Professional Documents
Culture Documents
Affidavit of Del Zanette
Affidavit of Del Zanette
Affidavit of Del Zanette
I Delmo Zanette, reside at 1357 King St, Greenwich, CT, am duly deposed and swear to be true
the following stated facts and circumstances; as I agree in advance to subject myself to a
(Pecunies) and his associate Author K. Watson (Watson) who on the basis of fraud, are now
seeking to evict me from the home I own so they can sell my property for their exclusive benefit.
Whereby, both, Pecunies and Watson (P&W) initially impressed me as being successful business
men. Insomuch as they were co-owners of Mercedes-Benz of Greenwich and with claims of
owning a vast amount of real estate. In addition Pecunies impressed me that they were both well
respected in the Greenwich community and philanthropists; but what especially impressed me
was when Pecunies enlightened me to how Watson was an individual of social prominence.
Consequently, I believed the P&W were legitimate business persons and dealmakers. Thus, it
never occurred to me that they would not adhere to the presented business arrangement for them
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to buy my four acres of property in Greenwich, CT. Insomuch as I was previously offered 3.2
million about four years before, by a Ms. Alvus, just for buying one of the two parcels containing
the farm land. Specifically, I would still keep the 1.8 acre parcel where my home is located (that
I am now have a marshals warrant of eviction that I am fighting to keep my right of occupancy)
and she would buy the 2.3 acres containing to operation of Purdy’s Farms. In addition, Ms.
Alvus made a final concession that she would still allow me to occupy the entire building of my
farm store where I would live above it for five years after the sale, even without my having to
pay a cent. Since, she wanted the land to build a hotel; thereby to exploit its commercial zoning
status, unique to the area, and proximity of being located right next to the Westchester Airport.
Consequently, I have long regretted not selling the farm parcel for 3.2 million, since I still would
of owned my home on the 1.8 acres parcel that is now in summary proceeding, of where I could
have plowed a garden of a non-commercial size on its vast front lawn in the spring. However, the
reason why I declined accepting the offer for 3.2 million was because it was of greater value for
me at that time to be able to continue with the commercial farming on the field to my land.
Essentially, I just didn’t want to give up being able to offer to my customers who shop in my
farm store, farm fresh organic produce. Thereby, where I could sell them produce, I might of had
picked that very morning, as a manifestation from the sweat on my brow; rather than to sell them
something that I unpacked from a box. In addition, I have amassed many antiques and
collectables that I had planned to exhibit in a children’s museum I long have planned to have on
my property. I have three 40’ foot containers on my property filled with art, antiques, and
collectables, outside of my furnished home that defendant had illegally changed the locks.
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In fact, I tilled this land for 44 years, before plaintiff blocked my ability to continue. Since
plaintiff claims that the law of our land affirms it is his legal right to dispose of everything I own;
everything dear and sacred to me, plaintiff feels entitled to take from me as a matter of his right.
Insomuch as plaintiff has promised me through his agents that the last bit of everything I own
At the time of the “agreement,” the property was appraised to be worth at least four million, so I
thought we met on common ground where both parties were happy with the agreement,
considering I could still stay on the property for as long as I wanted. Consequently, I agreed for
the sale price to be three million, instead of requiring to be paid the four million I could get on
Therefore, I expected the sale would go smoothly with all my full cooperation extended to
accommodate what plaintiff had wanted. Since I thought my compliance was just to support their
ability to consummate their business intentions. However, what I did not take notice as
suspicious was that within the first two months they kept presenting to me, yet another
agreement to sign (exhibits A-D). Now in retrospect, I should have seen this as being an
indicator I needed to scrutinize any new agreement. Since, if I wasn’t trusting that plaintiffs
would make good to their word, and read the contracts before signing, I would have noticed in
the ‘contract’ the numerous terms that didn’t correspond to what was verbally promised.
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Point in fact, even though I possess a copy of the first agreement with Pecunies dated on March
27th, he testified that the very first time meeting me was when I signed the May 27th agreement.
In addition, Philips contradicted Pecunies first meeting me at about the middle of year by his
testifying Pecunies met me at the beginning of the year in 2004. Moreover, Pecunies testified
that I used plaintiffs’ financial investment to prevent my losing the properties, saying it was on
the brink of being foreclosed on. However, this could not be more further from the truth, since it
was not until November 17th, (6 months later) when they refinanced the property that any money
was paid out towards the mortgage, which unnecessarily imposed penalties.
Yet, the afore stated subsequent fiduciary loss, albeit needless is almost nothing compared to
plaintiffs’ conduct of not paying out anything towards the interest only mortgage for three years.
This is most disturbingly, since the basis of my authorizing them to get refinancing in the first
place was to obtain a better rate. Yet, they secured a usury rate 11 ½ %, to replace an 8½ %
mortgage; of which I was paying before they took over the responsibility.
Then to add insult to injury, plaintiffs never made any of the monthly payments, and depleted the
$520,000 balance left over after they embezzled about $460,000. This was drawn upon the open-
credit that plaintiff obtained at refinancing by imposing a two million lean on the property.
Not to mention, unlike Pecunies’ bold faced lie to this court that the property was going into
foreclosure before they took over its management to overt my losing the property, the truth is
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that the property is now going into foreclosure. Essentially, this is because they took over its
management. As plaintiff’s role of being the ‘manager’ of the property is, in effect an artifice to
a scheme to loot the equity contained in the properties. Thereby, plaintiffs perverted their
position of authority and responsibility of being the manager of my properties to cloak their
On the last and applicable agreement in May 2004 that superseded prior agreements, I did not
even read it before I signed, as they only pushed it in front of me to sign on top of my name. Yet,
unbeknownst to me was what I was promised and was expecting in plaintiffs’ performance was
being made verbally, and not incorporated in the contracts. Such as where in the prior agreement
I was named as being the 100% owner of the LLCs; of which was changed without my being
consulted or informed before I signed the ‘agreement’ where I designated 25% ownership to
Pecunies and another 25% to Watson. Essentially, from the onset the designation of ownership of
Pecunies and Watson was a product of trickery and foul play, yet they act as if they paid me half
of its market value at that time and say they financially bailed me out from losing everything.
Essentially, I was duped to unknowingly assign over to the plaintiffs my rights of ownership and
right to appreciate revenue by them collecting the rents. Then when I asked Pecunies why he was
named as the manager of my properties, he said it was for my conveyance. Although, I still
collected rents from my tenants that was written out to my name they required I give them
$6,300 of the rents. This is where for over four years I would sign on the back of the checks
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However, after my tenants were telling me that the returned checks were showing they were not
cleared in the bank account of the LLC’s, but in the business account of Mercedes Benz and
Watson Enterprises. Not surprising, plaintiff’s accountant, John L. Cox, told me the LLC’s
At the onset when the agreement was made, I consented they could use the rents towards the
properties debts, and they collected approximately $6,700, or less at times, for rentals of specific
apartments, and I would collect a total of $3,600 for three units and give them $1,000 towards
the taxes. Since the agreement was I could continue to occupy my farm store and live on the
floor above. However, if they were to sell the entire property to the outsider, it must be for 4
million dollars, yet I would share the extra million I received with them. Essentially, I foolishly
agreed to give someone $500,000 for doing nothing, except for not living up to what they
verbally, and or, contractually promised. Later I moved things that were in my garage into a
container I rented to receive $375, but in February when plaintiff was trashing all my property on
the land they stole $1,500 of property from my renter and tools him he had to leave in one
month. He went to the Greenwich police and was off for about two hours to be ultimately told
that plaintiff owns the property and can do whatever they want. In addition, I was receiving rent
from a masonry company who was using the land until plaintiff interfered.
