THE CRIMES OF SENATOR EHIGIE EDOBOR A.K.A. "GODWIN" UZAMERE
1. Home2. Once Upon A Time3. Victim's Statement4. My Search for Justice5. Descent into Hell6. U.S. Laws Violated by Senator Uzamere7. Nigerian Laws Violated by Senator Uzamere8. Ignored by Federal Agencies9. Ignored by Nigerian Authorities10. Victims' Loss of Child Support11. The Uzamere Family12. Municipal Employees Who Helped Senator Uzamere13. John Gray and Non-Profit Legal Community14. Hall of Shame15. 1st Judicial Blow By African-American Judge Thomas16. Law Firm of Allen E. Kaye17. Too Many Discrepancies...18. Allen E. Kaye And His Diabolical Talmud-Following Minions19. Will Sampson Staff Refuse To Help Identity Fraud Victims?20. Law Office of Gladstein & Messinger21. Patrick Synmoie's Attempts to Hide22. Consulate General of Nigeria23. Strange Chat with Senator Ekweremadu24. Proof of Legal Marriage25. Proof of Illegal Marriage/Identity Fraud26. Senator Uzamere's Attempts to Hide Crimes Will Fail27. The Proof...28. Success -- The Proof Is Finally Here!29. Will Senator Uzamere Evade Child Support Again?30. Nigeria's New Commitment to Protect Child Abandoned by Sen. Uzamere31. Judge Prus -- What Gives?32. Back on Track!33. Eugene Uzamere -- Third Attorney to Break the Law34. Petitioner's Verified Petition35. Supplemental Verified Petition36. Judge Prus Recuses Himself37. Eugene's Failed Attempt to Thwart Justice38. Kate Ezomo -- Diabolical Liar39. Letters of Complaint Against Kate Ezomo40. My Factual Response to Imaginary Cousin Godwin41. Federal Action Against Defendant Dismissed42. Open Letters to the FBI43. Open Letter to All U.S. Judges44. Open Letter to Ehigie and Eugene45. Tara's Affidavit46. $100,000,000.00 Lawsuit Against Corrupt Fiduciaries47. Will Fiduciaries Settle?48. New York City Defrauds Disabled Schvartze49. There Is No Cousin Godwin!50. Warning Letter to Governor and Chief Justice of New York State51. Deprived of Child Support by Allen Kaye52. Can International Agency Help?53. Chief Judge Wood's Court54. Will NYS' Dept. Disc. Committee and Commission on Judicial Conduct Be Corrupted?55. Subpoena Planned for Judge Garaufis56. No Negotiations for Justice...Justice is Owed!57. Will Attorneys Sign Affirmation?58. Am I Finally Being Taken Seriously?59. Evidentiary Hearing is Scheduled!60. Amy Feinstein Refuses to Prosecute!61. Robert Juceam's Useless Excuses62. Appellate Brief pages 24 to end63. No Justice -- No Peace!64. Happy Birthday My Beautiful Angel65. Are You A Victim of A Green Card Marriage Scam?66. End Green Card Marriage Sponsorship67. How to Report an Immigration Scammer and the Attorney68. Is The End Finally in Sight?69. Will Appellate Division Justices Decide Fairly?70. What Will NYSCJC's Response Be?71. How Will NYSDDC Respond?72. Will Obama's Administration Coerce Helpless Schvartze's Silence73. Will U.S. Department of State's Secretary Rise To The Challenge?74. Eugene Uzamere Calls It Quits75. Bigot Judge Sunshine Continues Courtroom Corruption76. Schvartze's Complaints Still Ignored By Appellate Division's White Judiciary77. More Talmudic Bias and Anti-Schvartze Racism At SDNY78. Senator Uzamere...You Are The Husband!79. Will U.S. Solicitor General Office Look On Idly?80. What will SCOTUS Do?81. Why did they disobey?82. Cabranes' Fraud Upon The Court83. Is Hinds-Radix Their 'Secret' Weapon?84. New York State Lawsuit for Fraud85. Judge Sunshine Is A Loser86. Judge Sunshine Out of Options87. Petitioner Prepares Request for Rehearing...88. Petition for Rehearing89. Loser Sunshine's Last Hurrah90. Lawsuit Against Daily News and Scott Shifrel91. Mort Zuckerman's Bigoted Tabloid92. Corruption at Nassau County Supreme Court and Nassau County Clerk93. Judge Scuccimarra Ruling94. Defendants Have Defaulted95. Will Judge Parga Accepts Anne Carroll's Drivel Because Defendants Are Rich Jews?96. New York and Anne B. Carroll97. Lawsuit Against President98. Will Obama Listen?99. Open Letter to Al Jazeera, President Obama and Judge Allegra100. More Court Shenanigans?101. Howard U. Schmokescreen102. Into the fire...103. What Will The New York State Division of Human Rights Do?104. Housing Court Corruption105. Mayor Bloomberg's Finest106. FEGS in Criminal Conspiracy107. FEGS Gave Victim No Choice108. What Will The New York State Supreme Court Do?109. What Will Court of Claims Do?110. Abuse of Religion Not New111. How Wicked Are They?112. What Lies???113. Federal Lawsuit114. Disastrous Results to Appeal115. Judge Garaufis' Discriminatory Decision116. Garaufis' Talmudic Shenanigans117. FOIA Hiding Evidence118. Congressional Testimony119. Unintelligible Complaint of Rachel G. Yohalem120. Uzamere v. USA, et al121. Judicial Whores Willy and Patty122. Uzamere v. USA123. Find an Unbiased Court124. U.S. Government Blacklists Own Citizens125. Appellate Brief First Circuit126. U.S. Government Hides Prosecution127. A Jewish RICO128. Jews' Demonic Doctrine -- Law of the Moser129. Mishkin Yanks His Own Nuts130. Will African American Victim of Grand Laceny Receive Justice?131. Judicial Ethics Hypocrite132. Jew Shenanigans Involved in Random Selection of Morally Compromised Judge133. Please save my family!134. Psychopaths135. Jewish Paradigm Put Jews on Top136. Pretender Bharara137. Int'l Complaint Against Israel, United States and Nigeria138. Memorial of Impeachment139. Supplemental Complaint140. Appellate Brief to UN and US141. U.S. Supreme Court Petition -- UN and U.S.142. A Real Man

Federal Lawsuit Against
Andrew M. Cuomo and New York State

Davis Conversation -- Click Here

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK 

___________________________________________

Cheryl D. Uzamere                                                                               Civil Action No.: 11-CV-2831

                                         Plaintiff,                                                      VERIFIED COMPLAINT

             - against -                                                                               JURY TRIAL DEMANDED

Andrew M. Cuomo, in his official capacity as Governor
Of the State of New York; Nirav R. Shah, in his official
capacity  as  Commissioner  of  the   New  York State
Department Of Health; Michael F. Hogan, in his official
capacity as Commissioner Of the New York State Office
Of Mental Health; Ann Pfau, in her official capacity as
Chief Administrative Judge for the New York State
Unified Court System; Roy L. Reardon, in his official
capacity as Chair of the New York State Departmental
Disciplinary Committee, New York State Supreme
Court for the First Judicial Department; State of New
York; the New York State Department Of Health; the
New York State Office Of Mental Health; the New York
State Unified Court System; the Daily News, LP;
Uzamere and Associates, PLLC; Allen E. Kaye, PC;
the Law Offices Of Harvey Shapiro; Gladstein and
Messenger; Federation Employment And Guidance
Service, Interfaith Hospital And Medical Center; New
York Psychotherapy and Roman Catholic Diocese of
Brooklyn

                                       Defendants.

__________________________________________

 

*****Plaintiff Cheryl D. Uzamere, a citizen of the United States and a constituent of federally- and state-funded mental health services, appearing on her own behalf, sues the defendants and alleges:

PRELIMINARY STATEMENT

Defendants Violated Federal Laws With Regard to Plaintiff's Disability

*****1)*****Title II of the Americans With Disabilities Act, 42 U.S.C. §§12131, 12132, prohibits discrimination against individuals with disabilities, including those with mental illness. Similarly, Section 504 of the Rehabilitation Act, 29 U.S.C. §794, provides that no person with a disability, including those with mental illness, shall: “solely by reason of his or her disability, be excluded from participation in, be denied benefits of, or be subjected to discrimination under any program or activity receiving Federal financial assistance.”

*****2)*****In the decision regarding Disability Advocates, Inc. vs. Paterson, et al, the Honorable Nicholas G. Garaufis stated that “The Supreme Court held in Olmstead v. L.C., 527 U.S. 581 (1999), that “[u]njustified isolation . . . is properly regarded as discrimination based on disability,” observing that “institutional placement of persons who can handle and benefit from community settings perpetuates unwarranted assumptions that persons so isolated are incapable of or unworthy of participating in community life.” 527 U.S. at 597, 600. The “integration mandate” of Title II of the American with Disabilities Act, 42 U.S.C. § 12101 et seq., and Section 504 of the Rehabilitation Act, 29 U.S.C. §791 et seq., as expressed in federal regulations and Olmstead, requires that when a state provides services to individuals with disabilities, it must do so “in the most integrated setting appropriate to their needs.” The “most integrated setting,” according to the federal regulations, is “a setting that enables individuals with disabilities to interact with non-disabled persons to the fullest extent possible.” 28 C.F.R. §35.130(d); 28 C.F.R. pt. 35 app. A.

*****3)*****Further, Title II of the Americans With Disabilities Act requires that “a public entity shall administer services, programs, and activities in the most integrated setting appropriate to the needs of qualified individuals with disabilities.” See 28 C.F.R. §35.130(d) (emphasis added).

*****4)*****In the landmark decision Olmstead v. L.C., 527 U.S. 581 (1999), the U.S. Supreme Court held that these provisions of law are violated when a state places people with mental illness in “unjustified isolation,” and that a person with mental illness may sue the state for failing to place him or her “in the most integrated setting appropriate to [his or her] needs.”

*****5)*****Judge Garaufis further stated in the aforementioned decision that Title II of the ADA applies to “any State or local government” and “any department, agency, special purpose district, or other instrumentality of a State or States or local government.” 42 U.S.C. §12131(1). Accordingly, all governmental Defendants in this action are subject to Title II of the Americans With Disabilities Act.”

*****6)*****This action is brought in furtherance of those mandates. Rather than comply with these laws, New York State officials and agencies responsible for the care and treatment of people with mental illness (and hospitals they license and supervise) engaged in conduct that effectively blacklisted the Plaintiff from accessing outpatient psychiatric care from specific not-for-profit outpatient psychiatric care providers, from accessing unbiased judicial services from New York State trial courts, and from obtaining accommodations and assistance from all government defendants.

Defendants Violated Federal Laws With Regard to Blacklisting

*****7)*****Federal courts recognize blacklisting as a cause of action. In the lawsuit Castillo v. Spiliada Maritime Corporation MV, 937 F. 2d 240, the United State Court of Appeals for the Fifth Circuit stated that “. . .Plaintiffs have offered substantial evidence that they were coerced into agreeing to the settlements with threats that charges would be filed against them with the POEA and that they would be blacklisted. As the threats of blacklisting endangered the possibility of future employment in their established trade, Plaintiffs reasonably could have been intimidated into settling.” In the lawsuit Duckworth v. Pratt & Whitney, Inc., 152 F.3d 1 (1st Cir. 1998), the United States Court of Appeals for the First Circuit stated that “As both Duckworth and the Secretary of Labor persuasively argue, the achievement of these objectives would be frustrated by adopting Pratt & Whitney's interpretation. That interpretation would permit an employer to evade the Act by blacklisting employees who have used leave in the past or by refusing to hire prospective employees if the employer suspects they might take advantage of the Act.” The United States Court of Appeal's use of the term “leave” refers to medical leave. The United States Court of Appeals use of the term “Act” refers to the Family and Medical Act of 1993. In the case Davis v. Paul, et al, 505 F.2d 1180 the United States Court of Appeals for the Sixth circuit stated that “Few things are as fundamental to our legal system as the presumption of innocence until overcome by proof of guilt beyond a reasonable doubt at a fair trial. The dissemination of the flyer in the case at bar is in the face of the presumption of innocence, disregards the Due Process Clause and is based on evidence that is not probative of guilt. Condemning a man to a suspect class without a trial and on a wholly impermissible standard, as in the case at bar, offends the very essence of the Due Process Clause, i.e., protection of the individual against arbitrary action. Slochower v. Board of Education, 350 U.S. 551, 559, 76 S.Ct. 637, 100 L.Ed. 692 (1956); Peters v. Hobby, 349 U.S. 331, 351-352, 75 S.Ct. 790 (1955) (Douglas, J., concurring.) As said by Mr. Justice Black in his concurring opinion in Joint Anti-Fascist Refugee Committee v. McGrath, 341 U.S. 123, 144-145, 71 S.Ct. 624, 634 (1951): 'Our basic law, however, wisely withheld authority for resort to executive. . .condemnations and blacklists as a substitute for imposition of legal types of penalties by courts following trial and conviction in accordance with procedural safeguards of the Bill of Rights.'”

*****8)*****The United States Equal Employment Opportunity Commission's, (EEOC) Office of Legal Counsel the Americans with Disabilities Act of 1990 and the Family and Medical Leave Act of 1993 overlap, and that where employees are concerned, “ADA Title II covers all public employers without regard to the number of employees.”

*****9)*****By this action, Plaintiff seeks an end to New York State's practice of blacklisting the Plaintiff by refusing to provide her with outpatient psychiatric care, accommodations required to be provided by the New York State Unified Court System as its courts are covered under Title II of the Americans With Disabilities, and by ending the corporate defendants' use of the media to encourage members of the not-for-profit psychiatric outpatient community to blacklist the Plaintiff by publicly denigrating her because of symptoms of her mental illness that were publicized by government and corporate defendants.

PARTIES

*****10)*****The Plaintiff is a recipient of federally- and state-funded psychiatric services, and is a plaintiff in various legal actions in trial courts over which Defendant the Honorable Ann Pfau has oversight. The Plaintiff also has docket number 2010-07636 with the Appellate Division, 2nd Judicial Department; an appeal to file regarding an unfavorable decision rendered by the New York Court of Claims; Notice of Appeal already filed with the Appellate Division, First Judicial Department file regarding an unfavorable decision rendered with regard to Defendant Federation Employment and Guidance Service, Inc., and an appeal to file in what Plaintiff predicts to be an unfavorable decision with regard to Defendant Daily News, LP. Once Justice Wooten renders his decision in favor of Defendant Daily News, LP, Plaintiff will file her already-prepared Notice of Appeal, Notice of Motion to proceed as a poor person and to prosecute her action on the lower court's original records, nine copies of her Appellate Brief at the same time, if possible.

Role of Defendants Andrew M. Cuomo and the New York State Government

*****11)*****Defendant Andrew M. Cuomo is the Governor of the State of New York, a public entity covered by Title II of the Americans With Disabilities Act. 42. U.S.C. §12131(1). He is ultimately responsible for ensuring that New York State operates its service systems in conformity with the Americans With Disabilities Act and the Rehabilitation Act. He is sued in his official capacity.

Role of Defendants Nirav R. Shah and the NYS Department of Health

*****12)*****Defendant New York State Department of Hea1th ("DOH") is the agency created by the State of New York that licenses, supervises and enforces the laws and regulations applicable to adult homes, and is responsible for protecting Plaintiff's rights. DOH is a public entity covered by Title II of the Americans With Disabilities Act. 42 U.S.C. 12131(1).

*****13)*****Defendant Nirav R. Shah is the Commissioner of DOH. He is responsible for the operation and administration of DOH. He is sued in his official capacity.

Role of Defendants Michael F. Hogan and the NYS Office of Mental Health

*****14)*****Defendant New York State Office of Mental Health (“OMH”) is the agency responsibility for providing outpatient psychiatric services to the Plaintiff, who has a serious and persistent mental illness. OMH is a public entity covered by Title II of the Americans With Disabilities Act. 42 U.S.C. §12131(1).

*****15)*****OMH shares the responsibility for protecting the rights of mentally ill constituents with DOH.

*****16)*****OMH also operates state psychiatric facilities and is responsible for discharge planning, placement and follow-up for individuals residing in such facilities. Additionally OMH funds privately-operated psychiatric hospitals for clients of the public mental health system and is responsible for developing standards for discharges from these hospitals.

*****17)*****OMH is charged by statute with “the responsibility for seeing the mentally ill persons are provided with care and treatment, that such care, treatment and rehabilitation is of high quality and effectiveness, and that the personal and civil rights of persons receiving care, treatment and rehabilitation are adequately protected.” Mental Hyg. Law §7.07(c).

*****18)*****Defendant Michael F. Hogan is the Commissioner of OMH. He is responsible for the operation and administration of OMH, including its activities regarding state psychiatric facilities and the overall planning, programs and services for the mental health system in New York State. He is sued in his official capacity.

*****19)*****DOH and OMH are recipients of federal funds.

*****20)*****DOH and OMH are programs of state government.

Role of Defendants Ann Pfau and the NYS Unified Court System

*****21)*****Defendant New York State Unified Court System (“NYSUCS”), Defendant New York State's judicial branch of government is responsible for hearing cases of its litigants and for rendering unbiased decisions based on New York State State Constitution, and other laws of New York State. NYSUCS's Office of Court Administration (“OCA”) is the administrative arm of the New York State Unified Court System, under the direction of the Chief Administrative Judge. OCA's Division of Administrative Services provides a wide range of support services to OCA units and to the trial courts, including oversight of Title II of the Americans with Disabilities Act. All courts in New York State are covered under Title II of the Americans With Disabilities Act.

