INDEX NO. 056717/2013
-against- SUPPORT
Michael Krichevsky,,
Michael Krichevsky,
Third Party Plaintiff,
-against- —
-= ~
John Fasone, Yonatan Levoritz, Esq., Victor Katkalov, KINGS -<
Svenson, -^
Third Party Defendant. ^
Michael Krichevsky, Plaintiff, Pro Se, sues defendants and under penalty of perjury
respectfully avers upon his firsthand knowledge, except where it stated upon information
and belief, or where it stated that he verily believes it to be true and certifies that this
document is not frivolous per 130-1.1:
1. I am the plaintiff in the within action.
• 2. I incorporate all the statements made by me in my complaint (exhibit Al) as if stated in full
3. I make this affidavit in support of this OSC for an order striking defendants' Answers,
denials, Affidavits and Affirmations in their motions to dismiss my third-party complaint.
4. All exhibits herein I use as Offer of Proof and move this Honorable Court to enter them in
5. This affidavit used to supplement my complaint for the purpose of defendants' motion to
dismiss for failure to state a alarm, and averments in it should be presumed as true.
6. B ecause I am disabled due to stroke., I am a slow typist and by this paragraph I notify this
Honorable Court and other defendants that I will supplement this affidavit later to address their
motions to dismiss.
7. This affidavit is another of my failed attempts to report Federal Crimes of Treason and
Misprision of Treason to the judge, as well as a violations of Code of Judicial Conduct and New
York Rules of Professional Conduct to New York Tribunal per Rule 8.3 - Reporting Professional
"When an honest man, honestly mistaken, comes face-to-face with undeniable and
irrefutable truth, he is faced with one of two choices, he must either cease been mistaking
or cease being honest." Amicus Solo
8. About 6 years ago, defendants started maliciously prosecuting me for not paying my child
support, which I never refused to pay. When these defendants engaged in the conflict between
defendant S venson and me - there was a presumption that they are honest men. When my attorney,
Daniel Singer, during family court litigation approached them with undeniable and irrefutable
truth of documentary evidence - they destroyed their honesty presumption and violated NYRPC
rule 4.4 by needlessly violating my rights, causing embarrassment and harm, to me.
9. During this Family Court proceedings, defendants bamboozled my attorney and me and
cast a spell over my fatherhood, which turned now into my curse - where I am damned if I pay
child support - and I am damned if I don't This was summarily done hy defendant Fasone
knowingly ordering me to pay more child support that I was able. This non-dischargeable in
bankruptcy debt piled up into about $110,000, which I never be able to repay - and that was his
goal. It allows Fasone and child support collection unit (CSCU), for as long as I owe the child
support, both collect grants from Federal title IV - D finding (taxpayer's money) enriching
themselves by getting commensurable pay for ruining my life and harassing me - under pretext of
child support enforcement. CSCU restricted my driver's license for no legitimate and logical
reason. Now after I started instant litigation, CS CU begun harassing me with threat that they going
to put a lien on my property that is in foreclosure. Being Injured by defendants, disabled and
unemployed by defendants3 torts and criminal activity against me, I'm falsely Imprisoned in
debtor's prison. My cell is my home office. There, day and night, I am working on finding a legal
remedy to break defendant's spell and get my shattered life back.
10. What defendants did to me described in the book "The Importance of Being Honest" by
Law Professor Steven Lubet (available at AMAZON). In Chapter 31 "Stupid Judge Tricks" on
page 174 Professor relates, "In California, Judge Gregory Caskey was publicly admonished for
sending the following e-mail to an attorney:
"I am considering summarily rejecting [opposing counsel's] requests. Do you want
me to let [opposing counsel] have a hearing on this, or do we cut [opposing
counsel] off summarily and run the risk [of] the [Court of Appeals] reversing? ... I
say screw [the other party] and let's cut [opposing counsel] off without hearing.
OJL? By the way, this message will self-destruct in five seconds."
The recipient of Caskey5 s message replied as follows:
"Your Honor, I don't feel comfortable responding ex-parte [sic] on how you should rule on
a pending case."
By return e-mail the judge sent a one-word response, stating, 'chicken'."
11. These causes of action started in the beginning of 2008, when while I was working 60 - 80
hours a week at law office paralegal job, unemployed for life gold digger Svenson was working
hard at my home going through my personal tax records, bank accounts and ownership records.
