UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK
SUZANNAH B. TROY
v.
CITY OF NEW YORK, ET AL.,
Commissioner Raymond Kelly, NYPD,
Chief Charles Campisi, IAB, DI Ed Winski,
Lt. Angelo Burgos, Sgt Chen, IAB Sgt
Mary O’Donnell, Lt. Agnes of The Integrity
Unit, Det John Vergona, Det Andy Dwyer

13 Civ. 5082 (AJN) (GWG)
PLAINTIFF’S OPPOSITION TO
DEFENDANTS’ MOTION TO DISMISS
PURSUANT TO FED. R. CIV. P. 12(B)(6).

PLAINTIFF’S OPPOSITION TO DEFENDANTS’ MOTION TO DISMISS THE COMPLAINT PURSUANT
TO FED. R. CIV. P. 12(B)(6)
Suzannah B. Troy
Pro Se Plaintiff

“Justice too long delayed is justice denied.” Dr Martin Luther King Jr.
I swear to uphold The Constitution.... NYPD Oath, an excerpt
No person shall be denied the equal protection of the laws of this state or any subdivision thereof. No person shall, because
of race, color, creed or religion, be subjected to any discrimination in his or her civil rights BY ANY OTHER PERSON
OR BY ANY FIRM, CORPORATION, OR INSTITUTION, OR BY THE STATE OR ANY AGENCY OR SUBDIVISION
OF THE STATE. 14th Amendment
From the NYPD IAB Retaliation Section: I gave mayor Bloomberg, the NYPD , Internal Affairs , SAIC and HP a black
eye. The NYPD IAB were sending me, a whistle blower, a message when Delita Hooks yelled at me, I will slap the crap
out of your ass, and landed a running punch to my eye as I held my bags and my phone--my arm numb from two
injections.... More than violating my first amendment rights, they wanted to silence me. Det. Vergona spoke to me as if I
were a criminal. He told me not to contact him or Delita Hooks, in so many words to shut up and keep my head down.
Reminder: the mayor gave Commish Kelly free rides on Air Bloomberg. Why do I have to wait four days (19 days after
being attacked) to be falsely arrested on Saturday? Arrest the Jew on the Sabbath? Are you Anti-Semitic? No response
from Det. Vergona, who was aware I have a collapsed bladder (not from the assault) and serious damage to both my
cervical spine and my eye, which turned out to be a detached retina .The first day we spoke, on Oc.t 4, Det. Vergona said,
“I don’t care if you have two black eyes. Stop your babbling. Commish Kelly, Air Bloomberg the only way to travel.
“Coercion ia a crime, not a policing tool.” Suzannah Troy, Det Vergona coerced me to drop charges Sat. Oct. 20. 2012
Oct 6, 2012: “Fight Picking C-word” forwarded cyber attack, alleged aggravated harassment by sock puppet “lawyer”
possible witness tampering to Det. Vergona, Sunday night after savage attack trying to heal. No response from Det. Vergona,
but “lawyer” immediately deleted account when I notified him “gender hate crime” reported to Google YouTube. Oct. 4, 3 days
after the attack, Det. Vergona became abusive at the same time the first YouTube abuse cyber abuse began falsely blaming me,
and continued for 10 months blaming me, the victim. When I filed the lawsuit against the NYPD and IAB, the alleged
aggravated harassment stopped. Yet IAB refused to believe that the NYPD had anything to do with this, even with two YouTubes
removed: “Det. John Vergona, Delita Hooks Assault, False Cross Complaint, no arrest” was removed just before Passover and
Passover miracle, despite being wrongly flagged for “bullying and harassment”, I unrelentingly emailed Google, stating that it
was a human rights violation as well as evidence of a crime. The video proves I was assaulted and that her cross complaint is
false. I got my both my videos back and an apology from Google YouTube. Suzannah B. Troy Artist

Page 4 of this Motion to not Dismiss begins the table of contents with “highlights” in each section as to
why this case should not

be dismissed. Thank you. (I refer to my Dad page 10 Judaism page 44 )
-----------

My Father died on the Sabbath, Nov. 2, 2013, much like Oct. 20th, 2012, the Sabbath I agreed to
come in and be “false arrested” because I would not drop the charges; Det John Vergona yelled at
me: You are going to drop those charges or I am arresting you! I was devoted to my Father and it
was a 7 day a week commitment including the Sabbath which required phone calls and even emergency
repairs because the house like his heart was wearing down. Ron Kuby explained Det Vergona wanted to
punish me and put me through the system. I had a hole in my retina, floaters, cervical damage, a neck
brace, pain killers, a result of Dr Fagelman’s receptionist Delita Hooks’ savage attack that Det Vergona
was in process of false arresting me for. Det Vergona knew I have a collapsed bladder (not from the
assault) but he wanted to inflict even more suffering on me, the victim of an attack at a doctor’s office.
Det Vergona’s refused to explain why I had to wait 4 days until the Sabbath to be false arrested. Arrest
the Jew on the Sabbath? Are you anti-Semitic? Det Vergona refused to answer as he continued to
violate my 14th Amendment rights treating me with bias, prejudice and malice (like a Jew in the Early
Stages of Nazi Germany) as he openly committed the crime of coercion despite me alerting DI Ed Winski
via a note, I am to be false arrested on Saturday, I want you to be there, attached to the envelope NYPD
Hero Lt Giuseppie Petrosino’s memorial pin w/ his badge number #285. Lt. Petrosino was murdered in
Italy murdered by the Black Hand in 1909 I wrote please give this pin to Commish Kelly and I asked DI
Ed Winski. Ms. Nam implies in her motion I didn’t speak up about being coerced until after the fact, but
this powerful gesture occurred Oct. 16, the day I agreed to be false arrested twice and when I handed in
this note no one at the Precinct was willing to arrest me on the spot for some reason. To date I have no
idea if Delita Hooks was alerted to turn herself in on Oct. 16 and than Oct 20 as I agreed twice to be false

2
Justifying references: commissioner Ray Kelly’s free rides Mr. Kerik’s relates to helicopter rides

page 35 lawsuit suggesting uses/abuses emulating Mr. Kelly NYPD icon take what you can when u
you can culture Rudin references in lawsuit minus his name + photo w/ Rudin protest sign I am
wearing when attacked omitted in motion to dismiss. Gartner employe John Doe page 25 lawsuit
Serpico references page 36 lawsuit Knapp synonymous

arrested with Det Vergona using her false cross complaint a serious crime on both their parts. Ms Nam
makes Delita Hooks” Detectives “non existent” in her motion to dismiss. Why?

Before my Father’s death, I requested mediation, but now I am asking to move to trial so I can question
all the defendants under oath to see if they are willing to commit perjury when I show them the video of
me being savagely attacked by Dr. Andrew Fagelman’s receptionist/office manager Delita Hooks, her
false cross complaint - also a serious crime, Ron Kuby’s letter which is short hand for me being coerced stating I
drop the charges against my attacker if my attacker drops the charges in contrast to Delita Hooks letter threatening to
file yet another (false) cross complaint if I dare to come back and press assault charges. Kuby comes as close to
saying coerced as possible.

I had basic Human Rights, Patient Rights and Constitutional Rights to get medical care and not have
them violated and be savagely attacked hit with an Iphone, shoe, a key, my hair ripped out, running punch
to my eye and than I had the right to report Assault without being coerced to drop the charges as well as
turned away when I attempted to report Delita Hooks’ false cross complaint (Lawsuit Page 42 Prof Eterno
PhD, said egregious I was turned away), that was obvious to any honest NYPD officer; I had the right to
report alleged hate crime by Det Vergona and not be turned away. The NYPD violated my rights as laid
out clearly in my lawsuit. I allege that Det Vergona’s verbal violence, threats and a 4 day delay to false
arrest me, fall under the United Nations Convention against Torture with the goal to punish, intimidate
and coerce me to drop charges. See Page 45 of my lawsuit.

I am filing 2nd degree assault charges in 2014 with the new police commissioner and the new head of
Internal Affairs that I hope actually have integrity. I will be asking for Det John Vergona’s arrest as well

3
Justifying references: commissioner Ray Kelly’s free rides Mr. Kerik’s relates to helicopter rides

page 35 lawsuit suggesting uses/abuses emulating Mr. Kelly NYPD icon take what you can when u
you can culture Rudin references in lawsuit minus his name + photo w/ Rudin protest sign I am
wearing when attacked omitted in motion to dismiss. Gartner employe John Doe page 25 lawsuit
Serpico references page 36 lawsuit Knapp synonymous

as all NYPD IAB involved in covering up the crime of coercion and alleged “fabrication of
evidence.” (See page 36 of my lawsuit my call to retired Honorable Judge Mollen) It should be noted I
am working hard to get a New Commission in to NYPD and Internal Affairs Corruption and because of the
research I did for my retaliation section I am asking for scrutiny of retired NYPD and contractors, banks,
billionaires, “oligarchs of New York, etc that employ them so Mr. Kelly’s future employers and even “free
rides” (see my lawsuit page 35 ”mishandling police corruption...helicopters, etc. perhaps a cue from Mr
Kelly’s free rides) for example would come under scrutiny possible so my commission and or permanent
outside monitor and this would be ground breaking with an emphasis on Internal Affairs role as never
exposed before in the history of the NYPD and the role of “employers” of retired NYPD that call
themselves consultants but I question if they are really providing fixing and favors see my lawsuit page 29
when I speak with Detective Del Pozo - I don’t explain in the lawsuit but that was what the conversation
on page 29 when I call wondering why Delita Hooks has not been arrested and why I haven’t heard from
Det John Vergona. I tell Det Del Pozo about me witnessing a retired NYPD commander attempted to fix a
ticket for a Rudin Flunkie (Rudin referenced not by name page 15 lawsuit “hospital” protest), this retired
commander is on Bill Rudin’s payroll and I reported it to DI Del Pozo. The lawsuit sites fixing for (page
30 lawsuit) The Mercer Hotel as well and years after reporting to IAB the Mercer Hotel uses the loading
and unloading as private parking with valet service the practices continue on.
I am asking this case not be dismissed because the lawsuit and the motion are compelling and for my
case to move forward to a trial giving me subpoena power and the ability to hold the defendants
accountable under oath.

4
Justifying references: commissioner Ray Kelly’s free rides Mr. Kerik’s relates to helicopter rides

page 35 lawsuit suggesting uses/abuses emulating Mr. Kelly NYPD icon take what you can when u
you can culture Rudin references in lawsuit minus his name + photo w/ Rudin protest sign I am
wearing when attacked omitted in motion to dismiss. Gartner employe John Doe page 25 lawsuit
Serpico references page 36 lawsuit Knapp synonymous

1)

Preliminary Statement page Page 12 - 14

2)

Brief Statement of Facts Page 14 - 20

3)

PLAINTIFF’S OPPOSITION TO DEFENDANTS’ ARGUMENTS Page 19 -41

4) Evidence Section: P 42 -49, continues page 217- 232 Some highlights page number email to
Det John Vergona I contacted the DA Oct 16, 2012 cc: Commish Kelly’s Det Brown Community
Affairs LGBT Det Duffy
The Video of Savage Assault - repeated violation of my patient rights and body, audio NYPD PO Migori
turning me away telling me I cannot report a false cross complaint because I am not a detective or from
the DA which is not true and a violation of my Constitutional rights, audio of IAB Sgt Mary O’Donnell
calling me because the Commission to Combat Police Corruption has forwarded my email to them and in
her own voice you can hear her in my opinion the “poster girl for the Blue Wall of Corruption” case closed
unwilling to listen to me so I tell her to not contact me, medical reports proof of a hole in my retina,
cervical damage and many emails including one giving Det Vergona hell for coercion before I drop
charges refuting Ms. Nam implying I didn’t speak up prior to being coerced to drop charges. The email
includes NYPD at One Police Plaza including Det Brown in Commissioner Ray Kelly’s office and LGBT
Det Duffy One Police Plaza. There are many emails and faxes so the evidence section is large and
continues after the Conclusion Section. It should be noted I am “straight” but have been gay bashed and
participated in LGBT Equality protests hence my emails including NYPD LGBT Det Duffy.
5)

Fabrication of Evidence Page 49 - P88

6)

Proof of Coercion Page 89- 92

5
Justifying references: commissioner Ray Kelly’s free rides Mr. Kerik’s relates to helicopter rides

page 35 lawsuit suggesting uses/abuses emulating Mr. Kelly NYPD icon take what you can when u
you can culture Rudin references in lawsuit minus his name + photo w/ Rudin protest sign I am
wearing when attacked omitted in motion to dismiss. Gartner employe John Doe page 25 lawsuit
Serpico references page 36 lawsuit Knapp synonymous

7)

Coercion is a Crime Not a Policing Tool Page Page 92-97

8)

NYPD Watching the Video takes the NYPD out of the Contect of not obligated to investigate
crime to “witness of a crime Page 97 -102 HIghlight: Mr. Kelly is a civilian so when I handed him
the Justice Card referring him to the video and the false cross complaint I allege he is not protected as
his subordinates in the NYPD from a federal ruling protecting NYPD from the obligation of
investigating. Also IAB watched the video and they are obligated to take action and I allege they did
not.

9)

Evidence for my case in Ms. Nam’s Motion to Dismiss Page 102- 133 Highlights: Ms Nam’s
motion to dismiss highlights that I expressed fear for my safety, shares a fabrication in Det
Vergona’s notes that I said we tussled to the ground. I never said that. I never touched the ground.
Ms. Nam omits Det Vergona’s telephone conversations from Oct. 4 in the afternoon,-- a series of
telephone calls punctuated with emails I sent him or did he?
Oct 4, 2012 9:35 am Det Vergona or his lawyer omit an email with a striking photo of me before the

assault. I have Mae West cleavage and underneath it a sign that gives “Rudin” hell (sign referenced page
7 of lawsuit) stating he is killing us literally with no Trauma Level 1 Hospital. The photo shows me looking
beautiful. I don’t look and feel beautiful any more because of this assault and trauma including that from
the NYPD and IAB. The photo shows a sign that may have equated me with OWS, (OWS lawsuit
referenced page 39, 51) but also links me to IAB complaints and a conversation I had with Det Del Polzo
first Precinct telling him what I told DI Delpozo of the 06 Precinct that I caught a retired NYPD commander
trying to pressure an NYPD officer from the 06 to fix a ticket for a Rudin flunkie. See Retaliation Section.
The email page 2 of the evidence section states “I am not a great beauty but I felt beautiful and happy.
Was in a great mood when I saw Dr Vine.

6
Justifying references: commissioner Ray Kelly’s free rides Mr. Kerik’s relates to helicopter rides

page 35 lawsuit suggesting uses/abuses emulating Mr. Kelly NYPD icon take what you can when u
you can culture Rudin references in lawsuit minus his name + photo w/ Rudin protest sign I am
wearing when attacked omitted in motion to dismiss. Gartner employe John Doe page 25 lawsuit
Serpico references page 36 lawsuit Knapp synonymous

You also see my blog address under the photo and I was blogging about when are the NYPD Heroin
Rape Cop going to jail. Why was this beautiful photo omitted either by Det Vergona or Lt Agnes or his
lawyer? See page 1 of the evidence section in the very back.
Series of emails and calls Oct 4 omitted include phone records with all calls Det Vergona and or lawyer
omitted plus emails.
email Oct. 7, 2012 Asking Det Vergona re: Confrontative “C/nt” calling lawyer is this witness tampering in
the email re: to threaten to turn the tables on me and notify him the “lawyer” closed his YouTube account.
No response.
Oct 17 email G-d Sees All evidence section at the very end of the motion page 25b one of many
emails proving I was extremely upset about Det Vergona false arresting me threatening me -- this email a
must see. cc: Community Affairs Det Brown in Commish Kelly’s office and LGBT Det Duffy.
email Wed Oct 17, 2012 Subject: I am to be falsely arrested Saturday unless I drop charges

If Det Vergona did not include all the telephones calls, the emails, and what we discussed than I am
alleging he omits key evidence, where he repeatedly refuses to meet with me to see the injuries to my
eye. I allege this is a dereliction of duty and negligence if he did omit calls on Oct 4 and Oct 16th. I
have the phone records to prove the calls and I am alleging he left out or Ms Nam omits refusing to meet
me and that Det Vergona said he did not care if I had two black eyes. Ditto for Oct 16, 2 key phone
calls where he lost control and yelled at me,

If you don’t drop charges I will arrest you.
7

Justifying references: commissioner Ray Kelly’s free rides Mr. Kerik’s relates to helicopter rides

page 35 lawsuit suggesting uses/abuses emulating Mr. Kelly NYPD icon take what you can when u
you can culture Rudin references in lawsuit minus his name + photo w/ Rudin protest sign I am
wearing when attacked omitted in motion to dismiss. Gartner employe John Doe page 25 lawsuit
Serpico references page 36 lawsuit Knapp synonymous

Where are the DD5s for the 2 phone calls where I agree to be arrested and ask why I have to wait
4 days until Saturday. Why, arrest the Jew on the Sabbath? Are you anti-Semitic? Where the
DD5s. I have the phone records.

He is suppose to investigate without bias but clearly he

was biased and he did not do a proper investigation. What little he did with bias was a violation of
my 14th amendment rights and Det Verogna actually committed serious crimes: coercion and I
allege fabrication of evidence. He did not work alone and Ms. Nam omits all of Det Dwyer’s notes
on Ms. Hooks, which again evokes the need for a trial so I can subpoena files and question all
involved under oath. Ms Nam further implicates Lt Burgos who opens my file for 22 hours and closes
the case. Lt Agnes closes the case despite overwhelming evidence I was the victim and there was no
mutual assault. Ditto for IAB Sgt Mary O’Donnell . We can listen to the audio where we can hear her
refuse to listen to me and say the closed which is why I perceive her as corrupt and do not want to talk to
her ever again despite Ms. Nam’s dismissal of my dismay at an Internal Affairs officer’s unwillingness to
investigate coercion which I refer to as “The Blue Wall of Corruption”. Mr. Kuby’s letter is short hand for
coercion, his goal to get me out of the clutches of Vergona + that are ignoring key evidence as IAB
continues to do so not interviewing me on coercion at all. Kuby worried about my health. January, 2014 I
contact the new police commissioner and the new head of Internal Affairs to have Delita Hooks arrested
and ditto for the NYPD involved in coercing me starting with Det John Vergona. I am an open critic of Cy
Vance who I allege protects the NYPD’s corrupt dealings with the Michael Premo case (page 51 lawsuit)
as just one example. It should be noted I am working hard to get a (page 35 lawsuit) New
Commission in to NYPD and Internal Affairs Corruption and because of the research I did for my
retaliation section I am asking for scrutiny in to retired NYPD and contractors, banks, etc that
employ them so Mr. Kelly’s future employers and even “free rides” for example would come under
scrutiny so a new commission would be ground breaking with an emphasis on Internal Affairs
role as never exposed before in the history of the NYPD and the role of “employers” of retired
NYPD as well as retired consultants but I question if they really providing fixing and favors

8
Justifying references: commissioner Ray Kelly’s free rides Mr. Kerik’s relates to helicopter rides

page 35 lawsuit suggesting uses/abuses emulating Mr. Kelly NYPD icon take what you can when u
you can culture Rudin references in lawsuit minus his name + photo w/ Rudin protest sign I am
wearing when attacked omitted in motion to dismiss. Gartner employe John Doe page 25 lawsuit
Serpico references page 36 lawsuit Knapp synonymous

because for instance, I allege Dr Fagelman made calls and got “help”. I am asking this case not
be dismissed and the lawsuit and the motion are compelling for my case to move forward to a trial
giving me subpoena power and the ability to hold the defendants accountable. to investigate
despite The Commission Combat Police Corruption forwarding my email to Sgt O’Donnell and she
says case closed, etc.
10)

Conversations with Ms. Nam P133-140 Highlights: Ms Nam tells me Delita Hooks (false) cross
complaint is sealed (less than a year.) Ms Nam tells me I have no case. There was no assault so they
could turn me away from reporting Delita Hooks’ false cross complaint. I tell her the audio recording
refutes her statement. I am turned away and prevented from reporting a crime which the NYPD is not
allowed to do. Auido: I am told I can’t report the crime because I am not a detective or DA. This is on
an audio recording I posted on YouTube. Ms Nam says there is no assault and the case is closed so I
go to the precinct to report Assault in the 2nd degree since the NYPD coerced me to drop assault in
the 3rd degree. The NYPD violated my rights yet again . I call Ms Nam to tell her the case is open
almost 1 year to the date I was attacked and I was not allowed to upgrade the assault charges. Ms
Nam demands the officer’s badge numbers and I cooperate vs Ms Nam will not give me a response to
a note I sent her clients via her where I demand my case me moved out of the hands of the Det Squad
that coerced me to Chief Pulaski’s Det Squad One Police Plaza. I contact Chief Pulaski via Fed Ex.
Only silence so I have no idea to date if my case is still open but I do know IAB and the NYPD have
not done their job because Delita Hooks has not been arrested for assault and a false cross complaint,
and Det Vergona and Lt Burgos have retired rather than face the consequences for their actions along
with everyone else involved. IAB is required to investigate corruption and they let Vergona retire
instead of arresting him.

11)

The NYPD and Internal Affairs Retaliation List Against Suzannah B. Troy
Whistleblower Page 140 -163
9

Justifying references: commissioner Ray Kelly’s free rides Mr. Kerik’s relates to helicopter rides

page 35 lawsuit suggesting uses/abuses emulating Mr. Kelly NYPD icon take what you can when u
you can culture Rudin references in lawsuit minus his name + photo w/ Rudin protest sign I am
wearing when attacked omitted in motion to dismiss. Gartner employe John Doe page 25 lawsuit
Serpico references page 36 lawsuit Knapp synonymous

12) Internal Affairs’ History of Corruption (Including My Case ) P164- 178 I allege I
got the Serpico treatment from NYPD and IAB -- they didn’t plan on me getting
punched and kicked etc but the message they sent me is I got what I deserved and
shut up stop blowing the whistle on IAB, NYPD etc.
13) Economic Racism and the NYPD (including my case) Page 178 - 186 If we move to trial I can take
what was done to me and call Adrian Schoolcraft, Prof Eterno, and many others including victims of
NYPD to underscore the Bloomberg Kelly policing policies that prove the worst kind of bias and
violations of the Constitution. The NYPD fix crimes like a Las Vegas Casino(front page of my lawsuit) .
The NYPD sell the lie crime is down to help push real estate development, mass displacement and to
bring big contractors in to do business many I expose from my blog that I allege they are overbilling us
like SAIC and HP (lawsuit page 5) I allege are “cozy” with the NYPD and I allege make sure retired
NYPD profit by securing them as “consultants” or advisors for Gartner Group (John Doe in my lawsuit)
who saw “no evil” with HP’s role in 911 Tech mess which I dubbed The Tax Payer’s Titanic. Please see
Retaliation Section.

14) NYPD are Not allowed to Turn People away From Reporting Crimes Page 186- 188Det
John Vergona’s supervisor Sgt Chen -- I have phone records Nov. 20 , 2012 9:11 2 min call I
am told he is changing in to his uniform Nov. 20. 9:24 10 min conversation -- he is rude and
mocking but agrees I have a right to report Delita Hook’s false cross complaint yet I have
audio proof of his involvement with PO Migori turning me.
10
Justifying references: commissioner Ray Kelly’s free rides Mr. Kerik’s relates to helicopter rides

page 35 lawsuit suggesting uses/abuses emulating Mr. Kelly NYPD icon take what you can when u
you can culture Rudin references in lawsuit minus his name + photo w/ Rudin protest sign I am
wearing when attacked omitted in motion to dismiss. Gartner employe John Doe page 25 lawsuit
Serpico references page 36 lawsuit Knapp synonymous

15)

NYPD Culture of Misogyny and The First Precinct page 188-191

16)

Failure to Supervise Page 191 - 195

17)

Conclusion 195 - 216

18)

Evidence Section continued 216- 232

PRELIMINARY STATEMENT
On July 22, 2013, Suzannah Troy, proceeding pro se, filed the instant lawsuit and jury
demand against the City of New York (“City”), Commissioner Raymond Kelly (“Kelly”), New
York City Police Department (“NYPD”), Internal Affairs Bureau (“IAB”), Chief Campisi
(“Campisi”), New York City Police Department (“NYPD”), Deputy Inspector Ed Winski
(“Winski”), NYPD Lieutenant Angelo Burgos (“Burgos”), NYPD Sergeant Chen (“Chen”),
NYPD Detective John Vergona (“Vergona”), Detective Andy Dwyer (“Dwyer”), IAB Integrity
Unit Lieutenant Agnes (“Agnes”), and IAB Sergeant Mary O’Donnell (“O’Donnell”), in their
official and individual capacities, for their numerous and egregious violations of plaintiff’s
constitutional rights.
The complaint alleges the following causes of action: (1) deprivation of plaintiff’s rights
under the United States Constitution through 42 U.S.C. §1983; (2) failure to intervene under §
11
Justifying references: commissioner Ray Kelly’s free rides Mr. Kerik’s relates to helicopter rides

page 35 lawsuit suggesting uses/abuses emulating Mr. Kelly NYPD icon take what you can when u
you can culture Rudin references in lawsuit minus his name + photo w/ Rudin protest sign I am
wearing when attacked omitted in motion to dismiss. Gartner employe John Doe page 25 lawsuit
Serpico references page 36 lawsuit Knapp synonymous

1983; (3) retaliation under the First Amendment; (4) threats of lodging false charges in violation
of plaintiff’s due process rights under the Fifth and Fourteenth Amendments; (5) fabrication of
evidence in violation of the Fifth and Fourteenth Amendments; (6) constitutional violations of
plaintiff’s right to the equal protection under the laws; (7) municipal liability against the City
under Monell and § 1983; (8) respondeat superior liability of the City for violations of the laws
of the State of New York; (9) violations of the New York State Constitution; (10) intentional and
negligent infliction of emotional distress; (11) negligence; and (12) negligent hiring, screening,
retention, supervision, and training under state law.
THE COURT SHOULD ACCEPT AS TRUE ALL OF THE ALLEGATIONS OF THE
COMPLAINT BECAUSE THEY CONTAIN MORE THAN THREADBARE LEGAL
CONCLUSIONS AND ARE SUPPORTED BY MORE THAN SUFFICIENT FACTS
DEMONSTRATING PLAINTIFF IS ENTITLED TO RELIEF

Under Fed. R. Civ. P. 8(a)(2), a pleading must contain a “short and plain statement of the
claim showing that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2) does not require
“detailed factual allegations.”

Ashcroft v. Iqbal, 556 U.S. 662, 677-78 (2009) (citing Bell

Atlantic Corp. v. Twombly, 550 U.S. 544). To survive a motion to dismiss, the complaint is only
required to “contain sufficient factual matter, accepted as true, to ‘state a claim to relief that
is plausible on its face.’”

Id. at 678 (citing Twombly, supra, 550 U.S. at 570) (emphasis

added)). “A claim has facial plausibility when the plaintiff pleads factual content that allows the
12
Justifying references: commissioner Ray Kelly’s free rides Mr. Kerik’s relates to helicopter rides

page 35 lawsuit suggesting uses/abuses emulating Mr. Kelly NYPD icon take what you can when u
you can culture Rudin references in lawsuit minus his name + photo w/ Rudin protest sign I am
wearing when attacked omitted in motion to dismiss. Gartner employe John Doe page 25 lawsuit
Serpico references page 36 lawsuit Knapp synonymous

court to draw the reasonable inference that the defendant is liable for the misconduct alleged.”
Id. (citing Twombly, supra, 550 U.S. at 556) (emphasis added)).
Pursuant to the Supreme Court’s holding in Twombly, supra, a court must accept as
true all of the factual allegations contained in a complaint on a Fed. R. Civ. P. (12)(b)(6)
motion to dismiss. Ashcroft, supra, 556 U.S. at 678-79 (citing Twombly, supra, 550 U.S. at 555)
(emphasis added).
Further, documents filed by a pro se litigant “is to be liberally construed and a pro se
complaint, however inartfully pleaded, must be held to less stringent standards than formal
pleadings drafted by lawyers.” Erickson v. Pardus, 551 U.S. 89, 94 (2007) (internal citations
omitted) (emphasis added).
As plaintiff’s sixty-one paged complaint contains more than threadbare legal conclusions
but sets forth numerous and detailed factual allegations supporting her causes of action, the court
is required, based on the above well-established legal principles, to accept all of plaintiff’s
allegations as true on defendants’ motion to dismiss for failure to state a claim.

BRIEF STATEMENT OF FACTS

13
Justifying references: commissioner Ray Kelly’s free rides Mr. Kerik’s relates to helicopter rides

page 35 lawsuit suggesting uses/abuses emulating Mr. Kelly NYPD icon take what you can when u
you can culture Rudin references in lawsuit minus his name + photo w/ Rudin protest sign I am
wearing when attacked omitted in motion to dismiss. Gartner employe John Doe page 25 lawsuit
Serpico references page 36 lawsuit Knapp synonymous

This matter arises initially out of a vicious physical assault perpetrated by a doctor’s
receptionist, Delita Hooks, against plaintiff, an innocent victim, inside that doctor’s office
located at 155 Spring Street in Manhattan, New York. See Complaint pg. 11. On October 1,
2012, at approximately 3:30 p.m., plaintiff went to a doctor’s appointment at Dr. Kathleen Vine’s
office (“Dr. Vine”) to remove a cyst in her elbow. Id. Dr. Vine shared her office with other
medical doctors, including Dr. Andrew Fagelman, who all shared a single reception area. Id. At
approximately 4:10 p.m., after plaintiff’s medical procedure, plaintiff attempted to get some
water from the cooler in the reception area. Id. Plaintiff, who is, inter alia, an environmental
activist, politely asked Hooks, Dr. Fagelman’s receptionist, “Would you consider using paper
cups instead of Styrofoam? It’s better for the environment.” Id. Hooks reacted angrily stating
who are you, you have no rights! Ms. Troy was provoked to seek help from Dr Vine asking her
assistant where is Dr. Vine. Dr Vine was in with a patient so Ms. Troy asked what’s with her
signaling Ms. Hooks who had come out from behind the long closed off reception desk to further
harass and menace Ms. Troy getting in front of the exit by the water cooler “giving plaintiff the
finger” physically menacing plaintiff. Id. at 11-12. Plaintiff, was than provoked to document the
unprofessional and violent gesture began recording Hooks’ aggressive and threatening behavior ,
a violation of Patient Rights via her iPhone. Id. at 12. Hooks then began her physical assault
upon plaintiff, slapping plaintiff’s hand, knocking plaintiff’s iPhone to the ground (it was still
filming), taking off her shoes and throwing one at plaintiff, charging towards plaintiff, then
punched plaintiff in the left eye damaging plaintiff’s eye, grabbing plaintiff’s hair, punching
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plaintiff’s face with her fist, wrenching back plaintiff’s neck with her fingers and fist, repeatedly
attempting kicking plaintiff in her crotch, and ripping plaintiff’s earring out. Id. at 12-16. Hooks’
vicious and unprovoked attack upon plaintiff, when in fact Ms. Hooks could have easily closed
the door since plaintiff, an innocent victim, retreated outside but Ms. Hooks left the door open
using the door for balance to first strike plaintiff who was recorded on plaintiff’s iPhone and can
be found on Youtube now with aprox 17,500 YouTube views.1 Ms. Hooks was captured in the
video stating, “I will slap the crap out your ass” as she than began her brutal physical attack
upon plaintiff landing a running punch to the plaintiff’s eye which is when the Iphone video
capacity was shut off by Ms. Hooks contact with plaintiff’s body. Id. Plaintiff sustained, inter
alia, the following serious injuries as a result of Hooks’ vicious assault: (i) a hole in her retina
made by Hooks from a running punch to her eye which required plaintiff to endure eye surgery
or go blind; floaters in both eyes from head jerked back (ii) bulging and herniated disks as
evidenced by an MRI; (iii) a doctor instructed plaintiff to wear a neck brace and get an epidural
injection in her neck for the pain post the violent assault by Hooks; and (iv) constant and
debilitating pain in her neck. Id. at 16-17. Long defensive marks on arm from the key on Ms.
Hooks wrist that became like a weapon.
Following Hooks’ horrific and unprovoked attack, plaintiff went into the First Precinct
and filed a complaint report against Hooks. Id. at 15. Detective Vergona was assigned to

1

Youtube search “Delita Hooks” to easily find plaintiff’s video of the horrific attack clearly showing Hooks was the
aggressor who caused plaintiff serious injuries and violated her right to be safe from bodily harm and her patient’s
rights.

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investigate plaintiff’s case and called her Oct. 4, 2012.. Id. In the first phone conversation in a
series Oct. 4, 2012 with Detective Vergona plaintiff provided Vergona with the video via email
as Ms. Troy has not posted the video on YouTube of the October 1, 2012 attack clearly showing
Hooks as the attacker, the medical report of plaintiff’s primary care physician reflecting the
injuries sustained by plaintiff from the attack, and three photographs of plaintiff’s bodily injuries,
one photo right before the attack.

Id. at 18-19.

Detective Vergona refused to investigate

plaintiff’s case in person despite him repeatedly saying he would. Id. at 15-18.

Ms. Troy

contacted Det Vergona at lunch Oct 4, 2012 to alert him an anonymous YouTube account had
made a comment on a YouTube Ms. Troy did after the attack with a black eye stating Ms. Troy
was a liar and threw the first punch. Ms. Troy asked for permission to post Det Vergona’s tele
number because if there was any video Ms. Troy wanted to see it because it would show her
holding 2 bags and her phone as Ms. Hooks repeatedly attacked her.

(There are no records of

this calls and a series thereafter Oct. 4 in Ms Nam’s evidence section Motion to Dismiss) Det
Vergona as if in concert with Ms. Troy’s tormentors that appeared to be connected with Ms.
Hooks also became abusive. He yelled at her no! I don’t care what they say! I will go over there
and interview everyone. (He never did and stated during arrangement of false arrest he did not
have to go to the office since her detectives went.) He would letter in send Ms. Troy an email
stating he would go over and interview everyone and to date he never did.

He refused to

interview Dr Vine who came to Ms. Troy immediately after her medical asst. broke in and got
her. She was examining a woman completely undressed. Dr. Vine had treated Ms. Troy’s arm
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and had given her 2 numbing injections. Ms. Troy showed Dr Vine her damaged left forearm
with long defensive wounds and the blood in and around her eye.

Det Vergona refused to

interview the medical assistant who was so alarmed for Ms. Troy’s safety she broke in to get Dr
Vine to assist Ms. Troy.
Det Vergona said he didn’t have to interview them because they did not witness the
attack. He became more and more abusive asking which eye did you get punched in. He even
put his partner on the phone to mock Ms. Troy just like the slanderous comment he began
treating Ms. Troy no longer as a victim but an object of hate and scorn. Ms. Hooks said Ms.
Troy had not rights and it appeared Vergona agreed.

Ms. Troy explained that Mac Book in

photo booth had flipped the image but he was not interested or refused to understand. He said I
don’t care if you have two black eyes. Stop babbling. Ms. Troy told him she would call Apple
and have a supervisor explain and when she got the info from Apple to forward she called back
and Det Vergona’s partner put her on hold. It was for an extended period of time. Ms. Troy told
the Apple supervisor she needed help that she was a victim of the crime and the detective was
abusive and treating her like a liar.

Det Vergona’s partner finally got on the phone

sounding like a frat boy mockingly asking are you still there? Again not treated like a victim of a
savage attack.
Ms. Troy alerted him she was forwarding an email explain the flipped image. Ms. Troy
repeatedly asked to come to the First Precinct to show him her eye so he could see the damage
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and he repeatedly refused. She was with her Father in NJ and left him to rush back to NYC and
again called from the train station but Det Vergona refused to take her call. It should be noted
that Ms. Troy understands if Det Vergona or any police officer does not want to investigate a
crime they don’t have to we begin to see bias and abuse that appears in concert with the doctor’s
office. Ms. Troy gave all this and more information to Internal Affairs and Internal Affairs is
obligated to investigate police corruption and Ms. Troy alleges they did not and instead allowed
Det Vergona to retire.
Rather than investigating plaintiff’s case and notwithstanding the evidence plaintiff
showed him of Hooks being the vicious attacker, Detective Vergona subjected plaintiff to a series
of derogatory and discriminatory actions as perceived by Ms. Troy including when Ms. Troy
asked why did she have to wait 4 days (that would be 19 days after being a victim of a savage
attack at an MD’s office until Saturday. Arrest the Jew on the Sabbath. Det Vergona never
explained why she was being arrested except to say it was even steven, and refused to answer if
he was anti-semtiic. previously made comments I don’t care if you have two black eyes and stop
babbling which is tantamout to saying “shut-up”, religion, and selectively treated her based on
her gender and religion in violation of her constitutional rights. Det Vergona treated Ms. Troy
like she was not an American Citizen with 14th amendment rights as well as 1st amendment -stop babbling. Id. at 9-10, 16, 21-22, 26, 33, 38.

Further, when Hooks filed a false cross

complaint in response to plaintiff’s complaint, Detective Vergona threatened to falsely arrest
plaintiff if she did not drop her legitimate charges, selectively treating plaintiff based on her
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gender and religion, even though Vergona had evidence of Hooks being the aggressor.

Det

Vergona could not disguise his hatred and disdain for Ms. Troy yelling at her YOU ARE GOING
TO DROP THE CHARGES OR I AM GOING TO ARREST YOU. Id. at 9-10, 18-19, 22, 37,
38, 46, 47. Ms. Troy agreed to be false arrested twice. Plaintiff was finally forced to drop her
complaint against Hooks fearing for her imminent loss of liberty and even worse damage to her
health/serious medical conditions hole in retina, neck in neck brace with cervical damage, rapid
weight loss so Saturday, Oct. 20 she did drop charges despite refusing to do so from Oct. 16 thru
Saturday at 4pm the agreed time of false arrest when Ron Kuby intervened concerned for her
health although agreeing to represent her if she did go thru with the false arrest he would sue on
her behalf but he was gravely concerned for her health as a result of Detective Vergona’s
outrageous and hostile threats of false arrest.2 Id. at 38.

Ron Kuby told Ms. Troy Det Vergona

wants to punish you and put you thru the system. Plaintiff reported Detective Vergona’s
unconstitutional behavior and selective discriminatory treatment to the IAB and other
supervisory officials, however, plaintiff received no help or response. Id. at 24, 25, 26, 28, 29,
30, 33, 41, 42, 43, 44.

Instead, plaintiff was turned away by various police officers and

precincts from making her legitimate complaints against Hooks and Detective Vergona based on
their extreme bias and prejudice. Id. at 26, 33, 36-37, 41, 46, 47. Plaintiff’s constitutional rights
2

Exhibit D of defendants’ motion to dismiss contains an e-mail letter dated October 22, 2012, sent from plaintiff’s
former attorney, Ron Kuby, Esq., to Detective Vergona stating plaintiff “has chosen not to proceed with a criminal
complaint against her attacker, provided her attacker agrees not to pursue a criminal complaint against her.” Plaintiff
submits the reason why she authorized Kuby to write the letter was because she was extremely fearful of Detective
Vergona and his verbal violence and threats of false arrest, and was concerned about the consequences to her already
impaired health if she were to be held prisoner by defendants, however plaintiff also did not think it was fair for
Hooks to be permitted to pursue her false and baseless cross-complaint against plaintiff as the evidence clearly
shows plaintiff was the innocent victim in the assault.

