IN THE UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT
JACQUELYN B. NJAI, Appellee/Appellant, vs.MR. HOMER FLOYD, ET AL, Appellant/Appellees Case No.: 10-1062, RELATED CASE #08-2366DC. Civil No. 07-1506REPLY BRIEF OF THE APPELLANT
Table of Contents……………………………………………………….1Issues…………………………………………………………………….2-3Argument (ALL Appellees)…………………………………………….3-11Reply Argument To Pittsburgh Board of Public Education…………12-15Conclusion………………………………………………………………..15Certification of Service…………………………………………………..16New Matter………………………………………………………………..16
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ISSUES:
The questions before the court are:
1. Did the district court correctly and impartially follow the intent and elements of Poulis v. State Farm Fire & Casualty Co., 747 F.2d 863 (3d Cir.1984), in dismissing a complaint for the failure of the plaintiff to file a timely complaint after the final decision of the Human Relations Commission and EEOC, who gave her from 12/2006-12/2008, when she filed 11/07 and for failure to prosecute? (NO)
2. (1) For alleged frivolous prior cases? (NO)
3. Did the District Court re-abuse its discretion after having the previous (4/4/08-(that included (3/3/08, 3/4/08, or 3/5/08 judgments), judgment and order vacated for not following true Poulis Factors? (YES)
4. Did the Court show impartiality towards the Appellant-Plaintiff? (NO)
5. Were fraudulent statements and/or documents *submitted by the Wilkinsburg 10-1062, Anthony Sanchez, Andrews and Price, et al. used to substantiate sanctions of consistent dismissals with prejudice against the Plaintiff? (YES)
6. Do the piecemeal decisions of the District Court contradict the evidence submitted in favor of the Plaintiff and against the Defendants? (YES)
7. Is it Constitutional for a Court to sanction a Plaintiff for past prima facie participation and opposition to violations of Title VII, ADA, Sections 1981, 1983, 1985, and 1986 retaliation, conspiracy and discrimination? (NO)
8. Did the Court error when it suppressed exculpatory evidence (i.e. especially the August 17, 2009 right to sue letter and envelop directions with the Right To Sue Letter) from the PAHRC/EEOC, that stated the envelope proof of receipt is the start of statutes of limitation, not the letter date? (YES)
9. Is EEOC a state or federal agency? If federal did not the Court error when it dismissed Plaintiff’s FIOA (Federal) requests? (YES)
10. Should an attorney or others tamper with witnesses to win lawsuits? (NO)
11. Is working as legal civil rights advisor, liability insurance LLP Company for only the state, being a defendant, representing teachers and other public employees all at the same time, IMPERMISSIBLE COMMINGLING? (YES)
12. Did Anthony Sanchez, along with some the PPS/Wilkinsburg School District, change the address of Appellant so it could interfere with her forced early retirement check, during this very appeal February 28-March 31, 2010-by accessing her confidential information and then sending in an rerouting form from the district to PSERS in a malicious attempt to interfere with her benefit checks? (YES)
13. Is this the same tactic and conspiracy that Anthony Sanchez’s firm did, with some EEOC agent Mr. Hardiman, when they changed a letter date and address of Appellant and then claimed she failed to timely respond to a right to sue letter dated June, 2008, sent August 17, 2009?
ARGUMENT:
According to this Third Circuit Court, “In exercising our appellate function to determine whether the trial court has abused its discretion in dismissing, or refusing to lift a default, we will be guided by the manner in which the trial court balanced the following factors, which have been enumerated in the earlier cases, and whether the record supports its findings: (1) the extent of the party's personal responsibility; (2) the prejudice to the adversary caused by the failure to meet scheduling orders and respond to discovery; (3) a history of dilatoriness; (4); whether the conduct of the party or the attorney was willful or in bad faith; (5) the effectiveness of sanctions other than dismissal, which entails an analysis of alternative sanctions and (6) the meritoriousness of the claim or defense.”
Unlike the case footnoted, Plaintiff [N’Jai] had no lawyer that was ill, who constantly did not fulfill his/her responsibilities. Plaintiff even though pro se, did not neglect her responsibilities, and none of her claims were frivolous.
Similarly, as in this appeal by Appellant [N’Jai], she requests the Third Circuit court to please determine whether the District Court abused its discretion in dismissing all complaints and parties of Plaintiff with prejudice, and in ruling that because she [N’Jai], rightfully participated in protected activities against Anthony Sanchez and his firm Andrews and Price, LLP, et al., in the past, that some how is the District Court’s constitutional basis for its sanctions against the Plaintiff with regards to the above Poulis factors in this case.