12. When she has stolen everything she needed, she quietly filed for an order of protection and
immediately attempted to incarcerate me by provoking some kind of violence on my part by
visiting my employer to badmouth me. That attempt has failed, but I had to abandon my apartment
in order to avoid arrest by police when police came to arrest me, but missed me. Thereafter,
Svenson withdrew her petition for order of protection before the judge had any opportunity to rule
on it, Exhibit A.
13. At the same time, she brought stolen documents to her lawyers and filed for child support.
14. Even though the lawyers had every stolen document they needed for the child support
proceedings, they engaged in the harassment and extensive discovery alleging that I am hiding
15. During scheduling conference in Family Court, Fasone on the record specifically
prohibited Levoritz from doing third-party discovery, and only authorized subpoenas on banks
after deposition of Plaintiff and normal discovery.
16. Avoiding normal, court ordered discovery process (see Exhibit B4 after B1-B3) where
parties just exchange documents and bills, having depositions, etc., defendants Levoritz and
Katkalov refused to depose me, but immediately started broadcasting 16 non-party deposition
subpoenas to every possible bank in New York and my contractors who were doing renovation of
my house.
17. Because those were not information subpoenas, but deposition subpoenas, which my
attorney would have to attend - we knew that this was harassment and churning of Levoritz
attorney's fees - in contempt of Fasone's order.
18. Additionally, they started demanding from me for the last 5 years the very same documents
that Svenson has stolen from me.
19. In reply, on September 8,2009 my attorney filed Order to Show Cause with TRO to Quash
Subpoenas and for Sanctions, Exhibits B1-B3.
20. Svenson also attempted extortion by blackmail with the documents that she has stolen from
me, which is self evident from her blackmail note, exhibit C. hi this note, Svenson writes in rusty
Russian that she went to lawyers and they told her that my employer and I doing money-laundering
using law office.
21. While I was waiting for decision on that OSC to continue discovery and evidentiary
hearing, defendant Fasone scheduled a trial without any notice to parties. On February 3,2010
Fasone convened a kangaroo court without parties present. Transcript of this kangaroo court is
attached as Exhibit D. Using above described by Professor Lubet "Stupid Judge Trick," Fasone
"screwed me" by summarily cutting off my discovery and trial. After he created his void for fraud
upon the court child support order, he falsified the court record by denying this OSC statincr that
there was a hearing scheduled, but nobody appeared. That there was an objection to some
proffered documents, Exhibit E. I believe that this order was not done by Fasone, because the
content of the order sounds crazy - it says that the "motion" was filed by Yoram Nachimovsky
(former Svenson's attorney).! am informed and verily believe that Fasone uses Fasoms-robosigners
(court's employees) to fabricate orders. In addition to this egregious conduct, this order was never
mailed to me and I discovered that order about a year later when I was reviewing the court's file
Needless to say, that by this time the appeal of that order was moot because I was already
22. Before I had a chance to disobey Fasone's void order or appeal it, onMarch 1,2010 CSCU
seized all my earnings, Exhibit F
23. Now in the answer, defendants Levoritz and Katkalov deny that they possessed my
documents from 2002 until 2008, deny sending harassing subpoenas to my contractors, and deny
even that they knew about my contracts and contractors.
ARGUMENT I: Plaintiff objects to be "screwed" by res judicata and collateral estoppel
24. The issues of this litigation boils down to premises: a) defendants' corrupt aggression using
State police power against me and my contractors caused me a harm in violation of New York
Rules of Professional Conduct rule 4.4 by needlessly violating plaintiffs rights, causing
embarrassment and harm to me; b) to succeed, attorney and client lied to court, causing me harm.
25.. UABB ATE BALKAN COLAVITA & CONTINI specialize in defense of corrupt lawyers
such as Levoritz when they sued. I would like to put this Honorable Court on notice that I am
working on the motion to disqualify Mr. Nunberg and his firm as whole. Therefore,
jurisdictionally this court should decide my cross-motion to disqualify as first sequential priority in
order to obtain jurisdiction and determine whether Mr. Nunberg and his firm was authorized by
law to represent defendants Levoritz and Katkalov and prepare their answer, since I am Mr.
Nunberg's former client and objected from 2010 that he proceeds adversely against me.
