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Koenig to Paul Gottsegen
July 1 2018 2338 GMT

Started February 20 2018

Paul Gottsegen
Time Equities
55 Fifth Avenue 15th Floor
New York NY 10003-4398
fax: +1.212.727.0563

Dear Mr Gottsegen:

I am not a lawyer, and I don’t want to “practice law” with you.  But here’s what’s happening.   I seek to resuscitate an action in NYS Supreme Court for New York County on the basis of extrinsic fraud upon the court.

Without wishing to bore you with the legal details: my theory is that the conspiracy between 55 Liberty Owners Corp lawyers:

Michael Seth Feuer Esq  [1]  Henry Lee Saurborn Esq [2]  Phyllis H Weisberg Esq  [3]  Fred L Seeman Esq  [4]  Daniel Ward White Esq  [5] , Carol A Pisano Esq  [6] , Alan M Goldberg Esq  [7] , Aaron "Ron" Goldstein Esq [8],  Jonathan Jay Fink Esq [9], James Gaither Samson Esq [10]

and my unincorporated insurance syndicate’s lawyers:

Neil Leslie Kanzer Esq [11],  Anthony D Perri Esq [12],  John Robert Seybert Esq [13],   Deborah Ann Pochtar Esq [14],   Bradford Whitman Rich Esq [15],   William M McCrae Esq [16],  David Arnold Woodard Esq [17],  Deneen Lynette Donnley Esq ,[18]  Steven Allan Bennett Esq  [19],  Kenneth W Smith Esq ,[20]  Steven A Bennett Esq  [21],  George Edward Joy Esq [22]

had the effect of generating a failure to join necessary parties to the action:  which is canon extrinsic fraud.

These courts were tainted:

The Honorable Carol E Huff [23] ,  The Honorable Martin Schoenfeld Esq  [24] , The Honorable Diane Alexis Lebedeff [25] 

These are the bad guys at USAA:

Robert Frances McDermott  [26] , Wilson Charles "Bill" Cooney  [27] , Charles Emerson Bishop  [28] , Norma Mendiola Gerrald  [29] , Jannie D Morse [30].

The court was so tainted by the conduct of the lawyers that the matter should be reopened.  It is not necessary that I prove “fraud” in the conventional sense:  I need only establish that the court was tainted.

Now - how does this involve you?  Here’s the problem bears on you - in a nutshell!

During the 1988/1989 heating season, you were the Douglas Elliman - Gibbons & Ives management executive for 55 Liberty Owners Corp management contract.  Is that correct? I think so.

Here is how Douglas Elliman personnel presented at the time:

Paul Gottsegen
Douglas Elliman - Gibbons & Ives
575 Madison Avenue (@ 57th)
New York, N.Y. 10022

Jack Oelberger  [31] [32]
Douglas Elliman - Gibbons & Ives
575 Madison Avenue (@ 57th)
New York, N.Y. 10022

Adjudged and admitted criminal Kessler, as you doubtless know, is dead.

Here is how we know Kessler and Oelberger were criminals:

Jack Oelberger is alive and well in California.

This is my insurance company’s June 23 1989 photograph of the damaged floor in 55 Liberty Street # 17C.

[Blue arrow is mine]
The Blue Arrow is mine and  points to the section of undamaged floor that was subject of perjury by both USAA Adjuster Grace Ward, 55 Liberty Owners Corp superintendent Robert J Phillips, and 55 Liberty Board President Elizabeth P Dominguez  [33] . Phillips and Ward perjured themselves with Robert Spadaro’s encouragement to so-called Judge Diane Lebedeff - stating that I had cut open the undamaged floor and poured water into it - or something like that.  Judge Lebedeff was dripping vaginal juices under her chair when she heard that.  I thought she was going to have a fucking orgasm.  Judge Diane Lebedeff was thrown off the Supreme Court for corruption.

As noted on June 23 1989 by my insurance syndicate’s unlicensed independent adjuster Richard J Froese the floor had been destroyed by repeated explosions of a coop corporation steam pipe located behind the walls.

The blue arrow points to an undistinguished section of floor which involves you.

In June 1989, you (personally) arranged for Douglas Elliman’s contract carpenter who worked at 55 Liberty to begin removal of the floor.

55 Liberty Owners Corp Carpenter Mark Brannon’s instructions were to cut an initial hole in the floor to determine if there was water either between the subfloor and the finished floor or on the concrete slab beneath the subfloor.

Douglas Elliman - Gibbons & Ives contract carpenter, Mark Brannon, arrived on July 28 1989 with four men:  and began the floor removal.

