Petition for Rehearing — Helen Allen, Petitioner v. Ford Motor Company

No.24-399

In the

Supreme Court of the United States

HELEN ALLEN, Petitioner,

V.

FORD MOTOR COMPANY, Respondent.

On Petition For A Writ Of Certiorari to the

United States Court of Appeals For the Seventh Circuit

PETITION FOR REHEARING

Helen Allen

9530 Pineview Road

Suffolk, Virginia

23437

Appellant, Pro Se

RECEIVED

JAN 10 2025

SUPREME cObaL UE

TABLE OF CONTENTS

TABLE OF AUTHORITIUES........:...cccccssecsseseereeseressnseneseetenssenees 3

PETITION FOR REHEARING........c:cccccessceseesesereesneeesnaeenseenneees 4

REASONS FOR GRANTING REHEARING.........cccseceseeneeerens 4

I. ISSUES THAT LED TO TERMINATION OF

SETTLEMENT OFFER NECESSITATES REVIEW ........... 5

II. PETITIONER’S NUMEROUS COMPLAINTS OF

JUDICIAL MISCONDUCT REMAINS UNADDRESSED ...7

III. CONCLUSION wasssssscsssssinssssavnasensscnenencosaoncneacnsonnonencees 10

CERTIFICATION OF PRO SE LITIGANT ........:c:csseeeeeereeenees 11

CERTIFICATE OF COMPLIANCE ........:cccccccsessesseeeseeseeeeeeeees 12

APPENDIX wissssscesssesseesscesseeesecesccenccesrecseesseesenesssesenaeensensesenes 13

Appendix A saisssascisssesisascescecnacciia...--osesrsssnecssrsesennensseeoterenseeres 14

ASPEN GIXEB) xn. an: coxeeeomecenenreescocnssmensellveseemnsenecsensneessnee Nene aA 46

Appendix C serssssissssstsicniselaasioviapsvanaeanserieniercicesmnsreacencasannens 48

TABLE OF AUTHORITIES

Case Law

In re Japanese Electronic Products Antitrust Litigation, 723

F.2d 238 (8rd Cir. 1983) .....ccccccsesseseeseesees 5

Gerard A. Cassino and Sally Cassino v. Reichhold Chemicals,

Inc., 817 F.2d 1338 (9th Cir. 1987) ...cccceeeeeeee sees 5

Zurich American Insurance v. Watts Industries, Inc., 417 F.3d

682 (7th Cir! 2005) iwossscvrcseuancaumvernca 6

Common Cause Indiana v. Individual Members of the Indiana

Election Commission, 800 F.3d 913 (7th Cir. 2015) vc... 7

Statute

28 U.S.C § 851 oo... ccccccescecececeececesseseeeeessseneeeceseees |

Rules

Rule 44 of the Rules of the Supreme Court of the United

States ..cccccccecceescccevecececsnccsessuseaees 4

PETITION FOR REHEARING

Helen Allen, pursuant to Supreme Court Rules 44,

respectfully petitions this court, for rehearing of its November,

15, 2024 Order denying her Petition for Certiorari.

REASONS FOR GRANTING REHEARING

Facts previously not presented provide strong grounds

for rehearing. To be exact, Respondent in 2023, offered to

settle in exchange for release of all claims (App. A). Petitioner

rejected offer because she was subject to judicial misconduct.

Counsel for FMC and Petitioner’s co-plaintiff were engaged in

an overt improper relationship while case was ongoing.

Petitioner reported this behind the scenes inappropriate

relationship, however, misconducts were never investigated.

More so, transcripts of Petitioner reporting misconduct are

now sealed, and inaccessible by Petitioner. These records are

relevant to Petition for Certiorari as it paints a complete

picture of procedural unfairness.

Vital to emphasize, Petitioner acknowledges that

Federal Rules of Evidence 408 prohibits presenting a

settlement offer as evidence of liability. Petitioner, to the

contrary, argues that Settlement Agreement reveals the

inconsistencies of a Respondent who is cunningly navigating

the legal system. One that was successfully perpetrated on the

District Court and 7th Circuit. Accordingly, Settlement

Agreement and unaddressed Judicial Misconduct throughout

the lower courts warrant a Rehearing and grant of Petition for

Certiorari,

I. ISSUES THAT LED TO TERMINATION OF

SETTLEMENT OFFER NECESSITATES REVIEW

To reiterate, Petitioner is of the knowledge that under

Rule 408, evidence of “Promising, or offering — or accepting,

promising to accept, or offering to accept — a valuable

consideration in compromising or attempting to compromise

the claim” is inadmissible. In the same vein, “Rule 408 is not a

privilege, for by its terms it does not require exclusion when

the evidence is offered for another purpose, such as proving

bias or prejudice of a witness...” In re Japanese Electronic

Products Antitrust Litigation , 723 F.2d 238 (8rd Cir. 1983).

