Willie-Anthony:Brown,

Authorized Representative,
Natural Person, In Propria Persona:
Ex Relatione BROWN, WILLIE A:
All Rights Reserved:
U.C.C. 1-207/ 1-308; U.C.C. 1-103
c/o 5824 Ludlow St Philadelphia, PA
[19139]Non-Domestic

IN THE EASTEN DISTRICT OF PENNSYLVANIA

Willie-Anthony: Brown
Affiant
PETITION FOR JUDICIAL REVIEW
CORAM NON JUDICE
15 PA CS 1502
Case No: CP-51-CR-0006768-2022
Order Date Filed: 03/17/2023.
V.

Commonwealth of Pennsylvania, et al
Judge Assigned: Hangley, Michele, et al
Respondent

March 22th, 2023

PETITION FOR JUDICIAL REVIEW PURSUANT TO 15 PA CS 1502

Rule 60. Relief from a Judgment or Order

(a) Corrections Based on Clerical Mistakes; Oversights and Omissions. The court may correct a

clerical mistake or a mistake arising from oversight or omission whenever one is found in a
judgment, order, or other part of the record. The court may do so on motion or on its own, with

or without notice. But after an appeal has been docketed in the appellate court and while it is

pending, such a mistake may be corrected only with the appellate court's leave.

(b) Grounds for Relief from a Final Judgment, Order, or Proceeding. On motion and just terms,

the court may relieve a party or its legal representative from a final judgment, order, or

proceeding for the following reasons:

(1) mistake, inadvertence, surprise, or excusable neglect;

(2) newly discovered evidence that, with reasonable diligence, could not have been discovered in

time to move for a new trial under Rule 59(b);

(3) fraud (whether previously called intrinsic or extrinsic), misrepresentation, or misconduct by

an opposing party;

(4) the judgment is void:

(5) the judgment has been satisfied, released, or discharged; it is based on an earlier judgment

that has been reversed or vacated; or applying it prospectively is no longer equitable; or

(6) any other reason that justifies relief.

CANON OF POSITIVE LAW

Article 142 - Mistake

Canon 2392

A Mistake, also known as a Mistake of Fact is an erroneous belief or trust that certain facts are

true when committing a reasonable action. A Mistake of Fact does not exist when an action is

considered unreasonable.

Canon 2393
A Reasonable action in terms of a Mistake of Fact is any action that one would expect to

represent the norms of respectful society and behaviou?, thus excluding such actions as violence,

depravity, perfidy, fraud and other acts considered universally as anti-social and grossly

disrespectful.

Canon 2394

A Mistake of Fact is not permitted to be argued when the alleged actions by the person are

grossly unreasonable.

Canon 2395

In the permitted admission of a Mistake of Fact, any assumed surety for liability from alleged

injury ceases to exist.

Canon 2396

A person is not considered to consent who commits a mistake.

Canon 2397

Any person permitted to admit a Mistake of Fact must be offered relief to any alleged injury in

addition to cessation of any claimed surety for any liabilities associated with the alleged injury.

Canon 2398

Any competent authority that refuses to release a person from surety for any liability upon a

permitted admission of Mistake of Fact fully consents to assume the liability for themselves..

Canon 2399

Any competent authority that refuses to offer relief to a person upon a permitted admission of

Mistake of Fact is guilty of fraud and a gross injury to the law.

Canon 2400
When a person has been deliberately deceived by fraud, then neither mistake nor injury exists.

Canon 2401

Excluding fraud, consent obviates a mistake.

LETTER OF RELIEF

Chapter I. ALCOHOL AND TOBACCO TAX AND TRADE BUREAU, DEPARTMENT OF

THE TREASURY

27 CF 19.171 - Surety notice of relief from bond liability.

§ 19.171 Surety notice of relief from bond liability.

(a) Notice to principal. A surety on a bond may, at any time, notify the principal in writing that

the surety desires to be relieved of liability under the bond.

