UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

---------------------------------------------------------------------------------X

CIVIL ACTION NO.

JACOB TEITELBAUM, individually and as father to

CHILD A and CHILD B,

PLAINTIFF

-against-

COUNTY ATTY. DAVID LEE DARWIN; ATTY. REBECCA

BALDWIN MONTELLO; ATTY. GREGG D. WEINSTOCK;

ATTY. JEFFREY B. SILER; ATTY. TERENCE S. HANNIGAN;

ATTY. PATRICK T. BURKE; HON. VINCENT L. BRICCETTI;

JUDA KATZ; CHAYA KATZ; JOEL TENNENBAUM;

BLUMA TENNENBAUM; DAVID RUBENSTEIN; KIRYAS

JOEL COMMUNITY AMBULANCE CORPORATION;

ATTY. MARIA A. PATRIZIO; CHILDREN'S RIGHTS

SOCIETY, INC; ATTY. KIM PAVLOVIC; ATTY JOHN

FRANCIS X. BURKE; COUNTY OF ORANGE;

CHRISTINE BRUNET; ATTY. STEPHANIE BAZILE;

DAVID HOLLANDER; MIRIAM TEITELBAUM;

JOHN DOES 1 THROUGH 95; JANE DOES 1 THROUGH 20,

DEFENDANTS

COMPLAINT

JURY TRIAL DEMANDED 

-----------------------------------------------------------------------------------X

Plaintiff JACOB TEITELBAUM, appearing Pro Se, by way of complaint against the

Defendants respectfully alleges as follows:

  1

NATURE OF COMPLAINT

1. Plaintiff is a resident in a Hasidic, ultra-Orthodox, closely-knit community (hereinafter

referred to as the “community”). In 2010, Plaintiff got involved in a religious campaign

against forced divorces that have been taking place through the use of kidnapping within

the community.

2. Certain people in the community disagreed with the religious campaign. They entered

into a conspiracy with Defendant Orange County, a State actor, and others outside the

community, with an objective to unlawfully stop Plaintiff from participating in the

religious campaign. In pursuance of the conspiracy, Plaintiff has constantly been

subjected to severe terrorization and intimidation by certain individuals and

establishments - some of whom are named herein as Defendants - acting in collusion with

and/or with the tacit support of Defendant Orange County.

3. To further the object of the conspiracy, aforesaid individuals and establishments, acting

in concert and collaboration with each other and separately, as well as with the

connivance of Defendant Orange County, not only subjected Plaintiff to cruel, inhuman

and degrading treatment but also used the State machinery directly and/or indirectly, and

abused the process of law, to illegally deprive Plaintiff of his Fundamental Rights granted

to him by the U.S. Constitution.

4. On or about April 11th, 2012, Plaintiff filed in Federal District Court an action, entitled

Teitelbaum v. Katz et al, 12-CV-2858 (hereinafter referred to as the “original action”),

against some of the individuals and establishments referred to above, as well as Orange

County (hereinafter collectively referred to as the “original Defendants”), to seek

  2

protection from the harassment, intimidation, terrorization, and violation of his civil

rights he had been suffering at the hands of the original Defendants.

5. As the original complaint alleged, Plaintiff was subjected to severe intimidation,

harassment, and terror; his freedom was unlawfully taken away; his family was broken

up; and his children taken away; all by the original Defendants in pursuance of aforesaid

conspiracy, forcing him to live under constant fear, trauma and emotional turmoil,

caused by the continued and ongoing terror they unleashed upon him with a common

objective to unlawfully deprive him of his Fundamental Constitutional Rights, in order to

stop him from participating in aforementioned religious campaign.

6. After filing the original action, the previously ongoing harassment, intimidation and

terrorization of Plaintiff was renewed with increased intensity by the original Defendants

in connivance with some other parties, who along with original Defendants are named as

Defendants in this complaint, and it was targeted to stop – (a) Plaintiff’s original action,

(b) his access to court, and (c) his involvement in aforesaid religious campaign. As a

result, Plaintiff’s children were terminated from him, and he was pushed into a destitute,

homeless situation, without normal living conditions.

7. Plaintiff even informed Defendant Judge Briccetti; i.e., presiding judge of the District

Court where the original action had been filed, about his ongoing harassment,

intimidation and terrorization aimed at silencing his original action, and curtailing his

ability to gain ultimate protection from the said Court. Initially, Defendant Judge

Briccetti acted to stop his other co-Defendants from their evil designs, but once the

Defendant Kiryas Joel Community Ambulance Corporation, in collusion with other

Defendants; namely, County Attorney David Lee Darwin, Attorney Rebecca Baldwin

  3

Montello, Attorney Gregg D. Weinstock, Attorney Jeffrey B. Siler, Attorney Terence S.

Hannigan, Attorney Patrick T. Burke, along with the original Defendants, by misusing

the huge political influence wielded by the community of Kiryas Joel Village and its

leaders, managed to establish a connection with Defendant Judge Briccetti, the latter

backed off from stopping the Defendants, and became biased against Plaintiff.

8. Later, Defendant Judge Briccetti, acting under extraneous influence, not only participated

in furthering the object of aforesaid conspiracy, but also stopped performing his neutral

judicial function, and eventually issued a Memorandum of Decision and Order on July

2nd, 2013 (hereinafter referred to as the “July 2nd, 2013 Order”) whereby he

unceremoniously dismissed the original action with prejudice, after allowing the original

Defendants’ Motions to Dismiss and rejecting the Plaintiff’s Motions; including, his

Motion to file Modified Amended Complaint/Supplemental Pleadings, without giving

Plaintiff a fair opportunity of being heard.

9. As such, Defendant Judge Briccetti’s July 2nd, 2013 Order, whose true and correct copy

is attached hereto as Exhibit ‘A’, is, in fact, an order produced by committing extrinsic

fraud on Court; therefore, it is void, non est, and is liable to be set aside.

10. Because the July 2nd, 2013 Order is vitiated by fraud, in which Judge Briccetti himself is

involved, and because Plaintiff was never given the rightful opportunity of being heard in

the original action, Plaintiff has no other remedy at law than to invoke the provisions of

Rule 60(d) of Federal Rules of Civil Procedure by bringing this independent action in this

Court to seek protection of his Fundamental Rights that are being violated by Defendants.

  4

11. This complaint sets forth a clear pattern of Plaintiff being targeted, intimidated, and

terrorized in pursuance of a deliberate conspiracy among Defendants. It sets forth a clear

meeting of the minds of all Defendants, including Defendant Orange County, a State

actor. Plaintiff sets forth his claims under the provisions of 42 U.S.C. §§ 1983 and 1985

for various deprivations of his Fundamental Constitutional Rights by Defendants, and

under Rule 60(d) of FRCP for filing this complaint as an independent action following

dismissal of the original action by an order produced by fraud on the Court.

JURISDICTION AND VENUE

12. Plaintiff Jacob Teitelbaum, Child A, and Child B are residents of the Town of Monroe,

County of Orange, State of New York.

13. Upon information and belief all of the above named Defendants are residents of, or

conduct business in, the County of Orange, State of New York.

14. This action is brought pursuant, but not limited, to Federal Question, 28 U.S.C. § 1331

for violations of the Fundamental Rights granted to Plaintiff by constitutional

amendments, and pursuant to the State as well as Federal Statutes.

15. This Court also has jurisdiction over this matter pursuant, but not limited, to 42 U.S.C.

§§ 1983 and 1985, besides Rule 60(d) of Federal Rules of Civil Procedure.

16. Venue is Southern District of the United States District Court of New York, since the

events alleged herein happened in Orange or Westchester County, New York, and

Plaintiff as well as Defendants are residing, and/or conducting business, in Orange or

Westchester County, New York.

PARTIES IN THIS COMPLAINT

  5

17. Plaintiff Jacob Teitelbaum, is an individual over the age of 18 years, and is a citizen of

the United States of America, residing at 20 Getzel Berger Boulevard, Unit 104, Monroe,

New York, 10950. Plaintiff Jacob Teitelbaum is representing himself pro se, and is

hereinafter referred to as “Plaintiff”.

a. Plaintiff Child “A”, represented by Plaintiff Jacob Teitelbaum, is an individual, a

minor child, and a resident of the State of New York, and is hereinafter referred to

as “Child ‘A’”.

b. Plaintiff Child “B”, represented by Plaintiff Jacob Teitelbaum, is an individual, a

minor child, and a resident of the State of New York, and is hereinafter referred to

as “Child ‘B’”.

18. Defendant County Attorney David Lee Darwin holds his primary office at 15 Matthews

Street, Suite 305, Goshen, New York, 10924. This Defendant acted as attorney for

Defendant’s County of Orange, Attorney Stephanie Bazile, and Social Caseworker

Christine Brunet in the original action. This Defendant may be served a summons at the

Orange County Law Department, which is located at 15 Matthews Street, Suite 305,

Goshen, New York, 10924.

19. Defendant Attorney Rebecca Baldwin Montello holds her primary office at One Corwin

Court, P.O. Box 1479, Newburgh, New York, 12550. This Defendant acted as attorney

for Defendant’s Children’s Rights Society Inc., and Attorney Kim Pavlovic in the

original action. This Defendant may be served a summons at One Corwin Court, P.O.

Box 1479, Newburgh, New York, 12550.

20. Defendant Attorney Gregg D. Weinstock holds his primary office at 432 Park Avenue

South, 9th Floor New York, New York, 10016. This Defendant acted as attorney for

  6

Defendant Attorney Maria A. Patrizio in the original action. This Defendant may be

served a summons at 432 Park Avenue South, 9th Floor, New York, New York, 10016.

21. Defendant Attorney Jeffrey B. Siler holds his primary office at 1399 Franklin Ave, Suite

103, Garden City, NY 11530. This Defendant acted as attorney for Defendant Kiryas Joel

Community Ambulance Corporation in the original action. This Defendant may be served

a summons at 1399 Franklin Ave, Suite 103, Garden City, New York, 11530.

22. Defendant Attorney Terence S. Hannigan holds his primary office at 1881 Western

Avenue, Suite 140, Albany, New York, 12203. This Defendant acted as attorney for

Defendant David Rubenstein in the original action. This Defendant may be served a

summons at 1881 Western Avenue, Suite 140, Suite 140, Albany, New York, 12203.

23. Defendant Attorney Patrick T. Burke holds his primary office at 40 Mathews Street, Suite

209, P.O.B. 216, Goshen, New York, 10924. This Defendant acted as attorney for

Defendant Attorney John Francis X. Burke in the original action. This Defendant may be

served a summons at the location specified above.

24. Defendant United States District Court Judge Vincent L. Briccetti holds his primary

office at 300 Quarropas Street, White Plains, New York, 10601. This Defendant acted as

Judge in the proceedings in the original action. This Defendant may be served a summons

through the Clerk of the Southern District of New York, Ruby J. Krajick, at her place of

business located at 300 Quarropas Street, White Plains, New York, 10601. Hereinafter,

this Defendant will be referred to as “Judge Briccetti”.

25. Defendant Juda Katz is a New York state resident located at 22 Hayes Court, Unit 201,

Kiryas Joel, New York. Defendant Juda Katz is the brother-in-law to Defendant Miriam

Teitelbaum and was once a foster parent to Child ‘A’.

  7

26. Defendant Chaya Katz is a New York State resident located at 22 Hayes Court, Unit 201,

Kiryas Joel, New York. Defendant Chaya Katz is sister to Defendant Miriam Teitelbaum

and was once a foster parent to Child ‘A’.

