A car parked in a parking lot

Description generated with high confidence

 

Home

 

Chapter 1: Forward: Babylonian Talmudic Hatred of Humans -- Are You a Victim of the Worship of Molech

 

 

Chapter 2: Come and Hear:  America’s New Government Church – Death for Christians

 

 

Chapter 3: Come and Hear: Sex with Children by Talmud Rules

 

 

Chapter 4: Come and Hear: Human Sacrifice, the Talmud, and the Moloch Problem

 

 

Chapter 5: United States v. Uzamere

 

Chapter 6: Uzamere v. Various Ashkenazi Leaders and Ashkenazi Judaism as a Hate Group

 

Chapter 7: Chapters of the Original Website

 

Chapter 8: Once Upon a Time

 

Chapter 9: Victim's Statement

 

Chapter 10: My Search for Justice

 

Chapter 11: Descentinto Hell

 

Chapter 12: U.S. Laws Violated by Senator Uzamere

 

 

Chapter 13: Nigerian Laws Violated by Senator Uzamere

 

 

Chapter 14: Ignored by Federal Agencies

 

Chapter 15: Ignored by Nigerian Authorities

 

Chapter 16: Victims' Loss of Child Support

 

Chapter 17: The Uzamere Family

 

Chapter 18: Municipal Employees Who Helped Senator Uzamere

 

Chapter 19: John Gray and Non-Profit Legal Community

 

Chapter 20: Hall of Shame

 

Chapter 21: 1st Judicial Blow by African-American Judge Thomas

 

Chapter 22: Law Firm of Allen E. Kaye

 

Chapter 23: Too Many Discrepancies...

 

Chapter 24: Allen E. Kaye and His Diabolical Talmud-Following Minions

 

Chapter 25: Will Sampson Staff Refuse to Help Identity Fraud Victims?

 

Chapter 26:  Law Office of Gladstein and Messinger

 

Chapter 27: Patrick Synmoie's Attempts to Hide

 

Chapter 28: Consulate General of Nigeria

 

Chapter 29: Strange Chat with Senator Ekweremadu

 

Chapter 30: Proof of Legal Marriage

 

Chapter 31: Proof of Illegal Marriage/Identity Fraud

 

Chapter 32: Senator Uzamere's Attempts to Hide Crimes Will Fail

 

Chapter 33: The Proof...

 

Chapter 34: Success -- The Proof Is Finally Here!

 

Chapter 35: Will Senator Uzamere Evade Child Support Again?

 

Chapter 36: Nigeria's New Commitment to Protect Child Abandoned by Sen. Uzamere

 

Chapter 37: Judge Prus -- What Gives?

 

Chapter 38: Back on Track!

 

Chapter 39: Eugene Uzamere -- Third Attorney to Break the Law

 

Chapter 40: Petitioner's Verified Petition

 

Chapter 41: Supplemental Verified Petition

 

Chapter 42: Judge Prus Recuses Himself

 

Chapter 43: Eugene's Failed Attempt to Thwart Justice

 

Chapter 44: Kate Ezomo -- Diabolical Liar

 

Chapter 45: Letters of Complaint Against Kate Ezomo

 

Chapter 46: My Factual Response to Imaginary Cousin Godwin

 

Chapter 47: Federal Action Against Defendant Dismissed

 

Chapter 48: Open Letters to the FBI

 

Chapter 49: Open Letter to All U.S. Judges

 

Chapter 50: Open Letter to Ehigie and Eugene

 

Chapter 51: Tara's Affidavit

 

Chapter 52: $100,000,000.00 Lawsuit Against Corrupt Fiduciaries

 

Chapter 53: Will Fiduciaries Settle?

 

Chapter 54: New York City Defrauds Disabled Schvartze

 

Chapter 55: There Is No Cousin Godwin!

 

Chapter 56: Warning Letter to Governor and Chief Justice of New York State

 

Chapter 57: Deprived of Child Support by Allen Kaye

 

Chapter 58: Caninternational Agency Help?

 

Chapter 59: Chief Judge Wood's Court

 

Chapter 60: Will NYS' Dept. Disc. Committee and Commission on Judicial Conduct Be Corrupted?

 

Chapter 61: Subpoena Planned for Judge Garaufis

 

Chapter 62: No Negotiations for Justice...Justice is Owed!

 

Chapter 63: Will Attorneys Sign Affirmation?

 

Chapter 64: Am I Finally Being Taken Seriously?

 

Chapter 65: Evidentiary Hearing is Scheduled!

 

Chapter 66: Amy Feinstein Refuses to Prosecute!

 

Chapter 67: Robert Juceam's Useless Excuses

 

Chapter 68: No Justice -- No Peace!

 

Chapter 69: Happy Birthday My Beautiful Angel

 

Chapter 70: Are You a Victim of a Green Card Marriage Scam?

 

Chapter 71: End Green Card Marriage Sponsorship

 

Chapter 72: How to Report an Immigration Scammer and the Attorney

 

Chapter 73: Is the End Finallyin Sight?

 

Chapter 74: Will Appellate Division Justices Decide Fairly?

 

Chapter 75: What Will NYSCJC's Response Be?

 

Chapter 76: How Will NYSDDC Respond?

 

Chapter 77: Will Obama's Administration Coerce Helpless Schvartze's Silence

 

Chapter 78: Will U.S. Department of State's Secretary Rise to The Challenge?

 

Chapter 79: Eugene Uzamere Calls It Quits

 

Chapter 80: Bigot Judge Sunshine Continues Courtroom Corruption

 

Chapter 81: Schvartze's Complaints Still Ignored by Appellate Division's White Judiciary

 

Chapter 82: More Talmudic Bias and Anti-Schvartze Racism At SDNY

 

Chapter 83: Senator Uzamere...You Are the Husband!

 

Chapter 84: Will U.S. Solicitor General Office Look on Idly?

 

Chapter 85: What will SCOTUS Do?

 

Chapter 86: Why did they disobey?

 

Chapter 87: Cabranes' Fraud Upon the Court

 

Chapter 88: Is Hinds-Radix Their 'Secret' Weapon?

 

Chapter 89: New York State Lawsuit for Fraud

 

Chapter 90: Judge Sunshine Is a Loser

 

Chapter 91: Judge Sunshine Out of Options

 

Chapter 92: Petitioner Prepares Request for Rehearing

 

Chapter 93: Petition for Rehearing

 

Chapter 94: Loser Sunshine's Last Hurrah

 

Chapter 95: Lawsuit Against Daily News and Scott Shifrel

 

Chapter 96: Mort Zuckerman's Bigoted Tabloid

 

Chapter 97: Corruption at Nassau County Supreme Court and Nassau County Clerk

 

Chapter 98: Judge Scuccimarra Ruling

 

Chapter 99: Defendants Have Defaulted

 

Chapter 100: Judge Parga Accepts Anne Carroll's Drivel

 

Chapter 101: New York Daily News and Anne B. Carroll

 

Chapter 102: Lawsuit Against President

 

Chapter 103: Will Obama Listen?

 

Chapter 104: Open Letter to Al Jazeera, President Obama and Judge Allegra

 

Chapter 105: More Court Shenanigans

 

Chapter 106: Molech-Fomented Anti-Black Racism at Howard University

 

Chapter 107: into the fire...

 

Chapter 108: What Will The New York State Division of Human Rights Do?

 

Chapter 109: Housing Court Corruption

 

Chapter 110: Mayor Bloomberg's Finest

 

Chapter 111: FEGSin Criminal Conspiracy

 

Chapter 112: FEGS Gave Victim No Choice

 

Chapter 113: What Will The New York State Supreme Court Do?

 

Chapter 114: What Will Court of Claims Do?

 

Chapter 115: Molech-Worshipers’ Abuse of Religion Not New

 

Chapter 116: How Wicked Are They?

 

Chapter 117: What a Bunch of Lies

 

Chapter 118: Federal Lawsuit

 

Chapter 119: Disastrous Results to Appeal

 

Chapter 120: Judge Garaufis' Discriminatory Decision

 

Chapter 121: Garaufis' Talmudic Shenanigans

 

Chapter 122: FOIA Hiding Evidence

 

Chapter 123: Congressional Testimony

 

Chapter 124: Unintelligible Complaint of Rachel G. Yohalem

 

Chapter 125: Uzamere v. USA

 

Chapter 126: Judicial Whores Willy and Patty

 

Chapter 127: Find an Unbiased Court

 

Chapter 128: U.S. Government Blacklists Own Citizens

 

Chapter 129: Appellate Brief First Circuit

 

Chapter 130: U.S. Government Hides Prosecution

 

Chapter 131: A Molech-Fomented RICO

 

Chapter 132: Molech-Fomented Doctrine -- Law of the Moser

 

Chapter 133: Will African American Victim of Grand Larceny Receive Justice?

 

Chapter 134: Judicial Ethics Hypocrite

 

Chapter 135: Molech-Fomented Shenanigansinvolvedin Random Selection of Morally Compromised Judge

 

 

Chapter 136: Please save my family!

 

Chapter 137: Psychopathic Defendants

 

Chapter 138: Molech-Fomented Paradigm Puts Molech Worshipersin Positions of Power

 

 

Chapter 139: Pretender Bharara

 

Chapter 140:international Lawsuit against Israel, the United States and Nigeria

 

 

Chapter 141: A Real Man

 

A close up of a mans face

Description generated with very high confidence

 

Both of My Children Were Molested in Foster Care. Member of the Democratic Party Have Ganged up on My Family to Stop Us from Telling Our Story.

A person smiling for the camera

Description generated with high confidenceA person smiling for the camera

Description generated with very high confidence

My Son David Describes an incident Where He Was Sexually Accosted While He Was Living in Democrat-Ashkenazi-Jew-Run Foster Care Group Home

A screenshot of a cell phone

Description generated with very high confidence

Proof that Ehigie Edobor Uzamere Was Still Married to Me at the Time that He Celebrated his 25th Wedding Anniversary with 2nd Wife Iriagbonse Irowa.

 

Federal Law Enforcement Visits My Apartment Without Warrants to Kill Me and Take My Computer Under the Guise of “Counterterrorism.”

Telephone Call with Verizon Employees Who Confirm that Verizon Violated NACHA and EFTA Rules by Taking Money from My Paid Telephone Bill and Sending it to Metavante Corporation 18 Days after I Paid the Bill

Proof that Verizon’s Telephone Service Was Off by February 3, 2018

 

Problems with Social Security Administration: Proof that the Social Security Administration Sent Two Test Checks to Confirm the Existence of my Paypal Prepaid Account

Problems with the Social Security Administration: Proof that the Social Security Administration Illegally Held my SSDI Check

 

 

 

·         Bridgette Davis’ False Allegation that I Threatened Federal Employees

 

·         Conversation with CMS that Proves that I Did Not Threaten Anyone

 

·         FBI’s Implied Threat to Put Me in a Mental Institution

 

    

The Crimes of Senator Ehigie Edobor Uzamere

 

 

 

 

 

 

 

 

 

 

 

 

 

 

CHERYL D. UZAMERE

APPEARING PRO SE

Cheryl D. Uzamere

1209 Loring Avenue

Apt. 6B

Brooklyn, NY 11208

Tel.: (718) 233-4386

Fax: (347) 365-7198

E-mail: cuzamere@netzero.net  

 

 

UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT of NEW YORK

 

(under construction – to be completed within the next few days)

 

 

 

 

 

CHERYL D. UZAMERE, on Her Own Behalf,

 

            - against -

 

VARIOUS ASHKENAZI JEWISH LEADERS, AND ASHKENAZI JUDAISM AS A HATE GROUP UNDER THE FIGHTING WORDS DOCTRINE;

 

DECLARATORY AND INJUNCTIVE RELIEF ONLY:

 

UNITED STATES DEPARTMENT OF JUSTICE;

 

FEDERAL TORT CLAIMS ACT/DECLARATORY AND INJUNCTIVE RELIEF:

 

UNITED STATES DEPARTMENT OF THE TREASURY; UNITED STATES DEPARTMENT OF HOMELAND SECURITY; UNITED STATES DEPARTMENT OF EDUCATION; UNITED STATES DEPARTMENT OF HEALTH AND HUMAN SERVICES; NATIONAL CREDIT UNION ASSOCIATION; SOCIAL SECURITY ADMINISTRATION; EQUAL EMPLOYMENT OPPORTUNITY COMMISSION; NATIONAL CREDIT UNION ASSOCIATION;

 

DEMOCRATIC NATIONAL COMMITTEE:

 

U.S. DEPARTMENT OF HOMELAND SECURITY:

 

Rachel McCarthy, Former Bar Counsel, U.S. Department of Immigration and Citizenship Service, U.S. Department of Homeland Security; Officer Barnes, Shield 345, Federal Protective Service, U.S. Department of Homeland Security; D. Gregg, Shield 298, Federal Protective Services, U.S. Department of Homeland Security; Unknown Officer, Federal Protective Service (as of January 3, 2018), U.S. Department of Homeland Security; Unknown Officer, Federal Protective Service (As of August 2004), Federal Protective Service, U.S. Department of Homeland Security; “John Doe” #1, individually and in His Official Capacity as a Government Law Enforcement Officer For Unknown Governmental Agency Based On Youtube Video https://Youtu.Be/Jefbwolohmu;        “John Doe” #2, Individually and in His Official Capacity as A Government Law Enforcement Officer For Unknown Governmental Agency Based On Youtube Video https://Youtu.Be/Jefbwolohmu            “John Doe” #3, Individually and in His Official Capacity as a Government Law Enforcement Officer For Unknown Governmental Agency Based On Youtube Video https://Youtu.Be/Jefbwolohmu; “John Doe” #4, Individually and in His Official Capacity as a Government Law Enforcement Officer For Unknown Governmental Agency Based On Youtube Video https://Youtu.Be/Jefbwolohmu;  “John Doe” #5, Individually and in His Official Capacity as a Government Law Enforcement Officer For Unknown Governmental Agency Based On Youtube Video https://Youtu.Be/Jefbwolohmu;          “John Doe” #6, Individually and in His Official Capacity as a Government Law Enforcement Officer For Unknown Governmental Agency Based On Youtube Video https://Youtu.Be/Jefbwolohmu;           “John Doe” #7, Individually and in His Official Capacity as a Government Law Enforcement Officer For Unknown Governmental Agency Based On Youtube Video https://Youtu.Be/Jefbwolohmu;           Capacity as a Government Law Enforcement Officer For Unknown Governmental Agency Based On Youtube Video https://Youtu.Be/Jefbwolohmu;          “John Doe” #8, Individually and in His Official Capacity as a Government Law Enforcement Officer For Unknown Governmental Agency Based On Youtube Video https://Youtu.Be/Jefbwolohmu; 

 

U.S. Department of the Treasury:

 

Steven Mnuchin, Individually and His Official Capacity as Secretary For The U.S. Department of The Treasury; Cynthia Sydmor-Jones, Individually and in Her Official Capacity as Co-Disclosure Officer, Freedom of Information and Privacy Requests, U.S. Department of The Treasury; “John/Jane Doe” #1, in His/Her Official Capacity as Call Center Operator For The Bureau of The Fiscal Service, U.S. Department of The Treasury; “John/Jane Doe” #2, in His/Her Official Capacity as Call Center Operator For The Bureau of The Fiscal Service, U.S. Department of The Treasury; “John/Jane Doe” #3, in His/Her Official Capacity as Call Center Operator For The Bureau of The Fiscal Service, U.S. Department of The Treasury; “John/Jane Doe” #4, in His/Her Official Capacity as Call Center Operator For The Bureau of The Fiscal Service;

 

Social Security Administration:

 

Nancy A. Berryhill, in Her Official Capacity as Commissioner for The Social Security Administration; Asheesh Agarwal, Individually and in His Official Capacity as General Counsel for the Social Security Administration; “John/Jane Doe” #1, in His/Her Official Capacity as Call Center Operator For “John/Jane Doe” #1, Individually and in His/Her Official Capacity as Call Center Operator For The Social Security Administration; “John/Jane Doe” #2, Individually and in His/Her Official Capacity as Call Center Operator For The Social Security Administration; “John/Jane Doe” #3, Individually and in His/Her Official Capacity as Call Center Operator For The Social Security Administration; “John/Jane Doe” #4, Individually and in His/Her Official Capacity as Call Center Operator For The Social Security Administration; “John/Jane Doe” #5, Individually and in His/Her Official Capacity as Call Center Operator For The Social Security Administration; “John/Jane Doe” #6, Individually and in His/Her Official Capacity as Call Center Operator For The Social Security Administration; “John/Jane Doe” #7, Individually and in His/Her Official Capacity as Call Center Operator For The Social Security Administration; “John/Jane Doe” #8, Individually and in His/Her Official Capacity as Call Center Operator For The Social Security Administration; J. Mark Mcwatters, Commissioner For The National Credit Union Administration; Alex Azar, Secretary For The U.S. Department of Health and Human Services;

 

STATE OF NEW YORK:

 

Andrew M. Cuomo, Governor;

 

NEW YORK STATE OFFICE OF THE ATTORNEY GENERAL:

 

Barbara Underwood, New York State Attorney General; “Jane Doe”, Receptionist;

 

NEW YORK STATE OFFICE OF MENTAL HEALTH:

 

Ann Marie T. Sullivan, Commissioner For The New York State Office of Mental Health; “John Doe”/“Jane Doe”, Former Commissioner For The New York State Department of Mental Health; Michael Hogan, Former Commissioner For The New York State Office of Mental Health;

 

Kingsboro Psychiatric Center:

 

Samuel Gant, Individually and in His Official Capacity as Director, ICM Program, Kingsboro Psychiatric Facility; Bridget Davis, Intensive Case Worker, Icm Program, Kingsboro Psychiatric Facility, New York State Office of Mental Health; Marie Bauduy, Individually and in Her Official Capacity as Psychiatrist, Kingsboro Psychiatric Facility, New York State Office of Mental Health; Dhananjay Bhagoji, Medical Specialist,  Kingsboro Psychiatric Facility, New York State Office of Mental Health; Luther Turner, Social Worker, Kingsboro Psychiatric Facility, New York State Office of Mental Health; Soly Jalwan, Nurse, Kingsboro Psychiatric Facility, New York State Office of Mental Health; Beatrix Mcleod, Recreation Assistant, Kingsboro Psychiatric Facility, New York State Office of Mental Health; Melissa Schorers, Licensed Psychologist, Kingsboro Psychiatric Facility, New York State Office of Mental Health; Laurie Velcime, Social Worker, Kingsboro Psychiatric Facility, New York State Office of Mental Health; Ruth O’connor Dietician, Kingsboro Psychiatric Facility, New York State Office of Mental Health; Merlene Hyppolite, Nurse, Kingsboro Psychiatric Facility, New York State Office of Mental Health;

 

NEW YORK STATE EDUCATION DEPARTMENT:

 

Maryellen Elia, Commissioner, The New York State Education Department;

 

NEW YORK STATE HIGHER SERVICES EDUCATION CORPORATION:

 

Alan M. Klinger, Individually and in His Official Capacity as Chairman of the Board;

 

NEW YORK STATE UNIFIED COURT SYSTEM:

 

Eileen A. Rakower, Individually and in Her Official Capacity as Justice For The New York State Supreme Court; Matthew D'emic, Individually and His Official Capacity as Justice For The New York State Supreme Court; Anthony Cutrona, Individually and in His Official Capacity as Justice For The New York State Supreme Court; Michael Gerstein, Individually and in His Official Capacity as Judge For The Kings County Criminal Court; Eric I. Prus, Individually and in His Official Capacity as Justice For The New York State Supreme Court; Jeffrey S. Sunshine, Individually and in His Official Capacity as Justice For The New York Supreme Court; Arthur M. Schack, Individually and in His Official Capacity as Justice For The New York State Supreme Court;

 

CITY OF NEW YORK:

 

Office of the Mayor of New York City:

 

