Application for Appellate Review — Kengne v. ID.me, Inc.

Record facts

U.S. District Court for the Northern District of Georgia · No. 1:22-cv-02237-SEG · Doc. 5 · 2022-07-05 · Docket on CourtListener

Full text

IN THE COURT OF APPEALS 
STATE OF GEORGIA 
) 
Case No. 1:22-CV-2237 
) 
(Related Case No. 
RAISSA DJUISSI KENGNE, 
) 
I :22-CV-2297-SEG) 
Applicant, 
) 
(Related Case No. 
) 
l:22-CV-2263) 
V. 
) 
ID.ME,INC. 
) 
COGENCY GLOBAL INC. 
) 
250 BROWNS HILL CT, 
) 
MIDLOTHIAN, VA, 23114- 9510, USA 
) 
) 
Respondent. 
) 
PLAINTIFF RAISSA DJUISSI KENGNE'S APPLICATION FOR 
APPELLATE REVIEW 
1 of33 
Raissa Djuissi Kengne 
Pro Se 
Mailing Address: 
570 Piedmont Ave. NE #55166 
Atlanta, GA 30308 
Physical Address: 
1280 W. Peachtree ST NW. Unit 2109 
Atlanta, GA 30309 
Telephone: (404) 932-1651 
Email: cianeseya2022(@gmail.com 
Case 1:22-cv-02237-SEG     Document 5     Filed 07/05/22     Page 1 of 34

RAISSA DJUISSI K.ENGNE, 
Applicant, 
v.' 
ID.ME,INC. 
COGENCY GLOBAL INC. 
250 BROWNS HILL CT, 
IN THE COURT OF APPEALS 
STATE OF GEORGIA . 
) 
Case No. l:22-CV-2237 
) 
(Related Case No. 
) 
1 :22-CV-2297-SEG) 
) 
(Related Case No. 
) 
1 :22-CV-2263) 
) 
) 
) 
) 
MIDLOTHIAN, VA, 23114 - 9510, USA 
) 
) 
Respondent. 
) 
PLAINTIFF RAISSA DJUISSI KENGNE'S APPLICATION FOR 
APPELLATE REVIEW 
1 of33 
Raissa Djuissi Kengne 
Pro Se 
Mailing Address: 
570 Piedmont Ave. NE #55166 
Atlanta, GA 30308 
Physical Address: 
1280 W. Peachtree ST NW. Unit 2109 
Atlanta, GA 30309 
Telephone: (404) 932-1651 
Email: cianeseya2022@gmail.com 
Case 1:22-cv-02237-SEG     Document 5     Filed 07/05/22     Page 2 of 34

IN THE COURT OF APPEALS 
STATE OF GEORGIA 
) 
Case No. 1:22-CV-2237 
) 
(Related Case No. 
RAISSA DJUISSI KENGNE, 
) 
1 :22-CV-2297-SEG) 
Applicant, 
) 
(Related Case No. 
) 
1 :22-CV-2263) 
v. 
) 
ID.ME,INC. 
) 
COGENCY GLOBAL INC. 
) 
250 BROWNS HILL CT, 
) 
MIDLOTHIAN, VA, 23114- 9510, USA 
) 
) 
Respondent. 
) 
APPENDIX TO RAISSA DJUISSI KENGNE'S APPLICATION FOR 
APPELLATE REVIEW IN COMPLIANCE WITH RULES 30 AND 31 OF 
THE FEDERAL RULES OF APPELLATE PROCEDURE 
Exhibit lA 
2022CV365268 - COMPLAINT - Related Case 
Exhibit lB 
2022CV365268 - NOTICE OF FILING - Related Case 
Exhibit 2 
ID .ME Email Communications 
Exhibit 3 
Raissa Djuissi Kengne's Georgia Department of Labor Separation Notice 
Exhibit4A 
Delta Community Credit Union Foreclosure Notice 
Exhibit 4B 
AGSOUTH Farm Credit Foreclosure Notice 
Exhibit 5 
· Bills Past Due 
Exhibit 6 
ID.ME - Motion to Proceed in Forma Pauperis Local Form 
Exhibit 7 
Final Report and Recommendation and Order Filed June 10th, 2022 
Exhibit 8 
Order For Service of Report And Recommendation Filed June 101\ 2022 
Exhibit 9 
9A. Plaintiffs Responses And Objections To The Final Report And 
Recommendation And Order Issued In Relation To Plaintiffs Original 
Complaint, Injunction For Relief, And Declaratory Judgment And Motion 
To Reconsider Plaintiffs Initial Motion To Filing In Forma Pauperis 
9B. Motion For Reconsideration 
Exhibit 10 
ID.ME, Inc. Complaint and Request For Injunction 
Exhibit 11 
Affidavit 
2 of33 
Case 1:22-cv-02237-SEG     Document 5     Filed 07/05/22     Page 3 of 34

RAISSA DJUISSI KENGNE, 
Applicant, 
v. 
ID.ME,INC. 
COGENCY GLOBAL INC. 
250 BROWNS HILL CT, 
IN THE COURT OF APPEALS 
STATE OF GEORGIA 
) 
Case No. 1:22-CV-2237 
) 
(Related Case No. 
) 
1 :22-CV-2297-SEG) 
) 
(Related Case No. 
) 
1:22-CV-2263) 
) 
) 
) 
) 
MIDLOTHIAN, VA, 23114- 9510, USA 
) 
) 
Respondent. 
) 
TABLE OF CONTENT TO RAISSA DJUISSI KENGNE'S 
APPLICATION FOR APPELLATE REVIEW IN COMPLIANCE WITH 
RULES 30 AND 31 OF THE FEDERAL RULES OF APPELLATE 
PROCEDURE 
TABLE OF CONTENT 
I .............................................................................................................................................. INTRODUCTION 
·······································································································································································6 
II ............................................................................................................ JURISDICTION AND VENUE - APPEAL 
..................................................................................................................................................................... 11 
Ill .............................................. JURISDICTION AND VENUE -COMPLAINT AND REQUEST FOR INJUNCTION 
·····································································································································································14 
IV ............................................................................................................................ STATEMENT OF THE CASE 
·····································································································································································17 
V ........................................................................ ENUMERATION OF ERRORS AND CITATION TO AUTHORITY 
················································································································································ ..................... 19 
3 of33 
Case 1:22-cv-02237-SEG     Document 5     Filed 07/05/22     Page 4 of 34

A ....................................................... Objections, Responses, and Arguments to Statement of Analysis 1: 
................................................................................................................................................................. 19 
B ........................................................... Objections, Responses, and Arguments Statement of Analysis 2: 
·································································································································································20 
C. .......................................................... Objections, Responses, and Arguments Statement of Analysis 3: 
·································································································································································21 
D ...................................... Objections, Responses, and Arguments Response To Statement of Analysis 4: 
·································································································································································23 
E ...................................................... Objections, Responses, and Arguments To Statement of Analysis 5: 
·································································································································································24 
F ....................................................... Objections, Responses, and Arguments To Statement of Analysis 6: 
·································································································································································26 
G .............................................. Plaintiff's Request Related To Her Motion To Proceed in Forma Pauperis 
·································································································································································28 
H ......................................................................................................................... Plaintiff's Additional Filing 
·································································································································································28 
VI. ............................................................................................ ARGUMENTS AND CITATIONS TO AUTHORITY 
·····································································································································································29 
1. ................................................................................................................. The 14th Amendment - Title I 
·································································································································································29 
2 ...................................................................... The 14th Amendment - Public Health, Safety, and Morals 
·································································································································································31 
3 ...................................................................................................................... Claim and Prayer For Relief: 
·································································································································································32 
VII ............................................................................................................................................... CONCLUSION 
·····································································································································································32 
VIII ........................................................................................................................................... CERTIFICATION 
·····································································································································································32 
4 of33 
Case 1:22-cv-02237-SEG     Document 5     Filed 07/05/22     Page 5 of 34

