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FAMILY COURT OF THE STATE OF NEW YORK COUNTY OF WESTCHESTER ....................................................... ................ 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 OF MOTION - against - FOR THE RETENTION OR REINSTATEMENT SUSAN SAMORA, OF COURT APPOINTED Respondent ATTORNEYS _______________________________nycour40.doc 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 judges. 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 me. 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. _____________________________ PHOTIUS COUTSOUKIS SUBSCRIBED AND SWORN TO before me _______________, 1999 ____________________________________ NOTARY PUBLIC FOR NEW YORK My commission expires: . . TRUTH METER
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