Preview
= INDEX NO. 16328/2008
NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 00/13/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
360 ADAMS STREET
BROOKLYN, NY 11201
PH. 718-675-7699
NATIONAL CITY MORTGAGE
#3, (MO
3232 Newmark Drive
~y KCS.
Miamisburg, Ohio 45342
OKTO BE FY
Plaintiff
Ne
dex No 1308-200 i[22| 17
Against
PATRICIA LEE STOKES A/K/A PATRICIA L.
STOKES, ROBERT STOKES A/K/A ROBERT
W. STOKES, CAPITAL ONE BANK, NEW
YORK CITY ENVIRONMENTAL CONTROL
BOARD, NEW YORK CITY PARKING
VIOLLATIONS BUREAU, NEW NORK CITY
TRANSIT ADJUDICATION BUREAU, THE
BANK OF NEW YORK, US DEPARTMENT
te
OF JUSTICE, UNITED STTATE OF
AMERICA
Defendants
754 of 1117
INDEX NO. 16328/2008
NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 00/13/2023
Ay é&* ~~
Pa
}
rr
Not
soi
755 of 1117
INDEX NO. 16328/2008
NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 00/13/2023
lam Patricia Lee Stokes, a defendant in this foreclosure matter. | have lived at the
address shown above since | purchased the house in 2000. Robert Stokes, a named
defendant in this case has never lived in the house, and has never stayed in the house
that is the subject of this foreclosure action. | moved away from Bob Stokes, who lived
in Michigan, and had not lived with Bob Stokes for over 10 years when Bob Stokes
worked with his attorneys at Weissman, Young, Schloss and Ruemanapp Law Firm in
illegally taking my 401K retirement plan worth over $1 million dollars. Bob Stokes and his
attorneys attached a federal lien to my house in Brooklyn, in order to pay a federal fine
that was owed by Bob stoke’s medical Professional Corporation. | did not agree to
that. Bob Stokes and his attorneys also arranged an illegal sale of my $7.3 million dollar
house in Michigan. As you will see in the evidence included in my objections 1-8
below, Bob Stokes and his attorneys worked in criminal cooperation with Lars Anderson,
the CEO of National City Mortgage, and with the Plaintiffs Attorneys in this case, and
with Judge Lawrence Knipel, who has been the Judge in this case of home foreclosure.
There has been significant Judicial misconduct and criminal fraud on the part of the
Plaintiff and Plaintiffs Attorneys, and the previous Judge in this foreclosure case, in
cooperation with the defendant Bob Stokes. Under the New York six year rule, the
Plaintiff's foreclosure case, which was filed in June of 2008 expired in June of 2014.
This objection was included in my response to Plaintiff's motion in March of 2018.
756 of 1117
INDEX NO. 16328/2008
NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 00/13/2023
Plaintiff's motion before this court January 22°4, 2019 was filed in an effort to have the
court appoint a new mediator. The previous mediator, who was appointed in June of
2018 declined the work. Plaintiff failed to provide me with any notice of Plaintiff's June
2018 motion, leaving me with no opportunity fo respond and object. When the first
mediator declined the work, Plaintiff filed a motion scheduled for November 2018 in
order to name a new mediator. | appeared for the November 2018 motion. Plaintiff
failed to appear. The motion was rescheduled to January 22, 2019. | object to
Plaintiff's motion for the following reasons:
OBJECTION #1.) Lack of required pre-foreclosure notice, and lack of required
foreclosure notice. Real Property Actions and Proceedings Law RPAP § 1304. RPAPL
§1304[2] Further provides that such notice must be sent by registered or certified mail,
and also by first-class mail, to the borrower. Steven Baum, Plaintiff's attorney for
National City Mortgage, filed the foreclosure action in 2008.
1-A.) There was no pre-foreclosure notification served on me as is required by RPAPL
§1304[2] There was no foreclosure notice served on me, which is required by RPAPL
§1304(2]
1-B.) Improper and defective service: There are seven Affidavits of Service for Steven
Baum’s motions that were included in Gross Pollowy'’s March , 2018 motion before
Judge Knipel. Steven Baum's father , [Exhibit 1-A] used a false name name, Anthony
Barone, and acted as the notary public on all of the Affidavits of Service for Steve
Baum's foreclosure action, and motions. The fact that a family member served as the
notary invalidated all seven of Steven Baum's Affidavits of Service which in fact were
757 of 1117
INDEX NO. 16328/2008
NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 00/13/2023
never served. There is an inherent conflict of interest on the part of the notary for all of
the Affidavits of Service. Steven Baum's father could not have been an impartial
witness or a disinterested party, and could not have served as a notary for any of the
Affidavits of Service for Steven Baum. Notary Anthony Barone is former CIA Director
Hoyt Vandenberg. Barone is a Ludwick Nobel descendant of the Royal Dutch Shell oil
company.
1-C.) Legal Precedent: In TD Bank, N.A. v. Leroy, 121 A.D. 3d 1206 (3 Dept. 2014), the
Third Department dismissed the Complaint and denied the Plaintiff's motion for
summary judgment, holding that the mortgagee failed to comply with the mandatory
RPAPL §1304 condition precedent to commencing the foreclosure action.
As a result of Plaintiff's failure to comply with RPAP § 1304, and because of improper
service as a result of the use of a family member as notary on all of the Affidavits of
Service, the court must dismiss Plaintiff's claim of foreclosure.
OBJECTION #2.) Judicial misconduct by Judge Knipel, working in criminal cooperation
with the Plaintiff and Plaintiff's Attorneys in this foreclosure matter.
CPLR 5015(a) provides: The court which rendered a judgment or order may relieve a
party from it upon such terms as may be just, on motion of any interested person with
such notice as the court may direct, upon the ground of: 1. excusable default, if such
motion is made within one year after service of a copy of the judgment or order with
written notice of its entry upon the moving party, or, if the moving party has entered the
judgment or order, within one year after such entry; or 2. newly-discovered evidence
ti t! ve
which could not have been discovered in time to move for a new trial under section
758 of 1117
INDEX NO. 16328/2008
NYSCEF DOC. NO. 28 RECEIVED NYSCEF: @0/13/2023
4404; or 3. misrepresentation,
fraud, or other misconduct of an adverse party: or 4. lack
of jurisdiction to render the judgment or order; or 5,modification
reversal. or vacatur of
Qprior judament or order upen which itis based.
| focus on the underlined portions of CPLR 5015 (a) above. There is newly
discovered evidence of serious Judicial Misconduct on the part of Judge
Lawrence Knipel which shows Judge Lawrence Knipel's coordination of efforts
with the Plaintiffs and Plaintiffs Attorneys and one of the defendants, Bob Stokes
in this foreclosure matter. In 2014. Judge Lawrence Knipel dismissed Plaintiff's
claim for lack of activity. The Plaintiff had one year to appeal that ruling and
did not do so. In fact, the Plaintiff did not file an appeal to that ruling until
March of 2018. During 2014, however, the foreclosure action expired under
CPLR §204 (a),the New York Six Year Statute of Limitations. The evidence
shown in [Exhibit 2-A] shows that Judge Lawrence Knipel is Stalin descendant of
William Wesley Peters and Svetlana Stalin, a relative of Thomas Rosicki, one of
the Plaintiff's attorneys in this foreclosure matter. Thomas Rosicki is the son of
David Koch, another Stalin descendant. Exhibit 2-A shows that Judge Knipel ,
the Judge in this foreclosure case, has previously worked in criminal cooperation
with the Plaintiff and Plaintiff's attorneys and with Bob Stokes, one of the named
defendants in this case, in posing in photos as 9-11-01 false victims of Flight 11,
Flight 93 and Flight 175. Exhibit 2-A also shows that Bob Stokes is currently
working with Mikhail Khodorkovsky, the former CEO of Yukos Oil Company. Lars
Anderson was previously using the name Francoise Buclez, a member of the
5
759 of 1117
INDEX NO. 16328/2008
NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 00/13/2023
board of directors for Yukos Oil Company. Defendant Bob Stokes and Plaintiff
National City Mortgage CEO Lars Anderson have a prior criminal business
connection.
2-A.) As Plaintiff's attorney Steven Baum was put out of business by the Attorney
General for the State of NY, Svetlana Kaplun, an attorney at Druckman Law Firm
became the second Plaintiff's attorney. Svetlana Kaplun filed a motion in 2014 and did
not appear for her own motion. |appeared. Judge Knipel did not rule on Svetlana
Kaplun's motion, Judge Lawrence Knipel noted the non - appearance of attorney
Svetlana Kaplun, and dismissed the Plaintiff's claim due to inactivity.
