IN THE UNITED STATES DISTRICT COURTDISTRICT OF CONNECTICUT

PAUL SHAFER AND JOSHUA HARDER. )

) CASE NO. 3:12-CV-00039-AWTPlaintiffs,

v. ) JUDGE THOMPSON

RODERICK BREMBY, )

Defendants. )

REPLY MEMORANDUM IN SUPPORT OFMOTION OF BETTY J. KING

TO FILE AS INTERVENOR OR AS AMICUS CURIAE

I. Public Notice of Deceit as Published on Thanksgiving Day, 22 Nov.

2012.

Dear Commissioner Bremby and Attorney Callahan: You two and your happy little Affiant Silvana M. Flattery are a bunch of

jive turkeys. First of all Flattery's Affidavit must be stricken because she has

no firsthand knowledge of what I sent Diane Wood. Only Diane Wood can

offer an Affidavit but she won't because she won't lie to cover your tracks.

Therefore I am not even reading said Affidavit. All right, I did read it and note

that she claims the W-1 was not sent until fall of 2012 when in point of fact I

have proof that it was sent in November of 2011 as noted below. Then there

were at least ten (10) emails to Diane Wood requesting additional information

about what Intervenor could do to expedite the process with no mention from

he about any outstanding issues, because you are a couple of jive turkeys.

I do not suffer lies and fools gladly, and I am going to be submitting my

counter Affidavit to the Court along with various emails proving the my

mother's application was provided in full in December of 2011, or nine (9)

months prior.  Apparently you all believe I don't have the common sense to

retain emails when dealing with government attorneys, even though I was a

government attorney. I aim to rip you to shreds for you patent dishonesty

because you did not make a Good Faith inquiry into the substance of your

arguments on timeliness. All you had to do was check your emails. 

1

However thank you for this because it neatly removes any credibility

you were hoping to establish with the Court regarding your other defenses. If

you will lie about receipt of documents you will lie about anything.  A Motion

for Sanctions will be sent to you contemporaneously with this Reply

Memorandum under the Fair Harbor provisions of Rule 11.

II. Defendant's First and Primary Defense of Timeliness is at Once Completely without Merit and Sanctionable Based on the Email Chain Between Intervenor and Administrator Agent/Processor Diane Wood.

The application for Betty King was COMPLETE on 15 December 2011

yet Defendants failed to take action until Intervenor sued them in September

of 2012.

Here is a summary of emails for the Court’s edification. This response is a

sworn response, noting that Diane Wood told Intervenor to keep sending

these emails regarding the delay so that they could document the problem.

****************

On January 23, 2012: Betty King info.

Hi Diane,I know I am blowing up your email, sorry. I also know you've got about a billion other things on your plate as well.

Thanks,*****************

On January 18, 2012: Any word yet on Betty King app? Thanks, Diane. 

On 16 Dec. 212 Diane Wood sent a confirmatory email regarding the last document, i.e. the Divorce Decree:

2

The package will expire on Sunday January 15, 2012 at 08:22:55 EST5.

***************On 15 December Intervenor provided the last necessary document -- the divorce decree:

***************On 14 Nov. 2011 Intervenor wrote: Betty King updates -- final docs for Title XIX 

1. Foreclosure: I found the Sheriff sale proof online and it is attached. Please confirm you can open and read it.  2. U.S. Bank: The package was sent and is at my apartment awaiting my return on Wed night or TH morning -- I will overnight to you.  3. Divorce Decree My father is going to fax to me shortly and I will scan and send in the next 48 hours. 4. W-1SA: Calling you now I need to find this document and send it to you. Will call you again to find it. That should complete everything. Again Diane thank you for your help. Sincerely, 

3

********** On 22. Nov. Intervenor wrote: The Application. Note this email contained the W-1.

That is why on 20 Jan, 2012 Intervenor wrote Diane Wood: Hi Diane, I was just looking at the submission.... is there anything more that we could do. I'm stressing. Thanks and have a great weekend. 

Intervenor's sister – a very established corporate executive with no propensity to lie -- wrote on the same day: Thanks Chris, good follow up. We are both concerned about the process and outcome. Thanks for your attention to this matter.

********** 27 August: Hello Ms. Wood, We are all concerned about our mother and this process. Do you have any more news or information for us? Thank you in advance. Sincerely, 

Again from Intervenor's sister: Thanks for the note Chris. Ms Wood as Chris stated we are concerned and I do not understand why this had not been

4

resolved. We would like a full accounting of the procedures and the plans to get this approved or what has to be done to escalate it. At this stage we can no longer continue waiting. 

As such, Defendant's first Defense is clearly without merit and this

Court must issue a stern rebuke to Defendants via the immediate imposition

of sanctions.

II.   Defendant's Second Defense Regarding Commonality of Actions is Based on the First and is Also Clearly Without Merit.

Intervenor submits that this purported defense is almost as lame as

the first one because it is in effect a restatement of the first one because all

they are doing is stating that this case does not have common operative facts

because the application was tardy… but it was not as proved. This litigation,

as the other ones involved, concerns the failure of a non-delegable duty, i.e.

the Defendant’s responsibility to timely process a Title XIX application. The

application was 100% complete on 15 December, 2011 and Defendants are

attempting to obfuscate this issue with an Affidavit by a person with no first

hand knowledge of the communications. That Affidavit must be summarily

stricken from the Record and Intervenor must be granted approved status

immediately. 

REQUEST FOR EVIDENTIARY HEARING

Further, should the Court have any doubts or questions whatsoever,

Intervenor will appear Under Oath at a proper evidentiary hearing. Perhaps

Defendants will bring Ms. Wood to such a hearing, instead of some would-be

intervenor with no first hand knowledge of the facts. Respectfully submitted

and Sworn as if on Oath and subject to the Pains of Perjury.

/s/ Christopher King, J.D._____________________________Christopher King, J.D.http://KingCast.net -- Reel News for Real Peoplekingjurisdoctor@gmail.com617.543.8085

_____________________

5

NOTARY PUBLIC

MY COMMISSION EXPIRES: ______________

6

CERTIFICATE OF SERVICE

I the undersigned, solemnly swear that a true copy of this MemorandumWas delivered via email on 22 November 2012

And viaRegular U.S. Mail, 23 September 2012 to:

Defendant Roderick Bremby c/o Jennifer L. CAllahan, Esq. ct 29033

CT AG55 Elm Street PO Box 120

Hartford, CT 06141hugh.barger@ct.gov

Plaintiffs Shafer and HarderSheldon Toubman (ct08533)

New Haven Legal Assistance Assoc. 426 State StreetNew Haven, CT 06510-2018

Phone: 203.946.4811Fax: 203.498-9271

stoubman@nhlegal.org

__________________________________KingCast.net

By and through Christopher King, J.D.617.543.8085m

7