of
Recapture of Carol Ann Pisano perjury
and Fraud upon the Court (as a body)
January 23 2018 1713 GMT
 

January 23 2018 1713 GMT

Below (see my letter to the First Department), we can now see the dark matter that was missing from the corrupt big-bang universe that:

Paul R Gottsegen
Executive Asset and Acquisitions Manager Canada & US
Time Equities
55 Fifth Avenue 15th Floor
New York NY 10003-4398
+1.212.206.6000
fax: +1.212.727.0563
dbudzick@halstead.com

spawned in November of 1989 when he criminally failed to process the Koenig family’s duty to repair the steampipe damage in an orderly manner.

So Gottesman fucked up: at the time he was probably occupied turning state’s witness in what came to be known as the great Coop Pay-to-Play Fraud.  I am no choirboy.  But in Gottesman’s place - I’d man up.


Carol Ann Pisano as forgotten more about coop law and the duty of coop tenants than I will ever know.

But in 1996, Carol Ann Pisano knew that 55 Liberty Owners Corp did not have in place the requisite insurance to meet the subrogated claim of my family’s insurance syndicate.

And Carol Ann Pisano that the steam pipe explosion  that spread the asbestos and destroyed the apartment flowed from the criminal negligence of building superintendent Robert J Phillips when he surreptitiously repaired a previously exploded steam riser branch runout in December 1986 and contumaciously failed to replace the exploded steam pipe with this fitting:

Flexonics 100 fitting which superintendent Robert J Phillips was order to install.

But it gets worse.

  1. Carol Ann Pisano knew that I knew that I was 100% responsible to repair all damage to 55 Liberty Street # 17C regardless of souce or responsibility.
  2. Carol Ann Pisano knew that my family had purchased and paid the syndicate name deposits for the exactly correct indemnification contract from our unincorporated reciprocal interinsurance exchange  [1] [Exhibit “_”]
  3. Carol Ann Pisano knew that the limits of liability were entirely consistent with the damage.
  4. Carol Ann Pisano knew that 55 Liberty Owners Corp did not have in place the proper limits of liability for steam and water damage under Greater New York Mutual Insurance Company NAIC 22187 Policy # 1131M75921-S.
  5. Carol Ann Pisano knew that my family’s insurance syndicate had ascertained that they would not be able to subrogate their costs to Greater New York Mutual Insurance Company NAIC 22187 Policy # 1131M75921-S; but rather would have to commence an action as the subrogee to my family as subrogors of the Koenig family rights vs 55 Liberty Owner Corp’s as a criminally negligent landlord. [this is not well said - and needs work - which will get in due course]
  6. Carol Ann Pisano [and this goes on and on   .   .   is there some point ?]


Robert J. Koenig
115 Cove Neck Road
Oyster Bay, NY 11771-1822
516 624 9153
516 624 9236

koenig@ibm.net

Thursday, July 11, 1996 2:32 PM

Mady J Edelstein Esq
Registration Number:        1622042
Attorney of the Day
1st Department Departmental Disciplinary Committee
Supreme Court - Appellate Division
41 Madison Avenue - 39th
New York
 NY 10010

212 685 1000

212 545 8981

Dear Ms. Edelstein:

This is a question for the Attorney of the Day.  My name is Koenig and I am a pro se party to the three captioned items, below.

(continued on next page .  .  .  )


SUPREME COURT OF THE STATE OF NEW YORK
|
COUNTY OF NEW YORK  IAS PART 32

ROBERT J. KOENIG & ALICE H. HALL
        Plaintiffs,

        vs.

55 LIBERTY OWNERS CORP., JOSEPH PELL LOMBARDI and ATTORNEY GENERAL OF THE STATE OF NEW YORK,
        Defendants

)

)

)

)

)

)

55 LIBERTY IS REPRESENTED BY LAMBERT WEISS & PISANO IN THIS ACTION

INDEX # 2371/91

ACTION # 1
(Commenced October 2,
1990)

55 LIBERTY OWNERS CORP.
        Petitioner - Landlord

        vs.

ROBERT J. KOENIG & ALICE H. HALL
and “JOHN DOE” and “JANE DOE”,
        Defendants

)

)

)

)

)

)

)

55 LIBERTY IS REPRESENTED BY FRED SEEMAN ESQ. IN THIS ACTION

L&T INDEX # 114517/90

ACTION # 2 (commenced November 20, 1990, which is being tried jointly rather than fully consolidated)

ROBERT J. KOENIG & ALICE H. HALL
        Plaintiffs,

        vs.