27. Defendant Joel Tennenbaum is a New York state resident located at 16 Lizensk

Boulevard, Unit 102, Kiryas Joel, New York. Defendant Joel Tennenbaum is brother to

Defendant Miriam Teitelbaum and foster parent to Plaintiff’s children.

28. Defendant Bluma Tennenbaum is a New York state resident located at 16 Lizensk

Boulevard, Unit 102, Kiryas Joel, New York. She is the wife of Joel Tennenbaum, sister-

in-law to Defendant Miriam Teitelbaum, and foster parent to Plaintiff’s children.

29. Defendant David Rubenstein is a New York state resident located at 4 Lamberg Ct., Unit

301, Kiryas Joel, New York. This Defendant is a key member of Hatzalah Emergency

Medical Service (EMS), also known as Kiryas Joel Community Ambulance Corporation.

30. Defendant Kiryas Joel Community Ambulance Corporation of Kiryas Joel, New York,

upon information and belief is a New York state non-profit organization that operates at

times interstate. Its primary location is 51 Forest Road, Village of Kiryas Joel, New York.

Hereinafter, this Defendant will be referred to as “Hatzalah EMS”.

31. Defendant Attorney Maria A. Patrizio acted as attorney for Defendant Miriam

Teitelbaum in the Family Court Proceedings. Defendant Attorney Patrizio may be served

a summons at her primary office, which is located at 2 Court lane, P.O. Box 328, Goshen,

New York, 10924. Hereinafter, this Defendant will be referred to as “Attorney Patrizio”.

32. Defendant Children’s Rights Society Inc. has its primary place of business located at 213

West Main St., P.O. Box 1002, Goshen, New York, 10924. This Defendant acted through

its agent, Attorney Kim Pavlovic, as the law guardian for Plaintiff’s children; i.e., Child

  8

‘A’ and Child ‘B’. This Defendant may be served a summons at their primary place of

business, 213 West Main St., Goshen, New York, 10924. Hereinafter, this Defendant will

be referred to as “Attorney Pavlovic”.

33. Defendant Attorney John Francis X. Burke holds his primary office at 210 Main Street,

P.O. Box 943, Goshen, New York, 10924. This Defendant acted as attorney for Plaintiff

in the Family Court proceedings. Defendant Attorney Burke may be served a summons at

the location specified above. Hereinafter, this Defendant will be referred to as “Attorney

Burke”.

34. Defendant County of Orange, New York is a New York government entity located at 14

Scotchtown Avenue, 3rd Floor, Goshen, New York, 10924. This Defendant acted through

its agent’s Attorney Stephanie Bazile and Social Caseworker Christine Brunet, and John

or Jane Does, Department of Social Services of Orange County, and Child Protective

Services. This Defendant may be served a summons at the Orange County Law

Department, Family Law Division, which is located at 14 Scotchtown Avenue, 3rd Floor,

Goshen, New York, 10924. Hereinafter, Defendant County of Orange, will be referred to

as “Orange County”, or “DSS”, or “CPS”.

35. Defendant Attorney Stephanie Bazile holds his primary office at 14 Scotchtown Avenue,

3rd Floor, Goshen, New York, 10924.

36. Defendant Christine Brunet holds his primary office at 14 Scotchtown Avenue, 3rd Floor,

Goshen, New York, 10924.

37. Defendant David Hollander is a New York state resident located at 1 Chernobyl Court

Unit 102 Monroe, New York, 10950

  9

38. Defendant Miriam Teitelbaum is Plaintiff's wife, and is a New York State resident

located at 20 Getzel Berger Boulevard, Unit 104 Monroe, New York, 10950. Hereinafter,

this Defendant will sometimes also be referred to as “Miriam”, or “Plaintiff’s wife”.

39. Defendants John Does 1 through 95 and Jane Does 1 through 20 have, at all times

relevant herein, been part of the conspiracy against Plaintiff as of about March 2010 until

now.

NON-PARTIES

40. Ben Friedman, a friend of Plaintiff, is a non-party who was witness to events described in

the Statement of Facts.

41. Meir Tennenbaum is the father of Defendant Miriam Teitelbaum.

42. Mrs. Tennenbaum is the mother of Defendant Miriam Teitelbaum.

43. Rabbi Dr. Price is the Plaintiff’s psychiatrist.

STATEMENT OF FACTS

EVENTS BEFORE FILING OF ORIGINAL ACTION

44. On or about March, 2010, Plaintiff and his friend Mr. Ben Friedman got involved in a

religious campaign against forced divorces that had been taking place through the use of

illegal kidnapping in the community.

45. In pursuance of the conspiracy referred to hereinabove, on or about April 14th, 2010,

Defendant Chaya Katz arranged with Defendant Miriam Teitelbaum for the Defendant

Chaya Katz’s children to visit Plaintiff’s home in order to make an exchange of personal

items. The exchange was to occur while the Defendant Miriam Teitelbaum was going to

Mikveh (Ritual Bath).

  10

46. Defendant Chaya Katz’s children came to the house as previously arranged in order to

exchange the items. Not suspecting anything, Plaintiff allowed Defendant Katz’s children

into the house. Meanwhile, Plaintiff stepped outside the house with Child ‘A’. Child ‘B’

was sleeping in his crib at that time, and thus remained in the house with Defendant

Katz’s children. Defendant Katz’s children then abducted Child ‘B’ from his crib.

47. Plaintiff re-entered the house once Defendant Katz’s children left and noticed that Child

‘B’ was missing from his crib. Plaintiff then realized that Defendant Katz’s children had

abducted Child ‘B’. Plaintiff and his wife, i.e., Defendant Miriam Teitelbaum [once back

from Mikveh], tried reaching Defendants Juda and Chaya Katz by calling them on the

phone, but were unsuccessful.

48. Plaintiff and his wife then went to Defendants Juda and Chaya Katz’s home to get the

child back, and knocked at their door for about an hour. Defendant Hatzalah EMS then

arrived at Defendants Katzs’ home. Defendants Juda and Chaya Katz returned the Child

‘B’ to Plaintiff and his wife, i.e., Defendant Miriam Teitelbaum.

49. On or about April 27th, 2010, Defendant Miriam Teitelbaum gave baby Tylenol to Child

‘B’. Soon thereafter, Defendant Miriam Teitelbaum found Child ‘A’ playing with the

open baby Tylenol bottle. Defendant Miriam Teitelbaum then called Defendant Hatzalah

EMS so that they might determine whether Child ‘A’ had ingested the Tylenol.

50. Defendant David Rubenstein from Hatzalah EMS arrived at the home. In furtherance of

pre-orchestrated conspiracy that unfolded later, as explained in following paragraphs,

Defendant David Rubenstein falsely represented that he would take Child ‘A’ to the

hospital for a checkup, and Defendant Miriam Teitelbaum would accompany him and

Child ‘A’ to the hospital.

  11

51. Defendant David Rubenstein then asked Defendant Miriam Teitelbaum to sign a consent

that would allow him to keep Child ‘B’ at his apartment until she returned from the

hospital the next day with Child ‘A’. She signed the consent for Defendant David

Rubenstein. Once the consent was signed, he had another EMS member take the Child

‘B’ to his apartment.

52. Defendant David Rubenstein then abducted Defendant Miriam Teitelbaum with an

ambulance, taking her and committing her to a mental institution. He then gave Child ‘A’

to Defendants Juda and Chaya Katz without authorization or consent from Plaintiff.

53. Defendant David Rubenstein did not inform Plaintiff of the abduction of Defendant

Miriam Teitelbaum or of her placement in the hospital. Neither Defendant David

Rubenstein nor Defendants Juda or Chaya Katz informed Plaintiff of Child ‘A’s’

whereabouts.

54. On about April 28th, 2010, CPS confronted Plaintiff at his home. At that time, CPS

officially informed Plaintiff that they had removed his children. CPS served Plaintiff with

charges in the evening, and charged him with Child Neglect without proper investigation

and without probable cause. CPS removed the children without imminent danger.

55. All these actions of CPS were wholly unwarranted, and amounted to deliberate abuse of

State power, undertaken at the behest of other conspiring Defendants, and constituted part

of the larger conspiracy that would later embroil Plaintiff into a false litigation to

pressurize him into stopping his participation in the religious campaign.

56. On or about May 5th, 2010, Family Court assigned Defendant Attorney John F.X. Burke

to Plaintiff. Thereafter, Plaintiff asked Attorney Burke to both deny the charges and

prove to the Family Court that the charges were false, but he latter refused to fight for

  12

Plaintiff, claiming he had received a deal from DSS, and he insisted that, because of his

deal with DSS, Plaintiff must plead guilty to the charges.

57. Plaintiff was recently informed that Defendant Attorney Burke, in pursuance of the

conspiracy referred to hereinabove, had entered consent to all the charges without a fact

finding hearing.

58. On the other hand, Defendant Miriam Teitelbaum received an ACD for the same charges.

59. On or about August 2010, through several phone calls made to the Defendant Miriam

Teitelbaum, people in the community incited and obligated her to stop Plaintiff from

completing his religious campaign.

60. On or about September 7th, 2010, DSS returned the children to Plaintiff and his wife.

61. On or about September 15th, 2010, Plaintiff performed a peaceful demonstration in

Kiryas Joel as part of his religious campaign.

62. On or about September 16th, 2010, Child ‘B’ did not wake from his usual daytime nap,

whereupon Defendant Miriam Teitelbaum called Defendant Hatzalah EMS. Hatzalah

EMS took Child ‘B’ to Westchester Medical Center, and thereafter, removed the children

from the Plaintiff’s home once again.

63. Defendant Attorney Burke told Plaintiff that in order to get his children back he would

need to admit that he failed to secure his medication. However, Plaintiff had never taken

the medication. The medication bottle was unopened and contained within an unopened

bag.

64. Meanwhile, Family Court adjourned Defendant Miriam Teitelbaum’s trial to a later date

of March 10th, 2011, stating that this situation was an accident and she could not be

blamed for an accident.

  13

65. On or about September 26th, 2010, Meir Tennenbaum, Defendant Miriam Teitelbaum’s

father, visited Plaintiff’s house, .

66. Meir Tennenbaum then verbally harassed and embarrassed Mr. Ben Friedman - who was

present at the Plaintiff’s house - for being involved in the religious campaign, and he also

harassed Plaintiff for having a friendly relationship with Mr. Ben Friedman. Meir

Tennenbaum then ordered Defendant Miriam Teitelbaum to not allow Mr. Ben Friedman

into her house anymore. Since then, Defendant Miriam Teitelbaum has resisted each time

Plaintiff has wanted Mr. Ben Friedman to visit their house, and blocked all calls from

anyone who is associated with the religious campaign, effectively preventing Plaintiff

from receiving calls from those involved with the campaign.

67. On or about October 2010, DSS agreed to allow the Payos opsheren celebration of Child

‘A’ to take place at Plaintiff’s home on October 11th. On or about October 9th, DSS

informed Plaintiff that they were not sure about allowing the celebration to take place at

Plaintiff’s home.

68. \On or about October 10th, DSS informed Plaintiff that the celebration would only be

allowed to take place at the home of Meir Tennenbaum. DSS gave no reason for the

sudden change in required location though Plaintiff, upon information and belief, feels

that this was a deliberate attempt on the part of DSS in connivance with other Defendants

to penalize Plaintiff for his participation in the religious campaign, and for not severing

his friendship with Mr. Ben Friedman.

69. On or about July 2011, DSS informed Plaintiff that the court had ordered Plaintiff to

leave his house every Friday for 1-½ hours, during the time Defendant Miriam

Teitelbaum would have visitation with the Plaintiff’s children.

