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

Supreme Court briefOct 18, 2023

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Text

No. _______

Application No. 23A100

IN THE SUPREME COURT OF THE UNITED STATES

Meghan M. Kelly, Petitioner

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

On Petition for Writ of Certiorari to the United States Court of Appeals for the Third Circuit

Case No 21-3198

Appellant Plaintiff Meghan Kelly’s Opening Brief

moving the US Supreme Court to vacate the Third Circuit’s Orders dismissing the case

under Younger, denying recusals of Judge Scirica and Phipps and to remand the matter to

the Delaware District Court for consideration

October 17, 2023

Respectfully submitted,

/s/Meghan Kelly

Meghan Kelly, Pro se

Not acting as an Attorney

34012 Shawnee Drive

Dagsboro, DE 19939

meghankellyesq@yahoo.com

(302) 493-6693

US Bar 283696

QUESTIONS PRESENTED

This appeal requires the US Supreme Court to decide the question of whether

judges may be disciplined or otherwise corrected within the purview of the Constitutional limits

of 1. Case or controversy or 2. impeachment by allowing me to amend the complaint to sue the

Delaware Supreme Court and its members to void Kelly v Trump, and the disciplinary matter

based on violations of my procedural due process rights, and to seek relief for harm and

Constitutional deprivations the judges caused or whether judges are above the Constitutional rule

of law, or whether I, and parties or attorneys like me, may be retaliated against and disciplined

for seeking to petition members of the Court to uphold and not violate the Constitutional and

federal law.

II.

This case presents a unique important Constitutional question as to whether a

disciplinary proceeding brought to punish petitions against the government, in violation of the

US Amend I right to petition, and right to speech, on subject matter grounds, and the Equal

Protections Clause is subject to voidability. Defendants seek to discipline Colleague Abbott for

petitioning against the County and Courts. Are the courts above the law, or will this Court rule

judges may be corrected within the purview of the Constitutional limits 1. Cases and

controversies and impeachment, without vindictive retribution for correction.

III.

Whether the evidence outlined on the record below concerning both Kelly v

Trump and the DE Disciplinary show a high probability of procedural due process violations so

great that I should be permitted to argue before the trial Court the Delaware District Court

subject matter jurisdiction is void or voidable, especially since the statute of limitations would be

tolled for claims relating to Kelly v Trump and for retaliation in response to my exercise of the

1st Amendment right to petition for exemption for bar dues.

IV.

Whether the Court committed reversible error in dismissing my complaint given

Defendants indicate my religious beliefs and citations to the Bible contained in my speech in my

petitions to alleviate a government substantial burden upon my religious exercise by Trump’s

establishment of government religion is in issue, as Defendants’ reason for interfering with in an

attempt to cause me to forgo Kelly v Trump and later after the conclusion of my Religious

Freedom Restoration Act lawsuit Kelly v Trump, and after the filing of Kelly v Swartz, in

bringing the disability proceeding in violation of my 1st Amendment rights to petition, speech,

religious belief and exercise of belief applicable to the state pursuant to the 14th Amendment,

which claims I may only be bring in the federal court for damages and nominal damages, given

the State forum before the Board has no jurisdiction to grant monetary relief or nominal relief for

the State’s Constitutional, state and federal violations, and since it is highly probable the State

DE Supreme Court incited the interference especially since the DE Supreme Court concealed

evidence in my favor during Kelly v Trump and fired two material witnesses, two court staff to

prevent evidence in my favor during the disability proceeding while denying my right to call

them as witnesses.

Whether the Court abused its discretion for dismissing my initial complaint under

Younger arising from Defendants, the Delaware Supreme Court and the arms of the Court’s

interference in my RFRA law suit against former President Donald J. Trump made with the

intent to intimidate me to cause me to forgo my case based on the Defendants disdain for my

religious-political beliefs contained in my speech, in my petitions, or poverty and my petitions to

correct and stop Court misconduct in light of the admitted reason for discipline was the

Defendants found my religious beliefs in the bible and Jesus incomprehensible, when I sued

Trump to alleviate a substantial burden upon my exercise of religious belief from the burden he

III

caused by the establishment of government religious belief in a course of conduct not limited to

executive orders Ex. Or. No. 13198, Jan. 29, 2001, as amended by Ex. Or. 14015, Feb. 14, 2021;

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

13279, December 12, 2002, as amended by Exec. Or. No. 13559, November 17, 2010; Ex. Or.

No. 13559, Nov. 17, 2010; Ex Or. No. 13831, May 3, 2018, and Biden’s enactment of Ex. Or.

No. 14015, Feb. 14, 2021 that give churches money to perform government business under the

lie of charity and another executive order E.O. 13798 which allows churches to take parishioner’

donations to support or give the packing of government candidates or parties to give the

blasphemous backing that God backed Trump which incited violence or threats of violence

against me based on my apparent rejection of Trump religious belief.

VI.

Whether the Court erred in dismissing my claims against Defendants for

retaliation to prevent the initiation of an unlawful proceeding brought in bad faith to cover up

Court misconduct where Defendants unconstitutional sought to and did place my license to

practice law on inactive disabled preventing me from buying and selling as a lawyer in violation

of my 1st Amendment rights applicable to Defendants pursuant to the 14th Amendment based on

disdain for my private exercise of the fundamental rights to petition, to religious beliefs

contained in my protected speech, contained in my petition, essentially conditioning the

elimination of fundamental rights for the active license to practice law since they find my

religious beliefs repugnant or do not understand them. Basically can a Court place an attorney

on inactive disability because they find their religious beliefs illogical or repugnant even if they

are genuinely held.

VII.

Whether the Court erred in dismissing the case under Younger given the

numerous claims the Board whose subject matter jurisdiction under Rule 5 is limited to attorney

discipline could not address, including but not limited to claims for damages, nominal damages

and equitable relief for violations of 42 USC §§§ 1983, 1985, 1988, and harm to my reputation,

claims for emotional distress, defamation, loss of employment opportunities, or other economic

harm and for 1st Amendment rights to private petition, religious belief, speech, association and

exercise of religious belief applicable to Defendants via the 14th, compelled violations of my

religious belief, retaliation for the exercise of fundamental rights including but not limited to the

right to petition, 5th Amendment right against self-incrimination by compelled incrimination

required by the disciplinary rules, Constitutional arguments regarding a number of State

Disciplinary rules, Constitutional arguments against the disciplinary proceeding, and by

extension Constitutional arguments against federal judiciary disciplinary or disability

proceedings and rules and the absence of life time appointments during good behavior for

District and Appellate Court judges, Constitutional arguments to limit discipline or correction of

Judges, including United States Supreme Court members to the purview of Constitutional limits

of 1) cases and controversies and 2) impeachment by asking the court to find the US Supreme

Court may not violate my 5th Amendment right as a party of one to Equal protection by a partial

forum biased towards the regulations or regulators even by self-regulation instead of the

impartial application of the Constitution to the rule of law, and by finding judges are above the

law and above cases and controversy by depriving me of a forum for redressability for harm

caused by members of the DE Courts who may not be a judge in their own case, denying me

access to the record of a case where I am the accused No 341 to cover up additional deprivations

of my 14th Amendment right to be heard, sending Court of Common Pleas Judge Clark, DELapp and Defendants to attack me during Kelly v Trump to cause me to forgo my petition,

sealing evidence in my favor in Kelly v Trump to fix the outcome in Kelly v Trump and the

future disciplinary case, firing witnesses necessary to my defense, than preventing me the

opportunity to call them to cover up the DE Supreme Courts misconduct, Court staff writing on a

praecipe and instructing me to cross off local counsel’s address to prevent service and misleading

me to miss a filing deadline in Kelly v Trump, denial of access to the law library, violations of

my 6th Amendment rights applicable to Defendants via the 14th Amendment to self-represent,

6th Amendment right to call and confront witnesses in the Disciplinary Case, ancillary claims of

loss of employment opportunities but for the threats incurred during Kelly v Trump which ended

talks with my previous employer to start work but for the state’s attacks against me during Kelly

v Trump and other economic harm, and harm to my reputation, violations of procedural due

process, substantive due process and equal protection under the 14th Amendment based on

religious-political-poverty animus in both Kelly v Trump and the Disciplinary matter, bad faith

harassment in the form Defendant Patricia Swartz lying to me to cause me to expend additional

money or the case to be thrown out before the Boad, Defendants intimidating me by sending

state agents to attack me or otherwise threaten me to cause me to forgo Kelly v Trump, and lack

of notice, denial of opportunity to be heard, opportunity to prepare, perform discovery or call

witnesses, and numerous other claims I reserve on the record.

VIII.

Whether the Delaware District Court’s Orders (DI. (“District-Court”), (DI 16-17,

30-31, 59-60 (collectively, “District-Order”)), is now in error as a matter of law and as a matter

of fact, in light of with the passage of time the state proceeding has concluded. So, there is no

case to abstain from under the Younger abstention doctrine. So they case should be remanded to

be heard on the substance of the complaint and motions

IX.

Whether the District Court erred in applying Younger to dismiss my complaint

and motions by overlooking I asked for damages and relief unavailable in the state forum.

Whether the Court should have granted a stay as opposed to dismissal

Whether the District Court erred in applying Younger to dismiss my case,

complaint, and motions when I had no adequate opportunity to raise my federal claims or

ancillary claims for damages, equitable relief and nominal relief in state court

XI.

Whether the District Court erred in applying Younger when bad faith, harassment,

or extraordinary circumstances have arisen in my case that make a Younger abstention

inappropriate

XII.

Whether the Court abused its discretion by denying leave to amend the

Complaint, while applying the Younger abstention, when such amendments would certainly

overcome a Younger abstention

XIII.

Whether new and additional facts and arguments contained in my motions and

pleadings must be considered to prevent abuse of discretion, clear error of law, clear error of fact

and to prevent manifest injustice against me by denying me the opportunity to be heard to

safeguard my exercise of First Amendment rights, creating loss of First Amendment rights and

my interest in my ability to work in my profession

XIV. Whether the court deprived me of the 5th Amendment right to a fair proceeding or

violated 28 U.S. Code §§ 144 and 455, 29 CFR § 2200.68, or other applicable law by failing to

recuse Judge Phipps given Defendants attacks against me are based on my petitions against

Trump, Trump twice placed Phipp’s on a list of nominees for US Supreme Court, and Trump

will likely nominate Phipps’ as Supreme Court justice should he be reelected and an opening

occur considering the facts under objective standards, the probability of actual bias on the part of

VII

the Judge Phipps against me and in favor of Trump and my opponents is too high to be

constitutionally tolerable.

XV.

Whether the court deprived me of the 5th Amendment right to a fair proceeding or

violated 28 U.S. Code §§ 144 and 455, 29 CFR § 2200.68, or other applicable law by failing to

recuse Judge Scirica given the conflict of interest Judge Scirica chairs the Committee on Judicial

Conduct and Disability (“Judicial rules”). (DI 149). I made Constitutional arguments against the

judicial rules, against regulating the US Supreme Court by a Code of Conduct, self-discipline or

disciplinary rules, and made arguments against the State disciplinary rules and proceedings that

mirror the rules Judge Scirica is charged to revise and approve.

XVI. Whether the US Supreme Court errs as a matter of law by recognizing the

deception of appearance of justice instead of actual justice as an important state objection

somehow more important that the Constitutional application of the impartial rule of law by the

wicked partial selfish interest of the state’s own appearance, and if so whether this is not a

legitimate reason for part of the statute or regulations of the judiciary under 28 U.S. Code §§

144 and 455, 29 CFR § 2200.68, or otherwise. Since allowing partiality towards the state’s

appearance in light of fickle fads and popularity by the mob more than truth and justice creates a

biased partial unfair forum in violation of the 5th Amendment procedural due process safeguards

and equal protections component.

XVII Whether the Court should extend Brady violations to the Courts who intentionally

conceal evidence in favor of the accused to prejudice the accused case.

VIII

LIST OF PARTIES

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

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.

Kelly v Trump Chancery Court No. 2020-0809, Delaware Supreme Court No. 119-2021,

US Supreme Court No. 22-5522

Kelly v Democrats 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.

Reciprocal Disciplinary case I believe is stayed Delaware District Court No. 22-341.

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.

TABLE OF CONTENTS

Orders and Opinions……………………………………………………1

Jurisdiction……………………………………………………………...1

III.

Constitutional and Statutory Provisions involved……………….............1

IV.

