Free Motion for Miscellaneous Relief - District Court of Connecticut - Connecticut

Case 3:00-cv-00835-CFD Document 511 Filed 07/16/2007 Page 1 of 3
UNETED STATES DISTRICT COURT I 1 it _ I
DISTRICT OF CONNECTICUT
INDYMAC BANK, F.S.B.
Plaintiff CIVIL ACTION NO.
3:00CV835 (CFD)
V.
IVIOSTAFA REYAD AND WAFA REYAD
Defendants
DATE: JULY 16, 2007
DEFENDANTS’ MOTION FOR EXEMPTIONS
Defendant Nlostafa Reyad and Co-Defendant Wafa Reyad, move this
Court to Declare the following properties are exempted from execution, and
declare the following properties are exempted from attachment, as a matter of
law:
1. VALIC, the Variable Annuity Life insurance Company account number
4550744, in the amount approximately $ 125,000.
2. EOUITABLE, the Equitable Life Assurance Society of the United States,
Certiiicate number 98 501 734, in the amount approximately $` 150,000.
3. NEW ENGLAND, New England Financial, a Metlife Affiliate, contract
number V 435143, in the amount approximately $ 27,000.
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Case 3:00-cv-00835-CFD Document 511 Filed 07/16/2007 Page 2 of 3
4. EQUITABLE, the Equitable Life Assurance Society of the United States,
policy number PN 86 097 685, in the amount approximately $ 125,000.
5. EQUITABLE, the Equitable Life Assurance Society of the United States,
policy number PN 86 108 388, in the amount approximately $ 140,000.
6. Bank of America, belongsto Mostafa Reyad up to $ 1,000.
7. Hudson United Bank, belongs to Wafa Reyad up to $ 1,000.
8. One car belongs to Mostafa Reyad, fair market value up to $ 1,500.
9. One car belongs to Wafa Reyad, fair market value up to $ 1,500.
CONCLUSION
For reasons supported by legal authorities demonstrated in the
accompanying memorandum of law, the Honorable Court must Grant the instant
motion, Deciare the above properties are not subject to attachments or
execution. The Court must award Defendants, interest rate of 10% per year for
every year of the seven years of wrongful attachments. The total amount of the
unlawful attachments is 35 567,000. ln sum Defendants should be awarded the
amount of $ 396,900 for the wrongful attachment. The Court upon recognition of
the damages caused by wrongful attachments, must open the judgment and re-
review PIaintiff's’s award of attorney’s fee, which includes false expenses related
to insurance policies and insurance annuities, and modify the judgment as a
matter of law and fair justice.
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Case 3:00-cv-00835-CFD Document 511 Filed 07/16/2007 Page 3 of 3
The Defendant The Defendant
I\/Iostafa Re d Wafa Reyad
A
i
By: it By: - W
Mostaf R d Wafa eyad
2077 Center Ave # 22D 2077 Center Ave # 22D
Fort Lee, NJ 07024 Fort Lee, NJ 07024
Day Phone 203-325-4100 Home Phone 201-585-0562
CERTIFICATE OF SERVICE
The undersigned certifies that he hand delivered on the captioned date a true
and correct copy to Attorney David Schaefer at 271 Whitney Avenue, New
Haven, CT 06511
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J .M_,€:f· Z
M st fa R yad
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