Bill Di Blasio, Mayor, City of New York;

 

New York City Department of Law:

 

Zachary Carter; Chief Counsel, New York City Law Department;

 

NEW YORK CITY HUMAN RESOURCES ADMINISTRATION:

 

New York City Human Resources Administration:

 

Steven Banks, Individually and His/Her Official Capacity as Commissioner for The New York City Human Resources Administration – Department of Social Services;

 

New York City Human Resources Administration; Office of Adult Protective Services:

 

“John Doe”/“Jane Doe”, Individually and His/Her Official Capacity as Assistant/Deputy Commissioner, Office of Adult Protective Services, New York Human Resources Administration – Office of Social Services; Ms. Davis, Individually and in Her Official Capacity as Supervisor, Brooklyn District Office; Mr. Dicambri, Supervisor, Office of Adult Protective Services, New York Human Resources Administration – Office of Social Services; Kawane Harris, Office of Adult Protective Services, New York Human Resources Administration – Office of Social Services;

 

New York City Health and Hospital Corporation -- Bellevue Hospital and Medical Center:

 

Marcia E. Werchol, Individually and in Her Official Capacity as Psychiatrist, Family Court Mental Health Services At New York City Health and Hospitals Corporation

 

New York City Health and Hospital Corporation:

 

Woodhull Hospital and Medical Center: Agnes Flores, Individually and in His Official Capacity as Psychiatric Nurse for Woodhull Hospital; Martin Bolton, Individually and in His Official Capacity as Psychotherapist Woodhull Hospital;

 

New York City Health and Hospital Corporation -- Kings County Hospital – Act Team:

 

Dr. Scott Andrew Berger, Individually and in His Official Capacity as Psychiatrist For The Act Team For Kings County Hospital; Samuel Sarpong, Individually and in His Official Capacity as Program Manager For The Act Team For Kings County Hospital; Margaret Thomas, Individually and in Her Official Capacity as Licensed Practical Nurse For The Act Team For Kings County Hospital; Pauline Amo-Adu, Individually and in His Official Capacity as Social Worker (Unlicensed) For The Act Team For Kings County Hospital;  Mario Blake, Individually and in His Official Capacity as Psychiatric Technician For The Act Team For Kings County Hospital; James Oniwe, Individually and in His Official Capacity as Psychiatric Nurse For The Act Team For Kings County Hospital; Jean Barry, Individually and in His Official Capacity as Licensed Clinical Social Worker For The Act Team For Kings County Hospital; Hugette Guilliame Sam, Individually and in His Official Capacity as Registered Nurse For The Act Team For Kings County Hospital;

 

New York City Housing Authority:

 

Stan Brezenoff, Individually and in His Official Capacity asinterim Chair for The New York City Housing Authority; Shola Olatoye, Individually and in Her Official Capacity as Chair for The New York City Housing Authority; David Farber, Individually and in His Official Capacity as Executive Vice President and General Counsel for The New York City Housing Authority;

 

Disability Rights New York:

 

Timothy A. Clune, Esq.;individually and in His Official Capacity as Executive Director, Disability Rights New York, Inc.; Clifford Zucker, Esq.; General Counsel, Disability Rights New York, Inc.; Benjamin Thapa, Staff Attorney, Disability Rights New York, Inc.;

 

Brooklyn Defender Service:

 

Tim Gumkowski, Individually and in the Official Capacity as Attorney for The Brooklyn Defender Service; Joyce Kendrick, Esq., Lisa Schreibersdorf, Individually and in The Official Capacity as Attorney for the Brooklyn Defender Service;

 

NON-GOVERNMENTAL MENTAL HEALTH SERVICE CORPORATIONS:

 

The Joint Commission:

 

Mark R. Chassin, M.D., FACP, M.P.P., M.P.H. - President and Chief Executive Officer; David W. Baker, M.D., M.P.H., FACP - Executive Vice President, Division of Health Care Quality Evaluation; Anne Marie Benedicto, M.P.P., M.P.H. - Vice President, Joint Commission Center for Transforming Healthcare; Lynn B. Dragisic - Executive Vice President, Support Operations and Chief of Staff; Brian H. Enochs, J.D. - Executive Vice President, Business Development and Marketing; Michael W. Kaba, MBA, MS - Chief Human Resources Officer; Kin Lee, M.B.A., M.S. - Chiefinformation and Security Officer; Ana Pujols McKee, M.D. -  Executive Vice President and Chief Medical Officer; Mark G. Pelletier, R.N., M.S. - Chief Operating Officer, Accreditation and Certification Operations & Chief Nursing Executive; Paige A. Rodgers, C.P.A. - Chief Financial Officer; Margaret Van Amringe, M.H.S. - Executive Vice President, Public Policy and Government Relations; Lisa Diehl Vandecaveye, J.D., M.B.A., HRM, FACHE, General Counsel; Anne Bauer, Field Director, Hospital Accreditation, Surveyor Management and Development;

 

Federation Employment and Guidance Services:

 

Dr. Forster, In His Official Capacity as Psychiatrist of Federation Employment and Guidance Services, Inc.;

 

Mental Health Association of New York State:

 

Glenn Liebman, Chief Executive Officer, Mental Health Association of New York State; Giselle Stolper, Former Chief Executive Officer, Mental Health Association of New York State;

 

Brookdale Hospital Medical Center:

 

“John Doe” #1, Individually and in His Official Capacity as Psychiatrist For The Brookdale Hospital Medical Center; Brooklyn Hospital Medical Center; “John Doe” #2, Individually and in His Official Capacity as Psychiatrist For The Brookdale Hospital Medical Center; Brooklyn Hospital Medical Center; “John Doe” #3, Individually and in His Official Capacity as Psychiatrist For The Brookdale Hospital Medical Center; Brooklyn Hospital Medical Center; “John Doe” #4, Individually and in His Official Capacity as Psychiatrist For The Brookdale Hospital Medical Center; Brooklyn Hospital Medical Center; “Jane Doe”, Individually and in His Official Capacity as Psychiatrist For The Brookdale Hospital Medical Center; Brooklyn Hospital Medical Center;

 

CORPORATIONS:

 

Swatski Partners, Inc.

 

MG Security, Inc.:

 

MG Security, Inc.:  Manual Gomez, President, MG Security, Inc.; “John Doe” (Haitian Man), MG Security, Inc.; “Jane Doe”, (

 

National Credit Services:

 

A. H. Sarajy, President, National Credit Services, Inc.; Chris Cramer, National Credit Services, Inc.; Marsha Sarajy, Vice President, National Credit Services, Inc.

 

Affinity Federal Credit Union, Inc.:

 

John Fenton, Individually and in His Official Capacity as President and Chief Executive Officer; Affinity Federal Credit Union; Peter S. Liska, Esq., Law Offices of Peter J. Liska; Kevin Brauer, Individually and in His Official Capacity as Senior Vice President and Chief Financial Officer, Affinity Federal Credit Union; Jim Wilcox, Assistant Vice President, Risk Operations, Affinity Federal Credit Union; Maryanne Melanson, Assistant Vice President, Executive Administration and internal Communications; G. Haskell, Supervisory Committee; John/Jane Doe” #1, in His/Her Official Capacity as Call Center Operator, Affinity Federal Credit Union; John/Jane Doe” #2, in His/Her Official Capacity as Call Center Operator, Affinity Federal Credit Union; John/Jane Doe” #3, in His/Her Official Capacity as Call Center Operator, Affinity Federal Credit Union; John/Jane Doe” #4, in His/Her Official Capacity as Call Center Operator, Affinity Federal Credit Union; John/Jane Doe” #5, in His/Her Official Capacity as Call Center, Affinity Federal Credit Union; Operator John/Jane Doe” #5, in His/Her Official Capacity as Call Center Operator, Affinity Federal Credit Union; John/Jane Doe” #6, in His/Her Official Capacity as Call Center Operator John/Jane Doe” #7, in His/Her Official Capacity as Call Center Operator John/Jane Doe” #8, in His/Her Official Capacity As Call Center Operator John/Jane Doe” #9, in His/Her Official Capacity as Call Center Operator John/Jane Doe” #10, in His/Her Official Capacity as Call Center Operator;

 

Verizon, Inc.:

 

Lowell C. McAdam, Individually and in His Official Capacity as Chairman and Chief Executive Officer; Verizon, Inc.; Craig Silliman, Individually and in His Official Capacity as Executive Vice President, Public Policy and General Counsel, Verizon, Inc.; Hans Vestberg, Individually and in His Official Capacity Chief Technology Officer, Verizon, Inc.;

 

Fisglobal, Inc., (Metavante Corporation):

 

Gary Norcross, Individually and in His Official Capacity as President and Chief Executive Officer, Fisglobal, Inc.; James "Woody" Woodall, Individually and in His Official Capacity as Chief Financial Officer, Fisglobal, Inc.; Marc Mayo, Individually and in His Official Capacity as Chief Legal Officer, Fisglobal, Inc.;

 

Wells Fargo Bank:

 

“John Doe” #1, Individually and in His Official Capacity as Chief Executive Officer and President, Unknown Financial Institution For The New York City Housing Authority; “John Doe” #2, Individually and in His Official Capacity as Executive Vice President and Chairman of The Board, Unknown Financial Institution For The New York City Housing Authority; “John Doe” #3, Individually and in His Official Capacity Chief Financial Officer, Unknown Financial Institution For The New York City Housing Authority; “John Doe” #4, Individually and in His Official Capacity as General Counsel, Unknown Financial Institution For The New York City Housing Authority;

 

Unknown Financial Institution for Verizon, Inc.:

 

“John Doe” #2, Individually and in His Official Capacity as Executive Vice President and Chairman of The Board, Unknown Financial Institution For Verizon, Inc.; “John Doe” #3, Individually and in His Official Capacity Chief Financial Officer, Unknown Financial Institution for Verizon, Inc; “John Doe” #4, Individually and in His Official Capacity as General Counsel, Unknown Financial Institution For Verizon, Inc.;

 

America Works, Inc.:

 

America Works, Inc., Dr. Lee Bowes, Individually and in Her Official Capacity as Chief Executive Officer, America Works, Inc.; Peter Cove, America Works, Inc.; Melissa Corinne Wotton, General Counsel, America Works of New York, Inc.; Samantha Goldstein, Individually and in Her Official Capacity as Director, America Works, Inc.; Matthew Silverstein, Individually and in His Official Capacity as Program Director, America Works, Inc.;

 

Tronc., Inc.:

 

Justin C. Dearborn, Individually and in His Official Capacity as Chief Executive Officer and Chairman of Tronc, Inc; Julie Xanders, Individually and in Her Official Capacity as General Counsel or Tronc, Inc.; Unknown Investors of Tronc, Inc.;

 

New York Daily News:

 

Mortimer Zuckerman, Individually and in His Former Official Capacity as Editor, Publisher and Owner of The Daily News, Lp; Scott Shifrel, Former Staff Writer of The Daily News, LP; Laura Dimon, Individually and in Her Official Capacity as Journalist For The New York Daily News; Thomas, Individually and in His Official Capacity as Journalist For The New York Daily News; Andy Mai, Individually and in His Official Capacity as Journalist For The New York Daily News; John Annese, Individually and in His Official Capacity as Journalist For The New York Daily News;

 

Kelly Services, Inc.:

 

George S. Corona, Individually and in His Official Capacity as President and Chief Executive Officer; Hannah Lim-Johnson, Individually and in Her Official Capacity as Senior Vice President and Chief Legal Officer; Kristin Supancich, Individually and in Her Official Capacity as Senior Vice President, Chief Human Resources Officer; Debra Thorpe, Individually and in Her Official Capacity as Senior Vice President, Global Operations.

 

Goodwill Industries/Goodtemps, Inc.:

 

Allen E. Kaye., P.C.: Allen E. Kaye, Esq.;

 

Law Office of Harvey Shapiro: Harvey Shapiro; Esq.

 

Gladstein and Messinger: Jack Gladstein, Esq.,

 

Long Island Temps, Inc.:

 

MG Security Services, Inc.:

 

Twitter, Inc.:

 

Jack Dorsey, President and CEO, Twitter; Sean Edgett, Twitter

 

Uzamere & Associates, PLLC:

 

Osato Eugene Uzamere, Esq.

 

Ehigie Edobor Uzamere

 

 

 

            At all times hereinafter mentioned, Plaintiff Cheryl D. Uzamere, a victim of tortious and criminal violations committed by the Defendants, states the following under the penalties of perjury:

PRELIMINARY STATEMENT

U.S. CONSTITUTIONAL MANDATES

First Amendment

            1)         “Congress shall make no law respecting an establishment of religion. . .or abridging the freedom of speech, . . .and to petition the Government for a redress of grievances” See Lemon v. Kurtzman, 403 U.S. 602 (1971)

            2)         U.S. Supreme Court Case Law Regarding the Establishment Clause: “In 1947, the U.S. Supreme Court decision Everson v. Board of Education incorporated the Establishment Clause (i.e., made it apply against the states).in the majority decision, Justice Hugo Black wrote: 'The “establishment of religion” clause of the First Amendment means at least this: Neither a state nor the Federal Government can set up a church. Neither can pass laws which aid one religion, aid all religions, or prefer one religion to another . . .in the words of Jefferson, the [First Amendment] clause against establishment of religion by law was intended to erect 'a wall of separation between church and State' ... That wall must be kept high and impregnable. We could not approve the slightest breach.in the Board of Education of Kiryas Joel Village School District v. Grumet (1994), Justice David Souter, writing for the majority, concluded that “government should not prefer one religion to another, or religion to irreligion.”

            3)         U.S. Supreme Court Case Law Regarding the Free Speech Clause: in Herndon v. Lowry (1937), the Court heard the case of African American Communist Party organizer Angelo Herndon, who had been convicted under the Slave insurrection Statute for advocating black rule in the southern U.S.in a 5-4 decision, the Court reversed Herndon's conviction, upholding Holmes' "clear and present danger" test for the first time and arguing that the state of Georgia had not demonstrated that Herndon's actions met this standard (NSLs should be held to this standard).

            4)         U.S. Supreme Court Case Law Regarding the Petition Clause: “Today this right encompasses petitions to all three branches of the federal government—the Congress, the executive and the judiciary—and has been extended to the states through incorporation. According to the Supreme Court, 'redress of grievances' is to be construed broadly: it includes not solely appeals by the public to the government for the redressing of a grievance in the traditional sense, but also, petitions on behalf of private interests seeking personal gain. The right not only protects demands for "a redress of grievances" but also demands for government action.in Borough of Duryea v. Guarnieri (2011), the Supreme Court stated regarding the Free Speech Clause and the Petition Clause: It is not necessary to say that the two Clauses are identical in their mandate or their purpose and effect to acknowledge that the rights of speech and petition share substantial common ground... Both speech and petition are integral to the democratic process, although not necessarily in the same way. The right to petition allows citizens to express their ideas, hopes, and concerns to their government and their elected representatives, whereas the right to speak fosters the public exchange of ideas that is integral to deliberative democracy as well as to the whole realm of ideas and human affairs. Beyond the political sphere, both speech and petition advance personal expression, although the right to petition is generally concerned with expression directed to the government seeking redress of a grievance. The right of assembly was originally distinguished from the right to petition.in United States v. Cruikshank the Supreme Court held that 'the right of the people peaceably to assemble for the purpose of petitioning Congress for a redress of grievances, or for anything else connected with the powers or duties of the National Government, is an attribute of national citizenship, and, as such, under protection of, and guaranteed by, the United States. The very idea of a government, republican in form, implies a right on the part of its citizens to meet peaceably for consultation in respect to public affairs and to petition for a redress of grievances.' Justice Morrison Waite's opinion for the Court carefully distinguished the right to peaceably assemble as a secondary right, while the right to petition was labeled to be a primary right.

Fifth Amendment

            5)         “No person shall be . . .deprived of life, liberty, or property, without due process of law. . .” Correctional Services Corporation, v. John E. Malesko 534 U. S. __ (2001), page 5.

Thirteenth Amendment

            6)         “Neither slavery nor involuntary servitude, except as a punishment for crime whereof the party shall have been duly convicted, shall exist within the United States, or any place subject to their jurisdiction.”

Fourteenth Amendment

            7)         “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, or property, without due process of law; nor deny to any person within its jurisdiction the equal protection of the laws.” See Tennessee V. Lane (02-1667) 541 U.S. 509 (2004) 315 F.3d 680, affirmed.

FEDERAL STATUTES

Antiterrorism Act – Human Trafficking for Sexual Gratification

            8)         Federal Claim Under the Anti-Terrorism Act:  Section 2333 of the ATA creates a civil cause of action for “[a]ny national of the United States [who is]injured in his or her person, property, or business by reason of an act of international terrorism...” Section 2331 defines “international terrorism” as activities that: (A)involve violent acts or acts dangerous to human life that are a violation of the criminal laws of the United States or of any State, or that would be a criminal violation if committed within the jurisdiction of the United States or of any State; (B) appear to be intended -- (i) to intimidate or coerce a civilian population; (ii) to influence the policy of a government by intimidation or coercion; or (iii) to affect the conduct of a government by mass destruction, assassination, or kidnapping; and (C) occur primarily outside the territorial jurisdiction of the United States, or transcend national boundaries in terms of the means by which they are accomplished, the persons they appear intended to intimidate or coerce, or the locale in which their perpetrators operate or seek asylum...” Linde v Arab Bank, PLC, 882 F.3d 314, 326 (2d Cir. 2018) (citing Licci ex rel. Licci v. Lebanese Canadian Bank, SAL, 673 F.3d 50, 68 (2d Cir. 2012)).

Fighting Words Doctrine

            9)         There are certain well-defined and narrowly limited classes of speech, the prevention and punishment of which have never been thought to raise any Constitutional problem. These include the lewd and obscene, the profane, the libelous, and the insulting or "fighting" words--those which by their very utterance inflict injury or tend to incite an immediate breach of the peace. It has been well observed that such utterances are no essential part of any exposition of ideas and are of such slight social value as a step to truth that any benefit that may be derived from them is clearly outweighed by the social interest in order and morality. — Chaplinsky v. New Hampshire, 1942.[1], [2]

Federal Tort Claims Act (against Federal Agencies)

            10)       As the sovereign, the United States is immune from suit unless, and only to the extent that, it has consented to be sued. F.D.I.C. v. Meyer, --- U.S. ----, ----, 114 S.Ct. 996, 1000, 127 L.Ed.2d 308 (1994); McNeily v. United States, 6 F.3d 343, 347 (5th Cir.1993). Thus, to determine whether Truman can maintain this suit against the government, we must first decide whether one of the government's several waivers of sovereign immunity applies. If not, the government is immune from suit, and there is no subject matter jurisdiction to hear this case. United States v. Mitchell, 445 U.S. 535, 538, 100 S.Ct. 1349, 1351, 63 L.Ed.2d 607 (1980).

            11)       Through the enactment of the FTCA, the government has generally waived its sovereign immunity from tort liability for the negligent or wrongful acts or omissions of its agents who act within the scope of their employment. Specifically, the FTCA allows the government to be held liable in tort for any negligent or wrongful act or omission of any employee of the Government while acting within the scope of his office or employment, under circumstances where the United States, if a private person, would be liable to the claimant in accordance with the law of the place where the act or omission occurred. 28 U.S.C. Sec. 1346(b). The federal district courts have exclusive jurisdiction to hear claims cognizable under section 1346(b). Id. However, the exceptions to the FTCA's waiver of sovereign immunity that appear in 28 U.S.C. Sec. 2680 limit the federal courts' jurisdiction to hear FTCA claims and, if applicable, bar a suit brought against the government. Although there is no justification for any court "to read exemptions into the [Federal Tort Claims] Act beyond those provided by Congress," Rayonier, Inc. v. United States, 352 U.S. 315, 320, 77 S.Ct. 374, 377, 1 L.Ed.2d 354 (1957), the exceptions that do appear in the FTCA must be strictly construed in favor of the government. Atorie Air, Inc. v. Federal Aviation Admin., 942 F.2d 954, 958 (5th Cir.1991).

