Motion

PLEASE TAKE NOTICE, that upon the annexed Affidavit of Respondent,

sworn to on the 10th day of August, 2006, and upon all exhibits & papers annexed hereto, the

undersigned (respondent) will move this Court at a Motion term held before Part A, at the

New York County (Civil) Courthouse located at 111 Centre Street, on the 21st day of August, 2006 at

9:30 A.M., or as soon thereafter as practicable, for an order:

1. DISMISSING PETITION for WILLFUL DISOBEDIENCE & ATTORNEY MALFEASANCE &

MISCONDUCT & PERJURY.

2. ADDING ELEVENTH AFFIRMATIVE DEFENSE : As PREDICATE FELONIES (RICO) petitioners

ongoing violations of § 411 & § 412 Illegal Immigration Reform and Control Act and § 274

Immigration and Nationality Act, Executive Order #12989, 61 Fed. Reg. 6091 (Feb. 15, 1996), 8

U.S.C. § 1324, Federal Acquisition Regulation 9.406-2, 46 U.S.C. § 8704, etc.; and injunctive relief.

and all such and further relief that this court may deem just and proper.