TO THE HONORABLE JUDGE OF SAID COURT: 
Comes Now, PLAINTIFF, RAISSA DJUISSI KENGNE, Applicant, asks this Court as follows: 
(1) To issue an order granting the applicant an appeal from the order of the United States District 
Court for the Northern District of Georgia Atlanta Division, Honorable Catherine M. Salinas, 
presiding, in the case styled Raissa Djuissi Kengne, Plaintiff, v. ID.Me, Inc., Defendant, Case No. 
1:22-CV-2237, this order having held: that Plaintiffs complaint be DISMISSED without prejudice 
for lack of subject matter jurisdiction, and the case closed [and that] Plaintiffs application to 
proceed in IFP is DENIED. The order was entered on June 10th, 2022 and stamped "filed" on June 
101h, 2022. 
(2) Applicant shows that jurisdiction is properly in this Court because the courts of appeals have 
jurisdiction of appeals pursuant to 28 U.S. Code § 1292 - Interlocutory decisions. 
(3) This application for appeal is filed within 30 days of the entry of the order, decision, or 
judgment complained of. 
(4) Copies of all necessary documents have been attached to this application as exhibits, including 
a copy of the order being appealed, a copy of the motion to proceed In Forma Pauperis ("IFP"), 
which led directly to the order being appealed, a copy of the Motion for Reconsideration filed as 
response to the Court issuance of a Report and Recommendation ("R&R") and the motion to 
proceed in Forma Pauperis, and an index to the exhibits. 
(5) Interlocutory appellate review is needed because the Court erred in its decision to deny the 
motion to proceed in Forma Pauperis. 
(6) Applicant submits that an appeal should be granted to correct reversible errors oflaw based on 
misinterpreted information, which were not the facts presented by the Plaintiff. Applicant 
respectfully shows that if this Honorable Court declines the appeal of this matter and the trial 
5 of33 
Case 1:22-cv-02237-SEG     Document 5     Filed 07/05/22     Page 6 of 34

court's ruling will be permitted to stand, such would be a miscarriage of justice because Plaintiffs 
rights under the 14th Amendment Title 1, 42 U.S.C. § 1104 Unemployment Trust Fund, 26 U.S.C. 
3301 et seq. Federal Unemployment Tax Act, and O.C.G.A. § 34-8-45 Supplemental 
unemployment benefits would have been violated and Plaintiff damages would not have been 
redressed. 
I. 
INTRODUCTION 
Applicant Raissa Djuissi Kengne ("Appellant") seeks to reverse the order denying 
Plaintiff's motion to proceed in Forma Pauperis attached at Exhibits 7 and 8. 
Motions to proceed IFP on appeal are governed by 28 U.S.C. § 1915(a) and Federal Rule 
of Appellate Procedure 24. Section 1915(a) provides that any court of the United States may 
authorize the commencement, prosecution or defense of any suit, action or proceeding, civil or 
criminal, or appeal therein, without prepayment of fees or security therefor, by a person who 
submits an affidavit that includes a statement of all assets such person possesses that the person is 
unable to pay such fees or give security therefor. 
28 U.S.C. § 1915(a). The statute forbids a plaintiff to proceed IFP "if the trial court certifies in 
writing that [the action] is not taken in good faith."28 U.S.C. § 1915(a)(3). Federal Rule of 
Appellate Procedure 24 provides: 
(1) ... [A] party to a district court action who desires to appeal informa pauperis must file a motion 
in 
the 
district 
court. 
The 
party 
must 
attach 
an 
affidavit 
that: 
(A) shows ... the party's inability to pay or to give security for fees and costs; 
(B) claims an entitlement to redress; and 
(C) 
states 
the 
issues 
that 
the 
party 
intends 
to 
present 
on 
appeal. 
6 of33 
Case 1:22-cv-02237-SEG     Document 5     Filed 07/05/22     Page 7 of 34

Thus, based on§ 1915(a) and Rule 24, to grant a motion to proceed IFP on appeal, the 
moving party must submit an affidavit that demonstrates (1) an inability to pay, (2) entitlement 
to redress, (3) the issues on appeal, and (4) good faith. 
a. Inability to Pay 
When considering a motion to proceed IFP, "[t]he only determination to be made by the 
court ... is whether the statements in the affidavit satisfy the requirement of poverty." Martinez v. 
Kristi Kleaners, Inc., 364 F.3d 1305, 1307 (11th Cir. 2004). To show poverty, the Plaintiff need 
not show that he is "absolutely destitute." Id. Instead, the plaintiff must demonstrate that "because 
of his poverty, he is unable to pay for the court fees and costs, and to support and provide 
necessities for himself and his dependents." Id. 
In this case, Plaintiff submitted her Affidavit, her "Plaintiffs Responses And Objections 
To The Final Report And Recommendation And Order Issued In Relation To Plaintiff's Original 
Complaint, Injunction For Relief, And Declaratory Judgment And Motion To Reconsider 
Plaintiff's Initial Motion To Filing In Forma Pauperis" as well as her Motion For Reconsideration 
in order to Appeal IFP. (Exhibit 9) In her Motion for Reconsideration, she reports her earned 
monthly income as $0.00. Plaintiff has not earned any income in the last seven and a half (7.5) 
months and is has received SNAP benefits starting on May 19th, 2022. Plaintiff estimates her 
monthly expenses to be $13,125.00 before her constructive discharge from BDO USA, LLP in 
November 18th, 2021 due to her protected status as a whistleblower (Exhibits IA and 1B). 
Although Plaintiff has no income, she still has approximately the same amount of monthly 
expenses, which is spent on mortgage payments, utilities, home maintenance, and healthcare, 
among other expenses. Plaintiff is currently operating in deficit and is highly leveraged. These 
estimates from Plaintiffs Motion for Reconsideration demonstrate that her expenses are 
7 of33 
Case 1:22-cv-02237-SEG     Document 5     Filed 07/05/22     Page 8 of 34

tremendously greater than her income. This satisfies the requirement of demonstrating an inability 
to pay court fees. 
b. Entitlement of Redress 
To proceed IFP on appeal, the moving party must also state an entitlement of redress. In 
this case, Plaintiffs Complaint and Request for Injunction as well as Motion for Reconsideration 
includes "Grant any such additional relief to Plaintiff in law or equity as the Court deems just and 
proper under the circumstances". In addition, Plaintiff has submitted an Affidavit that claims "I 
believe I am entitled to redress." Plaintiff dated and signed her Affidavit, her Complaint and 
Request for Injunction as well as her Motion for Reconsideration. This is sufficient to demonstrate 
the fulfillment of the second requirement to proceed IFP on appeal. 
c. Issues on Appeal for ID.Me, Inc. 
The third condition for proceeding IFP requires the moving party to clearly state the issues 
on appeal. Plaintiffs Motion For Reconsideration (Exhibit 9) states four (4).issues to be appealed 
related to: 
(1) the violation of Plaintiffs rights under the 14th Amendment Section 1; If every person 
is afforded an opportunity to have food, shelter, and adequate healthcare, it is ensured that his or 
her rights to pursue happiness, life, and liberty are not violated. By delaying and preventing 
Plaintiff to have access to her ID.Me account, ID.Me, is wrongfully, illegally, and/or unlawful 
depriving Plaintiff of food, shelter, and adequate healthcare. Defendant ID.Me has violated 
Plaintiffs unalienable rights under the 14th Amendment Title I by delaying and preventing 
Plaintiff to have access to her ID.Me account; thereby, violating Plaintiffs right to Life, Liberty 
and the pursuit of Happiness as well as due process; 
8 of33 
Case 1:22-cv-02237-SEG     Document 5     Filed 07/05/22     Page 9 of 34

