^ Ov')'
`
`2-6551
`29-'
`
`—FILED
`JAN 0 3 2023
`IN THE
`SUPREME COURT OF THE UNITED STATWMSmSM.
`
`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
`- Respondents
`
`PETITION FOR WRIT FOR CERTIORARI
`to the United States Court of Appeals
`for the Third Circuit, before judgment is entered in that
`Court
`
`Palani Karupaiyan.
`Pro se, Petitioner,
`c/o Pravin
`110 Caton Ave, #2M
`Brooklyn, NY 11218
`nalanikav@gmail.com
`212-470-2048(m)
`
`

`

`:
`
`ised -k,
`
`"x
`
`TV
`
`•r
`
`!
`
`

`

`I. QUESTIONS PRESENTED
`Petitioner’s reliefs were prayed as Writ of Mandamus or
`Prohibition or alternative so the questions were part of three test
`condition of the Writs.
`II. PARTIES TO THE PROCEEDING
`All parties appear in the caption of the case on the cover page.
`PALANI KARUPAIYAN; P. P.; R. P., are petitioners
`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.
`
`III. RELATED CASE(S)
`USSC’s docket# 22-6342, Petition for Writ of Certiorari- Palani
`Karupaivan et al v. L Nasanda et al is Parallel dockets
`
`1
`
`

`

`1
`
`1 1
`
`4 4 4
`
`1 1
`
`1
`11
`
`V
`VI
`
`IV. TABLE OF CONTENTS
`Contents
`L QUESTIONS PRESENTED.............
`II. PARTIES TO THE PROCEEDING
`III. RELATED CASE(S)
`IV. TABLE OF CONTENTS
`V. INDEX TO APPENDICES
`VI. TABLE OF AUTHORITIES
`
`VII. PETITION FOR WRIT OF CERTIORARI
`VIII. Opinion(s)/orders/Judgment(s) BELOW (from Dist Court and
`USCA3)................. ....................................................................................
`IX. JURISDICTION...............................................................................
`X. CONSTITUTIONAL AND STATUTORY PROVISIONS INVOLVED
`2
`XI. STATEMENT OF THE CASE....................................................
`1) Dist Court Proceeding ..................................................................................
`2) Core facts of the Complaint........................................................................
`3) Dist Court analyze and ruling....................................................................
`4) USCA PROCEEDING............................................................................................
`XII. All Writs Act, 28 U.S.C. § 1651(a)........................................
`XIII. Petitioner’s Parenting rights.............................................
`XIV. Petitioner prayed declarative/injunctive reliefs in the
`LOWER COURT BY FOLLOWING..............................................................................
`XV. Why US CA3 Will not able to grant the Appellant’s
`Writs/Injunction(s) reliefs............ :..............................................
`XVI. USSC’s Writ against USCA/Dist Court or any Court......
`
`12
`14
`14
`14
`
`15
`
`16
`16
`
`11
`
`

`

`a) Against Any Judicial authority (Including NJ authority)
`16
`XVII. USSC’s Rule 20.1 and Rule 20.3. ..........................
`17
`XVIII. Three test Conditions for grant the Writs (of Mandamus,
`PROHIBITION OR ANY ALTERNATIVE) ...........................
`17
`XIX. Pro se pleading standards.....................
`18
`XX. REASONS FOR GRANTING THE WRIT
`18
`a) Parental rights against US and NJ..................................................................
`18
`1) Writ against United States and New Jersey that make amendment to the
`18
`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
`20
`b) Against INDIA for parental and inheritance /property rights.............
`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
`24
`property(s)/wealth need to transfer to the kids in USA......................................
`26
`C) AGAINST LOWER COURTS...........................................................................................................
`26
`4) Order to vacate the sua sponte order of dismissal the complaint...............
`5) Order to appoint guardian ad litem or alternatively pro bono attorney..... 27
`6) Order that Lower Court should exercise supplemental jurisdiction for state-
`30
`law claims
`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)............................................ ..........................................................
`D) WRITS AGAINST WOODBRIDGE.............................................................................
`
`24
`
`31
`
`33
`34
`
`111
`
`

`

`9) Order the respondent Woodbridge Township should pay 295/day for TAKEN
`34
`AAWAY Porsche cayenne to the plaintiff..............................................................
`e) Additional prayers.............................................................................................
`36
`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
`XXL CONCLUSION
`
`38
`
`IV
`
`

`

`V. INDEX TO APPENDICES
`Vol-I
`1. Notice of Appeal
`
`2. Dist Court order Aug 19 2022. Ecf-22
`
`3. USCA3’s Order to Attorney Representation for Minor
`
`App.01
`
`App.03
`
`App.13
`
`4. USCA3’s Order to submit 5 page brief in support appeal
`
`App,15
`
`JJ)
`
`5. US Dist Court’s Letter order (Sua sponte) dismiss compl.. .. App.17
`
`6. US Dist Court’s Injunctive reliefs denied.
`
`App.21
`
`Y
`
`

