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NEW YORK STATE SUPREME COURT
COUNTY OF KINGS
 Cheryl D. Uzamere VERIFIED COMPLAINT
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Plaintiff, JURY TRIAL DEMANDED
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against -
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Senator
Ehigie Edobor Uzamere, also known as Godwin E. Uzamere, Allen E. Kaye,
P.C., Allen E. Kaye, P.C., Allen E. Kaye, Esq., Harvey Shapiro, Esq.,
Bernard J. Rostanski and Jack Gladstein, Esq.
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Defendants.
STATE OF NEW YORK )
COUNTY OF KINGS ) ss:
Plaintiff
Cheryl D. Uzamere, appearing on her own behalf, states and alleges the
following:
1) That at all
times herein relevant, the Plaintiff was a resident of the State
of New York, City of Brooklyn and County of Kings.
2) That on or around December 1977,
two years before Plaintiff met Defendant Ehigie Edobor Uzamere, the
services of Defendant Allen E. Kaye were retained on behalf of the
aforesaid Defendant to apply for lawful permanent residence based on U.S.
Immigration and Naturalization Service's IR2 criteria for unmarried
immigrants under 21 years of age.
3) That at the time that the
aforesaid Defendant first retained the aforementioned
attorney, Defendant Uzamere retained the aforesaid attorney's
services using the proper name Ehigie Edobor Uzamere, and proper date of
birth, December 31, 1960; and that the aforesaid attorney accepted as
true and correct the aforementioned information as Defendant Uzamere's
name and birthday.
4) That almost two (2) years later,
on November 20, 1979, in an attempt to expedite receipt of lawful
permanent residence by circumventing the IR2 residence for which
Defendant Uzamere previously applied, the aforesaid Defendant wrote the
fictitious name and birthday Godwin Uzamere, June 1, 1955 on the marriage
affidavit without producing governmental identification to verify his age
and identity.
5) That on or around December 17,
1979, Defendant immigration attorney, Allen E. Kaye, Defendant
immigration attorney Harvey Shapiro, working under the supervision of
Defendant Allen E. Kaye, and New York State notary public Defendant
Bernard J. Rostanski signed their names to
swear and verify as true and correct the fraudulent name and birthday
that Defendant Uzamere placed on the I-130 immediate relative sponsorship
form and on which Defendant Uzamere perjured himself.
6) That Plaintiff did not discover
tangible evidence of Defendants' two (2) immigration file numbers
A24-027-764 and A35-201-224, Defendant's Family Court arrest warrant for
Defendant Uzamere's non-payment of child support, Plaintiff's immigration
fraud complaint against Defendant Uzamere dated August 12, 1980, and
other tangible evidence of Defendants' fraud until June 12, 2009.
7) That on or around October 1,
2003, Defendant Uzamere's divorce attorney Defendant Jack Gladstein sent
Plaintiff correspondence containing the same fictitious name that
Defendant Uzamere used to marry the Plaintiff.
8) That from November, 1979 until the
present time, each and every Defendant has refused to publicize and to
willingly participate in the publicizing of Defendant Uzamere's identity
to governmental agencies; that from 1979 until the present time,
Defendants have continuously, fraudulently and maliciously withheld the
proper legal name of Defendant Uzamere from the Plaintiff; and that from
1979 to the present time, Defendants have actively discouraged its public
use.
9) That as a result of the
Defendants' 30-year act of fraud, Defendants set in motion a series of
events that resulted in depriving Plaintiff of the use of Defendant
Uzamere's proper name as marital property.
10) That as a result of Defendants'
30-year act of fraud, Defendants set in motion a series of events that
included Defendant Uzamere's illegal retention of attorney Jack Gladstein
to attempt to dupe Plaintiff into filing a divorce action against
Defendant Uzamere using the same fictitious name that Defendants used to
assist Defendant Uzamere in contracting a green-card marriage with the
Plaintiff; and to continue to defraud Plaintiff by withholding the true
identity of Defendant Uzamere.
11) That as a result of Defendants'
30-year act of fraud, Defendants set in motion a series of events that
included publicly defaming Plaintiff as mentally unstable so as to publicly discredit her complaints against
Defendants.
12) That as a result of Defendants'
30-year act of fraud, Defendants set in motion a series of events that
included Defendant Uzamere's submission of a fraudulent unauthenticated
foreign counter-affidavit during Plaintiff's divorce proceeding; and that
the aforesaid unauthenticated foreign counter-affidavit created by
Defendant Uzamere fraudulently claimed to be from Defendant Uzamere's
cousin Godwin E. Uzamere.
13) That a result of Defendants'
30-year of fraud, Defendants set in motion a series of events that
include Plaintiff being publicly defamed as an anti-Semite by Defendant
Allen E. Kaye.
14) That as a result of Defendants'
30-year of fraud, Defendants set in motion a series of events that
include Plaintiff being falsely charged with simple assault.
