"If the judges interpret the laws themselves, and suffer none else to interpret, they may easily make, of the laws, [a shredded] shipman's hose!" - King James I of England, around 1616.

“No class of the community ought to be allowed freer scope in the expression or publication of opinions as to the capacity, impartiality or integrity of judges than members of the bar. They have the best opportunities of observing and forming a correct judgment. They are in constant attendance on the courts. Hundreds of those who are called on to vote never enter a court-house, or if they do, it is only at intervals as jurors, witnesses or parties. To say that an attorney can only act or speak on this subject under liability to be called to account and to be deprived of his profession and livelihood by the very judge or judges whom he may consider it his duty to attack and expose, is a position too monstrous to be entertained for a moment under our present system,” Justice Sharwood in Ex Parte Steinman and Hensel, 95 Pa 220, 238-39 (1880).

“This case illustrates to me the serious consequences to the Bar itself of not affording the full protections of the First Amendment to its applicants for admission. For this record shows that [the rejected attorney candidate] has many of the qualities that are needed in the American Bar. It shows not only that [the rejected attorney candidate] has followed a high moral, ethical and patriotic course in all of the activities of his life, but also that he combines these more common virtues with the uncommon virtue of courage to stand by his principles at any cost.

It is such men as these who have most greatly honored the profession of the law. The legal profession will lose much of its nobility and its glory if it is not constantly replenished with lawyers like these. To force the Bar to become a group of thoroughly orthodox, time-serving, government-fearing individuals is to humiliate and degrade it.” In Re Anastaplo, 18 Ill. 2d 182, 163 N.E.2d 429 (1959), cert. granted, 362 U.S. 968 (1960), affirmed over strong dissent, 366 U.S. 82 (1961), Justice Black, Chief Justice Douglas and Justice Brennan, dissenting.

" I do not believe that the practice of law is a "privilege" which empowers Government to deny lawyers their constitutional rights. The mere fact that a lawyer has important responsibilities in society does not require or even permit the State to deprive him of those protections of freedom set out in the Bill of Rights for the precise purpose of insuring the independence of the individual against the Government and those acting for the Government”. Lathrop v Donohue, 367 US 820 (1961), Justice Black, dissenting.

"The legal profession must take great care not to emulate the many occupational groups that have managed to convert licensure from a sharp weapon of public defense into blunt instrument of self-enrichment". Walter Gellhorn, "The Abuse of Occupational Licensing", University of Chicago Law Review, Volume 44 Issue 1, September of 1976.

“Because the law requires that judges no matter how corrupt, who do not act in the clear absence of jurisdiction while performing a judicial act, are immune from suit, former Judge Ciavarella will escape liability for the vast majority of his conduct in this action. This is, to be sure, against the popular will, but it is the very oath which he is alleged to have so indecently, cavalierly, baselessly and willfully violated for personal gain that requires this Court to find him immune from suit”, District Judge A. Richard Caputo in H.T., et al, v. Ciavarella, Jr, et al, Case No. 3:09-cv-00286-ARC in the U.S. District Court for the Middle District of Pennsylvania, Document 336, page 18, November 20, 2009. This is about judges who were sentencing kids to juvenile detention for kickbacks.

Saturday, December 9, 2023

A call for public attendance of an online court hearing to see why you can't get an honest and competent attorney to represent you in criminal, family state court and in civil rights cases: because attorneys are afraid to be dehumanized this way if the state who they sue too well takes their law licenses

People who would want to see a court hearing where a New York attorney Gerard N Misk of Ginsburg & Misk LLP will be arguing to the court that the loss of a law license (on political grounds in our case) must lead to a complete loss of a right to defend yourself in a property dispute, please, send me your emails by messenger or whatsup 1 843 240 7745.

Literally, attorney Misk has asked the court to deem all legal arguments coming from us, individuals with the collective experience of near a 1/2 century of practicing law, as bogus, and any evidence coming from us "incompetent", including public records, medical records, affidavits of us as witnesses and authenticators of photographic evidence made by us on our phones, and affidavits of our family members and a neighbor.

All because the State of New York was too afraid to keep us in practice because we litigated against the government for the people, including pro Bono, too well.