Similarly, “Rule 408 should not be used to bar relevant

evidence concerning the circumstances of the termination

itself simply because one party calls its communication with

the other party a "settlement offer." Gerard A. Cassino and

Sally Cassino v. Reichhold Chemicals, Inc., a New York

Corporation, 817 F.2d 1338 (9th Cir. 1987). More so,

settlement negotiations “...Has been admitted by courts for

additional purposes other than establishing lability, including

for purposes of rebuttal, for purposes of impeachment, to show

knowledge and intent, to show a continuing course of reckless

conduct....” Zurich American Insurance v. Watts Industries,

Inc., 417 F.3d 682 (7th Cir. 2005). Relatively, Petitioner draws

attention to Settlement Offer of Respondent to demonstrate

inconsistencies, furthermore, to illustrate status of action

prior to summary judgment. In essence, judicial misconduct is

the sole reason why settlement offer was terminated by

Petitioner.

II. PETITIONER'S NUMEROUS COMPLAINTS OF

JUDICIAL MISCONDUCT REMAINS

UNADDRESSED

Ford Motor Company asserted good faith in presenting

agreement, yet it waived response to Petition for Certiorari

(App.B). Waiver only served to help Ford Motor Company

escape scrutiny. Particularly to escape adjudication of

unlawful employment practices. Namely, violation of Title VII

of the 1964 Civil Rights Act (42 U.S.C. §§ 2000e-2(a)(1), 2000e-

3(a)), including Sexual Harassment, Racial Harassment,

Discrimination, Retaliation and violation of Petitioner’s First

Amendment Rights.

Petitioner, at the District court, and the 7th Circuit

called out and filed complaints of judicial misconduct against

two judges who refused to order investigation into an intimate

relationship between FMC’s lawyer and her co-plaintiff. No

action was taken against Ford Motor Company’s counsel. He

was allowed to proceed through settlement despite grave

conflict of interest (cases 14 cv 08708; 21 cv 00962). According

to the governing statute, “Any person alleging that a judge

has engaged in conduct prejudicial to the effective and

expeditious administration of the business of the courts [...]

may file with the clerk of the court of appeals for the circuit a

written complaint containing a brief statement of the facts

constituting such conduct.” 28 U.S.C § 351. Conversely, upon

filing complaints, Petitioner was subject to more judicial

misconduct by a sitting judge because she reported two judges

who failed to order investigation into an inappropriate

CERTIFICATION OF PRO SE LITIGANT

I certify that this petition for rehearing is restricted to

the grounds specified in Rule 44.2 and is presented in good

faith and not for delay.

Helen Allen

Dated

relationship between counsel for Ford Motor Company and

her co-plaintiff. Records which are now sealed and

inaccessible. In effect “The purpose of judicial discipline is not

primarily to punish a judge but to preserve the integrity of

and public confidence in the judicial system and, when

necessary, safeguard the bench and public from those who are

unfit.” Common Cause Indiana v. Individual Members of the

Indiana Election Commission, 800 F.3d 913 (7th Cir. 2015).

Above all, Petitioner, rejected FMC’s settlement offer due to

conflict of interest, breach of fiduciary duty, professional

misconduct, improper and undue influence in the settlement

process. Petitioner could not proceed with offer under these

circumstances.

Illinois Bar acknowledged complaint 9-12-23 but

refused to issue case number or conduct investigation.

California allowed Petitioner a year to gather evidence

against K. Smith (California State Bar (214872)). D.C. refused

to investigate M. Jaskiw, stating that denial of access to

transcripts was within the law. It is illogical that Petitioner is

denied the very same documents that are necessary to affirm

instances of judicial misconduct.

Accordingly, this court should consider the conditions

that created the circumstance which led to rejection of

Settlement Offer (App. C).

II. CONCLUSION

In light of the reasons stated above, and those

presented in Petition for Certiorari, the court should grant

Rehearing and grant Petition for Certiorari and review errors

of the courts below.

Respectfully Submitted,

Helen Allen

9530 Pineview Road

Suffolk, Virginia 23437

Appellant, Pro Se

Dated

CERTIFICATE OF COMPLIANCE

Pursuant to Rule 33.1(h) of the Rules of the Supreme

Court of the United States, I certify that this document

contains 905 words, excluding the parts of the document

exempted by Rule 33.1(d).

This word count was calculated using Microsoft Word.

Helen Allen

Dated

Additional material

from this filing is

available in the

Clerk’s Office.