Issues being raised

Questions Presented I THE REHEARING PANEL DENIAL DISREGARDED RULE OF LAW, LAW {NCGS 50-13.5(d)(3)}, AND/OR FEDERAL QUESTION (14% Amendment, EXTENDING THE INJUSTICE AND THE BREAKING OF LAW Il. THE APPEALLANT COURT OF THE MIDDLE DISTRICT OVERLOOKED OR MISAPPREHENDED AND MUST ARGUE IN SUPPORT OF THE PETITION Il. THE DISTRICT COURT JUDGE ERRED IN STRIKING THE AMMENDED COMPLAINT . a. The Rehearing En banc’s denial filed May 15" 2019, did not address the issue; federal question, deferring reunification, extending the alienation, breaking and denial of human and constitutional rights to live with maternal family whom they’ ve been estranged from, to whom the courts have discriminated against based on various factors including but not limited to race, color, nationality, familial status, religion, gender, social/financial status, favoring the more affluent and more powerful criminal abusive fathers who have continued and allowed to continue by the courts to not only break the law but deny appellant basic human inalienable rights awarded to any parent who “chose” and had the audacity to give birth; punishing appellant’s minors and appellant by causing anxiety through separation due to appellant’s choice of life, liberty and pursuit of happiness promised under the declaration of independence. A violation of the 14 amendment without question and the NC General Statute NCGS 50-13.5(d)(3) Page | 2 b. The court of appeal’s decision ruling dated April 8" 2019, in affirming district court’s decision overlooked the appellant’s right to “petition the government” thereby exercising her first amendment right against the sanctions set forth by the district court. Rule 40 states, a petition for panel rehearing may be filed within 14 days after entry of judgment. But in a civil case, unless an order shortens or extends the time, the petition may be filed by any party within 45 days after entry of judgment if one of the parties is: (A) the United States; (B) a United States agency, (C) a United States officer or employee sued in an official capacity, or ; (D) a current or former United States officer or employee sued in an individual capacity for an act or omission occurring in connection with duties performed on the United States’ behalf — including all instances in which the United States represents that person when the court of appeals’ judgment is entered or files the petition for that person. All except D of which are the case. c. The amended complaint is solely based on violations not presented on the original complaint. Emphasis on NCGS 50-13.5(d) d. The amended complaint supports the Executive Order 13841 of June 20, 2018, submitted on the standard of the administration and laws set forth (“families remain together”) hence the clause “It is also the policy of this Administration to_maintain family unity, including by detaining alien families together where appropriate and consistent with law and available resources. It is unfortunate that Congress’s failure to Page | 3 : act and court orders have put the Administration in the position of separating alien families to effectively enforce the law.” e. The arrival of Appellant’s oldest daughter H, on November 23"! 2018 as a transfer student to University (as a Naval Officer) prompted the amendment. The amended complaint reenforces the issue on the original complaint in correction to the ongoing dismissal of the “Rights regarding alienation, estrangement and violation of sibling rights: ..648 .. There is also a constitutional right to live together as a family, 649 and this right is not limited to the nuclear family.” f. Under Rule 60 (b) the motion, must be made within a reasonable time—and for reasons (1), 2), newly discovered evidence that, with reasonable diligence, could not have been discovered in time to move for a new trial under Rule 59(b); and (3) no more than a © year after the entry of the judgment or order or the date of the proceeding. (2) Effect on Finality. The motion does not af