|
|
|
TESTING IN A
SINGLE PERFECT CASE
THE CHECKS ON
FEDERAL JUDICIAL MISCONDUCT
TOUTED BY THE 1993
REPORT OF
THE NATIONAL
COMMISSION ON JUDICIAL DISCIPLINE & REMOVAL
— and documenting their
complete worthlessness
*
* * *
A public
interest lawsuit to protect
judicial
whistle-blowing attorneys from judicial retaliation
DORIS L.
SASSOWER,
Plaintiff,
-
v -
HON. GUY MANGANO, PRESIDING
JUSTICE OF THE APPELLATE DIVISION, SECOND DEPARTMENT OF
THE SUPREME COURT OF
THE STATE OF NEW YORK, and
the ASSOCIATE JUSTICES THEREOF, GARY CASELLA and EDWARD
SUMBER, Chief Counsel and Chairman, respectively, of the
GRIEVANCE COMMITTEE FOR THE NINTH JUDICIAL DISTRICT,
GRIEVANCE COMMITTEE FOR THE NINTH JUDICIAL DISTRICT,
Does 1-20, being present members thereof, MAX GALFUNT,
being a Special Referee, and G. OLIVER KOPPELL, Attorney
General of the State
of New York, all in their official and personal
capacities,
Defendants.
DISTRICT COURT: SOUTHERN
DISTRICT OF NEW YORK
PLAINTIFF'S VERIFIED COMPLAINT,
June 20, 1994
Exhibit A: Appellate Division, Second Dept's
June 14, 1991 suspension order
Exhibit
B: Written three-year judge-trading Deal between Republican
and Democratic Parties of New York’s Ninth Judicial
District
DEFENDANTS' ANSWER, January 9, 1995
DEFENDANTS' MOTION FOR JUDGMENT ON THE PLEADINGS,
January
19, 1995
Exhibit A:
Rapoport v. Departmental
Disciplinary Committee
Exhibit
B: Mason v. Departmental Disciplinary Committee
Exhibit C:
Maddox v. Mollen, et al.
Exhibit D:
Clouden v. Lieberman
DEFENDANTS' MEMORANDUM OF LAW IN SUPPORT OF THEIR MOTION FOR
JUDGMENT ON THE PLEADINGS, January 17, 1995
PLAINTIFF'S
AFFIDAVIT IN OPPOSITION TO DEFENDANTS' MOTION FOR DISMISSAL
ON THE PLEADING AND IN SUPPORT OF SUMMARY JUDGMENT IN
HER FAVOR, WITH SANCTIONS AGAINST DEFENDANTS, June 23, 1995
Exhibit 1: Plaintiff’s
May 25, 1995 letter to Asst.
A.G., advising of liability for sanctions if Defendants’ false and
fraudulent dismissal motion and Answer were not
withdrawn
Ex. A: Transcript of
March 3, 1995 court proceeding
Ex. B: Plaintiff's annotated "Chronology",
cross-referenced to disciplinary file
Ex. C: Plaintiff’s
March 8, 1994 letter to Defendant
Attorney General Koppell, transmitting disciplinary
file, with annotated Inventory
Ex. D: Plaintiff’s “Critique” of Defendants’
Answer, documenting that over 150 responses were
false and in bad faith
Exhibit 2a: Plaintiff's petition for a writ of
certiorari to the U.S. Supreme Court in her state
Article 78
proceeding,
Sassower v. Mangano,
February 1995
Exhibit 2b: Defendants' memorandum in opposition to cert
petition, April 10, 1995
Exhibit 2c: Plaintiff's reply memorandum, April
25, 1995
PLAINTIFF'S
RULE 3(g) STATEMENT, June 23, 1995
PLAINTIFF'S
MEMORANDUM OF LAW IN OPPOSITION TO DEFENDANTS' MOTION FOR
DISMISSAL ON THE PLEADINGS AND IN SUPPORT OF SUMMARY
JUDGMENT AND SANCTIONS IN PLAINTIFF'S FAVOR, June 23,
1995
PLAINTIFF’S ORDER TO SHOW CAUSE FOR PRELIMINARY INJUNCTION
WITH TEMPORARY RESTRAINING ORDER, which Judge Sprizzo
refused to sign, September 25, 1995
Exhibit A: Defendant 2nd Dept's
