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EDWARD MANFREDONIA SUES FOR HIS FBI FILES- AMENDED COMPLAINT

August 25, 2016
FBI Lawsuit Amended
3 messages
ed manfredonia <edmanfredonia8311@gmail.com> Sun, Oct 24, 2010 at 7:56 AM
To: edmanfredonia8311@gmail.com, edmanfredonia8337@gmail.com
UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF NEW YORK

____________________________________________________X

 

Edward Manfredonia,

 

Plaintiff,

AMENDED COMPLAINT

                  

                                                                   08-CV-1678 (SLT)(LB)

 

                                                                   JURY TRIAL DEMANDED

 

-against-

 

 

Securities and Exchange Commission of the United States,

Department of Justice of the United States,

Federal Bureau of Investigation

 

________________________________________________________________x

 

                                   

                                                VERIFIED COMPLAINT

 

_________________________________________________________________X

 

Edward Manfredonia, the plaintiff herein, being duly sworn, deposes and says:

 

Parties in this complaint are listed below:

 

A.  Plaintiff:

Edward Manfredonia

c/o McCormick

8337 St. James Avenue

Apt. 4B,

Elmhurst, NY 11373.

Telephone Number:  718-457-8135

 

 

B  Defendants:

 

1.      Department of Justice

One Saint Andrew Plaza

New York, NY 10007

212 637 2200

3.  Federal Bureau of Investigation

26 Federal Plaza

New York, NY 10278

212 384 1000

4.  Securities and Exchange Commission

3 World Financial Center

4th Floor

New York, NY 10281

212 336 1100

 

II   Basis for Jurisdiction:

 

The basis for Federal Jurisdiction related to Freedom of Information Act is that Plaintiff Edward Manfredonia was wired by the Federal Bureau of Investigation in 1993 and had assisted the Department of Justice in an investigation into money laundering, stock fraud, narcotics smuggling, etc. at the American Stock Exchange.  Plaintiff Edward Manfredonia has written numerous letters, which have detailed criminal activity and violations of federal law, to the Federal Bureau of Investigation; Internal Revenue Service; Department of Justice (United States Attorney for the Southern District of New York, Attorney General of the United States); Securities and Exchange Commission; and other federal agencies.

 

Plaintiff has provided extensive information to the Federal Bureau of Investigation, the Securities and Exchange Commission, and the Department of Justice concerning crime on Wall Street- especially information concerning violations of federal securities law and federal law at the American Stock Exchange.

 

Furthermore, Plaintiff has been informed that at times Plaintiff has been under surveillance by the Federal Bureau of Investigation.  Plaintiff has also been informed that Plaintiff’s phone has been wire tapped.  It must here be noted that in 1993 Plaintiff agreed for his telephone to be tapped- but that was for a limited period of time.  But Plaintiff has been informed that his telephone has been tapped at a much more recent period.  Plaintiff shall gladly testify to this matter in an open hearing.

 

Plaintiff has provided 3 documents, which prove that Plaintiff is not lying about narcotics smuggling, money laundering and rape at the American Stock Exchange.

 

The first document is Plaintiff’s FBI wire order, which document proves that Plaintiff had been wired by the FBI.  Please note that the FBI wire order was signed by AUSA Frances Fragos (Exhibit 1).

 

The second document is an affidavit, which Plaintiff sent to President Bush.  This affidavit explicates Plaintiff’s meeting with Assistant United States Attorney Frances Fragos and FBI Special Agent Joseph Yastremski on 13 September 1993 in the Offices of the United States Attorney for the Southern District of the State of New York.  In November 2007 Frances Fragos (Townsend) resigned as President Bush’s Advisor on Homeland Security and Counter-Terrorism.  (Exhibit 2)

 

The third document is a sworn statement by Patrick Azzara, a former member of the American Stock Exchange, who met with FBI Special Agent Joseph Yastremski.  This sworn statement concerns money laundering, narcotics smuggling, stock frauds etc. at the American Stock Exchange. (Exhibit 3)

 

The fourth document is a copy of the 26 April 1999 BusinessWeek cover story, Scandal On Wall Street.  More than one page is devoted to Plaintiff and Plaintiff is termed a whistle-blower.  (Exhibit 4)

 

The fifth document consists of copies of several articles, which were authored by Plaintiff for The Black Star News.  These article, Goldman’s Obscene Bonuses, Rip-Off:  Wall Street Price Fixing, AIG and Stock Manipulation; Goldman’s Toxic CMOs, and Goldman’s CMO Liabilities prove that Plaintiff possesses intimate knowledge of illegal trading on Wall Street and is an honest man.  (Exhibit 5)

 

The sixth document is an affidavit by anonymous.  This document appears on Plaintiff’s website, www.wallstreetscandals.com.  The affiant listened to several of Plaintiff’s telephone conversations with FBI Special Agent Yastremski discuss money laundering at the American Stock Exchange.  An original copy of this affidavit was provided to Representative John Dingell.  (Exhibit 6)

 

The aforementioned documents, Exhibits 1-6, prove that Plaintiff does not lie and should provide overwhelming confidence that Plaintiff’s statements are not incredible or delusion, but are verifiable incidents and that the Federal Bureau of Investigation, Department of Justice and Securities and Exchange Commission have extensive files (i.e., notes, memoranda, records, letters, documents, etc.) which mention Plaintiff’s name.  it is these documents that Plaintiff demands.

 

Plaintiff demands that all information pertaining to Plaintiff’s consent to have his telephone tapped be provided- that means all documents, files, notes, memoranda, surveillance, etc. of Plaintiff and which documents mention Plaintiff’s name in the period from April 1993 to January 1994 be provided to Plaintiff.  Note:  Plaintiff met with FBI Agent Joseph Yastremski circa April 1993 and circa July 1993 in the FBI office at 26 Federal Plaza in New York City.  This covers the 90 day time period, September 1993 to January 1994, for which Plaintiff consented to be wired- see Plaintiff’s “FBI wire order,” (Exhibit 1) which either Judge Towns or her law clerk has stated is illegible.  (New copy of wire order has been provided.)  Hopefully Judge Townes and her law clerk are able to read the new FBI wire order- or we can subpoena a new copy of the wire order.  Note:  Judge Townes it is a crime to forge a federal document and it is a crime to commit perjury.

 

Indeed Plaintiff is totally mystified that the learned Jude Townes and her astute law clerk were unable to recognize or even read what Plaintiff has referred to as Plaintiff’s wire order.  Just read the wire order and the numbered boxes and the Xs and words in the boxes.  Plaintiff showed this wire order to some high school students at Newtown High School, and these students understood the meaning of the wire order.

1.Reason for proposed use:  box checked- Corroborate Testimony.

2.  Type of equipment:  box checked- Concealed Recorder

3.  Consenting Party:  box checked- Nonconfidential Party:  Edward Manfredonia- that is Plaintiff’s name

8.  The following requirements have been fulfilled.  All three boxes were checked.

9.  Government attorney in judicial district where intercept will take place foresees no entrapment….

Identity of Gov’t Attorney:  AUSA Frances Fragos

Southern District of New (sorry the copy is truncated)

12.  Synopsis of case:  Case involves the manipulation of the price of PNF stock on     the American Stock Exchange

 

FBI Special Agent Joseph Yastremski wired Plaintiff Manfredonia for an investigation into PNF.

 

The above explication is proof that Plaintiff is not lying.  And Plaintiff has assisted in the explanation of the document.  So, I hope that I have assisted Judge Townes in her understanding of the document.

 

In 1993 Plaintiff was wired by the FBI- specifically, FBI Special Agent Joseph Yastremski.  Yastresmski placed the recording device upon Plaintiff- attached the document to Plaintiff’s back and the microphone was attached to Plaintiff’s undershirt.  Plaintiff then entered Pappoo’s, a bar/restaurant, which at that time was located on Greenwich Street and recorded a conversation.  The wire order (Exhibit 1) was signed by AUSA Frances Fragos (box 9), who until November 2007 was President Bush’s advisor on Homeland Security and Counter-Terrorism.  This document, the FBI wire order, (Exhibit 1) was provided to Plaintiff in 1994 pursuant to a request made to the FOIPA Section of the FBI.  The request merely stated that Plaintiff wished to obtain his files and Viola! Plaintiff was eventually sent a copy of the FBI wire order, an official government document.  So, Plaintiff did request his “FBI files” in the required manner.

 

If Judge Townes or her law clerk should believe that Plaintiff has committed perjury or has presented a false or manufactured document copy of a federal document, then Judge Townes is mandated under federal law to have Plaintiff Manfredonia arrested and charged with perjury and falsifying a federal document.  Please give Plaintiff 3 days notice of his arrest so that Plaintiff can make the necessary arrangements.

 

One day Plaintiff was walking with an FBI Agent and the FBI Agent stated that he did not wish to be seen walking down the street with Plaintiff because Plaintiff had been under surveillance.  Sorry Judge, but I do not lie and, therefore, there is evidence that Plaintiff had been under surveillance by the Federal Bureau of Investigation.  So let us subpoena all records, of Plaintiff’s surveillance, all notes, memoranda, letters, etc. in which Plaintiff’s name is mentioned.

 

Furthermore, it is Plaintiff’s belief that Plaintiff has been placed under surveillance by the Federal Bureau of Investigation.  Arthur Amey, who retired as a Special Agent of the Federal Bureau of Investigation and has continued to work for the FBI as a consultant, lives in the same co-op building and on the same floor, the fourth floor, of 83-37 St. James Avenue, Elmhurst, NY 11373, as Plaintiff.  If FBI Special Agent Amey has written any reports in which Plaintiff’s name is mentioned while either employed as an FBI Special Agent or as a consultant to the FBI or Department of Justice after his retirement, Plaintiff demands those records, which Plaintiff has referred to as Plaintiff’s FBI files, i.e., any notes, memoranda, documents, surveillance records, etc. which are maintained by the FBI or its parent, the Department of Justice.

 

Plaintiff seeks all FBI records, files, transcripts, records of surveillance, etc. in which Plaintiff’s name is mentioned.

 

It is here that Plaintiff must state most assertively that Plaintiff has been informed that Arthur Levitt ordered the Securities and Exchange Commission not to utilize any information that Plaintiff provided to the SEC and to pass along this information to the American Stock Exchange.  Plaintiff must state that this information was provided to Plaintiff on 13 September 1993 in the offices of the United States Attorney for the Southern District of the State of New York by Assistant Untied States Attorney Frances Fragos, later Frances Fragos Townsend, President Bush’s advisor on Homeland Security and Counter Terrorism.  If the Court believes that Plaintiff is committing perjury, Plaintiff demands that Judge Townes have Plaintiff arrested.

 

Circa 1996 Plaintiff had a telephone conversation with an SEC staff attorney at the New York Office of the SEC, Ira Spinnler (spelling approximate). Spinnler told Plaintiff that Arthur Levitt, then Chairman of the SEC, had ordered that Plaintiff’s correspondence with the SEC be sent to Helen Moore in Washington, DC.  Plaintiff is not lying, or rather committing perjury; Spinnler had another individual listen to the conversation.  So, there are records of conversations and Arthur Levitt’s order that all Plaintiff’s letters be sent to the SEC in Washington where everything could be covered up. Thus, Plaintiff demands these SEC records, i.e. files, documents, notes, memoranda, etc. in which Plaintiff’s name is mentioned and to which Plaintiff is entitled.

 

Plaintiff demands all SEC records pertaining to Plaintiff- including all records, files. Letters, etc. where Plaintiff’s name is mentioned.

 

Plaintiff also demands all Plaintiff’s files and all records, i.e., documents, notes, memoranda, letters, etc., in which Plaintiff’s name is mentioned at the Department of Justice.  Plaintiff had extensive contact with Assistant United States Attorney Frances Fragos, whose name appears as AUSA Frances Fragos on the FBI wire order.  Plaintiff has provided a new copy of the FBI wire order, which is legible and easy to read (Exhibit 1).  This wire order was provided to Plaintiff by the FBI in 1994.  The only information, which was redacted on this government document, pertained to personal information concerning Plaintiff Manfredonia- so the FBI wire order was not altered, which would be a violation of federal law.  Plaintiff is mystified that the learned Judge Townes could not read the FBI wire order.  Whenever Plaintiff has shown the FBI wire order to an attorney in federal court, the attorney immediately knows that Plaintiff has been wired by the FBI.  So, Plaintiff is stupefied by the Judge’s inability to recognize this FBI wire order.  Plaintiff demands a new copy of the FBI wire order from the FBI in part so that Judge Townes may more easily read what Plaintiff has termed as his “FBI wire order.”

 

Plaintiff also had contact with an Investigator for the Department of Justice named Steven Beck.  It was Steven Beck, who placed a NAGRA (hopefully spelled correctly) upon Angelo Meneghello in the Department of Justice investigation into the Oakford case.

 

Plaintiff spoke to Steven Beck because Beck was investigating the money laundering by Louis Miceli and Robert VanCaneghan from the Cayman Islands for the Department of Justice.  Beck also informed Plaintiff that Beck and Joseph Yastremski had meetings in which Plaintiff was discussed. Plaintiff demands all records of these meetings. Plaintiff attempted to have FBI Special Agent and Steven Beck investigate the illegal trading of Pat Schettino, Joseph Roffler, etc. at the American Stock Exchange.  Plaintiff demands all records, i.e., all notes, memoranda, records of surveillance, documents, letters, etc. at the Department of Justice in which Plaintiff’s name appears.

 

Plaintiff also had contact with another Special FBI Agent, Michael Degnan.  FBI Special Agent Michael Degnan was investigating the American Stock Exchange stock fraud, PNF, with FBI Special Agent Joseph Yastremski.

 

Plaintiff Manfredonia gained access to the FBI because Plaintiff Manfredonia knew FBI Special Agent Andre Cicero, when Cicero represented the clearing firm, Janney Montgomery, on the floor of the American Stock Exchange and Plaintiff was a member of the American Stock Exchange.

 

FBI Special Agent Joseph Yastremski informed Plaintiff that he (Yastremski) had attended Columbia University and had been employed by Salomon Brothers in he 1980sin the mortgage backed securities department.

 

On several occasions Plaintiff received telephone calls from FBI Special Agent Joseph Yastremski at Plaintiff’s home telephone:  718 457 8135. There are records, notes, memoranda, etc. of Yastremski’s telephone calls to Plaintiff.  Yastremski’s telephone calls to Plaintiff dealt with narcotics smuggling by Louis Miceli; money laundering by Louis Miceli and Robert VanCaneghan; Al Avasso’s Mafia payments to Steven Lister, Senior Vice President of Compliance at the American Stock Exchange; etc.  Plaintiff demands all FBI files, i.e., records, notes, memoranda, documents, letters, etc. in which Plaintiff’s name is mentioned.

 

Judge Townes Plaintiff would like to state that the FBI does not publish the names of FBI Agents, so Plaintiff had to personally know the FBI Agents, Investigators for the Department of Justice, and Securities and Exchange staff attorneys.

 

It is here that Plaintiff wishes to state one important fact.  Plaintiff had made it known to members of the Board of the American Stock Exchange that Plaintiff was not interested in money.  Plaintiff desired that Robert VanCaneghan and Louis Miceli be removed from the Board; that Robert VanCaneghan receive psychiatric treatment; that the victims of VanCaneghan’s depredations be compensated.

 

Judge Townes you are mandated by federal law to have Plaintiff charged with perjury if you believe that Plaintiff has committed perjury.  You must have Plaintiff arrested if you believe that Plaintiff has perjured himself.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

III   STATEMENT OF CLAIM

 

In this section of Plaintiff’s complaint, Plaintiff shall take issue with several major fallacious analyses of Plaintiff’s original complaint by the learned Judge Townes and her learned law clerk.  Plaintiff has affixed Plaintiff’s original complaint as Exhibit 7.