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were stripped away by defendants who used their official positions to perpetrate their widespread
custom and policy of discriminating against civilians based on gender and religion, to cover up
violations of the United States Constitution, and to downgrade and fix crimes. Id. at 54-57.
PLAINTIFF’S OPPOSITION TO DEFENDANTS’ ARGUMENTS
POINT I: THE COMPLAINT CONTAINS FACTUAL ALLEGATIONS, WHICH MUST
BE ACCEPTED AS TRUE, THAT DEFENDANTS VERGONA, AGNES, BURGOS,
CAMPISI, CHEN, DWYER, KELLY O’DONNEL, WINSKI, AND THE IAB FAILED TO
INVESTIGATE PLAINTIFF’S VARIOUS REPORTS OF OFFICIAL MISCONDUCT

42 U.S.C. § 1983 provides:
Every person who, under color of any statute, ordinance,
regulation, custom, or usage, of any State or Territory or the
District of Columbia, subjects, or causes to be subjected, any
citizen of the United States or other person within the jurisdiction
thereof to the deprivation of any rights, privileges, or immunities
secured by the Constitution and laws, shall be liable to the party
injured in an action at law, suit in equity, or other proper
proceeding for redress, except that in any action brought against a
judicial officer for an act or omission taken in such officer's
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judicial capacity, injunctive relief shall not be granted unless a
declaratory decree was violated or declaratory relief was
unavailable. For the purposes of this section, any Act of Congress
applicable exclusively to the District of Columbia shall be
considered to be a statute of the District of Columbia.

As an initial matter, for the purposes of opposing this motion, plaintiff concedes there is
no affirmative right accorded to a private citizen to governmental aid, “even where such aid may
be necessary to secure life, liberty, or property interests of which the government itself may not
deprive the individual.” Deshaney v. Winnebago County Dept. of Social Services, 489 U.S. 189,
195 (1989). Plaintiff also concedes there is no independent constitutional or federal right to a
fair and adequate investigation. See Harrington v. Cnty. of Suffolk, 607 F.3d 31, 34-35 (2d Cir.
2010).
However, plaintiff argues defendants failed to cite to any binding legal authority holding
that plaintiff has no legitimate constitutional entitlement to relief arising from the failure of
supervisory defendants Campisi, Kelly, Winski, and Sergeant Chen to properly investigate or
intervene based on plaintiff’s reports of Detective Vergona threatening her with an unlawful
arrest if she did not drop her criminal charges, despite clear videotape evidence that Delita Hooks

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and not plaintiff was the perpetrator of the vicious bodily assault.3

Further, plaintiff argues

defendants failed to cite to any binding legal authority holding plaintiff cannot sustain a claim of
supervisory liability against the supervisory defendants and the IAB for failing to investigate
plaintiff’s reports of racial and gender bias on the part of Detective Vergona who threatened her
with false arrest.4
In order to sustain a claim of supervisory liability under Section 1983, a plaintiff must
allege facts in the complaint of the personal involvement of a supervisory defendant, which may
be shown by evidence the defendant: “(1) directly participated in the violation; (2) failed to
remedy the violation after learning of it through a report or appeal; (3) created a custom or policy
fostering the violation or allowed the custom or policy to continue after learning of it; or (4) was
grossly negligent in supervising subordinates who caused the violation.” Sealey v. Gilner, 116 F.
3d 47, 51 (2d Cir. 1997).
Preliminarily, under the doctrine of stare decisis, defendants’ citations to Rivera v. Goord,
119 F. Supp. 2d 327, 344-45 (S.D.N.Y. 20001) and Thomas v. Commbe, No. 95 Civ. 10342 (HB),
1998 U.S. Dist. LEXIS 10519 at *6 (S.D.N.Y. Jul. 13, 1998), should only be regarded as
persuasive rather than binding authority. In Rivera, supra, plaintiff filed a Section 1983 claim
contending the supervisory defendants violated his constitutional rights by failing to investigate
the medical defendants despite his complaints he was not getting adequate medical treatment
3

See Point V infra for plaintiff’s argument regarding defendants’ failure to intervene.

4

See Point IV infra for plaintiff’s argument regarding defendants’ violation of plaintiff’s constitutional right to the
equal protection of the laws.

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during his stay in a correctional facility. Id. at 344. The Rivera Court held the complaint failed to
sufficiently allege the supervisory defendants had personal knowledge of the alleged
constitutional allegation as plaintiff merely alleged he wrote to the defendants with his
complaints and the same were ignored. Id. The Rivera Court also held plaintiff alleged no facts
by which the court could infer that the defendants were deliberately indifferent or grossly
negligent in supervising any of the other defendants. Id.; see also Thomas v. Commbe, No. 95
Civ. 10342 (HB), 1998 U.S. Dist. LEXIS 10519 at *6 (S.D.N.Y. Jul 13, 1998) (“the fact that an
official ignored a letter alleging unconstitutional conduct is not enough to establish personal
involvement”).
Plaintiff argues that contrary to the facts demonstrated in Rivera and Coombe, the
complaint clearly sets forth sufficient factual allegations that plaintiff reported Detective
Vergona’s threats of false arrest/deprivation of liberty and failure to investigate due to racial and
gender bias, with no response or remedy of the same from any of the supervisory defendants or
the IAB. See Sealey, supra, 116 F.3d at 51. Not only did plaintiff write multiple letters to
defendants Kelly, Winski, and Campisi, but plaintiff also complained orally on numerous
occasions to defendants and the IAB of Detective Vergona’s selective treatment in investigating
her case and threats of false arrest, with no response from any of the supervisory defendants. See
Complaint at 24, 25, 26, 28, 29, 30, 33, 41, 43, 44, 52. Plaintiff also attempted to complain in
person at the First and Ninth Precincts of the defendants’ selective treatment and failure to

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investigate; however, she was turned away from doing the same as a result of their continued
selective treatment of plaintiff. Id. at 33, 41, 42.
Plaintiff also alleges in the complaint that the supervisory defendants created a custom or
policy fostering constitutional violations or allowed the custom or policy to continue after
learning of it.

See Sealey, supra, 116 F.3d at 51; Complaint at 30-32, 34-35, 52-57. The

complaint references on numerous occasions defendants’ policy and practice of downgrading and
fixing crimes without considering objective evidence or finding probable cause by the NYPD
and IAD.

See Complaint at 54-57. The complaint also references defendants’ custom and

unwritten policy of discriminating based on impermissible factors such as race, gender, religion,
and age. Id. at 30-32, 34-35.
Plaintiff maintains that the complaint alleges the supervisory defendants were personally
involved in subjecting plaintiff to selective treatment based on her religion and gender. See
Sealey, supra, 116 F.3d at 51. The supervisory defendants had knowledge that Detective Vergona
was threatening to falsely arrest her despite clear videotape evidence showing Hooks as the
aggressor and selectively treated her based on her religion and gender, but did nothing to prevent
these blatant violations of plaintiffs’ constitutional rights. Id. Further, the supervisory defendants
adhered to unwritten policies of permitting or fostering constitutional violations. Id.
As the complaint has alleged more than sufficient facts demonstrating the supervisory
liability of the defendants, which the court must accept true, defendants’ motion to dismiss
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plaintiff’s claims of supervisory liability should be denied. See Ashcroft, supra, 556 U.S. at
678-79 (courts must accept the facts in the complaint as true); Twombly, supra, 550 U.S. at 570;
Erickson, supra, 551 U.S. at 94 (courts must liberally construe pleadings and documents filed by
pro se litigants).
POINT II: THE COMPLAINT CONTAINS FACTUAL ALLEGATIONS, WHICH MUST
BE ACCEPTED AS TRUE, THAT DEFENDANTS VIOLATED PLAINTIFF’S FIRST
AMENDMENT RIGHT AGAINST RETALIATION

The First Amendment reads: “Congress shall make no law respecting an establishment of
religion, or prohibiting the free exercise thereof; or abridging the freedom of speech, or of the
press; or the right of the people peaceably to assemble, and to petition the government for a
redress of grievances.” “A plaintiff asserting a First Amendment claim must allege that (1) he
has an interest protected by the First Amendment; (2) defendant’s actions were motivated by or
substantially caused by the plaintiff’s exercise of that right; and (3) the defendant’s actions
effectively chilled the exercise of the plaintiff’s First Amendment rights.” Connell v. Signoracci,
53 F.3d 74, 49 (2d Cir. 1998).
The complaint sets forth numerous factual allegations demonstrating defendants
retaliated against plaintiff’s political activity, protests against the NYPD’s discriminatory
practices, for plaintiff being a Jewish woman, and plaintiff’s attempts to expose Detective
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Vergona’s unlawful threats of false arrest and selective treatment of plaintiff during his
investigation based on her religion and gender.

See Complaint at 4-11, 24-25, 30-32 (for

examples of plaintiff’s political activity and protests). Defendants retaliated against plaintiff by
chilling her speech, hampering her ability to prosecute her criminal complaint through threats of
false arrest, and impeding her ability to report defendant’s threats of false arrest and selective
treatment of plaintiff. Specifically, Pages 21-22 of the complaint alleges that on October 4, 2012,
plaintiff called Detective Vergona to provide additional information about her case, at which time
Detective Vergona stated: “I DON’T CARE IF YOU HAVE TWO BLACK EYES. STOP
BABBLING.” (Emphasis added) (literally telling plaintiff to stop speaking in violation of her
First Amendment rights). On Page 33 of the complaint, plaintiff alleges she went to the Ninth
Precinct to file a complaint against Detective Vergona for racial bias per the instruction of (page
33 lawsuit) Detective Sanchez of the Hate Crimes Unit, but was turned away, in violation of her
First Amendment rights to free speech and conduct. On Pages 36-38 and 46-47 the complaint
alleges Detective Vergona threatened to falsely arrest plaintiff if she did not drop her charges
against Hooks, and plaintiff was forced to drop her complaint as a result of Vergona’s threats,
preventing plaintiff from exercising her constitutional right to free speech and prosecuting her
case. On Page 41, the complaint alleges plaintiff recorded an audio of Officer Migori turning
plaintiff away not allowing her to file a complaint against Delita Hooks for filing a false cross
complaint, in violation of plaintiff’s constitutional right to speech and conduct.

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Also, contrary to defendants’ argument, even if the officers possessed enough probable
cause to arrest plaintiff as a result of Delita Hook’s false cross complaint, which plaintiff
respectfully argues they did not, the defendants’ actions of preventing plaintiff from speaking,
complaining, or reporting the assault or Detective Vergona’s threats of false arrest and selective
treatment of plaintiff still violates plaintiff’s First Amendment rights to free speech and conduct.
Accordingly, as the complaint has alleged more than sufficient facts demonstrating
defendants retaliated against plaintiff by violating her First Amendment rights to free speech and
conduct, which the court must accept true, defendants’ motion to dismiss should be denied. See
Ashcroft, supra, 556 U.S. at 678-79 (courts must accept the facts in the complaint as true);
Twombly, supra, 550 U.S. at 570; Erickson, supra, 551 U.S. at 94 (courts must liberally construe
pleadings and documents filed by pro se litigants).
POINT III: THE COMPLAINT CONTAINS FACTUAL ALLEGATIONS, WHICH
SHOULD BE ACCEPTED AS TRUE, THAT DEFENDANTS THREATENED TO LODGE
FALSE CHARGES AND FABRICATED EVIDENCE IN VIOLATION OF HER FOURTH
AND FOURTEENTH AMENDMENT RIGHTS DUE PROCESS RIGHTS

A Section 1983 claim for fabrication of evidence arises under the Fourth Amendment.
See Zahrey v. Coffey, 221 F.3d 342, 349 (2d Cir. 2000).

“It is firmly established that a

constitutional right exists not to be deprived of liberty on the basis of false evidence fabricated
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by a government officer.” Id. (emphasis added). “When a police officer creates false information
likely to influence a jury’s decision and forwards that information to prosecutors, he violates the
accused’s constitutional right to a fair trial.” Ricciuti v. NYC Transit Auth., 124 F.3d 123, 130
(2d Cir. 1997). Plaintiff must demonstrate a loss of liberty in violation of the due process clause
of the Fourth and Fourteenth Amendments which was caused by fabrication of evidence by a
government official. Zahrey, supra, 221 F.3d at 347. Plaintiff has the constitutional right not to
be deprived of her liberty to be searched and seized, arrested, detained or imprisoned except
upon probable cause pursuant to the due process clause of the Fourth and Fourteenth
Amendments.
POINT IV: THE COMPLAINT CONTAINS FACTUAL ALLEGATIONS, WHICH
SHOULD BE ACCEPTED AS TRUE, THAT DEFENDANTS DEPRIVED PLAINTIFF OF
EQUAL PROTECTION OF THE LAWS UNDER THE FOURTEENTH AMENDMENT

The Fourteenth Amendment provides:
All persons born or naturalized in the United States, and subject to
the jurisdiction thereof, are citizens of the United States and of the
state wherein they reside. No state shall make or enforce any law
which shall abridge the privileges or immunities of citizens of the
United States; nor shall any state deprive any person of life, liberty,
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or property, without due process of law; nor deny to any person
within its jurisdiction the equal protection of the laws.

The Equal Protection Clause of the Fourteenth Amendment is “essentially a direction
that all persons similarly situated should be treated alike.” City of Cleburne v. Cleburne Living
Ctr., Inc., 473 U.S. 432, 439 (1985). The State may not selectively deny its protective services to
certain disfavored minorities without violating the Equal Protection Clause. Deshaney, 489 U.S.
at 197 n.3 (citing Yick Wo v. Hopkins, 118 U.S. 356 (1886)). In LeClair v. Saunders, 627 F.2d
606, 608 (2d Cir. 1980), the Second Circuit held such a claim may succeed if the plaintiff proves:
“(1) the [plaintiff], compared with others similarly situated, was selectively treated; and (2) that
such selective treatment was based on impermissible considerations such as race, religion, intent
to inhibit or punish the exercise of constitutional rights, or malicious or bad faith intent to injure
a person.” Id.
The complaint contains numerous factual allegations that defendants violated plaintiff’s
constitutional right to the equal protection of the laws by selectively treating her based on her
gender and religion.

Specifically, Page 9-10 of the complaint alleges Detective Vergona

threatened plaintiff with false arrest and demanded plaintiff wait 4 days until the Sabbath to be
falsely arrested knowing full well plaintiff is Jewish. Page 16 of the complaint alleges Detective
Vergona refused to take plaintiff’s injuries seriously because of his biases stating plaintiff should
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have kept walking treating her as if she was a rape victim to be blamed for being raped. Page 21
of the complaint alleges plaintiff joked with Vergona stating: “Thank you, I’ll see you next
summer, and if I can afford injections then I’ll get them to attract younger men” and Vergona
adopted a misogynistic attitude. Page 21-22 of the complaint alleges Detective Vergona never
conducted a single interview of a witness to the assault, Detective Vergona never met with
plaintiff to see her injuries, Detective Dwyer never contacted plaintiff for an interview, and only
plaintiff’s attacker Hooks was able to meet with the NYPD. Page 26 of the complaint alleges
plaintiff never met with any detective or supervisor who all refused to meet with her, but Hooks
was able to get a prompt meeting with the NYPD, despite clear videotape evidence showing
Hooks as the violent attacker. Page 33 of the complaint alleges IAB never contacted plaintiff
regarding her allegations of Vergona’s religious and gender bias against her. Page 38 of the
complaint alleges Vergona stated to plaintiff she must come to the station on Saturday October
20, 2012, four days after plaintiff offered to surrender to arrest, despite plaintiff having informed
him she is Jewish and Saturday is the Sabbath. Pages 46 through 52 of the complaint allege
Detective Vergona threatened plaintiff with false arrest and subjected plaintiff to verbal violence.
As the complaint has alleged more than sufficient factual allegations that defendants
violated plaintiff’s constitutional rights to the equal protection of the laws by selectively treating
her based on her gender and religion, defendants’ motion to dismiss should be denied. See
Ashcroft, supra, 556 U.S. at 678-79 (courts must accept the facts in the complaint as true);

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Twombly, supra, 550 U.S. at 570; Erickson, supra, 551 U.S. at 94 (courts must liberally construe
pleadings and documents filed by pro se litigants).
POINT V: THE COMPLAINT CONTAINS FACTUAL ALLEGATIONS, WHICH
SHOULD BE ACCEPTED AS TRUE, THAT DEFENDANTS FAILED TO INTERVENE
UNDER SECTION 1983 AND PREVENT THE CONSTITUTIONAL VIOLATIONS
PERPETRATED BY DETECTIVE VERGANO AND OTHER OFFICIALS AGAINST
PLAINTIFF
In O’Neill v. Krzeminski, 839 F.2d 9, 11-12 (2d Cir. 1987), the Second Circuit held
police officers may be liable if they observe or have reason to know: (1) excessive force is being
used; (2) a citizen is being unjustifiably arrested; or (3) any constitutional violation has been
committed by a law enforcement official. Id. The police officer must have had a realistic
opportunity to intervene to prevent the constitutional violation from occurring. Id. Whether the
police officer has a realistic opportunity to intervene is a question of fact reserved for the jury.
Id.
Plaintiff complained on numerous occasions to defendants and the IAB of Detective
Vergona’s unconstitutional selective treatment of plaintiff based on gender and religious bias and
his threats of false arrest. See Complaint at 24, 25, 26, 28, 29, 30, 33, 41, 42, 43, 44. However,
none of the defendants intervened to prevent Detective Vergona from violating plaintiff’s
constitutional rights.

Rather, defendants personally engaged in depriving plaintiff of her
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constitutional rights by not responding to her numerous complaints of Detective Vergona’s
outrageous and discriminatory conduct, turning her away at the First and Ninth Precincts, and
preventing her from making her legitimate complaints. Id. at 33, 41, 42.
Defendants had more than sufficient time to intervene, as it has been almost a full year
since plaintiff made defendants aware of their actions of depriving plaintiff of her constitutional
rights, however, nothing has been done to address or remedy plaintiff’s complaints.
As the complaint has alleged more than sufficient factual allegations that defendants
failed to intervene when they had knowledge that a government official was violating plaintiff’s
constitutional rights, defendants’ motion to dismiss should be denied. See Ashcroft, supra, 556
U.S. at 678-79 (courts must accept the facts in the complaint as true); Twombly, supra, 550 U.S.
at 570; Erickson, supra, 551 U.S. at 94 (courts must liberally construe pleadings and documents
filed by pro se litigants).
POINT VI: THE COMPLAINT CONTAINS FACTUAL ALLEGATIONS, WHICH
SHOULD BE ACCEPTED AS TRUE, TO ESTABLISH MUNICIPAL LIABILITY
AGAINST THE CITY UNDER MONELL

In order to prevail on a Section 1983 claim against a municipality, a plaintiff must
demonstrate that a municipal policy or custom caused the deprivation of his or her constitutional
rights. Monell v. Department of Social Services of New York, 436 U.S. 658, 690-91 (1978).
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“The plaintiff must first prove the existence of a municipal policy or custom in order to show that
the municipality took some action that caused his injuries . . . Second, the plaintiff must establish
a causal connection – an “affirmative link” – between the policy and deprivation of his
constitutional rights.” Vippolis v. Village of Haverstraw, 768 F.2d 40, 44 (2d Cir. 1985), cert.
denied, 480 U.S. 916 (1987) (citing Oklahoma City v. Tuttle, 471 U.S. 808, 824 n.8 (1985)).
Again, 42 U.S.C. § 1983 provides:
Every person who, under color of any statute, ordinance,
regulation, custom, or usage, of any State or Territory or the
District of Columbia, subjects, or causes to be subjected, any
citizen of the United States or other person within the jurisdiction
thereof to the deprivation of any rights, privileges, or immunities
secured by the Constitution and laws, shall be liable to the party
injured in an action at law, suit in equity, or other proper
proceeding for redress, except that in any action brought against a
judicial officer for an act or omission taken in such officer's
judicial capacity, injunctive relief shall not be granted unless a
declaratory decree was violated or declaratory relief was
unavailable. For the purposes of this section, any Act of Congress
applicable exclusively to the District of Columbia shall be
considered to be a statute of the District of Columbia.
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[Emphasis added.]
Municipalities may be sued for constitutional deprivations “visited pursuant to
governmental ‘custom’ even though such a custom has not received formal approval through the
body’s official decisionmaking channels.” As Mr. Justice Harlan, writing for the Court, said in
Adickes v. S.H. Kress & Co., 398 U.S. 144, 167-68 (1970): “Congress included customs and
usages [in Section 1983] because of the persistent and widespread discriminatory practices of
state officials . . . . Although not authorized by written law, such practices of state officials could
well be so permanent and well settled as to constitute a ‘custom or usage’ with the force of law.”
Id. (emphasis added).
The complaint contains factual allegations that the City and the NYPD have engaged in
customs or unwritten policies of downgrading crimes and using racial and gender bias to
perpetrate selective treatment to its citizens based on impermissible grounds. Specifically, Pages
30-32 of the complaint contains plaintiff’s reference to IAB’s history of non-responsive or
ineffectual policies (and her allegations IAB was unresponsive to her complaints mentioned
throughout the complaint).

Pages 34-35 of the complaint contains plaintiff’s reference to

Detective Shirley Page’s lawsuit against Chief Campisi and the IAB showing racial and sexual
bias and other discriminatory practices of the NYPD. Pages 54-57 of the complaint alleges
widespread customs and practices of defendants to downgrade crimes, cover up federal
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violations, failing to intervene where they see government officials committing constitutional
violations, etc. See also Pages 9, 10, 21-22, 26, 32, 37, and 38 for examples of defendants
practicing their unlawful policies against plaintiff thereby depriving her of her constitutional
rights.
Fed. R. Civ. P. Rule 8 requires only that a plaintiff provides enough facts in her complaint
to put the defendant on notice of the claim, and it does not require that a plaintiff prove his or her
case. Plaintiff is not required to prove the existence of a municipal custom at this stage of the
litigation; rather, alleging, with examples, of the existence of a custom or usage is sufficient,
especially in light of the fact that policies or customs of discriminatory practices by state officials
are not likely to be memorialized in any type of rule or regulation, and would be difficult to
prove at the outset of litigation without the opportunity for discovery. See Adickes, supra, 398
U.S. at 167-68.
As the complaint has alleged more than sufficient factual allegations that the City should
be held liable as it maintained a municipal policy or custom which caused the deprivation
plaintiff’s constitutional rights, defendants’ motion to dismiss should be denied. See Ashcroft,
supra, 556 U.S. at 678-79 (the court must accept the facts in the complaint as true); Twombly,
supra, 550 U.S. at 570; Erickson, supra, 551 U.S. at 94 (courts must liberally construe pleadings
and documents filed by pro se litigants).

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POINT VII: THE COMPLAINT CONTAINS FACTUAL ALLEGATIONS, WHICH
SHOULD BE ACCEPTED AS TRUE, THAT THE CITY IS LIABLE UNDER THE
COMMON LAW DOCTRINE OF RESPONDEAT SUPERIOR

Actions for false arrest and malicious prosecution may proceed against the City on the
theory of respondeat superior if the claim arises under state law. Raysor v. Port Authority of
New York & New Jersey, 768 F.2d 34, 38 (2d Cir. 1985). N.Y.Crim.Proc.Law 140.10 (McKinney
1981) requires “reasonable cause” for an arrest, which is the equivalent of probable cause. A
deprivation of liberty without “reasonable cause” is a section 1983 violation, and the defendant
bears the burden of proving the reasonableness of the arrest. Raysor, supra, 768 F.2d at 40.
Subjective good faith belief of probable cause is not enough to shield an officer for an unlawful
arrest. Id.
Here, defendants threatened to arrest plaintiff even despite clear videotape evidence that
she was not the perpetrator of the vicious attack. Plaintiff argues defendants would not have had
the objective probable cause to arrest her in the face of her evidence, but they still threatened to
subject her to a loss of liberty if she did not drop her charges against Hooks. Defendants argue
plaintiff has not sufficiently alleged an underlying violation of her state common law rights at the
hands of the police officers and detectives involved. However, the complaint contains countless
examples of defendants violating plaintiff’s state common law rights by threatening to falsely
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arrest her without “reasonable cause” and subjecting her to selective treatment based on her
gender and religion. See also Pages 9, 10, 21-22, 26, 32, 37, and 38.
As the complaint has alleged more than sufficient factual allegations the City should be
held liable to plaintiff under the theory of respondeat superior, defendants’ motion to dismiss
should be denied. See Ashcroft, supra, 556 U.S. at 678-79 (the court must accept the facts in the
complaint as true); Twombly, supra, 550 U.S. at 570; Erickson, supra, 551 U.S. at 94 (courts
must liberally construe pleadings and documents filed by pro se litigants).
VIII: THE COMPLAINT CONTAINED FACTUAL ALLEGATIONS, WHICH SHOULD
BE ACCEPTED AS TRUE, THAT PLAINTIFF HAS ESTABLISHED A PRIMA FACIE
CASE FOR NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS

To sustain a claim for intentional infliction of emotional distress (“IIED”), a plaintiff
must show: (1) extreme and outrageous conduct; (2) intent to cause severe emotional distress; (3)
a causal connection between the conduct and the injury; and (4) severe emotional distress.
Bender v. City of New York, 78 F.3d 787, 790 (2d Cir. 1996). To sustain a claim for negligent
infliction of emotional distress (“NIED”), a plaintiff must demonstrate: (1) defendant was
negligent in creating an unreasonable risk of bodily harm to the plaintiff; (2) such conduct was a
substantial factor in bringing about injuries to plaintiff; and (3) the injuries are a consequence
resulting from plaintiff’s contemporaneous observation of serious physical injury or death
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inflicted by defendant’s conduct on a member of plaintiff’s immediate family in his or her
presence. Bovsun v. Sanperi, 61 N.Y.2d (1984). While physical injury is no longer a necessary
element, a cause of action to recover damages for negligent infliction of emotional distress must
generally be premised upon conduct which unreasonably endangers the plaintiff’s physical and
emotional safety. Sibens v. American Airlines Inc., 913 F. Supp. 271, 276 (S.D.N.Y) 1996.
The complaint contains factual allegations which support plaintiff’s claims of intentional
and negligent infliction of emotional distress. To support this argument, plaintiff refers to every
instance in the complaint where she alleges Detective Vergona subjected her to religious and
gender bias, threatened her with false arrest, continuously yelled and berated plaintiff to turn
herself in for false arrest, and forced plaintiff to drop her legitimate criminal complaint even in
the face of clear evidence showing Hooks as the aggressor, to demonstrate element 1 of IIED.
See Complaint at 9, 10, 21-22, 26, 32, 37, and 38. Element 2 of IIED, namely, intent to cause
severe emotional distress, can be inferred from the facts set forth throughout the entire
complaint, i.e. Detective Vergona’s knowledge of her being Jewish but ordering her to surrender
to false arrest on the Sabbath; Detective Vergona’s knowledge of plaintiff’s physical ailments but
threatening her with false arrest; Detective Vergona yelling at her to drop charges despite
receiving evidence clearly demonstrating assault was perpetrated by Delita Hooks, etc. Facts
supporting elements 1-3 of NIED and elements 3-4 of IIED can be found on pages 38, 39 and 44
of the complaint: plaintiff suffered physical harm from the assault by Delita Hooks and had a
collapsed bladder and plaintiff was worried about her physical wellbeing if she were to be falsely
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arrested despite Vergona’s knowledge she has health issues (elements 1, 2, 3 of NIED) (element
4 of IIED); plaintiff suffered mental and emotional harm, depression, loss of body weight, loss of
her period for a month fearing her false arrest and in response to Vergona’s outrageous and
offensive discriminatory statements (elements 1, 2, 3 of NIED) (element 4 of IIED); Pages
38-39: plaintiff was forced to drop her charges as a result of Vergona’s threats of false arrest as
she feared for her physical wellbeing and mental health; and page 44: plaintiff’s father has health
problems and relies on plaintiff’s care, plaintiff feared defendants holding her prisoner would
have killed her father (element 1, 4 of IIED) (element 3 of NIED).
As the complaint has alleged more than sufficient factual allegations that the defendants
are liable for IIED and NIED, defendants’ motion to dismiss should be denied. See Ashcroft,
supra, 556 U.S. at 678-79 (the court must accept the facts in the complaint as true); Twombly,
supra, 550 U.S. at 570; Erickson, supra, 551 U.S. at 94 (courts must liberally construe pleadings
and documents filed by pro se litigants).
POINT IX: THE COMPLAINT CONTAINS FACTUAL ALLEGATIONS, WHICH
SHOULD BE ACCEPTED AS TRUE, THAT PLAINTIFF HAS DEMONSTRATED
SHE HAS A PRIMA FACIE CLAIM FOR NEGLIGENCE

To assert a prima facie claim for negligence, a plaintiff must allege the following three
elements: (1) the existence of a duty on defendant’s part as to plaintiff; (2) a breach of this duty;
and (3) injury to the plaintiff as a result thereof. Alfaro v. Wal-Mart Stores, Inc., 210 F.3d 111,1
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14 (2d Cir. 2000). Plaintiff concedes that she does not have a constitutional right to a fair and
thorough investigation. However, the complaint contains factual allegations asserting defendants
owed her a duty not to violate her constitutional rights by threatening her with false arrest,
selectively treating her on the basis of her religion and gender, or failing to intervene when they
witnessed other officers violating her constitutional rights, and they breached the same
(establishing elements 1 and 2 of negligence).
Facts supporting element 3 of negligence can be found on pages 38, 39 and 44 of the
complaint: plaintiff suffered physical harm from the assault by Delita Hooks and had a collapsed
bladder and plaintiff was worried about her physical wellbeing if she were to be falsely arrested
despite Vergona’s knowledge she has health issues; Plaintiff suffered mental and emotional harm,
depression, loss of body weight, loss of her period for a month fearing her false arrest and in
response to Vergona’s outrageous and offensive discriminatory statements; Pages 38-39: plaintiff
was forced to drop her charges as a result of Vergona’s threats of false arrest as she feared for her
physical wellbeing and mental health; and page 44: plaintiff’s father has health problems and
relies on plaintiff’s care, plaintiff feared defendants holding her prisoner would have killed her
father.
As the complaint has alleged more than sufficient factual allegations that the defendants
should be held liable to plaintiff for their negligence, defendants’ motion to dismiss should be
denied. See Ashcroft, supra, 556 U.S. at 678-79 (the court must accept the facts in the complaint

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as true); Twombly, supra, 550 U.S. at 570; Erickson, supra, 551 U.S. at 94 (courts must liberally
construe pleadings and documents filed by pro se litigants).
POINT X: THE COMPLAINT CONTAINS FACTUAL ALLEGATIONS, WHICH
MUST BE ACCEPTED AS TRUE, THAT THE CITY NEGLIGENTLY HIRED,
SCREENED, RETAINED, SUPERVISED AND TRAINED DEFENDANT POLICE
OFFICERS UNDER STATE LAW

To maintain a claim for negligent hiring and retention under New York law, plaintiff must
establish: (1) the tort-feasor and the defendant were in an employee-employer relationship; (2)
the employer knew or should have known of the employee’s propensity for the conduct which
caused the injury prior to the injury’s occurrence; and (3) the tort was committed on the

employer’s premises or with the employer’s chattels” Ehrens v. Lutheran Church, 385 F.
3d 232, 235 (2d Cir. 2004) (internal citations omitted).
“To maintain a claim against a municipal employer for the ‘negligent hiring, training, and
retention’ of a tortfeasor under New York law, a plaintiff must show that the employee acted
‘outside the scope of her employment.’” Velez v. City of New York, 2013 WL 5225784 at *6 (2d
Cir. 2013) (citing Gurevich v. City of New York, 2008 WL 113775 at &6 (S.D.N.Y. Jan. 10,
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2008)). “If the employee acted within the scope of her employment, the employer and the
employee's supervisors may be held liable for the employee's negligence only under a theory of
respondeat superior.” Velez, supra, 2013 WL 5225784 at *6. “This is because if the employee
was not negligent, there is no basis for imposing liability on the employer, and if the employee
was negligent, the employer must pay the judgment regardless of the ... adequacy of the
training.” Id.
Plaintiff concedes defendants were acting in the scope of their employment when they
violated her constitutional rights.

Accordingly, plaintiff shall proceed to assert negligence

against the City under the theory of respondeat superior.

The Evidence

1)

Google Dr Fagelman Assault and watch the YouTube with over 17,600 views. I added the
“NYPD Fixed” to the title when I got Delita Hooks false criminal report (a serious crime) and
scanned it in. Instead of handing in a disk to put in your computer it is cost effective and safer
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for your computer to just view the video posted directly from my phone 3 days later, Oct 4
when at lunch I came under attack suffering abuse and the same time an abuser came to the
YouTube on ECTP 911 Tech Corruption and I have black eye to call me a liar and blame me.
The 34 second video filmed from my iphone after Delita Hooks provoked a 2nd time, 1st to seek
help from Dr Vine who sadly was in with another patient and than the 2nd time to start filming; I
posted directly up to YouTube via my iphone Oct. 4, 3 days after cyber attack at lunch time on
behalf of Delita Hooks falsely accusing me of throwing the first punch and stating they have
video to prove it. Det John Vergona was very nice to me on the phone in the morning and he had
a copy of the video and saw it along with photos before and after but at lunch with my 88 year
old Father I call Det John Vergona and he is abusive so I decided time to post the video. It is
unedited. It is 36 seconds long. Aprox 4 seconds in to the video you can see her friend and coworker leaning against the wall like she is waiting for a bus -- maybe she see Delita Hooks give
patients the finger. I am non-violent but frustrated by even more abuse than Delita Hooks yelling
at me who are you, you have no rights. You leave trash in the waiting room and Dr Vine is in
with a patient so Delita Hooks first provoked me to see help from my physician and than 2nd
time provokes me to start filming to document the fact she gave me the finger and she didn’t
think she did anything wrong. She still does not blaming me for her violence and the video
proves she is a liar and her cross complaint is false. She could have closed the door. I had no
where to run as the all doors are locked in the hall way and the elevator is at the other end. You
see her gesture and state I will slap the crap out of your ass. I back away and she starts hitting
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me holding on the door knob for balance as she hits me with her hand and iphone twice instead
of closing the door.
2) I referenced the false cross complaint in my lawsuit repeatedly and Ms. Nam told me via our
first phone conversation the cross complaint is sealed which by the way is highly unusual
since it has not been a year and a guilty person would be thrilled but I allege they did this to
protect Delita Hooks false cross complaint also a crime as is assault and I allege the NYPD
sealed it to protect their crime of coercion carried out by Det John Vergona. It took almost
one year but I got a copy of her false criminal report which clearly proves Delita Hooks lied
and committed a serious crime. She assaulted me a serious crime and than lied and blamed
me stating I attacked her. Everything in the false cross complaint is a lie except she admits to
a heated fight with a patient. FYI it was one sided -- the heat on her side and what medical
professional/receptionist/office manager gets in a heated fight with a patient? She leaves out
the fact the offices include dermatology hinting she perhaps saw me as something “outside”
what she deemed part of the office yet she admits I am a patient. She lies about me pushing
her. She lies about me kicking her once she is down on the ground. I used her momentum
which was fierce enough to make a hole in my retina to get her down on the ground and I let
go and moved away. I made no contact with her left leg and I did not leave a bruise on her
thigh. The bruise is either self inflicted or perhaps from the heavy woman first seen in the
YouTube leaning against the wall who Delita Hooks kicked by accident when she repeatedly

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kicked me and the woman yelled out in pain. Maybe she accidentally stepped on Delita
Hooks when she kicked her from the ground.
3) Medical reports of serious damage to my left eye from 2 eye MD’s, one a surgeon. Medical
reports from my primary care physician who has known me for over 25 years. Medical
reports from neck and spine MD. MD report from MD for epidural for my neck. Prescription
for neck brace.
4)

Photos before and after the assault.

5) Ms Nam’s letter alerting me her defendants collectively agree that Det John Vergona should
be represented by the City of NY

I have over whelming evidence of me being savagely assaulted. It is assault and battery. I allege
the key on her wrist also became a weapon and even her iphone and shoe were used as weapons
although they key was the only weapon to leave marks on my body besides her repeatedly
slapping me, throwing her shoes, running punch to my body, repeatedly kicks to my body finally
touching my vaginal area with her foot as I never put down my bags which had a glass ipad I was
fearful of her shattering and I had no interest in fighting her only getting away from her. I am
told the women in the video all said it was me not knowing there was a video and none of them
stopped and asked if I was okay.

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I have additional evidence including phone records of attempts to get help and calling the NYPD
and even Internal Affairs when no one answers at the First Precinct.
I would like to see phone records etc of all involved but for now I focus on the key evidence
available as well as evidence I got from Ms .Nam’s motion to dismiss.

6) Audio “NYPD 01 Sgt. Chen False Cross Complaint Turned Away Call IAB, CCRB (note to
save money I posted on YouTube so no disks need to be placed in computers. There are 2
copies -- this one has over 400 views and the sound has been enhanced to hear much better. I
paid a tech person to help improve the sound quality.) Audio of NYPD PO Migori at the front
desk of the First Precinct turning me away, calling Sgt Chen who had told me via a rude and
unprofessional telephone conversation that I had a right to come in and report a false cross
complaint. He said you were the one assaulted at the MD’s office trying to hold back laughter
and yet he along with all involved from the women in the video to all NYPD and IAB
involved never asked are you okay. You can hear her (PO Migori) talking to Sgt Chen who
repeatedly refuses to come down, you can hear an associate answer when I call him from my
cel inside the precinct refusing to talk to me so we have PO Migori’s explanation which is
proof of the NYPD and supervisors violating my 1st and 14th amendment rights in my
opinion. I had the right to speak up and to file a complaint where the NYPD agrees or not or
choses to investigate or ignore. The video also gives us evidence of the NYPD’s failure to
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wearing when attacked omitted in motion to dismiss. Gartner employe John Doe page 25 lawsuit
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supervise and train employees correctly and on the 01 Community website they brag about
officers involved in this lawsuit including PO Migori yet she can be heard saying I can’t report
a false cross complaint because I am not a detective or DA. If she such a great cop as the 01
brags along with I believe Det Andy Dwyer why didn’t anyone want to get to the bottom of
this from meeting with me and my MD and her medical assistant? Why didn’t they want to
know why I would come back a month later and call Det Vergona’s supervisor and walk in to
the precinct as he instructed? You can hear me call IAB and more proof IAB failed to
supervisor as well as investigate police corruption. You hear me call DI Ed Winksi and I can’t
get his voice mail but am sent to Community Affairs answering machine where I alleged
NYPD PO Eugene Schatz was placed rather than punished for his actions using the squad card
illegally to intimidate me on behalf of the Mercer, the same Mr. Schatz I forwarded emails I
believed on his behalf that harassed me and gay bashed me although I am not gay. I have
video of NYPD Schatz illegally using his sirens in his squad car to harass our peaceful protest
in front of The Mercer which was to end in one minute -- a 15 min protest and he illegally
used sirens and rushed their to harass us on behalf of The Mercer Hotel.
7)

Letter to DI Ed Winski about being turned away. He has a poster at the front desk about
seeing something say something re: contacting IAB and in my opinion yet another example of
failure to supervise and acts of retaliation with the message to be silent and I deserved what I
got.

