In The
`SUPREME COURT OF THE UNITED ST
`PALANI KARUPAIYAN; P, P.; R. P.
`--Petitioners
`!v.
`WOODBRIDGE TOWNSHIP OF NJ;
`STATE OF NEW JERSEY;
`UNITED STATES;
`UNION OF INDIA;
`OFFICER GANDHI, 5038 individually and in his official capacity as Parking
`*
`enforcement officer of WoodBridge;
`£
`POLICE DEPARTMENT OF WOODBRIDGE
`h *•
`OmPetition for a Writ of Certiorari
`■ ''h ■'
`to the United States Court of Appeals
`for the Third Circuit
`
`,‘J/*
`
`FILED
`may o 5 ?m
`jyPRE^cojfnT1-^^
`
`- Respondents
`
`PETITION FOR A WRIT OF CERTIORARI
`
`Palani Karupaiyan.
`Pro se, Petitioner,
`1326 W William St,
`Philadelphia, PA 19132
`212-470-20481M)
`
`

`

`ii)
`
`I. Questions Presented
`Petitioner’s prayed reliefs were
`National importance of having the US Supreme
`i)
`Court decide or conflict with USSC ruling, or
`importance of similarly situated over millions of
`citizens or the first impression is raised at
`USSC.
`Petitioners’ property rights under 42 U.S.C §
`1982 and Hindu Successive Act were denied
`when USSC ruled in
`Sullivan v. Little Hunting Park. Inc.. 396 US
`229 - Supreme Court 1969 @237
`“Section 1982 [42 U.S.C § 1982/ covers the right
`"to inherit, purchase, lease, sell. hold, and
`convey real and personal property."
`Local Govts/Foreign Govt violating, Parents
`rights (14th amendment) which were ruled by
`USSC under Troxel v. Granville. 530 U.S. 57
`(2000) and Washington v. Glucksberg, 521 U. S.
`702, 720.
`Local Govts illegally taken away Petitioners
`property without Jury trial.
`Local Govts illegally issued arrest warrant
`without Jury trial.
`Petitioner’s prayed over 10 reliefs were as Writ of
`Mandamus or Prohibition or alternative so the questions
`, were part of three test condition requirement of the Writs.
`
`iii)
`
`iv)
`
`v)
`
`i
`
`

`

`II. Parties to the Proceeding
`i)
`PALANI KARUPAIYAN; P. P.; R. P., are
`petitioners
`ii) WOODBRIDGE TOWNSHIP OF NJ; STATE
`OF NEW JERSEY; UNITED STATES; UNION
`OF INDIA; OFFICER GANDHI, 5038
`individually and in his official capacity as
`Parking enforcement officer of Woodbridge;
`POLICE DEPARTMENT OF WOODBRIDGE
`are respondents.
`
`u
`
`

`

`in
`
`in
`vi
`
`1 11 2
`
`4
`4
`
`III. Table of Contents
`
`I. Questions Presented................................................
`II.
`Parties to the Proceeding....................................
`III. Table of Contents..................................................
`IV. Table of Authorities..............................................
`V.
`Petition for a Writ of Certiorari.........................
`VI. Opinion(s)/orders/Judgment(s) BELOW (from
`Dist Court and USCA3)..................................................
`VII. Jurisdiction............................................................
`VIII. Constitutional and Statutory Provisions
`Involved..............................................................................
`IX.
`Statement of the Case
`a) Dist Court Proceeding..................................
`
`b) Core facts of the Complaint.........................
`c)
`Dist Court analyze and ruling.......................
`
`4
`12
`IB
`USCA proceeding..........................................
`d)
`13
`All Writs Act, 28 U.S.C. § 1651(a)
`X.
`13
`XI. Petitioner’s Parenting rights........
`XII. Petitioner prayed declarative/injunctive reliefs in
`13
`the lower court by following..................................
`XIII. Why USCA3 was not able to grant the
`15
`Appellant’s Writs/Injunction(s) reliefs...............
`XIV. USSC’s Writ against USCA/Dist Court or any
`Court 15
`e) Against Any Judicial authority (Including NJ authority).........
`XV. USSC’s Rule 20.1 and Rule 20.3.........................
`XVI.
`Three test Conditions for grant the Writs (of
`Mandamus, prohibition or any alternative).................
`XVII. Pro se pleading standards................................
`
`16
`16
`
`17
`18
`
`m
`
`

