SUING LAWYERS YORAM NACHIMOVSKY & YONATAN LEVORITZ FOR MALICIOUS PROSECUTION AND FRAUD

SUPREME COURT OF THE STATE OF NEW YORKCOUNTY OF KINGS_______________________________________________________

MICHAEL KRICHEVSKY,Plaintiff,

-against-

YONATAN LEVORITZ, ESQ, YORAM NACHIMOVSKY, ESQ, ELENA SVENSON,

Defendants.

JURY TRIAL DEMANDED

Filed:_____________

INDEX NO. 24714/2010

Plaintiff designates Kings County as the place of trial.

AMENDED VERIFIED COMPLAINT

The basis of venue isthe County in which the causes of action aroused

Plaintiff, Pro Se and for his Verified Complaint, respectfully alleges, upon information

and belief:

1. JURISDICTION

1. This action is for money damages in excess of jurisdictional limits of all lower courts.

2. The plaintiff, MICHAEL KRICHEVSKY, at all times herein mentioned was and still is

a resident of the County of Kings and the State of New York.

Michael Krichevsky v. Levoritz, et al Page 1 of 31Index No:24714/2010

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3. The defendant, YONATAN LEVORITZ, Esq., at all times herein mentioned was and

still is a resident of the County of Kings and the State of New York.

4. The defendant, YONATAN LEVORITZ, Esq., at all times herein mentioned was and

still is conducting a business in the County of Kings and the State of New York.

5. The defendant, YORAM NACHIMOVSKY, Esq. at all times herein mentioned was

and still is a resident of the County of Kings and the State of New York.

6. The defendant, YORAM NACHIMOVSKY, Esq. at all times herein mentioned was

and still is conducting a business in the County of Kings and the State of New York.

7. At all times herein mentioned lawyers-defendants derived substantial revenue from

services rendered in the County of Kings and the State of New York.

8. The defendant, ELENA SVENSON, at all times herein mentioned was and still is a

resident of the County of Kings and the State of New York.

9. The causes of action aroused out of “assisted” by lawyers-defendants litigation between

defendant SVENSON against plaintiff in numerous courts and actions in County of

Kings and the State of New York.

2. PARTIES

10.MICHAEL KRICHEVSKY – victim, damaged and personally injured plaintiff.

11.ELENA SVENSON – former girlfriend of plaintiff with whom plaintiff has son,

DAVID SVENSON.


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12.YONATAN LEVORITZ, ESQ. - lawyer representing defendant SVENSON under

secret supervision of YORAM NACHIMOVSKY, ESQ. in the Kings County Family

Court action against plaintiff.

13.YORAM NACHIMOVSKY, ESQ. – lawyer representing defendant SVENSON in

Kings County Family Court and Kings County Supreme Court action against plaintiff

bearing index No 33343/2008

14.YORAM NACHIMOVSKY, ESQ. – lawyer still secretly representing defendant

SVENSON (as landlady) and codefendants VICTORIA EDELSTEIN and BORIS

KOTLYAR (as tenants) in Kings County Supreme Court action against plaintiff

bearing index No 33343/2008.

15.YORAM NACHIMOVSKY, ESQ. – lawyer who in 2008 represented petitioner

SVENSON (as landlady) and respondents VICTORIA EDELSTEIN and BORIS

KOTLYAR (as tenants) in Kings County Landlord & Tenant Court against each other

in eviction action.

16.YORAM NACHIMOVSKY, ESQ. – lawyer who in 2009 represented co-defendants

SVENSON (as landlady) and VICTORIA EDELSTEIN and BORIS KOTLYAR (as

tenants) in Kings County Civil Court action bearing index No 99601/2009.

3. FACTS AND UNREBUTTED ALLEGATIONS AS ADMISSIONS OF FACTS COMMON TO ALL CAUSES OF ACTION

17.On or about January of 2008 KRICHEVSKY and SVENSON, unmarried couple,

decided to break apart as a family.


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18.At that time they lived at 4336 Manhattan Ave, Brooklyn, New York with their son

DAVID SVENSON.

19.DAVID SVENSON was 14 years old teenager attending school.

20.Plaintiff, employed at that time with Wittenstein and Associates, PC, financially

supported whole family.

21.Defendant SVENSON was unemployed during party’s relationship starting in 1992.