(b) Notice to TTB. A surety on a bond may, at any time, notify the appropriate TTB officer in

writing that the surety desires to be relieved of liability under the bond, The notice must specify

the date after which the surety desires to be relieved of liability. In the case of a withdrawal

bond, the date specified in the notice must be at least ten days after the notice is received by the

appropriate TTB officer. In the case of an operations bond or unit bond, the date specified in the

notice must be at least 90 days after the notice is received by the appropriate TIB officer When a

surety files a termination notice with TB, the surety must include either an acknowledgement

from the principal that the principal is aware that the surety is terminating, the bond or proof that

the surety has served the principal with notice of its intent to terminate the bond.

(c)Effect of hotice. The bond coverage will end as of close of business on the date specified in

the notice, provided the surety timely filed a proper and complete termination notice, and the

surety does not withdraw its termination notice in writing prior to the termination date. The
surety will be released from future liability under the bond to the extent set forth in § 19.172. (26

U.S.C. 5173, 5175, 5176)

Appropriate TTB officer. An officer or employee of the Alcohol and Tobacco Tax and Trade

Bureau (TTB) authorized to perform any functions relating to the administration or enforcement

of this part by TTB Order 1135.19, Delegation of the Administrator's Authorities in

27 CFR Part 19, Distilled Spirits Plants

I, Willie Anthony Brown, in my Private Capacity as Bailor for Bailee of the Debtor, I accept as

value for consideration and return for value pursuant to “Accepting Gifts” 31 USC Section 3113

appoint the Court as temporary trustee of the trust created by the criminal complaint security in

the Court's books and order the trustee to exchange the Complaint security for a dismissal order

security. Should you, the trustee, fail to perform, you will have breached the trust and lose his

appointment and a federal tax inquiry into the whereabouts of the funding for this alleged

criminal infraction. I am now the sole trustee for the beneficiary - which collapses the trust under

trust law AND under statutes, Sec 402(a)(1) of the UCT (Uniform Trust Code)

I order the Grantor to obey my specific intentions and directives to exchange the securities. As

the Trustee of Said account with Power of Attorney in Fact.

NATURE OF THE ACTION

2. This antitrust and commodities class action concerns Defendants' collusive

manipulation of the market for U.S. Treasury bills, notes, and bonds (together, "Treasury

securities"), and derivative financial products based on these Treasury securities, including

Treasury futures and options traded on the Chicago Mercantile Exchange (collectively with

Treasury securities, "Treasury Instruments"). Treasury securities are debt instruments issued by

the U.S. Treasury Department ("Treasury Department") to help finance the operations of the U.S.
government. Treasury securities also serve as benchmarks for interest rates and pricing various

other assets, including student loan debt, bonds, interest rate swaps, and exchange-traded

Treasury futures and options. Treasury securities and related derivative financial products are

used by state and local municipalities, corporations, investment funds, hedge funds, pension

funds and individuals for investing and hedging purposes. In short, the integrity of the Treasury

securities market is paramount because it affects many facets of the U.S. economy.

3. Defendants, by virtue of their position as primary dealers in the market for Treasury securities,

have a special obligation to ensure the efficient function of this market. Instead, Defendants used

their critical position to subvert the proper operation of the Treasury securities market by

colluding to manipulate the Treasury Department auctions, as well as the pricing of Treasury

securities in the "when-issued market"—i.e., the period between auction announcement date and

the issuance (delivery) of the auctioned securities.

The when-issued market takes place during the seven days leading up to the Treasury

Department auction, but also includes the few days between the auction and the ultimate

issuance of the securities. During the pre-auction part of this period, entities including

Defendants, pension funds, investment funds, hedge funds, and other types of investors can trade

in the Treasury securities that are to be auctioned. Typically, Defendants act as sellers of

Treasury securities to their customers during the when-issued market. Then, at auction,

Defendants become buyers of the Treasury securities in order to cover the sales they made

during the when-issued market. The difference between the price at which Defendants sell in the

when-issued market and purchase at auction, or spread, is Defendants' profit. Defendants'

conspiracy was to cause these profits to be supracompetitive.

generally tend to be higher (lower) in the when-issued market than prices tendered at auction.

