|
African-American, mentally ill, but competent litigant Cheryl D. Uzamere
researched and specified federal courts in her verified complaints against governmental defendants,
but Jew-biased, anti-schartze judge Nicholas G. Garafis tossed out
African-American litigant's
verified complaints and offered no notice of deficiency to give African- American litigant a chance to correct defects
UNITED
STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK
_________________________________ Cheryl D. Uzamere
Civil Action No.: 11-CV-2831
Plaintiff, VERIFIED COMPLAINT - against -
JURY TRIAL DEMANDED * Andrew M. Cuomo, in his official
capacity as Governor of the State of New York; Nirav R. Shah, in his official capacity as Commissioner of the New York State
Department Of Health; Michael F. Hogan, in his official capacity as Commissioner of the New York State Office of Mental Health;
Ann Pfau, in her official capacity as Chief Administrative Judge for the New York State Trial Courts; Roy L. Reardon, in his
official capacity as Chair of the New York State Departmental Disciplinary Committee, New York State Supreme Court for the
First Judicial Department; State of New York; the New York State Department of Health; the New York State Office of Mental
Health; the New York State Unified Court System; the Daily News, LP; Uzamere & Associates, PLLC; Allen E. Kaye, PC; the
Law Offices Of Harvey Shapiro; Gladstein and Messinger; Federation Employment And Guidance Service, Interfaith Hospital And
Medical Center; New York Psychotherapy And Roman Catholic Diocese Of Brooklyn
Defendants.
___________________________________________
* *****Plaintiff
Cheryl D. Uzamere, a citizen of the United States and a constituent of federally- and state-funded mental health services,
appearing on her own behalf, sues the defendants and alleges: PRELIMINARY
STATEMENT Defendants Violated Federal Laws With Regard to Plaintiff's
Disability *****1)*****Title
II of the Americans With Disabilities Act, 42 U.S.C. §§12131, 12132, prohibits discrimination against individuals
with disabilities, including those with mental illness. Similarly, Section 504 of the Rehabilitation Act, 29 U.S.C. §794,
provides that no person with a disability, including those with mental illness, shall: “solely by reason of his or her
disability, be excluded from participation in, be denied benefits of, or be subjected to discrimination under any program
or activity receiving Federal financial assistance.” *****2)*****In the decision regarding Disability Advocates, Inc. vs. Paterson, et al, the Honorable
Nicholas G. Garaufis stated that “The Supreme Court held in Olmstead v. L.C., 527 U.S. 581 (1999), that “[u]njustified
isolation . . . is properly regarded as discrimination based on disability,” observing that “institutional placement
of persons who can handle and benefit from community settings perpetuates unwarranted assumptions that persons so isolated
are incapable of or unworthy of participating in community life.” 527 U.S. at 597, 600. The “integration mandate”
of Title II of the American with Disabilities Act, 42 U.S.C. § 12101 et seq., and Section 504 of the Rehabilitation Act,
29 U.S.C. §791 et seq., as expressed in federal regulations and Olmstead, requires that when a state provides services
to individuals with disabilities, it must do so “in the most integrated setting appropriate to their needs.” The
“most integrated setting,” according to the federal regulations, is “a setting that enables individuals
with disabilities to interact with non-disabled persons to the fullest extent possible.” 28 C.F.R. §35.130(d);
28 C.F.R. pt. 35 app. A. *****3)*****Further,
Title II of the Americans With Disabilities Act requires that “a public entity shall administer services, programs,
and activities in the most integrated setting appropriate to the needs of qualified individuals with disabilities.”
See 28 C.F.R. §35.130(d) (emphasis added). *****4)*****In the landmark decision Olmstead v. L.C., 527 U.S. 581 (1999), the U.S. Supreme Court
held that these provisions of law are violated when a state places people with mental illness in “unjustified isolation,”
and that a person with mental illness may sue the state for failing to place him or her “in the most integrated setting
appropriate to [his or her] needs.” *****5)*****Judge Garaufis further stated in the aforementioned decision that Title II of the ADA applies
to “any State or local government” and “any department, agency, special purpose district, or other instrumentality
of a State or States or local government.” 42 U.S.C. §12131(1). Accordingly, all governmental Defendants in this
action are subject to Title II of the Americans With Disabilities Act.” *****6)*****This action is brought in furtherance of those mandates. Rather
than comply with these laws, New York State officials and agencies responsible for the care and treatment of people with mental
illness (and hospitals they license and supervise) engaged in conduct that effectively blacklisted the Plaintiff from accessing
outpatient psychiatric care from specific not-for-profit outpatient psychiatric care providers, from accessing unbiased judicial
services from New York State trial courts, and from obtaining accommodations and assistance from all government defendants. Defendants Violated Federal Laws With Regard to Blacklisting *****7)*****Federal courts recognize blacklisting as a
cause of action. In the lawsuit Castillo v. Spiliada Maritime Corporation MV, 937 F. 2d 240, the United State Court
of Appeals for the Fifth Circuit stated that “. . .Plaintiffs have offered substantial evidence that they were coerced
into agreeing to the settlements with threats that charges would be filed against them with the POEA and that they would be
blacklisted. As the threats of blacklisting endangered the possibility of future employment in their established trade, Plaintiffs
reasonably could have been intimidated into settling.” In the lawsuit Duckworth v. Pratt & Whitney, Inc.,
152 F.3d 1 (1st Cir. 1998), the United States Court of Appeals for the First Circuit stated that “As both Duckworth
and the Secretary of Labor persuasively argue, the achievement of these objectives would be frustrated by adopting Pratt &
Whitney's interpretation. That interpretation would permit an employer to evade the Act by blacklisting employees who have
used leave in the past or by refusing to hire prospective employees if the employer suspects they might take advantage of
the Act.” The United States Court of Appeal's use of the term “leave” refers to medical leave. The United
States Court of Appeals use of the term “Act” refers to the Family and Medical Act of 1993. In the case Davis
v. Paul, et al, 505 F.2d 1180 the United States Court of Appeals for the Sixth circuit stated that “Few things
are as fundamental to our legal system as the presumption of innocence until overcome by proof of guilt beyond a reasonable
doubt at a fair trial. The dissemination of the flyer in the case at bar is in the face of the presumption of innocence, disregards
the Due Process Clause and is based on evidence that is not probative of guilt. Condemning a man to a suspect class without
a trial and on a wholly impermissible standard, as in the case at bar, offends the very essence of the Due Process Clause,
i.e., protection of the individual against arbitrary action. Slochower v. Board of Education, 350 U.S. 551, 559,
76 S.Ct. 637, 100 L.Ed. 692 (1956); Peters v. Hobby, 349 U.S. 331, 351-352, 75 S.Ct. 790 (1955) (Douglas, J., concurring.)
As said by Mr. Justice Black in his concurring opinion in Joint Anti-Fascist Refugee Committee v. McGrath, 341 U.S.
123, 144-145, 71 S.Ct. 624, 634 (1951): 'Our basic law, however, wisely withheld authority for resort to executive. . .condemnations
and blacklists as a substitute for imposition of legal types of penalties by courts following trial and conviction in accordance
with procedural safeguards of the Bill of Rights.'” *****8)*****The United States Equal Employment Opportunity Commission's, (EEOC) Office of Legal Counsel the
Americans with Disabilities Act of 1990 and the Family and Medical Leave Act of 1993 overlap, and that where employees are
concerned, “ADA Title II covers all public employers without regard to the number of employees.” *****9)*****By this action, Plaintiff
seeks an end to New York State's practice of blacklisting the Plaintiff by refusing to provide her with outpatient psychiatric
care, accommodations required to be provided by the New York State Unified Court System as its courts are covered under Title
II of the Americans With Disabilities, and by ending the corporate defendants' use of the media to encourage members of the
not-for-profit psychiatric outpatient community to blacklist the Plaintiff by publicly denigrating her because of symptoms
of her mental illness that were publicized by government and corporate defendants. Parties *****10)*****The
Plaintiff is a recipient of federally- and state-funded psychiatric services, and is a plaintiff in various legal actions
in trial courts over which Defendant the Honorable Ann Pfau has oversight. The Plaintiff also has docket number 2010-07636
with the Appellate Division, 2nd Judicial Department; an appeal to file regarding an unfavorable decision rendered by the
New York Court of Claims; Notice of Appeal already filed with the Appellate Division, First Judicial Department file regarding
an unfavorable decision rendered with regard to Defendant Federation Employment and Guidance Service, Inc., and an appeal
to file in what Plaintiff predicts to be an unfavorable decision with regard to Defendant Daily News, LP. Once Justice Wooten
renders his decision in favor of Defendant Daily News, LP, Plaintiff will file her already-prepared Notice of Appeal, Notice
of Motion to proceed as a poor person and to prosecute her action on the lower court's original records, nine copies of her
Appellate Brief at the same time, if possible. Role of Defendants Andrew
M. Cuomo and the New York State Government *****11)*****Defendant Andrew M. Cuomo is the Governor of the State of New York, a public entity covered by
Title II of the Americans With Disabilities Act. 42. U.S.C. §12131(1). He is ultimately responsible for ensuring that
New York State operates its service systems in conformity with the Americans With Disabilities Act and the Rehabilitation
Act. He is sued in his official capacity. Role of Defendants Nirav R. Shah
and the NYS Department of Health *****12)*****Defendant New York State Department of Hea1th ("DOH") is the agency created by the State
of New York that licenses, supervises and enforces the laws and regulations applicable to adult homes, and is responsible
for protecting Plaintiff's rights. DOH is a public entity covered by Title II of the Americans With Disabilities Act. 42 U.S.C.
12131(1). *****13)*****Defendant
Nirav R. Shah is the Commissioner of DOH. He is responsible for the operation and administration of DOH. He is sued in his
official capacity. Role of Defendants Michael F. Hogan and the NYS Office
of Mental Health *****14)*****Defendant
New York State Office of Mental Health (“OMH”) is the agency responsibility for providing outpatient psychiatric
services to the Plaintiff, who has a serious and persistent mental illness. OMH is a public entity covered by Title II of
the Americans With Disabilities Act. 42 U.S.C. §12131(1). *****15)*****OMH shares the responsibility for protecting the rights of mentally ill constituents with DOH. *****16)*****OMH also operates state
psychiatric facilities and is responsible for discharge planning, placement and follow-up for individuals residing in such
facilities. Additionally OMH funds privately-operated psychiatric hospitals for clients of the public mental health system
and is responsible for developing standards for discharges from these hospitals. *****17)*****OMH is charged by statute with “the responsibility
for seeing the mentally ill persons are provided with care and treatment, that such care, treatment and rehabilitation is
of high quality and effectiveness, and that the personal and civil rights of persons receiving care, treatment and rehabilitation
are adequately protected.” Mental Hyg. Law §7.07(c). *****18)*****Defendant Michael F. Hogan is the Commissioner of OMH. He is responsible for the operation and
administration of OMH, including its activities regarding state psychiatric facilities and the overall planning, programs
and services for the mental health system in New York State. He is sued in his official capacity. *****19)*****DOH and OMH are recipients of federal funds. *****20)*****DOH and OMH are programs
of state government. Role of Defendants Ann Pfau and the NYS Unified Court
System *****21)*****Defendant
New York State Unified Court System (“NYSUCS”), Defendant New York State's judicial branch of government is responsible
for hearing cases of its litigants and for rendering unbiased decisions based on New York State State Constitution, and other
laws of New York State. NYSUCS's Office of Court Administration (“OCA”) is the administrative arm of the New York
State Unified Court System, under the direction of the Chief Administrative Judge. OCA's Division of Administrative Services
provides a wide range of support services to OCA units and to the trial courts, including oversight of Title II of the Americans
with Disabilities Act. All courts in New York State are covered under Title II of the Americans With Disabilities Act. *****22)*****OCA's Division of Court
Operations is responsible for addressing inquiries regarding concerns under the Americans with Disabilities Act. It assists
the courts in assuring access to services and reasonable accommodations for court users and employees who qualify under the
ADA. Each courthouse has an ADA liaison responsible for implementing the Americans with Disabilities Act. *****23)*****Defendant Ann Pfau is the Chief Administrative
Judge of the trial courts of New York State. On behalf of the Chief Judge, the Chief Administrative Judge supervises the administration
and operation of the State's trial courts. In that capacity, she oversees the administration and operation of the Statewide
court system with a $2 billion budget, 3,600 State and locally paid judges and over 15,000 nonjudicial employees in over 300
locations around the State. Defendant Pfau is sued in her official capacity. Role
of Defendant Roy L. Reardon and the NYS Departmental Disciplinary Committee *****24)*****Defendant New York State Departmental Disciplinary Committee
(“the Committee”) for the First Judicial Department is responsible for protecting the public and the legal profession
by ensuring that lawyers adhere to the ethical standards set forth in the Rules of Professional Conduct. The Committee protects
the public by reviewing and investigating complaints against lawyers and by recommending sanctions against those who are proven
to have violated the Rules. It protects the legal profession by enforcing high standards of conduct, while at the same time
ensuring that complaints are dealt with fairly. *****25)*****The Committee has the authority to take the following actions, depending upon the seriousness
of the lawyer's conduct and the circumstances surrounding it: Refer
the complaint to a special Mediation Program, in which a trained volunteer mediator meets with the lawyer and the client to
assist them in resolving the complaint privately; Issue a private
sanction to the lawyer (a “Letter or Admonition”); Recommend
to the Court that the lawyer receive a public condemnation (“censure”); Recommend to the Court that the lawyer's right to practice law be taken away for a specified period of time (“suspension”);
or Recommend to the Court that the lawyer's license to practice law
be taken away (“disbarment”).
*****26)*****Defendant Roy L. Reardon is responsible for overseeing the activities of the Commission. Defendant
Reardon is sued in his official capacity. Role of Defendant Daily News,
LP *****27)*****Defendant
Daily News is a new-gathering and new-disseminating corporation. It is the fifth most-widely circulated daily newspaper in
the United States with a daily circulation of 632,595, as of June 13, 2009. The Plaintiff asserts that, although Defendant
Daily News is a private entity, it can be sued in federal court based on the lawsuit Gugliara vs. Daily News, et al, case
number 1:2008-CV-00912, filed on February 28, 2008 with the Federal District Court, Eastern District of New York in front
of Judge Nicholas G. Garaufis and magistrate Judge Lois Bloom, based on 28 U.S.C. §1331, federal question, jury trial
demanded. *****28)*****Defendant
Uzamere and Associates, PLLC is a law firm that provides, among other services, legal representation to individuals seeking
uncontested divorces and legal representation to individuals regarding immigration matters. Role of Defendant Uzamere and Associates, PLLC *****29)*****Defendant Uzamere and Associate, PLLC is a law firm that, among other services, provide legal
advice and representation with regard to matrimonial and immigration issues. Role
of Defendant Allen E. Kaye, PC *****30)*****Defendant Allen E. Kaye, PC is a law firm that exclusively provides legal advice and representation
to individuals regarding immigration issues. Role of Defendant Law Office
of Harvey Shapiro *****31)*****Defendant
The Law Offices of Harvey Shapiro is a law firm that exclusively provides legal advice and representation regarding immigration
issues. Role of Defendant Gladstein and Messinger *****32)*****Defendant Gladstein
and Messinger is a law firm that provides legal representation to individuals seeking divorces and legal advice and representation
regarding immigration issues. Role of Defendant Federation Employment and
Guidance Service, Inc. *****33)*****Defendant
Federation Employment and Guidance Service (FEGS) is a not-for-profit human services agency whose mission is to “meet
the needs of the Jewish and broader community through a diverse network of high quality, cost-efficient health and human services
that help each person achieve greater independence at work, at home, at school and in the community, and meet the ever-changing
needs of business and our society.” In its annual filing for charitable organizations to the IRS for 2008 FEGS reported
receiving $4,261,036 from the New York City Department of Health and Mental Hygiene; $1,331,099 from the New York State Department
of Mental Hygiene; $17,236,242 from the New York State Office of Mental Health; $336,470 from the New York State Department
of Health and $9,373,792 from the New York State Industries for the Disabled (See Exhibit 1). Role of Defendant Interfaith Hospital and Medical Center *****34)*****Defendant Interfaith Hospital and Medical
Center (“Interfaith”) is a multi-site community teaching health care system which provides a wide range of medical,
surgical, gynecological, dental, psychiatric, and pediatric and other services throughout Central Brooklyn, New York. The
institution operates a newly-modernized hospital with 287 beds and ambulatory care network of 16 clinics stretching across
the Central Brooklyn communities of Crown Heights and Bedford-Stuyvesant. Each year Interfaith Medical Center serves over
250,000 patients, representing every racial, ethnic and national origin group in Central Brooklyn with the majority of people
being Caribbean-Americans and African-Americans. *****35)*****Defendant Interfaith provides mental health and substance abuse services that include both inpatient
and ambulatory services with varying levels of intensity to meet the needs of the consumers in our community. The treatment
programs are designed to meet the needs of dual diagnosis consumers who may have both mental illness and substance abuse issues
or who may be both mentally ill and mentally retarded. Interfaith Medical Center provides a comprehensive array of outpatient,
inpatient and emergency behavioral health, psychiatric, detoxification and drug rehabilitation programs, including outpatient
mental health services to thousands of children, adults, geriatric mentally-ill and mentally-retarded patients. This program
has certification from the OMH and the Office of Mental Retardation and Developmental Disability (OMRDD). In its annual filing
for charitable organizations to the IRS for 2009, Defendant Interfaith reported receiving $528,175 from the U.S. Department
of Health and Human Services and $1,291,652 from the New York State Office of Mental Health (See Exhibit 2). Role of Defendant New York Psychotherapy and Counseling *****36)*****Defendant New
York Psychotherapy and Counseling Center (“NYPCC”) is responsible for examining, diagnosing and treating individuals
with mental and emotional challenges, as well as those suffering behavioral or emotional disorders; for assisting the culturally
diverse communities in which Defendant operates by assisting individuals with mental and emotional challenges and their families
to meet with their own needs, and thus improve the quality of their life; for providing quality mental health services, and
using the most up-to-date evidence-based practices to help our clients become active and productive members of their communities;
to establish and maintain appropriate professional levels of conduct among the staff; and to monitor and make use of new developments
in the examination, diagnosis and treatment of the mentally ill. In its annual filing for charitable organizations to the
IRS for 2006, 2007 and 2008, Defendant NYPCC reported receiving no income from any state or federal agency; however, at its
website http://www.nypcc.org/links.php, Defendant NYCPP states that it works with the National Institute of Mental Health and the New York State
Office of Mental Health (See Exhibit 3). Role of
Defendant Catholic Diocese/Catholic Charities of Brooklyn and Queens *****37)*****Defendant Catholic Diocese's Catholic Charities of Brooklyn
and Queens (“CCBQ”) provides behavioral health services addresses issues such as depression, substance abuse,
marital problems and other stress-related conditions. Among the services provided by Defendant's professional staff are short-term
and long-term counseling, stress management, activities therapy, vocational support and MICA services. Defendant's community-based
mental health clinics offer those with severe mental illness a broad range of outpatient services, as well as housing facilities
for residents with independent living skills, health management, counselor visits and educational and recreational opportunities.
