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NEW
YORK STATE SUPREME COURT
COURT OF NEW
YORK
Cheryl D. Uzamere Index
No. 403205/2010
*
Plaintiff, NOTICE
OF MOTION FOR LEAVE
TO RENEW
PLAINTIFF'S MOTIONS
-
against - FOR
DEFAULT JUDGMENT, SUMMARY
JUDGMENT, TO
DISMISS DEFENDANT'S
Daily News, LP and Scott Shifrel LATEST
MOTION AND TO HOLD IN
ABEYANCE PENDING
DEFENDANT'S
Defendants. AND
ATTORNEY'S ARREST
Plaintiff Cheryl D. Uzamere, being duly sworn, states the following under
the penalties of perjury:
1) I assert that my Notice of Motion
to Renew and accompanying Affidavit in Support are based upon my recent
discoveries: 1) that I was kidnapped, and that Defendant Scott Shifrel, by arbitrarily, maliciously, capriciously
and in a biased manner assisting court personnel under the care and
control of the Honorable Michael Gerstein, the Honorable Jeffrey S.
Sunshine and the Honorable Arthur M. Schack to illegally broadcast
nonpublic information regarding my lawsuits, tacitly admitted to
committing conspiracy in the second degree with regard to kidnapping in
the first degree; 2) that there is a continuing pattern of judicial
misconduct and bias in favor or the Defendants with regard to their
defamation of me as an anti-Semitic wacko, and with regard to Defendants'
intentional misrepresentation of my husband as Godwin Uzamere even though
two justices of a court of competent jurisdiction decided that Senator
Ehigie E. Uzamere was my husband; 3) that Defendants' attorney Anne B.
Carroll violated 22 NYCRR
130-1.1 and the New York
Lawyer's Code of Responsibility DR 1-102 with regard to asserting
material facts that are not supported by law by intentionally invoking
the legal doctrines res judicata and collateral estoppel although I filed
no prior lawsuit against the Defendants; 4) that Defendants' attorney
Anne B. Carroll committed fraud upon the court by violating New York
State Penal Law Section 105.05, conspiracy in the fifth degree and New York
State Penal Law 115.00, criminal facilitation in the fourth degree by holding out that the process
was properly mailed when a) the first USPS delivery
notice/reminder/receipt dated January 24, 2011 bore 07102, a Newark, New
Jersey zip code, b) the U.S. Postal Service's online Track and Confirm
web page does not recognize Article No. 7009 1080 0001 3780 9641 as having
been mailed, and c) I received the second USPS delivery
notice/reminder/receipt bearing the zip code 10458 that was used to
reference the first USPS delivery notice/reminder/receipt that bore the
zip code 07102; 5) that anti-Semitism is a violation of halachic/Jewish
religious law, not secular law, so that Defendants' libelous accusation
that I am an anti-Semite is a violation of my New York State
Constitutional right to freedom of worship; 6) that Defendants violated New York
State Civil Rights Law, Article Five, Section Fifty, Right of Privacy by using, for the purposes of
trade, my name, my picture, nonpublic information regarding my mental illness,
nonpublic information regarding the hospital that treated me; nonpublic
information regarding the symptoms of my mental illness; nonpublic
information with regard to Defendants' defamatory, derogatory portrayal
of me as a wacko; non-public information regarding their fraudulent
allegations regarding my being anti-Semitic; nonpublic information
regarding my marriage and divorce, including nonpublic information
regarding my ex-husband's criminal use of his fraudulent
counter-affidavit of any living person without having first obtained the
written consent me or my ex-husband; 7) that Defendant Daily News'
registered agent, the Prentice-Hall Corporation System Inc., a company
located and incorporated in the State of Delaware, accepts service of
process by mail; 7) that according to the Delaware Supreme Court's
attorney registration department (302-739-4155), Defendants' attorney
Anne B. Carroll is not licensed to practice law in Delaware, so that she
is not in a legal position to question Defendant Daily News' acceptance
of process by certified mail in Delaware; 8) that I filed a petition with
the New York State Commission on Judicial Conduct against the Honorable
Michael Gerstein, the Honorable Jeffrey S. Sunshine and the Honorable
Arthur M. Schack for violating 22 NYCRR
100.3(B)(8)(11) by making
or causing to be made public comments regarding my lawsuits and for
illegally disclosing or causing to be disclosed my nonpublic information
to the Defendants that they acquired during their adjudication of my
lawsuits Docket No. 2009KN087992, Index No. 26332/2007 and Index No.