Standard of Review is Strict Scrutiny…………………………………………1-4

Statement of the Case…………………………………………………………5-187

FACTS OF CASE…………………………………………………….5-126

1st Amendment establishment clause and Religious Freedom Restoration Act

against former Donald J Trump where I sought to substitute current President Biden for which

this case arises Kelly v Trump……………………………………………………….5-10

Unbeknownst to me at the time of the Delaware Supreme Court members’

misconduct, Delaware Supreme Court in Collussion with Defendants secretly sealed 4 docket

items in Kelly v Trump to conceal evidence in my favor without providing me notice or an

opportunity to be heard to hide my petitions regarding the State’s attacks against me to threaten

me in order to cause me to forgo the case in violation of 42 Section 1985, my 1st Amendment

rights to petition, religious belief, associate, speech, procedural due process, my right to be free

from intentional infliction of emotional distress and Equal Protections ……………..10

Kelly asserted Constitutional arguments against attorney disciplinary rules, Board

proceedings, Federal Judicial disciplinary and Disability proceedings, and regulations of the US

Supreme Court by a Code of Conduct or otherwise that would compromise the members

impartiality by partiality towards the rules sustaining their seats and instead of the impartial

application of the Constitutional rule of law to uphold the exercise of 1st Amendment individual

fundamental rights which do not conform to the courts or the majority’s, including mine. US

Amend I, V…………………………………………………………………………………..10-14

Timing, after Kelly v Trump concluded and the Civil rights proceeding was filed,

and the subsequent Attorney Disciplinary proceeding started, and ended, I discovered the DE

Supreme Court concealed evidence in my favor, DE Supreme Court Attorney Robinson signed

off on terminated Court staff, including a witness I noticed the Defendants I sought to cross

examine, and the DE Supreme Court sealed my petitions regarding the Sate’s misconduct in

Kelly v Trump to conceal evidence in my favor at the Nov 3, 2022 probable cause hearing, the

civil rights case, Kelly v Trump and reciprocal

cases……………………………………………………………..14-15

On 4/26/22, prior to the District Court’s Order dated 4/26/22 denying motion for

reagument, Kelly informed the District Court of the State eliminating 2 witnesses, Kelly’s desire

to amend the complaint once as a matter of right to conform to the facts, additional legal claim

and additional parties in a rolling motion when remanded back; assertions against Disciplinary

Rules 13 and 14, and proof the Delaware Supreme Court caused the interference in a letter by the

court to me copying Defendant agent of the Board dated 10/21/2020………………………15

The State committed attacks against me during 2020-2021 to interfere with and

cause me to forgo my case in Kelly v Trump, which included disparate treatment with religious

political animus, court staff writing on praecipe dated 10/5/20, and directing me to cross off local

counsel’s address on praecipe to prevent service to local counsel, court staff misleading me to

miss deadline for an order I did not know existed, sending Court of Common Pleas Judge

Kenneth S. Clark to attack me in public at a grocery store demeaning my faith in Jesus not I

money as God, and sending three threatening letters by the State to cause me to forgo Kelly v

Trump prior to the US Supreme Court’s denial of a writ………………………………….15-20

ODC’s letters threaten Kelly with punishment to compel her to violate her

previously asserted 1st Amendment religious objection to healthcare, and mental healthcare and

threaten actual punishment but for finding her religious beliefs in Jesus and citations to the Bible

as a source of her religious beliefs in defense of her private beliefs proof of disability…..20-21

On 10/25/21, Kelly Filed this civil rights law suit for monetary damages and

equitable relief for emotional distress, violations of procedural due process, Equal Protections

claims, First Amendment violations of private rights to petition, religious belief, exercise of

belief, speech and association, loss of employment opportunities, or other economic harm, harm

to my reputation, witness tampering, procedural due process violations and in violation of 42

USC §§§ 1983, 1985, 1988………………………………………….21-23

Probable cause hearing occurred where the Defendants accessed the docket

according to Lexis’s November 4, 2021 date. It is a delayed date, with evidence in my favor

sealed. The petition cites my religious beliefs and citations to the bible in Kelly v Trump to be

the reason for the petition……………………………………………………………….23

District Court Dismissed my Complaint under Younger. I filed a Motion for

Reargument and Motion to Amend the Motion for reagument. I showed the DE Members

participated in the State’s attacks. Since, I had an appeal in Kelly v Trump to the US Supreme

Court, I did not add the DE Supreme Court members initially because the writ of cert may be

granted in Kelly v Trump, and the case remanded back to the Court. I alleged additional

damages and claims. The State threatened to compel me to violate my asserted 1st and 6th

Amendment asserted right to self-represent as a religious-exercise, which caused emotional

distress so great a police made a wellness check. During check I told him I couldn’t find the

police report where I told the police people talked about shooting me. No report was made,

despite the fact I told the police. It may have been a police officer from my former gym outside

of his jurisdiction checking on my car because someone threw something at it…..23-36

10.

District Court denied my amended motion for a reagument under Younger. I

drafted 3 motions under FRCP R. 52(b), and 59 (e) for the Court to alter and amend the judgment

of the Court in its December 22, 2021 order to (1) include the availability of new evidence not

available previously available, and to later the order (2) to correct a clear error of law, (3) clear

error of fact, (4) and to prevent manifest injustice. I indicating my intent was cemented to add the

Delaware Supreme court and the members in the 3rd Motion. I included including additional

evidence and violations of my 1st, 6th and 14th Amendment rights including but not limited to

lack of notice, vitiation of my opportunity to be heard, denial of an opportunity to perform

discovery or call witnesses, emotional distress forming in the shingles, appointing counsel

despite my objection, denial of a fair impartial proceeding, which are within the scope of the

appeal I reserved in my motions for reargument…………………….36-52

11.

I filed a Motion to Amend my Complaint was as a matter of right, but accidentally

did not mail out the signature page. I moved the court to amend my complaint as a matter of

right to conform the complaint to the facts of the case in a rolling Motion. DI 58, and

continuously moved to add new evidence reserving my right………..52-59

12.

DE made a finding of disability causing reciprocal suits. Kelly asserted a physical

limitation under the ADA before the DE Supreme Court in the DE Disciplinary case and

reserved the potential claim on the record below……….59-66

13.

Judge Phipps’ created an obstacle so great as to vitiate my access to the US

Supreme Court to appeal the original disciplinary decision by denying my asserted right to fair

access to other courts by denying my Motion to stay the proceeding pending the US Supreme

Court’s determination of the original disciplinary proceeding, and by instead expediting the

hearing date before briefing was due…….66-72

14.

During my proceeding the Appellate Court below, reciprocating courts, and the

Defendant Delaware Supreme Court and staff punished me as to chill my First Amendment right

to petition to correct the Court staff’s docketing mistakes…………73-76

15.

Defendants the Board and Disciplinary Counsel violated Rule 9 and Rule h of the

disciplinary rules in additional ways by failing to provide documents 10 days in advance of any

hearing date to me and preventing me from calling witnesses by allowing me to self-represent

with fewer than the 10 days required to not only subpoena witnesses but to provide expected

testimony of witnesses to opposing counsel preventing me asserted right to call and cross

examine witnesses…………………………………………..76-79

16.

Kelly was denied access to the law library. Defendant Patricia Swartz in bad faith

lied to cause needless expenses in an attempt to prevent my petition. Delaware Supreme Court

refused to place my appeal on the record in full without fighting by taking additional steps to

place them on the docket………………………………..79-80

17.

Denial of access to the records where I am a party to discern if I was denied the

opportunity to be heard by failing to docket my motions………………..80-83

18.

Meghan Kelly’s Religious beliefs……………………..83-92

19.

Third Circuit denied Meghan Kelly motion to recuse Judge Phipps based on his

partial interest in punishing me for suing Trump to secure a potential Supreme Court seat by

Trump since he was a nominee for US Supreme Court and will likely be a nominee should

XII

Trump get reelected and based on relationships with Duquesne since I petitioned the law school

about rats in 2005…………………………………………………….92-97

20.

Third Circuit denied Meghan Kelly motion to recuse Judge Scirica based on my

pleadings against attorney disciplinary rules and regulations which mimic the rules he drafts, and

regulations of the US Supreme Court and federal Courts by eliminating the rules he is the

appointed chair on drafting to prevent US Supreme Court regulation, Constitutional arguments

against………………………………………………….97-105

21.

Justice Alito denied 30 day extension required to draft this appeal prejudicing my

ability to appeal. Kelly would consider retaining another attorney who got into trouble for doing

the right thing so long as I do not go into debt which violates my religious beliefs……..105-108

SUMMARY OF APPLICATION OF FACTS ABOVE TO THE LAW PLUS

ADDITIONAL REBUTTAL OF THIRD CIRCUIT’S FINDINGS……………….108-126

ARGUMENT……………………………………………………….126-187

The Delaware District Court’s Orders (DI. (“District-Court”), (DI 16-17, 30-31,

59-60 (collectively, “District-Order”)), is now in error as a matter of law and as a matter of fact,

in light of with the passage of time the state proceeding has concluded. So, there is no case to

abstain from under the Younger abstention doctrine. So they case should be remanded to be

heard on the substance of the complaint and motions………………..…………126-128

The Court erred in applying Younger to dismiss my complaint and motions by

overlooking I asked for damages and relief unavailable in the state forum. Whether the Court

should have granted a stay as opposed to dismissal……………129-142

The Court erred in applying Younger to dismiss my case, complaint, and motions

when I had no adequate opportunity to raise my federal claims or ancillary claims for damages,

equitable relief and nominal relief in state court……..142-146

The Court erred in applying Younger when bad faith, harassment, or

extraordinary circumstances have arisen in my case that make a Younger abstention

inappropriate………………………………………………………………………...146-148

The Court abused its discretion by denying leave to amend the Complaint, while

applying the Younger abstention, when such amendments would certainly overcome a Younger

abstention……………………………………………………..148-156

New and additional facts and arguments contained in my motions and pleadings

must be considered to prevent abuse of discretion, clear error of law, clear error of fact and to

prevent manifest injustice against me by denying me the opportunity to be heard to safeguard my

exercise of First Amendment rights, creating loss of First Amendment rights and my interest in

my ability to work in my profession…………………………………….156-173

The court deprived me of the 5th Amendment right to a fair proceeding or violated

28 U.S. Code §§ 144 and 455, 29 CFR § 2200.68, or other applicable law by failing to recuse

XIII

Judge Phipps given Defendants attacks against me are based on my petitions against Trump,

Trump twice placed Phipp’s on a list of nominees for US Supreme Court, and Trump will likely

nominate Phipps’ as Supreme Court justice should he be reelected and an opening occur

considering the facts under objective standards, the probability of actual bias on the part of the

Judge Phipps against me and in favor of Trump and my opponents is too high to be

constitutionally tolerable……………………………………173-175

The court deprived me of the 5th Amendment right to a fair proceeding or

violated 28 U.S. Code §§ 144 and 455, 29 CFR § 2200.68, or other applicable law by failing to

recuse Judge Scirica given the conflict of interest Judge Scirica chairs the Committee on Judicial

Conduct and Disability (“Judicial rules”). (DI 149). I made Constitutional arguments against the

judicial rules, against regulating the US Supreme Court by a Code of Conduct, self-discipline or

disciplinary rules, and made arguments against the State disciplinary rules and proceedings that

mirror the rules Judge Scirica is charged to revise and approve…………………175-.184

Whether the US Supreme Court errs as a matter of law by recognizing the

deception of appearance of justice instead of actual justice as an important state objection

somehow more important that the Constitutional application of the impartial rule of law by the

wicked partial selfish interest of the state’s own appearance, and if so whether this is not a

legitimate reason for part of the statute or regulations of the judiciary under 28 U.S. Code §§

144 and 455, 29 CFR § 2200.68, or otherwise. Since allowing partiality towards the state’s

appearance in light of fickle fads and popularity by the mob more than truth and justice creates a

biased partial unfair forum in violation of the 5th Amendment procedural due process safeguards

and equal protections component………………………………………………184-187

VI.

Conclusion…………………………………………………………187-190

XIV

APPENDIX

Appendix (hereinafter “App.”)