15) That the Defendants maliciously
engaged in the aforesaid tortious acts for the sole purpose of hiding the
existence of Plaintiff's marriage and the birth and existence of the
child of the marriage.
16) That wholly and solely as a result
of the Defendants' tortious acts of fraud over the course of nearly 30
years, Plaintiff suffered severe personal injuries and has been damaged
in the amount of $100,000,000.00.
AS AND FOR A FIRST SEPARATE AND DISTINCT CAUSE
OF ACTION
17) Plaintiff
hereby repeats and realleges each and every
allegation contained in paragraphs 1 through 16 as if fully set forth
herein.
18) That Defendant Uzamere owed Plaintiff
the duty of not engaging in fraud with regard to the use of his proper
name and other legal identifiers that by marriage now belong to the
Plaintiff; that Defendant Uzamere owed Plaintiff the duty of not
withholding his legal identifiers in a manner that would cause the New
York State Unified Court System to question the existence of Plaintiff's
marriage to Defendant Uzamere and paternity of the child of the marriage,
thereby preventing Plaintiff from availing herself and her family of
receiving benefits associated with being the wife of Defendant Uzamere
and mother of Defendant Uzamere's daughter Tara.
19) That Defendant Uzamere owed
Plaintiff the duty of publicly disseminating information regarding
Plaintiff's marriage to governmental agencies, to encourage and enforce
the legal use of Defendant Uzamere's proper name and to cause it to be
publicly recognized as Plaintiff's primary marital property, so as to
allow Plaintiff to exercise her legal right to share title of all other
marital assets with Defendant Uzamere and to share the responsibilities
associated with caring for any child with whom Plaintiff and Defendant
Uzamere share consanguinity; and that Defendant Uzamere owed Plaintiff
the duty of not defrauding Plaintiff by taking advantage of Plaintiff's
lack of knowledge of Title 8, U.S.C. -- Aliens and Nationality by
withholding from Plaintiff's her role as an unwitting participant in a
federal felony.
20) That Defendant Uzamere owed
Plaintiff the duty of protecting Plaintiff's due process rights with
regard to Defendant Uzamere's proper name by not withholding it, and by
legally recognizing it as Plaintiff's primary marital property, and to
not engage in defrauding Plaintiff of her property based on Defendant
Uzamere's desire to engage in an act of green card marriage fraud for
permanent residence.
21) That wholly and solely as a result
of the Defendant Uzamere's nearly thirty (30) years of tortious acts of
fraud, the Plaintiff suffered severe personal injuries and have been
damaged in the amount of $100,000,000.00.
AS AND FOR A SECOND SEPARATE AND DISTINCT
CAUSE OF ACTION
22) Plaintiff
hereby repeats and realleges each and every
allegation contained in paragraphs 1 through 21 as if fully set forth
herein.
23) That Defendant Uzamere failed in
his duty to provide Plaintiff with his proper name by creating and
facilitating the existence of the fraudulent name and birthday Godwin E.
Uzamere, June 1, 1955.
24) That Defendant Uzamere failed in
his duty to publicly disseminate information regarding Plaintiff's
marriage to appropriate governmental agencies; that Defendant Uzamere
failed in his duty to encourage and enforce the legal use of his proper
name and to cause it to be publicly recognized as Plaintiff's primary
marital property, so as to allow Plaintiff to exercise her legal right to
share title of all other marital assets with Defendant Uzamere and to
share the responsibilities associated with caring for any child with whom
Plaintiff and Defendant Uzamere share consanguinity.
25) That Defendant Uzamere failed in
protecting Plaintiff's due process rights with regard
to Defendant Uzamere's proper name as being Plaintiff's primary
marital property.
26) That wholly and solely as a result
of the Defendant Uzamere's nearly thirty (30) years of tortious acts of
fraud, the Plaintiff suffered severe personal injuries and have been
damaged in the amount of $100,000,000.00.
AS AND FOR A THIRD SEPARATE AND DISTINCT CAUSE
OF ACTION
27) Plaintiff hereby repeats and
realleges each and every allegation contained in
paragraphs 1 through 26 as if fully set forth herein.
28) That Plaintiff has suffered
financial deprivation insofar as Plaintiff has never been unable to
obtain government documentation to establish her legal status as
Defendant Uzamere's spouse, and has never been able to establish that
Defendant Uzamere is the biological father of the child of the marriage;
that Plaintiff has been unable to obtain Defendant Ehigie Edobor
Uzamere's identification including, real social security number, real driver's
license, real passport, real address or any other identification that the
Plaintiff can use to take to court to establish her legal status as the
spouse of Defendant Uzamere so as to share title with and obtain benefits
from Defendant Uzamere based on being Defendant's spouse.