When, the naming of Pecunies as Manager first came to my attention, Pecunies told me that it
was just for my own convenience. He said it was just so I won’t have to come down to their
office to sign the checks. Yet, in actuality this blocked me from having access to know they were
embezzling many hundreds of thousands of dollars from the property (probably over a million).
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In effect, I have been completely shut out and kept in the dark and denied access to know
anything about the business of the LLC, or was ever allowed any participation whatsoever.
Essentially, my last involvement in the business of the LLC’s was over 5 years ago when I
unknowingly had signed the contract to be a 50% member. Yet, Pecunies told me this was only
to be until they got refinancing, and he promised me immediately after refinancing it would be
changed, naming me as a 100% owner. However, I now know, exists only as a shell corporation
to create a façade of legitimacy, such as when they act to defraud me, or now with this eviction.
Consequently, I have been deprived from receiving most of the revenue from the rentals on my
property for the last 5 years that mostly went into plaintiffs’ pockets. Not to mention, all the
additional expenses they imposed upon me as a result of their shenanigans to have exhausted my
life savings. Especially when I now am desperately in of need funds since I am disabled and
chronically ill with chronic pulmonary disorder. This condition caused me to constantly
throughout most days to have episodes, when I have difficulty breathing and respiratory spasms.
Defendant used his key to move back in to his home as a matter of legal right in September 2009.
Insomuch as the tenant in his home were his tenants and paid rent to the LLCs and until in April 2009
when the plaintiffs demanded all rents were to be paid to them. Thereafter tenants in defendants home
paid checks directly to the LLCs until they left in October and defendant moved in thereafter. This was
especially, appropriate because plaintiff was forcing him to vacate from a building on the other property
he owns. This was when he was living with his health aid, Joanne Gramacy. Plaintiff had given her a
thirty day notice to leave, even though she was totally paid up in rent.
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Clearly, the reason of notice to vacate was that plaintiff did not want defendant living on his property.
Although, she had paid rent on the apartment through the winter while she was in Florida with defendant,
yet plaintiff broke in to change the locks, under the color of claim to cure a water leak. As plaintiff said
they changed the locks and lost the key to cause her and defendant to be locked out for two days. This
was until Ms Gramcay was plaintiff and Ms. Gramacy to be let back in where they resided until she was
Complaint Showing How Fraud Upon the Court has Corrupted All Past Rulings
opportunity to present my position to the court. This is because of Judge Grogins’ refusal to set a
trial date in two months from now when I would be able to appear to participate and testify in the
beginning of April. Yet, Judge Grogins refusal is without any reasonable justification,
considering that my physical disability impairs my ability to be present. Since this issue that I am
currently very frail and in poor health, has been brought to his attention by my council Mark
Katz. Insomuch as my doctor says traveling to New York from Florida places me in serious
jeopardy and my pulmonary doctor prescribes I must avoid exposure to cold weather.
contrasting temperatures of frigid temperatures; cold could trigger a serious attack. Not to
intimidate me to willfully allow them to usurp most of everything I own. Since this has involved
a tremendous amount of major incidents of outrageous abuse that was accompanied by many
incidents of threats and harassment to intimidate my compliance. Whereby, plaintiffs’ goal has
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been to force me to move out of my home and sell its property to them for a small fraction of
In fact, not only has this entire proceedings been corrupted by ‘fraud upon the court’ with
councils from both sides, Robert Kaelin and Mark Katz, but all the other proceedings. Such as
with considering the criminal misconduct of plaintiffs’ past attorney Steven Phillips, who
actively participated in plaintiff’s confidence scheme to defraud me. Then, when I hired lawyers
to counter plaintiff utilizing their legal rights to cheat me these lawyers only supported the
opposition’s ability to obtain their legal agenda. In effect, my lawyers betrayed my trust and
deprived me of pursuing available legal opportunities for me to have obtained relief. These
lawyers were in order, Demetrois Adamis, Donald Brown Robert Heisler, and Mark Katz. In
effect, all the lawyers on both sides engaged in activities of judicial misconduct, focused on
depriving me out of my rights of entitlements through foul play and the misuse of your court.
Consequently, I have also attached material to show the wanton acts of professional misconduct
of each lawyer as an individual actor. This is where I can show how they not only violated my
rights by neglecting to perform their official duty to uphold the law, but knowingly acted to
violate the law. In effect, they perpetrated misconduct under the color of being “officers of the
court.” Yet, in spite of the fact they are entrusted to demonstrate allegiance to the laws of the
land. This is expected by a lawyer’s utilization of their knowledge, skill, and acknowledged
aptitude to apply the law in an appropriate manner to the matters in dispute to ensure the
integrity of decisions.
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Whereby, my complaint against Judge Grogins is that he denied me of my right to due process
provided by my constitutional rights to receive justice in State Court on matters of equity. This
was manifested by perverting his discretionary authority. In effect, by Judge Grogins depriving
me from receiving a full, fair, and impartial hearing it consummated the interests of my
opposition. Since, their intent has been dedicated to deprive me of my legal right of entitlement
being a material fact upon the review of the record to the proceeding. In fact, just a cursory view
upon the record shows a material fact of judicial wrongfulness was performed in a chronic,
extreme and pervasive pattern. Thereby, as a causation of the corrupt conduct of my lawyers, I
consistently have been deprived of exposing the major criminal activity and Herculean
falsehoods of the opposition. It shocks the conscious that my own lawyers stifled me from
refuting the fraudulent claims of the other side. Consequently, I was deprived of exposing the
major criminal activity and Herculean falsehoods spun out as a web of lies by the opposition.
However, not only have my own lawyers stifled me from refuting the fraudulent claims of the
other side, but also Judge Grogins denied me the right to testify and plead my cause. This was in
a prior legal matter involving eviction from a different building on my property about a year and
a half ago. As when the matter went before the Superior Court of Norwalk to vacate a stipulation
that was the product of coercion and misrepresentation by my own lawyer, Donald Brown. Yet,
this was my second one sided stipulation I signed as a product of being duped by own council’s
misrepresentation of its importune necessity. Whereby, the first stipulation I signed was due to
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being pressured by Demetrois Adamis. He said don’t worry about be evicted because I will bring
an action to dissolve the LLCs and remove Pecunies as manager so you won’t be evicted.
