DEFENDANT’S AFFIDAVIT IN SUPPORT

I Delmo Zanette, reside at 1357 King St, Greenwich, CT, am duly deposed and swear to be true

the following stated facts and circumstances; as I agree in advance to subject myself to a

polygraph test to verify the veracity of my complaint herein.

I am a senior of 79 years and pursuant to CT Gen. L §17b-450f, am complaining of being a

victim of fiduciary elder abuse. This is perpetrated by “wrongdoers”: Ronald E. Pecunies

(Pecunies) and his associate Author K. Watson (Watson) who on the basis of fraud, are now

seeking to evict me from the home I own so they can sell my property for their exclusive benefit.

Whereby, both, Pecunies and Watson (P&W) initially impressed me as being successful business

men. Insomuch as they were co-owners of Mercedes-Benz of Greenwich and with claims of

owning a vast amount of real estate. In addition Pecunies impressed me that they were both well

respected in the Greenwich community and philanthropists; but what especially impressed me

was when Pecunies enlightened me to how Watson was an individual of social prominence.

Consequently, I believed the P&W were legitimate business persons and dealmakers. Thus, it

never occurred to me that they would not adhere to the presented business arrangement for them

to buy my four acres of property in Greenwich, CT. Insomuch as I was previously offered 3.2

million about four years before, by a Ms. Alvus, just for buying one of the two parcels containing

the farm land. Specifically, I would still keep the 1.8 acre parcel where my home is located (that

I am now have a marshals warrant of eviction that I am fighting to keep my right of occupancy)

and she would buy the 2.3 acres containing to operation of Purdy’s Farms. In addition, Ms.

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Alvus made a final concession that she would still allow me to occupy the entire building of my

farm store where I would live above it for five years after the sale, even without my having to

pay a cent. Since, she wanted the land to build a hotel; thereby to exploit its commercial zoning

status, unique to the area, and proximity of being located right next to the Westchester Airport.

Consequently, I have long regretted not selling the farm parcel for 3.2 million, since I still would

of owned my home on the 1.8 acres parcel that is now in summary proceeding, of where I could

have plowed a garden of a non-commercial size on its vast front lawn in the spring. However, the

reason why I declined accepting the offer for 3.2 million was because it was of greater value for

me at that time to be able to continue with the commercial farming on the field to my land.

Essentially, I just didn’t want to give up being able to offer to my customers who shop in my

farm store, farm fresh organic produce. Thereby, where I could sell them produce, I might of had

picked that very morning, as a manifestation from the sweat on my brow; rather than to sell them

something that I unpacked from a box. In addition, I have amassed many antiques and

collectables that I had planned to exhibit in a children’s museum I long have planned to have on

my property. I have three 40’ foot containers on my property filled with art, antiques, and

collectables, outside of my furnished home that defendant had illegally changed the locks.

In fact, I tilled this land for 44 years, before plaintiff blocked my ability to continue. Since

plaintiff claims that the law of our land affirms it is his legal right to dispose of everything I own;

everything dear and sacred to me, plaintiff feels entitled to take from me as a matter of his right.

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Insomuch as plaintiff has promised me through his agents that the last bit of everything I own

will be trashed if I don’t willfully agree to obey their demands.

At the time of the “agreement,” the property was appraised to be worth at least four million, so I

thought we met on common ground where both parties were happy with the agreement,

considering I could still stay on the property for as long as I wanted. Consequently, I agreed for

the sale price to be three million, instead of requiring to be paid the four million I could get on

the open market.

Therefore, I expected the sale would go smoothly with all my full cooperation extended to

accommodate what plaintiff had wanted. Since I thought my compliance was just to support their

ability to consummate their business intentions. However, what I did not take notice as

suspicious was that within the first two months they kept presenting to me, yet another

agreement to sign (exhibits A-D). Now in retrospect, I should have seen this as being an

indicator I needed to scrutinize any new agreement. Since, if I wasn’t trusting that plaintiffs

would make good to their word, and read the contracts before signing, I would have noticed in

the ‘contract’ the numerous terms that didn’t correspond to what was verbally promised.

Point in fact, even though I possess a copy of the first agreement with Pecunies dated on March

27th, he testified that the very first time meeting me was when I signed the May 27th agreement.

In addition, Philips contradicted Pecunies first meeting me at about the middle of year by his

testifying Pecunies met me at the beginning of the year in 2004. Moreover, Pecunies testified

that I used plaintiffs’ financial investment to prevent my losing the properties, saying it was on

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the brink of being foreclosed on. However, this could not be more further from the truth, since it

was not until November 17th, (6 months later) when they refinanced the property that any money

was paid out towards the mortgage, which unnecessarily imposed penalties.

Yet, the afore stated subsequent fiduciary loss, albeit needless is almost nothing compared to

plaintiffs’ conduct of not paying out anything towards the interest only mortgage for three years.

This is most disturbingly, since the basis of my authorizing them to get refinancing in the first

place was to obtain a better rate. Yet, they secured a usury rate 11 ½ %, to replace an 8½ %

mortgage; of which I was paying before they took over the responsibility.

Then to add insult to injury, plaintiffs never made any of the monthly payments, and depleted the

$520,000 balance left over after they embezzled about $460,000. This was drawn upon the open-

credit that plaintiff obtained at refinancing by imposing a two million lean on the property.

Consequently, as a result of plaintiff’s delinquency of making any of their required monthly

payments, astronomical extra charges on the property were imposed as a result.

Not to mention, unlike Pecunies’ bold faced lie to this court that the property was going into

foreclosure before they took over its management to overt my losing the property, the truth is

that the property is now going into foreclosure. Essentially, this is because they took over its

management. As plaintiff’s role of being the ‘manager’ of the property is, in effect an artifice to

a scheme to loot the equity contained in the properties. Thereby, plaintiffs perverted their

position of authority and responsibility of being the manager of my properties to cloak their

racketeering activities in an ‘enterprise’ in violation of RICO.

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On the last and applicable agreement in May 2004 that superseded prior agreements, I did not

even read it before I signed, as they only pushed it in front of me to sign on top of my name. Yet,

unbeknownst to me was what I was promised and was expecting in plaintiffs’ performance was

being made verbally, and not incorporated in the contracts. Such as where in the prior agreement

I was named as being the 100% owner of the LLCs; of which was changed without my being

consulted or informed before I signed the ‘agreement’ where I designated 25% ownership to

Pecunies and another 25% to Watson. Essentially, from the onset the designation of ownership of

Pecunies and Watson was a product of trickery and foul play, yet they act as if they paid me half

of its market value at that time and say they financially bailed me out from losing everything.

Essentially, I was duped to unknowingly assign over to the plaintiffs my rights of ownership and

right to appreciate revenue by them collecting the rents. Then when I asked Pecunies why he was

named as the manager of my properties, he said it was for my conveyance. Although, I still

collected rents from my tenants that was written out to my name they required I give them

$6,300 of the rents. This is where for over four years I would sign on the back of the checks

written out to my name as they requested, over to the LLCs.

However, after my tenants were telling me that the returned checks were showing they were not

cleared in the bank account of the LLC’s, but in the business account of Mercedes Benz and

Watson Enterprises. Not surprising, plaintiff’s accountant, John L. Cox, told me the LLC’s

doesn’t have a bank account.

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At the onset when the agreement was made, I consented they could use the rents towards the

properties debts, and they collected approximately $6,700, or less at times, for rentals of specific

apartments, and I would collect a total of $3,600 for three units and give them $1,000 towards

the taxes. Since the agreement was I could continue to occupy my farm store and live on the

floor above. However, if they were to sell the entire property to the outsider, it must be for 4

million dollars, yet I would share the extra million I received with them. Essentially, I foolishly

agreed to give someone $500,000 for doing nothing, except for not living up to what they

verbally, and or, contractually promised.

