Demetric Simon v. Officer Keith Gladstone, et al.
SocialSecurity DueProcess FourthAmendment CriminalProcedure Securities Privacy
In a now proven criminal conspiracy framing Petitioner but likely undiscoverable before Federal indictment on Conspiracy to Deprive Civil Rights, should a plausibly plead and argued "Equitable Tolling," "Equitable Estoppel," 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 defense?
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).
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 Reported 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 Bromwich explained based on other public and sealed records, over 200 interviews with public officials and police personnel, explaining the extraordinary fraudulent, perjurious, and unconstitutional lengths both generally and specifically involving Petitioner, but which the trial Court noted she would "not consider" this Report attachment as "way too long[…]."
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