(2) the violation of 42 U.S.C. § 1104 Unemployment Trust Fund; 
(3) the violation of 26 U.S.C. 3301 et seq. Federal Unemployment Tax Act; and 
(4) the violation of O.C.G.A. § 34-8-45 Supplemental unemployment benefits. 
These statements satisfy the third requirement. 
Plaintiff re-alleges and incorporates each and every paragraph of the PLAINTIFF'S 
COMPLAINT AND REQUEST FOR INJUNCTION (case number 1:22-CV-2237) and the facts 
as if set forth here in full for all purposes. 
In evaluating the legal sufficiency of a complaint for purposes of§ 1915( d), the courts apply 
the customary standard enunciated in Conley v. Gibson, 355 U.S. 41, 45-46, 78 S.Ct. 99, 101-102, 
2 L.Ed.2d 80 (1957), that a complaint should not be dismissed for failure to state a claim unless it 
appears beyond doubt that the Plaintiff can prove no set of facts in support of his or her claim, 
which would entitle him or her to relief. Plaintiff can prove the facts to support her claims and has 
provided evidence to support her claims. 
d. Issues on Appeal for Georgia Power 
The third condition for proceeding IFP requires the moving party to clearly state the issues 
on appeal. Plaintiffs Motion For Reconsideration (Exhibit 9) states four (4) issues to be appealed 
related to: 
(1) 
Plaintiff asserts in Counts 1 through 5, taken together, that the rates that she 
was charged were arbitrary and/or unreasonable, due to the fact that the readings were 
inaccurate and therefore, the total amount on the Plaintiff's electricity bill was inaccurate; 
9 of33 
Case 1:22-cv-02237-SEG     Document 5     Filed 07/05/22     Page 10 of 34

thereby, rendering th rate charged to the Plaintiff different from the rates approved by the 
Public Service Commission ("PSC"). 
(2) 
Plaintiff asserts in Counts 1 through 5, taken together, that by wrongfully 
and/or illegally disconnecting her service without notice, Defendant Georgia Power 
violated Plaintiffs due process rights as mandated and protected by the 14th Amendment. 
(3) The 14th Amendment also applies to Health, Safety, and Morals. The 
Fourteenth Amendment Rights Guaranteed Privileges And Immunities of Citizenship, Due 
Process And Equal Protection states that "Even under the narrowest concept of the police 
power as limited by substantive due process, it was generally conceded that states could 
exercise the power to protect the public health, safety, and morals. 
(4) Plaintiff asserts in Counts 1 through 5, taken together, that Georgia Power 
violated Plaintiffs 14th Amendment by wrongfully and illegally disconnecting the 
electricity. The National Association for the Advancement of Colored People (''NAACP") 
recently released a report called Lights Out in the Cold, Reforming Utility Shut-Off 
Policies as if Human Rights Matter. Plaintiffs assertion that electricity and its related 
services are a basic human right and that access to electricity is a critical component to the 
prosperity, safety and general well-being of every human being, is supported by the 
NAACP 
research. 
The 
NAACP 
research 
report 
can 
be 
found 
at 
https://naacp.org/resources/lights-out-cold. Without electricity, Plaintiff is unable to have 
access to adequate food, health, and safety. 
These statements satisfy the third requirement. 
e. Good Faith 
10 of 33 
Case 1:22-cv-02237-SEG     Document 5     Filed 07/05/22     Page 11 of 34

Finally, the fourth requirement to proceed IFP on appeal is good faith. The test for whether 
an appeal is taken in good faith under section 1915(a) is whether the litigant seeks appellate review 
of any issue that is not frivolous. Mixon v. Corizon, Inc., 2012 WL 1136331 at *2 (S.D. Ala. Mar. 
30, 2012). A claim is frivolous if it is "without ·arguable merit either in law or fact." Bilal v. Driver, 
251 F.3d 1346, 1349 (11th Cir. 2001). In this case, the issues on appeal, as listed above, are not 
frivolous. 
To summarize, Plaintiff Raissa Djuissi Kengne has satisfied the four (4) requirements for 
proceeding IFP on appeal, and therefore, her Motion to Proceed in IFP (Exhibit 6) should be 
granted. 
II. 
JURISDICTION AND VENUE - APPEAL 
This Application for Interlocutory Appeal is brought pursuant to 28 U.S. Code§ 1292; 
(a) Except as provided in subsections (c) and (d) of this section, the courts of appeals shall have 
jurisdiction of appeals from: 
(1) Interlocutory orders of the district courts of the United States, the United States District 
Court for the District of the Canal Zone, the District Court of Guam, and the District Court of the 
Virgin Islands, or of the judges thereof, granting, continuing, modifying, refusing or dissolving 
injunctions, or refusing to dissolve or modify injunctions, except where a direct review may be 
had in the Supreme Court; 
(2) Interlocutory orders appointing receivers, or refusing orders to wind up receiverships 
or to take steps to accomplish the purposes thereof, such as directing sales or other disposals of 
property; 
11 of 33 
Case 1:22-cv-02237-SEG     Document 5     Filed 07/05/22     Page 12 of 34

(3) Interlocutory decrees of such district courts or the judges thereof determining the rights 
and liabilities of the parties to admiralty cases in which appeals from final decrees are allowed. 
(b) When a district judge, in making in a civil actibn an order not otherwise appealable under this 
section, shall be of the opinion that such order involves a controlling question of law as to which 
there is substantial ground for difference of opinion and that an immediate appeal from the order 
may materially advance the ultimate termination of the litigation, he shall so state in writing in 
such order. The Court of Appeals which would have jurisdiction of an appeal of such action may 
thereupon, in its discretion, permit an appeal to be taken from such order, if application is made to 
it within ten days after the entry of the order: Provided, however, That application for an appeal 
hereunder shall not stay proceedings in the district court unless the district judge or the Court of 
Appeals or a judge thereof shall so order. 
(c) The United States Court of Appeals for the Federal Circuit shall have exclusive jurisdiction-
( 1) of an appeal from an interlocutory order or decree described in subsection (a) or (b) of 
this section in any case over which the court would have jurisdiction of an appeal under section 
1295 of this title; and 
(2) of an appeal from a judgment in a civil action for patent infringement which would 
otherwise be appealable to the United States Court of Appeals for the Federal Circuit and is final 
except for an accounting. 
(d) 
(1) When the chief judge of the Court of International Trade issues an order under the 
provisions of section 256(b) of this title, or when any judge of the Court of International Trade, in 
issuing any other interlocutory order, includes in the order a statement that a controlling question 
of law is involved with respect to which there is a substantial ground for difference of opinion and 
12 of 33 
Case 1:22-cv-02237-SEG     Document 5     Filed 07/05/22     Page 13 of 34

