Archive for November, 2012

This interlocutory appeal to change the venue, was denied by N.J. appellate, and pending in N.J. Supreme Court

November 4, 2012

First, the motion letter

Superior Court, Appellate Division

Docket No. 303136

 

In the matter of the estate

Of Vera Fedorov, Deceased

 

Vic Fedorov Pro Se Appellant

219 Yardville-Allentown Rd

Hamilton N.J. 08620

201 232-1154

v

Veronica Savage, Mark Fedorov

C/o Ron Fraioli Esq.

304 Hackensack St

Wood-Ridge N.J. 07075

201 438-5522

 

Notice of Motion for Leave to Interlocutorily Appeal

Order not Changing Venue, of July 19th 2012, by Judge

Velazquez of Hudson County Superior Court per Rule 4:80

 

To The Appellate Court of N.J. From Vic Fedorov, Pro Se Appellant:

Through this brief and appendix, we seek to inlocutorily appeal, the decision of a Hearing by Judge Velazquez to deny the changing venue to Mercer County, where Vera Fedorov was Domiciled.

Lying on Probate that Vera had an apartment in Hoboken, when her death certificate said Princeton, does not follow rules, undermines credibility, and is not a dispute or controversy for Superior Court to determine. There is nothing to determine. It is obvious and uncaught, shows rarefied judicial airs. There are not two sides to this like a dispute. It is fraud. There is nothing sensational to this, it is not a controversy, it is a wrong. It is not in dispute being too material and verifiable crime. There is nothing to Determine, Superior Court is left with merely discharging and disposing of its duties. Fraud does not rise to the level criteria for Superior Court determination of 4:82, and should be immediately inquired into it and disposed of. This is not “doubt” that requires analysis or has moral shades. This is crime, that is obviously wrong.

Judge Velazquez said it was too late. But this fraud has been cited repeatedly since the letter of complaint in the second sentence, and should have been discharged and disposed of, by any judge, scared by fraud. Hudson County venue was never considered good by anyone that knows where Vera resided, and not known as landlord. There were just higher priorities of gaining discovery since I was being shown nothing, and fear and know crime. My siblings did not and do not appear to be understanding their interests, or comprehending the situation. And I fear people have long been behind them, oppressing them, to this purpose here, and I wanted concern of the courts regarding suspicions; A docket number and judge offered these hopes.

Yet is not the deck stacked against me? I was a farmer, and new to fraud. Crime takes time to deal with deception. Logically the point of fraud to obtain Hudson venue would be to work with a judge to ignore the suspicions and falsehood of the will and situation. Judge Olivieri, who retired after the first Jan 27th hearing, and Judge Velazquez, have not probed into any allegations. After the hearing for Reconsideration to change executor, May 4, 20122, I motioned to change the venue, filing June 20th 2012.

Judge Velazquez did not even inquire into the fraud, at the July 19th hearing. Such lack of concern demonstrates a form applicable to other cases and issues before him.

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Then                           Overview (optional)

I am doing more than trying to protect family property; my mother’s murder, my younger brother and sister’s state of mind, to be along so, indicates something is seriously, seriously wrong. There are criminal elements behind them; and nieces and nephews to care about, as well as all disrupted. My brother and sister are not like this, to not work with me as a family regarding family wealth management.

A calm inquiry, into the form, of the control, over so many people aware, I believe, what I say is true, would be greatly beneficial, as it is a victimizing form of obeisance. Does “God” explain the lack of reason? Does our systemic ignorance make this possible? There is something to figure out here? Why can’t my siblings come to the table and work with me, easily? Why was probate applied for in Hudson County, where Vera did not ever spend nights, or even work for whole seasons in Hoboken where she owned properties?

While the issue here is handling fraud, fraud and unfair trial, are very close, in the rules of changing venue PB9 R.3.2.  The criminal nature has made discovery difficult, and subpoening, not responded too. PA252 The case requires a concerned court, who may issue subpoenas through the clerk, since I am not executor, PB9, enforce discovery requests and sound out inquiries, PA152,and offer the opportunity to work out this tragedy. This does not emerge from a court covering up a suspicious death and ensuing false will, outrageous and cruel as this may be. It is beyond cruel, it is depraved.

The court did not sound out the thinking and behavior of defending party regarding numerous suspicions once. The legal system has enabled criminals hiding behind it. Is this is widespread? The appropiate nature to our government?

My trustee and trust is not paying for my general counsel, I have few funds.  This litigation was steered by defendants into the wrong venue, with voidable decisions and orders, because of the fraud on the probate applicationPB9. I’ve had to travel to Jersey City from Trenton numerous times, because Defense lied where Vera was domiciled under oath to qualified oath-takers.PB8,9,202

The issues should have been worked on through pleadings initially.

What judge, and why, would want another county to examine his work, and frauds in his court?

What judge would not inquire into fraud, or find it suspicious the lawyer, who advised lying, and not of record, escape blame?

On Aug 10, 2012, there was a hearing for summary judgement that dismissed the case. Defense demanded medical records Vera was on three medications, a respirator, traumatized, near death, anxious and a quadrapylygic. These facts are true, and relevant to any attorney. The nature of this case, with its intimidation, (including from the probate fraud) has made it difficult to effectively deal with anyone who knows something. I followed instructions regarding subpoenas. There has been no production of records from Kessler Institute of Rehab, and while the rules encourage waiting for relevant affadavits and records, the case was dismissed, unfairly.

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Then Statutes and rules and cases cited

Citation of Cases, Statutes and Rules

Diodata v. Camden County Park Commission, 136 N.J. Super. 342, 346, A,2d 100 (App. Dic. 1975)

“While venue provisions may be subjecct to change upon a showing of proper circumstances, they do express strong policy considerations not to be lightly regarded”

Gray v. Cholodenko 34 N.J. Super. 190, 111, A.2d 918 (App. Div. 1955)

A perjurious deposition, purposely false and willfully given on partof an attesting witness in proving wills, if proofs are clear, convincing and satisfactory of perjury, will be held fraud upon the coust and ground for vacating such probate decree.”

State v. Collins, 2 N.J. 406, 67 A.2d 158 (1949)

“Motions for a change in venue in criminal prosecution or civil action or for a foreign jury are addressed to court’s sound discretion guided by law, and excercise of the discretion cannot be arbitrary, vague or fanciful”

Rules of The Court

Rule 4:80-1:C (c) “The application for probate of a will for letters of administration shall be filed with the Surrogate Court of the county in which the decedent was domiciled at death”

Rule 4:3-3 Change of Venue in the Superior Court: a) By Whom ordered: Grounds. In actions in the Superior Court, a change of venue may be ordered by the Assignment Judge, or the designee of the Assignment judge of the county in which Venue is laid…..

1) If the venue is not laid in accordance with R.4:3-2, or 2) if there is substantial doubt that a fair and impartial trial can be had in the county where the venue is laid or 3) for the convenience of of parties and witneses in the interest of justice.

4:83 a) Where the surrogate’s court may not act. In an action brought because the Surrogate’s Court is barred from acting by 4:82, venue shall be laid in that county.

4:82 Matters in which the Surrogate Court may not act….1) a caveat has been filed in it before the entry of judgement 2) doubt arises on the face of the will…3) the application is to probate a writing intended as a will…4) The application is to appoint an administrator…5) A dispute arises before Surrogate Court as to any matter 6) The surrogate certifies the case to be of doubt or difficulty.

1:9- 1 A subpoena may be issued by the clerk of the court or by an attorney or party in the name of the clerk.

4:26-2 a) Representation by guardian…a minor or mentally incapacitated person shall be represented in an action by the guardian of either the person or the property…..or if no such guardian has been appointed….by a guardian ad litem appointed by the court..

4- The court may appoint a guardian ad litem for an…alleged mentally incapacitated person on its own motion.

4:50 1) …the court may relieve a party….from final judgement or order for the following reasons; c) fraud…or other misconduct of an adverse party..

Statutes

3B: 11-36 Findings, declarations regarding special needs trust. 1A) It is in the public interest to encourage persons to set aside amounts to supplement and augment assistance provided by government entities to persons with severe chronic disability.

