|
Cheryl
D. Uzamere
Plaintiff
- against
United States
of America
-and-
The Honorable
Barack H. Obama, Individually and in His Official Capacity as President of
the United States of America; the Honorable Judge John D. Bates,
Individually and in His Capacity as Director of the Administrative Office
of the U.S. Courts; the Honorable William E. Smith, Individually and in His
Official Capacity as Judge for the Federal District Court, District of
Rhode Island; the Honorable William E. Smith, Individually and in His
Official Capacity as Judge for the Federal District Court, District of
Rhode Island; the Honorable Patricia A. Sullivan, Individually and in His
Official Capacity as Magistrate Judge for the Federal District Court,
District of Rhode Island; the Honorable Keith B. Alexander, Individually
and in His Official Capacity as Director of the National Security Agency;
Rajesh De, Individually, and in His Official Capacity as General Counsel
for the National Security Agency; National Security Agency; Andrew
Weissman, Individually and in His Official Capacity as General Counsel for
the Federal Bureau of Investigation; James X. Dempsey, Individually and in
His Official Capacity as Member, Privacy and Civil Liberties Oversight
Board; Elisebeth Collins Cook, Individually and
in Her Official Capacity as Member, Privacy and Civil Liberties Oversight
Board; David Medine, Individually and in His
Official Capacity as Chairman, Privacy and Civil Liberties Oversight Board;
Rachel L. Brand, Individually and in His Official Capacity as Member,
Privacy and Civil Liberties Oversight Board, Patricia M. Wald, Individually
and in His Official Capacity as Member, Privacy and Civil Liberties
Oversight Board, Nicholas G. Garaufis, Individually and in His Official
Capacity as Judge, U.S. District Court for the Eastern District of New
York; Dennis Jacobs, Individually and in His Official Capacity as Chief
Judge, U.S. Court of Appeals for the Second Circuit; Jon O. Newman,
Individually and in His Official Capacity as Judge for the U.S. Court of
Appeals for the Second Circuit; Amalya L. Kearse,
Individually and in Her Official Capacity as Judge for the U.S. Court of
Appeals for the Second Circuit; Ralph K. Winter, Individually and in His
Official Capacity as Judge for the U.S. Court of Appeals for the Second
Circuit; John M. Walker, Jr., Individually and in His Official Capacity as
Judge for the U.S. Court of Appeals for the Second Circuit; Joseph M.
McLaughlin, Individually in His Official Capacity as Judge for the U.S.
Court of Appeals for the Second Circuit; Pierre N. Leval,
Individually in His Official Capacity as Judge for the U.S. Court of
Appeals for the Second Circuit; Guido Calabresi,
Individually and in His Official Capacity as Judge for the U.S. Court of
Appeals for the Second Circuit; José A. Cabranes, Individually and in His
Official Capacity as Judge for the U.S. Court of Appeals for the Second
Circuit; Chester J. Straub, Individually and in His Official Capacity as
Judge for the U.S. Court of Appeals for the Second Circuit; Rosemary S.
Pooler, Individually and in Her Official Capacity as Judge for the U.S.
Court of Appeals for the Second Circuit; Robert D. Sack, Individually and
in His Official Capacity as Judge for the U.S. Court of Appeals for the
Second Circuit; Robert A. Katzmann, Individually
and in His Official Capacity as Judge for the U.S. Court of Appeals for the
Second Circuit; Barrington D. Parker, Individually and in His Official
Capacity as Judge for the U.S. Court of Appeals for the Second Circuit;
Reena Raggi, Individually and in Her Official Capacity as Judge for the
U.S. Court of Appeals for the Second Circuit; Richard C. Wesley,
Individually and in His Official Capacity as Judge for the U.S. Court of
Appeals for the Second Circuit; Peter W. Hall, Individually and in His
Official Capacity as Judge for the U.S. Court of Appeals for the Second
Circuit; Debra Ann Livingston, Individually and in Her Official Capacity as
Judge for the U.S. Court of Appeals for the Second Circuit; Gerard E.
Lynch, Individually and in His Official Capacity as Judge for the U.S.
Court of Appeals for the Second Circuit; Denny Chin, Individually and in
His Official Capacity as Judge for the U.S. Court of Appeals for the Second
Circuit; Raymond J. Lohier, Jr., Individually and
in His Official Capacity as Judge for the U.S. Court of Appeals for the
Second Circuit; Susan L. Carney, Individually and in Her Official Capacity
as Judge for the U.S. Court of Appeals for the Second Circuit; Christopher
F. Droney, Individually and in His Official
Capacity as Judge for the U.S. Court of Appeals for the Second Circuit;
Carol Bagley Amon, Individually and in Her Official Capacity as Chief Judge
for the U.S. District Court for the Eastern District of New York; Frederic
Block, Individually and in His Official Capacity as Judge for the U.S.
District Court for the Eastern District of New York; Joseph F. Bianco,
Individually and in His Official Capacity as Judge for the U.S. District
Court for the Eastern District of New York; Margo K. Brodie, Individually
and in Her Official Capacity as Judge for the U.S. District Court for the
Eastern District of New York; Brian M. Cogan, Individually and in His
Official Capacity as Judge for the U.S. District Court for the Eastern
District of New York; Raymond J. Dearie, Individually and in His Official
Capacity as Judge for the U.S. District Court for the Eastern District of
New York; Sandra J. Feuerstein, Individually and in His Official Capacity
as Judge for the U.S. District Court for the Eastern District of New York;
Nina Gershon, Individually and in Her Official Capacity as Judge for the
U.S. Court for the Eastern District of New York; I. Leo Glasser, Individually
and in His Official Capacity as Judge for the U.S. District Court for the
Eastern District of New York; John Gleeson, Individually and in His
Official Capacity as Judge for the U.S. District Court for the Eastern
District of New York; Denis R. Hurley, Individually and in His Official
Capacity as Judge for the U.S. District Court for the Eastern District of
New York; Dora L. Irizarry, Individually and in Her Official Capacity as
Judge for the U.S. District Court for the Eastern District of New York; Sterling
Johnson, Jr., Individually and in His Official Capacity as Judge for the
U.S. District Court for the Eastern District of New York; Edward R. Korman,
Individually and in His Official Capacity as Judge for the U.S. District
Court for the Eastern District of New York; Kiyo A. Matsumoto, Individually
and in His Official Capacity as Judge for the U.S. District Court for the
Eastern District of New York; William F. Kuntz, Individually and in His
Official Capacity as Judge for the U.S. District Court for the Eastern
District of New York; Roslynn R. Mauskopf, Individually and in His Official
Capacity as Judge for the U.S. District Court for the Eastern District of
New York; Allyne R. Ross, Individually and in His Official Capacity as
Judge for the U.S. District Court for the Eastern District of New York;
Thomas C. Platt, Individually and in His Official Capacity as Judge for the
U.S. District Court for the Eastern District of New York; Joanna Seybert,
Individually and in Her Official Capacity as Judge for the U.S. District
Court for the Eastern District of New York; Arthur D. Spatt, Individually
and in His Official Capacity as Judge for the U.S. District Court for the
Eastern District of New York; Sandra L. Townes, Individually and in His
Official Capacity as Judge for the U.S. District Court for the Eastern
District of New York; Eric N. Vitaliano, Individually and in His Official
Capacity as Judge for the U.S. District Court for the Eastern District of
New York; Jack B. Weinstein, Individually and in His Official Capacity as
Judge for the U.S. District Court for the Eastern District of New York;
Leonard D. Wexler, Individually and in His Official Capacity as Judge for
the U.S. District Court for the Eastern District of New York; Ronnie
Abrams, Individually and in His Official Capacity as Judge for the U.S.
District Court for the Southern District of New York; Harold Baer,
Individually and Individually and in His Official Capacity as Judge for the
U.S. District Court for the Southern District of New York; Deborah A.
Batts, Individually and in Her Southern District of New York; Richard M.
Berman, Individually and in His Official Capacity as Judge for the U.S.
District Court for the Southern District of New York; Vincent L. Briccetti, Individually and in His Official Capacity as
Judge for the U.S. District Court for the Southern District of New York;
Naomi Reice Buchwald, Individually and in Her
Official Capacity as Judge for the U.S. District Court for the Southern
District of New York; Andrew L. Carter, Jr., Individually and in His
Official Capacity as Judge for the U.S. District Court for the Southern
District of New York; P. Kevin Castel, Individually and in His Official
Capacity as Judge for the U.S. District Court for the Southern District of
New York; Miriam Goldman Cedarbaum, Individually
and in Her Official Capacity as Judge for the U.S. District Court for the
Southern District of New York; Denise L. Cote, Individually and in Her
Official Capacity as Judge for the U.S. District Court for the Southern
District of New York; Paul A. Crotty, Individually and in His Official
Capacity as Judge for the U.S. District Court for the Southern District of
New York; George B. Daniels, Individually and in His Official Capacity as
Judge for the U.S. District Court for the Southern District of New York;
Kevin T. Duffy, Individually and in His Official Capacity as Judge for the
U.S. District Court for the Southern District of New York; Paul A. Engelmayer, Individually and in His Official Capacity
as Judge for the U.S. District Court for the Southern District of New York;
Katherine B Forrest, Individually and in Her Official Capacity as Judge for
the U.S. District Court for the Southern District of New York; Jesse M.
Furman, Individually and in His Official Capacity as Judge for the U.S.
District Court for the Southern District of New York; Paul G. Gardephe, Individually and in His Official Capacity as
Judge for the U.S. District Court for the Southern District of New York;
Thomas P. Griesa, Individually and in His
Official Capacity as Judge for the U.S. District Court for the Southern
District of New York; Charles S. Haight, Individually and in His Official
Capacity as Judge for the U.S. District Court for the Southern District of
New York; Alvin K. Hellerstein, Individually and
in His Official Capacity as Judge for the U.S. District Court for the
Southern District of New York; Lewis A. Kaplan, Individually and in His
Official Capacity as Judge for the U.S. District Court for the Southern
District of New York; Kenneth M. Karas, Individually
and in His Official Capacity as Judge for the U.S. District Court for the
Southern District of New York; John F Keenan, Individually and in His
Official Capacity as Judge for the U.S. District Court for the Southern
District of New York; John G. Koeltl, Individually and in His Official
Capacity as Judge for the U.S. District Court for the Southern District of
New York; Victor Marrero, Individually and in His Official Capacity as
Judge for the U.S. District Court for the Southern District of New York;
Colleen McMahon, Individually and in Her Official Capacity as Judge for the
U.S. District Court for the Southern District of New York; Alison J.
Nathan, Individually and in His Official Capacity as Judge for the U.S.
District Court for the Southern District of New York; J. Paul Oetken, Individually and in His Official Capacity as
Judge for the U.S. District Court for the Southern District of New York;
Richard Owen, Individually and in His Official Capacity as Judge for the
U.S. District Court for the Southern District of New York; Robert P.
Patterson, Individually and in His Official Capacity as Judge for the U.S.
District Court for the Southern District of New York; William H. Pauley,
Individually and in His Official Capacity as Judge for the U.S. District
Court for the Southern District of New York; Loretta A. Preska,
Individually and in Her Official Capacity as Chief Judge for the U.S.
District Court for the Southern District of New York; Jed S. Rakoff, Individually and in His Official Capacity as
Judge for the U.S. District Court for the Southern District of New York;
Edgardo Ramos, Individually and in His Official Capacity as Judge for the
U.S. District Court for the Southern District of New York; Leonard B Sand,
Individually and in His Official Capacity as Judge for the U.S. District
Court for the Southern District of New York; Shira A. Scheindlin,
Individually and in His Official Capacity as Judge for the U.S. District
Court for the Southern District of New York; Cathy Seibel, Individually and
in His Official Capacity as Judge for the U.S. District Court for the
Southern District of New York; Louis L. Stanton, Individually and in His
Official Capacity as Judge for the U.S. District Court for the Southern
District of New York; Sidney H. Stein, Individually and in His Official
Capacity as Judge for the U.S. District Court for the Southern District of
New York; Richard J Sullivan, Individually and in His Official Capacity as
Judge for the U.S. District Court for the Southern District of New York;
Laura Taylor Swain, Individually and in His Official Capacity as Judge for
the U.S. District Court for the Southern District of New York; Robert W.
Sweet, Individually and in His Official Capacity as Judge for the U.S.
District Court for the Southern District of New York; Kimba M. Wood,
Individually and in Her Official Capacity as Judge for the U.S. District
Court for the Southern District of New York; Steven M. Gold, Individually
and in His Official Capacity as Chief Magistrate Judge for the U.S.
District Court for the Eastern District of New York; Joan M. Azrack, Individually and in Her Official Capacity as
Magistrate Judge for the U.S. District Court for the Eastern District of
New York; Lois Bloom, Individually and in Her Official Capacity as
Magistrate Judge for the U.S. District Court for the Eastern District of
New York; E. Thomas Boyle, Individually and in His Official Capacity as
Magistrate Judge for the U.S. District Court for the Eastern District of
New York; Gary R. Brown, Individually and in His Official Capacity as
Magistrate Judge for the U.S. District Court for the Eastern District of
New York; Marilyn D. Go, Individually and in Her Official Capacity as
Magistrate Judge for the U.S. District Court for the Eastern District of
New York; Robert M. Levy, Individually and in His Official Capacity as
Magistrate Judge for the U.S. District Court for the Eastern District of
New York; Arlene R. Lindsay, Individually and in Her Official Capacity as
Magistrate Judge for the U.S. District Court for the Eastern District of
New York; Roanne L. Mann; Individually and in Her
Official Capacity as Magistrate Judge for the U.S. District Court for the
Eastern District of New York; James Orenstein, Individually and in Her
Official Capacity as Magistrate Judge for the U.S. District Court for the
Eastern District of New York; Viktor V. Pohorelsky;
Individually and in His Official Capacity as Magistrate Judge for the U.S.
District Court for the Eastern District of New York; Cheryl L. Pollak,
Individually and in Her Official Capacity as Magistrate Judge for the U.S.
District Court for the Eastern District of New York; Vera M. Scanlon,
Individually and in Her Official Capacity as Magistrate Judge for the U.S.
District Court for the Eastern District of New York; A. Kathleen Tomlinson,
Individually and in Her Official Capacity as Magistrate Judge for the U.S.
District Court for the Eastern District of New York; William D. Wall,
Individually and in His Official Capacity as Magistrate Judge for the U.S.
District Court for the Eastern District of New York; James L. Cott, Individually and in His Official Capacity as
Magistrate Judge for the U.S. District Court for the Southern District of
New York; Paul E. Davison, Individually and in His Official Capacity as
Magistrate Judge for the U.S. District Court for the Southern District of
New York; Michael H. Dolinger, Individually and
in His Official Capacity as Magistrate Judge for the U.S. District Court
for the Southern District of New York; Ronald L. Ellis, Individually and in
His Official Capacity as Magistrate Judge for the U.S. District Court for
the Southern District of New York; Kevin N. Fox, Individually and in His
Official Capacity as Chief Magistrate Judge for the U.S. District Court for
the Southern District of New York; James C. Francis, Individually and in
His Official Capacity as Magistrate Judge for the U.S. District Court for
the Southern District of New York; Debra Freeman, Individually and in Her
Official Capacity as Magistrate Judge for the U.S. District Court for the
Southern District of New York; Gabriel W. Gorenstein,
Individually and in His Official Capacity as Magistrate Judge for the U.S.
District Court for the Southern District of New York; Frank Maas,
Individually and in His Official Capacity as Magistrate Judge for the U.S.
District Court for the Southern District of New York; Sarah Netburn, Individually and in His Official Capacity as
Magistrate Judge for the U.S. District Court for the Southern District of
New York; Andrew J. Peck; Individually and in His Official Capacity as
Magistrate Judge for the U.S. District Court for the Southern District of
New York; Henry Pitman, Individually and in His Official Capacity as
Magistrate Judge for the U.S. District Court for the Southern District of
New York; Lisa Margaret Smith, Individually and in His Official Capacity as
Magistrate Judge for the U.S. District Court for the Southern District of
New York; Individually and George A. Yanthis,
Individually and in His Official Capacity as Magistrate Judge for the U.S.
District Court for the Southern District of New York; Martin R. Goldberg,
Individually and in His Official Capacity as Magistrate Judge for the U.S.
District Court for the Southern District of New York; Lawrence E. Kahn,
Individually and in His Official Capacity as Judge for the U.S. District
Court for the Northern District of New York; José Linares, Individually and
in His Official Capacity as Judge for the District of New Jersey; Catherine
O'Hagan Wolfe, Individually and in Her Official Capacity as Clerk of Court
for the U.S. Court of Appeals for the Second Circuit; Nancy B. Firestone,
in Her Official Capacity as Judge for the United States Court of Claims;
Christine O.C. Miller, in Her Official Capacity as Judge for the United
States Court of Claims; John P. Wiese, in His Official Capacity as Judge
for the United States Court of Claims; the Honorable Patrick J. Leahy,
Individually and in His Official Capacity as Chairman, U.S. Senate
Judiciary Committee; the Honorable Charles Schumer, Individually and in His
Official Capacity as Member, U.S. Senate Judiciary Committee; the Honorable
Dick Durbin, Individually and in His Official Capacity as Member, U.S.
Senate Judiciary Committee; the Honorable Sheldon Whitehouse, Individually
and in His Official Capacity as Member, U.S. Senate Judiciary Committee;
the Honorable Amy Klobuchar, Individually and in Her Official Capacity as
Member, U.S. Senate Judiciary Committee; the Honorable Al Franken,
Individually and in His Official Capacity as Member, U.S. Senate Judiciary
Committee; the Honorable Christopher A. Coons, Individually and in His
Official Capacity as Member, U.S. Senate Judiciary Committee; the Honorable
Richard Blumenthal, Individually and in His Official Capacity as Member,
U.S. Senate Judiciary Committee; the Honorable Mazie Hirono,
Individually and in His Official Capacity as Member, U.S. Senate Judiciary
Committee; the Honorable Chuck Grassley, Individually and in His Official
Capacity as Member, U.S. Senate Judiciary Committee; the Honorable Orrin G.
Hatch, Individually and in His Official Capacity as Member, U.S. Senate
Judiciary Committee; the Honorable Jeff Sessions, Individually and in His
Official Capacity as Member, U.S. Senate Judiciary Committee; the Honorable
Lindsey Graham, Individually and in His Official Capacity as Member, U.S.
Senate Judiciary Committee; the Honorable John Cornyn, Individually and in
His Official Capacity as Member, U.S. Senate Judiciary Committee; the
Honorable Michael S. Lee, Individually and in His Official Capacity as
Member, U.S. Senate Judiciary Committee; the Honorable Ted Cruz,
Individually and in His Official Capacity as Member, U.S. Senate Judiciary
Committee; the Honorable Jeff Flake, Individually and in His Official
Capacity as Member, U.S. Senate Judiciary Committee; the Honorable Bob
Goodlatte, Individually and in His Official Capacity as Member, U.S. House
Judiciary Committee; the Honorable Jim Sensenbrenner, Jr., Individually and
in His Official Capacity as Member, U.S. House Judiciary Committee; the
Honorable Howard Coble, Individually and in His Official Capacity as
Member, U.S. House Judiciary Committee; the Honorable Lamar Smith,
Individually and in His Official Capacity as Member, U.S. House Judiciary
Committee; the Honorable Steve Chabot, Individually and in His Official Capacity
as Member, U.S. House Judiciary Committee; the Honorable Spencer Bachus, Individually and in His Official Capacity as
Member, U.S. House Judiciary Committee; the Honorable Darrell Issa,
Individually and in His Official Capacity as Member, U.S. House Judiciary
Committee; the Honorable J. Randy Forbes, Individually and in His Official
Capacity as Member, U.S. House Judiciary Committee; the Honorable Steve
King, Individually and in His Official Capacity as Member, U.S. House
Judiciary Committee; the Honorable Trent Franks, Individually and in His
Official Capacity as Member, U.S. House Judiciary Committee; the Honorable
Louie Gohmert, Individually and in His Official
Capacity as Member, U.S. House Judiciary Committee; the Honorable Jim
Jordan, Individually and in His Official Capacity as Member, U.S. House
Judiciary Committee; the Honorable Ted Poe, Individually and in His
Official Capacity as Member, U.S. House Judiciary Committee; the Honorable
Hon. Jason Chaffetz, Individually and in His Official Capacity as Member,
U.S. House Judiciary Committee; the Honorable Tom Marino, Individually and
in His Official Capacity as Member, U.S. House Judiciary Committee; the
Honorable Hon. Trey Gowdy, Individually and in
His Official Capacity as Member, U.S. House Judiciary Committee; the
Honorable Mark Amodei, Individually and in His
Official Capacity as Member, U.S. House Judiciary Committee; the Honorable
Raul Labrador, Individually and in His Official Capacity as Member, U.S.
House Judiciary Committee; the Honorable Blake Farenthold,
Individually and in His Official Capacity as Member, U.S. House Judiciary
Committee; the Honorable George Holding, Individually and in His Official
Capacity as Member, U.S. House Judiciary Committee; the Honorable Doug
Collins, Individually and in His Official Capacity as Member, U.S. House
Judiciary Committee; the Honorable Ron DeSantis, Individually and in His
Official Capacity as Member, U.S. House Judiciary Committee; the Honorable
John Conyers, Individually and in His Official Capacity as Member, U.S.
House Judiciary Committee; the Honorable Jerrold Nadler, Individually and
in His Official Capacity as Member, U.S. House Judiciary Committee; the
Honorable Bobby Scott, Individually and in His Official Capacity as Member,
U.S. House Judiciary Committee; the Honorable Mel Watt, Individually and in
His Official Capacity as Member, U.S. House Judiciary Committee; the
Honorable Zoe Lofgren, Individually and in Her Official Capacity as Member,
U.S. House Judiciary Committee; the Honorable Jackson Lee, Individually and
in Her Official Capacity as Member, U.S. House Judiciary Committee; the
Honorable Steve Cohen, Individually and in His Official Capacity as Member,
U.S. House Judiciary Committee; the Honorable Hank Johnson, Individually
and in His Official Capacity as Member, U.S. House Judiciary Committee; the
Honorable Pedro Pierluisi, Individually and in
His Official Capacity as Member, U.S. House Judiciary Committee; the
Honorable Judy Chu, Individually and in His Official Capacity as Member,
U.S. House Judiciary Committee; the Honorable Ted Deutch,
Individually and in His Official Capacity as Member, U.S. House Judiciary
Committee; the Honorable Luis V. Gutierrez, Individually and in His
Official Capacity as Member, U.S. House Judiciary Committee; the Honorable
Karen Bass, Individually and in His Official Capacity as Member, U.S. House
Judiciary Committee; the Honorable Cedric Richmond, Individually and in His
Official Capacity as Member, U.S. House Judiciary Committee; the Honorable
Suzan DelBene, Individually and in His Official Capacity as Member, U.S.
House Judiciary Committee; the Honorable Joe Garcia, Individually and in
His Official Capacity as Member, U.S. House Judiciary Committee; the
Honorable Hakeem Jeffries, Individually and in His Official Capacity as
Member, U.S. House Judiciary Committee; the Honorable Dianne Feinstein,
Individually and in Her Official Capacity as Chairperson, Senate Select
Committee on Intelligence; the Honorable John D. Rockefeller IV,
Individually and in His Official Capacity as Member, Senate Select
Committee on Intelligence; the Honorable Ron Wyden, Individually and in His
Official Capacity as Member, Senate Select Committee on Intelligence; the
Honorable Barbara A. Mikulski, Individually and in Her Official Capacity as
Member, Senate Select Committee on Intelligence; the Honorable Mark Udall,
Individually and in His Official Capacity as Member, Senate Select
Committee on Intelligence; the Honorable Mark Warner, Individually and in
His Official Capacity as Member, Senate Select Committee on Intelligence;
the Honorable Martin Heinrich, Individually and in His Official Capacity as
Member, Senate Select Committee on Intelligence; the Honorable Angus King,
Individually and in His Official Capacity as Member, Senate Select
Committee on Intelligence; the Honorable Saxby Chambliss, Individually and
in His Official Capacity as Vice Chairman, Senate Select Committee on
Intelligence; the Honorable Richard Burr, Individually and in His Official
Capacity as Member, Senate Select Committee on Intelligence; the Honorable
James E. Risch, Individually and in His Official
Capacity as Member, Senate Select Committee on Intelligence; the Honorable
Daniel Coats, Individually and in His Official Capacity as Member, Senate
Select Committee on Intelligence; the Honorable Marco Rubio, Individually
and in His Official Capacity as Member, Senate Select Committee on
Intelligence; the Honorable Susan Collins, Individually and in Her Official
Capacity as Member, Senate Select Committee on Intelligence; the Honorable
Tom Coburn, Individually and in His Official Capacity as Member, Senate
Select Committee on Intelligence; the Honorable Mike Rogers, Individually
and in His Official Capacity as Chairman, House Permanent Select Committee
on Intelligence; the Honorable Mac Thornberry, Individually and in His
Official Capacity as Member, House Permanent Select Committee on
Intelligence; the Honorable Jeff Miller, Individually and in His Official
Capacity as Member, House Permanent Select Committee on Intelligence; the
Honorable Mike Conaway, Individually and in His Official Capacity as
Member, House Permanent Select Committee on Intelligence; the Honorable
Peter King, Individually and in His Official Capacity as Member, House
Permanent Select Committee on Intelligence; the Honorable Frank LoBiondo,
Individually and in His Official Capacity as Member, House Permanent Select
Committee on Intelligence; the Honorable Devin Nunes, Individually and in
His Official Capacity as Member, House Permanent Select Committee on
Intelligence; the Honorable Lynn Westmoreland, Individually and in His
Official Capacity as Member, House Permanent Select Committee on
Intelligence; the Honorable Michele Bachmann, Individually and in His
Official Capacity as Member, House Permanent Select Committee on
Intelligence; the Honorable Thomas J Rooney, Individually and in His
Official Capacity as Member, House Permanent Select Committee on
Intelligence; the Honorable Joe Heck, Individually and in His Official
Capacity as Member, House Permanent Select Committee on Intelligence; the
Honorable Mike Pompeo, Individually and in His Official Capacity as Member,
House Permanent Select Committee on Intelligence; the Honorable C.A. Dutch
Ruppersberger, Individually and in His Official Capacity as Member, House
Permanent Select Committee on Intelligence; the Honorable Mike Thompson,
Individually and in His Official Capacity as Member, House Permanent Select
Committee on Intelligence; the Honorable Jan Schakowsky, Individually and
in His Official Capacity as Member, House Permanent Select Committee on
Intelligence; the Honorable Jim Langevin, Individually and in His Official
Capacity as Member, House Permanent Select Committee on Intelligence; Hon.
Adam Schiff, Individually and in His Official Capacity as Member, House
Permanent Select Committee on Intelligence; Hon. Luis Gutierrez,
Individually and in His Official Capacity as Member, House Permanent Select
Committee on Intelligence; Hon. Ed Pastor, Individually and in His Official
Capacity as Member, House Permanent Select Committee on Intelligence; Hon.
Jim Himes, Individually and in His Official Capacity as Member, House
Permanent Select Committee on Intelligence; Hon. Terri Sewell, Individually
and in His Official Capacity as Member, House Permanent Select Committee on
Intelligence; Mr. Ruslan Agarunov, Individually
and in His Official Capacity as Campaign Contributor to Congressman Hakeem
Jeffries; Bertram Berns, Individually and in His
Official Capacity as Campaign Contributor to Congressman Hakeem Jeffries;
Mr. Norman Bobrow, Individually and in His
Official Capacity as Campaign Contributor to Congressman Hakeem Jeffries;
Mr. Paul Burg, Individually and in His Official Capacity as Campaign
Contributor to Congressman Hakeem Jeffries; Ms. Vickie Fishman,
Individually and in His Official Capacity as Campaign Contributor to
Congressman Hakeem Jeffries; Mr. Sander Gerber, Individually and in His
Official Capacity as Campaign Contributor to Congressman Hakeem Jeffries;
Mr. Michael Granoff, Individually and in His
Official Capacity as Campaign Contributor to Congressman Hakeem Jeffries;
Mr. Marvin Israelow, Individually and in His
Official Capacity as Campaign Contributor to Congressman Hakeem Jeffries;
Mr. Alan Levow, Individually and in His Official
Capacity as Campaign Contributor to Congressman Hakeem Jeffries; Mr.
William Russell-Shapiro, Individually and in His Official Capacity as
Campaign Contributor to Congressman Hakeem Jeffries; Ms. Donna Sternberg,
Individually and in His Official Capacity as Campaign Contributor to
Congressman Hakeem Jeffries; Mr. Marc Spiegel, Individually and in His
Official Capacity as Campaign Contributor to Congressman Hakeem Jeffries;
Mr. Daniel Tenenblatt, Individually and in His
Official Capacity as Campaign Contributor to Congressman Hakeem Jeffries;
Leslie Topper, Individually and in His Official Capacity as Campaign
Contributor to Congressman Hakeem Jeffries; Mr. Craig Weiss, Individually
and in His Official Capacity as Campaign Contributor to Congressman Hakeem
Jeffries; World Alliance for Israel PAC, Individually and in Its Official
Capacity as Campaign-Contributor to Congressman Hakeem Jeffries; Lee Ziff,
Individually and in His Official Capacity as President of the World
Alliance for Israel; the Honorable Eric H. Holder, Individually and in His
Official Capacity as Attorney General for the United States; Thomas Perez,
Individually and in His Official Capacity as Assistant Attorney General,
Disability Right Section for the U.S. Department of Justice; Michael E. Horowitz,
Individual and His in Official Capacity as Inspector General for the U.S.
Department of Justice; the U.S. Department of Justice; the Honorable Robert
Swan Mueller, Individually and in His Official Capacity as Director of the
Federal Bureau of Investigation; George Venizelos, Individually and in His
Official Capacity as Assistant Director in Charge of the Federal Bureau of
Investigation, New York Branch; the Federal Bureau of Investigation; Mr.
Stein, Individually and in His Official Capacity as Employee of the Federal
Bureau of Investigation; “John Doe” #1, Individually and in His Official
Capacity as Employee of the Federal Bureau of Investigation; the Honorable
Janet Napolitano, Individually and in Her Official Capacity as Secretary
for the U.S. Department of Homeland Security; John Morton, Individually and
in His Official Capacity as Director for the U.S. Immigration and Customs
Enforcement; Daniel Ragsdale, Individually and in His Official Capacity as
Deputy Director for the U.S. Immigration and Customs Enforcement; Radha Sekar, Individually and in Her Official Capacity as
Acting Executive Associate Director for the U.S. Immigration and Customs
Enforcement; James Dinkins, Individually and in His Official Capacity as
Executive Associate Director for the U.S. Homeland Security Investigations,
U.S. Immigration and Customs Enforcement; Gary Mead, Individually and in
His Official Capacity as Executive Associate Director for the Enforcement
and Removal Operations, U.S. Immigration and Customs Enforcement; Peter S.
Vincent, Individually and in His Official Capacity as Principal Legal
Adviser for the U.S. Immigration and Customs Enforcement;Timothy
Moynihan, Individually and in His Official Capacity as Assistant Director,
Office of Professional Responsibility U.S. Immigration and Customs
Enforcement; Tamara Kessler, Individually and in Her Official Capacity as
Acting Officer for the Office for Civil Rights and Civil Liberties; Rachel
McCarthy, Individually and Her Official Capacity as Bar Counsel for the U.S.
Department of Homeland Security; Rand Beers, Individually and in His
Official Capacity as Under Secretary for the Homeland Security for National
Protection and Programs; Denis P. McGowan, Individually and in His Official
Capacity as Regional Director, Federal Protection Service, National
Protection and Programs Directorate for the U.S. Department of Homeland
Security; Gayle Worthy, Individually and in Her Official Capacity as FOIA
Officer/Public Liaison for the U.S. Department of Homeland Security; Ivan K.
Fong, Individually and in His Official Capacity as General Counsel of the
U.S. Department of Homeland Security; Charles K. Edwards, Individually and
in His Official Capacity as Inspector General of U.S. Department of
Homeland Security; the U.S. Department of Homeland Security; Stacia Hylton, Individually and in Her Official Capacity as
Director of the U.S. Marshal Service; Gerald Auerbach, Individually and in
His Official Capacity as General Counsel for the U.S. Marshals Service;
Charles Dunne, Director, U.S. Marshals Service for the Eastern District of
New York; “John Doe #2”, U.S. Marshals Service for the Eastern District of
New York; “John Doe #3, U.S. Marshals Service for the Eastern District of
New York; “Jane Doe”, U.S. Marshals Service for the Eastern District of New
York; the U.S. Marshals Service; Kathleen Sebelius, Individually and in Her
Official Capacity as Secretary of the U.S. Department of Health and Human
Services; William B. Schultz, Individually in His Official Capacity as
General Counsel for the U.S. Department of Health and Human Services; the
U.S. Department of Health and Human Services; Marilyn Tavenner,
Individually and in Her Official Capacity as Acting Administrator Chief
Operating Officer, Centers for Medicare and Medicaid Office; Eric
Schneiderman, Individually and in His Official Capacity as New York State
Attorney General, New York State Attorney General's Office; Eric Adams,
Individually, and in His Official Capacity as Member, New York Senate
Judiciary Committee; John J. Bonacic, Individually,
and in His Official Capacity as Member, New York Senate Judiciary
Committee; Neil D. Breslin, Individually, and in His Official Capacity as
Member, New York Senate Judiciary Committee; John A. DeFrancisco,
Individually, and in His Official Capacity as Member, New York Senate
Judiciary Committee; Martin Malavé Dilan,
Individually, and in His Official Capacity as Member, New York Senate
Judiciary Committee; Adriano Espaillat,
Individually, and in His Official Capacity as Member, New York Senate Judiciary
Committee; John J. Flanagan, Individually, and in His Official Capacity as
Member, New York Senate Judiciary Committee; Charles J. Fuschillo
Jr., Individually, and in His Official Capacity as Member, New York Senate
Judiciary Committee; Kemp Hannon, Individually, and in His Official
Capacity as Member, New York Senate Judiciary Committee; Ruth
Hassell-Thompson, Individually, and in Her Official Capacity as Member, New
York Senate Judiciary Committee; Brad Hoylman,
Individually, and in His Official Capacity as Member, New York Senate
Judiciary Committee; Andrew J Lanza, Individually, and in His Official
Capacity as Member, New York Senate Judiciary Committee; Kenneth P.
LaValle, Individually, and in His Official Capacity as Member, New York
Senate Judiciary Committee; Betty Little, Individually, and in Her Official
Capacity as Member, New York Senate Judiciary Committee; Michael F. Nozzolio, Individually, and in His Official Capacity as
Member, New York Senate Judiciary Committee; Thomas F. O'Mara, Individually,
and in His Official Capacity as Member, New York Senate Judiciary
Committee; Bill Perkins, Individually, and in His Official Capacity as
Member, New York Senate Judiciary Committee; Michael H. Ranzenhofer,
Individually, and in His Official Capacity as Member, New York Senate
Judiciary Committee; John L. Sampson, Individually, and in His Official
Capacity as Member, New York Senate Judiciary Committee; Diane J. Savino,
Individually, and in His Official Capacity as Member, New York Senate Judiciary
Committee; Malcolm A. Smith, Individually, and in His Official Capacity as
Member, New York Senate Judiciary Committee; Toby Ann Stavisky,
Individually, and in His Official Capacity as Member, New York Senate
Judiciary Committee; Lee M. Zeldin, Individually,
and in His Official Capacity as Member, New York Senate Judiciary
Committee; Andrew M. Cuomo, Individually and in His Official Capacity as
Governor of the State of New York; the State of New York; Jonathan Lippman,
Individually and in His Official Capacity as Chief Judge for the New York
State Unified Court System; John W. McConnell, Individually and in His
Official Capacity as Counsel to the Chief Administrative Judge, for the New
York State Unified Court System; Daniel D. Angiolillo,
Individually and in His Official Capacity as Appellate Judge for the New
York State Unified Court System; Second Judicial Department; Cheryl E.
Chambers, Individually and in Her Official Capacity as Appellate Judge for
the New York State Unified Court System; Second Judicial Department;
Jeffrey A. Cohen, Individually and in His Official Capacity as Appellate
Judge for the New York State Unified Court System; Second Judicial
Department; Mark C. Dillon, Individually and in His Official Capacity as
Appellate Judge for the New York State Unified Court System; Second
Judicial Department; Anita R. Florio, Individually and in Her Official
Capacity as Appellate Judge for the New York State Unified Court System;
Second Judicial Department; Steven W. Fisher, Individually and in His Official
Capacity as Appellate Judge for the New York State Unified Court System;
Second Judicial Department; L. Priscilla Hall, Individually and in Her
Official Capacity as Appellate Judge for the New York State Unified Court
System; Second Judicial Department; John M. Leventhal, Individually and in
His Official Capacity as Appellate Judge for the New York State Unified
Court System; Second Judicial Department; Plummer E. Lott, Individually and
in His Official Capacity as Appellate Judge for the New York State Unified
Court System; Second Judicial Department; William F. Mastro,
Individually and in His Official Capacity as Appellate Judge for the New
York State Unified Court System; Second Judicial Department; Robert J.
Miller, Individually and in His Official Capacity as Appellate Judge for
the New York State Unified Court System; Second Judicial Department; A.
Gail Prudenti, Individually and in Her Official
Capacity as Appellate Judge for the New York State Unified Court System;
Second Judicial Department; Reinaldo E. Rivera, Individually and in His
Official Capacity as Appellate Judge for the New York State Unified Court
System; Second Judicial Department; Sheri S. Roman, Individually and in Her
Official Capacity as Appellate Judge for the New York State Unified Court
System; Second Judicial Department; Sandra L. Sgroi,
Individually and in Her Official Capacity as Appellate Judge for the New
York State Unified Court System; Second Judicial Department; Peter B. Skelos, Individually and in His Official Capacity as
Appellate Judge for the New York State Unified Court System; Second
Judicial Department; Thomas Scuccimarra, Individually and in His Official
Capacity as Justice for the New York State Unified Court System; Jeffrey S.
Sunshine, Individually and in His Capacity as Justice, New York State
Unified Court System; Nancy Tegtmeier Sunshine,
Individually and in her Official Capacity as Chief Clerk of Court for the
New York State Unified Court System; Lara J. Genovesi,
Individually and in Her Official Capacity as Court Attorney for the New
York State Unified Court System; Antonio Diaz, Individually and in His
Official Capacity as Borough Chief Clerk for the New York State Unified
Court System; Arthur M. Schack, Individually and in His Official Capacity
as Justice of the New York State Unified Court System; Ronald D. Bratt, Individually and in His Official Capacity as Law
Clerk for the New York State Unified Court System; Barbara Guida, Individually and in Her Official Capacity as
Secretary for the New York State Court System; Yolanda Jennings,
Individually and in Her Official Capacity as Part Clerk for the New York
State Unified Court System; Kalisha Evans,
Individually and in Her Official Capacity as Officer for the New York State
Unified Court System; Eileen A. Rakower,
Individually and in Her Official Capacity as Justice for the New York State
Unified Court System; Donna Mills, Individually and in Her Official
Capacity as Justice for the New York State Unified Court System; Matthew D'Emic, Individually and in His Official Capacity as
Justice for the New York State Unified Court System; Michael Gerstein,
Individually and in His Official Capacity as Justice for the New York State
Unified Court System; New York State Unified Court System; Anthony Cutrona, Individually and in His Official Capacity as
Justice for the New York State Unified Court System; New York State Unified
Court System; Thomas A. Klonick, Individually and
in His Official Capacity as Chair of the New York State Commission on
Judicial Conduct; the New York State Commission on Judicial Conduct; Jorge
Del Tipico, Individually and in His Capacity as
Chair for the New York State Departmental Disciplinary Committee for the
First Department; New York State Departmental Disciplinary Committee for
the First Department; Richard M. Gutierrez, Individually and in His
Official Capacity as Chair for the Grievance Committee for the Second,
Eleventh, and Thirteenth Judicial Districts; Grievance Committee for the
Second, Eleventh, and Thirteenth Judicial Districts; The Honorable Nirav R.