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8)

“NYPD Internal Affairs Call re: 2 Videos Corruption Fixing Delita Hook's Violent Assault” to
save money and using discs to insert in computers you can hear the audio in this YouTube. It
should be noted I edited aprox 5 seconds of an allegation re: Dr Fagelman and the NYPD.
Audio you can hear IAB Sgt Mary O’Donnell stating cases closed. I said I don’t want to talk
to her. Det Vergona further humiliated me telling my lawyer not to contact my savage lying
attacker as my video and her false cross complaint proves and HIM! As Ms Nam points out I
say I don’t want to talk to her. Why? I allege she is corrupt and I allege her refusal to
acknowledge my points re: the video and Ron Kuby’s letter and even offering to fax her the
email of what I agree to Ron Kuby saying you can her respond with what I call me hitting my
head repeatedly against the blue wall of corruption.

Note: I was filming myself and waiting

for a call from my eye surgeon to find out if I need the 2nd surgery from Delita Hooks savage
attack asap but the phone rings and it is IAB Sgt. O’Donnell. If you want to see how in my
opinion I made to suffer not treated as a victim and just one example how IAB and NYPD I
accuse of fixing crimes as listed in lawsuit cause me emotional distress you can see and hear it
and if you want to see and hear it with out the brief edit I can bring it in to court or spend
money transferring it in to DVD. IAB Lt. Fikru had me come in to IAB offices on Hudson
street and audio recorded it from my computer so IAB has a copy.
9)

removal of the YouTube
“Det. John Vergona 01 Det. Squad Delita Hooks Assaults me files false cross complaint No
Arrest!” for violation of terms cyber bullying and harassment removed March 19, 2013
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Google apologizes and returns my YouTube because it is the truth. If anyone is being bullied and
harassed it is me.

“Dr Fagelman's Office Mgr/ Receptionist Delita Hooks Menaced Violently Gave Finger,
Assaulted Me” After the Det John Vergona YouTube was removed this YouTube was removed
which I believe was aprox March 23, 2012 Friday. It took until Wednesday during Passover to
get this video back. I sent this email blast out to everyone this is censorship of true events,
human rights violations. Wednesday 28, 2012 a Passover miracle an apology my work returned
and intact. This is from a series on my 2ndary Channel Suzannah Troy where I made extra
copies of the video with different titles.
Note the evidence section continues at the back pages 217- 232 with emails, medical reports,
telephone records proving Det Vergona or his lawyer omitted key telephone calls, etc.

Fabrication of Evidence
The video is evidence there was no mutual assault. The video that proves I was assaulted and
there was no mutual assault. The video shows I did not assault Delita Hooks as she stated in her
false cross complaint. There is no mutual assault as Det John Vergona and Delita Hooks
fabricated. In Ms Hooks false cross complaint she says falsely I attacked her but once she and
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her alleged NYPD helpers get on the same page her letter which Ms Nam does not share in her
motion to dismiss holds the threat that if I file assault charges again she will retaliate by filing
assault charges. Ron Kuby’s letter on my behalf shouts coercion in the most clever way we
need to understand there are so many checks and balances and my perception as to why Ms Nam
writes me all her clients want her to defend Det Vergona.
The video is powerful proof evidence that evidence was fabricated with the goal to
coerce me to drop charges or retaliate against me with false imprisonment on the
Sabbath 19 days after I was savagely attacked at the MD’s office when Ms Hooks could
have closed the door but aggressively starts her attack holding the door for balance.

Commissioner Ray Kelly , has 43 years experience serving the NYPD, Chief Campisi at
least 20 years but is bio on the NYC gov website is blank, DI Ed Winski aprox 20 years,
 Lt Burgos at least 20, Det Vergona at least 20, Det Andy Dwyer 16 years who is
carefully not referred to in evidence Ms Nam shares in her motion to dismiss; all have
on average at least 20 years and all the defendants including Lt Agnes and IAB sgt
O'Donnell and Sgt Chen, agree retired NYPD Det Vergona must be represented by
their lawyer Ms Nam and to serve Mr Vergona at 1 Police Plaza however, the
video is proof I never assaulted Delita Hooks, before and after the assault photos,
and the medical reports prove Delita Hooks committed a serious crime of a false
criminal report framing her victim, me with all NYPD helping her in my opinion
joining her effort fabricating the the false report stating I attacked her in to mutual
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assault. Ron Kuby's letter short hand for I was coerced using the words I agree
to drop the charges against my attacker if my attacker drops the charges alludes
all these NYPD veterans including Ray Kelly -- from his wiki page : 
“He also holds a juris doctor from the St. John's University School of Law,
[7] a LL.M. from

the New York University School of Law,[8] and an M.P.A. from

theHarvard Kennedy School.[9]”

Ray Kelly prides himself on expanding aka spending mega millions of taxpayer dollars
on Internal Affairs yet he and Charles Campisi agree I was not coerced despite
evidence to the contrary and notify me through their lawyer they want the tax payers to
pay for Det Vergona's defense!!!!

From the wiki page:
“Mr Kelly has an education in law and I have none but he took an oath to uphold The
Constitution and my case proof he didn't keep his oath to uphold The Constitution  if
Illegal Stop and Frisks and mass false arrests of Protestors during Republican
Convention and OWS weren't enough evidence. “

Why would Mr Kelly request retired Det Vergona be defended by his lawyer?   I was
coerced and sent a message to shut up and to instill fear in me which they succeeded in
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doing until I filed a Notice of Claim and begin embracing suing for the first time in my 50
year old life.

The same Det Squad succeeded in silencing Jane Doe a 9-11 whistle blower (page 32
of my lawsuit). I also allege Dr Fagelman just like Michael Rawson and Bill Rudin (Bill
Rudin is not referenced not by name but he was discussed in conversation with Det Del
Pozo page when I call and Det Vergona is not in and also his name on protest sign in
photo shown before I am attacked in email I sent Vergona (evidence section page 1 in
back of this motion) put in calls either directly to the NYPD or in Rudin's case the Rudin
family has a retired NYPD commander on the payroll who I witnesses instructing an 06
police officer to not ticket. ( I reference me wearing a sign in my lawsuit -when I am hit
by Delita Hooks and the sign says Rudin which can be seen page 1 evidence section).
My private investigator asked Dr Fagelman did you talk to the police and he responded
no comment as if in my opinion he had something to hire. If we move to trial I would
subpoena Dr Fagelman, Delita Hooks and women in the videos phone records and
emails.  In my opinion IAB wanted to close this for fear of a Chief Marino aka Adrian
Schoolcraft kidnappers HGH illegal usage or a Bill Rudin type.  From commissioner Ray
Kelly on down I allege they retaliated against me for being a whistle blower. 

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If we ask Mr Kelly under Oath and all defendants to please show us the mutual assault,
they can't because the mutual assault was a fabrication of evidence.  

Ask Mr Kelly besides his great legal education and insights how about simple Integrity
and again please show me where is the mutual assault. Like the NYPD Rape Cops he
could own up to the fact the video and enormous evidence presented despite no access
to IAB and NYPD files on me, Delita Hooks and all officers involved is enough to prove I
was savagely assaulted and can be seen retreated from Ms Hooks savage attack of me
a medical patient. 

Below more evidence into opinion that Ray Kelly runs the show and it is corrupt where
coercion is a police tool not a crime because Mr Kelly insists on the City Defending
retired Vergona.  I believe all detectives involved worked with Ms Hooks and certain
figures from medical office including women in the video with the goal to fabricate
evidence and than seal the NYPD's wrong doing aka coercion with Delita Hooks crimes
if assault and a false cross complaint with Ray Kelly's blessings as he approved Mr
Vergona's legal bills because I exposed Mr Kelly's boss mayor Bloomberg's corrupt
actions pushing SAIC and HP like a drug king pin pushes heroin; the same mayor who
gave Mr and Mrs Kelly free rides and who Mr Kelly hoped would help him with a job in
The White House which is not going to happen. 
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An NYPD Inspector General? Leonard Levitt  June 18, 2012
"Kelly refused to allow CCRB investigators to question supervisors of the mass arrests
at the 2004 Republican National Convention. Mayor Michael Bloomberg said or did
nothing to force him to comply. [See NYPD Confidential, Sept 16, 2005.]

Kelly also sidelined the other city agency charted with monitoring the police department:
the Mayor's Commission to Combat Corruption.

In 2005, the commission's chairman, Mark Pomerantz, requested departmental crime
statistics to investigate claims of systemic crime-downgrading. Again, Kelly refused to
comply. Again, Bloomberg said and did nothing. Pomerantz resigned in protest. [See
NYPD ConfidentialApril 22, 2005.]

Despite beefing up Internal Affairs, final decisions are made not by its longtime chief,
Charles Campisi, but by Kelly."

I am alleging that Det John Vergona fabricated evidence knowingly and
with malice using Dr Andrew Fagelman's receptionist Delita Hooks  false
cross complaint to false arrest me  and or coerce me to drop charges acting
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with Ms Hooks as well as the other NYPD  detectives to send me a message
with all parties wanting to silence me.  If I was incorrect why didn't one
detective go to IAB and blow the whistle.  IAB Lt Fikru said the video
speaks for itself but his job was too investigate IAB Sgt Mary O'Donnell.  
The detectives all had access to the video and Delita Hooks false cross
complaint and did not go to the DA or to IAB.   I believe by gaining access
to all files, mine, Delita Hooks and NYPD and IAB files including of the
officers I can prove this even more but I think my line of reason is strong
enough since Delita Hooks was not arrested immediately.

On page 3 of 11 of Ms .Nam’s motion to dismiss “Complaint Follow Up
Informational Review Telephone --- Det John Vergona states falsely -- he
writes “the two struggled to the ground”. That is a blatant lie and I never
said that in our conversation. I question where he got that from?

I now

have a copy of Delita Hooks false criminal report thanks to my “incessant”
hard work and unwillingness to give up. There is proof of fabrication right
there as well. Delita Hooks has motive to lie but in Det Verogona’s notes
from Oct 4 phone conversation Ms Nam omits the fact we had a series of
phone conversations which I have phone records to prove that correspond
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to the first cyber attack on a YouTube not of the assault because I had not
posted it and when I call him to tell him he as if on cue had turned abusive
so the first call Ms Nam shares notes with he understands I am the victim
and told me I had a right to defend myself. The 2nd in a series of calls from
NJ where I a with my Dad but standing outside hiding these calls from him
as not to disturb him because it was very disturbing that I was being
harassed and I alleged “tampered with” witness tampering and I allege on
cue Det John Vergona has joined in now stating he doesn’t understand why
the photo shows my right eye. The series of calls on Oct 4 that Ms Nam
does show us one note summing up my allegation -- there are no notes with
all the conversations where Det Vergona refuses to allow me to come in and
show him my eye and the damage to my neck and defensive wounds to my
arm. His partner puts me on hold for extended amount of time and than
again in a mocking manner asks are you still there like they are enjoying it.
The conversation before without telling me his partner’s name he put the
partner on the phone and had him tell me which eye did the photo show
and the partner said right. They refused to understand or could not
understand that photo booth flipped the image and made it clear they
didn’t care if I had two black eyes and did not want to meet me joining the
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aggravated harassment on YouTube that I alleged Det Vergona and his
accomplices joined fabricated evidence that I was at fault when I was not.
There is nothing I or any patient could do to be verbally assaulted and than
physically assaulted and Det Vergona, NYPD, IAB, the Integrity Bureau,
head of IAB Chief Campisi and commissioner Ray Kelly can all see Delita
Hooks hand on the door she could have closed but instead uses the door
know to begin the physical assault proving there was not mutual assault Det
Vergona and associates agreed to fabricate to send me a message and fix
this violent crime. Assault an NYPD officer or an MTA worker and you will
be punished more than if you assault the average citizen yet there is no
special protection for medical patients and there should be. For Delita
Hooks to assault a medical patient and lie to the police is like hitting a
person in church -- it just isn’t done but for the NYPD to coerce me to drop
charges using fabricated evidence making over Delita Hooks false cross
complaint is also egregious like “elder abuse” or hitting a child -- violence of
a patient is particularly offensive and Det Vergona along with Ms. Hooks
fabricates evidence because the video and all evidence I submitted prove
without a doubt there was no mutual assault that Det Vergona stated via
verbal violence that he would arrest me if I didn’t drop charges. When he
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calmed down he said he would arrest us both but again all information on
Ms. Hooks being contacted to turn herself in is omitted or does not exist
because the police worked as a group with the MD’s office and Delita Hooks
my attacker to fabricate evidence making over her false cross complaint
into a mutual assault. Ms. Nam via our first phone conversation states her
(false) cross complaint is sealed. We see nothing in her clients notes about
Delita Hooks false cross complaint along with her clients crime of coercion
sealed within less than a year. Why? It would incriminate her clients
because they sealed Delita Hooks crime with their own coercion.

The NYPD and Delita Hooks I allege work together because 1) there is fabrication in
Det Vergona’s DD5 Ms. Nam submits as we did not “tussle to the ground” and he omits
a series of calls through out the day were he turns very abusive refuses to meet me to
see the damage to my eye and 2) Delita Hooks false cross complaint states I attack her
and more proof of Det Vergona, Ms Hooks and “her detectives” who Ms Nam omits all
notes from her motion to dismiss I allege work together so Ms Hooks letter to dismiss
now no longer states I assaulted her but that if I file assault charges again she will fiel
another (false) cross complaint so she is changing her story from her lie I attacked her
to her lie it was mutual. IAB Sgt O’Donnell read me the letter ghost written for Ms.
Hooks signed by Ms Hooks and the letter is yet another threat just more civil than her “I
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will slap the crap out of your ass” before she begins her savage attack on me as I held
two bags I was unwilling to put down and my phone.

She struck me with her hand and

phone, her key damaged my left forearm and she threw her shoe at me before she
grabbed my hair with the goal to drag me down the hall to the elevator by my hair until I
finally began to defend myself the bare minimiun There was nothing “mutual” but the
NYPD working with Ms. Hooks fabricated evidence and Ms. Hooks letter Ms. Nam is
careful not to share shows her and her NYPD collobrators intent to fix this making it
over for Ms. Hooks in to a mutual assault. What they NYPD and IAB officers involved
including Mr. Kelly and IAB Chief Campisi did not count on is I would go in almost one
year later after Ms Nam told me there was no assault and I had no case is report
assault in the 2nd degree and was turned away told the First Precinct Det Squad refuse
to allow me to upgrade my case but the case is now open. By refusing me the right to
upgrade my allegations to 2nd degree assault I allege they NYPD yet again violated my
1st and 14th amendment right denying me every right of all Americans including a
criminal like Delita Hooks right to file a false cross complaint which is a serious crime as
is assault.

I allege the NYPD are working with Ms. Hooks and Dr Fagelman to protect her from her
arrest which is why they sealed her false cross complaint and met with her and refused
to meet with me. Det Vergona called her as Ms. Nam shares with us but Ms Hooks
detectives never contact me because I allege they worked together as a group to deny
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me due process and take my case to the DA and instead fabricated Ms. Hooks false
cross complaint in to a fabrication of evidence of mutual assault and Ms. Hooks letter to
the NYPD shows she is confident the NYPD have her back despite the video proof she
lied and filed a false cross complaint. Her letter to the NYPD now no longer states I
attacked her but echoes Det Vergona’s statement that is is in his words “even steven”
when in fact it was not proving in my opinion they worked together Det Vergona, Ms.
Hooks and other NYPD and I alleging Dr Fagelman’s “hook”.

Det Vergona committed a serious crime when he coerced me making her false cross
complaint stating I attacked her in to mutual assault. I contacted IAB asap after he
finally succeeding in coercing me Saturday Oct. 20th to drop charges.  There was no
mutual assault.  She attacked me. I retreated as the video states.  She is so verbally
abusive and shocking before I started filming violating my patient rights I started filming
her alerting her first which gave her amble time to close the door.  Instead she becomes
more abusive and you can hear me say would you say that again? 

Ms. Nam omits all of Det Andy Dwyer’s notes as if he does not exist but I
allege she does so to protect her clients, her job to do so and that his notes
would underscore my allegations that all the detectives worked with Delita
Hooks and all the women in the video with the goal to coerce me to drop
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charges and knowingly and will malice did so with fabricated evidence
Delita Hooks false cross complaint that Det John Vergona and his partner
who’s name I do not have and Det Andy Dwyer and his partner who’s name
I do not have willfully and with malice made Delita Hooks false cross
complaint a very serious crime over in to “mutual assault” and the video
proves the NYPD fabricated evidence and coerced me to drop charges and
that Mr. Kelly and IAB Chief Campisi and all IAB involved are protecting all
NYPD involved in serious crimes of coercion and fabricating evidence as I
never assaulted anyone. I had Ron Kuby one of the most successful lawyers
when it comes to suing the NYPD willing to represent me if I did not drop
the charges and sue on my behalf. We only dropped charges because of my
health deteriorating and serious vision problems. Dr Young saw the hole in
my retina and had me clear my schedule Friday before I was suppose to
turn myself in Oct. 20 to be false arrested and further humiliated and
abused for not dropping charges but did because I was having vision
problems. severe weight loss, serious neck problems from Delita Hooks
giving me bulging and herniated disks on top of a serious arthritic
condition so we decided for my health to not put me through Det Vergona’s
abusive retaliatory action of false imprisonment his punishment putting me
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through the system as if I was a criminal when I was clearly the victim of a
savage attack at a doctor’s office as the video proves. That Internal Affairs
from Chief Campisi on down in IAB in my opinion are protecting criminal
behavior on behalf of the NYPD who I am alleging not only did this to me
but I am alleging that fabricating evidence and coercion is emblematic of
NYPD corruption as if perjury called testiflying. The video of me being
assaulted proves everything I am saying. I am alleging IAB who is
obligated to investigate Police Corruption did not investigate this refusing
to interview me and meet me with evidence because they don’t want to
leave all of Det Vergona and his co-workers and supervisor’s work open to
further scrutiny but allow them to retire in Det Vergona’s case with historic
over time thanks hugely to OWS.

In Ms. Nam’s Motion to Dismiss she gives us Lt Burgos’s notes Feb 7, 2012
he opened my case for 22 hours. He defines me an “uncooperative
complainant” and how am I uncooperative? Uncooperative because I won’t
cooperate with NYPD fabricating evidence and also committing a crime of
coercion? Lt. Burgos did not respond to my emails asking for badge
numbers and ditto to everyone senior ranking NYPD IAB and Mr. Kelly
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listed as defendants. Lt. Burgos did not call me just like Det Andy Dwyer
Ms. Hooks detective and why? Because the NYPD involved knowingly
fabricated evidence as the video proves I was assaulted there was no mutual
assault and by not meeting with me, returning calls including Lt Agnes of
The Integrity Bureau the goal was to succeed in the group agenda to
fabricate evidence and coerce me the victim of a savage attack at the MD’s
office to drop charges on behalf of the medical office to help them especially
since Dr Fagelman did not fire Delita Hooks as he should have just like the
NYPD did not arrest Delita Hooks as they should have and I allege both the
doctors’ office and the NYPD conspired together to falsify evidence hence
the NYPD involved sealing Delita Hooks false cross complaint as Ms Nam
told me in our first conversation Delita Hooks complaint is sealed which
should be noted is as shocking as the NYPD coercing me to drop charges.
The NYPD do not seal allegations in under on year as a rule. Why would
they? Because the NYPD wanted to seal her false cross complaint, their
fabricating her false allegations in to “mutual assault” and the NYPD crime
of coercion.

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Det John Vergona is allowed to lie to me but he is not allowed to fabricate
evidence and on page 3 of 11 he states I was punched in the eye and right
there should have been enough to arrest Delita Hooks along with the video
that goes black upon impact and you can see impact of some kind as the
camera shakes and you can hear her co-workers scream NO DEE DON”T
DO IT but instead she is not arrested but I allege Delita Hooks and Det
John Vergona along with the other NYPD worked to fabricate evidence
portraying me as a criminal rather than a victim and her savage attack was
mutual so where her serious damage? There isn’t any because I would not
put down my bags and phone and pulled my body as far from her as you
can see in the video I move as far from her as possible. On page 3-11 Det
Vergona’s first notes right away I find he has fabricated his notes on page 3
of 11 in Ms Nam’s motion to dismiss, omits the series of conversations that
include him stating he didn’t care if I had two black eyes and was clearly on
Oct. 4 no longer treating me as a victim and Ms. Nam does not share Det
Andy Dwyer’s notes. We learn Det Vergona got my complaint on the 2nd
the same day Delita Hooks filed her false cross complaint but calls me on
the 4th. Delita Hooks false cross complaint is referenced in my lawsuit
and now I have Delita Hooks false criminal report a summary of the false
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cross complaint and just like Det Vergona’s notes from our phone
conversation it is one complete fabrication except for the fact she admits
she had a heated verbal fight with a medical patient and what reception
does that let alone punches, kicks, slaps and rips out a patients hair and
than along with co-workers all yelling No Dee don’t do it collectively lie and
blame the patient and than the NYPD join in modifying her falsified assault
allegations that they know is a serious crime along with assault and Det
John Vergona with his partner and two other detectives known to me as
“her detectives” since on Oct. 16th when I agreed to false arrested and made
it clear to Det Vergona yes I agreed to be false arrested with using a false
cross complaint Det Vergona and accomplices made over in to mutual
assault. Delita Hooks provoked me to first seek help and than 2ndly start
filming to document her outlandish abusive and unprofessional behavior.
If I didn’t film and told you she threw her shoes and told you she said I will
slap the crap out of you, that when she said get out, I was outside her hand
on the door, would you believe me or 4 women from the shared doctor’s
offices? That is how important the video is and the NYPD value video so
much they are upgrading TARU to 30 -40 million dollar video system called
Domain Awareness (page lawsuit) but my video they ignored with malice
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to degrade and humiliate. Ms Nam does not share Delita Hooks false
criminal report but I do and there is another interesting clue in Ms Hooks
false criminal report. She lists the medical professions of the doctors in the
office but leaves out “dermatology” as if my MD doesn’t exist underscoring
who am I, I have no rights as if Dr Vine’s patients are not part of her office
perhaps why she told me I have no rights? Without subpoena power and a
trial where I can question all involved including Ms. Hooks and all NYPD
who’s faces I don’t know and badge numbers I allege I would have more
information and if we have a trial enough to have more than one NYPD
officer arrested for coercion but for now with what I have lets look further
in to the coercion allegations Ms. Nam claims I haven’t proved.

All detectives involved, they all saw her false cross complaint and the video
and they all knew it was not mutual assault as well as I did not attack her
and all should have agreed to not violate my due process and coerce me to
drop charges, fixing crime and fabricating evidence and go to the DA. You
can read my report and my blog has the telling of what happened to me
over and over and I never say the two of us struggled to the ground ever.
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Mysteriously it is in John Vergona’s first interview with me. Dr Vine came
to me immediately as the women ignored me though I had clear injuries
from their co-worker’s attack and Det Vergona refused to interview Dr Vine
because I allege that would have ruined his goal to fabricate evidence as I
found fabricated on page 3 of 11 in Ms Nam’s motion to dismiss. Also Det
John Vergona and his lawyer omitted the rest of the phone conversations
that day because Det John Vergona was than acting on behalf of my
attacker Delita Hooks even refusing to believe I was punched in the left eye
and if he had documented the phone conversations that very same but
already he was beginning to fabricate evidence repeatedly refusing my
requests to come to the first precinct and it should be noted I have my
records of repeatedly phone that afternoon which was Oct 4 and it should
noted the NYPD involved in supporting fabrication of a mutual assault and
coercion met with Delita Hooks but refused to contact me even via despite
her allegations I attacked so I am implying they knowingly fabricated
evidence rather than interview because “the fix was in.”

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There is something called a DD5 which is a follow-up report detectives due
when they interview witnesses and if we move to trial I will subpoena this
along with my NYPD and IAB files on me, as well as Delita Hooks and all
the NYPD officers involved because I also want to at other cases “they
closed”.

I am alleging that Det John Vergona fabricated evidence making this in to a
mutual assault knowingly and with malice using Dr Andrew Fagelman's
receptionist Delita Hooks false cross complaint to false arrest me instead of
taking her false cross complaint to the Manhattan DA as an ethically police officer
would have. Det John Vergona yelled at me you are going to drop those charges
or I am going to arrest you! He did say as an after thought he would arrest me
and arrest her but we see no dates and confirmation that he and “Delita Hooks”
detectives who met with her and never contacted me and as already sited Det
John Vergona repeatedly refused to meet with me Oct 4th when I practically
begged him to allow me to come to the First Precinct so he could see the wounds
to my eye and the defensive wounds to my left forearm. He refused. Why? I am
alleging he and the other detectives never contacted Ms. Hooks to turn herself in
Tuesday Oct. 16th when Det Vergona stated I must immediately come down to
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the precinct to turn myself in and I agreed and made it clear to him it is a false
arrest and a Judge will take one look at the video and he or she will dismiss the
charges and I would sue him. Ms. Hooks was not notified to turn herself in than
and than when I called back 10 minutes later and Det Vergona decided I must
wait until Saturday I am alleging she was not notified to turn herself in Saturday
because I am alleging she and Det Vergona along with the other detectives
involved agreed in concert to falsify evidence at the video, the photos before and
after, the medical reports and even Ron Kuby’s letter which defines Ms. Hooks as
“my attacker” clearly prove I was the victim of a violent assault and the video
clearly shows me backing away not fighting back as she hits me repeatedly, the
camera shaking before shutting off as she lands a running punch to my
eye making a hole in my retina as I held two bags one with a glass ipad which did
not shatter but could have and my arm numb from 2 injections while I held my
iphone in my right hand.

The video now on YouTube posted 3 days after the assault Oct. 4th, 2012 after it
seemed clear to me that Det John Vergona was no longer treating me as a victim
but was behaving like Deilta Hooks and her pals that were beginning what would
be what I allege is 10 months of aggravated harassment and witness tampering
which stopped once I filed the lawsuit. It should be noted that Det John Vergona
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stated she should not contact me and I should not contact her and I should not
contact him as if he and Delia Hooks where partners.

I posted the video which I sent to Det John Vergona Oct. 4, 2012 after I
first conversation along with photos before and after including showing defensive
wounds on my forearm and damage to my eye, fax from my MD which was
followed up later with fax from spine MD damage to cervical spine bulging and
herniated disks.
Det John Vergona in our conversation where I agreed to be false arrested Oct 16,
2012 stated this.

That video is something.
Ron Kuby said to me. The video is powerful
I am alleging that the video is proof that Det John Vergona fabricated evidence with the
goal to violate my rights because he saw me as someone not worthy of basic rights and
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deserved what I got. He said You should have kept walking. At that point he too is making
it clearly he blames me for Delita Hooks savage attack and that I got what I deserved.
(Thank G-d I wasn’t a rape vicitm but it sure felt like a gang rape on some level and her barefoot
was pressed against my vaginal area.)

I am alleging that Det Vergona’s behavior was verbally violent and hateful of me and he agreed
with the “misogynist lawyer sock puppet comment” that I was a fight picking c/nt since he never
said a word about that and my allegations of possible witness tampering and the video proves
Delita Hooks is the aggressor. Delita Hooks could have closed the door. The video shows me
backing away not engaging in a physical fight and or mutual assault. Delita Hooks provoked me
to film to document her abuse of me and my patient rights and her behavior so shocking without
video words could not do Justice. Without video it would have been her word, the women in the
video and the NYPD and IAB against me that it was a mutual assault which is a fabrication of
evidence.

I am alleging that Det John Vergona helped Delita Hooks my attacker as Ron Kuby clearly
defines her in a letter he wrote 2 days after I was coerced to drop charges Oct. 20, 2012 and
informed him I went to CCRB and IAB to knowingly coerce me in to dropping charges. You can
hear me warn Delita Hooks not to touch my body. She is so perverse she does not care that I
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explained that is assault. She goes over the top to touch my body as hard and aggressively from
my face to my hair to my vaginal area with her bare foot with the goal to slap the crap out of my
ass and to drag me down the hall like a bouncer. You can hear her say got out but I was out and
she could close the door. It seems Det Vergona want to violate me and degrade me as her agent
telling me I assaulted her and to not contact her. I have never contacted her and I didn’t
appreciate being spoken to like a criminal. He told Ron Kuby that I am not to contact him
either. Interesting huh? As if he and Delita Hooks are both my victims or that he and Delita
Hooks are both working together. I asked him why he didn’t go to the office like he said he
would. He said he did not have to because “her detectives went” and they did not have to talk to
me since he talked to me. Note non met with me and Vergona Ms. Hooks agent in my opinion
repeatedly refused to meet me me to see the damage to my left eye although he was confused as
to which eye I got punched in because Apple’s photobooth flipped the image but he never
accepted that even with the email I forwarded to him from Apple yet refused to meet with me.
The NYPD only met with my attacker and I allege to act with her to coerce me to drop charges.
She is so confident the NYPD will protect her when she files a false cross complaint as the video
proves her criminal report included in the evidence section proves her cross complaint is false
that I allege in her letter ghost written and signed by her she states she will in so many words
retaliate against me yet again and file yet another (false) cross complaint against me if I file
assault charge against. She has no fear making this threat and someone educated has drafted this
letter for her as you can see in the evidence section Ms Nam shows us the NYPD marked her off
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as not having a grasp of English which I find interesting as she is the office manager and
receptionist for the MD but my point is that when Det John Vergona says he doesn’t have to go
to the office because her detectives do and they don’t have to talk with me (let alone no one in
the NYPD is willing to meet with me) I am alleging that Det Vergona, his partner who’s name
and badge number I do not have and the detectives called “her detectives” worked with Delita
Hooks fabricating evidence. She states in her criminal report that I attacked her which clearly I
did not as you can see in the video so I am alleging the detectives as a group just like they
decided to not meet with me, that Det Vergona didn’t have to go to the office and her detectives
didn’t contact me all also worked as a group with Delita Hooks and her false cross complaint
with the goal on behalf of Delita Hooks to fabricate evidence making her complaint over in to a
mutual assault when in fact it was not.

Det John Vergona states Oct. 16 he just learned Delita Hooks filed a cross complaint. I believed
he was lying to me and the reason is his co-conspirators the other set of detectives never
contacted me in the 2 weeks they had Deilta Hooks false cross complaint because I am alleging it
was decided they were not going to investigate this case but fix it and coerce me to drop charges
on behalf of Delita Hooks with the goal to fabricate evidence and make her savage attack and
false cross complaint two serious crimes in to fabricated evidence of a mutual assault. There are
so many checks and balances yet all failed because the NYPD and later IAB including the

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Integrity Bureau ala Lt. Agnes wanted to send me a message to shut up and keep my head down
and stay out of trouble which is what Det Vergona said to me in so many words after

Det John Vergona knowingly used Delita Hooks false cross complaint to threaten me twice with
false arrest and I made it clear I have never assaulted anyone in my life. I did not assault her.

Det John Vergoan yelled at me You are going to drop those charges or I am going to arrest you.
I also dropped the charges because he threatened me with loud harsh voice which was a verbal
assault and by Saturday when I finally dropped the charges his verbal assault and abuses on the
phone with the further decline of my health and worsening vision in my left eye made me afraid
of Det Vergona and what he had in store for me to further degrade, humiliate me with his goal to
false imprison me and put me through the system despite the fact I was a victim of violence at
the doctor’s office and now his victim yet he told me that I should not contact him or Delita
Hooks when he should have been arresting her for assault, a false cross complaint, alleged
witness tampering and alleged aggravated harassment with I am alleging agents on her behalf
including the NYPD also agents coercing me to drop charges acting on her behalf because they
did not go to the DA with her false cross complaint but used it to fabricate evidence.

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I am alleging that he violated my rights, abused his power an his statement an admission of
fabricating evidence to false arrest me and or coerce me a violating of my rights to fix this crime
and close this case. You can hear IAB Sgt Mary O’Donnell on audio stating “case closed” and
refusing to investigate why I would drop charges. I didn’t know Ron Kuby had worded the letter
I drop the charges against my attacker. I believe Ms O’Donnell in reading my letter careful not
to show me the letter never used Ron Kuby’s words “my attacker” which were a red flag to any
honest cop.

I am alleging that Delita Hooks abused my constitutional rights, patient rights and my repeatedly
violating my body and than the aggravated harassment began on line another form of violence
with the goal on behalf of Delita Hooks to in what feels like yet another form of violence
because I was clearly the victim and a patient and she had no right to do what she did to me -and instead of the NYPD investigating aggravated harassment and witness tampering they took
over acting with Delita Hooks and Det John Vergona used verbal violence yelling at me
threatening me with false arrest if I didn’t drop the charges working with Delita Hooks who was
confident she could walk in and file a false cross complaint. Det Vergona tells Ms Nam he spoke
to Ms Hooks once? Well he told me the 2 sets of detectives worked together as one unit hence
no need to go to the office or for her detectives to call me and I allege they as an ever expanding
group worked on behalf of Delita Hooks and her employer who did not fire her to coerce me to
drop charges fabricating evidence. My first conversation on the phone with Ms Nam she tells me
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Deilta Hooks false cross complaint is sealed. I allege it is sealed because both sets of detectives
wanted to seal her crimes of assault and false cross complaint with their own alleged fabrication
of evidence and coercion.

IAB Lt. Fikru who only contacted me to discuss IAB SGT Mary O’Donnell said the video
speaks for itself.

I am alleging that Det John Vergona as part of fabricating evidence against me did a
criminal background check on me as per his admission after his verbal assault yelling at me
if did not drop charges he would arrest me!
Oct 16, 2012 during 2 disturbing phone conversations, Det Vergona stated it was “even
steven” but Delita Hooks false criminal report I obtained only recently with persistence and
hard work proves Delita Hooks falsely reported in her cross complaint I attacked her and
pushed her to the ground. Det Vergona fabricated a “mutual assault” a term IAB Sgt
Decker explained to me when he told me Lt Agnes would interview everyone and just like
det Vergona that never happened because I allege evidence was fabricated by Delita Hooks
and Det John Vergona either in the one phone call Ms Nam tell’s us he made. We are given
no date or content so was it before -- I will take care of this for you --- from the man that
told me he didn’t care if I had two black eyes or after working together with Delita Hooks
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detectives, Vergona called after and said you don’t have to worry any more? Did he say I
understand why you did what you did. His behavior was so strikingly similar his verbal
assault was like an emotional pistol whipping but I did not give in until a famous criminal
lawyer Ron Kuby familiar with police corruption and abuses expressed concern for my
health and made it clear Det Vergona wanted to punish me.
An honest NYPD officer who I told about Det Vergona coercing me to drop charges told me
it is hard to do now a days because there are so many checks and balances.
In Ms. Nam’s motion to dismiss she omits Det John Vergona’s records and notes of phone
conversations on Oct 16 when he emotional pistol whipped and said I assaulted her and I
said I never assaulted anyone in my life.
Where are Det Vergona's notes 2 phone conversations where on Oct 16 he twice got
me to consent to false arrest Oct 16 and I agreed twice to be jailed rather than drop
charges and even wait until 0ct 20 a Saturday!

Det Vergona was so committed to fabricating evidence we talked Oct 16 and he refused
to interview dr vine and her medical
Asst.  he said they did not witness the crime.

Why did the medical asst break in when Dr Vine was with a patient completely
undressed?
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Why did Dr V rush to me.  Why did she demand Delita Hooks be fired.  Why did she and
her partner move out.   Det Vergona did not want to know because it interfered with him
fabricating evidence.  
He said the women in the video all said it was me.  Why didn't he show them my video
and warn them under oath it is perjury especially Delita Hooks?  Why? Because he was
committed to fabricating evidence on behalf of Delita Hooks and her employer as well
as send me a message to be silent and stay out of trouble.  Stop babbling or as IAB
says via Ms Nam stop incessant emails. The emails are about serious crimes and fixing
including IAB's shocking role.

Ms Nam’s letter on behalf of Det Vergona proves as a group they are sticking together
including protecting Det Vergona from a criminal charge of coercion as well as any
investigation in to allegations of bias and prejudice including anti-Semtism and misogyny
including I deserved what I got. He said I should have kept walking. Ms Nam makes no
mention of Det Andy Dywer and why he never called me. We don’t have a date of the one
call to Delita Hooks by Det Vergona but we know Det Vergona never went to the office as
he promised to via telephone calls and one email where he says he understands my
frustration which is shocking because he showed me no understanding or concern for the

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violence inflicted on me as a medical patient and the seriousness of the injuries to my eye
and neck and how I got the long defensive wounds on my arm.

Did Det John Vergona fabricate and fix this crime alone? I believe he acted in concert with
Delita Hooks and what of Det Andy Dwyer who IAB Mary O’Donnell tells me is Delita
Hooks Detective in a meeting we had pre the audio recording submitted. Why does Det
Andy Dwyer go to the office and upon learning there is an allegedly violent patient
attacking medical staff make no call to talk to the suppose violent patient? Why? Why
does Det John Vergona refused repeatedly to meet me Oct. 4th when he has turned abusive
telling me I don’t care if you have two black eyes since he is confused by the photo taken on
a MacBook which in photo shop flipped the image. Why is there only one call to Delita
Hooks when in theory if it was a mutual assault and I agreed to be false arrested twice, Det
Vergona had to make a series of calls to her and the other NYPD involved okay Ms. Troy
agreed to be arrested Oct 16 and Oct 20. Why does Ms. Nam’s letter carefully worded state
the defendants all want Det John Vergona defended by the City of NY aka the tax payers?
Because there are so many checks and balances as an honest cop told me I am alleging they
all knew at the time or as soon as they were alerted in the case of commissioner Ray Kelly
rather than take responsibility and do the right thing, which he did in the case of the rape
cops, I am alleging they all went along with I got what I deserved and Ms. Troy has no case
since she did not go through process of false arrest so we can get away with this case
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dismissed meaning I am alleging Det John Vergona was the front man for fabricating
evidence boldly and with the consent of all at the time or the blessing of all after because
they want me, a whistle blower to be sent a message. In Ms Nam’s motion to dismiss she
mentions even more police officers involved on behalf of Delita Hooks who’s names I have
never heard but none of them contacted me. All of them had to know something was wrong
including that their supervisor and the lead detectives never met with me but met with
Delita Hooks. That Det John Vergona called Delita Hooks but Delita Hooks detectives
refused to contact me and were not even curious what I had to say just like no one was
interested why I came Oct. 20, 2012 to report a false cross complaint by my attacker Delita
Hooks. No honest cop was interested enough to allow me to file a report. If I was lying I
could get arrested for that. Not one honest cop and or supervisor contacted IAB either
despite the large sign at the front desk.