 

But first it is readily apparent that Judge Townes or her law clerk has willfully delayed providing Plaintiff with a copy of Judge Townes’ Memorandum and Order.  Although Judge Townes’ Memorandum and Order was dated June 24, 2008, Judge Townes did not provide a copy of her Memorandum and Order to the Court Clerk’s Office until June 30, 2008.

 

At this juncture of the complaint, Plaintiff wishes to take issue with Judge Townes, characterization of “real or imagined” encounters, which Judge Townes lists on page 2 of her Memorandum and Order.  It is transparently obvious that Judge Townes, a federal judge who has tried both criminal and civil cases, affects a belief that Wall Street is an environment inhabited by men of the Mary Poppins variety- whose main duty is to perform philanthropic acts and not to make money- ruthlessly.

 

Plaintiff also wishes to express outrage with Judge Townes’ mistaken belief that Wall Street is like the Tooth Fairy, which version is stated on Page 6 of Judge Townes’ Memorandum and Order.

 

Thus, Judge Townes states on page 6:

“In the instant complaint, plaintiff’s allegations regarding wrongdoing on Wall Street in the 1990’s, is frivolous because the allegations are incredible.”

“To the extent that plaintiff seeks to have this Court instigate an investigation into alleged criminal activity that occurred on Wall Street during the 1990’s, his complaint is dismissed as frivolous as the facts he alleges are wholly incredible.”

 

Sorry Judge Townes and her law clerk, but Plaintiff has stated the truth.  Let the legal action proceed and Plaintiff shall prove that you are wrong.  If Judge Townes believes that Plaintiff has committed perjury, Judge Townes has no recourse but to have Plaintiff arrested for perjury.

 

Judge Denny Chin of the Southern District of the State of New York knows that the government plays fast and loose with indictments and favors the rich and powerful.  Thus, Judge Chin dismissed the charges against Brian Finnerty in the NYSE specialists’ case because the government did not indict Finnerty’s superiors, who had earned even more money than Finnerty from this illegal trading.

 

And please Judge Townes, you have insulted Plaintiff. Plaintiff knows that a federal judge cannot instigate or initiate an investigation- and nowhere in Plaintiff’s complaint did Plaintiff request such an investigation.

 

Plaintiff strongly suggests that Judge Townes read John Crudele’s columns, the latest being written on 11 July 2008, concerning the cover by Eliot Spitzer and the Department of Justice concerning the involvement of Richard Grasso in the illegal trading of Oakford Corp.- and Plaintiff’s proof that Grasso covered up the illegal trading of William Johnston, President of the NYSE- and a personal friend of Grasso.

 

Plaintiff shall briefly refute the willful misstatements of Judge Townes, which appear on page 2 of the Memorandum and Order.  Plaintiff shall then prove that Judge Townes has no idea of the reality of Wall Street.  Or perhaps Judge Townes truly understands Wall Street, but does not wish the confluence of the federal government and its acceptance of criminal activity on Wall Street to be exposed.

 

Judge Townes’ first example involves solicitation of Plaintiff’s murder.  In March 1996 Steve Peter, then a member of the American Stock Exchange, sought to enlist the assistance of Edwin Crooks, the most powerful member of the Board of the American Stock Exchange, to influence an arbitration case in an amount exceeding $20,000 between Margot Reilly (later Mrs. Peter) and Nino Armenti.  To accomplish this Peter met with Edwin Crooks at Michael’s Restaurant, which was situated on Trinity Place.

 

Edwin Crooks assented to fix the arbitration complaint if Steve Peter would murder Plaintiff.  Crooks also offered to make Steve Peter a member of the Amex Board; to obtain a small specialist unit for Steve Peter; and, to arrange a joint book operation for financing.  The source of this information: Steve Peter.  Peter told Plaintiff that Crooks hated Plaintiff because in 1985 and 1990 Plaintiff had reported Crooks for trading on inside information concerning the movement of the XMI, a stock index- information that Edwin Crooks had received from his cousin, Donald Crooks, at Morgan Stanley.  In April 1985 Ed Crooks told Plaintiff about the insider trading and even displayed a ticket to purchase puts in the XMI.  There are more details, but Plaintiff shall gladly address them in open court.  These were discussed in the original complaint (Exhibit 7 of this complaint) and in a letter, dated 30 December 1999, addressed to Inspector O’Hare (Exhibit 8).  In 2000 Inspector O’Hare was removed from his position as Commander of the Wall Street Substation for having Plaintiff illegally followed by the NYPD.  Glad to discuss this in open court- and Plaintiff has enclosed Plaintiff’s letter to Inspector O’Hare as Exhibit 7.   Believe that Plaintiff is lying, then Plaintiff must be arrested for perjury.

 

Approximately two weeks before his murder or suicide, Edwin Crooks approached Plaintiff.  Crooks apologized to Plaintiff for attempting to have Plaintiff murdered.  Crooks also apologized for covering up the rapes that had been perpetrated by Robert VanCaneghan.

 

Judge Townes’ second example involves someone posing as Assistant Attorney General Joanne Harris.  As stated in the original complaint, Plaintiff had addressed three letters to Joanne Harris, (13 June 1994, certified mail Z 282 188 889; 14 June 1994, certified mail Z 282 188 892; and, 7 August 1994, Z 306 464 541).  Assistant Attorney General Joanne Harris was in charge of the Criminal Division of the Justice Department.  Plaintiff wrote to Harris concerning the sexual assaults/rapes to which Robert VanCaneghan, a member of the Board of the Amex, had admitted.  Plaintiff had written to Assistant Attorney General Joanne Harris and had requested that the Department of Justice and the FBI investigate the rapes that had been perpetrated by Robert VanCaneghan and to which rapes Robert VanCaneghan had admitted in a confession to members of the Board of the American Stock Exchange.

 

On 6 July 1994, Plaintiff received a message on his telephone answering machine, purportedly from Joanne Harris.  In this message the individual posing as Harris stated that FBI Special Agent Joseph Yastremski was investigating the sexual assault/rapes, to which Robert VanCaneghan had admitted to the Amex Board.  Note:  Plaintiff was informed of VanCaneghan’s admission that he had sexually assaulted/raped his female employees by Denis Goin, at that time a member of the Board.  Plaintiff was also informed that Lewis Lowenfells resigned from the Amex Board in protest of the cover up.  Believe Plaintiff is lying, then have Plaintiff arrested for perjury.

 

The above incident involving Assistant Attorney General Harris is the reason that Plaintiff demands access to his Department of Justice files, i.e., all notes memoranda, letters, documents, records of surveillance, etc. and to all documents in which Plaintiff’s name appears.  These files shall show, who had access to Plaintiff’s letters and Plaintiff’s files.

 

Several weeks later Plaintiff contacted FBI Special Agent Joseph Yastremski concerning this purported message from Harris.  Yastremski stated that he was not investigating the rapes to which Robert VanCaneghan had admitted.  On the last page of Scandal On Wall Street, Gary Weiss stated:  “He learned that employees of a specialist firm, run by a highly placed figure at the exchange, had allegedly been sexually assaulted by the official.”       So someone at the Department of Justice or the FBI knew of Plaintiff’s letters and interfered with a federal investigation.

 

Judge Townes’ third example involves money laundering, narcotics smuggling, etc., Plaintiff was informed of these crimes by FBI Agent Yastremski. Plaintiff knew of these crimes, but did not report these crimes to Yastremski because Plaintiff knew that these crimes were unbelievable and that Yastremski eventually would uncover the money laundering and narcotics smuggling.  Yastremski asked Plaintiff for his assistance in investigating money laundering by Louis Miceli and Robert VanCaneghan via their eponymous broker dealer, Miceli-VanCaneghan.  The money came from the Cayman Islands.  If Judge Townes had read the affidavit of anonymous, (Exhibit 6 of this complaint), Judge Townes would have seen collaboration for the money laundering.  Also Plaintiff in open court shall gladly explain the money laundering.  As for the narcotics smuggling, Plaintiff was informed of the narcotics smuggling by FBI Agent Yastremski during a telephone call and Plaintiff’s assistance was requested.  Note:  A copy of the original affidavit was sent to Representative John Dingell.

 

Most importantly Plaintiff Manfredonia has provided a copy of a sworn statement by Patrick Azzara (Exhibit 3).  This sworn statement proves that FBI Special Agent Joseph Yastremski was investigating money laundering, narcotics smuggling, payoffs by Al Avasso to Amex officials, etc. at the American Stock Exchange.  Please note that Azzara has sworn that FBI Special Agent Joseph Yastremski was investigating money laundering by Robert VanCaneghan and Louis Miceli, and drug smuggling by Louis Miceli.

 

It is precisely these files, that contain Plaintiff’s name and information, which files Plaintiff is demanding from the FBI because Plaintiff assisted the FBI and provided information.

 

But Judge Townes is totally devoid of any reality when she describes as incredible Plaintiff’s statement of facts and makes reference to a court decision, which uses the term “delusion” to describe Plaintiff’s facts.  Sorry, Judge but here is a real life example of life on Wall Street- and it shall be brief.  But Plaintiff shall gladly discuss this matter in open court.  But now Plaintiff shall provide an example of a threat that is in the FBI files- and another reason why Plaintiff seeks his FBI files, which the FBI has refused to grant to Plaintiff.

 

On 3 December 1993 Plaintiff was threatened with murder by Alan Umbria, a member of the American Stock Exchange.  Umbria was employed by Carl Icahn.  Umbria credited his employment with Icahn as a favor Icahn made to a Mafia-controlled pension fund for financing years ago.  Plaintiff immediately reported this death threat to FBI Special Agent Joseph Yastremski and to AUSA Frances Fragos.  Plaintiff also delivered a letter, dated 3 December 1993, which described this incident, personally to the FBI.  It was a copy of this letter, which James Kallstrom, Assistant Director of the FBI gave to the American Stock Exchange.  A copy of this letter was in the possession of Louis Miceli on the day that Miceli was forced to leave the Amex.  On this date, Miceli met with members of the Italian Mafia at Umbria’s Mafia controlled restaurant, The Court of the Three Sisters.  Check it out in Plaintiff’s FBI files.

 

As a result of Umbria’s death threat, AUSA Frances Fragos ordered FBI Special Agent to go to the Amex and pick up Umbria for threatening Plaintiff.  Yastremski did this and told Umbria that he would be arrested if he (Umbria) were to threaten Plaintiff’s life on another occasion.

 

The above incident is described in the notes and records of FBI Special Agent Yastremski and Assistant United States Attorney Frances Fragos.  These notes are proof of the veracity of Plaintiff’s statements.  Plaintiff’s demands all notes, memoranda, letters, records, etc., which discuss Umbria’s death threat to Plaintiff; Yastremski warning to Umbria; Fragos’ order authorizing Yastremski to pick up Umbria, etc. which records, files, notes, memoranda, documents, etc. are in the possession of the Department of Justice and the Federal Bureau of Investigation.

 

Once again Plaintiff must stress that if Judge Townes believes that Plaintiff has committed perjury, Judge Townes must have Plaintiff arrested and charged with perjury.  Then Plaintiff shall obtain his “FBI files.”  Incidentally, Plaintiff finds it strange that Judge Townes does not understand the meaning of the term, “FBI files,” but the FBI certainly does.

 

Plaintiff finds it incredible that a federal judge should be a follower of the Mary Poppins school of Wall Street and believe, especially after the CMO crisis, that the federal government does not cover up crime on Wall Street.  Furthermore, contrary to the delusional view of the Mary Poppins school of thought, Plaintiff has proved throughout his original complaint, Exhibit 7, proof that the federal government has covered up hellacious crime on Wall Street.  Judge Townes can read the original complaint and then can compare the disciplinary actions undertaken by the Amex and the SEC with Plaintiff’s letters, which have reported these same violations of federal security laws.  And then Judge Townes can read several of Plaintiff’s articles in which Plaintiff explains his letters and elucidates the violations of federal securities laws.

 

Sorry Judge Townes, but Wall Street is not exactly Willy Wonka and the Chocolate factory for the American public.  But you know that and do not wish Plaintiff to obtain his FBI files.

 

A book about Wall Street does not begin:  “And the men and women of Wall Street were so altruistic that rather than make money on increasing the price of rice, wheat and corn so that children could be healthy ….”  That is the Mary Poppins view of Wall Street.

 

It is here that Plaintiff would like to discuss “the FBI wire order,” (Exhibit 2).  Plaintiff received this document in 1994 in response to a request to the FBI.  The learned Judge Townes has stated that this document is “an altered and indecipherable document.”  The only alteration made was to delete some personal information concerning Plaintiff.  As for the document being indecipherable, Plaintiff wishes to state that whenever Plaintiff has shown that document to an attorney in federal court, the attorney immediately recognizes the document as authorizing a wire order.  So, Plaintiff has joyously provided another copy of the document (Exhibit 1).  By the way it is a violation of federal law to forge a federal document.  So Judge Townes you could have Plaintiff arrested for forging an official document or a federal document and for committing perjury.  Then the federal court can assign an attorney to represent Plaintiff.  Perhaps this is the best alternative.  Plaintiff shall be glad to discuss this in open court- and on the record.

 

In her Memorandum and Order Judge Townes abruptly dismissed Plaintiff’s affidavit to President Bush (Original complaint, Exhibit 2, this complaint Exhibit 2).  Judge dismissed this affidavit, which described Plaintiff’s meeting with AUSA Frances Fragos (Townsend).  It would be very easy to verify this meeting and the discussion, which took place.  Plaintiff was required to sign in at the office of the United States Attorney for the Southern District.  AUSA Frances Fragos asked Plaintiff what Greenwald told Plaintiff about Motel 6.  Plaintiff responded that it was either “Buy it. It’s guaranteed,” or “It’s guaranteed. Buy it.”  AUSA Frances Fragos stated that she knew that Plaintiff had not traded Motel 6 on the basis of inside information.  As a matter of fact, FBI Special Agent Joseph Yastremski verified that Plaintiff had represented Frost & Sullivan on the floor of the Amex.  Plaintiff executed option orders, always to purchase call options, for Frost & Sullivan and provided advice in trading options.

 

Plaintiff even explained to FBI Special Agent Joseph Yastremski that Plaintiff had asked for markets in options in Square D- five hundred lots at a time- prices began at 1 11/16 for 500 option calendar spreads, 1 ¾ for the next 500, and so forth.  There are records of this at the Securities and Exchange Commission, the Department of Justice, and the Federal Bureau of Investigation.  These records shall prove that Plaintiff provided excellent information concerning illegal trading in Motel 6.  Plaintiff shall explain this in greater detail in Court.  Plaintiff demands these notes, memoranda, documents, letters, etc. which are in the exclusive possession of the Securities and Exchange Commission, Department of Justice and the Federal Bureau of Investigation, which notes, memoranda, files, documents, letters, etc., which pertain to Motel and mentions Plaintiff’s name or allude to Plaintiff.

 

One more incident shall suffice to prove that members of the American Stock Exchange do not sit around and recite:  “Little Bo Peep has lost her sheep….”

 

Richard Mondarine (Monderine) was at one time in charge of floor operations at the Amex.  Under threat of dismissal and also of not receiving earned promotions, Mondarine forced young African-American single mothers to perform fellatio upon him in order to maintain employment at the Amex. In 1987 Plaintiff reported Mondarine.  Mondarine was not fired.  The Amex members were in an uproar.  But when Plaintiff was threatened, Plaintiff simply stated that he could beat them and the threats upon Plaintiff stopped.  For a while the sex slavery of performing fellatio stopped.  It was only after Plaintiff was forced from the floor that Mondarine continued his sexual slavery.  But Judge Townes is a federal judge with lifetime tenure- so the degradation of minority women does not matter to her.

