JURISDICTION AND VENUE

24)              This Court has jurisdiction over this matter based on 28 U..S.C. 1332(a) since the amount requested by plaintiff is in excess of $75,000.00.

25)              This Court also has jurisdiction over this matter pursuant to Title 28 U.S.C. 1331, which states that “the district courts shall have original jurisdiction of all civil actions arising under the Constitution, laws, or treaties of the United States.”

EQUITABLE TOLLING

FUGITIVE FROM JUSTICE 

26)              Ballentine’s Law Dictionary describes the word “fugitive of justice” as:  “A person who departs a jurisdiction (or conceals herself within the jurisdiction).”  It is a well-settled federal statute that there is no statute of limitation for individuals who flee from justice.  It is also established within federal laws that a fugitive’s physical absence from the jurisdiction is not required to trigger tolling of statute regarding the commission of a crime.  In the case of the husband, the tolling for federal judicial intervention regarding the husband’s crimes of moral turpitude started on November 21, 1979, the day that the husband used the fictitious name “Godwin Uzamere” to marry the Plaintiff.  Furthermore, tolling of the statute regarding the husband’s crimes of moral turpitude continued when the husband used the fictitious social security number 099-20-2291 to conceal himself with U.S. and New York State jurisdiction.

27)              Furthermore, Plaintiff alleges that the federal, state and municipal Defendants, whose responsibility it was to thoroughly investigate the complaints that she made regarding the crimes that the husband committed against her and the child of the marriage were routinely ignored.  Plaintiff alleges that not only have attorney Defendants not performed those duties necessary to ensure that the identification provided by the husband was correct, but attorney Defendants and governmental Defendants let Plaintiff and the child of the marriage suffer economic deprivation from the husband and social isolation, defamation of character

and other forms of social terrorism by members of the husband’s ethnic group (see various insults from Nigerians Plaintiff’s YouTube and Lycos websites.

28)              Plaintiff has been unable to secure her husband’s immigration records due to the Federal Privacy Act; the effects of the Defendants’ application of said act has been instrumental in facilitating the husband’s felonies, but deleterious for the Plaintiff and the child of the marriage.

29)              Plaintiff alleges that in her case and in the case of the child of the marriage, the husband’s successful creation of a fictitious identity and social security number facilitated his abandoning his legal responsibility to care for his child; and that such abandonment took place over a 21-year-period, so that any imposition of a statute of limitations would be unduly harsh, prejudicial in favor of the Defendants and not in the best interest of justice.

30)              Plaintiff alleges that contained in the husband’s federal records are documents were signed by the Plaintiff, and that said documents have been intentionally withheld by the federal Defendants to hide the felonious relationship that the husband and his immigration attorneys have with various employees of the federal Defendants, and to hide prima facie evidence that the husband’s immigration attorneys  showed the husband how to defraud the Plaintiff in order to circumvent the “spirit of the law” while satisfying the “letter of the law,” and that the husband’s divorce attorney emulated the immigration attorney’s course of conduct by preparing to present to the Court the husband’s fictitious name, and refusing to provide to the Plaintiff evidence of the husband’s real identity up to and including the date of the filing of this Complaint..

31)              Plaintiff further alleges that, based on the lack of response from all the Defendants, that Plaintiff’s faxes regarding her complaints of the husband’s crimes were intentionally misplaced or discarded by

the federal, state and municipal Defendants, so that reliance on the Defendants to produce said records of complaints may be an exercise in futility for the Court.  Plaintiff believes that telling the Defendants about the existence of her well-documented websites, namely, http://africandiasporal.tripod.com/thecriminalandimmoralactsofchiefehigieedoborakagodwinuzamere, http://getjusticeforanamericanschvartze.tripod.com, http://www.youtube.com/cuzamere and http://www.myspace.com/cuzamere, and the Defendants refusal to report or act on the irrefutable evidence of the husband’s crimes as contained in said websites is sufficient proof for this Court to establish the veracity of the Plaintiff’s allegations (please note:  as of the filing of the Amended Complaint, the websites have been removed by Lycos and YouTube).