To underscore my allegations why did Sgt. Chen, Lt. Burgos, DI Ed Winski, Chief Esposito
, Chief Campisi, commissioner Ray Kelly and his office all ignore my request for Sgt
Chen’s and Det Vergona’s badge number. I even left Sgt Chen a message with a detective
the comptroller’s office investigator asked for their badge numbers may I please have
them. I am alleging the NYPD often do this and are confident they can get away with
“creative policing” and not obeying protocols to do either fixing and favors or to send a
message all illustrated by the NYPD Ramos case now in front of a jury in the Bronx, the
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Adrian Schoolcraft Tapes, as well as countless other examples including other NYPD
officers like Det Harold Hernandez (page 52 lawsuit Det H referenced) (NYPD Tapes 3: A
Detective Coes Forward About Downgraded Sexual Assaults June 8, 2010) who retired in
disgust and anger when he learned his fellow officers were down grading rapes by a serial
rapist to robbery. All involved in my case I allege were are confident they can get away
with the common practice of creative policing and sending a message. In my case the sent a
message and it was on behalf of a long list that can be found in my list of why the NYPD
and IAB would retaliated against me in this motion to not dismiss my case. In the Adrian
Schoolcraft tapes you can hear his commander tell an African American man trying to
report his car was stolen being told by the commander he would not take the report and the
reason is the man had a criminal past and got his karma.

If I had access to all the files including Delita Hooks and mine, all the NYPD and Internal
Affairs file on me as well as all involved I could tell you more but the video, Delita Hooks
false cross complaint, the medical records and photos and the fact Ron Kuby had to call the
First Precinct Det Squad Saturday the day I agreed to turn myself in and I made it clear
agreeing Oct. 16 and Oct 20 to be FALSE Arrested since the video shows I did not touch
her as she took the verbal assaults and threat to cause me bodily harm to reality. The video
shows me backing away even defining her action as assault and telling her not to touch me
but she does again and again. The camera is literally shaking from the violence of impact
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to my eye and shuts off but not before you hear her co-workers repeatedly scream No Dee
don’t do it and this alluded seasoned NYPD detectives many on the verge of retiring. Det
Dwyer on his linked in page is close to 20 years. DI Ed Winski about 20 years, etc.

When Det John Vergona yelled at me he made it clear it was a group against me with him
at the helm. He defended the fact he did not go to the office as he had promised stating he
did not have to since the receptionist’s detectives went to the office. He said they did his
work and by interviewing me he did their work and that the women all said it was me so he
it appeared they were working as a group to fabricate evidence to coerce me to drop
charges and or to false arrest me yet we have no documentation from Ms Nam to Ms Hooks
being notified to turn herself in and than being called or is at the police station Oct. 20th
when I agreed to be false arrested because the fix was in and they worked as a group with
malice and bias using fabricated evidence as the video, photos before and after, medical
reports and medical damage from assault on going still be treated proof there was one
victim and that was and is me victimized by Delita Hooks, the women in the video Det
Vergona told me said it was me and Det Vergona’s NYPD associates as well as IAB who

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continues to protect Det John Vergona as Ms. Nam’s letter stating the defendants agree to
defend Det John Vergona.
The video clearly shows I am not the aggressor and I did not assault Delita Hooks yet I am
alleging Det John Vergona took sadistic and misogynist pleasure in his verbal abusive
telling me the lie I assaulted her treating me as a criminal not a victim with of a serious
injury at a medical office.
By Det John Vergona admitting he did a criminal back round check on me when I did not
commit a crime I questioning whether Det John Vergona violated State Laws. It should be
noted I have no criminal background and never even got a detention in high school.
I requested files including Delita Hooks and my own as well as all NYPD and IAB involved
would help me to prove my case but I paid a private investigator under auspices of a lawyer
to do a criminal investigation for Delita Hooks and he found nothing. Ms Nam told me her
False Cross Complaint was sealed. I question whether any other prior incidents were
“sealed” for her on behalf of the NYPD. If I was a criminal I would be thankful the NYPD
sealed allegations against me but these are false and a false cross complaint is a serious
crime as is assault third degree and now allege in the 2nd degree based on in the video you
can see the key which damaged my forearm, she hits me in the video with her hand and
phone and she throws a shoe at me so it should be for the Manhattan DA to decide
otherwise but the NYPD won’t allow me to upgrade when they conceded Friday, Sept. 27,
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2013 the case is now open which challenges Lt Burgos’s 24 hour investigation as per Ms
Nam’s “motion to dismiss” shows us.
In my allegation of fabricating crime I allege Det John Vergona knowingly and
purposefully violated my rights to due process as well.

Ms. Nam in her motion to dismiss states Det John Vergona made 1 call to Delita Hooks. I
am alleging Det Vergona helped Delita Hooks by fabricating evidence her false cross
complaint so he could false arrest me or better yet coerce me to drop charges rather than
go to the DA and report she filed a false cross complaint as well as threatened a medical
patient (Ms. Troy) with bodily harm and than repeatedly assaulted her as caught on video
until the camera shuts off from a running punch to the eye causing serious damage to the
retina and continued on her savage attack until co-workers got her to let go of Ms. Troy
escorting Ms. Hooks back in to the office ignoring Ms. Troy’s serious injuries very much
like Det John Vergona.

Ms. Troy also asked a retired NYPD officer turned investigator if he could get me any
possible criminal history from which ever Island Ms. Hooks lived or visited which I have
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now learned is Jamaica. He said not possible. This retired NYPD officer turned
investigator agreed with all I have spoken to I was clearly the victim here so I am summing
up this section on “Fabrication of Evidence” by quoting IAB Lt Fikru who said the video
speaks for itself.
I am stating the video proves I was assaulted. The video proves I was coerced to drop
charges and why after all the emails, calls and even a Fed Ex to commissioner Ray Kelly
would I suddenly drop charges Saturday Oct. 20, 19 days later and Ron Kuby felt
compelled to write an email stating I drop charges against my attacker if she drops charges
against me unless I was coerced and how was I coerced? With the threat of false arrest
using clearly fabricated evidence Delita Hooks false cross complaint.

Det Vergona succeeded coercing me using fabricated evidence Saturday Oct 20 only
because of serious health issues including the worsening of my eye. I finally dropped the
charges Oct 20 Saturday via Ron Kuby (as you can hear in the audio once in my opinion I
believe IAB Sgt O’Donnell to be corrupt just like Vergona I don’t want to talk to him) so
Ron Kuby “reached out Saturday no Monday as Ms. Nam states in the motion to dismiss
because I did not feel safe and feared for even worse damage to my eye with a Saturday
arrest that would leave me in jail in to the evening and possible the weekend as I was
continuing to see flashing lights, floaters and what seemed like a film of vaseline. Once I
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agreed to the false arrest Oct. 16 for Oct 20th I lost weight rapidly going from 150 to 145
and did not get my period which I was suppose to get on the Oct. 20. My neck was in a
brace and I was given three types of pain killers and a prescription for an epidural. If I
begged to go the hospital I would have been chained to a bed and for what? Being a victim
of a savage attack at a medical office and than I agreed twice to be false arrested by Det
John Vergona whom I allege fabricated evidence because the moment Det John Vergona
decided to not take Delita Hooks false cross complaint to the DA he became party to and
guilty of fabrication. I feared for my shockingly declining health and well being. I learned
First Aid and CPR and I can’t do CPR on someone if I don’t believe the area is safe for me
-- and I felt unsafe to turn myself in to a man named Det John Vergona who yelled, you are
going to drop the charges or I will arrest you! He had told me I don’t care if you have two
black eyes. Like Delita Hooks he was verbally assaultive with the goal to prevent me from
being to the attention Tuesday Oct. 16 when he first insisted I be arrested immediately for
not dropping charges and than changing his mind delaying me to wait so I can’t bring the
fabricated evidence Delita Hooks false cross complaint to a Judges attention Tuesday Oct.
16 but would have to wait until the weekend if and when he got me to a judge as his
precinct was known to hold OWS victims false arrested for 2 days without seeing a judge
and in the photo of me being assaulted I was wearing a sign I believe had the NYPD group
using fabricated evidence the false cross complaint to retaliate against me for being a
whistle blower and activist wanted to send a message I deserved what I go and were willing
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to use false evidence a false cross complaint to violently threaten me with a false arrest
which I clearly alerted to my abuser Det John Vergona yes I agree to be false arrested as I
have never assaulted anyone in my life. I continue to allege Det John Vergona knowingly
fabricated evidence knowingly using a false cross complaint as he stated the video was some
thing and his goal to coerce me to drop charges and or to punish me and solely me not Ms.
Hooks with a weekend arrest. Ms. Nam withholds any evidence of Ms. Hooks being alerted
to turn herself in perhaps because she was never told to turn herself in immediately as Det
John Vergona alerted me to do so Oct. 16 and again 10 minutes later Oct 16 Delita Hooks
was never alerted to turn herself in Oct 20th because I was made to suffer even more she
was not preparing for arrest because I was being targeted solely with the goal to drop
charges or to be made to suffer a weekend arrest unlike Ms. Hooks who was given special
treatment including a meeting at work where the Detectives saw she sits right up front
behind a long closed off reception desk proving she came quite a long way to come after me
including to follow me down the hall menacing me as I asked for help from Dr Vine’s
medical assistant who both sets of NYPD detectives, supervisors and all Internal Affairs
involved refused to interview who was so fearful for my safety she broke in to get Dr Vine
to come to me! By not interviewing Dr Vine’s medical assistant and she saw Delita Hooks
following me as Delita Hooks provoked me to get help from Dr Vine, I am alleging the
NYPD involved did their best to fabricate this savage attack and abuse of power by medical
staff and NYPD and IAB in my opinion with the collective goal to fabricate evidence with
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the goal to coerce me using Det John Vergona verbally assault me like Ms Hooks to coerce
me to drop charges who put me threw the system with a false arrest to inflict even more
suffering as a form of retaliation for not dropping charges.
Delita Hooks provoked me first to get help from Dr Vine and when I couldn’t get help
Delita Hooks provoked me to start filming to document her repeatedly violating my patient
rights. Det Vergona said it was “even steven” when in fact it was not. He with Delita
Hooks fabricated evidence with the goal to make this violent crime go away. Det Vergona
knowingly also coerced me to drop charges a serious crime knowingly using a false cross
complaint which he never read me the contents or explained because the false cross
complaint said I attacked her and his goal was to fabricate mutual assault although the
term he used “even steven”. There was nothing “even steven” about Delita Hooks savage
attack and Vergona joins Hooks in fabrication and falsifying evidence with the goal to
coerce me to drop charges and they did not act alone but more NYPD and now since IAB
has not contacted The First Precinct to arrest her and Vergona it is clear IAB is involved as
well.
It should be noted in the Ms Nam’s motion to dismiss and evidence and notes from the
NYPD involved we never see or hear any mention of Det Andy Dwyer who IAB Sgt Mary
O’Donnell stated was Delita Hooks detective. Det John Vergona did not work alone
fabricating evidence using falsified evidence -- a false cross complaint with Ms. Hooks
stating I attacked her and the NYPD involved with Det Vergona as the lead abuser stated it
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was “even steven” slang for mutual assault -- a term Sgt Decker explained to me in Dec.
2012 when he told me Lt. Agnes would interview everybody and he never did.

Proof of Coercion
1)

The Video

2)

Delita Hooks false cross complaint which Ms. Nam informed me the NYPD sealed. It is
highly unusual to seal anything under one year but the detectives did because I am alleging
they wanted to seal Delita Hooks violent assault of me that they felt I deserved (see retaliation
section) and their own crime of fabricated a “mutual assault” despite Delita Hooks stating
falsely I attacked her. Please see her false criminal report in the evidence section.

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3)

Ron Kuby’s letter a red flag I requested despite him leaving out “alleged” as we agreed to
describe Delita Hooks false allegations against me but Ron Kuby did an excellent job using
the word “ATTACKER” twice in one sentence of a two sentence email.

4) Ms Nam misrepresents when I dropped charges which was Saturday Oct 20, 2012 because my
health from the injuries from the savage assault and coping with the NYPD abuses and
violation of my rights, threats, intimidation and suffering further declined my health; I had 2
emergency visits to 2 eyes Friday before the date to be false arrested. Dr Young found the
hole in my eye, made me drop everything to get laser surgery. Dr Khadem saw the contusion
in my eye, the floaters if both eyes from Delita Hooks jerking my head back but didn’t see the
hole so I would have gone to jail to be false arrested with a hole not repaired and was fearful
Delita Hooks would be there if the NYPD contacted herself to turn herself in. Ms Nam to
protect her clients never tells us if or when Delita Hooks was notified to turn herself in but it
seems from the beginning the NYPD acted with bias and malice from the first day and on
going.
I was fearful for my safety from even more abuse from Det John Vergona and I had hole in my
retina, was seeing flashing lights, floaters, my neck was in a neck brace and Det Vergona knew I
had a collapsed bladder. I was prepared to come in Saturday wearing a long dress because I read
OWS women say there was no privacy to use the toilet and male NYPD walk by. I also worried
that Delita Hooks would be there but it appears she was never contacted to turn herself in only
me.

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Note Internal Affairs is obligated to investigate police corruption and they violated my rights as
well. They sent my coercion allegations to Lt. Agnes who refused to call me back and interview
me and wrote my allegations unfounded. IAB has a list of allegations including against IAB and
did not investigate them but I allege violating my rights in part as an act of retaliation because I
am a whistle blower.
5)

Ms Nam’s Exhibit C page 9-11 Lt Angelo Burgos Reviewing supervisor describes me as
uncooperative complaint

6)

Ms Nam’s Exhibit C page 10 of 11 States I am fearful of my safety -- that was regarding
Delita Hooks and when Det John Vergona said to me he did not care if I had two black eyes
and repeatedly refused to meet me and than humilated me Oct 16 treating me as a criminal
and telling me I should not contact him or Delita Hooks as if they were both part of this
horrifying crime against me and in a sense weren’t they? Ron Kuby can verify from their
conversation Saturday -- Oct 20th -- that was their only verbal contact -- not Monday when
Ms Nam states Ron reached out to Det Vergona. Ron only issued the email because I alerted
him I went to IAB and CCRB. Note I remain fearful of both Delita Hooks, Det Vergona but
no where in the summation of Ms. Hooks complaint do you read her expressing fear and in the
video she states she is going to slap the crap out of my ass.

7)

Based on all the above evidence WHY WOULD I DROP THE CHARGES????
I was coerced and only because I feared even more verbal violence, further humiliations

including possible physical ones and loss of my vision if Delita Hooks was there and going to
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attack me or someone else accidentally hit me. I need to rest and even now I do but because Det
John Vergona humiliated me, violated my rights and emotionally violated me like Delita Hooks
but she did also repeatedly on a physical level I can’t even rest and heal.

Coercion is a Crime Not A Policing Tool
Please see the Fabrication of evidence section.
The NYPD violated my 5th Amendment and 14th Amendment rights pertaining to
Coercion.
The NYPD are not allowed to prevent People from reporting crimes and the NYPD
did this to me repeatedly. Coercing me to drop charges violated my 5th
Amendment right as outlined in my lawsuit as well as my 14th amendment
rights - a decision made under duress is not binding.
Where did Internal Affairs send my allegations to? To the Integrity Unit which I
am told is where cases are sent to die. Lt Agnes’s name was given to me by Sgt
Decker along with his telephone number. I was told just like Det Vergona told me
that everyone would be interviewed and of course it never happened. Lt. Anges
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refused to return my calls. He wrote my allegations unfounded and Lt. Agnes was
allowed to retire instead of face arrest. I also allege in the “Fabrication Section”
that he did not act alone. The NYPD has many checks and balances as does IAB.

I allege Det Vergona verbal violence, threats and a 4 day delay to false arrest me fall
under United Nations Convention against Torture with the goal to punish, intimidate and
coerce me to drop charges; please see Page 45 of my lawsuit.

AMENDMENT I
Congress shall make no law respecting an establishment of religion, or
prohibiting the free exercise thereof; or abridging the freedom of speech, or of
the press; or the right of the people peaceably to assemble, and to petition the
government for a redress of grievances.

The NYPD violated my first amendment rights in many ways and one
was by “abridging the freed of speech” when they weren’t actually
silencing me violating my 1st and 14th amendment rights to speak
up and report crime, be a whistle blower and not be retaliated
against by IAB and NYPD, as well as the NYPD coercing me to drop
charges; in so many words Det John Vergona said I should have kept
going when in fact I had the right to speak up because Ms. Hooks
violated my patient rights and since she exhibited no shame I had
the right to document her violating on my patient rights. From
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Internal Affairs to Det Vergona telling me to stop my babbling and
refusing to actually interview me and really investigate the fact Det
John Vergona coerced me they were all collectively sending me a
message to shut up.

New Evidence of Coerced Confessions, NYCLU Calls on Police to Videotape
Interrogations | American Civil Liberties Union https://www.aclu.org/racialjustice_prisoners-rights_drug-law-reform_immigrants-rights/following-new-evidencecoerced-con September 17, 2002

Because the NYPD are accused of Coercion re: the gang of men that alleged gang
raped a Central Park runner activists are now asking that all interviews be video
taped. I was not even afforded a meeting with the Det John Vergona who on Oct.
4 based on a series of conversations of which I have phone records that for
reason are either omitted by him and I have emails I sent him before and after
phone calls and than I call again after leaving my father yet again asking to meet
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with Det Vergona to show him my eye since he has turned abusive stating he did
not care if I had two black eyes and was treating me like a criminal. There was no
arrest of Delita Hooks which was a shocker and I asked Commish Kelly about it in
a Fed Ex on an idea I had called “Project Peace to the Streets Project Hope” and
made calls to the precinct and emailed Mr. Vergona.

I wish I had video tape of a

meeting but I can’t even get evidence from my file, Delita Hooks file, my file that
IAB has which would prove why IAB is not doing their job which on a Federal
level they are obligated to do -- their file on me will prove why I am alleging IAB
fixed this for the NYPD that broke the law “coercion” and “fabrication of
evidence”, as well as all the files of the NYPD involved and I need phone records
from Dr Fagelman’s cel phone and office and emails ditto for Ms. Hooks if I am to
prove they or Dr Fagelman contacted the NYPD or retired NYPD or a wealthy
client like a “Bill Rudin” who has a retired NYPD commander like I caught trying
to fix a ticket in front of me as I protested Rudin Luxury condos. My point there
motive to coerce me to drop charges from not wanting to be bothered to
retaliation and note the IAB’s role in coercion since they allowed Det Vergona to
retire and his supervisor Mr. Agnes who has at least 20 years and did not think
Ron Kuby a famous criminal lawyer letter was a red flag short hand for Suzannah
Troy has been coerced which is why she is dropping charges or the video or the
false cross complaint or the photos including the one Ms. Nam omitted of me me
with serious cleavage looking joyful before I am attacked at the Dr Fagelman’s.
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All the NYPD and IAB involved should have take action and IAB is obligated and I
alleging that IAB involved are guilty of not doing their job and going after all the
NYPD involved in coercion, fabrication and I allege also fixing this crime for Dr
Fagelman as well as retaliating against me but IAB also involved in retaliating
against me; see “Retaliation Section”.

If Mr Vergona did not include these conversations it is a a serious breach on his
part or is it Ms Nam did not include them to protect her client? All the calls and
his abusive threatening conversations are omitted because they incriminate Mr.
Vergona and all involved.

Ms Nam's clients committed crimes of coercion and fabrication so it makes sense she
omitted so much 

My attacker gets meeting with NYPD and calls from both sets of detectives. Delita
Hooks detectives never contacted me. Det Vergona states in Oct 16, 2012 call they did
not have to.  No where in DD5s are there records of his abuse threats and goal to
coerce me via threatening phone calls and Det Vergona refused to meet me unless it
was to false arrest me on the Sabbath 19 days after Delita Hooks attacked me.  4 days
after I agreed to immediate false arrest and to date Vergona (Italian for shame
Vergogna) has never met me.  He retired. Ray Kelly insists on defending him and
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serving Vergona at 1 Police Plaza protecting a dirty cop and Vergona was not alone.
 There are too many checks and balances involved.  

I was treated with bias and prejudice my 1st, 14th and 5th pertaining to coercion
violated. 14th also violated pertaining to coercion. 

I found retired NYPD consulting for SAIC. SAIC that over billed us over half a billion
dollars and Rudy Giuliani's deputy mayors became lobbyists for SAIC.  I did my best
and succeeded in getting SAIC banned.  SAIC is banned from all NY State and city
contracts.  

Ditto 911 tech contractors starting with Hewlett Packard one of the top 20 military
contractors.  

Posting in Coercion section and retaliation section. The goal was to punish me and to
make me fearful and to shut me up and to fix a violent crime for Dr Fagelman as much
as Delita Hooks who he did not fire.
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NYPD watching the video takes the NYPD out of the context of not obligated to investigate
crime to “witness of a crime”
The video evidence does not excuse Internal Affairs and Mr. Kelly a civilan from not taking
action when witness a crime caught on video that proves NYPD coerced me the victim seen
retreating from a violent crime in a medical office from taking action

The NYPD are not obligated to investigate crime but what I am suggesting is that once the
NYPD officers from the 2 sets of detectives to their supervisors to IAB and commissioner Ray
Kelly when I handed him a Justice Card stating my attacker Delita Hooks filed a false cross
complaint are obligated to take action because watching the video made them no different than
“Housing Police” and reading the false cross complaint or being notified that victim is alleging
the complaint although it was obvious from the video her complaint was false with photos and
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medical records all NYPD, IAB that viewed the video were now witnesses of a crime and
obligated to take action and did not. Note: Internal Affairs and commissioner Ray Kelly upon
watching the video and reading Delita Hooks false cross complaint cannot enjoy the luxury of
brazen corrupt cops choosing to not investigate crime as well as brazenly fixing. IAB is
obligated to take action watching the video because it proves that NYPD officers did in fact
coerce me. Mr Kelly expanded IAB’s budget and yet he insists on defending Det John Vergona
who blatantly coerced me to drop charges and did not take Delita Hooks false cross complaint to
the DA. Mr. Kelly is technically a civilian and does not enjoy the luxuries of the same
protections as the NYPD as their boss and ultimate supervisor is what I am putting forth as a pro
se litigant.
Ditto for the false cross complaint. Upon reading the false cross complaint -- a crime all NYPD
and IAB that saw the video and read the false cross complaint where obligate to take action and
did not.

Mr Kelly has pushed through 30 -40 million dollars on Domain Awareness, Taru on

Steriods....Taru is the video unit so it proves how highly Mr. Kelly values video yet the Michael
Premo (referenced page 51 lawsuit) trial shows us how corrupt the NYPD are when it comes to
withholding video and even the Manhattan DA’s role false prosecuting Michael Premo who
never harmed an NYPD officer as falsely accused and prosecuted. Democracy Now was
standing next to NYPD Taru and provided video that NYPD Taru did not want to share with the
court proving Premo’s innocence. (Page 49 lawsuit) As instructed by the Attorney General’s
Investigative Unit I contacted Cy Vance and every office in the Manhattan DA (page 49 lawsuit)
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to direct report the crime and share the video only to be told I had to have IAB contact the DA,
that I the victim could not but the video is enough to prove that NYPD fabricated evidence to
coerce me to drop charges and what did IAB, commissioner Ray Kelly and Charles Campisi do
about the NYPD role in coercion a serious crime? Despite this powerful video evidence which
evokes the question why did I drop charges Oct. 20 a Saturday 19 days after the attack and why
on Oct 22 did Ron Kuby write I drop the charges against the attacker if the attacker drops the
charges? It was short hand a red flag for I was coerced which the video proves.

If a housing police officer sees a man kicking a dog on video on the housing monitor he or she is
obligated to take action and make an arrest. It is clear I rate lower than a dog as I gave the video
to the NYPD and repeatedly directed all NYPD and IAB I spoke with to watch the video
including Chief Esposito and his detective assistant I spoke to.
When I agreed to be false arrested I showed the video to an NYPD officer in the subway and he
said the woman in the video threatened you with bodily harm, the key becomes a weapon, she
assaults you and than she filed a false cross complaint. Get another detective. As you can see
even Det Vergona’s supervisors I allege were bias and bent on closing this case and protecting
Det John Vergona and all involved in coercing me to drop charges.

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If Delita Hooks did this to a dog at a Vet’s office, the ASPCA would have made sure she was
arrested. Instead I was treated lower than a dog. How many videos did have we seen of the
NYPD making arrests purely on video in housing projects of abusers kicking and beating a dog
in an elevator?
I don’t know if this is a new boundary I am pushing as a victim of a violent crime I allege was
fixed by the NYPD and IAB as I allege the NYPD fix crimes like a Las Vegas Casino but the
moment the NYPD and IAB saw the crime they were no different than Housing NYPD officers
obligated to take action and not protected on the Federal rulings that protect police from being
obligated to investigate crime. The distinction of watching the video takes them out of the
“investigation not obligated to take action” to witness a crime and taking action.
Ditto for the false cross complaint/report Delita Hooks filed. As soon as the NYPD and IAB saw
the video along with the false cross complaint they were obligated to take action as now they
“witnessed” two crimes and did not take action.
Internal Affairs I am alleging was legally required to take action and contact the First Precinct to
arrest Delita Hooks and it is 1 year and 45 days no arrest.

So why did IAB and NYPD not make the arrest based on the video?

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I allege bias, prejudices of the worst kinds, I allege the NYPD and IAB did a “round robin” a
slang NYPD term to check me out and didn’t like what they say ex. my continued posts asking
when are the NYPD rape cops going to jail and my stand-up blog comedy posts about Detective
Louis Pepe and the NYPD issuing Bullet Proof Condoms. Det Pepe was having an off duty
adulterous affair and got shot with his own gun and wearing no pants.
Perhaps he lives near Det John Vergona in Staten Island.

I believe IAB retaliated against me for a long list of reasons that some are related to my
allegations of “economic racism” and me blowing the whistle on special treatment of the wealthy
of Soho vs the Veteran and Artist vendors and the use of The Mercer Hotel’s loading and
unloading as well as referenced in my lawsuit billionaire Rudin’s retired NYPD commander
caught trying to fix a ticket by me as I protesting Rudin Luxury Condos no Trauma Level 1
Hospital with a Rape Crisis Center and AIDS Care.
(put in page numbers and create a retaliation list_

Evidence for my case in Ms. Nam’s motion to dismiss

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1) First where are the notes on the video which proves everyone involved is guilty from Deita
Hooks and the office workers that back her up to all the NYPD and IAB that are involved in
collusion with this crime? Oct 16 all notes omitted by Ms Nam or Det Vergona never
included that he said to me That video is something. I include in the evidence section in the
back the emails to Vergona including that I sent him the video but for all the opening and
closing of case with many of the officers with close to 20 years or more on the job except for
Commissioner Kelly who has even more all agree I was not coerced and no evidence was
fabricated even though the NYPD according to Ms Nam sealed Delita Hooks (false) report
which very strange in under a year and the video proves she savagely attacked when she could
closed the door because I standing outside and she is still inside holding the door for balance
as she begins her attack. So where are all the notes on the video from the detectives and
supervisors and IAB? So there should be a DD5 concerning the video and it’s content and he
said to me on the phone when he planned to force me to drop the charges he said that is some
video but it was even steven. Where is DD5 and why isn’t in his file and how did the video
proof escape all the defendants who rally to defend Det Vergona who committed crime
threatening and coercing me. Where the notes to conservations Thursday afternoon, Oct 4,
2012 as you can see evidence section page 11 and 12 in the back this motion as well as Oct
16 when he yells at me and threaten with arrest if I don’t drop charges. Where are the DD5s
to conversations?

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2)

Page 2 of Ms Nam’s “Motion to Miss” is a gross misrepresentation of fact re: Ron Kuby
“reaching out” to Det John Vergona Oct. 22, 2012 when Saturday was actually “follow-up”
from Saturday Oct 20, 2012 the “coercion due date to turn myself in and there is no mention
of that in Det John Vergona’s notes for some reason that Ms. Nam chose to share. Ms.Nam
has limited what she chose to share including Det John Vergona’s verbally violent phone call
Oct 16 and his demand I immediately come to the 01 Precinct for immediate arrest , than a
2nd call and agreeing to be false arrested Oct 20th -- the coercion date and there are no
references to Det Andy Dwyer’s notes or existence. Ron Kuby “reached out” if that is what
you want to call it, I prefer rescued me from even more abuse and torture as I define in my
lawsuit see page..... (United Nations referenced ) Oct. 20th and I was on stand by to turn
myself despite serious medical conditions if Det John Vergona so decided but it seems Det
John Vergona was pleased and achieved his goal to coerce me to drop charges.

I agreed to be

arrested first immediately Tuesday, Oct. 16th immediately as per Det John Vergona’s angry
verbally violent demand. She than called back aprox 10 minutes later because she had a
medical appointment for a chipped front too so she asked Det. John Vergona if she could come
at 3PM to be false arrested. He said no she should come see him Saturday Oct. 20th to be
false arrested. Ron Kuby called Det John Vergona Saturday at aprox 4pm or slightly there
after because Mr Kuby had convinced me not that I needed any but Ron is an expert that Det
John Vergona wanted to punish me clearly the victim of an attack and put her through the
system and her health was continuing to seriously decline. He spoke to Det John Vergona
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who was polite and agreed to drop charges. No mention in Det Vergona’s notes Ms Nam
shares with us about why Det Vergona is contacted on Saturday. Ms. Nam omits Det
Vergona’s notes on me agreeing to be false arrested twice in our 2 phone conversations Oct.
16, 212. After being coerced to drop charges Saturday later that weekend I contacted Mr.
Kuby and alerted him I had contacted Internal Affairs Bureau and CCRB so Mr. Kuby decided
to draft a letter. The email consent is in the evidence section. Ms. Troy agrees to drop the
charges if the receptionist drops the ALLEGED charges. Ms Troy praised Ron Kuby from her
blog and YouTube channel stating his brilliant red flag to IAB. I am thankful to finally see the
letter thanks to Ms. Nam presenting it and it is a huge red flag -- not Mr. Kuby reaching out as
Ms Nam’s client writes but Mr Kuby stating in so many words 2 days after I finally gave in
after 4 days of emotional distress so grave I dropped 5 pounds, that I was coerced hence he
wrote I drop the charges against my ATTACKER if my attacker drops the charges.
Ms. Nam by misrepresenting the actual date of Saturday erases the allegations that Ms. Troy was
coerced to drop charges finally Saturday -- the agreed upon 4 day wait for weekend arrest with
Det Vergona refusing to explain why I had to wait for days until Saturday and why are you antisemitic. (page 33 lawsuit) Arrest the Jew on the Sabbath. Ms. Nam omits this from her clients
notes.
I agreed to drop the charges as in coerced because I felt it was too dangerous to go in with
serious eye damage that Dr. Young correctly diagnosed as a whole in the retina aka detached
retina -- see medical report evidence section and that was the day before the agreed false arrest.
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The Saturday Ron Kuby call is practically erased when it is key (why would I drop charges 19
days later on a Saturday and Lt. Agnes and IAB saw all my emails?) and instead Ms. Nam
presents Monday Mr Kuby “reached out”. Not true and misleading. He was following up
because I contacted IAB and CCRB .
I had also had my neck in a brace from bulging herniated disks cervical spine from Ms. Hooks
unrelenting savage attacks on my body. (Again where is the DD5 with photo of me in neck
brace giving Det Vergona Hell see “G-d Sees All” email evidence section page 25c)Det John
Vergona was also aware I had a collapsed bladder which is why I didn’t call 911 or go back and
call 911 as NYPD public member Marks who took her complaint Oct. 1 told her. Public
Member Marks said if you don’t go back it will go no where. Ms Troy alleges Det John Vergona
repeatedly humiliated her verbally assaulting her Oct. 16 falsely accusing her of assault. Yelling
at her you are going to drop the charges or I will arrest you! He only said as an after thought I
will arrest her too. I will arrest both of you. It was even steven. You assaulted her she assaulted
you. You hurt her she hurt you. Ron Kuby told Ms. Troy if she did not go through the process of
false arrest for him it was over with this letter. He apparently held no faith in CCRB and IAB.
Mr. Siegel took over from that point but could not represent Ms Troy in this matter because he
was too busy. Where are Ms. Nam’s clients including Det Dwyer’s notes on contacting Delita
Hooks to turn herself in because I didn’t see them and there should have been a series of calls by
Det Vergona not 1 unless she was sitting there Saturday Oct 20 at the first precinct and since I
allege they worked together on behalf of Dr Fagelman’s rabbi or hook a term for someone of
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influence in the Police department and I also allege it was agreed to send me a message as a
whistle blower to shut up and be silent.
Where are the notes from Det Vergona Oct. 15
evidence section page page 43 B -- photo of long closed off reception desk that Delita Hooks
came out from behind to stalk and menace me. She sits up front across from the water cooler.
She followed me back after she provoked me to seek help and than got to the exit by the water
cooler before I could exit provoking me to film but Det Vergona never went to the office so he
had no idea where she sat
See the infamous reception desk that is long and closed off showing IAB how far Delita
Hooks had to come. Det Vergona asked me why I walked by Delita Hooks not aware she
sits at the exit. (fax to IAB Kroll IAB O’Donnell’s partner page 43B evidence sect. the desk)

3) Ms Nam thankfully includes Ron Kuby’s letter. Finally Ms. Troy got to see the actual copy.
Upon reading the letter it is not what she agreed to exactly but it is still brilliant. We did not
know Delita Hook’s name but she is described as Ms. Troy’s attacker. Why would Ms Troy
drop the charges against her attacker on Oct 20 -- 19 days after she was savagely attacked
when you can read emails of her asking when is Delita Hooks gong to be arrested and warning
Det Vergona the receptionist is violent --- see emails in evidence section, Saturday the day
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she agreed to be falsely arrested for the 2nd time and than upon alerting Mr Kuby of her
actions contacting CCRB and IAB why would he write this. He did it to alert investigators in
so many words I was coerced but as you can hear in the audio of IAB Sgt Mary O’Donnell she
refuses to listen and says case closed. The NYPD do not have to investigate crime if they
don’t feel like it but IAB has and here is just one example in many of what Ms Troy alleges is
a Blue Wall of Corruption with an unwillingness to investigate NYPD corruption fixing a
crime and coercion as you can hear IAB Sgt Mary O’Donnell in her own words “case closed’.
Ms. Troy reported her concerns to Lt Fikru who said he would investigate Ms O’Donnell. He
admitted he saw the video and it spoke for itself but he only investigates IAB corruption. He
no longer would return my calls.
4) Page 3 of Motion to dismiss Ms Nam does not reference the video Ms Troy sent Det Vergona.
On Oct 4 with the photos I sent the photos, video and medical reports. Det John Vergona
referenced the video in their conversation when he alerted her he was going to arrest her if she
did not drop the charges. I told Det John Vergona a judge would take one look at the video
and throw out his false arrest. She would sue him. Det John Vergona admitted that video is
something. His words. Ron Kuby told Ms Troy that video is powerful. He or Ms Nam
omits the photo of me looking beautiful with lots of cleavage wearing a large sign like a
necklace protesting Rudin Condos no Trauma Level 1 Hospital which I am suggesting
evoked a series of bias responses by the NYPD.

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5)

Page 3 Incorrect I asked repeatedly why wasn’t Delita Hooks arrested before she was
coerced to drop charges. See emails in the evidence section. See email “G-d Sees All” before
I cave in to coercion giving Det John Vergona hell for his evil actions towards me. I also fed
exed commissioner Ray Kelly and asked why wasn’t she arrested. Ms Nam is incorrect
stating Ms. Troy asked it after she was coerced. See emails in evidence section. “ I thought it
was very odd that Det Vergona has not arrested Delita Hooks and in a Fed Ex to commissioner
Kelly I referenced my concern as well as had a conversation with Det Delpozo.” From
“retaliation section” page 64 number 8 . See emails I include but key to refuting Ms. Nam’s
claims’ I was objected to being coerced after Oct. 20th not true. Even more proof, Oct. 16th
also I walked in to the precinct and handed in Lt Petroino’s memorial pin honoring his death
in the line of duty killed abroad in 1909 in the line of duty with badge number 285 demanding
DI Ed Winski be there when I was to be false arrested. It should be noted I told every NYPD
officer there what was going on and no one would arrest me or even tell me to leave but asked
me to hold on to my Lt Petrosino pin and my NYPD Memorial hats etc. I appreciated their
kindness and my neck was in a brace but they were the exception and they didn’t go to IAB
either. I understand they have more to lose than to gain speaking up on my behalf.

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6) Page 4 Motion to Dismiss top of page -- Ms Troy paid attorneys not to represent her but to her
advise her before she filed suit. Ms. Troy’s would like to be reimbursed for all costs.
7)

Misogynist Confrontative C/nt Calling “Lawyer” threatens to turn the tables on me if I sue
Delita Hooks.

Ms. Nam included on page...... that the NYPD officers noted she did not have

a good grasp of the English language yet the letter IAB Sgt Mary O’Donnell read to me was
highly articulate and the last sentence sounded like the same author, the “misogynist lawyer”
who called me a confrontative c/nt and promised to turn the tables on me. I am alleging Delita
Hooks letter is ghost written by the same man who I accuse of witness tampering in an email
to Det John Vergona who never responds to the me when the “lawyer” called me a
confrontative c/nt on Oct. 6, 2012. In the last sentence of the letter that Delita Hooks signed
as if she wrote it she states if I file assault charges again she will file another cross complaint.
There is the misogynist lawyer’s threat to turn the tables on me. That would make 2 false
cross complaints because the video clearly shows I never touch her let alone assault her and
she had begun the physical assault making good her threat to slap the crap out of me.
8)

Lt. Angelo Burgos opened my case for 24 hours and closed it. Any honest police officer
would have instantly and quickly seen I was a victim of a savage attack and a false cross
complaint by my attacker. I hired a famous criminal attorney who rights I will drop the
charges against my attacker if my attacker drops the charges...Ms. Nam was kind enough to
include Ron Kuby’s letter so I saw it for the first time. We did not know my attacker’s name.
What I agreed to via email to Ron is I will drop the charges if the receptionist drops the
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“alleged” charges so there would be a red flag for IAB. I was pleased that Ron Kuby called
her my attacker which is a red flag but this alluded Lt. Angelo Burgos who along with Det
Vergona had aprox. 20 years of NYPD experience or even more.
9)

Did Det John Vergona also decided I was taller and weighed more than Delita Hooks so it
wasn’t really an assault even though the video shows her repeatedly assaulting me before the
camera shuts off from her running punch as I back away? Ms. Nam’s motion to dismiss
included Delita Hooks weight and she is aprox 135 pounds which is a considerable amount of
weight to be pulling my hair serious enough to damage my neck and create bulging and
herniated disks as she repeatedly wrenched and pulled my hair with the goal to drag me down
the hall and throw me in the elevator. I successfully got her to the ground using her
momentum and let go while she continued to damage my neck using her full weight to pull me
towards her as she repeatedly tried to kick me.

