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

Case 3:00-cv-00835-CFD

Document 390

Filed 05/25/2004

Page 1 of 4

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: MAY 24, 2004

DEFENDANTS EXPEDITED MOTION TO REOPEN TRIAL

Defendants Mostafa Reyad and Wafa Reyad hereby respectfully move this Court to expeditiously reopen the Trial Proceedings, Mr. Brian Ainslie and Attorney David Schaefer misrepresented serious material facts. Mr. Ainslie committed perjury in his testimony under oath on April 7, 2004 before this Court, and attorney Schaefer committed a fraud upon the Court, in collaboration with Mr. Ainslie. The perjury and the fraud against United States effectuate this Court decision, and in fact they were successful to defraud the Court for the admission of certain Plaintiff s exhibits, and without that misconduct, the Court would decide different decision. The two (2) violations of perjury and fraud upon the Court entailed the misconduct of obstruction of justice necessitates immediate attention by the Court, cannot be postponed till the end of the Trial.

1

Case 3:00-cv-00835-CFD

Document 390

Filed 05/25/2004

Page 2 of 4

Plaintiff and his attorney are continuing this misconduct for more then four (4) years; caused Defendants actual damages approximately $ 15 million. For reasons stated herein and in the accompanied memorandum of law. The Honorable Court should Grant Defendant s motion, and Order the proper relief deems reasonable taking into consideration the extraordinary circumstances of this action.

2

Case 3:00-cv-00835-CFD

Document 390

Filed 05/25/2004

Page 3 of 4

By: Mostafa Reyad 2077 Center Ave # 22D Fort Lee, NJ 07024 Day Phone 203-325-4100 Home Phone 201-585-0562

By: Wafa Reyad 2077 Center Ave # 22D Fort Lee, NJ 07024 Home Phone 201-585-0562

CERTIFICATE OF SERVICE

The undersigned certifies that he mailed on the captioned date a true and correct copy to Attorney David Schaefer at 271 Whitney Avenue, New Haven, CT 06511.

Mostafa Reyad

3

Case 3:00-cv-00835-CFD

Document 390

Filed 05/25/2004

Page 4 of 4

4