************************************
Rafael I. PINKHASOV PINCHAS,
Plaintiff,
v. Civil Action No.
WMN 01 CV 2758
Jerald M. JORDAN, AFFIDAVIT
Donalda K. AMMONS, In Opposition to
Motion
John M. LOVETT, to Strike and Dismiss
Defendants.
************************************
I, Rafael I. Pinkhasov Pinchas, being duly sworn, deposes and
says:
1. That I am a plaintiff and pro se in the above-captioned action. I make
this Affidavit in Opposition to defendants' Motion to Strike and Dismiss.
2. Defendants' Motion to Strike and Dismiss is a clear and vain attempt by
defendants in evading justice. By calling my Verified Complaint as a "rambling
complaint", defendants chose to utilize Rules 8 (a) and (e) and Rules 12 (b) and
(f) of the Federal Rules of Civil Procedure in order to strike and dismiss this
Complaint in its entirety.
3. Defendants even provided a misleading publicity about this ongoing
Complaint. On or about October 9, 2001, defendants, in order to garner sympathy
and support from the National Sports Associations - members of the CISS and from
the non-English- speaking members of the CISS Executive Committee, issued
communication to the world headlined as CISS Statement ( see Exhibit A ).
4. On that communication, defendants, among the other things, not only
called plaintiff's 39-page Verified Complaint as "a rambling complaint", but
also mentioned that such a complaint "contains too many inaccuracies to be
addressed point by point" and "that it is worth noting that many of the
allegations are completely unsupported and defy common sense."
5. Additionally, on that CISS Statement , defendants misled the world by
giving the false impression that the CISS as an organization is also as if a
party to this lawsuit.
6. Since defendants stated that my "pleadings do not state any claims upon
which relief can be granted nor does it contain any averments that are simple,
concise and direct", I am now accomodating defendants by submitting my 13-page
Amended Verified Complaint in a condensed, simple, concise and direct manner,
which in good faith specifically points out the main statement of charges and
claims and the relief sought by plaintiff.
WHEREFORE, plaintiff respectfully requests the following relief:
a) that this Court deny defendants' Motion to Strike and Dismiss;
b) for such other and further relief as this Court deems just and
proper.
Dated: October 26, 2001
Queens, New York
----------------------------
Rafael I. Pinkhasov Pinchas
Plaintiff and Pro se
To: Kelby N. Brick
Attorney for Defendants
Sworn to before me
this day of October, 2001
------------------------
Notary Public
================================================================================
THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND
***********************************
Rafael I. PINKHASOV PINCHAS,
Plaintiff,
AMENDED VERIFIED COMPLAINT
v. Civil Action No.:
WMN 01 CV 2758
Jerald M. JORDAN, Donalda K. AMMONS
and John M. LOVETT,
Defendants.
************************************
I, Plaintiff, presenting my Amended Verified Complaint, respectfully allege
the following:
1. I, Rafael I. Pinkhasov Pinchas ( "Pinchas", "plaintiff" ) is the former
Chairman of the Awards Commission of the International Committee of Sports for
the Deaf with my following residence addresses at 76-54 168 Street Hillcrest New
York 11366 USA and 6 Dadashev Kuchasi Tashkent 700015 The Republic of
Uzbekistan.
2. Upon information and belief, the International Committee of Sports for
the Deaf ( "CISS" ) is an international sports organization with its following
Home Office address at 814 Thayer Avenue Suite 350 Silver Spring Maryland 20910
USA.
3. Upon information and belief, Jerald M. Jordan ( "Jordan", "defendant" )
is the former President of the CISS and current CISS Honorary Member and Member
of the CISS Legal Commission with his following addresses at 814 Thayer Avenue
Suite 350 Silver Spring Maryland 20910 USA ( office ) and 826 Locust Drive West
River Maryland 20778 USA ( residence ).
