SUPREME COURT OF THE STATE OF NEW YORKAPPELATE DIVISION: SECOND JUDUCIAL DEPARTMENT

In the Matter of Michael Krichevsky, INDEX NO. 0-20755-14Falsely Accused, Claimant, ;

Appellate Division Dojbket-against- No 2015-01324

Elena Svenson Respondent. FIRST SET OFINTEROGATORIES ANDREQUEST FORADMISSION

PUBLIC NOTICE TO ATTAORNEY GENERAL OF THE STATE OF NEW YORK ANDCORPORATION COUNSEL: THIS MATTER IS OF GREAT PUBLIC INTEREST AS ITRELATES TO ABUSES OF FAMILIES AND CORRUPTION BY THE JUDICIARY IN

KINGS COUNTY FAMILY COURT

MADAM:

PLEASE TAKE NOTICE that Michael Krichevsky under duress expressly rebuts

presumption of Neutrality, Justice and Fairness toward him, forced to self defend against crimes of

Criminal Harassment, False Arrests and Imprisonments, Financial Genocide, Barratry and

Personage by licensed state actors requests that the Respondent answer under oath, in seriatim, in

accordance with Article 31 of the Civil Practice Law and Rules, the interrogatories and requests

for admission contained herein:

DEFINITIONS AND INSTRUCTIONS

A. As used herein, the word "person" means any individual, partnership, association, joint

venture, corporation or other business operation.

B. As used herein, the terms "document" and "documents" include, but are not limited to,

books, records, financial statements, letters, telegrams, notes, memoranda, calculations, diaries,

worksheets and drafts, originals and copies, and other recordings, from whatever source and any

material underlying, supporting or used in the preparation of any documents.

C. As used herein, the terras "identify", "identity" or "identification":

(a) when used in reference to an individual person means to state his full name and present or

last-known address and his present or last-known position and business affiliation;

(b) when used in reference to a business operating, firm, corporation, partnership, jointventure or association, means to state its full name and address; and

(c) when used in reference to a document, means to state the date, author, recipient, type of

document, (e.g., letter, memoranda, report, etc.) or some other means of identifying it, and the

present location and custodian of the original document.

D. As used herein, the term "state whether" means (i) to provide a "yes" or "no" response to

the inquiry, or (ii) in the event you cannot provide a "yes" or "no" response, to set forth the reason

or reasons you cannot so respond and otherwise respond -fully and accurately in accordance with

the information you have available to you.

E. As used herein, the term "set forth" means (i) in the event the inquiry asks for specific

names, numbers, dates, items, or other specific designations, to state or list such names, numbers,

items, dates, or other designations, or (ii) in the event the inquiry asks for information other than

specific names, numbers, dates, items or other specific designations, to provide in full detail the

information requested.

F. As used herein, the terms "and" and "or" shall be read to mean "and/or".

G. As used herein, the term "Respondent" shall be read to mean ELENA SVENSON, and

her agents, servants, and employees.

MODE AND DETAIL OF ANSWERS

In answering each interrogatory:

AA. Identify and produce each document requested, or relied upon or which forms the

basis for the answer given or which corroborates -the answer given or the substance of which is

given in answer to the interrogatory; sign and notarize your answers and admissions.

BB. In answering these interrogatories. Respondent is requested to furnish all information

known or available to her regardless of whether this information is possessed directly by

Respondent or by her agents, employees, representatives, investigators, by Respondent's present or

former attorneys or their agents, employees, representatives, or investigators, by Respondent's

affiliates or predecessors, or by Respondent or with which Respondent is in any manner affiliated.

CC. If any of these interrogatories cannot be answered in full, answer to the extent

possible, specifying the reasons for Respondent's inability to answer the remainder and stating

whatever information, knowledge, or belief Respondent has concerning the unanswered portion.

DD. These interrogatories are continuing in nature. If, after answering the interrogatories,

Respondent obtains or becomes aware of any further information responsive to these

interrogatories, Respondent is required to make a supplemental interrogatory answer.

EE. If any information requested by these interrogatories is claimed to be immune from

discovery on the grounds of privilege, the basis of the privilege and a description of the

information sufficient to enable a court to decide if the privilege has been properly invoked should

be specified.

