Preview
FILED: QUEENS COUNTY CLERK 10/25/2023 03:55 PM INDEX NO. 722594/2023
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/25/2023
INSTRUCTIONS FILL IN THE NAMES IN THE BOX NUMBER BELOW, THE INDEX NUMBER ANDTHE
DATETHElmEKNUMBERWASPURCHASED COMPLETE ALL 8LANKS INACCORDANCE WITH THE
DIRECTIONS 8ET FORTH IN BOLDPRINT
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
Plaint (s), Index No 7 U/13
-against- Date Index No
purchased ( () /
b b3
/3errr efesme. 26 /,r
(NAME OF PERSON(8) SUEDI 4
g SUMMONS
Defenda t(a
To the Person(s) Named as Defendant(s) Above
PLEASE TAKE NOTICE THAT YOU ARE HEREBY SUMMONED to answer the
complaint of the plaintiff(s) herein and to serve a copy of your answer on the plaintdf(s) atthe
address indicated below within 20 daya after the service of this Summons (not counting the
day of service itself), or wdhin 30 days after service is complete if the Summons la not
delivered personally to you witinn the State of New York
YOU ARE HEREBY NOTIFIED THAT should you fail to answer, a judgment will be
entered against you by default for the raisef demanded in the complaint
Dated , 20.½.3 A I S-
(DATE OF SUMMON8] [YOUR NAME(8)]
Sme . Hfo
IYOUh ADUltE88(ES and
, Z
A
PHONE NUMBER(6)] C)
Defendants Address
[ADDitESS
&5
OF PERSON(8)
3
SUED]
s%..r µ AJ o 22..
Venue Plaint designate(s) Queens County as the place of tnal The basis of this
(s)
dessnation is [CHECK ONE)
Plaintiff(s)'
Residence in Queens County
Defendant(a)'
Residence in Queens County
Other - Descnbe
NOTE THIS FORM OF SUMMONS MUST BE SERVED WITH A COMPLAINT
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1
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
=========================================
1JJS94/b3
INDEX no-------------
VERIFIED COMPLAINT
BART J TARULLI Plaintiff
Against
BEATRICE LESSER , & GALLET DREYER & BERKEY,LLP
Defendants
Plaintiff BART J. TARULL1, being duly sworn hereby deposes and states all
Are true and correct, under penalty of perjury:
1) As and for his complaint against
Defendants, BEATRICE LESSER, & GALLET
DREYER & BERKEY, LLP
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2 -
Respectfully alleges as follows:
PRELIMINARY STATEMENT
2) This is an action for monetary damages
under common law causes of action .BART
TARULLI brings this
Action against BEATRICE LESSER, & GALLET
DREYER & BERKEY, LLP inter alia for:
A) DEFAMATION
B) KNOWINGLY SUBMITTING DEFECTIVE
DOCUMENTSTOTHE COURT
C) CONSPIRACY TO COMMITT FRAUD
D) FRAUD
E) PLACING HER INTERESTS ABOVE OF THE
INTERESTS OF HER CLIENTS
F) PERJURY
G) VILOLATIONS OF THE CODE OF
PROFESSIONAL RESPONSIBILITY, AND
RULES OF ABA
H) PUNITIVE DAMAGES
PARTIES INVOLVED
3) BART J TARULLI is a known eclectic
collector of historically and monetary high
value objects
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unique objects of art and artifacts as well
as written documents. Apart from
furniture that I have for personal use and
are for living with, I do not buy ,sell, store,
or deal with furniture in any manner,
contrary to the false and vicious
accusations to the contrary, stated by
BEATRICE LESSER.
BEATRICE LESSER, IS AN ATTORNEY,
SENIOR PARTNER WITH LAW FIRM, GALLET
DREYER & BERKLEY LLP.
STATEMENT OF FACT COMMON TO ALL CLAIMS
4) By Deed on October 27 1982, BART J
TARULLI ESTABLISHED ŒWNERSHIP OF
UNIT 9R at 2
Bay Club Drive, BAYSIDE, N.Y. #
11360,which is known as The Bay Club
Condominium( referred to
' Club'
As the Bay which was declared a
condo in November 19, 1981.
