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FRAUD OF THE COURT

6/7/2018

ANJELICA GRGORY
BRENT FERGUSON.

Fraud on the Court Must be Proved by Clear and Convincing EvidencePrint

On May 8, 2014, the Court of Appeals after finding that the defendants had, among other things “suborned perjury by providing [witnesses] with a ‘script’ containing false answers to be given to their attorneys and at their depositions; created . . . wholly fictitious individuals and intentionally implicated as controlling the defendant corporations; [and] forged the affidavits of others,” the Supreme Court granted the motion, struck the defendants’ answers, and granted default judgments.
The First Department affirmed. The Court of Appeals granted leave to appeal to address the proper evidentiary and legal standards for such a motion. The court reviewed a number of federal cases and imported the federal “clear and convincing evidence” standard into New York law:
The federal courts have applied the clear and convincing standard in determining whether the offending party’s actions constitute fraud on the court. Characteristic of federal cases finding such fraud is a systematic and pervasive scheme, designed to undermine the judicial process and thwart the non-offending party’s efforts to assert a claim or defense by the offending party’s repeated perjury or falsification of evidence . . . .

We adopt this standard and conclude that in order to demonstrate fraud on the court, the non-offending party must establish by clear and convincing evidence that the offending party has acted knowingly in an attempt to hinder the fact finder’s fair adjudication of the case and his adversary’s defense of the action. A court must be persuaded that the fraudulent conduct, which may include proof of fabrication of evidence, perjury, and falsification of documents concerns issues that are central to the truth-finding process. Essentially, fraud upon the court requires a showing that a party has sentiently set in motion some unconscionable scheme calculated to interfere with the judicial system’s ability impartially to adjudicate a matter by improperly influencing the trier or unfairly hampering the presentation of the opposing party’s claim or defense. A finding of fraud on the court may warrant termination of the proceedings in the non-offending party’s favor . . . . Therefore, once a court concludes that clear and convincing evidence establishes fraud on the court, it may strike a pleading and enter a default judgment.

We caution that dismissal is an extreme remedy that must be exercised with restraint and discretion. Dismissal is most appropriate in cases like this one, where the conduct is particularly egregious, characterized by lies and fabrications in furtherance of a scheme designed to conceal critical matters from the court and the nonoffending party; where the conduct is perpetrated repeatedly and wilfully, and established by clear and convincing evidence, such as the documentary and testimonial evidence found here.

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Official Complaint: Brent Ferguson, NY State Bar. Assistant District Attorney, City of New York

6/7/2018

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Official Complaint:
Brent Ferguson, New York State Bar.
Assistant District Attorney, City of New York

PROSECUTORIAL MISCONDUCT.

The information contained in this document and it's attachments shall be considered an official Complaint to the State Bar of New York, and provides unequivocal proof of gross prosecutorial misconduct and criminal acts committed by Brent Ferguson, State Bar #

These violations include, but are not limited to the following:

Fraud of the Courts
Conspiracy
NY State Bar Rules of Professional Conduct

Rule 5-110 Performing the duty of a Member in Government Service
Rule 5-200 Trial Conduct
Rule 5-220 Suppression of Evidence

Violations of the New York State Bar Act
Violations of the American Bar Association, Professional Rules of Conduct.
Violations of Federal Civil Rights under Color of Law.

The State Bar is advised that this document is also provided to the New York State Grand Jury as supplemental information to the formal Public Corruption Complaint filed independently by a collaboration of Human Rights organizations, specifically naming Brent Ferguson, NY State Bar.

The State Bar is distinctly advised that the prosecutorial misconducts and criminal acts of Mr. Brent Ferguson detailed herein are not isolated incidents. They are part of a sustained pattern and course of misconduct, warrants criminal conviction, and necessitate permanent disbarment to protect the people of New York.

A substantial amount of supplemental documentation will be provided to the State Bar, the New York State Grand Jury, the Center for Prosecutorial Integrity, the Attorney General of New York, and other Human Rights Organizations investigating Brent Ferguson, New York State Bar.

BACKGROUND AND SYNOPSIS

"Contrary to defendant's contention, the "reasonable fear" and "no legitimate purpose" elements of the offense were established by the testimony of the complainant and additional eye-witnesses, who testified that defendant repeatedly appeared at and lingered around Shields' home; followed her when she left her house; ignored numerous warnings by family, security and the police to stop contacting her; parked near her home for days at a time and slept in his car; and sent her unwanted communications, including a letter with a shirtless photograph of himself and an email to her publicist in which defendant referenced an actress that had been murdered by a stalker. The court could rationally infer that defendant's conduct was designed to hound, frighten, intimidate and threaten (see People v Stuart, 100 NY2d 412, 428 [2003])."
Mr. Ferguson not only mislead, but fabricated grossly. .