Defendant CCBQ has more than 25 behavioral health programs that help individuals strive for rehabilitation and independence.
It provides intensive training in daily living skills, behavior intervention, counseling, crisis and case management, socialization,
discharge planning, medication management and support. Defendant did not provide financial information with the New York State
Attorney General's Office; however, Defendant CCBQ receives revenue for its mental health services from Medicaid. Services
financed by Medicaid are covered under the U.S. Health and Portability and Accountability Act of 1996 (“HIPAA”)
(see Exhibit 4). Jurisdiction *****38)*****This Court has jurisdiction
over this action pursuant to 28 U.S.C. §1331, federal question, which states that “The district courts shall have
original jurisdiction of all civil actions arising under the Constitution, laws, or treaties of the United States.” *****39)*****This Court has jurisdiction
over this action pursuant to 28 U.S.C. 1343, Civil Rights and elective franchise, which states that “(a) The district
courts shall have original jurisdiction of any civil action authorized by law to be commenced by any person: (1) To recover
damages for injury to his person or property, or because of the deprivation of any right or privilege of a citizen of the
United States, by any act done in furtherance of any conspiracy mentioned in section 1985 of Title 42; (2) To recover damages
from any person who fails to prevent or to aid in preventing any wrongs mentioned in section 1985 of Title 42 which he had
knowledge were about to occur and power to prevent; (3) To redress the deprivation, under color of any State law, statute,
ordinance, regulation, custom or usage, of any right, privilege or immunity secured by the Constitution of the United States
or by any Act of Congress providing for equal rights of citizens or of all persons within the jurisdiction of the United States.
. .” *****40)*****This
Court has jurisdiction over this action pursuant to 42 U.S.C. §1983, Civil action for deprivation of rights, which states
that “Every person who, under color of any statute, ordinance, regulation, custom, or usage, of any State or Territory
or the District of Columbia, subjects, or causes to be subjected, any citizen of the United States or other person within
the jurisdiction thereof to the deprivation of any rights, privileges, or immunities secured by the Constitution and laws,
shall be liable to the party injured in an action at law, suit in equity, or other proper proceeding for redress, except that
in any action brought against a judicial officer for an act or omission taken in such officer’s judicial capacity, injunctive
relief shall not be granted unless a declaratory decree was violated or declaratory relief was unavailable. For the purposes
of this section, any Act of Congress applicable exclusively to the District of Columbia shall be considered to be a statute
of the District of Columbia.” *****41)*****This Court has jurisdiction over this action pursuant to 42 U.S.C. §1985(2), Obstructing
justice; intimidating party, witness, or juror, which states that “If two or more persons in any State or Territory
conspire to deter, by force, intimidation, or threat, any party or witness in any court of the United States from attending
such court, or from testifying to any matter pending therein, freely, fully, and truthfully, or to injure such party or witness
in his person or property on account of his having so attended or testified, or to influence the verdict, presentment, or
indictment of any grand or petit juror in any such court, or to injure such juror in his person or property on account of
any verdict, presentment, or indictment lawfully assented to by him, or of his being or having been such juror; or if two
or more persons conspire for the purpose of impeding, hindering, obstructing, or defeating, in any manner, the due course
of justice in any State or Territory, with intent to deny to any citizen the equal protection of the laws, or to injure him
or his property for lawfully enforcing, or attempting to enforce, the right of any person, or class of persons, to the equal
protection of the laws. . .” *****42)*****This Court has jurisdiction over this action pursuant to Bivens v. Six Unknown Named Agents,
403 U.S. 388 (1971). “For the reasons set forth below, I am of the opinion that federal courts do have the power to
award damages for violation of 'constitutionally protected interests' and I agree with the Court that a traditional judicial
remedy such as damages is appropriate to the vindication of the personal interests protected by the Fourth Amendment.”
The Court, in an opinion by Justice Brennan, 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.” *****43)*****This
Court has jurisdiction over the action pursuant to Morgan v. National Railroad Passenger Corporation, DBA Amtrak,
232 F.3d 1008 (November 8, 2000) with regard to the continuing violations doctrine, in which the U.S. Supreme Court stated
in its decision that “the continuing violations doctrine. . .allows courts to consider conduct that would ordinarily
be time barred "as long as the untimely incidents represent an ongoing unlawful. . .practice. . .The district court's
reliance on Galloway was mistaken. This court has never adopted a strict notice requirement as the litmus test for application
of the continuing violation doctrine; in fact, in Fiedler v. UAL Corp., 218 F.3d 973 (9th Cir. 2000), we explicitly
rejected such an approach from the Fifth Circuit. See id. at 987 n.10. Fiedler examined Berry v. Board of Sup'rs of L.S.U.,
715 F.2d 971 (5th Cir. 1983), a case which involved equal pay based upon gender discrimination, where the Fifth Circuit created
a multi-factor test for determining whether discrete acts of harassment are closely related enough to satisfy the continuing
violation theory. The Berry court's final factor, "perhaps of most importance," asked whether the harassing act
"should trigger an employee's awareness of and duty to assert his or her rights.” Berry, 715 F.2d at 981. We rejected
the Berry analysis, holding that test was not "applicable in determining the continuation of a hostile environment."
Fiedler, 218 F.3d at 987 n.10. *****44)*****In tort law, if a defendant commits a series of illegal acts against another person, or, in criminal
law, if someone commits a continuing crime (which can be charged as a single offense), the period of limitation begins to
run from the last act in the series. In the case of Treanor v. MCI Telecommunications, Inc., the U.S. Court of Appeals for
the Eighth Circuit explained that the continuing violations doctrine "tolls the statute of limitations in situations
where a continuing pattern forms due to [illegal] acts occurring over a period of time, as long as at least one incident .
. . occurred within the limitations period. In the case Douglas v. California Department of Youth Authority, 271
F.3d 812, Dossey Douglas was denied employment by the California Youth Authority because a vision test indicated that he was
color-blind. Douglas brought suit against CYA for its failure to hire him under Title I of the ADA. The district court granted
summary judgment to CYA on the ground that Douglas' claims are barred by the applicable statutes of limitations. Douglas argued
on appeal that his claims are timely under the continuing violations doctrine because the CYA's discriminatory policy was
on-going. The U.S. Court of Appeals stated the following: “Applying the continuing violations doctrine to these facts,
we are guided by two earlier Ninth Circuit decisions. In Domingo v. New England Fish Co., 727 F.2d 1429 (9th Cir.
1984), amended 742 F.2d 520 (9th Cir. 1984), we considered a class action suit against a cannery operator involving allegations
of discrimination on the basis of race in hiring and promotions. The plaintiffs argued that their claims were saved from the
time bar by the fact that the discriminatory hiring and promotion polices continued until the plaintiffs brought suit. Id.
at 1443. We required the plaintiffs to demonstrate that because of the discriminatory policy, they were either discriminated
against or “exposed to discrimination” during the limitations period. Id. Almost a decade later, we again addressed
the issue whether a case was timely under a continuing violations theory based on an alleged systemic discrimination in hiring.
EEOC v. Local 350, Plumbers and Pipefitters, 998 F.2d 641, 643 (9th Cir. 1993). The EEOC filed an Age Discrimination
in Employment Act suit on behalf of union members who were excluded from hiring lists on the ground that they received pension
benefits. Id. at 643. We noted that the union's policy that excluded retirees from the hiring lists applied to the class members
as early as 1984, five years earlier. Id. at 644. We found that the action was not barred by the relevant statute of limitations,
because the discriminatory policy prohibiting retirees from joining the hiring lists continued. Id. ("Here, Local 350's
allegedly discriminatory policy was in effect when [the plaintiff] first encountered[the policy] in 1984 and remains in force
today. Thus, under the continuing violations doctrine, relief for [the plaintiff ] is not barred."). Although we did
not cite Domingo in our analysis in Local 350, the two decisions are consistent. In Local 350, the plaintiffs, as union members,
continued to be "exposed " to the discriminatory hiring policies of the union.” The U.S. Court of Appeals
for the Ninth Circuit finally decided that “. . .With respect to the ADA claim. . .We REVERSE the district court's grant
of summary judgment on both the Rehabilitation Act and ADA claims because we conclude that the claims were timely filed under
the continuing violations doctrine.” *****45)*****Declaratory and injunctive relief are sought against all defendants under 28 U.S.C. §2201(a),
Creation of remedy, it states that “In a case of actual controversy within its jurisdiction. . .any court of the United
States, upon the filing of an appropriate pleading, may declare the rights and other legal relations of any interested party
seeking such declaration, whether or not further relief is or could be sought. Any such declaration shall have the force and
effect of a final judgment or decree and shall be reviewable as such.” *****46)*****Monetary damages are sought against all except judiciary
defendants pursuant to 28 U.S.C. §1983 and Bivens. *****47)*****Venue in the Eastern District of New York is proper under 28 U.S.C. §1391(b)(2), which states
that “A civil action wherein jurisdiction is not founded solely on diversity of citizenship may, except as otherwise
provided by law, be brought only in. . .a judicial district in which a substantial part of the events or omissions giving
rise to the claim occurred, or a substantial part of property that is the subject of the action is situated. . .” Statute of Limitations *****48)*****Plaintiff's Verified Complaint, which speaks to Defendants' violations of Title II, ADA, Section
504 of the Rehabilitation Act, and federal civil rights violations under 42 U.S.C. §1983 and 42 U.S.C. §1985 are
timely. According to 42 U.S.C. §1988, Proceedings in vindication of civil rights, (a) Applicability of statutory and
common law, the statute holds that “The jurisdiction in civil and criminal matters conferred on the district courts
by the provisions of titles 13, 24, and 70 of the Revised Statutes for the protection of all persons in the United States
in their civil rights, and for their vindication, shall be exercised and enforced in conformity with the laws of the United
States . . . but in all cases where they are not adapted to the object, or are deficient . . .the common law, as modified
and changed by the constitution and statutes of the State wherein the court having jurisdiction of such civil or criminal
cause is held . . .shall be extended to and govern the said courts in the trial and disposition of the cause . . .”
Federal case law that buttresses Plaintiff's assertion regarding the timeliness of her filing is as follows: Limitations of Time With Regard to 42 U.S.C. §§1983, 1985 **********a)*****In the U.S. Supreme
case Board of Regents v. Tomanio, 446 U.S. 478 (1980), the Court held that “Congress did not establish a statute
of limitations or a body of tolling rules applicable to actions brought in federal court under 1983 - a void which is commonplace
in federal statutory law. When such a void occurs, this Court has repeatedly “borrowed” the state law of limitations
governing an analogous [446 U.S. 478, 484] cause of action. Limitation borrowing was adopted for civil rights action filed
in federal court as early as 1914, in O'Sullivan v. Felix, 233 U.S. 318 . . . In 42 U.S.C. 1988, Congress 'quite
clearly instructs [federal courts] to refer to state statutes' when federal law provides no rule of decision for actions brought
under 1983. Robertson v. Wegmann, supra. See [446 U.S. 478, 485] also Carlson v. Green, ante, at 22, n.
10. As we held in Robertson, by its terms, 1988 authorizes federal courts to disregard an otherwise applicable state
rule of law only if the state law is "inconsistent with the Constitution and laws of the United States.” **********b)*****Chief
Justice Stevens, in delivering his unanimous decision regarding U.S. Supreme Court case Hardin v. Straub, 490 U.S.
536, stated, inter alia that “In enacting 42 U.S.C. 1988 Congress determined that gaps in federal civil rights acts
should be filled by state law, as long as that law is not inconsistent with federal law. See Burnett v. Grattan,
468 U.S. 42, 47 - 48 (1984). Because no federal statute of limitations governs, federal courts routinely measure the timeliness
of federal civil rights suits by state law. Id., at 49; Chardon v. Fumero Soto, 462 U.S. 650, 655 - 656 (1983); Johnson
v. Railway Express Agency, Inc., 421 U.S. 454, 464 (1975). This tradition of borrowing analogous limitations statutes,
cf. O'Sullivan v. Felix, 233 U.S. 318 (1914), is based on a congressional decision to defer to 'the State's judgment on the proper balance between
the policies of repose and the substantive policies of enforcement embodied in the state cause of action.' Wilson v. Garcia,
[490 U.S. 536, 539] 471 U.S. 261, 271 (1985). 'In virtually all statutes of limitations the chronological length of the limitation
period is interrelated with provisions regarding tolling, revival, and questions of application.' Johnson, supra,
at 464. Courts thus should not unravel state limitations rules unless their full application would defeat the goals of the
federal statute at issue. See, e. g., Wilson, supra, at 269; Chardon, supra, at 657.” Limitations of Time With Regard to the Federal Rehabilitation Action **********c)*****In the case J.S.,
a Minor, by His Mother Sharon Duck, v. Isle of Wight County School Board, et al, 402 F.3d 468, one of the issues acknowledged
by Judge Duncan of the United State Court for the Fourth Circuit was issue holding that federal statutes, lacking a statute
of limitations, 'borrowed” the statute of limitations of the state in the which the action accrued pursuant to 42 U.S.C.
§1988. With reference to the court's decision, Judge Duncan stated, inter alia, that “ . . .the Rehabilitation
Act is a federal civil rights statute, and thus the three-step framework provided by §1988 governs the selection of appropriate
state law rules to fill deficiencies in the federal statute. See McCullough v. Branch Banking & Trust Co., 35 F.3d 127,
129 (4th Cir.1994); Wolsky v. Medical Coll. of Hampton Rds., 1 F.3d 222, 223 (4th Cir.1993); see also Holmes
v. Texas A & M Univ., 145 F.3d 681, 684 (5th Cir.1998) ('The selection of a limitations period applicable to Rehabilitation
Act cases is governed by 42 U.S.C. § 1988(a)....')” Limitations
of Time With Regard to the American With Disabilities Action **********d)*****42 U.S.C. §1988's requirement for a federal court to adopt the statute of limitations in
the case where the action accrued also applies to the Americans With Disabilities Act. In the case Soignier v. American
Board of Plastic Surgery, 92 F.3d 547, Judge Manion, speaking for the U.S. Court of Appeals for the Seventh Circuit stated,
inter alia, that “The ADA, like many federal civil rights statutes, does not contain a specific statute of limitations.
Thus, the most appropriate state limitations period applies. 42 U.S.C. §1988(a); Wilson v. Garcia, 471 U.S.
261, 266-67, 105 S.Ct. 1938, 1941-42, 85 L.Ed.2d 254 (1985). Wilson dictates a three-step borrowing analysis . .
. Under step 2, courts are to select the statute of limitations of the state cause of action "most appropriate"
or "most analogous" to the plaintiff's claim . . .” New
York State Statute of Limitations **********e)
New York State Civil Practice Law and Rules Section 214(5) with regard to actions that must be commenced within 3 years, “an
action to recover damages for a personal injury except as provided in sections 214-b, 214-c and 215 . . .” Issues with Regard to Defendant New York State's Sovereign Immunity *****49)*****The Eleventh Amendment
of the U.S. Constitution says that “The Judicial power of the United States shall not be construed to extend to any
suit in law or equity, commenced or prosecuted against one of the United States by Citizens of another State, or by Citizens
or Subjects of any Foreign State.” This means that generally, a sovereign state cannot commit a legal wrong and is immune
from civil suit or criminal prosecution. This legal doctrine, however, is refuted when a state engages in conduct that violates
Federal law. *****50)*****In the U.S. Supreme
Court case, quoting verbatim: “Goodman, petitioner
in No. 04–1236, is a paraplegic who sued respondent state defendants and others, challenging the conditions of his confinement
in a Georgia prison under, inter alia, 42 U. S. C. §1983 and Title II of the Americans with Disability Act of 1990. As
relevant here, the Federal District Court dismissed the §1983 claims because Goodman’s allegations were vague,
and granted respondents' summary judgment on the Title II money damages claims because they were barred by state sovereign
immunity. The United States, petitioner in No. 04–1203, intervened on appeal. The Eleventh Circuit affirmed the District
Court’s judgment as to the Title II claims, but reversed the §1983 ruling, finding that Goodman had alleged facts
sufficient to support a limited number of Eighth Amendment claims against state agents and should be permitted to amend his
complaint. This Court granted certiorari to decide the validity of Title II’s abrogation of state sovereign immunity.”
