Plaintiff Cheryl D. Uzamere, being duly sworn, states the
following under the penalties of perjury:
1) I assert that my Notice of Motion to Renew and accompanying Affidavit in Support are based upon
my recent discoveries: 1) that I was kidnapped, and that Defendant Scott Shifrel, by arbitrarily, maliciously, capriciously
and in a biased manner assisting court personnel under the care and control of the Honorable Michael Gerstein, the Honorable
Jeffrey S. Sunshine and the Honorable Arthur M. Schack to illegally broadcast nonpublic information regarding my lawsuits,
tacitly admitted to committing conspiracy in the second degree with regard to kidnapping in the first degree; 2) that there
is a continuing pattern of judicial misconduct and bias in favor or the Defendants with regard to their defamation of me as
an “anti-Semitic wacko”, and with regard to Defendants' intentional misrepresentation of my husband as “Godwin
Uzamere” even though two justices of a court of competent jurisdiction decided that Senator Ehigie E. Uzamere was my
husband; 3) that Defendants' attorney Anne B. Carroll violated 22 NYCRR §130-1.1 and the New York Lawyer's Code of Responsibility DR 1-102 with regard to asserting material facts that are not supported by law by intentionally invoking the legal doctrines res judicata
and collateral estoppel although I filed no prior lawsuit against the Defendants; 4) that Defendants' attorney Anne B. Carroll
committed fraud upon the court by violating New York State Penal Law Section 105.05, conspiracy in the fifth degree and New York State Penal Law 115.00, criminal facilitation in the fourth degree by holding out that the process was properly mailed when a) the first USPS delivery notice/reminder/receipt dated January
24, 2011 bore 07102, a Newark, New Jersey zip code, b) the U.S. Postal Service's online Track and Confirm web page does not
recognize Article No. 7009 1080 0001 3780 9641 as having been mailed, and c) I received the second USPS delivery notice/reminder/receipt
bearing the zip code 10458 that was used to reference the first USPS delivery notice/reminder/receipt that bore the zip code
07102; 5) that anti-Semitism is a violation of halachic/Jewish religious law, not secular law, so that Defendants' libelous
accusation that I am an anti-Semite is a violation of my New York State Constitutional right to freedom of worship; 6) that
Defendants violated New York State Civil Rights Law, Article Five, Section Fifty, Right of Privacy by using, for the purposes of trade, my name, my picture, nonpublic information regarding my mental illness, nonpublic information
regarding the hospital that treated me; nonpublic information regarding the symptoms of my mental illness; nonpublic information
with regard to Defendants' defamatory, derogatory portrayal of me as a “wacko”; non-public information regarding
their fraudulent allegations regarding my being “anti-Semitic”; nonpublic information regarding my marriage and
divorce, including nonpublic information regarding my ex-husband's criminal use of his fraudulent counter-affidavit of any
living person without having first obtained the written consent me or my ex-husband; 7) that Defendant Daily News' registered
agent, the Prentice-Hall Corporation System Inc., a company located and incorporated in the State of Delaware, accepts service
of process by mail; 7) that according to the Delaware Supreme Court's attorney registration department (302-739-4155), Defendants'
attorney Anne B. Carroll is not licensed to practice law in Delaware, so that she is not in a legal position to question Defendant
Daily News' acceptance of process by certified mail in Delaware; 8) that I filed a petition with the New York State Commission
on Judicial Conduct against the Honorable Michael Gerstein, the Honorable Jeffrey S. Sunshine and the Honorable Arthur M.
Schack for violating 22 NYCRR §100.3(B)(8)(11) by making or causing to be made public comments regarding my lawsuits and for illegally disclosing or causing to be disclosed
my nonpublic information to the Defendants that they acquired during their adjudication of my lawsuits Docket No. 2009KN087992,
Index No. 26332/2007 and Index No. 18012/2009; 9) that I filed a petition with the New York State Grievance Committee against
my criminal attorney Tim Gumkowski for illegally disclosing symptoms of my mental illness to the Defendants based on my belief
that only he and those court personnel who were present while I was in Kings County Criminal Court's holding area could have
known; and that if this Court grants leave for me to present the aforementioned new facts, this Court's decision will greatly
differ from any decision that this Court would have rendered had it based its decision on Defendants' fraudulent statements
as presented in the motions that the Defendants offered the Honorable Anthony L. Parga, Nassau County Supreme Court.