`

`18
`XVIII. Reasons for Grating the Writs
`18
`a)
`Parental rights against US and NJ...................
`1) Writ against United States and New Jersey that make amendment
`18
`to the Constitution that Parental rights are Constitutional rights..........
`2)
`(i)US govt/President should not appoint the US Supreme Court
`justices and (ii) Thru Collegium process Promote 34 most
`experience/expertise USCA Judge to US Supreme Court for 5 years, and
`they should retire at 70 whichever comes 1st. (iii) invalidate the
`Judge/Justice Brown appointment to US Supreme Court.......................
`
`19
`
`b) Against INDIA for parental and inheritance /property rights .24
`3) Order to Union of India that US citizen kids should not be hold in
`India, and US citizen Kids need to return to US for their education,
`vacations, and holidays, parental rights and properly kids Ancestral
`inheritance property(s)/wealth need to transfer to the kids in USA...... 24
`
`c)
`
`26
`
`Against lower courts
`25
`4) Order to vacate the sua sponte order of dismissal the complaint. 25
`5) Order to appoint guardian ad litem or alternatively pro boho
`attorney....................................................................................................
`6) Order that Lower Court should exercise supplemental jurisdiction
`for state-law claims.............................. ...................................................
`30
`7)
`(i)Moving New Jersey Municipal Judges into New Jersey payroll and
`(ii) NJ Municipal Mayor should not appoint Municipal Court Judge(s) and
`such appointment should be done by NJ State govt, and (iii) Deposit
`traffic violations fine in New Jersey treasury, (iv) Remove the Petitioners
`traffic ticket to US District Court (v) By parties request Jury should be
`available for traffic ticket hearing/municipal hearing..............................
`8)
`NJ and it's local Govt should not tow/taken away the home less's
`property(s)................................................................................................
`
`30
`
`32
`
`d) Writs against Woodbridge..............................................................
`33
`9) Order the respondent Woodbridge Township should pay 295/day
`for TAKEN AAWAY Porsche cayenne to the plaintiff
`33
`
`e) Additional prayers
`
`36
`
`IV
`
`

`

`10) Order the each defendant to pay $15 million for the Petitioners'
`effort, pain and suffering, expenses, litigation cost or pain and suffering
`by litigation
`36
`XIX.
`Conclusion
`38
`
`v
`
`

`

`IV. Table of Authorities
`Cases
`
`27
`
`27
`
`14
`14
`
`ANKENBRANDT, as next friend and mother of L. R., et al. v.
`RICHARDS et al 504 U.S. 689 (1992)................................................
`Antoine v. Byers&Anderson, Inc.. 508 U.S. 429, 433 n. 5,113 S.Ct. 2167,124
`L.Ed.2d 391(1993).......................................................................................
`Azubuko v. Royal, 443 F. 3d 302 - USCA, 3rd Cir 2006.....................................
`Babb v. SECRETARY. DEPT. OF VETERANS AFFAIRS. 992 F. 3d 1193 - Court of
`Appeals, 11th Circuit 2021..................................................
`20, 22
`Babb v. Wilkie, 140 S. Ct. 1168 - Supreme Court 2020
`20, 22
`Bankers Life & Casualty Co. v. Holland. 346 US 379 - Supreme Court 1953.15,17
`Bayron v. Trudeau. 702 F.2d43, 45 (2d Cir.1983);............................................
`25
`Bethel School District No. 403 Et Al. V. Fraser, A Minor, et al. 478
`U.S. 675 (1986)..........................................................................................
`Bivens v. Six Unknown Named Agents of Fed. Bur. ofNarc.. 456 F. 2d 1339 -
`Court of Appeals, 2nd Circuit 1972...............................................................
`26
`Board Of Education Of The Westside Community Schools (Dist. 66) et
`al. V. Mergens, By And Through Her Next Friend, Mergens, Et. 496
`U.S. 226(1990),.......................................................................................
`27
`Bolin v. Story. 225 F. 3d 1234 - USCA. llthCir2000......................................
`13
`Bolin v. Storv. 225 F.3d 1234,1242 {11th Cir.2000)........................................
`14
`Bontkowski v. Smith, 305 F. 3d 757 - USCA, 7th Cir. 2002..............
`14
`Bontkowskiv. Smith. 305 F.3d 757, 762 (7th Cir. 2002)..................................
`15
`Bovadiian v. Cigna Companies. 973 F. Supp. 500 - Dist. Court, D. New Jersey
`1997
`37
`Bover v. CLEARFIELD COUNTY INDU. DEVEL. AUTHORITY. Dist. Court, WD Penn
`2021
`14
`Cheney v. United States Dist. Court for DC. 542 US 367 - Supreme Court 2004.17
`GLG v. Barr, 923 F. 3d 622 - Court of Appeals, 9th Circuit 2019.................
`29
`Crooker v. United States Dep't of Justice, 632 F.2d 916, 921 (1st Cir.1980))
`37
`Cunningham. 664 F.2d at 387 n. 4...............................................................
`37
`De Beers Consolidated Minesv. United States. 325 U. S. 212, 217 (1945)..
`16
`De Beers Consolidated Minesv. United States. 325 U. S. 212, 217 (1945)....
`17
`
`VI
`
`

