THE CRIMES OF SENATOR EHIGIE EDOBOR A.K.A. "GODWIN" UZAMERE
1. Home2. Once Upon A Time3. Victim's Statement4. My Search for Justice5. Descent into Hell6. U.S. Laws Violated by Senator Uzamere7. Nigerian Laws Violated by Senator Uzamere8. Ignored by Federal Agencies9. Ignored by Nigerian Authorities10. Victims' Loss of Child Support11. The Uzamere Family12. Municipal Employees Who Helped Senator Uzamere13. John Gray and Non-Profit Legal Community14. Hall of Shame15. 1st Judicial Blow By African-American Judge Thomas16. Law Firm of Allen E. Kaye17. Too Many Discrepancies...18. Allen E. Kaye And His Diabolical Talmud-Following Minions19. Will Sampson Staff Refuse To Help Identity Fraud Victims?20. Law Office of Gladstein & Messinger21. Patrick Synmoie's Attempts to Hide22. Consulate General of Nigeria23. Strange Chat with Senator Ekweremadu24. Proof of Legal Marriage25. Proof of Illegal Marriage/Identity Fraud26. Senator Uzamere's Attempts to Hide Crimes Will Fail27. The Proof...28. Success -- The Proof Is Finally Here!29. Will Senator Uzamere Evade Child Support Again?30. Nigeria's New Commitment to Protect Child Abandoned by Sen. Uzamere31. Judge Prus -- What Gives?32. Back on Track!33. Eugene Uzamere -- Third Attorney to Break the Law34. Petitioner's Verified Petition35. Supplemental Verified Petition36. Judge Prus Recuses Himself37. Eugene's Failed Attempt to Thwart Justice38. Kate Ezomo -- Diabolical Liar39. Letters of Complaint Against Kate Ezomo40. My Factual Response to Imaginary Cousin Godwin41. Federal Action Against Defendant Dismissed42. Open Letters to the FBI43. Open Letter to All U.S. Judges44. Open Letter to Ehigie and Eugene45. Tara's Affidavit46. $100,000,000.00 Lawsuit Against Corrupt Fiduciaries47. Will Fiduciaries Settle?48. New York City Defrauds Disabled Schvartze49. There Is No Cousin Godwin!50. Warning Letter to Governor and Chief Justice of New York State51. Deprived of Child Support by Allen Kaye52. Can International Agency Help?53. Chief Judge Wood's Court54. Will NYS' Dept. Disc. Committee and Commission on Judicial Conduct Be Corrupted?55. Subpoena Planned for Judge Garaufis56. No Negotiations for Justice...Justice is Owed!57. Will Attorneys Sign Affirmation?58. Am I Finally Being Taken Seriously?59. Evidentiary Hearing is Scheduled!60. Amy Feinstein Refuses to Prosecute!61. Robert Juceam's Useless Excuses62. Appellate Brief pages 24 to end63. No Justice -- No Peace!64. Happy Birthday My Beautiful Angel65. Are You A Victim of A Green Card Marriage Scam?66. End Green Card Marriage Sponsorship67. How to Report an Immigration Scammer and the Attorney68. Is The End Finally in Sight?69. Will Appellate Division Justices Decide Fairly?70. What Will NYSCJC's Response Be?71. How Will NYSDDC Respond?72. Will Obama's Administration Coerce Helpless Schvartze's Silence73. Will U.S. Department of State's Secretary Rise To The Challenge?74. Eugene Uzamere Calls It Quits75. Bigot Judge Sunshine Continues Courtroom Corruption76. Schvartze's Complaints Still Ignored By Appellate Division's White Judiciary77. More Talmudic Bias and Anti-Schvartze Racism At SDNY78. Senator Uzamere...You Are The Husband!79. Will U.S. Solicitor General Office Look On Idly?80. What will SCOTUS Do?81. Why did they disobey?82. Cabranes' Fraud Upon The Court83. Is Hinds-Radix Their 'Secret' Weapon?84. New York State Lawsuit for Fraud85. Judge Sunshine Is A Loser86. Judge Sunshine Out of Options87. Petitioner Prepares Request for Rehearing...88. Petition for Rehearing89. Loser Sunshine's Last Hurrah90. Lawsuit Against Daily News and Scott Shifrel91. Mort Zuckerman's Bigoted Tabloid92. Corruption at Nassau County Supreme Court and Nassau County Clerk93. Judge Scuccimarra Ruling94. Defendants Have Defaulted95. Will Judge Parga Accepts Anne Carroll's Drivel Because Defendants Are Rich Jews?96. New York and Anne B. Carroll97. Lawsuit Against President98. Will Obama Listen?99. Open Letter to Al Jazeera, President Obama and Judge Allegra100. More Court Shenanigans?101. Howard U. Schmokescreen102. Into the fire...103. What Will The New York State Division of Human Rights Do?104. Housing Court Corruption105. Mayor Bloomberg's Finest106. FEGS in Criminal Conspiracy107. FEGS Gave Victim No Choice108. What Will The New York State Supreme Court Do?109. What Will Court of Claims Do?110. Abuse of Religion Not New111. How Wicked Are They?112. What Lies???113. Federal Lawsuit114. Disastrous Results to Appeal115. Judge Garaufis' Discriminatory Decision116. Garaufis' Talmudic Shenanigans117. FOIA Hiding Evidence118. Congressional Testimony119. Unintelligible Complaint of Rachel G. Yohalem120. Uzamere v. USA, et al121. Judicial Whores Willy and Patty122. Uzamere v. USA123. Find an Unbiased Court124. U.S. Government Blacklists Own Citizens125. Appellate Brief First Circuit126. U.S. Government Hides Prosecution127. A Jewish RICO128. Jews' Demonic Doctrine -- Law of the Moser129. Mishkin Yanks His Own Nuts130. Will African American Victim of Grand Laceny Receive Justice?131. Judicial Ethics Hypocrite132. Jew Shenanigans Involved in Random Selection of Morally Compromised Judge133. Please save my family!134. Comment135. Psychopaths136. Jewish Paradigm Put Jews on Top137. Pretender Bharara138. Guest Book139. Guest Book Members' Area140. A Woman's Fed Up141. A Real Man

New York State Lawsuit for Fraud...
 senatoruzamere.jpg allenkaye.jpg jackgladstein2.jpg
and one from which Senator Uzamere
and his diabolical cohorts can no longer find a "safe harbor"

Date Summons filed: July 13, 2009. Plaintiff designates Kings County as the place of trial. The basis of venue Plaintiff’s county of residence.

 

 

 

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Cheryl D. Uzamere
                                                                                             SUMMONS
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                            Plaintiff,                                                     Plaintiff resides at:
                                                                                             1209 Loring Avenue
         -against-                                                                        Apt. 6B
                                                                                             Brooklyn, NY 11208

Senator Ehigie Edobor Uzamere, also known as “Godwin E. Uzamere”, Allen E. Kaye, P.C., Allen E. Kaye, P.C., Allen E. Kaye, Esq., Harvey Shapiro, Esq., Bernard J. Rostanski and Jack Gladstein, Esq.

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                         Defendants.
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        YOU ARE HEREBY SUMMONED to serve a notice of appearance on the Plaintiff OR  Plaintiff’s Attorney within twenty (20) days after the service of this Summons, exclusive of the day of service, or within thirty (30) days after the service is completed (if this Summons is not personally delivered to you within the State of New York); and in case of your failure to appear, judgment will be taken against you by default for the relief demanded in the notice set forth below.

