# Prologue — Hollis-Arrington v. Fannie Mae > Briefs, arguments, decisions, and more. URL: https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40386016_0004%3A0 ## Record - **Collection:** Supreme Court brief - **Document type:** Prologue - **Published:** January 1, 2005 - **Citation:** 546 U.S. 874 ## Text Supreme Court, U.S. Ch ae FILED ey O5-114MAY 11 2009 In the OFFICE OF THE CLERK SUPREME COURT OF THE UNITED STATES - —_— as BEVERLY ANN’ HOLLIS-ARRINGTON Petitioner, Vs. FANNIE MAE, CENDANT MORTGAGE CORPORATION, JUDGE CONSUELO B. MARSHALL, JUDGE STEVEN V. ———— WILSON, JUDGE ANDREW KLEINFELD, JUDGE PAMELA D. REYMER, FIDELITY NATIONAL TITLE INSURANCE COMPANY, SUZANNE M. HANKINS, ET. AL. . Respondents On petition for a Writ of Certiorari to the United States Court of Appeals for the District of Columbia Circuit PETITION FOR WRIT OF CERTIORARI 4 BEVERLY ANN HOLLIS-ARRINGTON 22912 Hartland Street West Hills, Ca 91307 (818) 999-3561 May 10, 2005 tr —Petitioner In Pro Se i Questions presented 1. Whether the Court of Appeals must follow the precedent set by this Honorable Court? 2. Whether the Court Of Appeals must follow its own precedents. 3. Given the Congressional intent of the established jurisdiction of the United States Appeals Courts, as a court of review to the orders of a lower Court, did the appeals Court act properly by rewriting the order of the lower court to reflect what they believe the judge should have said, then rule on their own changes? : 4. When a United States Judges have usurped hts authority, and ignored the jurisdiction of the Court, codified in article II] of the United States Constitution; and thereby lifting their immunity, followed by allegations of conspiring with the defendants, to corruptly fix the out come of three prior cases filed by this petitioner, by way of bribery; can this petitioner use denial of access as a precursor to a Constitutional claim of due process violation, consistent with this Honorable Courts holding in “Christopher v Harbury”? 5. Can the Court ignore its own precedent, and DC Code Ann. § 13-423(a) (1) set in “Second Amendment Foundation v United States Conference of Mayors, et. al., and refuse to accept personal jurisdictions of all defendants, based on an alleged conspiracy, with one defendant residing in the forum state, and the remain defendants acting as the agents of that defendant? 6. Can the court depart from the holdings of all Circuits, including its own, and-rewrite the doctrine of res judicata, as they did in this case? ii PARTIES TO PROCEEDINGS Beverly Ann Hollis-Arrington is the petitioner, in pro se in this matter. Respondents are: Fannie Mae, Cendant Mortgage Corporation, - Fidelity National Title Insurance Company, Judge Consuelo B. Marshall, Judge Steven V. Wilson, Judge Pamela Rymer, Judge Andrew Kleinfeld, Judge Browning, Suzanne M. Hankins, esq., Robert O. Matthews, Conny B. McCormack ( in her official sta as register recorder for the County of Los Angeles) David W. Goewey Venable LLP 575 Seventh Street N.W. Washington D C 20004-1601 Attorneys for: | Fidelity National Title insurance Robert O. Matthews Weiner Brodsky Sidman Kider Pc Attention: David M. Souders 1300 19" Street Fifth Floor Washington D. C. 20036- 1609 Attorneys For: Fannie Mae, Cendant Mortgage Corp: And, Suzanne M. Hankins, Esq. TABLE OF CONTENTS EO PINs pc Sasi titiduksas pangs as ae eae Petes Us Te PHI, sinc Be a wt il CNN a a ee ee Table of Authorities......... 2.0.0.1. cece estes cee ences ee ctineee ce eneeeeed Opinions below. . eo a a PI oi eek RG Being wacesnias fee as oe EVER SUUOEY PHOVIGIONE, «5 oss is oh as since bniwadee. oe 2 Reason Why the writ Should be Granted ... ............ 00... cee ee eee ee RII ip ops con Cache ani orn ede’ oes bdoatan cake sa ae Appendix Appendix A- 02-11-04- United States Court of Appeal for the District Of Columbia Order on pees En Banc... pecan mere Snaveuk say eon sae Appendix B — 11-15-04- United States Court Of Appeals for the District of Columbia RN i ou Se anna es Geen dine Rae eee Appendix C- 02-17-04- Initial Order of the District | MMM is igs ad ari peg tics tae Wha hav ALD SAR SO ee at AG enc Appendix D-Filed material so that the court may better understand I oi a a ee iv TABLE OF AUTHORITIES Judicial Authority Best v Kelly 309 U.S. D.C. 51; 39 F. 3d 328.........0............3 Bieneman v City of Chicago, 864 F. 2d 463, 469 (7" Cir. ae Bivens v Six Unknown Named Agents of federal Bureau of Narcotics 403 U.S. 388, 29 L Ed. 2d 619, 91 S. Ct. 1999 (1971).......... passim Conley v Gibson, 355 U.S. 41, 45-46, 2L Ed. 2d 80, 78 S Ct. 99 Davis v Passman, 42? U.S. 228, 60 L. Ed. 2d 846, 99 Ct. 2264 Maharaj v Bank of America Corp. 128 F3d. 94,97 (2d Cir. 1997)..4 Maher v Durango Metals Inc., 144 F. 3d 1302, 1304 (10" Cir. Pai ois en eae Ang oh ol eaeace a ee Melvin P. Deutsch v United States Department of Justice, ET. al., - G1 F. Sepp. 49; 1995 US. Dee. «0: ..- 0 a. Rivet, et al., pteunnies Bank pai Louisiana et al., 522 U.S. 470; 118 S. ka Fee sehen ou sreseilicon appa rd alae ates tet we . .passim ' Scheuer v Rhodes, 416 U.S. 232, 236, 40 L. Ed. 2d 90, 94 S Ct. 1683 (1974) overruled on other grounds, Davis v Scherer 468 U.S. 183, a2 L. Bd 26. 