On October 12, 2023 a
Letter,Correspondence
was filed
involving a dispute between
City Of Binghamton, New York,
and
Not Applicable. Map 9,
for Real Property - Condemnation
in the District Court of Broome County.
Preview
FILED: BROOME COUNTY CLERK 11/15/2023 01:06 AM INDEX NO. EFCA2023002255
NYSCEF DOC. NO. 34 RECEIVED NYSCEF: 11/15/2023
F R O M TH E DE SK O F
L IA M B U RN S
November 15, 2023
Hon. Oliver N. Blaise III J
Justice of the Supreme Court Supreme Court Chambers
Broome County Courthouse
P.O. Box 1766
Binghamton, NY 13902
Dear Justice Blaise:
I am compelled to write to you regarding the ongoing eminent domain proceedings
EFCA2023000254, and EFCA2023000255, to urgently highlight a deeply troubling
pattern of subversion by Robert S. Hite of HITE & BEAUMONT, P.C., representing the
City of Binghamton, a pattern which strikes at the very heart of legal integrity and due
process.
The primary issue, which forms the basis of my motion to dismiss, is the significant
procedural error concerning the omission of my entity's name in the caption and the
resulting chaos in attempting to register with NYCEF. This is not a trivial or
inconsequential matter; it is a glaring breach of procedural norms that has materially
affected my ability to participate in the legal process. The neglect to correctly identify
my entity in legal documents has impeded my fundamental right to a fair and timely
response, undermining the basic tenets of justice.
Regrettably, the response from the Robert S. Hite has consistently been to evade this
core issue, choosing instead to engage in a strategy of legal sidestepping and
deflection. This pattern of response is not only dismissive but also indicative of an
approach that seeks to trivialize and overlook critical procedural failings. For instance,
the City incorrectly challenges my telephone transcript claiming Mr. Hite was in
Massachusetts a two-person consent state, despite the recording clearly occurring in
New York, thus making his location irrelevant. The most recent communication from
the Mr. Hite, which culminates in a remark about my non-status as a dentist,
exemplifies this tendency towards trivial and irrelevant argumentation. Such
responses are not only disrespectful but also detract significantly from the substantive
legal concerns that should be the focus of these proceedings.
9 0 RIV E RS ID E D R . BI N G H A M TO N N Y (607) 240-8714
1 of 2
FILED: BROOME COUNTY CLERK 11/15/2023 01:06 AM INDEX NO. EFCA2023002255
NYSCEF DOC. NO. 34 RECEIVED NYSCEF: 11/15/2023
This behavior represents more than mere legal oversight; it is a deliberate and
ongoing strategy to undermine the principles of due process and fair legal practice,
which by all virtues is the very merit of this motion. It is a tactic that I find not only
legally unsound but also deeply concerning in a system that upholds the rule of law.
Given the severity of these procedural irregularities and the pattern of obfuscation by
the Mr. Hite, I urge the Court to recognize the gravity of this matter. My motion to
dismiss is predicated on these substantial procedural breaches, which warrant serious
and immediate consideration. The integrity of our legal system is contingent upon the
equitable treatment of all parties involved and the adherence to established legal
procedures.
I respectfully request that the Court not allow Mr. Hite, HITE & BEAUMONT, P.C., and
the City of Binghamton’s procedural gamesmanship to overshadow the critical issues
at stake and to grant my motion to dismiss on its substantive, cited, precedented, and
meticulous merits.
Given the seriousness of these procedural breaches and the mr. Hite’s pattern of
diversionary and trivializing responses, it is imperative that the Court takes decisive
action. The integrity of our legal system and the principles of due process are at stake.
I am confident that this Court, in its wisdom and commitment to justice, will not only
recognize but also rectify these procedural transgressions. By doing so, the Court will
reinforce the trust and reliability inherent in our judicial system. I thank you for your
thorough consideration of these matters and look forward to a resolution that upholds
the highest standards of justice
Thank you for your attention to this pressing matter.
