Free Motion for Contempt - District Court of Connecticut - Connecticut

Case 3:00-cv-00835-CFD

Document 424

Filed 09/20/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

INDYMAC BANK, F.S.B. Plaintiff CIVIL ACTION NO. 3:00CV835 (CFD)

V.

MOSTAFA REYAD AND WAFA REYAD Defendants DATE: SEPTEMBER 17, 2004

DEFENDANT S MOTION TO HELD PLAINTIFF AND ITS ATTORNEY IN CRIMINAL CONTEMPT

Defendant Mostafa Reyad hereby requests from this Court to held Plaintiff IndyMac Bank, F.S.B. and its attorney David R. Schaeffer in criminal contempt. Plaintiff and its attorney committed direct criminal contempt in the immediate view and presence of the Court on April 7, 2004, and committed indirect criminal contempt at the commencement of the action continued thereafter throughout all proceedings. They acted in such character constitute criminal offenses under United States Code. They commenced their action by perjured affidavits. Plaintiff s attorney prepared on his own eight (8) writs of garnishment, each writ cites two (2) provisions of law and defrauded Magistrate Garfinkel who rubber stamped the writs for him, and furtherly defrauded the District Clerk and caused none entry of these eight (8) writs on this action docket sheet. The Magistrate

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Case 3:00-cv-00835-CFD

Document 424

Filed 09/20/2004

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Ordered to maintain personal and business bank accounts, Plaintiff s attorney defrauded the Magistrate and obtained writs garnished all bank accounts and established on his own a powerful permanent injunction killed Defendant s business in one hit, because no business can be transacted without bank accounts, furtherly it prevented Defendant to appeal the injunction due to the absence of these writs in the Court s record. Moreover, it precluded the District Judge to conduct a fair trial. The Defendant claims to the Judge relating to the permanent injunction, and the Judge responds only to the prejudgment remedy, because he does not see the injunction, it is not on the records.

Defendant is entitled to this Court s Order to held Plaintiff and their attorney in criminal contempt. Defendant is entitled to award of his actual damages. Plaintiff s actions is wanton and willful entitle Defendant to punitive damages. Defendant s actual damages are fifteen million dollar as of todate. Plaintiff and his attorney are also entitle to a fair trial by jury if they elected, and independent prosecution, but in no event the trial can proceed fairly in abeyance of this criminal proceeding. The Court also is obligated to review de novo the permanent injunction imposed on Defendant in the amount of $ 18.5 million.

The Honorable Court must refer this motion to the office of Attorney General for possible investigation and prosecution, and review de novo the permanent injunction labeled prejudgment remedy.

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Case 3:00-cv-00835-CFD

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The Defendant Mostafa Reyad

By: Mostafa Reyad 2077 Center Avenue # 22D Fort Lee, NJ 07024 Day Phone # 203-325-4100 E-mail [email protected]

CERTIFICATION

The Undersigned certifies that he emailed and mailed a true and correct copy of this Document to Attorney David Schaefer 271 Whitney Avenue, New Haven, CT 06511 and Hand delivered to Wafa Reyad

Mostafa Reyad

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Case 3:00-cv-00835-CFD

Document 424

Filed 09/20/2004

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