 

Nor obviously do the horrors of 70 million Filipinos possess any meaning to Judge Townes.  As Plaintiff stated in his original complaint, Plaintiff’s business associate, Heinz Grein, Chairman of Frost & Sullivan and a former currency trader for a German Bank, laundered money for the Italian Mafia (Al Avasso) into Luxembourg Banks and the $10 billion, which sum Ferdinand Marcos looted from the Philippines into Swiss Banks.  Heinz Grein pleaded guilty to masterminding the Motel 6 insider trading scandal and the FBI knew that he had laundered money- due to Plaintiff’s information.  Plaintiff demands all information concerning the location of Marcos’ billions, which is in the possession of the Department of Justice and the Federal Bureau of Investigation.

 

It must here be noted that Plaintiff was the only individual associated with Frost & Sullivan and several other firms, who both possessed inside information on Motel 6 and did not trade on the basis of inside information.  AUSA Frances Fragos stated that she knew that Plaintiff had not traded on the basis of inside information.  AUSA Frances Fragos stated that she knew that Plaintiff had not traded on the basis of inside information.  AUSA Frances Fragos stated that Joseph Greenwald, who pleaded guilty to trading Motel 6 on the basis of inside information, had provided Plaintiff with inside information on Motel 6.  This information concerning Motel 6 and Grein’s laundering of money for Al Avasso and Ferdinand Marcos can be found in the notes, memoranda, documents, letters, etc. of the Federal Bureau of Investigation, Department of Justice, and the Securities and Exchange Commission.  (See BusinessWeek article, The System Was Perfect, 10 August 1992 (Exhibit 9).  Plaintiff has enclosed a copy of his American Stock Exchange identification card, which proves that Plaintiff had represented Frost & Sullivan on the floor of the American Stock Exchange.  Please note that Heinz Grein’s business card has Grein’s 1989 home telephone number.

 

Furthermore, Plaintiff Manfredonia provided names of other individuals, who traded Motel 6 on the basis of inside information- most notably Gary Rosen, who boasted of having earned more money trading on inside information than Jeff Green, who was prosecuted for trading on the basis of inside information.

 

And here is a bonus for Judge Townes. Plaintiff Manfredonia provided FBI Special Agent Joseph Yastremski with information that Michael Borlinghaus, a principal in Frost & Sullivan, had another firm, to which he provided inside information on Motel 6 and other issues, and which firm had traded on the basis of this inside information.  The FBI did not know this until Plaintiff informed the FBI..  Borlinghaus served a prison term for not providing this information to the FBI.  If Judge Townes does not believe Plaintiff, eh Court can either subpoena the relevant notes, documents, files, letters, etc. which are in the exclusive control of the Federal Bureau of Investigation, the Department of Justice, and the Securities and Exchange Commission.  Plaintiff Manfredonia demands the aforementioned notes, memoranda, letters, documents, etc., i.e., everything that mentions Plaintiff’s name pertaining to insider trading in Motel 6 that is in the possession of the Department of Justice, the Federal Bureau of Investigation and the Securities and Exchange Commission.

 

This fact can be easily verified by records at the Department of Justice, Federal Bureau of Investigation and Securities and Exchange Commission, which detail Plaintiff’s involvement with the firm of Frost & Sullivan and the fact that Plaintiff did not trade on the basis of inside information. Plaintiff demands these records from the Department of Justice, Federal Bureau of Investigation and Securities and Exchange Commission.

 

Judge Townes is aware from reading Plaintiff’s original complaint (Exhibit 7) that Richard Syron, former Chairman of the American Stock Exchange, former Chairman of Thermo Electron and currently Chairman of Freddie Mac, was involved in stock manipulation and illegal trading.  Furthermore, Judge Townes knows that Syron had been institutionalized.  Plaintiff wishes to assure the Court that Judge Townes would never write about Syron, a certified lunatic and stock price manipulator in the same manner in which Judge Townes has degraded Plaintiff.  Why?  Because Plaintiff has no money and is self-represented.  Syron, who did not work for more than one year because of mental health issues, is one of the individuals most responsible for the housing and CMO mess, yet Judge Townes would treat Richard Syron with respect.  Plaintiff reported illegal trading in subsidiaries of Thermo Electron to the SEC as early as 1996- yet it was only in 2006 that the Amex disciplined Ron Menello and Al Merendino for price manipulation of Thermo Electron subsidiaries.  Syron was actively involved in covering up the civil and criminal violations of federal securities laws, which were highlighted in the article, Scandal On Wall Street.  Furthermore, Syron was actively involved in the price manipulation of the subsidiaries of Thermo Electron, so that his good friend, John Hatsopoulos, could benefit at thee expense of the shareholders of Thermo Electron when the stocks of the subsidiaries were purchased by Thermo Electron.  Currently, Syron more than any other individual is responsible for the collapse of Freddie Mac.  Plaintiff demands his records at the SEC to know why Plaintiff was ignored.

 

It is also apparent that Judge Townes has willfully mischaracterized much of Plaintiff’s original complaint.  Plaintiff illustrated his original complaint with much detail concerning many violations of federal securities law that the Department of Justice, the Securities and Exchange Commission, and the Federal Bureau of Investigation have refused to investigate.

 

Surely, Judge Townes recalls the stock fraud, Crazy Eddie.  So Plaintiff shall only repeat the part of the original complaint that deals with Plaintiff’s letter of 9 April 2007, which letter stated that Crazy Eddie was illegally laundering money into the United States.  Please note the date.  2007 was last year; not ten years ago.

 

On 9 April 2007 Plaintiff wrote a letter, certified mail 7005 1820 0004 1210 8872, to Christopher Cox, Chairman of the Securities and Exchange Commission concerning Eddie Antar’s illegal tens of millions of dollars.

 

“The following information came to me from several members of an orthodox synagogue, which is situated on Ocean Parkway in Brooklyn, New York.

 

“Sam Antar, Eddie Antar, and other individuals involved in the scam of Crazy Eddie were members of this synagogue.

 

“In September 2005 I met a cousin of Eddie Antar.  This cousin informed me that Crazy Eddie was sending money via an Israeli Bank to his relatives. He told me that Eddie Antar had sent $20,000 to pay for his niece’s bat mitzvah.  If my memory is correct, it was for the daughter of Eddie’s sister.

 

“This individual and other members of the synagogue, whom I knew, told me that members of Crazy Eddie’s orthodox Sephardic synagogue, had been informed by the Antars (Crazy Eddie, his father, Sam Antar) that Crazy Eddie was a fraud.  These individuals then shorted the stock of Crazy Eddie- and made millions.  Also, the Antars contributed millions of dollars to their synagogue.

 

“Members of the synagogue also told me that Eddie Antar had shorted the stock in offshore accounts and that Eddie Antar had made tens of millions of dollars shorting the stock- and that the SEC was unaware of this.”

 

Plaintiff also reported that Eddie Antar had illegally kept tens of millions of dollars that Eddie had illegally earned in the stock fraud, Crazy Eddie, to the Department of Justice, the Federal Bureau of Investigation, and to the Securities and Exchange Commission- pages 63-65 of Plaintiff’s original complaint (Exhibit 7).

 

Eddie Antar owes hundreds of millions of dollars to the SEC and the American public.  The federal government has refused to follow Plaintiff’s leads- because the federal government has been covering up crimes that Plaintiff reported.

 

Plaintiff wishes to take issue with a misstatement in Judge Townes’ decision.  Plaintiff never requested a Bivens action.  Plaintiff never suggested that he would sue any individual, who was an employee of the federal government.  So it is an utter falsehood to state this,

 

Judge Townes also falsely states on page 5 of her Memorandum and Order:  “The Complaint does not provide the Court with notice of what claim or claims he seeks to make, and does not provide defendants with the information necessary for them to respond.”  That is simply not true.  In the section, REMEDY SOUGHT of Plaintiff’s original complaint (Exhibit 7), Plaintiff has written:

 

“IV:  REMEDY SOUGHT

Plaintiff Edward Manfredonia is entitled to his FBI files, his Department of Justice files, and his Securities and Exchange Commission files- and all material requested in this Complaint.

The Freedom of Information Act requires that the FBI, DOJ, and SEC provide Plaintiff Manfredonia with all information.”

 

That should be sufficient notice of remedy sought.

 

Judge Townes, if you believe that Plaintiff Manfredonia is dissembling, Plaintiff Manfredonia should be arrested and charged with perjury.  And then the Court can provide Plaintiff with an attorney, who shall properly submit court papers for Plaintiff’s files at the Department of Justice, Federal Bureau of Investigation, and Securities and Exchange Commission.  There is nothing to be gained by defaming Plaintiff, although Plaintiff knows that a Judge cannot be charged with defamation for official pronouncements.  Charge Plaintiff with perjury and let the Courts determine the veracity of Plaintiff’s claims.

 

 

FREEDOM OF INFORMATION ACT REQUEST- DEPRTMENT OF JUSTICE

 

Plaintiff Edward Manfredonia also followed the proper procedure in requesting Plaintiff’s records from the Department of Justice.

 

On 3 May 1994 Plaintiff Manfredonia sent a registered letter to Mr. Benjamin Burrell, Director, Justice Management Division of the Department of Justice.  Plaintiff requested his records thus:  “I wish to have access to my records.”  (Exhibit 10)

 

Plaintiff never received a response from the Department of Justice.  The Department of Justice never granted Plaintiff access to his records, i.e., all files, documents, notes, memoranda, records of surveillance, etc. which Plaintiff had requested.

 

It is here that Plaintiff must once again discuss his 13 September 1993 meeting with AUSA Frances Fragos in the offices of the United States Attorney for the Southern District of the State of New York.  As Plaintiff had previously stated there were three participants in this meeting:  Plaintiff Edward Manfredonia, Assistant United States Attorney Frances Fragos, and Federal Bureau of Investigation Special Agent Joseph Yastremski.  Plaintiff’s affidavit to President Bush, Exhibit 2, explicates this 13 September 1993 meeting.  Plaintiff demands all notes, memoranda, letters, documents, etc. which pertain to this meeting and all documents of this meeting which describe the money laundering, narcotics smuggling, payoffs to Amex officials, etc. that were discussed at this meeting.

 

Plaintiff also demands all notes, memoranda, documents, letters, etc. which pertain to the confrontation between Alan Umbria, a front for the Italian Mafia at the AMEX, and FBI Special Agent Joseph Yastremski- and the approval of AUSA Frances Fragos for FBI Special Agent Joseph Yastremski to pickup Alan Umbria.

 

As Plaintiff has stated AUSA Frances Fragos believed Plaintiff Manfredonia- and this belief was stated after FBI Special Agent Joseph Yastremski had totally vetted Plaintiff Manfredonia and Plaintiff’s information.

 

It is not that Judge Townes and her law clerk do not believe that Plaintiff met with AUSA Frances Fragos and FBI Special Agent Joseph Yastremski, it is that Judge Townes is an advocate of covering up malfeasance and criminal activity of the Department of Justice and the FBI.  After all, AUSA Frances Fragos believed Plaintiff about the serial rapes that had been perpetrated by Robert VanCaneghan.  And one more caveat.  AUSA Frances Fragos told Plaintiff that Mary Jo White, United States Attorney for the Southern District of the State of New York, had to go to Washington personally in order to obtain approval to investigate the American Stock Exchange because of the influence of Arthur Levitt, then Chairman of the Securities and Exchange Commission.  Plaintiff was led to believe that Janet Reno, United States Attorney General, was involved in the decision to investigate the American Stock Exchange.

 

On 9 April 2001 Plaintiff met with two representatives of the Anti-Trust Division of the Department of Justice, Hayes Gorey and George Baranko, in the 40 Exchange Place offices of Bill T. Singer.  Plaintiff Manfredonia proved in a five and a half hour discussion, replete with blackboard demonstration, that the prices of the Exchange Traded Funds, which were traded at the American Stock Exchange, were price-fixed to the amount of $350 million per annum.

 

Several weeks later, Bill T. Singer contacted Plaintiff Manfredonia.  Singer stated that he had been informed by Baranko and Gorey that Baranko had been told that they could not utilize any information that Plaintiff Manfredonia had provided.  Gorey and Baranko were told that if their investigation were the result of information, which Plaintiff Edward Manfredonia had provided. The investigation must be dropped.  Plaintiff demands to know why Plaintiff’s information could not be utilized.  Plaintiff seeks all records, documents, files, notes, memoranda, etc. of this meeting and all records, notes, memoranda, documents, etc. at the Department of Justice in which Plaintiff’s name is mentioned.

 

Bill T, Singer stated that Baranko and Gorey had informed him that Arthur Levitt had utilized his influence to smear Plaintiff Manfredonia.  It must here be noted that Plaintiff Manfredonia had agreed to assist Bill T. Singer in a class action lawsuit, which would involve the Exchange Traded Funds, if Singer would sue for Plaintiff’s FBI, SEC and DOJ files.  Singer reneged and his planned lawsuit collapsed.

 

It was Singer, who told Plaintiff that there was a directive that forbade the Securities and Exchange Commission and the Department of Justice from utilizing Plaintiff’s information.  Plaintiff demands a copy of this document.

 

Plaintiff seeks all notes, memoranda, documents, files, records, records of surveillance, which not only pertain to Plaintiff’s meeting with Hayes Gorey and George Baranko but also all notes, memoranda, of Plaintiff’s meeting with AUSA Frances Fragos; all records of telephone conversations with AUSA Frances Fragos; all documents, files, records, memoranda, etc.- everything which mentions Plaintiff’s name.

 

Plaintiff had written letters to the Department of Justice.  Plaintiff also spoke to Steven Beck, an Investigator for the Department of Justice, several times on the telephone.  Plaintiff demands all records, notes, memoranda, etc. which pertain to Plaintiff and in which Plaintiff’s name is mentioned. This is especially true of Plaintiff’s telephone conversations with Steven Beck.

 

I cannot fathom how Judge Townes cannot believe me.  My documentation is extensive.

 

SECURITIES AND EXCHANGE COMMISSION FREEDOM OF INFORMATION ACT REQUESTS

 

In this section Plaintiff shall prove that on numerous occasions Plaintiff has faithfully and properly requested his “SEC files,” that is, all letters, records, files, notes, memoranda, etc., which documents mention Plaintiff’s name or allude to Plaintiff via a pseudonym.

 

Plaintiff had written to the Securities and Exchange Commission on other occasions and has requested to view his records.  On 6 July 1993 Plaintiff Manfredonia wrote to Arthur Levitt, Chairman of the Securities and Exchange Commission, to “view my dossier.”  On 10 January 1993 Plaintiff Edward Manfredonia wrote to William McLucas, Director, and requested: “Would you please reply to my request to vie my files at the SEC?”

 

On 17 February 1993 Plaintiff wrote to Ms. Hanna Hall, FOIA/Privacy Act Branch Chief at SEC headquarters and requested his files.  (Exhibit 11)

 

On 24 January 1993 Plaintiff wrote to Arthur Levitt and requested that the SEC:  “order the American Stock Exchange to grant me access to my records.”

 

On 27 July 1993 Plaintiff wrote to Arthur Levitt and requested that the SEC:  “order the American Stock Exchange to grant me access to my files.” Incidentally, Judge I wrote to the head of the SEC.

 

On 23 August 1993 Plaintiff Manfredonia received a response from the SEC from Gay La D. Sessoms and was told that the Securities and Exchange Commission could not order the American Stock Exchange to grant Plaintiff access to his records.  When Plaintiff Manfredonia met with Assistant United States Attorney Frances Fragos on 13 September 1993, AUSA Frances Fragos told Plaintiff that this was a lie.

 

Plaintiff Manfredonia shall now quote from the letter, dated August 27, 1993, which letter Gayla D. Sessoms sent to Plaintiff.