AS AND FOR A FOURTH SEPARATE AND DISTINCT
CAUSE OF ACTION
29) Plaintiff
hereby repeats and realleges each and every
allegation contained in paragraphs 1 through 28 as if fully set forth
herein.
30) That the Defendant Uzamere knew or
should have known that when governmental employees, attorneys, notaries
or any type of fiduciary agent uses the power of his/her office to help a
client create fraudulent documents, said fraudulent documents can be used
to circumvent a poor spouse's ability to locate a missing parent or
spouse, forcing the abandoned spouse and children into poverty.
Furthermore; as the potential recipient of immigration benefits with
immediate access to legal counsel, Defendant Uzamere knew or should have
known that using the power of one's position as a fiduciary agent to
swear to create a fraudulent document for the sole purpose of obtaining
immigration benefits is a tort and a crime.
AS AND FOR A FIRST SEPARATE AND DISTINCT CAUSE
OF ACTION
31) Plaintiff
hereby repeats and realleges each and every
allegation contained in paragraphs 1 through 30 as if fully set forth
herein.
32) That Defendant corporation Allen E.
Kaye, P.C. owed Plaintiff the duty of not engaging in fraud with regard
to the use of Defendant Uzamere's proper name and other legal identifiers
belonging to Defendant Uzamere; and that the Defendant corporation owed
Plaintiff the duty of not withholding Defendant Uzamere's legal
identifiers in a manner that would cause the New York State Unified Court
System to question the existence of Plaintiff's marriage to Defendant
Uzamere and paternity of the child of the marriage, thereby preventing
Plaintiff from availing herself and her family of receiving benefits
associated with being the wife of Defendant Uzamere and mother of
Defendant Uzamere's daughter Tara.
33) That Defendant corporation Allen E.
Kaye, P.C. owed Plaintiff the duty of publicly disseminating information
regarding Plaintiff's marriage to governmental agencies, to encourage and
enforce the legal use of Defendant Uzamere's proper name and to cause it
to be publicly recognized as Plaintiff's primary marital property, so as
to allow Plaintiff to exercise her legal right to share title of all
other marital assets with Defendant Uzamere and to share the
responsibilities associated with caring for any child with whom Plaintiff
and Defendant Uzamere share consanguinity; and that Defendants owed
Plaintiff the duty of not defrauding Plaintiff by taking advantage of
Plaintiff's lack of knowledge of Title 8, USC, Aliens and Nationality by
withholding from Plaintiff's her role as an unwitting participant in a
federal felony.
34) That Defendant corporation Allen E.
Kaye owed Plaintiff the duty of protecting Plaintiff's due process rights
with regard to Defendant Uzamere's proper name by not withholding it from
Plaintiff, and by legally recognizing it as Plaintiff's primary marital
property, and by not engaging in defrauding Plaintiff of her property
based on Defendant's desire to conspire to aid and abet Defendant
Uzamere's commission of the crime of marriage fraud for permanent
residence.
35) That wholly and solely as a result
of the Defendant corporation Allen E. Kaye P.C.'s nearly thirty (30)
years of tortious acts of fraud, the Plaintiff suffered severe personal
injuries and have been damaged in the amount of $100,000,000.00.
AS AND FOR A SECOND SEPARATE AND DISTINCT
CAUSE OF ACTION
36) Plaintiff hereby repeats and
realleges each and every allegation contained in
paragraphs 1 through 35 as if fully set forth herein.
37) That Defendant corporation Allen E.
Kaye, P.C. failed in its duty to provide Plaintiff with the proper name
of Defendant Uzamere by facilitating the existence of the fraudulent name
and birthday Godwin E. Uzamere, June 1, 1955.
38) That Defendant corporation Allen E.
Kaye, P.C. failed in its duty to publicly disseminate information
regarding Plaintiff's marriage to appropriate governmental agencies; that
Defendant corporation failed in its duty to encourage and enforce the
legal use of Defendant Uzamere's proper name and to cause it to be
publicly recognized as Plaintiff's primary marital property, so as to
allow Plaintiff to exercise her legal right to share title of all other
marital assets with Defendant Uzamere and to share the responsibilities
associated with caring for any child with whom Plaintiff and Defendant
Uzamere share consanguinity.
39) That Defendants failed in
protecting Plaintiff's due process rights with regard
to Defendant Uzamere's proper name as being Plaintiff's primary
marital property.
40) That wholly and solely as a result
of the Defendant corporation Allen E. Kaye P.C.'s nearly thirty (30)
years of tortious acts of fraud, the Plaintiff suffered severe personal
injuries and have been damaged in the amount of $100,000,000.00.
AS AND FOR A THIRD SEPARATE AND DISTINCT CAUSE
OF ACTION
41) Plaintiff
hereby repeats and realleges each and every
allegation contained in paragraphs 1 through 40 as if fully set forth
herein.
