CIVIL COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK : HOUSING PART
----------------------------------------------------------X
KENMORE ASSOCIATES, L.P. & : Index # 071507/2007 &
HOUSING & SERVICES INC. & : Index # 52851/2006
Norris McLaughlin & Marcus :
Petitioner, : AFFIDAVIT IN SUPPORT
v. : OF MOTION TO DISMISS
: PRE-ANSWER
, :
:
Respondent. :
---------------------------------------------------------X
(State of New York)
(County of New York)
SS: I,____________________, ( ), Respondent in this Action, being duly
sworn, hereby depose and state: That plaintiff's "Collateral Attack" on respondent's
FIFTH AMENDMENT and Due Process Civil Rights is a Strategic Lawsuit Against
Public Participation (SLAPP). The RICO's CRIMINAL BARRATRY is retaliation for
respondent's attempt to obtain REMEDY & SEVENTH AMENDMENT rights. Petitioner's
UNLAWFUL OBSTRUCTION of JUSTICE of the Honorable Jean Schneider's LAWFUL
AUTHORITY is grounds in and of itself for DISBARMENT and INDICTMENT. Notice of
Petition & Petition were defective and unlawfully served. Petition to Recover Possession
of Real Property is UNSIGNED (att. fax to NM&M) and NoP&P was not sent by certified/
registered and regular mail and no attempts at personal service were made.
The RICO, in "both" cases, violated FDCPA by having their "Debt Collector" sign
Predicate Notice, without required Validation Notice. If this is disputed (not stipulated to)
respondent will require appearance of both "debt collectors"at trial (Romea v. Heiberger & Assoc., 989 F.Supp. 712 (SDNY 1997).
Petitioner (RICO) due to SECTION 8 status of respondent (even if induced by
"Landlord"Fraud) is required to follow Federal "Williams Consent Judgment" (Quesada
v. Hernandez, 5 Misc 3d 1028 (A)[NY Sup. 2004]). In "both" cases petitioner failed to
include or Serve or Notice NYCHA or DHPD. Upon Information and Belief (see att.),
RICO is receiving (unlawful) Section 8 subsidy, negating any need for "rent".
Respondent requests of Court that $1,000,000 Fine/Damages be levied Jointly &
Severely against Dean Roberts/Mia Falls, Norris McLaughlin & Marcus and/or
Kenmore Associates a.k.a Housing & Services inc. a.k.a. Kenmore Housing Corp. a.k.a.
Kenmore Housing Development Fund Corp..
Plaintiff's five cases against respondent (3 dismissed) and well over 400 Housing
Cases against tenants in stolen government property (only 320 apartments) in the last
10 years constitute Vexatious and Frivolous Litigation, Abuse of Process and the Courts.
WHEREFORE, respondent prays for the granting of an Order from the Court
dismissing petitioner's Petition in its entirety, and for all such and further relief that this
Court may deem just and appropriate.
______________________________
, Respondent Pro-Se
145 east 23rd street
New York, NY 10010
Sworn Before me on the
13th Day of June, 2007
Thursday, August 16, 2007
Kenmore Housing Corp
CIVIL COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK : HOUSING PART
----------------------------------------------------------X
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. :
---------------------------------------------------------X
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
COUNTY OF NEW YORK : HOUSING PART
----------------------------------------------------------X
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. :
---------------------------------------------------------X
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
Norris McLaughlin & Marcus2
CIVIL COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK : HOUSING PART
----------------------------------------------------------X
KENMORE ASSOCIATES, L.P. & : Index # 071507/2007 &
HOUSING & SERVICES INC. & : Index # 52851/2006
Norris McLaughlin & Marcus :
Petitioner, : AFFIDAVIT & CROSS-MOTION
v. : REPLY TO OPPOSITION
: PRE-ANSWER
, :
:
Respondent. :
---------------------------------------------------------X
(State of New York)
(County of New York)
SS: I,____________________, ( ), Respondent in this Action, being duly
sworn, hereby depose and state: The plea of RES JUDICATA is reiterated. The case,
index #071507/07, is an IDENTICAL CAUSE OF ACTION with IDENTICAL PARTIES to
index #52851/06 (exhibit A (att.)). In plaintiff's UNSIGNED and UNDATED (CPLR §2101
& §2106) affirmation?, without claimed (and without foundation) exhibit? attached,
petitioner claimed THE HONORABLE MARIA MILIN wished (by order?) to prospectively
dismiss case (#52851/06) after 90 days if without response by either party. This "order"
was NEVER SERVED ON THE PARTIES OR THE COURT and the CASE IS NOT
DISMISSED (i.e. current (see exhibit A)). Obviously, JUDGE MILIN, upon review of
relevant law, CPLR §3216, §3404, Uniform Rule 202.27 (22 NYCRR 202.27) and
NYCRR §208.14[c]), saw that sufficient time (one year) has not elapsed. Case
#52851/06 was never marked off calendar by agreement of both parties.