App 1-A

CONSTITUTIONAL AND STATUTORY PROVISIONS INVOLVED….1

App 1-B

Petition Letter requesting an exemption for bar dues for all attorneys facing

economic hardship dated January 7, 2021, which was denied…5, 6, 16, 17, 21, 22, 30, 96, 108,

118, 121, 141, 142, 123, 130, 131, 136, 137, 141, 142, 146, 149, 151, 183

App 1-C

Petition in response to denial of January 7, 2021 petition, with a new petition

letter dated February 5, 2021 wherein I requested an exemption for bar dues for all

attorneys…5, 6, 16, 108, 136, 137, 183

App 1-D

Separate sheet affidavit accompanying Motion for permission to appeal in forma

pauperis I supplied when I initially appealed the Delaware District Court decision to the Third

Circuit Court of Appeals wherein I indicated Delaware Supreme Court incitement of attacks ,

against me to cause me to forgo my religious freedom restoration act lawsuit against former

President Trump…5, 16, 108, 183

App 1-E

CONSTITUTIONAL AND STATUTORY PROVISIONS INVOLVED

continued, additional Delaware Disciplinary rules…………………………………….1

App. A

June 30, 2023 Order and opinion dismissing the case…1

App. B

April 20, 2023 Order and opinion dismissing the case……………….1,

App. C

108

June 22, 2023 Order denying the petition for a rehearing…………….1,

App. D

June 20, 2023 Order Denying 1. Motion to recuse Judge Scirica, 2. Motion

for a caveat to recusal for judicial consideration of drafting laws to prevent non-lawyers and nonjudges from practicing law or taking the place of people judges without government authority,

and 3. Motion for a Second Caveat to Motion for this Court to recuse Judge Scirica to move him

for judicial consideration of drafting laws to prevent judges from speaking engagements on

behalf of political think tanks such as lobbyists at the Federalist Society……………1, 18

App. E

July 10, 2023 Order Denying En Banc request and Motion for

Reconsideration of Order denying recusal of Scirica………………………………………….1

App. F

March 15, 2023 Order denying recusal of Judge Phipps………………………1

App. G

January 6, 2023 Order granting an extension of time and denying of a

stay……………………………………………………………………………………………..1

App. H

February 9, 2023 Order Denying a stay pending the US Supreme Court’s denial of

Judge Phipps Jan 6, 2023 Order denying a stay……………………………………………….1

App I

District Court Order and opinion dated November 2021 dismissing my case under

Younger………………………………………………………………………………………..1, 24

App. J

District Court Order and opinion dated December 22, 2021 dismissing my case

under Younger………………………………………………………………………………….1

App. K

District Court Order and opinion dated April 26, 2021…………………1, 115

App L

Memorandum order dated 12/28/23……………………………………..1

App. M

Order granting ECF Access and exemption to PACER fees, dated January 5,

2023……………………………………………………………………………………1,

Exhibit A

(DI 2) Initial Complaint Kelly v Trump Case No. 2020-0809, filed 9/22/2020…2,

5, 6, 8, 9, 16, 18, 19, 24-26, 60, 108, 115, 121

A-4

Kelly’s Motion to the Delaware Supreme Court to rein in its arms from unlawfully

pressuring me to forgo or impede my case to protect my free exercise of religion, and exhibits

thereto, , including December 1, 2020 letter to Master Patricia Griffin of the Chancery Court

regarding my belief I received disparate treatment by the court’s staff based on religious belief,

political association or poverty; emails, Internal Exhibit, Oct 19, 2020 letter to Patricia Griffin

regarding I am acting as a party not as an attorney, DE-Lapp threatening email, Internal Exhibit,

letter dated May 21, 2020, (3DI 121-11, DI 4)…5, 9, 10, 16, 18-19, 21, 27-30, 108, 131, 136,

171, 182

A-5 Kelly’s motion for the Delaware Supreme Court to require the recusal of the Honorable

Justice Collins J. Seitz, and related exhibits thereto, proof of payment of bar dues, emails to

Mark Vavala confirming he did not incite the investigation, Internal Exhibit Letter from the

Court in response to my request for exemption of bar dues for all attorneys facing hardship,

dated February 5, 2021; attachment relating my concerns relating to recent US Supreme Court

cases I disagreed with. (3DI-121-12, DI 4)…5, 9, 10, 16, 18-19, 21,27-30, 108, 131, 136, 171,

182

Exhibit B

First Page of letter by Defendants dated 8/23/2021, showing Defendants claim

“several pleadings in the “Court of Chancery and the [Delaware] Supreme Court in connection

with the lawsuit Kelly v Trump” where my religious beliefs are in issue as the source of the

Defendants’ interference in Kelly v Trump…5, 6, 18-19, 23, 60, 78-79, 108, 122, 132-137, 139,

182

Exhibit C

Page 7 of Defendant’s petition to the Board, dated 11/3/2021, initiating a

disciplinary proceeding where they alleged the reason to discipline me is based on my references

to the Bible in Kelly v Trump where my religious belief are in issue……………5, 6, 18-19, 23,

60, 78-79, 122, 132-137, 139

Exhibit D

Exhibits showing belief of danger based on partnerships between not only church

and state but government backed and condoned foreign and private partners inciting private

attacks based on perceived religious or political association or beliefs, including Email to Bo at

the Delaware Department of elections, forwarding an email to Jesse Chadderon at the democrat’s

office where I was concerned about a neighbor threatening me for my sign because he previously

threatened to ram my car if I park it on my parents side lot, and he allegedly threatened to use his

gun should someone at the board of the development come onto his property to inspect it without

XVI

authorization, pictures of substance thrown at my car, Police report concerning 2 bullets shot into

the home of Greg Layton hitting the wall above the dining room table as he and his wife sat there

but for his political beliefs incited by Trump-religion, some of my signs I created which caused

outrage and attacks, excluding Impeach [Trump] Serve your country not your seat, excluding

Impeach [Trump] No one is above the law, No one is below the law.; Exhibit 43 which includes

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

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

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

seeks Federal Consideration of Health Care Proposal,

3. Meghan Kelly’s teaching certificate, which goes to credibility. I learned psychology

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

something about health.

4. Meghan Kelly’s redacted law school transcript to show she took a course Health Care

Finance and the course Law and Medicine while attending Duquesne School of Law.

5. Meghan Kelly’s redacted undergraduate college transcript to show she took relevant

courses related to

History of Western Medicine

Economics

Medieval Philosophy

Psychology courses

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

due to dehydration when I have my period. I lose five pounds every month. This is still

a challenge. I must assert my right to live because many people serve Satan by not

wanting to be inconvenienced to care to adapt to safeguard my life, or the lives and health

of others.)……………………………………5, 6, 8, 21, 23, 34,53, 60, 61, 63, 78-79

Appendix N July 12, 2021 letter from Kelly to the Delaware Supreme Court concerning

Chancery Court staff Arline Simmons instructing me to cross of the Delaware Civil Process

Clerk’s address to prevent service, and the praecipes thereto, attached praecipes with the crossed

off civil process clerk’s address, dated October 12, 2020………………16, 122

App. 0

Chancery Court Staff wrote on praecipe confusing Court dated October 5, 2020, a

court stamped Copy of the Oct 12, 2012 praecipe to local counsel with address crossed

off…………………………………………………………………16, 122

App P

11/6/20 letter to Master Patricia Griffin in Kelly v Trump…16, 122

App Q

Letter to the Court regarding difficulty accessing documents. Delaware Supreme

Court indicated Kelly v Trump documents were sealed without notice to me, not destroyed. The

correction made by District Court on 10/27/21 were not yet made public. So, I could not see

them until I was granted ECF access

XVII

Cont App Q Court Link docket of Kelly v Trump showing A-4 and A-5 were invisible not

accessible and that the docket was last accessed 11/4/22, the date of the probably cause hearing

without the sealed documents.

Cont. App. Q DE Supreme Court Docket where I point out DI 21 and 16 are missing. I

discovered DI 40 and 41 were also missing…10, 14, 15, 122

App R Email from file and serve with graph confirming 4 items necessary to my defense in

Kelly v Trump, the disciplinary proceeding, reciprocal proceedings and the civil rights case were

secretly sealed by the DE Supreme Court without notice or opportunity for me to be heard with

dates items were sealed and dates of any changes as of the email’s date…10, 14, 15, 122

App S

File and Serve Graph of sealed documents from file and serve in a readable

format on one page…10, 14, 15, 122

App T

Letter dated 4/26/22 filed before Order by Chief Judge Colms that same day

wherein I assert constitutional violations regarding certain rules and regarding the proceeding,

indicate my intent to move the court to amend the complaint once as a matter of right in a rolling

motion, I also submit videos an additional information on the record that had arisen notably my

discovery of two Court staff were fired to prevent their testimony in my favor to hide their

whereabouts from me.

Continued (“Cont.”) App T Table of contents to this April 26, 2022 letter, included are videos

with this letter

Cont. App T

Continued Email to ODC concerning stop interfering with my case Kelly

v Trump, and forwarded emails to school staff. Also emails regarding Judge Smalls and Judge

Slights showing place of origin animus telling me to go back to PA or calling me a Philadelphia

lawyer as if place of origin denotes value or worth when everyone has rights even those born in

PA like me. …11, 13, 14, 15, 16, 57, 115, 118-119, 122, 125, 167, 176-184

App T-2

Respondent Meghan Kelly’s Motion for good cause, 1 Pursuant to Supreme Court

Rule 9, to Unseal the Record, 2. to declare self-regulation of attorneys, other Professions, and

judges unconstitutional, making business above the law, by making the dictates of professionals,

or bureaucrats within agencies, as opposed to laws enacted by congress people, checked by the

vote of the people, the law, and 3. in lieu of and in the alternative, eliminate the secret trial

requirements of professionals before Boards, including the Board on Professional Responsibility,

requiring the choice of an open or confidential forum left to the accused professional, instead of

requiring a secret proceeding, concealing the accused’s defense, to the advantage of the accuser

state, in violation of equal protections, and due process 1st and 14th Protections, dated

8/15/22………………………………………………….11, 13, 15, 57, 62, 167, 176-184

App T-3

Respondent Meghan Kelly’s Motion to 1. declare the Reporting Requirements

unconstitutional, requiring by written rule I violate my 5th Amendment right not to testify

against myself to the government in order that the government may have evidence to prosecute

me, 2. Declare the Case and Controversy requirements are not met in the system of attorney selfregulation, dated 8/19/22………………………11, 15, 57,

XVIII

App T-4

Respondent Meghan M Kelly’s Motion for permission to use electronic filing, and

waiver of paper copies before this Honorable Court, and an exemption from PACER costs to

prevent unaffordable costs from becoming a substantial burden upon my access to the courts, and

compelled violation of my religious beliefs against indebtedness in order to exercise my right to

petition the Court in my defense of the exercise of fundamental rights, dated

6/20/22…………………………………………11, 13, 15, 57, 167, 176-184

App T-5

Plaintiff’s 79th Affidavit, DI 194, dated September 7, 2023 regarding my gratitude

when US Supreme Court staff talk to me including Danny Bickle, my concern Justice

Kavanaugh appeared to encourage regulation of the US Supreme Court

AppT-5 Continued (“Cont”). Letter to the US Supreme Court members addressed to Chief

Justice Roberts regarding Please refrain from addressing Senator Whitehouse’s publicized

disciplinary complaint against Justice Alito as it interferes with my case and controversies as to

deprive me of the opportunity to petition this court in two cases regarding the same issue

Cont. App T-5 Exhibits on an Agenda to Eliminate people in the law to eliminate the

government that restrains entities from getting as much as they can for as little unrestrained from

the just rule of law from oppressing, killing, stealing or destroying human life, liberty or health

for the bottom line, including internal exhibits

➢ Obituary of Richard Goll, a Delaware attorney who was exploited by an out of

state real estate company practicing law without a license

➢ Newspaper Article I drafted in the Coastal Point on a proposition on how to

resolve the fact non attorneys are practicing law without a license

➢ Article by the Venus project How can laws be eliminated regarding a new system

to replace governments after 2050

➢ Excerpts from the Book Shaping the Fourth Industrial Revolution By Klaus

Schwabb, Founder of the World Economic Forum and Chairman with Nicolas

Davis, Copywrite 2018, Published in the United States by Currency, an imprint of

the Crown Publishing Group, a division of Penguin Random House LLC

➢ Excerpts from the Fourth Industrial Revolution by Klaus Schwabb

➢ Article by World Government Summit Could an AI ever replace a judge in court?,

dated 2017

➢ Article Robot justice: China’s use of Internet courts By Tara Vasdani This article

was originally published by The Lawyer’s Daily

(https://www.thelawyersdaily.ca/), part of LexisNexis Canada Inc

➢ Excerpts from The Great Narrative for a Better Future, by Klaus

Schwabb……………11, 13, 57, 167, 176-184

App U

Letter dated April 13, 2022, DI 55 discussing new fact I was denied admission

into the law library and other facts arising showing additio15, nal potential claims or injuries

continuously arising. DI 55

Cont App U, Exhibit B 35 pages of pages of procedural history, attached. I Incorporate the other

exhibits by reference….15, 142, 144, 163

App V

DI 51, March 10, 2022 to Court regarding the Clerk confirmed the entire Court

reviewed request for bar dues, Denied an opportunity to be heard on Motions dated, 12/18/21,

XIX

12/31/21, 1/15/21 and 1/31/22, denied an opportunity to be heard before it was too late and my

rights were vitiated by denying notice, discovery, ability to call or cross examine hidden

witnesses and a fair opportunity to present my defense , in the Board’s ruling it required loyalty

to organization as opposed to the Constitutional rule of law which violates the superseding

Constitutional rule of law…

App V Cont Exhibit A Board finding that required my loyalty to mere people and

organizations preempt the Constitution and the rule of law as opposed the mark of the beast the

lusts of those who commit human sacrifice of life and liberty for material gain, convenience,

avoidance of cost, position, pride, power or profit.

App. V Cont. Exhibit B Order dated 1/11/22 Order denying my emergency appeal dated

1/12/22if the Board’s denial of my objection to notice, asserted rights to call witnesses, perform

discovery, adequate opportunity to prepare to meet my accusers as I overcame the shingles, and a

fair proceeding

App V Cont. Exhibit C Order dated 1/18/22 denying my appeal of the Board’s email

order denying an extension of time to allow me to adequately prepare for the proceeding.

App V Cont. Exhibit D Email Order dated 1/10/22 I appealed to the DE Supreme

Court on 1/12/22 which it rejected 1/18/22 holding

“The Board plans to move forward with the virtual hearing as scheduled...”

