🚨 MOTION FOR RECONSIDERATION FILED January 28, 2026 | JUDICIAL HIJACKING | DEFAULT JUDGMENT BYPASS | FRCP 55(a) VIOLATED - ADA VIOALTIONS @EDNYnews

EDNY Case 2:23-cv-06507-SJB-AYS

CORE VIOLATION: Judge Bulsara & Judge Shields were PERMANENTLY RECUSED on November 5 & 17, 2025 (DE [127]).

March 2024: Public statements by @SenJohnKennedy raised concerns regarding Judge Bulsara, which are relevant to the issues presented herein.(J. Bulsara nominated by @SenSchumer)

Yet on November 26, an unlawful ADMINISTRATIVE NOTE reassigned the case BACK to them—WITHOUT notice, WITHOUT explanation, WITHOUT opportunity to object.

🔴 THE LEGAL REALITY: Under 28 U.S.C. § 455, recusal is PERMANENT and divests judges of ALL jurisdiction. An administrative note CANNOT override a mandatory recusal order.

🔴 CONSEQUENCE: All post-recusal rulings are VOID AB INITIO—legally null from the moment issued.

This includes: ✓ DE [143] (Jan 16, 2026) – Dismissal ✓ Filing injunctions (Aug 14 & Sep 16, 2025) ✓ All orders after Nov 5 & 17, 2025

📋 LEGAL AUTHORITY: • Liljeberg v. Health Servs. Acquisition Corp., 486 U.S. 847 (1988) • Contreras v. Bourke (Ariz. Aug. 21, 2025) • FRCP 60(b)(4) – Void judgments must be vacated

📄 Full Motion Access: bit.ly/45EDUuG

Truth. Transparency. Justice. 🔗

@SFranklmt @ladybea67 @Jenilyn67961481 @MikeYup10 @TERYDIXON @ProEthanSmith @GWash02221732 @SamAntar @CorneliaDiNunz1 @MaryWalterRadio @W4Nevada @naomirwolf @IngrahamAngle @julie_kelly2 @LoggieNY_ @Hunter_Eagleman @BrianOSheaSPI @SteveMcNY @LitaONYC @franko_ufo @SteffyAlis72269 @BirdsForLiberty @kwasny007 @DisabledOfficer @thematthew @drrodrigo23 @DosMoscas @ConservativeNY3 @imranigra @DJTNYCLUB @UnitingNYS @ClaudiaYadette1 @KevinBerge9223 @maverick2886 @MisterScarlett @Amusement2022 @WhimsyWithStyle @SoleFranco1979 @slgarelli_cnn @FrankFurter420a @BrettDoyleMCS @DeckerKell36048 @EF039229637459 @Attorney_Cox @HouseofElon @DeckerKell36048 @RandomHvacGuy **

JUDICIAL HIJACKING:

Judges Bulsara & Shields PERMANENTLY RECUSED (DE [127]) Nov 5 & 17, 2025. Unlawful admin note (Nov 26) reassigned case without notice. 28 U.S.C. § 455 is MANDATORY—admin notes cannot override recusal. All post-recusal rulings VOID AB INITIO.

RICO ENTERPRISE EXPOSED: @WorkersLaw (Pasternack Tilker Ziegler Walsh Stanton & Romano LLP) @StradleyRonon (Stradley Ronon Stevens & Young LLP) @RivkinRadler (Rivkin Radler LLP) @DrHochfelder + First Choice Evaluation LLC

Ignored FRCP 55(a) defaults. Law firms operate ABOVE THE LAW. #EDNY #RICOEnterprise