Here is the "hero", attorney Misk, attempting to litigate outside of the area in which he "concentrates" in his law firm (easement dispute):

And here is what this "hero" submits to the court:

Mind that he is asking the court to deep all of our evidence incompetent because he has failed to rebut it and is deemed to have admitted it on behalf of his alleged client.

But that is not all.

In the next paragraph, this "hero" mocks our disabilities in clear violation of the Joint Order of Appellate Divisions of 2020 on Lawyer Civility

Attorney Misk talks in this manner about a 76-old man, my husband, who has practiced law in Delhi, NY for 37 years and whose law office was open 24/7 for free consultations to the public.

He was disbarred based on fraudulent lawsuit of former Supreme Court Justice and Chief Judge of the 6th Judicial District Robert Harlem and his son and attorney Richard Harlem, of which one of the claimed Plaintiffs in the case allegedly represented by these two fraudsters (one dead by now) has sent to us an affidavit after the case has concluded and after my husband was disbarred.

Here it is:

It is apparent that, considering that the Harlems have rented, for decades, an office space to a recently retired local State Senator, simply removed - by fraud - a successful competitor (my husband) from the market.

That my husband was also a pro bono source of legal advice for poor people of several local upstate poor counties, did not concern the fraudsters one bit.

We have received this affidavit in November of 2015.  Within days of receipt of that affidavit, I was suspended, after repeatedly refusing demands of certain high-power individuals to divorce my husband and thus expose his assets to being robbed - or else.

Or else happened, and we simply left the State of New York and now live quietly in South Carolina.

But now - tada! - every punk coming out of the woodwork who does not know us or about us - like Mr. Misk - consider it their sacred duty to kick us claiming that anything coming from us is frivolous, vexatious and incompetent, simply because the State of New York considered us too dangerous for the New York State government to remain in practice.

And, that punk considers that he can kick us even FOR our disabilities - multiple after COVID and due to our respective ages and stress we went through, representing our clients in good faith and to the best of our collective abilities.

Here is WHO he is insulting as faking his disability and for what (and, mind, these documents have been submitted to the court and to Mr. Misk's attention and are available for public viewing on NYSCEF, guest search, see case # above.  

Any document in this case is downloadable by anybody from any place on Earth with an Internet connection.

So, here is who Mr. Misk is insulting, kicking and mocking for his allegedly "fake" disability:

This is how he "walks", fighting cruel pain with every step, the man who has not only generously provided FREE legal consultations and often a free representation to the community in Delaware, Otsego, Chenango counties and to anybody who would call - for 37 years, the service that now is lost to the people.  Look at his face - can you fake such a concentration to try to prevent un-preventable pain?

Here is one of the sources of his pain: the completely destroyed hip joint:

Note one side of the body having the round joint and the other not having it.  This is the source of tremendous pain and inability to walk for him - Mr. Neroni could not walk outside the house for a YEAR! and is moving between floors only with the help of - thank God! - existing elevator.

Here is another source of his pain:  two hernias with loops of intestines protruding into one of them

Recognizing Mr. Neroni's restrictions on mobility, a licensed physician in the State of South Carolina has submitted on Mr. Neroni's behalf a certified statement of his disability and pain, and, based on that statement, the State of South Carolina has recognized Mr. Neroni as permanently disabled and gave him a placard for parking purposes for the maximum of 4 years that is given in South Carolina only for a permanent disability:

Mr. Neroni, as a result of his disabilities, suffers cruel pains at night, including debilitating, long, relentless leg cramps.  The only thing that helps relieve those cramps at least a little bit is a muscle spasm spray, but Mr. Neroni cannot reach where it hurts on his own, it is I who is applying the spray every night.

Naturally, after sleepless nights fill for Mr. Neroni with pain and sleep deprivation and for me with mental anguish for my husband and with sleep deprivation, too, which undermines my own - multiple - health conditions after COVID and due to my age of 60, we are unable to be coherent enough to attend court hearings, even virtual ones, and effectively representing ourselves.

To understand what is at stake, Mr. Misk is suing us on behalf of - allegedly, he did not prove his authority to prosecute this lawsuit so far, in my legal opinion on my own behalf - a commercial corporation that claims to own the Stewart's Store in Delhi, NY, and that claims an alleged right to drive vehicles over our property.  That's it.  A property dispute.

