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Appeal at the Appellate Division,
Third Dept.
Appellants' October 23, 2018 Motion
to Strike
Respondents' Brief, to Declare the Attorney General's Appellate
Representation
of Respondents Unlawful, & for Other Relief
* furnished to AG Underwood
& TOP
supervisory/managerial attorneys --
CJA's October 23, 2018 transmitting e-mail
CJA's October 23, 2018 affidavit of service
Appellants'
October 23, 2018 Notice of Motion,
with declined OSC beneath
Appellants' Moving Affidavit
Exhibit A-1: Appellants’ September 21, 2018 e-mail to
Assistant Solicitor General Frederick Brodie –
“NOTICE: Your duty to withdraw your respondents’ brief, as it is ‘a fraud on
the court’…”
Exhibit A-2: Asst. Solicitor General Brodie’s
September 21, 2018 e-mail
Exhibit B-1: Appellants’ October 3, 2018 letter to
Appellate Division, Third Department Clerk
Robert Mayberger – “Leave to File Oversized Reply Brief”
Exhibit B-2: October 4, 2018 e-mail and letter from
Managing Attorney Erica Putnam Little
Exhibit B-3: Appellants’ October 4, 2018 e-mail to
Managing Attorney Little –
“…Appellants’ Oversized Reply Brief”
Exhibit C: Appellant
Sassower’s May 16, 2018 letter/complaint to Attorney General Barbara
Underwood – “NOTICE:
Corruption and Litigation Fraud by Former Attorney General
Eric Schneiderman & his Office – and Your Duty to Take Investigative and
Remedial
Action, most immediately, in the Citizen-Taxpayer Action...and pursuant to
‘The Public
Trust Act (Penal Law §496: ‘Corrupting the government’)”
Exhibit
D: Appellant Sassower's May 30, 2018
letter to Attorney General Underwood --
“What is the Status? – CJA's May
16, 2018 letter: NOTICE...,
(1) Disclosure of facts
giving rise to your duty to secure appointment of
independent/outside counsel to
investigate and report on your ethical and
law enforcement obligations with respect to the May 16, 2018 NOTICE,
or a special prosecutor;
(2) FOIL/records request
– conflicts of interest; Executive Law §63.11;
legislative oversight.”
Exhibit E-1: ¶¶11-23 of appellant Sassower’s
July 24, 2018 moving affidavit in support of
the second branch of appellants’ order to show cause – “Threshold Integrity
Issues
Pertaining to the Attorney General: Plaintiffs’ Entitlement to its
Representation/Intervention
& its Disqualification on Conflict of Interest Grounds”
Exhibit E-2:
Inventory of Free-Standing Exhibit I (eye) to appellant Sassower’s July 24,
2018 moving
affidavit in support of order to show cause
Exhibit E-3: Inventory of Free-Standing Exhibit J to
appellant Sassower’s July 24, 2018
moving affidavit in support of order to show cause
Exhibit F: pages 22-24 of
appellants’ “legal autopsy”/analysis
of Asst. Solicitor General Brodie’s July 23, 2018 letter –
(Exhibit Z to appellant Sassower’s August 1, 2018 reply affidavit)
Exhibit G: pages 4-7 of appellants’
“legal autopsy”/analysis
of Asst. Solicitor General Brodie’s August 3, 2018 memorandum –
(Exhibit DD to Sassower’s August 6, 2018 reply affidavit)
incorporated:
Appellants'
October 4, 2018 Reply Brief
* * *
Chief Motion Attorney Ed Carey's October 22, 2018 e-mail
Appellants' October 22, 2018 e-mail
* * *
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