that an immediate appeal from that order may materially advance the ultimate termination of the 
litigation, the United States Court of Appeals for the Federal Circuit may, in its discretion, permit 
an appeal to be taken from such order, if application is made to that Court within ten days after the 
entry of such order. 
(2) When the chief judge of the United States Court of Federal Claims issues an order under 
section 798(b) of this title, or when any judge of the United States Court of Federal Claims, in 
issuing an interlocutory order, includes in the order a statement that a controlling question of law 
is involved with respect to which there is a substantial ground for difference of opinion and that 
an immediate appeal from that order may materially advance the ultimate termination of the 
litigation, the United States Court of Appeals for the Federal Circuit may, in its discretion, permit 
an appeal to be taken from such order, if application is made to that Court within ten days after the 
entry of such order. 
(3) Neither the application for nor the granting of an appeal under this subsection shall stay 
proceedings in the Court oflntemational Trade or in the Court of Federal Claims, as the case may 
be, unless a stay is ordered by a judge of the Court oflntemational Trade or of the Court of Federal 
Claims or by the United States Court of Appeals for the Federal Circuit or a judge of that court. 
(4) 
(A) The United States Court of Appeals for the Federal Circuit shall have exclusive 
jurisdiction of an appeal from an interlocutory order of a district court of the United States, 
the District Court of Guam, the District Court of the Virgin Islands, or the District Court 
for the Northern Mariana Islands, granting or denying, in whole or in part, a motion to 
transfer an action to the United States Court of Federal Claims under section 1631 of this 
title. 
13 of33 
Case 1:22-cv-02237-SEG     Document 5     Filed 07/05/22     Page 14 of 34

(B) When a motion to transfer an action to the Court of Federal Claims is filed in a 
district court, no further proceedings shall be taken in the district court until 60 days after 
the court has ruled upon the motion. If an appeal is taken from the district court's grant or 
denial of the motion, proceedings shall be further stayed until the appeal has been decided 
by the Court of Appeals for the Federal Circuit. The stay of proceedings in the district court 
shall not bar the granting of preliminary or injunctive relief, where appropriate and where 
expedition is reasonably necessary. However, during the period in which proceedings are 
stayed as provided in this subparagraph, no.transfer to the Court of Federal Claims pursuant 
to the motion shall be carried out. 
( e) The Supreme Court may prescribe rules, in accordance with section 2072 of this title, to provide 
for an appeal of an interlocutory decision to the courts of appeals that is not otherwise provided 
for under subsection (a), (b), (c), or (d). 
III. 
JURISDICTION AND VENUE - COMPLAINT AND 
REQUEST FOR INJUNCTION 
The Plaintiffs case against ID.ME, Inc. falls under the following U.S. Civil Statutes. 
a. 
42 U.S.C. § 1104 Unemployment Trust Fund 
b. 
26 U.S.C. 3301 et seq. Federal Unemployment Tax Act 
c. 
O.C.G.A. § 34-8-45 Supplemental unemployment benefits 
d. 
14th Amendment Section 1. 
This Court has subject matter jurisdiction over this case because the Plaintiffs claims arise 
under the laws of the State of Georgia and the United States. It has jurisdiction over the Plaintiffs 
state law and regulations claims because they are so closely related to the federal claims as to form 
14 of33 
Case 1:22-cv-02237-SEG     Document 5     Filed 07/05/22     Page 15 of 34

part of the same case or controversy. The N orthem District of Georgia consists of four ( 4) divisions 
as outlined and described in 28 U.S.C. § 90. The Atlanta Division comprises the counties of 
Cherokee, Clayton, Cobb, DeKalb, Douglas, Fulton, Gwinnett, Henry, Newton, and Rockdale. 
Pursuant to 28 U.S. Code § 1391, a civil action may be brought in a judicial district in 
which a substantial part of the events or omissions giving rise to the claim occurred, or a substantial 
part of property that is the subject of the action is situated. 
Pursuant to 28 U.S. Code§ 1391, for purposes of venue in a State, which has more than 
one judicial district and in which a defendant that is a corporation is subject to personal jurisdiction 
at the time an action is commenced, such corporation shall be deemed to reside in any district in 
that State within which its contacts would be sufficient to subject it to personal jurisdiction if that 
district were a separate State, and, if there is no such district, the corporation shall be deemed to 
reside in the district within which it has the most significant contacts. 
Pursuant to 28 U.S. Code§ 1343, Civil rights and elective franchise, the Northern District 
Court of the State of Georgia has authority: 
(1) 
To recover damages for injury to his person or property, or because of the 
deprivation of any right or privilege of a citizen of the United States, by any act done in 
furtherance of any conspiracy mentioned in section 1985 of Title 42; 
(2) 
To recover damages from any person who fails to prevent or to aid in 
preventing any wrongs mentioned in section 1985 of Title 42 which he had knowledge 
were about to occur and power to prevent; 
(3) 
To redress the deprivation, under color of any State law, statute, ordinance, 
regulation, custom or usage, of any right, privilege or immunity secured by the Constitution 
15 of 33 
Case 1:22-cv-02237-SEG     Document 5     Filed 07/05/22     Page 16 of 34

of the United States or by any Act of Congress providing for equal rights of citizens or of 
all persons within the jurisdiction of the United States; 
(4) 
To recover damages or to secure equitable or other relief under any Act of 
Congress providing for the protection of civil rights, including the right to vote; 
(5) 
To exercise such other powers, not contrary to the Constitution, as are or 
may be given to such courts by law. 
Venue is proper in this Court because all or a substantial part of the conduct and 
violations giving rise to the claims in the case occurred in the State of Georgia. See O.C.G.A § 
14-2-510, O.C.G.A § 9-10-91, O.C.G.A § 9-10-93, O.C.G.A § 9-10-31, and O.C.G.A § 9-10-34. 
This Court has personal jurisdiction over Defendant ID.ME, Inc. because Defendant 
ID.Me, Inc, through its agents committed the acts that are the subject matter of this lawsuit in the 
State of Georgia. See O.C.G.A § 14-2-510, O.C.G.A § 9-10-91, O.C.G.A § 9-10-93, O.C.G.A § 
9-10-31, and O.C.G.A § 9-10-34. 
This Court has personal jurisdiction over Defendant ID.Me, Inc. because Defendant 
ID.Me, Inc. and its agents and employees, have ongoing and systematic contacts with the State 
of Georgia, maintains headquarter offices in the State of Georgia, and reside in the State of 
Georgia, and have committed the acts that are the subject matter of this lawsuit in the state of 
Georgia. 
Venue is proper in this Court because Defendant ID.Me, Inc.'s conducts substantial 
business in Fulton County, Atlanta, Georgia. 
PlaintiffRaissa Djuissi Kengne has standing to bring this Complaint in Court because she 
will be adversely affected by the actions of the Defendant and will be subject to undue harm if 
Defendant does not allow Plaintiff to have access to her ID .Me account. 
16 of33 
Case 1:22-cv-02237-SEG     Document 5     Filed 07/05/22     Page 17 of 34

