UNITED STATES BANKRUPTCY COURT FilEO

SOUTHERN DISTRICT OF NEW YORK , : c:. BAN:rnuPrcy COURT

-----------------------------------x -:,,,111 ~•r' ?b
) LU.'.. '1 t h,,) _
A 9: 35
)
) c.o. 0. • h I •

IN THE MATTERS OF ) INDEX NOS. 23-22095, 23-11805

)
)
RAHUL MANCHANDA, ) NOTICE OF MOTION FOR CONTEMPT OF
MANCHANDA LAW OFFICE PLLC ) COURT AGAINST US COURT OF APPEALS
) SECOND CIRCUIT JUDGE ALISON NATHAN,
) RICHARD LOHIER, AND JOSEPH BIANCO
-----------------------------------x
PLEASE TAKE NOTICE that upon the annexed aff i rmation of Rahul Manchanda duly
affirmed the 25th day of August 2024, the annexed Memorandum of Law and
Exhibits, and all the Pleadings and Proceedings heretofore had herein, the
Undersigned will move this Honorable Court at US SDNY Bankruptcy Court, 300
Quarropas Street White Plains, NY 10601-4150 on September 12, 2024 at 2:30
PM or at a mutually agreeable time and place for an order holding US Court
of •Appeals for the Second Circuit Judges Alison Nathan, Richard Lohier, and
J o seph Bianco in Civil and Criminal Contempt of Court pursuant to U.S .
Federal Bankruptcy Law for repeated and willful violations of the Stay
pursuant to 111 U.S.C. § 362, and the following:

1. On the grounds that as per the attached, even though these people know
that a Stay exists, but anyway they still continue to willfully fail
to comply with this Honorable Bankruptcy Court through the Automatic
Stay pursuant to 111 U.S.C. § 362 and Protection of this Honorable
Court by continuing to engage in issuing monetary claims and threats,
intimidation, harassment, mockery, verbal abuse, orders, judicial
misconduct, judicial bias, and judgments in violation of the stay, all
the while threatening, harassing, intimidating, litigating, ordering,
collecting, and otherwise violating federal the bankruptcy protection
and the stay and the orders of this federalj court;

2. On the ground that even though they repeatedly received written and
electronic Notice of Chapter 7 Bankruptcy Filings for cases 23-22095
and 23-11805, they continue to engage in threatening, harassing,
intimidating, litigating, ordering, collecting, and otherwise violating
federal bankruptcy protection and the stay;

3. On the grounds that nothing less than sanctions, penalties, fines, and
incarceration will persuade them to comply with this Honorable Court's
Automatic Stay and Protection from continuing to engage in threatening,
harassing, intimidating, litigating, ordering, collecting, and
otherwise violating federal bankruptcy protection and the stay;
4. On the grounds that if they are not forced to comply with this
Honorable Court's Automatic Stay and Protection from continuing to
engage in threatening, harassing, intimidating, litigating, ordering,
collecting, and otherwise violating federal bankruptcy protection and
the stay, then they will have reduced federal bankruptcy protection to
a shambles;
'
5. On the grounds that their willful and intentional noncompliance with
the Automatic Stay and Protection proh'ibi ting their continuing to
engage in threatening, harassing, intimidating, litigating, ordering,
collecting, and otherwise violating federal bankruptcy protection and
the stay, and otherwise aggressive disregard foi federal bankruptcy
protection of this Honorable Court they will have defeated, impaired,
impeded and prejudiced Debtor's rights;

6. And for such other further relief as this Honorable Court deems just
and proper, including contempt, costs, penalties, fines, incarceration,
and sanctions against them for willful violations of U.S. Federal
Bankruptcy Law, willful violations of the Stay pursuant to 111 U.S.C.
§ 362, and in light of the information contained herein.

Dated: August 25, 2024 ~~~~

New York, NY Rahul Manchanda, Esq.
Manchanda Law Office PLLC
270 Victory ~oulevard
New Rochelle, New York 10804
Tel: (212) 968-8600
Fax: (212) 968-8601

To: US Court of Appeals Second Circuit Judges Alison Nathan, Richard

Lohier, Joseph Bianco located at 40 Foley Square, New York NY 10007
UNITED STATES BANKRUPTCY COURT
SOUTHERN DISTRICT OF NEW YORK
-----------------------------------x
)
)
)
IN THE MATTER OF ) INDEX NOS. 23-22095, 23-11805
)
)
RAHUL MANCBANDA, ) AFFIRMATION IN SUPPORT OF
MANCBANDA LAW OFFICE PLLC ) MOTION FOR CONTEMPT
)
)
-----------------------------------x
STATE OF NEW YORK }
:ss
COUNTY OF WESTCHESTER }

RAHUL MANCHANDA, an Attorney duly licensed to practice law in the State of

New York, affirms the following to be true under penalty of perjury:

1. I make this Affirmation in support of this Motion for Contempt of

Court against US Court of Appeals for the Second Circuit Judges Alison
Nathan, Richard Lohier, and Joseph Bianco in all respects based upon
my personal knowledge of the facts and experiences I relate herein and
based upon information and belief, based on the contents of the file.

