Exhibits A

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IN NEW YORK SUPREME COURT

SEVENTH JUDICIAL DISTRICT

APPELLATE DIVISION

STATE OF NEW YORK

In the Matter of mandelqry,uncanditional relief owed toKevin Patrick Brady, pro #

EXHIBITS A

Pursuant to Wells Fargo Bank NA v Kevin Patrick Brady

Fourth Dept Docket # CA 14-00073Supreme Court Docket # 4419/09

NEWYORK STATE SUPREME COURTAPPELLATE DIVISION, FOI-IRTH DEPARTMENT

M. DOLORES DENMAN COURTHOUSE50 EAST AVENUE, SUITE 2OO

ROCHESTER, NEW YORK 14604

(s8s) s30-3100 Fax (585) s30-3247FRANCES E. CAFARELL

CLERK OF THE COI'RTALAN L. Ross

DEPUTY CLERI( OF THB CO1IRT

January 23.2014

.-..

Kevin Patrick Brady508 Locust Lane ,,.* ,,,.* _,.-, -East Rochester, NY 14445

Re: In the Matter of Wells Fargo Bank, NA v Kevin Patrick BradyDocket No. CA 14-00073

Dear Mr. Brady:

Please be advised that the papers received by the Court on January 17 ,2014, entitledNotice of Answer and Cross Motion, are being accepted only as a response to the pending motionto dismiss for failure to perfect timely the appeal in the above referenced matter because yourpapers failed to provide proof that the cross motion was properly served via personal service orby overnight delivery pursuant to this Court's rule 1000.13 (a) (3).

Very truly yours,

Ivan E. LeePrincipal Appellate Court Attorney

IEL/slEnc.pc: Jonathan E. Samon, Esq.

Merideth H. Smith, Esq.

:

I-twww courts. state.ny.usi ad4

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IN NEW YORK SUPREME COURTSEVENTH JUDICIAL DISTRICT

Wells Fargo Bank, NA

3476 Stateview Blvd.

Ft. Mill, S.C.29715 ptaintiff

V

Kevin Patrid< Brady, defendant

APPELTATE DIVISION

STATE OF NEW YORK

MOTION TO VACATE VOID JUDGMENTSAppellate Court # CA 14-00073

Supreme Court # 44lgl09

NOTICE

Please be advised that the annexed Motion to Vacate was filed in the Court above as ofMarch S,zor+. "hlf/The Motion requests this very protracted matter be assumed from the trial court forcontinued failures to observe and cpnfirm fraudulent mortgage documents, due processand equal protection violations, other controlling principles of law and ultimately putativeplaintiffs lack of capacity to invoke subject matter jurisdiction in the first place.

rhis matrer is made rerumabre * t/f/ {Answers, if any, must be filed in the Court on or beforeprovided to defendant in error on or before J

{ . Copies to be

TO THE COURT

Be it known that on 3lq /t I provided true and complete copies of alltheattached documents to the folbwing parties at the addresses identified..

Jonathan samon Lovell us LLp. g75 Third Ave, Naryork, Ny 1002a

I depose under penalty of law that everything contained herein is conect and truthful to the best of myknowledge, excepl for rnatters alleged on information and belief and I believe those matters to be true.

rl

Wn,cL(KEVIN PATRICK BRADY

508 Locust Lane

-'(AREN a*f;ffi$ochester NY 14445lo4yoh"d-At@h, ,&/"t/,No. flIsM624148(

Quolllled ln Monroe CounlyMy Comml$lon txptrer Moy 23, 2015

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Ft. Mill, S-C.29715 Plaintiff

V

Kevin Patrick Brady, defendant

Please be advised that the annexed Motion to Vacate was filed in

March fl,zot+. '/

/The Motion requests this very protracted matter be assumed from the trial coun for

continued failures to observe and confirm fraudulent mortgage documents, due process

and equal protection violations, other c-ontrolling principles of law and ultimately putative

plaintiffs lack of capacity to invoke subject matter jurisdiction in the first place.

I depose under penalty of law that everything contained herein is conect and truthful to the best of my

knowledge, except for matters alleged on information and belief and I believe those matters to be true.

NOTICE

Quollfled in Monroe CountY

My Commlillon Fxplr.6 MsY 23, 2015*a v/

APPELLATE DIVISION

STATE OF NEW YORK

MOTION TO VACATE VOID JUDGMENTS

Appellate Court # CA 14-00073

Supreme Court # 4419109

iri^rir fi ? ''i!14

AglElhi3,i ,+'l'isi i!rf !;{g{tr* eff ri'f *ibbvft A $-€ft i

KEVIN PATRICK BRADY

508 Locust Lane

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Ft. Mill, S.C.29715 plaintiff

V

Kevin Patrick Brady, defendant

APPELLATE DIVISION

STATE OF NEW YORK

MOTION TO VACATE VOID JUDGMENTS

Appellate Court # CA 14-00073

Supreme Court # 4419109

AMENDEDNOTICE

t z7 Copies to be

Ptease be advised that Motion to Vacate served on you fultlhas been amended and filed

in the Court above as of Marcn [[, ZOI+.

I

The Motion requests this very protracted matter be assumed from the trial court for continued

failures to observe and confirm fraudulent mortgage documents, due process and equal

protection violations, other controlling principles of law and ultimately putative plaintiffs lack of

€pacity to invoke subject matter jurisdiction in the first place.

Answers, if any, must be filed in the Court on or before

provided to defendant in error on or before

TO THE COURT

Be it known ,nu, onSh f-l mailed true and complete copy of all the attached documents to-.-|-----1-the following pafties b! regular US Mail at the addresses identified. Amended Notice was

mailed resular US Mail o" 3l fl ltI--T---r---r-

Jonathan Samon Lovell US LLP. 875 Third Ave, NewYork, NY 10022

I depose under penalty of law that everything contained herein is correct and truthfulto the best

of my knowledge, except for matters alleged on information and belief and I believe those

i_ic. #0'tC060i0r44tctary publiorstato of Nflv yfik

Quatified in MONROE,My Comrnission E)eirse 10E0lZ01q

matters to be Uue.