`

`DeBold, 735 at 1043...........................................................................
`37
`18
`Erickson v. Pordus, 551 US 89 - Supreme Court 2007.......................
`18
`Estelle. 429 U.S.. at 106.97S.Ct. 285...............................................
`16
`Ex parte Peru, 318 U.S. 578, 585, 63 S.Ct. 793, 87 LEd. 1014 (1943)
`Fries v. Barnes, 618 F.2d 988, 989 (2d Cir.1980................................
`25
`15,16
`Hines v. D'Artois. 531 F. 2d 726, 732, and n. 10 (CA51976).............
`Hobby Lobby Stores. Inc, v. Sebelius. 568 US 1401 - Supreme Court 2012 .... 1,17
`27
`Hodge v. Police Officers. 802 F. 2d 58 - Court of Appeals, 2nd Circuit 1986
`1
`Hohn v. United States. 524 US 236 - Supreme Court 1998
`Holt Civic Club v. City of Tuscaloosa, 439 U.S. 60, 65-66, 99 S.Ct. 383,
`14
`58 L.Ed.2d 292 (1978)..............................................................................
`29
`In re Gault. 387 U.S. 1, 36-37, 87S.Ct. 1428,18 *632 LEd.2d 527 (1967).......
`Jacob WINKELMAN. a minor, bv and through his parents and legal guardians.
`Jeff and Sendee WINKELMAN. etai.. y. PARMA CITY SCHOOL DISTRICT. 550
`U.S. 516-127 S.Ct. 1994 (2007)
`27
`Lassiter v. Dep't of Social Servs. of Durham Ctv.. 452 U.S. 18, 27,101 S.Ct.2153,
`29
`68 L.Ed.2d 640 (1981)..................................................................
`Maclin v. Freake, 650 F. 2d 885 - Court of Appeals, 7th Circuit 1981
`27
`29
`Mathews, 424 U.S...................................................................
`Montgomery v. Pinchak, 294 F. 3d 492 - USCA, 3rd Cir. 2002
`26
`Moses H. Cone Memorial Hospital v. Mercury Constr. Coro.. 460 US 1 - Supreme
`15,16
`Court 1983
`MulHs v. United States Bankr. Court for the Dist. ofNev., 828 F.2d 1385 (9th
`14
`Cir.1987)......................................................................................................
`14
`Newman v. Alabama. 683 F.2d 1312 (11th Cir.1982).....................................
`Osei-Afriye v. The Medical College of Pennsylvania, 937 F.2d 876 (3d Cir. 1991)
`................................................................................................................ 26, 28
`Pa. Bureau of Correction v. US Marshals Service. 474 US 34 - Sup Ct 1985......13
`16
`re US. 139 S.Ct. 452
`19
`Reno y. Flores. 507 U. S. 292, 301-302 (1993)........................................
`29
`Robidoux v. Rosenaren. 638 F. 3d 1177-USCA9 2011...........................
`15
`Roche v. Evaporated Milk Assn.. 319 U. S. 21, 26 (1943)........................
`1
`Rosado y. Wyman. 397 U. S. 397, 403, n. 3 (1970).................................
`Salahuddin v. Cuomo. 861 F. 2d 40 - Court of Appeals, 2nd Circuit 1988
`25
`i, 25
`Sullivan v. Little Hunting Park. Inc.. 396 US 229 - Supreme Court 1969...
`Tabron v. Grace. 6 F. 3d 147 - Court of Appeals, 3rd Circuit 1993..........
`26
`
`Vll
`
`

`

`Troxel v. Granville. 530 U.S. 57 (2000)..............
`Troxel v. Granville. 530 U.S. 57 (U.S. 2000J.......
`Washington v. Glucksbera. 521 U. S. 702, 720..
`Washington v. Glucksbera. 521 U.S. 702 (1997)
`
`Statutes
`
`28 U. S. C. § 1254(1)........
`28 U. S. C. § 1651............
`28 U.S.C. § 1651(a)..........
`28 U.S.C. § 1654..............
`28 USC § 1915(e)(2)(B)(ii)
`28 USC5 1651(a)..............
`42 U.S.C §1982
`42 U.S.C. § 1983
`All Writs Act.....
`Foreign Sovereign Immunities Act ("FSIA")...............................
`The Supreme Court (Number of Judges) Amendment Bill, 2019)
`
`Rules
`
`Rule 12(b)(6)
`Rule 17(c)....
`Rule 8(a)(3)....
`S.Ct. Rule 20.1
`S.Ct. Rule 20.3
`Constitutional Provisions
`
`11th amendment......
`14th amendment......
`lsl amendment.........
`due process..............
`Fifth Amendment.....
`FIRST AMENDMENT.
`
`i, 13
`19, 28
`i, 13
`18, 28
`
`2
`1,15
`13
`26
`3
`17
`i, 25
`14
`1, 13
`25
`22
`
`15
`29
`14
`16
`16
`
`25
`28
`10, 32
`32
`10,19
`27
`
`V1U
`
`