*****22)*****OCA's Division of Court Operations is responsible for addressing inquiries regarding concerns under the Americans with Disabilities Act. It assists the courts in assuring access to services and reasonable accommodations for court users and employees who qualify under the ADA. Each courthouse has an ADA liaison responsible for implementing the Americans with Disabilities Act.

*****23)*****Defendant Ann Pfau is the Chief Administrative Judge of the trial courts of New York State. On behalf of the Chief Judge, the Chief Administrative Judge supervises the administration and operation of the State's trial courts. In that capacity, she oversees the administration and operation of the Statewide court system with a $2 billion budget, 3,600 State and locally paid judges and over 15,000 nonjudicial employees in over 300 locations around the State. Defendant Pfau is sued in her official capacity.

Role of Defendant Roy L. Reardon and the NYS Departmental Disciplinary Committee

*****24)*****Defendant New York State Departmental Disciplinary Committee (“the Committee”) for the First Judicial Department is responsible for protecting the public and the legal profession by ensuring that lawyers adhere to the ethical standards set forth in the Rules of Professional Conduct. The Committee protects the public by reviewing and investigating complaints against lawyers and by recommending sanctions against those who are proven to have violated the Rules. It protects the legal profession by enforcing high standards of conduct, while at the same time ensuring that complaints are dealt with fairly.

*****25)*****The Committee has the authority to take the following actions, depending upon the seriousness of the lawyer's conduct and the circumstances surrounding it:

  • Refer the complaint to a special Mediation Program, in which a trained volunteer mediator meets with the lawyer and the client to assist them in resolving the complaint privately;

  • Issue a private sanction to the lawyer (a “Letter or Admonition”);

  • Recommend to the Court that the lawyer receive a public condemnation (“censure”);

  • Recommend to the Court that the lawyer's right to practice law be taken away for a specified period of time (“suspension”); or

  • Recommend to the Court that the lawyer's license to practice law be taken away (“disbarment”).

*****26)*****Defendant Roy L. Reardon is responsible for overseeing the activities of the Commission. Defendant Reardon is sued in his official capacity.

Role of Defendant Daily News, LP

*****27)*****Defendant Daily News is a new-gathering and new-disseminating corporation. It is the fifth most-widely circulated daily newspaper in the United States with a daily circulation of 632,595, as of June 13, 2009. The Plaintiff asserts that, although Defendant Daily News is a private entity, it can be sued in federal court based on the lawsuit Gugliara vs. Daily News, et al, case number 1:2008-CV-00912, filed on February 28, 2008 with the Federal District Court, Eastern District of New York in front of Judge Nicholas G. Garaufis and magistrate Judge Lois Bloom, based on 28 U.S.C. §1331, federal question, jury trial demanded.

*****28)*****Defendant Uzamere and Associates, PLLC is a law firm that provides, among other services, legal representation to individuals seeking uncontested divorces and legal representation to individuals regarding immigration matters.

Role of Defendant Uzamere and Associates, PLLC

*****29)*****Defendant Uzamere and Associate, PLLC is a law firm that, among other services, provide legal advice and representation with regard to matrimonial and immigration issues.

Role of Defendant Allen E. Kaye, PC

*****30)*****Defendant Allen E. Kaye, PC is a law firm that exclusively provides legal advice and representation to individuals regarding immigration issues.

Role of Defendant Law Office of Harvey Shapiro

*****31)*****Defendant The Law Offices of Harvey Shapiro is a law firm that exclusively provides legal advice and representation regarding immigration issues.

Role of Defendant Gladstein and Messinger

*****32)*****Defendant Gladstein and Messinger is a law firm that provides legal representation to individuals seeking divorces and legal advice and representation regarding immigration issues.

Role of Defendant Federation Employment and Guidance Service, Inc.

*****33)*****Defendant Federation Employment and Guidance Service (FEGS) is a not-for-profit human services agency whose mission is to “meet the needs of the Jewish and broader community through a diverse network of high quality, cost-efficient health and human services that help each person achieve greater independence at work, at home, at school and in the community, and meet the ever-changing needs of business and our society.” In its annual filing for charitable organizations to the IRS for 2008 FEGS reported receiving $4,261,036 from the New York City Department of Health and Mental Hygiene; $1,331,099 from the New York State Department of Mental Hygiene; $17,236,242 from the New York State Office of Mental Health; $336,470 from the New York State Department of Health and $9,373,792 from the New York State Industries for the Disabled (See Exhibit 1).

Role of Defendant Interfaith Hospital and Medical Center

*****34)*****Defendant Interfaith Hospital and Medical Center (“Interfaith”) is a multi-site community teaching health care system which provides a wide range of medical, surgical, gynecological, dental, psychiatric, and pediatric and other services throughout Central Brooklyn, New York. The institution operates a newly-modernized hospital with 287 beds and ambulatory care network of 16 clinics stretching across the Central Brooklyn communities of Crown Heights and Bedford-Stuyvesant. Each year Interfaith Medical Center serves over 250,000 patients, representing every racial, ethnic and national origin group in Central Brooklyn with the majority of people being Caribbean-Americans and African-Americans.

*****35)*****Defendant Interfaith provides mental health and substance abuse services that include both inpatient and ambulatory services with varying levels of intensity to meet the needs of the consumers in our community. The treatment programs are designed to meet the needs of dual diagnosis consumers who may have both mental illness and substance abuse issues or who may be both mentally ill and mentally retarded. Interfaith Medical Center provides a comprehensive array of outpatient, inpatient and emergency behavioral health, psychiatric, detoxification and drug rehabilitation programs, including outpatient mental health services to thousands of children, adults, geriatric mentally-ill and mentally-retarded patients. This program has certification from the OMH and the Office of Mental Retardation and Developmental Disability (OMRDD). In its annual filing for charitable organizations to the IRS for 2009, Defendant Interfaith reported receiving $528,175 from the U.S. Department of Health and Human Services and $1,291,652 from the New York State Office of Mental Health (See Exhibit 2).

Role of Defendant New York Psychotherapy and Counseling

*****36)*****Defendant New York Psychotherapy and Counseling Center (“NYPCC”) is responsible for examining, diagnosing and treating individuals with mental and emotional challenges, as well as those suffering behavioral or emotional disorders; for assisting the culturally diverse communities in which Defendant operates by assisting individuals with mental and emotional challenges and their families to meet with their own needs, and thus improve the quality of their life; for providing quality mental health services, and using the most up-to-date evidence-based practices to help our clients become active and productive members of their communities; to establish and maintain appropriate professional levels of conduct among the staff; and to monitor and make use of new developments in the examination, diagnosis and treatment of the mentally ill. In its annual filing for charitable organizations to the IRS for 2006, 2007 and 2008, Defendant NYPCC reported receiving no income from any state or federal agency; however, at its website http://www.nypcc.org/links.php, Defendant NYCPP states that it works with the National Institute of Mental Health and the New York State Office of Mental Health (See Exhibit 3).

Role of Defendant Catholic Diocese/Catholic Charities of Brooklyn and Queens

*****37)*****Defendant Catholic Diocese's Catholic Charities of Brooklyn and Queens (“CCBQ”) provides behavioral health services addresses issues such as depression, substance abuse, marital problems and other stress-related conditions. Among the services provided by Defendant's professional staff are short-term and long-term counseling, stress management, activities therapy, vocational support and MICA services. Defendant's community-based mental health clinics offer those with severe mental illness a broad range of outpatient services, as well as housing facilities for residents with independent living skills, health management, counselor visits and educational and recreational opportunities. Defendant CCBQ has more than 25 behavioral health programs that help individuals strive for rehabilitation and independence. It provides intensive training in daily living skills, behavior intervention, counseling, crisis and case management, socialization, discharge planning, medication management and support. Defendant did not provide financial information with the New York State Attorney General's Office; however, Defendant CCBQ receives revenue for its mental health services from Medicaid. Services financed by Medicaid are covered under the U.S. Health and Portability and Accountability Act of 1996 (“HIPAA”) (see Exhibit 4).

JURISDICTION

*****38)*****This Court has jurisdiction over this action pursuant to 28 U.S.C. §1331, federal question, which states that “The district courts shall have original jurisdiction of all civil actions arising under the Constitution, laws, or treaties of the United States.”

*****39)*****This Court has jurisdiction over this action pursuant to 28 U.S.C. 1343, Civil Rights and elective franchise, which states that “(a) The district courts shall have original jurisdiction of any civil action authorized by law to be commenced by any person: (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 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. . .”

*****40)*****This Court has jurisdiction over this action pursuant to 42 U.S.C. §1983, Civil action for deprivation of rights, which states that “Every person who, under color of any statute, ordinance, regulation, custom, or usage, of any State or Territory or the District of Columbia, subjects, or causes to be subjected, any citizen of the United States or other person within the jurisdiction thereof to the deprivation of any rights, privileges, or immunities secured by the Constitution and laws, shall be liable to the party injured in an action at law, suit in equity, or other proper proceeding for redress, except that in any action brought against a judicial officer for an act or omission taken in such officer’s judicial capacity, injunctive relief shall not be granted unless a declaratory decree was violated or declaratory relief was unavailable. For the purposes of this section, any Act of Congress applicable exclusively to the District of Columbia shall be considered to be a statute of the District of Columbia.”

*****41)*****This Court has jurisdiction over this action pursuant to 42 U.S.C. §1985(2), Obstructing justice; intimidating party, witness, or juror, which states that “If two or more persons in any State or Territory conspire to deter, by force, intimidation, or threat, any party or witness in any court of the United States from attending such court, or from testifying to any matter pending therein, freely, fully, and truthfully, or to injure such party or witness in his person or property on account of his having so attended or testified, or to influence the verdict, presentment, or indictment of any grand or petit juror in any such court, or to injure such juror in his person or property on account of any verdict, presentment, or indictment lawfully assented to by him, or of his being or having been such juror; or if two or more persons conspire for the purpose of impeding, hindering, obstructing, or defeating, in any manner, the due course of justice in any State or Territory, with intent to deny to any citizen the equal protection of the laws, or to injure him or his property for lawfully enforcing, or attempting to enforce, the right of any person, or class of persons, to the equal protection of the laws. . .”

*****42)*****This Court has jurisdiction over this action pursuant to Bivens v. Six Unknown Named Agents, 403 U.S. 388 (1971). “For the reasons set forth below, I am of the opinion that federal courts do have the power to award damages for violation of 'constitutionally protected interests' and I agree with the Court that a traditional judicial remedy such as damages is appropriate to the vindication of the personal interests protected by the Fourth Amendment.” The Court, in an opinion by Justice Brennan, laid down a rule that it will imply a private right of action for monetary damages where no other federal remedy is provided for the vindication of a Constitutional right, based on the principle that for every wrong, there is a remedy.”

*****43)*****This Court has jurisdiction over the action pursuant to Morgan v. National Railroad Passenger Corporation, DBA Amtrak, 232 F.3d 1008 (November 8, 2000) with regard to the continuing violations doctrine, in which the U.S. Supreme Court stated in its decision that “the continuing violations doctrine. . .allows courts to consider conduct that would ordinarily be time barred "as long as the untimely incidents represent an ongoing unlawful. . .practice. . .The district court's reliance on Galloway was mistaken. This court has never adopted a strict notice requirement as the litmus test for application of the continuing violation doctrine; in fact, in Fiedler v. UAL Corp., 218 F.3d 973 (9th Cir. 2000), we explicitly rejected such an approach from the Fifth Circuit. See id. at 987 n.10. Fiedler examined Berry v. Board of Sup'rs of L.S.U., 715 F.2d 971 (5th Cir. 1983), a case which involved equal pay based upon gender discrimination, where the Fifth Circuit created a multi-factor test for determining whether discrete acts of harassment are closely related enough to satisfy the continuing violation theory. The Berry court's final factor, "perhaps of most importance," asked whether the harassing act "should trigger an employee's awareness of and duty to assert his or her rights.” Berry, 715 F.2d at 981. We rejected the Berry analysis, holding that test was not "applicable in determining the continuation of a hostile environment." Fiedler, 218 F.3d at 987 n.10.

*****44)*****In tort law, if a defendant commits a series of illegal acts against another person, or, in criminal law, if someone commits a continuing crime (which can be charged as a single offense), the period of limitation begins to run from the last act in the series. In the case of Treanor v. MCI Telecommunications, Inc., the U.S. Court of Appeals for the Eighth Circuit explained that the continuing violations doctrine "tolls the statute of limitations in situations where a continuing pattern forms due to [illegal] acts occurring over a period of time, as long as at least one incident . . . occurred within the limitations period. In the case Douglas v. California Department of Youth Authority, 271 F.3d 812, Dossey Douglas was denied employment by the California Youth Authority because a vision test indicated that he was color-blind. Douglas brought suit against CYA for its failure to hire him under Title I of the ADA. The district court granted summary judgment to CYA on the ground that Douglas' claims are barred by the applicable statutes of limitations. Douglas argued on appeal that his claims are timely under the continuing violations doctrine because the CYA's discriminatory policy was on-going. The U.S. Court of Appeals stated the following: “Applying the continuing violations doctrine to these facts, we are guided by two earlier Ninth Circuit decisions. In Domingo v. New England Fish Co., 727 F.2d 1429 (9th Cir. 1984), amended 742 F.2d 520 (9th Cir. 1984), we considered a class action suit against a cannery operator involving allegations of discrimination on the basis of race in hiring and promotions. The plaintiffs argued that their claims were saved from the time bar by the fact that the discriminatory hiring and promotion polices continued until the plaintiffs brought suit. Id. at 1443. We required the plaintiffs to demonstrate that because of the discriminatory policy, they were either discriminated against or “exposed to discrimination” during the limitations period. Id. Almost a decade later, we again addressed the issue whether a case was timely under a continuing violations theory based on an alleged systemic discrimination in hiring. EEOC v. Local 350, Plumbers and Pipefitters, 998 F.2d 641, 643 (9th Cir. 1993). The EEOC filed an Age Discrimination in Employment Act suit on behalf of union members who were excluded from hiring lists on the ground that they received pension benefits. Id. at 643. We noted that the union's policy that excluded retirees from the hiring lists applied to the class members as early as 1984, five years earlier. Id. at 644. We found that the action was not barred by the relevant statute of limitations, because the discriminatory policy prohibiting retirees from joining the hiring lists continued. Id. ("Here, Local 350's allegedly discriminatory policy was in effect when [the plaintiff] first encountered[the policy] in 1984 and remains in force today. Thus, under the continuing violations doctrine, relief for [the plaintiff ] is not barred."). Although we did not cite Domingo in our analysis in Local 350, the two decisions are consistent. In Local 350, the plaintiffs, as union members, continued to be "exposed " to the discriminatory hiring policies of the union.” The U.S. Court of Appeals for the Ninth Circuit finally decided that “. . .With respect to the ADA claim. . .We REVERSE the district court's grant of summary judgment on both the Rehabilitation Act and ADA claims because we conclude that the claims were timely filed under the continuing violations doctrine.”

*****45)*****Declaratory and injunctive relief are sought against all defendants under 28 U.S.C. §2201(a), Creation of remedy, it states that “In a case of actual controversy within its jurisdiction. . .any court of the United States, upon the filing of an appropriate pleading, may declare the rights and other legal relations of any interested party seeking such declaration, whether or not further relief is or could be sought. Any such declaration shall have the force and effect of a final judgment or decree and shall be reviewable as such.”

*****46)*****Monetary damages are sought against all except judiciary defendants pursuant to 28 U.S.C. §1983 and Bivens.

*****47)*****Venue in the Eastern District of New York is proper under 28 U.S.C. §1391(b)(2), which states that “A civil action wherein jurisdiction is not founded solely on diversity of citizenship may, except as otherwise provided by law, be brought only 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. . .”

STATUTE OF LIMITATIONS

*****48)*****Plaintiff's Verified Complaint, which speaks to Defendants' violations of Title II, ADA, Section 504 of the Rehabilitation Act, and federal civil rights violations under 42 U.S.C. §1983 and 42 U.S.C. §1985 are timely. According to 42 U.S.C. §1988, Proceedings in vindication of civil rights, (a) Applicability of statutory and common law, the statute holds that “The jurisdiction in civil and criminal matters conferred on the district courts by the provisions of titles 13, 24, and 70 of the Revised Statutes for the protection of all persons in the United States in their civil rights, and for their vindication, shall be exercised and enforced in conformity with the laws of the United States . . . but in all cases where they are not adapted to the object, or are deficient . . .the common law, as modified and changed by the constitution and statutes of the State wherein the court having jurisdiction of such civil or criminal cause is held . . .shall be extended to and govern the said courts in the trial and disposition of the cause . . .” Federal case law that buttresses Plaintiff's assertion regarding the timeliness of her filing is as follows:

Limitations of Time With Regard to 42 U.S.C. §§1983, 1985

**********a)*****In the U.S. Supreme case Board of Regents v. Tomanio, 446 U.S. 478 (1980), the Court held that “Congress did not establish a statute of limitations or a body of tolling rules applicable to actions brought in federal court under 1983 - a void which is commonplace in federal statutory law. When such a void occurs, this Court has repeatedly “borrowed” the state law of limitations governing an analogous [446 U.S. 478, 484] cause of action. Limitation borrowing was adopted for civil rights action filed in federal court as early as 1914, in O'Sullivan v. Felix, 233 U.S. 318 . . . In 42 U.S.C. 1988, Congress 'quite clearly instructs [federal courts] to refer to state statutes' when federal law provides no rule of decision for actions brought under 1983. Robertson v. Wegmann, supra. See [446 U.S. 478, 485] also Carlson v. Green, ante, at 22, n. 10. As we held in Robertson, by its terms, 1988 authorizes federal courts to disregard an otherwise applicable state rule of law only if the state law is "inconsistent with the Constitution and laws of the United States.”