2. On the grounds that as per the attached, even though they knew that
a Stay exists, but anyway they still continue to willfully fail to
comply with this Honorable Bankruptcy Court through the Automatic Stay
pursuant to 111 U.S.C. § 362 and Protection of this Honorable Court
by continuing to engage in issuing monetary claims and threats,
intimidation, harassment, mockery, verbal abuse, orders, judicial
misconduct, judicial bias, and judgments in violation of the stay, all
the while threatening, harassing, intimidating, litigating, ordering,
collecting, and otherwise violating federal the bankruptcy protection
and the stay and the orders of this federal court;

3. On the ground that even though they repeatedly received written and
electronic Notice of Chapter 7 Bankruptcy Filings for cases 23-22095
and 23-11805, they continue to engage in threatening, harassing,
intimidating, litigating, ordering, collecting, and otherwise
violating federal bankruptcy protection and the stay;

4. On the grounds that nothing less than sanctions, penalties, fines, and
incarceration will persuade them to comply with this Honorable Court's
Automatic Stay and Protection from continuing to engage in
threatening, harassing, intimidating, litigating, ordering,
 collecting, and otherwise violating federal bankruptcy protection and
the stay;

5. On the grounds that if they are not forced to comply with this
Honorable Court's Automatic Stay and Protection from continuing to
engage in threatening, harassing, intimidating, litigating, ordering,
collecting, and otherwise violating federal bankruptcy protection and
the stay, then they will have reduced federal bankruptcy protection
to a shambles;

6. On the grounds that their willful and intein tional noncompliance with
the Automatic Stay and Protection prohibiting their continuing to
engage in threatening, harassing, intimidating, litigating, ordering,
collecting, and otherwise violating federal bankruptcy protection and
the stay, and otherwise aggressive disregard for federal bankruptcy
protection of this Honorable Court they will have defeated, impaired,
impeded and prejudiced Debtor's rights;

7. And for such other further relief as this Honorable Court deems just
and proper, including contempt, costs, penalties, fines,
incarceration, and sanctions against them for willful violations of
U.S. Federal Bankruptcy Law, willful violations of the Stay pursuant
to 111 U.S.C. § 362, and in light of the information contained herein;

WHEREFORE, it is respectfully requested that this Motion be granted in all

respects together with such other and further relief as this Honorable
Court deems to be just and proper, including contempt, costs, penalties,
fines, incarceration, and sanctions against Defendants for violation of
U.S. Federal Bankruptcy Law, willful violations of the Stay pursuant to 111
U.S.C. § 362, and in light of the information contained herein.

Dated: August 25, 2024 ~/~

New York, NY Rahul Manchanda
 CERTIFICATE OF SERVICE
On August 25, 2024, I, Rahul Manchanda, served a copy of this Motion for
Contempt of Court and any attached pages to US Court of Appeals for the
Second Circuit Judges Alison Nathan, Richard Lohier, and Joseph Bianco
located at 40 Foley Square, New York NY 10007 via Electronic and U.S. Mail,
and Facsimile.

~df'#'6--
By: Rahul Manchanda, Esq.
Manchanda Law Office PLLC
27 0 Victory Boulevard
New Rochelle, New York 10804
Tel: (212) 968-8600
Fax : ( 212 ) 9 6 8 - 8 6 0 1
 From: Rahul Manchanda, Esq. rdm@manchanda-law.com
Subject: Re: NEW CLAIM - DECISION AND MONETARY SANCTION
Date: Aug 25, 2024 at 6:33:21 AM
To: claims@guard.com, 15708250611@efaxsend.com,
civilcases@ca2.uscourts.gov, newcases@ca2.uscourts.gov,
prosecases@ca2. uscou rts .gov, efilerhel pdesk@ca 2. uscourts.gov,
cit_mgmt@ca2.uscourts.gov
Cc: Ashley@l2ins.com, 16169401196@efaxsend.com, Torrance, Benjamin
(USANYS) Benjamin.Torrance@usdoj.gov, Gitlin, Adam (USANYS)
Adam.Gitlin@usdoj.gov, Lawrence Ill, David
David. Lawrence! Il@ag.ny.gov, stephanie.costa@ag.ny.gov, Elizabeth
Stillings ESTILLIN@traveters.com, krayford@travelers.com, Pat Kroll
PKROLL@travelers.com
Bee: Rahul Manchanda, Esq. rdm@manchanda-law.com, Law Office
Manager Sylwia Manchanda sylwia.manchanda@manchanda-law.com

Dear Travelers Insurance Employee Dishonesty Program:

Please also see the below and attached NEW CLAIM NO F1L6139 submitted online
under our former EMPLOYEE DISHONESTY PROGRAM POLICY for me getting
blamed and a threat of monetary sanctions claim against me for legal work that they
did on past cases cited by US Court of Appeals 2nd Circuit Judges Alison Nathan,
Joseph Bianco, and Richard Lohier.

I also attach our 2 pending chapter 7 bankruptcy notices with automatic stays for me
personally in SONY Bankruptcy Court case index 23-22095 and the law firm in
SDNY Bankruptcy Court case index 23-11805, cc'ed to the Trustees as well.