@realDonaldTrump @POTUS @SCOTUS @elonmusk @DonaldJTrumpJr @AlinaHabba @PamBondi @FBIDirectorKash @Kash_Patel @charliekirk11 @JDVance @VP @FoxNews @VigilantFox @ImMeme0 @damonimani @megynkelly @mrddmia @ReidFirm @ProjectConstitu @Article3Project @nypost @bennyjohnson @TheBabylonBee

youtu.be/awC6Or6JXdY?si… **

🔴 CHIEF JUDGE BRODIE MUST ACT NOW

The Motion for Reconsideration demands immediate intervention under 28 U.S.C. § 137 and EDNY Rule 50.4 and 50.5

Plaintiff invoked EDNY Division of Business Rule 50.4 and 50.5 because the District Judge and Magistrate Judge assigned to the case were permanently recused and disqualified from further participation, leaving the matter without an authorized judicial officer.

Why invoke EDNY Rules 50.4 & 50.5?

Once judges are recused, they lose the authority to act. The case must be routed to the Chief Judge (Rule 50.4) or a Duty/Miscellaneous Judge (Rule 50.5) so a neutral judge with jurisdiction can hear emergency matters. Anything else risks voiding orders and due-process violations.

@EDNYnews Division of Business

Rule 50.4 expressly permits reassignment in the interest of justice where continued handling by the assigned judges is impossible or improper (judge(s) cannot properly continue, including due to recusal, disqualification, incapacity, or other circumstances). Invocation of Rule 50.4 was therefore necessary to secure prompt reassignment to the Chief Judge, prevent further void post-recusal actions, and preserve Plaintiff’s due process right to adjudication by a neutral judge with jurisdiction.

Rule 50.5 Permits and governs the administrative procedure for reassignment after a judge’s disqualification or recusal, ensuring the case is transferred to a different, authorized judicial officer and preventing further action by the disqualified judge.

DEMANDS: 1. Declare all post-recusal rulings VOID & strike DE [143] 2. Lift unlawful injunctions (Aug 14 & Sep 16, 2025) 3. Restore filing privileges + ADA electronic filing 4. Reassign to neutral judge 5. Issue Temporary Restraining Order under FRCP 65(b)

🔴 THE PATTERN: Judge Bulsara previously reversed for ignoring controlling law. Senator Kennedy’s March 2024 hearing: Judge Bulsara’s boss stated he "ignored a large collection of cases in this District."

Same defect here. He ignored 28 U.S.C. § 455.

🔴 VIOLATIONS: ✓ Recusal violation (§ 455) ✓ Injunction without notice/hearing (FRCP 65) ✓ Docket manipulation (FRCP 5(d)(4)) ✓ Denial of ADA accommodations ✓ Obstruction of justice (18 U.S.C. § 1503)

📄 Full Motion: bit.ly/45EDUuG

Truth. Transparency. Justice. 🔗

#RecusalViolation #DueProcess #EDNY

**

🚨 DOCKET MANIPULATION & OBSTRUCTION

The Motion documents systematic obstruction by the Clerk’s Office:

EVIDENCE DISAPPEARED: ✓ 32-page Letter Motion (Nov 21, 2025) – UNDOCKETED ✓ 299-page filing (DE [211]) – Docketed as SINGLE PAGE ✓ Multiple filings – RETURNED without explanation ✓ Filings marked "URGENT – EMERGENCY" – MISROUTED to recused judge

VIOLATIONS: • FRCP 5(d)(4) – Clerk CANNOT refuse proper filings • FRCP 79(a) – Docket must be accurate & unaltered • 18 U.S.C. § 1503 – Obstruction of justice

RESULT: Evidence vanishes from official record. Judges claim "no filings received." Pro Se litigant denied access to courts. Defendants protected from accountability.

This is INSTITUTIONAL OBSTRUCTION, not clerical error.

📄 Full Motion: bit.ly/45EDUuG

Truth. Transparency. Justice. 🔗

#DocketManipulation #ObstructionOfJustice #ProSeLitigant #EDNY #AccessToCourts **

🚨 ADA DISCRIMINATION & DUE PROCESS VIOLATIONS

The Motion documents systematic discrimination against a disabled Pro Se litigant.