5) Before the NYS Supreme Court on
December 13, 2017, and March 22, 2019
two distinctive
Lawsuits from the Bay Club entitled The
Board of Managers of the Bay Club
Condominium v
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Bartholomew J Tarulli a/k/a Bart Tarulli
were filed in the Queens County Court
Clerk's Office
Under the Index Numbers of 712145/2017
and 71846/2019
6) Upon information and belief Defendant
GALLET DREYER & BERKEY LLP. is a
domestic business corporation
doing business in the State of New York
5th
with an address listed as 845 Third Ave,
Floor,
New York,New York, 212-935 3131.
7) Upon information and belief, Beatrice
Lesser is a senior partner in the
aforementioned firm
And was the primary attorney
Responsible for handling the legal affairs of
The Bay Club as well as the primary
attorney with whom Plaintiff
communicated.
8) As will be further demonstrated and proven
in this instant case, BART J TARULLI
maintains a
Plausible action against BEATRICE LESSER,
AND GALLET DREYER & BERKEY,LLP, as
complained herein.
PRIOR TO SPECIFICS BEING CITED, PLAINTIFF STATES THAT FROM THE
' OMEGA'
ALPHA TO THIS CASE BROUGHT AGAINST DEFENDANTS IS
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5
PLAGUED WITH EVERYTHING VIOLATIVE BY A LAW FIRM
AND SENIOR PARTNER, AND APPROPRIATE PENALTIES MUST BE
ENACTED.
1St
Cause of action
LEGAL STANDARDS FOR DEFAMATION
.
'
9) Defamation is the making of a false
statement which tends to expose the
plaintiff to public contempt,
Ridicule, aversion or disgrace or induce an
opinion of him in the minds of right thinking
persons, and to deprive him of their friendly
society'
intercourse in ( Foster v Churchbill
87 NY2d 751 [ 1996][ internal quotation
marks
omitted)
10) To prove a claim for defamation a
Plaintiff must show;
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6
1) False statement that is
2) Published to a third party
3) Without privilege or authorization
4) Causes harm unless the statemen
is one of the types of publication
actionable
Regardless of harm ( see Dillon v
City oF New York, 261 AD2d 34, 38
[1"
Dept 1999]
11) Defamation of character is an
12) offense
13) for which a complainant may be
eligible to
Bring another party to court. There
are two types of defamation:
1) Spoken defamation, or slander
and written defamation or libel
14) In today's society, people should not
be able to ruin the lives of others by
disseminating lies
But generally speaking , four criteria
must be met for a slander or libel suit
to stand a chance
Of success. The defamation whether
written or spoken must be:
1) Demonstrably and objectively
false
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2) Seen or heard by a public third
party
3) Quantifiably injurious
4) Unprivileged by law
15) As in this case before the court
,respectively it must be decided
whether the statements considered
In the context of the entire
'
publication are reasonably
susceptible of a defamatory
connotation.
such that the issue is worthy of
submission to a jury( Silsdorf v Levine
59 NY 2d 8, 12 [1983]
EXAMPLES OF DEFAMATORY LANGUAGE
WHAT FOLLOWS ARE CONCRETE
DESCRIPTIONS OF INJURIOUS
DEFAMATION WRITTEN
WHOS' d'
BY BEATRICE LESSER, RAISON
ETRE, IS TO WIN CASES AND Is WILLING TO
BREAK THE
ESTABLISHED RULES TO DO SO. Ms. Lesser
19th
embodies the Russian Centu
philosopher who
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TABLE OF CONTENTS
1st
1)
CAUSE OF ACTION, DEFAMATION
PAGES 5-7
2ND
2)
CAUSE OF ACTION, 'UPON
BELIEF'
INFORMATION AND PAGES 8-11
3RD
3)
CAUSE OF ACTION, LEGAL
STANDARD FOR FRAUD PAGES 11-12 . .
