Petition for Rehearing — Alvin Sheldon Kanofsky, Petitioner v. Commissioner of Internal Revenue

Supreme Court briefMay 18, 2018

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IN THE

SUPREME COURT OF THE UNITED STATES

ALVIN S. KANOFSKY PETITIONER

VS.

COMMISSIONER OF THE IRS RESPONDENT

-

JEFF SESSIONS

ATTORNEY GENERAL OF THE UNITED STATES

-

NOEL FRANCISCO

-

SOLICITOR GENERAL OF THE UNITED STATES

ROOM 5614, DEPT. OF JUSTICE

950 PENNSYLVANIA AVE, WASHINGTON, D.C.

PETITION FOR REHEARING

OF PETITION FOR WRIT OF CERTIORARI

THE UNITED STATES 4TH CIRCUIT COURT OF APPEALS ENTERED IN

RICHMOND, VA. CASE NO. 17-1246

DR. ALVIN S. KANOFSKY. 229 E. CHURCH STREET BETHLEHEM, PA 18018

610-867-8064

QUESTIONS PRESENTED TO THE COURT

Is IT UNLAWFUL TO RETALIATE AGAINST WHISTLEBLOWING?

Government statutes state that it is unlawful to retaliate against whistleblowers. The laws state that retaliation will result in penalties against the

individuals or entities retaliating.

The Petitioner has acted as a whistle-blower for many years in these

proceedings, and is currently actively pursuing compensation from the

government for this activity. The petitioner also worked as a government

employee for many years, and the law clearly states that such retaliation by

the government against an employee is severely punishable.

The petitioner worked as a government contractor for some 25 years in

his role as a researcher at government laboratories such as Brookhaven

National Lab, Fermilab west of Chicago, Argonne National Lab, and also

finally the Superconducting Supercollider Laboratory to be build South of

Dallas Texas. As well, he worked as a contractor for for the Naval Air

Development Center in Warminster, as an investigator on radiation effects

on optical fibers and other components. Thus, he claims retaliation by his

former employer, the US government for his whistle blowing activities

,

IS IT UNLAWFUL TO IGNORE AFFIRMATIVE DEFENSES OF FRAUD

AND CORRUPTION? DOES THIS VIOLATE THE FIRST AMENDMENT

FREEDOM OF SPEECH?

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As stated above, the petitioner has frequently claimed fraud and corruption

as an affirmative defense. By not recognizing this defense the government is aiding

and abetting fraud and corruption, and is therefore complicit in these activities and

subject to the statutes against fraud and corruption such as RICO, acting under

color of law, etc.

Petitioner has presented numerous exhibits demonstrating the fraud and corruption

practiced against the petitioner. As well, he has presented many exhibits of Fraud

and Corruption in the societal environment within which he does business.

The government and the Courts have continued to ignore and block this

evidence, to the point of calling it frivolous and irrelevant and have threatened the

petitioner with sanctions of a fine up to $25,000 if he persists and more levies and

garnishments. This indicates that they condone and support the fraudulent and

corrupt activities.

As well, the courts and government have blocked any testimony by witnesses

the petitioner has proposed, where the petitioner can present evidence and

testimony of fraud and corruption, and of his own business activities.

IS IT UNLAWFUL TO IGNORE EVIDENCE OF BUSINESS ACTIVITY?

DOES THIS VIOLATE THE FIFTH AMENDMENT, DUE PROCESS?

The laws clearly state that obstructing justice, aiding and abetting unlawful

activity, acting under cover of law, RICOH, are all unlawful activities and

subject to severe penalties.

The petitioner has presented numerous exhibits of his own business activity

continual, ongoing, and with a purpose of showing a profit. The Court and

government again have chosen to ignore these exhibits and testimony, and have

thus in fact obstructed justice, aided and abetted unlawful activity, acted under

cover of law, and in conspiracy with others in unlawful activity.

-

WAS KANOFSKY TARGETED BECAUSE OF HIS CLAIMS OF FRAUD

AND CORRUPTION? AGAIN, A VIOLATION OF FREEDOM OF SPEECH

A FIRST AMENDMENT VIOLATION

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By threatening Sanctions for Claiming Fraud and Corruption, the Court was

targeting Kanofsky. In fact, it appears that this new ruling of the court to be able to

impose sanctions for frivolous and irrelevant statements may have been a direct

result of the Kanofsky Cases in the Court. Affirmative defenses are seemingly

allowed by the court, but seemingly not in Kanofsky's case. Was Kanofsky's

Freedom of Speech violated?