2) I assert
that my failure to present the aforementioned facts is based on various events that took place after Defendants defamed me
and publicly disclosed my nonpublic information that was originally acquired in a judicial capacity but was thereafter illegally
acquired by the Defendants and used for purposes unrelated to the duties of the judges who adjudicated
my lawsuits; and that Defendants and their attorney Anne B. Carroll committed crimes that I did not know until now were crimes
at the time that Defendants committed them.
3) While it
is my intention to obey Civil Practice Law and Rules §2221(3) with regard to its requirement to present new information
to this honorable Court, I respectfully request this Court's merciful indulgence to allow me to invoke the continuing violations
doctrine by establishing a link between Defendant's current criminal course of conduct and the Defendants' present criminal
course of conduct by referencing the following past events:
a) I assert that my ex-husband's attorney, Osato Eugene Uzamere presented a fraudulent affirmation
and counter-affidavit that falsely held that I am married to “Godwin Uzamere” (see Exhibit A);
b) I assert
that I received correspondence from the U.S. Citizenship and Immigration Services that recognizes that Senator Ehigie Edobor
Uzamere was my husband (see Exhibit B);
c) I assert that the U.S. Citizenship and Immigration Service (formerly U.S. Department of Justice
Immigration and Naturalization Service) revoked my ex-husband's fraudulently obtained IR2 benefits that my ex-husband received
under his proper name and birthday as Ehigie E. Uzamere, date of birth: December 31, 1960, unmarried, under 21 years of age,
because he applied for IR1 benefits under the fictitious name and birthday “Godwin Uzamere”, date of birth: June
1, 1955, married to me and over 21 years of age (see Exhibit C);
d) I assert that the Honorable Jeffrey S. Sunshine and the Honorable Matthew D'Emic adjudged that
Senator Ehigie Edobor Uzamere was my husband (see Exhibit D and Exhibit E);
e) I assert
that on or around October 28, 2009, attorneys Allen E. Kaye, Harvey Shapiro and Jack Gladstein submitted affirmations to the
Kings County Supreme Court that fraudulently hold that I am married to “Godwin Uzamere” (see Exhibit
f) I assert that on November 3, 2009, the Honorable Michael Gerstein declared that I was mentally
unfit, and at his behest, I was kidnapped and taken, first to to Elmhurst Hospital, and then to Rose M. Singer Center (Rikers
Island), where I was held for thirty-three (33) days, and then transferred to Kingsboro Psychiatric Center, where I was held
for parts of five (5) months (see Exhibit G).
g) I assert that eight (8) days after the aforementioned attorneys submitted their fraudulent affirmations
to the Kings County Supreme Court, that on November 5, 2009, Defendants published a newspaper article fraudulently holding
that “Godwin Uzamere” is my husband, that I am an “anti-Semitic wacko”, and that I am mentally unfit
(see Exhibit H).
4) I assert
that on November 30, 2009, less than a month after the Daily News libeled me an “anti-Semitic wacko”, I was discharged
from receiving FEGS, Inc.'s government-funded services for committing the Jewish religious crime of anti-Semitism based on
Dr. Forster's statement “given client's history of making anti-Semitic remarks, treatment at an FEGS facility is inappropriate
for her” (see Exhibit I).
5) I assert that in February 2010,
during my last week of my first hospitalization with Kingsboro Psychiatric Center as an inpatient, my social worker, Laurie
Velcimé informed me that except for Brookdale Medical Center's outpatient psychiatric department, all the not-for-profit
outpatient mental health rehabilitative service agencies with which Ms. Velcimé filed a request for services on my
behalf turned down her request for me to receive outpatient services.
6) I further assert that while I was an inpatient with Kingsboro Psychiatric Center, I informed its
staff that based on my lawsuit against the three (3) Jewish attorneys who facilitated my ex-husband's commission of immigration
fraud and identity fraud, and based on my fear of backlash from members of the Jewish community, I would only accept therapy
from therapists who were not Jewish.
7) I assert that during my last week of my second hospitalization with Kingsboro Psychiatric Center
as an inpatient, my social worker, Laurie Velcimé informed me that nearly all the not-for-profit outpatient mental
health agencies with which Ms. Velcimé filed a request on my behalf turned down Ms. Velcimé request to provide
me with outpatient mental health services.
8) I assert that the not-for-profit outpatient mental health rehabilitative service agencies that
social worker Laurie Velcimé contacted include, but are not limited to: 1) Interfaith Medical Center CDT; 2) Saint
Vincent Catholic Medical Center CDT and 3) New York Psychotherapy and Counseling Center.