            12)       One of the exceptions to the FTCA's general consent-to-be-sued policy is integral to the case before us today. This exception retains the government's sovereign immunity for "[a]ny claim arising out of assault, battery, false imprisonment, false arrest, malicious prosecution, abuse of process, libel, slander, misrepresentation, deceit, or interference with contract rights." 28 U.S.C. Sec. 2680(h).

                13)       To determine whether a claim is one "arising out of" any of these enumerated torts, we focus on the conduct upon which the plaintiff's claim is based. If the conduct upon which a claim is based constitutes a claim "arising out of" any one of the torts listed in section 2680(h), then the federal courts have no jurisdiction to hear that claim. United States v. Neustadt, 366 U.S. 696, 81 S.Ct. 1294, 6 L.Ed.2d 614 (1961); Commercial Union Ins. Co. v. United States, 928 F.2d 176, 178-79 (5th Cir.1991). Even if a plaintiff styles a claim so that it is not one that is enumerated in section 2680(h), the plaintiff's claim is still barred "when the underlying governmental conduct 'essential' to the plaintiff's claim can fairly be read to 'arise out of' conduct that would establish an excepted cause of action." McNeily, 6 F.3d at 347 (citing Atorie, 942 F.2d at 958). Thus, the FTCA bars a claim based on conduct that constitutes a tort listed in section 2680(h), even though that conduct may also constitute another tort not listed in section 2680(h). Similarly, a plaintiff cannot circumvent the purpose of section 2680(h) by "framing his complaint in terms of [the government's] negligent failure to prevent the excepted harm." Id. at 347. Thus we held in Garcia v. United States, 776 F.2d 116 (5th Cir.1985), that a plaintiff could not evade the reach of section 2680(h) by raising a claim for negligence in the supervision of a military recruiter who allegedly assaulted the plaintiff. For the purposes of section 2680(h), Garcia's negligence claim arose out of an assault and battery. Id. at 118.

            14)       In contrast, if a plaintiff bases a claim on conduct that does not constitute a claim "arising out of" a tort specified in section 2680(h), then the plaintiff's suit is not barred. Even in cases in which the facts alleged in a complaint have two distinct aspects that may give rise to two similar torts, "the partial overlap between ... two tort actions does not support the conclusion that if one is excepted under the Tort Claims Act, the other must be as well. Neither the language nor history of the Act suggests that when one aspect of the Government's conduct is not actionable [because it constitutes a tort enumerated in section 2680(h)], a claimant is barred from pursuing a distinct claim arising out of other aspects of the Government's conduct." Block v. Neal, 460 U.S. 289, 298, 103 S.Ct. 1089, 1094, 75 L.Ed.2d 67 (1983). So long as some aspect of the conduct upon which a plaintiff bases a tort claim does not constitute a tort listed in section 2680(h), the suit is not barred. Thus, in Block, the Supreme Court held that the plaintiff could maintain a cause of action against the government for negligently failing to detect defects in the construction of a house, even though the plaintiff in that case may also have had a claim for misrepresentation--a tort excepted from the FTCA by section 2680(h).

            15)       In the present case, Truman described in her complaint an extensive pattern of offensive conduct undertaken by Whittaker. She claimed that this conduct gave rise to several tort claims. The district court dismissed Truman's suit, holding that Truman's claims were barred by section 2680(h) because they arose out of an assault or a battery or constituted slander. We hold that the district court erred when it dismissed Truman's suit. The conduct alleged in Truman's complaint can fairly be read to state a claim for intentional infliction of emotional distress--not a claim for assault, battery, or slander. And, a claim for intentional infliction of emotional distress based on the conduct described in Truman's complaint is not barred by an exception to the FTCA.

Qui Tam/False Claims Act

            16)       “any person who knowingly presents, or causes to be presented, a false or fraudulent claim for payment or approval; or knowingly conceals or knowingly and improperly avoids or decreases an obligation to pay or transmit money or property to the Government, is liable to the United States Government for a civil penalty of not less than $5,000 and not more than $10,000, as adjusted by the Federal Civil Penalties Inflation Adjustment Act of 1990 (28 U.S.C. 2461 note; Public Law 104–410[1]), plus 3 times the amount of damages which the Government sustains because of the act of that person.

            17)       Costs of Civil Actions: A person violating this subsection shall also be liable to the United States Government for the costs of a civil action brought to recover any such penalty or damages.

Title II of the Americans With Disabilities and Federal Rehabilitation Act of 1973

            18)       The Americans With Disabilities Act, 42 U.S.C. §§12131, 12132, prohibits discrimination against individuals with disabilities, Including those with mental illness. Similarly, Section 504 of the Rehabilitation Act, 29 U.S.C. §794, provides that no person with a disability, including those with mental illness, shall: “solely by reason of his or her disability, be excluded from participation in, be denied benefits of, or be subjected to discrimination under any program or activity receiving Federal financial assistance.”

            19)       In the decision regarding Disability Advocates, Inc. vs. Paterson, et al, Defendant Garaufis stated that “The Supreme Court held in Olmstead v. L.C., 527 U.S. 581 (1999), that “[u]njustified isolation . . . is properly regarded as discrimination based on disability,” observing that “institutional placement of persons who can handle and benefit from community settings perpetuates unwarranted assumptions that persons so isolated are incapable of or unworthy of participating in community life.” 527 U.S. at 597, 600. The “integration mandate” of Title II of the American with Disabilities Act, 42 U.S.C. §12101 et seq., and Section 504 of the Rehabilitation Act, 29 U.S.C. §791 et seq., as expressed in federal regulations and Olmstead, requires that when a state provides services to individuals with disabilities, it must do so “in the most integrated setting appropriate to their needs.” The “most integrated setting,” according to the federal regulations, is “a setting that enables individuals with disabilities to interact with non-disabled persons to the fullest extent possible.” 28 C.F.R. §35.130(d); 28 C.F.R. pt. 35 app. A.

            20)       Further, Title II of the Americans With Disabilities Act requires that “a public entity shall administer services, programs, and activities in the most integrated setting appropriate to the needs of qualified individuals with disabilities.” See 28 C.F.R. §35.130(d).

            21)       In the landmark decision Olmstead v. L.C., 527 U.S. 581 (1999), the U.S. Supreme Court held that these provisions of law are violated when a state places people with mental illness in “unjustified isolation,” and that a person with mental illness may sue the state for failing to place him or her “in the most integrated setting appropriate to [his or her] needs.”

Sherman and Clayton Antitrust Act

            22)       Every contract, combination in the form of trust or otherwise, or conspiracy, in restraint of trade or commerce among the several States, or with foreign nations, is declared to be illegal. Every person who shall make any contract or engage in any combination or conspiracy hereby declared to be illegal shall be deemed guilty of a felony, and, on conviction thereof, shall be punished by fine not exceeding $100,000,000 if a corporation, or, if any other person, $1,000,000, or by imprisonment not exceeding 10 years, or by both said punishments, in the discretion of the court.

            23)       §3 Clayton Act, 15 U.S.C. § 14, Sale, etc., on agreement not to use goods of competitor: It shall be unlawful for any person engaged in commerce, in the course of such commerce, to lease or make a sale or contract for sale of goods, wares, merchandise, machinery, supplies, or other commodities, whether patented or unpatented, for use, consumption, or resale within the United States or any Territory thereof or the District of Columbia or any insular possession or other place under the jurisdiction of the United States, or fix a price charged therefor, or discount from, or rebate upon, such price, on the condition, agreement, or understanding that the lessee or purchaser thereof shall not use or deal in the goods, wares, merchandise, machinery, supplies, or other commodities of a competitor or competitors of the lessor or seller, where the effect of such lease, sale, or contract for sale or such condition, agreement, or understanding may be to substantially lessen competition or tend to create a monopoly in any line of commerce.

            24)       §4 Clayton Act, 15 U.S.C. § 15, Suits by persons injured (a) Amount of recovery; prejudgment interest:  Except as provided in subsection (b) of this section, any person who shall be injured in his business or property by reason of anything forbidden in the antitrust laws may sue therefor in any district court of the United States in the district in which the defendant resides or is found or has an agent, without respect to the amount in controversy, and shall recover threefold the damages by him sustained, and the cost of suit, including a reasonable attorney's fee.

Civil Rights Act of 1964, Title VI, §601

Nondiscrimination in Federally Assisted Programs

            25)       “No person in the United States shall, on the ground of race, color, or national origin, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving Federal financial assistance.” Fogg v. Gonzales, Nos. 05-5439, 05-5440 says the following: “In the case Correctional Services Corporation, v. John E. Malesko, the U.S. Supreme Court stated that “In 30 years of Bivens jurisprudence we have extended its holding only twice, to provide an otherwise nonexistent cause of action against individual officers alleged to have acted unconstitutionally, or to provide a cause of action for a plaintiff who lacked any alternative remedy for harms caused by an individual officers unconstitutional conduct.” However, In the same case, the Court said: “Most recently, In FDIC v. Meyer, we unanimously declined an invitation to extend Bivens to permit suit against a federal agency, even though . . .Congress had waived sovereign immunity [and] was otherwise amenable to suit. 510 U. S., at 484, 486. Our opinion emphasized that the purpose of Bivens is to deter the officer, not the agency. Id., at 485 (emphasis in original) (citing Carlson v. Green, supra, at 21). We reasoned that if given the choice, plaintiffs would sue a federal agency instead of an individual who could assert qualified immunity as an affirmative defense. To the extent aggrieved parties had less incentive to bring a damage claim against individuals, the deterrent effects of the Bivens remedy would be lost. 510 U.S. at 485. Accordingly, to allow a Bivens claim against federal agencies would mean the evisceration of the Bivens remedy, rather than its extension. 510 U. S., at 485.”

42 USC §1983 – CIVIL ACTION FOR DEPRIVATION of RIGHTS

42 USC §1985 - CONSPIRACY TO INTERFERE WITH CIVIL RIGHTS

 

            27)       “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. . .If two or more persons in any State or Territory conspire to deter, by force, Intimidation, or threat, any party or witness in any court of the United States from attending such court, or from testifying to any matter pending therein, freely, fully, and truthfully, or to injure such party or witness in his person or property on account of his having so attended or testified, or to influence the verdict, presentment, or indictment of any grand or petit juror in any such court, or to injure such juror in his person or property on account of any verdict, presentment, or indictment lawfully assented to by him, or of his being or having been such juror; or if two or more persons conspire for the purpose of impeding, hindering, obstructing, or defeating, In any manner, the due course of justice in any State or Territory, with intent to deny to any citizen the equal protection of the laws, or to injure him or his property for lawfully enforcing, or attempting to enforce, the right of any person, or class of persons, to the equal protection of the laws. . .the party so injured or deprived may have an action for the recovery of damages occasioned by such injury or deprivation, against any one or more of the conspirators.” See Haddle V. Garrison et al, 525 U.S. 121 (1998).

            28)       Federal courts recognize blacklisting as a cause of action.in the lawsuit Castillo v. Spiliada Maritime Corporation MV, 937 F. 2d 240, the United State Court of Appeals for the Fifth Circuit stated that “. . .Plaintiffs have offered substantial evidence that they were coerced into agreeing to the settlements with threats that charges would be filed against them with the POEA and that they would be blacklisted.  As the threats of blacklisting endangered the possibility of future employment in their established trade, Plaintiffs reasonably could have been intimidated into settling.” In the lawsuit Duckworth v. Pratt & Whitney, Inc., 152 F.3d 1 (1st Cir. 1998), the United States Court of Appeals for the First Circuit stated that “As both Duckworth and the Secretary of Labor persuasively argue, the achievement of these objectives would be frustrated by adopting Pratt & Whitney's interpretation. That interpretation would permit an employer to evade the Act by blacklisting employees who have used leave in the past or by refusing to hire prospective employees if the employer suspects they might take advantage of the Act.” The United States Court of Appeal's use of the term “leave” refers to medical leave. The United States Court of Appeals use of the term “Act” refers to the Family and Medical Act of 1993.in the case Davis v. Paul, et al, 505 F.2d 1180, the United States Court of Appeals for the Sixth circuit stated that “Few things are as fundamental to our legal system as the presumption of innocence until overcome by proof of guilt beyond a reasonable doubt at a fair trial. The dissemination of the flier in the case at bar is in the face of the presumption of innocence, disregards the Due Process Clause and is based on evidence that is not probative of guilt. Condemning a man to a suspect class without a trial and on a wholly impermissible standard, as in the case at bar, offends the very essence of the Due Process Clause, i.e., protection of the individual against arbitrary action. Slochower v. Board of Education, 350 U.S. 551, 559, 76 S.Ct. 637, 100 L.Ed. 692 (1956); Peters v. Hobby, 349 U.S. 331, 351-352, 75 S.Ct. 790 (1955) (Douglas, J., concurring.) as said by Mr. Justice Black in his concurring opinion in Joint Anti-Fascist Refugee Committee v. McGrath, 341 U.S. 123, 144-145, 71 S.Ct. 624, 634 (1951): 'Our basic law, however, wisely withheld authority for resort to executive. . .condemnations and blacklists as a substitute for imposition of legal types of penalties by courts following trial and conviction in accordance with procedural safeguards of the Bill of Rights.'” The United States Equal Employment Opportunity Commission's, (EEOC) Office of Legal Counsel the Americans with Disabilities Act of 1990 and the Family and Medical Leave Act of 1993 overlap, and that where employees are concerned, “ADA Title II covers all public employers without regard to the number of employees.”

CIVIL ACTION FOR RICO

            29)       “The district courts of the United States shall have jurisdiction to prevent and restrain violations of section 1962 of this chapter by issuing appropriate orders, Including, but not limited to: ordering any person to divest himself of any interest, direct or indirect, In any enterprise; imposing reasonable restrictions on the future activities or investments of any person, Including, but not limited to, prohibiting any person from engaging in the same type of endeavor as the enterprise engaged in, the activities of which affect interstate or foreign commerce; or ordering dissolution or reorganization of any enterprise, making due provision for the rights of innocent persons.”

            30)       “Any person injured in his business or property by reason of a violation of section 1962 of this chapter may sue therefore in any appropriate United States district court and shall recover threefold the damages he sustains and the cost of the suit, Including a reasonable attorney’s fee, except that no person may rely upon any conduct that would have been actionable as fraud in the purchase or sale of securities to establish a violation of Section 1962. The exception contained in the preceding sentence does not apply to an action against any person that is criminally convicted in connection with the fraud, in which case the statute of limitations shall start to run on the date on which the conviction becomes final.”

INTERFERENCE WITH COMMERCE BY THREATS OR VIOLENCE

            31)       “Whoever in any way or degree obstructs, delays, or affects commerce or the movement of any article or commodity in commerce, by robbery or extortion or attempts or conspires so to do, or commits or threatens physical violence to any person or property in furtherance of a plan or purpose to do anything in violation of this section shall be fined under this title or imprisoned not more than twenty years, or both.”

            32)       “The term “extortion” means the obtaining of property from another, with his consent, Induced by wrongful use of actual or threatened force, violence, or fear, or under color of official right.”

RIGHTS OF CRIME VICTIMS

            33)       A crime victim has the following rights:

                        a)         The right to be reasonably protected from the accused. The right to reasonable, accurate, and timely notice of any public court proceeding or any parole proceeding, Involving the crime or of any release or escape of the accused.

                        b)         The right not to be excluded from any such public court proceeding, unless the court, after receiving clear and convincing evidence, determines that testimony by the victim would be materially altered if the victim heard other testimony at that proceeding.

                        c)         The right to be reasonably heard at any public proceeding in the district court involving release, plea, sentencing, or any parole proceeding.

                        d)         The reasonable right to confer with the attorney for the Government in the case.

                        e)         The right to full and timely restitution as provided in law.

                        f)         The right to proceedings free from unreasonable delay.

                        g)         The right to be treated with fairness and with respect for the victim’s dignity and privacy.

CONTINUING VIOLATIONS DOCTRINE

            34)       This Court has jurisdiction over the action pursuant to Morgan v. National Railroad Passenger Corporation, DBA Amtrak, 232 F.3d 1008 (November 8, 2000) with regard to the continuing violations doctrine, In which the U.S. Supreme Court stated in its decision that “the continuing violations doctrine. . .allows courts to consider conduct that would ordinarily be time barred "as long as the untimely incidents represent an ongoing unlawful. . .practice. . .The district court's reliance on Galloway was mistaken. This court has never adopted a strict notice requirement as the litmus test for application of the continuing violation doctrine; in fact, In Fiedler v. UAL Corp., 218 F.3d 973 (9th Cir. 2000), we explicitly rejected such an approach from the Fifth Circuit. See id. at 987 n.10. Fiedler examined Berry v. Board of Sup'rs of L.S.U., 715 F.2d 971 (5th Cir. 1983), a case which involved equal pay based upon gender discrimination, where the Fifth Circuit created a multi-factor test for determining whether discrete acts of harassment are closely related enough to satisfy the continuing violation theory. The Berry court's final factor, "perhaps of most importance," asked whether the harassing act "should trigger an employee's awareness of and duty to assert his or her rights.” Berry, 715 F.2d at 981. We rejected the Berry analysis, holding that test was not “applicable in determining the continuation of a hostile environment.” Fiedler, 218 F.3d at 987 n.10.

            35)       In tort law, if a defendant commits a series of illegal acts against another person, or, In criminal law, if someone commits a continuing crime (which can be charged as a single offense), the period of limitation begins to run from the last actin the series.in the case of Treanor v. MCI Telecommunications, Inc., the U.S. Court of Appeals for the Eighth Circuit explained that the continuing violations doctrine "tolls the statute of limitations in situations where a continuing pattern forms due to [illegal] acts occurring over a period of time, as long as at least one incident . . . occurred within the limitations period.in the case Douglas v. California Department of Youth Authority, 271 F.3d 812, Dossey Douglas was denied employment by the California Youth Authority because a vision test indicated that he was color-blind. Douglas brought suit against CYA for its failure to hire him under Title I of the ADA. The district court granted summary judgment to CYA on the ground that Douglas' claims are barred by the applicable statutes of limitations. Douglas argued on appeal that his claims are timely under the continuing violations doctrine because the CYA's discriminatory policy was on-going. The U.S. Court of Appeals stated the following: “Applying the continuing violations doctrine to these facts, we are guided by two earlier Ninth Circuit decisions.in Domingo v. New England Fish Co., 727 F.2d 1429 (9th Cir. 1984), amended 742 F.2d 520 (9th Cir. 1984), we considered a class action suit against a cannery operator involving allegations of discrimination on the basis of race in hiring and promotions. The plaintiffs argued that their claims were saved from the time bar by the fact that the discriminatory hiring and promotion polices continued until the plaintiffs brought suit. Id. at 1443. We required the plaintiffs to demonstrate that because of the discriminatory policy, they were either discriminated against or “exposed to discrimination” during the limitations period. Id. Almost a decade later, we again addressed the issue whether a case was timely under a continuing violations theory based on an alleged systemic discrimination in hiring. EEOC v. Local 350, Plumbers and Pipefitters, 998 F.2d 641, 643 (9th Cir. 1993). The EEOC filed an Age Discrimination in Employment Act suit on behalf of union members who were excluded from hiring lists on the ground that they received pension benefits. Id. at 643. We noted that the union's policy that excluded retirees from the hiring lists applied to the class members as early as 1984, five years earlier. Id. at 644. We found that the action was not barred by the relevant statute of limitations, because the discriminatory policy prohibiting retirees from joining the hiring lists continued. Id. (“Here, Local 350's allegedly discriminatory policy was in effect when [the plaintiff] first encountered [the policy]in 1984 and remains in force today. Thus, under the continuing violations doctrine, relief for [the plaintiff] is not barred.”). Although we did not cite Domingo in our analysis in Local 350, the two decisions are consistent.in Local 350, the plaintiffs, as union members, continued to be “exposed” to the discriminatory hiring policies of the union.” The U.S. Court of Appeals for the Ninth Circuit finally decided that “. . .With respect to the ADA claim. . .We REVERSE the district court's grant of summary judgment on both the Rehabilitation Act and ADA claims because we conclude that the claims were timely filed under the continuing violations doctrine."

