In the United State
Court of Federal Claims
Cheryl D. Uzamere
- against -
United States of America
- and -
Honorable Barack H. Obama, President of
of the United States; F. Michael Kelleher,
Special Assistant to the President;
Honorable Eric H. Holder, Jr., Attorney
General, United States Department of
of Justice; Thomas E. Perez,
Assistant Attorney General,
Division, United States Department
Justice; Marc Kappelhoff, Acting
Coordination and Review, Civil Rights
Division, United States Department of
Justice; Rita J. Craig, Acting Chief,
Coordination and Review Section,
United States Department of Justice;
Judy Preston, Acting Chief, Special
Litigation Unit, United States Department
Justice; Laurie O. Robinson, Assistant
General, United States Depart-
ment of Justice;
Glenn A. Fine, Inspector
General, United States Department of
Justice; Honorable Janet Reno, Secretary,
United States Department
Security; Lynden Melmed, Chief Counsel,
United States Citizenship and Immigration
Rachel McCarthy, Counsel,
United States Citizenship
Services; Joseph Demarest, Special-Agent
-in-Charge, Federal Bureau of Investiga-
tion; Sandra A. Bungo, Unit Chief, United
Department of Justice; Eric A.
Johnson, Special-Agent-in Charge, United
Department of Justice; United
States Department of Justice, the United
States Department of Homeland Security
the United States Citizenship and
1) At all times hereinafter mentioned, Plaintiff was and still is a resident of the City of Brooklyn, County of Kings and
State of New York.
2) This Court has jurisdiction over this action pursuant to 28 USC §1491, which says that “The United States Court of Federal Claims shall have jurisdiction to render judgment upon any
claim against the United States founded...upon the Constitution...”
3) This Court has jurisdiction over this action as it is an implied cause of action in the manner of Bivens v. Six Unknown Named Agents, 403 U.S. 388 (1971).
3) Defendant is the United States acting by and through the following employees: Honorable Barack H. Obama; Honorable Eric
H. Holder, Jr.; Thomas E. Perez; Marc Kappelhoff; Rita J. Craig, Judy Preston; Laurie O. Robinson; Glenn A. Fine; Honorable
Janet Reno; Lynden Melmed; Rachel McCarthy; Joseph Demarest; Sandra A. Bungo; Eric A. Johnson, and those federal agencies
for which the aforesaid individuals are employed, to wit: the United States Department of Justice, the United States Department
of Homeland Security and the United States Department of Citizenship and Immigration Services.
ASSERTIONS/ALLEGATIONS COMMON TO ALL PARTIES
4) Plaintiff first invokes the followings laws: 1) Title 18 of the United States Code, Crimes and Criminal Procedure, Section 4, misprision of felony, that says “Whoever, having knowledge of the actual commission of a felony cognizable by a court of the United
States, conceals and does not as soon as possible make known the same to some judge or other person in civil or military authority
under the United States, shall be fined under this title or imprisoned not more than three years, or both” and Title 18 of the United States Code, Section 3290 that says “No statute of limitations shall extend to any person fleeing from justice.”
5) Plaintiff strongly asserts that she is now familiar
with the manner in which Ashkenazi members of a court's judiciary acts when a litigant against whom charges have been brought
is also a member of the Ashkenazim, and what this Court will do as soon as it receives Plaintiff's lawsuits: 1) it will employ
clerk of of Court Hazel C. Keahey to pretend that the selection of a Jewish judge is “random”, when, in fact,
the selection of the aforesaid Ashkenazi judge is purposeful and intentional; 2) the Ashkenazi judge will render a decision
that ensures that the case is dismissed before it is presented to the jury; 3) if the lawsuit's decision is appealed, the
lawsuit is subsequently presented to a group of judges, the presiding judge being a member of the Ashkenazim; 4) the case
is dismissed and the non-Ashkenazi litigant's constitutional rights to petition the government for a redress of grievances,
to freedom of speech, to due process of law and to equal protection under the law are violated with the litigant having no
6) Plaintiff strongly asserts
that 1) every exhibit presented in Plaintiff's complaint is irrefutable; and, 2) that there is no amount of subterfuge any
Jewish judge can use to change that the Jewish judge has lied, and that the evidence Plaintiff submitted with lawsuit is irrefutable.
7) That Plaintiff asserts that at the time of the
aforesaid individuals' defamation of the Plaintiff, Plaintiff was litigating Index Number 26332/2007, her divorce action against
her then husband Senator Ehigie Edobor Uzamere and Index Number 18012-2009, Plaintiff's action for fraud against Senator Ehigie
E. Uzamere, immigration attorneys Allen E. Kaye, Harvey Shapiro, notary public/traffic court judge Bernard J. Rostanski and
immigration/divorce attorney Jack Gladstein.