OMNIBUS MOTION TO DISMISS, in exhibit(1), shows MOTION ORDER by THE
HONORABLE JEAN T SCHNEIDER demanding reply, by petitioner, by August
21, 2006. Despite parties appearing before THE HONORABLE KEVIN C
MCCLANAHAN on 08/21/06 due to respondent's OPPOSITION TO CROSS-
MOTION return date, and petitioners acknowledgment, on the record, of
outstanding ORDER, petitioner has, like with stipulation, failed to comply. Due to
petitioners failure to REPLY to respondent's OPPOSITION TO CROSS-MOTION,
JUDGE SCHNEIDER and/or JUDGE MILIN felt justifiably unable to rule on
respondent's two outstanding OMNIBUS MOTION(s) TO DISMISS (included as
exhibits in OMTDWP) on the merits and are presumably still waiting.
Respondent requests (A) MOTION TO REARGUE/RENEW courts vacatur of
stipulation. Petitioner (RICO (USC Title 18 Part I Chapter 96 §1961-1968)) by
counsel/Consiglieri's ongoing predicate Felony Perjury, Obstruction of Justice
(see exhibits), Fraud etc. as well as breach of Stipulation constitute grounds for
disbarment and/or incarceration. Barring Consiglieri/"House Counsel" as well as
substantial Fines under 22 NYCRR §130-1 are demanded as relief.
(B) MOTION TO DISMISS for willful and purposeful violation of respondent's
CPLR §2214 Motion demand within instant OMNIBUS MOTION TO DISMISS
WITH PREJUDICE.
(1) Respondent lacks knowledge or information sufficient to form a belief of
the truth of the allegation that individual who refers to himself as "Dean M.
Roberts" is an attorney at all but agrees he should be prosecuted under "penalties
of Perjury" etc.. Respondent agrees that RICO "law firm" (see exhibit) NM&M is a
party to RICO case and past and future counterclaims. "Paper" submitted by
Consiglieri/"House Counsel" does not constitute "Affirmation" under CPLR
§2106, §2101 or any other rule as it is unsigned and undated.
(2) This proceeding commenced in 2006 under index #52851 and is ACTIVE.
No "rent" has been paid to RICO or the People of the United States (the actual
owner (see Amended Answer)). Upon information and belief and documentary
evidence (att. exhibit B) RICO petitioner has received "section 8" payments for
relevant apartment over said period, constituting additional Fraud. Respondent will
request, during discovery, relevant vendor and voucher numbers for Comptroller's
investigation and thorough forensic accounting, paid by petitioner.
(3) Petitioner (RICO) is apparently stipulating to "Section 8" Fraud (2921
Associates v. Willis, Title 24 CFR: Ch VII HUD Part 792) as it is not answered.
Admittedly RICO puts no value on Stipulations unless it is for dispossession of
Enemy (Chattel(Tenant (see Amended Answer))).
(4) Respondent claims the existence of a CURRENT "non-payment" (and RICO)
proceeding (index #52851/06).
(5) Respondent submitted attached (to OMTDWP) motions to HONORABLE
JEAN T SCHNEIDER (see OMTDWP exhibit A). Alleged proposed?
"decision" (not attached) was not served on parties or the court and is not in
effect. Case, index #52851, is not dismissed (see attached exhibit A) and
petitioner (RICO) need only Reply to Opposition a year late, or serve a Motion
to Renew or Motion for Accelerated Judgment, similar to the previous Fake
Motion for Accelerated Oral Argument served to respondent in previous
(dismissed) case between parties and stop continual Perjury and Obstruction
of Justice.
(6) "We did not discovery[sic] the decision" is apparently a stipulation to
respondent's discovery requests.
(7) Perjury and Obstruction of Justice and lack of Due Diligence (again
(ABA Model Rules of Professional Conduct)).
(8) RICO Consiglieri apparently has not read and/or cannot read attached "fact"
though has not informed parties or court as to any reasonable accommodation
needs (dyslexia?). The Amended Answer and/or other attached and admitted
papers are the "fact" RPAPL §743 The answer may contain any legal or equitable defense, or counterclaim. The court may render affirmative judgment for the amount found due on the counterclaim.
(9) Jury fees have been paid into and accepted by court in instant (index
#52851/06) case. Respondent requests Jury Trial pursuant to CPLR §2218. Trial of issue raised on motion. The court may order that an issue of fact raised on a motion shall be separately tried by the court or a referee. If the issue is triable of right by jury, the court shall give the parties an opportunity to demand a jury trial of such issue. Failure to make such demand within the time limited by the court, or, if no such time is limited, before trial begins, shall be deemed a waiver of the right to trial by jury. An order under this rule shall specify the issue to be tried.
for all motions.