*****51)*****Justice Scalia, giving
the opinion of the Court, stated the following: “We
consider whether a disabled inmate in a state prison may sue the State for money damages under Title II of the Americans with
Disabilities Act of 1990 (ADA), 104 Stat. 337, as amended, 42 U.S.C. § 12131 et seq. (2000 ed. and Supp. II). Title II of the ADA provides
that “no qualified individual with a disability shall, by reason of such disability, be excluded from participation
in or be denied the benefits of the services, programs, or activities of a public entity, or be subjected to discrimination
by any such entity.” §12132 (2000 ed.). A “ ‘qualified individual with a disability’ ”
is defined as “an individual with a disability who, with or without reasonable modifications to rules, policies, or
practices, the removal of architectural, communication, or transportation barriers, or the provision of auxiliary aids and
services, meets the essential eligibility requirements for the receipt of services or the participation in programs or activities
provided by a public entity.” §12131(2). The Act defines “ ‘public entity’ ” to include
“any State or local government” and “any department, agency, … or other instrumentality of a State,”
§12131(1). We have previously held that this term includes state prisons. See Pennsylvania Dept. of Corrections v.
Yeskey, 524 U.S. 206, 210 (1998). Title II authorizes suits by private citizens for money damages against public entities that
violate §12132. See 42 U.S.C. § 12133 (incorporating by reference 29 U.S.C. § 794a). . . Once Goodman’s complaint is amended, the lower courts
will be best situated to determine in the first instance, on a claim-by-claim basis, (1) which aspects of the State’s
alleged conduct violated Title II; (2) to what extent such misconduct also violated the Fourteenth Amendment; and (3) insofar as such misconduct violated Title II but did not violate the Fourteenth Amendment, whether Congress’s purported abrogation of sovereign immunity as to that class of conduct is nevertheless
valid. The judgment of the Eleventh Circuit is reversed, and the suit is remanded for further proceedings consistent with
this opinion.”
*****52)*****The U.S. Supreme Court held, as did the U.S. Court of Appeals, that a state abrogates sovereign
immunity when it violates both Title II, ADA and the Fourteenth Amendment. Plaintiff asserts that her Verified Complaint will
show that Defendants OMH, DOS and Defendant government-funded not-for-profit outpatient mental health agencies violated Title
II, ADA and the Due Process Clause of the Fourteenth Amendment by conspiring with other Defendants to: 1) illegally publish
Plaintiff's nonpublic, confidential psychiatric information to publicly hold Plaintiff out to be psychotic with anti-Semitic
tendencies; to prevent Defendant NYSUCS' judiciary employees from seeing and hearing Plaintiff's complaints regarding the
commission of perjury and facilitation of identity fraud by employees of Defendant law firms Uzamere and Associate, PLLC,
Allen E. Kaye, PC, Law Office of Harvey Shapiro and Gladstein and Messenger so as to employ willful blindness; and to deny
Plaintiff access to more socially integrated outpatient psychiatric program so as to forcibly steer Plaintiff into an inpatient
setting, intentionally misdiagnosed as psychotic with anti-Semite tendencies so as to discredit Plaintiff's criminal complaint
as the rantings of a psychotic patient. *****53)*****Plaintiff holds that, based on the above, government Defendants' violation of Plaintiff's Title
II, ADA and Fourteenth Amendment rights have caused government Defendant to abrogate sovereign immunity, and that Plaintiff's
action rises to the level of an action in the manner of Bivens v. Six Unknown Named Agents, 403 U.S. 388 (1971). BACKGROUND FACTS Administrative/Judicial
Decisions Specific to the Plaintiff *****54)*****The following are issues that have already been adjudicated by an administrative or judiciary
agency: *****Decision of Federal Administrative
Agencies **********U.S. Citizenship and Immigration
Service (USCIS) **********a)*****On
August 4, 1980 and August 12, 1980, Plaintiff filed a complaint against her ex-husband Senator Ehigie Edobor Uzamere based
on immigration benefit fraud with the U.S. Department of Justice's Immigration and Naturalization Service (“INS”).
Shortly after February 10, 1984, Plaintiff received correspondence from INA which stated that “I have considered the
reason (child support proceedings) you gave in your request for the address of Mr. Ehigie Edobor Uzamere, and I have determined
that the overriding public interest for disclosure outweighs Mr. Uzamere's right to privacy.” In March 2008 Plaintiff
filed Freedom of Information request number NRC 200823721 with USCIS for her ex-husband's immigration records that also contained
Plaintiff's name. In October 2008, Plaintiff received correspondence from Rachel McCarthy that said that . . . IR2 fraudulently
obtained because he was married at the time.” Shortly after January 6, 2009, Plaintiff received more correspondence
from Rachel McCarthy that said inter alia, that “The acts that you allege constitute a violation of the Rules of Professional
Conduct for Practitioner occurred in the course of representation by an attorney associated with Mr. Kaye in connection with
a petition for immediate relative filed by you with the Immigration and Naturalization Service (“INS”) 1979.”
Plaintiff subsequently contacted President Obama to expedite the FOIA request she filed with USCIS. Shortly after June 12,
2009, Plaintiff received correspondence and exhibits from T. Diane Cejka, Director of USCIS' Freedom of Information/Privacy
Act Office that hold that Ehigie Edobor Uzamere was Plaintiff's husband and is the father of the child of the marriage, Tara
A. Uzamere. Correspondence from the White House and USCIS documents concerning Ehigie Edobor Uzamere's identity are attached
as Exhibit 5. **********U.S.
Department of Health and Human Services (USHHS) **********b)*****On or around November 28, 2010, Plaintiff filed a complaint against Defendant FEGS' employees
Dr. Howard Forster, Dr. Clifford Nafus and Roberta Siegal based on religiously-oriented retaliation against Plaintiff. Plaintiff's
complaint was dismissed without administrative trial or hearing. Plaintiff's complaint is attached as Exhibit 6. *****Decisions by Federal Courts **********U.S. Supreme Court **********c)
No. 09-5816, Plaintiff's petition for a writ of certiorari was denied. Information regarding Plaintiff's petition is attached
as Exhibit 7. **********U.S.
District Court – Eastern District of New York **********d)*****Plaintiff filed Docket Nos. 1:2007-CV-2471, 1:2007-CV-1194, 1:2007-CV-891, 1:2007-CV-2703, 1:2007-CV-3709
were filed with the U.S. District Court for the Eastern District of New York. Plaintiff's actions were dismissed without ever
having been tried. Information regarding Plaintiff's actions from Justia.com are attached as Exhibit 8. *****U.S. District Court – Southern District of New York **********e)*****Plaintiff filed
Docket Nos. 1:209-CV-1617, 1:2009-CV-3506 and 1:2010-CV-7668. Plaintiff's actions were dismissed without ever having been
tried. Documentation regarding the aforementioned cases is attached as Exhibit 9. *****U.S. Federal Court of Claims **********f)*****Plaintiff filed Docket Nos. 1:2010-CV-555, 1:2010-CV-585
and 1:2010-CV-591. Plaintiff's actions were dismissed without ever having been tried. Documentation regarding the aforementioned
cases is attached as Exhibit 10. *****Decision
of State Administrative Agency **********g)*****On November 15, 2010, Plaintiff filed a Verified Complaint with the New York State Division of
Human Rights (“Division). The Division dismissed the case finding no probable cause. Division's decision dismissing
Plaintiff's complaints is attached as Exhibit 11. *****New York State Courts **********New
York State Supreme Court, County of Kings **********h)*****Plaintiff filed Index No. 26332-2007 divorce action on or near July 2007. Intelius.com's skiptrace
results that hold that there are no records of “Godwin E. Uzamere” in the United States, Affidavit of Tara A.
Uzamere holding Ehigie Edobor Uzamere to be her father, Decision and Order of the Honorable Jeffrey S. Sunshine dated May
12, 2009 and Decision and Order of the Honorable Matthew D'Emic dated March 15, 2010 holding that Senator Ehigie Edobor Uzamere
was the Plaintiff's husband and is the father Tara A. Uzamere, the child of the marriage are attached as Exhibit
12. **********i)*****Plaintiff
filed Index 18012-2009 on July 17, 2009, action for fraud. The Honorable Arthur M. Schack ruled in favor of defendants Ehigie
Edobor Uzamere, Allen E.Kaye, Harvey Shapiro and Jack Gladstein based on res judicata. Plaintiff appealed Justice
Schack's decision and is awaiting a date for oral argument. *****New
York State Supreme Court, County of New York **********j)*****Plaintiff filed Index No. 009998-2010 in May 2010, action for defamation. Plaintiff's case was
transferred to the New York County Supreme Court and assigned Index No. 403205-2010. On May 11, 2011 the Honorable Paul Wooten
marked all motions as submitted. Plaintiff is awaiting a decision. Affidavit of service of Plaintiff's Notice to Admit, U.S.
Postal Service certified mail and return receipts, Plaintiff's unanswered Notice to Admit and Defendant Daily News' attorneys
admission of late filing are attached as Exhibit 13. **********k)*****Plaintiff filed Index No. 115748 on December 3, 2010.
Plaintiff's Affidavit of Service of her Notice to Admit, Plaintiff's unanswered Notice to Admit, Decision and Order of the
Honorable Donna M. Mills dismissing Plaintiff lawsuit for “failing to plead the elements necessary for the defamation
and intentional infliction of emotional distress” and lack of actionability of Plaintiff's conspiracy claims and Plaintiff's
Notice of Appeal are attached as Exhibit 14. *****New
York State Court of Claims *****l)*****Plaintiff
filed Claim No. 119244-A on or around December 6, 2010. Plaintiff filed Claim No.: “None” on an undetermined dated.
Decision and Orders of the Honorable Thomas Scuccimarra dismissing Claims Nos. 119244-A and “None” in their entirety
are attached as Exhibit 15. Facts *****55)*****Sometime after the Plaintiff
filed her divorce action in October 2007, Uzamere and Associates, by its attorney Eugene Osato Uzamere, told Nigerian news-gathering
agency Point Blank News that “Most of her commentaries are misguided, and I won't give credence to them. She is basically
crazy. I won't give credence to insanity. She is certifiably insane. That is all I have to say. She is crazy”, in defiance
of the decision rendered by the the former U.S. Immigration and Naturalization Service (“INS”), that nearly 30
years earlier administratively adjudged that INA's file no. A35 201 224, assigned to Ehigie Edobor Uzamere and file no. A24
027 764 assigned to “Godwin Uzamere” both belong to Ehigie Edobor Uzamere; and that based on Rachel McCarthy,
Bar Counsel for the U.S. Citizenship and Immigration Service, Ehigie Uzamere's IR2 benefits as an unmarried immigrant under
21 years of age were revoked because he applied for IR1 benefits as “Godwin Ehigie Uzamere”, married and over
21 years of age. Point Blank News article is attached as Exhibit 16). *****56)*****During the Plaintiff's litigation of her divorce,
Plaintiff's divorce action was adjourned 19 times, although Plaintiff's ex-husband never interposed an answer and never appeared.
WebCivil Supreme Appearance list is attached as Exhibit 17. *****57)*****On or around October 8, 2008, Defendant Uzamere and Associates,
by its employee attorney Eugene Uzamere, hand-delivered an affirmation and a fraudulent, unauthenticated, unnotarized counter-affidavit
from Nigeria which stated that “The plaintiff who has openly professed her mental illness is also delusional and outlandish
in her claims”; and “I have before now, ignored the Plaintiff's outburst but her claim to be married to my cousin
who was not in the United States at the time of our marriage is a new twist to this sad tale. . .Her obsession with this destruction
has taken her mental ailment to a new level which should not be encouraged” in defiance of the administrative decision
rendered by the INS regarding Plaintiff's ex-husband's identity. Fraudulent affirmation and counter-affidavit are attached
as Exhibit 18. *****58)*****By January 13, 2009, the Plaintiff obtained and submitted to Justice Jeffrey S. Sunshine a copy
of USCIS attorney Rachel McCarthy's reporting regarding Plaintiff's ex-husband's commission of immigration benefits fraud. *****59)*****On January 12, 2009
Justice Sunshine rendered a decision in which he stated that “Moreover, the opposition submitted by defendant raises
a genuine issue as to whether or not plaintiff and defendant were married in the first instance”, in defiance of INA's
administrative decision that recognized the names “Godwin E. Uzamere” and Ehigie Edobor Uzamere as belonging to
Ehigie Edobor Uzamere, and that Ehigie Edobor Uzamere was married to the Plaintiff. Page 9 of Justice Sunshine's decision
and order dated January 12, 2009 is attached as Exhibit 19. *****60)*****On January 20, 2009, the Plaintiff forwarded a complaint
to former U.S. Ambassador to Nigeria Robin Renee Sanders regarding Justice Sunshine's planned act of identity fraud. The Plaintiff
received a response from the U.S. Embassy on January 30, 2009. E-mail to former U.S. Ambassador to Nigeria Robin Renee Sanders
and e-mail from the U.S. Embassy in Nigeria are attached as Exhibit 20. *****61)*****On May 12, 2009, Justice Sunshine rendered
his decision and order that states that “Today at 10:35 am. defendant was declared in default for failure to appear
at the hearing. Accordingly, 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. Plaintiff is directed to serve a copy of this decision and order and serve and file a note of issue, forthwith, with
proof of mailing by regular international mail and overnight international mail for a trial on all issues within this matrimonial
action to be held before this court on July 7, 2009. at 9:30 a.m. This shall constitute the decision and order of the court.” *****62)*****On July 7, 2009, the
Plaintiff filed an action for fraud against her ex-husband and against Defendants Allen E. Kaye, Harvey Shapiro and Jack Gladstein
based on aforementioned Defendant's defiance of INA's administrative decision rendered 30 years earlier that recognizes Ehigie Edobor Uzamere as Plaintiff's husband, and based on the aforementioned Defendants' facilitation of Plaintiff's
ex-husband commission of immigration fraud and identity fraud. *****63)*****On or near October 28, 2009, employees for Defendants Allen E. Kaye, PC, the Law Office of Harvey
Shapiro and Jack Gladstein submitted affirmations holding “Godwin Uzamere” to the Plaintiff's husband, in defiance
of INS' administrative order rendered 30 years earlier that recognizes Ehigie Edobor Uzamere as the Plaintiff's husband and
the father of Tara A. Uzamere, the child of the marriage. Defendants' employees' fraudulent affirmations are attached as Exhibit
21. *****64)*****On
November 3, 2009, the Plaintiff was arrested by the New York City Police Department for threatening Justice Sunshine. Plaintiff's
letter of incarceration is attached as Exhibit 22. *****65)*****On November 5, 2009, Defendant Daily News, LP, by its employee
Scott Shifrel published a news article which publicly holds the Plaintiff to be psychotic; and that the symptoms that Defendant
Daily News associated with Plaintiff's psychosis were: 1) stripping and screaming about her “senator” husband;
2) Plaintiff's “obsession with his (Senator Uzamere's destruction has taken her mental ailment to a new level which
should not be encouraged”; 3) that “she comes in her and files all these papers and threatens people”; 4)
her “anti-Semitic screeds against judges and others”; and, 5) that Plaintiff “was declared mentally unfit
and taken to Bellevue Hospital” that Defendant Daily News, LP published that it obtained its information from “one
courthouse source”; and that the Plaintiff believes Defendant Daily News' admission regarding the courthouse source
to be true insofar as the aforesaid statement was a declaration made against the Defendant's interest as New York State Civil
Rights Law 79-h (Shield Law) does not requires a news-gathering entity to reveal its sources; and insofar as the courthouse
source so identified violated 22 NYCRR §100.3(B)(8)(11) which state that “A judge shall not make any public comment
about a pending or impending proceeding in any court within the United States or its territories. The judge shall require
similar abstention on the part of court personnel subject to the judge's direction and control...” and “A judge
shall not disclose or use, for any purpose unrelated to judicial duties, nonpublic information acquired in a judicial capacity.”