4" ACTION STANDARD
4)
CAUSE OF LEGAL
FOR CONSPIRACY TO COMMITT FRAUD
PAGES 13-19
5). ACCOMPLICE LIABILITY
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5"
6) CAUSE OF ACTION, PINKERTON
DOCTRINE PAGES 20-26
7) VALERIE BERG/ COURT REPORTER
PAGES 129-131 (5 ½ CAUSE OF ACTION)
8) UNANNOUNCED VISIT FROM DEPT OF
BUILDING 26-28
6"
9) CAUSE OF ACTION, SWORN
COMPLAINTS, MS. LESSER PAGES 28-36
7"
10) CAUSE OF ACTION, NEW YORK
STATE
RULES OF PROFESSIONAL CONDUCT
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PAGES 37-40
8TH
11) CAUSE OF ACTION, SUBMISSION OF
FLAWED DOCUMENTS, PAGES 40-43
9"
12) CAUSE OF ACTION, DECEPTIVE
PRACTICES
10"
13) CAUSE OF ACTION, FAILED
FIDUCIARY
11"
14) CAUSE OF ACTION, INVASION OF
PRIVACY, PAGES 47-68
12"
15) CAUSE OF ACTION, BANISHMENT
IN PERPETUITY
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16) VIOLATIONS /ALTERATIONS OF
DOCUMENTS TO THE BENFIT OF
MS. LESSER
(13)th
CAUSE OF ACTION PAGES 45-54
17) FAILURE AS SUPERVISOR AS REQUIRED
BY N.Y.STATE RULES OF PROFESSIONAL
14TH
CONDUCT CAUSE OF ACTION
PAGES 56-59
18) SUBMISSION OF FLAWED DOCUMENTS
15"
CAUSE OF ACTION PAGES 59-62
19) DECEPTION BY MS. LESSER TO NOT
ALERT AFFIANTS OF PENALTIES FOR
16"
PERJURY CAUSE OF ACTION
20) FRAUD COMMITTED BY MS. LESSER IN
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IN: CONJUNCTION WITH OTHERS
CONCERNING INSPECTION OF
APARTMENT
17"
(
CAUSE OF ACTION) PAGES
55-56
21) INTRUSION BY SECLUSION/ INVASION
18"
OF PRIVACY (TORT) CAUSE OF
ACTION PAGES 69-76, 99-105
22) FAILED FIDUCIARY HIRED SPECIALTY
COMPANY EIGHT TIMES MORE THAN
19TH
LOCAL CAUSE OF ACTION
23) COURT REPORTER LETTER
CONCERNING MISTREATMENT
20TH
(
CAUSE OF ACTION) PAGES 76-77
24) ASSOCIATE ALYSSA C GOLDRICH
PERJURY, ZERO KNOWLEDGE
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(21st
. CAUSE OF ACTION) 78-81
25) MR. CRAIG S. TARASOFF,
22ND
PERJURY (
CAUSE OF ACTION)
PAGES 82-86
26) MR, DAVID BERKEY, PERJURY
23RD
(
CAUSE OF ACTION)
PAGES 87-88
27) CONSPIRACY TO BANISH PLAINTIFF
24TH
FROM LEISURE CLUB ( CAUSE
OF ACTION) PAGES 89-99
28) FALSE ACCUSATION/DEFAMATION
(25"
CAUSE OF ACTION )
PAGES 106-113
29) DRACONIAN BEHAVIOR OF MS.
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(26"
. LESSER CAUSE OF ACTION)
113-118
30) FAILURE TO PERFORM HER
FIDUCIARY OBLIGATION AND
IMPROVE VIOLATIONS WITH
27TH
LEISURE CLUB (
CAUSE OF
ACTION) PAGES 119-123
31) DEMAND FOR DAMAGES
(28"
CAUSE) OF ACTION PAGES
124-128
29"
32) PUNITIVE DAMAGES (
CAUSE
OF DAMAGE) PAGES 132-134
33) SUMMARY, PAGES 135-136
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8
' meansl'
Stated The end justifies the
COMPLAINT FILED
ON 4/2 2019 BEATRICE LESSER, FILED
with Queens County Clerk. The complaint
that consists of
12 pages making false allegations which
Plaintiff will debunk at trial.
On page # 3 bullet # 18 of the complaint
Ms. Lesser states the following;
UPON INFORMATION AND BELIEF
'
MOST IF NOT ALL OF HIS FURNITURE HAS
BEEN DISCARDED AND LEFT ON THE STREET
IT!'
WHERE DEFENDANT FINDS .
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THE EQUlVALENT WOULD BE TO STATE A PERSON IS A CHILD
MOLESTER.
THE ACCOUNTANT IS A CROOK!
MY NEIGHBOR STEALS PROPERTY.
THE STUDENT PLAGARIZES.
THE DENTIST FOLDLES HIS PATIENTS.
WITHOUT PROOF ALL OF THE ABOVE ARE VICIOUS LIES THAT COULD
CAUSE IRREPARABLE DAMAGE TO AN INNOCENT VICTIM.
