I have done this legal brief without any help and I have post-traumatic stress and severe insomnia from the assault at Dr Andrew Fagelman's where my vision was damaged from a running punch to my head from a violent savage attack by Delita Hooks, medical receptionist/office manager who was not arrested or fired. The first precinct detective squad joined in committing crimes, a pile-up of crimes and because I did not go thru the process of false arrest due to coercion, a hole in my retina, cervical damage, fear of more bodily harm and even more NYPD crimes and fabricated DD5s. I was not able to get a lawyer and legal support after I was coerced so I don't have the legal cases that I should be on this page. Therefore I'm using this page instead as a pro se litigant to sum up some key points why you should return my lawsuit to New York State Supreme Court and if you don't what if I am further harmed or murdered like Eric Garner, a fellow pro se litigant from 8yrs ago? Eric Garner was also a victim of NYPD crimes and retaliation.1) I'm suggesting you could do something and if you don't like prior judges, I am suggesting possible you've given corrupt cops a green light to get away with everything but murdering me, so far. When Eric Garner said it stops today you don't know what he really meant unless you read his hand written pro se lawsuit from Rikers 8 years ago and the horrors he endured at the hands of NYPD in Staten Island including public sexual violations by NYPD as well as retaliating against him for stating he would sue by planting drugs on him! For me it does not stop until I have Justice and I hope to testify under oath and everyone involved in my case will have to answer questions under oath in front of the new commission into police corruption and DA corruption, Corp Counsel protecting NYPD crimes that is televised around the world.
2. NY State Supreme Court Pro se Office packet on serving the NYPD was no more clear to me that it was to the pro se employee that looked at my paperwork and stated I did it correctly, the paperwork was correct. If you throw out my case after corporate counsel accepted it, then you did what was done to Eric Garner's, pro se lawsuit, throw out my case on a clerical technicality and Eric Garner is now dead at the hands of reckless cops.
Based on the fact the pro se instructions are so confusing that even the pro se employee said I was correct and Judge Nathan never responded to my requests for assistance I am asking you return my case to NY State Supreme Court were I can request a new judge and amend my complaint and request assistance serving NYPD in hiding.
Even the city lawyers did not notice anything wrong and look how many months it took if there is anything actually wrong enough to ask dismiss my case over a technicality. Corporate counsel has lied for years on behalf of the defendants and even judge Nathan who refused to meet me like the detectives in my case, Judge Nathan, in the year she held onto my case acknowledged I could pursue my case in New York State Supreme Court.
3 I'm asking you to see something say something and forward my case to any and all government agencies starting with the Attorney General Who currently has Eric Garner's case, as well as the New York State AG and US Attorneys including Brooklyn since Preet Bharara decided to investigate similar NYPD Fixing crimes in Williamsburg, Brooklyn, maybe the Brooklyn US Attorney would investigate NYPD fixing in favors in Manhattan?
4 It was truly a default ruling because the city lawyers took advantage of the fact I'm one of the last manual files New York State Supreme Court and did not get me their response until almost 2 months later. Ask them to show you proof of service on this and every document especially filed by Catherine Papandrew. I believe you'll find an affidavit of service missing on at least one of her filings. By giving me a Default ruling you may save my life and allow me time to prepare to respond to the city challenging default since my Dad a WW2 Veteran died during the federal knowing I was treated like a Jew in the early stages of Nazi Germany including by Ray Kelly and my Bronx born Mom is in hospice right now.
5 The city lawyers submitted the wrong notice of claim and I'd be happy to redo the lawsuit to fit that one which includes Bratton who taught me turn broken windows back on the NYPD and add PC James O'Neill, Chief Reznick and Chief Boyce.
6 Judge Kotler, I allege is a bias judge against pro se litigants and never responded to my request for assistance to serve defendants Sgt Chen, Lt Agnes I now know to be Lt Michael J Agnes but I still have the affidavits of service and paperwork of attempted service by hand and by mail mailed to Internal Affairs and the 1st Precinct with their names and Charles Campisi accepted service by mail so the majority of the defendants accepted service and the lawsuit and that was good enough to move my case forward. Joel Graber, owner of the process serving company, wrote a powerful affidavit regarding my service and I'd like permission to share it with you and corp counsel at the oral argument I am requesting. Judge Kotler, like Corp Counsel who I allege judge Kotler favors took advantage of my lack of education, experience and PTSD, anxiety and prevented me from any possible Justice so I'm asking you to send my case back to New York State Supreme Court where I can ask for her to recuse herself and for me to get a new judge and to ask to redo my complaint and get assistance serving the cops that have hid their identities and badge numbers all these years with Internal Affairs and corporate counsel's help!
