In The United States District Court For The Western District of Pennsylvania
Corey L Harris, Prose Civil Action 04-281-Erie
CASE NO: Civil Action 10383-2007 Reinstated or Reopened, Removed base on FACT.
Superior Court No: 220 WDA 2008
Judge Kelly: Copy of matters of facts below
Vs. MOTION To Removed From State Court Case No: 10383- 07
Erie County Economic Development and planning et al U. S. District Court 04-281-e
MOTION To Reinstated or Reopened Civil Action:
Motion To Remove From State Court Case No: 10383-2007, SUPERIOR COURT PA. 220 WDA 2008 AND IN SUPPOT OF Docket No: NS20020708 and NS200200563 ON MAY 8th Judge Kelly Haring on matter at hand.
The Plaintiff pro se, Corey L. Harris, files this Motion for Reinstated or Reopened civil action complaint directed to the respondents, Erie County Department of Public Welfare et al. supported by (FRCP 50 (a) (2) (b) base on this “Notice Pleading” this statute states “command or prohibit something, or declare policy must be in haromny with the fundamental law of the constitution this motion is permitted under this rule it alters the periods of time as follows, unless a different time is fixed see section (b).
1. This court has personal jurisdiction and constitutionally can authorize to issue an order under the Controversy Clause of Article III of the United States Constitution “ under Article III, Section 2, Clause (1) that has been deemed to impose a requirement that United States Federal Courts are not permitted to hear cases that do not pose an actual controversy. Plaintiff states this motion supports an actual dispute between adverse parties, which is capable of being resolved by this court. This Motion is informing this court of the wrong that Plaintiff has allegedly suffered because of the defendant’s action in his State Court Contempt Court cases on his civil actions on December 15, 2004 and on December 21, 2007 see exhibits # 9 1of 5 are attached in support and plaintiff is now requesting an Immediate Appeal under title 28, 1292 on the courts Interlocutory Decisions section under federal claims issues on the order under section 798 (b) in support of substantial ground for difference of opinion which supports an immediate appeal based on the court order to dismiss plaintiff civil action case 04-281-E, on plaintiff State Court Case 10383-2007 and this gives plaintiff an remedy for relief under (FRCP 8 (a) (2)). Rule that is when a party alleges a fraud it must plead the facts of alleged fraud with particularity (FRCP 9 (9)). Plaintiff is motioning this U.S. District Court to amend his complaint under rule (FRCP 15) in U.S. District Court. This court has territorial jurisdiction, which is the power of the court to render a Judgment concerning events that have occurred within a well-defined territory (like from across the street from the U.S. District Court For the Western District of PA). This Motion is supported under Article III Section 2 of U.S. Const. 28 U.S.C. §§ 1330 – 1369 and U.S.C. § 1332
B. THE FACTS ON WHICH MOTION RELIES
2. On November 21, 2007 in the court of common pleas of Erie County Pennsylvania Domestic Relation Section had issued an bench warrant for Plaintiff Corey L. Harris apprehension after denying plaintiff motion for the Court Judge to excuse him self from plaintiff civil as if impose an Conflict of Interest and Controversy between adverse parties of DRS and the Pennsylvania Attorney General Office as Judge William R. Cunningham served as Erie Court District Attorney in the 1980’s and 90’s also was serving as family court civil contempt judge for the State Domestic Relations of Erie County this was clearly an unfair litigation an should support a remedy for relief deemed by this U.S. District Court , see exhibit # 9 1 of 5 and Exhibit # 10 1of 6 in support plaintiff relief deemed by this court and for factual legal clause to reinstate and reopen civil action for an harmful interference to Plaintiff in his child support contempt order Docket numbers NS20020708 and NS200200563, see Domestic Relation orders of the State Court interference of plaintiff right to bring a civil action in Erie County Court of Common Pleas with an
Conspiracy to interfere on plaintiff Corey L. Harris State and Federal civil rights on date above to support the state courts alleged fraud and conspiracy on plaintiff state civil court litigation see Exhibit # 16 A, B, C which support that the Domestic Relation Section on March 17, 2007 the DRS Received From Plaintiff Yearly tax return an amount of $4536.00 and on May 18, 2007 the DRS Received From Plaintiff Yearly tax return anther amount of $3494.00 totaling the amount of $8.353.00 and plaintiff December 21, 2007 Exhibits # 1of 5 and Exhibits # 10 1of 6 support that will was Sentence and Jailed for willfully failing to pay support as ordered and giving three month in county prison for it and three days later the court of common pleas family court Judge William R. Cunningham on December 24, 2007 Dismissed plaintiff civil suit against the defendants DRS et al. leaving plaintiff to be unable to appeal the court decision in a timely matter as was stated in superior court January 7, 2007 DENYING Appellant his request for Reconsideration to appeal in a timely matter this support an Breach of Judicial and Ethical Duty by the Erie Court of Common Pleas State Court Judge and the court Functions as to the Civil Liberty of Plaintiff State and Federal Constitutional Rights see Exhibit # 11(1 of 2) again this supports an remedy for plaintiff relief and a judgment against all defendants DRS et al jointly and severally, award a compensatory damages to plaintiff in an amount to be determined by a jury.