UNITED SERVICES AUTOMOBILE ASSOCIATION
        Defendant

)

)

)

)

)

INDEX #  103754/95

ACTION # 3 (commenced in February 1995, and which is being tried jointly with Action # 1)


Caption for the Three Cases

I want to know if Lambert Weiss & Pisano may make uninvited appearances in Action # 2 representing their client when 55 Liberty is being represented in Action # 2 by Fred Seeman, Esq.?  Mr. Seeman is the third attorney to represent 55 Liberty in Action # 2.

Part of the problem here is that there may have been a splitting of a cause of action when Action # 2 Plaintiff’s first attorney commenced the action in 1990.  This is because the L&T Complaint went far beyond L&T’s jurisdiction, which is essentially a court of Equitable Jurisdiction over the possession of apartments.  L&T may not consider Breach of Contract or Torts.  My previous attorney may have compounded 55 Liberty’s original error by stating certain counterclaims in my Verified Answer to the original L&T Complaint (Action # 2):  this is at least the reasoning voiced by Fred Seeman, who says that it is O.K. for Action # 1 Attorneys to be making appearances in Action # 2 as if they were the attorneys of record.  The situation was further worsened when my first attorney moved to consolidate the L&T Action into the Supreme Court Action.

The Honorable Carol E. Huff (JSC) seems to have rectified the situation by “unconsolidating” Action # 1 and Action # 2, and setting Action # 2 to be tried jointly.  Thus Action # 2 is a completely independant matter.

Now that they are being tried jointly, the next order of business is a Referee Hearing to determine various jurisdictional matters.  I do not understand why Action # 1 attorneys seem to handling the bulk of the work on Action # 2 matters.

And if you think it is confusing for me, you should try talking to them.  Action # 1 attorneys, Lambert Weiss & Pisano are in essence representing 55 Liberty Street at the behest of the building’s E&O Carrier (Board of Director Liabilities).  They apparently have an unlimited budget as the breech of contract  and tort issues are indeed weighty.

Obviously, Lambert Weiss & Pisano are interested in the matter of Action # 2, and they may observe whatever public proceedings there are to be observed.  But I’m not sure that this interest permits them to act as if they a representing a party to the matter.  But it is impossible to get a straight answer out of either Lambert Weiss & Pisano or Fred Seeman as to who is doing what:  and that seems just plain unconscionable.  And I do not believe that this confusion flows from malice of forethought;  it seems to be genuine confusion.  I believe I am entitled to know which attorney to deal with if I am to be able to defend myself in Action # 2.

It is an ironic twist that the jurisdictional issues being heard by the referee flow from an default judgment obtained by yet a second attorney in Action # 2 who had never even identified himself as being an attorney of record in the matter.  When I spoke in May to the first Action # 2 attorney (Michael Feuer - who originally filed the L&T Action), he told me that he considered himself to still be the attorney of record;  and he is “two attorneys ago”.

May I please receive guidance from your office as to how I should deal with this?

Sincerely,

Robert J. Koenig

These are the names and addresses of the attorneys:

Attorneys for other parties

'

7

Action # 11

Daniel W. White, Esq. & Carol A. Pisano, Esq.
Lambert Weiss & Pisano
61 Broadway - Suite 2020
New York, NY  10006-2802

212 344 3100

212 422 4047

Action # 1

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

212 285 4904

212 732 0198

Action # 2

Fred L. Seeman, Esq.
170 Broadway - Suite # 410
New York, NY 10038-4154

212 608 5000

212 385 8161

Action # 3

Robert M. Spadaro, Esq.
Spadaro and Petrocelli
217 Broadway - # 606
New York, NY  10007-2909

212 608 3550

212 608 4827


Robert J. Koenig
115 Cove Neck Road
Oyster Bay, NY 11771
516/624-9153
Fax:  516/624-9236

Internet:  koenig@ibm.net

Friday, December 08, 1995 5:56 AM (sent?)