(10) This has been answered extensively in attached (to OMTDWP) AFFIDAVIT
IN SUPPORT OF MOTIONS pages 6-8. RICO "house counsel" has not supplied
(forged) papers RICO allegedly refers to (see CPLR §2221(c) "Only papers served in accordance with the provisions of this rule shall be read in support of, or in opposition to, the motion,").
(11) Respondent requests that all MOTIONS not answered by RICO petitioner
be deemed stipulated to. In consideration of prior RICO Frauds by petitioner's
Consiglieri (see attached); for 22 NYCRR §130-1 relief Respondent requests of
Court that $1,000,000 Fine/Damages be levied Jointly & Severely against Dean
Roberts/Mia Falls, Norris McLaughlin & Marcus and/or Kenmore Associates a.k.a
Housing & Services Inc. a.k.a. Kenmore Housing Corp. a.k.a. Kenmore Housing
Development Fund Corp. and/or any other related Shell Corporations/Money
Laundering Organizations (not John Z. Delorean Front).
(12) Respondent continues to deny proper personal (service RPAPL §735) or court
jurisdiction or petitioner RICO's standing (see all papers). Additionally Petition for
Possession of Real Property is defective (unsigned and undated (RPAPL §741)).
These issues are apparently stipulated to by RICO as they have again gone
unanswered.
WHEREFORE, respondent prays for the granting of an Order from the Court
dismissing petitioner's Petition in its entirety, and for all such and further relief that this
Court may deem just and appropriate.
______________________________
, Respondent Pro-Se
145 east 23rd street #4R
New York, NY 10010
Sworn Before me on the
9th Day of August, 2007
COUNTY OF NEW YORK : HOUSING PART
----------------------------------------------------------X
KENMORE ASSOCIATES, L.P. & : Index # 071507/2007 &
HOUSING & SERVICES INC. & : Index # 52851/2006
Norris McLaughlin & Marcus :
Petitioner, : AFFIDAVIT & CROSS-MOTION
v. : REPLY TO OPPOSITION
: PRE-ANSWER
, :
:
Respondent. :
---------------------------------------------------------X
(State of New York)
(County of New York)
SS: I,____________________, ( ), Respondent in this Action, being duly
sworn, hereby depose and state: The plea of RES JUDICATA is reiterated. The case,
index #071507/07, is an IDENTICAL CAUSE OF ACTION with IDENTICAL PARTIES to
index #52851/06 (exhibit A (att.)). In plaintiff's UNSIGNED and UNDATED (CPLR §2101
& §2106) affirmation?, without claimed (and without foundation) exhibit? attached,
petitioner claimed THE HONORABLE MARIA MILIN wished (by order?) to prospectively
dismiss case (#52851/06) after 90 days if without response by either party. This "order"
was NEVER SERVED ON THE PARTIES OR THE COURT and the CASE IS NOT
DISMISSED (i.e. current (see exhibit A)). Obviously, JUDGE MILIN, upon review of
relevant law, CPLR §3216, §3404, Uniform Rule 202.27 (22 NYCRR 202.27) and
NYCRR §208.14[c]), saw that sufficient time (one year) has not elapsed. Case
#52851/06 was never marked off calendar by agreement of both parties.
OMNIBUS MOTION TO DISMISS, in exhibit(1), shows MOTION ORDER by THE
HONORABLE JEAN T SCHNEIDER demanding reply, by petitioner, by August
21, 2006. Despite parties appearing before THE HONORABLE KEVIN C
MCCLANAHAN on 08/21/06 due to respondent's OPPOSITION TO CROSS-
MOTION return date, and petitioners acknowledgment, on the record, of
outstanding ORDER, petitioner has, like with stipulation, failed to comply. Due to
petitioners failure to REPLY to respondent's OPPOSITION TO CROSS-MOTION,
JUDGE SCHNEIDER and/or JUDGE MILIN felt justifiably unable to rule on
respondent's two outstanding OMNIBUS MOTION(s) TO DISMISS (included as
exhibits in OMTDWP) on the merits and are presumably still waiting.
Respondent requests (A) MOTION TO REARGUE/RENEW courts vacatur of
stipulation. Petitioner (RICO (USC Title 18 Part I Chapter 96 §1961-1968)) by
counsel/Consiglieri's ongoing predicate Felony Perjury, Obstruction of Justice
(see exhibits), Fraud etc. as well as breach of Stipulation constitute grounds for
disbarment and/or incarceration. Barring Consiglieri/"House Counsel" as well as
substantial Fines under 22 NYCRR §130-1 are demanded as relief.
(B) MOTION TO DISMISS for willful and purposeful violation of respondent's
CPLR §2214 Motion demand within instant OMNIBUS MOTION TO DISMISS
WITH PREJUDICE.
