Petition for Writ of Certiorari/ Maryland Courts

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As an educated disabled black woman, I believe in justice, fairness and integrity. I was taught and always try to live by the rules of authority and law. As a former advocate, I always respected others regardless of class, race or religion, etc., but I take issue when authority abuses their powers especially against the vulnerable community. My experience as a disabled black woman in Maryland courts and public safety I clearly understand the meaning of racial profiling and the discrimination of being disabled. I never thought that I would experience a bad relationship with some police officers since I moved in the State of Maryland nor the ill-treatment against disabled citizens in public places.The Court of Appeals states "This isn't public interest" in the State of Maryland. You have wonder....What public. Who's interest? What race? Who determines or speak for the interest of the public? I hope my experience help others!

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Content

MERCEDA D. GOODING,

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IN THE

Pro Se Petitioner

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COURT OF APPEALS

v.

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OF MARYLAND

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January 13th 2016

STATE OF MARYLAND,

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Respondent
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Petition Docket No. _____
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PETITION FOR WRIT OF CERTIORARI
This matter concerns Case No. 127795C, appealed from District Court in Montgomery
County, MD filed at the Circuit Court of Montgomery County 8/11/2015. The District Court
cases No #. 0130MF7, held a trial on 7/24/2015, the Petitioner was found guilty of a minor
traffic offense; failure to obey properly placed traffic control device instructions. The petitioner
was denied ADA accommodations by the District Court Judge which contends that the principles
of Rule 2-513 were ignored and the Court refused the application of the granted ADA request
which was implemented 30 days prior to the date of the proceeding, as required by Rule 2-513(c)
and refused to fulfill any of the requirements set forth in Rule 2-513(d) and (e).
I gave the District Court ADA Accommodation request 6/22/2015 & Letter to Judge 5/12/2015
stamped by the court of ADA Accommodations.
“The ADA, codified at 42 U.S.C. §12132 (1990), provides that “no qualified individual with a
disability shall, by reason of such disability, be excluded from participation in or be denied the
benefits of the services, programs, or activities of a public entity, or be subjected to
discrimination by any such entity.
The District court Judge violated the petitioner’s constitutional rights (1st, 14th , 5th and
6th) suppressing factual evidence and supporting “police misconduct” and he restrict me from
“due process” granted ADA accommodations that refuse me the right “defend” and cross
examine the Trooper. The Petitioner moved to Maryland at the age of 42 with 0 points since then
ever year targeted by police officers in Maryland.
The Petitioner’s statistics demonstrates “inequality” within the MD judicial system and
the violations of “due process” against African Americans (blacks) in the Montgomery County,

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MD courts/ traffic stops. Blacks are highest race with traffic stops and this was investigated by
the Justice Department.
(U.S. Department of Justice, 2002). “The unequal treatment of minorities in the criminal
justice system manifests itself in a mushroom prison population that is overwhelmingly black
and Hispanic; which black and Hispanic deserves to neither trust nor support judicial
system”.
White

52.6%

62.1%

Race

Maryland

America

Black African/
American

30.3%

13.2%

American
Indian/Native

0.6%

1.2%

Asian

6.4%

5.4%

Native Hawaiian

0.1%

0.2%

Two or more races

2.6%

2.5%

Hispanic or Latino

9.3%

17.4%

Total

49.3%

39.9%

*Total of
minorities in
the State of
Maryland is
less than the
majority one
race whites.
Black
/African
American
are almost
half
compared to
whites is the

highest in traffic stops, incarceration and paying fines.
These factors contribute to a perception that lawlessness is a “colored” problem. The
disproportionate treatment of blacks and Hispanics within the criminal justice system is a
rational response to a statistical imperative.
“Over 72 percent of people in Maryland’s prisons are African American, according to the
2010 Division of Corrections Annual Report. “Only 29.4 percent of Marylanders are black.
These contributing statistical factors are part of police misconduct during the traffic stop
on 3/18/2015. The petitioner filed a complaint immediately after she discovered who the
Trooper’s supervisor. Then I reported and file a complaint to internal affairs on 4/9/2015. Later
the Petitioner received harassing phone calls from the State Trooper office that “I am going to
make the Trooper to lose his career”, which I wrote a letter to Attorney General Frosh.