IMPLIED CAUSE OF ACTION

            36)       “For the reasons set forth below, I am of the opinion that federal courts do have the power to award damages for violation of 'constitutionally protected interests' and I agree with the Court that a traditional judicial remedy such as damages is appropriate to the vindication of the personal interests protected by the Fourth Amendment.” See Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388, 91 S. Ct. 1999; 29 L. Ed. 2D 619; 1971 U.S. Lexis 23; at Correctional Services Corporation, v. John E. Malesko, it says: “In the decade following Bivens, we recognized an implied damages remedy under the Due Process Clause of the Fifth Amendment, Davis v. Passman, 442 U. S. 228 (1979), and the Cruel and Unusual Punishment Clause of the Eighth Amendment, Carlson v. Green, 446 U. S. 14 (1980).in both Davis and Carlson, we applied the core holding of Bivens, recognizing in limited circumstances a claim for money damages against federal officers who abuse their constitutional authority.in Davis, we inferred a new right of action chiefly because the plaintiff lacked any other remedy for the alleged constitutional deprivation. 442 U. S., at 245 (For Davis, as for Bivens, it is damages or nothing).in Carlson, we inferred a right of action against individual prison officials where the plaintiff's only alternative was a Federal Tort Claims Act (FTCA) claim against the United States. 446 U. S., at 18. 23. We reasoned that the threat of suit against the United States was insufficient to deter the unconstitutional acts of individuals. Id., at 21. (Because the Bivens remedy is recoverable against individuals, it is a more effective deterrent than the FTCA remedy). We also found it crystal clear that Congress intended the FTCA and Bivens to serve as parallel and complementary sources of liability. 446 U.S., at 19.20...In 30 years of Bivens jurisprudence we have extended its holding only twice, to provide an otherwise nonexistent cause of action against individual officers alleged to have acted unconstitutionally, or to provide a cause of action for a plaintiff who lacked any alternative remedy for harms caused by an individual officers unconstitutional conduct.”

PURPOSE OF PLAINTIFF'S ACTION

            37)       By this action, Plaintiff seeks enforce her rights pursuant to put an end to Defendants' commission of misprision of felony, 18 USC §4; fraud, 18 USC §1001; identity theft, 18 USC §1028; aggravated identity fraud, 18 USC §1028A; deprivation of rights under color of law (including being kidnapped, unlawfully imprisoned and blacklisted), 18 USC §242/42 USC §1985; extortion, 18 USC §872§, blackmail, 18 USC §873; violation of Title II of the Americans With Disabilities Act; violation of the Federal Rehabilitation Act of 1973; violation of the Civil Rights Act of 1964, Title VI, §601; violation of the Free Speech Clause of the First Amendment; violation of the Establishment Clause of the First Amendment; violation of the Petition Clause of the First Amendment; violation of the Due Process Clause of the Fifth and Fourteenth Amendments; violation of the Notice Clause of the Sixth Amendment; violation of the Assistance of Counsel Clause of the Sixth Amendment; violation of Plaintiff's right of privacy with regard to the illegal dissemination of her psychiatric records, Plaintiff marriage history, Plaintiff married name, and the non-content information associated with Plaintiff's internet and telephone accounts; violation of the Equal Protection Clause of the Fourteenth Amendment, Intentional misuse of national security letters (NSLs) and violation of the Hobbs Act.

JURISDICTION AND VENUE

            38)       This Court has jurisdiction over this action pursuant to 28 U.S.C. §1331, federal question, which states that “The district courts shall have original jurisdiction of all civil actions arising under the Constitution, laws, or treaties of the United States.”

            39)       This Court has jurisdiction over this action pursuant to

            40)       Declaratory and injunctive relief are sought against

            41)       Venue has its basis in 28 USC §1404(a)(c), that states:

VERIFIED COMPLAINT

            )          

FACTUAL ANALYSIS

1.       Curse of Ham: http://www.ottmall.com/mj_ht_arch/v15/mj_v15i20.html#CDX;

 

2.       Come and Hear, Elizabeth Dilling: Judaism, Anti-Gentilism and the Exploitation of Non-Jews: http://come-and-hear.com/dilling/chapt04.html;

 

3.       Come and Hear, Sex with Children by Talmud Rules: http://www.come-and-hear.com/editor/america_2.html;

 

4.       Age of Child Prostitutes in Israel Dropping, Report Finds: https://www.haaretz.com/.premium-report-age-of-child-prostitutes-dropping-1.5322978;

 

5.       Student Says Alleged Paedophile Malka Leifer Manipulated All of Us: https://www.youtube.com/watch?v=LDv3l8bhF-g;

 

6.       Sex Slaves Hidden in Walls in Israel: https://www.youtube.com/watch?v=1PFvTW23Oi0;

 

7.       Babylonian Talmudic Hatred of Blacks and other Gentiles (the reason so many black children are raped in Ashkenazi Jewish-run group homes and why white Gentile women are being gang-raped in Israel: http://www.ottmall.com/mj_ht_arch/v15/mj_v15i20.html#CDX; http://come-and-hear.com/dilling/chapt04.html;

 

8.       The Child-Rape Assembly Line: https://www.vice.com/en_us/article/qbe8bp/the-child-rape-assembly-line-0000141-v20n11;

 

9.       Can This Number Be Credible? Jewish Anti-Abuse Activists Say Half of Hasidic Boys Are Raped by Elders: http://friendlyatheist.patheos.com/2013/11/13/can-this-number-be-credible-jewish-anti-abuse-activists-say-half-of-hasidic-boys-are-raped-by-elders/;

 

10.    Child Sex Abuse in Orthodox Jewish Bathhouses: https://www.youtube.com/watch?v=vFeK8LIP6EM (https://www.youtube.com/watch?v=vFeK8LIP6EM);

 

11.    SPEAK UP! 7 Orthodox Abuse Survivors Break the Silence: https://www.youtube.com/watch?v=Asza6pEQVfQ (https://www.youtube.com/watch?v=Asza6pEQVfQ);

 

12.    Nechemya Weberman Guilty of Abuse Gets 103 Years in Prison: https://www.youtube.com/watch?v=YHeiPaE8TR8 (https://www.youtube.com/watch?v=YHeiPaE8TR8);

 

13.    Hasidic Child Abuse: https://www.youtube.com/watch?v=hJZ060pQBQ4;

 

14.    Colombian Cops Bust Global Child Sex Slave Ring Run by Israeli Crime Network: https://www.youtube.com/watch?v=8JF24XkqJMU (https://www.youtube.com/watch?v=8JF24XkqJMU);

 

15.    Governor Eliot Spitzer Resigns After Being Connected to Prostitution Ring: https://www.youtube.com/watch?v=zPdT_qB92Pg (https://www.youtube.com/watch?v=zPdT_qB92Pg);

 

16.    Pedophile Rabbi David Kaye RAW VIDEO: https://www.youtube.com/watch?v=RI2lc1LW5G0;

 

17.    A Timeline of Harvey Weinstein’s Sexual Harassment Allegations: https://www.youtube.com/watch?v=50nysL24aKY (https://www.youtube.com/watch?v=50nysL24aKY);

 

18.    DNC in Meltdown as Multiple Democrats Face Child Sex Probe: https://www.youtube.com/watch?v=hyi4V1McUowNYC

 

            )           The federal government grants and guarantees students loans are given to individuals who, because of poverty and/or other issues that interfere with ability to obtain a post-high school education and subsequent employment, are unable to pay the high costs of education. The federal government’s main goal, especially in the case of individuals who are members of federally-protected groups, such as non-foreign African Americans and mentally disabled individuals who are statistically overrepresented in lower education, unemployment and poverty. When the federal government provides students loans to members of the aforementioned groups who complete their education and obtain employment, both the federal government, the graduate-turned-employed student and the country at large benefit financially, politically and socially.

            )           I allege that Ashkenazi Jewish immigration Allen E. Kaye and Harvey Shapiro are sexual sadists. From the time that they took on my husband’s case, they knew and planned to use my husband Ehigie Edobor Uzamere, desperate to become a permanent resident and to obtain an education and social status associated with a college education was infantilized, corporately/psychologically raped and then unleashed and trafficked to any childlike, defenseless individual who was not knowledgeable regarding immigration issues.  From the time that corporate “pedophiles” Allen E. Kaye and Harvey Shapiro met my husband, the planned to use my husband to cause misery to me or some other innocent, childlike individual to cause psychological pain, for the sole purpose of being sexually titillated.

            )           Since November 30, 1979, the day that corporate “pedophiles” Allen E. Kaye and Harvey Shapiro tricked me into signing the immigration sponsorship form, other members of Ashkenazi Jewish leadership and joined Allen E. Kaye and Harvey Shapiro to traffic me and my children as sex objects. Both of my children were sexually molested while in foster care. My daughter Tara had tissue placed so far into her vagina that it became infected. She had to be taken to Kings County Hospital and put to sleep to have the tissue removed. My son David was forced to eat feces while he wasin foster care. On his Facebook page David reported having been approached by a teenage boy and told to lick his penis after he masturbated. By the time David came home, he was bulimic. I allege that based on my son’s bulimia, he was drugged and sodomized while in Ashkenazi Jewish-run group homes.

 

                149)        By reason of the foregoing irrefutable allegations, Plaintiff asserts that there exists a justiciable controversy with respect to which Plaintiff is entitled to the relief prayed for herein.

 

FIRST CLAIM FOR RELIEF

 

First Amendment Mandate -- Separation of Church and State

\

                150)        Plaintiff repeats and realleges the above paragraphs.

 

                151)        With regard to all natural Defendants, this claim is brought against themindividually and in their official capacities.

 

                152)        Plaintiff is an American citizen with a serious and persistent mental illness. Plaintiff has a mental impairment that substantially limits one or more major life activities.

 

                153)        Plaintiff is a qualifiedindividual with disabilities within the meaning of 42 U.S.C. §12131(2).

 

                154)        Plaintiff is a descendant victim of the African Holocaustin which Africans, whose sale was brokered by Jews and kidnapped by whites, forever lost the ability to bear the correct paternal name of her African male forebears; and having married Defendant Ehigie Edobor Uzamere, now retains the right from now to eternity to have borne and to bear the name of Defendant Ehigie Edobor Uzamere, as does Tara A. Uzamere, the adult child of the marriage between Plaintiff and Defendant Ehigie Edobor Uzamere and blood heir with the legal right to bear, and for her progeny to bear the correct Edo/Bini name and culture associated with Defendant Ehigie Edobor Uzamere.

 

                155)        Defendants owed Plaintiff and her family the duty, pursuant to 5 USC §3331, to support and defend the Constitution of the United States against all enemies, foreign and domestic; to bear true faith and allegiance to the same; to take said obligation freely, without any mental reservation or purpose of evasion; and to well and faithfully discharge the duties of the office on which Defendants entered. This requires the Defendants to establish a clear separation of church and state, and to distance themselves from the Talmudic Law of the Moserin their application and enforcement of the law. Defendants owed Plaintiff and her children the duty to give themselves over to the transparency of U.S. law, and not the secrecy of the Talmudic Law of the Moser.

 

                156)        Defendants failedin their duty to meet their legal obligations as detailed by the First Amendment mandate regarding the separation of church and state. Defendants, at the behest of Defendant Garaufis and other Jewish judiciary Defendants have conspired to force the tenets of the Talmud and other Jewish religious dogma on the Plaintiff based on the Talmud's viewpoint of the Plaintiff's as a gentile/non-Jewish, African-American/schvartze slave to prevent Plaintiff from filing civil and criminal complaints against corrupt immigration attorneys Allen E. Kaye, Harvey Shapiro and Jack Gladstein.

 

                157)        Plaintiff suffered and continues to sufferinjury because she is still under attack by all the Defendants, who, at the clandestine behest of Defendants Judge Garaufis, Judge Schack, Judge Sunshine and Judge Gerstein, have continued the same government-wide hostile environment that Plaintiff complained aboutin her prior lawsuits, Uzamere vs. Uzamere (Plaintiff's divorce action) and Uzamere vs. Cuomo, et al, 11-cv-2831/11-2713-cv. Plaintiff has been forced by Defendant Garaufis to obey the Talmud, Tractate Abodah Zarah, folio 26b, Tractate Sanhedrin, folio 108b and footnote 34; Jewish doctrine Law of the Moser, the doctrine that prohibits anyone from reporting the crimes of Jews to secular, Gentile authorities; and the Curse of Black Skin, the doctrine that requires people of dark-skinned African descent to be obedient to Jews and white people because dark-skinned Africans are meant to be slaves.in Plaintiff's prior lawsuit Uzamere vs. Cuomo, et al Case Nos. 11-cv-2831/11-2713-cv, Plaintiff provided Defendant Garaufis with proof that employees of Defendant New York State conspired with Defendant Shifrel of Defendant Daily News, LP , to defame the Plaintiff as an “anti-Semitic wacko”, to illegally publicize Plaintiff's psychiatric and maritalinformation to give their false publicized statement regarding Plaintiff's ex-husband being “Godwin Uzamere” believability. Defendant Garaufis violated Plaintiff's rightsin the same manner by relying on the Talmud, Tractate Abodah Zarah, folio 26b and the Talmudic doctrine Law of the Moser, not the U.S. Constitution to prevent the Plaintiff from reporting the commission of aggravated identity theft by corrupt Jewish attorneys Allen E. Kaye, Harvey Shapiro and Jack Gladstein.

 

                158)        The courts of Defendant United States of America recognize excessive entanglement of religion as aninjury.in the case Lemon v. Kurtzman, 403 U.S. 602 (1971), the Supreme Court ruled that government may not “excessively entangle” with religion. The caseinvolved two Pennsylvania laws: one permitting the state to “purchase” servicesin secular fields from religious schools, and the other permitting the state to pay a percentage of the salaries of private school teachers, Including teachersin religiousinstitutions. The Supreme Court found that the government was “excessively entangled” with religion and invalidated the statutesin question.

 

                159)        Plaintiff submits that Defendants' violation of the First Amendment's Mandate to keep church and government separate also violates the Due Process Clause of the Fifth and Fourteenth Amendments, the Equal Protection Clause of the Fourteenth Amendment and 42 USC §1985, conspiracy tointerfere with civil rights, such that Plaintiff's Verified Complaint rises to the level of an actionin the manner of Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388 with regard to those Defendants who are natural persons. Plaintiff understands the U.S. Supreme Court's application of Bivens to natural persons and its refusal to extend Bivens to agencies.

 

SECOND CLAIM FOR RELIEF

 

Defendants Violated the Americans With Disabilities Act Mandate

 

                160)        Plaintiff repeats and realleges the above paragraphs.

 

                161)        With regard to all natural Defendants, this claim is brought against themindividually and in their official capacities.

 

                162)        Plaintiff is an American citizen with a serious and persistent mental illness. Plaintiff has a mental impairment that substantially limits one or more major life activities. 

 

                163)        Plaintiff is a qualifiedindividual with disabilities within the meaning of 42 U.S.C. §12131(2).

 

                164)        Plaintiff is a descendant victim of the African Holocaustin which Africans, whose sale was brokered by Jews and kidnapped by whites, forever lost the ability to bear the correct paternal name of her African male forebears; and having married Defendant Ehigie Edobor Uzamere, now retains the right from now to eternity to have borne and to bear the name of Defendant Ehigie Edobor Uzamere; and that the aforesaid right is retained by Tara A. Uzamere, the adult child of the marriage between Plaintiff and Defendant Ehigie Edobor Uzamere., and for her progeny to bear the correct Edo/Bini name and culture associated with of Defendant Ehigie Edobor Uzamere.

 

                165)        Defendants owed Plaintiff the duty, pursuant to Title II of the Americans With Disabilities Act, to prohibit the practice of disability discrimination. As public entities, Defendants owed Plaintiff the duty to comply with Title II regulations by the U.S. Department of Justice. These regulations cover access to all programs and services offered by the entity. Accessincludes physical access describedin the ADA Standards for Accessible Design and programmatic access that might be obstructed by discriminatory policies or procedures of the entity.

 

                166)        Defendants failedin their duty to meet the obligations as detailedin Title II of the Americans With Disabilities Act. Defendants continue to discriminate against Plaintiff based on Plaintiff's status of having a mental illness because Plaintiff will not stop filing complaints against corrupt Jews immigration attorneys Allen E. Kaye, Harvey Shapiro and Jack Gladstein. 

 

                167)        Plaintiff suffered and continues to sufferinjury because Plaintiff is still under attack by all the Defendants who, at the clandestine behest of Defendant Garaufis, Judge Schack, Judge Sunshine and Judge Gerstein, have continued the same government-wide hostile environment that Plaintiff complained aboutin her prior lawsuit, Uzamere vs. Cuomo, et al, 11-cv-2831/11-2713-cv. Defendants continue to discriminate against Plaintiff by using Plaintiff's status of having a mental illness to falsely and to publicly hold out that judicial Defendants will not allow Plaintiff to file criminal and civil complaints against corrupt Jewish Defendants corrupt immigration attorneys Allen E. Kaye, Harvey Shapiro and Jack Gladstein because Plaintiff's complaints are unintelligible based on her status of having a mental illness.192021. Defendants New York State, New York State Office of Mental Health, New York City, New York City Health and Hospitals Corporation, Brookdale Hospital Medical Center and their employeesintentionally misdiagnosed Plaintiff as psychotic and violent so as to deprive Plaintiff of her right to due process and equal protection under the law. Defendants accused Plaintiff of the commission of 18 USC §115, threatening a federal employee and discriminated against the Plaintiff by using her status of having a mental illness as an excuse to deprive her of the right to defend herselfin criminal court against said criminal charges. Proof of Defendant New York State's and New York City's continued conspiracy to attack the Plaintiff based on her status of having a mental illness is at http://articles.nydailynews.com/2009-11-05/local/17938323_1_supreme-court-judge-criminal-court; and http://www.law.com/jsp/article.jsp?id=1202435221996&slreturn=20120729115138; see Daily News article dated November 5, 2009in which staff writer Scott Shifrel publicly defames Plaintiff as a “wacko.” 

 

                168)        The courts of Defendant the United States of America recognize discrimination based on disability as aninjury. The Supreme Court heldin Olmstead v. L.C., 527 U.S. 581 (1999), that “[u]njustified isolation . . . is properly regarded as discrimination based on disability,” observing that “institutional placement of persons who can handle and benefit from community settings perpetuates unwarranted assumptions that persons so isolated areincapable of or unworthy of participatingin community life.” 527 U.S. at 597, 600. 

 

                169)        Plaintiff submits that Defendants' violation of the Title II, Americans With Disabilities Mandate tointegrate Plaintiff also violates the Due Process Clause of the Fifth and Fourteenth Amendments, the Equal Protection Clause of the Fourteenth Amendment and 42 USC §1985, conspiracy tointerfere with civil rights, such that Plaintiff's Verified Complaint rises to the level of an actionin the manner of Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388 with regard to those Defendants who are natural persons. Plaintiff understands the U.S. Supreme Court's application of Bivens to natural persons and its refusal to extend Bivens to agencies. 

 

THIRD CLAIM FOR RELIEF

 

Defendants Violated Sixth Amendment Mandate

 

                170)        Plaintiff repeats and realleges the above paragraphs.

 

                171)        With regard to all natural Defendants, this claim is brought against themindividually and in their official capacities.

 

                172)        Plaintiff is an American citizen with a serious, persistent mental illness. Plaintiff has a mental impairment that substantially limits one or more major life activities…

 

                173)        Plaintiff is a qualifiedindividual with disabilities within the meaning of 42 U.S.C. §12131(2).