Defendant Daily News' article is attached as Exhibit 23. *****66)*****On November 30, 2009, twenty-five (25) days after Defendant
Daily News, LP published its article regarding the Plaintiff, Defendant Federation Employment and Guidance Service terminated
its mental health services to the Plaintiff. In its discharge summary it stated that “given client's history of anti-Semitic
remarks treatment at an FEGS facility is inappropriate for her.” FEGS' discharge summary is attached as Exhibit
24. *****67)*****On
December 7, 2009, the Plaintiff was placed with Defendant New York State Office of Mental Health's Kingsboro Psychiatric Facility. *****68)*****Between December 7,
2009 and January 15, 2009, Plaintiff was seen by Defendant New York State Justice Anthony Cutrona of Kings County Supreme
Court's Mental Hygiene Court. *****69)*****On
January 15, 2009, Defendant New York State Justice Arthur M. Schack contacted psychiatrist Dr. Marie Bauduy of New York State
Office of Mental Health's Kingsboro Psychiatric Facility and ordered her not to produce the Plaintiff. In his decision dated
January 25, 2010, Justice Justice stated that “The Court is concerned that plaintiff UZAMERE is unfit to proceed. . .Therefore, the instant matter is adjourned to Friday, March 19, 2010. . .” Justice Schack's decision
is attached as Exhibit 25. *****70)*****During the beginning of February, 2010, Plaintiff was discharged by Kingsboro Psychiatric Facility. *****71)*****On or near February
23, 2010, while the Plaintiff was in her apartment faxing letters of complaint to various governmental agencies, a social
worker from Brookdale Hospital contacted the management office of New York City Housing Authority's Louis H. Pink Houses,
the New York City Police Department and the New York City Fire Department. An employee of the New York City Housing Authority
opened the Plaintiff's apartment door, and Plaintiff was again hospitalized by Defendant New York State Office of Mental Health's
Kingsboro Psychiatric Center. During the Plaintiff's last week as an inpatient, Kingsboro social worker Laurie Velcimé
informed the Plaintiff that she was engaged in aftercare preparation, including locating an outpatient mental health program.
The Plaintiff advised Ms. Velcimé that she was interested in attending New York Psychotherapy and Counseling Center
(NYPCC) on Hendrix Street, located close to where the Plaintiff lives. After Ms. Velcimé performed a search of NYPCC
and other outpatient mental health care providers, she informed the Plaintiff that not only had NYPCC refused to accept Plaintiff
as a client, but that virtually all the not-for-profit outpatient mental health facilities that Ms. Velcimé contacted
rejected her request to provide Plaintiff with outpatient psychiatric services. Discharge summary for Plaintiff's second hospitalization
is attached as Exhibit 26. *****72)*****On May 14, 2010, the Plaintiff appeared before
Justice Arthur M. Schack. Plaintiff complained throughout the hearing that she was not given a chance to talk. Transcript
regarding Plaintiff's appearance is attached as Exhibit 27. *****73)*****In May, 2010, the Plaintiff filed her lawsuit against Defendant
Daily News, LP with the Defendant New York State Court, County of Nassau. In Plaintiff's Verified Complaint, the Plaintiff
stated 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.” Plaintiff's statement regarding paragraph 20 from her Verified Complaint is attached as Exhibit 28. *****74)*****On June 7, 2010, Defendant
Daily News' registered agent for process accepted service of Plaintiff's Summons and Verified Complaint for, inter alia, defamation.
Defendant's registered agent's Notice of Service of Process is attached at Exhibit 29. *****75)*****On or around June 21,
2010, Defendant Daily News, LP filed a demand for transfer to the New York County venue with the Defendant New York State's
Nassau County Supreme Court. Defendant Daily News' demand for transfer is attached as Exhibit 30. *****76)*****On or near June 30,
2010, while under the supervision, care and control of Kings County Chief Clerk Nancy Teigtmeier Sunshine, the wife of the
Honorable Jeffrey S. Sunshine, an employee with the initials “SP” mail the Plaintiff a fraudulent court document
labeled “Kings County Clerk, Equity Department, Window #9, 360 Adams Street, Brooklyn, NY 11201”, requiring the
Plaintiff to refile her lawsuit against the Daily News with the Kings County Supreme Court. Fraudulent form from Kings County
Clerk's Office is attached as Exhibit 31. *****77)*****On July 13, 2010, Justice
Arthur M. Schack rendered his decision, holding among other things, that “Godwin Uzamere” is Plaintiff's husband,
in defiance of both the administrative decision of the U.S. Citizenship and Immigration Service holding Ehigie Edobor Uzamere
to be Plaintiff's husband, and the decisions of Justice Jeffrey S. Sunshine and Justice Matthew D'Emic holding that Senator
Ehigie Edobor Uzamere was Plaintiff's husband and is the father of the Tara A. Uzamere, the child of the marriage. Page 1,
5 and 6 of Justice Schack's decision are attached as Exhibit 32. *****78)*****On or near July 19, 2010, the Defendant New York State's court employee “Tara S.”
of Nassau County Supreme Court's motion department and the Nassau County Clerk's Office mailed all of Plaintiff's motion papers
back to the Plaintiff. Plaintiff was forced to go to Justice Parga's chambers to explain to the part clerk that CPLR §20013 allowed for harmless errors and that CPLR 2102(c)4 requires clerks of court to accept papers. The court subsequently took back all of Plaintiff's motion papers.
Nassau County Supreme Court's motion submission instruction form is attached as Exhibit 33. *****79)*****On or near July 27,
2010, Defendant Daily News' attorney sent correspondence to the Honorable Anthony L. Parga, Justice for the New York State
Supreme Court, County of Nassau in which she stated that “I now withdraw both of those motions and am serving today,
and will promptly file, two new motions (identical in every material respect to the withdrawn motions), returnable on September
1, 2010. The reason for the withdrawal of the earlier motions is that this past Friday the U.S. Post Office returned to my
office the copies of the motion papers that had been served on plaintiff, on the basis that they were undeliverable: we had
made a typographical error on the address label, indicating that plaintiffs apartment number is "68," when in fact
it is "6B''”; that the aforementioned statement is Defendant Daily News' overt admission that it defaulted insofar
as the Respondent did not serve any documents on the Plaintiff until fifty (50) days after the Daily News's registered agent
accepted service of Defendant's Summons and Verified Complaint. Correspondence from Defendant Daily News' attorney is attached
as Exhibit 34. *****80)*****On August 5, 2010, in accordance with 22 NYCRR §670.3 Plaintiff filed her notice to appeal
Justice Schack's decision. Appellant subsequently filed her brief and three (3) appendices with Defendant New York State's
Appellate Division's 2nd judicial department. Cover page for Plaintiff's Notice of Appeal, Appellate Division decision dated
April 6, 2011 and Appellate Brief are attached as Exhibit 35. *****81)*****On October 29, 2010, Justice Anthony L. Parga granted Defendant
Daily News' motion to transfer Plaintiff's lawsuit to the New York State Supreme Court, New York County. Justice Parga's short
form order is attached as Exhibit 36. *****82)*****On January 25, 2011, the Plaintiff received a U.S. Postal Service delivery notice/reminder/receipt
bearing article number 70091080000137809641 and bearing Newark, New Jersey zip code 07102. Plaintiff alleges that this package
was mailed by Defendant Daily News. When Plaintiff checking the article number with the U.S. Postal Service's online Track
and Confirm function, she discovered that the article number was untraceable. Two (2) days after the Plaintiff refused to
accept service of the process that was mailed from Newark, New Jersey, Plaintiff received another notice/reminder/receipt
from the U.S. Postal Service. The second notice/reminder/receipt was dated January 27, 2011. It bore the zip code 10458, but
had no article number. When Plaintiff contacted the post office, she was told that the second notice bearing zip code 10458
and no article number referenced the first notice notice bearing article number 70091080000137809641 zip code 10458 dated
January 27, 2011 referred to the notice/reminder/receipt dated January 25, 2011 bearing the number 70091080000137809641 and
bearing Newark, New Jersey zip code 07102. U.S. Postal Service forms are attached as Exhibit 37. *****83)*****On March 30, 2011, Defendant
Daily News' attorney Anne B. Carroll appeared before Justice Wooten and stated that she had not been served with the Notice
of Motion to Renew; that Justice Wooten refused to check or have his staff check the files to see if the files contained affidavits
of services for the documents in question; that Justice Wooten ordered an adjournment date for oral arguments for May 11,
2011, and that, as usual, the Plaintiff was not given the opportunity to present her arguments to the Court. Affidavits of
service for Plaintiff's Notice of Motion to Renew, Affidavit in Support, return receipts signed by Defendants and Web Civil
Supreme Appearance Detail for oral argument schedule for May 11, 2011 scheduled for 2011 are attached as Exhibit
38. *****84)*****On
April 5, 2011, the Plaintiff submitted a complaint against Defendant Daily News' attorney Anne B. Carroll based on violation
of disciplinary rules of the New York Lawyer's Code of Professional Responsibilities. Plaintiff's complaint is attached as
Exhibit 39. *****85)*****On or near April 6, 2011, the Plaintiff faxed Defendant Daily
News' attorney Anne Carroll the Appellate Brief that she prepared in anticipation of having Justice Wooten render a decision
in Defendant Daily News' favor, although Defendant Daily News file its cross motion on July 27, 2010, fifty (50) days after
its registered agent acknowledged receipt of service and although it failed to respond to Plaintiff Notice to Admit pursuant
to CPLR §§3123, and CVR §79-h(d); although Defendant Daily News' attorney lied about the identity of Plaintiff
ex-husband and although Defendant Daily News publicly admitted in its news article that it had obtained confidential information
from Defendants' “courthouse sources.” Plaintiff's Appellant Brief to Defendant Daily News, LP is attached as
Exhibit 40. *****86)*****On April 20, while Plaintiff was in therapy with Dr. Elio of Brookdale Hospital, Plaintiff spoke
with regard to her legal problems with Defendant Daily News and made comment regarding its owner, Mortimer Zuckerman. Dr.
Elio stated that Plaintiff sees Mortimer Zuckerman at the vegetable stand and at every corner, although the Plaintiff never
made such statements. *****87)*****On
April 29, 2011, the Plaintiff filed complaints with Defendant NYSDDC against employees of Allen E. Kaye, PC, the Law Office
of Harvey Shapiro and Gladstein and Messinger based on their having submitted perjurious affirmations to the court on October
28, 2009 to the New York State Departmental Disciplinary Committee. Complaints are attached as Exhibit 41. *****88)*****On or after April 29,
2011, the Plaintiff received correspondence from Jorge Dopico, New York State Departmental Disciplinary Committee stating
that it had deactivated Plaintiff's complaint against Defendant Daily News' attorney, Anne B. Carroll. Correspondence from
the New York State Departmental Disciplinary Committee is attached as Exhibit 42. *****89)*****On
or around May 5, 2011, the Plaintiff received ex-parte correspondence from Defendant Daily News' attorney Anne B. Carroll
in which she stated that “It was my understanding that the Court anticipated oral argument of plaintiff's motion –
as well as defendants' motion for dismissal of the action – to take place on the same day. However, when our service
attempted to file our opposition papers last moth, the clerk's office declined to accept them, directing that they be handed
up on May 11.” The correspondence indicated “Enclosures”; however, the envelope in which Defendant Daily
News' correspondence was mailed was postmarked “$.0044 and did not contain the enclosures that the correspondence indicated
were sent to Justice Wooten. Copy of correspondence and envelope are attached as Exhibit 43. *****90)*****On May 6, 2011, while
the Plaintiff was in session with therapist Emma Smith, the Plaintiff was crying loudly about having been victimized by her
ex-husband and his attorneys Allen E. Kaye and Harvey Shapiro, and about her inability to obtain justice in the courts. During
the session, several employees of Brookdale Hospital accused the Plaintiff of engaging in threatening behavior and forced
Plaintiff to be hospitalized. When Plaintiff saw the possibility that she would again be forced into a long-term hospitalization
that would cause her to lose her ability to appear in court, upon arriving in the emergency room, the Plaintiff reminded its
staff that mental hygiene law required a 24-hour observation, and that if there was nothing remarkable, the facility would
have to release her. Thereafter the Plaintiff remained silent for twenty-four (24) hours. Shortly after the 24th hour, Dr.
Shawkat Mustafa attempted to interview the Plaintiff along with a 2nd employee. Plaintiff informed them that she would not
allow them to double-team her. Dr. Mustafa interviewed her and thereafter, released the Plaintiff. Brookdale Hospital's discharge
papers are attached as Exhibit 44. *****91)*****On May 11, 2011, the Plaintiff appeared in court for her oral argument at 9:07 am. When she arrived,
Justice Wooten's part clerk Mr. Rubio told the Plaintiff that she could not appear in front of Justice Wooten. Furthermore,
Mr. Rubio explained that he had contacted the Defendant's attorney to inform her not to appear, and that the motions would
be marked as submitted. Plaintiff respectfully asks this Court to note that Justice Wooten's decision not to allow Plaintiff
to appear before him were made less than a week after he received Defendant Daily News' ex-parte communication. *****92)*****On or near May 13, 2011,
the Plaintiff visited Brookdale Hospital to speak with its patient's advocate, Ms. Gray. While speaking with Ms. Gray, the
Plaintiff showed Ms. Gray legal papers concerning her cases in court. The Plaintiff also produced documentation from the ICSWorld.com
website that showed that medical blacklisting, while common, is a form of discrimination. Documentation from ICSWorld.com
is attached as Exhibit 45. *****93)*****On or near May 16, 2011, the Plaintiff received correspondence from Jorge Dopico of Defendant
the New York State Departmental Disciplinary Committee stating that Defendant NYSDDC had forwarded Plaintiff concerning Defendant
Gladstein and Messinger's employee to the Grievance committee for the 2nd and 11th Judicial Departments. Correspondence from
Jorge Dopico is attached as Exhibit 46. *****94)*****During the morning of May 23, 2011, Plaintiff called several individuals within the Defendant's
court system to inquire as to how to obtain records of the mental health evaluations that were adjudicated by Defendant's
judiciary employee Justice Cutrona. A courthouse employee whose name Plaintiff does not know directed the Plaintiff to contact
Justice D'Emic, the justice who adjudicates cases regarding mentally ill criminal defendants and who adjudicated Plaintiff's
divorce. When Plaintiff identified herself, the receptionist stammered out that she was given orders not to speak with Plaintiff
and abruptly hung up. *****95)*****During
the afternoon of May 23, 2011, the Plaintiff received copies of the decisions of the mental health in response to Plaintiff's
phone request to Taylor Green, the attorney from the New York State Mental Hygiene Legal Service, Second Judicial Department
that was assigned to litigate Plaintiff's request for release while the Plaintiff was an inpatient with the Defendant New
York State Office of Mental Health's Kingsboro Psychiatric Facility. Decision and Orders of the Honorable Anthony J. Cutrona
are attached as Exhibit 47. *****96)*****On May 24, 2011, the Plaintiff e-mailed correspondence to Defendant Roy L. Reardon, in his official
capacity as Chairman of Defendant New York State Departmental Disciplinary Committee. In the e-mailed Plaintiff stated that
“Even if I am psychotic”, that I none of your agency's business . . .I am entitled to the protection of the U.S.
