On November 12, 2015 the U.S. Court of Appeals for the 2nd Circuit has ruled that the U.S. District Court for the Northern District of New York is a party appellee in a case started by the NDNY court against my husband (without notice to me) based on two cases still pending in that court where my husband was counseled by me.
Thus, the court injected itself AS A PARTY into pending litigation, though a parallel proceeding, without notice to parties, counsel or presiding judges, and pre-judged to pending actions as frivolous.
Based on that, on November 16, 2015, I filed a motion to vacate and recuse any orders of the court made after the ex parte parallel proceeding was filed, and that was on October 20, 2014. I keep promising to publish the motion, and I will do it, I need a couple more days to do that, the motion is large. I downloaded the official (filed) version of it from Pacer and am preparing it for publishing, it will be published on this blog until Tuesday, I promise.
Since courts always require EXHAUSTIVE evidence in support of even APPEARANCE of impropriety regarding a judge, and since I was already punished by courts for not providing enough information to request a recusal (it is never enough, by the way), I provided enough now.
I provided two supporting affirmations, one with 34 documentary exhibits and the other with 9 documentary exhibits.
It is apparent that NDNY was disqualified from making any decisions pertaining my husband or myself after October 20, 2014 (the filing date of the ex parte parallel proceedings without notice to me as attorney of record for the Plaintiffs in Neroni v Zayas, 3:13-cv-127 and Neroni v Grannis, 3:11-cv-1485), and especially after November 12, 2015 when the 2nd Circuit branded the court as a party in related proceeding commenced before these two COUNSELED cases were adjudicated.
And, I already wrote on this blog that I was given a deadline until November 17, 2015 to file a Rule 11 motion for sanctions against top judges of the State of New York and its Attorney General. I ultimately did not file the Rule 11 motion because of the threats of NYS Attorney General (a defendant in the action where the Rule 11 motion was about to be filed) that I am practicing in federal court without a license (it was not true, I was on "active" status, but I preferred not to play with my liberty, since I learnt courts do not care about the law, and could incarcerate me anyway).
The result of my activity in federal court?
The State of New York suspended my law license on November 16, 2015, but backdated it to November 13, 2015, and then claimed in Neroni v Grannis that my motion to vacate and recuse is invalid because I filed it when I was suspended (I was not suspended at that time in federal court and was not notified of my suspension by the state court).
NDNY, Magistrate Peebles, having read information in the Nov. 16, 2015 motion pertaining to his own and his court's too-close-for-propriety relationships with powerful and rich law firms, as spelled out in supporting affirmations and exhibits, made two adverse decisions against me and my husband since the filing date of the motion, November 16, 2015.
Peebles ordered me to RE-file a document that was filed as Dkt. 68-2 (at the very top of the main Dkt. 68) because allegedly he did not want to "sift through" 620 pages filed (all affirmations and all exhibits included) to get to my affirmation in opposition to motion to compel discovery that became invalid once the court's involvement in the parallel proceedings as a party was revealed.
Peebles also allowed the State of New York to file a motion for sanctions against me - even though the State of New York did not follow the mandatory procedure for such a motion under federal Rule 11.
By the way, the rude manner in which Peebles treated me is revealing in and of itself.
Peebles would never dream of telling an attorney from a powerful law firm in such a disrespectful and disdainful manner that he does not have to "sift through" what was filed with the court.
Ok, I re-filed what Peebles asked to refile, and, since the NYS Attorney General tried to intimidate me with claims that I practice law without a license in federal court by proceeding on behalf of a client (my husband), I flat out printed out my "active" attorney status in NDNY court and attached it as an exhibit to the filing, so that there are no claims that I practiced law in federal court without a license.
That was on Friday night, November 20, 2015.
Guess what?
On Sunday morning my attorney status in federal court was already "suspended", and that is - without notice or opportunity to be heard, without notification to me, and before I was even served with the state order of suspension.
I must note that suspension in federal court is not automatic after suspension in state court. I know that for a fact because I represented an attorney who was disbarred in state court and was still served with a notice of petition in a federal court, giving the attorney an opportunity to oppose the suspension in federal court.
NDNY did not have authority to even suspend me, not after it injected itself, without notice to me, in a two pending counseled cases of my husband by pre-judging such cases as "frivolous" while they were still not so ruled by the assigned judge.
I guess, Peebles snapped when I pointed out to him, in my November 20, 2015 filing, that his two adverse orders to me based since I caught the court red-handed in filing ex parte proceedings against my husband in two pending counseled cases over my head.
Or, maybe, Peebles read my yesterday's blog about his own incestous relationship with his prior law firm that results in what appears to be case-fixing where state judges are sued.
In any event, after the court was caught, it snapped.
I will keep telling you how the "snapping saga" continues.
Stay tuned.
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