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CJA's May 17, 2021
complaint
EVIDENTIARY WEBPAGE FOR FOOTNOTE 3
pertaining to the disqualification for interest
of DOI Commissioner
Margaret Garnett
& Deputy Commissioner Daniel Cort
REFERRED-TO:
RECORD: CJA's declaratory judgment action
CJA v. Cuomo,...Schneiderman, et. al.
(Bronx Co. #302951-2012; NY Co. #401988-2012)
RECORD: CJA's FIRST citizen-taxpayer action
CJA v. Cuomo,...Schneiderman, et. al.
(Albany Co. #1788-2014)
RECORD: CJA's intervention in Legislature's declaratory Judgment
action
Senate, Assembly... v. Rice...Commission to Investigate Public Corruption
(NY Co. #160941-2013)
RECORD: CJA's SECOND citizen-taxpayer action
CJA v. Cuomo,...Schneiderman...DiFiore
(Albany Co. #5122-2016 -- & Appellate Division & Ct of Appeals)
REFERRED-TO:
CJA's February 11, 2021
conflict-of-interest/misconduct complaint vs A.G James, Solicitor General (&
former A.G.) Underwood for litigation fraud...
------------
NYC Dept of
Investigation
Commissioner MARGARET GARNETT
November 27, 2018
"City
Council Considers De Blasio Nominee for Department of Investigation"
Gotham Gazette (Samar Khurshid)
February 26, 2020
"DiNapoli,
James, and Garnettee Announce Sentencing in Straw Donation Scheme"
Comptroller DiNapoli press release
1.
May 16, 2018 transmitting e-mail to Garnett
May 17, 2018 transmittinge-mail to Garnett
CJA's May 16, 2018 NOTICE/complaint to Acting
Attorney General Underwood --
"NOTICE:
Corruption and Litigation Fraud by Former Attorney General Eric Schneiderman
and his Office – and Your Duty to Take Investigative and Remedial Action,
most immediately, in the Citizen-Taxpayer Action: Center
for Judicial Accountability, et al. v. Cuomo,…Schneiderman, et al. (Albany
Co. #5122-16; RJI #01-16-122174) and pursuant to 'The Public Trust Act'
(Penal Law §496:
'Corrupting the government')"
substantiating EVIDENTIARY webpage for May 16, 2018 NOTICE/complaint
[NOTE: May 16, 2018 NOTICE/complaint
and transmitting e-mails are:
Exhibits A-1, A-2 to CJA's Feb. 11, 2021 attorney misconduct complaint
vs AG JAMES & former AG/now Solicitor General Underwood]
2.
May 18, 2018 transmitting e-mail to Garnett
CJA's May 18, 2018 letter to Interim New York Attorney General Candidates --
"Testing the Fitness of Acting Attorney General Barbara Underwood --
& Every Other Candidate for Interim Attorney General"
3.
May 30, 2018 transmitting e-mail to Garnett
&
June 6, 2018 transmitting e-mail to Garnett
CJA's May 30, 2018 letter to Attorney General Underwood --
"What is the Status? – CJA’s May 16, 2018 letter:...
(1) Disclosure
of facts giving rise to your duty to secure appointment
of independent/outside counsel to investigate and report on your ethical
and law enforcement obligations with respect to the May 16, 2018 NOTICE,
or a special prosecutor;
(2) FOIL/records
request – conflicts of interest; Executive Law §63.11;
legislative oversight."
substantiating EVIDENTIARY webpage for May 30, 2018 letter
[NOTE: May 30, 2018 letter and
transmitting e-mails are:
Exhibits B-1, B-2 to CJA's Feb. 11, 2021 attorney misconduct complaint
vs AG JAMES & former AG/now Solicitor General Underwood]
---------------
CJA's June 14, 2018 e-mail --
"NOTICE: OSC/with preliminary injunction & TRO to be presented to the
Appellate Division, 3rd Dept"
Plaintiffs' drafted Appeal Brief --
cover questions
presented table
of contents brief
Plaintiffs' drafted Record on Appeal --
cover table
of contents
Stipulation
pursuant to CPLR
§5532 in lieu of Certification
Statement pursuant to CPLR §5531
CJA's June 18, 2018 e-mail
CJA's June 18, 2018 e-mail
CJA's July 6, 2018 e-mail --
"Stipulation in Lieu of Certification Pursuant to CPLR 5532..."
Record on Appeal: Vol. 1
Record on Appeal: Vol. 2
Record on Appeal: Vol. 3
(without stipulation)
Stipulation in Lieu of Certification
click here for:
record of proceedings in Appellate Division, Third Dept.
Illustrative e-mails sent to Garnett
--
essentially of the ENTIRETY of the proceedings
August 6, 2018 e-mail.
October 9, 2018 affidavit of service,
annexing Sept. 12, Sept 11, Aug 7, Aug 6 e-mails
September 26, 2018 e-mail
Oct 4, 2018 affidavit of service for reply brief, annexing Oct 4, 2018
e-mail
CJA's October 12, 2018 e-mail
"...ON-HOLD: Appellants' Fully-Submitted OSC to Disqualify the Court for
Demonstrated Actual Bias, Etc."