42) That Plaintiff has suffered
financial deprivation insofar as Plaintiff has never been unable to
obtain government documentation to establish her legal status as
Defendant Uzamere's spouse, and has never been able to establish that
Defendant Uzamere is the biological father of the child of the marriage;
that Plaintiff has been unable to obtain Defendant Ehigie Edobor
Uzamere's identification including, real social security number, real
driver's license, real passport, real address or any other identification
that the Plaintiff can use to take to court to establish her legal status
as the spouse of Defendant Uzamere so as to share title with and obtain
benefits from Defendant Uzamere based on being Defendant's spouse.
AS AND FOR A FOURTH SEPARATE AND DISTINCT
CAUSE OF ACTION
43) Plaintiff
hereby repeats and realleges each and every
allegation contained in paragraphs 1 through 42 as if fully set forth
herein.
44) That the Defendant corporation
Allen E. Kaye, P.C. knew or should have known that when governmental
employees, attorneys, notaries or any type of fiduciary agent uses the
power of his/her office to help a client create fraudulent documents,
said fraudulent documents can be used to circumvent a poor spouse's
ability to locate a missing parent or spouse, forcing the abandoned
spouse and children into poverty. Furthermore; the Defendant corporation,
operating under the laws of the State of New York as a law firm, knew or
should have known that using the power of one's position as a fiduciary
agent to swear to create a fraudulent document is a tort and a crime.
AS AND FOR A FIRST SEPARATE AND DISTINCT CAUSE
OF ACTION
45) Plaintiff
hereby repeats and realleges each and every
allegation contained in paragraphs 1 through 44 as if fully set forth
herein.
46) That Defendant Allen E. Kaye, Esq.
owed Plaintiff the duty of not engaging in fraud with regard to the use
of Defendant Uzamere's proper name and other legal identifiers belonging
to Defendant Uzamere; and that the Defendant Kaye owed Plaintiff the duty
of not withholding Defendant Uzamere's legal identifiers in a manner that
would cause the New York State Unified Court System to question the
existence of Plaintiff's marriage to Defendant Uzamere and paternity of
the child of the marriage, thereby preventing Plaintiff from availing
herself and her family of receiving benefits associated with being the
wife of Defendant Uzamere and mother of Defendant Uzamere's daughter
Tara.
47) That Defendant Kaye owed Plaintiff
the duty of publicly disseminating information regarding Plaintiff's
marriage to governmental agencies, to encourage and enforce the legal use
of Defendant Uzamere's proper name and to cause it to be publicly
recognized as Plaintiff's primary marital property, so as to allow
Plaintiff to exercise her legal right to share title of all other marital
assets with Defendant Uzamere and to share the responsibilities
associated with caring for any child with whom Plaintiff and Defendant
Uzamere share consanguinity; and that Defendants owed Plaintiff the duty
of not defrauding Plaintiff by taking advantage of Plaintiff's lack of
knowledge of Title 8, USC, Aliens and Nationality by withholding from
Plaintiff's her role as an unwitting participant in a federal felony.
48) That Defendant Kaye owed Plaintiff
the duty of protecting Plaintiff's due process rights with regard to
Defendant Uzamere's proper name by not withholding it, and by legally
recognizing it as Plaintiff's primary marital property, and to not engage
in defrauding Plaintiff of her property based on Defendant's desire to
conspire to aid and abet Defendant Uzamere's commission of the crime of
marriage for permanent residence.
49) That wholly and solely as a result
of the Defendant Kaye's nearly thirty (30) years of tortious acts of
fraud, the Plaintiff suffered severe personal injuries and have been
damaged in the amount of $100,000,000.00.
AS AND FOR A SECOND SEPARATE AND DISTINCT
CAUSE OF ACTION
50) Plaintiff
hereby repeats and realleges each and every allegation
contained in paragraphs 1 through 49 as if fully set forth herein.
51) That Defendant Kaye failed in his
duty to provide Plaintiff with the proper name of Defendant Uzamere by
facilitating the existence of the fraudulent name and birthday Godwin E.
Uzamere, June 1, 1955.
52) That Defendant Kaye failed in his
duty to publicly disseminate information regarding Plaintiff's marriage
to appropriate governmental agencies; that Defendant Kaye failed in his
duty to encourage and enforce the legal use of Defendant Uzamere's proper
name and to cause it to be publicly recognized as Plaintiff's primary
marital property, so as to allow Plaintiff to exercise her legal right to
share title of all other marital assets with Defendant Uzamere and to
share the responsibilities associated with caring for any child with whom
Plaintiff and Defendant Uzamere share consanguinity.
53) That Defendant Kaye failed in
protecting Plaintiff's due process rights with regard
to Defendant Uzamere's proper name as being Plaintiff's primary
marital property.
54) That wholly and solely as a result
of the Defendant Kaye's nearly thirty (30) years of tortious acts of
fraud, the Plaintiff suffered severe personal injuries and have been
damaged in the amount of $100,000,000.00.