 

                174)        Plaintiff is a descendant victim of the African Holocaustin which Africans, whose sale was brokered by Jews and kidnapped by whites, forever lost the ability to bear the correct paternal name of her African male forebears; and having married Defendant Ehigie Edobor Uzamere, now retains the right from now to eternity to have borne and to bear the name of Defendant Ehigie Edobor Uzamere; and that the aforesaid right is retained by Tara A. Uzamere, the adult child of the marriage between Plaintiff and Defendant Ehigie Edobor Uzamere, and for her progeny to bear the correct Edo/Bini name and culture associated with Defendant Ehigie Edobor Uzamere.

 

                175)        On or around June 22, 2011, Defendant Garaufis renderedin decision for Plaintiff's civil rights action which said the following:

 

“Plaintiff's most recent Complaint—one of at least five she has filed with this court—is 89-pages long and is accompanied by 589 pages of exhibits. Plaintiff has also sent at least 60 pages of faxes directly to chambers, purporting to bein connection with her most recent action. The substance of Plaintiffs Complaint—if one can be discerned—concerns, among other things, her divorce from Ehigie Edobor Uzamere; a defamation claim filed against the Daily News; a Departmental Disciplinary Committee complaint filed against the attorney representing the Daily News; and other state court actions, Including a state court action against the attorneys who represented her former husband. (Compi. at 27-45.) Plaintiff has a long, tired history of vexatious litigationin this court. See Uzamere v. State of New York, No. 09-cv-2703 (E.D.N.Y. July 9, 2009).”

 

Defendant Garaufis' judgment regarding Plaintiff's civil rights action was biased. It did not address the acts of fraud, identity theft or aggravated theft perpetrated by corrupt Jewish attorneys Allen E. Kaye, Harvey Shapiro and Jack Gladstein that Plaintiff provedin her civil rights action, nor did Defendant Garaufis' address Plaintiff's contentions regarding the Court's discrimination against Plaintiff based on her having a mental illness. Defendant Garaufis' judicial commentary did not address most of the issues Plaintiff discussedin her civil rights action (“. . .a unanimous Supreme Court has admonished that pro sein forma pauperis complaints must be read with tolerance: Dismissal is impermissible unless the court can say “with assurance that under the allegations of the pro se complaint, which we hold to less stringent standards than formal pleadings drafted by lawyers, it appears 'beyond doubt that the plaintiff can prove no set of factsin support of his claim which would entitle him to relief.'” Haines v. Kerner, 404 U.S. 519, 520-21, 92 S.Ct. 594, 595-96, 30 L.Ed.2d 652 (1972), quoting Conley v. Gibson, 355 U.S. 41, 45-46, 78 S.Ct. 99, 101-102, 2 L.Ed.2d 80 (1957), reaffirmedin Estelle, 429 U.S. at 106, 97 S.Ct. at 292.) The judgment condemned the Verified Complaint's number of pages and the numbers of complaints Plaintiff filed with the Court (“. . .but a complaint filedin forma pauperis is not subject to dismissal simply because the plaintiff is litigious. The number of complaints a poor person files does not alone justify peremptory dismissal.in eachinstance, the substance of the impoverished person's claim is the appropriate measure. Crisafi v. Holland, et al, 655 F2d 1305) Defendant Garaufis admits that he has difficultyin understand ing the substance of Plaintiff's complaint based on his statement: “The substance of Plaintiff's Complaint – if one can be discerned. . .” Defendant Garaufis' displayed even more mean-spirited bias with regard to all of Plaintiff's actions when he saidin his statement: “Plaintiff has a long, tired history of vexatious litigationin this court. Defendant Garaufis engagedin an act of racketeering, obstruction of justice and criminal facilitation of aggravated identity theft by rendering an FRCP-lacking, memorandum-lacking decision regarding Uzamere vs. Cuomo, et al, 11-CV-2831 for the sole purpose of: 1) advancing the Talmudic doctrine Law of the Moser; 2) not filing a criminal complaint against corrupt, dishonest, lying, racketeering, racist Jewish immigration attorneys Allen E. Kaye, Harvey Shapiro and Jack Gladstein for their fraudulent commission of 3) trick Plaintiffinto believing that a res judicata determination – a purely civil adjudicative function – was a permanent and final determination to nullify and render harmless corrupt Jewish attorneys Allen E. Kaye's, Harvey Shapiro's, Jack Gladstein's, and Mortimer Zuckerman's and Scott Shifrel's commission of aggravated identity theft – a wrongful act for which the correct criminal adjudicative function of double jeopardy was never attached because the crime was never tried; and, 4) Defendant Bloom's commission of misprision of felony racketeering, obstruction of justice, criminal facilitation of aggravated identity theft and fraud upon the court as well.

 

                176)        Defendants owed Plaintiff the duty, pursuant to the Sixth Amendment, to provide Plaintiff with defense counsel and witnessesin Plaintiff's favor. More importantly, Defendants owed Plaintiff the right to confront Defendants' adversarial witnessesin order to prevent Plaintiff from being prosecuted based on what turned out to be the falsified hearsay of the Defendants.

 

                177)        Defendants failed to meet the obligations as detailedin the Sixth Amendment. Defendants accused Plaintiff of the commission of 18 USC §111(a), simple assault and 18 USC §115, threatening federal employees and then deprived Plaintiff of her Sixth Amendment rights to notice of accusation, witnesses and appointment of defense counsel even though Defendants' criminal accusation against the Plaintiff required them to file a criminal complaint pursuant to 18 USC §4, misprision of felony. Plaintiff strongly alleges that Defendant Garaufis, In orchestrating the conspiracy with Defendant U.S. Marshal Service, Defendant Denis P. McGowan of Defendant the U.S. Department of Homeland Security, and defendants of the New York State and New York City mental health agencies, has opened the means by which, at any of the Defendants can accuse Plaintiff of any crime and prevent Plaintiff from speaking to an attorney. Plaintiff alleges that the only way that Plaintiff can avoid Defendants'intimidation, false criminal allegations and Defendants ' use of psychiatricinpatient hospitalization as a substitute for prison is by keeping silent and not filing papers against corrupt Jewish immigration attorneys Allen E. Kaye, Harvey Shapiro and Jack Gladstein.

 

                178)        Plaintiff has suffered and continues to sufferinjury because she is still under attack by all the Defendants, who, at the clandestine behest of Defendant Garaufis, have continued the same government-wide hostile environment that Plaintiff complained aboutin her prior lawsuit, Uzamere vs. Cuomo, et al, 11-cv-2831/11-2713-cv. Defendants continue to wrongfully accused Plaintiff of the commission of 18 USC §115, threatening federal employees; nor have the Defendants sent correspondence apologizing for wrongfully accusing Plaintiff of a crime she did not commit; however, Defendants continue to deprive Plaintiff of the right to beinformedin writing of the nature and cause of the criminal accusation Defendants raised against Plaintiff, to allow Plaintiff to confront adversarial witnesses and witnessesin Plaintiff's defense, and to have the assistance of counsel.in Plaintiff's prior lawsuit Uzamere vs. Cuomo, et al Case Nos. 11-cv-2831/11-2713-cv, Plaintiff provided Defendant Garaufis with proof that Defendant New York State conspired with Defendant Daily News, by Defendant former staff writer Scott Shifrelto defame Plaintiff as a “wacko”, to hold Plaintiff out at a violent criminal for a crime or which Plaintiff was eventually declared not guilty – as she was declared not guilty when Defendant McCarthy – a federal attorney – falsely accused Plaintiff of committing 18 USC §111(a), simple assault – while Plaintiff was 260 miles awayin Brooklyn, New York. Defendant Garaufis and the other Defendants – most of whom are Jews, have revisited the same act of fraud for the same reason – to enforce the Jewish religious doctrine Law of the Moser to prevent Plaintiff from filing complaints against corrupt Jewish attorneys Allen E. Kaye, Harvey Shapiro and Jack Gladstein, who hid and continue to hide their aggravated identity theft on behalf of their client, Defendant Ehigie Edobor Uzamere, thereby depriving Plaintiff and her daughter Tara of the right to bear Defendant Ehigie Edobor Uzamere's name.

 

                179)        The courts of Defendant United States of America recognizes a poor defendantin a criminal case that does not have counsel as aninjury. proceedingin Johnson v. Zerbst, 304 U.S. 458 (1938), the Supreme Court ruled thatin all federal cases, counsel would have to be appointed for defendants who were too poor to hire their own.

 

                180)        The courts of Defendant the United States of America recognize that a criminal defendant not having been given a notice of accusation aninjury.individuals who have been accused of a serious federal offense have the right to beinformed of the nature and cause of the accusation against him. The Supreme Court heldin United States v. Carll, 105 U.S. 611 (1881) that “in anindictment ... it is not sufficient to set forth the offensein the words of the statute, unless those words of themselves fully, directly, and expressly, without any uncertainty or ambiguity, set forth all the elements necessary to constitute the offenseintended to be punished.”in Crawford v. Washington, 541 U.S. 36 (2004), the Supreme Courtincreased the scope of the Confrontation Clause by ruling that “testimonial” out-of-court statements areinadmissible if the accused did not have the opportunity to cross-examine that accuser and that accuser is unavailable at trial.

 

                181)        Plaintiff submits that Defendants' violation of the Sixth Amendment's mandate to provide the accused Plaintiff with witnesses, and with an attorney for her defense also violates the Due Process Clause of the Fifth and Fourteenth Amendments, the Equal Protection Clause of the Fourteenth Amendment and 42 USC §1985, conspiracy tointerfere with civil rights, such that Plaintiff's Verified Complaint rises to the level of an actionin the manner of Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388 with regard to those Defendants who are natural persons. Plaintiff understands the U.S. Supreme Court's application ofBivens to natural persons and its refusal to extend Bivens to agencies.

 

FOURTH CLAIM FOR RELIEF

 

Civil Rights Act of 1964, Title VI, §601
Nondiscriminationin Federally Assisted Programs

 

                182)        Plaintiff repeats and realleges the above paragraphs.

 

                183)        With regard to all natural Defendants, this claim is brought against themindividually and in their official capacities.

 

                184)        Plaintiff is an American citizen with a serious and persistent mental illness. Plaintiff has a mental impairment that substantially limits one or more major life activities.

 

                185)        Plaintiff is a qualifiedindividual with disabilities within the meaning of 42 U.S.C. §12131(2).

 

186)        Plaintiff is a descendant victim of the African Holocaustin which Africans, whose sale was brokered by Jews and kidnapped by whites, forever lost the ability to bear the correct paternal name of her African male forebears; having married Defendant Ehigie Edobor Uzamere, Plaintiff now retains the right from now to eternity to have borne and to bear the name of Defendant Ehigie Edobor Uzamere; and that the aforesaid right is retained by Tara A. Uzamere, the adult child of the marriage between Plaintiff and Defendant Ehigie Edobor Uzamere, and for her progeny to bear the correct Edo/Bini name and culture associated with Defendant Ehigie Edobor Uzamere.

 

                187)        Defendants owed Plaintiff the duty, pursuant to the Civil Act of 1964, §601, to ensure that no personin the United States, Including the Plaintiff, shall be excluded from participationin or otherwise discriminated against on the ground of race, color, or national origin under any program or activity receiving Federal financial assistance.

 

                188)        Defendants failed to meet the obligations as detailedin the Civil Rights Act of 1964. Defendants discriminated and continue to discriminate against Plaintiff based on the Talmudic view of Gentilesin general, and blacksin particular. Plaintiff's ethnicity as a gentile/African-American/schvartze. See documentation regarding the Curse of Dark Skin and Law of the Moser attached as Exhibit Q.in addition, while refusing to accept from the Plaintiff irrefutable proof of Jews Allen E. Kaye's, Harvey Shapiro's, Jack Gladstein's, Mortimer Zuckerman's and Scott Shifrel's commission of misprision of felony, fraud, identity theft, aggravated identity theft, racketeering, obstruction of justice and extortion/blackmail, Defendant Barack H. Obama, Andrew Weissman, General Counsel for Defendant Federal Bureau of Investigation, James X. Dempsey, Defendant, Privacy and Civil Liberties Oversight Board; Elisebeth Collins Cook, Defendant, Privacy and Civil Liberties Oversight Board; David Medine, Chairman, Privacy and Civil Liberties Oversight Board; Rachel L. Brand, Privacy and Civil Liberties Oversight Board; and Patricia M. Wald, Defendant, Privacy and Civil Liberties Oversight Board; Keith B. Alexander, General, National Security Agency; Rajesh De, General Counsel, National Security Agency; Eric H. Holder; U.S. Attorney General, U.S. Department of Justice; Charles Schumer, Senate Judiciary Committee; Dianne Feinstein, Senate Select Committee onintelligence Chairperson; Senator Saxby Chambliss, Patrick Leahy, Senator Judiciary Chairman, Hon. Goodlatte, Chairman, U.S. House Judiciary Chairman, Mike Rogers, House Permanent Select Committee onintelligence, U.S. Marshals Service Director Charles Dunne, U.S. Department of Homeland Security, Federal Protection Service, Threat Assessment Branch employee Denis P. McGowan, FBI Assistant Directorin Charge, George Venizelos and Judge Nicholas G. Garaufis engagedin overseeing a criminal, unconstitutional system of government that specifically discriminated against the law-abiding, psychiatric-treatment-compliant, mentally disabled Gentile/Schvartze/African American Plaintiff by allowing Defendant Judge Garaufis and other Jews to fraudulently use the PATRIOT Act to spy on non-criminal, constitutionally-protected telephone calls regarding Plaintiff's HIPAA-protected mental health and other HIPAA-protected issues; that said telephone calls were spied on at the behest of Defendant Judge Garaufis and other Jews, not based on the belief that the Plaintiff had violated the law, but to enslave the Plaintiff by extorting/blackmailing her; by using Plaintiff's confidential, non-contentinformation regarding Plaintiff's telephone calls to her outpatient psychiatric care provider that maybe embarrassing or shameful if publicly disseminated; to fraudulently accuse the Plaintiff of the commission of a crime and to associate the fraudulent criminal allegation with Plaintiff's confidential non-contentinformation; to frighten the Plaintiff by publicizing embarrassing or shamefulinformation associated with Plaintiff's psychiatric non-contentinformation for the sole purpose of forcing the Plaintiff not to petition the government for a redress of grievances with regard to Plaintiff's First Amendment right to report the activities of lawbreaking Jews to the secular/Gentile law enforcement authorities; that those Jews' violation of Plaintiff's and other Gentiles' right to privacy is based on the Talmudic doctrine for Jews to enslave Gentiles, with an emphasis on the enslavement of people who are dark-skinned or considered by Jews to be Africans, Cushites, Hamites and Canaanites. See Exhibit Q.in the meantime, Defendants Allen E. Kaye, Harvey Shapiro, Jack Gladstein, Mortimer Zuckerman and Scott Shifrel, who engagedin illegally obtaining and publicly disseminatinginformation regarding the crime (for which Plaintiff was falsely accused, for which Defendants never had anyintention of confronting Plaintiffin any court of laws and that was eventually dismissed), Plaintiff's mental illness and her marriage and who are still engagingin misprision of felony, fraud, identity theft, aggravated identity theft, racketeering, obstruction of justice and extortion/blackmail have never beeninvestigated for the continued commission of their crimes.

 

                189)        Plaintiff suffered and continues to sufferinjury because she is still under attack by all the Defendants, who, at the clandestine behest of Defendant Garaufis, have continued the same government-wide hostile environment that Plaintiff complained aboutin her prior lawsuit, Uzamere vs. Cuomo, et al, 11-cv-2831/11-2713-cv. Defendants continue to deprive Plaintiff of her civil rights because Plaintiff is a gentile/schvartze.in the case of disruptive Jewish litigant Rebecca Gloria Yohalem, Plaintiff alleges that Defendant Jewish judge Joanna Seybert accepted the Jewish litigant's virtually unintelligible lawsuit.in Defendant Boyle's order regarding the disruptive, Jewish litigant, he said:

 

“The pro se plaintiff appearedin court today for aninitial conference, after having failed to appear at two priorinitial conferences. Her action purports to be one under 42 U.S.C. §1983, based on assault, kidnapping and other various general allegations that allegedly occurred at one or more mental health facilitiesin New York.

 

The pro se plaintiff is virtually deaf and it is therefore difficult for her to participatein any meaningful wayin this litigation - whether itinvolvesinteraction with opposing counsel or the Court. As a result ofthis severe limitation, the plaintiff’s conduct wasinvariably nonresponsive, which undoubtedly led to her frustration at the conference, which, In turn, led to her disruptive behaviorin the courtroom after theinitial conference was concluded.

 

For the foregoing reasons, the Court strongly recommends that the pro se plaintiff seek counsel by contacting William M. Brooks, Professor of Law at the Touro College Jacob D. Fuchsberg Law Center. Touro Law Center has been designated, along with other organizations, as an ombudsperson by the State of New York, under the Protection and Advocacy forindividuals with Mental Illness program (“PAIMI”), to represent patients and former patients at mental hospitalsin the State of New York. These duties are apparently carried out by the Law Center through the Civil Rights Litigation Clinic, which is primarily responsible for patientsin the Long Island area, and of which Professor Brooks is the director. He may be contacted by telephone at (631) 761-7086.”

 

                190)        Defendant Boyle was even able to “purport” a cause of action from the mentally disabled Jewish plaintiff's difficult-to-read complaint.in yet another act of pro-Jew favoritism, the court, at the behest of Defendant Jewish judge Joanna Seybert, the Jewish litigant was allowed to appear – for the thirdinitial conference after missing the first two. During the thirdinitial conference, the Jewish litigant became disruptive. See Complaint of Rebecca Gloria Yohalem attached as Exhibit O.

 

                191)        However, although the African-American Plaintiff went to college to become a paralegal and made the Dean's List twice, has shown the ability to teach herself federal procedural law (FRCP/FRAP/Rules of the Supreme Court), federal statutes, Constitutional law, appellate case law and to apply them to her Verified Complaint on her own and in spite of her mental illness, the only reactions that Plaintiff has received from corrupt, racist Defendant Garaufis and the other Defendants is their mistreatment of the Plaintiff both as a Gentile and as the descendant of African slaves. See Plaintiff's Dean's List certificates attached as Exhibit P.

 

                192)        The courts of Defendant the United States of America recognize that discrimination based on race is aninjury. Discrimination based on race violates the Equal Protection Clause of the Fourteenth Amendment. The Civil Rights Act of 1964 (Pub.L. 88–352, 78 Stat. 241, enacted July 2, 1964) was a landmark piece of legislationin the United States that outlawed major forms of discrimination against racial, ethnic, national and religious minorities, and women. It ended unequal application of voter registration requirements and racial segregationin schools, at the workplace and by facilities that served the general public.

 

                193)        Plaintiff submits that Defendants' violation of Civil Rights Act of 1964, Title VI, §601 because Plaintiff's is an “inferior” gentile/African-American/schvartze who continues to file complaints against corrupt “superior” Jews immigration attorneys Allen E. Kaye, Harvey Shapiro and Jack Gladstein also violates the Due Process Clause of the Fifth and Fourteenth Amendments, the Equal Protection Clause of the Fourteenth Amendment and 42 USC §1985, conspiracy against civil rights such that Plaintiff's Verified Complaint rises to the level of an actionin the manner of Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388 with regard to those Defendants who are natural persons only. Plaintiff understands the U.S. Supreme Court's application of Bivens to natural persons and its refusal to extend Bivens to agencies.

 

FIFTH CLAIM FOR RELIEF

 

Defendants are a Racketeerinfluenced Corrupt Organization

 

                194)        Plaintiff repeats and realleges the above paragraphs.

 

                195)        With regard to all natural Defendants, this claim is brought against themindividually and in their official capacities.