Additionally, I will call Mr. Nunberg, Ms. Ratner and other attorneys of Ms firm as -witnesses
against his clients Levoritz and Katkalov on the issue of res judicata and collateral estoppel in this
26. The facts set in all defendants frivolous motions to dismiss clearly indicate that all
participating attorneys have conspired to "screw" Plaintiff and expect that this judge will "cut
Plaintiff off without hearing" by summarily dismissing my complaint with prejudice as done by
defendant Fasone, corrupt Judge Bernadette Bayne and corrupt attorney NoahNunberg in prior
Family and Supreme Court cases. Judge Bernadette Bayne essentially repeated after Fasone the
trick described by Law Professor Lubet above. Thereafter, Judge Bernadette Bayne ruled that my
cross-motions for default judgment against Levoritz and to disqualify Noah Nunberg are moot
"What really happened described in my certified mail letter to attorneys and the judge Bernadette
Bayne (Exhibit G), which still unrebutted, and therefore tacitly admitted. Accordingly, this letter is
prima facie evidence and my Offer of Proof describing events of that litigation. Therefore, no res
judicata or collateral estoppel exists because I did not have a chance fully and fairly litigate the
issues in the court of record, Law and Equity. Accordingly, this court should not give full faith and
credit to the order of Bernadette Bayne.
27. Judge's Bernadette Bayne order is VOID because of her and other participating attorneys'
not kosher due process and dealings against Pro Se Plaintiff hi Ross v. Bveready Ins. Co., 156 AD
2d 657 - NY Appellate Div., 2nd Dept (1989) the court explained:
Contrary to the determination of the Supreme Court, the defendant's motion to vacate the
judgment pursuant to CPLR5015 (a) (4) was not untimely. The judgment, which was
entered without acquiring personal jurisdiction over the defendant, was a nullity and did
not bind it (see, McMullen vArnone, 79 AD2d 496,499). Thus, the defendant was free to
"ignore the judgment, resist it or assert its invalidity at any and all times" (McMullen v
Arnone, supra, at 499; emphasis supplied); the defendant was not Abound to appeal from
[the] void judgment"1 (Hughes v Cuming, 165 N.Y. 91, 94, quoting Kamp -y Kamp 59 N Y
28. The old attorney's maxim goes, "If you can't beat your opponent with the facts, beat them
with the law. If you can't beat them with the law - discredit them." In f 3 of Noah Nunberg's
affirmation under penalty of perjury in the instant case, he writes that my Third-party Complaint is
frivolous because Levoritz and Katkalov denied material allegations of my complaint, (Exhibit H,
pages 2 & 3 of affirmation). Nunberg's argument is this, "if Levoritz denied averments in the
complaint, then Levoritz didn't do anything wrong to me." This argument by "prominent super
lawyer" insults my intelligence. He goes on to testify under penalty of perjury about matters
beyond his personal knowledge on behalf of his clients that "I am disgruntled plaintiff who doesn't
want to pay the child support..." as if his biased opinion is fact. In Fritts v. Krug, 92 NW 2d 604
(1958) Supreme Court of Michigan eloquently stated about disgruntled litigant:
A "void" judgment, as we all know, grounds no rights, forms no defense to actions
taken thereunder, and is vulnerable to any manner of collateral attack (thus here, by
habeas corpus). No statute of limitations or repose runs on its holdings, the matters
thought to be settled thereby are not resjudicata^ and years later, when the
memories may have grown dim and rights long been regarded as vested, any
disgruntled litigant may reopen the old wound and once more probe its depths. And
it is then as though trial and adjudication had never been."
29. In the same spirit of Nunberg's false testimony and intentionally fallacious arguments, I
should rebut his fallacy with mine, "Because I want to win this case, the judge should side with me
— not Levoritz and Katkalov who brazenly denied my material allegations. Defendants made
denials because they don't want to pay me for my injuries so I can pay my child support.
Therefore., this court should summarily strike their answers. Then I will be able to pay my child
support from the award I will collect from the defendants"
3 0. Here is a jewel of logical fallacy by Levoritz from Ms affidavit in instant case and appeal to
judge as brethren member of Bar Association:
"Remarkably, after the Family Court issued that ruling, Plaintiff contemptuously attempted
to have the Judge recused claiming that the Judge was biased in favor of Ms. Svenson."
31. Is plaintiffs motion for recusal a crime? Is this motion lawfully warrants dismissal of this
third-party complaint? How relevant is this statement to the issues of defendants' perjuries? Mr.
