ct
violation of freedom of information act.
Bovadiian v. Cigna Companies. 973 F. Supp.
500 - Dist. Court, D.NJ 1997@504
Although plaintiff may not recover attorneys'
fees, he may recover litigation costs reasonably
incurred. See Cunningham. 664 F.2d at 387 n.
4; Carter. 780 F.2d@1482: DeBold. 735 at 1043
(citing Crooker v. United States Dep't of Justice. 632
F.2d 916, 921 (lstCir.l980)) ("[A] pro se litigant who
substantially prevailed certainly is entitled to
litigation costs reasonably incurred' A pro se
litigant is made whole thereby, serving as a small
32
incentive to pursue litigation if no attorney may be
found to represent the litigant.")
The First Circuit has reached the opposite
conclusion in Crooker v. Department of Justice.
supra, holding that "in actions where the complainant
represents himself, sometimes as a hindrance instead
of an aid to the judicial process, an award of fees does
nothing more than subsidize the litigant for his own
time and personal effort. Petitioner suffered from
spine injury and with this injury drafting the legal
document is extremely painful, no proper computer
table available to the petitioner,
k) Writs against Landlord respondents(ii)
30. Order the Landlord Atlantic to pay the
Petitioners Karupaiyan, RP and PP for
violating Conjugal/cohabiting rights.
Test-2: Due to Landlord ordered plaintiff to clean
lease expired/moved out apartment, which cause
separation of Petitioner Palani, RR. RP since Sep
2015. Landlord took under table money from
Jayabalan to occupy lease expired apartment.
Landlord is original wrongdoer.
Test-3: We all human beings and know pain
and suffering. Respondents including landlord hired
proxy people in India to file case in Indian S.Ct to
invalidate the law on which plaintiff got Indian family
consolidation order.
So petitioner(s) pray this Court 60 million dollar per
month to petitioners for separating petitioners and
violation of conjugal/cohabitation rights of the
petitioners.
31. Order the landlord to pay $250 per day for
illegally towing the camping Eurovan
Test-2: Before towing, Edison police offer told towing
agent that car is parked in private property and
should not be towed. There is Middlesex family Court
order with lien that Petitioner need to preserve the
33
car. The towing agency and landlord employee fill the
pocketed, towed Van and claiming that Van was
abandoned.
Test-3: Landlord wrongdoing is clear. Petitioner
home is evicted and homeless. If van would be with
petition, camp van should fill need of home evicted.
No home for years and sleep here & there. When
Corona attached, no place to take rest. Renting a
camper van cost $250/day.
5 years and 5 months. [5 x 365 + 150 days =1975
days]. 1975 * 250 =$493,750. So petitioner Landlord
should Court should order landlord to pay this money.
32. Order the each NJ Judicial authorities, NJ
and Middlesex county respondents to pay
$50 million for Children Education and
marriage expense
Test-2: Because Petitioner told his Wife Ramya to go
work for children educational and marriage expense,
these NJ judicial authorities entered FRO, filed fraud
consolidation order to prevent petitioner appeal,
denied petition with Judicial defect with their own
mistake in NJ S.Ct. These are illegal, jail able wrong
doing. Petitioner is head of family and nobody should
stand against petitioner when he take good decision
for family and children.
Test-3: Education cost money. Marriage cost money.
For Indian, cost of marriage is infinite. NJ Judicial
authorities ruled that NJ give $45 dollar marriage
license for unlimited sex which does not fit for this
petitioner or any one in Indian society. In India,
parents sell kidneys for marriage expense.
33.Order Ranjeeth to pay $600 million dollar to
the petitioner Karupaiyan.
Test-2; Purpose of black money transaction against
Govt of India, Ranjeeth filed/induced fake domestic
violence case and separated the family.
34
Test-3. Due to Ranjeeth’s wrong doing, petitioners
were separated, till today. Family matter, Kids
matter. Ramya’s Bank account has Ranjeeth’s black
money transaction.
34. Order to i) NJ that NJ should standardized
the NJ’s Municipal Mayors and councilmen‘s
salary.
Test-2: NJ municipal Mayor and Councilmen raise
their salary themselves.
Test-3: NJ Assembly men salary is standard thru
entire NJ. This year alone Jersey City mayor
increased his salary $50k.
35. Order that NJ Judicial authorities
respondents and Naga to pay $60 million per
months
violating
petitioners
conjugal/cohabiting rights.