8) That Plaintiff asserts that during Plaintiff's litigation of her divorce action, Plaintiff's ex-husband's attorney/nephew,
Eugene O. Uzamere submitted a fraudulent counter-affidavit to the Honorable Jeffrey S. Sunshine for the purpose of hiding
Plaintiff's ex-husband's true identity, and to hide ex-husband's commission of immigration fraud, identity fraud and non-payment
of child support for which Justice Sunshine never filed a contempt of court order against the aforesaid attorney's act of
perjury; and although during Plaintiff's divorce action she obtained proof from Defendant's agent the United States Citizenship
and Immigration Services of Plaintiff's ex-husband's true identity (see Exhibit B, pages 1-4 and Exhibit
C, page 1-2).
Plaintiff asserts that paragraphs 9 and 10 of Daily News' and Scott Shifrel's newspaper article states that: “The senator,
however, is a cousin of her actual ex-husband, Godwin Uzamere, according to an affidavit he filed in Supreme Court...Her obsession
with his destruction has taken her mental ailment to a new level which should not be encouraged,” Godwin Uzamere's affidavit
said'”; and that paragraph 10 of the aforesaid newspaper article quotes verbatim a part of paragraph 10 of Plaintiff's
ex-husband's fraudulent counter-affidavit.
10) That Plaintiff asserts that her ex-husband's attorney Eugene O. Uzamere acquired the false identity from the fraudulent
I-130 immediate relative sponsorship form that was falsified by Plaintiff's ex-husband, and by ex-husband's attorneys Allen
E. Kaye, Harvey Shapiro, Bernard Rostanski and Jack Gladstein, and that the false identity is still on the birth certificate
of the child of Plaintiff's marriage (see Exhibit D, pages 1-3 and Exhibit E).
11) That Plaintiff strongly asserts that as of this
Court's reading of paragraphs 8, 9, 10 and this Court's viewing of the accompanying exhibits, that it is obvious that Plaintiff
has sufficiently proven that attorneys Allen E. Kaye, Harvey Shapiro, Bernard J. Rostanski, Jack Gladstein and Eugene O. Uzamere
committed acts of immigration fraud, identity fraud and facilitated fraud upon the court; and that further to this, that the
Defendant, by and through its employees never prosecuted the aforesaid attorneys for the crimes Plaintiff has successfully
proven that the aforesaid attorneys committed.
12) That Plaintiff asserts that in paragraphs 1, 2 and 7, Scott Shifrel admits that he obtained information from New York
State court employees based on his statement that “A woman suing her Nigerian husband for millions started screaming
and ripping off her clothes before her arraignment yesterday on charges of threatening to kill a Brooklyn judge. Cheryl Uzamere,
50, known around courthouse circles for her anti-Semitic screeds against judges and others was declared to be mentally unfit...oh,
she's a smart person and she really knows how to use the system, said one courthouse source.”
13) That Plaintiff asserts that after she tried to lodge complaints concerning
fraud upon the court against Justice Sunshine with Defendant New York State Unified Court System's Office of the Inspector
General, Plaintiff was charged with Penal Law §240.30/aggravated harassment.
14) That Plaintiff asserts that she was arrested and kept in dirty cells, given hardened bread to eat, and not allowed to
bath for parts of two days.
Plaintiff asserts that she was subsequently transported to three different hospitals and then to the Rose M. Singer Detention
Center for 33 days.
16) That Plaintiff
asserts that she was then presented to Kings County Criminal Court where the charges against her were dismissed (see
17) That Plaintiff
asserts that she was then transported to one of New York State's psychiatric facilities where Plaintiff was not permitted
to use the services of the aforesaid psychiatric facility's notary public to notarize any documents pertaining to Claimant's
handwritten notice of claim against the State of New York.
18) That Plaintiff asserts that she was released 60 days later on February 5, 2010.
19) That Plaintiff asserts that on or around February 23, 2010, while Plaintiff was at home faxing a letter of complaint regarding
judicial corruption in New York State, Plaintiff's apartment was invaded by the New York City Police Department; that Plaintiff
was then pulled out of her apartment, falsely accused of not taking her psychotropic medication by a social worker from Brookdale
Hospital Center and was eventually transferred to a New York State psychiatric facility and hospitalized for nearly three
(3) months (see Exhibit G).
20) That Plaintiff asserts
that although the Kings County Clerk's minutes correctly represent that the Plaintiff's action for divorce was uncontested
because ex-husband never interposed an answer, never filed a notice of appearance and never physically appeared although Justice
Prus and Justice Sunshine ordered 19 S.L.A.P.P-like, unnecessary adjournments, Justice Sunshine fraudulently fraudulently
represented that Plaintiff's ex-husband, who is a millionaire, was present at the preliminary conference in violation of New
York Code Rules and Regulation Section 202.16(f)(1)(vi)(b) that says that “Both parties personally must be present in
court at the time of the conference, and the judge personally shall address the parties at some time during the conference”,
and New York Code Rules and Regulations Section 202.16(k)(5)(i) that says that “The failure to comply with the provisions
of this subdivision shall be good cause, in the discretion of the judge presiding...(i) to draw an inference favorable to
the adverse party with respect to any disputed fact or issue affected by such failure”; and that although the aforesaid
laws direct justices to require the present of both spouses at the preliminary conference, and requires judges to rule in
favor of the party who fails to appear, that Justice D'Emic subsequently ruled in the no-show ex-husband 's favor; and that
Plaintiff received nothing from her 30-year marriage (see Exhibit H, pages 1-3).
