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

cherylphoto.jpgCheryl D. Uzamere -- Sister of victim of grand larceny and Law of the Moser by attorney/porn actor Scott Michael Mishkin

 

 

 

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Attorney Scott
Michael Mishkin

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Alan Kadish

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Patricia Salkin

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Peter H. Mayer
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Denise F. Molia

 

Dear Scott Michael Mishkin: I seriously believe that your involvement in the pornographic film industry as an actor (Doug Jeffries) caused you to jump into bed with JP Morgan Chase and then sabotage my case against them. After all, the sexual harasser at Chase was also a porn star working in the same industry as you. Additionally, the secretiveness surrounding your career as a porn star makes you a threat to the public interest. What happens if someone threatens to expose you as a porn star if you do not throw a case? Is that what Chase did? Did they hire a P.I. and discover your secret? Also, remember, someone sent me (anonymously) a copy of your "Crossing The Line Video" a month into working with you. Whatever, the bottom line is this, I will be reporting you to the Disciplinary Committee and I will be exposing you to the public because your areas of practice require that your clients know that you are vulnerable to blackmail.

http://www.merchantcircle.com/business/Mishkin.Scott.Michael.PC.631-234-1154/review/read?cid=414199#review-414199

Porn Makes Him Dishonest

Mr. Mishkin's involvement in the pornographic film industry as an actor and a director hinders his ability to be objective when representing a victim of sexual harassment on the job. His lack of success when it comes to representing victims of sexual harassment on the job speaks for itself. Moreover, there is a preponderance of evidence to support the allegation that he takes payments from the defendants to throw his clients' cases.

http://www.merchantcircle.com/business/Mishkin.Scott.Michael.PC.631-234-1154/review/read?cid=307636#review_detail

 I would not recommend him to anyone, when I hired him to represent me in a lawsuit against a major financial institution I used to work for he refused to listen to any of my concerns and he was more concerned with pleasing the financial institution that he was supposed to be suing on my behalf. You can read about my experience with him at: http://joel031.vox.com/ And I rate his services with a ZERO!

Black-skin hater, Jewish Attorney, porn actor and Touro Alumnus Scott Michael Mishkin defrauds naïve African American schoolteacher to enter into a retainer agreement to "work on" a case that was time-barred before they even met -- then steals $15,000 from her without doing any legal work to determine how much time he had "left" on her time-barred case.

Now Jewish idiot, cum guzzler and "attorney" Scott Michael Mishkin has given the court a notice telling racist white trash judge Denise F. Molio not to consider her testimony and to  declare that he has standing to require the Defendant to pay him $76,000 for "litigating" a case he ignore to determine was time-barred.

Respectable Jewish Attorney Scott Mishkin Wins Award As Best Attorney -- but has no pictures identifying himself. What is the name of the organization that gave Scott the "award?" And how many of the cases for which Scott won this reward were already time-barred when he got them?

Corrupt Justice Denise F. Molio Joins Law of the Moser RICO Whose Members include but are not limited to: Justice Molio, Justice Mayer and Cum-Guzzlin Porn actor Jewish Attorney Scott M. Mishkin.

The judicial idiots now hide the fact that nutsack-yankin'-cum-guzzlin' Jew attorney Scott has no standing to ask the court to require that "P.G." pay his greed ass $76,000 for a job Scott refused to do. The Semitic idiot even went so far as to send the judge a notice that was an illegal ex-parte notice with an illegal request: when you receive my adversary's letter, do not consider it. Play willfully blinds and ignore it.

Purposely choosing not to do his job to determine the action's statute of limitations, and how much time Scott Had to file his client's action is essentially saying to his client:"P.G." I yanked on my own nutsack, you have to pay me for doing it."

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How can any judge be so goddam stupid that the judge would allow the attorney-litigant to collect a "fee" for a case that was time-barred before the attorney and the client ever met. Stupid bitch Denise F. Molio knows that Jewish cum-guzzlin'-porn-obsessed attorney has no standing to ask that the court require the Defendant pay him for a time-barred case that he was too incompetent or to willfully blind to use his legal skills to recognize as time-barred. Now the stupid, racist, white-trash bitch wants to fake a summary judgment on P. Guity's case to make her pay thousands of dollars for a case that the incompetent-Jewish-attorney-turned-asshole-licker should have known had no case value because the statute of limitation had already run out.Now, in order to illegally have his way, the asshole-lickin' Jew-attorney sent a letter to the stupid bitch Denise F. Molina not to read the truthful testimony that P. Guity submitted as truth testimony.

 

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Now Stupid-Ass Bitches Justices Peter H. Mayer and Justice Denise F. Molio are Members in a lawbreaking, Jew-oriented RICO to help the cum-guzzlin', asshole-lickin' Jew-lawyer steal money from my sister under the guise that my sister owes him money for working on a case that no judge adjudicate because the case was already seen to be time-barred and too late to adjudicate in any courtroom.

 

Can't the stupid bitch see on page 8, first paragraph? It clearly referred to the case as "time-barred."

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NEW YORK STATE SUPREME COURT
COUNTY OF SUFFOLK

-----------------------------------------------------X

Scott Michael Mishkin, P.C.
 

                                            Plaintiff,


 

- against -

"P.G."

                                            Defendants.

 

------------------------------------------------------X

 

2nd AMENDED VERIFIED ANSWER OF DEFENDANT "P.G." 

Defendant, "P.G.", appearing pro se, complaining of the Defendant, alleges as follows:

PRELIMINARY STATEMENT

..........1).....This Answer is also a criminal complaint against the RICO formed by the enterprise corruption of Hon. Peter H. Mayer, Hon. Denise F. Molio and Plaintiff Scott Michael Mishkin to recover damages based on the aforesaid RICO continued attempts to employ the Judaic doctrines Law of the Moser, Use of Subterfuge to Trick Gentiles and Curse of Dark Skin. Law of the Moser prohibits Jews from reporting the crimes of fellow Jews to the Gentile/secular law enforcement authorities; and which requires Jews' active participation to ensure that Gentiles are prevented from filing criminal complaints against Jewish attorney Scott Michael Mishkin or any other Jew. See Babylonian Talmud, Tractate Abodah Zarah, 26b); Informing on Fellow Jews Who Commit Crimes; Babylonian Talmud, Tractate Baba Kamma, Folio 113a; Babylonian Talmud, Tractate Sanhedrin, Folio 108b, footnote 34; Midrash Rabbah, page 293 attached as Exhibit A.

Crimes With Which Defendant Charges RICO Members:

  ........2).....RICO/enterprise corruption, 18 USC §1962-1968, NYS Penal Law §460; official misconduct, §195.00; New York State Judiciary Law, Misconduct by attorney; §487, collusion; New York State Hate Crimes, §485; New York State larceny, §155.35 Grand larceny in the third degree; New York State offenses involving false written statement, §175.35, offering a false instrument for filing in the first degree; New York State perjury and related offenses, §210.15, perjury in the first degree; New York State kidnapping, coercion and related offenses §135.65 coercion in the first degree. Illegal Acts For Which Defendant Charge the Plaintiff and Other Members of RICO.

  .........3).....On March 13, 2012, while employing willful blindness so as not to be aware that the statute of limitation on the action on which he pretended to work had already expired, Plaintiff engaged in racism, fraud and grand larceny by stealing $12,000, $3,000 to be deposed from the Defendant for which to do work on her time-barred. On the following day, Defendant faxed the complaint for the time-barred case.

  .........4).....On March 23, 2012, Plaintiff sent Defendant an e-mail that stated that he received the entire EEOC file of Defendant's time-barred action. Plaintiff sent an e-mail to start performing work on the time-barred demanding $12,000 for the retainer fee and $350 for the filing fee. Defendant also procured the following information of her time-barred case: a) Defendant's 50H transcript; b) Plaintiff's complaint; c) chronology; d) the notice of claim; e) a “right to sue” letter. At the time that Defendant submitted her documents, Defendant, who lacks legal experience, was unaware that her legal action was time-barred because the statute of limitation on her action had expired.

  .........5).....Defendant alleges that, from ____________ 201__ to ___________201__, that while unknown to the Defendant, and in an attempt to create a legal technicality on which to base dismissal of Defendant's case, Hon. Denise F. Molia employed willful blindness regarding knowledge of the Defendant's address, so as to later charge the Defendant with some fictitious form of “contempt” for not responding to the court appearance documents expeditiously that Defendant never knew she had; and that Plaintiff and Hon. Denise F. Molio colluded and conspired to use one of the court's clerk to illegally mail court appearance documents to than Defendant's post office box, even though court personnel had immediate access to Defendant's post office box, her telephone number, her telephone, her job and her home address.