Accordingly, venue is proper pursuant to 28 U.S.C. § 90, 28 U.S. Code§ 1391, 28 U.S. 
Code§ 1343, and Georgia Civil Practice and Corporations, Partnerships, And Associations Code 
§ 15-6-8, O.C.G.A § 14-2-510, O.C.G.A § 9-10-91, O.C.G.A § 9-10-93, O.C.G.A § 9-10-31, 
O.C.G.A § 9-10-34. 
IV. 
STATEMENT OF THE CASE 
a. Timeline: 
Plaintiff signed up for an ID.me account on April 22nd, 2022 at Georgia DOL to receive 
unemployment benefits. Plaintiff was unable to create an ID.Me account and contacted ID.Me 
customer support on May 16th, 2022. Plaintiff received an email from ID.Me stating that "A 
Member Support Representative will be reaching out as soon as possible with assistance. For your 
records, your ticket number is 10770653." Plaintiff received additional emails from Shamora 
(Member Support Associate) on May 17th, 2022 and nothing since then despite several emails 
from Plaintiff. Plaintiff received an email from John (Member Support Associate) on May 27th, 
2022 and shortly thereafter, had a video conference call with John to validate Plaintiffs identity. 
Plaintiff is still not able to access her account on ID.Me in order to receive unemployment benefits. 
b. Facts: 
Plaintiff signed up for an ID.me account on April 22nd, 2022 at Georgia DOL to receive 
unemployment benefits. Plaintiff was unable to create an ID.Me account and contacted ID.Me 
customer support on May 16th, 2022. Plaintiff received an email from ID.Me stating that "A 
Member Support Representative will be reaching out as soon as possible with assistance. For your 
records, your ticket number is 10770653." Plaintiff received additional emails from Shamora 
17of33 
Case 1:22-cv-02237-SEG     Document 5     Filed 07/05/22     Page 18 of 34

(Member Support Associate) on May 17th, 2022 and nothing since then despite several emails 
from Plaintiff. Plaintiff received an email from John (Member Support Associate) on May 27th, 
2022 and shortly thereafter, had a video conference call with John to validate Plaintiffs identity. 
Plaintiff is still not able to access her account on ID.Me in order to receive unemployment benefits. 
c. Irreparable Injury: 
Preventing Plaintiffs access to unemployment benefits will cause "irreparable harm" 
because Plaintiff will not be able to pay for housing or food. In addition, Plaintiff was 
constructively discharged from BDO USA, her former employment, because of retaliation after 
notifying her supervisor, the SEC, and the PCAOB of unethical behaviors that are in violation of 
SEC regulations and PCAOB standards exhibited by Wesley Freeman, Scott Meier, Peter Poppo, 
Paul Davidson, Mark Davenport, and Johnson Wong at the following public companies and their 
affiliates: Interface, Atlanticus, BioHorizons (Henry Schein's subsidiary), Otelco, BlueLinx, NMS 
SPAR (subsidiary of SPAR). Since Plaintiff filed a complaint with the SEC and the PCAOB, her 
home has been broken into. Her phones and computers have been hacked. (Case No. 
2022CV365268) Also, Plaintiff has been unable to access the limited amount of money she had 
invested on the Gemini platform. Furthermore, the economy has not yet fully recovered and 
Plaintiff is dealing with a complex set of issues such as non-existent income due to being 
blacklisted in the industry and ongoing concerns about the pandemic. 
A loss of housing or medical care and the inability to provide food, shelter and adequate 
childcare for a family constitute irreparable harm pending resolution of this cause of action and 
are not adequately compensable by an award of damages. 
18 of33 
Case 1:22-cv-02237-SEG     Document 5     Filed 07/05/22     Page 19 of 34

V. 
ENUMERATION OF ERRORS AND CITATION TO 
AUTHORITY 
A. Objections, Responses, and Arguments to Statement of Analysis 1: 
United Stated Magistrate Judge Catherine M. Salinas asserts in the Final Report And 
Recommendation And Order issued in relation to the Plaintiff's Original Complaint, Injunction 
For Relief, And Declaratory Judgment that "The affidavit of poverty submitted by Plaintiff 
indicates that over the past twelve months, Plaintiff, has earned an average monthly income of 
$7,500 from her employment and retirement, which amounts to $90,000 on an annual basis." 
The information and interpretations presented in the Report related to the Plaintiff's 
financial situation are incomplete and are therefore not facts. Plaintiff's monthly income over the 
past seven and a half (7.5) months is $0.00. 
Plaintiff did not leave her job; Plaintiff was constructively discharged. The Occupational 
Safety and Health Administration ("OSHA") defines Constructively Discharged as "quitting when 
an employer makes working conditions intolerable due to the employees' protected activity)", 
which Plaintiff performed as a Whistleblower and rendered a service to the community. Plaintiff 
has opened a complaint with OSHA. 
In addition, Plaintiff has provided in Exhibit 1 herein evidence showing that her home was 
broken into, she was blacklisted from her industry, and prevented to find a job in line with her· 
qualifications due to the subject matter of case number 2022CV365268 filed in Fulton County 
Superior Court. 
Plaintiff has utilized all her retirement savings in order to pay for the security and safety of 
her family, which is also related to the subject matter of case number 2022CV365268 filed in 
19 of 33 
Case 1:22-cv-02237-SEG     Document 5     Filed 07/05/22     Page 20 of 34

Fulton County Superior Comi. Therefore, the average monthly income of $7,500 from Plaintiffs 
employment and retirement, does not reflect the fact that the money was used for safety and 
security expenses in view of the threats Plaintiff and her family were faced with. Plaintiffs 
priorities were and are perfectly aligned to the law of God and the thought process of any 
reasonable person. In view of the subject matter in case number 2022CV365268, Plaintiffs family 
came first and she spent a considerable amount of money to ensure their security and safety. 
Further, Plaintiff has provided in Exhibits 2 and 3 herein evidence that she was not able to 
receive unemployment benefits since her constructive discharge on November 18th, 2022. The 
Plaintiffs lawsuit against ID.Me, Inc. is to allow Plaintiff to receive her unemployment benefits. 
The Plaintiff lawsuit against ID.ME, Inc. is documented in case file number 1 :22-CV-2237. 
Based on the information provided above, Plaintiff is unable to pay the legal filing fees 
because she does not have any income and is being blacklisted from the industry she works in. 
B. Objections, Responses, and Arguments Statement of Analysis 2: 
United Stated Magistrate Judge Catherine M. Salinas asserts in the Final Report And 
Recommendation And Order issued in relation to the Plaintiffs Original Complaint, Injunction 
For Relief, And Declaratory Judgment that "Before she left her most recent employment, she was 
earning $9,583.00 per month." 
The information and interpretations presented in the Report related to the Plaintiffs 
financial situation are incomplete and are, therefore, not facts. 
Plaintiff did not leave her job; Plaintiff was constructively discharged. The Occupational 
Safety and Health Administration ("OSHA") defines Constructively Discharged as "quitting when 
an employer makes working conditions intolerable due to the employees' protected activity)", 
20 of33 
Case 1:22-cv-02237-SEG     Document 5     Filed 07/05/22     Page 21 of 34

