this case involves corruption both at the heart of the complaint and then the criminal prosecution the convict the conviction of which is a subject of at issue in this case as we all know district attorney vance has been investigated by the attorney general and the kind of conduct that he is being investigated for which involves either action or inaction for powerful people is at the heart of this case and i've been arguing it for years unfortunately my lawyer did not file my appeal into so i had to take it over it's now been perfected it is going to be heard in may  case is absolutely blatantly clear in the appellate case now in this case we have criminality of perjury of the with respect to the april eighteenth two thousand and twelve complaint that had contempt complaint that had two counts one from march thirteenth two thousand and twelve and one for april fourth two thousand and two of the photograph in each case of  house now i it is clear that the jug was corrupted below and i say that because this could complete evidence of that that advance has perverse control and influence over the criminal court which was also proved by the fact that the criminal court refused to prosecute me at least twice in the normal course and then powerful people after i've been told by the commander  neighborhood of twenty some odd years to petition my government to address zoning violations now the first amendment cries out and the problem was the d which in forces only wanted to cave in to bloomberg view that the film industry should go where and where it wants and do what it wants so they would not enforce only so the community members including christine quinn who that we're not a trial court and we're not going to be able to decide the factual dispute that you have not you have a number of claims that maybe if we parse them out of we can be sure we understand your position to the extent that you're bringing claims based on the april eighteenth arrest now as i understand the record you were convicted of one charge that i mean from that incident and that usually forecloses challenges to false arrest and malicious prosecution on a charge for which there's been a conviction so tell me what it is you want what relief it is you want with usually means that there's then probable cause to support the arrest and the prosecution right now the cases that i've cited in that indicate that until there has been a full hearing an opportunity to be heard only evidence until there's a final upholding on appeal of of that conviction it's only evidence of of probable cause now this is a motion to dismiss this is not even a summary judgment so if it's evidence of it and i come in and say ok yes but we have in this util it was that the police officer in concert an agreement with the complainant committed indisputable perjury proved by photography and the photograph was taken in front of my own building where as in order to get this prosecution the rescue detective lied under oath as did the complainant in supporting the complaint by deposition that i was staying directly in front of a building but what you what did you get convicted for i got convicted for attempted contempt they took the jury away from right which is different from the circumstances that you're saying that was perjury complaint yeah ok the count i'm sorry the count was march thirteenth the alleged violation now that was a very day the very day that another contempt complaint that was completely baseless  was dismissed so the eighty eight called up and this was over the trial we had a call that the complainant said he's going to be out so she was stalking me on and you can tell in this video that she was stalking me trolling for something but she found nothing so she said i was in front of a building which wasn't even precluded by the protective order unlike another protective order it was facially on its face this prosecution had no basis whatsoever it's clear from her own video that i was standing well in front of my own building and i took a photograph of an individual who assaulted me just to have evidence that that he was an employee or  now there's no mention of photography and then subsequent orders there is mention of photography in the april eighteenth complete they you should have protective words said you cannot take photographs of the house under other conditions now as had many other conditions and music wasn't included originally and she testified in the criminal trial that i didn't take a photograph of the house i took a photograph of her worker yet when the red light is enjoyment of his property is disturbed do you want to address that well you're out of that so that's an interesting and novel question but the very novelty of it shows that at the very least the police officers have qualified immunity this court has never addressed the question supreme court has never addressed the question and there is far from a robust consensus in any other circuits in fact most of the courts that have considered such questions have concluded that the fourth amendment is not implicated ok thank you thank you all right under jennings i think it is and hammer and broke in this conviction where there's been an appeal and if you please you know revisit those those citations where there's been an appeal  then it's not final and in a criminal case in particular you do not want to hold that against the defendant so let's get to the a p to the next charge is what they kept doing i think believed in the first amendment and you know i went to columbia law school forty five years ago and i dissolution by the fact that this is so clear that you know but that is cleared events now and he's very concerned about this in terms of what the you know the criminality the corporation counsel committed crimes at my trial now talking about a conspiracy we have that we have the police officer committing perjury in conjunction w so that's criminal tampering with a witness so what we have is certainly evidence of a conspiracy now let's go to the next day which is they kept saying all right april fourth we know she committed perjury because i proved that i couldn't possibly been which she said i was take a picture of a house that wasn't prohibited in the first place other conditions not included but the thing is let's just so we knew she was unreliable there i'm saying first of all if it's evidence and it as as as broken says it's evidence is not conclusive evidence it's not definitive evidence meaning other matter of law until we get to it to find out what happens on  so i have all these other that as a perjury of people that when you say perjury talking about what she told the police officers she and the police officer both signed either a complaint or deposition in support of the complaint right but that's but but the her video if you look at it she took a video she was stalking me on the very day that another order got dismissed and she was at the ready stalking me and she said that i was standing in front of her house when i took a lawyer i'm cautious so i didn't go in front of us the video shows me clearly well in front of my building over a building away from hers and they both admitted to trial that that was true so it's indisputable that they committed perjury  me your four let's take away the conviction and look at june twenty five which is that now you're going to go into another issue we have your position in your paper you don't know about that that one was decided in your favor  and that they knew they knew about the perjury we're going to take it under advisement thank you very much thank you thank you don could we