`
`IN THE SUPREME COURT OF THE UNITED STATES
`
`Sororazam Bethune - Petitioner
`
`VS.
`
`MTA Long Island Bus - Respondent.
`
`PETITIONER'S REPLY TO DEFENDANTS
`
`OPPOSITION BRIEF
`
`PETITION FOR WRIT OF CERTIORARI
`
`Prose
`fne.
`YMCA-Samaritan Village, Van Siclen Shelter
`89-25 Parsons Blvd., No. 534
`Jamaica, New York 11432
`Tel. No.: 516-423-0608
`
`
`
`QUESTIONS PRESENTED
`
`Obstruction of Justice during Nov. 5,
`2015 Liability Trial by Sup. Ct., NC.
`
`Mis-Representation, Legal Malpractice;
`By my attorney not filing papers on time, and
`dismissing my case for untimely filing of:
`"OSC", Untimely Appeal from the 4/22/2016
`Judgment.
`
`Facts of my Permanent Irreversible
`Debilitating Injuries, Surgeries, Loss of
`Abilities, Real Estate Business and Real
`Estate Income; Hope and Motivation; Pain
`and Suffering; and
`
`FEDERAL QUESTION: There is OCNFLICT
`between Court of Appeal's Decision dated
`Sept. 8, 2016 and App. Div. 2ndJ.D. Decision
`dated June 30, 2016; specifically the Court of
`Appeals Decision dated Sept. 8, 2016 stating:
`
`"Motion, insofar as it seeks leave to
`appeal from the June 2016 Appellate
`Division Order, dismissed upon the
`Order does Not finally Determine the
`Action within the Meaning of the
`Constitution.".
`
`MTA did not file Answer on time in Nov. 2012;
`MTA filed answer TWO years later in Nov.
`2014; Armienti et al. backdated it to Nov. 2012.
`
`MTA did not produce the Latino Driver who
`injured, crippled me life time; affected my
`children detrimentally. MTA / MTA attorneys
`could have produced the Latino Driver who
`injured me, but manipulated, Mis-represented
`facts decided Not to, in order to dismiss my
`and
`surgeries
`injuries,
`permanent
`disabilities.
`
`ii
`
`Nor
`
`
`
`TABLE OF CONTENTS
`JURISDICTION
`There is a CONFLICT between the Court of Appeals'
`September 8, 2016 Decision with respect to App. Div.
`2nd J.D. Decision dated June 30, 2016.
`
`A. The Clerk at Court of Appeals, Albany, NY, advised
`me that I could make a Motion to the United States
`Supreme Court in Washington D.C.
`
`II. CONSTITUTIONAL AND STATUTORY
`PROVISIONS INVOLVED
`Obstruction of Justice.
`
`Legal Malpractice by my attorney.
`
`Permanent Irreversible Disabilities.
`Federal Question (Conflict).
`MTA did not file "Answer" in 2012.
`MTA did not produce the Latino Driver.
`
`
`
`
`
`
`
`
`
`PAGE
`
`1
`
`2-3
`
`3
`
`3
`
`4
`
`4
`
`5
`
`5
`
`6
`
`6
`
`III. STATEMENTS OF FACTS
`
`Justice Angela lannaci's Order Dated July 6,
`2015; Entered July 8, 2015 Denied Def.'s Motion
`for Summary Judgment, found the Driver "Negligent".
`
`OBSTRUCTION OF JUSTICE DURING NOV. 5,
`2015 ]ABILITY TRIAL: Approx. 2.5 Hours of Threats.
`
`Michael Paglino's Jan. 7, 2016 Affm. Par. 26.
`
`Justice Feinman Disclosure Re MTA case when
`After years of Litigation Plaintiff passed away.
`
`Mr. Paglino using Vanessa Corchia's Slandering
`Strategy against injured plaintiffs.
`
`I was injured on Aug. 24, 2011 before MTA L.I. Bus
`Discharged MTA on Dec. 30, 2011.
`
`Stuart A. Jackson, my attorney called me last week
`In April, 2016, told me that MTA had filed Money
`Judgment of $1200, told me I did not have to pay, and
`that he was going to file appeal from the Judgment.
`
`--------.
`
`Iii F
`
`3
`
`
`
`I. There is Question of Federal Law and Question of
`Law for this Court's Review of Petition and Motion.
