UNITED STATES DISTRICT COURT & & 4 SOUTHERN DISTRICT OF NEW YORK
we. Plaintiff, :
We Vv. 1S-cv-7761
20203 and DETECTIVEBRIAN KUSTERER, Shield # 4667, and CITY OF Defendants. _ To.Hon. P. Kevin Castel, United States _ District Judge.
Plaintiff respect submitted a motion | _ to the court by amende the case caption complaint, Pursuant to 42,U.S,C.§ 1983 Under Federal Rules for granting _ reconsideration pursuant to Local Civil _ _ Rule 6.3, for amending in vacating judgment pursuant to Rules 59 and 60, Fed. R. Civ. P. mistake, surprise, and _ 59,(e), legal errors,for Memorandum Order date Dec 4,2017..Under this _ court order Jan 23, 2026, for relief. 1.
On march 6, 2015, | was Seat in the _ parked car, at 132 Street between. _ Seventh and Eighth Avenues, whele : _ police officers aproach my car and start _ "question me and remove me of the car false arrest me without probable cause _and search the carin accuse me forbe _ stolen my own | phone, and claim again _ _ my Tennessee valid licence was forged, _ _ and took me to the police custody at the _ 33rd precinct. A valid Tennessee license _ _Isalegitimate document aNYofficer _ can't just declare it forged, US law.?,
_ Atthe precinct police officertookmy _ wallet from my pocket and took my □ _ bank cards inside my wallet searchto the card reader. The subsequent search _ _ of my wallet at the precinct After being _ _ false arrest was akin to searching a small bag or change purse and that was _ unlawful."As Pétition convicted charge?,’ _ The protections embodied inarticle|, _ §12 of the New York State Constitution _ _ serve to shield citizensfrom warrantless _ _ intrusions on their privacy interests, _ including their personal effects’(People _ Jimenez, 2014, 22 N.Y.3d 717,719. 2.
_ The same police officers false arrest me | _ | in charged me with 7, différents charges | _ Penal Law 170.25, In Penal Law 155.35, in Penal Law 165.45, in Penal Law □ 165.05, in Penal Law 220.03, □□ Penal Law 221.05, inVTL 051.10. Grand jury dismiss, 6, of that arrest 7, charges | against me without my present in court. | Lwas indicted with Penal Law 170.25, _ for my valid Tennessee driver's licence, _ with:my own bank credit cards. Number appear on the state court trial record 45473500000. As conviction charges _ Reading ‘same number five zéro link _ print on the banks crédit card?????.
How five zéro link print cant be abanks _ card,? number appear on the state trial
_ court Workers have banks crédit card _ Verify, why one of they court Workers _ did not have five zéro link print on they bank card?. impossible banks card five zéro link can’t purchase, As 00000, link.
The grand jury indictment was procured | by fraud in perjury under false oath. 3.
UNnMa&recn 7, 2U To, | Was danlstefeag tO court, at the grand jury procedure my _ due process right was violated without _ my present in front of the jurys. □
_ Police officer O'hara, false testify at grand jury that my valid Tennessee □ driver's licence was forged, and officer Kusterer also testify at grand jury that _ he used a scanner to inspect my valid _ driver's license the results flaggedthe license was forged, Officer Kusterer did notused an ID scanner issued bythe _ New York Police Department and used an ID scanner that he owned personally. □ _ AvalidTennessee license is a legitimate _ document a NY officer can't declare it forged without justification in false arrest me, See: Monell v. New York Dept. of Social Services, 436U.S.658
_ charged valid tennessee driver's licence, the grand jury indictment was procured □ . under perjury in false oath. Officer O'hara lie that | was parked in the _ front of the church, another false oath, 4 □
officer Kusterer and officer O'Hara _ violated my due process right in Fourth _ Amendment protections garantee under © the U.S. Constitution, Both officers there are personally involved with deprivation _ of my rights under the color of law.
