E. Defendants, Marsha Finnan and Asadourian perverted justice and conspired with Molly Nichols of the NY State Police to entrap Terence Finnan into admitting he had committed a crime during his testimony in the Family Court for having a copy of the e-mail sent by Marsha Finnan. In Family Court, Molly Nichols sent notes on behalf of Marsha Finnan and Asadourian to the Judge which I was not allowed to see. Marsha Finnan on the advice of Asadourian lied to the sheriff’s deputy about the address of Victoria Finnan who was subpoenaed to said Family Court in order to obstruct justice by depriving me of Victoria Finnan as a witness.

            F. Defendants, Ryan and Caruso, neglected andlor refused to prevent the denial of my rights to justice, due process and Constitutional rights as described in 4.A. (all). Although both maybe immune from liability, neither is immune from declaratory relief.

            G. Defendants Essex County andlor Caruso through the County Clerk, Mr. Provoncha, and Court Clerk(s) prepared false documents to deprive Terence Finnan of his right to a Jury Trial as described above in 4.A.(m.).

            H. Defendants, Essex County through its funded entities andlor J. Does(s) and Defendant, Kennedy, assisted Marsha Finnan to prepare false, misleading, and fraudulent testimony and perjured court papers to deprive Terence Finnan of his rights and property under Law
.
            I. Defendants, Asadourian and Ryan, deprived me of rights as described in my letter dated 12/18/2007 to Caruso and in 4.A. (p.) above, in meeting ex parte just prior to a court appearance of Terence Finnan. This meeting was not an official act of Ryan, since such an ex parte meeting is forbidden by law. Ryan’s court schedule had no other actions except the one with Terence Finnan to which Asadourian was a party and/or attorney on that date
.
            J. Defendant Ryan deprived Terence Finnan of Equal Protection under law when he refused to follow precedent in Kaplan v Kaplan 2007 NY Slip O 09734 and in above 4.A.(t.). Ryan also refused to follow the law concerning fault divorces as defined by the NEW YORK STATE UNlFIED COURT SYSTEM’s rules and procedures.

            K. Defendant, Ryan, refused to allow any discovery in the action Finnan v Finnan, Breckenridge et al.. Defendants Asadourian, Marsha Finnan, and Breckenridge conspired to prevent discovery in this action.

            L. Defendant, Ryan, refused to allow Defendant Breckenridge to be identified as a Jane Doe in Finnan v Finnan, Breckenridge et a!., depriving me of my rights.

            M. Defendants Ryan, Asadourian and Marsha Finnan deprived me of equal protection under law when Ryan refused to act on my CRIMINAL COMPLAINT AND Request for ORDER OF PROTECTION made in November 2007. These crimes in the mentioned CRIMINAL COMPLAINT included:

                           Page -5-


                    By Asadourian:

    a. perjuring an affirmation dated March 8, 2006 in the Supreme Court -Appellate Division in violation of the Penal Law of NY Section 210.15 (Perjury in the first degree)

                By Marsha Finnan

    b. committing assault (NY Penal 120.10) and battery and recklessly endangerment (NY Penal 1120.25) on Terence Finnan and injuring his eye when she attempted to blind him. This is in Finnan v Finnan, Breckenridge et al.

    c. committing attempted murder of Terence Finnan when she in many individual and/or multiple actions, (NY Penal 110.00, 120.25, 120.30, 120.35) by attempted to cause the suicide or death of Terence Finnan and removing a ladder when Terence Finnan was on the roof in expectation that he would jump and die because he was taking a blood thinner and refusing him medicine and liquids when he was extremely ill causing him to be treated in the Emergency Room

    d. committing perjury (NY Penal 210.15) in multiple affidavits in Finnan v Finnan,

    e. committing subordination of perjury (NY Penal 210.15) in Finnan v Finnan, paying Asadourian falsely affirm the Appellate Division

    f. paying her attorney her attorney to recklessly endanger and harass (NY Penal 20.25) Terence Finnan by wildly emoting, swinging his arms, stamping his feet, and in a loud voice crying out repeatedly that Terence Finnan was crazy. This caused my attorney and me to leave the courthouse by a back way to avoid physical confrontation with Asadourian.

    g. criminally acting based on the race of my mother in violation of NY Penal §485.05.

                N. I had two heart attacks, heart surgery, a stroke and many other medical conditions and
I was harmed by acts of the all the Defendants and except for Ryan and Caruso, ask for
$1,500,000.00 as compensatory damages and $1,000,000.00 as punitive damages. According to
NY Law §487 -Misconduct by attorneys, damages for the unethical conduct in violation of
disciplinary rules by Defendant Asadourian are to be tripled.

                0. All of the Defendants are continuing to be involved in pending court actions against the Plaintiff and remedy is needed to forestall further harm.

                P. Defendant Asadourian on behalf of Defendant Marsha Finnan defrauded the court by lying about the testimony of two witness (Dr. Richard Smith and Father O’Reilly), who corrected Asadourian’s fraud in sworn affidavits. Defendant Asadourian acting with Defendant Marsha Finnan and, having the power, neglected to correct this harm under § 1985 to my person.

                    -End of Facts-.