  .........6).....That prior to June 17, 2014, Justice Denise F. Molio and Plaintiff Scott Michael Mishkin colluded and conspired to deprive Defendant of her right to due process by cancelling the appointment for Defendants to attend the certification conference.

QUESTIONS AND ANSWERS

  .........7).....Defendant denies Plaintiff's statement as provably perjurious and irrelevant because, inter alia, at the risk of filing a criminal complaint against this Court, the Plaintiff does not have standing to tell this Court that the Defendant should be made to pay money to the Plaintiff because he was so incompetent that he performed work on a case that was time-barred when he met it and adjudged to be time-barred a few months later.1 The statute of limitation to the case to which the Plaintiff refers expired months before the Defendant met the Plaintiff. The Plaintiff has no legal standing to ask this Court to force the Defendant to pay for an contract that would have been too unconscionable to honor because the case was found to be time-barred (there was never any viable cause of action for which the Plaintiff could present a viable case, a fact that is verified by federal district judge Sandra Feuerstein and federal magistrate Tomlinson and Counsel for the Defendant (http://docs.justia.com/cases/federal/district-courts/new-york/nyedce/2:2012cv01482/328688/75/0.pdf; also see Frost Line Refrigeration, Inc. v. Gastwirth, Mirsky & Stein LLP, 806 NYS2d 436 (2006), the court held that the three-year statute of limitations period for the legal malpractice case started running from the date that the plaintiff-client signed a Consent to Change Attorney form with the defendant-client. By signing that form (which indicates that a client no longer wants the attorney to act as its counsel), the attorney-client relationship terminated and the clock began ticking on the potential legal malpractice claim. As the lawsuit was filed after the three-year period, the plaintiff-client was time-barred from commencing the legal malpractice case and it was dismissed. Defendant reiterates under penalties of perjury that the Plaintiff committed perjury. Defendant will contact Allstate Insurance Company to ensure that the Plaintiff does not use his false testimony to illegally collect money from Defendant's insurance to receive payment for a case that was already adjudicated as time-barred.

JURISDICTION

  .....FIRST-Q: The jurisdiction of the Court over this controversy is based upon breach of contract as well as for quantum meruit that form part of this case and controversy.

  .....FIRST-A: Defendant denies Plaintiff's statement as provably perjurious. This Court has no jurisdiction over this case for the following reasons: 1) Plaintiff has no standing to ask this Court to help him trick the Defendant into helping him submit a fraudulent insurance claim to pay his “fee” for doing work on a case that was time-barred when he met it, and adjudged to time-barred a few months later. The Plaintiff does not have standing to commit perjury for the sole purpose of steal money from the Defendant for a time-barred case. The Plaintiff had no right to defraud the Defendant into paying money into a case that was adjudicated as time-barred based on the expiration of the statute of limitation. The statute of limitations for Defendant's case expired even before Defendant met with the Plaintiff. The Plaintiff's acceptance of Defendant's $12,000 for a res judicata case are fraud and grand larceny, both of which are crimes, that amazingly, the Plaintiff admits to in his Verified Complaint.

  .....SECOND-Q: Therefore, this Court has jurisdiction over the defendants in this action.

  .....SECOND-A: Defendant denies Plaintiff's statement as provably perjurious and irrelevant because the Plaintiff has no standing. This Court has no legal jurisdiction over the Defendant because the case cannot be tried in any court. It is time-barred. In addition, the Plaintiff's contractual condition are greedy, racially motivated and unconscionable. The Plaintiff's conditions allows the Plaintiff, who is a Jew, to charge the Defendant thousands of dollars to honor an unconscionable contract to “litigate” a case that has no chance of being accepted by any court because it is time-barred and too late to file anywhere.

VENUE

  .....THIRD-Q: The unlawful conduct alleged below was committed within Suffolk County in the State of New York.

  .....THIRD-A: Defendant denies Plaintiff's statement as provably perjurious and irrelevant because the Plaintiff has no standing to demand that the Court force the Defendant to pay for legal services on a case that was already adjudicated as time-barred. The illegal conduct alleged by the Plaintiff did not start with the Defendant – it started with the Plaintiff and soon branched out to become a RICO that now includes court personnel. Cheryl D. Uzamere reported said crimes to the following law enforcement agencies: 1) the New York State Supreme Court, Appellate Division, 2nd Jurisdictional Department; 2) the Suffolk County District Attorney; 3) Loretta Lynch, U.S. Attorney for the Eastern District of New York; 4) the Supreme Court of the United States (Defendant's sister Cheryl included Plaintiff's adherence to the Judaic doctrine Law of the Moser in her petition for a writ of certiorari); and, 5) the United Nations Office of the High Commission for Human Rights. Said crimes were also mentioned at Defendant's sister's website (http://thecrimesofsenatoruzamere.net/will_black_victim_get_justice.html) which shows the pictures of those court employees who are involved in helping the Plaintiff force his unconscionable contract on the Defendant that requires her to pay the Plaintiff for legal services for a case that can never be used in any courtroom because the case is time-barred; this is also based on case law (Frost Line Refrigeration, Inc. v. Gastwirth, Mirsky & Stein LLP, 806 NYS2d 436 (2006).

  .....FOURTH-Q: At the time of the unlawful practices, plaintiff's principle place of business was in Suffolk County in the State of New York.

  .....FOURTH-A: Defendant denies Plaintiff's statement as provably perjurious and irrelevant because the Plaintiff lack the standing to tell this or any court that he suffered injury because the Defendant figured out that the Plaintiff had defrauded her to give him $12,000 for a time-barred case. There are not, nor have there ever been any unlawful practices on the part of the Defendant who is a practicing and obedient Jehovah's Witness. Defendant's case was time-barred even before she met and discussed the case with the Plaintiff. Defendant intends to produce her Verified Answer to the Allstate Insurance Company's general counsel to give the Plaintiff the opportunity to tell Allstate's attorney that the Defendant's insurance should be used to pay for litigating a case that was time-barred even before he met the Defendant.

  .....FIFTH-Q: At all times relevant to this action, plaintiffs residence was in Suffolk County in the State of New York.

  .....FIFTH-A: Defendants denies Plaintiff's statement as irrelevant because the case was adjudicated as time-barred.

  .....SIXTH-Q: Therefore, this Court is the proper venue.

  .....SIXTH-A: Defendant denies Plaintiff's statement as provably perjurious and ridiculous because it was time-barred by the statute of limitations when he met it, and adjudged to be time-barred a few months later. The only way that this Court can exercise jurisdiction over the Dependant is illegally. If this Court exercises jurisdiction over the Defendant, this Court's justice will be reported to: 1) the New York State Supreme Court, Appellate Division, 2nd Jurisdictional Department; the Suffolk County District Attorney; the New York State Court of Appeals; the Supreme Court of the United States and the United Nations Office of the High Commission for Human Right, and to Defendant's sister's website. There is no legal or logical way that this Court can require the Defendant to pay for legal services for a case that can never be used in any courtroom because it has already been declared time-barred. While the Plaintiff's religion allows him to take advantage of Gentiles, it would violate the Defendant's First Amendment rights to separation of church and state and freedom of speech; her Fifth Amendment right to due process of the law; and her Fourteenth Amendment right to equal protection of the law as a Gentile, as an African American and as one of Jehovah's Witnesses.

FACTS

  .....SEVENTH-Q: On April 11, 2012, the plaintiff and defendant entered into a retainer agreement where the plaintiff agreed to represent the defendant in connection with an action in the United States District Court for the Eastern District of New York, pursuant to Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e et seq. (Title VII), for national origin discrimination and retaliation against defendant, by her employer as well as for discrimination against defendant by her employer and certain individuals, in violation of 42 U.S.C. § 1983, as well as for pendent State Causes of action in violation of New York Executive Law §290 et seq.

  .....SEVENTH-A: Defendant denies Plaintiff's statement as provably perjurious and as ridiculous because the Plaintiff does not have the right to require the Defendant to pay him more money because he tricked her earlier to pay him $12,000 for a case that he refused to acknowledge as properly time-barred. The Plaintiff perjures himself and defrauded the Defendant based on his attempt to give this Court the false impression that Defendant's case was and is not time-barred. Defendant's case was time-barred even before the met the Plaintiff for the first time.

  .....EIGHTH-Q: The April 11, 2012, fully executed retainer agreement, provided, inter alia, that in consideration for the services plaintiff would render, the defendant would pay plaintiff a minimum fee of Twelve Thousand ($12,000.00) Dollars, (minimum fee) toward the hourly rate for attorney work at Three Hundred Seventy Five ($375.00) Dollars and at the hourly rate of One Hundred Eighty Five ($185.00) Dollars for paralegal work.