**********b)*****Chief Justice Stevens, in delivering his unanimous decision regarding U.S. Supreme Court case Hardin v. Straub, 490 U.S. 536, stated, inter alia that “In enacting 42 U.S.C. 1988 Congress determined that gaps in federal civil rights acts should be filled by state law, as long as that law is not inconsistent with federal law. See Burnett v. Grattan, 468 U.S. 42, 47 - 48 (1984). Because no federal statute of limitations governs, federal courts routinely measure the timeliness of federal civil rights suits by state law. Id., at 49; Chardon v. Fumero Soto, 462 U.S. 650, 655 - 656 (1983); Johnson v. Railway Express Agency, Inc., 421 U.S. 454, 464 (1975). This tradition of borrowing analogous limitations statutes, cf. O'Sullivan v. Felix, 233 U.S. 318 (1914), is based on a congressional decision to defer to 'the State's judgment on the proper balance between the policies of repose and the substantive policies of enforcement embodied in the state cause of action.' Wilson v. Garcia, [490 U.S. 536, 539] 471 U.S. 261, 271 (1985). 'In virtually all statutes of limitations the chronological length of the limitation period is interrelated with provisions regarding tolling, revival, and questions of application.' Johnson, supra, at 464. Courts thus should not unravel state limitations rules unless their full application would defeat the goals of the federal statute at issue. See, e. g., Wilson, supra, at 269; Chardon, supra, at 657.”

Limitations of Time With Regard to the Federal Rehabilitation Action

**********c)*****In the case J.S., a Minor, by His Mother Sharon Duck, v. Isle of Wight County School Board, et al, 402 F.3d 468, one of the issues acknowledged by Judge Duncan of the United State Court for the Fourth Circuit was issue holding that federal statutes, lacking a statute of limitations, 'borrowed” the statute of limitations of the state in the which the action accrued pursuant to 42 U.S.C. §1988. With reference to the court's decision, Judge Duncan stated, inter alia, that “ . . .the Rehabilitation Act is a federal civil rights statute, and thus the three-step framework provided by §1988 governs the selection of appropriate state law rules to fill deficiencies in the federal statute. See McCullough v. Branch Banking & Trust Co., 35 F.3d 127, 129 (4th Cir.1994); Wolsky v. Medical Coll. of Hampton Rds., 1 F.3d 222, 223 (4th Cir.1993); see also Holmes v. Texas A & M Univ., 145 F.3d 681, 684 (5th Cir.1998) ('The selection of a limitations period applicable to Rehabilitation Act cases is governed by 42 U.S.C. § 1988(a)....')”

Limitations of Time With Regard to the American With Disabilities Action

**********d)*****42 U.S.C. §1988's requirement for a federal court to adopt the statute of limitations in the case where the action accrued also applies to the Americans With Disabilities Act. In the case Soignier v. American Board of Plastic Surgery, 92 F.3d 547, Judge Manion, speaking for the U.S. Court of Appeals for the Seventh Circuit stated, inter alia, that “The ADA, like many federal civil rights statutes, does not contain a specific statute of limitations. Thus, the most appropriate state limitations period applies. 42 U.S.C. §1988(a); Wilson v. Garcia, 471 U.S. 261, 266-67, 105 S.Ct. 1938, 1941-42, 85 L.Ed.2d 254 (1985). Wilson dictates a three-step borrowing analysis . . . Under step 2, courts are to select the statute of limitations of the state cause of action "most appropriate" or "most analogous" to the plaintiff's claim . . .”

New York State Statute of Limitations

**********e) New York State Civil Practice Law and Rules Section 214(5) with regard to actions that must be commenced within 3 years, “an action to recover damages for a personal injury except as provided in sections 214-b, 214-c and 215 . . .”

ISSUES WITH REGARD TO DEFENDANT NEW YORK STATE'S SOVEREIGN IMMUNITY

*****49)*****The Eleventh Amendment of the U.S. Constitution says that “The Judicial power of the United States shall not be construed to extend to any suit in law or equity, commenced or prosecuted against one of the United States by Citizens of another State, or by Citizens or Subjects of any Foreign State.” This means that generally, a sovereign state cannot commit a legal wrong and is immune from civil suit or criminal prosecution. This legal doctrine, however, is refuted when a state engages in conduct that violates Federal law.

*****50)*****In the U.S. Supreme Court case, quoting verbatim:
“Goodman, petitioner in No. 04–1236, is a paraplegic who sued respondent state defendants and others, challenging the conditions of his confinement in a Georgia prison under, inter alia, 42 U. S. C. §1983 and Title II of the Americans with Disability Act of 1990. As relevant here, the Federal District Court dismissed the §1983 claims because Goodman’s allegations were vague, and granted respondents' summary judgment on the Title II money damages claims because they were barred by state sovereign immunity. The United States, petitioner in No. 04–1203, intervened on appeal. The Eleventh Circuit affirmed the District Court’s judgment as to the Title II claims, but reversed the §1983 ruling, finding that Goodman had alleged facts sufficient to support a limited number of Eighth Amendment claims against state agents and should be permitted to amend his complaint. This Court granted certiorari to decide the validity of Title II’s abrogation of state sovereign immunity.”

*****51)*****Justice Scalia, giving the opinion of the Court, stated the following:

“We consider whether a disabled inmate in a state prison may sue the State for money damages under Title II of the Americans with Disabilities Act of 1990 (ADA), 104 Stat. 337, as amended, 42 U.S.C. § 12131 et seq. (2000 ed. and Supp. II).

Title II of the ADA provides that “no qualified individual with a disability shall, by reason of such disability, be excluded from participation in or be denied the benefits of the services, programs, or activities of a public entity, or be subjected to discrimination by any such entity.” §12132 (2000 ed.). A “ ‘qualified individual with a disability’ ” is defined as “an individual with a disability who, with or without reasonable modifications to rules, policies, or practices, the removal of architectural, communication, or transportation barriers, or the provision of auxiliary aids and services, meets the essential eligibility requirements for the receipt of services or the participation in programs or activities provided by a public entity.” §12131(2). The Act defines “ ‘public entity’ ” to include “any State or local government” and “any department, agency, … or other instrumentality of a State,” §12131(1). We have previously held that this term includes state prisons. See Pennsylvania Dept. of Corrections v. Yeskey, 524 U.S. 206, 210 (1998). Title II authorizes suits by private citizens for money damages against public entities that violate §12132. See 42 U.S.C. § 12133 (incorporating by reference 29 U.S.C. § 794a). . .

Once Goodman’s complaint is amended, the lower courts will be best situated to determine in the first instance, on a claim-by-claim basis, (1) which aspects of the State’s alleged conduct violated Title II; (2) to what extent such misconduct also violated the Fourteenth Amendment; and (3) insofar as such misconduct violated Title II but did not violate the Fourteenth Amendment, whether Congress’s purported abrogation of sovereign immunity as to that class of conduct is nevertheless valid. The judgment of the Eleventh Circuit is reversed, and the suit is remanded for further proceedings consistent with this opinion.”

*****52)*****The U.S. Supreme Court held, as did the U.S. Court of Appeals, that a state abrogates sovereign immunity when it violates both Title II, ADA and the Fourteenth Amendment. Plaintiff asserts that her Verified Complaint will show that Defendants OMH, DOS and Defendant government-funded not-for-profit outpatient mental health agencies violated Title II, ADA and the Due Process Clause of the Fourteenth Amendment by conspiring with other Defendants to: 1) illegally publish Plaintiff's nonpublic, confidential psychiatric information to publicly hold Plaintiff out to be psychotic with anti-Semitic tendencies; to prevent Defendant NYSUCS' judiciary employees from seeing and hearing Plaintiff's complaints regarding the commission of perjury and facilitation of identity fraud by employees of Defendant law firms Uzamere and Associate, PLLC, Allen E. Kaye, PC, Law Office of Harvey Shapiro and Gladstein and Messenger so as to employ willful blindness; and to deny Plaintiff access to more socially integrated outpatient psychiatric program so as to forcibly steer Plaintiff into an inpatient setting, intentionally misdiagnosed as psychotic with anti-Semite tendencies so as to discredit Plaintiff's criminal complaint as the rantings of a psychotic patient.

*****53)*****Plaintiff holds that, based on the above, government Defendants' violation of Plaintiff's Title II, ADA and Fourteenth Amendment rights have caused government Defendant to abrogate sovereign immunity, and that Plaintiff's action rises to the level of an action in the manner of Bivens v. Six Unknown Named Agents, 403 U.S. 388 (1971).

BACKGROUND FACTS

ADMINISTRATIVE/JUDICIAL DECISIONS SPECIFIC TO THE PLAINTIFF

*****54)*****The following are issues that have already been adjudicated by an administrative or judiciary agency:

*****Decision of Federal Administrative Agencies

**********U.S. Citizenship and Immigration Service (USCIS)

**********a)*****On August 4, 1980 and August 12, 1980, Plaintiff filed a complaint against her ex-husband Senator Ehigie Edobor Uzamere based on immigration benefit fraud with the U.S. Department of Justice's Immigration and Naturalization Service (“INS”). Shortly after February 10, 1984, Plaintiff received correspondence from INA which stated that “I have considered the reason (child support proceedings) you gave in your request for the address of Mr. Ehigie Edobor Uzamere, and I have determined that the overriding public interest for disclosure outweighs Mr. Uzamere's right to privacy.” In March 2008 Plaintiff filed Freedom of Information request number NRC 200823721 with USCIS for her ex-husband's immigration records that also contained Plaintiff's name. In October 2008, Plaintiff received correspondence from Rachel McCarthy that said that . . . IR2 fraudulently obtained because he was married at the time.” Shortly after January 6, 2009, Plaintiff received more correspondence from Rachel McCarthy that said inter alia, that “The acts that you allege constitute a violation of the Rules of Professional Conduct for Practitioner occurred in the course of representation by an attorney associated with Mr. Kaye in connection with a petition for immediate relative filed by you with the Immigration and Naturalization Service (“INS”) 1979.” Plaintiff subsequently contacted President Obama to expedite the FOIA request she filed with USCIS. Shortly after June 12, 2009, Plaintiff received correspondence and exhibits from T. Diane Cejka, Director of USCIS' Freedom of Information/Privacy Act Office that hold that Ehigie Edobor Uzamere was Plaintiff's husband and is the father of the child of the marriage, Tara A. Uzamere. Correspondence from the White House and USCIS documents concerning Ehigie Edobor Uzamere's identity are attached as Exhibit 5.

**********U.S. Department of Health and Human Services (USHHS)

**********b)*****On or around November 28, 2010, Plaintiff filed a complaint against Defendant FEGS' employees Dr. Howard Forster, Dr. Clifford Nafus and Roberta Siegal based on religiously-oriented retaliation against Plaintiff. Plaintiff's complaint was dismissed without administrative trial or hearing. Plaintiff's complaint is attached as Exhibit 6.

*****Decisions by Federal Courts

**********U.S. Supreme Court

**********c) No. 09-5816, Plaintiff's petition for a writ of certiorari was denied. Information regarding Plaintiff's petition is attached as Exhibit 7.

**********U.S. District Court – Eastern District of New York

**********d)*****Plaintiff filed Docket Nos. 1:2007-CV-2471, 1:2007-CV-1194, 1:2007-CV-891, 1:2007-CV-2703, 1:2007-CV-3709 were filed with the U.S. District Court for the Eastern District of New York. Plaintiff's actions were dismissed without ever having been tried. Information regarding Plaintiff's actions from Justia.com are attached as Exhibit 8.

*****U.S. District Court – Southern District of New York

**********e)*****Plaintiff filed Docket Nos. 1:209-CV-1617, 1:2009-CV-3506 and 1:2010-CV-7668. Plaintiff's actions were dismissed without ever having been tried. Documentation regarding the aforementioned cases is attached as Exhibit 9.

*****U.S. Federal Court of Claims

**********f)*****Plaintiff filed Docket Nos. 1:2010-CV-555, 1:2010-CV-585 and 1:2010-CV-591. Plaintiff's actions were dismissed without ever having been tried. Documentation regarding the aforementioned cases is attached as Exhibit 10.

*****Decision of State Administrative Agency

**********g)*****On November 15, 2010, Plaintiff filed a Verified Complaint with the New York State Division of Human Rights (“Division). The Division dismissed the case finding no probable cause. Division's decision dismissing Plaintiff's complaints is attached as Exhibit 11.

*****New York State Courts

**********New York State Supreme Court, County of Kings

**********h)*****Plaintiff filed Index No. 26332-2007 divorce action on or near July 2007. Intelius.com's skiptrace results that hold that there are no records of “Godwin E. Uzamere” in the United States, Affidavit of Tara A. Uzamere holding Ehigie Edobor Uzamere to be her father, Decision and Order of the Honorable Jeffrey S. Sunshine dated May 12, 2009 and Decision and Order of the Honorable Matthew D'Emic dated March 15, 2010 holding that Senator Ehigie Edobor Uzamere was the Plaintiff's husband and is the father Tara A. Uzamere, the child of the marriage are attached as Exhibit 12.

**********i)*****Plaintiff filed Index 18012-2009 on July 17, 2009, action for fraud. The Honorable Arthur M. Schack ruled in favor of defendants Ehigie Edobor Uzamere, Allen E.Kaye, Harvey Shapiro and Jack Gladstein based on res judicata. Plaintiff appealed Justice Schack's decision and is awaiting a date for oral argument.

*****New York State Supreme Court, County of New York

**********j)*****Plaintiff filed Index No. 009998-2010 in May 2010, action for defamation. Plaintiff's case was transferred to the New York County Supreme Court and assigned Index No. 403205-2010. On May 11, 2011 the Honorable Paul Wooten marked all motions as submitted. Plaintiff is awaiting a decision. Affidavit of service of Plaintiff's Notice to Admit, U.S. Postal Service certified mail and return receipts, Plaintiff's unanswered Notice to Admit and Defendant Daily News' attorneys admission of late filing are attached as Exhibit 13.

**********k)*****Plaintiff filed Index No. 115748 on December 3, 2010. Plaintiff's Affidavit of Service of her Notice to Admit, Plaintiff's unanswered Notice to Admit, Decision and Order of the Honorable Donna M. Mills dismissing Plaintiff lawsuit for “failing to plead the elements necessary for the defamation and intentional infliction of emotional distress” and lack of actionability of Plaintiff's conspiracy claims and Plaintiff's Notice of Appeal are attached as Exhibit 14.

*****New York State Court of Claims

*****l)*****Plaintiff filed Claim No. 119244-A on or around December 6, 2010. Plaintiff filed Claim No.: “None” on an undetermined dated. Decision and Orders of the Honorable Thomas Scuccimarra dismissing Claims Nos. 119244-A and “None” in their entirety are attached as Exhibit 15.

FACTS

*****55)*****Sometime after the Plaintiff filed her divorce action in October 2007, Uzamere and Associates, by its attorney Eugene Osato Uzamere, told Nigerian news-gathering agency Point Blank News that “Most of her commentaries are misguided, and I won't give credence to them. She is basically crazy. I won't give credence to insanity. She is certifiably insane. That is all I have to say. She is crazy”, in defiance of the decision rendered by the the former U.S. Immigration and Naturalization Service (“INS”), that nearly 30 years earlier administratively adjudged that INA's file no. A35 201 224, assigned to Ehigie Edobor Uzamere and file no. A24 027 764 assigned to “Godwin Uzamere” both belong to Ehigie Edobor Uzamere; and that based on Rachel McCarthy, Bar Counsel for the U.S. Citizenship and Immigration Service, Ehigie Uzamere's IR2 benefits as an unmarried immigrant under 21 years of age were revoked because he applied for IR1 benefits as “Godwin Ehigie Uzamere”, married and over 21 years of age. Point Blank News article is attached as Exhibit 16).

*****56)*****During the Plaintiff's litigation of her divorce, Plaintiff's divorce action was adjourned 19 times, although Plaintiff's ex-husband never interposed an answer and never appeared. WebCivil Supreme Appearance list is attached as Exhibit 17.

*****57)*****On or around October 8, 2008, Defendant Uzamere and Associates, by its employee attorney Eugene Uzamere, hand-delivered an affirmation and a fraudulent, unauthenticated, unnotarized counter-affidavit from Nigeria which stated that “The plaintiff who has openly professed her mental illness is also delusional and outlandish in her claims”; and “I have before now, ignored the Plaintiff's outburst but her claim to be married to my cousin who was not in the United States at the time of our marriage is a new twist to this sad tale. . .Her obsession with this destruction has taken her mental ailment to a new level which should not be encouraged” in defiance of the administrative decision rendered by the INS regarding Plaintiff's ex-husband's identity. Fraudulent affirmation and counter-affidavit are attached as Exhibit 18.

*****58)*****By January 13, 2009, the Plaintiff obtained and submitted to Justice Jeffrey S. Sunshine a copy of USCIS attorney Rachel McCarthy's reporting regarding Plaintiff's ex-husband's commission of immigration benefits fraud.

