No.
`
`IN THE
`SUPREME COURT OF THE UNITED STATES
`
`ELENA STURDZA
`Petitioner
`Vs.
`THE GOVERNMENT OF THE UNITED ARAB EMIRATES,
`Respondent
`VASILIOS DEMFFRIOU,
`Personal Representative of the Estate of
`ANGELO S DEMEThJOU & ASSOCIATS,
`ANGELO S DEMETRIOU,
`Respondent
`NATHAN LEWIN, et al,
`Respondent
`
`On Petition for a Writ of Certiorari to
`
`UNITED STATES COURT OF APPEALS
`FOR THE DISTRICT OF COLUMBIA CIRCUIT
`District Court No. 98-cv-02051 (HHK)
`Court of Appeals No. 00-7279, 06-7069, 10-7054, 14-7038, 17-7036
`Supreme Court No. 02-5218, 10M63, 11-5304, 11-5307, 11-5645
`
`PEHTION FOR WRIT OF CERTIORARI
`ELENA STURDZA
`ELENA STURDZA ARCH ITECT
`6705 Tomlinson Terrace
`Cabin John, MD 20818-1307
`Tel: 301 320 4345
`
`October 30, 2018
`
`PRO SE
`THE SUBJECT OFTHIS CASE:
`
`

`

`No.
`
`IN THE
`
`SUPREME COURT OF THE UNITED STATES
`
`LEM4—
`(Your Name)
`
`- PETITIONER
`
`uirb4A4
`
`RESPONDENT(S)
`
`ON PETITION FOR A WRIT OF CERTIORARI TO
`
`W 'lEl rcrs rLs'
`Luj
`(NAME OF COURT THAT LAST RULED ON MERITS OF YOUR CASE)
`
`PETITION FOR WRIT OF CERTIORARI
`
`(Your Name)
`
`(Address)
`
`iqLI/'iS€N T-1q
`
`J1 2
`(City, State, Zip Code)
`3Dt
`(Phone Number)
`
`- (o7
`R ECEIVED
`2018
`HECLERK
`URT, U.S.
`
`

`

`No
`
`IN THE
`
`SUPREME COURT OF THE UNITED STATES
`
`LEM4-
`(Your Name)
`
`- PETITIONER
`
`tJ!irEbhA4?M3
`
`RESPONDENT(S)
`
`ON PETITION FOR A WRIT OF CERTIORARI TO
`
`u qEr. srs rs'
`Lef
`(NAME OF COURT THAT LAST RULED ON MERITS OF YOUR CASE)
`
`PETITION FOR WRIT OF CERTIORARI
`
`L-4A
`(Your Name)
`a-rb
`(Address)
`
`(City, State, Zip Code)
`
`(Phone Number)
`
`23 t3— (o7
`10
`ERECEIVED]
`J DEC 11 2018
`OFFICE OF THE CLERK I
`SUPREME COURT, U.S. I
`
`

`

`Is a work of extreme national importance. The subject of the infringement is of an
`extraordinary national importance since it constitutes an innovative work of scientific useful
`
`arts arising from within the Islamic culture in ways that has never been risen before.
`Poses several questions of exceptional importance. It is a criminal infringement of an
`extraordinary copyrighted work by a foreign state. Fired lawyer illegally rehires himself with
`
`the aid of illegally appointed Guardian.
`Has no precedent in the U.S. There is no other criminal infringement by a foreign state
`of such a complex work combining so many trades.
`Its ruling would create a precedent of national and global importance. This case law
`will affect the whole architectural establishment in the U.S. and its role in the whole world.
`Is a world-class copyrighted work that must be fully protected as mandated by the
`Constitution. Article I of the Constitution delegates the Congress to encourage the progress
`of the science and useful arts. For the first time in history an architectural design incorporates
`
`the latest discoveries in science, medicine, technology, engineering and useful arts in a
`
`modern Islamic architectural design.
`QUESTIONS PRESENTED
`The affirmative answer to the following questions constitutes the proof
`that both US Courts have drastically departed from the accepted and usual
`course of judicial proceedings in a case that is of national and global
`importance.
`
`THE "INSTANT CASE" ON REMAND TO THE DISTRICT COURT TO RULE ON
`THE MOTION FOR APPOINTMENT OF GUARDL4NAD LITEM. 2002-2011
`
`Whether the court erred when it adjudged that "The district court's May 27, 2009, and
`
`July 23, 2009, orders are not properly before the court, because the notice of appeal is untimely
`
`as to them."
`
`Whether the court erred when it adjudged that "The district court did not abuse its
`discretion in denying appellant's motions for reconsideration under Fed. R. Civ. P. 60(b).", and:
`
`11
`
`