The initial arrest lacked probable cause. | even if later indicted on a separate _ charge. Six charges dismissed by a grand jury suggests weak evidence. precinct fake charge. See Sankara v. Martuscellor,18-cv-6308, Oct 27, 2025. □ _ The City of New York are liable too, □ | | was wrongfully convicted by the jury's. □ who did not knew about the laws as for _ precinct fake charged got me convicted _ Number appear on the state court trial record 45473500000?. My conviction = _ charges Reading same number five zero link print.on the banks crédit card?????, false arrest, false imprisonment, "unlawful seizure, malicious prosecution, malicious'abuse of process, excessive _ force, imposing unconstitutional conditions of confinement. 5.
MEE MINI OILY SMELL Veo IE _ the parties’ citizenship) or other specific — statutes. Federal question jurisdiction, _ The basis for federal question matter of _
_ federal courts the authority to-hear civil — _ cases that involve a question of federal _ law, such as those arising under the U.S. _ Constitution, federal laws, or treaties The general authority of federal courts _ _ to hear a civil case based onthe subject matter of the dispute., See:United _ Student Aid Funds, Inc., 559 U.S. at 275.
_ The authority for this jurisdiction comes _ _ from Article 3 of the U.S. Constitution = and is codified in 28 U.S.C.§ 1331. the — resolution of the dispute dependson _ Interpreting the Constitution, a federal law, or atreaty. For a case'to qualify, the — _ federal question must appearonthe = _ face of the plaintiff's complaint.
Officer O'hara and Officer Kusterer _ cause me indicted with perjury oath.trial _ paper fabricate charge counts appear _on the state trial record,See TOWNEv. DAVIS, 66 NH. 396 22 A, 450. 6.
Police onicer Ohara misconduct taise arrest me without probable cause and process me at two different precinct = 33rd. Precinct and 32 precinct, and used _ two different shield number at the state _ court different procedure mislead _ identified himself. both number, Badge #4408, Shield # 20203.0on court records _
Police officer O'hara original precinct he _ was a signe to 25th Precinct. Inwithout _ his jurisdiction, he false arrest me took | me to 33rd precinct in process me again | at 32nd Precinct.?, 33rd precinctand 32nd Precinct both precinct process paper on the state court record. Police officer O'hara at the precinct took _ my wallet inside my pocket inswipmy bank cards to the card reader in Switch _ my credit cardsnumber number appear on the state trial record, See, 45473500000, two of the conviction _ charges Reading same numbers five = _-zéro print onthe card?, number appear on the state trial record. without any accuse crime items évidence submit to the court for to convicted me?: 7.
The Fourth Department analyzed _ whether this principal applied to alegal _ _ malpractice action with an underlying criminal matter. Id. 915 N.Y.S.2d at 780. _ The First Department addressed this very issue in Wilson v. City of New York, 294 A.D.2d 290, 743 N.Y.S.2d 30 (ist _ Dep't 2002), holding that the recovery of | nonpecuniaty damages is not permitted. However, the Fourth : Department declined to follow the : holding in Wilson. _
In'rendering its decision, the Fourth _ Department analogized a criminal legal _ malpractice action to causes of action _ for false arrest and malicious prosecution, both of which permit _ recovery for the plaintiff's loss of liberty — _ resulting from the plaintiff's wrongful _ incarceration. Id. at 1589, 915N.Y.S.2d at 780. The Court further observed that _ _ ina criminal case, the risk of imprisonment is a direct result of attorney malpractice. Consequently, "the _ Fourth Department concluded, See, Dombrowski v. Bulson, 79 A.D.3d 1587, N.Y.S.2d 778 (4th Dep't 2010). 8. |
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UNITED STATES DISTRICT COURT & & 4 SOUTHERN DISTRICT OF NEW YORK
we. Plaintiff, :
We Vv. 1S-cv-7761
20203 and DETECTIVEBRIAN KUSTERER, Shield # 4667, and CITY OF Defendants. _ To.Hon. P. Kevin Castel, United States _ District Judge.