App. V Cont. Exhibit E

Email where I asserted my right to a formal appealable

order and other rights. The Board lied by granting an extension for a reason my motion did not

without sufficient days the rule required to call witnesses 8, when more than 10 days is needed

with postage assuming 3 and 10 days required to call witnesses. The original date was

insufficient time to call witnesses in the sham proceeding against me too. There is no way I

could have adhered to the required notice to call witnesses in the sham proceeding against me

especially since the DE Supreme Court participated in hiding two witnesses by firing them from

the Chancery Court…………………………………….15, 18, 53, 55, 79, 163

App W

Letter to the Court regarding the emergency 2/14/22 TRO, Preliminary

injunction and emergency motion and notice of new immediate danger of compelled violations

of my religious beliefs, with an outline of the documents filed in the Delaware Disciplinary

proceeding, excluding other exhibits dated March 30, 2022 by mistake, filed March 29, 2022. DI

53, with exhibit B thereto, not all of the exhibits showing the table of exhibits in the Disciplinary

proceeding, including my ignored filed, but not returned or rejected motions which I do not

believe were docketed in a case against me No 58. Clerk refused to provide docket items, or

proof of materials on the record……………………………………14, 15, 21

App X

Plaintiff’s Motion for an urgent Emergency preliminary restraining order

to be applied immediately, with a waiver of bond, to prevent immediate and irreparable injury by

compelled violations of my religious beliefs, but for the exercise of religious beliefs, filed

2/14/22

App X Cont. Exhibit A

Jan 18, 2022 request for an order in an appealable form,

instead of an order in form evading opportunity for review

App X Cont. Exhibit B

Jan. 11, 2022 request for a copy of the docket, the record to

the person acting as clerk or administrator to the Board. My request was ignored,

App X Cont. Exhibit C

Jan. 31, 2022, Email to the Board and Patricia Swartz

requesting she please send the state's exhibits Patricia and the Board required due Jan. 31,

overruling my objection to refer to the record

App X Cont. Exhibit D

Jan 31, 2022, email requesting Exhibit names, and

forwarded E-mail espousing facts and religious beliefs

App X Cont. Exhibit E

Jan.31, 2022 email asking for exhibits in attachment form

with name

App X Cont. Exhibit F

Jan. 25, 2022, Respondent's Motion for Dismiss for lack of

notice in the state forum

App X Cont. Exhibit G

Jan. 31, 2022, RESPONDENTS MEGHAN KELLYS

MOTION FOR A PROTECTIVE ORDER PREVENTING MENTAL EXAMINATION OF

RESPONDENT AS A GOVERNMENT COMPELLED VIOLATIONS OF HER RELIGIOUS

BELIEF IN JESUS CHRIST

App X Cont. Exhibit H

Email dated January 1, 2022 concerning immediately

noticed errors in transcript emailed to me on Jan 31, 2022

App X Cont. Exhibit I

Email dated January 31, 2022 to Board and Patricia

regarding serious errors of court reporter, space for faith, I got cancer for I got the answer, and

other errors

Cont. App X Exhibit J

Email to Board and Patricia regarding court

reporting errors regarding hegemonic state, Not head demonic state, highly prejudicial inaccurate

transcript of hearing

Cont. App X Exhibit K

my filed corrections of the transcript via Letter and

attachment of corrections, with reserve to file additional corrections

Cont. App X Exhibit L

Resubmitted second petition to the Delaware Supreme

Court regarding license filing dues, dated Feb 5, 2021, resubmitted Feb. 1, 2022

Cont. App X Exhibit M

Feb. 1, 2022, Third request relating to attorney dues, # 14

Exhibit N, order granting third request relating to lawyer dues

Cont. App X Exhibit N

Feb. 26, 2022 granted request for 2022 for me

only……………………………………………………….14, 21, 53-55, 79

App. Y.

Letter dated May 21, 2023 requesting the Clerk of Court to resubmit my

application in Kelly v Swartz for an interim stay, dated 2/11/23 rejected by justice Alito in this

case under No. 22-6783 and NO. 22 A 747 incorporated herein by reference…………………14,

App Z

(DI 188-9)Email to Clerk of DE Supreme Court Lisa Dolph dated January

10, 2023, wherein I request all the documents regarding appointed counsel despite my religious

objection and objection on the 6th Amendment grounds. Lisa’s response, she would not give

documents to me to see show whether I was deprived of the right to petition to cover up more

Supreme Court misconduct January 10, 2023.

App Z Continued (DI 115) Plaintiff Meghan Kelly’s Tenth Affidavit, filed 2/15/23

regarding the Delaware Supreme Court denied me access to or a copy of the records in the case

against me No 58 appointing counsel, depriving me of seeing whether my prior objections to

appointed Counsel were not docketed as to deprive me of the opportunity to be heard in defense

of ny fundamental rights.

XXI

App. Z Cont. Exhibit A (DI-115-4) Email, dated January 11, 2023 to DE Supreme

Court Clerk citing case law requesting the records and asserting the right to the pleadings used

against me in No. 58 in appointing counsel.

App. Z Cont. Exhibit B (DI 115-5) Order dated December 30, 2021 Motion to selfrepresent in Case No 541, Board Number 115327-B DE Supreme Court No 58, fewer than two

weeks before the hearing date with Court closed January 1, 2023.

App Z Cont. Exhibit C (DI 115-6) December 16, 2021 Email to Opposing counsel and

US Attorney General David Weiss regarding my religious objections to appointed counsel

App Z Cont. Exhibit D (DI 115-7) Obituary for Dick Goll, Esq. pamphlets for when I

ran for office in 2018………………………………………………………….115

App. AA

(DI 209-2,3) Docket sheet for US Supreme Court matter Kelly v PA ODC,

No. 7695 showing the US Supreme Court denied my petition on October 2, 2023

(DI 209-3) Meghan M. Kelly’s Petition for a rehearing of this the US Supreme Court’s

Denial of Petition for a writ of certiorari to appeal a decision by the Supreme Court of PA, dated

October 2, 2023

(DI 209-4) Petitioner Respondent Meghan Kelly’s petition for writ of certiorari to appeal the

Pennsylvania Supreme Court dated February 28, 2023, filed May 30, 2023………………14, 68-76

App. BB (DI 209-6, 7) US Supreme Court docket sheet for Kelly v US Court of

Appeals for the Third Circuit, No. 22-6584, denied March 27, 2023

(DI 209-8) On Petition for Writ of Certiorari to the United States Court of Appeals for the

Third Circuit, Case Number Case Number 22-8037, signed 1/12/23……………14, 68-76

App. CC

(209-10-11) Docket sheet for US Supreme Court Kelly v Trump, No.

21-5522, petition denied 11/1/21

(209-12) Petition for writ of certiorari of the Delaware Supreme Court in Kelly v

Trump…………………………………………………14, 68-76

App. DD

Motion to Reopen Case to Consider pleadings filed July 4, 2023 and July

5, 2023, Motion to Reopen the case to excercise the 1st Amendment right to petition under FRAP

40 Motions for reargument on denied motions and another potential motion, dated July 10, 2023

Internal Exhibits to App. DD Exhibit P Letter by US Supreme Court, dated 2/7/23,

rejecting my petition as exceeding the page limit since I filed a motion to exceed the page limit

prior to not simultaneously therewith

App DD Cont Proof I timely filed a petition of the original disciplinary case 2/3/23, but it

was returned, with the new due date conflicting with my civil rights case. I do not have the paper,

money or resources to fight it simultaneously.

App DD Cont. Cert pool confirmation the conference for my petition before judgment in

this case would be too late to grant me relief rendering it moot, April 21, 2023.

App DD Cont. Docket Sheet in this Matter NO. 22-6783

Internal Exhibits to App. DD Exhibit Q Letter dated 8/24/22 to third circuit to

correct a Court staff error that prejudices my case by filing documents from another matter, the

reciprocal disciplinary matter onto this case.

XXII

Internal Exhibits to App. DD Exhibit R Respondent Meghan Kelly’s Motion pursuant

to Federal Rules of Appellate Procedure, Rule 10 (e), to Strike DI 77 as misfiled to be rescanned

in to the Correct Matter No. 22-8037, without lifting my motion for a stay, dated 8/24/22

Internal Exhibits to App. DD Exhibit S Petitioner Plaintiff Meghan Kelly’s

Corrected Second Motion pursuant to Federal Rules of Appellate Procedure, Rule 10 (e), to

Strike 3DI 77 as misfiled to be rescanned in to the Correct Matter No. 22-8037, without lifting

my motion for a stay, dated August 25, 2022

Internal Exhibits to App. DD Exhibit T Petitioner Plaintiff Meghan Kelly’s Motion

pursuant to Rule 40 for a panel Reargument on Order Dated August 31, 2022, and move for a

Judge, not the Clerk of the Court to render an order on this Motion for Reagument, and her

Corrected Second Motion pursuant to Federal Rules of Appellate Procedure, Rule 10 (e), to

Strike 3DI 77 as misfiled to be rescanned in to the Correct Matter No. 22- 8037, without lifting

my motion for a stay, and Motion to strike 3DI 77, and exhibits thereto, and related document,

due to the fact I brought up mistakes or potential misconduct by the clerk’s office to correct, to

preserve impartiality, dated August 30, 2022

Internal Exhibits to App. DD

Docketed proof of postage to show the Clerk

threatened me with sanctions based on a false allegation that I sent the document through the

emergency email, when the proof of postage was on the record, the case manager and court had

prior knowledge I was mailing the documents, and to cover up the mistake or misconduct in

placing documents from another matter on this case. (Case: 21-3198 Document: 87-10 Page: 1

and Page 2 Date Filed: 08/30/2022)

Internal Exhibit to App. DD.

Appellant Respondent Meghan Kelly’s Motion to

Correct the Record, specifically District Court Docket Item, DI 12 under Rule 10 (e)(2)(c) and

Rule 27, to show I sought to correct the record in the Eastern District Court case, and the Court

through Judge Diamonds also too retaliated against me, dated May 27, 2023.

Internal Exhibit to App DD another person’s filings in my Eastern District of PA case,

showing we need court staff to correct misfilings and we need to be able to assert our rights for

am accurate record without retaliation, (Case 2:22-mc-00045-PD Document 12-45 (12-46)(1247) Filed 10/18/22, with cert of word Court 22-45, DI 55, and also placed on 211490……………………………………………………………………14, 68-76

(DI 77-3-DI 77-4) Respondent’s reply to ODC’s Corrected Response to Respondent’s

Objections to the Report and Recommendation of the Board on Professional Responsibility, June

7, 2022………………14, 15, 65, 109-110, 118-119

(3DI 98) Appellant Plaintiff Meghan Kelly’s Opening Brief moving the Third Circuit Court of

Appeals to vacate the Delaware District Orders (DI. DI 16-17, 30-31, 59-60), and to remand the

matter to the Delaware District Court for consideration, dated October 22, 2022 …14, 62, 115,

118-121

(3DI 199-1) Appellant Meghan Kelly’s Petition for a Panel Rehearing , June 3,

20214,…….14, 15, 62, 109-110, 118-119

XXIII

(DI 20) Plaintiff’s Motion for Reargument, filed 11/8/21, Delaware District Court No. 211490, and exhibits thereto…

(DI 20) Cont. Exhibit 1 ODC’s Petition to Transfer Plaintiff to disability

(DI 20) Cont Exhibit 2 Email to Defendant Patricia Swartz, regarding, “I have no

working phone, and my computer is going into repairs. My car broke down at Delmar last week,

and I am going to need maintenance. So, I may not be reachable for a week or so. I have other

religious objections to appointed counsel, as going into debt is against my religious beliefs.

Please hold off on filing. I would like to talk with you concerning my religious objections to

appointment of counsel, and would like to hear your concerns, even if you prefer to

communicate via email. Instead, of wasting resources. I prefer we discuss matters directly, and

resolve disputes and misunderstandings without litigation, in your proceeding against me, or at

least reduce costs by unnecessary mailing….”

(DI 20) Cont. Exhibit 3 Oct 26, 2021 Email regarding calling Justice Seitz as a witness

in civil rights law suit.

(DI 20) Cont Exhibit 4 Nov 6, 2021 Email to Defendant regarding it appeared Justice

Traynor was seeking jury instruction in federal court for a lawsuit against me

(DI-20) Cont Exhibit 5 Pleading to expedite the case, filed Nov. 6, 2021

(DI 21) Plaintiff’s Motion to Amend Plaintiff’s Motion for reargument, and exhibits thereto,

including Plaintiff’s Amended Motion for Reargument filed 11/9/21…8, 12, 15, 21, 24, 29-3036, 109-110, 115

(DI 21) Cont Exhibit 1

Proof of cert of mailing

(DI 21) Cont Exhibit 2.

Email to Counsel concerning my computer needs repairs

(DI 21) Cont Exhibit 3

Email from Computer repair warranty confirming the

computer is in repair

(DI 21) Cont Exhibit 4

Confirmation I could not file my attorney registration

inactive since a disciplinary proceeding began

(DI 21) Cont Exhibit 5

Police report when my neighbor threatened me due to my

signs

(DI 21) Cont Exhibit 6

Pictures of substance thrown on my vehicle.