Marvin G. Pickholz
Camhy Karlinsky & Stein LLP
1740 Broadway - 16th floor
New York, NY 10019-4315

212 977 6600

212 977 8389

Dear Mr. Pickholz:

It is with extreme disappointment that I enclose the following complaint about your client, Carol Pisano.

This is a draft and goes forward after you have had a chance to comment.  Lacking a response from you by COB Thursday, it goes forward Friday morning.

I also report with deep frustration that your client, Ms. Pisano, has further perjured herself by placing with the court copies of various papers which are plainly incorrect.  I think that she should correct her mistake before it becomes an issue.

I also wish to add that if I detect Mr. White, her associate, following me around Long Island as he was doing on Saturday morning December 2, 1995, I shall swear out a complaint in Nassau County Criminal Court.

We have a trial to prepare for:  your client has a great deal of work to do to get ready, as do I.  It would behoove us to git with the gittin and to prepare for trial.

Yours faithfully,

Robert J. Koenig

Encl:

PS        The Time-Line follows by separate fax.


Robert J. Koenig
115 Cove Neck Road
Oyster Bay, NY 11771
516/624-9153
Fax:  516/624-9236

Internet:  koenig@ibm.net

draft

1st Department Departmental Disciplinary Committee
Supreme Court - Appellate Division
41 Madison Avenue
New York, NY 10010

212 685 1000

Dear Sirs:

This is to file a complaint with the Supreme Court Appellate Division about the outrageous s conduct of a NYC lawyer:

name

phone

fax

Carol Pisano
Partner
Lambert, Weiss & Pisano
61 Broadway
New York, NY  10006

212 344 3100

212 422 4047

Statements recently uttered by Lawyer Pisano go far far beyond enthusiastic advocacy of her client’s interests, and clearly enter the treacherous domain of perjury and palpable untruths.  Lawyer Pisano’s statements are inclusively and exhaustively untrue;  in fact, nothing she says is true.  The issues which are to be determined in the court action we are involved in are clear and well understood by all parties.  All that is needed is for Lawyer Pisano to prepare for trial in an honest, truthful, and forthright manner.

As I am now pro se until I can find another attorney, and as Lawyer Pisano’s 6-years of fancy-footwork and delay has exhausted most of my assets, I reject her apparent view that my temporary pro se status is a special hunting permit for her to engage in illegal and unethical activities.

This letter is part of a new intensive effort on my part to stop Lawyer Pisano from conducting herself in an illegal manner just because I may not quite fast enough to detect and counter her illegal and unethical conduct.

It is lawyer Pisano’s clear and manifest purpose to bypass proper discovery and motion procedures, and to introduce a steady flow of incorrect and untrue information about my actions and intent so as to disguise her complete unwillingness to prepare for trial..  She is painting the record in an illegal and unethical manner.


Here are faithfully recorded instances of Lawyer Pisano’s blatant misconduct and various public utterances and publications of perjury and untruths:

What Lawyer Pisano said and did:

Why this was wrong::

On the morning of December 1, 1995, at approximately 9:15 AM, Lawyer Pisano, who is a partner at her law firm, and an associate Daniel W, White, did purposefully engage me in an abusive conversation and complete unethical conversation.  In that completely untoward and improper contact, they virtually shouted at me in full public view in the middle of a corridor full of other parties.  And they voiced a systematic series statements to the effect that I was dishonest and was abusing the judicial process,  etc. etc.

At the very moment Lawyer Pisano and her associate, Daniel W. White were shouting at me, all activity in all matters before the Supreme Court had been stayed.  At the very same moment that all matters had been stayed, Lawyer Pisano and Lawyer White were shouting at me in an open corridor of the halls of court.

Lawyer Pisano and Lawyer White, as officers of the court, had a compelling and comprehensive responsibility to observe the court order which was in effect at the time.

Lawyer Pisano palpably, wittingly, willingly, did violate this court order which stayed al proceedings in front of an entire room-full of people..

After shouting at me in the corridors, Lawyer Pisano then went on to utter a systematic series of bold-faced lies to the judge.

What Lawyer Pisano said:

The Truth:

In her statement to the court on December 1, 1995, lawyer Pisano stated that numerous settlements had been arrive at between the parties, and that I had reneged on all of them.

Lawyer Pisano knows full well that she and her clients have never made one single offer in settlement of our dispute.

And I challenge her to produce some evidence that she or her client have made an offer of settlement.

