NEW YORK STATE SUPREME COURT COUNTY
OF KINGS
Cheryl D. Uzamere
Index No.: 10-009998
Plaintiff,
VERIFIED COMPLAINT
- against -
JURY TRIAL DEMANDED Daily News,
L.P. and Scott Shifrel
Defendants. 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 Defendant the Daily News and its agent/staff
writer Scott Shifrel committed defamation per se, defamation and fraud against Plaintiff, and violated Plaintiff's constitutional
rights, to wit:
3) That on November 5, 2009, Defendants published a newspaper article entitled “Hate-Spewing
Wacko Goes Into Fit In Court.”
4) That in the aforesaid article, Defendants defamed Plaintiff as “wacko.” 5)
That in the aforesaid article, Defendants publicly defamed Plaintiff as “anti-Semitic.” 6) That in the aforesaid
article, Defendants never produced any proof of Plaintiff's “anti-Semitism.” 7) That in the aforesaid
article, Defendants did not state the names of the individual Defendants' article identified as a “courthouse source”,
nor did the aforesaid article state the names of any other individual able to corroborate Defendants'
charge that Plaintiff is anti-Semitic.
8) That Defendants defamed Plaintiff as a liar by publishing as true and correct a fraudulent counter-affidavit
from Nigeria that Plaintiff's ex-husband criminally submitted during Plaintiff's divorce action to hide his identity during
Plaintiff's divorce action.
9) That Defendants published the following statements with regard to the aforesaid fraudulent counter-affidavit:
“The senator, however, is a cousin of her actual ex-husband Godwin Uzamere, according to an affidavit file he filed
in Supreme Court...Her obsession with his destruction has taken her mental ailment to a new level which should be encouraged. 10)
That on May 12, 2009, the Honorable Jeffrey S. Sunshine adjudicated that Senator Ehigie Edobor Uzamere is Plaintiff's husband,
thereby rejecting Senator Uzamere's, and now Defendants' attempt to hide Plaintiff's ex-husband's identity; and to hide the
acts of immigration fraud and identity fraud that were facilitated by Senator Uzamere's attorneys Allen E. Kaye, Harvey Shapiro,
Bernard Rostanski and Jack Gladstein.
11) That based on Defendants' own admission, Defendants obtained the aforesaid fraudulent counter-affidavit
from a “courthouse source”; and that the aforesaid admission is proof that Defendants conspired to commit fraud,
conspired to aid and abet fraud and conspired to violate Plaintiff's constitutional rights.. AND AS FOR A FIRST CAUSE OF ACTION 12) Plaintiff hereby
repeats and realleges each and every allegation contained in paragraphs 1 through 11 as if fully set forth herein.
13) That Defendants, as professionals who provide the public with news, owed Plaintiff the duty of
checking their news sources to ensure that the information they published about Plaintiff would not expose Plaintiff to defamation
(see Exhibit A1 to A6).
14) That Defendants owed the Plaintiff the duty of ensuring that they avoid the commission of fraud
when obtaining documents and other sources of news; that Defendants owed Plaintiff the duty of not publishing criminally fraudulent
documents about Plaintiff.
15) That Defendants owed Plaintiff the duty not to conspire with other individuals to publish criminally
fraudulent news about Plaintiff.
16) That Defendants, as professionals who provide the public with news, owed Plaintiff the duty of
not conspiring with any member of the court to obtain falsified information. 17) That Defendants, as professionals who provide
the public with news, owed Plaintiff the duty of not violating Plaintiff's constitutional right to due process of law by engaging
in “trial by media” to facilitate public and judiciary bias against Plaintiff in a manner that violates Plaintiff's
constitutional right to an impartial trial (see Exhibit B1 and B2). 18) That Defendants
owed Plaintiff the duty of not defaming Plaintiff an “anti-Semitic.” 19) That Defendants owed Plaintiff the duty not
to violate Plaintiff's right to freedom of religion; That Defendants owed Plaintiff the duty not to publicly accusing Plaintiff
of the halachic crime of anti-Semitism.