Dated: July 9, 2009

NOTICE: The nature of this action is based on:  Discovery of fraud; tolling of statute of limitations based on discovery of fraud
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The relief sought is: $100,000,000.00.

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS 
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Cheryl D. Uzamere
                                                                                             Index No. 18012/2009
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                            Plaintiff,                                                     VERIFIED COMPLAINT
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         -against-                                                                        JURY TRIAL DEMANDED
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Senator Ehigie Edobor Uzamere, also known as “Godwin E. Uzamere”, Allen E. Kaye, P.C., Allen E. Kaye, P.C., Allen E. Kaye, Esq., Harvey Shapiro, Esq., Bernard J. Rostanski and Jack Gladstein, Esq.

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                         Defendants.
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STATE OF NEW YORK  )
COUNTY OF KINGS      )    ss:

        Plaintiff Cheryl D. Uzamere, appearing on her own behalf, states and alleges the following:

        1)     That at all times herein relevant, the Plaintiff was a resident of the State of New York, City of Brooklyn and County of Kings.

        2)     That on or around December 1977, two years before Plaintiff met Defendant Ehigie Edobor Uzamere, the services of Defendant Allen E. Kaye were retained on behalf of the aforesaid Defendant to apply for lawful permanent residence based on U.S. Immigration and Naturalization Service's IR2 criteria for unmarried immigrants under 21 years of age.

        3)     That at the time that the aforesaid Defendant first retained the aforementioned attorney, Defendant Uzamere retained the aforesaid attorney's services using the proper name “Ehigie Edobor Uzamere”, and proper date of birth, December 31, 1960; and that the aforesaid attorney accepted as true and correct the aforementioned information as Defendant Uzamere's name and birthday.

        4)     That almost two (2) years later, on November 20, 1979, in an attempt to expedite receipt of lawful permanent residence by circumventing the IR2 residence for which Defendant Uzamere previously applied, the aforesaid Defendant wrote the fictitious name and birthday “Godwin Uzamere, June 1, 1955” on the marriage affidavit without producing governmental identification to verify his age and identity.

        5)     That on or around December 17, 1979, Defendant immigration attorney, Allen E. Kaye, Defendant immigration attorney Harvey Shapiro, working under the supervision of Defendant Allen E. Kaye, and New York State notary public Defendant Bernard J. Rostanski signed their names to swear and verify as true and correct the fraudulent name and birthday that Defendant Uzamere placed on the I-130 immediate relative sponsorship form and on which Defendant Uzamere perjured himself.

        6)     That Plaintiff did not discover tangible evidence of Defendants' two (2) immigration file numbers A24-027-764 and A35-201-224, Defendant's Family Court arrest warrant for Defendant Uzamere's non-payment of child support, Plaintiff's immigration fraud complaint against Defendant Uzamere dated August 12, 1980, and other tangible evidence of Defendants' fraud until June 12, 2009.

       7)     That on or around October 1, 2003, Defendant Uzamere's divorce attorney Defendant Jack Gladstein sent Plaintiff correspondence containing the same fictitious name that Defendant Uzamere used to marry the Plaintiff.

        8)     That from November, 1979 until the present time, each and every Defendant has refused to publicize and to willingly participate in the publicizing of Defendant Uzamere's identity to governmental agencies; that from 1979 until the present time, Defendants have continuously, fraudulently and maliciously withheld the proper legal name of Defendant Uzamere from the Plaintiff; and that from 1979 to the present time, Defendants have actively discouraged its public use.

        9)     That as a result of the Defendants' 30-year act of fraud, Defendants set in motion a series of events that resulted in depriving Plaintiff of the use of Defendant Uzamere's proper name as marital property.

        10)    That as a result of Defendants' 30-year act of fraud, Defendants set in motion a series of events that included Defendant Uzamere's illegal retention of attorney Jack Gladstein to attempt to dupe Plaintiff into filing a divorce action against Defendant Uzamere using the same fictitious name that Defendants used to assist Defendant Uzamere in contracting a green-card marriage with the Plaintiff; and to continue to defraud Plaintiff by withholding the true identity of Defendant Uzamere.

        11)    That as a result of Defendants' 30-year act of fraud, Defendants set in motion a series of events that included publicly defaming Plaintiff as mentally unstable so as to publicly discredit her complaints against Defendants.

        12)    That as a result of Defendants' 30-year act of fraud, Defendants set in motion a series of events that included Defendant Uzamere's submission of a fraudulent unauthenticated foreign counter-affidavit during Plaintiff's divorce proceeding; and that the aforesaid unauthenticated foreign counter-affidavit created by Defendant Uzamere fraudulently claimed to be from Defendant Uzamere's “cousin Godwin E. Uzamere.”

        13)    That a result of Defendants' 30-year of fraud, Defendants set in motion a series of events that include Plaintiff being publicly defamed as an anti-Semite by Defendant Allen E. Kaye.

        14)    That as a result of Defendants' 30-year of fraud, Defendants set in motion a series of events that include Plaintiff being falsely charged with simple assault.

        15)    That the Defendants maliciously engaged in the aforesaid tortious acts for the sole purpose of hiding the existence of Plaintiff's marriage and the birth and existence of the child of the marriage.

        16)    That wholly and solely as a result of the Defendants' tortious acts of fraud over the course of nearly 30 years, Plaintiff suffered severe personal injuries and has been damaged in the amount of $100,000,000.00.

AS AND FOR A FIRST SEPARATE AND DISTINCT CAUSE OF ACTION

        17)    Plaintiff hereby repeats and realleges each and every allegation contained in paragraphs 1 through 16 as if fully set forth herein.

        18)    That Defendant Uzamere owed Plaintiff the duty of not engaging in fraud with regard to the use of his proper name and other legal identifiers that by marriage now belong to the Plaintiff; that Defendant Uzamere owed Plaintiff the duty of not withholding his legal identifiers in a manner that would cause the New York State Unified Court System to question the existence of Plaintiff's marriage to Defendant Uzamere and paternity of the child of the marriage, thereby preventing Plaintiff from availing herself and her family of receiving benefits associated with being the wife of Defendant Uzamere and mother of Defendant Uzamere's daughter Tara.

        19)   That Defendant Uzamere owed Plaintiff the duty of publicly disseminating information regarding Plaintiff's marriage to governmental agencies, to encourage and enforce the legal use of Defendant Uzamere's proper name and to cause it to be publicly recognized as Plaintiff's primary marital property, so as to allow Plaintiff to exercise her legal right to share title of all other marital assets with Defendant Uzamere and to share the responsibilities associated with caring for any child with whom Plaintiff and Defendant Uzamere share consanguinity; and that Defendant Uzamere owed Plaintiff the duty of not defrauding Plaintiff by taking advantage of Plaintiff's lack of knowledge of Title 8, U.S.C. -- Aliens and Nationality by withholding from Plaintiff's her role as an unwitting participant in a federal felony.

        20)    That Defendant Uzamere owed Plaintiff the duty of protecting Plaintiff's due process rights with regard to Defendant Uzamere's proper name by not withholding it, and by legally recognizing it as Plaintiff's primary marital property, and to not engage in defrauding Plaintiff of her property based on Defendant Uzamere's desire to engage in an act of green card marriage fraud for permanent residence.

        21)    That wholly and solely as a result of the Defendant Uzamere's nearly thirty (30) years of tortious acts of fraud, the Plaintiff suffered severe personal injuries and have been damaged in the amount of $100,000,000.00.

