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FAMILY COURT OF THE STATE OF NEW YORK
COUNTY OF WESTCHESTER
................................................................ .........
FU#: 53516
PHOTIUS COUTSOUKIS Docket #
X-748-00/V-734-97
Petitioner,
-against- AFFIDAVIT IN SUPPORT
OF MOTION TO FOR
SUSAN SAMORA THE JUDGE'S RECUSAL
Respondent
...............................................................
nyaffi40.doc
TO THE FAMILY COURT:
The undersigned Petitioner respectfully shows that:
(Numbers in table of contents refer to paragraphs)
- DENIAL OF DUE PROCESS . . . . . . . . . . . . . . . 1
- DELIBERATE MISREPRESENTATION OF MY
PLEADINGS . . . 13
- JUDGE'S CALCULATED MANEUVER VIA ADJOURNMENT . . . 18
- MORE MISREPRESENTATION OF MY PLEADINGS . . . . . . 20
- BIAS AND PREJUDICE . . . . . . . . . . . . . . . . 25
- UNFAIR TREATMENT FAVORING THE FEMAILE PETITIONER . 30
- COMPLETE DISREGARD FOR THE WELFARE OF CHILDREN . . 32
- PRESUMPTION OF GUILT AND PROPAGANDA FROM THE BENCH 42
- ABUSE OF DISCRESSION . . . . . . . . . . . . . . . 42
- ABUSE OF DISCRESSION . . . . . . . . . . . . . . . 43
- IRREGULAR ASSIGNMENT OF THE JUDGE . . . . . . . . . 44
- THE PRESENT JUDGE SHOULD NOT HANDLE THIS
CASE WHILE
ARTICLE 78 CASE IS PENDING . . . . . . . . . . . . 48
- UNEXPLAINED SECOND ADJOURNMENT . . . . . . . . . . 49
1. The present judge continues to deny me due process. My
job is to present the Court with the facts of this case and it is
quite apparent that the judge prefers to not allow any facts to
become known, as follows.
2. In a decision dated July 13 2000. [EXHIBIT 1], the judge
denied my Motion to Compel. [EXHIBIT 12] discovery on
technical grounds
3. The judge's decision is strange and biased as follows.
4. She notes that the "copy of the notice of deposition is
neither dated nor notarized". Apart from the fact that my
motion to compel states the date of the notice, there is also no
requirement of notarization of a notice of deposition while my
original, notarized notice was served on the Petitioner in
accordance with CPLF 3102. The unnotarized copy was
supplied as a courtesy to the judge, not to give her excuses to
help the Petitioner avoid discovery. There is no legal
requirement to give the judge a notarized copy of a notice of
deposition addressed to a party.
5. The judge is trying to find a way to deny my legally
mandated right to discovery.
6. The judge notes that "there is no accompanying affidavit
of service indicating when this request for interrogatories was
served upon Petitioner" while my motion to compel clearly
states that the notice of deposition and the interrogatories were
served together and my signed and notarized affidavit of
service so states.
7. The judge herself noted that "the motion papers are in
compliance with CPLR 2214(b) in terms of notice to
Petitioner. Additionally no papers in opposition to the instant
motion which was served on June 16, 2000 have been
received by the Court." Quite obviously then the petitioner
would have also been made aware of the documents that this
judge questions, via the papers that the judge found "in
compliance".
8. Yet she denied my motion stating that "Clearly, in the
absence of any documentary evidence regarding service of the
request for interrogatories . . ." and that "Even if this Court
were to assume that the FedEx shipment tracking page which
indicates delivery to Ossining New York on May 30, 2000
was made with respect to both the notice of deposition as well
as the request for interrogatories, it still would not have
justified an order compelling disclosure inasmuch as the
twenty days would not have run at the time this motion was
made on June 16, 2000 [my emphasis added]"
9. This sort of voodoo arithmetic overlooks the facts, the
calendar and the law. I served the notice of deposition and the
interrogatories on May 24, 2000 and the Deposition was
scheduled on June 16, 2000 (=23 days). I even attached a
transcript from the deposition whereby I stated that "the
Petitioner was notified that her deposition would be taken at
this time and she was notified via notice on the 24th of May
by Federal Express, by surface Mail as well and by another
copy of the notice which was handed to her during a visitation
exchange." [Transcript of my statement by Dalco Reporting,
p.3, lines 12-18]. It is entirely illogical and prejudicial for the
judge to presume that somehow the Petitioner was not served
the notice as I stated in my affidavit of service, as shown on
the FedEx receipt (supplied as courtesy to the judge and
additional proof, as the law does not require FedEx Receipts,
but courtesies apparently back fire in the case of this judge.)
