MERCEDA D. GOODING, * IN THE

Pro Se Petitioner * COURT OF APPEALS

v. * OF MARYLAND

STATE OF MARYLAND, * January 13th 2016

Respondent * Petition Docket No. _____

* * * * * * * * * * * * * * * * *

PETITION FOR WRIT OF CERTIORARI

This matter concerns Case No. 127795C, appealed from District Court in Montgomery

County, MD filed at the Circuit Court of Montgomery County 8/11/2015. The District Court

cases No #. 0130MF7, held a trial on 7/24/2015, the Petitioner was found guilty of a minor

traffic offense; failure to obey properly placed traffic control device instructions. The petitioner

was denied ADA accommodations by the District Court Judge which contends that the principles

of Rule 2-513 were ignored and the Court refused the application of the granted ADA request

which was implemented 30 days prior to the date of the proceeding, as required by Rule 2-513(c)

and refused to fulfill any of the requirements set forth in Rule 2-513(d) and (e).

I gave the District Court ADA Accommodation request 6/22/2015 & Letter to Judge 5/12/2015

stamped by the court of ADA Accommodations.

“The ADA, codified at 42 U.S.C. §12132 (1990), provides that “no qualified individual with a disability shall, by reason of such disability, be excluded from participation in or be denied the benefits of the services, programs, or activities of a public entity, or be subjected to discrimination by any such entity.

The District court Judge violated the petitioner’s constitutional rights (1st, 14th , 5th and

6th) suppressing factual evidence and supporting “police misconduct” and he restrict me from

“due process” granted ADA accommodations that refuse me the right “defend” and cross

examine the Trooper. The Petitioner moved to Maryland at the age of 42 with 0 points since then

ever year targeted by police officers in Maryland.

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The Petitioner’s statistics demonstrates “inequality” within the MD judicial system and

the violations of “due process” against African Americans (blacks) in the Montgomery County,

MD courts/ traffic stops. Blacks are highest race with traffic stops and this was investigated by

the Justice Department.

(U.S. Department of Justice, 2002). “The unequal treatment of minorities in the criminal justice system manifests itself in a mushroom prison population that is overwhelmingly black and Hispanic; which black and Hispanic deserves to neither trust nor support judicial system”.

White 52.6% 62.1%

*Total of minorities in the State of Maryland is less than the majority one race whites. Black /African American are almost half

compared to whites is the highest in traffic stops, incarceration and paying fines.

These factors contribute to a perception that lawlessness is a “colored” problem. The

disproportionate treatment of blacks and Hispanics within the criminal justice system is a

rational response to a statistical imperative.

“Over 72 percent of people in Maryland’s prisons are African American, according to

the 2010 Division of Corrections Annual Report. “Only 29.4 percent of Marylanders are black.

These contributing statistical factors are part of police misconduct during the traffic stop

on 3/18/2015. The petitioner filed a complaint immediately after she discovered who the

Trooper’s supervisor. Then I reported and file a complaint to internal affairs on 4/9/2015. Later

the Petitioner received harassing phone calls from the State Trooper office that “I am going to

make the Trooper to lose his career”, which I wrote a letter to Attorney General Frosh.

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Race Maryland America

Black African/ American

30.3% 13.2%

American Indian/Native

0.6% 1.2%

Asian 6.4% 5.4%

Native Hawaiian 0.1% 0.2%

Two or more races 2.6% 2.5%

Hispanic or Latino 9.3% 17.4%

Total 49.3% 39.9%

During the District Court Montgomery County, MD trial on 7/24/2015, I tried to argue

police misconduct during the traffic stop however the Judge refused to neither hear nor obtain

evidence such as the ticket which proves the officer’s suppressed his identification or badge.

ATTACHMENT I- Traffic ticket no identity of the Trooper. The Trooper refused to identify

himself only to cover up his wrong doing during the traffic stop on 3/18/2015.

“Public trust and confidence in our legal system are grounded in the perception of

fairness and equality in our courts and in the offices that support our courthouses”. While

minorities are overrepresented in the justice system as defendants in criminal cases and as

inmates in, traffic stops, fines, jails and prisons, they are underrepresented as judges, judicial

appointees, clerks and court employees. There are over 90% of white male Judges, representation

on MD Judicial disability board, internal affairs employees and police officers in the State of

Maryland especially in Montgomery County, MD. “How can justice be fair, colorblind or

impartial?”