  .....EIGHTH-A: Defendant denies Plaintiff's statement as provably perjurious enough to warrant arresting him. The Defendant has no standing to demand this Court to force the Defendant to pay him to litigate a time-barred case, nor does the Plaintiff have the standing to use this Court to trick the Defendant into believing that it is normal to pay thousands of dollar for a case that the Plaintiff found to be time-barred, and that was adjudged to be time-barred a few months later.

  .....The leading case for unconscionability in the United States is Williams v. Walker-Thomas Furniture Co., 350 F.2d 445 (D.C. Cir. 1965). In this case that explains an unconscionable contact, the defendant, a retail furniture store, sold multiple items to a customer from 1957 to 1962. The extended credit contract was written so that none of the furniture was considered to be purchased until all of it was paid for. When the plaintiff defaulted and failed to make payments on the last item of furniture, the furniture store attempted to repossess all of the furniture sold since 1957, not just the last item. The District of Columbia Court of Appeals returned the case to the lower court for trial to determine further facts, but held that the contract could be considered unconscionable and negated if it was procured due to a gross inequality of bargaining power.

  .....The Defendant holds that even if she included persuasive case law, justice requires fairness. Defendant holds that it is unfair to trick a client to pay for a service for which neither Defendant or her case can obtain any benefit. Defendant holds that the Plaintiff's act in charging the Defendant money for a service from which her case could never benefit was an act of fraud. It was fraudulent then, and it is fraudulent now. It is also racist based on the Judaic believe that as a Jew, the Plaintiff has the right to rip Gentiles off with impunity – especially African Americans, and to allow Plaintiff and other Jews to oppress Gentiles with impunity.

  .....NINTH-Q: Defendant also agreed and acknowledged that in further consideration of the services rendered to her by plaintiff that in the event she received monetary recovery, whether by settlement and/or by any other means, (exclusive of disbursements), including but not limited to a jury verdict and/or mediation, that exceeded her minimum fee, that her minimum fee would be returned to her first by plaintiff and then plaintiff's fee would be thirty-three and one third percent of any sum recovered in excess of her minimum fee.

  .....NINTH-A: Defendant first denies Plaintiff's statement as hearsay, unusable by this Court. Additionally, Defendant denies Plaintiff's statement as perjurious, unprovable, racially and religiously motivated based on the Judaic doctrines Law of the Moser, that requires Jews not to report the crimes of fellow Jews to other Gentiles (Babylonian Talmud, Tractate Abodah Zarah, Folio 26b; that allows Jews to use subterfuge to trick Gentiles in judicial settings (Babylonian Talmud, Tractate Baba Kamma, Folio 113a); and the Curse of Dark Skin (Babylonian Talmud, Tractate 108b, footnote 34). Defendant also reminds this Court that the Plaintiff has no standing to require the Defendant to obey an unconscionable contract that requires her to pay an attorney to attempt to litigate a case that was adjudged as time-barred.

  .....TENTH-Q: As per the retainer agreement, defendant further agreed that in the event a dispute should arise as to plaintiff's fees for legal services, that the fee dispute will be resolved by arbitration conducted pursuant to Part 137 of the Rules of the Chief Administrator of the Courts (22 NYCRR), and that plaintiff and defendant agreed to be bound by the decision of the arbitrator(s) and agreed to waive their respective rights to reject the arbitrator(s) award and would not commence an action on the merits (trial de novo) in a court of law.

  .....TENTH-A: First, Defendant denies Plaintiff's statement as perjurious and irrelevant because the Plaintiff has no standing to tell this Court that it has a legal obligation to help the Plaintiff trick the Defendant into paying thousands of dollars for legal work that the Plaintiff never did, based on the Plaintiff's refusal to ascertain how many days the Plaintiff had left to litigate the case. Defendant first denies Plaintiff's statement as hearsay, unusable by this Court. Additionally, Defendant denies Plaintiff's statement as perjurious, unprovable, racially and religiously motivated because the Plaintiff took the $12,000 to perform “legal work”, he did not do the legal work necessary to determine and acknowledge the case's lack of court-worthiness of the time-barred case. Defendant denies Plaintiff's statement as perjurious, unprovable and racially and religiously motivated. In addition, the Plaintiff has no standing to ask this Court to require the Defendant to obey an unconscionable contract that requires Defendant to pay the Plaintiff for work he never did, based on the Plaintiff's failure to see that the case was time-barred. The Plaintiff instead formed a RICO with members of this Court to engage in some  childish prank that a corrupt justice would use to employ willful blindness2, in order not to see the truth, but to see legal minutiae and other ways to misuse the law in order to render decisions based on wrongly employed legal technicalities. The Plaintiff engaged in fraud to trick the Defendant into agreeing to going along with a unconscionable contract for which Plaintiff rationalized Defendant as worthless based on her race and religion, worthless as a Gentile and deserving to have $12,000 stolen from her by the Plaintiff, who rationalizes his commission of grand larceny and fraud are entitlements because he is Jewish, and because of his belief that he can make arrangements with this Court's justice because he is Jewish. Part 137 of the Rules of the Chief Administrator of the Courts (22 NYCRR), never applied to the Defendant because at the time of the Plaintiff's pretense of entering into a “contract”, Defendant's case was declared res judicata by the federal district court because it was time-barred by the case's statute of limitations.

  .....ELEVENTH-Q: The plaintiff and defendant understood that each were not required to agree to waive their rights to seek a trial de novo under Part 137.

.....ELEVENTH-A: Defendant denies Plaintiff's statement as perjurious and irrelevant because the Plaintiff lacks standing to seek a trial because Defendant's case was time-barred before they met. It was officially adjudged to be time-barred by federal district magistrate Tomlinson in her Memorandum and Order, and found to be correct by federal district just Sandra Feuerstein in her Order. The Plaintiff does not possess psychic skills to be able to tell this Court 

what Defendant understood. Defendant demands that this Court suffice it to say that a person who holds himself/herself out to be psychic must not be believed.

Plaintiff's attempt to offer unprovable statement as testimony to be believed by this Court is so incredibly dangerous that Defendant has no recourse other than to report this grab for undeserved judicial favor to law enforcement.

  .....TWEFLTH-Q: On April 18, 2013, defendant directed plaintiff to stop representing her and requested to know what her financial obligation was to plaintiff.

  .....TWEFLTH-A: To be determined during discovery.

  .....THIRTEENTH-Q: Defendant further advised plaintiff that she wanted to represent herself, and that she was not firing plaintiff, that she was parting with plaintiff in very good terms, and knew in her heart that plaintiff wanted to continue representing her and fighting for her.

  .....THIRTEENTH-A: Defendant denies Plaintiff's statement as perjurious and irrelevant because the Plaintiff has no standing to require this Court to force the Defendant to pay for “service rendered to a case that was time-barred before Plaintiff met the Defendant, and officially adjudicated by a competent court of law. Also, if there is any time at which the Defendant believed the Plaintiff “knew in her heart that Plaintiff wanted to continue representing her and fighting her”, all this implies is that the Defendant was naive and lacked legal experience. Proof of this is the fact, instead of checking her case for the statute of limitations, a relatively easy task for a person with a little bit of legal knowledge, instead, the Defendant naively gave the Plaintiff $12,000 for a case that was time-barred when she met him, and adjudged to be time-barred a few months later. Defendant in no way implies that the Plaintiff was anything other than a liar/perjurer, a thief and a criminal motivated by greed and by so much of a sense of superiority over African Americans that he has no scruples to present his criminal verified complaint to this Court – with a belief to an entitlement that requires this Court to form a RICO to violate the law – solely because Plaintiff is a Jew.

  .....In addition, the Plaintiff lacks standing to seek a trial anywhere the Defendant is concerned. Defendant's case was time-barred before they met. The case was officially adjudicated as time-barred by federal district magistrate Tomlinson in her Memorandum and Order, and found to be correct by federal district just Sandra Feuerstein in her Order.

  .....FOURTEENTH-Q: Defendant thanked plaintiff for all their work, and that she was honorably discharging plaintiff as her attorney's.