Only one offer was ever agreed to by the parties:  and that offer was the one expressed in R J. Koenig’s confirming letter to Henry L. Saurborn, Esq., dated 31 May 1994 @ 03:40 PM (attached as Appendix A).  Although that offer was described at the time by Mr. Saurborn as being completely acceptable, it is my understanding, upon information and belief, that 55 Liberty Owners Corp. “house counsel” quashed my offer with a statement to William Simon, my attorney at the time, that Mr. Saurborn “had exceeded his authority”.  No more was ever heard about my written confirmation of Mr. Saurborn’s  and my negotiations of term to a settlement.

Lawyer Pisano then uttered another completely bold-faced lie to the court:

What Lawyer Pisano said:

The Truth:

In her statement to the court on December 1, 1995, lawyer Pisano offered into evidence a photograph of a rectangular hole cut through two levels of flooring at 55 Liberty Street- # 17C, NYC.  Lawyer Pisano then represented that the cut hole in the floor was the only damage, and trivial damage at that.

The rectangular hole depicted in Ms. Pisano’s photograph was an opening cut by a contractor named Mark Brannon on August  (see attached Time Line).  Lawyer Pisano knows this hole was cut as a result of negotiations conducted by me between Mr. Gottsegen of Douglas Elliman and Mr. Froese, an adjuster for the USAA Insurance Company.  By plan and by the agreement of all parties, the hole was cut in a relatively undamaged section of the floor so as to determine the extent of the flow of water beneath the floor.

The fact is that other photographs and documentary evidence in Lawyer Pisano’s posession accurately depict the devestation which has resulted from three separate high-pressure steam pipe explosions in my apartment at 55 Liberty Street.

After leaving court that day, Lawyer Pisano then engaged in an egregious example of barratry and legal maneuvering.  In a private ex parte motion, achieved I assume by asserting a need for judicial discretion, Ms. Pisano evidently prosecuted a highly specious and defective argument laden with false ascertains, untrue and false facts, and insinuations designed to create incorrect inferences.  And finally, in her draft for an order to show cause and her supporting affidavit, Lawyer Pisano systematically perjured herself.

In her Affidavit dated and sworn to on the 1 December 1995 (which was later on the same day of the hearing, above) Lawyer Pisano published the following palpable lie:  It is important to understand that although Lawyer Pisano published this affidavit on December 1st, and although she evidently met with the court shortly thereafter (the date on my copy of the order is been blurred), I never received a copy of the Order to Show Cause until Thursday, December 6th, 5 full days later, and less than 22 hours before the hearing.  This was in spite of the fact that Lawyer Pisano knows my fax number and knows very well how to get in touch with me.


This is an exact photographic copy of what Lawyer Pisano wrote:

Lawyer Pisano’s deceit (item by item in the above example of per gratuitous lies):

The truth:

i.  Lawyer Pisano, knowing full well that there would be a strong chance that the I would miss the hearing since she had noticed me only 22 hours earlier, was hoping to take advantage of my absence to create an appearance on my part of disrespect for the court.  Had she succeeed, she doubtless would have lied to the court and by saying that I had been noticed within the time frame envisioned by the Order to Show Cause, i.e. not later than 6 December 1995.

i.  The suggestion here that I deceived the court is a palpable lie:  and Lawyer Pisano should be sanctioned for even making the suggestion.

I am very anxious to proceed immediately to trial and all that is needed at this point is for the partis to agree to the vacating of the default judgement which is the sole source of delay at this point.

ii.  Lawyer Pisano, knowing that I would probably not be present since she had delayed sending me a copy of the Order to Show Cause until 22 hours before the hearing, was seeking to create the impression that I had given her those papers with the willful intend to disregard a court order in the matter.