18012/2009; 9) that I filed a petition with the New York State Grievance
Committee against my criminal attorney Tim Gumkowski
for illegally disclosing symptoms of my mental illness to the Defendants
based on my belief that only he and those court personnel who were
present while I was in Kings County Criminal Court's holding area could
have known; and that if this Court grants leave for me to present the
aforementioned new facts, this Court's decision will greatly differ from
any decision that this Court would have rendered had it based its
decision on Defendants' fraudulent statements as presented in the motions
that the Defendants offered the Honorable Anthony L. Parga, Nassau County
Supreme Court.
2) I assert that my failure to
present the aforementioned facts is based on various events that took place
after Defendants defamed me and publicly disclosed my nonpublic
information that was originally acquired in a judicial capacity but was
thereafter illegally acquired by the Defendants and used for purposes
unrelated to the duties of the judges who adjudicated my lawsuits; and
that Defendants and their attorney Anne B. Carroll committed crimes that
I did not know until now were crimes at the time that Defendants
committed them.
BACKGROUND FACTS
3) While
it is my intention to obey Civil Practice Law and Rules 2221(3) with
regard to its requirement to present new information to this honorable
Court, I respectfully request this Court's merciful indulgence to allow
me to invoke the continuing violations doctrine by establishing a link
between Defendant's current criminal course of conduct and the
Defendants' present criminal course of conduct by referencing the
following past events:
a) I assert that my ex-husband's
attorney, Osato Eugene Uzamere presented a fraudulent affirmation and
counter-affidavit that falsely held that I am married to Godwin Uzamere
(see Exhibit A);
b) I assert that I received
correspondence from the U.S. Citizenship and Immigration Services that
recognizes that Senator Ehigie Edobor Uzamere was my husband (see Exhibit
B);
c) I assert that the U.S. Citizenship and Immigration
Service (formerly U.S. Department of Justice Immigration and
Naturalization Service) revoked my ex-husband's fraudulently obtained IR2
benefits that my ex-husband received under his proper name and birthday
as Ehigie E. Uzamere, date of birth: December 31, 1960, unmarried, under
21 years of age, because he applied for IR1 benefits under the fictitious
name and birthday Godwin Uzamere, date of birth: June 1, 1955, married to
me and over 21 years of age (see Exhibit C);
d) I assert that the Honorable Jeffrey S. Sunshine and
the Honorable Matthew D'Emic adjudged that
Senator Ehigie Edobor Uzamere was my husband (see Exhibit
D and Exhibit
E);
e) I assert that on or around October 28, 2009, attorneys
Allen E. Kaye, Harvey Shapiro and Jack Gladstein submitted affirmations
to the Kings County Supreme Court that fraudulently hold that I am
married to Godwin Uzamere (see Exhibit F).
f) I assert that on November 3, 2009, the Honorable
Michael Gerstein declared that I was mentally unfit, and at his behest, I
was kidnapped and taken, first to Elmhurst Hospital, and then to Rose M.
Singer Center (Rikers Island), where I was held for thirty-three (33)
days, and then transferred to Kingsboro
Psychiatric Center, where I was held for parts of five (5) months (see Exhibit
G).
g) I assert that eight (8) days after the aforementioned
attorneys submitted their fraudulent affirmations to the Kings County
Supreme Court, that on November 5, 2009, Defendants published a newspaper
article fraudulently holding that Godwin Uzamere is my husband, that I am
an anti-Semitic wacko, and that I am mentally unfit (see Exhibit
H).