22.SVENSON and KRICHEVSKY own condominium unit located at 120 Oceana Drive

West, apt 5D in Brooklyn, New York, which later became the subject of litigation in

Supreme court action bearing Index No 33343/2008

23.Said condominium was rented by VICTORIA EDELSTEIN and BORIS KOTLYAR

for $2575 per month on a month to month tenancy starting from December of 2006.

24.VICTORIA EDELSTEIN and BORIS KOTLYAR later became defendants in the

above action for, inter alia, torturous interference with prospective economic

relationship.

25.Plaintiff was solely and contractually responsible for first and second mortgage

payments to the banks.

26.Mortgage plus condominium fees expenses were more than the monthly rent and

owners were trying to sell this condo in order to stop losing money.

27.During 2008, SVENSON and KRICHEVSKY were in discussions of future child

support, how to fairly divide their assets and to go their own ways.


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28.Due to SVENSON’s complete ignorance of law and fairness principles, as well as lack

of trust, plaintiff was having a hard time in negotiations and suggested that she hire an

attorney to negotiate with plaintiff.

29.She promised to do this and let plaintiff know when she was ready.

30.On or about July of 2008 plaintiff found an interested buyer of the above mentioned

condo, but tenants refused to let this buyer in to see this apartment.

31.On or about July of 2008, after discussing this incident with SVENSON, plaintiff hired

attorney Robert Rosenblatt to represent them in an eviction proceeding against

VICTORIA EDELSTEIN and BORIS KOTLYAR in order to recover control over the

condo.

32.During October-November court appearances attorney Rosenblatt learned that

SVENSON was simultaneously represented by lawyer YORAM NACHIMOVSKY

against plaintiff.

33.Rosenblatt informed plaintiff that SVENSON allegedly signed a lease to VICTORIA

EDELSTEIN and BORIS KOTLYAR for $2850 per month starting from October 1,

2008, and she received first month rent and deposit in the total amount of $5700.

34.Rosenblatt informed plaintiff that NACHIMOVSKY prepared, and SVENSON signed

a stipulation discontinuing the eviction action against tenants.

35.Due to the events in paragraphs 16-18, Rosenblatt started litigation in Supreme Court

action bearing Index No 33343/2008 to protect plaintiff’s interests and force the sale of

said condominium to above mentioned buyer.


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36.At the same time SVENSON became verbally abusive toward plaintiff.

37.At the same time SVENSON blackmailed plaintiff and threatened to report plaintiff to

FBI and IRS.

38.In the summer of 2008, SVENSON and plaintiff’s son moved out of apartment on

Manhattan Avenue into her cooperative apartment at 2620 Ocean Parkway, apt 3K in

Brooklyn.

39.At that point plaintiff still supported them with cash.

40.On or about October 21, 2008 SVENSON looted plaintiff’s apartment on 4336

Manhattan Avenue in Brooklyn.

41.On October 27, 2008 SVENSON filed false Family Offence Petition against plaintiff.

42.On October 27, 2008 after she, ex-parte, obtained order of protection against plaintiff

(but unknown at that time to plaintiff), she brought party’s son DAVID to plaintiff’s

place of work, and together harassed plaintiff’s employer, Mr. Wittenstein, and

demanded that he fire plaintiff.

43.In order to avoid contact with SVENSON, protection of personal belongings, and

possible provocation of violence by SVENSON, plaintiff on October 21, 2008, after

apartment looting incident, changed locks on 4336 Manhattan Avenue.

44.In the beginning of November 2008, plaintiff was served with order of protection at his

work by city marshal.

45.Fear of being arrested as a STANDARD OPERATING PROCEDURE by police

enforcing order of protection, plaintiff abandoned apartment and became homeless.


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46.In December of 2005 plaintiff’ bought a house located at 4221 Atlantic Avenue in

Brooklyn, New York that needed renovation.

47.Plaintiff was and still is the sole owner and mortgage payor of said house.

48.In June of 2008 plaintiff started renovation of said house with assistance of

construction company LEON CONSTRUCTION, which provided financial assistance

as well.

49.During the times that SVENSON blackmailed plaintiff, she also told him:”I am going

to make sure that you will not finish renovation, and instead file for bankruptcy”.

50.During November 2008, Family Court appearance, NACHIMOVSKY blackmailed

plaintiff and tried to coerce him into short sale of mentioned condo to VICTORIA

EDELSTEIN and BORIS KOTLYAR.