The relief sought in Lawyer’s Pisano motion for an Order to Show Cause is so vague that her only real intent was to take up the court’s valuable time in attempting to create, in what was likely to be an ex parte hearing, an appearance of disrespect for her court’s order.

ii.  The “requests for discovery” which Lawyer Pisano refers to were given to her at about 9:10 AM, on the morning of 1 December 1995:  which was at least one hour before the hearing in which a stay extant at the time was to be extended for 30 days.  I certainly had no idea that the stay was to be extended.  I had given the papers to Lawyer Pisano with the concomitant statement that they were information copies and that no action was required.  The provision of these papers to Lawyer Pisano was actually a manifest effort on my part to cooperate fully with her often expressed need to prepare for a speedy trial.  Since no time frame was expressed in the informal documents I gave Lawyer Pisano, it is clear that she was blowing spiteful and prejudicial hot air in her affidavit to the court.

iii.  Lawyer Pisano is attempting to aver that a 30-day delay in re-submitting for a referees hearing is somehow more damaging than her own 6-years of dawdling,  filibustering, and procrastinating.

iii.  The enclosed time-line (attached as Appendix B) is clear evidence that over 6 years, Lawyer Pisano has done absolutely nothing about preparing for trial.

In her affidavit, Lawyer Pisano further perjures herself by writing

Lawyer Pisano’s further deceit:

The truth:

Lawyer Pisano, knowing  that I would probably not be appearing as she had noticed me only 22 hours before the hearing (when she knew I would probably be away on a business trip) was attempting to create an incorrect impression that I had willfully violated a court order, and then not shown up in court to defend myself.

On 1 December 1995, between 9:15 AM and 10:15 AM, I personally observed Lawyer Pisano studiously pouring over the documents I had given her at least one hour before the hearing before the judge.  Lawyer Pisano had every chance to determine the substantive nature of the documents, and to see that they were only informational and intended to convey my plans once preparation for trial began anew.

Lawyer Pisano should be severely sanctioned for attempting to portray my efforts to cooperate with her as an attempt to violate a court order.

Lawyer Pisano should also be sanctioned for constructively with-holding a copy of the Order to Show Cause beyond the December 6th date laid out in the court order.

In her affidavit, Lawyer Pisano further perjures herself by stating:

Lawyer Pisano has once again engaged in willful professional misconduct:

What Lawyer Pisano should have done:

Lawyer Pisano willfully delayed service of papers beyond the December 6th deadline specified in Justice Huff’s order dated December 5, 1995.  The papers were not served until 10:49 AM, December 7th, by FEDEX.

By delaying notice until the last possible moment, Lawyer Pisano sought to unfairly prejudice my case by setting in place circumstances which would have caused me to miss the hearing, which was likely since I travel extensively on business.

Justice Huff’s Order to Show Cause clearly gave December 6, 1995 (actually, on or before December 6th) as the last day to provide notice of the hearing.

Lawyer Pisano had both my fax number, which was operating at the time, and my phone number.

Lawyer Pisano should have faxed me a copy of the Order to Show Cause at the first opportunity, which was apparently December 4th.

Lawyer Pisano, given the apparent urgency she imparted to the matter by her frenzied and unethical conduct, should have also FEDEX’d me a copy of the Order to Show Cause no later than December 5th, so as I could have received it no later than December 6th.

Lawyer Pisano should be sanctioned for this outrageous and probably illegal conduct.

And last but not least, Lawyer Pisano’s own request for an Order to Show Cause contained the following agenda for providing me with sufficient notice about the December 8th hearing she had managed to obtain through barratry and deceit:

I attach a copy of the date of the order so as to show that the actual date of the signing of the order is illegible on my copy.

(I have applied state-of-the-art technology to the original copy of the court order which was provided to me to enhance and resolve the above illegible date.  It was not possible to make the date readable.)


What do the actual and extremely delayed FEDEX delivery date and the unreadable date of the judges signature indicate?

Lawyer Pisano once again engaged in willful professional misconduct:

What Lawyer Pisano should have done:

It is clear that Lawyer Pisano willfully delayed service of papers beyond the December 6th deadline specified in Justice Huff’s order (date blurred on my copy).  The papers were not served until 10:00 AM, December 7th, by FEDEX.

By delaying notice until the last possible moment, Lawyer Pisano sought to unfairly prejudice my case setting in place circumstances which would have caused me to miss the hearing, which was likely since I travel extensively on business.

Justice Huff’s Order to Show Cause clearly gave December 6, 1995 (on or before December 6th) as the last day to provide notice of the hearing.  The order provided for notice by fax or by FEDEX.

Lawyer Pisano had both my fax number, which was operating at the time, and my phone number.

Lawyer Pisano should have faxed me a copy of the Order to Show Cause at her first opportunity, which was apparently December 4th.