 

“Your letters dated July 26 and July 27, 1993 addressed to Marcy Schapiro, Acting Chairman and William McLucas, Director of Enforcement, respectively were referred to this office for a response.  You requested the Commission to direct the American Stock Exchange (“AMEX”) to permit you access to your files under the Commission’s rules and regulations.

 

“The AMEX is a self-regulatory organization subject to the Commission’s oversight under the Securities Exchange Act of 1934.  However, the Commission does not have the authority to compel the AMEX to produce your records to you.  Therefore, you may wish to consult an attorney to discuss any legal alternatives for securing copies of your records directly from the AMEX.”

 

Now this Court and every first year law student know that Sessoms lied- and Sessoms lied with the approval of Mary Schapiro and William McLucas. But who told Sessoms to lie?

 

Plaintiff shall uncover this whey Plaintiff obtains his files from the Securities and Exchange Commission.  By “SEC files” Plaintiff means all records, letters, documents, and notes, memoranda, etc. in which Plaintiff’s name is mentioned or in which Plaintiff is refereed to by a pseudonym or alias.

 

Incidentally, if Judge Townes or her “hubris-confident” law clerk believes that Plaintiff has committed perjury, the Court can subpoena former Securities and Exchange Commissioner Cynthia Glassman and inquire why when she recommended the investigations of Plaintiff’s allegations; Commissioner Cox vetoed them and ordered a cover up.

 

Please remember that it was AUSA Frances Fragos, who in 1993 told Plaintiff that the SEC would not investigate any charges of violations of federal securities laws, which Plaintiff had made.  AUSA Frances Fragos stated that Arthur Levitt had ordered a cover up.  So, Judge Townes and her law clerk can read Plaintiff’s affidavit to President Bush.

 

In 2002 Plaintiff asked an attorney, Michael Bressler, to obtain his files at the Securities and Exchange Commission.  Michael Bressler wrote a letter to the Securities and Exchange Commission.  This letter requested Plaintiff’s records (Exhibit 11).  It must here be noted that Michael Bressler informed Plaintiff that if the SEC had not responded to Plaintiff’s previous requests for his SEC files, a lawsuit could be initiated by Plaintiff against the SEC. In 2002 Plaintiff provided Bressler with a copy of a letter to the SEC and a letter of authorization.  Plaintiff has attached as Exhibit 11, Bressler’s letter to the SEC, which letter requested Plaintiff Manfredonia’s files.  Note:  Michael Bressler was disbarred in 2004 and the letters, which Plaintiff had received from the SEC, were lost with Plaintiff’s records that were held by Bressler.  The SEC, however, does possess copies of all letters, which were sent to Plaintiff.  Plaintiff seeks copies of this correspondence.

 

Please note that although the letter names Plaintiff as Edward A. Manfredonia, all documents that were sent with this letter, including copies of Plaintiff’s previous requests and Plaintiff’s Certificate of Identity, identified Plaintiff as Edward Manfredonia, a former member of the American Stock Exchange.  Please note that Plaintiff Edward Manfredonia had been a member of the American Stock Exchange, so the SEC had a file or dossier on Plaintiff and was duty bound to provide copies of all information concerning Plaintiff to Plaintiff.

 

If Judge Townes does not believe Plaintiff, Judge Townes must have Plaintiff arrested and charged with perjury.  Then Plaintiff shall obtain his SEC files, i.e., all records, notes, memoranda, documents, etc., as the FBI stated.  The only way that Plaintiff shall obtain his SEC files is if Plaintiff is arrested on a federal charge.  So, let us begin the process.

 

 

 

FREEDOM OF INFORMATION REQUEST- FEDERAL BUREAU OF INVESTIGATION

 

Judge Townes in her Memorandum and Order has stated that Plaintiff Manfredonia was required to follow the proper procedure in requesting his FBI files, by which Plaintiff meant any documents, i.e., files, notes, records, memoranda, letters, records of surveillance, etc. which mentioned Plaintiff’s name.  So, it is here that Plaintiff must asseverate most forcefully that Plaintiff followed the proper procedures.

 

Circa 1994 Plaintiff requested his FBI files.  Plaintiff receive din the mail the document, which Plaintiff has referred to as “Plaintiff’s FBI wire order.” Plaintiff’s receipt of this document proves that Plaintiff not only wore a wire for the FBI, but that Plaintiff had properly requested his “FBI files,” which incidentally Judge Townes should be the proper way of requesting Plaintiff’s SEC files and Department of Justice files.  There cannot be a different wording for requesting files for each branch of the government.  Not only that but Plaintiff had properly requested “his FBI files” from the proper section, the FOIAPA Section.  So, Judge Townes it appears that Plaintiff has followed proper procedures.  For your information, if Plaintiff’s memory is correct, FBI Special Agent Joseph Yastremski was in the C2 Section.

 

And Judge Townes, please do not belittle the sworn statement of Patrick Azzara, which discusses his meeting with FBI Special Agent Joseph Yastremski and which sworn statement confirms Plaintiff’s charges of narcotics smuggling, money laundering, bribery, etc. at the American Stock Exchange.

 

Plaintiff shall provide samples of letters, which Plaintiff had sent to the Federal Bureau of Investigation, FOIA Section.  But Plaintiff must first note that Plaintiff Manfredonia had been told by an FBI Special Agent that the Federal Bureau of Investigation would never grant Plaintiff Manfredonia complete access to his FBI files, i.e. all notes, memoranda, documents, letters, records of surveillance, etc.,- unless Plaintiff were arrested on a federal warrant and were charged with a crime that would necessitate the release of Plaintiff’s FBI files, i.e., all notes, records, memoranda, documents, etc. that mention Plaintiff’s name or refer to him.

 

The FBI has violated federal statute by not permitting Plaintiff Manfredonia complete and unfettered access to his FBI files.  In violation of federal law and the Freedom of Information Act, Plaintiff Manfredonia has been denied the right to have access to his FBI files, i.e., notes, records, memoranda, letters, records of surveillance, etc., which mention Plaintiff’s name- or perhaps Judge Townes can provide Plaintiff with another term for Plaintiff’s records and files that are at the FBI?  The only information that the FBI has provided Plaintiff and that was in early 1994 was a copy of Plaintiff’s FBI wire order- an FBI document that Judge Townes did not recognize.  This document proves that Plaintiff had been wired by the FBI.

 

Plaintiff Manfredonia has requested access to his FBI files on many occasions.  In a letter, dated 21 July 1993 to J. Kevin O’Brien, FOIPA Section, Plaintiff wrote “concerning my request to view my records.”  (Exhibit12).  In a letter, dated 19 March 1994, to Mr. Kevin J. O’Brien, Plaintiff Manfredonia made reference to his FOIPA NO. 375,318 and asked to view his FBI records.

 

The Court must note that in 1994 Plaintiff Manfredonia received what Plaintiff has termed his “FBI wire order,” a document which Judge Townes has incomprehensibly disavowed- unless Judge Townes has never presided over a case where an informant was wired.  So Plaintiff’s FBI wire order is proof positive that Plaintiff had properly requested his FBI files, i.e., all documents, records, notes, memoranda, etc. that mentions Plaintiff’s name and pertains to Plaintiff.

 

On 15 October 1993 Plaintiff Manfredonia sent a letter, certified mail P 397 542 208, to Mr. Kevin J. O’Brien, Chief Freedom of Information and Privacy Act Section, and requested Plaintiff’s files.  (Exhibit 12)

 

On 11 June 1998 Plaintiff wrote a letter, certified mail P 311 766 501, to Mary Jane Broca, Supervisory Special Agent.  Plaintiff wrote to Broca requesting specific letters, which Broca had written (Exhibit 12).  Mary Jane Broca then instructed Plaintiff to write to the FOIA Section.  Plaintiff did so, but never received the requested letters.  Those were specific instructions, which Plaintiff followed, Judge Townes.

 

Plaintiff then wrote to the FBI and requested these letters.  Plaintiff received a letter in December 1998 from Kevin O’Brien, FOIPA Section.  This letter inquired if Plaintiff wished to continue his request for Plaintiff’s FOIPA request.  So, it appears that the FBI understood the meaning of Plaintiff’s requests.

 

Plaintiff then wrote to Kevin O’Brien on 14 December 1998, certified mail Z 055 653 268, which letter was sent to Mr. Kevin O’Brien, FOIPA Section, 935 Pennsylvania Avenue NW, Washington, DC 20535-0001 and requested Plaintiff’s files (Exhibit 12).  Unfortunately Plaintiff is unable to locate many of his letters from the FBI because many of these records were kept in the office of Michael Bressler and were lost in 2004.  Judge Townes, these are records readily available from the FBI- unless Judge Townes wishes to cover up more malfeasance.  Plaintiff’s letter, dated 14 December 1998, is Exhibit 12.  Plaintiff’s letter of 14 December 1998 to Kevin O’Brien was not answered- it was ignored.  Sorry, Judge Townes there is no way of appealing an ignored letter.  And Bill T. Singer told me that the only means, by which I could obtain my FBI files, when my letters were ignored, was to sue in federal court.

 

Furthermore in 2002 Plaintiff asked an attorney, Michael R. Bressler, to request Plaintiff’s FBI files.  While Plaintiff is unable to locate that letter, Plaintiff has supplied a copy of Bressler’s request to the SEC as Exhibit 11.

 

Plaintiff has proved that Plaintiff has followed the proper procedure and is entitled to Plaintiff’s FBI files- a term, which is understood by the FBI, although not by the Court.  By “FBI files” Plaintiff means all documents, files, records of surveillance, notes, memoranda, etc. which mention Plaintiff’s name.  As proof that Plaintiff has followed the proper procedure Plaintiff must asseverate that the FBI never instructed Plaintiff to follow another procedure to request Plaintiff’s files.

 

Judge Townes, or her law clerk, has made a deliberate and willful misstatement on page 8 of Judge Townes’ Memorandum and Order.  Judge Townes stated:  “… it appears that plaintiff began requesting information from the FBI in 1993, but there is no indication of the result of his requests or whether he appealed the decisions with which he now appears to disagree.”  This is a deliberate factual misstatement.  There were no decisions- and Judge Townes knows this.

 

In early 1994 Plaintiff received his “FBI wire order” as a result of his FOIAPA request, which Plaintiff made in 1993 to the FOIPA Section of the FBI. The FBI provided a copy of “Plaintiff’s FBI wire order.”  This document did not drop like manna from heaven.  Plaintiff did not find it like Miriam’s well.  And Judge Townes has seen many copies of FBI wire orders.

 

The FBI never responded except again to any letters, which Plaintiff had written, that requested Plaintiff’s FBI files- except to provide Plaintiff a copy of his “FBI wire order.”

 

Judge Townes, obey the law and let this legal action proceed- or arrest Plaintiff for perjury and let Plaintiff obtain the documents demanded in Court.

 

 

IV:  REMEDY SOUGHT

 

Plaintiff Edward Manfredonia wishes to asseverate most forcefully that he demands all records of surveillance of Plaintiff from the Federal Bureau of Investigation and the Department of Justice.  Plaintiff wishes to state that the FBI and the Department of Justice do not send individuals, whom it has kept under either surveillance or wire tap, a notice and record of the surveillance.  So, Plaintiff must make a broad request for his files, i.e. notes, memoranda, letters, records, records of surveillance, etc. that are maintained by the Federal Bureau of Investigation and the Department of Justice and which records mention Plaintiff’s name or refer to Plaintiff by an alias or pseudonym.  It is here that Plaintiff must asseverate most forcefully that Plaintiff was never involved in criminal activity so there was never reason for any surveillance or wire tap of Plaintiff Manfredonia..

 

Plaintiff Edward Manfredonia demands that he be provided with copies of his FBI files, that is, all records, documents, notes, memoranda, records of surveillance, records of FBI Special Agent Joseph Yastremski picking up Alan Umbria for threatening Plaintiff’s life, records of telephone conversations with FBI Special Agent Yastremski, etc.- in other words all documents, i.e., notes memoranda, files, records, records of surveillance, etc., in which Plaintiff Manfredonia’s name is mentioned.  Plaintiff has provided a copy of a federal document, Plaintiff’s FBI wire order, which proves that Plaintiff had been wired by the FBI.  Plaintiff has provided a sworn statement by Patrick Azzara a former member of the American Stock Exchange, who faithfully described a meeting with FBI Special Agent Joseph Yastremski.  Plaintiff is entitled to these records, files, etc. under the provisions of the Freedom of Information and Privacy Act.  The FBI must obey the law.

 

Plaintiff Edward Manfredonia demands that he be provided with copies of his Securities and Exchange Commission files, i.e. records, notes memorandums, letters notes, documents, etc. that mention the name of Plaintiff Edward Manfredonia.  Plaintiff wishes to stress that Plaintiff had been informed by several SEC staff attorneys that there was a directive from Arthur Levitt and this directive ordered the SEC not to utilize any information that Plaintiff had provided.  Plaintiff is entitled to these records, files, etc. under the provisions of the Freedom of Information Privacy Act and under the provisions of the Securities Exchange Act of 1934.

 

Plaintiff Edward Manfredonia demands that he be provided with copies of his Department of Justice files, that is, all records, documents, notes, memoranda, records of surveillance, records of telephone conversations with AUSA Frances Fragos, records of the authorization by AUSA Frances Fragos for FBI Special Agent Joseph Yastremski to pick up Alan Umbria for threatening Plaintiff’s life, all records of the 13 September 1993 meeting between Plaintiff Manfredonia, AUSA Frances Fragos, and FBI Special Agent Joseph Yastremski, of which meeting Plaintiff has submitted his affidavit to President Bush, etc.- in other words all documents on file at the Department of Justice that mention Plaintiff’s name.  Plaintiff is guaranteed this information by the Freedom of Information Privacy Act.

 

Plaintiff demands an apology from Justice Townes for using terms such as incredible, delusion, etc. in referring to Plaintiff’s chronology of criminal activity at the American Stock Exchange.  There is an affidavit by Patrick Azzara that confirms Plaintiff’s accusations.  As a federal judge, Judge Townes knows that the federal government chooses whom it prosecutes.

 

Perhaps the case should be assigned to the Honorable Jack Weinstein, who is a fair judge.

 

Plaintiff requests that he be granted in forma pauperis status to appeal any decision by Judge Townes.  Judge Townes has already made a bad faith effort in dismissing Plaintiff’s complaint with derision that should be reserved for a serial killer.  Please remember that Plaintiff is a whistle-blower

 

After all, Judge Townes has stated that Plaintiff’s “FBI wire order,” a document provided by the FBI to Plaintiff was illegible.

 

Plaintiff believes that for whatever reasons, which are known to Judge Townes, Judge Townes is biased against Plaintiff and does not wish to have any pro-se lawsuits, which were initiated by Plaintiff.  Judge Townes has already dismissed Plaintiff’s lawsuit against Yahoo on diversity issues, because, according to Judge Townes, Plaintiff requested excessive damages- even though Plaintiff proved defamation per se and a denial of employment.

 

Judge Townes just does not wish a pro se lawsuit that challenges the federal government.

 

Plaintiff is requesting that you, Judge Townes, recuse yourself from this case.

 

Judge Townes if you truly believe that Plaintiff has committed perjury, you are duty bound to have Plaintiff arrested and charged with perjury.

 

I declare under penalty of perjury that the foregoing is true and correct.

 

 

Dated:

 

Edward Manfredonia

ed manfredonia <edmanfredonia8311@gmail.com> Fri, May 6, 2011 at 2:28 PM
To: edmanfredonia8311@gmail.com, edmanfredonia8337@gmail.com
 

[Quoted text hidden]

Plaintiff shall uncover this whey Plaintiff obtains his files from the Securities and Exchange Commission.  By “SEC files” Plaintiff means all records, letters, documents, and notes, memoranda, etc. in which Plaintiff’s name is mentioned or in which Plaintiff is refereed to by a pseudonym or alias.