NY Jurisprudence -- 1963
NY Jurisprudence 2nd -- 2010
October 15, 2018 e-mail --
"...Demanding a "Surreply" from Attorney General Underwood, Personally as to
the CPLR 5015(a)(4) Vacatur Relief Sought by Appellants' Fully-Submitted
OSC"
October 23, 2018 affidavit of service annexing Oct 23, 2018 e-mail
November 13, 2018 affidavit of service annexing November 13, 2018 e-mail
November 27, 2018 affidavit of service annexing November 27, 2018 e-mail
December 13, 2018 e-mail
December 14, 2018 e-mail
December 14, 2018 e-mail
* * *
NYC Dept of Investigation
First
Deputy Commissioner DANIEL CORT
Attorney General Schneiderman's March 31,
2014 announcement
of appointment of Daniel Cort to lead his Public
Corruption Unit &
here
December 14, 2018
"NYC
Department of Investigation Names New Executives"
CJA's October 26, 2012 complaint, filed
with Dan Cort,
Chief of Manhattan D.A. Morgenthau's "Public
Integrity Unit",
his November 16, 2012 letter, & CJA's subsequent
correspondence
sent to him, to which he was cc'd
CJA's October 26, 2012 complaint to New York County Clerk Norman
Goodman --
"Quality Control at the New York County Clerk's Office:...(1)
Official Misconduct by Chief County Clerk James A. Rossetti; (2) Official
Misconduct by Chief Clerk Joseph F. Antonelli; (3) Official Misconduct by a
Uniformed Officer, believed to be a 'major', who refused to give his name or
badge number; (4) Certification Request Pursuant to Judiciary Law 255"
CJA's October 26, 2012 Affidavit in support of complaint --
"MISSING DOCUMENTS -- Affidavit in support of
misconduct complaint against Chief Deputy County Clerk Joseph A. Rossetti,
Chief Clerk Joseph F. Antonelli, & uniformed officer who refused to furnish
his name or badge number"
Exhibit
A: photos -- photo; photo; photo; photo, photo
Exhibit
B: Executive Summary to CJA's October 27, 2011 Opposition
Report
Exhibit
C: Bronx Co. Clerk's Office website
Exhibit
D: Plaintiff Sassower's August 30, 2012 letter to Assistant
Attorney General Andrew Meier
Exhibit
E: Assistant Attorney General Meier's September 12, 2012 and
September 13, 2012 e-mails
Exhibit
F: Plaintiff Sassower's unresponded-to e-mails to Chief Clerk
Antonelli,
with cc's to Chief Deputy Clerk James Rossetti, Assistant
Attorney General Andrew Meier,
& Bronx Co. Records Managment Officer Mark
Nusenbaum
(1) October 11, 2012 e-mail -- "Call to Chief Deputy Clerk Rossetti: WHAT IS
THE STATUS: Missing Records..."
(2) October 10, 2012 e-mail -- "I HAVE BEEN WAITING ON THE LINE: WHAT
IS THE STATUS? Missing Records..."
(3) September 28, 2012 e-mail -- "WHAT IS THE STATUS? Missing Records..."
(4) September 20, 2012 e-mail -- "STATUS: Missing Records"
(5) September 14, 2012 e-mail -- "Missing Record..."
November 9, 2012 letter from Administrative Judge Heitler's law clerk --
"Center for Judicial Accountability, et al. v. Cuomo, et al., Index No.
401988/2012"
November 16, 2012 letter from Manhattan District Attorney Public
Integrity Unit Chief Dan Cort
CJA's January 10, 2013 letter-complaint to New York County Clerk
Goodman --
"STATUS OF CJA'S OCTOBER 26, 2012 LETTER: Quality Control at the New York
County Clerk's Office..."
CJA's February 11, 2013 complaint to Unified Court System Inspector General
Sherrill Spatz --
"Complaint against New York County Clerk Norman Goodman for
obstructing justice and collusion in record tampering..."
CJA's February 11, 2013 letter to Sherry Klein Heitler, Administrative Judge
for Civil Matters/First Judicial Department --
"Your
Mandatory Supervisory and Disciplinary Responsibilities..."
Administrative Judge Klein Heitler's February 13, 2013 letter
CJA's May 1, 2013 letter to Inspector General Sherrill Spatz --
"Your Nonfeasance and Misfeasance: February
11, 2013 complaint against New York County Clerk Norman Goodman for
obstructing justice and collusion in record tampering: Center for
Judicial Accountability, Inc., et al. v. Cuomo, et al. (NY Co.
#401988/2012)
* *
*
CJA's March 7, 2013 FOIL request to OCA for records relating to
Office of Inspector General
OCA's March 20, 2013 FOIL response
C JA's
July 15, 2013 FOIL request to OCA for records relating to Office of
Inspector General
OCA's July 22, 2013 FOIL response
-------------------------------
"county clerks in New York
City receive a salary not less than that received by a Judge of the Civil
Court of New York City, subject to possible increases by the Chief
Administrator of the Courts (County Law, § 908).", Durante
v. Evans, 94 A.D.2d 141, 145 (3rd Dept. 1983)
-------------------------------
Articles of Note -- about Chief Administrative Judge Heitler -- "New
York's Real Scandal", NYT, 1/30/15 (Joe Nocera)
-------------------------
------------------
New York City Charter -- Chapter 68 "Conflicts of Interest"
Commissioner Garnett's November 13, 2019 testimony
before the City
Council's Committee on Oversight & Investigations
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