Later I moved things that were in my garage into a container I rented to receive $375, but in

February when plaintiff was trashing all my property on the land they stole $1,500 of property

from my renter and tools him he had to leave in one month. He went to the Greenwich police and

was off for about two hours to be ultimately told that plaintiff owns the property and can do

whatever they want. In addition, I was receiving rent from a masonry company who was using

the land until plaintiff interfered.

When, the naming of Pecunies as Manager first came to my attention, Pecunies told me that it

was just for my own convenience. He said it was just so I won’t have to come down to their

office to sign the checks. Yet, in actuality this blocked me from having access to know they were

embezzling many hundreds of thousands of dollars from the property (probably over a million).

In effect, I have been completely shut out and kept in the dark and denied access to know

anything about the business of the LLC, or was ever allowed any participation whatsoever.

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Essentially, my last involvement in the business of the LLC’s was over 5 years ago when I

unknowingly had signed the contract to be a 50% member. Yet, Pecunies told me this was only

to be until they got refinancing, and he promised me immediately after refinancing it would be

changed, naming me as a 100% owner. However, I now know, exists only as a shell corporation

to create a façade of legitimacy, such as when they act to defraud me, or now with this eviction.

Consequently, I have been deprived from receiving most of the revenue from the rentals on my

property for the last 5 years that mostly went into plaintiffs’ pockets. Not to mention, all the

additional expenses they imposed upon me as a result of their shenanigans to have exhausted my

life savings. Especially when I now am desperately in of need funds since I am disabled and

chronically ill with chronic pulmonary disorder. This condition caused me to constantly

throughout most days to have episodes, when I have difficulty breathing and respiratory spasms.

Facts Corresponding to Current Eviction Action of Summary Process

Defendant used his key to move back in to his home as a matter of legal right in September 2009.

Insomuch as the tenant in his home were his tenants and paid rent to the LLCs and until in April 2009

when the plaintiffs demanded all rents were to be paid to them. Thereafter tenants in defendants home

paid checks directly to the LLCs until they left in October and defendant moved in thereafter. This was

especially, appropriate because plaintiff was forcing him to vacate from a building on the other property

he owns. This was when he was living with his health aid, Joanne Gramacy. Plaintiff had given her a

thirty day notice to leave, even though she was totally paid up in rent.

Clearly, the reason of notice to vacate was that plaintiff did not want defendant living on his property.

Although, she had paid rent on the apartment through the winter while she was in Florida with defendant,

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yet plaintiff broke in to change the locks, under the color of claim to cure a water leak. As plaintiff said

they changed the locks and lost the key to cause her and defendant to be locked out for two days. This

was until Ms Gramcay was plaintiff and Ms. Gramacy to be let back in where they resided until she was

given notice to vacate.

Complaint Showing How Fraud Upon the Court has Corrupted All Past Rulings

I am complaining that in the current proceeding of “constructively” being deprived of an

opportunity to present my position to the court. This is because of Judge Grogins’ refusal to set a

trial date in two months from now when I would be able to appear to participate and testify in the

beginning of April. Yet, Judge Grogins refusal is without any reasonable justification,

considering that my physical disability impairs my ability to be present.

Since this issue that I am currently very frail and in poor health, has been brought to his attention

by my council Mark Katz. Insomuch as my doctor says traveling to New York from Florida

places me in serious jeopardy and my pulmonary doctor prescribes I must avoid exposure to cold

weather.

Consequently, traveling from Florida to Connecticut would be exposing me to the dramatic

contrasting temperatures of frigid temperatures; cold could trigger a serious attack. Not to

mention I am an emotional wreck from being victimized by plaintiffs’ criminal activities to

intimidate me to willfully allow them to usurp most of everything I own. Since this has involved

a tremendous amount of major incidents of outrageous abuse that was accompanied by many

incidents of threats and harassment to intimidate my compliance. Whereby, plaintiffs’ goal has

been to force me to move out of my home and sell its property to them for a small fraction of

what it was worth before they looted most of its equity.

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In fact, not only has this entire proceedings been corrupted by ‘fraud upon the court’ with

councils from both sides, Robert Kaelin and Mark Katz, but all the other proceedings. Such as

with considering the criminal misconduct of plaintiffs’ past attorney Steven Phillips, who

actively participated in plaintiff’s confidence scheme to defraud me. Then, when I hired lawyers

to counter plaintiff utilizing their legal rights to cheat me these lawyers only supported the

opposition’s ability to obtain their legal agenda.

In effect, my lawyers betrayed my trust and deprived me of pursuing available legal

opportunities for me to have obtained relief. These lawyers were in order, Demetrois Adamis,

Donald Brown Robert Heisler, and Mark Katz. In effect, all the lawyers on both sides engaged in

activities of judicial misconduct, focused on depriving me out of my rights of entitlements

through foul play and the misuse of your court.

Consequently, I have also attached material to show the wanton acts of professional misconduct

of each lawyer as an individual actor. This is where I can show how they not only violated my

rights by neglecting to perform their official duty to uphold the law, but knowingly acted to

violate the law. In effect, they perpetrated misconduct under the color of being “officers of the

court.” Yet, in spite of the fact they are entrusted to demonstrate allegiance to the laws of the

land. This is expected by a lawyer’s utilization of their knowledge, skill, and acknowledged

aptitude to apply the law in an appropriate manner to the matters in dispute to ensure the

integrity of decisions.

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Whereby, my complaint against Judge Grogins is that he denied me of my right to due process

provided by my constitutional rights to receive justice in State Court on matters of equity. This

was manifested by perverting his discretionary authority. In effect, by Judge Grogins depriving

me from receiving a full, fair, and impartial hearing it consummated the interests of my

opposition. Since, their intent has been dedicated to deprive me of my legal right of entitlement

and quite enjoyment in the property that I own.

Clarification of performance of judicial misconduct of those I have named is readily validated as

being a material fact upon the review of the record to the proceeding. In fact, just a cursory view

upon the record shows a material fact of judicial wrongfulness was performed in a chronic,

extreme and pervasive pattern. Thereby, as a causation of the corrupt conduct of my lawyers, I

consistently have been deprived of exposing the major criminal activity and Herculean

falsehoods of the opposition. It shocks the conscious that my own lawyers stifled me from

refuting the fraudulent claims of the other side. Consequently, I was deprived of exposing the

major criminal activity and Herculean falsehoods spun out as a web of lies by the opposition.

However, not only have my own lawyers stifled me from refuting the fraudulent claims of the

other side, but also Judge Grogins denied me the right to testify and plead my cause. This was in

a prior legal matter involving eviction from a different building on my property about a year and

a half ago. As when the matter went before the Superior Court of Norwalk to vacate a stipulation

that was the product of coercion and misrepresentation by my own lawyer, Donald Brown. Yet,

this was my second one sided stipulation I signed as a product of being duped by own council’s

misrepresentation of its importune necessity. Whereby, the first stipulation I signed was due to

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being pressured by Demetrois Adamis. He said don’t worry about be evicted because I will bring

an action to dissolve the LLCs and remove Pecunies as manager so you won’t be evicted.

At the time Judge Grogins denied me of my right to testify my position was right after hearing

the matter of the prior eviction action based on falsehoods. Yet, Judge Grogins not only acted

with ill-will towards me, but demonstrated favoritism by allowing the opposition to testify to

their fraudulent claims. Such as with plaintiff’s false declarations to egregiously misrepresent the

business arrangement and fiduciary obligations to be entered onto the record, but I was blocked

from presenting my position in refute. Even though my testimony was essential for him to

establish his cause of action to justify vacating the stipulation, as to the state of his mind at the

time when I signed the stipulation, . . . as this was the pivotal issue to be decided upon. Since the

matter before the court was whether my signing of the stipulation was through my own volition,

or was the product of misconduct and/or misrepresentations.

