LIPSHIE, PC appeared as attorneys in this action, and created unfounded legal sentences to subterfuge law, wherein it is not the law.
97. If the defense be that the act was not willful, the burden shall be on the Plaintiff to prove that they did not know that there was error in their falsified affidavit of service and non standing complaint. Any person guilty of falsely preparing any book, paper, record, instrument in writing, or other matter or thing, with intent to produce it, or allow it to be produced as genuine upon any trial, proceeding or inquiry whatever, authorized by law, SHALL BE GUILTY OF A FELONY. See NYPL 75.35 offering a false instrument for filing in the first degree; 175.40 issuing a false certificate.
98. In this case the specific subject matter jurisdictional failings are present: no contract, no verification, fraud committed in the procurement of jurisdiction, Fraud upon the court, violation of due process, no justifiable issue is presented to the court through proper pleadings, no independent basis for liability, no cognizable cause of action against alleged, Defendant Miriam Snyder. When there is a jurisdictional failing appearing on the face of the record, the matter is void, subject to dismissal with damages. Please see exhibits 7 and 8 which are NYS court decisions confirming jurisdictional failings.
99. Plaintiff has placed no facts on the record. No fact appears on record whether by verification, deposition, admission; answer to interrogatory, or by affidavit to support the complaint of plaintiff. Documents proffered by Plaintiffs are unverified, out-of-date, irrelevant, and inadmissible. The record shows that affiant and alleged Defendant, Miriam Snyder has stated that material facts to which there are substantial Plaintiff errors, and such errors and issues needed to be addressed before enjoining the courts.
100.
It is well stated that statements of counsel of alleged facts are not sufficient to establish
facts for its client; counsel cannot testify and represent its client in the same proceeding.
101.
I hereby claim the Due Process right to have findings of Fact and Conclusion of Law
included and in support of any Order of this Court.
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