INVOLVEMENT WITH NSA SURVEILLANCE CASES. KLAYMAN, ACLU

GOVERNMENT RETALIATION SEARCH AND SEIZURE WITHOUT

WARRANT PROBABLE CAUSE FOURTH AMENDMENT.

-

-

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Since all of the Kanofsky Cases have been handled in the Federal Third

Circuit Court of Appeals by the Department of Justice, and that Kanofsky was

continually critical of the United States and indeed served in a whistleblower

status as did Edward Snowden in revealing the government surveillance

program, it is reasonable to assume that Kanofsky was in fact subjected to the

surveillance that the national security agencies maintained on other high profile

people who were critical of government activity.

Thus, it it is highly probable that his phone communications, internet

communications, etc. were monitored without his knowledge and under the

government program revealed by Snowden. This violates his fourth amendment

rights of the constitution against illegal search and seizure without a warrant.

As well, it is worth noting that Kanofsky has worked as a consultant to the

U.S. Supreme Court Chief Justices' father when he was head of Bethlehem

Steel. Chief Justice Roberts oversees the FISA court, making appointments and

monitoring its operation. The FISA court, of course, oversees the operation of the

NSA Surveillance. The Petitioner has repeatedly requested that Justice Roberts

recuse himself from considering his Previous Petitions, but to no avail.

6. DID GOVERNMENT RETALIATE BECAUSE OF KANOFSKY'S

INVOLVEMENT WITH THE PHILADELPHIA L&I SCANDAL, AND

DEATHS DUE TO BUILDING COLLAPSE? FURTHER EXAMPLE OF

FRAUD AND CORRUPTION.

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Kanofsky recently won a case against the Licenses and Inspections Bureau of

the City of Philadelphia, again citing Fraud and Corruption. The ruling of the lower

district court was overturned by the State Commonwealth Court on Appeal and

Remanded back to the lower Courts for a Further Reduction in the amounts

charged against Kanofsky

In addition, Kanofsky is asking compensation for seizures of valuable articles

from the family home and for pain and suffering. As well, while the case was being

litigated there was the devastating Kensington Warehouse Fire killing two firemen,

and the tragic collapse of the wall in downtown Philadelphia at the Salvation Army

Store resulting in six deaths and numerous injuries, both supposedly which

resulted in numerous injuries to people trapped beneath the wall debris. Both of

these cases were supposedly monitored and supervised by the Philadelphia Licenses

and Inspections Bureau.

The Kanofsky case was remanded back to the lower, court for a further billing

Reduction, but the other claims were denied, and are now again being appealed

upward to the State Supreme Court.

Many of the claims of Kanofsky in this case apply to the tragic incidents and

Kanofsky will remain active in supporting the claims of these victims and their

families in the Salvation Army and Kensington Fire Tragedies, as related to

malfeasance of the Philadelphia Licenses and Inspections division.

DID GOVERNMENT RETALIATE BECAUSE OF PETITIONER'S

INVOLVEMENT WITH GROUPS DENIED NON-PROFIT APPROVAL

SUCH AS THE CONSERVATIVE GROUPS AND THE JEWISH GROUPS?

FIRST AMENDMENT PROTECTS ALSO FREEDOM OF ASSOCIATION

AS INTERPRETED BY THE SUPREME COURT.

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As is well known, Kanofsky is active in Jewish affairs, and as well his

involvement with Israel. Is he being targeted in the same way as the conservative

groups and Israel supporter groups were targeted in applying for non-profit status.

Government continues to retaliate against Kanofsky for Claiming Freedom of

Speech, Whistle blowing, for due Process, etc. By piling more penalties and fines

and refusing to recognize his legal business activities.

DID GOVERNMENT DENY PETITIONER THE RIGHT TO A FAIR TRIAL,

AS REQUIRED BY THE SIXTH AMENDMENT I.E. THE RIGHT TO

HAVE WITNESSES, AND PRESENT EVIDENCE?

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Justice Department Response:

"The Tax Court acted well within its discretion in excluding exhibits offered by

taxpayer that were not relevant to his federal income tax liability for 2006 and

2007."

"Court acted properly by not allowing timer to schedule witnesses."

Statement of the standard or scope of review from pg. 28, of brief of Justice

Department to Appeals Court.