Specifically, I had no interest to sign the stipulation, but my lawyer Donald Brown pressured me

to sign out of fear, by telling me that if you don’t sign it they’re going to suck out all the equity

in your property and you will end up with nothing. Moreover, Brown said it doesn’t matter if you

sign it because I am going to bring an action

Consequently, what occurred is that I did not sign under my own volition; rather I only agreed to

sign the stipulation as a byproduct of my lawyer’s coercion and misrepresentations. Thereby,

such interference is in accordance to Court Practice and Procedure, title 52, ch. 900, §52-212

II. Grounds for Relief, in 52-212 §58 Fraud and 52-212 §59 Duress, where statues say:

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 “In making its factual determination whether stipulated judgment should be opened,
pursuant to C.G.S.A. § 52-212a, trial court must inquire into whether decree itself
was obtained by fraud, duress, accident or mistake. (Jenks v. Jenks (1995) 657 A.2d
1107, 232 Conn. 750, on remand 663 A.2d 1123, 39 Conn. App. 139).

“To conclude that stipulated judgment resulted from duress, finder of fact must determine
that misconduct of one party induced party seeking to avoid stipulated judgment to
manifest assent thereto, not as exercise of that party's free will, but because that party had
no reasonable alternative in light of circumstances as that party perceived them to be.
(Jenks v. Jenks (1995) 657 A.2d 1107, 232 Conn. 750, on remand 663 A.2d 1123, 39
Conn.App. 139).

Essentially, I was denied the right to testify, and this ensured the status quo, of acknowledgment

of defendant’s fraudulent claims to be legitimate, by the records absence of any rebuttal to

contest the veracity of their fabrications to deceive the tier of facts. Thus, Judge Grogins

interference continued to ensure my position was not heard. This was after all the past lost

opportunities caused by plaintiff’s lawyers’ intentional neglect to expose the criminal conduct of

the adverse party. As where Brown told plaintiff he could not raise any issue besides the lease

and his rental payments in the eviction action, such as with fraud and other misconduct.

However, up to now I have never been able to contradict defendant’s outrageous falsehoods,

which are the very antithesis of the truth; such as where defendants testify to being the aggrieved

party . . . that should have been identified as bold faced lies that could have readily been refuted

by evidence. Whereas, instead of my lawyers refuting the lies of the opposition, they would

explain to me that it was never the time or place; and other ridiculous reasons to justify them

being ineffective representation.

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In effect, I was finally ready to have my day in court, after all my lawyers’ interfered with my

requests that they bring forth for the court’s consideration my rebuttals. Unfortunately, for a

reason, yet to be explained, the court did more of the same. Insomuch as, I was about to give

testimonial evidence to clarify what were the true facts contradicting the oppositions’

perpetration of a hoax upon the court. This is where I could refer to unimpeachable evidence in

support that would contradict their brazen lies. (see attachment exhs., which contains a detailed

compilation of the extensive false declarations of defendants on record and the material facts in

contradiction).

However, for a reason that is yet to be explained, Judge Grogins refused to allow me to testify

(exh. ). Rather, instead Judge Grogins skipped hearing my position to rule against me in an

arbitrary and capricious manner, as if I had no right for my argument to be heard as to why my

relief was justified. Insomuch as if it was a foregone conclusion I am to be evicted from my own

property by the court without being giving a chance to plead my defense. Essentially, it seemed

like it didn’t matter if I was afforded an opportunity to plead my position, because the matter has

already been decided.

This constituted unfair treatment in a court of equity, as the court’s demonstration of showing ill-

will against me and with extending favoritism towards my opposition. Consequently, I am

complaining that my guaranteed rights to justice through a fair trial have been usurped by Judge

Grogins refusal to grant me my right to receive due process. Since Judge Grogins refused to

allow me to plead my position and state the ‘cause’ why the stipulation should be vacated.

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Insomuch as he blocked not only my ability to present what my case was about, but denied me of

my opportunity to bring to bear evidence to substantiate the veracity to my claims.

Essentially, Judge Grogins’ misused his discretionary authority to effectively circumvent me

from receiving my due process guaranteed by the fourteenth amendment to the constitution.

Thus, by Judge Grogins denying me of my right to be heard is blatant act of judicial misconduct

and is a violation of his official duty and the public’s trust. Essentially, by Judge Grogins’ refusal

to allow me to plead my position was a decision of ultra vires, and a violation of canons of

judicial conduct in section 100.3 that says:

“A judge shall perform the duties of judicial office impartially and diligently, (B)

Adjudicative Responsibilities.(6) A judge shall accord to every person who has a legal

interest in a proceeding, or that person's lawyer, the right to be heard according to

law.” (§ 100.3)

In regard to Judge Grogins’s handling of my cases, the confluence of factors of his judicial

conduct substantiates that the offending conduct was not only outrageously unfair, but clearly

improper and adverse to what is required for him to perform his official duty. Whereby, to such

an extent that it would appear to a detached observer as a partisan administration of justice.

Essentially, the improper conduct of Judge Grogins constituted a palpable and pervasive pattern

of unbridled favoritism, along with demonstrating hostile treatment towards me of wanton

prejudice. Consequently, all of the bias misconduct I endured from Judge Grogins’ siding with

the opposition has caused a severe emotional wounding and profound traumatizing. In fact, this

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experience of where the Court’s past support to affirm plaintiff’s evil ambitions to destroy my

life for their gain was destined to drive me to into early grave--that is until I fired my last lawyer.

In fact, due to my extremely poor state of health and onslaught of malicious assaults on my

psyche from wicked doers, I am emotionally devastated. Consequently, I am enduring a chronic

major depression and acute anxiety disorder with a perpetual posttraumatic stress disorder. Since,

my health has dramatically deteriorated due to the shockingly abusive mistreatment I endured

over the last three years from my opposition that Judge Grogins extended privileged treatment.

Then upon this emotional distress the opposition caused was further compounded by my own

lawyer’s malicious misconduct, which on face supports the devious agenda of my opposition.

Moreover my poor health is profoundly made worse by my inability to afford the medical and

psychological care that I desperately need; so as to uplift me out from this living nightmare.

Consequently, since Judge Grogins neglected to perform his official duty I have been denied

justice in a court of equity up until this point when I am appealing to another judge.

Thus, along with the suffering from my poor physical health I am contending with “reactive

depression.” This is where I feel emotionally downtrodden with intense feelings of helplessness,

where I dread in the near future I will be homeless and destitute, while now I am broke. Albeit

the direct result from having the property I owned whose revenue and assets I depended upon

literally stolen right out from under me and this court making it “legal.”

Wherefore, in consideration of the serious nature of stated allegations herein, and the possibility

of being proven as a material fact, this matter is of importance to be reviewed.

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Since, the conduct I am exposing is a pending threat to the public at large of this state. Thus on

face value this matter is of great urgency to be resolved for societal benefit.

The misconduct of these judge’s corresponds to Hammermaster 985 P.2d at 942) that says:

“the judges knowingly violated litigants' rights in numerous instances, thus evidencing a
pattern of misconduct…The Court found that this behavior violated Canons 2A, 3A(1),
and 3A(3) of the Washington Code of Judicial Conduct, by demonstrating a pattern of
intimidating and offensive behavior, ignorance or disregard of basic legal principles,
particularly in regard to sentencing and an ambivalence toward maintaining professional
competence in his courtroom…The court considered factors…
(a) whether the misconduct is an isolated instance or evidenced a pattern of
misconduct;
(b) the nature, extent and frequency of occurrence of the acts of misconduct.”

Essentially, Judge Grogins, constantly and continuously performed his official duty with a

profound lack of judgment that can’t be contributed to any innocent explanations. Rather, on

appearance his questioned conduct indicates intent to deprive my right to justice by disregarding

the standard according to the law. Insomuch as he blatantly misused his authority to interfere

with my right to receive a fair trial. This was carried out with palpable neglect, and outright

refusal to perform his official duty.

Not to mention Judge Grogins making outrageously improper rulings that appear to have been

with conscious intent. Of which were often contradicted by law and dedicated to further the

criminal activities of my opposition who are obviously not acting within the law to effectively

deceive the fact finder to Judge Groins not doing what he is duty bound to perform in the

administration of justice.

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This is where my opposition successfully misused the court to achieve unlawful gains through

conducting a “fraud on the court” to defraud me of my legal rights of entitlement to property.