UNLAWFUL INJUNCTIONS (Aug 14 & Sep 16, 2025): ✓ Issued WITHOUT notice ✓ Issued WITHOUT hearing ✓ Issued WITHOUT evidence ✓ Issued WITHOUT findings of fact

VIOLATIONS OF FRCP 65: Injunctions require: (1) notice, (2) hearing, (3) findings of fact, (4) evidence. NONE provided.

ADA DISCRIMINATION: ✓ Denied electronic filing (reasonable accommodation) ✓ Blocked access to courts (Title II violation) ✓ Exacerbated documented disabilities: PTSD, major depression, chronic pain, sleep deprivation ✓ Caused multiple hospitalizations

RESULT: Meaningful access to courts DENIED. Equal protection VIOLATED. Due process DENIED.

CONSTITUTIONAL VIOLATIONS: • First Amendment – Right to petition • Fifth Amendment – Due process • Fourteenth Amendment – Equal protection • ADA § 12132 – Reasonable accommodations • ADA § 12203 – Anti-retaliation **

🚨 DEFAULT JUDGMENT BYPASS | FRCP 55(a) VIOLATED

The Motion exposes how DE [143] bypassed mandatory default procedures.

DEFENDANTS IN DEFAULT: ✓ Sam Cohen, Esq. ✓ Matthew Funk, Esq. ✓ Ginu Jacob, Esq. ✓ Joseph Mercurio, Esq. ✓ Mariana Vizuete ✓ Andrew Ziemianski, Esq.

WHAT HAPPENED: Plaintiff filed DEFAULT JUDGMENT MOTIONS (DE [125], DE [127]) post-recusal requesting entry of default under FRCP 55(a) for defendants who failed to plead or defend.

The Clerk refused to enter default judgment despite Plaintiff’s compliance with the procedural requirements and the absence of any lawful impediment. This refusal occurred notwithstanding the Clerk’s nondiscretionary duty under Federal Rule of Civil Procedure 55(a)–(b) to enter default and default judgment where a party has failed to plead or otherwise defend, and it further compounded the jurisdictional and due process violations already present in this case.

JUDGE BULSARA’S RESPONSE: @EDNYnews Sua sponte dismissal (DE [143]) WITHOUT addressing default, WITHOUT notice, WITHOUT hearing.

VIOLATION: FRCP 55(a) mandates entry of default when shown by affidavit that a party failed to plead or defend. Judge Bulsara BYPASSED this mandatory process.

RESULT: Defaulting defendants SHIELDED from liability. Pro Se plaintiff DENIED default judgment. Mandatory procedural rules IGNORED.

This is OBSTRUCTION OF JUSTICE under 18 U.S.C. § 1503. **

🚨 CALL TO ACTION | DEMAND ACCOUNTABILITY

The Motion for Reconsideration is filed. Now comes the critical moment.

CHIEF JUDGE MARGO K. BRODIE must act under 28 U.S.C. § 137 and EDNY Rule 50.4.

WHAT’S AT STAKE: ✓ Judicial integrity ✓ Access to courts for Pro Se litigants ✓ Protection of disabled litigants ✓ Rule of law

WHAT NEEDS TO HAPPEN: 1. Vacate all post-recusal orders (void ab initio) 2. Lift unlawful injunctions 3. Restore filing privileges 4. Reassign to neutral judge 5. Issue Temporary Restraining Order

THIS IS NOT JUST ONE CASE. This is about whether courts will hold themselves accountable.

322 PAGES OF EXHIBITS document: ✓ Recusal violations ✓ Docket manipulation ✓ Obstruction of justice ✓ ADA discrimination ✓ Due process violations ✓ Judicial misconduct

📄 READ THE MOTION: bit.ly/45EDUuG

SHARE THIS. DEMAND ACCOUNTABILITY.

Truth. Transparency. Justice. 🔗 **

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