Talitha Lacey Combs, aka Talitha Lacey Randall v. Urban Restaurant Group, et al.

When the bias, prejudice, or partiality against a pro se Plaintiff is based on either her pro se status or her previous whistleblowing activities against the court and the State Judicial System; and that bias, prejudice, or partiality against the pro se Plaintiff extends to every level of the State Judicial System and every member of the State judiciary so that a motion for disqualification is unhelpful; and there is no diversity jurisdiction or federal question in the claims, how is the Plaintiffs Constitutional right to an independent and impartial tribunal for any or all future claims made in her home state guaranteed?

If precedent indicates that the motion to dismiss at issue below for insufficiency of service was a sham or frivolous motion based on the rules delineated in precedent; and if the Plaintiff (also the Petitioner here) argued below that the motion to dismiss for insufficiency of service was a sham or frivolous motion, granted only in the particular court’s interest of denying (specifically) Plaintiff-Petitioner’s Constitutional right to be heard due to its past involvements with her or due to a general disregard of claims from pro se litigants; and if counsel for Defendants-Respondents admitted upon conferral that the motion to dismiss for insufficiency of service was a sham or frivolous motion: an argument preserved from below; then why did the court err in granting the sham, frivolous motion, in apparent targeted, and intentional violation of the particular Plaintiff-Petitioner’s Constitutional right to the opportunity to be heard by an impartial tribunal under the 5th, 6th and 14th Amendments?