2c:5-2e Conspiracy: Renunciation of purpose. It is an affirmative defense which the actor must prove by a preponderance of evidence that he, after conspiring to committ a crime, informed the authority of the existence of the conspiracy and his participation therein, and thwarted…the commission of any offense in furtherance of conspiracy…

3B: 1-9 Effect of fraud and evasion

Whenever fraud has been perpetuated in connection with any proceeding or in any state filed under this title….any person injured may obtain appropiate relief against the perpetratro of the fraud, or restitution from any person benefitting from the fraud, whether innocent or not.

3B:2-2 General authority of Superior Court as to probate matters

The Superior Court shall have full auhtority to hear and determine all controversies respecting wills, trusts, and estates, and full athority over fiuciaries, and also authority over all other matters andd things as are submitted to its determination under this title

3B:2-3 The Superior Court shall have jurisdiction to hear disputes or doubts arising before the surrogate or in the surrogate’s court of a county, to review any order, determination or judgement of the surrogate or surrogate’s court of a county and upon the review, to hear and determine the matter, and to grant relief from…..any order, determination or judgement of the surrogate…

3B: 10-13 Duty to apply in this state for original letters of administration

….Any person having knowledge of the grant in a foreign jurisdiction of original letters of administration upon the estate of a person dying resident in any county of New Jersy, shall give information thereof to the Superior Court.

The court may direct the clerk of the court to issue and have served suppoenas or an order to show cause requiring the appearance before it, ….., of any persons having any interest in the estate, and commanding them to abide the order of the court. The matter of the grant of letters of administration shall be wholly within the jurisdiction of the court.

3B:2-6 Oath; Affadavit; deposition or proof.

Any oath, affadavit…required to be made or taken in any proceeding before a surrogate, …..may be made and taken before the surrogate or before any individual authorized by law to administer oaths.

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Then there is a chapter, in form, of Procedural History of the The Case, and then Material Facts, and then Legal Arguments

 

Concise Procedural history with a statement of the nature proceedings with reference to the judgement

I was very close to my mother and an elaborate relationship with her. We both started small businesses, had friends and people we hired and worked with, were unmarried, and between her people and my people, and her homes in Sanibel Fl, Manhattan, and Princeton N.J., and the farm in Long Valley N.J. I managed since 2005, over the years our households intersected symbiotically and we supported and were useful to one another. PA1, PA215

I was working in Saratoga N.Y. with goats, chickens and organic vegetables when I learned my mother was paralyzed from the stairs, Aug 17th, 2010. I came back, and until Febuary, was with her 50 hours a week, as she wanted, and rented rooms in Newark to be near her rehabilitation in West Orange.

While I care for her, my brother and sister looked after her business and affairs, and while they were suspicious, I trusted them. It was only after Vera passed, and her estate handled with such conspiracy, exclusion and lack of transparancy, that I saw her injury was not accident, and fits in with the designs on her wealth through undocumented divestment and suspicious will from 1994. PA48 I only learned the will would not unite the family and care about more than her children, and was from 1994, unsigned until Oct 7 2010, with no lawyer on the will, witnesses known to family, on medications, traumatized, near death, a respirator and incredibly an, two months after Vera passed March 22, 2011.

I could not believe it. My money was in a trust controlled by Mark. I had no say in her business I had worked extensively for, an and off, through the years. When there was no conscience, and time expiring, I filed a complaint in Hudson County where probate was, which arrived Oct 24, 2010.

A hearing was set for January 13th 2012. A bomb threat postponed it to January 27th. A court clerk called and advised amid my numerous concerns, of which that Vera never spent nights in Hoboken where probated, the second sentence, to make the hearing about managing the estate till trial.

Despite my suspicions, Judge Olivieri said he did not want to disturb the will, even though letters of administration had no right to go through Hudson County Surrogate. He said managing the estate was about paying bills, when it is about making sure someone trustworty,  who is not taken advantage of and oppressed, protects the estate. He said I could file for reconsideration. I saw his decision as a real politic time could heal,

I stayed in jurisdiction. Discovery, which only accounts for less than half of my mother’s wealth and business, and shows mutual funds down five million,PA248, though tax returns are not shared to confirm this, PA252 had not arrived by the May 4 hearing. I had new evidence.PA163, April 2010 emails documenting my mother’s desire for 6 million set aside whose interest would be for future generations and the family in general: evidence that she extensively did use a lawyer, that her not wanting a lawyer for the will, was not sound.PA166,169 Witness signature differed printed statement. These could have been inquired into and sounded, as case law I submitted advocates as doubt shifts.PA152

Judge Velazquez first said I had no case work, then that it was insensible. Then he said my new evidence was old issue, and he didn’t want to revisit Olivieri’s reasoning. PA 269

I was not getting a fair trial and finally focused on venue, and the fraud particularily on the probate application, though there is fraud in their depiction of me as paranoid skitzophrenic, unable to work, etc, PA31, PA38, PA91 which was also not inquired into in previous hearing. I obtained transcripts and filed to change venue June 20th 2012.

On July 19th 2012, Judge Velazquez determined it was too late in the case to change the venue, appealed here. PA244

This fraud enables a foreign county, Hudson, whereby precisely Hudson’s County’s foreign nature enabled an overlooking and covering up of a suspicious will; nor examined the logical oppression of my siblings, who with any degree of freedom, would not be so unconstructive and negative or party to the situation. Imagine their state of mind and oppressed charactor. They know I work and care and am very trusted.

Money is not accounted for, no documentation of Vera’s wealth, tax returns, monthly revenues and expenditures of her 50 apartment units not shared, and I not put to work, whereas my mother was always making me useful, and had strict  guidelines about her money and business she worked so hard and long for. People I have known years and decades through her business, and, or would know about my allegations, can’t be reached, and seem scared.PA143

Even if you take Judge Velazquez’s claim too much time has passed to change venue, at face value; the fraud should still be inquired into. There are other frauds as well. Not caring about one, does not fit caring about aný. There is no integrity or trust to probating and lying about where Vera lived. How can you believe their claims now she was of sound mind, and unconstrained?PA204

Statute 3B:10-13 PB10Fraud of this nature, is to be reported, and then encouraged to be investigated. The judge did not question the fraud, why, or how, or what that says about their integrity. It is one thing to maintain venue, another to not inquire into fraud. PA244, PA280

How can their claim Vera was of sound mind and unconstrained be credible, next to an easily verifiable fraud, next to her death certificate listing Princeton? PA201 How can you expect Medical Records Directors, and administrative assistants to Vera, and her tax accountants, to comply with my requests and subpoenas, when the court is not looking into a lie, thus placing the case where the lie designs? The court is treating Vera as crudely as a landlord, and not the warm and caring and energetic woman with good friends she was.

It is our job to look into what happened, and by learning such, to help others.

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material facts

 

1) Vera Fedorov’s father fled Russian communism to Yugoslavia, where Vera was born in 1935. In 1940, he was captured by the German Nazi’s to repair aircrafts in Heidelberg, and Vera and her mother, Vera, moved to Heidelberg, which was not bombed, to be used as an Allied headquarters. She and her mother and father then made it to New York City in 1947. She taught at Woodbridge H.S., and worked procuring grants for Rutgers University until 1980 when Reagan budget cuts ended her job. She took some money her mother’s house left her, and invested in hoboken properties in 1981, taking out large renovation loans, and became a landlord, which she improved at each year, so by 2011, when she passed, she was worth 14 million dollars, and she worked hard and often for it. Some years I extensively helped her. Not marrying or reproducing  I helped her a lot, across the board, as a friend and family member. PA215

2) Her death was not natural. She was inured on the stairs, the night of Aug 17th 2010, found only 4pm Aug 19th and was a quadrapylygic, her vertabrae 5 and 6 fractured just above her breast. She was in intensive care in Trenton N.J. till mid September than near ICU for ten days, and then moved to Kessler Institute for Rehabilitation in West Orange N.J. till Febuary 3, 2011 when she moved to Princeton, and passed at Princeton Hospital March 22, 2011.

3) From 2005-2009 I was a small businessman producing and marketing organic potatoes in Long Valley N.J. In the three month off season, I often worked for and was in a household with my mother. In 2010 I ceased my own operations to travel and learn from different farms in nearby states. I was in Saratoga Springs N.Y. making goat cheese, raising chickens, and working another organic vegetable farm, Aug 17th 2010.