  14

70. On or about July 2011, Plaintiff’s psychiatrist, Rabbi Dr. Price, informed Plaintiff and his

wife that he saw no real necessity for Plaintiff taking the psychotropic medication that

had been prescribed to Plaintiff at an earlier time under the direction of the Plaintiff’s

family. Dr. Price also informed Plaintiff that as long as he insisted on continuing the

religious campaign, Plaintiff would not get his children back.

71. Defendant Miriam Teitelbaum disagreed with Dr. Price, insisting that Dr. Price tell

Plaintiff that he must take medication. Defendant Miriam Teitelbaum’s request was an

effort to stop Plaintiff from his religious campaign through the use of medication. This

tactic is a commonly used in the community in order to gain control over someone, and

was in fact the tactic that had resulted in the prescribing of the psychotropic medication

to Plaintiff in the first place.

72. On or about July 18th, 2011, Defendant David Rubenstein, in collusion with other

Hatzalah EMS members, in furtherance of the aforementioned conspiracy, organized the

abduction of the Plaintiff, and by making false allegations about Plaintiff’s mental

condition, forced Plaintiff into a mental institution (Bellevue Hospital Center).

73. On or about July 19th, 2011, Plaintiff was signed out of the hospital and returned to

Kiryas Joel through the assistance of his friend Mr. Ben Friedman. Bellevue Hospital

released Plaintiff only on the condition that Plaintiff would not return to his own home.

74. Once Plaintiff returned to Kiryas Joel, Defendant Rubenstein and other Hatzalah

members chased Plaintiff in the street, attempting to abduct him again. Plaintiff then took

cover by fleeing in a friend’s car to his friend Ben Friedman's house. Defendant

Rubenstein and other Hatzalah EMS members continued to chase Plaintiff to said house.

  15

75. Defendant Rubenstein even attempted to open the door of the house without asking

permission to enter. When he was denied entry, he intruded through the window,

threatening that he would kidnap both Plaintiff and Plaintiff’s friend Ben Friedman if the

latter would not open the door for Hatzalah EMS immediately.

76. Plaintiff’s friend Ben Friedman immediately called the N.Y. State Police. N.Y. State

Police arrived and did not allow Defendant Rubenstein or other Hatzalah EMS members

to abduct or institutionalize Plaintiff. Defendant Rubenstein and the other Hatzalah EMS

members then left the scene.

77. Plaintiff then went to Arden Hill Hospital to be evaluated in order to prove that the

allegations Hatzalah EMS were making against Plaintiff were false. On or about July

19th, 2011, Arden Hill Hospital confirmed that there was no reason to institutionalize

Plaintiff.

78. Plaintiff then returned to his home. Defendant Miriam Teitelbaum then called Hatzalah

EMS, asking them to remove Plaintiff from the home and to return him to a mental

institution. Defendant Hatzalah EMS did not respond to her request. Defendant Miriam

Teitelbaum then called the N.Y. State Police, asking them to remove Plaintiff from the

home. N.Y. State Police informed her that they could not remove Plaintiff, and advised

her that she could only have him removed through the family court system.

79. On or about July 2011, individuals in the community contacted Defendant Miriam

Teitelbaum again via telephone, attempting to incite her to separate from Plaintiff by

moving out of the home into another apartment of her own. However, Defendant Miriam

Teitelbaum refused; however, acting under the instructions of certain individuals within

the community, Defendant Miriam Teitelbaum seized Plaintiff’s Shabbas clothing.

  16

80. Plaintiff firmly demanded that his wife return the clothing. On or about August 2011,

Defendant Miriam Teitelbaum demanded that those individuals in the community who

possessed Plaintiff’s clothes must return the clothing to her. Once she received the

clothing, she then gave the clothing back to Plaintiff and resumed living in peace with

Plaintiff.

81. On or about August 2011, through more telephone calls to Defendant Miriam

Teitelbaum, individuals in the community threatened to abduct Defendant Miriam

Teitelbaum and to force her into a mental institution because she had resumed living in

peace with Plaintiff rather than attempting to deter Plaintiff from his religious campaign.

82. On or about September 8th, 2011, this threat was carried out. Hatzalah EMS abducted

Defendant Miriam Teitelbaum from the street outside her home and forced her into a

mental hospital (N.Y. Presbyterian, Westchester County). Hatzalah EMS did not inform

Plaintiff of Defendant Miriam Teitelbaum’s abduction.

83. Defendant Hatzalah EMS [or the Defendant Miriam Teitelbaum’s parents or other

members of her family] instructed the admitting hospital to not listen to Plaintiff or his

agents whatsoever.

84. Defendant Miriam Teitelbaum was thus institutionalized for about two and a half weeks,

lasting until late September 2011. On or about September 12th, 2011, she called her

mother Mrs. Tennenbaum to ask her why her mother had participated in said abduction.

85. Defendant Miriam Teitelbaum 's father, Rabbi Meir Tennenbaum, interrupted the phone

conversation, hysterically proclaiming that Defendant Miriam Teitelbaum “…deserved it,

because six weeks ago you told me that your husband is the problem, and now you are in

peace with him and Mr. Friedman. I'm not afraid of your husband or Mr. Friedman.”

  17

86. On or about October 6th, 2011, after Defendant Miriam Teitelbaum had been released

from the mental institution, Defendant Miriam Teitelbaum’s parents - Meir and Mrs.

Tennenbaum - had another heated discussion with Defendant Miriam Teitelbaum.

During the conversation, they expressed their anger about her living in peace with

Plaintiff as well as the fact that she was no longer trying to deter Plaintiff from his

religious campaign.

87. Defendant Miriam Teitelbaum’s parents then sent Hatzalah EMS to Plaintiff’s home with

the goal of once again abducting her and forcing her into a mental institution. Defendant

Miriam Teitelbaum then called the N.Y. state police.

88. Hatzalah EMS took Defendant Miriam Teitelbaum to Orange County Horton Medical

Center, who released her the very same day once the Plaintiff contacted them to say that

his wife; i.e., Defendant Miriam Teitelbaum, was fine.

89. On or about October 21st, 2011, DSS did not allow Plaintiff’s children to visit Plaintiff in

the men’s section of the synagogue for Simchas Torah dancing with their father as all

children do. DSS then fought with Defendant Miriam Teitelbaum for having allowed the

children to go into the men’s section with Plaintiff for a mere few minutes.

90. Since that incident, DSS has prevented visitations from occurring at the Plaintiff’s home;

rather, visitations must occur at the office of DSS.

91. On or about November 4th, 2011, DSS shortened the length of Defendant Miriam

Teitelbaum’s scheduled visitation with her children without warning or explanation.

When Defendant Miriam Teitelbaum inquired as to why the visitation was shortened and

rightfully requested that she be granted the full agreed scheduled time, she was forcefully

  18

committed into Orange Regional Medical Center. Defendant DSS justification for this

action was that the Defendant Miriam Teitelbaum was “irritated.”

92. In this case, DSS had hospitalized Defendant Miriam Teitelbaum on the eve of a

weekend when no resident psychiatrist was there, requiring the hospital to keep her at the

hospital until a doctor would be able to discharge her on Monday after verifying that

there was no reason that she must stay there.

93. Upon information and belief, Plaintiff asserts that all the foregoing actions and deeds of

Defendant DSS, a State actor, amounted to abuse of State power, as these were politically

motivated and were undertaken at the behest of other co-defendants with ulterior

objective of causing mental torture to Plaintiff by depriving him of his children’s love

and affection, turning Plaintiff’s wife against Plaintiff, and penalizing Plaintiff’s wife for

not doing enough to deter the Plaintiff from participating in the religious ceremony/

94. On or about Dec 27th, 2011, Plaintiff filed a motion with Family Court to stop DSS’s

politically motivated actions. Plaintiff asked Family Court to make a determination

through a fact finding hearing that the underlying involvement of DSS in this matter was

based on political reasons. Plaintiff stated that Defendant DSS, Defendant Hatzalah EMS,

and others in the community were now targeting Defendant Miriam Teitelbaum in an

effort to stop Plaintiff from his religious campaign. By saying this, Plaintiff alleged that

this clearly demonstrated that Defendant DSS’s actions were politically motivated, and

were part of the aforesaid conspiracy.

95. On or about January 3rd, 2012, Defendant Attorney Maria Patrizio called Defendant

Miriam Teitelbaum and stated that Plaintiff would never get custody of the children

because:

  19

a. Plaintiff had filed a motion;

b. Plaintiff had a friendly relationship with Mr. Ben Friedman; and

c. Plaintiff had not cooperated with Defendant Attorney Burke.

96. Defendant Attorney Patrizio also stated that should the subject of the Plaintiff’s motion

be raised in court the next day, then Plaintiff would have to say in court that he did not

file this motion. Attorney Patrizio also stated that Defendant Miriam Teitelbaum must

choose between either separating from Plaintiff or giving up the right to her children

forever.

97. On or about January 4th, 2012, while in the Court building, Attorney Patrizio suggested to

Defendant Miriam Teitelbaum that she ignore and abandon Plaintiff because he had filed

the above mentioned motion.

98. Defendant Attorney Patrizio then demanded to know what Defendant Miriam Teitelbaum

had chosen of the two options she had been given during the previous day’s conversation:

whether Defendant Miriam Teitelbaum would separate from Plaintiff or give up her right

to her own children.

99. On or about January 9th, 2012, Defendant Attorney Kim Pavlovic (who was then

representing Defendant CRS.), in a conspiratorial bid to turn Defendant Miriam

Teitelbaum against Plaintiff, proposed in Court that the children be returned to Defendant

Miriam Teitelbaum on the condition that Plaintiff would be evicted from the home.

100. Defendant Attorney Pavlovic stated that the major issue that would prevent the return of

the children was Plaintiff, and that only by evicting Plaintiff could the situation be helped

101. In yet another manifestation of his involvement in the conspiracy, Defendant Attorney

Burke did not object.

  20

102. Likewise, DSS did not object to Attorney Pavlovic’s proposal to return the children to

Defendant Miriam Teitelbaum on the condition that Plaintiff was evicted from his home.

103. Family Court agreed and affirmed all of this.

104. After the Court session, Defendant Attorneys Patrizio and Burke demanded that Plaintiff

leave his home immediately and for good. Defendant Attorney Patrizio stated again to

Defendant Miriam Teitelbaum that she would lose the children forever if she would not

comply with their request to evict Plaintiff from the home.

105. On or about January 20th, 2012, Defendant Attorney Patrizio called Defendant Miriam

Teitelbaum to insist that she file a motion that would evict Plaintiff from the home for

several months Attorney Patrizio said that this action would result in Defendant Miriam

Teitelbaum getting the children back, and also stated again that she would lose her

children forever if she did not file it. Attorney Patrizio very strongly pressured her to file

this motion.

106. Thereafter, Plaintiff sent a letter to Family Court informing the Court of the intimidation

his wife was experiencing. The letter also asked why this was happening.

107. On or about January 26th, 2012, Attorney Patrizio called Defendant Miriam Teitelbaum

and asked what she had decided to do about evicting Plaintiff. In response, she said that

she needed Plaintiff, especially if the kids were at home, and that it would be detrimental

to her and to the well being of the children if the Plaintiff was not at home.

108. Defendant Attorney Patrizio continued to insist that Defendant Miriam Teitelbaum file a

request to evict Plaintiff because the Family Court had already made up its mind not to

return the children to Plaintiff. Attorney Patrizio also pressurized her by stating that the

Court would not change its mind.

  21

109. Thereafter, Defendant Attorney Maria Patrizio sent a letter to Defendant Miriam

Teitelbaum dated February 9th, 2012, reiterating her previous warning that Defendant

Miriam Teitelbaum should separate from Plaintiff to facilitate having the children

returned to her custody. The letter further stated that if Defendant Miriam Teitelbaum

decided to remain with Plaintiff, her parental rights could be terminated: that she would

no longer be the legal parent of her own children and that the children could potentially

be adopted by another party. A true and correct copy of February 9th, 2012 letter is

Exhibit ‘B’.