21) That Plaintiff asserts that she litigated Index Number 18012-2007,
action for fraud (including tolling the statute of limitations) against ex-husband Ehigie E. Uzamere, Allen E. Kaye, Esq.,
Harvey Shapiro, Esq., Bernard J. Rostanski, Esq.; and Jack Gladstein, Esq.; that the aforementioned individuals failed to
interpose an answer or file an appearance; that during Justice Schack's adjudication of Plaintiff's lawsuit, Justice Schack
attempted to render a decision that Plaintiff was unfit to stand trial against Plaintiff's no-show ex-husband and the four
(4) no-show Jewish attorneys; and that in spite of Defendants' failure to interpose and answer and failure to file an appearance,
Justice Schack ruled in favor of the no-show ex-husband and the no-show attorneys (see Exhibit I).
22) That Plaintiff asserts that she is presently
litigating Index Number 10-00998 at the Nassau County Supreme Court against the Daily News and Scott Shifrel so as to avoid
what Plaintiff alleges to be acts of Talmud-oriented bias at the Kings County Supreme Court.
23) That Plaintiff asserts that with regard to her action for defamation
against the Daily News and staff writer Scott Shifrel, that their attorney, Anne B. Carroll, filed a demand to change the
venue (see Exhibit J).
24) That on July 2, 2010, Plaintiff asserts she received correspondence from the Kings County Clerk's Office; that the the
index number that was supposed to be placed on the correspondence was missing; that the correspondence was entitled “Kings
County Clerk's Office, Equity Department, Window 9” in an envelope labeled “County Clerk's Office, County of Kings...mailed
from zip code 11201”, that although Plaintiff's action for defamation is in Nassau County; Plaintiff strongly alleges
that attorney Anne B. Carroll enlisted the assistance of New York State court employees to send the aforesaid document to
trick Plaintiff into believing that her action for defamation was transferred to Kings County Supreme Court, and to coerce
Plaintiff by manipulating her fear that Plaintiff's action would be transferred to the Kings County Supreme Court so that
Plaintiff would instead allow lawsuit to be transferred to the New York County Supreme Court where Plaintiff's lawsuit would
then be transferred to the Honorable Judge Shulman who is presently adjudicating Index Number 100053/2008, lawsuit for defamation
between the Honorable Larry D. Martin, a sitting judge against Defendants the Daily News and columnist Errol Louis; and based
on what Plaintiff alleges was Anne Carroll's belief that she could manipulate Plaintiff's fear of litigating her case in Kings
County and arrange for Justice Shulman's to render one decision on the not-legally-knowledgeable Plaintiff that would be different
from Justice Shulman's decision on the rich, powerful judge Exhibit K, pages 1 and 2).
25) That Plaintiff asserts that on Friday, July
23, 2010, she received all the motion papers that Nassau County Supreme Court's employees stamped as having received on July
19, 2010; that Plaintiff's motion papers were accompanied by correspondence in which Plaintiff was ordered by the court to
add the court's address that was missing on Plaintiff's notices of motion, and then to effect service on the Daily News and
Scott Shifrel again (see Exhibit L, page 1-5); that New York State Civil Practice Law and Rules Section
2101(f) says that “The party on whom a paper is served shall be deemed to have waived objection to any defect in form
unless, within two days after the receipt thereof, he returns the paper to the party serving it with a statement of particular
objections”; that instead of attorney Anne Carroll filing an objection regarding the missing court address (that she
already knows) within the two (2) days allotted to her by the aforesaid law, Anne Carroll instead contacted Nassau County
Supreme Court or the Nassau County Clerk's Office and told one of its clerks to send Plaintiff the papers to be corrected
insofar as Plaintiff informed Ms Carroll that she would not accept untimely filed papers from the Defendants; and that Plaintiff
alleges that it was Ms. Carroll's scheme to defraud Plaintiff of her right to receive a decision from the court in the least
amount of time possible by coercing Plaintiff to believe that Plaintiff had no other choice but to beg the court to extend
the time to answer; and that if the no-interposing-an-answer-having, no-reasonable-excuse-meritorious-defense-having Defendants
succeeded in coercing the Plaintiff to request and receive more time, that attorney Anne Carroll would then engage the court's
assistance to employ S.L.A.P.P-like adjournments until Plaintiff gets so frustrated that Plaintiff gives up.
That Plaintiff asserts that with regard to the proper handling of papers containing mistakes, omissions, defects and irregularities,
she researched New York State Civil Practice Law and Rules Section 2101(f); New York State Civil Practice Law and Rules Section
2102(c); New York State Civil Practice Law and Rules Section 2001 and New York Code Rules and Regulations Section 202.5(d)(1)(i)(ii)(iii)(iv)(v)(a)(b)(c),
and discovered that based upon the aforesaid laws, Nassau County Supreme Court and Nassau County Clerk's Office, by their
employees, violated the law, thereby violating Plaintiff's New York State and U.S. constitutional right to due process.