3. Plaintiff was apprehended and found in Contempt of Court for willfully failing to pay support as order and appear as order and hereby order to sever three (3) months for
County Case Numbers above and three days later the court of common pleas civil court division same judge dismissed plaintiff civil action on December 24, 2007 with prejudice as plaintiff was in jail unable to file an timely appeal to support defendants et al cause of harm and State Court Interference to support state an Conspiracy to Deprive plaintiff of his Civil Rights under State and Federal Constitution laws.
4. On December 21, 2007 State Judge William R. Cunningham same Judge holding over plaintiff State Child Support in family Court matter for contempt and holding Over plaintiff State Civil Court Action Case No: 10383-2007 see, exhibits # 9 (1of 5) and exhibits # 10 (1 of 6) and exhibits # 11 (1 of 2) and Exhibit # 16 a, b, c in support of court interference and fraud of civil action in violation of plaintiff civil rights under State and Federal Constitution law. A copy of these orders can be found in plaintiff Exhibits Motion to reinstated or reopened and in support of plaintiff relief in support of the public interest at hand and in dignity of the Judicial Civil Judicial System.
5. At the time that the State Court of Domestic Relation issued the arrest warrant, the plaintiff
had an Ongoing Civil Litigation on the Erie County Domestic Relation Section et al for an violation of his civil rights and infringement, Copyrights and Property Rights, Insider Trading and discrimination to grant license and contracts to his Company Service Provider Transportation Service Now Known as CH’S SERVICE PROVIDER Plaintiff now seek relief in this United State District Court fro the Western District of Pennsylvania and to removed from state court case 10383-2007 and to grant plaintiff motion to amend complaint base on these set of facts that supports an state interference, fraud or plaintiff civil rights state and federal violation of the constitution law and under section 1295 (a) (b) this U.S. District Court hold personal jurisdiction over the determinations of law and fact to be made in the case of controversy plaintiff states that this court has power to decide a dispute as against a particular person DRS et al. see Exhibit # 12 (1of 2) support the State Conspiracy on December 15, 2004 and December 21, 2007 plaintiff is also requesting this court to probe these allegation for civil rights violation and crimes of Fraud and Conspiracy of Cause Business Interruptions and Interference see, flyer Coming Soon Erie dated on 11/18/2004 as plaintiff was working and trying to startup up his own transportation business this in also in support plaintiff request to reinstate and reopen civil action case 04-281-E and State Civil action case 10383-2007 base on the importance of the public interest with jobs and the economy exhibits support plaintiff company income statement if the state did not use its tricks under the cover of their child support contempt’s.