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During the District Court Montgomery County, MD trial on 7/24/2015, I tried to argue
police misconduct during the traffic stop however the Judge refused to neither hear nor obtain
evidence such as the ticket which proves the officer’s suppressed his identification or badge.
ATTACHMENT I- Traffic ticket no identity of the Trooper. The Trooper refused to identify
himself only to cover up his wrong doing during the traffic stop on 3/18/2015.
“Public trust and confidence in our legal system are grounded in the perception of
fairness and equality in our courts and in the offices that support our courthouses”. While
minorities are overrepresented in the justice system as defendants in criminal cases and as
inmates in, traffic stops, fines, jails and prisons, they are underrepresented as judges, judicial
appointees, clerks and court employees. There are over 90% of white male Judges, representation
on MD Judicial disability board, internal affairs employees and police officers in the State of
Maryland especially in Montgomery County, MD. “How can justice be fair, colorblind or
impartial?”
The Judge perpetuated police misconduct and allowed dubious police tactics in the court
to demonstrate pervasive culture of police impunity. A Maryland Judge “shall disqualify himself
or herself in any proceedings in which the judge’s impartiality might reasonably be questioned.
MD Rule 16-813, Md. Code of Judicial Conduct Rule 2.11(a) (the “Rules” Similarly, (a)
judge shall avoid conduct that would create in reasonable minds a perception of impropriety.
The Pro se Petitioner was charged a traffic fine $150.00 costs $25.00 which the total fines
and costs for the case $175.50. The Petitioner is a pro se indigent litigant; refused a public
defender because the ticket was minor and the charge was not a jail-able offense, appealed this
case to Circuit Court 8/11/2015. Faretta v. California 422 U.S/ 806 d 562 (1975)
THE ISSUE
The Petitioner raised issues due to her current disability and impairments to receive a fair
trial to prove “racial profiling;” violation of “due process” and “equal protection” in a white male
dominated judicial system in Maryland. The problem is her ethnicity and 1st Amendment rights to
be “express” “racial” and “inequality” against a while male dominated system. The Trooper
perjured two different testimonies, refused to ID himself during the traffic stop or the ticket,
police misconduct and the refusal of ADA accommodations. The Circuit Court Judge violated
my 5th, 6th and 14th Amendment rights “equal protection”, “due process” and refused me to cross
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examine of witness (Trooper). The Petitioner deserve a fair procedural process that is related to
a "liberty," regardless the Judge feel uncomfortable addressing race, inequality and injustice or
“racial profiling” as her defense.
The Circuit Court Judge didn’t allow the Petitioner to defend themselves however relied
on perjured testimony by the State Trooper testified under oath two with different testimonies
regarding the traffic stop on 3/18/2015 (District Court trial 7/24/2015 & Circuit Court trial
12/16/2015). In addition, the Petitioner became ill and the Judge refused to allow her to object
violating her medical privacy and disclosure during trail. The court didn’t obtain her consent nor
subpoena to gain medical records however the Circuit Court Judge took the role as the ADA
coordinator and instructed a clerk to illegally obtain medical records. The Petitioner did not give
the Circuit Court of Montgomery County, MD permission to disclose nor consent my medical
records from any doctors.
Department of Health & Mental Hygiene/disclosures § 4-306 requires a health care provider
to disclose a medical record, without authorization of a person in interest, in nine enumerated
circumstances.
The Circuit Court Judge acted bias and focused one doctor’s note whereas the Petitioner
provided more than 4 medical certifications even though she has several impairments monitored
by different doctors. She filed ADA accommodations and it was approved; they never requested
any documents to support her impairments. However, the ADA accommodation request was
granted but wasn’t executed during both of the petitioner trails. The petitioner doctors’ with the
exception refused to respond to the Circuit Judge’s clerk phone call requesting disclosure
without proper ID, my consent or a court order to obtain health information , if needed she
should provided if the Circuit Court would’ve asked.
Department of Health & Mental Hygiene/disclosures § 4-309 Refusal to disclose records;
violations of subtitle; penalties.
Even though, the Circuit Court Judge administratively took the role of the ADA
coordinator and presumed to know the laws however he instructed the clerk to violate the
Petitioner’s medical privacy/disclosure and/or HIPPA law.
MARYLAND CODE OF JUDICIAL CONDUCT Rule 2.8. “When bias, prejudice or lack of
impartiality is alleged, the decision is a discretionary one . . .” Surratt v. Prince George’s
County, 320 Md. 439, 465 (1990). A “trial judge is presumed to know the law and apply it
properly.”
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QUESTIONED PRESENTED
The issue in the Petitioner’s case is raised the right to a fair trial in a white dominated
Maryland judicial system without impropriety and discrimination.
MARYLAND CODE OF JUDICIAL CONDUCT Rule 1.2(b). Impartiality under the Rules
means the “absence of bias or prejudice in favor of, or against, particular classes of parties, as
well as maintenance of an open mind in considering issues that may come before a judge .
The Circuit Court Judge was predisposed to believe that the petitioner is guilty, judges
are likely to disbelieve the defendant and judges do not like to call police officers liars. Police are
human and has the ability to perjury themselves in court.
State of Maryland vs ADAM LEWELLEN, officer A Baltimore City police detective who
lied about a fictitious controlled narcotics purchase to get into a victim's home was
sentenced. On March 27, 2014, appellant pled guilty to one count of perjury and one count of
misconduct in office.
See 42 U.S.C 1983 Civil action for deprivation of rights
