Helga G. Suarez Clark v. Republic of Peru, et al.

l.USCA(case 20-7119) erroneously denied court appointed counsel aledging case did not have merits but chief judge Colleen Me Mahon NYSD court(case 18-01740) judged it had merits and transferred it to DC june 13 2018.Since then my complaints keep getting dismissed because of mere formalities and presentation instead of merits so obviously I do need court appointed counsel. 2.USCA did not correct the errors of DC district judge K.Brown J.,without considering the text of the complaint I indicated had filed 2 days before the last day of main claim(tentative of extrajudicial killing personal injuries,torture)accrued on february 28 2008,so that if i refile a new case as she asks,the statute of limitation will be barred and amounts to a dismissal with prejudice.So USCA should have ordered admitting my complaint because of res judicata. 3.Errors of district judge DC Brown(case 20cv3111): affirming that the complaint”is 133 pp long so neither short nor plain” has no value because FRCP art 8 and others doesn’t set a limit on length of the complaint ,only it must include “a short and plain statement of the claim showing that the pleader is entitled to relief, “which it did,despite the court of appeals claims that not for which reason I include a copy of the whole complaint for You to see for Yourself.This was overlooked by USCA,ordering ” that the district court's order filed November 20 2020 be affirmed.The district court correctly concluded .. .”,as USCA overlooks the arguments in my appeal because on page 6 of my brief,I had mentioned that on p.95 of my pleading there was a chapter “short and plain statement of claims”,and that on p. 125 of my pleading there was a chapter”Plaintiff claim for relief’; on p.6 of my brief I demonstrated this and that’’A 25 PP.AMENDED COMPLAINT,AS RESUME,MAY BE FOUND ON DOCKET DC CIRCUIT 18 1460,FILING 12 17 2018)violating res judicata (collateral estoppel)in june 13 2018 transfer order from C.Mc Mahon chief judge(l 8cv01740) that already admitted it on merits. 4.USCA did not correct District judge BROWN aledging wrongly on p.2 of attached memo November 30 2020”Plaintiff is a resident of Peru, who has sued the Republic of Peru and Peruvian officials for sweeping misconduct.”which is a banalization of the case,that is a complaint,as of civil cover sheet, for nature of suit Personal injuries from terrorism and torture resting on the Antiterrorism Act and Torture Victim Protection Act. -3-