FF. If the information furnished is not within the personal knowledge of the Respondent

state the name of each person to whom the information is a matter of personal knowledge, if

known, and, if not known, state the source of the Respondent's information and the grounds of her

belief.

INTERROGATORIES AND REQUESTS FOR ADMISION

1. State whether you were at any time or are under psychiatric treatment until present, and if

the answer is "yes," submit any document supporting your answer.

2. State whether you were at any time during the parties' litigation under any medication,

which would impair your sanity or common sense judgment, and if the answer is "yes," submit anydocument supporting your answer.

3. State whether you consulted any attorney or anyone assisted you in preparation of your

affidavit, Exhibit A.

4. State whether you are aware that YOU cannot lawfully benefit from something that was

created by fraud or unclean hands.

5. State whether your attorneys or their staff; or anyone who connected you to your attorneys

implied to you that attorneys can manipulate the court and outcome of litigation in your favor.

6. Identify all persons having first-hand knowledge of any material fact alleged in your

affidavit, exhibit A, and, with regard to each such person, list the address with phone numbers,

state -what they know about each such fact, how and when they came to know it.

7. Explain why you failed to state in this affidavit, exhibit A, what you stated under penalty

of perjury during 2013-2014 contempt proceedings (under current appeal) to Mr. Fasone and Mr.Milsap on the record, to wit:

A) that you (Svenson) spoke with the condominium management company worker and the

worker told you mat Mr. Krichevsky is collecting $3000 monthly in rent;

B) that Mr. Krichevsky owns two properties that could be sold to satisfy his child support

obligation;

C) that Mr. Krichevsky bought a new car.

D) that some person(s) saw Mr. Krichevsky in restaurants, therefore his is having a lavish

lifestyle while the child is still desperately needs psychological or psychiatric treatment, but lacks

the money.

8. State whether you were aware and had any proof of the facts listed in ^ 1 A, B, C, D above

in this interrogatory at the time of preparation and signing of your contempt petition in 2013.

9. State whether you consulted any attorney, or court clerk who prepared your contempt

petition; or anyone coached you to testify with those facts listed in If 7 A, B, C, D above in this

interrogatory.

10. State whether you consulted any attorney, or court clerk who prepared your contempt

petition; or anyone coached you not to write these facts in your contempt petition while you told

these facts to the person preparing contempt petition.

11. Explain why in 2013 in reply to Krichevsky's 2013 petition to modify the child support

you second time cross-filed contempt petition, but not before while you knew that Rrichevsky

does not comply with Fasone's order from 2010.

12. Admit that Mr. Fasone on the record directed you to go to child support collection office

located in Kings County family court and file contempt petition in 2013 after Krichevsky lost his

unemployment insurance and filed petition to modify his child support.

Admitted: Denied:

13. Admit, that if true, facts listed in \ above in this interrogatory were material, relevant and

necessary to show the court that Mr. Krichevsky willfully failed to pay his child support because

he was able.

Admitted: Denied:,

14. Admit, that if true, facts listed in ^J 7 above in this interrogatory would also be material,

relevant and necessary now to show this court that Mr. Krichevsky is able to pay expenses of

appeal.

Admitted: Denied:

15. State whether you are aware that inconsistency in your testimony would amount to actually

changing it, hence perjury.16. If you changed your testimony, explain why you failed to notify this court and me that you

changed your prior testimony and on what ground or fact.

17. If you deny request for admission of the ^[14 above in this interrogatory, state on what facts

or ground you rely this time to deny the admission.

18. If your explanation to fflf 15, 16 of this interrogatory that you forgot to mention these facts

(listed in If 7 A, B, C, D) in current affidavit, would you like to amend this affidavit, exhibit A and

list these facts so as to be consistent with your prior testimony to Mr. Fasone and Mr. Milsap on the

record?

19. State whether you knew during 2013 - 2014 contempt proceeding that the properties you

are mentioning in your affidavit, exhibit A, are in foreclosure from 2009.

20. State whether you wanted to mislead the court with a statement that "the properties could

be sold to satisfy the obligation of the child support."

21. State whether you consulted any person who advised you that properties in question even

in foreclosure could be sold by Krichevsky for profit, which would satisfy his purported child

support debt, and, with regard to each such person, list the address with phone numbers, state -what

they know about each such advice , how and when they came to know it.