6. This Motion is supported by the pleading facts of an alleged fraud with particularity supported facts under (FRCP) 9 (b) as to state (DRS) fraud on November 21, 2007 and on December 21, 2007 December 24, 2007 with international deception to damage anther individual plaintiff states that this was an fraudulent act and seeks relief under FRCP 8 (a) (2)). And under section 256 (b) states when the Chief Judge of the Court international trade issues and order under the provisions of the above section of this title, or when any Judge of The OF international trade, in issuing any other interlocutory order includes I the order a statement that a controlling question of law is involved with respect to which there is a substantial ground for difference of opinion and that an immediate appeal from that order may materially advance the ultimate termination of the litigation, the United States Court of Appeals for the Federal Circuit may, in its Discretion, Permit an appeal to be taken from such order like what we have herein this motion.
7. The way the court of common pleas Judge decide whether to not remove themselves from considering a case from arguments over Plaintiff Corey L. Harris state cases no: December 15, 2004 and 10383- 2007 was more then an ethical fact of reasoning but a violation of the public interest as well as for the interest of plaintiff state and federal civil rights without an harmful interference and Due Process. This State Court interference is also supported by and State Court Judge ‘s of the Court of Common Pleas December 15, 2004 Civil Action interference on Plaintiff U.S. District Court Civil Action case no: 04-281-E and should be reopened and granted to amend as for the Public Interest of this civil action and plaintiff motion to reinstated or reopened civil action 04-281-E base on denying plaintiff to litigate and by being jail for an fraudulent child support contempt enable plaintiff to seek outside legal counsel so that his family own state up business could have legal representation would not had to litigate his federal civil action on a prison F pond over an 14 months duration with having only once (1) week law library for only an hour a week.
8. Base on the Court of Common Pleas DRS and it Manipulating in the way the Courts had their hands to pill off their unconstitutional Child Support Order of Contempt’s to support an ongoing interference to work or handling their skillfully way that the Courts of Common Pleas Manage and Artfully or Shrewdly, their often child support contempt’s in an unfair way in order to alter or figure for one’s own purposes was in violation of the 4th and 5th and 6th, 7th and 8th, 10th, 14th Amendments of The United States of America’s Constitution.
9. The Motion Supports that the Commonwealth Court of the Court of Common Pleas DRS et al was falsifying court records, and causing threats against plaintiff, in their conspiracy to cover up their fraud, violations of there oaths of office and alleged Treason against the United States of America with the knowledge and acquiescence of and cover up by plaintiff support order’s on contempt’s the DRS et al tried to make an civil contempt of support an complicated legal issues by the Department of Public Welfare looking the other way under the actions of the court of common pleas and their fraud worked at that time in December 15, 2004 and November 21, 2007 and December 21, 2007 see Exhibits # 9 (1 of 2) Exhibit # 10 (1of 6 and Exhibit #11 (1of 2) in support of plaintiff Motion to reinstated or reopened civil action case no: 04-281-E and State case 10383-2007.
10. On December 15, 2004 plaintiff was sentence in the court of common pleas without any his rights to an attorney or was his attorney allowed to defend his client because the court main purpose was to interfere in Plaintiff United States Court Civil Litigation case 04-281-E this violates the interest of the public and this action should to granted for trial by jury demand and the defendant should be held to answer plaintiff 04-281 –E civil complaint.
11 On December 21, 2007 Motion was sentence in the court of common pleas without any rights to an attorney because the court main purpose was to interfere in plaintiff Court of Common Pleas of Erie County Civil Litigation case no: 10383-2007 this two violated the interest of the public and this court should grant my request to demand this case by trial by jury, or relief.
12. This United State District Court should be concern about this potential interference with Plaintiff Corey L. Harris 2004 civil case no: 04 –281- E and State civil action case no: 10383-2007 by the commonwealth court and its partnership with DRS and Erie County Economic Development and Planning et al see, United Mine Workers of America v. Bagwell, 512 U.S. 821,831 (1994) and see generally 42 U.S.C. § 654 (1994) and order this civil action demand this cases by trail by jury, or relief.