Is a property dispute worth for the court system to TORTURE, literally, physically and mentally, TORTURE a disabled man over?

Apparently, it is.

Mr. Misk, apparently, also thinks so.

Because being aware of all of medical problems of Mr. Neroni, he submitted the following response to Mr. Neroni's MINIMAL request to the court - to either move the virtual hearing to the afternoon from the early morning so that he could catch some sleep after his horrible nights, or, even better, to allow his motions to be heard on submitted basis, as IS THE DEFAULT PROCEDURE FOR EVERYBODY in Delaware County Supreme Court anyway.

Here is the response of Mr. Misk in which he asks the judge to DENY the reasonable accommodation to a severely disabled individual who is in pain based on that individual's complaint against the presiding Justice McBride saying this:


Subject:complaint about misconduct and potential bribery of Justice Joseph A. McBride, assigned justice, Delaware County Supreme Court, Berrian Inc. v. Frederick J. Neroni, Tatiana Neroni, EF 2023-322
Date:2023-09-24 21:51

Dear Sirs

Attached please find the following documents:

(1) the e-docket as of today in the above entitled Delaware County Supreme Court Action that I have downloaded as a guest, as any other person with an Internet connection can do; this is not an appearance or waiver of any rights in this action;

(2) Justice McBride's court calendars in Chenango, Broome, and Delaware County Supreme Courts for October 13, 2023;

(3) Justice McBride's court orders, NYSCEF Docs. 21, 22 in Berrian Inc. v. Frederick J. Neroni, Tatiana Neroni.


My wife and I, two retired and disabled individuals, are domiciliaries and residents of the State of South Carolina since 2015.

In May this year, we were sued in Delaware County Supreme Court by a corporation over an alleged easement dispute.

After recusals of two other local judges, Justice Joseph A. McBride, my opponent of many years in criminal cases as a prosecutor, was assigned to the case.

The case is currently at a pre-service stage, we are UNSERVED NONDOMICILIARY defendants who did not appear in the case in any way, shape or form.

A third party has notified us that Plaintiff has applied, without serving us properly with the motion, to extend time to serve the Summons and Complaint on us in South Carolina, and for expedient service by e-mail.  The reason the third party notified us was because Plaintiff's counsel has dumped into public access our Social Security numbers, (NYSCEF Doc. 12, it was pulled on August 30, 2023 and returned into the docket on September 14, 2023, but remained within reach of identity thieves from August 16 to August 30, 2023) since New York court system allows anybody to download any files from e-filed cases for free, so now we are exposed to identity thieves thanks to Plaintiff's counsel's actions. 

I have attached the court docket as of today showing that I did not so far oppose the pending purported motion, and I do not have to.  I was not served with the motion, and the motion is clearly legally insufficient.  Moreover, even if I decide to oppose the motion, it will not be an appearance on the merits or waiver of personal jurisdiction, and the court still has no jurisdiction to order my in person appearance in the State of New York, as the whole issue Plaintiff is litigating right now is to get permission from the court for extra time to serve my wife and me in South Carolina since its 120 days to do that expired as of September 7, 2023.

My copying of this complaint to the 6th Judicial District is not a waiver on the merits either, but a notification of the court administration of a potential bribery of a Supreme Court justice.

The complaint requests a judgment qualifying under CPLR 314(2), and even if my wife and I ARE served in South Carolina, the court still will not have personal jurisdiction over us.

Justice McBride appears to have received some improper encouragement from the corporate Plaintiff or its counsel, as I have received in the mail a letter claiming that I am "listed as an attorney for one of the parties" and that my appearance in person is required by the court on October 13, 2023.

Justice McBride has no authority whatsoever to order my personal appearance, as he has no power over me as an unserved non-domiciliary defendant.