4. Upon information and belief, Donalda K. Ammons ( "Ammons", "defendant" )
is the CISS Secretary General and Member of the CISS Legal Commission with her
following addresses at 814 Thayer Avenue Suite 350 Silver Spring Maryland 20910
USA ( office ) and 11617 Orchard Grove Road North Potomac Maryland 20878 USA (
residence ).
5. Upon information and belief, John M. Lovett ( " Lovett", "defendant" )
is the CISS President and Member of the CISS Legal Commission with his following
addresses at 814 Thayer Avenue Suite 350 Silver Spring Maryland 20910 USA (
office ) and 5/42 Wright Street McKinnon Victoria 3204 Australia ( residence ).
6. Like myself, the defendants in this action - Jordan, Ammons and Lovett -
are profoundly deaf individuals and during our business dealings the main modes
of our communication were the American Sign Language, English and the Gestuno,
which is the International Sign Language of the Deaf.
7. The main charges of this Verified Complaint against defendants
are as follows:
- Violation of the CISS Constitution Rules;
- Breach of Contract;
- Breach of Trust;
- Discrimination;
- Defamation of Character;
- Conspiracy;
- Invasion of Privacy.
8. On or about February 11, 2001, the Sport Organization of the Deaf in the
Republic of Uzbekistan, which is an affiliate to the CISS and which I am a
member in good standing, nominated my name as a candidate for the CISS Executive
Committee ( "CISS EC") member position for the 2001-2005 year term.
9. But, on July 21, 2001, at the 37th CISS Congress held at the Jolly Midas
Hotel 800 via Aurelio Rome, Italy, and in the presence of the delegates from
some 55 nations, Lovett, after the closed-door consultations with his
hand-picked and biased CISS Legal Commission members, abruptly removed my name
as a candidate for the CISS EC member position for the 2001-2005 term. This move
by Lovett was an unconstitutional and undemocratic one.
10. On July 29, 2001, the 37th CISS Congress delegates from 41 nations
signed a petition re: Unconstitutional Expulsion of Mr. Rafael I. Pinkhasov
Pinchas, Delegate of Uzbekistan, as a candidate for the 2001 to 2005 CISS
Executive Committee. This petition was handed to the CISS EC , including to
Lovett and Ammons. The petition cites the four rules of the CISS Constitution,
which Lovett violated regarding my candidacy for the CISS EC member position and
the petition also demands the reversal of the decision made by Lovett and free,
fair and democratic elections, in which Pinchas is allowed to participate as a
candidate. To date, neither Lovett nor the CISS EC took any action with this
petition.
11. After the end of the XIXth Deaflympic Summer Games, Lovett, in concert
with Ammons, decided to remove my name from the position of the Chairman of the
CISS Awards Commission. To date, neither Lovett nor Ammons nor the CISS EC
provided to me an explanation as to why I was removed from the position.
12. By denying me the opportunity to run for a CISS EC elective position,
the following acts were committed:
VIOLATION OF THE CISS CONSTITUTION RULES
Number A. Rule 10.4.2 ( All members of the Executive Committee
must be a deaf person fluent in international signs ).
Lovett's position: During the Pinchas election debate matter, he treated me as
an alien person or persona-non-grata to the CISS and the deaf sports movement at
the Congress floor premises; therefore, in his view, I was an unfit candidate
for the CISS EC position.
Fact: I am a very profoundly deaf person and wholly fluent in international
signs.
Argument: Everyone in the deaf sports world knows of my profound deafness
handicap as well as my fluency in the international sign language.
Number B. Rule 10.4.3 ( The Executive Committee shall consist of persons
who are members of the National Association of their country of
residence admitted to Full Membership by virtue of this
Constitution ).
Lovett's position: Provided the vaguely worded statement like "Pinchas, a New
York, America, resident". In addition, in order to "legitimize" his above
statement, he got a well-planned "supporting act" from an Australian
CISS
Congress delegate, David Peters - the only one delegate - to raise the issue of
the four foreign passports Pinchas possessed.