(DI 21) Cont Exhibit 7

Plaintiff’s Amended Complaint

(DI 21) Cont Exhibit 8

Blackline of changes from motion for reagument to

Plaintiff’s Amended Motion for reagument……8, 14, 21, 29-30-36, 24, 109-110, 115

(DI 34) PLAINTIFF’S MOTION TO AMEND FINDINGS OF FACTS AND ALTER THE

ORDER, DATED DECEMBER 22, 2021, BASED ON NEW FINDINGS OF FACT, TO

PREVENT, CLEAR ERROR OF FACTS, CLEAR ERROR OF LAW, AND TO PREVENT

MANIFEST INJUSTICE and internal exhibits, Table of contents and the following

exhibits……14, 37-42, 115

(DI 35) TABLE OF CONTENTS

(DI 35) Cont. EXHIBIT A

First Page of Defendants letter to me dated, August 23,

2021, showing the reason for the law suit against me to retire my license was the Delaware

Supreme Court pleadings too.

(DI 35) Cont. EXHIBIT B

Pages of the Complaint relating to claims for damages for

infliction of emotional distress

XXIV

(DI 35) Cont. EXHIBIT B 2 Letter Dated December 1, 2021, regarding harassment by

Defendants, regarding my Answers were sent with confirmation, and resent, and additional facts

relating to the case

(Internal exhibits) Exhibit 1 return receipt confirmation, and receipt.

Exhibit 2

Electronic signature item was delivered

Exhibit 3

Email dated November 30, 2021, to Defendant regarding confirmation of

Answers, and my religious objection to Ms. Miss and Mrs., Jesus teaches us not to use

titles

Exhibit 4

Email dated November 28, 2021 responding to Defendant about physical

delivery, not delivery through email.

Exhibit 5

Receipt and return receipt of the second set of answers I spent hours

printing out, and paid postage, dated November 30, 2021

Exhibit 6

Email from Defendant indicating November 30, 2021 they received the

answers, which is a lie, since I did not mail out the second set until this date, and the

confirmation indicates it was delivered November 22, 2021

Exhibit 7

November 6, 2020 to Master Patricia Griffin in the Delaware Chancery

Court relating to Kelly v Trump, regarding the Court’s staff booby trapped me and my

concern about Trump inciting an insurrection as an excuse to kill his own people to stay

in office under a national emergency, a civil war, with attached statutes regarding the

President’s authority to use force against his own people in an insurrection, and

newspaper clips where force was used or allowed by President Trump, when might

makes wrong, not right.

(Attached) (Exhibit A) 10 USCS Sections 252, 253, 254

(Exhibit B) Newspaper article, New York Times, Armed Agents are allowed to

oversee ballot-Counting venues, by Katie Benner, 11/5/2020, Business Insider,

Federal officers sent to Portland by Trump teargassed protesters, despite being

told to leave by the mayor and governor, dated 7/17/2020

(DI 35) Cont. EXHIBIT C Email and letter from arm of the Delaware Supreme Court DeLapp, threatening me for my petition to the Court for relief on attorney license dues.

(DI 35) Cont. EXHIBIT D

First page of an Order by the Delaware Supreme Court

dated July 7, 2021, in Kelly v Trump by Justice Vaughn, Traynor, and Montgomery-Reeves

(DI 35) Cont. EXHIBIT E

Letter to the Court, dated November 23, 2021, regarding

my intent to object on subject matter grounds, and reasons the Court does not have subject

matter.

(DI 35) Cont. EXHIBIT F

Letter to court, dated November 22, 2021, regarding my

intent to object to appointment of counsel on religious grounds.

(DI 35) Cont. EXHIBIT G

Letter Motion to the Board, dated December 18, 2021,

regarding intent to object to appointed counsel, request to postpone hearing, request time for

discovery and a determination on counsel

(DI 35) Cont. EXHIBIT H Respondent Meghan Kelly’s Motion for Reconsideration of Order

dated December 13, 2021, appointing counsel despite my Notice of intent to object, and

objection of improper service of the Board’s notice of hearing

(Internal Exhibits) Exhibit 1, the Delaware Supreme Court Order relating to Counsel,

dated December 13, 2021

Exhibit 2, Letter from Appointed Counsel and Notice of a hearing dated December 10,

2021, received indirectly by email December 17, 2021

XXV

Exhibit 4 Email to appointed counsel after I declined forced representation concerning

another idea for the court to entertain.

Attachment to Exhibit 4, Five Articles of Impeachment I proposed and

contacted all 541 federal law makers about

Exhibit 5, the In Forma Pauperis which discussed the Delaware Supreme Court's

behavior and the burden this petition has upon me from preventing me from rejoining my

old law firm where I would be performing real estate settlements and using the company

car. So, I could give the car my parents gave me back. My dad needs a car.

Exhibit 6 Email to Attorney Generals regarding DE Supreme Court concerns, and

religious beliefs

Attachments to Exhibit 6, Exhibit 3, Email to the Delaware Supreme

Court regarding forced violation by swearing in without honoring my

request to affirm

Exhibit 4 Letter to family court regarding performing family law

violates my religious beliefs

Exhibit 5 (Not included) regarding judicial partiality was not included

though attached and cited in the Email of Exhibit 6. I included it in

another exhibit to the Motion for rearmament, Exhibit 8.

Exhibit 6 My E-mail directed to Senator Carper regarding using words

not weapons to defeat ISIS/ conduct the government performs by funding

charities which funds ISIS/evil under the guise of good/charity to reward

violence/ using education to prevent leaders from using government

established religion for their own vanity.

Exhibit 8 Proposals sent to law makers to prevent oil drilling.

Revelation 11:18 provides, there will be a time to "destroy all who have

caused destruction on the earth.”

Exhibit 2 My lawsuit against the democrats to allow me to run for office

without violating my religious beliefs by forcing me to collect donations

or signatures in violation of Matthew 6:1-4.

Exhibit 7 E-mail to Attorney Generals regarding Delaware Supreme Court partiality

concerns, objection to counsel as compelled forced violations of my religious belief, and

other concerns.

Exhibit 8 Letter to the Delaware Supreme Court, dated October 1, 2012, regarding

Judicial partiality and religious beliefs regarding preventing partiality in the courts

Exhibit 9 Letter dated November 22, 2021 to DE Supreme Court providing notice of

intent to object to appointed counsel

Exhibit 10 Communication to my former employer, as recent as August 6, 2021, before

the August 23, 2021 threatening letter.

(DI 35) Cont. EXHIBIT I Letter to the state court, dated December 21, 2021, concerning I

declined representation from counsel, per attached letter to appointed counsel, and requested the

court honor my motion. For reconsideration of the order dated December 13, 2021 appointing

counsel, despite my objection.

(DI 35) Cont. EXHIBIT J Letter to the Board of Professional Conduct of the state of

Delaware and the Delaware Supreme Court, dated December 29, 2021, two weeks from the

hearing, concerning the court’s and board’s determination of postponement of the hearing in the

XXVI

interest of justice, and status of a determination of my 6th Amendment right to selfrepresentation.

(DI 35) Cont. Internal Exhibits (Exhibit A) First Page of the Office of Disciplinary’s April 23,

2021 letter indicating the Supreme Court’s pleadings as a source of their concern.

(Exhibit A part 2) Page 2-3 of Defendants petition showing the reason why

they bring the state law suit against me is for my religious beliefs, citing the bible

as authority for my beliefs, and their inability to understand my beliefs in Jesus.

(Exhibit B) E-mail to Attorney Generals, dated December 16, 2021, showing my

distress at appointment of counsel, in the form of tears, admissible present sense

impression, putting planning to prevent an economic crash on the back burner.

(Exhibit C) November 23, 2021 letter to DE Supreme Court indicating I intend to

object on subject matter grounds and why.

(Exhibit C part 2) Email to Attorney General, dated December 15, 2021,

concerning PACER, and showing emotional distress, and the need to protect free

exercise of religion from the forced worship of money by the state, and

discussions of the planned, preventable, reversible economic crash.

(Exhibit D) Certificate of Service of Respondent’s Motion for Reconsideration of

Order Dated December 13, 2021, appointing counsel despite notice of my intent

to object, and objection of improper service of the board’s notice of a hearing,

dated December 21, 2021, (This shows I gave the board a copy a day after I

served opposing counsel and the Court)

(Exhibit E) Email to Defendant, dated November 4, 2021, objecting to improper

service of the August 23, 2021 letter and requiring paper mailed copies, also

objecting to the appointment of counsel on religious grounds, and grounds of

harassment and intentional infliction of emotional distress, providing notice to the

Defendant appointment of counsel uniquely upsets me, and copying loved ones

for my safety.

(Exhibit F) Email, dated December 22, 2021, to Defendant opposing appointed

counsel

(Exhibit G) E-mail dated December 21, 2021, to the Court, Board and

Defendant, indicating I did not accept representation from appointed counsel, and

requested a docket, and an attachment of the

December 21, 2021 letter objecting to counsel, attached letter to Counsel

declining representation, dated December 20, 2021

(Exhibit H) Email dated, December 22, 2021, E-mail to court about

representation forwarding my email to counsel showing I fired him.

(Exhibit I) E-mail dated, December 27, 2021, to the court regarding concern not

all documents were filed with the court, and attached docket.

(Exhibit J) E-mail dated, December 28, 2021 to the Court, indicating appointed

counsel did not have the documents I filed, and the Court did not send him all of

the documents I sent, which may be needed in case of an appeal.

(Exhibit K) E-mail dated, December 23, 2021, to the Court regarding my

religious oppositions to expert examinations, and conformation of receipt of

filings, with attached filings for the Monday December 20, 2021 Motion filed

with the court and board.

XXVII

(DI 35) Cont. EXHIBIT K Email, dated Jan. 6, 2022, one week from the hearing, I sent to the

Board of Professional Conduct of the state of Delaware and opposing counsel to check on the

status of my motion to postpone the hearing scheduled Jan. 13,

2022……………………………14, 37-42, 115

(DI 39)

PLAINTIFF’S SECOND ADDITIONAL MOTION PURSUANT TO FRCP R.

52(b), 59(e) and 60(b)(1)(2)(6) TO AMEND FINDINGS OF FACTS AND ALTER THE

ORDER, DATED DECEMBER 22, 2021, BASED ON NEW FINDINGS OF FACT, TO

PREVENT, CLEAR ERROR OF FACTS, CLEAR ERROR OF LAW, AND TO PREVENT

MANIFEST INJUSTICE and exhibits thereto, including table of contents, and the following

exhibits

(DI 39) Cont. Table of Contents

(DI 39) Cont. EXHIBIT 1ST A,

Letter of investigation by arm of state court, dated

May 24, 2021

(DI 39) Cont. EXHIBIT A, E-mail to Defendant regarding my religious beliefs, and

world economic forum founder’s plan as outlined in the two books The Fourth Industrial

Revolution “to entice people through temptations to make 47 percent of Americans unemployed,

to use the unemployed by labeling them mentally disabled, for mad science to teach the lie the

mind can be controlled through robotics and medicine.”

(DI 39) Cont. EXHIBIT B Letter Motion, Dated December 18, 2021 to Board, DE

Supreme Court and Defendant regarding discovery, reconsideration of counsel, and

postponement of hearing due 1. to ineffective service, until after a final determination is made on

counsel, and 3. Until discovery is complete, and the Receipt and postal confirmation Board and

ODC received the December 18, 2022 filing on December 21, 2022

(DI 39) Cont. EXHIBIT C Respondent’s Objection to and Motion to enjoin expert

observation and analysis of Respondent at hearings and in discovery; notice she will move for a

protective order during the discovery stage, and requests to prevent costs as going into Debt is

against her religious beliefs, and

Memorandum of Law in Support and Respondent’s Objection to and Motion to enjoin

expert observation and analysis of Respondent at hearings and in discovery; notice she will move

for a protective order during the discovery stage, and requests to prevent costs as going into Debt

is against her religious beliefs

(DI 39) Cont. EXHIBIT

Respondent Meghan M. Kelly’s Emergency

Objections and Emergency Motion filed with both the Board of Professional Responsibility for

the Supreme Court of Delaware, and the Delaware Supreme Court, simultaneously, to postpone

the hearing against her to prevent manifest injustice to afford her an opportunity to perform

discovery, potentially call witnesses and prepare a defense for the state’s allegedly illegally

motivated petition against her for her exercise of fundamental rights, motivated by the state’s

disdain for her religious political beliefs, dated January 11, 2022,

(DI 39) Cont. Exhibit A excluded since it is a District Court Doc.

(DI 39) Cont. Exhibit B includes internal exhibits, in one saved document

Email to Board and Patricia Swartz, dated Thursday, January 6, 2022,

following up on motion to postpone the hearing one week from the date, to afford a full

XXVIII

and fair trial, including an opportunity to gather evidence, so as not to violate the

substantive and procedural due process clause, and an opportunity to use the evidence to

present motions, including a motion to dismiss based on subject matter grounds.