and as noted by the court reporter in my statement at the
deposition.
10. The judge noted that "the accompanying document from
FedEx which purports to be proof of service indicates that
service was made on May and 30, 2000 and, thus, at the time
the motion was made, namely June 16, 2000, the twenty day
time period had not yet expired". The judge here ignores the
rules which state that date of service is when I mailed the
notice NOT when FedEx finally got hold of the Petitioner.
Furthermore, the Petitioner who was served with a copy of
my motion to compel this exact same deposition had ample
opportunity to respond and, as stated by the judge in her
decision, dated July 13, 2000 "no papers in opposition to the
instant motion which was served on June 16, 2000 have been
received by the Court."
11. The Petitioner had from no later than May 30, 2000
until July 23, 2000, ALMOST EIGHT WEEKS to respond
somehow and perhaps explain why she would not come to the
deposition or even to claim not to have been served and she
did not do so. Yet the Judge clearly looks for ways to excuse
her from having to reveal the facts via oral deposition.
12. It is particularly disturbing that the judge looks for
defects in my affidavits of service to the Petitioner. As the
judge stated in her decision dated June 26, 2000, she reviewed
"the file in this matter" (as opposed to the record on the
particular motion pertaining to her decision) [EXHIBIT 2].
She would have then been quite aware of the highly defective
proofs of service presented to the court by the Petitioner in
the past, hand written, without the proper format, not
notarized and, in one instance I received the copy of such a
document in the same envelope as the Petitioner's pleading,
the one that the document stated was served on me. Not once
were these highly defective documents questioned by any
Family Court judges. What is good for the goose is apparently
not good for the gander.
13. In her decision dated March 7, 2000, Judge DiFiore
again misrepresented what is stated in my pleadings. She
stated that "and contrary to Petitioner's assertion, the
assignment of counsel was not required in relation to the
support proceeding in absence of an allegation of willful
violation . . ." [EXHIBIT 3]
14. Nowhere in my pleading in that matter did I ever
mention that assignment of counsel was required in relation to
the support proceeding. Following are the passages where
"assigned counsel" is mentioned in my document, clearly not
pertaining to assignment of counsel in the support proceeding.
The first describes how my daughter and I were separated by
the disgraced formerly Hon. Ingrid Braslow.
We [my daughter and I] were separated without a hearing,
without representation and without being told that I was
entitled to counsel as required by law, by a vicious
feminocracy that has been operating in Westchester Family
Court and whose misdeeds are, in part, described below, and
which have resulted in the forced resignation in midterm of
Judge Ingrid S. Braslow, Mary Chapiak and two attorneys,
with others to follow.
15. The second passage describes the illegal manner in
which the existing order was obtained and states that the
supervising judge Joan Cooney abused her authority when she
denied me counsel when I was so entitled (see chronology
below for details).
The above mentioned support order was obtained via perjury
and judicial irregularities perpetrated by the Respondent, her
unscrupulous attorneys, Judge Braslow and her cohorts in
Westchester Family Court, including the supervising judge,
Joan Cooney, who abused her authority in making irregular
judicial assignments to favor the Respondent and denying me
counsel when I was so entitled.
16. The judge's misquoting of my pleadings is not just
overreaching but a deliberate attempt to prejudice my case and
to deny me justice. Having engaged in this tactic, the Hon.
Janet DiFiore must recuse herself from this case.