At the time Judge Grogins denied me of my right to testify my position was right after hearing
the matter of the prior eviction action based on falsehoods. Yet, Judge Grogins not only acted
with ill-will towards me, but demonstrated favoritism by allowing the opposition to testify to
their fraudulent claims. Such as with plaintiff’s false declarations to egregiously misrepresent the
business arrangement and fiduciary obligations to be entered onto the record, but I was blocked
from presenting my position in refute. Even though my testimony was essential for him to
establish his cause of action to justify vacating the stipulation, as to the state of his mind at the
time when I signed the stipulation, . . . as this was the pivotal issue to be decided upon. Since the
matter before the court was whether my signing of the stipulation was through my own volition,
Specifically, I had no interest to sign the stipulation, but my lawyer Donald Brown pressured me
to sign out of fear, by telling me that if you don’t sign it they’re going to suck out all the equity
in your property and you will end up with nothing. Moreover, Brown said it doesn’t matter if you
Consequently, what occurred is that I did not sign under my own volition; rather I only agreed to
such interference is in accordance to Court Practice and Procedure, title 52, ch. 900, §52-212
II. Grounds for Relief, in 52-212 §58 Fraud and 52-212 §59 Duress, where statues say:
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“In making its factual determination whether stipulated judgment should be opened,
pursuant to C.G.S.A. § 52-212a, trial court must inquire into whether decree itself
was obtained by fraud, duress, accident or mistake. (Jenks v. Jenks (1995) 657 A.2d
1107, 232 Conn. 750, on remand 663 A.2d 1123, 39 Conn. App. 139).
“To conclude that stipulated judgment resulted from duress, finder of fact must determine
that misconduct of one party induced party seeking to avoid stipulated judgment to
manifest assent thereto, not as exercise of that party's free will, but because that party had
no reasonable alternative in light of circumstances as that party perceived them to be.
(Jenks v. Jenks (1995) 657 A.2d 1107, 232 Conn. 750, on remand 663 A.2d 1123, 39
Conn.App. 139).
Essentially, I was denied the right to testify, and this ensured the status quo, of acknowledgment
contest the veracity of their fabrications to deceive the tier of facts. Thus, Judge Grogins
interference continued to ensure my position was not heard. This was after all the past lost
opportunities caused by plaintiff’s lawyers’ intentional neglect to expose the criminal conduct of
the adverse party. As where Brown told plaintiff he could not raise any issue besides the lease
and his rental payments in the eviction action, such as with fraud and other misconduct.
However, up to now I have never been able to contradict defendant’s outrageous falsehoods,
which are the very antithesis of the truth; such as where defendants testify to being the aggrieved
party . . . that should have been identified as bold faced lies that could have readily been refuted
by evidence. Whereas, instead of my lawyers refuting the lies of the opposition, they would
explain to me that it was never the time or place; and other ridiculous reasons to justify them
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In effect, I was finally ready to have my day in court, after all my lawyers’ interfered with my
requests that they bring forth for the court’s consideration my rebuttals. Unfortunately, for a
reason, yet to be explained, the court did more of the same. Insomuch as, I was about to give
testimonial evidence to clarify what were the true facts contradicting the oppositions’
perpetration of a hoax upon the court. This is where I could refer to unimpeachable evidence in
support that would contradict their brazen lies. (see attachment exhs., which contains a detailed
compilation of the extensive false declarations of defendants on record and the material facts in
contradiction).
However, for a reason that is yet to be explained, Judge Grogins refused to allow me to testify
(exh. ). Rather, instead Judge Grogins skipped hearing my position to rule against me in an
arbitrary and capricious manner, as if I had no right for my argument to be heard as to why my
relief was justified. Insomuch as if it was a foregone conclusion I am to be evicted from my own
property by the court without being giving a chance to plead my defense. Essentially, it seemed
like it didn’t matter if I was afforded an opportunity to plead my position, because the matter has
This constituted unfair treatment in a court of equity, as the court’s demonstration of showing ill-
complaining that my guaranteed rights to justice through a fair trial have been usurped by Judge
Grogins refusal to grant me my right to receive due process. Since Judge Grogins refused to
allow me to plead my position and state the ‘cause’ why the stipulation should be vacated.
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Insomuch as he blocked not only my ability to present what my case was about, but denied me of
from receiving my due process guaranteed by the fourteenth amendment to the constitution.
Thus, by Judge Grogins denying me of my right to be heard is blatant act of judicial misconduct
and is a violation of his official duty and the public’s trust. Essentially, by Judge Grogins’ refusal
to allow me to plead my position was a decision of ultra vires, and a violation of canons of
“A judge shall perform the duties of judicial office impartially and diligently, (B)
Adjudicative Responsibilities.(6) A judge shall accord to every person who has a legal
law.” (§ 100.3)
In regard to Judge Grogins’s handling of my cases, the confluence of factors of his judicial
conduct substantiates that the offending conduct was not only outrageously unfair, but clearly
improper and adverse to what is required for him to perform his official duty. Whereby, to such
Essentially, the improper conduct of Judge Grogins constituted a palpable and pervasive pattern
prejudice. Consequently, all of the bias misconduct I endured from Judge Grogins’ siding with
the opposition has caused a severe emotional wounding and profound traumatizing. In fact, this
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experience of where the Court’s past support to affirm plaintiff’s evil ambitions to destroy my
life for their gain was destined to drive me to into early grave--that is until I fired my last lawyer.
In fact, due to my extremely poor state of health and onslaught of malicious assaults on my
major depression and acute anxiety disorder with a perpetual posttraumatic stress disorder. Since,
my health has dramatically deteriorated due to the shockingly abusive mistreatment I endured
over the last three years from my opposition that Judge Grogins extended privileged treatment.
Then upon this emotional distress the opposition caused was further compounded by my own
lawyer’s malicious misconduct, which on face supports the devious agenda of my opposition.
Moreover my poor health is profoundly made worse by my inability to afford the medical and
psychological care that I desperately need; so as to uplift me out from this living nightmare.
Consequently, since Judge Grogins neglected to perform his official duty I have been denied
justice in a court of equity up until this point when I am appealing to another judge.
Thus, along with the suffering from my poor physical health I am contending with “reactive
depression.” This is where I feel emotionally downtrodden with intense feelings of helplessness,
where I dread in the near future I will be homeless and destitute, while now I am broke. Albeit
the direct result from having the property I owned whose revenue and assets I depended upon
literally stolen right out from under me and this court making it “legal.”
Wherefore, in consideration of the serious nature of stated allegations herein, and the possibility
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Since, the conduct I am exposing is a pending threat to the public at large of this state. Thus on
face value this matter is of great urgency to be resolved for societal benefit.
The misconduct of these judge’s corresponds to Hammermaster 985 P.2d at 942) that says:
“the judges knowingly violated litigants' rights in numerous instances, thus evidencing a
pattern of misconduct…The Court found that this behavior violated Canons 2A, 3A(1),
and 3A(3) of the Washington Code of Judicial Conduct, by demonstrating a pattern of
intimidating and offensive behavior, ignorance or disregard of basic legal principles,
particularly in regard to sentencing and an ambivalence toward maintaining professional
competence in his courtroom…The court considered factors…
(a) whether the misconduct is an isolated instance or evidenced a pattern of
misconduct;
(b) the nature, extent and frequency of occurrence of the acts of misconduct.”