In part, Police will commit perjury to further the prosecution of a citizen by adding
inculpatory "evidence" to better secure a conviction," to gild the lily of police conduct, or merely
to sanitize the record of uncomfortable facts. Put most broadly, as long as a police officer's use of
power and fulfillment of responsibilities is reviewed (whether by courts, government agencies or
supervisors), and as long as such reviews are deemed by the officer as creating legal
impediments to more immediate goals, he will have an incentive to lie. None of the incentives
and pressures for police officers to lie can be properly distinguished from the reasons many other
citizens have to falsify.
See Skolnick, supra note 16, at 42 "Perjury represents a sub cultural norm rather than an
individual aberration"; id. at 43"The policeman lies because lying becomes a routine way of
managing legal impediments-whether to protect fellow officers or to compensate for what he
views as limitations the courts have placed on his capacity to deal with criminals.
REASONS OF GRANTING THE WRIT
The U.S. Supreme Court has held that racial profiling violates the constitutional
requirement that all persons be accorded equal protection of the law. The "Guidance Regarding
the Use of Race by Federal Law Enforcement Agencies" that was issued by the U.S. Department
of Justice in 2003 states:
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"Racial profiling" at its core concerns the invidious use of race or
ethnicity as a criterion in conducting stops, searches and other law
enforcement investigative procedures. It is premised on the erroneous
assumption that any particular individual of one race or ethnicity is
more likely to engage in misconduct than any particular individual of
another race or ethnicity.
Racial profiling in law enforcement is not merely wrong, but also
ineffective. Race-based assumptions in law enforcement perpetuate
negative racial stereotypes that are harmful to our rich and diverse
democracy, and materially impair our efforts to maintain a fair and
just society.
This Court should issue a Writ of Certiorari and review this case so as to resolve and
correct their error and grant the petitioner a fair trial and fair procedural process. Under the “due
process” and “equal protection” e.g., ADA accommodations and the implicit guarantee without
depriving the petitioner rights of “life, liberty or freedom of speech.
See Whren v. United States, 517 U.S. at 813.
The right to “due process and equal protection” of the law in regards to ADA
accommodations. The Circuit Court Judge realized that the petitioner was a disabled plaintiff
had no chance of prevailing in her trial and violated the court constitutional violations (equal
protection and due process. The Petitioner were supposed to have 1 hour of court and enough
time to present her case, the Circuit Court Judge announced 15 minutes at the beginning of trial
12/16/2015. The Notice of Pending Events I was supposed to be granted 1 hour of trial.
However, the respect to the refusal of ADA accommodations the petitioner didn’t have access to
the courts which is a fundamental right.
Tennessee v. Lane the court said, “The unequal treatment of disabled persons in the
administration of judicial services has a long history, and has persisted despite several
legislative efforts to remedy the problem of disability discrimination.” The trial judge never
considered whether the plaintiff had been discriminated against right of an opportunity equal to
that of a person without a disability to litigate her claim. See Tennessee v. Lane, 541 U.S. 509,
522, 524, 529, 531, 534 (2004).
During the trial on 12/16/2015, I request that my escort Jackie Rhrone to read my letter to
the court ATTACHMENT 1I – Merceda’s letter. After the letter was read in court the Judge
was immediately defensive to my statements such as “racial profiling” and racial disparity within
the justice system. The Judge stated that he didn’t know the petitioner’s ethnicity before the
court. The Judge statement is dishonest, (1) the Judge had possession of my file which identifies
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my race and my name is “urban” “Merceda” originated from Haiti (black). After the letter was
read, the petitioner informed the Circuit Court Judge that she was “passing out” and he told her
to leave instead of ensuring that the petitioner receives a fair trial. The Judge action was
egregious after the petitioner yelled out three times that she felt like she was going to pass out
and refused to provide her medical treatment. The Judge lost his integrity and his action was
horrendous and monstrous only to abuse the petitioner’s due process. The Judge is a public
official/ and officer of the court.
According to Black's Law Dictionary a "public official" is "[o]ne who holds or is invested
with a public office; a person elected or appointed to carry out some portion of a government's
sovereign powers." "Public officer" is defined in a similar way.
The terms "public officials" and "public officers" are interchangeable. Nationally “injured
or ill” black citizens in the hands of public officials/ servants are unsafe especially when they
ignore the request medical aid to benefit a “conviction” or just “de-value” black lives. The
Circuit Court Judge informed the petitioner to “leave the court” demonstrating a lack of
integrity, heartless only to favor the officer to secure a conviction. The petitioner laid in the
Circuit Court in Montgomery County, MD lobby on the second floor until my escort came to
escort me out the court to get some “air”. This is the example as blacks (African Americans)
faced as we are requesting medical assistance in the presence of a public official/servant.
Barbara Dawson, Ralkina Jones, Raynetta Turner, Freddie Gray and Eric Garner who died in the
hands of public officials/servants who didn’t value their life because of their ethnicity. Judge
Debelious III demonstrate this bias and prejudicial behavior questions his ethics, integrity and
bias actions against the petitioner.
MARYLAND CODE OF JUDICIAL CONDUCT Section B 1.2 (a) 2.2 -2.3 Further, a judge
“shall act at all times in a manner that promotes public confidence in the independence, integrity, and
impartiality of the judiciary.”