AS AND FOR A THIRD SEPARATE AND DISTINCT CAUSE
OF ACTION
55) Plaintiff
hereby repeats and realleges each and every
allegation contained in paragraphs 1 through 54 as if fully set forth
herein.
56) That Plaintiff has suffered
financial deprivation insofar as Plaintiff has never been unable to
obtain government documentation to establish her legal status as
Defendant Uzamere's spouse, and has never been able to establish that
Defendant Uzamere is the biological father of the child of the marriage;
that Plaintiff has been unable to obtain Defendant Ehigie Edobor
Uzamere's identification including, real social security number, real
driver's license, real passport, real address or any other identification
that the Plaintiff can use to take to court to establish her legal status
as the spouse of Defendant Uzamere so as to share title with and obtain
benefits from Defendant Uzamere based on being Defendant's spouse.
AS AND FOR A FOURTH SEPARATE AND DISTINCT
CAUSE OF ACTION
57) Plaintiff hereby repeats and
realleges each and every allegation contained in
paragraphs 1 through 56 as if fully set forth herein.
58) That the Defendant Kaye knew or
should have known that when governmental employees, attorneys, notaries
or any type of fiduciary agent uses the power of his/her office to help a
client create fraudulent documents, said fraudulent documents can be used
to circumvent a poor spouse's ability to locate a missing parent or
spouse, forcing the abandoned spouse and children into poverty.
Furthermore; Defendant Kaye, who is an attorney, knew or should have
known that using the power of one's position as a fiduciary agent to
swear to create a fraudulent document is a tort and a crime.
AS AND FOR A FIRST SEPARATE AND DISTINCT CAUSE
OF ACTION
59) Plaintiff
hereby repeats and realleges each and every
allegation contained in paragraphs 1 through 58 as if fully set forth
herein.
60) That Defendant Harvey Shapiro owed
Plaintiff the duty of not engaging in fraud with regard to the use of
Defendant Uzamere's proper name and other legal identifiers belonging to
Defendant Uzamere; and that the Defendant Shapiro owed Plaintiff the duty
of not withholding Defendant Uzamere's legal identifiers in a manner that
would cause the New York State Unified Court System to question the
existence of Plaintiff's marriage to Defendant Uzamere and paternity of
the child of the marriage, thereby preventing Plaintiff from availing
herself and her family of receiving benefits associated with being the
wife of Defendant Uzamere and mother of Defendant Uzamere's daughter
Tara.
61) That Defendant Shapiro owed
Plaintiff the duty of publicly disseminating information regarding
Plaintiff's marriage to governmental agencies, to encourage and enforce
the legal use of Defendant Uzamere's proper name and to cause it to be
publicly recognized as Plaintiff's primary marital property, so as to
allow Plaintiff to exercise her legal right to share title of all other
marital assets with Defendant Uzamere and to share the responsibilities
associated with caring for any child with whom Plaintiff and Defendant
Uzamere share consanguinity; and that Defendants owed Plaintiff the duty
of not defrauding Plaintiff by taking advantage of Plaintiff's lack of
knowledge of Title 8, USC, Aliens and Nationality by withholding from Plaintiff's
her role as an unwitting participant in a federal felony.
62) That Defendant Shapiro owed
Plaintiff the duty of protecting Plaintiff's due process rights with
regard to Defendant Uzamere's proper name by not withholding it, and by
legally recognizing it as Plaintiff's primary marital property, and to
not engage in defrauding Plaintiff of her property based on Defendant
Shapiro's desire to conspire to aid and abet Defendant Uzamere's
commission of the crime of marriage for permanent residence.
63) That wholly and solely as a result
of the Defendant Shapiro's nearly thirty (30) years of tortious acts of
fraud, the Plaintiff suffered severe personal injuries and have been
damaged in the amount of $100,000,000.00.
AS AND FOR A SECOND SEPARATE AND DISTINCT
CAUSE OF ACTION
64) Plaintiff
hereby repeats and realleges each and every
allegation contained in paragraphs 1 through 63 as if fully set forth
herein.
65) That Defendant Shapiro failed in
his duty to provide Plaintiff with the proper name of Defendant Uzamere
by facilitating the existence of the fraudulent name and birthday Godwin
E. Uzamere, June 1, 1955.
66) That Defendant Shapiro failed in
his duty to publicly disseminate information regarding Plaintiff's
marriage to appropriate governmental agencies; that Defendant Shapiro
failed in its duty to encourage and enforce the legal use of Defendant
Uzamere's proper name and to cause it to be publicly recognized as
Plaintiff's primary marital property, so as to allow Plaintiff to
exercise her legal right to share title of all other marital assets with
Defendant Uzamere and to share the responsibilities associated with
caring for any child with whom Plaintiff and Defendant Uzamere share
consanguinity.