Shah, M.D., M.P.H., Individually and in His Official Capacity as
Commissioner of the New York State Department of Health; New York State
Department of Health; Kristin M. Woodlock, RN,
MPA, Individually and in Her Official Capacity as Acting Commissioner for
the New York State Office of Mental Health; John Tauriello,
Esq. Individually and in His Official Capacity as Deputy Commissioner and
Chief Counsel of the New York State Office of Mental Health; Samuel Gant,
Individually and in His Official Capacity as Director of the Intensive Case
Management Program, Kingsboro Psychiatric
Facility, New York State Office of Mental Health, Bridget Davis,
Individually and in Her Official Capacity as Intensive Case Worker for the
Intensive Case Management Program, New York State Office of Mental Health;
New York State Office of Mental Health; Kristin M. Proud, Individually and
in Her Official Capacity as Commissioner of the New York State Office of
Temporary and Disability Assistance; Maria T. Vidal, Individually and in
Her Official Capacity as General Counsel for the New York State Office of
Temporary and Disability Assistance; Robert Doar,
Individually and in His Official Capacity as Administrator and Commissioner
of the New York City Human Resources Administration; Roy A. Esnard, Individually and in His/Her
Official Capacity as General Counsel of the New York City Human Resources
Administration; the New York City Human Resources Administration; the New
York City Human Resources Administration; Michael Bloomberg, Individually
and in His Official Capacity as Mayor of the City of New York; the City of
New York; Michael Cardozo, Individually and in His Official Capacity as
Corporation Counsel for the City of New York; Charles A. Hynes,
Individually and in his Official Capacity as District Attorney for Kings
County; Amy Feinstein, Individually and in Her Official Capacity as Chief
Assistant District Attorney, Kings County District Attorney's Office; Kings
County District Attorney's Office; Salvatore J. Russo, Individually and in
His Official Capacity as General Counsel for the New York City Health and
Hospitals Corporation; Agnes Flores, Individually and in Her Former
Official Capacity as Psychiatric Nurse for the New York City Health and
Hospitals Corporation; Martin Bolton, Individually and in Former His
Official Capacity as Psychotherapist for the New York City Health and
Hospitals Corporation; Margaret Thomas, Individually and in Her Office
Capacity as Licensed Practical Nurse for the New York City Health and
Hospitals Corporation; Pauline Amo-Adu,
Individually and in Her Official Capacity as (unlicensed) Master Social
Worker for the New York City Health and Hospitals Corporation; Mario Blake,
Individually and in His Official Capacity as Psychiatric Technician; James Oniwe, Individually and in His Official Capacity as
Registered Nurse for the New York City Health and Hospitals Corporation;
Jean Barry, Individually and in Her Official Capacity as Licensed Clinical
Social Worker for the New York City Health and Hospitals Corporation; Hugette Guilliame Sam,
Individually and in Her Official Capacity as Registered Nurse for the New
York City Health and Hospitals Corporation; Samuel Sarpong, Individually
and in His Official Capacity as Program Manager for the New York City
Health and Hospitals Corporation; Dr. Scott Andrew Berger, Individually and
in His Official Capacity as Psychiatrist for the New York City Health and
Hospitals Corporation; New York City Health and Hospitals Corporation;
Joseph Visceglia, Individually and in His
Official Capacity as City Clerk for the Office of the City Clerk; Office of
the City Clerk, Marriage License Bureau; City of New York; Dr. “John Doe”
#4, Psychiatrist, Brookdale Hospital Medical Center; Brooklyn Hospital
Medical Center; Giselle Stolper, President and
CEO, Mental Health Association of New York City; Robert P. Borsody, Esq., Secretary of the Mental Health
Association of New York City; Mental Health Association of New York City;
Sean Bolser, Esq., Federal Defender, Federal
District of New York; Heidi C. Cesare, Esq,
Federal Defenders, Federal District of New York; Randi L. Chavis, Esq, Federal Defenders, Federal District of New York;
Deirdre von Dornum, Esq,
Federal Defenders, Federal District of New York; Tracey E. Gaffey, Esq, Federal
Defenders, Federal District of New York; Michelle A. Gelernt,
Esq., Federal Defenders, Federal District of New York; Lisa Hoyes, Federal Defenders, Federal District of New York;
Len H. Kamdang, Federal Defenders, Federal
District of New York; Peter Kirchheimer, Federal
Defenders, Federal District of New York; David A. Lewis, Federal Defenders,
Federal District of New York; Douglas G. Morris, Federal Defenders, Federal
District of New York; Michael P. Padden, Federal Defenders, Federal
District of New York; David Patton, Federal Defenders, Federal District of
New York; Jan A. Rostal, Federal Defenders,
Federal District of New York; Michael K. Schneider, Federal Defenders,
Federal District of New York; Chase A. Scolnick,
Federal Defenders, Federal District of New York; Kannan Sundaram, Federal
Defenders, Federal District of New York; Michael D. Weil, Federal
Defenders, Federal District of New York; Mildred M. Whalen, Federal
Defenders, Federal District of New York; Robert M. Baum, Federal Defenders,
Federal District of New York; Sarah Baumgartel,
Federal Defenders, Federal District of New York; Susanne Brody, Federal
Defenders, Federal District of New York; Jennifer Brown, Federal Defenders,
Federal District of New York; Martin Cohen, Federal Defenders, Federal
District of New York; Peggy Cross-Goldenberg, Federal Defenders, Federal
District of New York; Christopher Flood, Federal Defenders, Federal
District of New York; Julia Gatto, Federal
Defenders, Federal District of New York; Mark Gombiner,
Federal Defenders, Federal District of New York; Jonathan Marvinny, Federal Defenders, Federal District of New
York; Annalisa Mirón, Federal Defenders, Federal
District of New York; David Patton, Federal Defenders, Federal District of
New York; Sabrina Shroff, Federal Defenders, Federal District of New York;
Roland Thau, Federal Defenders, Federal District
of New York; Jerrod Thompson-Hicks, Federal Defenders, Federal District of
New York; Philip Weinstein, Federal Defenders, Federal District of New
York; Federal Defenders, Federal District of New York; Leonardo Aldridge,
Esq., Brooklyn Defender Service; Mary Beth Anderson, Esq., Brooklyn
Defender Service; Michael Arthus, Esq., Brooklyn
Defender Service; Adam Axel, Esq., Brooklyn Defender Service; Betty Baez
Melo, Esq., Brooklyn Defender Service; Elyse Bataller
Schneider, Esq., Brooklyn Defender Service; Michael F. Baum, Esq., Brooklyn
Defender Service; Whitney Z. Bernstein, Esq., Brooklyn Defender Service;
Sarah Boyette, Esq., Brooklyn Defender Service;
Michael Brown, Esq., Brooklyn Defender Service; Joyce Brunwasser,
Esq., Brooklyn Defender Service; Jamie Burke, Esq., Brooklyn Defender
Service; Sarah M. Burleson, Esq., Brooklyn Defender Service; Amos Cohen,
Esq., Brooklyn Defender Service; George Cooke, Esq., Brooklyn Defender
Service; Virginia Curry, Esq., Brooklyn Defender Service; Edward Daniels,
Esq., Brooklyn Defender Service; Chad Dauman,
Esq., Stephen Dean, Esq., Brooklyn Defender Service; Christina M. Dieckmann, Esq., Brooklyn Defender Service; Sara
Feinberg, Esq., Juan Fiol, Esq., Brooklyn
Defender Service; Molly Gallivan, Esq., Brooklyn Defender Service; Tim Gumkowski, Esq., Brooklyn Defender Service; Amanda
Hamann, Esq., Brooklyn Defender Service; Le'Shera
Hardy, Esq., Brooklyn Defender Service; Scott Hechinger, Esq., Brooklyn
Defender Service; Shannon Heery, Esq., Brooklyn
Defender Service; Nyasa Hickey, Esq., Brooklyn Defender Service; Linda
Hoff, Esq., Brooklyn Defender Service; Dorothy Hughes, Esq., Joseph Indusi, Esq., Brooklyn Defender Service; Amanda Jack,
Esq., Brooklyn Defender Service; Joyce Kendrick, Esq., Elizabeth Kilstein, Esq., Brooklyn Defender Service; Ashley Kloepfer, Esq., Brooklyn Defender Service; Jared Kneitel, Esq., Brooklyn Defender Service; Dara Kristt, Esq., Brooklyn Defender Service; Summer Lacey,
Esq., Brooklyn Defender Service; Richard M. LaFontaine, Esq., Brooklyn
Defender Service; Elizabeth Latimer, Esq., Yung-Mi Lee, Esq., Brooklyn
Defender Service; Thomas Leith, Esq., Brooklyn Defender Service; Hela Levi,
Esq., Brooklyn Defender Service; Paul Lieberman, Esq., Brooklyn Defender
Service; Jacob Lipsky, Esq., Brooklyn Defender Service; Cary London, Esq.,
Brooklyn Defender Service; Ruben Loyo, Esq.,
Brooklyn Defender Service; Alyssa Mack, Esq., Brooklyn Defender Service;
Harvey Mandelcorn, Esq., Brooklyn Defender
Service; Marie Mark, Esq., Brooklyn Defender Service; Ed Mayr, Esq.,
Brooklyn Defender Service; Cameron Mease, Esq.,
Brooklyn Defender Service; Becca Miller, Esq., Brooklyn Defender Service;
Susan Mitchell, Esq., Brooklyn Defender Service; Jillian Modzeleski, Esq., Brooklyn Defender Service; Benjamin
Moore, Esq., Brooklyn Defender Service; Lauren Nakamura, Esq., Brooklyn
Defender Service; Anders Nelson, Esq., Sarah Nolan, Esq., Brooklyn Defender
Service; Hemangi S. Pai,
Esq., Brooklyn Defender Service; Sydney Peck, Esq., Brooklyn Defender
Service; Talia Peleg, Esq., Brooklyn Defender Service; Christopher Perks,
Esq., Alex Perlin, Esq., Brooklyn Defender Service; Guy Raimondi, Esq.,
Brooklyn Defender Service; Danielle Regis, Esq., Brooklyn Defender Service;
Robert Riether, Esq., Brooklyn Defender Service;
Alan Rosenberg, Esq., Brooklyn Defender Service; Scott Ruplinger,
Esq., Brooklyn Defender Service; Laura Saft,
Esq., Brooklyn Defender Service; Lisa Salvatore, Esq., Iliana Santiago,
Esq., Josh Saunders, Esq., Brooklyn Defender Service; Lisa Schreibersdorf, Esq., Brooklyn Defender Service; Amanda
Scioscia, Esq., Brooklyn Defender Service; David
Secular, Esq., Brooklyn Defender Service; Renee Seman,
Esq., Brooklyn Defender Service; Marissa Sherman, Esq., Brooklyn Defender
Service; Joseph P. Sieger, Esq., Brooklyn
Defender Service; Debora Silberman, Esq., Brooklyn Defender Service;
Arielle Simon, Esq., Brooklyn Defender Service; Angad Singh, Esq., Brooklyn
Defender Service; Shari Stein, Esq., Brooklyn Defender Service; Sonia
Tate-Cousins, Esq., Brooklyn Defender Service; Sarah Vendzules,
Esq., Brooklyn Defender Service; C. Randall Walker, Esq., Brooklyn Defender
Service; Emilie Williams, Esq., Brooklyn Defender Service; Ken Womble, Esq.,
Brooklyn Defender Service; Aminie Woolworth,
Esq., Brooklyn Defender Service; Brooklyn Defender Service; Marianne C.
Yang, Esq., Brooklyn Defender Service; Brooklyn Defender Service; Iris
Ying, Esq., Brooklyn Defender Service; Benjamin Zeman, Esq., Brooklyn
Defender Service; Lauren Zimmerman, Brooklyn Defender Service, Brooklyn
Defenders Service, Inc.;Mortimer Zuckerman,
Individually and in His Official Capacity as Editor, Publisher and Owner of
the Daily News, LP; Mortimer Zuckerman, Individually and in His Official
Capacity as Editor, Publisher and Owner of the Daily News, LP; Scott Shifrel, former Staff Writer of the Daily News, LP; the
Daily News, LP; Rupert Murdoch, New York Post, New York Post; Mark Fass, Staff Writer, ALM.com; ALM.com; Jazmin M. Quary, Michael J. Fitzpatrick, Individually and in His
Official Capacity as Executive Director for NAMI, Inc.; NAMI, Inc.; Andrew Lavoott Bluestone, Esq., Roberta Siegal, Individually
in Her Official Capacity as Assistant Vice President of Federation Employment
and Guidance Services, Inc.; Dr. Forster, in His Official Capacity as
Psychiatrist of Federation Employment and Guidance Services, Inc.; Clifford
Nafus, in His Official Capacity as Rehabilitation
Technician of Federation Employment and Guidance Services, Inc.; Federation
Employment and Guidance Services, Inc.; Rabbi Michael J. Broyde, Esq., Rabbi Michoel Zylberman, Esq., Rabbi Yona
Reiss, Esq., Rabbi Shlomo Weissmann,
Esq.; Abraham H. Foxman, Individually and in His Capacity as Executive
Director of the Anti-Defamation League, Inc.; Steven M. Freeman, Esq., Anti Defamation League, Inc.; Steven C. Sheinberg,
Esq., Anti-Defamation League, Inc.; Deborah Bensinger,
Esq., Anti-Defamation League, Inc.; David L. Barkey, Esq., Anti-Defamation
League, Inc.; Allen E. Kaye, P.C.; Jan Eastman, Esq., Chair, Vermont
Professional Responsibility Program, Office of Bar Counsel; Michael
Kennedy, Individually and in His Official Capacity as Bar Counsel for the
Vermont Professional Responsibility Program, Office of Bar Counsel; Vermont
Professional Responsibility Program, Office of Bar Counsel; George Wachtel,
Esq.; Jonathan D. Schwartz, Individually and in His Official Capacity as
Executive Vice President and General Counsel for Cablevision, Inc.;
Cablevision, Inc.; Ruslan Agarunov, Campaign
Contributor, Bertram Berns, Campaign, Norman Bobrow, Campaign Contributor, Paul Burg, Campaign
Contributor; Vickie Fishman, Campaign Contributor; Sander Gerber; Sander
Gerber; Michael Granoff; Campaign Contributor;
Sander Gerber, Michael Granoff, Marvin Israelow, Alan Levow, Mr.
William Russell-Shapiro, Marc Spiegel, Donna Sternberg, Mr. Daniel Tenenblatt, Leslie Topper, Craig Weiss, Alan Wildes, World Alliance for Israel PAC, Lee Ziff, Allen
E. Kaye, Esq. Harvey Shapiro, Esq., Law Office of Harvey Shapiro; Jack
Gladstein, Esq., Law Office of Jack Gladstein and Messinger,
Osato Eugene Uzamere, Esq., Uzamere and Associates, PLLC and Senator Ehigie
Edobor Uzamere
Defendants.
|
|
Civil Action No.: 1:2013-CV-00505
VERIFIED COMPLAINT
JURY TRIAL DEMANDED
|
|
At all times hereinafter
mentioned, Plaintiff Cheryl D. Uzamere, a natural person, and mother of
David P. Walker and Tara A. Uzamere, all of whom are victims of fraud, identity
theft, aggravated identity theft, other federal offenses and civil rights
violations committed by the Defendants, states the following under the
penalties of perjury:
PRELIMINARY
STATEMENT
U.S.
Constitutional Mandates
First
Amendment
1) “Congress
shall make no law respecting an establishment of religion. . .or abridging
the freedom of speech, . . .and to petition the Government for a redress of
grievances” See Lemon v. Kurtzman,
403 U.S. 602 (1971).
2) U.S.
Supreme Court Case Law Regarding the Establishment Clause: “In 1947, the
U.S. Supreme Court decision Everson v. Board of Education incorporated the
Establishment Clause (i.e., made it apply against the states). In the
majority decision, Justice Hugo Black wrote: 'The “establishment of religion”
clause of the First Amendment means at least this: Neither a state nor the
Federal Government can set up a church. Neither can pass laws which aid one
religion, aid all religions, or prefer one religion to another . . . in the
words of Jefferson, the [First Amendment] clause against establishment of
religion by law was intended to erect 'a wall of separation between church
and State' ... That wall must be kept high and impregnable. We could not
approve the slightest breach. In the Board
of Education of Kiryas Joel Village School
District v. Grumet (1994), Justice David
Souter, writing for the majority, concluded that “government should not
prefer one religion to another, or religion to irreligion.”
3) U.S. Supreme Court Case Law Regarding the Free Speech Clause:
In Herndon v. Lowry (1937), the Court heard the case of African American
Communist Party organizer Angelo Herndon, who had been convicted under the
Slave Insurrection Statute for advocating black rule in the southern U.S.
In a 5-4 decision, the Court reversed Herndon's conviction, upholding
Holmes' "clear and present danger" test for the first time and
arguing that the state of Georgia had not demonstrated that Herndon's
actions met this standard (NSLs should be held to this standard).
4) U.S. Supreme Court Case Law Regarding the Petition
Clause: “Today this right encompasses petitions to all three branches of
the federal government—the Congress, the executive and the judiciary—and
has been extended to the states through incorporation. According to the
Supreme Court, 'redress of grievances' is to be construed broadly: it
includes not solely appeals by the public to the government for the
redressing of a grievance in the traditional sense, but also, petitions on
behalf of private interests seeking personal gain. The right not only
protects demands for "a redress of grievances" but also demands
for government action. In Borough of
Duryea v. Guarnieri (2011), the Supreme Court
stated regarding the Free Speech Clause and the Petition Clause: It is not
necessary to say that the two Clauses are identical in their mandate or
their purpose and effect to acknowledge that the rights of speech and
petition share substantial common ground... Both speech and petition are
integral to the democratic process, although not necessarily in the same
way. The right to petition allows citizens to express their ideas, hopes,
and concerns to their government and their elected representatives, whereas
the right to speak fosters the public exchange of ideas that is integral to
deliberative democracy as well as to the whole realm of ideas and human
affairs. Beyond the political sphere, both speech and petition advance
personal expression, although the right to petition is generally concerned
with expression directed to the government seeking redress of a grievance.
The right of assembly was originally distinguished from the right to
petition. In United States v. Cruikshank the Supreme Court held that 'the right of
the people peaceably to assemble for the purpose of petitioning Congress
for a redress of grievances, or for anything else connected with the powers
or duties of the National Government, is an attribute of national
citizenship, and, as such, under protection of, and guaranteed by, the
United States. The very idea of a government, republican in form, implies a
right on the part of its citizens to meet peaceably for consultation in
respect to public affairs and to petition for a redress of grievances.'
Justice Morrison Waite's opinion for the Court carefully distinguished the
right to peaceably assemble as a secondary right, while the right to
petition was labeled to be a primary right.1
Fifth
Amendment
5) “No person shall be . . .deprived
of life, liberty, or property, without due process of law. . .”
Correctional Services Corporation, v. John E. Malesko
534 U. S. __ (2001), page 5.
Sixth
Amendment
6) “In all criminal prosecutions, the
accused shall enjoy the right to a speedy and public trial, by an impartial
jury of the State and district wherein the crime shall have been committed,
which district shall have been previously ascertained by law, and to be
informed of the nature and cause of the accusation; to be confronted with
the witnesses against him; to have compulsory process for obtaining
witnesses in his favor, and to have the Assistance of Counsel for his
defense.” See Pointer v. Texas,
380 U.S. 400 (1965)
7) U.S. Supreme Court Case Law
regarding the Notice Clause: “In all criminal prosecutions, the accused
shall enjoy the right to a speedy and public trial, by an impartial jury of
the State and district wherein the crime shall have been committed, which
district shall have been previously ascertained by law, and to be informed
of the nature and cause of the accusation; to be confronted with the
witnesses against him; to have compulsory process for obtaining witnesses
in his favor, and to have the Assistance of Counsel for his defence.” In the case United States v. Carll, 105 U.S. 611
(1881).”
8) U.S. Supreme Court Case Law regarding the Assistance of Counsel
Clause: “The Sixth Amendment is a part of what is called our Bill of
Rights. In Gideon v. Wainwright,
supra, in which this Court held that the Sixth Amendment's right to the
assistance of counsel is obligatory upon the States, we did so on the ground
that 'a provision of the Bill of Rights which is 'fundamental and essential
to a fair trial' is made obligatory upon the States by the Fourteenth
Amendment.' 372 U. S. at 342. And last Term in Malloy v. Hogan, 378 U. S. 1, in holding that the Fifth Amendment's
guarantee against self-incrimination was made applicable to the States by
the Fourteenth, we reiterated the holding of Gideon that the Sixth
Amendment's right-to-counsel guarantee is 'a fundamental right, essential
to a fair trial,' and thus was made obligatory on the States by the
Fourteenth Amendment.' 378 U. S., at 6. See also Murphy v. Waterfront Commission, 378 U. S. 52. We hold today
that the Sixth Amendment's right of an accused to confront the witnesses
against him is likewise a fundamental right and is made obligatory on the
States by the Fourteenth Amendment.”
Fourteenth
Amendment
9) “No State shall make or enforce any
law which shall abridge the privileges or immunities of citizens of the
United States; nor shall any State deprive any person of life, liberty, or
property, without due process of law; nor deny to any person within its
jurisdiction the equal protection of the laws.” See Tennessee V. Lane (02-1667) 541 U.S. 509 (2004) 315 F.3d 680,
affirmed.
FEDERAL
STATUTES
Title II of the
Americans With Disabilities
Federal
Rehabilitation Act of 1973
10) Title II of the Americans With
Disabilities Act, 42 U.S.C. §§12131, 12132, prohibits discrimination
against individuals with disabilities, including those with mental illness.
Similarly, Section 504 of the Rehabilitation Act, 29 U.S.C. §794, provides
that no person with a disability, including those with mental illness,
shall: “solely by reason of his or her disability, be excluded from
participation in, be denied benefits of, or be subjected to discrimination
under any program or activity receiving Federal financial assistance.”
11) In the decision regarding Disability Advocates, Inc. vs. Paterson, et al, Defendant
Garaufis stated that “The Supreme Court held in Olmstead v. L.C., 527 U.S.
581 (1999), that “[u]njustified isolation . . .
is properly regarded as discrimination based on disability,” observing that
“institutional placement of persons who can handle and benefit from
community settings perpetuates unwarranted assumptions that persons so
isolated are incapable of or unworthy of participating in community life.”
527 U.S. at 597, 600. The “integration mandate” of Title II of the American
with Disabilities Act, 42 U.S.C. §12101 et seq., and Section 504 of the
Rehabilitation Act, 29 U.S.C. §791 et seq., as expressed in federal
regulations and Olmstead, requires that when a state provides services to
individuals with disabilities, it must do so “in the most integrated
setting appropriate to their needs.” The “most integrated setting,”
according to the federal regulations, is “a setting that enables
individuals with disabilities to interact with non-disabled persons to the fullest extent possible.” 28 C.F.R. §35.130(d);
28 C.F.R. pt. 35 app. A.
12) Further, Title II of the Americans With Disabilities Act
requires that “a public entity shall administer services, programs, and
activities in the most integrated setting appropriate to the needs of
qualified individuals with disabilities.” See 28 C.F.R. §35.130(d).
13) In the landmark decision Olmstead v. L.C., 527 U.S. 581 (1999), the U.S. Supreme Court
held that these provisions of law are violated when a state places people
with mental illness in “unjustified isolation,” and that a person with
mental illness may sue the state for failing to place him or her “in the
most integrated setting appropriate to [his or her] needs.”
14) Defendant Garaufis stated in the aforementioned
decision that Title II of the ADA applies to “any State or local
government” and “any department, agency, special purpose district, or other
instrumentality of a State or States or local government.” 42 U.S.C.
§12131(1). Accordingly, all governmental entities are subject to Title II
of the Americans With Disabilities Act.
Civil
Rights Act of 1964, Title VI, §601
Nondiscrimination
in Federally Assisted Programs
15) “No person in the United States shall, on the ground of
race, color, or national origin, be excluded from participation in, be denied
the benefits of, or be subjected to discrimination under any program or
activity receiving Federal financial assistance.” Fogg v. Gonzales, Nos. 05-5439, 05-5440 says the
following: “In the case Correctional
Services Corporation, v. John E. Malesko, the
U.S. Supreme Court stated that “In 30 years of Bivens jurisprudence we have
extended its holding only twice, to provide an otherwise nonexistent cause
of action against individual officers alleged to have acted
unconstitutionally, or to provide a cause of action for a plaintiff who
lacked any alternative remedy for harms caused by an individual officers
unconstitutional conduct.” However, in the same case, the Court said: “Most
recently, in FDIC v. Meyer, we
unanimously declined an invitation to extend Bivens to permit suit against
a federal agency, even though . . .Congress had waived sovereign immunity
[and] was otherwise amenable to suit. 510 U. S., at 484, 486. Our opinion
emphasized that the purpose of Bivens is to deter the officer, not the agency.
Id., at 485 (emphasis in original) (citing Carlson v. Green, supra, at 21). We reasoned that if given the
choice, plaintiffs would sue a federal agency instead of an individual who
could assert qualified immunity as an affirmative defense. To the extent aggrieved
parties had less incentive to bring damages claim against individuals, the
deterrent effects of the Bivens remedy would be lost. 510 U.S. at 485.
Accordingly, to allow a Bivens claim against federal agencies would mean
the evisceration of the Bivens remedy, rather than its extension. 510 U.
S., at 485.”
42 USC §1983 –
Civil Action for Deprivation of Rights
42 USC §1985 -
Conspiracy to Interfere with Civil Rights
16) “Every person who, under color of any statute, ordinance,
regulation, custom, or usage, of any State or Territory or the District of
Columbia, subjects, or causes to be subjected, any citizen of the United
States or other person within the jurisdiction thereof to the deprivation
of any rights, privileges, or immunities secured by the Constitution and
laws, shall be liable to the party injured in an action at law, suit in
equity, or other proper proceeding for redress, except that in any action
brought against a judicial officer for an act or omission taken in such
officer’s judicial capacity, injunctive relief shall not be granted unless
a declaratory decree was violated or declaratory relief was unavailable. .
.If two or more persons in any State or Territory conspire to deter, by
force, intimidation, or threat, any party or witness in any court of the
United States from attending such court, or from testifying to any matter
pending therein, freely, fully, and truthfully, or to injure such party or
witness in his person or property on account of his having so attended or
testified, or to influence the verdict, presentment, or indictment of any
grand or petit juror in any such court, or to injure such juror in his
person or property on account of any verdict, presentment, or indictment
lawfully assented to by him, or of his being or having been such juror; or
if two or more persons conspire for the purpose of impeding, hindering,
obstructing, or defeating, in any manner, the due course of justice in any
State or Territory, with intent to deny to any citizen the equal protection
of the laws, or to injure him or his property for lawfully enforcing, or
attempting to enforce, the right of any person, or class of persons, to the
equal protection of the laws. . .the party so injured or deprived may have
an action for the recovery of damages occasioned by such injury or
deprivation, against any one or more of the conspirators.” See Haddle V. Garrison et al, 525 U.S. 121
(1998).
17) Federal courts recognize blacklisting as a cause of
action. In the lawsuit Castillo v. Spiliada Maritime Corporation MV, 937 F. 2d 240,
the United State Court of Appeals for the Fifth Circuit stated that “. .
.Plaintiffs have offered substantial evidence that they were coerced into
agreeing to the settlements with threats that charges would be filed
against them with the POEA and that they would be blacklisted. As the
threats of blacklisting endangered the possibility of future employment in
their established trade, Plaintiffs reasonably could have been intimidated
into settling.” In the lawsuit Duckworth
v. Pratt & Whitney, Inc., 152 F.3d 1 (1st Cir. 1998), the United
States Court of Appeals for the First Circuit stated that “As both
Duckworth and the Secretary of Labor persuasively argue, the achievement of
these objectives would be frustrated by adopting Pratt & Whitney's
interpretation. That interpretation would permit an employer to evade the
Act by blacklisting employees who have used leave in the past or by
refusing to hire prospective employees if the employer suspects they might
take advantage of the Act.” The United States Court of Appeal's use of the
term “leave” refers to medical leave. The United States Court of Appeals
use of the term “Act” refers to the Family and Medical Act of 1993. In the
case Davis v. Paul, et al, 505
F.2d 1180, the United States Court of Appeals for the Sixth circuit stated
that “Few things are as fundamental to our legal system as the presumption
of innocence until overcome by proof of guilt beyond a reasonable doubt at
a fair trial. The dissemination of the flier in the case at bar is in the
face of the presumption of innocence, disregards the Due Process Clause and
is based on evidence that is not probative of guilt. Condemning a man to a
suspect class without a trial and on a wholly impermissible standard, as in
the case at bar, offends the very essence of the Due Process Clause, i.e.,
protection of the individual against arbitrary action. Slochower v. Board of Education, 350 U.S. 551, 559, 76 S.Ct. 637, 100 L.Ed. 692 (1956); Peters
v. Hobby, 349 U.S. 331, 351-352, 75 S.Ct. 790 (1955) (Douglas, J.,
concurring.) As said by Mr. Justice Black in his concurring opinion in Joint Anti-Fascist Refugee Committee v.
McGrath, 341 U.S. 123, 144-145, 71 S.Ct. 624, 634 (1951): 'Our basic
law, however, wisely withheld authority for resort to executive. .
.condemnations and blacklists as a substitute for imposition of legal types
of penalties by courts following trial and conviction in accordance with
procedural safeguards of the Bill of Rights.'” The United States Equal
Employment Opportunity Commission's, (EEOC) Office of Legal Counsel the
Americans with Disabilities Act of 1990 and the Family and Medical Leave
Act of 1993 overlap, and that where employees are concerned, “ADA Title II
covers all public employers without regard to the number of employees.” By
this action, Plaintiff seeks to put an end to New York State's practice of
blacklisting the Plaintiff by refusing to provide her with outpatient
psychiatric care and accommodations required to be provided by the New York
State Unified Court System as its courts are covered under Title II of the
Americans With Disabilities, and by ending the corporate defendants' use of
the media to encourage members of the not-for-profit psychiatric outpatient
community to blacklist the Plaintiff by publicly denigrating her because of
symptoms of her mental illness that were publicized by government and
corporate defendants.
Commission of
RICO Crimes
18) “Racketeering activity” means (A) any act or threat
involving murder, kidnapping, gambling, arson, robbery, bribery, extortion,
dealing in obscene matter, or dealing in a controlled substance or listed
chemical (as defined in section 102 of the Controlled Substances Act),
which is chargeable under State law and punishable by imprisonment for more
than one year; (B) any act which is indictable under any of the following
provisions of title 18, United States Code: (relating to fraud and related
activity in connection with identification documents), Section 1513
(relating to retaliating against a witness, victim, or an informant) . . .”
19) “State” means any State of the United States, the District
of Columbia, the Commonwealth of Puerto Rico, any territory or possession
of the United States, any political subdivision, or any department, agency,
or instrumentality thereof;
20) “enterprise” includes any individual, partnership,
corporation, association, or other legal entity, and any union or group of
individuals associated in fact although not a legal entity;
21) pattern of racketeering activity” requires at least two
acts of racketeering activity, one of which occurred after the effective
date of this chapter and the last of which occurred within ten years
(excluding any period of imprisonment) after the commission of a prior act
of racketeering activity.
22) Commission of RICO Crimes – “It shall be unlawful for any
person employed by or associated with any enterprise engaged in, or the
activities of which affect, interstate or foreign commerce, to conduct or
participate, directly or indirectly, in the conduct of such enterprise’s
affairs through a pattern of racketeering activity or collection of
unlawful debt.”
23) Civil Remedies for RICO Crimes – “The district courts of
the United States shall have jurisdiction to prevent and restrain
violations of section 1962 of this chapter by issuing appropriate orders,
including, but not limited to: ordering any person to divest himself of any
interest, direct or indirect, in any enterprise; imposing reasonable
restrictions on the future activities or investments of any person,
including, but not limited to, prohibiting any person from engaging in the
same type of endeavor as the enterprise engaged in, the activities of which
affect interstate or foreign commerce; or ordering dissolution or
reorganization of any enterprise, making due provision for the rights of
innocent persons.”
24) “Any person injured in his business or property by reason
of a violation of section 1962 of this chapter may sue therefor in any
appropriate United States district court and shall recover threefold the
damages he sustains and the cost of the suit, including a reasonable
attorney’s fee, except that no person may rely upon any conduct that would
have been actionable as fraud in the purchase or sale of securities to
establish a violation of Section 1962. The exception contained in the
preceding sentence does not apply to an action against any person that is
criminally convicted in connection with the fraud, in which case the
statute of limitations shall start to run on the date on which the conviction
becomes final.”
Campaign
Contributions and The Hobbs Act and Conspiracy to Deprive Plaintiff and
Gentile Constituents of Honest Services
U.S. Supreme
Court Mandate
25) “This is not to say that it is impossible for an elected official
to commit extortion in the course of financing an
election campaign. Political contributions are of course vulnerable if
induced by the use of force, violence, or fear.
The receipt of such contributions is also vulnerable under the Act as
having been taken under color of official right, but only if the payments
are made in return for an explicit promise or undertaking by the official
to perform or not to perform an official act. In such situations the
official asserts that his official conduct will be controlled by the terms
of the promise or undertaking. This is the receipt of money by an elected
official under color of official right within the meaning of the Hobbs
Act.” McCormick v. United States,
500 US 257.
26) “The requirement of a quid pro quo means that without
pretense of any entitlement to the payment, a public official violates
§1951 if he intends the payor to believe that absent payment the official
is likely to abuse his office and his trust to the detriment and injury of
the prospective payor or to give the prospective payor less favorable
treatment if the quid pro quo is not satisfied. The official and the payor
need not state the quid pro quo in express terms, for otherwise the law's
effect could be frustrated by knowing winks and nods. The inducement from
the official is criminal if it is express or if it is implied from his
words and actions, so long as he intends it to be so and the payor so
interprets it.” Evan v. United States,
112 S.Ct. 1881, 504 U.S. 255, 119 L.Ed.2d 57.
18 USC § 1951
- Interference with Commerce by Threats or Violence
27) “Whoever in any way or degree obstructs, delays, or
affects commerce or the movement of any article or commodity in commerce,
by robbery or extortion or attempts or conspires so to do, or commits or
threatens physical violence to any person or property in furtherance of a
plan or purpose to do anything in violation of this section shall be fined
under this title or imprisoned not more than twenty years, or both.”
28) “The term “extortion” means the obtaining of property from
another, with his consent, induced by wrongful use of actual or threatened
force, violence, or fear, or under color of official right.”
When Is a
Campaign Contribution a Bribe?2
29) “The Supreme Court’s guidance on the issue is thin. In
1991, it ruled that a campaign contribution could be a bribe if prosecutors
proved a quid pro quo — that the contribution was “made in return for an
explicit promise or undertaking by the official to perform or not to
perform an official act.” In a subsequent case, Justice Anthony Kennedy
said the quid pro quo need not be expressly stated.”
Criminal
Resource Manual 2404, Hobbs Act—Under Color of Official Right
30) Some courts have held that a Hobbs Act violation does not
require that the public official have de jure power to perform any official
act paid for as long as it was reasonable to believe that he/she had the de
facto power to perform the requested act. See United States v. Nedza, 880 F.2d 896,
902 (7th Cir. 1989) (victim reasonably believed state senator had the
ability to impact a local business); United
States v. Bibby, 752 F.2d 1116, 1127-28 (6th Cir. 1985); United States v. Sorrow, 732 F.2d
176, 180 (11th Cir. 1984); United
States v. Rindone, 631 F.2d 491, 495 (7th
Cir. 1980) (public official can extort money for permit beyond control of
his office, so long as victim has a reasonable belief that he could affect
issuance); United States v. Rabbitt, 583 F.2d 1014 (8th Cir. 1978), cert.
denied, 439 U.S. 1116 (1979); United
States v. Harding, 563 F.2d 299 (6th Cir. 1977), cert. denied, 434 U.S.
1062 (1978); United States v. Brown,
540 F.2d 364 (8th Cir. 1976); United
States v. Hall, 536 F.2d 313 (10th Cir.), cert. denied, 429 U.S. 919
(1976); United States v. Hathaway, 534 F.2d 386 (1st Cir.), cert. denied,
429 U.S. 819 (1976); United States v.
Mazzei, 521 F.2d 639, 643 (3rd Cir.) (en
banc), cert. denied, 423 U.S. 1014 (1975); United States v. Price, 507 F.2d 1349 (4th Cir. 1974).
31) Some courts have held that private persons who are not
themselves public officials can be convicted under this provision if they
caused public officials to perform official acts in return for payments to
the non-public official. United
States v. Margiotta, 688 F.2d 108 (2d Cir.
1982), cert. denied, 461 U.S. 913 (1983) (court upheld conviction of head
of local Republican Party under color of official right where defendant
could be said to have caused, under 18 U.S.C. §2(b), public officials to
induce a third party to pay out money); see United States v. Haimowitz, 725 F.2d
1561, 1572-73 (11th Cir.), cert. denied, 469 U.S. 1072 (1984) (private
attorney's conviction of Hobbs Act violation upheld due to complicity with
state senator); United States v.
Marcy, 777 F.Supp. 1398, 1399-400 (N.D.Ill. 1991); United
States v. Barna, 442 F.Supp.
1232 (M.D. Pa.), aff'd mem., 578 F.2d 1376 (3rd Cir.), cert. denied, 439
U.S. 862 (1978). See United States v.
McClain, 934 F.2d 822, 829-32 (7th Cir. 1991) (“we believe that, as a
general matter and with caveats as suggested here, proceeding against
private citizens on an 'official rights' theory inappropriate under the
literal and historical meanings of the Hobbs Act, irrespective of the
actual 'control' that citizen purports to maintain over governmental
activity”).
32) “The Supreme Court has held that, when an allegedly
corrupt payment masquerades as a campaign contribution, and when there is
no evidence that the corpus of the “contribution” inured to the personal
benefit of the public officer in question or was a product of force or
duress, the Hobbs Act requires proof of a quid pro quo agreement between
the contributor and the public officer. McCormick v. United States, 500
U.S. 257 (1991). However, the Court has also held that proof that a quid
pro quo agreement existed in a corruption case brought under the Hobbs Act
may be proven circumstantially.
Evans v. United States, 504 U.S. 255 (1992). This
interpretation of the dimensions of the Hobbs Act in corruption scenarios is
consistent with the parameters of the facts needed to prove the federal
crimes of bribery and gratuities under 18 U.S.C. §201.” See United States v. Brewster, 50-6 F.2d
62 (D.C. Cir. 1972), 9 U.S.A.M. §§85.101 through 85.105, supra.
Fraud Upon the
Court
33) “Whenever any officer of the court
commits fraud during a proceeding in the court, he/she is engaged in fraud
upon the court. In Bulloch v. United
States, 763 F.2d 1115, 1121 (10th Cir. 1985), the court stated “Fraud
upon the court is fraud which is directed to the judicial machinery itself
and is not fraud between the parties or fraudulent documents, false
statements or perjury. . . It is where the court or a member is corrupted
or influenced or influence is attempted or where the judge has not performed
his judicial function --- thus where the impartial functions of the court
have been directly corrupted.”
34) Fraud upon the court has been defined by the 7th Circuit
Court of Appeals to embrace that species of fraud which does, or attempts
to, defile the court itself, or is a fraud perpetrated by officers of the
court so that the judicial machinery cannot perform in the usual manner its
impartial task of adjudging cases that are presented for adjudication.” Kenner v. Commissioner of Internal Revenue,
387 F.3d 689 (1968); 7 Moore's Federal Practice, 2d ed., p.512, ¶ 60.23.
The 7th Circuit further stated: “a decision produced by fraud upon the
court is not in essence a decision at all, and never becomes final."
35) Fraud upon the court makes void the orders and judgments
of that court.
36) Plaintiff offers as persuasive authority, laws of the
State of Illinois. In Illinois law, “it is also clear and well-settled . .
.that any attempt to commit fraud upon the court vitiates the entire
proceeding. The People of the State of Illinois v. Fred E. Sterling, 357
Ill. 354; 192 N.E. 229 (1934) (“The maxim that fraud vitiates every
transaction into which it enters applies to judgments as well as to
contracts and other transactions.”); Allen
F. Moore v. Stanley F. Sievers, 336 Ill. 316; 168 N.E. 259 (1929) (“The
maxim that fraud vitiates every transaction into which it enters ...”); In re Village of Willowbrook,
37 Ill.App.2d 393 (1962) (“It is axiomatic that fraud vitiates
everything.”); Dunham v. Dunham,
57 Ill.App. 475 (1894), affirmed 162 Ill. 589
(1896); Skelly Oil Co. v. Universal Oil Products Co., 338 Ill.App. 79, 86 N.E.2d 875, 883-4 (1949); Thomas Stasel
v. The American Home Security Corporation, 362 Ill. 350; 199 N.E. 798
(1935). Under Illinois and Federal law, when any officer of the court has
committed “fraud upon the court”, the orders and judgment of that court are
void, of no legal force or effect.”
Right to
Privacy
37) The Connecticut statute forbidding use of contraceptives
violates the right of marital privacy which is within the penumbra of
specific guarantees of the Bill of Rights. Pp. 381 U. S. 481-486. The
foregoing cases suggest that specific guarantees in the Bill of Rights have
penumbras, formed by emanations from those guarantees that help give them
life and substance. See Poe v. Ullman,
367 U. S. 497, 367 U. S. 516-522 (dissenting opinion). Various guarantees
create zones of privacy. The right of association contained in the penumbra
of the First Amendment is one, as we have seen. The Third Amendment, in its
prohibition against the quartering of soldiers "in any house" in
time of peace without the consent of the owner, is another facet of that
privacy. The Fourth Amendment explicitly affirms the "right of the
people to be secure in their persons, houses, papers, and effects, against
unreasonable searches and seizures." The Fifth Amendment, in its
Self-Incrimination Clause, enables the citizen to create a zone of privacy
which government may not force him to surrender to his detriment. The Ninth
Amendment provides: "The enumeration in the Constitution, of certain
rights, shall not be construed to deny or disparage others retained by the
people." The Fourth and Fifth Amendments were described in Boyd v. United States, 116 U. S. 616,
116 U. S. 630, as protection against all governmental invasions "of
the sanctity of a man's home and the privacies of life." We recently
referred in Mapp v. Ohio, 367 U.
S. 643, 367 U. S. 656, to the Fourth Amendment as creating a "right to
privacy, no less important than any other right carefully a particularly
reserved to the people." See Beaney, The
Constitutional Right to Privacy, 1962 Sup. Ct. Rev. 212; Griswold, The
Right to be Let Alone, 55 Nw. U.L. Rev. 216 (1960) ... NAACP v. Alabama, 377 U. S. 288, 377 U.S. 307. Would we allow
the police to search the sacred precincts of marital bedrooms for telltale
signs of the use of contraceptives? The very idea is repulsive to the
notions of privacy surrounding the marriage relationship.” Griswold v. Connecticut, 381 U.S.
479 (1965).
38) According to the Health Insurance Portability and
Accountability Act of 1996's Wrongful Disclosure of Individually
Identifiable Health Information, it says that: “(a) Offense – A person who
knowingly and in violation of this part -- (1) uses or causes to be used a
unique health identifier; (2) obtains individually identifiable health
information relating to an individual; or (3) discloses individually
identifiable health information to another person, shall be punished as
provided in subsection (b). (b) Penalties – A person described in
subsection (a) shall -- (1) be fined not more than $50,000, imprisoned not
more than 1 year, or both; (2) if the offense is committed under false
pretenses, be fined not more than $100,000, imprisoned not more than 5
years, or both; and (3) if the offense is committed with intent to sell,
transfer, or use individually identifiable health information for
commercial advantage, personal gain, or malicious harm, be fined not more
than $250,000, imprisoned not more than 10 years, or both.” See United States of America v. Huping Zhou, 2:08-cr-01356-AJW-1.
National
Security Letters
39) “The Director of the Federal Bureau of Investigation, or
his designee in a position not lower than Deputy Assistant Director at
Bureau headquarters or a Special Agent in Charge in a Bureau field office
designated by the Director, may: (1) request the name, address, length of
service, and local and long distance toll billing records of a person or
entity if the Director (or his designee) certifies in writing to the wire
or electronic communication service provider to which the request is made
that the name, address, length of service, and toll billing records sought
are relevant to an authorized investigation to protect against
international terrorism or clandestine intelligence activities, provided
that such an investigation of a United States person is not conducted
solely on the basis of activities protected by the first amendment to the
Constitution of the United States; and (2) request the name, address, and
length of service of a person or entity if the Director (or his designee)
certifies in writing to the wire or electronic communication service
provider to which the request is made that the information sought is
relevant to an authorized investigation to protect against international
terrorism or clandestine intelligence activities, provided that such an
investigation of a United States person is not conducted solely upon the
basis of activities protected by the first amendment to the Constitution of
the United States.” in the stipulation and order regarding the case Doe et
al. v. Holder, et al it says: “3) Plaintiff John Doe is hereby permitted to
identify himself and his company as the recipient of the NSL that has been
the subject of this litigation. Plaintiffs ACLU and ACLU Foundation may
publicly disclose this information as well. In addition, the Government
acknowledges that plaintiffs may discuss matters and information that have
been filed without redaction on the public docket in this case; 4)
Plaintiffs are also permitted to publicly discuss plaintiff Doe's personal
background, background about his company, the services Doe generally
provided to his clients, and his type of clientele generally, including (a)
the information that is redacted in the public filing of the Third
Declaration of John Doe, dated August 21, 2009, Paragraph 1; (b) the
information that is redacted in the public filing of the Second Declaration
of John Doe, dated September 8, 2006, Paragraph 4; and (c) the information
that is redacted in the public filing of the Second Declaration of John
Doe, dated September 8, 2006, Paragraph 37. . . 6) Nothing in this
Stipulation shall affect plaintiff Doe's right and plaintiffs ACLU and ACLU
Foundation's right, if any, to petition in the future under 18 U.S.C. §
3511(b) ('or an order modifying or setting aside the nondisclosure
requirement imposed in connection with the NSL served on plaintiff Doe.” Doe, et al v. Holder, et al, 04 Civ.
2614 (VM).