13. The United States Supreme Court has recognized that contempt power is uniquely “ liable to Abuse”. As it leaves the offended Judge solely responsible for identifying, prosecuting, adjudication, and sanctioning the contumacious conduct”. As support by United Mine Workers of America v. Bagwell, 512 U.S. 821, 831 (1994). And see generally 42 U.S.C. § 654 (1994)
14. Plaintiff submits reliable documents are permitted under FRCP rules of Evidence rule 902 of self authentication and evidence that this was an intentional act and was planned, guided ad supported by the court of common pleas DRS Director in his official capacity et al plaintiff Motion is supported by the relevancy requirement under FRCP 401 AND 402 In which is supported by plaintiff Exhibits. Plaintiff states in his alleged civil rights violation as to the defendants DRS et al were action under Color of State Law
15. The plaintiff documents clearly show that his civil rights violations was carried out with the direct involvement of the DRS et al Respondents as supported by the action and inactions of the court judges above see, (Bivens Action) to be implied from provision of federal constitution see, Supreme Court case 127 L Ed 2d 715. See a civil liability with respect to conspiracies to interfere with civil rights see 122 L Ed 2d 807. And see “Bivens action, seeking damages for alleged civil rights violations 116 L Ed 2d 965. In section (b) Supreme Court views as to Judge’s liability for Damages see 166 L Ed 2d 947.
16. This Motion is supported by 42 USCS § 1983 and by 42 U.S.C. § 1983. As the DRS et al was acting under color of state laws within the meaning of civil rights under the above civil rights statutes and in violation of the plaintiff civil action case no: 04-281-E and state court case 10383-2007 plaintiff pray this court grant his Motion to reinstated or reopened and grant an order to amend plaintiff complaint or to grant a judgment against all defendants et al jointly and severally, award a compensatory damages to the plaintiff in an amount to be determined by a jury and / or the court on civil action cases 04-281-E, 10383-2007.
C. NATURE OF THE RELIEF SOUGHT
17. The plaintiff seeks an order directed at respondent DRS and Erie County Economic Development and Planning et al to be prepared for adequate defense to said plaintiff 2004 civil action case no: 04-281-E, on Allegations base on the above conceivable set of facts that fall within the language of Corey L. Harris Allegations base on the above showing of poor judgment or lack of care in handling affairs of one’s office, element which, distinguishes negligent mishandling of public business from unlawful conduct buy public officer in handling a discretionary matter is the existence of a corrupt motive, see Com v. Steinberg, 362 A.2d 379,240 PA. Super.139. Or is dad faith is essence of the offense of misbehavior in office 18 Pa, C.S.A. § 5101 AND § 107 (b) Support either breach of a positive statutory duty or performance by public official of a discretionary act with an improper or corrupt motive if injuries to Counties, Business, or if other elements were present would also support a allegation of Misconduct in office see also Com v, Green, 211 A 2d 5, 205 Pa. Super.539.
WHEREFRE, Plaintiff prayer and request that this Honorable Court to grant him the Following Relief:
1. A Judgment against all Defendant DRS et al Jointly and Severally, Award a Compensatory Damages to the plaintiff in an amount to be determined by a jury and / or the court
2. A Judgment against the State and DRS et al Awarding punitive and mandatory damages to the plaintiff and an amount to be determined by a jury and / or the court.
3. A Monetary Award for the Plaintiff Violation suffered for this actions, pursuant to 42 U.S.C.§ 1983
4. Any other relief that this court finds to be Just, Proper and Equitable.
18.Plaintiff also Motion this court to reinstate state court case No: 10383-2007 and plaintiff Motion this court to reopen federal civil action case No: 04-281-E and plaintiff also Motion this court to allow plaintiff to Amend his civil case No: 04-281-E in support of the Public Interest that’s at hand and to direct to the respondents to prepared for an adequate defense from this Plaintiff Corey L. Harris on his claims Civil Rights and on Infringement, Copyrights violations an on breach of contract as an Membership Member of an Corporation Economic Development of Business Memberships and Property Claims has Plaintiff will Amend his complaint to include Individuals in their official capacity, State Corporations in their official capacity on claims of corporations violations and insider trading, copyrights violations and Breach of Membership Contract violation, Verbal Contract Agreement and Conspiracy to prohibit plaintiff from seek Federal Grants and Contracts on his November 2004 Transportation Program that’s now running throughout Erie County under the e entity and left entity and medical transportation entity all were working under the color of state law. This is how plaintiff will diagram his Amend complaint if granted by this United States District Court case no: 04-281 civil action complaint and all parties to this action will be notified on this Motion request if granted with good cause of action in support of states interference. As Plaintiff was unable to seek counsel as he was litigating his 04- 281-E civil action case behind prison walls with no rights to counsel.