which Plaintiff performed as a Whistleblower and rendered a service to the community. Plaintiff 
has filed a complaint with OSHA. 
Plaintiffs monthly income over the past seven.and a half (7.5) months is $0.00. 
Plaintiff has utilized all her retirement savings, including her income she earned prior to 
being constructively discharged, in order to pay for the security and safety of her family, which is 
also related to the subject matter of case number 2022CV365268 filed in Fulton County Superior 
Court. Therefore, the average monthly income of $7,500 from Plaintiffs employment and 
retirement, does not reflect that the money was used for safety and security in view of the threats 
Plaintiff and her family were facing. Plaintiffs priorities were and are perfectly aligned to the law 
of God and the thought process of any reasonable person. In view of the subject matter in case 
number 2022CV365268, Plaintiffs family came first and she spent a considerable amount of 
money to ensure their security and safety. 
Further, Plaintiff has provided in Exhibits 2 and 3 herein evidence showing that she was 
not able to receive unemployment benefits since her constructive discharge on November 18th, 
2022. The Plaintiffs lawsuit against ID.Me, Inc. is to allow Plaintiff to receive her unemployment 
benefits. 
Based on the information provided above, Plaintiff is unable to pay the legal filing fees 
because she does not have any income and is being blacklisted from the industry she works in. 
C. Objections, Responses, and Arguments Statement of Analysis 3: 
United Stated Magistrate Judge Catherine M. Salinas asserts in the Final Report And 
Recommendation And Order issued in relation to the Plaintiffs Original Complaint, Injunction 
For Relief, And Declaratory Judgment that Plaintiff "owns a condominium valued at 
21 of 33 
Case 1:22-cv-02237-SEG     Document 5     Filed 07/05/22     Page 22 of 34

approximately $500,000, a land lot worth $55,000, and an abandoned house worth approximately 
$200,000." 
The facts presented in the Report related to the Plaintiffs financial situation are 
incomplete. Plaintiffs liabilities on the properties listed, particularly the condominium, the land, 
and the abandoned house as well as the state of pre-foreclosure on certain of the said properties 
were not taken into consideration by the Judge of the Magistrate Court. Plaintiff does not have 
significant equity in the land and the house. Due to the foreclosure process, Plaintiff may not 
receive any funds from the sale of those properties. 
Plaintiff has provided in Exhibit 4 herein evidence showing that the said properties are at 
risk of foreclosure. The abandoned and inhabitable house worth approximately $200,000 is 
mortgaged with Delta Community Credit Union. The land lot worth approximately $55,000 is 
mortgaged with AGSOUTH Farm Credit, ACA. Both properties are under foreclosure notices as 
shown in Exhibit 4. 
Plaintiffs main asset is the condominium with a value of approximately $500,000, which 
is Plaintiffs primary residence and is subject to a mortgage that Plaintiff is also unable to pay due 
to the subject matter of case number 2022CV365268 filed in Fulton County Superior Court. 
In addition, Plaintiff has provided in Exhibit 2 herein evidence showing that her home was 
broken into, she was blacklisted from her industry, and prevented to find a job in line with her 
qualifications due to the subject matter of case number 2022CV365268 filed in Fulton County 
Superior Court. 
Further, Plaintiff has provided in Exhibits 2 and 3 herein evidence showing that she was 
not able to receive unemployment benefits since her constructive discharge on November 18th, 
22 of 33 
Case 1:22-cv-02237-SEG     Document 5     Filed 07/05/22     Page 23 of 34

2022. The Plaintiffs lawsuit against ID.Me, Inc. is to allow Plaintiff to receive her unemployment 
benefits. 
Based on the information p~ovided above, Plaintiff is unable to pay the legal filing fees 
because she does not have any income and is being blacklisted from the industry she works in. 
D. Objections, Responses, and Arguments Response To Statement of Analysis 4: 
United Stated Magistrate Judge Catherine M. Salinas asserts in the Final Report And 
Recommendation And Order issued in relation to the Plaintiffs Original Complaint, Injunction 
For Relief, And Declarato~ Judgment that "Plaintiffs allegations of poverty are not fully 
supported by the record. With an annual income of approximately $90,000, Plaintiff is well above 
the poverty level." 
The information and interpretations presented in the Report related to the Plaintiffs 
financial situation are incomplete and are therefore not facts. Plaintiffs monthly income over the 
past seven and a half (7 .5) months is $0.00. 
Plaintiff did not leave her job; Plaintiff was constructively discharged. The Occupational 
Safety and Health Administration ("OSHA") defines Constructively Discharged as "quitting when 
an employer makes working conditions intolerable due to the employees' protected activity)", 
which Plaintiff performed as a Whistleblower and rendered a service to the community. Plaintiff 
has filed a complaint with OSHA. 
In addition, Plaintiff has provided in Exhibit 2 herein evidence showing that her home was 
broken into, she was blacklisted from her industry, and prevented to find a job in line with her 
qualifications due to the subject matter of case number 2022CV365268 filed in Fulton County 
Superior Court. 
23 of33 
Case 1:22-cv-02237-SEG     Document 5     Filed 07/05/22     Page 24 of 34

Plaintiff has utilized all her retirement savings in order to pay for the security and safety of 
her family, which is also related to the subject matter of case number 2022CV365268 filed in 
Fulton County Superior Court. Therefore, the average monthly income of $7,500 from Plaintiffs 
employment and retirement, does not reflect that the money was used for safety and security in 
view of the threats Plaintiff and her family were faced with. Plaintiffs priorities were and are 
perfectly aligned to the law of God and the thought process of any reasonable person. In view of 
the subject matter in case number 2022CV365268, Plaintiffs family came first and she spent a 
considerable amount of money to ensure their security and safety. 
Further, Plaintiff has provided in Exhibits 2 and 3 herein evidence that she was not able to 
receive unemployment benefits since her constructive discharge on November 18th, 2022. The 
Plaintiffs lawsuit against ID.Me, Inc. is to allow Plaintiff to receive her unemployment benefits. 
Based on the information provided above, Plaintiff is unable to pay the legal filing fees 
because she does not have any income and is being blacklisted from the industry she works in. 
E. Objections, Responses, and Arguments To Statement of Analysis 5: 
United Stated Magistrate Judge Catherine M. Salinas asserts in the Final Report And 
Recommendation And Order issued in relation to the Plaintiffs Original Complaint, Injunction 
For Relief, And Declaratory Judgment that "Although Plaintiff lists average monthly expenses of 
$13,125.00, some of the discretionary amounts for one person seem unnecessarily high, such as 
$1,000 for food, $200 for laundry and dry cleaning, and $6,000 in monthly credit card installment 
payments to Bank of America, Citi Bank, and American Express. Although Plaintiff may have 
limited funds and may have other priorities for those funds, I believe that she is able to pay the 
required $402 filing fee and should do so of she wishes to pursue this case. For the reasons stated, 
24 of33 
Case 1:22-cv-02237-SEG     Document 5     Filed 07/05/22     Page 25 of 34

