In the case Argro v Osborne in the U.S. District Court for the Northern District of New York, attorney Woodruff Carroll submitted a Memorandum of Law where he claimed:
1) that MY suspension in state court was the result of my own AND MY HUSBAND's civil rights lawsuits against political figures of The State of New York and the U.S. District Court for the Northern District of New York (including David Peebles):First, you will not find any lawsuits of political figures as the basis of my suspension in the order of suspension though, raising a question - how Mr. Carroll came upon such interesting knowledge, coincidentally after an ex parte hearing before David Peebles (one of the political figures I sued), who sealed the transcript of the ex parte hearing?
Such a suspension would raise clear political persecution and motivation and would be a 1st Amendment issue that I would immediately addressed - but my civil rights litigation against the "political figures" in the State of New York and NDNY was NOT mentioned as the basis for my disciplinary proceedings or suspension, so I had no notice that the underlying cause of disciplinary proceedings against me is political.
Second, my husband filed several lawsuits pro se, without my participation - Neroni v Coccoma, Neroni v Mayberger, so Mr. Carroll's claim that I was suspended for my husband's civil rights litigation raises clear due process issues.
Mr. Carroll also married me to another man - a Frank Neroni.
2) that, even though Attorney Carroll characterized my civil rights lawsuit that were allegedly the basis of my suspension as "crackpot", "sour grapes" and frivolous, attorney Carroll never read those lawsuits and doesn't know what is in those allegedly frivolous lawsuits:
4) that David Peebles would have been very upset if the Plaintiffs did not settle the case (and instead proceeded to trial)
5) Moreover, attorney Carroll submitted to the court an Affidavit where he listed issues discussed by David Peebles in an ex parte hearing on June 3, 2016 (after his term expired), and those issues included issues of Peebles' misconduct that I put into my motion to recuse (which is still pending):
And, David Peebles quickly sealed the evidence of David Peebles discussing two motions involving me,
1) Dkt. 112 - my motion to recuse, with a returnable date of June 17, 2016, which was NOT referred to Peebles by court order, and
2) an ex parte motion of Defendants for an anti-filing injunction against me personally
by sealing the transcript of such an ex parte oral argument -
while attorney Carroll who the press claimed "lacks a filter" emerged out of that ex parte hearing in front of David Peebles who I sued in 2014, with a wealth of knowledge, not derived from reading the cases (because Carroll claimed under oath he did not read those cases) that I was suspended because I sued political figures of the State of New York and of the NDNY court - and that includes Peebles himself.
Where else the no-filter attorney Carroll could get the knowledge that my suspension was based on my lawsuits against political figures in New York and NDNY court?
Certainly not from my order of suspension in state court - it has not a word about it.
Certainly not in any records of the disciplinary proceedings - the prosecutors did not bring this issue, the court did not mention that issue, and prosecutors denied political motivation of my disciplinary proceedings when I raised that issue.
The only reasonable source is David Peebles.
And, of course, this new evidence gives me a basis to seek re-opening of my disciplinary proceedings.
Which, of course, I will do.
And will report it on this blog.
Stay tuned.
And, David Peebles quickly sealed the evidence of David Peebles discussing two motions involving me,
1) Dkt. 112 - my motion to recuse, with a returnable date of June 17, 2016, which was NOT referred to Peebles by court order, and
2) an ex parte motion of Defendants for an anti-filing injunction against me personally
by sealing the transcript of such an ex parte oral argument -
while attorney Carroll who the press claimed "lacks a filter" emerged out of that ex parte hearing in front of David Peebles who I sued in 2014, with a wealth of knowledge, not derived from reading the cases (because Carroll claimed under oath he did not read those cases) that I was suspended because I sued political figures of the State of New York and of the NDNY court - and that includes Peebles himself.
Where else the no-filter attorney Carroll could get the knowledge that my suspension was based on my lawsuits against political figures in New York and NDNY court?
Certainly not from my order of suspension in state court - it has not a word about it.
Certainly not in any records of the disciplinary proceedings - the prosecutors did not bring this issue, the court did not mention that issue, and prosecutors denied political motivation of my disciplinary proceedings when I raised that issue.
The only reasonable source is David Peebles.
And, of course, this new evidence gives me a basis to seek re-opening of my disciplinary proceedings.
Which, of course, I will do.
And will report it on this blog.
Stay tuned.
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