51.NACHIMOVSKY told plaintiff that they will “reveal in open court all machinations of

plaintiff and it will cost him much much more (implying criminal prosecution) than

what they ask”.

52.NACHIMOVSKY refused to first mediate child support issue, and gave plaintiff an

ultimatum of temporary child support amount of $2500 per month.

53.That incident was reported to Rosenblatt and demand was made by plaintiff that

NACHIMOVSKY resign from the case due to outrageous conflict of interest and

unprofessional conduct.

54.NACHIMOVSKY told Rosenblatt that he will NO longer represent SVENSON,

VICTORIA EDELSTEIN and BORIS KOTLYAR.


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55.Plaintiff learned that it was hoax.

56.NACHIMOVSKY still represents above mentioned people through puppet - puppeteer

scheme.

57.NICOLAS RATUSH, ESQ. – employee of NACHIMOVSKY, ESQ.

58.NICOLAS RATUSH, ESQ. – lawyer-puppet as employee of NACHIMOVSKY,

lawyer-puppeteer.

59.RATUSH represents VICTORIA EDELSTEIN and BORIS KOTLYAR in Supreme

Court action bearing Index No 33343/2008 against plaintiff.

60.RATUSH represents VICTORIA EDELSTEIN and BORIS KOTLYAR in Kings

County Civil Court action bearing Index No 99601/2009 against plaintiff.

61.YONATAN LEVORITZ, ESQ. – lawyer-puppet, through which NACHIMOVSKY

represents SVENSON by continuous pattern of blackmail, fraud and extortion.

62.MICHAEL BIANCANELLO, ESQ. - lawyer-puppet, recently resigned, represented

SVENSON against plaintiff in Supreme Court action bearing Index No 33343/2008

against plaintiff.

63.NACHIMOVSKY, LEVORITZ, BIANCANELLO AND RATUSH hired to act, acted

and/or continue to act in capacity of “contractual assassins” to harm plaintiff.

4. CAUSES OF ACTION

4.1 COUNT I: AIDING AND ABETTING THE COMMISSION OF TORT AS TO ALL OF THE DEFENDANTS

64.All allegations above are incorporated by this reference as if fully restated herein.


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65.SVENSON, under pretense of seeking to protect the best interest of the child, started a

war and hired NACHIMOVSKY to commit, advice, aid and abet her in all further

stated torts and criminal activities in order to gain financially and harm plaintiff.

66.NACHIMOVSKY knowingly and willingly accepted employment and created

numerous fraudulent schemes through conflict of interest in violation of code of

professional responsibility.

67.One of such schemes was conspiracy to create backdated lease between SVENSON,

EDELSTEIN and KOTLYAR, to present it in court and to plaintiff’s lawyer, Robert

Rosenblatt, Esq.

68.That scheme resulted in profit of $34,200.00 from rent to SVENSON, while plaintiff

was left with immediate loss of paying condominium expenses and necessity of starting

the Supreme Court action against conspirators as eviction action failed.

69.That scheme substantially undermined and prejudiced plaintiff’s financial rights, later

on resulted in loss of the buyer of condo, plaintiff’s inability to pay mortgages and loss

of credit rating, which further damaged and crippled plaintiff’s finances.

70.That scheme resulted in all of the properties placed in foreclosure.

71.That scheme is still in play through NACHIMOVSKY’s lawyer-puppet RATUSH.

72.After NACHIMOVSKY’s creation of racketeering enterprise by employing his

lawyers-puppets, they knowingly and willingly continued to harm plaintiff, as well as

aiding and abetting SVENSON in her war against plaintiff.


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73.LEVORITZ created, aided and abetted SVENSON in creation and filing of fraudulent,

perjurious and misleading instruments in child support proceeding of Brooklyn Family

Court.

74.Misleading and perjurious actions and testimony of LEVORITZ resulted in unfair child

support order against plaintiff.

75.Targeted actions of LEVORITZ resulted in plaintiff’s loss of job, income and money.

76.Losses above resulted in plaintiff’s loss of credit and failure of his renovation project

on 4221 Atlantic Avenue house.

77.On the Supreme Court front NACHIMOVKSY’s lawyer-puppet, BIANCANELLO,

through misleading and fraudulent pleadings convinced judge that $34,200.00 profit is

actually money spent on SVENSON’s son as a child support and that this issue being

decided by Family Court when he knew it was not.