Under CPLR § 5015, Svetlana Kaplun had one year until 2015 to file an appeal to the
court's ruling pursuant to CPLR Rule 5015 Relief from Judgment or Order, but did not do
so. Plaintiff made no further motions before the court until March of 2018. The
Plaintiff was time barred by CPLR 5015, and lost the right to appeal Judge Knipel's
ruling of dismissal of their claim.
In 2018 however, Gross Pollowy filed a motion before Judge Knipel , asking him to
vacate his prior ruling. In my response, one of my objections was based on CPLR Rule
5015, the expiration of the 1 year statute of limitations to appeal Judge Knipel’s ruling.
Judge Knipel did not rule on my objections to the motion, but vacated his prior ruling.
He knew that he was already guilty of Judicial misconduct. Svetlana Kaplun’s photo
appears online, and is shown in [Exhibit 2-A]. Note that the photograph shows that
Judge Lawrence Knipel himself posed as female attorney Svetiana Kaplun. Judge
760 of 1117
INDEX NO. 16328/2008
NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 00/13/2023
Knipel posed as Plaintiff's attorney Svetlana Kaplun, and filed the 2014 motion to be
head before his own court. Note that Judge Lawrence Knipel also appears in another
photo in [Exhibit 2-A] with Blackwater International Executive Anna Bundy. Note that
Judge Lawrence Knipel also appears in another photograph in [Exhibit 2-A] as one of
the victims of Flight 175 on 9-11-01, presumed to have died on 9-11-01.
2-B.) Eric Prince, the CEO of Blackwater International also appears in photos as one of
the victim passengers on Flight 175, the same flight as Judge Lawrence Knipel. [Exhibit
2-B] Defendant Bob Stokes also appears in photos as one of the victim passengers of
9/11/01 Flight 175. [Exhibit 2-A and Exhibit 2-L] Plaintiff's attorney Cynthia Rosicki is
defendant Bob Stokes's half sister. Tom Rosicki's mother also appeared in photos as
one of the victims of 9-11-01 Flight 11. [Exhibit 2-L] Gross Pollowy Attorney Lisa Pollowy
also appears in photos as one of the victim passengers of 9-11-01 Flight 175. [Exhibit 2-
G] Attorney Svetlana Kalun held one status conference. | appeared for that status
conference. Svetlana Kaplun did not appear. Judge Knipel did appear for that
motion, and noted the non - appearance of Svetlana Kaplun, and dismissed the
Plaintiff's claim for inactivity from 2008 to 2014.
There had been no activity on the foreclosure action since it was filed by Steven Baum
in June of 2008 until Judge Knipe! dismissed the claim in 2014. The foreclosure action
was set to expire in June of 2014. Judge Knipel’s motion before his own court
occurred just before the foreclosure action expired under CPLR §204 (a),the New York
Six Year Statute of Limitations. Regardless of Judge Knipel's ruling the foreclosure
action expired in 2014.
761 of 1117
INDEX NO. 16328/2008
NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 00/13/2023
2-C.) Plaintiff's next motion was filed in 2018 by Gross Pollowy. Under CPLR §5015
Plaintiff had one year to appeal Judge Knipels 2014 ruling to dismiss their claim but
failed to do so within the time limitations. By 2018 Plaintiff was time barred from
appealing Judge Knipel's 2014 dismissal of their claim. In addition to this, the
foreclosure action expired in June of 2014 under CPLR§204. There is a second
individual who has posed in photos as Svetalana Kaplun #2. Svetlana Kaplun #2 is a
known Iraqi terrorist, Abu Ayub Al Masri, who is wanted by the US State Department.
[Exhibit 2-C] Svetlana Kaplun #2 is not permitted to enter the US, nor could he practice
law in the US, nor could he file any motions in any court in NY.
Whether the motion was filed by Svetlana Kaplun #1, Judge Knipel, or Svetlana
Kaplun #2, a known terrorist, Svetlana Kaplun's motion was an illegal motion which
could not be heard before Judge Knipel. Judge Knipel did not actually rule on the
motion filed by Svetiana Kaplun. Judge Knipel noted the non- appearance of Svetlana
Kaplun, and dismissed the claim based on inactivity in the foreclosure matter from 2008
- 2014. The foreclosure action was set to expire at the point Judge Knipel made that
ruling and did expire in June of 2014 under CPLR §204 (a),the New York Six Year Statute
of Limitations. Svetlana Kaplun's motion was an illegal motion, and Svetlana Kaplun
did not even appear for that motion, which cannot be counted as any action being
taken by the Paintiff. In total there was no action taken whatsoever by the Plaintiff
from the point of filing the foreclosure action in June of 2008 until Gross Pollowy’s
motion in March of 2018.
2-D.) Under CPLR 5015 Plaintiff had a one year 1 year to appeal Judge Knipel's ruling
and did not do so. The next motion filed by Gross Pollowy Law Firm, the third Plaintiff's
attorney, asking Judge Knipel to vacate his prior ruling to dismiss their claim was in 2018.
762 of 1117
INDEX NO. 16328/2008
NYSCEF DOC. NO. 28 RECEIVED NYSCEF: @0/13/2023
Plaintiff had only one year, from 2014-2015 to appeal the dismissal. Plaintiff's motion
in 2018, asking the court to vacate its prior ruling was too late. Plaintiff was time barred
from appealing the 2014 ruling of Judge Knipel.
2-E.) Regardless of Judge Knipel's 2014 ruling to dismiss Plaintiff's claim for inaction, the
foreclosure action filed by Steven Baum in 2008 expired that same year, in 2014 under
CPLR §204 (a),the New York Six Year Statute of Limitations. This point was raised in my
objections to the Gross Pollowy motion in 2018. Judge Knipel did not note or rule on
this objection.
2-F.) Please see [Exhibit 2-A ], and notice that Judge Lawrence Knipel is shown in one
photo walking with Anna Bundy of Blackwater International. Judge Lawrence Knipel is
the son of Svetlana Stalin and William Wesley Peters. Craig Nixon, another Stalin
descendant, and relative of Judge Knipel is the current CEO of Blackwater
International, which is now called “XE.” {Exhibit 2-A] contains one photo showing
Judge Knipel posing as one of the victims of Flight 175 on 9-11-01. That plane was the
second plane to hit the WTC on 9-11-01. That passenger (who was Judge Knipel) was
presumed to have died, and would have collected from a life insurance policy taken
out under another name. [Exhibit 2-F] Shows that National City Mortgage CEO, Lars
Anderson, the Plaintiff in this foreclosure case, also posed as one of the reported
passengers on Flight 93 on 9-11-01.
2-G.) [Exhibit 2-G] Shows that Lisa Pollowy, the senior partner of the Gross Pollowy Law
Firm also posed in photos shown here, as one of the passengers on Flight 175 on 9-11-
ol.
2-H.) [Exhibit 2-H] Shows another of the Gross Pollowy attorneys who uses the name Ben
Elmore is another Stalin descendant, and is also the CEO of a software development
763 of 1117
INDEX NO 16328/2008
NYSCEF DOC. NO. 28 RECEIVED NYSCEF 0/13/2023
company “Twin Technologies” in Albany, NY. Gross Pollowy Law Firm is located in or
around Albany, NY. Ben Elore is shown in the photo in [Exhibit 2-H] with one of his
developers, who also posed in photos shown here as one of the false passengers on
Flight 93 on 9-11-01 “Tom Burnett.”
2-1.) [Exhibit 2-I] Shows attorney Plaintiff's attorney for J.P. Morgan Cynthia Rosicki and
her husband Tom Rosicki of Rosicki and Rosicki Law Firm, Plaintiff's attorneys for J.P.
Morgan, a Plaintiff in this case. Bob Stokes is a named defendant in this foreclosure
case. Cynthia Rosicki, Bob Stokes's half sister, is one of the Plaintiff's attorneys in this
case. [Exhibit 2-1] shows that Lom Rosicki's father is David Koch, a Stalin descendant. a
family member of Judae Lawrence Knipel, David Koch's wife Julia Koch posed in
photos published in US NEWS as a Flight Attendant aboard Flight 11 on 9-11-01, under
the name Jennifer Lewis. David Koch is shown in [Exhibit 2-l] to have posed in this
photo as one of the NYPD killed in the line of duty. Tom Rosicki, Plaintiff's attorney for
J.P. Morgan in this case, is shown in [Exhibit 2-I] to have posed in this photo as one of
the reported “victims” of the Las Vegas Shooting Incident. Each of the false victims
shown in these exhibits collected from life insurance policies taken out in advance of
the 9-11-01 attack and the Las Vegas Shooting Incident. Each of them would have
also collected from federal funds intended for the families of those victims, which is a
violation of the Federal False Claims Act. These exhibits show coordination of efforts in
life insurance fraud, and Federal False Claims Act violations, and coordination of efforts
in two terrorist attacks by the Plaintiff and Plaintiffs attorneys who were working in
criminal coordination of efforts with the Judge in this case. Blackwater International
and its CEO Eric Prince was clearly involved in the 9-11-01 attack against the US, posing
as false passengers on 9-11-01 Flights 93, 11, and 175 as shown in these exhibits.