27) That Plaintiff asserts that July 29, 2010, she
received motions and supporting affidavits from attorney Anne B. Carroll that she falsely claimed she served the first set
on Plaintiff by mail; that on page 9 of Anne Carroll's affirmation, she states that “the applicability of the privilege
is a question for this Court to decide as a matter of law by comparing the judicial or other official document at issue with
the material that plaintiff has put into controversy...The Article (Daily News article) reports that the Nigerian senator
whom Uzamere claims is (or was) her husband [is] however, a cousin of her actual ex-husband...a facial comparison of the article
with Godwin Uzamere itself...demonstrates defendants' statements are a fair and true report of the document” (see Exhibit
M, pages 1-2).
Plaintiff asserts that in spite of Ms. Carroll's illegal attempt to pass off as true and correct the Daily News and Scott
Shifrel's false statements regarding the fraudulent counter-affidavit to which they referred, Justice Sunshine rendered a
decision dated May 12, 2009 – six (6) months earlier – in which he stated that “...defendant's motion to
dismiss this action upon the grounds that he is not the husband of the plaintiff is denied in its entirety. The defendant
is the husband in conformity with the parties' marriage on November 21, 1979” (see Exhibit N, pages 1-2);
that based on Justice Sunshine's decision and Plaintiff's commonsense, New York State court employees did not have privilege
to disseminate a document to the Daily News and Scott Shifrel known by court personnel to be fraudulent; and that based on
Plaintiff's having provided Anne Carroll with Justice Sunshine's decision, Ms. Carroll's statements, including her reference
to the “counter-affidavit” that is not authenticated by a consular employee or notarized by a duly licensed New
York State notary public, Ms Carroll committed perjury for which Plaintiff is sure she will not be charged with contempt and
prosecuted because of her having white skin and Jewish defendants.
29) That Plaintiff asserts that she filed the first of four (4) implied causes of action claims in the manner of Brown v.
State of New York, 89 N.Y.2d 172, 674 N.E.2d 1129, 652 N.Y.S.2d 223, 65 USLW 2355 (1996) for New York State Constitutional
30) That Plaintiff
asserts that she created the website http://www.thecrimesofsenatoruzamere.net/ to chronicle her attempts to obtain justice; as a means to inform the international public of Defendant's
refusal to bring to justice those alleged by Plaintiff to have committed crimes against her, and to see if any of Defendant's
employees would read Plaintiff's website, have pity on Plaintiff and assist her.
31) That Plaintiff asserts that in response to Plaintiff's attempt to file her complaint regarding fraud upon the court, judicial
corruption and the encroachment of the Talmud into the New York State Unified Court System Defendant, Defendant's employee
Rita J. Craig, acting at the behest of Mark J. Kappelhoff, sent Plaintiff correspondence that said that “this office
will take no further action regarding your letter” (Exhibit O).
32) That Plaintiff asserts that in response to Plaintiff's attempt to
file her complaint regarding fraud upon the court, judicial corruption and the encroachment of religion into the New York
State Unified Court System, Defendant's employee Sandra A. Bungo stated that “there is no evidence of misconduct on
the part of any FBI employee. Therefore, no further action will be taken by this office” (see Exhibit P).
33) That Plaintiff asserts that in response to Plaintiff's
attempt to file her complaint regarding fraud upon the court, judicial corruption and and the encroachment of religion into
the New York State Unified Court System, Defendant's employee Eric A. Johnson that “the matters
that you raised are more appropriate for review by another office or agency” (see Exhibit Q).
34) That Plaintiff asserts that in response to Plaintiff's
attempts to file her complaint regarding fraud upon the court, judicial corruption and the encroachment of the Talmud into
the New York State Unified Court System, Defendant's White House employee F. Michael Kelleher said that “...due to the
separation of powers, it is not within our authority to become involved in legal matters” (see Exhibit R).
35) That Plaintiff alleges that the four (4) employees
with whom Plaintiff unsuccessfully tried to file complaints regarding violation of Plaintiff's constitutional rights are not
the only ones; that Plaintiff filed many complaints, some of which are displayed at Plaintiff's website http://www.thecrimesofsenatoruzamere.net.
36) That Plaintiff
asserts that the pattern of Defendant's employees with reference to Plaintiff's complaints are: 1) to refuse to handle it;
or, 2) to transfer it to another federal agency, department, division, section or unit where another of Defendant's employees
emulates the same behavior as their predecessors.
37) That Plaintiff alleges that Allen E. Kaye, Harvey Shapiro, Bernard J. Rostanski, Jack Gladstein, Justice Prus, Justice
Sunshine, Justice D'Emic and Justice Schack are Ashkenazi Jews.
38) That Plaintiff asserts that the aforesaid individuals are adherents of the Talmud.
39) That Plaintiff asserts that the Talmud, Tractate Abodah Zarah, Folio
26b promulgates the religious doctrine “the law of the moser”; that the aforesaid religious doctrine prohibits
Jews from reporting the crimes of fellow Jews to non-Jewish authorities under penalty of shunning, or penalty of death (see
Exhibit S, pages 1-3).