9) I assert that during my second
visit as an inpatient with Kingsboro Psychiatric Center, I informed its staff that based on my lawsuit against three (3) Jewish
attorneys who facilitated my ex-husband's commission of immigration fraud and identity fraud, and based on my fear of backlash
from members of the Jewish community, I would only accept therapy from therapists who were not Jewish.
10) I assert that Kingsboro Psychiatric
Center's Ward 12 staff honored my request by providing me with a psychiatric treatment team that contained no Jews (see Exhibit
I assert that on August 3, 2010, while at Brookdale Pharmacy, my wallet was stolen by a customer, and that I called the police.
When the police came, they viewed the customer who had stolen my wallet on the pharmacy's camera; however, on the word of
the pharmacy's owner, who is Jewish, the police refused to take my complaint. The lawsuit I filed against the City of New
York and the New York City Police Department that was first filed with the New York City Comptroller's Office as Claim No.
2010PI028483 is attached as Exhibit K.
12) I assert that in September 2010, Kingsboro Psychiatric Center's Intensive Management Program's caseworker Bridget Davis
arranged for me to meet with Flatlands Guidance Center and Open Door Psychosocial Club; and that I was made to believe that
Kingsboro Psychiatric Center would continue to accede to my request to ensure that the only individuals who would provide
me with therapy were non-Jews who were culturally sensitive to my needs as a crime victim.
13) I assert that on three (3) occasions,
I was misled into divulging sensitive information about my legal situation to Catholic Charities' employees Monica “Doe”,
Dr. Sterling and Dr. Partyka, all of whom attempted to hide the fact that they are Jewish from me.
14) I assert that while I was an outpatient
with after Flatlands Guidance Center, an unidentified Jewish male employee informed fellow employees that I am an anti-Semite;
and that after weeks of issues with transference, and continued fear and sadness at being identified
as anti-Semitic, I left.
15) I assert that in November 2010, and upon receipt of FEGS's discharge summary that libeled me as
an anti-Semite, I immediately commenced preparing her lawsuit against FEGS. My lawsuit against FEGS, Index No. 115748/2011
is attached as Exhibit L.
16) I assert that I filed a lawsuit against the State with the New York State Court of Claims on December
6, 2010 with regard to what I believe is New York State's condonation of FEGS' discharging me for religious reasons. My lawsuit
against the State of New York is attached as Exhibit M.
17) I assert that after losing my lawsuit Index No. 18012-2009 in which the Honorable Arthur M. Schack
accepted attorneys Allen E. Kaye's, Harvey Shapiro's and Jack Gladstein's affirmations that fraudulently hold that “Godwin
Uzamere” is my husband, I filed my appeal to what I believe to be Justice Schack's biased decision. My brief is attached
as Exhibit N.
18) I assert that I filed a complaint with the New York State Commission on Judicial Conduct with
regard the Honorable Michael Gerstein's, the Honorable Jeffrey S. Sunshine's and the Honorable Arthur M. Schack's violation
of 22 NYCRR §100.3(B)(8)(11)'s statutes prohibiting judges and court personnel from publicly commenting on pending and impending cases, and from
disclosing nonpublic information that the aforementioned judges obtained in their capacity as judges. The petition is attached
as Exhibit O.
19) I assert that on January 24, 2011 and January 26, 2011 I received certified mail receipts from
the U.S. Postal Service, the identity of the sender unknown; one that appeared to have been illegally mailed from zip code
07102, Newark New Jersey, but which article number 7009 1080 0001 3780 9641 does not register as having ever been mailed at
the U.S. Postal Service's Track and Confirm web page; that I received a second USPS delivery notice/reminder/receipt bearing
the zip code 10458 but not bearing an article number; and that according to an employee with the U.S. Postal Service's New
Lots' branch, the delivery notice/reminder/receipt bearing the zip code 10458 referenced the delivery notice/reminder/receipt
that bore the article number 7009 1080 0001 3780 9641 and the zip code 07102; (see Exhibit P).