AS AND FOR A SECOND SEPARATE AND DISTINCT CAUSE OF ACTION

        22)    Plaintiff hereby repeats and realleges each and every allegation contained in paragraphs 1 through 21 as if fully set forth herein.

        23)    That Defendant Uzamere failed in his duty to provide Plaintiff with his proper name by creating and facilitating the existence of the fraudulent name and birthday “Godwin E. Uzamere, June 1, 1955.”

        24)    That Defendant Uzamere failed in his duty to publicly disseminate information regarding Plaintiff's marriage to appropriate governmental agencies; that Defendant Uzamere failed in his duty to encourage and enforce the legal use of his proper name and to cause it to be publicly recognized as Plaintiff's primary marital property, so as to allow Plaintiff to exercise her legal right to share title of all other marital assets with Defendant Uzamere and to share the responsibilities associated with caring for any child with whom Plaintiff and Defendant Uzamere share consanguinity.

        25)    That Defendant Uzamere failed in protecting Plaintiff's due process rights with regard to Defendant Uzamere's proper name as being Plaintiff's primary marital property.

        26)    That wholly and solely as a result of the Defendant Uzamere's nearly thirty (30) years of tortious acts of fraud, the Plaintiff suffered severe personal injuries and have been damaged in the amount of $100,000,000.00.

AS AND FOR A THIRD SEPARATE AND DISTINCT CAUSE OF ACTION

        27)    Plaintiff hereby repeats and realleges each and every allegation contained in paragraphs 1 through 26 as if fully set forth herein.

        28)    That Plaintiff has suffered financial deprivation insofar as Plaintiff has never been unable to obtain government documentation to establish her legal status as Defendant Uzamere's spouse, and has never been able to establish that Defendant Uzamere is the biological father of the child of the marriage; that Plaintiff has been unable to obtain Defendant Ehigie Edobor Uzamere's identification including, real social security number, real driver's license, real passport, real address or any other identification that the Plaintiff can use to take to court to establish her legal status as the spouse of Defendant Uzamere so as to share title with and obtain benefits from Defendant Uzamere based on being Defendant's spouse.

AS AND FOR A FOURTH SEPARATE AND DISTINCT CAUSE OF ACTION

        29)    Plaintiff hereby repeats and realleges each and every allegation contained in paragraphs 1 through 28 as if fully set forth herein.

        30)    That the Defendant Uzamere knew or should have known that when governmental employees, attorneys, notaries or any type of fiduciary agent uses the power of his/her office to help a client create fraudulent documents, said fraudulent documents can be used to circumvent a poor spouse's ability to locate a missing parent or spouse, forcing the abandoned spouse and children into poverty. Furthermore; as the potential recipient of immigration benefits with immediate access to legal counsel, Defendant Uzamere knew or should have known that using the power of one's position as a fiduciary agent to swear to create a fraudulent document for the sole purpose of obtaining immigration benefits is a tort and a crime.

AS AND FOR A FIRST SEPARATE AND DISTINCT CAUSE OF ACTION

        31)    Plaintiff hereby repeats and realleges each and every allegation contained in paragraphs 1 through 30 as if fully set forth herein.

        32)    That Defendant corporation Allen E. Kaye, P.C. owed Plaintiff the duty of not engaging in fraud with regard to the use of Defendant Uzamere's proper name and other legal identifiers belonging to Defendant Uzamere; and that the Defendant corporation owed Plaintiff the duty of not withholding Defendant Uzamere's legal identifiers in a manner that would cause the New York State Unified Court System to question the existence of Plaintiff's marriage to Defendant Uzamere and paternity of the child of the marriage, thereby preventing Plaintiff from availing herself and her family of receiving benefits associated with being the wife of Defendant Uzamere and mother of Defendant Uzamere's daughter Tara.

        33)    That Defendant corporation Allen E. Kaye, P.C. owed Plaintiff the duty of publicly disseminating information regarding Plaintiff's marriage to governmental agencies, to encourage and enforce the legal use of Defendant Uzamere's proper name and to cause it to be publicly recognized as Plaintiff's primary marital property, so as to allow Plaintiff to exercise her legal right to share title of all other marital assets with Defendant Uzamere and to share the responsibilities associated with caring for any child with whom Plaintiff and Defendant Uzamere share consanguinity; and that Defendants owed Plaintiff the duty of not defrauding Plaintiff by taking advantage of Plaintiff's lack of knowledge of Title 8, USC, Aliens and Nationality by withholding from Plaintiff's her role as an unwitting participant in a federal felony.

        34)    That Defendant corporation Allen E. Kaye owed Plaintiff the duty of protecting Plaintiff's due process rights with regard to Defendant Uzamere's proper name by not withholding it from Plaintiff, and by legally recognizing it as Plaintiff's primary marital property, and by not engaging in defrauding Plaintiff of her property based on Defendant's desire to conspire to aid and abet Defendant Uzamere's commission of the crime of marriage fraud for permanent residence.

        35)    That wholly and solely as a result of the Defendant corporation Allen E. Kaye P.C.'s nearly thirty (30) years of tortious acts of fraud, the Plaintiff suffered severe personal injuries and have been damaged in the amount of $100,000,000.00.

AS AND FOR A SECOND SEPARATE AND DISTINCT CAUSE OF ACTION

        36)    Plaintiff hereby repeats and realleges each and every allegation contained in paragraphs 1 through 35 as if fully set forth herein.

        37)    That Defendant corporation Allen E. Kaye, P.C. failed in its duty to provide Plaintiff with the proper name of Defendant Uzamere by facilitating the existence of the fraudulent name and birthday “Godwin E. Uzamere, June 1, 1955.”

        38)    That Defendant corporation Allen E. Kaye, P.C. failed in its duty to publicly disseminate information regarding Plaintiff's marriage to appropriate governmental agencies; that Defendant corporation failed in its duty to encourage and enforce the legal use of Defendant Uzamere's proper name and to cause it to be publicly recognized as Plaintiff's primary marital property, so as to allow Plaintiff to exercise her legal right to share title of all other marital assets with Defendant Uzamere and to share the responsibilities associated with caring for any child with whom Plaintiff and Defendant Uzamere share consanguinity.

        39)    That Defendants failed in protecting Plaintiff's due process rights with regard to Defendant Uzamere's proper name as being Plaintiff's primary marital property.

        40)    That wholly and solely as a result of the Defendant corporation Allen E. Kaye P.C.'s nearly thirty (30) years of tortious acts of fraud, the Plaintiff suffered severe personal injuries and have been damaged in the amount of $100,000,000.00.

AS AND FOR A THIRD SEPARATE AND DISTINCT CAUSE OF ACTION

        41)    Plaintiff hereby repeats and realleges each and every allegation contained in paragraphs 1 through 40 as if fully set forth herein.

        42)    That Plaintiff has suffered financial deprivation insofar as Plaintiff has never been unable to obtain government documentation to establish her legal status as Defendant Uzamere's spouse, and has never been able to establish that Defendant Uzamere is the biological father of the child of the marriage; that Plaintiff has been unable to obtain Defendant Ehigie Edobor Uzamere's identification including, real social security number, real driver's license, real passport, real address or any other identification that the Plaintiff can use to take to court to establish her legal status as the spouse of Defendant Uzamere so as to share title with and obtain benefits from Defendant Uzamere based on being Defendant's spouse.