Facts: I own home residences in Uzbekistan and USA, therefore, I am a dual
resident. Whenever necessary, as a free human being and by having my
prerogative, I consider my residence in Uzbekistan as my primary one with the
mailing address with my name on it.
I was born, reared and educated there. My familial roots are in Uzbekistan. I
have the two citizenships and the two foreign passports. Since the National
Sports Association of Uzbekistan nominated me for the position, I was viewed as
a resident of Uzbekistan and Uzbekistan's candidate for the CISS EC position. In
1997, the CISS had no problem, when I was nominated for the CISS Treasury
position with the support received from the same National Sports Association of
Uzbekistan, in which I was automatically viewed as a resident of Uzbekistan.
Arguments:
Number One - There was no problem for the CISS ( and for Jordan, when he began
serving on the CISS EC in 1967 ) with Dragoljub Vukotic who had his mixed
residence/citizenship status ( Vukotic had the two homes at Trieste, Italy, and
Belgrade, Yugoslavia ), while he was serving as the CISS EC member ( between
1953 and 1965 ) and the CISS Vice President ( between 1967 and 1973).
By the way, Vukotic also was the
President of the World Federation of the Deaf between1955 and 1983;
Number Two - There was no problem for the CISS ( and for both Jordan and Lovett,
who served as the CISS President and First Vice President, respectively, and
Ammons, who was a USA delegate in 1985 ) with Wai-on-Light, a Hong Kong citizen
with his residence at Los Angeles, USA, who was a CISS EC member candidate
during the elections held at the 28th CISS Congress in Los Angeles, USA, in
1985.By the way, by obtaining the insufficient number of votes,Wai-on-Light lost
the election ).
Number Three - There was no problem for the CISS ( and for both Jordan and
Lovett, who still served as the CISS President and First Vice President,
respectively, and Ammons, who was a USA delegate in 1993) with Ted Staroyiannis
with his Greece/USA residence/citizenship status when he ran as a candidate for
the CISS EC member position at the 33rd CISS Congress in Sofia, Bulgaria, in
1993. By the way, by collecting the inadequate number of votes, Staroyiannis
lost the election.
Number Four - There was no problem for the CISS ( and for the troika of Jordan,
Lovett and Ammons in the years of 1991-2001), when they chose the three persons
with their respective dual residence/citizenship status for the CISS Technical
Director positions in Ice Hockey ( David Stewart of Canada/USA ), Athletics (
Emmanuil Slutsky of Israel/Russia ) and Wrestling ( Ilya Cherches of
Russia/Ukraine ).
Number Five - In the non-deaf and hearing sports world a) there are many members
of the International Olympic Committee ( briefly known as the IOC ) who are in
possession of the mixed residence/citizenship status ( for example, Jean Claude
Killy of France/Switz- erland, Alexander Popov of Russia/Australia, Vladimir
Smirnov of Kazakhstan/ Sweden, Sergei Bubka of Ukraine/Monaco, Alex Gilady of
Israel/USA and Olaf Koss of Norway/Canada ); b) there are also a number of the
high-ranking officials in the various International Sports Federations who are
the dual residents/citizens ( for instance, the President of the International
Ice Hockey Federation Rene Fasel of Switzerland/Spain and the Secretary General
of the International Basketball Federation Borislav Stankovic of
Yugoslavia/Germany).
Number Six - In an unrelated matter, but for this Court to get an idea as to
what kind of people attended the past Deaflympic Summer Games in 1993,1997 and
2001; there was a number of athletes, delegates,and officials - deaf and hearing
- who had the mixed residence/citizenship status and they represented the
country of their own choice with the approval of their National Sports
Association - a member of the CISS.