The extent of the Appellant/Petitioner’s responsibility is reflected in the docket sheets of this case that is attached to the Appellant’s concise statement. Clearly the Pro Se Appellant, who has no help, forma pauperis status due to very limited resources, who is being challenged by legal liability insurance companies, established law firms and attorneys, and who has never been to law school, has a great responsibility that she has remarkably kept up from 2004-2010 -despite the partialities and pain she faces from being constantly retaliated against and discriminated against by some of the same attorney, state and federal-defendants 1994-2010. It is Appellant’s [N’Jai’s], position that she has overly compensated her (informal-liberally construed), responsibility. Even this Third Circuit Court who vacated a judgment (in related case 08-2366), did not do so based upon frivolous claims. The District Court, and most of the Defendants acknowledge her skill in writing briefs, appendixes, and persevering in meeting her court ordered or legal responsibilities. See January 30, 2009 Proceeding, page 58, lines 16-19.
Although Appellant filed this case in 11/07, from that time until now 3/10, there has been no discovery, until now, no filing of appellees’ briefs, no interrogatories, etc. against the Plaintiff. So the District Court capriciously tried to redundantly order Appellant-Petitioner to file motions and briefs, (11/08-12/09), and report to oral (1/30/10 and 8/21/09) arguments, in order to try and help the Defendants come up with a false perception of the Appellant-Petititoner, that she is prejudicing the Defendants for filing lawsuits against them for violating her civil and constitutional rights, instead of sanctioning and stopping the discrimination, or finding out the truth-or the merits of the case. They ignored this 3rd Circuit Appeal vacation of 4/4/08 order, page 2, although not precedential, this court that stated,
“We review the District Court’s order for abuse of discretion. See Emerson v. Thiel College, 296 F.3d 184, 190 (3d Cir. 2002). Wjile we defer to the District Court’s Discretion, dismissal with prejudice is only appropriate in limited circumstances and doubts should be resolved in favor of reaching a decision on the merits.”
Appellant finds it abusive for a court, EEOC, Commonwealth 10-1062 Defendants, a liability insurance firm (that was in charge of the Appellant’s liability insurance with both the Pittsburgh Public Schools and Wilkinsburg SD 10-1062 and other Defendants), and attorneys to continuously think she [N’Jai] has to allow someone to deny her tenure and other professional opportunities, her own personal property, liberties, and resources of the State she is forced to pay taxes for and that she went to school for, that she has permanent certification in, that she is entitled to ; and if she exerts her rights against them, then she has to be subjected to unwarranted sanctions, judgments with prejudice, and retaliation against her. The Defendants had a right to Federal and state information that Plaintiff was not allowed. They were allowed to file for extensions of time after they were late, or after they failed to fulfill their responsibilities. So, the prejudice did not come to the Appellees, but clearly the Appellant was prejudiced.
According to the Court, to be ill, suffering from bitter cold, and inconvenienced-yet brave and determined enough to file for a timely extension of time and motion to reconsider using what Appellant thought was “electronic filing,” are not important considerations for that extension and is cruel and unreasonable sanctions. This makes the Appellant wonder if the interference of her motions were deliberate to justify a 1st, or 3rd Poulis factor- dismissal with prejudice to save face of the Court who had its prior judgment and order vacated by a pro se litigant. This is especially true when each of the Commonwealth 10-1062, Wilkinsburg 10-1062, and other defendants stated in their responses that there was NO history of dilatoriness. Why create dilatoriness by the Court’s “hearsay” of some other judge that Plaintiff never had a chance to defend or have due process against? Appellant argues she was no dilatory intention in this case.
Appellant has shown beyond a reasonable doubt, and by the preponderance of the evidence that she was discriminated against, she has a lot of evidence and other people saw and/or wrote about witnessing discrimination against the Appellant in Wilkinsburg 10-1062 Defendant-School District. The very list of past cases of the Appellant themselves show that the timing, bad faith motives of the Defendants, and opportunities with the District show ongoing retaliation from 1994-2010, despite the pending of the protected activities 1994-2010. Evidence submitted by the Appellant and the PHRC shows discrimination based upon race, disability, age, Sections 1981, 1983, 1985 and 1986, ADA, IDEA, Whistleblower’s Acts retaliation. Judgments in favor of the Appellant prove the cases could not have been made in bad faith and were not frivolous. Appellant will stop suing the Defendants when they stop discriminating and retaliating against her. As a result, the 4th Poulis factor is also in the Appellant’s favor.
