Dean M Roberts

Exhibit is respondent's ANSWER & AFFIDAVIT and/or AMENDED ANSWER

&AFFIDAVIT included in court record and duly and properly served upon plaintiff's

counsel. Additionally for MOTION TO RECUSE, respondent is informed and

believes, and upon such information and belief, alleges that plaintiff's counsel

knew and/or should have known and/or had prior knowledge and affirmatively and

unlawfully assisted Crimes, Unlawful Conspiracies, Coverups and Corruption of

various Government Officials in an ongoing manor. As "House Counsel" for

petitioner (RICO) for ten years, petitioner's counsel engaged in Obstruction of

Justice allowing/encouraging/assisting/supporting petitioner in avoiding/quashing

lawful investigations, performing conspiracies and coverups, money laundering,

tax evasion,and violating tenants and others Civil, Constitutional, and other rights

and protections under Law, Precedent, Regulations, Rules and or Charter, Federal

State and City. For precedent see barring of Bruce Cutler as "House Counsel" for

Gambino Crime Family in 1991 case United States v John Gotti.

WHEREFORE, respondent prays for the granting of an Order from the Court

dismissing petitioner's Petition in its entirety, with prejudice, and for all such and

further relief that this Court may deem just and appropriate.