Albert L. Peia, Pro Se

P.O. Box 862156

Los Angeles, CA 90086

(213) 219-7649

# UNITED STATES DISTRICT COURT

# DISTRICT OF CONNECTICUT

________________________________________

In re: Richard M. Coan 3:09GP 18 AVC

________________________________________

# REPLY TO RESPONSE OF RESPONDENT COAN

If only Respondent Coan’s fairy tale version of the facts were true, he wouldn’t have needed nor felt compelled to bring the subject action before The Honorable Robert N. Chatigny, Chief Judge, U.S.D.C., District of Connecticut, to preclude me from suing him without leave of court. This intent to sue defendant Coan for damages arising from his illegal acts in the context of his purported role as trustee of my Chapter 7 estate in bankruptcy was clearly articulated and subsumed in the proceeding before Judge Chatigny and included his past, current and anticipated future illegal acts [ie., the Swann matter, the still unaccounted for Judgment entered in my favor by The Honorable Alvin W. Thompson, U.S.D.C.J. (Dist.Conn)] violative of RICO and other federal law. Specifically, in Judge Chatigny’s own concluding words in pertinent part,

‘On the existing record, a “leave of court” requirement should not (emphasis supplied) be

imposed on Peia with regard to any (emphasis supplied) future legal action he might bring

against plaintiff Coan………………If Peia does sue Coan, and the complaint proves to be

frivolous, appropriate sanctions can be imposed by the judge who gets that complaint,

including an order prohibiting Peia from filing another action without leave of court.’

212 B.R. 217, 220 (D.Conn.1997).

Additionally, in his own sworn testimony before Judge Chatigny, Coan acknowledged his fiduciary duty to debtor’s estate and debtor thereby (Exhibit B), which duty he purposefully, in the alternative, negligently breached. Reciting the 1951 case of Mosser v.Darrow, 341 U.S. 267, 71 S.Ct. 680, 95 L.Ed. 927 (1951), the Court in Conn. Gen. Life Ins. V. Universal Ins. Cos., 838 F.2d 612 (1st Cir. 1988), sets forth the words of the Supreme Court as are apposite here and provided in pertinent part, “a trusteeship is serious business and is not to be undertaken lightly or so discharged. The most effective sanction for good administration is personal liability for the consequences of forbidden acts……”, Id. at 621, and hence, respondent Coan’s personal liability herein, having been sued individually herein. Indeed, said Court in Conn. Gen. Life Ins., supra, continues stating that federal courts have uniformly held that bankruptcy trustees are subject to personal liability for the willful and deliberate violation of their fiduciary duties, and even for negligent acts by said trustees. Id.; see e.g., In re Gorski, 766 F.2d. 723,727 (2d.Cir.1985); In re Cochise College Park, Inc., 703 F.2d. 1339, 1357 (9th Cir. 1983). Moreover, the U.S. District Court has a significant interest in overseeing and correcting the conduct of (corrupt) trustees as Coan.

THE FACTS UNDER PENALTY OF PERJURY

Coan had contacted me by mail in California, relating that he had been appointed Chapter 7 trustee, and further requested that I call his office. I did so, further apprised him of the California proceeding and the numerous improprieties (RICO predicate acts) by Shiff and (bankruptcy) court. He stated that there was a motion to dismiss adversary proceedings, that he was reviewing same, and that he might be inclined to abandon same. I received nothing further from him (or the bankruptcy court) until I received a copy of the order dismissing the adversary proceedings with prejudice which I distinctly remember inasmuch as I quipped to my landlord that he, Coan, had just cost me a lot of money. In the meanwhile, I had faxed copies of the papers to the FBI fax number that had been given to me. The interim months included the use of the mails by Shiff relative to the California Chapter 7 proceeding, perpetuating the lie/fraud by Shiff regarding the date of dismissal by Shiff of a proceeding over which he presided (dismissed) upon which he predicated a spurious contempt proceeding which as borne out by counsel on my behalf, Robert Sullivan, Esq., who filed papers revealing the case had actually been dismissed with prejudice at the hearing before Shiff on 6-3-92, in which I among other creditors was in attendance, and not the date of October 8, 1992, upon which he based his spurious contempt proceeding which under color of right extorted a sum of money from me, wrongfully threatening me with jail (Attorney Sullivan also asserted with cited authority that the Shiff Bankruptcy Court was without jurisdiction to bring such a contempt proceeding). Although I was in California, I hadn’t given up residency in Connecticut and the U.S. Attorney’s Office should have set forth the fact that the date of dismissal was 6-3-92 at the Shiff hearing as confirmed by counsel on my behalf, Robert Sullivan of Westport, Connecticut. I had indicated to the Hartford Division (I filed there, though transferred to Shiff/venue) of the U.S. Bankruptcy Court by correspondence delivered by courier that I would file and seek transfer of the case to another jurisdiction (the California, 1996 case) absent other than Shiff’s wrongful conduct of the case. It is noteworthy in Coan’s Exhibit A, that Shiff does not mention the September, 1989 Virginia Chapter 7 proceeding which should have resolved all legal/property issues but was never consummated according to law (which would have made unnecessary the subsequent filings for paper trail).

