Feifei Gu v. Michael Sher, New York City Police Officer, et al.
FirstAmendment FourthAmendment Punishment
Whether state officials can be enjoined from pursuing allegedly retaliatory and bad-faith criminal and civil proceedings that purportedly violate a plaintiff's First Amendment constitutional rights
is extraordinary: 1) 2) Petitioner has been the target of harassment from multiple state officials. Respondent Hang Chen first conspired with Respondents police officer Michael Sher and Steven Vitelli and arrested Petitioner without any cause and with forged evidence, a criminal case is pending in New York City Kings County Criminal Court; Respondents Hang Chen, Emily Hui Chen-Liang, Susana Chong Chen further maliciously sued Petitioner in New York State Kings County Supreme Court with false information and forged evidence, presiding over by judge JOY F. CAMPANELLI (a petition for writ of certiorari is pending against JOY F. CAMPANELLI in case 24-7376 in this Court), in this civil case, Joy F. Campanelli is corrupted, repeatedly having ex parte communication with Hang Chen, etc, forged Court documents, and issued Order without jurisdiction and deprived Petitioner First Amendment Rights by enjoining Petitioner from suing anyone in the New York State Unified Court System. Petitioner is facing a Contempt Hearing presiding by Joy F, Campanelli; 3) The lower Court Order by Eric Komitee is deeply flawed (Exhibit B). Petitioner requests the Court to stay the criminal and civil proceedings, Eric Komitee denied, reasoning that abstention is warranted without a showing of bad faith. However, evidence listed in Complaint already evidenced that Respondent Hang Chen forged evidence in Criminal Court, conspired with multiple police officers by forging police reports and arrested Petitioner without any cause, even though police officers and DA were all aware of such falsified evidence, they still continued the criminal prosecution against Petitioner in bad faith. On the other hand, the civil litigation is orchestrated by Hang Chen to retaliate against Petitioner for filing good faith 311 complaints jn regocds ‘te ever 30 violations in the apartment. 4. We concluded that intervention would be warranted in those cases "where a prosecution or proceeding has been brought to retaliate for or to deter constitutionally protected conduct, or where a prosecution or proceeding is otherwise brought in bad faith or for the purpose to harass." Id. at 103-04 (citing Lewellen v. Raff, 843 F.2d 1108, 1109-10 (8th Cir.1988)). [a]bstention would serve no purpose because a state cannot have a legitimate interest in discouraging the exercise of constitutional rights or, equally, in continuing actions otherwise brought in bad faith, thereby reducing the need for deference to state proceedings." Cullen, 18 F.3d at 104, It is always in the public interest to prevent the violation of a party’s constitutional rights, see Pryor v. Sch. Dist. No. 1, 99 F.4th 1243 (10th Cir. 2024), 5. The Second Circuit dismissed Petitioner’s Appeal without a reason. This Court is Petitioner’s final place to seek relief, to stop the harassment. Respondents Hang Chen, Emily Hui Chen-Liang, Susana Chong Chen’s conspiracy with multiple police officers, DA, clerks of lower Court and judges of State Court is here to see the light. This Court needs to intervene in the bad faith criminal and civil litigation, or else Petitioner will face severe consequences in State Court. 6. For all the reasons above, Petitioner prays this Court to grant the extension for Petitioner to file a petition for a writ of certiorari to 8/30/25. Executed on: 6/16/25 8705 19th Ave, Brooklyn, NY 11214 fg1011@nyu.edu Exhibit A Vaou. Gt4£i a7, UtVEILULY, UNILINWY. 2.1, Layo rut E.D.N.Y.—Bklyn. 24-cv-6157 Komitee, J. United States Court of Appeals FOR THE SECOND CIRCUIT At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 2™ day of April, two thousand twenty-five. Present: Barrington D. Parker, Beth Robinson, Myrna Pérez, Circuit Judges. Feifei Gu, v. 24-2799 Police Officer Michael Sher, et. al., Appellant, pro se, moves for leave to proceed in forma pauperis (“IFP”) and an injunction.