<

Ed Manfredonia <edmanfredonia8311@gmail.com> Thu, Aug 18, 2016 at 4:03 PM
To: Ed Manfredonia <edmanfredonia8311@gmail.com>, edmanfredonia8337@gmail.com
 

———- Forwarded message ———-
From: ed manfredonia <edmanfredonia8311@gmail.com>
Date: Sun, Oct 24, 2010 at 7:56 AM
Subject: FBI Lawsuit Amended
To: edmanfredonia8311@gmail.comedmanfredonia8337@gmail.com
UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF NEW YORK

____________________________________________________X

 

Edward Manfredonia,

 

Plaintiff,

AMENDED COMPLAINT

                  

                                                                   08-CV-1678 (SLT)(LB)

 

                                                                   JURY TRIAL DEMANDED

 

-against-

 

 

Securities and Exchange Commission of the United States,

Department of Justice of the United States,

Federal Bureau of Investigation

 

________________________________________________________________x

 

                                   

                                                VERIFIED COMPLAINT

 

_________________________________________________________________X

 

Edward Manfredonia, the plaintiff herein, being duly sworn, deposes and says:

 

Parties in this complaint are listed below:

 

A.  Plaintiff:

Edward Manfredonia

c/o McCormick

8337 St. James Avenue

Apt. 4B,

Elmhurst, NY 11373.

Telephone Number:  718-457-8135

 

B  Defendants:

 

1.      Department of Justice

One Saint Andrew Plaza

New York, NY 10007

212 637 2200

3.  Federal Bureau of Investigation

26 Federal Plaza

New York, NY 10278

212 384 1000

4.  Securities and Exchange Commission

3 World Financial Center

4th Floor

New York, NY 10281

212 336 1100

 

II   Basis for Jurisdiction:

 

The basis for Federal Jurisdiction related to Freedom of Information Act is that Plaintiff Edward Manfredonia was wired by the Federal Bureau of Investigation in 1993 and had assisted the Department of Justice in an investigation into money laundering, stock fraud, narcotics smuggling, etc. at the American Stock Exchange.  Plaintiff Edward Manfredonia has written numerous letters, which have detailed criminal activity and violations of federal law, to the Federal Bureau of Investigation; Internal Revenue Service; Department of Justice (United States Attorney for the Southern District of New York, Attorney General of the United States); Securities and Exchange Commission; and other federal agencies.

 

Plaintiff has provided extensive information to the Federal Bureau of Investigation, the Securities and Exchange Commission, and the Department of Justice concerning crime on Wall Street- especially information concerning violations of federal securities law and federal law at the American Stock Exchange.

 

Furthermore, Plaintiff has been informed that at times Plaintiff has been under surveillance by the Federal Bureau of Investigation.  Plaintiff has also been informed that Plaintiff’s phone has been wire tapped.  It must here be noted that in 1993 Plaintiff agreed for his telephone to be tapped- but that was for a limited period of time.  But Plaintiff has been informed that his telephone has been tapped at a much more recent period.  Plaintiff shall gladly testify to this matter in an open hearing.

 

Plaintiff has provided 3 documents, which prove that Plaintiff is not lying about narcotics smuggling, money laundering and rape at the American Stock Exchange.

 

The first document is Plaintiff’s FBI wire order, which document proves that Plaintiff had been wired by the FBI.  Please note that the FBI wire order was signed by AUSA Frances Fragos (Exhibit 1).

 

The second document is an affidavit, which Plaintiff sent to President Bush.  This affidavit explicates Plaintiff’s meeting with Assistant United States Attorney Frances Fragos and FBI Special Agent Joseph Yastremski on 13 September 1993 in the Offices of the United States Attorney for the Southern District of the State of New York.  In November 2007 Frances Fragos (Townsend) resigned as President Bush’s Advisor on Homeland Security and Counter-Terrorism.  (Exhibit 2)

 

The third document is a sworn statement by Patrick Azzara, a former member of the American Stock Exchange, who met with FBI Special Agent Joseph Yastremski.  This sworn statement concerns money laundering, narcotics smuggling, stock frauds etc. at the American Stock Exchange. (Exhibit 3)

 

The fourth document is a copy of the 26 April 1999 BusinessWeek cover story, Scandal On Wall Street.  More than one page is devoted to Plaintiff and Plaintiff is termed a whistle-blower.  (Exhibit 4)

 

The fifth document consists of copies of several articles, which were authored by Plaintiff for The Black Star News.  These article, Goldman’s Obscene Bonuses, Rip-Off:  Wall Street Price Fixing, AIG and Stock Manipulation; Goldman’s Toxic CMOs, and Goldman’s CMO Liabilities prove that Plaintiff possesses intimate knowledge of illegal trading on Wall Street and is an honest man.  (Exhibit 5)

 

The sixth document is an affidavit by anonymous.  This document appears on Plaintiff’s website, www.wallstreetscandals.com.  The affiant listened to several of Plaintiff’s telephone conversations with FBI Special Agent Yastremski discuss money laundering at the American Stock Exchange.  An original copy of this affidavit was provided to Representative John Dingell.  (Exhibit 6)

 

The aforementioned documents, Exhibits 1-6, prove that Plaintiff does not lie and should provide overwhelming confidence that Plaintiff’s statements are not incredible or delusion, but are verifiable incidents and that the Federal Bureau of Investigation, Department of Justice and Securities and Exchange Commission have extensive files (i.e., notes, memoranda, records, letters, documents, etc.) which mention Plaintiff’s name.  it is these documents that Plaintiff demands.

 

Plaintiff demands that all information pertaining to Plaintiff’s consent to have his telephone tapped be provided- that means all documents, files, notes, memoranda, surveillance, etc. of Plaintiff and which documents mention Plaintiff’s name in the period from April 1993 to January 1994 be provided to Plaintiff.  Note:  Plaintiff met with FBI Agent Joseph Yastremski circa April 1993 and circa July 1993 in the FBI office at 26 Federal Plaza in New York City.  This covers the 90 day time period, September 1993 to January 1994, for which Plaintiff consented to be wired- see Plaintiff’s “FBI wire order,” (Exhibit 1) which either Judge Towns or her law clerk has stated is illegible.  (New copy of wire order has been provided.)  Hopefully Judge Townes and her law clerk are able to read the new FBI wire order- or we can subpoena a new copy of the wire order.  Note:  Judge Townes it is a crime to forge a federal document and it is a crime to commit perjury.

 

Indeed Plaintiff is totally mystified that the learned Jude Townes and her astute law clerk were unable to recognize or even read what Plaintiff has referred to as Plaintiff’s wire order.  Just read the wire order and the numbered boxes and the Xs and words in the boxes.  Plaintiff showed this wire order to some high school students at Newtown High School, and these students understood the meaning of the wire order.

1.Reason for proposed use:  box checked- Corroborate Testimony.

2.  Type of equipment:  box checked- Concealed Recorder

3.  Consenting Party:  box checked- Nonconfidential Party:  Edward Manfredonia- that is Plaintiff’s name

8.  The following requirements have been fulfilled.  All three boxes were checked.

9.  Government attorney in judicial district where intercept will take place foresees no entrapment….

Identity of Gov’t Attorney:  AUSA Frances Fragos

Southern District of New (sorry the copy is truncated)

12.  Synopsis of case:  Case involves the manipulation of the price of PNF stock on     the American Stock Exchange

 

FBI Special Agent Joseph Yastremski wired Plaintiff Manfredonia for an investigation into PNF.

 

The above explication is proof that Plaintiff is not lying.  And Plaintiff has assisted in the explanation of the document.  So, I hope that I have assisted Judge Townes in her understanding of the document.

 

In 1993 Plaintiff was wired by the FBI- specifically, FBI Special Agent Joseph Yastremski.  Yastresmski placed the recording device upon Plaintiff- attached the document to Plaintiff’s back and the microphone was attached to Plaintiff’s undershirt.  Plaintiff then entered Pappoo’s, a bar/restaurant, which at that time was located on Greenwich Street and recorded a conversation.  The wire order (Exhibit 1) was signed by AUSA Frances Fragos (box 9), who until November 2007 was President Bush’s advisor on Homeland Security and Counter-Terrorism.  This document, the FBI wire order, (Exhibit 1) was provided to Plaintiff in 1994 pursuant to a request made to the FOIPA Section of the FBI.  The request merely stated that Plaintiff wished to obtain his files and Viola! Plaintiff was eventually sent a copy of the FBI wire order, an official government document.  So, Plaintiff did request his “FBI files” in the required manner.

 

If Judge Townes or her law clerk should believe that Plaintiff has committed perjury or has presented a false or manufactured document copy of a federal document, then Judge Townes is mandated under federal law to have Plaintiff Manfredonia arrested and charged with perjury and falsifying a federal document.  Please give Plaintiff 3 days notice of his arrest so that Plaintiff can make the necessary arrangements.

 

One day Plaintiff was walking with an FBI Agent and the FBI Agent stated that he did not wish to be seen walking down the street with Plaintiff because Plaintiff had been under surveillance.  Sorry Judge, but I do not lie and, therefore, there is evidence that Plaintiff had been under surveillance by the Federal Bureau of Investigation.  So let us subpoena all records, of Plaintiff’s surveillance, all notes, memoranda, letters, etc. in which Plaintiff’s name is mentioned.

 

Furthermore, it is Plaintiff’s belief that Plaintiff has been placed under surveillance by the Federal Bureau of Investigation.  Arthur Amey, who retired as a Special Agent of the Federal Bureau of Investigation and has continued to work for the FBI as a consultant, lives in the same co-op building and on the same floor, the fourth floor, of 83-37 St. James Avenue, Elmhurst, NY 11373, as Plaintiff.  If FBI Special Agent Amey has written any reports in which Plaintiff’s name is mentioned while either employed as an FBI Special Agent or as a consultant to the FBI or Department of Justice after his retirement, Plaintiff demands those records, which Plaintiff has referred to as Plaintiff’s FBI files, i.e., any notes, memoranda, documents, surveillance records, etc. which are maintained by the FBI or its parent, the Department of Justice.

 

Plaintiff seeks all FBI records, files, transcripts, records of surveillance, etc. in which Plaintiff’s name is mentioned.

 

It is here that Plaintiff must state most assertively that Plaintiff has been informed that Arthur Levitt ordered the Securities and Exchange Commission not to utilize any information that Plaintiff provided to the SEC and to pass along this information to the American Stock Exchange.  Plaintiff must state that this information was provided to Plaintiff on 13 September 1993 in the offices of the United States Attorney for the Southern District of the State of New York by Assistant Untied States Attorney Frances Fragos, later Frances Fragos Townsend, President Bush’s advisor on Homeland Security and Counter Terrorism.  If the Court believes that Plaintiff is committing perjury, Plaintiff demands that Judge Townes have Plaintiff arrested.

 

Circa 1996 Plaintiff had a telephone conversation with an SEC staff attorney at the New York Office of the SEC, Ira Spinnler (spelling approximate). Spinnler told Plaintiff that Arthur Levitt, then Chairman of the SEC, had ordered that Plaintiff’s correspondence with the SEC be sent to Helen Moore in Washington, DC.  Plaintiff is not lying, or rather committing perjury; Spinnler had another individual listen to the conversation.  So, there are records of conversations and Arthur Levitt’s order that all Plaintiff’s letters be sent to the SEC in Washington where everything could be covered up. Thus, Plaintiff demands these SEC records, i.e. files, documents, notes, memoranda, etc. in which Plaintiff’s name is mentioned and to which Plaintiff is entitled.

 

Plaintiff demands all SEC records pertaining to Plaintiff- including all records, files. Letters, etc. where Plaintiff’s name is mentioned.

 

Plaintiff also demands all Plaintiff’s files and all records, i.e., documents, notes, memoranda, letters, etc., in which Plaintiff’s name is mentioned at the Department of Justice.  Plaintiff had extensive contact with Assistant United States Attorney Frances Fragos, whose name appears as AUSA Frances Fragos on the FBI wire order.  Plaintiff has provided a new copy of the FBI wire order, which is legible and easy to read (Exhibit 1).  This wire order was provided to Plaintiff by the FBI in 1994.  The only information, which was redacted on this government document, pertained to personal information concerning Plaintiff Manfredonia- so the FBI wire order was not altered, which would be a violation of federal law.  Plaintiff is mystified that the learned Judge Townes could not read the FBI wire order.  Whenever Plaintiff has shown the FBI wire order to an attorney in federal court, the attorney immediately knows that Plaintiff has been wired by the FBI.  So, Plaintiff is stupefied by the Judge’s inability to recognize this FBI wire order.  Plaintiff demands a new copy of the FBI wire order from the FBI in part so that Judge Townes may more easily read what Plaintiff has termed as his “FBI wire order.”

 

Plaintiff also had contact with an Investigator for the Department of Justice named Steven Beck.  It was Steven Beck, who placed a NAGRA (hopefully spelled correctly) upon Angelo Meneghello in the Department of Justice investigation into the Oakford case.

 

Plaintiff spoke to Steven Beck because Beck was investigating the money laundering by Louis Miceli and Robert VanCaneghan from the Cayman Islands for the Department of Justice.  Beck also informed Plaintiff that Beck and Joseph Yastremski had meetings in which Plaintiff was discussed. Plaintiff demands all records of these meetings. Plaintiff attempted to have FBI Special Agent and Steven Beck investigate the illegal trading of Pat Schettino, Joseph Roffler, etc. at the American Stock Exchange.  Plaintiff demands all records, i.e., all notes, memoranda, records of surveillance, documents, letters, etc. at the Department of Justice in which Plaintiff’s name appears.

 

Plaintiff also had contact with another Special FBI Agent, Michael Degnan.  FBI Special Agent Michael Degnan was investigating the American Stock Exchange stock fraud, PNF, with FBI Special Agent Joseph Yastremski.

 

Plaintiff Manfredonia gained access to the FBI because Plaintiff Manfredonia knew FBI Special Agent Andre Cicero, when Cicero represented the clearing firm, Janney Montgomery, on the floor of the American Stock Exchange and Plaintiff was a member of the American Stock Exchange.

 

FBI Special Agent Joseph Yastremski informed Plaintiff that he (Yastremski) had attended Columbia University and had been employed by Salomon Brothers in he 1980sin the mortgage backed securities department.

 

On several occasions Plaintiff received telephone calls from FBI Special Agent Joseph Yastremski at Plaintiff’s home telephone:  718 457 8135. There are records, notes, memoranda, etc. of Yastremski’s telephone calls to Plaintiff.  Yastremski’s telephone calls to Plaintiff dealt with narcotics smuggling by Louis Miceli; money laundering by Louis Miceli and Robert VanCaneghan; Al Avasso’s Mafia payments to Steven Lister, Senior Vice President of Compliance at the American Stock Exchange; etc.  Plaintiff demands all FBI files, i.e., records, notes, memoranda, documents, letters, etc. in which Plaintiff’s name is mentioned.

 

Judge Townes Plaintiff would like to state that the FBI does not publish the names of FBI Agents, so Plaintiff had to personally know the FBI Agents, Investigators for the Department of Justice, and Securities and Exchange staff attorneys.

 

It is here that Plaintiff wishes to state one important fact.  Plaintiff had made it known to members of the Board of the American Stock Exchange that Plaintiff was not interested in money.  Plaintiff desired that Robert VanCaneghan and Louis Miceli be removed from the Board; that Robert VanCaneghan receive psychiatric treatment; that the victims of VanCaneghan’s depredations be compensated.