67) That Defendant Shapiro failed in
protecting Plaintiff's due process rights with regard
to Defendant Uzamere's proper name as being Plaintiff's primary
marital property.
68) That wholly and solely as a result
of the Defendant Shapiro's nearly thirty (30) years of tortious acts of
fraud, the Plaintiff suffered severe personal injuries and have been
damaged in the amount of $100,000,000.00.
AS AND FOR A THIRD SEPARATE AND DISTINCT CAUSE
OF ACTION
69) Plaintiff
hereby repeats and realleges each and every
allegation contained in paragraphs 1 through 68 as if fully set forth
herein.
70) That Plaintiff has suffered
financial deprivation insofar as Plaintiff has never been unable to
obtain government documentation to establish her legal status as
Defendant Uzamere's spouse, and has never been able to establish that
Defendant Uzamere is the biological father of the child of the marriage;
that Plaintiff has been unable to obtain Defendant Ehigie Edobor
Uzamere's identification including, real social security number, real
driver's license, real passport, real address or any other identification
that the Plaintiff can use to take to court to establish her legal status
as the spouse of Defendant Uzamere so as to share title with and obtain
benefits from Defendant Uzamere based on being Defendant's spouse.
AS AND FOR A FOURTH SEPARATE AND DISTINCT
CAUSE OF ACTION
71) Plaintiff
hereby repeats and realleges each and every
allegation contained in paragraphs 1 through 70 as if fully set forth
herein.
72) That the Defendant Shapiro knew or
should have known that when governmental employees, attorneys, notaries
or any type of fiduciary agent uses the power of his/her office to help a
client create fraudulent documents, said fraudulent documents can be used
to circumvent a poor spouse's ability to locate a missing parent or
spouse, forcing the abandoned spouse and children into poverty.
Furthermore; the Defendant Shapiro, who is an attorney, knew or should
have known that using the power of one's position as a fiduciary agent to
swear to create a fraudulent document is a tort and a crime.
AS AND FOR A FIRST SEPARATE AND DISTINCT CAUSE
OF ACTION
73) Plaintiff hereby repeats and
realleges each and every allegation contained in
paragraphs 1 through 72 as if fully set forth herein.
74) That Defendant New York State Notary
Public Bernard J. Rostanski owed Plaintiff the
duty of not engaging in fraud by verifying the authenticity of all
documents that served as legal identifiers of Defendant Uzamere, and that
Defendant Rostanski owed Plaintiff the duty of
not withholding Defendant Uzamere's legal identifiers in a manner that
would cause the New York State Unified Court System to question the
existence of Plaintiff's marriage to Defendant Uzamere and paternity of
the child of the marriage, thereby preventing Plaintiff from availing
herself and her family of receiving benefits associated with being the
wife of Defendant Uzamere and mother of Defendant Uzamere's daughter
Tara.
75) That Defendant Rostanski
owed Plaintiff the duty of verifying documents regarding Defendant Uzamere's
identity so as to ensure that any information that was disseminated to
governmental agencies regarding Plaintiff's marriage to Defendant Uzamere
was authenticated and not fraudulent; and that Defendant Rostanski owed Plaintiff the duty of encouraging and
enforcing the proper legal use of Defendant Uzamere's legal documents
containing his proper name and birthday and to cause it to be publicly
recognized as Plaintiff's primary marital property, so as to allow
Plaintiff to exercise her legal right to share title of all other marital
assets with Defendant Uzamere and to share the responsibilities
associated with caring for any child with whom Plaintiff and Defendant
Uzamere share consanguinity; and that Defendants owed Plaintiff the duty
of not defrauding Plaintiff by taking advantage of Plaintiff's lack of
knowledge of Title 8, USC, Aliens and Nationality by withholding from
Plaintiff's her role as an unwitting participant in a federal felony.
76) That Defendant Rostanski
owed Plaintiff the duty of protecting Plaintiff's due process rights with
regard to Defendant Uzamere's proper name by not withholding it, and by
legally recognizing it as Plaintiff's primary marital property, and to
not engage in defrauding Plaintiff of her property based on Defendant Rostanski's desire to conspire to aid and abet
Defendant Uzamere's commission of the crime of marriage for permanent
residence.
77) That wholly and solely as a result
of the Defendant Rostanski's nearly thirty (30)
years of tortious acts of fraud, the Plaintiff suffered severe personal
injuries and have been damaged in the amount of $100,000,000.00.
AS AND FOR A SECOND SEPARATE AND DISTINCT
CAUSE OF ACTION
78) Plaintiff hereby repeats and
realleges each and every allegation contained in
paragraphs 1 through 77 as if fully set forth herein.
79) That Defendant Rostanski
failed in his duty to provide Plaintiff with the proper name of Defendant
Uzamere by facilitating the existence of the fraudulent name and birthday
Godwin E. Uzamere, June 1, 1955.