A close examination of the ORDER OF DISMISSAL (with prejudice), Exhibit A, sets forth that the court ordered on May 31, 1996 that the adversary proceedings would be subject to dismissal (only) if Interim Trustee Coan failed to submit a filing by June 18, 1996; that at a hearing held on June 25, 1996 the court determined that Interim Trustee Coan had submitted no filing and dismissed as to all defendants with prejudice.

THE LAW

Reciting the 1951 case of Mosser v.Darrow, 341 U.S. 267, 71 S.Ct. 680, 95 L.Ed. 927 (1951), the Court in Conn. Gen. Life Ins. V. Universal Ins. Cos., 838 F.2d 612 (1st Cir. 1988), sets forth the words of the Supreme Court as are apposite here and provided in pertinent part, “a trusteeship is serious business and is not to be undertaken lightly or so discharged. The most effective sanction for good administration is personal liability for the consequences of forbidden acts……”, Id. at 621, and hence, defendant coan’s personal liability herein, having been sued individually herein. Indeed, said Court in Conn. Gen. Life Ins., supra, continues stating that federal courts have uniformly held that bankruptcy trustees are subject to personal liability for the willful and deliberate violation of their fiduciary duties, and even for negligent acts by said trustees. Id.; see e.g., In re Gorski, 766 F.2d. 723,727 (2d.Cir.1985); In re Cochise College Park, Inc., 703 F.2d. 1339, 1357 (9th Cir. 1983). Business judgment as alluded to by Coan? What business judgment (other than that akin to the likes of AIG, CITIBANK, among other wall street fraudsters/banksters, etc., which despite the multi-trillion dollar securities fraud, there has been as here yet not one prosecution for which disgorgement is appropriate)? Is that supposed to be a joke as is his disingenuous portrayal of himself as the “grieved”? In his own sworn testimony Coan has admitted he had a fiduciary duty to the Chapter 7 estate, that he contacted neither the FBI nor the Chapter 13 Trustee, that without investigation he summarily concluded my true sworn statements unbelievable concerning mafia/drug-crazed individual (Swann), and has mischaracterized my limited references to corrupt Judges Trump Barry and Shiff along with the corrupt Deidre Martini (to somehow by leap refer to all judges and officials). Exhibit B. Rather than being complicit as Coan would ask this Committee to be, the U.S. District Court has a significant interest in overseeing and correcting the conduct of (corrupt) trustees as Coan herein. See generally, In re Lehal Realty Associates, In re Lehal Associates, 101 F.3d 272, 275-277 (2nd Cir. 1996) (distinguishable from the instant case inasmuch as the trustee in that case had benefited the estate through his actions, as opposed to Coan who has purposefully, wrongfully, and illegally damaged the estate). There is applicable insurance/surety coverage. Parenthetically, I invite this Committee’s attention to the fact that RICO is a criminal statute with a civil money damages remedy purportedly to vindicate the law for which preponderance of evidence is the evidentiary standard and for which there are no immunities (nobody being above the law, including Coan).

THE 1881 CASE OF BARTON V. BARBOUR IS NOT APPOSITE, RELEVANT,

OR IN THE ALTERNATIVE IS MOOT IN LIGHT OF CLOSURE OF THE BANKRUPTCY CASE ON OCTOBER 20, 2004, FINAL REPORT SUPPOSEDLY RENDERED, THE DAMAGE TO DEBTOR CONSUMATED BY DEFENDANT COAN AT SAID POINT IN TIME (NO NOTICE TO EITHER PLAINTIFF OR CREDITORS).