F"
UPON INFORMATION AND BELIE
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to
This phrase used by attorneys is a method
of defaming someone, without taking
responsibility or fault.
It is an EXCULPATORY phrase, a weasel
clause where a party can state something
VILE and have
No penalties exacted, simply by injection of
this phrase. Ms. Lesser did not do her
homework
As plaintiff has . She is obligated to name
the source that supplied this information,
and obligated
to answer any related questions that
plaintiff requests.
How vulgar to stoop to such level as has Ms.
Lesser! This statement was mean spirited,
intended to
place plaintiff as a low tier dealer , as
opposed to the established, respected
dealer who some auction
houses place in the highest esteem.
CONSEQUENCES: I have been black mailed
in my business ,threatened to expose the
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11
false and vile lies set in place by this
despicable act of Ms. Lesser. My business
suffered substantial
Loses financially due to this tract.1 have
suffered from people who trusted me, and
now hold
me suspect. I have started this business ,
part time in 1985. I have traveled overseas
too many times
to count, and have a pristine reputation. I
have set auction records at both Christies
and Swann
Galleries and donated most proceeds to
charity.
The clients developed at the Bay Club, all
seven will no longer buy from me. This one
career
Ending sentence is enough to have Ms.
Lesser serve the harshest penalty.
Preview
FILED: QUEENS COUNTY CLERK 10/25/2023 03:55 PM INDEX NO. 722594/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/25/2023 INSTRUCTIONS FILL IN THE NAMES IN THE BOX NUMBER BELOW, THE INDEX NUMBER ANDTHE DATETHElmEKNUMBERWASPURCHASED COMPLETE ALL 8LANKS INACCORDANCE WITH THE DIRECTIONS 8ET FORTH IN BOLDPRINT SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS Plaint (s), Index No 7 U/13 -against- Date Index No purchased ( () / b b3 /3errr efesme. 26 /,r (NAME OF PERSON(8) SUEDI 4 g SUMMONS Defenda t(a To the Person(s) Named as Defendant(s) Above PLEASE TAKE NOTICE THAT YOU ARE HEREBY SUMMONED to answer the complaint of the plaintiff(s) herein and to serve a copy of your answer on the plaintdf(s) atthe address indicated below within 20 daya after the service of this Summons (not counting the day of service itself), or wdhin 30 days after service is complete if the Summons la not delivered personally to you witinn the State of New York YOU ARE HEREBY NOTIFIED THAT should you fail to answer, a judgment will be entered against you by default for the raisef demanded in the complaint Dated , 20.½.3 A I S- (DATE OF SUMMON8] [YOUR NAME(8)] Sme . Hfo IYOUh ADUltE88(ES and , Z A PHONE NUMBER(6)] C) Defendants Address [ADDitESS &5 OF PERSON(8) 3 SUED] s%..r µ AJ o 22.. Venue Plaint designate(s) Queens County as the place of tnal The basis of this (s) dessnation is [CHECK ONE) Plaintiff(s)' Residence in Queens County Defendant(a)' Residence in Queens County Other - Descnbe NOTE THIS FORM OF SUMMONS MUST BE SERVED WITH A COMPLAINT 1 of 146 FILED: QUEENS COUNTY CLERK 10/25/2023 03:55 PM INDEX NO. 722594/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/25/2023 1 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS ========================================= 1JJS94/b3 INDEX no------------- VERIFIED COMPLAINT BART J TARULLI Plaintiff Against BEATRICE LESSER , & GALLET DREYER & BERKEY,LLP Defendants Plaintiff BART J. TARULL1, being duly sworn hereby deposes and states all Are true and correct, under penalty of perjury: 1) As and for his complaint against Defendants, BEATRICE LESSER, & GALLET DREYER & BERKEY, LLP 2 of 146 FILED: QUEENS COUNTY CLERK 10/25/2023 03:55 PM INDEX