T. A., et al. v. Howard B. Leff, et al.
DueProcess
Is it error to impose judicial immunity when the pleadings detail that NYS Judge and sua sponta appointed Part 36 Fiduciaries acted without jurisdiction, acted criminally, engaged in quid pro quo agreements, and conspired to enrich themselves and take millions of dollars from divorced women and children by a pattern of racketeering?
QUESTIONS PRESENTED 1. Is it error to impose Judicial immunity, in a 12(b) dismissal, when the pleadings detail that NYS Judge and sua sponta appointed Part 36 Fiduciaries acted without jurisdiction, ©. : acted criminally, engaged in quid pro quo agreements, and conspired to enrich themselves and take millions of dollars (> $1,000,000’s) in property from divorced women and children by a pattern of racketeering ? Answer: YES , 2. Is it error to impose collateral estoppel and res judicata upon Federal Causes of action that were not litigated previously in Federal Court or State Court (namely the extensive ; pattern of racketeering and Constitutional Violations by the sua sponta Receiver appointments), to dismiss the Federal Lawsuits ? _ Answer: YES ; 3. Is it error to impose Rooker -Feldman to dismiss the Federal Causes of Action when the issues in the Federal Lawsuits were not litigated in State Court and the RICO enterprise still continues and illegally has $50,000 of Plaintiffs money in Defendant LEFF’S escrow account, Ordered by STEINMAN, for Defendant LEBER’s criminal defense? Answer: YES 4. Is it error to impose the Domestic Relations Exception to a Federal Complaint which does not request relief to overturn custody, equitable distribution, child support, but requests _ relief from Post Judgment Receiverships, which a RICO enterprise was formed to take . over $2.5 million dollars in the T.A. v. Leff et al. matter and continued into the Kramer v. Dane et al. taking over $1 million and Due Process rights, by a pattern of racketeering ? Answer: YES 5. Is it error to whitewash what is contained in the Federal Complaints and assert facts that are not presented in the Federal Complaints to create a firewall to prevent access to the Courts, and thereby continue the targeting of women and children in NYS by the ongoing RICO enterprise? ; . Answer: YES 6. Is it error to ignore the consolidation requests, error to deny any opportunity to amend the : complaints, error to deny poor person relief, after the Defendants took millions of dollars in assets from all Plaintiffs by Constitutional violations, a pattern of Racketeering and quid pro quo enrichments? Answer: YES : . i 5 4 i