Essentially their intent to improperly influence the court in its decision was achieved by Judges

Grogins not functioning as the neutral and detached magistrate. Even though the impartiality and

dedication to fairness he is to pursue in justice is guaranteed by the fourth amendment. At the

very least is seems as though he turned a blind eye, While it was so obvious that the conduct of

my opposition, and the lawyers to both sides shows on face value to suggest they acted complicit

in a scheme to defraud me out of my legal rights and lawful entitlements.

Insomuch as Judge Grogins acknowledged as a matter of fact the unsubstantiated bogus claims

of my opposition. Whereby through his rulings he consummated the opposition’s success in an

unconscionable scheme of unlawful deception; going by ruling on their word alone.

History

The plaintiffs in March 2004 enticed me with their credibility and promises for buying my two

lots of property for three million. (At the time I owed $980,000 in mortgages). I readily extend

special accommodations to plaintiff far beyond what is generally offered in a purchase contract.

This is because unlike other interested parties in my property, they enticed me with an offer I

could not refuse. This is where Pecunies promised me that even though they would buy the

property, I could still operate my farm store Purdy’s Farms and live above it.

Consequently, I as an act of good will, volunteered that I should contribute a $1,000.00 a month

towards taxes, because that seemed as a fair consideration towards their interests. The ability to

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stay was why I agreed to the three million, instead of demanding the four million that I knew the

property was worth. Since giving up getting the extra million was worth it to me, because it

would allow me to continue with my way of life. I could not be more pleased, and cooperated

with whatever they wanted to make it happen.

Consequently, on the basis of the above verbal promise they drew up various agreements of

intent, the first on March 27, then on April, 20, and again on April 21, when I received the first

loan of $20,000.00 (later made into a mortgage). Finally, they had me sign the attached

agreement dated May 27, 2004. As the ‘contract’ filed as their exhibit A, to my first eviction

action in Norwalk Housing Court. Ironically, this is the very “contract’ plaintiffs egregiously

breached on its face, by their willful noncompliance to its terms set forth in the bargain of the

promised business arrangement (exh. A).

Ironically, this agreement was initially misrepresented by them as to legally protect both parties’

business interests, which I believed was the basis of it being as wordy as it was. Yet, in actuality

this agreement unbeknownst to me states a completely different business arrangement than what

I was told it meant by their lawyer Steven Phillips. As it was Phillips who drew up the agreement

and had assured me that all of what was promised to me was incorporated in the agreement, and

everyone’s interests and rights were protected.

Insomuch as, I was told by Pecunies that I didn’t need to spend the money to hire a lawyer,

because their lawyer Phillips would also be “amicably” representing both our legal interests (as

is stated in the court records). I remember him saying amicably because I have spent a

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tremendous amount of time reflecting on what had occurred to have had allowed plaintiff to have

such power to have turned my life upside down.

Since, I have painfully come to realize that Phillips was in on their scheme to scam me through

fraud and deceit. (At the time I signed the agreement Mr. Philips just referred to the parts on the

contract about my loans; staying on the property; and showing me where it says I would be

receiving the $1,900,000.00, considering my $40,000.00 loan. As the $40,000 loan was not

something that I asked for, but Pecunies insisted that he wanted me to have the money, so I could

buy some flowers to put out at my farm store.

Unfortunately, I was manipulated not to feel the need to read over the contract, or have an

opportunity to reflect upon what the contract says, or have someone look it over. Thus, I was

deprived of an opportunity to consider if parts of the contract had a different meaning than what I

was told by Pecunies and especially Phillips. As I was naively relying of Philips who was

supposed to be representing my legal interests to point out anything that I should take notice of

what it implies. Insomuch as with considering Phillips being an officer of the court, I expected

that he was duty bound to be faithfully honest and responsible to me with providing me with my

legal support.

Yet, I painfully have come to realize that I could not have been more wrong than to have

believed what Phillips told me was true. Since he exploited my assumption that he was

compelled to adhere to the oath of integrity he swore upon to be licensed to practice law in the

State of Connecticut.

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Essentially, I was tricked into signing what I thought was an agreement to sell my property, of

which I felt was extraordinarily accommodating with affirming my particular interest.

Specifically, what was made especially appealing to me that it was promised to have a provision

I still retained rights to possession in the property to live and operate my commercial enterprise.

Rather, the contract states something completely different than what it was supposed to declare

of what I was promised. Such as where I would get only $200,000 at the time of the sale and

$100,000 each year thereafter, yet this arrangement had been proposed before and I had made it

clear that it was unacceptable. Especially since I needed a lot more than $200,000, just to

develop my land in Maine, not to mention, I would be giving up receiving the revenue I was

receiving from the rentals on my property.

In effect, the portioning out the payments over eighteen years meant I was planning on getting

my last $100,000 payment when I was 103 years old. Moreover, when it was discussed that an

outside buyer would probably not be agreeable to my continued occupancy, we agreed that if it

was sold to an outsider then it must be for at least four Million, and we would split the extra

million above the three million. Insomuch as Pecunies got me to agree to the three million

amount through his insisting it was only worth $3 million, considering I would continue to live

and operate my business on the property.

Whereby, upon first glance, the agreement is an unconscionable contract, as it is what it was

intended to be, a one sided agreement, implemented in bad faith, as an artifice to a scheme.

20
However, with blind sighted confidence in their intent to be fair-dealing, I signed the agreement

as an expression of my confidence with their ability to follow through with what they promised.

Yet, I was duped to sign over my rights, powers, and even the value of the equity of my property

to another party under the color I could stay. This is where I was contractually promised to net

$1,900,000.00 (after the approximate one million debt was met); or I would get 2.4 Million if an

outsider was to pay us four million for the entire properties.

However, plaintiff in their capacity as ‘management’ did nothing constructive, rather they

enthusiastically exploited this title to pressure me by imposing their absolute control. Even

without my receiving any benefit in return they substituted my rights of ownership with their

own, totally devoid of any quid-quo-pro factor in the equation of transference of right. Then to

add insult to injury, last April 2009, plaintiffs demanded from my tenants who were paying me

$3,600 to quit paying me rent and redirect their payments to them. This stopped my flow of

revenue that I was depending upon and was verbally agreed upon in shaping the agreement.

Essentially, Pecunies and his lawyer Steven Phillips duped me into signing an egregiously

misrepresented agreement as to its terms and meaning. Essentially, Phillips supported a

confidence scheme intended to defraud me and inflict devastating injuries. In addition, Phillips

obtained my signature on the quit-claim deed through some manner of fraud. Such as where it

was falsely presented for me to sign as being a part of all the paperwork corresponding to what I

was told was a loan from Pecunies.

Whereas, papers I signed had turned out instead to be for a mortgage on my own property

naming Pecunies as the “Lender” on my mortgage. On the ‘agreement’ I signed it stated it was

21
to be a loan from plaintiffs that was to be derived from a mortgage placed on my property. Yet, I

did not realize this because I didn’t read through the agreement before I signed it and believed up

to October 2009 that the fact I accepted a loan gave them legal right of owning 50%. As it was

the lawyers I engaged encouraged me to believe I was legally powerless to contest.

I was shocked when I was told in October 2009 that I had transferred the title from my name, as I

was never informed that this occurred. In addition when Pecunies attempted to bring the fact that

the LLC’s had the deeds in its name to bolster his position, he was abruptly stopped in mid-

sentence by Kaelin giving a ‘queue’ by saying: “OK.” Clearly, the transferred deeds was a

material fact they wanted me not to be privileged to know had occurred, lest I might raise this as

an issue of forgery or foul play.

Essentially, I was either tricked in signing the paperwork for the loan, or the other possibility is

that either the documents I signed were altered thereafter, or my signature was forged. In effect,

whatever the scenario that was played out for plaintiff to have obtained my required signatures,

the fact is that the transference was not what I agreed upon. Since, I was never even asked to sign

the deed to my property over to the LLCs. Thereby, since the title transference was without my

knowledge or authorization it is a product of statutory forgery.