June 14, 1991 interim
suspension order
Exhibit B-1: Plaintiff's 1989 Martindale-Hubbell Law
Listing
Exhibit B-2: Letter confirming Plaintiff's election in
1989 as Fellow of American Bar Foundation
Exhibit C: Plaintiff's uncontroverted Rule 3(g)
statement
Exhibit D: Judge Sprizzo's
November 14, 1994 order
Exhibit E: Judge Sprizzo's
December 28, 1994 order
Exhibit F: Judge Sprizzo's
March 6, 1995 order
Exhibit G-1:
Matter of Nuey, 61 NYS2d 512 (1984)
Exhibit G-2:
Matter of Russakoff, 79 NY2d 520
(1992)
Exhibit G-3: 22 NYCRR 691.4
Exhibit H: Plaintiff's
December 14, 1992 affidavit before
2nd Dept demonstrating that her suspension was
a fortiori
to that in Russakoff
Exhibit I-1: Plaintiff's
March 8, 1993 supplemental affidavit
before 2nd Dept. demonstrating, by comparison
to 20 other attorneys suspended in the 2nd Dept, its denial of her due
process & equal protection
rights
Exhibit J-1:
February 27, 1992 order of Judge Griesa suspending
plaintiff from practice in U.S. District
Court/SDNY, predicated on state suspension
Exhibit J-2:
September 11, 1991 order of Judge Griesa
Exhibit J-3: Plaintiff's
October 14, 1991 letter to Judge
Griesa's assistant
Exhibit J-4: Plaintiff's
December 11, 1991 letter to Judge Griesa,
invoking the exception provided by Rule 4 &
requesting
hearing
Exhibit J-5: Plaintiff's
December 19, 1991 letter to Judge Griesa,
reiterating her hearing request & notifying him
of
constitutional challenge presented by
Russakoff
Exhibit J-6: Plaintiff's
January 17, 1992 ltr to Judge Griesa,
reiterating her hearing request & the significance
of Russakoff
Exhibit K-1:
July 30, 1991 letter from NYS Bar Association
Exhibit K-2:
August 9, 1994 letter from Westchester County Bar
Association
Exhibit K-3: Plaintiff's
September 20, 1994 letter to Westchester
County Bar Association
Exhibit K-4: Plaintiff's
October 6, 1994 letter to Westchester
County Bar Association
Exhibit K-5: Plaintiff's
September 21, 1995 letter to Westchester
County Bar Association
Exhibit L: "Barred Attorney Removed From Court",
Gannett, 5/24/95, "Judge Rejects Suit by Suspended Lawyer",
Gannett, 8/4/95
Exhibit M: classified ad, New York Law Journal
Exhibit N: due process violations in Wolstencroft:
from appellate brief & record on appeal
Exhibit O: Plaintiff's
January 10, 1995 affidavit before 2nd
Dept in support of its recusal from Wolstencroft appeals
PLAINTIFF'S MEMORANDUM OF LAW IN SUPPORT OF PRELIMINARY
INJUNCTION AND TRO, September 25, 1995
DEFENDANTS' STATEMENT OF OPPOSITION TO PLAINTIFF'S RULE 3(g)
STATEMENT, October 6, 1995
DEFENDANT CASELLA'S AFFIDAVIT,
October 6, 1995
DEFENDANTS' "MEMORANDUM OF LAW IN REPLY TO PLAINTIFFS'
CROSS-MOTION (sic) FOR SUMMARY JUDGMENT AND IN OPPOSITION TO
PLAINTIFF'S MOTION FOR SANCTIONS, October 6, 1995
PLAINTIFF’S ORDER TO SHOW CAUSE FOR JUDGE SPRIZZO’S RECUSAL,
PURSUANT
TO 28 USC §§144 AND 455, which Judge Sprizzo refused to sign,
October 26, 1995
Exhibit A: Transcript of
September 28, 1995 court proceeding
Exhibit B:
September 26, 1995 receipt stamp
Exhibit C: Judge Sprizzo's decision in
Mason v.
