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 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
bylaws, policy and procedures. Defendants have filed two liens on
without his knowledge while he challenged alleged debt in court. This is alsoan action that seeks declaratory and injunctive relief that challenges
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
of the 5
amendment of the United States Constitution and Article 1, paragraph 6of the New York State Constitution
JURISDICTION AND VENUE
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