Constitution and those federal statutes that were promulgated to ensure the enforcement of the Due Process and Equal Protection
clauses of the U.S. Constitution.” Plaintiff's e-mail to Defendant Roy L. Reardon is attached as Exhibit
48. *****97)*****On
May 25, 2011, at 10:25 am, the Plaintiff e-mailed Defendant Roy L. Reardon a request to reactive her complaint against Defendant
Daily News attorney Anne B. Carroll. Plaintiff's e-mail to Defendant Roy L. Reardon is attached as Exhibit 49. *****98)*****On May 27, 2011, the
Plaintiff received correspondence from Defendant NYSDDC acknowledging Plaintiff's e-mail to Defendant Reardon, and treating
Plaintiff's e-mail as a request to reconsider Defendant NYSDDC's deactivation of Plaintiff's complaint against Defendant Daily News' attorney Anne B. Carroll. Correspondence from Defendant NYSDDC dated May 26, 2011 is attached
at Exhibit 50. *****99)*****By reason of the foregoing allegations, Plaintiff asserts that there exists a justiciable controversy
with respect to which Plaintiff is entitled to the relief prayed for herein. FIRST
CLAIM FOR RELIEF Defendants Violated the Americans With Disabilities
Act Mandate to Administer Services and Programs in the Most Integrated Setting *****100)*****Plaintiff
repeats and realleges the above paragraphs. *****101)*****With regard to the governmental Defendants Andrew M. Cuomo, Nirav R. Shah, Michael F. Hogan, Ann
Pfau and Roy L. Reardon, this claim is brought against them in their official capacities. *****102)*****With regard to Defendants Federation Employment
and Guidance Service, Inc. Interfaith Hospital and Medical Center, New York Psychotherapy and Counseling Center and Catholic
Diocese of Brooklyn/Catholic Charities of Brooklyn and Queens, this claim is brought against them as instrumentalities of
governmental Defendants OMH and DOH. *****103)*****With regard to Defendants Daily News, LP and the Defendant law firms, this claim is brought against
them as corporate citizens having engaged in illegal activity that rises to the level of a federal question (in much the same
way as in the case Gordy v. the Daily News, LP, et al, 95 F.3d 829). *****104)*****Plaintiff is a citizen of the United States with a serious and persistent mental illness. Plaintiff
has a mental impairment that substantially limits one or more major life activities. *****105)*****Plaintiff is a qualified individual with disabilities within
the meaning of 42 U.S.C. §12131(2). *****106)*****Plaintiff is under attack by Defendants, who have created a State-wide hostile environment that
encourages Defendants and private citizens alike to attack Plaintiff as a “anti-Semitic wacko.” Proof of Defendants'
conspiracy to attack the Plaintiff forever exists at Defendant Daily News' website http://articles.nydailynews.com/2009-11-05/local/17938323_1_supreme-court-judge-criminal-court. Defendant Ann Pfau has a duty as NYSUSC's Chief Administrative Judge, and a disciplinary duty, pursuant to
22 NYCRR §100.3(D)5 to ensure that Justice Arthur M. Schack and Justice Paul Wooten are held criminally liable for their facilitation
of the acts of perjury by employees of Defendant law firms Allen E. Kaye, PC, Law Office of Harvey Shapiro and Gladstein and
Messenger. Defendant Pfau has, however behaved in manner that shows that she is more influenced with collegial loyalty and
Defendant Daily News' owner Mortimer Zuckerman's power and money than with removing proof that the agency she supervises illegally
disclosed Plaintiff's federally-protected confidential psychiatric information that was uploaded to billionaire Mortimer Zuckerman's
news corporation's website. Governmental Defendants' depraved lack of loyalty to the U.S. Constitution allows them to continue
to turn a blind eye while NYSUCS' continues to hold Plaintiff to be psychotic with anti-Semitic features. Defendants watch
with sadistic glee while NYSUCS' justice Arthur M. Schack continues to hold that “Godwin E. Uzamere” is the Plaintiff's
husband – even while USCIS and NYSUCS' justices Jeffrey S. Sunshine and Mathew D'Emic have already adjudged that Plaintiff's
ex-husband and the father of the child of the marriage is Senator Ehigie Edobor Uzamere. Plaintiff continues to be negatively
impacted because Defendants OMH and DOH continue to allow their federally- and Defendant-funded not-for-profit mental health
providers to withhold their services from the Plaintiff based on Defendant Daily News' public dissemination of Plaintiff's
mental health information that was illegally disclosed to Defendant Daily News staff writer Scott Shifrel by Defendant NYSUSC's
court personnel – based on Defendant Daily News' own words. Ever since Defendant Daily News publicly portrayed Plaintiff
as psychotic with anti-Semitic features, Plaintiff has been unable to access Defendant OMH's not-for-profit psychiatric continuing
day treatment programs. No OMH-funded psychosocial clubhouse and virtually no OMH-funded not-for-profit outpatient mental
health providers will allow the Plaintiff to become a client. In addition, Defendant NYSUCS's justices have flouted judicial
convention with regard to New York State's and U.S. Constitution's Due Process and Equal Protection Clauses by allowing Defendant
law firms to submit fraudulent affirmations holding “Godwin Uzamere” to be Plaintiff's husband when both the USCIS,
and Defendant NYSUCS's justices Jeffrey S. Sunshine and Matthew D'Emic rendered administrative and judicial decisions holding
Senator Ehigie Edobor Uzamere to be Plaintiff's husband and the father of Tara A. Uzamere, the child of the marriage. Plaintiff
is in continued danger of having Defendant's NYSUCS's justices Arthur S. Schack, Paul Wooten and NYSUSC's appellate justices
continue to render decisions against Plaintiff, not based on the law, but based on Defendants' continued conspiracy to blacklist
Plaintiff as psychotic with anti-Semitic features so as to protect Defendant law firms' employees from
the legal consequences of their acts of perjury as they pertain to the identity of Plaintiff's ex-husband. *****107)*****Serving Plaintiff in a setting which rendered
justice to Plaintiff in spite of her disability can and must be reasonably accommodated. *****108)*****Defendants Cuomo, Shah and Hogan are responsible
for the operation of public entities covered by Title II of the ADA. 42 U.S.C. §§12131(1)(A) and (B). In addition,
it is the responsibility of the government Defendants to ensure that Defendants' private citizens obey Defendant's Constitution
and its laws, including those that pertain to treatment of the disabled. *****109)*****Title II of the ADA prohibits Defendants from discriminating
against individuals with disabilities in programs and activities. 42. U.S.C. §§12131, 12132. *****110)*****Title II also requires that “public
entity shall administer services, programs, and activities in the most integrated setting appropriate to the needs of qualified
individuals with disabilities.” See 28 C.F.R. §35.130(d). *****111)*****Governmental Defendants have failed to meet
this obligation. Defendants have, like other State employees, bowed and scraped to the whims of the powerful, rich corporate
Defendants, to accommodate them in their quest to silence the Plaintiff's cries for justice by using confidential psychiatric
information stolen by Defendant Daily News, LP, not only to hold Plaintiff out to be psychotic with anti-Semitic features,
but to ensure Plaintiff's silence – even if it means murdering the Plaintiff. Defendant NYSUCS flouted federal judicial
and statutory convention by disclosing Plaintiff psychiatric information to Defendant Daily News in violation of Defendant's
own rules.6 SECOND CLAIM FOR RELIEF Defendants
Violated the Americans With Disabilities Act's Prohibition on Using Methods of Administration that Subjected Plaintiff to
Discrimination *****112)*****Plaintiff repeats and realleges the above paragraphs. *****113)*****With regard to the governmental Defendants Andrew M. Cuomo,
Nirav R. Shah, Michael F. Hogan, Ann Pfau and Roy L. Reardon, this claim is brought against them in their official capacities. *****114)*****With regard to Defendants
Federation Employment and Guidance Service, Inc. Interfaith Hospital and Medical Center, New York Psychotherapy and Counseling
Center and Catholic Diocese of Brooklyn/Catholic Charities of Brooklyn and Queens, this claim is brought against them as instrumentalities
of governmental Defendants OMH and DOH. *****115)*****With regard to Defendants Daily News, LP, and the Defendant law firms, this claim is brought against
them as corporate citizens having engaged in illegal activity that rises to the level of a federal question (in much the same
way as in the case Gordy v. the Daily News, LP, et al, 95 F.3d 829). *****116)*****Plaintiff is a citizen of the United States with a serious and persistent mental illness. Plaintiff
has a mental impairment that substantially limits one or more major life activities. *****117)*****Plaintiff is a qualified individual with disabilities within
the meaning of 42 U.S.C. §12131(2). *****118)*****Plaintiff is under attack by Defendants, who have created a State-wide hostile environment that
encourages Defendant's governmental, private and corporate citizens to attack Plaintiff as a “anti-Semitic wacko.”
Plaintiff is continued risk of not being able to access OMH-funded continuing day treatment programs, psychosocial clubhouse
and other not-for-profit outpatient mental health care providers because Defendant NYSUCS illegally disclosed Plaintiff's
psychiatric information to Defendant Daily News, who then publicly held and continues to hold Plaintiff out to be psychotic
with anti-Semitic features. *****119)*****Title
II of the ADA prohibits defendants from discriminating against individuals with disabilities. 42 U.S.C. §§12131,
12132. *****120)*****Regulations
implementing Title II of the ADA provide that “a public entity may not, directly or through contractual or other arrangements,
utilize criteria or methods of administration (i) That have the effect of subjecting qualified individuals with disabilities
to discrimination on the basis or disability; [or] (ii) That have the purpose or effect of defeating or substantially impairing
accomplishment of the objectives of the public entity'[s] program with respect to individuals with disabilities...” *****121)*****Defendants utilize
methods of administration that have the effect of subjecting the Plaintiff to discrimination based on Defendant NYSUCS having
illegally disclosed confidential psychiatric information to Defendant Daily News, who then publicly held Plaintiff out to
be psychotic with anti-Semitic features. Defendant NYSDDC, who Plaintiff provided with more than enough proof of Plaintiff's
allegations regarding the acts of perjury by the employees of Allen E. Kaye, PC, the Law Offices of Harvey Shapiro and Gladstein,
has not yet provided Plaintiff with responses from the aforesaid Defendants. Furthermore, as a result of Defendant NYSUCS'
and Daily News illegal disclosure to the public, Defendants Federation Employment Guidance Service, Inc, Interfaith Hospital
and Medical Center, New York Psychotherapy and Counseling Center and Catholic Diocese of Brooklyn' Catholic Charities' of
Brooklyn and Queens, have refused to provide services to the Plaintiff. Governmental Defendant. Plaintiff has also experience
great difficulty in find an OMH-funded continuing day treatment program or an OMH-funded psychosocial clubhouse that is willing
to accept the Plaintiff. THIRD CLAIM FOR RELIEF Discrimination on the Basis of Disability in Violation of the Americans With Disabilities Activities *****122)*****Plaintiff
repeats and realleges the above paragraphs. *****123)*****With regard to the governmental Defendants Andrew M. Cuomo, Nirav R. Shah, Michael F. Hogan, Ann
Pfau and Roy L. Reardon, this claim is brought against them in their official capacities. *****124)*****With regard to Defendants Federation Employment
and Guidance Service, Inc. Interfaith Hospital and Medical Center, New York Psychotherapy and Counseling Center and Catholic
Diocese of Brooklyn/Catholic Charities of Brooklyn and Queens, this claim is brought against them as instrumentalities of
governmental Defendants OMH and DOH. *****125)*****With regard to Defendants Daily News, LP, and Defendant law firms, this claim is brought against
them as corporate citizens having engaged in illegal activity that rises to the level of a federal question (in much the same
way as in the case Gordy v. the Daily News, LP, et al, 95 F.3d 829). *****126)*****Plaintiff is under attack by Defendants, who have created a State-wide hostile environment that
encourages Defendant's governmental, private and corporate citizens to attack Plaintiff as a “anti-Semitic wacko.”
Plaintiff is continued risk of not being able to access OMH-funded continuing day treatment programs, psychosocial clubhouse
and other not-for-profit outpatient mental health care providers because Defendant NYSUCS illegally disclosed Plaintiff's
psychiatric information to Defendant Daily News, who then publicly held and continues to hold Plaintiff out to be psychotic
with anti-Semitic features. *****127)*****Title
II of the ADA prohibits defendants from discriminating against individuals with disabilities. 42 U.S.C. §§12131,
12132. *****128)*****Defendants
continue to discriminate against Plaintiff on the basis of her mental illness in violation of the ADA by failing to take adequate
measures to ensure that Plaintiff can access those instrumentalities that Defendant OMH and DOH use to provide outpatient
mental health services; and that Defendant NYSUCS failed to take adequate measures to ensure that Plaintiff can obtain unbiased
judgments, and not judgments to favor corporate Defendants' plan to hold Plaintiff out to be psychotic with anti-Semitic features
so as to hide their acts of perjury regarding the identity of Plaintiff's ex-husband. FOURTH
CLAIM FOR RELIEF Defendants Failed to Administer Services in the
Most Integrated Setting Appropriate in Violation of the Rehabilitation Act *****129)*****Plaintiff repeats and
realleges the above paragraphs. *****130)*****This
claim against Defendant NYSUCS is for equitable relief only. Plaintiff understands that judges have immunity for their judicial
acts, even those that are malicious. Plaintiff further understands that save for what the Plaintiff alleges to be Defendants'
commission of 18 U.S.C. §241, conspiracy against rights; 18 U.S.C. §242, deprivation of rights under color of law;
NYS Pen. §105.05, conspiracy, NYS Pen. §115.00, criminal facilitation with regard to Defendant law firms' commission
of NYS Pen. §210.15, perjury in the first degree and NYS Pen. §135.65, coercion in the first degree, those issues
raised in Plaintiff's lawsuits with Defendant NYSUCS courts are outside the purview of this Court's to adjudicate, pursuant
to FRCP Rule 12(h)(3). *****131)*****This
claim for equitable relief and for damages is brought against all other defendants. *****132)*****Section 504 of the Rehabilitation Act, 29 US.C. §794,
provides: No otherwise qualified individual with a disability
in the United States . . . shall, solely by reason of her or his disability, be excluded from participation in, be denied
benefits of, or be subjected to discrimination under any program or activity receiving Federal assistance.
*****133)*****Governmental
Defendants are recipients of Federal financial assistance. *****134)*****OMH and DOH are programs receiving Federal financial assistance. *****135)*****Plaintiff is at continued risk of receiving
biased services by judicial and non-judicial employees of Defendant NYSUCS, who, based on the very words of Defendant Daily
News' article dated November 5, 2009, discriminated against Plaintiff by illegally disclosing Plaintiff's psychiatric information
to Defendant Daily News. Defendant Daily News then publicly held Plaintiff out to be psychotic with anti-Semitic features.
Said information, after having been publicly disseminated, was used by Defendants OMH and DOH to blacklist Plaintiff as psychotic
with anti-Semitic features. Plaintiff now spend the greater part of her time, alone, lonely and in fear – fear that
she will continue her life of loneliness based on Plaintiff's not meeting new people, and fear that Plaintiff will meet new
people who will recognize her as psychotic with anti-Semitic features. *****136)*****Serving Plaintiff in more integrated settings can and must be reasonably accommodated. *****137)*****Defendants violated
Section 504 of the Rehabilitation Act by failing to administer services to Plaintiff in the most integrated setting appropriate
for them. FIFTH CLAIM FOR RELIEF Defendants Violated the Rehabilitation Act's Prohibition on Using Methods of Administration that Subjected
Plaintiff to Discrimination *****138)*****Plaintiff repeats and realleges the above paragraphs. *****139)*****This claim against
Defendant NYSUCS is for equitable relief only. Plaintiff understands that judges have immunity for their judicial acts, even
those that are malicious. Plaintiff further understands that save for what the Plaintiff alleges to be Defendants' commission
of 18 U.S.C. §241, conspiracy against rights; 18 U.S.C. §242, deprivation of rights under color of law; NYS Pen.
§105.05, conspiracy, NYS Pen. §115.00, criminal facilitation with regard to Defendant law firms' commission of NYS
Pen. §210.15, perjury in the first degree and NYS Pen. §135.65, coercion in the first degree, those issues raised
in Plaintiff's lawsuits with Defendant NYSUCS' courts are outside the purview of this Court's to adjudicate, pursuant to FRCP
Rule 12(h)(3). *****140)*****This
claim for equitable relief and for damages is brought against all other defendants. *****141)*****Regulations implementing Section 504 of the Rehabilitation
Act provide that a “recipient may not, directly or through contractual or other arrangements, utilize criteria or methods
of administration: (i) That have the effect of subjecting qualified handicapped persons to discrimination on the basis of
disability; [or] (ii) That have the purpose or effect of defeating or substantially impairing accomplishment of the objectives
of the recipient's program with respect to handicapped persons . . .” 45 C.F.R. §84.4(b)(4). *****142)*****Governmental Defendants are recipients of
Federal financial assistance. *****143)*****OMH
and DOH are programs that receive Federal financial assistance. *****144)*****Defendants utilize methods of administration that have the effect of subjecting Plaintiff to discrimination.
Defendants utilize methods of administration that perpetuate the Defendants' and the public's view that Plaintiff is psychotic
with anti-Semitic features; and that as such, Plaintiff is undeserving of justice, mercy and must be isolated at all costs
– even if it means hospitalizing, jailing or murdering the Plaintiff. SIXTH
CLAIM FOR RELIEF Defendants Discriminated against Plaintiff on
the Basis of Disability in Violation of the Rehabilitation Act *****145)*****Plaintiff repeats and realleges the above paragraphs. *****146)*****This claim against
Defendant NYSUCS is for equitable relief only. Plaintiff understands that judges have immunity for their judicial acts, even
those that are malicious. Plaintiff further understands that save for what the Plaintiff alleges to be Defendants' commission
of 18 U.S.C. §241, conspiracy against rights; 18 U.S.C. §242, deprivation of rights under color of law; NYS Pen.
§105.05, conspiracy, NYS Pen. §115.00, criminal facilitation with regard to Defendant law firms' commission of NYS
Pen. §210.15, perjury in the first degree and NYS Pen. §135.65, coercion in the first degree, those issues raised
in Plaintiff's lawsuits with Defendant NYSUCS' courts are outside the purview of this Court's to adjudicate, pursuant to FRCP
Rule 12(h)(3). *****147)*****This
claim for equitable relief and for damages is brought against all other defendants. *****148)*****Section 504 of the Rehabilitation Act, 29 U.S.C. §794,
provides: No otherwise qualified individual with a disability
in the United States . . . shall, solely by reason of her or his disability, be excluded from participation in, be denied
benefits of, or be subjected to discrimination under any program or activity receiving Federal financial assistance.
*****149)*****Governmental Defendants
are recipients of Federal financial assistance. *****150)*****OMH and DOH are programs receiving Federal financial assistance. *****151)*****With regard to
OMH-funded and DOH-funded not-for-profit outpatient continuing day treatment programs and psychosocial clubhouses, Plaintiff
is qualified to participate in these settings. Plaintiff types between 75-80 wpm. Plaintiff has a fair working knowledge of
Spanish, French and Haitian Creole. The Plaintiff has built websites for herself and others (http://www.uzamerewordprocessing.net; http://www.thecrimesofsenatoruzamere.net; http://www.africandiasporalenterprises.net; http://leglisebaptistedeclarteceleste.tripod.com/; http://victoriouschurchofgod.tripod.com). Before the Plaintiff was arrested and placed in Riker's Island's ward for mentally disabled inmates at Defendants'
behest, Plaintiff taught a computer class at Defendant Federation Employment and Guidance Center at 199 Jay Street in Brooklyn,
New York. Plaintiff is known in the building where she lives as a person who enjoys helping others. Plaintiff's former best
friend, Yitzkhaak (Robert) Benji. When Plaintiff was a client as Defendant Federation Employment and Guidance Service at 3312
Surf Avenue in Brooklyn, New York, the Plaintiff typed program work for Rabbi Yeheskel Lebovic. The Plaintiff continued to
type program documents and documents for Rabbi Lebovic's synagogue after Plaintiff left Defendant FEGS' Coney Island location.