"The taxpayer also seeks to challenge the Tax Court's Rulings at trial excluding

some of his exhibits as irrelevant to the issue of taxpayers federal income tax

liability for 2006 and 2007. (Br. 2.6) The tax Court's decision to exclude evidence is'

reviewed for abuse of discretion to exclude evidence is reviewed for abuse of

discretion. See e,g, Polack v. Commissioner, 366 F. 3rd 608 612 (8th Cir. 2004);

Drobny v. Commissioner, 113 F. 3rd 670 684 n. 23 (7th Vit 1997); Little.

Commissioner, 106 F. 3d 1445, 1449 (9th Cir. 1997)

"The tax court acted well within its discretion in excluding certain trial

exhibits offered by taxpayer. At the beginning of the trail taxpayer submitted a

commingled pile of papers that the court referred to as a stack of documents and

taxpayer admitted that I realize that they could be considered irrelevant. (Doe. 12

at 78)

The court stated that it is I'm sustaining an objection not entirely for relevance but

because the documents are inappropriately collectively marked after urging

taxpayer to pull any documents that you think show deductible expenses, get them

marked, and I will give you a chance to prove them." In response, taxpayer offered

receipts for real estate taxes paid on the property that he described as my mountain

house. He also offered receipts and other records that he asserted he'd paid of real

estate taxes, repairs, and mortgage interest on the building next to Lehigh

University. The court did not admit any of these exhibits into evidence agreeing

with the Commissioner that they were irrelevant to taxpayers federal income tax

liability.

The Tax Court's evidentiary rulings were proper. The Tax Court is required

to conduct its proceedings in compliance with the rules of evidence applicable in

federal district courts, including the Federal Rules of Evidence. See IRC See 7463

Tax Cr. R 143 (a). Rule 401 of the Federal Rules of Evidence provides that evidence

is relevant if (a) the fact is of consequence in determining the the action "All of the

excluded exhibits fail the second part of the test because the taxpayer never

demonstrated that he had ongoing business activities that would permit him to

claim these expenses as a business deductions. As the court noted, these exhibits

were irrelevant and thereby inadmissible because taxpayer had not presented that

the properties in question were used for legitimate puniness purpose that would

have affect (taxpayer's )individual income tax liability. (Doc. 12 at 56) As a result,

the taxpayers expenses were of no consequence in determining the outcome of the

case, and the Tax Court Properly exercised its discretion in excluding these

exhibits."

DID GOVERNMENT VIOLATE EIGHTH AMENDMENT? I.E.

GOVERNMENT CANNOT REQUIRE EXCESSIVE BAIL OR FINES OR

CRUEL AND UNUSUAL PUNISHMENT.

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In determining the Petitioner's tax

liability, by actual direct action of the Secretary of the Treasury,the government

continues to apply the maximum penalties, fines, levies, and garnishment.

SHOULD PETITIONER BE GRANTED A CHANGE OF VENUE ON THIS

CASE?

As stated repeatedly, the Petitioner pursues his business activities in

theThird Circuit Court of Appeals, where fraud and corruption are all

pervasive, the Judges of the Third Circuit Court of Appeals are subjected to

the pressures brought to bear on them to not rule against their friends and

associates, and thus where numerous conflicts of interest exist.

RECENT EVENTS SINCE THE ORIGINAL SUBMISSION

In the interim period between when the first submission of the Petition

was made back in October 23, 2017 and now the following substantive events

have occurred in regard to petitioner's business activities. Most of this is in

regard to his real estate holdings, and how that affects his property values,

business expenses, and taxes.

The Conviction of the Allentown Mayor, Mr. Ed Pawlowski, on 47 Counts

of Fraud and Corruption in Federal Court, out of 54 original counts. This

was prosecuted by the U.S. Attorney General Louis Lappen of the

Philadelphia Office. This is as well a condemnation of the same

organizations that the Petitioner Kanofsky deals with in developing his

properties in the Lehigh Valley.

The Petitioner has had to deal with numerous fraudulent and corrupt

activities by the local entities supposedly representing the interests of the

local governments in the course of the current five year period of intensive

litigation. Many of the corrupt and fraudulent activities were amply in

evidence during the extensive trial in the Allentown Courthouse, and the

U.S. Attorney and his staff need no reiteration from this litigant as to what

they are. As well, they are clearly stated in his numerous court filings.