“Justice Must
Satisfy the Appearance of Justice”
40) Courts have repeatedly held that positive proof of the
partiality of a judge is not a requirement, only the appearance of
partiality. Liljeberg v. Health Services Acquisition Corp.,
486 U.S. 847, 108 S.Ct. 2194 (1988) (what matters is not the reality of
bias or prejudice but its appearance); United
States v. Balistrieri, 779 F.2d 1191 (7th
Cir. 1985) (Section 455(a) “is directed against the appearance of
partiality, whether or not the judge is actually biased.”) (“Section 455(a)
of the Judicial Code, 28 U.S.C. §455(a), is not intended to protect
litigants from actual bias in their judge but rather to promote public
confidence in the impartiality of the judicial process.”
41) In Pfizer Inc. v.
Lord, 456 F.2d 532 (8th Cir. 1972), the Court stated that "It is
important that the litigant not only actually receive justice, but that he
believes that he has received justice."
42) The Supreme Court has ruled and has reaffirmed the
principle that “justice must satisfy the appearance of justice”, Levine v. United States, 362 U.S.
610, 80 S.Ct. 1038 (1960), citing Offutt v. United States, 348 U.S. 11, 14,
75 S.Ct. 11, 13 (1954).
Rights of
Crime Victims
43) It has been the Plaintiff's sad experience that the
judicial defendants' complicity with regard to implementation of the
horrible Talmudic Law of the Moser has developed in them a delusion that
has made them both arrogant and stupid, as though U.S. law is written in
Greek or Chinese, and the Plaintiff lacks the ability to either research
it, or that if she researches it, she cannot understand it. To force the
defendants to divest themselves of said delusion, Plaintiff has chosen to
copy and paste federal criminal law as it pertains to crime victims. The Plaintiff
demands that defendants recognize that the following is in English, and
Plaintiff is not a dumb schvartze. Plaintiff can
read English – legalese included.
44) Rights of Crime Victims. A crime victim has the following
rights:
a) The right to be reasonably
protected from the accused. The right to reasonable, accurate, and timely
notice of any public court proceeding or any parole proceeding, involving
the crime or of any release or escape of the accused.
b) The right not to be excluded from any
such public court proceeding, unless the court, after receiving clear and
convincing evidence, determines that testimony by the victim would be
materially altered if the victim heard other testimony at that proceeding.
c) The right to be reasonably heard at
any public proceeding in the district court involving release, plea,
sentencing, or any parole proceeding.
d) The reasonable right to confer with
the attorney for the Government in the case.
e) The right to full and timely
restitution as provided in law.
f) The right to proceedings free from
unreasonable delay.
g) The right to be treated with
fairness and with respect for the victim’s dignity and privacy.
45) 18 USC §3771 contains other rights specific to crime victims;
Plaintiff trusts, however, that defendants are sufficiently convinced on
Plaintiff's level of intelligence that she does not have waste either ink
or paper cutting and pasting the law. If even after this, the defendants
are arrogantly unconvinced, the defendants can visit http://www.law.cornell.edu/uscode/text/18/3771
after they facilitate the arrest of corrupt, lying, racist, racketeering
Jewish attorneys Allen E. Kaye, Harvey Shapiro and Jack Gladstein for their
act of fraud and aggravated identity theft by filing their fraudulent
affirmations that criminally hold “Godwin Uzamere” to be Plaintiff's
husband and the father of Plaintiff's daughter without presenting
USCIS-issued identification cards or passports for both Ehigie Edobor
Uzamere and “Godwin Uzamere.”
Continuing
Violations Doctrine
46) This Court has jurisdiction over the action pursuant to Morgan v. National Railroad Passenger
Corporation, DBA Amtrak, 232 F.3d 1008 (November 8, 2000) with regard
to the continuing violations doctrine, in which the U.S. Supreme Court
stated in its decision that “the continuing violations doctrine. . .allows
courts to consider conduct that would ordinarily be time barred "as
long as the untimely incidents represent an ongoing unlawful. . . practice.
. .The district court's reliance on Galloway was mistaken. This court has
never adopted a strict notice requirement as the litmus test for
application of the continuing violation doctrine; in fact, in Fiedler v.
UAL Corp., 218 F.3d 973 (9th Cir. 2000), we explicitly rejected such an
approach from the Fifth Circuit. See id. at 987 n.10. Fiedler examined
Berry v. Board of Sup'rs of L.S.U., 715 F.2d 971
(5th Cir. 1983), a case which involved equal pay based upon gender
discrimination, where the Fifth Circuit created a multi-factor test for
determining whether discrete acts of harassment are closely related enough
to satisfy the continuing violation theory. The Berry court's final factor,
"perhaps of most importance," asked whether the harassing act
"should trigger an employee's awareness of and duty to assert his or
her rights.” Berry, 715 F.2d at 981. We rejected the Berry analysis,
holding that test was not “applicable in determining the continuation of a
hostile environment.” Fiedler, 218 F.3d at 987 n.10.
47) In tort law, if a defendant commits a series of illegal
acts against another person, or, in criminal law, if someone commits a
continuing crime (which can be charged as a single offense), the period of
limitation begins to run from the last act in the series. In the case of Treanor v. MCI Telecommunications, Inc.,
the U.S. Court of Appeals for the Eighth Circuit explained that the
continuing violations doctrine "tolls the statute of limitations in
situations where a continuing pattern forms due to [illegal] acts occurring
over a period of time, as long as at least one
incident . . . occurred within the limitations period. In the case Douglas v. California Department of
Youth Authority, 271 F.3d 812, Dossey Douglas was denied employment by
the California Youth Authority because a vision test indicated that he was
color-blind. Douglas brought suit against CYA for
its failure to hire him under Title I of the ADA. The district court
granted summary judgment to CYA on the ground that
Douglas' claims are barred by the applicable statutes of limitations.
Douglas argued on appeal that his claims are timely under the continuing
violations doctrine because the CYA's discriminatory policy was on-going.
The U.S. Court of Appeals stated the following: “Applying the continuing
violations doctrine to these facts, we are guided by two earlier Ninth
Circuit decisions. In Domingo v. New
England Fish Co., 727 F.2d 1429 (9th Cir. 1984), amended 742 F.2d 520
(9th Cir. 1984), we considered a class action suit against a cannery
operator involving allegations of discrimination on the
basis of race in hiring and promotions. The plaintiffs argued that
their claims were saved from the time bar by the fact that the
discriminatory hiring and promotion polices continued until the plaintiffs brought suit. Id. at 1443. We required the plaintiffs to
demonstrate that because of the discriminatory policy, they were either
discriminated against or “exposed to discrimination” during the limitations
period. Id. Almost a decade later, we again addressed the issue whether a
case was timely under a continuing violations theory based on an alleged
systemic discrimination in hiring. EEOC
v. Local 350, Plumbers and Pipefitters, 998 F.2d 641, 643 (9th Cir.
1993). The EEOC filed an Age Discrimination in Employment Act suit on
behalf of union members who were excluded from hiring lists on the ground that they received pension benefits. Id.
at 643. We noted that the union's policy that excluded retirees from the
hiring lists applied to the class members as early as 1984, five years
earlier. Id. at 644. We found that the action was not barred by the
relevant statute of limitations, because the discriminatory policy
prohibiting retirees from joining the hiring lists continued. Id. (“Here,
Local 350's allegedly discriminatory policy was in effect when [the
plaintiff] first encountered [the policy] in 1984 and remains in force
today. Thus, under the continuing violations doctrine, relief for [the
plaintiff] is not barred.”). Although we did not cite Domingo in our
analysis in Local 350, the two decisions are consistent. In Local 350, the
plaintiffs, as union members, continued to be “exposed” to the
discriminatory hiring policies of the union.” The U.S. Court of Appeals for
the Ninth Circuit finally decided that “. . .With respect to the ADA claim.
. .We REVERSE the district court's grant of summary judgment on both the
Rehabilitation Act and ADA claims because we conclude that the claims were
timely filed under the continuing violations doctrine."
Code of
Conduct for Judges and Attorneys – Federal Code of Conduct for Judges
48) A judge should take appropriate action upon learning of
reliable evidence indicating the likelihood that a judge’s conduct contravened
this code, or a lawyer violated applicable rules of professional conduct.
49) A judge shall disqualify himself or herself in a
proceeding in which the judge’s impartiality might reasonably be
questioned, including but not limited to instances in which . . . the judge
or the judge’s spouse, or a person related to either within the third
degree of relationship, or the spouse of such a person is . . .a party to
the proceeding, or an officer, director, or trustee of a party.
Code of
Conduct for New York State Judges
50) A judge who receives information indicating a substantial
likelihood that another judge has committed a substantial violation of this
Part shall take appropriate action.
51) A judge who receives information indicating a substantial
likelihood that a lawyer has committed a substantial violation of the Code
of Professional Responsibility shall take appropriate action.
New York
Lawyer's Code of Professional Responsibility
52) A lawyer possessing knowledge, (1) not protected as a
confidence or secret, or (2) not gained in the lawyer's capacity as a
member of a bona fide lawyer assistance or similar program or committee, of
a violation of DR 1-102 [1200.3] that raises a substantial question as to
another lawyer's honesty, trustworthiness or fitness as a lawyer shall
report such knowledge to a tribunal or other authority empowered to
investigate or act upon such violation.
53) A lawyer possessing knowledge or evidence, not protected
as a confidence or secret, concerning another lawyer or a judge shall
reveal fully such knowledge or evidence upon proper request of a tribunal
or other authority empowered to investigate or act upon the conduct of
lawyers or judges.
54) A lawyer shall not present, participate in presenting, or threaten
to present criminal charges solely to obtain an advantage in a civil
matter.
H.R. 40
Commission to
Study Reparation Proposals for African-Americans Act (as it concerns the
African Holocaust/The Maafa)
55) Commonly known as the “African Reparations Bill”, it was
promulgated by African-American Congressman John Conyers “To acknowledge
the fundamental injustice, cruelty, brutality, and inhumanity of slavery in
the United States and the 13 American colonies between 1619 and 1865 and to
establish a commission to examine the institution of slavery, subsequently
de jure and de facto racial and economic discrimination against
African-Americans, and the impact of these forces on living
African-Americans, to make recommendations to the Congress on appropriate
remedies, and for other purposes.”
Implied Cause
of Action
56) “For the reasons set forth below, I am
of the opinion that federal courts do have the power to award
damages for violation of 'constitutionally protected interests' and I agree
with the Court that a traditional judicial remedy such as damages is
appropriate to the vindication of the personal interests protected by the
Fourth Amendment.” See Bivens v. Six Unknown Named Agents of Federal
Bureau of Narcotics, 403 U.S. 388, 91 S. Ct. 1999; 29 L. Ed. 2D 619;
1971 U.S. Lexis 23; at Correctional
Services Corporation, v. John E. Malesko, it
says: “In the decade following Bivens, we recognized an implied damages
remedy under the Due Process Clause of the Fifth Amendment, Davis v. Passman, 442 U. S. 228 (1979), and the Cruel and
Unusual Punishment Clause of the Eighth Amendment, Carlson v. Green, 446 U.
S. 14 (1980). In both Davis and Carlson, we applied the core holding of
Bivens, recognizing in limited circumstances a claim for money damages against
federal officers who abuse their constitutional authority. In Davis, we
inferred a new right of action chiefly because the plaintiff lacked any
other remedy for the alleged constitutional deprivation. 442 U. S., at 245
(For Davis, as for Bivens, it is damages or nothing). In Carlson, we
inferred a right of action against individual prison officials where the
plaintiff's only alternative was a Federal Tort Claims Act (FTCA) claim
against the United States. 446 U. S., at 18. 23. We reasoned that the threat
of suit against the United States was insufficient to deter the
unconstitutional acts of individuals. Id., at 21. (Because the Bivens
remedy is recoverable against individuals, it is a more effective deterrent
than the FTCA remedy). We also found it crystal clear that Congress
intended the FTCA and Bivens to serve as parallel and complementary sources
of liability. 446 U.S., at 19.20...In 30 years of Bivens jurisprudence we
have extended its holding only twice, to provide an otherwise nonexistent
cause of action against individual officers alleged to have acted
unconstitutionally, or to provide a cause of action for a plaintiff who
lacked any alternative remedy for harms caused by an individual officers’
unconstitutional conduct.”
Purpose of
Plaintiff's Action
57) By this action, Plaintiff seeks to put an end to
Defendants' commission of misprision of felony, 18 USC §4; fraud, 18 USC
§1001; identity theft, 18 USC §1028; aggravated identity fraud, 18 USC
§1028A; deprivation of rights under color of law (including being
kidnapped, unlawfully imprisoned and blacklisted), 18 USC §242/42 USC
§1985; extortion, 18 USC §872§, blackmail, 18 USC §873; violation of Title
II of the Americans With Disabilities Act; violation of the Federal
Rehabilitation Act of 1973; violation of the Civil Rights Act of 1964,
Title VI, §601; violation of the Free Speech Clause of the First Amendment;
violation of the Establishment Clause of the First Amendment; violation of
the Petition Clause of the First Amendment; violation of the Due Process
Clause of the Fifth and Fourteenth Amendments; violation of the Notice
Clause of the Sixth Amendment; violation of the Assistance of Counsel
Clause of the Sixth Amendment; violation of Plaintiff's right of privacy
with regard to the illegal dissemination of her psychiatric records,
Plaintiff marriage history, Plaintiff married name, and the non-content
information associated with Plaintiff's internet and telephone accounts;
violation of the Equal Protection Clause of the Fourteenth Amendment, intentional
misuse of national security letters (NSLs) and violation of the Hobbs Act.
58) Furthermore, Plaintiff's also seeks to expose that
Defendant U.S. Department of Homeland Security has had knowledge of the
correct identity and has been in possession of the identification documents
for Defendant Ehigie Edobor Uzamere for well over thirty (30) years.
Defendant the United States of America, along with the rest of the
Defendants, owed Plaintiff and her children the duty to use the
aforementioned documentation regarding Defendant Ehigie Edobor Uzamere's
identity to protect Plaintiff and her children from being victims of fraud,
immigration fraud, aggravated identity theft and victims of Plaintiff's
inability to obtain spousal and children support based on Plaintiff and her
daughter having the legal right to bear Defendant Ehigie Edobor Uzamere's
correct name. However, rather than comply with the law, the Defendants, in particular, the Jewish Defendants, engaged in a
course of conduct that violated Plaintiff rights and the rights of her
daughter, Tara, for the sole purpose of preventing Plaintiff from filing
complaints against hateful, racist, dishonest, Jewish immigration attorneys
Allen E. Kaye, Harvey Shapiro and Jack Gladstein. Defendants' criminal
conduct deprived them then, and continues to
deprive Plaintiff and her family of the right to bear Defendant Ehigie
Edobor Uzamere correct African name, and continues to condemn Plaintiff and
her family to the same deprivation of the knowledge of African bloodline
indicators that racist Jews and racist white Christians forced upon
Plaintiff's African ancestors.
Issues with Regard to Claims of Sovereign Immunity
59) The Eleventh Amendment of the U.S. Constitution says that
“The Judicial power of the United States shall not be construed to extend
to any suit in law or equity, commenced or prosecuted against one of the
United States by Citizens of another State, or by Citizens or Subjects of
any Foreign State.” This means that generally, a sovereign state cannot commit
a legal wrong and is immune from civil suit or criminal prosecution. This
legal doctrine, however, is refuted when a state engages in conduct that
violates U.S. Constitutional law – especially the Equal Protection Clause
of the Fourteenth Amendment.
60) In the U.S. Supreme Court case
United States vs. Georgia, et al, quoting verbatim:
“Goodman,
petitioner in No. 04–1236, is a paraplegic who sued respondent state
defendants and others, challenging the conditions of his confinement in a
Georgia prison under, inter alia, 42 U. S. C. §1983 and Title II of the
Americans with Disability Act of 1990. As relevant here, the Federal
District Court dismissed the §1983 claims because Goodman’s allegations
were vague and granted respondents' summary judgment on the Title II money
damages claims because they were barred by state sovereign immunity. The
United States, petitioner in No. 04–1203, intervened on appeal. The
Eleventh Circuit affirmed the District Court’s judgment as to the Title II
claims, but reversed the §1983 ruling, finding that Goodman had alleged
facts sufficient to support a limited number of Eighth Amendment claims
against state agents and should be permitted to amend his complaint. This
Court granted certiorari to decide the validity of Title II’s abrogation of
state sovereign immunity.
61)Justice
Scalia, giving the opinion of the Court, stated the following:
“We consider
whether a disabled inmate in a state prison may sue the State for money damages
under Title II of the Americans with Disabilities Act of 1990 (ADA), 104
Stat. 337, as amended, 42 U.S.C. § 12131 et seq. (2000 ed. and Supp. II).
Title II of
the ADA provides that “no qualified individual with a disability shall, by
reason of such disability, be excluded from participation in or be denied
the benefits of the services, programs, or activities of a public entity,
or be subjected to discrimination by any such entity.” §12132 (2000 ed.). A
“ ‘qualified individual with a disability’ ” is defined as “an individual
with a disability who, with or without reasonable modifications to rules,
policies, or practices, the removal of architectural, communication, or
transportation barriers, or the provision of auxiliary aids and services,
meets the essential eligibility requirements for the receipt of services or
the participation in programs or activities provided by a public entity.”
§12131(2). The Act defines “ ‘public entity’ ” to
include “any State or local government” and “any department, agency, … or
other instrumentality of a State,” §12131(1). We have previously held that
this term includes state prisons. See Pennsylvania Dept. of Corrections v. Yeskey, 524 U.S. 206, 210 (1998). Title II authorizes
suits by private citizens for money damages against public entities that
violate §12132. See 42 U.S.C. §12133 (incorporating by reference 29 U.S.C.
§ 794a). . .
Once Goodman’s
complaint is amended, the lower courts will be best situated to determine
in the first instance, on a claim-by-claim basis, (1) which aspects of the
State’s alleged conduct violated Title II; (2) to what extent such
misconduct also violated the Fourteenth Amendment; and (3) insofar as such
misconduct violated Title II but did not violate the Fourteenth Amendment,
whether Congress’s purported abrogation of sovereign immunity as to that
class of conduct is nevertheless valid. The judgment of the Eleventh
Circuit is reversed, and the suit is remanded for further proceedings
consistent with this opinion.”
62)In United
States vs. Georgia, et al, The U.S. Supreme Court held that a state
abrogates sovereign immunity when it violates both Title II, ADA and the
Fourteenth Amendment. The decision stated:
“Goodman,
petitioner in No. 04-1236, is a paraplegic who sued respondent state defendants
and others, challenging the conditions of his confinement in a Georgia
prison under, inter alia, 42 U.S.C. §1983 and Title II of the Americans
with Disability Act of 1990. As relevant here, the Federal District Court
dismissed the §1983 claims because Goodman's allegations were vague, and granted respondents summary judgment on the
Title II money damages claims because they were barred by state sovereign
immunity. The United States, petitioner in No. 04-1203, intervened on
appeal. The Eleventh Circuit affirmed the District Court's judgment as to
the Title II claims, but reversed the §1983 ruling, finding that Goodman
had alleged facts sufficient to support a limited number of Eighth
Amendment claims against state agents and should be permitted to amend his
complaint. This Court granted certiorari to decide the validity of Title
II's abrogation of state sovereign immunity.
Held: Insofar
as Title II creates a private cause of action for damages against States
for conduct that actually violates the Fourteenth
Amendment, Title II validly abrogates state sovereign immunity. Pp. 5-8.
Because this
Court assumes that the Eleventh Circuit correctly held that Goodman had
alleged actual Eighth Amendment violations for purposes of §1983, and
because respondents do not dispute Goodman's claim that this same conduct
violated Title II, Goodman's Title II money damages claims were evidently
based, at least in part, on conduct that independently violated §1 of the
Fourteenth Amendment. No one doubts that §5 grants Congress the power to
enforce the Fourteenth Amendment's provisions by creating private remedies
against the States for actual violations of those provisions. This includes
the power to abrogate state sovereign immunity by authorizing private suits
for damages against the States. Thus, the Eleventh Circuit erred in
dismissing those of Goodman's claims based on conduct that violated the
Fourteenth Amendment.
63)Plaintiff
holds that, based on the above, government Defendants' violation of
Plaintiff's Fifth and Fourteenth Amendment right to due process, Fourteenth
Amendment right to equal protection under the law as an African American
citizen who is mentally disabled is an abrogation of their sovereign
immunity, such that Plaintiff's action rises to the level of an action in
the manner of Bivens v. Six Unknown Named Agents, 403 U.S. 388 (1971) for
all defendants who are natural persons. Defendants who are natural person
are either attorneys or represented by attorneys; it should not be
difficult for Defendants to understand the concept of abrogation of
sovereign immunity.
Jurisdiction
and Venue
64)This Court
has jurisdiction over this action pursuant to 28 U.S.C. §1331, federal
question, which states that “The district courts shall have original
jurisdiction of all civil actions arising under the Constitution, laws, or
treaties of the United States.”
65)This Court has jurisdiction over this
action pursuant to 28 U.S.C. 1343, Civil Rights and elective franchise,
which states that “(a) The district courts shall have original jurisdiction
of any civil action authorized by law to be commenced by any person: (1) To
recover damages for injury to his person or property, or because of the
deprivation of any right or privilege of a citizen of the United States, by
any act done in furtherance of any conspiracy mentioned in section 1985 of
Title 42; (2) To recover damages from any person who fails to prevent or to
aid in preventing any wrongs mentioned in section 1985 of Title 42 which he
had knowledge were about to occur and power to prevent; (3) To redress the
deprivation, under color of any State law, statute, ordinance, regulation,
custom or usage, of any right, privilege or immunity secured by the
Constitution of the United States or by any Act of Congress providing for
equal rights of citizens or of all persons within the jurisdiction of the
United States. . .”
66)Declaratory
and injunctive relief are sought against all Defendants under 28 U.S.C.
§2201(a), Creation of remedy, which states that “In a case of actual
controversy within its jurisdiction. . .any court of the United States,
upon the filing of an appropriate pleading, may declare the rights and
other legal relations of any interested party seeking such declaration,
whether or not further relief is or could be sought. Any such declaration
shall have the force and effect of a final judgment or decree and shall be
reviewable as such.”
67)Venue has its basis in 28 USC
§1404(a)(c), that states:
“For the
convenience of parties and witnesses, in the interest of justice, a district
court may transfer any civil action to any other district or division where
it might have been brought or to any district or division to which all
parties have consented. . . A district court may order any civil action to
be tried at any place within the division in which it is pending.”
68)28 USC
§455(b)(5)(i) says:
“He shall also
disqualify himself in the following circumstances: He or his spouse, or a
person within the third degree of relationship to either of them, or the
spouse of such a person: Is a party to the proceeding, or an officer,
director, or trustee of a party.”
69)Plaintiff
states that based on 28 USC §455(b)(5)(i), all of
the judges employed by the Eastern District of New York, the Southern
District of New York and the U.S. Court of Appeals for the Second Circuit
are defendants in Plaintiff's lawsuit, based on Defendants' commission of
18 USC §4, misprision of felony, and their criminal participation in a
religiously-oriented racket, run by a majority-Jewish judiciary, that
enforces the Talmudic doctrine Law of the Moser by not prosecuting Jews who
violate civil or criminal law.
70)28 USC
§455(b)(1) says:
He shall also
disqualify himself in the following circumstances: Where he has a personal
bias or prejudice concerning a party, or personal knowledge of disputed
evidentiary facts concerning the proceeding. . .”
71)Plaintiff
states that based on 28 USC §455 (b)(1), no judge employed by the for the
Northern District of New York and the for the Western District of New York
can render a decision of Plaintiff's lawsuit because Plaintiff cannot
appeal her lawsuit to judges against whom she has filed this lawsuit.
Plaintiff has deliberately cut off the federal judiciary in the entire
State of New York because it is corrupt. Plaintiff's reliance on 28 USC
§1404(a) has its entire basis on Jew-biased corruption.
Lawsuit
History
72)In most of
the lawsuits that Plaintiff presented to Defendant Judge Nicholas Garaufis,
he included a FRCP-based memorandum in his judgment:
a)On March 27, 2007, the Honorable Lois
Bloom, Magistrate Judge, working with Defendant Nicholas G. Garaufis,
rendered her Memorandum and Order regarding the lawsuit Cheryl D. Uzamere
vs. New York City Housing Authority, 07-CV-1194 (NGG) (LB). Judge Bloom remanded Plaintiff's complaint to the Civil Court of the
City of New York pursuant to 28 USC §1447(c) because the District Court
lacked subject matter jurisdiction. Plaintiff further states that Plaintiff
will not question the veracity of this case's decision with
regard to any act of fraud upon the court by and Defendant Bloom and
Defendant Garaufis.
b)On July 6, 2007, Defendant Nicholas G.
Garaufis rendered his Memorandum and Order regarding the lawsuit Cheryl D.
Uzamere vs. John Doe, et al. , 07-CV-2471 (NGG). Judge Garaufis dismissed
Plaintiff's complaint because the court lacked subject matter jurisdiction
pursuant to Fed. R. Civ. P. 12(h)(3). Plaintiff further states that she
will not question the veracity of this case's decision with
regard to any act of fraud upon the court by Defendant Bloom and
Defendant and Defendant Garaufis.
c)On April 9,
2008, Defendant Garaufis rendered his Memorandum and Order regarding the
lawsuit Cheryl D. Uzamere v. George W. Bush, et al. When Defendant Judge
Garaufis dismissed Plaintiff's lawsuit, he referenced Plaintiff's previous
lawsuit Cheryl D. Uzamere vs. John Doe, et al. ,
07-CV-2471, and that the previous lawsuit was dismissed because the court
lacked subject matter jurisdiction pursuant to Fed. R. Civ. P. 12(h)(3).
However, Defendant Judge Nicholas G. Garaufis did not reference the FRCP in
dismissing Cheryl D. Uzamere v. George W. Bush, et al. The decision
rendered on this case was an act of racketeering because it was an act of
obstruction of justice. It was a clear act of fraud upon the court,
designed to: 1) advance the Talmudic doctrine Law of the Moser; 2) trick
Plaintiff into believing that a res judicata determination – a purely civil
adjudicative function – was a permanent and final determination to nullify
and render harmless corrupt Jewish attorneys Allen E. Kaye's, Harvey
Shapiro's, Jack Gladstein's, Mortimer Zuckerman's
and Scott Shifrel's commission of aggravated
identity theft – a wrongful act for which the correct criminal adjudicative
function of double jeopardy was never attached because the crime was never
tried; and, 3) Defendant Garaufis' and Defendant Bloom's commission of
misprision of felony, racketeering, obstruction of justice, criminal
facilitation of aggravated identity theft and fraud upon the court as well.
The decision of this case is null and void. Plaintiff will no longer
tolerate any more of the corrupt, racist, racketeering, justice-obstructing
shenanigans of the Jewish defendants.
d)On April 7,
2009, Defendant Sands rendered his Memorandum and Order regarding the
lawsuit Uzamere vs. Kaye, et al, 09-cv-3506 dismissing Plaintiff's lawsuit.
The decision rendered on this case was an act of racketeering because it
was an act of obstruction of justice. It was also a clear act of fraud upon
the court, designed to: 1) advance the Talmudic doctrine Law of the Moser;
2) trick Plaintiff into believing that a res judicata determination – a
purely civil adjudicative function – was a permanent and final
determination to nullify and render harmless corrupt Jewish attorneys Allen
E. Kaye's, Harvey Shapiro's, Jack Gladstein's,
and Mortimer Zuckerman's and Scott Shifrel's
commission of aggravated identity theft – a wrongful act for which the
correct criminal adjudicative function of double jeopardy was never
attached because the crime was never tried; and, 3) Defendant Sands'
commission of misprision of felony, obstruction of justice, criminal
facilitation of aggravated identity theft and fraud upon the court as well.
The decision of this case is null and void. Plaintiff will no longer
tolerate any more of the justice-obstructing shenanigans of the Jewish
defendants.
e)On July 22, 2009, Defendants Judge
Parker, Judge Barrington and Judge Cedarbaum
dismissed Plaintiff's appeal, referring to it as frivolous. The mandate was
issued on November 3, 2009. The decision rendered on this case was an act
of racketeering because it was an act of obstruction of justice. It was
also a clear act of fraud upon the court, designed to: 1) advance the
Talmudic doctrine Law of the Moser; 2) trick Plaintiff into believing that
a res judicata determination – a purely civil adjudicative function – was a
permanent and final determination to nullify and render harmless corrupt
Jewish attorneys Allen E. Kaye's, Harvey Shapiro's, Jack Gladstein's, Mortimer Zuckerman's and Scott Shifrel's commission of aggravated identity theft – a
wrongful act for which the correct criminal adjudicative function of double
jeopardy was never attached because the crime was never tried; and, 3)
Defendant Garaufis' and Defendant Bloom's commission of misprision of
felony, obstruction of justice, criminal facilitation of aggravated
identity theft and fraud upon the court as well. The decision of this case
is null and void. Plaintiff will no longer tolerate any more of the
corrupt, racist, racketeering, justice-obstructing shenanigans of the
Jewish defendants.
f)On August 11, 2009, Defendant Nicholas
G. Garaufis rendered his memorandum-lacking Order regarding the lawsuit
Cheryl D. Uzamere v. The State of New York, et al 09-CV-2703 (NGG). Judge
Garaufis dismissed Plaintiff's complaint without prejudice to give
Plaintiff a chance to produce proof of her allegations regarding her having
been falsely arrested by the Metropolitan Transit Authority's Police
Department. Plaintiff further states that she will not question the
veracity of this case's decision with regard to
any act of fraud upon the court by Defendant Bloom and Defendant and
Defendant Garaufis.
.g)On October
21, 2009, Defendant Garaufis rendered his Memorandum and Order regarding
the lawsuit Cheryl D. Uzamere v. The United States Postal Service
09-CV-3709 (NGG). Defendant Judge Garaufis dismissed Plaintiff's complaint
based on lack of subject matter jurisdiction, pursuant to Fed. R. Civ. P.
12(h)(3). The decision rendered on this case was an act of racketeering
because it was an act of obstruction of justice. It was a clear act of
fraud upon the court, designed to: 1) advance the Talmudic doctrine Law of
the Moser; 2) trick Plaintiff into believing that a res judicata determination
– a purely civil adjudicative function – was a permanent and final
determination to nullify and render harmless corrupt Jewish attorneys Allen
E. Kaye's, Harvey Shapiro's, Jack Gladstein's,
and Mortimer Zuckerman's and Scott Shifrel's
commission of aggravated identity theft – a wrongful act for which the
correct criminal adjudicative function of double jeopardy was never
attached because the crime was never tried; and, 3) Defendant Garaufis' and
Defendant Bloom's commission of obstruction of justice, criminal
facilitation of aggravated identity theft and fraud upon the court as well.
The decision of this case is null and void. Plaintiff will no longer
tolerate any more of the corrupt, racist, racketeering, justice-obstructing
shenanigans of the Jewish defendants.
h)On August 16,
2010, Plaintiff filed lawsuit 2010-cv-555 with the U.S. Court of Claims,
and that said lawsuit assigned to Defendant judge Christine O.C. Miller.
Plaintiff alleges that she provided Defendant Miller with irrefutable
evidence of Allen E. Kaye's, Harvey Shapiro's, Jack Gladstein's,
Mortimer Zuckerman's and Scott Shifrel's
commission of aggravated identity theft, and that Defendant Miller
disobeyed 18 USC §4 by failing to file a criminal complaint against the aforementioned Jewish attorneys, Mortimer Zuckerman and
Scott Shifrel. The decision rendered on this case
was an act of racketeering because it was an act of obstruction of justice.
It was also a clear act of fraud upon the court, designed to: 1) advance
the Talmudic doctrine Law of the Moser; 2) trick Plaintiff into believing
that a res judicata determination – a purely civil adjudicative function –
was a permanent and final determination to nullify and render harmless
corrupt Jewish attorneys Allen E. Kaye's, Harvey Shapiro's, Jack Gladstein's, and Mortimer Zuckerman's and Scott Shifrel's commission of aggravated identity theft – a
wrongful act for which the correct criminal adjudicative function of double
jeopardy was never attached because the crime was never tried. The decision
of this case is null and void. Plaintiff will no longer tolerate any more
of the corrupt, racist, racketeering, justice-obstructing shenanigans of
the Jewish defendants.
i)On August 30, 2010, Plaintiff filed
lawsuit 2010-cv-585 with the U.S. Court of Claims, and that said lawsuit
assigned to Defendants Nancy B. Firestone and John P. Wiese of the U.S.
Court of Claims. Plaintiff alleges that she provided Defendants Firestone
and Wiese with irrefutable evidence of Allen E. Kaye's, Harvey Shapiro's
and Jack Gladstein's commission of aggravated
identity theft, and that Defendants Firestone and Wiese disobeyed 18 USC §4
by failing to file a criminal complaint against the aforementioned
Jew attorneys. The decision rendered on this case was an act of
racketeering because it was an act of obstruction of justice. It was also a
clear act of fraud upon the court, designed to: 1) advance the Talmudic
doctrine Law of the Moser; 2) trick Plaintiff into believing that a res
judicata determination – a purely civil adjudicative function – was a
permanent and final determination to nullify and render harmless corrupt
Jewish attorneys Allen E. Kaye's, Harvey Shapiro's, Jack Gladstein's, and Mortimer Zuckerman's and Scott Shifrel's commission of aggravated identity theft – a
wrongful act for which the correct criminal adjudicative function of double
jeopardy was never attached because the crime was never tried. The decision
of this case is null and void. Plaintiff will no longer tolerate any more
of the corrupt, racist, racketeering, justice-obstructing shenanigans of
the Jewish defendants.
j)On September 1, 2010, Plaintiff filed
lawsuit 2010-cv-591 with the U.S. Court of Claims, and that said lawsuit
was assigned to Defendant judge Christine O.C. Miller of the U.S. Court of
Claims. Plaintiff alleges that she provided Defendant Miller with
irrefutable evidence of Allen E. Kaye's, Harvey Shapiro's and Jack Gladstein's commission of aggravated identity theft,
and that Defendant Miller disobeyed 18 USC §4 by failing to file a criminal
complaint against the aforementioned Jewish
attorneys. The decision rendered on this case was an act of racketeering
because it was an act of obstruction of justice. It was also a clear act of
fraud upon the court, designed to: 1) advance the Talmudic doctrine Law of
the Moser; 2) trick Plaintiff into believing that a res judicata
determination – a purely civil adjudicative function – was a permanent and
final determination to nullify and render harmless corrupt Jewish attorneys
Allen E. Kaye's, Harvey Shapiro's, Jack Gladstein's,
and Mortimer Zuckerman's and Scott Shifrel's
commission of aggravated identity theft – a wrongful act for which the
correct criminal adjudicative function of double jeopardy was never
attached because the crime was never tried. The decision of this case is
null and void. Plaintiff will no longer tolerate any more of the corrupt,
racist, racketeering, justice-obstructing shenanigans of the Jewish
defendants.
k)With regard to the lawsuit that Plaintiff
filed against Defendant New York State on or around January 11, 2011,
Defendant Scuccimarra's decision was an act of
racketeering because it was an act of obstruction of justice. It was also a
clear act of fraud upon the court, designed to 1) advance the Talmudic
doctrine Law of the Moser; and, 2) trick Plaintiff into believing that a
res judicatadetermination – a purely civil
adjudicative function – was a permanent and final determination to nullify
and render harmless corrupt Jewish attorneys Allen E. Kaye's, Harvey
Shapiro's, Jack Gladstein's, and Mortimer
Zuckerman's and Scott Shifrel's commission of
aggravated identity theft – a wrongful act for which the correct criminal
adjudicative function of double jeopardy was never attached because the
crime was never tried. The decision
of this case is null and void. Plaintiff will no longer tolerate any more
of the corrupt, racist, racketeering, justice-obstructing shenanigans of
the Jewish defendants.
l)With regard
to the lawsuit that Plaintiff filed against Defendants Gerstein, Schack and
Sunshine on or around January 19, 2011, Defendant Klonick's
decision was an act of racketeering because it was an act of obstruction of
justice. It was also a clear act of fraud upon the court, designed to 1)
advance the Talmudic doctrine Law of the Moser; 2) trick Plaintiff into
believing that a res judicatadetermination – a
purely civil adjudicative function – was a permanent and final
determination to nullify and render harmless corrupt Jewish attorneys Allen
E. Kaye's, Harvey Shapiro's, Jack Gladstein's, and
Mortimer Zuckerman's and Scott Shifrel's
commission of aggravated identity theft – a wrongful act for which the
correct criminal adjudicative function of double jeopardy was never
attached because the crime was never tried. The decision of this case is
null and void. Plaintiff will no longer tolerate any more of the corrupt,
racist, racketeering, justice-obstructing shenanigans of the Jewish
defendants.
m)With regard
to the lawsuit that Plaintiff filed against Defendants Kaye, Shapiro and
Gladstein, Defendant Klonick's decision was an
act of racketeering because it was an act of obstruction of justice. It was
also a clear act of fraud upon the court, designed to 1) advance the
Talmudic doctrine Law of the Moser; 2) trick Plaintiff into believing that
a res judicata determination – a purely civil adjudicative function – was a
permanent and final determination to nullify and render harmless corrupt
Jewish attorneys Allen E. Kaye's, Harvey Shapiro's, Jack Gladstein's, Mortimer Zuckerman's and Scott Shifrel's commission of aggravated identity theft – a
wrongful act for which the correct criminal adjudicative function of double
jeopardy was never attached because the crime was never tried. The decision
of this case is null and void. Plaintiff will no longer tolerate any more
of the corrupt, racist, racketeering, justice-obstructing shenanigans of
the Jewish defendants.
n)In June, 2011, Plaintiff filed the
lawsuit Uzamere v. Cuomo, et al, 11-cv-2831 with the for the Eastern
District of New York.
o)On or around
June 22, 2011, Defendant Garaufis engaged in an act of racketeering,
obstruction of justice and criminal facilitation of aggravated identity
theft by rendering an FRCP-lacking, memorandum-lacking decision regarding
Uzamere vs. Cuomo, et al, 11-CV-2831 for the sole purpose of: 1) advancing
the Talmudic doctrine Law of the Moser; 2) not filing a criminal complaint
against corrupt, dishonest, lying, racketeering, racist Jewish immigration
attorneys Allen E. Kaye, Harvey Shapiro, Jack Gladstein, Mortimer Zuckerman
and Scott Shifrel for their fraudulent commission
of aggravated identity theft; 3) trick Plaintiff into believing that a res
judicata determination – a purely civil adjudicative function – was a
permanent and final determination to nullify and render harmless corrupt
Jewish attorneys Allen E. Kaye's, Harvey Shapiro's, Jack Gladstein's, Mortimer Zuckerman's and Scott Shifrel's commission of aggravated identity theft – a
wrongful act for which the correct criminal adjudicative function of double
jeopardy was never attached because the crime was never tried; and, 4) his
own and Defendant Bloom's commission misprision of felony, racketeering,
obstruction of justice, criminal facilitation of aggravated identity theft
and fraud upon the court as well. Also, Plaintiff alleges that during the
end of June, beginning of July, 2011, Defendant Garaufis, “John Doe” #1 of
Defendant FBI-New York, “John Doe” #2, “John Doe” #3, “Jane Doe” of the
U.S. Marshals Service of the Eastern District of New York, Denis P. McGowan
of Defendant the U.S. Homeland Security conspired with Jonathan D.
Schwartz, Executive Vice President and General Counsel for Cablevision,
Inc. to receive an NSL for the sole purpose of tracking telephone calls
made by the Plaintiff and to use the non-content information of said phone
calls to blackmail Plaintiff by accusing her of crimes that she did not
commit, thereby frightening Plaintiff into complying not to file further
actions against corrupt Jewish attorneys Allen E. Kaye, Harvey Shapiro and
Jack Gladstein.
p)On or around June 22, 2011, Defendant
Garaufis rendered a memorandum-lacking, FRCP-lacking decision regarding the
lawsuit Uzamere v. Cuomo, et al. 11-2831-cv. The decision rendered on this
case was an act of racketeering because it was an act of obstruction of
justice. It was a clear act of fraud upon the court, designed to: 1)
advance the Talmudic doctrine Law of the Moser; 2) trick Plaintiff into
believing that a res judicata determination – a purely civil adjudicative
function – was a permanent and final determination to nullify and render
harmless corrupt Jewish attorneys Allen E. Kaye's, Harvey Shapiro's, Jack Gladstein's, and Mortimer Zuckerman's and Scott Shifrel's commission of aggravated identity theft – a
wrongful act for which the correct criminal adjudicative function of double
jeopardy was never attached because the crime was never tried. and, and
Defendant Garaufis' and Defendant Bloom's commission of obstruction of
justice, criminal facilitation of aggravated identity theft and fraud upon
the court as well. The decision of this case is null and void. Plaintiff
will no longer tolerate any more of the corrupt, racist, racketeering,
justice-obstructing shenanigans of the Jewish defendants.
q)On November 28, 2011, based on
information and belief, Defendants Judge Raggi, Judge Carney and Judge Kahn
rendered a decision regarding the lawsuit Uzamere v. Cuomo, et al.,
11-2713-cv ordering that Plaintiff's motions be denied and Plaintiff's
appeal be dismissed because it lacks an arguable basis in law or fact. The
mandate was issued on December 22, 2011. The decision rendered on this case
was an act of racketeering because it was an act of obstruction of justice.
It was also a clear act of fraud upon the court, designed to: 1) advance
the Talmudic doctrine Law of the Moser; 2) trick Plaintiff into believing
that a res judicata determination – a purely civil adjudicative function –
was a permanent and final determination to nullify and render harmless
corrupt Jewish attorneys Allen E. Kaye's, Harvey Shapiro's, Jack Gladstein's, and Mortimer Zuckerman's and Scott Shifrel's commission of aggravated identity theft – a
wrongful act for which the correct criminal adjudicative function of double
jeopardy was never attached because the crime was never tried; and, 3)
Defendant Garaufis' and Defendant Bloom's commission of misprision of
felony, obstruction of justice, criminal facilitation of aggravated
identity theft and fraud upon the court as well. The decision of this case
is null and void. Plaintiff will no longer tolerate any more of the
corrupt, racist, racketeering, justice-obstructing shenanigans of the
Jewish defendants. Also, from 2009 to 2011, Plaintiff to obtain justice
from Defendant the New York State Unified Court System. 1) Uzamere v Daily
News, L.P., 2011 NY Slip Op 52421(U) [34 Misc 3d
1203(A)], Decided on November 10, 2011, Supreme Court, New York County, Rakower, J; 2) Uzamere v Uzamere, 2011 NY Slip Op 08583
[89 AD3d 1013], November 22, 2011, Appellate Division, Second Department;
3) Uzamere v Uzamere, 2009 NY Slip Op 09214 [68 AD3d 855], December 8,
2009, Appellate Division, Second Department; 4) Uzamere v Uzamere, Motion
No: 2010-07636, Slip Opinion No: 2010 NY Slip Op 83241(U), Decided on
September 23, 2010, Appellate Division, Second Department, Motion Decision;
5) Uzamere v Uzamere, Motion No: 2010-07636, Slip Opinion No: 2011 NY Slip
Op 65346(U), Decided on February 28, 2011, Appellate Division, Second
Department, Motion Decision; 6) Uzamere v Uzamere, Motion No: 2010-07636,
Slip Opinion No: 2011 NY Slip Op 69114(U), Decided on April 6, 2011,
Appellate Division, Second Department, Motion Decision; and 7) Uzamere v
Uzamere, Motion No: 2010-07636, Slip Opinion No: 2011 NY Slip Op 69622(U),
Decided on April 11, 2011, Appellate Division, Second Department, Motion
Decision. The following appellate judges presided over the aforementioned
cases: Daniel D. Angiolillo; Cheryl E. Chambers;
Jeffrey A. Cohen; Mark C. Dillon; Anita R. Florio; Steven W. Fisher; L.