110. Plaintiff’s first motion filed in Family Court on or about December 27th, 2011, was

returnable for January 17th, 2012. As of January 17th, 2012, none of the Defendants had

replied to the motion. Subsequently, in pursuance of the aforesaid conspiracy, the

proceedings before the Family Court were manipulated by DSS, Defendant Attorney

Burke, and other original Defendants to the detriment of Plaintiff.

111. On or about January 17th, 2012, Plaintiff filed a 3rd motion that the Court should relieve

Plaintiff’s attorney, allowing Plaintiff to proceed Pro Se. On or about February 10th,

2012, Plaintiff received Defendant Family Court’s decision to Plaintiff’s 3rd motion dated

February 8th, 2012. Family Court denied Plaintiff’s motion to proceed Pro Se.

112. Plaintiff reiterates that through this action he is not seeking either review or rejection of

any of the Family Court’s orders, nor is he complaining about any injury caused by such

order(s); instead, his grievance is directed against the deliberate deprivation and violation

of his Fundamental Constitutional Rights caused by the conspiratorial misuse of State

power by Defendants against Plaintiff, which was further aggravated by the abuse of the

  22

process of law by CRS acting through its agent, Attorney Pavlovic,, and by Attorney

Burke, as evidenced from the aforementioned proceedings in Family Court.

113. On or about January 25th, 2012, Defendant DSS filed a petition to terminate parental

rights for Plaintiff and his wife based on mental illness. DSS brought new claims of

mental illness against Plaintiff.

114. On or about February 3rd, 2012, Plaintiff received Defendant DSS’s motion dated January

25th, 2012, which stated that Plaintiff and his wife must be evaluated for mental illness.

115. On or about February 7th, 2012, Plaintiff filed opposition papers against both the

Defendant DSS’s motion for mental evaluation and their petition.

116. On or about February 17th, 2012, at the Family Court hearing on this matter, Defendant

Attorney Burke did not object to the motion for mental evaluation.

117. Family Court ordered that both Plaintiff and his wife have a mental evaluation.

118. On or about January 25th, 2012, during a scheduled visitation at Plaintiff’s home,

Defendant DSS’s supervisor Mr. James screamed loudly and angrily at Plaintiff in the

presence of Plaintiff’s children, who became terrified and cried.

119. Thereafter, Plaintiff immediately wrote to Family Court about the visitation incident.

120. Plaintiff alleged that Defendant DSS was seeking to justify their new plan to return the

children to only Defendant Miriam Teitelbaum [and not to the Plaintiff] by creating a

new theory that it would be harmful to the children for the Plaintiff to remain in the

house. Plaintiff also wrote to DSS about the incident whereupon DSS changed the

Plaintiff’s visitation supervisor.

  23

Plaintiff is not currently having visitation because of the difficulties presented since this

incident, as it regards his children. Plaintiff believes that a set up is being planned against

him by Defendant DSS.

121. On or about July 11th, 2011, Defendant Attorney Burke requested an interpreter on

Plaintiff’s behalf. Family Court denied the request.

122. On or about January 3rd, 2012, Plaintiff wrote to Family Court, again requesting an

interpreter. Plaintiff does not fully understand the English language, nor does he know

how to properly speak the English language. Despite these facts, Family Court did not

grant an interpreter to the Plaintiff.

123. On or about January 2011, Plaintiff’s children ‘A’ and ‘B’ were moved and began to

reside at Defendants Joel and Bluma Tennenbaum’s house.

124. Thereafter, Plaintiff Child ‘A’ began to call Defendant Miriam Teitelbaum [their mother]

as “Mrs. Teitelbaum” and not “mommy”. Instead, Plaintiff Child ‘A’ called Defendant

Bluma Tennenbaum “mommy.” Plaintiff Child ‘A’ since claims that Plaintiff is not his

father. Plaintiff Child ‘A’ since claims that his family name is not Teitelbaum. Instead,

Plaintiff Child ‘A’ claims that his family name is Tennenbaum.

125. Plaintiff Child ‘A’ resists getting in the car to attend visitation with his true mother,

Plaintiff’s wife. Plaintiff Child ‘A’ constantly fights with Plaintiff during visitations,

rebelling against any request made by Plaintiff and overall refusing to be friendly or to

enjoy the visit.

126. On or about October 2011, Plaintiff and Plaintiff’s wife found a family in the community

who were willing and able to foster Plaintiff’s children.

  24

127. Thereafter, upon information and belief, Defendants Joel and Bluma Tennenbaum

discouraged said family from fostering Plaintiff’s children. Defendant Joel Tennenbaum

claimed G-d punished Plaintiff by removing his children because of Plaintiff’s

involvement in the religious campaign.

128. Upon information and belief, Defendant DSS and certain individuals in the community

involved in the matter agreed to return Plaintiff’s children to Plaintiff and stop all

intimidation and accusation if Plaintiff would willingly stop his religious campaign

against forced divorces.

129. However, it is the Plaintiff’s belief that it is his religious obligation, as someone who

obeys the true Torah teachings and principles, to continue with his peaceful religious

campaign. Jewish history is full of events where certain people have tried to change

fundamental principles of the Torah and others have fought against that change. It is also

documented that those people who have fought against changing the true principles of the

Torah have met much resistance.

130. Our sages have foretold that before the redemption of exiles and the coming of the

Messiah, there will be very strong movements to overthrow and reform the true teachings

of and adherence to the Torah. Through this foretelling, we were forewarned to fight and

resist such changes. Plaintiff is trying to uphold the true teachings of the Torah and

believes that the opposition and intimidation he and his wife are facing are a fulfillment

of this foretelling.

EVENTS AFTER FILING OF THE ORIGINAL ACTION

131. On or about April 11th, 2012, Plaintiff filed in Federal District Court an action, entitled

Teitelbaum v. Katz et al, 12-CV-2858 (hereinafter referred to as the “original action”) to

  25

seek protection from the continued harassment, intimidation, terrorization and violation

of Plaintiff’s civil rights by the Defendants named in the original action (hereinafter

collectively referred to as the “original Defendants”), who are also named as Defendants

in this complaint. A true and correct copy of the complaint filed by Plaintiff in the

original action (hereinafter referred to as the “original complaint”).

132. As the original complaint alleged, Plaintiff was subjected to severe intimidation,

harassment, and terror; his freedom was unlawfully taken away; his family was broken

up; and his children taken away; all by the original Defendants in pursuance of aforesaid

conspiracy, forcing him to live under constant fear, trauma and emotional turmoil,

caused by the continued and ongoing terror they unleashed upon him with a common

objective to unlawfully deprive him of his Fundamental Constitutional Rights, in order to

stop him from participating in aforementioned religious campaign.

133. But after filing of the original action, the previously ongoing harassment, intimidation

and terrorization of Plaintiff was renewed with increased intensity by the original

Defendants, in connivance with other parties who along with some of the original

Defendants are now also named as Defendants in this complaint, and it was targeted to

stop – (a) Plaintiff’s original action, (b) his access to court, and (c) his involvement in the

aforementioned religious campaign, and also to pressurize Plaintiff into complying with

their unlawful demands.

134. Since about April of 2012, Defendant Miriam Teitelbaum began to interfere whenever

Plaintiff was on the phone with Ben Friedman, and discussing the original action.

  26

135. Defendant Miriam Teitelbaum continued blocking the incoming calls from Ben Friedman

and others to Plaintiff. On or about the same time, Defendant Miriam Teitelbaum seized

Plaintiff’s private cell phone.

136. Defendant Miriam Teitelbaum stated the reason for the above; that Plaintiff must stop the

original action. She then stated another reason; that Plaintiff should not communicate

with his friend Ben Friedman.

137. On or about April 2012, Defendant Miriam Teitelbaum loudly approached Plaintiff and

his friend Ben Friedman during a private meeting in the street, verbally attacking and

harassing them.

138. Defendant Miriam Teitelbaum then demanded of Plaintiff and his friend to stop

communicating with each other.

139. Defendant Miriam Teitelbaum then harassed Plaintiff and his friend for filing and

pursuing the original action, and demanded Plaintiff and his friend to stop the original

action.

140. Defendant Miriam Teitelbaum continued to intimidate and harass Plaintiff in the same

manner at home for a few days after the above incident.

141. On or about late April, 2012, Defendant Miriam Teitelbaum was admitted to mental

hospital for a prolonged period.

142. On or about June 1st, 2012, Plaintiff was suddenly caught in surprise when Defendant

Miriam Teitelbaum unexpectedly and hurriedly came home from the hospital without any

notice.

143. Defendant Miriam Teitelbaum would otherwise always give notice when coming home

from a hospitalization.

  27

144. Defendant Miriam Teitelbaum was extremely upset when she came home.

145. Defendant Miriam Teitelbaum at the same time expressed great concern over Plaintiff’s

then recently filed original action.

146. Defendant Miriam Teitelbaum then insisted upon and demanded by pressuring Plaintiff

that his original action must immediately be withdrawn or stopped.

147. Plaintiff later came to know that on or about May 29th, 2012, the original summons and

Plaintiff’s original complaint were served on some of the Defendants in the original

action, including members of Defendant Miriam Teitelbaum’s family.

148. It appears that the service of summons along with a copy of original complaint on the

Defendant Miriam Teitelbaum’s family was the catalyst to Defendant Miriam

Teitelbaum’s aforementioned behavior.

149. Other individuals within the community joined hands with the original Defendants, all of

them have continually harassed and intimidated Plaintiff for pursuing his original action

since around April 2012.

150. Plaintiff accordingly informed Defendant Judge Briccetti by letter dated June 25th, 2012.

A true and correct copy of June 25th, 2012 letter is attached hereto as Exhibit ‘C’.

151. On or about June 6th, 2012, in the wee morning hours, Plaintiff woke from sleep and saw

his bed surrounded by Defendant Hatzalah EMS members and Police.

152. Plaintiff had not called anyone or given permission to enter his home and bedroom.

153. Plaintiff, immediately after waking from his sleep, while still in bed, was ordered by

members of Defendant Hatzalah EMS to get up immediately and go with them to be

confined into mental institution.

154. Plaintiff was perplexed and bewildered at this bizarre unexplainable show.

  28

155. Plaintiff then asked members of Defendant Hatzalah EMS why this was happening, as

everything was perfectly okay and Plaintiff had been sound asleep before that, and had

committed no wrong

156. In response to Plaintiff’s question, Defendant Hatzalah EMS members threatened

Plaintiff that failure to allow himself to be confined to mental institution will result in

Plaintiff being arrested immediately.

157. Plaintiff refused to follow the shocking demands from Defendant Hatzalah EMS.

158. Plaintiff then overheard Defendant Hatzalah EMS members pressuring Defendant

Miriam Teitelbaum to press charges, and to have Plaintiff arrested.

159. At the behest of Defendant Hatzalah EMS members, Defendant Miriam Teitelbaum, filed

false criminal charges against Plaintiff, and had him arrested.

160. On or about June 6th, 2012 Plaintiff was arrested without warrant, and thereafter

criminally charged in the Monroe Town Court.

161. Said charges against Plaintiff were false, fabricated and utterly baseless.

162. On said date, the local District Attorney requested said court to remove Plaintiff from the

marital home.

163. Monroe Town Court then issued an order of protection against Plaintiff, directing him not

to intimidate Defendant Miriam Teitelbaum, while allowing him to remain at home with

her.