80) That Defendant Rostanski
failed in his duty to publicly disseminate information regarding
Plaintiff's marriage to appropriate governmental agencies; that Defendant
Rostanski failed in his duty to encourage and
enforce the legal use of Defendant Uzamere's proper name and to cause it
to be publicly recognized as Plaintiff's primary marital property, so as
to allow Plaintiff to exercise her legal right to share title of all
other marital assets with Defendant Uzamere and to share the
responsibilities associated with caring for any child with whom Plaintiff
and Defendant Uzamere share consanguinity.
81) That Defendant Rostanski
failed in protecting Plaintiff's due process rights with
regard to Defendant Uzamere's proper name as being Plaintiff's
primary marital property.
82) That wholly and solely as a result
of the Defendant Rostanski's nearly thirty (30)
years of tortious acts of fraud, the Plaintiff suffered severe personal
injuries and have been damaged in the amount of $100,000,000.00.
AS AND FOR A THIRD SEPARATE AND DISTINCT CAUSE
OF ACTION
83) Plaintiff hereby repeats and
realleges each and every allegation contained in
paragraphs 1 through 82 as if fully set forth herein.
84) That Plaintiff has suffered
financial deprivation insofar as Plaintiff has never been unable to
obtain government documentation to establish her legal status as
Defendant Uzamere's spouse, and has never been able to establish that
Defendant Uzamere is the biological father of the child of the marriage;
that Plaintiff has been unable to obtain Defendant Ehigie Edobor
Uzamere's identification including, real social security number, real
driver's license, real passport, real address or any other identification
that the Plaintiff can use to take to court to establish her legal status
as the spouse of Defendant Uzamere so as to share title with and obtain
benefits from Defendant Uzamere based on being Defendant's spouse.
AS AND FOR A FOURTH SEPARATE AND DISTINCT
CAUSE OF ACTION
85) Plaintiff hereby repeats and
realleges each and every allegation contained in
paragraphs 1 through 84 as if fully set forth herein.
86) That Defendant Rostanski's
knew or should have known that when governmental employees, attorneys,
notaries or any type of fiduciary agent uses the power of his/her office
to help a client create fraudulent documents, said fraudulent documents
can be used to circumvent a poor spouse's ability to locate a missing
parent or spouse, forcing the abandoned spouse and children into poverty.
Furthermore; Defendant Rostanski, who is a New
York State notary public, knew or should have known that using the power
of one's position as a fiduciary agent to swear to create a fraudulent
document is a tort and a crime.
AS AND FOR A FIRST SEPARATE AND DISTINCT CAUSE
OF ACTION
87) Plaintiff hereby repeats and
realleges each and every allegation contained in
paragraphs 1 through 86 as if fully set forth herein.
88) That Defendant Jack Gladstein owed
Plaintiff the duty of not engaging in fraud with regard to the use of
Defendant Uzamere's proper name and other legal identifiers belonging to
Defendant Uzamere; and that Defendant Gladstein owed Plaintiff the duty
of not withholding Defendant Uzamere's legal identifiers in a manner that
would cause the New York State Unified Court System to question the existence
of Plaintiff's marriage to Defendant Uzamere and paternity of the child
of the marriage, thereby preventing Plaintiff from availing herself and
her family of receiving benefits associated with being the wife of
Defendant Uzamere and mother of Defendant Uzamere's daughter Tara.
89) That Defendant Gladstein owed
Plaintiff the duty of publicly disseminating information regarding
Plaintiff's marriage to governmental agencies, to encourage and enforce
the legal use of Defendant Uzamere's proper name and to cause it to be
publicly recognized as Plaintiff's primary marital property, so as to
allow Plaintiff to exercise her legal right to share title of all other
marital assets with Defendant Uzamere and to share the responsibilities
associated with caring for any child with whom Plaintiff and Defendant
Uzamere share consanguinity; and that Defendant Gladstein owed Plaintiff
the duty of not defrauding Plaintiff by sending Plaintiff correspondence
dated October 1, 2003 containing fictitious information regarding
Defendant client's Ehigie Edobor Uzamere's identity.
90) That Defendant Gladstein owed
Plaintiff the duty of protecting Plaintiff's due process rights with
regard to Defendant Uzamere's proper name by not withholding it, and by
legally recognizing it as Plaintiff's primary marital property, and to
not engage in defrauding Plaintiff of her property based on Defendant Gladstein's desire to conspire to aid and abet
Defendant Uzamere's original commission of the crime of marriage for
permanent residence.
91) That wholly and solely as a result
of the Defendant Gladstein's nearly thirty (30)
years of tortious acts of fraud, the Plaintiff suffered severe personal
injuries and have been damaged in the amount of $100,000,000.00.
AS AND FOR A SECOND SEPARATE AND DISTINCT
CAUSE OF ACTION
92) Plaintiff hereby repeats and
realleges each and every allegation contained in
paragraphs 1 through 91 as if fully set forth herein.