NEW ASSERTIONS/ALLEGATIONS
4) I
assert that on November 30, 2009, less than a month after the Daily News
libeled me an anti-Semitic wacko, I was discharged from receiving FEGS,
Inc.'s government-funded services for committing the Jewish religious
crime of anti-Semitism based on Dr. Forster's statement given client's
history of making anti-Semitic remarks, treatment at an FEGS facility is
inappropriate for her (see Exhibit I).
5) I assert that in February 2010,
during my last week of my first hospitalization with Kingsboro
Psychiatric Center as an inpatient, my social worker, Laurie Velcimé informed me that except for Brookdale Medical
Center's outpatient psychiatric department, all the not-for-profit
outpatient mental health rehabilitative service agencies with which Ms. Velcimé filed a request for services on my behalf
turned down her request for me to receive outpatient services.
6) I further assert that while I was
an inpatient with Kingsboro Psychiatric Center,
I informed its staff that based on my lawsuit against the three (3)
Jewish attorneys who facilitated my ex-husband's commission of
immigration fraud and identity fraud, and based on my fear of backlash from
members of the Jewish community, I would only accept therapy from
therapists who were not Jewish.
7) I assert that during my last week
of my second hospitalization with Kingsboro
Psychiatric Center as an inpatient, my social worker, Laurie Velcim頩nformed
me that nearly all the not-for-profit outpatient mental health agencies
with which Ms. Velcim頦iled
a request on my behalf turned down Ms. Velcim
request to provide me with outpatient mental health services.
8)
I assert that the not-for-profit outpatient mental health rehabilitative
service agencies that social worker Laurie Velcim頣ontacted
include but are not limited to: 1) Interfaith
Medical Center CDT; 2) Saint Vincent Catholic Medical Center CDT and 3)
New York Psychotherapy and Counseling Center.
9) I assert that during my second visit as an
inpatient with Kingsboro Psychiatric Center, I
informed its staff that based on my lawsuit against three (3) Jewish
attorneys who facilitated my ex-husband's commission of immigration fraud
and identity fraud, and based on my fear of backlash from members of the
Jewish community, I would only accept therapy from therapists who were
not Jewish.
10) I assert that Kingsboro
Psychiatric Center's Ward 12 staff honored my request by providing me
with a psychiatric treatment team that contained no Jews (see Exhibit
J).
11) I assert that on August 3, 2010,
while at Brookdale Pharmacy, my wallet was stolen by a customer, and that
I called the police. When the police came, they viewed the customer who
had stolen my wallet on the pharmacy's camera; however, on the word of
the pharmacy's owner, who is Jewish, the police refused to take my
complaint. The lawsuit I filed against the City of New York and the New
York City Police Department that was first filed with the New York City
Comptroller's Office as Claim No. 2010PI028483 is attached as Exhibit
K.
12) I assert that in September 2010, Kingsboro Psychiatric Center's Intensive Management
Program's caseworker Bridget Davis arranged for me to meet with Flatlands
Guidance Center and Open Door Psychosocial Club; and that I was made to
believe that Kingsboro Psychiatric Center would
continue to accede to my request to ensure that the only individuals who would
provide me with therapy were non-Jews who were culturally sensitive to my
needs as a crime victim.
13) I assert that on three (3)
occasions, I was misled into divulging sensitive information about my
legal situation to Catholic Charities' employees Monica Doe, Dr. Sterling
and Dr. Partyka, all of whom attempted to hide
the fact that they are Jewish from me.
14) I assert that while I was an
outpatient with after Flatlands Guidance Center, an unidentified Jewish
male employee informed fellow employees that I am an anti-Semite; and
that after weeks of issues with transference, and continued fear and
sadness at being identified as anti-Semitic, I left.
15) I assert that in November 2010, and
upon receipt of FEGS's discharge summary that libeled me as an
anti-Semite, I immediately commenced preparing her lawsuit against FEGS.
My lawsuit against FEGS, Index No. 115748/2011 is attached as Exhibit
L.
16) I assert that I filed a lawsuit
against the State with the New York State Court of Claims on December 6,
2010 with regard to what I believe is New York
State's condonation of FEGS' discharging me for religious reasons. My
lawsuit against the State of New York is attached as Exhibit
M.