10) Det Andy Dwyer -- Why is there no mention of him and his partner. There records and the
fact that he and his partner never contacted me. I allege he was a partner in coercion as he
did not go to Internal Affairs and report Det Vergona. It should be noted Det Andy Dwyer has
at least 16 years experience based on his linked in page. Det Vergona and Lt. Burgos has a
minimum of 20 years.
11) Why no record of Det John Vergona refusing repeatedly to meet me. Please see emails...put
page number
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12) Ms. Nam shows us my complaint which states I fear for my safety. Quite a
contrast from Delita Hooks false criminal report which the video proves is false. The video
proves Ms. Hooks committed yet another serious crime and has avoided arrest for over 1 year
now. I continue to fear for my safety as well as even more retaliation for blowing yet another
whistle. I fear for my safety and Det John Vergona say “even steven”, ditto for the video and
medical report proving how seriously injured I was and am vs Ms. Hooks falsified medical
report and false accusation I bruised her left thigh kicking her once she was on the ground
which never happened.
13) Ms. Nam shows Lt. Angelos Burgos opened my case for 24 hours Feb. 14, 2012 and than
closed it and I am alleging more proof he failed me besides refusing to answer my email
asking for the Sgt. Chen and Det Vergona’s badge numbers. I sent the email to him to
commissioner Ray Kelly, Chief Esposito, Chief Campisi, DI Ed Winski and got zero response
and again I allege a diverse varied series of violations of my 14th Amendment rights treated as
a Jew in the early stages of NGermany. He states I am uncooperative but he never contacted
me. Is uncooperative short hand for accusing his 20 year plus NYPD Det Vergona of coercion
because Lt Angelo Burgos never met with me, called me and refused to answer emails
including asking for badge number of Sgt Chen and Det Vergona.

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13) Motion to Dismiss page 6 Re: All defendants -- Ms Troy is an activist blogger, YouTuber,
artist. She spoke to an FBI Agent re: her concerns about Internal Affairs. He told her he
looked at her blog and he said, you are an investigative journalist, an artist and a character.
Ms. Troy suggests “character” could be similar to her being Mae West meets Mike Wallace.
Ms. Troy alleges they collectively violated her 1st and 14th amendment rights in so many
word telling her to shut up -- trying to silence her and make her fearful which was the result
achieved of Ms. Jane Doe a whistle blower on 911 Tech Corruption who was a victim of
“NYPD Creative Policing” by The First Precinct Det Squad on behalf of a cross complaint
filed after a series of hers by retired NYPD Sgt John Doe who is an advisor on 911 Tech, a
married man with a wife in Florida who offers to drive women home who work at a specific
gov agency that deals with technology. Please see emails in the evidence section that show
Ms. Troy contacted Mr. Kelly’s det in his community affairs division at One Police Plaza as
well as many others as this was unfolding expressing concerns of bias, etc. The NYPD and
IAB do not want to hear from me and they violated my rights as explained in this lawsuit to
shut me up and silence me and discourage me from reporting any further crimes and police
corruption which is a violation of my First Amendment rights.

Det John Vergona’s supervisor Sgt Chen spoke with me - I have phone records Nov. 20 , 2012
9:11 2 min call I am told he is changing in to his uniform Nov. 20. 9:24 10 min conversation -he is rude and mocking but agrees I have a right to report Delita Hook’s false cross
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complaint yet I have audio proof of his involvement with PO Migori turning me.The NYPD are
not allowed to turn someone away from reporting crime and yet they did repeatedly.
You can hear PO Migori in the audio Ms. Troy recorded as well as PO Migori calling Sgt Chen
who refuses to meet Ms Troy and she is wrongly told she cannot report a false cross complaint
because she is not a Det or from the DA. You can hear Ms. Troy call DI Ed Winski, leave him a
letter, call IAB, call CCRB Inspector Mesa. All along the way from before Ms. Troy was
coerced to drop charges, after and on going to present Ms Troy continues to fight for her
constitutional rights which alleges all of the defendants violated.

After Sgt Chen told me to come in and spent 10 minutes on the phone me, he should have come
downstairs and met me with to explain why now I was being turned away.

He should be noted in the 10 minute he said right away You were the one assaulted at the
doctor’s office.
The NYPD met with Delita Hooks but Oct 6 Det Vergona repeatedly refused to meet with
Ms .Troy showing one example of bias. IAB and Lt Agnes refused to return phone calls.

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Ms Nam’s letter on behalf of Det Vergona I am submitting as evidence to show the defendants
are working together as a group defending Det John Vergona who they had me serve at One
Police Plaza very similar to all the women in the video where I am clearly repeatedly assaulted
with Delita Hooks the aggressor as I back away - the camera shocking from the jolt of the attack
but the women as a group lied I was told Det John Vergona said they said it was me.
The letter drafted by Ms Nam states all her clients agree the City of NY should defend Det
Vergona so I am alleging this is even more evidence of a collaboration against me violating my
Constitutional Rights and their oaths of police officers to uphold the constitutional and why?
Because I am a whistle blower and activist. See my section listing why the NYPD, First
Precinct, IAB had motive to retaliate against me.

Page 1 -11 NYPD Complaint follow-up Informational System misleading and wrong
I was coerced to drop charges Saturday. Perhaps they called Delita Hooks and arranged the final
bit of work they did on her behalf and their own covering up coercion but I dropped the charges
against my will as Ron Kuby can verify Saturday. He only followed up with an email Monday
because I alerted him I called IAB and CCRB, not he says I will drop the charges against my
attacker if my attacker drops the charges against me shorthand for coercion.

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Note you can find the truth page 6-11 Ron Kuby called Oct 20 but not the real reason because I
was suppose to turn myself in for false arrest. No mention of that at all.
page 3 of 11 “Complaint follow up” like Delita Hooks false criminal report Det Vergona states
we both struggled to the ground not true. I used her momentum to get her to the ground and
remained standing as she repeatedly damaged my neck wrenching my neck repeatedly trying to
kick me. This is a blatant fabrication. I told him so and Det Vergona stated I had a right to
defend myself. Det Vergona is very careful to leave out key points in our conversation on how I
called the First Precinct over and over and no one answered so I walked over instead of going
back and calling 911 as public member Marks instructed me because I told him I have a
collapsed bladder and I need to use the bathroom a lot and the bathroom key is by Delita Hooks.
Public Member Marks told me if I did not return to Dr Fagelman’s and call 911 this would
go no where.
Contrast the number of times I called the police after I am attacked vs Delita Hooks calls to the
police which are none after the attack and I walked to the First Precinct and Ms Hooks went back
to her seat behind a long closed off reception desk. Dr. Vine informed me Delita Hooks returned
to her desk and acted as if nothing happened and worked until 7pm Dr Vine demanded Delita
Hooks be fired and Dr Fagelman refused. This was not in Det Vergona’s notes. He omits or his
lawyer Ms. Nam omits the series of calls Oct 4, 2012 when he begins his first verbal violence
telling me he does not care if I have two black eyes. I have the phone records and I call Apple
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because he refuses to meet me to see my black eye and refuses to understand that Photo Booth
flips the image. I have the emails from that afternoon all omitted like Ms. Nam omits Det
Dwyer’s notes completely again because I allege the evidence would further incriminate her
clients as if the video, Delita Hooks false criminal report, my medical reports and photos aren’t
enough.

page 6 of 11 proves what I am saying is the truth.... Where it is that Ron Kuby called Saturday
Oct. 20, 2012 and instead of me coming in to be false arrested as I had notified Commander DI
Ed Winski Tuesday night, Ron Kuby calls and says I drop the charges. Why would Ron Kuby
calls Saturday to say I drop the charges?
All of this is omitted from Ms Nam’s evidence she shares and on page 6-11 there is mention of
Saturday, Ron Kuby’s telephone call instead of the false arrest I agreed proving “The ComplaintFollow up is false! B-7 B7 inaccurate -- what is inaccurate? Even the notes at the bottom say
“omitted” What is omitted? Everything is omitted that proves the NYPD coerced me to drop
charges except Ron Kuby’s letter is short hand for my client is being coerced hence the word
“ATTACKER”. This page highlights the supervisors like Lt. Burgos, Sgt, Chen, DI Winski, and
all defendants in my opinion are willfully covering up so extreme that Ms. Nam informs me they

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all agree that Det Vergona must be defended by their lawyer and for me that is even proof of
cabal.

Even Delita Hooks letter to the NYPD which IAB Sgt O’Donnell read me but would not to see
threatens me and the threat is one of retaliation which I allege is the NYPD’s and IAB’s motive
to violate my 1st, 5th and 14th amendment rights and prevent me from having equal rights and
the right to due process and to not be coerced, intimidated and threatened in to dropping charges
as well turned away repeatedly when I tried to report crimes.
Ms Hooks according to the letter Ms. O’Donnell read me states if I file assault charges again
against she will retalatite against yet again by filing another (false) complaint against. That is an
incrediably brazen in your face threat to give the NYPD and for Internal Affairs to ignore just
like her false cross complaint. Ms Nam omitt’s Ms. Hooks letter and I allege to protect her
clients who are guilty including IAB who does not have Federal protection and is obligated to
investigate Police Corruption and the letter by Ms. Hooks escaping notice along with the false
cross complaint that Ms. Hooks and the NYPD made over in to “mutual assault” I alleges proves
it’s a cabal -- they are working together to protect all of their own self interests in violation of my
rights and to send me message to shut and I got what I deserved and that is criminal as well as a
violation of my rights.

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The NYPD lies and abuses is the reason why I contacted Ron Kuby and I feared for my safety
because of Vergona’s verbal violence and willingness to fabricate me being a victim in to mutual
assault and willfully committing coercioin. Where are the notes from Vergona and from Dwyer
re: me agreeing to be false arrested immediately, Tuesday Oct 16th , and than Vergona pushed it
back to Thursday Oct 20th which is why Ron Kuby called Saturday. I was suppose to turn
myself in to be false arrested. No where are notes on my agreeing to be arrested Oct. 16 and than
agreeing to delay to Oct. 20, 2012 and Det John Vergona has no notes explaining why Saturday
of all days Ron Kuby contacted him and that was to protect himself from his criminal act of
coercion omitting his threats about arresting me -- in my opinion, Det John Vergona was using
a false cross complaint to false arrested me and no where in Ms. Nam’s notes on behalf of her
client Det Vergona is the agreement that I said yes, I agree to be false arrested Oct 16. Det
Vergona’s notes do not show he yelled at me You are going to drop the charges! His notes do not
show us I agreed to turn myself in to be arrested as he instructed me immediately! Yes as
an after thought he says I will arrest her too but where are the note from Det Andy Dwyer
and Det Vergona on Detlia Hooks agreement to turn herself in Saturday?

Tuesday conversations DD5s omitted by Ms Nam or Det Vergona?
The first call came a a voice mail asking me to call Det Vergona. My phone was shut off so I do
not have the time of the call. I return his call at 12:50. The phone cuts out and when I call and
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try to tell the woman Detective she acts with bias as if I am not sincere and hangs up on me. I
call back 12:52 Det Vergona is very rude to me. There is another call 12: 57 for 1 minute which
may have been a problem with the phone. There is another call at 12:58 for 9 minutes with Det
Vergona is full out verbally violent. He threatens me with arrest unless I drop the charges. He
than as an after though realizing what he has done says I will arrest you both but again we never
given notes as to when Deilta Hooks was told to turn herself in. Why is this with held from us if
Ms Nam’s clients have nothing to hide. Ditto for Det Dwyer’s notes. Det Dwyer never called
me at all because it was group bias ditto for IAB. I am a non-person to them with no rights just
like Delita Hooks yelled at me who are you you have no rights.
Omitted 1:10 2 minute call 1:18 3 minute call. There are the records of AT&T so why are the
notes from Det Vergona? Where are the DD5s from these calls and where are all the DD5s from
Det Vergona and Det Andy Dwyer aka Delita Hooks detective as per IAB Sgt Mary O’Donnell.
If Vergona omitted Tuesday., Oct 16th, conversation where he forced me to agree to an
immediate rest ordering to come down to turn myself in right away --- where is the DD5?

I am alleging he omitted the threat because he was in breech of ethics and has commited the
crime of attempted coercion threateed with arrest if I did not drop charges. His notes from
Tuesday omit the fact he violated the law -- he is not allowed to pressure a victim of crime in
to dropping charges yet all this alluded his co-workers and supervisors and IAB (look at Lt
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Burgos notes and Burgos never contacts me!) as well as Commish Kelly and Chief Campisi who
I contacted repeatedly as was my right to do so considering the criminal act of coercion
committed by Vergona and there are so many checks and balances I am alleging he Vergona not
do this on his own in a vacuum..

His words to see him Saturday he gets in a 4 and he will arrest me. Me the victim of a savage
crime that he knew had eye damage, cervical damage and not from the assault a collapsed
bladder but no notes submitted by Ms Nam regarding why Ron Kuby called Saturday Oct 16 to
drop charges! It just was something out of the blue? No I had agreed to be false arrested and I
made it clear You are false arresting me in two conversations Oct. 16 no record in Ms. Nam’s
notes on behalf of her client Det Vergona.

Ron Kuby’s letter is the red flag I requested despite it not being exactly what I agreed to missing
the word “alleged” if my attacker drops her alleged complaint but the fact he phrased it I drop
the charges against my ATTACKER if my ATTACKER drops the charges along with the video is
proof enough. This is not the Central Park 5 case. Ron Kuby was worried for me and based on
his knowledge of the NYPD and Det Vergona’s verbal violence and his goal to coerce me or as
Ron said punish me and put me through the system over the weekend Ron worried for my health
but Norman Siegel supported my efforts if I so chose to do so which I did go to IAB and CCRB
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but Ron Kuby felt it was futile. Ron was happy to sue for me but he put my health first
considered how greatly upset I was and anyone reading my motion to not dismiss can feel I
remain greatly traumatized from what Det Vergona and all involved did to me.

In her motion to dismiss, Ms Nam attacks me for telling IAB Sgt Mary O’Donnell not to contact
me. Why would I have any future conversations who does not think it is odd that Ron Kuby who
she makes clear is famous wrote a letter that said I agree to drop the charges against my
ATTACKER if my ATTACKER drops the charges. That along with the video, the medical
reports, Delita Hooks false cross complaint and Ms. O’Donnell in our one and only meeting pre
the recording read me Delita Hooks letter threatening me yet again stating if I file assault charges
again she will retaliate against me yet again filing another (false cross complaint). Ms Nam was
careful not to include Delita Hooks ghost written letter I allege is written by the “misogynist
lawyer” that threatened to turn the tables on me in a series of abusive aggravated harassment
witness tampering YouTube comments the Sunday night after I was assaulted and was trying to
heal. I had to call Norman Siegel Sunday night to help me deal with this. Mary O’Donnell
stating case closed based on all the info she has in my opinion proves she is a corrupt cop and
how ironic that Det John Vergona who in my opinion is far worse than she told Ron Kuby I am
not to contact him! I don’t talk to corrupt cops that coerce me to drop charges but no one
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thought that was mildly interesting that he instructed me not to contact him and Delita Hooks.
He degraded and humiliated me and pistol whipped me. He treated me like a criminal and did a
background check on me and fyi I didn’t even get a detention in High School. I just was trying
to get medical care and I am alleging NYPD and IAB fixed this to protect their own and to send
me a message to shut up.

If my emails “incessant” why not include them all? Because they prove every point that Ms.
Nam made in asking the Honorable Judge to dismiss my case. I also conceded the NYPD are not
obligated to investigate crime but made it clear that they violated my First Amendment Rights in
so many ways and the ultimate message to shut up with the goal to silence a whistle blower as
well as violated my 14th amendment and I prove with the video, Delita Hooks false cross
complaint, medical records, photos before and after, Ron Kuby’s brilliant letter he wrote after I
alerted him I contacted him telling him I filed complaints against Det Vergona after he finally
succeeded in coercing me to drop charges Oct 20. Ron’s letter I drop the charges against my
ATTACKER if my ATTACKER drops the charges against me underscores the fact I was coerced
to drop charges yet everyone involved including supervisors and the Integrity Bureau, Lt Agnes
who would not call me, IAB Sgt Mary O’Donnell who read my the letter and I allege replaced
the “ATTACKER” with Delita Hooks -- she was careful to not show me the letters but to read
them to me and she promised to mail me back my notes and did not. I had spelled Det Andy
Dywer “Drier” and she was not going to correct me just like I believe she “edited” Ron’s letter
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to me. I alleged that Ms Nam’s defendants clients want Det Vergona protected because they are
confident they can get this case dismissed and protect what I allege is the NYPD and IAB’s
criminal role. The NYPD “coercion” and John Vergona didn’t do it alone. There are too many
checks and balances. IAB is obligated to investigate crime and did not and proof Det Vergona
was allowed to retire and Chief Campisi is party to the group decision by defendants to pay his
bills.
The new commander of the 01, Capt Brendan Timoney, told me he would arrest Delita Hooks as
soon as IAB contacted him. He knew I had a long talk with Chief Banks Lt. Gannon. He said I
am sure IAB will act promptly. I responded no disrespect but IAB moves as swiftly as a turtle in
molasses.
Delita Hooks sits at that front desk telling anyone who will listen that it was my fault and I
provoked her. She and Det John Vergona and the NYPD and IAB don’t seem to understand there
is nothing a medical patient could do to provoke a receptionist to punch a medial patient. Not in
Ms. Nam’s note from Det John Vergona -- he said you should have kept walking.

It should be noted I “incessantly” contacted the AG’s investigation unit for help fearful Delita
Hooks who attack another person. My video has inspired her to behave better I hear. The AG’s
Investigative Unit referred me to the Manhattan DA and I called all divisions including Cy Vance
directly and was turned away by all stating IAB would have to contact them. I filed a complaint
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with the AG’s office against Cy Vance for this, failing to take action on John Liu’s audit of the
911 Tech Corruption where he requested a criminal investigation and for not criminal
investigation of the “St. Vincent’s Crooks. I expect if IAB alerted the NYPD to arrest Deilta
Hooks and John Vergona the Manhattan DA would I allege fix it for them just like Cy Vance
refuse to investigate the fact mayor Bloomberg broke campaign laws and I allege testilied during
the Haggerty Trial so why are the NYPD and IAB more than reluctant to arrest Delita Hooks?
Ms Nam didn’t share much but what she shared I believe helped me case and I will use to testify
when I get a new Commission in to NYPD and IAB corruption along with her clients letter
stating they want Det Vergona to be represented by what I call tax payer money and their City
lawyer as well as they had me serve Det John Vergona at one police plaza.

In Ms. Nam’s motion to dismiss she omits Det John Vergona’s records and notes of phone
conversations on Oct 16 when he emotional pistol whipped and said I assaulted her and I
said I never assaulted anyone in my life.

Where are Det Vergona’s notes from Oct. 4 the first day we spoke on the phone. I have
phone records of my repeated calls asking for his help asking to meet him to see my black
eye since is confused to meet. Calls to coordinate Apple supervisor to explain about

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Photobooth flipping image but he has become treating me with hatred stating I don’t care
if you have took black eye.
Ms. Nam gives me DD5 not the original notes. Ms Nam gives me none of Det Andy Dwyer’s
notes and I am alleging she with holds all this, Ms Hooks letter to drop charges which has a
yet another threat of retaliation if I go to the police and nothing re: any other defendants
except IAB Sgt O’Donnell but to listen to the audio I have shows I perceive her as corrupt
and want no further contact.
Where are Det Vergona's notes 2 phone conversations where on Oct 16 he twice got
me to consent to false arrest Oct 16 and I agreed twice to be jailed rather than drop
charges and even wait until 0ct 20 a Saturday!

Det Vergona was so committed to fabricating evidence we talked Oct 16 and he refused
to interview dr vine and her medical
Asst.  he said they did not witness the crime.

says via Ms Nam stop incessant emails. The emails are about serious crimes and fixing
including IAB's shocking role.

Ms Nam or defendants leaves out one of the three photos I sent via email after hanging
up with Det Vergona on bus to see my Dad. The photo of me is looking beautiful and
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happy with Mae West cleavage and a big sign just under plunging neckline excoriating
Rudin for no Trauma Level 1 Hospital. Omissions like the phone calls Oct. 4 in the
afternoon, Oct 15 Det Vergona refuses to return my call after he instructed me to
specifically call him the 15, the 2 phone calls Oct. 16, and all of Det Andy Dwyer’s notes
and the fact he never contacted me and any information on any notifications by the
NYPD for Delita Hooks to turn herself in or they never did because they worked with her
to coerce me to drop charges. Did Dr Fagelman call his “hook” to get assistance since
Det Vergona state no medical doctors would be interviewed and my Private Investigator
upon speaking with Dr Andrew Fagelman, Dr Fagelman refused to comment on whether
he spoke with the police? Dr Fagelman did comment he was aware of the situation and
that he had never met me.

I have phone records from Oct 4, 2012 showing I called and spoke to Det John Vergona
detective repeatedly and he either omitted these calls when he turned abusive and
repeatedly refused to meet me to see the injuries to my eye, neck and arm. The arm
had defensive injuries from Ms. Hooks key. There are desperate calls to Apple asking
for help because Mr. Vergona, detective refuses to under photo booth so I arrange to
forward him emails which are in the evidence section but just like the photo of me with
lots of cleavage looking beautiful and happy wearing a protest sign protesting Rudin

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Family Greed and no Trauma Level 1 Hospital where St. Vincent’s was the photo like
the phone calls and emails are omitted by Ms. Nam and or Mr. Vergona.

Ms. Nam omits all of Det Andy Dwyer and his partners DD5 notes calls etc to Ms. Hooks
so we still do not know if she was ever contacted to turn her in.

We do learn Delita Hooks Detectives never contacted me yet Det Vergona did contact
Delita Hooks but we do not learn what the conversation is about. Why? I submit emails
that show I was very upset with Vergona threatening me Sabbath arrest, Vergona’s
email he would go the office and understood my frustration yet he never goes to the
office. He told me he did not have to because her detective went and her detective did
not have to speak to me because Vergona spoke to me yet more proof I was treated
with bias because both sets of detectives met with Delita Hooks.

In conversations with Ms. Nam she admits the NYPD sealed Delita Hooks (False)
criminal report yet she omits this I suggest because like everything else she omits I
allege it all incriminates her clients who violated my rights and also are guilty of coercion
a serious crime as well as fixing crime. The NYPD Fix crimes like a Las Vegas Casino
and make People feel fearful to come forward like so many innocent People stopped
and Frisked or in my case turned away.

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Ms Nam hides the fact the audio of Mary O’Donnell proves I do not want to talk to her
because I am clearly banging my head against what I allege is “The Blue Wall of
Corruption”. Talking to Ms. O’Donnell is futile. Listen to IAB Sgt O’Donnell in her own
words just like PO Migori in her own words turning me away from reporting Delita Hooks
filed a false cross complaint. Please listen to the audio. Thank you.

IMs. Nam’s evidence she submits in her motion to dismiss --- it is like Joseph Heller’s
opening paragraph in “Catch 22” and just like the assault at the MD’s office like a cruel
joke with Ms Nam omitting everything and she can’t say it was because of a time
constraint.
First where is the arrest of Delita Hooks is what I wrote on “NYPD Complaint Follow-up
Informational System Index Sheet page 1-11.

Page 2 of 11 -I showed a former NYPD po page 2 -11 . He asked where is the UF61
Original Complaint. DD5 is a follow up to original complaint. I already allege Det
Vergona has fabrication in Oct 4, 2012 DD5 -- page 3-11
my phone records show 13 minute conversation and I never said we tussled to the
ground. He agreed I had a right to defend myself and I used her momentum to take her
to the ground but she would not let go of me repeatedly attacking me even from the
floor. (We never tussled to the floor and I remained standing trying to get away her as
she pulled me to here repeatedly 135lb of her wrenching my neck and I chose not to
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hurt never kicking her as she was done as she states in her false criminal report -- see
the last page of the evidence section at the back.

DD5 2nd follow-up Lt Burgos page 4-11 remember he would not answer my email
asking for badge numbers see (back evidence section ) Page 30
page 5-11 photos omitting 2 others I emailed him plus reference to video
page 6-11 see bottom of chart B-7 B-7 omitted inaccurate information References Ron
Kuby’s letter but Lt Angelo Burgos like all involved including IAB supervisors thought
nothing odd about the video, photo and medical reports and Ron Kuby writing I agree to
drop the charges against my ATTACKER if my ATTACKER drops the charges. This
entire situation in my opinion crazy. The video says it all and the fact I had to get Ron
Kuby to help and he writes this brilliant letter that is shorthand for my client was coerced
and that alludes them? Ms Nam write Kuby reached out on Monday -- no he followed
up on Saturday’s coercion with this letter Monday after I notified him I went to IAB and
CCRB which he alluded futile and wanted nothing to do with the case. If I did not drop
the charges Ron Kuby was happy to sue on my behalf but based on Vergona’ goal to
inflict more suffering on me and eye and neck damage and rapid weight loss and
emotional distress he suggested for my health to give in to Vergona which was painful
but at agge 50 to be a victim of crime and be jailed when I never even got a detention in
high school and I was having problems seeing, severe neck pain, collapsed bladder -even now as you read this you feel how much I suffered and continue to suffer.
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Page 9-11 case closed --- As IAB Sgt Mary O’Donnell says case closed in audio as
she said to me in our one and only meeting before the audio.

These aren’t Sherlock

Holmes or Miss Marples-- they don’t want to investigate but keep this closed which is
sure lucky for Dr Faglman who did not fire Delita Hooks which is also crazy.

page 9 of 11 bottom of the page SLANDER ‘uncooperative complainant” are you
kidding me? How could I be uncooperative when Lt Angelo Burgos, Sgt Chen,
Det Vergona, Delita Hooks Detectives won’t meet with me but the NYPD met with
Delita Hooks and Det Vergona called Delita Hooks but her detectives lead Det
Andy Dwyer with 16 years at least NYPD experience never contacted me. Again
thank you Ms Nam for more evidence implicating your clients. I have proof of how
many phone calls and emails proving the NYPD are the ones that are more than
uncooperative. I am alleging they coerced me, protected the NYPD that coerced me,
they fixed a savage crime for two reasons -- I allege fixing and favors for Dr Fagelman
and retaliation against me violating my 1st, 5th and 14th amendment rights.

page 10 of 11 “Fearful of my safety” thank you Ms. Nam for this and 00001548
indicates medical reports -- well where are they? The medical reports show
defensive wounds to arm and extensive damage from THE AGGRESSOR Delita
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Hooks. Ms Nam withholding an awful lot and everything involving Det Andy Dwyer/
Delita Hooks detectives as well as Det Vergona’s abusive phone conversations on
Tuesday Oct 16 and Oct 20th as well as emails
like “G-d Sees All” before my date of Saturday Oct 20th false arrest?

Where are the notes on conversations with Ms Hooks? When if at all did they
contact Ms Hooks to turn herself in for false arrest.

Page 11-11 --- I finally learn Ms Hooks age 32 and that she weighs at least 135 pound
and is 5 foot 4. I am alleging Det Vergona was bias against me because of my size and
height hence he said “even steven” no DD5 on that conversation along with shocking
verbal violence and threat of imprisonment if I don’t drop charges which is a serious
crime and from Ms Nam’s evidence we get an idea of supervisors protecting all involved
from Delita Hooks to the NYPD involved --- including Vergona that coerced me in to
dropping charges. I had 135 pound pulling on my severely arthritic neck and I did not
want to fight her or hurt her. I felt the message I got from Det Vergona and all corrupt
cops that fix crime is you are on your own and I understand why many People that feel
violated by the NYPD and feel that they cannot go to the NYPD get guns. The NYPD
don’t want to admit their corrupt dealings add to street violence. I won’t do anything so
foolish. I will continue to report crime and work to get a new Commission in to Police
corruption as stated in my lawsuit.
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P11-11 See “Delite”n again it feels like a cruel joke -- and yet my attacker had my
name, the NYPD involved spoke with her and or met her but I did not have equal rights
under the 14th amendment...... P11-11 shows the NYPD mark off not proficient in
English for a woman, Delita Hooks, that is an office manager/receptionist for Dr
Fagelman; she says on linked in for 10 years yet the letter threatening me signed by
her is written by some one quite proficient in English. Why did Ms. Nam omits that letter
an open threat to me --- Delita Hooks said I attacked her a lie in her false cross
complaint which is a crime but in the letter she takes on Det Vergona’s strategy that it is
even steven and if I file assault charges against her she will file them against me and Lt
Burgos, Sgt Chen, Dwyer and Vergona police on the force established tenure police for
a long time; they did not think anything of that or the video or the medical reports -- Ms
Nam shares Delita Hooks medical reports I allege fabricated medical report - I did not
kick her on the ground and never made contact with the left side of her body. Ms Nam
omits my medical reports.
Why? It was not even Steven as Vergona says (which is omitted in DD5s -- there are
no DD5 shared by Ms Nam on my agreeing twice to false arrests) but watch the video,
reading my emails, see my phone records we see a good person, a victim trying
desperately to get help from the NYPD who in my opinion behaving criminally just like
Ms Hooks and working with her so she can remain at the front desk for her employer
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that doesn’t think her behavior is wrong or even dangerous along with the NYPD and
IAB all involved and IAB can’t get away with the excuse they do not have to investigate
this.

More proof what Ms Nam shares and even more proof what Ms Nam omits which is an
awful lot. The fact her clients won’t take responsibility just like Dr Fagelman and Delita
Hooks appears to me like they have too much in common and is why Det Vergona
instructed me to not contact him or Delita Hooks but where is that DD5. Where is that in
the notes because his instructions sound like he and Delita Hooks are in this together.
Ms. Nam told me Delita Hooks (false) cross complaint was sealed. Well where is the
record of sealing it. Why is that omitted? What is omitted along with what Ms. Nam
shares if more evidence this case must not be dismissed.

Conversations with Ms. Nam lawyer for Denfendants

First conversation Ms. Nam told me email her as much as I wanted with the same tone Sgt Chen
tone of amusement of Sgt Chen who said You were the one assaulted at the doctor’s office.
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In the motion to dismiss she refers to me incessantly emailing Internal Affairs. I wouldn’t have
to incessantly email anyone if they responded to me and do the job they are suppose to be trained
and supervised to do. The NYPD and IAB has how many supervisors and checks and balances?
I am a victim of a violent crime and abuse by the NYPD and IAB.
In that same conversation Ms. Nam told me Delita Hooks what I term (false) cross
complaint against me was sealed. (We so no evidence of this in the evidence Ms. Nam
submits. I allege Ms. Nam omits an enormous amount including the fact her clients sealed Delita
Hooks false cross complaints because it proves my case and would mean the possible arrest of 1
or more of her clients. This is highly unusual. If I was a criminal I would be thrilled but I am a
victim of a violent crime and by rushing to sealing Delita Hooks false cross complaint I am
alleging the detectives involved where sealing the fact they coerced in me to dropping charges
also a serious crime as well.

Ms. Nam in phone conversation re: motion to dismiss. She never asked me if I paid for lawyers
and in fact despite being pro se -- pre filing I paid lawyers to consult and help. I have a lot of
expenses that I deem are her clients fault. I went to get medical care and than I went to NYPD
and than I went to the IAB -- this is a horror story but true -- I feel like the character in Franz’s
Kafka’s The Metamorphosis. This can’t be happening. Det John Vergona with malice coerced
me and HUMILIATED me as well as verbally abused me. You can hear me in the audio from
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the First Precinct repeatedly ask for help from PO Migori, from Sgt Chen who both turn me
away and prevent me from filing a complaint Delita Hooks filed a false cross complaint even
after Sgt Chen instructed me to come down and file it, than you hear me call DI Ed Winski, IAB
and CCRB. I described my emotional distress as “garden variety” and I have yet to get the help I
need and focus on healing as I continue to deal with the trauma and upset from the NYPD and
IAB abuses and Ms. Nam’s motion to dismiss and Ms. Hooks false cross complaint gave me
more insights to the depths of the lies and abuses. It has harmed me life and even my
relationships as I am so exhausted from this own going struggle to get Justice and clear my
name. My YouTube showing Delita Hooks threatening me and the beginning of the assault and
not the abuse I suffered pre has prevented her from abusing any other patient and if she harms
anyone again the victim can go after her employer and the NYPD as well. I have suffered
greatly and continue on with terrible insomnia and worsening health conditions because I can’t
get the rest I need to heal and I can’t focus on healing because Ms. Nam’s clients refuse to take
responsibility and the evidence I present is proof of the indefensible yet Ms. Nam and her clients
defend it and Det John Vergona even making the tax payers pay his legal bills and having me
serve him at One Police Plaza adds even more suffering to my emotional distress. I can’t see my
mother and have to focus on my father who are divorced because I am so exhausted from this
and also have on going medical treatment and care for the damages of the assault. Any
emotional support I have gotten from the Police Abuse is so far free and they all agree I am the
victim her and I have received praise for my actions as a victim advocate.
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It is clear from the evidence I present and I could present far more emails that are not incessant
as in a nuisance like the misogynist term “nagging housewife” for a woman that works a full
time job for zero dollars and is devalued and not heard thanks for anti-woman label for seeking
to hold the NYPD and IAB accoutable. The NYPD do not have to investigate crime but IAB has
to and did not. Proof Delita Hooks has not been arrested and Det John Vergona was allowed to
retired without me being interviewed.
Ms. Nam told me I had no case. There was no assault. That was why they didn’t allow me to
report Delita Hooks filed a false cross complaint. I instructed Ms. Nam to listen to the audio I
recorded and hear NYPD Migori state the reason I can’t report Delita Hooks filed a false cross
complaint is Ms. Migori states only a detective or DA can do that which is not true. The NYPD
violated my rights not allowing me to report the false cross complaint just like they violated my
rights coercing me to drop charges which took from Tuesday Oct. 16 - Oct 20 to do because I
feared for my shockingly declining health and well being. I learned First Aid and CPR and I
can’t do CPR on someone if I don’t believe the area is safe for me -- and I felt unsafe to
turn myself in to a man named Det John Vergona who yelled, you are going to drop the
charges or I will arrest you! He had told me I don’t care if you have two black eyes. Like
Delita Hooks he was verbally assaultive.

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Since Ms Nam told me there was no assault I decided to go to the 01 Precinct to report a new
assault -- and I am only allowed to go to that Precinct and no other because of the location and
again I was turned away just like the attempt to report a false cross complaint and again I called
for a supervisor. Unlike Sgt Chen who I allege is a coward who would not come down and face
me, 2 supervisors did come and meet with me. This was Friday Sept. 27, 2012 and Sgt Feldman
and Lt. Hendricks met with me. I got names and the Sgt.’s badge number.
Lt. Hendricks informed me the case was “open” and I was not being allowed to upgrade the
assault charges which again in my opinion is a violation of my rights.
I called Ms. Nam and gave her the information including badge numbers and names. When I
asked her for equal respect and information in my opinion I didn’t get it. In contrast see
evidence section page 30 in the back of this motion, Lt. Burgos refuses to answer my emails
giving me badge numbers. I sent hard copies of this email to Commish Kelly, Chief Esposito,
Chief Campisi, and DI Winski no response.
Whether the NYPD agree with me re: my allegations of Det John Vergona’s allege hate crime his
treatment of me and words or no words when I ask are you anti-Semitic, whether they agree
assault in the 2nd degree or not, false cross complaint or not -- the NYPD is suppose to allow to
report crime.

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I am stating the violated my rights by not allowing me to report crime and also coercing me to
drop charges which was again not allowing me to report a crime and any half decent cop would
want a record that I came in and made these complaints. If they were false the NYPD could
arrest me.

Ms. Nam told me the case was closed. In my section on her motion to dismiss I point out Lt.
Agnes re-opened the case as evidence Ms. Nam shows us in her motion and I allege he failed to
supervisor properly and the fact the case is now open as of Sept. 27, 2013 I believe proves
already there was reason for Lt. Burgos, a season NYPD veteran to take a closer look but just
like IAB Sgt Mary O’Donnell can be heard to say on the audio recording...”case closed” which is
the NYPD mantra in my case despite overwhelming evidence I was assaulted when Delita Hooks
could have easily closed the door. The video shows me clearly retreating to avoid physical
violence not rush to meet it.

Ms Nam in a letter to the Honorable Judge put words in my mouth I allege just like her
clients all collectives supporting a mutual assault where the evidence most especially the
video, Delita Hooks false cross complaint, the photos, the medical reports prove there was
no mutual assault but Delita Hooks savagely attacked me when she could have closed the
door --- Ms. Nam said in the letter I was considering amending my lawsuit and I was not as
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you can see from this opposition motion that was not true. In a letter to the Judge after Ms
Nam put words in my mouth and Lt Angelo Burgos alerted my server Vergona’s home is on
Staten Island I did think about amending my lawsuit but I never ever discussed the
consideration with Ms Nam prior to the letter she wrote to the Honorable Judge yet she
states that I am considering it.
Ms. Nam has not provided a convincing argument that her clients did not violate my rights
as powerfully explained in my lawsuit and besides coercion which is a serious crime that
IAB was obligated to take action against Det Vergona and all involved as well as also alert
the First Precinct to arrest Delita Hooks for assault and a false cross complaint. I continue
to allege the NYPD at all levels from Det Vergona and his partner to Delita Hooks
detectives who never contacted me, to Lt Burgos who refuses to even answer an email
asking for badge numbers and the email is in this evidence section and was mailed to Mr.
Kelly, Mr. Campisi and Mr. Winski, as well as Lt. Agnes refusing to return my calls and all
involved not meeting with me the victim of savage violence, a false cross complaint a
serious crime, and the NYPD’s criminal action coercion and I allege fabrication of evidence
based on the video as proof and the made over Delita Hooks false cross complaint stating I
attacked her in to a mutual assault. There was nothing mutual about this and what Ms
Nam presents helps my case and what she omits also helps my case.
I want to ask you to look at page 53 and point out they all violated my right to Due
Process under the 5th amendment.
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;

(c) freedom from the threat of lodging of false charges against her by
police officers in violation of her rights to due process, under the Fifth
and Fourteenth Amendments; From Page 52 on the lawyer that I paid
not to represent me but consult me and I would like to be compensated
for that, the legal expenses of filing, serving all with subpoenas,
xeroxing, etc --- her legal work on my behalf in my opinion compelling
to not dismiss this case but to move forward.

The NYPD and Internal Affairs Retaliation List Against Suzannah B. Troy Whistleblower
With out access to my files both the NYPD and IAB files I can still present what I believe is
viable motive for retaliation against me.