Judge Debelious III, Administrative Judge for Circuit Court Montgomery County, MD a
leader of the court should undertake the exercise of self-examination to identify actual prejudice,
discrimination, and practices that appear to be discriminatory. This exercise is also salutary in
and of itself. Effective outreach and a willingness to listen and self-examine bring diversified
people into the system and create a confidence in the interest, concern, and goodwill of the
system. As a leader, he must be ready to work together to redesign those aspects that have
operated in a discriminatory, exclusionary, or otherwise unfair way. Equally important are the
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affirmative commitments, not just to eliminate the outcroppings of bias, but also to make justice
equally available, fair, and impartial.
Judges can abuse their power when there is no consequence because of absolute
immunity for discriminatory actions. Another issue, Maryland Judicial disabilities board is
identical to internal affairs they (all) are co-workers and dominated by white males.
ANTHONY QUINTIN KELLY, #352736 PLAINTIFFS, V. JOHN W. DEBELIUS
LORETTA E. KNIGHT DIANNA K. SCHAEBERLE DEFENDANTS,
CIVIL ACTION NO. AW-10-2363
UNITED STATES DISTRICT COURT, D. MARYLAND
SEPTEMBER 3, 2010
Judge Debelius and the court staff were accused for “deceptive and dishonest” pattern of practice
against litigants. He was accused of violating a plaintiff’’s civil rights acting “above the law”
abusing and taking advantage the “immunity clause”. The immunity clause for Judges were
created to ensure that a judge can be “fair and impartial”. However, some Judges uses their
position in power for political favors, support their biases, and oppress litigants for personal
causes. However, Judge Debelius is otherwise entitled to absolute immunity for judicial actions.
See Stump v. Sparkman, 435 U.S. 349. 356-57(1978) Pressley v. Gregory, 831 F. 2d 514 (4th Cir.
1987) Court clerks likewise enjoy derivative (absolute) immunity when they are acting in
obedience to a judicial order or under the court's direction. See Mc Cray v. Maryland, 456 F2d
1(4th Cir. 1972): Lockhart v. Hoenstine, 411 F. 2d 455 (3rd Cir. 1969).
The Circuit Court Judge acknowledges that the petitioner is impaired and requested ADA
accommodations for trial 12/16/2015 when ADA wasn’t executed, I requested a postponement of
the trial. However, the Judge maliciously violated my “due process” and “equal protection”
clause ADA accommodations. I became ill during the trial and the Judge knew my inability to
cross-examine the State Trooper, only to favor the Trooper. The Circuit Court Judge didn’t invite
all my medical experts, however, violate the “privacy act” and instructed the clerk to call my
doctor’s offices. He refused to invite the court’s disability coordinator to advise him on the
effects of the plaintiff’s condition the ability to litigate her case. The judge denied the
postponement motion on the eve of court on 12/15/ 2015 and during trail in a way suggestive
failure to understand the petitioner’s illness and disregarded the physical and mental
impairments; including the psychologist who explain in her letter why I couldn’t move forward
with the case; the Judge deny the truth. After going through the disability coordinator and the
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judge, the accommodations were not forthcoming; I couldn’t consider filing a motion for
declaratory relief asking the court to declare what must be done to comply with the ADA for the
trail date 12/16/2015.
Judges who have been giving the wink and nod to questionable police testimony, who
have been working with an improper (and frankly illegal) presumption in favor of police witness
credibility, must change both practice and perspective. One of the strongest reasons that police
lie in court is the simple fact that judges allow them to get away with it. The wink and the nod
convey many messages-either that the judge is politically hamstrung and so cannot afford to
confront the lies or that the judge defers to the police witness, knowing that confronting the lie
aids the defendant or most disturbingly, that the judge actually approves of the lie.
United States v. Bayless [11l, 921 F. Supp. 211 (S.D.N.Y. 1996), where after months of political
fallout and calls for the Judge's impeachment.
Judge W. Kennedy Boone III who was driving and received a DUI, however, his
punishment was less severe than a citizen who is charged with a DUI. Another Judge Bryant