Respectfully,
Liam Burns
90 Riverside Dr.
Binghamton, NY 13905
TheLiamBurns@gmail.com
607-240-8714
2 of 2
Document Filed Date
November 15, 2023
Case Filing Date
October 12, 2023
Category
Real Property - Condemnation
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Preview
FILED: BROOME COUNTY CLERK 11/15/2023 01:06 AM INDEX NO. EFCA2023002255 NYSCEF DOC. NO. 34 RECEIVED NYSCEF: 11/15/2023 F R O M TH E DE SK O F L IA M B U RN S November 15, 2023 Hon. Oliver N. Blaise III J Justice of the Supreme Court Supreme Court Chambers Broome County Courthouse P.O. Box 1766 Binghamton, NY 13902 Dear Justice Blaise: I am compelled to write to you regarding the ongoing eminent domain proceedings EFCA2023000254, and EFCA2023000255, to urgently highlight a deeply troubling pattern of subversion by Robert S. Hite of HITE & BEAUMONT, P.C., representing the City of Binghamton, a pattern which strikes at the very heart of legal integrity and due process. The primary issue, which forms the basis of my motion to dismiss, is the significant procedural error concerning the omission of my entity's name in the caption and the resulting chaos in attempting to register with NYCEF. This is not a trivial or inconsequential matter; it is a glaring breach of procedural norms that has materially affected my ability to participate in the legal process. The neglect to correctly identify my entity in legal documents has impeded my fundamental right to a fair and timely response, undermining the basic tenets of justice. Regrettably, the response from the Robert S. Hite has consistently been to evade this core issue, choosing instead to engage in a strategy of legal sidestepping and deflection. This pattern of response is not only dismissive but also indicative of an approach that seeks to trivialize and overlook critical procedural failings. For instance, the City incorrectly challenges my telephone transcript claiming Mr. Hite was in Massachusetts a two-person consent state, despite the recording clearly occurring in New York, thus making his location irrelevant. The most recent communication from the Mr. Hite, which culminates in a remark about my non-status as a dentist, exemplifies this tendency towards trivial and irrelevant argumentation. Such responses are not only disrespectful but also detract significantly from the substantive legal concerns that should be the focus of these proceedings. 9 0 RIV E RS ID E D R . BI N G H A M TO N N Y (607) 240-8714 1 of 2 FILED: BROOME COUNTY CLERK 11/15/2023 01:06 AM INDEX NO. EFCA2023002255 NYSCEF DOC. NO. 34 RECEIVED NYSCEF: 11/15/2023 This behavior represents more than mere legal oversight; it is a deliberate and ongoing strategy to undermine the principles of due process and fair legal practice, which by all virtues is the very merit of this motion. It is a tactic that I find not only legally unsound but also deeply concerning in a system that upholds the rule of law. Given the severity of these procedural irregularities and the pattern of obfuscation by the Mr. Hite, I urge the Court to recognize the gravity of this matter. My motion to dismiss is predicated on these substantial procedural breaches, which warrant serious and immediate consideration. The integrity of our legal system is contingent upon the equitable treatment of all parties involved and the adherence to established legal procedures. I respectfully request that the Court not allow Mr. Hite, HITE & BEAUMONT, P.C., and the City of Binghamton’s procedural gamesmanship to overshadow the critical issues at stake and to grant my motion to dismiss on its substantive, cited, precedented, and meticulous merits. Given the seriousness of these procedural breaches and the mr. Hite’s pattern of diversionary and trivializing responses, it is imperative that the Court takes decisive action. The integrity of our legal system and the principles of due process are at stake. I am confident that this Court, in its wisdom and commitment to justice, will not only recognize but also rectify these procedural transgressions. By doing so, the Court will reinforce the trust and reliability inherent in our judicial system. I thank you for your thorough consideration of these matters and look forward to a resolution that upholds the highest standards of justice Thank you for your attention to this pressing matter. Respectfully, Liam Burns 90 Riverside Dr. Binghamton, NY 13905 TheLiamBurns@gmail.com 607-240-8714 2 of 2