`
`J. Michael Paglino is making manipulative, false,
`misleading statements; and not disclosing my
`communication with the App. Div. 2nd J. D.
`Regarding my. attorney's Release.
`
`K. My daughter was represented by same attorney in
`Her Injury cases at:
`"NUMC" municipality hospital;
`Brunswick Hospital,
`both cases dismissed in Sup. Ct. N.C., and at
`App. Div. 2nd J.D. due to Mis-representation.
`
`L. Michael Paglino in his Opposition Brief, Pg.: 14
`Degrading a person with disabilities:
`"This is simply, a matter of Unsuccessful Litigant".
`
`M. Eardrum Rupture, Tinnitus by ENT, Dr. Monhian .
`Responding to Michael Paglino Slandering me.
`
`N. Dr. Monhian's Medical Records Admitting Negligence.
`
`0. Dr. Monhian's Attorney, Denise Buda stated:
`"Your only Remedy is to sue your attorney for legal
`Malpractice".
`
`Eviction Case: Mayfield no longer funding; I offered
`To Court and Landlord to place a Lien against my
`Lawsuit for owed amount plus interest, and let me
`and my daughter stay for Lease Term, but Landlord
`did not agree.
`
`Defendant's attorney in his Opposition Brief: Pg.: 11,
`states that Court of Appeals dismissed my case on
`Sept. 12, 2017. However, he manipulates and does not
`disclose to this Court that App. Div. 2nd J.D.'s Order
`dated August 17, 2017 (APPENDIX NO. 6) did not
`permit my Appeal to the Court of Appeals, and that
`Court of Appeals could not review my case 2' time
`Without Permission by App. Div. 21u J. D.
`IV. CONCLUSION
`
`7
`
`7
`
`8-9
`
`9
`
`9
`
`10
`
`10
`
`11
`
`11
`
`12
`
`L~
`
`
`
`APPENDIX INDEX:
`
`APPENDIX NO. 1:
`
`Michael Paglino's Affm. 01/07/2016: Par: 26:
`
`APPENDIX NO. 2:
`
`MARLO POLESE'S AFF. DATED DEC. 29, 2015.
`
`APPENDIX NO. 3:
`
`Vanessa Corchia Affirmations attached to Michael
`Paglino's Brief Opposition dated 04/05/2018 as
`APPENDIX Nos: 16 and 19.
`
`APPENDIX NO. 4:
`
`Stuart A. Jackson's Letter asking App. Div. 2nd J.D.
`for a Hearing which was rejected by the App. Div.
`2nd J.D,; and letters between App. Div.2dJ.D.,
`myself & Stuart A. Jackson re Discharge.
`
`APPENDIX: NO. 5:
`
`Affs. Dated June 30, 2017 Pg: 10; and July 16, 2017
`Pg: 5; asking Court to let us stay at the Apt. and
`place a Lien by Landlord for Months of unpaid
`Rent; and any future rent including Interest, but
`Landlord and Court did not agree.
`
`APPENDIX NO. 6:
`
`Appellate Division Second J.D. Dec. Dated July 17,
`Not Permitting Appeal to Court, of Appeal
`TABLE OF AUTHORITIES CITED
`
`CASES:
`
`PAGE NO.
`
`Justice Angella lannacci's Order Entered07/08/2015:
`
`3
`
`Zuckerman v. City of New York, 49 NY2d 557 [19801).
`
`Urquhart v New York City Transit Auth., 85 NY2d 828 [1995].
`
`I?A
`
`$
`
`
`
`STATUTES AND RULES:
`
`FEDERAL QUESTION: there is a CONFLICT between Court
`
`Of Appeal's Decision dated Sept. 8, 21016; and Appellate Div.
`
`Decision dated June 30, 2016 (Dismissing the Action due to
`
`Untimely Appeal) disregarding the fact that I was Mis-
`
`represented by my attorney. Court of Appeals stating:
`
`"Motion, insofar as it seeks leave to appeal from the
`June 2016 Appellate Division• Order, dismissed
`upon the order does not finally determine the
`action within the meaning of the Constitution."
