SUING THE NEW YORK TIMES
for libel & journalistic fraud
* * *
SUPREME COURT OF THE STATE OF NEW YORK
WESTCHESTER COUNTY -- #19841-05
Defense Counsel
Freeman's Reply Affidavit, June 9, 2006
Exhibit A:
transcript pages of the Senate Judiciary Committee's May 22, 2003 confirmation
hearing
Plaintiff
Sassower's Reply Affidavit,
June 13, 2006
JUNE 14, 2006 ORAL ARGUMENT at which Plaintiff
Sassower handed up to the Court two law review articles in substantiation of
Plaintiffs' journalistic fraud cause of action:
(1)
Journalistic Malpractice:
Suing Jayson Blair and the New York
Times for Fraud and Negligence",
by Professors Clay Calvert & Robert D.
Richards, 14 Fordham Intellectual Property,
Media & Entertainment Law Journal 1 (2003-2004)
(2)
"Access
to the Press -- A New First Amendment Right",
by Professor Jerome A. Barron,
80 Harvard Law Review 1641 (1966-1967)
PLAINTIFFS' NOTICE OF MOTION for Disqualification of
"Acting Supreme Court Justice" Gerald E. Loehr for Demonstrated Actual Bias &
Interest, Vacatur of his July 5, 2006 Decision & Order by Reason Thereof or Upon
the Granting of Reargument/Renewal, Disclosure & Referral to Administrative
Judge Francis A. Nicolai, Vacatur of the County Clerk's August 1, 2006 Judgment
& Other Relief,
dated August 21, 2006
---
Plaintiff Sassower's Moving Affidavit in Support of
Disqualification/Disclosure, Reargument/Renewal, Vacatur,
sworn to August 21,
2006
Exhibit CC:
Judge Gerald E. Loehr’s July 5, 2006 decision and order,
granting defendants’
motion to dismiss
the complaint
and denying plaintiffs’ cross-motion
Exhibit
DD: Administrative Judge Francis A. Nicolai’s May 8, 2006
notice
assigning this action to "Acting
Supreme Court
Justice" Gerald E. Loehr
Exhibit EE:
August 1, 2006 judgment signed by Westchester
County Court Clerk Timothy C. Idoni
Exhibit FF: Request for Judicial Intervention (RJI), filed with the
Westchester County
Clerk’s Office on
April 25, 2006,
by George Freeman, Esq. on behalf of defendants The
New York
Times
Company, et al.
Exhibit
GG-1: Supreme Court Justice Mary H. Smith’s August 4, 2004
recusal order in
George Sassower v. Feltman, Karesh,
Major & Farbman, et al. (Index
#20421-92)
Exhibit GG-2: Supreme Court Justice John R. LaCava’s April 16,
2004 order
of recusal in George Sassower v. Feltman,
Karesh, Major & Farbman, et al. (Index #20421-92)
Exhibit HH:
“Veteran Democrats bid to unseat Republican judges”, The
Journal News,
October 27, 2004
Exhibit II:
“Politicos pay tribute to a poster boy of cronyism: Tax cheat
Arred
gets a big turnout at party”, The Journal News,
column by Phil Reisman, August 1, 2006
Exhibit JJ: Doris L. Sassower’s published Letter to the Editor,
The Westchester Crusader, April 8, 2004
Exhibit
KK-1: CJA’s webpage of
Castracan v. Colavita
Exhibit
KK-2: CJA’s webpage “papertrail of suppression,
protectionism, and
blackballing” by The New York
Times
from 1990 & 1991
Exhibit LL-1: Doris L. Sassower’s October 24, 1991 letter to Governor
Cuomo, with enclosures, filed as a
complaint with the
New York State Commission on Judicial Conduct:
(a)
1989 three-year judge-trading cross-endorsements
deal
(b)
Doris L. Sassower’s Letter to the Editor, “Cross-Endorsement:
Questions of Protection”, New York Times, June 9, 1991
(c) Doris
L. Sassower’s column “Judicial-Selection Panels: An
Exercise in Futility?”,
NYLJ, September 22, 1971
(d)
Doris L. Sassower’s 1989 Martindale-Hubbell Law
Directory
listing
Exhibit
LL-2: Commission’s January 7, 1992 letter dismissing
the October 24, 1991
complaint
Exhibit MM: “Where
Do You Go When Judges Break the Law?”, CJA’s
$16,770 public interest ad on
The New York Times’
Op-Ed page of October 26, 1994
Exhibit NN-1: CJA’s March 4, 2003 facially-meritorious and
documented
judicial misconduct complaint against
Justice LaCava and Administrative Judge Nicolai, filed
with the New York State
Commission on
Judicial
Conduct
Exhibit NN-2: Commission’s June 19, 2003 letter dismissing the
March 4,
2003 complaint
Exhibit OO: “Westchester’s
Matrimonial Part Revamped in Wake of
Infighting”, New York Law Journal,
June 26, 2006,
front page
Exhibit
PP-1: Plaintiff Sassower’s August 7, 2006 letter to
Westchester County
Clerk Timothy C. Idoni
Exhibit PP-2: August 8, 2006 letter of Westchester County Deputy
Clerk
John J. Allen
---
Plaintiffs' Memorandum of Law in Support of Motion for
