CPLR 2221(f) to renew and reargue the completion of service nunc pro tunc with new transactions and with CPLR 3025(b) to supplement the complaint (COMBINED proposed Verified Supplement to the Complaint annexed) before the Honorable David I. Schmidt J.S.C. at the Part 47 Courtroom in the Courthouse at 360 Adams Street Brooklyn New York 10007, on the 28
th
day of March 2014, at 9:30 O’clock before Noon or at a time designated by the court or as soon thereafter as counsel can be heard; and, 2.
That Plaintiff in regards to the proposed intervener as a matter of housekeeping resubmits (see
Exhibit 7
herewith) his then response to the proposed intervener motion of November 4, 2011 attached here as a continuation of his own motion with Exhibits 1 thru 6; 3.
Further in regards to Plaintiff’s motion for completion of service motion NUNC PRO TUNC, re-submits herewith my Notice of Motion for leave to file proof of service nunc pro tunc filed with the clerk of the court on November 28, 2011 with support affidavit shown as Exhibit 1 with sub--exhibits A through E, Mr. Van Allen’s affidavit of service of January 13, 2011 for service of the defendants having been completed on December 4, 2008, and as reaffirmed on March 26, 2014 (see
Exhibit 8
)
;
and 4.
Regards to Plaintiffs Reply to the AG’s COMBINED RESPONSE that alleges:
•
That this
Court dismissed this case on the merits
on December 4, 2008 offering
AG’s COMBINED RESPONSE
Exhibit
A.
•
That Plaintiff now seeks to reopen this case but
offers no reason
for this Court to do so.
•
That Proposed Intervener William Van Allen also
seeks to reopen this case
and to intervene as co-plaintiff, but this Court has already denied his motion to intervene, and
•
That Van Allen offers
no reason to revisit
this Court's denial.
STRUNK’s REPLY Affidavit to the AG’s MOL IN OPPOSITION Page 2 of 9
5.
Plaintiff in REPLY based upon the affidavit and exhibit in support denies that the Court dismissed the case that is why the Court ordered the Hearing on March 28, 2014 at the request of Mr. Van Allen to Judge Prudenti (see
Exhibit 9
) as the fact that the case remains active for more than five years has pre-empted his and my ability to appeal interlocutory orders and barred parties accordingly from seeking remedy elsewhere. 6.
Plaintiff in REPLY based upon the affidavit and exhibit in support denies that Plaintiff somehow
offers no reason
references his Exhibit 4 in which the Appellate Division on 4 March 2014 denied Appellant / Plaintiff provision “for civilian due process of law”, and in that Mr. Pepper is disingenuously because he personally represented the State Appellees in opposition to Appellant’s motion for guaranteed provision of Civilian Due Process rather than Martial dues process for all Public US Citizens, and as Appellant Plaintiff (notwithstanding Mr. Van Allen who remains the surety for his Public US Citizen) is entitled equal protection of the law under colour of Statute 12 USC 95 and 50 USC App. 5(b) as a duly registered Private Citizen of the United States with the United States Secretary of the Treasury for both his 5
th
and Section 1 of the 14
th
Amendment rights under the U.S. Constitution and related provisions of the NYS Constitution has been denied. 7.
That at the heart of the reason for Plaintiff’s motion in this instant matter is that Mr. Obama by his own admission in his autobiography “Dreams From my Father” (1995) he is not a “Natural-born Citizen” because his legal father was both a British subject and then subject of the Sultanate of Zanzibar, and now appears that Mr. Obama is not a citizen of the United States at all based upon evidence that would be presented at a trial on say June 18, 2014, nevertheless based upon his own admission Mr. Obama is not eligible to be the President of the United States (POTUS) Commander-in-chief with direct authority over the martial law defacto executive Federal and States Court system accordingly; and as such Mr. Obama has been properly served as the POTUS Commander-in-Chief with direct
STRUNK’s REPLY Affidavit to the AG’s MOL IN OPPOSITION Page 3 of 9
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