`

`iI
`
`"Appellant's motions for reconsideration raised no new arguments concerning the
`
`appointment, and the district court could not have granted a Rule 60(b) motion on grounds
`
`that this court had already rejected. Moreover, appellant's allegations do not satisfy any of the
`
`specific criteria for relief in Rule 60(b) (1)-(5), or present "extraordinary circumstances" that
`
`would entitle her to relief under Rule 60(b) (6).
`
`Whether the court erred when it adjudged that "Appellant has shown no error in the
`
`district court's denial of her motion for leave to file a response to the question whether a
`
`guardian ad lithem should be appointed, as she received an opportunity to speak at a hearing
`
`on the issue, and the proffered response appears to have consisted of material that was either
`
`irrelevant to the issue at hand or legally unsound."
`
`Whether the court erred when it adjudged that "the district court did not abuse its
`
`discretion in denying appellant's motion for leave to file a supplemental complaint, or her
`motion for reconsideration of the district court's denial of leave to file a supplemental complaint
`
`as of right.", and "Because the guardian has been given the authority to "assist [appellant] 's
`
`counsel with prosecuting this case in Ms. Sturdza's best interests," appellant cannot
`
`unilaterally decide to file a supplemental complaint."
`
`Whether a party has the right to fire his or her Lawyer, enter Pro-se representation, file
`
`in Court important meritorious information, and correct the Court Record, his or her Lawyer
`
`refused to do.
`Whether the Courts can declare a party "incompetent person", and a "client with
`diminished capacity" only because the party wants to correct the Court Record.
`
`Whether the courts drastically departed from their normal procedure when the US District
`Court, violating all the Laws governing the Appointment of a Guardian ad Litem, appointed the
`Guardian to a person who is not an infant, an incompetent, or a disabled, and does not fit any
`
`description of actions taken for which a Guardian should be appointed under law, and the US
`
`111
`
`

`

`Court of Appeals, violating the same laws, Summarily Affirmed the District Court's decision.
`
`8. Whether the courts drastically departed from their normal procedure when the US
`
`courts accepted that a lawyer, currently defendant, fired and sued for good cause by a party,
`
`be rehired by the Guardian to represent that party, against her will, to whom the layer caused
`
`great harm.
`9. Whether the Courts acted under the rule of a lawyer instead of the rule of law when they
`
`helped Lewin not only to amend the DC Rule of Professional Conduct 1.14 but to create a
`
`precedent to be later used as a case law to validate the Rule by allowing fired attorneys to
`
`declare their clients incompetents for the lawyer's financial interest.
`
`10. Whether this case ruling would create precedents of national and global importance
`
`because:
`Its ruling will create a case law that will help appoint a Guardian to any person without any
`
`reason, and will affect anyone in U.S. and even in the world;
`
`Its ruling will create a second case law that will affect any person in U.S. who wants to
`
`control his/her lawsuit;
`Its ruling will create a third case law that will affect any person in U.S. who wants to fire
`
`his/her lawyer for good cause.
`
`11. Whether the US Court of Appeals for the District of Colombia violated the FRAP Rules
`
`when it denied the FRAP given right to file a Petition for Rehearing and Rehearing en Bane to a
`party who was not served with the final order, nor notified in any other way, and not being
`
`permitted at the time to file electronically did not receive an electronic notice.
`
`12. Whether the District Court has helped the irreparable harm caused to Appellant Sturdza
`
`by the Defendants to grow enormously when it stalled the entire case for eight years,
`
`preventing her to obtain Discovery and giving a green light to the Defendants to keep on
`
`infringing her copyright.
`
`iv
`
`