7 I did make claims and they were debated in court with Catherine Papandrew who lied about me and the fact I was coerced. NYPD coerced me, prevented me from reporting a series of crimes some of its captured on audios posted on YouTube and the defendants violated my Constitutional Rights and due process either directly preventing me from reporting crime or conspiring along with Dr Fagelman who did not fire his violent lying attack receptionist but let her go right back to her desk as if nothing had happened.
8 Judge Kotler violated my first amendment rights preventing me from responding to Catherine Papandrew during the oral arguments because she is bias and favors corporate counsel as proven yet again giving Corp counsel a chance to respond but not me the victim of violent crimes and ongoing lies! Judge Kotler could not hide her bias and favoritism of corporate counsel and she even allows corp counsel their own special row to sit in front of their victims. The first time I stepped into her court room there was no court reporter or court officer and her clerk Corp counsel calls Lorraine yelled at me everywhere I stood was wrong in an empty court room.
I am requesting an oral argument and that you allows me my first amendment right to respond especially when I'm lied about.
9.You, like Judge Kotler are suppose to give me as much latitude as possible because I'm a pro se litigant and if you dismiss my case I am concerned and fearful that like Eric Garner's case dismissed on a technicality, you could be assisting the cycle of violence and harassment and worse even deaths of pro se litigants like Eric Garner's. Pro se litigants are set up to fail especially by New York State Supreme Court pro se office. I contacted judge Kotler's supervisor and suggested video instructions as 1 example. I allege Judge Kotler joined in setting me up to fail as well so please send my case back so I can be reassigned a new judge and ask to amend my lawsuit, help with service by NYPD that are being hidden or give me a default ruling rather than prevent me from having Justice. I have come such a long way and spent so much money for so many years when I tried to get a cyst removed from my elbow assist that was biopsied and I left with a hole in my retina cervical damage severe insomnia and posttraumatic stress from violence and lies from the doctors office to police department that joined in the crimes. I would ask you again to forward my case and point out corporate counsel lied just look at the police reports the video and audio's that are footnoted in the lawsuit I believe that obligates you to look at the evidence along with the police reports that were submitted in the evidence section approve Det Vergona lied in his DD5 police notes signed off by his supervisor Lt Burgos whenever contacted me and never acknowledge me when a subordinate gave me his email and I asked for badge numbers there's detectives and Sgt Chen. were acting inappropriately. Lt Burgos never responded and lied about me but when I file this lawsuit he didn't respond yet email his personal email asking that I include him in my linked in network on Friday the 13th 2015 at 5:30 am. This is just another example of very disturbing inappropriate behavior by supervisor is been protected by the city of New York all these years he still doesn't understand right from wrong along the detectives that downgraded a series of crimes including their own crimes in my case to a fabricated mutual assault to no crimes at all. I allege Dr Fagelman made a call 1800 NYPD Fix it and the NYPD assured him they could fix this by coercing me and fabricating a mutual assault.
10) I’m asking you to see something say something including corp counsel lying joining in obstructing justice exploiting a victim of NYPD IA crimes as well as NYPD IA acting outside there scope. I'm also asking you to take a special step since they are using Ron Kuby's letter to pretend the NYPD didn't commit any crimes when they downgraded crimes including 2nd degree assault as see in video evidence posted on YouTube, menacing me coming out from behind the reception desk and then the NYPD line and police reports threatening new conspiring to obstruct justice preventing need to process, coercion, Sgt Chen refuses to come down stairs and meet me a violation of protocol and you can hear he has PO Migori refusing to allow me to report Delita Hooks false crossed complaint all captured on audio posted to YouTube and you can hear me call DI Ed Winski, CCRB and Internal Affairs on the audio, etc -- a series of crimes, violation of due process and obstruction of Justice, coercion refusing to allow me to reports crimes as well as my constitutional rights and Catherine Papandrew lying in court the defendants investigated the crime when in fact they conspired to force me to drop charges and down graded a series of crimes to no crimes and used Ron Kuby’s letter which says in so many words my client is being threatened with her attacker’s false cross complaint. Why else would I have dropped charges on that horrific attack and I mention over and over I am scared which is noted in NYPD public member Marks police report after the attack and in emails to Ron Kuby Ron I am scared. I have never met Ron Kuby. but he protected me from horror and even more crimes if I turned myself in on Saturday 4pm to Det Vergona who yelled at me You are going to drop those charges or I am going to arrest you. I asked Det Vergona false arrest the Jew on the Sabbath? Are you anti-Semitic? I followed up immediately that day Oct 16, 2012 and wrote false arrest the babbling Jew see the email in the evidence setion. In appellate court corp counsel lied and stated Vergona did know I was Jewish. Vergona knew and the email Oct 16 re G-d Sees All included Ray Kelly’s community affairs liaison Det Martin Brown. Det VERGONA fabricated police reports, refused to meet me and lied in police reports along with Delita HOOKS detective Andy Dwyer but Catherine Papandrew states police acting with in their scope and did an investigation when they committed crimes and obstruction Justice! I don’t even have badge numbers. There was no investigation just fixing and favors. The audio I submitted posted on YouTube and footnoted in the lawsuit of Mary O'Donnell's refusing evidence you can hear me say Ron's letter is not what I agreed to.