The 1881 case of Barton v. Barbour, 104 U.S. 126 (1881), involved a plaintiff that had brought an action for injuries sustained while a passenger in a train, which railroad was currently in receivership. Said plaintiff brought the action against the receiver without having sought leave of court from the court that had appointed him. It is important to emphasize that there was no allegation nor even a hint of impropriety, culpability, or illegality on the part of either the receiver or the subject court that had appointed him. Indeed, the fundamental and underlying ratio decidendi and policy considerations leading ineluctably to said Court’s conclusion was that to permit such an action without leave of court would potentially impair the (value of the) property in the hands of the receiver, to the detriment of existing creditors and prior claimants. Id.,127-129. In the case sub judice, the precise opposite is true where respondent Coan has through his wrongful acts/conduct /negligence impaired the (value of the) property in to the detriment of existing creditors and prior claimants. Moreover, there was no RICO statute extent at said time to address the endemic and pervasive corruption that has become synonymous with America today and that the RICO statute was enacted thwart consistent with the liberal construction to be accorded said remedial legislation as per the Court in Sedima, S.P.R.L. v. Imrex Co., Inc., 473 U.S. 479 (1989). Specifically, complainant’s action herein has been to preserve the estate which has been purposefully and consistently damaged by defendant Coan, consistent with a pattern of racketeering activity by an associated-in-fact enterprise of which defendant Coan along with the U.S. Bankruptcy court that appointed him was a part. It should further be noted a fortiori that complainant’s action would inure to the benefit of the estate and consequently, legitimate creditors and/or claimants thereof. It further is true that at the evidentiary hearing before Judge Chatigny, on cross examination by complainant and repeated in follow-up questioning by Judge Chatigny, defendant Coan admitted he did not know of any legal way a real property as complainant’s could have been sold during the pendancy of the automatic stay [and the consequent fraud concerning surplus funds among other causes/predicate violations, etc., and those ripe for the entry of default (/judgment)], nor how without violating fiduciary duty the September, 1989 Virginia Chapter 7 proceeding which should have resolved all legal/property issues was never consummated according to law (which would have made unnecessary the subsequent filings for paper trail), etc.. Exhibit B. Moreover, in said sworn testimony Coan also confirmed he had considered abandoning said proceedings.

It should be noted that a cause of action under RICO is fundamentally recognized for losses (to ie., creditors, the debtor, lienholders, etc.) caused by sales of a debtor’s assets in bankruptcy proceedings at submarket prices. See, e.g., Bivens Gardens Office Bldg., Inc. v. Barnett Banks of Fla., 140 F.3d 898,908(11 th Cir. 1998). In the instant case, defendant Coan’s acts are even more egregious (and within the ambit of RICO) inasmuch as he has at all times relevant hereto purposefully, wrongfully, negligently, and flagrantly damaged assets of debtor’s estate, purposefully, wrongfully, alternatively negligently causing dismissal of adversary proceedings involving RICO claims ripe for entry of default (judgment) Exhibit A, Exhibit “A“ RICO Verified Complaint, Exhibit “B“ Affidavit, Exhibit “A“ RICO Statement, obstructing justice thereby, damaging plaintiff (debtor, as well as, ie., creditors, lienholders, etc.) , while concomitantly benefiting RICO co-conspirators, and committing a fraud upon the estate of debtor and creditors/lienholders thereby (violations of Sections 1513, 102 and that concerning extortion would also have been appropriate). The same violations apply to the adversary proceeding where the Trustee was named as a party plaintiff concerning junkie and thief, David George Swann (DOB 4-6-60; three guilty pleas to theft in less than 5 years residence in California) who stole (bankruptcy) estate among other assets of plaintiff and against whom default (judgment) was ripe for entry. Coan neither abandoned nor re-brought same, violating Section 1503 and (defrauding) damaging complainant thereby, and consistent with his defalcation of duty ab initio. It is preposterous for Coan to assert (falsely) to this Committee that I would fly in for the hearing concerning the relatively small Swann matter, and the subsequent hearing before The Honorable Robert N. Chatigny, Chief Judge, U.S.D.C., District of Connecticut, yet ignore the adversary proceedings integral to the value of the Chapter 7 Estate.