It is very apparent that Justice McBride is actively helping the corporate Plaintiff and its counsel in this matter, as the unauthorized order of Justice McBride unlawfully directing my own and my wife's personal appearance in New York from South Carolina is an obvious setup that will resolve for the Plaintiff the current problem of being unable to acquire personal jurisdiction over us because we are out of state domiciliaries, CPLR 314(2).  If we are served in court, that problem goes away, and Plaintiff's motion becomes moot.  This is, apparently, Justice McBride's approach to resolving the issue - he simply undertook to represent the Plaintiff in the matter and use his non-existent in this matter judicial power over me to order a physical appearance of unserved nondomiciliary defendants in court, which is completely unheard of and stinks of a bribe.

I have attached Justice McBride's calendars for the day when he ordered my wife's and my own appearance 850 miles away from home, a 1700 mile roundtrip for Justice's McBride's pleasure.

Justice McBride has on that day motion calendars in the Supreme Court of three counties: Broome, Chenango, Delaware.

In Broome, Justice McBride has a long list of cases which are obviously, judging by their scheduled time at the same time at 9 30 am, scheduled to be submitted.

In Chenango, Justice McBride has a full calendar, both before and after noon.  His last case in the morning is scheduled at 9 45 am and his first case in the afternoon is at 13 30, with 3.5 hours in between, which is barely enough for a roundtrip of 2+ hours to Delhi, NY and back, a public motion hearing in person, and a lunch.  Our case is the only case scheduled in Delaware County Supreme Court for Justice McBride.  The Plaintiff did not request a personal appearance, and we did not appear, so we obviously did not either.

It is very obvious that Justice McBride is going to appear virtually - while not announcing it to the public and not allowing public viewing of that virtual appearance - while setting us up to have us served by Plaintiff in the courtroom or on the steps of the courthouse, which is the only apparent reason for him to order our personal appearance.

I cannot pound it enough that since we were never served, Justice McBride has no authority over us whatsoever, whether we file an opposition to the current purported motions on submitted basis or not.  The problem is that the personnel of the court may reject our papers on submission because of Justice McBride's scheduling order requiring that the appearance is in person.  

This is a sua sponte order, Plaintiff did not ask for such an appearance, and Justice McBride certainly has no authority to order personally appearances in court of non-domiciliary unserved defendants.

That sua sponte order was issued on September 12, 2023, 5 days after Plaintiff's time to serve us in South Carolina has expired per statute, CPLR 306-b.

It is apparent that Justice McBride is acting in clear absence of authority and knows it well, and adamantly and is publicly abusing its non-existing power a corporate Plaintiff to gain jurisdiction that the Plaintiff cannot otherwise gain.

I am wondering whether Justice McBride was bribed by the Plaintiff or its counsel to make this outrageous unlawful order of personal appearance against non-appearing (as yet) unserved out of state defendants.

And, again, even if I or my wife appear in opposition to a pre-service motion to extend service, the court has no authority to order our personal appearance in the State of New York.

I request to investigate this potential bribery case.

As you understand, I am not going to stay silent about what I believe is an ongoing bribery of a Supreme Court justice, and will publish my complaint as I please.

I request to take this obviously dishonest judge off this case and off the bench.

Thank you,

Frederick J. Neroni

240 Harvest Moon Drive

Georgetown SC, 29440

Phone 843 461 3344



This complaint was NOT filed with the court.  Mr. Neroni simply stated to Justice McBride that the denial of an ADA accommodation may create an appearance of retaliation for his complaint against the judge.

As to the mentioning of Mr. Misk's little revenge-doxxing of us, putting online our social security numbers, Mr. Misk did not tell the court about that little adventure of his, or that he was notified back in August that we have evidence that his affidavits of service submitted to the court are false.

The reaction of Attorney Misk to that:  he tried to make his false affidavits filed with the court into a bargaining tool, applying pressure upon me to accept service as a price of him not defrauding the court, see our exchange here:


Tatiana Neroni

AttachmentsWed, Aug 30, 1:39 PM
to infonf

Dear Sirs:

I am writing to the law firm rather than to attorney Gerard N. Misk, as attorney Misk has been listed 
as "inactive" in this case on e-courts as of 8/17/2023, see snapshot from E-courts attached.

The firm may be unaware of Mr Misk's filings, but it is the firm against whom I will have to request 
sanctions based on such filings, therefore, I am sending you a good faith notification ahead of time, 
and a request to withdraw certain filings, which I will also follow up by certified mail as 
soon as Hurricane Idalia is out of our hair.