*****59)*****On January 12, 2009 Justice Sunshine rendered a decision in which he stated that “Moreover, the opposition submitted by defendant raises a genuine issue as to whether or not plaintiff and defendant were married in the first instance”, in defiance of INA's administrative decision that recognized the names “Godwin E. Uzamere” and Ehigie Edobor Uzamere as belonging to Ehigie Edobor Uzamere, and that Ehigie Edobor Uzamere was married to the Plaintiff. Page 9 of Justice Sunshine's decision and order dated January 12, 2009 is attached as Exhibit 19.

*****60)*****On January 20, 2009, the Plaintiff forwarded a complaint to former U.S. Ambassador to Nigeria Robin Renee Sanders regarding Justice Sunshine's planned act of identity fraud. The Plaintiff received a response from the U.S. Embassy on January 30, 2009. E-mail to former U.S. Ambassador to Nigeria Robin Renee Sanders and e-mail from the U.S. Embassy in Nigeria are attached as Exhibit 20.

*****61)*****On May 12, 2009, Justice Sunshine rendered his decision and order that states that “Today at 10:35 am. defendant was declared in default for failure to appear at the hearing. Accordingly, defendant's motion to dismiss this action upon the grounds that he is not the husband of the plaintiff is denied in its entirety. The defendant is the husband in conformity with the parties marriage on November 21, 1979. Plaintiff is directed to serve a copy of this decision and order and serve and file a note of issue, forthwith, with proof of mailing by regular international mail and overnight international mail for a trial on all issues within this matrimonial action to be held before this court on July 7, 2009. at 9:30 a.m. This shall constitute the decision and order of the court.”

*****62)*****On July 7, 2009, the Plaintiff filed an action for fraud against her ex-husband and against Defendants Allen E. Kaye, Harvey Shapiro and Jack Gladstein based on aforementioned Defendant's defiance of INA's administrative decision rendered 30 years earlier that recognizes Ehigie Edobor Uzamere as Plaintiff's husband, and based on the aforementioned Defendants' facilitation of Plaintiff's ex-husband commission of immigration fraud and identity fraud.

*****63)*****On or near October 28, 2009, employees for Defendants Allen E. Kaye, PC, the Law Office of Harvey Shapiro and Jack Gladstein submitted affirmations holding “Godwin Uzamere” to the Plaintiff's husband, in defiance of INS' administrative order rendered 30 years earlier that recognizes Ehigie Edobor Uzamere as the Plaintiff's husband and the father of Tara A. Uzamere, the child of the marriage. Defendants' employees' fraudulent affirmations are attached as Exhibit 21.

*****64)*****On November 3, 2009, the Plaintiff was arrested by the New York City Police Department for threatening Justice Sunshine. Plaintiff's letter of incarceration is attached as Exhibit 22.

*****65)*****On November 5, 2009, Defendant Daily News, LP, by its employee Scott Shifrel published a news article which publicly holds the Plaintiff to be psychotic; and that the symptoms that Defendant Daily News associated with Plaintiff's psychosis were: 1) stripping and screaming about her “senator” husband; 2) Plaintiff's “obsession with his (Senator Uzamere's destruction has taken her mental ailment to a new level which should not be encouraged”; 3) that “she comes in her and files all these papers and threatens people”; 4) her “anti-Semitic screeds against judges and others”; and, 5) that Plaintiff “was declared mentally unfit and taken to Bellevue Hospital” that Defendant Daily News, LP published that it obtained its information from “one courthouse source”; and that the Plaintiff believes Defendant Daily News' admission regarding the courthouse source to be true insofar as the aforesaid statement was a declaration made against the Defendant's interest as New York State Civil Rights Law 79-h (Shield Law) does not requires a news-gathering entity to reveal its sources; and insofar as the courthouse source so identified violated 22 NYCRR §100.3(B)(8)(11) which state that “A judge shall not make any public comment about a pending or impending proceeding in any court within the United States or its territories. The judge shall require similar abstention on the part of court personnel subject to the judge's direction and control...” and “A judge shall not disclose or use, for any purpose unrelated to judicial duties, nonpublic information acquired in a judicial capacity.” Defendant Daily News' article is attached as Exhibit 23.

*****66)*****On November 30, 2009, twenty-five (25) days after Defendant Daily News, LP published its article regarding the Plaintiff, Defendant Federation Employment and Guidance Service terminated its mental health services to the Plaintiff. In its discharge summary it stated that “given client's history of anti-Semitic remarks treatment at an FEGS facility is inappropriate for her.” FEGS' discharge summary is attached as Exhibit 24.

*****67)*****On December 7, 2009, the Plaintiff was placed with Defendant New York State Office of Mental Health's Kingsboro Psychiatric Facility.

*****68)*****Between December 7, 2009 and January 15, 2009, Plaintiff was seen by Defendant New York State Justice Anthony Cutrona of Kings County Supreme Court's Mental Hygiene Court.

*****69)*****On January 15, 2009, Defendant New York State Justice Arthur M. Schack contacted psychiatrist Dr. Marie Bauduy of New York State Office of Mental Health's Kingsboro Psychiatric Facility and ordered her not to produce the Plaintiff. In his decision dated January 25, 2010, Justice Justice stated that “The Court is concerned that plaintiff UZAMERE is unfit to proceed. . .Therefore, the instant matter is adjourned to Friday, March 19, 2010. . .” Justice Schack's decision is attached as Exhibit 25.

*****70)*****During the beginning of February, 2010, Plaintiff was discharged by Kingsboro Psychiatric Facility.

*****71)*****On or near February 23, 2010, while the Plaintiff was in her apartment faxing letters of complaint to various governmental agencies, a social worker from Brookdale Hospital contacted the management office of New York City Housing Authority's Louis H. Pink Houses, the New York City Police Department and the New York City Fire Department. An employee of the New York City Housing Authority opened the Plaintiff's apartment door, and Plaintiff was again hospitalized by Defendant New York State Office of Mental Health's Kingsboro Psychiatric Center. During the Plaintiff's last week as an inpatient, Kingsboro social worker Laurie Velcimé informed the Plaintiff that she was engaged in aftercare preparation, including locating an outpatient mental health program. The Plaintiff advised Ms. Velcimé that she was interested in attending New York Psychotherapy and Counseling Center (NYPCC) on Hendrix Street, located close to where the Plaintiff lives. After Ms. Velcimé performed a search of NYPCC and other outpatient mental health care providers, she informed the Plaintiff that not only had NYPCC refused to accept Plaintiff as a client, but that virtually all the not-for-profit outpatient mental health facilities that Ms. Velcimé contacted rejected her request to provide Plaintiff with outpatient psychiatric services. Discharge summary for Plaintiff's second hospitalization is attached as Exhibit 26.

*****72)*****On May 14, 2010, the Plaintiff appeared before Justice Arthur M. Schack. Plaintiff complained throughout the hearing that she was not given a chance to talk. Transcript regarding Plaintiff's appearance is attached as Exhibit 27.

*****73)*****In May, 2010, the Plaintiff filed her lawsuit against Defendant Daily News, LP with the Defendant New York State Court, County of Nassau. In Plaintiff's Verified Complaint, the Plaintiff stated that “given the seriousness of Defendants' statement regarding the “courthouse source” from whom they obtained falsified information, Plaintiff respectfully prays this Court to allow Plaintiff to file her action at this Court.” Plaintiff's statement regarding paragraph 20 from her Verified Complaint is attached as Exhibit 28.

*****74)*****On June 7, 2010, Defendant Daily News' registered agent for process accepted service of Plaintiff's Summons and Verified Complaint for, inter alia, defamation. Defendant's registered agent's Notice of Service of Process is attached at Exhibit 29.

*****75)*****On or around June 21, 2010, Defendant Daily News, LP filed a demand for transfer to the New York County venue with the Defendant New York State's Nassau County Supreme Court. Defendant Daily News' demand for transfer is attached as Exhibit 30.

*****76)*****On or near June 30, 2010, while under the supervision, care and control of Kings County Chief Clerk Nancy Teigtmeier Sunshine, the wife of the Honorable Jeffrey S. Sunshine, an employee with the initials “SP” mail the Plaintiff a fraudulent court document labeled “Kings County Clerk, Equity Department, Window #9, 360 Adams Street, Brooklyn, NY 11201”, requiring the Plaintiff to refile her lawsuit against the Daily News with the Kings County Supreme Court. Fraudulent form from Kings County Clerk's Office is attached as Exhibit 31.

*****77)*****On July 13, 2010, Justice Arthur M. Schack rendered his decision, holding among other things, that “Godwin Uzamere” is Plaintiff's husband, in defiance of both the administrative decision of the U.S. Citizenship and Immigration Service holding Ehigie Edobor Uzamere to be Plaintiff's husband, and the decisions of Justice Jeffrey S. Sunshine and Justice Matthew D'Emic holding that Senator Ehigie Edobor Uzamere was Plaintiff's husband and is the father of the Tara A. Uzamere, the child of the marriage. Page 1, 5 and 6 of Justice Schack's decision are attached as Exhibit 32.

*****78)*****On or near July 19, 2010, the Defendant New York State's court employee “Tara S.” of Nassau County Supreme Court's motion department and the Nassau County Clerk's Office mailed all of Plaintiff's motion papers back to the Plaintiff. Plaintiff was forced to go to Justice Parga's chambers to explain to the part clerk that CPLR §20013 allowed for harmless errors and that CPLR 2102(c)4 requires clerks of court to accept papers. The court subsequently took back all of Plaintiff's motion papers. Nassau County Supreme Court's motion submission instruction form is attached as Exhibit 33.

*****79)*****On or near July 27, 2010, Defendant Daily News' attorney sent correspondence to the Honorable Anthony L. Parga, Justice for the New York State Supreme Court, County of Nassau in which she stated that “I now withdraw both of those motions and am serving today, and will promptly file, two new motions (identical in every material respect to the withdrawn motions), returnable on September 1, 2010. The reason for the withdrawal of the earlier motions is that this past Friday the U.S. Post Office returned to my office the copies of the motion papers that had been served on plaintiff, on the basis that they were undeliverable: we had made a typographical error on the address label, indicating that plaintiffs apartment number is "68," when in fact it is "6B''”; that the aforementioned statement is Defendant Daily News' overt admission that it defaulted insofar as the Respondent did not serve any documents on the Plaintiff until fifty (50) days after the Daily News's registered agent accepted service of Defendant's Summons and Verified Complaint. Correspondence from Defendant Daily News' attorney is attached as Exhibit 34.

*****80)*****On August 5, 2010, in accordance with 22 NYCRR §670.3 Plaintiff filed her notice to appeal Justice Schack's decision. Appellant subsequently filed her brief and three (3) appendices with Defendant New York State's Appellate Division's 2nd judicial department. Cover page for Plaintiff's Notice of Appeal, Appellate Division decision dated April 6, 2011 and Appellate Brief are attached as Exhibit 35.

*****81)*****On October 29, 2010, Justice Anthony L. Parga granted Defendant Daily News' motion to transfer Plaintiff's lawsuit to the New York State Supreme Court, New York County. Justice Parga's short form order is attached as Exhibit 36.

*****82)*****On January 25, 2011, the Plaintiff received a U.S. Postal Service delivery notice/reminder/receipt bearing article number 70091080000137809641 and bearing Newark, New Jersey zip code 07102. Plaintiff alleges that this package was mailed by Defendant Daily News. When Plaintiff checking the article number with the U.S. Postal Service's online Track and Confirm function, she discovered that the article number was untraceable. Two (2) days after the Plaintiff refused to accept service of the process that was mailed from Newark, New Jersey, Plaintiff received another notice/reminder/receipt from the U.S. Postal Service. The second notice/reminder/receipt was dated January 27, 2011. It bore the zip code 10458, but had no article number. When Plaintiff contacted the post office, she was told that the second notice bearing zip code 10458 and no article number referenced the first notice notice bearing article number 70091080000137809641 zip code 10458 dated January 27, 2011 referred to the notice/reminder/receipt dated January 25, 2011 bearing the number 70091080000137809641 and bearing Newark, New Jersey zip code 07102. U.S. Postal Service forms are attached as Exhibit 37.

*****83)*****On March 30, 2011, Defendant Daily News' attorney Anne B. Carroll appeared before Justice Wooten and stated that she had not been served with the Notice of Motion to Renew; that Justice Wooten refused to check or have his staff check the files to see if the files contained affidavits of services for the documents in question; that Justice Wooten ordered an adjournment date for oral arguments for May 11, 2011, and that, as usual, the Plaintiff was not given the opportunity to present her arguments to the Court. Affidavits of service for Plaintiff's Notice of Motion to Renew, Affidavit in Support, return receipts signed by Defendants and Web Civil Supreme Appearance Detail for oral argument schedule for May 11, 2011 scheduled for 2011 are attached as Exhibit 38.

*****84)*****On April 5, 2011, the Plaintiff submitted a complaint against Defendant Daily News' attorney Anne B. Carroll based on violation of disciplinary rules of the New York Lawyer's Code of Professional Responsibilities. Plaintiff's complaint is attached as Exhibit 39.

*****85)*****On or near April 6, 2011, the Plaintiff faxed Defendant Daily News' attorney Anne Carroll the Appellate Brief that she prepared in anticipation of having Justice Wooten render a decision in Defendant Daily News' favor, although Defendant Daily News file its cross motion on July 27, 2010, fifty (50) days after its registered agent acknowledged receipt of service and although it failed to respond to Plaintiff Notice to Admit pursuant to CPLR §§3123, and CVR §79-h(d); although Defendant Daily News' attorney lied about the identity of Plaintiff ex-husband and although Defendant Daily News publicly admitted in its news article that it had obtained confidential information from Defendants' “courthouse sources.” Plaintiff's Appellant Brief to Defendant Daily News, LP is attached as Exhibit 40.

*****86)*****On April 20, while Plaintiff was in therapy with Dr. Elio of Brookdale Hospital, Plaintiff spoke with regard to her legal problems with Defendant Daily News and made comment regarding its owner, Mortimer Zuckerman. Dr. Elio stated that Plaintiff sees Mortimer Zuckerman at the vegetable stand and at every corner, although the Plaintiff never made such statements.

*****87)*****On April 29, 2011, the Plaintiff filed complaints with Defendant NYSDDC against employees of Allen E. Kaye, PC, the Law Office of Harvey Shapiro and Gladstein and Messinger based on their having submitted perjurious affirmations to the court on October 28, 2009 to the New York State Departmental Disciplinary Committee. Complaints are attached as Exhibit 41.

*****88)*****On or after April 29, 2011, the Plaintiff received correspondence from Jorge Dopico, New York State Departmental Disciplinary Committee stating that it had deactivated Plaintiff's complaint against Defendant Daily News' attorney, Anne B. Carroll. Correspondence from the New York State Departmental Disciplinary Committee is attached as Exhibit 42.

*****89)*****On or around May 5, 2011, the Plaintiff received ex-parte correspondence from Defendant Daily News' attorney Anne B. Carroll in which she stated that “It was my understanding that the Court anticipated oral argument of plaintiff's motion – as well as defendants' motion for dismissal of the action – to take place on the same day. However, when our service attempted to file our opposition papers last moth, the clerk's office declined to accept them, directing that they be handed up on May 11.” The correspondence indicated “Enclosures”; however, the envelope in which Defendant Daily News' correspondence was mailed was postmarked “$.0044 and did not contain the enclosures that the correspondence indicated were sent to Justice Wooten. Copy of correspondence and envelope are attached as Exhibit 43.

*****90)*****On May 6, 2011, while the Plaintiff was in session with therapist Emma Smith, the Plaintiff was crying loudly about having been victimized by her ex-husband and his attorneys Allen E. Kaye and Harvey Shapiro, and about her inability to obtain justice in the courts. During the session, several employees of Brookdale Hospital accused the Plaintiff of engaging in threatening behavior and forced Plaintiff to be hospitalized. When Plaintiff saw the possibility that she would again be forced into a long-term hospitalization that would cause her to lose her ability to appear in court, upon arriving in the emergency room, the Plaintiff reminded its staff that mental hygiene law required a 24-hour observation, and that if there was nothing remarkable, the facility would have to release her. Thereafter the Plaintiff remained silent for twenty-four (24) hours. Shortly after the 24th hour, Dr. Shawkat Mustafa attempted to interview the Plaintiff along with a 2nd employee. Plaintiff informed them that she would not allow them to double-team her. Dr. Mustafa interviewed her and thereafter, released the Plaintiff. Brookdale Hospital's discharge papers are attached as Exhibit 44.

*****91)*****On May 11, 2011, the Plaintiff appeared in court for her oral argument at 9:07 am. When she arrived, Justice Wooten's part clerk Mr. Rubio told the Plaintiff that she could not appear in front of Justice Wooten. Furthermore, Mr. Rubio explained that he had contacted the Defendant's attorney to inform her not to appear, and that the motions would be marked as submitted. Plaintiff respectfully asks this Court to note that Justice Wooten's decision not to allow Plaintiff to appear before him were made less than a week after he received Defendant Daily News' ex-parte communication.

*****92)*****On or near May 13, 2011, the Plaintiff visited Brookdale Hospital to speak with its patient's advocate, Ms. Gray. While speaking with Ms. Gray, the Plaintiff showed Ms. Gray legal papers concerning her cases in court. The Plaintiff also produced documentation from the ICSWorld.com website that showed that medical blacklisting, while common, is a form of discrimination. Documentation from ICSWorld.com is attached as Exhibit 45.