22. State whether in your opinion it would be fair to Mr. Krichevsky to sell his property and

become homeless.

23. State whether, in your opinion it would be possible and fair to Mr. Krichevsky while

homeless have a job and pay the child support.

24. State whether Mr. Fasone or Mr. Milsap; or your prior attorney Jonathan Levoritz or Mr.

Katkalov; or any other person communicated to you in any way that you could safely disregard

order of Mr. Fasone directing you, Svenson, to file financial disclosure affidavit for the purpose of

supporting your contempt petition,

25. State whether Mr. Fasone or Mr. Milsap inquired as to why you disobeyed Mr. Fasone's

order to file Financial Disclosure Affidavit during 2013-2014 contempt proceeding.

26. Explain why you willfully failed to obey the order of Mr. Fasone directing you to file

Financial Disclosure Affidavit during 2013-2014 contempt proceeding, exhibit C.

27. State whether Mr. Fasone or Mr. Milsap inquired as to why you failed to rebut my

affidavits in 2013 - 2014 contempt proceeding,

28. State whether someone advised you to disregard my affidavits from 2010, and particularly

during 2013 - 2014 contempt proceeding without any negative consequences to you.

29. State whether you were aware that you have to rebut my affidavits.

30. State whether you were aware that my averments, if unrebutted, by operation of law would

be deemed admitted in my favor by the court and your contempt petition would be dismissed.

31. Admit that you willfully failed to rebut my affidavits in two contempt proceedings filed by

you without any negative consequences to you such as dismissal of your petition for contempt.

Admitted: Denied:

32. Explain why you failed to rebut my averments in my numerous affidavits that child support

order is VOID for fraud upon the court due to perjury by your attorney Yonatan Levoritz and you.33. State whether you perjured yourself at any time during the parties' litigation, includinglitigation in bankruptcy court.

34. Explain why you NUMEROUS TIMES willfully failed to reply to my REQUESTS FOR

ADMISSION, exhibit B.

35. State whether you would like this time, reply to my REQUESTS FOR ADMISSION and

produce your Financial Disclosure Affidavit with the copy of your latest income tax filing, which

was mandatory for my numerous child support modification petitions, which ignored by Mr.

Fasone or Mr. Milsap.

36. Explain why you would like or not this time to reply to my REQUESTS FOR

ADMISSION and produce your Financial Disclosure Affidavit with the copy of your latest income

tax filing, which was mandatory for my numerous child support modification petitions.

37. Explain why you failed to show the court how my non-compliance with purported lawful

order by Fasone damaged you.

38. Explain why you willfully failed to obey the order of the court directing you to file

Financial Disclosure Affidavit in my latest Petition to Modify the child support. Exhibit C.

39. Explain how alleged by you my "willful noncompliance with court's order" would remedy

your purported damage by your request for my incarceration.

40. State whether your request for my incarceration intended to harass me, hinder and delay the

resolution of the bankruptcy court proceedings where you are the Defendant and I am the Plaintiff.

41. Regarding your affidavit' statement in ^f 1. "That I am humiliated and insulted mother,"

explain with particularity "who, were, what, why when and how" you became "humiliated and

insulted mother."

42. Regarding your affidavit' statement in Tf 2. "I am making this affidavit in support of my

point of view that prove claimant's fraudulence, corruption, and dirty tricks ,and dishonesty," state

with particularity "were, what, why when and how" you came to "point of view that prove

claimant's fraudulence, corruption, and dirty tricks., and dishonesty" and how this even if true,

which is not, makes me able to pay for expenses of appeal, whereas you never paid a dime in

family and this court; and have no qualification for your opinion other than your wish to prevail

against me.

43. Go ahead and give your opinion with particularity (dollar amounts for each such

expense) as to how much would this appeal cost to Krichevsky listing and numbering each

such expense.

44. Regarding your affidavit' statement in 1J 3 "Claimant is the owner of the few properties:

4219 Atlantic Avenue, 4221 Atlantic Avenue - two family house, and 120 Oceana Drive West

Condominium..," explain how Mr. Krichevsky is the owner of the properties when in ownership

documents created by the State, he and you (Svenson on 120 Oceana Drive West) are listed as the

tenants on the land, for which tenants have to pay taxes (rent?) to the State and if tenants do not pay

the State (landlord?), the Sate would foreclose (evict?) on tenants.

