Notice of Appeal — Federal District Court

ERIC J. BONETTI,

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Plaintiff, CIVIL Case No. 1:21cv0190 (CMHJFA)

vs.

EPISCOPAL DIOCESE OF VIRGINIA, ROBERT HILLER MALM, CITY OF ALEXANDRIA, COMMONWEALTH OF VIRGINIA, EPISCOPAL DIOCESE OF MASSACHUSETTS, ST. GABRIEL’S EPISCOPAL CHURCH, Defendants

NOTICE OF APPEAL

COMES NOW Plaintiff, Eric J. Bonetti, and files notice of appeal in the above-captioned matter this 31st day of May 2021. As previously stated in prior pleadings, Plaintiff alleges: -

The Commonwealth of Virginia cannot validly enter a protective order without a showing of a threat against the Petition without violating the express terms of the relevant Virginia statute, and constitutional guarantees of due process and equal protection.

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The City of Alexandria cannot wade into a civil dispute, provide free legal advice and other services to one party, while ignoring complaints of illegal behavior by that party, consistent with constitutional guarantees of due process and equal protection. Thus, the City of Alexandria’s refusal to address allegations of perjury and other misconduct on the part of Robert Hiller Malm violates Plaintiff’s right to due process and the equal protection of the laws.

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The Commonwealth of Virginia, acting through its courts, cannot issue a court order prohibiting plaintiff from discussing his litigation against Robert Hiller Malm and his family absent a rational basis, including but not limited to a showing of some sort of protected privacy interest on the part of Robert Hiller Malm, or some legitimate interest that outweighs the right First

Plaintiff’s Motion for Removal

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Amendment rights of the Plaintiff and the public from discussing allegations concerns Robert Hiller Malm and his conduct.

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The Commmonwealth of Virginia, acting through the Alexandria Circuit Court, continues to display and evince bias against the Plaintiff, including prejudging the merits of his case now before the court, and refusing to permit reasonable discovery by the Plaintiff. As such, the actions of the Commonwealth are violative of constitutional guarantees of due process and equal protection.

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That violation of First Amendment rights, as well as the constitutional guarantees of due process and the equal protection of the laws, as is alleged here, are per se harm that warrants judicial scrutiny and remediation.

Plaintiff further respectfully requests that this court consider his request for a writ of mandamus against the Circuit Court of the City of Alexandria, which Plaintiff avers has issued, or is about to issue, an order violative of Plaintiff’s First Amendment rights.

Craig D. Roswell, Esquire (VSB No.: 33901) Matthew J. Youssef, Esquire (VSB No.: 85339) NILES, BARTON & WILMER, LLP 111 S. Calvert Street, Suite 1400 Baltimore, Maryland 21202 (410) 783 –6357 (410) 783 –6452 cdroswell@nilesbarton.com mjyoussef@nilesbarton.com Counsel for Defendant, Grace Episcopal Church and Episcopal Diocese of Virginia Wayne F. Cyron, Esquire (VSB No. 12220) CYRON & MILLER LLP 100 N. Pitt St., Suite 200 Alexandria, VA 22314 703-299-0600 703-299-0603 (fax) wcyron@cyronmiller.com Counsel for Defendant, Robert H. Malm Alexandria City Attorney 301 King Street, Suite 1300 P. O. Box 178 Alexandria, Virginia 22313 George.mcandrews@alexandriava.gov Plaintiff’s Motion for Removal

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Virginia Office of Attorney General Via email

Plaintiff’s Motion for Removal

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