Petitioner Kanofsky has been a co-defendant with the United States

Government, represented by the local U.S. Attorney, Louis Lappen, in

Philadelphia in these proceedings, by virtue of the IRS liens filed by

the U.S. Government ,and it is required that Attorney Lappen, with

the United States of America as co-defendant, be served through U.S.

Attorney Lappen all the legal papers by the Petitioner.

The completion of the enormous office complex and Parking

Garage 200 feet from the Petitioner's building and lot. The office building will

house various offices of Lehigh University and Saint Luke's Hospital. The

developer is Atty. Dennis Benner.

Initially, Atty. Benner's Realtor, Ms. Lucy Lennon, had approached

the Petitioner with an offer to buy the building for $325 K, which the

Petitioner turned down. They then shifted to a more aggressive approach,

working with the city to pile up numerous violations on the Petitioner,

followed by formal court cases and litigation. The work and expenses that the

Petitioner had put into the building were presented to the Tax Court, and are

the subject of this Supreme Court Appeal, with the Tax Court Judge totally

ruling out any of the massive expenses in repairing the building the years

considered by the Tax Court 2007-2011.

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The City conveniently lost all records of the City when the Petitioner

finally obtained again the right to store objects in his building, and they fired

the Inspector who oversaw earlier work and repairs, Mr. Michael Palos.

There is numerous interim Litigation on numerous legal cases of the

Petitioner's Properties (the Lot and Building).This is presently in

progress in the Pa.State Commonwealth Court and State Supreme Court

with some of the cases now being prepared for the U.S. Supreme Court.

This litigation, with subsequent add-ons could proceed for several years.

Hopefully, the Conservator Ruling by the City of Betlehem and the

County Court will eventually be totally overturned by the Courts as totally

illegal and improper with proper compensation awarded to the Petitioner.

Other new developments are now in progress in the neighborhood.

These include the purchase of the Sands Casino Property down the Street

from the Petitioner's properties being purchased for $1.3 B dollars from

owner Sheldon Adelson by an Indian Tribe from Florida. Again, this should

further enhance the value of the Petitioner's properties.

The purchase requires the approval of the State Casino

Gambling Commission, which oversees the Gambling in the State of

Pennsylvania. This is an Alabama Indian Tribe, The Poarch Band of

Creek Indians, with company name Wind Creek Hospitality they

own the Wa She Shu Casino in Gardnerville, Nev. owned by the

Washoe Tribe.

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New Developments in regard to the City management and entities

involved in the development on the South Side of Bethlehem. The large

office complex and parking Garage Project Headed by Attorney Dennis

Benner has been completed in regard to construction and now is being

occupied by staff of Lehigh University and St. Luke's Hospital. This

should further enhance the value of the Petitioner's Properties by at least

a fourfold factor according to Real Estate Lawyers and Appraisers that

the Petitioner has consulted. Thus the appraised property values must be

greatly increased up to and above about $1M.

This amount is far more than what has been approved for than in the

Conservator proceedings.

Continuing Ongoing Litigation in regard to this other real estate

properties in Philadelphia and the Poconos. The house property in the

Poconos is again coming up for a Sheriff Sale, but this property as well is

part of the assets of the Petitioner and the United States of America has a

controlling interest in it which prevents it from being sold.

As well, the house in Philadelphia was sold despite the U.S.

Government having a controlling interest in that as well, and the court

case is coming up the end of the month before a Judge in Philadelphia as

to the resolution of the case.

There have been recent changes in Government, Local (Redistricting),

Nationally, and Worldwide. The congressional district boundaries in the

State of Pennsylvania have been changed to supposedly reduce the

Gerrymandering which supposedly favored the Republican Party. The

new election is the 15th of May.

Conclusion

In conclusion, the Petitioner respectfully requests that this court rule

in his favor and award compensation for loss of income and pain and suffering over

the many years that the City and State and it's various collaborators have

fraudulently and corruptly acted to prevent the Petitioner from pursuing his

business interests and activities.

Sincerely Yours,

V

V

Dr. Alvin S. Kanofky

May i%, 2018

APPENDIX -RECONSIDERATION FILING

RECONSIDERATION OF COURT ORDER DENYING PETITION FOR

ALLOWANCE OF APPEAL OF APRIL 16, 2018

The Petitioner was not responsible for the damage to the building such as the

cracked front window, stucco damage, etc. This was due to the city piling and

shoving snow against his building with a huge front loader after the record

32 inch snowfall of January 22, 2016 The impacts were also responsible for

the roof collapse. This was evident from the total destruction of the adjacent

concrete and steel sewer cover with the remains found on the Petitioner's lot

and against his building's wall. Exhibit A

.