Departmental Disciplinary Committee
Exhibit D-1: Plaintiff's
August 25, 1995 letter to Judge Sprizzo, requesting pre-motion
conference on August 31,
1995 to present OSC for preliminary injunction with TRO
Exhibit D-2: Plaintiff's
September 12, 1995 letter to Asst. A.G.
confirming 9/22/95 as date for presentment of
OSC
for
preliminary injunction with TRO
Exhibit E-1: Asst. A.G.'s
September 13, 1995 letter advising of his
assignment to case
Exhibit E-2: Asst. A.G's
September 13, 1995 letter to Judge Sprizzo,
requesting he so-order his ltr,
extending defendants' time
Exhibit E-3: Plaintiff's
September 18, 1995 letter to Judge Sprizzo,
detailing Asst. A.G.'s litigation misconduct
& opposing his extension request
Exhibit F-1: Plaintiff's
December 16, 1994 letter to Judge Sprizzo,
detailing Asst. A.G. 's litigation misconduct
Exhibit F-2: Judge Sprizzo's
June 26, 1995 letter to Plaintiff,
advising her that "all further communications with the
Court must be in writing"
Exhibit F-3: Plaintiff's
July 26, 1995 letter to Judge Sprizzo,
detailing as unwarranted his requirement that she
communicate with the Court only in writing & requesting date to present
for preliminary injunction
with TRO
Exhibit F-4:
August 3, 1995 letter to Plaintiff from Judge Sprizzo's
law clerk, reaffirming court directive & advising to
arrange
a pre-motion conference for her OSC, as required by Judge
Sprizzo's individual rules
Exhibit F-5: Plaintiff's
September 19, 1995 letter to Judge Sprizzo,
detailing the "disparate and discriminatory"
treatment
accorded
her by him & his staff
PLAINTIFF'S MEMORANDUM OF LAW IN SUPPORT OF HER ORDER TO
SHOW CAUSE FOR RECUSAL
[rejected by Judge Sprizzo at the October 27, 1995 date of
presentment of the Order to Show Cause]
PLAINTIFF'S AFFIDAVIT IN FURTHER SUPPORT OF TEMPORARY
INJUNCTION AND SANCTIONS, October 27, 1996
PLAINTIFF’S NOTICE OF MOTION FOR REARGUMENT,
RECONSIDERATION, AND RENEWAL OF ORDER TO SHOW CAUSE FOR
RECUSAL AND FOR OTHER RELIEF,
March 8, 1996
Exhibit A-1: Judge Sprizzo's
March 5, 1996 order
Exhibit A-2:
March 4, 1996 coverletter from Judge Sprizzo's law
clerk
Exhibit B: Transcript of
October 27, 1995 court proceeding
Exhibit C: Plaintiff's unanswered
December 27, 1995 letter to
Judge Sprizzo, detailing his 11/9/95 order as
factually erroneous & legally unsupported & requesting clarification
Exhibit D: Plaintiff's unanswered
January 9, 1996 letter to Judge
Sprizzo, reiterating her request for clarification
of his
November 9, 1995 order & the exigency of injunctive relief
Exhibit E: Plaintiff's
January 23, 1996 letter to Judge Sprizzo,
detailing his prejudicial disregard of her rights by
his refusal to
respond to her
December 27, 1995 and February 9, 1996 letters & his favored
treatment
of defendants
Exhibit F: Plaintiff's
March 5, 1996 letter to Judge Sprizzo,
protesting his prejudicial conduct & request that it be
accepted in lieu of formal motion as a renewal of her
October 27, 1995 motion
for his recusal
DEFENDANTS' MOTION TO DISMISS PURSUANT TO FRCP 41(b), March 8, 1996
DEFENDANTS' MEMORANDUM OF LAW, March 7, 1996
MEMORANDUM OPINION AND ORDER,
May 21, 1996
JUDGMENT,
May 24, 1996
PLAINTIFF-APPELLANT'S NOTICE OF APPEAL,
June 27, 1996
CONTINUES WITH:
SECOND CIRCUIT COURT
OF APPEALS
(#96-7805)
UNITED STATES SUPREME
COURT
(#98-106)
|
|
|
