Whether equitable tolling, fraudulent concealment, and civil rights claims should apply when law enforcement officers conspired to frame a defendant and conceal evidence in a criminal case

The District Court’s gran t of a Motion to Dismiss under Statute of Limitations is supposed to be for “rare circumst ances. ” This case examines the ope n que stion of law in this Court, subject to a Circuit Split, of when inquiry notice begins and/or Petitioner ’s claims are otherwis e equitably tolled or fraudulent ly conceal ed when : (1) Respondent Officer s Gladstone, Vignola, and Hankard , conspired and concealed not only their direct involvement , but existence, plant ing evidence to frame Petitione r an d found guilty between 2019 through 2022, and (2) a reasonable fact -finder would conclude the criminal indictmen t unsealed in 2019 began Petitioner ’s inquiry notice . Lacking definite analysis from this Court, the case was simply and wrongly dis missed before discovery began for not being filed by 2017, for the initial inciden t in 2014 . The Questions Presented are: 1. In a now proven criminal conspiracy framing Petitioner but likely undiscover able before Federal indictment on Conspiracy to Deprive Civil Rights , should a plaus ibly plead and argued “Equitable Tolling ,” “Equitable Estoppe l,” and/or “Fraudulent Concealment” apply to Petitioner ’s Federal Civil Rights case on matching facts to the Motion to Dismiss based on Statute of Limitation defens e? 2. Whether Federal Courts should allow “High Low” Agreements on Appeal, especially when kept secret and undisclosed , the subject of a Circuit Split, which characteristics are more in nature of “collusive ” from this Court ’s classical cases of Lord v. Veazie , 49 U.S. 251 (1850) and Am. Wood Paper Co. v. Heft, 131 U.S. 92 (1869 ). iii 3. Whether Summary Reversal should be issued on whether the 660-Page Steptoe Taskforce Report on the Gun Trace Task Force (GTTF) , admissible under both public record and judicial notice , published two months prior to Petitioner ’s suit being filed, incorporated specifically into the Complaint with page number citations , linked to in other R eported Fourth Circuit cases like United States v. Paylor , 88 F.4th 553, 563 n.2 (4th Cir. 2023) , and discussing throughout the Report, Respondents ’ continuing pattern of similar corruption for many years, and as Inspector B romwich explained based on other publi c and sealed records, over 200 interviews with public officials and police personnel , explaining the extraordinary fraud ulent, perjurious, and unconstitutional lengths both ge nerally and specifically involving Petitioner, but which the trial Court noted she would “not consider ” this Report attachment as “way too long[…].”