 

                196)        Plaintiff is an American citizen with a serious and persistent mental illness. Plaintiff has a mental impairment that substantially limits one or more major life activities.

 

                197)        Plaintiff is a qualifiedindividual with disabilities within the meaning of 42 U.S.C. §12131(2).

 

                198)        Plaintiff is a descendant victim of the African Holocaustin which Africans, whose sale was brokered by Jews and kidnapped by whites, forever lost the ability to bear the correct paternal name of her African male forebears; and having married Defendant Ehigie Edobor Uzamere, now retains the right from now to eternity to have borne and to bear the name of Defendant Ehigie Edobor Uzamere; and that the aforesaid right is retained by Tara A. Uzamere, the adult child of the marriage between Plaintiff and Defendant Ehigie Edobor Uzamere, and for her progeny to bear the correct Edo/Bini name and culture associated with Defendant Ehigie Edobor Uzamere.

 

                199)        Defendants owed Plaintiff the duty not to engagein racketeering behavior for the purpose of making Plaintiff a victim of honest services fraud at the hands of the Defendants, thereby preventing Plaintiff and her daughter, Tara from retaining the correct African name that they should have received from Defendant Ehigie Edobor Uzamere, based on Defendant New York City's and the U.S. Department of Homeland Security's recognition of Plaintiff's and her daughter Tara's relationship with Defendant Ehigie Edobor Uzamere through marriage and bloodline.

 

                200)        Defendants failed to meet their obligation by not engagingin those behaviors that areindicative of a racketeering-influenced, corrupt organization as detailedin 18 USC 18 USC §§1961–1968. Defendants engagedin racketeering for the sole purpose of 1) advancing the Talmudic doctrine Law of the Moser so as to prevent Plaintiff from filing her complaint against corrupt, Jewish immigration attorneys Allen E. Kaye, Harvey Shapiro and Jack Gladstein, thereby forever depriving Plaintiff and her daughter Tara of their right to bear the African name of Defendant Ehigie Edobor Uzamere. Plaintiff alleges that the only way that Plaintiff can avoid Defendants' racketeering is by keeping silent and not filing papers against corrupt Jewish Defendants Allen E. Kaye, Harvey Shapiro and Jack Gladstein.

 

                201)        Plaintiff suffered and continues to sufferinjury because she is still under attack by all the Defendants, who, at the clandestine behest of Defendant Garaufis, have continued the same government-wide hostile environment that Plaintiff complained aboutin her prior lawsuit, Uzamere vs. Cuomo, et al, 11-cv-2831/11-2713-cv. Plaintiff holds that Defendant Garaufis and rest of the Defendants engagedin racketeering by engagingin the following acts, to wit:

 

                                a)            that Defendants Allen E. Kaye, Harvey Shapiro, Jack Gladstein and Osato Eugene Uzamere engagedin racketeeringin that they committed 18 USC §1028, thereby 1) knowingly and without lawful authority, produced a false identification document knowing that such document was produced without lawful authority; 2) knowingly possessed a false identification document with theintent that such document be used to defraud the United States; 3) knowingly transferred the fraudulent affirmations to Defendant the New York State Unified Court System without lawful authority; 4) transferred a means of identification of another person with theintent to commit, or to aid or abet, orin connection with, any unlawful activity that constitutes a violation of Federal law, or that constitutes a felony under any applicable State or local law; with all the Defendants' goal to complete their act of racketeering by ensuring that Plaintiff and her daughter Tara never be able to file her complaint against corrupt Jewish immigration attorneys Allen E. Kaye, Harvey Shapiro and Jack Gladstein, and thereby forever be deprived of their right to bear Defendant Ehigie Edobor Uzamere's correct African name.

 

                                b)            that Defendants Garaufis, Schack, Sunshine, Cutrona and Gerstein engagedin racketeeringin that they committed 18 USC §1512in that they used physical force and the threat of physical force with theintent to: 1) prevent Plaintiff's testimony against corrupt Jewish immigration attorneys Allen E. Kaye, Harvey Shapiro and Jack Gladstein; 2) that the aforesaid defendants caused Plaintiff to withhold her testimony against corrupt Jewish immigration attorneys Allen E. Kaye, Harvey Shapiro and Jack Gladstein; 3) that the aforesaid defendant – especially Defendant Schack forced Plaintiff to be absent from an official proceeding to which that person has been summoned by legal process; 4) That the aforementioned defendants knowingly usesintimidation, threats, and corruptly persuaded the New York City Police Department and the New York City Fire Department, with theintent to prevent Plaintiff from giving testimony regarding the commission of aggravated identity theft by corrupt Jewish immigration attorneys Allen E. Kaye, Harvey Shapiro and Jack Gladstein conspiracy.

 

                c)             that Defendant Osato E. Uzamere engagedin racketeeringin that he committed 18 USC §1543, false use of passport. Defendant Osato E. Uzamere falsely made a copy of aninstrument purporting to be the passport of Defendant Ehigie Edobor Uzamere, withintent that the same may be usedin court by Defendant Sunshine as a means to pretend to identify Defendant Ehigie Edobor Uzamere. See copies of passport bearing the number A0588053 but bearing no name is attached as Exhibit C;

 

                d)            that Defendant Osato E. Uzamere engagedin racketeeringin that he committed 18 USC 1028A, false use of a social security number. Defendant Osato E. Uzamere falsely made a copy of aninstrument bearing the number XXX-XX-1205 purporting to be the social security number of “Godwin Uzamere”, a fictitious identity that was used to defraud the Plaintiff. See copy ofinstrument bearing false social security number attached as Exhibit C.

 

                202)        The courts of Defendant the United States of America recognize that obstruction of justice caused by racketeeringinfluenced, corrupt organizations as aninjury. RICO laws were successfully citedin NOW v. Scheidler, 510 U.S. 249, 114 S. Ct. 798, 127 L.Ed. 2d 99 (1994), a suitin which certain parties, Including the National Organization for Women, sought damages and aninjunction against pro-life activists who physically block access to abortion clinics. Amazingly, the Court held that a RICO enterprise does not need an economic motive, and that the Pro-Life Action Network could therefore qualify as a RICO enterprise.in the federal lawsuit against judges Michael Conahan and Mark Ciavarella, federal grand juryin the Middle District of Pennsylvania handed down a 48-countindictment against former Luzerne County Court of Common Pleas Judges Michael Conahan and Mark Ciavarella. The judges were charged with RICO after allegedly committing acts of wire fraud, mail fraud, tax evasion, money laundering, and honest services fraud. The judges were accused of taking kickbacks for housing juveniles, that the judges convicted for mostly petty crimes, at a private detention center. Theincident was dubbed by many local and national newspapers as the “Kids for cash scandal”. On February 18, 2011, a federal jury found Michael Ciavarellaguilty of racketeering because of hisinvolvementin accepting illegal payments from Robert Mericle, the developer of PA Child Care, and Attorney Robert Powell, a co-owner of the facility. Ciavarella is facing 38 other countsin federal court.

 

                203)        Plaintiff submits that Defendants' commission of racketeering violates the Due Process Clause of the Fifth and Fourteenth Amendments, the Equal Protection Clause of the Fourteenth Amendment and 42 USC §1985, conspiracy against civil rights such that Plaintiff's Verified Complaint rises to the level of an actionin the manner of Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388 with regard to those Defendants who are natural persons only. Plaintiff understands the U.S. Supreme Court's application of Bivens to natural persons and its refusal to extend Bivens to agencies.

 

SIXTH CLAIM FOR RELIEF

 

Fraud upon the Court

 

                204)        Plaintiff repeats and realleges the above paragraphs.

 

                205)        With regard to all natural Defendants, this claim is brought against themindividually and in their official capacities.

 

                206)        Plaintiff is an American citizen with a serious and persistent mental illness. Plaintiff has a mental impairment that substantially limits one or more major life activities.

.

                207)        Plaintiff is a qualifiedindividual with disabilities within the meaning of 42 U.S.C. §12131(2).

 

                208)        Plaintiff is a descendant victim of the African Holocaustin which Africans, whose sale was brokered by Jews and kidnapped by whites, forever lost the ability to bear the correct paternal name of her African male forebears; and having married Defendant Ehigie Edobor Uzamere, now retains the right from now to eternity to have borne and to bear the name of Defendant Ehigie Edobor Uzamere; and that the aforesaid right is retained by Tara A. Uzamere, blood heir and the adult child of the marriage between Plaintiff and Defendant Ehigie Edobor Uzamere, and for her progeny to bear the correct Edo/Bini name and culture associated with Defendant Ehigie Edobor Uzamere.

 

                209)        Defendants owed Plaintiff the duty to provide her with honest judicial services, free from fraud. Defendants owed Plaintiff the duty to render decisionsin her lawsuits that were reflective of their recognition of the aggravated identity theft committed by Defendants Allen E. Kaye, Harvey Shapiro, Jack Gladstein and Osato E. Uzamere. Defendants owed Plaintiff the duty to file a criminalinstrument against the aforementioned attorney, and to not allow their own Talmudic bias to affect their obligation to support and defend the Constitution of the United States against all enemies, foreign and domestic; to bear true faith and allegiance to the same; to take said obligation freely, without any mental reservation or purpose of evasion; and to well and faithfully discharge the duties of the office on which Defendants entered. Defendants owed Plaintiff the duty to establish a clear separation of church and state, and to distance themselves from the Talmudic Law of the Moserin their application and enforcement of the law. Defendants owed Plaintiff and her children the duty to give themselves over to the transparency of U.S. law, and not the secrecy of the Talmudic Law of the Moser – a stupid law that is stupid for Defendants to enforce since the Defendants actively keep said law secret from Gentiles. It is stupid for Defendants to force Plaintiff – and the public at large – to obey a law that they do not know they are supposed to obey and is not transparentlyincludedin any normal law code.

 

                210)        Defendants failed to meet the obligations as detailedin Bulloch v. United States. Defendant judges engaged rendering fraudulent decisions, and then commenced a extortionate shakedown from the judicial positions of Defendants Garaufis, Schack, Sunshine and Gerstein for the sole purpose of advancing the Talmudic doctrine Law of the Moser so as to prevent Plaintiff from filing her complaint against corrupt, Jewish immigration attorneys Allen E. Kaye, Harvey Shapiro and Jack Gladstein, thereby forever depriving Plaintiff and her daughter Tara of their right to bear the African name of Defendant Ehigie Edobor Uzamere. Plaintiff alleges that the only way that Plaintiff can avoid Defendants'intimidation, false criminal allegations and Defendants' racial discrimination against her is by keeping silent and not filing papers against corrupt Jewish Defendants Allen E. Kaye, Harvey Shapiro and Jack Gladstein.

 

                211)        Plaintiff suffered and continues to sufferinjury because she is still under attack by all the Defendants judges has have rendered biased decisions designed to hide Defendant judges' commission of misprision of felony with regard to Defendants Allen E. Kaye's, Harvey Shapiro's, Jack Gladstein's and Osato E. Uzamere's commission of aggravated identity theft. Defendants, at the clandestine behest of Defendant Garaufis, have continued the same government-wide hostile environment that Plaintiff complained aboutin her prior lawsuit, Uzamere vs. Cuomo, et al, 11-cv-2831/11-2713-cv.in every single casein which Plaintiff presented irrefutable proof that immigration attorney Allen E. Kaye, Harvey Shapiro and Jack Gladstein engagedin criminally facilitating the immigration fraud and identity fraud of Plaintiff's ex-husband, the Defendant judgein that case would render a decision that would ignore Defendant attorneys of any criminal liability, or worse, they conspired with other Defendants to accuse Plaintiff of being too mentally disabled and violent to use the court system. The defendant judges acted, not as judges, but as Talmudic attorneys for the corrupt, Jewish immigration attorneys, leaving the position of judge unfilled by a U.S. Constitution-obeying, unbiased judge. Their actions stink of fraud upon the court, which under the U.S. Courts of Appeal for the Seventh and Tenth Circuit, renders any decision rendered by them null and void. Lastly, Defendant Jewish judges rendered fictitious decision to their true motive – to Talmud-based decisions against the Plaintiff because she is Gentile, because she is black-skinned, and because of the Talmudic doctrine Law of the Moser that prohibits the Defendants from directly orindirectly filing complaints against corrupt Jewish immigration attorneys Allen E. Kaye, Harvey Shapiro, Jack Gladstein. See Defendant Daily News article dated November 5, 2009, attached as Exhibit R.

 

                212)        The courts of Defendant the United States of America recognize that fraud upon the court is aninjury.in Bulloch v. United States, 763 F.2d 1115, 1121 (10th Cir. 1985), the court stated “Fraud upon the court is fraud which is directed to the judicial machinery itself and is not fraud between the parties or fraudulent documents, false statements or perjury. . .It is where the court or a member is corrupted orinfluenced orinfluence is attempted or where the judge has not performed his judicial function --- thus where the impartial functions of the court have been directly corrupted.” Fraud upon the court is aninjury because it deprives a litigant of the court's most valuable “commodity” – justice.

 

                213)        Plaintiff submits to this Court that Defendant Judge Garaufis' commencement and orchestration to defame Plaintiff as psychotic and violent to stop her from filing her appeal against his FRCP-lacking, memorandum-lacking decision are irrefutable proof that his decisionin Plaintiff's lawsuit Uzamere vs. Cuomo, et al was biased, and is an act of fraud upon the court the violates the Due Process Clause of the Fifth and Fourteenth Amendments, the Equal Protection Clause of the Fourteenth Amendment and 42 USC §1985, conspiracy against civil rights such that Plaintiff's Verified Complaint rises to the level of an actionin the manner of Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388 with regard to those Defendants who are natural persons only. Plaintiff understands the U.S. Supreme Court's application of Bivens to natural persons and its refusal to extend Bivens to agencies.

 

SEVENTH CLAIM FOR RELIEF

 

Defendants' Blacklisting of Plaintiff Violates 42 U.S.C. §1983, §1985

 

                214)        Plaintiff repeats and realleges the above paragraphs.

 

                215)        With regard to all Defendants, this claim is brought against themindividually and in their official capacities.

 

                216)        Plaintiff is an American citizen with a serious and persistent mental illness. Plaintiff has a mental impairment that substantially limits one of more major life activities.

 

                217)        Plaintiff is a descendant victim of the African Holocaustin which Africans, whose sale was brokered by Jews and kidnapped by whites, forever lost the ability to bear the correct paternal name of her African male forebears; and having married Defendant Ehigie Edobor Uzamere, now retains the right from now to eternity to have borne and to bear the name of Defendant Ehigie Edobor Uzamere; and that the aforesaid right is retained by Tara A. Uzamere, blood heir and the adult child of the marriage between Plaintiff and Defendant Ehigie Edobor Uzamere, and for her progeny to bear the correct Edo/Bini name and culture associated with Defendant Ehigie Edobor Uzamere.

 

                218)        Defendants owed Plaintiff the duty to not blacklist Plaintiffin the Jewish Defendants' continued attempts to stop filing criminal complaints against Defendants Allen E. Kaye, Harvey Shapiro and Jack Gladstein. Defendants owed Plaintiff the duty to make their federally-financed outpatient mental health and other programs available to the Plaintiff program free from fraud. Defendants owed Plaintiff the duty to recognize Plaintiff's complaints against the aforementioned attorneys as true, and not trick Plaintiffinto believing that Defendants' blacklisting were legitimate acts brought on by wrongful acts by the Plaintiff. Defendants owed Plaintiff the duty not to render Plaintiff persona non grata based on the Jewish Defendants' desire to enforce the Talmudic doctrine Law of the Moser, that prohibits Jews fromindirectly or directly filing complaints against fellow Jews who have violated secular law.

 

                219)        Defendants failed to meet the obligations as detailedin 42 USC §1983, 1985. Defendant judges engagedin blacklisting the Plaintiff from the New York State courts, from the federal courts, and from receiving outpatient mental health services, In order to engagein racketeering/obstruction of justice for the sole purpose of advancing the Talmudic doctrine Law of the Moser, that prohibits Jews fromindirectly or directly reporting the wrongdoings of fellow Jews to the secular/gentile authorities. Plaintiff alleges that the only way that Plaintiff can avoid Defendants' blacklisting, Intimidation, false criminal allegations and Defendants' racial discrimination against her is by keeping silent and not filing a criminal complaint against corrupt Jewish Defendants Allen E. Kaye, Harvey Shapiro and Jack Gladstein.

 

                220)        Plaintiff suffered and continues to sufferinjury because she is still under attack by all the Defendants like FEGS, Inc., who still have Plaintiff listed as persona non grata for life. Defendant judges Eileen A. Rakower and Nicholas Garaufis have come to Defendant FEGS aid, by allowing FEGS to blacklist Plaintiff because Plaintiff used Defendant FEGS, Inc Services for complaining against Defendants Allen E. Kaye, Harvey Shapiro and Jack Gladstein's commission of aggravated identity theft. See Defendant Daily News article dated November 5, 2009, attached as Exhibit R.

 

                221)        The courts of Defendant the United States of America recognize that blacklisting is aninjury – and a constitutional tort as well. Mr. Justice Blackin his concurring opinionin the U.S. Supreme Court case Joint Anti-Fascist Refugee Committee v. McGrath, 341 U.S. 123, 144-145, 71 S.Ct. 624, 634 (1951): stated: “Our basic law, however, wisely withheld authority for resort to executive. . .condemnations and blacklists as a substitute for imposition of legal types of penalties by courts following trial and convictionin accordance with procedural safeguards of the Bill of Rights.”

 

                222)        Plaintiff submits to this Court that the Defendants – especially the Jewish Defendants' orchestration of a hostile environment to exclude Plaintiff from government-financed judicial, legal, and medical services to prevent Plaintiff from reporting the aforesaid Jewish immigration attorneys' commission of aggravated identity theft to the appropriate law enforcement authorities, violates the Due Process Clause of the Fifth and Fourteenth Amendments, the Equal Protection Clause of the Fourteenth Amendment and 42 USC §1983 and §1985, conspiracy against civil rights such that Plaintiff's Verified Complaint rises to the level of an actionin the manner of Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388 with regard to those Defendants who are natural persons only. Plaintiff understands the U.S. Supreme Court's application of Bivens to natural persons and its refusal to extend Bivens to agencies.

 

EIGHTH CLAIM FOR RELIEF

 

Defendantsinvaded Plaintiff's Privacy Based onintentional Misuse of NSL
or Based on Obtaining Non-NSL, Non-Contentinformation Illegally

 

                223)        Plaintiff repeats and realleges the above paragraphs.

 

                224)        With regard to all Defendants, this claim is brought against themindividually and in their official capacities.

 

                225)        Plaintiff is an American citizen with a serious and persistent mental illness. Plaintiff has a mental impairment that substantially limits one of more major life activities.

.

                226)        Plaintiff is a descendant victim of the African Holocaustin which Africans, whose sale was brokered by Jews and kidnapped by whites, forever lost the ability to bear the correct paternal name of her African male forebears; and having married Defendant Ehigie Edobor Uzamere, now retains the right from now to eternity to have borne and to bear the name of Defendant Ehigie Edobor Uzamere; and that the aforesaid right is retained by Tara A. Uzamere, blood heir and the adult child of the marriage between Plaintiff and Defendant Ehigie Edobor Uzamere, and for her progeny to bear the correct Edo/Bini name and culture associated with Defendant Ehigie Edobor Uzamere.

 

                227)        Defendants owed Plaintiff the duty not toinvade Plaintiff's privacy by using the non-contentinformation regarding Plaintiff's telephone calls to psychiatric service providers and to government healthcare providers to accuse Plaintiff of crimes that were used to illegally rationalize Defendant Garaufis' dismissal of Plaintiff's civil rights action. Defendants owed Plaintiff the duty not toinvade Plaintiff's privacy by using the non-contentinformation regarding Plaintiff's telephone calls to psychiatric care providers and government healthcare providers to illegally rationalize extortionate/threatening telephone calls and visits to Plaintiff's home. Defendants owed Plaintiff the duty not toinvade Plaintiff's privacy by using the non-contentinformation regarding Plaintiff's telephone calls to psychiatric service providers and government healthcare providers to accuse Plaintiff of crimes that were used to kidnap Plaintiff and unlawfully imprison/illegally misdiagnose Plaintiff for crimes that she never committed.