1) Note the emails to Det John Vergona. I believe he saw my passionate blog posts demanding
to know when the NYPD Heroin Rape Cop Moreno was going to jail. (Page 9 of original
lawsuit NYPD Rape Cop) An activist warned me not to blog about this while Det Vergona
was investigating my case but I could not have less freedom under the First Amendment
because I was a victim of a violent crime.
2) I was getting a lot of blog activity on NYPD Detective Pepe and my Bullet Proof Condoms
posts, ultimately stand up comedy from my blog about how the NYPD should issue bullet
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proof condoms considering the state of affairs so rampant in the dept. Note “Internal Affairs”,
Community Affairs” so is this Staten Island resident perhaps Det John Vergona’s neighbor?
3)

My IAB file will show you I asked them for help because of what I term economic racist
policies of DI Ed Winski and gang cleansing the streets of the (page 5 of original lawsuit)
Veteran Vendors and Artists while ignoring The Mercer Hotel using the loading and unloading
zone as private parking.

4)

IAB Complaint number 10-37939 from 0728/10 I found a forged NYPD parking placard
parked in front of the Mercer Hotel and I could not get the NYPD to look at it instead unfairly
ticketing Veterans over inches. I ended up calling Commissioner Kelly’s office and making
contact with Det Brown who you can see I email as I grow more alarmed at Det John
Vergona’s behavior as well as LGBT Det Duffy. See evidence Section. Det Brown told me
to call IAB. IAB phone system doesn’t pick up until the 13 ring which they now remedied but
07/27/10 IAB Det Pavlovici (he was transferred out of IAB) wrote up IAB for not answering
the phone when he met with me the next day and saw how many times (what Ms. Nam’s
clients in a negative way call incessant) but Det Pavlooci saw it a a good thing and wrote up
IAB. He told me to call 911. I don’t believe they caught the guy that forged the NYPD
parking placard and if they had just ticketed him instead of cleansing the sidewalks as per
Michael Rawson than manager of The Mercer they would have had the illegal placard diver’s
lic plate.

If someone is bold enough to put a forged NYPD placard in the window of their car

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what else would they be bold enough to do? I embarrassed IAB and the NYPD on top of
which the NYPD wouldn’t even look to busy ticketing vets for The Mercer Hotel.
5) I am the only one in the media and blogosphere to report that Internal Affairs is behind by as
much as 3 months each year getting the NYPD their parking placards. From my blog I called
for People to not pay their parking tickets as IAB can’t get their 2012 parking placards to the
NYPD by Dec 2011 as required. In terms of Terrorism and any crimes of people
impersonating police this is concerning.
6)

I found an expired or forged parking placard outside Rudin Luxury Condos Sales Office
while protesting to demand a Trauma Level 1 Hospital. IAB did tell me the car belongs to a
woman who lives on Park Avenue but as usual I hear nothing more.

7)

No Third Term Protest of Mayor Bloomberg at City Hall Park which was blacked out by
everyone except “World News” and “El Diario” a protest deeply critical of Mike Bloomberg’s
illegal third term and reminder commissioner Ray Kelly was accepting (page 35 lawsuit IAB
allegations abuse of rides helicopters etc. is that because Mr. Kelly was taking them?) free
rides from mayor Bloomberg and states it’s his favorite way to travel so I am suggesting Mr
Kelly’s role in defending Mr. Vergona who coerced me to drop charges and told me I should
have kept going if what Mr. Kelly, Mr. Campisi and anyone fear of bloggers reporting
corruption and reporting Injustice wants for us to be silent hence the NYPD and IAB in league

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wearing when attacked omitted in motion to dismiss. Gartner employe John Doe page 25 lawsuit
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with Delita Hooks and making over her false cross complaint a serious crime in to mutual
assault.
8) (Page 31 original lawsuit) First Precinct PO Eugene Schatz used his squad car in an aggressive
manner to attempt to intimidate me and lied to me telling me The Mercer Hotel can use the
loading and unloading as private parking. I was leaving a voice mail for IAB and I wonder if
they destroyed it because he used his squad car and sirens illegal to rush from the First
Precinct to get to my 15 minute protest of Michael Rawson and The Mercer Hotel minute 14
all documented on YouTube harassing us. For this he was promoted to “Community Affairs”
at the first precinct. When I learned of it I left a message for Community Affairs for a Det I
thought was nice and the next day I got a series of anonymous emails from a man responding
to my “Schatz is terrible” with I am a terrible artist...he made comments re fixing me up with
his lesbian sister that appeared to me homophobic and forwarded to IAB as well.
9) I thought it was very odd that Det Vergona has not arrested Delita Hooks and in a Fed Ex to
commissioner Kelly I referenced my concern as well as had a conversation with Det Delpozo.
He tried to comfort me and told me Det Vergona would get back to me. He was working on a
homicide. There had been a bunch of them in other precincts near by. I asked if he was
related to Deputy Inspector Brandon Delpozo rumored to be on the fast track for Police
Commissioner despite his youth. He said no. I told him he seemed like a nice guy but I was
disappointed in him I had not heard from him when I reported a retired commander attempting
to fix a parking ticket for a Rudin flunkie.
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10)

(Page 39 lawsuit at bottom of page)The NYPD and Deutsche Bank violated our First
Amendment rights and thanks to Norman Siegel we won. I called Norman Siegel ASAP to
alert him that DB made me remove my sign I wore as body art and they were violating the

rights of OWS and visitors like me and I called a NYT reporter. We won and the NYPD and
DB lost. This is at 60 Wall Street part of DI Ed Winski’s domain and more proof of economic
racism. As usual the invisible woman I am not referenced in the NYT article and Norman
thought my video a tad sympathetic to the NYPD but he can verify I was the prime mover
although his letter was the powerful genius that got us a victory! See: The NY Times “At a
Meeting Spot for Occupiers, Prohibit Signs” by Colin Moynihan. Letter on Scribd.com
Norman Siegel Herbert Teitelbaum Deutsche Bank NYPD First Amendment Letter regarding
sign policy 60 Wall St. The NYPD were enforcers for DB making me remove my signing
violating my 1st Amendment right and again I felt like a Jew in the Early stages of Nazi
Germany but the NYPD and IAB took it to a whole new level turing me away preventing me
from reporting crime including IAB who refused to investigate my allegations of aggravated
harassment including possibly NYPD on YouTube including the removal of the Det Vergona
Delita Hooks assaulted me filed a false cross complaint no arrest.
11) (Page 5 and 32 Lawsuit 911) I went to testify at City Hall re: 911 Tech corruption and the
system is flawed. My stirring testimony is audio recorded and on YouTube demanding an
investigation in to Mark Carson’s ambulance response time and a criminal investigation in to
911 tech corruption as requested by John Liu a year and a half ago. I handed in FOIL reports
of ambulances delayed and a refusal to give me Mark Carson’s response time. I saw NYPD
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commissioner Ray Kelly before I testified at City Hall and handed him a Justice Card pre the
lawsuit that made it clear I was assaulted and Delita Hooks filed a false cross complaint and
the NYPD fixed this violent crime like a Las Vegas Casino. Once inside I handed a Justice
Card to everyone in the room possible including FDNY Chiefs. I handed one to NYPD Chief
Dowd who’s field is technology. After I attempted to hand him my testimony for fear he
would leave before I testified and he did leave early along with Cas Holloway and the FDNY
Chiefs. The FDNY Chiefs took my written testimony.
NYPD Chief Dowd refused to take my testimony after reading my card again underscoring the
NYPD’s bias towards critics and a subtle form of retaliation. It should also be noted that 911
Tech is the NYPD’s baby so to speak. I had contacted the FBI Aug 20, 2012 asking for their help
with an investigation in to 911 and warning them the 911 system would collapse and it did under
Hurricane Sandy. Commissioner Ray Kelly along with mayor Bloomberg stated the 911 System
worked which is not true. The system is a mess and is over budget by at least 1 billion, 4
million dollars. The 2nd back up system is not up and running yet despite 50 million dollars of
tax payer money and the NYPD is retaliating against me for being the most vocal critic of 911
tech corruption. Mr. Ray Kelly wanted The Homeland Security Job which he will not get and I
followed up with a letter to Homeland Security after Lillian Robert,
“Holloway’s letter was a response to a formal complaint to Napolitano from Lillian
Roberts, executive director of District Council 37, the main city workers union.” See
belowL
NYDN Juan Gonzalez: Bloomberg lauds 911 audit he once called ‘stupid’
No mention of “stupid” findings or of the city disagreeing “almost entirely” with Liu.
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Holloway’s letter was a response to a formal complaint to Napolitano from Lillian
Roberts, executive director of District Council 37, the main city workers union.
]

Letter dated Aug. 9 from Deputy Mayor Cas Holloway to Homeland
Security Secretary Janet Napolitano regarding the 911 system.

Cas Holloway insulted us gravely before we testified and he was made to
eat his words. I am alleging that mayor Bloomberg and commissioner
Kelly are fully aware of my activism exposing contractors that I believe
based on John Liu’s audits bilked tax payers historic amounts and this is in
the tech sector with Mr Bloomberg a suppose tech whiz and great biz man
allowing a revolving door of corruption so they retaliated as I just explained
as soon as Chief Dowd read my Justice Card he refused to take a copy of
my testimony although his FDNY counterparts agreed to take my
testimony. YouTube:

“City Hall Suzannah Troy 911 Testimony on Mark Carson Interrupted” June 21, 2013. (I
repeatedlly as interrrupted as I tried to testify about LGBT Hate crime murder of Mark Carson after
waiting for almost 5 hours to testify and most everyone had left.)

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The NYPD and IAB were essential telling me to shut up as well as don’t report crime violating
my constitutional rights.

9) I am the 2nd whistle blower on 911 to be the victim of NYPD creative policing. Unlike me,
the same Det Squad succeeded in intimidation and silencing her. The commander of the 01 at
the Time was DI Bologna who Ron Kuby is suing on behalf of a woman pepper sprayed for
no good reason, just like Delita Hooks had no good reason to violate my patient rights and
body but I allege the NYPD and IAB violated my rights sending me a message to shut up.
10) My not allowing me to report crimes that too was a violation of my 1st amendment rights. I
had a right to make a complaint re: assault and not be coerced with the goal to not be silence.
Det John Vergona talked me to like a criminal with the goal to shut me up and told me not to
contact me. Jane Doe was silenced using intimidation and the Manhattan DA was involved as
well like the Michael Premo case but it didn’t go to trial and instead they said what Det
Vergona said to me stay out of trouble. They sealed her false arrest on behalf a retired NYPD
Sgt who’s wife lives in Florida yet he kindly offers to drive single women working at DOITT
home. DOITT for some reason has a high volume of lawsuits by women for some reason.
11) Again sent a message to shut up be silent in retaliation against me for successfully exposing
mayor Bloomberg’s NYPD intelligence division (page 47 lawsuit Kevin Lynch, Bloomberg’s
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bodyguards) det Kevin Lynch violating NYPD protocol refusing to give me his name and
badge number. CCRB ruled in my favor. I am waiting to hear how commissioner Ray Kelly
punished him. I believe I will never here of any punishment despite CCRB’s ruling. Before I
was savagely assaulted Oct. 1, 2012 you can see on my phone bill a conversation I had with
Mike Bloomberg’s NYPD Intelligence Division Sgt. Kevin Lynch’s supervisor asking how I
got Lynch’s first name. I had to laugh the Intelligence Division asking me about my Intel.
12)

Reposted from my 


Economic Racism and NYPD Policing Section” My private investigator told me Dr Fagelman
lives in Battery Park City. I believe that makes him a neighbor of commissioner Ray Kelly.
Why would that matter? Does it? I don’t know. The NYPD under Mike Bloomberg and Ray
Kelly run the communities like the one Dr Fagelman lives and works in as an gated
community with invisible gates and One Police Plaza which IAB offices, The First Precinct as
well as IAB commander center are all near Dr Fagelman’s offices and his home so I am
suggesting he was given “favor-tism” and it gave all parties sadistic pleasure that I was
savagely punched in the eye as I help my bags and Iphone -- are numbs because I have given
them all “a black eye” via my blog. I held Ray Kelly in esteem but he accepted free rides on
“Air Bloomberg” , mayor Bloomberg’s private Jet for both him and his spouse when he is not
allowed to accept a cup of coffee. So yes I am alleging that Dr Fagelman made calls either
directly to the NYPD for help the way Michael Rawson (page 31 protest reference original
lawsuit) formerly of The Mercer Hotel would call the 01 to get the Veteran Vendors and artists
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swept off the street. I am also alleging the possibility that he called someone like a “Bill
Rudin” who has a retired NYPD commander on his payroll whom I witnessed tried to fix a
ticket for a Rudin Flunkie.

I keep calling for a criminal investigation in to 911 Tech Corruption and HP is one of our
Countries top 20 military contractors. This would be a huge problem for Ray Kelly is he was
hired as homeleand security but because of Stop and Frisk and his response after the Honorable
Judge Shira Scheindlin -- and by the way Stop and Frisk Abuses another form of economic
racism.

Ray Kelly’s popularity crashed like a stock during the Great Depression.

Ditto for SAIC who I believe I helped to get banned from any NY State and NY Gov contracts
with my “incessant” blog posts and YouTubes. I am alleging the NYPD has a long standing
relationship with SAIC and even considered them for what people call “spy ware” the Domain
System. Oakland has hired SAIC to do their video system “to keep People “safe”” but based on
my experience why video prove that can’t be challenged along with her false cross complaint a
serious crime I have written from my blog many times that the 35 Million Dollar Domain system
will need a special unit in IAB to destroy video that implicates corrupt NYPD and an example is
the false prosecution of Michael Premo (yet another example of economic racism) where the DA
and the NYPD claimed The Taru police office was a on a secret mission and they did not want to
provide the video that would prove this was a false arrest, trumped up charges just like Det
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Vergona yelling at me I am going to arrest you if you don’t drop the charges. Well the Judge
made the NYPD Taru video appear. He is accused of testilying and Democracy Now turned over
the video since they were standing next to Taru and Michael Premo was acquitted.
Please see page 6 of my lawsuit:
CityTime and SAIC was brought in by Rudy Giuliani and Rudy’s deputies turned lobbyist for
SAIC. Mike Bloomberg pushed SAIC like a drug king pin pushed heroin. Working with Local
375 DC 37 we kept up the heat on SAIC corruption and pressured Bloomberg to stop being
SAIC’s cheerleader and to demand 600 million dollars back. We got $450 million tax dollars
back cash. On linkedin I found retired NYPD consulting SAIC. I was the first person to call for
termination of all SAIC contracts with NYC Gov and the NY State Comptroller did so months
after I posted a YouTube calling for no renewal with SAIC. The NY State Comptroller banned all
SAIC State and City contracts and again this is motivation in my opinion for Mr. Kelly to defend
Det John Vergona’s crime of coercion and verbal violence treating me like a criminal and telling
me to stay out of trouble.

I think it is a fair question to ask if commissioner Ray Kelly accepts free rides while employed
by mayor Bloomberg how many free rides was Ray Kelly entertaining from top contractors I
alleged grossly over billed/ robbed tax payer money?

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13) The NYPD and IAB were sending me a message because I gave them “a black eye” as well
as contractors SAIC and HP which I believe the NYPD have had a long term relationship
including after they retire? “Mayor Mike Bloomberg's CityTime tax payers Titanic renewal
must be stopped Sept” YouTube dated May 27, 2010 I called for an end to contract with SAIC.
The NY State Comptroller agreed with me later banning all contracts gov and state which isn’t
good for NYPD and retired NYPD planning on SAIC consulting jobs.
A Village Voice news reporter told me SAIC had a contract with the NYPD under Commissioner
Safir and searching Linked in I found an NYPD counter-terrorism listing SAIC on his resume
along with an NYPD sgt who on linkedin states he is a consultant to SAIC, as well as Jane Doe’s
cross complaint by retired NYPD Sgt John Doe who was consulting for Gartner Group on tech
including the 911 Tech system I call the Tax Payer’s Titanic -- including HP as the lead
contractor with no 911 Tech experience. I am alleging that the NYPD is retaliating against for
blow the whistle aka “giving a black eye” exposing NYPD and IAB corruption as well as
contractors like SAIC and HP. HP is listed as one of the top twenty US Military Contractors and I
have been calling for a criminal investigation daily for their role in the 911 Tax Payer’s Titanic as
well as other and I believe this is upsetting for mayor Bloomberg who was giving commissioner
Kelly free rides on his jet and the NYPD retaliated against me to send me a message treating me
like a criminal when I was clearly the victim. (Also see “NYPD Economic Racism for SAIC HP
and the NYPD’s retaliation page 80.)

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The NYPD have a history of stealing from drug dealers back in the day of Serpico, Joe Sanchez
a heroic NYPD officer set up by drug dealers today still going on NY Post “April

14, 2013

17-year NYPD vet was busted yesterday for allegedly helping a stickup
crew pull off a series robberies of drug dealers in which they all posed as
cops.
Officer José Tejada, 45, is accused of taking part in the raids, dating back
to 2008, in which he and his pals wore police uniforms as they allegedly
barged into drug dens with fake warrants, handcuffed the dealers and
robbed them.”
I am suggesting that the NYPD and IAB gave me the Serpico, Sanchez
treatment -- not that they set me up but when I was savagely attacked it
was like the civilian version of getting shot in the face as Serpico did or
falsely arrested like Joe Sanchez did 30 years ago.
I am suggesting is the NYPD has graduating to collecting pensions and biz deals with Oligarchs,
SAIC who was robbing us, advising for Gartner who in my opinion was robbing us and like
mayor Bloomberg and Mark Page could not do simple math we were being robbed on CityTime
and 911. 911 we went over budget over 1 billion dollars and I was retaliated against because I
called for an end to contracts with SAIC and HP. I also want Gartner investigated for their
consulting and the billing which I believe was excessive and they were exposed for agreeing to
give Spherion kick backs on CityTime “quality control work”. I believe these companies all
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employ retired NYPD who may be ethical or like the contractors that employ them may not but
may resent my work to end biz with NYC gov.

If it was a drug dealer and I was a whistle blower they would have sent an NYPD enforcer to
beat me up in the day or like Serpico set him up to be blown away is what I am alleging. Dr
Fagelman’s Delita Hooks did them a favor and they did her a favor fixing for her and her
employer who did not fire her.
14)

Before I was assaulted by Delita Hooks I got a call from mayor Bloomberg’s NYPD
intelligence division to interview me via th phone and Det Kevin Lynch making contact with
my body. He did not hurt me but he used his body to intimidate me and he made contact
with my foot and my bag. I assured his supervisor he did not hurt me but he behavior was
wrong. Just like Delita Hooks you can hear me in the video telling him to get away from me
and he did unlike Delita Hooks who attacked me. I embarrassed the “NYPD Intelligence
Division”.... the supervisor asked me how I get Det Kevin Lynch’s name and his supervisor’s
name. I had to laugh -- the intelligence division asking me about my “intelligence”? I
referred to them as the “unintelligence division” because there are countless videos of mayor
Bloomberg’s intelligence division detectives getting physical with protestors or media and or
violating protocol refusing to show their badges and identify themselves. I created a playlist
on YouTube.

“Going

over phone records.  Oct 1, 2012: There is call

from of NYPD Det KevinLynch’s supervisor, the Bloomberg
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bodyguard who violated protocol.   The call comes in before I am
assaulted.  Det Lynch's supervisor admit that Lynch has to obey
protocol.

Than I am assaulted.  Got the phone records from Oct. 1.
NYPD Intelligence Division supervisor for Kevin Lynch called before
Assault Oct 1, 2012, that Det Vergona fixed me being assaulted coercing
to drop charges.  
DD5 omission by lawyer or Det Vergona calls Oct 4 afternoon where he
was extremely abusive to me and refused to meet me in person to see
damage to my eye.    The fix was in. 
DD5 submitted by NYPD and IAB lawyer shows 1 call only Oct 4. “ I
have the phone records from Oct 4 where Vergona turns abusive there
are a series of calls and I call again when I leave my Dad and get in to
Penn Station and again Det Vergona refuses to meet me to see the
damage to the eye so did Ms. Nam omits or Det Vergona never recorded
the calls where he was extremely abusive stating he didn’t care if I had
two black eyes. Where is the DD5 to these calls? The calls also involve
2 desperate calls to Apple telling them how abusive Det Vergona is and
that he does not understand photo booth and the image is flipped.
At the end of Oct. 2013 I mail out a press release to news reporters that
report on NYPD. The ones that have press passes like all media get their
press passes from the NYPD. I show them the front of this motion and
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the word c/nt. Shortly there after the cyber bullying alleged witness
tampering starts up again as it did on Oct. 4, 2012 when Det Vergona
became abusive in concert with the first cyber abuse (aggravated
harassment) and continued on until I filed the lawsuit against the NYPD
and IAB. Than just before my Dad dies Nov. 2, 2013 it starts again on 2
NYPD YouTubes one Det Vergona IAB and DElita Hooks and one on
Det Kevin Lynch. I am told I am c/nt, to shut up, and to get a life. On
the way home from my Father’s funeral more abuse and the next couple
of days until I contact the FBI re: this motion and the abuse as well as
Google YouTube and Google US Law Enforcement. I also let the press
involved I allege one of them showed my email to a dirty cop who set up
the equivilent of the Dirty 30 when dirty cops would beat up people -called enforcer and this is the YouTube equivalent to harass and
intimidate victims of NYPD abuses.
15) Ms Nam’s omitted a third photo of me before I was assaulted where a protest sign like a very
large necklace slamming Rudin. I allege the NYPD and IAB violated my rights for two key
reasons. 1) I reported to IAB Bill Rudin’s private security is headed by a retired NYPD
commander who I caught trying to fix a parking ticket for a Rudin flunkie and 2) NYPD IAB
retaliated against me violating my rights because they associated me with OWS.
16.

I am including this because in my lawsuit on page page 35 I talk
about IAB “rides” on helicopters as Eric Sanders, lawyer writes on
behalf of Det Pelage suing IAB Chief Campisi and IAB for 15 million
dollars so I am alleging IAB just playing follow the leader Mr. Kelly
and his “rides”.

Bloomberg Is Still
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Letting Ray Kelly Use His Jet,
Getting Flak for It 8/14/2013 at 2:02 AM
By Margaret Hartmann
I am one of mayor Bloomberg’s biggest critics and I have exposed him as the little emperor of
NYC with no clothes when it comes to being a great tech and biz whiz when he in guilty of over
seeing the largest abuses and or theft in NYC gov history with CityTime SAIC and subcontractors like TechnoDyne and I allege Gartner Group on SAIC and 911, 911 Tech corruption
over 1 billion dollars over budget, CityTime only 700 million over budget, NYCAPS $277
million dollars over budget, Board of Election tech mess 98 million dollars, I can’t get the
figures on 311 but I allege another Tax Payer’s Titanic cost far more than what 311 is actually
delivering, FDNY Wireless and NYC WiN I allege over budget and messes as well.
I allege SAIC and others hire retired NYPD which is yet another reason for retaliation against me
like the retired NYPD Sgt John Doe who advises on 911 Tech and I believe his company charged
90 million dollars for advice when they couldn’t do simple Math that HP one of the top military
contractors had no 911 experience and I allege grossly overbilled NYC tax payers and they were
not alone.
Mr. Ray Kelly admits to taking free rides on Air Bloomberg when he is not allowed to take a free
ride from a diner. Bernie Kerik the last police commissioner while in jail was excepting free
rides from wealth friends for his wife and family. (Why is he offered these?) I am asking what
free ride Mr. Kelly will accept after he leaves office like the ones he enjoyed from mayor
Bloomberg for he and his wife. I am a whistle blower hence Mr. Kelly’s support of my rights,
my body being violated and the NYPD coercing me to drop charges and fabricating evidence
making over Delita Hooks false cross complaint into mutual assault.
“Sly Stallone, other A-listers visit Kerik in clink Sometimes, the family hitches a ride with
Kerik’s friends — in cars, private planes and helicopters. October 22, 2012 | 4:00am The

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NY Post His visitors include Sylvester Stallone, former stock-exchange chief Dick Grasso,
retired cops, correction officers and even a congressman.”

Det Vergona told me I should have get going and not documented Delita Hooks violating my
patient rights. I am alleging Det Vergona got Ray Kelly and top brasses blessing including
Internal Affairs blessing because of my whistle blowing that I deserved to be a victim of violence
and to fix this crime as Mr. Kelly and Mr. Campisi insist on defending John Vergona 3rd grade
detective and having Vergona served at one police plaza to further protect an NYPD officer
caught involved in committing a crime of coercion. Det Vergona could not have fixed this crime
without assistance and protection just like the NYPD sealed Delita Hooks false cross criminal
complaint with their crime coercion Mr. Kelly and Mr Campisi instead of taking responsibility
and apologizing are in my opinion as guilty as Det John Vergona.
By me being a whistle blower I have helped to prevent SAIC from doing further business with
NYC gov and what do I find on Linkedin but retired NYPD as advisors to SAIC. Jane Doe was
a victim of creative policing by the same det squad First Precinct under DI Bologna on behalf of
retired NYPD Sgt an advisor and the goal was to make her and I fearful and to silence us. I did
cave in to coercion due to the very dangerous state of my health that was declining the hole in
my retina, weight loss (now sadly large weight gain), and collapsed bladder which is the only
condition not from the assault plus I feared what Det Vergona who had been repeatedly verbally
violent to me on the phone threatening me yelling at me if I did not drop the charges he would
arrest me and would not answer questions why did I have to wait 4 days to be false arrested until
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Serpico references page 36 lawsuit Knapp synonymous

the Sabbath and is he anti-Semitic. I feared for my safety and I learned in First Aid and CPR
before I can attempt to save someone’s life I have to make sure the environment is safe for me to
perform CPR and in this case I felt I was walking in to even more danagerous circumstances. I
felt I was in further danger and was never told if Delita Hooks would there. To date IAB has
refused to tell me if the NYPD ever notified Delita Hooks to turn herself in on Tuesday when I
agree to Tues Oct 16 arrest and than Oct. 20th false arrest. Ms Nam’s evidence carefully omitts a
lot of evidence that incriminiates her clients so I do not believe Delita Hooks was contacted and
the NYPD acted with bias, prejudice and malice against me and continue to do so because I am a
whistle blower and also I allege because Dr Fagelman contacted someone powerful in the
NYPD.

My YouTube channel starting with Mr. Kelly’s source of free rides on Air Bloomberg
“Mayor Bloomberg King of New York” youtube one of 343 where all removed (page 48
lawsuit)before an election Mr. Bloomberg barely won. The Wiki page (page 48 lawsuit)
on this was removed during the harassment phase on line on behalf of Dr Fagelman,
Delita Hooks and Det Vergona and I don’t believe it was a coincidence. I am alleging
there has been a long term goal to violate my rights and silence me and you can see from
Mr. Kelly’s actions in this lawsuit including his support of Det Vergona that in my
opinion he condones me being violently punched in the eye almost blinded to send me a
message on behalf of Mr. Free Rides Mike Bloomberg and the NYPD and IAB.
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“Suzannah B. Troy Will Not Be Quiet(ed) The NY Observer (Azi Paybarah page 48
lawsuit)
By Azi Paybarah 9/22/09 8:52pm

The YouTube account for one of Michael

Bloomberg’s most prolific, and eccentric, critics has been suspended.”

Actually my YouTube account was deleted and it had a video from 6 months before the
election telling views do not believe the media Mike Bloomberg may not win due to vote
anger.

Before my Father died Nov. 2, 2013 I wanted to settle with the City but now I want to go to
trial. I want to ask Mr. Ray Kelly about his relationship with all contractors that I have
exposed on my blog starting with SAIC who has NYPD “consultants” as posted on linked
in NYPD resumes, HP, Gartner Group, and all contractors involved in CityTime and the
911 Tech mess as well as 311 and also JP Morgan who may employ Mr. Kelly if Mr. Kelly
loses his job at the end of this year. I want to ask him about private rides on jet planes or
helicpoters other than mayor Bloomberg’s, his relationship with Mr. Bloomberg because
the NY Post article on Mr. Kerik illustrates to me that being police commissioner even
tainted by jail time is still significant to the likes of Richard Grasso and why is that?

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I believe I answer this question on my blog a post I wrote on Nov. 10, 2013 which gives you
a hint on why the NYPD and IAB would retaliate against me and allow all the NYPD
involved in fixing me being savagely assaulted as well as protect al involved in coercing me
to drop charges.

S U N D AY, N O V E M B E R 1 0 , 2 0 1 3

The NYPD from Policing to Free Rides on Private Jets
Fixing Favors Billion + Biz
“If you want to tell the history of the NYPD read what I am filing and learn why
Ray Kelly and the head of Internal Affairs are defending police officers that
coerced me to drop charges against Dr Andrew Fagelman's savagely violent lying
receptionist Delita Hooks who like Det John Vergona can be charming and well
behaved when they need to be but both involved in criminal actions. Mr John
Vergona coerced me to drop charges, a serious crime.  The NYPD involved sealed
Delita Hooks false cross complaint as told to me by Ray Kelly and all defendants
lawyers.  
To seal Delita Hooks crime of a false criminal report in less than a year is highly
unusual but so is Ray Kelly's role. 
Do you think JP Morgan wants him on the payroll to fix crimes like the NYPD
and IAB did for Dr Fagelman who did not fire Delita Hooks and IAB fixed it for
Det John Vergona and all involved because they are too many checks in balances
which is why Delita Hooks detectives rushed to seal her false cross complaint. 
Without hacking which I can't do to subpoena power which I don't have I have
found resumes of NYPD who "consult" contractors that robbed us starting with
SAIC and a retired cop who advises on tech like 911 and HP. 
Bernie Kerik gets free rides for his family on jets to see him in jail and Ray Kelly
says flying on Air Bloomberg his favorite way to travel.  Bloomberg is putting his
nypd detectives on the payroll to make them sign a confidentiality agreement
buying them for bubkas.  
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Being police commissioner even one living in jail is still a lucrative big biz
transforming the NYPD in to a multi billionaire corporation military company
that we need an outside monitor to monitor the NYPD's dealings with contractors
and perks fixing and favors....????
The NYPD and retired cops with ambitions has transformed policing in to
something never seen with more than free rides on jets.  
The NYPD crushed OWS violating their oaths to uphold The Constitution as they
trampled all over The Constitution and Ray Kelly considers himself patriotic in
his mafia suits and White House ambitions but like his special friend Mike
Bloomberg they will not work at The White House and Ray is called KKK Ray
since Schoolcraft tapes prove the police knowingly violated People's rights and
had no problem falsely arresting them.  
No surprise the banks buy up retired NYPD.  Who better to fix for them oops
protect and serve them. 
Protect and serve is false advertising by The City of NY and the NYPD.  
The police aren't obligated to do do unless you are rich, a retired cops on a
billionaire's payroll calls in a favor or you are politically connected.
The NYPD are about big business and money run like a corrupt corruption by Ray
Kelly in his hideous high priced suits like a whore house neon sign for sale. 
No disrespect to sex workers.
G-d sees all.

http://www.scribd.com/doc/173385168/Dr-Andrew-FagelmanReceptionist-Office-Manager-Delita-Hooks-False-Criminal-Report-toNYPD
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Dr Andrew Fagelman's receptionst office manager Delita Hooks
blatantly attacked me. Look at the beginning of the YouTube and see
her friend leaning against the wall as if nothing is happening. Not
fired and the NYPD with Ray Kelly's blessings coerced me in the most
brutal and anti-Semitic way with a false arrest on the Sabbath which I
agreed to. Kelly's lawyer gave us no notes on Deilta Hooks be notified
to be arrested and she was the criminal who assaulted me and was
very confident she could file a false cross complaint and handed in
fraudlent medical as well as I never made contact with the left side of
her body let alone kicked her left leg. Pure evil a doctor's office and
the NYPD and IAB involved. Waiting for new commissioner and head
of IAB because of Kelly Campisi corruption.”

I want to ask all defendants as well as experts in criminology to watch the video of me being
assaulted and show me where is the mutual assault under oath. I want to ask them is it usual to
see Ms. Hooks criminal report against me in under a year. I want to read them Ron Kuby’s letter
and ask them is something strikes them about Mr. Kuby stating I agree to drop the charges
against my attacker if she drops the charges against me. IAB Sgt Decker told me what Det
Vergona told me that Lt. Agnes like Det Vergona would interview everybody and it never
happened. I want to ask them is it good police work for Delita Hooks Detectives to never
contact me and Det John Vergona to refuse to meet me to see the wounds to my eye since he
became abusive and acted confused about which eye I was punched in but refused to meet me. I
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believe they will all have to commit perjury or finally take responsibility but they confident this
case will be thrown out so they remain confident they are above the law.

The next section is on NYPD and the culture of misogyny. I want to ask Mr. Ray Kelly true or
false, one night after mass arrests of protestors during the Republican Convention did Mr. Kelly
and his son go to a Strip Club to celebrate?

The NYPD play judge and juries aka “Round Robin” taking a look at who you are before they
decide if they are going to do their job or not.... and the NYPD/IAB I allege are not shy about
violating our 5th amendment rights to due process as well as other constitutional rights like the
14th or 1st the right to protest and speak up.
January 4, 2013 I did a teach in for Occupy Wall Street Evolve and I was clear I was once a
supporter of the NYPD but not anymore. I did a teach in on The Knapp Commission and The
Mollen Commission and I allege this is yet another reason the NYPD and IAB giving me “The
Serpico Treatment”.

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Internal Affairs’ a History of Corruption
Please read The NY Times Article “Experts Say N.Y. Police Dept. Isn’t Policing
Itself’” by William Rushbaum, Joseph Goldstein and Al Baker, Nov. 2, 2011.
On a Federal level the NYPD are not obligated to investigate crime but Internal
Affairs is obligated to investigate police corruption and in my case I have proven
they did not. IAB let Det Verogna retire and his supervisor Lt. Burgos retire
without interviewing me on my allegations of coercion. IAB Lt. Agnes wrote case
closed my allegations unfounded and refused to return my calls. When I called to
speak to his supervisors I was told he did not have supervisors.
Ms. Nam states my complaints to IAB incessant.

Not true but even more proof

IAB did not do their jobs and Ms. Nam is not eager to share my incessant emails
because I allege they further incriminate her clients along with her withholding all
of Det Andy Dwyer’s note and Vergona’s re his phone conversations with me that
incriminate him as well as all contact with Ms. Hooks and her employer.
I would need a subpoena to get IAB records on me and all records on defendants as
well as my attacker Delita Hooks, her employer who enjoyed not firing her and
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who I allege call 1-800- NYPD PBA Fix it or in NYPD lingo called his “Rabbi” or
“Hook” to arrange fixing.
I would subpoena IAB Sgt Mary O’Donnell and her partner Sgt Kroll’s files and
audio -- I hope they taped our one and only conversation in person because I
believe O’Donnell lies to me when she carefully reads Ron Kuby’s letter not
allowing me to see it and I think she removes the word “Attacker” and puts in
Delita Hooks. I should have known if she did because we never had her name. I
only learned it later.

IAB Sgt Mary O’Donnell lies to me and tells me she will return my notes when I
call her after our meeting. IAB O’Donnell never mailed me back my notes I
accidentally handed her. She does read me Det Andy Dwyer’s name but she is
careful to not tell me I spelled his name wrong “Drier” to protect him. Det Andy
Dwyer “Delita Hooks” special detective never contacted me and acting in concert
with Delita Hooks, Dr Faglman and Det John Vergona, supervisors and IAB to
keep this case closed is what I allege. My proof. Delita Hooks isn’t arrested or
fired. Det Vergona is allowed to retire and I was never interviewed by IAB about
the fact he did coerce me. From Ray Kelly to Campisi on down everyone is
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protecting Vergona. Why? He wasn’t alone fixing this crime. The NYPD do have
a history of using coercion as a policing tool and I am guessing the “hook” for Dr
Fagelman is someone very powerful. Reminder Bill Rudin has a retired NYPD
commander on the payroll and I caught him attempting to force a young cop to fix
a ticket in front of me by Bill Rudin’s St Vincent’s Hospital Luxury Condos and
IAB did not interview and DI Delpozo never contacted me when I alerted him as
well since he was once an IAB Capt and commander where the incident occurred.

I am making the YouTube documentary on Joe Sanchez (I include Joe Sanchez
because on page 44 of my lawsuit I reference CCRB testimony and in that
testimony, I refer to Joe Sanchez and a CCRB complaint from 1982 given to him
by an honest cop like the honest cop that helped me to get Delita Hooks false cross
complaint -- the CCRB form shows IAB trying to coerce a man in to fabricating
evidence against Joe Sanchez and held him for 3 days which was illegal and in my
CCRB testimony I reference my YouTube documentary on Joe) who I dub the
Hispanic Serpico. The CCRB complaint form from 30 years ago proves IAB broke
the law and violated a man’s constitutional rights very much like Adrian
Schoolcraft and countless New Yorkers, false arrested and detained Internal Affairs
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officers kidnapped this man who filled out the CCRB complaint forcing him to
leave his car double parked as they held him for days, refusing him the right to
contact his family pressuring him to fabricate evidence against Joe Sanchez and his
partner which he refused to do and instead filed a complaint against his kidnappers.
Joe Sanchez was innocent and Internal Affaird didn’t care. They were trying to
coerce this guy to testify against Joe Sanchez to get an NYPD Whistle Blower of
the force just like IAB and the NYPD involved are sending me a message to shut
up and as Vergona said stay out of trouble and in so many words keep your head
down.

