RODERICK BREMBY, Defendants. ) ) ) JUDGE THOMPSON ) ) CASE NO. 3:12-CV-00039-AWT

REPLY MEMORANDUM IN SUPPORT OF PLAINTIFF’S MOTION FOR RULE 11 SANCTIONS Intervenor King respectfully demands that the Court impose sanctions for some of the same reason that the Court must deny Defendant Bremby’s Motion for Leave to File a Supplemental Memorandum in Opposition to Intervene. 1. First and foremost, they are lying about the application and the facts will clearly show as much. The law is clear and Intervenor King has already cited substantive case law from this very jurisdiction showing that the Court must order Diane Wood to the Stand and/or order a hard drive search -- unlike Defendant who tries to reach into other jurisdiction to make Ms. King go away. Now that Diane Wood -- after months of wrangling – has provided an Affidavit claiming that Ms. Slattery’s affidavit is true, Intervenor King will now take the time to prove even that is a lie: a) Ms. Slattery, at para. Indicates that the W-1 was not provided prior to 15

December, 2012. But that is a complete lie as the Court can already see that the W-1 was indeed sent on 22 November, 2011 in an email with the subject header “The Application” with a one-word body statement “Thanks!” as previously noted. So now the Court can clearly see the presence of at least one lie. Said email – with the W-1 showing as attached in the thumbnails -- is again reproduced below:


b) Further, on the issue of the bank statements as provided to Defendant, Intervenor stands by his position as previously noted: On 14 Nov. 2011 Intervenor wrote: “Betty King updates -- final docs for Title XIX” 
1. Foreclosure: I found the Sheriff sale proof online and it is attached. Please confirm you can open and read it. 
 2. U.S. Bank: The package was sent and is at my apartment awaiting my return on Wed night or TH morning -- I will overnight to you………


TD Bank had long since provided the information. Intervenor does not have a record of this because it was done in the bank at a local branch, but it was most assuredly done, just as was the W-1. 2. Defendant has become tangled up in his own lies: In addition to the email chains that clearly indicate Intervenor’s application was timely filed on 15 December, 2011 Ms. King will now disclose the silver bullet, given by Affiant Slattery herself at para. 7 where she notes the Intervenor had indeed provided the banking information! It says right there: “Mr. King provided the requested bank account information only.”


As to Ms. Wood’s purported email to Intervenor on 16 December 2011 – the day

after the final documents were indeed provided -- Intervenor on information and belief recalls a phone call in which Ms. Wood informed that the documents sent must have been lost in the system, which again, is not Intervenor’s fault. Intervenor will search his phone records for indicia of that, in order to prove up the lie yet again. Furthermore this is the issue of what is missing in this case from Diane Wood or Defendant Bremby: There are no return emails to the multitude of emails from Intervenor and Cecilia, Intervenor’s daughter, a person Certified in Six Sigma training among other things. If there was outstanding materials surely Ms. Wood is responsible for notifying an Applicant but there were no such notifications, only requests from Intervenor and Cecilia as previously noted, i.e. 27 August: Hello Ms. Wood, We are all concerned about our mother and this process. Do you have any more news or information for us? Thank you in advance. Sincerely, Again from Intervenor's sister: Thanks for the note Chris. Ms Wood as Chris stated we are concerned and I do not understand why this had not been resolved. We would like a full accounting of the procedures and the plans to get this approved or what has to be done to escalate it. At this stage we can no longer continue waiting.


5. But what is most telling is the 20 July 2012 email from Ms. Wood that Intervenor has kept in his pocket. The system of emails that the State uses makes emails expire unless you cut and paste the information out of them prior to expiration. Fortunately for Intervenor King, she maintained at least one such email, and in it Dian Wood clearly states that the problem has nothing to do with bank statements. As the Court reads this email it must remember that Intervenor did not send the second round of bank statements until September, 2012:


So to be clear, the problem then, is defined by Ms. Wood as being an internal issue: Unfortunately not. I am getting closer. The problem is there is a huge influx of new ones that at least need to be screened and initial requests made and older ones completed first. It is a never ending battle. I will attempt a.s.a.p. …… Intervenor has previously stated on the cover page of his Motion for Sanctions: May it please the Court: The application for Betty King was COMPLETE on 15 December 2011 yet Defendants failed to take action until Intervenor sued them in September of 2012. Here is a summary of emails for the Court’s edification. This response is a sworn response, noting that Diane Wood told Intervenor to keep sending these emails regarding the delay so that they could document the problem. There we have it, folks. Not one stinking word about anything outstanding from Intervenor. If this Court denies Intervenor’s Motion for Sanctions or the Motion to Intervene there is simply no Justice in that courthouse. Lastly, public policy militates in favor of Intervention and in favor of sanctions. Defendants have been given repeated opportunity to come clean and they instead gambled on whether Intervenor saved those emails or not and in the end, they lost. Their own Affidavit from Affiant Slattery proves that bank statements were already provide, and their own email from Diane Wood proves that bank statements were not the cause of the delay. As such, the actions of Defendant Bremby, and of Attorney General Jepsen, are deplorable and a copy of this Reply Memorandum is going straight to the reviewing authorities and straight to YouTube on an accelerated calendar. This is a case with far-reaching implications even if Defendant hates to admit it, and that is why Intervenor is seeking the cost of this sham Defense so that the taxpayers and the World Public can see how they are being fleeced.:


CHRISTOPHER KING, J.D. 617.543.8085m

22 January 2013 Re:


Cost of Federal Defense for Title XIX Litigation Occasioned by DSS Malfeasance

Dear Commissioner Bremby and Attorney Jepsen: This letter serves as a demand for immediate production of information of publiclyheld information relative to the current Title XIX litigation (i.e. Shafer v. Bremby 12CV-00039 and Briggs v. Bremby, 12-CV-000324 and) that has resulted as a direct and proximate cause of the State’s willful malfeasance in this area. Such malfeasance has had a marked impact on the quality of life for thousands of Connecticut residents in terms of healthcare and food stamps, and to compound injury both of you have issued material lies in Shafer v. Bremby 12-CV-00039, in which both of you know damn well that the Title XIX application for Intervenor Betty J. King was submitted in full on 15 December, 2011. The pending Motion for Sanctions – to which you were granted an extension of time until 28 January 2013 to respond – is the direct and proximate result of your lies. A Complaint to the Statewide Grievance Committee will be forthcoming as well, because frankly, you’ve earned it. See generally Exhibit 1 (part of the email correspondence from my sister and me to Title XIX Case Worker Diane Wood, whom you have failed to produce an affidavit from) as embedded below. Now then please provide for immediate inspection the following items per The Connecticut Freedom of Information Act, §14 Section 1-200 et seq: Briggs v. Bremby, 12-CV-000324 1. Documentation showing the total number of attorney hours expended from 5 March, 2012 to 22 January, 2013. Be certain to include the relevant hourly rate for each block of time. Shafer v. Bremby 12-CV-00039: 1. Documentation showing the total number of attorney hours expended from 9 January, 2012 to 22 January, 2013. Be certain to include the relevant hourly rate for each block of time. 2. Documentation showing the total number of attorney hours expended defending the Motion to Intervene of Betty J. King from 2 November 2012 to 22 January, 2013. Be certain to include the relevant hourly rate for each block of time.


Respectfully submitted, /s/ Christopher King, J.D. _____________________________ Christopher King, J.D. -- Reel News for Real People 617.543.8085 CERTIFICATE OF SERVICE I the undersigned, solemnly swear that a true copy of this Memorandum Was delivered via ECF service, this 28th day of January, 2013 Defendant Roderick Bremby c/o Hugh Barber, Esq. CT AG 55 Elm Street PO Box 120 Hartford, CT 06141 Plaintiffs Shafer and Harder Sheldon Toubman (ct08533) New Haven Legal Assistance Assoc. 426 State Street New Haven, CT 06510-2018 Phone: 203.946.4811 Fax: 203.498-9271 /s/Christopher King, J.D. __________________________________ By and through Christopher King, J.D. 617.543.8085m


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