Omnibus Motion 1

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

sworn to on the 23rd day of June, 2006, and upon all exhibits & papers annexed hereto, the

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

New York County (Civil) Courthouse located at 111 Centre Street, on the 29th day of June, 2006 at

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

1. Granting SPECIAL APPEARANCE status for jurisdictional argument.

2. MOTION TO DISMISS WITH PREJUDICE for improper jurisdiction.

3. MOTION TO DISMISS WITH PREJUDICE for improper standing.

4. MOTION FOR CHANGE OF VENUE to United States District Court if previous motion(s) is/are not granted.

5. MOTION TO RECUSE OR DISQUALIFY OR BARR plaintiff's counsel for reasons of conflict of

interest and/or appearance of conflict of interest (see Bruce Cutler (United States v Gotti)).

6. MOTION TO ALLOW DISCOVERY, if not moot, to allow proper defense (see Smilow v Ulrich).

7. MOTION TO APPOINT INDEPENDENT SPECIAL PROSECUTOR to investigate crimes alleged

in attached AFFIDAVIT as well as respondent's ANSWER & AFFIDAVIT and/or AMENDED ANSWER & AFFIDAVIT.

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