4) My brother, married, with two children in Allentown Pa, convinced my other to sell several buildings in 2006 and 2007 to put the money in mutual funds, giving her less work and more retirement. He and Vera and I looked after those mutual funds and quarterly statements. By 2009 they, to my recollection, tax returns have not been produced which would show this PA252* they were approaching 7 million. Now the mutual funds are in another mutual fund and worth 2.5 million. PA249 The monthly expenses and revenues from her buildings, like her old tax returns, are not shared with me, despite discovery requests. The lack of my exposure to what I helped look after many years is disturbing, and I feel brother and sister can not govern themselves in a situation where money is taken from him. This is a serious psychological claim, indicating a need for authority to determine if they act in his own interests, which my siblings don’t seem to do, as they can always work with me. I just want to make sure everything is OK.  As that doesn’t happen, I conclude serious problems.

5) In 2007, I believe, Mark said his position at Air Products of Allentown PA, was    eliminated, and in January 2010 he began assisting in Hoboken. Vera had moved out her Manhattan Apartment and she was preparing to sell her house in Princeton and move to another apartment in Manhattan upon its closing, which ocurred in July 2010. That winter of 09/10, I helped her move from Manhattan and improve Princeton for sale.

6) Veronica, her domestic partner Craig, her step-son Brandon 19, her two children with her first husband Dexter Savage, and a baby with Craig, moved to Princeton in early June 2010 from New Mexico. As I would stop by Vera’s and help her in between my agricultural jobs. I was painting a fire escape and living in an unfinished Hoboken apartment that first week in June 2010.

7) Vera lived an active life. She reunited with a cousin she hadn’t seen since 1940 who had moved to Chile, entertaining her and her daughter and son, and her daughter’s two college-age children, in May in Sanibel Fl, where she had a house, (and I joined them there for a week) and then in Princeton, and then several of them flew to Russia and were there two weeks.

7) On Monday and Tuesday August 15th and 16th, 2010, Veronica and her family had finished a move from Princeton to an apartment in Hoboken. The permits had finally come through allowing the last building my mother owned, which was not rented to yuppies or renovated, to be renovated and converted to condos, which Craig, being a contractor from Taos New Mexico, was entrusted with managing, for which his son Brandon helped.

8) I had worked on a farm in Virginia,  the last half of June and early July, came back to Vera’s, helped her to July 18th, and was intending to return after August after stints at farms in Connecticut and New York.

9) Upon hearing what happened to her I returned to N.J. and focused on assisting the nursing of Vera, often spending nights with her at Trenton. When Vera was at Kessler, I rented  nearby rooms in Newark and spent over 40 hours a week assisting nurses and spending time and nights with Vera, as she requested. Mark managed Hoboken, Veronica was occupied by children, and trying to make herself useful. I entirely trusted them regarding a will. They only showed me the will 2 months after my mother passed March 22, May 22, 2012. I  had no idea it was from 1994, and had no elaborate guidelines of intention for her legacy, of which she was proud. My brother also showed me a special needs trust allegedly signed by Vera May 15th 2012, which I had heard nothing about. Both documents did not have lawyer signatures on them. I do not have a chronic severe disability, PB9, PB69.

9A) The will remembers none of her friends, gives all to Veronica and Mark, mine in trust for Mark.  I am effectively excluded from her business and managment of her wealth and am not a voting member of surviving corporations. I have emails of her wanting her legacy consolidated for specific actions involving future generations, such as college or business start up or family vacations. PA48,  PA163

10) This will was drafted in 1994, see will, not signed, see discovery, and signed Oct 7 2010. She famously stayed in her 5th avenue apartment if she worked in Hoboken, Princeton, which was her primary residence, where voted, and was her residence on personal tax returns. She spent months at a time in Sanibel where she wanted to move.

11)  This probate fraud, lying about where she resided,  was perpetuated so the will would be looked at in Hudson County. My siblings do not have the wherewithal for this calculation or need for such construction. It is central to my case that there are people behind them, fronting them, long controlling them who broke them; because they are not simply showing me that the money is staying in the family and not being taken by those manipulating and controlling them. Who would do this to their mother and family? They do not want this situation. They are forced. This is something court must honestly, openly look into, to figure out how this sort of control is done, as it seems severe, and may be more common than known.

12)How can they be believed in their claim she was of sound mind and unconstrained PA202,204 when they lie about where she lived, she was definitely a quardrapylygic, the death certificatePA201 listed her residence as Princeton, and, according to them Interrogatory, she did not want a lawyer to come to the hospital and that I am a paranoid skitzophrenic unable to work.PA31, PA91 There convey several instances of fraud.

13) On June 22 I believe, they applied for probabate and were granted administration in Hudson County Surrogate Court. Rule 4:80 does not allow this, plus certifications, They claimed she lived at apt B2 913 Garden St Hoboken. She did not. She famously did not.PA202

14) Is this a dispute, or, ascertainable fraud? And if fraud, shouldn’t it be inquired into and not allowed by Superior Court. I have cited it often, and if a concern, could have been discharged, while I was concerned with discovery, and evidence of crime.

15) Don’t these transpirings show, the will was probated in Hudson County, to gain a judge and foreign jurisdiction that covers up and insures a suspicious will and circumstance? And doesn’t this show, my mother’s injury was no accident? The fraud upon Surrogate was not even inquired into, or resulted in any concern by Judge Velazquez.

15) I mentioned this in the letter to show cause, second sentence.PA1

16) While Judge Velazquez said it was too late, the deck is stacked, and my higher priorities of Discovery, Concern of Courts upon Suspicious Items and Crime, and the leverage of a docket number, made changing venue not as high a priority, though important. I applied for an emergent motion for the assignment judge to hear the motion to change venue, but Judge Payne, said there was no evidence behind the logic, the probate fraud was perpetuated to insure an unfair judge and courtroom.PA231 There is a lot I have to present at trial and require a fair court for its presentation.

18) For instance, I need help from the court with subpoenas so they are followed, as well as complying with discovery requests, PA252, 128, and inquiries into such things as witnesses to the will I can’t reach, why no tax returns produced, what we know about Vera Fedorov, as evidenced in emails of 2010 desiring 6 million set aside for general family benefits. The court needs hearings that sound out defendants thinking and behavior. Witnesses seem scared. People I’ve known decades, do not reach me back. Who would take such risks as the judge condones fraud, and does not sound out my allegations at hearings.

19) I worked extensively for Vera through the years.

20) The claim I am a paranoid skitzophrenic incapable of holding a job. That is neither true,  nor sound to assert.PA215,221,225

21) The money is being stolen from Mark and Veronica, they know they would have benefitted more than enough when our mother passed; so how they went along with this, is difficult to imagine.PB24

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Legal Arguments

 

LEGAL ARGUMENTS

Rules, eschatological dignity, not dispute, doubt, controversy, but fraud, crime, wrong; mandating following rules by Superior Court Judge.

L     If little rules, like probating in county deceased was not domiciled in, are not followed, there is a liklihood of larger, more important rules not being followed.PA196

Per Rule 4:80,PB8 Vera was not domiciled in Hudson County, that was and is a lie, to benefit the people behind my siblings with control in Hudson County. Vera last spent nights in Hoboken  in 1992. She resided in Mercer County. That was where she voted, and her personal income taxes listed.

There is an eschatological propiety and dignity behind this rule, of counties looking after their own; of knowing people as human  beings, not as a landlord.  HHudson county, a foreign county, is not looking after the deceased rights in credible devolution of legacy, but has taken over what she worked for and needs protection.

This fraud is not a doubt, where perspective comes into play, or a dispute, which has two sides, or a controversy; but a wrong, a fraud, and a crime devised to criminal purposes.  This fraud is not something to be determined or reviewed, for analytical content, but discharged and disposed of according to Rule 4:80.

OTHER FRAUDS AS WELL

There are other frauds. The will and trust was not shared or known to me till two months after Vera passed, thus perpetuating the fraud she wanted this will from1994. The fraud Vera gave money without guidelines is perpetuated by this will, as is the fraud, she did not have numerous friends and people she would have remembered. This will also fraudulently obscures how close Vera and I became through working together and sometimes sharing a household.

Not including me in the management of property I care about many years, is to perpetuate the Fraud Veronica and Mark are actually running the business and in control.