17) I assert that after losing my
lawsuit Index No. 18012-2009 in which the Honorable Arthur M. Schack
accepted attorneys Allen E. Kaye's, Harvey Shapiro's and Jack Gladstein's affirmations that fraudulently hold that
Godwin Uzamere is my husband, I filed my appeal to what I believe to be
Justice Schack's biased decision. My brief is attached as Exhibit
N.
18) I assert that I filed a complaint
with the New York State Commission on Judicial Conduct with regard the
Honorable Michael Gerstein's, the Honorable Jeffrey S. Sunshine's and the
Honorable Arthur M. Schack's violation of 22 NYCRR
100.3(B)(8)(11)'s statutes
prohibiting judges and court personnel from publicly commenting on
pending and impending cases, and from disclosing nonpublic information
that the aforementioned judges obtained in their capacity as judges. The
petition is attached as Exhibit O.
19) I assert that on January 24, 2011
and January 26, 2011 I received certified mail receipts from the U.S.
Postal Service, the identity of the sender unknown; one that appeared to
have been illegally mailed from zip code 07102, Newark New Jersey, but
which article number 7009 1080 0001 3780 9641 does not register as having
ever been mailed at the U.S. Postal Service's Track and Confirm web page;
that I received a second USPS delivery notice/reminder/receipt bearing
the zip code 10458 but not bearing an article number; and that according
to an employee with the U.S. Postal Service's New Lots' branch, the
delivery notice/reminder/receipt bearing the zip code 10458 referenced
the delivery notice/reminder/receipt that bore the article number 7009
1080 0001 3780 9641 and the zip code 07102; (see Exhibit
P).
SPECIFIC REASONS FOR RENEWAL
20) That I submit the within Affidavit
to renew my motions for default judgment and summary judgment based on
Defendant Scott Shifrel's commission of the
following:
21) I assert that Defendant Daily News'
registered agent, the Prentice-Hall Corporation System Inc., a company
located and incorporated in the State of Delaware, accepts service of
process by mail, and that said corporation can be contacted at (302) 636-5400
to confirm my assertion; and that according to the Delaware Supreme
Court's attorney registration department (302-739-4155), Defendants'
attorney Anne B. Carroll is not licensed to practice law in Delaware, so
that she is not in a legal position to challenge Defendant Daily News'
acceptance of process by certified mail in Delaware (see Exhibit
Q).
22) I assert that based on the exact
definition of conspiracy in the second degree, Defendant the Daily News,
by and through Defendant Scott Shifrel, with
intent that the crimes of coercion in the first degree and kidnapping in
the first degree be performed, agreed with one or more persons to engage
in or cause the performance of such conduct; and that I describe the
Defendants' orchestration of my arrest as a kidnapping because Defendant
Scott Shifrel overtly admitted in paragraph
seven (7), line three (3) of Defendants' newspaper to illegally obtaining
information about my lawsuits from one courthouse source, in violation of
22 NYCRR
100.3(B)(8)(11) that
prohibits judges and court personnel from commenting on pending and
impending cases, and from publicly disclosing nonpublic information that
was acquired in a judicial capacity; that the reasons for which Defendant
Daily News, by and through Scott Shifrel,
judges Michael Gerstein, Jeffrey S. Sunshine, Arthur M. Schack and
attorneys Allen E. Kaye, Harvey Shapiro and Jack Gladstein orchestrated
my arrested are not only biased, but are untrue, and therefore tainted;
and that since the illegally disclosed information with regard to my
cases Docket No. 2009KN087992, Index 26332/2007 and Index 18012/2009 is
tainted, and therefore not usable in an unbiased court of law, the
arrest, being based on the tainted allegations are fruit of the poison
tree, so that my arrest was in actuality an act of coercion in the first
degree and an act of kidnapping in the first degree.