Cochran 11th US Court abused his power and cannot be sued due to judicial immunity; Judges
takes advantage with this clause “Judicial Immunity”.
The State of Maryland Courts must improve “access to justice” and diminished
discrimination which continues to threaten equality within the judicial system. Instances of bias
include, but are not limited to, bias towards an individual’s gender, race and ethnicity, and sexual
orientation. Make strides toward eliminating bias in their court system through accomplishments
such as increased access to justice, improvement jury pool representation, promoting diversity in
court appointments, providing adequate interpreter services, conducting educational programs,
encouraging diversity in law enforcement, and promoting the availability of legal representation
for the poor.
Katherine Getty, State Prosecutor should avoid a conflict of interest with respect
to her official duties. A prosecutor should not permit his or her professional judgment or
obligations to be affected by his or her own political, financial, business, property, or personal
interests. The State prosecutor dismiss the case on record 12/16/2015, however, proceeded even
though the petitioner couldn’t represent due to health impairments. The Prosecutor stated in court
that there were no police report/notes for the traffic stop on 3/18/2015, the Petitioner requested
discovery November 30, 2015, & December 13, 2015.
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The Petitioner’s requests discovery on 11/7/2015, 11/30/2015 &12/13/2015; the
petitioner was refused discovery request by the State prosecutor and Lieutenant Pickett to
prepare for trial. Even though the Trooper perjured himself the State prosecutor preceded trial on
12/16/2015 without correcting the error of false testimony by the Trooper.
On 3/18/2015, there was an incident report regarding the traffic stop. Trooper Knowles
neither refuse to identify himself nor was his identity exposed on the ticket. Therefore, with the
assistance of a Montgomery County legislative council, the petitioner contacted the Troopers’
superior Sgt Burton #0407 who supplied the petitioner’s name and identification. His refusal
only indicates “deception” during the traffic stop on 3/18/2015; that he did not want me to report
him. By the Trooper’s own testimony 7/24/2015 in District Court indicates that there was an
incident during the traffic stop on 3/18/2015. On 4/9/2015, I reported the traffic stop
incident/police misconduct against the Trooper who refused to give me his name during the
traffic stop on 3/18/2015; how I was stopped is questionable which caused me “anxiety” and
“fear”. On 4/10/2015, the petitioner reported to the State Attorney General office concerning
intimidating retaliatory calls from State Trooper’s main office therefore, the petitioner was
retaliated for filing a complaint against the Trooper. I believe the court, Trooper office, Internal
Affairs and State prosecutor’s desire to suppress the Trooper’s behavior and deception
concerning the traffic stop 3/18/2015.
Police officers have the ability to lie to expected to omit, redact and even lie on their police
reports sworn or unsworn; they will conceal or misrepresent to cover up corruption and
brutality. They are trained to deceive during investigations as part as good police facts and
even lie to cover up the misconduct of fellow police officers See Chi & Wells supra 7the effects
of the “blue wall of silence” in covering up police misconduct.
Katherine Getty, a Maryland State prosecutor who is in charged with responsibility for
prosecutions in its jurisdiction supported actions violating my civil rights to due process
especially if she tried to suppress my testimony concerning the egregious actions of the State
Trooper/ and officials. The State prosecutor suppose to acted as an administrator of justice, an
advocate, and an officer of the court; the prosecutor must exercise sound discretion in the
performance of his or her functions. She requests to dismiss the case because she agreed that the
Petitioner couldn’t represent due to health impairments. However, to cooperate with corruption
from others she proceeded to ensure a conviction not to seek justice, however merely to convict
and to violate the Petitioner’s civil rights/due process. As part of the prosecutor’s job is to ensure
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to seek to reform and improve the administration of criminal justice, especially when
inadequacies or injustices in the substantive or procedural law come to the prosecutor's attention,