40) That Plaintiff asserts that the Talmud, Tractate Baba Kamma, Folio 113a promulgates the religious doctrine of using “subterfuge”
to deceive “heathens” (see Exhibit T).
41) That Plaintiff asserts that the Talmud, Tractate Sanhedrin, Folio 108b promulgates the religious doctrine that blacks
are cursed and meant to be enslaved (Exhibit U, pages 1-3).
42) That Plaintiff asserts that this complaint's exhibits have proven beyond a reasonable doubt that attorneys Allen E. Kaye,
Harvey Shapiro, Bernard Rostanski, Jack Gladstein and Eugene O. Uzamere facilitated the identity fraud of Plaintiff's ex-husband
Ehigie Edobor Uzamere.
42) That Plaintiff
asserts that in an effort to ensure that this Court does not employ the principle of “res judicata” or collateral
estoppel to dismiss Plaintiff's complaint based on Plaintiff's previous unsuccessful encounters with both state and federal
judges, Plaintiff concedes that she has litigated cases against the aforesaid individuals in front of the Honorable Nicholas
G. Garaufis (who is Jewish and refused to recuse himself), and the Honorable Leonard B. Sands (also Jewish and refused to
recuse himself) in spite Plaintiff's allegations that would give rise to Plaintiff's belief that the federal judges were partial
pursuant to 28 USC §455, disqualification of judges.
43) That Plaintiff asserts that on November 5, 2010, Daily News and Scott Shifrel revisited the facilitation of identity fraud
commenced by attorneys Allen E. Kaye, Harvey Shapiro, Bernard Rostanski, Jack Gladstein and Eugene O. Uzamere; that attorney
Anne B. Carroll's affirmation containing her statement regarding he ex-husband's identity and the falsified counter-affidavit
also revisited the original facilitation of identity fraud by the aforesaid attorneys in much the same way that a rapist sexually
assaults a victim once, catches her on another occasion and violates her again; that this Court must not view the violations
of Defendant's employees as the same crimes that the aforesaid attorneys perpetrated against Plaintiff; that each act, while
revisiting the original facilitation of identity fraud, is a separate act.
1 – PLAINTIFF'S FIRST CAUSE OF ACTION
VIOLATION OF PLAINTIFF'S RIGHT DUE PROCESS UNDER THE LAW BASED ON DEFENDANT'S
EMPLOYEES' MISPRISION OF FELONY
Plaintiff hereby repeats and realleges each and every allegation contained in paragraphs 1 through 44 as if fully set forth
45) That Plaintiff asserts
that Ballentine's Law Dictionary says that “due process” is “law administered through courts of justice,
equally applicable to all under established rules that do not violate fundamental principles of fairness”; that Defendant
owed Plaintiff the constitutional duty of administering all rules fairly toward Plaintiff by investigating the aforesaid justices'
acts of fraud upon the court, those acts including, but not limited to: 1) Justice Sunshine's refusal to declare attorney
Eugene O. Uzamere in contempt of court for submitting the fraudulent counter-affidavit to the court; 2) Justice Sunshine's
suggestion to use videoconferencing from Nigeria to pretend to ascertain the identity of Plaintiff's ex-husband instead of
ascertaining Plaintiff's ex-husband's identity by the documents that Plaintiff obtained from Defendant's agent the United
States Citizenship and Immigration Services; 3) Justice Sunshine's complicity (stated or implied) in the dissemination of
the fraudulent counter-affidavit to the Daily News and Scott Shifrel; 4) Justice Prus' and Justice Sunshine's complicity in
adjourning Plaintiff's divorce action 19 times, although Plaintiff's ex-husband never interposed an answer; Justice D'Emic's
complicity for continuing the acts of fraud upon the court and Talmud-oriented bias commenced by Justice Eric I. Prus and
Justice Jeffrey S. Sunshine by violating New York State Civil Practice Law and Rules Section 236 regarding the equitable distribution
of marital property such that the disabled Plaintiff was left with nothing so as to protect Plaintiff's ex-husband, and by
extension ex-husband's attorneys from the consequences of having used Plaintiff to participate in a “green-card”
marriage; that fraud upon the court has no statute of limitations; such that, if the law where administered fairly, the aforesaid
justices would be investigated, jailed, impeached and disbarred or suspended from the practice of law; and that this is not
the case because the justices are adherents of the Talmud's religious doctrine “law of the moser”, and as such,
will not report the Jewish attorneys to the non-Jewish authorities.
46) That Plaintiff asserts that Defendant, by and through its employees, failed to follow the constitution mandate for due
process by honestly investigating Plaintiff's complaints regarding the attorneys who facilitated the ex-husband's act of immigration
fraud, identity fraud and non-payment of child support; that Defendant United States, by and through its employees, failed
to follow the constitutional mandate for due process by discarding Plaintiff's complaints to investigate the aforesaid justices
for rendering decisions in favor of those attorneys who facilitated Plaintiff's ex-husband commission of immigration fraud,
identity fraud and non-payment of child support.