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APPELLATE DIVISION

STATE OF NEW YORK

In the Matter of mandatqry,unconditional relief owed toKevia Patrick Brady, pro #

EXHIBITS d

Pursuant to Kevin Patrick Brady v People of New York by Attorney Generaland Steven E. Feder Attorney

Fourth Dept Docket # CA 13-02202Supreme Court Docket # 2012-053

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NEW YORK SUPREME COURT

FOURTH JUDICIAL DEPT.

KEVIN PATRICK BRADY, petitionerMAR 2 * 2014

APPEI,I,ATE DT\rISION4TH BEPARTWTENF.C.

THE PEOPLE OF NEW YORK by Attorney General , respondent

STEVEN E. FEDER, Aftorney respondent

NOTICE

APPELLATE DIVISION

Kffiilffi. vffi#^'=OF NEWYORK

'\.1-fi T:* 'd'F

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BE lr KNowN that a motion has been filed in the court above tlV{W for an

EXTRAORDINARY WRIT OF ERROR based on an extraordinary series of dirty tricks,

life altering ministerial errors, and malicious due process violations by officers of New

York supreme court and the Department of Law.

The Court is asked to review the latest in a decade plus of government abuse, dirty

and courthouse thuggery manifest by a malicious summary termination, with preiudice,

of a facially meritorious pro se petition to supreme court by Judge Richard Dollinger.

The proceedings below were so defective as to be VOID on due process violence

alone. ln fact they rise to the level of extrinsic fraud. Having already been cheated out of

nearly $8,000 in filings fees and production costs, it rises to the level of 18 U,S. S 1346

HONEST SERVICES FRAUD.

Please note that

[1] Jurisdiction was properly invoked by proper pleadings. [2lthe relief requested was

mandatory; [3] the opposition by the State was jurisdictionally defective; disingenuous,

and a cover up that violated inter alia, NY DR 7-102( )(7) EC 7-5 EC 7-6 NY EC 7-26

an allegedly laMul, but unconstitutional manifestation of ABA Rule 1.6 at my expense

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[a] The alleged neutralfact finder [Dollinger] elevated a benign civil motion, sua sponte,

into criminal contempt inquiry, later feigned acknowledging the error, but imposed

criminal punishment anyway. NO HEARING WAS HELD

[5] State actors have again exploited an ambiguous 'pre-filing' order to the level of

extrinsic fraud. [6] Dollinger arbitrarily expanded it to relieve respondents from due

process mandates and to constructively block Brady from court completely.

'lJnder color of 'a quasi lavrrful 'pre-filing' order, unconstitutionally applied, they have

unanimously deprived Brady of access to court; to redress grievances; once minor, but

have grown extemporaneously and caused unfathomable, life-altering injuries.

New York courts and attorneys general clearly do not have a functioning grasp of the

constitutional limitations of 'pre-filing'orders and clearly do not care. This pro se victim

has repeatedly advised them of the statutory scheme and controlling legal precedents

that establish their wrongful interpretation of the order. They don't care.

[7] Owing to the subject matter ABA Rule 1.6 dictates that 'permission' will never be

granted for pro se's petitions. .

[8] They act under color of 'the Rule'to the level of extrinsic fraud.

[9] Dollinger acknowledged having received but ignored a post summary termination

Motion to Show Cause and refused to return my filing fee. The motion constructively

remains on supreme court docket at this time..

Pro se victim demands to be free from two [2] decades of 'anything goes' lawlessness,

consumer fraud, no win litigation and direct and indirect punishnents; including

unlawful incarcerations for lawful exercises of constitutional rights

The Court is asked to consider, in context, two [2]additional actions * pending review

by this Court at this time and declare that so many patently fataljurisdictionaldefects

cannot be coincidental.

NOTICES ATTACHED Brady v People of New York; [coram nobis]

Wells Fargo Bank, v Kevin Patrick Brady

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On Law Day, 2010 Chief Judge Jonathan Lippman lamented 'iudicial salaries must be

raised for the societal value of the work judges perform; for their incredible dedicatian

to the rule of law and well-being of the citizens of New York.

He said '[the PeoplesJ abitity to live the American dream is in question, that the

judiciary more than ever holds together the fabric of socieqr and our way of life,

fostering the rule of taw, protecting individuat liberties, and meeting the constitutional

mandate to provide 'equaliustice for all.

This pro se Americans protracted nightmare with the judiciary belies his every word.

ln so far as I have been shut down, shut out, unanimously punished and abandoned by

New York supreme court ON EVERY OCCASION cognizable remedies for me are

exhausted. This is ostensibly the only state judicial forum accessible'

I request a hearing to submit the proof supreme court cannot accept given Rule 1.6

Any allegation made here not clearly understood will, on demand,

More Definite Statement. Any relevant document which should be

will be made immediately available on demand.

be enunciated in a

included but is not

This Motion is made returnable to the Fourth Department op or befo," sfr/,/With copies provided to the undersigned on or before 2/27 ft

HOWEVER, PLEASE NOTE;

Although NO PLENARY HEARING WAS HELD BELOW, the November B, 2013 order of

Judge Richard Dollinger declares " frJespondents [the StateJ and their caunsel are notto respond to any papers filed or serued by BRADY in this or any other action he has

previously filed or may file in the future unless fapprovedJ etc. etc.

I submit this misfeasance to be infinitely unconstitutional, and duplicitous of Rule 1.6.

It exemplifies my two [2J decades of up close and personal experiences as a pro se

litigant in New York's Unified Court System.

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AFFIDAVIT OF SERVICE

Be advised that I Be@{yserved a true and complete copy of this Notice and Action to the

following pafties on the dates indicated, 5V t/S ftl*[Ct\

AAG Hilell Deutsch, Public lntegrity Officer

New York Department of Law

144 Exchange Blvd.

Rochester, New York 14614

Steven E. Feder, Afty I

-"j:i::ffi ;;,?,;.,, uJ *

J, +

Courtesy Copy

Monroe County Department of Law

39 W. Main Street

Rochester, 14614

I hereby depose that everything alleged herein is, to the best of my knowledge, correct and truthful except

for mafters alleged on information and belief and I believe those to be true. Nothing is intended to be

frivolous, harassing or completely without merit.

ln fact as a matter of numerous court records I have nevef filed any action in any court that legally or

constructively rose to the level of frivolous, vexatious, and/or completely without merit. I have not broken

any laws, unlawfully prosecuted and incarcerated myself, violated my own constitutional rights and/ or

destroyed my own livelihood,

ln the final analysis I have no complicity whatsoever for the decade plus of abuse[s] I have suffered from

officers of the courts AND I challenge every allegation to the contrary.

