Page of pages
Report on Alan M Goldberg Esq
July 11 2018 1415 GMT
Started May 1 2018
To be read in conjunction with:
9 years of sloth in The Honorable Carol E Huff’s courtroom now metamorphoses into a corrupt rocket justice in The Honorable Martin Schoenfeld’s courtroom.
Alan M Goldberg Esq, whose willful blindness as to the true facts enabled him to blissfully lie, uses:
A Pretense to being indemnified:
A child can appreciate that a party who is fully insured is likely to be more believable than an uninsured party.
In essence, Daniel Ward White Esq feigns the quiescent indifference of the fully insured party while at the same time hinting to the court that the tenant’s frantic antics are those of a frivolous uninsured.
The truth seems to be quite the opposite.
55 Liberty Owners Corp is not insured. I have the original Daniel Ward White Esq insurance policy production which avers that 55 Liberty Owners Corp is insured.
Question: Does Daniel Ward White Esq’s misleadingly offering insurance policies rise to the level of perjury?
Question: Is Daniel Ward White Esq’s misleading the court as to who was insured and who was not insured extrinsic fraud upon the court?
Put another way:
The Honorable Martin Schoenfeld has before him a beseechingly simply case: a standard cookie-cutter 2nd/3rd party insurance matter - with two self-evident parties and their insurers:
As The Honorable Martin Schoenfeld after many years of divorce court knows full well, 2nd/3rd party insurance matter resemble the 8 slice/3 cut cake riddle:
The third slice takes place in a different plane.
Ordinarily (and The Honorable Martin Schoenfeld knows this full well):
The extrinsic facts test should have produced a tenant defended by his insurer against landlord’s split actions and landlord’s wild accusations:
Once the Koenig family is defended and indemnified, the matter then proceeds to USAA’s subrogated claim against the landlord’s multi-peril carrier.
I, the fully insured plaintiff, ask The Honorable Martin Schoenfeld’s court this question.
Irregardless (if I were writing to an honest intelligent judge,I’d say ”regardless”) of tort(s):
Who is the first payor of the $25,000 of costs and the loss-of-use for the damages caused # 17C?
300 pages of neatly-typed Alan M Goldberg and Daniel Ward White gobbledygook cum swooning do not change the outcome of that question.
The black-letter cookie-cutter proprietary lease (the equivalent of law), all precedent, all state statutes and codes, common law, and (entirely lacking in Judge Schoenfeld’s corrupt courtroom) common sense inform us that the Koenig family was the first payor.
Now - this is what The Honorable New York State Supreme Court Justice Martin Schoenfeld also knows.
The Honorable New York State Supreme Court Justice Martin Schoenfeld serves or has certainly served on his own cooperative housing corporation’s board of directors and I am prepared to wager that The Honorable New York State Supreme Court Justice Martin Schoenfeld scienter as to the ins-and-outs of property damage claims in NYS cooperative housing corporations borders on that of a Talmudic scholar’s mastery of that other subject material: so give me a fucking break.
I, the tenant, have joined my cooperative housing corporation and my insurer to an action which can actually ask for no more than this declaratory judgement:
The Koenig family pays.
It would be just, nice, elegant, terribly wonderful and enlightening, and fucking Talmudic if The Honorable New York State Supreme Court Justice Martin Schoenfeld would then go on to order as follows:
The adjusters for the two insurers shall parlay and fucking adjust the claim without respect to the status of the insurance policies which are in effect.
Unless coming across as a major Jüdischer Ordnungsdienst member is his objective:
The Honorable New York State Supreme Court Justice Martin Schoenfeld could then ask the parties to report back to him in four weeks any dispute as to the indemnification supplied by the insurers.
Lurking on back stage there is yet a 4th party that The Honorable New York State Supreme Court Justice Martin Schoenfeld should account for:
Lombardi is joined to the action by me under a different theory. But if one reads back - 55 Liberty Owners Corp makes its own claim against Lombardi.
Apparently, according to the county clerk files, Lombardi never furnished a verified answer to any complaint: in which case the complaint is alive and well. Thus: for having failed to furnish a verified answer - Lombardi is in.
Question: Why does Daniel Ward White Esq permit defendant Joseph Pell Lombardi to skip filing a verified answer?
Here is the point:
A good faith responsible tenant insurer [USAA] wants 55 Liberty Owners Corp’s joinder maintained in force;
A good faith responsible landlord insurer [Greater NY Mutual] wants Lombardi’s joinder maintained in force.
And the Honorable New York State Supreme Court Justice Martin Schoenfeld’s bench must satisfy itself that there is no subrogor/subrogee funny business going on.
In that regard, I ask The Honorable New York State Supreme Court Justice Martin Schoenfeld to refer to the NYS Insurance Division organic criminal investigation team the question as to whether tenant’s insurer and landlord’s insurer ever communicated.
And if tenant’s insurer and landlord’s insurer dod communicate; is there a conspiracy to tortiously interfere with the standard industry practice of leaving to the adjusters the first two cuts.
I also ask The Honorable New York State Supreme Court Justice Martin Schoenfeld to refer to the 1st Appellate Division, as a matter of extrinsic fraud upon his own court:
How did Daniel W White Esq come to be selected by Chubb Insurance Company to act for 55 Liberty when there is possibility that Daniel W White Esq and Joseph Pell Lombardi are intimately connected.
Robert J Koenig
Exhibit “_”: 55 Liberty’s Memorandum of Law in Opposition to Koenig’s Motion to renew, amend, commence a new action, and consolidate (Return Date 4/29/97)
Needs something like:
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Exhibit “_”: Alan M Goldberg’s April 23 1999 Defendant 55 Liberty’s Memorandum of Law in Opposition to Plaintiff’s Motion
Exhibit “_”: Alan M Goldberg’s August 6 1999 Notice of Motion and August 6 1999 Memorandum of Law
Notice of Motion and Affidavit
Alan M Goldberg Esq’s Memorandum of Law
Exhibit “_”: Alan M Goldberg’s August 27 1999 Memorandum of Law in Opposition (19 pages total): filed January 7, 2000
Exhibit “_”: Joseph Kuroly’s August 27 1999 Affidavit in Opposition
Exhibit “_”: Alan M Goldberg’s September 4 1999 letter to The Honorable Martin Schoenfeld
Exhibit “_”: Koenig September 20 1999 letter to The Honorable Martin Schoenfeld
Exhibit “_”: Daniel Ward White Esq’s September 10 1999 Supplemental Affidavit
Exhibit “_”: The Honorable Martin Schoenfeld’s January 3 2000 order filed January 7 2000
Deep background on Alan M Goldberg
Exhibit”_”: Background and search for Alan M Goldberg
Alan M Goldberg