195, OOS. CO SOL I... 505-0 a 3 Second Amendment Foundation v United States Conference of — et al., 348 US. — D.C. 238; 274 F. 3d 521; 2001 US. Vv or gala sige: Inc v. Stanley, 819 F.2.d 294, 297 (D.C. Cir. 1987)... Eso asks tae kee de GR honda Hk eh Se Warren Christopher, Former Secretary of State, Et Al, v Jennifer K. Harbury $36 U.S. 403; 122 S. Ct. 2179; 153 L ed. 2d 413............1 Petition for Writ of Certiorari Petitioner Beverly Ann Hollis-Arrington respectfully petition for a writ of certiorari to review the judgment of the United States Court of Appeals for the District of Columbia Circuit in this case. Opinion Below The Appeals Court issued an unpublished order on initial review/ 11-15-04 and on petition for rehearing en banc. Jurisdiction “ The Jurisdiction of this Court is invoked under 28 U.S.C. § 1254(1) Constitutional and Statutory Provisions Involved < Article III of the U.S. Constitution Fourteenth amendment of the U.S. Constitution Statement of the Case This petition seeks review of a decision of the United States Court of Appeals for the District of Columbia Circuit, rewriting the lower courts as “patently insubstantial” that it presents no federal questions suitable for disposition. (a) Petitioner believes that the decision of the Court of Appeals is inconsistent with a controlling decision of this court in Warren Christopher, Former Secretary of State, ET. Al. v. Jennifer K. Harbury. (b) Additionally, the congressional intent for the court of appeals is a court of review. The lower court’s order dismisses the case based on res judicata, and lack of personal jurisdiction. © The appeals court states that the case is “Patently insubstantial” and that it presented no suitable question for \deposition. Using “Best v. Kelly, 39 F. 3d 328, 330 (D. C. ) circuit, as controlling law. There is no correlation between this case and the sighted case. (c) Congress did not intend for the appeals court to rewrite a lower courts opinion, and then review its own findings. (d) The lower court dismissed this case finding res judicata applied, even though petitioners claim for denial of access to the court did not accrue until the final case had been | dismissed. There was never a claim for violations of my constitutionally protected right to due process, as a result of the denial of the petitioner’s right of access to the court. However, on appeal, res judicata was not addressed in favor or rewriting the lower courts order, to a patently insubstantial, with no federal question present. (e) The lower court sighted a lack of personal jurisdiction Personal jurisdiction to some defendants (assumingly the judges), even though petitioner plead conspiracy to deprive her the night to due process, as well as depravation of due process. The appeals court did not address the issue of personal. (f) Jurisdiction at all in favor of changing the ruling to no federal question presented. Totally ignoring D.C. Code Ann. § 13- 423. Under the Districts long arm statute, a District court may exercise Personal Jurisdiction over a person, who acts directly or by agent, as toa claim for relief arising from the person’s... transacting any business in the District of Columbia. The complaint alleges that the defendants acted as agents of Fannie Mae, who resides in the District of Columbia. The ruling is in conflict with the D.C. Circuits own precedents and the State code which governs the long arm statute. Reason Why the Writ Should Be Granted This petition should be granted for two principal reasons. First, the Court of appeals decision flatly conflicts with controlling Supreme Court, other circuits, Congressional intent, and their own precedents, and almost operates to negate the Congressional intent for which the appeals court was established. The conflict is that the Appeals court is suppose to review the orders of the lower court. If the Court has the ability to change the orders, then, summarily affirm ~ their change, then, what happens to the petitioner’s due process? Secondly this process in itself violates the constitutionally protected right to due process under the law. THE ISSUES ARE OF EXCEPTIONAL IMPORTANCE TO EVERY ONE WHO COMES TO THE APPEALS COURTS This is the first case to be adjudicated in any circuit in which Five United States Judges have intentionally acted outside their Constitutional authority of Federal Jurisdiction. Title three of the United States Constitution is clear, as to what matter can be heard in Federal Court. Jurisdiction was raised every step along the way ~ give each of the named judges a chance to return case number CV- 02-6568 CBM, back to the court of proper jurisdiction. Each ignored federal jurisdiction, as granted in the United States Constitution, completely. This, I allege was ete in aid of their cocaine This makes this case one of first impression not only for the D.C. circuit but for all circuits. The three judge panel and the full Court chose to summarily dismiss this ugly matter at my constitutionally protected expense. This is a dangerous precedent to set, and --- Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40386016_0004%3A0. Public record. Not legal advice.