REQUEST FOR JUDICIAL INTERVENTION es.sco (72012) Supreme. COURT, COUNTY oF Queens PAULD. GRAZIANO ar PAULA. VALLONE and THE BOARD OF ELECTIONS IN THE CITY OF NEW YORK AL, | O Contested ‘Busnes Enity (inching corporations, partnerstips, LLOS, 6) NOTE: For al Natiironalaciors whars ne parses have cnteren unser | Canract the age of 18 complet and atach the MATRIMONIAL Ril Addendum, For Unconosied Matimonil setons, use Rl rm UD-13, © treurarce (wnere insure is aperty, xcept artiraton) QUCC (ncusing sales, nagotebe instruments) TORTS O other Commerc: [OQ Asbestos onal © Breas: implant NOTE: For Commercial Divsion ssignment request [22 NYCRR § O Envirenmartal 202 70(6, compete and attach tho COMMERCIAL DIV Rul Addendum. wean REAL PROPERTY: tow mw toe he eas ae O Metical, Dental or Posiatric Malpractice ‘T candemnation Qworrvenice Onongege Foveconure wn ©) Restental OQ Conmersa © Products ist: Property Acaress ‘seat Sees ow a = Ootner Nepigerce: NOTE: For Mongage Forecicsure actons involving @ one- to foursamily, Wem] cmmeraotapeg, ecientl popuiy, orancomecosinee © omer Pretessionat Malpractice: ‘condominium, complate and attach the FORECLOSURE Rul Addendum. eT OQ Tex conor - sect Block be, 1O other For: Orex Foreciosure: aod Oorner Real Property: [OTHER WATTERS ‘ood Cortese of icorperator/Dissoluion (eee NOTE under Connecial [SPECIAL PROGEEDINGS. © Emergency Mesica Treatment CPLR Arico 75 (Ativaton) [see NOTE under COMNeraa] }O Habeas Corpus QCCPLR Article 78 (Body or Offic) 'O toca out Appeat © Election Law ‘O Mechanics en OWL artcte 0.80 (Kendre's Law) QName Change Omit. 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Other Menta Hygiene: Has a summons and conpiin or summons winotce beer ied? tyes, cate ne: as asummons and conpiaint or suminons winotce been served? = GS @ tyes. catesenod_ 's ts actorproceeding being led postudomant? © © tyes judgmontdete;Infants Conpronise Nota cf lsu enclor Cartcate of Read © force orMosicl Denial orPodievic Napractoe Dat lsue Joined - 8 Hotce ot tien Relief Sought: Retr Date Notce of Petition Fale Sougre Return Date © order 0 show Cause Rolie Sougre: ETECHOR LAW Return Date: © other Ex Parte Application Relief Sought: © Focr Person appicaion © Requestor Preliminary Confrence © Fesdental Motoace Foreceeure Stiement Conforence © Witotrcboas copie © ainer seecty) CASES: any eaedacioe ee aa eee a aay ine de Fal Cont ae He TindexiCase No. [Court [Judge (if assigned) | Relationship Fi Teese en SOTGY, RAL Un-Re ox AND aia party address, share nate’ ard anal Bian Fens POSE “comple and attach the Rl Addendum = a [Attorneys andlor Unrepresented Ltigants z esse 2 [ete epi eit ars [Prove stray ana vara brass odiesa PapeTomranreTa ele, | tmuranco Ne fbeterey ieee, [uiendsiateen cumctastca ps mecee™ fama | Senne ses at) Fagan. prove atten, pote rue’ ae seat sens F aRAEING joanne aaa teas ee iene Pauo LAworceor MASTNTE coon Ove oO may Re Je peacponr srrecr.«r+ —“gmoORLIN 20 Petitioner ea tae Oe he Senay oe any oeroacanse ses7seoea SENCEMI @A0L-5OM pe TASH PAULA. _ om = YES Rospondsnt tout tne oy ~~ © bon mien BOARD OF EESTIONG, CFV OF WRTENGER TE caine iis ruin | JConporanion cGUNSEL OF CTY OF NEW YORK Oo pinay Rae sco crunererneer. «rr rework 1007 | Respondent nar om aes. Secondary Rote (H any) |212s562087 SKITZING@LAW.NYC.GOV waa vt tae mes a cin ee = aetna Wo GAERIRM UNDER THE PENALTY OF PERJURY THAT, TO MY KNOWLEDGE, OTHER THAN AS NOTED ABOVE. THERE ARE AND HAVE BEEN NO RELATED ACTIONS OR PROCEEDINGS, NOR HAS A REQUEST FOR JUDICIAL INTERVENTION PREVIOUSLY BEEN FIL Co IN THIS ACTION OR PROCEEDING. Z a Dated: JULY 25,2017 Dhar EG SIGNATURE 1916958 MARTIN CONNOR “ATTORNEY REGISTRATION NUMBER PRINT OR TYPE NAME Ca]Fu Pert & VP Ata Special Election Part A of the Supreme Court of the State of New York, held in and for the County of Queens, at the Supreme Courthouse thereof, at 88-11 Sutphin Blvd., Jamaica, New York, on the 25" day of July, 2017. Index No. 747/147 PAUL D. GRAZIANO, Petitioner, ORDER TO SHOW CAUSE ~ against - PAUL A. VALLONE, 40 MOTION FEE, Candidate, 2 FILED ON and THE BOARD OF ELECTIONS IN THE CITY COMMENCEMENT OF NEW YORK, Respondents, For an Order Pursuant to Sections 16-100, 16-102 and 16-116 of the Election Law, Declaring Invalid the Designating Petition Purporting to Designate the Respondent-Candidate for the Public Office of Member of the New York City Council, in the 19" Council District, County of ‘Queens, State of New York, in the Democratic Party Primary Election to be held on September 12, 2017, and Restraining the said BOARD OF ELECTIONS from Printing and Placing the Name of Said Candidate Upon the Official Ballots of Such Primary Election. Upon the