Essentially, Judge Grogins, constantly and continuously performed his official duty with a
profound lack of judgment that can’t be contributed to any innocent explanations. Rather, on
appearance his questioned conduct indicates intent to deprive my right to justice by disregarding
the standard according to the law. Insomuch as he blatantly misused his authority to interfere
with my right to receive a fair trial. This was carried out with palpable neglect, and outright
refusal to perform his official duty. Not to mention making outrageously improper rulings that
appear to have been with conscious intent. Of which were often contradicted by law and
dedicated to further the criminal activities of my opposition who are obviously not acting within
the law to effectively deceive the fact finder to Judge Groins not doing what he is duty bound to
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This is where my opposition successfully misused the court to achieve unlawful gains through
Essentially their intent to improperly influence the court in its decision was achieved by Judges
Grogins not functioning as the neutral and detached magistrate. Even though the impartiality and
very least is seems as though he turned a blind eye, While it was so obvious that the conduct of
my opposition, and the lawyers to both sides shows on face value to suggest they acted complicit
Insomuch as Judge Grogins acknowledged as a matter of fact the unsubstantiated bogus claims
History
The plaintiffs in March 2004 enticed me with their credibility and promises for buying my two
lots of property for three million. (At the time I owed $980,000 in mortgages). I readily extend
special accommodations to plaintiff far beyond what is generally offered in a purchase contract.
This is because unlike other interested parties in my property, they enticed me with an offer I
could not refuse. This is where Pecunies promised me that even though they would buy the
property, I could still operate my farm store Purdy’s Farms and live above it.
Consequently, I as an act of good will, volunteered that I should contribute a $1,000.00 a month
towards taxes, because that seemed as a fair consideration towards their interests. The ability to
stay was why I agreed to the three million, instead of demanding the four million that I knew the
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property was worth. Since giving up getting the extra million was worth it to me, because it
would allow me to continue with my way of life. I could not be more pleased, and cooperated
Consequently, on the basis of the above verbal promise they drew up various agreements of
intent, the first on March 27, then on April, 20, and again on April 21, when I received the first
loan of $20,000.00 (later made into a mortgage). Finally, they had me sign the attached
agreement dated May 27, 2004. As the ‘contract’ filed as their exhibit A, to my first eviction
action in Norwalk Housing Court. Ironically, this is the very “contract’ plaintiffs egregiously
breached on its face, by their willful noncompliance to its terms set forth in the bargain of the
Ironically, this agreement was initially misrepresented by them as to legally protect both parties’
business interests, which I believed was the basis of it being as wordy as it was. Yet, in actuality
this agreement unbeknownst to me states a completely different business arrangement than what
I was told it meant by their lawyer Steven Phillips. As it was Phillips who drew up the agreement
and had assured me that all of what was promised to me was incorporated in the agreement, and
Insomuch as, I was told by Pecunies that I didn’t need to spend the money to hire a lawyer,
because their lawyer Phillips would also be “amicably” representing both our legal interests (as
is stated in the court records). I remember him saying amicably because I have spent a
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tremendous amount of time reflecting on what had occurred to have had allowed plaintiff to have
Since, I have painfully come to realize that Phillips was in on their scheme to scam me through
fraud and deceit. (At the time I signed the agreement Mr. Philips just referred to the parts on the
contract about my loans; staying on the property; and showing me where it says I would be
receiving the $1,900,000.00, considering my $40,000.00 loan. As the $40,000 loan was not
something that I asked for, but Pecunies insisted that he wanted me to have the money, so I could
Unfortunately, I was manipulated not to feel the need to read over the contract, or have an
opportunity to reflect upon what the contract says, or have someone look it over. Thus, I was
deprived of an opportunity to consider if parts of the contract had a different meaning than what I
was told by Pecunies and especially Phillips. As I was naively relying of Philips who was
supposed to be representing my legal interests to point out anything that I should take notice of
what it implies. Insomuch as with considering Phillips being an officer of the court, I expected
that he was duty bound to be faithfully honest and responsible to me with providing me with my
legal support.
Yet, I painfully have come to realize that I could not have been more wrong than to have
believed what Phillips told me was true. Since he exploited my assumption that he was
compelled to adhere to the oath of integrity he swore upon to be licensed to practice law in the
State of Connecticut.
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Essentially, I was tricked into signing what I thought was an agreement to sell my property, of
Specifically, what was made especially appealing to me that it was promised to have a provision
I still retained rights to possession in the property to live and operate my commercial enterprise.
Rather, the contract states something completely different than what it was supposed to declare
of what I was promised. Such as where I would get only $200,000 at the time of the sale and
$100,000 each year thereafter, yet this arrangement had been proposed before and I had made it
clear that it was unacceptable. Especially since I needed a lot more than $200,000, just to
develop my land in Maine, not to mention, I would be giving up receiving the revenue I was
In effect, the portioning out the payments over eighteen years meant I was planning on getting
my last $100,000 payment when I was 103 years old. Moreover, when it was discussed that an
outside buyer would probably not be agreeable to my continued occupancy, we agreed that if it
was sold to an outsider then it must be for at least four Million, and we would split the extra
million above the three million. Insomuch as Pecunies got me to agree to the three million
amount through his insisting it was only worth $3 million, considering I would continue to live
Whereby, upon first glance, the agreement is an unconscionable contract, as it is what it was
intended to be, a one sided agreement, implemented in bad faith, as an artifice to a scheme.
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However, with blind sighted confidence in their intent to be fair-dealing, I signed the agreement
as an expression of my confidence with their ability to follow through with what they promised.
Yet, I was duped to sign over my rights, powers, and even the value of the equity of my property
to another party under the color I could stay. This is where I was contractually promised to net
$1,900,000.00 (after the approximate one million debt was met); or I would get 2.4 Million if an
However, plaintiff in their capacity as ‘management’ did nothing constructive, rather they
enthusiastically exploited this title to pressure me by imposing their absolute control. Even
without my receiving any benefit in return they substituted my rights of ownership with their
own, totally devoid of any quid-quo-pro factor in the equation of transference of right. Then to
add insult to injury, last April 2009, plaintiffs demanded from my tenants who were paying me
$3,600 to quit paying me rent and redirect their payments to them. This stopped my flow of
revenue that I was depending upon and was verbally agreed upon in shaping the agreement.
Essentially, Pecunies and his lawyer Steven Phillips duped me into signing an egregiously
confidence scheme intended to defraud me and inflict devastating injuries. In addition, Phillips
obtained my signature on the quit-claim deed through some manner of fraud. Such as where it
was falsely presented for me to sign as being a part of all the paperwork corresponding to what I
Whereas, papers I signed may of turned out instead to be for a mortgage on my own property
naming Pecunies as the “Lender” on my mortgage. On the ‘agreement’ I signed it stated it was
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to be a loan from plaintiffs that was to be derived from a mortgage placed on my property. Yet, I
did not realize this because I didn’t read through the agreement before I signed it and believed up
to October 2009 that the fact I accepted a loan gave them legal right of owning 50%. As it was
I was shocked when I was told in October 2009 that I had transferred the title from my name, as I
was never informed that this occurred. In addition when Pecunies attempted to bring the fact that
the LLC’s had the deeds in its name to bolster his position, he was abruptly stopped in mid-
sentence by Kaelin giving a ‘queue’ by saying: “OK.” Clearly, the transferred deeds was a
material fact they wanted me not to be privileged to know had occurred, lest I might raise this as
Essentially, I was either tricked in signing the paperwork for the loan, or the other possibility is
that either the documents I signed were altered thereafter, or my signature was forged. In effect,
whatever the scenario that was played out for plaintiff to have obtained my required signatures,
the fact is that the transference was not what I agreed upon. Since, I was never even asked to sign
the deed to my property over to the LLCs. Thereby, since the title transference was without my
The plaintiffs’ obscene sense of right of entitlement (albeit on the basis of having tricked me into
signing onto the said agreements) was that in 2006 they refused to be brought out of the contract
for $100,000. Later it was increased to $600,000, just to get the farm property back. This is
because but they still said it wasn’t enough money. At the time I was just hopping on getting my
22
farm back. At the time I was lied to by being told that at the closing of refinancing that Pecunies
and Watson each put up $125,000.00, but in actuality they got about $460,000.00 ( plus
In effect, they were expecting me to cover the discrepancy created in the fiduciary accounting
from their act of embezzlement with bank fraud. However, at the time I believed I was paying
plaintiffs back for what they claimed they paid out, because my lawyer Aldamis backed up this
fraudulent claim that they put up their own funds. Yet, when Phillips sent the papers and I saw it
said if there was any dispute I would not have a right to a jury I became suspicious and I back
out.