I find thar Plaintiff has sufficient means to pay the filing fee and incur the costs of these 
proceedings. Thus, Plaintiffs request to proceed IFP is DENIED." 
Plaintiff $1,000 for food would include all her grocery items, including toilet paper and 
cleaning products, which is not uncommon in the city where Plaintiff lives. 
Plaintiffs expense for laundry and dry-cleaning amounting to approximately $200 was 
prior to her constructive discharge on November 18th, 2022 as shown in Exhibit 3. Since then, 
Plaintiff has focused her efforts into ensuring the security and safety of her family. Plaintiff is now 
looking for justice for herself and her family. 
Plaintiffs monthly income over the past seven and a half (7.5) months is $0.00. 
Plaintiff did not leave her job; Plaintiff was constructively discharged. The Occupational 
Safety and Health Administration ("OSHA") defines Constructively Discharged as "quitting when 
an employer makes working conditions intolerable due to the employees' protected activity)", 
which Plaintiff performed as a Whistleblower and rendered a service to the community. Plaintiff 
has opened a complaint with OSHA. Plaintiff has filed a complaint with OSHA. 
In addition, Plaintiff has provided in Exhibit 2 herein evidence showing that her home was 
broken into, she was blacklisted from her industry, and prevented to find a job in line with her 
qualifications due to the subject matter of case number 2022CV365268 filed in Fulton County 
Superior Court. 
Plaintiff has utilized all her retirement savings in order to pay for the security and safety of 
her family, which is also related to the subject matter of case number 2022CV365268 filed in 
Fulton County Superior Court. Therefore, the average monthly income of $7,500 from Plaintiffs 
employment and retirement, does not reflect that the money was used for safety and security in 
view of the threats Plaintiff and her family were faced with. Plaintiffs priorities were and are 
25 of33 
Case 1:22-cv-02237-SEG     Document 5     Filed 07/05/22     Page 26 of 34

perfectly aligned to the law of God and the thought process of any reasonable person. In view of 
the subject matter in case number 2022CV365268, Plaintiffs family came first and she spent a 
considerable amount of money to ensure their security and safety. 
Further, Plaintiff has provided in Exhibit 3 herein evidence that she was not able to receive 
unemployment benefits since her constructive discharge on November 18th, 2022. The Plaintiffs 
lawsuit against ID.Me, Inc. is to allow Plaintiff to receive her unemployment benefits. 
Based 
on the information provided above, Plaintiff is unable to pay the legal filing fees because she does 
not have any income and is being blacklisted from the industry she works in. 
F. Objections, Responses, and Arguments To Statement of Analysis 6: 
United Stated Magistrate Judge Catherine M. Salinas asserts in the Final Report And 
Recommendation And Order issued in relation to the Plaintiff's Original Complaint, Injunction 
For Relief, And Declaratory Judgment that "Before she left her most recent employment, she was 
earning $9,583.00 per month." 
The information and interpretations presented in the Report related to the Plaintiff's 
financial situation are incomplete and are, therefore, not facts. 
Plaintiff did not leave her job; Plaintiff was constructively discharged. The Occupational 
Safety and Health Administration ("OSHA") defines Constructively Discharged as "quitting when 
an employer makes working conditions intolerable due to the employees' protected activity)", 
which Plaintiff performed as a Whistleblower and rendered a service to the community. Plaintiff 
has opened a complaint with OSHA. 
Plaintiffs monthly income over the past seven and a half (7.5) months is $0.00. 
Plaintiff has utilized all her retirement savings, including her income she earned prior to 
being constructively discharged, in order to pay for the security and safety of her family, which is 
26 of 33 
Case 1:22-cv-02237-SEG     Document 5     Filed 07/05/22     Page 27 of 34

also related to the subject matter of case number 2022CV365268 filed in Fulton County Superior 
Court. Therefore, the average monthly income of $7,500 from Plaintiffs employment and 
retirement, does not reflect that the money was used for safety and security in view of the threats 
Plaintiff and her family were facing. Plaintiffs priorities were and are perfectly aligned to the law 
of God and the thought process of any reasonable person. In view of the subject matter in case 
number 2022CV365268, Plaintiffs family came first and she spent a considerable amount of 
money to ensure their security and safety. 
Further, Plaintiff has provided in Exhibit 3 herein evidence that she was not able to receive 
unemployment benefits since her constructive discharge on November 18th, 2022. The Plaintiffs 
lawsuit against ID.Me, Inc. is to allow Plaintiff to receive her unemployment benefits. 
On December 6, 2019, the Second Circuit (Calabresi, Pooler, Park) issued a published per 
curiam decision in United States v. Kosic (Nunez), concerning the defendant-appellant's motion 
for in forma pauperis ("IFP") status in his direct criminal appeal. The appellant's motion arose 
from a district court order denying his IFP motion based on a finding that the appeal would be 
frivolous pursuant to 28 U.S.C. §1915. In its published decision, the Second Circuit granted the 
motion and held that it is proper to consider only the defendant's financial eligibility-and not the 
merits-when deciding motions for IFP status and appointment of counsel under the Criminal 
Justice Act ("CJA") in a direct criminal appeal. 
As the Court explained, a litigant seeking IFP status on appeal generally must first seek a 
ruling in the district court. If the district court denies the motion and finds that an appeal cannot be 
taken in good faith, then the defendant may seek an IFP determination from the appellate court. 
When the appellate court reviews such motions, it applies different standards depending on 
27 of33 
Case 1:22-cv-02237-SEG     Document 5     Filed 07/05/22     Page 28 of 34

whether the case is civil or criminal. In the civil context, the Court considers the merits of an 
appeal. 
Plaintiff has provided in Exhibit 5 evidence showing her expenses and that she could no 
longer draw from her credit cards. 
Plaintiff has provided herein evidence that her request to proceed in IFP was not frivolous 
or malicious. Based on the information and documents provided herein, Plaintiff is unable to pay 
the legal filing fees because she does not have any income and is being blacklisted from the 
industry she works in. 
G. Plaintiffs Request Related To Her Motion To Proceed in Form a Pauperis 
Plaintiff hereby requests that her motion to proceed in IFP be reconsidered by the Court 
for her case against ID.Me, Inc. (1 :22-CV-2297) as well as her cases against ID.ME, Inc. (case file 
number 1:22-CV-2237), and AGSOUTH FARM CREDIT, ACA (case file number l:22-CV-
2263). 
H. Plaintiffs Additional Filing 
Plaintiff filed a corresponding Plaintiffs Motion For Reconsideration of Plaintiffs Motion 
to Proceed in Format Pauperis under case number 1 :22-CV-2297 in June 21st, 2022 titled 
"OBJECTIONS to 4 Report and Recommendation" along with attachments and exhibits that were 
entered on 06/22/2022. 
28 of33 
Case 1:22-cv-02237-SEG     Document 5     Filed 07/05/22     Page 29 of 34