164. On or about June 6th, 2012, Plaintiff notified Defendant Judge Briccetti of his arrest and

false criminal charges filed against Plaintiff by Defendant Miriam Teitelbaum on the

behest of Defendant Hatzalah EMS during that day. A true and correct copy of Plaintiff’s

June 6th, 2012 letter is attached hereto as Exhibit ‘D’.

  29

165. After the arrest, Plaintiff returned home, but later that day left the marital home out of

fear of being charged falsely again with new charges or with violating the protection

order, which could potentially turn the crime into a felony.

166. On June 7th, 2012; i.e., barely a day after she filed false charges against Plaintiff,

Defendant Miriam Teitelbaum arranged and admitted herself into NY Cornell

Westchester Hospital, apparently due to the severe stress of the acts of the day before., .

167. Plaintiff upon finding out about Defendant Miriam Teitelbaum’s hospitalization went

back to the marital home.

168. Plaintiff remained in the marital home until about June 28th, 2012.

169. On or about June 11th, 2012, Defendant Miriam Teitelbaum, subsequent to Plaintiff’s

arrest, wrote a letter dated June 11th, 2012, stating that she did not file any charges against

Plaintiff. A true and correct copy of Defendant Miriam Teitelbaum’s letter dated June

11th, 2012 is attached hereto as Exhibit ‘E’.

170. Defendant Miriam Teitelbaum’s letter dated June 11th, 2012 also states that she would

never file any charges against Plaintiff.

171. Said letter further states that she withdraws all charges against Plaintiff.

172. Said letter also states that she wants to stop Plaintiff’s friends who helped him bring this

action from communicating with Plaintiff anymore.

173. In the aforesaid letter dated June 25th, 2012 (Exhibit ‘C’) to Defendant Judge Briccetti,

Plaintiff wrote about the above, annexing therewith a copy of Defendant Miriam

Teitelbaum’s aforementioned letter dated June 11th, 2012.

174. On or about June 19th, 2012, in response to Plaintiff’s letter dated June 6th, 2012,

Defendant Judge Briccetti ordered both Defendant Orange County and Plaintiff to appear

  30

in Court regarding Plaintiff’s allegations of terror and intimidation to stop the religious

campaign and stop his original action.

175. On or about June 2012, Defendant Miriam Teitelbaum during her stay in hospital,

repeatedly demanded Plaintiff to stop his original action.

176. On or about June 12th, 2012, Plaintiff received a phone call from a social worker at the

hospital, stating that Defendant Miriam Teitelbaum could not be released due to the

pending criminal charges and protection order against Plaintiff.

177. On or about June 13th, 2012, a certain Mrs. Pasternak called Plaintiff that the Hospital

would not allow Defendant Miriam Teitelbaum to go home because of her ongoing clash

with Plaintiff.

178. On or about June 24th, 2012, Mrs. Pasternak called again, demanding from Plaintiff to

stop the original action immediately.

179. Mrs. Pasternak then recited again that the Hospital would not allow Defendant Miriam

Teitelbaum to come home, as long as the criminal charges remain and the clash with

Plaintiff continues.

180. Mrs. Pasternak then stated that as long as Plaintiff pursues his original action, Defendant

Miriam Teitelbaum would not withdraw the criminal charges against him.

181. On or about June 22nd, 2012, a social worker for Defendant Orange County (DSS) called

to advise Plaintiff that if he wanted visitation with his children, they will have to arrange

for his visitation at a separate time from Plaintiff’s wife, stating this was due to his

criminal charges and the aforesaid protection order against him..Incidentally, Defendant

Miriam Teitelbaum was hospitalized at that time, and Defendant DSS knew well that

  31

Plaintiff was not having visitation for a long time prior, for fear of a setup being planned

against him by Defendant DSS, after an incident at the last visitation he had.

182. On or about June 27th, 2012, the Defendant Orange County (DSS) social worker called

Plaintiff again, asking if he wanted visitation that day.

183. Plaintiff was not barred by the protection order at that time or by any other court order to

be near Defendant Miriam Teitelbaum or at home.

184. Defendant Orange County (DSS) was aware that Defendant Miriam Teitelbaum was not

having visitation during most of June 2012.

185. Defendant Orange County (DSS) knew that Plaintiff was not having visitation for a long

time prior to that.

186. Said Defendant knew that Plaintiff did not wish to have any visitation arranged through

Defendant Orange County (DSS).

187. During the aforementioned phone call of Defendant Orange County (DSS) on June 27th\,

2012, the Social Worker did not inform Plaintiff about the planned upcoming religious

“Payos Opsheren” celebration of Plaintiff’s younger child, scheduled to take place at

Plaintiff’s home on Friday, June 29th (as Plaintiff was to learn the next day).

188. On June 25th, 2012, Plaintiff was in Monroe Town Court for a pre-trial hearing on the

false criminal charges brought against him by the Defendants.

189. On said date, the local District Attorney requested an adjournment from said court,

stating he had been unable to communicate with Defendant Miriam Teitelbaum.

190. The hearing was adjourned for July 23rd, 2012

191. On or about June 28th, Plaintiff received a phone call from Defendant Miriam

Teitelbaum, informing him that she was coming home later that day.

  32

192. Plaintiff immediately left the house to avoid confrontation or further false charges.

193. Since Plaintiff’s arrest, he has been living in constant fear that the conspiring Defendants

would frame or kidnap him yet again, and he often has to take cover, or be on the run, or

in hiding, and to avoid appearing in public in the community so as to avoid his ongoing

harassment, intimidation and humiliation, continually orchestrated by the Defendants in

connivance with each other.

194. On June 28th, 2012, during the aforementioned phone call of Defendant Miriam

Teitelbaum, she informed Plaintiff that the celebration for the child would take place at

their house on the following day on Friday, the 29th. She also informed him then, that

both his and her family would attend the celebration, she demanded that Plaintiff be

present at that time, Plaintiff briefly advised her that as long as the fight ensues, he would

not participate whatsoever.

195. The above was communicated to Defendant Judge Briccetti in a letter dated July 2nd,

2012 written by Plaintiff’s friend Ben Friedman on behalf of Plaintiff, and given to the

Court during the conference on said date. A true and correct copy of said letter dated July

2nd, 2012 is attached hereto as Exhibit ‘F’.

196. On July 2nd, 2012, Defendant Judge Briccetti held his scheduled conference.

197. During the conference, Defendant Judge Briccetti stated he would proceed to discovery.

198. After said conference and until about early November 2012, the terrorization and

intimidation of Plaintiff seemed to have somewhat subsided or lessened.

199. On or about late July 2012, Plaintiff returned to his marital home.

  33

200. On or about said time, Defendant Miriam Teitelbaum admitted to Plaintiff that the

incident on June 6th, 2012, which led to warrantless arrest of Plaintiff, was planned to

confine Plaintiff to mental institution.

201. Defendant Miriam Teitelbaum then stated that the plan was not to arrest Plaintiff at all on

June 6th, 2012.

202. Defendant Miriam Teitelbaum also stated that this plan was designed to stop Plaintiff’s

original action.

203. Defendant Miriam Teitelbaum also returned Plaintiff’s private cell phone.

204. Between July 19th, 2012 and October 9th, 2012, various Defendants named in the original

action filed their Motions to Dismiss.

205. On or about September 23rd, 2012, Plaintiff received a letter from Defendant Attorney

Stephanie Bazile , informing him about an inquest to be held on January 17th, 2013, at the

Family Court. A true and correct copy of said letter is attached hereto as Exhibit ‘G’.

206. Said inquest was to be held on the request and behalf of Defendant Orange County (DSS)

and Defendant Attorney Stephanie Bazile.

207. On or about October 11th, 2012, Plaintiff requested Defendant Judge Briccetti to order

discovery that was necessary to oppose the Motions to Dismiss.

208. On or about October 23rd, 2012, Defendant Judge Briccetti denied the Plaintiff’s request

for ordering discovery, and directed Plaintiff to answer all pending Motions to Dismiss.

209. On or about November 5th, 2012, Plaintiff filed an opposition to the Motions to Dismiss.

210. Since filing of said opposition, the intimidation and terrorization of Plaintiff that had

somewhat abated before, now resumed with more vigor, putting Plaintiff under harsh

intimidation and pressure again.

  34

211. On or about late December 2012, Defendant Miriam Teitelbaum informed Plaintiff that

on December 24th, 2012, the Family Court held a hearing, during which; at the insistence

of numerous named and unnamed Defendants, it was decided that Plaintiff’s wife shall

regain custody of the children once she removes and evicts Plaintiff from the marital

home.

212. Plaintiff had been unable to participate in said hearing in Family Court, due to the lack of

an interpreter, and due to the Family Court’s insistence that Plaintiff only appear with an

attorney they choose.

213. This was noted in a letter sent to Defendant Judge Briccetti dated December 24th, 2012. A

true and correct copy of December 24th, 2012 letter is attached hereto as Exhibit ‘H’.

214. On or about late December 2012, Defendant Miriam Teitelbaum also informed Plaintiff

that a certain Rabbi in the community had urged Defendant Miriam Teitelbaum to do

everything in her power to cut Plaintiff off from anyone assisting with pursuing the

original action.

215. This was also noted Defendant Judge Briccetti in aforementioned letter dated December

24th, 2012 (Exhibit ‘H’).

216. On or about December 2012, Defendant Miriam Teitelbaum started interfering again

during the phone conversations Plaintiff had with his friends helping him with the

original action, particularly with Ben Friedman.

217. Defendant Miriam Teitelbaum stated that this was all being done at the guidance and

instruction of various Rabbis and leaders in the community, who have a clout with state

authorities.

  35

218. On or about the first half of January 2013, Defendant Miriam Teitelbaum again seized

Plaintiff’s cell phone.

219. Defendant Miriam Teitelbaum then said that she had handed the Plaintiff’s cell phone

over to certain Rabbi within the community.

220. Plaintiff notified Defendant Judge Briccetti on the above in a letter dated January 8th,

2013. A true and correct copy of said letter is attached hereto as Exhibit ‘I’.

221. On or about January 17th, 2013, the Family Court held its scheduled inquest.

222. Upon information and belief, said inquest lasted for about a week or more lasting through

the week of January 20th, 2013.

223. Plaintiff had been unable to participate in said inquest. in Family Court, due to the lack of

an interpreter, and due to the Family Court’s insistence that Plaintiff only appear with an

attorney they choose.

224. On or about Saturday, January 26th, 2013, in the early evening hours during Plaintiff’s

observance of “Shabos”, the Sheriff Department served Plaintiff with another order of

protection and another set of false criminal charges, which were brought by Defendant

Miriam Teitelbaum at the behest of the original Defendants directly and/or through their

co-conspirators, again, in pursuance of the conspiracy referred to hereinabove

225. To his utter shock, the Plaintiff then came to know that during the week of aforesaid

inquest, on January 19th, 2013, another set of false criminal charges had been brought

against him by Defendant Miriam Teitelbaum at the behest of the original Defendants

directly and/or through their co-conspirators in the Orange County Family Court; and,

based on those false charges, the Orange County Family Court, on January 25th, 2013,

had issued an order of protection to evict Plaintiff from the marital home.

  36

226. In compliance of the aforesaid order of protection, which was based on false criminal

charges, Plaintiff left the marital home on the evening of January 26th, 2013, during sub-

zero temperatures, and became absolutely homeless, with no ability to take anything but

the clothing he had on his person at that time, all because of the wrongful, insulting, and

conspiratorial acts of the original Defendants, who, directly and/or through their co-

conspirators, finally succeeded in snatching away from Plaintiff, his home, his wife, and

his children, besides violating his Fundamental Constitutional Rights.