Priscilla Hall; John M. Leventhal; Plummer E. Lott; William F. Mastro; Robert J. Miller; A. Gail Prudenti;
Reinaldo E. Rivera; Sheri S. Roman; Sandra L. Sgroi
and Peter B. Skelos. Plaintiff alleges that just
as in the trial courts, Plaintiff provided the appellate courts with the
Daily News article and the fraudulent affirmations in which Defendants
Allen E. Kaye, Harvey Shapiro, Jack Gladstein Osato E. Uzamere committed 18
USC §1028A, aggravated identity theft and New York State Penal Law Section
210.15, perjury in the first degree, class D felony by stating that “Godwin
Uzamere” was Plaintiff's husband. The appellate judges, just as every judge
with whom Plaintiff presented the aforementioned testimony ignored
Plaintiff's cries for justice, engaged in fraud upon the court and
disobeyed 18 USC §4, misprision of felony, the Code of Conduct for Judges,
18 USC §1028A, the New York State Penal Law Section 210.15 and the Code of
Lawyers Professional Responsibility with regard to a judge's and an
attorney's responsibility to report a judge and/or an attorney who engages
in acts of wrongdoing.
Facts
73)Plaintiff
prays that this Court rapidly facilitates Plaintiff's emergency motion for
expedited judicial notice of adjudicative facts pursuant to Fed. R. Evid. Rule 201 and for on conversion to Plaintiff's motion
for summary judgment pursuant to Fed. R. Civ. Rule 56, based on Plaintiff's
presentation of the following irrefutable facts:
74)a)In December, 1977, approximately two (2) years before
the Plaintiff met Defendant Ehigie Edobor Uzamere, Nosayaba
(John) Uzamere and his wife Ethel Uzamere (Defendant Uzamere's brother and
sister-in-law, not his father and stepmother) filed for IR2 residence for
Defendant Ehigie Edobor Uzamere. The IR2 visa for Defendant Uzamere was
approved on January 28, 1980.
b)On November 20, 1979, the Plaintiff and
Defendant Ehigie Edobor Uzamere visited Defendant City of New York's City
Clerk's marriage department and filled out the marriage affidavit form with
the fictitious name “Godwin Ehigie Uzamere” and the fictitious birthday “XXXXXX
XX, 19XX” without providing his current passport to verify his age and
identity. Defendant City Clerk Joseph Visceglia
verified the identification Plaintiff presented to him; however, at the
clandestine behest of Defendants Allen E. Kaye, Harvey Shapiro and Ehigie
Edobor Uzamere, Defendant Visceglia, made no
attempt to obtain Defendant Ehigie Edobor Uzamere's passport. While
Defendant Ehigie Edobor Uzamere wrote the fictitious name “Godwin Ehigie
Uzamere” on the marriage affidavit form, he inadvertently signed the form
with his real name Ehigie Edobor Uzamere.
c)On November
21, 1979, the Plaintiff unwittingly entered into a “green card” marriage
with Defendant Ehigie Edobor Uzamere under the fictitious named “Godwin
Ehigie Uzamere, and under the fictitious birthday “XXXXXX XX, 19XX.” On or
after November 30, 1979, Defendant Ehigie Edobor Uzamere and Defendants
Allen E. Kaye and Harvey Shapiro, Esq. engaged in an act of aggravated
identity theft and immigration fraud by giving the Plaintiff form I-130 to sign
so as to sponsor the Defendant for IR1 residence under the fictitious name
“Godwin Ehigie Uzamere” and fictitious birthday “XXXXXX XX, 19XX” without
requiring their client to produce his current passport.
d)In December, 1979, Defendant Uzamere left for Nigeria,
abandoning the Plaintiff and leaving her poor and pregnant with his
daughter Tara A. Uzamere. On January 28, 1980, Defendant Ehigie Edobor
Uzamere entered the port of New York as a lawful permanent resident. The aforementioned attorneys exacerbated their act of
aggravated identity theft by refusing to require Defendant Ehigie Edobor
Uzamere to produce his passport to establish proof of his identity, and by
engaging in willful blindness by pretending not to have knowledge of the
existence of Senator Uzamere's passport or of knowledge that Senator
Uzamere previously applied under his correct name as an unmarried
beneficiary under 21 years of age. At the time of Plaintiff's signing the
fraudulent I-130 relative sponsorship form, Plaintiff did not know that
Defendant Ehigie Edobor Uzamere had applied and been found eligible for
permanent residence under his real name via sponsorship by Nosayaba Uzamere and Ethel Uzamere. See report prepared
by Defendant Rachel McCarthy, Bar Counsel, U.S. Citizenship and Immigration
Service attached as Exhibit A.
75)On or around October 1, 2003, Jack
Gladstein engaged in an act of racketeering, and aggravated identity theft
by mailing to the Plaintiff correspondence falsely holding Plaintiff's
ex-husband out to be “Godwin Uzamere” even though the only correct
identification that the U.S. Citizenship and Immigration Service holds is
for Ehigie Edobor Uzamere, not “Godwin Uzamere.”
76)On or
September 25, 2008, after Plaintiff had engaged in a series of leaving
angry telephone calls on Defendant McCarthy's voice mail based on
Plaintiff's perception that Defendant McCarthy had engaged in racketeering
designed to nullify Plaintiff's complaint against Defendant Kaye and
Defendant Shapiro, Defendant McCarthy engaged in an act of racketeering and
fraud3 by engaging the U.S. Attorney's Office for Vermont to say that “In
or about September 2008, in the District of Vermont, the defendant, Cheryl
Uzamere, impeded, intimidated, and interfered with a federal employee,
namely an employee of the United States Customs and Immigration Service,
while that person was engaged in and on account of that person's
performance of official duties.” Plaintiff emphatically states that she has
never been to Vermont, Defendant McCarthy's state of resident, so that it
was impossible for Plaintiff to have engaged in any form of simple assault
against Defendant McCarthy. See documentation regarding USA v. Uzamere,
1:08-cr-114-1 attached as Exhibit B.
77)On or around October 8, 2008,
Defendant Eugene Uzamere, engaged in an act of racketeering, aggravated
identity theft, violation of Title II of the Americans with Disabilities
Act and violation of Section 504 of the Rehabilitation Act by
hand-delivering a fraudulent affirmation and a fraudulent, unauthenticated,
unnotarized counter-affidavit from Nigeria4, 5 which stated that “The
plaintiff who has openly professed her mental illness is also delusional
and outlandish in her claims”; and “I have before now, ignored the
Plaintiff's outburst but her claim to be married to my cousin who was not
in the United States at the time of our marriage is a new twist to this sad
tale. . .Her obsession with his destruction has taken her mental ailment to
a new level which should not be encouraged” in defiance of the administrative
decision rendered by the INS regarding Plaintiff's ex-husband's identity.
Defendant Osato Uzamere also gave Defendant Sunshine a copy of a Nigerian
passport bearing the number A05588053, but no name; and a copy of a social
security card receipt with the number XXX-XX-1205, with the name and
address “Godwin E. Uzamere, 239 Clifton Avenue, Apt. 3, Brooklyn, New York,
11216.” The unnamed passport copies and the social security receipt were
notarized by “Kate Ezomo, Principal Registrar, Commissioner for Oaths”, in
Nigeria. Justice Sunshine refused to commission a diplomatic or consular
officer for the purpose of determining the
genuineness of the fraudulent foreign document that was presented to him by
attorney Osato Uzamere on behalf of his uncle, Plaintiff's ex-husband
Nigerian senator Ehigie Edobor Uzamere. From then until the present,
Justice Sunshine has never made any attempt to arrest Osato Uzamere for
committing perjury. See fraudulent affirmation and fraudulent foreign
counter-affidavit Exhibit C. During the same month, Defendant McCarthy and
Defendant Cowles gave Plaintiff's criminal attorney Beth Mann a copy of the
I-130 immigration sponsorship form that Plaintiff signed on November 30,
1979 and a report explaining the two (2) immigration files having birthdays
“XXXXXX XX, 19XX” and XXXXXX XX, 19XX. and explaining “IR2 fraudulently
obtained because he was married at the time” and “Compare fingerprints
between the two files.”
78)On or around January 6, 2009,
Plaintiff received a notice from Defendant McCarthy in which she said that
“This office has completed its review of the complaint of professional
misconduct that you filed against Allen E. Kaye, Esquire. The matter is
confidential at this stage in accordance with the Rules and Procedures of Professional
Conduct for Practitioners (“Rules”), except for necessary disclosures in the course of conducting a preliminary inquiry. U.S.
Citizenship and Immigration Services (“USCIS”) has authority to conduct a
preliminary inquiry of complaints of criminal, unethical, or unprofessional
conduct in matters before USCIS. In your June 9, 2008 complaint, you allege
that Alan E. Kaye “colluded with my husband, the now Senator Ehigie Edobor
Uzamere to submit a marriage certificate with the fictitious name "Godwin
Uzamere: in order to avoid paying child support.
and three years later, in order to hide the 2nd
marriage that my husband contracted in the United States.” The acts that
you allege constitute a violation of the Rules of Professional Conduct for
Practitioner occurred in the course of
representation by an attorney associated with Mr. Kaye in connection with
an immediate relative filed by you with the Immigration and Naturalization
(“INS”) in 1979. The New York Departmental Disciplinary Committee, Supreme
Court, Appellate Division First Judicial Department considered these
allegations in 2003 and determined that no further action was warranted.
After a careful and thorough review of your complaint I do not find clear
and convincing evidence of an ethical violation of the Rules on the part of
Mr. Kaye. No further action will be taken with regard to
your complaint.” Defendant McCarthy's statement “occurred in the course of representation by an attorney
associated with Mr. Kaye” makes direct reference to Defendant Harvey
Shapiro. See correspondence from Defendant McCarthy dated January 6, 2009
attached as Exhibit A.
79)On January 12, 2009, Defendant
Sunshine engaged in misprision of felony, racketeering, aggravated identity
theft and fraud upon the court by rendering a decision in which he stated
that “Moreover, the opposition submitted by defendant raises a genuine
issue as to whether or not plaintiff and defendant were married in the
first instance”, in defiance of INS' administrative decision that
recognized the names “Godwin E. Uzamere” and Ehigie Edobor Uzamere as
belonging to Ehigie Edobor Uzamere, and that Ehigie Edobor Uzamere was
married to the Plaintiff. Defendant Sunshine made no attempt to obey
commission a consular officer of the U.S. Embassy in Abuja, Nigeria to
verify the authenticity of the unauthenticated counter-affidavit from
Nigeria purporting to be from “Godwin Uzamere.” See Page 9 of Justice
Sunshine's decision and order dated January 12, 2009 is attached as Exhibit
D.
80)On January 20, 2009, the Plaintiff
e-mailed a complaint to former U.S. Ambassador to Nigeria, Robin Renee
Sanders in which she said that “While I was in court on January 13, 2008,
my husband's attorney, Eugene O. Uzamere asked Judge Sunshine if Senator
Ehigie Edobor Uzamere, my real husband, along with some Nigerian pretending
to be my real husband can be allowed to video-conference their appearance
in court. As it is apparent that the level of corruption in my divorce
action has reached an all-time new low, it appears that Judge Sunshine will
allow this silliness. This would give Eugene the opportunity of paying some
poor Nigerian a pittance to engage in identity fraud that would reach a New
York State Court. In the likely event that Judge Sunshine allows this
silliness, is there some way that your office can ensure that the unknown
Nigerian who engages in this video-conference first signs some kind of
affidavit that is notarized by your office? That way, your office can check
that person's identification to ensure that if he attempts to say that he
is my husband, his identification will prove otherwise.” Although Plaintiff
had the presence of mind to ask former U.S. Ambassador Robin Renee Sanders
to require anyone posing as Plaintiff's husband to produce identification,
Defendant Sunshine did not require Defendant Osato E. Uzamere to produce
any type of U.S. Embassy-authenticated, color-photograph-bearing government
identification of his client, and the only forms of identification that
Defendant Osato E. Uzamere produced was a copy of a passport bearing no
one's name and social security number XXX-XX-1205, the fictitious number
associated with the fictitious name “Godwin Uzamere.” See e-mail to former
Ambassador Robin Renee Sanders and response from the U.S. Embassy in
Nigeria attached as Exhibit E. See fraudulent passport cover and fraudulent
social security number attached as Exhibit C.
81)On May 12, 2009, Defendant Sunshine
rendered his decision recognizing the identity of Plaintiff's ex-husband as
Ehigie Edobor Uzamere by stating that “Today at 10:35 am. defendant was
declared in default for failure to appear at the hearing. Accordingly,
defendant's motion to dismiss this action upon the grounds that he is not
the husband of the plaintiff is denied in its entirety. The defendant is
the husband in conformity with the parties
marriage on November 21, 1979. Plaintiff is directed to serve a copy of
this decision and order and serve and file a note of issue, forthwith, with
proof of mailing by regular international mail and overnight international
mail for a trial on all issues within this matrimonial action to be held
before this court on July 7, 2009. at 9:30 a.m. This shall constitute the
decision and order of the court.” See Defendant Sunshine's decision
attached as Exhibit F.
82)On July 7, 2009, the Plaintiff filed an
action for fraud against her ex-husband and against Defendants Allen E.
Kaye, Harvey Shapiro and Jack Gladstein. From the year 2009 to 2011,
Plaintiff also attempted to engage the judicial assistance of Defendant New
York State Unified Court System for the Second Judicial Department with
regard to the following appellate cases: 1) Uzamere v Daily News, L.P.,
2011 NY Slip Op 52421(U) [34 Misc 3d 1203(A)],
Decided on November 10, 2011, Supreme Court, New York County, Rakower, J; 2) Uzamere v Uzamere, 2011 NY Slip Op 08583
[89 AD3d 1013], November 22, 2011, Appellate Division, Second Department;
3) Uzamere v Uzamere,2009 NY Slip Op 09214 [68 AD3d 855], December 8, 2009,
Appellate Division, Second Department; 4) Uzamere v Uzamere, Motion No:
2010-07636, Slip Opinion No: 2010 NY Slip Op 83241(U), Decided on September
23, 2010, Appellate Division, Second Department, Motion Decision; 5)
Uzamere v Uzamere, Motion No: 2010-07636, Slip Opinion No: 2011 NY Slip Op
65346(U), Decided on February 28, 2011, Appellate Division, Second
Department, Motion Decision; 6) Uzamere v Uzamere, Motion No: 2010-07636,
Slip Opinion No: 2011 NY Slip Op 69114(U), Decided on April 6, 2011,
Appellate Division, Second Department, Motion Decision; and 7) Uzamere v
Uzamere, Motion No: 2010-07636, Slip Opinion No: 2011 NY Slip Op 69622(U),
Decided on April 11, 2011, Appellate Division, Second Department, Motion
Decision. The following appellate judges presided over the aforementioned
cases: Daniel D. Angiolillo; Cheryl E. Chambers;
Jeffrey A. Cohen; Mark C. Dillon; Anita R. Florio; Steven W. Fisher; L.
Priscilla Hall; John M. Leventhal; Plummer E. Lott; William F. Mastro; Robert J. Miller; A. Gail Prudenti;
Reinaldo E. Rivera; Sheri S. Roman; Sandra L. Sgroi
and Peter B. Skelos. Plaintiff alleges that just
as in the trial courts, Plaintiff provided the appellate courts with the
Daily News article and the fraudulent affirmations in which Defendants
Allen E. Kaye, Harvey Shapiro, Jack Gladstein Osato E. Uzamere perjured
themselves and stated that “Godwin Uzamere” was Plaintiff's husband. The
appellate judges, just as every judge with whom Plaintiff presented the aforementioned testimony as done, ignored Plaintiff's
cries for justice, engaged in fraud upon the court and disobeyed 18 USC §4,
misprision of felony, the Code of Conduct for Judges and the Code of
Lawyers Professional Responsibility with regard to report a judge an
attorney who engages in acts of wrongdoing. Plaintiff also filed various
complaints with the New York State Commission on Judicial Conduct against
Defendants Michael Gerstein, Jeffrey S. Sunshine and Arthur Schack; the
Departmental Disciplinary Committee for the First Department against Allen
E. Kaye, Harvey Shapiro and Osato E. Uzamere; and the New York State
Grievance Committee for the Second Judicial Department against Jack
Gladstein. Plaintiff produced the Daily News article, the fraudulent,
unauthenticated, unnotarized, foreign counter-affidavit from Defendant
Osato E. Uzamere, and the fraudulent affirmation from Defendants corrupt
attorneys Allen E. Kaye, Harvey Shapiro, Jack Gladstein and Osato E.
Uzamere that are proof of their act of 18 USC §1028A, aggravated identity
theft and New York State Penal Law Section 210.15, perjury in the first
degree, and proof of the true identity of Ehigie Edobor Uzamere the
Plaintiff obtained from Defendant Rachel McCarthy (who can be reached at
(802) 660-5043; fax (802) 660-5067). No member of the New York State
Commission on Judicial Conduct, the New York State Departmental
Disciplinary Committee for the First Judicial Department or the New York
State Grievance Committee for the Second Judicial Department ever reported
the aforementioned attorneys for their commission
of 18 USC §1028A, aggravated identity theft or New York State Penal Law
Section 210.15, perjury in the first degree.
83)On or near
October 28, 2009, Defendants Allen E. Kaye, Harvey Shapiro and Jack
Gladstein, engaged in racketeering and aggravated identity theft by
submitting fraudulent affirmations to the court holding “Godwin Uzamere” to
be the Plaintiff's husband based on the fraudulent I-130 immigration
sponsorship form that Plaintiff's ex-husband filed with Defendants Kaye and
Shapiro. Seefraudulent affirmations of Defendants
Kaye, Shapiro and Gladstein attached as Exhibit G.
84)On November 3, 2009, Defendants Jeffrey
S. Sunshine, Arthur M. Schack, Michael Gerstein, Allen E. Kaye, Harvey
Shapiro and Jack Gladstein engaged in an act prohibited by the New York
Lawyers Code of Professional Responsibility in that, after filing the
fraudulent affirmations, they planned and implemented Plaintiff's false
arrest for the sole purpose of obtaining an advantage in the action for
fraud that Plaintiff filed against Defendants Allen E. Kaye, Harvey Shapiro
and Jack Gladstein. Plaintiff stayed in jail for 33 days. Because Plaintiff
was remanded and was not able to leave, Plaintiff was coerced into
accepting the plea as mentally unfit, and employees of Defendant New York
State Office of Court Administration/Unified Court System intentionally
avoided appearing before court to explain their false charge against the
Plaintiff. Charges against Plaintiff were dismissed. See correspondence
from Rikers Island, attached as Exhibit H.
85)On November 5, 2009, Defendants Judge
Gerstein, Justice Sunshine and Justice Schack, on their own and/or by
courthouse employees that were under said Defendants' care, control and
supervision at the time of the incident, engaged in an act of
racketeering/obstruction of justice by illegally commenting on and
providing nonpublic information regarding Plaintiff's cases Kings County
Criminal Court Case Docket No. 2009KN087992, Kings County Supreme Court
Index No. 18012-2009 and Kings County Supreme Index No. 26332-2007 to Daily
News staff writer Scott Shifrel in violation of
22 NYCRR §100.3(B)(8)(11)6; that said nonpublic information was provided to
the Daily News, by staff writer Scott Shifrel,
who did knowingly, fraudulently and with malice aforethought engage in an
act of racketeering/obstruction of justice by publishing the newspaper
article that illegally disclosed Plaintiff's nonpublic information that was
acquired by Defendant Judge Gerstein, Justice Sunshine and Justice Schack
during their adjudication of Plaintiff's cases including Plaintiff's photo;
Plaintiff's name; Plaintiff's age; Plaintiff's mental illness; Plaintiff's
psychiatric diagnosis; symptoms of Plaintiff's mental illness; the courts
where Plaintiff's cases were adjudicated; the town where Plaintiff's lives
and the name of the hospital that treated Plaintiff; that Daily News staff
writer Scott Shifrel, on behalf the Defendants,
engaged in an act of racketeering/obstruction by charging Plaintiff with
the halachic/Jewish religious crime of anti-Semitism by saying “Cheryl
Uzamere, 50, known around courthouse circles for her anti-Semitic screeds,
was declared mentally unfit and taken to Bellevue Hospital for
observation”; and, that “...she's a smart person and she really know how to
use the system, said one courthouse source...she comes in here and files
all these papers and threatens people. Uzamere was in a Criminal Court
holding cell when she started stripping and screaming about her “senator”
husband in Nigeria loud enough to be heard in the courtroom. The senator, however,
is a cousin of her actual ex-husband, Godwin Uzamere, according to an
affidavit he filed in Supreme Court. . .”; and that “the senator, however,
is a cousin of her actual ex-husband, Godwin Uzamere, according to
affidavit filed in Supreme Court”; and “Her obsession with his destruction
has taken her mental ailment to a new level which should not be encouraged,
Godwin Uzamere said. . .” Scott Shifrel, at the
behest of Mortimer Zuckerman and and Defendants
Judge Gerstein, Justice Sunshine and Justice Schack, on their own and/or by
courthouse employees that were under said Defendants' care, control and
supervision at the time of the incident, engaged in an act of
racketeering/obstruction of justice by engaging in aggravated identity
theft; said act of identity theft accomplished by publicly holding in the
Defendant Daily News that false identity of Plaintiff's ex-husband as
“Godwin Uzamere. On the following day, the company ALM.com, by its website
Law.com, published an article entitled N.Y. Arrested for Threatening Judge;
that said nonpublic information was provided to the Law.com, by staff
writer Mark Fass who did knowingly, fraudulently
and with malice aforethought, publish the internet article that illegally
disclosed Plaintiff's nonpublic information that was acquired by the
Defendant judges during their adjudication of Plaintiff's cases, leaving
out Jews Allen E. Kaye's, Harvey Shapiro's, Jack Gladstein's,
Scott Shifrel's and Mortimer Zuckerman's
commission of misprision of felony, fraud, identity theft and aggravated
identity theft. Around that same period of time, Defendant Jazmin M. Quary, a paralegal (not an attorney), fraudulently and
with malice aforethought, committed misprision of felony, fraud, identity
theft and aggravated identity theft by conspiring with, at the very least,
corrupt Jewish attorney Allen E. Kaye, Harvey Shapiro, Jack Gladstein and
other Defendants to give the impression of being a legal expert,
disparagingly criticizing Plaintiff's lawsuit Uzamere v. Bush, 08:CV-891 at
her website; by stating the following:
“In Uzamere v.
Bush, et al., Cheryl D. Uzamere alleged that her “American” husband Ehigie
Edobor a.k.a. "Goodwin" Uzamere was a ringleader in a green card
scam marriage. After filing her complaint with the United States Immigration
and Naturalization Office in 1980 Mrs. Uzamere pursued her allegations in
the Federal Court system.
She claims
that her husband, Mr. Uzamere tricked her into signing his immigration
paperwork and ultimately abandoned her and their daughter. She claims that
she had no idea his name was fictitious, that he was not a United States
citizen and that he had obtained entrance into the United States illegally.
She claims that Mr. Uzamere, a Nigerian Senator, and his immigration
attorneys created this scheme to outsmart someone that had no knowledge of
the law or his true origin.
I was
beginning to feel sorry for the woman, but then the case took a unusual
turn: The funny part of this case is that in addition to suing the husband
and his attorneys she is also going after New York State (yes, the entire
state), New York State Grievance Committee for the 2nd and 11th
Departments, City of New York (yes, the entire city), New York City Police
Department, New York City Human Resources Administration/Department of Social
Services, Google Corporation (yes, the entire Google) and YouTube
Corporation (same here), Condoleeza Rice (what
did she do?), Michael Chertoff, Julie Myers, The United States Of America,
United States Department of State, United States Department of Homeland
Security, United States Department of Citizenship and Immigration Services,
United States Department of Immigration and Customs Enforcement.
Why? Because
she thinks that they should have known that he was lying. She believes that
they should have discovered the fraud and uncovered the truth. See the
remainder of the complaint here.
There is no
surprise that Mrs. Uzamere's complaint was dismissed for not stating a
claim as to the Federal government defendants and for having a frivolous
cause. But it sure was entertaining!”7
Plaintiff
alleges that as Defendant Quary has publicly held
herself out to be a legal expert, she knew that corrupt Jewish Allen E.
Kaye, Harvey Shapiro and Jack Gladstein had engaged in fraud, identity
fraud and aggravated identity theft, and that Defendant Quary
was illegally influenced to publicly disseminate Plaintiff's attempts to
obtain justice as “funny” and “entertaining”, while holding out corrupt
Jewish Allen E. Kaye, Harvey Shapiro and Jack Gladstein as not having engaged
in any wrongdoing, and being victims, and holding out Plaintiff's Verified
Complaint as being even more false based on the word of a “legal expert”
who could not have any racism toward the Plaintiff because like the
Plaintiff, she is African American. While Defendant Quary
held out the ridiculousness of Plaintiff's lawsuit, she made no attempt to
negatively critique corrupt Jewish Allen E. Kaye's, Harvey Shapiro's and
Jack Gladstein's commission of fraud, identity
fraud and aggravated identity theft, and their refusal to check Plaintiff's
ex-husband's passport to verify their client's identity. Seenegative internet articles concerning Plaintiff and
Plaintiff's Verified Complaint Docket No. 08-CV-891, attached as Exhibit
Kl. During the time that Plaintiff was unlawfully imprisoned, Plaintiff
explained to her attorneys Timothy Gumkowski and
Joyce Kendrick that the Defendants had engaged in aggravated identity theft
with reference to Plaintiff's ex-husband's identity. Defendant Kendrick
told Plaintiff to let it go.
86)On November
30, 2009, twenty-five (25) days after Defendant Daily News, LP published
its article regarding the Plaintiff, Defendant Federation Employment and
Guidance Service terminated its mental health services to the Plaintiff. In
its discharge summary it stated that “given client's history of
anti-Semitic remarks treatment at an FEGS facility is inappropriate for
her.” FEGS' discharge summary is attached as Exhibit J1.
....87)On
December 7, 2009, the Plaintiff was placed with Defendant New York State
Office of Mental Health's Kingsboro Psychiatric
Facility.
88)On December 24, 2009, Plaintiff was
seen by Defendant New York State Unified Court System judicial employee the
Honorable Anthony Cutrona of Kings County Supreme
Court's Mental Hygiene Court.
89)On January 15, 2010, Defendant Schack
engaged in an act of racketeering, obstruction of justice, violation of
Title II of the Americans With Disabilities Act and Section 504 of the
Federal Rehabilitation Act by ordering Defendant New York State Office of
Mental Health's psychiatrist Dr. Marie Bauduy of
the Kingsboro Psychiatric Facility not to produce
the Plaintiff for court. In his decision dated January 25, 2010, Justice
Schack stated that “The Court is concerned that plaintiff UZAMERE is unfit
to proceed. . .Therefore, the instant matter is adjourned to Friday, March
19, 2010. . .” See interim decision of Defendant Schack attached as Exhibit
I.
....90)During
the beginning of February, 2010, Plaintiff was discharged by Kingsboro Psychiatric Facility.
91)On or near February 23, 2010, while the
Plaintiff was in her apartment faxing letters of complaint to various
governmental agencies, Defendants Sunshine, New York State Office of Mental
Health and Brookdale University Hospital Medical Center engaged in an act
of racketeering/obstruction of justice, insofar as they contacted a social
worker from Defendant Brookdale University Hospital Medical Center, who
then arranged for Plaintiff to be kidnapped and hospitalized by Defendant
New York State Office of Mental Health's Kingsboro
Psychiatric Center. Defendant Brookdale University Hospital Medical Center
caused one of its employees to contact Defendant City of New York's
agencies, the New York City Housing Authority's Louis H. Pink Houses, the
New York City Police Department and the New York City Fire Department. An
employee of the New York City Housing Authority opened the Plaintiff's
apartment door, and Plaintiff was taken out of her apartment by force and
hospitalized by Defendant New York State Office of Mental Health's Kingsboro Psychiatric Center. During Plaintiff's last
week as an inpatient, Kingsboro social worker
Laurie Velcimé informed the Plaintiff that she
was engaged in aftercare preparation, including locating an outpatient
mental health program. The Plaintiff advised Ms. Velcimé
that she was interested in attending New York Psychotherapy and Counseling
Center (NYPCC) on Hendrix Street, located close to where the Plaintiff
lives. After Ms. Velcimé performed a search of
NYPCC and other outpatient mental health care providers, she informed the
Plaintiff that not only had NYPCC refused to accept Plaintiff as a client,
but that virtually all the not-for-profit outpatient mental health
facilities that Ms. Velcimé contacted rejected
her request to provide Plaintiff with outpatient psychiatric services.
92)On July 13,
2010, Justice Arthur M. Schack engaged in an act of racketeering,
obstruction of justice and aggravated identity theft by rendering a
decision, holding that “Godwin Uzamere” is Plaintiff's husband and that
ORDERED, that the instant complaint is dismissed with prejudice; and it is
further ORDERED, that plaintiff CHERYL UZAMERE is hereby enjoined from
commencing any future actions in the New York State Unified Court System
against SENATOR EHIGIE EDOBOR UZAMERE a/k/a "GODWIN E. UZAMERE,"
ALLEN E. KAYE, P.C., ALLEN E. KAYE, ESQ., HARVEY SHAPIRO, ESQ., BERNARD J.
ROSTANSKI and JACK GLADSTEIN, ESQ., without the prior approval of the
appropriate Administrative Justice or Judge; and it is further ORDERED,
that any violation of the above injunction by CHERYL UZAMERE will subject
CHERYL UZAMERE to costs, sanctions and contempt proceedings. This
constitutes the decision and order of the Court.” See Defendant Schack's
decision dated July 13, 2010 attached as Exhibit J.
“One theme
that we have considered over the years is whether attorneys get
preferential treatment in legal malpractice litigation. Are motions to
dismiss granted on too little evidence? Do the attorneys get the benefit of
the doubt? Is the fact that legal malpractice law is written mostly by
attorneys, is decided upon by attorneys and affects attorneys sometimes
dispositive of the outcome?Well,
all that aside, sometimes the client just can't help themselves. Here is an
example from today's NYLJ: Uzamere v. Uzamere; KINGS COUNTY; Justice
Schack. . .”
93)Shortly
thereafter, Defendant Lawline.com published the same article, even going so
far as to compare Jewish Defendant Kaye's, Defendant Shapiro's and
Defendant Gladstein's monstrous act of aggravated
identity theft, including the deprivation of Plaintiff's and her daughter
Tara's right to bear the African/Nigerian name of Defendant Ehigie Edobor
Uzamere nothing more than Plaintiff's delusion that it was an act of legal
malpractice, and not a crime.
94)On August
16, 2010, Plaintiff filed lawsuit 2010-cv-555 with the U.S. Court of
Claims, and that said lawsuit assigned to Defendant judge Christine O.C.
Miller. Plaintiff alleges that she provided Defendant Miller with
irrefutable evidence of Allen E. Kaye's, Harvey Shapiro's and Jack Gladstein's commission of aggravated identity theft,
and that Defendant Miller disobeyed 18 USC §4 by failing to file a criminal
complaint against the aforementioned Jew
attorneys. The decision rendered on this case was an act of racketeering
because it was an act of obstruction of justice. It was also a clear act of
fraud upon the court, designed to: 1) advance the Talmudic doctrine Law of
the Moser; 2) trick Plaintiff into believing that a civil res judicata determination
was a permanent and final determination to nullify and render harmless any
legal consequences based on corrupt Jewish attorneys Allen E. Kaye's,
Harvey Shapiro's and Jack Gladstein's criminal
commission of aggravated identity theft. The decision of this case is null
and void. Plaintiff will no longer tolerate any more of the corrupt,
racist, racketeering, justice-obstructing shenanigans of the Jewish
defendants.
95)On August
30, 2010, Plaintiff filed lawsuit 2010-cv-585 with the U.S. Court of Claims,
and that said lawsuit assigned to Defendants Nancy B. Firestone and John P.
Wiese of the U.S. Court of Claims. Plaintiff alleges that she provided
Defendants Firestone and Wiese with irrefutable evidence of Allen E.
Kaye's, Harvey Shapiro's and Jack Gladstein's
commission of aggravated identity theft, and that Defendants Firestone and
Wiese disobeyed 18 USC §4 by failing to file a criminal complaint against
the aforementioned Jew attorneys. The decision
rendered on this case was an act of racketeering because it was an act of
obstruction of justice. It was also a clear act of fraud upon the court,
designed to: 1) advance the Talmudic doctrine Law of the Moser; 3) trick
Plaintiff into believing that a res judicata determination – a purely civil
adjudicative function – was a permanent and final determination to nullify
and render harmless corrupt Jewish attorneys Allen E. Kaye's, Harvey
Shapiro's, Jack Gladstein's, and Mortimer
Zuckerman's and Scott Shifrel's commission of
aggravated identity theft – a wrongful act for which the correct criminal
adjudicative function of double jeopardy was never attached because the
crime was never tried. The decision of this case is null and void.
Plaintiff will no longer tolerate any more of the corrupt, racist, racketeering,
justice-obstructing shenanigans of the Jewish defendants.
96)On September 1, 2010, Plaintiff filed
lawsuit 2010-cv-591 with the U.S. Court of Claims, and that said lawsuit
was assigned to Defendant judge Christine O.C. Miller of the U.S. Court of
Claims. Plaintiff alleges that she provided Defendant Miller with
irrefutable evidence of Allen E. Kaye's, Harvey Shapiro's and Jack Gladstein's commission of aggravated identity theft,
and that Defendant Miller disobeyed 18 USC §4 by failing to file a criminal
complaint against the aforementioned Jew
attorneys. The decision rendered on this case was an act of racketeering
because it was an act of obstruction of justice. It was also a clear act of
fraud upon the court, designed to: 1) advance the Talmudic doctrine Law of
the Moser; 2) trick Plaintiff into believing that a res judicata
determination – a purely civil adjudicative function – was a permanent and
final determination to nullify and render harmless corrupt Jewish attorneys
Allen E. Kaye's, Harvey Shapiro's, Jack Gladstein's,
and Mortimer Zuckerman's and Scott Shifrel's
commission of aggravated identity theft – a wrongful act for which the
correct criminal adjudicative function of double jeopardy was never
attached because the crime was never tried. The decision of this case is
null and void. Plaintiff will no longer tolerate any more of the corrupt,
racist, racketeering, justice-obstructing shenanigans of the Jewish
defendants.
97)On or around January 11, 2011,
Plaintiff filed a lawsuit against Defendant State of New York with the New
York State Court of Claims. As part of Plaintiff's testimony, Plaintiff
provided Defendant Scuccimarra with the fraudulent affirmations that
corrupt, Jewish attorneys Allen E. Kaye, Harvey Shapiro and Jack Gladstein
used to commit aggravated identity theft with regard to
Defendant Ehigie Edobor Uzamere's identity. Defendant Scuccimarra never
made any attempt to address the aforementioned Jewish
attorneys' commission of a federal felony.
98)On or around January 19, 2011, Plaintiff
filed a lawsuit against Defendant Gerstein, Defendant Sunshine and
Defendant Schack with Defendant the New York State Commission on Judicial
Conduct. As part of Plaintiff's testimony, Plaintiff provided Defendant Klonick with the fraudulent affirmations that corrupt,
Jewish attorneys Allen E. Kaye, Harvey Shapiro and Jack Gladstein used to
commit aggravated identity theft with regard to
Defendant Ehigie Edobor Uzamere's identity. Defendant Klonick
never made any attempt to address the aforementioned
Jewish attorneys' commission of a federal felony.
99)On or
around April 29, 2011, Plaintiff filed a lawsuit against Defendants Allen
E. Kaye, Harvey Shapiro and Jack Gladstein with Defendants the New York
State Departmental Disciplinary Committee for the First Judicial Department
and the New York Grievance Committee for the Second Judicial Department. As
part of Plaintiff's testimony, Plaintiff provided Defendants Del Tipico and Gutierrez with the fraudulent affirmations
that Defendants Kaye, Shapiro and Gladstein used to commit aggravated
identity theft at the behest of their client, Defendant Ehigie Edobor
Uzamere. Defendants Del Tipico and Gutierrez
never made any attempt to address the aforementioned
Jewish attorneys commission of a federal felony.
100)In June,
2011, Plaintiff filed the Uzamere v. Cuomo, et al, 11-cv-2831 for the
Eastern District of New York.
101)On or around June 22, 2011, Defendant
Garaufis rendered in decision for Plaintiff's civil rights action which
said the following:
“Plaintiff's
most recent Complaint—one of at least five she has filed with this court—is
89-pages long and is accompanied by 589 pages of exhibits. Plaintiff has
also sent at least 60 pages of faxes directly to chambers, purporting to be
in connection with her most recent action. The substance of Plaintiffs
Complaint—if one can be discerned—concerns, among other things, her divorce
from Ehigie Edobor Uzamere; a defamation claim filed against the Daily
News; a Departmental Disciplinary Committee complaint filed against the
attorney representing the Daily News; and other state court actions,
including a state court action against the attorneys who represented her
former husband. (Compi. at 27-45.) Plaintiff has
a long, tired history of vexatious litigation in this court. See Uzamere v.
State of New York, No. 09-cv-2703 (E.D.N.Y. July 9, 2009).”
Defendant
Garaufis' judicial commentary on Plaintiff's lawsuit was biased. It did not
address the acts of fraud, identity theft or aggravated theft perpetrated
by corrupt Jewish attorneys Allen E. Kaye, Harvey Shapiro and Jack
Gladstein that Plaintiff proved in her civil rights action Nor did Defendant Garaufis' address Plaintiff's
contentions regarding the Court's discrimination against Plaintiff based on
her having a mental illness. Defendant Garaufis' judicial commentary did
not address most of the issues Plaintiff discussed in her civil rights
action (“. . .a unanimous Supreme Court has admonished that pro se in forma
pauperis complaints must be read with tolerance: Dismissal is impermissible
unless the court can say “with assurance that under the allegations of the
pro se complaint, which we hold to less stringent standards than formal
pleadings drafted by lawyers, it appears 'beyond doubt that the plaintiff
can prove no set of facts in support of his claim which would entitle him
to relief.'” Haines v. Kerner, 404 U.S. 519, 520-21, 92 S.Ct. 594, 595-96,
30 L.Ed.2d 652 (1972), quoting Conley v. Gibson, 355 U.S. 41, 45-46, 78
S.Ct. 99, 101-102, 2 L.Ed.2d 80 (1957), reaffirmed in Estelle, 429 U.S. at
106, 97 S.Ct. at 292.) The commentary condemned the Verified Complaint's
number of pages and the numbers of complaints Plaintiff filed with the
Court (But a complaint filed in forma pauperis is not subject to dismissal
simply because the plaintiff is litigious. The number of complaints a poor
person files does not alone justify peremptory dismissal. In each instance,
the substance of the impoverished person's claim is the appropriate
measure. Crisafi v. Holland, et al, 655 F2d 1305)
Defendant Garaufis admits that he has difficulty in understanding the
substance of Plaintiff's complaint based on his statement: “The substance
of Plaintiff's Complaint – if one can be discerned. . .” Defendant
Garaufis' displayed even more mean-spirited bias with regard to all of
Plaintiff's actions when he said in his statement: “Plaintiff has a long,
tired history of vexatious litigation in this court. Defendant Garaufis
engaged in an act of racketeering, obstruction of justice and criminal
facilitation of aggravated identity theft by rendering an FRCP-lacking,
memorandum-lacking decision regarding Uzamere vs. Cuomo, et al, 11-CV-2831
for the sole purpose of: 1) advancing the Talmudic doctrine Law of the
Moser; 2) not filing a criminal complaint against corrupt, dishonest,
lying, racketeering, racist Jewish immigration attorneys Allen E. Kaye,
Harvey Shapiro and Jack Gladstein for their fraudulent commission of 3)
trick Plaintiff into believing that a res judicata determination – a purely
civil adjudicative function – was a permanent and final determination to
nullify and render harmless corrupt Jewish attorneys Allen E. Kaye's,
Harvey Shapiro's, Jack Gladstein's, and Mortimer
Zuckerman's and Scott Shifrel's commission of
aggravated identity theft – a wrongful act for which the correct criminal
adjudicative function of double jeopardy was never attached because the
crime was never tried; and, 4) Defendant Bloom's commission of misprision
of felony racketeering, obstruction of justice, criminal facilitation of
aggravated identity theft and fraud upon the court as well.
102)On or around June 25, 2011, less than
thirty (30) after Plaintiff submitted her lawsuit to the court, Defendant
Garaufis engaged in an act of racketeering, obstruction of justice and
criminal facilitation of aggravated identity theft of at the behest of
Defendant Judge Garaufis three (3) marshals from the U.S. Marshals Service
for Defendant the Eastern District of New York banged on Plaintiff's
apartment door, embarrassing Plaintiff within earshot of her neighbors.
When the U.S. Marshal for the Eastern District of New York identified
themselves, Plaintiff asked them if she had committed a crime. The marshals
stalled for a few seconds, and then said that Plaintiff had not committed any
crimes. When Plaintiff asked the U.S. Marshals why they were there, the
U.S. Marshal that banged on Plaintiff's door said “I'm gonna
annoy you like you annoyed Judge Garaufis.” When Plaintiff told them that
she would not open the door, the one banging on the door said
“then I'm gonna keep bangin”,
and for another 1.5 minutes continued to bang on Plaintiff's door. He also
asked Plaintiff “is your daughter Tara home?”, to find out if Plaintiff was
home alone. Within minutes of Plaintiff telling them that her daughter Tara
was there, they left. Later on, between the end of June and the beginning
of July, 2011, under the leadership of President Barack H. Obama;8 Andrew
Weissman, General Counsel for Defendant Federal Bureau of Investigation,
James X. Dempsey, Defendant, Privacy and Civil Liberties Oversight Board; Elisebeth Collins Cook, Defendant, Privacy and Civil
Liberties Oversight Board; David Medine,
Chairman, Privacy and Civil Liberties Oversight Board; Rachel L. Brand,
Privacy and Civil Liberties Oversight Board; and Patricia M. Wald,
Defendant, Privacy and Civil Liberties Oversight Board; Keith B. Alexander,
General, National Security Agency; Rajesh De, General Counsel, National
Security Agency; Eric H. Holder; U.S. Attorney General, Patrick Leahy, Senator
Judiciary Chairman, Hon. Goodlatte, Chairman, U.S. House Judiciary
Chairman, Mike Rogers, House Permanent Select Committee on Intelligence,
U.S. Marshals Service Director Charles Dunne, U.S. Department of Homeland
Security, Federal Protection Service, Threat Assessment Branch employee
Denis P. McGowan, FBI Assistant Director in Charge, George Venizelos, their
subordinates, U.S. Department of Justice; Charles Schumer,9 Senate
Judiciary Committee; Dianne Feinstein,10 Senate Select Committee on
Intelligence Chairperson; Senator Saxby Chambliss,11 and at the direct
behest of Defendant Judge Nicholas G. Garaufis, Plaintiff alleges that a
national security letter (or national security letters) was/were given to
Cablevision, Inc. to obtain non-content information regarding Plaintiff's
telephone calls to governmental agencies and outpatient psychiatric care
providers for the sole purpose of associating the non-content information
with false reports that Plaintiff had made threatening telephone calls to
government employees.