`

`Whether the US Court of Appeals and the US District Court for the DC violated Articles
`
`I and III of the Constitution and the US laws when they helped the plaintiffs counsels to
`
`prevent the completion of an important innovative masterpiece in the domain of scientific useful
`
`art by denying her a fair trial.
`Whether the US Court of Appeals and the US District Court for the District of Colombia
`
`violated Articles I and III of the Constitution when they helped the plaintiffs counsels, not only
`
`to engage in a willful process of severe intimidation and severe intentional infliction of
`
`emotional distress, but, by preventing the creation of other innovative scientific useful art, to
`
`diminish the progress of science and arts in the US and in the entire world.
`
`Whether the US Courts can approve such Settlement through which the defendants
`steal millions from plaintiff.
`
`Whether the US Court of Appeals intentionally ruled considering Lewin's lies as truth
`and refused to consider the proof that she was licensed before, during and after her
`Competition submission.
`
`Whether the US Court of Appeals can deny Sturdza's Petition for Rehearing en Banc
`
`when she filed the proof that she was licensed and she was right.
`
`Whether both US Courts can force Sturdza to spend all her time during the 20 years of
`
`trial to work as a lawyer instead of working as an architect creating high quality buildings for
`people to live a healthier, better life in them.
`
`Whether both US Courts can prevent Sturdza to work on her inventions, which can
`
`improve the lives of people and even save their life when mother- nature strikes down.
`
`Whether both US Courts do not care about thousands of lives being lost, they only care
`
`that Plaintiff Appellant not to be paid for her Competition Winning Design UAE used to build
`
`two Embassies and Morrison one Embassy. Demetriou, Morrison and an architect in Germany
`were paid, not her. Sturdza worked on her Competition Winning Design for five full years.
`
`V
`
`

`

`two Embassies and Morrison one Embassy. Demetriou, Morrison and an architect in Germany
`
`were paid, not her. Sturdza worked on her Competition Winning Design for five full years.
`LIST OF PARTIES
`All parties in the 'Instant Case" appear in the caption of the case on the cover page.
`
`TABLE OF CONTENTS
`OPINIONS BELOW.........................................................................1
`JURISDICTION ................................................................................ 2
`CONSTITUTIONAL AND STATUTORYPRO VISIONS INVOLVED
`3
`STATEMENT OF THE CASE ............................................................4
`REASONS FOR GRANTING THE WRIT .............................................15
`CONCLUSION...............................................................................46
`
`INDEX TO APPENDICES
`APPENDIX A. US Court of Appeals for the District of Columbia OPINIONS
`
`And US District Court for the District of Colombia OPINIONS
`
`APPENDIX B: DOCUMENTS and PLEADINGS filed in the US Court of Appeals:
`
`BRIEF FOR THE PLAINTIFF-APPELLANT ELENA STURDZA
`
`APPENDIX A: Applicable laws and Appendix A to Brief
`
`APPENDIX B: Photos of her design and of the infringing designs.
`
`All PETITIONS and their APPENDIXES listed below are on file.
`
`PETITION FOR A WRIT OF CERTIORARI filed in the US SUPREME COURT
`
`on August 31, 2015.
`
`Vi
`
`

`

`APPENDIX B: US District Court for the District of Colombia OPINIONS .............
`
`APPENDIX C: DOCUMENTS and PLEADINGS filed in the US Court of Appeals...
`
`APPENDIX D: PETITION FOR A WRIT OF CERTIORARI filed in the US SUPREME COURT
`
`on September 15, 2010, and, PETITION FOR A WRIT OF CERTIORARI filed in the US
`
`SUPREME COURT on July 11, 2011 with the Appendixes listed below.
`
`THE "INSTANT CASE"
`APPENDIX A: US Court of Appeals for the District of Columbia ORDERS ............
`
`APPENDIX B: US District Court for the District of Colombia OPINIONS .............
`
`APPENDIX C: DOCUMENTS and PLEADINGS filed in the US Court of Appeals...
`
`THE ORIGINAL CASE
`See APPENDIX filed in Case No. 02-5218
`
`APPENDIX A: US Court of Appeals for the District of Columbia OPINIONS
`
`APPENDIX B: US District Court for the District of Colombia OPINIONS
`
`APPENDIX C: DOCUMENTS and PLEADINGS filed in the US Court of Appeals.
`
`APPENDIX D: COMPLAINT and PLEADINGS filed in the US District Court in a RELATED
`
`CASE against Defendants Szymkowicz and Mattar, Defendant UAE's Counsel and Contract
`
`Negotiator, and their former in house Legal Advisor.
`
`Vii
`
`