.19. Plaintiff also states this Motion this ultimately lead to the Ninth Amendment IX enumerating various rights that could “ enlarge the powers delegated by the Constitution. Plaintiff admit the Ninth Amendment Arguments with and questions of Fundamental Foundation, also states that it is true the powers of the general government are circumscribed they are directed to particular objects, but even if government keeps within its limits, it has certain discretionary powers with respect to the means which may admit of Abuse to support this court specific legal remedy plaintiff states in support of the following five originals models of interpretation:
1. The State law rights models
2. The Residual rights models
3. The Individual natural rights models
4. The Collective rights models,
5. And The federalism model
These models has again been deemed to impose a requirement that United States Federal Courts are not permitted to hear cases that do not pose an actual controversy plaintiff states that this civil action 04-281-E and State court action 10383-2007 supports an actual dispute between adverse parties which is capable of being resolved by this Court. Informing this court of the wrong that plaintiff has allegedly suffered because of the Respondents et al and requesting a remedy to reinstate and reopen state and federal civil action with plaintiff right to amend complaint 04-281-E.
D. ARGUMENT IN SUPPORT OF THIS MOTION
I Corey L. Harris of Erie County Pennsylvania currently have evidence dating back from years 2000 and 2004, 2007 to present 2012. That support the Erie County Workforce Board Members of The State of Pennsylvania, Erie County and Erie County Workforce Development and the Agency of Greater Erie Community Action Committee (GECAC Transportation Division) and there State Job Access Program Federal and State Founding Though the Department of Transportation (DOT) and Federal Transit Administration (FTA), and the Pennsylvania Department of Erie County Economic Development and Planning (DCED) to operate the service, which was called JOB ACCESS, see Exhibit # 13 (1of 6). Plaintiff motion is also alleging that the Defendant et al were and are still working and are still operating plaintiff alleged Transpiration Service Provider Program of CH’S Service Provider Under An State For profit Service Under Erie Yellow Cab and County of “e’ under a Nonprofit Entity of GECAC LIFT, Erie Metropolitan Transit Authority the “e” and working in partnerships with the State of Pennsylvania Workforce Investment in Urban Development also are working in partnerships with Local State Agency Such as the Pennsylvania Career Link and The State Department of Public Warfare, and GECAC Transportation Founding of Job Access, EMTA now Known as the “e” of Erie County and Workforce Investment Board Just Received $1.8 million federal grant for Job Creation and Transportation for other issues in The Erie Region. Plaintiff State this is why this Current Motion to Reinstate or Reopen and Remove plaintiff civil action case from State Court to U.S. District Court for Trial by Jury Demand because these issues are in the public best interest and motion to reinstate and reopen should be Granted for Trial by Jury Demand because of the Public Interest at hand for this Erie Region see Exhibits # 14 (1of 4) and Exhibit # 15 (1of 4) in support of plaintiff seeking founding from Erie County Economic Devolvement and Planning at the time of 2001,2004,2007 to provide an 24/7 days a week at low rates contracted Transportation Services to Pennsylvania and local governments of non-profit and for profit companies like the EMTA And Left, GECAC LIFT Service now call the “e” bus left service of Erie County Pennsylvania and the above Defendants et al Executives/ Board Members of GECAC LIFT And EMTA “e” Filed to notify the State of Pennsylvania Cooperation Bureau and or its Corporation Board Members of The States Workforce Investment Board and or their shareholders and stakeholders to whom or investing in them services and or commodities.