It is clear to even Pro Se Appellant, that the Court was not interested in fair “effectiveness of sanctions other than dismissal, which entail[ed] an analysis of alternative sanctions.” Instead the Court continued to belittle, and put down each technical thing Appellant did, and whenever something went to motive in behalf of the Appellant and merits, the Court came up with an order to interfere with that exculpatory evidence-despite that these actions appear bias and unreasonable on the record.
Lastly, in terms of the Poulis factors, the case merits were not fairly considered, because to state that Appellants claims that whites or younger colleagues getting promotional and other opportunities that were denied Appellant are not claims for which relief can be granted. Yet, in case Samuel Howard v. Pittsburgh Board of Public Education, Sam being denied promotional opportunities unlike his white peers was a claim for which relief could be granted. To state that Appellant is crazy in her employer’s administrative offices because she participated in protected activities are claims for which relief can and has been granted hundreds of times. To state that the agents for PAHRC/EEOC conspired with Wilkinsburg School District, by and through Anthony Sanchez is not under the color, or Section 1983, 1985, and 1986 is not a claim for which relief could be granted is not true and is unconstitutional. For Wilkinsburg School District to deprive Appellant of any due process, or equal protections afforded to others is a claim for which relief can be granted. To ignore orders and judgments from courts to return the monetary property of Appellant, is depriving Appellant of her 5th and 14th Amendment rights. Therefore, it is Appellant’s position that her claims including the Section 1981 claims are not valid just because the Defendants denied them, is unconstitutional and unreasonable.
"An unconstitutional act is not a law; it confers no rights; it imposes no duties; it affords no protection; it creates no office; it is in legal contemplation, as inoperative as though it had never been passed." [Norton v. Shelby County, 118 US 425 (1885)]
“[W]e have held that dismissals based on the apparent default of counsel require the court not just to balance the Poulis factors but also to provide the litigant notice and a hearing. Dunbar v.
Triangle Lumber & Supply Co., 816 F.2d 126, 129 (3d Cir. 1987). Even where the attorney’s actions are “flagrant,” a litigant’s potentially meritorious claim is not to be dismissed in the absence of evidence that the litigant bears any personal responsibility. Id. Here, the District Court neither considered the Poulis factors nor provided DiFrancesco with the opportunity to respond to thethreat of dismissal. That was an abuse of discretion.”
Because the final judgment in favor of all Appellees relied upon false information from the Appellees, to get out of liability for their actions, and without any proof whatsoever, the orders should be overturned. Here the District Court blamed Plaintiff for not being able to get the EEOC to give her a right to sue letter until 8/17/09, and then when she got the letter, the Court and the Defendants ignored the regulations of the EEOC to rely upon the envelop dated 8/17/09 vs some fabricated date on a letter claimed to be sent to a wrong address. This address was used dispite the fact that the correct PO Box number has been on the record since 1994-2010. A bad address was used dispite the fact that the EEOC sent Appellant other mail to the correct address and Appellant sent EEOC mail with the correct PO Box address. It is also an important new matter that Appellant just found out on 3/31/2010, that the same Defendants (Anthony Sanchez (using his State Board of Education Positions), accessed confidential information of Appellant, changed her address from PO Box that PSERS had since 2007, to a bad address, and caused 2/28/10 and 3/31/10 benefit checks to be cut off due to a bad address. The PSERS acknowledged what happened, told Appellant and attached is an apology letter from that state agency to Appellant to submit to whomever it concerns. Appellant finds it ironic that in the past from 1994-2010 the same fraudulent and illegal patterns of the behaviors keep surfacing, even during protected Title VII, ADA, and other Federal and state protected activities are pending. Appellant called the US Postal Inspector 3/31/10 and was informed that this is a federal offense and is ID Fraud when someone outside of the Appellant or person, uses personal information to change another’s address. Appellant is filing a mail fraud complaint, as well as wants to tack on this retaliation to this appeal.