227. It is pertinent to mention here that the aforesaid protection order was based on the same

old false charges, which had been brought many months prior on June 6th, 2012 in

Monroe Town Court, and regarding which Defendant Miriam Teitelbaum later stated in

her letter dated June 11th, 2012 (Exhibit ‘E’), that she had never filed these charges (See,

¶¶ 169-173 of this complaint).

228. Moreover, Plaintiff was, on July 23rd, 2012, advised by the Monroe Town Court that all

these charges had been dropped against Plaintiff.

229. Defendant Miriam Teitelbaum, on the behest of other original Defendants directly or

through their co-conspirators, and in furtherance of the object of the conspiracy referred

to hereinabove, falsely stated in papers filed in Family Court on January 19th, 2013, that

the charges brought on June 6th, 2012, had been transferred from Monroe Town Court to

the Town of Goshen Court, due to the Monroe Town Court having a negative history

with Plaintiff.

230. Said statement of Defendant Miriam Teitelbaum was false, fallacious, and baseless.

  37

231. Before the filing of aforesaid papers and false criminal charges on January 19th, 2013,

Defendant Miriam Teitelbaum had threatened Plaintiff numerous times that failure of

Plaintiff to stop the original action would result in Plaintiff’s arrest.

232. Defendant Miriam Teitelbaum clearly stated in aforesaid papers that Plaintiff had failed

to comply with the demands of original Defendants and/or others, who, in fact, were the

co-conspirators of original Defendants.

233. Defendant Miriam Teitelbaum also further stated in the papers that this failure of

Plaintiff led to her filing of criminal charges on January 19th, 2013.

234. From the foregoing, all the concerns and fears of Plaintiff stand vindicated, and it is also

proved that the eviction of Plaintiff from his marital home had been planned by the

Defendants long ago, and all their wrongful, conspiratorial acts of intimidating and

harassing Plaintiff by misusing the State power and thereby depriving Plaintiff of his

Fundamental Rights, were, in fact, a part of their evil plan aimed at forcing Plaintiff’s

compliance with Defendants’ unlawful demands.

235. On or about January 27th, 2013, Plaintiff sent another letter to Defendant Judge Briccetti,

notifying the latter of intimidation and terrorization Plaintiff was subjected to, as

described above. A true and correct copy of said letter is attached hereto as Exhibit ‘J’.

236. Defendant Judge Briccetti did nothing to stop this intimidation and terrorization at that

time.

237. During the two weeks following January 19th, 2013, Defendant Miriam Teitelbaum stated

numerous times that unless the conditions listed below were met she would neither accept

a Get nor resume to live with Plaintiff for the following two years: (1) Plaintiff breaks up

  38

all ties with his friend Ben Friedman; (2) Plaintiff stops the religious campaign against

forced divorces; and (3) Plaintiff completely withdraws his federal action.

238. Plaintiff then informed Defendant Judge Briccetti again on February 11th, 2013, that this

clearly illustrated how the conspiring Defendants are determined to keep Plaintiff chained

and stuck in limbo until their demands are met. A true and correct copy of the letter

Plaintiff sent to Defendant Judge Briccetti on February 11th, 2013 is attached hereto as

Exhibit ‘K’.

239. On or about the last week of February 2013, Plaintiff requested Defendant Miriam

Teitelbaum to accept a “Get” (Religious Jewish Divorce).

240. Defendant Miriam Teitelbaum refused to accept a “Get”.

241. Defendant Miriam Teitelbaum also refused to resume living together with Plaintiff.

242. Plaintiff then wrote and explained in a letter dated January 29th, 2013 to Defendant Judge

Briccetti, as to how this refusal of Defendant Miriam Teitelbaum clearly illustrated the

bad intent and malice of Defendants and their co-conspirators behind the January 19th,

2013 charges brought at their behest by Defendant Miriam Teitelbaum against Plaintiff,

which were designed just to harm, intimidate, and terrorize Plaintiff into complying with

their unjustified demands. A true and correct copy of Plaintiff’s January 29th, 2013 letter

is attached hereto as Exhibit ‘L’.

243. Plaintiff has constantly been subjected to continuous harassment from others, aligned

with the Defendants and their co-conspirators in the community, including during the

period between January and June, 2013.

244. Particularly outstanding were two individuals, a certain Mr. Yoel Shpitzer and a certain

Mrs. Pasternak, who would continually harass Plaintiff to stop the otiginal action.

  39

245. Said individuals would harass Plaintiff and make him feel guilty as though the family

breakup was his fault.

246. Said individuals demanded and insisted of Plaintiff that he must please Defendant Miriam

Teitelbaum at all costs.

247. Plaintiff wrote to Defendant Judge Briccetti about the above in a letter dated February

11th, 2013.

248. On February 11th, 2013, a certain Mr. Yoel Schwartz, an acquaintance of Defendant

Miriam Teitelbaum’s family, confronted Plaintiff during the morning prayers in the

synagogue, and in a hasty and threatening manner intimidated Plaintiff that Plaintiff had

one last chance to withdraw the original action and religious campaign, and to get his

wife and children back (if and only if his original action is withdrawn).

249. Said individual proceeded to inform Plaintiff that unless Plaintiff agreed immediately to

withdraw the original action, Defendant Judge Briccetti would “dismiss” the original

action “as soon as today or tomorrow”; i.e., on that very day or the next day..

250. Said individual further claimed that he had inside information from a very reliable source

associated with the original Defendants.

251. On the following day February 12th, 2013, Plaintiff received in mail a Memorandum

Decision dated February 11th, 2013 issued by Defendant Judge Briccetti, in which he

dismissed Plaintiff’s Complaint against all the original Defendants who had filed Motions

to Dismiss.

252. This Memorandum Decision neither referred to nor discussed any of the rulings produced

by Plaintiff, nor did it give any consideration to; rather, ignored the Plaintiff’s arguments

  40

raised in opposing the Motions to Dismiss. A true and correct copy of Defendant Judge

Briccetti’s February 11th, 2013 Memorandum Decision is attached hereto as Exhibit ‘M’.

253. In a stark contrast, as evident from the court record relating to original action, Defendant

Judge Briccetti, at a hearing held on February 20th, 2013, denied Plaintiff’s motion for

default judgment against one of the original Defendants, named Attorney John Burke,

who had failed to answer the original complaint for over 6 months.

254. During said hearing, Defendant Judge Briccetti had asked Plaintiff what he intended to do

about other two original Defendants; namely, Katz and Tennenbaum, as according to

Defendant Judge Briccetti they had not been served with the original complaint.

255. Plaintiff then informed Defendant Judge Briccetti that the two abovenamed original

Defendants, Katz and Tennenbaum, had been served according to the Marshals.

256. Later, on said date, Defendant Judge Briccetti issued an order, directing Plaintiff to

inform the Court if he intended to move for default judgment against the two above

named original Defendants.

257. Strangely, Defendant Judge Briccetti, in its February 11th, 2013 Memorandum Decision,

wrote that the two abovenamed original Defendants, Chaya and Katz, had not been

served.

258. Upon information and belief, Plaintiff understands that Defendants, directly and/or

through their co-conspirators, used political influence to get Defendant Judge Briccetti do

a turnabout, and to gain this outcome to dismiss the original complaint. Plaintiff felt as if

the Court turned its back on him, thereby giving rise to a new pattern and further terror

from the original Defendants and their co-conspirators, as more fully explained by

Plaintiff in a letter dated February 20th, 2013 to he sent to Honorable Loretta A. Preska,

  41

United States District Court Chief Judge, Southern District of New York. A true and

correct copy of the Plaintiff’s February 20th, 2013 letter is attached hereto as Exhibit ‘N’.

It is requested that the contents of said letter may kindly be allowed to be read as part of

this complaint, as if specofocally pleaded herein.

259. Thereafter, on February 21st, 2013, Plaintiff wrote to Defendant Judge Briccetti that it

appeared that two above named original Defendants had already answered the original

complaint.

260. On February 22nd, 2013, Defendant Judge Briccetti issued an order (See, Docket # 145 of

the original action) stating that he had erred about aforesaid Defendants, and that they

had indeed been served.

261. Defendant Judge Briccetti then permitted Plaintiff to amend his complaint against these

two Defendants as well, just as he permitted to amend it against the other Defendants

Hatzalah EMS and David Rubenstein.

262. On Feb 27th, 2013, Plaintiff requested from Defendant Judge Briccetti clarification on

which claims Judge Briccetti had in his February 11th, 2013 decision, permitted the

Plaintiff to amend the original complaint as to Defendants Hatzalah EMS and David

Rubenstein.

263. Plaintiff also requested clarification on the differences among the various original

Defendants that Defendant Judge Briccetti had ruled differently in his February 11th,

2013 decision.

264. On February 27th, 2013, Plaintiff also requested Defendant Judge Briccetti to clarify his

February 11th, 2013 decision, as to how to view original Defendant John Burke in relation

  42

to the various other original Defendants whom Judge Briccetti had differentiated one

from the other.

265. On February 28th, 2013, Defendant Judge Briccetti, in an order (See, Docket # 156 of the

original action) stated that Plaintiff erred by saying the Court had only allowed to amend

partial claims for Defendants Hatzalah EMS and David Rubenstein, referring Plaintiff to

the conclusion of his February 11th, 2013 decision.

266. Defendant Judge Briccetti then further stated the pending deadlines to file the amended

reconsideration, amended complaint, and opposing the motion to dismiss by Defendant

John Burke, and that he would not extend those deadlines.

267. On March 3rd, 2013, Plaintiff again requested clarification from Defendant Judge

Briccetti, explaining that it would be a difficult task to complete said filings, without

further clarification from the Court on its February 11th, 2013 decision.

268. On March 4th, 2013, Defendant Judge Briccetti denied Plaintiff’s request again.

269. On March 5th, 2013, Plaintiff once again requested clarification from Defendant Judge

Briccetti, stating that it is not requesting any relief, rather just a mere clarification.

270. Thereafter, on said date, Defendant Judge Briccetti directed Plaintiff to comply with its

prior order of February 28th, 2013, as best as he could, and that no clarification was

warranted.

271. On March 5th, 2013, Defendant David Hollander warned Plaintiff in a very threatening

manner directing him to leave the village of Kiryas Joel immediately.

272. Said Defendant further warned and directed Plaintiff to stay out of the village of Kiryas

Joel for, at least, the following six (6) months.

  43

273. Said Defendant further stated that he has the full backing from all the community Rabbis

and the political power enjoyed by Kiryas Joel Village Community.

274. Said Defendant further stated that the reason for all this is to cut Plaintiff off from having

any ties or communication with his friend Ben Friedman.

275. Plaintiff has since been evicted, under threat, from the village Kiryas Joel. As a result of

this eviction, Plaintiff has been unable to receive any mail correspondence; and has

effectively been deprived of right to access the Court.untill the extrincek frud is

continuing

276. On or about March 18th 2013, Plaintiff had, through an intermediary, requested from

Defendant Miriam Teitelbaum to return his religious and holiday garment, which Plaintiff

urgently needed for the then upcoming Passover Holiday.

277. Since January 26th, 2013, after his eviction, Plaintiff has been unable to gain control to

necessary clothing still remaining within the control of Defendant Miriam Teitelbaum.

278. Defendant Miriam Teitelbaum refused to return the clothing.

279. Plaintiff has, since his eviction from the marital home, requested Defendant Miriam

Teitelbaum directly and through intermediaries to return to Plaintiff, or allow Plaintiff

access to, his religious books and articles.

280. Defendant Miriam Teitelbaum has repeatedly refused to grant Plaintiff his religious

books and articles or access thereto.