The Judge perpetuated police misconduct and allowed dubious police tactics in the court

to demonstrate pervasive culture of police impunity. A Maryland Judge “shall disqualify himself

or herself in any proceedings in which the judge’s impartiality might reasonably be questioned.

MD Rule 16-813, Md. Code of Judicial Conduct Rule 2.11(a) (the “Rules” Similarly, (a)

judge shall avoid conduct that would create in reasonable minds a perception of impropriety.

The Pro se Petitioner was charged a traffic fine $150.00 costs $25.00 which the total fines

and costs for the case $175.50. The Petitioner is a pro se indigent litigant; refused a public

defender because the ticket was minor and the charge was not a jail-able offense, appealed this

case to Circuit Court 8/11/2015. Faretta v. California 422 U.S/ 806 d 562 (1975)

THE ISSUE

The Petitioner raised issues due to her current disability and impairments to receive a fair

trial to prove “racial profiling;” violation of “due process” and “equal protection” in a white male

dominated judicial system in Maryland. The problem is her ethnicity and 1st Amendment rights

to be “express” “racial” and “inequality” against a while male dominated system. The Trooper

perjured two different testimonies, refused to ID himself during the traffic stop or the ticket,

police misconduct and the refusal of ADA accommodations. The Circuit Court Judge violated

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my 5th, 6th and 14th Amendment rights “equal protection”, “due process” and refused me to cross

examine of witness (Trooper). The Petitioner deserve a fair procedural process that is related to

a "liberty," regardless the Judge feel uncomfortable addressing race, inequality and injustice or

“racial profiling” as her defense.

The Circuit Court Judge didn’t allow the Petitioner to defend themselves however relied

on perjured testimony by the State Trooper testified under oath two with different testimonies

regarding the traffic stop on 3/18/2015 (District Court trial 7/24/2015 & Circuit Court trial

12/16/2015). In addition, the Petitioner became ill and the Judge refused to allow her to object

violating her medical privacy and disclosure during trail. The court didn’t obtain her consent nor

subpoena to gain medical records however the Circuit Court Judge took the role as the ADA

coordinator and instructed a clerk to illegally obtain medical records. The Petitioner did not give

the Circuit Court of Montgomery County, MD permission to disclose nor consent my medical

records from any doctors.

Department of Health & Mental Hygiene/disclosures § 4-306 requires a health care provider to disclose a medical record, without authorization of a person in interest, in nine enumerated circumstances.

The Circuit Court Judge acted bias and focused one doctor’s note whereas the Petitioner

provided more than 4 medical certifications even though she has several impairments monitored

by different doctors. She filed ADA accommodations and it was approved; they never requested

any documents to support her impairments. However, the ADA accommodation request was

granted but wasn’t executed during both of the petitioner trails. The petitioner doctors’ with the

exception refused to respond to the Circuit Judge’s clerk phone call requesting disclosure

without proper ID, my consent or a court order to obtain health information , if needed she

should provided if the Circuit Court would’ve asked.

Department of Health & Mental Hygiene/disclosures § 4-309 Refusal to disclose records; violations of subtitle; penalties.

Even though, the Circuit Court Judge administratively took the role of the ADA

coordinator and presumed to know the laws however he instructed the clerk to violate the

Petitioner’s medical privacy/disclosure and/or HIPPA law.

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MARYLAND CODE OF JUDICIAL CONDUCT Rule 2.8. “When bias, prejudice or lack of impartiality is alleged, the decision is a discretionary one . . .” Surratt v. Prince George’s County, 320 Md. 439, 465 (1990). A “trial judge is presumed to know the law and apply it properly.”

QUESTIONED PRESENTED

The issue in the Petitioner’s case is raised the right to a fair trial in a white dominated

Maryland judicial system without impropriety and discrimination.

MARYLAND CODE OF JUDICIAL CONDUCT Rule 1.2(b). Impartiality under the Rules means the “absence of bias or prejudice in favor of, or against, particular classes of parties, as well as maintenance of an open mind in considering issues that may come before a judge.

The Circuit Court Judge was predisposed to believe that the petitioner is guilty, judges

are likely to disbelieve the defendant and judges do not like to call police officers liars. Police are

human and has the ability to perjury themselves in court.