47) That Plaintiff asserts that because of Defendant's violation of her right to due process, Plaintiff was subjected to theft
of Plaintiff's reputation/being publicly defamed as a liar with regard to the identity of Plaintiff's ex-husband by the Daily
News, Scott Shifrel and their attorney Anne B. Carroll.
48) That Plaintiff asserts that Defendant's refusal to enforce Plaintiff's
constitutional under the law is an injury that is recognized by the U.S. Supreme Court regarding its decision in the case
Bivens v. Six Unknown Named Agents, 403 U.S. 388 (1971).
COUNT 2 –
PLAINTIFF'S SECOND CAUSE OF ACTION
VIOLATION OF PLAINTIFF'S
RIGHT NOT TO BE FORCED TO OBSERVE THE TALMUD AND
ASHKENAZI JUDAISM AS A STATE RELIGION
49) Plaintiff hereby repeats and realleges each and every allegation contained
in paragraphs 1 through 49 as if fully set forth herein.
50) That Plaintiff asserts that Defendant, by and through its employees owed Plaintiff the duty of ensuring that Plaintiff's
constitutional right to enforce Plaintiff's constitutional right to due process with regard to her attempts to file criminal
complaints with federal law enforcement agencies based on Plaintiff's allegations regarding the encroachment of the Talmud
and the illegal interference of its adherents who are in positions of great authority.
51) That Plaintiff asserts that Defendant's violation of Plaintiff's constitutional
right to due process by way of Defendant's failure to investigate Plaintiff's well-founded complaints regarding those justices
at the Kings County Supreme Court who were “randomly” assigned to adjudicate Plaintiff's lawsuit were Jews/adherents
of the Talmud were read and discarded; that based on Plaintiff understanding of the laws of probability, it is impossible
for a random drawing of a judge to a case to end up where the litigants and the judge are always the same ethnicity and the
same religion, but that when Plaintiff's cases had a Jewish litigant, or a non-Jewish litigant who was a client of Jewish
litigants who violated the law, Plaintiff's cases were always “randomly” assigned to a judge who was Jewish; and
that further to this; Plaintiff asserts that in each of her cases where the litigants did not interpose an answer or file
an appearance so that litigants should have been declared defaulted by natural operation of law New York State Civil Practice
Law and Rules Section 320, appearance of attorneys; New York State Civil Practice Law and Rules Section 3215; default judgment
and New York Code Rules and Regulations 202.27, default judgment; the Jewish judges instead rendered
decisions in favor of the no-show Jewish defendant, and Plaintiff lost all her cases.
52) That Plaintiff asserts that Defendant, by and through its employees, failed in its duty to 1) protect Plaintiff's constitutional
right to due process by refusing to investigate her well-founded complaints; 2) by refusing to bring to justice those individuals
for whom Plaintiff provided well-founded proof of their crimes of facilitation of immigration fraud, identity fraud, non-payment
of child support and fraud upon the court in violation of the following laws: Title 18 of the United States Code, Section 1341, frauds and swindles; Title 18 of the United States Code, Section 1346, definition of “scheme or artifice to defraud”; violation of Title 18 of the United State Code Section 241, conspiracy against rights; Title 18 of the United States Code, Section 242, deprivation of rights under color of law; Title 42 of the United States Code, Section 1981(a)(c) , equal rights under the law; Title 42 of the United States Code, Section 1983, civil action for deprivation of rights under color of law; Plaintiff's First Amendment right to redress grievances to the
government; Plaintiff's First Amendment right to freedom of speech; Plaintiff's First Amendment right to freedom from the
establishment of a state-sponsored religion; Plaintiff's Fifth Amendment right to due process under the law; Plaintiff Fifth
Amendment right to Plaintiff Fourteenth right to due process under the law and Plaintiff's Fourteenth right to equal protection
under the law.
53) That Plaintiff asserts
that Defendant's failed to protect Plaintiff's right to freedom from the enforcement of a state-sponsored religion; Plaintiff
asserts that she has forever lost the ability to successfully file charges against a litigant who is Jewish; and that the
aforesaid loss is evidence that Defendant, by and through is employees has allowed itself to become a Talmudic police state
(see Exhibit V, page 2).
COUNT 3 – PLAINTIFF'S
THIRD CAUSE OF ACTION
DEFENDANT VIOLATED PLAINTIFF RIGHT TO
UNDER THE LAW
54) Plaintiff hereby repeats and realleges each and every allegation contained
in paragraphs 1 through 54 as if fully set forth herein.