17. In the judge's decision and order dated June 26, she
dismissed my motion to recuse herself, again with the help of
maneuvering. She stated that my motion "was made returnable
on June 15, 2000, totally ignoring the required minimum
notice to the opposing party of at least eight days."
18. What the judge failed to note here is that the proceeding
was scheduled for that same day, June 15, 2000 and that,
obviously in order to cause this problem, the judge herself, on
her own motion chose to adjourn that proceeding, while
knowing that both parties where present outside the court
room and ready to proceed, and that neither of the parties
requested an adjournment. Obviously, this motion was
intended for presentation in the court room and the judge
chose to make that impossible.
19. After I was told by the chief clerk of the Family Court
that the Judge adjourned the proceeding, I immediately came
home and I sent a fax to the judge asking for a written
decision of the adjournment, as I am entitled by law.
According to the judge's staff, including Ms. Greene, the fax
was received and given to the judge, yet to this day I have not
received a written order of the adjournment as required by
law. [EXHIBIT 6]
20. In the same order dated June 26, 2000, also denied the
application "on the merits" saying that "the affidavit in
support of the motion contains a long history of attacks on
various judges without giving any specific reason why this
particular court should recuse herself." This is a deliberate
and malicious misrepresentation of my affidavit which, at the
top contained the following headings, each one expounded in
detail in my affidavit [EXHIBIT 11].
- IRREGULAR ASSIGNMENT OF THE JUDGE
- THE PRESENT JUDGE SHOULD NOT HANDLE THIS CASE WHILE
ARTICLE 78 CASE IS PENDING IN SUPREME COURT
- BIAS AND PREJUDICE
21. Additionally, the affidavit contained a long chronology
of the events showing that on several occasions the
supervising judge de-assigned judges who did not recuse
themselves, when their decisions were less than sympathetic to
the Petitioner.
22. It takes more than a great deal of imagination to
misrepresent the above contents of my affidavit as "attacks on
various judges" or "without giving any specific reason why
this particular court should recuse herself."
23. In the decision dated March 7, 2000 Judge DiFiore states
that my motion "simply indicates petitioner's version of the
chronology of the case and contains an expressed preference
of the Petitioner to have a male judge preside over the
matter." This is yet another blatant misrepresentation of my
written statements.
24. Although chances are that a male judge would be
unlikely to display a maniacal bias against male parties,
nowhere does my motion contain an expressed preference for
a male judge. I am appalled by this judge's persistent
tendency to put words in my mouth so as to justify adverse
decisions.
25. In a decision and order dated July 13, 2000 [EXHIBIT
5], Judge DiFiore stated that my Motion to Dismiss the instant
petition [EXHIBIT 13] was "for failure to state a cause of
action pursuant to PCLR 3211(a)(7)" and the rest of the
decision and order consists of excruciatingly technical
arguments why there is sufficient cause of action not to
dismiss it.
26. The above constitutes a gross misrepresentation of my
motion to dismiss, as follows.
27. First of all, my motion to dismiss stated six separate
reasons, described under separate headings in my affidavit in
support:
I. PETITIONER'S PREVIOUS FILINGS OF MODIFICATION PETITIONS
WERE DISMISSED "WITH PREJUDICE"
II. PETITIONER'S FORUM SHOPPING
III. PETITIONER PETITION IS YET ANOTHER ONE IN A LONG SERIES
INTENDED TO HARRASS ME AND TO EXCLUDE ME FROM THE LIFE
OF MY BELOVED CHILD
IV. THE PETITIONER'S PETITION CONTRADICTS STATEMENTS THAT
SHE MADE IN FAMILY COURT UNDER OATH.
V. TWO JUDGES HAVE ALREADY REFUSED THE PETITIONER'S
REQUEST TO CHANGE THE TIME AND VENUE
OF THE VISITATION EXCHANGE.
VI. THE PETITIONER'S PETITION DOES NOT SHOW A CHANGE OF CIRCUMSTANCES.
28. The judge in this instance pretended that the first five
reasons listed for dismissing the Petitioner's petition were not
there, and just focused on reason number six. It is highly
prejudicial that this judge chose to ignore the first five main
reasons that I cited for dismissal of the present petition and
chose to deny my motion "in its entirety" on the merits of just
the last one.