State of Maryland vs ADAM LEWELLEN, officer A Baltimore City police detective who lied about a fictitious controlled narcotics purchase to get into a victim's home was sentenced. On March 27, 2014, appellant pled guilty to one count of perjury and one count of misconduct in office.

See 42 U.S.C 1983 Civil action for deprivation of rights

In part, Police will commit perjury to further the prosecution of a citizen by adding

inculpatory "evidence" to better secure a conviction," to gild the lily of police conduct, or merely

to sanitize the record of uncomfortable facts. Put most broadly, as long as a police officer's use of

power and fulfillment of responsibilities is reviewed (whether by courts, government agencies or

supervisors), and as long as such reviews are deemed by the officer as creating legal

impediments to more immediate goals, he will have an incentive to lie. None of the incentives

and pressures for police officers to lie can be properly distinguished from the reasons many other

citizens have to falsify.

See Skolnick, supra note 16, at 42 "Perjury represents a sub cultural norm rather than an individual aberration"; id. at 43"The policeman lies because lying becomes a routine way of managing legal impediments-whether to protect fellow officers or to compensate for what he views as limitations the courts have placed on his capacity to deal with criminals.

REASONS OF GRANTING THE WRIT

The U.S. Supreme Court has held that racial profiling violates the constitutional

requirement that all persons be accorded equal protection of the law. The "Guidance Regarding 5 | P a g e

the Use of Race by Federal Law Enforcement Agencies" that was issued by the U.S. Department

of Justice in 2003 states:

"Racial profiling" at its core concerns the invidious use of race or ethnicity as a criterion in conducting stops, searches and other law enforcement investigative procedures. It is premised on the erroneous assumption that any particular individual of one race or ethnicity is more likely to engage in misconduct than any particular individual of another race or ethnicity.

Racial profiling in law enforcement is not merely wrong, but also ineffective. Race-based assumptions in law enforcement perpetuate negative racial stereotypes that are harmful to our rich and diverse democracy, and materially impair our efforts to maintain a fair and just society.

This Court should issue a Writ of Certiorari and review this case so as to resolve and

correct their error and grant the petitioner a fair trial and fair procedural process. Under the “due

process” and “equal protection” e.g., ADA accommodations and the implicit guarantee without

depriving the petitioner rights of “life, liberty or freedom of speech.

See Whren v. United States, 517 U.S. at 813. 

The right to “due process and equal protection” of the law in regards to ADA

accommodations. The Circuit Court Judge realized that the petitioner was a disabled plaintiff

had no chance of prevailing in her trial and violated the court constitutional violations (equal

protection and due process. The Petitioner were supposed to have 1 hour of court and enough

time to present her case, the Circuit Court Judge announced 15 minutes at the beginning of trial

12/16/2015. The Notice of Pending Events I was supposed to be granted 1 hour of trial.

However, the respect to the refusal of ADA accommodations the petitioner didn’t have access to

the courts which is a fundamental right. 

Tennessee v. Lane the court said, “The unequal treatment of disabled persons in the administration of judicial services has a long history, and has persisted despite several legislative efforts to remedy the problem of disability discrimination.” The trial judge never considered whether the plaintiff had been discriminated against right of an opportunity equal to that of a person without a disability to litigate her claim. See Tennessee v. Lane, 541 U.S. 509, 522, 524, 529, 531, 534 (2004).

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During the trial on 12/16/2015, I request that my escort Jackie Rhrone to read my letter to

the court ATTACHMENT 1I – Merceda’s letter. After the letter was read in court the Judge

was immediately defensive to my statements such as “racial profiling” and racial disparity within

the justice system. The Judge stated that he didn’t know the petitioner’s ethnicity before the

court. The Judge statement is dishonest, (1) the Judge had possession of my file which identifies

my race and my name is “urban” “Merceda” originated from Haiti (black). After the letter was

read, the petitioner informed the Circuit Court Judge that she was “passing out” and he told her

to leave instead of ensuring that the petitioner receives a fair trial. The Judge action was

egregious after the petitioner yelled out three times that she felt like she was going to pass out

and refused to provide her medical treatment. The Judge lost his integrity and his action was

horrendous and monstrous only to abuse the petitioner’s due process. The Judge is a public

official/ and officer of the court.

According to Black's Law Dictionary a "public official" is "[o]ne who holds or is invested with a public office; a person elected or appointed to carry out some portion of a government's sovereign powers."  "Public officer" is defined in a similar way.