281. Upon information and belief, Plaintiff understands that Defendant Kiryas Joel

Community Ambulance Corporation, in collusion other Defendants; namely, County

Attorney David Lee Darwin, Attorney Rebecca Baldwin Montello, Attorney Gregg D.

Weinstock, Attorney Jeffrey B. Siler, Attorney Terence S. Hannigan, Attorney Patrick T.

  44

Burke, along with the original Defendants, by misusing the political influence wielded by

the community of the Village of Kiryas Joel, as well as the political machinery affiliated

with it, managed to establish a connection with Defendant Judge Briccetti. As a result,

Defendant Judge Briccetti, who initially acted to stop the Defendants from their evil

designs, subsequently backed off from stopping the Defendants, and became biased

against Plaintiff.

282. Later, Defendant Judge Briccetti, acting under extraneous influence, not only participated

in furthering the object of the other aforementioned conspiracy, aimed at depriving the

Plaintiff of access to Court and curtailing his fundamental rights, but also stopped

performing his neutral judicial function, and eventually issued the July 2nd, 2013 Order

(Exhibit ‘A’) whereby he unceremoniously dismissed the original action with prejudice,

after allowing the original Defendants’ Motions to Dismiss and rejecting the Plaintiff’s

Motions, including his Motion to file Modified Amended Complaint/Supplemental

Pleadings, without giving Plaintiff a fair opportunity of being heard, leaving him in a

much worse condition now. As such, the Memorandum of Decision and Order dated July

2nd, 2013 (hereinafter referred to as the “impugned order”), is, in fact, an order produced

by committing extrinsic fraud on Court; therefore, the impugned order is void, non est,

and is liable to be set aside.

283. All the Defendant attorneys; namely, David Lee Darwin, Rebecca Baldwin Montello,

Gregg D. Weinstock, Jeffrey B. Siler, Terence S. Hannigan, Patrick T. Burke, were not

only aware of the aforesaid extrinsic fraud perpetrated on the Court, but they also

participated in it.

  45

284. As of today, it is due to the aforesaid extrinsic fraud upon the Court that the Plaintiff has

been, and is continually being, denied the right of access to the Court without hear and is

deprived of getting a fair judicial process in any Court.

285. Plaintiff is in a destitute, homeless condition, and has been without proper shelter or

access to living necessities, where Plaintiff immediate protection from the extrinsic fraud

upon the Court is needed, in order to be able to receive any other relief Plaintiff is in

desperately need.

The Plaintiff does hereby set forth as his Causes of Action the following claims, to wit;

CAUSES OF ACTION

COUNT ONE DEFENDANT’S VIOLATION OF PLAINTIFF’S CIVIL RIGHTS

PURSUANT TO 42 U.S.C. § 1983

286. Plaintiff repeats and reaffirms each and every allegation contained in paragraphs 1

through 285 above, as if fully set forth herein.

287. Defendant County Attorney David Lee Darwin, Defendant Attorney Rebecca Baldwin

Montello, Defendant Attorney Gregg D. Weinstock, Defendant Attorney Jeffrey B. Siler,

Defendant Attorney Terence S. Hannigan, Defendant Attorney Patrick T. Burke,

Defendant Judge Vincent L. Briccetti, Defendants Kiryas Joel Community Ambulance

Corp., County of Orange, David Rubenstein, Atty. Kim Pavlovic, Christine Brunet, Atty.

Stephanie Bazile, Atty. John F.X. Burke, Atty. Maria Patrizio, David Hollander, Miriam

Teitelbaum, John Does 1 – 95, and Jane Does 1 - 20, in their capacities as State run

entities and/or agents of the State of New York or the various political subdivisions

contained therein, and acting under the Color of Law, did, both individually and in

  46

collusion with one another, deprive the Plaintiff of his Constitutional Rights pursuant to

42 USC §1983 by and through the 14th Amendment to the United State Constitution.

288. The various Defendants, acting jointly and severally, in violation of the Plaintiff’s Civil

Rights, unlawfully deprived him of his freedom, without affording him Due Process

under the law, at various times since, on or about April 14, 2010, and continuing to this

time in that they, without cause, blocked Plaintiff from receiving a fair judicial process in

the original action proceedings.

289. The various Defendants, acting jointly and severally, deprived the Plaintiff of his

Constitutional Right at various times since about April 11, 2012 in that they severed

Plaintiff's access to Court and justice, and mislead Plaintiff about his Constitutional

Rights.

290. The various Defendants, acting jointly and severally, deprived the Plaintiff of his

Constitutional Right to a fair and just procedure in his action, by influencing the judicial

system not to rule in accordance to the law enshrined in the Sixth Amendment of the

United States Constitution.

291. The various Defendants, acting jointly and severally, in violation of the Plaintiff’s Civil

Rights, unlawfully deprived him of his freedom, without affording him Due Process

under the law, at various times since, on or about April 14, 2010, and continuing to this

time in that they, without cause, facilitated and, in fact, confined the Plaintiff to Bellevue

Hospital Center, in violation of Plaintiff’s rights and interests.

292. Defendants, acting jointly and severally, in furtherance of conspiracy they hatched

together to compel the Plaintiff into accepting their unwarranted demands, deprived the

Plaintiff of his unenumerated Constitutional Right to raise his children in a manner that

  47

he deems proper and in his children’s best interests, and deprived the Plaintiff of

reasonable and unfettered access to his children.

293. The Defendants, in cooperation with religious interests, deprived the Plaintiff of his

Constitutional Rights for reasons that are based on the tenets of the religious community

prevalent in the area and contrary to the interests of the Plaintiff.

COUNT TWO DEFENDANTS ACTING IN CONCERT TO DEPRIVE PLAINTIFF OF HIS

CONSTITUTIONAL RIGHTS PURSUANT TO 42 U.S.C. 1985.

294. Plaintiff repeats and reaffirms each and every allegation contained in paragraphs 1

through 285 above, as if fully set forth herein.

295. Defendant County Attorney David Lee Darwin, Defendant Attorney Rebecca Baldwin

Montello, Defendant Attorney Gregg D. Weinstock, Defendant Attorney Jeffrey B. Siler,

Defendant Attorney Terence S. Hannigan, Defendant Attorney Patrick T. Burke,

Defendant Judge Vincent L. Briccetti, Defendants Kiryas Joel Community Ambulance

Corp., County of Orange, David Rubenstein, Atty. Kim Pavlovic, Christine Brunet, Atty.

Stephanie Bazile, Atty. John F.X. Burke, Atty. Maria Patrizio, David Hollander, Miriam

Teitelbaum, John Does 1 – 95, and Jane Does 1 - 20, in their capacities as State run

entities and/or agents of the State of New York, or the various political subdivisions

contained therein, and acting under Color of Law, did, both individually and in collusion

with one another, deprive the Plaintiff of his Constitutional Rights pursuant to 42 USC

§1985.

296. The various Defendants, acting jointly and severally in pursuance of conspiracy, deprived

the Plaintiff of his Constitutional Right at various times since about April 11, 2012 in that

  48

they severed Plaintiff's access to Court, and mislead Plaintiff about his Constitutional

Rights.

297. The various Defendants, acting jointly and severally, deprived the Plaintiff of his

Constitutional Right to a fair and just procedure in his action, by influencing the judicial

system not to rule in accordance to the law enshrined in the Sixth Amendment of the

United States Constitution.

298. The Defendants acted in concert to facilitate the depravation of the Defendant’s

Constitutional Right to his freedom by acting to place him, on or about July 18, 2011 in

Bellevue Hospital Center, a secure mental facility, thereby depriving the Plaintiff of his

personal freedom. The Defendants, in furtherance of conspiracy they hatched together to

compel the Plaintiff into accepting their unwarranted demands, acted in concert to

deprive the Plaintiff of his unenumerated Constitutional Right to raise his children in a

manner that he sees fit and, further, have continued to deny him reasonable, unfettered

access to his children. The Defendants, in cooperation with religious interests, deprived

the Plaintiff of his Constitutional Rights for reasons that are based on the tenets of the

religious community prevalent in the area and contrary to the interests of the Plaintiff/

COUNT THREE FALSE ARREST WITHOUT WARRANT IN VIOLATION OF

FOURTH AMENDMENT TO THE CONSTITUTION

299. Plaintiff repeats and reaffirms each and every allegation contained in paragraphs 1

through 285 above, as if fully set forth herein.

300. Defendant County Attorney David Lee Darwin, Defendant Attorney Rebecca Baldwin

Montello, Defendant Attorney Gregg D. Weinstock, Defendant Attorney Jeffrey B. Siler,

Defendant Attorney Terence S. Hannigan, Defendant Attorney Patrick T. Burke,

  49

Defendant Judge Vincent L. Briccetti, Defendants Kiryas Joel Community Ambulance

Corp., County of Orange, David Rubenstein, Atty. Kim Pavlovic, Christine Brunet, Atty.

Stephanie Bazile, Atty. John F.X. Burke, Atty. Maria Patrizio, David Hollander, Miriam

Teitelbaum, John Does 1 – 95, and Jane Does 1 - 20, in their capacities as State run

entities and/or agents of the State of New York and acting under the Color of Law, or the

various political subdivisions contained therein, did, both individually and in collusion

with one another, intentionally cause Plaintiff to be unlawfully arrested without a warrant

and without any probable cause.

301. The Plaintiff was wrongfully arrested by Defendants on or about June 6 , 2012. th

302. The Plaintiff was actually harmed in that he had to undergo acute mental suffering, fright,

shame, and mortification from the indignity and disgrace, consequent upon his illegal

detention; and

303. The Defendants’ conduct was substantial factor in causing Plaintiff’s harm.

COUNT FOUR WRONGFUL EVICTION FROM HOME IN VIOLATION OF FOURTEENTH

AMENDMENT (DUE PROCESS CLAUSE) TO THE CONSTITUTION

304. Plaintiff repeats and reaffirms each and every allegation contained in paragraphs 1

through 285 above, as if fully set forth herein.

305. Defendant County Attorney David Lee Darwin, Defendant Attorney Rebecca Baldwin

Montello, Defendant Attorney Gregg D. Weinstock, Defendant Attorney Jeffrey B. Siler,

Defendant Attorney Terence S. Hannigan, Defendant Attorney Patrick T. Burke,

Defendant Judge Vincent L. Briccetti, Defendants Kiryas Joel Community Ambulance

Corp., County of Orange, David Rubenstein, Atty. Kim Pavlovic, Christine Brunet, Atty.

Stephanie Bazile, Atty. John F.X. Burke, Atty. Maria Patrizio, David Hollander, Miriam

  50

Teitelbaum, John Does 1 – 95, and Jane Does 1 - 20, in their capacities as State run

entities and/or agents of the State of New York, and acting under the Color of Law, or the

various political subdivisions contained therein, did, both individually and in collusion

with one another, wrongfully evict Plaintiff from his marital home on or about January

26th, 2013 in pursuance of a false protection order, obtained from court on the basis of

same old false charges, which the Defendant Miriam Teitelbaum had previously admitted

to never having filed.

306. The Defendant’s intentionally caused the Plaintiff to be wrongfully evicted from his

home with an ulterior objective of causing harm to the Plaintiff.

307. The Plaintiff was actually harmed in that he was rendered homeless during sub-zero

temperatures, with no ability to take anything but the clothing Plaintiff had on at the time.

308. The Defendant’s conduct was a substantial factor in causing Plaintiff’s harm.

COUNT FIVE ABUSE OF PROCESS

309. The Defendant’s conduct was a substantial factor in causing Plaintiff’s harm.

310. Plaintiff repeats and reaffirms each and every allegation contained in paragraphs 1

through 285 above, as if fully set forth herein.