Email to the Board and Patricia, dated Monday, January 10, 2022, follow

up on status of my request to postpone the hearing.

Email to the Board and Patricia, dated Friday, December 24, 2021,

regarding following up on my request to postpone the hearing, and the outstanding issues

relating to appointed counsel verses permission to represent myself, undecided by the

Court. Notice of my intention to file a Motion objecting to an expert’s attendance at the

hearing as against my religious beliefs, and notice of my intent to file a protective order

to protect myself from examinations from mental health and physical health experts on

religious grounds.

Email notification the Board member is out until December 28, 2021,

dated December 24, 2021.

Email from the Board dated January 10, 2022, indicating the Board plans

to move forward with the virtual hearing as scheduled, despite my appeal based on

improper notice, and the need to prepare to defend my case.

Email to the DE Supreme Court, Board and Patricia, dated January 6,

2022, regarding the federal government is helping me with the vulture attacks.

Accidental duplicate of Dec 24, 2021 email, at No. 3.

Email to Court, dated December 22, 2021, forwarded emails to appointed

counsel, firing him, and copying to others to protect my safety, dated December 21 and

22, 2021.

Email to Court asking for the Board’s number, December 22, 2021. I was

only able to leave messages.

(DI 39) Cont. EXHIBIT E Respondent Meghan M. Kelly’s motion appealing the

Order of the Board on Professional Responsibility of the Supreme Court of the State of Delaware

dated, January 11, 2022, granting postponement of the hearing for 8 days due to illness, not a

reason identified in my motion to grant postponement to afford me opportunity to prepare a

defense, perform discovery, research, file motions, be heard on outstanding motion(s)

unaddressed by the Board, to defend my exercise of fundamental rights and to preserve my

license to practice law, on the grounds the amount of time is not enough and a hearing date must

be postponed until after a fair opportunity to build a defense is granted, and moves the court to

suspend a hearing date until the parties and the Board determine a fair opportunity to perform

discovery has been allowed so as not to violate the norms of a fair proceeding, displaying

disparate treatment towards respondent based on her unique religious political beliefs, in

violation of the Equal Protections clause applicable to her as a party of one, dated January 12,

2022.

(DI 39) Cont. (Internal Exhibits) Exhibit A Respondent Meghan M. Kelly’s

Emergency Objections and Emergency Motion filed with both the Board of Professional

Responsibility for the Supreme Court of Delaware, and the Delaware Supreme Court,

simultaneously, to postpone the hearing against her to prevent manifest injustice to afford

her an opportunity to perform discovery, potentially call witnesses and prepare a defense

XXIX

for the state’s allegedly illegally motivated petition against her for her exercise of

fundamental rights, motivated by the state’s disdain for her religious political beliefs,

dated January 11, 2022

(DI 39) Cont. Exhibit B The Delaware Supreme Court Order Denying my

emergency objections and motion to postpone the hearing.

(DI 39) Cont. Exhibit C The Board Order granting a postponement of the

hearing to the date January 21, 2021, “due to illness,” a reason I did not request.

(DI 39) Cont. Exhibit D

Email to Patricia Swartz, dated January 3, 2022,

regarding I am not feeling well, took a covid tests, and negative, but believe I am

developing the shingles.

(DI 39) Cont. Exhibit E Email to Board, Lisa at the Supreme Court and Patricia

Swartz regarding still sick, problems with phone, and vulture issue at home, which may

interfere with scheduling, also attached pictures of the vultures that chase me and peck at

the glass windows, and do not go away when I yell at them.

(DI 39) Cont. Exhibit F

Email from the Board dated January 10, 2022,

responding to my most recent request on my motion to postpone the hearing indicating

“The Board plans to move forward with the hearing as scheduled

(DI 39) Cont. Exhibit G

Email To the Board and Patricia, dated December

24, 2021, regarding

1. I received docket ending before December 21, 2021,

2. Told the Board I would send them my November 19, 2021 answers to the

petition via email for ease,

3. Indicated the Board is aware of my request to postpone a hearing date so I may

properly defend my exercise of Constitutionally protected activity from state retaliation,

but for the exercise of fundamental rights, requiring the government to bear the burden of

strict scrutiny.

I told the Defendants I intend to file a motion objecting to an expert's

attendance at a hearing, as it is against my religious beliefs. I am a child of God, not a

scientific object for observation and examination by health or mental health examiners

who play God by seeking to mold people like me to scientifically conditioned and

conformed dictates instead of protecting the individual's dictates of conscience. Experts

deem those whose will does not bend with temptations to adhere to the communally

accepted trendy molds as unfit. My God teaches me those who are conformed to the

world do not have eternal life and will be unfit for heaven, should they not repent.

I also told the Defendants I will likely file a protective order to protect

myself from examination from mental health or physical health experts on religious

grounds, should petitioner seek an examination. My exercise of fundamental rights,

including exercise of my religious beliefs, requires the state meet strict scrutiny, which it

is not likely to meet.

(DI 39) Cont. Exhibit H

Emails dated January 11, 2022, email from Patricia

Swartz to Board and me, objecting to postponing the hearing, and my responses,

including my right to believe differently than the majority, and my religious objections to

healthcare.

XXX

(DI 39) Cont. Exhibit I

Email January 11, 2022, my email responding to

opposing counsel, providing religious objections to healthcare and my religious beliefs,

my disagreement with many democrats on healthcare when I ran for office in 2018, and a

sign healthcare that cares not healthcareless, your health is your wealth, as I was still

under the weather.

(DI 39) Cont. Exhibit J

January 4, 2022 email to Court, Board and

Defendant regarding I wasn’t feeling well. The covid test was negative, but looks like I

developed shingles.

(DI 39) Cont. Exhibit K

Email, dated January 5, 2022, relating to a broken

phone through the federal government

(DI 39) Cont. Exhibit L Email dated December 31, 2022, to the Board of

motion, Respondent Meghan M. Kelly’s objection to and motion to enjoin expert

observation and analysis of respondent at hearings and discovery; notice she will move

for a protective order during the discovery stage; and requests to prevent costs as going

into debt is against her religious beliefs; Memorandum of law in support of this motion,

certificate of service, postal receipt, table of contents of the exhibits, and exhibits thereto

contained, dated December 31, 2021

(DI 39) Cont. Exhibit M

Emails January 12, 2022, regarding I was not

making a new motion merely because I communicated with the Board and Defendant I

desired time to afford a fair opportunity to prepare a defense.

(DI 39) Cont. Exhibit F Answer to petition, excluding exhibits.

(DI 39) Cont. Exhibit G

Respondent’s more particularized motion to suspend the

hearing, scheduled for January 21, 2022 to allow me opportunity to research and prepare a

defense, requesting opportunity to draft requests for admission, interrogatories and subpoena

opposing counsel, Patricia Swartz, as a necessary witness in her defense, and subpoena other

necessary witnesses, including but not limited to, Chief Justice Collins J. Seitz, Judge Kenneth S.

Clark, Jr., due to his admission he interrogated me based on my exercise of fundamental rights

incited by the ODC, and Arline Simmons, to show unconstitutional motive for this petition, to

allow, the accused, respondent an opportunity to defend herself on the defense illegality of

proceeding, as applied to her, motivated by disdain by the state for her religious associated

beliefs and exercise of fundamental rights, and lack of jurisdiction based on the Delaware

Supreme Court’s apparent participation in inciting this petition against respondent.

(DI 39) Cont. (Internal Exhibits) Exhibit A

Post Office Receipt, and certified mail

receipt and confirmation the December 18, 2021 letter motion requesting opportunity to perform

discovery and file motions to dismiss was received by the Board and ODC on December 21,

2021

(DI 39) Cont. Exhibit B

Postal Receipt for December 29, 2021 letter to Court,

Board and ODC, dated December 29, 2021

(DI 39) Cont. Exhibit C

Emails to and from Patricia regarding moot motion

(DI 39) Cont. Exhibit D

January 12, 2022 email correction to Motion filed January

12, 2022, the federal government is helping me with the vultures, forwarded email from the

Federal government representative.

XXXI

(DI 39) Cont. Exhibit E

Email to and from federal government official relating to

the fact there is no charge for federal assistance with elimination of vulture problem, so as not to

violate my religious beliefs.

(DI 39) Cont. Exhibit F

Email filing dated Thursday, January 13, 2022, motion to

expedite motion to appeal with the Delaware Supreme Court.

(DI 39) Cont. App Q Health docs averring I require time in order not to harm my health or die,

including medical exhibit…14, 42-48, 115

(DI 36)

PLAINTIFF MEGHAN M. KELLY’S 3rd EMERGENCY MOTION

PURSUANT TO FRCP R. 52(b), 59 (e), 60(b)(1)(2)(6), and 65

(DI 36) Cont Exhibit A Postal Receipt

(DI 36) Cont Exhibit B Confirmation of receipt

(DI 36)Cont Exhibit B email confirming seek to cross examine Justice Seitz

(DI 36) Cont C Exhibit C Motions for time to perform discovery, call witnesses, prepare

given less than 2 weeks was granted right to self-represent deemed frivolous request by State

court in bad faith, showing the Court made a determination on my case without affording me an

opportunity to be heard

(DI 36) Cont D Exhibit D Order denying appeal for time to perform discovery, call

witnesses, prepare

(DI 36)

Cont E Rehearing rescheduled for a reason I did not request with fewer

days than the rules permit to call witnesses

(DI 36) Cont F

Communication by Defendant Aug 23, 2023……14, 48-52, 115-122

XXXII

TABLE OF CITATIONS

BIBLE

1 Corinthians 1:18, 2:14-16……………………………19, 135

1 Corinthians 3-17…………………………………………60

1 John 5:19……………………………………………..34, 88

2 Thes. 9- 12………………………………………………..83

2 Corinthians 4:4……………………………………….101

Amos 5:15…………………………………………………….12, 31, 52, 63, 85

Deuteronomy 1:16-17…………………………………..105

Deuteronomy 1:17…………………………………………..….12

Deuteronomy 16:19……………………………………………...12

Ephesians 5:11…………………………………………..…34

Exodus 23:6……………………………………………………….12

Ezekial Chapter 9………………………………………………...34

Ezekiel 34:2-5……………………………………………………90

Genesis 3………………………………………………20, 107

Hebrews 12:14………………………………..……..……..34, 38

Hosea 4:6…………………………………………………..34, 83

Isaiah 9:16……………………………………………………….7

Isaiah 10:1-2………………………………………………..52, 88

Isaiah 10:22……………………………………………………..89

Isaiah 14 …………………………………….…………….88, 139

James 2:1………………………………………………………12

James 2:9………………………………………………………..12

Jeremiah 31…………………………………..…………………20

Job 13:10………………………………………………………..12

Job 34:19………………………………………..……………….12

John 2:16…………………………………………..7, 20, 34, 35

John 7:24…………………………………………....……85, 185

John 12:40………………………………………………...37, 49

John 14:26……………………………………..…………..33, 35

John 19:4-6…………………………………………………..185

John 19:11…………………………………………..……….185

Leviticus 19:15………………………..……………………….12

Luke 11:34…………………………………………………37, 49

Luke 13:23-28………………………………………………….89

Luke 16:15……………………………………………………..84

Malachi 2:9……………………………………………………12

Mark 7:8…………………………………………..…………...34

Mark 8:36-38…………………………………………………..20

Mark 13:11……………………………….……………….33, 35

Matthew 5:4…………………………………………………...34

Matthew 6:1-4…………………………….7, 35, 87, 88, 101, 138,

Matthew 6:24……………………7, 20, 31, 33, 87, 101, 106, 124

XXXIII

Matthew 7:13-15……………………………………………88

Matthew 12:34-38………………………………………..…85

Matthew 13………………………………………...………101

Matthew 16:24-26……………………………………..……84

Matthew 16:26…………………………….……………..…31

Matthew 23:23…………………………..….12, 31, 52, 63, 85

Nu. 23:9………………………………………..……………38

Proverbs 15:27…………………………………..………… .90

Proverbs 18:5………………………………….….…………12

Proverbs 24:23……………………………………..………..12

Psalm 51:5……………………………………….…………..84

Rev. 13:17…………………………………………….….….38

Romans 1:25……………………………….19, 20, 60, 83, 106

Romans 4:4……………………………………………20, 101

Romans 12:2……………………………………………34, 38

Book

1 Chrles Alan Wright, Arthur R. Miller & Mary Kay Kane, Federal Practice and Procedure §

2862…………………………154

Article Robot justice: China’s use of Internet courts By Tara Vasdani This article was originally

published by The Lawyer’s Daily (https://www.thelawyersdaily.ca/), part of LexisNexis Canada

Inc………………………………………………………………………….See App. T-5

Article by the Venus project How can laws be eliminated…………………See App. T-5

Article by World Government Summit Could an AI ever replace a judge in court?, dated

2017…………………………………………………………………………See. App. T-5

The Great Narrative for a Better Future, by Klaus Schwabb………………See App. T-5

Covid-19:The Great Reset, by Claus Schwab and Thierry Malleret, Portfolio

Penguin Publishing, published 2020, by Forum Publishing, which may be found at

https://carterheavyindustries.files.wordpress.com/2020/12/covid-19_-the-great-resetklaus-schwab.pdf, (Excerpts of this Book in Exhibit D)……………. See App T-5

The Great Narrative for a Better Future, by Klaus Schwabb……………See App. T-5

The Fourth Industrial Revolution, by Klaus Schwab, 2016 version, excluding

additional pages of the 2017 updated version published by Portfolio Penguin, which

may be found at

https://www.academia.edu/38203483/The_Fourth_Industrial_Revolution_pdf?fbclid=

IwAR1koMak7N-40mbSf9wSGt8XzdhAJgafnbmobfn70FB4nbqcafl_hsN-RnQ…….38, See

App T-5

XXXIV

Shaping the Fourth Industrial Revolution By Klaus Schwabb, Founder of the World Economic

Forum and Chairman with Nicolas Davis, Copywrite 2018, Published in the United States by

Currency, an imprint of the Crown Publishing Group, a division of Penguin Random House

LLC… See App. T-5

CASES

Abbott v. Mette, No. CV 20-131-RGA, 2021 WL 327375, at *3 (D. Del. Jan. 31, 2021), report

and recommendation adopted, No. 20-CV-131-RGA, 2, 1021 WL 1168958 (D. Del. Mar. 26,

2021), aff'd, No. 21-1804, 2021 WL 5906146 (3d Cir. Dec. 14, 2021)……………2, 141

Abdul-Akbar v. McKelvie, 239 F.3d 307, 317 (3d Cir. 2001)…………………………168

Abington School District v. Schempp, 374 U.S. 203 (1963)……………………………135

Adams v. Quattlebaum, 219 F.R.D. 195 (D.D.C. 2004) ………………3, 150-151.