(1) Respondent lacks knowledge or information sufficient to form a belief of
the truth of the allegation that individual who refers to himself as "Dean M.
Roberts" is an attorney at all but agrees he should be prosecuted under "penalties
of Perjury" etc.. Respondent agrees that RICO "law firm" (see exhibit) NM&M is a
party to RICO case and past and future counterclaims. "Paper" submitted by
Consiglieri/"House Counsel" does not constitute "Affirmation" under CPLR
§2106, §2101 or any other rule as it is unsigned and undated.
(2) This proceeding commenced in 2006 under index #52851 and is ACTIVE.
No "rent" has been paid to RICO or the People of the United States (the actual
owner (see Amended Answer)). Upon information and belief and documentary
evidence (att. exhibit B) RICO petitioner has received "section 8" payments for
relevant apartment over said period, constituting additional Fraud. Respondent will
request, during discovery, relevant vendor and voucher numbers for Comptroller's
investigation and thorough forensic accounting, paid by petitioner.
(3) Petitioner (RICO) is apparently stipulating to "Section 8" Fraud (2921
Associates v. Willis, Title 24 CFR: Ch VII HUD Part 792) as it is not answered.
Admittedly RICO puts no value on Stipulations unless it is for dispossession of
Enemy (Chattel(Tenant (see Amended Answer))).
(4) Respondent claims the existence of a CURRENT "non-payment" (and RICO)
proceeding (index #52851/06).
(5) Respondent submitted attached (to OMTDWP) motions to HONORABLE
JEAN T SCHNEIDER (see OMTDWP exhibit A). Alleged proposed?
"decision" (not attached) was not served on parties or the court and is not in
effect. Case, index #52851, is not dismissed (see attached exhibit A) and
petitioner (RICO) need only Reply to Opposition a year late, or serve a Motion
to Renew or Motion for Accelerated Judgment, similar to the previous Fake
Motion for Accelerated Oral Argument served to respondent in previous
(dismissed) case between parties and stop continual Perjury and Obstruction
of Justice.
(6) "We did not discovery[sic] the decision" is apparently a stipulation to
respondent's discovery requests.
(7) Perjury and Obstruction of Justice and lack of Due Diligence (again
(ABA Model Rules of Professional Conduct)).
(8) RICO Consiglieri apparently has not read and/or cannot read attached "fact"
though has not informed parties or court as to any reasonable accommodation
needs (dyslexia?). The Amended Answer and/or other attached and admitted
papers are the "fact" RPAPL §743 The answer may contain any legal or equitable defense, or counterclaim. The court may render affirmative judgment for the amount found due on the counterclaim.
(9) Jury fees have been paid into and accepted by court in instant (index
#52851/06) case. Respondent requests Jury Trial pursuant to CPLR §2218. Trial of issue raised on motion. The court may order that an issue of fact raised on a motion shall be separately tried by the court or a referee. If the issue is triable of right by jury, the court shall give the parties an opportunity to demand a jury trial of such issue. Failure to make such demand within the time limited by the court, or, if no such time is limited, before trial begins, shall be deemed a waiver of the right to trial by jury. An order under this rule shall specify the issue to be tried.
for all motions.
(10) This has been answered extensively in attached (to OMTDWP) AFFIDAVIT
IN SUPPORT OF MOTIONS pages 6-8. RICO "house counsel" has not supplied
(forged) papers RICO allegedly refers to (see CPLR §2221(c) "Only papers served in accordance with the provisions of this rule shall be read in support of, or in opposition to, the motion,").
(11) Respondent requests that all MOTIONS not answered by RICO petitioner
be deemed stipulated to. In consideration of prior RICO Frauds by petitioner's
Consiglieri (see attached); for 22 NYCRR §130-1 relief Respondent requests of
Court that $1,000,000 Fine/Damages be levied Jointly & Severely against Dean
Roberts/Mia Falls, Norris McLaughlin & Marcus and/or Kenmore Associates a.k.a
Housing & Services Inc. a.k.a. Kenmore Housing Corp. a.k.a. Kenmore Housing
Development Fund Corp. and/or any other related Shell Corporations/Money
Laundering Organizations (not John Z. Delorean Front).
(12) Respondent continues to deny proper personal (service RPAPL §735) or court
jurisdiction or petitioner RICO's standing (see all papers). Additionally Petition for
Possession of Real Property is defective (unsigned and undated (RPAPL §741)).
These issues are apparently stipulated to by RICO as they have again gone
unanswered.
WHEREFORE, respondent prays for the granting of an Order from the Court
dismissing petitioner's Petition in its entirety, and for all such and further relief that this
Court may deem just and appropriate.
______________________________
, Respondent Pro-Se
145 east 23rd street #4R
New York, NY 10010
Sworn Before me on the
9th Day of August, 2007
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