AS AND FOR A FOURTH SEPARATE AND DISTINCT CAUSE OF ACTION

        43)    Plaintiff hereby repeats and realleges each and every allegation contained in paragraphs 1 through 42 as if fully set forth herein.

        44)    That the Defendant corporation Allen E. Kaye, P.C. knew or should have known that when governmental employees, attorneys, notaries or any type of fiduciary agent uses the power of his/her office to help a client create fraudulent documents, said fraudulent documents can be used to circumvent a poor spouse's ability to locate a missing parent or spouse, forcing the abandoned spouse and children into poverty. Furthermore; the Defendant corporation, operating under the laws of the State of New York as a law firm, knew or should have known that using the power of one's position as a fiduciary agent to swear to create a fraudulent document is a tort and a crime.

AS AND FOR A FIRST SEPARATE AND DISTINCT CAUSE OF ACTION

        45)    Plaintiff hereby repeats and realleges each and every allegation contained in paragraphs 1 through 44 as if fully set forth herein.

        46)    That Defendant Allen E. Kaye, Esq. owed Plaintiff the duty of not engaging in fraud with regard to the use of Defendant Uzamere's proper name and other legal identifiers belonging to Defendant Uzamere; and that the Defendant Kaye owed Plaintiff the duty of not withholding Defendant Uzamere's legal identifiers in a manner that would cause the New York State Unified Court System to question the existence of Plaintiff's marriage to Defendant Uzamere and paternity of the child of the marriage, thereby preventing Plaintiff from availing herself and her family of receiving benefits associated with being the wife of Defendant Uzamere and mother of Defendant Uzamere's daughter Tara.

        47)    That Defendant Kaye owed Plaintiff the duty of publicly disseminating information regarding Plaintiff's marriage to governmental agencies, to encourage and enforce the legal use of Defendant Uzamere's proper name and to cause it to be publicly recognized as Plaintiff's primary marital property, so as to allow Plaintiff to exercise her legal right to share title of all other marital assets with Defendant Uzamere and to share the responsibilities associated with caring for any child with whom Plaintiff and Defendant Uzamere share consanguinity; and that Defendants owed Plaintiff the duty of not defrauding Plaintiff by taking advantage of Plaintiff's lack of knowledge of Title 8, USC, Aliens and Nationality by withholding from Plaintiff's her role as an unwitting participant in a federal felony.

        48)    That Defendant Kaye owed Plaintiff the duty of protecting Plaintiff's due process rights with regard to Defendant Uzamere's proper name by not withholding it, and by legally recognizing it as Plaintiff's primary marital property, and to not engage in defrauding Plaintiff of her property based on Defendant's desire to conspire to aid and abet Defendant Uzamere's commission of the crime of marriage for permanent residence.

        49)    That wholly and solely as a result of the Defendant Kaye's nearly thirty (30) years of tortious acts of fraud, the Plaintiff suffered severe personal injuries and have been damaged in the amount of $100,000,000.00.

AS AND FOR A SECOND SEPARATE AND DISTINCT CAUSE OF ACTION

        50)    Plaintiff hereby repeats and realleges each and every allegation contained in paragraphs 1 through 49 as if fully set forth herein.

        51)    That Defendant Kaye failed in his duty to provide Plaintiff with the proper name of Defendant Uzamere by facilitating the existence of the fraudulent name and birthday “Godwin E. Uzamere, June 1, 1955.”

        52)    That Defendant Kaye failed in his duty to publicly disseminate information regarding Plaintiff's marriage to appropriate governmental agencies; that Defendant Kaye failed in his duty to encourage and enforce the legal use of Defendant Uzamere's proper name and to cause it to be publicly recognized as Plaintiff's primary marital property, so as to allow Plaintiff to exercise her legal right to share title of all other marital assets with Defendant Uzamere and to share the responsibilities associated with caring for any child with whom Plaintiff and Defendant Uzamere share consanguinity.

        53)    That Defendant Kaye failed in protecting Plaintiff's due process rights with regard to Defendant Uzamere's proper name as being Plaintiff's primary marital property.

        54)    That wholly and solely as a result of the Defendant Kaye's nearly thirty (30) years of tortious acts of fraud, the Plaintiff suffered severe personal injuries and have been damaged in the amount of $100,000,000.00.

AS AND FOR A THIRD SEPARATE AND DISTINCT CAUSE OF ACTION

        55)    Plaintiff hereby repeats and realleges each and every allegation contained in paragraphs 1 through 54 as if fully set forth herein.

        56)    That Plaintiff has suffered financial deprivation insofar as Plaintiff has never been unable to obtain government documentation to establish her legal status as Defendant Uzamere's spouse, and has never been able to establish that Defendant Uzamere is the biological father of the child of the marriage; that Plaintiff has been unable to obtain Defendant Ehigie Edobor Uzamere's identification including, real social security number, real driver's license, real passport, real address or any other identification that the Plaintiff can use to take to court to establish her legal status as the spouse of Defendant Uzamere so as to share title with and obtain benefits from Defendant Uzamere based on being Defendant's spouse.

AS AND FOR A FOURTH SEPARATE AND DISTINCT CAUSE OF ACTION

        57)    Plaintiff hereby repeats and realleges each and every allegation contained in paragraphs 1 through 56 as if fully set forth herein.

        58)    That the Defendant Kaye knew or should have known that when governmental employees, attorneys, notaries or any type of fiduciary agent uses the power of his/her office to help a client create fraudulent documents, said fraudulent documents can be used to circumvent a poor spouse's ability to locate a missing parent or spouse, forcing the abandoned spouse and children into poverty. Furthermore; Defendant Kaye, who is an attorney, knew or should have known that using the power of one's position as a fiduciary agent to swear to create a fraudulent document is a tort and a crime.

AS AND FOR A FIRST SEPARATE AND DISTINCT CAUSE OF ACTION

        59)    Plaintiff hereby repeats and realleges each and every allegation contained in paragraphs 1 through 58 as if fully set forth herein.

        60)    That Defendant Harvey Shapiro owed Plaintiff the duty of not engaging in fraud with regard to the use of Defendant Uzamere's proper name and other legal identifiers belonging to Defendant Uzamere; and that the Defendant Shapiro owed Plaintiff the duty of not withholding Defendant Uzamere's legal identifiers in a manner that would cause the New York State Unified Court System to question the existence of Plaintiff's marriage to Defendant Uzamere and paternity of the child of the marriage, thereby preventing Plaintiff from availing herself and her family of receiving benefits associated with being the wife of Defendant Uzamere and mother of Defendant Uzamere's daughter Tara.

        61)    That Defendant Shapiro owed Plaintiff the duty of publicly disseminating information regarding Plaintiff's marriage to governmental agencies, to encourage and enforce the legal use of Defendant Uzamere's proper name and to cause it to be publicly recognized as Plaintiff's primary marital property, so as to allow Plaintiff to exercise her legal right to share title of all other marital assets with Defendant Uzamere and to share the responsibilities associated with caring for any child with whom Plaintiff and Defendant Uzamere share consanguinity; and that Defendants owed Plaintiff the duty of not defrauding Plaintiff by taking advantage of Plaintiff's lack of knowledge of Title 8, USC, Aliens and Nationality by withholding from Plaintiff's her role as an unwitting participant in a federal felony.