Kevin Patrick Brady508 Locust Lane

East Rochester, New York '14445

TONI LCOONUc. #01C06050144

Notary Publiostate of l'l€r , YorkQualifi€d in MONROE

My Commission Expire6 '!0n0/2014

'l"l r

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NEWYORK STAIE SUPREME COURTAPPELLATE DIVISION, FOURTH DEPARTMENT



(585) 530-3100 Fax (585) s30-3247FRANCES E. Carenill

CLERK OF TIIE COURT

Ar,au L. RossDEPUTY CLERK OF THB COI,JRT

Re:

March 3,2014

..:::

Kevin Patrick Brady I

508 Locust LaneEast Rochester. NY 14445

Brady v State of New York, et al.

Docket No. CA 13-02202

Dear Mr. Brady:

I am returning your motion entitled "Notice of Constitutional Violations, Abuse ofDiscretion and Continuous Obstruction ol.Tustice" because you failed to have your affidavitnotarized and did not provide a proper affidavit of service. Please re-serve all parlies if you re-

submit a compliant motion.

Ivan E. LeePrincipal Appellate Court Attorney

IEL/s1Enc.pc: Eric T. Schneiderman, Esq.

Merideth H. Smith, Esq.

www. courts. state. ny. us/ad4

SUPREME COURT OF THE STATE OF NEW YORK

9pp elts te Wtbisr 0 n, f ourtll Vu[ f cf s t 4 ep s r tment

DOCKET NO. CA 13-02202

PRESENT: SCUDDER, P. J., SMITH, CENTRA, FAHEY, AND PERADOTTO. JJ.

IN THE MATTER OF KEVIN PATzuCK BRADY, PETITIONER.APPELLANT,

V

PEOPLE OF STATE OF NEW YORK BY ATTORNEY GENERAL,STEVEN E. FEDER, ES Q., RESPONDENTS -RESPONDENTS.

Appellant having moved for permission to proceed as a poor person on the appeal taken

herein from an order of the Supreme Court entered in the Office of the Clerk of the County of

Monroe on November 20,2013,having applied for an order to show cause, and having moved

for other retee

Now, upon reading and filing the affidavit of Kevin Patrick Brady sworn to Decemb er 17,

2013, the statements of Kevin Patrick Brady received December 18,20l3,the notice of motion

with proof of service thereof, the proposed order to show cause, and all documents attached

thereto, and due deliberation having been had thereon,

It is hereby ORDERED that the motion is denied.

FRaNcps E. C.qrannll, Clerk -: -Entered: January 22, 2014

A Legal Center:

Pirrello, Missal, Personte & Feder2040 Ridge Road East

Rochester, I\rY 14622-2488Mario J. PirrelloPaul T, Missal (1933-2011)

Michael J. Personte

Steven E. Feder**also admitted in Florida

New York Supreme CourtAppellate DivisionFourth Department50 East AvenueRochester, New York 14604Attn: Court Clerk

RE: Kevin Patrick Brady vs.The People of New York byAttorney General andSteven E. Feder, Attorney

Ladies and Gentlemen:

I have received some largely incomprehensible papers, including an Affidavit, withregard to the above matter.

I respectfully remind the Court of Judge Gorski's standing Order, disallowing the

Plaintiffthe use of any Court in New York State without the specific permission of the ChiefJudge of that Court, with respect to his ex-wife, his previous custody actions, or anything related

to same. For the Court's convenisnce, I have enclosed a copy of that Order.

Inasmuch as the matter appears to have been submitted without the specific permission ofthe Chief Judge of the Appellate Division, it should be ignored and sent back to Mr. Brady.

Respectfully yours,

SEF/cbsEncs.

Telephone: (585) 544-7090Facsimile: (585) 544-7093Website: PMPFLegal.com

June 5,2013I

ht:

f,I

Steven E. Feder

A Legm$ Cem€er:

FfrreflXw, &&&ssmK, ffiews&Kefe & Feder?S4S Rie$ge Roact East

ft.oq:hester" $iY i4622'248&h{ario "}. FirrelloFaul T, Missal (1933-201n)

&'lichaetr J. Fersonte

Steven E. Feder'e{'also adrnitted in Florida September 9,2013

Honorable Matthew A. Rosenbaun;Supreme Court Justice545 Hall of JusticeRochester, New York 14614

Frances CaffarellChief Clerk, Appellate Division50 East AvenueRochester, New York 146A4

SEFicbsEncs.cc rv/encs: Kevin Patrick Bradv

Teneplione: (5E5) 544-709CI

Facsimile: {5E5) 544-7893

Website: FMPFn-egaX.corn

RE: In the Matter of Kevin Patrick Brad,r' vs.People of New York, et alIndex Number 2013-053

Dear Judge Rosenbaum and Chief tllerk Caffarell:

I received copies of the sornewhat incomprehensible documents sent to you by KevinPatrick Brady with regard to the above matter. *

First of all, I don't believe tirat the matter;s even a case that is before the Court.

Second of all, Mr. Brady is prohibited from using the Courts rf the State of New York atall in this fashion, absent specific pennission from the Chief Judge ;f the relevant Court in whichhe seek to proceed. Along those lines, please find Judge Gorski's Order to that effect.

Mr. Brady had defied this Clrder on numerous occasions, and on numerous occasionsvarious Court have refused to allour him to proceed because he has failed to obtain the necessarypermission.

Respectfully yours,

PIRRELLO, MISSAL, PERSONTE & FEDER

C ft&u{t

A Legal Center:

Pirrello, Missal, Personte & Feder2040 Ridge Road East

Rochester, NY 1'4622'2488Mario J. PirrelloPaul T. Missal (1933-2011)

Michael J. Personte

Steven E. Feder**also admitted in Florida October 10" 2013

Honorable Richard A. DollingerSupreme Court Justice545 Hall of JusticeRochester, New York 146t4

RE: Kevin Patrick Brady vs.People of the New York, et alIndex Number 053/13

Telephone: (585) 544-7090Facsimile: (585) 544-7093Websitq PMPFLegal.com

Dear Judge Dollinger:

I received the enclosed papers from Kevin Patrick Brady on October 8, 2013; they areentitled "Notice of Due Process Requirements".