During May and June 1989, you and I had exchanged phone calls on the matter - and you were very solicitous and cooperative.

My insurance syndicate adjuster Richard J Froese and 55 Liberty employee and building superintendent Robert J Phillips [RIP] were supposed to be there on July 28 1989 when Douglas Elliman  - Gibbons & Ives  carpenter Mark Brannon arrived.

I had written my insurer’s adjuster  on July 27th 1989, the day before Douglas Elliman - Gibbons & Ives contract carpenter Mark Brannon’s arrival as follows:

Here is the proof of fax for that letter:

As it turned out, Mr Phillips had earlier that day been taken to the hospital in extremis and unable to be there:  so his # 2, 55 Liberty employee Joseph Pelican, was in attendance.  I did not know that Mr Phillips was ill:  and I’d not be the least bit surprised if Mr Phillips’ illness was connected to Manhattan DA Morgenthau’s unfolding discovery of his massive fraud and his taste for Jack Daniels.

As I said above:  Douglas Elliman  - Gibbons & Ives contract carpenter Mark Brannon arrived on July 28th with 3 men and a 10” circular saw and made a first finished-floor cut - about 36” square.

There were clear signs of water - the subfloor was soaked.

And then Douglas Elliman  - Gibbons & Ives contract carpenter Brannon made a second cut into the subfloor: about 24” x 12”.

As the subfloor was pulled up from the concrete slab, it was easy to see that water had ponded under the floor about ½ ” deep.

Here (below) is USAA unlicensed adjuster Richard J Froese’s August 3 1989 photograph of the cut in the floor and the black plastic bag which contained the finished floor and the subfloor which had been removed.

USAA Adjuster Photo August 3 1989

USAA insurance syndicate adjuster Mr Froese took the black bag and the the damp wood with him for USAA’s forensic analysis.

As you and I had agreed over the phone - if water was discovered - the floor removal would stop until all parties had had the chance to assess the situation.

Water was indeed discovered - right away - upon the first cut:  and the work stopped.

The next day I faxed my insurance syndicate’s adjuster Richard J Froese - at exactly 10:03 AM EDT.

Here is the proof of fax:

I also wrote you:

You never responded.

Richard J Froese, my insurance syndicate’s adjuster, did respond:

Mr Froese came on August 3 1989.

I wrote you after Mr Froese’s visit:

And you never responded.

Of course now we now know why you didn’t respond - you had been swept up in a huge criminal conspiracy - for which 55 Liberty Street superintendent Robert J Phillips was the criminal doorkeeper.

And I’d like to know, please, exactly when you left Douglas Elliman

Now we get to the more refractory  and less pleasant part of this letter:

Paul:  you have forgotten more than I will ever know about parsing out the duties and costs to restore damaged NYC apartments.

But in May - August 1989:  here is what you did know.  And I am going to hang this around your neck unless you help me now.

Paul:  you knew that the 1 ¼ ” steam pipe run-outs that were attached to nipples that were screwed into weldments on the 6” steam riser were cracking and exploding.

Paul - you also knew with absolute certainty that my family had the absolute undiluted duty to restore our apartment to its ur-condition after any sort of damage.  There was no option - as in the case of a freehold in an unincorporated area - to simply live with the damaged property.

It was our duty to restore.

Paul - you also knew that my family was 100% and inescapably responsible for all the costs of such a restoration.

Paul - you knew (because I told you) that my family was 100% indemnified for all the costs of restoring unit 1# 17C at 55 Liberty Street.

Paul - you also knew that 55 Liberty Owners Corp had run through the policy limits on its Greater New York Mutual Insurance Company (NAIC 22187) Policy # 1131M75921-S.

Paul - you knew that any claim for costs to restore paid by my insurance syndicate USAA was virtually certain to be subrogated to 55 Liberty Owners Corp.

Paul - you never told me, as you were duty bound to do - that my my duty to restore was determined neither by:

Our duty to repair was entirely independent of damage or cause.

And we were responsible for all the costs - except of course that we had full recourse to other responsible parties once the damage had been fully ascertained and the restoration was complete.

But and my family were subrogors of the power(s) to pursue 55 Liberty Owners Corp:  and my insurance syndicate USAA was the subrogee of those powers.

We were prohibited from making a claim.

The best analogy is a leased auto vs an owned auto.

If your leased auto is hit from behind by a drunken non-licensed CEO of a large corporation:  it is still your job to restore the automobile.

It matters not one hoot who’s responsible.

And the vehicle owner’s subrogee, his insurer,  pursues the responsible parties.

In your and my May-July 1989 telephone conversations, you deceived me.  And you let me and my family down.