10
764 of 1117
INDEX NO. 16328/2008
NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 00/13/2023
2-J.) [Exhibit 2-J] Shows Blackwater International (XE) CEO Craig Nixon posed as one of
the victims of the more recent Las Vegas Shooting Incident. He would have collected
from a life insurance policy for that terrorist incident. He would also have collected
from federal funds intended for victims of that shooting incident. He is a Stalin
descendant.
2-K.) [Exhibit 2-K] shows that there were 8 other Stalin family members who participated
in the 9-11-01 attack and the Las Vegas Shooting incident, including Mayor Rick
Deblasio, a Stalin descendant of Nadezhda Stalin. Mayor DeBlasio posed as one of the
FDNY who died in the line of duty on 9-11-01. The Plaintiff and Plaintiff's attorneys and
the Judge in this matter have coordinated efforts in home foreclosures in New York.
The photos in [Exhibits 2-A , 2-B, 2-F, 2-G, 2-H, 2-1, 2-J, 2-K ] contain criminal evidence
that the Plaintiff and Plaintiffs attorneys in this case posed in photos published in US
NEWS as victims of 9-11-01 Flight 11 and Flight 175 and Flight 93. This is a criminal
connection by Judge Lawrence Knipel to life insurance fraud and Federal False Claims
Act Violations/ This is also significant evidence of treason against the United States and
adherence to the enemies of the United States on the part of the Plaintiffs in this case
and their attorneys, and Judge Lawrence Knipel. This shows foreknowledge of the
attack, and is evidence of steps that were taken to profit from the attack. Years after
the 9-11-01 attack, they are still clearly working together. Judge Knipel has clearly
worked in criminal cooperation with the Plaintiffs in this case of home foreclosure.
2-L.) [Exhibit 2-L] My 2.4 husband, Bob Stokes'’s half sister is Cynthia Rosicki, who is
married to attorney Tom Rosicki, one of the Stalin descendants, David Koch's son.
Janet Rosicki is the plaintiff's attorney working for J.P. Morgan in this case. Bob Stokes is
a defendant in this case. Bob Stokes took out a 2"4 mortgage in 2008 by illegally
11
765 of 1117
INDEX NO. 16328/2008
NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 00/13/2023
signing my name to 2"4 mortgage documents with National City Mortgage. National
City Mortgage’s CEO Lars Anderson was already shown in [Exhibit 2-F] to have posed in
photographs as one of the passengers on 9-11-01 Flight 93. Bob Stokes is the son of
Leona Helmsley of Helmsley Spears, who was a man. Bob's mother was Gretta Garbo.
Gretta Garbo's daughter by a different husband is attorney Janet Rosicki, the Plaintiff's
attorney representing J.P. Morgan. Leona Helmsley died in 2002 to my knowledge.
Bob Stokes inherited Helmsley Spears.
2-M.) [Exhibit 2-L ] shows Bob Stokes and Janet and Tom Rosicki.
2-N.) [Exhibit 2-L] shows Bob Stokes posing as one of the passengers on Flight 175, the
same flight as Eric Prince, the CEO of Blackwater International and the same 9-11-01
flight as Judge Lawrence Knipel. Bob Stokes and Judge Lawrence Knipel and Lars
Anderson, the CEO of National City Mortgage, and the Plaintiff's attorneys working for
National City Mortgage and J.P. Morgan were working together with Blackwater
International, posing in photos as false victims of the 9-11-01 attack. This shows
foreknowledge of the attack, and is evidence of steps that were taken to profit from
the attack. They did not take steps to save innocent civilian lives, by alerting authorities
of the pending attack.
2-O.) [Exhibit 2-O] shows New York FBI Director Diego Rodriguez posing as one of the
passengers aboard Flight 175 on 9-11-01. Diego Rodriguez is Bob Stokes's half brother.
Diego Rodriguez is the son of Leona Helmsley and Barbara Walters.
2-P.) From the evidence included here in Exhibits 2-A through 2-0, it is clear that Judge
Lawrence Knipel, the Judge in this foreclosure case until this point, acted in criminal
coordination of efforts with the Plaintiffs and the Plaintiff's attorneys in this foreclosure
matter, and one of the defendants in this same foreclosure matter.
12
766 of 1117
INDEX NO. 16328/2008
NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 00/13/2023
Whether Judge Knipel posed as Svetiana Kaplun #1 and filed a motion to be heard
before his own court, or whether Svetlana Kaplun #2 filed the motion, it was an illegal
motion before his court, but for the reasons listed below, it is most likely that Judge
Knipel posed as Svetlana Kaplun #1 and filed the motion to be heard before his own
court.
Judge Knipel did not rule on the motion for one of twe reasons: Either Svetlana Kaplun
was not there, or Judge Knipel was in fact, Svetlana Kaplun.
In Gross Pollowy's motion filed by Gross Pollowy in 2018, Gross Pollowy included a Sworn
Affidavit from Svetlana Kaplun that she in fact did appear for her 2014 motion.
| appeared for that motion. Svetlana Kaplun did not appear. Judge Knipel in fact
noted the non- appearance of Svetlana Kaplun in his ruling. If her Svetlana Kaplun’s
Affidavit would be considered to be truthful and she really appeared for that motion,
why would Svetlana Kaplun not have taken the necessary steps to make certain that
her own appearance was noted, and her motion before the court was heard that
day? If she was there and did not notice me or felt that | did not appear, why would
attorney Svetlana Kaplun, who filed the motion, not take the necessary steps to see to
it that this was entered into the court record in order to get a default judgement in
favor of Plaintiff? Itis not credible that the attorney who filed the motion took no
action. Furthermore, when Judge Knipel noted Svetlana Kaplun's non- appearance,
Svetlana Kaplun took no action to correct this and appeal Judge Knipel’s ruling. She
had one year to appeal Judge Knipel’s dismissal of the claim, and did not do so. If
we are to believe the sworn statement by Svetlana Kaplun, either a known terrorist
wanted by the US State Department was present in court for that motion, and took no
action whatsoever, or Svetlana Kaplun was in fact Judge Knipel. Because | appeared
13
767 of 1117
INDEX NO. 16328/2008
NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 00/13/2023
for that motion, there could be no default judgment entered by Judge Knipel. |
believe that Judge Knipel who is shown in Exhibit 2-A to have posed in photos as
Svetlana Kaplun, filed the 2014 motion to be heard before his own court. What
possible explanation could Judge Knipel offer the court for that photograph? From the
evidence shown in 2-A through 2-0, it is clear that Gross Pollowy attorneys were
working in criminal cooperation with Judge Knipel in posing in photos as passengers on
9-11-01 fights 11,93. and 175. The sworn statement included in Gross Pollowy's March
of 2018 motion was perjury, and Gross Attorneys know that and still submitted the sworn
statement to the court.
NY Consolidated Laws. Penal Law §175.40 Issuing a False Certificate: A person is guilty
of issuing a false certificate when, being a public servant authorized by law to make or
issue official certificates or other official written instruments, and with intent to defraud,
deceive or injure another person, issues such an instrument, or makes the same with
intent that it be issued, knowing that it contains a false statement or false information.
Issuing a false certificate is a class E felony, an egregious violation on top of the criminal
coordination of efforts in connection to the 9-11-01 attack and the Las Vegas Shooting
incident already shown in [Exhibits 2-A , 2-B, 2-F, 2-G, 2-H, 2-1, 2-J, 2-K, 2-L, 2-0]
Under CPLR 5015 Plaintiff had a one year window of time to appeal Judge Knipel’s
dismissal but did not do so. Svetlana Kaplun took no further steps at all. Plaintiff's
attorney Gross Pollowy filed a motion in March of 2018, asking Judge Knipel to vacate
his prior ruling to dismiss their claim was filed too late to be considered by the court.