The plaintiffs executed a calculated scheme to mislead me to gain an unlawful legal advantage to
swindle me out of my rights and powers to my own property. This was carried out in a
conspiracy through a pervasive pattern of fraud and deceit to rob me, even with the complicity
with all four of the lawyers I hired; since my own lawyers acted in furtherance of supporting the
agenda of the plaintiff, by constantly and continuously working adverse to my legal interests.
This manifested by my lawyers’ extreme and chronic dereliction of supporting my legal interests
and providing false testament of bogus facts. This was all dedicated to be in support of bolstering
23
Whereby, Katz was the last lawyer I have dismissed for ‘cause’, due to my conviction he was
double dealing, as is verifiable to anyone who would read the last letters he sent me in December
“Pecunies and Watson are now taking the position that they will no longer contribute
mortgage payments and a foreclosure is now possible. Of course, if the mortgage is
foreclosed, it will affect both pieces of property and the likelihood of you receiving any
substantial sums after a foreclosure sale are doubtful. It is my personal belief that one of the
pieces must be sold to substantially liquidate the mortgage which would reduce the carrying
costs and thereby make it possible to hold on to the other piece for a more advantageous
sale.”
“I have found you to be a difficult and stubborn client. You fail to understand the
realities of the situation that you have placed yourself in. You failed to grasp that your
prior agreements in Court, the judgments that were entered against you, your statements
and stipulations in Court, your failure to get proper representation before signing
documents and agreements and your misconduct in the last year or so by reentering the
property, and exerting control over the property and collecting rents to which you had no
legal right have put you in a position of severe jeopardy. Unfortunately, I have not been
able to convince you of your substantial exposure to the claims that Pecunies and Watson
are now making against you. “
Such a statement appears to have sprung out more from the mind of the plaintiffs’ lawyer. Since
it interfaces perfectly with what they want me to believe and do. While, what is said in the
opportunities; except to agree to the sale of one property, just to pay off the debts that I never
occurred; and then have my ‘hat in hand’, to accept whatever plaintiffs determine is my half of
the equity left over after the sale of the second property.
24
Now, with considering that a standard of misconduct that constitutes an act of fraud is the
concealment of that which should have been disclosed. So as it was with Katz’s contractual
promise of providing legal representation that was defacto implied would be prudent and
zealous; yet in fact was fraudulent. Rather, this afore stated letter on its face, can be construed to
acts I would never even consider by acting under my own volition. Albeit, an ambitious attempt
intimidation, and moral coercion. Not to mention, Katz was attempting to install in me the belief
of fear of economic loss if I did not do what the opposition wanted I will lose everything.
Yet, what is most obscene with the legal advice Katz gave me in the letter was that it was an
attempt to abuse of the trust I extended to him as leverage to manipulate me. Thereby, to do
something that would not only devastatingly harm me financially, but would psychologically
scare me for the rest of my limited existence. Since for me to settle now for a couple of $100,000
and be without my cherished home and farm enterprise when I could of easily had over THREE
MILLION, plus my home, if I just sold my farm in 2001, or listed my properties on the open
market 2004 or thereafter, would tear open an emotional wound that I would never heal from.
My outrage of the audacity that Pecunies has of treating me as a pushover was never given a time
of respite or time to subside. Such as when after the first year he attempted to get me to sell both
of the entire properties for $800,000 by telling me I would be getting more than the properties
were worth. However, at this time the figures show with considering they want to sell of the
property with my home for $900.000 and the other property if it is reduced as much as my home
25
will fetch $1.8 million. Yet, with considering a lot more than 2 million is owed on both
properties debts are paid off, plus brokers fee, hardly anything, if anything at all, will be left over
In effect, what Katz was advising me as my council that the law viewed me as the only one
acting in bad faith. Moreover that the only legal option I possessed was to agree to whatever
Pecunies was offering me, or the consequence was that I would lose everything. Exactly, the
same legal support I received from Donald Brown, when he coerced me to sign a stipulation,
“If you don’t sign this stipulation now, then they will have the ability to suck out all the
equity in your property.” “In addition, brown assured me he was going to be filing an
action in a higher court in a few weeks, so what I was signing now would not matter after
this new action was filed.
me, a great sense of urgency that I had to sign, right then and now. However, when I later
enquired when the action would be filed, Brown said that he could only do the work for me if I
paid him $20,000.00, even though he knew at that time I had very little money. Thus, by him
demanding $20,000.00 he knew I would not be able to meet his request. Consequently, Brown
did not do the action that he promised, so I hired Katz, and he did more of the same.
I have serious issues of major abusive mistreatment that I had endured from Browns ambitions
to beat me down, dominate and control me. This is where he had the audacity to act out with
malicious intent to interfere with my ability to prevail in court. Specifically, with the misconduct
of Brown to thwart a demand that plaintiff put forth as a requirement for them to allow me to
26
continue in occupancy and drop the eviction action. This was when plaintiff said they would
require at least $24,000 to insure that they were no longer injured by my fraudulently claimed
delinquency to pay my $1,000 rental obligation. To wit, even though it was known I had no
money I was able borrowed $24,000 at a very high rate of interest from a ‘private lender’.
Whereas, I was motivated to get this “painful loan,” out of desperation of saving myself from
being evicted. Not to mention, I was even willing to pay twice from the money I had to spend in
rehabilitation of all the extensive damage caused from the burst pipes and to give them the
advance rent that they demanded. (Of which it is beyond belief that my reliable heating system
happened to have stopped on its own while I was in Florida) This $24,000.00 was to pay money
for past rent and to be applied to future rents. Yet, Brown was avoiding applying the rent to
satisfy the stipulated requirement of plaintiff. In fact, the judge did not even know about its
For some reason, yet to be explained this $24,000,00 was held by the court and my stipulation
was not vacated for about five months. This was extraordinarily disturbing to me because each
month this certified check was held was accruing a very high interest. Then when I went before
the judge to get the check back, Kaelin said “we are holding it as a hammer upon his head.” To
wit I replied to the court: “When I last looked in the mirror this morning to shave, my head didn’t
Then, the requirement to satisfy the court was that I had to show I had a lease for them to release
the check. As this was the only way I would get the money back if I showed a lease.