`

`V. Petition for a Writ of Certiorari
`Petitioner respectfully prays that a Writ of Certiorari issue
`to review the opinion/judgment/orders of USCA3’s (docket 22-
`2949) and US Dist Court for New Jersey- Newark div (Dist
`docket 21-cv-19737) below.
`VI. Opinion(s)/orders/Judgment(s) BELOW (from Dist Court
`AND USC A3)
`1. USCA3’ Opinion date Feb 23, 2023 (App.la)
`Hon. KRAUSE. PORTER, and AMBRO, USCA3’s Circuit
`Judges
`2. USCA3’ Judgment date Feb 23, 2023 (App.4a)
`3. Dist Court order Aug 19 2022. Ecf-22 (App.6a)
`4. USCA3’s Order to Attorney Representation for Minor
`(App.lla)
`5. USCA3’s order that forma pauperis granted and denied to
`appoint attorney (App.l3a)
`6. US Dist Court’s Letter order (Sua sponte) dismiss the
`Complaint (App.l5a)
`7. US Dist Court’s Injunctive reliefs denied. (App.23a)
`Hon. Esther Salas USDJ; Hon. Jessica S. Allen USMJ
`VII. Jurisdiction
`In Hohn v. United States. 524 US 236 - Supreme Court
`1998@ 258 (“Rosado v. Wyman, 397 U. S. 397, 403, n. 3 (1970)
`(a court always has jurisdiction to determine its jurisdiction)).
`Hohn @264 (“We can issue a common-law writ of
`certiorari under the All Writs Act. 28 U. S. C. § 1651.)
`Hobby Lobby Stores, Inc, v. Sebelius, 568 US 1401 - Supreme
`Court 2012% 643
`The only source of authority for this Court to issue an
`injunction is the All Writs Act, 28 U.S.C. § 1651(a) and
`Following a final judgment, they [Petitioner] may, if
`necessary, file a petition for a writ of certiorari in this
`Court.
`
`1
`
`

`

`On Feb 23 2023, United States Court of Appeals for 3rd
`Cir entered opinion and Judgment. App-la to App-4a
`The jurisdiction of this Court is invoked under 28 U. S.
`C. § 1254(1).
`VIII. Constitutional and
`Statutory Provisions Involved
`Fed.R.Civ.P. 8(a)(2) and (3)
`Fed.R.Civ.P. 12(b)
`Fed.R.Civ.P. 17
`Fed.R.Civ.P. 54(c)
`
`1st Amendment
`
`Article VI. Paragraph 2 of the U.S. Constitution (Supremacy
`Clause)
`42 US Code § 1983 - Civil action for deprivation of rights
`42 US Code § 1982 - Property rights of citizens
`42 US Code § 1988 - Proceedings in vindication of civil rights
`
`Hindu Marriage Act, 1955 and its Amended
`Hindu Succession Act, 1956 and its Amended
`
`Comparative Approaches of Supreme Courts of the World's
`Largest and Oldest Democracies
`-By Justice Hon. Stephen Breyer of US Supreme Court, Chief
`Justice Hon. NV Ramana of Supreme Court of India, and
`William M Treanor, Dean of Georgetown University Law
`Centre Dated: April 11, 2022
`
`The New Jersey Law Against Discrimination (NJLAD)
`.. and more
`
`Article II and III
`5th amendment
`11th amendment - New Jersey State’s sovereign immunity.
`2
`
`

`

`14th amendment- Glucksberg, 521 U.S. 702 (1997)) (Parental
`rights)
`Troxel v. Granville, 530 U.S. 57 (U.S. 2000).” (Parental rights)
`Foreign Sovereign Immunities Act, 28 U.S.C. §§ 1605-1607
`28 USC § 1915(e)(2)(B)(ii) (forma pauperis)
`Civil Rights Act of 1866
`42 U.S.C. § 1981 & 1982
`
`3
`
`