NO. 722594/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/25/2023 2 - Respectfully alleges as follows: PRELIMINARY STATEMENT 2) This is an action for monetary damages under common law causes of action .BART TARULLI brings this Action against BEATRICE LESSER, & GALLET DREYER & BERKEY, LLP inter alia for: A) DEFAMATION B) KNOWINGLY SUBMITTING DEFECTIVE DOCUMENTSTOTHE COURT C) CONSPIRACY TO COMMITT FRAUD D) FRAUD E) PLACING HER INTERESTS ABOVE OF THE INTERESTS OF HER CLIENTS F) PERJURY G) VILOLATIONS OF THE CODE OF PROFESSIONAL RESPONSIBILITY, AND RULES OF ABA H) PUNITIVE DAMAGES PARTIES INVOLVED 3) BART J TARULLI is a known eclectic collector of historically and monetary high value objects 3 of 146 FILED: QUEENS COUNTY CLERK 10/25/2023 03:55 PM INDEX NO. 722594/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/25/2023 3 unique objects of art and artifacts as well as written documents. Apart from furniture that I have for personal use and are for living with, I do not buy ,sell, store, or deal with furniture in any manner, contrary to the false and vicious accusations to the contrary, stated by BEATRICE LESSER. BEATRICE LESSER, IS AN ATTORNEY, SENIOR PARTNER WITH LAW FIRM, GALLET DREYER & BERKLEY LLP. STATEMENT OF FACT COMMON TO ALL CLAIMS 4) By Deed on October 27 1982, BART J TARULLI ESTABLISHED ŒWNERSHIP OF UNIT 9R at 2 Bay Club Drive, BAYSIDE, N.Y. # 11360,which is known as The Bay Club Condominium( referred to ' Club' As the Bay which was declared a condo in November 19, 1981. 5) Before the NYS Supreme Court on December 13, 2017, and March 22, 2019 two distinctive Lawsuits from the Bay Club entitled The Board of Managers of the Bay Club Condominium v 4 of 146 FILED: QUEENS COUNTY CLERK 10/25/2023 03:55 PM INDEX NO. 722594/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/25/2023 4 Bartholomew J Tarulli a/k/a Bart Tarulli were filed in the Queens County Court Clerk's Office Under the Index Numbers of 712145/2017 and 71846/2019 6) Upon information and belief Defendant GALLET DREYER & BERKEY LLP. is a domestic business corporation doing business in the State of New York 5th with an address listed as 845 Third Ave, Floor, New York,New York, 212-935 3131. 7) Upon information and belief, Beatrice Lesser is a senior partner in the aforementioned firm And was the primary attorney Responsible for handling the legal affairs of The Bay Club as well as the primary attorney with whom Plaintiff communicated. 8) As will be further demonstrated and proven in this instant case, BART J TARULLI maintains a Plausible action against BEATRICE LESSER, AND GALLET DREYER & BERKEY,LLP, as complained herein. PRIOR TO SPECIFICS BEING CITED, PLAINTIFF STATES THAT FROM THE ' OMEGA' ALPHA TO THIS CASE BROUGHT AGAINST DEFENDANTS IS 5 of 146 FILED: QUEENS COUNTY CLERK 10/25/2023 03:55 PM INDEX NO. 722594/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/25/2023 5 PLAGUED WITH EVERYTHING VIOLATIVE BY A LAW FIRM AND SENIOR PARTNER, AND APPROPRIATE PENALTIES MUST BE ENACTED. 1St Cause of action LEGAL STANDARDS FOR DEFAMATION . ' 9) Defamation is the making of a false statement which tends to expose the plaintiff to public contempt, Ridicule, aversion or disgrace or induce an opinion of him in the minds of right thinking persons, and to deprive him of their friendly society' intercourse in ( Foster v Churchbill 87 NY2d 751 [ 1996][ internal quotation marks omitted) 10) To prove a claim for defamation a Plaintiff must show; 6 of 146 FILED: QUEENS COUNTY CLERK 10/25/2023 03:55 PM INDEX NO. 722594/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/25/2023 6 1) False statement that is 2) Published to a third party 3) Without privilege or authorization 4) Causes harm unless the statemen