A prior complaint was made against former ADA Ms. Anjelcia Gregory for her role in the initial 2015 case. Within two weeks of the complaint presented to Kirkland & Ellis, Ms. Gregory was no longer an employed by them. .

Mr. Ferguson in the above brief, willfully and knowledgeably committed Fraud of the Courts.

"Fraud on the court occurs when the judicial machinery itself has been tainted, such as when an attorney, who is an officer of the court, is involved in the perpetration of a fraud or makes material misrepresentations to the court. Fraud upon the courtmakes void the orders and judgments of that court."

1. There was no sleeping in the car, it was awaiting street cleaning.
2. The shirtless photograph was an inch x 3/4 inch picture used as logo for a personal correspondence to Dear Friend, to support Sandy Hook, and encourage a clear mission statement.
3. Letter sent to publicist was to preserve a relationship between myself and the agency dating back to 2002. To suggest Rebecca Schaefer as a threat was utterly irresponsible. Ms. Schaefer was shot and killed just two days after I arrived from NT to Los Angeles- on the same block. It scared me, and was a significant reason I quit acting after Rob Reiner’s “A Few Good Men.”

BACKGROUND.
In 2003, Mr. Chris Henchy and I met after a Broadway play. After introducing myself to him, he grabbed me , pulling me across the room and said I had to meet his wife, Brooke Shields personally. There had been a gift sent that she was said to be so in love with that she had told me point blank, 1. It was too nice to share, and 2. It would remain on her bed-room bureau. I was very pleased because throughout my life I had developed a sense of gratitude to the Shields after their stepping in and having my abuser prosecuted. Through Mrs. Shields' kindness, I was no longer of abuse, but a survivor..

After many kind words were exchanged, I gave a friendly man to man pat on his shoulder and said my good-byes.

There was no further communication since 2003 aside from my attending 3 or 4 Broadway shows..

In 2012, after my father had died things of his became more valuable to me. And in 2013 or so I stumbled upon an old gift Mrs. Teri Shields bestowed to me as a kindness.. The loss of a parent is tough, but the loss of a grandparent is especially tragic because this relationship ends when the grandchild is often quite young. Since I was given such a lavish gift of a heart shaped silver frame, I felt obliged to return it to its rightful owner, Brooke with a comment that I thought her eldest daughter would appreciate it more that I. At the time it seemed to be the right thing to do.

In 2014, I received a bulk mailing from Ms. Shields inviting me to several events to which she was to speak on behalf of a book she had previously published. During one event the mc was kind enough to ask if there were any questions, I put my hand up and we spoke of my 'paying it forward' and attributed my philanthropic work to her mother who was kind to a child a long time ago.' Brooke then asked if there was a question, and I just said no. I had only wanted to say thank you. She moved on and before I knew it I had said, yeah I do have a question after-all.. but someone had already begun to speak, and Brooke smiled at me, and I smiled back.

The next event was several hours away and was a book signing at Barnes and Noble. While I joined the line to have my book signed, I didn't solicit a conversation, but when Brooke saw me, she quickly apologized for not getting to me to ask my question. She took it upon herself to engage me, I might add.

In just a few months later, I would run into Ms. Shields in my neighborhood. For the record, Ms. Shields moved within 2blocks of me.. and to run into her in a total of 3 or 4 times over the course of many years seems expected- especially when Ms. Shields lives just two doors down from my pharmacy that I've been patronizing for over 20years.

The quantity and severity of the many criminal acts committed against me has been so expansive, so much so that it has drawn the attention of a number of Human Rights organizations, who have collaborated on a comprehensive investigation and have assisted in the filing of a formal public corruption complaint with the New York City Bar.

The evidence provided herein proves unequivocally that ADA Brent Ferguson of the Manhattan DA's office violated his oath of office, abused public trust, and made a mockery of our judicial system in her relentless pursuit of a criminal conviction.

I'd also like to add Mr. Ferguson is with no moral compass as a result of his arriving to the Manhattan District Attorneys office. Prior to his taking a position at the Manhattan DA’s office, Mr. Ferguson was a notable asset to Brennan Center for Justice, and thought to possess a great deal of integrity.