Plaintiff was time barred in 2018 from appealing Judge Knipel’s 2014 ruling. In addition
to this, the foreclosure action, and the plaintiff's ability to foreclose on this house
expired in 2014, regardless of Judge Knipel's ruling to dismiss Plaintiff's claim for inaction,
14
768 of 1117
INDEX NO. 16328/2008
NYSCEF DOC. NO. 28 RECEIVED NYSCEF: @0/13/2023
or the lack of timely appeal by the Plaintiff, under CPLR §204 (a),the New York Six Year
Statute of Limitations,
My response to the 2018 motion by Gross Pollowy included my objection based on
CPLR 5015, expiration of Plaintiff's one year window of time to appeal Judge Knipel’s
ruling. In March of 2018 | knew only about Svetlana Kaplun #2, Abu Ayub Al Masri, a
known terrorist wanted by the US State Department. | did not know that Judge Knipel
himself had posed in photos as Svetlana Kaplun and had filed the 2014 motion to be
heard before he own court. It is clear that he could not be both Judge and Plaintiff's
attorney, and sought a default judgment if | failed to appear for that motion. But | did
appear for that motion, and Svetlana Kaplun did not appear. [Exhibits 2-A ] shows
that Judge Lawrence Knipel posed as Svetlana Kaplun #1 and filed a motion to be
heard before his own court. | did not have the information included in [Exhibit 2-A]
showing that Judge Knipel has a connection to Blackwater International employees. |
did not know that National City Mortgage CEO Lars Anderson, [Exhibit 2-F] the Plaintiff
in this case, and the Plaintiff's Attorneys in this case, and Bob Stokes, one of the
defendants in this case, and Bob's half sister, the Plaintiff's Attorney for J.P. Morgan,
and Bob's half brother, Diego Rodriguez, the Director of the FBI in NY and also Bill
DeBlasio, the Mayor of NY were criminally involved in this.
CPLR 5015(a) provides: The court which rendered a judgment or order may relieve a
party from it upon such terms as may be just, on motion of any interested person with
such notice as the court may direct, upon the ground of: 2. newly-discovered evidence
which, if introduced at the trial, would probably have produced a different result and
15
769 of 1117
INDEX NO. 16328/2008
NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 00/13/2023
which could not have been discovered in time to move for a new trial under section
4404; or 3. misrepresentation,
fraud, or other misconduct of an adverse party; or 5,
reversal. modification or vacatur of @ prior judament or order upon which itis based.
NEWLY DISCOVERED EVIDENCE: The Judge in this foreclosure action has been working
in criminal cooperation with the Plaintiffs and Plaintiff's attorneys and one of the
defendants in this foreclosure case, and dressed as Plaintiff's attorney Svetlana Kaplun,
and filed a motion to be heard before his own court. Judge Knipel reversed his 2014
dismissal of Plaintiff's foreclosure. For the above stated reasons and evidence
provided here in [Exhibits 2-A , 2-B, 2-F, 2-G, 2-H, 2-1, 2-J, 2-K, 2-L, 2-O] | ask the court
to reverse Judge Lawrence Knipel’s 2018 vacatur of his 2014 dismissal of Plaintiff's claim
of foreclosure.
There has been clear fraud, misrepresentation, and criminal misconduct on the part of
the Plaintiff and Plaintiff's attorneys and Judge and one of the defendants in this case.
| ask that the court dismisses with prejudice, Plaintiff's claim of foreclosure.
In addition to the grounds set forth in CPLR§5015(a), a court retains “its discretionary
Mi it WI it
substantial justice. “ Goldman v. Cotter, 10 A. D. 3d 289, 293, (2d Dept. 2004); Mendon
Leasing Corp. at 68; Ladd v. Stevenson, 112 N.Y. 325, 332 (1889).
OBJECTION #3.) Objection #2 notwithstanding, based on CPLR 5015, Plaintiff's one
year time limitation in which to appeal Judge Knipel’s 2014 ruling to dismiss Plaintiff's
16
770 of 1117
INDEX NO. 16328/2008
NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 00/13/2023
claim, | ask the court to overturn Judge Knipel’s March 2018 ruling to vacate his 2014
dismissal of Plaintiff's claim of foreclosure.
Under CPLR 5015(a) The Plaintiff had one vearto appeal Judge Knipel's 2014 ruling to
dismiss their foreclosure action, and did not do so. Gross Pollowy Law Firm did not file a
motion asking Judge Knipel to vacate his prior 2014 dismissal of Plaintiff's claim until
2018. Plaintiffs were time barred from filing their 2018 motion, asking the court to
reverse Judge Knipel's 2014 dismissal of their claim. Pursuant to CPLR 5015(a)
defendant asks the court to vacate Judge Knipel’s March 2018, ruling to vacate his
2014 dismissal of Plaintiff's claim.
OBJECTION #4.) Previous objections #2 and #3 notwithstanding, under the CPLR §204
(a), the New York Six Year Statute of Limitations, the foreclosure action, and the plaintiff's
ability to foreclose on this house expired in 2014, regardless of Judge Knipel’s ruling to
dismiss Plaintiff's claim for inaction, or the lack of timely appeal by the Plaintiff, and
regardless of Judge Knipel’s 2018 ruling to vacate his prior ruling to dismiss their claim.
Under CPLR §204 (a), the foreclosure action, and the plaintiff's ability to foreclose on
this house expired in June of 2014. Because Svetlana Kaplun was not able to file a
otion to be heard before Judge Knipel, there were no motions filed from the point
Plaintiff's attorney Steven Baum filed the foreclosure action in June of 2008 until March
of 2018. The Plaintiff slept on its rights to foreclose and the time to do so expired.
Pursuant to CPLR §204 (a), the court must dismiss Plaintiff's claim of foreclosure.
OBJECTION 5.) CPLR § 1402: Latches — Different from a statute of limitations, the
essential element of latches is an unreasonable delay by the plaintiff in bringing the
17
771 of 1117
INDEX NO. 16328/2008
NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 00/13/2023
claim. There was a 5 year delay in filing any motions in regards to this foreclose matter
after the initial foreclosure action was filed by Steven Baum. Svetlana Kaplun, the next
attorney to work as Plaintff's Attorney for National City Mortgage came into this case
as a Plaintiff's attorney five years after the foreclosure action was filed.
Svetlana Kaplun , whether she was Svetlana Kaplun #1 - Judge Knipel himself, or
Svetlana Kaplun #2, Abu Ayub Al Masri, a known terrorist, could not have filed a legal
motion to be heard before Judge Knipel. This means that there were no legal motions
filed in this case from the point Steven Baum filed the foreclosure action in 2008 until
Gross Pollowy filed their motion in 2018 - 10 years later. The foreclosure action was
dismissed by Judge Knipel for lack of any activity in 2014. The foreclosure action
expired under the New York Six Year Rule in 2014. In complete disregard of these
statutes of limitations, Plaintiff's attorneys waited until March of 2018, to file any other
motions, 10 years after the foreclosure action was filed.
4-D.) There has been an unreasonable and unjustifiable delay by the plaintiff in bringing
the claim; a five year delay after attorney Steven Baum was put out of business in NY
by NY Attorney General Eric Schneiderman ; another five year delay between the
illegal motion filed by Svetlana Kaplun and the next motion that was filed by Gross
Pollowy Law Firm in 2018. My objections to the legality of the 2.4 mortgage, my
objections regarding lack of pre-foreclosure, and foreclosure notices, lack of service of
any motions by Steven Baum, the non- appearance by Svetlana Kaplun, the lack of
notice by Gross Pollowy for their June, 2018 motion, and non -appearance by Gross
Pollowy for their November 2018 motion have never been heard by the court. 10 years
have elapsed between the filing of the foreclosure action and this new motion by
Plaintiff's attorneys.
18
772 of 1117
INDEX NO. 16328/2008
NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 00/13/2023
OBJECTION #5. ) CPLR § 3211 Lack of Standing - Illegal 2.4 Mortgage: National City
Mortgage has no standing to foreclose on the house at 39 72n4 Street, Brooklyn, NY.
National City Mortgage has been working in criminal coordination of efforts with one of
the defendants, Bob Stokes.
5-A.) Illegal second mortgage document signed by Bob Stokes in 2008. [Plaintiff's
Exhibit A] New York Penal Code PEN§ 470.000 Section 1700.15 First Degree Forgery
New York Penal Code Sections 170.20 — 170.40 Criminal possession of forged instruments
and devices.
An offense will be elevated to the first degree if it involves: Part of an issue of money,
stocks, bonds, or other instruments representing interests in or claims against a
corporation or other organization or its property.
5-B.) There is a complete lack of documentation by the Plaintiff, with respect to the 24
mortgage documents.
5-C.) Plaintiff and each one of the four Plaintiff's attorneys working for National City
Mortgage and J.P. Morgan has been shown in [Exhibit 2-A, 2-B, 2-F, 2-G, 2-H, 2-I, 2-J,
2-K, 2-L, 2-O, 5-E, 5-G, 5-H 5-I, 5-J] to have coordinated efforts in posing as false
victims of 9-11-01 Flight 11, Fight 93, or Fight 175, and they are connected by family and
by Blackwater International to the Las Vegas Shooting Incident, and so two terrorist
attacks against the US.
From the time | first met Bob Stokes, there has been organized fraud , and fraudulent
inducement on the part of Bob Stokes and his family members and business associates
who were working with former CIA Director William Casey, who was the son of Harry
19
773 of 1117
INDEX NO. 16328/2008
NYSCEF DOC. NO. 28 RECEIVED NYSCEF: @0/13/2023
Helmsley. The family that was introduced to me as Bob Stokes's family was not his
family. | was told that Bob's father had died when Bob was 10 years old. Bob's father
was Leona Helmsley, who was a man, and was still alive until 2002. Those men set out
to gain illegal access into a private trust that was set up for my father in the early 1900s.