Plaintiff respect submitted a motion | _ to the court by amende the case caption complaint, Pursuant to 42,U.S,C.§ 1983 Under Federal Rules for granting _ reconsideration pursuant to Local Civil _ _ Rule 6.3, for amending in vacating judgment pursuant to Rules 59 and 60, Fed. R. Civ. P. mistake, surprise, and _ 59,(e), legal errors,for Memorandum Order date Dec 4,2017..Under this _ court order Jan 23, 2026, for relief. 1.
On march 6, 2015, | was Seat in the _ parked car, at 132 Street between. _ Seventh and Eighth Avenues, whele : _ police officers aproach my car and start _ "question me and remove me of the car false arrest me without probable cause _and search the carin accuse me forbe _ stolen my own | phone, and claim again _ _ my Tennessee valid licence was forged, _ _ and took me to the police custody at the _ 33rd precinct. A valid Tennessee license _ _Isalegitimate document aNYofficer _ can't just declare it forged, US law.?,
_ Atthe precinct police officertookmy _ wallet from my pocket and took my □ _ bank cards inside my wallet searchto the card reader. The subsequent search _ _ of my wallet at the precinct After being _ _ false arrest was akin to searching a small bag or change purse and that was _ unlawful."As Pétition convicted charge?,’ _ The protections embodied inarticle|, _ §12 of the New York State Constitution _ _ serve to shield citizensfrom warrantless _ _ intrusions on their privacy interests, _ including their personal effects’(People _ Jimenez, 2014, 22 N.Y.3d 717,719. 2.
_ The same police officers false arrest me | _ | in charged me with 7, différents charges | _ Penal Law 170.25, In Penal Law 155.35, in Penal Law 165.45, in Penal Law □ 165.05, in Penal Law 220.03, □□ Penal Law 221.05, inVTL 051.10. Grand jury dismiss, 6, of that arrest 7, charges | against me without my present in court. | Lwas indicted with Penal Law 170.25, _ for my valid Tennessee driver's licence, _ with:my own bank credit cards. Number appear on the state court trial record 45473500000. As conviction charges _ Reading ‘same number five zéro link _ print on the banks crédit card?????.
How five zéro link print cant be abanks _ card,? number appear on the state trial
_ court Workers have banks crédit card _ Verify, why one of they court Workers _ did not have five zéro link print on they bank card?. impossible banks card five zéro link can’t purchase, As 00000, link.
The grand jury indictment was procured | by fraud in perjury under false oath. 3.
UNnMa&recn 7, 2U To, | Was danlstefeag tO court, at the grand jury procedure my _ due process right was violated without _ my present in front of the jurys. □
_ Police officer O'hara, false testify at grand jury that my valid Tennessee □ driver's licence was forged, and officer Kusterer also testify at grand jury that _ he used a scanner to inspect my valid _ driver's license the results flaggedthe license was forged, Officer Kusterer did notused an ID scanner issued bythe _ New York Police Department and used an ID scanner that he owned personally. □ _ AvalidTennessee license is a legitimate _ document a NY officer can't declare it forged without justification in false arrest me, See: Monell v. New York Dept. of Social Services, 436U.S.658
_ charged valid tennessee driver's licence, the grand jury indictment was procured □ . under perjury in false oath. Officer O'hara lie that | was parked in the _ front of the church, another false oath, 4 □
officer Kusterer and officer O'Hara _ violated my due process right in Fourth _ Amendment protections garantee under © the U.S. Constitution, Both officers there are personally involved with deprivation _ of my rights under the color of law.
The initial arrest lacked probable cause. | even if later indicted on a separate _ charge. Six charges dismissed by a grand jury suggests weak evidence. precinct fake charge. See Sankara v. Martuscellor,18-cv-6308, Oct 27, 2025. □ _ The City of New York are liable too, □ | | was wrongfully convicted by the jury's. □ who did not knew about the laws as for _ precinct fake charged got me convicted _ Number appear on the state court trial record 45473500000?. My conviction = _ charges Reading same number five zero link print.on the banks crédit card?????, false arrest, false imprisonment, "unlawful seizure, malicious prosecution, malicious'abuse of process, excessive _ force, imposing unconstitutional conditions of confinement. 5.
