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Upstate Citizens for Equality

“Enforce the law . . . what Pataki is doing is an impeachable offense.” Richard Ricci 5/2004

Warren v. Spitzer, et al.

This action seeks to compel the State of New York and Erie County to enforce the sales tax imposed by the NYS Legislature Articles 12-a, 20, 28, and 29 of the New York Tax Law on sales to non-indians that occur on Indian Land.

The damage that this illegal and unconstitutional policy is causing to our form of government, the economy of the counties in New York where Indian land is situated and our national security is outlined on our taxation page which can be viewed by clicking here

Below are the documents in this litigation in chronological order:

Summons with Notice [HTML] [PDF]

Verified Complaint [HTML] [PDF]

Defendant Pataki and Roth's motion to dismiss the Complaint [HTML] [PDF]

Defendant Erie County's Answer [HTML] [PDF]

Supplemental Summons [HTML] [PDF]

Amended Verified Complaint [HTML] [PDF]

Plaintiff's Memorandum of Law in Opposition to State Defendants motion to dismiss [HTML] [PDF]

State Defendants' Reply Memorandum in Support of Motion to Dismiss [PDF]

County Defendants' Cross-motion for Summary Judgment [PDF]

Plaintiff's Affidavit in Opposition to County Defendants' Cross-motion [HTML] [PDF]

Plaintiff's Memorandum of Law in Opposition to County Defendants' Cross-motion [HTML] [PDF]

County Defendants' Reply Memorandum in Support of Motion for summary judgment [PDF]

Decision deciding Motion to Dismiss and Cross-motion for Summary Judgment [PDF]

Plaintiff's Motion and Memorandum of Law in Support of Reargument and Settlement of Order [HTML] [PDF]

State Defendants' Memorandum in Opposition to Motion to Reargue [PDF]

County Defendants' Affidavit in Opposition to Motion to Reargue [PDF]

Plaintiff's Reply Memorandum of Law in Support of motion to reargue [HTML] [PDF]

Decision and Order on Motion to Reargue and Settle Order [PDF]

Order and Judgment dismissing action [PDF]

I am currently moving to vacate the above Judgment based on the State Defendants' misrepresentations and misconduct and newly discovered evidence and to amend and supplement the complaint and to substitute various defendants. Below are the papers on this motion which is currently returnable on March 1, 2007 at 9:30 a.m. before Justice Sconiers:

  • Notice of Motion and supporting Affidavit [PDF]
  • Exhibit O [PDF]
  • Exhibit P [PDF]
  • Exhibit Q [PDF]
  • Exhibit R [PDF]
  • Memorandum of Law in Support of Motion [PDF]
  • (All other exhibits are available above.)

State Defendants' Affidavit in opposition to the motion to vacate the judgment of dismissal [PDF]

State Defendants' Memorandum of Law in opposition to the motion to vacate the judgment of dismissal [PDF]

Plaintiff's Reply Memorandum of Law in support of motion to vacate the judgment of dismissal [PDF]

County Defendants' Letter Brief in opposition to the motion to vacate the judgment of dismissal [PDF]




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