`
`LAW QUESTION: my injuries were not resolvedbased on facts
`of my injuries; based on Mis-representation and Legal Mal-
`practice; based on having testified on Nov. 5, 2015- under stress
`having chest pains and head pressure, caused by Justice
`Feinman's threats before trial; I was forced to testify and not
`allowed to talk to my attorney when I asked court several
`times.; and based- on MTA not file Answer in 2012; Not
`Producing the Latino Driver who injured me
`
`Vi
`
`.' -----
`
`on
`
`
`
`I
`
`)
`
`IN THE SUPREME COURT OF THE
`UNITED STATES, WASHINGTON D.C.
`PETITIONER'S REPLY TO DEFENDANT'S
`BRIEF IN OPPOSITION
`
`I
`
`JURISDICTION
`
`The United States Supreme Court has Jurisdiction regarding my case and
`
`there is merit to review my petition and my motion. There is a Question of
`
`Federal Law.
`
`There is a CONFLICT between the Court of Appeals'
`
`September 8, 2016 Decision with respect to App. Div. 2nd J.D. Decision dated
`
`June 30, 2016 which dismissed my appeal due to Untimely Appeal, which
`
`was caused by my attorney, Stuart A. Jackson, Mis-Representing me. Court
`
`of Appeals, Albany, NYS, Decision Dated September 8, 2016 stated:
`
`"Motion, insofar as it seeks leave to appeal from the June
`30, 2016 App. Div. 2nd J.D. Order, dismissed upon the
`order does not finally determine the action within the
`meaning of the Constitution.".
`
`•
`
`A. The Clerk at Court of Appeals, Albany, NY, advised me that
`
`I could make a Motion to the United States Supreme Court
`
`in Washington D.C. I started filing Petition and Motion.
`
`MTA / MTA Attorneys did not produce the LATINO DRIVER who injured
`
`me, they produced a White driver, Mr. Epstein, he was not the driver who
`
`injured me.
`
`'
`
`APPENDIX NO. 2: MTA - Màrlô Pole si'sAFF. 12/29/2015.'
`
`
`
`3. MTA arg•ucd that since Mr. Greenidge, MTA Mgr. in charge of both incidents
`
`in 2011, and. the Latino Bus driver who injured me work for now "Viola"
`
`corporation that MTA could not produce them. BUT MTA produced .MR.
`
`Epstein who worked for MTA Long Island Bus during. 2011 until December,
`
`2011; and Mr. Epstein worked thereafter, Effective Dec. 30, 2011 worked for
`
`Viola Bus N.C. due to transition. Mr. Epstein during his EBT, testified that
`
`during 2011 until Dec. 2011, he worked for MTA Long Island Bus, and in
`
`Dec., 2011 when N.C. released MTA, formed its own "Viola" Corp., that he
`
`has been working for Viola Bus. Since Dec. 30, 2011. Mr. Epstein said that
`
`•
`
`he received a Letter from James Dunning, ESQ., Armienti, et al. to testify for
`
`at EBT and Trial for MTA.
`
`II. CONSTITUTIONAL AND STATUTORY
`PROVISIONS INVOLVED
`
`Obstruction of Justice during Nov. 5, 2015 Liability Trial by Sup. Ct., NC.
`
`Mis-Representation, Legal Malpractice by my attorney; untimely filing of
`
`"OSC", not filing Notice of Appeal from the 4/22/2016 Judgment.
`
`Facts of my Permanent Irreversible Debilitating Injuries, Surgeries, Loss of
`
`Hope, Real Estate Business and Income; Pain and Suffering.
`
`2.
`
`
`
`FEDERAL QUESTION: There is CONFLICT between Court of Appeal's
`
`Decision dated Sept. 8, 2016 and App. Div. 2'J.D. Dec. dated June 30, 2016;
`
`specifically the Court of Appeals Decision dated Sept. 8, 2016 stating:
`
`"Motimi, insofar as it seeks leave to appeal from the June 2016
`Appellate Division Order, dismissed upon the Order does Not
`finally Determine the Action within the Meaning of the
`Constitution.".
`
`MTA did nct file Answer in Nov. 2012 at Nassau County Clerk's Office. I
`
`was not served with MTA's Answer in 2012. Their Answer was not attached
`
`to any motion during period 2012 to 2014; MTA filed Answer two (2) years
`
`later in Nov. 2014; Armienti Et al backdated it to Nov., 2012.