93) That Defendant Gladstein failed in
his duty to provide Plaintiff with the proper name of Defendant Uzamere
by facilitating the existence of the fraudulent name and birthday Godwin
E. Uzamere, June 1, 1955.
94) That Defendant Gladstein failed in
his duty to publicly disseminate information regarding Plaintiff's
marriage to appropriate governmental agencies; that Defendant Gladstein
failed in its duty to encourage and enforce the legal use of Defendant
Uzamere's proper name and to cause it to be publicly recognized as
Plaintiff's primary marital property, so as to allow Plaintiff to
exercise her legal right to share title of all other marital assets with
Defendant Uzamere and to share the responsibilities associated with
caring for any child with whom Plaintiff and Defendant Uzamere share
consanguinity.
95) That Defendant Gladstein failed in
protecting Plaintiff's due process rights with regard
to Defendant Uzamere's proper name as being Plaintiff's primary
marital property.
96) That as a result of the Defendant Gladstein's act of fraud regarding Defendant client
Ehigie Edobor Uzamere, the Plaintiff suffered severe personal injuries
and have been damaged in the amount of $100,000,000.00.
AS AND FOR A THIRD SEPARATE AND DISTINCT CAUSE
OF ACTION
97) Plaintiff hereby repeats and
realleges each and every allegation contained in
paragraphs 1 through 96 as if fully set forth herein.
98) That Plaintiff has suffered
financial deprivation insofar as Plaintiff has never been unable to
obtain government documentation to establish her legal status as
Defendant Uzamere's spouse, and has never been able to establish that
Defendant Uzamere is the biological father of the child of the marriage;
that Plaintiff has been unable to obtain Defendant Ehigie Edobor
Uzamere's identification including, real social security number, real
driver's license, real passport, real address or any other identification
that the Plaintiff can use to take to court to establish her legal status
as the spouse of Defendant Uzamere so as to share title with and obtain
benefits from Defendant Uzamere based on being Defendant's spouse.
AS AND FOR A FOURTH SEPARATE AND DISTINCT
CAUSE OF ACTION
99) Plaintiff hereby repeats and
realleges each and every allegation contained in
paragraphs 1 through 98 as if fully set forth herein.
100) That the Defendant Gladstein knew or
should have known that when governmental employees, attorneys, notaries
or any type of fiduciary agent uses the power of his/her office to help a
client create fraudulent documents, said fraudulent documents can be used
to circumvent a poor spouse's ability to locate a missing parent or
spouse, forcing the abandoned spouse and children into poverty.
Furthermore; the Defendant Gladstein, who is an attorney, knew or should
have known that using the power of one's position as a fiduciary agent to
swear to create a fraudulent document is a tort and a crime.
101) That prior to and at
all times mentioned, Plaintiff Cheryl D. Uzamere is the wife of
Ehigie Edobor Uzamere and that the name Godwin E. Uzamere and the name
Ehigie Edobor Uzamere belong to Defendant Uzamere and that Defendants are
fully aware that the two names belong to the same person.
102) That Plaintiff prays that based on
Plaintiff's discovery of Defendants' act of fraud that this Court tolls
the statute of limitations for fraud as the Plaintiff and her family are
still being victimized; and that tolling the statute for limitations for
fraud based on Plaintiff's recent discovery of evidence of the
Defendants' acts of fraud is in the best interest of justice.
103) By reason of the foregoing, Plaintiff
Cheryl D. Uzamere has been deprived, injured and impaired such that
deprivation and impairment continues now and will continue in the future,
all to this Plaintiff's damage in the sum of $100,000,000.00.
WHEREFORE, Plaintiff Cheryl D. Uzamere respectfully prays that
this Court grants a jury trial, and for this Court to render judgment
against the Defendants in the sum of $100,000,000.00 for the first,
second, third and fourth causes of action herein, together with the costs
and disbursement of this action, and for such other, further, and
additional relief as to this Court may seem just and proper.
Dated: Brooklyn, New York
July 10, 2009
*
Cheryl D. Uzamere
Appearing Pro Se
1209 Loring Avenue
Apt. 6B
Brooklyn, NY 11208
Tel.: (718) 647-1708
Fax: (267) 543-3317
STATE OF NEW YORK, COUNTY OF KINGS
ss:
*
I, Cheryl D.
Uzamere, am the Plaintiff in the within Verified Complaint. I have read
the foregoing complaint and know the contents thereof. The contents are
true to my own knowledge except as to matters therein stated to be
alleged upon information and belief, and as to those matters, I believe
them to be true.
Cheryl D. Uzamere
Appearing Pro Se
1209 Loring Avenue
Apt. 6B
Brooklyn, NY 11208
Tel.: (718) 647-1708
Fax: (267) 543-3317
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