Please urgently process as they are only giving me 30 days to respond to their claim
order dated August 14, 2024 which I only just received yesterday by mail (I moved
out of that office address 2 months ago and notified the court clerks in writing of our
new address but they still sent it to the old address).

New York Southern Live System https://nysb-ecf.sso.dcn/cgi-bin/NoticeOtFiliq.pm 18:

United States Bankruptcy Court

Southern District of New York

Notice of Bankruptcy Case Filing

A bankruptcy case concerning the debtor(s) listed below
was filed wider Chapter 7 of the United States Bankruptcy
Code, entered on 11/13/2023 at 1: 13 PM and filed on
11/13/2023.

Mancbanda Law Office PLLC

30 Wall St
FL8
New York, NY 10005-2205
Tax ID I EIN: 45-4661951

The case was filed by the debtor's attorney: The bankruptcy trustee is:

Rabul Mancbanda Salvatore LaMonica

30 Wall St LaMonica Herbst & Maniscalco, LLP
8th Floor 8207 3305 Jerusalem Avenue
New York, NY 10005 Wantagh, NY 11793
(212) 968-8600 (516) 826-6500
The case was assigned case number 23-11805-shl to Judge Sean H. Lane.
In most instances, the filing of the bankruptcy case automatically stays certain collection and other actions
against the debtor and the debtor's property. Under certain circumstances, the stay may be limited to 30 days or
not exist at all, although the debtor can request the court to extend or impose a stay. If you attempt to collect a
debt or take other action in violation of the Bankruptcy Code, you may be penalized. Consult a lawyer to
determine your rights in this case.

If you would like to view the bankruptcy petition and other documents filed by the debtor, they are available at
our Internet home page http://ecf.nysb.uscourts.gov or at the Clerk's Office, One Bowling Green, New York,
NY 10004-1408.
You may be a creditor of the debtor. If so, you will receive an additional notice from the court setting forth
important deadlines.

,,::.ft, £"'4,,.., __ _
 Yn.u ucaua•
Clerk, U.S. Bankruptcy Court

I of2 ll/13/2023. 1:.35 Pl

NOTICE OF BANKRUPTCY
pdf I CASE NO 23-22095 FILING
106 KB

Kind regards,

Rahul D. Manchanda, Esq.

Manchanda Law Office & Associates PLLC

125 Park Avenue, 25th FloQ[
Tel: .(212) 968-86.00
Mob: .(.6.42) 645-0993
Fax: .(212) 968- 8601
Toll Free 24 Hour Hotline: .(8-5.5) 2.07- 7660
e- mail: rdm@manchanda-law.com
web: ht!~ /lmanchanda- law.com/attorneY.-Qrofiles/

Ranked amongst Top Immigration Attorneys in the United States by Newsweek

Magazine in 2012 and Top Attorneys Nationwide in 2013.

Martindale Hubbell Client Champion 2017 Silver Award Winner, 2020 Gold Award
Winner, 2020 Platinum Award Winner.

Better Business Bureau Accredited Business A+ Rating .

Association of American Trial Lawyers Top 100 In New York State.

Best Family Lawyers and Best Immigration Lawyers in New York City in 2022 as
published on ExQertise.cum

U.S. News and World Report Listed Lawyer.

Licensed New York State Real Estate Broker.

CLIENT TESTIMONIALS: httQ.S..;/f.mancha nda-law.comf.testi monia Isf.

This electronic transmission is both personal and confidential, and contains

privileged information intended only for the use of the individual or entity named
above. If the reader is not the intended recipient, you are hereby notified that any
dissemination or copying of this transmission is strictly prohibited . If there are any
problems with this transmission, or you have received it in error, please immediately
notify us by telephone and return the original transmission to us at the above
address via the U.S. Postal Service. Attention: All foreign nationals (permanent
residents and children included) are required to report any change in address within
ten (10) days to the USCIS using Form AR-11. Foreign nationals must report address
changes to the USCIS by completing this form and sending it to the USCIS. The form
can be obtained from the USCIS website at: httgs://.www.uscis.gov/.ar-11. Please also
notify our office of your new address.

Make An Online Legal Fee Payment via https://.QaYAIBY§WYMmJ/.QOS_link/.

deFP-Bu7Sv5ogk1gZhB9cQi59Yj, wire transfer, check, cash, ApplePay
(6466450993)

On Aug 24, 2024, at 7:45 AM, Rahul Manchanda, Esq. <rdm@manchanda-law.com>

wrote:
U.S. Court of Appeals 2nd Circuit Pro Se Unit Law Clerk Connie Marziega:

Please see and file our attached Letter Reply to Judicial Order Dated 08/14/2024
for Manchanda v. Reardon, No. 24-392.

Thanks,

cc: AMGuard Insurance, L2 Insurance Brokers

Kind regards,

Rahul D. Manchanda, Esq.

Manchanda Law Office & Associates PLLC

125 Park Avenue, 25th Floor
New Yorki NY 10017
Te 1: .( 212 ) 9 6 8-8 6 0 0
Mob : .( 6 4 6 ) 6 4 5 - 0 9 9 3
Fax : .( 2 12 ) 9 6 8 - 8 6 0 1
Toll Free 24 Hour Hotline: .(855) 207-7660
e-mail: rdm@manchanda-law.com
web: httP.s://manchanda-law.com/attorneY.-P.rofiles/

Ranked amongst Top Immigration Attorneys in the United States

by Newsweek Magazine in 2012 and Top Attorneys Nationwide in
2013.

