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THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF INDIANA

Kay Kim,
Plaintiff, )
)
v. )
) Cause No. 1:08-cv-1644-SEB-DML
State of Indiana Attorney General, et al. )
Defendants. )

NOTICE OF JOINDER OF REQUIRED PARTIES


DEFENDANT STATE OF INDIANA

I, Plaintiff, Kay Kim, Pro Se filed her Notice of Joinder of Required Parties Defendant
State of Indiana pursuant R19(a)this 31st day of March, 2009 and as one entity and joinder of
claims and remedies pursuant to R18 as follows and not limited to:

1. Party: Indiana Civil Court Judge Theodore M. Sosin, Commissioner Richard


Gilroy, the clerks who signed State’s witness in the Indiana Criminal Case against Plaintiff, Kay
Kim, Pro se of this suit in “Trespass” charge in city county building.

(a) Service or process address: (ref. cause no. 49F15-0606-CM-112139)

Judge Theodore M. Sosin


W-506 City-County Building
200 E. Washington Street
Indianapolis, Indiana 46204
Phone: (317) 327-4010
Fax: (317) 327-4473
Clerk: (317) 327-4009

2. Party: Arresting Officers Melvin Clayton & officer ? in the case above line 1.

(a) Service or process address: (ref. cause no. 49F15-0606-CM-112139)

Officer Melvin Clayton


50 N. Alabama St.,
Indianapolis, IN 46204

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FED1 Notice ofJoinder ofRequired Parties R19(1)Required Party
IN #1Judge Sosin Clerks C15Clerk-bailiff F8Clerks Prosecutors IN Judges 31Mar09
3. Party: Arresting officer Ryan J. Romeril, IMPD James Waters, (4250 #3) Patricia
Ladenthin & (4250 #4) Linda Handlon of case# 49F08-0607-CM-140781.

(a) Service or process address: (ref. case#49F08-0607-CM-14078)

Officer Ryan J. Romeril IMPD


50 N. Alabama St.,
Indianapolis, IN 46204

4. Party: Northwest District prosecutor(s)

(a) Service or process address: (ref. Cause# 49F080505CM-083990,


49F150606CM-112139, 49F080607CM-14078, 49F080811CM-
254608)
Northwest District Prosecutor’s Office
3821 Industrial Blvd.
Indianapolis, IN 46254

5. On that day, Judge Sosin acted as an office manager capacity which is not
immune from prosecution and certainly civil responsibility to the Plaintiff Kay Kim, Pro Se of
this suit.

6. Judge Sosin’s court acted as one entity engaged in criminal/Gestapo tactic


against Plaintiff of the Indiana civil suit CAUSE NO. 49D01-0604-PL-0013949 to help
conspiringly &/or individually corroboration with the Defense counsel for Defendant(s) to
win the lawsuit at any and all costs. Such as, and not limited to:

(a) prevent me from filings, got rid of the files, miss placed files, told the lie
that I did not filed, told the lie about that I did not enclosed self
address envelopes and postages. I had to file same thing 2nd, 3rd,
and 4th times because they didn’t receive it.

(b) Because of their hostility, lies and arrogance over the phone, I try to avoid
going in the court clerk’s office to file and I had gut feeling that
they will lie against me and make me a criminal just like my
neighbors. But, I could not give up; because, it is just more than a
money. It is money + my civil rights as an equal human being & dignity. I
am myself. My rights are no less important and meaningless.

(c) I went twice to file in the clerk’s office. They called the police on me both
times. First time visit to clerk’s office was on Friday; the clerk was
complaining that I have too much filings & take too long to file.
They called the Police on me. Police was yelling/shouting on top of her
lung and out loud while I was filing to tell me to hurry up and get out. I
saw other came to clerk’s office using stamp from the clerk’s desk and
stamping themselves own documents. Since, the clerks complaining so
much and called the police while she was stamping my documents
on the first visit, I try to please her by stamping myself like other and took
the stamp from the clerk’s desk and stamping my own documents to
hand to her with stamped documents. So, she can’t complaint nor
calls the police. But, she still upset whatever reason(s) and lied and they
call the police on me 2nd time. Another clerk came out snatched
stamp out of my hand shouting like maniac. Two police and the Judge
Sosin came in the clerk’s office while I was filing and Judge Sosin
talked aloud with top of his lung and ordered the two police to take
me out of the city county building.