29. Additionally, as in the other decision issued on July 13,
2000 [EXHIBIT 1], judge DeFiore, while being aware that
my motions were returnable on June 15, 2000, the day of the
scheduled proceeding, and while being aware that the
Petitioner and I were both present and awaiting to be called
into the court room for the proceeding on that day, chose to
adjourn the proceeding so as to rule on my motions without
an opportunity for the Petitioner to respond to my motions in
the court room or any oral statements on my part. The
Petitioner could have easily stated to the judge in the court
room that she was served with the documents whose service
now the judge gave herself the opportunity to challenge. As
noted above, Judge DiFiore has yet to produce a written
decision of the adjournment, which I requested on June 16,
2000. [EXHIBIT 6]
30. Regarding the cause of action aspect of the judge's
decision, it is amazing to see how this matter is treated in
contrast to the petition that I submitted in April 1998 with a
nine page affidavit showing the demise of my daughter in the
hands of her psychopathic mother following my daughter's
forced separation from me (by Braslow, in without a hearing,
without representation, without her stating my right to be
represented as required by law, without a cause and in
violation of UCCJA) [EXHIBIT 14, notirized original is in
Family Court File]. The evidence in terms of severe damage
inflicted on my child's brain, her motor skills, her eyes, her
digestive system, her skin and her intellectual abilities, not to
mention the psychological ravaging and the emergency
hospitalizations, was supported with volumes of
documentation, consisting of 25 exhibits, primarily from
medical and educational providers. These providers, as noted
on that petition, were the mother's providers, so, there was no
possibility of bias here.
31. While the formerly Hon. Braslow dismissed my petition
with the volumes of evidence regarding the hideous damaging
of a child as not showing a cause for action, without the
mother moving for such dismissal, the mother's one-sentence
petition for change of venue is treated as showing ample cause
for action, even though I supplied several reasons for the
court to dismiss it.
32. The stark contrast of the treatment of father and mother
in this case by Westchester Family Court does not only show
the callous disregard for the welfare of children (we can keep
pretending that we don't know why America's children shoot
each other or how this society has become a crime and drug
infested fatherless bordello) but also the malicious bias that
emanates from what amounts to a father bashing and child
destroying feministic Mafia operating out of Westchester
Family Court.
33. As previously noted, this mentality is rooted in
indoctrination by the so called battered women's movement,
whereby judges partake of "training" that teaches them that
men are villains by nature, that all women must always be
presumed credible and that men must pay a historical debt
because the Americans' supposedly vicious male ancestors
mistreated their apparently not very smart wives; that they
must act regardless of the law and with no regard to the
constitutional rights of men, because, after all, the US
constitution was written by men. Furthermore, they proclaim
that women have justification to kill men and that men must
have something to do with mothers killing their own babies
(in most actual cases the fathers were not even aware of the
prospective child).
34. This is no historical debt collection, but a malicious shake
down by a deadly feminist cult acting as loan sharks, who
stop at nothing, including the destruction of their own
children, in their pursuit of male victims.
35. The above is what I was "taught" by the so called
battered women's movement in a "batterers class" to which
Braslow sentenced me after a kangaroo style trial, whereby at
no time was I ever accused of battery, any violence or fear of
violence whatsoever. It was that feminocratic judge's last
"zing" before getting off the bench in disgrace; my
punishment for exposing her fascist tactics and for justly
forcing her sudden resignation in mid term.
36. Following my description of the goings on in that
"batterers class" and investigation by the county, the
"instructors" and their feministic outfit were ejected by the
commissioner.
37. The present judge has apparently partaken of the
"training" offered by these misandrous baby-killers which
teaches that judges must disregard laws in order to help
women and that to dish out injustice to men is ok, because
someone has to pay the price for alleged historical inequity. It
is illegal for judges to act in this manner and one more reason
why the present judge must recuse herself.
38. The present judge is continuing to act in the manner of
the disgraced formerly Hon. Ingrid Braslow, her resigned law
clerk and former judge Mary Chapiak, the resigned
unscrupulous lawyers assigned by Braslow to defend the
Petitioner, and the now expelled "batterers" cult.