This resulted in numerous citation violations for which Kanofsky was fined

a total of $30K and a sentence of 5 days in prison. Exhibit B

The city has been determined to seize the building of the Petitioner over the

many years he has owned it, with the most recent attempt being the

Conservator proceedings. In the hearing before Judge Beltrami the $30 K in

fines were incorporated into the costs billed against Kanofsky in the

Conservator settlement of funds obtained from the sale of the Petitioner's

building. Exhibit C

,

There was an attempt by the City to silence any opposition with bail and

conditions of Bail. There was a Statement by Judge Zito to the Prosecuting

City Solicitor Matthew lJeschler that :"My impression is he's become a burr

in your saddle so to speak" Zito said to Deschler. "I had to think that the city

of Bethlehem just wants bail to make a statement to be punitive." Exhibit D

The Petitioner discovered a Beltrami Case several years earlier that became

nationally known as one of the top Travesty of Justice cases in the country.

This was a case of a thirteen year old boy who was sentenced by Judge

Beltrami to two years incarceration and restitution of $625 K for setting fire

to a house. The only witness to the case was the woman who owned the

house. Despite the boy's insistence that he was innocent, acting on

the promise of the arresting officer that he could be home for Christmas if he

pleaded guilty, Judge Beltrami imposed the sentence.

It was only several years later that the Judge's stenographer Jane Walker

noticed the same woman who had accused the boy was there for a similar case with

another house. She suspected the woman had wrongfully accused the boy.

Judge Beltrami recused himself. The woman was indeed the guilty one in the

earlier case. The boy was totally exonerated and won $175K for damages in his

wrongful conviction. Exhibit E

There are numerous conflicts of interest with Judge Beltrami. For example,

Sharon Fields (head of Lehigh University Parking Authority) is the ex wife of

Beltrami's High School classmate, John Conahan, who works at the main

Bethlehem Post Office. Prosecuting Attorney, Mathew Deschler Assistant

Solicitor of Bethlehem, was Judge Beltrami's former law clerk. Exhibit F

,

,

Petitioner had a hearing before Judge Zito and with numerous violations

daily given by Bethlehem Chief Inspector Craig Hynes who has now retired,

thus complicating getting testimony. Exhibit G

Chief Inspector Hynes had no records of earlier repairs and work on building

which resulted in the City allowing occupancy by Kanofsky back in 2008.

It was remarkable in that these records were entirely missing from his files. Exhibit

H

The Conservator case was already in process when the trial before Judge

Zito was held, since the calls for proposals had already gone out in September,

2016, with the Conservator papers issued in October. Exhibit I

The city acted to block and delay the broken front window case, finally held

before Judge Murray. The city delayed any appearance on the resurrected

case before a Judge for several months, as can be seen from the Docket on the

case.In any event the court's all agree that Petitioner should be allowed to file

a civil lawsuit on the case as a response. Exhibit J

The Zito Commonweath Case was handed over to the Bethlehem City lawyer,

Matthew Deschler, rather than, as usual, being tried by the State District

Attorney of Northampton County, John Morganelli. Morganelli Is now

running for the United States House of Representatives, with the motto

"District Attorney with a heart." Exhibit K

There was repeated False testimony by all of the city witnesses, including

Redevelopment Director, Tony Hanna, Police Officer Hackett, Chief City

Code Director, Craig Hynes, and Development Director Alicia Karner.

There are numerous examples of Fraud and Corruption in the City of

Bethlehem and the Lehigh Valley. Recently, the Allentown Mayor, Ed Pawlowski,

was convicted of 47 counts of Fraud and Corruption in a case prosecuted by the

Philadelphia office of the FBI, headed by Director Louis Lappen. Attorney Lappen is

also representing the United States of America, with the Petitioners' Conservator

Proceedings.

Some entities involved with Pawlowski are the Chamber of Commerce, the

Economic Development Corporation, Community Development Corporation,

etc.,where these entities represent and serve for the City of Bethlehem, Easton,

and Allentown. Exhibit L

The case before Judge Murray dealt exclusively with the window crack, but

has a major bearing on the Zito Case since the crack and stucco violations

issued were due to the damage by the city's front loader removing snow from

the city street and lot after the record breaking 32 inch snowfall of January

22, 2016, and shoving and piling it against the building wall.