Levoritz is simply saying, wink-wink, "How dare this pro se slave demand equal treatment that
belongs only to lawyers? Get him Judge."
32. All participating in this case attorneys expect this judge to "cutme off without hearing" and
make all other plaintiffs motions, arguments and evidence moot. The Plaintiffs case is winning,
backed by witnesses and substantiated by multiple documentary exhibits, which, should be entered
into evidence.
33. I challenge every statement, affidavit, affirmation and order of defendants as perjury and
fraud upon the court. Therefore, any fact taken from such documents exhibited in their motions or
arguments does not deserve this court's presumption in favor of defendants as per Atlantic Capital
Realty v Cayuga Capital Mgt., LLC (2014 NY Slip Op 02733):
" On a motion to dismiss the complaint pursuant to CPLR 321 l(a)(7) for failure to
state a cause of action, the court must afford the pleading a liberal construction,
accept all facts as alleged in the pleading to be true, accord the plaintiff the benefit
of every possible favorable inference, and determine only whether the facts as
' alleged fit within an}r cognizable legal theory (see Felix v Thomas R. Stachecki
Gen.Contr., LLC, WAD36.664;Breytmanv Olinville Realty, LLC,54AD3d703,
34. The burden of proof that I had full and fair opportunity to litigate Supreme Court's action is
on the defendants. During last hearing, attorney Ratner attempted to testify about what happened
during Supreme Court action, which was beyond her personal knowledge, and-fherefore she lacked
competence to testify. All she did, was she showed the Judge the void order of judge Bemadette
Bayne, which I challenge. This void order—which Ratner called do cumentary evidence—by itself,
does not conclusively prove that it is not void under requirement of CPLR 321 l(a)(l). In. Atlantic
Capital Realty v Cayuga Capital Mgt., LLC (2014 NY Slip Op 02733) the court stated:
"A motion pursuant to CPLR 3211 (a)(l) to dismiss a complaint on the ground that a
defense is founded on documentary evidence may be appropriately granted only where the
documentary evidence utterly refutes the plaintiffs factual allegations, conclusively
establishing a defense as a matter of law" (Parkoffv Stavsky, 109 AD3d 646, 647; see
Goshen v Mutual Life Ins, Co. ofKY., 98 NY2d 314,326; Benson v Deutsche BankNatl
Trust, Inc., 109 AD3d495,497).
35. If this Honorable Court decides to rely on statements and facts derived from affidavits,
affirmations, denials and exhibits of defendants and summarily dismiss my complaint -1 object
and demand discovery, evidentiary hearing and/or trial on motion's issues for the purpose of an
impeachment per CPLR §2218. In addition, I reserve my right to amend my complaint per CPLR
3025 based on the discovery of evidence in defendants3 possession per CPLR §2214(c).
ARGUMENT II: the answer, motion to dismiss, affirmation, and affidavits of defendants
Levoritz and Katkalov should be stricken for perjury and fraud upon the court
3 6. Annexed hereto, as Exhibit B is their answer. To rebut their brazen denials of averments in
my complaint, I attached as Exhibit I, my FIRST NOTICE TO ADMIT with exhibits, which I
Offer of Proof of documentary evidence in support of my third-party complaint and fully
incorporate by reference herein.
37. I will not bore this Honorable Court with their denials such as averment in my complaint f
24, "At all times mentioned herein, Law office of Yonatan S. Levoritz P.C. derived substantial
revenue from trade or commerce in the County of Kings and the State of New York." If that were
not true however, why would they keep an office in Kings County? Or with myriad of frivolous
denials of my averments that addressed to other defendants.
38. Starting from ^ \9— 39, defendants denied any knowledge of me having a credit card,
even though I went on the record and told defendants Fasone and Levoritz that Svenson has stolen
my credit card "bills and that I use credit cards for my renovation. Exhibit 2 - Subpoena to the
Citibank clearly demonstrates my point that the defendants knew about my credit card.
39. In f32 of my complaint I aver, "Additionally, during child support proceedings Kricheysky
notified all of the defendants on the record that he has a credit card and that Svenson stole all of his
bills --which. Svenson immediately did not deny." Moreover, Fasone declared, "I don't care let
him go to police" - while Levoritz confirmed the fact of theft, but commented to Fasone, "Judge
they lived together."
