The Case for Jubilee

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS

------------------------------------------x Index 14449/06

COMBINED VENTURES L.L.C

REPLY TO OPPOSITION

-AGAINST-

FISKE HOUSE APT. CORP., DANNY BROWNE, KAREN V.M. SMITH, DEPARTMENT OF FINANCE OF THE CITY OF NEW YORK, AND JOHN DOE #1- 8 (DEFENDANTS)

Opposition #1. I Karen V.M. Smith, did not request that the order to appoint a receiver be vacated as “totally non-meritorious and frivolously” as accused by the plaintiff’s attorney. I do not deny Hornbrook’s law. I have exercised my right to request that this appointed agent be removed and a new one assigned as applicable law CPLR 6404 allows for. My Answer dated 6-21-2006 was in before he was assigned on 7-3-2006. on page 4 of said assignment it gives clear instructions not to proceed if an answer has already been placed questioning the validity of said mortgage. This agent continued without letting due process proceed and my answer be given full consideration in a trail.

Oppositon #2 “That ‘Ms.’ Smith has no defense to the within action and that she has no standing to bring an application because she is not the mortgagee” I have been named as a defendant in this action, therefore I have the right to defend. I am 100% liable for this mortgage both as the owner of Fiske House Apartment Corp., which I own 100% and also personally as the guarantor for the mortgage. It does not lend to reason that I not be able to defend myself in any manner of which I feel fit. The Plaintiff is going to request that my answer be stricken from the record based on a non-meritorious excuse.

Therefore the pending application to strike based on locating John Doe 1-8 is also non-meritorious because the reason they needed to be located is that they have not lived on the premise since 7-1-2006 at which time their stock option expired.

Opp. #3. “A letter forwarded to my office by ‘Ms’ Smith dated July 28, 2005 wherein she admits the debt in the within matter in the first paragragh” In the same letter that I admit to the debt I owe them, I also request that the debt be forgiven by the plaintiff. Thus begins the Estopple defense. I note that I have wired funds for the 2nd mortgage of $170,000.00 as my consideration for the forgiveness of the debt for the sins of their forefathers. I sent $2000.00 and it was never returned as non-payment.

I will further prove that one of the owners of Combined Ventures in particular benefited greatly for his for-fathers involvement in slavery (Mr. Ray Rothschild) and that slavery is one of the “Sins” I am referring to. That the sins are just as tangible as the $135,000.00 I received in hand after paying the plaintiff’s attorney fees, my attorney, points, taxes and other fees. That the Cotton that my for-parents picked which created the wealth of America, which created the New York Cotton Exchange (currently the New York Stock Exchange) which created every single minted US dollar because every dollar bill is made of 100 percent cotton is in and of itself the tangible connection for their forgiveness

I will show the trace of said plaintiff’s forefathers involvement in franchising the middle passage of slavery and thus prove that this Estoppel is justifiably requested and legally binding. Therefore it is not a frivolous argument. When the council for the plaintiff’s brought in the “race card” argument it implied that African Americans have no bases to claim any grievance, both, past or present. I will prove by the crux of my defense that we do. It goes to reason that if the Jewish man (which the plaintiff is) can go into Palestine and demand land based on Heritage rights of 1000 years ago, then an African Descendant (of which I am) can ask for forgiveness of any debt for the free labor my ancestors provided. I will also do it based on proof of the gross, indifferent, in-humane and tortuous conditions (as well as usury) practice that slavery was. I plan to prove all of this in the forthcoming case and I categorically deny any “race card” maneuver. In fact, in “Exhibit H” of the plaintiff’s opposition to motion, this letter was my way of letting them know that what I am doing was nothing personal but strictly necessary.

Opp. #4. “The Plaintiff attempted to work with ‘Ms.” Smith …and that is the reason that the within action was not commenced until May 11, 2006.” The Estoppel defense makes note that ‘a reasonable time’ must be taken for an action against a debtor who ask for forgiveness or they default. I beg to differ as to why the plaintiff’s took so long to bring suit. The Plaintiff was waiting to assume the first mortgage which actualized for them in May 2006. see Exhibit “A”. If they where indeed trying to work with me, then at the very same time they were also undermining me by positioning themselves to take the underlying mortgage, and indeed they acquired it. However, you will note that Acrobat Reality is not made mention in this foreclosure suit, of which the suit states that “there is no other mortgage” Which leads me to believe that, that portion of the debt was forgiven. Thus giving me reason to believe this portion of the debt is within bounds for an Estoppel defense.

I have attempted the undaunted task of finding a reasonable price for a human being. The slave trade swiped up hundred’s of millions of African descendants globally. My building is worth over 3 million dollars. It is both where I live and work. I have put this all on the line for just one of my ancestors. However, given the mass amount of wealth these plaintiff’s have enjoyed at my forefathers expense, I didn’t think asking them to forgive $170,000.00 was much of a request.

Respectfully submitted.
Karen V.M. Smith
Defendant