The foregoing statements made by me are true under penalty of perjury pursuant to the

laws of the United States of America.

Dated: 4-22-09

Respectfully Submitted and Signed by: _______________________

Albert L. Peia, Pro Se

P.O. Box 862156

Los Angeles, CA 90086

(213) 219-7649

CERTIFICATION OF SERVICE

I, Albert L. Peia, hereby certify that copies of the within, including Autorun DVD with relevant (PDF formatted) documents, as set forth therein including the foregoing instant document designated by date as 4-22-09 Complainant’s Reply to Response of Respondent Coan (42209complainantreply.pdf) were served by way of regular first class mail, postage pre-paid on this ______day of April, 2009, upon the following:

MEMBERS OF THE FEDERAL GRIEVANCE COMMITTEE as set forth in the Federal Grievance Committee Service List (As Updated March 24, 2009 – 14 Members) which is appended immediately hereto.

Richard M. Coan,

Coan, Lewendon, Gulliver, and Miltenberger , LLC.,

495 Orange St.,
New Haven, Ct. 06511

Walter W. Grattan, Jr., Supervisory Special Agent

Kimberly K. Mertz, Special Agent in Charge

Federal Bureau of Investigation

600 State Street, New Haven, Connecticut 06511

Dated: 4- -09 Signed:______________________________

Albert L. Peia

P.O. Box 862156

Los Angeles, CA 90086

(213) 219-7649

4-22-09 Complainant’s Reply to Response by Respondent Coan

Albert L. Peia, Pro Se
P.O. Box 862156

Los Angeles, CA 90086

(213) 219-7649

# UNITED STATES DISTRICT COURT

# DISTRICT OF CONNECTICUT

_________________________________________

In re: Richard M. Coan 3:09GP 18 AVC

# _________________________________________

#

#

# SUMMARY OF COMPLAINT

Defendant Coan, as Chapter 7 Trustee, was ordered by the Bankruptcy Court to submit a filing in adversary proceedings by a Court Ordered deadline or said adversary proceedings would be subject to dismissal. Defendant Coan failed to file anything whatsoever and said adversary proceedings were dismissed with prejudice causing this complainant (and legitimate creditors) substantial damages.

#### BRIEF BACKGROUND SUMMARY

A client had been referred to me regarding the concerns of two shareholder/owners over third shareholder /owner’s ever more integral involvement with the mob, which concerns were assuaged and problem solved by me by way of a voting trust edging out the third partner (see Plaintiff’s (5 page) RICO Summary Under Penalty of Perjury provided to the FBI at their request, reiterated and filed herein, nunc pro tunc, for more detailed account). I deferred some fees consistent with vagaries/difficulties of the client’s business and was owed a substantial sum by said client. There came a point in time when it was obvious there was illegal activity (illegal/drug money laundering, including through the Trump casinos) on the part of said client and in seeking funds owed to me I was told by the remaining shareholder /owner, Dilena, that assuming my compliance (and hence complicity), I would be paid. I filed a RICO Action and the case was assigned to newly appointed federal judge Maryanne Trump Barry, Donald Trump’s sister. I moved to recuse her for the obvious conflict – hundreds of thousands per month of revenue to her brother’s casinos from defendant Dilena /companies, which motion she personally heard and denied. I personally met with District of N.J. Assistant U.S. Attorney Jonathon Lacey, provided him with documentary evidence of the illegal money laundering, and explained the various illegal activities to him, and in the context of my pending RICO Case. About a month or so later I inquired as to his progress and was told Lacey was no longer with the U.S. Attorney’s office, no further information available, and that the file could not be located. I thereupon delivered by hand another set of copies of the documents to U.S. Attorney Sam Alito with the federal employee receiving same assuring the package addressed to Alito would go directly to him. Upon inquiry not long thereafter I was informed Alito was no longer with the office of the U.S. Attorney and the file/documents could not be located (Alito was appointed to the 3rd Circuit Court of Appeals and amazingly, now is a U.S. Supreme Court Justice. Many people have served prison time for far less than his crime, ie., Martha Stewart, etc. Maryanne Trump Barry also sits on 3rd Circuit Court of Appeals where they sat together). In the meantime, I was constrained to file under Chapter 11 of Title 11, U.S.C., and sought by way of personal meeting with U.S. Trustee Hugh Leonard that he join in my motion to recuse Trump Barry which he refused to do but he did leave his position as U.S. Trustee, upon information, for a position as partner at Cole, Shotz, et als, on retainer with Dilena and companies as central clients. I had moved to Connecticut where I filed a Chapter 13 proceeding which should have crystallized the legal/property aspects of the case if not for improprieties by Alan Shiff of the bankruptcy court in Connecticut, when I finally, in light of the corrupt processes, filed a Chapter 7 in Virginia where I maintained an office seeking an orderly liquidation of my properties/assets, payment of creditors, and in light of the substantial equity in my real properties a substantial sum even at substantially reduced prices, the RICO action being the primary thorn in the side of said court and again the matter wrongfully/illegally handled and never consummated according to law which otherwise would have concluded all matters except for, by inference, the RICO action]. [Former FBI Agent Richard M. Taus attests by affidavit to drug money laundering endemic to this 2nd Circuit (equally applicable to 3rd Circuit, ie., Atlantic City, etc., and crime families) and former CIA Agent Dois Gene Tatum attests by sworn declaration to high level government involvement in such illegal drug related crimes ].