23) I assert that Defendants committed
criminal facilitation in the fourth degree with regard to Defendants
assisting Senator Ehigie Edobor Uzamere, Osato Uzamere, Allen E. Kaye,
Harvey Shapiro and Jack Gladstein to commit New York State Penal Law
Section 210.15, perjury in the first degree by holding out that my
husband is Godwin Uzamere even though a court of competent jurisdiction
decided that Senator Ehigie Edobor Uzamere was my husband.
24) I assert that Defendants committed
criminal facilitation in the fourth degree regarding Defendants assist
Senator Ehigie Edobor Uzamere, Allen E. Kaye, Harvey Shapiro and Jack
Gladstein to commit New York
State Penal Law Section 135.65, coercion in the first degree;
25) I assert that Defendants committed
criminal facilitation in the fourth degree with regard to Defendants'
assisting Judge Jeffrey S. Sunshine's and Judge Arthur M. Schack's to
publicly hold out as true and correct the fraudulent counter-affidavit
and affirmations of my ex-husband Senator Ehigie Edobor Uzamere and his
attorneys Allen E. Kaye, Harvey Shapiro and Jack Gladstein with regard to
my ex-husband's identity; and that Defendants assisted Judge Michael
Gerstein, Justice Jeffrey S. Sunshine, Justice Arthur M. Schack, and
attorneys Allen E. Kaye, Harvey Shapiro and Jack Gladstein by illegally
disclosing other nonpublic information associated with my criminal action
Docket No. 2009KN087992, my action for divorce Index No. 26332-2007 and
my action for fraud Index No. 18012-2009 for purpose unrelated to
judicial duties.
26) That I submit the within Affidavit
to renew my motions based on attorney Anne B. Carroll's violation of 22 NYCRR
130-1.1 with regard
to her fraudulent request to this Court to invoke res judicata regarding
lawsuits that I filed with the U.S. District Courts for the Eastern and
Southern Districts that were dismissed due to lack of subject matter
jurisdiction, as said dismissals were based on the courts' belief that my
lawsuits were really attempts to relitigate my divorce and that the
federal courts' dismissals were based on the Younger abstention that
prohibits federal courts from adjudicating matters that are relegated to
the states; and that in attorney Anne B. Carroll's motion, she knowingly,
fraudulently and maliciously attempts to present her legal strategy that
relies on her mistaken, arrogant belief that I will not figure out that
res judicata does not apply to the present action because the Defendants
were never parties to any previous action that I filed in any court on
the planet Earth.
27) I allege that Anne B. Carroll
arranged for the mailing of Article 7009 1080 0001 3780 9641 that on face
value, appears to have been improperly mailed from 07102, Newark, New
Jersey, but which article number is not recognized by the U.S. Postal
Service's online Track and Confirm web page; and that further to this,
that Defendants' attorney Anne B. Carroll has attempted previous
fraudulent stunts that are designed to: 1) trick or confuse me; 2)
circumvent New York State Law regarding proper service of process; 3)
circumvent the New York Lawyer's Code of Professional Conduct with regard
to statutes that prohibit attorneys from engaging in fraud, deceit and
misrepresentation; 4) invoke this Court's anti-black racism and
anti-mentally ill bigotry so as to embolden this Court trier of fact to
violate 22 NYCRR
100.3 with regard
to judicial conduct.
28) I assert that because of the
Defendants' illegal disclosure of my lawsuits and disclosure of nonpublic
information that was acquired in a judicial capacity, I was forced to
file a petition against the Honorable Michael Gerstein, the Honorable
Jeffrey S. Sunshine and the Honorable Arthur M. Schack with the New York
State Commission on Judicial Conduct because the aforesaid judges'
illegally commented on, or allowed court personnel to comment on my
lawsuits Docket No. 2009KN087992, Index No. 26332/2007 and Index No.
18012/2009, and because the aforesaid judges illegally disclosed or
allowed court personnel to illegally disclose my nonpublic information to
the Defendants in violation of 22 NYCRR
100.3(B)(8)(11) , that says
that a judge shall not make any public comment about a pending or
impending proceeding in any court within the United States or its
territories. The judge shall require similar abstention on the part of
court personnel subject to the judge's direction and control... and that
a judge shall not disclose or use, for any purpose unrelated to judicial
duties, nonpublic information acquired in a judicial capacity.