The terms "public officials" and "public officers" are interchangeable. Nationally “injured

or ill” black citizens in the hands of public officials/ servants are unsafe especially when they

ignore the request medical aid to benefit a “conviction” or just “de-value” black lives. The

Circuit Court Judge informed the petitioner to “leave the court” demonstrating a lack of

integrity, heartless only to favor the officer to secure a conviction. The petitioner laid in the

Circuit Court in Montgomery County, MD lobby on the second floor until my escort came to

escort me out the court to get some “air”. This is the example as blacks (African Americans)

faced as we are requesting medical assistance in the presence of a public official/servant.

Barbara Dawson, Ralkina Jones, Raynetta Turner, Freddie Gray and Eric Garner who died in the

hands of public officials/servants who didn’t value their life because of their ethnicity. Judge

Debelious III demonstrate this bias and prejudicial behavior questions his ethics, integrity and

bias actions against the petitioner.

MARYLAND CODE OF JUDICIAL CONDUCT Section B 1.2 (a) 2.2 -2.3 Further, a judge “shall act at all times in a manner that promotes public confidence in the independence, integrity, and impartiality of the judiciary.”

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Judge Debelious III, Administrative Judge for Circuit Court Montgomery County, MD a

leader of the court should undertake the exercise of self-examination to identify actual prejudice,

discrimination, and practices that appear to be discriminatory. This exercise is also salutary in

and of itself. Effective outreach and a willingness to listen and self-examine bring diversified

people into the system and create a confidence in the interest, concern, and goodwill of the

system. As a leader, he must be ready to work together to redesign those aspects that have

operated in a discriminatory, exclusionary, or otherwise unfair way. Equally important are the

affirmative commitments, not just to eliminate the outcroppings of bias, but also to make justice

equally available, fair, and impartial.

Judges can abuse their power when there is no consequence because of absolute

immunity for discriminatory actions. Another issue, Maryland Judicial disabilities board is

identical to internal affairs they (all) are co-workers and dominated by white males.

ANTHONY QUINTIN KELLY, #352736 PLAINTIFFS, V. JOHN W. DEBELIUS

LORETTA E. KNIGHT DIANNA K. SCHAEBERLE DEFENDANTS,

CIVIL ACTION NO. AW-10-2363

UNITED STATES DISTRICT COURT, D. MARYLAND

SEPTEMBER 3, 2010

Judge Debelius and the court staff were accused for “deceptive and dishonest” pattern of practice against litigants. He was accused of violating a plaintiff’’s civil rights acting “above the law” abusing and taking advantage the “immunity clause”. The immunity clause for Judges were created to ensure that a judge can be “fair and impartial”. However, some Judges uses their position in power for political favors, support their biases, and oppress litigants for personal causes. However, Judge Debelius is otherwise entitled to absolute immunity for judicial actions. See Stump v. Sparkman, 435 U.S. 349. 356-57(1978) Pressley v. Gregory, 831 F. 2d 514 (4th Cir. 1987) Court clerks likewise enjoy derivative (absolute) immunity when they are acting in obedience to a judicial order or under the court's direction. See Mc Cray v. Maryland, 456 F2d 1(4th Cir. 1972): Lockhart v. Hoenstine, 411 F. 2d 455 (3rd Cir. 1969).

The Circuit Court Judge acknowledges that the petitioner is impaired and requested ADA

accommodations for trial 12/16/2015 when ADA wasn’t executed, I requested a postponement of

the trial. However, the Judge maliciously violated my “due process” and “equal protection”

clause ADA accommodations. I became ill during the trial and the Judge knew my inability to 8 | P a g e

cross-examine the State Trooper, only to favor the Trooper. The Circuit Court Judge didn’t invite

all my medical experts, however, violate the “privacy act” and instructed the clerk to call my

doctor’s offices. He refused to invite the court’s disability coordinator to advise him on the

effects of the plaintiff’s condition the ability to litigate her case. The judge denied the

postponement motion on the eve of court on 12/15/ 2015 and during trail in a way suggestive

failure to understand the petitioner’s illness and disregarded the physical and mental

impairments; including the psychologist who explain in her letter why I couldn’t move forward

with the case; the Judge deny the truth. After going through the disability coordinator and the

judge, the accommodations were not forthcoming; I couldn’t consider filing a motion for

declaratory relief asking the court to declare what must be done to comply with the ADA for the

trail date 12/16/2015.