        62)    That Defendant Shapiro owed Plaintiff the duty of protecting Plaintiff's due process rights with regard to Defendant Uzamere's proper name by not withholding it, and by legally recognizing it as Plaintiff's primary marital property, and to not engage in defrauding Plaintiff of her property based on Defendant Shapiro's desire to conspire to aid and abet Defendant Uzamere's commission of the crime of marriage for permanent residence.

        63)    That wholly and solely as a result of the Defendant Shapiro's nearly thirty (30) years of tortious acts of fraud, the Plaintiff suffered severe personal injuries and have been damaged in the amount of $100,000,000.00.

AS AND FOR A SECOND SEPARATE AND DISTINCT CAUSE OF ACTION

        64)    Plaintiff hereby repeats and realleges each and every allegation contained in paragraphs 1 through 63 as if fully set forth herein.

        65)    That Defendant Shapiro failed in his duty to provide Plaintiff with the proper name of Defendant Uzamere by facilitating the existence of the fraudulent name and birthday “Godwin E. Uzamere, June 1, 1955.”

        66)    That Defendant Shapiro failed in his duty to publicly disseminate information regarding Plaintiff's marriage to appropriate governmental agencies; that Defendant Shapiro failed in its duty to encourage and enforce the legal use of Defendant Uzamere's proper name and to cause it to be publicly recognized as Plaintiff's primary marital property, so as to allow Plaintiff to exercise her legal right to share title of all other marital assets with Defendant Uzamere and to share the responsibilities associated with caring for any child with whom Plaintiff and Defendant Uzamere share consanguinity.

        67)    That Defendant Shapiro failed in protecting Plaintiff's due process rights with regard to Defendant Uzamere's proper name as being Plaintiff's primary marital property.

        68)    That wholly and solely as a result of the Defendant Shapiro's nearly thirty (30) years of tortious acts of fraud, the Plaintiff suffered severe personal injuries and have been damaged in the amount of $100,000,000.00.

AS AND FOR A THIRD SEPARATE AND DISTINCT CAUSE OF ACTION

        69)    Plaintiff hereby repeats and realleges each and every allegation contained in paragraphs 1 through 68 as if fully set forth herein.

        70)    That Plaintiff has suffered financial deprivation insofar as Plaintiff has never been unable to obtain government documentation to establish her legal status as Defendant Uzamere's spouse, and has never been able to establish that Defendant Uzamere is the biological father of the child of the marriage; that Plaintiff has been unable to obtain Defendant Ehigie Edobor Uzamere's identification including, real social security number, real driver's license, real passport, real address or any other identification that the Plaintiff can use to take to court to establish her legal status as the spouse of Defendant Uzamere so as to share title with and obtain benefits from Defendant Uzamere based on being Defendant's spouse.

AS AND FOR A FOURTH SEPARATE AND DISTINCT CAUSE OF ACTION

        71)    Plaintiff hereby repeats and realleges each and every allegation contained in paragraphs 1 through 70 as if fully set forth herein.

        72)    That the Defendant Shapiro knew or should have known that when governmental employees, attorneys, notaries or any type of fiduciary agent uses the power of his/her office to help a client create fraudulent documents, said fraudulent documents can be used to circumvent a poor spouse's ability to locate a missing parent or spouse, forcing the abandoned spouse and children into poverty. Furthermore; the Defendant Shapiro, who is an attorney, knew or should have known that using the power of one's position as a fiduciary agent to swear to create a fraudulent document is a tort and a crime.

AS AND FOR A FIRST SEPARATE AND DISTINCT CAUSE OF ACTION

        73)    Plaintiff hereby repeats and realleges each and every allegation contained in paragraphs 1 through 72 as if fully set forth herein.

        74)    That Defendant New York State Notary Public Bernard J. Rostanski owed Plaintiff the duty of not engaging in fraud by verifying the authenticity of all documents that served as legal identifiers of Defendant Uzamere, and that Defendant Rostanski owed Plaintiff the duty of not withholding Defendant Uzamere's legal identifiers in a manner that would cause the New York State Unified Court System to question the existence of Plaintiff's marriage to Defendant Uzamere and paternity of the child of the marriage, thereby preventing Plaintiff from availing herself and her family of receiving benefits associated with being the wife of Defendant Uzamere and mother of Defendant Uzamere's daughter Tara.

        75)    That Defendant Rostanski owed Plaintiff the duty of verifying documents regarding Defendant Uzamere's identity so as to ensure that any information that was disseminated to governmental agencies regarding Plaintiff's marriage to Defendant Uzamere was authenticated and not fraudulent; and that Defendant Rostanski owed Plaintiff the duty of encouraging and enforcing the proper legal use of Defendant Uzamere's legal documents containing his proper name and birthday and to cause it to be publicly recognized as Plaintiff's primary marital property, so as to allow Plaintiff to exercise her legal right to share title of all other marital assets with Defendant Uzamere and to share the responsibilities associated with caring for any child with whom Plaintiff and Defendant Uzamere share consanguinity; and that Defendants owed Plaintiff the duty of not defrauding Plaintiff by taking advantage of Plaintiff's lack of knowledge of Title 8, USC, Aliens and Nationality by withholding from Plaintiff's her role as an unwitting participant in a federal felony.

        76)    That Defendant Rostanski owed Plaintiff the duty of protecting Plaintiff's due process rights with regard to Defendant Uzamere's proper name by not withholding it, and by legally recognizing it as Plaintiff's primary marital property, and to not engage in defrauding Plaintiff of her property based on Defendant Rostanski's desire to conspire to aid and abet Defendant Uzamere's commission of the crime of marriage for permanent residence.

        77)    That wholly and solely as a result of the Defendant Rostanski's nearly thirty (30) years of tortious acts of fraud, the Plaintiff suffered severe personal injuries and have been damaged in the amount of $100,000,000.00.

AS AND FOR A SECOND SEPARATE AND DISTINCT CAUSE OF ACTION

        78)    Plaintiff hereby repeats and realleges each and every allegation contained in paragraphs 1 through 77 as if fully set forth herein.

        79)    That Defendant Rostanski failed in his duty to provide Plaintiff with the proper name of Defendant Uzamere by facilitating the existence of the fraudulent name and birthday “Godwin E. Uzamere, June 1, 1955.”

        80)    That Defendant Rostanski failed in his duty to publicly disseminate information regarding Plaintiff's marriage to appropriate governmental agencies; that Defendant Rostanski failed in his duty to encourage and enforce the legal use of Defendant Uzamere's proper name and to cause it to be publicly recognized as Plaintiff's primary marital property, so as to allow Plaintiff to exercise her legal right to share title of all other marital assets with Defendant Uzamere and to share the responsibilities associated with caring for any child with whom Plaintiff and Defendant Uzamere share consanguinity.

        81)    That Defendant Rostanski failed in protecting Plaintiff's due process rights with regard to Defendant Uzamere's proper name as being Plaintiff's primary marital property.

        82)    That wholly and solely as a result of the Defendant Rostanski's nearly thirty (30) years of tortious acts of fraud, the Plaintiff suffered severe personal injuries and have been damaged in the amount of $100,000,000.00.

AS AND FOR A THIRD SEPARATE AND DISTINCT CAUSE OF ACTION

        83)    Plaintiff hereby repeats and realleges each and every allegation contained in paragraphs 1 through 82 as if fully set forth herein.