is one of the types of publication actionable Regardless of harm ( see Dillon v City oF New York, 261 AD2d 34, 38 [1" Dept 1999] 11) Defamation of character is an 12) offense 13) for which a complainant may be eligible to Bring another party to court. There are two types of defamation: 1) Spoken defamation, or slander and written defamation or libel 14) In today's society, people should not be able to ruin the lives of others by disseminating lies But generally speaking , four criteria must be met for a slander or libel suit to stand a chance Of success. The defamation whether written or spoken must be: 1) Demonstrably and objectively false 7 of 146 FILED: QUEENS COUNTY CLERK 10/25/2023 03:55 PM INDEX NO. 722594/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/25/2023 7 2) Seen or heard by a public third party 3) Quantifiably injurious 4) Unprivileged by law 15) As in this case before the court ,respectively it must be decided whether the statements considered In the context of the entire ' publication are reasonably susceptible of a defamatory connotation. such that the issue is worthy of submission to a jury( Silsdorf v Levine 59 NY 2d 8, 12 [1983] EXAMPLES OF DEFAMATORY LANGUAGE WHAT FOLLOWS ARE CONCRETE DESCRIPTIONS OF INJURIOUS DEFAMATION WRITTEN WHOS' d' BY BEATRICE LESSER, RAISON ETRE, IS TO WIN CASES AND Is WILLING TO BREAK THE ESTABLISHED RULES TO DO SO. Ms. Lesser 19th embodies the Russian Centu philosopher who 8 of 146 FILED: QUEENS COUNTY CLERK 10/25/2023 03:55 PM INDEX NO. 722594/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/25/2023 TABLE OF CONTENTS 1st 1) CAUSE OF ACTION, DEFAMATION PAGES 5-7 2ND 2) CAUSE OF ACTION, 'UPON BELIEF' INFORMATION AND PAGES 8-11 3RD 3) CAUSE OF ACTION, LEGAL STANDARD FOR FRAUD PAGES 11-12 . . 4" ACTION STANDARD 4) CAUSE OF LEGAL FOR CONSPIRACY TO COMMITT FRAUD PAGES 13-19 5). ACCOMPLICE LIABILITY 9 of 146 FILED: QUEENS COUNTY CLERK 10/25/2023 03:55 PM INDEX NO. 722594/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/25/2023 5" 6) CAUSE OF ACTION, PINKERTON DOCTRINE PAGES 20-26 7) VALERIE BERG/ COURT REPORTER PAGES 129-131 (5 ½ CAUSE OF ACTION) 8) UNANNOUNCED VISIT FROM DEPT OF BUILDING 26-28 6" 9) CAUSE OF ACTION, SWORN COMPLAINTS, MS. LESSER PAGES 28-36 7" 10) CAUSE OF ACTION, NEW YORK STATE RULES OF PROFESSIONAL CONDUCT 10 of 146 FILED: QUEENS COUNTY CLERK 10/25/2023 03:55 PM INDEX NO. 722594/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/25/2023 PAGES 37-40 8TH 11) CAUSE OF ACTION, SUBMISSION OF FLAWED DOCUMENTS, PAGES 40-43 9" 12) CAUSE OF ACTION, DECEPTIVE PRACTICES 10" 13) CAUSE OF ACTION, FAILED FIDUCIARY 11" 14) CAUSE OF ACTION, INVASION OF PRIVACY, PAGES 47-68 12" 15) CAUSE OF ACTION, BANISHMENT IN PERPETUITY 11 of 146 FILED: QUEENS COUNTY CLERK 10/25/2023 03:55 PM INDEX NO. 722594/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/25/2023 16) VIOLATIONS /ALTERATIONS OF DOCUMENTS TO THE BENFIT OF MS. LESSER (13)th CAUSE OF ACTION PAGES 45-54 17) FAILURE AS SUPERVISOR AS REQUIRED BY N.Y.STATE RULES OF PROFESSIONAL 14TH CONDUCT CAUSE OF ACTION PAGES 56-59 18) SUBMISSION OF FLAWED DOCUMENTS 15" CAUSE OF ACTION PAGES 59-62 19) DECEPTION BY MS. LESSER TO NOT ALERT AFFIANTS OF PENALTIES FOR 16" PERJURY CAUSE OF ACTION 20) FRAUD COMMITTED BY MS. LESSER IN 12 of 146 FILED: QUEENS COUNTY CLERK 10/25/2023 03:55 PM INDEX NO. 722594/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/25/2023 IN: CONJUNCTION WITH OTHERS CONCERNING INSPECTION OF APARTMENT 17" ( CAUSE OF ACTION) PAGES 55-56 21) INTRUSION BY SECLUSION/ INVASION 18" OF PRIVACY (TORT) CAUSE OF ACTION PAGES 69-76, 99-105 22) FAILED FIDUCIARY HIRED SPECIALTY COMPANY EIGHT TIMES MORE THAN 19TH LOCAL CAUSE OF ACTION 23) COURT REPORTER