June 6, 2022 -- D-DAY plus 78 years
CJA's Article 78 proceeding/
declaratory judgment action/citizen-taxpayer action

click here for:
electronic court file -- NYSCEF:
Albany Co. #90425-22

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Below is:
EXPANDED CASE PROGRESSION --
IN SUPREME COURT & OUT

Albany County Supreme Court

1.
CJA's June 6, 2022 verified petition 

2.
CJA's original order to show cause
& June 6, 2022 moving affidavit
& Part 1 Duty Judge Peter Lynch's signed OSC 

3.
CJA's June 12, 2022 letter to NYS' 15 law school deans
comprising the "independent review committee"
of the "ethics commission reform act of 2022"

4.
CJA's Intervention, Amicus Curiae Requests
to "JCOPE Must Go" Coalition Members,
Bar Associations, Etc.

5.
CJA's order to show cause
& June 21, 2022 moving affidavit

6.
CJA's June 23, 2022 notice of petition
& affidavit in support   xx

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Ulster County Supreme Court

August 21, 2021
"Three running unopposed for state supreme court judge positions"
Daily Freeman (Ariel Zangla)

7.
How the Attorney General Litigates:
June 27, 2022 dismissal motion

AAG Rodriguez' Notice of Motion (#50)

AAG Rodriguez' Memorandum of Law (#51)

Affidavit for Comproller (#52)
Affirmation for Inspector General (#53)
Affirmation for JCOPE (#54)
Affirmation for LEC (#55)
Affirmation for Senate (#56)
Affirmation for Assembly (#57)
Affidavit for AG (#58)

8.
CJA's CPLR §2214(c) NOTICE
to respondents to furnish "papers" to the Court

9.
CJA's June 28, 2022 affidavit in opposition
& in further support of TRO & preliminary injunction

10.
"TIME IS OF THE ESSENCE" --
SECURING THE PUBLIC'S "MATTER OF LAW" ENTITLEMENT
TO A TRO & PRELIMINARY INJUNCTION TO PREVENT THE "ETHICS COMMISSION REFORM ACT OF 2022" FROM REPLACING JCOPE WITH SOMETHING WORSE

11.
CJA's July 6, 2022 ORDER TO SHOW CAUSE
for a TRO, &/or for an Immediate Hearing on & Determination of Petitioners’ entitlement, as a matter of law, to a Preliminary Injunction

12.
CJA's July 8, 2022 e-mail to Supreme Court Justice Gandin's Law Clerk

July 11, 2022 e-mail from Gandin's Law Clerk

CJA's July 11, 2022 e-mail from Gandin's Law Clerk

13.
Judge Gandin's July 21, 2022 decision

14.
CJA's August 16, 2022 e-mail to Court Reporter --
"July 7, 2022 transcript -- CJA., et al. v. JCOPE, et al. (Albany Co. #904235-22)"
transcript mark-up

15.
How the Attorney General Litigates:

AAG Rodriguez' August 18, 2022 notice of cross-motion

AAG Rodriguez' memorandum of law

affidavit -- JCOPE

affirmation -- IG

16.
CJA's September 1, 2022 verified amendment
to June 6, 2022 verified petition/complaint (#84)

17.
CJA's September 3, 2022 notice of papers
to be furnished to the Court
pursuant to CPLR §2214(c) (#85)

18.
CJA's September 15, 2022 notice for discovery & inspection
pursuant to CPLR §3120 (#86)

19.
CJA's September 15, 2022 affidavit (#87)
in Opposition to Respondents’ August 18, 2022 Cross-Motion
& in Support of Petitioners’ September 15, 2022 Motion for Sanctions,
Summary Judgment & Other Relief

Exhibit A:  Analysis of AG's cross-motion (#88)

Exhibit B-1:  CJA's July 8, 2022 e-mail (#89)

Exhibit B-2: CJA's Aug 16, 2022 e-mail
& July 11 exchange (#90)

Exhibit C:  July 7, 2022 transcript (#91)

Exhibit D: CJA's Sept. 15, 2022 notice
for discovery & inspection pursuant to CPLR §3120 (#92)

20.
CJA's September 15, 2022 notice of motion (#93) --
for sanctions, disqualification of AG, summary judgment
& other relief

CJA's September 15, 2022 memorandum of law (#94) --
in support of sanctions vs AG James, culpable attorneys of the AG's office, & respondents for their litigation fraud, disqualification of the AG, summary judgment & other relief

21.
CJA's September 19, 2022 letter to Supreme Court Justice Gandin (#95) --
(1) This Court’s individual rules pertaining to page limits on motions conflicts with, and subverts,  the Uniform Civil Rules for the Supreme Court & the County Court (22 NYCRR §202.8-b); (2) petitioners’ word-count certifications

22.
AAG Rodriguez' September 20, 2022 letter to Supreme Court Justice Gandin (#96)

Judge's response (#97)

23.
CJA's September 21, 2022 e-mail to Bennett Liebman --
"EXPLANATION REQUIRED: Your Sept. 15th 'Explaining the Ethics Commission Reform Act of 2022' -- & the foreseeability of 'What comes next in New York State's pursuit of ethics reform'"