        84)    That Plaintiff has suffered financial deprivation insofar as Plaintiff has never been unable to obtain government documentation to establish her legal status as Defendant Uzamere's spouse, and has never been able to establish that Defendant Uzamere is the biological father of the child of the marriage; that Plaintiff has been unable to obtain Defendant Ehigie Edobor Uzamere's identification including, real social security number, real driver's license, real passport, real address or any other identification that the Plaintiff can use to take to court to establish her legal status as the spouse of Defendant Uzamere so as to share title with and obtain benefits from Defendant Uzamere based on being Defendant's spouse.

AS AND FOR A FOURTH SEPARATE AND DISTINCT CAUSE OF ACTION

        85)    Plaintiff hereby repeats and realleges each and every allegation contained in paragraphs 1 through 84 as if fully set forth herein.

        86)    That Defendant Rostanski's knew or should have known that when governmental employees, attorneys, notaries or any type of fiduciary agent uses the power of his/her office to help a client create fraudulent documents, said fraudulent documents can be used to circumvent a poor spouse's ability to locate a missing parent or spouse, forcing the abandoned spouse and children into poverty. Furthermore; Defendant Rostanski, who is a New York State notary public, knew or should have known that using the power of one's position as a fiduciary agent to swear to create a fraudulent document is a tort and a crime.

AS AND FOR A FIRST SEPARATE AND DISTINCT CAUSE OF ACTION

        87)    Plaintiff hereby repeats and realleges each and every allegation contained in paragraphs 1 through 86 as if fully set forth herein.

        88)    That Defendant Jack Gladstein owed Plaintiff the duty of not engaging in fraud with regard to the use of Defendant Uzamere's proper name and other legal identifiers belonging to Defendant Uzamere; and that Defendant Gladstein owed Plaintiff the duty of not withholding Defendant Uzamere's legal identifiers in a manner that would cause the New York State Unified Court System to question the existence of Plaintiff's marriage to Defendant Uzamere and paternity of the child of the marriage, thereby preventing Plaintiff from availing herself and her family of receiving benefits associated with being the wife of Defendant Uzamere and mother of Defendant Uzamere's daughter Tara.

        89)    That Defendant Gladstein owed Plaintiff the duty of publicly disseminating information regarding Plaintiff's marriage to governmental agencies, to encourage and enforce the legal use of Defendant Uzamere's proper name and to cause it to be publicly recognized as Plaintiff's primary marital property, so as to allow Plaintiff to exercise her legal right to share title of all other marital assets with Defendant Uzamere and to share the responsibilities associated with caring for any child with whom Plaintiff and Defendant Uzamere share consanguinity; and that Defendant Gladstein owed Plaintiff the duty of not defrauding Plaintiff by sending Plaintiff correspondence dated October 1, 2003 containing fictitious information regarding Defendant client's Ehigie Edobor Uzamere's identity.

        90)    That Defendant Gladstein owed Plaintiff the duty of protecting Plaintiff's due process rights with regard to Defendant Uzamere's proper name by not withholding it, and by legally recognizing it as Plaintiff's primary marital property, and to not engage in defrauding Plaintiff of her property based on Defendant Gladstein's desire to conspire to aid and abet Defendant Uzamere's original commission of the crime of marriage for permanent residence.

        91)    That wholly and solely as a result of the Defendant Gladstein's nearly thirty (30) years of tortious acts of fraud, the Plaintiff suffered severe personal injuries and have been damaged in the amount of $100,000,000.00.

AS AND FOR A SECOND SEPARATE AND DISTINCT CAUSE OF ACTION

        92)    Plaintiff hereby repeats and realleges each and every allegation contained in paragraphs 1 through 91 as if fully set forth herein.

        93)    That Defendant Gladstein failed in his duty to provide Plaintiff with the proper name of Defendant Uzamere by facilitating the existence of the fraudulent name and birthday “Godwin E. Uzamere, June 1, 1955.”

        94)    That Defendant Gladstein failed in his duty to publicly disseminate information regarding Plaintiff's marriage to appropriate governmental agencies; that Defendant Gladstein failed in its duty to encourage and enforce the legal use of Defendant Uzamere's proper name and to cause it to be publicly recognized as Plaintiff's primary marital property, so as to allow Plaintiff to exercise her legal right to share title of all other marital assets with Defendant Uzamere and to share the responsibilities associated with caring for any child with whom Plaintiff and Defendant Uzamere share consanguinity.

        95)    That Defendant Gladstein failed in protecting Plaintiff's due process rights with regard to Defendant Uzamere's proper name as being Plaintiff's primary marital property.

        96)    That as a result of the Defendant Gladstein's act of fraud regarding Defendant client Ehigie Edobor Uzamere, the Plaintiff suffered severe personal injuries and have been damaged in the amount of $100,000,000.00.

AS AND FOR A THIRD SEPARATE AND DISTINCT CAUSE OF ACTION

        97)    Plaintiff hereby repeats and realleges each and every allegation contained in paragraphs 1 through 96 as if fully set forth herein.

        98)    That Plaintiff has suffered financial deprivation insofar as Plaintiff has never been unable to obtain government documentation to establish her legal status as Defendant Uzamere's spouse, and has never been able to establish that Defendant Uzamere is the biological father of the child of the marriage; that Plaintiff has been unable to obtain Defendant Ehigie Edobor Uzamere's identification including, real social security number, real driver's license, real passport, real address or any other identification that the Plaintiff can use to take to court to establish her legal status as the spouse of Defendant Uzamere so as to share title with and obtain benefits from Defendant Uzamere based on being Defendant's spouse.

AS AND FOR A FOURTH SEPARATE AND DISTINCT CAUSE OF ACTION

        99)    Plaintiff hereby repeats and realleges each and every allegation contained in paragraphs 1 through 98 as if fully set forth herein.

        100)   That the Defendant Gladstein knew or should have known that when governmental employees, attorneys, notaries or any type of fiduciary agent uses the power of his/her office to help a client create fraudulent documents, said fraudulent documents can be used to circumvent a poor spouse's ability to locate a missing parent or spouse, forcing the abandoned spouse and children into poverty. Furthermore; the Defendant Gladstein, who is an attorney, knew or should have known that using the power of one's position as a fiduciary agent to swear to create a fraudulent document is a tort and a crime.

        101)   That prior to and at all times mentioned, Plaintiff Cheryl D. Uzamere is the wife of Ehigie Edobor Uzamere and that the name “Godwin E. Uzamere” and the name Ehigie Edobor Uzamere belong to Defendant Uzamere and that Defendants are fully aware that the two names belong to the same person.

        102)   That Plaintiff prays that based on Plaintiff's discovery of Defendants' act of fraud that this Court tolls the statute of limitations for fraud as the Plaintiff and her family are still being victimized; and that tolling the statute for limitations for fraud based on Plaintiff's recent discovery of evidence of the Defendants' acts of fraud is in the best interest of justice.

        103)   By reason of the foregoing, Plaintiff Cheryl D. Uzamere has been deprived, injured and impaired such that deprivation and impairment continues now and will continue in the future, all to this Plaintiff's damage in the sum of $100,000,000.00.

        WHEREFORE, Plaintiff Cheryl D. Uzamere respectfully prays that this Court grants a jury trial, and for this Court to render judgment against the Defendants in the sum of $100,000,000.00 for the first, second, third and fourth causes of action herein, together with the costs and disbursement of this action, and for such other, further, and additional relief as to this Court may seem just and proper.