311. Defendant County Attorney David Lee Darwin, Defendant Attorney Rebecca Baldwin

Montello, Defendant Attorney Gregg D. Weinstock, Defendant Attorney Jeffrey B. Siler,

Defendant Attorney Terence S. Hannigan, Defendant Attorney Patrick T. Burke,

Defendant Judge Vincent L. Briccetti, Defendants Kiryas Joel Community Ambulance

Corp., County of Orange, David Rubenstein, Atty. Kim Pavlovic, Christine Brunet, Atty.

Stephanie Bazile, Atty. John F.X. Burke, Atty. Maria Patrizio, David Hollander, Miriam

  51

Teitelbaum, John Does 1 – 95, and Jane Does 1 – 20, in their capacities as State run

entities and/or agents of the State of New York, and acting under the Color of Law, or the

various political subdivisions contained therein, did, both individually and in cooperation

with one another, abuse the process of law by bringing false criminal charges against

Plaintiff in Orange County Family Court on January 19, 2013, obtaining from court a

false order of protection on the basis of those charges, and having served that order of

protection along with set of false charges on Plaintiff by the Sheriff department on or

about January 26, 2013.

312. The Defendants thus intentionally used this legal procedure to terrorize, intimidate, and

frighten Plaintiff into complying with their unreasonable demands and not pursuing this

action.

313. The Plaintiff was harmed as a result of Defendants’ aforesaid abuse or process in that

Plaintiff was, at first, unlawfully evicted from his marital home, and then from Kiryas

Joel, and finally, he has been rendered homeless, without access to court and/or justice.

COUNT SIX NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS ON PLAINTIFF

BY TORTUOUS ACTS OF DEFENDANTS

314. Plaintiff repeats and reaffirms each and every allegation contained in paragraphs 1

through 285 above, as if fully set forth herein.

315. Defendant County Attorney David Lee Darwin, Defendant Attorney Rebecca Baldwin

Montello, Defendant Attorney Gregg D. Weinstock, Defendant Attorney Jeffrey B. Siler,

Defendant Attorney Terence S. Hannigan, Defendant Attorney Patrick T. Burke,

Defendant Judge Vincent L. Briccetti, Defendants Kiryas Joel Community Ambulance

Corp., County of Orange, David Rubenstein, Atty. Kim Pavlovic, Christine Brunet, Atty.

  52

Stephanie Bazile, Atty. John F.X. Burke, Atty. Maria Patrizio, David Hollander, Miriam

Teitelbaum, John Does 1 – 95, and Jane Does 1 – 20, in their capacities as State run

entities and/or agents of the State of New York, and acting under the Color of Law, or the

various political subdivisions contained therein, did, both individually and in cooperation

with one another, in willful disregard for the Plaintiff’s and the Plaintiff’s family’s well

being, act negligently in a manner designed to inflict emotional distress on the Plaintiff

and to cause harm to his spiritual, emotional, and physical well being.

316. The Defendants negligently inflicted emotional distress on the Plaintiff to further the ends

of certain Defendants by conspiratorially removing the Plaintiff’s children from the

custody and care of the Plaintiff and his wife.

317. The Defendants acted in concert to force a separation and potential divorce on the

Plaintiff and his wife by offering to reunite the Defendant Miriam Teitelbaum with the

children in exchange for her separating from and divorcing the Plaintiff. The negligent

actions of the Defendants caused the Plaintiff to suffer emotional distress.

318. The Plaintiff continues to be separated from his family because of the negligent actions of

the Defendants and continues to suffer ongoing emotional distress.

COUNT SEVEN PLAINTIFF SUBJCTED TO CRUEL, INHUMAN AND DEGRADING

TREATMENT IN VIOLATION OF FIFTH, EIGHTH, AND/OR FOURTEENTH AMENDMENTS TO THE CONSTITUTION

319. Plaintiff repeats and reaffirms each and every allegation contained in paragraphs 1

through 285 above, as if fully set forth herein.

320. Defendant County Attorney David Lee Darwin, Defendant Attorney Rebecca Baldwin

Montello, Defendant Attorney Gregg D. Weinstock, Defendant Attorney Jeffrey B. Siler,

  53

Defendant Attorney Terence S. Hannigan, Defendant Attorney Patrick T. Burke,

Defendant Judge Vincent L. Briccetti, Defendants Kiryas Joel Community Ambulance

Corp., County of Orange, David Rubenstein, Atty. Kim Pavlovic, Christine Brunet, Atty.

Stephanie Bazile, Atty. John F.X. Burke, Atty. Maria Patrizio, David Hollander, Miriam

Teitelbaum, John Does 1 – 95, and Jane Does 1 – 20, in their capacities as State run

entities and/or agents of the State of New York, and acting under the Color of Law, or the

various political subdivisions contained therein, both individually and in collusion with

one another, have intentionally subjected Plaintiff to cruel, inhuman and degrading

treatment by taking his children away from him, causing his false and warrantless arrest,

effectuating his wrongful eviction from home, based on false protection order, and

bringing false, fabricated and utterly baseless criminal charges against Plaintiff with

ulterior objective to terrorize and intimidate him into complying with the Defendants’

unreasonable demands and withdrawing this action.

321. As a result of the cruel, inhuman and degrading treatment meted out to him by

Defendants, Plaintiff has been constantly harmed in that he has been made to suffer acute

mental torture and trauma, besides deprivation of home, family, children, and friends.

322. The Defendants’ conduct was a substantial factor in causing Plaintiff harm

COUNT EIGHT INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS ON PLAINTIFF BY

TORTUOUS ACTS OF DEFENDANTS

323. Plaintiff repeats and reaffirms each and every allegation contained in paragraphs 1

through 285 above, as if fully set forth herein.

324. Defendants Juda Katz, Chaya Katz, Yoel Tennanbaum, Bluma Tennanbaum, David

Hollander, and Miriam Teitelbaum, by virtue of their familial relationship with the

  54

Plaintiff, conspired with one another to facilitate their own goals to separate the Plaintiff

and his wife and children, and in doing so Intentionally Inflicted Emotional Distress on

the person of the Plaintiff.

325. Above named Defendants, acting in collusion with one another, took custody of the

Plaintiff’s children from the Plaintiff and his wife by adopting unscrupulous means, and

caused those children to call others, not their mother and father, mommy and daddy,

thereby intentionally inflicting emotional distress on the Plaintiff.

326. Defendants, acting in collusion with one another, have sought to divide the Plaintiff from

his wife by counseling her to divorce her husband, and by using the Plaintiff’s children as

an incentive to do so.

327. Defendants have caused false and misleading information to be disseminated throughout

the local and close knit Hasidic Community, attempting to bring dishonor and shame on

the Plaintiff and thereby to Intentionally Inflict Emotional Distress on the Plaintiff.

328. Defendants have acted in connivance with one another to permanently deprive Plaintiff of

access to his children, and in doing so, have Intentionally Inflicted Emotional Distress on

the Plaintiff.

COUNT NINE EXTRINSIC FRAUD

329. Plaintiff repeats and reaffirms each and every allegation contained in paragraphs 1

through 285 above, as if fully set forth herein.

330. Defendant Kiryas Joel Community Ambulance Corporation, in collusion with Defendant

attorneys; namely, David Lee Darwin, Rebecca Baldwin Montello, Gregg D. Weinstock,

Jeffrey B. Siler, Terence S. Hannigan, Patrick T. Burke, and other co-Defendants, by

misusing the huge political influence wielded by the community of Village Kiryas Joel

  55

and its leaders, managed to establish a connection with Defendant Judge Briccetti, as a

result of which Defendant Judge Briccetti became biased against Plaintiff.

331. Later, Defendant Judge Briccetti, acting under extraneous influence, not only participated

in furthering the object of aforesaid conspiracy, but also stopped performing his neutral

judicial function, and eventually issued a Memorandum of Decision and Order on July

2nd, 2013 whereby he unceremoniously dismissed the original action with prejudice, after

allowing the original Defendants’ Motions to Dismiss and rejecting the Plaintiff’s

Motions; including, his Motion to file Modified Amended Complaint/Supplemental

Pleadings, without giving Plaintiff a fair opportunity of being heard.

332. As such, Defendant Judge Briccetti’s aforesaid Memorandum of Decision and Order

dated July 2nd, 2013 is, in fact, an order produced by committing extrinsic fraud on the

Court; therefore, it is void, non est, and is liable to be set aside.

333. Because the July 2nd, 2013 Order is vitiated by fraud, in which Judge Briccetti himself is

involved, and because Plaintiff was never given the rightful opportunity of being heard in

the original action, Plaintiff has no other remedy at law than to invoke the provisions of

Rule 60(d) of Federal Rules of Civil Procedure by bringing this independent action in this

Court to seek protection of his Fundamental Rights that are being violated by Defendants

PRAYER FOR RELIEF

WHEREFORE, Plaintiff prays for consequential, compensatory, statutory damages

to adequately compensate Plaintiff for his damages, with attorney’s fees, costs of suit, an award

of damages as allowed under 42 U.S.C. §1988, and all such other costs as this Honorable Court

  56

deems just and appropriate under the circumstances of this case. Additionally, the Plaintiff seeks

injunctive relief barring the Defendants from interfering with the Plaintiff’s peaceful enjoyment

and from continued interference in his life as any and all injunctive relief that this Court deems

just and equitable.

PLAINTIFF DEMANDS TRIAL BY JURY ON ALL COUNTS

Dated at Monroe, in the County of Orange and State of New York this 29th day of

July 2013.

_______________________________ Jacob Teitelbaum, Plaintiff Pro Se c/o Ben Friedman 5 Leipnik Way, #102 Monroe, New York, 10950 Tel. No. 845-782-7830

  57

Exhibit ‘A’

  58

  59

  60

  61

  62

  63

  64

Exhibit ‘B’

  65

  66

Exhibit ‘C’

  67

  68

  69

Exhibit ‘D’

  70

  71

  72

Exhibit ‘E’

  73

  74

 

  75

May  11, 2012 (Erroneously dated to May on page 1) Yiddish omitted   To whom this may concern  To the court of Monroe, the KJ public safety, and KJ EMS, and to bais din.  I have a legal problem of harassment from two people of the village of kiryas joel, they are harassing me, my phone line and my husband, for two consecutive years, I was trying to get help but my efforts were in vein, please help me bring these two people to justice.  Benjamin Friedman 3 Leipnik way Monroe NY 10950, Mendel Blum address unknown, he  is constantly floating around.  I did try numerous times to call police on him and all kind of rabbinical help. Until he finally trapped my husband by exhausting him and instigating him.  I never will and never pressed charges against him, he is a special character and battered, no one shows up for us, that is why he gets caught in their laps, please bring these two  criminals to justice as soon as possible.  I  hereby  withdraw  all  charges  against  my  husband  which  I  never  charged  against  Jacob Teitelbaum,  (Rabbi Moshe Jacob Shamshon Teitelbaum).  Sincerely Miriam Teitelbaum 

  76

Exhibit ‘F’

  77

  78

  79

  80

Exhibit ‘G’

  81

  82

Exhibit ‘H’

  83

  84

  85

Exhibit ‘I’

  86

  87

  88

Exhibit

‘J’

  89

  90

  91

  92

  93

  94

  95

  96

  97

Exhibit ‘K’

  98

  99

  100

Exhibit ‘L’

  101

  102

  103

Exhibit

‘M’

  104

  105

  106

  107

  108

  109

  110

  111

  112

  113

  114

  115

  116

  117

Exhibit ‘N’

  118

  119

  120

  121

  122

  123

  124

  125

  126

  127