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NEW YORK STATE SUPREME COURT
COURT OF NEW
YORK
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Cheryl D. Uzamere
Plaintiff,
-against-
Daily News, LP and Scott Shifrel
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Index
No. 403205/2010
NOTICE
OF MOTION FOR LEAVE TO RENEW PLAINTIFF'S MOTIONS FOR DEFAULT
JUDGMENT, SUMMARY JUDGMENT, TO DISMISS DEFENDANT'S LATEST MOTION AND TO
HOLD IN ABEYANCE PENDING DEFENDANT'S AND ATTORNEY'S ARREST
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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.
BACKGROUND FACTS
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).
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).
NEW ASSERTIONS/ALLEGATIONS
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
J).
11) 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 Q).
22) 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.
23) 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;
25) 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 violate22
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.
Dated: New York, New York
February
10, 2011
*
To: Anne B. Carroll
Deputy Vice President and General Counsel
Daily News, LP
450 W. 33rd Street 1209 Loring Avenue
New York, NY 10001
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