When Plaintiff was with FEGS, she also had friends of other ethnic groups (see Exhibit 51; DVDs containing
phone calls from Yitzhaak's mother and cousin). The Plaintiff has a extensive knowledge with regard to helping citizens obtain
government services, and has used her knowledge to help others obtain services. The Plaintiff offers services to help others
at her website http://www.uzamerewordprocessing.net/my_brothers_keeper.html. In November, 2010, while Plaintiff was a client with Catholic Charities' Open Door Psychosocial Clubhouse,
she started feeling the effects of one of Catholic Charities' employees telling other employees that Plaintiff is an anti-Semite.
The Plaintiff subsequently designed the website http://www.uzamerewordprocessing.net/lookingforaclubhousetocallhome to enlist Defendants OMH, DOH and their government-funded instrumentalities to help Plaintiff find another
clubhouse. With regard to Defendant NYSUCS, Plaintiff has displayed a growing knowledge of the law and has advocated for herself
on several occasions. Plaintiff is well-suited to offer friendship and help to clients and staff alike and to receive in kind
if this Court intercedes and ensures governmental Defendants' compliance with the Americans With Disabilities Act and Section
504 of the Rehabilitation Act. *****152)*****Defendants'
practice of knowingly placing and maintaining Plaintiff in socially bankrupt settings, not allowing Plaintiff to use Defendants
OMH's and DOH's government-funded not-for-profit outpatient psychiatric continuing day treatment programs and their psychosocial
clubhouses isolates the Plaintiff and is the antithesis of the Supreme Court's decision in the case Olmstead v. L.C., 527
U.S. 581 (1999), which states that “[u]njustified isolation . . . is properly regarded as discrimination based on disability,”
observing that “institutional placement of persons who can handle and benefit from community settings perpetuates unwarranted
assumptions that persons so isolated are incapable of or unworthy of participating in community life.” 527 U.S. at 597,
600. *****153)*****The
Plaintiff respectfully informs this Court that the Plaintiff has greatly borrowed on the lawsuit Disability Advocates, Inc.
v. David Paterson, et al. The Plaintiff also respectfully asks this Court to realize that, although the aforementioned lawsuit
never used the terms “blacklist” and “continuing violations”, that is exactly what happened to the
Plaintiffs in DAI's action. The plaintiffs were effectively “blacklisted” from accessing more integrated forms
of housing based on having a mental illness – and according to DAI, it took place over a period of 25 years. Defendants
in Plaintiff's action have done exactly the same thing, except that in this case, Defendants were specifically warned by this
Court not to do so. SEVENTH CLAIM FOR RELIEF Defendants' Blacklisting of Plaintiff Violates 42 U.S.C. §1983 *****154)*****Plaintiff repeats and realleges the above
paragraphs. *****155)*****This
claim against Defendant NYSUCS is for equitable relief only. Plaintiff understands that judges have immunity for their judicial
acts, even those that are malicious. Plaintiff further understands that save for what the Plaintiff alleges to be Defendants'
commission of 18 U.S.C. §241, conspiracy against rights; 18 U.S.C. §242, deprivation of rights under color of law;
NYS Pen. §105.05, conspiracy, NYS Pen. §115.00, criminal facilitation with regard to Defendant law firms' commission
of NYS Pen. §210.15, perjury in the first degree and NYS Pen. §135.65, coercion in the first degree, those issues
raised in Plaintiff's lawsuits with Defendant NYSUCS' courts are outside the purview of this Court's
to adjudicate, pursuant to FRCP Rule 12(h)(3). *****156)*****This claim for equitable relief and for damages is brought against all other defendants. *****157)*****Federal courts recognize
a plaintiff's right to commence a civil action for deprivation of her rights. The statute provides that “Every person
who, under color of any statute, ordinance, regulation, custom, or usage, of any State or Territory or the District of Columbia,
subjects, or causes to be subjected, any citizen of the United States or other person within the jurisdiction thereof to the
deprivation of any rights, privileges, or immunities secured by the Constitution and laws, shall be liable to the party injured
in an action at law, suit in equity, or other proper proceeding for redress.” Plaintiff asserts that Defendants actions
were calculated. The government Defendants conspired – based on Defendant Daily News' own news article – to illegally
disclose Plaintiff's confidential psychiatric information to Defendant Daily News, have Defendant Daily News publicly hold
Plaintiff out to be psychotic with anti-Semitic tendencies, and finally, to ensure that only place that Plaintiff would be
able to recount the crimes committed against her by the Defendant law firms' employees is in the inside of a mental institution
as an inpatient. This level of blacklisting rises to the level of a criminal conspiracy. *****158)*****It is well-established that judges cannot
be sued for damages based on their judicial acts – even if those acts are malicious. However, Defendant NYSUCS' acceptance
of Defendant law firms' employees' perjurious affirmations regarding Plaintiff's ex-husband's identity – even in the
face of administrative and judicial decisions rendered by USCIS and members of Defendant NYSUCS's own judiciary that Senator
Ehigie Edobor Uzamere was Plaintiff's husband and is father of Tara A. Uzamere, the child of the marriage, rises to violations
of criminal law – both State and federal. Judges are not immune from their criminal acts – only their judicial
acts. Defendant NYSUCS' judiciary acted criminally. Documentation regarding U.S. Government's conviction of former Judge Michael
Walker (Operation “Broken Gavel”) and former Judge Michael T. Toole are attached as Exhibit 52. EIGHTH CLAIM FOR RELIEF Defendants'
Blacklisting of Plaintiff from Proceeding in New York Stte Courts Violate 42 U.S.C. §1985(2)(3) *****159)*****Plaintiff
repeats and realleges the above paragraphs. *****160)*****This claim against Defendant NYSUCS is for equitable relief only. Plaintiff understands that judges
have immunity for their judicial acts, even those that are malicious. Plaintiff further understands that save for what the
Plaintiff alleges to be Defendants' commission of 18 U.S.C. §241, conspiracy against rights; 18 U.S.C. §242, deprivation
of rights under color of law; NYS Pen. §105.05, conspiracy, NYS Pen. §115.00, criminal facilitation with regard
to Defendant law firms' commission of NYS Pen. §210.15, perjury in the first degree and NYS Pen. §135.65, coercion
in the first degree, those issues raised in Plaintiff's lawsuits with Defendant NYSUCS's courts are outside the purview of
this Court's to adjudicate, pursuant to FRCP Rule 12(h)(3). *****161)*****This claim for equitable relief and for damages is brought against all other defendants. *****162)*****The referenced federal
statute regarding obstructing justice, intimidating a party, witness or juror to a legal action says that “If two or
more persons in any State or Territory conspire to deter, by force, intimidation, or threat, any party or witness in any court
of the United States from attending such court, or from testifying to any matter pending therein, freely, fully, and truthfully,
or to injure such party or witness in his person or property on account of his having so attended or testified, or to influence
the verdict, presentment, or indictment of any grand or petit juror in any such court, or to injure such juror in his person
or property on account of any verdict, presentment, or indictment lawfully assented to by him, or of his being or having been
such juror; or if two or more persons conspire for the purpose of impeding, hindering, obstructing, or defeating, in any manner,
the due course of justice in any State or Territory, with intent to deny to any citizen the equal protection of the laws,
or to injure him or his property for lawfully enforcing, or attempting to enforce, the right of any person, or class of persons,
to the equal protection of the laws . . . If two or more persons in any State or Territory conspire or go in disguise on the
highway or on the premises of another, for the purpose of depriving, either directly or indirectly, any person or class of
persons of the equal protection of the laws, or of equal privileges and immunities under the laws; or for the purpose of preventing
or hindering the constituted authorities of any State or Territory from giving or securing to all persons within such State
or Territory the equal protection of the laws; or if two or more persons conspire to prevent by force, intimidation, or threat,
any citizen who is lawfully entitled to vote, from giving his support or advocacy in a legal manner, toward or in favor of
the election of any lawfully qualified person as an elector for President or Vice President, or as a Member of Congress of
the United States; or to injure any citizen in person or property on account of such support or advocacy; in any case of conspiracy
set forth in this section, if one or more persons engaged therein do, or cause to be done, any act in furtherance of the object
of such conspiracy, whereby another is injured in his person or property, or deprived of having and exercising any right or
privilege of a citizen of the United States, the party so injured or deprived may have an action for the recovery of damages
occasioned by such injury or deprivation, against any one or more of the conspirators. *****163)*****In the U.S. Supreme Court case Haddle
V. Garrison et al, 525 U.S. 121 (1998), the U.S. Supreme Court held that, with reference to 42 U.S.C. §1985, the
statute proscribes conspiracies to "deter, by force, intimidation, or threat, any. . .witness in any [federal] court
... from attending such court, or from testifying to any matter pending therein, ... or to injure [him] in his person or property
on account of his having so attended or testified," § 1985(2), and provides that if conspirators "do ... any
act in furtherance of ... such conspiracy, whereby another is injured in his person or property, ... the party so injured
... may" recover damages, §1985(3) . . . Such harm has long been, and remains, a compensable injury under tort law,
and there is no reason to ignore this tradition here. To the extent that the terms "injured in his person or property"
refer to such tort principles, there is ample support for the Court's holding. pp. 124-127. 132 F.3d 46, reversed and remanded.” *****164)*****Plaintiff asserts that
Defendants actions were calculated. The government Defendants conspired – based on Defendant Daily News' own news article
– to illegally disclose Plaintiff's confidential psychiatric information to Defendant Daily News, have Defendant Daily
News publicly hold Plaintiff out to be psychotic with anti-Semitic tendencies, and finally, to ensure that the only place
that Plaintiff would be able to recount the immigration fraud and identity fraud that was committed against her by the Defendant
law firms' employees is in the inside of a mental institution as an inpatient. This level of blacklisting rises to the level
of a criminal conspiracy. Judges cannot not be sued for damages for their judicial acts. Defendant NYSUCS has rules of appellate
procedure in 22 NYCRR Part 670 with which the Plaintiff has become familiar and has obeyed. However, Plaintiff obeying all
of Defendant's rules with regard to Defendant NYSUCS' trial and appellate procedures are useless. Governmental Defendants
have become so enamored with the wealth and power of the corporate Defendants they have flown in the face of New York State
law and federal law as they deal with treatment of the disabled. Defendants NYSOMH, NYSDOH and NYSUCS – all of whom
are covered by Title II of the ADA, have taken money allotted to make accommodations for the disabled, and have instead created
a “diagnosis” causing the public to pay for Seroquel although the Plaintiff was diagnosed – not with schizophrenia
– but with bipolar disorder which requires lithium. The first psychiatrist to attempt to prescribe Seroquel to the Plaintiff
was Defendant FEGS' employee Dr. Howard Forster – the same psychiatrist who blacklisted the Plaintiff from all of Defendant
FEGS' facilities based on being psychotic with anti-Semitic tendencies. NINTH
CLAIM FOR RELIEF Defendants' Violations are Violations of the
First, Fifth and Fourteenth Amendments and Give Rise to an Implied Cause of Action *****165)*****Plaintiff
repeats and realleges the above paragraphs. *****166)*****This claim against Defendant NYSUCS is for equitable relief only. Plaintiff understands that judges
have immunity for their judicial acts, even those that are malicious. Plaintiff further understands that save for what the
Plaintiff alleges to be Defendants' commission of 18 U.S.C. §241, conspiracy against rights; 18 U.S.C. §242, deprivation
of rights under color of law; NYS Pen. §105.05, conspiracy, NYS Pen. §115.00, criminal facilitation with regard
to Defendant law firms' commission of NYS Pen. §210.15, perjury in the first degree and NYS Pen. §135.65, coercion
in the first degree, those issues raised in Plaintiff's lawsuits with Defendant NYSUCS' courts are outside the purview of
this Court's to adjudicate, pursuant to FRCP Rule 12(h)(3). *****167)*****This claim for equitable relief and for damages is brought against all other defendants. *****168)*****The famous U.S. Supreme
Court case Bivens v. Six Unknown Named Agents, 403 U.S. 388 (1971) recognized a private citizen's right to sue for
damages for commission of constitutional violation. Justice Brennan, in issuing the the majority decision stated: “For
the reasons set forth below, I am of the opinion that federal courts do have the power to award damages for violation of 'constitutionally
protected interests' and I agree with the Court that a traditional judicial remedy such as damages is appropriate to the vindication
of the personal interests protected by the Fourth Amendment.” *****169)*****Plaintiff asserts that Defendants actions were calculated. The government Defendants conspired
– based on Defendant Daily News' own news article – to illegally disclose Plaintiff's confidential psychiatric
information to Defendant Daily News, have Defendant Daily News publicly hold Plaintiff out to be psychotic with anti-Semitic
tendencies, and finally, to ensure that only place that Plaintiff will be able to recount the immigration fraud and identity
fraud committed against her by the Defendant law firms' employees is in the inside of a mental institution as an inpatient.