40. Levoritz and Katkalov denied 1 41 of my complaint where I aver, "at all relevant times
during the child support proceedings, Svenson and Levoritz caused false and penurious financial
disclosure affidavits filed in court and falsely testified in court." As can be seen from my FIRST
NOTICE TO ADMIT and its Exhibits 5 and 6, PRE-FATHER ABANDONMENT and
POST-FATHER ABANDONMENT, these affidavits are gross exaggerations, cannot withstand
simple mathematical scrutiny and logically fallacious. According to exhibit J, Bill from TRS to
Svenson she owes $132,082.60 as of November 10,2008 -approximately the time of preparation
of her POST-FATHER ABANDONMENT disclosure affidavit However, Levoritz and Svenson
listed in said POST-FATHER ABANDONMENT affidavit debt to IRS is $300,000. This is not a
clerical mistake because Levoritz and Svenson also testified that debt to IRS is $300,000, which is
due to my financial machinations.
41. This is what my attorney, Daniel Singer, eloquently said about defendants' testimony in
reply affirmation, Exhibit B3, page3-4:
"Petitioner is again outright lying to this Court in claiming that Respondent is
spending "$178,020.00 per year or $14,835.00 per month"
Respondent makes clear in his Financial Disclosure Affidavit (Exhibit
"A", hereto) that he is not spending $14,835.00 per month. Rather, these are merely
his monthly expenses which he is unable to pay on his weekly salary of $1,000.00.
More than $10,000.00 of these monthly expenses are for mortgage payments which
are not being paid due to Respondent's financial hardships. Indeed, as a result of
these multiple mortgages, Respondent has liabilities in excess of 1.6 million.
Contrary to Petitioner's allegations, Respondent is by no means living a luxurious
Indeed, foreclosure proceedings have been commenced with respect to the parties'
property having an address of 120 Oceana Drive West, Apt 5D, Brooklyn, New
York (Exhibit "B" hereto).
Moreover, the bank is repossessing Respondent's automobile. (See Respondent's
Reply Affidavit)
As Respondent sets forth in his Financial Disclosure Affidavit in support of his
application for a variance in the statutory child support percentages, "my debt is i
1.6 million vs. income less than 4K per month. I am technically a bankrupt"
Moreover, your affirrnant is perplexed as to how Petitioner's counsel
possesses a sufficient degree of misinformation regarding Respondent's
finances (including misinformation regarding his purported car and
renovation expenses) as to set forth same in an affirmation under penalty of
perjury, without any documentary evidence regarding same!
Clearly, the motivations of Petitioner and her attorney are not to determine child
support Rather, as set forth in Respondent's accompanying affidavit, they are to
harass Respondent."
42. As my attorney, Daniel Singer, demonstrated their testimony and affidavits were baseless,
false and therefore perjury and fraud upon the court by officers of the court. These total
exaggerations were necessary in order to conveniently argue that I am hiding assets.
43. Levoritz and Katkalov brazenly denied knowledge of ^ f 43 where I stated that I b ecame
unemployed. I served on Svenson petition for modification, which is defendants' notice that I
became unemployed.
44. Levoritz and Katkalov brazenly denied ^ 51, 52 and 5 8 where I stated that I had valid
contract with LEON CONSTRUCTION and even knowledge of that contract Exhibits 3 and 4 -
Subpoenas that defendants served on LEON CONSTRACTION and CONSELA
ENGINEERING, P.C. is proof that they perjured themselves by denying ^ 51, 52 and 58 of my
third-party complaint
45. Levoritz; and Katkalov brazenly denied ^ 64 of my complaint even though only Svenson
has firsthand knowledge. This paragraph says that I offered Svenson mediation 6 months before
the litigation in Firmly Court. At that time, defendants were not even retained.
46. Defendants brazenly denied 1 72, which stated that they did not produce a timely reply to
my custody and visitation petition-1 challenge them to produce their timely reply and enter it into
the record.
47. Defendants brazenly denied ^ 73, where I stated that they did not produce a timely reply to'
my modification petition. I challenge them to produce their timely reply and enter It into the
48. However, defendants filed petition to punish me for contempt of Fasone's void order,
Exhibit 7.
49. In reply, I filed cross-motion for sanctions, Exhibit 8, by which I notified defendants once
again that I lost my j ob, that I collect $405 per week in unemployment insurance and that they have
no probable cause to file contempt petition. Additionally, in my statement of fact, I describe their
harassing subpoenas served on my contractors, and to deny knowledge that I had contractors is
egregious conduct deserving suspension of the law license.