In light of defendant Coan’s wrongful/illegal conduct damaging me and benefitting other RICO co-conspirators /defendants, I made no secret of my intent to utilize the judicial process to seek damages against defendant Coan for his intentional and illegal acts damaging me, and coincidentally, any legitimate creditors of my estate. Parenthetically, it is reasonably inferred that it was defendant Coan’s knowledge of his own illegal/wrongful acts damaging me and constituting a fraud under Title 11 U.S.C. and a RICO violation thereby that did prompt Coan’s subject action before Judge Chatigny to preclude me from suing him without leave of court. It is noteworthy that the action brought by defendant Coan and heard at the subject hearing before The Honorable Robert N. Chatigny, Chief Judge, USDC (Dist.Conn) had the subject bankruptcy court case reference, viz., Bankruptcy No. 95-51862, No. 3:97-CV1165(RNC) for which I flew in from California, gave testimony and had occasion to cross-examine Coan . The Honorable Robert N. Chatigny, Chief Judge, USDC (Dist.Conn) denied Coan’s relief as to Coan but granted same as to Shiff. On or about April 28, 2005, I received a call from a person named Sandra who identified herself as an employee of the U.S. Bankruptcy Court, Bridgeport Division, who stated that the subject bankruptcy case had been closed on October 20, 2004 and a final report filed, the details of which I set forth in my affidavit dated 5-2-05, filed with the court on 5-4-05, and referenced in my motion/application to withdraw as moot the application for leave to file the complaint I had sought to file in light of same, which was granted by Judge Kravitz without prejudice while denying the request for criminal refer-ral except as to the local police which I delivered by hand to LAPD, Attention:LAPD Chief Bratton.

The documents filed by me in this RICO litigation have been filed under penalty of perjury [RICO Verified Complaint, RICO Statement, Affidavit in Support of RICO Verified Complaint, Addendum, 6-6-05 Addendum , Plaintiff’s Opposition papers set forth below, etc., just dismissed by Janet Hall, U.S.D.C.J., for lack of jurisdiction.].It should be noted as set forth in Plaintiff’s (5 page) RICO Summary Under Penalty of Perjury provided to the FBI at their request, reiterated and filed herein, nunc pro tunc, as Addendum to Plaintiff’s Affidavit in Support of RICO Verified Complaint, the prior filed RICO Action was stayed by Judge Gilroy Daley (he had previously presided over cases of prosecutions involving organized crime but passed away which then resulted in the transfer of the RICO case first to Judge Thompson, and then to Judge Arterton, U.S.D.C.J., who dismissed the case without prejudice stating in her Order her incorrect presumption that the case was being resolved in bankruptcy court although the adversary proceedings which had the same defendants /causes of action had just been dismissed with prejudice by Alan Shiff, U.S.B.C.J. owing to Richard M. Coan’s illegal/wrongful conduct) as the subsequent bankruptcy case/adversary proceedings went forward providing a mechanism for assurance to and payment of legitimate creditors, with defendant Coan’s wrongful conduct resulting in dismissal with prejudice benefiting the RICO defendants and damaging the bankruptcy estate, creditors, and me. There is applicable insurance/surety coverage.