Number Seven - There was no problem for Lovett and Ammons when I was nominated
for the CISS Treasury position in October 20, 1997, as was described above. But
there was problem for both Lovett and Ammons in 2001 when they were opposing my
candidacy for the CISS EC. Thus, Lovett and Ammons took an ironically
double-standard approach with me: on the one side, in 1997 they did not oppose
my being nominated for the high-ranking CISS EC position - the Treasurer, while,
on the other side, in 2001, they were vehemently against my nomination for the
low-ranking position of the CISS EC member. Moreover, there were no problems for
the CISS, Lovett and Ammons who did nothing to prevent me for my being as an
Uzbekistani delegate at the 1999 and 2001 CISS Congresses as well as
Uzbekistan's Chief of Mission at the just-ended XIX Deaflympic Summer Games at
Rome, Italy.
Number C Rule 10.4.4. ( Only one member per National Associ- ation shall be
elected to the Executive Committee).
Lovett's position: Tried to mesmerize the many non-English-speaking Congress
delegates by giving the impression that " Pinchas was as if both a USA citizen
and a member of the USA-based National Sports Association."
This way, Lovett created the false impression that there might be as if the two
CISS EC members from the USA ( Ammons and myself ) which would be in violation
of the above rule.
Facts: Although I am a USA citizen, I was not a member of the National Sports
Association in the USA. By July 21, 2001, I was and am still a member of the
National Sports Association of Uzbekistan.
Arguments: Lovett showed his total disrespect and ignorance for the National
Sports Association of Uzbekistan, when its President Mukim Karimov,wrote a long
letter to Chou Tung, the President of the Asia-Pacific Deaf Sports Confederation
and CISS EC member, on July 4, 2001. That letter was copied and sent to Lovett
on July 4, 2001 as well. On that letter re:
the issue of the Pinchas CISS EC candidacy, Karimov wrote the following ( here
are the excerpts ):
"We receive the info that some people at the CISS are unhappy that
our organization nominated our nation's native and proud son, Mr.
Pinchas, as a candidate for the CISS EC membership".
"We would like to advise you that the nomination of Mr. Pinchas for
this position is a purely internal matter. Therefore, in the
interests of free democratic and fair election contest, you and the
CISS people, if any, can not tell or influence us to tell Mr.
Pinchas not to run for the position!" "I want also to tell you that
Mr. Pinchas owns property residences in the USA and Uzbekistan as
well as he has the dual citizenship status ( are you aware of the
fact that there are many IOC members who have the dual citizenships
and residences? ). In addition, unlike the deaf sports leaders, Mr.
Pinchas is a financially self-sufficient individual as some of our
organization's activities are financed from his own pocket." "Mr.
Pinchas is not only a highly-revered member of our deaf community,
but he is also deeply and widely respected among the many top
governmental and National Olympic Committee officials in our country
( for example, recently, Mr. Pinchas received a gold medal from our
National Minister of Sports )." "Additionally, Mr. Pinchas' past
professional background - positive or negative one - has nothing to
do with sports or his ongoing CISS EC candidacy aspirations."
"Therefore, our organization sincerely hopes that politics, personal
grudge and blackmail among certain members against Mr. Pinchas will
have no place in Mr. Pinchas' current pursuit for the CISS EC
position."
By reading the above eloquently-written letter, Lovett committed an abusive
act as the CISS President by interfering into the internal affairs on an
independent National Sports Association of Uzbekistan. Namely, Lovett completely
neglected and disrespected Karimov's words, when he wrote to say that "the
nomination of Mr. Pinchas is a purely internal matter".
NUMBER D Rule 15 Dispute Resolution ( If any dispute arises
concerning the construction of this Constitution or any matter
arising from it or any disciplinary matters, then such a dispute
will solely and exclusively be resolved by the Congress. The
decision of the Congress will be final and binding on the parties
and it is agreed that neither party will institute or maintain
proceedings in any court or tribunal beyond the Congress ).
Lovett's position: Completely ignored and disregarded this Rule when the Pinchas
CISS EC candidacy matter was brought up.
Facts: The Congress delegates, including the delegation of Uzbekistan, asked
Lovett to let the Congress decide the Pinchas matter itself, not Lovett
alone.Lovett also ignored the petition signed by the delegates from 41 nations
and delivered to Lovett and entire CISS EC members on July 29,2001.
