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JCOPE LAWSUIT
June 6, 2022
VERIFIED PETITION/COMPLAINT
TABLE OF EXHIBITS
Exhibit
A-1: Petitioners’ April 13, 2022 complaint to JCOPE –
cc to NYS-IG
Exhibit A-2: (linked)
Petitioners’ January 22, 2022 written statement in support of oral testimony
at the Legislature’s January 25, 2022 “public protection” budget hearing
Exhibit A-3: (linked)
Petitioners’ January 25, 2022 (written) oral testimony at the Legislature’s
January 25, 2022 “public protection” budget hearing
Exhibit A-4: (linked) Petitioners’
March 25, 2022 e-mail to legislators –
“NYS BUDGET:
What findings of fact & conclusions of law did you make regarding my
testimony at the Jan 25, 2022 ‘public protection’ budget hearing?”
Exhibit A-5: (linked)
Petitioners’ March 18, 2020 letter to Governor Cuomo, etc., with its annexed
August 21, 2013 letter to Governor Cuomo, etc.
Exhibit A-6:
(linked) Petitioners’ ninth cause of action of their 2nd
citizen-taxpayer action
with its incorporated sixteenth cause of action
of their 1st
citizen-taxpayer action
Exhibit B:
Petitioners’ December 17, 2021 complaint to JCOPE –
cc to NYS-IG
Exhibit C: Petitioners’ November 24, 2021
complaint to JCOPE,
with its
enclosed November 24, 2021 complaint to NYS Commission on Judicial Conduct
Exhibit D-1: Petitioners’ March 5, 2021 complaint to JCOPE,
with its enclosures: (Ex. A) Petitioners’
June 4, 2020 grand jury/public corruption complaint to Albany County D.A.
Soares; (Ex. B) Petitioners’ June 13, 2020 grand jury/public corruption
complaint to Montgomery County D.A. McCoski; (Ex. C-1) D.A. Soares’ June 27,
2020 letter; (Ex. C-2) D.A. McCoski’s August 20, 2020 letter
Exhibit D-2: (linked)
Petitioners’ February 11, 2021 complaint against AG James
to Appellate Division attorney disciplinary committees
Exhibit D-3: (linked)
Petitioners’ February 7, 2021 complaint to NYS Commission on Judicial
Conduct
Exhibit E: Petitioners’ August 31, 2020
complaint to JCOPE
Exhibit F: Petitioners’ December 11,
2014 complaint to JCOPE,
with its enclosures: (Ex. A) Petitioners’ July
11, 2014 letter (w/o attachments); (Ex. B) Petitioners’ July 18, 2014
letter; (Ex. C): NYC Bar Association’s July 9, 2014 letter
Exhibit G: Petitioner’s June 27, 2013
complaint to JCOPE,
with its enclosed April 15, 2013 public
corruption complaint to SDNY U.S. Attorney Preet Bharara
Exhibit H: Petitioners’ July 11, 2013 complaint to NYS-IG --
cc to JCOPE,
constituting two inter-related complaints
against “covered agencies”
Exhibit I: Petitioners’ November 2, 2021 complaint to NYS-IG Lang,
“ENABLING YOU TO FAITHFULLY DISCHARGE THE DUTIES
OF YOUR OFFICE”,
constituting six inter-related complaints
against "covered agencies”
Exhibit J: Petitioners’ May 6, 2022
e-mail to JCOPE – cc
to NYS IG
“Setting the record straight on Executive Law §94 – as to JCOPE & CELG –
& taking the emergency correcti[ve] action with
respect thereto warranted by CJA’s April 13, 2022 complaint (#22-052)”
Exhibit K: Petitioners’ May 16, 2022
letter to NYS-IG Lang – cc
to JCOPE
“(1) Accounting for, and
rectifying, your Office’s flagrant violations of its ‘Policy and Procedure
Manual’ and Executive Law Article 4-A with regard to CJA’s Nov. 2, 2021
complaint vs JCOPE, etc.; (2) Confirmation that you will not have
jurisdiction over CELG, pursuant to the newly-enacted Executive Law §94, in
contrast to your jurisdiction over
JCOPE, pursuant to the current Executive Law §94”
Exhibit L-1: Petitioners’ July 9, 2021 written statement in
support of oral testimony
at the July 12, 2021 Senate hearing on “New
York State’s System of Ethics Oversight and Enforcement”
Exhibit L-2: Petitioners’ July
12, 2021 written testimony in lieu of oral testimony
Exhibit L-3: Petitioners'
November 8, 2021 e-mail requesting to testify at December 9, 2021 hearing
on “New York State’s System of Ethics Oversight and Enforcement"
Exhibit L-4: Petitioners'
November 15, 2021 e-mail requesting to testify at December 9, 2021 hearing
Exhibit L-5: Petitioners' November 30, 2021 e-mail
requesting to testify at December 9, 2021 hearing
Exhibit L-6: December
9, 2021 e-mail from Senator Biaggi's Chief of Staff
Exhibit M-1: Petitioners’ March 9, 2017 e-mail to Committee on Open
Government
Exhibit M-2:
Petitioners’ Sept. 16, 2019 e-mail to
Committee on Open Government
Exhibit M-3: Deputy Director’s September 30, 2019
e-mail
Exhibit M-4: Petitioners’
January 13, 2020 e-mail to Committee on Open Government
Exhibit M-5: Executive
Director’s February 12, 2020 e-mail
RESOURCE SECTION
Ethics in Government Act of 1987
Chapter 813 of the Laws of 1987
Public Employee Ethics Reform Act of 2007 ("PEERA")
Chapter 14 of the Laws of 2007
Public Integrity Reform Act of
2011 ("PIRA")
Chapter 399 of the Laws of 2011
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