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THIRD AMENDED COMPLAINT

THIRD AMENDED COMPLAINT

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THIRD AMENDED COMPLAINT IN ADVERSARY PROCEEDING. BUNKRUPTCY COURT
THIRD AMENDED COMPLAINT IN ADVERSARY PROCEEDING. BUNKRUPTCY COURT

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Published by: SLAVEFATHER on Aug 25, 2013
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10/10/2013

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UNITED STATES BANKRUPTCY COURT RETURN DATE: August 1, 2013EASTERN DISTRICT OF NEW YORK ---------------------------------------------------------xIN THE MATTER OF:ELENA SVENSON, CASE NO. 1-12-43050-essDebtor. CHAPTER 7--------------------------------------------------------xMICHAEL KRICHEVSKY,Plaintiff/Creditor,v.ELENA SVENSON, Adversary Proceeding No. 12-01229-essDefendant/debtor,BOARD OF MANAGERS OF OCEANACONDOMINIUM NO. TWO; INTERNALREVENUE SERVICE, INC.,Defendants/Creditors,
THIRD AMENDED
 VICTORIA EDELSTEIN, DDS; BORIS
COMPLAINT
 KOTLYAR, COOPER SQUARE REALTY, INC;LANA KAPLUN, personally; FARIDBADALOV, personally; BORIS MEYDID, personally;
TRIAL BY JURY DEMANDED
JOHN DOE and JANE JOHNS, personally (fictitious names to be discovered),Defendants.---------------------------------------------------------------xVICTORIA EDELSTEIN, DDS and BORISKOTLYAR,Cross-Claimants,v.MICHAEL KRICHEVSKY,Cross-Defendant.-----------------------------------------------------------------xMichael Krichevsky, Plaintiff, Pro Se, sues defendants and under penalty of perjuryrespectfully alleges upon his firsthand knowledge, except where it stated upon information and belief, or where it stated that he verily believes it to be true:
INTRODUCTORY STATEMENT
This is an action where plaintiff 
, with “clean hands,”
collaterally attacks NULL andVOID documents, orders, contracts and liens. This is the action were plaintiff exercises hisConstitutional right to petition the government for redress of grievances. Said grievances arousedwhen the defendants in contracting with plaintiff acted as predators, and some as vultures, to
 
 
2obtain their goal of enrichment by unjust and unlawful means. Individual defendants in this casedid not want to work hard and play by the rules as millions of Americans do. No, thesedefendants are smarter than other Americans are, and deserve more
 – 
or so they think. DefendantSvenson
was the plaintiff‟
s girlfriend and business partner who never wanted work a day in her life. After breakup with plaintiff, she wanted to continue her parasitic lifestyle. She did not wantto work and did not want to support her son. To achieve this goal, defendant Svenson attemptedto blackmail plaintiff by threatening to report him and his employer to IRS and FBI, therebymaking his life miserable by being subjected to their investigation
and attorney‟s expenses
.When her attempt failed, she, using money stolen from plaintiff, started a legal war against him by unleashing against him four lawyer-bullies along with police, sheriffs and family court.Defendant Svenson, through fraud, misrepresentations, defamation and violations of Penal Codeof the State of New York, obtained a void order of child support, which allows her not to work and not to support her son. She and her attorneys committed and conspired to commit numerouscriminal acts in violation of Penal Code of the State of New York.Defendants Svenson, Edelstein, Kotlyar and their attorneys conspired to extort moneyfrom plaintiff and force him into the short sale of his condominium to Edelstein and Kotlyar.Watching defendants Svenson, Edelstein and Kotlyar hurting plaintiff and hurting hiscondominium interests by not paying common charges, Homeowners Association, its board,agents and other individual corporate defendants, having fiduciary duty to intervene on behalf of  plaintiff and other homeowners, refused to do so when plaintiff requested help. This is the casewhere these officers decided that they do not serve homeowners, but instead homeowners servethem.
 
 
3All of the defendants decided that Plaintiff is weak and too busy defending himself sothey can walk all over him,
empty his pockets “while he is laying unconscious
and bleeding,
 loot
and plunder plaintiff‟s hard earned assets.
Lana Kaplun, under pretext of acting in the bestinterest of homeowners association ordered Farid Badalov and Boris Meydid to create artificialcontroversy with plaintiff. In the process, she, using corrupt attorneys and vexatious litigation,turned about $5000 of alleged debt created by her into about $50,000. Then she added postfactum additional litigation fees and expenses to common charges, filed unlawful liens, started
foreclosure of plaintiff‟s unit
and made homeowners fit her bills by raising monthly commoncharges each homeowner must pay. Her behavior is akin to corporate raider like squeezing out of minority shareholders.This is an action for declaratory and injunctive relief that challenges the constitutionality of 
“Oceana‟s
 
Condominium.”
bylaws, policy and procedures. Defendants have filed two liens on
Plaintiff‟s property
without his knowledge while he challenged alleged debt in court. This is alsoan action that seeks declaratory and injunctive relief that challenges
“Oceana‟s Condominium”
 practice of deactivating magnetic keys from the amenities, building entrance and gates. Plaintiff seeks a declaration that Defendants failure to provide proper notice violated the
due processclause
of the 5
th
and14
th
amendment of the United States Constitution and Article 1, paragraph 6of the New York State Constitution
JURISDICTION AND VENUE
1.
 
The plaintiff, Michael Krichevsky, at all times herein mentioned was and still is aresident of the County of Kings and the State of New York.2.
 
The defendant, Elena Svenson, at all times herein mentioned was and still is a resident of 

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