For the Defendants to retaliate in 2004, for Appellants participation in Whistleblower Act activities in the past 1994-2004, where she reported drugs, cigarette smoking, sexual harassment and other violations of the Public School Code and federal law, are claims for which relief in both civil and criminal aspects can be granted. For the Court to say that Appellant’s requests for FOIA are dismissed with prejudice, due to no federal agency, but granting the Defendants FOIA requests are merit claims for which relief can and has been granted and shows clear abuse and partiality on the part of the court.
Fraudulent statements (Perjury), and evidence to prove fraud on the part of most Defendants, cannot be a legitimate reason for F.R.Civ.P. 12(b)(6); or any other dismissal. In the appendix filed with Appellant’s Brief of the Appellant, docketed and dated 2/23/2010, Exhibits 1-past 25O to (#9 analysis), show fraud, especially on the part of Anthony Sanchez and Andrews and Price Attorneys, as well as prior filed exhibits that show EEOC/PAHRC, Flipping, et al conspired to deprive Appellant of her rights. They then went further and now used a state agency to tamper with Appellant’s state retirement fund that she mentioned on the forma pauperis form in this Appeals Court that included the very same thing.
For Sanchez to get Wilkinsburg to terminate and not promote the Plaintiff, then state to her bosses and Mr. Rabare (a witness), et al. she is crazy; along with fabricating or misrepresenting the EEOC June 2008 letter sent in an August 17, 2009 envelope; along with claiming there was probable cause, then changing it in retaliation; along with filing legal papers with courts and state and federal agencies stating sanctions should be taken against Appellant’s participation and opposition to their discrimination, along with having exparte legal meetings without the Appellant, with judges and hand pick unknown lawyers who claim to represent Appellant without her knowledge or permission; along with years of past and similar misconduct, show "[p]roof that defendant[s] created a scheme to deceive reasonable people [and this] is sufficient evidence that the defendant intended to deceive, [and] a defendant who intends to deceive the ignorant or gullible by preying on their infirmities is no less guilty."
The District Court cut causal connections and threw out important claims, in order to interfere with Appellant’s ability to prove discrimination. She [the Court] then went on to call oral arguments to intimidate and try and build a false paper trail to buttress the Defendants’ position(s). The Court dismissed (with prejudice) Anthony Sanchez (in his personal and professional capacities), and Andrews and Price, prior to dismissing any Commonwealth 10-1062 Defendants; when Appellant was allowed to sue Anthony Sanchez and his firm et al, and was successful in other case(s). The Court erroneously forbade Appellant to mention anything Anthony Sanchez and his firm did even if unlawful, unconstitutional, or malicious.
In the transcript proceedings for January 30, 2009, before the Hon. Judge Barry Fischer, Mr. Smart (the attorney for Wilkinsburg School District), stated: “Your Honor, just as a point of clarification. In the complaint when references are constantly made between either the Wilkinsburg or the city schools and Mr. Sanchez, he is always referred to as the solicitor. Mr. Sanchez was never the solicitor for either of those districts. HE IS ALWAYS SERVING IN THE CAPACITY AS DEFENSE COUNSEL APPOINTED BY THE INSURANCE CARRIER. So, just to clarify that for the record.” See pages 29 (lines 24-250), and page 30 (lines 1-6).
“No man can serve two masters; for either he will hate the one and love the other, or he will be devoted to the one and despise the other.” Matthew 6:24
ISSUES:
According to the Pittsburgh Board of Public Education, the following arguments have been proven to justify an affirmation of the lower court’s punitive dismissals:
1. Appellant failed to notify the ECF staff to help her with the electronic filing done on April 1, 2008, and therefore failed to prosecute.
2. The District Court’s vacated 4/4/08 punitive dismissal(s) were not done due to an abuse of discretion because Appellant was negligent in notifying the Court by 4/3/08, and therefore the dismissal with prejudice on 4/4/08 was warranted.
3. Appellant never appealed the May 29, 2009 order before the 12/9/09 final order, and therefore the appeal is untimely, or she failed to prosecute by not filing an appeal before the final order of the lower court on 12/09/09.
4. Appellant “is a former employee of the Pittsburgh Board where she was employed as a substitute teacher. (Docket No. 3; at 4; Docket No. 59 at 3: Docket No. 62 at 4).” P. 5
5. Appellant did not state a claim for which relief could be granted.
6. Appellant argued that Anthony Sanchez served as counsel for both Wilkinsburg and the Pittsburgh Board of Public Education.