`
`MTA did not produce the Latino Driver who injured, crippled me life time;
`
`affected my children detrimentally.
`
`'III. STATEMENT OF THE CASE
`
`B. Justice Angela lannaci's Order Dated July 6, 2015;
`Entered July 8, 2015 Denied Def.'s Motion for 'Summary
`Judgment, stated:
`
`"The Defendant has failed to establish its entitlement to
`judgment as a matter of law because it failed to present any
`evidence that the bus driver operating the bus at the time of
`the alleged incident was free of negligence (see Zuckerman v.
`City of New York, 49 NY2d 557 [19801). In any event, the
`plaintiff submitted sufficient evidence to create a triable issue
`as to whether her fall was caused by a sudden and violent
`jerking motion of the bus (Urquhart v New York City Transit
`Auth., 85 NY2d 828 [1995]. Accordingly, the motion is denied.".
`
`
`
`OBSTRUCTION OF JUSTICE BEFORE AND DURING
`NOV. 5, 2015 LIABILITY TRIAL:
`
`I asked three different times to talk to my attorney but court did
`not allow.
`
`In his affirmation, Jan. 7, 2016, Par:: 26, Michael Paglino
`states the following:
`
`.
`
`"26. In addition, during cross-examination, of the bus
`operator, Mr. Epstein, Plaintiff blurred out the following
`from where she was seated in the courtroom:
`
`.
`
`THE COURT: Hold on one second.
`THE WITNESS: Mr. Jackson? Mr. Jackson?
`Excuse me: Can I speak to my
`attorney?
`THE COURT: Not right now.
`THE WITNESS: Can I give him a Note?
`THE CLERK: Not Now. '
`
`EXHIBIT "C" at P. 92. ".
`
`APPENDIX NO. 1: Michael Paglino's Affm. Jan. 7, 2016: Par: 26:
`
`4. During the 2.5 hours threats made by Sup. Ct. Justice Feinman on Nov. 5,
`
`2015, after my attorney rejected Justice Feinman's low offer not consistent
`
`with my permanent irreversible injuries, Justice Feinman asked me and my
`
`attorney, Stuart A. Jackson, to go to his Chamber. Justice Feinman asked
`
`me about my real estate success. I was crying and told him that I had
`
`become very successful, that I loved real estate and I was planning to have
`
`my own real estate office hiring agents, expanding my business He said he
`
`liked that I worked hard and he added $10,000.00 at $100,000.00. My
`
`attorney rejected.
`
`Justice Feinman became furious started yelling at me:
`
`4.
`
`.
`
`..
`
`
`
`"Main, take the offer while you can. If you don't take it I
`make sure you don't get anything, I have the authority to
`dismiss your case even if Jury returns verdict for you. ".
`
`I was crying, having chest pains; Justice Feinman laughed:
`
`"Let me tell you about a case I had involving MTA, I was the
`trial Judge. The Petitioner was sitting on a chair. The jury
`returned verdict at $3 Million. Of course I told MTA to
`appeal. It took years for the App. Div. to make a decision
`reducing the Jury's amount to $1 Million. But by the time
`funds were ready for the plaintiff, he had died. He never
`collected the money. Listen to me carefully, take the offer
`or you are going to end up dead like that plaintiff.".
`
`5. It was not a laughing matter, my attorney was shaking his head and I was
`
`crying, having chest pains and head pressure, I felt horrible for that plaintiff
`
`who died due to years of litigation, sitting on a chair, :pain and suffering,
`
`financial problems, his family probably affected, which is the saddest of all.
`
`Mr. Paglino copying Vanessa Corchia's "Slandering"
`Method/Strategy in her motion to Court of Appeals to
`dismiss my appeal to Court of Appeal; in his Opposition
`• Brief, Pg. 20, Par. 1 states the following slandering stated
`• by Vanessa COrchia in her Motions to Court of Appeals and
`Appellate Div. 211d J D stating
`
`"Unfortunately, Plaintiff is no
`stranger to the litigation system.".
`
`Michael Paglino's Brief Opposition dated April 5, 2018;
`Appendix No. 19: Vanessa Corchia, Esq., Partner at Armienti et
`al., Vanessa Corchia's Affm. Pg. 14, Par.' 49, states the same:
`
`"Unfortunately, Plaintiff is no'
`stranger to the litigation system.".
