page  of  pages:  Koenig study of
The Honorable Carol E Huff, Justice (ret.)
NYS Supreme County for New York County
July 6 2018 0104 GMT

Started July 5 2018

The Honorable Carol E Huff

Justice [ret.]

New York State Supreme Court for New York County

NYS Registration Number: 1409218

150 W 131st Street APT 1

New York NY 10027-2036

+1.212.281.8826

Daniel Ward White Esq

NYS Registration Number: 1972736

Of Counsel

Chiesa Shahinian & Giantomasi PC

11 Times Square 31st Floor

New York NY 10036-6600

+1.973.530.2095

fax: +1.973.530.2295

dwhite@csglaw.com

The Honorable Martin Schoenfeld

NYS Registration #: 1121649

457 FDR Drive APT 2104

New York NY 10002

+1.212.979.8141


Chart of Exhibits:

Exhibit “_”:  Order The Honorable Carol E Huff signed March 25 1991 and filed (almost three months later) on June 18 1991

Exhibit “_”:  through Daniel Ward White Esq, 55 Liberty Owners Corp’s putative July 30 1991 Combined Demands

Exhibit “_”:  The Honorable Carol E Huff’s signed December 10 1992 Order of Preclusion; filed December 14 1992

Exhibit “_”:  The Honorable Carol E Huff’s Order _________ signed _________ and filed October 6 1993

Exhibit “_”:  The Honorable Carol E Huff’s Order _________ signed December 10 1992 and filed (five months later) May 12 1994

Exhibit “_”:  The Honorable Carol E Huff Order______signed January 10 1996 and filed January 19 1996

Exhibit “_”:  The Honorable Carol E Huff Order signed June 21 1997 filed July 25 1997


Dear Judge Huff:

Your order (and Judge Schoenfeld’s eager buying into it) is a product of extrinsic fraud on your court - perpetrated by officers of your court.

The ex parte shopping of the combined demand [Exhibit “_”] in a secret prove-up in your court room is particularly reprehensible.  And I believe you must bear the responsibility and the permanent public opprobrium that will run with your conduct in the matter.  It was your courtroom.

 

None of the documents requested and none of the particulars demanded had anything do with the four corners of the case.

As you knew, and as every attorney for 55 Liberty Owners Corp knew, and as every Board Member at 55 Liberty Owners Corp knew:

The essence of fair and honest dealing as it applied to the Koenig family’s duty and conduct was that the Koenig family should immediately set about repairing the extensive damage to their property and personalty, exclusively bearing all the costs  [1].

Daniel Ward White Esq and Carol Ann Pisano Esq did not need $10,000 of document production work to know that.

Daniel Ward White Esq and Carol Ann Pisano Esq need only to encourage their client to apply the permanent fix ordered by 55 Liberty Owners Corp’s professional consulting engineer, and while in the hole installing the flexible fitting, to abate the asbestos in anticipation of future repairs.

The extrinsic facts of the unfortunate situation triggered a defense by the Koenig family insurer; and Daniel Ward White Esq and Carol Ann Pisano Esq know that I am insured and that the Koenig family had indemnified us for just such an eventuality as 55 Liberty’s negligently exploding steam pipes.

If Daniel Ward White Esq and Carol Ann Pisano Esq were conducting a secret closet defense against the Koenig family insurer’s subrogated claim: Daniel Ward White Esq and Carol Ann Pisano Esq should have explained to the court.

The Koenig family was absolutely indifferent as to the $25,000 of costs that ran with the repair as the Koenig family was fully insured.

Your court knew that.

All that remains is to understand why Daniel Ward White Esq and Carol Ann Pisano Esq did not demand a copy of the Koenig family’s insurance policy if indeed a comprehensive document production was their intent.

But of course Daniel Ward White Esq and Carol Ann Pisano Esq already have a copy of the Koenig family insurance document as well as all the other documents that are demanded.

In toto:  the combined demand of Daniel Ward White Esq and Carol Ann Pisano Esq is libel by extrinsic fact:  and should be immediately sanctioned by the court and rejected by the court.



Exhibit “_”:  The Honorable Carol E Huff oeder ________ signed March 25 1991 and filed (almost three months later) on June 18 1991

Exhibit “_”:  The Honorable Carol E Huff’s December 10 1992 Order of Preclusion; signed December 101992 and filed December 14 1992

Exhibit “_”:  Combined Demands through Daniel Ward White Esq, 55 Liberty Owners Corp’s putative July 30 1991


Exhibit “_”:  The Honorable Carol E Huff’s Order _________ signed _________ and filed October 6 1993


Exhibit “_”:  The Honorable Carol E Huff’s order _________ signed December 10 1992 filed (five months later) May 12 1994

Exhibit:  The Honorable Carol E Huff order _________ signed January 10 1996 and filed January 19 1996

Exhibit “_”:   The Honorable Carol E Huff order _________ signed June 21 97 filed July 25 1997


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https://docs.google.com/document/d/1LKZKBHeMJr03JfUTeEewN5EKHx9se7CxOIr2JFrA7jY/edit#

http://compartmentalizedfraud.com/fraud_upon_the_court/nys_supreme_court_judge_carol_e_huff 

http://compartmentalizedfraud.com/fraud_upon_the_court/nys_supreme_court_judge_carol_e_huff/nys_supreme_court_judge_carol_e_huff_load_w_ip_address.php 


Discussion of Compartmentalized Fraud

http://compartmentalizedfraud.com/fraud_upon_the_court/nys_supreme_court_judge_carol_e_huff/index_set_aside_07_jul_18.html 


[1] The single one document which might have altered the Koenig family’s responsibilities would have been proof positive that some or all of the damages fixtures had been installed by the sponsor or perhaps by the first sponsor/shareholder - Stephen Edward Globus.

Those records are under the exclusive control of Daniel Ward White Esq.