`

`IX. Statement of the Case
`a) Dist Court Proceeding
`Plaintiff filed complaint with US Dist Court of New
`Jersey-Newark and timely served the complaint to all
`captioned defendants.
`On Dec 09 2021 Dist Court dismissed the complaint by
`Sua Sponte when no defendants appeared. App.l5a
`On Jan 13 2022, Dist Court denied the plaintiff
`injunctive relieve motion. App.23a
`Dist Court entered the final order of dismissal on Aug 19
`2022. App.06a.
`Plaintiff filed notice of appeal for final order. App.6a
`b) CORE FACTS OF THE COMPLAINT
`a) Plaintiffs9 facts
`Pro se plaintiff Palani Karupaiyan (“Plaintiff’) initiated
`the instant action against defendants Woodbridge Township of
`NJ, the State of New Jersey, the United States, the “Union of
`India,” Officer Gandhi, and the Police Department of
`Woodbridge
`Plaintiff Palani Karupaiyan (“Palani”) is 50 yrs old
`Naturalized US citizen from India. Home evicted and
`homeless. Palani is Tamil speaking ethnicity, black color.
`Before filing complaint I talked to Woodbridge that I or
`car did not violated any traffic rule, my home is evicted, the car
`is my sleeping, living, laptop charging place, why did you tow
`the car.
`
`b) Following facts against Woodbridge
`Township
`
`4
`
`

`

`26. On Sep 24 2021, My living place was standing at Silzer ave,
`Iselin NJ.
`27. Both keys of the Porsche is[are] with plaintiff.
`28. Silzer ave is dead-end no-traffic, about 10 houses both
`sides. General resident with parking sticker park both side.
`29. No cleaning, or maintenance were done to the silzer ave.
`there are few potholes.
`30. At Parking violation signs were hidden in short live dense
`tree.
`31. Only walk close to the parking sign, anyone see the parking
`hours,
`32. When I walked close and looked at the parking violation
`sign said that weekdays 12am to 1pm is no parking for non­
`resident,
`33. One of the indian living in the street, that he is happy to
`see Porsche stopped on their street.
`34. None of the street resident is disturbed or they complaint to
`Woodbridge that they were disturbed by my living place.
`Traffic also not disturbed; it is deadend street.
`35.1 placed two big visible notice on the car windshield and
`driver window.
`36. Notice on the car had “Tow service is coming, Palani 212-
`470-2048”
`37.1 called local towing he said that fee is $45 for in-town and
`should come by 4pm
`38. On Sep 23 2021 by 2:30pm I was called my friend and said
`that a towing vehicle accompanied by black unmarked black
`car towing the Porsche.
`39. When my friend said the our towing is coming pick and
`leave the car, the woodbridge towing guys waved his hand and
`said I love you to him.
`40. The Woodbridge did not put the car in to neutral, uplift
`only two wheels dragged the car.
`
`5
`
`

`

`41. My friend said that the way Woodbridge dragged, two tires
`were scratching the road and tire marks were visible.
`42. Sep 23 2021, on or around 3:20pm, Gandhi drive thru to
`Silzer ave, told me “you black madrasi register your car and
`park here. I wanted to charge parking violation. It is my living.
`Otherwise kill you goback to madras”
`43. When Sep 24 20211 called Woodbridge police to confirm
`who towed the car, they wanted me to say the vin number. I
`never come to know anyone remember the vin number. I told
`them I will find out the vin and call them back,
`44. At the time of buying car, I wrote the vin my nail which
`was not able to withstand for 5+yrs
`45.1 tried to reach home in India for any document have
`Porsche vin and got from them.
`46. Oct 29 20211 saw a google voice mail at 212-470-2048
`saying that I have hearing on Oct 25 2021.
`47. When I called the woodbridge, asked about what hearing,
`they said about unregistered car, and they send summon to 606
`Cinder rd, Edison NJ 08820. (already evicted more than year
`ago).
`48. Township told that I need to pay $55 fine for unregistered
`car.
`49.1 told township, I or car did not violated any traffic rule. My
`home is evicted, the car is my sleeping, living, laptop charging
`place, why did you tow the car.
`50. After Conversation Township took my phone number again
`and said they should get back to me.
`51.1 called Woodbridge PD, my home is evicted, the car is my
`home, sleeping place, I or the car did not violated any traffic
`violation. Woodbridge PD said they do not believe and refused
`to return my car.
`52.1 was told by Woodbridge PD that I need to Mvc to register
`
`6
`
`