`

`TABLE OF AUTHOR11Y
`FEDERAL STATUTES
`18 U.S.C. sec. 2319
`17 U.S.C. sec. 501, 502, 503, 504, 505, 506
`42 U.S.C. sec. 1983, 1985, 1986
`28 U.S.C. sec. 1251, 1602, 1603, 1605, 1606
`Pub. L. No. 90-553, Stat. 958, The International Center Act as amended by
`Pub. L. No. 97- 186, Stat. L. 101
`
`FEDERAL REGULATIONS
`THE DEVELOPMENT CONTROLS for the CHANCERY SECTION of the
`INTERNATIONAL CENTER in the DISTRICT OF COLUMBIA adopted by the
`National Capital Park ant Planning Commission in 1971 and amended in 1976-1984
`THE DEPARTMENT OF STATE APPROVAL PROCESS FOR CHANCERY
`CONSTRUCTION AT THE INTERNATIONAL CENTER. . .appendix C, Sc 02-5218
`FAR Title 48 chapter 1 part 36.209
`
`STATE STATUTES
`
`D.C. Code sec. 2 - 262 (1993)
`D.C. Code sec. 2-263 (1993)
`D.C. Code sec. 36-401,402,403,405,407(1989)
`D.C. Code sec. 2 - 2501, 2511 (1981)
`DC ST § 47-2853.04, DC ST § 47-2853.05, (2001).............................20
`
`viii
`
`

`

`IN THE
`SUPREME COURT OF THE UNITED STATES
`
`PETITION FOR WRIT OF CERTIORARI
`
`Petitioner respectfully prays that a writ of certiorari issue to review the judgment below.
`
`The Petition demonstrates that: The subject of this case is of national and global importance,
`
`Exceptional circumstances warrant the exercise of the Court's discretionary powers, and
`
`Adequate relief cannot be obtained in any other form or from any other court because both
`
`courts rule considering appelees' lies as truths and appelant's truths as lies.
`OPINIONS BELOW
`
`THE "INSTANT CASE" APPOINTMENT OF GUARDIAN Al) LITEM
`2002-2011
`
`The orders of the US Court of Appeals for the DC appear at Appendix A
`
`The opinion of the US Court of Appeals for the DC of 03.08.02, published in the Federal
`
`Reporter, 281 F.3d 1287, appears at Appendix A to the petition filed on September 16, 2010.
`See Petition for a Writ of Certiorari dated September 15, 2010 retained by the
`US Supreme Court with the denied Motion 10M63.
`
`The opinion and orders of the US District Court for the DC appear at Appendix B
`The District Court's 06.27.09 Order Granting the Motion for Appointment of Guardian Ad
`
`Litem
`The District Court's 07.23.09 Order Appointing a Guardian Ad Litem and Memorandum
`Opinion.
`The Motion for Reconsideration of December 17, 2009 Order Granting Summary Affirmance
`
`appears at Appendix C of the July 11, 2011 Petition for a Writ of Certiorari, and at
`Appendix C of the September 15, 2010 Pet ition for a Writ of Certiorari, 10M63.
`
`

`

`JURISDICTION
`
`THE "INSTANT CASE"
`
`[x] For cases from federal courts:
`The date on which the United States Court of Appeals decided my case was January 18,
`2011.
`[]No petition for rehearing was timely filed in my case.
`[xl A timely petition for rehearing was denied by the United States Court of Appeals on the
`following date: April 11, 2011, and a copy of the order denying rehearing appears at
`Appendix A of the previous petition for a writ of certiorari filed on July 11, 2011.
`[1 An extension of time to file the petition for a writ of certiorari was granted to and including
`(date) on (date) in Application No. A. The jurisdiction of this Court is invoked under 28 U. S.
`C. § 1254(1).
`
`THE ORIGINAL CASE
`
`[x] For cases from federal courts:
`The date on which the United States Court of Appeals decided my case was January 18,
`2015.
`[1 No petition for rehearing was timely filed in my case.
`[x] A timely petition for rehearing was denied by the United States Court of Appeals on the
`following date: August 15, 2018, and a copy of the order denying rehearing appears at
`Appendix A.
`I An extension of time to file the petition for a writ of certiorari was granted to and including
`(date) on (date) in Application No. A . The jurisdiction of this Court is invoked under 28 U. S.
`C. § 1254(1).
`
`Supreme Court Rule 10 (a).
`Considerations Governing Review on Certiorari.
`I have further made my case that both federal courts, the US District Court and the
`US Court of Appeals have "so far departed from the accepted and usual course of
`judicial proceedings, ... as to call for an exercise of this Court's supervisory power,".
`
`2
`
`