29) I assert that Defendants' attorney
Anne B. Carroll's act of deceit with regard to the arrogance with which
she improperly served process of Article No. 7009 1080 0001 3780 9641 is
no different than the arrogance with which she attempted previous stunts
on behalf of the Defendants: 1) her first attempt to trick me into
believing that my lawsuit against the Defendants was transferred to the
Kings County Supreme Court by arranging with the Honorable Jeffrey S.
Sunshine and Justice Sunshine's wife, the Honorable Nancy Teigtmeier of the Kings County Clerk's Office to mail
me a document entitled Kings County Clerk, Equity Window 9 that feigned
the color of authority in order to trick me e to go to the Kings County
Clerk's Office to add a missing index number when my lawsuit was still in
Nassau County in order for Justice Sunshine to gain access to my lawsuit
against the Defendants and summarily dismiss it; and, 2) attempted to
trick me into believing that Nassau County Supreme Court and the Nassau
County Clerk's Office and the legal right to physically remove all the
motion papers that I properly served on them, when, in fact they violated
CPLR 2001, 2101(f) and 2102(c) , which allow for errors that
do not prejudice the opposing party, and which the clerk of court is
required to accept (see Exhibit R).
30) I assert that attorney Anne B.
Carroll again violated 22 NYCRR 130-1.1 by the New York State
Constitution's freedom to worship clause it its reference to me as
anti-Semitic. Anti-Semitism is a violation of halachic/Jewish religious
law. According to the Exhibit Daat Emet, Gentiles in Halacha, the prohibition to hate
only applies to Jews. One may hate a gentile; that one make take revenge
against or hold a grudge towards Gentiles; likewise the commandment love
your neighbor applies only to Jews, not to Gentiles; that anyone who
hates a Jew in his heart transgresses a negative commandment; that also,
anyone who hold a grudge against a Jew transgresses a negative
commandment; and that it is a commandment for each and every person to
love each and every Jew as he loves himself. Such a hateful religious
tenet, that requires all non-Jews to love every single Jew, even if Jews
hate non-Jews, is the very antithesis of justice. This tenet fosters
racism as it requires non-Jews to love Jews simply because they are Jews,
instead of expressing one's like or dislike of a person based on, as
Martin Luther King advocated, the content of their character. Attorney
Anne B. Carroll's attempt to hide the Defendants' obvious criminal
conduct by demonizing my constitutionally-protected right to privacy
(including private thought); my right to freedom of thought and my right
to freely express my hatred of attorneys Allen E. Kaye, Harvey Shapiro
and Jack Gladstein for violating my rights and my family's rights not
because they are Jews, not because they are Jews, but because they are
wicked.
31) I assert that attorney Anne B.
Carroll's violated 22 NYCRR
130-1.1 by
frivolously holding herself out as having psychic abilities. According to
the Israel Central Bureau of Statistics, as of 2010, there are 13,421,000
Jews worldwide. Is Anne Carroll prepared to present this Court with proof
of her belief that she has psychic abilities, is able
to tell that I hate all 13,421,000 Jews on the planet Earth and
that I have never befriended even one person who is Jewish? I answer in
the negative based on 1) Ms. Carroll's inability to form a legal strategy
that would thwart my ability to discover her fraudulent attempt to
require this Court's use of res judicata for my federal lawsuits in which
the Defendants were not parties to the action. If Ms. Carroll's psychic
prowess was useless in helping her form a legal strategy based on what I
was thinking when she prepared her cross-motions, it stands to reason
that this Court must not view her psychic skills as sufficiently strong
enough to tell what I feel about all 13,421,000 Jews on the planet Earth,
nor does Ms. Carroll possess the psychic ability to tell if I had Jewish
friends at the time that the Defendants published the libelous newspaper
article about me.