Arguments: In the past the many controversial issues - one of them, the recent
Turkish- Norwegian CISS membership suspension - were decided by the Congress
delegates. Another instance was on March 7, 1999, when a petition - to overrule
the CISS EC decision to increase the Games athlete/official participation fee to
$50.00 from $15.00 - was accepted, debated and voted at the Congress, in which,
afterward, the $50.00 fee proposal became a moot.
Thus, the CISS Legal Commission members, including Lovett, Ammons and Jordan (
all these three persons, by the way, lack the proper legal education and
professional legal training), are not the "owners" or "proprietors" of the CISS,
but it is the Congress and its delegates who own the CISS.
13. Besides the Violation of the CISS Constitution Rules, here are the six
different main charges against Lovett, Ammons and Jordan on this Verified
Complaint -
BREACH OF CONTRACT by
Lovett: When I became the official Chairman of the CISS Awards Commission
in 1997, Lovett and I made a good-faith agreement that anything related to the
activities of my Awards Commission ( i.e.,the annual Selections of the World
Male and Female Athlete of the Year and the once-a-lifetime Selections of the
Deaflympic Games Athlete of the Century and the Deaf Olympian of the Century )
Lovett was obliged to consult me first and in advance. But Lovett did not keep
that agreement. What Lovett did was these:
a) the trophies for the 1999 and 2000 World Male and Female Athlete of
the Year Award winners were purchased by Ammons ( not by Renzo Corti, the
CISS
Vice President, as was previously agreed );
b) Lovett went ahead, without my advance knowledge and agreement, with the
preparation and the publication of the diplomas ( some of them printed
erroneously ) intended for the finalists of the Deaflympic Games Athlete of the
Century and the Deaf Olympian of the Century; c) in the new and just-released
2000 CISS Year Book ( pages 39 through 51 ), Lovett without my advance
knowledge, permission and consent, under my name's authorship, untruthfully and
vaguely wrote to say that "the top ten deaf athletes were judged by a panel of
15 members drawn from the current CISS EC and a selection of former and present
national deaf sports leaders."; d) Lovett, aided by Ammons,did not treat me in
my capacity as the CISS Awards Commission Chairman accordingly: he refused to
cover the accomodations during my stay at Rome; e) Lovett removed my name as the
CISS Awards Commission Chairman without providing a validly justified reason.
Ammons: In my role as a writer, Ammons and I had a basic agreement that anything
related to my writing work and its publishing, she would consult me in advance.
But what Ammons did was these:
a) between 1995 and 2001 I contributed my various stories to the CISS Bulletin,
in which Ammons was its Editor. Ammons , without my knowledge, advance
consultation and prior fact verification, published a number of my stories in
the Bulletin, which were cut or altered by her and which were, as a result,
flooded with errors and misfacts; b) Ammons, for the still unknown reason, did
not include me, a leading CISS Bulletin contributing writer and a key authority
on the history of the Deaflympic Games, as part of the 2001 CISS Media Team to
cover the XIXth Deaflympic Summer Games at Rome. c) in addition, twice Ammons or
some one under her direction at the CISS Home Office, forged my signature on the
CISS stationery, without my advance knowledge, permission and consent.
Jordan: He broke the two promises made to me in 1979, when I was appointed as
one of the three members of the CISS World Records Commission in Athletics,
Swimming and Shooting:
a) that before elevating or removing me from the CISS-appointed position Jordan
would consult me first, but he failed to fulfil that obligation; b) Jordan
advised me that as a CISS Commission officer I would receive the the customary
free-of-charge meals and lodgings during the 1981 Deaflympic Games at Cologne,
Germany, but this was not done by Jordan.