Other than the fact that I have no idea what this means, and other than the fact that it is aprocedural nullity, I am aware of Your Honor's recent ruling with regard to Mr. Brady. It is myunderstanding that he has failed to sign a Stipuiation of Discontinuance (even though JudgeRosenbaum dismissed this case last summer), and that you are imposing sanctions and will besigning an Order to that effect.

I would appreciate receiving a copy of that Order once it has been signed and filed.

In the meantime, given the Court's ruling in this matter and the Court's position, I do notintend to respond to this iatest missive from Mr. Brady. If for some reason the Court requires meto respond to it in any way, I certainly will do so if so informed.

Thank you for your courtesy in this matter.

PIRRELLO, Mi PERSONTE & FEDER

SEF/cbscc dencs; Hillelcc w/o encs: Kevin

Respectfully yours,

Deutsch, Esq. /Patrick Brady'1/

ven E. Feder

a-L-

cc w/encs: Craig Doran, JSCMonroe County District AttomeyNew York State Dept. of LawMonroe County Bar AssociationKevin Patrick Brady

etr4t"r-" V"* r 71*../"r"rzr &//*E*z;*

9/,n/*hr, e-//L &4 r'ttrr't-zr'a,,

eZtz/*'t Qd %"tt- /*r"-44.-,*t;y o6/f%a'r eZr"- %r*.a

e7;tt-Z*{'Z:*''/@;a"zrOctober 31,2013

Kevin Patrick Brady508 Locust LaneEast Rochester, New York 14445

Dear Mr. Brady:

Judge Rosenbaunr is unable to grant you any relief on the paBers which the Court

receivedonOctober30,20l3bearinglndexNo.20l3100053. lfyoudonotagreewiththeDecision rendered in the matter, the proper avenue to pursue is an Appeal to the Appellate

Division.

Very truly yours,

/!', j'a-.-..,1:--a*^-,t-- .-i *'t<-n'{.- -tu,r-,,""

Maryanne H. Townsend, Esq.Law Glerk to Hon. Matthew A. Rosenbaum

cc: Hon. Richard DollingerHon. Craig Doran

7*,". /nr) .?zr'--?zfig,- /nr) ztz-tsatr

A Legal Center:

Pirrello, Missal, Personte & Feder2040 Ridge Rcad East

Rochester, NY 14622-2488Mario J. PirrelloPaul T. Missal (1933-2011)

Michael J. Personte

Steven E. Feder'!'

'"also admitted in Florida

Appellate Division50 East AvenueRochester, New York 14604Attn: Motion Clerk

RE: Kevin Patrick Brady vs.People of New York,Steven E. FederIndex #20t3-53


December 20,2013

ln accordance with Judge Doiiinger's recent directive, I am not responding to the mostrecent papers filed by Kevin Patrick Brady.

Such a lack of response in no way indicates acquiescence or agreement.

In accordance with Judge Dollinger's ruling (and Judge Gorski's ruling before him), Mr.Brady's filing is a nullity.

Respectfully yours,

PIRRELLO, MISSAL, PERSONTE & FEDER

Steven E. Feder

Telephoner (585) 544-7090Facsimile: (585) 544-7093Website: PMFFLegal.com

SEF/cbs /cc: Kevin Patrick Bradf,/

Hillel Deutsch, Esq.

A Legal Cenatee':

Pirrello, h$issaX, pu*q-gry&q &S*dq*202*S R.idge

Rociaester, NYRoad flas$

14622-2488Mario J. FirrelloPaul T. Missal (1933-2011)

V[ichaeX J. Fersonte

Steven E. Feder'3

':'also admitted in Florida

Supreme Court545 Hall of Justice


Attn: Motion Clerk

Telephone: {585) 544-?890

Facsixnitre: {585) 544"-7093

Wehsite: FMPFn-egal.con'r

March 24,2014

RE: Kevin Patrick Brady vs. POSNY, et aI

Index Number 53113


I have received a number of,mostly incomprehensible papers with regard to the above

matter.

Enclosed please find the Decision and Order of the Honorable Jerome Gorski with regard

to this petitioner. As you will see, this Petitioner is barred from utilizing any Court in the State

of New York for this and related matters without first obtaining the permission of the

Supervising Judge of the Court in rvhich he seeks to move forward.

It does not appear that such permission has been obtained here, and the motion is

therefore a nullity.

Given Judge Gorski's Order, I will refrain from responding to this latest missive from this

Petitioner, wirich itseif is riie with iechnical errors.

If for some reason the Court is even going to consider the application that has been

brought by the Petitioner, please so advise, and I will respond.

Respectfully yours,

teven E. F

SEF/cbsEncs.cc wlencs: Kevin

HiIleIPatrick BradYr iDeutsch, Esq.

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APPELLATE DIVISION

STATE OF NEW YORK

In the Matter of mandatorl,unconditional relief owed toKevin Patrick Brady, pro se

EXHIBITS C

Pursuant to Kevin Patrick Brady v People of New York and Craig DoranAdministrative Judge and eleven [11]jurisdictionally VOID criminal

convictions

EF

SUPREME COURT OF THE STATE OF NEW YORK

9pp etls te TBibisf 0 n, fi ourtls TuDi cf s[ @ ep sr tment

DOCKET NO. CA 13-00994

PRESENT: SCUDDER, P. J., SMITH, CENTRA, FAHEY, AND PERADOTTO, JJ.

IN THE MATTER OF KEVIN PATRICK BRADY, PETITIONER-APPELLANT,

V

THE PEOPLE OF THE STATE OF NEW YORK, RESPONDENT-RESPONDENT.

Index No:2012107593

Appellant having applied for a writ of coram nobis/vobis and a writ of extraordinary

errors, and having moved for permission to merge said application with his appeal from an order

of Supreme Court, County of Monroe, dated November 7,2012, and for other relief,

Now, upon reading and filing the affidavit of Kevin Patrick Brady sworn to May 2,2013,

the statements of Kevin Patrick Brady received May 30, 2013, and the notice of motion with

proof of service thereof, and due deliberation having been had thereon,

It is hereby ORDERED that the motion is denied.

