Civil Investigative Demand Wolf

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Civil Investigative Demand on Judges/Defendants

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    UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY

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    KARIN WOLF, individually & as the parent, natural guardian and next friend on behalf of D.C. and G.C., Plaintiffs, -against- GERALD C. ESCALA, individually and as a STATE actor Judge for the Bergen County Family Court, EDWARD J. CRANE, PETER VAN AULEN, ESQ., DR. JUDITH BROWN GREIF, WILLIAM R. DELORENZO, individually and as a STATE actor Judge for the Bergen County Family Court, JUDGE BONNIE J. MIZDOL, individually and as a STATE actor Judge for the Bergen County Family Court, JUDGE PETER DOYNE, individually and as a STATE actor Judge for the Bergen County Court, CHIEF JUSTICE STUART RABNER, individually and as a STATE actor Judge for the NJ SUPREME COURT, GOVERNOR CHRIS CHRISTIE, individually and as STATE actor Governor, STATE OF NEW JERSEY, BERGEN COUNTY FAMILY COURT OF THE SUPERIOR COURT OF NEW JERSEY; OFFICE OF THE COUNTY COUNSEL, APPELLATE DIVISION OF THE SUPERIOR COURT OF NEW JERSEY, JUDGE WILLIAM E. NUGENT, individually and as a STATE actor Judge for the Appellate Court, JUDGE HARRY G. CARROLL, individually and as a STATE actor Judge for the Appellate Court, JUDGE ELLEN L. KOBLITZ, individually and as a STATE actor Judge for the Appellate Court, JUDGE JOHN C. KENNEDY, individually and as a STATE actor Judge for the Appellate Court, JUDGE JEROME M ST. JOHN, individually and as a STATE actor Judge for the Appellate Court, JUDGE VICTOR ASHRAFI,

    CASE NUMBER: 14-cv-5985

    CIVIL INVESTIGATIVE DEMAND PURSUANT TO

    18 USC 1968 and 31 USC 3733

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    individually and as a STATE actor Judge for the Appellate Court, JUDGE JOSEPH L. YANNOTTI, individually and as a STATE actor Judge for the Appellate Court, OFFICE OF COURT ADMINISTRATION, BERGEN FAMILY CENTER, CONSTANCE RITZLER, JOHN CUTTITO, ALEXANDRA STREMLER, ESQ., ROGER RADOL, ESQ., DIANA MOSKAL, KATHY KATONA, ESQ., LISA ESTRIN, DYFS n/k/a DCP&P, TARA HORNE, SANDRA CRUZ, CRUZS SUPERVISOR, PATRICK YAN, DEBBIE GOMEZ, ERIKA FRANK, DIONOS BURGOS, IVAN NINA, FULL CIRCLE, KRISTIN CIRELLI, ADVISORY COMMITTEE ON JUDICIAL CONDUCT, ATTORNEY GENERAL OF THE STATE OF NEW JERSEY - BOARD OF ETHICS, GOOD SHEPHERD LUTHERAN CHURCH, THE REVEREND ROGER W. SPENCER, JANET TENORE, LUCIANA COUNTINHO, MARLENI COUNTINHO, PLINIO COUNTINHO, BANK OF AMERICA MERRILL LYNCH, a corporation, DOES,

    Defendants.

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    Karin Wolf P.O. Box 473 New York, NY 10163 Tel. 201-450-2192 Fax 646-786-3347 [email protected]

    CIVIL INVESTIGATIVE DEMAND

    To: All Defendants

    Pursuant to the authority granted to Karin Wolf as a private attorney general under the provisions of 18 USC 1964 of the Federal RICO Act, 18 USC Chapter 96, you are hereby directed to produce the documentary material specified herein.