Lawyer Pisano, given the apparent urgency she imparted to the matter by her frenzied and unethical conduct, should have also FEDEX’d me (placed on board FEDEX) a copy of the Order to Show Cause no later than December 5th, so as I could have received it no later than December 6th.

Federal Express Corporation advises me that Lawyer Pisano turned the package over the FEDEX on Airbill # 7055769626 at 5:15 PM on 6 December 1995.  This  could hardly be said to be complying with her obligations under the court order.

Lawyer Pisano should be sanctioned for this outrageous, blatant, and illegal attempt to deny me the notice contemplated in Justice Huff’s order.

Lawyer Pisano then capped her incredibly abusive conduct at the actual hearing by submitting papers as follows:

What Lawyer Pisano did:

What Lawyer Pisano should have done::

In her statement to the court on December 7, 1995, lawyer Pisano submitted and placed into the judges files a whole raft of papers that I had never seen and which I have never seen since. I was not given a chance to inspect these papers, and I have never been given copies of them.  Thus, Lawyer Pisano is willfully attempting to deny me justice.

I should have been given a chance to inspect the papers she submitted to the cout:  and I should have received copies of whatever papers she submitted to the court.

Finally, the below example of Lawyer Pisano’s publications on this matter serve as further proof that her intent is to abuse and to violate the court order herself.

Lawyer Pisano intentionally mis-characterized what was at worst a simple error on my part to express courtesy towards her by advising her as to the type of information I would require in my discovery efforts, and she mis-described it to Œ to obtain a completely unnecessary private ex parte hearing with the judge, and then  to engineer an open hearing about which I was likely never to receive notice, and then Ž to place on the record a whole series of untrue and largely perjured statements without my ever having a chance to review or correct them.

Here are more examples of the blatant untruths Lawyer Pisano published on 1 December 1995..

More lies from Lawyer Pisano:

The Truth:

Lawyer Pisano suggests that “I seek a delay”.  The enclosed time-line clearly demonstrates that Lawyer Pisano, who represents the Errors and Omissions Insurance Carrier for the Board of Directors which is responsible for this whole mess, is the party who has been dragging its heels.

All delays over 6 years since the steam pipes first exploded and through the 2nd and 3rd explosions in my apartment have been at the hands of Lawyer Pisano and the other attorneys representing the owner of the apartment building.

I am terribly anxious to get this matter in front of a jury so that the issue of responsibility and damages can be resolved.

Lawyer Pisano then goes on to make this completely outrageous, gratuitous, and patently unsupported statement about my attitude:

Lawyer Pisano now bores us with her lies:

The Truth:

This is just plain simple libel.

I have only cooperated fully in this entire matter.

The only party to truly engage in systematic contempt for the court and he justice system is Lawyer Pisano, herself.

Summary:

It bears pointing out that Lawyer Pisano initiated all of this in her initial affidavit signed and sworn to on 1 December 1995.  Her actions were unprovoked, and seem to indicate an intent to take advantage of my temporary pro se status more than to further any legitimate interest her client might have in this matter.

I request sanctions against Lawyer Pisano;  specifically, I ask that she be disbarred, and that she be assessed a fine of $100,000.

Yours faithfully,

Robert J. Koenig

Encl.:

Appendix A:        Record of correspondence to Henry L. Saurborn.
Appendix B:        Time Line

cc:

Marvin G. Pickholz
Camhy Karlinsky & Stein LLP
1740 Broadway - 16th floor
New York, NY 10019-4315

212 977 6600
212 977 8389


R. Julian Koenig
115 Cove Neck Road
Oyster Bay, NY 11771

 516/624-9153
516/624-9236

31 May 1994 03:40 PM

Henry L. Saurborn, Jr., Esq.
Kurtzman Karelson & Frank
230 Park Avenue
New York, NY 10169

212/867-9500

212/599-1759

Dear Mr. Saurborn

This is to confirm our understanding arrived at in this afternoon’s conversation.

I am prepared to pay over to the building all capital assessments, which are about $48,000.

I am prepared to resume occupancy immediately after your adjuster meets with mine, or after the building’s portion of the repairs (as determined by any joint decision of the adjusters) is finished, which ever is later.

I am prepared to agree not to declare bankruptcy.

I am prepared to submit the portion of the dispute not settled by the insurance adjusters to binding arbitration (ADR);  this will require my insurance company’s approval.