The Defendants et al in plaintiff motion were at all time working under the color of state law and failed to inform the stakeholders of whom the programs True Founder Was of the State Federal Founded Grant Program of Workforce Investment in which the public holds valuable interest of the State and County Workers Transportation Programs called at the time in 2001 or thereof in 2002 “JOB ACCESS” and now are being formed under anther public or private entity like the Exhibits # 13 dated for 2001/ 2002. This is the program of that of Corey L. Harris 2000 and 2004 and Current Business Plan As Plaintiff is The Owner and Founder of CH’S Service Provider Founded in year January of 2000 to Present and Plaintiff now Motion this U.S. District Court to award plaintiff for an 12 years of Compensation Plan and Order the defendant to Cease & Desist its States Workforce Investment Grants pass and current to Cease and Desist and order this plaintiff motion for compensation and or a trial by jury demand. As plaintiff is seeking an court awarded State Compensation in support of plaintiff motion as the State alleged defendant et al of Pennsylvania were and are now still operating plaintiff Transportation Service Program without his knowledge or Permission or without Compensation and or without Just and Proper Benefits to him as the defendants were and are currently operating under the Erie County Left and under State Erie Medical Transportation Services and without compensation to plaintiff as plaintiff was seeking financial grant support from the defendants et at in years 2001, 2002 and 2004 and Presently 2012 the defendants have received State and Federal Monies for plaintiff program totaling the resent amount of 1.8 million for the County and State workforce Investment Grant For Economic Development Planning issues as well as for operating plaintiff County and State Medical Transportation Services outline under the States and Erie County “OVR” program funded by federal money and State monies for non- profit Corporation like the defendant GECAC has received Monies under their Entity and under the Erie County Entity of the “e” an County Left Services.
The defendants et al, all working under the color of state law have all fielded to notify their board members of services true founder and or fielded to notify the Pennsylvania State Corporation Bureau of who to true founder of the Erie County Transportation Service serving under The Workforce Investment Act, without compensation Corey L. Harris the true founder of Pennsylvania State Program Called “ Workforce Investment of Erie County Job Access” the defendants et al were and still are in working Partnership with Workforce Investment and their Economic Development of the State and County and working with Pennsylvania Career-link and with the Pennsylvania Department of Public Welfare.
I now submit Exhibit # 13 (1of 6) in support of Corey Harris Motion to grant an relief and or to grant plaintiff motion to Cease & Desist and grant plaintiff motion to reinstate civil action case no: 04-281-E and state civil court action no: 10383-2007 be removed from state court proceeds that initiated in state court an now being motion to removed to U.S. District Court under Title 28 U.S.C. Section 1441. States when the petition for removal is granted as plaintiff is seeking Ownership and compensation in the form of Relief of the State and County of Erie County Pennsylvanian Program DRS Conspiracy in support of Exhibit # 17, Under Civil Rights § 27 Government Liability States or Local Official under local government liable under 42 U.S.C.S § 1983, for the official’s actions in question and the States Final policymaking in a particular area or an on a particular issue, and liability of incoming partner under 15 Pa. C.S.A. § 8329 also see Exhibit # 17. As party was awarded State and Federal Money to Operate Plaintiff Corey L. Harris 2000/2004 Business Plan of “CH’S Service Provider State Entity” and defendant et at misrepresented plaintiff Transportation Plans and embezzle plaintiff Ideas of an better state and local service on servicing the workforce of State and Erie County Workers and Abroad and to have plaintiff plans, ideas as plaintiff was seeking state and federal contracts for transportation service of that of CH’S SERVICE PROVIDER Owner Corey L. Harris, though Local Agency now operating without plaintiff permission and without compensation to plaintiff. This is in support of plaintiff motion to reinstate or reopen and or to grant Compensatory and Monetary Relief in this United States District Court and in support of plaintiff motion to this U.S. District Court of Plaintiff Request of an Federal investigate on these matter at hand of the Erie County and State of Pennsylvania Oversight of its Medical Transportation and Workforce Investment Board of the County and the State Agency’s of Pennsylvania to investigate this improper action. See exhibit # 10, 17 and 13 (1of 6) in support of the following alleged.