32)              The action of each of the Defendants by failing to provide an accounting to the Plaintiff as to their failure to report Plaintiff’s complaints regarding the husband, the commission of the husband’s crimes and the newly committed federal violations by Defendants Jaewoong Lee of Lycos, Inc. and Dr. Schmidt of Google, Inc. constitute continuing torts that tolls the statute.

COUNT I -- VIOLATION OF TITLE 18 U.S.C. §4

MISPRISION OF FELONY

33)              Plaintiff alleges that the Defendants failed to act in a manner that guaranteed that Plaintiff’s complaint regarding her husband’s crimes was reported to the appropriate government agency or agencies that existed during that time that the Defendants received said complaints.

34)              Plaintiff alleges that the Defendants’ failure to report the husband’s crimes of moral turpitude to the appropriate governmental agencies has inflicted great mental and emotional distress on Plaintiff.

35)              Plaintiff alleges that the Defendants continued their acts of misprision of the husband’s felonies by refusing to report the husband’s  violation  of  the  New  York  State  Penal Code, Section 175.35, offering a false instrument for filing in the first degree; said felony a form of fraud that is viewed by Title 8 of the United States Code as a crime of moral turpitude.

36)              Plaintiff alleges that the Defendant continued their acts of misprision of the husband’s felonies by failing to report the husband’s violation of the New York State Penal Code, Section 260.05, non-support of a child in the second degree; said crime that, although a misdemeanor, is viewed by Title 8 of the United States Code as a crime of moral turpitude.

37)              Plaintiff reiterates and re-alleges the same allegation of Defendants’ misprision of the husband’s felonies regarding every crime so enumerated with the same force.

38)              Plaintiff alleges that up to and including the present, Defendants continue to conspire to pretend not to view the names “Godwin Uzamere” and “Ehigie Edobor Uzamere as both belonging to the husband.

39)              Plaintiff alleges that up to and including the present, the Defendants continue to conceal the husband’s simultaneous marriages from other federal agencies, from the public, and have failed to work with the foreign government where the husband is employed as a senator so as to bring the husband to justice.

40)              Plaintiff further alleges that the Defendants have formed an illegal alliance with the husband’s immigration attorneys Allen Kaye, Harvey Shapiro and Jack Gladstein by hiding the illegal disparity that was created by the husband’s use of the names “Godwin Uzamere” and “Ehigie Edobor Uzamere; said disparity further exacerbated by the assistance of the husband’s attorneys Allen Kaye and Harvey Shapiro; that the aforesaid attorneys continue to allow the disparity to exist by not reporting it in a manner that would precipitate an criminal investigation of the husband; and that the aforesaid attorneys continue to allow the disparity in the husband names to exist by withholding documentation from the Plaintiff so as to prevent the Plaintiff from verifying the husband’s identity.

COUNT II – VIOLATION OF TITLE 18 U.S.C. §1961 -- §1968

RACKETEERING INFLUENCED AND CORRUPT ORGANIZATION ACT

41)              Plaintiff alleges that based on several occasions in which various African American women alleged to have been victims of green-card-marriage scams perpetrated by Nigerian men, that the federal Defendants, with the help Allen E. Kaye, Harvey Shapiro and Jack Gladstein have established an illegal enterprise in which the aforesaid Defendants attorneys show Nigerian immigrants how to trick African American women into marriage, trick them into signing the sponsorship applications, and then direct them to divorce attorneys who circumvent the spirit of the Federal Patriot Act, which requires financial institution to demand governmental identification.  Defendant attorneys, with the help of those federal Defendants concerned with immigration and naturalization matters then “fast-track” the applications so as to ensure that Nigerian immigrants’ applications/requests for permanent residence are quickly granted without the applications being questioned or scrutinized.

42)              Plaintiff further alleges that Defendants’ participation in the enterprise of falsifying the applications of Nigerians seeking permanent legal residence is in violation of federal laws identified as “RICO” laws and further violates Title 18 U.S.C. §4, regarding the misprision of felony.