55) That Plaintiff asserts that Defendant, by and through its employees, had a duty to ensure that Plaintiff receives the
same “the intangible right to honest service” that is guaranteed in Title 18 of the United States Code, Section 1346; that Defendant, by and through its employees had the duty of showing compassion for Plaintiff as a past and current victim
of federal crimes that were orchestrated by Ashkenazi Jews; that Plaintiff offers as proof of her assertion Exhibit
V, page 3 in which Defendant the Honorable Barack H. Obama visits Israel and bows in respect to those Jews who
were cruelly murdered during the Holocaust; that if Defendant Barack H. Obama can gracefully bow in respect to those Holocaust
victims whose religion has no business in the affairs of secular government, then Plaintiff can logically assume that the
President of the United States, a 10-year professor and expert of U.S. Constitutional law, while never needing to bow before
the Plaintiff, owes Plaintiff a duty to treat Plaintiff, who is a crime victim, with the same compassion with which he treats
present-day Ashkenazi Jews, who are no longer victims of individuals who promulgated white superiority pursuant to the Fourteenth
Amendment's equal protection clause; that all Plaintiff requires of Defendant Obama, of Defendant United States and of all
other employees named as defendants is for them to obey the U.S. Constitution and do their jobs.
56) That Plaintiff asserts
that Defendant's failure to exercise its duty to provide Plaintiff with equal protection under that law that it afford Jews,
especially those in positions of financial and government power, has caused Plaintiff to suffer the following: 1) loss of
the Plaintiff's ability to enlist Defendant's help to enforce Plaintiff's constitutional rights; 2) a great fear of Ashkenazi
Jews; 3) lack of respect for the United States government; 4) loss of respect for Defendant Barack H. Obama insofar as Plaintiff
voted for him based on her belief that he cared for her and would keep his “word” and help her, but has never
done so (see Exhibit W); 5) loss of marital property based on Justice's D'Emic's biased decision in
favor of no-show ex-huband, leaving disabled Plaintiff with nothing; 6) the fictitious name “Godwin Uzamere” is
still on the birth certificate of the child of the marriage, such that the loss of the right of African slaves and their progeny
to bear the true and full African name of their husbands and fathers, something that Plaintiff naively believed that Kenyan-descendant
Defendant Barack H. Obama would understand; 7) loss of reputation based on Daily News and Scott Shifrel's libel of Plaintiff
as “anti-Semitic” and “wacko”; that Plaintiff could go on and on, however, Plaintiff strongly asserts
that she has proven her point well.
57) That Plaintiff asserts that Defendant's failure to exercise its duty to provide Plaintiff with equal protection under
the law, as well as those constitutional rights previously enumerated by Plaintiff, is the loss of the aforesaid rights themselves,
such that the losses are damages recognized in law; that in U.S. Supreme Court case Bivens v. Six Unknown Named Agents, 403 U.S. 388 (1971), the Honorable William J. Brennan said that “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..."; that the U.S. Supreme Court laid
down a rule that it will imply a private right of action for monetary damages where no other federal remedy is provided for
the vindication of a Constitutional right, based on the principle that for every wrong, there is a remedy.
COUNT 4 – PLAINTIFF'S FOURTH CAUSE OF ACTION
VIOLATED PLAINTIFF'S RIGHT TO FREE SPEECH
58) Plaintiff hereby repeats and realleges each and every allegation contained
in paragraphs 1 through 58 as if fully set forth herein.
59) That Plaintiff asserts that Defendant, by and through its employees, had a duty enforce Plaintiff constitutional right
to free speech; that Defendant had a duty to ensure that those employees who are adherents of the Talmud's “law of the
moser” did not overstep their constitutional duties by censuring Plaintiff's by discarding them and causing Plaintiff
to be ignored;
60) That Plaintiff asserts
that Defendant, by and through its employees, failed in its duty to enforce Plaintiff's right to free speech, and to establish
sufficient to this Court of Plaintiff's assertion, Plaintiff notes that following: 1) that Senator Ehigie Edobor Uzamere,
who Plaintiff has sufficiently proven committed immigration fraud, identity fraud and non-payment of child support, was never
arrested for his crime, and that instead, both the federal district court and the New York State court determined that Plaintiff
can no longer file complaints against Allen E. Kaye fraudulently based on the principles of “res judicata” and
colleteral estoppel; 2) that Allen E. Kaye, who Plaintiff has sufficiently proven facilitated the immigration fraud and identity
fraud of his client, ex-husband Senator Ehigie Uzamere, was never arrested for his crime, and that instead, both the federal
district court and the New York State court determined that Plaintiff can no longer file complaints against Allen E. Kaye
fraudulently based on the principles of “res judicata” and collateral estoppel; and that for every individual Plaintiff names as having committed crimes against the Plaintiff falls under the same harsh
judgment, although Plaintiff has sufficiently proven that the aforesaid individuals violated Plaintiff constitutional rights.
61) That Plaintiff asserts that the primary damages
that were caused by Defendant are the loss of Plaintiff's ability to enlist Defendant's assistance in enforcing her constitutional
rights when the subject of Plaintiff's complaint is Jewish/adherent of the Talmud; that based on the U.S. Supreme Court case
Bivens v. Six Unknown Named Agents, 403 U.S. 388 (1971), loss or violation of constitutional rights is an injury recognized in law; that those damages Plaintiff alleges are recognized
in U.S. Law can be found in paragraphs 48 and 54.