78.While BIANCANELLO was “protecting” interests of the child in Supreme Court, he

knew that LEVORITZ is “protecting” same child by asking for child support in Family

Court and while KRICHEVSKY was paying to SVENSON $627.00 per month in

temporary child support pursuant to order of Family Court.

79.These acts resulted in substantial loss to plaintiff as family court ordered plaintiff to pay

SVENSON $31,599.42 in arrears.

WHEREFORE, the plaintiff demands judgment against each defendant awarding

damages in the amount exceeding jurisdictional limits of all lower courts, together with


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interest and the costs and disbursements of this action, and such other and further relief

as to Interest of Justice and this Court seems just and proper.

4.2 COUNT II: CONCERT OF ACTION AS TO ALL OF THE DEFENDANTS


81.In 2009, plaintiff’s attorney Daniel Singer filed Emergency Order to Show Cause with

TRO in Supreme Court action bearing Index No 33343/2008 against SVENSON,

EDELSTEIN and KOTLYAR in order to gain control over rent money to be able to

pay mortgage and keep properties out of foreclosure.

82.RATUSH and BIANCANELLO stipulated with the Judge of Supreme Court Hon Bert

Bunyan that SVENSON will pay $7,000.00 and EDELSTEIN with KOTLYAR

$1,000.00 in escrow account of Daniel Singer, so he will pay mortgage to keep

properties out of foreclosure.

83.However, all of them became in Contempt of Court and in concert failed to send

checks.

84.None of the puppets contacted Mr. Singer in order to apologize or get more time to

comply.

85.When Mr. Singer contacted them, all of them had arguments as to why they should not

pay, even though they agreed at the time of stipulation.

86.RATUSH, instead of advising his clients to pay $1,000.00 and comply with this order,

engaged in frivolous motion practice in order not to pay this $1,000.00.


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87.This motion practice cost more than $1,000.00 and was designed to harm and

financially wear out plaintiff.

88.Simultaneously with above mentioned frivolous motion practice, LEVORITZ engaged

plaintiff in even costlier frivolous motion practice completely wearing out plaintiff

financially.

89.Plaintiff had no choice but to finish Family Court hearing as Pro Se.

90.For SVENSON, having two lawyers in two different courts instead of one lawyer

standing in front of one judge, was necessary to be able to claim different sets of facts,

ask for different reliefs, pointing to other lawyer-puppet, play stupid and confuse two

different judges, to divide subject matter jurisdiction and get double recovery of child

support and arrears, at which they succeeded under orchestration of NACHIMOVSKY

and acting in concert.

91.That NACHIMOVSKY scheme yet another proof for aid and abet cause of action

92.Actions of all lawyers-defendants constitute Fraud upon the Court by Officers of the

Court.





4.3 COUNT III: CONCEALMENT OR DESTRUCTION OF EVIDENCE (EVIDENCE SPOLIATION) AS TO ALL OF THE DEFENDANTS



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94.In 2008, SVENSON, acting upon advice and/or knowledge of NACHIMOVSKY, stole

plaintiff’s personal records, bills, receipts, copies of income tax filings for prior years,

W-2 forms, tax bills and computer back up media.

95.That evidence was destroyed or concealed (it is unknown which) but was not produced

during proceeding.

96.During child support hearings in Family Court, after NACHIMOVSKY’ substitution by

LEVORITZ, he knowingly and selectively presented favorable to SVENSON

plaintiff’s documents over objection of plaintiff’s attorney that they been stolen from

plaintiff and, therefore, not admissible.

97.Then, LEVORITZ demanded documents from plaintiff knowing that plaintiff is not in

possession of them.

98.Then, LEVORITZ blamed plaintiff for being evasive and uncooperative.

99.Absence of this evidence played a major role in plaintiff’s defense and rendered

unfavorable order against plaintiff.





4.4 COUNT IV: MALICIOUS ABUSE OF LEGAL PROCESS AS TO ALL OF THE DEFENDANTS

100. All allegations above are incorporated by this reference as if fully restated herein.

101. All of the defendants refused to mediate disputed issues with plaintiff.


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102. On October 27, 2008 Defendant quietly filed fraudulent Petition for Order of

Protection against plaintiff forcing him out of his apartment on 4336 Manhattan Ave in

Brooklyn, New York, which defendant abandoned in summer of 2008 and moved to

her apartment at 2620 Ocean Pkwy, Apt 3K, Brooklyn, New York.

103. When Police came to arrest plaintiff, but missed him, plaintiff fled this apartment

for the fear of been arrested if he stayed there.