They claim she was of sound mind and unconstrained; yet she was on a respirator, paralyzed, and according to them, did not want to pay for a lawyer to come to Kessler Rehabilitation, as too expensive. That is not demonstrating sound mind, or unconstrained. PA202,204

Not using will witnesses the family knows, also perpetuates the fraud Vera wanted this will.  The witnesses were hospital administrators.

Their demand of medical records, I am having trouble acquiring, to justify Summary Judgement, perpetuates a fraud regarding her condition.PA252

Their denial of financial records, as of that not owned by Vera when she passed, perpetuates also the fraud Vera’s wealth has not been stolen from Mark and Veronica; As is not showing federal tax records of Vera’s last years.PA128

Not sharing emails between themselves and Vera before her injury, for the fraud they were getting along in 2010. And remember, Mark had just started in Hoboken in Januarý, and Veronica, who was in New Mexico, and her family, only came into N.J.  in June 2010. PA252

Their lies about me, paranoid skitzophrenia, with severe chronic disability, unable to work, is fraud to justify excluding me from financial matters and responsibilities. PA 31,38,91

The surrogate clerk in December who advised not focusing on Venue fraud, but executorship, engaged in fraud, for purpose of dismissing such motion later.

Surrogate Court’s ignorance of the discrepancy of the death certificate and probate application, regarding residence, is suspect, and the fraud that Surrogate is independant from this situation.

WHY FRAUD ON PROBATE APPLICATION

The probate fraud logically must be to insure a judge with Hudson County ties, to facilitate the cover up of a bad will and murder and exploitation of siblings. This causes the concern other families and people are victims of Hudson County this way.

One thing to not change venue, another to not inquire into fraud

3B:10-13  Judge Velazquez does not rise to a level of professional competence, when he asks defendants no questions about the lie on the probate application. How can we then expect concern of other frauds? Likewise, the defense has evaded the issue of fraud, nor had to admit they’ve done anything wrong in this whole process.

3B:10-13 mandates reporting this information, of one dying in one county, being probated in another, to the court which I did. Court is then expected to Subpoena interested people to fix this.

Also, logically, why doesn’t opposing counsel and admit the fraud was advised by Chris Garvin, PA143 the former estate lawyer, now tax attorney, who is not of record to this case now. Does opposing counsel represent my siblings, or Chris Garvin. Chris Garvin is from Wood-Ridge N.J., as is Ron Fraoili.

Why would a judge not want another venue and jurisdiction to inquire into Hudson County’s Surrogate’s admission of fraud? I submitted this tautology in an emergent motion to Appellate Judge Payne, requesting Hudson County Assignment Judge Peter Bariso hear the motion to change the venue and/or invalidate proceedings so far, which is the first option in the rules per rule regarding hearing motions to change venues. PA231

With this fraud, do Mark and Veronica have competent legal counsel

Do Mark and Veronic have competent legal counsel, and are they incapacitated by being in over their head, and unable truly to manage or look after their own interest? The two go together. If Mark and Veronica are being stolen from and coerced, the court needs to be sure they have a counsel of good authority able to give them choices, and make sure they understand the scopes of action available to choose from. PA19

This fraud, the advice that led to it,  is perfect example of third party liability, which does not seem explained to them. PA143

Mr. Fraoli should be explaining to them, “renunciation of purpose, 2C:52 where a conspirator in an affirmative defense, alert authorities as to the intent of a conspiracy to committ crimes”PB9

My brother and sister don’t seem advised they can share records and work with me, as a family Vera intended. That if people are behind them, they can be protected.

Crime takes time, caution, insight, overcoming

Crime takes time, caution, insight, overcoming. Our goal to heal and strengthen family and friends, and overcome a form and culture oppressing others as well.  There is brutality and long-term exploitation, I am moving through it, as best I can, with faith, construction, and the future and should not be stuck in wrong venue. They led the way here with lies and crime. Nor has one item of mine been inquired about. The nature of this case requires the leverage of the courts to pressure breaks, nudge freedom, diminish fear, support subpeonas and discovery requests, and from inquiry. Starting this case again, with the experience I have now, is good, not bad.

Good Reasons for not bringing up fraud in hearing January

I desired concern regarding suspicions, discovery, and leverage regarding crime and my family being on the level. I focused on the fraud at hand, after focusing on larger issues.

The Court has been unfair so far

PART G As rule 4:80 commands proper venue, so does 3:2, unfair trial. While making the timliness of venue considerations an issue, the courts could have discharged that issue prominently before I got around to it. I believe I have cited many instances and general tenor of unfairness.

There has been an unconcerned disposition regarding lying about where Vera lived.

Is this a nature of Hudson County? Cultural? This rises to the level of class action, if forms of agencies of Hudson County oppress or can oppress the people. We have to admit, my siblings were not strong enough to take on crime or a virtuous life; though God’s will be strong. Where too, is the reason, to a legal system, crime can hide behind? It stems from ignorance of what culture can be. The gall of missing what victims my siblings, co-workers, friends and family and the people are to this, is metaphysical, not individual.

How do my siblings agree to fraud, and agree to not admit it is wrong?

This may involve coercion, threat, electric shock, prostituting, homosexuality, lying about homosexuality, arranged marriages, a ring of criminals over several states, oppressing who they can. This case shows the anger of homosexuals who do not admit their homosexuality, and the lack of subjectivity or wherewithal that comes from being prostituted. It may show the vulnerabilities that lead to blackmail. It may show how shame is too great for some people to function for themselves, and tell people what they are going through. My siblings could have known the people behind them since the late seventies or early eighties. There could have been sexual abuse, degredation, beginning when Mark was ten and Veronica in High School, that was latched onto by manipulators, to this day. This is meant to come out.

 

 

 

 

 

 

 

 

oppossing response to this, was a paragraph, how if a case is dismiss, pending interlocutory appeals are no longer considered. Which is vexing argument with no basis in law. Appellate Court denied my interlocutory appeal, and this is very suspicious, and possibly crooked, subject to criminal influence

 

Vic Fedorov

219 Yardville-Allentown Rd

Yardville N.J. 08620  201 232 1154

Sept 12, 2012

Re: Estate of Vera Fedorov, Docket 303136

 

 

Dear Mr. Orlando:

There is no cited basis in rule or statute for  Ron Fraoili’s notion that an interlocutory appeal, of an order denying venue change, is moot upon dismissal of the case.

If the venue is changed, per fraud, the case is remanded to Mercer County, and it is not Judge Velazquez’a to dismiss; logically, the venue-issue, is pivotal regarding what judge and venue should have the right to dismiss the case.

I do not think defense here has any base in law. None was cited. Remember, they lied Vera had an apartment in Hoboken, on probate application. If so, this is harrassment. I honestly think this is a dishonest, vexing defense, neither candor to tribunal, R.1.6(b)(2), DR 7-102(A): What is warranted, in preventing crime, and RPC 8.4, (misconduct) to d) engage in conduct prejudicial to the administration of justice.

 

Thank You

Victor Fedorov

Accepted Interlocutory Appeal to Change the Venue to Mercer County from Hudson County, to the Supreme Court of N.J (granted docket number) .

November 3, 2012

This is an appeal to the Supreme Court of N.J. regarding a denied motion to change the venue to Mercer County where Vera was domiciled, and looking into the fraud that probated her legacy in Hudson County, and suspicions therein. As I was late in filing the complete papers, necessary letter and affadavit below, after which Interlocutory Appeal, to Supreme Court of N.J.  follows.