`

`VI. TABLE OF AUTHORITIES
`Cases
`
`also Ex parte Peru. 318 U.S. 578, 585, 63 S.Ct. 793, 87 L.Ed. 1014 (1943)
`
`17
`
`ANKENBRANDT, as next friend and mother of L. R., et al. v. RICHARDS et al 504
`U.S. 689 (1992)
`28
`
`Antoine u. 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
`
`15
`
`15
`
`Babb v. SECRETARY. DEPT. OF VETERANS AFFAIRS. 992 F. 3d 1193 - Court of
`Appeals, 11th Circuit 2021
`20, 23
`
`Babb v. Wilkie, 140 S. Ct. 1168 - Supreme Court 2020
`
`20, 23
`
`Bankers Life & Casualty Co. v. Holland. 346 US 379 - Supreme Court 1953.... 16, 17
`
`Bavron v. Trudeau. 702 F.2d 43, 45 (2d Cir. 1983);
`
`26
`
`Bethel School District No. 403 Et Al. V. Fraser, A Minor, et al. 478 U.S. 675 (1986)
`27
`
`Bivens v. Six Unknown Named Asents of Fed. Bur, of Narc.. 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, 11th Cir 2000
`
`Bolin v. Storv. 225 F.3d 1234, 1242 (11th Cir.2000)
`
`Bontkowski v. Smith, 305 F. 3d 757 - USCA, 7th Cir. 2002
`
`Bontkowskiv. Smith. 305 F.3d 757, 762 (7th Cir. 2002)
`
`15
`
`15
`
`15
`
`16
`
`VI
`
`

`

`Bovadiian v. Cigna Companies. 973 F. Supp. 500 - Dist. Court, D. New Jersey 1997
`37
`
`Boyer v. CLEARFIELD COUNTYINDU. DEVEL. AUTHORITY. Dist. Court, WD
`Penn 2021
`
`Cheney v. United States Dist. Court for DC. 542 US 367 - Supreme Court 2004
`
`CJLG v. Barr, 923 F. 3d 622 - Court of Appeals, 9th Circuit 2019
`
`Crooker v. United States Dep't of Justice, 632 F.2d 916, 921 (1st Cir.1980))
`
`Cunninsham. 664 F.2d at 387 n. 4
`
`De Beers Consolidated Minesv. United States. 325 U. S. 212, 217 (1945)
`
`De Beers Consolidated Minesv. United States. 325 U. S. 212, 217 (1945).
`
`DeBold, 735 at 1043
`
`Erickson v. Pardus. 551 US 89 - Supreme Court 2007.
`
`Estelle. 429 U.S.. at 106. 97 S.Ct. 285
`
`Fries v. Barnes. 618 F.2d 988, 989 (2d Cir.1980
`
`15
`
`18
`
`29
`
`37
`
`37
`
`16
`
`18
`
`37
`
`18
`
`18
`
`26
`
`Hines v. D'Artois. 531 F. 2d 726, 732, and n. 10 (CA5 1976)
`
`Hobby Lobby Stores. Inc, v. Sebelius. 568 US 1401 - Supreme Court 2012.
`
`Hodse v. Police Officers. 802 F. 2d 58 - Court of Appeals. 2nd Circuit 1986
`
`Hohn v. United States. 524 US 236 - Supreme Court 1998.
`
`16, 17
`
`2, 18
`
`27
`
`1
`
`Holt Civic Club v. City of Tuscaloosa, 439 U.S. 60, 65-66, 99 S.Ct. 383, 58 L.Ed.2d
`292 (1978).......................................................................................................................... 15
`
`In re Gault. 387 U.S. 1, 36-37, 87 S.Ct. 1428, 18*632 L.Ed.2d 527(1967)
`
`29
`
`Jacob WINKELMAN. a minor, by and through his parents and lesal suardians. Jeff
`and Sandee WINKELMAN. et al. v. PARMA CITY SCHOOL DISTRICT. 550 U.S.
`28
`516- 127 S.Ct. 1994(2007)
`
`Karuoaiyan et al v. Nasanda et al, 22-6342
`
`24
`
`Vll
`
`