*

Dated: Brooklyn, New York
           July 10, 2009
* 
mysignature2.jpg 
Cheryl D. Uzamere
Appearing Pro Se
1209 Loring Avenue
Apt. 6B
Brooklyn, NY 11208
Tel.: (718) 647-1708
Fax: (267) 543-3317

STATE OF NEW YORK, COUNTY OF KINGS           ss:

*

I, Cheryl D. Uzamere, am the Plaintiff in the within Verified Complaint. I have read the foregoing complaint and know the contents thereof. The contents are true to my own knowledge except as to matters therein stated to be alleged upon information and belief, and as to those matters I believe them to be true.

mysignature2.jpg 
Cheryl D. Uzamere
Appearing Pro Se
1209 Loring Avenue
Apt. 6B
Brooklyn, NY  11208
Tel.: (718) 647-1708
Fax: (267) 543-3317

 

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS 
_________________________________

Cheryl D. Uzamere
                                                                                             Index No. 18012/2009
*
                            Plaintiff,                                                     NOTICE TO ADMIT
*
         -against- 
*

Senator Ehigie Edobor Uzamere, also known as “Godwin E. Uzamere”, Allen E. Kaye, P.C., Allen E. Kaye, P.C., Allen E. Kaye, Esq., Harvey Shapiro, Esq., Bernard J. Rostanski and Jack Gladstein, Esq.

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*
                         Defendants.
______________________________________
STATE OF NEW YORK  )
COUNTY OF KINGS      )    ss:

        PLEASE TAKE NOTICE that pursuant to CPLR §3123, you are hereby requested to furnish to the undersigned, within twenty (20) days after the service of this notice, a written admission as to genuineness, correctness, fairness and truthfulness of any and all representations of the following facts with reference to the following specific documents:

        a)     With regard to Defendant Allen E. Kaye, Esq., please admit or deny the genuineness, correctness, fairness and truthfulness of Plaintiff's assertion that you have sole or primary control of the corporation named “Allen E. Kaye, P.C.,” and that you have retained sole or primary control of same since November, 1979.

        b)     With regard to Defendant Senator Ehigie Edobor Uzamere, please admit or deny the genuineness, correctness, fairness and truthfulness of Plaintiff's representation of the Affidavit and Application for License to Marry with the name and birthday “Godwin E. Uzamere, June 1, 1955” and whether it is the same document you signed in preparation for marriage to the Plaintiff.

        c)     With regard to Defendants Ehigie Edobor Uzamere, Allen E. Kaye, Esq. and Harvey Shapiro, Esq., please admit or deny the genuineness, correctness, fairness and truthfulness of Plaintiff's representation of the marriage certificate and whether its original was used by you to apply for IR1 immigration benefits for Defendant Uzamere as Plaintiff's spouse.

        d)     With regard to Defendants Ehigie Edobor Uzamere, Allen E. Kaye, Esq., Harvey Shapiro, Esq., and Bernard J. Rostanski, Esq., please admit or deny the genuineness, correctness, fairness and truthfulness of Plaintiff's representation of I-130(E), the immediate relative sponsorship form that contains your' names, and whether you are the individuals to whom the aforementioned form refers.

        e)     With regard to Defendant Harvey Shapiro, please admit or deny the genuineness, correctness, fairness and truthfulness of Plaintiff's representation of the USINS Notice of Entry of Appearance as Attorney or Representative, and whether you are the named attorney and whether the aforementioned form contains your signature.

        f)     With regard to Defendants Ehigie Edobor Uzamere, Allen E. Kaye, Esq. and Harvey Shapiro, Esq., please admit or deny the genuineness, correctness, fairness and truthfulness of immigration number A35-201-224 noted on the attached copies of correspondence from U.S. Immigration and Naturalization Service and whether this number correctly reflects the number that was assigned to Defendant Uzamere during your representation of the aforesaid defendant.

        g)     With regard to Defendants Ehigie Edobor Uzamere, Allen E. Kaye, Esq. and Harvey Shapiro, Esq., please admit or deny the genuineness, correctness, fairness and truthfulness of immigration number A24-027-764 noted on the attached copies of correspondence from U.S. Immigration and Naturalization Service from John J. Gaffney, and whether the aforesaid number accurately reflects the number that was assigned to Defendant Uzamere during your representation of the aforesaid defendant.

        h)     With regard to Defendant Allen E. Kaye, Esq., please admit or deny the genuineness, correctness, fairness and truthfulness of Plaintiff's representation of correspondence from the Law Offices of Allen E. Kaye., P.C., dated July 22, 2003, to determine if you issued the aforesaid correspondence.

        i)     With regard to Defendant Jack Gladstein, Esq., please admit or deny the genuineness, correctness, fairness and truthfulness of Plaintiff's representation of correspondence received from Gladstein & Messinger, dated October 1, 2003, to determine whether you issued the aforementioned correspondence in which Plaintiff's husband is referred to as “Godwin E. Uzamere.”

        j)     With regard to Defendant Jack Gladstein, Esq., please admit or deny the genuineness, correctness, fairness and truthfulness of Plaintiff's representation of correspondence from Gladstein & Messinger, dated October 9, 2007, to determine whether you issued the aforementioned correspondence to the Plaintiff.

        k)     With regard to Defendant Allen E. Kaye, Esq., please admit or deny the genuineness, correctness, fairness and truthfulness of Plaintiff's representation of the attached e-mail sent to ILW.com member Jeremy Schmitt, dated June 1, 2008, to determine if you are the individual who said about Plaintiff that “there are heavy overtones of antisemitism in her writings which you may not have seen.”

        l)     With regard to Defendant Ehigie Edobor Uzamere, please admit or deny the genuineness, correctness, fairness, and truthfulness of Plaintiff's representation of the attached document entitled “further counter-affidavit”, and whether Eugene O. Uzamere was acting as your attorney at the time that he submitted the aforesaid counter-affidavit to the Court.

        m)   With regard to Defendant Ehigie Edobor Uzamere, please admit or deny the genuineness, correctness, fairness, and truthfulness of Plaintiff's representation of each and every document containing the stamp “Kate Ezomo, Principal Registrar, Commissioner of Oaths”, and whether Eugene O. Uzamere was legally acting as your attorney at the time that he submitted the aforesaid documents to the court during Plaintiff's divorce action.

        n)     With regard to Defendant Allen E. Kaye, Esq., please admit or deny the genuineness, correctness, fairness and truthfulness of Plaintiff's representation of the attached e-mail sent to the Honorable Jeffrey S. Sunshine, dated March 24, 2009, to determine if you are the individual who stated in the aforesaid correspondence that “I do not anticipate being in Court on March 30, 2009.”

        o)     With regard to Defendants Ehigie Edobor Uzamere, Allen E. Kaye, Esq., Harvey Shapiro, Esq., and Jack Gladstein, Esq., please admit or deny the genuineness, correctness, fairness and truthfulness of the attached photograph to determine whether it is an accurate depiction of the person known as “Godwin E. Uzamere” and Defendant Ehigie Edobor Uzamere.

        Unless you serve a sworn statement either denying specifically the matters for which an admission is requested, or set forth in detail why you cannot truthfully either admit or deny those matter, each of the matters for which an admission is requested shall be deemed admitted.

        Furthermore, if you do not admit the genuineness, correctness, fairness and truthfulness of any representation of Plaintiff's papers, documents and photographs based on questions specifically posed to you, the Plaintiff will move for a summary judgment, or, if summary judgment is not granted, for an order requiring you to pay reasonable expenses incurred in making such proof, including reasonable attorney's fees at the trial or immediately following the trial. Unless the court finds that there were good reasons for the denial or the refusal otherwise to admit, or that the admissions sought were of no substantial importance, the order shall be made irrespective of the result of the action. Upon a trial by jury, the motion for such an order shall be determined by the court outside the presence of the jury.