                                                                                             SUPREME COURT OF NEWJERSEY
Docket #
Vic Fedorov Pro Se
Plaintiff-Movant
         v.                                                                 CERTIFICATION
Mark Fedorov
Veronica Savage
C/O Ron Fraoili Esq.,
Defendant-Respondent
1) Regarding the estate of my deceased Mother, Vera Fedorov; as she was domiciled in Mercer County, I moved before Judge Velazquez to change venue, and that there was fraud in the probate application, which stated Vera had an apartment in Hoboken, of Hudson County. This is not true. Her primary residence was Princeton N.J.. She spent no nights in Hoboken.
2) Judge Velazquez denied the motion at the July 19th 2012 hearing. I calculated, the fraud was to ensure an unfair judge of foreign county where she owned 50 apartment units, to ignore many suspicions in the handling of her devolution, and I interlocutory appealed to Appellate Court.
3) This was filed timely. The motion was denied September 16th, by Appellate Court, filed September 17th, arrived at my residence September 19th, and received by me September 20, 2012. Because the legal facts and arguments I believe are fairly certain and strong, near irreparable damages, and constitutionally questioning the liberty Judges have under the Constitutions, I appeal to The Supreme Court of N.J..
4)  I work alone pro se, to interlocutory appeal to The Supreme Court of New Jersey,  as the suspicions are troubling and true,  and was prepared to file Oct 11, 2012. When I went to Bill’s Print Shop, on South Broad St, to pick up copies of the four volume appendix, in mid afternoon, I discovered they had done double of the third volume and did not have the second. I brought them the second volume, and they prepared it for the next day, Friday, Oct 12, 2012. When I then went to file in the state Supreme Court.
5) There, I learned, four copies of the large first appendix volume, which appellate had, could not be transferred to Supreme, and on Monday, Oct 15th 2012, received those four copies from the printer which I hope to complete what I provided of the motion papers, Friday, Oct 12, 2012. Not having 9 copies, was my mistake and confusion. I am sure this can be ascribed to not having internalized a new and relatively elaborate procedure.                                     
                I certify the foregoing statements made by me are true. I am aware that if any of the foregoing statements made by me are willfully false, I am subject to punishment.
Date, Oct 15, 2012              Victor Fedorov
                                        Thank You
Victor Fedorov
219 Yardville-Allentown Rd
201 232 1154
(Matter of Estate of Vera Fedorov,
Deceased)
                                                                                 SUPREME COURT OF NEWJERSEY
                                                                                  App Div. # AM-000767-11T1
Vic Fedorov, Pro Se
Plaintiff-Movant
            v.                                                        NOTICE OF MOTION
Mark Fedorov                                       to File Motion for Leave to Appeal
Veronica Savage                                              as within Time
Defendant-Respondent
C/0 Ron Fraoili Esq.
To: Ron Fraoili, 304 Hackensack St Wood-Ridge N.J. 07075
       Mark Fedorov, 1483 Shelburne Ct, Allentown PA 18104
Please take notice, for the reasons explained in the accompanying affidavit, I am motioning for leave to appeal the denial of my interlocutory appeal to change the venue, per Vera Fedorov not being domiciled in Hudson County, and such lie on the probate application, that she spent any nights in Hudson County, as suspicious and consistent with her murder, as within time, and good faith.
I hope you review the brief as exculpatory, and constructive and forward-looking and precedential, with wide-ranging effect, as meritorious.
Date, Oct 15 2012,                         Victor Fedorov
———————————————————————————————————————–
The following is my letter brief to the Supreme Court of N.J. which was accepted and granted a docket number
Vic Fedorov
219 Yardville-Allentown Rd
Hamilton N.J. 08620
                                                                                 SUPREME COURT of New Jersey
                                                                                     Docket # 
                                                                                     App. Div # AM-000767-11T1
Vic Fedorov
Plaintiff-Movant                                                        Notice of Motion
       v.                                                                           (For Leave to Appeal)
Mark Fedorov
Veronica Savage
Defendant-Respondent
To: Ron Fraoili Esq. 304 Hackensack St, Wood-Ridge N.J. 07075
The point to understand is that numerous criminal behaviors have been signified, to compel my production of a Truth, and Whole: that I have faith will remedy matters.
To that empathetic end; the undersigned is the moving party before The Supreme Court. The foil Judge’s Velazquez’s Order of July 19th 2012, denying the changing of Venue, to the County of Domicility of my mother, Vera Fedorov; is too much fodder and opportunity to deny. Appellate Rejection as well, further raises questions upon a constitutional structure of Judiciary hiding criminals, as well as healing statutory confusion upon Fraud before Probate enabling a foreign Venue and certain Judge.
I shall demonstrate the proximity of irreparable harm, at an widespread, networking level; and seek relief; specifically, investigation, hearing into why there was fraud lied to probate, and how and why such cover-up and dereliction continue malfeasant through your courts, and what knowledge is necessary for the wide-ranging reform the people have the right to at all times, article 2a, of the state constitution, inferring through the courts, and wisdom, and ultimately trusted, leadership. I want you to be reassured this can be done in healthy enlightened way. I see judges. as I do my brother, and you, vulnerable, and not wanting to go against the law and critically wanting to stop crime.
                                Thank You
                                      Vic Fedorov        
This is the affadavit
             SUPREME COURT of NEW JERSEY

                                                                              Docket No.
Vic Fedorov                           :
Plaintiff-Movant                   :
     v.                                        :                                        CERTIFICATION
Mark Fedorov                       :
Veronica Savage                  :
Defendant-Respondent      :
I, Victor Fedorov, the understand, commence support of motion with following facts:
1) Defense et al. lied on probate application, and their financial documentation raises my suspicions they are being extorted from, and my mother’s wealth taken from us, as her paralyzing fall was no accident. PA   Notice of Appeal, PA   Interlocutory Appeal Brief.
2) If they can control my siblings, and stifle so many, they can control judges. I see judges just as much the victims, coerced into covering up, easy to see suspicions.
3) This is of grave concern to everyone. I will show how to handle it, and hope I will be trusted, and case remanded for hearings in Mercer County Superior Court, or where deemed appropriate, be worked with to reform the system from ignorance and atheism.
4) It can be construed there is an international child pornography ring, with powerful connections, to have this covered up. PA interlocutory brief, notice of appeal
5) I have  had previous instances of courtly darkness; I argued the reservation of powers for the state or people were violated by local officials, whose ordinance also abridges peaceful assemblies where local decisions be made. It’s in no one’s interest to be against enlightened democratic form. Now realize I must explain the whole to prevail; A whole including natures shown by this case. And even then, this may be too hard to the condition here.
6) I seek to bring relief to you, and alter and reform, per State Constitution Art. 2a, through your interest in your profession, under God. “It is not the function of our government, to keep the citizen from falling into error, It is the function of the citizen to keep government from falling into error.” U.S. Supreme Court, 1950.
7) I have been utterly denied a chance to run my faith in the court, so the fair hearings will be a  relief where I will demonstrate, reassurance, and security through seriousness regarding the Kingdom of God; Something History ignores, but justice requires, that is more protective than the state.
8) I want to sort out this mess in a way that hurts no one and benefits all. I think it is possible this is a faithful opportunity. I hope you are able to be reasonable, and not prey to the same intimations, my siblings and others appear under, or work through them in sight of The Kingdom of God.
9) If you get into and apprehend the following brief, you may see there is a science there to focus on.
10) I cannot claim to have been threatened or specifically intimidated.
11) There is a clear misassumption about the Kingdom of God that can be shown in court, with wide-ranging legal effects upon individuals, challenging America.
12) There seems to be an upper class culture that resolves itself appropriately.
13) Everyone bares this earth and the effects of the world.
I swear the foregoing statements by me are true, I am aware if any of the foregoing statements are willfully false I am subject to punishment.
Oct 11, 2012, Victor Fedorov
then the letter brief itself
Vic Fedorov, Pro Se                                                                       
Plaintiff-Movant
In the matter of Vera Fedorov
(deceased)
     