32) That based on Defendant Scott Shifrel's flagrant commission of various crimes
against me, and based on what I believe to be logical, I allege that
Defendant Scott Shifrel accepted bribes from my
ex-husband, Senator Ehigie Edobor Uzamere, to use the Defendants to
criminally facilitate Senator Uzamere's commission of identity fraud and
perjury in the same manner that he and attorneys Allen E. Kaye, Harvey
Shapiro and Jack Gladstein criminally facilitated the use of the
fictitious name Godwin Uzamere to hide his identity and his commission of
immigration fraud and identity fraud from the Nigerian public, where he
sits as a senator, and where he is preparing to run as senator again.
While my allegation with regard to Defendant
Scott Shifrel's acceptance of bribes is just an
allegation, the level of wickedness associated with Defendants' crimes
should, by the preponderance of the evidence show this Court this the
Defendants did not commit the aforementioned crimes for fun, or for free.
They perpetrated the aforementioned crimes for
financial gain, and used their false accusations as published in
Defendants' newspaper as a rationalization to gorge themselves on my
ex-husband's money. I strongly allege that what motivated the Defendants
is greed.
33) I respectfully remind this Court
that based on various instances of judicial corruption (including what I
allege to be the acceptance of bribes; judges' use of the Defendants to
illegally disclose my nonpublic information that was obtained during
judges' adjudication of my lawsuits in violate of 22 NYCRR
100.3(B)(8)(11) ),
religiously-oriented racism and discrimination of me based on my
government-protected status as mentally disabled as rationalizations to
assuage their guilty consciences for having accepted bribes from my
ex-husband while my family and I suffer in poverty; I have no other
choice but to forward this lawsuit to Robert S. Mueller, Director of the
Federal Bureau of Investigation and to President Obama, as I am terrified
that I my complaint will be forwarded to another corrupt judge.
34) I respectfully assert before this
Court that based on my limited knowledge of the law, in situations where
fact patterns straddle both criminal law and civil law, it is civil cases
that are ancillary; and pending Defendant Scott Shifrel's
arrest and possible conviction, I respectfully pray that this Court
facilitates Defendant Scott Shifrel's and Anne
B. Carroll arrest for conspiracy/criminal facilitation (to commit
perjury); conspiracy/criminal facilitation (of coercion) and
conspiracy/criminal facilitation (of kidnapping). While I am not an
attorney, my requests to the honorable Court are based on the laws I have
already read (and quoted in my motion) and my ability to find relevant
laws that I do not presently know on the internet. Lastly, I apologize
for presenting this inartfully drawn motion to this honorable Court.
WHEREFORE, Plaintiff Cheryl D. Uzamere respectfully prays that
this Court do the following: 1) that if Defendants insist on holding out
that I was properly served, that this Court dismisses Defendants' motion
as improperly served; 2) to find that Defendant Daily News was properly
served; 3) to facilitate the arrest of Defendant Scott Shifrel and Anne B. Carroll based on their
conspiracy/criminal facilitation of perjury in the first degree, coercion
in the first degree and kidnapping in the first degree; 4) sanction
Defendant's attorney Anne B. Carroll for violation of the New York
Lawyer's Code of Responsibility Responsibility
with regard to her commission of fraud and her violation of 22 NYCRR
130-1.1 that allows
the court, as appropriate, to impose financial sanctions against an
attorney for asserting material factual statements that are false; 5) to
grant leave for Plaintiff to correctly effect service of process on
Defendant Scott Shifrel pursuant to CPLR 308; 6) to grant leave for
Plaintiff to proceed as a poor person to refile her papers against Scott Shifrel; 7) to substitute service of process on
Defendant Scott Shifrel to prevent him from
absenting himself from receipt of process, and if Defendant Scott Shifrel objects to substituted service, to require
him to pay for personal service; 8) to find Defendant Daily News in
default for failure to interpose an answer; 9) for this honorable Court
to require Defendants to make a full public retraction of their
defamatory, criminal and cruel statements, and to render judgment against
Defendant Daily News in the sum of $10,000.000.00.
Dated: New York, New York
February
10, 2011
*
To: Anne B. Carroll
Deputy Vice President and General Counsel
Daily News, LP
450 W. 33rd Street 1209 Loring Avenue
New York, NY 10001
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