`

`CONSTITUTIONAL AND STATUTORY PROVISIONS INVOLVED
`
`THE CONSTITUTION OF THE UNITED STATES:
`Article I - Section 8:
`"The Congress shall have power.................................
`To promote the progress of science and useful arts, by securing for limited
`times to authors and inventors the exclusive right to their respective writings
`and discoveries.
`
`To make all laws which shall be necessary and proper for carrying into
`execution the foregoing powers, and all other powers vested by this
`Constitution in the government of the United States or in any department or
`officer thereoL"
`Article III - Section 2:
`'The judicial power shall extend to all cases, in law and equity, arising under
`this Constitution, the laws of the United States and treaties made, or which
`shall be made, under their authority; - to all cases affecting ambassadors,
`other public ministers and consuls;... - to controversies between a state, or the
`citizens thereof, and foreign states, citizens or subjects.
`In all cases being affecting ambassadors, other public ministers and consuls,
`and those in which a state shall be the party, the Supreme Court shall have
`original jurisdiction".
`TITLE 28> PART W> CHAPTER 81 > Sec. 1251.
`Sec. 1251. - Original jurisdiction
`(b) The Supreme Court shall have original but not exclusive jurisdiction
`of:
`(1) All actions or proceedings to which ambassadors, other public
`ministers, consuls, or vice consuls of foreign states are parties;
`In this Case a foreign state is a Party, therefore under the Article III - Section 2 of the US
`
`Constitution the Supreme Court shall have original jurisdiction"
`
`

`

`STATEMENT OF THE CASE
`
`Plaintiff Appellant Sturdza
`Is the Winner of The Design Competition for the New
`United Arab Emirates Chancery Complex in Washington, Dc.
`A Masterpiece Created in One Year.
`
`In early 1994 Plaintiff Appellant Sturdza won first place in a design competition for the
`
`new United Arab Emirates Chancery Complex in Washington, DC over 15 competitors.
`Among them were world famous giants like SOM New York, Leo Daly and RTKL (ranking in
`the top 30 in the world), world famous like the former The Architects Collaborative of Boston
`
`(the firm of Walter Gropius, founder of the Bauhaus), and other established local firms,
`
`including the firm of the Dean of the University of Maryland.
`
`His Excellency Ambassador Mohammad Al-Shaali and other jury members
`
`congratulated Elena Sturdza for having the best design, the only one respectful to their
`architectural heritage, and the only one with a very large and impressive gathering space for
`
`their receptions.
`
`Contract Negotiations and Architectural Services
`Performed Over a Period of 4 Years for Free.
`At their request, Elena Sturdza, sole proprietor of Elena Sturdza Architect, submitted the AlA,
`
`B 141 Agreement between Owner and Architect. Elena Sturdza negotiated the contract and
`
`provided architectural and engineering services for the project until 1997. The leading
`publication on new construction projects, the Dodge Report, based on information given by
`U.A.E., listed Elena Sturdza Architect as the Architect for the U.A.E. Embassy project from
`May '94 until May '97.
`At the End of December 1997 Sturdza Discovered that
`Demetriou Stole Her Design.
`
`Mr. Hamdan testified that he has no doubt that somebody gave Sturdza's competition
`
`drawings to Respondent Demetriou, telling him that her design was considered the best.
`
`Demetriou's competition submission is a derivative of the
`
`4
`
`