`

`39:3-4
`
`39:6B-2
`
`53. Woodbridge PD should release the car when I comeback
`with Car Registration and pay $1445
`54. When I asked do I need to pay $1445 the Woodbridge
`Township, Police said no, pay to the police and they need to
`share with towing guy.
`55.1 asked the PD to provide me itemized bill for $1445 which
`was denied.
`56. Police confirmed the car is parked on the yard.
`57. When say the web docket, following charges are against me
`DRIVING OR PARKING
`UNREGISTERED
`MOTOR VEHICLE
`NO LIABILITY
`INSURANCE
`COVERAGE ON
`MOTOR VEHICLE
`WILLFULLY
`ABANDONING MOTOR
`VEHICLE
`FAILURE TO HAVE
`39:8-1
`INSPECTION
`Petitioner’s car is Petitioner’s living place, I do not need to
`have above state’s requirement. Township did not need to
`search above for a parked car.
`c) Against traffic/Parking enforcement officer.
`42. Sep 23 2021, on or around 3:20pm, Gandhi drive thru to
`Silzer ave, told me “you black madrasi register your car and
`park here. I wanted to charge parking violation. It is my living.
`Otherwise kill you goback to madras”
`60. 20 foot away where my car was stopped at Silzer ave by
`white women, in Aug 2021, more than 2 weeks a car was
`parked with sticker saying that towing service requested with
`her phone number. This women is not homeless.
`
`39:4-56.1(B)
`
`7
`
`

`

`d) Allegation against United States and India.
`63.1 (Palani Karupaiyan) requested Dept of States of US for
`deny the passport of kids to go to India because of they should
`be injured in India.
`64. Dep of State said Because of NJ state Court order the kids
`go India, US will not be able to stop the kids going to India.
`65. After visiting India, the Kids come back to US with
`injuries.
`66. When I see the kids injured, I cried and did not sleep few
`days.
`67. The kids said the injuries were continuously paining.
`68.1 was not allowed to take care of the medical attention of
`kids injuries
`69. No others did not take care of the medical attention or need
`of kids for their injuries.
`
`72. Relief 0- Plaintiff pray a declarative order and/or
`permanent injunction against US that make amendment to the
`Constitution that Parental rights are Constitutional rights
`115. Relief (). Plaintiff pray declarative order or permanent
`injunction against Union of India that 1) US citizen kids
`should not be hold in India, and Kids need to return to US for
`their education, summer vacations and 2) properly kids
`inheritance property/wealth need to transfer to the kids in
`USA.
`
`e) Allegations against New Jersey - MVC
`
`84.1 requested NJ Motor Vehicle Commission (“MVC”) to
`provide me duplicate title Of Porsche cayenne so I can register
`my car on some other state which was denied by NJ Mvc.
`
`8
`
`