45. State whether you are the owner of refrigerator or TV, for which you are required to pay

taxes to the State.

46. State whether you have information that Krichevsky pays taxes (rent?) and/or is able to pay

to the State.

47. State whether you are aware that these properties are in foreclosure and how in your

opinion, ownership of these properties would enable Krichevsky to pay for an appeal today.

48. Regarding your affidavit' statement in ^j 3 "also claimant owned all expensive furnituresilverware, lightings., TV, computers that we possessed together and peculate from apartment we

lived," list in particular number for each item its brand, date of claimants ownership, today's value

and provide supporting documentation, as well as explanation how these would help Krichevsky

to pay for an appeal today (such as selling everything to pay for appeal).

49. Regarding your affidavit' statement in 1f 4, "Claimant is driving mini cooper made about

2009 and look in excellent condition," state whether you have any mechanical skills such as "I am

fixing my own Toyota Canary, which I acquired from Krichevsky by fraud, and therefore qualified

to judge the excellence condition of his car," list the date the car was made and the date you orsomeone inspected it; list today's value of the car and how you came to know it; provide

supporting documentation, as well as explanation how that would help Krichevsky to pay for an

appeal today (such as selling everything to pay for appeal).

50. State whether in your opinion the car that Krichevsky is driving should be sold as

unnecessary luxury and proceeds are given to you so that you can shop Bloomingdales together

with Bergdorf and Goodman and Sachs 5l Avenue even harder and more often (as per bankruptcy

court discovery).

51. State whether you would like to stop shopping in Bloomingdales together with Bergdorf

and Goodman and Sachs 5th Avenue and save some serious coin to pay for the child's psychiatric

or psychological treatment today.

52. State whether you would like that Mr. Krichevsky produce the car to independent

mechanic to judge the condition of the car.53. State whether the almost 21 year's old child is able and going to any school.

54. State whether the almost 21 year's old child is able and working at any job giving the factthat Krichevsky does not comply with the child support absurd order.

55. Regarding your affidavit' statement in ^ 5, "In 2010 as soon as claimant find out that he

should pay $2045 per month of child support Claimant falsely reassured court that he (krichevsky)

was fired and called himself "disabled", state when, where and how Krichevsky "falsely reassured

court that he (krichevsky) was fired and called himself "disabled".

56. Regarding your affidavit' statement in Tj 5 "approximately for period between 2000-2009claimant made about $180.000-$250.000 per year" state whether you have any information that

Krichevsky saved or hided, besides the amounts of money that you (Svenson) as partner of

Krichevsky embezzled from him as per bankruptcy court discovery, any money to pay for an

appeal today.

57. Regarding your affidavit' statements in ^f 5 ".. .called himself "disabled" but never provide

any proof of disability", state whether you at any time requested from Krichevsky any proof of his

disability including in discovery in bankruptcy court.

58. Regarding your affidavit' statements in If 5, state whether you at any time requested from

Krichevsky any proof of his unemployment including in discovery in bankruptcy court.

59. Regarding your affidavit' statements in U 5, state whether you at any time answered

Krichevsky's numerous petitions for downward modification and how or when would Krichevsky

submit such proof when he was harassed by Mr. Fasone, Mr. Milsap and you with constant

contempt proceedings, including your harassment of Krichevsky in bankruptcy court.

60. Admit that you consider yourself a good mother and that you owe debt free corporative

apartment at 2620 Ocean Pkwy., Brooklyn, NY, where you live with your son.

Admitted:, Denied:

61. Given your opinion that Krichevsky is Aggressive, Abusive and Insulting Father, state

whether it was possible to sell this apartment or borrow from its equity to satisfy child's desperate

medical needs you continuously testified about during 2009 - 2014 Family Court proceedings

without waiting for Krichevsky to sell his properties in foreclosure.

62. Provide disclosure of medical doctor who diagnosed the child with any medical condition.

63. Given your opinion that Krichevsky is Aggressive, Abusive and Insulting Father, whereas

you are a good mother explain why you willfully disregarded 2009 order of magistrate Castaldi to

enroll the child in Medicaid.

64. Admit mat starting from 2010 you and the child enrolled or had an option to enroll in

medical coverage provided by the company you worked for at that time until present.