`

`Appellant's wining design.
`
`Demetriou prepared a derivative of Sturdza's design very similar to hers, but in order to give it
`
`a different look and claim it as a design of his own, he stripped off the exterior lattice wall, and
`
`some elements, Sturdza's modern innovative designs inspired from the Islamic Architecture.
`
`Demetriou's design acquired through plagiarism placed third in the competition.
`
`In August 1998 Filed a Lawsuit in the U.S. District Court for DC.
`UAE And Demetriou Shared Full Discovery
`The Court Denied Discovery To Sturdza
`Zero Discovery In Four Years
`At the July '99 Hearing, knowing that Sturdza's lead Counsel, Mark Lane, was ill for some
`time, the judge opened discovery for Demetriou only (see transcript of status hearing on file).
`The Court forced Sturdza to produce detailed answers and all the documents. The
`
`respondents shared it. Sturdza's remaining counsels refused to serve discovery requests,
`
`although they promised to the court that they would, they then declared themselves
`
`incompetent and withdrew. See transcripts of December '99 and February '00 Status
`
`Hearings on file. Sturdza's new Counsels Anthony Herman and Ron Dove of Covington and
`
`Burling did not serve discovery requests although the discovery period was still open. When,
`
`at the June 26'00 status hearing Mr. Dove asked for the court's permission to serve discovery
`
`requests, the Court refused. See transcript of Status Hearing of June 2000 on Me.
`Expert Witness Report Removed From Court File,
`Two Others Not Considered
`
`The petitioner's first expert, Kenneth Britz, examined the drawings on July 15'98 prior to the
`filing of the complaint on August 26'98. The petitioner's first Expert Witness Report of October
`8'98 was removed from the District Court file, (see transcript of December '99 Status Hearing
`
`on file when the Court said the report was not on file). The petitioner and a witness saw the
`
`report on file prior to the December '99 hearing. The second, more detailed report of Kenneth
`
`Britz and the report of Renata Holod, professor at the University of Pennsylvania and member
`
`5
`
`

`

`of the jury for the Aga Khan Award for Islamic Architecture, were not considered. The US
`Court of Appeals, in the March 8 2002 Opinion questions the necessity of expert witnesses.
`
`The petitioner's Design is a brake-through in today's concepts of architectural design, which
`
`can never be understood if not explained by an expert. Ordinary people in the US are not
`knowledgeable enough of traditional and modern Islamic architecture to be able to decide
`
`what is original in Petitioner Sturdza's design.
`
`Transcript Under Seal Altered
`
`Petitioner's allegations were removed from the transcript of the Ex Parte Hearing of
`
`February 16, 2000. Also statements of her counsels were altered. On appeal, counsel Lewin
`
`refused to mention it in the brief. The Court of Appeals refused to permit petitioner to correct
`
`the brief. See attached orders of Aug. 29, and Oct. 5, 2001.
`
`Case Dismissed
`On October 30, 2000, the District Court dismissed the case on Summary Judgement.
`
`Sturdza files Notice of Appeal and hires Mr. Lewin on contingency.
`
`Counsel Files Misleading Brief, The Court Ignores the Mischief
`
`Sturdza has filed pro se several motions and affidavits asking permission to correct the brief
`after her counsel failed to do so. The court denied all motions stating that she could not file
`
`pro se as long as she was represented by a lawyer, and completely disregarded her
`
`complaints about the misleading conduct of her counsel. See pro se pleadings by Petitioner
`
`Sturdza on file and the August 29, and October 5, 2001 orders. The brief must be rewritten
`
`because it conveys a totally false view of the case.
`Fourteen years ago Plaintiff-Appellant Sturdza has requested her counsel to discuss
`and correct the Brief he was just about to file on her behalf.
`
`For one year she continuously requested a dialog with him and, due to the total lack of
`response from her counsel, after that year, she asked this court for permission to correct the
`
`