`

`85. On or around Aug 2021 (approx) at Edison, Sugartree
`plaza, I requested the NJ
`Mvc mobile service to provide me registration to Porsche which
`was denied.
`86.1 was told by NJ Mvc’s mobile service that Stop order is
`placed on this Porsche cayenne registration.
`f) Complaint with NJ attorney general office (NJAG)
`87. On Oct 29 2021, after talking to Woodbridge, I called NJ
`attorney general (NJAG) office to help about the illegal towing
`of the vehicle.
`88.1 told NJAG that my home evicted and Porsche car is my
`home, sleeping place.
`89. NJAG told that Woodbridge can tow the vehicle for
`unregistred and refused to help me.
`90. NJAG told that they do not have jurisdiction to resolve
`the issue. [NJ waived its 11th amendment immunity]
`91. NJAG told that always I should keep the unregistered car
`in my shoulder or park it in Walmart parking lot to sleep.
`92. NJag told that I should apply for housing assistant and
`should not sleep in the car.
`93. NJAG told that apply food stamp, pay the food stamp
`money to Woodbridge. Need to pay the municipal judges by
`money collected by municipal orders.
`g) NJ judicial authority
`NJ judicial authority denied plaintiff Palani
`94.
`Karupaiyan’s multiple request that children should not go to
`India because they should be injured.
`h) Allegations against NJ, US, India
`163. India, US, NJ failed to protect the kids from injury is
`violation in NJ personal injury act, the Fifth Amendment US
`Constitution
`
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`165. India, US, NJ failed to protect the kids from injury is
`violation in NJ Pain and suffering act, the Fifth Amendment
`US Constitution
`168. India, US, NJ failed to protect the kids from injury and
`cause the plaintiff father and kids suffer from sleep difficulties,
`untreated injuries is emotional distress violation in NJ Pain
`and suffering act, the Fifth Amendment US Constitution
`i) Against United States
`73. When the plaintiffs were injured in Little Rock, Arkansas, I
`filed petition and its reconsideration with US Supreme Court,
`docket# 10-9787 which was denied because not enough
`resource(Justices) available with US Supreme Court. Top most
`Court denying justice is because of resource is injustice,
`violation of 1st amendment Constitutional rights.
`74. After disposing ex-rays of broken ribcage, Dr Blankenship
`told me that I could go anywhere for justice.
`75. In the situation in accident, Little Rock, Arkansas, my rib
`cage is collapsed, untreatable injury, still today I have pain,
`and the injuries were not healed yet. So top most US Court
`denying justice to me because of resource is unacceptable
`injustice to civilized society.
`76. A dog cannot be kick, break its bone under law which is jail
`able crime but my bone broken, justice is denied because
`unavailability of resource with US Supreme Court.
`83. ReliefO for any all reason stated above plaintiff prays this
`Court declarative order or permanent injunction against US
`that i) US govt/President should not appoint the US Supreme
`Court justices and promote the Judges from United States
`Court of appeal by most experienced/expertise. Ii) Promote 34
`most experience/expertise USCA Judge to US Supreme Court
`
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`for 5 years, and they should retire at 70 whichever comes 1st.
`12. Plaintiff Roshna P (“RP”) is Plaintiff Palani Karupaiyan’s
`daughter.
`13. RP is born from Edison , NJ.
`k) Defendant Woodbridge’s facts
`14. Woodbridge is a township in Middlesex County, New
`Jersey, United States.
`15. Address of Woodbridge is 1 Main Street Woodbridge, NJ
`07095.
`
`16. Woodbridge’s email is john.mitch@twp.woodbridge.nj.us.
`j) Allegation against Officer Gandhi and Woodbridge
`
`17. Office Gandhi is parking enforcement officer of woodbridge
`township and his id is
`5038. Gandhi is Guajarati speaking north Indian ethnicity,
`white skin.
`18. New Jersey is a state in United States.
`153. Officer Gandhi called the plaintiff as black madrasi is
`Racial/color/ethnicity discrimination by woodbridge, Office
`Gandhi violation of
`NJ Law against Discrimination (LAD), 18 U.S.C. §§ 242 ,42
`U.S. Code § 1988
`(vindication of civil rights), 42 U.S.C. § 1983, Civil Rights Act
`of 1866, Title VI of
`the Civil Rights Act of 1964 and the "OJP Program Statute as
`set forth in
`paragraph 42, above.
`
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`c) Dist Court analyze and ruling
`Dist Court ruled that Plaintiff alleges various claims for relief
`that do not exist, such as “denial of justice” (Count 14),
`“unfair justice” (Count 17), and
`“excessive charging” (Count 18).
`Plaintiff does include some recognized legal theories for relief
`such as
`malicious prosecution (Count 1),
`unlawful discrimination (Count 2),
`Violation of the Americans with Disabilities Act (Count 5), and
`violation of due process (Count 16).
`
`Compl. 1 153 (152?) (alleging that by taking away Plaintiffs
`“living property,” Woodbridge and its police violated the
`Americans with Disabilities Act)
`Additionally failure to exercise the Supplemental
`jurisdiction over any state-law claims, (see. Footnote, Dec 9
`202 l’s order)
`First, the Foreign Sovereign Immunities Act (“FSIA”)
`“provides the sole basis for obtaining jurisdiction over a foreign
`state in federal Court.” Specifically, the FSIA provides that a