MEE MINI OILY SMELL Veo IE _ the parties’ citizenship) or other specific — statutes. Federal question jurisdiction, _ The basis for federal question matter of _
_ federal courts the authority to-hear civil — _ cases that involve a question of federal _ law, such as those arising under the U.S. _ Constitution, federal laws, or treaties The general authority of federal courts _ _ to hear a civil case based onthe subject matter of the dispute., See:United _ Student Aid Funds, Inc., 559 U.S. at 275.
_ The authority for this jurisdiction comes _ _ from Article 3 of the U.S. Constitution = and is codified in 28 U.S.C.§ 1331. the — resolution of the dispute dependson _ Interpreting the Constitution, a federal law, or atreaty. For a case'to qualify, the — _ federal question must appearonthe = _ face of the plaintiff's complaint.
Officer O'hara and Officer Kusterer _ cause me indicted with perjury oath.trial _ paper fabricate charge counts appear _on the state trial record,See TOWNEv. DAVIS, 66 NH. 396 22 A, 450. 6.
Police onicer Ohara misconduct taise arrest me without probable cause and process me at two different precinct = 33rd. Precinct and 32 precinct, and used _ two different shield number at the state _ court different procedure mislead _ identified himself. both number, Badge #4408, Shield # 20203.0on court records _
Police officer O'hara original precinct he _ was a signe to 25th Precinct. Inwithout _ his jurisdiction, he false arrest me took | me to 33rd precinct in process me again | at 32nd Precinct.?, 33rd precinctand 32nd Precinct both precinct process paper on the state court record. Police officer O'hara at the precinct took _ my wallet inside my pocket inswipmy bank cards to the card reader in Switch _ my credit cardsnumber number appear on the state trial record, See, 45473500000, two of the conviction _ charges Reading same numbers five = _-zéro print onthe card?, number appear on the state trial record. without any accuse crime items évidence submit to the court for to convicted me?: 7.
The Fourth Department analyzed _ whether this principal applied to alegal _ _ malpractice action with an underlying criminal matter. Id. 915 N.Y.S.2d at 780. _ The First Department addressed this very issue in Wilson v. City of New York, 294 A.D.2d 290, 743 N.Y.S.2d 30 (ist _ Dep't 2002), holding that the recovery of | nonpecuniaty damages is not permitted. However, the Fourth : Department declined to follow the : holding in Wilson. _
In'rendering its decision, the Fourth _ Department analogized a criminal legal _ malpractice action to causes of action _ for false arrest and malicious prosecution, both of which permit _ recovery for the plaintiff's loss of liberty — _ resulting from the plaintiff's wrongful _ incarceration. Id. at 1589, 915N.Y.S.2d at 780. The Court further observed that _ _ ina criminal case, the risk of imprisonment is a direct result of attorney malpractice. Consequently, "the _ Fourth Department concluded, See, Dombrowski v. Bulson, 79 A.D.3d 1587, N.Y.S.2d 778 (4th Dep't 2010). 8. |
to 42, U.S.C.§ 1983 Under Federal Rules civil procedure to granted my motionin _ vacated the judgment Memorandum and Order date Dec 4, 2017, Underthis _ court order Jan 23, 2026,
Police Officer Liam.O'Hara and Detective _ Brian Kusterer, are employed by NYCPD _ are liable for false arrest imprisonment unlawful seizure, malicious prosecution, _ malicious abuse of process, excessive _ force, imposing unconstitutional _ conditions of confinement, and inflicting □
emotional distress inaconsciousand negligent fashion. Plaintiff sought relief is $50.000.000.00, dollars. Hon Judge _ discrimination cant setllethe lawsuit = conpersation money amount damage under the Law. Respectfully submitted. _ "CC:To, David Ferrari, New York City Law Dept. Special Federal Litigation Divisio 100 Church St. New York,NY 10007"
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