 

Judge Townes you are mandated by federal law to have Plaintiff charged with perjury if you believe that Plaintiff has committed perjury.  You must have Plaintiff arrested if you believe that Plaintiff has perjured himself.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

III   STATEMENT OF CLAIM

 

In this section of Plaintiff’s complaint, Plaintiff shall take issue with several major fallacious analyses of Plaintiff’s original complaint by the learned Judge Townes and her learned law clerk.  Plaintiff has affixed Plaintiff’s original complaint as Exhibit 7.

 

But first it is readily apparent that Judge Townes or her law clerk has willfully delayed providing Plaintiff with a copy of Judge Townes’ Memorandum and Order.  Although Judge Townes’ Memorandum and Order was dated June 24, 2008, Judge Townes did not provide a copy of her Memorandum and Order to the Court Clerk’s Office until June 30, 2008.

 

At this juncture of the complaint, Plaintiff wishes to take issue with Judge Townes, characterization of “real or imagined” encounters, which Judge Townes lists on page 2 of her Memorandum and Order.  It is transparently obvious that Judge Townes, a federal judge who has tried both criminal and civil cases, affects a belief that Wall Street is an environment inhabited by men of the Mary Poppins variety- whose main duty is to perform philanthropic acts and not to make money- ruthlessly.

 

Plaintiff also wishes to express outrage with Judge Townes’ mistaken belief that Wall Street is like the Tooth Fairy, which version is stated on Page 6 of Judge Townes’ Memorandum and Order.

 

Thus, Judge Townes states on page 6:

“In the instant complaint, plaintiff’s allegations regarding wrongdoing on Wall Street in the 1990’s, is frivolous because the allegations are incredible.”

“To the extent that plaintiff seeks to have this Court instigate an investigation into alleged criminal activity that occurred on Wall Street during the 1990’s, his complaint is dismissed as frivolous as the facts he alleges are wholly incredible.”

 

Sorry Judge Townes and her law clerk, but Plaintiff has stated the truth.  Let the legal action proceed and Plaintiff shall prove that you are wrong.  If Judge Townes believes that Plaintiff has committed perjury, Judge Townes has no recourse but to have Plaintiff arrested for perjury.

 

Judge Denny Chin of the Southern District of the State of New York knows that the government plays fast and loose with indictments and favors the rich and powerful.  Thus, Judge Chin dismissed the charges against Brian Finnerty in the NYSE specialists’ case because the government did not indict Finnerty’s superiors, who had earned even more money than Finnerty from this illegal trading.

 

And please Judge Townes, you have insulted Plaintiff. Plaintiff knows that a federal judge cannot instigate or initiate an investigation- and nowhere in Plaintiff’s complaint did Plaintiff request such an investigation.

 

Plaintiff strongly suggests that Judge Townes read John Crudele’s columns, the latest being written on 11 July 2008, concerning the cover by Eliot Spitzer and the Department of Justice concerning the involvement of Richard Grasso in the illegal trading of Oakford Corp.- and Plaintiff’s proof that Grasso covered up the illegal trading of William Johnston, President of the NYSE- and a personal friend of Grasso.

 

Plaintiff shall briefly refute the willful misstatements of Judge Townes, which appear on page 2 of the Memorandum and Order.  Plaintiff shall then prove that Judge Townes has no idea of the reality of Wall Street.  Or perhaps Judge Townes truly understands Wall Street, but does not wish the confluence of the federal government and its acceptance of criminal activity on Wall Street to be exposed.

 

Judge Townes’ first example involves solicitation of Plaintiff’s murder.  In March 1996 Steve Peter, then a member of the American Stock Exchange, sought to enlist the assistance of Edwin Crooks, the most powerful member of the Board of the American Stock Exchange, to influence an arbitration case in an amount exceeding $20,000 between Margot Reilly (later Mrs. Peter) and Nino Armenti.  To accomplish this Peter met with Edwin Crooks at Michael’s Restaurant, which was situated on Trinity Place.

 

Edwin Crooks assented to fix the arbitration complaint if Steve Peter would murder Plaintiff.  Crooks also offered to make Steve Peter a member of the Amex Board; to obtain a small specialist unit for Steve Peter; and, to arrange a joint book operation for financing.  The source of this information: Steve Peter.  Peter told Plaintiff that Crooks hated Plaintiff because in 1985 and 1990 Plaintiff had reported Crooks for trading on inside information concerning the movement of the XMI, a stock index- information that Edwin Crooks had received from his cousin, Donald Crooks, at Morgan Stanley.  In April 1985 Ed Crooks told Plaintiff about the insider trading and even displayed a ticket to purchase puts in the XMI.  There are more details, but Plaintiff shall gladly address them in open court.  These were discussed in the original complaint (Exhibit 7 of this complaint) and in a letter, dated 30 December 1999, addressed to Inspector O’Hare (Exhibit 8).  In 2000 Inspector O’Hare was removed from his position as Commander of the Wall Street Substation for having Plaintiff illegally followed by the NYPD.  Glad to discuss this in open court- and Plaintiff has enclosed Plaintiff’s letter to Inspector O’Hare as Exhibit 7.   Believe that Plaintiff is lying, then Plaintiff must be arrested for perjury.

 

Approximately two weeks before his murder or suicide, Edwin Crooks approached Plaintiff.  Crooks apologized to Plaintiff for attempting to have Plaintiff murdered.  Crooks also apologized for covering up the rapes that had been perpetrated by Robert VanCaneghan.

 

Judge Townes’ second example involves someone posing as Assistant Attorney General Joanne Harris.  As stated in the original complaint, Plaintiff had addressed three letters to Joanne Harris, (13 June 1994, certified mail Z 282 188 889; 14 June 1994, certified mail Z 282 188 892; and, 7 August 1994, Z 306 464 541).  Assistant Attorney General Joanne Harris was in charge of the Criminal Division of the Justice Department.  Plaintiff wrote to Harris concerning the sexual assaults/rapes to which Robert VanCaneghan, a member of the Board of the Amex, had admitted.  Plaintiff had written to Assistant Attorney General Joanne Harris and had requested that the Department of Justice and the FBI investigate the rapes that had been perpetrated by Robert VanCaneghan and to which rapes Robert VanCaneghan had admitted in a confession to members of the Board of the American Stock Exchange.

 

On 6 July 1994, Plaintiff received a message on his telephone answering machine, purportedly from Joanne Harris.  In this message the individual posing as Harris stated that FBI Special Agent Joseph Yastremski was investigating the sexual assault/rapes, to which Robert VanCaneghan had admitted to the Amex Board.  Note:  Plaintiff was informed of VanCaneghan’s admission that he had sexually assaulted/raped his female employees by Denis Goin, at that time a member of the Board.  Plaintiff was also informed that Lewis Lowenfells resigned from the Amex Board in protest of the cover up.  Believe Plaintiff is lying, then have Plaintiff arrested for perjury.

 

The above incident involving Assistant Attorney General Harris is the reason that Plaintiff demands access to his Department of Justice files, i.e., all notes memoranda, letters, documents, records of surveillance, etc. and to all documents in which Plaintiff’s name appears.  These files shall show, who had access to Plaintiff’s letters and Plaintiff’s files.

 

Several weeks later Plaintiff contacted FBI Special Agent Joseph Yastremski concerning this purported message from Harris.  Yastremski stated that he was not investigating the rapes to which Robert VanCaneghan had admitted.  On the last page of Scandal On Wall Street, Gary Weiss stated:  “He learned that employees of a specialist firm, run by a highly placed figure at the exchange, had allegedly been sexually assaulted by the official.”       So someone at the Department of Justice or the FBI knew of Plaintiff’s letters and interfered with a federal investigation.

 

Judge Townes’ third example involves money laundering, narcotics smuggling, etc., Plaintiff was informed of these crimes by FBI Agent Yastremski. Plaintiff knew of these crimes, but did not report these crimes to Yastremski because Plaintiff knew that these crimes were unbelievable and that Yastremski eventually would uncover the money laundering and narcotics smuggling.  Yastremski asked Plaintiff for his assistance in investigating money laundering by Louis Miceli and Robert VanCaneghan via their eponymous broker dealer, Miceli-VanCaneghan.  The money came from the Cayman Islands.  If Judge Townes had read the affidavit of anonymous, (Exhibit 6 of this complaint), Judge Townes would have seen collaboration for the money laundering.  Also Plaintiff in open court shall gladly explain the money laundering.  As for the narcotics smuggling, Plaintiff was informed of the narcotics smuggling by FBI Agent Yastremski during a telephone call and Plaintiff’s assistance was requested.  Note:  A copy of the original affidavit was sent to Representative John Dingell.

 

Most importantly Plaintiff Manfredonia has provided a copy of a sworn statement by Patrick Azzara (Exhibit 3).  This sworn statement proves that FBI Special Agent Joseph Yastremski was investigating money laundering, narcotics smuggling, payoffs by Al Avasso to Amex officials, etc. at the American Stock Exchange.  Please note that Azzara has sworn that FBI Special Agent Joseph Yastremski was investigating money laundering by Robert VanCaneghan and Louis Miceli, and drug smuggling by Louis Miceli.

 

It is precisely these files, that contain Plaintiff’s name and information, which files Plaintiff is demanding from the FBI because Plaintiff assisted the FBI and provided information.

 

But Judge Townes is totally devoid of any reality when she describes as incredible Plaintiff’s statement of facts and makes reference to a court decision, which uses the term “delusion” to describe Plaintiff’s facts.  Sorry, Judge but here is a real life example of life on Wall Street- and it shall be brief.  But Plaintiff shall gladly discuss this matter in open court.  But now Plaintiff shall provide an example of a threat that is in the FBI files- and another reason why Plaintiff seeks his FBI files, which the FBI has refused to grant to Plaintiff.

 

On 3 December 1993 Plaintiff was threatened with murder by Alan Umbria, a member of the American Stock Exchange.  Umbria was employed by Carl Icahn.  Umbria credited his employment with Icahn as a favor Icahn made to a Mafia-controlled pension fund for financing years ago.  Plaintiff immediately reported this death threat to FBI Special Agent Joseph Yastremski and to AUSA Frances Fragos.  Plaintiff also delivered a letter, dated 3 December 1993, which described this incident, personally to the FBI.  It was a copy of this letter, which James Kallstrom, Assistant Director of the FBI gave to the American Stock Exchange.  A copy of this letter was in the possession of Louis Miceli on the day that Miceli was forced to leave the Amex.  On this date, Miceli met with members of the Italian Mafia at Umbria’s Mafia controlled restaurant, The Court of the Three Sisters.  Check it out in Plaintiff’s FBI files.

 

As a result of Umbria’s death threat, AUSA Frances Fragos ordered FBI Special Agent to go to the Amex and pick up Umbria for threatening Plaintiff.  Yastremski did this and told Umbria that he would be arrested if he (Umbria) were to threaten Plaintiff’s life on another occasion.

 

The above incident is described in the notes and records of FBI Special Agent Yastremski and Assistant United States Attorney Frances Fragos.  These notes are proof of the veracity of Plaintiff’s statements.  Plaintiff’s demands all notes, memoranda, letters, records, etc., which discuss Umbria’s death threat to Plaintiff; Yastremski warning to Umbria; Fragos’ order authorizing Yastremski to pick up Umbria, etc. which records, files, notes, memoranda, documents, etc. are in the possession of the Department of Justice and the Federal Bureau of Investigation.

 

Once again Plaintiff must stress that if Judge Townes believes that Plaintiff has committed perjury, Judge Townes must have Plaintiff arrested and charged with perjury.  Then Plaintiff shall obtain his “FBI files.”  Incidentally, Plaintiff finds it strange that Judge Townes does not understand the meaning of the term, “FBI files,” but the FBI certainly does.

 

Plaintiff finds it incredible that a federal judge should be a follower of the Mary Poppins school of Wall Street and believe, especially after the CMO crisis, that the federal government does not cover up crime on Wall Street.  Furthermore, contrary to the delusional view of the Mary Poppins school of thought, Plaintiff has proved throughout his original complaint, Exhibit 7, proof that the federal government has covered up hellacious crime on Wall Street.  Judge Townes can read the original complaint and then can compare the disciplinary actions undertaken by the Amex and the SEC with Plaintiff’s letters, which have reported these same violations of federal security laws.  And then Judge Townes can read several of Plaintiff’s articles in which Plaintiff explains his letters and elucidates the violations of federal securities laws.

 

Sorry Judge Townes, but Wall Street is not exactly Willy Wonka and the Chocolate factory for the American public.  But you know that and do not wish Plaintiff to obtain his FBI files.

 

A book about Wall Street does not begin:  “And the men and women of Wall Street were so altruistic that rather than make money on increasing the price of rice, wheat and corn so that children could be healthy ….”  That is the Mary Poppins view of Wall Street.

 

It is here that Plaintiff would like to discuss “the FBI wire order,” (Exhibit 2).  Plaintiff received this document in 1994 in response to a request to the FBI.  The learned Judge Townes has stated that this document is “an altered and indecipherable document.”  The only alteration made was to delete some personal information concerning Plaintiff.  As for the document being indecipherable, Plaintiff wishes to state that whenever Plaintiff has shown that document to an attorney in federal court, the attorney immediately recognizes the document as authorizing a wire order.  So, Plaintiff has joyously provided another copy of the document (Exhibit 1).  By the way it is a violation of federal law to forge a federal document.  So Judge Townes you could have Plaintiff arrested for forging an official document or a federal document and for committing perjury.  Then the federal court can assign an attorney to represent Plaintiff.  Perhaps this is the best alternative.  Plaintiff shall be glad to discuss this in open court- and on the record.

 

In her Memorandum and Order Judge Townes abruptly dismissed Plaintiff’s affidavit to President Bush (Original complaint, Exhibit 2, this complaint Exhibit 2).  Judge dismissed this affidavit, which described Plaintiff’s meeting with AUSA Frances Fragos (Townsend).  It would be very easy to verify this meeting and the discussion, which took place.  Plaintiff was required to sign in at the office of the United States Attorney for the Southern District.  AUSA Frances Fragos asked Plaintiff what Greenwald told Plaintiff about Motel 6.  Plaintiff responded that it was either “Buy it. It’s guaranteed,” or “It’s guaranteed. Buy it.”  AUSA Frances Fragos stated that she knew that Plaintiff had not traded Motel 6 on the basis of inside information.  As a matter of fact, FBI Special Agent Joseph Yastremski verified that Plaintiff had represented Frost & Sullivan on the floor of the Amex.  Plaintiff executed option orders, always to purchase call options, for Frost & Sullivan and provided advice in trading options.

 

Plaintiff even explained to FBI Special Agent Joseph Yastremski that Plaintiff had asked for markets in options in Square D- five hundred lots at a time- prices began at 1 11/16 for 500 option calendar spreads, 1 ¾ for the next 500, and so forth.  There are records of this at the Securities and Exchange Commission, the Department of Justice, and the Federal Bureau of Investigation.  These records shall prove that Plaintiff provided excellent information concerning illegal trading in Motel 6.  Plaintiff shall explain this in greater detail in Court.  Plaintiff demands these notes, memoranda, documents, letters, etc. which are in the exclusive possession of the Securities and Exchange Commission, Department of Justice and the Federal Bureau of Investigation, which notes, memoranda, files, documents, letters, etc., which pertain to Motel and mentions Plaintiff’s name or allude to Plaintiff.

 

One more incident shall suffice to prove that members of the American Stock Exchange do not sit around and recite:  “Little Bo Peep has lost her sheep….”