#### RECAP/SUMMARY/CONCLUSION

#

# The Chapter 13 plan provided for 100% payment to the (relative to assets) small (minimal amount of debt) number of creditors and as well designated the proceeds of the#3:93cv02065 (AWT) judgment to Norwalk Savings relative to the 62 Barnum Road, Danbury, CT property. As set forth in plaintiff’s Verified Complaint, RICO Statement, and Affidavit, the Chapter 13 proceeding was converted to a case under Chapter 7 on or about 5-1-96 on Alan Shiff’s own motion, after plaintiff had already filed a petition under Chapter 7 in California on or about 3-11-96, and had already consummated the 341A hearing in the California proceeding. Alan Shiff, U.S.B.C.J., (and Coan), did utilize the mails in perpetrating said fraud (on courts, creditors, plaintiff, etc.), constituting the RICO predicate violation of mail fraud thereby, violative of Section 1341, fraudulently misrepresented the date of dismissal of a proceeding over which he himself had presided perpetrating a fraud connected with a case under Title 11 as proscribed in Title 18 U.S.C. Section 1961(1) (D); and further, brought a (retaliatory against a witness/victim/informant violative of Section l5l3) spurious contempt proceeding against plaintiff, obstructing justice thereby in violation of Section 1503 (and additionally was without jurisdiction to legitimately do so). Quite simply, he lied (materially false fraudulent representation); knew he lied (scienter); lied with the intention of deceiving (intent); the lies were relied upon (ie., government, courts, etc.)(reliance); said offense/fraud in connection with a case under Title 11 directly causing damage to plaintiff’s property and business (and as well to plaintiff’s estate and creditors), which lie/false statement was brought to the attention of the court presiding over the contempt proceeding by counsel on my behalf; viz., Robert Sullivan, Esq., Westport, CT.. The separate referenced judgment entered 9-18-96/filed 9-19-96 dkt. 393cv02065(AWT) in my favor by Judge Thompson in the U.S. District Court for the District of Connecticut is now worth well in excess of $300,000 with interest and/or trebling and remains unaccounted for, and according to the filed Chapter 13 plan was to go to Norwalk Savings for the 62 Barnum Rd., Danbury, CT property. The within referenced filings with exhibits thereto, have been sent to FBI, and the RICO Summary under penaltyof perjury sent to and at the request of the FBI. Richard M. Coan has not rebutted even one sworn statement by plaintiff herein, all averments being under penalty of perjury (RICO Verified Complaint, RICO Statement, Affidavit, and filings), and in the paramount judicial interests of truth and justice, respectfully submits that without action by this Committee legitimate creditors and I will left without a remedy. Indeed, a rule of reason should obtain herein, particularly in light of the numerous conflicts and hence, incentives to cover-up and further obstruct justice. Specifically, the Bankruptcy Court is part of the associated-in-fact enterprise. Moreover, Alan Shiff, U.S.B.C.J., has committed various RICO violations including that extortionate ploy (and fraud) under color of right based on Shiff’s false statement, the falsity of which was borne out by counsel on my behalf, Robert Sullivan, Westport, CT. Moreover, Albert Dabrowski, Chief Judge, U.S.B.C., was U.S. Attorney at the time of the spurious contempt proceeding, and Diedre Martini, now U.S. Trustee for the District, the prosecuting Assistant U.S. Attorney. To require leave of court from said Court is almost tantamount to requiring my seeking leave of a mafia godfather or under-boss before commencing a RICO action as here relating to the illegal money laundering, fraud connected to a case under Title 11 U.S.C., etc.. Stated another way, as a direct consequence of defendant Coan’s wrongful conduct, there is nothing left of the bankruptcy estate for the bankruptcy court to preside over (what does remain are the substantial damages caused by defendant Coan as documented in the instant case before the present Court). Additionally, in light of the closure of the case, as well as the destruction of any and all assets of the estate by defendant Coan’s wrongful conduct, and the consummation of the fraud by defendant Coan thereby, it would be but a fool’s errand to pretend that justice could be served thereby.

The foregoing statements made by me are true under penalty of perjury pursuant to the laws of the United States of America.