The plaintiffs’ obscene sense of right of entitlement (albeit on the basis of having tricked me into

signing onto the said agreements) was that in 2006 they refused to be brought out of the contract

for $100,000. Later it was increased to $600,000, just to get the farm property back. This is

because but they still said it wasn’t enough money. At the time I was just hopping on getting my

22
farm back. At the time I was lied to by being told that at the closing of refinancing that Pecunies

and Watson each put up $125,000.00, but in actuality they got about $460,000.00 ( plus

imposing $17,000 for refinancing fees to get a much higher rate).

Philips drew up the papers

In effect, they were expecting me to cover the discrepancy created in the fiduciary accounting

from their act of embezzlement with bank fraud. However, at the time I believed I was paying

plaintiffs back for what they claimed they paid out, because my lawyer Aldamis backed up this

fraudulent claim that they put up their own funds. Yet, when Phillips sent the papers and I saw it

said if there was any dispute I would not have a right to a jury I became suspicious and I back

out.

The plaintiffs executed a calculated scheme to mislead me to gain an unlawful legal advantage to

swindle me out of my rights and powers to my own property. This was carried out in a

conspiracy through a pervasive pattern of fraud and deceit to rob me, even with the complicity

with all four of the lawyers I hired; since my own lawyers acted in furtherance of supporting the

agenda of the plaintiff, by constantly and continuously working adverse to my legal interests.

This manifested by my lawyers’ extreme and chronic dereliction of supporting my legal interests

and providing false testament of bogus facts. This was all dedicated to be in support of bolstering

the legal and scurrilous business agendas of my opposition to be obtained.

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Whereby, Katz was the last lawyer I have dismissed for ‘cause’, due to my conviction he was

double dealing, as is verifiable to anyone who would read the last letters he sent me in December

2009 (Exh ) this is when Katz said:

“Pecunies and Watson are now taking the position that they will no longer contribute
mortgage payments and a foreclosure is now possible. Of course, if the mortgage is
foreclosed, it will affect both pieces of property and the likelihood of you receiving any
substantial sums after a foreclosure sale are doubtful. It is my personal belief that one of the
pieces must be sold to substantially liquidate the mortgage which would reduce the carrying
costs and thereby make it possible to hold on to the other piece for a more advantageous
sale.”

“I have found you to be a difficult and stubborn client. You fail to understand the
realities of the situation that you have placed yourself in. You failed to grasp that your
prior agreements in Court, the judgments that were entered against you, your statements
and stipulations in Court, your failure to get proper representation before signing
documents and agreements and your misconduct in the last year or so by reentering the
property, and exerting control over the property and collecting rents to which you had no
legal right have put you in a position of severe jeopardy. Unfortunately, I have not been
able to convince you of your substantial exposure to the claims that Pecunies and Watson
are now making against you. “

Such a statement appears to have sprung out more from the mind of the plaintiffs’ lawyer. Since

it interfaces perfectly with what they want me to believe and do. While, what is said in the

communication is in no way adversarial to even suggest I have any legal position of

opportunities; except to agree to the sale of one property, just to pay off the debts that I never

occurred; and then have my ‘hat in hand’, to accept whatever plaintiffs determine is my half of

the equity left over after the sale of the second property.

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Now, with considering that a standard of misconduct that constitutes an act of fraud is the

concealment of that which should have been disclosed. So as it was with Katz’s contractual

promise of providing legal representation that was defacto implied would be prudent and

zealous; yet in fact was fraudulent. Rather, this afore stated letter on its face, can be construed to

be an act of an artifice to a scheme to ‘unduly influence’ me. As to be unduly influenced to do

acts I would never even consider by acting under my own volition. Albeit, an ambitious attempt

to unduly influence me to willfully agree to be a victim of a fiduciary crime, through deception,

intimidation, and moral coercion. Not to mention, Katz was attempting to install in me the belief

of fear of economic loss if I did not do what the opposition wanted I will lose everything.

Yet, what is most obscene with the legal advice Katz gave me in the letter was that it was an

attempt to abuse of the trust I extended to him as leverage to manipulate me. Thereby, to do

something that would not only devastatingly harm me financially, but would psychologically

scare me for the rest of my limited existence. Since for me to settle now for a couple of $100,000

and be without my cherished home and farm enterprise when I could of easily had over THREE

MILLION, plus my home, if I just sold my farm in 2001, or listed my properties on the open

market 2004 or thereafter, would tear open an emotional wound that I would never heal from.

My outrage of the audacity that Pecunies has of treating me as a pushover was never given a time

of respite or time to subside. Such as when after the first year he attempted to get me to sell both

of the entire properties for $800,000 by telling me I would be getting more than the properties

were worth. However, at this time the figures show with considering they want to sell of the

property with my home for $900.000 and the other property if it is reduced as much as my home

25
will fetch $1.8 million. Yet, with considering a lot more than 2 million is owed on both

properties debts are paid off, plus brokers fee, hardly anything, if anything at all, will be left over

to be split with me by Pecunies.

In effect, what Katz was advising me as my council that the law viewed me as the only one

acting in bad faith. Moreover that the only legal option I possessed was to agree to whatever

Pecunies was offering me, or the consequence was that I would lose everything. Exactly, the

same legal support I received from Donald Brown, when he coerced me to sign a stipulation,

without so much as having been handed it to read, when he told me:

“If you don’t sign this stipulation now, then they will have the ability to suck out all the
equity in your property.”

In addition, brown assured me he was going to be filing an action in a higher court in a few

weeks, so what I was signing now would not matter after this new action was filed.Clearly, such

aforementioned conduct by Brown constituted an intentional act of installing in me, a great sense

of urgency that I had to sign, right then and now. However, when I later enquired when the

action would be filed, Brown said that he could only do the work for me if I paid him

$20,000.00, even though he knew at that time I had very little money. Thus, by him demanding

$20,000.00 he knew I would not be able to meet his request. Consequently, Brown did not do the

action that he promised, so I hired Katz, and he did more of the same.

I have serious issues of major abusive mistreatment that I had endured from Browns ambitions

to beat me down, dominate and control me. This is where he had the audacity to act out with

malicious intent to interfere with my ability to prevail in court. Specifically, with the misconduct

26
of Brown to thwart a demand that plaintiff put forth as a requirement for them to allow me to

continue in occupancy and drop the eviction action. This was when plaintiff said they would

require at least $24,000 to insure that they were no longer injured by my fraudulently claimed

delinquency to pay my $1,000 rental obligation. To wit, even though it was known I had no

money I was able borrowed $24,000 at a very high rate of interest from a ‘private lender’.

Whereas, I was motivated to get this “painful loan,” out of desperation of saving myself from

being evicted. Not to mention, I was even willing to pay twice from the money I had to spend in

rehabilitation of all the extensive damage caused from the burst pipes and to give them the

advance rent that they demanded. (Of which it is beyond belief that my reliable heating system

happened to have stopped on its own while I was in Florida) This $24,000.00 was to pay money

for past rent and to be applied to future rents. Yet, Brown was avoiding applying the rent to

satisfy the stipulated requirement of plaintiff. In fact, the judge did not even know about its

existence and I had to insist that the court accept it.

For some reason, yet to be explained this $24,000,00 was held by the court and my stipulation

was not vacated for about five months. This was extraordinarily disturbing to me because each

month this certified check was held was accruing a very high interest. Then when I went before

the judge to get the check back, Kaelin said “we are holding it as a hammer upon his head.” To

wit I replied to the court: “When I last looked in the mirror this morning to shave, my head didn’t

look like a nail”

Then, the requirement to satisfy the court was that I had to show I had a lease for them to release

the check. As this was the only way I would get the money back if I showed a lease.

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Thus, I had Mr Gramacy drive in early from Florida to write up a lease because I was to live with

them on my property that they were paying rent to plaintiff. Although, Brown charged me $500

for writing it up he did not submit it to the court. In fact he then refused to provide me with a

copy of it for me to use in court even though I paid him $500, that was something I could have

done myself, but it was demanded it had to be from a lawyer, yet he refused to give me a copy or

submit to court and it took me a great effort to get the check back myself from the Clerk. As a

result of that finally abuse I hired his law associate Heisler to represent my interests, upon

Browns recommendation that he ‘specialized’ in housing matters.