 

                228)        Defendants failed to meet the obligations as detailedin 18 USC §2709 and Griswold v. Connecticut, 381 U.S. 479 (1965). Defendants, In their haste to libel Plaintiff as a violent, lawbreaking “wacko” to make Plaintiff's complaint against them appear to be unbelievable, Defendant judges conspired with Defendants Jewish billionaire Mortimer Zuckerman and Jewish staff writer Scott Shifrel of the Daily News, LP to disseminate confidential, nonpublicinformation regarding Plaintiff's mental illness and her marriage on paper and in theinternet – with theinternet still disseminating the false story regarding the Plaintiff. Plaintiff is still being attacked by several members of the Jewish community to prevent her from successfully filing her complaint against the original lawbreaking attorneys, corrupt immigration attorneys Allen E. Kaye, Harvey Shapiro and Jack Gladstein.

 

                229)        Plaintiff suffered and continues to sufferinjury because she is still under attack by all the Defendants. See Defendant Daily News article dated November 5, 2009, attached as Exhibit R.

 

                230)        The courts of Defendant the United States of America recognize theintentional misuse of an NSL as aninjury – and a constitutional tort as well. Mr. Justice Blackin his concurring opinionin the U.S. Supreme Court case Joint Anti-Fascist Refugee Committee v. McGrath, 341 U.S. 123, 144-145, 71 S.Ct. 624, 634 (1951): stated: “Our basic law, however, wisely withheld authority for resort to executive. . .condemnations and blacklists as a substitute for imposition of legal types of penalties by courts following trial and convictionin accordance with procedural safeguards of the Bill of Rights.”

 

                231)        Plaintiff submits to this Court that the Defendants – especially the Jewish Defendants' orchestration of a hostile environment to exclude Plaintiff from government-financed judicial, legal, and psychiatric services to prevent Plaintiff from reporting the aforesaid Jewish immigration attorneys' commission of fraud, identity theft and aggravated identity theft to the appropriate law enforcement authorities, violates the Due Process Clause of the Fifth and Fourteenth Amendments, the Equal Protection Clause of the Fourteenth Amendment and 42 USC §1983 and §1985, conspiracy against civil rights such that Plaintiff's Verified Complaint rises to the level of an actionin the manner of Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388 with regard to those Defendants who are natural persons only. Plaintiff understands the U.S. Supreme Court's application of Bivens to natural persons and its refusal to extend Bivens to agencies.

 

NINTH CLAIM FOR RELIEF

 

Congressional Defendants Engagedin Campaign Bribery to Advance the Talmudic
Law of the Moser; Congressional Defendants Deprived Plaintiff and Gentiles of Honest Services

 

                232)        Plaintiff repeats and realleges the above paragraphs.

 

                233)        With regard to all Defendants, this claim is brought against themindividually and in their official capacities.

 

                234)        Plaintiff is an American citizen with a serious and persistent mental illness. Plaintiff has a mental impairment that substantially limits one of more major life activities.

 

                235)        Plaintiff is a descendant victim of the African Holocaustin which Africans, whose sale was brokered by Jews and kidnapped by whites, forever lost the ability to bear the correct paternal name of her African male forebears; and having married Defendant Ehigie Edobor Uzamere, now retains the right from now to eternity to have borne and to bear the name of Defendant Ehigie Edobor Uzamere; and that the aforesaid right is retained by Tara A. Uzamere, blood heir and the adult child of the marriage between Plaintiff and Defendant Ehigie Edobor Uzamere, and for her progeny to bear the correct Edo/Bini name and culture associated with Defendant Ehigie Edobor Uzamere.

 

                236)        Defendant Jeffries and his congressional staff, owed Plaintiff the duty, pursuant to 18 USC §4, to report the crimes that Plaintiff reported to him to the U.S. Department of Justice, the U.S. Department of Homeland Security and other Defendants. Plaintiff alleges that Defendant Jeffries and his congressional staff had, In de jure, thana de facto responsibility to the Plaintiff to ensure that Plaintiff's criminal complaint would beinvestigated or would be presented to Defendants U.S. Department of Justice and the U.S. Department of Homeland Security forinvestigation.

 

                237)        Defendant Jeffries, his congressional staff and Jews who contributed financially to Defendant Jeffries' congressional campaign owed Plaintiff the duty to ensure that they not engagein quid pro quo campaign contributions that were provided/accepted with the understand ing that the aforementioned were bribes used to require Defendant Jeffries and his staff to engagein activities that would advance Jewish religion and culture, Including the Talmudic doctrine Law of the Moser, at the expense of violating the civil rights of Gentile constituents, especially the Due Process and Equal Protection clauses of the U.S. Constitution.

 

                238)        Defendant Jeffries, his congressional staff and Jews who contributed financially to Defendant Jeffries' congressional campaign owed Plaintiff the duty to allow her the same type of free access to call and visit Defendant Jeffries' offices as the Jews who contributed money to Defendant Jeffries' congressional campaign, and to not conspire to blacklist the Plaintiff based on herinsistence to obtain help from Defendant Jeffries to report those Defendants – especially those Defendants who are Jewish, for Defendants' commission of misprision of felony, fraud,  deprivation of rights under color of law, conspiracy tointerfere with civil rights, racketeering, obstruction of justice, extortion/blackmail, blacklisting and violation of the PATRIOT Act.

 

                239)        Defendant Jeffries and his congressional staff, failedin their duty, pursuant to 18 USC §4, to report the crimes that Plaintiff reported to him, to the U.S. Department of Justice, the U.S. Department of Homeland Security and other Defendants. Plaintiff alleges that Defendant Jeffries and his congressional staff failedin de jure, or de facto responsibility to the Plaintiff to ensure that Plaintiff criminal complaint would beinvestigated or would be presented to Defendants U.S. Department of Justice and the U.S. Department of Homeland Security forinvestigation.

 

                240)        Defendant Jeffries, his congressional staff and Jews who contributed financially failedin their duty to ensure that they not engagein qui pro quo campaign contributions that were provided/accepted with the understand ing that the aforementioned were bribes used to require Defendant Jeffries and his staff to engagein activities that would advance Jewish religion and culture, Including the Talmudic doctrine Law of the Moser, the prohibits Jews from reporting crimes of fellow Jews to the secular/Gentile authorities, at the expense of violating the civil rights of Gentile constituents, especially the Due Process and Equal Protection clauses of the U.S. Constitution.

 

                241)        Defendant Jeffries, his congressional staff and Jews who contributed financially to Defendant Jeffries' congressional campaign failedin their duty to allow Plaintiff the same type of free access to call and visit Defendant Jeffries' offices as the Jews who contributed money to Defendant Jeffries' congressional campaign; that Defendant Jeffries, his congressional staff and Jews who contributed financially to Defendant Jeffries' congressional campaign failedin their duty not to conspire to blacklist the Plaintiff based on herinsistence to obtain help against those Jews whom Plaintiff has proven committed misprision of felony, fraud, deprivation of rights under color of law, conspiracy tointerfere with civil rights, racketeering, obstruction of justice, extortion/blackmail and blacklisting.

 

                242)        Plaintiff suffered and continues to sufferinjury because she is still under attack by all the Defendants. See Defendant Daily News article dated November 5, 2009, attached as Exhibit R.

               

                243)        The courts of Defendant the United States of America recognize the acceptance of a bribe by a public servant as aninjury cognizablein law.  

 

                244)        Plaintiff submits to this Court that the Defendants – especially the Jewish Defendants' orchestration of a hostile environment to exclude Plaintiff from government-financed judicial, legal, and psychiatric services to prevent Plaintiff from reporting the aforesaid Jewish immigration attorneys' commission of fraud, identity theft and aggravated identity theft to the appropriate law enforcement authorities, violates the Due Process Clause of the Fifth and Fourteenth Amendments, the Equal Protection Clause of the Fourteenth Amendment and 42 USC §1983 and §1985, conspiracy against civil rights such that Plaintiff's Verified Complaint rises to the level of an actionin the manner of Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388 with regard to those Defendants who are natural persons only. Plaintiff understands the U.S. Supreme Court's application of Bivens to natural persons and its refusal to extend Bivens to agencies.

 

This Court Must Enforce

28 USC §455, 28 USC §1404, 28 USC §1654 and 28 USC §144
to Protect Pro Se Plaintiff's Right to Self-Representation

 

                245)        28 USC §144 says: “Whenever a party to any proceedingin a district court makes and files a timely and sufficient affidavit that the judge before whom the matter is pending has a personal bias or prejudice either against him orin favor of any adverse party, such judge shall proceed no further therein, but another judge shall be assigned to hear such proceeding.”

 

                246)        28 USC §455 says: “(a) Any justice, judge, or magistrate judge of the United States shall disqualify himselfin any proceedingin which his impartiality might reasonably be questioned. (b) He shall also disqualify himselfin the following circumstances: (5) He or his spouse, or a person within the third degree of relationship to either of them, or the spouse of such a person.”

 

                247)        28 USC §1404(a) says: “For the convenience of parties and witnesses, In theinterest of justice, a district court may transfer any civil action to any other district or division where it might have been brought or to any district or division to which all parties have consented.”

 

                248)        28 USC §1654 says: “In all courts of the United States the parties may plead and conduct their own cases personally or by counsel as, by the rules of such courts, respectively, are permitted to manage and conduct causes therein.”

 

                249)        Plaintiff alleges that if any judgein the Eastern District or Southern District of New York gets his/her hands on Plaintiff's lawsuit, even though he/she is a defendant, he/she will violate 28 USC §455, 28 USC §1404, 28 USC §1654 and 28 USC §144, and make a ruling dismissing Plaintiff's case based on: 1) halachic law's mandate not to report the crimes of corrupt Jews Allen E. Kaye, Harvey Shapiro, Jack Gladstein, Mortimer Zuckerman and Scott Shifrel to the secular authorities, 2) judicial nepotism based on their desire to save Defendant Garaufis from being prosecuted; and, 3) their ability to hide any act of fraud upon the court on Plaintiff's being aninexperienced, mentally disabled pro se litigant. If Plaintiff appeals to the U.S. Court of Appeals to the Second Circuit, even though its judges are also defendants presently engagedin the commission of several federal offenses, they will violate 28 USC §455, 28 USC §1404, 28 USC §1654 and 28 USC §144, and make an unexplained ruling dismissing Plaintiff's case based on: 1) halachic law's mandate not to report the crimes of corrupt Jews Allen E. Kaye, Harvey Shapiro, Jack Gladstein, Mortimer Zuckerman and Scott Shifrel to the secular authorities; judicial nepotism based on their desire to save Defendant Garaufis from being prosecuted; and, 3) their ability to hide any act of fraud upon the court on Plaintiff's being aninexperienced, mentally disabled pro se litigant. Defendant Garaufis will also depend on law enforcement agencies like the FBI to illegally monitor Plaintiff and to hospitalize Plaintiff for any action that can be misconstrued as warranting long-term psychiatric hospitalization so that Plaintiff can be “jailed” for having a mental illness without the benefits of a notice of accusation, a defense attorney and a chance to confront adversarial witnesses. When Plaintiff last checked, an employee of Defendant FBI contacted Plaintiff's psychiatric treatment provider to tell them that Plaintiff had an argument with them about her rights to file criminal complaints against Jewish persons who violated federal law, treating Plaintiff'sinsistence as mentalinstability. Defendant Garaufis also setin motion Plaintiff's being falsely accused of committing 115, threatening Defendant Garaufis with bodily harm, other federal judges, and employees of the Centers for Medicare and Medicaid Services call center with death. Defendant Garaufisinstigated the violation of Plaintiff's Sixth Amendment rights (Plaintiff was able to confront the Centers for Medicare and Medicaid Services. They confirmed that Plaintiff did not threaten anyone). Lastly, Defendant Garaufis setin motion the kidnapping and unlawful imprisonment of Plaintiffin a mentalinstitution for a federal offense/psychiatric diagnosis which Plaintiff did not commit. This Court, pursuant to 4, misprision of felony owes both the Plaintiff and the Constitution of the United States to enforce the law.

 

                250)        Defendant United States' statutes have justly made arrangements to ensure that any justice, judge, or magistrate judge of the United States disqualifies himself/herselfin any proceedingin which a judge's impartiality might reasonably be questioned.in theinterest of justice and mercy, federal statutes, along with case law, have arranged that a district court may transfer any civil action to any other district or division where it might have been brought or to any district or division to which all parties have consented –in the bestinterest of justice. However, while U.S. Constitutional law ensures that any decisionin any court of the U.S. States reflect that the Due Process Clause and the Equal Protection Clause of the Fifth and Fourteenth Amendments areincorporatedin all U.S. judges' decisions, sometimes dishonest federal judges canintentionally misconstrue federal statutesin a way that allows the meritless dismissal of a pro se litigant's cases, simply because a pro se litigant's cases are automatically viewed as lacking merit, or worse, because the pro se litigant's case has merit but addresses legal issues against which the judge has a bias.

 

                251)       in the case of the pro se Plaintiff, Plaintiff alleges that any Defendant judge against whom her action is filed has already conspired with defendants' attorneys not to enterinto any stipulation with the Plaintiff to transfer her lawsuit to an unbiased venue/venue that does not have a Jewish majority. Furthermore, none of the defendants have reported or will report attorneys Allen E. Kaye, Harvey Shapiro, Jack Gladstein, Osato Eugene Uzamere and Ehigie Edobor Uzamere for their commission of aggravated identity theft. Plaintiff alleges that a disproportionate percentage of the second district's federal judges will adjudicate Plaintiff's lawsuitin favor of those members of the judiciary and defendants who are adherents of Talmudic doctrines such as: 1) Law of the Moser;23 2) Curse of Dark Skin;24 3) Judaism, American's New Government Religion;25 4) Only a Jew Can Rule Over Jews;26 5) Gentiles, rightful slaves of Jews;27 6) Use of Subterfuge to Trick Goyim During Lawsuits;28 and, 7) A Gentile's Lost Item Must Not Be Returned if Based on Compassion.29 Because of the Second Circuit's religious imbalance of power, non-adherent judges, who Judaic law does not benefit, In attempts to keep their jobs and social stand ing, participatein rendering decisions that honor and due obeisance to Judaism.in the Second Circuit, Plaintiff's attempts to have the court enforce 28 USC §455, 28 USC §1404, 28 USC §1654 and 28 USC §144 are a death knell for Plaintiff's lawsuit. Most of the judges are Jews. Plaintiff does not understand how the Second Circuit was able to hirein such a manner as to hire a Jewish majority, or at least a disproportionately high percentage of Jews.

 

                252)        This court must display the legal, moral and constitutional fortitude to assist the pro se Plaintiff to enforce 28 USC §455, 28 USC §1404, 28 USC §1654 and 28 USC §144. Judicial Defendants' district – essentially a beth din where pro se litigants are concerned, must not be allowed to secretly enforce halachic doctrines by relying on the presumed naivéte of pro se litigants who have meritorious claims that corrupt, federal and New York State judges ignore because of judges' own personal, unconstitutional biases. Decisions rendered by the Second Circuit's Talmud-biased federal judges, which have been discarded by such terms as “not for publication” or “mandate,” but make absolutely no mention of the meritorious issuesin the pro se litigant's appeal should be noticed by a trained and unbiased judicial eye as an act of fraud upon the court. This Court must ensure that the pro se Plaintiff can rely on its unbiased services to enforce 28 USC §455, 28 USC §1404, 28 USC §1654 and 28 USC §144. See Liteky v. U.S., 114 S.Ct. 1147, 1162 (1994); Liljeberg v. Health Services Acquisition Corp., 486 U.S. 847, 108 S.Ct. 2194 (1988); (what matters is not the reality of bias or prejudice but its appearance); United States v. Balistrieri, 779 F.2d 1191 (7th Cir. 1985) (Section 455(a) "is directed against the appearance of partiality, whether or not the judge is actually biased.") ("Section 455(a) of the Judicial Code, 28 U.S.C. §455(a), is notintended to protect litigants from actual biasin their judge but rather to promote public confidencein the impartiality of the judicial process."); “Section 455(a)” requires a judge to recuse himselfin any proceedingin which her impartiality might reasonably be questioned." Taylor v. O'Grady, 888 F.2d 1189 (7th Cir. 1989); Pfizerinc. v. Lord, 456 F.2d 532 (8th Cir. 1972), “It is important that the litigant not only actually receive justice, but that he believes that he has received justice.” “Justice must satisfy the appearance of justice.” Levine v. United States, 362 U.S. 610, 80 S.Ct. 1038 (1960), citing Offutt v. United States, 348 U.S. 11, 14, 75 S.Ct. 11, 13 (1954); United States v. Sciuto, 521 F.2d 842, 845 (7th Cir. 1996) "The right to a tribunal free from bias or prejudice is based, not on section 144, but on the Due Process Clause."

 

Federal Judges Are Required to Construe Pro Se Litigant's Pleadings Liberally

 

                253)       in the U.S. Supreme Court case Haines V. Kerner, 404 U. S. 519 (1972), Petitioner Menard, a person convicted by the State of Illinois as a felon – and anindividual deemed by the State of Illinois to be unworthy of living with law-abiding citizens of Illinois, commenced an action against the Governor of Illinois and other state officers and prison officials under the Civil Rights Act of 1871, 17 Stat. 13, 42 U.S.C. §1983, and 28 U.S.C. §1343(3), seeking to recover damages for claimedinjuries and deprivation of rights whileincarcerated. The dismissed Mr. Menard's complaint and the U.S. Court of Appeals for the Seventh Circuit affirmed the court's decision. The U.S. Supreme Court, however, decided against the Federal District's and U.S. Court of Appeals' decisions. The U.S. Supreme Court statedin its decision that “Whatever may be the limits on the scope ofinquiry of courtsinto theinternal administration of prisons, allegations such as those asserted by petitioner, howeverinartfully pleaded, are sufficient to call for the opportunity to offer supporting evidence. . .Accordingly, although weintimate no view whatever on the merits of petitioner's allegations, we conclude that he is entitled to an opportunity to offer proof.”

 

There Is No Constitutional or Statutory Rationale to Dismiss Plaintiff’s Complaint

 

                254)       in the past, Plaintiff alleges that Defendant Garaufis has fraudulently misused reasonsin the Federal Rules of Civil Practice to illegally dismiss Plaintiff's Verified Complaint. Plaintiff alleges that Defendant Garaufis' primarily relies on the religious doctrine Law of the Moser to prevent Plaintiff from reporting corrupt Jewish immigration attorneys Allen E. Kaye, Harvey Shapiro and Jack Gladstein. Plaintiff believes that the following FRCP reasons for dismissal do not apply to Plaintiff's Verified Complaint: (1) lack of subject-matter jurisdiction; (2) lack of personal jurisdiction; (4)insufficient process; (5)insufficient service of process; (6) failure to state a claim upon which relief can be granted; and (7) failure to join a party under Rule 19. Plaintiff advises this Court that if Defendant Garaufis receives this case, even though he is a defendant, he will rule on it. If the judges of the Second Circuit get it, they will rule on it, even though they are also Defendants. Plaintiff asks this Court to place her lawsuitin abeyance until such time that the Defendants stipulates this court as the venue for Plaintiff's action pursuant to 28 USC §455 and 28 USC §1404, and if not, to be courageous and make new law that the Plaintiff can proudly present to the Supreme Court of the United States. 