The quid pro quo of this is:

You agree to cease collection efforts.

You agree to be bound by the decision of the insurance adjusters if they jointly agree that the sub-floor and final top floor is the building’s responsibility.  (The floor’s finish and repainting of walls are my responsibility in any case).

You agree to ADR on the portion not handled by our respective insurers.

I can cut you a check for the capital assessment tomorrow.

Yours faithfully,

Robert J. Koenig


cc:

William Simon, Esq.
McGarry & Simon
605 Third Avenue
New York, NY 10158

212/867-0100

Richard Eagan
Manager - NY Zone
USAA (Claims)
USAA Building
San Antonio,  TX 78288

ATTN:        Roger Quisenberry
Examiner

RE:        Water Damage 2/15/89
55 Liberty Street - # 17C
USAA Homeowners Policy # 843707-93A
        6 March 1988 - 6 March 1989
        6 March 1989 - 6 March 1990)
USAA  Personal Umbrella Policy # 084 37 07-70U
        6-December 1987 - 6 December 1988
        6 December 1988 - 6 March 1989
[2]
        6 March 1989 - 6 March 1990
Froese File # JO6-047

800/531-8295 (o-direct)
210-498-2211

800/531-3255


R. Julian Koenig
115 Cove Neck Road
Oyster Bay, NY 11771
516/624-9153
516/624-9236

27 May 1994 05:07 PM

Henry L. Saurborn, Jr., Esq.
Kurtzman Karelson & Frank
230 Park Avenue
New York, NY 10169

212/867-9500
212/599-1759

Dear Mr. Saurborn

In connection with your intentions to serve me at the above address, please be advised that this is only a mail drop for me.  Since my recent divorce, I am living with a friend in NYC.  The address you have approached is that of my mother who has been gracious enough to provide me with a place to get my mail over the course of this unfortunate incident.

Contrary to what you may have been told in this matter, I am most anxious to get the question of 55 Liberty Street #17C settled.  However, my financial condition probably precludes a substantial settlement from my own resources.

However, I am adequately in every regard in this matter and I think that you will find my insurer very cooperative if only you will cooperate with them.

Of the essence in settling this matter is the absolute requirement that 55 Liberty Street’s insurers meet with mine to adjust the loss.  I and my previous wife are insured for property damage and negligence.  You will also note that we are insured for loss of use of the apartment.

I am enclosing copies of the policies for your files.

If you would be so good as to have the pertinent insurer contact:

Grace L. Ward
President
Excel Claims Service, Incorporated
88 Sunnyside Boulevard - # 203
Plainview, NY 11803

516/576-7007
fax:  516/576-0433


Alternatively, you may contact the insurer:

Richard Eagan
Manager - NY Zone
USAA (Claims)
USAA Building
San Antonio,  TX 78288

ATTN:        Roger Quisenberry
Examiner

800/531-8295 (o-direct)
Fax:  800/531-3255

RE:        Water Damage 2/15/89
55 Liberty Street - # 17C
USAA Homeowners Policy # 843707-93A
        6 March 1988 - 6 March 1989
        6 March 1989 - 6 March 1990)
USAA  Personal Umbrella Policy # 084 37 07-70U
        6-December 1987 - 6 December 1988
        6 December 1988 - 6 March 1989
        6 March 1989 - 6 March 1990

I also want to take this opportunity to ad:

1.        The judgment you are collecting on was received (awarded) through the use of perjured testimony  - felony perjury.

2.        If you read the New York Times, you will see that the building’s management, Douglas Elliman, was so riddled with fraud and deceit at the time our apartment was water damaged that to follow on this case at this time borders, in my view, on a RICCO Statute Violation.

3.        I plan to take this up with the NYC and Federal Authorities.

In the meantime, the best way to get this matter settled is to have your client carry out the terms of the lease and repair the damaged floor to # 17 so that I can resume my occupancy.  This strikes me as a fairly simple proposition and I will confess to you that I am having extreme difficulty understanding why it is so hard for 55 Liberty Street to understand it.

Yours faithfully,

Robert J. Koenig



Exhibit “_”:  Koenig family insurance contract (language from previous year’s contract.



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Republished 23 feb 18 0423 GMT

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[1] 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.

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".

[2]        The  Personal Umbrella Policy Declarations for this period is missing from our files.  May I please have a copy.