Now with addressing the professional malfeasance of my last lawyer, Katz, he not only did not

do any discovery to counter this eviction action, as so it was with the scheduling order, dated

April 6th, 2009 ( exh ) This was the case management for the discovery to the pending action in

the Superior Court, that Katz handled. This is where all the scheduled time to complete

discovery and submit the trial itinerary has already lapsed at the end of last year for this litigant.

Consequently, this litigant’s adversary, the plaintiff to this action can move the Superior Court

that this litigant should be precluded from doing discovery. However, the fact is that defendant

probably needs to subpoena the records of the bank that wrote the mortgage to Pecunies as he is

named as the borrower. This bank M&T, put a two million lean on defendant’s property where

the open-end mortgage has been met, and now the properties are going into foreclosure.

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Moreover, when Katz first filed the action in Superior court against plaintiff, fraud was

mentioned in the numerous elements composing the cause of action. Yet, Katz lied to me, saying

he had to amend the petition, because the time restrictions for fraud had lapsed and the only

standing I would have would be for contractual breach.

Yet, this is a bold faced lie and fraudulent misrepresentation of a material fact, which I was

relying on. Since, contracts in Connecticut have a six year statute of limitations. Instead, the

pleading is now confined to a general cause of breach of contract, and was needlessly scheduled

for a complex litigation trial in 18 months. Yet, dissolution of a corporation can be obtained by

an injunction that can be heard in a matter of less than a month upon its application when fraud is

the cause of action.

Clearly such outrageous professional misconduct can’t be contributed to innocent explanations;

rather it indicates that collusion occurred. This is with the wanton acts done by all my lawyers, to

support the other side’s ability to achieve their business goals. Whereby, perverting the judicial

process and contract law through foul play, maliciously misapplied for unlawful self gain; albeit

at the life devastating detriment of imposing an emotional nightmare on a frail senior citizen.

Although what bothers me most is with knowing that this nightmare I have been entrapped in

was facilitated by my good nature to be kind and generous to plaintiff. Since I knew that I gave

them a price well below market, and was willing to do whatever they wanted to smooth their

way.

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Thereby, to support their ability to consummate the deal, not realizing the affect my trusting

them would have on threatening to shorten my life. As I am absolutely, convinced they would be

delighted if I dropped dead from a heart attack that triggered a stroke that they caused.

Since they wouldn’t have to beat me down anymore and this would lock in their efforts of

preventing me from standing up to them, or contradicting their lies. In effect, finally eliminating

an obstacle that has long stood in their way of getting what they wanted.

Insomuch as my dropping dead, is a medical fact that I am warned can occur, due to my

biochemical disposition of having high levels of adrenalin and cortisone in my body. Since this is

the direct causation of plaintiff’s five year campaign of terrorizing me that has made me neurotic,

as they have made me very anxious, frustrated and emotionally distraught.

In effect, I worry constantly. This is where my mind has become obsessed and fixed at being

constantly focused at how I have been outrageously abused, exploited and mistreated. Not only

from plaintiffs malicious assaults to intimidate me into submission, but from the obscene

mistreatment from all four of my own lawyers. It seems as though those whom I trusted, have all

stabbed me in my back in return. Albeit compounded by the injustice I have received from the

courts that believe anything plaintiff says. Yet, when I ask to testify as to what the true facts are,

the court denied my request to be heard.

Consequently, I feel persecuted and downtrodden, while all the malicious abuse I have received

compounds upon each incident. This is from the all the threats and other malicious mistreatment

I have endured that has been directed at me by wrong-doers to have the desired result of causing

30
devastating injuries. Consequently, causing me to be constantly entertaining feelings of intense

aggravation, frustration, worry and horror. This is where my mind is fixated on being the

recipient of obscene abuse, exploitation, and mistreatment that I received from plaintiff. Along

with those who support their efforts that have made my life miserable, and caused me to feel I

was constantly being beaten up my abuse and persecution.

As a result of the constant agitated anxiety and the frustration from never receiving any justice, I

am extraordinarily annoyed at myself for signing what I did. This is for allowing others to

exploit me, and run roughshod over me, due to my trusting them. Since I am entrapped within a

predicament where I feel vulnerable and fear I am on the blink of becoming homeless by blindly

believing in the integrity of others . . . that has resulted in transforming my life into a living hell.

These are miserable feelings I have turned this inward, being annoyed with myself for allowing

things to happen where I am now being victimized.

Consequently, I experience reactive depression, where I now feel helpless, and without any

power, or hope that things will get better. Rather, if not but for someone who came into my life

who has given me hope that I can prevail in court, I am sure I would now have been feeling as if

my life was going down the toilet.

Insomuch as I am facing the prospect of becoming homeless, unable to benefit from the unpaid

services of my health aid, and the pending loss of my land in Maine. Since the note is coming

due to the bank who gave me the loan to start the development of my land in Maine that I still

need to build its roads. Thereby, my only option to survive would be to become a ward of the

31
state and go into a nursing home to live out the rest of my miserable life. My horrible situation in

my life now is all contributed to the insatiable greed of plaintiff and those supporting his agenda.

Since the fact of my current situation is that plaintiff has usurped my wealth and drove me to be

in deep debt. Yet, before I did business with plaintiff, I planned to work my land as a farmer as

long as I was physically able and then I would retire and have the where-what-for-all to live

comfortably. However, although I have worked hard all my life I now don’t have the ability to

get quality medical care, since I lack funds for the co-pay. This is of great concern, due to my

frail health where on a daily basis I have difficulty breathing and entertain a state of malaise.

In effect, the plaintiff, Pecunies and Watson, acted in a conspiracy with accomplices, their

attorney Phillips and my attorneys Demetrois Adamis, along with Donald M. Brown and his

associate Abrim Heisler, along with my last attorney, Mark Katz. This was a conspiracy

perpetrated in a pervasive pattern of criminal activity, constituting racketeering and in violation

of RICCO. Essentially, they have acting in consort in support of achieving real estate fraud under

the artifice of a two year contract to buy the property.

Yet, even the buying option was dishonest since the three million dollar price, instead of the four

million it would bring on the open market. This was based upon a false promise to me that even

though I was selling the property, I could still stay on the property, and still serve my customers

in my farm store. In fact, the only concern of a threat to me that I thought I would ever entertain

might be a pending thunderstorm, when I would have to rush to bring in my flowers from getting

32
damaged. Yet, I never believed in this day and age I would be a victim of organized crime,

looting my wealth, and harassing me, to drive me out of where I always planned to live.

Whereby, plaintiffs deprived me out of my rights to my own property under the color of

Pecunies and Watson’s legal right, albeit fabricated through extrinsic fraud and misuse of the

judicial process. This is in accordance to U.S.C., which defines an act of racketeering in Title 18,

Part 1, chapter. 19, §1957:

“Engaging in monetary transactions in property derived from specified unlawful

activity”…. (F)(2) “the term “criminally derived property” means any property
constituting, or derived from, proceeds obtained from a criminal offense.”

Whereby, the plaintiffs’ misconduct corresponds to criminal conversion, embezzlement and

extortion. This is when without my knowledge, authorization, or with ever being informed

thereafter, the wrongdoers mortgaged my property for $1,480,000.00. Consequently, about four

hundred thousand is unaccounted as to what happened to it. Even though the agreement and

understanding I had with them was specific to my only having authorized a refinancing to get the

mortgage reduced from the rate of 8.5%. Considering that even if a checking account was set up

for the LCC’s, it is improper that I am not included as a principal since the LLC’s is half owned

by me. Also no meetings were ever held for me to have authorized anything. Thus, no party has

controlling interest to assign financial control or management thereof. Yet, now the wrongdoers

lawyer Philips is the trustee and entitled to a percentage of its revenue, 9exh )

Although in plaintiff’s court papers they explain that the partnership came about at the time I was

facing eminent foreclosure, and they bailed me out with their money and credit. Yet, nothing

33
could be further from the truth (exh. ). Since, I didn’t need their credit for refinancing, because at

the time they had approached me my mortgagers had offered me a retention agreement.