*****93)*****On or near May 16, 2011, the Plaintiff received correspondence from Jorge Dopico of Defendant the New York State Departmental Disciplinary Committee stating that Defendant NYSDDC had forwarded Plaintiff concerning Defendant Gladstein and Messinger's employee to the Grievance committee for the 2nd and 11th Judicial Departments. Correspondence from Jorge Dopico is attached as Exhibit 46.

*****94)*****During the morning of May 23, 2011, Plaintiff called several individuals within the Defendant's court system to inquire as to how to obtain records of the mental health evaluations that were adjudicated by Defendant's judiciary employee Justice Cutrona. A courthouse employee whose name Plaintiff does not know directed the Plaintiff to contact Justice D'Emic, the justice who adjudicates cases regarding mentally ill criminal defendants and who adjudicated Plaintiff's divorce. When Plaintiff identified herself, the receptionist stammered out that she was given orders not to speak with Plaintiff and abruptly hung up.

*****95)*****During the afternoon of May 23, 2011, the Plaintiff received copies of the decisions of the mental health in response to Plaintiff's phone request to Taylor Green, the attorney from the New York State Mental Hygiene Legal Service, Second Judicial Department that was assigned to litigate Plaintiff's request for release while the Plaintiff was an inpatient with the Defendant New York State Office of Mental Health's Kingsboro Psychiatric Facility. Decision and Orders of the Honorable Anthony J. Cutrona are attached as Exhibit 47.

*****96)*****On May 24, 2011, the Plaintiff e-mailed correspondence to Defendant Roy L. Reardon, in his official capacity as Chairman of Defendant New York State Departmental Disciplinary Committee. In the e-mailed Plaintiff stated that “Even if I am psychotic”, that I none of your agency's business . . .I am entitled to the protection of the U.S. Constitution and those federal statutes that were promulgated to ensure the enforcement of the Due Process and Equal Protection clauses of the U.S. Constitution.” Plaintiff's e-mail to Defendant Roy L. Reardon is attached as Exhibit 48.

*****97)*****On May 25, 2011, at 10:25 am, the Plaintiff e-mailed Defendant Roy L. Reardon a request to reactive her complaint against Defendant Daily News attorney Anne B. Carroll. Plaintiff's e-mail to Defendant Roy L. Reardon is attached as Exhibit 49.

*****98)*****On May 27, 2011, the Plaintiff received correspondence from Defendant NYSDDC acknowledging Plaintiff's e-mail to Defendant Reardon, and treating Plaintiff's e-mail as a request to reconsider Defendant NYSDDC's deactivation of Plaintiff's complaint against Defendant Daily News' attorney Anne B. Carroll. Correspondence from Defendant NYSDDC dated May 26, 2011 is attached at Exhibit 50.

*****99)*****By reason of the foregoing allegations, Plaintiff asserts that there exists a justiciable controversy with respect to which Plaintiff is entitled to the relief prayed for herein.

FIRST CLAIM FOR RELIEF

DEFENDANTS VIOLATED THE AMERICANS WITH DISABILITIES ACT MANDATE TO ADMINISTER SERVICES AND PROGRAMS IN THE MOST INTEGRATED SETTING

*****100)*****Plaintiff repeats and realleges the above paragraphs.

*****101)*****With regard to the governmental Defendants Andrew M. Cuomo, Nirav R. Shah, Michael F. Hogan, Ann Pfau and Roy L. Reardon, this claim is brought against them in their official capacities.

*****102)*****With regard to Defendants Federation Employment and Guidance Service, Inc. Interfaith Hospital and Medical Center, New York Psychotherapy and Counseling Center and Catholic Diocese of Brooklyn/Catholic Charities of Brooklyn and Queens, this claim is brought against them as instrumentalities of governmental Defendants OMH and DOH.

*****103)*****With regard to Defendants Daily News, LP and the Defendant law firms, this claim is brought against them as corporate citizens having engaged in illegal activity that rises to the level of a federal question (in much the same way as in the case Gordy v. the Daily News, LP, et al, 95 F.3d 829).

*****104)*****Plaintiff is a citizen of the United States with a serious and persistent mental illness. Plaintiff has a mental impairment that substantially limits one or more major life activities.

*****105)*****Plaintiff is a qualified individual with disabilities within the meaning of 42 U.S.C. §12131(2).

*****106)*****Plaintiff is under attack by Defendants, who have created a State-wide hostile environment that encourages Defendants and private citizens alike to attack Plaintiff as a “anti-Semitic wacko.” Proof of Defendants' conspiracy to attack the Plaintiff forever exists at Defendant Daily News' website http://articles.nydailynews.com/2009-11-05/local/17938323_1_supreme-court-judge-criminal-court. Defendant Ann Pfau has a duty as NYSUSC's Chief Administrative Judge, and a disciplinary duty, pursuant to 22 NYCRR §100.3(D)5 to ensure that Justice Arthur M. Schack and Justice Paul Wooten are held criminally liable for their facilitation of the acts of perjury by employees of Defendant law firms Allen E. Kaye, PC, Law Office of Harvey Shapiro and Gladstein and Messenger. Defendant Pfau has, however behaved in manner that shows that she is more influenced with collegial loyalty and Defendant Daily News' owner Mortimer Zuckerman's power and money than with removing proof that the agency she supervises illegally disclosed Plaintiff's federally-protected confidential psychiatric information that was uploaded to billionaire Mortimer Zuckerman's news corporation's website. Governmental Defendants' depraved lack of loyalty to the U.S. Constitution allows them to continue to turn a blind eye while NYSUCS' continues to hold Plaintiff to be psychotic with anti-Semitic features. Defendants watch with sadistic glee while NYSUCS' justice Arthur M. Schack continues to hold that “Godwin E. Uzamere” is the Plaintiff's husband – even while USCIS and NYSUCS' justices Jeffrey S. Sunshine and Mathew D'Emic have already adjudged that Plaintiff's ex-husband and the father of the child of the marriage is Senator Ehigie Edobor Uzamere. Plaintiff continues to be negatively impacted because Defendants OMH and DOH continue to allow their federally- and Defendant-funded not-for-profit mental health providers to withhold their services from the Plaintiff based on Defendant Daily News' public dissemination of Plaintiff's mental health information that was illegally disclosed to Defendant Daily News staff writer Scott Shifrel by Defendant NYSUSC's court personnel – based on Defendant Daily News' own words. Ever since Defendant Daily News publicly portrayed Plaintiff as psychotic with anti-Semitic features, Plaintiff has been unable to access Defendant OMH's not-for-profit psychiatric continuing day treatment programs. No OMH-funded psychosocial clubhouse and virtually no OMH-funded not-for-profit outpatient mental health providers will allow the Plaintiff to become a client. In addition, Defendant NYSUCS's justices have flouted judicial convention with regard to New York State's and U.S. Constitution's Due Process and Equal Protection Clauses by allowing Defendant law firms to submit fraudulent affirmations holding “Godwin Uzamere” to be Plaintiff's husband when both the USCIS, and Defendant NYSUCS's justices Jeffrey S. Sunshine and Matthew D'Emic rendered administrative and judicial decisions holding Senator Ehigie Edobor Uzamere to be Plaintiff's husband and the father of Tara A. Uzamere, the child of the marriage. Plaintiff is in continued danger of having Defendant's NYSUCS's justices Arthur S. Schack, Paul Wooten and NYSUSC's appellate justices continue to render decisions against Plaintiff, not based on the law, but based on Defendants' continued conspiracy to blacklist Plaintiff as psychotic with anti-Semitic features so as to protect Defendant law firms' employees from the legal consequences of their acts of perjury as they pertain to the identity of Plaintiff's ex-husband.

*****107)*****Serving Plaintiff in a setting which rendered justice to Plaintiff in spite of her disability can and must be reasonably accommodated.

*****108)*****Defendants Cuomo, Shah and Hogan are responsible for the operation of public entities covered by Title II of the ADA. 42 U.S.C. §§12131(1)(A) and (B). In addition, it is the responsibility of the government Defendants to ensure that Defendants' private citizens obey Defendant's Constitution and its laws, including those that pertain to treatment of the disabled.

*****109)*****Title II of the ADA prohibits Defendants from discriminating against individuals with disabilities in programs and activities. 42. U.S.C. §§12131, 12132.

*****110)*****Title II also requires that “public entity shall administer services, programs, and activities in the most integrated setting appropriate to the needs of qualified individuals with disabilities.” See 28 C.F.R. §35.130(d).

*****111)*****Governmental Defendants have failed to meet this obligation. Defendants have, like other State employees, bowed and scraped to the whims of the powerful, rich corporate Defendants, to accommodate them in their quest to silence the Plaintiff's cries for justice by using confidential psychiatric information stolen by Defendant Daily News, LP, not only to hold Plaintiff out to be psychotic with anti-Semitic features, but to ensure Plaintiff's silence – even if it means murdering the Plaintiff. Defendant NYSUCS flouted federal judicial and statutory convention by disclosing Plaintiff psychiatric information to Defendant Daily News in violation of Defendant's own rules.6

SECOND CLAIM FOR RELIEF

DEFENDANTS VIOLATED THE AMERICANS WITH DISABILITIES ACT'S PROHIBITION ON USING METHODS OF ADMINISTRATION THAT SUBJECT PLAINTIFF TO DISCRIMINATION

*****112)*****Plaintiff repeats and realleges the above paragraphs.

*****113)*****With regard to the governmental Defendants Andrew M. Cuomo, Nirav R. Shah, Michael F. Hogan, Ann Pfau and Roy L. Reardon, this claim is brought against them in their official capacities.

*****114)*****With regard to Defendants Federation Employment and Guidance Service, Inc. Interfaith Hospital and Medical Center, New York Psychotherapy and Counseling Center and Catholic Diocese of Brooklyn/Catholic Charities of Brooklyn and Queens, this claim is brought against them as instrumentalities of governmental Defendants OMH and DOH.

*****115)*****With regard to Defendants Daily News, LP, and the Defendant law firms, this claim is brought against them as corporate citizens having engaged in illegal activity that rises to the level of a federal question (in much the same way as in the case Gordy v. the Daily News, LP, et al, 95 F.3d 829).

*****116)*****Plaintiff is a citizen of the United States with a serious and persistent mental illness. Plaintiff has a mental impairment that substantially limits one or more major life activities.

*****117)*****Plaintiff is a qualified individual with disabilities within the meaning of 42 U.S.C. §12131(2).

*****118)*****Plaintiff is under attack by Defendants, who have created a State-wide hostile environment that encourages Defendant's governmental, private and corporate citizens to attack Plaintiff as a “anti-Semitic wacko.” Plaintiff is continued risk of not being able to access OMH-funded continuing day treatment programs, psychosocial clubhouse and other not-for-profit outpatient mental health care providers because Defendant NYSUCS illegally disclosed Plaintiff's psychiatric information to Defendant Daily News, who then publicly held and continues to hold Plaintiff out to be psychotic with anti-Semitic features.

*****119)*****Title II of the ADA prohibits defendants from discriminating against individuals with disabilities. 42 U.S.C. §§12131, 12132.

*****120)*****Regulations implementing Title II of the ADA provide that “a public entity may not, directly or through contractual or other arrangements, utilize criteria or methods of administration (i) That have the effect of subjecting qualified individuals with disabilities to discrimination on the basis or disability; [or] (ii) That have the purpose or effect of defeating or substantially impairing accomplishment of the objectives of the public entity'[s] program with respect to individuals with disabilities...”

*****121)*****Defendants utilize methods of administration that have the effect of subjecting the Plaintiff to discrimination based on Defendant NYSUCS having illegally disclosed confidential psychiatric information to Defendant Daily News, who then publicly held Plaintiff out to be psychotic with anti-Semitic features. Defendant NYSDDC, who Plaintiff provided with more than enough proof of Plaintiff's allegations regarding the acts of perjury by the employees of Allen E. Kaye, PC, the Law Offices of Harvey Shapiro and Gladstein, has not yet provided Plaintiff with responses from the aforesaid Defendants. Furthermore, as a result of Defendant NYSUCS' and Daily News illegal disclosure to the public, Defendants Federation Employment Guidance Service, Inc, Interfaith Hospital and Medical Center, New York Psychotherapy and Counseling Center and Catholic Diocese of Brooklyn' Catholic Charities' of Brooklyn and Queens, have refused to provide services to the Plaintiff. Governmental Defendant. Plaintiff has also experience great difficulty in find an OMH-funded continuing day treatment program or an OMH-funded psychosocial clubhouse that is willing to accept the Plaintiff.

THIRD CLAIM FOR RELIEF

DISCRIMINATION ON THE BASIS ON DISABILITY IN VIOLATION OF THE AMERICANS WITH DISABILITIES ACTIVITIES

*****122)*****Plaintiff repeats and realleges the above paragraphs.

*****123)*****With regard to the governmental Defendants Andrew M. Cuomo, Nirav R. Shah, Michael F. Hogan, Ann Pfau and Roy L. Reardon, this claim is brought against them in their official capacities.

*****124)*****With regard to Defendants Federation Employment and Guidance Service, Inc. Interfaith Hospital and Medical Center, New York Psychotherapy and Counseling Center and Catholic Diocese of Brooklyn/Catholic Charities of Brooklyn and Queens, this claim is brought against them as instrumentalities of governmental Defendants OMH and DOH.

*****125)*****With regard to Defendants Daily News, LP, and Defendant law firms, this claim is brought against them as corporate citizens having engaged in illegal activity that rises to the level of a federal question (in much the same way as in the case Gordy v. the Daily News, LP, et al, 95 F.3d 829).

*****126)*****Plaintiff is under attack by Defendants, who have created a State-wide hostile environment that encourages Defendant's governmental, private and corporate citizens to attack Plaintiff as a “anti-Semitic wacko.” Plaintiff is continued risk of not being able to access OMH-funded continuing day treatment programs, psychosocial clubhouse and other not-for-profit outpatient mental health care providers because Defendant NYSUCS illegally disclosed Plaintiff's psychiatric information to Defendant Daily News, who then publicly held and continues to hold Plaintiff out to be psychotic with anti-Semitic features.

*****127)*****Title II of the ADA prohibits defendants from discriminating against individuals with disabilities. 42 U.S.C. §§12131, 12132.

*****128)*****Defendants continue to discriminate against Plaintiff on the basis of her mental illness in violation of the ADA by failing to take adequate measures to ensure that Plaintiff can access those instrumentalities that Defendant OMH and DOH use to provide outpatient mental health services; and that Defendant NYSUCS failed to take adequate measures to ensure that Plaintiff can obtain unbiased judgments, and not judgments to favor corporate Defendants' plan to hold Plaintiff out to be psychotic with anti-Semitic features so as to hide their acts of perjury regarding the identity of Plaintiff's ex-husband.

FOURTH CLAIM FOR RELIEF

DEFENDANTS FAILED TO ADMINISTER SERVICES IN THE MOST INTEGRATED SETTING APPROPRIATE IN VIOLATION OF THE REHABILITATION ACT

*****129)*****Plaintiff repeats and realleges the above paragraphs.

*****130)*****This claim against Defendant NYSUCS is for equitable relief only. Plaintiff understands that judges have immunity for their judicial acts, even those that are malicious. Plaintiff further understands that save for what the Plaintiff alleges to be Defendants' commission of 18 U.S.C. §241, conspiracy against rights; 18 U.S.C. §242, deprivation of rights under color of law; NYS Pen. §105.05, conspiracy, NYS Pen. §115.00, criminal facilitation with regard to Defendant law firms' commission of NYS Pen. §210.15, perjury in the first degree and NYS Pen. §135.65, coercion in the first degree, those issues raised in Plaintiff's lawsuits with Defendant NYSUCS courts are outside the purview of this Court's to adjudicate, pursuant to FRCP Rule 12(h)(3).

*****131)*****This claim for equitable relief and for damages is brought against all other defendants.

*****132)*****Section 504 of the Rehabilitation Act, 29 US.C. §794, provides:

No otherwise qualified individual with a disability in the United States . . . shall, solely by reason of her or his disability, be excluded from participation in, be denied benefits of, or be subjected to discrimination under any program or activity receiving Federal assistance.

*****133)*****Governmental Defendants are recipients of Federal financial assistance.

*****134)*****OMH and DOH are programs receiving Federal financial assistance.

*****135)*****Plaintiff is at continued risk of receiving biased services by judicial and non-judicial employees of Defendant NYSUCS, who, based on the very words of Defendant Daily News' article dated November 5, 2009, discriminated against Plaintiff by illegally disclosing Plaintiff's psychiatric information to Defendant Daily News. Defendant Daily News then publicly held Plaintiff out to be psychotic with anti-Semitic features. Said information, after having been publicly disseminated, was used by Defendants OMH and DOH to blacklist Plaintiff as psychotic with anti-Semitic features. Plaintiff now spend the greater part of her time, alone, lonely and in fear – fear that she will continue her life of loneliness based on Plaintiff's not meeting new people, and fear that Plaintiff will meet new people who will recognize her as psychotic with anti-Semitic features.

*****136)*****Serving Plaintiff in more integrated settings can and must be reasonably accommodated.

*****137)*****Defendants violated Section 504 of the Rehabilitation Act by failing to administer services to Plaintiff in the most integrated setting appropriate for them.

