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

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.





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, … 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.








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