They worked with GHW Bush and his family members which includes Lars Anderson, the
CEO of Gross Pollowy Law firm, the Plaintiff in this foreclosure matter, and Plaintiffs
attorneys working for Gross Pollowy Law Firm. Steven Baum is the son of former CIA
Director Hoyt Vandenberg, who served as the notary for Steven Baum in this foreclosure
action. Bob Stokes's best friend and roommate
Preview
= INDEX NO. 16328/2008 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 00/13/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS 360 ADAMS STREET BROOKLYN, NY 11201 PH. 718-675-7699 NATIONAL CITY MORTGAGE #3, (MO 3232 Newmark Drive ~y KCS. Miamisburg, Ohio 45342 OKTO BE FY Plaintiff Ne dex No 1308-200 i[22| 17 Against PATRICIA LEE STOKES A/K/A PATRICIA L. STOKES, ROBERT STOKES A/K/A ROBERT W. STOKES, CAPITAL ONE BANK, NEW YORK CITY ENVIRONMENTAL CONTROL BOARD, NEW YORK CITY PARKING VIOLLATIONS BUREAU, NEW NORK CITY TRANSIT ADJUDICATION BUREAU, THE BANK OF NEW YORK, US DEPARTMENT te OF JUSTICE, UNITED STTATE OF AMERICA Defendants 754 of 1117 INDEX NO. 16328/2008 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 00/13/2023 Ay é&* ~~ Pa } rr Not soi 755 of 1117 INDEX NO. 16328/2008 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 00/13/2023 lam Patricia Lee Stokes, a defendant in this foreclosure matter. | have lived at the address shown above since | purchased the house in 2000. Robert Stokes, a named defendant in this case has never lived in the house, and has never stayed in the house that is the subject of this foreclosure action. | moved away from Bob Stokes, who lived in Michigan, and had not lived with Bob Stokes for over 10 years when Bob Stokes worked with his attorneys at Weissman, Young, Schloss and Ruemanapp Law Firm in illegally taking my 401K retirement plan worth over $1 million dollars. Bob Stokes and his attorneys attached a federal lien to my house in Brooklyn, in order to pay a federal fine that was owed by Bob stoke’s medical Professional Corporation. | did not agree to that. Bob Stokes and his attorneys also arranged an illegal sale of my $7.3 million dollar house in Michigan. As you will see in the evidence included in my objections 1-8 below, Bob Stokes and his attorneys worked in criminal cooperation with Lars Anderson, the CEO of National City Mortgage, and with the Plaintiffs Attorneys in this case, and with Judge Lawrence Knipel, who has been the Judge in this case of home foreclosure. There has been significant Judicial misconduct and criminal fraud on the part of the Plaintiff and Plaintiffs Attorneys, and the previous Judge in this foreclosure case, in cooperation with the defendant Bob Stokes. Under the New York six year rule, the Plaintiff's foreclosure case, which was filed in June of 2008 expired in June of 2014. This objection was included in my response to Plaintiff's motion in March of 2018. 756 of 1117 INDEX NO. 16328/2008 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 00/13/2023 Plaintiff's motion before this court January 22°4, 2019 was filed in an effort to have the court appoint a new mediator. The previous mediator, who was appointed in June of 2018 declined the work. Plaintiff failed to provide me with any notice of Plaintiff's June 2018 motion, leaving me with no opportunity fo respond and object. When the first mediator declined the work, Plaintiff filed a motion scheduled for November 2018 in order to name a new mediator. | appeared for the November 2018 motion. Plaintiff failed to appear. The motion was rescheduled to January 22, 2019. | object to Plaintiff's motion for the following reasons: OBJECTION #1.) Lack of required pre-foreclosure notice, and lack of required foreclosure notice. Real Property Actions and Proceedings Law RPAP § 1304. RPAPL §1304[2] Further provides that such notice must be sent by registered or certified mail, and also by first-class mail, to the borrower. Steven Baum, Plaintiff's attorney for National City Mortgage, filed the foreclosure action in 2008. 1-A.) There was no pre-foreclosure notification served on me as is required by RPAPL §1304[2] There was no foreclosure notice served on me, which is required by RPAPL §1304(2] 1-B.) Improper and defective service: There are seven Affidavits of Service for Steven Baum’s motions that were included in Gross Pollowy'’s March , 2018 motion before Judge Knipel. Steven Baum's father , [Exhibit 1-A] used a false name name, Anthony Barone, and acted as the notary public on all of the Affidavits of Service for Steve Baum's foreclosure action, and motions. The fact that a family member served as the notary invalidated all seven of Steven Baum's Affidavits of Service which in fact were 757 of 1117 INDEX NO. 16328/2008 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 00/13/2023 never served. There is an inherent conflict of interest on the part of the notary for all of the Affidavits of Service. Steven Baum's father could not have been an impartial witness or a disinterested party, and could not have served as a notary for any of the Affidavits of Service for Steven Baum. Notary Anthony Barone is former CIA Director Hoyt Vandenberg. Barone is a Ludwick Nobel descendant of the Royal Dutch Shell oil company. 1-C.) Legal Precedent: In TD Bank, N.A. v. Leroy, 121 A.D. 3d 1206 (3 Dept. 2014), the Third Department dismissed the Complaint and denied the Plaintiff's motion for summary judgment, holding that the mortgagee failed to comply with the mandatory RPAPL §1304 condition precedent to commencing the foreclosure action. As a result of Plaintiff's failure to comply with RPAP § 1304, and because of improper service as a result of the use of a family member as notary on all of the Affidavits of Service, the court must dismiss Plaintiff's claim of foreclosure. OBJECTION #2.) Judicial misconduct by Judge Knipel, working in criminal cooperation with the Plaintiff and Plaintiff's Attorneys in this foreclosure matter. CPLR 5015(a) provides: The court which rendered a judgment or order may relieve a party from it upon such terms as may be just, on motion of any interested person with such notice as the court may direct, upon the ground of: 1. excusable default, if such motion is made within one year after service of a copy of the judgment or order with written notice of its entry upon the moving party, or, if the moving party has entered the judgment or order, within one year after such entry; or 2. newly-discovered evidence ti t! ve which could not have been discovered in time to move for a new trial under section 758 of 1117 INDEX NO. 16328/2008 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: @0/13/2023 4404; or 3. misrepresentation, fraud, or other misconduct of an adverse party: or 4. lack of jurisdiction to render the judgment or order; or 5,modification reversal. or vacatur of Qprior judament or order upen which itis based. | focus on the underlined portions of CPLR 5015 (a) above. There is newly discovered evidence of serious Judicial Misconduct on the part of Judge Lawrence Knipel which shows Judge Lawrence Knipel's coordination of efforts with the Plaintiffs and Plaintiffs Attorneys and one of the defendants, Bob Stokes in this foreclosure matter. In 2014. Judge Lawrence Knipel dismissed Plaintiff's claim for lack of activity. The Plaintiff had one year to appeal that ruling and did not do so. In fact, the Plaintiff did not file an appeal to that ruling until March of 2018. During 2014, however, the foreclosure action expired under CPLR §204 (a),the New York Six Year Statute of Limitations. The evidence shown in [Exhibit 2-A] shows that Judge Lawrence Knipel is Stalin descendant of William Wesley Peters and Svetlana Stalin, a relative of Thomas Rosicki, one of the Plaintiff's attorneys in this foreclosure matter. Thomas Rosicki is the son of David Koch, another Stalin descendant. Exhibit 2-A shows that Judge Knipel , the Judge in this foreclosure case, has previously worked in criminal cooperation with the Plaintiff and Plaintiff's attorneys and with Bob Stokes, one of the named defendants in this case, in posing in photos as 9-11-01 false victims of Flight 11, Flight 93 and Flight 175. Exhibit 2-A also shows that Bob Stokes is currently working with Mikhail Khodorkovsky, the former CEO of Yukos Oil Company. Lars Anderson was previously using the name Francoise Buclez, a member of the 5 759 of 1117 INDEX NO. 16328/2008 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 00/13/2023 board of directors for Yukos Oil Company. Defendant Bob Stokes and Plaintiff National City Mortgage CEO Lars Anderson have a prior criminal business connection. 