Moreover, since my prior existing mortgage was only $980,000 compared to the value of my

land, and with considering my revenue from rentals, social security check, and sales from my

farm stand, refinancing on my own and getting a good rate would have been a simple task. In

fact, I am sure I could have secured at the same time a better rate than ½% below the maximum

legally allowed rate

No foreseeable explanation can justify why Pecunies waited six months after the agreement in

May 2004 to get the new mortgage in November. Further contradicting the oppositions claim in

their pleadings for my eviction is that I took advantage of them to offset losing my property. This

is where they falsely claim that they personally had invested a lot of their own money into the

property.

Moreover, with falsely claiming that the property was incurring more of a burden of expense on

them each day, while I in return was interfering with their ability to sell the property. Whereas,

the mortgage they got does not show a rate; rather the note states that it is one half of a percent

below the maximum legal rate, which is hard to understand why they could not have gotten a

better rate. (On the other hand, outside of my receiving the $40,000, I hardly received any more

revenue from my property, since the agreement five years ago. Outside of my agreed ability to

collect $3,600 monthly in rents for four years, but I paid plaintiff $1,000 of this.

34
In addition, the wrongdoers abused their position as managers of the LCCs to collect numerous

rents from tenants on my property, including $1,000.00 per month from me. Since, they didn’t

deposit any of the rents that they collected in the accounts of the LCC’s (where I was a 50%

owner), rather they comingled the funds with their own accounts as their personal money.These

self serving acts of appropriating revenue generated from my property when they have no legal

right, constituted conversion. Insomuch as all of the rent checks they collected were deposited in

their business accounts; either Mercedes Benze of Greenwich or Watson Enterprises.

The wrongdoers committing extrinsic fraud when they lied in their eviction papers by stating I

never paid the $1,000 rent November 2004. I was consistently paying all of my rent from the

onset in to them (I have canceled checks to prove it) until April 2008. This was when they told

me to redirect my rent payment towards restoring the major damage that was done to my

apartment from flooding when the pipes in my apartment froze and burst in 2006, which appears

as though they may have deliberately made this happen.

The water damage had occurred when I was in Florida over the winter, and although I am

absolutely confident that I left the heat on at the time I left in the fall, when it was already cold,

for some reason yet to be explained, the pipes froze, burst and then flooded the apartment. At the

time I asked the wrongdoers to send an adjuster to restore the damage, but they claimed, there

was no insurance (unlike before when I was managing my own property and was covered). Thus,

in total I spent about $15,000.00 with replacing the damaged plumbing, kitchen cabinets, rugs,

furniture and restoration work.

35
Then, after the last time I returned from Florida in April 2009, the wrongdoers broke into the

apartment of my health-aid, Joanne Gramacy to change the locks for an illegal lock out. Then

when I asked for them to let us in they said they could not because they had lost the key.

Thereafter, it took them two days to let us back into the apartment, only after I had contacted the

authorities to force their compliance. Yet, Ms Grammacy was paying them monthly rents when I

was staying with her in Florida. The issue that the plaintiff had with her was that I was staying

with her, this was where they gave her notice to leave at the end of September for no other

reason but she was my health aid and they did not want me on my own property.

I only now have revenue of $613 from my social security check, yet, my car payment alone is

$583, no savings, my credit cards are all maxed out and I have been borrowing each month just

to pay off the minimum amounts. Essentially, I had borrowed many tens of thousands from

friends

Specifically, the original agreement was that the they would collect approximately $6,300 total

from most of my tenants, while I was entitled to collect $3,700 from four tenants However, when

I was in Florida one year ago the wrongdoers intimated my tenants out of fear they would abuse

their power of management and evict them if they did not quit paying rent to me and pay them

instead. Thus, they breached the agreement with conduct of extortion to deprive me from the

revenue from rents that I needed to pay them the $1,000 that they demanded. But when they took

me to court they stated in their papers that I never paid them anything.

36
Noteworthy, is that the mortgagor who encumbered my property was privileged to the

foreknowledge that Pecunies achieved title by filing, the very day this mortgage was signed onto

by parties and filed. Albeit, the County Clerk’s record before the mortgage indicates conveyance

was achieved upon my acceptance of a second $20,000.00 mortgage applied for by Pecunies.

This is where 10 days before, and without my own representation, I signed onto a quit-claim on

the day I received the second $20,000.00.

However, I was told that they would be getting another mortgage to reduce the current 8.5.% ,

rate for their ability to buy the property. In addition, I was told to sign a paper after the afore

mentioned agreement of reducing my interest to 50% by their lawyer Philips who said that it was

necessary for them to get the mortgage and after they got the mortgage they would change it

back to my 100% ownership, which they later out right refused to do. This was presented to me

that the loans would be in exchange for my entering into an agreement through the setting up of

LCC’s so they could have the legal authority to be business managers of my property. This is

where I was told that the LCC’s would first list me as 50% owner for practical purposes,

thereafter my ownership would later be changed to 100%

Consequently, Pecunies authority of title was based upon his being a partner in two LCC’s that I

signed onto as holding 50% of its shares. Thus, this raises serious questions as to what if any of

the papers of the said LCC’s the lender was going by in its loan application to determine the

authority of the principal parties composing the LCC’s. Moreover, why was no due diligence

done by the mortgagor to identify the legitimacy of the right of title to my property. Since, my

37
having 50% ownership in the LCC, made my authorization mandated for any business decision

of the LCC, such as with taking on a large debt.

Whereas by face appearance of the documents corresponding to the tile of right to Pecunies was

achieved that day by issuing the prior owner (me) a $40,000.00 loan that was written into the

mortgage as Pecunies was identified as being the “lender;” as opposed to almost every other

instance the obtaining right of title to a property is through its purchase, not by issuing a

mortgaging.

Noteworthy, is that it appears the property debt at the time was about $950,000.00, and my

$40,000.00 loan was written into the mortgage at the rate of 6%. Pecunies and Watson were each

identified as borrowers to receive one million each from M&T as an open-end loan established

by a two million lean on my property. On the mortgage where they signed it states that they are

attesting to be the sole owners of the property where Pecunies signs as the executive director of

RKD Ventures. I do not find my signature anywhere on the mortgage. However, it is on a quit

claim that was witnessed by two individuals in the Mercedes Benz office owned by P&W and by

Steven Philips, their lawyer, who misrepresented whatever I signed as either paperwork for the

$40,000.00 loan that turned out to be a mortgage, or to assist P &W to get refinancing on the

properties This is where I signed on two “Quit Claim Deed” where I am identified as : the

releaser, for consideration paid, does hereby grant to R.K.D VENTURE TWO… with quitclaim

covenants all the right, title, interests…”

38
Consequently, although I was paid $20,000.00 for each property it was money received

identified as being a part of the mortgage where it states I am to pay a 6% interests. Although I

was paid from the lending bank, it was money produced from a mortgage on my property. Thus,

the quit claim is subject to be summary set aside, according to the “Uniform Fraudulent

Transference Act’ that requires payment of a ‘fair consideration’ for real property. Consequently,

because it was clearly a bad title with a defective chain of title no innocent explanation can

justify why M&T would have produced the deed trust.

Especially, as in this instance, where the mortgage shown the consideration paid was only just

about 1% of its market value, hardly a consideration of a meeting of minds of a quid-quo-pro.

Rather, more of an indication of the possibility that the mortgagor acted in complicity with

Pecunies through intentional neglect to verify the legitimacy of his right to tile to receive one and

a half million dollars on the basis of showing my signature on some documents, in absence of

having a bill of sale.