104. Plaintiff became homeless and suffered a great deal of emotional distress, as well as

loss of productive time and energy.

105. That willful and malicious act caused plaintiff to suffer financial loss when he fled

that apartment.

106. Plaintiff hired attorney Charles Gayner, Esq. to represent him in court which cost

plaintiff $5,000.00.

107. During said Order of Protection hearing, this petition was withdrawn by

NACHIMOVSKY, before the court had any opportunity to rule and it was dismissed.

108. Neither SVENSON, nor plaintiff’s son DAVID were afraid of contact with plaintiff

as they willfully entered plaintiff’s place of work few hours after obtaining order of

protection, and which they were supposed to avoid.

109. On April 22, 2010 Respondent filed Petition to modify his child support obligation

due to the fact that he lost his job.

110. The hearing was adjourned by Magistrate Fasone from May 18 to August 6 over

Respondent’s Objection.


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111. Defendant’s reason for such a long adjournment period was the argument that her

attorney Mr. Levoritz has “celebrity status and is already booked for the summer”.

112. In reality this was just another dirty trick to deny Respondent due process and to

“milk more money” from Respondent’s unemployment benefits.

113. While been so busy, Mr. Levoritz failed to answer my petitions for modification and

custody, and instead served plaintiff with petition to hold him in contempt for violating

the court order of not paying ordered child support, even though plaintiff notified

respondent that he is unemployed.

114. On June 28, 2010 after custody hearing, LEVORITZ approached respondent and

“made him an offer he cannot refuse”: plaintiff withdraws his custody petition in

exchange for not sending plaintiff to jail, and arrears will be converted into money

judgment.

115. Such act constitutes extortion and is prohibited by lawyer’s Ethics as well.





4.5 COUNT V: ABUSE OF PROCESS AS TO ALL OF THE DEFENDANTS


117. During civil actions that defendants engaged plaintiff in, as a standard operating

procedures they used frivolous motion practice as defined by NYCRR rule 130-1.1.


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118. During civil actions that defendants engaged plaintiff in, as a standard operating

procedures they used delay and adjournment tactics to harass and wear out plaintiff

financially, emotionally and to gain more money from their acts that otherwise they

will not gain.

119. Defendants went as far as been in contempt of court as officers of the court in order

to deny plaintiff access to justice.





4.6 COUNT VII: LEGAL FRAUD AS TO ALL OF THE DEFENDANTS


121. During litigation induced by the defendants, perjurious documents were created and

filed in courts under penalty of perjury.

122. During litigation induced by the defendants, perjurious statements were made under

penalty of perjury in courts.

123. Material facts were misrepresented and plaintiff’s statements were misquoted in

order to confuse judges and/or create bias against plaintiff.

124. Defendants obstructed justice every time they had an opportunity to do so.

125. Felonious witness tampering and lies were standard operating procedures.

126. Frivolous motion practice was standard operating procedure.


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127. According to RES JUDICATA doctrine, LEVORITZ did not have any right to claim

arrears on child support since BIANCANELLO in Supreme Court action pleaded that

$34,200.00 rent money were spent on child support and SVENSON stipulated with

Hon. Bert Bunyan that she will pay back $7,000.00 to plaintiff, which she also failed to

do.

128. Such acts are criminal in nature and constitute Fraud upon the Court.

129. If lawyers-defendants were not hired by SVENSON to act as “contractual assassins”

to harm plaintiff, than they acted in their own best interest and advised SVENSON not

to mediate disputed issues with plaintiff in order to churn more legal fees for

themselves.

130. These lawyers acted and gave legal advice to SVENSON which was contrary to her

and/or her child’ best interests.

131. Fraud against SVENSON negatively affected plaintiff as well.

132. Acts like these destroy public confidence in our legal system and judiciary as a

whole.

133. All lawyers are officers of the Court and their Fraud upon the Court triggers their

disbarment and referral to appropriate authorities.