COUNT III – VIOLATION OF THE CIVIL RIGHTS ACT

43)              Plaintiff alleges that the Defendants frequently work in concert with attorneys of a specific ethnocentric group that have more political power than do the African American women who have been victimized by the clients of the aforesaid attorneys; that the fraudulent marriages that are the product of a conspiracy by the immigration lawyers of said ethnic group and their Nigerian clients intentionally target African American women because  of  the  low  social  status that has been forcibly placed on African American women by members of the Defendant attorneys’ ethnic group.

44)              Plaintiff further alleges that a disproportionate percentage of the attorneys with whom the Defendants engage in the enterprise of illegal immigration belong to an ethnic group that teaches that blacks are meant to be enslaved; and that said doctrine, while not the cause, is used by attorneys of said ethnic group to rationalize the abuse of African American women in much the same manner as it was used to rationalize the enslavement of African slaves, that is, for financial enrichment.

COUNT IV – VIOLATION OF H.R. 3162, SEC. 326

THE PATRIOT ACT -- VERIFICATION OF IDENTIFICATION

45)              Plaintiff states that although the aforesaid statute specifically applies to banks, the Court should not misconstrue the law to imply that federal agencies and attorneys, who are officers of the Court, can circumvent the “spirit of the Patriot Act” by allowing immigrant clients to present falsified names or other false information to them that may eventually be submitted to the Court as true.

46)              Plaintiff states that proof of the aforementioned statement is reflected in New York State Penal Code, Section 175.35, offering a false instrument for filing in the first degree; said felony a form of fraud that is viewed by Title 8 of the United States Code as a crime of moral turpitude; and as such, is consistent with the “spirit” of the Patriot Act.

47)              Plaintiff further states that in the best interest of justice, the Court must not misconstrue Plaintiff’s unfamiliarity with the finer point of federal law in a way that would allow the Defendants’ the opportunity to misapply the law, or for the Defendants to rely on the Court to misapply the law in such a manner that the “letter of the law” is obeyed, but the “spirit of the law” is not.  Plaintiff states that the Court must obey the entire law whether Plaintiff knows it or not.

COUNT V – VIOLATION OF THE FEDERAL REHABILITATION ACT OF 1973

VIOLATION OF THE AMERICANS WITH DISABILITIES ACT

48)              The Federal Rehabilitation Act of 1979 holds that it is illegal for any agency that received federal funding to discriminate against an individual based solely on the individual’s status as being mentally ill.  Furthermore, the Americans with Disabilities Act prohibits governmental agencies from withholding services from individuals who are disabled and governmental agencies are in fact, required to provide accommodations for said individuals.

49)              At points throughout the 28 years in which she petitioned the Defendants for assistance in reporting and prosecuting the husband, Plaintiff alleges that the Defendants intentionally ignored her because of Plaintiff’s status as being mentally ill; and that said status was the rationalization Defendants used to regard Plaintiff’s complaints as not credible, in spite of Plaintiff’s providing Defendants with irrefutable proof of her allegations against the husband.

COUNT VI – VIOLATION OF FIRST AMENDMENT

FREEDOM OF SPEECH

50)              Plaintiff alleges that her right to use Defendant’s Jaewoong Lee and Lycos’ site to disseminate documents that irrefutably established Plaintiff’s allegations of crimes perpetrated by the husband was intentionally violated.  Further to this, Plaintiff alleges that irrefutable proof of her statements regarding Judaic religious dogma that advocates anti-black racism was removed as an excuse to extort the Plaintiff’s silence, thereby allowing the aforesaid Defendants to intentionally violate Plaintiff’s right to freedom of speech.

COUNT VII – CONSPIRACY TO VIOLATE CONSTITUTIONAL RIGHTS

DEPRIVATION OF FREEDOM OF SPEECH 

51)              As of the date of the filing of the Amended Complaint, website http://africandiasporal.tripod.com/thecriminalandimmoralactsofchiefehigieedoborakagodwinuzamere was removed by Defendant Lycos, Inc. for as yet unspecified “terms of service” violations that did were not mentioned until approximately three day after Plaintiff filed the federal complaint.

52)              Plaintiff alleges that the data that was contained in Plaintiff’s websites will be destroyed, constituting destruction of Plaintiff’s intellectual property, or, not returned to Plaintiff in a timely manner in an attempt to extort Plaintiff’s silence.