1!bmilll 
R:--in>iDfoinlK~t: 
,. 
Udu.dant 
rt'l,'f(Mtll'l:d ls-.! RaitnDjunliKu•p• 
f,(Jpi,J,ao,.::::A~eNE 
•i~I~ 
Al!.,..~GAi-:>:-m: 
l'R(!Si: 
VI. 
ARGUMENTS AND CITATIONS TO AUTHORITY 
1. The 14th Amendment - Title I 
Plaintiff re-alleges and incorporates each and every paragraph of this PLAINTIFF'S 
COMPLAINT AND REQUEST FOR INJUNCTION (case number 1:22-CV-2237) and the facts 
as if set forth here in full for all purposes. 
The 14th Amendment Section 1 states that "All persons born or naturalized in the United 
States, and subject to the jurisdiction thereof, are citizens of the United States and the State wherein 
they reside. No State shall make or enforce any law which shall abridge the privileges· or 
immunities of citizens of the United States; nor shall any State deprive any person of life, liberty, 
or property, without due process of law; nor deny to any person within its jurisdiction the equal 
protection of the laws. 
Plaintiff asserts in her Complaint and Request For Injunction that preventing Plaintiffs 
access to unemployment benefits will cause "irreparable harm" because Plaintiff will not be able 
to pay for her food, her mortgage, healthcare, and safety. 
Plaintiff was constructively discharged fro!-11 BDO USA, her former employment, because 
of her status as a whistleblower and _ the retaliatory practices she faced after notifying her 
supervisor, the SEC, and the PCAOB of unethical behaviors that are in violation of SEC 
29 of 33 
Case 1:22-cv-02237-SEG     Document 5     Filed 07/05/22     Page 30 of 34

regulations and PCAOB standards exhibited by Wesley Freeman, Scott Meier, Peter Poppo, Paul 
Davidson, Mark Davenport, and Johnson Wong at the following ~ublic companies and their 
affiliates: Interface, Atlanticus, BioHorizons (Henry Schein's subsidiary), Otelco, BlueLinx, NMS 
SP AR (subsidiary_ of ~PAR). 
Since Plaintiff filed a complaint with the SEC and the PCAOB, her home has' been broken 
into. Her phones and computers have been hacked. (Case No. 2022CV365268) Also, 
Plaintiff has been unable to access the limited amount of money she had invested. on the 
Gemini platform. 
Furthermore, the economy has not yet fully recovered and Plaintiff is dealing with a 
complex set of issues such as non-existent income due to being blacklisted in the industry as well 
as ongoing concerns about the pandemic.· 
Because of the delay and refusal to provide Plaintiff with an ID.Me account, ID.Me has 
contributed to Plaintiff not being able to receive income from her unemployment and has rendered 
more difficult the current financial hardship experienced by Plaintiff, including but not limited to 
the ability to pay for food, mortgage and healthcare. 
A loss of housing or medical care and the inability to provide food, shelter and adequate 
healthcare constitute irreparable harm and are not adequately compensable by an award of 
damages. 
If every person is afforded an opportunity to have food, shelter, and adequate healthcare, 
it is ensured that his or her rights to pursue happiness, life, and liberty are not violated. By delaying 
' 
and preventing Plaintiff to have access to her ID.Me account, ID.Me, is wrongfully, illegally, 
and/or unlawful depriving Plaintiff of food, shelter, and adequate healthcare. 
30 of 33 
Case 1:22-cv-02237-SEG     Document 5     Filed 07/05/22     Page 31 of 34

Defendant ID.Me has violated Plaintiffs unalienable rights under the 14th Amendment 
Title I by delaying and preventing Plaintiff to have access to her ID.Me.account; thereby, violating 
Plaintiffs right to Life, Liberty and the pursuit of Happiness as well as due process. 
2. The 14th Amendment- Public Health, Safety, and Morals 
Plaintiff re-alleges and incorporates each and every paragraph of this PLAINTIFF'S 
COMPLAINT AND REQUEST FOR INJUNCTION (case number 1:22-CV-2237) and the facts 
as if set forth here in full for all purposes. 
The 14th Amendment also applies to Health, Safety, and Morals. The Fourteenth 
Amendment Rights Guaranteed Privileges And Immunities of Citizenship, Due Process And Equal 
Protection states that "Even under the narrowest concept of the police power. as limited by 
substantive due process, it was generally conceded that states could exercise the power to protect 
the public health, safety, and morals. 
Plaintiff asserts in her Complaint and Request For Injunction that ID .Me violated Plaintiffs 
14th Amendment by delaying and preventing Plaintiffs access to her ID.Me account. Food, 
shelter, and healthcare are basic human rights. Plaintiff asserts that access to food, shelter, and 
healthcare are critical component to the prosperity, safety and general well-being of every human 
being. Without her ID.Me account, Plaintiff is not able to pay for adequate food, healthcare, 
shelter, and safety. 
Defendant ID.Me has violated Plaintiffs unalienable rights under the second paragraph of 
the American Declaration of Independence by delaying and preventing Plaintiffs access to her 
ID.Me account, thereby, violating Plaintiffs rights to Life, Liberty and the pursuit of Happiness, 
to due process, and to Health, Safety, and Morals. 
31 of 33 
Case 1:22-cv-02237-SEG     Document 5     Filed 07/05/22     Page 32 of 34

3. Claim and Prayer For Relief: 
In evaluating the legal sufficiency of a complaint for purposes of§ 1915( d), the courts apply 
the customary standard enunciated in Conley v. Gibson, 355 U.S. 41, 45-46, 78 S.Ct b. 99, 101-
. 102, 2 L.Ed.2d 80 (1957), that a complaint should not be dismissed for failure to state a claim 
unless it appears beyond doubt that the Plaintiff can prove no set of facts in support of his or her 
claim, which would entitle him or her to relief. Plaintiff can prove to facts to support her claims 
and has provided evidence to support her claims.· 
Plaintiffs Prayers for Relief to the Court in Plaintiffs Complaint and Request For 
Injunction include, but is not iimited to, a Court's request to "Grant any such additional relief to 
. 
. 
Plaintiff in law or equity as _the Court deems just and proper under the circumstances." Plaintiffs 
request includes actual and punitive damages. 
VII. 
CONCLUSION 
For the foregoing reasons, Appellant Raissa Djuissi Kengne respectfully requests that this 
Court answer the Appellant's Motion to Proceed in Forma Pauperis presented in the affirmative, 
hold that the Court erred in denying the Motion to Proceed in Forma Pauperis, and direct that the 
Motion to Proceed in Forma Pauperis be approved. 
VIII. 
CERTIFICATION 
Under Federal Rule of Civil Procedure 11, I certify to the best of my knowledge, 
information, and belief that this complaint: ( 1) is not being presented for an improper purpose, 
such as to harass, cause unnecessary delay, or needlessly increase the cost of litigation; (2) is 
supported by existing law or by a nonfrivolous argument for extending, modifying, or reversing 
32 of 33 
Case 1:22-cv-02237-SEG     Document 5     Filed 07/05/22     Page 33 of 34

existing law; (3) the factual contentions have evidentiary support or, if specifically so identified, 
will likely have evidentiary support after a reasonable opportunity for further investigation or 
discovery; and (4) the complaint otherwise complies with the requirements of Rule 11. 
I agree to provide the Clerk's Office with any changes to my address where case related papers 
may be served. I understand that my failure to keep a current address on file with the Clerk's Office 
may result in the dismissal of my case. 
Dated: July 04, 2022 
Physical Address: 
1280 W. Peachtree ST NW. Unit 2109 
Atlanta, GA 30309 
Telephone: (404) 932-1651 
Email: cianeseya2022@gmail.com 
Jocelyn Algarin 
NOTARY PUBLIC 
Cobb County, GEORGIA 
commission Expires 
08/ 026 
33 of33 
Respectfully submitted, 
Raissa Djuissi Kengne 
Pro Se 
Mailing Address: 
570 Piedmont Ave. NE #55166 
Atlanta, GA 30308 
Case 1:22-cv-02237-SEG     Document 5     Filed 07/05/22     Page 34 of 34

File and source

File

gov.uscourts.gand.304058.5.0.pdf

Size

509,033 bytes

SHA-256

5b1e23d4994c2e39b979c923d6bbe7851398a09dfd2c91ad8e933abfa0bb18bf

Our copy

gov.uscourts.gand.304058.5.0.pdf

Original

PACER (login required)