27
Thus, I had Mr Gramacy drive in early from Florida to write up a lease because I was to live with
them on my property that they were paying rent to plaintiff. Although, Brown charged me $500
for writing it up he did not submit it to the court. In fact he then refused to provide me with a
copy of it for me to use in court even though I paid him $500, that was something I could have
done myself, but it was demanded it had to be from a lawyer, yet he refused to give me a copy or
submit to court and it took me a great effort to get the check back myself from the Clerk. As a
result of that finally abuse I hired his law associate Heisler to represent my interests, upon
Now with addressing the professional malfeasance of my last lawyer, Katz, he not only did not
do any discovery to counter this eviction action, as so it was with the scheduling order, dated
April 6th, 2009 ( exh ) This was the case management for the discovery to the pending action in
the Superior Court, that Katz handled. This is where all the scheduled time to complete
discovery and submit the trial itinerary has already lapsed at the end of last year for this litigant.
Consequently, this litigant’s adversary, the plaintiff to this action can move the Superior Court
that this litigant should be precluded from doing discovery. However, the fact is that defendant
probably needs to subpoena the records of the bank that wrote the mortgage to Pecunies as he is
named as the borrower. This bank M&T, put a two million lean on defendant’s property where
the open-end mortgage has been met, and now the properties are going into foreclosure.
Moreover, when Katz first filed the action in Superior court against plaintiff, fraud was
mentioned in the numerous elements composing the cause of action. Yet, Katz lied to me, saying
28
he had to amend the petition, because the time restrictions for fraud had lapsed and the only
Yet, this is a bold faced lie and fraudulent misrepresentation of a material fact, which I was
relying on. Since, contracts in Connecticut have a six year statute of limitations. Instead, the
pleading is now confined to a general cause of breach of contract, and was needlessly scheduled
for a complex litigation trial in 18 months. Yet, dissolution of a corporation can be obtained by
an injunction that can be heard in a matter of less than a month upon its application when fraud is
rather it indicates that collusion occurred. This is with the wanton acts done by all my lawyers, to
support the other side’s ability to achieve their business goals. Whereby, perverting the judicial
process and contract law through foul play, maliciously misapplied for unlawful self gain; albeit
at the life devastating detriment of imposing an emotional nightmare on a frail senior citizen.
Although what bothers me most is with knowing that this nightmare I have been entrapped in
was facilitated by my good nature to be kind and generous to plaintiff. Since I knew that I gave
them a price well below market, and was willing to do whatever they wanted to smooth their
way.
29
Thereby, to support their ability to consummate the deal, not realizing the affect my trusting
them would have on threatening to shorten my life. As I am absolutely, convinced they would be
delighted if I dropped dead from a heart attack that triggered a stroke that they caused.
Since they wouldn’t have to beat me down anymore and this would lock in their efforts of
preventing me from standing up to them, or contradicting their lies. In effect, finally eliminating
an obstacle that has long stood in their way of getting what they wanted.
Insomuch as my dropping dead, is a medical fact that I am warned can occur, due to my
biochemical disposition of having high levels of adrenalin and cortisone in my body. Since this is
the direct causation of plaintiff’s five year campaign of terrorizing me that has made me neurotic,
In effect, I worry constantly. This is where my mind has become obsessed and fixed at being
constantly focused at how I have been outrageously abused, exploited and mistreated. Not only
from plaintiffs malicious assaults to intimidate me into submission, but from the obscene
mistreatment from all four of my own lawyers. It seems as though those whom I trusted, have all
stabbed me in my back in return. Albeit compounded by the injustice I have received from the
courts that believe anything plaintiff says. Yet, when I ask to testify as to what the true facts are,
Consequently, I feel persecuted and downtrodden, while all the malicious abuse I have received
compounds upon each incident. This is from the all the threats and other malicious mistreatment
I have endured that has been directed at me by wrong-doers to have the desired result of causing
30
devastating injuries. Consequently, causing me to be constantly entertaining feelings of intense
aggravation, frustration, worry and horror. This is where my mind is fixated on being the
recipient of obscene abuse, exploitation, and mistreatment that I received from plaintiff. Along
with those who support their efforts that have made my life miserable, and caused me to feel I
As a result of the constant agitated anxiety and the frustration from never receiving any justice, I
am extraordinarily annoyed at myself for signing what I did. This is for allowing others to
exploit me, and run roughshod over me, due to my trusting them. Since I am entrapped within a
predicament where I feel vulnerable and fear I am on the blink of becoming homeless by blindly
believing in the integrity of others . . . that has resulted in transforming my life into a living hell.
These are miserable feelings I have turned this inward, being annoyed with myself for allowing
Consequently, I experience reactive depression, where I now feel helpless, and without any
power, or hope that things will get better. Rather, if not but for someone who came into my life
who has given me hope that I can prevail in court, I am sure I would now have been feeling as if
Insomuch as I am facing the prospect of becoming homeless, unable to benefit from the unpaid
services of my health aid, and the pending loss of my land in Maine. Since the note is coming
due to the bank who gave me the loan to start the development of my land in Maine that I still
need to build its roads. Thereby, my only option to survive would be to become a ward of the
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state and go into a nursing home to live out the rest of my miserable life. My horrible situation in
my life now is all contributed to the insatiable greed of plaintiff and those supporting his agenda.
Since the fact of my current situation is that plaintiff has usurped my wealth and drove me to be
in deep debt. Yet, before I did business with plaintiff, I planned to work my land as a farmer as
long as I was physically able and then I would retire and have the where-what-for-all to live
comfortably. However, although I have worked hard all my life I now don’t have the ability to
get quality medical care, since I lack funds for the co-pay. This is of great concern, due to my
frail health where on a daily basis I have difficulty breathing and entertain a state of malaise.
In effect, the plaintiff, Pecunies and Watson, acted in a conspiracy with accomplices, their
attorney Phillips and my attorneys Demetrois Adamis, along with Donald M. Brown and his
associate Abrim Heisler, along with my last attorney, Mark Katz. This was a conspiracy
of RICCO. Essentially, they have acting in consort in support of achieving real estate fraud under
Yet, even the buying option was dishonest since the three million dollar price, instead of the four
million it would bring on the open market. This was based upon a false promise to me that even
though I was selling the property, I could still stay on the property, and still serve my customers
in my farm store. In fact, the only concern of a threat to me that I thought I would ever entertain
might be a pending thunderstorm, when I would have to rush to bring in my flowers from getting
32
damaged. Yet, I never believed in this day and age I would be a victim of organized crime,
looting my wealth, and harassing me, to drive me out of where I always planned to live.