....103)On July
4, 2011, Plaintiff filed her appeal for the lawsuit Uzamere vs. Cuomo, et
al.
104)From July
6, 2011, the date in which Plaintiff is alleged to have committed 18 USC
§115 against Defendant Garaufis, other federal judges and employees of the
U.S. Department of Health and Human Services' Centers for Medicare and
Medicaid Services call center, no federal law enforcement agency made any
attempt to arrest the Plaintiff for the aforementioned
offenses. According to Defendant Catherine O'Hagan Wolfe, the judges
who rendered decisions on Plaintiff's appeal for her lawsuit Uzamere vs.
Cuomo, et al, 11-2713-cv were not indicated on the decision because others
unknown to Plaintiff told Defendant O'Hagan Wolfe that Plaintiff threatened
Defendant Garaufis, other federal judges and Defendant Sunshine.
105)On or around July 7, 2011, Defendants
psychiatric nurse Agnes Flores and psychologist Martin Bolton, employees of
Defendant New York City Health and Hospitals Corporation came to
Plaintiff's apartment, speaking about Plaintiff's psychiatric issues in the
hallway and shaming Plaintiff within earshot of her neighbors. Defendants
Flores and Bolton said that Defendant U.S. Marshal Service12 told them that
Plaintiff contacted Defendant Mental Health Association's LifeNet psychiatric helpline and made threats of bodily
harm against Defendant Garaufis. Plaintiff told them that had she done such
a thing that the U.S. Marshal Service would have arrested her when they
visited her and given her an attorney, which would have forced Plaintiff's
attorney to examine Plaintiff's civil claims. Also, at the behest of
Defendant Garaufis, Plaintiff alleges that Defendant O'Hagan Wolfe returned
Plaintiff's appellate brief, all of Plaintiff's motions, Appendix A and Appendix
B that Plaintiff served on the U.S. Court of Appeals for the Second Circuit
on July 4, 2012. Defendant O'Hagan Wolfe did not include any correspondence
explaining why Plaintiff's appellate documents were returned. Seecopies of UPS envelopes for Plaintiff's appellate
documents, Uzamere vs. State of New York, et al 09-cv-2703/09-3197-cv and
Uzamere vs. Cuomo, et al, 11-2831-cv and 11-2713-cv attached as Exhibit K
13 and Exhibit L.
106)Plaintiff alleges that this is the
first time that an accuser was correct about the non-content information of
a phone call she made (but not about the content). At the time the
accusation was made, Plaintiff was not able to tell how Defendants Flores
and Bolton discovered the non-content information of her phone call to LifeNet.
....107)Plaintiff
alleges that Defendants Agnes Flores and Martin Bolton do not possess the
psychic ability to read Plaintiff's thoughts and tell whom she called.
Plaintiff alleges that Defendants Agnes Flores and Martin Bolton received
non-content information regarding phone call to LifeNet
from an NSL that Defendant Garaufis signed off, or that Defendants Flores
and Bolton received non-NSL, non-content information from an unauthorized
source.
108)Some days later while in the month of
July 2011, Plaintiff received another visit from Defendants Flores and
Bolton. Because Plaintiff was afraid that someone would enter her apartment
and place Plaintiff in a psychiatric hospital against her will, so
Plaintiff hid in her closet so she would not appear
to be home. Thereafter, Plaintiff received a call from Defendant Davis, but
Plaintiff did not answer her cellphone.
109)A day or so later, someone knocked on
Plaintiff's door but did not announce themselves. Again
Plaintiff hid in her closet to feign that she was not home. When Plaintiff
went to the door, there was a notice from Woodhull Hospital's psychiatric
unit with an appoint to appear at their psychiatric outpatient clinic.
110)On July 16, 2011, in terror of forced
hospitalization at the behest of Defendant Garaufis, the U.S. Marshal
Service and psychiatric facilities over which the New York State Office of
Mental Health and the New York State Department of Health have oversight,
Plaintiff faxed a copy of a complaint to U.S. Attorney Preetinder
Bharara. However, Defendant Davis called Plaintiff again, frightening
Plaintiff by making Plaintiff believe that Plaintiff would be forcibly
hospitalized because Defendant U.S. Marshal Service told her that Plaintiff
had threatened judges and others at the (federal) Medicaid office,
something that Plaintiff did not do. Plaintiff took the liberty of
recording the conversation14 in its entirety. Plaintiff uploaded the
conversation http://www.thecrimesofsenatoruzamere.net/federallawsuit.html.
111)Plaintiff alleges that by the end of
June/beginning of July 2011, Plaintiff alleges that Defendant Garaufis
authorized a national security letter that was sent to Movant's telephone
company and internet service provider, Cablevision, giving Defendants
Garaufis, the U.S. Marshals Service, the U.S. Department of Homeland
Security and the Federal Bureau of Investigation the ability to obtain
non-content information regarding Plaintiff's daughter, Tara A. Uzamere and
Movant's psychiatric care providers for the sole purpose of contacting them
to give them false criminal/psychiatric reports concerning the Movant, in
violation of 18 USC §2709 and 18 USC §3511. Plaintiff alleges this based on
her belief that the aforementioned Defendants are
not psychic but were able to obtain non-contact information regarding
Movant's telephone calls to her daughter, Tara A. Uzamere and to
psychiatric care providers from sources other than the Plaintiff. Please
refer to http://www.thecrimesofsenatoruzamere.net/federallawsuit.html; and
http://www.thecrimesofsenatoruzamere.net/uzamere_v_obama.html. 15 See
letter from Cablevision to Plaintiff, letter from the U.S. Attorney's
Office, SDNY to Defendant Judge Victor Marrero, Memorandum of Law from
Defendant Marrero and Stipulation and Order of Dismissal of Action between
U.S. Attorney's Office, SDNY and the American Civil Liberties Union,
attached as Exhibit L1.
112)In the month of August,
2011 Defendant Davis contacted Defendant Sarpong for the purpose of forcing
Plaintiff to go to Defendant Brookdale Hospital Medical Center, where
Plaintiff was unlawfully imprisoned as an inpatient for threatening
Defendant Garaufis and other judges with bodily harm, and threatening CMS
workers with death, something that Plaintiff never did. Plaintiff stayed a
few days as an inpatient with Defendant Brookdale because Defendant Dr.
“John Doe” and other employees of Defendant Brookdale Hospital Medical
Center were told by Defendant Sarpong that Plaintiff threatened Judge
Garaufis, other judges and CMS call center workers with death and with
bodily harm. Thereafter, Brookdale Hospital Medical Center terminated its
outpatient psychiatric services to the Plaintiff and transferred Plaintiff
to the East New York Diagnostic and Treatment Center's Assertive Community
Treatment Team in order Plaintiff illegally monitor along with Defendant
Denis P. McGowan of Defendant U.S. Department of Homeland Security.
113)On or around August 18, 2011,
Defendant New York City Health and Hospitals Corporation's East New York
Diagnostic and Treatment Center's Assertive Community Treatment Team
received correspondence from U.S. Department of Homeland Security on its
original letterhead bearing the name “Denis P. McGowan, Chief, Threat
Management Branch.” The letter stated: “On July 06, 2011, Federal
Protective Service (FPS) was notified of a telephonic threat made by CHERYL
UZAMERE to the Centers for Medicare & Medicaid call center. The threat
consisted of HER stating: since SHE did not get the job, SHE was going to
“COME DOWN THERE AND KILL EVERYBODY. Since FPS has investigated UZAMERE
multiple times for similar behavior, we are well aware
of HER mental health history. Based on that information, a referral was
made to LifeNet for mental health intervention on
July 07 2011. Subsequently, UZAMERE's Intensive
Case Manager (ICM) Bridgett Davis of the New York State Office of Mental
Health has advised that UZAMERE's treatment has been transferred to the
Assertive Community Treatment (ACT) program. We were informed that CHERYL
D. UZAMERE is being treated as a patient by your program and we would like
to keep you abreast of this situation as it evolves. We also request that
we be notified as HER status changes in particular any
change from in-patient to out-patient treatment and in the case of the
latter any refusal of treatment. In addition, please notify FPS of any
relapses or deterioration of HER condition that may pose a risk to life or
property.” See letter from Denis P. McGowan, U.S. Department of Homeland
Security attached as Exhibit M.
114)This is the second time that a
defendant was correct about the non-content information of a phone call
made by the Plaintiff (but not correct about the content). At the time the
accusation was made, Plaintiff was not able to tell how Defendant McGowan
knew that Plaintiff called the Centers for Medicare and Medicaid Services
call center. Further to this, Defendant McGowan became a regional director
(someone with power to issue NSLs) shortly after he revealed the
non-content information regarding Plaintiff's phone call to CMS in the
letter that he sent to Samuel Sarpong.
115)Plaintiff alleges that Defendant
McGowan does not possess the psychic ability to read Plaintiff's thoughts
and tell whom Plaintiff called. Plaintiff further alleges that Defendant
McGowan received non-content information regarding Plaintiff's phone call
to CMS from an NSL that he authorized, and Judge Garaufis signed off, or
that he received non-NSL, non-content information from an unauthorized
source.
116)On February 26, 2012, Defendant HHC's
ACT Team where Defendant Sarpong is employed prepared a psychiatric
treatment plan. Under the title “Alerts”, the treatment plan states “. . .
H/O threats to judges and Center for Medicaid and Medicare, patient is
being monitored by Homeland Security.” Under the title “Discharge Plan”, it
says “Patient is not being considered for discharge at this time, she was
transferred to the program 6 months ago after she made a threat to the
Medicare and Medicaid call center and is being monitored by the U.S.
Department of Homeland Security.” Under the title “Patient/Family
Statement”, it says that “She reported not being aware of being monitored
by Homeland Security. . .” (See Plaintiff's psychiatric treatment plan from
the East New York Diagnostic and Treatment Center's Assertive Community
Treatment Team, attached as Exhibit M).
117)From June 6, 2012, Plaintiff sent a number of e-mails to employees Mike J. Fitzpatrick,
Katrina Gay, David Levy and Sue Medford of the organization National
Alliance for the Mental Ill (NAMI) regarding Defendant Daily News use of
the term “wacko” to publicly malign the Plaintiff. None of the employees
that Plaintiff contacted made any attempt to speak with the Plaintiff.
118)On November 26, 2012, Plaintiff sent
an e-mail to Hakeem Jeffries regarding the act of fraud of Defendant Denis
P. McGowan. Included in the e-mail was Plaintiff's impending lawsuit
against various federal employees, the correspondence from Defendant
McGowan and psychiatric treatment plans of Defendant New York City Health
and Hospitals Corporations that reflect Defendant McGowan's fraudulent
statement that Plaintiff threatened judges with bodily harm and employees
of the Centers for Medicare and Medicaid Services call center with murder.
Plaintiff received an e-mail from Defendant Jeffries stating that “In order
to best serve you, I have opened a South Brooklyn office in Coney Island
and a Central Brooklyn office in Fort Greene. You are cordially invited to
join me, my staff, and your fellow neighbors at an Open House to learn more
about what we can do for you. As far as Plaintiff knows, neither Defendant
Jeffries, nor any of his staff made any attempt to contact Defendant U.S.
Department of Homeland Security, the Defendant Federal Bureau of
Investigation or U.S. Marshals Service.
119)On November 28, 2012, based on
information and belief, Defendants Raggi, Carney and Kahn of the U.S. Court
of Appeals for the Second Circuit engaged in an act of racketeering,
obstruction of justice and criminal facilitation of aggravated identity
theft by rendering an FRAP-lacking decision regarding Uzamere vs. Cuomo, et
al, 11-2713-cv for the sole purpose of advancing the Talmudic doctrine Law
of the Moser by not filing a criminal complaint against corrupt, dishonest,
lying, racketeering, racist Jewish immigration attorneys Allen E. Kaye,
Harvey Shapiro and Jack Gladstein for their fraudulent commission of
aggravated identity theft, and their own commission of racketeering,
obstruction of justice, criminal facilitation of aggravated identity, for
their own commission of obstruction of justice by tricking Plaintiff into
believing that a res judicata determination – a purely civil adjudicative
function – was a permanent and final determination to nullify and render
harmless corrupt Jewish attorneys Allen E. Kaye's, Harvey Shapiro's, Jack Gladstein's, Mortimer Zuckerman's and Scott Shifrel's commission of aggravated identity theft – a
wrongful act for which the correct criminal adjudicative function of double
jeopardy was never attached because the crime was never tried. Plaintiff
was told the names of Defendant judges Raggi, Carney and Kahn by an unknown
employee of the U.S. Court of Appeals for the Second Circuit. Defendant
O'Hagan Wolfe also engaged in an act of racketeering, obstruction of justice
and criminal facilitation of aggravated identity theft for the sole purpose
of advancing the Talmudic doctrine Law of the Moser by not filing a
criminal complaint against corrupt, dishonest, lying, racketeering, racist
Jewish immigration attorneys Allen E. Kaye, Harvey Shapiro and Jack
Gladstein for their criminal commission of aggravated identity theft.
Plaintiff's alleges that Defendant O'Hagan Wolfe left out the names of the
judges who rendered their illegal decision on Plaintiff's decision based on
defendants' delusion that Plaintiff would either not figure out the judges'
identity and would therefore be unable to sue them.
....120)Soon
thereafter, the Plaintiff called Defendant Catherine O'Hagan Wolfe, Clerk
of Court for U.S. Court of Appeals for the Second Circuit and asked why the
appellate judges' names were not indicated on the U.S. Court of Appeals'
decision. Defendant O'Hagan Wolfe indicated that the judges' names were
left out because Plaintiff had threatened federal judges, something that Plaintiff
never did.
....121)During the month of December,
2012, Plaintiff sent several e-mails containing a copy of the lawsuit
Uzamere vs. Cuomo, et al, 11-cv-2831 that Plaintiff filed, as well as those
lawsuits that Plaintiff will file with the of the Eastern District of New
York, along with proof of Plaintiff's ex-husband's identity and the
fraudulent affirmations that corrupt Jewish immigration attorneys Allen E.
Kaye, Harvey Shapiro and Jack Gladstein filed with the New York State
Supreme Court to First Lady Michele Obama, and to all the defendants. See
one of several e-mails Plaintiff sent the Defendants attached as Exhibit N.
....122)On or
around January 30, 2013, Plaintiff received a letter from the Centers for
Medicare and Medicaid Services. The letter stated: "Our records show
that you placed calls to 1-800-MEDICARE on the dates and times listed below
(all times Central). We can confirm that none of these calls contained
threatening comments: June 14,2010, 10:38 AM; June 1,2011, 7:39 AM; July 8,
2011, 12:56 PM; May 18, 2012, 11:17 AM, 1:29 PM, 3:51 PM; July 2, 2012,
10:47 AM; July 10, 2012, 2:24 PM; July 17, 2012, 1:09 PM; July 18, 2012,
11:14 AM; July 19, 2012, 5:02 PM; July 23, 2012, 2:51 PM; July 24, 2012,
5:21 PM, 5:43 PM, 5:47 PM, 6:05 PM, 9:56 PM; July 26, 2012, 9:39 PM; July
27, 2012, 5:48 PM; September 9, 2012, 4:39 PM; October 18, 2012, 2:26 PM;
November 16, 2012 7:38 PM; November 26, 2012, 1:46 PM; December 12, 2012,
11:13AM; December 13, 2012, 4:29 AM, 5:05 PM, 5:09 PM. See letters from the
Centers for Medicare and Medicaid Services attached as Exhibit S.
....123)On March
7, 2013, Plaintiff contacted the New York State Court of Appeals to inform
Chief Judge Jonathan Lippman of Plaintiff's plans to include him in her
lawsuit. Later on, Plaintiff received an e-mail
from Richard Reed that said: “This is further to the telephone conversation
that you had with the Clerk's Office of the New York State Court of Appeals
this morning regarding your proposed federal complaint. Please be advised that
the matter has been turned over to Counsel's Office for the Office of Court
Administration. They will contact you in due course.” See e-mail from
Richard Reed attached as Exhibit U. Towards the end of the same day,
Plaintiff received a telephone call from Defendant Michael J. Broyde and attempted to tell him of what Plaintiff
called a contradiction in term with regard to
being both a rabbi and a U.S. attorney. Plaintiff informed the
rabbi-attorneys of her plans to file her Verified Complaint against them,
and consistent with Plaintiff's stated plans, e-mailed her Verified
Complaint and the exhibits to rabbi-attorneys Michael J. Broyde, Esq., Rabbi Michoel Zylberman, Esq., Rabbi Yona
Reiss, Esq., Rabbi Shlomo Weissmann,
Esq.
....124)On March 9, 2013, Plaintiff
e-mailed Abraham H. Foxman, Steven M. Freeman, Esq., Steven C. Sheinberg,
Esq., Deborah Bensinger, Esq. and David L.
Barkey, Esq. of the Anti-Defamation League, Inc. to advise them how Jewish
Defendants Allen E. Kaye, Esq., Harvey Shapiro, Esq., Jack Gladstein, Esq.,
Mortimer Zuckerman and Scott Shifrel employed
their Talmud-fostered racial hatred and hatred of mentally ill goyim to
rationalize their commission of 18 USC §1028A, aggravated identity theft;
their false accusation that Plaintiff harassed Defendant Sunshine; their
false accusation that Plaintiff made threats of violence; their violation
of Plaintiff's Sixth Amendment insofar as the aforesaid Defendants never
had any intention of confronting the Plaintiff; and the Defendants'
continued violation of 18 USC §4, misprision of felony, insofar as none of
the Defendants have ever made any attempt to file any criminal complaint
against Allen E. Kaye, Esq., Harvey Shapiro, Esq., Jack Gladstein, Esq.,
Mortimer Zuckerman and Scott Shifrel in spite of Plaintiff's
irrefutable criminal accusations.
....125)On March
15, 2013, Plaintiff sent a copy of her lawsuit and a her complaint
regarding Defendant McCarthy to Defendant the Professional Responsibility
Program. Plaintiff explained in her e-mail that Defendant McCarthy violated
18 USC §4, misprision of felony based on Defendant's McCarthy's having
knowledge of the actual commission of a Allen E. Kaye's and Harvey
Shapiro's aggravated identity theft and her continued refusal to it make
known; and her refusal to obey Vermont’s Rules of Professional Conduct's
Rule 3.4, Fairness to Opposing Party and Counsel, which requires attorneys
not to: (a) unlawfully obstruct another party’s access to evidence or
unlawfully alter, destroy or conceal a document or other material having
potential evidentiary value; b) not to counsel or assist another person to
do any such act; and, c) not to falsify evidence, counsel or assist a
witness to testify falsely, or offer an inducement to a witness that is
prohibited by law. See letters from Vermont's Rules of Professional
Conduct, attached as Exhibit V.
126)On March 24, 2013, Plaintiff called
Defendant FBI New York Office and asked one of its agents if the FBI office
would refuse to take Plaintiff's complaints if the person against whom
Plaintiff complained was Jewish, as Plaintiff alleges was done to her in
the past. True to past behavior, someone hung up the phone. When Plaintiff
called back, the person on the phone said that Plaintiff had posed the
question to Mr. Stein, hurting his feelings. Plaintiff was then called
anti-Semitic, and then subjected to having the telephone hung up. Plaintiff
took her three (3) phones and engaged in a blitz phone call session,
allowing all of her phones to ring at the same
time. When "John Doe" #1 finally answered the phone, Plaintiff
got into an argument with Defendant “John Doe” #1 with
regard to Plaintiff's right to file a criminal complaint against
Jews who had violated federal law. Defendant “John Doe” #1 blackmailed
Plaintiff by telling her that he would call Plaintiff's daughter,
mentioning Plaintiff's daughter's name (something that generally precedes a
threat of psychiatric hospitalization), and then would come to Plaintiff's
apartment; however, when asked if Plaintiff had committed a crime and
whether Plaintiff would be assigned an attorney, "John Doe" #1
said that Plaintiff would have to obtain an attorney on her own. As it
turned out, "John Doe" #1 never came to Plaintiff's apartment,
and never contacted Plaintiff's daughter. During Plaintiff's conversation
with "John Doe" #1, Plaintiff told the employee that she was
recording the conversation. Plaintiff recorded the conversation and
uploaded it to http://www.thecrimesofsenatoruzamere.net/uzamere_v_obama.html (this site, at the link that says FBIconversation - click here). The following day,
Plaintiff contacted the FBI and spoke with a woman (who sounded black).
Plaintiff told the woman that an FBI employee would not allow her to file
any complaints if the subject of the complaint is Jewish. Plaintiff also
told the woman that she recorded the conversation and uploaded it to her
website. The woman asked Plaintiff how Plaintiff
knew whether the person with whom Plaintiff spoke was an employee of the
FBI. Plaintiff told the woman she was right, and that the person with whom
Plaintiff spoke could have been Bozo the Clown. Subsequently, an employee
of the FBI called Plaintiff's psychiatric treatment facility and reported
that Plaintiff had an argument with an FBI employee; that said argument was
indicative that Plaintiff has psychiatric issues that warrant
hospitalization. On March 28, 2013, the day of Plaintiff's treatment
appointment, Plaintiff was asked by her psychiatrist, Dr. Beaudouin if she had had an argument with anyone.
Later, Plaintiff was interviewed simultaneously by Dr. Beaudouin
and Ms. Fletcher in an attempt to find reasons to
hospitalize the Plaintiff. It was so obvious that Plaintiff asked if they
planned to hospitalize her. Plaintiff's psychiatrist and therapist said no;
however, Plaintiff's psychiatrist and therapist never disclosed to
Plaintiff that they had been contacted by Defendant FBI and requested to
act as agents of the police. Plaintiff had committed no crime and has been
treatment compliant such that Plaintiff felt double-teamed by Dr. Beaudouin and Ms. Fletcher with their bombardment of
questions that were geared, not to help Plaintiff, but as an investigative
tool of the FBI to determine whether Plaintiff had any argument with the
FBI. Plaintiff alleges that her treatment facility is now being used
surreptitiously to ensure that if Plaintiff files a complaint with the FBI
against any Jew, that the FBI will contact her psychiatric treatment
facility and tell them to hospitalize Plaintiff. Furthermore, Plaintiff also
alleges that at the continued behest of Defendant Garaufis, “John Doe” #1
of Defendant Federal Bureau of Investigation's New York Office illegally
obtained information regarding Plaintiff's outpatient psychiatric care
provider from Defendants' network of as yet unknown informants from the
U.S. Department of Health and Human Services' Centers for Medicare and
Medicaid Office, and/or from the New York State Office of Mental Health,
and/or from the New York State Department of Health and/or from the New York
State Office of Temporary and Disability Assistance and/or from the New
York City Health and Hospital's Corporation, and/or from the New York City
Human Resources Administration.
127)On March 25, 2013 Plaintiff sent a reply back to Vermont's Professional Responsibility
Program with copies of the attorneys' fraudulent affirmations that hold
"Godwin Uzamere" to be Plaintiff's husband.
128)On April 9, 2013, Plaintiff e-mailed a
formal complaint to Defendant Jeffries containing the Center for Medicare
and Medicaid Services confirming that Plaintiff did not threaten anyone
during any of the phone calls Plaintiff made to the CMS call center.
Plaintiff sent a copy of the formal complaint to the following e-mail
addresses: newyork@fbi.gov; stuart.f.delery@usdoj.gov;
tristram.coffin@usdoj.gov; Preet.Bharara@usdoj.gov;
loretta.lynch@usdoj.gov; eric.schneiderman@ag.ny.gov; mcardozo@law.nyc.gov;
peter_kirchheimer@fd.org; david_patton@fd.org; Lschreib@bds.org;
michael.brown@oandb.com; robert.roarke@wilsonelser.com;
mdesroches@mhaofnyc.org; mleish@nydailynews.com; RonH@nami.org;
support@lawline.com;ALB@Bluestonelawfirm.com; yreiss@yu.edu;
mbroyde@emory.edu; sweissmann@bethdin.org; mzylberman@bethdin.org;
sfreeman@adl.org; ssheinberg@adl.org; dbensinger@adl.org; dbarkey@adl.org;
akaye@kayevisalaw.com;ckawalsky@harveyshapiro.com; gladmessattys@aol.com;
info@uzalaw.com ehigieuzamere@yahoo.com;
AskDOJ@usdoj.gov; internal.affairs@usdoj.gov; Preet.Bharara@usdoj.gov;
info@jeffriesforcongress.com; ogc@dhs;
ivan.fong@dhs.gov; firstladycorrespondence@who.eop.gov;
William.Schultz@hhs.gov;
Suzan_Orlove@schumer.senate.gov;DOJOIG.NewYorkComplaints@usdoj.gov;
kathleen.sebelius@hhs.gov. Defendant Jeffries made no attempt to send a
written response to Plaintiff's requesting assistance as a crime victim
with irrefutable of the crime.
129)During the month of May, 2013,
Plaintiff's made several phone calls and spoke with Patrick Boyle,
Defendant Jeffries with reference to the crimes that were committed against
Plaintiff by various members of the Jewish community, explaining her belief
that the reason her complaint is continually ignored is because of the
Talmud doctrine Law of the Moser, that prohibits Jews from reporting the
crimes of fellow Jews to the secular/Gentile authorities. On one of the
last occasions in which Plaintiff spoke with Patrick Boyle, he demanded
that Plaintiff never call back, without giving Plaintiff a reason in
writing or any explanation as to why Plaintiff was being blacklisted.
130)In May, 2013, Plaintiff performed an
internet research and discovered the following contributors to Defendant
Jeffries' congressional campaign: Mr. Ruslan Agarunov,
Bertram Berns, Mr. Norman Bobrow,
Mr. Paul Burg, Ms. Vickie Fishman, Mr. Sander Gerber, Mr. Michael Granoff, Mr. Marvin Israelow,
Mr. Alan Levow, Mr. William Russell-Shapiro, Ms.
Donna Sternberg, Mr. Marc Spiegel, Mr. Daniel Tenenblatt,
Leslie Topper, Mr. Craig Weiss, World Alliance for Israel PAC, Lee Ziff,
President of the World Alliance for Israel. Based on the number of Jews who
contributed money to Defendant Jeffries' campaign, including the World
Alliance for Israel, combined with Defendant Jeffries' refusal to provide
Plaintiff with a written why neither he nor anyone else in his office can
contact the U.S. Department of Justice to investigate Plaintiff's complaint
or cause it to be investigated, and Patrick Boyle's demand that Plaintiff
not call the office against even though Plaintiff is a constituent,
Plaintiff alleges that Defendant Jeffries and his staff understand that
campaign contributions from Jewish contributors are quid pro quo and will
only be provided if Defendant Jeffries and his staff espouse and promulgate
Jewish/Talmudic culture, including the Talmudic doctrine Law of The Moser,
that prohibits Jews from reporting the crimes of fellow Jews to the
secular/Gentile authorities, an never participate in the criminal
investigation, arrest, indictment, trial, conviction, sentencing and
imprisoning anyone who is Jewish.16 From at least 2012 through and
including the present time, in the Eighth Congressional District and
elsewhere, Defendant Jeffries, Patrick Boyle, other members of Congressman
Jeffries congressional staff and campaign contributors who are Jewish, and
others known and unknown, unlawfully willfully and knowingly combined,
conspired, confederated and agreed together and with each other to receive
bribes masking as campaign contributions from a number of Jewish
individuals, in exchange for advancing the Jewish religion, including the
Talmudic doctrine, Law of the Moser, which prevents Jews (and Jew slaves)
from reporting the crimes of fellow Jews to the secular/Gentile authorities
in order to make sure that no Gentile's criminal complaint in which the
defendant is Jewish would ever come to legal fruition in any court of law;
that in furtherance of the conspiracy, Defendant Jeffries and his staff
ignored Plaintiff's request to investigate and/or cause to be investigated
Plaintiff's criminal complaint by the appropriate law enforcement agency,
and to effect the illegal objects thereof, the following over acts, among
others, were committed in the Eighth Congressional District in Brooklyn,
New York and elsewhere: 1) Defendant Jeffries ignored Plaintiff's
complaint; 2) Plaintiff refused to respond to the Plaintiff in writing as
to whether he would forward Plaintiff request to the appropriate federal
law enforcement agency; 3) more than one of Defendant told Plaintiff not to
call back or would become irritated over the phone when Plaintiff would
call; and 4) Defendant Boyle blackmailed Plaintiff not to call their office
anymore, even though Plaintiff is a constituent and voted for Defendant
Jeffries.
131)On and
before May, 2013, while refusing to accept from the Plaintiff irrefutable
proof of Jews Allen E. Kaye's, Harvey Shapiro's, Jack Gladstein's,
Mortimer Zuckerman's and Scott Shifrel's
commission of misprision of felony, fraud, identity theft, aggravated
identity theft, racketeering, obstruction of justice and
extortion/blackmail, Defendant Barack H. Obama, Andrew Weissman, General
Counsel for Defendant Federal Bureau of Investigation, James X. Dempsey,
Defendant, Privacy and Civil Liberties Oversight Board; Elisebeth
Collins Cook, Defendant, Privacy and Civil Liberties Oversight Board; David
Medine, Chairman, Privacy and Civil Liberties
Oversight Board; Rachel L. Brand, Privacy and Civil Liberties Oversight
Board; and Patricia M. Wald, Defendant, Privacy and Civil Liberties
Oversight Board; Keith B. Alexander, General, National Security Agency;
Rajesh De, General Counsel, National Security Agency; Eric H. Holder; U.S.
Attorney General, U.S. Department of Justice; Charles Schumer, Senate
Judiciary Committee; Dianne Feinstein, Senate Select Committee on
Intelligence Chairperson; Senator Saxby Chambliss, Patrick Leahy, Senator
Judiciary Chairman, Hon. Goodlatte, Chairman, U.S. House Judiciary
Chairman, Mike Rogers, House Permanent Select Committee on Intelligence,
U.S. Marshals Service Director Charles Dunne, U.S. Department of Homeland
Security, Federal Protection Service, Threat Assessment Branch employee
Denis P. McGowan, FBI Assistant Director in Charge, George Venizelos and
Judge Nicholas G. Garaufis engaged in overseeing a criminal,
unconstitutional system of government that specifically discriminated
against the law-abiding, psychiatric-treatment-compliant, mentally disabled
Gentile/Schvartze/African American Plaintiff by
allowing Defendant Judge Garaufis and other Jews to fraudulently use the
PATRIOT Act to spy on non-criminal, constitutionally-protected telephone
calls regarding Plaintiff's HIPAA-protected mental health and other
HIPAA-protected issues; that said telephone calls were spied on at the
behest of Defendant Judge Garaufis and other Jews, not based on the belief
that the Plaintiff had violated the law, but to enslave the Plaintiff by
extorting/blackmailing her; by using Plaintiff's confidential, non-content
information regarding Plaintiff's telephone calls to her outpatient
psychiatric care provider that maybe embarrassing or shameful if publicly
disseminated; to fraudulently accuse the Plaintiff of the commission of a
crime and to associate the fraudulent criminal allegation with Plaintiff's
confidential non-content information; to frighten the Plaintiff by
publicizing embarrassing or shameful information associated with
Plaintiff's psychiatric non-content information for the sole purpose of
forcing the Plaintiff not to petition the government for a redress of
grievances with regard to Plaintiff's First Amendment right to report the
activities of lawbreaking Jews to the secular/Gentile law enforcement
authorities; that those Jews' violation of Plaintiff's and other Gentiles'
right to privacy is based on the Talmudic doctrine for Jews to enslave
Gentiles, with an emphasis on the enslavement of people who are
dark-skinned or considered by Jews to be Africans, Cushites,
Hamites and Canaanites. See Exhibit Q. In the meantime, Defendants Allen E.
Kaye, Harvey Shapiro, Jack Gladstein, Mortimer Zuckerman and Scott Shifrel, who engaged in illegally obtaining and
publicly disseminating information regarding the crime (for which Plaintiff
was falsely accused, for which Defendants never had any intention of
confronting Plaintiff in any court of laws and that was eventually
dismissed), Plaintiff's mental illness and her marriage and who are still
engaging in misprision of felony, fraud, identity theft, aggravated
identity theft, racketeering, obstruction of justice and
extortion/blackmail have never been investigated for the continued
commission of their crimes.
132)On or near
August 7, 2013, Plaintiff alleges that Defendants federal Judge John Bates,
federal Judge John William E. Smith and federal Magistrate Judge Patricia
A. Sullivan conspired with or were extorted/blackmailed by the Jewish
Defendants who used the Daily News and other internet news articles to
commit 18 USC §1001, fraud; 18 USC §1028, identity theft and 18 USC §1028A,
aggravated identity theft; namely, Defendant Jew billionaire Mortimer
Zuckerman, speaking on behalf of Jew Defendants Allen E. Kaye, Harvey
Shapiro, Jack Gladstein, Jeffrey S. Sunshine and Arthur M. Schack; that the
goal of said conspiracy is: 1) for Defendants federal Judge John Bates,
federal Judge Judge William E. Smith and
Magistrate Judge Patricia A. Sullivan to engage in misprision of felony by
not reporting the crimes that Plaintiff's exhibits proved occurred; 2) by
Defendant Smith and Magistrate Judge Patricia A. Sullivan committing the
requisite affirmative acts of not uploading Plaintiff's exhibits to PACER's
Electronic Court Filing System, the court's more efficient electronic
filing system, by not filing Plaintiff's subpoena duces tecum with
Defendant U.S. Department of Homeland Security to leave no doubt regarding
the identity of Plaintiff's ex-ex-husband and the father of Tara A.
Uzamere, the child of the marriage; 3) to allow the aforementioned Jew
Defendants to leave their criminally fraudulent statements on the internet
regarding Plaintiff's ex-husband's identity to be unchallenged; 4) to
deprive Plaintiff of her First Amendment right to proceed without
government's encroachment of the Jewish religion; 5) to deprive Plaintiff
of her right to freedom of speech; 6) to deprive Plaintiff of her right to
petition PACER.gov, a government agency, with a redress of grievances by
uploading her exhibits; and, 7) by relying on the U.S. Supreme Court case
regarding the legal doctrine “void for vagueness” by explaining what makes
Plaintiff's exhibits are too voluminous, by giving Plaintiff the
opportunity to learn what Defendant Smith means by “too voluminous” so that
Plaintiff could make repairs on said exhibits and upload them to PACER.gov.
See the following: 1) Daily News article criminally holding Plaintiff to be
mentally unfit and that “Godwin Uzamere” is Plaintiff's husband; 2) page
two (2) of Defendant Garaufis' Order regarding Plaintiff's civil rights
lawsuit, Cheryl D. Uzamere v. Andrew M. Cuomo, et al., Case No.
1:2011-cv-2831, enumerating 589 that were uploaded to PACER.gov, attached
as Uzamere vs. Cuomo, Memorandum and Order page two (2); 3) lawsuit Viacom
International Inc., et al. v. Youtube, Inc, et
al, Case No. 1:07-CV-2103 (LLS) that explains the conditions associated
with what makes exhibits “voluminous”, PACER Monitor statements describing
Plaintiff's exhibits as “too voluminous” but being vague as to why the 245
pages of exhibits are considered too voluminous, attached as Exhibit R.
Factual
Analysis
133)Since Plaintiff relies on federal
criminal law with regard to RICO, Plaintiff
specifically identifies the racketeering-influenced corrupt organizations
of which Plaintiff speaks. Since 1979, the RICO has done business with the
Plaintiff and her family with dirty hands.17
134)The Defendants reentered their legal
relationship with the Plaintiff and her children with dirty hands.
Defendants' failed relationship with the Plaintiff and her children as
providers of honest, unbiased government-funded services has existed since
1979, and as a direct result of Defendants State of New York, City of New
York, Allen E. Kaye, Esq., Harvey Shapiro, Esq. and Ehigie Edobor Uzamere
act of aggravated identity and theft and immigration fraud have never
provided Plaintiff and her daughter Tara with monies that Plaintiff is
still owed from Defendant Ehigie Edobor Uzamere. Because of the acts of
aggravated identity theft that was facilitated by Defendants the State of
New and the City of New York, and committed by Allen E. Kaye, Esq., Harvey
Shapiro., and Ehigie Edobor Uzamere Plaintiff was subjected to a worsening
of her preexisting mental illness and a distancing from normal society.
Because of the acts of aggravated identity theft that was facilitated by
Defendants State of New York and City of New York, and committed by Allen
E. Kaye, Esq., Harvey Shapiro, Esq., and Ehigie Edobor Uzamere, Plaintiff's
children were forced to remain in Defendant State of New York's foster care
system for nearly all of their lives. David P.
Walker, the older child, suffers from dysthymia and bulimia. Tara A.
Uzamere, child of the marriage, is mentally high functioning, but she lacks
the maternal and paternal care and companionship from which she and her
brother were deprived all of their lives.
Plaintiff suffers from constant shame from never having been a good parent
to her children, who, in spite of Plaintiff's
failure as a parent, are amazingly well-behaved and believers of Jehovah
God. The racketeering-influenced corrupt organizations Defendants the
United States of America, State of New York, City of New York and those
Jews having both positions of power and money, pay bribes to unsuspecting,
greedy Gentile Americans who do not realize that their acceptance of bribes
from Jews makes, not just those who accepted the bribes, but all Gentile
Americans slaves to the Jews forever without the ability to enforce their
Constitutional rights. Plaintiff emphatically states that the force that
unifies the more powerful Jewish Defendants is Judaism, with its emphasis
on the Babylonian Talmud. The Babylonian Talmud provides the religious
rationalization for the Jewish Defendants to enslave both the Plaintiff and
the Gentile Defendants to engage in conduct which is not in the
constitutional interests of the Gentile Defendants – like the doctrine Law
of the Moser, that now requires Gentile slaves to obey their Jewish master
counterparts and keep silent regarding the crimes committed by other Jews.
Understandably, those corrupt Jewish Defendants who engage in bribing
governmental employees feel a sense of entitlement based both on Jews
having paid money for services, and for the Jewish religion that teaches
that Gentiles are meant to be enslaved by Jews. In the article entitled
Come and Hear, under the subtitle “Coexistence?”, it says: “What does the
future hold? Can the Jews ever co-exist with the rest of humanity? The
answer is “yes” provided the rest of humanity accepts the role designed for
them by Jewish leadership. If Gentiles do not accept enslavement, there
will be conflict.” In the subtitle US vs. Talmud Law, it says: “. . .Talmud
law insists on unequal justice under law. Talmudic law holds there is one
law for Jews, and one for Gentiles. This is not inconsistent with the Old
Testament in which LORD God decrees that Jews should not enslave other
Jews: Gentiles are the proper slaves of Jews. See newspaper article from Crains, sealed complaint regarding USA vs. Kruger, et
al and articles entitled Come and Hear, attached as Exhibit T.
135)Defendant
United States of America, by its employee Defendant McCarthy, Bar Counsel
for Defendant U.S. Department of Homeland Security, provided Plaintiff with
a report detailing the two Uzamere18 files A35 201 224 and A24 027 764,
going so far as to indicate that Defendant Ehigie Edobor Uzamere, having
obtained a visa as an unmarried student under 21 years of age and having
been sponsored by his brother and sister-in-law, fraudulently applied for
permanent residence as Plaintiff's husband “Godwin E. Uzamere”, and over
the age of 21. Defendant McCarthy referenced the fingerprints in the two
files which Plaintiff understood to mean were the same. Defendant U.S.
Department of Homeland Security's employee T. Diane Diane
Cejka, former Director of the FOIA/PA Division,
U.S. Citizenship and Immigration Service in Lee Summit, Missouri provided
the Plaintiff with even more irrefutable documentation, including the two
(2) immigration number A35 201 224 and A24 027 764 to establish that
Plaintiff's ex-husband filed for residence under two (2) different
immigration numbers.
136)....Years later, after several
attempts by Defendant judges Jewish judges Michael Gerstein, Jeffrey S.
Sunshine, Arthur M. Schack and Nicholas G. Garaufis and the powerful,
racist Jewish criminal newspaper publisher and editor Mortimer Zuckerman to
prevent Plaintiff from filing criminal complaints against corrupt Jewish
immigration attorneys Allen E. Kaye, Harvey Shapiro and Jack Gladstein by
publicly declaring Plaintiff's incredible based on her status of having
mentally ill with violent tendencies have all but blown up in their faces,
Defendant Garaufis has embarked on yet another equally unoriginal course of
conduct – by saying “I didn't do it!” Plaintiff has responded to that stunt
by filing a criminal complaint against Mortimer Zuckerman, Scott Shifrel and the Daily News, LP for their commission of
aggravated identity theft.
137)Defendant
Garaufis' game plan now is to stop Plaintiff's reliance on the continuing
criminal violations doctrine in its tracks. Defendant Garaufis has
attempted to do this by being willfully blind of his extortionate
psychiatric/criminal “shakedown” of the Plaintiff, and instead, to say that
Plaintiff's mental illness (lacking the threat of violence this time)
caused her to falsely claim that Defendants Garaufis; “John Doe” #1 of the
Federal Bureau of Investigation; LifeNet of the
Mental Health Association of New York City; “John Doe” #2 of the U.S.
Marshals Service for Eastern District of New York; “John Doe” #3 of the
U.S. Marshals Service for Eastern District of New York; “Jane Doe” of the
U.S. Marshals Service for the Eastern District of New York; Bridget Davis
of the New York State Office of Mental Health; “Dr. John Doe” of Brookdale
Hospital and Medical Center; Samuel Sarpong of the East New York Diagnostic
and Treatment Center, Assertive Community and Treatment Team; and Dr. Scott
A. Berger of the East New York Diagnostic and Treatment Center, Assertive
Community and Treatment Team never said that Plaintiff threatened any
federal employee. Defendant Garaufis' attempt is lacking in commonsense
because Plaintiff, who was within the State of New York at the time of the
telephone call, availed herself of New York State's one-party law with
regard to recording in-person or in-telephone conversations, by giving
herself permission to record the conversation with Defendant Bridget Davis,
who was also within the State of New York at the time of the recording.
Plaintiff subsequently uploaded the recorded telephone call to
http://www.thecrimesofsenatoruzamere.net/federallawsuit.htmland noted,
among other things, that Defendant Davis said that Plaintiff threatened
others, that there were others federal agencies that thought Plaintiff was
a danger to others. Plaintiff gave herself permission to record her
conversation with “John Doe” #1 of the Federal Bureau of Investigation,
who, during the aforesaid conversation, extorted Plaintiff not to file any
complaint against anyone Jewish or she would call Plaintiff's daughter,
visit Plaintiff's apartment and (by inference) report Plaintiff's argument
to her psychiatric care providers, which he did. Plaintiff also gave
herself permission to record the conversation and upload it to her web page
http://www.thecrimesofsenatoruzamere.net/uzamere_v_obama.html. In addition,
the same falsified criminal allegations that are contained in the telephone
conversation that Plaintiff uploaded to her web page is written down in
Defendant McGowan's correspondence dated August 18, 2011 and Defendant New
York City Health and Hospitals Corporation psychiatric treatment plan dated
February 26, 2012. And in spite of several years of unconstitutional
treatment at the hands of Defendant Chief Judge Jonathan Lippman's judicial
subordinates, no subordinate judge, starting from Defendant Lippman, has
ever allowed Plaintiff to file any complaint that makes reference to the
aggravated identity theft that was committed by corrupt Jews Allen E. Kaye,
Harvey Shapiro, Jack Gladstein, Mortimer Zuckerman, Scott Shifrel and Ehigie Edobor Uzamere and Osato Eugene
Uzamere.