39. In a decision and order dated March 7, 2000, the judge
states that "The Affidavit of Service was sworn to on
February 16, 2000, but gives no date with respect to when
service by mail was performed." [EXHIBIT 4] Well, apart
from the fact that the Petitioner's past proofs of service were
severely defective and yet no Family Court judge ever raised
the issue, quite logically the documents that I said were served
would have been served on or before the date of the affidavit,
in compliance with the time requirements.
40. Further, the judge stated that "While the motion seeks
recusal of 'the judge', it is not addressed to any particular
judge." OK, to which judge would the docket number and this
matter pertain? So, Judge Janet DiFiore issued the decision in
which she said that she did not know which judge I was
asking to decide.
41. Again my motions specifically gave Judge Janet
DiFiore's previous decision as a reason for the recusal (which
judge?) as well as the irregular assignment of this case to her,
Judge Janet DiFiore, yet judge DiFiore stated in her decision
that my motion "is totally devoid of any reason why this court
should recuse itself."
42. As noted in my previous motion for recusal of the
judge, the Hon. Janet DiFiore made presumptions and
blatantly accused me of lying and cheating in my taxes with
no proof or even the slightest notion of my business, but by
speculating that ".. $20,000.00 in cost of goods sold and
$16,237.00 in office expenses, are inconsistent with Mr.
Coutsoukis' assertion that he works from home .." My
income was not questioned by the Hearing Examiner, and no
such issue was ever raised by the other side, or by me in my
Objections.
43. To be looking for issues not raised by the parties,
particularly in such a speculative fashion, so as to discredit a
male party is arbitrary and capricious and it constitutes abuse
of discretion by the judge.
44. Assignment of the present judge was made by Judge
Joan O. Cooney, supervising judge in Family Court, who has
taken the case from other judges whenever a judge appeared
less than sympathetic to the other side and she purposely
superseded the normal procedure for the assignment of judges
so as to deny me justice in Family Court, as follows.
45. Following is a chronological table that more clearly
shows what I am talking about.
46. CHRONOLOGY
April 1999 The formerly Hon. Ingrid S. Braslow issues a
Decision and Order, post-dated to April 28, 1998, recusing
herself from the case initiated by my former wife Susan
Samora. Susan fled Oregon in the midst of divorce
proceedings and a Court ordered psychological evaluation.
April 1999 Hon. Joan Cooney colludes with Braslow
(resigned following my presentation of audio evidence of
irregularities), Braslow's clerk, Mary Chapiak (also resigned)
and the two attorneys assigned by Braslow (both resigned as
well) to cover up improper activities on the part of Braslow,
Chapiak and the two attorneys, including violation of the
rules, perjury and transcript manipulation.
May 1999 Supervising Judge Cooney overrules normal
computerized procedure for random selection of the Judge in
my case and assigns the case to herself.
May 18, 1999 Cooney issues a Decision and Order
recusing herself from the case, stating "something" said to her
by the Administrative Judge as the reason. I have no clue of
why she recused herself.
Cooney again overrules the normal procedure and reassigns
my case to Judge John Sweeny of Putnam County.
In this manner she also gave an excuse to Braslow's
assigned attorneys to resign from the case, in a manner that
was explicitly condemned subsequently by Judge Sweeny.
June 1999 Over my persistent protestations, Cooney
withholds my Family Court file in her chambers causing
delays in my preparation of an appellate brief and in my case
scheduled to be heard now in Putnam County.
A month passes without my order to show cause being
shown to a judge (that's irregular).
June 22, 1999 Judge John W. Sweeney of Putnam
County, acting as a Westchester Family Court judge, holds a
preliminary proceeding in Putnam County courthouse.
During the proceeding, Judge Sweeney receives a call
from Cooney's chambers authorizing assigned counsel for me,
on the basis of financial disclosure documents that were
already present in my file, and for months preceding her
refusal to do so.
The file available to Judge Sweeney during that
proceeding was inadequate, Cooney having withheld
documents in her chambers.