However, as a result of Defendants' unlawful manipulation of the Treasuries market, the prices of

when-issued Treasury securities were artificially high and the prices of Treasury securities at

auction were artificially low. This scheme maximized Defendants' profits at the expense of their

customers and others in the market.

6. Defendants employed a two-pronged scheme to manipulate the Treasury securities market.

First, Defendants used electronic chatrooms, instant messaging, and other electronic and

telephonic methods to exchange confidential customer information, coordinate trading strategies,

and increase the bid-ask spread in the when-issued market to inflate prices of Treasury securities

they sold to the Class. Second, Defendants used the same means to rig the Treasury auction

bidding process to deflate prices at which they bought Treasury securities to cover their pre-

auction sales. Recent reports confirm that traders at some of these primary dealers "talked with

counterparts at other banks via online chatrooms"land "swapped gossip about clients' Treasury

orders."2

7. By engaging in this unlawful conduct, Defendants maximized the spread not only for

transactions in the when-issued market, but also between their buy (auction) price and sell

(when-issued) price. This conduct lined the pockets of Defendants while raising prices to

investors trading Treasury securities in the when-issued market, investors trading Treasury

security-based futures and options, and investors transacting in instruments benchmarked to the

prices of Treasury securities determined at auction, including certain bonds and other asset-

backed securities and interest rate swaps.

NATURE OF RELIEF SOUGHT

a. Petition for Judicial Review

b. Cure for Breach of Contract

c. Any and all relief deemed fit, including, but not limited to;

d. Due Process as protected by the Fourth (4th) and Fifth (5th)

Amendments of the Constitution for the United States of

America (Republic)

e. The Pennsylvania Supreme Court to issue a Writ of Mandamus

and stop these abuses of the colorable authority by the Plaintiff

as it pertain to this Petitioner.

f. any criminal charges be found, let them be placed upon the

Plaintiffs.

g. All UNCONSTITUTIONAL Citations – Summons / Ticket –

Suit / (misrepresented) Bill of Exchange: Number <CP-51-CR-

0006768-2022>, and any other ‘Order’ or ‘Action’ associated

with it / them, to be dismissed and expunged for the record on

it’s face and merits; or, otherwise, be brought before a

legitimately - delegated, and competent ‘Court of Law’ of

International jurisdiction / venue.

Law of the Land (Constitution) and their obligation to uphold

the same and to no longer be excused without action on the part

of the Sheriff for violating the same. And to be made

cognizance of the recompense of colorable actions on their

part, by not adhering to the Law.

i. Any Plaintiff, Corporate or Natural, Party-Claimants;

Involvements be found guilty of the charges and shall result

in immediate Recusal of Office

j. Plaintiff STATE OF PENNSYLVANIA is being sued for

$75,000 for compensatory damages and $75,000 for punitive

damages in its official capacity.

k. Plaintiff COURT OF COMMON PLEAS is being sued for

$75,000 for compensatory damages and $75,000 for punitive

damages in its official capacity.

l. Plaintiff ERIC FEDER is being sued for $75,000 for

compensatory damages and $75,000 for punitive damages in

his private capacity.

m. Plaintiff Policeman, Duane White, is being sued for $75,000

for compensatory damages

TRIAL BY JURY OF MY OWN PEERS WAS, AND IS, DEMANDED

above is true and correct to the best of my knowledge and honorable intent.

Day 22, March, 2009 = 1429 M.C.

I Am Willie-Anthony: Brown

Authorized Representative Natural Person, In Propria Persona: All Rights Reserved; U.C.C. 1-

207 / 308; U.C.C. 1-103