  .....FOURTEENTH-A: First, Defendant denies Plaintiff's statement as perjurious and irrelevant because the Plaintiff has no standing to tell this Court that it has a legal obligation to help the Plaintiff trick the Defendant into paying thousands of dollars for legal work that the Plaintiff never did, based on the Plaintiff's refusal to ascertain how many days the Plaintiff had left to litigate the case. Defendant first denies Plaintiff's statement as hearsay, unusable by this Court. Additionally, Defendant denies Plaintiff's statement as perjurious, unprovable, racially and religiously motivated because the Plaintiff took the $12,000 to perform “legal work”, he did not do the legal work necessary to determine and acknowledge the case's lack of court-worthiness of the time-barred case. Defendant denies Plaintiff's statement as perjurious, unprovable and racially and religiously motivated. In addition, the Plaintiff has no standing to ask this Court to require the Defendant to obey an unconscionable contract that requires Defendant to pay the Plaintiff for work he never did, based on the Plaintiff's failure to see that the case was time-barred.

  .....Defendant denies Plaintiff's statement as hearsay, perjurious and irrelevant because the Plaintiff has no standing to require this Court to force the Defendant to pay for the legal services of determining when was that the Plaintiff never rendered”i to a case that was time-barred Defendant he Union dale Union Free School District, and http://docs.justia.com/cases/federal/district-courts/new-york/nyedce/2:2012cv01482/328688/75/0.pdf on page eight (8), paragraph one (1), which says:

In countering these arguments, Defendants contend that (i) Plaintiff’s allegations regarding her attorneys are vague and conclusory and are not sufficient to establish good cause; (ii) the addition of the Board of Education is unnecessary since Plaintiff has already named the School District as a Defendant, which encompasses the Board of Education, and, in any case, Plaintiff has long been aware of the existence of the Board of Education; (iii) any new details with respect to Plaintiff’s national origin discrimination claims are unnecessary and/or duplicative since Plaintiff has already conducted full discovery on these claims; and (iv) the alleged facts underlying Plaintiff’s new sex discrimination allegations were known to Plaintiff at the time of the filing of the FAC, and, in any event, those claims are barred by the statute of limitations because plaintiff never filed a charge of sex discrimination with the EEOC. See Defs.’ Opp. At 1-3. 

  .....FIFTEENTH-Q: Plaintiff advised defendant that in order to honor her decision, that plaintiff had to letter motion via an application to the Court for its "SO ORDER," to be relieved as defendant's counsel. 

  .....FIFTEENTH-A: Defendant denies Plaintiff's statement as perjurious and irrelevant, insofar as the Plaintiff has no standing to tell this Court that he has been injured because the Defendant refused to pay him for “litigating” a case that has already been adjudicated as time-barred.

  .....SIXTEENTH-Q: As such, on April 18, 2013, plaintiff drafted a letter application for defendant's approval, prior to filing same with the Court, to be relieved as defendant's counsel, which read, “Via ECF, April 18.2013, Hon. Sandra J. Feuerstein, United States District Court, Eastern District of New York, Long Island Federal Courthouse, 814 Federal Plaza, Central Islip, NY 11722-9014, Re: CV: 12-1481)SJF)(AKT), Guitar v. Uniondale Union Free School District, et al.

  .....SIXTEENTH-A: Defendant denies Plaintiff's statement as provably perjurious and irrelevant because, inter alia, the Plaintiff does not have standing to tell this Court that the Defendant is obliged to pay money to the Plaintiff even though the Plaintiff stole thousands of dollars under the guise of “performing legal work,” but failed to do so when the Plaintiff incompetently and fraudulently failed to perform any work associated with determining the amount of time left for the statute of limitations. Defendant denies Plaintiff's statement as perjurious and lacking standing because the Plaintiff does not have the legal right to commit perjury for the sole purpose of pretending that Plaintiff's intentional failure to determine the statute of limitations for Defendant's case and the amount of time left to file Defendant's case while forcing the Plaintiff to honor an unconscionable contract the requires the Defendant to pay thousands of dollars for Plaintiff's failure to determine the statute of limitations for the Defendant's cause of action and how much time was left to file Plaintiff's case would ever represent “performing legal work” in any court of law.

  .....SEVENTEENTH-Q: Prior to submitting the draft letter motion as described herein in Paragraph "SIXTEENTH," plaintiff read the draft letter motion to defendant for her approval, to which defendant stated after plaintiff read same to defendant that it “was wonderful," and gave plaintiff authorization to file it with the Court, and then stated that she wanted to pay plaintiff all her legal fees and to please send her a bill.

  .....SEVENTEENTH-A: Defendant denies Plaintiff's statement as provably perjurious and irrelevant because, inter alia, the Plaintiff does not have standing to tell this Court that the Defendant is obliged to pay money to the Plaintiff even though the Plaintiff stole thousands of dollars under the guise of “performing legal work,” but failed to do so when the Plaintiff incompetently and fraudulently failed to perform any work associated with determining the amount of time left for the statute of limitations. Defendant denies Plaintiff's statement as perjurious and lacking standing because the Plaintiff does not have the legal right to commit perjury for the sole purpose of pretending that Plaintiff's intentional failure to determine the statute of limitations for Defendant's case and the amount of time left to file Defendant's case while forcing the Plaintiff to honor an unconscionable contract the requires the Defendant to pay thousands of dollars for Plaintiff's failure to determine the statute of limitations for the Defendant's cause of action and how much time was left to file Plaintiff's case would ever represent “performing legal work” in any court of law.

  .....EIGHTEENTH-Q: Plaintiff advised defendant that a Statement for Services would be provided to her shortly. Defendant replied "very well," and "thank you very much."

  .....EIGHTEENTH-A: Defendant denies Plaintiff's statement as provably perjurious, as unprovable hearsay and irrelevant because, inter alia, the Plaintiff does not have standing to tell this Court that the Defendant is obliged to pay money to the Plaintiff even though the Plaintiff stole thousands of dollars under the guise of “performing legal work,” but failed to do so when the Plaintiff incompetently and fraudulently failed to perform any work associated with determining the amount of time left for the statute of limitations. Defendant denies Plaintiff's statement as perjurious and lacking standing because the Plaintiff does not have the legal right to commit perjury for the sole purpose of pretending that Plaintiff's intentional failure to determine the statute of limitations for Defendant's case and the amount of time left to file Defendant's case while forcing the Plaintiff to honor an unconscionable contract the requires the Defendant to pay thousands of dollars for Plaintiff's failure to determine the statute of limitations for the Defendant's cause of action and how much time was left to file Plaintiff's case would ever represent “performing legal work” in any court of law.

  .....NINETEENTH-Q: Plaintiff then filed said letter application, and on April 19, 2013, Judge Feuerstein granted plaintiff's letter application to withdraw as defendant's attorney.

  .....NINETEENTH-A: Defendant denies Plaintiff's statement as irrelevant because, inter alia because the Plaintiff does not have standing to tell this Court that the Defendant is obliged to pay money to the Plaintiff even though the Plaintiff stole thousands of dollars under the guise of “performing legal work,” but failed to do so when the Plaintiff incompetently and fraudulently failed to perform any work associated with determining the amount of time left for the statute of limitations. Defendant denies Plaintiff's statement as perjurious and lacking standing because the Plaintiff does not have the legal right to commit perjury for the sole purpose of pretending that Plaintiff's intentional failure to determine the statute of limitations for Defendant's case and the amount of time left to file Defendant's case while forcing the Plaintiff to honor an unconscionable contract the requires the Defendant to pay thousands of dollars for Plaintiff's failure to determine the statute of limitations for the Defendant's cause of action and how much time was left to file Plaintiff's case would ever represent “performing legal work” in any court of law.

  .....TWENTY-Q: As of April 18, 2013, plaintiff worked Two Hundred Twenty One hours and Eleven (221.11) minutes on defendants matter for a total of hourly fee of Seventy Six Thousand Nine Hundred Twenty Seven ($76,927.51) Dollars and Fifty One Cents.

  .....TWENTY-A: Defendant denies Plaintiff's statement as irrelevant because, inter alia because the Plaintiff does not have standing to tell this Court that the Defendant is obliged to pay money to the Plaintiff because the Plaintiff padded his bill after refusing to determine the the statute of limitations for the causes of action Defendant's case, and then charging thousands of dollars in “fees” for refusing to determine whether Defendant's case was time-barred, something that would have been his fiduciary responsibility had he been dealing with the Defendant honestly. Even though the Plaintiff stole thousands of dollars under the guise of “performing legal work,” Plaintiff failed to do so when the Plaintiff incompetently and fraudulently failed to perform any work associated with determining the amount of time left for the statute of limitations. Defendant denies Plaintiff's statement as perjurious and lacking standing because the Plaintiff does not have the legal right to commit perjury for the sole purpose of pretending that Plaintiff's intentional failure to determine the statute of limitations for Defendant's case and the amount of time left to file Defendant's case while forcing the Plaintiff to honor an unconscionable contract the requires the Defendant to pay thousands of dollars for Plaintiff's failure to determine the statute of limitations for the Defendant's cause of action and how much time was left to file Plaintiff's case would ever represent “performing legal work” in any court of law. http://www.recordonline.com/apps/pbcs.dll/article?AID=/20040218/NEWS/302189994&cid=sitesearch, Lawyer Accused of Padding Bills, By Oliver Mackson,Times Herald-Record:

Poughkeepsie defense lawyer Donald Roth may face more trouble besides five years in federal prison for trying to submarine a Newburgh drug case. For months, Dutchess County prosecutors have been examining Roth's billing records, which showed him working as much as 25 hours a day on court-assigned cases. Federal prosecutors used those records to attack Roth's credibility during a trial that ended last week. Roth and a private investigator, David St. John of Millerton, were convicted of conspiracy to tamper with witnesses and obstruction of justice. 