Africa v. Pennsylvania, 662 F.2d 1025, 1025, 1981 U.S. App. LEXIS 16448, *1, (3d Cir.), cert.

denied, 456 U.S. 908, 72 L. Ed. 2d 165, 102 S. Ct. 1756………………27, 138

Agosto v. Aponte Roque, 631 F. Supp. 1082, 1986 U.S. Dist. LEXIS 27992 (D.P.R. 1986),

remanded, 889 F.2d 1209, 4 I.E.R. Cas. (BNA) 1827, 1989 U.S. App. LEXIS 18910 (1st Cir.

1989)…………………………………………………………………………………132

Alexander v. Ieyoub, 62 F.3d 709, 713 (5th Cir. 1993)……………………………………...2, 140

Allgeyer v. Louisiana, 165 U.S. 578, 589-590…………127

Anderson v. Creighton,483 U.S. 635, 640, 107 S.Ct. 3034, 97 L.Ed.2d 523 (1987)…….136

Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). …………………………………………..136, 150

Bank of Am. Nat'l Tr. & Sav. Ass'n v. Hotel Rittenhouse Assocs., 800 F.2d 339, 343 (3d Cir.

1986)……………………………………………………………………………………83, 161

Board of Trustees v. Holso, 584 P.2d 1009, 1978 Wyo. LEXIS 228 (Wyo.), reh'g denied, 587

P.2d 203, 1978 Wyo. LEXIS 245 (Wyo. 1978)…………………………………………..132

Bolden v. SEPTA, 21 F.3d 29, 9 I.E.R. Cas. (BNA) 676, 146 L.R.R.M. (BNA) 2065, 127 Lab.

Cas. (CCH) ¶ 57650, 1994 U.S. App. LEXIS 6575 (3d Cir. 1994)………………………132

Ben-Levi v. Brown, 136 S. Ct. 930, 934, 194 L. Ed. 2d 231, 235-236, 2016 U.S. LEXIS 991, *1012…………………………………………………………………………26, .138

Boyd v. Farrin, 575 Fed. Appx. 517 (5th Cir. 2014)……………………………………140, 161

Brady v. Maryland, 373 U.S. 83, 87 (1963)………………………………………………57-163

Brindley v. McCullen, 61 F.3d 507 (6th Cir. 1995)……………………………….140, 145, 190

Burwell v. Hobby Lobby Stores, Inc., 573 U.S. 682…………………………19, 27, 138, 159

Bush v. Rauch, 38 F.3d 842, 847 (6th Cir. 1994)………………………………………154

Cantwell v. State of Connecticut, 310 U.S. 296, 60 S. Ct. 900, 84 L. Ed. 1213 (1940)…27, 138

Caperton v. A.T. Massey Coal Co., 556 U.S. 868, 872 (2009)……………………………….183184

Carroll v. City of Mount Clemons, 139 F.3d 107(6th Cir. 1998)……2, 141

Carter v. Kubler, 320 U.S. 243………………………………………………127

Centifanti v. Nix, 865 F.2d 1422, 1430 (3d Cir. 1989)…………………….119

Constr. Drilling, Inc. V. Chusid, No. 03-3786, 2005 WL 1111760, at *3 (3d Cir. May 11, 2005)

……………………………………………………………………………………143, 154, 169

Crane v. Fauver, 762 F.2d 325 (3d Cir. 1985)…………………………………………….2, 140

XXXV

Cunard Line Ltd. v. Abney, S.D.N.Y.1982, 540 F.Supp. 657……………………………..…..151

Datastorm Technologies, Inc. v. Excalibur Communications, Inc., N.D.Cal.1995, 888 F.Supp.

112……………………………………………………………………………151

Davis v. Jones, 506 F.3d 1325, 1330 (11th Cir. 2007)…………………………………….39

Deakins v. Monaghan, 484 U.S. 193, 108 S. Ct. 523, 98 L. Ed. 2d 529 (1988)…………2, 140

De La Cruz-Saddul v. Wayne State University, E.D.Mich.1980, 482 F.Supp. 1388…….3, 150

Dent v. West Virginia, 129 U.S. 114…………………..126-127

Doe v. Indian River School Dist, 653 F.3d 256, 283 n.14 (3d Cir. 2011)………18, 47, 135

Elrod v. Burns, 427 U.S. 347, 374, 96 S.Ct. 2673, 49 L.Ed.2d 547 (1976)……………….15, 47

Employment Div., Dept. of Human Resources of Ore. v. Smith, 494 U. S. 872, 887, 110 S. Ct.

1595, 108 L. Ed. 2d 876 (1990)…………………………………………………… 27, 138, 160

State ex rel. Tate v. Cubbage, 210 A.2d 555, 557, 1965 Del. Super. LEXIS 67, *1, 58 Del. 430,

433……………………………………………………27, 138

Exxon Mobil Corp. v. Saudi Basic Industries Corp., 544 U.S. 280, 292–293, 125 S.Ct. 1517, 161

L.Ed.2d 454 (2005)……………………….119-120

Faretta v. California, 422 U.S. 806, 95 S. Ct. 2525, 45 L. Ed. 2d 562 (1975)………..115, 117

Fisher v. City of Cincinnati, 753 F. Supp. 681, 687 (S.D.Ohio 1990)……………………..133

Fletcher-Harlee Corp. v. Pote Concrete Contractors, Inc., 482 F.3d 247, 253 (3d Cir. 2007)..

Flores v. Pierce, 617 F.2d 1386, 1980 U.S. App. LEXIS 17814 (9th Cir.), cert. denied, 449 U.S.

875, 101 S. Ct. 218, 66 L. Ed. 2d 96, 1980 U.S. LEXIS 3269 (1980)………………..132

Foman v. Davis, 371 U.S. 178, 182 (1962)…………………………120

Freedom from Religion Found. Inc. v. New Kensington Arnold Sch. Dist., 832 F.3d 469, 490,

2016 U.S. App. LEXIS 14594, *49-5…………………………………………………….43

Gianetti v. Cross, No. 091416, at *16-17 (May 18, 2010)………………………..3

Greene v. McElroy, 360 U.S. 474, 475 (1959)…………………..117, 126,

Hammond v. Baldwin, 866 F.2d 172, 177 (6th Cir. 1989)…………………………144

Harmon v. Department of Finance, 3rd Cir.(Del.), April 27, 2020………………..144

Harsco Corp. v Zlotnicki, 779 F.2d 906, 909 (3d Cir. 1985)…………………37

Harris v. Raymond, No. 3:20-CV-01119, 2020 WL 5267920, at *4 (M.D. Pa. Aug. 17, 2020),

report and recommendation adopted, No. 3:20-CV-1119, 2020 WL 5260769 (M.D. Pa. Sept. 3,

2020)………………………………………………………………………………………154

Hill v. City of Scranton, 411 F.3d 118, 122 (3d Cir. 2005)…………………………….160

Holt v. Hobbs, 574 U.S. 352, 352, 135 S. Ct. 853, 856, 190 L. Ed. 2d 747, 747, 2015 U.S. LEXIS

626, *1, 83 U.S.L.W. 4065, 93 A.L.R. Fed. 2d 777, 25……………………27, 138

Inc. v. Lopez, CIV. No. 14-1223 (PG) (D.P.R. Oct. 27, 2015)………………………...…144

In re a Member of the Bar of the Supreme Court, of the State Enna, 971 A.2d 110, 125 (Del.

2009)………………………………………………….112

In re Cincinnati Radiation Litigation, 874 F. Supp. 796, 823 (S.D. Ohio 1995)…………….133

In re Oliver, 333 U.S. 257, 273………………………………………………127

Ins. Corp. of Ir. v. Compagnie Des Bauxites De Guinee, 456 U.S. 694 702-03 (1982)…112

In re Kelly, No. 58, at *3 (Del. Sep. 7, 2022)…………………………………………128.

International Shoe Co. v. Washington, 326 U.S. 310, 316 (1945)….112-113

In Re Murchinson, 349 US 133, 136 (1955)……………………………39, 144, 180

Isom v. Arkansas, 205 L. Ed. 2d 373, 140 S. Ct. 342, 343–44 (2019)…………………..180

Johnson v. Carroll, 369 F.3d 253, 259 (3d Cir. 2004)………………………………………….39

Joint Anti-Fascist Committee v. McGrath, 341 U.S. 168-169…………………………….127

XXXVI

Jones v. Prescott, 702 Fed. Appx. 205, 209 (5th Cir. 2017)…………………………..2, 140

Kalman v. Cortes, 723 F. Supp. 2d 766, 769, (2010)……………………………………7

Kalniz v. Ohio State Dental Bd., 699 F. Supp. 2d 966, 975 (S.D. Ohio 2010)…………2, 141

Kennedy v. Bremerton Sch. Dist., 142 S. Ct. 2407 (2022)………………………………154

Kirby v. United States, 174 U.S. 47……………………….127

Lavoie v. Aetna Life & Casualty Co., 374 So. 2d 310, 312 (1979)……………………….181

Laird v. Tatum, 409 U.S. 824, 93 S. Ct. 7, 34 L. Ed. 2d 50 (1972)………………………181

Lewis v. Beddingfield, 20 F.3d 123, 124 (5th Cir. 1994)……………………………2, 140

Lewis v. Casey, 518 U.S. 343, 370 (1996)……………………………………………168

Licata v. U.S. Postal Serv., 33 F.3d 259, 260 (3d Cir. 1994)…………………..24

Liljeberg v. Health Servs. Acquisition Corp., 486 U.S. 847, 108 S. Ct. 2194, 100 L. Ed. 2d 855

(1988)…………………………………………………………………….180

Liteky v. United States, 510 U.S. 540, 114 S. Ct. 1147, 127 L. Ed. 2d 474 (1994)…. 180

Lucero v. Ramirez, No. 20-CV-2411-CAB-JLB, 2021 WL 1529932, at *1 (S.D. Cal. Apr. 16,

2021)…………………………………………………………………………………155

N. Jersey Media Grp. Inc. v. United States, 836 F.3d 421, 434 (3d Cir. 2016)…….117

Night Clubs, Inc. v. City of Fort Smith, 163 F.3d 475 (8th Cir. 1998)……………2, 141

Magera v. Lincoln National Life Insurance Company, CIVIL ACTION No. 3:08-CV-0565, at *4

(M.D. Pa. May 14, 2009) ………………………………………………………………………4

Malhan v. Sec'y U.S. Dep't of State, 938 F.3d 453, 462 (3d Cir. 2019)………………………..129

Maraan v. Off. of Ohio Disciplinary Couns. for Supreme Ct. of Ohio, No. 1:18CV645, 2021 WL

3173311, at *3 (S.D. Ohio July 27, 2021)……………………………………….2, 141-142

Mayle v. Felix, 545 U.S. 644, 663 (2005)……………………120

May v. Anderson, 345 U.S. 528, 537 (1953)……………………………………143

Mattox v. United States, 156 U.S. 237, 242-244…………………….127

Max’s Seafood Cafe ex rel. Lou-Ann, Inc. v.Quinteros, 176 F.3d 669, 677 (3d Cir. 1999)……37

Mayberry v. Pennsylvania, 400 U.S. 455 (1971)………………………………….……155

McCool v. Gehret, 657 A.2d 269, 277 and 280 (Del. 1995)……………………………144

McDonough, Petitioner, 457 Mass. 512, 519 n.16 (Mass. 2010)………………………..64

Meyers v. Franklin Cty. Court of Common Pleas, 23 F. App'x 201, 206 (6th Cir. 2001)…2, 241142

Middlesex Cnty. Ethics Comm. v. Garden State Bar Ass'n, 457 U.S. 423, (1982)……4, 129

Mir v. Bureau of Pro. & Occupational Affs., No. 2557 C.D. 2015, 2016 WL 6407477, at *3 (Pa.

