Kenmore Housing Corp

CIVIL COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK : HOUSING PART
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KENMORE ASSOCIATES, L.P. & : Index # 071507/07 & HOUSING & SERVICES INC. & Norris : Index # 52851/06
McLaughlin & Marcus : PRE-ANSWER
Petitioner, : OMNIBUS
v. : MOTION TO
: DISMISS WITH
: PREJUDICE
: JURY DEMAND
, :
:
Respondent. :
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PLEASE TAKE NOTICE, that upon the annexed Affidavit of ,

Respondent, sworn to on the 13th day of June, 2007, and upon all exhibits &

papers annexed hereto, the undersigned (respondent) will move this Court at a

Motion term held before Civil Clerk Room 225 at the New York County (Civil)

Courthouse located at 111 Centre Street, on the 5th day of July, 2007 at 9:30 A.M. ,

for an order: (1) That SPECIAL APPEARANCE be granted to challenge lack of

PERSONAL JURISDICTION Book Review, New York Civil Practice, 112 U.Pa.L.Rev. 1222, 1230 (1963)
(2) That JURY TRIAL be granted for instant motion (CPLR §2218).

(3) That instant case be dismissed due to IDENTICAL CAUSE OF ACTION (Res

Judicata) in prior (and current) case before Honorable Jean Schneider

(index #52851/06(see att.)).

(4) That $1,000,000.00 fine and/or punitive and compensatory damages be levied

against plaintiff's for reasons of VEXATIOUS & FRIVOLOUS LITIGATION, ABUSE

OF PROCESS, JUDGE/FORUM SHOPPING and BARRATRY.

(5) That "House Counsel" of RICO petitioner, Dean M. Roberts esq. and Mia Falls

esq., be immediately DISBARRED for same as well as MALFEASANCE,

INCOMPETENCE and lack of DUE DILIGENCE (ABA Model Rules of Professional

Conduct).

(6) That #52851/06 (actual) case be dismissed for violating FEDERAL FAIR DEBT

COLLECTIONS PRACTICES ACT (15 U.S.C. § 1692).

(7) That #52851/06 (actual) case be dismissed for violating FEDERAL CONSENT

JUDGMENT ( Williams v. New York City Hous. Auth., 975 F. Supp. 317, 319 (S.D.N.Y. 1997) (hereinafter the "Williams Consent Judgment').

(8) That #52851/06 case be dismissed for "landlord" SECTION 8 FRAUD

(additional Predicate RICO Felonies) and pending INDEPENDENT SPECIAL

PROSECUTOR motion be expanded to review same (see att.).

(9) That violations of FEDERAL FALSE CLAIMS ACT (31 U.S.C. § 3729) be added

as additional defense in actual case.

(10) That pending discovery motion expand to include Request for Information on

RICO's Section 8 and other FRAUDS for Due Process Defense if not moot.

(11) That Special Federal Grand Jury be impaneled to examine and INDICT

plaintiff and others for RICO ACTs and POLITICAL CORRUPTION (see att.).

(12) That plaintiff's be Barred from initiating further legal actions as VEXATIOUS

LITIGANTS.

(13) That First Counterclaim in actual case be raised to $100,000,000.

(14) That RICO lacks Standing and Jurisdiction (Federal(see Att.)).
Under CPLR 2214 (b) 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;

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

dismissing petitioner's Notice of Petition & Petition in its entirety, granting

respondent's Motion and for all such and further relief that this Court may deem just

and appropriate.
________________________
, Respondent pro se
145 east 23rd street
Petitioners counsel: New York, NY, 10010
Norris McLaughlin & Marcus, P.A.
875 Third Avenue Fl 18
New York, NY 10022

Dated June 12, 2007