APPELLANT’S ARGUMENT AGAINST OF THE PITSBURGH BOARD
OF PUBLIC EDUCATION:
According to the Pittsburgh Board of Public Education, Appellant failed to notify the ECF staff or seek help with her April 1, 2008 Motion for Reconsideration and Motion for and Expansion of Time. As a result, the Appellees claim that Appellant, who was sick, cold, and suffering from C/O exposure, who took the time to file timely motions directly to the Judge Nora Barry Fischer, and the Help Desk staff of the ECF, should have her Complaint dismissed for failure to prosecute. This is despite the proof that she did contact them. Please wipe out her social security number from the record.
More importantly, the court did allow the Appellant to amend her complaint after the Third Ciruit Court vacated the 4/3/-4/4/08 judgments. So, the issue of dismissing for failure to prosecute on 4/3/08 was resolved and is moot.
According to the Appellee, Pittsburgh Board of Public Education, the Appellant failed to appeal before the final order of the District Court, dated 12/9/09, because the 12/9/09 order only included Wilkinsburg School District 10-1062 Appellees. Yet, see docket sheet for this case, 07-1506, #90, dated 7/15/09,
“Memorandum Order denying #83 Plaintiff’s Motion for a right to Reserve Issues and the Defendants Dismissed With Prejudice for Appeal; Details more fully stated in said Order. Signed by Judge Nora Barry Fischer on 7/15/09.”
According to that attached Memorandum Order,
“And now , this 15th day of July, 2009, upon consideration of the Plaintiff Jacqueline B. N’Jai’s “Motion for a Right to Reserve Issues and the Defendants Dismssed With Prejudice for Appeal,” filed on June 15, 2009, (Docketed No. 83), in which Plaintiff requests “a rigfht to reserve these defendants and claims that were dismissed after the final disposition of this entire case, after she files her amended complaint” because she “cannot appeal claims that were dismissed because this is not a final memorandum or judgment, (Docketed No. 83-2 at 3), and the Defendants’ Respsonses (Docket Nos. 88, 89, and 90), this Court finds that Plaintiff has presented no grounds upon which this Court can issue a certificate for immediate appeal, pursuant to 28 U.S.C. § 1292(b); see also Nasone v. Spudnuts, Inc., 735 F.2d 763 (3d Cir. 1984)(a district court has discretion to decide whether to certify a case for immediate appeal); Pontius v. Delta Fin. Corp., Civ. A. No. 04-1737, 2007 U.S. Dist, LEXIS 90268, at *5 (W.D. Pa. Dec. 7, 2007)(same); or enter a judgment pursuant to Federal Rule of Civil Procedure 54(b). See Waldorf v. Shuta, 142 F.3d 601, 609 (3d Cir. 1998)(discussing analysis for proper certification pursuant to Rule 54(b)); Roberson v. Pelosi, Civ. A. No. 99-3574, 2001 U.S. Dist. LEXIS 6647, at *8-9 (E.D. Pa. May 21, 2001)(same). Plaintiff retains her opportunity to appeal as provided by the applicable Federal Rules of Appellate Procedure. See FED.R.APP.P. 1, et seq.
Accordingly, IT IS HEREBY ORDERED that Plaintiff’s Motion (Docketed No. [83]) is DENIED.” Signed by Judge Nora Barry Fischer., Pages 1-2, attached to the Appellant’s Concise Summary of the Case document filed 1/4/10. How can the Appellees now argue a frivolous issue that Appellant’s appeal should be
denied because she did not override the above order to deny her a right to appeal the May 29, order? More importantly, in Appellant’s Concise Summary of the Case, she stated,
“PLAINTIFF ATTACHES ALL JUDGMENTS OR OTHER ACTIONS OF THE DISTRICT COURT FROM WHICH THIS APPEAL IS TAKEN. APPELLANT APPEALS ALL ESPECIALLY 12/9/09.”