Martindale Hubbell Client Champion 2017 Silver Award Winner,

2020 Gold Award Winner, 2020 Platinum Award Winner.
Better Business Bureau Accredited Business A+ Rating.

Association of American Trial Lawyers Top 100 In New York

State.

Best Family Lawyers and Best Immigration Lawyers in New York

City in 2022 as published on EXP.ertise.com

U.S. News and World Report Listed Lawyer.

Licensed New York State Real Estate Broker.

CLIENT TESTIMONIALS: httP.s://manchanda-law.com/testimonials/

This electronic transmission is both personal and

confidential, and contains privileged information intended
only for the use of the individual or entity named above. If
the reader is not the intended recipient, you are hereby
notified that any dissemination or copying of this
transmission is strictly prohibited. If there are any problems
with this transmission, or you have received it in error,
please immediately notify us by telephone and return the
original transmission to us at the above address via the U.S.
Postal Service. Attention: All foreign nationals (permanent
residents and children included) are required to report any
change in address within ten (10) days to the users using Form
AR-11. Foreign nationals must report address changes to the
users by completing this form and sending it to the users. The
form can be obtained from the users website at: httP.s://
www.uscis.gov/ar-11. Please also notify our office of your new
address.
Make An Online Legal Fee Payment via https://p-2:Y..:..P...2:Y~Y.-QQrn/
P.9S link/deFP.Bu7Sy5ogklgZhB9cQi59Yj, wire transfer, check,
cash, ApplePay (6466450993)

On 8/23/2024 7:12 PM, Rahul Manchanda, Esq. wrote:

Ashley Slot:

Please see the below new claim. I have to respond within 30 days of 8/14/24 which
is 9/14l24 to avoid having to pay a monetary sanction. That means I don't have a
lot of time.

Kind regards, -- Rahul D. Manchanda, Esq.

Manchanda Law Office & Associates PLLC 125 P~rk Aveou~, 2_5th Floor N~w York,
NY 10017 Tel: _(212) 968- 8600 Mob: .(646) 645- 0993 Fax: .(212) 968-8601 Toll
Free 24 Hour Hotline: _(855) 207-7660 e-mail: rdm@manchanda-law.com
web: httgs:/f.rnanchanda- law.comf.attorneY.-Qrofiles/. Ranked amongst Top
Immigration Attorneys in the United States by Newsweek Magazine in 2012 and
Top Attorneys Nationwide in 2013. Martindale Hubbell Client Champion 2017 Silver
Award Winner, 2020 Gold Award Winner, 2020 Platinum Award Winner. Better
Business Bureau Accredited Business A+ Rating. Association of American Trial
Lawyers Top 100 In New York State. Best Family Lawyers and Best Immigration
Lawyers in New York City in 2022 as published on Expertise.corn U.S. News and
World Report Listed Lawyer. Licensed New York State Real Estate Broker. CLIENT
TESTIMONIALS: bll~//,rnanchanda-law.com/,testirnonials/. This electronic
transmission is both personal and confidential, and contains privileged information
intended only for the use of the individual or entity named above. If the reader is
not the intended recipient, you are hereby notified that any dissemination or
copying of this transmission is strictly prohibited. If there are any problems with
this transmission, or you have received it in error, please immediately notify us by
telephone and return the original transmission to us at the above address via the
U.S. Postal Service. Attention: All foreign nationals (permanent residents and
children included) are required to report any change in address within ten (10) days
to the USCIS using Form AR-11. Foreign nationals must report address changes to
the USCIS by completing this form and sending it to the USCIS. The form can be
obtained from the USCIS website at: htt~//,www.uscis.gm.,/ar-11 . Please also notify
our office of your new address. Make An Online Legal Fee Payment via httpJi;//.
pay:pay~yM)IJ)/pos _link/sjeFQBu7Sv5ogk1gZhB9cQi59Yj, wire transfer, check,
cash, ApplePay (6466450993)

On Aug 73, 2024, at 6:45 PM, Rahul Manchanda, E:sq. <rdm@manchanda-

law.com> wrote:

Berkshire Hathaway GUARD

P. 0 . Box 1368
Wilkes-Barre. PA 18703- 136.8
 claims@g_uard.com

570-825-0611 (fax)

t •FW CLAIM - DECISION AND MONETARY SANCTION attached.

Kind regards,

Rahul D. Manchanda, Esq.

Manchanda Law Office & Associates PLLC

12 5 _:e,~1;k.. ~yenue, 25th Floo.,r
N C\y_'/..Qr k ,._,NY 1 0 Ql 7
Tel: .(212) 9~8-86-QJl
Mob : .(..6.i.6J 6 4 5 - 0 9 9 i
Fax : .L212 )_9_6,.8- 8 6 Ql
Toll :t'ree 24 Hour Hotline: .0155..} 207-7660
e-mail: rdm@manchanda-law.com
web: https://manchanda-law.com/attorneY.-P.rofiles/

Ranked amongst Top Immigration Attorneys in the United States

ny Newsweek Magazine in 2012 and Top Attorneys Nationwide in
2013.