Admitted: Denied:

65. In regard to statement in fflf 6 and 7, you are requested to admit the Negative Observation

that as of this date, after a reasonably diligent search and/or investigation, neither you nor any

agents, employees, or representatives acting on your behalf are aware of any fact or documentary

evidence in support of these paragraphs.

Admitted: Denied:

66. In regard to statement in Yff 6 and 7, Corporation counsel, HRA litigation Department

and child support collection unit, you are requested to admit the Negative Observation mat as of

this date, after a reasonably diligent search and/or investigation, neither you nor any agents,

employees, or representatives acting on your behalf are aware of any fact or documentary evidence

in support of these paragraphs.

Admitted: Denied:

67. In regard to statement in ^f 7 "...(who is wittenstein's partner and friend) unlawful

business..." state whether your attorney Jonathan Levoritz and/or you sincerely believed and

expected that Mr. Wittenstein would continue conduct of alleged by both of you unlawful

business (whether it's true or not), risk losing his attorney license in order to pay you unlawful

child support from unlawful business, while Krichevsky litigate with State and you for 7 years

instead of managing his practice.

68. In regard to ^[8, state what qualification does Svenson have now to issue her medical

opinions about Krichevsky's disability.

69. In regard to fS statement"... complications such as weakness of one part of the body

limited range of motions of upper and lower extremities and -or slurred speech," you are requested

to admit the Negative .Observation that as of this date Svenson. did not medically examine

Krichevsky before making such statements.

70. In regard to 1(8 statement".., complications such as weakness of one part of the body

limited range of motions of upper and lower extremities and -or slurred speech," you are requested

to admit your disappointment that Krichevsky did not suffer a major stroke and lacks thesymptoms you would like him to have.

Admitted: Denied:

71. In regard to f 8 statement".. .claimant still able to provide his child with basic needs",

Corporation counsel, HRA litigation Department, child support collection unit and Svenson,

you are requested to admit Negative Observation that as of this date, after a reasonably diligent

search and/or investigation, neither you nor any agents, employees, or representatives acting on

your behalf are aware of any information that Krichevsky declined any job opportunity or is "ableto provide his child with basic needs."

Admitted: Denied:

72. In regard to fS statement".. .child's mother(svenson) due to harassment by Krichevsky..."

state whether your filing of contempt petition and your request to incarcerate Krichevsky would

constitute that Krichevsky is harassing mother Svenson.

73. In regard to ^8 statement".. .developed diabetes and should constantly take

antidepressant", state whether you failed to submit any proof with this affidavit to the court

because you believe that the woman does not have to provide any proof to the court when making

a statement of medical condition, while a man must, which is why you accuse Krichevsky in

paragraph^ 5 *',.. called himself "disabled" but never provide any proof of disability".

74. In regard to f 8 statement".. .developed diabetes and should constantly take

antidepressant", provide documentary evidence from the doctor or hospital,

75. In regard to 1J8 statement"... I am working hard to support our son financially..." state with

particularity from what hour until what hour per day and how many days per week you work hard

and at which job or business.76. Admit mat before you begun the child support proceedings in 2008, Krichevsky was

working 60 - 80 hours per week including Saturdays and Sundays; and his cell phone was 24/7 on

while you were not working.

Admitted: Denied:

77. In regard to f8 statement ".. .During all this time Krichevsky never made any effort to

communicate with our son," admit that in 2008 you obtained the order of protection prohibiting

Krichevsky to communicate with the child.

78. In regard to ^[8 statements "...child's mother(svenson) due to harassment by

Krichevsky. .."and "During all this time Krichevsky never made any effort to communicate with

our son," admit that Krichevsky from 2010 filed several petitions for custody and visitation while

you three times cross-filed for order of protection and two cross-petitions to hold Krichevsky in

contempt.

Admitted: Denied:

79. In regard to ffi[ 9 and 10, state whether you considered it reasonable and logical that

Krichevsky is shopping 99-cent store in order to save money to pay for the transcripts.

80. In regard to statements in Tfl 1, produce any evidence in support of your statements.

including number $9000.

Dated: Brooklyn, New YorkJune 18, 2015

Michael Krichevsky, Pro Se, requesting party4221 Atlantic AveBrooklyn, New York 11224(718)687-2300

Sworn to before meOn ,2015

Elena Svenson

NOTARY PUBLIC