`
`APPENDIX NO. 3: Vanessa Corchia Affirmations and Michael
`Paglino's Brief Opposition dated 04/05/2018.
`
`5
`
`'
`
`''
`
`'•
`
`',•,,
`
`i(
`
`
`
`6• Arrtheti, EtAl unethically keep Slandering me just like they slander many
`
`other injured plaintiffs preying for them to dismiss the case without liability.
`
`They are not Implementing Justice, they are against justice. I am hoping
`
`that the United States Supreme Court Washington D.C. will review my
`
`Petition and Motion and Justice will prevail.
`
`7. Vanessa Corchia, Esq. also Partner at Armienti Law firm for years worked
`
`at Appelliate Division 2nd J.D. and now she works for Armienti, et al.
`
`She
`
`kept slandering me just like Michael Paglino (Copying her slandering me in
`
`his Brief Oppossition); accusing me of Threatening MTA Attorneys? As far as
`
`I know 1 aIn the only injured crippled individual here having lost everything,
`
`I am the only loser here. 'I don't see Vanessa Corchiaoi' Michael Paglino
`
`with injuries, pain and suffering. I don't understand what they mean by
`
`stating to Court of Appeals and Appellate' Div. repeatedly that I am
`
`91
`
`targeting MTA and MTA attorneys. If anyone being targeted is me having
`
`permanent injuries, crippled in life, having lost everything, not them.
`
`G. I was injured by MTA Long Island Bus on August 24, 2011,
`Before MTA Long Island Bus ceased Operations as of Dec.
`31, 2011; I was injured by MTA Long Island Bus.
`
`APPENDIX NO. 2: MarIo Pólesi, MTA Internal Attorney Aff.: Dec.. 29, 2015.
`
`'H. My attorney then, Stuart A. Jackson, 'called me last week
`in April of 2016, telling me that MTA had filed, money
`judgment of $1200, he said I didn't have to pay, that he was
`going to file appeal from Judgment.
`
`I 0a
`
`
`
`8. He did not file, he dismissed my Permanent injuries, pain, suffering. With
`
`respect to Order to Show Cause, (to set aside Jury's Verdict Coitt.rary to the
`
`wight of the Evidence for the interest of Justice CPLR 4404; Post Trial, my
`
`attorney had no idea about OSC after Jury's Verdict and 15 day limitation
`
`I. There is Question of Law for this Court's Review; there
`is Question of Federal Law for this Court's Review.
`
`9. The Sup. Ct. dismissed my injuries, and then App. Div. 2nd J.D. permitted me
`
`to file Untimely Appeal due to Mis-Representation; giving me a NEW
`
`DOCKET NO.; 2016-11032. I filed untimely notice of Appeal on Sept. 18,
`
`2616; an was informed I had six (6) months tofilé my Brief. Thereafter,
`
`since 'Vanessa Corchia, objected and App. Div. dismissed my Appeal;
`
`APPENDIX NO. 6: App. Div. 2nd J.D. Order dated AUG. 17, 2017.
`
`J. Michael Paglino is making manipulative, false, misleading
`statements not disclosing my communication with the App.
`Div. 2nd J.D. which communication (letters) MTA attorneys.
`were sent copies of same:
`
`10.1 called the Deputy Clerk at Appellate Division 2nd J.D. asked him if 'I could
`
`rele'ae my attorney. 'I also 'asked him to watch the video tape of the 18t MTA
`
`case (V11/2,011) when thy left foot Was injured, that during the Oral
`
`Arguméit Stuart A. Jackson, was making inappropriategestures and shapes
`
`with his 'hands towards the Justices getting then angry.
`
`'...
`
`'..
`
`:'
`
`.
`
`
`
`11.During the Oral Arguments of all Cases, we were called last and he was
`
`angry and was being totally inappropriate and disrespectful to the four
`
`Justices, Lwas asking him to please not point fingers or make shapes with
`
`his fiuigers towards the Four (4) Justices, but he was out of control and angry.
`
`The Appellate Div. 2nd J.D. Deputy Clerk then directed me as to how to
`
`discharge my attorney, told me had to send letters by mail to App. Div. 2'
`
`J.D. to both my attorney and to App. Division releasing my attorney.