Subsequent removal of the stucco wall, as revealed in later pictures

demonstrate that it served merely a cosmetic function and provided no support or

protection for the underlying wall, as seemingly claimed by the violation notices.

Exhibit M

As well, the files on an earlier building inspection and clean out where

allowance of storage of were allowed, as evidenced by the notification from

the city, were claimed by Chief inspector, Mr.Craig Hynes to be totally nonexistent, as for example the agreement that Kanofsky could store his

personal items in the building.

The Petitioner has just learned that Mr. Craig Hynes, the chief City

Inspector who issued all the citations retired from his city position the beginning

of March 2018. Conveniently, he joins the prior inspector for the City, Mike Palos,

with no longer working for the city, thus making it more difficult for the Petitioner

to have them as witnesses in court proceedings. Exhibit N

13. Judge BROBSON, of Commonwealth Court, has repeatedly ruled against

Kanofsky, even ruling adversely on an earlier case in the Seizure of Petitioner's

building in Philadelphia. His claim in the Commonwealth Court Opinion that the

recent version of KanOfsky can not be accepted by the court, has no basis in reality

and evidence , as shown by the letter from the city, recent discussions with Mr.

John Rohal, the Director of Re-development at the time, and numerous pictures and

court documents of the of the building clean out, bills charged, court litigation, etc.

etc. for the work done on the building roof and walls in 2007,

2008, and allowances by the City, Building inspector Mr. Michael Palos, and

Magistrate Nancy Matos for occupancy by Kanofsky at the time. Exhibit 0

14. The courts have begun to rule in favor of the Petitioner as the become

familiar with the case, with numerous another travesties of Justice.

The Petitioner begs this court to continue in reversing earlier erroneous

decisions based on corrupt and conspiring actions, and provide just compensation

for pain and suffering inflicted on the Petitioner.

Respectfully Submitted,

2018

Alvin S.Kanofsky

".

V

EXHIBIT A

BUILDING DAMAGE FROM FRONT LOADER

EXHIBIT B

ZITO ORDER FROM CITATIONS

EXHIBIT C

CONSERVATOR PROCEEDINGS

EXHIBIT D

CITY ATTEMPT TO SHUT DOWN

PETITIONER'S OPPOSITION

EXHIBIT E

JUDGE BELTRAMI TRAVESTY OF JUSTICE CASE AS GIVEN IN UNIVERSITY

OF MICHIGAN INNOCENCE

PROJECT

• EXHIBIT F

CONFLICTS OF INTEREST

EXHIBIT G

VIOLATIONS ISSUED BY INSPECTOR CRAIG

HYNES

EXHIBIT H

REQUEST FOR PROPOSALS

EXHIBIT I

VIOLATIONS ON CRACKED WINDOW GLASS

EXHIBIT J

BROKEN WINDOW CASE

SHOWING DELAY.

EXHIBIT K

JUDGE MURRAY DECISION AND DOCKET

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JUDGE ZITO COMMONWEALTH CASE DOCKET SHOWING TRANSFER

OF CASE FROM D.A. JOHN MORGANELLI TO CITY ATTORNEY

DESCHLER

EXHIBIT L

FALSE TESTIMONY PAWLOWSKI

ALLENTOWN CASE

-

EXHIBIT M

JUDGE MURRAY CASE BROKEN WINDOW

-

1 *4IHJ zi

CERTIFICATE OF OCCUPANCY

ALLOWANCE

EXHIBIT 0

IN JUDGE BROBSON RULING, IT WAS CLAIMED VIOLATIONS WERE

MAINLY FOR A BROKEN WINDOW AND STUCCO DAMAGE BOTH OF

WHICH PETITIONER CLAIMS WERE CAUSED BY CITY AND NOT A LEAKING

ROOF AND LACK OF A CERTIFICATE OF OCCUPANCY.

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STATEMENT ON REHEARING SUBMISSION.

CASE 17-1271

This is to state that this Petition for a Rehearing on

my Petition for a Writ of Certiorari is submitted in

good faith to not extend the Period of Rejection

but on the basis of new events and material that

has occurred in the interim Period since the original

submission and the present time and is of essential

relevance to the case.

The Petitioner requests that the Court

reconsider the case 17-1271 in view of this additional

relevant information.

Respectfully Submitted,

Dr.

May 18, 2018

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