138)Defendant
McCarthy made no attempt to warn immigration attorneys Allen E. Kaye,
Harvey Shapiro, Jack Gladstein and Osato E. Uzamere to stop holding out
“Godwin E. Uzamere and Ehigie Edobor Uzamere as two (2) different people
even after Plaintiff warned Defendant McCarthy that Defendants Allen E.
Kaye, Harvey Shapiro, Jack Gladstein and the Daily News were still holding
out “Godwin Uzamere” as a real person, and even after Plaintiff provided
Defendants Allen E. Kaye, Harvey Shapiro, Jack Gladstein and Osato E.
Uzamere proof that Ehigie Edobor Uzamere and “Godwin E. Uzamere” are the
same the person. In addition, no employee of Defendant U.S. Department of
Homeland Security ever made any attempt to investigate and then arrest
Defendants Allen E. Kaye, Harvey Shapiro, Jack Gladstein for their
commission of aggravated identity theft. Worse still, in
spite of black letter law that requires federal judges and attorneys
to report the commission of wrongdoing by fellow judges and attorneys, not
one of the defendants, upon receiving irrefutable proof of corrupt
immigration attorneys Allen E. Kaye's, Harvey Shapiro's, Jack Gladstein's and Osato E. Uzamere's commission of
aggravated identity theft, filed a complaint with any law enforcement
agency. Plaintiff's Verified Complaint speaks to, not only separate
criminal acts of the Defendants, but of a pattern of behavior that is
indicative of an anti-U.S. Constitution, pro-Talmud, pro-Jew, anti-Gentile,
anti-schvartze bias that permeates every court in
New York's Second Circuit and the New York State Unified Court System.
Defendant judges, in violation of 18 USC §4, misprision of felony and the
code of conduct for federal and New York State judges that require judges
to report the crimes of attorneys to pertinent law enforcement agencies,
Plaintiff's complaints regarding the commission of aggravated identity
theft go ignored, as well as Plaintiff's complaints regarding those acts of
fraud with regard to the false criminal accusation made against Plaintiff
by Defendant Judge Garaufis, Defendant “John Doe” #1 of the U.S. Marshals
Service for the Eastern District of New York, and/or “John Doe” #2, of the
U.S. Marshals Service for the Eastern District of New York, and/or “Jane
Doe” #3 of the U.S. Marshals Service for the Eastern District of New York,
and Defendant Denis P. McGowan of Defendant the U.S. Department of Homeland
Security, and Defendant Bridget Davis of Defendant the New York State
Office of Mental Health, and Defendants Samuel Sarpong and Dr. Scott A.
Berger of the New York City Health and Hospitals Corporation. The aforementioned Defendants accused Plaintiff of
committing 18 USC §115, threatening a federal employee, something that
Plaintiff never did. On or around January 30, 2013, Plaintiff received
correspondence from the U.S. Department of Health and Human Services'
Centers for Medicare and Medicaid Services. The correspondence indicated
all the telephone calls that Plaintiff made to the call center, and that
Plaintiff made no threatening telephone calls. However, where Plaintiff's
innocence is concerned, it does not matter. Plaintiff holds that there is a
specific hierarchy where the Defendants are concerned. Plaintiff strongly
alleges that the Gentile Defendants' most important responsibility is not
enforcement of the U.S. Constitution, but their ability to worship the
Jewish community as their gods, to serve the Jews as their obedient slaves,
and to ensure that any judicial decision that is rendered is rendered, not
according to the U.S. Constitution, but according to what makes the Jewish
community happy. See correspondence from CMS attached as Exhibit S.
139)Plaintiff has had difficulty in
explaining, well enough for this Court to understand, that there is a
pervasive attitude that fosters and encourages the courts' bestowing on
Jews certain understood, but not mentioned, favors associated with being
white and Jewish. This clandestinely understood right, known as “white skin
privilege”, was openly requested by members of the website
http://www.jewishdefense.org. The site stated: “Contact Stewart Judge: No
White Skin Privilege For Lynne” and: “Click Here
For Printer Friendly Suggested Letter To Judge Koeltl Asking Him Not To
Treat Lynne Stewart Differently Than Her Co-defendants.” Combine these
racist statements with Jewish doctrines about black-skinned people in the
Babylonian Talmud, Tractate 108b, and footnote 34; Midrash Rabbah, page
293; Legends of the Jews, Vol. 1, page 169, Artsot
Ha-Hayyim, pages 52a and 52b, and the Defendants' continued commission of
18 USC §4, misprision of felony with regard to their recalcitrance by not
reporting Ehigie Edobor Uzamere's, Osato Eugene Uzamere's, Allen E. Kaye's,
Harvey Shapiro's, Jack Gladstein's Mortimer
Zuckerman's and Scott Shifrel's commission of
aggravated identity theft, Plaintiff has a justiciable reason not to trust
Judge Koeltl or any other judge in the eastern district, southern district
or the U.S. Court of Appeals for the Second Circuit. See internet article
regarding Lynne Stewart attached as Exhibit W.
140)Plaintiff restates and realleges that
Defendants committed the following offenses and constitutional torts:
misprision of felony, 18 USC §4; fraud, 18 USC §1001; identity theft, 18
USC §1028; aggravated identity fraud, 18 USC §1028A; deprivation of rights
under color of law (including being kidnapped, unlawfully imprisoned and
blacklisted), 18 USC §242/42 USC §1985; extortion, 18 USC §872§, blackmail,
18 USC §873; violation of Title II of the Americans With Disabilities Act;
violation of the Federal Rehabilitation Act of 1973; violation of the Civil
Rights Act of 1964, Title VI, §601; violation of the Free Speech Clause of
the First Amendment; violation of the Establishment Clause of the First
Amendment; violation of the Petition Clause of the First Amendment;
violation of the Due Process Clause of the Fifth and Fourteenth Amendments;
violation of the Notice Clause of the Sixth Amendment; violation of the
Assistance of Counsel Clause of the Sixth Amendment; violation of
Plaintiff's right of privacy with regard to the illegal dissemination of
her psychiatric records, Plaintiff marriage history, Plaintiff married
name, and the non-content information associated with Plaintiff's internet
and telephone accounts; violation of the Equal Protection Clause of the
Fourteenth Amendment, intentional misuse of national security letters
(NSLs) or some manner in which Defendants obtained non-content information
illegally.
141)Plaintiff alleges that although all
the Defendants actively participated in preventing Plaintiff from filing
complaints against Allen E. Kaye, Esq., Harvey Shapiro and Jack Gladstein,
the heart of the conspiracy are the following persons: Defendant Garaufis,
(authorized NSLs/unauthorized telephone investigations that were used to
rationalize dismissal of Plaintiff's civil rights action Uzamere vs. Cuomo,
et al, 11-cv-2831 and 11-2713-cv; Plaintiff's psychiatric hospitalization
in Brookdale Hospital based on threats that Plaintiff never made); “John
Doe” #1 of Defendant FBI (threatened psychiatric hospitalization after
Plaintiff insisted on filing complaint against Jews who violated
Plaintiff's rights, conversation uploaded to
http://www.thecrimesofsenatoruzamere.net/uzamere_v_obama.html; “John Doe” #2, “John Doe #3” and “Jane
Doe” of Defendant U.S. Marshals Service (conversation in which Bridget
Davis stated that the Marshals said that Plaintiff threatened the (federal)
Medicaid Office, uploaded to
http://www.thecrimesofsenatoruzamere.net/federallawsuit); Denis P. McGowan
of Defendant U.S. Department of Homeland Security (sent secret letter to
Samuel Sarpong in which Plaintiff was accused of threatening employees of
the Centers for Medicare and Medicaid Services' call center); Dr. Scott A.
Berger of Defendant New York City Health and Hospitals Corporation; New
York State Judge Michael Gerstein; New York State Justice Jeffrey S. Sunshine
and New York State Justice Arthur M. Schack, Allen E. Kaye, Esq., Harvey
Shapiro, Esq., Jack Gladstein, Mortimer Zuckerman of the Daily News, LP and
Scott Shifrel of the Daily News, LP. In spite of the aforesaid Defendants'
accusation/diagnosis that I threatened Defendant Garaufis, other judges and
employees of CMS, none of the Defendants made any attempt to bring their
allegations to trial, thereby providing Plaintiff with the opportunity to
confront her accusers and prove her innocence.
142)Defendants' engaged in the misprision
of Defendants Allen E. Kaye's, Harvey Shapiro's, Jack Gladstein's,
NYS Justice Jeffrey S. Sunshine, NYS Justice Arthur M. Schack, Mortimer
Zuckerman and federal Judge Nicholas G. Garaufis' act of identity theft of
the name “Mrs. Ehigie Edobor Uzamere,” so that the child of the marriage
Tara A. Uzamere was subsequently deprived of her right by consanguinity to
bear her father, Defendant Ehigie Edobor Uzamere's name; that Plaintiff and
child of the marriage Tara A. Uzamere and David P. Walker, stepson of
Defendant Ehigie Edobor Uzamere were deprived of the legal, social and
financial benefits of bearing the proud African/Nigerian/Edo/Bini name of
Defendant Ehigie Edobor Uzamere; that Defendants continue to engage in
misprision of felony to hide Defendant Ehigie Edobor Uzamere's misuse of
the social security numbers XXX-XX-2291, the fictitious social security
number under which the entity “Godwin Ehigie Uzamere” was searched by the
New York City Department of Social Services' Bureau of Child Support
Enforcement; XXX-XX-7854, the number under which Ehigie Edobor Uzamere owes
a student loan (this may be George Uzamere's social security number); and
XXX-XX-1205, the number under which “Godwin Ehigie Uzamere” actually filled
out a filled out an application for a social card is prima facie evidence
that governmental agencies viewed “Godwin Uzamere” and “Ehigie Edobor
Uzamere” as two different persons.
143)Plaintiff asks this Court to do
something that this Court has probably never done before: to review the
facts regarding the Jewish Defendants wholistically.
This means rendering a judgment, not just based on what they've done, but
based on what they intend to do because of their religion. The Plaintiff
asks this Court not to be tricked by the fraudulent statement that the
Jewish Defendants and other Jews who have committed crimes against Gentiles
had different intentions. This is a boldfaced lie. The criminal acts of the
Jewish Defendants and the crimes committed against Gentiles by other Jews
may be different but there is only mind. The intention is always the same
because the mindset is the same: preventing anti-Semitism in order to save the Jewish nation at all cost, and to
prevent anti-Semitism by enslaving Gentiles at all cost.
144)In Plaintiff's Appellate Affidavit in
Support of Judicial Recusal of Defendant Garaufis for the lawsuit Uzamere
v. Cuomo, et al, 1:2011-2713-cv, Plaintiff stated the following:
“I allege that
Judge Garaufis' bias is an act of malice; however, I allege that Judge
Garaufis' act of malice is secondary to the terror and rage that he and
many of Israel's adult children continue to suffer as a result of the Roman
government's/Catholic Church's 2,000-year holocaust to eradicate the memory
of the Jewish Nation from the planet Earth, starting with the destruction
of Jerusalem's 2nd temple in 70 C.E., where 1,100,000 innocent Jews were
slaughtered and 97,000 were taken captive, and culminating with the
slaughter of 6,000,000+ innocent Jews in Catholic-controlled Nazi Germany.
I allege that based on Judge Garaufis' various knee-jerk reactions to my
lawsuit, like so many of the adult children of European Jews, he is
terrified that yet another goy
is going to hurt him and the Jewish Defendants. I make this allegation, not
to challenge the learning and experience of psychoanalytical and
psychiatric professionals, but because I am suffering something akin to
post traumatic stress disorder, so I understand and sympathize with Judge
Garaufis and European Jews' terror and rage at being oppressed again by
non-Jews.
While I
sympathize with the terrors that Israel's children suffered and continue to
suffer at the hands of unscrupulous non-Jews, this Court, in its wisdom,
must not allow Judge Garaufis' legitimate fear of anti-Semitism to be used
as a rationalization to excuse the tortious and criminal conduct of the
Defendants, or to continue to hurt me or my children. Defendant law firm
Allen E. Kaye, PC mounted an unprovoked attack on me and my children on
November 30, 1979 by facilitating my ex-husband's commission of immigration
fraud and identity fraud, preventing us from obtaining money from my
ex-husband to live. I had to put my children in foster care. In 2008, a
year after I filed my divorce from my-husband, Defendant law firm Uzamere
and Associates, PLLC, its owner being a blood relative of my ex-husband,
was then enlisted to discredit my story as the rantings of an insane woman.
In 2009, the following year, Defendant law firms Allen E. Kaye, PC, the Law
Offices of Harvey Shapiro and Gladstein and Messinger,
knowing my ex-husband's true identity, submitted fraudulent affirmations
falsely holding my ex-husband out to be “Godwin Uzamere” even after the
U.S. Citizenship and Immigration Service and the New York State Unified Court
Systems' Second Judicial Department held that Senator Ehigie Edobor Uzamere
was my husband and is the father of our daughter, Tara. Judge Garaufis'
attempts to come to the rescue of fellow Jewish Defendants to save them
from the machinations of an anti-Semitic litigant are more than misplaced.
They are now malicious. I am not Hitler, and if Defendant Allen E. Kaye, PC
had not engaged in its original criminal act by tricking me for the sole
purpose of helping his client get a green card, thereby denying me and my
daughter the right to be identified by my ex-husband's and Tara's father
African name and to receive money from him for our care, I would not be
litigating against the Jewish Defendants. My litigation against the
Defendants has no basis in anti-Semitism. The Defendants broke the law.
Judge Garaufis' use of the term “frivolous and malicious” is truthful – but
his use of the term does not have its basis in the Federal Rules of Civil
Practice. I allege that it is in Judge Garaufis' culture's
to rule that Jews must defend themselves from the anti-Semitic machinations
of non-Jews at all costs – even if it means violating the legal rights of a
non-Jew. Judge Garaufis' decision is therefore an act of bias that has its
basis in my ethnicity as a member of the goyim.”
145)In the criminal case of People of the
State of New Jersey vs. Jesse K. Timmendequas,
during the death penalty phase, an “August 1995 videotape – made during an
interview at their mother's South Carolina trailer – came as the defense
sought to show that the childhood years of Jesse Timmendequas
were so horrific that he should not be sentenced to death for the sexual
assault and murder of 7-year-old Megan Kanka. New
Jersey's state court abolished the death penalty in 2007, converted to a
life sentence with no possibility of parole and uphold his life sentence
for kidnapping Megan Kanka. The court did not
render its decision based on mercy because Mr. Timmendequas
was sexually victimized by in father when he was young boy. See
http://articles.philly.com/1997-06-11/news/25526762_1_sexual-assault-jesse-james-sexual-abuse.
146)This Court
must now must differentiate between the complaints
of a person who is being victimized now between the complaints of a bully
whose forebears were crime victims but he himself is not. If this Court
treats the Defendants wholistically, it will see
a pattern of behavior indicative of a predator who has thrown moral, social
and legal convention to the wind and preys on Gentiles with impunity.
Examples of such predatory behavior by members of the Jewish community
include the following:
The lawsuit
Stephen Unterberg v. Jimmy Carter, Case 1:11-cv-00720-TPG; said the
following on page 2: “. . .In truth, however, the book is filled with
demonstrable falsehoods, omissions, and knowing misrepresentations intended
to promote carter's agenda of anti-Israel propaganda. . .According to John
Turley's article entitled “A Basis for Damages or Sanctions? Jimmy Carter
Sued Over His Book on Palestine, he says: “Former President Jimmy Carter
has been named in a disturbing and clearly frivolous lawsuit over over his representations on the Israeli-Palestinian
Apartheid.” The five plaintiffs are seeking $5 million, but, in my view,
should be held by Rule 11 sanctions in filing a vexatious and frivolous
lawsuit. See
http://jonathanturley.org/2011/02/16/jimmy-carter-sued-over-his-book-on-palestine/
Common use of
the term “nigger” that white-skinned Jews used to address Ethiopian Jews.
Seehttp://www.irinnews.org/report/94819/israel-the-tribulations-of-being-an-ethiopian-jew.
•
o Jewish laws that teach the
following doctrines:
The
murder of Gentile is less severe than the murder of a Jew;
Ban
on returning a Gentile's lost item if the reason for returning it is
sympathy for the Gentile;
If
a Gentile accidentally overpays a Jew, the Jew does not have to give the
money back;
One
who kills a Gentile is exempt; one who kills a Jew is put to death;
A
Jew who hurts or injures a Gentile is not liable for compensation or
damages;
Only
Jews can rule over Jews, not Gentiles, not even a Jewish convert;
The
prohibition to hate applies only to Jews; one may hate a Gentile; see
http://www.come-and-hear.com/supplement/so-daat-emet/index.html;
According
to Babylonian Talmud, Tractate Baba Kamma, folio
113A, when a lawsuit occurs between a Jew and a Gentile, a Jew can use
deceit (subterfuge) against the Gentile to fool him/him;
There
is no equality between Jews and Gentiles;
Gentiles
are the proper slaves of Jews;
In
Jewish law, Jews are hard to convict; Gentiles are easy to convict;
o Law Licensing Statuses:
The
Jew-controlled judiciary will not reinstate the law license of
African-American C. Vernon Mason, who was never convicted or even accused
of a crime, and has been disbarred for 18 years; however there is a
petition signed by over 70,000 Jews to release convicted Jewish spy
Jonathan Pollard, who admitted on spying on the United States government
for Israel; see en.wikipedia.org/wiki/C._Vernon_Mason;
also seehttp://www.petitionbuzz.com/petitions/freepollard;
Alton
H. Maddox, Jr., who never was convicted or even accused of a crime, has
been disbarred since 1990; seeen.wikipedia.org/wiki/Alton_Maddox;
Jewish
Solomon Wachtler, Esq., who was convicted and
imprisoned for stalking his former lover, had his law license reinstated;
seehttp://blogs.wsj.com/law/2007/10/03/sol-wachtler-got-his-law-license-back;
Jewish
Eliot Spitzer, Esq., who committed adultery (NYS Pen. Law §255.15, Bigamy
is a class B misdemeanor) by paying a prostitute for sex (isn't paying for
sex illegal all over the United States?), currently running for Mayor of
New York;
Jewish
Anthony Weiner, having admitted to recently uploading more pictures to the
internet (see attached internet photo of him sitting on the toilet with his
penis exposed; currently running for Mayor of New York;
o Law of the Moser:
See
http://theawarenesscenter.blogspot.com/2012/12/attack-against-rabbi-nuchem-rosenberg.html
regarding Rabbi Nuchum Rosenberg. A member of the
ultra-orthodox Jewish community threw bleach or some other chemical in
Rosenberg's face. Rabbi Rosenberg has since been labeled a moser by members of his community;
Reverend
Israel Dwek renounces his son, Shlomo Dwek as a moser because he reported several lawbreaking Jews to
the secular authorities;
seehttp://www.nypost.com/p/news/regional/item_XezdmX81B2uEHc6euKYWFP, See
Exhibit W1 for exhibits also listed as websites;
The
brokering and sale of body parts by Jews;
http://cannonfire.blogspot.com/2009/07/butchers-hidden-truth-about-israels.html.
Rabbi Levy Izhak Rosenbaum of Brooklyn was
accused by the FBI of conspiring to broker the sale of human kidney for a
transplant. According to the complaint, Rosenbaum said he has been
brokering the sale of kidneys for 10 years.
147)There is a
major similarity between the illegal acts committed by the Defendants and
by the Jews in those aforementioned acts. That
similarity is intent. In the case of all the individuals, their intent is:
1) to allow the unconstitutional encroachment of the Jewish religion; 2) to
devalue and dehumanize Gentiles as a means to rationalize Jews' illegal
acts; 3) to rely on the Talmudic doctrine Law of the Moser to ensure that
Jews do not report the illegal acts of lawbreaking Jews to the secular
(Gentile) authorities, and to ensure that those Gentiles who attempt to
report the illegal acts of lawbreaking Jews are stopped by fellow Jews; and
4) to hold uncooperative Gentiles out as anti-Semites deserving of a social
death or as close to a real death as possible. The Jew-controlled New York
State judiciary will never allow C. Vernon Mason and Alton Maddox to retain
their law licenses, even in front of the glaring acts of crimes of sexual
dysfunction by Jews Sol Wachtler, Eliot Spitzer
and Andrew Weiner, who, as the Court considers Plaintiff's lawsuit, is
running for Mayor of New York and electronically sending out photos of his
penis while he is sitting on the toilet at the same time. There is the
lawsuit that members of the Jewish community filed against a former U.S.
President for having what amount to be an opposing opinion about Israel.
There is the case of brave Rabbi Nuchum
Rosenberg's who has suffered mightily because his legal stance against the
Talmudic doctrine Law of the Moser, at the expense of vision in his left
eye, being shot in his head by a BB gun, and being shunned by members of
his community for reporting acts of child abuse to the secular authorities
Lastly, also mentioned are various halachic doctrines that hold Gentiles
out to be worthless, not on equal standing with Jews legally, socially or
in any way that allows Gentiles to be considered “men.”
148)The sum
total of Plaintiff's living in an atmosphere where predatory Jews make
fraudulent reference to real acts of anti-Semitism that took place in the
past in order to hide their illegal predation of Plaintiff and her
children, based on the encroachment of racist Jewish religious doctrines
Curse of Dark Skin and Law of the Moser, has caused thirty-four (34) years
of deprivation of Plaintiff and her family's constitutional, civil,
marital, parental, social and financial rights. The Defendants' have
staunchly refused to overtly acknowledge the legal relationship between
Plaintiff, her children, and Defendant Ehigie Edobor Uzamere, and have
instead, referred to the same, tired, old excuse of anti-Semitism to hide
their crimes and to continue to prey on Plaintiff and her children. For
thirty-four (34) years, Plaintiff and her children were condemned to the
same Jewish religious generational curse that condemned millions of
enslaved Africans to the permanent loss of their parents' proper African
names, languages and customs associated with those names, and the wealth
and social status that would have passed on to African children had they been
able to bear their African forefathers' names. Because of the Defendants'
determination to stop Plaintiff from reporting the original crimes that
were perpetrated by those Defendants who helped Plaintiff's ex-husband
commit fraud and aggravated identity theft, Plaintiff and her children are
now victims in a hateful, racist environment that forgives and gives second
chances to lawbreaking Jews, forever condemns the descendants of African
slaves for being dark-skinned, and like the pedophile Jesse Timmendaguas, use past incidents of anti-Semitism to
rationalize their abusive, hateful, predatory behavior towards Gentiles.
149)By reason of the foregoing
irrefutable allegations, Plaintiff asserts that there exists a justiciable
controversy with respect to which Plaintiff is entitled to the relief
prayed for herein.
FIRST CLAIM
FOR RELIEF
First
Amendment Mandate
Separation of
Church and State
150)Plaintiff
repeats and realleges the above paragraphs.
151)With
regard to all natural Defendants, this claim is brought
against them individually and in their official capacities.
152)Plaintiff
is an American citizen with a serious and persistent mental illness.
Plaintiff has a mental impairment that substantially limits one or more
major life activities.
153)Plaintiff
is a qualified individual with disabilities within the meaning of 42 U.S.C.
§12131(2).
154)Plaintiff
is a descendant victim of the African Holocaust in which Africans, whose
sale was brokered by Jews and kidnapped by whites, forever lost the ability
to bear the correct paternal name of her African male forebears; and having
married Defendant Ehigie Edobor Uzamere, now retains the right from now to
eternity to have borne and to bear the name of Defendant Ehigie Edobor
Uzamere, as does Tara A. Uzamere, the adult child of the marriage between
Plaintiff and Defendant Ehigie Edobor Uzamere and blood heir with the legal
right to bear, and for her progeny to bear the correct Edo/Bini name and
culture associated with Defendant Ehigie Edobor Uzamere.
155)Defendants
owed Plaintiff and her family the duty, pursuant to 5 USC §3331, to support
and defend the Constitution of the United States against all enemies,
foreign and domestic; to bear true faith and allegiance to the same; to
take said obligation freely, without any mental reservation or purpose of
evasion; and to well and faithfully discharge the duties of the office on
which Defendants entered. This requires the Defendants to establish a clear
separation of church and state, and to distance themselves from the
Talmudic Law of the Moser in their application and enforcement of the law.
Defendants owed Plaintiff and her children the duty to give themselves over
to the transparency of U.S. law, and not the secrecy of the Talmudic Law of
the Moser.
156)Defendants
failed in their duty to meet their legal obligations as detailed by the
First Amendment mandate regarding the separation of church and state.
Defendants, at the behest of Defendant Garaufis and other Jewish judiciary
Defendants have conspired to force the tenets of the Talmud and other
Jewish religious dogma on the Plaintiff based on the Talmud's viewpoint of
the Plaintiff's as a gentile/non-Jewish, African-American/schvartze slave to prevent Plaintiff from filing civil
and criminal complaints against corrupt immigration attorneys Allen E.
Kaye, Harvey Shapiro and Jack Gladstein.
157)Plaintiff
suffered and continues to suffer injury because she is still under attack
by all the Defendants, who, at the clandestine behest of Defendants Judge
Garaufis, Judge Schack, Judge Sunshine and Judge Gerstein, have continued
the same government-wide hostile environment that Plaintiff complained
about in her prior lawsuits, Uzamere vs. Uzamere (Plaintiff's divorce
action) and Uzamere vs. Cuomo, et al, 11-cv-2831/11-2713-cv. Plaintiff has
been forced by Defendant Garaufis to obey the Talmud, Tractate Abodah Zarah, folio 26b,
Tractate Sanhedrin, folio 108b and footnote 34; Jewish doctrine Law of the
Moser, the doctrine that prohibits anyone from reporting the crimes of Jews
to secular, Gentile authorities; and the Curse of Black Skin, the doctrine
that requires people of dark-skinned African descent to be obedient to Jews
and white people because dark-skinned Africans are meant to be slaves. In
Plaintiff's prior lawsuit Uzamere vs. Cuomo, et al Case Nos.
11-cv-2831/11-2713-cv, Plaintiff provided Defendant Garaufis with proof
that employees of Defendant New York State conspired with Defendant Shifrel of Defendant Daily News, LP , to defame the
Plaintiff as an “anti-Semitic wacko”, to illegally publicize Plaintiff's
psychiatric and marital information to give their false publicized
statement regarding Plaintiff's ex-husband being “Godwin Uzamere”
believability. Defendant Garaufis violated Plaintiff's rights in the same
manner by relying on the Talmud, Tractate Abodah Zarah, folio 26b and the Talmudic doctrine Law of the
Moser, not the U.S. Constitution to prevent the Plaintiff from reporting
the commission of aggravated identity theft by corrupt Jewish attorneys
Allen E. Kaye, Harvey Shapiro and Jack Gladstein.
158)The courts
of Defendant United States of America recognize excessive entanglement of
religion as an injury. In the case Lemon v. Kurtzman, 403 U.S. 602 (1971),
the Supreme Court ruled that government may not “excessively entangle” with
religion. The case involved two Pennsylvania laws: one permitting the state
to “purchase” services in secular fields from religious schools, and the
other permitting the state to pay a percentage of the salaries of private
school teachers, including teachers in religious institutions. The Supreme
Court found that the government was “excessively entangled” with religion, and invalidated the statutes in question.
159)Plaintiff
submits that Defendants' violation of the First Amendment's Mandate to keep
church and government separate also violates the Due Process Clause of the
Fifth and Fourteenth Amendments, the Equal Protection Clause of the
Fourteenth Amendment and 42 USC §1985, conspiracy to interfere with civil
rights, such that Plaintiff's Verified Complaint rises to the level of an
action in the manner of Bivens v. Six Unknown Named Agents of Federal
Bureau of Narcotics, 403 U.S. 388 with regard to those Defendants who are
natural persons. Plaintiff understands the U.S. Supreme Court's application
of Bivens to natural persons and its refusal to extend Bivens to agencies.
SECOND CLAIM
FOR RELIEF
Defendants
Violated The Americans With Disabilities Act
Mandate
160)Plaintiff
repeats and realleges the above paragraphs.
161)With
regard to all natural Defendants, this claim is
brought against them individually and in their official capacities.
162)Plaintiff
is an American citizen with a serious and persistent mental illness.
Plaintiff has a mental impairment that substantially limits one or more
major life activities.
....163)Plaintiff
is a qualified individual with disabilities within the meaning of 42 U.S.C.
§12131(2).
....164)Plaintiff is a descendant victim
of the African Holocaust in which Africans, whose sale was brokered by Jews
and kidnapped by whites, forever lost the ability to bear the correct
paternal name of her African male forebears; and having married Defendant
Ehigie Edobor Uzamere, now retains the right from now to eternity to have
borne and to bear the name of Defendant Ehigie Edobor Uzamere; and that the
aforesaid right is retained by Tara A. Uzamere, the adult child of the
marriage between Plaintiff and Defendant Ehigie Edobor Uzamere., and for
her progeny to bear the correct Edo/Bini name and culture associated with
of Defendant Ehigie Edobor Uzamere.
165)Defendants
owed Plaintiff the duty, pursuant to Title II of the Americans With
Disabilities Act, to prohibit the practice of disability discrimination. As
public entities, Defendants owed Plaintiff the duty to comply with Title II
regulations by the U.S. Department of Justice. These regulations cover
access to all programs and services offered by the entity. Access includes
physical access described in the ADA Standards for Accessible Design and
programmatic access that might be obstructed by discriminatory policies or
procedures of the entity.
166)Defendants
failed in their duty to meet the obligations as detailed in Title II of the
Americans With Disabilities Act. Defendants continue to discriminate
against Plaintiff based on Plaintiff's status of having a mental illness
because Plaintiff will not stop filing complaints against corrupt Jews
immigration attorneys Allen E. Kaye, Harvey Shapiro and Jack Gladstein.
167)Plaintiff suffered and continues to
suffer injury because Plaintiff is still under attack by all the Defendants,who, at the clandestine behest of Defendant
Garaufis, Judge Schack, Judge Sunshine and Judge Gerstein, have continued
the same government-wide hostile environment that Plaintiff complained
about in her prior lawsuit, Uzamere vs. Cuomo, et al,
11-cv-2831/11-2713-cv. Defendants continue to discriminate against
Plaintiff by using Plaintiff's status of having a mental illness to falsely
and to publicly hold out that judicial Defendants will not allow Plaintiff
to file criminal and civil complaints against corrupt Jewish Defendants
corrupt immigration attorneys Allen E. Kaye, Harvey Shapiro and Jack
Gladstein because Plaintiff's complaints are unintelligible based on her
status of having a mental illness.19, 20, 21. Defendants New York State,
New York State Office of Mental Health, New York City, New York City Health
and Hospitals Corporation, Brookdale Hospital Medical Center and their
employees intentionally misdiagnosed Plaintiff as psychotic and violent so
as to deprive Plaintiff of her right to due process and equal protection
under the law. Defendants accused Plaintiff of the commission of 18 USC
§115, threatening a federal employee and discriminated against the
Plaintiff by using her status of having a mental illness as an excuse to
deprive her of the right to defend herself in criminal court against said
criminal charges. Proof of Defendant New York State's and New York City's
continued conspiracy to attack the Plaintiff based on her status of having
a mental illness is at
http://articles.nydailynews.com/2009-11-05/local/17938323_1_supreme-court-judge-criminal-court;
andhttp://www.law.com/jsp/article.jsp?id=1202435221996&slreturn=20120729115138;
see Daily News article dated November 5, 2009 in which staff writer Scott
Shifrel publicly defames Plaintiff as a “wacko.”
168)The courts
of Defendant the United States of America recognize discrimination based on
disability as an injury. The Supreme Court held in Olmstead v. L.C., 527
U.S. 581 (1999), that “[u]njustified isolation .
. . is properly regarded as discrimination based on disability,” observing
that “institutional placement of persons who can handle and benefit from
community settings perpetuates unwarranted assumptions that persons so
isolated are incapable of or unworthy of participating in community life.”
527 U.S. at 597, 600.
....169)Plaintiff submits that Defendants'
violation of the Title II, Americans With Disabilities Mandate to integrate
Plaintiff also violates the Due Process Clause of the Fifth and Fourteenth
Amendments, the Equal Protection Clause of the Fourteenth Amendment and 42
USC §1985, conspiracy to interfere with civil rights, such that Plaintiff's
Verified Complaint rises to the level of an action in the manner of Bivens
v. Six Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388
with regard to those Defendants who are natural persons. Plaintiff
understands the U.S. Supreme Court's application of Bivens to natural
persons and its refusal to extend Bivens to agencies.
THIRD CLAIM
FOR RELIEF
Defendants
Violated Sixth Amendment Mandate
....170)Plaintiff
repeats and realleges the above paragraphs.
171)With
regard to all natural Defendants, this claim is
brought against them individually and in their official capacities.
172)Plaintiff
is an American citizen with a serious, persistent mental illness. Plaintiff
has a mental impairment that substantially limits one or more major life
activities.
173)Plaintiff
is a qualified individual with disabilities within the meaning of 42 U.S.C.
§12131(2).
174)Plaintiff
is a descendant victim of the African Holocaust in which Africans, whose
sale was brokered by Jews and kidnapped by whites, forever lost the ability
to bear the correct paternal name of her African male forebears; and having
married Defendant Ehigie Edobor Uzamere, now retains the right from now to
eternity to have borne and to bear the name of Defendant Ehigie Edobor
Uzamere; and that the aforesaid right is retained by Tara A. Uzamere, the
adult child of the marriage between Plaintiff and Defendant Ehigie Edobor
Uzamere, and for her progeny to bear the correct Edo/Bini name and culture
associated with Defendant Ehigie Edobor Uzamere.
175)On or
around June 22, 2011, Defendant Garaufis rendered in decision for
Plaintiff's civil rights action which said the following:
“Plaintiff's
most recent Complaint—one of at least five she has filed with this court—is
89-pages long and is accompanied by 589 pages of exhibits. Plaintiff has
also sent at least 60 pages of faxes directly to chambers, purporting to be
in connection with her most recent action. The substance of Plaintiffs
Complaint—if one can be discerned—concerns, among other things, her divorce
from Ehigie Edobor Uzamere; a defamation claim filed against the Daily
News; a Departmental Disciplinary Committee complaint filed against the
attorney representing the Daily News; and other state court actions,
including a state court action against the attorneys who represented her
former husband. (Compi. at 27-45.) Plaintiff has
a long, tired history of vexatious litigation in this court. See Uzamere v.
State of New York, No. 09-cv-2703 (E.D.N.Y. July 9, 2009).”
Defendant
Garaufis' judgment regarding Plaintiff's civil rights action was biased. It
did not address the acts of fraud, identity theft or aggravated theft
perpetrated by corrupt Jewish attorneys Allen E. Kaye, Harvey Shapiro and
Jack Gladstein that Plaintiff proved in her civil rights action Nor did Defendant Garaufis' address Plaintiff's
contentions regarding the Court's discrimination against Plaintiff based on
her having a mental illness. Defendant Garaufis' judicial commentary did
not address most of the issues Plaintiff discussed in her civil rights
action (“. . .a unanimous Supreme Court has admonished that pro se in forma
pauperis complaints must be read with tolerance: Dismissal is impermissible
unless the court can say “with assurance that under the allegations of the
pro se complaint, which we hold to less stringent standards than formal
pleadings drafted by lawyers, it appears 'beyond doubt that the plaintiff
can prove no set of facts in support of his claim which would entitle him
to relief.'” Haines v. Kerner, 404 U.S. 519, 520-21, 92 S.Ct. 594, 595-96,
30 L.Ed.2d 652 (1972), quoting Conley v. Gibson, 355 U.S. 41, 45-46, 78
S.Ct. 99, 101-102, 2 L.Ed.2d 80 (1957), reaffirmed in Estelle, 429 U.S. at
106, 97 S.Ct. at 292.) The judgment condemned the Verified Complaint's
number of pages and the numbers of complaints Plaintiff filed with the
Court (“. . .but a complaint filed in forma pauperis is not subject to
dismissal simply because the plaintiff is litigious. The number of
complaints a poor person files does not alone justify peremptory dismissal.
In each instance, the substance of the impoverished person's claim is the appropriate
measure. Crisafi v. Holland, et al, 655 F2d 1305)
Defendant Garaufis admits that he has difficulty in understanding the
substance of Plaintiff's complaint based on his statement: “The substance
of Plaintiff's Complaint – if one can be discerned. . .” Defendant
Garaufis' displayed even more mean-spirited bias with regard to all of
Plaintiff's actions when he said in his statement: “Plaintiff has a long,
tired history of vexatious litigation in this court. Defendant Garaufis
engaged in an act of racketeering, obstruction of justice and criminal
facilitation of aggravated identity theft by rendering an FRCP-lacking,
memorandum-lacking decision regarding Uzamere vs. Cuomo, et al, 11-CV-2831
for the sole purpose of: 1) advancing the Talmudic doctrine Law of the
Moser; 2) not filing a criminal complaint against corrupt, dishonest,
lying, racketeering, racist Jewish immigration attorneys Allen E. Kaye,
Harvey Shapiro and Jack Gladstein for their fraudulent commission of 3)
trick Plaintiff into believing that a res judicata determination – a purely
civil adjudicative function – was a permanent and final determination to
nullify and render harmless corrupt Jewish attorneys Allen E. Kaye's,
Harvey Shapiro's, Jack Gladstein's, and Mortimer
Zuckerman's and Scott Shifrel's commission of
aggravated identity theft – a wrongful act for which the correct criminal
adjudicative function of double jeopardy was never attached because the
crime was never tried; and, 4) Defendant Bloom's commission of misprision
of felony racketeering, obstruction of justice, criminal facilitation of
aggravated identity theft and fraud upon the court as well.
176)Defendants
owed Plaintiff the duty, pursuant to the Sixth Amendment, to provide
Plaintiff with defense counsel and witnesses in Plaintiff's favor, More importantly, Defendants owed Plaintiff the right to
confront Defendants' adversarial witnesses in order to prevent Plaintiff
from being prosecuted based on what turned out to be the falsified hearsay
of the Defendants.
177)Defendants
failed to meet the obligations as detailed in the Sixth Amendment.
Defendants accused Plaintiff of the commission of 18 USC §111(a), simple
assault and 18 USC §115, threatening federal employees and then deprived
Plaintiff of her Sixth Amendment rights to notice of accusation, witnesses
and appointment of defense counsel even though Defendants' criminal
accusation against the Plaintiff required them to file a criminal complaint
pursuant to 18 USC §4, misprision of felony. Plaintiff strongly alleges
that Defendant Garaufis, in orchestrating the conspiracy with Defendant
U.S. Marshal Service, Defendant Denis P. McGowan of Defendant the U.S.
Department of Homeland Security, and defendants of the New York State and
New York City mental health agencies, has opened the
means by which, at any of the Defendants can accuse Plaintiff of any
crime and prevent Plaintiff from speaking to an attorney. Plaintiff alleges
that the only way that Plaintiff can avoid Defendants' intimidation, false
criminal allegations and Defendants ' use of psychiatric inpatient
hospitalization as a substitute for prison is by keeping silent and not
filing papers against corrupt Jewish immigration attorneys Allen E. Kaye,
Harvey Shapiro and Jack Gladstein.
178)Plaintiff
has suffered and continues to suffer injury because she is still under
attack by all the Defendants, who, at the clandestine behest of Defendant
Garaufis, have continued the same government-wide hostile environment that
Plaintiff complained about in her prior lawsuit, Uzamere vs. Cuomo, et al,
11-cv-2831/11-2713-cv. Defendants continue to wrongfully accused Plaintiff
of the commission of 18 USC §115, threatening federal employees; nor have
the Defendants sent correspondence apologizing for wrongfully accusing
Plaintiff of a crime she did not commit; however, Defendants continue to
deprive Plaintiff of the right to be informed in writing of the nature and
cause of the criminal accusation Defendants raised against Plaintiff, to
allow Plaintiff to confront adversarial witnesses and witnesses in
Plaintiff's defense, and to have the assistance of counsel. In Plaintiff's
prior lawsuit Uzamere vs. Cuomo, et al Case Nos. 11-cv-2831/11-2713-cv,
Plaintiff provided Defendant Garaufis with proof that Defendant New York
State conspired with Defendant Daily News, by Defendant former staff writer
Scott Shifrel to defame Plaintiff as a “wacko”,
to hold Plaintiff out at a violent criminal for a crime or which Plaintiff
was eventually declared not guilty – as she was declared not guilty when
Defendant McCarthy – a federal attorney – falsely accused Plaintiff of
committing 18 USC §111(a), simple assault – while Plaintiff was 260 miles
away in Brooklyn, New York. Defendant Garaufis and the other Defendants –
most of whom are Jews, have revisited the same act of fraud for the same
reason – to enforce the Jewish religious doctrine Law of the Moser to
prevent Plaintiff from filing complaints against corrupt Jewish attorneys
Allen E. Kaye, Harvey Shapiro and Jack Gladstein, who hid and continue to
hide their aggravated identity theft on behalf of their client, Defendant
Ehigie Edobor Uzamere, thereby depriving Plaintiff and her daughter Tara of
the right to bear Defendant Ehigie Edobor Uzamere's name.
179)The courts
of Defendant United States of America recognizes a
poor defendant in a criminal case that does not have counsel as an injury.
proceeding In Johnson v. Zerbst, 304 U.S. 458
(1938), the Supreme Court ruled that in all federal cases, counsel would
have to be appointed for defendants who were too poor to hire their own.
180)The courts
of Defendant the United States of America recognize that a criminal
defendant not having been given a notice of accusation an injury.
Individuals who have been accused of a serious federal offense have the
right to be informed of the nature and cause of the accusation against him.
The Supreme Court held in United States v. Carll,
105 U.S. 611 (1881) that “in an indictment ... it is not sufficient to set
forth the offense in the words of the statute, unless those words of themselves
fully, directly, and expressly, without any uncertainty or ambiguity, set
forth all the elements necessary to constitute the offense intended to be
punished.” In Crawford v. Washington, 541 U.S. 36 (2004), the Supreme Court
increased the scope of the Confrontation Clause by ruling that
“testimonial” out-of-court statements are inadmissible if the accused did
not have the opportunity to cross-examine that accuser and that accuser is
unavailable at trial.
181)Plaintiff
submits that Defendants' violation of the Sixth Amendment's mandate to
provide the accused Plaintiff with witnesses, and with an attorney for her
defense also violates the Due Process Clause of the Fifth and Fourteenth
Amendments, the Equal Protection Clause of the Fourteenth Amendment and 42
USC §1985, conspiracy to interfere with civil rights, such that Plaintiff's
Verified Complaint rises to the level of an action in the manner of Bivens
v. Six Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388
with regard to those Defendants who are natural persons. Plaintiff
understands the U.S. Supreme Court's application ofBivens
to natural persons and its refusal to extend Bivens to agencies.