20) That Defendants owed Plaintiff the duty not to defame Plaintiff as having committed the halachic
crime of anti-Semitic as a ruse to hide the acts of fraud that Plaintiff charged in her lawsuit against attorneys Allen E.
Kaye, Harvey Shapiro, Bernard Rostanski and Jack Gladstein, all of whom practice the Jewish faith (see Exhibits
C1 through C3).
21) That Defendants owed Plaintiff the duty of not defaming Plaintiff as a “wacko” by
publishing false information regarding Plaintiff's mental illness to hide Plaintiff's lawsuit against the aforementioned attorneys,
and to give the public the false impression that Plaintiff is either a liar or out of touch with reality (see Exhibit
D).
22) That Defendants owed Plaintiff the duty to not use their positions to intentionally inflicting
mental and emotional distress on the Plaintiff.
23) That Defendants owed Plaintiff the duty not to hold Plaintiff responsible for commiting the halachic/Jewish
religious crime of meshira (whistleblowing) by using defamation of character to punish Plaintiff for publicly reporting the
commission of acts of fraud by attorneys Allen E. Kaye, Harvey Shapiro, Bernard Rostanski and Jack Gladstein, all of whom
practice the Jewish faith.
24) That wholly and solely as a result of Defendants' tortious acts, Plaintiff suffered personal injuries
by way of public scorn and severe mental and emotional distress for which Plaintiff was damaged in the amount of $10,000,000.00. AS AND FOR A SECOND SEPARATE AND DISTINCT CAUSE OF ACTION 25)
Plaintiff hereby repeats and realleges each and every allegation contained in paragraphs 1 through 24 as if fully set forth
herein.
26) That Defendants failed in their duty to Plaintiff to check their news source to ensure that the
information they published would not expose Plaintiff to defamation. 27) That Defendants failed in their duty to Plaintiff
to avoid the commission of fraud; that Defendants failed in their duty to Plaintiff not to publish criminally fraudulent information
designed to defame Plaintiff.
28) That Defendants failed
in their duty to Plaintiff not to conspire with employees of the New York State Supreme Court Kings County to obtain criminally
fraudulent information to defame Plaintiff.
29) That Defendants failed in their duty not to violate Plaintiff's constitutional rights to due process
of law by engaging in “trial by media” to facilitate public and judiciary bias against Plaintiff and to violate
Plaintiff's constitutional right to an impartial trial by defaming Plaintiff. 30) That Defendants failed in their duty not to
defame Plaintiff as an “anti-Semitic.”
31) That Defendants failed in their duty to Plaintiff not to violate Plaintiff's right to freedom
not to practice another person's religion; that Defendants failed in their duty not to force Plaintiff to practice halachic
law by publicly charging Plaintiff with commission of the halachic crimes of anti-Semitism and meshira/whistleblowing. 32)
That Defendants failed in their duty to Plaintiff not to defame Plaintiff as an “anti-Semitic”; that Defendants
failed by using defamation of Plaintiff's character as a ruse to prevent Plaintiff from going public with information regarding
the acts of fraud that were committed by Allen E. Kaye, Harvey Shapiro, Bernard Rostanski and Jack Gladstein, all of whom
practice the Jewish faith.
33) That Defendants failed in their duty to Plaintiff not to defame Plaintiff as “wacko”;
that is, publishing fraudulent information regarding Plaintiff's status of having a mental illness to prevent Plaintiff from
exposing the crimes committed by attorneys Allen E. Kaye, Harvey Shapiro, Bernard Rostanski and Jack Gladstein. 34)
That Defendants failed in their duty to Plaintiff not to avoid intentionally inflicting mental and emotional distress on the
Plaintiff.
35) That wholly and solely as a result of Defendants' tortious and criminal acts, Plaintiff suffered
personal injuries by way of public scorn, and severe mental and emotional distress for which Plaintiff was damaged in the
amount of $10,000,000.00. AS AND FOR A THIRD
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 Plaintiff suffered public scorn because of Defendants' publication of the same fraudulent
counter-affidavit that was illegally used by Plaintiff's ex-husband Senator Ehigie Uzamere and the ex-husband's attorney,
Eugene O. Uzamere during Plaintiff's divorce action in order to facilitate “trial by media to make it impossible for
Plaintiff to obtain justice in court, in order to hide the identity of Plaintiff's ex-husband and in order to hide the crimes
of the ex-husband's attorneys.”