53)              Plaintiff alleges that Plaintiff’s evidence, the aforesaid website’s removal within three (3) days of the filing of the original federal complaint, along with Defendant’s inability to provide Plaintiff with a legal, or at very least, a plausible reason for Defendant’s claim that Plaintiff violated a condition or conditions within the Defendant’s terms of service is not a coincidence, but an act of conspiracy where Defendant Lycos, Inc. was impelled to remove Plaintiff’s websites.

54)              Plaintiff alleges that Defendant Lycos’ intention to remove the website http://africandiasporal.tripod.com was meant to extort Plaintiff’s silence, insofar as the aforementioned website makes references to various Jewish religious books that teach that dark-skinned/black people are cursed by God.  Further to this, Plaintiff alleges that Defendants’ belief that the discovery of this information on Plaintiff’s website will infuriate Jewish judges within the federal court system is shared by the Plaintiff as well.  Plaintiff alleges and agrees with Defendant’s assessment that obtaining an impartial decision after a Jewish judge discovered the existence of the aforesaid website would be virtually impossible.  Plaintiff is terrified and alleges that, like the Defendant(s), she believes that exposing the aforesaid website will prevent this Court from using the website regarding the husband’s crimes as evidence and would also ensure that Jewish judges within this Court would not try Plaintiff’s action in a just manner.

COUNT VIII – OBSTRUCTION OF JUSTICE

55)              Plaintiff alleges that Defendants have consistently withheld proof of Senator Ehigie Uzamere’s identity and/or whereabouts from the Plaintiff.  Furthermore, Plaintiff also alleges that on various attempts that

she uploaded information regarding Defendant Ehigie Uzamere’s various crimes onto the internet, along with irrefutable proof of same, Defendants Google/YouTube, Inc. and Lycos, Inc. have blacklisted Plaintiff from using their websites.  Plaintiff further states that the State of New York, by its agency the New York State Grievance Committee for the 2^nd and 11^th District have refused to entertain Plaintiff complaint regarding Defendant Jack Gladstein’s obvious attempt to trick Plaintiff into divorcing his client using the fictitious name said client used to marry the Plaintiff.  Further to this, Defendant City of New York, from the time that Plaintiff applied for public assistance and supplied Defendant the New York City Human Resources Administration with adequate information for the aforesaid Defendant to contact federal immigration authorities, neither Defendant City of New York nor Defendant New York City Human Resources Administration have never contacted federal immigration authorities to locate Defendant Ehigie Uzamere.

COUNT IX – EXTORTION

56)              Plaintiff alleges that Defendant Ehigie E. Uzamere from the day that Plaintiff reported Defendant Ehigie Uzamere’s crimes to various law enforcement agencies, Defendant Ehigie E. Uzamere withheld his whereabouts, proof of his identity and money from the Plaintiff, and caused members of his family and community to do the same to the Plaintiff and to Plaintiff’s daughter.  When Defendant Ehigie Uzamere believed that Plaintiff was desperate to divorce him, Defendant Ehigie Uzamere contacted Defendant Jack Gladstein to trick Plaintiff into divorcing him using Defendant’s fictitious name. When Plaintiff should herself not to be compliant, both Defendant Ehigie Uzamere and Defendant Jack Gladstein ended all discussion with the Plaintiff.

COUNT X – ENFORCEMENT OF TITLE 28 U.S.C. §1361

ACTION TO COMPEL FEDERAL OFFICIALS TO PERFORM MANDATORY DUTY

57)              Because Plaintiff is somewhat familiar with the legal theory regarding governmental immunity from lawsuits, Plaintiff realizes that her demand for financial compensation will more than likely be rejected. 