SPECIFIC REASONS FOR RENEWAL
20) That I submit the within Affidavit to renew my motions for default judgment and summary judgment
based on Defendant Scott Shifrel's commission of the following:
21) I assert that Defendant Daily News' registered agent, the Prentice-Hall Corporation System Inc.,
a company located and incorporated in the State of Delaware, accepts service of process by mail, and that said corporation
can be contacted at (302) 636-5400 to confirm my assertion; and that according to the Delaware Supreme Court's attorney registration
department (302-739-4155), Defendants' attorney Anne B. Carroll is not licensed to practice law in Delaware, so that she is
not in a legal position to challenge Defendant Daily News' acceptance of process by certified mail in Delaware (see Exhibit
I assert that based on the exact definition of conspiracy in the second degree, Defendant the Daily News, by and through Defendant
Scott Shifrel, with intent that the crimes of coercion in the first degree and kidnapping in the first degree be performed,
agreed with one or more persons to engage in or cause the performance of such conduct; and that I describe the Defendants'
orchestration of my “arrest” as a kidnapping because Defendant Scott Shifrel overtly admitted – in paragraph
seven (7), line three (3) of Defendants' newspaper to illegally obtaining information about my lawsuits from “one courthouse
source”, in violation of 22 NYCRR §100.3(B)(8)(11) that prohibits judges and court personnel from commenting on pending and impending cases, and from publicly disclosing nonpublic
information that was acquired in a judicial capacity; that the reasons for which Defendant Daily News, by and through Scott
Shifrel, judges Michael Gerstein, Jeffrey S. Sunshine, Arthur M. Schack and attorneys Allen E. Kaye, Harvey Shapiro and Jack
Gladstein orchestrated my arrested are not only biased, but are untrue, and therefore tainted; and that since the illegally
disclosed information with regard to my cases Docket No. 2009KN087992, Index 26332/2007 and Index 18012/2009 is tainted, and
therefore not usable in an unbiased court of law, the arrest, being based on the tainted allegations are “fruit of the
poison tree”, so that my arrest was in actuality an act of coercion in the first degree and an act of kidnapping in
the first degree.
I assert that Defendants committed criminal facilitation in the fourth degree with regard to Defendants assisting Senator
Ehigie Edobor Uzamere, Osato Uzamere, Allen E. Kaye, Harvey Shapiro and Jack Gladstein to commit New York State Penal Law
Section 210.15, perjury in the first degree by holding out that my husband is “Godwin Uzamere” even though a court
of competent jurisdiction decided that Senator Ehigie Edobor Uzamere was my husband.
24) I assert that Defendants committed criminal facilitation in the fourth degree regarding Defendants
assist Senator Ehigie Edobor Uzamere, Allen E. Kaye, Harvey Shapiro and Jack Gladstein to commit New York State Penal Law Section 135.65, coercion in the first degree;
I assert that Defendants committed criminal facilitation in the fourth degree with regard to Defendants' assisting Judge Jeffrey
S. Sunshine's and Judge Arthur M. Schack's to publicly hold out as true and correct the fraudulent counter-affidavit and affirmations
of my ex-husband Senator Ehigie Edobor Uzamere and his attorneys Allen E. Kaye, Harvey Shapiro and Jack Gladstein with regard
to my ex-husband's identity; and that Defendants assisted Judge Michael Gerstein, Justice Jeffrey S. Sunshine, Justice Arthur
M. Schack, and attorneys Allen E. Kaye, Harvey Shapiro and Jack Gladstein by illegally disclosing other nonpublic information
associated with my criminal action Docket No. 2009KN087992, my action for divorce Index No. 26332-2007 and my action for fraud
Index No. 18012-2009 for purpose unrelated to judicial duties.
26) That I submit the within Affidavit to renew my motions based on attorney Anne B. Carroll's violation
of 22 NYCRR §130-1.1 with regard to her fraudulent request to this Court to invoke res judicata regarding lawsuits that I filed with the
U.S. District Courts for the Eastern and Southern Districts that were dismissed due to lack of subject matter jurisdiction,
as said dismissals were based on the courts' belief that my lawsuits were really attempts to relitigate my divorce and that
the federal courts' dismissals were based on the Younger abstention that prohibits federal courts from adjudicating matters
that are relegated to the states; and that in attorney Anne B. Carroll's motion, she knowingly, fraudulently and maliciously
attempts to present her legal strategy that relies on her mistaken, arrogant belief that I will not figure out that res judicata
does not apply to the present action because the Defendants were never parties to any previous action that I filed in any
court on the planet Earth.
27) I allege that Anne B. Carroll arranged for the “mailing” of Article 7009 1080 0001
3780 9641 that on face value, appears to have been improperly mailed from 07102, Newark, New Jersey, but which article number
is not recognized by the U.S. Postal Service's online Track and Confirm web page; and that further to this, that Defendants'
attorney Anne B. Carroll has attempted previous fraudulent stunts that are designed to: 1) trick or confuse me; 2) circumvent
New York State Law regarding proper service of process; 3) circumvent the New York Lawyer's Code of Professional Conduct with
regard to statutes that prohibit attorneys from engaging in fraud, deceit and misrepresentation; 4) invoke this Court's anti-black
racism and anti-mentally ill bigotry so as to embolden this Court trier of fact to violate 22 NYCRR §100.3 with regard to judicial conduct.