`
`Stuart A. Jackson, my attorney sent a letter back to the Appellate Div. 2I
`
`J.D. stating that he could understand why I was discharging him. But that
`he wanted to have a hearing on my daughter's 2 Cases at App. Div. 2fid J.D.
`
`-
`
`asking for a hearing to keep my daughter's cases; he knew I had power of
`
`attorney and Healthcare proxy signed by my daughter, executed by an
`
`attorney, designating me as her authorized agent/representative
`
`APPENDIX NO. 4: Letters/ Communication Re: I Attorney Release
`
`K. My daughter's 2 Injury eases: Nassau County, NY, against
`"NUMC" hospital and "Brunswick Hospital were both
`dismissed at Sup. Ct.; App.Div. 2uJ.D. for Legal
`Malpractice.
`
`(i) Tessa Bethune v. Nassau University Medical Center Hospital
`('NUMC") Municipality Hospital; lApp.Div. 2nd J.D. Docket No.:
`2015-07566: and Sup. Ct. Index No.: 010750-14 filed inNov. 1,
`the injuries happened during June 20, 2014 to July,
`2014 -
`2014, involving attack, overmedication. Stuart A. Jackson did
`
`8
`
`'cr1
`
`
`
`not know that "NUMC" was a municipality hospital and did not
`file a. Notice of Claim, he filed Summons and Complaint.
`
`(ii) Tessa Bethune v. Brunswick Hospital; . involving brain injury
`and cervical sprain - Stuart A. Jackson, Esq. did not open the
`Opposition Papers from the Hospital Attorneys, did not
`respond on time several times, and the Sup. Ct. Justice
`dismissed the Case; I appealed. on behalf of my daughter. It
`was dismissed at. App.. Div. since Stuart A. Jackson, did not
`appeal properly, did not communicate with Hospital attorneys.
`
`APPENDIX NO. 4: Stuart A. Jackson's Letter asking App. Div. 2nd
`J.D. for .a Hearing which was rejected by the App. Div. 2nd J.D: and
`letters/ Communication with App.Div.2nd J.D. re Attorney Discharge.
`
`L. Defendant's Attorney, Michael Paglino in his Opposition
`Brief; Page: 14, Degrading a Disabled Person, by stating:
`
`•
`
`"This is simply a matter of an Unsuccessful litigant
`seeking to avail herself of further appellate review
`for what she perceived a wrongs committed
`against her, but which were not established.".
`
`M Sororazam Bethune V. Mónhian, Nathan, MD: This is the
`first time I was injured in my life and since Michael
`Paglino unethically gathering my injuries to dismiss my
`case again, so I have to explain:
`
`14.1 had Earache, visited Dr. Monhian on July 2, 2010. He looked very tired,
`
`and he was busy talking to two female Re Cosmetic Plastic Surgeries; yelled:
`
`"Who gave you my name, I don't know you" in a negative
`manner. I said: "Mitra, your client, she is a Jewish Real
`Estate Broker in Great Neck." He said: "Oh yes I treated her
`daughter".
`
`15.He examined my right ear said thresvas no infection, he examined my left
`
`ear, when he pushed the medical equipment into my left ear too far, and
`
`caused excoriating pain, due to which I Instantly screamed due to
`
`9
`
`, (y
`
`
`
`excruciating pain affecting my brain awfully crying so loud that all the
`
`assistant came to the examining room immediately. Same day, July 2, 2010
`
`Dr. Monhian gave me a Drop medication (which I found out months after
`
`injuries that it had been prohibited by FDA not to put the drop inside the ear
`
`for it could cause permanent injuries, FDA advising Doctors and healthcare
`
`professionals to warn patients that it was for external use not internal use.
`
`16. On Oct. 1, 2010 suddenly there was an extreme high impact in my left ear it
`
`closed to the outside world suddenly, and I had High Pitch sounds of Cricket
`
`sounds, wires intercepting sounds, water fall sounds, which were very
`
`disturbing. I kept walking up and down my apt. trying to figure out these
`
`disturbing sounds. I was crying, I could not hear from my left ear.
`
`N. Dr. Monhian in his Medical Records submitted to Courts
`dated October 21, 2010 states:
`
`"Hearing Loss, Tinnitus in left ear for Last Three weeks".