annexed petition of Paul D. Graziano, duly verified the 24” day of Jaly, 2017, and upon the original Democratic Party designating petition naming Respondent Paul A. Vallone (hereinafter “the Respondent-Candidatc”) as a candidate forthe public office of City CouneilMember tom the 19% Councilmanie District, Queens County, State of New York, and upon all the proceedings heretofore had herein, itis hereby: ORDERED, that the Respondents named herein above, Show Cause before this Court at Special Election Part A, to be held at the Courthouse, 88-11 Sutphin Boulevard, Jamaica, New York, in the Borough of Queens, Queens County, City and State of New York, Room ag. onthe _“Ytay of August, 2017 at 9:30 a.m, of that day or as soon thereafter as counsel can be heard, why an order should not be made and entered herein: 1. Declaring insufficient, defective, invalid, mull and void the designating petition filed with the BOARD OF ELECTIONS IN THE CITY OF NEW YORK, purporting to designate Respondent Paul A. Vallone as a candidate for the public office of City Council Member from the 19 Couneilmanie District, New York State, in the Democratic Party Primary Election to be held on September 12, 2017; and 2, Enjoining, restraining, and probibiting the BOARD OF ELECTIONS IN THE CITY OF NEW YORK from printing and placing the name of the said Respondent on the official ballots to be used at the September 12, 2017 Democratic Party Primary Election in the 19” Councilmanic District, County of Queens, City and State of New York; and 3. why the Petitioner should not have such other and further relief as to ‘this Court may seem just and proper in the premises; and it is further ORDERED, that the Respondent BOARD OF ELECTIONS IN THE CITY OF NEW YORK be and is hereby ordered to produce, ifand as may be further directed by the court, the aforesaid designating petition, cover sheet(s) and amended cover sheet(s), identification number application form(s) and any other documents purporting to designate the said Respondent-Candidate, any written notification of a determination of non-compliance together Jwith proof of service upon the candidate named therein, any writing purporting to cure or correct Said determination of non-compliance, the list of Election Districts for the 19" Councilmanic District, Queens County, City and State of New York and such other and further documents and 2:records as the court shall direct. SUFFICIENT CAUSE APPEARING THEREFOR, leave is hereby granted to the Petitioner to submit, upon the return day of this Order to Show Cause and any adjournments thereof, and the argument thereof, such additional evidence, exhibits, and other proof.as may be necessary. SUFFICIENT CAUSE APPEARING THEREFOR, it is further ORDERED, that service of a copy of this order, together with a copy of the papers upon which it is granted, on the Respondent BOARD OF ELECTIONS IN THE CITY OF NEW YORK be made by leaving @ copy of said order and papers at the General Office (headquarters) of the said BOARD OF ELECTIONS at 32 Broadway, 7" Floor, in the Borough of Manhattan, City of New York, on or before the 27" day of July, 2017; and it is further ORDERED, that service of a copy of this Order to Show Cause, together with a copy of the papers upon which it is omit upon the Respondent Paul A. Vallone, be made either (1) by "delivering the same to such Respondent personally pursuant to CPLR 308 (1) on or before the 27" day of July, 2017; or, (2) by enclosing the same in a securely sealed and duly prepaid wrapper, addressed to the said Respondent at the address set forth in his designating petition filed with the Board of Elections in the City of New York and by depositing the same in a Post Office Branch regularly maintained by the United States Postal Service in the City of New York, by Guaranteed Next Day Delivery Express mail, by 6:00 p.m. on the 25" day of July, 2017; or, ) by affixing the samie to the outer or inner door of the residence of the said Respondent at the address set forth in his designating petition filed with the Board of Elections in the City of New York, and by enclosing the same ina securely sealed and duly prepaid wrapper, addressed to said Respondent at the address set forth in his designating petition filed with the Board ofElections in the City of New York and by depositing the same in a Post Office Branch regularly maintained by the United States Postal Service in the City of New York, by Guaranteed Next Day Delivery Express mail, on or before the 26" day of July, 2017; and that such service shall be deemed due, timely, good and sufficient service thereof, and such service shall constitute sufficient notice hereof. ENTER , JSC HON, KEVIN J, KERRIGAN,SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS In the Matter of the Application of Index No. 759/117 PAUL D. GRAZIANO, VERIFIED PETITION Petitioner, ~ against - PAUL A. VALLONE, Candidate, and THE BOARD OF ELECTIONS IN THE CITY OF NEW YORK, Respondents, For an Order Pursuant to Sections 16-100, 16-102 and 16-116 of the Election Law, Declaring Invalid the Designating Petition Purporting to Designate the Respondent-Candidate for the Public Office of Member of the New York City Council, in the 19" Council District, County of Queens, State of New York, in the Democratic Party Primary Election to be held on September 12, 2017, and Restraining the said BOARD OF ELECTIONS. from Printing and Placing the Name of Said Candidate Upon the Official Ballots of Such Primary Election. TO THE SUPREME COURT OF THE STATE OF NEW YORK: ‘The Petitioner, by his attomey, Martin E. Connor, respectfully shows and alleges: |. Petitioner Paul D, Graziano resides at 146-24 32"4 Avenue, Flushing New York 11354, + On July 12, 2017 a designating petition wes filed with the Board of Elections in the City of New York naming Petitioner as a candidate for Member of the New York City Council from the 19" Councilmanic District in the Democratic Party Primary Election to be held on September 12, 2017. 2. Therefore, Petitioner is a candidate aggrieved who has standing under Section 16-102 1of the Election Law to bring this proceeding de novo, 3. Atall of the times hereinafter mentioned, the Respondent BOARD OF ELECTIONS INTHE CITY OF NEW YORK was and is charged with the responsibility of the supervision of the conduct of official elections held in the City of New York, including the duties of receiving {or filing designating petitions for public office in political subdivisions located entirely within the City of New York, the review and determination of objections and specifications of objections to such designating petitions, notification of a determination of non-compliance, ‘maintaining the permanent personal voter registration poll records of voters and official maps for all election districts located within the City of New York, and the preparation of official Primary Election ballots for use in the City of New York. 4 That on July 10, 2017, there were filed with the BOARD OF ELECTIONS IN THE CITY OF NEW YORK certain papers allegedly constituting a petition purporting to designate for the September 12, 2017 Democratic Party Primary Election the following person for the public office as hereinafter set forth: Name of Candidate: Paul A. Vallone Place of Residence: 170-12 32™ Avenue Flushing, New York 11358 Public Office: City Council Member from the 19" Councilmanic District, Queens County, State of New York. 5. The aforesaid alleged designating petition filed by, or on behalf of, Respondent Paul A. Vallone is insufficient, ineffective and invalid, does not conform to the provisions of the Election Law and other Laws of the State of New York, and the Rules and Regulations of the NEW YORK STATE BOARD OF ELECTIONS and the BOARD OF ELECTIONS IN THE 2CITY OF NEW YORK, and is null and void by reason of the facts and allegations set forth herein and the Respondent BOARD OF ELECTIONS IN THE CITY OF NEW YORK should be restrained and enjoined from printing the name of said Respondent upon the official ballots of said Primary Election, 6. Upon information and belief, the designating petition naming the Respondent as a candidate for the aforesaid public office is invalid by reason of the following facts: fa) ) © (@ (e) (ea) @ ‘That the petition does not contzin the minimum number of valid signatures of registered voters enrolled in the Democratic Party in the 19% Councilmanic District required for the designation, ‘That many of the signers are not registered voters at the residence addresses given in said petition and were not and are not qualified electors and their names cannot be counted as valid. That signatures to the said petition were obtained in violation of law. That on some of the respective sheets of the purported petition, material alterations and/or additions were made thereon subsequent to the obtaining of the signatures and/or subsequent to the execution thereof by the subscribing witnesses, That many of the signatories set forth incomplete, insuificient, or untrue residence addresses, or no addresses, ‘That many alterations, interlineations, erasures, and mutilations appear in dates and signatures of signatories. That many of those whose signatures appear on said purported petition had previously signed the same petition. 