..... Theodora

Marc Domicello
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    In the Matter of a Proceeding
    Under Article six of the Family Court Act              
    Docket No: X-820-99
                                            File #    53516
    PHOTIUS COUTSOUKIS,                                    
              Petitioner,                   PETITIONER'S
    AFFIDAVIT                                    IN SUPPORT
         - against -                        FOR THE
                                       OR REINSTATEMENT
    SUSAN SAMORA,                      OF COURT APPOINTED
              Respondent                    ATTORNEYS
    I, PHOTIUS COUTSOUKIS, being first duly sworn, depose
    and state:
    1.   I am the Petitioner in this matter.
    2.   Judges Braslow and Cooney of Westchester Family
    Court were recused in an irregular manner, transferring
    the case to Judge Sweeny of Putnam County, while
    retaining Westchester County Jurisdiction, in an
    apparent attempt to prejudice my case by, among other
    effects, offering the two court appointed attorneys,
    Mr. Marc Domicello, assigned counsel for Susan Samora,
    the Respondent in this matter, and Ms. Robin Cotler,
    Law Guardian, cover for past misdeeds and the
    opportunity to go without exposing the judges.
    3.   The irregularities involved in the transferring of
    the case to the Putnam judge are described in Exhibit
    1, my "Petitioner's Affidavit in Support of Motion to
    Recuse the Judge", dated July 7, 1999.
    4.   Mr. Domicello previously resigned when I uncovered
    ex parte plotting between him and judge Braslow. This
    time he is resigning via an affirmation which also
    contains scurrilous and sham characterizations of me
    and he should be present in court so that I can answer
    them for the record. I cannot question Mr. Domicello,
    but the Judge can, if he is present.
    5.   It is also important that Mr. Domicello, who has
    been a player in my forced separation from my daughter
    Theodora and her subsequent destruction, to face up to
    his responsibilities and to the part he played,
    including false statements that he made "under the
    penalties of perjury", in covering up his client's and
    the judge's misdeeds.
    6.   The Court must consider my and my daughter's
    plight and not allow Mr. Domicello off the hook, just
    because his Camp Rehoboth (gay beach) timeshare is up.
    7.   Similarly, Ms. Cotler's excuse that it would be
    inconvenient for her to schlep to Putnam should not be
    considered, when I am being forced to do so to comply
    with the plots hatched by two crooked White Plain
    8.   Ms. Cotler resigned via an Affirmation, with a
    zing, a vitriolic misstatement of facts and
    characterizations of me. Letting her go, would allow
    this vicious attempt to distort the facts and to damage
    my case from behind a locked door, quintessentially
    cowardly, to succeed, and that would be prejudicial to
    8.   Additional facts and arguments regarding these
    resignations and how they came about are included in my
    aforesaid Exhibit 1.
    9.   Finally, these two lawyers must not be allowed to
    quit, so as to prevent further exposure of serious
    irregularities and judicial misconduct in the White
    Plains court.
                   SUBSCRIBED AND SWORN TO before me
    _______________, 1999
                                  NOTARY PUBLIC FOR NEW
                                  My commission expires:
    Photius Coutsoukis 1111 Howard Street Peekskill, NY 10566 (914)739-8888 or (800)483-4856 Fax: (914)739-8913 email: Photius@theodora.com - URL: www.photius.com

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