During the proceeding, Judge Sweeney unambiguously
characterized the resignation of the two assigned lawyers as
irregular and stated that parties are welcome to one of them,
the law guardian, as a witness.
November 3, 1999 Cooney assigns my case to Judge Sandra
Edlitz in Yonkers.
This assignment was done following the June hearing in
Putnam which showed that Judge Sweeney did not express
any sympathy for the other side and also expressed sympathy
for my case and explicitly condemned the resignations of the
lawyers assigned by Braslow, whose misdeeds the resignations
where intended to cover up and which were facilitated by
Cooney's re-assignment of the case to Putnam. The
subsequent re-assignment to Yonkers was made by Cooney
without Judge Sweeny recusing himself and prior to his
issuing an order.
Cooney again took matters into her own hands, overruled the
normal procedure and unilaterally assigned my case to Judge
Sandra Edlitz in Yonkers.
So, my case, which belonged in White Plains, was thrown to
Putnam and Yonkers, all to facilitate the other side's forum
shopping.
November 25, 1999 Judge Sweeney (from Putnam County)
issues an Order Enforcing Visitation.
December 3, 1999 Judge Edlitz conducts a hearing in Yonkers
without the parties, having informed them in advance that
their presence would not be needed.
December 16, 1999 Judge Edlitz issues a Decision and Order
dismissing the other side's petition "with prejudice".
With Edlitz also not showing sympathy for the other
side, and without her having recused herself, Cooney yet
again took matters into her own hands, removed the case from
Judge Edlitz, overruled the normal procedure and manually
assigned the case to yet another judge, the present one, still
deliberately excluding the only male judge in White Plains
Family Court, so as to facilitate the other side's forum
shopping.
47. It is evident that Joan Cooney, who has abused
administrative authority in order to pursue her and Braslow's
political agenda, will not be satisfied until every possibility of
fairness is removed from my case; until she is sure of finding
another Braslow who will make me go away or put me in jail,
so as to cover up the irregularities that were perpetrated in my
case by her, the resigned judge Braslow, her resigned law
clerk and her two assigned attorneys who resigned in an
irregular fashion, one of them twice.
48. Following the recent judicial assignment I filed a
Petition in Supreme Court for relief by certiorari under
Article 78 requesting that the Supreme Court overrule the
current assignment of the case to the present judge. Judge
Franco of Nassau County Supreme Court ruled that my
petition should be submitted to the Appellate Division instead,
because of Judge Nicolai's status as a Supreme Court judge.
An original petition (i.e., not an appeal) was submitted to the
Appellate Division and the matter is now pending. It would be
inappropriate for the present judge to handle this case before
the Article 78 complaint is resolved.
49. While waiting to be called into the court room for the
scheduled proceeding on this matter on June 15, 2000, the
Petitioner and I were informed by the chief clerk of the
Family Court that judge Janet DiFiore had moved to adjourn
the proceeding and we were told that the proceeding was now
scheduled for July 14, 2000.
50. On July 12 and 13, 2000 I called the Family Court and I
was told that the proceeding was adjourned to July 27th. I
was not given any explanation for this change even though I
asked. I was told that "there is nothing on July 14th".
51. It appears that the adjournment was yet another
maneuver by the judge, this time to enable her to issue the
above mentioned orders dated July 13, 2000, the day before
the scheduled court appearance, so as to avoid the presence of
the parties prior to those decisions. During an appearance the
Petitioner could very well have stated that she was served
with my pleadings and I would have had an opportunity to
mention items that the judge completely ignored in her
decisions, such as the numerous reasons for her recusal and
the numerous reasons for dismissing the Petitioner's petition.
52. The present judge has already exhibited bias and
prejudice in a decision dated March 7, 2000 under Docket #
X-00284/F-1190-00.
53. In that case I had filed objections to a decision by the
hearing examiner Esther R. Furman entered March 24, 2000
(in her decision, the Hon. Janet DiFiore erroneously states the
date of that order as "March 24, 1999" [sic]).