24.
WANTED: your scholarship, expertise, & independent expert opinion as to the state of the record in CJA v. JCOPE, et al -- starting with the 6th cause of action to VOID the "ethics commission reform act of 2022"

CJA's September 25, 2022 e-mail to New York State Bar Association

CJA's September 25, 2022 e-mail to New York City Bar Association

“Explaining the Ethics Commission Reform Act of 2022”  news release

25.
How the Attorney General Litigates:

AAG Rodriguez' Opposing Affirmation (#98)

AAG Rodriguez' Opposing Memorandum of Law (#99)

AAG Rodriguez' Reply Affirmation (#101)

AAG Rodriguez Reply Memorandum of  Law (#102)

26.
CJA's October 4, 2022 Reply Affidavit  (#104)
Ex. A  (#105)
Ex. B-1  (#106)
Ex. B-2  (#107)
Ex. C-1  (#108)
Ex. C-2 (#109)

CJA's October 4, 2022 Reply Memorandum of Law  (#110)

27.

Supreme Court Justice Gandin's November 23, 2022 decision (##111-116)

28.
CJA's November 25, 2022 letter to Supreme Court Justice Gandin (#117)

29.
How the Attorney General Litigates:

AAG Rodriguez' November 29, 2022 notice of entry  (#118)

30.
On December 16, 2022, to commemorate the 78^th anniversary
of the start of the Battle of the Bulge,
petitioners have fought back, on TWO FRONTS, on Justice Gandin's assault on the ten causes of action of their June 6, 2022 D-Day-plus-78-years verified petition:

 #1:  December 16, 2022 reargument/vacatur motion

notice of motion  (#119)

moving affidavit (#120)

Exhibit 1 (#121)
"legal autopsy/analysis of
Nov 23, 2022 "Decision, Order and Judgment"

#2: December 16, 2022 notice of appeal

notice of appeal (#122)

Informational Statement (#123)

31.
December 23, 2022 e-mail exchange

AAG Rodriguez letter to the Court (#124)

32.
Requests for Discharge of Professional,
Ethical, & Civic Responsibilities

CJA's December 28, 2022 e-mail to New York State Bar Association --
"NYSBA's role in Executive Committee Member Kaylin Whittingham's nomination to CELG; ethical, professional, & civic responsibilities with respect to CJA v. JCOPE, et al.; & the fake scholarship of members of the Committee on the NYS Constitution"

CJA's December 29, 2022 e-mail to New York City Bar Association --
"Does the NYC Bar Association dispute that the record of CJA v. JCOPE, et al. is a perfect 'paper trail'
of public corruption, obliterating constitutional state governance -- &, if not, what actions will it take, consistent with its responsibilities?"

CJA's December 29, 2022 e-mail to "Watchdog Groups" --
"When will "Watchdog Groups" be confronting the CJA v. JCOPE, et al. lawsuit
– & such other EVIDENCE dispositive that 'CELG Must Go'"

33.
CJA's January 19, 2023 e-mail to Gandin

34.
How the Attorney General Litigates:

AAG Rodriguez' January 13, 2023 affirmation in opposition (#126)

AAG Rodriguez' January 13, 2023 memorandum of law in opposition (#127)

35.
CJA's January 19, 2023 reply affidavit in further support of motion (#128)

Exhibit (#129)

36.
Supreme Court Justice Gandin's February 15, 2023 Decision & Order (#130)

Schneider v. Solowey, 141 AD2d 813 (2^nd Dept. 1988)

Foley v. Roche, 68 AD2d 558 (1^st Dept 1979)

Luderowski v. Sexton, 152 AD3d 918 (3^rd Dept. 2017)

37.
CJA's February 23, 2023 notice of appeal (#131)

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correspondence

CJA's June 8, 2022 e-mails to Gov --
"AGAIN -- Contact info for Gov. Hochul's counsel's office --
oral argument on TRO"

CJA's June 9, 2022 e-mail to AG --
"Contact info for AG's Albany offices -- NOTICE of oral argument for TRO in lawsuit
vs JCOPE...LETITIA JAMES...(Albany County #904235-22)"

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 Supreme Court/Albany County 

Ulster County Supreme Court

Uniform Rules for NYS Trial Courts: 202
 

Third District Administrative Judge Gerald Connolly

2022 Third District rules, etc.

p. 15: The District Administrative Judge will:
a) Make case assignments when judges are disqualified;

Service -- CPLR Article 3

CPLR Article 78 proceeding

declaratory judgment action (CPLR 3001)

citizen-taxpayer action -- State Finance Law Article 7-A

CPLR Article 63 Preliminary Injunctions, TROs 
6313. Temporary restraining order. (a) Generally. If, on a motion for a preliminary injunction, the plaintiff shall show that immediate and irreparable injury, loss or damages will result unless the defendant is restrained before a hearing can be had, a temporary restraining order may be granted without notice. Upon granting a temporary restraining order, the court shall set the hearing for the preliminary injunction at the earliest possible time. ..."

& here

Judge David Gandin's Court Rules

CPLR Article 31 discovery

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