2-A.) As Plaintiff's attorney Steven Baum was put out of business by the Attorney General for the State of NY, Svetlana Kaplun, an attorney at Druckman Law Firm became the second Plaintiff's attorney. Svetlana Kaplun filed a motion in 2014 and did not appear for her own motion. |appeared. Judge Knipel did not rule on Svetlana Kaplun's motion, Judge Lawrence Knipel noted the non - appearance of attorney Svetlana Kaplun, and dismissed the Plaintiff's claim due to inactivity. Under CPLR § 5015, Svetlana Kaplun had one year until 2015 to file an appeal to the court's ruling pursuant to CPLR Rule 5015 Relief from Judgment or Order, but did not do so. Plaintiff made no further motions before the court until March of 2018. The Plaintiff was time barred by CPLR 5015, and lost the right to appeal Judge Knipel's ruling of dismissal of their claim. In 2018 however, Gross Pollowy filed a motion before Judge Knipel , asking him to vacate his prior ruling. In my response, one of my objections was based on CPLR Rule 5015, the expiration of the 1 year statute of limitations to appeal Judge Knipel’s ruling. Judge Knipel did not rule on my objections to the motion, but vacated his prior ruling. He knew that he was already guilty of Judicial misconduct. Svetlana Kaplun’s photo appears online, and is shown in [Exhibit 2-A]. Note that the photograph shows that Judge Lawrence Knipel himself posed as female attorney Svetiana Kaplun. Judge 760 of 1117 INDEX NO. 16328/2008 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 00/13/2023 Knipel posed as Plaintiff's attorney Svetlana Kaplun, and filed the 2014 motion to be head before his own court. Note that Judge Lawrence Knipel also appears in another photo in [Exhibit 2-A] with Blackwater International Executive Anna Bundy. Note that Judge Lawrence Knipel also appears in another photograph in [Exhibit 2-A] as one of the victims of Flight 175 on 9-11-01, presumed to have died on 9-11-01. 2-B.) Eric Prince, the CEO of Blackwater International also appears in photos as one of the victim passengers on Flight 175, the same flight as Judge Lawrence Knipel. [Exhibit 2-B] Defendant Bob Stokes also appears in photos as one of the victim passengers of 9/11/01 Flight 175. [Exhibit 2-A and Exhibit 2-L] Plaintiff's attorney Cynthia Rosicki is defendant Bob Stokes's half sister. Tom Rosicki's mother also appeared in photos as one of the victims of 9-11-01 Flight 11. [Exhibit 2-L] Gross Pollowy Attorney Lisa Pollowy also appears in photos as one of the victim passengers of 9-11-01 Flight 175. [Exhibit 2- G] Attorney Svetlana Kalun held one status conference. | appeared for that status conference. Svetlana Kaplun did not appear. Judge Knipel did appear for that motion, and noted the non - appearance of Svetlana Kaplun, and dismissed the Plaintiff's claim for inactivity from 2008 to 2014. There had been no activity on the foreclosure action since it was filed by Steven Baum in June of 2008 until Judge Knipe! dismissed the claim in 2014. The foreclosure action was set to expire in June of 2014. Judge Knipel’s motion before his own court occurred just before the foreclosure action expired under CPLR §204 (a),the New York Six Year Statute of Limitations. Regardless of Judge Knipel's ruling the foreclosure action expired in 2014. 761 of 1117 INDEX NO. 16328/2008 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 00/13/2023 2-C.) Plaintiff's next motion was filed in 2018 by Gross Pollowy. Under CPLR §5015 Plaintiff had one year to appeal Judge Knipels 2014 ruling to dismiss their claim but failed to do so within the time limitations. By 2018 Plaintiff was time barred from appealing Judge Knipel's 2014 dismissal of their claim. In addition to this, the foreclosure action expired in June of 2014 under CPLR§204. There is a second individual who has posed in photos as Svetalana Kaplun #2. Svetlana Kaplun #2 is a known Iraqi terrorist, Abu Ayub Al Masri, who is wanted by the US State Department. [Exhibit 2-C] Svetlana Kaplun #2 is not permitted to enter the US, nor could he practice law in the US, nor could he file any motions in any court in NY. Whether the motion was filed by Svetlana Kaplun #1, Judge Knipel, or Svetlana Kaplun #2, a known terrorist, Svetlana Kaplun's motion was an illegal motion which could not be heard before Judge Knipel. Judge Knipel did not actually rule on the motion filed by Svetiana Kaplun. Judge Knipel noted the non- appearance of Svetlana Kaplun, and dismissed the claim based on inactivity in the foreclosure matter from 2008 - 2014. The foreclosure action was set to expire at the point Judge Knipel made that ruling and did expire in June of 2014 under CPLR §204 (a),the New York Six Year Statute of Limitations. Svetlana Kaplun's motion was an illegal motion, and Svetlana Kaplun did not even appear for that motion, which cannot be counted as any action being taken by the Paintiff. In total there was no action taken whatsoever by the Plaintiff from the point of filing the foreclosure action in June of 2008 until Gross Pollowy’s motion in March of 2018. 2-D.) Under CPLR 5015 Plaintiff had a one year 1 year to appeal Judge Knipel's ruling and did not do so. The next motion filed by Gross Pollowy Law Firm, the third Plaintiff's attorney, asking Judge Knipel to vacate his prior ruling to dismiss their claim was in 2018. 762 of 1117 INDEX NO. 16328/2008 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: @0/13/2023 Plaintiff had only one year, from 2014-2015 to appeal the dismissal. Plaintiff's motion in 2018, asking the court to vacate its prior ruling was too late. Plaintiff was time barred from appealing the 2014 ruling of Judge Knipel. 2-E.) Regardless of Judge Knipel's 2014 ruling to dismiss Plaintiff's claim for inaction, the foreclosure action filed by Steven Baum in 2008 expired that same year, in 2014 under CPLR §204 (a),the New York Six Year Statute of Limitations. This point was raised in my objections to the Gross Pollowy motion in 2018. Judge Knipel did not note or rule on this objection. 2-F.) Please see [Exhibit 2-A ], and notice that Judge Lawrence Knipel is shown in one photo walking with Anna Bundy of Blackwater International. Judge Lawrence Knipel is the son of Svetlana Stalin and William Wesley Peters. Craig Nixon, another Stalin descendant, and relative of Judge Knipel is the current CEO of Blackwater International, which is now called “XE.” {Exhibit 2-A] contains one photo showing Judge Knipel posing as one of the victims of Flight 175 on 9-11-01. That plane was the second plane to hit the WTC on 9-11-01. That passenger (who was Judge Knipel) was presumed to have died, and would have collected from a life insurance policy taken out under another name. [Exhibit 2-F] Shows that National City Mortgage CEO, Lars Anderson, the Plaintiff in this foreclosure case, also posed as one of the reported passengers on Flight 93 on 9-11-01. 2-G.) [Exhibit 2-G] Shows that Lisa Pollowy, the senior partner of the Gross Pollowy Law Firm also posed in photos shown here, as one of the passengers on Flight 175 on 9-11- ol. 2-H.) [Exhibit 2-H] Shows another of the Gross Pollowy attorneys who uses the name Ben Elmore is another Stalin descendant, and is also the CEO of a software development 763 of 1117 INDEX NO 16328/2008 NYSCEF DOC. NO. 28 RECEIVED NYSCEF 0/13/2023 company “Twin Technologies” in Albany, NY. Gross Pollowy Law Firm is located in or around Albany, NY. Ben Elore is shown in the photo in [Exhibit 2-H] with one of his developers, who also posed in photos shown here as one of the false passengers on Flight 93 on 9-11-01 “Tom Burnett.” 2-1.) [Exhibit 2-I] Shows attorney Plaintiff's attorney for J.P. Morgan Cynthia Rosicki and her husband Tom Rosicki of Rosicki and Rosicki Law Firm, Plaintiff's attorneys for J.P. Morgan, a Plaintiff in this case. Bob Stokes is a named defendant in this foreclosure case. Cynthia Rosicki, Bob Stokes's half sister, is one of the Plaintiff's attorneys in this case. [Exhibit 2-1] shows that Lom Rosicki's father is David Koch, a Stalin descendant. a family member of Judae Lawrence Knipel, David Koch's wife Julia Koch posed in photos published in US NEWS as a Flight Attendant aboard Flight 11 on 9-11-01, under the name Jennifer Lewis. David Koch is shown in [Exhibit 2-l] to have posed in this photo as one of the NYPD killed in the line of duty. Tom Rosicki, Plaintiff's attorney for J.P. Morgan in this case, is shown in [Exhibit 2-I] to have posed in this photo as one of the reported “victims” of the Las Vegas Shooting Incident. Each of the false victims shown in these exhibits collected from life insurance policies taken out in advance of the 9-11-01 attack and the Las Vegas Shooting Incident. Each of them would have also collected from federal funds intended for the families of those victims, which is a violation of the Federal False Claims Act. These exhibits show coordination of efforts in life insurance fraud, and Federal False Claims Act violations, and coordination of efforts in two terrorist attacks by the Plaintiff and Plaintiffs attorneys who were working in criminal coordination of efforts with the Judge in this case. Blackwater International and its CEO Eric Prince was clearly involved in the 9-11-01 attack against the US, posing as false passengers on 9-11-01 Flights 93, 11, and 175 as shown in these exhibits. 