54. The judge did not address any of my objections, which
included that the amount of child support is and has always
been out of proportion to my income; that the hearing
examiner ignored my numerous statements under oath and
written statements entered into the record during the hearing;
the hearing examiner's misleading inclusion of my company's
gross sales as my annual income; that I did not offer "proof"
of projected 1999 income when such proof was not requested
and there is no proof of income in a year not yet finished
anyway; that I should have presented documentation that I
was prevented from working full time, when I had already
stated under oath that I worked no less than 70 hours per
week; she accused me of failing to obtain proper employment,
meaning that operating my own company does not constitute
proper employment.
55. While not addressing my objections as she should, the
present judge made fallacious, misleading and inappropriate
"findings" of her own, apparently so as to make up for the
nonsense in Esther Furman's decision.
56. She stated that "During the hearing of this matter
Petitioner acknowledged that during his former employment
he earned approximately $80,000", without this judge
mentioning that that was ten years ago.
57. The present judge then goes into an IRSque mode of
stating, with no documentation or knowledge of my business,
that "$20,000.00 in cost of goods sold and $16,237.00 in
office expenses are inconsistent with Mr. Coutsoukis'
assertion that he works from home.."
58. Apart from the plain ignorance of my business (or any
business for that matter) and the stupidity of stating that my
numbers are inconsistent (in fact, my Internet based home
business incurred enormous office expenses that included over
$10,000.00 in telephone expenses and over $6,000.00 in
Internet expenses; and the $20,000.00 in cost of goods sold is
actually very small in proportion to gross sales by most
standards and attributed to the software component of my
company's sales, which has a huge gross margin), this judge
is clearly implying that I lied in stating the figures of my
business operation. And that in spite of the fact that I made
her aware that the other side had my tax return audited by the
IRS, to no effect.
59. In terms of this judge's presumption of me as a liar and
a tax cheat, I am not surprised to find that the formerly Hon.
Ingrid Braslow's shoes are now filled by someone straight out
of the same father-bashing and child-destroying feministic cult
that has turned American society into a crime- and drug-
infested fatherless bordello.
60. That cult, which teaches that men are villains by nature
and that women are victims whose perceptions constitute
reality, among other such propaganda, has been indoctrinating
judges, such as Braslow, who then went on to proclaim the
message herself (see attachment 1).
61. On the basis of this virulently militant feministic
mentality, Braslow presumed the other side's false accusations
as reality while refusing to allow evidence which clearly
showed that I was innocent. For example, while the other side
accused me of sending her a fax late at night ("after 9:00
PM"), the telephone company records that I subpoenaed
(Braslow signed the subpoena) show that my fax was a reply
to hers, following her calls to my fax number four times on
that day, beginning at 10:42 PM (see attachment 2).
62. So, even as Braslow was on her way out of the judiciary
and on her way to Arizona out of the reach of New York
justice, she falsely and maliciously found me guilty of
harassment and sentenced me to a batterers class, even though
no accusations of any violence or fear of violence were made
by the other side.
63. In the process of serving that sentence I became aware
of the above mentioned feministic cult, in the so called
batterers class, populated entirely by minority men, most of
them sentenced by Braslow, and conducted by a man-hating
butch lesbian and her associates who were ejected and their
feministic outfit's contract terminated by the county following
my strong objections to the commissioner (see EXHIBIT 10).
64. It is quite evident that the present judge has no intention
of rendering impartial justice, but she intends to perpetuate
the feminocratic atrocities committed against me and against
my innocent infant child, who was abducted, beaten, tortured,
starved, raped, brain damaged, poisoned and crippled for life
(see EXHIBIT 7, photo of severe burns in Teddy's anal area
and EXHIBIT 8 and EXHIBIT 9, audio files of Teddy's
screams under abuse) by a psychopathic mother and her
barbaric cohorts, including sleazy now resigned lawyers and a
corrupt now resigned feminist judge.
Dated: --------_____________________________
________________________
Petitioner
Sworn before me this _______ day of ________________,
2000
___________________________________
NOTARY PUBLIC FOR NEW YORK
My commission expires:
o O o