Motion2

PLEASE TAKE NOTICE, that Respondent, sworn to on the 6th day of July

2006, and upon all exhibits & papers annexed hereto, the undersigned (respondent) will move this

Court at a Motion term held before Part A, Room 523 at the New York County (Civil) Courthouse

located at 111 Centre Street, on the 13th day of July, 2006 at 9:30 A.M., or as soon thereafter as

practicable, for an order:

5. Granting MOTION TO COMPEL petitioner's REPLY to respondent's ANSWER & AFFIDAVIT or

AMENDED ANSWER & AFFIDAVIT or or to stipulate to said facts for joint MOTION FOR SUMMARY

JUDGMENT.

6. Adding tenth Affirmative Defense re: violations of USA PATRIOT Act and 18 U.S.C. § 2331 domestic terrorism means activities that (A) involve acts dangerous to human life that are a violation of the criminal laws of the U.S. or of any state, that (B) appear to be intended (i) to intimidate or coerce a civilian population, (ii) to influence the policy of a government by intimidation or coercion, or (iii) to affect the conduct of a government by mass destruction, assassination, or kidnapping, and (C) occur primarily within the territorial jurisdiction of the U.S.

and New York State Anti-Terrorism Laws.
cplr 2214(b) Time for service of notice and affidavits. A notice of motion and supporting affidavits shall be served at least eight days before the time at which the motion is noticed to be heard. Answering affidavits shall be served at least two days before such time. Answering affidavits shall be served at least seven days before such time if a notice of motion served at least twelve days before such time so demands; whereupon any reply affidavits shall be served at least one day before such time.

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