This level of blacklisting rises to the level of a criminal conspiracy. Judges cannot not be sued for damages for their judicial
acts. Defendant NYSUCS has rules of appellate procedure in 22 NYCRR Part 670 with which the Plaintiff has become familiar
and has obeyed. However, Plaintiff obeying all of Defendant's rules with regard to judicial procedure are useless. Governmental
Defendants have become so enamored with the wealth and power of the corporate Defendants they have have flown in the face
of New York State law and federal law as they deal with treatment of the disabled. Defendants NYSOMH, NYSDOH and NYSUCS –
all of whom are covered by Title II of the ADA, have taken money allotted to make accommodations for the disabled, and have
instead created a “diagnosis” – causing the public to pay for Seroquel although the Plaintiff was diagnosed
– not with schizophrenia – but with bipolar disorder which requires lithium. The first psychiatrist to attempt
to prescribe Seroquel to the Plaintiff was Defendant FEGS' employee Dr. Howard Forster – the same psychiatrist who blacklisted
the Plaintiff from all of Defendant FEGS' facilities based on being psychotic with anti-Semitic tendencies. Reiteration Of Violations Committed by Defendants *****170)*****Wikipedia.org describes
the term “due process” as “the legal principle that the government must respect all of the legal rights
that are owed to a person according to the law. Due process holds the government subservient to the law of the land protecting
individual persons from the state. When a government harms a person without following the exact course of the law it constitutes
a due process violation which offends against the rule of law.” *****171)*****Plaintiff reasserts that the Defendants committed the following violations of due process: **********a)*****That Defendant NYSUCS's
judiciary employees the Honorable Michael Gerstein, the Honorable Jeffrey S. Sunshine and the Honorable Arthur M. Schack,
on their own and/or by courthouse employees that are under their care and control, illegally commented on and provided nonpublic
information regarding Petitioner's cases Kings County Criminal Court Case Docket No. 2009KN087992, Kings County Supreme Court
Index No. 18012-2009 and Kings County Supreme Index No. 26332-2007 to Daily News staff writer Scott Shifrel in violation of
22 NYCRR §100.3(B)(8), (11), that “a judge shall not make any public comment about a pending or impending proceeding
in any court within the United States or its territories. The judge shall require similar abstention on the part of court
personnel...” and that “a judge shall not disclose or use, for any purpose unrelated to judicial duties, nonpublic
information acquired in a judicial capacity.”; that Defendant's commission of said violations is based on Defendant
law firms' employees' inability to file a lawsuit against Plaintiff for defamation because Plaintiff's assertions regarding
Defendant law firm employees' facilitation of her ex-husband's commission of immigration fraud and identity fraud are true;
that Defendant law firm Allen E. Kaye, PC's active conspiracy is based on its employees' original desire to coerce Plaintiff
to be silent based on Plaintiff's original fear of being publicly shamed as sexually promiscuous and has having another child
without a husband; that Defendants' active conspiracy is based on their desire to prevent Plaintiff from receiving honest
judicial services to allow Plaintiff to report Defendant law firms' employees' crimes against her; that Defendants' active
conspiracy is based on their desire to prevent Plaintiff from receiving honest outpatient mental health services so as to
allow Plaintiff to utilize Defendants' outpatient mental health services as a crime victim; and that Defendants' active conspiracy
is based on their desire to forcibly steer Plaintiff to only report Defendant law firms' employees' crimes against her in
an inpatient psychiatric setting so as to discredit Plaintiff's irrefutable testimony regarding attorneys Osato Eugene Uzamere's,
Allen E. Kaye's, Harvey Shapiro's and Jack Gladstein's facilitation of Plaintiff's ex-husband Senator Ehigie Edobor Uzamere's
commission of immigration fraud and identity fraud based on her status of having a mental illness, in violation of Title II,
ADA, Section 504 of the Federal Rehabilitation Act, 42 U.S.C. §1983, 42 U.S.C. §1985, 18 U.S.C. §241 and 18
U.S.C. §242. **********b)*****That
Defendant NYSUCS' judiciary employees the Honorable Arthur M. Schack's, the Honorable Jeffrey S. Sunshine's and the Honorable
Eric I. Justice Prus' refused to take disciplinary actions against Defendant law firms' employees for their submission of
perjurious affirmations, in violation of 22 NYCRR §100.3(D), which states that (2) A judge who receives information indicating
a substantial likelihood that a lawyer has committed a substantial violation of the Code of Professional Responsibility shall
take appropriate action; and (3) Acts of a judge in the discharge of disciplinary responsibilities are part of a judge's judicial
duties; Defendant NYSUCS' judiciary employees the Honorable Justice Arthur M. Schack's, the Honorable Jeffrey S Sunshine's,
the Honorable Eric I. Prus and the Honorable Paul Wooten's facilitation of Plaintiff's ex-husband's commission of identity
fraud and facilitation of Defendant law firm's attorneys' commission of perjury; that Defendant's commission of said violations
is based on Defendant law firms' employees' inability to file a lawsuit against Plaintiff for defamation because Plaintiff's
assertions regarding their facilitation of Plaintiff's ex-husband's commission of immigration fraud and identity fraud are
true; that Defendant law firm Allen E. Kaye, PC's active conspiracy is based on its employees' original desire to coerce Plaintiff
to be silent based on Plaintiff's original fear of being publicly shamed as sexually promiscuous and has having another child
without a husband; that Defendants' active conspiracy is based on their desire to prevent Plaintiff from receiving honest
judicial services to allow Plaintiff to report Defendant law firms' employees' crimes against her; that Defendants' active
conspiracy is based on their desire to prevent Plaintiff from receiving honest outpatient mental health services so as to
allow Plaintiff to utilize Defendants' outpatient mental health services as a crime victim; and that Defendants' active conspiracy
is based on their desire to forcibly steer Plaintiff to only report Defendant law firms' employees' crimes against her in
an inpatient psychiatric setting so as to discredit Plaintiff's irrefutable testimony regarding attorneys Osato Eugene Uzamere's,
Allen E. Kaye's, Harvey Shapiro's and Jack Gladstein's facilitation of Plaintiff's ex-husband Senator Ehigie Edobor Uzamere's
commission of immigration fraud and identity fraud based on her status of having a mental illness, in violation of Title II,
ADA, Section 504 of the Federal Rehabilitation Act, 42 U.S.C. §1983, 42 U.S.C. §1985, 18 U.S.C. §241 and 18
U.S.C. §242. *****c)*****That
Defendant NYSUCS's judiciary employee the Honorable Paul Wooten's refused to take disciplinary action against Defendant Daily
News' attorney Anne B. Carroll's commission of perjury in violation of 22 NYCRR §100.3(D) which states that (2) A judge
who receives information indicating a substantial likelihood that a lawyer has committed a substantial violation of the Code
of Professional Responsibility shall take appropriate action; and (3) Acts of a judge in the discharge of disciplinary responsibilities
are part of a judge's judicial duties; that Defendant's commission of said violations is based on Defendant law firms' employees'
inability to file a lawsuit against Plaintiff for defamation because Plaintiff's assertions regarding Defendant law firm employee's
facilitation of her ex-husband's commission of immigration fraud and identity fraud are true; that Defendant law firm Allen
E. Kaye, PC's active conspiracy is based on its employees' original desire to coerce Plaintiff to be silent based on Plaintiff's
original fear of being publicly shamed as sexually promiscuous and has having another child without a husband; that Defendants'
active conspiracy is based on their desire to prevent Plaintiff from receiving honest judicial services to allow Plaintiff
to report Defendant law firms' employees' crimes against her; that Defendants' active conspiracy is based on their desire
to prevent Plaintiff from receiving honest outpatient mental health services so as to allow Plaintiff to utilize Defendants'
outpatient mental health services as a crime victim; and that Defendants' active conspiracy is based on their desire to forcibly
steer Plaintiff to only report Defendant law firms' employees' crimes against her in an inpatient psychiatric setting so as
to discredit Plaintiff's irrefutable testimony regarding attorneys Osato Eugene Uzamere's, Allen E. Kaye's, Harvey Shapiro's
and Jack Gladstein's facilitation of Plaintiff's ex-husband Senator Ehigie Edobor Uzamere's commission of immigration fraud
and identity fraud based on her status of having a mental illness, in violation of Title II, ADA, Section 504 of the Federal
Rehabilitation Act, 42 U.S.C. §1983, 42 U.S.C. §1985, 18 U.S.C. §241 and 18 U.S.C. §242. **********d)*****That Defendant NYSUCS'
judiciary employee the Honorable Donna A. Mills' dismissed Plaintiff's lawsuit based on a reason that is not based in law;
that Defendant's commission of said violations is based on Defendant law firms' employees' inability to file a lawsuit against
Plaintiff for defamation because Plaintiff's assertions regarding Defendant law firm employee's facilitation of her ex-husband's
commission of immigration fraud and identity fraud are true; that Defendant law firm Allen E. Kaye, PC's active conspiracy
is based on its employees' original desire to coerce Plaintiff to be silent based on Plaintiff's original fear of being publicly
shamed as sexually promiscuous and has having another child without a husband; that Defendants' active conspiracy is based
on their desire to prevent Plaintiff from receiving honest judicial services to allow Plaintiff to report Defendant law firms'
employees' crimes against her; that Defendants' active conspiracy is based on their desire to prevent Plaintiff from receiving
honest outpatient mental health services so as to allow Plaintiff to utilize Defendants' outpatient mental health services
as a crime victim; and that Defendants' active conspiracy is based on their desire to forcibly steer Plaintiff to only report
Defendant law firms' employees' crimes against her in an inpatient psychiatric setting so as to discredit Plaintiff's irrefutable
testimony regarding attorneys Osato Eugene Uzamere's, Allen E. Kaye's, Harvey Shapiro's and Jack Gladstein's facilitation
of Plaintiff's ex-husband Senator Ehigie Edobor Uzamere's commission of immigration fraud and identity fraud based on her
status of having a mental illness, in violation of Title II, ADA, Section 504 of the Federal Rehabilitation Act, 42 U.S.C.
§1983, 42 U.S.C. §1985, 18 U.S.C. §241 and 18 U.S.C. §242. **********e)*****That Defendant NYSUCS' judiciary employee the Honorable
Ann Pfau refused to take disciplinary action in violation of which states that (1) “A judge who receives information
indicating a substantial likelihood that another judge has committed a substantial violation of this Part shall take appropriate
action; that Defendant's commission of said violations is based on Defendant law firms' employees' inability to file a lawsuit
against Plaintiff for defamation because Plaintiff's assertions regarding Defendant law firm employee's facilitation of her
ex-husband's commission of immigration fraud and identity fraud are true; that Defendant law firm Allen E. Kaye, PC's active
conspiracy is based on its employees' original desire to coerce Plaintiff to be silent based on Plaintiff's original fear
of being publicly shamed as sexually promiscuous and has having another child without a husband; that Defendants' active conspiracy
is based on their desire to prevent Plaintiff from receiving honest judicial services to allow Plaintiff to report Defendant
law firms' employees' crimes against her; that Defendants' active conspiracy is based on their desire to prevent Plaintiff
from receiving honest outpatient mental health services so as to allow Plaintiff to utilize Defendants' outpatient mental
health services as a crime victim; and that Defendants' active conspiracy is based on their desire to forcibly steer Plaintiff
to only report Defendant law firms' employees' crimes against her in an inpatient psychiatric setting so as to discredit Plaintiff's
irrefutable testimony regarding attorneys Osato Eugene Uzamere's, Allen E. Kaye's, Harvey Shapiro's and Jack Gladstein's facilitation
of Plaintiff's ex-husband Senator Ehigie Edobor Uzamere's commission of immigration fraud and identity fraud based on her
status of having a mental illness, in violation of Title II, ADA, Section 504 of the Federal Rehabilitation Act, 42 U.S.C.
§1983, 42 U.S.C. §1985, 18 U.S.C. §241 and 18 U.S.C. §242. **********f)*****That Defendants New York State, OMH, DOS and Defendants
not-for-profit outpatient mental health agencies refused to take measures to provide Plaintiff with services in the most integrated
setting appropriate to Plaintiff's needs, and in a setting that enables the Plaintiff to interact with non-disabled persons
to the fullest extent possible; that Defendant's commission of said violations is based on Defendant law firms' employees'
inability to file a lawsuit against Plaintiff for defamation because Plaintiff's assertions regarding Defendant law firm employee's
facilitation of her ex-husband's commission of immigration fraud and identity fraud are true; that Defendant law firm Allen
E. Kaye, PC's active conspiracy is based on its employees' original desire to coerce Plaintiff to be silent based on Plaintiff's
original fear of being publicly shamed as sexually promiscuous and has having another child without a husband; that Defendants'
active conspiracy is based on their desire to prevent Plaintiff from receiving honest judicial services to allow Plaintiff
to report Defendant law firms' employees' crimes against her; that Defendants' active conspiracy is based on their desire
to prevent Plaintiff from receiving honest outpatient mental health services so as to allow Plaintiff to utilize Defendants'
outpatient mental health services as a crime victim; and that Defendants' active conspiracy is based on their desire to forcibly
steer Plaintiff to only report Defendant law firms' employees' crimes against her in an inpatient psychiatric setting so as
to discredit Plaintiff's irrefutable testimony regarding attorneys Osato Eugene Uzamere's, Allen E. Kaye's, Harvey Shapiro's
and Jack Gladstein's facilitation of Plaintiff's ex-husband Senator Ehigie Edobor Uzamere's commission of immigration fraud
and identity fraud based on her status of having a mental illness, in violation of Title II, ADA, Section 504 of the Federal
Rehabilitation Act, 42 U.S.C. §1983, 42 U.S.C. §1985, 18 U.S.C. §241 and 18 U.S.C. §242. *****g)*****That Defendant Daily
News, LP theft and disclosure of Defendant NYSUCS's Kings County Criminal Court's nonpublic, confidential psychiatric information
concerning Plaintiff's criminal lawsuit Docket No. 2009KN087992; Defendant Daily News' theft and disclosure of Defendant NYSUCS's
Kings County Supreme Court's nonpublic, confidential information regarding Plaintiff's divorce Index No. 26332-2007; Defendant
Daily News' facilitation of Defendant law firms' employees' commission of perjury; perjurious that Defendant's commission
of said violations is based on Defendant law employees' inability to file a lawsuit against Plaintiff for defamation because
Plaintiff's assertions regarding Defendant law firm employee's facilitation of her ex-husband's commission of immigration
fraud and identity fraud are true; that Defendant law firm Allen E. Kaye, PC's active conspiracy is based on its employees'
original desire to coerce Plaintiff to be silent based on Plaintiff's original fear of being publicly shamed as sexually promiscuous
and has having another child without a husband; that Defendants' active conspiracy is based on their desire to prevent Plaintiff
from receiving honest judicial services to allow Plaintiff to report Defendant law firms' employees' crimes against her; that
Defendants' active conspiracy is based on their desire to prevent Plaintiff from receiving honest outpatient mental health
services so as to allow Plaintiff to utilize Defendants' outpatient mental health services as a crime victim; and that Defendants'
active conspiracy is based on their desire to forcibly steer Plaintiff to only report Defendant law firms' employees' crimes
against her in an inpatient psychiatric setting so as to discredit Plaintiff's irrefutable testimony regarding attorneys Osato
Eugene Uzamere's, Allen E. Kaye's, Harvey Shapiro's and Jack Gladstein's facilitation of Plaintiff's ex-husband Senator Ehigie
Edobor Uzamere's commission of immigration fraud and identity fraud based on her status of having a mental illness, in violation
of Title II, ADA, Section 504 of the Federal Rehabilitation Act, 42 U.S.C. §1983, 42 U.S.C. §1985, 18 U.S.C. §241
and 18 U.S.C. §242. *****h)*****That
Defendant law firms' employees' facilitated of Plaintiff's ex-husband Senator Ehigie Edobor Uzamere's commission of immigration
fraud and identity fraud; that Defendant law firms' employees' committed perjury with respect to the I-130 immediate sponsorship
form that the U.S. Citizenship and Immigration Service held was a falsified document thirty-two years ago; that Defendant
law firm Allen E. Kaye, PC's active conspiracy is based on its employees' original desire to coerce Plaintiff to be silent
based on Plaintiff's original fear of being publicly perceived as sexually promiscuous and has having another child without
a husband; that Defendants' active conspiracy is based on their desire to prevent Plaintiff from receiving honest judicial
services to allow Plaintiff to report Defendant law firms' employees' crimes against her; and that Defendants' active conspiracy
is based on their desire to prevent Plaintiff from receiving honest outpatient mental health services so as to allow Plaintiff
to utilize Defendants' outpatient mental health services as a crime victim; that Defendants' active conspiracy is based on
their desire to forcibly steer Plaintiff to only report Defendant law firms' employees' crimes against her in an inpatient
psychiatric setting so as to discredit Plaintiff's irrefutable testimony regarding attorneys Osato Eugene Uzamere's, Allen
E. Kaye's, Harvey Shapiro's and Jack Gladstein's facilitation of Plaintiff's ex-husband Senator Ehigie Edobor Uzamere's commission
of immigration fraud and identity fraud based on her status of having a mental illness, in violation of Title II, ADA, Section
504 of the Federal Rehabilitation Act, 42 U.S.C. §1983, 42 U.S.C. §1985, 18 U.S.C. §241 and 18 U.S.C. §242. *****i)*****That Defendant NYSDDC
deactivated Plaintiff's complaint against billionaire owner Mortimer Zuckerman's company Daily News' employee attorney Anne
B. Carroll; that the aforementioned Defendant has made no attempt to contact Plaintiff with regard to Plaintiff's complaint
against Defendant law firms' employees and attorney Matthew Kaufman; that Defendant law firm Allen E. Kaye, PC's active conspiracy
is based on its employees' original desire to coerce Plaintiff to be silent based on Plaintiff's original fear of being publicly
shamed as sexually promiscuous and has having another child without a husband; that Defendants' active conspiracy is based
on their desire to prevent Plaintiff from receiving honest judicial services to allow Plaintiff to report Defendant law firms'
employees' crimes against her; that Defendants' active conspiracy is based on their desire to prevent Plaintiff from receiving
honest outpatient mental health services so as to allow Plaintiff to utilize Defendants' outpatient mental health services
as a crime victim; and that Defendants' active conspiracy is based on their desire to forcibly steer Plaintiff to only report
Defendant law firms' employees' crimes against her in an inpatient psychiatric setting so as to discredit Plaintiff's irrefutable
testimony regarding attorneys Osato Eugene Uzamere's, Allen E. Kaye's, Harvey Shapiro's and Jack Gladstein's facilitation
of Plaintiff's ex-husband Senator Ehigie Edobor Uzamere's commission of immigration fraud and identity fraud based on her
status of having a mental illness, in violation of Title II, ADA, Section 504 of the Federal Rehabilitation Act, 42 U.S.C.
§1983, 42 U.S.C. §1985, 18 U.S.C. §241 and 18 U.S.C. §242. Summary *****172)*****Thirty-two years ago,
Plaintiff, unbeknownst to her, had an active sexual addiction. Plaintiff met her ex-husband, and within a month of meeting
him, Plaintiff was pregnant with his daughter – having already had a nine-month-old son from a previous relationship
(see photos of Plaintiff on a foster care visit with her children, David P. Walker and Tara A. Uzamere; after Plaintiff's
children were released from foster care and chapter from Plaintiff's website attached as Exhibit 53).
While dating her ex-husband, Plaintiff also had other aberrant “personality” characteristics that Plaintiff did
not know were symptoms of bipolar disorder. Plaintiff asserts that both her ex-husband and the employees of Defendant law
firm Allen E. Kaye, PC knew or strongly suspected Plaintiff's aberrant behavior were symptoms of a mental illness, and that
the marriage, subsequent to a two-month courtship between a no-green-card-having immigrant and a unrepresented, mentally unstable
citizen was not equitable. However, Plaintiff's ex-husband and the Defendant law firms' employees did not care that Plaintiff
was “wacko.” They did not care if Plaintiff had anti-Semitic features. They did not care that Plaintiff was pregnant,
legally unprotected, alone, and mentally ill. Plaintiff's ex-husband and Defendant law firms' employees used Plaintiff's mental
illness against her as a weapon to obtain her signature for the I-130 immediate relative sponsorship to assist their client
in obtaining residence. *****173)*****Thirty-two years later, Defendant law firms'
employees now realize that they made a mistake by equating Plaintiff's mental illness with her intelligence, her ability to
learn the law, her persistence – and her rage. Plaintiff expressed this rage by broadcasting Defendant law firms' employees'
criminal facilitation of their client's act of immigration fraud and identity fraud on her website, http://www.thecrimesofsenatoruzamere.net. With Defendant law firms' inability to launch a legal defensive by way of an honest action for defamation
against her (like Plaintiff filed against Defendant Daily News, LP), the only weapon they have is Plaintiff's mental illness,
the shame associated with the publication of Plaintiff's mental illness, originally associated with Plaintiff's sexual promiscuity
and her fear of not having a husband – and the participation of corrupt government employees and the corporate Defendants
that support their efforts to permanently silence the Plaintiff. *****174)*****Plaintiff asserts that it is not illegal to have a mental disorder that makes one crave sex. Plaintiff
asserts that it is not illegal to engage in behaviors that are socially unpleasing. Plaintiff asserts that is not illegal
to have, and to openly express feelings toward specific groups of people that may be considered abhorrent. See See Curley
v. NAMBLA, No. Civ.A. 00-10956-GAO, 2003 WL 21696547 (D.Mass. March 31, 2003). However, according to the Honorable Nicholas
G. Garaufis, it is both abhorrent and illegal to engage in unjustified isolation of people who have mental illnesses. In Judge
Garaufis' Memorandum and Order regarding Disability Advocates, Inc. vs. Paterson, et al, 03-CV-3209 Judge Garaufis
quoted from the landmark U.S. Supreme Court case Olmstead v. L.C., 527 U.S. 581 (1999), stating that that “[u]njustified
isolation . . . is properly regarded as discrimination based on disability,” observing that “institutional placement
of persons who can handle and benefit from community settings perpetuates unwarranted assumptions that persons so isolated
are incapable of or unworthy of participating in community life.” Documentation regarding the case Curley v. NAMBLA
is attached as Exhibit 54. *****175)*****Defendants have shown this Court great contempt with regard to this Court order to integrate individuals
who have mental illness. It has used media corporations like Defendant Daily News and the New York Post to publicly disagree
with this Court order, going so far as to the this Court's trier of fact a “dictator” and “in conflict.”