Martindale Hubbell Client Champion 2017 Silver Award Winner,

2020 Gold Award Winner, 2020 Platinum Award Winner.

Better Business Bureau Accredited Business A+ Rating.

Association of American Trial Lawyers Top 100 In New York
State.

Best Family Lawyers and Best Immigration Lawyers in New York

City in 2022 as published on Expertise.com

U.S. News and World Report Listed Lawyer.

Licensed New York State Real Estate Broker.

CLIENT TESTIMONIALS: httP.s://manchanda-law.com/testimonials/

This electronic transmission is both personal and

confidential, and contains privileged information intended
only for the use of the individual or Jntity named above. If
the reader is not the intended recipient, you are hereby
notified that any dissemination or copying of this
transmission is strictly prohibited. If there are any
problems with this transmission, or you have received it in
error, please immediately notify us by telephone and return
the original transmission to us at the above address via the
u.s. Postal Service. Attention: All foreign nationals
(permanent residents and children included) are required to
report any change in address within ten (10) days to the
USCIS using Form AR-11. Foreign nationals must report address
changes to the users by completing this form and sending it
to the users. The form can be obtained from the users website
at: https://www.uscis.gov/ar-11 . Please also notify our
office of your new address.

Hake An Online Legal Fee Payment via https: //p...ay....:.P...aY~Y.-CQm/

P.9S link/deFP.Bu7Sy5oqtlgZhB9cQi59Yj , wire transfer, check,
l eash, ApplePay (6466450993 )

_--,.,..

; pdf l Letter Reply to Judicial

Order Dated 08142024
107 KB

B
DECISION AND NOTICE OF
CLAIM - MONETARY
74 KB
 Case: 24-392, 08/14/2024, DktEntry: 84.1, Page 1 of 2

S.D.N.Y. - N.Y.C.
23-cv-9292
Cronan, J.

United States Court of Appeals

FOR THE
SECOND CIRCUIT

At a stated term of the United States Court of Appeals for the Second
Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square,
in the City ofNew York, on the 14th day of August, two thousand twenty-four.

Present:
Raymond J. Lohier, Jr.,
Joseph F. Bianco,
Alison J. Nathan,
Circuit Judges.

Rahul Dev Manchanda,

Plaintiff-Appeilan1,

V. 24-392

Abigail Reardon, Attorney Grievance Committee Chief, et al.,

Defendants-Appellees.