1.  Public exposure online by attorney Gerard N. Misk of parts of my own and my husband's SSN 
that are not allowed to be exposed, likely as a revenge doxxing for our refusal to consent to 
service by e-mail and to tell them our residential address

Disclaimer:  Where, below, I am discussing my exposure of my husband's confidential 
private information (CPI) exposing my husband to identity theft, I am writing this not as my 
husband Frederick J. Neroni's attorney or representative, because I am not, but as his spouse 
with a joint income and livelihood, where my own income and livelihood may be severely 
affected by identity theft against my husband that was simplified by your attorney Misks's e-filings.

I was alerted by the court notification sent by mail to us in South Carolina that you have 
made a motion against us in the above matter.  While I have never been legally served 
with that motion, I was nevertheless, interested what was filed online, in order to protect my rights.

 As a guest, I have searched the E-docket on NYSCEF for free, as any member of the 
public from anywhere in the world is allowed to do.

The docket of Berrian, Inc. v. Neroni has showed an "Exhibit D", NYSCEF Doc. 12, filed 
electronically by your attorney Gerard N. Misk.

Documents in Exhibit D are completely unredacted, contrary to 22 NYCRR 202.5(1)(e)(i) 
and (ii) and contain:

(1) 5 FIRST digits of my Social Security Number (only 4 LAST digits are allowed to be 
disclosed by subsection (i) above;
(2) 5 FIRST digits of my husband's Social Security number;
(3) my month and year of birth (the month is prohibited for disclosure by subsection (ii) above;
(4) my husband's month and year of birth; and
(5) complete dates of birth or months of birth of our multiple family members, including our children, 
and of people listed as being in possible association with us.

You must be aware of NYS General Business Law 399DDD, which allows NYS Attorney General t
o impose, even for the first multiple violation of that section (exposure of even portions of SSNs t
hat are not allowed to be exposed) a fine of up to $100,000.00.

Such misconduct certainly qualifies as frivolous conduct, especially that Exhibit D, as your 
review must show, was completely unnecessary to file in the first place, as you and your 
client have had our residential address in South Carolina from day 1 of the litigation, but made 
no due diligence efforts to serve us.

This matter is urgent for me, as you have exposed me and my husband (which affects me) 
personally to increased chances of identity theft.

As residents of South Carolina and a consumers protected by South Carolina law, we are 
exploring options how to protect ourselves under South Carolina, New York and federal law 
from this exposure.

One of the options that we are considering is a security freeze on our credit score.

Yet, such a freeze, in itself, presents a major inconvenience to me and my husband, as the 
freeze may cause us to be turned down in certain applications for credit, or require me to 
engage in additional efforts to thaw my credit report temporarily for a particular period of time 
or a particular creditor.

In view of the above and as a matter of good faith I request that you IMMEDIATELY remove 
Exhibit D from the E-file of the court, as every extra second our 5 first digits of SSNs plus our 
months of birth remain online in free guest access to anybody from anywhere in the world, the 
chances that that information will be obtained and used for ulterior purposes and result in identity 
theft increases manifold.

Moreover, I insist that you do not refile Exhibit D after bringing it in compliance with 
22 NYCRR 202.5(1)(e)(i) and (ii), as subsection (i) allows posting of the last digits of our SSNs 
which were not posted yet by your while the first 5 digits were.

Posting the remaining 4 digits, under the circumstances, will simply put our entire SSNs online, 
exposing us completely to identity thieves.

I repeat that you must well know, as experienced attorneys, that Exhibit D was completely 
unnecessary for you to obtain personal service over us in South Carolina at the address that is 
and has been on your Summons since the filing date of the action, and I have incontrovertible 
proof to establish that iin court. 

If Exhibit D is not removed by you from the docket, I will ask the court for sanctions against your 
client, your law firm and Gerard N. Misk personally, in addition to other measures you have made 
necessary for me to protect myself from identity theft and redress the wrong imposed on me by you.

2.  False affidavits 

Attorney Gerard N. Misk has submitted to the court several affidavits of service by one J
ohnny McRae Jr.  