3w® oO (a) (a) © ) (@ w (s) That in some instances, the date of execution of witness statements is missing, incomplete, or insufficient, That the date of some signatures is incomplete, missing, or inaccurate. ‘That many persons signing said purported petition are not registered voters 4s stated although they allege on their sheets that they are registered, ‘That many signatories failed to set forth their complete and true names, ‘That in several instances, the addresses set forth for signers are incorrect and, in some instances, said addresses do not exist. ‘That in some instances, the subscribing witnesses on the respective sheets inaccurately set forth the number of signatures contained on the sheets, or did not set forth any number of signatures in the witness statement ‘That many persons who subscribed their names to the purported petition do not reside in the 19" Couneilmanic District, That some signatures are dated later than the dates of signatures appearing thereafter, on the same sheet. That some signatures are dated prior to the dates of signatures appeering above them, on the same sheet, That many of those whose signatures appear upon said petition, had, prior thereto, or on the same date, signed another petition for the same position, ‘That in some instances, the person whose name appears es the subscribing witness on a sheet also appears as a signatory on the sheet, ‘That on some sheets, the person appearing as the subscribing witness is not a registered voter and/or is not an enrolled Party member, as stated, 4& @) wy) (w) Oo &y) (2) (aa) (bb) (cc) although it is stated that such person is registered, That many of the subscribing witnesses on respective sheets set forth incomplete, insufficient, or untrue residence addresses, or no addresses, ‘That on some sheets, the name, address, number of signatures on sheet, date, and/or signature in the witness statement is illegible. ‘That the Witness Identification information on some sheets is missing or incorrect. ‘That the purported petition is invalid for other reasons, which will be established upon the heering of this application. That many signatures on the designating petition are invalid for the teasons set forth in the Specifications of Objections. That certain duplicate signatures attributed to the same voter were written by different individuals, That many of the signatures are printed and not written in the manner in which the purported voter signed the registration and poll records of the Board That many of the signatures attributed to different individuals are written by the same individual. That several of the subscribing witnesses are not the persons who collected or actually witnessed the signatories sign the sheets that they witnessed, ‘That many of the sheets of the petition are invalid due to fraud committed by the subscribing witness on other sheets of the petition, 5(dd) ‘That many sheets of the petition are invalid because the subscribing witnesses thereto witnessed sheets containing forged signatures of voters (Cc) That the petition is invalid because it does not contain sufficient valid signatures aside fiom signatures that are invalid due to fraud and forgery. () That the petition is invalid because it is permeated with fraud 7. James M. Lynch witnessed 19 pages of signatures containing 256 signatures. Those Signatures are contained on: pages 25, 26, 32, 33, 34, 35, 37, 38 and 39 of Volume QN1700017; pages 3 and 4 of Volume QNI700044; pages 12 through 19 of Volume QN1700047, 8 With a single exception, every signature on the sheets witnessed by James M. Lynch is dated June 28, 2017 and the witness statements are all dated June 30, 2017. The exception is a Single signature dated June 26 on page 26 of Volume QN1700047 on which all other signatures are dated June 28, 9. On June 28, 2017 a large celebratory event was held at Fort Totten with hundreds of people in attendance. At that event a large number of under 18-year-old high school students were observed collecting signatures on designating petitions for Respondent Vallone. 10, James M. Lynch was at the event. He demonstrably could not see all of the underage students who were soliciting and obtaining signatures. 11, Upon information and belief, James M. Lynch signed as subscribing witness for the signatures collected by under 18 year-old persons on June 28, 12. On page 18 of Volume QN1700047, James M. Lynch signed as the subscribing witness. The signatures of voters on lines 6, 7, 8, 9, 10, 12, 13, 14, 15, 18 and 20 of that page areforged. The forged signatures on lines 12 and 13 even misspelled the voters’ names. 13, On page 17 of Volume QN1700047, wimessed by James M. Lynch, the signatures on lines 5 and 6 are signed by the same person and not the voter(s). 