Fnc.Ncns E. CAr.tRElr,, Clerk

l[

Entered: June 20' 2013

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SEVENTH JUDICIAL DISTRICTSTATE OF NEW YORK

KEVIN PATRICK BRADY

V

PE.PLE.FNEWY.RK Kffit'ffi..VKffi n*' EADM|NTSTRATIVE JUDGE CRAIG DORAN

*t\R ',

0 ,;014 t.; #=>fr

BE tT KNOWN AFHIF'H'*"'4:F'P; }}{YISHON *'t* B--*ryi:g

Uugigr6st'{'MIIF{'T ttt } &

As to an action to vacate eleven [11]jurisdictionally void criminal conviction. tfrlg.in'$.i"Court on or about February 20,2014, due to circumstances beyond my controTl'musfamend the Notice and affidavit of Service as follows

This matter is made returnable on March '17,2014. Answers, if any, to be filed in theCourt on or before March 14,2014 with simultaneous copies provided to defendant

TO THE COURT

I herby depose that the following parties were each served true and exact copies of thePETITION FOR WRIT OF ERRORS on the dates identified.

February 21,2014JUDGES CRAIG DORAN, ALEX RENZI, VINCENT DINOLFO

MONROE COUNW HALL OF JUSTICE Rochester, NY 14614

Fei.,;'uary 25,2014NEW YORK DEPARTMENT OF LAW 144 Exchange Bvd Rochester, NY 14614

MONROE COUNW DEPARTMENT OF LAW 39 W. Main Street Rochester, NY 14614

APPELLATE DIVISION

PETITION FOR WRIT OF ERRORS

KEVINPATRICK BRADY508 Locust Lane

KAREN A. SMITH

NOTARY PUBLIC-STATE OF NEW YORK

No. 0l SM6241 488

Suolltled ln Monroe CountY

My Commisslon Explres MoY 23, 20'l5

Judge Joseph Vale

s u p re m e c o u runp #i[1" o, u,., o " ffi $q fl.: tr; Krufl 'ffi K] 0 2014

February 19,2414

50 East Ave


Judge Valentino and Staff

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I am providing this record to the Fourth Department and the parties below to verify the

merits for unconditional relief I have sought from Monroe County courts from the inception.

It is, admittedly, voluminous. However, in the final analysis it will take an experienced legal

practitioner no more than twenty [20] minutes to confirm the patently fatal defects I allege.

They have been repeatedly confirmed by New York's appellate divisions including the

Fourth Dept and Court of Appeals. I also include on point commentary by Eric H. Sills,

Esq., Albany Criminal Defense Attorney,

These infinitely offensive and prolonged government intrusions [and others like it], have

cost me a twenty [20] year career in financial services, personal and family relationships

and nearly two [2] decades of my life. I have consistently tried to attack them in theprocedurally correct manner only to be obstructed. As a matter of record I have been

cheated, denied, degraded, dismissed, and abandoned by my judiciary at EVERY

opportunity that has presented itself.. ln fact, I have been punished unanimously for simply

and lawfully exercising my First Amendment right. I now realize that for me there is noprocedurally correct manner. My lawful petitions have been exercises in futility.

I will not sub;ect myself to anymore abuse. I respectfully request this honorable court topurge these lawless stains from my personal and professional record now bv any means

necessary. The only party who can be prejudiced in this matter is me. To make a man live

his life knowing he has been serially cheated, criminally convicted, abandoned anddestroyed for exercising a fundamental right is cruel and inhuman beyond my ability toarticulate.

Kevin Patrick Brady

NEW YORK DEPARTMENT OF LAW 144 Exchange Bvd Rochester, NY L46L4MONROE COUNTY DEPARTMENT OF LAW 39 W. Main Street Rochester, NY 14614JUDGES CRAIG DORAN, ALEX RENZI, VINCENT DINOLFO

MOROE COUNTY HALI OF JUSTICE Rochester, NY 14614

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KEVIN PATRICK BRADY

V

PEOPLE OF NEW YORKADMINISTRATIVE JUDGE CRAIG DORAN


BE IT KNOWN

As to an action to vacate eleven [11]jurisdictionally void criminal convictions filed in this

Court on or about February 20,2014, due to circumstances beyond my control I mustamend the Notice and affidavit of Service as follows

This matter is made returnable on March 17,2014. Answers, if any, to be filed in theCourt on or before March 14,2014 with simultaneous copies provided to defendant

TO THE COURT

I herby depose that the following pafties were each served true and exact copies of thePETITION FOR WRIT OF ERRORS on the dates identified.

February 21,2014JUDGES CRAIG DORAN, ALEX RENZI, VINCENT DINOLFO

MONROE COUNry HALL OF JUSTICE Rochester, NY 14614

February 25,2014NEW YORK DEPARTMENT OF LAW 144 Exchange Bvd Rochester, NY 14614

MONROE COUNTY DEPARTMENT OF LAW 39 W. Main Street Rochester, NY 14614

/ffilicrL6,,t,

KAREN A. SMITH

NOTARY PUBLIC-STATE OF NEW YORK

No' 01SM624.l488Suollfiad in Monroe CountY

My Commisslon Expires Mav 23' 2015

b,q,eq

APPELLATE DIVISION

KEVINPATRICK BRADY508 Locust LaneNew York 14445

585 381 2063

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NEWYORK STATE SI-IPREME COI'KTAPPELLATE DIVISION, FOURTH DEPARTMENT



(585) 530-3100 Fax (585) s30-3247FNENces E. CAFARELL

CLERK OF THB COIJRT

ALAN L. RossDEPUTY CLERK OF THE COI'RT

March 1,2074

Kevin P. Brady508 Locust LaneEast Rochester, New York 14445

Re: Matter of Brady v Doran

Dear Mr. Brady:

Enclosed please find the above-referenced notice of petition and supporting papers, which cannot

be accepted for filing for failure to comply with the requirements of 22 NYCRR 1000.9'

Moreover, you must obtain prior permission from the Court to commence any proceeding.