10 764 of 1117 INDEX NO. 16328/2008 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 00/13/2023 2-J.) [Exhibit 2-J] Shows Blackwater International (XE) CEO Craig Nixon posed as one of the victims of the more recent Las Vegas Shooting Incident. He would have collected from a life insurance policy for that terrorist incident. He would also have collected from federal funds intended for victims of that shooting incident. He is a Stalin descendant. 2-K.) [Exhibit 2-K] shows that there were 8 other Stalin family members who participated in the 9-11-01 attack and the Las Vegas Shooting incident, including Mayor Rick Deblasio, a Stalin descendant of Nadezhda Stalin. Mayor DeBlasio posed as one of the FDNY who died in the line of duty on 9-11-01. The Plaintiff and Plaintiff's attorneys and the Judge in this matter have coordinated efforts in home foreclosures in New York. The photos in [Exhibits 2-A , 2-B, 2-F, 2-G, 2-H, 2-1, 2-J, 2-K ] contain criminal evidence that the Plaintiff and Plaintiffs attorneys in this case posed in photos published in US NEWS as victims of 9-11-01 Flight 11 and Flight 175 and Flight 93. This is a criminal connection by Judge Lawrence Knipel to life insurance fraud and Federal False Claims Act Violations/ This is also significant evidence of treason against the United States and adherence to the enemies of the United States on the part of the Plaintiffs in this case and their attorneys, and Judge Lawrence Knipel. This shows foreknowledge of the attack, and is evidence of steps that were taken to profit from the attack. Years after the 9-11-01 attack, they are still clearly working together. Judge Knipel has clearly worked in criminal cooperation with the Plaintiffs in this case of home foreclosure. 2-L.) [Exhibit 2-L] My 2.4 husband, Bob Stokes'’s half sister is Cynthia Rosicki, who is married to attorney Tom Rosicki, one of the Stalin descendants, David Koch's son. Janet Rosicki is the plaintiff's attorney working for J.P. Morgan in this case. Bob Stokes is a defendant in this case. Bob Stokes took out a 2"4 mortgage in 2008 by illegally 11 765 of 1117 INDEX NO. 16328/2008 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 00/13/2023 signing my name to 2"4 mortgage documents with National City Mortgage. National City Mortgage’s CEO Lars Anderson was already shown in [Exhibit 2-F] to have posed in photographs as one of the passengers on 9-11-01 Flight 93. Bob Stokes is the son of Leona Helmsley of Helmsley Spears, who was a man. Bob's mother was Gretta Garbo. Gretta Garbo's daughter by a different husband is attorney Janet Rosicki, the Plaintiff's attorney representing J.P. Morgan. Leona Helmsley died in 2002 to my knowledge. Bob Stokes inherited Helmsley Spears. 2-M.) [Exhibit 2-L ] shows Bob Stokes and Janet and Tom Rosicki. 2-N.) [Exhibit 2-L] shows Bob Stokes posing as one of the passengers on Flight 175, the same flight as Eric Prince, the CEO of Blackwater International and the same 9-11-01 flight as Judge Lawrence Knipel. Bob Stokes and Judge Lawrence Knipel and Lars Anderson, the CEO of National City Mortgage, and the Plaintiff's attorneys working for National City Mortgage and J.P. Morgan were working together with Blackwater International, posing in photos as false victims of the 9-11-01 attack. This shows foreknowledge of the attack, and is evidence of steps that were taken to profit from the attack. They did not take steps to save innocent civilian lives, by alerting authorities of the pending attack. 2-O.) [Exhibit 2-O] shows New York FBI Director Diego Rodriguez posing as one of the passengers aboard Flight 175 on 9-11-01. Diego Rodriguez is Bob Stokes's half brother. Diego Rodriguez is the son of Leona Helmsley and Barbara Walters. 2-P.) From the evidence included here in Exhibits 2-A through 2-0, it is clear that Judge Lawrence Knipel, the Judge in this foreclosure case until this point, acted in criminal coordination of efforts with the Plaintiffs and the Plaintiff's attorneys in this foreclosure matter, and one of the defendants in this same foreclosure matter. 12 766 of 1117 INDEX NO. 16328/2008 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 00/13/2023 Whether Judge Knipel posed as Svetiana Kaplun #1 and filed a motion to be heard before his own court, or whether Svetlana Kaplun #2 filed the motion, it was an illegal motion before his court, but for the reasons listed below, it is most likely that Judge Knipel posed as Svetlana Kaplun #1 and filed the motion to be heard before his own court. Judge Knipel did not rule on the motion for one of twe reasons: Either Svetlana Kaplun was not there, or Judge Knipel was in fact, Svetlana Kaplun. In Gross Pollowy's motion filed by Gross Pollowy in 2018, Gross Pollowy included a Sworn Affidavit from Svetlana Kaplun that she in fact did appear for her 2014 motion. | appeared for that motion. Svetlana Kaplun did not appear. Judge Knipel in fact noted the non- appearance of Svetlana Kaplun in his ruling. If her Svetlana Kaplun’s Affidavit would be considered to be truthful and she really appeared for that motion, why would Svetlana Kaplun not have taken the necessary steps to make certain that her own appearance was noted, and her motion before the court was heard that day? If she was there and did not notice me or felt that | did not appear, why would attorney Svetlana Kaplun, who filed the motion, not take the necessary steps to see to it that this was entered into the court record in order to get a default judgement in favor of Plaintiff? Itis not credible that the attorney who filed the motion took no action. Furthermore, when Judge Knipel noted Svetlana Kaplun's non- appearance, Svetlana Kaplun took no action to correct this and appeal Judge Knipel’s ruling. She had one year to appeal Judge Knipel’s dismissal of the claim, and did not do so. If we are to believe the sworn statement by Svetlana Kaplun, either a known terrorist wanted by the US State Department was present in court for that motion, and took no action whatsoever, or Svetlana Kaplun was in fact Judge Knipel. Because | appeared 13 767 of 1117 INDEX NO. 16328/2008 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 00/13/2023 for that motion, there could be no default judgment entered by Judge Knipel. | believe that Judge Knipel who is shown in Exhibit 2-A to have posed in photos as Svetlana Kaplun, filed the 2014 motion to be heard before his own court. What possible explanation could Judge Knipel offer the court for that photograph? From the evidence shown in 2-A through 2-0, it is clear that Gross Pollowy attorneys were working in criminal cooperation with Judge Knipel in posing in photos as passengers on 9-11-01 fights 11,93. and 175. The sworn statement included in Gross Pollowy's March of 2018 motion was perjury, and Gross Attorneys know that and still submitted the sworn statement to the court. NY Consolidated Laws. Penal Law §175.40 Issuing a False Certificate: A person is guilty of issuing a false certificate when, being a public servant authorized by law to make or issue official certificates or other official written instruments, and with intent to defraud, deceive or injure another person, issues such an instrument, or makes the same with intent that it be issued, knowing that it contains a false statement or false information. Issuing a false certificate is a class E felony, an egregious violation on top of the criminal coordination of efforts in connection to the 9-11-01 attack and the Las Vegas Shooting incident already shown in [Exhibits 2-A , 2-B, 2-F, 2-G, 2-H, 2-1, 2-J, 2-K, 2-L, 2-0] Under CPLR 5015 Plaintiff had a one year window of time to appeal Judge Knipel’s dismissal but did not do so. Svetlana Kaplun took no further steps at all. Plaintiff's attorney Gross Pollowy filed a motion in March of 2018, asking Judge Knipel to vacate his prior ruling to dismiss their claim was filed too late to be considered by the court. Plaintiff was time barred in 2018 from appealing Judge Knipel’s 2014 ruling. In addition to this, the foreclosure action, and the plaintiff's ability to foreclose on this house expired in 2014, regardless of Judge Knipel's ruling to dismiss Plaintiff's claim for inaction, 14 768 of 1117 INDEX NO. 16328/2008 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: @0/13/2023 or the lack of timely appeal by the Plaintiff, under CPLR §204 (a),the New York Six Year Statute of Limitations, My response to the 2018 motion by Gross Pollowy included my objection based on CPLR 5015, expiration of Plaintiff's one year window of time to appeal Judge Knipel’s ruling. In March of 2018 | knew only about Svetlana Kaplun #2, Abu Ayub Al Masri, a known terrorist wanted by the US State Department. | did not know that Judge Knipel himself had posed in photos as Svetlana Kaplun and had filed the 2014 motion to be heard before he own court. It is clear that he could not be both Judge and Plaintiff's attorney, and sought a default judgment if | failed to appear for that motion. But | did appear for that motion, and Svetlana Kaplun did not appear. [Exhibits 2-A ] shows that Judge Lawrence Knipel posed as Svetlana Kaplun #1 and filed a motion to be heard