`

`Karunaiyan et al v. Nasanda et al, 22-6342
`
`24
`
`Lassiter v. Dev't of Social Servs. of Durham Cty.. 452 U.S. 18, 27, 101 S.Ct.2153, 68
`L.Ed.2d 640 (1981)
`30
`
`Maclin v. Freake. 650 F. 2d 885 - Court of Appeals, 7th Circuit 1981
`
`Mathews, 424 U.S.
`
`Montgomery v. Pinchak. 294 F. 3d 492 - USCA, 3rd Cir. 2002
`
`27
`
`30
`
`27
`
`Moses H. Cone Memorial Hospital u. Mercury Constr. Corp.. 460 US 1 - Supreme
`Court 1983
`16, 17
`
`Mullis v. United States Bankr. Court for the Dist. of Nev., 828 F.2d 1385 (9th
`Cir. 1987)..................................................................................................................
`
`Newman v. Alabama. 683 F.2d 1312 (11th Cir. 1982)
`
`15
`
`15
`
`Osei-Afriye v. The Medical College of Pennsylvania. 937 F.2d 876 (3d Cir. 1991) ..27,
`29
`
`Pa. Bureau of Correction v. US Marshals Service. 474 US 34 - Sup Ct 1985
`
`re US. 139 S. Ct. 452,
`
`Reno v. Flores. 507 U. S. 292, 301-302(1993)
`
`Robidoux v. Rosengren. 638 F. 3d 1177- USCA9 2011
`
`Roche v. Evaporated Milk Assn.. 319 U. S. 21, 26 (1943)
`
`Rosado v. Wyman. 397 U. S. 397, 403, n. 3 (1970)
`
`Salahuddin u. Cuomo. 861 F. 2d 40 - Court of Appeals, 2nd Circuit 1988
`
`Sullivan u. Little Hunting Park. Inc.. 396 US 229 - Supreme Court 1969
`
`Tabron v. Grace. 6 F. 3d 147 - Court of Appeals, 3rd Circuit 1993
`
`Troxel v. Granville. 530 U.S. 57 (2000)
`
`Troxel v. Granville. 530 U.S. 57 (U.S. 2000)
`
`14
`
`17
`
`19
`
`29
`
`16
`
`1
`
`26
`
`25
`
`27
`
`14
`
`19, 29
`
`Vll
`
`

`

`Washington v. Glucksbere. 521 U- S. 702, 720
`
`Washington v. Glucksbere. 521 U.S. 702 (1997)
`Statutes
`
`28 U. S. C. § 1651
`
`28 U. S. C. § 2101(e)
`
`28 U.S.C. § 1651(a)
`
`28 U.S.C. § 1654
`
`28 USC § 1915(e)(2)(B)(ii)
`
`28 USCS 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 11
`
`S.Ct. Rule 20.1
`
`S.Ct. Rule 20.3
`Constitutional Provisions
`
`11th amendment
`
`IX
`
`14
`
`19, 29
`
`2, 16
`
`1
`
`14
`
`27
`
`3
`
`17
`
`25
`
`15
`
`2, 14
`
`26
`
`22
`
`15
`
`29
`
`15
`
`1
`
`17
`
`17
`
`26
`
`

`

`14th amendment
`
`1st amendment
`
`due process
`
`Fifth Amendment
`
`FIRST AMENDMENT
`
`29
`
`10, 32
`
`32
`
`10, 19
`
`27
`
`X
`
`

`

`VII.
`
`PETITION FOR 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.
`
`VIII. Opinion(s)/orders/Judgment(s) BELOW (from Dist
`Court and USCA3)
`1. Dist Court order Aug 19 2022. Ecf-22 (App.3)
`2. USCA3’s Order to Attorney Representation for Minor (App.13)
`3. USCA3’s Order to submit 5 page brief in support appeal (App.15)
`4. US Dist Court’s Letter order (Sua sponte) dismiss compl (App.17)
`5. US Dist Court’s Injunctive reliefs denied. (App.21)
`Hon. Esther Salas USDJ; Hon. Jessica S. Allen USMJ
`
`IX. 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)).
`
`US Supreme Court has Jurisdiction under s.ct. rule ll
`Certiorari to a United States Court of Appeals Before Judgment A
`petition for a writ of certiorari to review a case pending in a United
`States Court of appeals, before judgment is entered in that Court, will be
`granted only upon a showing that the case is of such imperative public
`importance as to justify deviation from normal appellate practice and to
`require immediate determination in this Court. See 28 U. S. C. § 2101(e).
`b) 28 U. S. C. § 2101(E).
`
`1
`
`

`

`An application to the Supreme Court for a writ of certiorari to review a
`case before judgment has been rendered in the COURT OF APPEALS may
`be made at any time before judgment
`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.
`
`On Dec 20 2022, United States Court of Appeals 3rd Cir ordered the
`appellant to submit the 5 pages brief in support for appeal. App.15 and
`the appeal is pending with USCA3.
`X. 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
`Indian family court order Q
`
`Comparative Approaches of Supreme Courts of the World's Largest and Oldest
`Democracies
`
`2
`
`