However, Defendants have, brazenly and hypocritically violated Judge Garaufis order, as well as Title II, ADA, Section 504
of the Rehabilitation Act, 42 U.S.C. §1983, 42 U.S.C. §1985, 18 U.S.C. §241 and 18 U.S.C. §242 (see Exhibit
55). David Rosen, former CEO of Brookdale Hospital, a healthcare facility that receives various government grants,
is reported to have made $1,764,235 for fiscal year 2009 to provide professional executive services for the government-funded
healthcare facility. According to the U.S. Attorney's Office for the Southern District of New York, however, Mr. Rosen engaged
in paying out at least $1,000,000 to two (2) of Defendant New York State's politicians for political favors. Like Defendant
New York State's politicians, governmental Defendants have made themselves comfortable with billionaire-Mortimer-Zuckerman-owned
Defendant Daily News, said comfort exhibiting itself with Defendant NYSUSC's employees' illegal disclosure of Plaintiff's
confidential psychiatric information. Defendants have conspired to physically and socially isolate the Plaintiff from as many
of Defendants OMH's and DOH's government-funded, not-for-profit, outpatient mental health facilities as possible so as to
forcibly steer Plaintiff into a psychiatric inpatient setting to prevent Plaintiff from reporting the crimes of Defendant
law firms' employees Osato Eugene Uzamere, Esq., Allen E. Kaye, Esq., Harvey Shapiro, Esq., and Jack Gladstein, Esq. Defendants
ignored Plaintiff's cries for justice and instead harkened to the call of billionaire owner Mortimer Zuckerman's media company,
Defendant Daily News to publish the lie that Plaintiff is married to “Godwin Uzamere”, and that Plaintiff is psychotic
with anti-Semitic – using Defendant Daily News' public portrayal of the Plaintiff as psychotic with anti-Semitic features
as a weapon against the Plaintiff in much the same manner that Defendant law firm Allen E. Kaye, PC's employees used Plaintiff's
shame of being sexual promiscuous and Plaintiff's fear of not having a husband thirty-two years ago. *****176)*****Defendants have also placed the Plaintiff
in a position of great danger. Psychiatry is a branch of medicine. Therapeutic sessions with psychologists and/or social workers
are in tandem with the diagnosis of the treating psychiatrist. If Defendants can arbitrarily turn Plaintiff down for one type
of medical service without having to honor Plaintiff's right to an administrative hearing, without this Court's intervention,
what prevents the Defendants from withholding other forms of medical assistance from the Plaintiff? In the case of Esmin Green,
the mentally ill patient who died of blood clots while waiting for a bed in Kings County's inpatient psychiatric unit, she
died as a direct result of its staff's withholding life-saving medical assistance from Ms. Green based on the mistaken belief
that Ms. Green was manifesting symptoms of psychosis – the same type of mental illness which Defendants ascribe to the
Plaintiff. If Kings County's psychiatric staff acted with such nonchalance toward a woman who was just a private citizen,
with no publicly known persona that would cause anyone to hate her, what would government Defendants' do with the Plaintiff,
who now has a persona, created by Defendant Daily News, that the public has been taught to hate? Plaintiff believes that Defendants'
isolating is not just to stop her from talking. Defendants' desire is to stop her from talking permanently, and Plaintiff
is terrified. News article of mentally ill woman Esmin Green is attached as Exhibit 56. *****177)*****This Court strongly
advised Plaintiff not to present it with frivolous issues, including Plaintiff's former unintentional – but wrong habit
of using irrelevant causes of action to mask legal issues for which this Court lacks subject matter jurisdiction. Plaintiff
has provided this Court with proof – including proof from Defendant NYSUSC's Appellate Division's First and Second Judicial
Departments, of her due diligent attempts to obey this Court's order. Plaintiff has gone so far as to read the Complaint of
Disability Advocates, Inc., researching its cited statutes and case law to determine relevance, if any, to Plaintiff's situation,
and then to copy Disability Advocates, Inc.'s writing style to ensure that Plaintiff's Verified Complaint achieve judicial
muster and does not anger this Court and waste its limited resources again. Plaintiff strongly asserts that she has succeeded.
Plaintiff prays that this Court's past experiences with the mentally disabled Plaintiff are not misconstrued as disrespect
on the part of the Plaintiff, but as Plaintiff's desperation to be treated justly. *****178)*****Not all victims of civil rights violations are equipped
to defend themselves in court. The ultimate victim of civil right violations is a person who has been murdered. She cannot
defend herself; however, out of respect and honor of the former life that was lost – and out of respect for the victim's
due process rights that were violated, laws are established to publicly proclaim that the dead victim continues to have rights
that courts must protect and enforce. If the dead victim was also a party to a divorce, the court that adjudicated her divorce
would still have to seal her records from public view to ensure that the dead victim's right to privacy of her records is
protected and enforced. Why should this Court not treat as equal the rights of the mentally ill Plaintiff? In the U.S. Supreme
Court case Haines V. Kerner, 404 U. S. 519 (1972), Petitioner Menard – a person convicted by the State of Illinois
as a felon, commenced this action against the Governor of Illinois and other state officers and prison officials under the
Civil Rights Act of 1871, 17 Stat. 13, 42 U.S.C. § 1983, and 28 U.S.C. § 1343(3), seeking to recover damages for
claimed injuries and deprivation of rights while incarcerated. The Federal District Court dismissed Mr. Menard's complaint
and the U.S. Court of Appeals for the Seventh Circuit affirmed the Seventh Circuit's decision. The U.S. Supreme Court decided
against the Federal District's and U.S. Court of Appeals' decisions. The U.S. Supreme Court stated in its decision that “Whatever
may be the limits on the scope of inquiry of courts into the internal administration of prisons, allegations such as those
asserted by petitioner, 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.” Plaintiff begs this Court's mercy to allow her to offer proof of her allegations. *****179)*****The cumulative effect
of Defendants' attack on the Plaintiff is that, except when Plaintiff goes to twice monthly therapy sessions, once per month
sessions with her psychiatrist and weekly visits with her ICM worker, Plaintiff spends the vast majority of her time alone
and afraid that attempts at making friends will expose her to more negative attention as psychotic with anti-Semitic features.
The Plaintiff is, for the most part, just as Defendants planned – alone, very lonely with intermittent feelings of rage,
worthlessness and hopelessness, an exacerbation of Plaintiff's preexisting mentally illness. *****180)*****This
Court must enforce its own mandate – and the mandate as expressed in Olmstead v. L.C. It must find Defendants guilty
of civil and criminal contempt, require the Defendants to obey, and appoint a federal monitor to ensure government Defendants'
compliance. This Court must, as a matter of law, require the criminal investigation of the Defendants with regard to Defendants'
violation of 18 U.S.C. §241, 18 U.S.C. §242, 18 U.S.C. §1341 and 18 U.S.C. §1346 and facilitate their
arrest. Finally, this honorable Court, in its mercy, must expedite Plaintiff's requests so as to bring Plaintiff's Defendant-induced
nightmare to an end. *****WHEREFORE,
Plaintiff prays for the following: *****a)*****Federal
monitor to ensure that Defendant NYSUSC's courts treat Plaintiff fairly; *****b)*****Federal monitor to oversee the federal and New York State
criminal investigation of Defendants with regard to Defendants' violation of 18 U.S.C. §241, 18 U.S.C. §242; 18
U.S.C. §1341, 18 U.S.C. §1346; NYS Pen. §105.05, conspiracy, NYS Pen. §115.00, criminal facilitation with
regard to Defendant law firms' commission of NYS Pen. §210.15, perjury in the first degree and NYS Pen. §135.65,
coercion in the first degree; and with regard to Defendant law firms' employees commission of perjury; *****c)*****to require Defendant
Daily News to remove the news article at its website http://articles.nydailynews.com/2009-11-05/local/17938323_1_supreme-court-judge-criminal-court and similar sites maintained overtly, covertly, directly and indirectly by Defendant Daily News in their entirety,
and to refrain from publicly referencing or having others covertly, directly or indirectly refer to any portion of Defendant
Daily News' article as Defendant Daily News publicly admitted that courthouse sources of Defendant New York State Unified
Court System illegally disclosed nonpublic, confidential information concerning Plaintiff's marriage and Plaintiff's mental
illness, in violation of 22 NYCRR §50.1(D), 22 NYCRR §100.3(B)(8) and 22 NYCRR §100.3(B)(11) which prohibits
judges and courthouse personnel from disclosing or using, for any purpose unrelated to judicial duties, nonpublic information
acquired in a judicial capacity, or from publicly commenting on a pending or impending case, so as to prevent Defendant Daily
News from continuing to use its website to criminally victimize the Plaintiff; *****d)*****an order requiring that Defendants promptly take such steps
as are necessary to enable Plaintiff to receive outpatient services (including attendance on continuing day treatment programs
and psychiatric clubhouses) in the most integrated setting appropriate to the Plaintiff's needs so that the Plaintiff does
not continue to sit at home alone and lonely; *****e)*****an order to ensure that governmental Defendants OMH, DOH and their not-for-profit instrumentalities
that receive governmental funding for the purpose of never against engage in any form of blacklisting the Plaintiff from any
federally- or state-funded outpatient mental health treatment facility. *****f)*****a federal monitor to ensure that Defendants obey the law; *****g)*****an award of monetary
damages in the amount of $100,000,000.00 or an amount that is acceptable to this Court to enable the Plaintiff to relocate. *****h)*****such other relief as
to this honorable Court seems just and proper. Dated: Brooklyn, New York June 6, 2011 * CHERYL D. UZAMERE APPEARING PRO SE 
_______________________ By: Cheryl D. Uzamere
1209 Loring Avenue Apt. 6B Brooklyn, NY 11208
(347) 985-2495 _______________________ In Re: Aimster
Copyright Litigation, 334 F.3d 643: Willful blindness is knowledge . . . One who, knowing or strongly suspecting that he is
involved in shady dealings, takes steps to make sure that he does not acquire full or exact knowledge of the nature and extent
of those dealings is held to have a criminal intent, United States v. Giovannetti, 919 F.2d 1223, 1228 (7th Cir.1990), because a deliberate effort to avoid guilty knowledge is all that the law requires to establish a guilty
state of mind. United States v. Josefik, 753 F.2d 585, 589 (7th Cir.1985); AMPAT/Midwest, Inc. v. Illinois Tool Works Inc., 896 F.2d 1035, 1042 (7th Cir.1990) ("to know, and to want not to know because one suspects, may be, if not the same state of mind, the same
degree of fault) Plaintiff respectfully asks this Court to note that
included in the documents that USCIS provided Plaintiff regarding Ehigie Edobor Uzamere's identity is correspondence containing
immigration files nos. A35 201 224 (associated with Ehigie Edobor Uzamere, date of birth December 31, 1960 and A24 027 764
(associated with “Godwin Ehigie Uzamere”, date of birth “June 1, 1955”). INA's correspondence containing
file no. A24 027 764 was forwarded to Allen E. Kaye, Esq. CPLR §2001.
Mistakes, omissions, defects and irregularities. At any stage of an action, including the filing of a summons with notice,
summons and complaint or petition to commence an action, the court may permit a mistake, omission, defect or irregularity,
including the failure to purchase or acquire an index number or other mistake in the filing process, to be corrected, upon
such terms as may be just, or, if a substantial right of a party is not prejudiced, the mistake, omission, defect or irregularity
shall be disregarded, provided that any applicable fees shall be paid. CPLR
§2102. A clerk shall not refuse to accept for filing any paper presented for that purpose except where specifically directed
to do so by statute or rules promulgated by the chief administrator of the courts, or order of the court. (D) Disciplinary Responsibilities. (1) A judge who receives information indicating a substantial
likelihood that another judge has committed a substantial violation of this Part shall take appropriate action. (2) A judge
who receives information indicating a substantial likelihood that a lawyer has committed a substantial violation of the Code
of Professional Responsibility shall take appropriate action. (3) Acts of a judge in the discharge of disciplinary responsibilities
are part of a judge's judicial duties. 22 NYCRR §50.1(D.) Court
employees shall not disclose any confidential information received in the course of their official duties, except as required
in the performance of such duties, nor use such information for personal gain or advantage. 22 NYCRR §100.3(B)(8) – A judge shall not make any public comment about a pending or impending proceeding
in any court within the United States or its territories. The judge shall require similar abstention on the part of court
personnel subject to the judge's direction and control. This paragraph does not prohibit judges from making public statements
in the course of their official duties or from explaining for public information the procedures of the court. This paragraph
does not apply to proceedings in which the judge is a litigant in a personal capacity. 22 NYCRR §100.3(B)(11) A judge shall not disclose or use, for any purpose unrelated to judicial duties, nonpublic
information acquired in a judicial capacity.
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Mentally disorganized Jewish litigant Rebecca G. Yohalem sued governmental defendants
for one billion dollars without specifying any federal torts that were committed by the defendants. Jew-biased Joanna Seybert
prepared an order recommending that Rebecca Yohalem contact William M. Brooks, Director, Civil Rights Litigation Clinic,Touro
College, Jacob D. Fuchsberg Law Center. No Jew-biased judge ever made any attempt to refer to any PAIMI program.
Jew-biased Nicholas G. Garaufis renders a memorandumless decision that does not
incorporate any portion of the FRCP. He then conspires with employees of the U.S. Marshal Service, the U.S. Department of
Homeland Security, the New York State Office of Mental Health and the New York City Health and Hospitals Corporations to commence a
witch hunt that falsely accuses me of 18 USC §115, threatening federal employees to imply that I am so violent
and mentally imcompetent that I should never be able to file any complaint any federal court.
Midrash Rabbah/B'Reshith (Soncino), page 293 R(abbi) Huna also said in R(abbi) Joseph's name: You have prevented me from doing something in the dark (sc. cohabitation),
therefore your seed will be ugly and dark- skinned
Babylonian Talmud/Tractate Sanhedrin, Folio 108b, footnote 34 Our Rabbis taught: Three copulated
in the ark, and they were all punished -- Ham was smitten in the skin. Footnote 38 reads: I.e., from him descended Cush (the negro) who is blackskinned.
Artsot Ha-Hayyim, pages 52a, 52b "the reason Abraham Lincoln
was killed was because he freed the blacks. This is also the reason why Kennedy
was killed, because he was good to the blacks. This will
be the fate of any who adopt a progressive attitude towards blacks, because they are meant to be enslaved."
Informing on Fellow Jews who Commit Crimes:
Mesira in
Modern Times
Rabbi Michael J. Broyde
Even though Jewish law expects people to observe the laws of the
land, and
even imposes that obligation as a religious duty, the Talmud
recounts - in a number of places - that it is prohibited
to inform on Jews to
the secular government, even when their conduct is a violation of secular law
Letter created by Denis P. McGowan of the U.S. that falsely accuses me of 18 USC §115
Psychiatric Treatment Plan that includes lie that I threatened
CMS call center employees with death
Immigration Sponsorship form that was falsified by ex- husband Ehigie E. Uzamere and
his corrupt Jewish attorneys, Allen E. Kaye and Harvey Shapiro
Ex-husband Senator Ehigie Edobor Uzamere and his attorney/nephew Osato E. Uzamere
deny Ehigie's identity; refer to me as mentally incompetent and ask for the New York State Supreme Court to dismiss
my divorce action based on my having a mental illness.
Corrupt Jewish attorneys Allen E. Kaye, Harvey Shapiro, Jack Gladstein, corrupt
Jewish judges Michael Gerstein, Jeffrey S. Sunshine and Arthur M. Schack and corrupt Jewish staff writer Scott Shifrel of
the Daily New conspire to lie about my ex-husband's identity and my state of mind.
Left to rot in Rikers Island for 33 days. . .
. . .for a crime for which I was found not guilty
T. Diane Cejka, former director of the FOI/PA Division of the U.S. Citizenship and Immigration Service
confirms that Nigerian Senator Ehigie Edobor Uzamere was my husband and Tara's father
Rachel McCarthy, Bar Counsel for the U.S. Citizenship and Immigration Service confirms
that Nigerian Senator Ehigie Edobor Uzamere was my husband and Tara's father
Tara A. Uzamere, the mentally competent child of the marriage and registered professional nurse swears
that Nigerian Senator Ehigie Edobor Uzamere is her father
Corrupt Jewish judge Jeffrey S. Sunshine and corrupt judge Matthew D'Emic adjudge that Nigerian
Senator Ehigie Edobor Uzamere was my husband and is Tara's father
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