I'd like to also add that for close to two years, I was repeatedly asked to accept a disorderly conduct. With advise from Assemblyman O'Donnell, I was told not to accept if I was innocent. I was also advised that as long I was fighting a celebrity I would not win with Cy Vance as District Attorney. But, at that point the only thing that was important was the lesson I’d be instilling upon my little boy, 'perjury isn't an option even if it will afford you your freedom.'

Specifically, the facts and evidence herein establish:

Notably, Mr. Ferguson was the Attorney on record who took this case to NY Apelate Court. Throughout his brief, he constantly contradicted himself and flat out fabricated several truths. The biggest travesty was his flat out misrepresentation of facts.

Ms. Anjelica Gregory was already reported for her oath violations and within weeks of my filing was no longer employed by Kirkland & Ellis. Mr. Ferguson’s role herein was essentially his committing Fraud of the Courts.

“Fraud on the court occurs when the judicial machinery itself has been tainted, such as when an attorney, who is an officer of the court, is involved in the perpetration of a fraud or makes material misrepresentations to the court. Fraud upon the court makes void the orders and judgments of that court.”

Ms. ADA Anjelica Gregory filed criminal charges on behalf of Ms. Brooke Shields even though insufficient probable cause existed.

The assumption of criminal behavior was based on the discovery from an extortion/ consumer site called Rip Off Report. This site defamed me in its accusations of being a child predator and running an illegal non profit. In 2010, thanks to Detective Paul Arroyo, these reviews were proven false. Yet, they remained because reports can not be removed. The only option was to then pay a $5,000- $100,000 service fee to have the reports 'buried.'

Ms. Angelica Gregory then committed fraud to procure this deficiency by fabricating a false accusation of a crime (Ms. Shields made up a history of events that never took place, lied about situations, and even Ms. Shields' husband lied in court stating he had only one encounter with me despite documentation the prosecution released that clearly contradicted both Ms. Shields and her husband Chris Henchy.) to convince the judge that I should have reasonably known that Ms. Shields was fearful. All the while making up dots... a how to do to speak that was necessary to make a stalker out of a guy who's soul existence for the past 25 years was to eradicate abuse, and to stop the bullying- both I hold responsible for all the gun/school violence. Essentially, fabricate a skillfully crafted scenario to procure a wrongful conviction.
Subsequent to fabricating her false accusations, Ms. Gregory had met with Ms. Shields dozens of times, as said in court, over the previous two years to create her testimony. The facts herein prove beyond any reasonable doubt that Ms. Gregory conspired with and coached Ms. Shields to elicit perjured testimony. They essentially re-wrote history which again contradicted a paid for security detailed 'Rinaldi' file. In addition, they trolled my social media accounts and created their own narratives. For example, someone had made a comment discrediting Ms. Shields and came to her defense on social media.

I could go on and on, but trust me when I say everything out of Ms Shields and Mr. Henchy's mouths were lies. To prove this any and all my actions and activities were/ are transparent on-line connected with evidentiary proof of no wrong-doing.

FACTS AND EVIDENCE.

www.TheSandyHookKidsCenter.com
www.JohnMRinaldi.com

NO Mr. Ferguson, I was in my car for Street Cleaning.

You know, so I could move my car without getting a ticket!

ASS HOLE.

THIS is the sexy shirtless pic sent to titilate Ms. Shields?

I'm gay you idiot.

Gavin deBecker places Stalkers based upon level of Romantic interest.

Gavin deBecker, you are a hack.

Hugh Jackman, Sarah Jessica Parker, Liv Tyler, + Brooke all were sent the same letter.

If you didn't want to support Gun Reform, you didn't have to go through so much trouble.

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FRAUD OF THE COURT

ANJELICA GRGORY
BRENT FERGUSON.

Official Complaint: Brent Ferguson, NY State Bar. Assistant District Attorney, City of New York

NO Mr. Ferguson, I was in my car for Street Cleaning.

You know, so I could move my car without getting a ticket!

ASS HOLE.

Commission of Prosecutor Accountability.

SUBORN PERJURY IS A CRIME- NOT A TACTIC.

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FRAUD OF THE COURT

ANJELICA GRGORY ​BRENT FERGUSON.

Official Complaint: Brent Ferguson, NY State Bar. Assistant District Attorney, City of New York

NO Mr. Ferguson, I was in my car for Street Cleaning. You know, so I could move my car without getting a ticket!ASS HOLE.

Commission of Prosecutor Accountability.

SUBORN PERJURY IS A CRIME- NOT A TACTIC.

Author

Archives

Categories

ANJELICA GRGORY
BRENT FERGUSON.

NO Mr. Ferguson, I was in my car for Street Cleaning.

You know, so I could move my car without getting a ticket!

ASS HOLE.