`“foreign state shall be immune from the jurisdiction” of both
`federal and state Courts except as provided by 28 U.S.C. §§
`1605-07. See 28 U.S.C. § 1604. Based on the facts as pled, it
`does not appear that any of the exceptions apply to permit suit
`against India
`Second, “[t]he United States, as sovereign, is immune
`from suit save as it consents to be sued, and the terms of its
`consent to be sued in any Court define that Court’s jurisdiction
`to entertain the suit
`The Court ruled that Karupaiyan’s claims against New
`Jersey, the United States and India are barred by immunity
`doctrines. The Court also ruled
`
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`that Karupaiyan’s allegations against the Woodbridge
`defendants were too conclusory to state a federal claim, and it
`declined to exercise supplemental jurisdiction over any state-
`law claims,
`He also filed several post-judgment motions, which the District
`Court construed in part as motions for reconsideration and
`denied. Karupaiyan has amended his notice of appeal to
`challenge that ruling as well.
`d) USCA PROCEEDING
`Appellant filed all the reconsideration motions and post
`judgement motions from Dist court with USCA 3rd circuit, 22-
`2949. Dkt-07
`USCA granted the forma pauperis to the appellant(s)
`and ordered the appellant(s) to file 5 pages brief in support
`appeal.
`On Feb 23, 2023, USCA3 affirmed the dist court order(s)
`and entered Judgment. App.la, App.4a.
`X. All Writs Act, 28 U.S.C. § 1651(a)
`In Pa. Bureau of Correction v. US Marshals Service. 474 US 34
`- Sup Ct 1985 @43
`The All Writs Act is a residual source of authority to issue writs
`that are not otherwise covered by statute.
`XI.
`Petitioner’s Parenting rights
`Petitioners’ Parenting Rights were in 14th Amendment of
`Constitution, Troxel v. Granville, 530 U.S. 57 (2000) and
`Washinston v. Glucksberg. 521 U. S. 702, 720.
`XII.
`Petitioner prayed declarative/injunctive reliefs in the
`lower court by following.
`In Bolin v. Story, 225 F. 3d 1234 - USCA, 11th Cir 2000
`@ 1243
`“_In order to receive declaratory or injunctive relief,
`plaintiffs must establish that there was a violation, that
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`there is a serious risk of continuing irreparable injury
`if the relief is not granted, and the absence of an
`adequate remedy at law” See Newman v. Alabama. 683
`F.2d 1312 (11th Cir.1982).
`In Azubuko v. Roval. 443 F. 3d 302 - USCA, 3rd Cir
`2006 @ 304
`Injunctive relief shall be granted when a declaratory
`decree was violated or declaratory relief was
`unavailable." 42 U.S.C. § 1983; Bolin v. Story. 225 F.3d 1234,
`1242 (11th Cir.2000) (explaining that the amendment applies
`to both state and federal Judges); see also Mullis v. United
`States Bankr. Court for the Dist. of Nev., 828 F.2d 1385 (9th
`Cir. 1987): Antoine v. Byers &Anderson. Inc.. 508 U.S. 429, 433
`n. 5, 113 S.Ct. 2167, 124 L.Ed.2d 391 (1993) (noting that the
`rules regarding judicial immunity do not distinguish between
`lawsuits brought against state officials and those brought
`against federal officials).
`In Bontkowski v. Smith. 305 F. 3d 757 - USCA, 7th Cir.
`2002®762 <ecan be interpreted as a request for the imposition of
`such a trust, a form of equitable relief and thus a cousin to an
`injunction. Rule 54(c), which provides that a prevailing party
`may obtain any relief to which he's entitled even if he "has not
`demanded such relief in [his] pleadingsSee Holt Civic Club v.
`City of Tuscaloosa. 439 U.S. 60, 65-66, 99 S.Ct. 383, 58 L.Ed.2d
`292 (1978);
`In Bover v. CLEARFIELD COUNTYINDU. DEVEL.
`A UTHORITY. Dist. Court, WD Penn 2021
`t(Thus a prayer for an accounting, like a request for
`injunctive relief, is not a cause of action or a claim upon
`which relief can be granted. Rather, it is a request for
`another form of equitable relief, i.e., a "demand for
`judgment for the relief the pleader seeks" under Rule 8(a)(3)
`of the Federal Rules of
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`Civil Procedure. D****As such, it too is not the proper
`subject of a Rule 12(b)(6) motion. D***Global Arena, LLC,
`2016 WL 7156396, at *2; see also Bontkowskiv. Smith. 305
`F.3d 757, 762 (7th Cir. 2002).
`Petitioners prays this court any and all benefit of above ruling.
`XIII. Why USCA3 was not able to grant the Appellant’s
`Writs/Injunction(s) reliefs
`In the USCA3, Appellants filed appeal and injective
`reliefs thru motion. As per the Moses footnote [6], USCA3 shall
`not able to grant the injunctive reliefs along with the appeal.
`In Moses H. Cone Memorial Hospital v. Mercury Constr.
`Cory.. 460 US 1 - Supreme Court 1983(^footnote[61.
`More fundamentally, a court of appeals has no
`occasion to engage in extraordinary review by
`mandamus "in aid of [its] jurisdictionfn],” 28 U. S.
`C. § 1651, when it can exercise the same review by a
`contemporaneous ordinary appeal. See, e. g., Hines v.
`D Artois. 531 F. 2d 726, 732, and n. 10 (CA5 1976).
`XIV. USSC’s Writ against USCA/Dist Court or any Court
`Bankers Life & Casualty Co. v. Holland. 346 US 379 -
`Supreme Court 1953@383
`As was pointed out in Roche v. Evaporated Milk Assn..
`319 U. S. 21, 26 (1943), the "traditional use of the
`writ in aid of appellate jurisdiction both at
`common law and in the federal courts has been to
`confine an inferior court to a lawful exercise of its
`
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