FIFTH CLAIM FOR RELIEF

DEFENDANTS VIOLATED THE REHABILITATION ACT'S PROHIBITION ON USING METHODS OF ADMINISTRATION THAT SUBJECT PLAINTIFF TO DISCRIMINATION

*****138)*****Plaintiff repeats and realleges the above paragraphs.

*****139)*****This claim against Defendant NYSUCS is for equitable relief only. Plaintiff understands that judges have immunity for their judicial acts, even those that are malicious. Plaintiff further understands that save for what the Plaintiff alleges to be Defendants' commission of 18 U.S.C. §241, conspiracy against rights; 18 U.S.C. §242, deprivation of rights under color of law; NYS Pen. §105.05, conspiracy, NYS Pen. §115.00, criminal facilitation with regard to Defendant law firms' commission of NYS Pen. §210.15, perjury in the first degree and NYS Pen. §135.65, coercion in the first degree, those issues raised in Plaintiff's lawsuits with Defendant NYSUCS' courts are outside the purview of this Court's to adjudicate, pursuant to FRCP Rule 12(h)(3).

*****140)*****This claim for equitable relief and for damages is brought against all other defendants.

*****141)*****Regulations implementing Section 504 of the Rehabilitation Act provide that a “recipient may not, directly or through contractual or other arrangements, utilize criteria or methods of administration: (i) That have the effect of subjecting qualified handicapped persons to discrimination on the basis of disability; [or] (ii) That have the purpose or effect of defeating or substantially impairing accomplishment of the objectives of the recipient's program with respect to handicapped persons . . .” 45 C.F.R. §84.4(b)(4).

*****142)*****Governmental Defendants are recipients of Federal financial assistance.

*****143)*****OMH and DOH are programs that receive Federal financial assistance.

*****144)*****Defendants utilize methods of administration that have the effect of subjecting Plaintiff to discrimination. Defendants utilize methods of administration that perpetuate the Defendants' and the public's view that Plaintiff is psychotic with anti-Semitic features; and that as such, Plaintiff is undeserving of justice, mercy and must be isolated at all costs – even if it means hospitalizing, jailing or murdering the Plaintiff.

SIXTH CLAIM FOR RELIEF

DEFENDANTS DISCRIMINATED AGAINST PLAINTIFF ON THE BASIS OF DISABILITY IN VIOLATION OF THE REHABILITATION ACT

*****145)*****Plaintiff repeats and realleges the above paragraphs.

*****146)*****This claim against Defendant NYSUCS is for equitable relief only. Plaintiff understands that judges have immunity for their judicial acts, even those that are malicious. Plaintiff further understands that save for what the Plaintiff alleges to be Defendants' commission of 18 U.S.C. §241, conspiracy against rights; 18 U.S.C. §242, deprivation of rights under color of law; NYS Pen. §105.05, conspiracy, NYS Pen. §115.00, criminal facilitation with regard to Defendant law firms' commission of NYS Pen. §210.15, perjury in the first degree and NYS Pen. §135.65, coercion in the first degree, those issues raised in Plaintiff's lawsuits with Defendant NYSUCS' courts are outside the purview of this Court's to adjudicate, pursuant to FRCP Rule 12(h)(3).

*****147)*****This claim for equitable relief and for damages is brought against all other defendants.

*****148)*****Section 504 of the Rehabilitation Act, 29 U.S.C. §794, provides:

No otherwise qualified individual with a disability in the United States . . . shall, solely by reason of her or his disability, be excluded from participation in, be denied benefits of, or be subjected to discrimination under any program or activity receiving Federal financial assistance.

*****149)*****Governmental Defendants are recipients of Federal financial assistance.

*****150)*****OMH and DOH are programs receiving Federal financial assistance.

*****151)*****With regard to OMH-funded and DOH-funded not-for-profit outpatient continuing day treatment programs and psychosocial clubhouses, Plaintiff is qualified to participate in these settings. Plaintiff types between 75-80 wpm. Plaintiff has a fair working knowledge of Spanish, French and Haitian Creole. The Plaintiff has built websites for herself and others (http://www.uzamerewordprocessing.net; http://www.thecrimesofsenatoruzamere.net; http://www.africandiasporalenterprises.net; http://leglisebaptistedeclarteceleste.tripod.com/; http://victoriouschurchofgod.tripod.com). Before the Plaintiff was arrested and placed in Riker's Island's ward for mentally disabled inmates at Defendants' behest, Plaintiff taught a computer class at Defendant Federation Employment and Guidance Center at 199 Jay Street in Brooklyn, New York. Plaintiff is known in the building where she lives as a person who enjoys helping others. Plaintiff's former best friend, Yitzkhaak (Robert) Benji. When Plaintiff was a client as Defendant Federation Employment and Guidance Service at 3312 Surf Avenue in Brooklyn, New York, the Plaintiff typed program work for Rabbi Yeheskel Lebovic. The Plaintiff continued to type program documents and documents for Rabbi Lebovic's synagogue after Plaintiff left Defendant FEGS' Coney Island location. When Plaintiff was with FEGS, she also had friends of other ethnic groups (see Exhibit 51; DVDs containing phone calls from Yitzhaak's mother and cousin). The Plaintiff has a extensive knowledge with regard to helping citizens obtain government services, and has used her knowledge to help others obtain services. The Plaintiff offers services to help others at her website http://www.uzamerewordprocessing.net/my_brothers_keeper.html. In November, 2010, while Plaintiff was a client with Catholic Charities' Open Door Psychosocial Clubhouse, she started feeling the effects of one of Catholic Charities' employees telling other employees that Plaintiff is an anti-Semite. The Plaintiff subsequently designed the website http://www.uzamerewordprocessing.net/lookingforaclubhousetocallhome to enlist Defendants OMH, DOH and their government-funded instrumentalities to help Plaintiff find another clubhouse. With regard to Defendant NYSUCS, Plaintiff has displayed a growing knowledge of the law and has advocated for herself on several occasions. Plaintiff is well-suited to offer friendship and help to clients and staff alike and to receive in kind if this Court intercedes and ensures governmental Defendants' compliance with the Americans With Disabilities Act and Section 504 of the Rehabilitation Act.

*****152)*****Defendants' practice of knowingly placing and maintaining Plaintiff in socially bankrupt settings, not allowing Plaintiff to use Defendants OMH's and DOH's government-funded not-for-profit outpatient psychiatric continuing day treatment programs and their psychosocial clubhouses isolates the Plaintiff and is the antithesis of the Supreme Court's decision in the case Olmstead v. L.C., 527 U.S. 581 (1999), which states that “[u]njustified isolation . . . is properly regarded as discrimination based on disability,” observing that “institutional placement of persons who can handle and benefit from community settings perpetuates unwarranted assumptions that persons so isolated are incapable of or unworthy of participating in community life.” 527 U.S. at 597, 600.

*****153)*****The Plaintiff respectfully informs this Court that the Plaintiff has greatly borrowed on the lawsuit Disability Advocates, Inc. v. David Paterson, et al. The Plaintiff also respectfully asks this Court to realize that, although the aforementioned lawsuit never used the terms “blacklist” and “continuing violations”, that is exactly what happened to the Plaintiffs in DAI's action. The plaintiffs were effectively “blacklisted” from accessing more integrated forms of housing based on having a mental illness – and according to DAI, it took place over a period of 25 years. Defendants in Plaintiff's action have done exactly the same thing, except that in this case, Defendants were specifically warned by this Court not to do so.

SEVENTH CLAIM FOR RELIEF

DEFENDANTS' BLACKLISTING OF PLAINTIFF VIOLATES 42 U.S.C. §1983

*****154)*****Plaintiff repeats and realleges the above paragraphs.

*****155)*****This claim against Defendant NYSUCS is for equitable relief only. Plaintiff understands that judges have immunity for their judicial acts, even those that are malicious. Plaintiff further understands that save for what the Plaintiff alleges to be Defendants' commission of 18 U.S.C. §241, conspiracy against rights; 18 U.S.C. §242, deprivation of rights under color of law; NYS Pen. §105.05, conspiracy, NYS Pen. §115.00, criminal facilitation with regard to Defendant law firms' commission of NYS Pen. §210.15, perjury in the first degree and NYS Pen. §135.65, coercion in the first degree, those issues raised in Plaintiff's lawsuits with Defendant NYSUCS' courts are outside the purview of this Court's to adjudicate, pursuant to FRCP Rule 12(h)(3).

*****156)*****This claim for equitable relief and for damages is brought against all other defendants.

*****157)*****Federal courts recognize a plaintiff's right to commence a civil action for deprivation of her rights. The statute provides that “Every person who, under color of any statute, ordinance, regulation, custom, or usage, of any State or Territory or the District of Columbia, subjects, or causes to be subjected, any citizen of the United States or other person within the jurisdiction thereof to the deprivation of any rights, privileges, or immunities secured by the Constitution and laws, shall be liable to the party injured in an action at law, suit in equity, or other proper proceeding for redress.” Plaintiff asserts that Defendants actions were calculated. The government Defendants conspired – based on Defendant Daily News' own news article – to illegally disclose Plaintiff's confidential psychiatric information to Defendant Daily News, have Defendant Daily News publicly hold Plaintiff out to be psychotic with anti-Semitic tendencies, and finally, to ensure that only place that Plaintiff would be able to recount the crimes committed against her by the Defendant law firms' employees is in the inside of a mental institution as an inpatient. This level of blacklisting rises to the level of a criminal conspiracy.

*****158)*****It is well-established that judges cannot be sued for damages based on their judicial acts – even if those acts are malicious. However, Defendant NYSUCS' acceptance of Defendant law firms' employees' perjurious affirmations regarding Plaintiff's ex-husband's identity – even in the face of administrative and judicial decisions rendered by USCIS and members of Defendant NYSUCS's own judiciary that Senator Ehigie Edobor Uzamere was Plaintiff's husband and is father of Tara A. Uzamere, the child of the marriage, rises to violations of criminal law – both State and federal. Judges are not immune from their criminal acts – only their judicial acts. Defendant NYSUCS' judiciary acted criminally. Documentation regarding U.S. Government's conviction of former Judge Michael Walker (Operation “Broken Gavel”) and former Judge Michael T. Toole are attached as Exhibit 52.

EIGHTH CLAIM FOR RELIEF

DEFENDANTS' BLACKLISTING OF PLAINTIFF FROM PROCEEDING IN NEW YORK STATE COURTS VIOLATE 42 U.S.C. §1985(2)(3)

*****159)*****Plaintiff repeats and realleges the above paragraphs.

*****160)*****This claim against Defendant NYSUCS is for equitable relief only. Plaintiff understands that judges have immunity for their judicial acts, even those that are malicious. Plaintiff further understands that save for what the Plaintiff alleges to be Defendants' commission of 18 U.S.C. §241, conspiracy against rights; 18 U.S.C. §242, deprivation of rights under color of law; NYS Pen. §105.05, conspiracy, NYS Pen. §115.00, criminal facilitation with regard to Defendant law firms' commission of NYS Pen. §210.15, perjury in the first degree and NYS Pen. §135.65, coercion in the first degree, those issues raised in Plaintiff's lawsuits with Defendant NYSUCS's courts are outside the purview of this Court's to adjudicate, pursuant to FRCP Rule 12(h)(3).

*****161)*****This claim for equitable relief and for damages is brought against all other defendants.

*****162)*****The referenced federal statute regarding obstructing justice, intimidating a party, witness or juror to a legal action says that “If two or more persons in any State or Territory conspire to deter, by force, intimidation, or threat, any party or witness in any court of the United States from attending such court, or from testifying to any matter pending therein, freely, fully, and truthfully, or to injure such party or witness in his person or property on account of his having so attended or testified, or to influence the verdict, presentment, or indictment of any grand or petit juror in any such court, or to injure such juror in his person or property on account of any verdict, presentment, or indictment lawfully assented to by him, or of his being or having been such juror; or if two or more persons conspire for the purpose of impeding, hindering, obstructing, or defeating, in any manner, the due course of justice in any State or Territory, with intent to deny to any citizen the equal protection of the laws, or to injure him or his property for lawfully enforcing, or attempting to enforce, the right of any person, or class of persons, to the equal protection of the laws . . . If two or more persons in any State or Territory conspire or go in disguise on the highway or on the premises of another, for the purpose of depriving, either directly or indirectly, any person or class of persons of the equal protection of the laws, or of equal privileges and immunities under the laws; or for the purpose of preventing or hindering the constituted authorities of any State or Territory from giving or securing to all persons within such State or Territory the equal protection of the laws; or if two or more persons conspire to prevent by force, intimidation, or threat, any citizen who is lawfully entitled to vote, from giving his support or advocacy in a legal manner, toward or in favor of the election of any lawfully qualified person as an elector for President or Vice President, or as a Member of Congress of the United States; or to injure any citizen in person or property on account of such support or advocacy; in any case of conspiracy set forth in this section, if one or more persons engaged therein do, or cause to be done, any act in furtherance of the object of such conspiracy, whereby another is injured in his person or property, or deprived of having and exercising any right or privilege of a citizen of the United States, the party so injured or deprived may have an action for the recovery of damages occasioned by such injury or deprivation, against any one or more of the conspirators.

*****163)*****In the U.S. Supreme Court case Haddle V. Garrison et al, 525 U.S. 121 (1998), the U.S. Supreme Court held that, with reference to 42 U.S.C. §1985, the statute proscribes conspiracies to "deter, by force, intimidation, or threat, any. . .witness in any [federal] court ... from attending such court, or from testifying to any matter pending therein, ... or to injure [him] in his person or property on account of his having so attended or testified," § 1985(2), and provides that if conspirators "do ... any act in furtherance of ... such conspiracy, whereby another is injured in his person or property, ... the party so injured ... may" recover damages, §1985(3) . . . Such harm has long been, and remains, a compensable injury under tort law, and there is no reason to ignore this tradition here. To the extent that the terms "injured in his person or property" refer to such tort principles, there is ample support for the Court's holding. pp. 124-127. 132 F.3d 46, reversed and remanded.”

*****164)*****Plaintiff asserts that Defendants actions were calculated. The government Defendants conspired – based on Defendant Daily News' own news article – to illegally disclose Plaintiff's confidential psychiatric information to Defendant Daily News, have Defendant Daily News publicly hold Plaintiff out to be psychotic with anti-Semitic tendencies, and finally, to ensure that the only place that Plaintiff would be able to recount the immigration fraud and identity fraud that was committed against her by the Defendant law firms' employees is in the inside of a mental institution as an inpatient. This level of blacklisting rises to the level of a criminal conspiracy. Judges cannot not be sued for damages for their judicial acts. Defendant NYSUCS has rules of appellate procedure in 22 NYCRR Part 670 with which the Plaintiff has become familiar and has obeyed. However, Plaintiff obeying all of Defendant's rules with regard to Defendant NYSUCS' trial and appellate procedures are useless. Governmental Defendants have become so enamored with the wealth and power of the corporate Defendants they have flown in the face of New York State law and federal law as they deal with treatment of the disabled. Defendants NYSOMH, NYSDOH and NYSUCS – all of whom are covered by Title II of the ADA, have taken money allotted to make accommodations for the disabled, and have instead created a “diagnosis” causing the public to pay for Seroquel although the Plaintiff was diagnosed – not with schizophrenia – but with bipolar disorder which requires lithium. The first psychiatrist to attempt to prescribe Seroquel to the Plaintiff was Defendant FEGS' employee Dr. Howard Forster – the same psychiatrist who blacklisted the Plaintiff from all of Defendant FEGS' facilities based on being psychotic with anti-Semitic tendencies.

NINTH CLAIM FOR RELIEF

DEFENDANTS' VIOLATIONS ARE VIOLATIONS OF THE FIRST, FIFTH AND FOURTEENTH AMENDMENTS AND GIVE RISE TO A BIVENS CAUSE OF ACTION

*****165)*****Plaintiff repeats and realleges the above paragraphs.

*****166)*****This claim against Defendant NYSUCS is for equitable relief only. Plaintiff understands that judges have immunity for their judicial acts, even those that are malicious. Plaintiff further understands that save for what the Plaintiff alleges to be Defendants' commission of 18 U.S.C. §241, conspiracy against rights; 18 U.S.C. §242, deprivation of rights under color of law; NYS Pen. §105.05, conspiracy, NYS Pen. §115.00, criminal facilitation with regard to Defendant law firms' commission of NYS Pen. §210.15, perjury in the first degree and NYS Pen. §135.65, coercion in the first degree, those issues raised in Plaintiff's lawsuits with Defendant NYSUCS' courts are outside the purview of this Court's to adjudicate, pursuant to FRCP Rule 12(h)(3).

*****167)*****This claim for equitable relief and for damages is brought against all other defendants.

*****168)*****The famous U.S. Supreme Court case Bivens v. Six Unknown Named Agents, 403 U.S. 388 (1971) recognized a private citizen's right to sue for damages for commission of constitutional violation. Justice Brennan, in issuing the the majority decision stated: “For the reasons set forth below, I am of the opinion that federal courts do have the power to award damages for violation of 'constitutionally protected interests' and I agree with the Court that a traditional judicial remedy such as damages is appropriate to the vindication of the personal interests protected by the Fourth Amendment.”