On May 25, 2001, "Donald Roth became Superman and he billed 25 hours in a day," a federal prosecutor told the jury during closing arguments in Roth's trial last week. "He was padding the bill, and that's dishonest."

The jury also saw copies of bills that Roth submitted for work he did in April 2001. One day showed 24 hours of work; another showed 24.6 hours.


.....TWENTY FIRST-Q: As of April 18, 2013, defendants only payment was her minimum fee of Twelve Thousand ($12,000.00) Dollars.

  ...TWENTY FIRST-A: Defendant denies Plaintiff's statement as irrelevant because, inter alia because the Plaintiff does not have standing to tell this Court that the Defendant is obliged to pay money to the Plaintiff because the Plaintiff padded his bill after refusing to determine the the statute of limitations for the causes of action Defendant's case, and then charging thousands of dollars in “fees” for refusing to determine whether Defendant's case was time-barred, something that would have been his fiduciary responsibility had he been dealing with the Defendant honestly. Even though the Plaintiff stole thousands of dollars under the guise of “performing legal work,” Plaintiff failed to do so when the Plaintiff incompetently and fraudulently failed to perform any work associated with determining the amount of time left for the statute of limitations. Defendant denies Plaintiff's statement as perjurious and lacking standing because the Plaintiff does not have the legal right to commit perjury for the sole purpose of pretending that Plaintiff's intentional failure to determine the statute of limitations for Defendant's case and the amount of time left to file Defendant's case while forcing the Plaintiff to honor an unconscionable contract the requires the Defendant to pay thousands of dollars for Plaintiff's failure to determine the statute of limitations for the Defendant's cause of action and how much time was left to file Plaintiff's case would ever represent “performing legal work” in any court of law.

  .....TWENTY SECOND-Q: Defendant's outstanding balance that is due and owed to plaintiff is Sixty Four Thousand Nine Hundred Twenty Seven ($64,927.51) Dollars and Fifty-One Cents.

  .....TWENTY SECOND-A: Defendant denies Plaintiff's statement as irrelevant because, inter alia because the Plaintiff does not have standing to tell this Court that the Defendant is obliged to pay money to the Plaintiff because the Plaintiff padded his bill after refusing to determine the the statute of limitations for the causes of action Defendant's case, and then charging thousands of dollars in “fees” for refusing to determine whether Defendant's case was time-barred, something that would have been his fiduciary responsibility had he been dealing with the Defendant honestly. Even though the Plaintiff stole thousands of dollars under the guise of “performing legal work,” Plaintiff failed to do so when the Plaintiff incompetently and fraudulently failed to perform any work associated with determining the amount of time left for the statute of limitations. Defendant denies Plaintiff's statement as perjurious and lacking standing because the Plaintiff does not have the legal right to commit perjury for the sole purpose of pretending that Plaintiff's intentional failure to determine the statute of limitations for Defendant's case and the amount of time left to file Defendant's case while forcing the Plaintiff to honor an unconscionable contract the requires the Defendant to pay thousands of dollars for Plaintiff's failure to determine the statute of limitations for the Defendant's cause of action and how much time was left to file Plaintiff's case would ever represent “performing legal work” in any court of law.

  .....TWENTY THIRD-Q: As per defendant's requests, on April 25, 2013, plaintiff provided defendant with her Eighteen (18) Page Statement for Professional Services, which described all work and time performed by plaintiff for defendant with an outstanding of Sixty Four Thousand Nine Hundred Twenty Seven ($64,927.51) Dollars and Fifty-One Cents due and owed to plaintiff.

  .....TWENTY THIRD-A: Defendant denies Plaintiff's statement as irrelevant because, inter alia, the Plaintiff does not have standing to tell this Court that the Defendant is obliged to pay money to the Plaintiff because the Plaintiff padded his bill after refusing to determine the statute of limitations for the causes of action Defendant's case, and then charging thousands of dollars in “fees” for refusing to determine whether Defendant's case was time-barred, something that would have been his fiduciary responsibility had he been dealing with the Defendant honestly. Even though the Plaintiff stole thousands of dollars under the guise of “performing legal work,” Plaintiff failed to do so when the Plaintiff incompetently and fraudulently failed to perform any work associated with determining the amount of time left for the statute of limitations. Defendant denies Plaintiff's statement as perjurious and lacking standing because the Plaintiff does not have the legal right to commit perjury for the sole purpose of pretending that Plaintiff's intentional failure to determine the statute of limitations for Defendant's case and the amount of time left to file Defendant's case while forcing the Plaintiff to honor an unconscionable contract the requires the Defendant to pay thousands of dollars for Plaintiff's failure to determine the statute of limitations for the Defendant's cause of action and how much time was left to file Plaintiff's case would ever represent “performing legal work” in any court of law.

  .....TWENTY FOURTH-Q: When plaintiff failed to remit her requested balance due, pursuant to the retainer agreement, on May 31, 2013, plaintiff filed its "Attorney Request for Fee Arbitration" with the Suffolk County Bar Association.

  .....TWENTY FOURTH-A: Defendant denies Plaintiff's statement as irrelevant because, inter alia, the Plaintiff does not have standing to tell this Court that the Defendant is obliged to pay money to the Plaintiff because the Plaintiff padded his bill after refusing to determine the statute of limitations for the causes of action Defendant's case, and then charging thousands of dollars in “fees” for refusing to determine whether Defendant's case was time-barred, something that would have been his fiduciary responsibility had he been dealing with the Defendant honestly. Even though the Plaintiff stole thousands of dollars under the guise of “performing legal work,” Plaintiff failed to do so when the Plaintiff incompetently and fraudulently failed to perform any work associated with determining the amount of time left for the statute of limitations. Defendant denies Plaintiff's statement as perjurious and lacking standing because the Plaintiff does not have the legal right to commit perjury for the sole purpose of pretending that Plaintiff's intentional failure to determine the statute of limitations for Defendant's case and the amount of time left to file Defendant's case while forcing the Plaintiff to honor an unconscionable contract the requires the Defendant to pay thousands of dollars for Plaintiff's failure to determine the statute of limitations for the Defendant's cause of action and how much time was left to file Plaintiff's case would ever represent “performing legal work” in any court of law.

  .....TWENTY FIFTH-Q: On July 9, 2013, plaintiff received notification from the Suffolk County Bar Association advising that since defendant was planning on bringing a malpractice action against plaintiff in the future, that the Fee Dispute Resolution Committee lacked jurisdiction to determine plaintiff's fee dispute set forth in 22 NYCRR §137.1(b)(3) (4).

  .....This notification by the Suffolk County Bar Association provided plaintiff with the authority to commence this instant action for its earned fees.

  ....TWENTY FIFTH-A: Defendant denies Plaintiff's statement regarding the Suffolk County Bar Association as perjurious. The Suffolk County Bar Association is, in practice, a RICO that allows attorneys, especially those who are Jewish, to steal money from Gentile clients under the guise the money stolen by the attorneys are “fee disputes” and not acts of crime based on the Judaic doctrine Law of the Moser, that prohibits Jews from reporting fellow Jews who commit crimes; and also acts to block Gentiles from filing criminal complaints against fellow Jews – even crimes as serious as child rape by a rabbi. Defendant also denies Plaintiff's statement as irrelevant because, inter alia, the Plaintiff does not have standing to tell this Court that the Defendant is obliged to pay money to the Plaintiff because the Plaintiff padded his bill after refusing to determine the the statute of limitations for the causes of action Defendant's case, and then charging thousands of dollars in “fees” for refusing to determine whether Defendant's case was time-barred, something that would have been his fiduciary responsibility had he been dealing with the Defendant honestly. Even though the Plaintiff stole thousands of dollars under the guise of “performing legal work,” Plaintiff failed to do so when the Plaintiff incompetently and fraudulently failed to perform any work associated with determining the amount of time left for the statute of limitations. Defendant denies Plaintiff's statement as perjurious and lacking standing because the Plaintiff does not have the legal right to commit perjury for the sole purpose of pretending that Plaintiff's intentional failure to determine the statute of limitations for Defendant's case and the amount of time left to file Defendant's case while forcing the Plaintiff to honor an unconscionable contract the requires the Defendant to pay thousands of dollars for Plaintiff's failure to determine the statute of limitations for the Defendant's cause of action and how much time was left to file Plaintiff's case would ever represent “performing legal work” in any court of law.