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4.7 COUNT VIII: SLANDER AS TO LEVORITZ


135. On August 6, 2009 during child support hearing in Kings County Family Court, Part

27, LEVORITZ made several malicious and slanderous allegations about plaintiff on

the record to support magistrate Fasone and others present:

a) Your Honor, with all due respect this gentleman has complete control over his

income… He works almost as a partner in a law firm, Your Honor.

b) I am going to explain it. He brings in clients for the law firm and receives a

percentage of the recovery on personal injury matters.

c) If you look at his tax return his tax return reflects the fact that he actually

owned a company and he put everything through his company and not through

him.

d) Because it’s not necessary reported on a W-2, Your Honor. No, in the past

some of it has been reported on W-2, some of it has gone through the

company. He shelters it in different…

e) The Court: “His income is diverted, but that doesn’t mean his employer is

giving him extra income. Unless you’re gonna tell me he’s in cahoots with

these people…” LEVORITZ:”That’s exactly what I’m saying, Your Honor.

As I said before, he’s a pseudo-partner in this particular business…”

136. On October 8, 2009 during continuation of child support hearing which started on

August 6, 2009 in Kings County Family Court, Part 27, LEVORITZ made several


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malicious and slanderous allegations about plaintiff on the record to support magistrate

Fasone and others present:

a) Isn’t it true that you have no time to rest because you’re actually an owner of

Wittenstein and Associates …

b) Your Honor, unfortunately, in certain communities it does happen where non-

lawyers actually own law firms, and it’s a lawyer that’s used as a front”.

137. On January 6, 2010 during continuation of said child support hearing in Kings

County Family Court, Part 27, LEVORITZ made several malicious and slanderous

allegations about plaintiff on the record to support magistrate Fasone and others

present:

a) His Affidavit of Net Worth has in excess of $200,000 in annual expenses. If

he claims he made $56,000, he spent roughly four times that amount, not

including what he spent on constructing the two family house…

138. LEVORITZ knew these statements were false and designed to influence bias and

prejudice of the court against plaintiff.

139. LEVORITZ’ intentionally and unjustifiably made those statements.

140. Levoritz did not present any evidence to support his allegations.

141. LEVORITZ intentionally and unjustifiably did not put defendant SVENSON on the

stand to examine and get these allegations from her, because then she would be cross-

examined by plaintiff’s attorney.


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142. LEVORITZ intentionally and unjustifiably refused to depose plaintiff and produce

defendant SVENSON for deposition so that there will be no statements or facts he did

not want to know in order to be able to slander plaintiff and have slanderous

accusations and arguments during hearing.

143. LEVORITZ made unsworn testimony, making it look as if he has firsthand

knowledge of facts after due diligence done by him when he did not.

144. LEVORITZ knew that he will not be cross-examined by plaintiff’s lawyer.

145. LEVORITZ knew that magistrate Fasone labeled KRICHEVSKY as moneyed party

and looking for a reason to award maximum amount of child support as he has personal

interest in the outcome of this case.

146. As result of LEVORITZ’s “pitching” this slanderous accusations to Fasone, Fasone

“hit a home run” by ordering plaintiff to pay defendant maximum amount of money he

could possibly come up with.

147. To return a favor, Fasone awarded defendant’s legal fees against plaintiff.

148. As the direct or proximate result of this tort plaintiff was fired from his job.

149. As the direct or proximate result of this tort construction company LEON

CONSTRUCTION terminated renovation of 4221 Atlantic Avenue house living

plaintiff devastated.

150. LEVORITZ achieved his goal as “assassin”.

151. As the direct or proximate result of that tort, the damages alleged by the plaintiff

were sustained while LEVORITZ and SVENSON were involved in harassment and


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slander activity of plaintiff’s employer and contractor, which was entered into with full

knowledge of the potential hazard thereof. That the inherent risk incident to such

activity, and that such risk and any damages flowing therefrom were foreseeable,

expected and assumed upon entering into and continuing such activity.





4.8 COUNT IX: INJURIOUS FALSEHOOD AS TO LEVORITZ AND SVENSON


153. Plaintiff had employment contract for many years with Wittenstein & Associates,

PC.

154. Plaintiff had business contract with LEON CONSTRUCTION to renovate and

finance 4221 Atlantic Avenue project.

155. Defendants knew about existence of said relationships.

156. Defendants’ intentional and unjustifiable interference with plaintiff’ personal

business during child support proceeding brought negative results and barred no fruits.

157. Due to slanderous utterance and publication of false statements, plaintiff’s

reputation was damaged in the eyes of above mentioned persons.

158. By harassment activities against them, they were threatened to be involved in this

litigation, incur financial loss, loss of productive time and energy.


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159. Through harassment activities against them, they were induced to refrain from

continuing economic relationship with plaintiff in order to avoid harassment and be left

alone.