`

`record by herself When the court responded that a party represented by counsel speaks
`through counsel to the Court, Plaintiff Sturdza decided to dismiss Mr. Lewin if he did not
`
`respond to her requests for correction of the brief by a deadline. Instead of correcting the
`record, or explain his reasons, Mr. Lewin reacted by filing a Motion for Appointment of
`Guardian Ad Litem. Plaintiff-Appellant Sturdza was left with no choice but enter in all courts
`
`Mr. Lewin's dismissal and enter pro se representation in order to correct the record herself,
`
`but, immediately after that she learned that instead of giving her the permission to correct
`
`the record in her rightful pro se capacity, the court has remanded the "instant case"
`
`concerning the guardian to the District Court. Her two motions of reconsideration of that
`
`June 6, 2002 Order were denied.
`
`As a result of the refusal to correct the record, one Discrimination Count was
`
`abandoned by Mr. Lewin, a second Discrimination Count was affirmed, all other counts were
`reversed but, Sturdza warned, when a Question on DC Architect License misstating the facts
`
`about Sturdza's status proposed by Mr. Lewin and certified to the DC Court of Appeals will be
`
`ruled upon, the Contract Count and five other counts he said all depend on it, will be
`
`dismissed despite the fact that Sturdza did meet all the Federal and DC licensing
`
`requirements. In the end, the only reversed count will be the Copyright Infringement.
`
`LATEST FACTS
`Plaintiff Sturdza dismisses her lawyers.
`On May 23, 2002 Sturdza fired Lewin, on June 112002, she has filed the dismissal of her
`
`lawyers Nathan Lewin, Alyza Lewin, of Lewin & Lewin and David Shapiro of Mintz, Levin,
`
`Cohn, Ferris, Glovsky & Popeo, PC, and has entered Pro Se representation in all Courts.
`
`Lewin Refuses to Be Fired and Requests Guardian
`On May 28, 2002 Mr. Lewin filed a Motion forAppointment of Guardian Ad Litem containing
`only false allegations.
`
`7
`
`

`

`IN CASE No: 98-cv-02051 (HHK)
`IN THE "INSTANT CASE", APPOINTMENT OF GUARDIAN
`Pro se Plaintiff Sturdza requests again a New Trial.
`Within ten days from dismissal of her counsels rather than from the date of the court order or
`
`opinion as required by F.R.C.P. 59 (a) (b) (e), Plaintiff Sturdza is requesting again a new trial.
`
`Newly discovered evidence contributed to the decision to act.
`The previous Motion for New Trial awaited long for the Court's decision
`Sturdza asked her former lawyers to file for the reconsideration of the October 30, 2000
`
`Opinion but they refused to do it. She filed within one year of the opinion, on October 30
`
`2001, a Motion for relief from Judgment and for a New Trial, but the court did not issue a
`
`decision for more than seven month.
`Petition for a Writ of Certiorari Filed: US Supreme Court No. 02-5218
`Because her Petition for Reconsideration of the June 6, 2002 Order and for RehearingEn Banc
`was denied, in 2002 Sturdza filed a Petition for a Writ of Certiorari, but her Application to
`Proceed in Forma Pauperis and her Motion for Reconsideration were denied.
`District Court held Status Hearing
`At the July 10, 2002 Hearing the discussion was about how to proceed with Lewin's Motion
`
`for Appointment of Guardian Ad Litem.
`Magistrate Judge Facciola Recommends No Guardian.
`On August 6 the District Court referred Lewin's Motion to Magistrate Judge Facciola,
`who, after the October 9, 2002 hearing, in his Report and Recommendations concluded that
`Plaintiff Sturdza is capable of representing herself and a guardian should not be
`appointed.
`The Court declined to adopt Magistrate Judge Facciola's Report
`On April 24, 2003, the District Court ordered a Show Cause Hearing and declined to adopt
`Magistrate Judge Facciola's Report and Recommendations.
`
`8
`
`