AS FOR DEFENDANT'S FIRST CAUSE OF ACTION, PLAINTIFF HAS NO RIGHT
TO RECOVER ANY DAMAGES ON THE BASIS OF QUANTUM MERUIT
 

   .....Plaintiff is entitled to jail time for the following: fraud; grand larceny; coercion (first degree); to pay all attorney fees and costs associated with this proceeding, to publicly apologize to the Defendant and for equitable relief. Plaintiff did not work to determine the case's statute of limitation. Any padding of Defendant's case, whether intentional or unintentional were the fault of the Plaintiff for using willful blindness for not doing his job and an attorney to determine the case's statute of limitation, or how much time he had left to file the case with the court, or if the case was time-barred. That was Plaintiff's job and he did not do it. Plaintiff now lacks the standing to tell this Court to make the Defendant pay for his mistake.

  .....TWENTY SEVENTH-Q: Plaintiff repeats and realleges each and every allegation contained in paragraphs “FIRST” through “TWENTY SIXTH” as though fully set forth at length herein.

  .....TWENTY SEVENTH-A: Defendant repeats and realleges each and every allegation contained in paragraphs “1A through TWENTY SEVENTH-A as though fully set forth at length herein.

  .....TWENTY EIGHTH-Q: Plaintiffs honorable discharge as defendant's counsel, at the direction of defendant, was justifiable for plaintiff to motion the Court to be relieved as defendant's counsel and therefore does not forfeit any right to recover damages for services rendered by plaintiff to defendant.

  .....TWENTY-EIGHTH-A: Defendant denies Plaintiff's statement as irrelevant because, inter alia because the Plaintiff does not have standing to tell this Court that the Defendant is obliged to pay money to the Plaintiff because the Plaintiff padded his bill after refusing to determine the statute of limitations for the causes of action Defendant's case, and then charging thousands of dollars in “fees” while engaging in willfulness to rationalize Plaintiff's refusal to determine whether Defendant's case was time-barred, something that would have been his fiduciary responsibility had he been dealing with the Defendant honestly. Even though the Plaintiff stole thousands of dollars under the guise of “performing legal work,” Plaintiff failed to do so when the Plaintiff incompetently and fraudulently failed to perform any work associated with determining the amount of time left for the statute of limitations. Defendant denies Plaintiff's statement as perjurious and lacking standing because the Plaintiff does not have the legal right to first employ willfulness blindness to commit perjury, to pretend that the Plaintiff had do competent legal work when the Plaintiff's intentionally failure to determine the statute of limitations for Defendant's case and the amount of time left to file Defendant's case while forcing the Plaintiff to honor an unconscionable contract the requires the Defendant to pay thousands of dollars to engage in willful blindness to rationalize Plaintiff's failure to determine the statute of limitations for the Defendant's cause of action and how much time was left to file Plaintiff's case would ever represent “performing legal work” in any court of law.

  .....TWENTY NINTH-Q: Plaintiff has the right to recover all attorney fees, as damages, pursuant to quantum meruit, due to defendant's directive that plaintiff advise the Court that defendant honorably discharged plaintiff as its attorneys.

  .....TWENTY NINTH-A: Defendant denies Plaintiff's statement as irrelevant because, inter alia because the Plaintiff does not have standing to tell this Court that the Defendant is obliged to pay money to the Plaintiff because the Plaintiff padded his bill after refusing to determine the the statute of limitations for the causes of action of Defendant's case, and then engage in willful blindness to charge Defendant thousands of dollars in “fees” for refusing to determine whether Defendant's case was time-barred, something that would have been his fiduciary responsibility had he been dealing with the Defendant honestly. Even though the Plaintiff stole thousands of dollars under the guise of “performing legal work,” Plaintiff failed to do so when the Plaintiff incompetently and fraudulently failed to perform any work associated with determining the amount of time left for the statute of limitations. Defendant denies Plaintiff's statement as perjurious and lacking standing because the Plaintiff does not have the legal right to commit perjury for the sole purpose of pretending that Plaintiff's intentional failure to determine the statute of limitations for Defendant's case and the amount of time left to file Defendant's case while forcing the Plaintiff to honor an unconscionable contract the requires the Defendant to pay thousands of dollars for Plaintiff's failure to determine the statute of limitations for the Defendant's cause of action and how much time was left to file Plaintiff's case would ever represent “performing legal work” in any court of law.

  .....THIRTY-Q: Since it was defendant that breached the retainer agreement, plaintiff is entitled to its earned hourly attorney fees on a quantum meruit basis.

AS FOR DEFENDANT'S SECOND CAUSE OF ACTION PLAINTIFF HAS THE RIGHT
TO RECOVER HIS DAMAGES ON THE BASIS OF BREACH OF CONTRACT
 

  .....THIRTY-A: Defendant holds that in the mind of the Plaintiff, there was no breach of contract, only the opportunity to rip off a Gentile, and an African American who is one of Jehovah's Witnesses. In addition, Defendant holds that even in the best of circumstances, it was not Defendant who violated the contract, it was the Plaintiff. It was not the Defendant's responsibility to know enough of the law to determine the statute of limitation for her case. If there was any breach of contract at all, it was the Plaintiff, not the Defendant.

  .....Defendant denies Plaintiff's statement as irrelevant because, inter alia because the Plaintiff does not have standing to tell this Court that the Defendant is obliged to pay money to the Plaintiff because the Plaintiff padded his bill after refusing to determine the the statute of limitations for the causes of action Defendant's case, and then charging thousands of dollars in “fees” for refusing to determine whether Defendant's case was time-barred, something that would have been his fiduciary responsibility had he been dealing with the Defendant honestly. Even though the Plaintiff stole thousands of dollars under the guise of “performing legal work,” Plaintiff failed to do so when the Plaintiff incompetently and fraudulently failed to perform any work associated with determining the amount of time left for the statute of limitations. Defendant denies Plaintiff's statement as perjurious and lacking standing because the Plaintiff does not have the legal right to commit perjury for the sole purpose of pretending that Plaintiff's intentional failure to determine the statute of limitations for Defendant's case and the amount of time left to file Defendant's case while forcing the Plaintiff to honor an unconscionable contract the requires the Defendant to pay thousands of dollars for Plaintiff's failure to determine the statute of limitations for the Defendant's cause of action and how much time was left to file Plaintiff's case would ever represent “performing legal work” in any court of law.

  .....THIRTY FIRST-Q: Plaintiff repeats and realleges each and every allegation contained in paragraphs "FIRST" through "THIRTY" as though fully set forth at length herein.

  .....THIRTY FIRST-A: Defendant repeats and realleges each and every allegation contained in paragraphs “1A through THIRTY FIRST-A as though fully set forth at length herein.

  .....THIRTY SECOND-Q: Defendant discharged plaintiff after plaintiff performed Two Hundred Twenty One and Eleven hours (221.11) minutes, of service for defendant, resulting in defendant's unjust enrichment and thus having an outstanding contractual obligation to plaintiff for its hourly fees of Sixty Four Thousand Nine Hundred Twenty Seven ($64,927.51) Dollars and Fifty-One Cents, prior to the completion of the services for which the fee was agreed upon.

  .....THIRTY SECOND-A: Defendant holds that in the mind of the Plaintiff, there was no breach of contract, only the opportunity to rip off a Gentile, and an African American who is one of Jehovah's Witnesses. In addition, Defendant holds that even in the best of circumstances, it was not Defendant who violated the contract, it was the Plaintiff. It was not the Defendant's responsibility to know enough of the law to determine the statute of limitation for her case. That was the Plaintiff's responsibility. If there was any breach of contract at all, it was the Plaintiff, not the Defendant.