Appellant, a lawyer acting prose, moves to stay "lower court" proceedings and to file a sur-reply. We don't
Appellee the Federal Bureau oflnvestigation moves to dismiss or for summary affirmance. Upon agreel th at
due consideration, it is hereby ORDERED that the appeal is DISMISSED because it "lacks an m~re _Y
arguable basis either in law or in fact." Neitzke v. Williams, 490 U.S. 319,325 (1989); see also ~~~;;gout
Pillay v. INS, 45 F .3d 14, 17 (2d Cir. 1995) (per curiam) (holding that this Court has "inherent observed first -
authority" to dismiss an appeal that lacks an arguable basis in law or fact). The motions are hand and by
DENIED as moot. direct
observation of
It is also equally We conclude that the imposition of sanctions, including leave-to-file or monetary sanctions, might civil rights
inappropriate be appropriate, in light of Appellant's litigation history. This Court's procedure for imposing and human
and improper leave-to-file sanctions involves three stages: (1) the Court notifies the litigant that the filing of liberties
to sanction a future frivolous appeals, motions, or other papers could result in sanctions, see Sassower v. violations by
lawyer/litigant Sansverie, 885 F.2d 9, 11 (2d Cir. 1989); (2) if the litigant continues to file frivolous appeals, 99 ~ . ti
who me r ely motions or other papers, the Court orders the litigant to show cause why a leave-to-file sanction
~~~~::~~:c~e
d.
order sh~~ld not iss~e, see, In r~ Martin-Trigona, 9 ~-~d 226, 229 (2d Cir. 1993)_; and (3) if the ~~::~:t
pre o~man

ethmc/rehg1ous groups m NYC agamst less powerful, less poht1cally connected, and less established other racial ethnic or
1
seen tre<;t y f religious minorities in NYC '1acks an aguable basis either in law or in fact,;' especially when that "ruling" is written by the verv
over 22 years o . '
same members of those oppressive groups.
th estate an d
federal courts
discrimianting and destroying against Respondent, his children, and his family by those 2 same dominant ethnic/racial
groups in NYC, and for wanting Discovery thereon to prove his case, but keeps getting summarily dismissed or
threatened, mocked, humiliated, intimidated for seeking out justice for himself, his children, and his family destroyed by
these listed people and defendants.
 Case: 24-392, 08/14/2024, DktEntry: 84.1, Page 2 of 2

litigant fails to show why sanctions are not appropriate, the Court issues a sanctions order, see
Gallop v. Cheney, 667 F.3d 226,227 (2d Cir. 2012) (per curiam).

In March 2022, a panel of this Court dismissed Appellant's appeal for lack of jurisdiction, and Again, we
warned Appellant that "the continued filing of duplicative, vexatious, or clearly meritless appeals, fundamentally
motions, or other papers in this Court could result in the imposition of sanctions, including a leave- di~agree wi th
to-file sanction that would require Appellant to obtain permission from this Court prior to filing th ~s court and
any further submissions in this Court." Manchanda v. Senderoff, No. 21-1909, 2022 WL :i~rcourts
It is is also not 1667261, at *l (2d Cir. Mar. 24, 2022) (unpublished). In that order, the Court also noted that his R:spondent's
"racist" or
"pro se pleading in this appeal ... contains racist and anti-Semitic comments." The Court civil rights
"anti-semitic"
to point out "condemn[ed] Appellant's comments and warn[ed] him that the use of any similar language in claims against
the FACTS future filings in this Court will result in sanctions, regardless of whether the filing is otherwise himself, his
that 99% of duplicative, vexatious, or meritless." Id. Seeking justice in a civil rights case wherein one MUST name children, and
Respondent's • rac1a,
th e oppressive • I ethn 1c,
' or re1·1g1ous
• makeup is NOT "vexatious or meritless." hsi family are
oppressors in In April 2023, a panel of this Court dismissed another of Appellant's appeals for lack of ~ome~ow
the family, jurisdiction and additionally noted that Appellant "has brought eight other appeals to this Court in ;ex~t,ous or
state, and the last ten years, all of which were dismissed or denied." 2d Cir. 23-61, doc. 42. The panel c e~l ..
federal cburts reasoned that his litigation history was "particularly troubling in light of his status as an attorney" ; : ;1;~ecause
against his
and again warned him that "further filing of duplicative, vexatidus, or clearly meritless appeals, this comt and
children,
motions, or other papers in this Court will likely result in a leave-to-file sanction, barring any previous ones
himself, and
his family further submissions in this Court without permission." Id The only legal and factual point of have never
contention is whether or not this court has jurisdiction is a material dispute of fact and law should be litigated allowed
against him
have either 11\~~~-~~rlof~~,tia-~b~n"~\'ellil..~flloe 4~~tntm>~~. Appellant Respondent to
been Black or has filed the instant frivolous appeal, which includes numerous anti-Semitic and racist statements, either receive
Jewish, directly against our warnings. We, again, condemn these comments. Accordingly, AppeJlant is ~ An~wer to
usually with hereby ORDERED to file a response within 30 days of the entry of this order why a leave-to-file hi~ chums, or
Jewish and a monetary sanction should not be imposed. Again, seeking justice or litigating civil rights claims Dthiscovery
supervisors. ereon.
against more powerful, established, politically connected ethnic, racial or religious minorities in NYC is NOT
either "racist," "anti-demitic," or frivolous," simply FOR THE COURT:
because the judges who hail from those oppressive Catherine O'Hagan Wolfe, Clerk of Court
groups feel that way• otherwise there would be NO PROGRESS in t ~ t r y when it comes to fighting or
vindicating ones' own civil rights, hwnan rights for his children.
tp..

2
 Case: 24-392, 08/14/2024, DktEntry: 85.1, Page 1 of 1

United States Court of Appeals for the Second Circuit

Thurgood Marshall U.S. Courthouse
40 Foley Square
New York, NY 10007

DEBRA ANN LIVINGSTON CATHERINE O'HAGAN WOLFE

CHIEF JUDGE CLERK OF COURT

Date: August 14, 2024 DC Docket #: 1:23-cv-9292

Docket#: 24-392 D<;: Court: SONY (NEW YORK
Short Title: Manchanda v. Reardon CITY)
Trial Judge - John P. Cronan

NOTICE OF CASE MANAGER CHANGE

The case manager assigned to this matter has been changed.

Inquiries regarding this case may be directed to 212-857-8658.