FOURTH CLAIM
FOR RELIEF
Civil Rights
Act of 1964, Title VI, §601
Nondiscrimination
in Federally Assisted Programs
182)Plaintiff repeats and realleges the
above paragraphs.
183)With regard to all
natural Defendants, this claim is brought against them individually
and in their official capacities.
184)Plaintiff is an American citizen with
a serious and persistent mental illness. Plaintiff has a mental impairment
that substantially limits one or more major life activities.
185)Plaintiff is a qualified individual
with disabilities within the meaning of 42 U.S.C. §12131(2).
186)Plaintiff is a descendant victim of
the African Holocaust in which Africans, whose sale was brokered by Jews
and kidnapped by whites, forever lost the ability to bear the correct
paternal name of her African male forebears; having married Defendant
Ehigie Edobor Uzamere, Plaintiff now retains the right from now to eternity
to have borne and to bear the name of Defendant Ehigie Edobor Uzamere; and
that the aforesaid right is retained by Tara A. Uzamere, the adult child of
the marriage between Plaintiff and Defendant Ehigie Edobor Uzamere, and for
her progeny to bear the correct Edo/Bini name and culture associated with
Defendant Ehigie Edobor Uzamere.
187)Defendants owed Plaintiff the duty,
pursuant to the Civil Act of 1964, §601, to ensure that no person in the
United States, including the Plaintiff, shall be excluded from
participation in or otherwise discriminated against on the ground of race,
color, or national origin under any program or activity receiving Federal
financial assistance.
188)Defendants failed to meet the
obligations as detailed in the Civil Rights Act of 1964. Defendants
discriminated and continue to discriminate against Plaintiff based on the
Talmudic view of Gentiles in general, and blacks in
particular. Plaintiff's ethnicity as a gentile/African-American/schvartze. See documentation regarding the Curse of
Dark Skin and Law of the Moser attached asExhibit
Q. In addition, while refusing to accept from the Plaintiff irrefutable
proof of Jews Allen E. Kaye's, Harvey Shapiro's, Jack Gladstein's,
Mortimer Zuckerman's and Scott Shifrel's
commission of misprision of felony, fraud, identity theft, aggravated
identity theft, racketeering, obstruction of justice and
extortion/blackmail, Defendant Barack H. Obama, Andrew Weissman, General
Counsel for Defendant Federal Bureau of Investigation, James X. Dempsey,
Defendant, Privacy and Civil Liberties Oversight Board; Elisebeth
Collins Cook, Defendant, Privacy and Civil Liberties Oversight Board; David
Medine, Chairman, Privacy and Civil Liberties
Oversight Board; Rachel L. Brand, Privacy and Civil Liberties Oversight
Board; and Patricia M. Wald, Defendant, Privacy and Civil Liberties
Oversight Board; Keith B. Alexander, General, National Security Agency;
Rajesh De, General Counsel, National Security Agency; Eric H. Holder; U.S.
Attorney General, U.S. Department of Justice; Charles Schumer, Senate
Judiciary Committee; Dianne Feinstein, Senate Select Committee on
Intelligence Chairperson; Senator Saxby Chambliss, Patrick Leahy, Senator
Judiciary Chairman, Hon. Goodlatte, Chairman, U.S. House Judiciary
Chairman, Mike Rogers, House Permanent Select Committee on Intelligence,
U.S. Marshals Service Director Charles Dunne, U.S. Department of Homeland
Security, Federal Protection Service, Threat Assessment Branch employee Denis
P. McGowan, FBI Assistant Director in Charge, George Venizelos and Judge
Nicholas G. Garaufis engaged in overseeing a criminal, unconstitutional
system of government that specifically discriminated against the
law-abiding, psychiatric-treatment-compliant, mentally disabled Gentile/Schvartze/African American Plaintiff by allowing
Defendant Judge Garaufis and other Jews to fraudulently use the PATRIOT Act
to spy on non-criminal, constitutionally-protected telephone calls
regarding Plaintiff's HIPAA-protected mental health and other
HIPAA-protected issues; that said telephone calls were spied on at the
behest of Defendant Judge Garaufis and other Jews, not based on the belief
that the Plaintiff had violated the law, but to enslave the Plaintiff by
extorting/blackmailing her; by using Plaintiff's confidential, non-content
information regarding Plaintiff's telephone calls to her outpatient
psychiatric care provider that maybe embarrassing or shameful if publicly
disseminated; to fraudulently accuse the Plaintiff of the commission of a
crime and to associate the fraudulent criminal allegation with Plaintiff's
confidential non-content information; to frighten the Plaintiff by
publicizing embarrassing or shameful information associated with
Plaintiff's psychiatric non-content information for the sole purpose of
forcing the Plaintiff not to petition the government for a redress of
grievances with regard to Plaintiff's First Amendment right to report the
activities of lawbreaking Jews to the secular/Gentile law enforcement
authorities; that those Jews' violation of Plaintiff's and other Gentiles'
right to privacy is based on the Talmudic doctrine for Jews to enslave
Gentiles, with an emphasis on the enslavement of people who are
dark-skinned or considered by Jews to be Africans, Cushites,
Hamites and Canaanites. See Exhibit Q. In the meantime, Defendants Allen E.
Kaye, Harvey Shapiro, Jack Gladstein, Mortimer Zuckerman and Scott Shifrel, who engaged in illegally obtaining and
publicly disseminating information regarding the crime (for which Plaintiff
was falsely accused, for which Defendants never had any intention of
confronting Plaintiff in any court of laws and that was eventually
dismissed), Plaintiff's mental illness and her marriage and who are still
engaging in misprision of felony, fraud, identity theft, aggravated
identity theft, racketeering, obstruction of justice and
extortion/blackmail have never been investigated for the continued
commission of their crimes.
189)Plaintiff suffered and continues to
suffer injury because she is still under attack by all the Defendants, who,
at the clandestine behest of Defendant Garaufis, have continued the same
government-wide hostile environment that Plaintiff complained about in her
prior lawsuit, Uzamere vs. Cuomo, et al, 11-cv-2831/11-2713-cv. Defendants
continue to deprive Plaintiff of her civil rights because Plaintiff is a
gentile/schvartze. In the case of disruptive
Jewish litigant Rebecca Gloria Yohalem, Plaintiff
alleges that Defendant Jewish judge Joanna Seybert accepted the Jewish
litigant's virtually unintelligible lawsuit. In Defendant Boyle's order
regarding the disruptive, Jewish litigant, he said:
“The pro se
plaintiff appeared in court today for an initial conference, after having
failed to appear at two prior initial conferences. Her action purports to
be one under 42 U.S.C. §1983, based on assault, kidnapping and other
various general allegations that allegedly occurred at one or more mental
health facilities in New York.
The pro se
plaintiff is virtually deaf and it is therefore difficult for her to
participate in any meaningful way in this litigation - whether it involves
interaction with opposing counsel or the Court. As a
result of this severe limitation, the plaintiff’s conduct was
invariably nonresponsive, which undoubtedly led to her frustration at the
conference, which, in turn, led to her disruptive behavior in the courtroom
after the initial conference was concluded.
For the
foregoing reasons, the Court strongly recommends that the pro se plaintiff
seek counsel by contacting William M. Brooks, Professor of Law at the Touro
College Jacob D. Fuchsberg Law Center. Touro Law
Center has been designated, along with other organizations, as an
ombudsperson by the State of New York, under the Protection and Advocacy
for Individuals with Mental Illness program (“PAIMI”), to represent
patients and former patients at mental hospitals in the State of New York.
These duties are apparently carried out by the Law Center through the Civil
Rights Litigation Clinic, which is primarily responsible for patients in
the Long Island area, and of which Professor Brooks is the director. He may
be contacted by telephone at (631) 761-7086.”
190)Defendant Boyle was even able to
“purport” a cause of action from the mentally disabled Jewish plaintiff's
difficult-to-read complaint. In yet another act of pro-Jew favoritism, the
court, at the behest of Defendant Jewish judge Joanna Seybert, the Jewish
litigant was allowed to appear – for the third
initial conference after missing the first two. During the third initial
conference, the Jewish litigant became disruptive. See Complaint of Rebecca
Gloria Yohalem attached as Exhibit O.
191)However, although the African-American
Plaintiff went to college to become a paralegal and made the Dean's List
twice, has shown the ability to teach herself federal procedural law
(FRCP/FRAP/Rules of the Supreme Court), federal statutes, Constitutional
law, appellate case law and to apply them to her Verified Complaint on her
own and in spite of her mental illness, the only reactions that Plaintiff
has received from corrupt, racist Defendant Garaufis and the other
Defendants is their mistreatment of the Plaintiff both as a Gentile and as
the descendant of African slaves. See Plaintiff's Dean's List certificates
attached as Exhibit P.
192)The courts of Defendant the United
States of America recognize that discrimination based on race is an injury.
Discrimination based on race violates the Equal Protection Clause of the
Fourteenth Amendment. The Civil Rights Act of 1964 (Pub.L.
88–352, 78 Stat. 241, enacted July 2, 1964) was a landmark piece of
legislation in the United States that outlawed major forms of
discrimination against racial, ethnic, national and religious minorities,
and women. It ended unequal application of voter registration requirements
and racial segregation in schools, at the workplace and by facilities that
served the general public.
193)Plaintiff submits that Defendants'
violation of Civil Rights Act of 1964, Title VI, §601 because Plaintiff's
is an “inferior” gentile/African-American/schvartze
who continues to file complaints against corrupt “superior” Jews
immigration attorneys Allen E. Kaye, Harvey Shapiro and Jack Gladstein also
violates the Due Process Clause of the Fifth and Fourteenth Amendments, the
Equal Protection Clause of the Fourteenth Amendment and 42 USC §1985,
conspiracy against civil rights such that Plaintiff's Verified Complaint
rises to the level of an action in the manner of Bivens v. Six Unknown
Named Agents of Federal Bureau of Narcotics, 403 U.S. 388 with regard to
those Defendants who are natural persons only. Plaintiff understands the
U.S. Supreme Court's application of Bivens to natural persons and its
refusal to extend Bivens to agencies.
FIFTH CLAIM
FOR RELIEF
Defendants are
a Racketeer Influenced Corrupt Organization
194)Plaintiff repeats and realleges the
above paragraphs.
195)With regard to all
natural Defendants, this claim is brought against them individually
and in their official capacities.
196)Plaintiff is an American citizen with
a serious and persistent mental illness. Plaintiff has a mental impairment
that substantially limits one or more major life activities.
197)Plaintiff is a qualified individual
with disabilities within the meaning of 42 U.S.C. §12131(2).
198)Plaintiff is a descendant victim of
the African Holocaust in which Africans, whose sale was brokered by Jews
and kidnapped by whites, forever lost the ability to bear the correct
paternal name of her African male forebears; and having married Defendant
Ehigie Edobor Uzamere, now retains the right from now to eternity to have
borne and to bear the name of Defendant Ehigie Edobor Uzamere; and that the
aforesaid right is retained by Tara A. Uzamere, the adult child of the
marriage between Plaintiff and Defendant Ehigie Edobor Uzamere, and for her
progeny to bear the correct Edo/Bini name and culture associated with
Defendant Ehigie Edobor Uzamere.
199)Defendants owed Plaintiff the duty
not to engage in racketeering behavior for the purpose of making Plaintiff
a victim of honest services fraud at the hands of the Defendants, thereby
preventing Plaintiff and her daughter, Tara from retaining the correct
African name that they should have received from Defendant Ehigie Edobor
Uzamere, based on Defendant New York City's and the U.S. Department of
Homeland Security's recognition of Plaintiff's and her daughter Tara's
relationship with Defendant Ehigie Edobor Uzamere through marriage and
bloodline.
200)Defendants failed to meet their
obligation by not engaging in those behaviors that are indicative of a
racketeering-influenced, corrupt organization as detailed in 18 USC 18 USC
§§1961–1968. Defendants engaged in racketeering for the sole purpose of 1)
advancing the Talmudic doctrine Law of the Moser so as to
prevent Plaintiff from filing her complaint against corrupt, Jewish
immigration attorneys Allen E. Kaye, Harvey Shapiro and Jack Gladstein,
thereby forever depriving Plaintiff and her daughter Tara of their right to
bear the African name of Defendant Ehigie Edobor Uzamere. Plaintiff alleges
that the only way that Plaintiff can avoid Defendants' racketeering is by
keeping silent and not filing papers against corrupt Jewish Defendants
Allen E. Kaye, Harvey Shapiro and Jack Gladstein.
201)Plaintiff suffered and continues to
suffer injury because she is still under attack by all the Defendants, who,
at the clandestine behest of Defendant Garaufis, have continued the same
government-wide hostile environment that Plaintiff complained about in her
prior lawsuit, Uzamere vs. Cuomo, et al, 11-cv-2831/11-2713-cv. Plaintiff
holds that Defendant Garaufis and rest of the Defendants engaged in
racketeering by engaging in the following acts, to wit:
a)that
Defendants Allen E. Kaye, Harvey Shapiro, Jack Gladstein and Osato Eugene
Uzamere engaged in racketeering in that they committed 18 USC §1028,
thereby 1) knowingly and without lawful authority, produced a false
identification document knowing that such document was produced without
lawful authority; 2) knowingly possessed a false identification document
with the intent that such document be used to defraud the United States; 3)
knowingly transferred the fraudulent affirmations to Defendant the New York
State Unified Court System without lawful authority; 4) transferred a means
of identification of another person with the intent to commit, or to aid or
abet, or in connection with, any unlawful activity that constitutes a
violation of Federal law, or that constitutes a felony under any applicable
State or local law; with all the Defendants' goal to complete their act of
racketeering by ensuring that Plaintiff and her daughter Tara never be able
to file her complaint against corrupt Jewish immigration attorneys Allen E.
Kaye, Harvey Shapiro and Jack Gladstein, and thereby forever be deprived of
their right to bear Defendant Ehigie Edobor Uzamere's correct African name.
b)that
Defendants Garaufis, Schack, Sunshine, Cutrona
and Gerstein engaged in racketeering in that they committed 18 USC §1512 in
that they used physical force and the threat of physical force with the
intent to: 1) prevent Plaintiff's testimony against corrupt Jewish
immigration attorneys Allen E. Kaye, Harvey Shapiro and Jack Gladstein; 2)
that the aforesaid defendants caused Plaintiff to withhold her testimony
against corrupt Jewish immigration attorneys Allen E. Kaye, Harvey Shapiro
and Jack Gladstein; 3) that the aforesaid defendant – especially Defendant
Schack forced Plaintiff to be absent from an official proceeding to which
that person has been summoned by legal process; 4) That the aforementioned
defendants knowingly uses intimidation, threats, and corruptly persuaded
the New York City Police Department and the New York City Fire Department,
with the intent to prevent Plaintiff from giving testimony regarding the
commission of aggravated identity theft by corrupt Jewish immigration
attorneys Allen E. Kaye, Harvey Shapiro and Jack Gladstein conspiracy.
c) that
Defendant Osato E. Uzamere engaged in racketeering in that he committed 18
USC §1543, false use of passport. Defendant Osato E. Uzamere falsely made a
copy of an instrument purporting to be the passport of Defendant Ehigie
Edobor Uzamere, with intent that the same may be used in court by Defendant
Sunshine as a means to pretend to identify Defendant
Ehigie Edobor Uzamere. See copies of passport bearing the number A0588053
but bearing no name is attached as Exhibit C;
d)that
Defendant Osato E. Uzamere engaged in racketeering in that he committed 18
USC 1028A, false use of a social security number. Defendant Osato E.
Uzamere falsely made a copy of an instrument bearing the number XXX-XX-1205
purporting to be the social security number of “Godwin Uzamere”, a
fictitious identity that was used to defraud the Plaintiff. See copy of
instrument bearing false social security number attached as Exhibit C.
202)The courts
of Defendant the United States of America recognize that obstruction of
justice caused by racketeering influenced, corrupt organizations as an
injury. RICO laws were successfully cited in NOW v. Scheidler,
510 U.S. 249, 114 S. Ct. 798, 127 L.Ed. 2d 99
(1994), a suit in which certain parties, including the National
Organization for Women, sought damages and an injunction against pro-life
activists who physically block access to abortion clinics. Amazingly, the
Court held that a RICO enterprise does not need an economic motive, and
that the Pro-Life Action Network could therefore qualify as a RICO
enterprise. In the federal lawsuit against judges Michael Conahan and Mark Ciavarella, federal grand jury in the Middle District
of Pennsylvania handed down a 48-count indictment against former Luzerne
County Court of Common Pleas Judges Michael Conahan and Mark Ciavarella. The judges were charged with RICO after
allegedly committing acts of wire fraud, mail fraud, tax evasion, money
laundering, and honest services fraud. The judges were accused of taking
kickbacks for housing juveniles, that the judges convicted for mostly petty
crimes, at a private detention center. The incident was dubbed by many local
and national newspapers as the “Kids for cash scandal”. On February 18,
2011, a federal jury found Michael Ciavarella
guilty of racketeering because of his involvement in accepting illegal
payments from Robert Mericle, the developer of PA
Child Care, and Attorney Robert Powell, a co-owner of the facility. Ciavarella is facing 38 other counts in federal court.
203)Plaintiff submits that Defendants'
commission of racketeering violates the Due Process Clause of the Fifth and
Fourteenth Amendments, the Equal Protection Clause of the Fourteenth
Amendment and 42 USC §1985, conspiracy against civil rights such that
Plaintiff's Verified Complaint rises to the level of an action in the
manner of Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics,
403 U.S. 388 with regard to those Defendants who are natural persons only.
Plaintiff understands the U.S. Supreme Court's application of Bivens to
natural persons and its refusal to extend Bivens to agencies.
SIXTH CLAIM
FOR RELIEF
Fraud upon the
Court
204)Plaintiff repeats and realleges the
above paragraphs.
205)With regard to all
natural Defendants, this claim is brought against them individually
and in their official capacities.
206)Plaintiff is an American citizen with
a serious and persistent mental illness. Plaintiff has a mental impairment
that substantially limits one or more major life activities.
207)Plaintiff is a qualified individual
with disabilities within the meaning of 42 U.S.C. §12131(2).
208)Plaintiff is a descendant victim of
the African Holocaust in which Africans, whose sale was brokered by Jews
and kidnapped by whites, forever lost the ability to bear the correct
paternal name of her African male forebears; and having married Defendant
Ehigie Edobor Uzamere, now retains the right from now to eternity to have
borne and to bear the name of Defendant Ehigie Edobor Uzamere; and that the
aforesaid right is retained by Tara A. Uzamere, blood heir and the adult
child of the marriage between Plaintiff and Defendant Ehigie Edobor
Uzamere, and for her progeny to bear the correct Edo/Bini name and culture
associated with Defendant Ehigie Edobor Uzamere.
209)Defendants owed Plaintiff the duty to
provide her with honest judicial services, free from fraud. Defendants owed
Plaintiff the duty to render decisions in her lawsuits that were reflective
of their recognition of the aggravated identity theft committed by
Defendants Allen E. Kaye, Harvey Shapiro, Jack Gladstein and Osato E.
Uzamere. Defendants owed Plaintiff the duty to file a criminal instrument
against the aforementioned attorney, and to not allow their own Talmudic
bias to affect their obligation to support and defend the Constitution of
the United States against all enemies, foreign and domestic; to bear true
faith and allegiance to the same; to take said obligation freely, without
any mental reservation or purpose of evasion; and to well and faithfully
discharge the duties of the office on which Defendants entered. Defendants
owed Plaintiff the duty to establish a clear separation of church and
state, and to distance themselves from the Talmudic Law of the Moser in
their application and enforcement of the law. Defendants owed Plaintiff and
her children the duty to give themselves over to the transparency of U.S. law,
and not the secrecy of the Talmudic Law of the Moser – a stupid law that is
stupid for Defendants to enforce since the Defendants actively keep said
law secret from Gentiles. It is stupid for Defendants to force Plaintiff –
and the public at large – to obey a law that they do not know they are
supposed to obey and is not transparently included in any normal law code.
210)Defendants failed to meet the
obligations as detailed in Bulloch v. United States. Defendant judges
engaged rendering fraudulent decisions, and then commenced a extortionate
shakedown from the judicial positions of Defendants Garaufis, Schack,
Sunshine and Gerstein for the sole purpose of advancing the Talmudic
doctrine Law of the Moser so as to prevent Plaintiff from filing her complaint
against corrupt, Jewish immigration attorneys Allen E. Kaye, Harvey Shapiro
and Jack Gladstein, thereby forever depriving Plaintiff and her daughter
Tara of their right to bear the African name of Defendant Ehigie Edobor
Uzamere. Plaintiff alleges that the only way that Plaintiff can avoid
Defendants' intimidation, false criminal allegations and Defendants' racial
discrimination against her is by keeping silent and not filing papers
against corrupt Jewish Defendants Allen E. Kaye, Harvey Shapiro and Jack Gladstein.
211)Plaintiff suffered and continues to
suffer injury because she is still under attack by all the Defendants
judges has have rendered biased decisions designed to hide Defendant
judges' commission of misprision of felony with regard to
Defendants Allen E. Kaye's, Harvey Shapiro's, Jack Gladstein's
and Osato E. Uzamere's commission of aggravated identity theft. Defendants,
at the clandestine behest of Defendant Garaufis, have continued the same
government-wide hostile environment that Plaintiff complained about in her
prior lawsuit, Uzamere vs. Cuomo, et al, 11-cv-2831/11-2713-cv. In every
single case in which Plaintiff presented irrefutable proof that immigration
attorney Allen E. Kaye, Harvey Shapiro and Jack Gladstein engaged in
criminally facilitating the immigration fraud and identity fraud of
Plaintiff's ex-husband, the Defendant judge in that case would render a
decision that would ignore Defendant attorneys of any criminal liability,
or worse, they conspired with other Defendants to accuse Plaintiff of being
too mentally disabled and violent to use the court system. The defendant
judges acted, not as judges, but as Talmudic attorneys for the corrupt,
Jewish immigration attorneys, leaving the position of judge unfilled by a
U.S. Constitution-obeying, unbiased judge. Their actions stink of fraud
upon the court, which under the U.S. Courts of Appeal for the Seventh and
Tenth Circuit, renders any decision rendered by them null and void. Lastly,
Defendant Jewish judges rendered fictitious decision to their their true motive – to Talmud-based decisions against
the Plaintiff because she is Gentile, because she is black-skinned, and
because of the Talmudic doctrine Law of the Moser that prohibits the
Defendants from directly or indirectly filing complaints against corrupt
Jewish immigration attorneys Allen E. Kaye, Harvey Shapiro, Jack Gladstein.
See Defendant Daily News article dated November 5, 2009, attached as
Exhibit R.
212)The courts of Defendant the United
States of America recognize that fraud upon the court is an injury. In
Bulloch v. United States, 763 F.2d 1115, 1121 (10th Cir. 1985), the court
stated “Fraud upon the court is fraud which is directed to the judicial
machinery itself and is not fraud between the parties or fraudulent documents,
false statements or perjury. . .It is where the court or a member is
corrupted or influenced or influence is attempted or where the judge has
not performed his judicial function --- thus where the impartial functions
of the court have been directly corrupted.” Fraud upon the court is an
injury because it deprives a litigant of the court's most valuable
“commodity” – justice.
213)Plaintiff submits to this Court that
Defendant Judge Garaufis' commencement and orchestration to defame
Plaintiff as psychotic and violent to stop her from filing her appeal
against his FRCP-lacking, memorandum-lacking decision are irrefutable proof
that his decision in Plaintiff's lawsuit Uzamere vs. Cuomo, et al was
biased, and is an act of fraud upon the court the violates the Due Process
Clause of the Fifth and Fourteenth Amendments, the Equal Protection Clause
of the Fourteenth Amendment and 42 USC §1985, conspiracy against civil
rights such that Plaintiff's Verified Complaint rises to the level of an
action in the manner of Bivens v. Six Unknown Named Agents of Federal
Bureau of Narcotics, 403 U.S. 388 with regard to those Defendants who are
natural persons only. Plaintiff understands the U.S. Supreme Court's
application of Bivens to natural persons and its refusal to extend Bivens
to agencies.
SEVENTH CLAIM
FOR RELIEF
Defendants'
Blacklisting Of Plaintiff Violates 42 U.S.C.
§1983, §1985
214)Plaintiff repeats and realleges the
above paragraphs.
215)With regard to all Defendants, this
claim is brought against them individually and in their official
capacities.
216)Plaintiff is an American citizen with
a serious and persistent mental illness. Plaintiff has a mental impairment
that substantially limits one of more major life activities.
217)Plaintiff is a descendant victim of the
African Holocaust in which Africans, whose sale was brokered by Jews and
kidnapped by whites, forever lost the ability to bear the correct paternal
name of her African male forebears; and having married Defendant Ehigie
Edobor Uzamere, now retains the right from now to eternity to have borne
and to bear the name of Defendant Ehigie Edobor Uzamere; and that the
aforesaid right is retained by Tara A. Uzamere, blood heir and the adult
child of the marriage between Plaintiff and Defendant Ehigie Edobor Uzamere,
and for her progeny to bear the correct Edo/Bini name and culture
associated with Defendant Ehigie Edobor Uzamere.
218)Defendants owed Plaintiff the duty to
not blacklist Plaintiff in the Jewish Defendants' continued attempts to
stop filing criminal complaints against Defendants Allen E. Kaye, Harvey
Shapiro and Jack Gladstein. Defendants owed Plaintiff the duty to make
their federally-financed outpatient mental health and other programs
available to the Plaintiff program free from fraud. Defendants owed
Plaintiff the duty to recognize Plaintiff's complaints against the aforementioned attorneys as true, and not trick
Plaintiff into believing that Defendants' blacklisting were legitimate acts
brought on by wrongful acts by the Plaintiff. Defendants owed Plaintiff the
duty not to render Plaintiff persona non grata
based on the Jewish Defendants' desire to enforce the Talmudic doctrine Law
of the Moser, that prohibits Jews from indirectly or directly filing
complaints against fellow Jews who have violated secular law.
219)Defendants failed to meet the
obligations as detailed in 42 USC §1983, 1985. Defendant judges engaged in
blacklisting the Plaintiff from the New York State courts, from the federal
courts, and from receiving outpatient mental health services, in order to engage in racketeering/obstruction of
justice for the sole purpose of advancing the Talmudic doctrine Law of the
Moser, that prohibits Jews from indirectly or directly reporting the
wrongdoings of fellow Jews to the secular/gentile authorities. Plaintiff
alleges that the only way that Plaintiff can avoid Defendants'
blacklisting, intimidation, false criminal allegations and Defendants'
racial discrimination against her is by keeping silent and not filing a
criminal complaint against corrupt Jewish Defendants Allen E. Kaye, Harvey
Shapiro and Jack Gladstein.
220)Plaintiff suffered and continues to
suffer injury because she is still under attack by all the Defendants like
FEGS, Inc., who still have Plaintiff listed as persona non
grata for life. Defendant judges Eileen A. Rakower
and Nicholas Garaufis have come to Defendant FEGS aid, by allowing FEGS to
blacklist Plaintiff because Plaintiff used Defendant FEGS, Inc Services for
complaining against Defendants Allen E. Kaye, Harvey Shapiro and Jack Gladstein's commission of aggravated identity theft.
See Defendant Daily News article dated November 5, 2009, attached as
Exhibit R.
221)The courts of Defendant the United
States of America recognize that blacklisting is an injury – and a
constitutional tort as well. Mr. Justice Black in his concurring opinion in
the U.S. Supreme Court case Joint Anti-Fascist Refugee Committee v.
McGrath, 341 U.S. 123, 144-145, 71 S.Ct. 624, 634 (1951): stated: “Our
basic law, however, wisely withheld authority for resort to executive. .
.condemnations and blacklists as a substitute for imposition of legal types
of penalties by courts following trial and conviction in accordance with
procedural safeguards of the Bill of Rights.”
222)Plaintiff submits to this Court that
the Defendants – especially the Jewish Defendants' orchestration of a
hostile environment to exclude Plaintiff from government-financed judicial,
legal, and medical services to prevent Plaintiff from reporting the
aforesaid Jewish immigration attorneys' commission of aggravated identity
theft to the appropriate law enforcement authorities, violates the Due
Process Clause of the Fifth and Fourteenth Amendments, the Equal Protection
Clause of the Fourteenth Amendment and 42 USC §1983 and §1985, conspiracy against
civil rights such that Plaintiff's Verified Complaint rises to the level of
an action in the manner of Bivens v. Six Unknown Named Agents of Federal
Bureau of Narcotics, 403 U.S. 388 with regard to those Defendants who are
natural persons only. Plaintiff understands the U.S. Supreme Court's
application of Bivens to natural persons and its refusal to extend Bivens
to agencies.
EIGHTH CLAIM
FOR RELIEF
Defendants
Invaded Plaintiff's Privacy Based on Intentional Misuse of NSL
or Based on
Obtaining Non-NSL, Non-Content Information Illegally
223)Plaintiff
repeats and realleges the above paragraphs.
224)With
regard to all Defendants, this claim is brought against them individually
and in their official capacities.
225)Plaintiff
is an American citizen with a serious and persistent mental illness.
Plaintiff has a mental impairment that substantially limits one of more
major life activities.
226)Plaintiff
is a descendant victim of the African Holocaust in which Africans, whose
sale was brokered by Jews and kidnapped by whites, forever lost the ability
to bear the correct paternal name of her African male forebears; and having
married Defendant Ehigie Edobor Uzamere, now retains the right from now to
eternity to have borne and to bear the name of Defendant Ehigie Edobor
Uzamere; and that the aforesaid right is retained by Tara A. Uzamere, blood
heir and the adult child of the marriage between Plaintiff and Defendant
Ehigie Edobor Uzamere, and for her progeny to bear the correct Edo/Bini
name and culture associated with Defendant Ehigie Edobor Uzamere.
227)Defendants owed Plaintiff the duty not
to invade Plaintiff's privacy by using the non-content information
regarding Plaintiff's telephone calls to psychiatric service providers and
to government healthcare providers to accuse Plaintiff of crimes that were
used to illegally rationalize Defendant Garaufis' dismissal of Plaintiff's
civil rights action. Defendants owed Plaintiff the duty not to invade
Plaintiff's privacy by using the non-content information regarding Plaintiff's
telephone calls to psychiatric care providers and government healthcare
providers to illegally rationalize extortionate/threatening telephone calls
and visits to Plaintiff's home. Defendants owed Plaintiff the duty not to
invade Plaintiff's privacy by using the non-content information regarding
Plaintiff's telephone calls to psychiatric service providers and government
healthcare providers to accuse Plaintiff of crimes that were used to kidnap
Plaintiff and unlawfully imprison/illegally misdiagnose Plaintiff for
crimes that she never commit.
228)Defendants failed to meet the
obligations as detailed in 18 USC §2709 and Griswold v. Connecticut, 381
U.S. 479 (1965). Defendants, in their haste to libel Plaintiff as a
violent, lawbreaking “wacko” to make Plaintiff's complaint against them
appear to be unbelievable, Defendant judges conspired with Defendants
Jewish billionaire Mortimer Zuckerman and Jewish staff writer Scott Shifrel of the Daily News, LP to disseminate
confidential, nonpublic information regarding Plaintiff's mental illness
and her marriage on paper and in the internet – with the internet still
disseminating the false story regarding the Plaintiff. Plaintiff is still
being attacked by several members of the Jewish community to prevent her
from successfully filing her complaint against the original lawbreaking
attorneys, corrupt immigration attorneys Allen E. Kaye, Harvey Shapiro and
Jack Gladstein.
.... .229)Plaintiff suffered and continues to suffer injury
because she is still under attack by all the Defendants. See Defendant
Daily News article dated November 5, 2009, attached as Exhibit R.
230)The courts of Defendant the United
States of America recognize the intentional misuse of an NSL as an injury –
and a constitutional tort as well. Mr. Justice Black in his concurring
opinion in the U.S. Supreme Court case Joint Anti-Fascist Refugee Committee
v. McGrath, 341 U.S. 123, 144-145, 71 S.Ct. 624, 634 (1951): stated: “Our
basic law, however, wisely withheld authority for resort to executive. .
.condemnations and blacklists as a substitute for imposition of legal types
of penalties by courts following trial and conviction in accordance with
procedural safeguards of the Bill of Rights.”
231)Plaintiff submits to this Court that the
Defendants – especially the Jewish Defendants' orchestration of a hostile
environment to exclude Plaintiff from government-financed judicial, legal,
and psychiatric services to prevent Plaintiff from reporting the aforesaid
Jewish immigration attorneys' commission of fraud, identity theft and
aggravated identity theft to the appropriate law enforcement authorities,
violates the Due Process Clause of the Fifth and Fourteenth Amendments, the
Equal Protection Clause of the Fourteenth Amendment and 42 USC §1983 and
§1985, conspiracy against civil rights such that Plaintiff's Verified
Complaint rises to the level of an action in the manner of Bivens v. Six
Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388 with
regard to those Defendants who are natural persons only. Plaintiff
understands the U.S. Supreme Court's application of Bivens to natural
persons and its refusal to extend Bivens to agencies.
NINTH CLAIM
FOR RELIEF
Congressional
Defendants Engaged in Campaign Bribery to Advance the Talmudic
Law of the
Moser; Congressional Defendants Deprived Plaintiff and Gentiles of Honest
Services
232)Plaintiff repeats and realleges the
above paragraphs.
... 233)With
regard to all Defendants, this claim is brought against them individually
and in their official capacities.
234)Plaintiff is an American citizen with
a serious and persistent mental illness. Plaintiff has a mental impairment
that substantially limits one of more major life activities.
235)Plaintiff is a descendant victim of
the African Holocaust in which Africans, whose sale was brokered by Jews
and kidnapped by whites, forever lost the ability to bear the correct
paternal name of her African male forebears; and having married Defendant
Ehigie Edobor Uzamere, now retains the right from now to eternity to have
borne and to bear the name of Defendant Ehigie Edobor Uzamere; and that the
aforesaid right is retained by Tara A. Uzamere, blood heir and the adult
child of the marriage between Plaintiff and Defendant Ehigie Edobor
Uzamere, and for her progeny to bear the correct Edo/Bini name and culture
associated with Defendant Ehigie Edobor Uzamere.
236)Defendant Jeffries and his
congressional staff, owed Plaintiff the duty, pursuant to 18 USC §4, to
report the crimes that Plaintiff reported to him to the U.S. Department of
Justice, the U.S. Department of Homeland Security and other Defendants.
Plaintiff alleges that Defendant Jeffries and his congressional staff had,
in de jure, than a de facto22 responsibility to
the Plaintiff to ensure that Plaintiff's criminal complaint would be
investigated or would be presented to Defendants U.S. Department of Justice
and the U.S. Department of Homeland Security for investigation.
237)Defendant Jeffries, his congressional
staff and Jews who contributed financially to Defendant Jeffries'
congressional campaign owed Plaintiff the duty to ensure that they not
engage in quid pro quo campaign contributions that were provided/accepted
with the understanding that the aforementioned were bribes used to require
Defendant Jeffries and his staff to engage in activities that would advance
Jewish religion and culture, including the Talmudic doctrine Law of the
Moser, at the expense of violating the civil rights of Gentile
constituents, especially the Due Process and Equal Protection clauses of
the U.S. Constitution.
....238)Defendant Jeffries, his
congressional staff and Jews who contributed financially to Defendant
Jeffries' congressional campaign owed Plaintiff the duty to allow her the
same type of free access to to call and visit
Defendant Jeffries' offices as the Jews who contributed money to Defendant
Jeffries' congressional campaign, and to not conspire to blacklist the
Plaintiff based on her insistence to obtain help from Defendant Jeffries to
report those Defendants – especially those Defendants who are Jewish, for
Defendants' commission of misprision of felony, fraud, deprivation of rights under color of law,
conspiracy to interfere with civil rights, racketeering, obstruction of
justice, extortion/blackmail, blacklisting and violation of the PATRIOT
Act.
239)Defendant Jeffries and his
congressional staff, failed in their duty, pursuant to 18 USC §4, to report
the crimes that Plaintiff reported to him, to the U.S. Department of
Justice, the U.S. Department of Homeland Security and other Defendants.
Plaintiff alleges that Defendant Jeffries and his congressional staff
failed in their in de jure, or de facto
responsibility to the Plaintiff to ensure that Plaintiff criminal complaint
would be investigated or would be presented to Defendants U.S. Department
of Justice and the U.S. Department of Homeland Security for investigation.
240)Defendant Jeffries, his congressional
staff and Jews who contributed financially failed in their duty to ensure
that they not engage in qui pro quo campaign
contributions that were provided/accepted with the understanding that the
aforementioned were bribes used to require Defendant Jeffries and his staff
to engage in activities that would advance Jewish religion and culture,
including the Talmudic doctrine Law of the Moser, the prohibits Jews from
reporting crimes of fellow Jews to the secular/Gentile authorities, at the
expense of violating the civil rights of Gentile constituents, especially
the Due Process and Equal Protection clauses of the U.S. Constitution.
241)Defendant Jeffries, his congressional
staff and Jews who contributed financially to Defendant Jeffries'
congressional campaign failed in their duty to allow Plaintiff the same
type of free access to to call and visit Defendant
Jeffries' offices as the Jews who contributed money to Defendant Jeffries'
congressional campaign; that Defendant Jeffries, his congressional staff
and Jews who contributed financially to Defendant Jeffries' congressional
campaign failed in their duty not to conspire to blacklist the Plaintiff
based on her insistence to obtain help against those Jews whom Plaintiff
has proven committed misprision of felony, fraud, deprivation of rights
under color of law, conspiracy to interfere with civil rights, racketeering,
obstruction of justice, extortion/blackmail and blacklisting.
242)Plaintiff suffered and continues to
suffer injury because she is still under attack by all the Defendants. See
Defendant Daily News article dated November 5, 2009, attached as Exhibit R.
243)The courts of Defendant the United
States of America recognize the acceptance of a bribe by a public servant
as a injury cognizable
in law.
244)Plaintiff submits to this Court that
the Defendants – especially the Jewish Defendants' orchestration of a
hostile environment to exclude Plaintiff from government-financed judicial,
legal, and psychiatric services to prevent Plaintiff from reporting the
aforesaid Jewish immigration attorneys' commission of fraud, identity theft
and aggravated identity theft to the appropriate law enforcement
authorities, violates the Due Process Clause of the Fifth and Fourteenth
Amendments, the Equal Protection Clause of the Fourteenth Amendment and 42
USC §1983 and §1985, conspiracy against civil rights such that Plaintiff's
Verified Complaint rises to the level of an action in the manner of Bivens
v. Six Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388
with regard to those Defendants who are natural persons only. Plaintiff
understands the U.S. Supreme Court's application of Bivens to natural
persons and its refusal to extend Bivens to agencies.
This Court
Must Enforce 28 USC §455, 28 USC §1404, 28 USC §1654 and 28 USC §144
to Protect Pro
Se Plaintiff's Right to Self-Representation
245)28 USC §144 says: “Whenever a party
to any proceeding in a district court makes and files a timely and
sufficient affidavit that the judge before whom the matter is pending has a
personal bias or prejudice either against him or in favor of any adverse
party, such judge shall proceed no further therein, but another judge shall
be assigned to hear such proceeding.”
246)28 USC §455 says: “(a) Any justice,
judge, or magistrate judge of the United States shall disqualify himself in
any proceeding in which his impartiality might reasonably be questioned.
(b) He shall also disqualify himself in the following circumstances: (5) He
or his spouse, or a person within the third degree of relationship to
either of them, or the spouse of such a person.”
247)28 USC §1404(a) says: “For the
convenience of parties and witnesses, in the interest of justice, a
district court may transfer any civil action to any other district or
division where it might have been brought or to any district or division to
which all parties have consented.”
248)28 USC §1654 says: “In all courts of
the United States the parties may plead and conduct their own cases
personally or by counsel as, by the rules of such courts, respectively, are
permitted to manage and conduct causes therein.”
249)Plaintiff alleges that if any judge
in the Eastern District or Southern District of New York gets his/her hands
on Plaintiff's lawsuit, even though he/she is a defendant, he/she will
violate 28 USC §455, 28 USC §1404, 28 USC §1654 and 28 USC §144, and make a
ruling dismissing Plaintiff's case based on: 1) halachic law's mandate not
to report the crimes of corrupt Jews Allen E. Kaye, Harvey Shapiro, Jack
Gladstein, Mortimer Zuckerman and Scott Shifrel
to the secular authorities, 2) judicial nepotism based on their desire to
save Defendant Garaufis from being prosecuted; and, 3) their ability to
hide any act of fraud upon the court on Plaintiff's being an inexperienced,
mentally disabled pro se litigant. If Plaintiff appeals to the U.S. Court
of Appeals to the Second Circuit, even though its judges are also
defendants presently engaged in the commission of several federal offenses,
they will violate 28 USC §455, 28 USC §1404, 28 USC §1654 and 28 USC §144,
and make an unexplained ruling dismissing Plaintiff's case based on: 1)
halachic law's mandate not to report the crimes of corrupt Jews Allen E.
Kaye, Harvey Shapiro, Jack Gladstein, Mortimer Zuckerman and Scott Shifrel to the secular authorities; judicial nepotism
based on their desire to save Defendant Garaufis from being prosecuted;
and, 3) their ability to hide any act of fraud upon the court on
Plaintiff's being an inexperienced, mentally disabled pro se litigant.
Defendant Garaufis will also depend on law enforcement agencies like the
FBI to illegally monitor Plaintiff and to hospitalize Plaintiff for any
action that can be misconstrued as warranting long-term psychiatric
hospitalization so that Plaintiff can be “jailed” for having a mental
illness without the benefits of a notice of accusation, a defense attorney
and a chance to confront adversarial witnesses. When Plaintiff last
checked, an employee of Defendant FBI contacted Plaintiff's psychiatric
treatment provider to tell them that Plaintiff had an argument with them
about her rights to file criminal complaints against Jewish persons who
violated federal law, treating Plaintiff's insistence as mental
instability. Defendant Garaufis also set in motion Plaintiff's being
falsely accused of committing 115, threatening Defendant Garaufis with
bodily harm, other federal judges, and employees of the Centers for
Medicare and Medicaid Services call center with death. Defendant Garaufis
instigated the violation of Plaintiff's Sixth Amendment rights (Plaintiff
was able to confront the Centers for Medicare and Medicaid Services. They
confirmed that Plaintiff did not threaten anyone). Lastly, Defendant
Garaufis set in motion the kidnapping and unlawful imprisonment of
Plaintiff in a mental institution for a federal offense/psychiatric
diagnosis which Plaintiff did not commit. This Court, pursuant to 4,
misprision of felony owes both the Plaintiff and the Constitution of the
United States to enforce the law.
250)Defendant United States' statutes
have justly made arrangements to ensure that any
justice, judge, or magistrate judge of the United States disqualifies
himself/herself in any proceeding in which a judge's impartiality might
reasonably be questioned. In the interest of justice and mercy, federal
statutes, along with case law, have arranged that a district court may transfer
any civil action to any other district or division where it might have been
brought or to any district or division to which all parties have consented
– in the best interest of justice. However, while U.S. Constitutional law
ensures that any decision in any court of the U.S. States reflect that the
Due Process Clause and the Equal Protection Clause of the Fifth and
Fourteenth Amendments are incorporated in all U.S. judges' decisions,
sometimes dishonest federal judges can intentionally misconstrue federal
statutes in a way that allows the meritless dismissal of a pro se
litigant's cases, simply because a pro se litigant's cases are
automatically viewed as lacking merit, or worse, because the pro se
litigant's case has merit but addresses legal issues against which the
judge has a bias.