BREACH OF TRUST by
Lovett: By cosmetically posing as my "genuine and trusted deaf friend" and to my
much dismay and infuriation, Lovett did the following acts:
a) he disclosed the contents of my May 28, 2000 six-page personal and
confidential letter, which was addressed to him only, to the outsiders, i.e., to
a number of the CISS EC and non-CISS EC members;
b) he committed a strategic trick on me: on April 18, 2001, he sent to me his
one-page e-mail letter, in which he warned me that " at the Congress, some
foreign delegates (note the word "delegates" in plural ) will raise the
Securities Exchange Commission ( "SEC" ) court case against me". In my whole
heart, per Lovett's warning via that April 18,2001, e-mail message, I believed (
in case Lovett wanted to act against me ) that at the Rome Congress my SEC case
matter would be brought up, but, instead, at the Congress, Lovett and his
accomplice, David Peters- a lone delegate, raised very different matters against
me - the issues of my residence and my possession of the four foreign passports;
c) he, also on that April 18, 2001 e-mail letter, lied to me when he said that
"none of the them ( the CISS EC members ) were supportive of my candidature" for
the CISS EC.
Ammons: As the CISS Secretary General , Ammons committed the two unethical acts
by abusing her international position and by breaking the confidentiality rule:
a) she released my name as a CISS EC candidate to the outsiders, including to
Jordan, immediately after a faxed message from the Uzbekistani National Sport
Association arrived to the CISS Home Office in Silver Spring, Maryland, on or
about February 11, 2001;
b) on February 23, 2001, the President of the Russian Deaf Sport Union, Valery
Rukhledev of Moscow, Russia, visited the CISS Home Office and there Ammons,
among the other things, questioned Rukhledev as to why Nikolai Klimov , the
failed 1997 CISS EC member candidate from Russia, did not re-submit his
candidacy for this year's CISS EC member election considerations as the deadline
for the CISS EC candidacy submission was February 15, 2001.
DISCRIMINATION
Because I came from the remote and Moslem-dominated nation of Uzbekistan
and because I derive from a very culturally and linguistically different
background Lovett, Ammons and Jordan, who often love to tell everyone that they
are the lifelong fighters and advocates for the equal and just rights of every
deaf person in the world, made every effort to prevent me to get "a foothold" to
the top CISS establishment. Let me cite the following facts:
a) as an aspiring CISS EC member candidate, my record spoke for itself: since
the age of 13, I invested over 33 years of my comprehensive service to the deaf
sports movement; I was probably the only one candidate with such an unparalleled
and unmatched record compared with the other candidates.
Because I had a real record of results in the areas of sports, journalism,
multilingualism, history, administration, Lovett, aided by Ammons and Jordan and
by neglecting of the much-needed qualified man power gap for the CISS
administration, still very discriminatedly and prejudicedly chose to degradably
undermine me and my credentials by dumping me as "an ineligible candidate" at
Rome; b) Lovett committed an act of discrimination by uttering the following
words on his April 18, 2001, communication to me: "I am not sure what else you
could contribute to the CISS as a member of the CISS Executive from the general
perspective."
While defendant Lovett belittled my credentials as a versatile deaf individual
and able sports administrator and leader, another defendant Ammons gave a
contradictory view of me few weeks before the start of the 37th CISS Congress,
in which I was one of the six declared candidates for the CISS EC member
position:
"No question you are qualified with your extensive knowledge of sports and deaf
communities around the world..." ;
c) Lovett , Ammons and Jordan had also biasedly determined that the CISS should
be led and controlled by the persons whose primary language at birth was
English; d) in the views of Lovett, Ammons and Jordan, my first name of Rafael
is a Spanish-sounding one, while my Russian-sounding surname is Pinkhasov
Pinchas - both of these names have unappealingly-sounding and hard to spell or
pronounce names to this troika;
Thus, for the above reasons, Lovett, Ammons and Jordan, by behaving as if they
were the "real owners of the CISS", discriminatedly decided that the executive
position in the CISS was not a right and appropriate place for me, a native of
Uzbekistan and a deaf person whose mother tongue was not English.