160. Above mentioned persons terminated their economic relationship with plaintiff.

161. As direct result of forgoing, plaintiff was deprived from prospective economic

advantages.





4.9 COUNT X: EQUITABLE SUBROGATION AS TO ALL OF THE DEFENDANTS


163. During this litigation that defendants engaged plaintiff in, all defendants were

unjustly enriched.

164. Due to above mentioned child support order and income execution, defendants

extorted and continue to extort 65% of plaintiff’ income and unemployment insurance

benefits.

165. Plaintiff was forced to defend himself and his interests by hiring lawyers.




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4.10 COUNT XI: INTENTIONAL OR MALICIOUS HARM TO ANOTHER AS TO ALL OF THE DEFENDANTS (PRIMA FACIE TORT)


167. Above mentioned act and/or series of acts were malicious and unlawful.

168. These acts were made without legitimate excuse or justification.

169. As the direct result of these acts plaintiff suffered and continues to suffer great

financial loss and personal injuries triggering award of special damages to be

determined at trial.





4.11 COUNT XII: INVISIBLE HARM CAUSED BY SEPARATE TORTFEASORS AS TO ALL OF THE DEFENDANTS


171. Some or all of the acts by the defendants could be independent and/or separate from

each other.


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172. However when they combined together, caused and/or produced single and/or

successive and/or subsequent injuries which is impossible to distinguish from each

other and/or determine who caused more damage.

173. Such injuries are impossible to apportion amongst all of the tortfeasors.

174. Therefore all defendants jointly and severally liable for harm and injuries caused to

plaintiff.





4.12 COUNT XIII: RECOVERY OR CONTRIBUTION FROM TORTFEASORS AS TO ALL OF THE DEFENDANTS


176. Respondent, as the natural guardian of his son David Svenson, declares that

LEVORITZ, during his “zealous” representation of SVENSON in child support

proceeding against plaintiff, and in the name of the best interests of the child committed

legal malpractice causing plaintiff to lose his job and other economic opportunities.

177. Now that plaintiff is unable to fully comply with FASON’s child support order,

LEVORITZ must contribute to past, present and future compliance with plaintiff’s

child support obligation LEVORITZ illegally “won”, but made respondent injured and

unemployed.


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178. LEVORITZ’ intentional and/or negligent interference with plaintiff’ personal

business during representation of defendant SVENSON brought negative results and

barred no fruits.

179. As the direct result of plaintiff’s injury and loss of his job, he breached contract with

LEON CONSTRUCTION and owes damages to LEON CONSTRUCTION.

180. The damages aroused in this action are direct or proximate consequences of legal

malpractice and/or strict liability of all defendants, even though they could not have

been foreseen.





4.13 COUNT XIV: NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS AS TO ALL OF THE DEFENDANTS


182. All of the defendants own a duty to plaintiff to be honest and conduct this

proceeding against plaintiff according to Law and Lawyer’s Ethics.

183. All of the defendants breached that duty and are liable.

184. Solely as a result of the defendants' negligence, carelessness and recklessness,

plaintiff was caused to suffer serious personal injuries to mind and body, and further,

that plaintiff was subjected to great physical pain and mental anguish.


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185. The aforesaid occurrence was caused by the negligence of the defendants, without

any culpable conduct on the part of plaintiff.

186. By reason of the foregoing, plaintiff was severely injured and damaged, sustained

severe nervous shock and mental anguish, great physical pain and emotional upset,

some of which injuries are believed to be permanent in nature and duration, and

Plaintiff will be permanently caused to suffer pain, inconvenience and other effects of

such injuries; Plaintiff incurred and in the future will necessarily incur further hospital

and/or medical expenses in an effort to be cured of said injuries; and Plaintiff will be

unable to pursue his usual duties with the same degree of efficiency as prior to this

action, all to Plaintiff's great damage.

187. As result of defendants’ negligence plaintiff will be susceptible to future injuries as

well.

188. As a result of the forgoing, plaintiff has been injured and the defendants are liable

for all applicable damages under the law in the amount to be determined at trial,

including punitive damages; past, present and future medical expenses; loss of earnings

and enjoyment of life; economic loss.


damages in the amount exceeding jurisdictional limits of all lower courts, together

with interest and the costs and disbursements of this action, and such other and

further relief as to Interest of Justice and this Court seems just and proper.