before his own court. | did not have the information included in [Exhibit 2-A] showing that Judge Knipel has a connection to Blackwater International employees. | did not know that National City Mortgage CEO Lars Anderson, [Exhibit 2-F] the Plaintiff in this case, and the Plaintiff's Attorneys in this case, and Bob Stokes, one of the defendants in this case, and Bob's half sister, the Plaintiff's Attorney for J.P. Morgan, and Bob's half brother, Diego Rodriguez, the Director of the FBI in NY and also Bill DeBlasio, the Mayor of NY were criminally involved in this. CPLR 5015(a) provides: The court which rendered a judgment or order may relieve a party from it upon such terms as may be just, on motion of any interested person with such notice as the court may direct, upon the ground of: 2. newly-discovered evidence which, if introduced at the trial, would probably have produced a different result and 15 769 of 1117 INDEX NO. 16328/2008 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 00/13/2023 which could not have been discovered in time to move for a new trial under section 4404; or 3. misrepresentation, fraud, or other misconduct of an adverse party; or 5, reversal. modification or vacatur of @ prior judament or order upon which itis based. NEWLY DISCOVERED EVIDENCE: The Judge in this foreclosure action has been working in criminal cooperation with the Plaintiffs and Plaintiff's attorneys and one of the defendants in this foreclosure case, and dressed as Plaintiff's attorney Svetlana Kaplun, and filed a motion to be heard before his own court. Judge Knipel reversed his 2014 dismissal of Plaintiff's foreclosure. For the above stated reasons and evidence provided here in [Exhibits 2-A , 2-B, 2-F, 2-G, 2-H, 2-1, 2-J, 2-K, 2-L, 2-O] | ask the court to reverse Judge Lawrence Knipel’s 2018 vacatur of his 2014 dismissal of Plaintiff's claim of foreclosure. There has been clear fraud, misrepresentation, and criminal misconduct on the part of the Plaintiff and Plaintiff's attorneys and Judge and one of the defendants in this case. | ask that the court dismisses with prejudice, Plaintiff's claim of foreclosure. In addition to the grounds set forth in CPLR§5015(a), a court retains “its discretionary Mi it WI it substantial justice. “ Goldman v. Cotter, 10 A. D. 3d 289, 293, (2d Dept. 2004); Mendon Leasing Corp. at 68; Ladd v. Stevenson, 112 N.Y. 325, 332 (1889). OBJECTION #3.) Objection #2 notwithstanding, based on CPLR 5015, Plaintiff's one year time limitation in which to appeal Judge Knipel’s 2014 ruling to dismiss Plaintiff's 16 770 of 1117 INDEX NO. 16328/2008 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 00/13/2023 claim, | ask the court to overturn Judge Knipel’s March 2018 ruling to vacate his 2014 dismissal of Plaintiff's claim of foreclosure. Under CPLR 5015(a) The Plaintiff had one vearto appeal Judge Knipel's 2014 ruling to dismiss their foreclosure action, and did not do so. Gross Pollowy Law Firm did not file a motion asking Judge Knipel to vacate his prior 2014 dismissal of Plaintiff's claim until 2018. Plaintiffs were time barred from filing their 2018 motion, asking the court to reverse Judge Knipel's 2014 dismissal of their claim. Pursuant to CPLR 5015(a) defendant asks the court to vacate Judge Knipel’s March 2018, ruling to vacate his 2014 dismissal of Plaintiff's claim. OBJECTION #4.) Previous objections #2 and #3 notwithstanding, under the CPLR §204 (a), the New York Six Year Statute of Limitations, the foreclosure action, and the plaintiff's ability to foreclose on this house expired in 2014, regardless of Judge Knipel’s ruling to dismiss Plaintiff's claim for inaction, or the lack of timely appeal by the Plaintiff, and regardless of Judge Knipel’s 2018 ruling to vacate his prior ruling to dismiss their claim. Under CPLR §204 (a), the foreclosure action, and the plaintiff's ability to foreclose on this house expired in June of 2014. Because Svetlana Kaplun was not able to file a otion to be heard before Judge Knipel, there were no motions filed from the point Plaintiff's attorney Steven Baum filed the foreclosure action in June of 2008 until March of 2018. The Plaintiff slept on its rights to foreclose and the time to do so expired. Pursuant to CPLR §204 (a), the court must dismiss Plaintiff's claim of foreclosure. OBJECTION 5.) CPLR § 1402: Latches — Different from a statute of limitations, the essential element of latches is an unreasonable delay by the plaintiff in bringing the 17 771 of 1117 INDEX NO. 16328/2008 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 00/13/2023 claim. There was a 5 year delay in filing any motions in regards to this foreclose matter after the initial foreclosure action was filed by Steven Baum. Svetlana Kaplun, the next attorney to work as Plaintff's Attorney for National City Mortgage came into this case as a Plaintiff's attorney five years after the foreclosure action was filed. Svetlana Kaplun , whether she was Svetlana Kaplun #1 - Judge Knipel himself, or Svetlana Kaplun #2, Abu Ayub Al Masri, a known terrorist, could not have filed a legal motion to be heard before Judge Knipel. This means that there were no legal motions filed in this case from the point Steven Baum filed the foreclosure action in 2008 until Gross Pollowy filed their motion in 2018 - 10 years later. The foreclosure action was dismissed by Judge Knipel for lack of any activity in 2014. The foreclosure action expired under the New York Six Year Rule in 2014. In complete disregard of these statutes of limitations, Plaintiff's attorneys waited until March of 2018, to file any other motions, 10 years after the foreclosure action was filed. 4-D.) There has been an unreasonable and unjustifiable delay by the plaintiff in bringing the claim; a five year delay after attorney Steven Baum was put out of business in NY by NY Attorney General Eric Schneiderman ; another five year delay between the illegal motion filed by Svetlana Kaplun and the next motion that was filed by Gross Pollowy Law Firm in 2018. My objections to the legality of the 2.4 mortgage, my objections regarding lack of pre-foreclosure, and foreclosure notices, lack of service of any motions by Steven Baum, the non- appearance by Svetlana Kaplun, the lack of notice by Gross Pollowy for their June, 2018 motion, and non -appearance by Gross Pollowy for their November 2018 motion have never been heard by the court. 10 years have elapsed between the filing of the foreclosure action and this new motion by Plaintiff's attorneys. 18 772 of 1117 INDEX NO. 16328/2008 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 00/13/2023 OBJECTION #5. ) CPLR § 3211 Lack of Standing - Illegal 2.4 Mortgage: National City Mortgage has no standing to foreclose on the house at 39 72n4 Street, Brooklyn, NY. National City Mortgage has been working in criminal coordination of efforts with one of the defendants, Bob Stokes. 5-A.) Illegal second mortgage document signed by Bob Stokes in 2008. [Plaintiff's Exhibit A] New York Penal Code PEN§ 470.000 Section 1700.15 First Degree Forgery New York Penal Code Sections 170.20 — 170.40 Criminal possession of forged instruments and devices. An offense will be elevated to the first degree if it involves: Part of an issue of money, stocks, bonds, or other instruments representing interests in or claims against a corporation or other organization or its property. 5-B.) There is a complete lack of documentation by the Plaintiff, with respect to the 24 mortgage documents. 5-C.) Plaintiff and each one of the four Plaintiff's attorneys working for National City Mortgage and J.P. Morgan has been shown in [Exhibit 2-A, 2-B, 2-F, 2-G, 2-H, 2-I, 2-J, 2-K, 2-L, 2-O, 5-E, 5-G, 5-H 5-I, 5-J] to have coordinated efforts in posing as false victims of 9-11-01 Flight 11, Fight 93, or Fight 175, and they are connected by family and by Blackwater International to the Las Vegas Shooting Incident, and so two terrorist attacks against the US. From the time | first met Bob Stokes, there has been organized fraud , and fraudulent inducement on the part of Bob Stokes and his family members and business associates who were working with former CIA Director William Casey, who was the son of Harry 19 773 of 1117 INDEX NO. 16328/2008 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: @0/13/2023 Helmsley. The family that was introduced to me as Bob Stokes's family was not his family. | was told that Bob's father had died when Bob was 10 years old. Bob's father was Leona Helmsley, who was a man, and was still alive until 2002. Those men set out to gain illegal access into a private trust that was set up for my father in the early 1900s. They worked with GHW Bush and his family members which includes Lars Anderson, the CEO of Gross Pollowy Law firm, the Plaintiff in this foreclosure matter, and Plaintiffs attorneys working for Gross Pollowy Law Firm. Steven Baum is the son of former CIA Director Hoyt Vandenberg, who served as the notary for Steven Baum in this foreclosure action. Bob Stokes's best friend and roommate