Test-2: Naga and NJ judicial authorities filed fake
domestic violence case, filed fraud-on the
Court/judicial fraud consolidation order and
separated the petitioners till today.
Test-3: We all human being, know plain of
separating the family members, and kids.. Our fore
parents, and we run the family. These defendants
killed the children child hood in front of my eyes
which equal killed my children in front of my eyes.
Uncivilized street dogs do not allow anyone to touch
their bubbies. Even shot the dog, it carry the bullet
and defend the bubbies.
36. Order NJ govt/Middlesex County, NJ
Judicial authorities and Landlord to pay
following money for false arrest/false jailing.
Test-2: Once Petitioner was arrested falsely. Twice
petitioner was arrested and jailed falsely. NJ judicial
authorities denied appeal because of Judicial Fraud
consolidation order, petition with NJ S.Ct with the
own wrong of NJ S.Ct. Because of false, they decided
35
I should have sex with my wife, even after I got Indian
family Court consolidation order which is contempt of
Court.
Landlord is the original wrongdoer.
Test-3: Multiple times, falsely arresting.
Multiple times falsely jailing for i) petitioner canceled
child passport for prevent children abduction ii)
Petitioner told his wife that do not involve black
money transaction, do not take children to day time
parties, endanger them and go to work so need money
for children education and children marriage expense
which is unlimited/infinite, iii) Cleaned lease
expired/moved out apartment which was occupied by
Jayabalan who paid under table money to Landlord
to occupy apartment.
So petitioner pay this Court for order that each NJ,
Middlesex county, MARCIA SILVA,
CRAIG
CORSON, JERALD COUNCIL, STUART RABNER,
JAYNEE LA VECCHIA,
JUSTICE BARRY T.
ALBIN,
ANNE M. PATTERSON,
JUSTICE
FAUSTINO J. FERNANDEZ-VINA, JUSTICE LEE
A. SOLOMON,
WALTER F. TIMPONE, GLENN
GRANT, ALLISON E. ACCURSO,
PATRICK
DEALMEIDA, JOSEPH L. ANNOTTI, to pay $50
million for false arrest and $60 million for false
jailing.
Petitioner pay this Court for order that
landlord respondents to pay $500 million for false
arrest(s) and $750 million for false jailing.
37. Order that permanent protection order
against Khullars and Owner of Shalimar
Test-2: Rajesh Khullar, Raman Khullar, Tania
Khullar and Seth Latif owner of Shalimar hired by
these other respondents to kill the petitioners.
Test-3: This Court should grant protection order
against Rajesh Khullar, Raman Khullar, Tania
Khullar and Seth Latif and jail Khullars for 18 years.
36
These Khullars need to be deported to India so they
can practice upper caste Hinduism by drinking cow
urine.
38. Order that United States should enact
United States family
Test-2: When Entire United States, The family and
relationship between family numbers, Every State
have different family law. India, biggest democracy of
the world has family act/marriage act through India
when every state has different demography/diversity.
Based on marriage law, family properties are
attached to inheritance.
Test-3: Child Support Recovery Act (CSRA) ,
Respect
for
Marriage
Act is
there
for
unconventionally married people. Because majority
people married in traditional way the United States
should not ignore the traditional marriage of US
citizen. We are US citizen and family belong to the
United State. Parental rights are under 14th amend
of Constitution by , Troxel v. Granville. 530 U.S. 57
(2000) and Washington v. Glucksbers. 521 U. S. 702,
720. The States in United States have different family
law to do the different level of corruption. My son PP,
born from Little Rock, Arkansas and my daughter
born from Edison, NJ. Which states law applicable
and why should choose? Why the petitioner is not able
to choose? Family relationship is not shopping between
states. Respect for Marriage Act has Full Faith and
Credit Clause of the U.S. Constitution
39. Prose based additional relief(s)
Petitioner prays this Court for excuse if any
relief is duplicated, this Court should render best
justice to the prose petitioner for the best interest of
justice.
37
XII.
CONCLUSION
Petitioner(s) Palani Karupaiyan, PP, RP,
Santhosh Subramaniyan pray(s) the US Supreme
Court for the Petition for a Writ of Certiorari should
be granted.
Respectfully submitted.
lyjVT
Palani Karupaiyan, Pro se, Petitioner
1326 W William St, Philadelphia, PA 19132.
212-470-2048(m),palanikay@gmail.com
,1.
f
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