Whereby, plaintiffs deprived me out of my rights to my own property under the color of
Pecunies and Watson’s legal right, albeit fabricated through extrinsic fraud and misuse of the
judicial process. This is in accordance to U.S.C., which defines an act of racketeering in Title 18,
extortion. This is when without my knowledge, authorization, or with ever being informed
thereafter, the wrongdoers mortgaged my property for $1,480,000.00. Consequently, about four
hundred thousand is unaccounted as to what happened to it. Even though the agreement and
understanding I had with them was specific to my only having authorized a refinancing to get the
mortgage reduced from the rate of 8.5%. Considering that even if a checking account was set up
for the LCC’s, it is improper that I am not included as a principal since the LLC’s is half owned
by me. Also no meetings were ever held for me to have authorized anything. Thus, no party has
controlling interest to assign financial control or management thereof. Yet, now the wrongdoers
lawyer Philips is the trustee and entitled to a percentage of its revenue, 9exh )
Although in plaintiff’s court papers they explain that the partnership came about at the time I was
facing eminent foreclosure, and they bailed me out with their money and credit. Yet, nothing
33
could be further from the truth (exh. ). Since, I didn’t need their credit for refinancing, because at
the time they had approached me my mortgagers had offered me a retention agreement.
Moreover, since my prior existing mortgage was only $980,000 compared to the value of my
land, and with considering my revenue from rentals, social security check, and sales from my
farm stand, refinancing on my own and getting a good rate would have been a simple task. In
fact, I am sure I could have secured at the same time a better rate than ½% below the maximum
No foreseeable explanation can justify why Pecunies waited six months after the agreement in
May 2004 to get the new mortgage in November. Further contradicting the oppositions claim in
their pleadings for my eviction is that I took advantage of them to offset losing my property. This
is where they falsely claim that they personally had invested a lot of their own money into the
property.
Moreover, with falsely claiming that the property was incurring more of a burden of expense on
them each day, while I in return was interfering with their ability to sell the property. Whereas,
the mortgage they got does not show a rate; rather the note states that it is one half of a percent
below the maximum legal rate, which is hard to understand why they could not have gotten a
better rate. (On the other hand, outside of my receiving the $40,000, I hardly received any more
revenue from my property, since the agreement five years ago. Outside of my agreed ability to
collect $3,600 monthly in rents for four years, but I paid plaintiff $1,000 of this.
34
In addition, the wrongdoers abused their position as managers of the LCCs to collect numerous
rents from tenants on my property, including $1,000.00 per month from me. Since, they didn’t
deposit any of the rents that they collected in the accounts of the LCC’s (where I was a 50%
owner), rather they comingled the funds with their own accounts as their personal money.These
self serving acts of appropriating revenue generated from my property when they have no legal
right, constituted conversion. Insomuch as all of the rent checks they collected were deposited in
The wrongdoers committing extrinsic fraud when they lied in their eviction papers by stating I
never paid the $1,000 rent November 2004. I was consistently paying all of my rent from the
onset in to them (I have canceled checks to prove it) until April 2008. This was when they told
me to redirect my rent payment towards restoring the major damage that was done to my
apartment from flooding when the pipes in my apartment froze and burst in 2006, which appears
The water damage had occurred when I was in Florida over the winter, and although I am
absolutely confident that I left the heat on at the time I left in the fall, when it was already cold,
for some reason yet to be explained, the pipes froze, burst and then flooded the apartment. At the
time I asked the wrongdoers to send an adjuster to restore the damage, but they claimed, there
was no insurance (unlike before when I was managing my own property and was covered). Thus,
in total I spent about $15,000.00 with replacing the damaged plumbing, kitchen cabinets, rugs,
35
Then, after the last time I returned from Florida in April 2009, the wrongdoers broke into the
apartment of my health-aid, Joanne Gramacy to change the locks for an illegal lock out. Then
when I asked for them to let us in they said they could not because they had lost the key.
Thereafter, it took them two days to let us back into the apartment, only after I had contacted the
authorities to force their compliance. Yet, Ms Grammacy was paying them monthly rents when I
was staying with her in Florida. The issue that the plaintiff had with her was that I was staying
with her, this was where they gave her notice to leave at the end of September for no other
reason but she was my health aid and they did not want me on my own property.
I only now have revenue of $613 from my social security check, yet, my car payment alone is
$583, no savings, my credit cards are all maxed out and I have been borrowing each month just
to pay off the minimum amounts. Essentially, I had borrowed many tens of thousands from
friends
Specifically, the original agreement was that the they would collect approximately $6,300 total
from most of my tenants, while I was entitled to collect $3,700 from four tenants However, when
I was in Florida one year ago the wrongdoers intimated my tenants out of fear they would abuse
their power of management and evict them if they did not quit paying rent to me and pay them
instead. Thus, they breached the agreement with conduct of extortion to deprive me from the
revenue from rents that I needed to pay them the $1,000 that they demanded. But when they took
me to court they stated in their papers that I never paid them anything.
36
Noteworthy, is that the mortgagor who encumbered my property was privileged to the
foreknowledge that Pecunies achieved title by filing, the very day this mortgage was signed onto
by parties and filed. Albeit, the County Clerk’s record before the mortgage indicates conveyance
was achieved upon my acceptance of a second $20,000.00 mortgage applied for by Pecunies.
This is where 10 days before, and without my own representation, I signed onto a quit-claim on
However, I was told that they would be getting another mortgage to reduce the current 8.5.% ,
rate for their ability to buy the property. In addition, I was told to sign a paper after the afore
mentioned agreement of reducing my interest to 50% by their lawyer Philips who said that it was
necessary for them to get the mortgage and after they got the mortgage they would change it
back to my 100% ownership, which they later out right refused to do. This was presented to me
that the loans would be in exchange for my entering into an agreement through the setting up of
LCC’s so they could have the legal authority to be business managers of my property. This is
where I was told that the LCC’s would first list me as 50% owner for practical purposes,
Consequently, Pecunies authority of title was based upon his being a partner in two LCC’s that I
signed onto as holding 50% of its shares. Thus, this raises serious questions as to what if any of
the papers of the said LCC’s the lender was going by in its loan application to determine the
authority of the principal parties composing the LCC’s. Moreover, why was no due diligence
done by the mortgagor to identify the legitimacy of the right of title to my property. Since, my
37
having 50% ownership in the LCC, made my authorization mandated for any business decision
Whereas by face appearance of the documents corresponding to the tile of right to Pecunies was
achieved that day by issuing the prior owner (me) a $40,000.00 loan that was written into the
mortgage as Pecunies was identified as being the “lender;” as opposed to almost every other
instance the obtaining right of title to a property is through its purchase, not by issuing a
mortgaging.