*****169)*****Plaintiff asserts that Defendants actions were calculated. The government Defendants conspired – based on Defendant Daily News' own news article – to illegally disclose Plaintiff's confidential psychiatric information to Defendant Daily News, have Defendant Daily News publicly hold Plaintiff out to be psychotic with anti-Semitic tendencies, and finally, to ensure that only place that Plaintiff will be able to recount the immigration fraud and identity fraud committed against her by the Defendant law firms' employees is in the inside of a mental institution as an inpatient. This level of blacklisting rises to the level of a criminal conspiracy. Judges cannot not be sued for damages for their judicial acts. Defendant NYSUCS has rules of appellate procedure in 22 NYCRR Part 670 with which the Plaintiff has become familiar and has obeyed. However, Plaintiff obeying all of Defendant's rules with regard to judicial procedure are useless. Governmental Defendants have become so enamored with the wealth and power of the corporate Defendants they have have flown in the face of New York State law and federal law as they deal with treatment of the disabled. Defendants NYSOMH, NYSDOH and NYSUCS – all of whom are covered by Title II of the ADA, have taken money allotted to make accommodations for the disabled, and have instead created a “diagnosis” – causing the public to pay for Seroquel although the Plaintiff was diagnosed – not with schizophrenia – but with bipolar disorder which requires lithium. The first psychiatrist to attempt to prescribe Seroquel to the Plaintiff was Defendant FEGS' employee Dr. Howard Forster – the same psychiatrist who blacklisted the Plaintiff from all of Defendant FEGS' facilities based on being psychotic with anti-Semitic tendencies.

REITERATION OF VIOLATIONS COMMITTED BY DEFENDANTS

*****170)*****Wikipedia.org describes the term “due process” as “the legal principle that the government must respect all of the legal rights that are owed to a person according to the law. Due process holds the government subservient to the law of the land protecting individual persons from the state. When a government harms a person without following the exact course of the law it constitutes a due process violation which offends against the rule of law.”

*****171)*****Plaintiff reasserts that the Defendants committed the following violations of due process:

**********a)*****That Defendant NYSUCS's judiciary employees the Honorable Michael Gerstein, the Honorable Jeffrey S. Sunshine and the Honorable Arthur M. Schack, on their own and/or by courthouse employees that are under their care and control, illegally commented on and provided nonpublic information regarding Petitioner's cases Kings County Criminal Court Case Docket No. 2009KN087992, Kings County Supreme Court Index No. 18012-2009 and Kings County Supreme Index No. 26332-2007 to Daily News staff writer Scott Shifrel in violation of 22 NYCRR §100.3(B)(8), (11), that “a judge shall not make any public comment about a pending or impending proceeding in any court within the United States or its territories. The judge shall require similar abstention on the part of court personnel...” and that “a judge shall not disclose or use, for any purpose unrelated to judicial duties, nonpublic information acquired in a judicial capacity.”; that Defendant's commission of said violations is based on Defendant law firms' employees' inability to file a lawsuit against Plaintiff for defamation because Plaintiff's assertions regarding Defendant law firm employees' facilitation of her ex-husband's commission of immigration fraud and identity fraud are true; that Defendant law firm Allen E. Kaye, PC's active conspiracy is based on its employees' original desire to coerce Plaintiff to be silent based on Plaintiff's original fear of being publicly shamed as sexually promiscuous and has having another child without a husband; that Defendants' active conspiracy is based on their desire to prevent Plaintiff from receiving honest judicial services to allow Plaintiff to report Defendant law firms' employees' crimes against her; that Defendants' active conspiracy is based on their desire to prevent Plaintiff from receiving honest outpatient mental health services so as to allow Plaintiff to utilize Defendants' outpatient mental health services as a crime victim; and that Defendants' active conspiracy is based on their desire to forcibly steer Plaintiff to only report Defendant law firms' employees' crimes against her in an inpatient psychiatric setting so as to discredit Plaintiff's irrefutable testimony regarding attorneys Osato Eugene Uzamere's, Allen E. Kaye's, Harvey Shapiro's and Jack Gladstein's facilitation of Plaintiff's ex-husband Senator Ehigie Edobor Uzamere's commission of immigration fraud and identity fraud based on her status of having a mental illness, in violation of Title II, ADA, Section 504 of the Federal Rehabilitation Act, 42 U.S.C. §1983, 42 U.S.C. §1985, 18 U.S.C. §241 and 18 U.S.C. §242.

**********b)*****That Defendant NYSUCS' judiciary employees the Honorable Arthur M. Schack's, the Honorable Jeffrey S. Sunshine's and the Honorable Eric I. Justice Prus' refused to take disciplinary actions against Defendant law firms' employees for their submission of perjurious affirmations, in violation of 22 NYCRR §100.3(D), which states that (2) A judge who receives information indicating a substantial likelihood that a lawyer has committed a substantial violation of the Code of Professional Responsibility shall take appropriate action; and (3) Acts of a judge in the discharge of disciplinary responsibilities are part of a judge's judicial duties; Defendant NYSUCS' judiciary employees the Honorable Justice Arthur M. Schack's, the Honorable Jeffrey S Sunshine's, the Honorable Eric I. Prus and the Honorable Paul Wooten's facilitation of Plaintiff's ex-husband's commission of identity fraud and facilitation of Defendant law firm's attorneys' commission of perjury; that Defendant's commission of said violations is based on Defendant law firms' employees' inability to file a lawsuit against Plaintiff for defamation because Plaintiff's assertions regarding their facilitation of Plaintiff's ex-husband's commission of immigration fraud and identity fraud are true; that Defendant law firm Allen E. Kaye, PC's active conspiracy is based on its employees' original desire to coerce Plaintiff to be silent based on Plaintiff's original fear of being publicly shamed as sexually promiscuous and has having another child without a husband; that Defendants' active conspiracy is based on their desire to prevent Plaintiff from receiving honest judicial services to allow Plaintiff to report Defendant law firms' employees' crimes against her; that Defendants' active conspiracy is based on their desire to prevent Plaintiff from receiving honest outpatient mental health services so as to allow Plaintiff to utilize Defendants' outpatient mental health services as a crime victim; and that Defendants' active conspiracy is based on their desire to forcibly steer Plaintiff to only report Defendant law firms' employees' crimes against her in an inpatient psychiatric setting so as to discredit Plaintiff's irrefutable testimony regarding attorneys Osato Eugene Uzamere's, Allen E. Kaye's, Harvey Shapiro's and Jack Gladstein's facilitation of Plaintiff's ex-husband Senator Ehigie Edobor Uzamere's commission of immigration fraud and identity fraud based on her status of having a mental illness, in violation of Title II, ADA, Section 504 of the Federal Rehabilitation Act, 42 U.S.C. §1983, 42 U.S.C. §1985, 18 U.S.C. §241 and 18 U.S.C. §242.

*****c)*****That Defendant NYSUCS's judiciary employee the Honorable Paul Wooten's refused to take disciplinary action against Defendant Daily News' attorney Anne B. Carroll's commission of perjury in violation of 22 NYCRR §100.3(D) which states that (2) A judge who receives information indicating a substantial likelihood that a lawyer has committed a substantial violation of the Code of Professional Responsibility shall take appropriate action; and (3) Acts of a judge in the discharge of disciplinary responsibilities are part of a judge's judicial duties; that Defendant's commission of said violations is based on Defendant law firms' employees' inability to file a lawsuit against Plaintiff for defamation because Plaintiff's assertions regarding Defendant law firm employee's facilitation of her ex-husband's commission of immigration fraud and identity fraud are true; that Defendant law firm Allen E. Kaye, PC's active conspiracy is based on its employees' original desire to coerce Plaintiff to be silent based on Plaintiff's original fear of being publicly shamed as sexually promiscuous and has having another child without a husband; that Defendants' active conspiracy is based on their desire to prevent Plaintiff from receiving honest judicial services to allow Plaintiff to report Defendant law firms' employees' crimes against her; that Defendants' active conspiracy is based on their desire to prevent Plaintiff from receiving honest outpatient mental health services so as to allow Plaintiff to utilize Defendants' outpatient mental health services as a crime victim; and that Defendants' active conspiracy is based on their desire to forcibly steer Plaintiff to only report Defendant law firms' employees' crimes against her in an inpatient psychiatric setting so as to discredit Plaintiff's irrefutable testimony regarding attorneys Osato Eugene Uzamere's, Allen E. Kaye's, Harvey Shapiro's and Jack Gladstein's facilitation of Plaintiff's ex-husband Senator Ehigie Edobor Uzamere's commission of immigration fraud and identity fraud based on her status of having a mental illness, in violation of Title II, ADA, Section 504 of the Federal Rehabilitation Act, 42 U.S.C. §1983, 42 U.S.C. §1985, 18 U.S.C. §241 and 18 U.S.C. §242.

**********d)*****That Defendant NYSUCS' judiciary employee the Honorable Donna A. Mills' dismissed Plaintiff's lawsuit based on a reason that is not based in law; that Defendant's commission of said violations is based on Defendant law firms' employees' inability to file a lawsuit against Plaintiff for defamation because Plaintiff's assertions regarding Defendant law firm employee's facilitation of her ex-husband's commission of immigration fraud and identity fraud are true; that Defendant law firm Allen E. Kaye, PC's active conspiracy is based on its employees' original desire to coerce Plaintiff to be silent based on Plaintiff's original fear of being publicly shamed as sexually promiscuous and has having another child without a husband; that Defendants' active conspiracy is based on their desire to prevent Plaintiff from receiving honest judicial services to allow Plaintiff to report Defendant law firms' employees' crimes against her; that Defendants' active conspiracy is based on their desire to prevent Plaintiff from receiving honest outpatient mental health services so as to allow Plaintiff to utilize Defendants' outpatient mental health services as a crime victim; and that Defendants' active conspiracy is based on their desire to forcibly steer Plaintiff to only report Defendant law firms' employees' crimes against her in an inpatient psychiatric setting so as to discredit Plaintiff's irrefutable testimony regarding attorneys Osato Eugene Uzamere's, Allen E. Kaye's, Harvey Shapiro's and Jack Gladstein's facilitation of Plaintiff's ex-husband Senator Ehigie Edobor Uzamere's commission of immigration fraud and identity fraud based on her status of having a mental illness, in violation of Title II, ADA, Section 504 of the Federal Rehabilitation Act, 42 U.S.C. §1983, 42 U.S.C. §1985, 18 U.S.C. §241 and 18 U.S.C. §242.

**********e)*****That Defendant NYSUCS' judiciary employee the Honorable Ann Pfau refused to take disciplinary action in violation of which states that (1) “A judge who receives information indicating a substantial likelihood that another judge has committed a substantial violation of this Part shall take appropriate action; that Defendant's commission of said violations is based on Defendant law firms' employees' inability to file a lawsuit against Plaintiff for defamation because Plaintiff's assertions regarding Defendant law firm employee's facilitation of her ex-husband's commission of immigration fraud and identity fraud are true; that Defendant law firm Allen E. Kaye, PC's active conspiracy is based on its employees' original desire to coerce Plaintiff to be silent based on Plaintiff's original fear of being publicly shamed as sexually promiscuous and has having another child without a husband; that Defendants' active conspiracy is based on their desire to prevent Plaintiff from receiving honest judicial services to allow Plaintiff to report Defendant law firms' employees' crimes against her; that Defendants' active conspiracy is based on their desire to prevent Plaintiff from receiving honest outpatient mental health services so as to allow Plaintiff to utilize Defendants' outpatient mental health services as a crime victim; and that Defendants' active conspiracy is based on their desire to forcibly steer Plaintiff to only report Defendant law firms' employees' crimes against her in an inpatient psychiatric setting so as to discredit Plaintiff's irrefutable testimony regarding attorneys Osato Eugene Uzamere's, Allen E. Kaye's, Harvey Shapiro's and Jack Gladstein's facilitation of Plaintiff's ex-husband Senator Ehigie Edobor Uzamere's commission of immigration fraud and identity fraud based on her status of having a mental illness, in violation of Title II, ADA, Section 504 of the Federal Rehabilitation Act, 42 U.S.C. §1983, 42 U.S.C. §1985, 18 U.S.C. §241 and 18 U.S.C. §242.

**********f)*****That Defendants New York State, OMH, DOS and Defendants not-for-profit outpatient mental health agencies refused to take measures to provide Plaintiff with services in the most integrated setting appropriate to Plaintiff's needs, and in a setting that enables the Plaintiff to interact with non-disabled persons to the fullest extent possible; that Defendant's commission of said violations is based on Defendant law firms' employees' inability to file a lawsuit against Plaintiff for defamation because Plaintiff's assertions regarding Defendant law firm employee's facilitation of her ex-husband's commission of immigration fraud and identity fraud are true; that Defendant law firm Allen E. Kaye, PC's active conspiracy is based on its employees' original desire to coerce Plaintiff to be silent based on Plaintiff's original fear of being publicly shamed as sexually promiscuous and has having another child without a husband; that Defendants' active conspiracy is based on their desire to prevent Plaintiff from receiving honest judicial services to allow Plaintiff to report Defendant law firms' employees' crimes against her; that Defendants' active conspiracy is based on their desire to prevent Plaintiff from receiving honest outpatient mental health services so as to allow Plaintiff to utilize Defendants' outpatient mental health services as a crime victim; and that Defendants' active conspiracy is based on their desire to forcibly steer Plaintiff to only report Defendant law firms' employees' crimes against her in an inpatient psychiatric setting so as to discredit Plaintiff's irrefutable testimony regarding attorneys Osato Eugene Uzamere's, Allen E. Kaye's, Harvey Shapiro's and Jack Gladstein's facilitation of Plaintiff's ex-husband Senator Ehigie Edobor Uzamere's commission of immigration fraud and identity fraud based on her status of having a mental illness, in violation of Title II, ADA, Section 504 of the Federal Rehabilitation Act, 42 U.S.C. §1983, 42 U.S.C. §1985, 18 U.S.C. §241 and 18 U.S.C. §242.

*****g)*****That Defendant Daily News, LP theft and disclosure of Defendant NYSUCS's Kings County Criminal Court's nonpublic, confidential psychiatric information concerning Plaintiff's criminal lawsuit Docket No. 2009KN087992; Defendant Daily News' theft and disclosure of Defendant NYSUCS's Kings County Supreme Court's nonpublic, confidential information regarding Plaintiff's divorce Index No. 26332-2007; Defendant Daily News' facilitation of Defendant law firms' employees' commission of perjury; perjurious that Defendant's commission of said violations is based on Defendant law employees' inability to file a lawsuit against Plaintiff for defamation because Plaintiff's assertions regarding Defendant law firm employee's facilitation of her ex-husband's commission of immigration fraud and identity fraud are true; that Defendant law firm Allen E. Kaye, PC's active conspiracy is based on its employees' original desire to coerce Plaintiff to be silent based on Plaintiff's original fear of being publicly shamed as sexually promiscuous and has having another child without a husband; that Defendants' active conspiracy is based on their desire to prevent Plaintiff from receiving honest judicial services to allow Plaintiff to report Defendant law firms' employees' crimes against her; that Defendants' active conspiracy is based on their desire to prevent Plaintiff from receiving honest outpatient mental health services so as to allow Plaintiff to utilize Defendants' outpatient mental health services as a crime victim; and that Defendants' active conspiracy is based on their desire to forcibly steer Plaintiff to only report Defendant law firms' employees' crimes against her in an inpatient psychiatric setting so as to discredit Plaintiff's irrefutable testimony regarding attorneys Osato Eugene Uzamere's, Allen E. Kaye's, Harvey Shapiro's and Jack Gladstein's facilitation of Plaintiff's ex-husband Senator Ehigie Edobor Uzamere's commission of immigration fraud and identity fraud based on her status of having a mental illness, in violation of Title II, ADA, Section 504 of the Federal Rehabilitation Act, 42 U.S.C. §1983, 42 U.S.C. §1985, 18 U.S.C. §241 and 18 U.S.C. §242.

*****h)*****That Defendant law firms' employees' facilitated of Plaintiff's ex-husband Senator Ehigie Edobor Uzamere's commission of immigration fraud and identity fraud; that Defendant law firms' employees' committed perjury with respect to the I-130 immediate sponsorship form that the U.S. Citizenship and Immigration Service held was a falsified document thirty-two years ago; that Defendant law firm Allen E. Kaye, PC's active conspiracy is based on its employees' original desire to coerce Plaintiff to be silent based on Plaintiff's original fear of being publicly perceived as sexually promiscuous and has having another child without a husband; that Defendants' active conspiracy is based on their desire to prevent Plaintiff from receiving honest judicial services to allow Plaintiff to report Defendant law firms' employees' crimes against her; and that Defendants' active conspiracy is based on their desire to prevent Plaintiff from receiving honest outpatient mental health services so as to allow Plaintiff to utilize Defendants' outpatient mental health services as a crime victim; that Defendants' active conspiracy is based on their desire to forcibly steer Plaintiff to only report Defendant law firms' employees' crimes against her in an inpatient psychiatric setting so as to discredit Plaintiff's irrefutable testimony regarding attorneys Osato Eugene Uzamere's, Allen E. Kaye's, Harvey Shapiro's and Jack Gladstein's facilitation of Plaintiff's ex-husband Senator Ehigie Edobor Uzamere's commission of immigration fraud and identity fraud based on her status of having a mental illness, in violation of Title II, ADA, Section 504 of the Federal Rehabilitation Act, 42 U.S.C. §1983, 42 U.S.C. §1985, 18 U.S.C. §241 and 18 U.S.C. §242.

