1. This lawsuit is against the above defendants for the City of New York Department of Finance’s ongoing and continuous violations of the 1st, 4th,, 5th, 9th and 14th Constitutional Amendments, Deprivation of Constitutional Rights and Privileges, 42 U. S . C. § 1983, Conspiracy to Depriving Persons of Equal Protection of the Laws, 42 U. S. C. § 1985, Intentional Infliction of Emotional Distress, Defamation, Negligence, Invasion of Privacy, willful, malicious, retaliatory, discriminatory, abusive and outrageous actions against citizens, as well as for violations of the New York General Business Laws section §349, et seq., Violations of the Telephone Consumer Protection Act (TCPA) 47 U.S.C. § 227 et seq., 47 C.F.R. § 64.1200(a)(2); for violations of applicable sections of the Fair Debt Collection Practices Act (FDCPA) 15 U.S.C. § 1692, and for violations of applicable sections of the ADAAA 2009.
2. Plaintiff Miriam Snyder brings this action against the defendants for their willingn