As part of my research for my YouTube on The Hispanic Serpico, I interviewed
one of the “Dirty 30” who went to Federal jail and he told me that Internal Affairs
would prep him for the questions they would ask him and once prepped, than
would turn on the tape recorder and this went on for years until in 1994 they
finally had to arrest him. Clearly if IAB did not do this and held him accountable
at age 21 when his first temporary partner took him to a drug dealers apt and had
him wait downstairs as he beat a drug dealer and took $10,000 from him this

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young cop might have avoided escalating his abuses in to a prison sentence but
instead Internal Affairs aided and abetted him until they could not.
I also contacted Serpico because of Joe Sanchez so in my opinion have a right to
reference in this motion to not dismiss because I allege that like Joe Sanchez and
Serpico, I too, have been sent a message as a whistle blower, just like Adrian
Schoolcraft who I do reference lawsuit. I can reference Serpico also because I
mention the Knapp Commission on page 36 of my lawsuit.
If we move to trial I will call retired Det Shirley Pelage (see page 34 lawsuit Eric
Sanders $15 million dollar lawsuit) who worked for Charles Campisi at One Police
Plaza. Det Pelage can confirm that “The Integrity Bureau” is where complaints
like mine are sent to die.
I have audio of my phone conversation with IAB Sgt Mary O’Donnell and the
audio proves just like Sgt Chen of the First Precinct and the evidence Ms. Nam
gives me in her motion to dismiss that Lt. Angelo Burgos opened my case for less
than 24 hours all NYPD officers including all defendants in this lawsuit and I
contacted all of them did not want to investigate the fact I was savagely assaulted
but to close this case and protect the MD’s office I allege called and asked for help
to make this go away so Dr Fagelman would not get in trouble for his role
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protecting a violent employee who is clearly a ticking bomb yet he leaves her at the
front desk. My video prevents her from harming anybody else since her allies in
the NYPD that used her false cross complaint to coerce me to drop charges sealed
her assault and false cross complaint with their coercion -- a crime yet this alluded
all supervisors and all Internal Affairs officers. Lt. Fikru said “The video speaks
for itself” but he was investigating Mary O’Donnell and not anything else. How
convenient.
My CCRB testimony on their website and on Scribd.com has me demanding
CCRB take back my complaints against all involved as do a series of emails to
Graham Daw. I had contacted CCRB and IAB immediately. I can subpoena all
CCRB that ruled on moving my case to IAB because they believed a crime was
committed...something serious occurred and IAB must investigate it and instead
IAB farmed it out to Lt. Agnes who like all involved defendants IAB Sgt Kroll and
O’Donnell refused to contact me, return calls and meet with me. Sgt Kroll
watched the video and admitted I have I believe 3 years to have Delita Hooks
arrested for assault. IAB would have to contact the First Precinct to arrest her
which they have not done. I was turned away from the 01 Precinct after Ms. Nam
told me I had no case and there was no assault I walked over and reported assault
in the 2nd Degree and was turned away stating the case is open. The Det Squad
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refuses to allow me to upgrade assault charges and they won’t talk to me because I
am suing. I contacted Mr. Kelly and Mr. Campisi via their lawyer Ms. Nam asking
my case to be moved to NYPD Chief of Detectives Pulaski at 1 Police Plaza and
Ms. Nam has given me zero response but when she wanted the badge numbers of
the officers that told me the case was open I gave it to her because I have nothing
to hide but the evidence she showed me incriminates her clients including Internal
Affairs. It does not take rocket science to know from the video, false cross
complaint, photos and medical reports, the audio of me being turned away by
NYPD PO Migori and Sgt Chen who won’t come down and pick up the phone to
talk to me to explain why I can’t report a false cross complaint -- with PO Migori
telling me incorrectly because I am not a detective or from the DA -- that is on
audio as well as the audio of IAB Sgt Mary O’Donnell with her in my opinion
stone walling me “Blue Wall of Corruption” and I imply her unwillingness to look
at the email to Ron Kuby agreeing with me agreeing to drop the charges if my
attacker drops “the alleged” charges --- Ron left out alleged. She didn’t want to
hear it but Ron’s letter I had never seen it -- his letter was enough to single to IAB I
was coerced. I drop the charges against my ATTACKER if my ATTACKER drops
the charges against me is clearly Ron obeying my wish to send up a flare so to
speak I was coerced. I perceive Mary O’Donnell in my opinion to be a corrupt cop
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along with them all protecting Det John Vergona and all the IAB defendants
including Charles Campisi a chief agree they want Det John Vergona’s legal
representation including with their own. If that isn’t an indictment I don’t know
what is. I do know Internal Affairs is obligated to investigate crime and Charles
Campisi is the letter I will read in front of a Commission in to NYPD and IAB
corruption I will get I hope sooner than later under Mayor De Blasio when I testify.
I have blog calling for New Commission and that is my goal using Ms. Nam’s
motion to dismiss, her instructions to serve Det John Vergona at One Police Plaza
and the defendants as a group defending Det John Vergona just like all the women
in the video not knowing their is a video all defending Delita Hooks.

If I can cross examine all of the defendants and IAB listed in my lawsuit as well as
Lt. Fikru and IAB top brass along with IAB’s Delita Hooks Capt Wright under oath
I can prove my case. I would play the video and ask all defendants where is the
mutual assault. I would read Delita Hooks false cross complaint and ask
defendants show me where I pushed Delita Hooks. The video shows her as the
aggressor and me backing away. The video shows her hitting me first with her
iphone and hand after threatening me with bodily harm and than throwing her
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shoes, one at me. The video is shaking and goes black shutting off. Why? From
violent impact to my body, a running punch to my eye that makes a hole in my
retina. I would ask all defendants how was the Delita Hooks “false cross
complaint” made over in to a “mutual assault”. The NYPD fabricated evidence
using a false cross complaint and making it over in to mutual assault with IAB’s
blessing to protect the NYPD involved in fixing this violent crime and committing
the crime of coercion. To coerce me they fabricated evidence making over Delita
Hooks false cross complaint also a crime and I allege witness tampering including
possible on line actions on YouTube such as removing the YouTube “Det John
Vergona, Delita Hooks Assaulted me False Cross Complaint No Arrest”. It was
illegally removed and I was falsely labeled for bullying and harassment when yet
again I was the victim. Google YouTube apologized. The video speaks for itself as
IAB Lt Fikru said. A woman IAB Sgt at the commander center told me she
refused to believe the NYPD had any role in aggravated harassment on YouTube.

I speak to Sgt Decker of Internal Affairs and he tells me my case has been sent to
Lt Agnes of the Integrity Bureau. He gives me Lt Agnes number. He explains that
Det Vergona is being sent to the equivalent of the Principle’s offices if this was
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high school. Sgt Decker tells me Lt. Agnes will interview everyone which is what
Det John Vergona told me including email in the evidence section of this motion
and it never happened. Lt Agnes refuses to return my messages. The 2nd message
is a warning I will go to the Feds. When The Public Advocates Office calls IAB
on my behalf they are told the case is open but in reality the case is closed and Lt
Agnes has stated without interviewing me my allegations are unfounded.
Det Vergona is allowed to retire instead of being arrested for coercion.
IAB never took the allegations of coercion seriously even with CCRB forwarding
my complaints against Det Vergona,his co-workers and supervisors seriously
because as The NY Times article underscores IAB can’t police the police and Ray
Kelly has expanded their budget in the mega millions but in the article and my
direct experience proves they are just pushing paper not investigating crime and I
allege IAB is protecting the NYPD Brand.
IAB states my case is open but that is because every complaint I make they link to
my first complaint against Det John Vergona made on the weekend after I was
coerced again proving Ms Nam implying I waited to complain after the fact is
untrue.

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Internal Affairs has a history of protecting corruption than arresting corrupt cops
and in my case Det Vergona was allowed to retired with IAB mimicking the sloppy
and corrupt “investigation” on behalf of Delita Hooks and in IAB and the Integrity
Bureau’s case investigating Det John Vergona he is given the same treatment as
Delita Hooks which I call “creative policing” fixing and favors so they both can
walk free as I their victim continue to suffer. IAB is obligated to investigate
corruption and I believe I have proven without subpoena power at this time fully
my Constitutional Rights were violated as Det John Vergona is enjoying his
retirement and pension instead of being prosecuted for coercion and Mr. Kelly the
commissioner of the NYPD and Mr. Campisi, the Chief of IAB insist on their
lawyer defending Det John Vergona who is guilty of coercing me. I never dropped
those charges willingly. I was coerced which is a serious crime and thanks to Ms
Nam’s submission of evidence and her letters on behalf of her clients instructing
me to serve Det John Vergona at One Police Plaza and Mr. Kelly and Mr Campisi
want Mr Vergona defended courtesy of the tax payers and their lawyer is truly an
indictment of Mr. Kelly and Internal Affairs.

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IAB Sgt Mary O’Donnell on the audio recorded is calling me because The
Commission to Combat Police Corruption has forwarded her my email (perhaps an
email I shared with IAB that IAB via Ms Nam complains is incessant yet The
Commission wants IAB to investigate). You can hear in my opinion IAB Sgt Mary
O’Donnell does not want to investigate but says case closed.
Ms. Nam in my opinion puts me down the victim of a serious violent crime at a
doctor’s office and than of her clients the NYPD and IAB when I state I don’t want
to talk to her any more. Why do I not want to talk to IAB Mary O’Donnell?
Because I am tired of banging my head against the Blue Wall of Corruption that
she an IAB officer is clearly part of in my opinion as the audio proves in my
opinion. The audio like Lt. Burgos’s investigation and Lt. Agnes and all IAB
involved to date in my opinion proves corrupt dealings at all phases an levels in the
NYPD and IAB regarding me being savagely assaulted and coercion etc. The
NYPD does not have to investigate crime but IAB has to and the audio is an
example of IAB’s unwillingness to investigate crime and the NYPD are not
allowed to break the law coercing me to drop charges. The audio of PO Migori
turning me away and calling Sgt Chen who IAB Sgt Mary O’Donnell tells me in
this audio she is too investigate is proof the NYPD violate my Constitutional
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Rights turning me preventing me from reporting a crime which they are not
allowed to do. They don’t have to investigate a crime but the NYPD are not
allowed to turn People away from reporting a crime.
If we move to trial I can prove IAB’s history of Corruption protecting the NYPD
Brand and I will call Serpico, the Schoolcraft Family who the Village Voice author
Grayham Rayman wrote before getting laid off that NYPD may have violated
Schoolcraft’s sister who lives in Texas and Dad’s rights doing criminal
investigations in to them. If so IAB should have taken action. I spoke to Adrian’s
father Larry and he made it clear that IAB set Adrian up exposing him to his
supervisors at the precinct. Please see excerpt below and I allege similar treatment
as I was clearly a victim of a violent crime at a medical office aftera $430 medical
procedure. To get more evidence I need access to my IAB file.

NYPD Internal Affairs Went Digging For
Dirt On Whistleblower Cop Adrian
Schoolcraft's Father and Sister
By Graham Rayman Fri., Sep. 27 2013 at 6:00 AM

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“In the course of its investigation of whistleblower cop Adrian Schoolcraft,
the NYPD's Internal Affairs Bureau not only ran his father's name through
criminal databases, but his sister's name as well.
This revelatory tidbit emerged in federal court Tuesday during a hearing on
Schoolcraft's lawsuit before U.S. District Judge Robert Sweet. It raises the
question of whether it was proper for the NYPD to run the names of people
through criminal databases when those people are merely potential
witnesses and not under criminal investigation.
In 2010, the NYPD Internal Affairs Bureau was conducting an investigation
of Schoolcraft. It was not a criminal investigation. It was merely an
administrative investigation into why Schoolcraft went home early on Oct.
31, 2009. When Schoolcraft refused to report to work, after police dragged
him out of his home and forced him into the Jamaica Hospital psychiatric
ward, Internal Affairs investigated him for that, too. In all, the bureau filed
two dozens administrative charges against Schoolcraft.
In the course of that investigation, Internal Affairs ran Schoolcraft's name
in 2010 through the state criminal records database and the FBI's National
Crime Information Center's database, records show. Internal Affairs also
ran Schoolcraft's father Larry's name through the databases too. Larry was
clearly not under either an administrative or criminal investigation when
his name was run.
Internal Affairs also ran the name of Schoolcraft's sister, who lives in Texas
and has had no contact with Adrian or Larry on this story. Not only was the
sister not suspected of criminal conduct, she was not even remotely
involved in any of the events surrounding the case. She had not idea what
was going on. And yet, Internal Affairs thought it was okay to run her name
through the system. None of the three Schoolcrafts had any priors.”

The NYPD Tapes
NYPD Criminal History Search on Adrian Schoolcraft, Father and Sister May Have
Violated State Rules, Records Show

By Graham Rayman Wed., Oct. 23 2013 at 7:30 AM

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“The Voice has obtained the criminal records search agreement between the
NYPD and the state Department of Criminal Justice Services, which
oversees the database.
Under that agreement, there are a series of "authorized inquiries," which
are specified in appendix a of the agreement, which was obtained through
the Freedom of Information Law.
Searches are allowed for fingerprint submissions, during a criminal
investigations, for a jail or prison inquiry, for investigations related to
warrants and wanted persons, for prosective employment in law
enforcements agencies, and for people who work as contractors for law
enforcement agencies.
In short, it doesn't look like the searches of the Schoolcrafts' name fall
under any of those approved inquiries. The question now is whether
anyone's going to look into this possible misuse of one of the more sensitive
databases that exists.”

Dirty Little Secrets in NYPD's
Internal Affairs Bureau
Witch hunts, injustice, and just plain incompetence in the secretive policedepartment-within-a-department

By Graham Rayman Wednesday, Dec 1 2010

Page 52 of my lawsuit Det Harold Hernandez resigns when he catches his co-workers down
grading a serial rapist. The NYPD are so corrupt and IAB as well that an honest officer’s best
option is retirement rather than face retaliation. Det Hernandez caught the NYPD fixing stats like
Det Vergona did to me so my assault did not appear on the 01 Stat report as the front page of my

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lawsuit says “The NYPD Stats are like a Las Vegas Casino the fix is in.” They do this with IAB’s
blessings unless IAB is forced to finally take action.

(Front page of my lawsuit NYPD fix stats like a Las Vegas Casino )“Sergeant says NYPD
Manipulating Crime States WABC Eyewitness News “In an exclusive interview, a 19 year veteran
of the NYPD describes widespread manipulation of crime reports at the 100th Precinct in Queens.
The sergeant says when he blue the whistle on the routine fudging of crimes, the department
retaliated and transferred him to Bronx Central. Sgt Robert Borelli...

Page 27 NYPD Ramos criminal IAB scandals including investigator Capt. Wright I call
the male Delita Hooks and Schoolcraft referenced in my lawsuit.

Economic Racism and the NYPD’s Creative Policing
Economic Racism is a term I made up and to sum it up “he” or “she” who is rich and or
connected wins when it comes to the NYPD and policing. Please see “motives for the NYPD
and IAB to retaliate against me” section to see direct examples and in my case where I allege that
Dr Fagelman made calls and my private investigator told me Dr Fagelman refused to comment
on whether he spoke to the police which sounds to me in my opinion like he is hiding something
-- in my case as well the rich man and his violent employee who he paid for her time punching,
kicking me repeatedly violating my rights wins with the NYPD continuing to violating my rights
I allege fixing for the rich MD versus the artist just like the NYPD did Michael Rawson than
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Manager of The Mercer along with Henry Buhl with his illegal planers, Rawson would call the
NYPD at the First Precinct and get them to cleanse the sidewalk of vendors (page 4 of lawsuit)
and ignore The Mercer’s illegal parking scam run in their “loading and unloading” zone.

I caught a retired NYPD commander who all NYPD refuse to give me his name attempting to fix
a ticket for a Bill Rudin flunkie as I protested for a Trauma Level 1 Hospital with a Rape Crisis
Center and AIDS care outside Bill Rudin’s sale office where St. Vincent’s was. When I spoke to
Det Delpozo, a co-worker of Det Vergona’s I mentioned this and that I was saddened DI Delpozo
rumored to be on the fast track for Police Commissioner did not return my calls concerning a
retired NYPD commander attempting to fix a ticket with one of his police officers. I asked the
police office who was that man and the young police officer lied to me and said that man was an
MD that treated him at St. Vincent’s. Truth I learned from a community affairs Det. from One
Police Plaza, the man is a retired NYPD commander but I still do not have his name to date.

“What you Didn't know about NYPD's Stop & Frisk program ! “
http://youtu.be/rfJHx0Gj6ys This 45 minute YouTube is part of a powerful and
compelling YouTube series by “NewYorkResistance”, an African American activist
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that like me uses video to peaceful expose and protest government abuses in his
case mostly all NYPD. 25 minutes in to this YouTube you can see what appear
to be older white People interviewed by ABC news who have been savagely
assaulted and repeatedly prevented from reporting assault. NYResistance
explains in so many ways how poor African Americans and Latinos are routinely
falsely ticketed documenting NYPD abuse and with ABC news montages
explaining how the NYPD are forcing poor people out and or making them to live
in fear of the NYPD and that was what Det John Vergona tried to make me
feel...to be afraid of even more abuses. He gave me specific instructions
including not to contact him after coercing me to drop charges and we only did
because I was so fearful of Det Vergona who was verbally violent, screaming lies
at me and threatening me with arrest when I was clearly the victim.

NYC Resistance shows us another form of economic racism driving poor Black
and Latinos out by false ticketing them as they try to simply conduct their lives
and supports these allegations with his own video clips and many from ABC
news.

You can hear Adrian Schoolcraft’s secretly recorded audios of his own
commander turning away People from reporting crimes and even a man who he
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said his car getting stolen was karma.

These People are poor and middle class

but the NYPD don’t turn away the rich and connected.

When I was savagely attacked at Dr Fagelman’s I was wearing a protest sign which I believe put
me in the OWS classification which is the largest example of false arrests, creative policing and
economic racism including on behalf of banks like JP Morgan / * JPMorgan Chase

donated “...an unprecedented $4.6 million to the New York City Police
Foundation. The gift was the largest in the history of the foundation
and will enable the New York City Police Department to strengthen
security in the Big Apple. The money will pay for 1,000 new patrol car
laptops, as well as security monitoring software in the NYPD's main
data center.” *from the JP Morgan website.

See Norman Siegel’s letter on behalf of OWS and me in the retaliation section page number

My private investigator told me Dr Fagelman lives in Battery Park City. I believe that makes
him a neighbor of commissioner Ray Kelly. Why would that matter? Does it? I don’t know.
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The NYPD under Mike Bloomberg and Ray Kelly run the communities like the one Dr
Fagelman lives and works in as an gated community with invisible gates and One Police Plaza
which IAB offices, The First Precinct as well as IAB commander center are all near Dr
Fagelman’s offices and his home so I am suggesting he was given “favor-tism” and it gave all
parties sadistic pleasure that I was savagely punched in the eye as I help my bags and Iphone -are numbs because I have given them all “a black eye” via my blog. I held Ray Kelly in esteem
but he accepted free rides on “Air Bloomberg” , mayor Bloomberg’s private Jet for both him and
his spouse when he is not allowed to accept a cup of coffee. So yes I am alleging that Dr
Fagelman made calls either directly to the NYPD for help the way Michael Rawson formerly of
The Mercer Hotel would call the 01 to get the Veteran Vendors and artists swept off the street. I
am also alleging the possibility that he called someone like a “Bill Rudin” who has a retired
NYPD commander on his payroll whom I witnessed tried to fix a ticket for a Rudin Flunkie.

I keep calling for a criminal investigation in to 911 Tech Corruption and HP is one of our
Countries top 20 military contractors. This would be a huge problem for Ray Kelly is he was
hired as homeleand security but because of Stop and Frisk and his response after the Honorable
Judge Shira Scheindlin -- and by the way Stop and Frisk Abuses another form of economic
racism.

Ray Kelly’s popularity crashed like a stock during the Great Depression.

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(SAIC referenced page 5 lawsuit) Ditto for SAIC (please see NYPD IAB Retaliation Section for
more on SAIC and retired NYPD consultants page 90) who I believe I helped to get banned from
any NY State and NY Gov contracts with my “incessant” blog posts and YouTubes. I am
alleging the NYPD has a long standing relationship with SAIC and even considered them for
what people call “spy ware” the Domain System. Oakland has hired SAIC to do their video
system “to keep People “safe”” but based on my experience why video prove that can’t be
challenged along with her false cross complaint a serious crime I have written from my blog
many times that the 35 Million Dollar Domain system will need a special unit in IAB to destroy
video that implicates corrupt NYPD and an example is the false prosecution of Michael Premo
(yet another example of economic racism) where the DA and the NYPD claimed The Taru police
office was a on a secret mission and they did not want to provide the video that would prove this
was a false arrest, trumped up charges just like Det Vergona yelling at me I am going to arrest
you if you don’t drop the charges. Well the Judge made the NYPD Taru video appear. He is
accused of testilying and Democracy Now turned over the video since they were standing next to
Taru and Michael Premo was acquitted.

I think it is a fair question to ask if commissioner Ray Kelly accepts free rides while employed
by mayor Bloomberg how many free rides was Ray Kelly planning on after he left his job from
top contractors I alleged grossly over billed/ robbed tax payer money or power brokers
associated with them including Mike Bloomberg.
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NYPD economic racist policing on behalf of Republicans and Wall Street see excerpt from Mr.
Levitt’s piece. (Mr Levitt referenced lawsuit page 36)
An NYPD Inspector General? Leonard Levitt  June 18, 2012
"Kelly refused to allow CCRB investigators to question supervisors of the mass arrests
at the 2004 Republican National Convention. Mayor Michael Bloomberg said or did
nothing to force him to comply. [See NYPD Confidential, Sept 16, 2005.]

Kelly also sidelined the other city agency charted with monitoring the police department:
the Mayor's Commission to Combat Corruption.

In 2005, the commission's chairman, Mark Pomerantz, requested departmental crime
statistics to investigate claims of systemic crime-downgrading. Again, Kelly refused to
comply. Again, Bloomberg said and did nothing. Pomerantz resigned in protest. [See
NYPD ConfidentialApril 22, 2005.]

Despite beefing up Internal Affairs, final decisions are made not by its longtime chief,
Charles Campisi, but by Kelly." (page 35 of lawsuit IAB needs a top to bottom review
Det Pelage lawsuit)

The Bloomberg Kelly policy was to sell the lie crime is down, The NYPD fix crime like a
Las Vegas Casino and my case is just one example. If we move to trial I want t call the
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NYPD criminal like Ramos, NYPD hero whistle blowers like Adrian Schoolcraft who’s
audio recording have examples like what was done to me, (page 42 Prof Eterno
referenced) Prof John Eterno a retired NYPD Capt. Phd in criminology who agrees I
was assaulted. He is not a lawyer but he says the video is proof the NYPD fabricated
evidence because I did not assault someone and they should not have turned me away
when I tried to report a crime like Delita Hooks false cross complaint. Any honest NYPD
would allow me to report crime or upgrade Delita Hooks attack to 2nd degree assault
and investigate.

Economic Racism is a two sided coin == on one tickets and summons for the poor and
middle classes to drive them out, Stop and Frisk to make People to afraid to come
forward and report crime all part of forcing People out of their neighborhoods as much
as crime being fearful to walk to the Deli for fear of a false arrest and the NYPD made
so many including to make OWS protestors fearful and Cy Vance the Manhattan DA
was in on it. I can prove all this and the IAB and NYPD’s roles in what was done to me
in a trial with everyone under oath. The other side of the coin is by selling crime is down
when it isn’t it is great for NYC’s economy, real estate development and big contractors
eager to do biz here except I expose some of them I allege steal take payer $s like and
HP SAIC and they like Mr. Bloomberg hire retired NYPD.

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NYPD are Not allowed to Turn People away From Reporting Crimes
The NYPD do not have to investigate crime but they do have to allow People to walk in to the
precinct and they repeatedly prevented me from reporting crimes.
Ms. Nam challenges my allegations of anti-Semitism and misogyny and I believe Det Vergona
was abusive and bias against me as well as verbally violent but the issue but that the 9th Precinct
prevented me from reporting my allegations of a hate crime by Det John Vergona. They told me
IAB would investigate and too date IAB has never contacted me re: the assault, coercion and
alleged hate crime by Det John Vergona.
By coercing me to drop charges the NYPD also was preventing me from reporting crime
violating my 5th amendment rights as well as my 14th amendment rights.
I have video footage from ABC News, a report by Jim Hoffer that has People like me reporting
the NYPD repeatedly tried preventing them from reporting assault.

Please see the video segment referenced in the Evidence Section of Jim Hoffer’s special report
ABC News on the NYPD turning away victims of assault not allowing them to report the crimes.

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The NYPD are not allowed to do this and they did this repeatedly with me except the NYPD
allowed me to report the assault but coerced me to drop it which is ultimately the same and than
the commanders of the Precinct get to report that crime is down as does mayor Bloomberg and
commissioner Ray Kelly. By preventing me from filing complaints and also coercing my to
drop charges they violated my 14th Amendment rights and 5th amendment pertaining to
coercion. Coercion is a crime, not a policing tool.
1)

coercing me to drop charges the NYPD prevented me from reporting crime

2) NYPD PO Migori and Sgt Chen turn me away from reporting Delita Hooks filed a false cross
complaint caught on video. PO Migori says only detectives or the DA can report false cross
complaint which is not true
3)

Det Hernandez from the Hate Crimes Unit, One Police Plaza said I could report Det John
Vergona’s allege hate crimes including anti-Semitism Sabbath arrest and I was turned away
from the 9th Precinct told IAB would investigate. IAB has never investigated this allegations
and misogyny again like coercion allegations I was never interviewed.

4)

Ms Nam told me I have no case because there was no assault since I dropped charges so I
went in to report Assault 2nd degree since the NYPD coerced me to drop charges 3rd degree
almost 1 year later which is my legal right and I must go to the First Precinct only because it
occurred at Dr Fagelman’s 155 Spring and again I was turned away.

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The NYPD are not allowed to turn me away and repeatedly violated my rights to speak up and
report a crime part of my First Amendment rights and to report crime pat of my Fourteenth
Amendment rights.

NYPD Culture of Misogyny and The First Precinct
I believe Det John Vergona was misogynist and anti-Semitic. Ms. Nam says not true.
I make it clear I have a right 1st amendment and 14th to walk in to a precinct and report alleged
hate crime but the NYPD turned me away violating me rights silencing me and treating me like I
am not an American Citizen.
The NYPD have a culture of misogyny hiring strippers for parties after work when they aren’t
having post-work gatherings at bars to decompress which I find disturbing considering the
number of drunk driving NYPD arrested including for killing people “accidentally”. I donated
blood in a Camper for the NY Blood Center in front of the First Precinct and an officer upon
entering stared at my breasts as if I did not have ears and stated that reminds me I have to get a
stripper for the party.
I believe Det Vergona was prejudicial against me because of my Mae West humor and also
because in my file an old case where I had an honorable NYPD det who helped me deal with a
stalker duo one who gay bashed me from his blog and his sometimes boss was sent an email to
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out me for writing erotica under a pen name. The NYPD did not sexual shame me or harass me
but spoke to the parties involved and the harassment stopped. The First Precinct commander
pre- DI Winski was DI Bologna who is the poster boy for misogyny pepper spraying peaceful
women in the eyes as they stood behind barriers.

I believe because of his misogyny he refused

to meet me, had his partner but me on the phone for a long time and than asked are you still
there? It is why he was abusive to me and emotionally beat me up and like Delita Hooks tried to
make me in to the “bad guy” / criminal. Det Vergona said to me I don’t work for you I work for
the Police Dept. Yes I allege the misogynist police department where DI Ed Winski’s police
office mid-town south is a YouTube star in a viral video instructing a vendor “blow me” and the
NYPD officer is a woman -- my point is even the women of the NYPD are players in misogyny.
The NYPD have a history of preying on sex workers women and I have been told tranny’s and
mostly but not all NYPD have refused to investigate rape allegations by women sex workers. I
felt Det Vergona and his partner who name I still don’t know treated me like an annoying ex
girlfriend or “whore” but not as an American with equal rights.
Bottom line Det Sanchez of the Hate Crimes Unit agreed I had a right to report hate crimes and
yet again I was turned away.

Det Vergona could not have cared less that I was threatened, blamed for a savage attack where I
was the victim -- there was nothing “even steven” and I was called a c/nt. It was as if he agreed
and had joined the Delita Hooks gang bang attack of me. I sent the press who report on NYPD
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news and who get their tips and their press passes -- the NYC media gets press passes from the
NYPD which is wrong and a conflict of interest but I sent out the front page of his opposition to
dismiss with the word “c/nt” on it and the cyber stalking/bullying /alleged witness tampering
which has been silent since I filed this lawsuit started up on two YouTubes exposing Police
abuses including an IAB YouTube re Vergona and Deita Hooks and I was called C/Nt again and
told to shut up. The cyber bullying continued on thru my Father’s death and burial and after until
I wrote an email to NYPD news reporters suggesting one of them shared this with a corrupt cop
and FYI, I contacted the FBI. Than the c/nt calling and orders to shut up and get a life stopped. I
allege the removal of videos on behalf of Delita Hooks and Det Vergona which YouTube restored
where the NYPD or agents acting on behalf of the NYPD and Det Vergona’s non-response to me
being called a fight picking c/nt is as telling as him yelling at me he didn’t care if I had two black
eyes and to stop babbling and his verbal violence and unwillingness to see my eye, neck and
defensive wounds is emblematic of his misogyny and bias against me as well as his goal to fix
this violent crime for Dr Fagelman who did not fire Delita Hooks which would be hard to explain
if she is arrested for attacking a medical patient. When it comes to stripper parties and fixing
crimes I allege the NYPD is a boy’s club and considering IAB’s role I allege IAB too since
Delita Hooks isn’t arrested and neither is Det Vergona. I filed a complaint against IAB stating
IAB acts like they get viagra from Dr Fagelman. Dr Fagelman advertises viagra from his
website.

Failure to Supervise
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This entire motion to not dismiss gives many examples and every defendant who is not a
detective is in a supervisor position from Mr. Kelly to Chief Campisi, DI Ed Winski, Lt. Burgos,
Lt Agnes -- it should be noted I called to speak to his supervisors since he failed to return my
calls and interview me along with everyone as Sgt Decker told me would and Det Vergona told
me and emailed would and both did not. I was told Lt Anges has no supervisor. Lt Burgos
opened my case and is a season veteran and he did not notice anything that was wrong.
Commissioner Kelly was law education from a prestigious university insists on paying for Det
John Vergona who never told me what I had actually done except I assaulted her and it was even
steven and said not true. Det Vergona who said “her” detectives don’t have to talk to me because
he talked to me and he didn’t have to go to the office because they did. That is not in Ms. Nam’s
notes from Mr. Vergona. Dr Eterno, a prof of Criminology, head of the dept at Molloy
university called it sloppy police work and after viewing the video stated what most everyone
has said to me this is crazy.
I also show via this opposition to dismiss evidence that commissioner Kelly and his top brass
have a culture of failing to supervising and training their employees properly and would
reference the many Village Voice articles by Graham Rayman on police corruption and as Mr.
Levitt points out in his book NYPD Confidential the NYPD loses so much good talent and one
example is Det Harold Hernandez who resigned when he caught his co-workers down grading a
serial rapists rapes to robbery. Who alerted him? The serial rapists. Det Harold Hernandez was
a Veteran who’s only option facing what I allege is the Blue Wall of Corruption was to retire so I
proof my allegations and underscore my point with how many examples including how the
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NYPD continues to punish the whistle blowers including their own like the subject of my
YouTube documentary mentioned in my lawsuit Joe Sanchez, Serpico to Adrian Schoolcraft and
others as well as me not an NYPD officer but I blew the whistle on the NYPD and IAB. The
NYPD failed to supervise and train all the NYPD and IAB involved in my case as none came
forward to speak up for me and IAB did not take action. The NYPD puts up signs in the precinct
and alerts the NYPD to blow the whistle on police corruption but has failed to supervise and
train IAB as well as NYPD supervisors how to implement that which is why no one came
forward on my behalf but we have audio of IAB Sgt. Mary O’Donnell stating case closed. We
have Ms Nam’s client, as presented in her motion to dismiss , with notes he (Lt. Burgos) opened
the case Feb 7 and closed it 22 hours later and my letter to DI Ed Winski on Nov 20, left him a
voice mail reporting the false cross complaint the Sunday (Nov 18) before on his direct vm in
the precinct somehow I got through to that 1 time and Oct 16, I walked in to the precinct and
handed in Lt Petroino’s memorial pin honoring his death in the line of duty killed abroad in 1909
in the line of duty with badge number 285 demanding DI Ed Winski be there when I was to be
false arrested.
DI Ed Winski has been given awards as well by the police department and yet he did not contact
me or go to IAB despite me turning in this somewhat rare pin which can’t be bought.
“Bad Cop Cheats the Ax” July 1, 2013 NY Post Jamie Schram ( Mr. Schram exposing NYPD
tale of two cities Commissioner Kahn front page of my lawsuit and page 51) “...top cop Ray
Kelly let her keep her job. NYPD Officer falsely accused her the police her boyfriend
kidnapped her and raped her. She was not fired and allowed to keep her job despite NYPD Chief
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of Personnel Rafael Pineiro calling for her termination. I want to point out Mr. Kelly insists on
his lawyer defending Det Vergona.

Lt Angelo Burgos and Sgt Chen failed to supervise the First Precinct Det Squad. I can even show
you phone records Oct 16 where I get disconnected it was my iphone and I call back and the
woman detective that answered the phone for Det Vergona is so rude to me she hangs up and me
and than Det Vergona and I speak and he tells me I am the rude one and he doesn’t work for me
but for the police dept.

After Sgt Chen told me to come in (Nov 20, 2012) and spent 10 minutes on the phone with me,
he should have come downstairs and met me with to explain why now I was being turned away
and you can hear audio that he refuses to come down and refuses to get on the phone with me
when I call him from downstairs and after I report him to IAB and call CCRB and DI Ed Winski
all on audio.

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See evidence section page 30 in the back of this motion, Lt. Burgos refuses to answer my emails
giving me badge numbers. I sent hard copies of this email to Commish Kelly, Chief Esposito,
Chief Campisi, and DI Winski no response.

page 29 of Evidence Section on back of this motion: evidence 29 Letter to DI Ed Winski
handed in after Sgt Chen refuses to come down to speak with me.

I call Internal Affairs and

give him case number. The letter clearly indicates Ms Nam’s excuse for Sgt Chen via our phone
conversation is not what I was told as can be heard in the audio and read in this letter. Date Nov
20, 2012 12:15

I made a complaint against the Det Squad to IAB stating that Det Squad has to be broken up
because there is something very wrong.
I made a series of Complaints with IAB against IAB also in my opinion and a disgrace. Lt
Agnes his role as a supervisor who won’t return my calls and did not take seriously I would go to
the Feds.

CONCLUSION
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For the foregoing reasons, plaintiff respectfully submits that the court should deny
defendants’ motion to dismiss pursuant to Fed. R. Civ. P. 12(b)(6) in its entirety.

I am an artist with no legal education and I was not able to find the legal support I needed from
start to finish. I gave this my best pro se effort . I ask you to deny the defendants’ motion to
dismiss it it’s entirety. If you cannot, I request that take any part of my case presented and move
my case forward to mediation and or preferably a trial.
The NYPD and IAB violated my First Amendment Rights with the goal to shut me up and
silence me by retaliating against me. They violated my 14th amendment rights by treating me
with bias.

The NYPD met my attacker meeting with her and not me. Both sets of detectives

made contact with her not me. The NYPD and IAB treated me with extreme bias violating my
14th amendment rights as well repeatedly preventing me from reporting crimes as violating my
right to my First Amendment right to have a voice and report a crime as well as forcing me
against my will to drop charges violating my 5th amendment rights as pertaining to coercion and
as well as my 14th amendment right a decision made under duress is not binding.

The NYPD and IAB never meet with me to discuss me being the savage victim of an attack at a
medical office but met with my attacker and treated me like the criminal when I clearly was the
victim.

Delita Hooks yelled at me told I had no rights and the NYPD agreed violating a series
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of my Constitutional rights.

Dr. Andrew Fagelman’s receptionist office manager filed a false

criminal report which I included a copy of in this response, the very last page in the back of the
evidence section in this motion. I referenced her false cross complaint page 20 one example in
my lawsuit and the criminal report is just a short summary filed at One Police Plaza. A false
cross complaint is a serious crime and in it she blatantly lies stating I attacked her and pushed her
to the ground and than kicked her to her left leg which never happened. Not true. The NYPD
violated my 5th amendment preventing me from due process by not going to the DA and I
include an email in the evidence section I tried contacting the DA.
Delita Hooks has yet to be arrested for assault and false cross complaint. I believe she may be
involved in possible witness tampering and aggravated harassment with others.

Even in the

letter ghost written by someone perhaps “the misogynist lawyer” who called me a c/nt and
vowed to turn the tables on me if I took civil action against the receptionist --- that letter to the
NYPD vows to take action against me if I file assault charges again against her echoing the
“misogynist lawyers” threat to take action against me if I take action against my attacker.

It appears that I was not equal but the NYPD and Internal Affairs decided when it came to me
being attacked all was equal when in fact it was not and that the 14th amendment did not apply
to me.

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Det. John Vergona repeatedly abused me and humiliated me and treated me like a criminal when
I was clearly the victim with proof that can’t be denied. Det John Vergona did not use the term
“mutual assault” but “even steven” and in doing so he fabricated evidence and slandered me
acting as an agent of the NYPD with the goal to coerce me to drop charges which is also a
serious crime.

Detective John Vergona and Delita Hooks (who in my opinion appear to be

acting in concert) have not been arrested and, in my opinion, they should have been.
Det John Vergona stated he did not work for me; he works for the New York Police Dept. An
honest cop told me he was shocked because the NYPD has so many checks and balances these
days so he couldn’t understand how this could happen.

The NYPD are not obligated to investigate crime, but they took an oath to uphold The
Constitution not repeatedly violate The Constitution.
Det John Vergona did not have the right to verbally assault yelling at me, Drop the charges or I
will arrest you! He only added I will arrest both of you as an after thought and Ms. Nam is
careful to not show us any evidence that the NYPD either set of detectives contacted Delita
Hooks to turn herself in.

Was Delita Hooks sitting at the First Precinct Saturday night waiting

for me which I highly doubt since I am alleging the NYPD saw the evidence she threatened me,
repeatedly attacked me, saw the severity of the my injuries including Internal Affairs with the
latest news of even more damage growing scar tissue with the high likely hood my retina will
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detach again.

I allege the Saturday arrest was exclusively targeting me as part of Det Vergona’s

bias, prejudices and violation of my 1, 5 and 14th amendment rights.

The NYPD has a duty to not fabricate evidence and when Detective John Vergona knowingly
used Delita Hooks’ false cross complaint which says I attacked her and pushed her to the ground
and kicked, her which the YouTube with 17,650 view proves was not true! Det John Vergona
said it was even steven and her false criminal report and the YouTube as well as photos before
and after, medical reports proves Det John Vergona fabricated evidence stating I assaulted her. I
made it clear I did not assault her. I have never assaulted anyone. I never had a detention in high
school. I made it clear to Det John in our conversation Oct 16 of which there appears to be no
DD5, I would sue Det Vergona, and the Judge, he or she would take one look at the video
evidence and toss out his false arrest. I agreed to Det John Vergona’s immediate demand that I
turn myself in which was a devastating violation.
Det John Vergona is obligated to treat me without bias but he did with bias and even verbally
assaulted me over the phone. He never once asked me are you okay just like Delita Hooks coworkers in medical outfits who walked by me like I was trash and that was how Det. John
Vergona repeatedly treated me except the morning conversation on the bus to see my Dad. He
agreed I had a right to defend myself which I did after the third strike to my body. The only
other time he showed me an ounce of humanity as if he is a split personality is the email I
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enclose where he states he understands my frustration. How could he understand my frustration
when he previously had yelled at me I don’t care if you have two black eyes and stop babbling. I
almost wondered if someone else wrote it but in the email he says I will go interview everybody
and he never did.

When I agreed to be false arrested twice Oct. 16 and to delay Oct 20, Det John Vergona refused
to go to the office and interview ANYBODY. He said “her” detectives did that so he didn’t have
to and they did not have to contact me because he did. He refused to interview Dr Vine who
rushed to me and offered me assistance. She gave me her cel phone and called me that night to
tell me she demanded Delita Hooks be fired but Dr Andrew Fagelman refused. She told me
Delita Hooks sat at her desk until 7pm as if nothing had happened.

IAB was not interested in my phone records which show me repeatedly calling The First Precinct
and no one answered.