38) That Plaintiff suffered public scorn to the point where Plaintiff is unable to be found eligible by
FEGS and other continuing day treatment programs based on the Defendants defaming of Plaintiff as “anti-Semitic.” 39)
That Plaintiff suffered public scorn to the point of having to be hospitalized after Defendants' acts of defamation that Plaintiff
accurately detailed at her website http://www.thecrimesofsenatoruzamere.net, against which Plaintiff states that Defendants
have no legal defense.
40) That wholly and solely as a result of Defendants' tortious acts, Plaintiff suffered personal injuries
by way of public scorn and severe mental and emotional distress for which Plaintiff was damaged in the amount of $10,000,000.00. AS AND FOR A FOURTH 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 given that there is a pending case against Defendant New York Daily News for defamation in the
recent past by the Honorable Lawrence D. Martin, a Brooklyn Supreme Court justice named in the case Martin v. Daily News,
Defendants knew or should have known that the article they published regarding the Plaintiff would subject Plaintiff to public
scorn based on Defendants' “trial by media”, and that public scorn is an injury that is recognized in law. 43)
That Defendants knew or should have known that their conspiring with a “courthouse source” obtaining and publicizing
violates the Plaintiff's constitutional to due process; that violation of due process is itself an injury recognized by law
as giving rise to an implied cause of action.
44) That loss of reputation based on the stigma of being publicly labeled an anti-Semitic is an injury
recognized in law.
45) That Defendants knew or should have know that Plaintiff would suffer loss of reputation based
on Defendants' vilification of Plaintiff as a “wacko.” 46) That the mental and emotional stress resulting
from Defendants tortious acts are recognized in the law.
47) That Plaintiff's continued inability to obtain a fair trial at the New York State Supreme Court
Kings County as a result of Defendants' implementation of “trial by media” in an injury recognized in law. 48)
That Defendants knew or should have known that Defendants' illegal conduct as described inflicted great mental and emotional
distress on the Plaintiff.
49) That wholly and solely as a result of Defendants' tortious acts, Plaintiff suffered personal injuries
by way of inability to obtain a fair trial, loss of reputation, violation of Plaintiff' constitutional rights and severe mental
and emotional distress for which Plaintiff was damaged in the amount of $10,000,000.00. 50) That Plaintiff
respectfully alleges that if Plaintiff files the lawsuit against the State of New York that Plaintiff uploaded to here website,
namely, http://www.thecrimesofsenatoruzamere.net/lawsuitagainstnys.html, no employee of the New York State Supreme Court Kings County will admit to having conspired to committing such an
illegal act; thereby placing Defendants in the position of having defamed other employees of the Kings County Supreme Court
beside the Honorable Larry D. Martin; that Kings County Supreme Court employees' denial, or refusal to respond to Defendants'
allegations regarding the aforesaid employees involvement would make them liars in the presence of this honorable Court; that
this Court must then adjudge Defendants' statements to be untrue and to view Defendants as liars. 51) That given the
seriousness of Defendants' statement regarding the “courthouse source” from whom they obtained falsified information,
Plaintiff respectfully prays this Court to allow Plaintiff to file her action at this Court. 52) That if so pleases
this Court, that Plaintiff's legal action be adjudicated by at this courthouse based on Defendants' admitting to publishing
a fraudulent document that they obtained from a “courthouse source.” WHEREFORE, Plaintiff Cheryl D. Uzamere respectfully prays
this Court for a jury trial, for this honorable Court to require Defendants to make a full public retraction of their defamatory,
criminal and cruel statements, and to render judgment against the Defendants in the sum of $10,000.000.00. Dated: Brooklyn, New
York May 20, 2010 _____________________________ 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. 
_____________________________ 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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