However, Plaintiff’s primary objective in filing her complaint is based on Title 28 U.S.C. 1361.  For this reason, Plaintiff respectfully prays that this Court enforce the duty on all governmental agencies, governmental employees and legal officers of the court to comply with the spirit of the Patriot Act and the responsibility placed primarily on Defendant U.S. Department of Homeland Security to compel Defendant Ehigie Edobor E. Uzamere also known as “Godwin” Uzamere to produce identification so that the Plaintiff and the rest of the U.S. government can verify who he is and consolidate the fictitious alias “Godwin Uzamere” with the name real “Ehigie Edobor Uzamere.”  The district federal courts legally have original jurisdiction of any action in the nature of mandamus to compel an officer or employee of the United States or any agency thereof to perform a duty owed to the Plaintiff.  Plaintiff and the child of the marriage are owed the right to know Defendant husband’s identity.  For 28 years, Plaintiff has never been able to verify the Defendant husband’s identity, and in spite of numerous attempts to enlist the assistance of municipal, state and federal agencies, Plaintiff has never been successful.  Plaintiff begs this Court that in the likely event that Plaintiff’s action is dismissed based on the doctrine of immunity, that this action is treated by this Court as a writ of mandamus to compel the governmental employees to verify the identity of Defendant husband.  Plaintiff apologizes to this Court for providing it with an inartfully drawn complaint.

DEMAND FOR AN ACCOUNTING

58)              Plaintiff, on her own behalf, re-alleges as if fully set forth, each and every allegation contained in the preceding paragraphs.

59)              Plaintiff respectfully asks that the Court consider that Plaintiff is not an attorney; further to this, Plaintiff suffers depression and bipolar disorder for which Plaintiff respectfully requests that this Court provide Plaintiff with an attorney.

60)              Plaintiff respectfully requests that this Court consider the effects that a lifetime of Defendants’ abuse has had on Plaintiff’s ability to accurately recount all the detail in the Complaint, and that the Court instead rely on documentation that the Court, in its discretion will allow the Plaintiff to subpoena.

61)              Plaintiff demands judgment (a) to require Defendants to make a full disclosure of the identity and documentation of the husband to the Plaintiff; (b) to set aside the Federal Privacy Act insofar as Plaintiff’s demand for said documentation is based on crimes already committed and presently in commission by the husband; (c) to consolidate all of Plaintiff’s husband’s documents help under the fictitious named “Godwin Uzamere” with all federal files and relevant documentation held under the husband’s named “Ehigie Edobor Uzamere”; (d) to perform a countrywide criminal investigation of the husband to ensure that he does not have fictitious identities within U.S. boundaries;  (e) to require the husband to return to the United States to face trial; (f) to denaturalize the husband based on prima facie evidence presented by Plaintiff of the husband’s crimes; (g) to provide Plaintiff with the name of Nigerian officials and/or agencies to allow Plaintiff to file a complaint in Nigeria; (h) to compel the Defendants to provide the Nigerian government with a copy of Plaintiff’s complaint; (i) to compel the Defendants to immediately provide the Nigerian government with already-proven facts, including proof that Plaintiff’s husband and Senator Ehigie Edobor Uzamere are one and the same person; (j) to launch an investigation on all Defendant attorneys to determine the following:  (1) the accounting of number of Nigerian men who received green-card-marriage-sponsorship services and divorce services; (2) the number of Nigerian men who received green-card-marriage-sponsorship and divorce services from the same defendants; (3) the name of the judge(s) who oversaw the proceedings; (4) the nationalities of the women who married and then divorced their Nigerian husbands; (4) whether the divorces were contested or uncontested; (5) if the marriage resulted in children; (6) if there were children of the marriage, whether the children received child support from the Nigerian father; (k) and to financially compensate Plaintiff with 100,000,000.00 for 28 years of mental and emotional distress.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff demands a jury trial and judgment and damages against the Defendants, jointly, severally and/or in the alternative, as follows:

a)         Access to all federal records of the husband;

b)         $100,000,000.00 in punitive damages as a result of Defendants intentional infliction of emotional/mental distress upon the person of the Plaintiff.

c)         For a full-fledged criminal investigation against the husband;

d)        To be apprised of all stages of the criminal investigation as a victim of the husband’s crimes and to be viewed by the Defendant’s as a crime victim.

e)         Other issues to be determined during the preliminary conference;

f)          For the cost of this action.

Dated:    March 14, 2008

               Brooklyn, New York