Had you simply explained the drill back in 1989 - we’d not be in touch to today.

But you got out of Dodge to save your fucking ass from the unfolding fraud and deserted us - leaving my family high and dry.

And we got fucked - big time.

May we please return to the Douglas Elliman carpenter, Mark Brannon, and the hole in  the floor.

Here is what happened with that.

After 10 years of pre-trial absurdities, I obtained a trial on the facts before corrupt NYS Supreme Court Judge Diane Lebedeff.  What a major cunt.

At the last minute, and without the opportunity to depose him (except with further delay in scheduling the trial) - USAA’s corrupt lawyer Robert J Spadaro produced as a last minute witness - guess who?

Fucking lying drunkard and criminal 55 Liberty Superintendent Robert J Phillips [RIP].

And with USAA lawyer Robert J Spadaro’s encouragement, 55 Liberty Street Superintendent Robert J Phillips testified as follows:

That at the location of the blue arrow in the June 23rd 1989 photo I had intentionally spilled water .

And that this spilled water, which was spilled after USAA adjuster Froese’s June 23 1989 visit, had percolated through the floor leaving a damaged area 36” x 36”.

And that some time before Froese’s visit on August 3rd 1989, I had cut out the damaged floor out so as to conceal my responsibility.

USAA adjuster Grace Ward confirmed the story adding that I had been systematically uncooperative throughout the 6 years 1989 - 1995) that USAA spent adjusting the 4 separate steam pipe explosions behind the walls of #17C.

Corrupt Judge Lebedeff lapped it up, likely collected a big bribe, and was subsequently thrown off the Supreme Court for corruption.

Now - I believe that after Douglas Elliman was fired for fraud:

USAA and 55 Liberty Owners Corp. conspired to fuck my family.

But I say this to you:  if you had explained to me in any one of our numerous calls what the drill really was:  none of this would have ever happened.

And even better - if Douglas Elliman had given me a simple demand that we restore # 17C:  I am certain that everything would have gone smoothly.

[more to come]

Very truly yours,

Robert J Koenig
+ (cell, sms and mms)

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Published at:      


Paul Gottsegen
Halstead Management Company
770 Lexington Avenue
New York NY 10021

Denise Budzick

[1] Michael Seth Feuer Esq
NYS Registration Number: 2311082
(Disbarred for Federal Fraud)
Rosenbloom & Hofflich
15 Maiden Lane Suite 600
New York NY 10038

Michael Seth Feuer
27 Cambridge Drive
Jackson NJ 08527-2608k
+1.908.755.4344 (VOIP)
+1.732.656.7797 (landline)

Michael Seth Feuer
11 Old Church Road
Warren NJ 07059-5808

℅ Jerald Rosenbloom Esq
Rosenbloom & Hofflich
15 Maiden Lane Suite 600
|New York NY 10038

[2] Henry Lee Saurborn Jr Esq
NYS Registration Number: 2109825
Kaiser Saurborn & Mair PC
111 Broadway 18th Floor
New York NY 10006
fax:  +1.212.338.9088

[3] Phyllis H Weisberg Esq
NYS Registration Number: 1358274
Montgomery McCracken Walker & Rhoads LLP
(formerly Kurzman Karelsen & Frank
437 Madison Avenue, 29th Floo
New York NY 10022
fax:  +

[4] Fred L Seeman Esq
NYS Registration Number: 1912666
|32 Broadway - Suite 1214
New York NY 10004
fax:    +1.212.385.8161

[5] Daniel Ward White Esq
NYS Registration Number: 1972736
Of Counsel
Chiesa Shahinian & Giantomasi PC
11 Times Square 31st Floor
New York NY 10036-6600
fax: +1.973.530.2295

[6] Carol A Pisano Esq
NYS Registration Number:  1678333
Counsel to the Firm
McElroy Deutsch Mulvaney & Carpenter LLP
88 Pine Street 24th Floor
New York NY 10005
fax: +1.212.483.9129

[7] Alan M Goldberg Esq
Of Counsel
NYS Registration #: 1661859
Anderson Kill PC
1251 Avenue of the Americas
New York NY 10020
+ (o-direct)

[8] Aaron "Ron" Goldstein Esq
Managing Director
Legal and Claims Practice Group
Aon Financial Services Group (“FSG”)
199 Water Street
New York NY 10038
+1 212.441.1282

[9] Jonathan Jay Fink Esq
NYS Registration Number: 1551266
(registration to practice law in NYS is delinquent)
Samson Fink & Dubow LLP
10 E 40th St # 708
New York NY 10016‎