However, beyond the fact that I was a 50% principal of the LCC, I was not consulted, authorized

or informed about this loan, the condition of the purpose of the loan was violated. Insomuch as

on the grid note states:

“Purpose of the Loan…(b) that all loans shall be used for business purpose, and not for
any personal, family or household purpose…”

M&T on November 18th, 2004 lent to R.K.D. Venture LLC (LCC), the sum of $1,000,000.00. In

addition, also on November 18th, 2004, M&T lent to R.K.D. Venture 2, LLC (LCC2), the sum of

$480,000.00. The total amount of $1,480,000 dollars was assigned to and received by Pecunies,

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the representative of the LCC and LCC2, as its “executive manager.” This is where Pecunies

signed onto the two loan instruments of an “open-end mortgage” with MTC on the disputed

property on King Street.

In effect, these open-end mortgages allow additional monies to be borrowed against the property

put up as the assets to provide the security for the loans. This money was loaned with a promise

by the LCC and LCC2 (mortgagors) of a pay back of the outstanding principal with interest to be

calculated as one half of one percent below the maximum legal rate that was not identified in the

instruments filed with the Town Clerk’s office (exh. ). Yet, Pecunies authority to obtain the

mortgages was without MY authorization as the legitimate owner of the property. Rather, this

was a product of fraud and deceit.

Insomuch as this loan was achieved by a scheme and an artifice, and conversion to affect a

fraudulent conveyance and fraudulently obtain the said mortgages. Thereby, to defraud me out of

my rights and powers to my own property.

Complaint against all the Lawyers!

My complaint against my lawyers is of them being in collusion with the other side. Since, the

historical facts and circumstances supports the conclusion that they have acted in concert and

separately with the plaintiffs. This is for the furtherance of plaintiffs’ ability to achieve a

common goal shared with all the lawyers. Thereby, to affect the causation of my being deprived

of benefiting from affirming my legal opportunities and property rights of entitlements.

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Consequently, I am complaining herein about the professional misconduct of each lawyer as an

individual actor. This is where I will show how they acted to interfere with my legal rights to be

implemented. Thereby, through their neglecting to perform in a reasonable manner considering

their skill, knowledge and aptitude as being licensed lawyers. In effect, they perpetrated

misconduct under the color of being “officers of the court,” where they not only egregiously

violated the standards of professional conduct, but participated in a criminal enterprise.

Whereas, my lawyer’s violated the trust I bestowed upon them and the professional duty of

responsibility that they owed to me as their client. This is manifested by their dereliction to apply

the law in an appropriate manner to the matters in dispute and with their affirmative action’s that

benefited the intent of the opposition to perpetrate a hoax on the court; as well as with perverting

the authority of the court to further their scheme’s ability to succeed. Thereby, all these lawyers

misconduct made possible the evil intent of the opposition to cheat me. This is by perpetrating

fraud and deceit through a scheme and artifices. Since, if any of these lawyers were honest

and/or forthcoming at the very early stage the agreement would have been duly dissolved as an

unconscionable contract, deemed unenforceable in a court of law.

Essentially, my lawyers enthusiastically acted to deny me of my right to receive justice of equity

in State Court and prevent my eviction based on fraudulent misrepresentations of material facts.

This was manifested by their perverting their discretionary authority as if their professional

misconduct is beyond reproach. Thereby, to deprive me from having my legal rights upheld,

which they substituted by acts to consummate the interests of my opposition. As a result, my

legal right of entitlement to my own property was usurped.

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Clarification of the lawyer’s performance of judicial misconduct is readily validated as being a

material fact upon a review of the record to the proceedings corresponding to the eviction action.

In fact, just a cursory view upon the court records shows a material fact of judicial wrongfulness

was performed in a chronic, extreme and pervasive pattern. Consequently, the confluence of

factors of their judicial misconduct substantiates that the offending conduct not only constituted

gross dereliction of duty, but clearly was improper and unlawful. Whereby, to such an extent that

it would appear to a detached observer privileged to the facts that my lawyers acted as double

agents. Thereby the lawyers manipulated the authority and the records in the courts to pave a

road of credibility to the bogus claims of the opposition’s arguments. In effect, all my lawyers

mislead me to believe that plaintiffs are justified as a matter of legal right to entitlement. Except

Katz when he first was hired him had told me I had a case, only later to falsely tell me he found

out that statue of limitations had expired.

Whereas, the improper conduct of all of my lawyers constituted a palpable and pervasive pattern

of unbridled support for the opposition’s interests. Consequently, all of the misconduct I endured

from the malfeasant intent of the wrongdoers and the lawyers has caused a severe emotional

wounding and traumatizing. In fact after I was coerced to a buyout containing al the terms

Phillips demanded for a settlement I went to their office to consummate.

Yet, with no explanation except that plaintiffs felt they could get more out of their scheme that at

one time he said I could buy myself out of the agreement for $100,000, to wit he. Even though I

signed a settlement to dissolve the LCC I agreed that they could keep about 380,000 plus another

approximately hundreds of thousands- they already collected rents. This was misrepresented by

Adamis as only costing me $100,000. This was explained that through mismanagement of the

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mortgage a lot of money was imposed on the mortgage with penalties of hundreds of thousands

of dollars.

Thereafter, Steven Philips, lied and said he never agreed to the buy out to even though the

bargain had already been worked out an on papers that my lawyer, Aldamis drew up. I was upset

and told him: “your soul is going to burn in hell” to wit, he told me as he was walking out the

door to leave said “drop dead Del.” This was witnessed by my friend Joanne Gramacy and my

lawyer Adamis. Consequently, it occurs to me nothing would please the opposition more than if

all the aggravation and worry that they have imposed on me causes me to have a heart attack and

drop dead. Insomuch as my lawyers have stated for the court record, verification of the bogus

claims of the opposition. This is on the history of my business dealings with them to provide

them with a facade of credibility.

In fact, due to my extremely poor state of health and onslaught of malicious assaults on my

psyche from evil doers, I am emotionally devastated. Consequently, I am enduring a chronic

major depression and acute anxiety disorder with a perpetual post traumatic stress disorder.

Since, my health has dramatically deteriorated due to the shockingly abusive mistreatment I

endured over the last five years from the evil intent of the opposition to injure me. Then upon

this emotional distress they caused was further compounded by my own lawyer’s malicious

misconduct that on face supports the devious agenda of my opposition. Moreover, my poor

health is profoundly made worse by my poverty and inability to pay for the quality medical and

psychological care that I desperately need; so as to uplift me out from this living nightmare.

Thus, along with the suffering from my poor physical health I am contending with “reactive

depression.” This is where I feel emotionally downtrodden with intense feelings of helplessness,

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where I dread in the near future I will be homeless and destitute, while now I barely can get by

after being driven off operating my farm stand on the road. Consequently, I have a sign that leads

up a road to where I have only a couple of items for sale, when last Friday I only had two

customers the entire day. Albeit the direct result from having my rights of ownership of my

property whose revenue and assets would have supported me for the rest of my life, literally

stolen from me by those named who acted in complicacy to make it “legal.”

Wherefore, in consideration of the serious nature of stated allegations herein, and the possibility

of being proven as a material fact, this matter is of importune necessity to be investigated.

Since, the conduct I am exposing is a pending threat to the public at large of this state.

Thus on face-value this matter is of great urgency to be addressed by the laws of the land for

societal’s benefit. Thereby, to give a warning to others out to exploit the trusting nature of our

seniors that their misconduct will not be tolerated, and they will be held accountable for their

criminal intent.

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Yours, truly,
Dated: January 29, 2010
To: Robert Kaelin Defendant’s residing until April 3, 2009
Dena M. Castricone
Murtha Cullina LLp
CItyPLace I-185 Asylan Streeet
Hartford, Connecticut 06103
Tel: 860-240-6000
Fax: 860-240-6150
Defendant, Delmo L. Zanette, pro-se
____________________________
1353 King St
Greenwich, Conecticut 06830
914-844-0244
Delmo Zannette
c/o Steven Gramacy
127 Bird of Paradise
Palm Coast, FL 32137
914-844-0244
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