Dated: Brooklyn, New York
           July 31, 2009
mysignature.jpg
Cheryl D. Uzamere
Appearing Pro Se
1209 Loring Avenue
Apt. 6B
Brooklyn, NY 11208
Tel.: (718) 647-1708
Fax: (267) 543-3317

 

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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS 
_________________________________

Cheryl D. Uzamere
                                                                                             Index No. 18012/2009
*
                            Plaintiff,                                                   AFFIDAVIT IN SUPPORT
*                                                                                          OF MOTION FOR DEFAULT
         -against-                                                                      JUDGMENT AND SUMMARY
                                                                                         JUDGMENT

Senator Ehigie Edobor Uzamere, also known as “Godwin E. Uzamere”, Allen E. Kaye, P.C., Allen E. Kaye, P.C., Allen E. Kaye, Esq., Harvey Shapiro, Esq., Bernard J. Rostanski and Jack Gladstein, Esq.

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*
                         Defendants.
______________________________________
STATE OF NEW YORK  )
COUNTY OF KINGS      )    ss:

         I, Cheryl D. Uzamere, being duly sworn, depose and says that:

        1)     I am the Plaintiff in the above entitled action.

        2)     I make this Affidavit in support of my motion for summary judgment and default judgment against the Defendants.

       3)    That on November 20, 1979, the Defendant, Senator Ehigie Edobor Uzamere committed perjury by placing fraudulent information regarding his identity and birthday on the Application and Affidavit for License to Marry.

       4)    That on or around December 17, 1979, attorneys Allen E. Kaye, Harvey Shapiro and Bernard J. Rostanski committed perjury by placing, swearing to and notarizing false information regarding Defendant Uzamere's identity and birthday on Defendant Uzamere's I-130 immediate relative sponsorship form.

       5)    That Plaintiff received correspondence from Jack Gladstein, Esq. dated October 1, 2003, in which Defendant Gladstein used the fraudulent name “Godwin Uzamere” that Defendants Uzamere, Kaye, Shapiro and Rostanski fraudulently swore to/notarized as true and correct.

       6)   That Plaintiff effected service of her Verified Complaint and Notice to Admit on Defendants Uzamere, Kaye, Shapiro and Gladstein on July 31, 2009; Plaintiff effected service of her Verified Complaint and Notice to Admit on Defendant Rostanski on August 3, 2009; proof of mailing is hereby attached as Exhibit A. Affidavits of service are filed with this Court.

        7)   That Plaintiff's Notice to Admit contains the following documents that were falsified and bear Defendants' signatures:

              a)     Correspondence and attachments from T. Diane Cejka of the U.S. Department of Homeland Security's Citizenship and Immigration Service regarding the identity of Defendant Uzamere;

              b)     Affidavit and Application for License to Marry in which Defendant Uzamere wrote the fictitious name “Godwin Uzamere” on top of the application, but signed his real name at the bottom;

             c)     Falsified marriage certificate that was used by Defendants Uzamere, Kaye, Shapiro and Rostanski to apply for IR1 permanent residence for Defendant Uzamere;

             d)    I-130(E) immediate relative sponsorship form that bears the fictitious name “Godwin E. Uzamere” and contains the names and/or signatures of Defendants Allen E. Kaye, Harvey Shapiro and Bernard Rostanski;

             e)     Immigration and Naturalization's Notice of Entry of Appearance as Attorney or Representative bearing the fictitious name “Godwin E. Uzamere” and signed by Defendant Harvey Shapiro;

             f)     Correspondence from the U.S. Immigration and Naturalization Service bearing file number A35-201-224 based on Defendant Uzamere's real name;

             g)    Correspondence from the U.S. Immigration and Naturalization Service bearing file number A24-027-764 based on fictitious name “Godwin E. Uzamere”;

              h)    Correspondence from Defendant Kaye dated July 22, 2003, in which Defendant Kaye tacitly admits that Defendant Ehigie Uzamere is Plaintiff's husband;

              i)     Correspondence from Defendant Gladstein dated October 1, 2003 in which he fraudulently refers to Defendant Uzamere as “Godwin Uzamere”;

              j)     Subpoenas issued during Plaintiff's divorce action index number 26332/07 for Defendants Kaye and Shapiro to appear in court to identify Defendant Uzamere.

              k)    Defendant Kaye's letter sent to the Honorable Jeffrey S. Sunshine dated March 24, 2009, in which Mr. Kaye states that “I do not anticipate being in Court on March 30, 2009”; and,

              l)     Photograph of Defendant Uzamere with his illegal wife.

       8)    That as of the date of the submission of this Affidavit, Defendants have failed to interpose an answer, and have failed to deny the issues presented to them with regard to the falsified documents that bear their names.

       9)    That Plaintiff has gone so far as to mount a public campaign on her website, denouncing the actions of the Defendants; and that in spite of Plaintiff's public campaign to expose the Defendants, none of them have attempted to mount a truthful/factual defense against Plaintiff. Plaintiff's cyber-campaign against Defendants is hereby attached as Exhibit B1-3.

       10)  That Plaintiff asserts that she has mounted a legal onslaught against which Defendants have no legal defense.

       11)  That Plaintiff further asserts that based on her understanding of CPLR § 3215 and CPLR Rule 3212, Defendants have defaulted by not interposing an answer; and that further to this, Defendants have no defense to Plaintiff's cause of action such that legally this Court must grant Plaintiff's request.

        WHEREFORE, Plaintiff prays that this Court grants Plaintiff's summary judgment and default judgment against the Defendants, and for such other and further relief as to this Court seem just and proper.

mysignature2.jpg 
Cheryl D. Uzamere
Appearing Pro Se
1209 Loring Avenue
Apt. 6B
Brooklyn, NY  11208
Tel.: (718) 647-1708
Fax: (267) 543-3317

Proof of Service to
Senator Uzamere

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ehigieuzamere_usps_express_mail_receipt.jpg

Proof of Service to
Allen E. Kaye, Esq.
(and Allen E. Kaye, P.C.)

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allenkaye_return_receipt.jpg

Proof of Service to
Harvey Shapiro

harveyshapiro_usps_search_results.jpg
harveyshapiro_return_receipt.jpg

Proof of Service to
Bernard J. Rostanski

bernard_rostanski_usps_search_results.jpg
bernardrostanski_return_receipt.jpg

Proof of Service to
Jack Gladstein, Esq.

jackgladstein_usps_search_results.jpg
jackgladstein_env_refusal_stamp.jpg

...Proof of the marriage

marriagecertificate.jpg

...Proof of Defendant Uzamere's identity
("A" number in corner is for false identity "Godwin E. Uzamere")

ehigiefakenumber.jpg

...Proof of Defendant Uzamere's identity
("A" number in corner is for real identity "Ehigie Edobor Uzamere")

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...oh yeah, child support

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...and lest we forget, Judge Sunshine declared that the names "Godwin E. Uzamere and "Ehigie Edobor Uzamere
both belong to Plaintiff's husband

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...and in case Judge Sunshine chooses not to ur, um, "behave", there is a standing appeal against Senator Uzamere
...and an arrest warrant which Plaintiff plans to reactivate

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