 

Richard Mondarine (Monderine) was at one time in charge of floor operations at the Amex.  Under threat of dismissal and also of not receiving earned promotions, Mondarine forced young African-American single mothers to perform fellatio upon him in order to maintain employment at the Amex. In 1987 Plaintiff reported Mondarine.  Mondarine was not fired.  The Amex members were in an uproar.  But when Plaintiff was threatened, Plaintiff simply stated that he could beat them and the threats upon Plaintiff stopped.  For a while the sex slavery of performing fellatio stopped.  It was only after Plaintiff was forced from the floor that Mondarine continued his sexual slavery.  But Judge Townes is a federal judge with lifetime tenure- so the degradation of minority women does not matter to her.

 

Nor obviously do the horrors of 70 million Filipinos possess any meaning to Judge Townes.  As Plaintiff stated in his original complaint, Plaintiff’s business associate, Heinz Grein, Chairman of Frost & Sullivan and a former currency trader for a German Bank, laundered money for the Italian Mafia (Al Avasso) into Luxembourg Banks and the $10 billion, which sum Ferdinand Marcos looted from the Philippines into Swiss Banks.  Heinz Grein pleaded guilty to masterminding the Motel 6 insider trading scandal and the FBI knew that he had laundered money- due to Plaintiff’s information.  Plaintiff demands all information concerning the location of Marcos’ billions, which is in the possession of the Department of Justice and the Federal Bureau of Investigation.

 

It must here be noted that Plaintiff was the only individual associated with Frost & Sullivan and several other firms, who both possessed inside information on Motel 6 and did not trade on the basis of inside information.  AUSA Frances Fragos stated that she knew that Plaintiff had not traded on the basis of inside information.  AUSA Frances Fragos stated that she knew that Plaintiff had not traded on the basis of inside information.  AUSA Frances Fragos stated that Joseph Greenwald, who pleaded guilty to trading Motel 6 on the basis of inside information, had provided Plaintiff with inside information on Motel 6.  This information concerning Motel 6 and Grein’s laundering of money for Al Avasso and Ferdinand Marcos can be found in the notes, memoranda, documents, letters, etc. of the Federal Bureau of Investigation, Department of Justice, and the Securities and Exchange Commission.  (See BusinessWeek article, The System Was Perfect, 10 August 1992 (Exhibit 9).  Plaintiff has enclosed a copy of his American Stock Exchange identification card, which proves that Plaintiff had represented Frost & Sullivan on the floor of the American Stock Exchange.  Please note that Heinz Grein’s business card has Grein’s 1989 home telephone number.

 

Furthermore, Plaintiff Manfredonia provided names of other individuals, who traded Motel 6 on the basis of inside information- most notably Gary Rosen, who boasted of having earned more money trading on inside information than Jeff Green, who was prosecuted for trading on the basis of inside information.

 

And here is a bonus for Judge Townes. Plaintiff Manfredonia provided FBI Special Agent Joseph Yastremski with information that Michael Borlinghaus, a principal in Frost & Sullivan, had another firm, to which he provided inside information on Motel 6 and other issues, and which firm had traded on the basis of this inside information.  The FBI did not know this until Plaintiff informed the FBI..  Borlinghaus served a prison term for not providing this information to the FBI.  If Judge Townes does not believe Plaintiff, eh Court can either subpoena the relevant notes, documents, files, letters, etc. which are in the exclusive control of the Federal Bureau of Investigation, the Department of Justice, and the Securities and Exchange Commission.  Plaintiff Manfredonia demands the aforementioned notes, memoranda, letters, documents, etc., i.e., everything that mentions Plaintiff’s name pertaining to insider trading in Motel 6 that is in the possession of the Department of Justice, the Federal Bureau of Investigation and the Securities and Exchange Commission.

 

This fact can be easily verified by records at the Department of Justice, Federal Bureau of Investigation and Securities and Exchange Commission, which detail Plaintiff’s involvement with the firm of Frost & Sullivan and the fact that Plaintiff did not trade on the basis of inside information. Plaintiff demands these records from the Department of Justice, Federal Bureau of Investigation and Securities and Exchange Commission.

 

Judge Townes is aware from reading Plaintiff’s original complaint (Exhibit 7) that Richard Syron, former Chairman of the American Stock Exchange, former Chairman of Thermo Electron and currently Chairman of Freddie Mac, was involved in stock manipulation and illegal trading.  Furthermore, Judge Townes knows that Syron had been institutionalized.  Plaintiff wishes to assure the Court that Judge Townes would never write about Syron, a certified lunatic and stock price manipulator in the same manner in which Judge Townes has degraded Plaintiff.  Why?  Because Plaintiff has no money and is self-represented.  Syron, who did not work for more than one year because of mental health issues, is one of the individuals most responsible for the housing and CMO mess, yet Judge Townes would treat Richard Syron with respect.  Plaintiff reported illegal trading in subsidiaries of Thermo Electron to the SEC as early as 1996- yet it was only in 2006 that the Amex disciplined Ron Menello and Al Merendino for price manipulation of Thermo Electron subsidiaries.  Syron was actively involved in covering up the civil and criminal violations of federal securities laws, which were highlighted in the article, Scandal On Wall Street.  Furthermore, Syron was actively involved in the price manipulation of the subsidiaries of Thermo Electron, so that his good friend, John Hatsopoulos, could benefit at thee expense of the shareholders of Thermo Electron when the stocks of the subsidiaries were purchased by Thermo Electron.  Currently, Syron more than any other individual is responsible for the collapse of Freddie Mac.  Plaintiff demands his records at the SEC to know why Plaintiff was ignored.

 

It is also apparent that Judge Townes has willfully mischaracterized much of Plaintiff’s original complaint.  Plaintiff illustrated his original complaint with much detail concerning many violations of federal securities law that the Department of Justice, the Securities and Exchange Commission, and the Federal Bureau of Investigation have refused to investigate.

 

Surely, Judge Townes recalls the stock fraud, Crazy Eddie.  So Plaintiff shall only repeat the part of the original complaint that deals with Plaintiff’s letter of 9 April 2007, which letter stated that Crazy Eddie was illegally laundering money into the United States.  Please note the date.  2007 was last year; not ten years ago.

 

On 9 April 2007 Plaintiff wrote a letter, certified mail 7005 1820 0004 1210 8872, to Christopher Cox, Chairman of the Securities and Exchange Commission concerning Eddie Antar’s illegal tens of millions of dollars.

 

“The following information came to me from several members of an orthodox synagogue, which is situated on Ocean Parkway in Brooklyn, New York.

 

“Sam Antar, Eddie Antar, and other individuals involved in the scam of Crazy Eddie were members of this synagogue.

 

“In September 2005 I met a cousin of Eddie Antar.  This cousin informed me that Crazy Eddie was sending money via an Israeli Bank to his relatives. He told me that Eddie Antar had sent $20,000 to pay for his niece’s bat mitzvah.  If my memory is correct, it was for the daughter of Eddie’s sister.

 

“This individual and other members of the synagogue, whom I knew, told me that members of Crazy Eddie’s orthodox Sephardic synagogue, had been informed by the Antars (Crazy Eddie, his father, Sam Antar) that Crazy Eddie was a fraud.  These individuals then shorted the stock of Crazy Eddie- and made millions.  Also, the Antars contributed millions of dollars to their synagogue.

 

“Members of the synagogue also told me that Eddie Antar had shorted the stock in offshore accounts and that Eddie Antar had made tens of millions of dollars shorting the stock- and that the SEC was unaware of this.”

 

Plaintiff also reported that Eddie Antar had illegally kept tens of millions of dollars that Eddie had illegally earned in the stock fraud, Crazy Eddie, to the Department of Justice, the Federal Bureau of Investigation, and to the Securities and Exchange Commission- pages 63-65 of Plaintiff’s original complaint (Exhibit 7).

 

Eddie Antar owes hundreds of millions of dollars to the SEC and the American public.  The federal government has refused to follow Plaintiff’s leads- because the federal government has been covering up crimes that Plaintiff reported.

 

Plaintiff wishes to take issue with a misstatement in Judge Townes’ decision.  Plaintiff never requested a Bivens action.  Plaintiff never suggested that he would sue any individual, who was an employee of the federal government.  So it is an utter falsehood to state this,

 

Judge Townes also falsely states on page 5 of her Memorandum and Order:  “The Complaint does not provide the Court with notice of what claim or claims he seeks to make, and does not provide defendants with the information necessary for them to respond.”  That is simply not true.  In the section, REMEDY SOUGHT of Plaintiff’s original complaint (Exhibit 7), Plaintiff has written:

 

“IV:  REMEDY SOUGHT

Plaintiff Edward Manfredonia is entitled to his FBI files, his Department of Justice files, and his Securities and Exchange Commission files- and all material requested in this Complaint.

The Freedom of Information Act requires that the FBI, DOJ, and SEC provide Plaintiff Manfredonia with all information.”

 

That should be sufficient notice of remedy sought.

 

Judge Townes, if you believe that Plaintiff Manfredonia is dissembling, Plaintiff Manfredonia should be arrested and charged with perjury.  And then the Court can provide Plaintiff with an attorney, who shall properly submit court papers for Plaintiff’s files at the Department of Justice, Federal Bureau of Investigation, and Securities and Exchange Commission.  There is nothing to be gained by defaming Plaintiff, although Plaintiff knows that a Judge cannot be charged with defamation for official pronouncements.  Charge Plaintiff with perjury and let the Courts determine the veracity of Plaintiff’s claims.

 

 

FREEDOM OF INFORMATION ACT REQUEST- DEPRTMENT OF JUSTICE

 

Plaintiff Edward Manfredonia also followed the proper procedure in requesting Plaintiff’s records from the Department of Justice.

 

On 3 May 1994 Plaintiff Manfredonia sent a registered letter to Mr. Benjamin Burrell, Director, Justice Management Division of the Department of Justice.  Plaintiff requested his records thus:  “I wish to have access to my records.”  (Exhibit 10)

 

Plaintiff never received a response from the Department of Justice.  The Department of Justice never granted Plaintiff access to his records, i.e., all files, documents, notes, memoranda, records of surveillance, etc. which Plaintiff had requested.

 

It is here that Plaintiff must once again discuss his 13 September 1993 meeting with AUSA Frances Fragos in the offices of the United States Attorney for the Southern District of the State of New York.  As Plaintiff had previously stated there were three participants in this meeting:  Plaintiff Edward Manfredonia, Assistant United States Attorney Frances Fragos, and Federal Bureau of Investigation Special Agent Joseph Yastremski.  Plaintiff’s affidavit to President Bush, Exhibit 2, explicates this 13 September 1993 meeting.  Plaintiff demands all notes, memoranda, letters, documents, etc. which pertain to this meeting and all documents of this meeting which describe the money laundering, narcotics smuggling, payoffs to Amex officials, etc. that were discussed at this meeting.

 

Plaintiff also demands all notes, memoranda, documents, letters, etc. which pertain to the confrontation between Alan Umbria, a front for the Italian Mafia at the AMEX, and FBI Special Agent Joseph Yastremski- and the approval of AUSA Frances Fragos for FBI Special Agent Joseph Yastremski to pickup Alan Umbria.

 

As Plaintiff has stated AUSA Frances Fragos believed Plaintiff Manfredonia- and this belief was stated after FBI Special Agent Joseph Yastremski had totally vetted Plaintiff Manfredonia and Plaintiff’s information.

 

It is not that Judge Townes and her law clerk do not believe that Plaintiff met with AUSA Frances Fragos and FBI Special Agent Joseph Yastremski, it is that Judge Townes is an advocate of covering up malfeasance and criminal activity of the Department of Justice and the FBI.  After all, AUSA Frances Fragos believed Plaintiff about the serial rapes that had been perpetrated by Robert VanCaneghan.  And one more caveat.  AUSA Frances Fragos told Plaintiff that Mary Jo White, United States Attorney for the Southern District of the State of New York, had to go to Washington personally in order to obtain approval to investigate the American Stock Exchange because of the influence of Arthur Levitt, then Chairman of the Securities and Exchange Commission.  Plaintiff was led to believe that Janet Reno, United States Attorney General, was involved in the decision to investigate the American Stock Exchange.

 

On 9 April 2001 Plaintiff met with two representatives of the Anti-Trust Division of the Department of Justice, Hayes Gorey and George Baranko, in the 40 Exchange Place offices of Bill T. Singer.  Plaintiff Manfredonia proved in a five and a half hour discussion, replete with blackboard demonstration, that the prices of the Exchange Traded Funds, which were traded at the American Stock Exchange, were price-fixed to the amount of $350 million per annum.

 

Several weeks later, Bill T. Singer contacted Plaintiff Manfredonia.  Singer stated that he had been informed by Baranko and Gorey that Baranko had been told that they could not utilize any information that Plaintiff Manfredonia had provided.  Gorey and Baranko were told that if their investigation were the result of information, which Plaintiff Edward Manfredonia had provided. The investigation must be dropped.  Plaintiff demands to know why Plaintiff’s information could not be utilized.  Plaintiff seeks all records, documents, files, notes, memoranda, etc. of this meeting and all records, notes, memoranda, documents, etc. at the Department of Justice in which Plaintiff’s name is mentioned.

 

Bill T, Singer stated that Baranko and Gorey had informed him that Arthur Levitt had utilized his influence to smear Plaintiff Manfredonia.  It must here be noted that Plaintiff Manfredonia had agreed to assist Bill T. Singer in a class action lawsuit, which would involve the Exchange Traded Funds, if Singer would sue for Plaintiff’s FBI, SEC and DOJ files.  Singer reneged and his planned lawsuit collapsed.

 

It was Singer, who told Plaintiff that there was a directive that forbade the Securities and Exchange Commission and the Department of Justice from utilizing Plaintiff’s information.  Plaintiff demands a copy of this document.

 

Plaintiff seeks all notes, memoranda, documents, files, records, records of surveillance, which not only pertain to Plaintiff’s meeting with Hayes Gorey and George Baranko but also all notes, memoranda, of Plaintiff’s meeting with AUSA Frances Fragos; all records of telephone conversations with AUSA Frances Fragos; all documents, files, records, memoranda, etc.- everything which mentions Plaintiff’s name.

 

Plaintiff had written letters to the Department of Justice.  Plaintiff also spoke to Steven Beck, an Investigator for the Department of Justice, several times on the telephone.  Plaintiff demands all records, notes, memoranda, etc. which pertain to Plaintiff and in which Plaintiff’s name is mentioned. This is especially true of Plaintiff’s telephone conversations with Steven Beck.

 

I cannot fathom how Judge Townes cannot believe me.  My documentation is extensive.

 

SECURITIES AND EXCHANGE COMMISSION FREEDOM OF INFORMATION ACT REQUESTS

 

In this section Plaintiff shall prove that on numerous occasions Plaintiff has faithfully and properly requested his “SEC files,” that is, all letters, records, files, notes, memoranda, etc., which documents mention Plaintiff’s name or allude to Plaintiff via a pseudonym.

 

Plaintiff had written to the Securities and Exchange Commission on other occasions and has requested to view his records.  On 6 July 1993 Plaintiff Manfredonia wrote to Arthur Levitt, Chairman of the Securities and Exchange Commission, to “view my dossier.”  On 10 January 1993 Plaintiff Edward Manfredonia wrote to William McLucas, Director, and requested: “Would you please reply to my request to vie my files at the SEC?”

 

On 17 February 1993 Plaintiff wrote to Ms. Hanna Hall, FOIA/Privacy Act Branch Chief at SEC headquarters and requested his files.  (Exhibit 11)

 

On 24 January 1993 Plaintiff wrote to Arthur Levitt and requested that the SEC:  “order the American Stock Exchange to grant me access to my records.”

 

On 27 July 1993 Plaintiff wrote to Arthur Levitt and requested that the SEC:  “order the American Stock Exchange to grant me access to my files.” Incidentally, Judge I wrote to the head of the SEC.