Disqualification/Disclosure, Reargument/Renewal, Vacatur,
dated August 21,
2006
-- Appendix:
In-Depth Analysis of the "Deemed True" Allegations of the
Verified
Complaint Recited by the July 5, 2006 Decision & Order
Defense Counsel
Freeman's Affidavit in Opposition to Plaintiffs'
Motion for Disqualification, Reargument, Renewal and Vacatur,
sworn to September 19, 2006
Plaintiff Sassower's Reply Affidavit in Further Support of
Plaintiffs' August 21, 2006 Motion for Disqualification/Disclosure,
Reargument/Renewal, Vacatur,
sworn to September 25, 2006
Exhibit
QQ: exchange of correspondence
Exhibit
RR: "Institutional Reckless Disregard for Truth in Public
Defamation
Actions Against the Press"
by Professors
Randall P. Bezanson & Gilbert Cranberg, 90 Iowa Law
Review 887
(March 2005)
Judge Loehr's September 27, 2006 Decision & Order
APPELLATE DIVISION, SECOND DEPARTMENT
Docket # 2006-8091;
# 2006-10709; # 2007-186
PLAINTIFFS'
NOTICE OF APPEAL & REQUEST FOR APPELLATE DIVISION INTERVENTION,
dated August 21, 2006 --
Appellate
Division acknowledgment,
August 25, 2006
PLAINTIFFS' NOTICE OF APPEAL & REQUEST FOR APPELLATE DIVISION INTERVENTION,
dated December 21, 2006 --
Appellate Division acknowledgment, January 8, 2007
* * *
Elena Sassower's February 1, 2007 letter to George Freeman
George Freeman's
February 1, 2007 e-mail & subsequent e-mail exchange
Elena Sassower's February 15, 2007 letter to the Appellate
Division, Second Department, enclosing signed stipulation enlarging
plaintiffs-appellants' time to file their appeal brief to April 23, 2007
SO-ORDERED STIPULATION ENLARGING TIME
Elena
Sassower's March 29, 2007 letter to Appellate Division, Second Department Clerk
James Pelzer --
"RE: Application for Permission to File Oversized Brief"
Appellate Division Clerk Pelzer's
April 6, 2007 letter
Appellants'
APPEAL BRIEF,
April 23, 2007
Table of Contents to Record on
Appeal
Supplement to the Record
Appellant
Sassower's Order to Show Cause, signed April 23, 2007, returnable
May 2, 2007
Eli Vigliano's
Supporting Affirmation, dated April 24, 2007
Appellant Sassower's Supplemental Affidavit, sworn to April 25, 2007
--
Exhibit A:
Sassower's April 23, 2007 letter to Appellate Division
Clerk Pelzer
George Freeman's May
1, 2007 letter to Appellate Division
Appellate Division's May
8, 2007 Decision & Order on Motion
George
Freeman's June 27, 2007 coverletter to Appellate Division, Second Department
Clerk Pelzer
New York Times' Opposing Brief,
June 27, 2007
Elena
Sassower's July 5, 2007 letter to George Freeman -- "RE: Stipulation for
Enlargement of Time"
Mr. Freeman's
e-mail -- "RE: Stipulation Enlarging Time -- Reply Brief"
Elena Sassower's
July 9, 2007 letter to Appellate Division, Second Dept. Clerk Pelzer -- "RE:
So-Ordering of Stipulation for Enlargement of Time for Plaintiff-Appellants'
Reply Brief
Stipulation for
Enlargement of Time, so-ordered by Appellate Division, Second Dept. Clerk Pelzer
Appellants' REPLY BRIEF,
July 24, 2007
Elena Sassower's
December 10, 2007 letter to Appellate Division, Second Department Clerk
--
"Electronic Recording of Oral Argument: Friday, December 14, 2007"
ORAL ARGUMENT,
December 14, 2007
The New York Times did NOT show up!
Elena Sassower's
December 18, 2007 letter to Appellate Division, Second Department
--
"RE: December 14, 2007 Oral Argument: Videotape & Correction of my
Response to Appellate Panel Presiding Justice Santucci"
February 5,
2008 decision & order (Spolzino, J.P., Santucci, Lifson, Covello)
--
does NOT identify ANY of appellants' appellate issues, ANY of the facts, law, or
argument they presented in support, and conceals the existence of the
journalistic fraud cause of action in making it appear that appellants'
Complaint was limited to a single defamation cause of action, when there were
two
WHO ARE THESE JUDGES -- each of
whom earned $144,000 yearly -- who rendered such a fraudulent judicial decision,
corrupting any semblance of "the rule of law"?
Robert A. Spolzino
Fred T. Santucci
Robert A. Lifson
Joseph Covello
Spolzino -- left the bench
August 2009 because of dissatisfaction with his $144,000 yearly salary --
NYLJ: front page - News in Brief "Second Department Judge Quits Over Lack of
a Raise": August 4, 2009
March 8, 2014
"The
Uninhibited Press, 50 years Later"
New York Times Editorial