  .....Defendant denies Plaintiff's statement as irrelevant because, inter alia because the Plaintiff does not have standing to tell this Court that the Defendant is obliged to pay money to the Plaintiff because the Plaintiff padded his bill after refusing to determine the the statute of limitations for the causes of action Defendant's case, and then charging thousands of dollars in “fees” for refusing to determine whether Defendant's case was time-barred, something that would have been his fiduciary responsibility had he been dealing with the Defendant honestly. Even though the Plaintiff stole thousands of dollars under the guise of “performing legal work,” Plaintiff failed to do so when the Plaintiff incompetently and fraudulently failed to perform any work associated with determining the amount of time left for the statute of limitations. Defendant denies Plaintiff's statement as perjurious and lacking standing because the Plaintiff does not have the legal right to commit perjury for the sole purpose of pretending that Plaintiff's intentional failure to determine the statute of limitations for Defendant's case and the amount of time left to file Defendant's case while forcing the Plaintiff to honor an unconscionable contract the requires the Defendant to pay thousands of dollars for Plaintiff's failure to determine the statute of limitations for the Defendant's cause of action and how much time was left to file Plaintiff's case would ever represent “performing legal work” in any court of law.

.....THIRTY THIRD-Q: As such, plaintiff is entitled to recover compensation from the defendant for hours of work of completed services as damages in the amount of Sixty Four Thousand Nine Hundred Twenty Seven ($64,927.51) Dollars and Fifty-One Cents.

.....THIRTY THIRD-A: Defendant holds that in the mind of the Plaintiff, there was no breach of contract, only the opportunity to rip off a Gentile, and an African American who is one of Jehovah's Witnesses. In addition, Defendant holds that even in the best of circumstances, it was not Defendant who violated the contract, it was the Plaintiff. It was not the Defendant's responsibility to know enough of the law to determine the statute of limitation for her case. If there was any breach of contract at all, it was the Plaintiff, not the Defendant.

  .....Defendant denies Plaintiff's statement as irrelevant because, inter alia because the Plaintiff does not have standing to tell this Court that the Defendant is obliged to pay money to the Plaintiff because the Plaintiff padded his bill after refusing to determine the the statute of limitations for the causes of action Defendant's case, and then charging thousands of dollars in “fees” for refusing to determine whether Defendant's case was time-barred, something that would have been his fiduciary responsibility had he been dealing with the Defendant honestly. Even though the Plaintiff stole thousands of dollars under the guise of “performing legal work,” Plaintiff failed to do so when the Plaintiff incompetently and fraudulently failed to perform any work associated with determining the amount of time left for the statute of limitations. Defendant denies Plaintiff's statement as perjurious and lacking standing because the Plaintiff does not have the legal right to commit perjury for the sole purpose of pretending that Plaintiff's intentional failure to determine the statute of limitations for Defendant's case and the amount of time left to file Defendant's case while forcing the Plaintiff to honor an unconscionable contract the requires the Defendant to pay thousands of dollars for Plaintiff's failure to determine the statute of limitations for the Defendant's cause of action and how much time was left to file Plaintiff's case would ever represent “performing legal work” in any court of law.

  .....THIRTY FOURTH-Q: Since defendant breached the retainer agreement, plaintiff is entitled to all of its earned hourly attorney fees, based on defendant's breach of contract.

  .....THIRTY FOURTH-A: Defendant holds that in the mind of the Plaintiff, there was no breach of contract, only the opportunity to rip off a Gentile, and an African American who is one of Jehovah's Witnesses. In addition, Defendant holds that even in the best of circumstances, it was not Defendant who violated the contract, it was the Plaintiff. It was not the Defendant's responsibility to know enough of the law to determine the statute of limitation for her case. If there was any breach of contract at all, it was the Plaintiff, not the Defendant.

  .....Defendant denies Plaintiff's statement as irrelevant because, inter alia because the Plaintiff does not have standing to tell this Court that the Defendant is obliged to pay money to the Plaintiff because the Plaintiff padded his bill after refusing to determine the the statute of limitations for the causes of action Defendant's case, and then charging thousands of dollars in “fees” for refusing to determine whether Defendant's case was time-barred, something that would have been his fiduciary responsibility had he been dealing with the Defendant honestly. Even though the Plaintiff stole thousands of dollars under the guise of “performing legal work,” Plaintiff failed to do so when the Plaintiff incompetently and fraudulently failed to perform any work associated with determining the amount of time left for the statute of limitations. Defendant denies Plaintiff's statement as perjurious and lacking standing because the Plaintiff does not have the legal right to commit perjury for the sole purpose of pretending that Plaintiff's intentional failure to determine the statute of limitations for Defendant's case and the amount of time left to file Defendant's case while forcing the Plaintiff to honor an unconscionable contract the requires the Defendant to pay thousands of dollars for Plaintiff's failure to determine the statute of limitations for the Defendant's cause of action and how much time was left to file Plaintiff's case would ever represent “performing legal work” in any court of law. Plaintiff does not have the legal right to commit perjury for the sole purpose of pretending that Plaintiff's intentional failure to determine the statute of limitations for Defendant's case and the amount of time left to file Defendant's case while forcing the Plaintiff to honor an unconscionable contract the requires the Defendant to pay thousands of dollars for Plaintiff's failure to determine the statute of limitations for the Defendant's cause of action and how much time was left to file Plaintiff's case would ever represent “performing legal work” in any court.

  .....THIRTY FIFTH-Q: Defendant also agreed, pursuant to the retainer agreement, to pay for all disbursements in connection with her matter and that disbursements were separate fees from her hourly retainer fee and included but were not limited to, service of process, travel, charges for electronic research, depositions, photocopying, federal express and were due to notification to her.

  .....THIRTY-FIFTH-A: Defendant holds that in the mind of the Plaintiff, there was no breach of contract, only the opportunity to rip off a Gentile, and an African American who is one of Jehovah's Witnesses. In addition, Defendant holds that even in the best of circumstances, it was not Defendant who violated the contract, it was the Plaintiff. It was not the Defendant's responsibility to know enough of the law to determine the statute of limitation for her case. If there was any breach of contract at all, it was the Plaintiff, not the Defendant.

  .....Defendant denies Plaintiff's statement as irrelevant because, inter alia because the Plaintiff does not have standing to tell this Court that the Defendant is obliged to pay money to the Plaintiff because the Plaintiff padded his bill after refusing to determine the the statute of limitations for the causes of action Defendant's case, and then charging thousands of dollars in “fees” for refusing to determine whether Defendant's case was time-barred, something that would have been his fiduciary responsibility had he been dealing with the Defendant honestly. Even though the Plaintiff stole thousands of dollars under the guise of “performing legal work,” Plaintiff failed to do so when the Plaintiff incompetently and fraudulently failed to perform any work associated with determining the amount of time left for the statute of limitations. Defendant denies Plaintiff's statement as perjurious and lacking standing because the Plaintiff does not have the legal right to commit perjury for the sole purpose of pretending that Plaintiff's intentional failure to determine the statute of limitations for Defendant's case and the amount of time left to file Defendant's case while forcing the Plaintiff to honor an unconscionable contract the requires the Defendant to pay thousands of dollars for Plaintiff's failure to determine the statute of limitations for the Defendant's cause of action and how much time was left to file Plaintiff's case would ever represent “performing legal work” in any court of law. Plaintiff does not have the legal right to commit perjury for the sole purpose of pretending that Plaintiff's intentional failure to determine the statute of limitations for Defendant's case and the amount of time left to file Defendant's case while forcing the Plaintiff to honor an unconscionable contract the requires the Defendant to pay thousands of dollars for Plaintiff's failure to determine the statute of limitations for the Defendant's cause of action and how much time was left to file Plaintiff's case would ever represent “performing legal work” in any court of law.

  .....THIRTY SIXTH-Q: Defendant, is aware, due to plaintiff providing defendant with her outstanding disbursement balance during plaintiffs representation of her, that she has an outstanding balance due and owing for disbursements in the amount of Three Thousand Four Hundred Fifty Eight ($3,458.11) Dollars and Eleven Cents.

  .....THIRTY SIXTH-A: Defendant holds that in the mind of the Plaintiff, there was no breach of contract, only the opportunity to rip off a Gentile, and an African American who is one of Jehovah's Witnesses. In addition, Defendant holds that even in the best of circumstances, it was not Defendant who violated the contract, it was the Plaintiff. It was not the Defendant's responsibility to know enough of the law to determine the statute of limitation for her case. If there was any breach of contract at all, it was the Plaintiff, not the Defendant.

