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Koenig to Joseph Pell Lombardi
July 12 2018 1643 GMT

Started June 01 2018

Joseph Pell Lombardi
Joseph Pell Lombardi & Associates
412 Broadway 4th floor
New York NY 10013

Joseph I Rosenzweig Esq
225 Broadway - 38th floor
New York NY 10007-3001

RE: INDEX # 002371/1991 and INDEX #  103754/1995

Dear Mr Lombardi:

I can’t find Mr Rosenzweig who may be on Jamaica (the island).  If you have a new attorney - please let me know.

I am going to cover a lot of bases in this letter.

I believe that the carrier for 55 Liberty Owners Corp’s Multi-Peril Coop Policy # 1131M75921-S [1] was the subrogee of 55 Liberty Owners Corp’s rights to recover from you the cooperative corporation’s costs in connection with my insurer’s  [2] subrogated claim to 55 Liberty Owners Corp.

I also believe that you were instrumental in the selection of Daniel Ward White Esq to represent the 55 Liberty Board of Directors: and that Daniel Ward White Esq may have improperly acted so as to mitigate your exposure.  Daniel Ward White Esq and 55 Liberty Street Owners Corp should have joined you as you were a necessary party: and Daniel Ward White Esq and 55 Liberty Street Owners Corp should have maintained that joinder.

I also believe that you importuned 55 Liberty superintendent Robert J Phillips to commit serial perjury as to the true origins of the five several and documented steam riser runout explosions that afflicted # 17C.

I believe that a relationship I believe you have with Daniel Ward White Esq should be disclosed to the court: today.

I believe that a relationship I believe you had with Robert J Phillips should have been earlier disclosed to the court and should be disclosed today.

I believe that Mr Rosenzweig’s failure to make a clean breast of these possible conflicts of interest was classic extrinsic fraud upon the court.

Request for Admissions:

  1. That you know Daniel Ward White Esq: extra to Chubb’s agreement to represent the 55 Liberty Board of Directors.
  2. That you surreptitiously proposed Daniel Ward White Esq to represent 55 Liberty Owner’s Corp.
  3. That you knew Robert J Phillips [RIP] extra to the context of Robert J Phillips’ employment by 55 Liberty Street.
  4. That the damage to # 17C was extensive and consistent with this secret undated USAA adjustment:

  1. That 55 Liberty’s 32-story steam risers flexed 3” or more: which you failed to reflect in your design for the same floor steam riser runouts.

  1. That the cause of the extensive damage to # 17C was your liegeman Robert J Phillips’ failure to install this fitting:

May I please make arrangements to depose you in the matter of these and some open questions.

I wish to learn more about:

  1. The history of your relationship with Robert J Phillips;
  2. How Robert J Phillips came to work at 55 Liberty.
  3. How Daniel Ward White Esq came to be retained to defend 55 Liberty Street.

To close: a housekeeping note:  This reports to you that your Verified Answer [Exhibit “A”] was never verified.  Please verify your answer and file it with court and serve me with a copy.

Very truly yours,

Robert J Koenig
+ (cell)

Exhibit “A”:  Lombardi’s Verified Answer that was never verified.

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[1] Harold Glauberman
Vice President
Greater New York Mutual Insurance Company
[GNY Insurance Companies]
Greater New York Mutual Insurance Company
200 Madison Avenue - 3rd Floor
New York NY 10016
fax:  +1.212.532.8018
NAIC 22187
55 Liberty Owners Corporation Multi-Peril Policy # 1131M75921-S

[2] United Services Automobile Association; NAIC # 25941; FEIN  74-0959140; TDI Company Number 14-86800; Current TDI Certificate of Authority  [CofA]  # 14585 granted on April 2 2008: an unincorporated insurance syndicate organized as a Texas reciprocal inter-insurance exchange.

Unlawfully commenced inter-insuring by receipt of a syndicate name's deposit against a reciprocal contract on either June 20 or June 22 1922. First one year license (expired February 28 1926) to commence inter-insuring by reciprocal contract granted on or slightly before March 23 1925 (two and nine years after USAA's unlawful 1922 "receipt of a first deposit from a "syndicate name".