`

`Psychiatric Evaluation for No Good Reason, Not Ordered, Not Performed
`
`On August 26, 2003 the District Court intended to order, without any good reason, a
`Psychiatric evaluation, and ordered Lewin and Sturdza to submit two names of licensed
`
`Psychiatrists and on September 11, 2003 Lewin submitted two names. Sturdza was not
`
`notified of the June 4 and 23 Hearings. On September 12, 2003, she filed a statement about
`
`that fact. The Psychiatric Evaluation was not ordered and not performed
`No Activity for two Years
`Lewin's Motion Granted
`On September 28, 2005 the District Court entered an Order granting Lewin's Motion for
`Appointment of Guardian Ad Litem almost literally repeating Lewin's false allegations.
`
`Sturdza's and Demetriou's Motions for Reconsiderations were denied.
`Guardian IllegallyAppointed
`On March 26, 2006, the District Court appointed Martin Baach as Guardian ad Litem.
`Notices of Appeal Filed, Appeals Consolidated
`
`Timely Notices of Appeal were filed by Sturdza and by Demetriou.
`Case No: 06 - 7061 is consolidated with Case No: 06 - 7069 and Case No: 00 - 7279,
`the Appeal from the original District Court Case No: 98-cv-02051 (HHK).
`Lewin Amends Rule of Professional Conduct
`In his May 25, 2009 letter to the Legal Times, Mr. Lewin wrote:
`
`Letters to the editor, May 25, 2009
`LAWYER-CLIENT DISPUTE
`.The current version of District of Columbia Rule of Professional Conduct 1.14
`- which took effect on Feb. 1, 2007, and appears to have been drafted as a
`result of the unprecedented situation presented by my dilemma in Sturdza
`- precisely covers the Sturdza case and authorizes a lawyer to seek "the
`appointment of a surrogate decision-maker" in order "to protect the client's
`interests."...
`Nathan Lewin, Washington
`
`

`

`Mr. Lewin succeeded in creating a Rule and in using it to bypass a Law under which a
`
`Guardian can be appointed.
`
`Rule Not Retroactive, Orders Appointing Guardian Vacated
`The September 28, 2005 Order granting Lewin's Motion for Appointment of Guardian Ad
`Litem and the March 26, 2006 Order appointing a Guardian were vacated, Case remanded
`
`for Evidentiary Hearing.
`
`Evidentiary Hearing
`
`On May 13, 2009 an Evidentiary Hearing was held in the District Court. Sturdza
`
`demonstrated that the appointment of a guardian in her case would be illegal by providing
`
`proofs that her corrections of her Court Record are meritorious and all of Lewin's allegations
`
`are false and are lacking any proof. Lewin could not describe any specific acts or words by
`
`Sturdza that could be considered as proofs of incompetence.
`Guardian Illegally Reappointed
`On May 27, 2009 the District Court entered a new Order granting Lewin's Motion for
`Appointment of Guardian ad Litem and on July 23, 2009, a new Order appointing a Guardian.
`The District Judge reentered the two Orders previously vacated without any new proof. In
`his Memorandum the Judge repeats again, almost word by word Lewin's false allegations,
`
`again with no proof. Just like Mr. Lewin, the Judge could not name any specific thing
`
`committed by Sturdza that would show incompetency.
`
`The reappointment of the Guardian is as Illegal as the first appointment was.
`Notices of Appeal filed
`Timely Notices of Appeal were filed by Sturdza and by Demetriou. On August 17, 2009
`Sturdza filed the Notice ofAppeal from the Orders appointing a Guardian.
`Case returned in the Court of Appeals in Case No: 06 - 7061 consolidated with
`Case No: 06 - 7069 and Case No: 00— 7279.
`
`10
`
`

`

`Request to File Reply Brief Denied, No Hearing, Summary Affirmance.
`Sturdza filed Motions for permission to file Appellant's Reply Brief several years ago, and filed
`
`again after the Judgment was entered, but all her motions were denied. Without Appellant's
`Reply Brief and without a Hearing, on December 17, 2009 this Court entered an Order
`Summarily Affirming the District Court's Orders appointing a Guardian but failed to mail it
`
`to Sturdza.
`Leave to file Petition for Rehearing, Timely Request for Rehearing Denied.
`Sturdza learned about the Summary Affirmance Order more than one month later, several
`
`days after the time to file Petition has passed. All her motions for Leave to file Petition were
`
`denied. The last Order denying timely request for Rehearing was entered on June 17,
`
`2010.
`
`Petition for a Writ of Certiorari Filed: 10M63
`On September 16, 2010, in the morning, only a few hours late, Sturdza filed the Petition.
`The Clerk returned the Petition, but Sturdza refilled it with a Motion for leave to file Petition
`Out of Time explaining that due to a technical problem, the printer rejected the last new ink
`
`cartridge while all stores were closed, and no one was available to help over night. Motion
`was denied. See Petition for a Writ of Certiorari dated September 15, 2010 retained by
`the Supreme Court with the denied Motion 10M63.
`District Court Denies Outstanding Pleadings
`On March 29, 2010 the Distri