FRANCES E. CAFARELLCLERK OF THB COIJRT

NEWYORK STATE SUPREME COURTAPPELLATE DIVISION, FOURIH DEPARIMENT

M. DOLORES DENMAN COURTHOUSE50 EAST AVENUE, SI.IITE 2OO

ROCHESTER, NEW YORK 1 4604

(595)i539t100 Fax (s8s) s30 3247ALAN L. RoSs

DEPUTY CLERK OF THE COI,]RI

March 24,2014

Kevin P. Brady508 Locust LaneEast Rochester, New Yo?k

Re: Matter of Brady v-ffi;il

Dear Mr. Brady:

Enclosed please find the above-referenced notice of petition and supporting papers, which cannot

be accepted for filing for failure to comply with the requirements of 22 NYCRR 1000.9. Anotice of petition must include a retwn date of submission, and the filing fee is $315. Moreover,

you must obtain prior permission from the Court to commence any proceeding.

Very truly yours,

Appellate Division Clerk's OfficeLXD/sw

Encl.

Attorney General

www. courts. state.ny.us/ad4

NEW YORK STATE STIPREME COURTAPPELLATE DIVISION, FOURIH DEPARTMENT



(585) 530-3100 Fax (585) s30-3247FRANCES E. CaTARSU-

CLBRI( OF THE COURT

ALAN L. ROSSDEPUTY CLERK OF THE COURT

March 7,2014

Kevin Patrick Brady508 Locust LaneEast Rochester, NY 14445

Re: People v Kevin Patrick Brady

Dear Mr. Brady:

Enclosed please find your documentation entitled "notice for writ of errors" that wasfonrvarded to the Clerk's Office from the chambers of Justrce Joseph D. Valentino. Please be

advised that the above referenced documentation is being returned to you because your motionfails to comply with this Court's rules.

You have failed to provide an original and one copy of your coram nobis motion papers

and supporting exhibits (see 22 NYCRR'1000.13 [a] [5] [iii]). Also, you have failed to provide an

affidavit of service establishing when and how you served your coram nobis papers upon thenecessary parties (see 22 NYCRR 1000.13 [a] [2]). Furthermore, you have failed to designatea return date. A motion shall be made returnable on a Monday (or if Monday is a legal holiday,the first business day of the week) (see 22 NYCRR 1000.13 [a] t1l).

A formal motion on notice must include an original and one copy of each of the followingdocuments: (1) a notice of motion containing a specific return date (any Monday, orthe firstbusiness day of the week if Monday is a legal holiday, after the required notice period); (2) asupporting affidavit and any exhibits; and (3) proof of service of a copy of the motion papersand all exhibits on all parties at least 13 days priorto the selected return date if the copies wereserved by regular mail (8 days if served personally; 9 days if served by overnight mail).

Please be advised that your documentation entitled "notice of petition affidavit ofservice" has been forwarded to the area of this office that handles this type of documentationfor the Court. Enclosed is a copy of this Court's rules to assist you.

Vgry truly yours,

l!'!..n" 'r'-:l

,itJ"ti u"' , t- ta-,1 't '

" Amy M. Bogardus ,'

Principal Appellate Court AttorneyAMB:tlbEnclosurepc: Sandra J. Doorley, Esq


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As per your correspondence of 317i14.

The petition for coram nobis with exhibits was duly served by local US Mail cn the dates

indicated on the original Notice and Affidavit of Service AND by the enclosed USPS confirms'^

lnsofar as I have requested a hearing for this matter numerous times below without success, I

expected this Court would set a date as its earliest convenience and notify the parties.

I amended that expectation approx 13 days later as shown by the attached and notified all

parties simultaneously by US Mail. Apparently you had not yet received the amended papers

when we spoke on Monday. The originalwas filed to the attention of Judge Valentino on or

about March 5,2414.

I am including here an addition copy of the petition and exhibits.

Regardless of any defect in service, neither I nor apparently this Court has received any

objection as of this day. I attribute this, in part, to government attorneys inclination to scoff at

pro se litigants expecting to be taken seriously, AND, contrary to common misinformation, I

am not prohibited from requisitioning this Court for relief. [Order Judge John Lane].

Note however, that the Department of Law has 'officially' been relieved of responsibility for

responding to any of my 'frivolous' challenges by the order of Judge Richard Dollinger.

[annexed] despite that ABA Rule 1.6 already mandates the same.

Although the service defects at issue here have been corrected they are nevertheless

waivable issues. The constitutionaldefects alleged in the petition are not. There is no

cognizable defense to fatalfy void prosecutions. I submit that no party has been or could be

prejudiced by unilateral rules and breeched CPL mandates, but me.

Sent back with payment and original notice of service for CA13-02202

March 17 ,2014

Amy M Bogardus

Supreme Court/ Appellate Division

50 East Ave

Rochester, NY 14614

Ms. Boyardus

As per your correspondence of 317114.

The petition for coram nobis with exhibits was duly served by local US Mail on the dates

indicated on the original Notice and Affidavit of Service AND by the enclosed USPS confirms.,

lnsofar as I have requested a hearing for this matter numerous times below without success, I

expected this Court would set a date as its earliest convenience and notify the parties.

I amended that expectation approx 13 days later as shown by the attached and notified all

parties simultaneously by US Mail. Apparently you had not yet received the amended papers

when we spoke on Monday. The originalwas filed to the attention of Judge Valentino on or

about March 5,2414.

I am including here an addition copy of the petition and exhibits.

Regardless of any defect in service, neither I nor apparently this Court has received any

objection as of this day. I attribute this, in part, to government attorneys inclination to scoff at

pro se litigants expecting to be taken seriously, AND, contrary to common misinformation, I

am not prohibited from requisitioning this Court for relief. [Order Judge John Lane].

Note however, that the Department of Law has 'officially' been relieved of responsibility for

responding to any of my'frivolous'challenges by the order of Judge Richard Dollinger.

[annexed] despite that ABA Rule 1.6 already mandates the same.

Although the service defects at issue here have been corrected they are neveftheless

waivable issues. The constitutionaldefects alleged in the petition are not. There is no

cognizable defense to fatally void prosecutions. I submit that no party has been or could be

prejudiced by unilateral rules and breeched CPL mandates, but me.

r,/.t7

As to my docs having been forwarded to the office handling such matters. I reiterate that I am

entitled to a hearing by responsible judicial officers of this Court, not merely rubber stamped

and dismissed as my pro se papers have unanimously been in the past.