(d) The bailiff ordered me to file CMP on her own without the Judge’s order.
They are liars. So, I filed a paper with the court to verify bailiff’s
order whether Judge Sosin ordered me to file a CMP or not. I simply
wrote that I will file a CMP if it is ordered by the Judge but, I never got a
response. Maybe, there is a memo that I didn’t know about that the
bailiff can order me to file or not to file whatever. Besides, Indiana
Local Rule, there should be a preliminary conference take place
between / among the Plaintiff and the Defendant’s counsel(s) in order for
preparation of the CMP in writing. Indiana State’s CMP is very
simple and easy as shown in the local rule which matter of consenting a date for
this and that. It’s not the issue of not knowing how but their unruly
behavior that I had to verify.

(e) Commissioner Richard Gilroy enclosed own letter addressed to me when


the court sent/mailed back me my supposedly “missing files” after
the lawsuit Indiana Civil cause no. 49D01-0604-PL-0013949 was
dismissed in it, that I will be incarcerated because of my …?
behavior…- in the clerk’s office…..

7. Constitution Supreme Clause Article VI, Clause 2 of the Constitution (This


Constitution, and the Laws of the United States which shall be made in Pursuance thereof; . . . .
shall be the supreme Law of the Land. When a judge acts intentionally and knowingly to deprive
a person of his constitutional rights he exercises no discretion or individual judgment; he acts no
longer as a judge, but as a " minister" of his own prejudices. [386 U.S. 547, 568]. A judge is
liable for injury caused by a ministerial act; to have immunity the judge must be performing a
judicial function. See, e. g., Ex parte Virginia, 100 U.S. 339 ; 2 Harper & James, The Law of
Torts 1642-1643 (1956). The presence of malice and the intention to deprive a person of his civil
rights is wholly incompatible with the judicial function. When the state in the instant case is one
of the perpetrators and violators, there can be no expectation of just, indeed any, relief from it.

8. Marion Superior Court is under the authority of IC 33-33-49.

9. The entity-ln1 thru ln4 are subject to service of process and their joinder will not

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FED1 Notice ofJoinder ofRequired Parties R19(1)Required Party
IN #1Judge Sosin Clerks C15Clerk-bailiff F8Clerks Prosecutors IN Judges 31Mar09
deprive the court of subject-matter jurisdiction in accordance with the law.

10. In the absence of entity-ln1thru ln4, the court cannot accord complete relief
among existing parties.

11. The enityt-ln1 thru ln4 are an interest relating to the subject of the action and is so
situated that disposing of the action in the entities’ absence may:

(i) as a practical matter impair &/or impede the Plaintiff’s ability to protect
that interest.

(ii) leave an existing party subject to a substantial risk of incurring double,


multiple, or otherwise inconsistent obligations because of the
interest.

Respectfully submitted,

Dated: April 02, 2009 /s/ kay kim _


Kay Kim, Pro Se

DISTRIBUTION:

Chief Judge David F. Hamilton.


Judge Larry J. McKinney
Judge Sarah Evans Barker.

CERTIFICATE OF SERVICE

I do hereby certify that a copy of the foregoing to the lists were delivered &/or mailed by first class U.S.
Mail, postage prepaid no later than April 06, 2009.

Nicole R. Kelsey & Jonathan Lamont Mayes


Assistant Corp. Counsel, Office of Corporation Counsel & Chief
200 East Washington St., Room 1601
Indianapolis, IN 46204

Kathy J. Bradley
Deputy Attorney General
Office of the Indiana Attorney General,
Indiana Government Center South, Fifth floor,
302 West Washington St.,
Indianapolis, IN 46204,

James A. Edgar
Attorney, J. Edgar Law Office, Prof. Corp.,
1512 N. Delaware St.,
Indianapolis, IN 46202
/s/ kay kim
Kay Kim,
Pro Se Plaintiff
4250 Village Pkwy cir e unit 2, Indpls., IN 46254
Ph# 317-641-5977, e:spchiefeatapple@gmail.com