 

                255)        Plaintiff reminds this Court that even if Plaintiff fails to state a claim upon which relief can be granted, Plaintiff would still have the legal right to require this Court to point out Plaintiff's mistakes and allow Plaintiff to make necessary changes to ensure that Plaintiff’s amended Verified Complaint states a claim on which relief can be granted. Plaintiff reminds this Court of theinartfully drawn, virtuallyincomprehensible complaint of the disruptive, mentally disabled Jewish litigant Rebecca Gloria Yohalem and demands the same wide literal latitude – especially since Plaintiff's Verified Complaint is a lot easier for this Court to read and understand. See Haines v. Kerner, 404 U.S. 519 (1972) page 138.

 

Plaintiff's Request for Review of Her Allegations Satisfies
the “Good Faith” Requirement of Coppedge v. United States

 

                256)        According to Coppedge v. United States, “The requirement that an appeal be taken "in good faith" is satisfied when the defendant seeks. . . review of any issue that is not frivolous. Pp. 369 U. S. 444-445.

 

                257)        According to Coppedge vs. United States, “If, with such aid, the applicant then presents any issue for the court's consideration which is not clearly frivolous, leave to proceedin forma pauperis must be granted. P. 369 U. S. 446. . .P. 369 U. S. 448.”

 

                258)        Farley v. United States, 354 U.S. 521, 77 S.Ct. 1371, 1 L.Ed.2d 1529 defines how the U.S. Supreme Court applies the “good faith” standard. It states that “In the absence of some evident improper motive, the applicant's good faith is established by the presentation of any issue that is not plainly frivolous. The good-faith test must not be convertedinto a requirement of a preliminary showing of any particular degree of merit. Unless the issues raised are so frivolous that the appeal would be dismissedin the case of a nonindigent litigant . . .the request of anindigent for leave to appealin forma pauperis must be allowed.

 

                259)        Plaintiff's alleges that her Verified Complaint addresses issues that are not frivolous issues. At the very least, it questions the judicial Defendants' refusal to treat the Plaintiff and her daughter fairlyin the face of allegations that Plaintiff has established are irrefutable. It demands a final answer to the question of the identity of Plaintiff's former husband and father of Tara A. Uzamere, the adult child of the marriage. It accuses the Defendants – especially the judicial Defendants of criminal behavior, beginning with 18 USC §4, misprision of felony, up to and including 18 USC §1962, RICO/racketeering, based upon judicial Defendants obstruction of justice with regard to commencing a criminalinvestigation against immigration attorneys Allen E. Kaye, Harvey Shapiro, Jack Gladstein and Osato E. Uzamere for their commission of fraud, identity theft, and aggravated identity theft. Plaintiff's Verified Complaint is well-written, well-researched and well-documented. Plaintiff is legally entitled to be enveloped by the gossamer wings of the Fourteenth Amendment's Equal Protection extensionintended for people who are disabled –– Title II of the Americans With Disabilities Act and Olmstead v. L.C., 527 U.S. 581 (1999), which states that “[u]njustified isolation . . . is properly regarded as discrimination based on disability,” observing that “institutional placement of persons who can handle and benefit from community settings perpetuates unwarranted assumptions that persons so isolated areincapable of or unworthy of participatingin community life.” 527 U.S. at 597, 600. The “integration mandate” of Title II of the American with Disabilities Act, 42 U.S.C. §12101 et seq., and Section 504 of the Rehabilitation Act, 29 U.S.C. §791 et seq., as expressedin federal regulations and Olmstead, requires that when a state provides services toindividuals with disabilities, it must do so “in the mostintegrated setting appropriate to their needs.” The “mostintegrated setting,” according to the federal regulations, is “a setting that enablesindividuals with disabilities tointeract with non-disabled persons to the fullest extent possible.” 28 C.F.R. §35.130(d); 28 C.F.R. pt. 35 app. A.

 

            During the time that I was trying to obtain help from the Government-financed foster care system, my son David was forced to eat feces while a client with Edenwaldin Pleasantville, New York. David was given several psychotropic drugsincluding Benedryl, Melloril, Tegratol, Haldol, Haldol and Cogentin.

 

            While my daughter Tara was a client with Angel Guardian Home, she was sexually assaulted by other childrenin the home where she was living. She was about six years old at the time of her assault. She was taken to Kings County Hospital, where she was put to sleep to have foreign matter removed from her vagina.

 

            On February 3, 1993, while I was trying to have my children returned to me, the Government-financed foster care system placed mein St. Vincent’s Hospital from February 3, 1993 to February 19, 1993. This is the firstinstancein which the Government’s Ashkenazi-controlled leadership placed mein a mentalinstitution while I was exercising my First Amendment right to petition the government for a redress of grievances.

 

            Since that time, every single occasionin which I have been accused of some crime, jailed and later had the charges dismissedinvolved a member of Ashkenazi leadership whoseinterests were stymied based on my exercise of my First Amendment right to petition the government for a redress of grievances. Nearly everyinpatient psychiatricinterventionin which I was victimized wasinstigated by a member of Ashkenazi leadership. It is a miracle of Jehovah God, that my children are productive, employed members of society, and that while I am still a victim of this Court’s Ashkenazi-judge majority, I speak four (4) different languages; I am legally well-trained, both civilly and criminally, and in both federal and New York State law; I am knownin my neighborhood as someone who has helped others obtain governmental services and have given of my time and money to help others. Most importantly, with Jehovah God’s help, I am still alive, with a strong mind and with relatively good health, although I am nearly sixty (60) years old.

 

            The Government omits its own records that establishes that my visit to the Social Security Administration office was nothing more than the exercise of my First Amendment right to petition the government for a redress of grievances as the victim of bank fraud. The Ashkenazi-controlled Government has criminalized my family for nearly 40 years.  The sufficiency of evidence that I now present irrefutably establishes the Government’s failure to state a cognizable offensein thisinstance, just as it has donein everyinstancein which a member of Ashkenazi leadership used the Government to enforce Ashkenazi Jews’ religion that advocates hatred of people of African descent and enforcement of Law of Moser.

 

            Since the Government has failed to state to a cognizable offense, as it hasin the past, the Government’s complaints against me must be dismissed as a matter of law.

 

                        CHERYL D. UZAMERE

                        FORCED TO APPEAR PRO SE

                        1209 Loring Avenue

                        Apt. 6B

                        Brooklyn, NY  11208

                        Tel.: (718) 535-7628

                        Fax: (303) 943-4403

                        E-mail: cuzamere@netzero.net

                                A drawing of a face

Description generated with high confidence

            )           As the documents that I submitted to the United States for the Eastern District of New York irrefutably shows (see http://www.thecrimesofsenatoruzamere.net/chapter_5_united_states_v_uzamere.html), no member of Ashkenazi Jewish leadership made any attempt to refute any of my allegations – not one federal employee, not one state employee, not one corporate employee. in my Motion to Recuse, I stated the following:

           Furthermore, I allege that all the federal judges for the Eastern District of New York refuse to file any complaint against Judge Garaufis although I have proof of my allegations. Judge Garaufis, for his part, conspired with Web.com to take down my website, but my website can still be found at http://www.archives.org, and I have begun to rebuild the site that Judge Garaufis illegally ordered to be taken down because truth is aninstant barrier any charge of defamation.   Archive.org has taken the liberty of archiving my website since 2010.

 

            I now allege that the District Court’s is refusing to grant me an attorney/guardian ad litem, In spite of this Court’s illegal use of my status of being mentally disabled, forcing me to wait to obtain an attorney who has been ordered to throw my case so that I can go to jail, be killed and have it reported as an act of suicide.  Having U.S. District Court Pro Se Ralph Vega tell me that he would “pass your complaint” without allowing me to file it as a pro se litigant is proof that the court is still engagedin discriminating against me based on the contrived status of being a violent, psychotic mentally illindividual – a fabrication that has no basisin fact or law.

 

            Furthermore, I allege that the present actions before this Court are acts of blackmail to frighten meinto no longer filing charges against this Court’s corrupt judges.in exchange for recanting my charges against members of Ashkenazi Jewish leadership who brutalized my entire family, I will be “allowed” to a guilty plea and a contrived “promise” of no imprisonment (please refer to Babylonian Talmud, Tractate Nedarim, Folio 23A and 23B; Yom Kippur and vows; said “promise” will not be kept).  Of worse, I will be falsely arrested and placedin jail where I will be attacked and murdered, and that the murder will be reported as a suicide, and I will be slandered even when I am dead and not able to defend myself. If I am not killed, I allege that my jail sentenced will be continually lengthened not only to destroy what is left of my life, but to obtain the sexual thrill associated with the Diagnostic and Statistical Manual of Mental Illness Volume V’s description of sexual sadism disorder.

 

            The Bible book of Job describes a discussion between Jehovah God and Satan, In which Satan challenges Jehovah by saying: “Everything a man has he will givein exchange for his life.” According to that Biblical account, Satan proceeded to kill all of Job’s children, took his wealth, reduced him to ashes and left him with aninfectious disease from the crown of his head to the soles of his feet. The account goes on to describe Job’s faithfulnessin not cursing Jehovah. Jehovah accordingly restored Job’s life.

 

            Knowing this, I take comfortin the fact that I have formed a relationship with Jehovah God during the last days of my life; that Jehovah granted me love, peace and a sense of purpose; that even without a formal education, I have learned enough about the law to learn how to defend myself and to defend others. While I do not want to die, I relishin the fact that I was able to resist this Court’s Ashkenazi bullies until the end; and that if it is Jehovah’s will that I end my life this way, I am safein the knowledge that Jehovah will remember that I turned my life around and proved myself faithful until death. I will die with the hope that one day Jehovah God will demand an accounting of allindividuals who use Law of Moser as the beating drum to silence the cries for justice of those sacrificed to those wicked spirits who are embodiedin the alter-ego known as the God Molech.

 

            I also filed a complaint with the U.S. Department of Justice’s Disability Rights section against every judge at the United States District Court for the Eastern District of New York. I reiterate: no member of Ashkenazi Jewish leadership made any attempt to refute any of my allegations – not one federal employee.in Federal District Judge Nicholas Garaufis engaged the services of the United States Department of Homeland Security’s former regional director of the National Protection and Program Directorate for Region II, Denis McGowan to violate my HIPAA rights and accuse me of mentalinstability that caused me to be held against me will as aninpatient for crimes I never committed. However

            From the time that I married my husband until the present, members of Ashkenazi Jewish leadershipin the federal, state, municipal and corporate arenas sexually trafficked my entire family. They were and are still engagedin gang-stalking and gaslighting my family for the sole purpose of being sexually

            )           Ashkenazi Jewish leadership’s blacklisted me as the wife of Defendant Ehigie Edobor Uzamere who is legally entitled to equitable distribution of her husband’s wealth, and as anindividual that possesses the requisite knowledge to obtain employment as an entry-level legal assistant has its basisin the violation of the Fifth, Sixth, Seventh, Eighth and Fourteenth Amendments to the U.S. Constitution, which guarantees (1) due process, Including the accused’s dayin court; 2) an attorney who is appointed to represent the accused if the accusedin poor and cannot afford an attorney; 3) that once a person is tried and found not guilty by a jury of her peersin court of competent jurisdiction, the facts associated with lawsuit for which she was tried cannot be used against her; 4) freedom from cruel and unusual punishment; and 5) equal protection under the law, especiallyin my case because I am African American[3] and mentally disabled[4] – characteristics that Babylonian Talmud-fomented Ashkenazi Jewish leadership uses againstindividuals similarly situated to create a weaponized hatred that is used to facilitate the rape of the hated groups’ children.[5]

            )           Evenin criminal settings, Individuals who have been convicted, have done their time

            )           By reason of the foregoing irrefutable allegations, Plaintiff asserts that there exists a justiciable controversy with respect to which Plaintiff is entitled to the relief prayed for herein.

FIRST CLAIM FOR RELIEF

AS and FOR A FIRST CAUSE of ACTION

            )           Plaintiff repeats and realleges the above paragraphs.

            )           Plaintiffin the member of the following protected statuses:

                        a)         Plaintiff was diagnosed as having a serious and persistent mental impairment that substantially limits one or more major life activities. Plaintiff’s disability is recognized by the Americans With Disabilities. Plaintiff has received Social Security Disabilityinsurance since 1996; and as a condition of Plaintiff’s legal status, Plaintiff is eligible to receive vocational and rehabilitative services so that she can obtain employmentin the profession for which she garnered a guaranteed student loan, and for which Plaintiff is now qualified, at minimum, for an entry-level position as a legal assistant/paralegal assistant. Plaintiff is eligible to receive reasonable accommodations for his disability.

                        b)         Plaintiff is currently married;

                        c)         Plaintiff is a crime victim;

                        d)         Plaintiff is an African American;

            )           Plaintiff is a qualifiedindividual with disabilities within the meaning of 42 U.S.C. §12131(2).

            )           Defendants owed Plaintiff and her family the duty, pursuant to

            )           Defendants failedin their duty to

            )           Plaintiff suffered and continues to sufferinjury

            )           Plaintiff submits thatinjury Plaintiff suffered and the continues to suffer because of Defendants' violation of ______________ are recognizedin law based on (state U.S. Supreme Court or other Appellate review).

SECOND CLAIM FOR RELIEF

AS and FOR A SECOND CAUSE of ACTION

            )           Plaintiff repeats and realleges the above paragraphs.

            )           Plaintiffin the member of the following protected statuses:

                        a)         Plaintiff was diagnosed as having a serious and persistent mental impairment that substantially limits one or more major life activities. Plaintiff’s disability is recognized by the Americans With Disabilities. Plaintiff has received Social Security Disabilityinsurance since 1996; and as a condition of Plaintiff’s legal status, Plaintiff is eligible to receive vocational and rehabilitative services so that she can obtain employmentin the profession for which she garnered a guaranteed student loan, and for which Plaintiff is now qualified, at minimum, for an entry-level position as a legal assistant/paralegal assistant. Plaintiff is eligible to receive reasonable accommodations for his disability.

                        b)         Plaintiff is currently married;

                        c)         Plaintiff is a crime victim;

                        d)         Plaintiff is an African American;

            )           Plaintiff is a qualifiedindividual with disabilities within the meaning of 42 U.S.C. §12131(2).

            )           Defendants owed Plaintiff and her family the duty, pursuant to

            )           Defendants failedin their duty to

            )           Plaintiff suffered and continues to sufferinjury

            )           Plaintiff submits thatinjury Plaintiff suffered and the continues to suffer because of Defendants' violation of ______________ are recognizedin law based on (state U.S. Supreme Court or other Appellate review).

THIRD CLAIM FOR RELIEF

AS and FOR A THIRD CAUSE of ACTION

            )           Plaintiff repeats and realleges the above paragraphs.

            )           Plaintiffin the member of the following protected statuses:

                        a)         Plaintiff was diagnosed as having a serious and persistent mental impairment that substantially limits one or more major life activities. Plaintiff’s disability is recognized by the Americans With Disabilities. Plaintiff has received Social Security Disabilityinsurance since 1996; and as a condition of Plaintiff’s legal status, Plaintiff is eligible to receive vocational and rehabilitative services so that she can obtain employmentin the profession for which she garnered a guaranteed student loan, and for which Plaintiff is now qualified, at minimum, for an entry-level position as a legal assistant/paralegal assistant. Plaintiff is eligible to receive reasonable accommodations for his disability.

                        b)         Plaintiff is currently married;

                        c)         Plaintiff is a crime victim;

                        d)         Plaintiff is an African American;

            )           Plaintiff is a qualifiedindividual with disabilities within the meaning of 42 U.S.C. §12131(2).

            )           Defendants owed Plaintiff and her family the duty, pursuant to

            )           Defendants failedin their duty to

            )           Plaintiff suffered and continues to sufferinjury

            )           Plaintiff submits thatinjury Plaintiff suffered and the continues to suffer because of Defendants' violation of ______________ are recognizedin law based on (state U.S. Supreme Court or other Appellate review).

FOURTH CLAIM FOR RELIEF

AS and FOR A FOURTH CAUSE of ACTION

            )           Plaintiff repeats and realleges the above paragraphs.

            )           Plaintiffin the member of the following protected statuses:

                        a)         Plaintiff was diagnosed as having a serious and persistent mental impairment that substantially limits one or more major life activities. Plaintiff’s disability is recognized by the Americans With Disabilities. Plaintiff has received Social Security Disabilityinsurance since 1996; and as a condition of Plaintiff’s legal status, Plaintiff is eligible to receive vocational and rehabilitative services so that she can obtain employmentin the profession for which she garnered a guaranteed student loan, and for which Plaintiff is now qualified, at minimum, for an entry-level position as a legal assistant/paralegal assistant. Plaintiff is eligible to receive reasonable accommodations for his disability.

                        b)         Plaintiff is currently married;

                        c)         Plaintiff is a crime victim;

                        d)         Plaintiff is an African American;

            )           Plaintiff is a qualifiedindividual with disabilities within the meaning of 42 U.S.C. §12131(2).

            )           Defendants owed Plaintiff and her family the duty, pursuant to

            )           Defendants failedin their duty to

            )           Plaintiff suffered and continues to sufferinjury

            )           Plaintiff submits thatinjury Plaintiff suffered and the continues to suffer because of Defendants' violation of ______________ are recognizedin law based on (state U.S. Supreme Court or other Appellate review).

FIFTH CLAIM FOR RELIEF

AS and FOR A FIFTH CAUSE of ACTION

            )           Plaintiff repeats and realleges the above paragraphs.

            )           Plaintiff in the member of the following protected statuses:

                        a)         Plaintiff was diagnosed as having a serious and persistent mental impairment that substantially limits one or more major life activities. Plaintiff’s disability is recognized by the Americans With Disabilities. Plaintiff has received Social Security Disability insurance since 1996; and as a condition of Plaintiff’s legal status, Plaintiff is eligible to receive vocational and rehabilitative services so that she can obtain employment in the profession for which she garnered a guaranteed student loan, and for which Plaintiff is now qualified, at minimum, for an entry-level position as a legal assistant/paralegal assistant. Plaintiff is eligible to receive reasonable accommodations for his disability.

                        b)         Plaintiff is currently married;

                        c)         Plaintiff is a crime victim;

                        d)         Plaintiff is an African American;

            )           Plaintiff is a qualified individual with disabilities within the meaning of 42 U.S.C. §12131(2).

            )           Defendants owed Plaintiff and her family the duty, pursuant to

            )           Defendants failed in their duty to

            )           Plaintiff suffered and continues to suffer injury

            )           Plaintiff submits that injury Plaintiff suffered and the continues to suffer because of Defendants' violation of ______________ are recognized in law based on (state U.S. Supreme Court or other Appellate review).

SIXTH CLAIM FOR RELIEF

AS and FOR A SIXTH CAUSE of ACTION

            )           Plaintiff repeats and realleges the above paragraphs.

            )           Plaintiffin the member of the following protected statuses:

                        a)         Plaintiff was diagnosed as having a serious and persistent mental impairment that substantially limits one or more major life activities. Plaintiff’s disability is recognized by the Americans With Disabilities. Plaintiff has received Social Security Disabilityinsurance since 1996; and as a condition of Plaintiff’s legal status, Plaintiff is eligible to receive vocational and rehabilitative services so that she can obtain employmentin the profession for which she garnered a guaranteed student loan, and for which Plaintiff is now qualified, at minimum, for an entry-level position as a legal assistant/paralegal assistant. Plaintiff is eligible to receive reasonable accommodations for his disability.

                        b)         Plaintiff is currently married;

                        c)         Plaintiff is a crime victim;

                        d)         Plaintiff is an African American;

            )           Plaintiff is a qualifiedindividual with disabilities within the meaning of 42 U.S.C. §12131(2).

            )           Defendants owed Plaintiff and her family the duty, pursuant to

            )           Defendants failedin their duty to

            )           Plaintiff suffered and continues to sufferinjury

            )           Plaintiff submits thatinjury Plaintiff suffered and the continues to suffer because of Defendants' violation of ______________ are recognizedin law based on (state U.S. Supreme Court or other Appellate review).