28) I assert that because of the Defendants' illegal disclosure of my lawsuits and disclosure of nonpublic
information that was acquired in a judicial capacity, I was forced to file a petition against the Honorable Michael Gerstein,
the Honorable Jeffrey S. Sunshine and the Honorable Arthur M. Schack with the New York State Commission on Judicial Conduct
because the aforesaid judges' illegally commented on, or allowed court personnel to comment on my lawsuits Docket No. 2009KN087992,
Index No. 26332/2007 and Index No. 18012/2009, and because the aforesaid judges illegally disclosed or allowed court personnel
to illegally disclose my nonpublic information to the Defendants in violation of 22 NYCRR §100.3(B)(8)(11) , that says 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 that “a judge shall not disclose or use, for any purpose
unrelated to judicial duties, nonpublic information acquired in a judicial capacity.”
29) I assert that Defendants' attorney
Anne B. Carroll's act of deceit with regard to the arrogance with which she improperly served process of Article No. 7009
1080 0001 3780 9641 is no different than the arrogance with which she attempted previous stunts on behalf of the Defendants:
1) her first attempt to trick me into believing that my lawsuit against the Defendants was transferred to the Kings County
Supreme Court by arranging with the Honorable Jeffrey S. Sunshine and Justice Sunshine's wife, the Honorable Nancy Teigtmeier
of the Kings County Clerk's Office to mail me a document entitled “Kings County Clerk, Equity Window 9” that feigned
the color of authority in order to trick me me to go to the Kings County Clerk's Office to add a missing index number when
my lawsuit was still in Nassau County in order for Justice Sunshine to gain access to my lawsuit against the Defendants and
summarily dismiss it; and, 2) attempted to trick me into believing that Nassau County Supreme Court and the Nassau County
Clerk's Office and the legal right to physically remove all the motion papers that I properly served on them, when, in fact
they violated CPLR §2001, §2101(f) and §2102(c) , which allow for errors that do not prejudice the opposing party, and which the clerk of court is required to accept
(see Exhibit R).
30) I assert that attorney Anne B. Carroll again violated 22 NYCRR §130-1.1 by the New
York State Constitution's freedom to worship clause it its reference to me as “anti-Semitic.” Anti-Semitism is
a violation of halachic/Jewish religious law. According to the Exhibit Daat Emet, Gentiles in Halacha, “the prohibition
to hate only applies to Jews. One may hate a gentile”; that “one make take revenge against or hold a grudge towards
Gentiles; likewise the commandment “love your neighbor” applies only to Jews, not to Gentiles”; that “anyone
who hates a Jew in his heart transgresses a negative commandment”; that also, anyone who hold a grudge against a Jew
transgresses a negative commandment; and that “it is a commandment for each and every person to love each and every
Jew as he loves himself.” Such a hateful religious tenet, that requires all non-Jews to love every single Jew, even
if Jews hate non-Jews, is the very antithesis of justice. This tenet fosters racism as it requires non-Jews to love Jews –
simply because they are Jews, instead of expressing one's like or dislike of a person based on, as Martin Luther King advocated,
“the “content of their character.” Attorney Anne B. Carroll's attempt to hide the Defendants' obvious criminal
conduct by demonizing my constitutionally-protected right to privacy (including private thought); my right to freedom of thought
and my right to freely express my hatred of attorneys Allen E. Kaye, Harvey Shapiro and Jack Gladstein for violating my rights
and my family's rights – not because they are Jews, not because they are Jews, but because they are wicked.
31) I assert
that attorney Anne B. Carroll's violated 22 NYCRR §130-1.1 by frivolously holding herself out as having psychic abilities. According to the Israel Central Bureau of Statistics,
as of 2010, there are 13,421,000 Jews worldwide. Is Anne Carroll prepared to present this Court with proof of her belief that
she has psychic abilities, is able to tell that I hate all 13,421,000 Jews on the planet Earth and that I have never befriended
even one person who is Jewish? I answer in the negative based on 1) Ms. Carroll's inability to form a legal strategy that
would thwart my ability to discover her fraudulent attempt to require this Court's use of res judicata for my federal lawsuits
in which the Defendants were not parties to the action. If Ms. Carroll's psychic prowess was useless in helping her form a
legal strategy based on what I was thinking when she prepared her cross-motions, it stands to reason that this Court must
not view her psychic skills as sufficiently strong enough to tell what I feel about all 13,421,000 Jews on the
planet Earth, nor does Ms. Carroll possess the psychic ability to tell if I had Jewish friends at the time that the Defendants
published the libelous newspaper article about me.