                                          LETTER BRIEF (for N.J. Supreme Court)
                     In support of motion to change venue to where Vera Fedorov was domiciled
Supreme Court of New Jersey:
May it please the court to offer some utter rectitude upon situation through a long-needed explanation of the Whole; to show how such corruptions incur, to straighten them out. It’s a limited world, I plead to be heard out so.
For it is not about Vera’s demise, or the obvious protocol of referring a probate to the county of domicility, for as you can see, in Appendix, the rights and wrongs of the case easy to see, and, infer dangers of irreparable harm from; and the issue grounded in the constitutional structure of the judicial branch of government; moreover a form that relies on the Kingdom of God, and illumination of cultural corruption, will embody wide-ranging effect, as if precedent.
We seek remanding to Mercer County Superior Court for hearings, or any level or agency, to resolve civilly these issues before us, several opportunities for oral arguments to discuss structure and resolution, where the necessary improvements see pa,      may accessible.
                                    Procedural History
I refer to Procedural histories in Appendix. 1,           2,
A) Then wish to add: My appeal of summary judgment was accepted, pa   .
B)Is Mark pro se? Since the dismissal of interlocutory appeal he has been listed pro se. Up to then, since January, he has been represented by Mr. Fraoili Esq. Wood-Ridge N.J..
C) I consider the response to my interlocutory application, pa     to be vexing and not grounded in law. I do not see how a summary judgment dismissal, negates an interlocutory appeal to change the venue.
                                  Material Facts
Refer to Material Facts Documents in Appendix. PA    PA  
Then I wish to add again
A) Is Mark now pro se?
B) Is their response vexing and not based in law, pa   
C) The cover up  of obviously suspicious facts and goings on makes incumbent an analysis of the judiciary that concerns a situation out of control and manipulated through ignorance.
D) Applying and demonstrating knowledge of the kingdom of god, modern media is pointedly ignorant and obscuring of, requires seriousness, respect and trust, and is the opportunity, for which the people may alter and reform government through courts via analysis foregoing of the judiciary.
E) The idea to make evident the value of knowing the Kingdom of God, over the shame, or cover-up restricting inquiry and honest discussion to  the benefit of the people of N.J., for neither Superior nor Appellate court are giving honest consideration, an abdication, a citizen tries to remedy here, ongoing, and in appellate appeal, ensuing under you; where ignorance, of obvious suspicions, has again prevailed, which I bring up here.
                                   Legal Arguments
Refer you to Legal Issues PA      pa
         Basic Point is The Kingdom of God, Agency of The Kingdom of Heaven
1) This is a real test for you. I don’t know if you will be able to apprehend this. We will see. The Kingdom of God, (a frequent gospel term), is the transformation of the human, into the human being; service to a truth, our government ignores, a great pivotal Truth, rendering senses blind and negated. Thus through the means of The Kingdom of Heaven, History, and Society, is ably imposed; grossly, purposefully Ignorant of itself. That is how immorality, folly and crime, is sustained. Judges, Mark, others that know, law enforcement?, criminals? Are created this way to this effect. Truth, God, Knowledge, Demonstration of spiritual principle, is the only way out.
                        Judges like Silenced Victims
2) A judiciary ignorant of the appendix record, is no different than my brother, suspicious, and vulnerable to the same manipulations and corruptions, threats, threats and injury to family, enforced marriage, possible torture, and enforced depravity or perversion and blackmail. Neither would seem to want to do this or be this way, rather be saved, reason, desired. From an application, knowledge, of the Kingdom of God, the adult world we want may suffice, the irreparable harm we want to no longer worry about, may reason for long. This is Christian Terminology to good effect.
                            Self-Denial inflicted by meta-physic or you?
3) The self-denial Mark goes through, judge’s mark as well, as self-denial occludes thought and reason, yet it is catalyzed by fear from knowing the culture and people in this. Others and you, may be construed logically to know people, and yet do you? The means of corruption, ever attracted here,  is to ensure the corruption of those like Mark, yourselves perhaps, that otherwise object, enforced, possibly. Thus you are victims, impeded.
                    Enabled by Mind or Kingdom of Heaven
4)This world is enabled by the kingdom of god and such immobility,  really it is the mind, or kingdom of heaven that engineers this,  not the kingdom of god, which has no volition.
If aware of the kingdom of god, a morality can set in, that expunges everything, even as the echo lingers, the glory of change heard. The corruption is a function of the enforcement of the design of the judiciary. You must know the kingdom of god to deal with it. Yes you may know terrorizing people, or do so yourself,  who oppress, and you may have consorted with, or been bound to, and bonded; but they must be discounted in light of the Kingdom of God. This instant criminal oppression of the upper class, I am trying to show, is contingent upon your understanding, and leverage of mind. Knowledge is Power. I talk to you. The criminals do not talk or admit to me.
You are the foundation of moral society, with a vested interest in morality, reason, Truth and I am hoping on the vitality of your interest in this Matter and Question. It can set precedent, and expose what we do not want in our society, which is the theoretical rule and binding of powerful people and culture through pedophilia, child porn, prostitution, and consorting parties, extending to scary, dangerous modalities; insofar as Ignorance of the Kingdom of God, does not promote the understanding; there is something audacious and outrageous at several planes here, judicial and family treatment, but such mark can even greater signify the metaphysical outrageousness of the whole; and thus these further dangerous modalities, need to be tempered so, in order to be revealed, so crime stops, and the out-of-control, is marshaled, as you are compelled to. For you to know, and reveal, you must Know, and let my guidance and your trust lead  conciliatory work and hearings by virtue of the work and authority necessary to show the Kingdom of God, and absolve in context of it. This seems to be the point; that we can and will work through this.
Corruptions are designed to enforce the sacrificial nature captured in our judiciary, a covert pagan metaphysic then, and not corruptions per se. They have a purpose, and that point, the point, not the corruptions, which while passed over, require allusion. Are you able to reform, by god and faith and trust in me to handle this delicate situation and sin or culture of immorality, as has been completely denied so far, in forms you transpire.
                                   Constitutions, History
5) Our Constitutions are so much a part of this, as a structural issue. One is that by creating positions of such power, in government, and culturally and economically as well, those officials and powerful individuals, are so removed from the people and powerful, in effect they treat the people as children who are incapable of reasoning together among themselves and implementing ideas and plans; that domain has been given to the few, and when such treatment is ordinary, I believe, there can be a tendency to desire to relate to children sexually, as relating to adults is warded off by the enlargement and enhancement of power.
Our Constitution would ensure local decision making in peaceful assemblies, that local officials are neither state nor people, that the people like to think together; yet these points that would benefit all were ignored for which I realize the whole, God, Truth, the important part to the equation, more liberating, than shameful, ending victimization, respecting the present and people now, as the Kingdom of God is understood, or evident, for there is a traditional level there, denied here.
Secondly, “ Substantive due process or right protected by this amendment must be one that is fundamental, able to be recognized as such by references to reaching of history and basic values that underlie our society and such historical reference is necessary because of the need for objective standard”. Petrey v. Flaugher, D.C. Ky 1981, 505 F.Supp 1087 The amendment is the ninth, how to retain denied rights.
There have been three branches of government since antiquity and classical times, obscured by medieval times, they’ve existed in History books. To think our founders came up with such division, is Propaganda. The historical clouds of The Middle Ages seems to have rendered a critically imperfect reflection of classical times regarding the judiciary. Specifically, I shall cite The Germanic Tribes of Europe, whose judiciary, according to Julius Caesar’s account of the his Gallic Campaigns, were run by Druids, thus coupling, Justice, and The Spiritual, Removed from the sphere of History, War, and society, of the domain of the religious, Truth, Justice.
Thus the issues of Justice were in the Domain of Truth, the way humans are human beings, a reality dealt with, better by the religious and spiritual, countering History, than a removed government bound by History, metaphysically contracted. How bound are we, in light of Truth, to History?
Likewise, in The Roman Republic of those centuries before Jesus Christ, had a justice system of Tribunes, run by the lower class, out of 30 Tribes Romans belonged to. Justice should come from the people and Tribes, as they are closer to Truth, then the upper classes relegated to The Senate, and Executive. The Justice System here, parallels the opposition to Senate and Executive, The Democratic Party may have been designed to take on. The people operated and sought to influence through their Tribunes, and ratifications through Peaceful Assemble, two forms inoperable now.
                                     Inherent right of people to reform
6) 2a of our constitution, the people have the right to reform and alter government at all times. This is only through peaceful assemblies, or the Judiciary, manifest. The Supreme Court in 1950 said job of citizens to keep government from falling into error, not government to keep citizens from falling into error.
                                Pagan society, sacrifice overt
7) The pagan society back then had overt sacrifices. Today they covertly, sybaritically aided by a justice system seeming to enemate, at least in my case, a total obscuring of Truth. For instance, Sandusky’s self-denial is brought on by a fear of implicating his culture. Heaven is controlling and writing a story with moral truths, how perversion of justice, is like perversion, its degradation, the same; whose reform, rectification, is sought here, to reform, and rescue, by the value of Truth and its establishment, being greater, and explanatory. It is control. And the Truth, The Kingdom of God,  obviously Greater, and about ending our vulnerability here and protecting our autonomies. Aware of that great truth, these ensue little truths.
                        Homosexuality, The Kingdom of God
9) Thus, that appellate obscured the compelling facts about this case, and Judge Velazquez so unfair, necessitates this examination of the judiciary, and enemating implications. For Homosexuality may be used in The Kingdom of God, to close the remaining mind in comfort, society, prototypically, would find it painful, and thus anger-inducing, crime-justifying, pitiful-binding; Its dominance, a form kept secret, impedes, occludes, thought, which would rise up against the feared oppressors, contrived as, as behind the scenes, who can admit their evil-doings by first knowing The Kingdom of God, that puts it in honest perspective, alongside trust and faith, and help. Service, and psychology is necessary for reason to prevail. But will we, the justice system care about itself and reform government by law?
                              Common Delusions
10) Marriage, reproduction, school, the media, are far from what they may seem. Overcoming these institutions, being stronger than their lies, is necessary to Truth and Reform. You can see the power to a media network, in the absence of our power, and what public display holds.
                              Inquire into Fraud upon you
11) As per interlocutory appeal, isn’t there a contractual obligation to inquire into fraud via where my mother lived, to get a certain judge, who ripples through appellate so far? Held back by bad bonds, or the untoward effect of higher power? One is much greater than  the  other. Atheism holds back government’s self-analysis, and promotes the worst corrupt ways, the story works through.
That knowledge protects more than people or agency will be developed in appellate. Oral arguments as you see fit and abler probably required to talk this out,  via constitutional discussions, or logical fears of irreparable harm, inquiries into how probate fraud occurs, here, or Superior Court of proper venue, trusting my motions in honorable proceedings- the statutory and rule guidance isn’t specifically unconfusing and direct, yet dictate probate fraud being resolved in proper venue, not venue obtained by fraud. PA  This last in itself, while not constitutional, should have commanded the attention of appellate court, PA, further grounding analysis of the nature of the judicial branch of government. If you know the Kingdom of God, can see the Atheist structure, this is pleasant to deal with. If not, we suffer the compulsive effects of a tightly designed, metaphysical  control grounded in ignorance of the kingdom of god, yet whose awareness of, ends that oppression. As an agent of change and reform, per citizen I hope, we may heal, and see what caused me, tries our faith. The quality of “irreparable harm” is an injunctive criteria.