he or she should stimulate efforts for remedial action. She refused to act against her own witness
Officer Knowles and the Judge. The Trooper perjured in court his testimony stating that the
petitioner was “speeding” to pass a black car. However, the officer’s testimony in District Court
7/24/2015 was different the Trooper perjured himself and by admission “wrote notes”
concerning the traffic stop on 3/18/2015. However, the State prosecutor and State Trooper
Lieutenant Pickett suppressed the officer’s notes and refusing my discovery request. The State
Prosecutor discovery request was sent 12/6/2015 however requested information “no later than
30 days before the 1st scheduled trial date” which is 10/18/2015. The State prosecutor knows it’s
impossible to comply with her request which the Petitioner find offensive.
ATTACHMENT III- Discovery requests by the State Prosecutor.
For instance, police lying is no "dirtier" than the prosecutor's encouragement or conscious
use of tailored testimony or knowing suppression of Brady material; it is no more hypocritical
than the wink and nod of judges who regularly pass on incredible police testimony and no more
insincere than the demagogic politicians who decry criminality in our communities, but will not
legislate independent monitoring of police wrongdoing.
In Brady v. Maryland, the Court held "that the suppression by the prosecution of evidence
favorable to an accused upon request violates due process where the evidence is material either
to guilt or to punishment, irrespective of the good faith or bad faith of the prosecution." In that
case, the prosecution had suppressed an extrajudicial confession of defendant's accomplice that
he had actually committed the murder. "The heart of the holding in Brady is the prosecution's
suppression of evidence, in the face of a defense production request, where the evidence is
favorable to the accused and is material either to guilt or to punishment. Important, then, are (a)
suppression by the prosecution of a request by the defense, (b) the evidence's favorable character
for the defense and (c) the materiality of the evidence.
According to the American Bar Association, Prosecutor’s Standard 3-1.5 : Duty to Respond to
Misconduct (Maryland Rules )
See Brady v. Maryland & U. S v. Agurs
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The Petitioner is requesting a dismissal because she became sick and had to hear the trial
over a court taping. The Petitioner never received a fair trial under Constitution “freedom of
speech” “equal protection” and “due process”; violating her right to speak about racial
disparity/profiling, cross-examine the prosecutor’s witness and her impairments respectfully
gave her the inability to stand trial. ADA accommodations were approved however not executed,
Trooper perjured in court and the Circuit Court Judge abused his fiduciary powers with bias,
egregious behavior full of dishonesty violating the petitioner’s medical privacy, refused to call
medical assistance, refused to allow the petitioner’s access to Circuit Court. Even though the
State prosecutor (with the court taped) admit that I was too ill to stand trial, she refused to act to
ensure the Petitioner have the discovery requests. The Petitioner became ill and the Judge
promoted an unsafe environment; the Circuit Court Judge unfairness and lack of care caused the
petitioner anxiety.

CONCLUSION
WHEREFORE, the Petitioner respectfully requests that this Court grants this Petition for
Writ of Certiorari.

Respectfully

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________________
Merceda D. Gooding
Pro Se Litigant
FONT: Times New Roman 12
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 13th day of January 2016, a copy of the foregoing
Petition was mailed postage prepaid to:

Brian Frosh
Attorney General
Office of the Attorney General
200 Saint Paul Street
Baltimore, MD 21202

Katherine Getty
State’s Attorney
for Montgomery County
50 Maryland Avenue
Rockville, MD 20850

Respectfully Submitted,
________________
Merceda D. Gooding
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Pro Se Petitioner

ATTACHMENTS
1. ATTACHMENT I - Traffic ticket no identity of the Trooper
2. ATTACHMENT II -Merceda’s letter
3. ATTACHMENT III - Discovery requests by the State Prosecutor.
4. DOCKET ENTRIES, CASE NUMBER 127795

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“A justice system which tolerates injustice is doomed to collapse- Leonard Noisette, Former
Director Harlem”

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