`

`“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.
`
`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
`
`

`

`XI. STATEMENT OF THE CASE
`1) 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
`
`On Jan 13 2022, Dist Court denied the plaintiff injunctive relieve
`
`motion. App.21
`
`Dist Court entered the final order of dismissal on Aug 19 2022.
`
`App.03.
`
`Plaintiff filed notice of appeal for App.01 for final order.App.3
`
`2) Core facts of the Complaint
`a) Plaintiff s’ 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.
`
`4
`
`

`

`i
`
`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
`
`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.
`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
`
`5
`
`

`

`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 25 202 L
`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
`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.
`
`39:4-56.1(B)
`
`39:3-4
`
`39:6B-2
`
`6
`
`

`

`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.
`
`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. I was not allowed to take care of the medical attention of kids
`
`injuries
`
`7
`
`

`

`69. No others did not take care of the medical attention or need of kids
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`for their injuries.
`
`72. Relief Q. Plaintiff pray a declarative order and/or permanent
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`injunction against US that make amendment to the Constitution that
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`Parental rights are Constitutional rights
`
`115. Relief (). Plaintiff pray declarative order or permanent injunction
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`against Union of India that 1) US citizen kids should not be hold in
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`India, and Kids need to return to US for their education, summer
`
`vacations and 2) properly kids inheritance property/wealth need to
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`transfer to the kids in USA.
`
`e) Allegations against New Jersey - MVC
`
`84.1 requested NJ Motor Vehicle Commission (“MVC”) to provide me
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`duplicate title Of Porsche cayenne so I can register my car on some
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`other state which was denied by NJ Mvc.
`
`85. On or around Aug 2021 (approx) at Edison, Sugartree plaza, I
`
`requested the NJ
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`Mvc mobile service to provide me registration to Porsche which was
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`denied.
`
`8
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`

`

`86. I was told by NJ Mvc’s mobile service that Stop order is placed on
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`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
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`general (NJAG) office to help about the illegal towing of the vehicle.
`
`88. I told NJAG that my home evicted and Porsche car is my home,
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`sleeping place.
`
`89. NJAG told that Woodbridge can tow the vehicle for unregistred and
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`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
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`sleep in the car.
`
`93. NJAG told that apply food stamp, pay the food stamp money to
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`Woodbridge. Need to pay the municipal judges by money collected by
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`municipal orders.
`
`9
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`

`

`g) NJ judicial authority
`94. NJ judicial authority denied plaintiff Palani 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
`
`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-
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`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.
`10
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`

`

`... 1.
`
`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
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`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
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`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
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`Judge to US Supreme Court 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.
`
`11
`
`

`

`16. Woodbridge’s email is john.mitch@twp.woodbridge.nj.us.
`
`j) Allegation against Officer Gandhi and Woodhridge
`
`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
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`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.
`
`3) 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
`
`12
`
`

`

`violation of due process (Count 16).
`
`Compl. 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 2021’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 that Karupaiyan’s allegations against the Woodbridge
`
`13
`
`

`

`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.
`
`4) 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. App.15.
`
`xii.
`
`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.
`
`XIII.
`
`Petitioner’s Parenting rights
`
`Petitioners’ Parenting Rights were in 14th Amendment of Constitution,
`Troxel v. Granville. 530 U.S. 57 (2000) and Washinston v. Glucksbers.
`521 U. S. 702, 720.
`
`14
`
`

`

`XIV. 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 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. Royal, 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@162
`“can 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] pleadings." See
`Holt Civic Club v. City of Tuscaloosa. 439 U.S. 60, 65-66, 99 S.Ct. 383,
`58 L.Ed.2d 292 (1978);
`In Boyer v. CLEARFIELD COUNTYINDU. BEVEL. AUTHORITY.
`Dist. Court, WD Penn 2021
`“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 Civil Procedure. D****As such, it too is
`not the proper subject of a Rule 12(b)(6) motion. D***Global Arena,
`
`15
`
`

`

`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.
`XV. Why USCA3 Will 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 @foptnote [6].
`
`XVI.
`
`More fundamentally, a court of appeals has no occasion to
`engage in extraordinary review by mandamus "in aid of fits]
`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).
`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
`prescribed jurisdiction or to compel it to exercise its authority
`when it is its duty to do so."
`
`a) Against Any Judicial authority (Including NJ authority)
`@383 there is clear abuse of discretion or "usurpation of judicial
`power" of the sort held to justify the writ in De Beers
`Consolidated Minesv. United States. 325 U. S. 212, 217 (1945).
`
`16
`
`

`

`XVII. USSC’s Rule 20.1 and Rule 20.3.
`In re