Appellant was NOT A SUBSTITUTE FOR THE PITTSBURGH BOARD OF PUBLIC EDUCATION, SHE WAS TENURED PUBLIC SCHOOL TEACHER WITH A RETIREMENT PLAN, AND ALL THE BENEFITS THE STATE HAD AVAILABLE TO HER. Until she was wrongfully fired by defendants in the cases the Appellees claim were frivolous, before the court resolved them. She never was given a tenure hearing based upon continuous lies or perjury from the same Appellees that she failed to do what she did not fail to do. Proof has continuously been ignored as well. Andrews and Price were involed in her retaliatory dismissal. Now they are constantly claiming that she was a substitute, when she worked from 1990-2001 as a full time teacher for the state. Appellant believes this is another cover up of their misconduct or conspiracy so that this court will not see the causal connections between their retaliation and the protected activities. Appellant lost $63,000.00, all benefits, was only given the option of Early retirement benefits, and refused when she found out she had another option. This is why the Third Circuit Court granted her Bill of Costs, and held by Planary Review with mandate against the Defendants/Appellees, NOT the Appellant, until 1 year later when the Clerk changed the monetary ruling without an appeal by the Appellees. Ironically, the Appellees in this case left out the order of the clerk who signed Justice Stapleton’s name and the original order that signature is clearly not the same for Justice Stapleton. For the Appellees to continue in this appeal, using false information that the Appellant told them and they know is not true, that she was a substitute, goes to motive how the Appellees intend to lie, alter the record, and do any misconduct to win a civil lawsuit.
Stating that a counsel who advises only State agents within the Pittsburgh Board of Public Education, and the Wilkinsburg School District, and that gave false and damaging references to Appellant in public and private, which immediately or ultimately led to her construction discharge and termination, are claims for which relief has been granted in thousands of other civil rights cases. The past employer is liable for the bad references of a previous employee. Their employee damaged her reputation, even though she got a satisfactory teaching rating in Wilkinsburg School District. Stating she is insane without any medical license or release of medical information by a patient, or the Plaintiff is slanderous and libel at best. Instead of reprimanding the employee (Sanchez), the Board and Wilkinsburg joined forces with Sanchez and did the same thing to her (i,e, terminating her without adequate due process).
Also for the Pittsburgh Board of Public Education (by and through Sanchez et al), to deny her benefits, monetary property that was awarded her by the court, a right to her property and even liability insurance in contradiction to the PA Public School Code of 1949, then to lie about it in this court that all her cases were frivolous, are causes of action, despite the denials of the Board.
The above issues with the Board, infers a conspiracy, that it was motivated by racial or class based discriminatory intention to deprive Appellant Jacquelyn B. N’Jai of the equal protection under the federal and state laws; and in the furtherance of the conspiracy Appellant lost her right to teach, get a salary with benefits, practice public school teaching, and tenure. Furthermore, the Boards then sought to steel confidential information about the Appellant Jacquelyn B. N’Jai, and then change her address back to a bad address, like they did in this case 07-1506 with the EEOC. It caused Appellant not to get two PA Retirement checks, 2/28/10 and 3/31/10, during this very 10-1062 pending of a final 3rd cir. decision.
WHEREAS, Appellant has proven by the preponderance of the evidence, and testimony, that she did seek ECF help and notified the help desk, she took the ECF course, April 2009 when it was offered to her, and still is not allowed to file papers only view retrieve and pay for court documents blocked by the ECF. The mere fact that the case was pending from 2007-12/09, indicates the claims could not have been fruitless.
CONCLUSION(S):
N’Jai has showed that she could not appeal until the final 12/09 judgment by order of the court, and she has showed that she was a TENURED employee with the Pittsburgh Board of Education, with Early Retirement benefits that the Board/Attorney interfered with on 2/28/10, and a check for 3/31/10. Jacquelyn N’Jai also showed that her claims had monetary value and therefore could not be frivolous. Since the record holds that to the contrary then this Appellee Pittsburgh Board of Education, the past state employer of the same Appellant, has no basis for requesting that the Third Circuit Court of Appeal dismiss or affirm the lower court rulings. As a matter of law the Appellee Brief should be denied. Apellant Jacquelyn B. N’Jai, wants her $73,000.00 judgments with interest, benefits and the record to reflect the evidence.
NEW MATTER: Appellant request injunction or sanctions for the current 2/28/10-3/31/10 tampering with her address to interfere and retaliate against her by stopping her STATE public employee retirement benefits without any due process, and using postal and other ID fraud. These Retirement benefits came for Plaintiff being tenured with the Board of Public Education. It is the ONLY district who could have done this, by and through Anthony Sanchez who works for Wilkinsburg SD as well.
Respectfully Submitted,
Jacquelyn B. N’Jai
CERTIFICATE OF SERVICE
I, Appellant, Jacquelyn B. N’Jai, served the attached Reply Brief of the Appellant on the Pittsburgh Board of Public Education, by US Postal mail, on April ____, 2010.
Respectfully Submitted:
Jacquelyn B. N’Jai
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