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August 24, 2024

U.S. Court of Appeals for the Second Circui t

40 Foley Square
New York, NY 10007

RE: Letter Reply to Judicial Order Dated 08/14/2024

Manchanda v. Reardon, No . 24-392

U.S. Court of Appeals Second Circuit:

We don't agree that merely pointing out FACTS observed firsthand and by
direct observation of civil rights and human liberties violations over
the past 25 years of law practice both as a litigant and a lawyer by
99 % predominantly certain dominant ethnic/religious/racial groups in
New York City against less powerful, less politically connected, and
less established other racial, ethnic, or religious minorities in New
York City "lacks an arguable basis either in law or in fact,"
especially when that "ruling" is written by the very same members of
those oppressive groups.

It is also equally inappropriate and improper to sanction a

lawyer/litigant who merely points out the obvious facts seen directly
over 25 years of the state and federal courts discriminating and
destroying Plaintiff-Appellant, his children, and his family by those 2
same dominant ethnic/racial groups in NYC, and for wanting Discovery
thereon to prove his case, but keeps getting summarily dismissed or
threatened, mocked, humiliated, and intimidated for seeking out justice
for himself, his children, and his family destroyed by these listed
people and defendants.

Again, we fundamentally disagree with this court and prior courts that
Plaintiff-Appellant's civil rights claims defending himself, his
children, and his family are somehow "vexatious or clearly meritless"
simply because this court and previous ones have never allowed
Plaintiff-Appellant to either receive an Answer to his claims, or
Discovery thereon.

Seeking justice in a civil rights case wherein one MUST name the
oppressive racial, ethnic, or religious makeup
I
is NOT "vexatious or
meritless."

It is also not "racist" or "anti-semitic" to point out the FACTS that

99% of Plaintiff-Appellant's oppressors in the family, state, and
federal courts against his children, himself, and his family against
him have either been Black or Jewish, usually with Jewish supervisors.

The only legal and factual point of contention is whether or not this
court has jurisdiction, which is a material dispute of fact and law and
should be litigated, not met with threats, harassment, intimidation,
sanctions, mockery, humiliation, abuse, or insults.

Again, seeking justice or litigating civil rights claims against more

powerful, established, politically connected ethnic, racial or
religious minorities in New York City is NOT either "racist,"
"anti-semitic," or "frivolous," simply because the judges who hail from
those oppressive groups feel that way - otherwise there would be NO
PROGRESS in this country when it comes to fighting or vindicating ones'
own civil rights, human rights, for himself and his children.

Respec't fully submitted,

h'\

Rahul Manchanda, Esq.

New York State Division of Human Rights Complaint Form

Individual filing the complaint

Please provide the information requested below.
First Name

Rahul

Middle lntial

Last Name

Manchanda

Street Address

125 Park Avenue

City

New York

State
NY

Zip

10017

Are you completing this form for someone else?

No
Your complaint

Jurisdiction
Boycotting/Blacklisting
Basis

Basis of alleged discrimination involving boycott or blacklisting:

Creed/Religion (religious membership, belief, practice, or observance, including sabbath or holy day observance, or
wearing of attire, clothing or facial hair in accordance with your religion ; or discrimination because you do not have a
religious belief)
Familial Status (if you are pregnant, have a child , or are in the process of obtaining custody of a child, or have a child
or children under age 18 in your household)
National Origin (the country where you or your ancestors were born)
Race/Color (because you are Asian, Black, White , etc.; includes ethnicity; includes traits historically associated with
race such as hair texture or hairstyle)
Sexual Orientation (heterosexual, homosexual, bisexual, asexual, whether actual or perceived)
Relationship or Association (with a member or members of a protected category(ies) listed above)

Please specify creed/religion:

Indian American Christian Republican Conservative Values Against Jewish Supremacy and Institutional Bias and
Racism In the NYS Courts

Please specify the protected category of the person you were associated with:

Indian American Christian Republican Conservative Values Against Jewish Supremacy and Institutional Bias and
Racism In the NYS Courts
 Please specify sexual orientation:

Indian American Christian Republican Conservative Values Against Jewish Supremacy and Institutional Bias and
Racism In the NYS Courts

Please specify race/color:

Indian American Christian Republican Conservative Values Against Jewish Supremacy and Institutional Bias and
Racism In the NYS Courts

Please snecltv national orioln:

Indian American Christian Republican Conservative Values Against Jewish Supremacy and Institutional Bias and
Racism In the NYS Courts
You are filing a complaint against ,

Entity that discriminated against you:

Name of entity

US Court of Appeals 2nd Circuit

Street Address

40 Foley Square

City

New York

State
NY

Zip
10007

In what county or borough did the violation take place?

New York Lower (Below 42nd Street)

Phone Number

(212) 857-8700

Email address

Fax Number

(212) 857-8680

Company Website

https://www.ca2.uscourts.gov/circuit_executive/circuit_ executive_ office.html

Date of the most recent act of alleged discrimination

08/24/2024
Description of discrimination
 Tell us more about each act of discrimination that you experienced. Please Include dates, names of people
involved, and other details. You must explain why you think these acts were discriminatory and how these acts
are connected to the protected class (race, color, sex, disability, etc.) you selected previously.
If you have supporting documentation or evidence, you may provide it later.

U.S. Court of Appeals Second Circuit:

We don't agree that merely pointing out FACTS observed firsthand and by direct observation of civil rights and human
liberties violations over the past 25 years of law practice both as a litigant and a lawyer by 99% predominantly certain
dominant ethnic/religious/racial groups in New York City against less powerful, less politically connected, and less