Judges who have been giving the wink and nod to questionable police testimony, who

have been working with an improper (and frankly illegal) presumption in favor of police witness

credibility, must change both practice and perspective. One of the strongest reasons that police

lie in court is the simple fact that judges allow them to get away with it. The wink and the nod

convey many messages-either that the judge is politically hamstrung and so cannot afford to

confront the lies or that the judge defers to the police witness, knowing that confronting the lie

aids the defendant or most disturbingly, that the judge actually approves of the lie.

United States v. Bayless [11l, 921 F. Supp. 211 (S.D.N.Y. 1996), where after months of political fallout and calls for the Judge's impeachment.

Judge W. Kennedy Boone III who was driving and received a DUI, however, his

punishment was less severe than a citizen who is charged with a DUI. Another Judge Bryant

Cochran 11th US Court abused his power and cannot be sued due to judicial immunity; Judges

takes advantage with this clause “Judicial Immunity”.

The State of Maryland Courts must improve “access to justice” and diminished

discrimination which continues to threaten equality within the judicial system. Instances of bias

include, but are not limited to, bias towards an individual’s gender, race and ethnicity, and sexual

orientation. Make strides toward eliminating bias in their court system through accomplishments

such as increased access to justice, improvement jury pool representation, promoting diversity in

court appointments, providing adequate interpreter services, conducting educational programs,

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encouraging diversity in law enforcement, and promoting the availability of legal representation

for the poor.

Katherine Getty, State Prosecutor should avoid a conflict of interest with respect

to her official duties.  A prosecutor should not permit his or her professional judgment or

obligations to be affected by his or her own political, financial, business, property, or personal

interests. The State prosecutor dismiss the case on record 12/16/2015, however, proceeded even

though the petitioner couldn’t represent due to health impairments. The Prosecutor stated in court

that there were no police report/notes for the traffic stop on 3/18/2015, the Petitioner requested

discovery November 30, 2015, & December 13, 2015.

The Petitioner’s requests discovery on 11/7/2015, 11/30/2015 &12/13/2015; the

petitioner was refused discovery request by the State prosecutor and Lieutenant Pickett to

prepare for trial. Even though the Trooper perjured himself the State prosecutor preceded trial

on 12/16/2015 without correcting the error of false testimony by the Trooper.

On 3/18/2015, there was an incident report regarding the traffic stop. Trooper Knowles

neither refuse to identify himself nor was his identity exposed on the ticket. Therefore, with the

assistance of a Montgomery County legislative council, the petitioner contacted the Troopers’

superior Sgt Burton #0407 who supplied the petitioner’s name and identification. His refusal

only indicates “deception” during the traffic stop on 3/18/2015; that he did not want me to report

him. By the Trooper’s own testimony 7/24/2015 in District Court indicates that there was an

incident during the traffic stop on 3/18/2015. On 4/9/2015, I reported the traffic stop

incident/police misconduct against the Trooper who refused to give me his name during the

traffic stop on 3/18/2015; how I was stopped is questionable which caused me “anxiety” and

“fear”. On 4/10/2015, the petitioner reported to the State Attorney General office concerning

intimidating retaliatory calls from State Trooper’s main office therefore, the petitioner was

retaliated for filing a complaint against the Trooper. I believe the court, Trooper office, Internal

Affairs and State prosecutor’s desire to suppress the Trooper’s behavior and deception

concerning the traffic stop 3/18/2015.

Police officers have the ability to lie to expected to omit, redact and even lie on their police reports sworn or unsworn; they will conceal or misrepresent to cover up corruption and brutality. They are trained to deceive during investigations as part as good police facts and even lie to cover up the misconduct of fellow police officers See Chi & Wells supra 7the effects of the “blue wall of silence” in covering up police misconduct.10 | P a g e

Katherine Getty, a Maryland State prosecutor who is in charged with responsibility for

prosecutions in its jurisdiction supported actions violating my civil rights to due process

especially if she tried to suppress my testimony concerning the egregious actions of the State

Trooper/ and officials.  The State prosecutor suppose to acted as an administrator of justice, an

advocate, and an officer of the court; the prosecutor must exercise sound discretion in the

performance of his or her functions. She requests to dismiss the case because she agreed that the