Dated: 4-5-09

Respectfully Submitted and Signed by: _______________________

Albert L. Peia, Pro Se

CERTIFICATION OF SERVICE

I, Albert L. Peia, hereby certify that copies of the within, including Autorun DVD with relevant (PDF formatted) documents and hyperlinks, as set forth therein including the foregoing instant document designated by date as Grievance Summary Document (4509grievancesummarydocument.pdf) were served by way of regular first class mail, postage pre-paid on this ______day of April, 2009, upon the following:

MEMBERS OF THE FEDERAL GRIEVANCE COMMITTEE as set forth in the Federal Grievance Committee Service List (As Updated March 24, 2009 – 14 Members) which is appended immediately hereto.

Richard M. Coan,

Coan, Lewendon, Gulliver, and Miltenberger , LLC.,

495 Orange St., New Haven, Ct. 06511

Walter W. Grattan, Jr., Supervisory Special Agent

Kimberly K. Mertz, Special Agent in Charge

Federal Bureau of Investigation

600 State Street, New Haven, Connecticut 06511

Dated: 4- -09 Signed:______________________________

Albert L. Peia

4-5-09 Grievance Summary Document

Grievance Complaint Against Attorney Richard M. Coan

1) PLAINTIFF’S MEMORANDUM BY WAY OF DECLARATION /CERTIFICATION SUBMITTED PURSUANT TO THE ORDER OF THE HONORABLE JANET C. HALL, DISTRICT COURT JUDGE, DISTRICT OF CONNECTICUT, IN SUPPORT OF JURISDICTION BY THIS COURT IN THE INSTANT MATTER; 3-13-09
2) REQUEST FOR CRIMINAL REFERRAL AS PROVISIONALLY SET FORTH IN THE CORRESPONDENCE TO FBI DATED OCTOBER 20, 2008 AND ANNEXED HERETO AS EXHIBIT “A”.

1) Declaration/Certification in Opposition to Defendants’Motion to Dismiss FOR LACK OF SUBJECT MATTER JURISDICTION;

1) Declaration/Certification in Opposition to Defendants’Motion to Dismiss FOR LACK OF SUBJECT MATTER JURISDICTION;

2) PLAINTIFF’S CROSS-MOTION FOR ENTRY OF JUDGMENT ON THE PLEADINGS IN THE SUM CERTAIN AMOUNT OF $5 MILLION AS DEMANDED IN THE VERIFIED COMPLAINT;

3) REQUEST FOR CRIMINAL REFERRAL AS PROVISIONALLY SET FORTH IN THE CORRESPONDENCE TO FBI DATED OCTOBER 20, 2008 AND ANNEXED HERETO AS EXHIBIT “A”.

________________________________________

### Coan Testimony in Pertinent Part From Hearing Before The Honorable Robert N. Chatigny, Chief Judge, U.S.D.C. (Dist.Conn) [PDF file format]
[ HTML file format (opens in browser) ]

________________________________________

RICO VERIFIED COMPLAINT

RICO STATEMENT

AFFIDAVIT IN SUPPORT OF VERIFIED COMPLAINT

RICO Summary to FBI Under Penalty of Perjury at Their Request (5 pages)

Addendum to Affidavit Dated 3-3-08

Addendum to Affidavit Dated 6-6-05

Cross-Notice of Motion for Judgment on the Pleadings

Opposition to Motion to Dismiss

Supplemental Affidavit

Some More Recent Correspondence with the FBI

FBI Agent Affidavit Regarding Drug Trafficking, Money Laundering, Financial Fraud, and Government Corruption

CIA Agent Affidavit Regarding Drug Trafficking Involving High Level Government Officials

Shiff Order of Dismissal With Prejudice on Coan’s Failure to File Page 1 Page 2

________________________________________________

COMPLAINT AGAINST ATTORNEY RICHARD M. COAN

RICO Verified Complaint

RICO Statement

Affidavit in Support of Verified Complaint

RICO Summary to FBI Under Penalty of Perjury at Their Request (5 pages)

Addendum to Affidavit Dated 3-3-08

Addendum to Affidavit Dated 6-6-05

Cross-Notice of Motion for Judgment on the Pleadings

Opposition to Motion to Dismiss

Supplemental Affidavit

Some More Recent Correspondence with the FBI

FBI Agent Affidavit Regarding Drug Trafficking, Money Laundering, Financial Fraud, and Government Corruption

CIA Agent Affidavit Regarding Drug Trafficking Involving High Level Government Officials

Shiff Order of Dismissal With Prejudice on Coan’s Failure to File Page 1 Page 2