Courts are required to respect the Constitutional rights of
all persons. In November 2020 Petitioner filed complaint
in D.C. Superior Court alleging common law torts.
Respondents removed to federal court which remanded
in 2022. D.C. Superior Court denied 'with prejudice'
determining Respondents' functional immunity under
IBRD's Articles (an international treaty) deprived it of
subject-matter jurisdiction. Petitioner appealed. The D.C.
Court of Appeals affirmed on October 25, 2024.
Certiorari is sought because the D.C. Court of Appeals'
refusal to: allow proper appeal, follow procedural
requirements, and correctly apply legal principles and
federal law, and so refusal to correctly determine subject-
matter jurisdiction, denies Petitioner's Constitutional
rights to due process, to be heard, and to bring legal suit
when her rights are violated.
This court's writ is equally sought because the decision
usurps Congress's powers, so fails to observe separation-
of-powers, as the court purports to create a new absolute
immunity, oversteps the boundaries of judicial authority
and Congressionally-imposed jurisdictional limits and,
politicizes and weaponizes the justice system and courts,
and claims to create new legal rights or broaden existing
rights, dangerously, of both international organizations
and those working for them. A right reserved for
Congress, and the international parties to the treaty.

1. Whether a writ of certiorari is appropriate because,
contrary to the judgement of the District of Columbia
Court of Appeals and its holding, the court's
determination resulted from failure to carry out its
judicial duty to establish its jurisdictional authority under
applicable legal principles, including federal law where
applicable, not District of Columbia law, which in turn
requires international law considerations and principles
be applied in interpreting the body of law under which the
court determined it lacked jurisdiction (an international
treaty, the Articles of Association of the International
Bank for Reconstruction and Development ('IBRD') ). And
the District of Columbia Court of Appeals creation of a
new absolute immunity for persons claiming to be acting
in 'official capacity' for IBRD's 'purposes' (without
evidence or factual underpinning of such jurisdictional
facts which were in dispute) is unlawful judicial use of a
power reserved for Congress alone, and legal error, and
amounts to refusal to carry out the court's judicial duty to
respect the right of persons in this land to bring suit for
state law violations committed in the District of
Columbia.

2. Whether writ of certiorari, or other relief, is required
because the District of Columbia Court of Appeals, its
highest court, erred in failing to correct, and restrain, the
District of Columbia Superior Court's abuse of its powers,
and abuse of its discretion, denial of jurisdictional
discovery and refusal to properly use accepted legal
norms to evaluate and establish jurisdiction, and violation
of the Petitioner's Constitutional due process rights at
law. And whether in turn the District of Columbia Court of
Appeals violated those same due process rights in the
manner that proceedings in that court were conducted.

Whether the District of Columbia Court of Appeals erred in determining subject-matter jurisdiction and creating a new absolute immunity for IBRD officials, thereby violating the petitioner's constitutional due process rights