32) That based on Defendant Scott Shifrel's flagrant commission of various crimes against me, and
based on what I believe to be logical, I allege that Defendant Scott Shifrel accepted bribes from my ex-husband, Senator Ehigie
Edobor Uzamere, to use the Defendants to criminally facilitate Senator Uzamere's commission of identity fraud and perjury
in the same manner that he and attorneys Allen E. Kaye, Harvey Shapiro and Jack Gladstein criminally facilitated the use of
the fictitious name “Godwin Uzamere” to hide his identity and his commission of immigration fraud and identity
fraud from the Nigerian public, where he sits as a senator, and where he is preparing to run as senator again. While my allegation
with regard to Defendant Scott Shifrel's acceptance of bribes is just an allegation, the level of wickedness associated with
Defendants' crimes should, by the preponderance of the evidence show this Court this the Defendants did not commit the aforementioned
crimes for fun, or for free. They perpetrated the aforementioned crimes for financial gain, and used their false accusations
as published in Defendants' newspaper as a rationalization to gorge themselves on my ex-husband's money. I strongly allege
that what motivated the Defendants is greed.
33) I respectfully remind this Court that based on various instances of judicial corruption (including
what I allege to be the acceptance of bribes; judges' use of the Defendants to illegally disclose my nonpublic information
that was obtained during judges' adjudication of my lawsuits in violate of 22 NYCRR §100.3(B)(8)(11) ), religiously-oriented racism and discrimination of me based on my government-protected status as mentally disabled
as rationalizations to assuage their guilty consciences for having accepted bribes from my ex-husband while my family and
I suffer in poverty; I have no other choice but to forward this lawsuit to Robert S. Mueller, Director of the Federal Bureau
of Investigation and to President Obama, as I am terrified that I my complaint will be forwarded to another corrupt judge.
34) I respectfully
assert before this Court that based on my limited knowledge of the law, in situations where fact patterns straddle both criminal
law and civil law, it is civil cases that are ancillary; and pending Defendant Scott Shifrel's arrest and possible conviction,
I respectfully pray that this Court facilitates Defendant Scott Shifrel's and Anne B. Carroll arrest for conspiracy/criminal
facilitation (to commit perjury); conspiracy/criminal facilitation (of coercion) and conspiracy/criminal facilitation (of
kidnapping). While I am not an attorney, my requests to the honorable Court are based on the laws I have already read (and
quoted in my motion) and my ability to find relevant laws that I do not presently know on the internet. Lastly, I apologize
for presenting this inartfully drawn motion to this honorable Court.
WHEREFORE, Plaintiff Cheryl D. Uzamere respectfully prays that this Court do the following: 1) that if Defendants
insist on holding out that I was properly served, that this Court dismisses Defendants' motion as improperly served; 2) to
find that Defendant Daily News was properly served; 3) to facilitate the arrest of Defendant Scott Shifrel and Anne B. Carroll
based on their conspiracy/criminal facilitation of perjury in the first degree, coercion in the first degree and kidnapping
in the first degree; 4) sanction Defendant's attorney Anne B. Carroll for violation of the New York Lawyer's Code of Responsibility
Responsibility with regard to her commission of fraud and her violation of 22 NYCRR §130-1.1 that allows the court, as appropriate, to impose financial sanctions against an attorney for asserting material factual
statements that are false; 5) to grant leave for Plaintiff to correctly effect service of process on Defendant Scott Shifrel
pursuant to CPLR §308; 6) to grant leave for Plaintiff to proceed as a poor person to refile her papers against Scott Shifrel; 7) to substitute
service of process on Defendant Scott Shifrel to prevent him from absenting himself from receipt of process, and if Defendant
Scott Shifrel objects to substituted service, to require him to pay for personal service; 8) to find Defendant Daily News
in default for failure to interpose an answer; 9) for this honorable Court to require Defendants to make a full public retraction
of their defamatory, criminal and cruel statements, and to render judgment against Defendant Daily News in the sum of $10,000.000.00.