PRAYER FOR RELIEF
WHEREFRE, Plaintiff request that this Honorable Court Grant him the following relief:
1. A Judgment against all Defendants Jointly and Severally, Award a Compensatory Damages to The Plaintiff in amount to be determined by a Jury and/ or the Court
2. A Judgment to Grant Plaintiff Civil Case Action 04-281-E and turn civil case over from Trial By Jury demand
3. The Plaintiff hereby demands a trial by jury demand
4. A Judgment to Grant this civil action for trial Under 6.3. A Procedure motion on motions under FRCP 7 (b) (1) that requires that all motions, except those made at trial be made in writing and State with Particularity as to the defendant et al Awarded Grants in the year 2005. Awarded Erie County EMTA “e” Shuttle Bus Service that was State and Federal funding in the amount of 2.5 million on a Transportation Service that only run less then 5 miles in an 24 hour period. When plaintiff Corey L. Harris Grant application request for federal funding in year 2004 and 2007 in they amount of $ 463,000.00 for to operate State Wide on and 24/7 days a week plus holidays was to service an 90 mile radius within all county area’s which was stated in plaintiff 2004, 2007 business plan application for his workforce investment, community economic development grant for his transportation service of Ch’s Service Provider again plaintiff was seeking an 24/7 days a week a 90 mile radius program that runs all across the state and not just less then a 5 mile radius. This motion is in support of plaintiff Relief or an order to cease & desist in support of defendant DRS et al Plan Interferences. Plaintiff is motioning this U.S. District Court of an order and or a injunction on the Erie County Medial Transpiration Assistance Program Under “OVR” and the GECAC LIFT Transportation Service under the Erie County EMTA “e” and their Erie County Shuttle Service until this U.S. District Court Render its order on plaintiff motions.
5. To Order the Defendant to Civil Action case 04-281-E to Answer Plaintiff Complaint and respond
6. To Grant Plaintiff States Civil Action 10383-2007 and reinstate case over for Trial By Jury and or Award Compensatory Relief.
7. To Grant Plaintiff Request Of An United States District For The Western District Of Pennsylvania Federal Grand Jury Under The Constitutional Law Under The Fifth 5th Amendment Clause On Claims Alleged In Plaintiff Motions In Support Of The Public Interest.
8. Plaintiff Motion this U.S. District to order an Cease & Desist on the County and State Workforce Investment Board Federal Grant Founding of the resent 1.8 million Economic Deployment grant for Erie and its other issues in this Region until an Court order on this matter of plaintiff Motion to reinstate and or reopen and remove state case to U.S. District Court for Jury Trial by Demand or Award a Compensatory Damages to the plaintiff in an amount to be determined by a jury and / or the Court has been order in the entry.
9. Plaintiff motion this U.S. District Court for the Western District of Pennsylvania to Use its Constitutional Powers of The Fifth 5th Amendment Constitution and Find plaintiff to civil case 04-281-E and state case 10383-2007 is that of an public interest and should be send to be presented in front of an Federal Grand Jury for Crimes of an Civil Tort and On A State Judicial Misconduct to Support State Conspiracy to Deprive and to Interfere in an ongoing State Federal Civil Matter in support of plaintiff Corey L. Harris Exhibits # 9,10,11,12,13,14,15,16, and 17. This request by the plaintiff is that of the importance of our community and the importance of the public interest as plaintiff has suffered and unlawful and unjustifiable civil right violation as being alleged and support by Exhibits that is being alleged to have been caused by the State Defendant Acting out under the color of state law.
AFFIDAVIT IN SUPPORT OF MOTION
Pursuant to Federal Rule of Civil Procedure I Declare Under of Perjury That The Foregoing Is True And Correct.
CERITICATE OF SERVICE
The Undersigned Hereby Certifies That on April 27, 2012 a Copy of The Within Motion Was Send Out On All Counsels of Record By U.S. Mail Service, and Hand Delivered To Clerk of U.S. District Court Prothonotary By Plaintiff.
Corey L. Harris/ Ch’s Service Provider, Founder
Motion Pro Se
Address: 129 Chestnut Street Box 8
Edinboro PA, 16412
Phone: (814) 464- 6757
United States District Court For Pennsylvania Clerk Office
Court Of Common Pleas Judge Kelly