`
`17.Admitting I was injured three months after his treatment / prescription use
`prescribed on July 2, 2010; injured under his NEGLIGENT Care.".
`
`0. DENISE BUDA, ESQ.; PARTNER, Representing Dr. Nathan
`Monhian, MD, during our last Tel. Conversation told me:
`
`"Your only Remedy' is to sue your attorney for legal
`malpractice.".
`
`I TOLD MS. DENISE BUDA, ESQ., PARTNER:
`
`"STUART A. JACKSON WAS NOT OK, BUT
`HE DID NOT INJURE ME, DR. MONHIAN DID".
`
`10
`
`
`
`Sororazam Bethune v. Shelton Properties, CT I have stated
`previously to this Court that Mayfield Funding stopped
`helping me with my expenses including Rent effective
`December, 2016. I still had funds and I paid substantial
`security at Lease 'Signing renting the" two bedroom 2 bath
`Apt. 1' was negotiating- with Mayfield. 'to fund my cases for
`year 2017. I paid $4,540.00 two months security and one
`month rent for Feb. at $2,270.00. I ran out of funds.
`18. My. daughter was very upset due to eviction, crying, not having a place to
`live. She was hospitalized repeatedly, at Belleview 09/12/2017-10/25/2017;
`
`NW Medical Ctr: 11/12/2017-11/21/2017; Westchester Prespetarian Hospital
`
`in White Plains, NY: 11/22/2017-12/7/2017; South Oak Hospital: 12/13/2017-
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`Present (My daughter was transferred by South Oak Hospital to Pilgrim
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`State Hospital March 13, 2018-Present, she is at Pilgrim now, and they'll be
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`transferring her to a Community Residence if I don't provide a Lease" for
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`them soon I have a NYC partial Voucher but buildings require full voucher.
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`APPENDiX: NO. Th Affs. (Pages) Dated June 30.200 Pg: 10; and July 16, 2017 Pg:
`5; asking Court to let us stay at the Apt, and place a Lien b.yjAndlord for Owed
`Rent plus interest against my lawsuit.
`
`Def.'s Attorney in his Opposition Brief states on Page '11
`that Court of Appeals dismissed my case on Sept. 12, 2017.
`However, Michael Paglino as usual manipulating facts, he
`does not explain that the Appellate Div. 2nd J. D. in its Aug.
`17, 2017 Order did not Permit Court of Appeals to accept
`my Appel; Court of Appeals' 09/12/2017 Dec. rejected my
`Appeal.
`
`.
`
`'.
`
`APPENDIX NO. 6: Appellate Division Second J.D. Dec. Dated AUGUST
`17, 2017 Not Permitting Appeal from Court of Appeals.
`
`11
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`
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`IV. CONCLUSION
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`I don't understand why I was injured repeatedly I've been searching for answers in
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`my mind and I cannot find any answers. I did not do anything wrong to deserve
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`crippling disabilities, pain, suffering. My heart falls apart when I think about the
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`detrimental impacts on my children, caused by these injuries and disabilities. I
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`wanted to help them succeed in life, my daughter's goal was to get her PhD, work at
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`a University. I am respectfully requesting the United States Supreme Court that
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`my petition and motion be granted for the interest of justice together with
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`appointment of an attorney to represent me for my permanent irreversible
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`debilitating injuries, surgeries, disabilities, pain and suffering, loss of everything;
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`with any other relief this court may decide just and proper.
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`DATED: May _—ql,2018
`New York
`
`By:___________
`Sororazam Bethune, Petitioner, Pro Se
`sarabethunerealty@yahoo.com
`516-423-0608
`YMCA - Van Siklen-Samaritan Village Shelter
`89-2& Parsons Blvd., No. 534
`Jamaica, New York 11423
`
`Sworn to before me this
`7t' ate of, /2'?GJ/' 2018
`
`YPUBIC
`
`TO: Michael Paglino, Esq.
`Armienti, DeBellis, Et Al.
`170 Old Country Road, No. 607
`Mineola, New York 11501
`
`I
`
`LYNN J MOESSNER
`Notary Public, State of New York
`No. 01M04970982
`Qualified in Nassau County
`My Commission Expires 8/20120-1-tf,
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`Word Count: 2999.
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`12
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`F'
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`