DEMAND FOR AN ACCOUNTING
62) That Plaintiff demands an accounting from Defendant's
employees in person to ascertain their personal reasons why the United States government never investigated the crimes of
immigration and identity fraud attorneys Allen E. Kaye, Harvey Shapiro, Bernard Rostanski, Jack Gladstein, Eugene O. Uzamere,
Justice Eric I. Prus, Justice Jeffrey S. Sunshine; and further to this, why the United State of America refused to investigate
Plaintiff's well-documented claims regarding the aforesaid attorneys acts of fraud, and to make a full disclosure of same.
63) That Plaintiff strongly asserts that if Ashkenazi
Jewish attorney Philip Berg can file lawsuits with various federal courts to question the citizenship of Defendant Barack
H. Obama, whose mother is a white American citizen and who the U.S. Government recognizes as an American citizen, then Plaintiff
feels emboldened to file this lawsuit with the hope that there exists a judge at the U.S. Court of Federal Claims who is not
an adherent of the Talmud and will not allow himself or herself to be illegally influenced and become a slave to one; and
who will adjudicate Plaintiff's lawsuit with justice and mercy and require an accounting of the Defendant.
PRAYER FOR RELIEF
64) Plaintiff Cheryl D. Uzamere respectfully requests that this Court compels the Defendants to provide Plaintiff with the
aforesaid equitable relief:
a) That Plaintiff respectfully prays that this honorable Court requires that any justice, judge or magistrate judge who by
religion or culture subscribes to the Talmud disqualifies him/herself; that pursuant to Liteky v. United States, 114 S.Ct. 1147, 1162 (1994) , the U.S. Supreme Court held that “disqualification is required if an objective observer would entertain reasonable
questions about the judge's impartiality. If a judge's attitude or state of mind leads a detached observer to conclude that
a fair and impartial hearing is unlikely, the judge must be disqualified;” that pursuant to 28 USC §455 any member
of this honorable Court's judiciary who is an interested party in the aforementioned subject manner recuse him/herself from
adjudicating this claim to ensure that Plaintiff's First Amendment right to be free from the establishment of a state religion,
Plaintiff's Fifth Amendment right to due process of law, Plaintiff's right to free speech and Plaintiff's Fourteenth Amendment
right to equal protection under the law are no longer compromised or violated by members of the Ashkenazim in their fervor
to implement the Talmudic doctrine “law of the moser” to protect fellow Ashkenazi Jews who committed crimes against
b) That Plaintiff asserts that in the U.S. Supreme Court case Haines v. Kerner, 404 U.S. 519 (1972) , the court decided that “however inartfully pleaded, are sufficient to call for the opportunity to offer supporting
evidence...Accordingly, although we intimate no view whatever on the merits of petitioner's allegations, we conclude that
he is entitled to an opportunity to offer proof”; and that based on the foregoing case law, this Court must allow
Plaintiff, whose exhibits have proven that she is a federal crime victim, to present evidence of her
c) That Plaintiff accepts that Defendants Honorable Barack H. Obama, Honorable Eric H. Holder, Jr. and Honorable Janet Reno
must delegate duties that are specific to particular departments, divisions, section and units such that she is willing to
remove them (only) from being Defendants in her lawsuit; however, in order for Plaintiff not to have to add willful blindness or negligence to her claim against Defendant, Plaintiff demands she meet with the aforesaid
Defendants personally to acknowledge that Plaintiff and her daughter are still federal crime victims, to explain why the United
States government never helped Plaintiff and her children, and to personally ensure that Allen E. Kaye, Esq., Harvey Shapiro,
Esq., Bernard J. Rostanski, Esq., Jack Gladstein, Esq., Eugene O. Uzamere, the Honorable Eric I. Prus, the Honorable Jeffrey
S. Sunshine, the Honorable Matthew D'Emic and the Honorable Arthur M. Schack held criminally and/or civilly liable for their
facilitation of immigration fraud, identity fraud, non-payment of child support, fraud upon and court and religiously-oriented
racism against Plaintiff and her daughter; that if Plaintiff's allegations are correct (and Plaintiff has proven that they
are) that they will lead to the arrest of the aforesaid individuals; and to ensure that if the Honorable Anthony Parga in
Plaintiff's lawsuit Index Number 10-009998 makes a decision contrary to law, contrary to the facts and in favor of the never-interposed-an-answer-already-defaulted
Jewish defendants, that based on Plaintiff's complaint against him, that he is investigated, arrested, tried and convicted
for commission of fraud upon the court and criminal violation of Plaintiff's constitutional rights.
d) That if the aforesaid individuals refuse to meet with Plaintiff, then Plaintiff demands $10,000,000.00 will continue to
include the aforementioned Defendants for Defendant's violation of Plaintiff's constitutional rights.
WHEREFORE, Plaintiff Cheryl D. Uzamere respectfully requests
that this Court renders judgment against Defendant in the sum of $10,000,000.00 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.
August 28, 2010
Appearing Pro Se
Tel.: (718) 647-1708
2) In re Aimster Copyright Litigation, 334 F.3d 643 (7th Cir. 2003)
the Federal Tort Claims Act, 28 USC §2401(d); 28 USC §2675; 28 USC §2675(a); 28 USC §2675(a)