Public Member Marks said he was alone answering calls or taking

complaints and he can’t do both so as he took down my report the phone rang and rang with
many NYPD officers walking by ignoring calls. He told me go back and call 911 or this will go
no where. It was worse than he warned but I told him I could not because I have a collapsed
bladder and I used the bathroom repeatedly while there and the woman who punched me called
“Delite” according to Dr Vine’s receptionist has the keys to the bathroom.
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Det Vergona had nothing to say when I forwarded an email one of several YouTube comments-the “confrontative c/nt” one -- Sunday night when I was trying to recover from the attack falsely
blaming me -- in a sense framing me just like the first YouTube comment on my “911 Tech
corruption ECTP and I have a black eye YouTube” -- and at the moment of the abusive comment
that lied stating I threw the first punch and they had video -- not true of course -- I called Det
Vergona and that was the 2nd time we spoke and he was like a male version of Delita Hooks and
he had suddenly changed to act very much like my abusers....He showed a clear bias and he did
not understand why my black eye photo showed the opposite eye. He was clearly bias building a
case in his mind to rationalize fixing this case in my opinion -- I am alleging....

I got upset when he said he didn’t care if I had two black eyes. He didn’t seem to believe me and
put his partner on the phone like they were teenage boys and I was an object of derision not a
victim of a savage attack at the doctors office. I told him I would call Apple and enlist there
help.
You can see all this in the emails I include and he never said you being called a confrontative c/nt
is horrible.

When I asked are you anti-Semitic he also had no words when “no” would have

been appropriate so my point he is violated my rights and was bias against me.

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Sgt Chen was holding back laughter over the phone -- he said you were the one assaulted at the
doctor’s office.
disrespectful.

He called me lady like he meant c/nt in my opinion.

He was incredible

I allege Ms. Nam was similiar when on the phone in our fist telephone

conversation she mockingly said email me as much as I wanted. I thanked her.

She writes I incessantly contacted IAB. Thanks for not calling me a “nagging housewife” a
misoygnist term for a woman who works 24/7 without paid and wants to be heard, have equal
rights and is not heard. If IAB and everyone named in the lawsuit responded to emails, snail
mail, calls and or Fed Ex than I would not have to “incessantly contact” anyone. I am surge
King George thought our Founding Mothers and Fathers more than an incessant bother and ditto
for those seeking equality down south.

If I was Black Det John Vergona, his supervisors,

everyone named in the lawsuit and most especially IAB who is obligated to investigate police
corruption treated me like I did not have a right to get on the bus -- sit in the very back of the
bus. I had no rights.
IAB sent this to “the Integrity Bureau” for Lt Anges to close with the goal to allow Det John
Vergona to retire despite the fact he coerced me to drop charges against my will with a hole in
my retina, damage to my cervical spine, and not from the attack a collapsed bladder which makes
me urinate frequently ask if I pregnant with twins.

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Det Vergona, Lt Burgos, commissioner Ray Kelly, Charles Campisi, DI Ed Winski all have
enormous amount of years on the force and yet the found this not usual?
I am alleging The NYPD Fix Crime Like a Las Vegas Casino.

I am alleging I was retaliated

against for being a whistle blower and I include a list of why The First Precinct and Internal
Affairs would retaliate against me.

Page 32 lawsuit: I am also the 2nd NYPD whistle blower to be the victim of “creative policing”
by the First Precinct Detective Squad and Jane Doe is Jewish. John Doe is a retired NYPD Sgt
earning money as a consultant on 911 where I believe his company has charged NYC gov aprox
90 million dollars for advice. Jane Doe claims the 01 made two of her complaints which she
filed first vanish. Her story is worse than mine but I am alleging the NYPD have a history of
fixing crime. Sgt Chen said I was assaulted at the doctor’s office.

Well where is that on

October’s report. It isn’t. The NYPD prevented me from reporting Delita Hooks filed a false
cross complaint. In the evidence I direct you to in the evidence section -- you can hear PO
Migori state I can’t report a false cross complaint that I have to be detective or from the DA.

This is not true and my rights were violated. You will hear Sgt Chen via her tell me he won’t
come down to meet me to explain further. Ms. Nam said via phone conversation there was no
assault and therefore there was no false cross complaint.

I have a right to report an assault.

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There was an assault. I have a right to report a false cross complaint. I tried reporting an alleged
hate crime at the 9th Precinct as per Det Hernandez The Hate Crimes Unit instructions and was
turned away and the NYPD is not allowed to do so. I was told IAB would investigate it. Also
not true. IAB has never contacted me re: assault, coercion, being turned away from reporting the
false cross complaint and on the Migori audio you can hear me call Sgt Chen, DI Winksi, IAB
and CRRB.

At front desk huge poster urging NYPD to call IAB if they see something say

something and no one did including DI Ed Winski when I came Tuesday night after I agreed I
was to be false arrested. I handed in the Lt Giuseppie Petrosino pin honoring his death from
1905 and asked him on a note on the outside of the envelope to be there when I am false arrested
and to give the pin to commish Kelly. I have history of peaceful protests including protesting DI
Ed Winski himself for harassing Veteran Vendors and Artists right outside the precinct and all
officers were kind to me. That night Tuesday Oct 16 no NYPD officer would false arrest me and
all very very kind to me and urged me to give in the pin and my 911 Memorial hat.
My point is a group of NYPD and IAB clearly retaliated against me and where bias. I allege that
Dr Fagelman made calls either to the NYPD directly, a retired NYPD or both and or like a Bill
Rudin type that has a retired NYPD commander on the payroll which I mention in my lawsuit I
saw the retired commander try and fix a parking ticket and I reported it.
I sent in a private investigator via a lawyer and paid the private investigator out of pocket like I
paid lawyers to consult despite Ms. Nam stating I had no lawyers fees.

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My private investigator asked Dr Andrew Fagelman did you talk to the police.

He said he

wouldn’t comment but than went on to comment I wasn’t his patient and he never met me. Det
Vergona said the MDs would not be interviewed because they did not witness the attack.
Dr Vine’s assistant as referenced in my lawsuit a beautiful African American woman say Delita
Hooks come out from behind the reception desk to follow me back stalking me as I tried to get
help from Dr Vine. She broke in despite Dr Vine being with a patient completely undressed and
got Dr Vine to come to me. Both were worth interviewing as important as a crime victim walking
in a month later stating her attacker filed a false cross complaint in front of a poster that urges
NYPD to contact IAB. I contacted IAB and CCRB contacted IAB transferring my case to IAB
because of the criminal nature of it despite my pleas and debate with legal counsel for CCRB
Grahman Daw that the NYPD must be investigated because they abused their power and were
discourteous. I warned that IAB would go in to secret and protect them -- you can even read the
testimony posted on CCRB’ s website and that was IAB did allowing all to walk.
I called Chief Banks and Capt Timoney who replaced DI Ed Winski and both responded to me
unlike all in my lawsuit who ignored me except for IAB Sgt O’Donnell who said case closed and
promised to mail me my notes back and never did. Capt Timoney said he was sure IAB would
respond quickly and contact him. I said IAB is responding as quickly as a turtle in molasses.

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Sgt Decker of IAB told me that Lt Agnes would interview everyone but again this never
happened and I left 2 messages the second warning him ignore me and I will go to the Feds. I
have contacted the Feds (page 48 lawsuit)and spoke to a senior FBI agent who said he looked at
my blog. He said you are an investigative journalist, an artist and a character. I can only hope
that done the road he will help me and some many others like me and or even worse victims of
the NYPD and IAB.

Ms. Nam gave me even more evidence although she was careful to withhold information on
phone calls, notes from Delita Hook’s “Detectives’ who never called me even after reading I
allegedly attacked her. Why didn’t they call me. I am alleging they willfully violated my 14th
amendment rights along with Det John Vergona, his partner, all supervisors listed and others not
listed and therefore please consider moving some part of this case forward if you must dismiss
some part of it, I understand since like too many People this is not an “equal playing field” just
like the video where I was one person attacked and all the group is heard yelling “No, Dee, don’t
do it repeatedly until the video shuts off from her punch, I was told by Det Verogna they all said
it was me.

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It is me, a victim by workers at at medical office and NYPD and IAB officers that I allege frame
me in a mutual assault and wanted me coerced in to dropping charges to make this go away and
protect Dr Fagelman’s office.

I am one honest brave person against a large group with

connections and sadly Federal Laws that often protect the police accountable. I am one person
representing how many people.

See ABC news report on People turned away, Adrian

Schoolcraft lawsuit, NYPD Ramos Trial in the Bronx. I am one of countless victims of the
NYPD.

I believe will be changed to hold the police responsible across our Nation far more than

Federal laws currently do.
I would want a trial so I can call all the defendants and show them the video and Delita Hooks
false cross complaint. Show me please where did Ms. Delita Hooks savage attack of a patient
become a “mutual assault” or “even steven as Det John Vergona said. If we move to trial I can
access all their files and my own as well as Delita Hooks. I can subponea their phone records
especially Dr Fagelman and Delita Hooks as well as emails and serve Google so we can see if
NYPD or even IAB where involved in aggravated harassment and the illegal take down of 2
YouTubes one with Det John Vergona’s name and one with Delita Hooks name which is even
more proof that they were working in concert and the coercion a serious crime was not pulled off
just by Det John Vergona because there are too many checks and balances in place and so many
supervisors where notified and now we have Lt. Burgos admission he opened the case for 24
hours but the video, the false cross complaint, my medical records and Ron Kuby’s letter I drop
the charges against my ATTACKER if my ATTACKER drops the charges wasn’t in any way a
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signal that something was terrible wrong. We can hear IAB Sgt Mary O’Donnell in her own
words. If I get all the detectives and DI Ed Winski and all in involved -- if I get their files in
preparation for a trial I could not only learn their over time and alleged complaints against them,
past lawsuits but find other possible victims and in my opinion that is why IAB has this case
closed and won’t even meet with me to discuss coercion and Delita Hooks false cross complaint
and her fake medical report asserting I kicked her left thigh when I did not. These are serious
crimes they committed and IAB is protecting all involved. The NYPD don’t have to investigate
but IAB does and in one year and aprox 22 days IAB has not and therefore they more than
violated my rights.

Ray Kelly, police commissioner did come out against the NYPD Rape Cops and so he easily
could have done the same in my case preventing this from snow balling in to what it is today. He
did not.

This is a police commissioner that took free rides for him and his spouse on Air

Bloomberg aka mayor Bloomberg’s private jet with a police commissioner is not allowed to take
a cup of coffee. I once held him in esteem but now I see him in a corrupt police commissioner
who can brag he more than defeated OWS but by violating how many constitional right but the
victory will win him even more “free rides” after he gets out of office in my opinion.
The ABC News piece by Jim Hoffer proves I am not alone being a victim of the NYPD
preventing victims of crimes report crime as well as the Adrian Schoolcraft tapes so a trial would
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allow me to put the NYPD and IAB on trial and via access to their files possible learn even more
about how they violated my rights as Adrian Schoolcraft has learned that IAB did criminal
investigations in to his father and sister and possibly violated State laws doing so.

If I can’t get a trial than I ask you find some part or as many parts to move forward to mediation
as I was a patient and the NYPD and IAB has literally cost me money for their role in abusing
me including emotional pistol whipping me. sending me a message to shut up and stay out of
trouble keep me head down, stop contacting them or do not as Det John Vergona instructed me
on behalf of him and Delita Hooks and I have never contacted her. I did not even know her
name.

The defendants have caused me great suffering and continue to do so because they will not take
responsibility for their actions.

I had such a feeling of respect, admiration and compassion for the NYPD because of 9-11 and
also because of the courage required and often the toll it must take dealing with a lot of violence,
sadness and even frightening experiences most People don’t experience.

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Protesting and dealing with the NYPD I do believe I developed a form of Stockholm syndrome
where it is no longer became about admiration but something else because of constant fears of
false arrest as too many protestors know first hand.

To see the extremes the NYPD and IAB will go to just in my case as well as Adrian Schoolcrafts
and from my research a culture and history of protecting the Blue Wall -- has been a shattering
experience.

June 21, 2013 before I testified for Mark Carson on his ambulance ride being delayed and calling
for an investigation in to his ambulance ride which never happened and I was the only one to
question in my testimony at City Hall, John Liu’s audit and where is the criminal investigation
in to 911 corruption.
Before I testified, I handed police Commissioner Ray Kelly a Justice card -- pre the lawsuit -that made no mention of suing but did state the NYPD fixed me being assaulted and Delita
Hooks, Dr Fagelman’s receptionist filed a false criminal report and I said to Mr. Kelly -- I am
sorry to tell you I am going to sue you. My Dad is a World War 2 Vet and you are a Vet... and
Mr. Kelly took my card.

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This lawsuit could have been easily avoided if Mr. Kelly took responsibility than like did re: the
NYPD Rape cops.

I am alleging he was aware of my stance on the 911 Tech corruption and that was his baby as
well as his ambitions to become head of Homeland security and based on my work and others
Mr. Bloomberg and Mr. Kelly will not be getting any jobs at The White House so I am alleging
retaliation and I feel great sadness because my Father admired Mr. Kelly and encouraged me as
well to have admiration for him and before my Father died I had to tell him Mr Kelly and all the
defendants agreed to defend in my opinion an anti-Semitic Det who couldn’t answer simple
questions -- why do I have to wait 4 days to be false arrested, arrest the Jew on the Sabbath? Are
you anti-Semitic? My Father knew I have never ever been in trouble and I don’t assault People
or break the law. Det Vergona and all police involved in the coercion and fixing caused us great
suffering and even from the phone bill on Oct 16 you can see how much time Vergona’s abuse
took me away from my Father who’s Time in Earth was limited.

It is clear how much pain and suffering was inflicted on me and Mr. Kelly’s actions via his
lawyer have caused even more suffering when I was and clearly am the victim of violence by Dr

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Fagelman’s employee and of NYPD and IAB abuses.
United Nation’s ConventionTorture:

Page 45 of my lawsuit the definition of

Definition of torture

Any act by which severe pain or suffering, whether physical or
mental, is intentionally inflicted on a person for such purposes as
obtaining from him or a third person, information or a confession,
punishing him for an act he or a third person has committed or is
suspected of having committed, or intimidating or coercing him or
a third person, or for any reason based on discrimination of any
kind, when such pain or suffering is inflicted by or at the
instigation of or with the consent or acquiescence of a public
official or other person acting in an official capacity. It does not
include pain or suffering arising only from, inherent in or incidental
to lawful sanctions.
— Convention Against Torture, Article 1.1

I look forward to Ms. Nam’s response on behalf of her clients because I am using all her
efforts to pursue her clients and others not named when I testify in front of a new
commission and any attack on me is welcome because I am an artist with my most
popular YouTube “Condom Bra Art and Poem about Safe sex & Politics” about Rape,
AIDS and more with 35, 600 -- I am not a “public official or other person acting in official
capacity” as are the defendants.

I am an artist and activist Mae West Meets Mike

Wallace. Cas Holloway, mayor Bloomberg’s “deputy” insulted all of us before we
testified tantamount to calling us liars and stupid only to be forced to eat his words in a
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letter to Janet Napalitno. He looked in my direction and said look at who’s testifying.
Well Mae West is my idol and I am also American Citizen, a New Yorker and I promise
the defendants who were acting in an official capacity and Ms. Nam ,their team work
along with Michael Cardozo regarding this case will be brought before a New
Commission in to Police Corruption including Internal Affairs so thank you for for helping
my efforts especially the letter on behalf of all the defendants including Mr. Kelly and Mr.
Campisi who’s services will be terminated at the end of the year unless they resign first
stressing they want Mr Vergona defended. Thank you very much. I can’t wait to share
that with our New Commission in to Police Corruption.

Honorable Judge Nathan, if there is any way you can write an advisement that the
NYPD and IAB need an outside monitor like Honorable Judge Shira Scheindlin
please do. I didn’t ask for millions of dollars. I didn’t believe in that at the time I
filled but I do now because of the enormous amount of work it takes to sue. What
is crucially important is the NYPD and IAB be held accountable.

They violated

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my Constitutional Rights and in my opinion they believe it is a slam dunk my case
with be dismissed.
“Life is to be lived, not controlled; and humanity is won by continuing to
play in face of certain defeat.” 
― Ralph Ellison, Invisible Man

I allege I was emotionally pistol whipped, degraded, humiliated, verbally assaulted and
threatened with false arrest twice and that Det Vergona did not operate in a vacuum but within a
system filled with checks and balances including and most especially IAB who is obligated to
investigate police corruption and I allege did not unless it was to fix yet another crime “coercion”
and not alert Capt Timoney to arrest Delita Hooks for assault, false cross complaint, alleged
witness tampering via associates and alleged witness tampering and as I requested once I learned
at the end of Sept 2013 the case was open yet again -- testament in my opinion that Lt. Burgos’s
24 looksie was as false an investigation as Delita Hooks false cross complaint, Lt Agnes
“Integrity Bureau Investigation, IAB’s investigation that I initiated the weekend I was coerced 19
days after I was assaulted and repeatedly agreed to false arrested and imprisoned, that CCRB
forwarded my complaints to IAB which prevented me from having all questioned under oath and
now protected under IAB’s infamous secrecy with I allege the goal to protect the NYPD Brand
as mentioned in my lawsuit ---- I allege all defendants and others who’s names I do not have yet
to greatly damaged me that the only way I could begin to regain my life as a victim and pro se
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litigant to file a claim -- I was in terrible shock than and at times learning what I could without
subpoena power so finally begin to learn Ms. Hooks false allegations against me a serious crime
her false cross complaint I finally got to hold in my hands and read caused me great pain as well
as Ms. Nam’s clients telling me to serve retired Det Vergona at 1 Police Plaza and they want to to
defend him speaks volumes that Det Vergona was not a rogue cop and what he did to me is
protected by Mr. Ray Kelly, the NYPD Police Commissioner and Ray Kelly with a video that
proves I was savagely assaulted with over 17,655 views on YouTube speaks volumes.

I have no legal education at all -- zero and not even half the tools and resources their lawyer has
and I posted Ralph Ellison’s quote for a reason....Ms. Nam’s clients robbed me of my
“humanity”. Delita Hooks yelled at me who am I. I have no rights. I had compassion for her to
be so violent and abusive there must be something very wrong but than I lost it when I found out
she lied and was and is fearless of any arrest for some reason. The NYPD and IAB continued
her abuses confirming I have no rights and we are not equal except when Delita Hooks and the
Det Squad and all supervisors agreed we were suddenly equal in terms of Ms. Hooks assaulting
me which is a fabrication of evidence with the goal they all wanted which was to coerce me to
drop the charges.

Ms. Nam’s linkedin page states she graduated with honors from Brooklyn Law School and so I
embrace Ms Nam’s confident and in my opinion arrogant move to dismiss with Ralph Ellison’s
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quote and to explain I am fighting as hard as I can with all the tools I can muster as a victim of a
violent crime and NYPD and IAB abuse of me and my constitutional rights with no legal
education at all to regain my humanity and pursue Justice so far denied me.

Please look at page 45 of my lawsuit the United Nations Convention against Torture:
Definition --- it is devastating and applies to me -- the mental and physical pain and suffering
Det John Vergona wanted to inflict on me on top of what I was suffering to further degrade me
more than he had on the phone treating me like a criminal, humiliating and degrading me and
telling me not to call or Delita Hooks as if they were partners -- and his sadistic cruel goal
making me wait for 4 days to coerce me to drop charges or to suffer even greater physical and
mental suffering -- the discrimination in the definition --- and in the definition by any public
officila or person acting in an official capacity. I alerted DI Ed Winski and he did nothing. How
many supervisors knew including IAB I was to be false arrested. I was the victim of Medical
Office abuse and than NYPD abuse with IAB watching and doing nothing and it is still the case.
They continue to violate my Constitutional Rights in my opinion and IAB is required to
investigate police corruption and take action and based on my phone records and the lack of
DD5s that either Det Vergona never filled out and the NYPD sealing Delita Hooks false cross
complaint there is more than enough proof with the video etc that IAB did not do there job.

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I want compensation for as much as possible starting with fees I paid lawyers, process servers,
etc. I really want Justice most of all for me and so many People violated NYPD abuses.
The NYPD should remove “Protect and Serve” from all property because it is dishonest and false
advertising. (lawsuit page 35 bottom of the page).
My “incessant emails”, this lawsuit, underscores an innocent person framed , a victim of a violent crime, abused,
rights violated by Dr Fagelman’s employee and the NYPD and IAB proving there was nothing mutual/even steven
about the assault and the NYPD IAB were bias and there actions violated me/my rights. The abusers have carte
blanche thanks to Mr. Kelly and Mr. Campisi who chose to defend the lead detective guilty of coercion a serious
crime. The truth is I was assault and coerced. Mr Kuby cleverly wrote I was coerced in the letter without using the
word “coerced”. The rest of this document are my allegations, my opinions and I back it up with evidence. With
subpoena power and a trial I can do even better.

Thank you,
Suzannah B. Troy

Evidence Section Continued:

Proves Internal Affairs did not do their job and

they are obligated to investigate Police Corruption...Proof Det Vergona and all involved violated
my Constitutional Rights in my opinion because they all had access to these materials and the
video was a glaring red light something was very wrong but they wanted to send a message to
silence me and to accept the violence are my allegations as if I deserved what I got....
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The 34 second video of the beginning of the assault on YouTube with 17,500 views
YouTube turned away audio of PO Migori telling me I can’t report Delita Hooks false cross
complaint because I am not a Det or from the DA
YouTube audio of IAB Sgt Mary O’Donnell directed to call me by the Commission to Combat
Police Corruption and in my opinion I am stone walled and her behavior corrupt not that of an
investigator seeking the truth so I do not want to talk to her anymore
Paper evidence -- filed in back of motion to dismiss
Evidence Section page 1) Omitted from Det Vergona’s DD5 Oct 4, 2012 9:35 am emailed from
my iphone from the bus going to see my Dad after speaking with Det Vergona
2) Oct 4, 2012 9:59 photo black eye -- this would be the photo that Det Vergona and his partner
would humiliate me and mock me -- which eye passing the phone back and forth. They did
not understand photo booth flips the images. The phone records show the frantic calls in the
after Oct. 4, 2012 after abusive YouTube comments and the abusive behavior begins -Vergona says I don’t care if you have two black eyes. He went from friendly in the am to
changing at the same time the abusive YouTube comments begin.
3) email to Det Vergona Oct 4, 2012 - damage to left eye.

He can clearly see it is my left eye

but evidence page 2 image appears to be right because of photo booth phone records show I
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called able and I also forwarded emails from Apple to Vergona. I am so distressed by Det
Vergona tell Apple supervisors he is treating me like a liar I need your help. Phone records
show they called me to check that email came through because I am so distraught.
4) Det Vergona is so abusive and cruel doesn’t believe it is my left eye or he doesn’t care -- he
refuses to meet me. I left my Father and from the phone records you can see how much time
it took including Det Vergona’s partner mocking me leaving me on hold for 10 min. 10
minutes away from my Father to laugh and say are you still there?
email Oct 4, 1:48 of my eye it is getting worse I wanted to go from Penn Station at 2:30 to the
First Precinct but he won’t allow that to happen.
5) email Oct 4, 2012 sent from bus after call from Vergona 9:36 sent iphone video
6) Oct 4, 2012 9:39 blog created with photo of black eye photo booth with short summary -- so
upset I can’t find email and password to update it so it doesn’t have the video which I did not
post until Vergona and the cyber abuser appear on the same page Oct 4 in the afternoon.
Upload the video to YouTube than.
7) Oct 4, 2012 9:59 2 pages describing assault
8) Email to Det Vergona Oct 4 2012 Dr Vine says Delita Hooks 40. She and partner not happy
Delita Hooks is not fired -- they are vacating she says 2 months -- turned out 2 weeks.

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9) Page 9 “TheAjohn747” abusive comment attacking me the patient blaming me framing me
and Vergona ends up taking over where this abusive leaves off. Not in DD5 Ms Nam shares is
Vergona tells me he does not care what they say and no I can’t post his telephone number -- I
wanted to do so because if there is any video it will show me holding bags one very heavy and
my phone as she repeatedly hits me, punches me, rips out my hair and repeatedly kicks me
from the ground where I got her as gently as possible instead of hurting her as I had no interest
in fighting her. See the photo before the assault I was happy.
10) Page 10 The Ajohn747 2nd abusive comment.

Det Vergona says he does not care what they

say. He will go to the office and interview everybody. He never does. IAB Sgt Decker tells
me Lt Agnes will go interview everybody. He never does either. Vergona says he doesn’t
have to because “her detectives” went is what he said Oct. 16 when I agree to false arrest and
tell him I will sue him.
11) page 11 Att bill This bill shows:
Oct 4 Det Vergona 9:19 calls me 13 minute long call. He fabricates in DD5 we tussled to the
ground that is not what I said.
Oct 4 No DD5 because of dereliction of duty or Ms Nam omits 9 minute call Vergona turns
abusive -- I called because of aggravated harassment YouTube on behalf of Delita Hooks
He refuses to understand about photo booth flipping the image -- he says I do not care if you
have two black eyes.
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Oct 4 12:26 call Apple for help to explain to Det Vergona -- frantic say how abusive he is to me
treating me like a liar. 22 minute call and Apple supervisor did not follow through with email as
promised for Det Vergona.
Oct 4 12:48 call Det Vergona to tell him expect email from Apple his partner keeps me on hold
for almost 10 minutes are you still there as if mocking me fraternity like -- previous call the past
the phone back and forth. (I allege all this is bias and abusive violating my 14th amendment.
Oct 4 Apple 1:15 20 minute calls desperate the email didn’t come through
(All this time away from my Dad and I am so shocked and upset by Det Vergona and his
partner’s abusive behavior as if I am not the victim clearly now their victim as well of bias.)
Oct 4 Apple calls me the supervisor to check on me and to make sure I got the email to give Det
Vergona 2:09 4 min call
Oct 4 2:15 Call Det Vergona again to beg to come down on train will be there soon
Not allowed to come to Precinct and show him eye Where is DD5 for these calls?
Page 12 At&T 11:43

11 min call mayor Bloomberg’s Intelligence Division call me Sgt who is

one of Det Kevin Lynch’s supervisors. He wanted to know how I got Kevin Lynch’s name. I
asked him does Kevin Lynch have to obey protocol. Do mayor Bloomberg’s NYPD have to
obey protocol. He says yes.

(See NYPD IAB retaliation section)

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I am attacked by Delita Hooks aprox 4:05 - 4:10 Dr Vine comes to me -- I exit call 2 bloggers
quickly than the police -- you can see the calls to the First Precinct no one picks up so I call IAB
and 2 times I believe I tried conference calling to show IAB something wrong with precinct. You
can see I called Dr Vine’s office too from the precinct.
page 13 “Incident Information Slip” wrote at top Public member Marks tells me this will go no
where unless I go back and call 911 -- I tell him I am afraid for my safety. Ms Nam includes my
fear for my safety in her evidence to dismiss. It should be noted I called Dr Vine from the first
Precinct and spoke to her receptionist -- she in my opinion lies to me and says she doesn’t know
the woman’s name that sits next to her behind the reception desk -- I tell her the police want her
name. She says her name is “Delite” no last name. I wrote her “Delite” reference on this slip of
paper.
Page 14 evidence number 14 and
page 15 both emails from Apple who knew how much I was suffering and so upset and sent me
info to explain photo booth to Det Vergona -- see emails As usual Det Vergona has no response
and won’t allow me to meet him to show him the damage to eye, neck and arms. (Please tell me
what is “even steven” about any of this. He violated my Constitutional Rights.

Page 16 Oct 6 email to Det Vergona -- Black Eye day 6 Dr Fagelman no response from Vergona

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Page 17
Page 18 both 17 and 18 of evidence section extremely abusive YouTube comments by Bob
Dobalina -- I report him for gender hate crime and alert him that if he does indeed work for law
firm and is a lawyer -- I reported him. He immediately deletes account. I call Norman Siegel
right away. He is very kind to me. It is Sunday night and I am being aggravated harassed and I
told him and the lawyer in the next sock puppet account that came to me that I am concerned this
is witness tampering. He deletes his account as well. I forward to Det John Vergona. No
response to be me being called a fight picking c/nt -- reminder Oct 16 he would say you should
have kept walking where is that DD5?

No response to Vergona on aggravated harassment

witness tampering.
Page 19 Is this Witness Tampering - email to Det Vergona -- no response
page 20 email to Det Vergona Oct 11 going to specialist herniated disks bulging in neck

Page 21 evidence 21 page a and page b
email Oct 13, 2012 Why haven’t I heard from him --- I had spoken to Det Del Pozo so I sent
Det Vergona this email because I do not understand why he has not gotten to the office and her
arrested.
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page 22 email page a and b to Vergona -- he doesn’t take my call -- have more info from neck
MD
page 23 of evidence 23 a, b, c, d from my blog the 2 sock puppets 2 lawyers trying to convince
me I did something wrong and this would go on with different sock puppets and even patients on
behalf of Dr Fagelman and Delita Hooks. “Bob Dobalina” and “Charles Ward” back to back
Sunday night abuse the goal to turn the tables on me the victim -- Sunday night trying to heal
trying to deal with being violated at a MD’s office. Page 23 E, F Vergona no response migogyny

Evidence 24 page 24 a and 24 b Oct 16 Det John Vergona, LGBT Det Duffy, Commish Kelly’s
Det Martina Brown -- I have contacted the DA

-- as noted early I had contacted the AG

Investigative Unit and they told me to contact DA but DA turned me away and said they had to
hear from NYPD or IAB.

I contacted the DA many times including after I was coerced every

division possible also later stating AG told me to contact you.
Page 25 Evidence 25a to Det Vergona, Oct 16 Am I being sent a message include Det Brown,
LGBT Duffy, Norman Siegel, Ron Kuby

Page 25b G-d Sees All

(Despite Ms Nam’s in my opinion false assertion-- Oct 16 I email Det Vergona,
Det Martin Brown in Commish Kelly’s office and LGBT Det Duffy how evil
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Det Vergona’s action are but they don’t compare to the Holocaust I am clearly
very upset and I include a photo of me with an NYPD Detective hat given to
me by an NYPD Det from 9-11. PLEASE SEE THIS EMAIL.
Page 26 Send email with Lt. Petrosino Pin dropping off to o1 Preinct Oct 16 clearly I am very
upset
Page 27 evidence 27 Oct 17 email I am to be false arrested
Page 28 EMAIL FROM DET JOHN VERGONA HE WILL GO OVER TO THE DOCTOR’S
OFFICE MONDAY. HE UNDERSTANDS MY FRUSTRATION. This was his like the first
conversation Oct 3 but both he and Delita Hooks are like Dr Jekhyl Mr. Hyde (See bottom of
page for his email HE INSTRUCTS ME TO CALL HIM MONDAY -- again treating me like a
tramp girl friend or something like that and of course when I call him Monday the 15th of Oct he
won’t take my call!
page 29 evidence 29 Letter to DI Ed Winski handed in after Sgt Chen refuses to come down to
speak with me. I call Internal Affairs and give him case number. The letter clearly indicates Ms
Nam’s excuse for Sgt Chen via our phone conversation is not what I was told as can be heard in
the audio and read in this letter. Date Nove 20, 2012 12:15

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Page 30 Email to Lt Burgos asking for Badge numbers of Det Vergona and Sgt Chen -- I am so
clueless I do not even know to ask for Det Andy Dwyer’s name and badge number and ditto for
his partner and Vergona’s.
I mail this email snail mail to Commish Kelly, Chief Esposito (now retired), Chief Campisi at
One Police Plaza, DI Ed Winski and get no response.

Page 31 Email to IAB Det Vergona Corrupt just more proof in a series of emails to IAB that they
never investigated and proof they never me with me to discuss being coerced.

IAB Sgt Mary

O’Donnell and her partner meet with me to discuss my theory Dr Fagelman may be drug
pedaling since Chief Marino and 20 cops got busted getting HGH from MD Staten Island and Dr
F pedals viagra from his website I was am suspicious considering the bias treatment violation of
my 14th amendment rights by IAB and NYPD. I make complaint against IAB don’t understand
the word Coercion? Do you get viagra from Dr Fagelman also?

Also more proof IAB is not

properly supervised -- see many “incessant emails” --- but if IAB had actually done their job and
they are legally obligated to investigate crime I wouldn’t have had to email so much.
Det Vergona did not arrest her. In fact it appeared he worked for the MD’s office just the way DI
Winski appeared mostly to work for Michael Rawson of The Mercer Hotel. (See economic
racism section.)

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page 32 email to Commish Kelly, chief esposito, Chief Campisi,

Dec 3, 2012 cite bias

threatened lawsuit -- if they had taken the time all this could have been avoided...instead more
suffering, more pain, more of my energy, money and life gobbled up by abuses of the worst kind
by MD office and NYPD and IAB.
page 32 b and c to all of the above ask if you have to be a playmate to get DI Winksi to call. He
helped a playmate being stalked but question is would the stalker have actually come to NYC?
page 33 Letter from DI Dennis DeQuattro extremely respectful and responding to an email to
Commissioner Raymond Kelly (see page 8 lawsuit -- I wrote ideas on how to improve NYPD
community relations).
page 44 CCRB letter shocking -- Det Vergona violated CPR Courtesy Professionalism Respect
and CCRB and their lawyer Graham Daw refuse to hold on to my cases despite my warning that
IAB can fix this for these cops where CCRB will make them come in and testify under oath. I
had reported all of them to IAB. It was good that CCRB felt there was something criminal or
seriously wrong to forward to IAB Internal Affairs Bureau but I was correct secretive and let 2 of
the accused retire and it appears all are above accountability in opinion. I would have had their
testimony from CCRB and Det Vergona would not have been able to retire until CCRB had
finished their investigation.

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Page 35 I can’t find letter to Commish Kelly but I have it some where I know. He has a copy and
there were emails prior about my idea Project Peace to the Streets but this ended with a query
about why wasn’t Delita Hooks arrested. What’s with Det Vergona. Fed Bill dated 10/09/12
so he got my concerns right away.

I could not understand why Delita Hooks was not

arrested.

Page 36 in audio IAB Sgt O’Donnell I never had the actual copy of the email Ron Kuby
sent. He is very busy and did what he did for free without meeting me.

He left out the

word “alleged” but Ms Nam in her motion to dismiss shows us his email which is proof
enough something is wrong. He only emailed them Monday post the Saturday Coercion
Oct 20th when he learned I had gone to IAB and CCRB which he thought was a waste and
wanted nothing to do with it. His email is excellent and thanks to Ms Nam I know now he
did what I wanted

Page 37 Letter from NYC Police Foundation Thanking me for $200 donation to NYPD
Hero Police Officer Figoski Scholarship fund for his daughters. He was shot in the face.
Det Vergona and all involved destroyed the good feeling I had for the NYPD.

I gave

corrupt cops hell from my blog but honored the good ones.
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page 38 a and b faxed to Det Vergona Oct 4th am -- omitted from Ms Nam’s motion to
dismiss along with all medical records I faxed to Det Vergona for some reason including Dr
Keil’s notes that describe the damage to my forearm defensive wounds + medical records
post coercion conditions worse on going treatments.
Page 39 a b and c Dr Rachel Bergang damage to my cervical spine, neck brace -- question
Delita Hooks 135 pound pulling and pulling my hair yanking my head pulling my hair from
the ground as well do you think it is possible she caused the herniated and bulging disks
and greatlly aggravated the arthritic condition. I have more nerve damage and pain now.
page 39 post Vergona -- epidural -- treatment on going for neck pain -- some I am paying
out of pocket I was getting physical therapy while preparing for false arrest as well.
page 40 Proof of collapse bladder I told Det Vergona about and Public Member Marks.

Page 41 a-e Dr Young find hole in my retina detachment day before false arrest date Det
Vergona is so abusive and he is out of the office Oct 19th the day before scheduled arrest --Dr Young finds the hole in my retina. He makes me cancel treatment for my neck day
before scheduled false arrest Oct 20 and makes me get in a cab to Dr. Khadem.

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page 42 Dr Khadem Oct 19 - Dec -- He sees contusion in my eye, floaters from Delita
Hooks yanking my head back both eyes but not the hole that Dr Young found so I leave
with hole in my retina and return in Dec with same symptoms -- like vaseline is in my left
lower eye and problems with balls of light -- he makes me stay and does laser surgery -- he
know sees hole

page 43 email to IAB Sgt kroll IAB sgt Mary O’Donnell’s partner -- I sent him a couple of
emails because of the two I thought he appeared real -- he told me I have time to go after
Delita Hooks for assault and he admitted he had watched the video. I don’t have all the
pages handy so two key pages

Page 44 a and b May 11, 2013 Dr Khadem finds scar tissue where Delita Hooks made a hole
in my eye. I have to check my eye every day. Eventually I most likely will need a serious
surgery to repair “Macular Pucker”
b) the infamous reception desk that is long and closed off showing IAB how far Delita
Hooks had to come. Det Vergona asked me why I walked by Delita Hooks not aware she
sits at the exit.

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Page 45 A and B -- (See YouTube Comments one on NYPD Det Lynch YouTube which was
threatened with removal which I allege was harassment but Google sided with me -- c/nt
remark ) I sent the press that cover NYPD news the front page of this motion to not dismiss
and it had the work c/nt. I allege one of the news reporters tipped of a corrupt cop who got
a designated troll to start harassing me on YouTubes yet again and did so through out my
Dad’s funeral and 3 days after Dad dies until I blogged I went to the FBI for help and I
believe it is NYPD involved. Than it stopped I am called c/nt, fuckin loser, leave them alone
c/nt.

Reminder IAB Sgt a woman at the commander center IAB refused to take my

complaint and invesitiage NYPD role in possible aggravated harassment/witness
tampering. I am alleging from before the lawsuit was filed until

page 45 a and b lawsuit page 5 --- 911 references page 5 also page 32, page 50 lawsuit
see article The NYDN: I allege Commissioner Ray Kelly wanted the Homeland security
job and letters like “Holloway’s letter was a response to a formal complaint to Napolitano
from Lillian Roberts, executive director of District Council 37, the main city workers
union.”

I follow up with my own letter and I believe this is why in part the NYPD and

IAB I allege fixed me being savagely assaulted and wanted me humiliated and to suffer.

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911 is there baby. Ray Kelly said 911 worked during Hurricane Sandy. Not true I wrote
from my blog. He and Bloomberg not telling the truth I blogged my opinion.

Read more: http://www.nydailynews.com/news/election/gonzalez-bloomberg-lauds-911audit-called-stupid-article-1.1432452#ixzz2kYugZFUY

Juan Gonzalez: Bloomberg lauds
911 audit he once called ‘stupid’
That audit, one of two released by Liu that year on the problem-plagued
upgrade, claimed that the project’s main contractor, had repeatedly
submitted 'inflated' charges and that city officials 'grossly mismanaged' the
project.

page 46 A and 46 B you can see Aug I still and trying to get Delita Hooks false criminal
report or complaint because I was never told her viscous lies and false allegations.
I got my report.
page 47 Huge triumphant thanks to one honest cop almost 1 year later I get her false
cross complaint. You can see I wrote at the bottom please waive the $15 dollars since I
am the victim of a savage assault and a false cross complaint.

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