*****i)*****That Defendant NYSDDC deactivated Plaintiff's complaint against billionaire owner Mortimer Zuckerman's company Daily News' employee attorney Anne B. Carroll; that the aforementioned Defendant has made no attempt to contact Plaintiff with regard to Plaintiff's complaint against Defendant law firms' employees and attorney Matthew Kaufman; that Defendant law firm Allen E. Kaye, PC's active conspiracy is based on its employees' original desire to coerce Plaintiff to be silent based on Plaintiff's original fear of being publicly shamed as sexually promiscuous and has having another child without a husband; that Defendants' active conspiracy is based on their desire to prevent Plaintiff from receiving honest judicial services to allow Plaintiff to report Defendant law firms' employees' crimes against her; that Defendants' active conspiracy is based on their desire to prevent Plaintiff from receiving honest outpatient mental health services so as to allow Plaintiff to utilize Defendants' outpatient mental health services as a crime victim; and that Defendants' active conspiracy is based on their desire to forcibly steer Plaintiff to only report Defendant law firms' employees' crimes against her in an inpatient psychiatric setting so as to discredit Plaintiff's irrefutable testimony regarding attorneys Osato Eugene Uzamere's, Allen E. Kaye's, Harvey Shapiro's and Jack Gladstein's facilitation of Plaintiff's ex-husband Senator Ehigie Edobor Uzamere's commission of immigration fraud and identity fraud based on her status of having a mental illness, in violation of Title II, ADA, Section 504 of the Federal Rehabilitation Act, 42 U.S.C. §1983, 42 U.S.C. §1985, 18 U.S.C. §241 and 18 U.S.C. §242.

SUMMARY

*****172)*****Thirty-two years ago, Plaintiff, unbeknownst to her, had an active sexual addiction. Plaintiff met her ex-husband, and within a month of meeting him, Plaintiff was pregnant with his daughter – having already had a nine-month-old son from a previous relationship (see photos of Plaintiff on a foster care visit with her children, David P. Walker and Tara A. Uzamere; after Plaintiff's children were released from foster care and chapter from Plaintiff's website attached as Exhibit 53). While dating her ex-husband, Plaintiff also had other aberrant “personality” characteristics that Plaintiff did not know were symptoms of bipolar disorder. Plaintiff asserts that both her ex-husband and the employees of Defendant law firm Allen E. Kaye, PC knew or strongly suspected Plaintiff's aberrant behavior were symptoms of a mental illness, and that the marriage, subsequent to a two-month courtship between a no-green-card-having immigrant and a unrepresented, mentally unstable citizen was not equitable. However, Plaintiff's ex-husband and the Defendant law firms' employees did not care that Plaintiff was “wacko.” They did not care if Plaintiff had anti-Semitic features. They did not care that Plaintiff was pregnant, legally unprotected, alone, and mentally ill. Plaintiff's ex-husband and Defendant law firms' employees used Plaintiff's mental illness against her as a weapon to obtain her signature for the I-130 immediate relative sponsorship to assist their client in obtaining residence.

*****173)*****Thirty-two years later, Defendant law firms' employees now realize that they made a mistake by equating Plaintiff's mental illness with her intelligence, her ability to learn the law, her persistence – and her rage. Plaintiff expressed this rage by broadcasting Defendant law firms' employees' criminal facilitation of their client's act of immigration fraud and identity fraud on her website, http://www.thecrimesofsenatoruzamere.net. With Defendant law firms' inability to launch a legal defensive by way of an honest action for defamation against her (like Plaintiff filed against Defendant Daily News, LP), the only weapon they have is Plaintiff's mental illness, the shame associated with the publication of Plaintiff's mental illness, originally associated with Plaintiff's sexual promiscuity and her fear of not having a husband – and the participation of corrupt government employees and the corporate Defendants that support their efforts to permanently silence the Plaintiff.

*****174)*****Plaintiff asserts that it is not illegal to have a mental disorder that makes one crave sex. Plaintiff asserts that it is not illegal to engage in behaviors that are socially unpleasing. Plaintiff asserts that is not illegal to have, and to openly express feelings toward specific groups of people that may be considered abhorrent. See See Curley v. NAMBLA, No. Civ.A. 00-10956-GAO, 2003 WL 21696547 (D.Mass. March 31, 2003). However, according to the Honorable Nicholas G. Garaufis, it is both abhorrent and illegal to engage in unjustified isolation of people who have mental illnesses. In Judge Garaufis' Memorandum and Order regarding Disability Advocates, Inc. vs. Paterson, et al, 03-CV-3209 Judge Garaufis quoted from the landmark U.S. Supreme Court case Olmstead v. L.C., 527 U.S. 581 (1999), stating that that “[u]njustified isolation . . . is properly regarded as discrimination based on disability,” observing that “institutional placement of persons who can handle and benefit from community settings perpetuates unwarranted assumptions that persons so isolated are incapable of or unworthy of participating in community life.” Documentation regarding the case Curley v. NAMBLA is attached as Exhibit 54.

*****175)*****Defendants have shown this Court great contempt with regard to this Court order to integrate individuals who have mental illness. It has used media corporations like Defendant Daily News and the New York Post to publicly disagree with this Court order, going so far as to the this Court's trier of fact a “dictator” and “in conflict.” However, Defendants have, brazenly and hypocritically violated Judge Garaufis order, as well as Title II, ADA, Section 504 of the Rehabilitation Act, 42 U.S.C. §1983, 42 U.S.C. §1985, 18 U.S.C. §241 and 18 U.S.C. §242 (see Exhibit 55). David Rosen, former CEO of Brookdale Hospital, a healthcare facility that receives various government grants, is reported to have made $1,764,235 for fiscal year 2009 to provide professional executive services for the government-funded healthcare facility. According to the U.S. Attorney's Office for the Southern District of New York, however, Mr. Rosen engaged in paying out at least $1,000,000 to two (2) of Defendant New York State's politicians for political favors. Like Defendant New York State's politicians, governmental Defendants have made themselves comfortable with billionaire-Mortimer-Zuckerman-owned Defendant Daily News, said comfort exhibiting itself with Defendant NYSUSC's employees' illegal disclosure of Plaintiff's confidential psychiatric information. Defendants have conspired to physically and socially isolate the Plaintiff from as many of Defendants OMH's and DOH's government-funded, not-for-profit, outpatient mental health facilities as possible so as to forcibly steer Plaintiff into a psychiatric inpatient setting to prevent Plaintiff from reporting the crimes of Defendant law firms' employees Osato Eugene Uzamere, Esq., Allen E. Kaye, Esq., Harvey Shapiro, Esq., and Jack Gladstein, Esq. Defendants ignored Plaintiff's cries for justice and instead harkened to the call of billionaire owner Mortimer Zuckerman's media company, Defendant Daily News to publish the lie that Plaintiff is married to “Godwin Uzamere”, and that Plaintiff is psychotic with anti-Semitic – using Defendant Daily News' public portrayal of the Plaintiff as psychotic with anti-Semitic features as a weapon against the Plaintiff in much the same manner that Defendant law firm Allen E. Kaye, PC's employees used Plaintiff's shame of being sexual promiscuous and Plaintiff's fear of not having a husband thirty-two years ago.

*****176)*****Defendants have also placed the Plaintiff in a position of great danger. Psychiatry is a branch of medicine. Therapeutic sessions with psychologists and/or social workers are in tandem with the diagnosis of the treating psychiatrist. If Defendants can arbitrarily turn Plaintiff down for one type of medical service without having to honor Plaintiff's right to an administrative hearing, without this Court's intervention, what prevents the Defendants from withholding other forms of medical assistance from the Plaintiff? In the case of Esmin Green, the mentally ill patient who died of blood clots while waiting for a bed in Kings County's inpatient psychiatric unit, she died as a direct result of its staff's withholding life-saving medical assistance from Ms. Green based on the mistaken belief that Ms. Green was manifesting symptoms of psychosis – the same type of mental illness which Defendants ascribe to the Plaintiff. If Kings County's psychiatric staff acted with such nonchalance toward a woman who was just a private citizen, with no publicly known persona that would cause anyone to hate her, what would government Defendants' do with the Plaintiff, who now has a persona, created by Defendant Daily News, that the public has been taught to hate? Plaintiff believes that Defendants' isolating is not just to stop her from talking. Defendants' desire is to stop her from talking permanently, and Plaintiff is terrified. News article of mentally ill woman Esmin Green is attached as Exhibit 56.

*****177)*****This Court strongly advised Plaintiff not to present it with frivolous issues, including Plaintiff's former unintentional – but wrong habit of using irrelevant causes of action to mask legal issues for which this Court lacks subject matter jurisdiction. Plaintiff has provided this Court with proof – including proof from Defendant NYSUSC's Appellate Division's First and Second Judicial Departments, of her due diligent attempts to obey this Court's order. Plaintiff has gone so far as to read the Complaint of Disability Advocates, Inc., researching its cited statutes and case law to determine relevance, if any, to Plaintiff's situation, and then to copy Disability Advocates, Inc.'s writing style to ensure that Plaintiff's Verified Complaint achieve judicial muster and does not anger this Court and waste its limited resources again. Plaintiff strongly asserts that she has succeeded. Plaintiff prays that this Court's past experiences with the mentally disabled Plaintiff are not misconstrued as disrespect on the part of the Plaintiff, but as Plaintiff's desperation to be treated justly.

*****178)*****Not all victims of civil rights violations are equipped to defend themselves in court. The ultimate victim of civil right violations is a person who has been murdered. She cannot defend herself; however, out of respect and honor of the former life that was lost – and out of respect for the victim's due process rights that were violated, laws are established to publicly proclaim that the dead victim continues to have rights that courts must protect and enforce. If the dead victim was also a party to a divorce, the court that adjudicated her divorce would still have to seal her records from public view to ensure that the dead victim's right to privacy of her records is protected and enforced. Why should this Court not treat as equal the rights of the mentally ill Plaintiff? In the U.S. Supreme Court case Haines V. Kerner, 404 U. S. 519 (1972), Petitioner Menard – a person convicted by the State of Illinois as a felon, commenced this action against the Governor of Illinois and other state officers and prison officials under the Civil Rights Act of 1871, 17 Stat. 13, 42 U.S.C. § 1983, and 28 U.S.C. § 1343(3), seeking to recover damages for claimed injuries and deprivation of rights while incarcerated. The Federal District Court dismissed Mr. Menard's complaint and the U.S. Court of Appeals for the Seventh Circuit affirmed the Seventh Circuit's decision. The U.S. Supreme Court decided against the Federal District's and U.S. Court of Appeals' decisions. The U.S. Supreme Court stated in its decision that “Whatever may be the limits on the scope of inquiry of courts into the internal administration of prisons, allegations such as those asserted by petitioner, however inartfully pleaded, are sufficient to call for the opportunity to offer supporting evidence. . . . Accordingly, although we intimate no view whatever on the merits of petitioner's allegations, we conclude that he is entitled to an opportunity to offer proof.” Plaintiff begs this Court's mercy to allow her to offer proof of her allegations.

*****179)*****The cumulative effect of Defendants' attack on the Plaintiff is that, except when Plaintiff goes to twice monthly therapy sessions, once per month sessions with her psychiatrist and weekly visits with her ICM worker, Plaintiff spends the vast majority of her time alone and afraid that attempts at making friends will expose her to more negative attention as psychotic with anti-Semitic features. The Plaintiff is, for the most part, just as Defendants planned – alone, very lonely with intermittent feelings of rage, worthlessness and hopelessness, an exacerbation of Plaintiff's preexisting mentally illness.

*****180)*****This Court must enforce its own mandate – and the mandate as expressed in Olmstead v. L.C. It must find Defendants guilty of civil and criminal contempt, require the Defendants to obey, and appoint a federal monitor to ensure government Defendants' compliance. This Court must, as a matter of law, require the criminal investigation of the Defendants with regard to Defendants' violation of 18 U.S.C. §241, 18 U.S.C. §242, 18 U.S.C. §1341 and 18 U.S.C. §1346 and facilitate their arrest. Finally, this honorable Court, in its mercy, must expedite Plaintiff's requests so as to bring Plaintiff's Defendant-induced nightmare to an end.

*****WHEREFORE, Plaintiff prays for the following:

*****a)*****Federal monitor to ensure that Defendant NYSUSC's courts treat Plaintiff fairly;

*****b)*****Federal monitor to oversee the federal and New York State criminal investigation of Defendants with regard to Defendants' violation of 18 U.S.C. §241, 18 U.S.C. §242; 18 U.S.C. §1341, 18 U.S.C. §1346; NYS Pen. §105.05, conspiracy, NYS Pen. §115.00, criminal facilitation with regard to Defendant law firms' commission of NYS Pen. §210.15, perjury in the first degree and NYS Pen. §135.65, coercion in the first degree; and with regard to Defendant law firms' employees commission of perjury;

*****c)*****to require Defendant Daily News to remove the news article at its website http://articles.nydailynews.com/2009-11-05/local/17938323_1_supreme-court-judge-criminal-court and similar sites maintained overtly, covertly, directly and indirectly by Defendant Daily News in their entirety, and to refrain from publicly referencing or having others covertly, directly or indirectly refer to any portion of Defendant Daily News' article as Defendant Daily News publicly admitted that courthouse sources of Defendant New York State Unified Court System illegally disclosed nonpublic, confidential information concerning Plaintiff's marriage and Plaintiff's mental illness, in violation of 22 NYCRR §50.1(D), 22 NYCRR §100.3(B)(8) and 22 NYCRR §100.3(B)(11) which prohibits judges and courthouse personnel from disclosing or using, for any purpose unrelated to judicial duties, nonpublic information acquired in a judicial capacity, or from publicly commenting on a pending or impending case, so as to prevent Defendant Daily News from continuing to use its website to criminally victimize the Plaintiff;

*****d)*****an order requiring that Defendants promptly take such steps as are necessary to enable Plaintiff to receive outpatient services (including attendance on continuing day treatment programs and psychiatric clubhouses) in the most integrated setting appropriate to the Plaintiff's needs so that the Plaintiff does not continue to sit at home alone and lonely;

*****e)*****an order to ensure that governmental Defendants OMH, DOH and their not-for-profit instrumentalities that receive governmental funding for the purpose of never against engage in any form of blacklisting the Plaintiff from any federally- or state-funded outpatient mental health treatment facility.

*****f)*****a federal monitor to ensure that Defendants obey the law;

*****g)*****an award of monetary damages in the amount of $100,000,000.00 or an amount that is acceptable to this Court to enable the Plaintiff to relocate.

*****h)*****such other relief as to this honorable Court seems just and proper.

Dated: Brooklyn, New York
          June 6, 2011
* 
CHERYL D. UZAMERE
APPEARING PRO SE

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_______________________

By:   Cheryl D. Uzamere
       1209 Loring Avenue
       Apt. 6B
       Brooklyn, NY 11208
       (347) 985-2495
_______________________
  1. In Re: Aimster Copyright Litigation, 334 F.3d 643: Willful blindness is knowledge . . . One who, knowing or strongly suspecting that he is involved in shady dealings, takes steps to make sure that he does not acquire full or exact knowledge of the nature and extent of those dealings is held to have a criminal intent, United States v. Giovannetti, 919 F.2d 1223, 1228 (7th Cir.1990), because a deliberate effort to avoid guilty knowledge is all that the law requires to establish a guilty state of mind. United States v. Josefik, 753 F.2d 585, 589 (7th Cir.1985); AMPAT/Midwest, Inc. v. Illinois Tool Works Inc., 896 F.2d 1035, 1042 (7th Cir.1990) ("to know, and to want not to know because one suspects, may be, if not the same state of mind, the same degree of fault)
  2. Plaintiff respectfully asks this Court to note that included in the documents that USCIS provided Plaintiff regarding Ehigie Edobor Uzamere's identity is correspondence containing immigration files nos. A35 201 224 (associated with Ehigie Edobor Uzamere, date of birth December 31, 1960 and A24 027 764 (associated with “Godwin Ehigie Uzamere”, date of birth “June 1, 1955”). INA's correspondence containing file no. A24 027 764 was forwarded to Allen E. Kaye, Esq.
  3. CPLR §2001. Mistakes, omissions, defects and irregularities. At any stage of an action, including the filing of a summons with notice, summons and complaint or petition to commence an action, the court may permit a mistake, omission, defect or irregularity, including the failure to purchase or acquire an index number or other mistake in the filing process, to be corrected, upon such terms as may be just, or, if a substantial right of a party is not prejudiced, the mistake, omission, defect or irregularity shall be disregarded, provided that any applicable fees shall be paid.
  4. CPLR §2102. A clerk shall not refuse to accept for filing any paper presented for that purpose except where specifically directed to do so by statute or rules promulgated by the chief administrator of the courts, or order of the court.
  5. (D) Disciplinary Responsibilities.
 1.  A judge who receives information indicating a substantial likelihood that another judge has committed a substantial violation of this Part shall take appropriate action.
 2.  A judge who receives information indicating a substantial likelihood that a lawyer has committed a substantial violation of the Code of Professional Responsibility shall take appropriate action.
 3.  Acts of a judge in the discharge of disciplinary responsibilities are part of a judge's judicial duties.
     6.  22 NYCRR §50.1(D.) Court employees shall not disclose any confidential information received in the course of their official duties, except as required in the performance of such duties, nor use such information
          for personal gain or advantage.
     7.  22 NYCRR §100.3(B)(8) – A judge shall not make any public comment about a pending or impending proceeding in any court within the United States or its territories. The judge shall require similar
          abstention on the part of court personnel subject to the judge's direction and control. This paragraph does not prohibit judges from making public statements in the course of their official duties or
          from explaining for public information the procedures of the court. This paragraph does not apply to proceedings in which the judge is a litigant in a personal capacity.
     8.  22 NYCRR §100.3(B)(11) A judge shall not disclose or use, for any purpose unrelated to judicial duties, nonpublic information acquired in a judicial capacity.