DueProcess
Should a writ of mandamus be issued to the Eleventh Circuit
QUESTIONS PRESENTED Should a writ of mandamus be issued to the Eleventh Circuit, requiring it (A) to disregard matters dehors the record, (B) to rule without regard to matters dehors the record, (C) to reverse the order of the district court, (1) which granted a motion to dismiss the complaint based on a matter, which was: (i) outside the “four corners” of the complaint, and (ii) dehors the record, and (2) which disallowed requested relief from a state-court judgment under the Rooker Feldman Doctrine, where the judgment was entered: (a) without notice to Anabella Soury, (b) without affording to her an opportunity (i) to appeal or (ii) to be heard on the due-process violations, and (c) without affording to Robert Sarhan an opportunity to be heard on those due-process arguments, and (D) Mandating that the district court accept jurisdiction to grant relief from the state court judgment in regard to the due-process challenges to that judgment that the state court would not hear, notwithstanding the Rooker-Feldman Doctrine? (E) Is mandamus available to mandate relief from orders that recite reliance on items dehors the record and violate the ministerial duty to rule just on items within the record? (F) Is mandamus available to mandate relief from an order of dismissal of a complaint that recites reliance on items dehors the “four corners” of the complaint and violate the ministerial duty to rule just on items within those four corners? (G) Is mandamus available to mandate that the court take jurisdiction where it declined to do so because of a misinterpretation of the Rooker-Feldman Doctrine? (H) Is a judgment of foreclosure against Anabella Soury and Robert Sarhan, as owners of the foreclosed property, a denial of due process where that judgment was entered without serving, and without notice to, Anabella Soury or her attorney and without affording to Robert Sarhan an opportunity to be heard? Should a writ of prohibition be issued to the Eleventh Circuit, prohibiting it: (I) From considering any matters dehors the record, and i (J) Considering matters outside the “four corners” of the complaint? (K) Is prohibition available to prohibit reliance on items outside the record? (L) Is prohibition available to prohibit reliance on items outside the “four corners” of the complaint in ruling on a motion to dismiss the complaint? (M) Is a judgment of foreclosure against Anabella Soury and Robert Sarhan, as owners of the foreclosed property, a denial of due process and void where that judgment was entered without serving, and without notice to, Anabella Soury or her attorney and without affording to Robert Sarhan an opportunity to be heard? (N) Should a writ of certiorari be issued to the Eleventh Circuit determining that the state-court judgment was entered without notice to Anabella Soury, without any opportunity to be heard, was a denial of due process, and was void, and that the district court should order the state court to invalidate the judgment and that the relief hereinabove mentioned in regard to mandamus and prohibition should be granted via certiorari ? (O) Should sanctions be permitted to be based on matters dehors the record? ili CERTIFICATE OF INTERESTED PERSONS AND