application to appellate court in N.J. regarding circumstances of my mother’s death. (accepted) basis for brief

November 3, 2012

In order to appeal, county superior court, in N.J., one applies with papers, as seen below, for a docket number, and the opportunity to submit a formal brief that is more developed than the required. I submitted these application papers, and received a docket number, for which my brief is due later in the month.

 

Civil Case Information Statement

6) The complaint was dismissed without prejudice.

Regarding the future disposition of dismissed claims, there is no agreement. However, Mark and I have been meeting once a week. There is a real politic to work through, with faith, and integrity. Both before and after the case, it has been hard to reach people who know the situation, or for Mark and I to both know, what I believe we both know. I would still try to deal with the situation knowing what I know, however Mark is not apprehending the situation in its totality and danger, out of fear and pain

 

Now regarding whether this order is qualified pursuant to 4:42-2, first I must cite omissions that make the order not pursuant to 4:42-1 “An order shall include the following” ….”3) The appearance of counsel and parties appearing pro se”. As you can see from a copy of the order, there is no appearance of counsel to defense, Ron Fraoili Esq, nor, appearance of my pro se party. What can we conclude from this?

Likewise, “6) a notation as to whether the motion was oppossed, or unopposed, as required by R. 1:6-2a” as you can see, the words of the order are “having considered the moving papers, papers filed in opposition, if any, arguments of counsel, if any, and for good cause shown:” In Summary Judgement, disputation of material facts, in a special document, is essential for oppossing summary judgement. I disputed most of the material facts, and per 4:46 5b) can procure medical records recording her state of mind, and material facts of three medications, a respirator, and quadrapylygic at 75, with this duress, if my subpoenas are enforced through the courts, or Defense, as executor can procure these records, easily, enough to render hypocritical a dismissal grounded in their demanding of records, they don’t dispute, as executors, defense is responsible for. Not affirming or denying my submission of Response to Material Facts, and papers therein, nor mentioning my name, or opposing counsel, makes any purviewer of the record ignorant of truth and transpiring therein. To what effect would this be to muddle the paper trail away from people who know,  or suffered it? It’s so as to neither arouse suspicion via my reputation, and keep Mr. Fraoili unaccountable, by seeming to suggest, Mark and Veronica may have been pro se.

To move on to 4:42. Yes, if a proceeding was started to enforce the order, such would go by this order. Everything seems to have been dealt with. This was never about money transferring, but checking to make sure our mother’s wealth is ok.

——————————————————————————————————————–

Procedural History

 

Vera Fedorov, was wealthy from property in Hoboken she bought in 1981, injured quadrapalygic in Princeton, her chief residence Aug 17th, only found Aug 19th 2012, and passed March 22, 2011. She allegedly signed a will Oct 7 2010, at Kessler Institute for Spinal Rehabiliation, which was written in1993, and unsigned till Oct 7 2010, as well as a trust July 20, 2010. I was only shared these things May 22, 2011. I was very surprised the will left her legacy entirely to my younger brother and sister.

The will was probated June 22, 2011, in Hudson County N.J.. The probate application claimed Vera lived at an apartment in Hoboken. This is patently not true, and obtained a Hudson County venue. Brother and sister did not share with me any financial records, and excluded me from the operation of looking after and managing her wealth and property.

I filed a letter of complaint, received Oct 24 2011, primarily to gain the concern of courts, obtain discovery documents that would reassure me, or confirm my suspicions my siblings are extorted. But discovery was limited to less than half the estate, no old federal tax returns were shared to compare to, the monthly revenues and expenses of 50 rental units, never shared, nor any documentation of pre-death divestment. The first hearing was Jan 27th 2012, Judge Olivieri, now retired. My complaint cited the wrong venue in the second sentence. The hearing was about who should execute the estate before issues are resolved at trial, set for Jan 7th 2013. The hearing for reconsideration May 4, 2012, Judge Velazquez. Denied, and order for mediation given.

Here I  had email evidence from Vera in April 2010, how she wanted her mutual funds, to set aside 6 million, whose interest for family and future generations to use for education, business start-up, and family vacations. She always had guidelines to her money, as the emails show further. Inquiry was denied, and an order for mediation given. I was not getting a fair trial, and filed  to change the venue, per 4:80 and fraud, heard July 19th where Judge Velazquez said such motion was too late, “too much water under the bridge”, did not inquire into the false claims, and set a hearing for summary judgement Aug 10, 2012.

At that hearing, defense requested evidence my mother was on three medications, a respirator, and traumatized, which Kessler medical records extensively document. I subpoened those records, the subpoenas were not complied with, I asked the court to put their seal, and signature and directive on the subpoenas, per rule 4:46 5a, and these records can be procured. Likewise, defense, being entrusted with executorship, can easily have had those records sent to the court. The complaint was dismissed.

I filed for an interlocutory appeal to change venue Aug 16th, 20122. This was rejected September 16th 2012.  I now appeal summary judgement.

 

Material Facts

I believe my mothers injury was no accident and she was effectively murdered. Criminals, long behind oppressing my siblings, and others, from decades ago, are responsible, but they merge with a criminal corruption of Hudson County and Hoboken, impeding progress, extending into courts.

I was in organic agriculture, a small businessman, 2005-2009, in Long Valley N.J.. In 2010, I worked for my mother through March, then worked at several farms on eastern states and was near Saratoga NY when I came back upon Vera’s paralysis.

Veronica had moved  to Princeton with her family, where Vera lived, in June. Mark, started managing her  properties in Hoboken, in January, 2010. Her injury was August,  2010.  My siblings got everything in the will, despite emails by Vera, in April, asserting a 6 million fund whose principle was not to be touched, for family and future generations education, vacation and business. The will from 1993 unsigned tll OCt 7 2010, merely left everything for Veronica and Mark’s care. I assisted nurses untill Vera passed, often spending nights with her in rehab.

I was unable to assert what Vera’s Income and fiscal personality was in her last years, specifically from defense’s lack  of providing tax returns, and revenues and expenses from her properties, under their assertion, without documentation, the properties, and other items, she divested, before she passed, even though I requested them in discovery several times. Thus, it is logical to conclude, my siblings are scared and fronting for criminal elements. She was worth 7 million in mutual funds, last I looked, in 2010, and had over 7 million in property. The mutual funds are now  at 2.5 million.