Noteworthy, is that it appears the property debt at the time was about $950,000.00, and my
$40,000.00 loan was written into the mortgage at the rate of 6%. Pecunies and Watson were each
identified as borrowers to receive one million each from M&T as an open-end loan established
by a two million lean on my property. On the mortgage where they signed it states that they are
attesting to be the sole owners of the property where Pecunies signs as the executive director of
RKD Ventures. I do not find my signature anywhere on the mortgage. However, it is on a quit
claim that was witnessed by two individuals in the Mercedes Benz office owned by P&W and by
Steven Philips, their lawyer, who misrepresented whatever I signed as either paperwork for the
$40,000.00 loan that turned out to be a mortgage, or to assist P &W to get refinancing on the
properties This is where I signed on two “Quit Claim Deed” where I am identified as : the
releaser, for consideration paid, does hereby grant to R.K.D VENTURE TWO… with quitclaim
38
Consequently, although I was paid $20,000.00 for each property it was money received
identified as being a part of the mortgage where it states I am to pay a 6% interests. Although I
was paid from the lending bank, it was money produced from a mortgage on my property. Thus,
the quit claim is subject to be summary set aside, according to the “Uniform Fraudulent
Transference Act’ that requires payment of a ‘fair consideration’ for real property. Consequently,
because it was clearly a bad title with a defective chain of title no innocent explanation can
Especially, as in this instance, where the mortgage shown the consideration paid was only just
Rather, more of an indication of the possibility that the mortgagor acted in complicity with
Pecunies through intentional neglect to verify the legitimacy of his right to tile to receive one and
a half million dollars on the basis of showing my signature on some documents, in absence of
However, beyond the fact that I was a 50% principal of the LCC, I was not consulted, authorized
or informed about this loan, the condition of the purpose of the loan was violated. Insomuch as
“Purpose of the Loan…(b) that all loans shall be used for business purpose, and not for
any personal, family or household purpose…”
M&T on November 18th, 2004 lent to R.K.D. Venture LLC (LCC), the sum of $1,000,000.00. In
addition, also on November 18th, 2004, M&T lent to R.K.D. Venture 2, LLC (LCC2), the sum of
$480,000.00. The total amount of $1,480,000 dollars was assigned to and received by Pecunies,
39
the representative of the LCC and LCC2, as its “executive manager.” This is where Pecunies
signed onto the two loan instruments of an “open-end mortgage” with MTC on the disputed
In effect, these open-end mortgages allow additional monies to be borrowed against the property
put up as the assets to provide the security for the loans. This money was loaned with a promise
by the LCC and LCC2 (mortgagors) of a pay back of the outstanding principal with interest to be
calculated as one half of one percent below the maximum legal rate that was not identified in the
instruments filed with the Town Clerk’s office (exh. ). Yet, Pecunies authority to obtain the
mortgages was without MY authorization as the legitimate owner of the property. Rather, this
Insomuch as this loan was achieved by a scheme and an artifice, and conversion to affect a
fraudulent conveyance and fraudulently obtain the said mortgages. Thereby, to defraud me out of
My complaint against my lawyers is of them being in collusion with the other side. Since, the
historical facts and circumstances supports the conclusion that they have acted in concert and
separately with the plaintiffs. This is for the furtherance of plaintiffs’ ability to achieve a
common goal shared with all the lawyers. Thereby, to affect the causation of my being deprived
40
Consequently, I am complaining herein about the professional misconduct of each lawyer as an
individual actor. This is where I will show how they acted to interfere with my legal rights to be
their skill, knowledge and aptitude as being licensed lawyers. In effect, they perpetrated
misconduct under the color of being “officers of the court,” where they not only egregiously
Whereas, my lawyer’s violated the trust I bestowed upon them and the professional duty of
responsibility that they owed to me as their client. This is manifested by their dereliction to apply
the law in an appropriate manner to the matters in dispute and with their affirmative action’s that
benefited the intent of the opposition to perpetrate a hoax on the court; as well as with perverting
the authority of the court to further their scheme’s ability to succeed. Thereby, all these lawyers
misconduct made possible the evil intent of the opposition to cheat me. This is by perpetrating
fraud and deceit through a scheme and artifices. Since, if any of these lawyers were honest
and/or forthcoming at the very early stage the agreement would have been duly dissolved as an
in State Court and prevent my eviction based on fraudulent misrepresentations of material facts.
This was manifested by their perverting their discretionary authority as if their professional
misconduct is beyond reproach. Thereby, to deprive me from having my legal rights upheld,
41
Clarification of the lawyer’s performance of judicial misconduct is readily validated as being a
material fact upon a review of the record to the proceedings corresponding to the eviction action.
In fact, just a cursory view upon the court records shows a material fact of judicial wrongfulness
was performed in a chronic, extreme and pervasive pattern. Consequently, the confluence of
factors of their judicial misconduct substantiates that the offending conduct not only constituted
gross dereliction of duty, but clearly was improper and unlawful. Whereby, to such an extent that
it would appear to a detached observer privileged to the facts that my lawyers acted as double
agents. Thereby the lawyers manipulated the authority and the records in the courts to pave a
road of credibility to the bogus claims of the opposition’s arguments. In effect, all my lawyers
mislead me to believe that plaintiffs are justified as a matter of legal right to entitlement. Except
Katz when he first was hired him had told me I had a case, only later to falsely tell me he found
Whereas, the improper conduct of all of my lawyers constituted a palpable and pervasive pattern
of unbridled support for the opposition’s interests. Consequently, all of the misconduct I endured
from the malfeasant intent of the wrongdoers and the lawyers has caused a severe emotional
wounding and traumatizing. In fact after I was coerced to a buyout containing al the terms
Yet, with no explanation except that plaintiffs felt they could get more out of their scheme that at
one time he said I could buy myself out of the agreement for $100,000, to wit he. Even though I
signed a settlement to dissolve the LCC I agreed that they could keep about 380,000 plus another
approximately hundreds of thousands- they already collected rents. This was misrepresented by
Adamis as only costing me $100,000. This was explained that through mismanagement of the
42
mortgage a lot of money was imposed on the mortgage with penalties of hundreds of thousands
of dollars.
Thereafter, Steven Philips, lied and said he never agreed to the buy out to even though the
bargain had already been worked out an on papers that my lawyer, Aldamis drew up. I was upset
and told him: “your soul is going to burn in hell” to wit, he told me as he was walking out the
door to leave said “drop dead Del.” This was witnessed by my friend Joanne Gramacy and my
lawyer Adamis. Consequently, it occurs to me nothing would please the opposition more than if
all the aggravation and worry that they have imposed on me causes me to have a heart attack and
drop dead. Insomuch as my lawyers have stated for the court record, verification of the bogus
claims of the opposition. This is on the history of my business dealings with them to provide
In fact, due to my extremely poor state of health and onslaught of malicious assaults on my
major depression and acute anxiety disorder with a perpetual post traumatic stress disorder.
Since, my health has dramatically deteriorated due to the shockingly abusive mistreatment I
endured over the last five years from the evil intent of the opposition to injure me. Then upon
this emotional distress they caused was further compounded by my own lawyer’s malicious
misconduct that on face supports the devious agenda of my opposition. Moreover, my poor
health is profoundly made worse by my poverty and inability to pay for the quality medical and
psychological care that I desperately need; so as to uplift me out from this living nightmare.
Thus, along with the suffering from my poor physical health I am contending with “reactive
depression.” This is where I feel emotionally downtrodden with intense feelings of helplessness,
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where I dread in the near future I will be homeless and destitute, while now I barely can get by
after being driven off operating my farm stand on the road. Consequently, I have a sign that leads
up a road to where I have only a couple of items for sale, when last Friday I only had two
customers the entire day. Albeit the direct result from having my rights of ownership of my
property whose revenue and assets would have supported me for the rest of my life, literally
Wherefore, in consideration of the serious nature of stated allegations herein, and the possibility
Since, the conduct I am exposing is a pending threat to the public at large of this state.
Thus on face-value this matter is of great urgency to be addressed by the laws of the land for
societal’s benefit. Thereby, to give a warning to others out to exploit the trusting nature of our
seniors that their misconduct will not be tolerated, and they will be held accountable for their
criminal intent.
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Yours, truly,
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