    You are to make available the documentary material described herein on or before February 28, 2015. You may forward the responsive material via courier or certified mail to Karin Wolf at P.O. Box 473, New York, NY 10163, if the information is no bigger than a large envelope and can be sent to a P.O. box. If documentary evidence is in the form of a package or other large container, you must notify Karin Wolf when the materials are ready to arrange for receipt. The Civil Investigative Demand is relevant to the subject matter of an investigation of the above-named Defendants for racketeering pursuant to the provision of law coded at 18 USC Chapter 96, otherwise known as the RICO Act of 1972, for allegedly running a corrupt Enterprise via the New Jersey Family Courts.

    If you are not named above, you may have been identified as a racketeer, aid, and/or abettor.

    The nature of the conduct constituting the alleged racketeering violation is, but not limited to, unlawfully rigging family court proceedings for profit and pleasure of harming others, Kids for Cash, fraud, fraud upon the court, honest services fraud, bribery, human trafficking, child prostitution, child pornography, civil conspiracy to deprive others of rights and liberties, discrimination against a class of persons, Title 9, Title 4D, obstruction of justice, tampering with a witness, victim or informant, misprison of felonies, false advertising, false claims, sedition, treason, and the averments as set forth in the Plaintiffs RICO Complaint filed with the U.S. District Court, District of New Jersey, Newark, Wolf v. Escala, case no. 14-cv-5985. Further alleged conduct will be alleged in Plaintiffs upcoming Amended Complaint and Supplemental Pleadings, in which you may be named as a Defendant.

    Please be advised that any person who attempts to avoid, evade, or prevent compliance, in whole or in part, with this directive by removing, concealing, withholding, destroying, mutilating, altering, or by any other means falsifying any documentary material may be guilty of a crime punishable, upon conviction, by fine or by confinement, or both.

    Please be advised that the following is a preliminary list and further investigative discovery may be demanded or required.

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    MATERIALS DEMANDED

    1. All of your tax returns for the past 10 years. 2. All of your bank and other financial information for the past 10 years, including, but not

    limited to 401Ks, investments accounts, offshore accounts, mortgages, campaign contributions, donations and other monies given and/or received, etc.

    3. All correspondence by any means between you and Defendants for the past 10 years, including internal court emails and messages.

    4. Full disclosure and records of all real estate, car, boat, and other major properties owned by you in whole or part for the past 10 years, where they are located, and how they were purchased.

    5. Full disclosure and records of all businesses owned by you in whole or part in the past 10 years, where they are located, and how they were purchased.

    6. All child custody evaluations in the past 20 years in which you were involved. 7. All Court orders in the past 20 years concerning child custody, child abuse, adoption and

    termination proceedings in which you were involved. 8. All ethics and other complaints against you or submitted to you regarding Defendants in

    the past 20 years. 9. Disclosure of all lawsuits you have been involved in for the past 20 years. 10. All phone logs between you and other Defendants for the past 10 years. 11. All audio, video, and other recordings made by you of the Plaintiffs and/or of which they

    are in possession, for the past 10 years. 12. All audio, video, and other recordings of any child(ren) made by you and/or of which you

    are in possession, for the past 10 years. 13. All medical, dental, psychological, religious, and school records of D.C. and G.C. you

    have and/or to which you have access. If access is unattainable to you, state person(s) or entities who is/are in possession.

    14. All reports and data concerning D.C. and G.C. 15. Transcripts of all court proceedings for Bergen County Docket # FM-02-439-07. 16. Full disclosure of all organizations, programs, clubs, societies, institutions, politics, etc.

    to which you belong, attend, donate to, and/or otherwise participate, now and over the past 20 years (i.e. golf, Freemasons, political campaigns, etc.); the nature of which, where they are located, when they meet, when you attended, where and how they are funded.

    17. Full disclosure of any knowledge you have about the Defendants ownership of items as listed and as applicable above, such as properties and businesses they own or have owned in the past 10 years or documentation of which they are in possession or have access.

    ISSUED THIS 17th day of February, 2015 Designated Persons: _____________________________________ Rachel Alintoff Karin Wolf Private Attorney General