Regina B. Heisler, Individually and as the Executrix of the Succession of Frederick P. Heisler v. Girod LoanCo, LLC
DueProcess FirstAmendment JusticiabilityDoctri
Whether the Louisiana Supreme Court erred in failing to enforce Caperton v. A.T. Massey Coal Co. and Henson v. Santander Consumer USA
QUESTIONS PRESENTED i The integrity of the judicial process is paramount and a matter within this Court’s “...inherent power...” to protect, Chambers v. NASCO, 509 U.S. 32 (1991); Also, Implementation of the Judicial Conduct and Disability Act of 1980, A Report by Justice | Stephen BREYER (2006); the further failure by any tribunal below to enforce this | Court’s “...lawful mandates...” in Caperton and Henson raises 28 U.S.C. § 1651(a) to the | fore: | 1. Did the Louisiana Supreme Court err by failing to enforce Caperton v. A.T. Massey Coal Co., 556 U.S. 868 (2009) CCaperton’), as to District Judge Scott U. Schlegel, who was campaigning for Louisiana Supreme Court Justice and accepted $47,500 in contributions from the Kean-Miller law | firm and its client, Texas Brine? Contemporaneous with the contributions, Kean-Miller represented Girod LoanCo against Petitioner before Judge Schlegel, requiring vacatur | of his infirm orders per Caperton. 2. Did the Louisiana Supreme Court err by failing to enforce Henson v. Santander Consumer USA, 582 U.S. (2017) | i (“Henson”) as to Girod, a “...vulture fund...” enforcing $9.8 million in shill loans purchased from the FDIC after the closure of First NBC Bank under the guise that it was a | “debt collector...” not required to meet Louisiana’s DoorClosing laws? If so, is dismissal of all Girod judicial i \ demands against Petitioner required? | 3. Did Judge Schlegel’s (i) sua sponte prohibition that | Petitioner’s counsel not file pleadings without his permission, (ii) coupled with threats of contempt and (iii) his purging of | public records so violate due process principles, In re Murchison, 349 U.S. 188 (1955), as to warrant vacatur of his t writ of seizure and all further orders? | | } i i i i i ] i} j | i | GVR TREATMENT Based on Lawrence vu. Chater, 516 U.S. 163 (1996), Petitioner avers that Grant, iF Vacate and Remand treatment is appropriate, although this Court may wish to speak | to the significant national issues presented. Circumstances justifying GVR include the | facts that: | Q The ruling by Justice GORSUCH in Henson v. Santander chereinafter “Henson’) as to the sale of a failed bank’s loans to a | vulture fund has never been tested; | | Q Petitioner’s (i) advanced age of 78, (ii) liver cancer and (iii) her | inability to afford counsel in her pro se bankruptcy is proceeding without benefit of the 11 U.S.C. § 362(a) automatic stay, which may require a Motion to Circuit Justice ALITO if not cured immediately; Q The manifest violation of Caperton by Judge Schlegel has triggered the $15 million plunder without due process of law, heightening the : i importance of Justice BREYER’s 2006 Report on judicial misconduct; Q The mandate against “...the mere threat of unconstitutional sanctions...” Wolff v. Selective Service Local Board No. 16 requires courts to “...in¢ervene at once to vindicate the threatened liberties...” Q The ABA FORMAL OPINION 491, which cautions lawyers | iii | | representing “...silo structured...” entities in “...secrecy | jurisdictions...” such as TPG and Girod LoanCo, has been mocked in the case at bar. | + . + + . | Lawrence v. Chater provides ample authority for GVR in this case, to-wit: | | “Insofar as Congress, through 28 U.S.C. § 2106, appears to have | i} conferred upon this Court a broad power to GVR, the Court has the power to remand [to a lower court] any case raising a federal issue properly before it in its appellate capacity. Over the past 50 years GVR has become an integral part of this Court’s practice. Whether it is ultimately appropriate depends on a case’s equities.” Parties to Louisiana Supreme Court Rulings | | 1. Regina B. Heisler, (“Heisler”) was the Petitioner at the Louisiana | Supreme Court. Heisler is widowed, 78-years-old, with no significant education and no business or banking acumen. When FNBC was closed on April 28, 2017, Heisler owed $600,000, tried to pay in full, but was told the debt was $9.8 million+ and would be sold in the