My mother suffered a brutal traumatizing tragic injury. She had been a very robust women. We were very close. I have no family and we supported each other. I know at least 10-20 people, co-workers, family friends, that know what happened and is going on; that there are criminals behind my siblings, taking the money, through pain and fear, upon Vera’s injury caused by drugs and being tossed down the stairs at night. It looked like there was a hammer blow to the top of the head. But I only suspected foul play, after she passed, and the estate revealed handled suspiciously. These people that know, accountants, lawyers, witnesses to the will, do not reach me back, which like the lack of discovery, I construe, as signifying, fear, intimidation, and control. Many people know, I believe, including her grandchildren.

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Legal Arguments

1) Murder, covering up murder, and the syndicate or ring behind it, the danger of irreparable harm, to my family oppressed and corrupted that knows Vera was murdered, to the many people (and law enforcement) I believe know, is my concern to courts. Danger to me as well; I see the situation as, neither reasonable nor adult, strive to do good, because I have faith, and knowledge of what the Christian term, “The Kingdom of God” means, and this a shining opportunity, if you work with me, and work through this, to rectify many planes intersecting into this, including the judiciary. It is not hard to see many suspicious items. If so many people can be controlled regarding, so can justice, and I hope you work with me and law enforcement.

2) Hearings exploring this, will have some wide-ranging, precedential effect, insofar the form involves a ring of pedophilia and sexual abuse and prostition, degredation, torture, arranged marriages, blackmail, whereby those abused as kids, are taken care of by the abusers for decades, used and controlled, to criminal ends. And the form reveals criminals operating behind the government of corrupt Hudson County, and Hoboken, with a history of legendary corruption, a history though that stops short of the criminals, that must be behind the system, using it, through corrupted, controlled,  public officials. A corrupt county is needed to stifle so many people and knowledge of this; signifying many resources and other crimes. A judge obtained through probate application fraud, to cover-up suspicious behavior, will intimidate potential witnesses. At some point, if my brother and sister, and many co-workers, lawyers, accountant, can be controlled,  these overlapping “syndicates” have to exert some controll over you and judges, and police and others in your office.

3) If everyone desires a reasonable, adult world, why isn’t one here? In gallic times, druids administered spirituality and justice, whereas the knights did politics, laws, policy; yet today, our government is ignorant of The Kingdom of God, and justice, from the government. Thus the sacrificial quality of the judiciary is missed; as is how easy it is to claim The Kingdom of God is responsible for crimes; as is how judges themselves are so super-imposed upon The Kingdom of God. Hopefully, this legal argument reassures the defense, and yourselves, this is a sophisticated opportunity to reform our world and help our people, than something to fear. I believe Mark was sexually abused since 1979, and Veronica, corrupted in High School and college, and soon handled and controlled ever since. This places their children, in danger of severe exploitation and abuse. The courts are needed to investigate this, and such, as to whether Mark and Veronica are incapacitated, as they can share discovery  of Vera’s last tax returns, monthly revenues and expenses of 50 apartment units, and emails: They can reassure me the money has not been extorted, yet they cannot show me the money is missing, though the mutual funds were 5 million higher in 2010, without implicating third parties who controll them. Thus they can not manage their affairs, and are incapacitated, which requires inquiry, and court psychologist, and their lawyers violating a host of client protections. Why else would they not blame Mr. Garvin, who per interrogatory, current tax lawyer, who the whole flows through, advised to probate in Hudson County and lie Vera had and used an apartment in Hoboken. Veronica and Mark have a lot to work through, and quite an oppressed past. They can not be blamed for this, having been parcell to their own mother’s demise and not in controll of her wealth. They are in fear and pain. They have a lot to work through, and want to be rescued. They would talk to you.

Hudson County is legendarily corrupt. Read the webblog, Mile Square View, data theft, voter payment, bribes, suspicious resignations. I have stood up to oppressive municipal structures twice. In 1992, I carried signs around Hoboken, conveying what “The Kingdom of God” means, but expressed in my pre-christian way, such as, Everyone is a Body, Man is Dead, whose truth, respected, shines light on right and wrong and forgives. In 2003 I ran for public local office, in Princeton on a platform of making local decisions in Peaceful Assemblies, making the point in Federal Court, and on PACER, in 2004, local officials abridge peaceful assembly, and violate the reservation of powers for the state or the people. 04-366. The courts have failed to admit those last points, which is darkness, for everyone benefits from more reasonable society in metå-physical ways. There is some segueway between this sexual crime operation, corrupt county and local government, and organized criminals. As I have said, Christopher Garvin, is a major player, I am very worried my sister was a prostitute, and in danger, because she knows people, yet was not one of sexually-abused young. Christopher, her son, and Grant, Mark’s son, may have been, or be. And this situation is very capable of hiding behind the legal system, it has powerful connections, it is nation-wide, it is in your interest, to look into the matter, with someone who knows the saving-grace meaning, and can show it, and the absolving, of “The Kingdom of God”. For without working with me, Law Enforcement may not be able to corral it. It takes integrity to exert reason upon an out-of-control situation. One must be free,  in a way, to stand up to pressure, with reason.

This is essentially what I know, some far reaching criminal influence and exploitation of our government, including judiciary, audacious enough to kill my mother and critically corrupt my siblings. I am one to stand up for rights with. My knowledge and working with the courts, will lead to a roundly beneficial situation to N.J. And beyond. This is the nexus of this complaint. Care about this, let’s go further. Fear of this is grounded in shadows ofan ignorance, of how easy it to effect the kingdom of god as people.

2) I subpoened and tried to work with Elinor Taylor, Medical Records Director, Kessler Institute, West Orange, for the elaborate medical records on Vera’s condition. R.4:46b, asserts concerns with evidence itself, not procuring it. The court has not helped with discovery noncompliance, my own ignored subpoenas, or the fact that 10-20 people, I know, or know well, with knowledge of this, do not reach me back. If the matter of her constraint and incapacity needs to be seen now by defense, or inhibit and restrict, the numerous trial issues before this case, the defense can have those records sent to the court very easily, according to Elinor Taylor, as executors; even though they committed fraud on probate application to gain those letters of administration this way.

Court did not inquire into emails specifying 6 million set aside for future generations, not touching the principle, for education, business, or family vacations, April 2010. Why were these concerns not tailored into a will, and a 1994 draft leaving all to Mark and Vern, gone with. Why were the  witnesses to this will, not compelled forth per statute?

Was the fraud Vera domiciled in Hudson County, done to gain a corrupt judge, who then ignores these inquiries and intimidates people with knowledge, Vera was murdered? Why per 3:B 10-13, was the fraud not looked into by Judge Velazquez? Isn’t their testimony tainted now? Why wasn’t per statute 3b: 2-3, superior court in Mercer County, discharged with the duty, as this isn’t a dispute, or controversy, but fairly undisputed fraud, as any superior court can oversee any surrogate court; Where is the recognition Statutes asking for other wills, can only be discharged by venue the deceased was domiciled in. 3B 2-29, other wills.

What about how since 1994, when the will was drafted, I have worked hard, gained trade and experience, and been very useful to her? Surely this ommission is suspiciously consistent with a will fro1994. Casting me as I may have been known in 1994, (it was unsigned till 2010), but certainly as no one knew me in 2010, is suspicious.

People want to be rescued. The roots of this situation goes to a judiciary ignorant enough for criminals to hide behind. Protocol gaps, such as not showing the will and trust while Vera was alive, not reassuring sharing documents, not including me in her business, an old will, witnesses the family doesn’t know, the injury itself, her death the morning after her inlaws arrived. Not blaming Chris Garvin or seeing I am trying to be a good guardian should defense be incapacitated.

Vera was denizen enough to be explicitly known by surrogate court as not residing in Hoboken. Our tragedy, is probably one among many victims to this.

Statutes compell inquiring into fraud, 3b 10-13, they suggest superior courts where domiciled be discharged to handle fraud, not superior court in same venue as surrogate. 3B:-29, ” Superior Court shall have jurisdiction to compel…a will of any decedent, who died a resident of the county, …..to be lodged with the surrogate of the county for probate. Vera died in Mercer County, on the death certificate.

R.P.C. Rules are violated by defense counsel, false testimony, knowing criminal acts. R.1.6 candor to tribunal. R. 4:50 show relief may be granted for fraud.