DEFAMATION OF CHARACTER by
Lovett:
a) he was one of the two individuals to disseminate the negatively reported SEC
case about me which is placed on the worldwide internet system; b) by
discrediting my name, Lovett also coached his long-time friend, David Peters, to
bring up the groundless issue and slanderous charge against me - my so-called
using of 4 foreign passports - at the Congress floor podium on July 21, 2001.
Ammons:
a) like Lovett, she was covertly and overtly engaged in distributing the
negative SEC case about me to a certain number of individuals in 2000 and 2001.
Jordan:
a) when he was the CISS President, he used the door-closed CISS EC meetings
between 1981 and 1986, as a forum to utter the negative things about me among
the CISS EC members;
b) under Jordan's direction, the CISS Bulletin published the negative and
libelous things about me on its various issues between the years of 1982 and
1986.
CONSPIRACY
Defendants committed the following acts of conspiracy:
a) in order to co-conspirationally strengthen personal crusade against me and to
prevent me from being elected to the CISS EC position, Jordan was the one to
skillfully and sophisticatedly mastermind my schism with Lovett and Ammons
before the elections at the 37th CISS Congress in Rome; b) Jordan, Ammons and
Lovett along with David Peters, Rebecca Adam and Tiffany Granfors were -
directly and indirectly - engaged in an act of conspiracy by participating in my
aborted 2001 CISS EC election scheme. David Peters is from Melbourne, Australia,
and he was his country's delegate at the 37th CISS Congress. Rebecca Adam is
from Sydney, Australia, and she is one of the four members of the CISS Legal
Commission, while Tiffany Granfors is an administrative assistant to Ammons at
the CISS Home Office in Silver Spring, Maryland. Although the three - Peters,
Adam and Granfors - are not named as defendants in my Verified Complaint, it
will be my intention to bring these three individuals as the witnesses at the
coming trial.
In addition, an obvious and fresh example of the act of conspiracy by defendants
is that for this Verified Complaint all three defendants hired one and same
attorney in spite of the facts that defendants are not related to each other
familially and each defendant lives in different location.
INVASION OF PRIVACY
Lovett was one of the three defendants on this suit who visited and stayed at my
home residence in 1996. While a visit by Lovett to my family residence was a
strictly private matter, Lovett irresponsibly and unethically shared such a
private visit and the doings and goings inside of my family life, including my
professional work as a stockbroker and the legal problems I had with the
brokerage industry officials, with the outsiders: Jordan, Ammons and Rudolf
Gast, a former CISS EC member from Germany.
By supporting my all of the above-mentioned charges, it will be my
intention that additional evidence - the documentary one and by live witness
appearance - will be presented during the trial.
14. Because of the acts mentioned on the above Paragraphs, defendants
committed massive improperties against plaintiff.
15. In order to prepare and submitt this Verified Complaint, I have been
compelled to expend a great deal of my time, my money and my energy to carry on
my case as well as to present this Verified Complaint.
16. As a result of the foregoing, I have been damaged as follows:
-loss of reputation
-loss of health
-loss of normal livelihood.
17. I also seek judgment for the reasonable attorney's fees, the costs of
utilizing the services of sign language interpreters, notetakers, witnesses,
mail, phone, travel, library research and visits for information to the court
offices. Additionally, my family and I suffered severe emotional trauma and
distress caused by defendants' wrongful and irresponsible acts.
18. Because of the foregoing facts, I request an award of the total damage,
including punitive, be assessed against defendants individually, jointly and
severally in the amount of $2,500,000.00.
19. I also seek the Court for the imposition of whatever other civil
stanctions may be deemed proper and appropriate to levy against each defendant.
20. I, as a plaintiff, respectfully request a trial to be held in this
Court to present my case. I will be attended by a sign language interpreter, a
notetaker and numerous individuals who will act as my witnesses.
Dated: October 26, 2001
Queens, New York,USA
------------------------------
Rafael I. Pinkhasov Pinchas
Plaintiff and Pro Se
To: Kelby N. Brick
Attorney for Defendants
Sworn to before me
this day of October, 2001
-----------------------
Notary Public
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