  .....Defendant denies Plaintiff's statement as irrelevant because, inter alia because the Plaintiff does not have standing to tell this Court that the Defendant is obliged to pay money to the Plaintiff because the Plaintiff padded his bill after refusing to determine the the statute of limitations for the causes of action Defendant's case, and then charging thousands of dollars in “fees” for refusing to determine whether Defendant's case was time-barred, something that would have been his fiduciary responsibility had he been dealing with the Defendant honestly. Even though the Plaintiff stole thousands of dollars under the guise of “performing legal work,” Plaintiff failed to do so when the Plaintiff incompetently and fraudulently failed to perform any work associated with determining the amount of time left for the statute of limitations. Defendant denies Plaintiff's statement as perjurious and lacking standing because the Plaintiff does not have the legal right to commit perjury for the sole purpose of pretending that Plaintiff's intentional failure to determine the statute of limitations for Defendant's case and the amount of time left to file Defendant's case while forcing the Plaintiff to honor an unconscionable contract the requires the Defendant to pay thousands of dollars for Plaintiff's failure to determine the statute of limitations for the Defendant's cause of action and how much time was left to file Plaintiff's case would ever represent “performing legal work” in any court of law. The Plaintiff does not have the legal right to commit perjury for the sole purpose of pretending that Plaintiff's intentional failure to determine the statute of limitations for Defendant's case and the amount of time left to file Defendant's case while forcing the Plaintiff to honor an unconscionable contract the requires the Defendant to pay thousands of dollars for Plaintiff's failure to determine the statute of limitations for the Defendant's cause of action and how much time was left to file Plaintiff's case would ever represent “performing legal work” in any court of law.

  .....WHEREFORE, plaintiff demand judgment against the Defendant as follows:

AS AND FOR DEFENDANT'S THIRD CAUSE OF ACTION, DEFENDANT HOLDS
THE AFFIRMATIVE DEFENSE THAT PLAINTIFF LACKS STANDING
 

In law, standing or locus standi is the term for the ability of a party to demonstrate to the court sufficient connection to and harm from the law or action challenged to support that party's participation in the case. Standing exists from one of three causes:

a) The party is directly subject to an adverse effect by the statute or action in question, and the harm suffered will continue unless the court grants relief in the form of damages or a finding that the law either does not apply to the party or that the law is void or can be nullified. This is called the "something to lose" doctrine, in which the party has standing because they directly will be harmed by the conditions for which they are asking the court for relief.

b) This is not the Plaintiff's situation. According to Frost Line Refrigeration, Inc. v. Gastwirth, Mirsky & Stein LLP, 806 NYS2d 436 (2006), the court held that the three-year statute of limitations period for the legal malpractice case started running from the date that the plaintiff-client signed a Consent to Change Attorney form with the defendant-client. By signing that form (which indicates that a client no longer wants the attorney to act as its counsel), the attorney-client relationship terminated and the clock began ticking on the potential legal malpractice claim. As the lawsuit was filed after the three-year period, the plaintiff-client was time-barred from commencing the legal malpractice case and it was dismissed. The Plaintiff was time-barred from commencing any actions in court.

c) In addition, any fault associated with employing willful blindness to pretend that it was not the Plaintiff's responsibility to carefully check the statute of limitations to determine how much time the Plaintiff had left, if any, to file Defendant's lawsuit is Plaintiff's own fault, not the Defendant's.

d) Plaintiff suffered no harm as a result of not being able to file an already time-barred case, no in not receiving money from the Defendant to litigate an already time-barred case, that again, the Plaintiff himself refused to check to determine if the Defendant's case was time-barred.

e) The Plaintiff perjured himself by pretending to have standing based on some harm involved that has some reasonable relation to their situation, and/or the continued existence of the harm may affect others who might not be able to ask a court for relief, such as the “chilling effects” associated with a S.L.A.P.P. action.

f) The party is granted automatic standing by act of law. Under some environmental laws in the United States, a party may sue someone causing pollution to certain waterways without a federal permit, even if the party suing is not harmed by the pollution being generated. The law allows them to receive a portion of any fines collected by the government from their violation of law. In some U.S. states, a person who believes a book, film or other work of art is obscene may sue in their own name to have the work banned directly without having to ask a District Attorney to do so.

g) This does not apply to the Plaintiff. There is no act of law associated with either the Plaintiff or the Defendant.

AS FOR DEFENDANT'S CAUSE OF ACTION, DEFENDANT HAS THE RIGHT TO RECOVER
DAMAGES BASED ON CRIMINAL AND CIVIL WRONGDOINGS
 

..... For all damages recoverable as a matter of law, due to defendant's deprivation of plaintiff rights pursuant to Quantum Meruit, including but not limited plaintiff's outstanding hourly fees in the amount of Sixty Four Thousand Nine Hundred Twenty Seven ($64,927.51) Dollars and Fifty-One Cents and for disbursements in the amount of Three Thousand Four Hundred Fifty Eight ($3,458.11) Dollars and Eleven Cents, and for all damages recoverable as a matter of law, including but not limited to:

..... ..... a) Summary judgment as against the Plaintiff based on CPLR b) §155.35, Grand larceny; 2) §175.35 Offering a false instrument for filing in the first degree; §210.15 Perjury; §135.65, Coercion in the first degree.; said crimes exacerbated as a result of Plaintiff's religiously-oriented hatred of African Americans; c) For all attorney fees and costs associated with this proceeding; d) One million, five hundred dollars ($1,000,000) for pain and suffering as a Gentile and as a African American; e) for pain and suffering inflicted by the Plaintiff based on Defendant's religion; f) pain and suffering as a victim of the crimes that Plaintiff inflicted on the Defendant; g) a public apology; h) For equitable relief; i) For such other and further relief as may be just and proper.

Dated: Islandia, New York
          
June 18, 2014 

TIME FOR SERVICE OF NOTICE AND AFFIDAVITS
 

A notice of motion and supporting affidavits shall be served at least eight days before the time at which the motion is noticed to be heard. Answering affidavits shall be served at least two days before such time. Answering affidavits and any notice of cross-motion, with supporting papers, if any, shall be served at least seven days before such time if a notice of motion served at least sixteen days before such time so demands; whereupon any reply or responding affidavits shall be served at least one day before such time.

CLIENT VERIFICATION


STATE OF NEW YORK )

COUNTY OF SUFFOLK ) ss:


         "P.G", being duly sworn, says that she is the Defendant appearing pro se in the within action; that Deponent has read the forgoing Verified Answer on the 17th day of June, 2014 and knows the contents thereof; that the same is true to Deponent's own knowledge, except as to those matters therein stated to be alleged upon information and belief, and as to those matters Deponent believes them to be true.

Dated: Islandia, New York
June 18, 2014


 

______________________
Sworn to before me this
18th day of June 2014
 

 

 

NOTARY PUBLIC

 
 
1CPLR 3211(a)(2) & (3) provide: A party may move for judgment dismissing one or more causes of action asserted against him on the ground that: (1) the court has not jurisdiction of the subject matter of the cause of action; (2) the party asserting the cause of action has not legal capacity to sue. In addition, CPLR 3211(e) provides that any objection or defense based on subdivision (3) must be raised in an answer or in a pre-answer motion or it is waived. There is no such waiver for subdivision (2). Wells Fargo Bank Minn. v Mastropaolo, 2007 NY Slip Op 04626, the Second Department held that it falls within subdivision (3), and thus must be raised in an answer or pre-answer motion or it is waived. Defendant respectfully reminds this Court that this is an answer, and as such, Defendant demands the dismissal of this case because it is Defendant's belief that the Plaintiff does not have standing to tell this Court that he suffered injuries because he wasn't paid to litigate a case that is time-barred, and impossible to adjudicate anywhere else as anything other than time-barred/statute of limitations has expired. Defendant will not allow this Court to bully her because she is black and one of Jehovah's Witnesses because it has aligned itself with the racist, greedy bigot. Defendant will report it to a law enforcement agency.
 
2Willful blindness (sometimes called ignorance of law, willful ignorance or contrived ignorance or Nelsonian knowledge) is a term used in law to describe a situation where an individual seeks to avoid civil or criminal liability for a wrongful act by intentionally putting himself in a position where he will be unaware of facts that would render him liable. For example, in a number of cases, persons transporting packages containing illegal drugs have asserted that they never asked what the contents of the packages were and so lacked the requisite intent to break the law. Such defenses have not succeeded, as courts have been quick to determine that the defendant should have known what was in the package and exercised criminal recklessness by failing to find out.[citation needed] A famous example of such a defense being denied occurred in In re Aimster Copyright Litigation, 34 F.3d 643 (7th Cir.2003), in which the defendants argued that the file-swapping technology was designed in such a way that they had no way of monitoring the content of swapped files. They suggested that their inability to monitor the activities of users meant that they could not be contributing to copyright infringement by the users. The court held that this was willful blindness on the defendant's part and would not constitute a defense to a claim of contributory infringement. Also see Global-Tech Appliances, Inc., et al. v. SEB S. A. 563 U. S. ____ (2011)