[10] James Gaither Samson Esq
NYS Registration Number: 1128701
Samson Fink & Dubow LLP
10 E 40th St # 708
New York NY 10016‎
fax:  +1.212.856.5818

[11] Neil Leslie Kanzer Esq
NYS Attorney Registration # 149735
75 Franklin Street  
Amityville NY 11701

[12] Anthony D Perri Esq
NYS Attorney Registration #:  1167055
46 Bayville Park Boulevard
Bayville NY 11709

[13] John Robert Seybert Esq
NYS Attorney Registration Number 1753938
353 Seabreeze Court
Moriches NY 11955-1739

[14] Deborah Ann Pochtar Esq
NYS Attorney Registration # 1938166
Imperial House
150 E 69th Street Apt 17C
New York NY 10021

[15] Bradford Whitman Rich Esq
[Former USAA General Counsel]
TX Bar Card Number: 24000359
2102 E Sentry Ridge Court
Tucson AZ 85718

[16] William M McCrae Esq [RIP]
TX Bar Card Number 13479500
Helen M McCrae
20 Eton Green Circle
San Antonio TX 78257 (78258?)

[17] David Arnold Woodard
2571 Rolling Creek
Spring Branch TX 78070
+1.830.885.5065 (home)
+1.210.325.0707 (cell)

[18] Deneen Lynette Donnley Esq
[Ostensibly registered in Delaware
Not registered to practice law in Texas]
Executive Vice President, General Counsel and
Corporate Secretary
United Services Automobile Association
9800 Fredericksburg Road
San Antonio TX 78288
+1.210.498.8874 (executive offices)
fax:  +1.210.498.0385

[19] Steven Alan Bennett Esq
950 North Michigan Avenue
Chicago IL 60611

[20] Kenneth W Smith Esq
TX Bar Card Number: 18635301
Senior Vice President
Corporate Finance and Governance Counsel
United Services Automobile Associatio
9800 Fredericksburg Roa
San Antonio TX 78288

Kenneth W Smith
Loretta L Smith
203 Chattington Court
San Antonio TX 78213

[21] Steven Alan Bennett Esq
950 North Michigan Avenue
Chicago IL 60611

[22] George Edward Joy Esq
Bar Card Number: 11034600
134 Lakeview Drive
Boerne TX 78006

104 Krieg Drive
Boerne TX 78006

[23] 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

[24] The Honorable Martin Schoenfeld Esq
NY Registration #: 1121649
457 FDR Drive APT 2104
New York NY 10002

[25] The Honorable Diane Alexis Lebedeff
NYS Registration Number: 1292119
2623 Seville Boulevard # 201
Clearwater FL 33764

[26] Robert Frances McDermott
c/o Robert F McDermott [Jr] Esq
Of Counsel
Jones Day
51 Louisiana Avenue NW
Washington DC 20001-2113
+1.202.879.3875 (o-direct)
fax: +1.202.626.1700

[27] Wilson Charles "Bill" Cooney
[Wilson C Cooney Company]
29350 Grand Coteau Drive
Boerne TX 78015-4507
+1.830.981.8581 (home)
+1.210.568.3596 (office)
+1.210.859.1495 (cell)

[28] Charles Emerson Bishop
Patricia Ann Bishop
29626 Double Eagle Circle
Fair Oaks Ranch TX  78015

Charles E Bishop
Patch Port
PO Box 293
26 Tennis Club Road
Northeast Harbor ME 04662

[29] Norma Mendiola Gerrald
[Everett Lee Gerrald]
8803 Terra Cliff
San Antonio TX 78255

[30] Jannie D Morse
Northeast and Overseas Region
United Services Automobile Association
9800 Fredericksburg Road
San Antonio TX 78288

Jannie D Morse
aka Jannie Mobley Morse
aka Jannie Mobley
13814 Hunters Hawk Street
San Antonio TX 78230
+1.210.415.5835 (cell)

[31] This is of course Jack Oelberger, your direct underling, who was jailed for criminal fraud for soliciting and collecting bribes to admit contractors to 55 Liberty Street.

[32] Richard "Jack" A Oelberger
Irene Oelberger
Courtney Oelberger
5845 Doverwood Dr Unit 101
Culver City CA 90230

[33] Elizabeth P Dominguez
55 Liberty Owners Corp.
c/o J C Klein Inc
3 Hanover Square - Suite 15G
New York NY 10004

Elizabeth P Dominguez
c/o Nestor D Dominguez
Managing Member
KMN Capital Management LLC
17 Bergen Street PH
Brooklyn NY 11201