I have incontrovertible proof that all of these affidavits are false.

Your review of the affidavits may show you why they are facially legally insufficient, even 
without being blatantly false.

Since your client's entire purported motion is supported by these false affidavits, I may argue 
to the court that the entire motion is frivolous.

If these affidavits are not withdrawn from the case, I will be forced to ask for sanctions 
against you and, possibly, to file a lawsuit against your law firm pursuing appropriate 
causes of action in appropriate courts.

As you understand, I have sufficient litigation experience as a trial lawyer not to have 
to pay an attorney to sue you.

Please, advise how you want to proceed regarding the above described matters.

Tatiana Neroni

One attachment • Scanned by Gmail

Gerard Misk

Wed, Aug 30, 3:14 PM

Thank you for pointing out the error in the filing of Exhibit D. It has now been corrected, 

with my apologies. With regard to the affidavits of attempted service, we do not believe 

that they have been filed in bad faith. If you think that the request for alternative service 

is not well founded, you can file opposition. Or we can short circuit the whole affair and 

you can accept service and I will withdraw my motion.


Gerard Misk

Ginsburg & Misk LLP

215-48 Jamaica Ave

Queens Village, NY 11428

718-468-0500 X 106



P Please conserve and don't print this e-mail unless it's necessary.

Confidentiality Disclosure: The information in this email and in attachments is confidential and intended solely for the attention a

nd use of the named addressee(s). This information may be subject to legal professional or other privilege or may otherwise be 

protected by work product immunity or other legal rules. It must not be disclosed to any person without our authority. If you are 

not the intended recipient, or a person responsible for delivering it to the intended recipient, you are not authorized to disclose, a

nd must not disclose, copy, distribute, or retain this message or any part of it.

Tatiana Neroni

AttachmentsWed, Aug 30, 3:38 PM
to Gerard
Mr Misk

1. As the snapshot from the court website that I have sent to your law firm shows, you are 
listed as "inactive" on this case's page on E-courts.  I will be deeming you as having no authority
 to represent Plaintiff in this action, as per official court records, unless proof otherwise is provided.

2.  I have made a good faith effort to notify you of your potentially frivolous filing of an apparently
 false and facially insufficient affidavits before moving for sanctions.  You have a chance to withdraw
 them before I move for sanctions or/and pursue other venues of legal redress available to me 
regarding that issue.

3.  As you well know, I have no legal obligation to accept service from you, especially that 
you know full well where I reside, and that I am fully amenable to personal service there.  


Tatiana Neroni

One attachment • Scanned by Gmail

Gerard Misk

Wed, Aug 30, 3:44 PM
to me

Do as you wish. It is obvious that you would rather stand on ceremony than simply accept 

service of a complaint you have already received.

I did not complain against Judge McBride and did not say I did in the court filings.

Yet, here is what Mr. Misk is responding to Judge McBride, claiming that I did complain against Judge McBride and asking Judge McBride to punish both Mr. Neroni and me - with denial of ADA accommodations, no less - because of that complaint.

Mind that Mr. Misk did not disclose to the court - to this day - that he was notified by me in August that his affidavits submitted to the court are false, or that he used that fact to pressure me to waive service, while conducting no investigation of that fact.

Now, consider this beautiful piece from Mr. Misk to the court:

Mr. Misk is of an opinion, contrary to medical evidence submitted by Mr. Neroni to the court, that Mr. Neroni is faking his disability, and requests to deny his minimum ADA accommodation BECAUSE Mr. Neroni complained against the judge.

One day prior to this letter Mr. Neroni has filed a motion to vacate Judge McBride's order against Mr. Neroni made because Mr. Neroni did not appear IN NEW YORK, physically, summoned there without being served, in order to deliver Mr. Neroni as a present for service in the courtroom to the corporate alleged Plaintiff.

Mr. Neroni and I submitted enough evidence to the court to show that Mr. Misk's affidavits of service or, rather, non-service on us in South Carolina were false and that the process server has never been at our house, as he has claimed it to be "not occupied", when we had dogs and cats on the OUTSIDE screened porch from 7 30 am to 9 pm EVERY SINGLE DAY, and only a fraudster can claim to the court under such circumstances (and that was only one detail, there were a lot more) that the house was "not occupied", NYSCEF Docs. 4, 5.