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4.14 COUNT XV: PUNITIVE DAMAGES DUE FROM TORTFEASORS AS TO ALL OF THE DEFENDANTS


190. Acts of all of the defendants were wanton, reckless and malicious.

191. To protect public and society from future acts of the defendants, they must be

punished to prevent similar acts in the amount to be determined by the Jury.





4.15 VIOLATIONS OF CONSTITUTIONAL RIGHTS AND DUE PROCESS

192. Above mentioned acts by defendants enticed plaintiff into slavery under 18 U.S.C.

1583 and Involuntary Servitude under: 18 U.S.C. §1589 (3)

193. Defendants, officers of the Court, in violation of their oath of office, have proceeded

to institute slavery and involuntary servitude in violation of the Fifth and Thirteenth

Amendment of Constitution of United States of America and Constitution of The State

of New York as a way to harass plaintiff and deprive him of property in the form of his

labor, time, money and servicing.

194. Defendants forced plaintiff to perform unnecessary for him work without just

compensation for his labor, energy and time.


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195. Defendants forced plaintiff to defend himself from their derogatory actions in order

for them to make profit from their activities.

196. For more than two years plaintiff performs legal work without any just

compensation.

197. Defendants obtained $31,599.42 VOID order against plaintiff and enforcing it

through attempt to jail plaintiff.

198. Due to defendant’ above mentioned acts, plaintiff is unable to pay for appeal of this

unfair and void child support order.

199. As of 11/14/10 plaintiff owes $52,049.42 to New York City Office of Child Support

Enforcement.

200. The recruitment, harboring, transportation, provision, or obtaining of a person for

labor or services, through the use of force, fraud, or coercion for the purpose of

subjection to involuntary servitude, peonage, debt bondage, or slavery is prohibited by

LAW.

201. According to the National Human Rights Center in Berkeley, California, there are

currently about 10,000 forced laborers in the U.S., around one-third of who are

domestic servants.

202. Through manipulation of justice system, defendants violated plaintiff’s

constitutional right to due process.

203. Defendants tortuously interfered with federally protected right for employment.


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http://en.wikipedia.org/wiki/Peon#Peonage

204. Defendants tortuously interfered with federally protected right to be recipient of

federal unemployment insurance program through unlawful seizure of his funds.

205. Plaintiff must be fairly compensated for his labor and time in the amount to be

determined by the Jury.


damages in the amount exceeding jurisdictional limits of all lower courts, together

with interest and the costs and disbursements of this action, and such other and

further relief as to Interest of Justice and this Court seems just and proper.

Dated: Brooklyn, New York November 21, 2010

______________________________Michael Krichevsky, Pro Se4221 Atlantic Ave

Brooklyn, New York 11224718-687-2300


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5. VERIFICATION

SUPREME COURT OF THE STATE OF NEW YORKCOUNTY OF KINGS_____________________________________________________


-against-

YONATAN LEVORITZ, ESQ, YORAM NACHIMOVSKY, ESQ, ELENA SVENSON,_____________________________________________________

Index NO. 24714/2010

INDIVIDUAL VERIFICATION

STATE OF NEW YORK) ) ss.:

COUNTY OF KINGS )

MICHAEL KRICHEVSKY, being duly sworn under penalty of perjury deposes and says:

I have prepared the foregoing Verified Complaint and know the contents thereof and the same is true to the best of my knowledge, except as to those matters herein stated to be alleged upon information and belief and that as to those matters, I believe them to be true.

Sworn to before me this day of , 2010

__________________________________

MICHAEL KRICHEVSKY, PRO SE_______________________ NOTARY PUBLIC


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SUPREME COURT OF THE STATE OF NEW YORKCOUNTY OF KINGS

Index No. 24714/2010

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-against-

YONATAN LEVORITZ, ESQ, YORAM NACHIMOVSKY, ESQ, ELENA SVENSON,

Defendants.

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_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

VERIFIED COMPLAINT

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

The documents herein are hereby certified pursuant to 25 NYCRR 130-1.1-A

By: ________________________________

Michael Krichevsky, Pro Se.4221 Atlantic Ave

Brooklyn, New York 11224

AGNOWLEGMENT OF IN-HAND SERVICE:In-Hand Service of the within document is hereby acknowledged on this _____ day of ____________ 2010, at _________ am/pm


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Documents

SUING LAWYERS YORAM NACHIMOVSKY & YONATAN LEVORITZ FOR MALICIOUS PROSECUTION AND FRAUD