14, The signatures on page 19 of Volume QN1700047 are witnessed by James M. Lynch and dated June 28. Upon information and belief, based on interviews with signers to that page, the signatures (including that of voter Grace Meng) were actually collected by Christine Coniglio at a soccer practice held weeks earlier in Cunningham Park. Mr. Lynch was not present at the soccer practice. Ms. Coniglio is the head of the Aubumdale Soccer League. Upon information and belief, Ms. Coniglio is a part time representative for Respondent Candidate. She also witnessed sheets 28 and 29 of QN1700047. 15. The conduct of James M. Lynch in witnessing sheets for which he did not see the voters sign, on which the dates are false, signatures are forged and/or other persons were the actual witness, constitutes fraud sufficient to invalidate all of the signatures witnessed by him. 16. Upon information and belief, based on interviews with persons, James M. Lynch is @ key person in Respondent Candidate's campsign and staff. His fraudulent conduct in the witnessing of petition sheets indicates a pattem and practice in the campaign of Respondent (Candidate such that the entire designating petition is invalid due to permeation with fraud. 17. Nicole Schmitt signed as the subscribing witness on sheet 10 of Volume QN1700017 and sheet 8 of Volume QN1700047. These two sheets contain signatures for the same voters, ‘The plain inference is that a single subscribing witness would not obtain two sheets from the same voters. Furthermore, the signature of voter Richard Coffey is forged and misspelled on one of the two sheets, 18, Millie Rigoli was the subscribing witness on sheets 42 and 43 of Volume yQN1700017. The first three signatures on sheet 42 and the signatures on 4 and 5 of'sheet 43 are forged. Further, the signature on line 7 of sheet 43 (Joan Bertrand) is forged. 19. Upon information and belief Karen LeRoy is an employee of the Board of Elections. She signed the petition at line 6 of page 4 in Volume QN1700017 on June 9, 2017 with her ‘eddress as being in Flushing, Queens. That sheet is witnessed by Patrick Jordan. 20. Karen LeRoy is the purported subscribing witness on two sheets of the petition: sheet 7 of QN1 700044 and sheet 33 of QN1700047. In the witness statement on those sheets Ms, LeRoy's address is given as being in the Bronx, her signature is forged and her initials are forged on an alteration in the witness statement. A comparison of handwriting indicates that the writing on these two sheets is that of Patrick Jordan. 21. Joy Chowdhury (aka Kartik Chowdhury) purported witnessed sheet 63 of QN1700047. However, his signature on the witness statement is forged and the printed name in the witness statement is misspelled. All other handwriting on the sheet (dates and witness Statement information) is that of Patrick Jordan. 22. Patrick Jordan witnessed sheet 5 of QN1 700018, The signatures on lines 3 and 4 (Nanette Dougherty and Larry Dangherty) were clearly signed by the same person, probably Nanette Dougherty. These signatures are dated June 10, However, on the same page and same date, at ine 15, Laurence Dougherty signed the petition. Yet, Patrick Jordan subscribed to, and Submitted both the clear forgery on line 4 and the genuine signature on line 15. 23. In total Patrick Jordan witnessed 233 signatures in the petition. In addition, his handwriting appears in dates and subscribing witness statements on numerous pages in the petition. 24. Upon information and belief, Patrick Jordan is the campaign manager for Respondent 8Candidate. Accordingly, his participation in fraud in connections with petitioning renders the petition invalid as permeated with fraud. 25. Petitioner is continuing his investigations and will more fully set forth allegations and evidence of fraud and invalidity in his Bill of Particulars and Offer of Proof to be filed on the return date of this proceeding. 26. In accordance with prior decisions of this and other Courts, whose decisions are controlling, Petitioner retains the right to submit proof establishing the invalidity of individual signatures and sheets on the purported petition not heretofore objected to, and of the purported Petition itself, for reasons not heretofore specified, and Petitioner intends to exercise such right. 