Kevin Patrick Brady

508 Locust LaneEastRochester 14445

Copies to Judges Doran, Renzi, Donofrio

NY Department of Law, Monroe County Dept of Law

I hereby depose that everything contained herein is correct and truthful except for matters alleged on

information and belief, and I believe those matters to be true. I further depose that nothing alleged here is

intended to be frivolous, embarrassing, harassing andlor completely without merit.

rauBy

TONILC@NLic. #01C0€050144

Notary Publiestate of New YorlQuallfi€d in MONRoE

My Cornmissbn FalrsB 1onol2o1{

f

At a Term of the Supreme Court ofthe State of New York, held in and

for the County of Monroe, at the Hallof Justice, Rochester, New York onthe 8th day ofNovember, 2013.

PRESENT: HON. RICHARD DO_LLINGERJustice Presiding

STATE OF NEW YORKSUPREME COURT: COUNTY OF MONROE

KEVIN PATRICK BRADY,

Petitioner, ORDER-vs-

Index No.2o13'053THE PEOPLE OF NEW YORK bY AttorneYGeneral, STEVEN E. FEDER, Esq.,

Respondents.

Petitioner, having instituted a proceeding by a Notice of Petition and affidavit, dated and

filed on June 26, 2013, seeking to render null and void previous judgments;

And Respondents, by their afforney, Eric T. Schneidefinan, Attorney General of the State

of New York, Hillel Deutsch, Assistant Attomey General of Counsel, having submitted a Notice

of Motion, Affirmation and Memorandum of Law all dated July 18,2013, seeking to dismiss the

Petition and requesting sanctions;

And the Court, having dismissed the Petition with prejudice by Order dated October 7,

2013 and ordered the Petitioner to shoe cause as to why sanctions should not be imposed for his

failure to abide by numerous Court Orders;

-:.t; ". tf.' t*' ':

And on Noyembcr S, 2013. thc Court having considsrccl the argumcnls of Pctitioncr and

Rcspondent. b-v llillel Deursch. Assistant Attorney Gcneral, and lbund that Pctitioner has failed

tc sho,"v cause RS to'rvly sanctions should not be imposetl against hirn fbr his failurc ta abid* b1'

numcrous Court Orclers. with due deliberations. it is heretry "=.*'fu: t't '1 .r

"' !s

a4;'

ORDnRI,ID. rhar pctitioner is d{i".i#hpFGt€effi4 at thc ratc ol'$50.00 per dav.

liorn the commencemcnt olthc aclion to the datc oJ'tlris (lourt's prior'Order of Oetohcr+' 2013'

rvhich is 100 clal's. lbr a total al-$5"(X)0.0(r- "10_*, r 1_* fl

(}RDr,RF.t). ttrar l)ctirioner t,6f;ffir!*3t"i*" at thc ratc ot'$50.(x) pcr clal'.

li.nr the rlatc p{'ths prior (}rclcr ril'Octobcr -1. 201i. until such time as Rcspandcnt rvithrlrai+'s

anii discontinucs with pre.iuilice thc currcnt action: and

ORDdRfi,D, that Peritioncr is held in contcmpt of court and. trpon motion t:1'ths

,., '+* Itespondents or their counsel. or upon dererminarion of the Court, mal' bc subja+t to additional:

{'-'i

L sanclion$ r,p to aiid including '-withour limitation - Iirss of drivcr's license and a period ol'

incarccration: and

ORI)}]RnD, rhat Respondenrs and their counsel arc nol to rcspond tlr an!' papers f'rled or

served by Petirioner- in this or an). other action hc has previottsly l'ilcd or rna-v lile in I'uturc.

unlcss such t-rl,-'cl anti scrvetl papcrs incluclc an Ordcr. signed bv thc Adnrinistrativc Judgu or the

Superlising Juilge lbr thc Civil I'erm in rhe Scvcnth Ju<Jicial l)istrict. dirccting a rcsFotrsc tiotrt

Ilcsponilcnls.

I)atcd; Novemtler 14" 201iRoclre-stc:r. N crn' York

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/,i

I ION. ITICI IARD DOI,LINT}IRActing Supremc Clourt .lrrstice

,)

{

l{ rPIlti.\IU CO{,iR"I OF ft{E SI.\IE t]F \UlV YORKC0{,' xTY OF },101\iRi}ii

K-[iVI]\ P;\'l RICK SRAD\'.

Pr.titioncr,vs. DgCISlOiq A;r-D ilRDIltt

INDEX \O. l(-)r)-1, 1()167T[{Oh{AS fu{. VA\STRYDONCK, JSC,C..\RLOS RODRIGLIEZ. Assistant Attomey Ceneral,S TEVNN R. SIRKT}I, JSC,n IANA 1RIZ,,\RRY, l{earing Ex am iner,RAY\,1 OND CO Ri\TELruS. JSC,SHFRRI E. WOOD. fulCCSE(-i,I

Rcspondents.

BEFORE: FIOr{. JOHN P. LANEJustice of the Supreme Court

.UIPEARANCIIS: KEVIN PATRICK BRADY, peritioner pro se

ELIO'T SPITZER, A TTORNEY CEi{EL{L OF -II{E STA IE OI;

NEW YORKAttorneys tbr Respondents VanStrydonck, Rodrig'_rez, Sirkin.fri z:r.rr,v,ind Ccrnel ius111, Robert ;\. Cnlon, Hsq., Assistant Artorncy (iencrnl

Dd\lEL V{. DEI.AUS, JR., MC}NROE COUNTY ;\'ITOR\,Ty,\ftorney lor Respondent Woadily tr{ichael E. Davis, S*nior Deputv Cr:untv ,\rt*nrcv

i'itc {.-'r_iurt ltrrs ".,,rtr,,ir.l*r*d Ihc iiriIe;rrIng i)JI)rrs

i " )uoticc {rt'ilctiricn ,iud ;ie titiorr. r{;rtecl -{eptcrn[:er rj, _]i.'rl..l;

l. )ii:iicc,rlrippeff;rnce,:n hehailoircsporrdcnt Sherri Il.,.!'ir,rtJ,I \,rtirrs ol';rpllc.irlrlcf (.ur hchrlf oirrsil{)n{1cnts vrilrsirisl,rr:ec.

i',:niclii:c" lrrkitr" uitd ftizzan,:

\'li.'t 5l:1" :ri:rfiJ:i ir.tr ilie .\'!rlnrilc t-'r-r11i1;, i"'itilti 5rr;:pi;rt i.litirrc*;1,:rri r ,t:t

13redy l VanStrl'donck, ct .riInrbr r\c. 2fl0"li' 1 i{: 7

cntiticri to prosccute iris rtppeals trom rrrdr-.rs of tirc \lanrae Caunty Flnrily (lcr.r:'t wi{}rout sccking

pern.:ission {rd., .i.:e itlso ?r*d.v v' 'l{iller,2:6 AD:d ll,i.1 [1996]). Horvevcr. :u] r]rriclc ll

prac*cdilig in tlte Supretne ('t)urt nlay not he L:sed Io r*r'ierv such orders.

l{.;-spondr-:nt S}:er-r, F-. Wood nroves to dismiss the petition on grounds that it is moot. f urls

ii.) iltt'.1 ,t cause of rction,rnri is rtthenvise trivolotts. ;\llcging that she has uniltrvfirllv,:rrg2u*d in

ti'rud in her eni'orcemcnt activitres, petitioner seeks an orcler directing respondent Wooil, rn

cntploysc olthe I,lCCSEtf. tn uease enlorcemcnt tctivitl,on support orders made in rhe pest ,urd

rcftrnd all sr"rms collected i-rom lum rctroactive to Septembcr 2003. Support collection units iu"e

csiahiisired io collect, ilccount lor and disburse iunds paid pursuant to any r:rder uf chiid support r-rr

r:liild and spar:sal sLlpport isc:e Social Sen'ices l-ar.v $lil-hIl]). Pctitioner's clairn lgarnst \.\rood

appiu'rn{lv relates to an lpplicatrtrn madc in ,\usust 1004 ta ftrmily court for ln intcnnetliate rppc:rl

ol;.t sr-tpport r:rder, '"vhich hatl bcen tleni*d, or to certily th* record tor direct;ippeal to thc ^,\ppcllatc

I,]ivitl..rtt. l.he pctilitlrl d{lcs not :itate rnv cr:gnizabie cu*se of ;:cticn under article 1$ .rr{*rnsi

i''J.'l-ri.)lt{ijtil \\rirc,.i.',thr: is Litt.tiilhcnz*d to rclirnd lhc iunrls petriioncr sceLs. Priiiidirer's,-rrrl',,

i'cnrcrl'',, :r*rinst entiirce m*nt rri rrn ordcr of contrnuing slipport is :rppeal.

In sLtnttttarv, .,''irrl* pctitroncr rnev nr)t prtlSrcutc t[:is artiule 78 prt-rcccriilrg seckrng i-c,- icr,, rri

trtil ,j rt'1xr;rrfils r.ii'!lpr,.-'ill* c()ild rlr l;rmil_V'corr11, irc is not .,vithr:,,Lrt i*llr:1. {.}rriers .rnti.ii{lt:ii

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KEVIN PATRICK BRADY

v

PEOPLE OF NEW YORKADMINISTRATIVE JUDGE CRAIG DORAN

APPELLATE DIVISION


BE IT KNOWN

As to an action to vacate eleven [11]jurisdictionally void criminal convictions filed in thisCourt on or about February 20,2014, due to circumstances beyond my control I mustamend the Notice and affidavit of Service as follows

This matter is made returnable on March 17,2014. Answers, if any, to be filed in theCourt on or before March 14,2O14 with simultaneous copies provided to defendant

TO THE COURT

I herby depose that the following parties were each served true and exact copies of thePETITION FOR WRIT OF ERRORS on the dates identified.

February 21,2A14JUDGES CRAIG DORAN, ALEX RENZI, VINCENT DINOLFOMONROE COUNTY HALL OF JUSTICE Rochester, NY 14614

February 25,2014NEW YORK DEPARTMENT oF LAW 144 Exchange Bvd Rochester, Ny 14614

MONROE COUNTY DEPARTMENT OF LAW 39 W. Main Street Rochester, NY 14014

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SUPREME COURT OF THE STATE OF NEW YORKCOTII{TY OF MONROE

KEVIN PATRICK BRADY,Petitioner.

VS.

THE PEOPLE OF NEW YORK,

ORDER

Index No. 2012107593

Respondent.

The petitioner in the above-captioned action having filed a motion to certif,i the record in the

above captioned action for appeal, said proposed record consisting of 105 pages, commencing with

apage entitled "Notice of Action, Demand for Hearing in the Nature of Writ of Error, Coram Nobis,

or Coram Vobis"; and the motion having been heard before the undersigned on papers; and this

Courl having found that the proposed record which was submitted with the instant motion by the

petitioner, consisting of 105 pages, is not the same set of papers as the "Notice of Action" filed by

the petitioner in the Monroe County Clerk's Office on July 10,2012, in that the Court's copy in its

file does not contain pages delineated "50 - 105" on the copy submitted with petitioner's motion;

and that, fuither the remainder ofthe record which should be contained therein as required by statute

is noi coiiiaineci in the proposed recor'i,

NOW, THEREFORE, it is hereby

ORDERED, that petitioner's motion to cerlify the record , in its present form, is

hereby denied.

J.Hoff. C

AprilDated:

fNew York

pre Court Justice

i"'

FRANCES E, CATENBII,CLERK OF TI{E COURT

August 22,2A13

-

*--F

NEW YORK STATE SUPREME COURT

APPELLATE DIVISION, FOIIRIH DEPARTMENTM. DOLORES DENMAN COURTHOUSE

50 EAST AVEN['E, SIJITE 2OO

ROCHESTE& NEW YORK 14604(585) 530-3100 Fax (585) s30-3247

ALAN L. ROSSDBPUTY CLERX O? THS COURT

. '::.::Kevin Patrick Brady ""''

508 Locust LaneE. Rochester, NY 14445

Re: Brady v Doran

Dear Mr. Brady:

ln response to your letter of August 1 B, 2013, please refer to the order of JusticeGorski entered March 5, 1996.

Appellate Division Clerk's OfficeLXD/cat

na'a

/-Fj.a

7

Very truly yours,

www. cburts. state.ny.us/ad4

Exhibits A

Documents

Transcript of Exhibits A