Petitioner couldn’t represent due to health impairments. However, to cooperate with corruption

from others she proceeded to ensure a conviction not to seek justice, however merely to convict

and to violate the Petitioner’s civil rights/due process. As part of the prosecutor’s job is to ensure

to seek to reform and improve the administration of criminal justice, especially when

inadequacies or injustices in the substantive or procedural law come to the prosecutor's attention,

he or she should stimulate efforts for remedial action. She refused to act against her own witness

Officer Knowles and the Judge. The Trooper perjured in court his testimony stating that the

petitioner was “speeding” to pass a black car. However, the officer’s testimony in District Court

7/24/2015 was different the Trooper perjured himself and by admission “wrote notes”

concerning the traffic stop on 3/18/2015. However, the State prosecutor and State Trooper

Lieutenant Pickett suppressed the officer’s notes and refusing my discovery request. The State

Prosecutor discovery request was sent 12/6/2015 however requested information “no later than

30 days before the 1st scheduled trial date” which is 10/18/2015. The State prosecutor knows it’s

impossible to comply with her request which the Petitioner find offensive.

ATTACHMENT III- Discovery requests by the State Prosecutor.

For instance, police lying is no "dirtier" than the prosecutor's encouragement or conscious

use of tailored testimony or knowing suppression of Brady material; it is no more hypocritical

than the wink and nod of judges who regularly pass on incredible police testimony and no more

insincere than the demagogic politicians who decry criminality in our communities, but will not

legislate independent monitoring of police wrongdoing. In Brady v. Maryland, the Court held "that the suppression by the prosecution of

evidence favorable to an accused upon request violates due process where the evidence is

material either to guilt or to punishment, irrespective of the good faith or bad faith of the

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prosecution." In that case, the prosecution had suppressed an extrajudicial confession of

defendant's accomplice that he had actually committed the murder. "The heart of the holding

in Brady is the prosecution's suppression of evidence, in the face of a defense production request,

where the evidence is favorable to the accused and is material either to guilt or to punishment.

Important, then, are (a) suppression by the prosecution of a request by the defense, (b) the

evidence's favorable character for the defense and (c) the materiality of the evidence.

According to the American Bar Association, Prosecutor’s Standard  3-1.5 : Duty to Respond to

Misconduct (Maryland Rules )

See Brady v. Maryland & U. S v. Agurs

The Petitioner is requesting a dismissal because she became sick and had to hear the trial

over a court taping. The Petitioner never received a fair trial under Constitution “freedom of

speech” “equal protection” and “due process”; violating her right to speak about racial

disparity/profiling, cross-examine the prosecutor’s witness and her impairments respectfully

gave her the inability to stand trial. ADA accommodations were approved however not executed,

Trooper perjured in court and the Circuit Court Judge abused his fiduciary powers with bias,

egregious behavior full of dishonesty violating the petitioner’s medical privacy, refused to call

medical assistance, refused to allow the petitioner’s access to Circuit Court. Even though the

State prosecutor (with the court taped) admit that I was too ill to stand trial, she refused to act to

ensure the Petitioner have the discovery requests. The Petitioner became ill and the Judge

promoted an unsafe environment; the Circuit Court Judge unfairness and lack of care caused the

petitioner anxiety.

CONCLUSION

WHEREFORE, the Petitioner respectfully requests that this Court grants this Petition for Writ of Certiorari.

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Respectfully

________________Merceda D. Gooding

Pro Se Litigant

FONT: Times New Roman 12

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 13th day of January 2016, a copy of the foregoing

Petition was mailed postage prepaid to:

Brian Frosh Katherine GettyAttorney General State’s AttorneyOffice of the Attorney General for Montgomery County200 Saint Paul Street 50 Maryland AvenueBaltimore, MD 21202 Rockville, MD 20850

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Respectfully Submitted,

________________Merceda D. Gooding

Pro Se Petitioner

ATTACHMENTS

1. ATTACHMENT I - Traffic ticket no identity of the Trooper

2. ATTACHMENT II -Merceda’s letter

3. ATTACHMENT III - Discovery requests by the State Prosecutor.

4. DOCKET ENTRIES, CASE NUMBER 127795

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“A justice system which tolerates injustice is doomed to collapse- Leonard Noisette, Former Director Harlem”

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