27. Petitioner requests leave and reserves the right 1o submit upon the argument and hearing of this application, evidence by way of affidavits, testimony, and documentary proof to substantiate and support this application 28. Petitioner may request the Court to direct the Respondent BOARD OF ELECTIONS INTHE CITY OF NEW YORK to produce upon the argument and hearing of this applications the aforesaid designating petition, cover sheet(s) and amended cover sheet(s), identification. number application form(s) and any other documents purporting to designate the said Respondent candidate, any written notification of a determination of non-compliance together with proof of service upon the candidate or contact person named therein, any writing purporting to cure or correct said determination of non-compliance, and the official maps for the 19° Councilmanie District, Queens County, City and State of New York. 29, Other than this proceeding, Petitioner has no adequate, sufficient, or effective temedy at law.30. In order to effect immediate personal service of the annexed Order to Show Cause and this Petition on the Respondent BOARD OF ELECTIONS IN THE CITY OF NEW YORK, the Commissioners of whom are required at various times to be on official business at places other than their official business offices, its respectfully requested that this Court direct that such service may be made at the General Office (headquarters) of the said BOARD OF ELECTIONS at 32 Broadway, 7" Floor, Borough of Manhattan, New York, New York. 31. Petitioner requests leave to effect service of a copy of the Order to Show Cause, together with a copy of the papers on which itis granted, upon Respondent candidate other than by personal service because: (@) This proceeding must be instituted on or before July 27, 2017; (b) Petitioner may, despite diligent effort, be unable to effect personal service ‘upon such Respondent on or before such date, because such Respondent may purposely absent himself from his homes and places of business; (© __ Petitioner is aware that in election matters governed by Article 16 of the Election Law, orders granting alternative methods of service are routinely granted by this Court in accordance with statute and prior decisional case law. 32. In order that issues with respect to the allegations of this Petition be joined expeditiously, it is respectfully requested that the Court fix the time within which the respective Answers of the Respondent shall be served upon your Petitioners! attorney. 33. No previous application by Petitioner has been made for the relief sought herein or for the Order to Show Cause hereunto the annexed, or for any similar relief. WHEREFORE, Patitioner respectfully prays for the relief requested in the annexed Order to Show Cause and for a final Order granting the relief prayed for in the said Order to 10Show Cause, and for such other and further relief. as to this Court may seem just and proper in the premises, Dated: Brooklyn, New York July 24, 2017 Respectfully submitted, 61 Pierrepont Street, #71 Brooklyn, New York 11201 Telephone: 347-645-9146 Facsimile: 718-875-6044 Email: sendem | @ Atiomey for Petitioner. ulVERIFICATION STATE OF NEW YORK) ) ss: COUNTY OF KINGS} in the courts MARTIN E. CONNOR, an attorney admitted to practi of the State of New York, affirms under the penalty of perjury: 1am the attorney for the Petitioner in this Proceeding. I am not a party to this proceeding, Thave read the within Petition and know the contents thereof and the same are true to my knowledge; as to matters therein alleged on information and belief, I believe them to be true, The basis for my belief is that I have examined: Board of Elections records involved in this matter; have reviewed and analyzed the designating petition; have reviewed Specifications of Objections to the designating petition; and have interviewed various persons and witnesses familiar with the facts involved herein; videotape depicting certain events and persons relating to this matter. The reason that I am making this verification is that I have my office in the County of Kings and the Petitioner is located in the County of Queens. Dated: Brooklyn, New York July 24, 2017 thal MARTIN E. CONNORSUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS Index No. 75 7/117 PAUL D. GRAZIANO, Petitioner, -against- PAUL A. VALLONE , et ano., Respondents. ATTORNEY'S CERTIFICATION ‘The undersigned, being an attomey admitted to practice law in and before the Courts of the State of New York, hereby certifies that, to the best of my knowledge, information and belief, formed after an inquiry reasonable under the circumstances, the presentation of the within papers or the contentions therein are not frivolous as defined in 22 NYCRR 103-I.1c. July 24, 2017 Tag rik MARTIN E, CONNOR ORDER TO SHOW CAUSE. AND VERIFIED PETITION MARTIN E. CONNOR, ESQ. 61 Pierrepont Street, #71 Brooklyn, New York 11201 ‘Telephone: (347) 645-9146 Facsimile: (718) 875-6044 E-mail: sendem|@aol.com Attorney for Petitioner.