251)In the case of the pro se Plaintiff,
Plaintiff alleges that any Defendant judge against whom her action is filed
has already conspired with defendants' attorneys not to enter
into any stipulation with the Plaintiff to transfer her lawsuit to
an unbiased venue/venue that does not have a Jewish majority. Furthermore,
none of the defendants have reported or will report attorneys Allen E.
Kaye, Harvey Shapiro, Jack Gladstein, Osato Eugene Uzamere and Ehigie
Edobor Uzamere for their commission of aggravated identity theft. Plaintiff
alleges that a disproportionate percentage of the second district's federal
judges will adjudicate Plaintiff's lawsuit in favor of those members of the
judiciary and defendants who are adherents of Talmudic doctrines such as:
1) Law of the Moser;23 2) Curse of Dark Skin;24 3) Judaism, American's New
Government Religion;25 4) Only a Jew Can Rule Over Jews;26 5) Gentiles,
rightful slaves of Jews;27 6) Use of Subterfuge to Trick Goyim During
Lawsuits;28 and, 7) A Gentile's Lost Item Must Not Be Returned if Based on
Compassion.29 Because of the Second Circuit's religious imbalance of power,
non-adherent judges, who Judaic law does not benefit, in attempts to keep
their jobs and social standing, participate in rendering decisions that
honor and due obeisance to Judaism. In the Second Circuit, Plaintiff's
attempts to have the court enforce 28 USC §455, 28 USC §1404, 28 USC §1654
and 28 USC §144 are a death knell for Plaintiff's lawsuit. Most of the
judges are Jews. Plaintiff does not understand how the Second Circuit was
able to hire in such a manner as to hire a Jewish majority, or at least a
disproportionately high percentage of Jews.
252)This court must display the legal, moral
and constitutional fortitude to assist the pro se Plaintiff to enforce 28
USC §455, 28 USC §1404, 28 USC §1654 and 28 USC §144. Judicial Defendants'
district – essentially a beth din where pro se
litigants are concerned, must not be allowed to secretly enforce halachic
doctrines by relying on the presumed naivéte of
pro se litigants who have meritorious claims that corrupt, federal and New
York State judges ignore because of judges' own personal, unconstitutional
biases. Decisions rendered by the Second Circuit's Talmud-biased federal
judges, which have been discarded by such terms as “not for publication” or
“mandate”, but make absolutely no mention of the
meritorious issues in the pro se litigant's appeal should be noticed by a
trained and unbiased judicial eye as an act of fraud upon the court. This
Court must ensure that the pro se Plaintiff can rely on its unbiased
services to enforce 28 USC §455, 28 USC §1404, 28 USC §1654 and 28 USC
§144. See Liteky v. U.S., 114 S.Ct. 1147, 1162
(1994); Liljeberg v. Health Services Acquisition
Corp., 486 U.S. 847, 108 S.Ct. 2194 (1988); (what matters is not the
reality of bias or prejudice but its appearance); United States v. Balistrieri, 779 F.2d 1191 (7th Cir. 1985) (Section
455(a) "is directed against the appearance of partiality, whether or
not the judge is actually biased.") ("Section 455(a) of the
Judicial Code, 28 U.S.C. §455(a), is not intended to protect litigants from
actual bias in their judge but rather to promote public confidence in the impartiality
of the judicial process."); “Section 455(a)” requires a judge to
recuse himself in any proceeding in which her impartiality might reasonably
be questioned." Taylor v. O'Grady, 888 F.2d 1189 (7th Cir. 1989);
Pfizer Inc. v. Lord, 456 F.2d 532 (8th Cir. 1972), “It is important that
the litigant not only actually receive justice, but that he believes that
he has received justice.” “Justice must satisfy the appearance of justice.”
Levine v. United States, 362 U.S. 610, 80 S.Ct. 1038 (1960), citing Offutt
v. United States, 348 U.S. 11, 14, 75 S.Ct. 11, 13 (1954); United States v.
Sciuto, 521 F.2d 842, 845 (7th Cir. 1996)
"The right to a tribunal free from bias or prejudice is based, not on
section 144, but on the Due Process Clause."
Federal Judges
Are Required to Construe Pro Se Litigant's Pleadings Liberally
253)In the U.S. Supreme Court case Haines
V. Kerner, 404 U. S. 519 (1972), Petitioner Menard, a person convicted by
the State of Illinois as a felon – and an individual deemed by the State of
Illinois to be unworthy of living with law-abiding citizens of Illinois,
commenced an action against the Governor of Illinois and other state
officers and prison officials under the Civil Rights Act of 1871, 17 Stat.
13, 42 U.S.C. §1983, and 28 U.S.C. §1343(3), seeking to recover damages for
claimed injuries and deprivation of rights while incarcerated. The
dismissed Mr. Menard's complaint and the U.S. Court of Appeals for the
Seventh Circuit affirmed the court's decision. The U.S. Supreme Court,
however, decided against the Federal District's and U.S. Court of Appeals'
decisions. The U.S. Supreme Court stated in its decision that “Whatever may
be the limits on the scope of inquiry of courts into the internal
administration of prisons, allegations such as those asserted by
petitioner, however inartfully pleaded, are sufficient to call for the
opportunity to offer supporting evidence. . .Accordingly, although we
intimate no view whatever on the merits of petitioner's allegations, we
conclude that he is entitled to an opportunity to offer proof.”
There Is No
Constitutional Or Statutory Rationale To Dismiss
Plaintiff’s Complaint
254)In the past, Plaintiff alleges that
Defendant Garaufis has fraudulently misused reasons in the Federal Rules of
Civil Practice to illegally dismiss Plaintiff's Verified Complaint.
Plaintiff alleges that Defendant Garaufis' primarily relies on the
religious doctrine Law of the Moser to prevent Plaintiff from reporting
corrupt Jewish immigration attorneys Allen E. Kaye, Harvey Shapiro and Jack
Gladstein. Plaintiff believes that the following FRCP reasons for dismissal
do not apply to Plaintiff's Verified Complaint: (1) lack of subject-matter
jurisdiction; (2) lack of personal jurisdiction; (4) insufficient process;
(5) insufficient service of process; (6) failure to state a claim upon
which relief can be granted; and (7) failure to join a party under Rule 19.
Plaintiff advises this Court that if Defendant Garaufis receives this case,
even though he is a defendant, he will rule on it. If the judges of the
Second Circuit gets it, they will rule on it, even
though they are also Defendants. Plaintiff asks this Court to place her
lawsuit in abeyance until such time that the Defendants stipulates this
court as the venue for Plaintiff's action pursuant to 28 USC §455 and 28
USC §1404, and if not, to be courageous and make new law that the Plaintiff
can proudly present to the Supreme Court of the United States.
255)Plaintiff reminds this Court that
even if Plaintiff fails to state a claim upon which relief can be granted,
Plaintiff would still have the legal right to require this Court to point
out Plaintiff's mistakes and allow Plaintiff to make necessary changes to
ensure that Plaintiff’s amended Verified Complaint states a claim on which
relief can be granted. Plaintiff reminds this Court of the inartfully
drawn, virtually incomprehensible complaint of the disruptive, mentally
disabled Jewish litigant Rebecca Gloria Yohalem
and demands the same wide literal latitude – especially since Plaintiff's
Verified Complaint is a lot easier for this Court to read and understand. SeeHaines v. Kerner, 404 U.S. 519 (1972) page 138.
Plaintiff's
Request for Review of Her Allegations Satisfies
the “Good
Faith” Requirement of Coppedge v. United States
256)According to Coppedge
v. United States, “The requirement that an appeal be taken "in good
faith" is satisfied when the defendant seeks. . . review of any issue
that is not frivolous. Pp. 369 U. S. 444-445.
257)According to Coppedge
vs. United States, “If, with such aid, the applicant then presents any
issue for the court's consideration which is not clearly frivolous, leave
to proceed in forma pauperis must be granted. P. 369 U. S. 446. . .P. 369
U. S. 448.”
258) Farley v. United States, 354 U.S.
521, 77 S.Ct. 1371, 1 L.Ed.2d 1529 defines how the U.S. Supreme Court
applies the “good faith” standard. It states that “In the absence of some
evident improper motive, the applicant's good faith is established by the
presentation of any issue that is not plainly frivolous. The good-faith
test must not be converted into a requirement of a preliminary showing of
any particular degree of merit. Unless the issues
raised are so frivolous that the appeal would be dismissed in the case of a
nonindigent litigant . . .the request of an indigent for leave to appeal in
forma pauperis must be allowed.
259)Plaintiff's alleges that her Verified
Complaint addresses issues that are not frivolous issues. At the very
least, it questions the judicial Defendants' refusal to treat the Plaintiff
and her daughter fairly in the face of allegations that Plaintiff has
established are irrefutable. It demands a final answer to the question of
the identity of Plaintiff's former husband and father of Tara A. Uzamere,
the adult child of the marriage. It accuses the Defendants – especially the
judicial Defendants of criminal behavior, beginning with 18 USC §4,
misprision of felony, up to and including 18 USC §1962, RICO/racketeering,
based upon judicial Defendants obstruction of justice with regard to
commencing a criminal investigation against immigration attorneys Allen E.
Kaye, Harvey Shapiro, Jack Gladstein and Osato E. Uzamere for their
commission of fraud, identity theft, and aggravated identity theft.
Plaintiff's Verified Complaint is well-written, well-researched and
well-documented. Plaintiff is legally entitled to be enveloped by the
gossamer wings of the Fourteenth Amendment's Equal Protection extension
intended for people who are disabled –– Title II of the Americans With
Disabilities Act and Olmstead v. L.C., 527 U.S. 581 (1999), which states
that “[u]njustified isolation . . . is properly
regarded as discrimination based on disability,” observing that
“institutional placement of persons who can handle and benefit from
community settings perpetuates unwarranted assumptions that persons so
isolated are incapable of or unworthy of participating in community life.”
527 U.S. at 597, 600. The “integration mandate” of Title II of the American
with Disabilities Act, 42 U.S.C. §12101 et seq., and Section 504 of the
Rehabilitation Act, 29 U.S.C. §791 et seq., as expressed in federal
regulations and Olmstead, requires that when a state provides services to
individuals with disabilities, it must do so “in the most integrated
setting appropriate to their needs.” The “most integrated setting,”
according to the federal regulations, is “a setting that enables
individuals with disabilities to interact with non-disabled persons to the fullest extent possible.” 28 C.F.R. §35.130(d);
28 C.F.R. pt. 35 app. A.
WHEREFORE, Plaintiff prays for the
following:
a)to proceed in forma pauperis;
b)to upload all of Plaintiff's lawsuit to
PACER – including the exhibits; and to NOT upload or assign Plaintiff's
lawsuit a number until the Court can determine if Plaintiff's 250 pages of
exhibits can be uploaded in their entirety. Plaintiff will not accept
partial uploading of her documents because of Defendant Mortimer
Zuckerman's use of the media to commit fraud, identity theft and aggravated
identity theft. Plaintiff wishes to the public to see that she is telling
the truth, and to see what the Defendants did to her and to her family.
c)to assign
Plaintiff her daughter pursuant to Fed. R. Civ. P. 17(c)(2)30
d)to not
accept bribes or extortion from the Defendants – especially corrupt Jewish
billionaire Mortimer Zuckerman. He will attempt to pay you off of extort your cooperation. If Plaintiff believes
that the court has become criminally biased, the Plaintiff will report it
to the FBI. The Plaintiff will not wait for proof.
e)rapid adjudication of Plaintiff's Emergency
Motion for Expedited Judicial Notice of Adjudicative Facts Pursuant to Fed.
R. Evid. Rule 201 and for Conversion to
Plaintiff's Motion for Summary Judgment Pursuant to Fed. R. Civ. Rule 56.
f)for a jury trial if the above request is
not granted;
g)to hold adjudication of Plaintiff's
lawsuit in abeyance until Defendants' attorneys stipulate to change venue
to the District of Rhode Island;
h)for the
presiding judge to commence a criminal investigation with the goal of
arrest for the following Defendants: Ehigie Edobor Uzamere; Judge Garaufis;
Judge Leonard Sand; New York State Justice Arthur M. Schack; New York State
Justice Jeffrey S. Sunshine; New York State Justice Eileen A. Rakower; New York State Justice Paul Wooten; New York
State Justice Donna Mills for their refusal to report immigration attorneys
Allen E. Kaye, Harvey Shapiro, Jack Gladstein and Osato E. Uzamere for
their commission of aggravated identity theft; Denis P. McGowan, Regional
Director, U.S. Department of Homeland Security; “John Doe” #1, U.S.
Marshals Service for the Eastern District of New York; “John Doe” #2, U.S.
Marshals Service for the Eastern District of New York; “Jane Doe”, U.S.
Marshals Service for the Eastern District of New York;
i)for an order restraining the
Defendants from engaging in any form of S.L.A.P.P. litigation;
j)for Defendant Garaufis to established his
innocence by holding the U.S. Marshals Service for the Eastern District of
New York criminally liable and Denis P. McGowan for racketeering/obstruction
of justice;
k)to declare Defendant Garaufis's
decision in Plaintiff's lawsuit Uzamere vs. Cuomo, et al an act of fraud
upon the court and render said decision null and void, and to allow
Plaintiff to reopen her lawsuit based on Defendant Garaufis' prior act of
fraud upon the court;
l)an
injunction permanently barring Defendant Garaufis from presiding over any
of Plaintiff's lawsuits in the future;
m) to ensure
that if no federal judge ever again makes any statement that questions
Plaintiff's mental state;
n)to establish
proof that Plaintiff's appeal with regard to her lawsuit Uzamere vs. Cuomo,
et al, 11-cv-2831/11-2713-cv was actually reviewed by appellate judges; to
reveal the names of the appellate judges who rendered their decision in
Plaintiff's appeal Uzamere vs. Cuomo, et al if Plaintiff's appeal was
actually reviewed; and to determine if judges for the 2nd circuit treated
lawsuits Uzamere vs. State of New York, et al and Uzamere vs. Cuomo, et al
as one and the same lawsuit.
o)for an award of monetary damages in the
amount of $58,824 for each of the 34 years that the Defendants withheld
Plaintiff African/Nigerian/Edo/Bini name Mrs. Ehigie Edobor Uzamere for a
grand total of $2,000,000,016 (Jewish litigant Rebecca Gloria Yohalem requested $1,000,000,000 in her complaint).
p)to toll the statute of limitations to
give Plaintiff the opportunity to appeal the issue regarding change of
venue based upon a corrupt venue to the United States Supreme Court.
q)issuance of a subpoena duces tecum to obtain
the immigration records of Defendant Ehigie Edobor Uzamere so as to put to
an end to questions regarding his identity;
r) Issuance of
a subpoena duces tecum to obtain the national security letter(s) that was
sent to Cablevision.
s)for this Court, based on Defendants'
prior discovery of Plaintiff's psychiatric records as disseminated to
Defendants Daily News and made public to the New York State Office of
Mental Health, to the New York State Department of Health and to the New
York City Health and Hospitals Corporation, do not allow them any further
discovery.
t)Issuance of a subpoena duces tecum to obtain
any and all NSLs, orders or other demands to obtain non-content information
regarding Plaintiff's telephone calls.
u)Issuance of
a subpoena duces for records containing copies of current U.S. or Nigerian
identification documents for “Godwin Uzamere” from the individuals: Allen
E. Kaye, Esq; Harvey Shapiro, Esq.; Jack
Gladstein, Esq.; Osato Eugene Uzamere, Esq., NYS Judge Jeffrey S. Sunshine;
NYS Justice Arthur M. Schack; Federal District Judge Nicholas G. Garaufis;
Charles Dunne of the U.S. Marshals Service for the Eastern District of New
York; Denis P. McGowan; Agnes Flores; Martin Bolton; Bridget Davis; Samuel
Sarpong, Mortimer Zuckerman and Scott Shifrel.
v)Issuance of
a subpoena duces tecum for records of all individuals who contributed money
to Defendant Jeffries' congressional campaign and the amount of money each individual contributed.
w)to dismiss action without prejudice in
the event that the Court does not approve Plaintiff's motion to hold in
abeyance;
x)commence a
criminal investigation against the Defendants for refusal to report the
crimes committed by Allen E. Kaye, Harvey Shapiro, Jack Gladstein, Scott Shifrel, Mortimer Zuckerman, Judge Sunshine, Judge
Schack, Judge Gerstein, Osato Eugene Uzamere and Ehigie Edobor Uzamere;
y)to ensure that if Defendant Ehigie
Edobor Uzamere does not appear (as in file an answer) that the Court takes
expedited judicial notice of his failure to identify himself and render
summary judgment.
z)a public apology;
and for such
other and further relief as to this honorable Court deems just and proper.
Dated:Brooklyn, New York
August __,
2013
STATEMENT OF VERIFICATION AND GOOD
FAITH CERTIFICATION
I, Cheryl D. Uzamere, certify that I have
read the above Complaint and it is true and correct to the best of my
knowledge. I certify that I have provided tangible, irrefutable proof of my
allegations before this Court; that I researched both facts and relevant
law to the best of my ability to ensure accuracy so that my Verified
Complaint is presented to this Court in good faith. I certify before this
Court that I do not present this Verified Complaint to embarrass, annoy or
defame the Defendants.
I certify the foregoing pursuant to the
laws for perjury of the United States of America.
CHERYL D. UZAMERE
APPEARING PRO SE
______________________
Cheryl D.
Uzamere
1209 Loring
Avenue
Apt. 6B
Brooklyn, NY
11208
Tel.: (347)
985-2495
Fax: (347) 227-0118
E-mail: cuzamere@netzero.net
STUART F. DELERY, ESQ.
U.S.
Department of Justice
50
Pennsylvania Avenue, NW
Washington, DC
20530-0001
Phone: (202)
514-3301
Fax: (202)
514-8071
E-mail: stuart.f.delery@usdoj.gov
Attorney for
Defendants
Federal
agencies/employees
in Washington,
D.C
TRISTRAM J. COFFIN, ESQ.
P.O. Box 570
Burlington, VT
05402
Phone:
802-951-6725
Fax:
802-951-6540
E-mail: tristram.coffin@usdoj.gov;
Attorney for
Defendants
U.S.
Department of Homeland Security,
Rachel
McCarthy
in the State
of Vermont
PREETINDER BHARARA, ESQ.
One St.
Andrews Plaza
New York, NY
10007
Phone: 212-637-2200
Fax:
212-637-2685
E-mail: Preet.Bharara@usdoj.gov;
Attorney for
Defendants
Federal
agencies and employees in the
Southern
District of the State New York
LORETTA LYNCH, ESQ.
271 Cadman
Plaza East
Brooklyn, NY
11201
Phone:
718-254-7000
Fax:
718-254-6479
E-mail: loretta.lynch@usdoj.gov;
Attorney for Defendants
Federal
agencies and employees in the
Eastern
District of the State of New York
ERIC SCHNEIDERMAN, ESQ.
Assistant
Attorney General
New York State
Attorney's Office
120 Broadway
24th Floor
New York, NY
10271
eric.schneiderman@ag.ny.gov
Attorney for
Defendants
Agencies and employees
of the
State of New
York
MICHAEL CARDOZO, ESQ.
Corporation
Counsel
100 Church
Street
New York, NY
10013
Phone:
212-788-0303
Fax:
212-788-0367
E-mail: mcardozo@law.nyc.gov;
Attorney for
Defendants
Agencies and
employees of
the City of
New York
PETER KIRCHHEIMER, ESQ.
Attorney-in-Charge
of the
Eastern
District Office
Federal
Defenders, Inc.
One Pierrepont Plaza
16th
Floor
Brooklyn, NY
11201
Phone:
718-330-1200
E-Mail: peter_kirchheimer@fd.org
Attorney for
Defendant
Federal
Defenders, Inc. for the
Eastern
District of the State of New York
DAVID PATTON, ESQ.
Executive
Director and Attorney-in-Chief
Federal
Defender, Inc.
52 Duane
Street
10th Floor
New York, NY
10007
Phone:
212-417-8700
E-mail: david_patton@fd.org
Attorney for
Defendant
Federal
Defenders, Inc.
Southern
District of the State of New York
LISA SCHREIBERSDORF, ESQ.
Executive
Director
Brooklyn
Defender Services
177 Livingston
Street, 5th Floor
Brooklyn, NY
11201
Telephone:
(718) 254-0700
Fax: (718)
254-0897
E-mail: Lschreib@bds.org
Attorney for
Defendant
Brooklyn Defenders,
Inc.
MICHAEL D. BROWN, ESQ.
Ohrenstein & Brown, LLP
1010 Franklin
Avenue
2nd Floor
Garden City,
NY 11530
Phone:
516-535-4403
Fax:
516-873-8912
E-mail: michael.brown@oandb.com
Attorneys for
Defendants
Dr. “John Doe”
and
Brookdale
University Hospital &
Medical
Center, Inc.
ROBERT F. ROARKE, ESQ.
Regional
Managing Partner
Wilson, Elser, Moskowitz,
Edelman &
Dicker LLP
150 East 42nd
Street
New York, NY
10017
Tel.:(212)
490-3000
Fax: (212)
490-3038
E-mail: robert.roarke@wilsonelser.com
Attorneys for
Defendant
Federation
Employment
and Guidance
Services
ROBERT P. BORSODY, ESQ.
Mental Health
Association
of New York
City
50 Broadway,
19th Floor
New York, NY
10004
Tel.: (212)
254-0333
Fax: (212)
785-1910;
(212)-964-7302
E-mail: mdesroches@mhaofnyc.org;
Attorney for
Defendant
Mental Health
Association of New York
MATTHEW LEISH, ESQ.
Daily News, LP
4 New York
Plaza
New York, NY
10004
Phone: (212)
210-2341
Fax: (212)
643-7843
E-mail: mleish@nydailynews.com
Attorney for
Defendants
Mortimer
Zuckerman, Scott Shifrel
and the Daily
News, LP
RONALD S. HONBERG, J.D., M.Ed
Director of
Policy and Legal Affairs
National
Alliance for the Mentally Ill
3803 N.
Fairfax Dr., Ste. 100
Arlington, VA
22203
Phone: (703)
516-7972
Fax: (703)
524-9094
E-mail:
RonH@nami.org
Attorney for
Defendant
National Alliance
for the Mentally Ill
HERALD PRICE FAHRINGER, ESQ.
Lawline.com
CLE Inc.
61 Broadway
Suite 1105
New York, NY
10006
Phone: (877)
518-0660
E-mail: support@lawline.com
Attorney for
Defendant
Lawline.com
CLE Inc.
STEVEN M. FREEMAN, ESQ.
Anti-Defamation
League
605 Third
Avenue
New York, NY
10158-3560
Telephone:
(212) 885-7700
Fax: (212)
885-5882
E-mail: sfreeman@adl.org
Attorney for
Defendant ADL, Inc.
STEVEN C. SHEINBERG, ESQ.
Anti-Defamation
League
605 Third
Avenue
New York, NY
10158-3560
Telephone:
(212) 885-7700
Fax: (212)
885-5882
E-mail: ssheinbere@adl.org
Attorney for
Defendant ADL, Inc.
DEBORAH BENSINGER, ESQ.
Anti-Defamation
League
605 Third
Avenue
New York, NY
10158-3560
Telephone:
(212) 885-7700
Fax: (212)
885-5882
E-mail: dbensinger@adl.org
Attorney for
Defendant ADL, Inc.
DAVID L. BARKEY, ESQ.
Anti-Defamation
League
605 Third
Avenue
New York, NY
10158-3560
Telephone:
(212) 885-7700
Fax: (212)
885-5882
E-mail: dbarkey@adl.org
Attorney for
Defendant ADL, Inc.
ANDREW LAVOOTT BLUESTONE, ESQ.
Law Office of
Andrew Lavoott Bluestone
233 Broadway
Suite 2702
New York, NY
10279
Phone: (212)
791-5600
Fax: (212)
513-7206
E-mail: ALB@Bluestonelawfirm.com
Defendant Appearing Pro Se
RABBI MICHAEL JAY BROYDE, ESQ.
The Center for
the Study of Law
and Religion
at Emory University
Gambrell Hall
Suite 310
1301 Clifton
Rd.
Atlanta, GA
30322-2770
Phone:
404-712-8710
Fax:
404-712-8605
Email: mbroyde@emory.edu
Defendant
Appearing Pro Se
RABBI YONA REISS, ESQ.
305 Seventh
Avenue
12th Floor
New York, NY
10001-6008
Phone: (212)
807-9042
Fax: (212)
807-9183
E-mail: yreiss@yu.edu;
Defendant
Appearing Pro Se
RABBI SHLOMO WEISSMANN, ESQ.
305 Seventh
Avenue
12th Floor
New York, NY
10001-6008
Phone: (212)
807-9042
Fax: (212)
807-9183
E-mail: sweissmann@bethdin.org;
Defendant
Appearing Pro Se
RABBI MICHOEL ZYLBERMAN, ESQ.
305 Seventh
Avenue
12th Floor
New York, NY
10001-6008
Phone: (212)
807-9042
Fax: (212)
807-9183
E-mail: mzylberman@bethdin.org
Defendant
Appearing Pro Se
MR. NORMAN BOBROW
18106 Tudor Rd
Jamaica, NY
11432-1447
Attorney Not
Yet Known
MR. SANDER GERBER
44 E End Ave
Apt 9A
New York, NY
10028-7977
Attorney Not
Yet Known
MR. RUSLAN AGARUNOV
122 Meridian
Blvd
Arverne, NY 11692-2027
Attorney Not
Yet Known
MR. PAUL BURG
161 E 71st St
New York, NY
10021-4322
Attorney Not
Yet Known
MR. MICHAEL GRANOFF
59 Bliss Ave
Tenafly, NJ
07670-3036
Attorney Not
Yet Known
BERTRAM BERNS
1831 Booksin Ave
San Jose, CA
95125-4502
Attorney Not
Yet Known
MS. VICKIE FISHMAN
2163 Royal
Lodge Dr
Falls Church,
VA 22043-3061
Attorney Not
Yet Known
MR. MARVIN ISRAELOW
835
Hardscrabble Rd
Chappaqua, NY
10514-3011
Attorney Not
Yet Known
MR. ALAN LEVOW
2891 Howell
Mill Rd NW
Atlanta, GA
303271333
Attorney Not
Yet Known
MR. WILLIAM RUSSELL-SHAPIRO
100 1st Street
Suite 1400
San Francisco,
CA 94105-4631
Attorney Not
Yet Known
MR. MARC SPIEGEL
26 Balboa CVS
Newport Beach,
CA 92663-3226
Attorney Not
Yet Known
MS. DONNA STERNBERG
PO Box 98100
Baton Rouge,
Louisiana 708989100
Attorney Not
Yet Known
MR. DANIEL TENENBLATT
608 N Beverly Dr
Beverly Hills,
CA 90210-3320
Attorney Not
Yet Known
LESLIE TOPPER
1045 Park Ave
Apt 3A
New York, NY
10028-1030
Attorney Not
Yet Known
MR. CRAIG WEISS
6387 Ronald Rd
Memphis, TN
38120-3208
Attorney Not Yet Known
WORLD ALLIANCE FOR ISRAEL PAC
8306 Wilshire
Blvd
Suite 1579
Beverly Hills,
CA 90211-2382
Attorney Not
Yet Known
MR. LEE ZIFF
439 N Canon
Dr.
Suite 300
Beverly Hills,
CA 90210-3909
Attorney Not
Yet Known
ALLEN E. KAYE, ESQ.
Allen E. Kaye,
P.C.
111 Broadway,
13th Floor
New York, NY
10006
Tel.: (212)
964-5858
Fax: (212)
68-3734
akaye@kayevisalaw.com
Attorney Not
Yet Known
HARVEY SHAPIRO, ESQ.
Law Offices of
Harvey Shapiro
250 W. 57th
Street
Suite 1720
New York, NY
10107
Tel.: (212)
355-5240
E-mail: ckawalsky@harveyshapiro.com;
Attorney Not
Yet Known
JACK GLADSTEIN, ESQ.
Gladstein
& Messinger
118-21 Queens
Boulevard
Forest Hills,
NY 11375
Tel.: (718)
793-7800
Fax: (718)
793-0524
E-mail: Gladmessattys@aol.com
Attorney Not
Yet Known
OSATO EUGENE UZAMERE, ESQ.
Uzamere and
Associates, PLLC
1851 Watson
Avenue
Bronx, NY
10472
(718) 409-3389
(718) 504-5326
E-mail: info@uzalaw.com
Attorney Not
Yet Known
SENATOR EHIGIE EDOBOR UZAMERE
Nigerian
Senate
The National
Assembly Complex,
3 Arms Zone
PMB 141 Abuja
FCT, Nigeria
Phone: (234)
(9) 523-2127
E-mail: ehigieuzamere@yahoo.com
Attorney Not
Yet Known
|
1
|
Wikipedia.org,
http://en.wikipedia.org/wiki/First_Amendment_to_the_Constitution_of_the_United_States,
credit for subparagraphs 1(a), (b), and (c).
|
|
2
|
Washington
Post, by Robert Barnes, August 12, 2012
|
|
3
|
18 USC §1001
|
|
4
|
New York
State Penal Law §210.15 Perjury in the first degree. A person is guilty
of perjury in the first degree when he swears falsely and when his false
statement (a) consists of testimony, and (b) is material to the action, proceeding
or matter in which it is made. Perjury in the first degree is a class D
felony.
|
|
5
|
22 CFR
§92.65 - Depositions to prove genuineness of foreign documents – (a)
Authority to execute commission. Under the provisions of section 1 of the
act of June 25, 1948, as amended (sec. 1, 62 Stat. 834, sec. 53, 63 Stat.
96; 18 U.S.C. 3492), a diplomatic or consular officer may be commissioned
by an United States court to take the testimony of a witness in a foreign
country either on oral or written interrogatories, or partly on oral and
partly on written interrogatories, for the purpose of determining the
genuineness of any foreign document.
|
|
6
|
22 NYCRR
100.3(8), (11): “. . .a judge shall not make any public comment about a
pending or impending proceeding in any court within the United States or
its territories. The judge shall require similar abstention on the part
of court personnel...” and that “a judge shall not disclose or use, for
any purpose unrelated to judicial duties, nonpublic information acquired
in a judicial capacity.” New York State Civil Rights Law §79-h (Shield
Laws) affords members of the media to keep their news sources
confidential. According to Wikipedia.org
(http://en.wikipedia.org/wiki/Shield_laws_in_the_United_States), however,
“currently the U.S. federal government has not enacted any national
shield laws. . .” Please refer to Branzburg v.
Hayes, 408 U.S. 665 (1972), in which reporter Paul Branzburg
of the Louisville Courier-Journal, in the course of
his reporting duties, witnessed people manufacturing and using hashish.
He was ordered to name his sources. Earl Caldwell, a reporter for the New
York Times, interviewed leaders of the Black Panthers, and Paul Pappas, a
Massachusetts television reporter who also reported on the Black
Panthers, were called to testify before separate
grand juries about illegal actions they might have witnessed. They
refused, citing privilege under the Press Clause, and were held in
contempt. In a fiercely split decision, the Court ruled 5-4 against the
existence of reportorial privilege in the Press Clause of the First
Amendment
|
|
7
|
Plaintiff
respectfully reminds this court of the continuing violations doctrine. In
tort law, if a defendant commits a series of illegal acts against another
person, or, in criminal law, if someone commits a continuing crime (which
can be charged as a single offense), the period of limitation begins to
run from the last act in the series. In the case of Treanor v. MCI
Telecommunications, Inc., the U.S. Court of Appeals for the Eighth Circuit
explained that the continuing violations doctrine "tolls the statute
of limitations in situations where a continuing pattern forms due to
[illegal] acts occurring over a period of time,
as long as at least one incident . . . occurred within the limitations
period. See paragraphs 46 and 47
|
|
8
|
Law of
Agency, Wikipedia.org, http://en.wikipedia.org/wiki/Law_of_agency: The
common law principle in operation is usually represented in the Latin
phrase, qui facit per alium,
facit per se, i.e. the one who acts through
another, acts in his or her own interests and it is a parallel concept to
vicarious liability and strict liability in which one person is held
liable in criminal law or tort for the acts or omissions of another.
Oklahoma City v. Tuttle, 471 U.S. 808 (1985): “As for those things which
a servant may do on behalf of his master, they seem all to proceed upon
this principle, that the master is answerable for the act of his servant,
if done by his command, either expressly given, or implied: “nam qui facit per alium, facit per se.”
|
|
9
|
18 USC §
2709(e) - Counterintelligence Access to Telephone Toll and Transactional
Records, Requirement That Certain Congressional Bodies Be Informed.— On a
semiannual basis the Director of the Federal Bureau of Investigation shall
fully inform the Permanent Select Committee on Intelligence of the House
of Representatives and the Select Committee on Intelligence of the
Senate, and the Committee on the Judiciary of the House of
Representatives and the Committee on the Judiciary of the Senate,
concerning all requests made under subsection (b) of this section. Hobbs Act: Some courts have held that a Hobbs Act
violation does not require that the public official have de jure power to
perform any official act paid for as long as it was reasonable to believe
that he/she had the de facto power to perform the requested act. See
United States v. Nedza, 880 F.2d 896, 902 (7th
Cir. 1989) (victim reasonably believed state senator had the ability to
impact a local business)
|
|
10
|
“It’s called
protecting America,” said Sen. Dianne Feinstein, California Democrat,
saying that the secret court order which Britain’s Guardian newspaper
posted online Wednesday night is a routine three-month renewal and proves
that the program is carefully overseen by federal judges.http://www.washingtontimes.com/news/2013/jun/6/white-house-defends-phone-snooping/#ixzz2VcmQgulO
|
|
11
|
Sen. Saxby
Chambliss, Georgia Republican, said the surveillance has “proved
meritorious, because we have gathered significant information on bad
guys, but only on bad guys, over the years.”
http://www.washingtontimes.com/news/2013/jun/6/white-house-defends-phone-snooping/#ixzz2VcmQgulO.
|
|
12
|
Plaintiff
alleges LifeNet suicide/mental health hotline
was fraudulently contacted by Defendant U.S. Marshal Service for the
Eastern District of New York and told that Plaintiff threatened Defendant
Nicholas with bodily harm. That Defendant USMS knew that Plaintiff
committed no crime is a clear violation of 18 USC §1001
|
|
13
|
Plaintiff's
lawsuit Cheryl D. Uzamere vs. The State of New York, The City of New
York, The Metropolitan Police Department and the New York City Transit
Authority Case Nos. 09-cv-2703/09-3197-cv dealt with issues pertaining to
defendants' refusal to provide Plaintiff with a half fare Metrocard. The issues raised in that lawsuit had
nothing to do with Plaintiff's lawsuit Uzamere vs. Cuomo, et al Case Nos.
1:2011-cv-02831/11-2713-cv, which dealt with, inter alia, Plaintiff's
being blacklisted from more integrated psychiatric service providers in
violation of Title II of the Americans With Disabilities Act. Defendant
Wolfe should have been able to see the glaring differences between the
two cases. Plaintiff therefore alleges that Defendant Catherine O'Hagan
Wolfe's return of Plaintiff's appeal was an act of fraud upon the court
done solely to prevent Plaintiff from filing her appeal against Defendant
Judge Nicholas G. Garaufis' FRCP-lacking, memorandum-lacking decision in
Plaintiff's lawsuit Uzamere vs. Cuomo, et al
|
|
14
|
New York
Wiretapping Law: New York's wiretapping law is a "one-party
consent" law. New York makes it a crime to record or eavesdrop on an
in-person or telephone conversation unless one party to the conversation
consents. N.Y. Penal Law §§ 250.00, 250.05. Thus, if you operate in New
York, you may record a conversation or phone call if you are a party to
the conversation or you get permission from one party to the conversation
in advance. This serves as a reminder to any defendant that wants to
nullify Plaintiff's recorded conversation with Defendant Davis based on
the delusion that Plaintiff's doesn't know N.Y. Penal Law §250.00 and
§250.05
|
|
15
|
18 USC
§2709(c): “If the Director of the Federal Bureau of Investigation. .
.certifies that otherwise there may result a danger. . .to the life or
physical safety or any person, no wire or electronic communications
service provider, or officer, employee, or agent thereof, shall disclose
to any person. . .that the Federal Bureau of Investigation has sought or
obtained access to information or records under this section.” This law
does not state that a telecommunications or internet service provider
cannot disclose that a consumer does not have a national security letter
filed against him/her with the consumer's telephone company and/or
internet provider. The nondisclosure agreement only prohibits disclosure
if a consumer has a national security letter filed against him/her with
the consumer's telephone company and/or internet service provider
|
|
16
|
The official
and the payor need not state the quid pro quo in express terms, for
otherwise the law's effect could be frustrated by knowing winks and nods.
The inducement from the official is criminal if it is express or if it is
implied from his words and actions, so long as he intends it to be so and
the payor so interprets it.” Evan v. United States, 112 S.Ct. 1881, 504
U.S. 255, 119 L.Ed.2d 57
|
|
17
|
Wikipedia.org
(http://en.wikipedia.org/wiki/Clean_hands) Unclean hands, sometimes
called the clean hands doctrine or the dirty hands doctrine, is an equitable
defense in which the defendant argues that the plaintiff is not entitled
to obtain an equitable remedy on account of the fact that the plaintiff
is acting unethically or has acted in bad faith with respect to the
subject of the complaint—that is, with “unclean hands. The defendant has
the burden of proof to show the plaintiff is not acting in good faith.
The doctrine is often stated as “those seeking equity must do equity” or
“equity must come with clean hands.” 2. The maxim "he who comes into
equity must come with clean hands" closes the doors of a court of
equity to one tainted with inequitableness or bad faith relative to the
matter in which he seeks relief, however improper may have been the
behavior of the defendant. P. 324 U. S. 814. 3. The "clean
hands" doctrine is rooted in the historical concept of a court of
equity as a vehicle for affirmatively enforcing the requirements of
conscience and good faith. P. 324 U.S. 814. 4. While equity does not
require that its suitors shall have led blameless lives as to other
matters, it does require that they shall have acted without fraud or
deceit as to the matter in issue. P. 324 U. S. 814. Where a suit in
equity concerns the public interest as well as the private interests of
the litigants, the "clean hands" doctrine assumes greater
significance, for if the equity court in such case properly applies the
maxim to withhold its assistance, it not only prevents a wrongdoer from
enjoying the fruits of his transgression but averts an injury to the public.
P. 324 U. S. 815. Precision Instrument Mfg. Co. v. Automotive Co. 324
U.S. 806 (1945
|
|
18
|
When
Defendant Ehigie E. Uzamere's brother Nosayaba
and his wife Ethel sponsored Defendant Ehigie Edobor Uzamere, Nosayaba and Ethel applied as his father and
mother-in-law. Sponsorship as a beneficiary's parents takes less time
than sponsorship as a beneficiary's brother and sister-in-law (IR2
sponsorship). Sponsorship as a spouse of a U.S. citizen takes even less
time (IR1 sponsorship).
|
|
19
|
Daily News
article dated November 5, 2009.
|
|
20
|
See pages
from attorneys' fraudulent affirmations falsifying Plaintiff's
ex-husband's identity as “Godwin Uzamere”; fraudulent 1-130 that was
falsified by attorneys Allen E. Kaye and Harvey Shapiro, documents from
Rachel McCarthy, Bar Counsel and T. Diane Cejka,
Director, FOIA/PA, U.S. Department of Citizenship and Immigration
Services and Daily News article dated November 5, 2009.
|
|
21
|
22 NYCRR
§50.1(D) Court employees shall not disclose any confidential information
received in the course of their official duties,
except as required in the performance of such duties, nor use such
information for personal gain or advantage. 22 NYCRR §100.3(B)(8) – A
judge shall not make any public comment about a pending or impending
proceeding in any court within the United States or its territories. The
judge shall require similar abstention on the part of court personnel
subject to the judge's direction and control. This paragraph does not
prohibit judges from making public statements in the
course of their official duties or from explaining for public
information the procedures of the court. This paragraph does not apply to
proceedings in which the judge is a litigant in a personal capacity. 22
NYCRR §100.3(B)(11) A judge shall not disclose
or use, for any purpose unrelated to judicial duties, nonpublic
information acquired in a judicial capacity
|
|
22
|
Some courts
have held that a Hobbs Act violation does not require that the public
official have de jure power to perform any official act paid for as long
as it was reasonable to believe that he/she had the de facto power to
perform the requested act. See United States v. Nedza,
880 F.2d 896, 902 (7th Cir. 1989) (victim reasonably believed state
senator had the ability to impact a local business); United States v.
Bibby, 752 F.2d 1116, 1127-28 (6th Cir. 1985); United States v. Sorrow,
732 F.2d 176, 180 (11th Cir. 1984); United States v. Rindone,
631 F.2d 491, 495 (7th Cir. 1980) (public official can extort money for
permit beyond control of his office, so long as victim has a reasonable
belief that he could affect issuance); United States v. Rabbitt, 583 F.2d 1014 (8th Cir. 1978), cert. denied,
439 U.S. 1116 (1979); United States v. Harding, 563 F.2d 299 (6th Cir.
1977), cert. denied, 434 U.S. 1062 (1978); United States v. Brown, 540
F.2d 364 (8th Cir. 1976); United States v. Hall, 536 F.2d 313 (10th
Cir.), cert. denied, 429 U.S. 919 (1976); United States v. Hathaway, 534
F.2d 386 (1st Cir.), cert. denied, 429 U.S. 819 (1976); United States v.
Mazzei, 521 F.2d 639, 643 (3rd Cir.) (en banc),
cert. denied, 423 U.S. 1014 (1975); United States v. Price, 507 F.2d 1349
(4th Cir. 1974).
|
|
23
|
http://www.come-and-hear.com/editor/moser-broyde/index.html
|
|
24
|
http://www.ottmall.com/mj_ht_arch/v15/mj_v15i20.html#CDX
|
|
25
|
http://www.come-and-hear.com/editor/america_1.html
|
|
26
|
http://www.come-and-hear.com/supplement/so-daat-emet/index.html
|
|
27
|
http://www.come-and-hear.com/editor/capunish_4.html
|
|
28
|
http://www.come-and-hear.com/babakamma/babakamma_113.html
|
|
29
|
http://www.come-and-hear.com/supplement/so-daat-emet/index.html
|
|
30
|
Minor or
incompetent person. Without a Representative. A minor or an incompetent
person who does not have a duly appointed representative may sue by a
next friend or by a guardian ad litem. The court
must appoint a guardian ad litem—or issue
another appropriate order -- to protect a minor or incompetent person
who is unrepresented in an action.
|
|
![Jew whipping slave[6]](chapter_125_uzamere_v_usa_files/image375.png)
![WTC Falling Death2[3]](chapter_125_uzamere_v_usa_files/image409.png)
![Jew whipping slave[6]](chapter_125_uzamere_v_usa_files/image456.png)