10a) Ron Kuby never supplied me with a copy of my attackers signed letter openly threatening me agreeing to drop charges and warning me to not come back mirroring the same threatening tone of the cunt misogynist hate crime why a lawyer use the sock puppet account six days (I allege was Joe Tacopina of Abner Louima cop infamy) yet again threatening me just like in her signed letter telling me not to come back don't file assault charges again. I would like a copy my attackers signed letter which I've never been given a copy of what shown to me by IA Sgt Mary O'Donnell who said case closed and protected yet another threat and crime by my attacker. Corp Counsel, the NYPD Internal Affairs have prevented me from getting a copy of this letter and I have no legal way of getting it without your help and I should have that letter corporate counsel won't share it because it incriminates their clients who they know are guilty.
10b) Please help me to obtain this letter I know this is a special request but I'm a pro se litigant a victim of violence and Lt Burgos harassing mocking communiqué is an unheard of acts I don't think that's ever been done in court before when a pro se or any lawyer files a lawsuit for one of the defendants to asked to be a LinkedIn friend and he did it on Friday the 13 November 2015 at 5:30 am same day as Terror Mass Murder Paris so please that was so harassing frightening and I worried for my safety please can you help me because of this unusual harassment and circumstances to please get a copy of my attacker's letter agreeing to drop charges against me her false cross-complaint if I drop my complaint and warning me to not come back and file second-degree assault charges.
I really should have a right to that signed letter and I asked Ron Kuby if he has a copy and he never responded to me. These corrupt cops have never answered any questions under oath and they should have to.
As a victim of a violent crime as a victim of coercion as a victim of NYPD doing a bait and switch downgrading second-degree assault menacing a pass cross complaint along with a series of crimes the NYPD committed into a fabricating a mutual assault in to 0 crimes and Internal Affairs top brass party covering up these crimes!
11) This was retaliation for many reasons including the fact that I am the loudest critic of mayor Bloomberg's tax payer Tech Titanics the biggest being 911 top corruption as contractors delivered late and delivered and top NYPD cops were talking lavish gifts. Only $65 million returned 0 arrests. That's retaliated for many reasons including being outspoken critic of the First Precinct's selective policing fixing in favors for the Mercer hotel down the street from the attack. Because of the 911 tech corruption bigger than CityTime again I am asking you to see something and say something and forwarded my case to the AG and US Attorneys.
12) I am asking you for De Novo and that included my opposition to dismiss which outlines on the first page how I was repeatedly threatened by my attacker including with NYPD protecting her signed threat to not come back and file assault charges, the NYPD threatened me and I allege Joe Tacopina using a sock poppet account Bob Dobalina threatened me.
It was a horrific assault violent 2nd degree assault posted on YouTube with almost half 1 million views and I am asking for my right at least have a copy of Delita Hooks signed letter in response to the Kuby letter which proves the NYPD threaten me with a force cross complaint in her letter proves they protected me being threatened yet again and we're not to come back and file second-degree assault charges or I would file another false cross-complaint and the NYPD, Internal affairs protecting these crimes and threats and preventing me to from to process.
The big picture: I'm asking for Justice as a pro se litigant and you are supposed to give us the most leeway possible so please do so in the name of Justice and to try and even the playing field where the city has unlimited financial resources and a very large staff and the city has even more evidence proving their clients are guilty and I can't even get to the discovery phase yet! They are not mafia lawyers please what the defendants and corporate counsel have done all these done should be reported to the Attorney General who is Eric Garner's case right now.