 

On 23 August 1993 Plaintiff Manfredonia received a response from the SEC from Gay La D. Sessoms and was told that the Securities and Exchange Commission could not order the American Stock Exchange to grant Plaintiff access to his records.  When Plaintiff Manfredonia met with Assistant United States Attorney Frances Fragos on 13 September 1993, AUSA Frances Fragos told Plaintiff that this was a lie.

 

Plaintiff Manfredonia shall now quote from the letter, dated August 27, 1993, which letter Gayla D. Sessoms sent to Plaintiff.

 

“Your letters dated July 26 and July 27, 1993 addressed to Marcy Schapiro, Acting Chairman and William McLucas, Director of Enforcement, respectively were referred to this office for a response.  You requested the Commission to direct the American Stock Exchange (“AMEX”) to permit you access to your files under the Commission’s rules and regulations.

 

“The AMEX is a self-regulatory organization subject to the Commission’s oversight under the Securities Exchange Act of 1934.  However, the Commission does not have the authority to compel the AMEX to produce your records to you.  Therefore, you may wish to consult an attorney to discuss any legal alternatives for securing copies of your records directly from the AMEX.”

 

Now this Court and every first year law student know that Sessoms lied- and Sessoms lied with the approval of Mary Schapiro and William McLucas. But who told Sessoms to lie?

 

Plaintiff shall uncover this whey Plaintiff obtains his files from the Securities and Exchange Commission.  By “SEC files” Plaintiff means all records, letters, documents, and notes, memoranda, etc. in which Plaintiff’s name is mentioned or in which Plaintiff is refereed to by a pseudonym or alias.

 

Incidentally, if Judge Townes or her “hubris-confident” law clerk believes that Plaintiff has committed perjury, the Court can subpoena former Securities and Exchange Commissioner Cynthia Glassman and inquire why when she recommended the investigations of Plaintiff’s allegations; Commissioner Cox vetoed them and ordered a cover up.

 

Please remember that it was AUSA Frances Fragos, who in 1993 told Plaintiff that the SEC would not investigate any charges of violations of federal securities laws, which Plaintiff had made.  AUSA Frances Fragos stated that Arthur Levitt had ordered a cover up.  So, Judge Townes and her law clerk can read Plaintiff’s affidavit to President Bush.

 

In 2002 Plaintiff asked an attorney, Michael Bressler, to obtain his files at the Securities and Exchange Commission.  Michael Bressler wrote a letter to the Securities and Exchange Commission.  This letter requested Plaintiff’s records (Exhibit 11).  It must here be noted that Michael Bressler informed Plaintiff that if the SEC had not responded to Plaintiff’s previous requests for his SEC files, a lawsuit could be initiated by Plaintiff against the SEC. In 2002 Plaintiff provided Bressler with a copy of a letter to the SEC and a letter of authorization.  Plaintiff has attached as Exhibit 11, Bressler’s letter to the SEC, which letter requested Plaintiff Manfredonia’s files.  Note:  Michael Bressler was disbarred in 2004 and the letters, which Plaintiff had received from the SEC, were lost with Plaintiff’s records that were held by Bressler.  The SEC, however, does possess copies of all letters, which were sent to Plaintiff.  Plaintiff seeks copies of this correspondence.

 

Please note that although the letter names Plaintiff as Edward A. Manfredonia, all documents that were sent with this letter, including copies of Plaintiff’s previous requests and Plaintiff’s Certificate of Identity, identified Plaintiff as Edward Manfredonia, a former member of the American Stock Exchange.  Please note that Plaintiff Edward Manfredonia had been a member of the American Stock Exchange, so the SEC had a file or dossier on Plaintiff and was duty bound to provide copies of all information concerning Plaintiff to Plaintiff.

 

If Judge Townes does not believe Plaintiff, Judge Townes must have Plaintiff arrested and charged with perjury.  Then Plaintiff shall obtain his SEC files, i.e., all records, notes, memoranda, documents, etc., as the FBI stated.  The only way that Plaintiff shall obtain his SEC files is if Plaintiff is arrested on a federal charge.  So, let us begin the process.

 

 

 

FREEDOM OF INFORMATION REQUEST- FEDERAL BUREAU OF INVESTIGATION

 

Judge Townes in her Memorandum and Order has stated that Plaintiff Manfredonia was required to follow the proper procedure in requesting his FBI files, by which Plaintiff meant any documents, i.e., files, notes, records, memoranda, letters, records of surveillance, etc. which mentioned Plaintiff’s name.  So, it is here that Plaintiff must asseverate most forcefully that Plaintiff followed the proper procedures.

 

Circa 1994 Plaintiff requested his FBI files.  Plaintiff receive din the mail the document, which Plaintiff has referred to as “Plaintiff’s FBI wire order.” Plaintiff’s receipt of this document proves that Plaintiff not only wore a wire for the FBI, but that Plaintiff had properly requested his “FBI files,” which incidentally Judge Townes should be the proper way of requesting Plaintiff’s SEC files and Department of Justice files.  There cannot be a different wording for requesting files for each branch of the government.  Not only that but Plaintiff had properly requested “his FBI files” from the proper section, the FOIAPA Section.  So, Judge Townes it appears that Plaintiff has followed proper procedures.  For your information, if Plaintiff’s memory is correct, FBI Special Agent Joseph Yastremski was in the C2 Section.

 

And Judge Townes, please do not belittle the sworn statement of Patrick Azzara, which discusses his meeting with FBI Special Agent Joseph Yastremski and which sworn statement confirms Plaintiff’s charges of narcotics smuggling, money laundering, bribery, etc. at the American Stock Exchange.

 

Plaintiff shall provide samples of letters, which Plaintiff had sent to the Federal Bureau of Investigation, FOIA Section.  But Plaintiff must first note that Plaintiff Manfredonia had been told by an FBI Special Agent that the Federal Bureau of Investigation would never grant Plaintiff Manfredonia complete access to his FBI files, i.e. all notes, memoranda, documents, letters, records of surveillance, etc.,- unless Plaintiff were arrested on a federal warrant and were charged with a crime that would necessitate the release of Plaintiff’s FBI files, i.e., all notes, records, memoranda, documents, etc. that mention Plaintiff’s name or refer to him.

 

The FBI has violated federal statute by not permitting Plaintiff Manfredonia complete and unfettered access to his FBI files.  In violation of federal law and the Freedom of Information Act, Plaintiff Manfredonia has been denied the right to have access to his FBI files, i.e., notes, records, memoranda, letters, records of surveillance, etc., which mention Plaintiff’s name- or perhaps Judge Townes can provide Plaintiff with another term for Plaintiff’s records and files that are at the FBI?  The only information that the FBI has provided Plaintiff and that was in early 1994 was a copy of Plaintiff’s FBI wire order- an FBI document that Judge Townes did not recognize.  This document proves that Plaintiff had been wired by the FBI.

 

Plaintiff Manfredonia has requested access to his FBI files on many occasions.  In a letter, dated 21 July 1993 to J. Kevin O’Brien, FOIPA Section, Plaintiff wrote “concerning my request to view my records.”  (Exhibit12).  In a letter, dated 19 March 1994, to Mr. Kevin J. O’Brien, Plaintiff Manfredonia made reference to his FOIPA NO. 375,318 and asked to view his FBI records.

 

The Court must note that in 1994 Plaintiff Manfredonia received what Plaintiff has termed his “FBI wire order,” a document which Judge Townes has incomprehensibly disavowed- unless Judge Townes has never presided over a case where an informant was wired.  So Plaintiff’s FBI wire order is proof positive that Plaintiff had properly requested his FBI files, i.e., all documents, records, notes, memoranda, etc. that mentions Plaintiff’s name and pertains to Plaintiff.

 

On 15 October 1993 Plaintiff Manfredonia sent a letter, certified mail P 397 542 208, to Mr. Kevin J. O’Brien, Chief Freedom of Information and Privacy Act Section, and requested Plaintiff’s files.  (Exhibit 12)

 

On 11 June 1998 Plaintiff wrote a letter, certified mail P 311 766 501, to Mary Jane Broca, Supervisory Special Agent.  Plaintiff wrote to Broca requesting specific letters, which Broca had written (Exhibit 12).  Mary Jane Broca then instructed Plaintiff to write to the FOIA Section.  Plaintiff did so, but never received the requested letters.  Those were specific instructions, which Plaintiff followed, Judge Townes.

 

Plaintiff then wrote to the FBI and requested these letters.  Plaintiff received a letter in December 1998 from Kevin O’Brien, FOIPA Section.  This letter inquired if Plaintiff wished to continue his request for Plaintiff’s FOIPA request.  So, it appears that the FBI understood the meaning of Plaintiff’s requests.

 

Plaintiff then wrote to Kevin O’Brien on 14 December 1998, certified mail Z 055 653 268, which letter was sent to Mr. Kevin O’Brien, FOIPA Section, 935 Pennsylvania Avenue NW, Washington, DC 20535-0001 and requested Plaintiff’s files (Exhibit 12).  Unfortunately Plaintiff is unable to locate many of his letters from the FBI because many of these records were kept in the office of Michael Bressler and were lost in 2004.  Judge Townes, these are records readily available from the FBI- unless Judge Townes wishes to cover up more malfeasance.  Plaintiff’s letter, dated 14 December 1998, is Exhibit 12.  Plaintiff’s letter of 14 December 1998 to Kevin O’Brien was not answered- it was ignored.  Sorry, Judge Townes there is no way of appealing an ignored letter.  And Bill T. Singer told me that the only means, by which I could obtain my FBI files, when my letters were ignored, was to sue in federal court.

 

Furthermore in 2002 Plaintiff asked an attorney, Michael R. Bressler, to request Plaintiff’s FBI files.  While Plaintiff is unable to locate that letter, Plaintiff has supplied a copy of Bressler’s request to the SEC as Exhibit 11.

 

Plaintiff has proved that Plaintiff has followed the proper procedure and is entitled to Plaintiff’s FBI files- a term, which is understood by the FBI, although not by the Court.  By “FBI files” Plaintiff means all documents, files, records of surveillance, notes, memoranda, etc. which mention Plaintiff’s name.  As proof that Plaintiff has followed the proper procedure Plaintiff must asseverate that the FBI never instructed Plaintiff to follow another procedure to request Plaintiff’s files.

 

Judge Townes, or her law clerk, has made a deliberate and willful misstatement on page 8 of Judge Townes’ Memorandum and Order.  Judge Townes stated:  “… it appears that plaintiff began requesting information from the FBI in 1993, but there is no indication of the result of his requests or whether he appealed the decisions with which he now appears to disagree.”  This is a deliberate factual misstatement.  There were no decisions- and Judge Townes knows this.

 

In early 1994 Plaintiff received his “FBI wire order” as a result of his FOIAPA request, which Plaintiff made in 1993 to the FOIPA Section of the FBI. The FBI provided a copy of “Plaintiff’s FBI wire order.”  This document did not drop like manna from heaven.  Plaintiff did not find it like Miriam’s well.  And Judge Townes has seen many copies of FBI wire orders.

 

The FBI never responded except again to any letters, which Plaintiff had written, that requested Plaintiff’s FBI files- except to provide Plaintiff a copy of his “FBI wire order.”

 

Judge Townes, obey the law and let this legal action proceed- or arrest Plaintiff for perjury and let Plaintiff obtain the documents demanded in Court.

 

 

IV:  REMEDY SOUGHT

 

Plaintiff Edward Manfredonia wishes to asseverate most forcefully that he demands all records of surveillance of Plaintiff from the Federal Bureau of Investigation and the Department of Justice.  Plaintiff wishes to state that the FBI and the Department of Justice do not send individuals, whom it has kept under either surveillance or wire tap, a notice and record of the surveillance.  So, Plaintiff must make a broad request for his files, i.e. notes, memoranda, letters, records, records of surveillance, etc. that are maintained by the Federal Bureau of Investigation and the Department of Justice and which records mention Plaintiff’s name or refer to Plaintiff by an alias or pseudonym.  It is here that Plaintiff must asseverate most forcefully that Plaintiff was never involved in criminal activity so there was never reason for any surveillance or wire tap of Plaintiff Manfredonia..

 

Plaintiff Edward Manfredonia demands that he be provided with copies of his FBI files, that is, all records, documents, notes, memoranda, records of surveillance, records of FBI Special Agent Joseph Yastremski picking up Alan Umbria for threatening Plaintiff’s life, records of telephone conversations with FBI Special Agent Yastremski, etc.- in other words all documents, i.e., notes memoranda, files, records, records of surveillance, etc., in which Plaintiff Manfredonia’s name is mentioned.  Plaintiff has provided a copy of a federal document, Plaintiff’s FBI wire order, which proves that Plaintiff had been wired by the FBI.  Plaintiff has provided a sworn statement by Patrick Azzara a former member of the American Stock Exchange, who faithfully described a meeting with FBI Special Agent Joseph Yastremski.  Plaintiff is entitled to these records, files, etc. under the provisions of the Freedom of Information and Privacy Act.  The FBI must obey the law.

 

Plaintiff Edward Manfredonia demands that he be provided with copies of his Securities and Exchange Commission files, i.e. records, notes memorandums, letters notes, documents, etc. that mention the name of Plaintiff Edward Manfredonia.  Plaintiff wishes to stress that Plaintiff had been informed by several SEC staff attorneys that there was a directive from Arthur Levitt and this directive ordered the SEC not to utilize any information that Plaintiff had provided.  Plaintiff is entitled to these records, files, etc. under the provisions of the Freedom of Information Privacy Act and under the provisions of the Securities Exchange Act of 1934.

 

Plaintiff Edward Manfredonia demands that he be provided with copies of his Department of Justice files, that is, all records, documents, notes, memoranda, records of surveillance, records of telephone conversations with AUSA Frances Fragos, records of the authorization by AUSA Frances Fragos for FBI Special Agent Joseph Yastremski to pick up Alan Umbria for threatening Plaintiff’s life, all records of the 13 September 1993 meeting between Plaintiff Manfredonia, AUSA Frances Fragos, and FBI Special Agent Joseph Yastremski, of which meeting Plaintiff has submitted his affidavit to President Bush, etc.- in other words all documents on file at the Department of Justice that mention Plaintiff’s name.  Plaintiff is guaranteed this information by the Freedom of Information Privacy Act.

 

Plaintiff demands an apology from Justice Townes for using terms such as incredible, delusion, etc. in referring to Plaintiff’s chronology of criminal activity at the American Stock Exchange.  There is an affidavit by Patrick Azzara that confirms Plaintiff’s accusations.  As a federal judge, Judge Townes knows that the federal government chooses whom it prosecutes.

 

Perhaps the case should be assigned to the Honorable Jack Weinstein, who is a fair judge.

 

Plaintiff requests that he be granted in forma pauperis status to appeal any decision by Judge Townes.  Judge Townes has already made a bad faith effort in dismissing Plaintiff’s complaint with derision that should be reserved for a serial killer.  Please remember that Plaintiff is a whistle-blower

 

After all, Judge Townes has stated that Plaintiff’s “FBI wire order,” a document provided by the FBI to Plaintiff was illegible.

 

Plaintiff believes that for whatever reasons, which are known to Judge Townes, Judge Townes is biased against Plaintiff and does not wish to have any pro-se lawsuits, which were initiated by Plaintiff.  Judge Townes has already dismissed Plaintiff’s lawsuit against Yahoo on diversity issues, because, according to Judge Townes, Plaintiff requested excessive damages- even though Plaintiff proved defamation per se and a denial of employment.

 

Judge Townes just does not wish a pro se lawsuit that challenges the federal government.

 

Plaintiff is requesting that you, Judge Townes, recuse yourself from this case.

 

Judge Townes if you truly believe that Plaintiff has committed perjury, you are duty bound to have Plaintiff arrested and charged with perjury.

 

I declare under penalty of perjury that the foregoing is true and correct.

 

 

Dated:

 

Edward Manfredonia

 

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