That made Justice McBride realize into what mess Attorney Misk has gotten him, and, combined with Attorney Misk's direct request to retaliate against an invalid by torturing him (denying him an elementary ADA accommodation Mr. Neroni requested) BECAUSE Mr. Neroni complained against the judge, Justice McBride immediately recused.

Justice Patrick O'Sullivan was assigned.

Justice Patrick O'Sullivan has, first, taken ALL of our motions off the calendar and replaced them with a "Conference/Unknown", again scheduled for 9:30 am, despite Mr. Neroni's threat of a lawsuit for violation of the ADA.

It took several more letters to the court - which was EXTREMELY uncomfortable for Mr. Neroni physically to even write, much less file - for the court to realize that it has no authority, at a pre-service stage of proceedings, with motions to dismiss for lack of service pending, to call any "conferences", especially for "unknown" reasons, and to take off the calendar the actual motions.

What the court did though was a compromise: the judge has denied us the request for what is given to any other litigant in Delaware County Supreme Court by default, to proceed with our fully briefed motions on paper, without a hearing.

We submitted that written policy to the court with one of our letters.

Yet, the judge (1) cancelled the "Conference/Unknown", (2) restored our motions to the calendar, albeit with an adjournment of a week, and (3) still ordered an oral argument by Teams for December 15, 2023 at 2 00 pm, because the court supposedly "had questions" about the fully briefed motions.

Since we do not know Justice O'Sullivan, and because Justice O'Sullivan's letter to us was polite - for a change, after the dehumanizing treatment we suffered by the same court for years, and in this case, too, we gave the court the benefit of the doubt, rescheduled our Notices of Motions to that date and time, and are going to appear for the court's questions.

I remind the public who wants to attend that the discussion is of JURISDICTION only.

It is a pre-service stage of litigation, we were not served, and the motions are 

(1) a motion to dismiss for lack of subject matter jurisdiction - my motion, (I am arguing that the lawsuit is brought by an attorney not legally authorized to file lawsuits on behalf of this corporation);

(2) A motion for authority of plaintiff's counsel to bring the lawsuit, CPLR 322(a) - my motion;

(3) A motion for a more definite statement of jurisdictional grounds for personal jurisdiction over the alleged tort of obstruction of an easement, CPLR 3024(a) - my motion;

(4) a motion to vacate the prior order of Justice McBride that extended the Plaintiff's time to serve the Summons and Complaint on us, CPLR 306-b, by 30 days after the entry of the order, and allowed service by e-mail, CPLR 308(5) - motions by both Mr. Neroni and myself.

Grounds are - CPLR 5015(a)(2), (3), (4) (new evidence, misrepresentation/fraud, lack of jurisdiction)

(5) a motion to dismiss for failure to serve us with the Summons and Complaint - Mr. Neroni's and my own motions Pro Se.

Again, the motions are fully briefed, with the exception that an opposition is due on the motion to dismiss for lack of subject matter jurisdiction (on Dec 13th), and our replies for all motions are due on Dec 14th.

All the documents so far filed are available on the NYSCEF website for free from any point of the world.


As I said above, if you want to attend this court hearing, you can send your e-mail addresses to me by e-mail, messenger on Facebook, same name Tatiana Neroni, or whatsup 1 843 240 7745.

When I receive your email, I will arrange for your admission to the hearing on Dec 15, 2023 at 2 00 pm eastern time via Microsoft Teams.  

Will appreciate attendance as support and as court observation - and public supervision.  

For those who want to apply for attendance on their own, the link to request attendance is here:

Info about the case to enter into the request form:

Name of court:  Delaware County Supreme Court, multibench

Case #:  EF2023-322 

Case name:  Berrian, Inc. V Neroni.

You can download and view all materials in the case, including the motions that are to be reviewed at the hearing, by typing in Google:

NYSCEF guest search, 

verifying that you are not a robot, entering my name, Tatiana Neroni, in the appearing search form and clicking the link when the case name appears.

Your attendance will be greatly appreciated. 

Thank you!

Tatiana Neroni


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