LETTER CONCERNING MISTREATMENT 20TH ( CAUSE OF ACTION) PAGES 76-77 24) ASSOCIATE ALYSSA C GOLDRICH PERJURY, ZERO KNOWLEDGE 13 of 146 FILED: QUEENS COUNTY CLERK 10/25/2023 03:55 PM INDEX NO. 722594/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/25/2023 (21st . CAUSE OF ACTION) 78-81 25) MR. CRAIG S. TARASOFF, 22ND PERJURY ( CAUSE OF ACTION) PAGES 82-86 26) MR, DAVID BERKEY, PERJURY 23RD ( CAUSE OF ACTION) PAGES 87-88 27) CONSPIRACY TO BANISH PLAINTIFF 24TH FROM LEISURE CLUB ( CAUSE OF ACTION) PAGES 89-99 28) FALSE ACCUSATION/DEFAMATION (25" CAUSE OF ACTION ) PAGES 106-113 29) DRACONIAN BEHAVIOR OF MS. 14 of 146 FILED: QUEENS COUNTY CLERK 10/25/2023 03:55 PM INDEX NO. 722594/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/25/2023 (26" . LESSER CAUSE OF ACTION) 113-118 30) FAILURE TO PERFORM HER FIDUCIARY OBLIGATION AND IMPROVE VIOLATIONS WITH 27TH LEISURE CLUB ( CAUSE OF ACTION) PAGES 119-123 31) DEMAND FOR DAMAGES (28" CAUSE) OF ACTION PAGES 124-128 29" 32) PUNITIVE DAMAGES ( CAUSE OF DAMAGE) PAGES 132-134 33) SUMMARY, PAGES 135-136 15 of 146 FILED: QUEENS COUNTY CLERK 10/25/2023 03:55 PM INDEX NO. 722594/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/25/2023 8 ' meansl' Stated The end justifies the COMPLAINT FILED ON 4/2 2019 BEATRICE LESSER, FILED with Queens County Clerk. The complaint that consists of 12 pages making false allegations which Plaintiff will debunk at trial. On page # 3 bullet # 18 of the complaint Ms. Lesser states the following; UPON INFORMATION AND BELIEF ' MOST IF NOT ALL OF HIS FURNITURE HAS BEEN DISCARDED AND LEFT ON THE STREET IT!' WHERE DEFENDANT FINDS . 16 of 146 FILED: QUEENS COUNTY CLERK 10/25/2023 03:55 PM INDEX NO. 722594/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/25/2023 9 THE EQUlVALENT WOULD BE TO STATE A PERSON IS A CHILD MOLESTER. THE ACCOUNTANT IS A CROOK! MY NEIGHBOR STEALS PROPERTY. THE STUDENT PLAGARIZES. THE DENTIST FOLDLES HIS PATIENTS. WITHOUT PROOF ALL OF THE ABOVE ARE VICIOUS LIES THAT COULD CAUSE IRREPARABLE DAMAGE TO AN INNOCENT VICTIM. F" UPON INFORMATION AND BELIE 17 of 146 FILED: QUEENS COUNTY CLERK 10/25/2023 03:55 PM INDEX NO. 722594/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/25/2023 to This phrase used by attorneys is a method of defaming someone, without taking responsibility or fault. It is an EXCULPATORY phrase, a weasel clause where a party can state something VILE and have No penalties exacted, simply by injection of this phrase. Ms. Lesser did not do her homework As plaintiff has . She is obligated to name the source that supplied this information, and obligated to answer any related questions that plaintiff requests. How vulgar to stoop to such level as has Ms. Lesser! This statement was mean spirited, intended to place plaintiff as a low tier dealer , as opposed to the established, respected dealer who some auction houses place in the highest esteem. CONSEQUENCES: I have been black mailed in my business ,threatened to expose the 18 of 146 FILED: QUEENS COUNTY CLERK 10/25/2023 03:55 PM INDEX NO. 722594/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/25/2023 11 false and vile lies set in place by this despicable act of Ms. Lesser. My business suffered substantial Loses financially due to this tract.1 have suffered from people who trusted me, and now hold me suspect. I have started this business , part time in 1985. I have traveled overseas too many times to count, and have a pristine reputation. I have set auction records at both Christies and Swann Galleries and donated most proceeds to charity. The clients developed at the Bay Club, all seven will no longer buy from me. This one career Ending sentence is enough to have Ms. Lesser serve the harshest penalty.