5 0. Even though defendants, once again, were notified that I lost my j ob and receive
unemployment insurance, defendants continued their malicious prosecution. That defendants'
egregious conduct caused me to suffer a stroke on November 2,2010.
51. Defendant's Levoritz affidavit in support of his motion to dismiss my thrrd-party
complaint, Exhibit K - Is perjury. To demonstrate my point and impeach Levoritz, I will discuss
the ^[ 18 of his perjurious affidavit and I quote:
"In addition, plaintiff served, but apparently did not file, a sanctions motion against
me in the Family Court action."
52. This statement is very telling. I can draw an inference that Levoritz admitted that he was
served, but never replied to that cross-motion and that there was never a hearing scheduled in
Family Court. Accordingly, Levoritz and I never appeared for the hearing on said cross-motion.
However, as I demonstrate in my Exhibit 8, cross-motion for sanctions -1 served on Levoritz and
filed that cross-motion in court on My 12,2010. Accordingly, this statement of Levoritz in instant
affidavit is perjury and one more proof of conspiracy between Fasone and Levoritz to railroad me.
Conspiracy, which I describe in my third-party complaint.
53. In reply to Levoritz contempt petition, I also produced and served on Levoritz my answer
with counterclaims and discovery demands, Exhibit 9. As usual, defendants ignored it and sent no
reply to me.
54. How did Fasone react to such constant egregious violations of CPLR and my constitutional
rights to due process? He looked the other way and covered it up.
55. However, nowhere in instant affidavit of Levoritz under oath, except the hypocrisy that he
is "success" (thanks to Fasone), has Levoritz stated that he did not He and information he entered in
those two (Exhibit 5 and 6, PRE-FATHBR and POST-FATHER ABANDONMENT) affidavits
correct. Levoritz has not stated that information in any of his Family Court affirmations correct
Overall, this affidavit is replete with misinformation instead of rebuttal of facts in my complaint.
For example, in ^[ 19 he writes:
"... To the extent I obtain legal relief from the court against Mr. Krichevsky, it was
fully justified from Ms wrongful behavior and if he cannot pay his bills due to a
judgment rendered by Supreme Court of New York against him that is not my
56. Nowhere in instant affidavits or affirmations in any court has Levoritz stated facts
backed up with any kind of admissible evidence proving "my wrongful behavior" or stating
what exactly I did wrong.
57. To read Mr. Nunberg's and Mr. Levoritz' (2 pounds of paper) of logically fallacious
statements in summary I would say, "So what, Svenson and Levoritz lied under penalty of perjury
to Fasone? So what, Fasone pretended that he believed their lies? Fasone gave defendants the legal
relief against Mr. Krichevsky to fulfill his duty, and therefore defendants' lies are not lies. And if
this relief is not fair to Krichevsky, it's not Levoritz' problem -1was not his lawyer. So what,
Krichevsky cannot pay -it's not my problem. I "succeeded," therefore I am hero, and therefore
everything I did was kosher and not lies, and therefore I fulfilled my Attorney's duty to the Court,
Public and Krichevsky's child. So what his child is not getting the child support I have won,
because I got Krichevsky fired, gave him stroke and he could not sell his house? I am immune. I
got paid by Svenson to get an order at any cost, and if Krichevsky cannot pay -"screw" the
child, Krichevsky and Svenson -now it's their problem." To put it bluntly, Nunberg and
Levoritz shamelessly admit -although corruptly, Levoritz "succeeded," and that is the only thing
that matters, therefore the plaintiffs third-party complaint must be dismissed.
58. Defendants' Levoritz and Katkalov answers, affidavits with misinformation under oath in
their motion to dismiss my third-party complaint, misleading affirmation of Mr. Nuiiberg under
penalty of perjury with misleading memorandum of law, which does not apply to me as apro se
litigant and/or to facts of my third-party complaint is brazen attempt to bamboozle this Court Yet,
this is defendants' second attempt to bamboozle the Plaintiff out of remedy -with logically
fallacious arguments and lies.
"WHEREFORE, it is respectfully requested that this motion be granted in its entirety, and
for such other and further relief as to this Court seems just and proper, including the costs of this
Sworn to before me this
day of May, 2014
N O T ARY PUBLIC, State of NwYork
N o.DtAS6082200
QMtlf!»d In King* Cou nty
Committlon Sx p lra* J u ly 30,2017

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