Commw. Ct. Oct. 31, 2016)………………………………………………………..63

Molina v. Pa. Soc. Serv. Union, 2019 U.S. Dist. LEXIS 120040, *27, 2019 WL 3240170…43

Moore v. Illinois, 408 U.S. 786 (1972)……………………………………………163

Moran v. Burbine, 475 U.S. 412, 466 (1986)……………………………………………163

Morgan v. United States, 304 U.S. 1, 19…………………………….127

Motes v. United States, 178 U.S. 458, 474……………………………………127

Mullin v. Sussex Cnty., Delaware, 861 F. Supp. 2d 411, 427 (D. Del. 2012)………47, 135

Murray v. Giarratano, 492 U.S. 1, 18 (1989)………………………………………168

Night Clubs, Inc. v. City of Fort Smith, 163 F.3d 475 (8th Cir. 1998)………………2, 141

Nimer v. Lichfield Twp. Bd. of Trustees, 707 F.3d 699 (6th Cir. 2013)……………2, 141

N. Jersey Media Grp. Inc. v. United States, 836 F.3d 421, 434 (3d Cir. 2016)………83, 117, 161

Nixon v. Warner Commc'ns, Inc., 435 U.S. 589, 98 S.Ct. 1306, 55 L.Ed.2d 570 (1978)….83

Obergefell v. Hodges, 576 U.S. 644……………………………………………………159

XXXVII

Ohio Bell Telephone Co. v. Public Utilities Commission, 301 U.S. 292………………..127

Parkview Assoc. Partnership v. City of Lebanon, 225 F.3d 321, 327-28 (3d Cir. 2000)…119

Pansy v. Borough of Stroudsburg, 23 F.3d 772, 780-81 (3d Cir. 1994)……………….83, 161

PDX N., Inc. v. Comm'r N.J. Dep't of Labor & Workforce Dev., 978 F.3d 871, 882 n.11 (3d Cir.

2020).……………………………………………………………………………..………128

Pease v. Rathbun-Jones Eng. Co., 243 U.S. 273, 276 (1917)……………………………143

Peters v. Hobby, 349 U.S. 331, 352………………………..127

Peters v. Kiff, 407 U.S. 493, 502 (1972), Overruled in Gregg v. Georgia, 428 U.S. 153, 169

(1976)………………………………………………………………………………………155

Powell v. Pennsylvania, 127 U.S. 678, 684……………………127

Presbyterian Church in U. S. v. Mary Elizabeth Blue Hull Memorial Presbyterian Church, 393

U. S. 440, 450, 89 S. Ct. 601, 21 L. Ed. 2d 658 (1969)…………………………27, 138

Quackenbush v. Allstate Ins. Co., 517 U.S. 706, 719 (1996)………………………2, 140

Reed v. Goertz, No. 21-442, at *5 (Apr. 19, 2023)…………..119

Reilly v. Pinkus, 338 U.S. 269…….127

Richards v. Jefferson County, 517 U.S. 793, 798 n.4 (1996)……………………….136

Rocker-Feldman doctrine, derived from 2 cases, 1) Rooker v. Fidelity Trust Co., 263 U.S. 413

(1923) and 2) District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (1983)..119, 120

Salazar v. Buono, 559 U.S. 700, 717 (2010)……………………………18, 29, 47, 135

Saucie v. Katz, 533 U.S. 194 (2001) ……………………………………………………….133

Schweiker v. McClure, 456 U.S. 188 (1982) reversed on other grounds; Gibson v. Berryhill, 411

U.S. 564, 570 (1973)………………………………………………………………………144

Schware v. Board of Bar Examiners, 353 U.S. 232………………………………………127

Sharp v. Johnson, 669 F.3d 144, 159 (3d Cir.2012)……………..136

Skinner v. Switzer, 562 U.S. 521, 532 (2011)……………………………………….119

Slochower v. Board of Education, 350 U.S. 551; Truax v. Raich, 239 U.S. 33, 41….127

Reed v. Illinois, No. 19-1164, at *4 (7th Cir. Jan. 9, 2020)………………………………64

Rippo v. Baker, 580 U.S. 285, 137 S. Ct. 905, 197 L. Ed. 2d 167 (2017)………179, 183

Sprint Communications, Inc. v. Jacobs, 571 U.S. 69,(2013)……………………2, 3, 4, 129, 140

Tanzin v. Tanvir, 141 S. Ct. 486, 208 L. Ed. 2d 295 (2020)……………………………..19

Tennessee v. Lane, 541 U.S. 509, 533 n.20 (2004)…………………………64, 168

Tumey v State of Ohio, 273 US 510 (1927)…………………………………………………144

Ungar v. Sarafite, 376 U.S. 575, 584 , Citing, Tumey v. Ohio, 273 U.S. 510………………144

United Church of the Medical Center v. Medical Center Comm'n, 689 F.2d 693, 701 (7th Cir.

1982)…………………………………………………………………………………144

United States v. Bagley, 473 U.S. 667 (1985)……………………………………………163

United States v. Fiorelli, 337 F.3d 282, 288 (3d Cir. 2003)…………………………………….37

United States v. Nixon, 418 U.S. 683, 703, 94 S.Ct. 3090, 41 L.Ed.2d 1039 (1974)……….135

University of Delaware, 434 F. Supp. 1273, 1977 U.S. Dist. LEXIS 15317 (D. Del.

1977)……………………………………………………………………………………132

U.S. v. Wecht, 484 F.3d 194, 221, 226 (3d Cir. 2007)……………………………………161

Utica Packing Co. v. Block, 781 F.2d 71, 77 (6th Cir. 1986)…………………………….144

Uzuegbunam v. Preczewski, 141 S. Ct. 792, 794, (2021)……………………………………….24

Velasquez v. Litz, No. CV 3:21-1659, 2021 WL 5298912, at *3 (M.D. Pa. Nov. 15, 2021)…154

Ward v Village of Monroeville, 409 US 57 61-62 (1972)………………………………144

XXXVIII

Watkins v. Ohio Dep't of Educ., No. 2:21-CV-04482, 2022 WL 672565, at *8 (S.D. Ohio Mar. 7,

2022……………………………………………………………………………………2, 141, 142

Werkheiser v. Pocono Twp., 780 F.3d 172, 176 (3d Cir. 2015)……………19, 26, 135, 136

Williams v. Hepting, 844 F.2d 138, 145 (3d Cir. 1988)………………………………2, 141

Williams v. Pennsylvania, 579 U.S. 1 (2016)………………………3, 180, 181, 183, 185

Williams-Yulee v. Fla. Bar, 575 U.S. 433, (2015)………………………………………184

Withrow v. Larkin, 421 U.S. 35, 46 (1975)……………… ……144, 180, 183

Yamaha Motor Corp. v. Stroud, 179 F.3d 598 (8th Cir. 1999)……………………………..2, 141

Younger v. Harris, 401 U.S. 37 (1971)…4, 23, 24, 25, 109-110, 119, 123-124, 128-129, 141-142

Zilich v. Longo, 34 F.3d 359 (6th Cir. 1994)………………………………………..133

CONSTITUTION

US Const. Amend I…4, 5, 6, 9-10, 11, 12, 13, 18-24, 27-100, 104, 105, 106, 107, 108, 109, 111,

112, 114, 115, 116, 117, 123-124, 125, 126, 133-135-137-167, 171, 174, 177, 178, 181-184, 187188, 189

US Const. Amend V…4, 5, 11, 13, 63, 65, 66, 67, 73, 85, 86, 90, 99, 100, 101, 104, 105, 106,

107, 111, 117, 119, 124, 179, 181-184, 187-188, 189

US Const Amend. IV……101, 174-175, 188

US Const. Amend. VI…4, 5, 18-24, 27-36, 107, 111, 116, 117, 126, 127, 163, 188

US Const Amend XIII….36-37, 90, 93, 100, 101, 105, 106, 107, 111

US Amend. XIV…4, 5, 6, 9-10, 27-100, 106, 107, 108, 109, 111, 112, 114, 115, 116, 117, 123,

125, 126, 133-167, 171, 177, 178, 187, 188, 189

US Art III…11, 13, 126

Executive orders

E.O. 13798…………………………………………………………………..6, 7, 9, 33, 35, 38,

155

Ex. Or. No. 13198, Jan. 29, 2001, as amended by Ex. Or. 14015, Feb. 14, 2021…6, 7, 9, 33, 35,

38, 155

Ex. Or. No. 13199, Jan. 29, 2001, as revoked by Ex. Or No. 13831, May 3, 2018…6, 7,9, 33, 35,

38, 155

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

2010…………………………………………………6, 7, 9, 33, 35, 38, 155

Ex. Or. No. 13559 Nov. 17, 2010………………..…6, 7, 9, 33, 35, 38, 155

Ex Or. No. 13831, May 3, 2018...6, 7, 9, 33, 35, 38, 155

Ex. Or. No. 14015, Feb. 14, 2021…6, 7, 9, 33, 35, 38, 155

FEDERAL STATUTES

CFR § 2200.68………………..98, 173-187

18 USC 227…………………………………………………………………………………….174

XXXIX

28 U.S. Code § 144 ………………………..98, 173-187

28 U.S.C.A. § 453…………………………………………………………………………185, 190

28 U.S. Code § 455…………… 3, 39, 40, 41, 98, 173-187

28 U.S.C. § 1253…………………………………………………………………………….1

28 U.S.C. § 1254…………………………………………………………………………….1

28 U. S. C. § 1343……………………………………………………………………………....…

28 U. S. C. § 2101(e)……………………………………………………………………68, 71-72

28 U.S.C. § 2106……………………………………………………………………………........1

28 U.S.C. § 2071-2077………………………………………………………………………..101

42 USC §1983…………………………………………21, 22, 27, 31, 38, 39, 108, 110, 125, 132,

188

42 USC §1985…10, 21, 27, 31, 38, 39, 108, 110, 125, 188

42 USC §1988……………………21, 22, 27, 31, 38, 39,108, 110, 125, 188

42 U. S. C. § 2000bb-1 through 4 Religious Freedom Restoration Act…5, 6, 17, 19, 21, 22, 23,

38, 39, 108, 109, 110, 125

42 U.S.C. §§ 12181- 12189…………………………………………………………….63, 64

Local District Court rule

D. Del. 7.1.5 (a)…………………………………………….24

FEDERAL RULES OF APPELLATE PROCEDURE

Fed. R. App. P. 27…………………………………………103, 104

FEDERAL RULES OF CIVIL PROCEDURE

Fed. R. Civ. P. 15 Rule (a)…3, 31-36, 59, 120

Fed. R. Civ. P. Rule 52……………………………………….36, 37, 42, 48, 51

Fed. R. Civ. P. Rule 59…………………………………………………….24, 36, 37, 42, 48, 51

Fed. R. Civ. P. Rule 60………………………………………….184, 42, 48, 51

Federal Rules of Evidence Rule 605……………………………………..40

SUPREME COURT RULES

Supreme Court Rule 23……………………………………………………………………71-72

STATE REGULATIONS

Del. Law. R. of Disciplinary Proc. Rule (also “DLRDP Rule”) 1 (a)..111-112, 176-184

Del. Law. R. of Disciplinary Proc. Rule 5…..111-112, 176-184

Del. Law. R. of Disciplinary Proc. Rule 7(d)………………….11, 13, 14, 176-184

Del. Law. R. of Disciplinary Proc. Rule 8…….111, 176-184

Del. Law. R. of Disciplinary Proc. Rule 9 (d) (2)………….176-184

DLRDP Rule 9(d)(3)……………………76, 163, 176-184

Del. Law. R. of Disciplinary Proc. Rule 10…….111, 176-184

Del. Law. R. of Disciplinary Proc. Rule 12 (h)……………………78, 68-76, 79, 167, 176-184

Delaware Rules of Disciplinary Procedure, Rule 13………………………11, 13, 14, 14, 176-184

Delaware Rules of Disciplinary procedure Rule 14…………………………..11, 13, 176-184

Del. Law. R. of Disciplinary Proc. Rule 18……………………………………176-184

Del. Law. R. of Disciplinary Proc. Rule 19 (a)………………………………11, 13, 176-184

Del. Law. R. of Disciplinary Proc. Rule 19 (c)……………………………….11, 13, 176-184

Del. Law. R. of Disciplinary Proc. Rule 19 (d)………………………11, 13, 176-184

Del. Law. R. of Disciplinary Proc. Rule 19 (e)…………… …………….11, 13, 176-184

XLI

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.