established other racial, ethnic, or religious minorities in New York City "lacks an arguable basis either in law or in fact,"
especially when that "ruling" is written by the very same members of those oppressive groups.

It is also equally inappropriate and improper to sanction a lawyer/litigant who merely points out the obvious facts seen
directly over 25 years of the state and federal courts discriminating and destroying Plaintiff-Appellant, his children , and
his family by those 2 same dominant ethnic/racial groups in NYC, and for wanting Discovery thereon to prove his case,
but keeps getting summarily dismissed or threatened, mocked, humiliated, and intimidated for seeking out justice for
himself, his children, and his family destroyed by these listed people and defendants.

Again, we fundamentally disagree with this court and prior courts that Plaintiff-Appellant's civil rights claims defending
himself, his children, and his family are somehow "vexatious or clearly meritless" simply because this court and
previous ones have never allowed Plaintiff-Appellant to either receive an Answer to his claims, or Discovery thereon.

Seeking justice in a civil rights case wherein one MUST name the oppressive racial , ethnic, or religious makeup is NOT
"vexatious or meritless."

It is also not "racist" or "anti-semitic" to point out the FACTS that 99% of Plaintiff-Appellant's oppressors in the family,
state, and federal courts against his children, himself, and his family against him have either been Black or Jewish,
usually with Jewish supervisors.

The only legal and factual point of contention is whether or not this court has jurisdiction, which is a material dispute of
fact and law and should be litigated, not met with threats, harassment, intimidation, sanctions, mockery, humiliation,
abuse, or insults. •

Again, seeking justice or litigating civil rights claims against more powerful, established, politically connected ethnic,
racial or religious minorities in New York City is NOT either "racist," "anti-semitic," or "frivolous," simply because the
judges who hail from those oppressive groups feel that way - otherwise there would be NO PROGRESS in this country
when it comes to fighting or vindicating ones' own civil rights, human rights, for himself and his children.

Respectfully submitted,
Rahul Manchanda, Esq.
Declaration

Based on the Information contained in this form, I charge the herein named respondent(s) with an unlawful
discriminatory practice, in violation of the New York State Human Rights Law.
I
I have not filed any other civil action, nor do I have an action pending before any administrative agency, under
any state or local law, based upon this same unlawful discriminatory practice. (If you have another action
pending and still wish to file, please contact our office to discuss.)

Please Initial:

RDM

I affirm under penalties of perjury, that I am the complainant herein; that I have read (or had read to me) the
foregoing complaint and know the content thereof; that the same Is true of my own knowledge except as to the
matters therein stated on information and belief; and that as to those matters, I believe the same to be true.

Rahul Manchanda, Esq.

Enter today's date.

08/24/2024
Additional information
Your contact information
Email Address
rdm@manchanda-law.com

Phone Number
2129688600

Mobile Phone
6466450993
Special needs

I am in need of:
I do not need any special accommodations
Settlement/Conciliation

To settle this complaint, I would accept:

Cease and desist from threatening, harassing, retaliating, mocking, humiliating, intimidating and removing my ability to
earn a living by depriving me of court access as a lawyer, merely for complaining and filing civil rights lawsuits to protect
my children, my family, and myself from institutional bias, racism, and discrimination by dominant ethnic/religious/racial
groups in the New York City courts and judicial system.
Prior complaint

Did you report or complain about the discrimination to someone else?

Yes

Date you reported or complained about discrimination:

08/24/2024

How exactly did you complain about the discrimination? (To whom did you complain?)
I

Administrative Office of the Courts Washington DC, various senators and congressmen, various media outlets, federal,
state and local law enforcement and ethics agencies.
Other information

Supporting Documentation
Letter Reply to Judicial Order Dated 08142024 Manchanda v Reardon 24-392,pdt
DECISION AND NOTICE OF CLAIM - MONETARY SANCTIONS.pelf

Please provide the name, last name, email address, and title of individual people who discriminated against
you.
Alison Nathan, Judge
Raymond Lohier, Judge
Joseph Bianco, Judge
Were other people treated the same as you? How?
Asians, Indians, Muslims, Chinese
Were other people treated better than you? How?
Jews, Blacks, White Christians
TRAVELERSJ
..... I Claim Summary

_;\,
..-..
LIABILITY
Rahul Manchanda
Damages: (Unknown) Property

CLAIM NUMBER F1L6139

COMPANY NAME MANCHANDA LAW OFFICE PLLC
DATE OF LOSS June 12, 2022
PREPARED BY Rahul Manchanda

CLAIM OFFICE DETAILS

P.O. BOX430
BUFFALO, NY 142400430
Phone:8009874735
Fax: 8668898376

COMPANY ASSOCIATED WITH LOSS

Company: MANCHANDA LAW OFFICE PLLC
30 WALL ST NEW YORK NY 10005
Account/Policy: 4813L2238 /75072438
INCIDENT DATE AND LOCATION
June 12, 2022
30 WALL ST NEW YORK NY 10005

ROLE OF THE INSURED

Contractor

Incident Details r

INCIDENT SCENARIO
Other

INCIDENT DETAILS
Did this involve fire? No
Result of a lawsuit? Unsure
Concerns if incident occurred as reported? Unsure
Contact from impacted party? Unsure

DAMAGES AND INJURIES

Any damage to property? Unsure
Was anyone injured in incident? No

Claimant Information
CLAIMANT I
Rahul Manchanda
270 Victory Boulevard New York NY 10804
rdm@manchanda- law.com, 646~645-0993
Damages: {Unknown) Property

Incident Information
DESCRIPTION
I am filing another claim under my Employee Di~honesty Program
Policy for a claim and threat of monetary sanctions from US Court of
Appeals 2nd Circuit Judges Alison Nathan, Joseph Bianco; and
Richard Lohier for their legal work

REPORTING PURPOSES ONLY

No

Claim Contact Details

CLAIM FILED BY
Rahul Manchanda
rdm@manchanda-law.com, 646-645-0993

PRIMARY CONTACT
Rahul Manchanda
270 Victory Boulevard New Rochelle NY 10804
rdm@manchanda-law.com, 646-645-0993

ADDITIONAL INFORMATION
US Court of Appeals Case Index No 24-392, Manchanda v Reardon
etal