discovered" Frauds and forgeries of Dispositive documents filed in the Shirley
Bernstein Estate case by attorneys working for and with Ted Bernstein, the alleged
"Trustee" and Plaintiff in this action being attorneys at Tescher and Spallina who
were the Estate Planners for Simon and Shirley Bernstein and made themselves
Personal Representatives of the Estates and Co-Trustees of Trusts.
9. As shown by Appellant's Answer and Counterclaims in this case and by a Motion
for Injunctive Relief filed in the US District Court in this action in Feb. of 2016,
the "same parties" involved with the frauds in the State of Florida cases are the
same as those frauds before the US District Court where no "original" documents
have been produced and all key dispositive Documents like the Insurance Policy
and alleged controlling Trust have all allegedly become "lost" and "missing".
10. To the contrary, Appellant has alleged this is all part of a fraudulent scheme to
"control" the Assets and Disposition of Assets and take away Appellant's
"standing" and right to be heard after Appellant has exposed frauds and crimes in
both actions and reported same to Federal and State investigative authorities.
11. Attached is a recent Order of Florida 15th Judicial Circuit Judge Scher which
confirms that I, Appellant, Eliot I. Bernstein am in fact a Beneficiary of the Simon Bernstein Estate which thus changes the circumstances and facts upon
which the District Court issued its Order.
12. Further, Judge Scher has also found that Ted Bernstein, who is the Plaintiff in this
case, is adverse to the Estate of Simon Bernstein and has a conflict of interest
involving the Illinois Insurance action and yet as later shown herein, continues to
act "in unity" with the Estate PR Brian O'Connell to "control" Discovery and
documents and the frauds and litigation in both this "Insurance" action and the
13. As this Court will note, while I have attempted in good faith to cite to the Docket
Entries in the Record of the US District Court of the Northern District of Illinois in
both the Jurisdiction Statement and this motion herein, there are references to
newly discovered facts and change of circumstances which have occurred after the
issuance of the Order being Appealed and this Court's Orders which I believe are
important and while I have attached some of these items in hard copy print, it
would be burdensome to do so for the entire motion and would further delay the
filing of these papers and I request permission to Electronically file in the future
and if required by this Court, to supplement my filings Electronically.
UNDISPUTED CLEAR AND CONVINCING PROOF OF ONGOING
FRAUD BY PLAINTIFF TED BERNSTEIN, HIS COUNSELS ALAN B.
ROSE, ESQ. AND ADAM SIMON, ESQ. AND INTERVENOR PR BRIAN
O'CONNELL, ESQ. FOR THE ESTATE OF SIMON BERNSTEIN ACTING
IN CONCERT AND ACTIVE CONCEALMENT OF THE FRAUD
DIRECTLY IMPACTING THE US DISTRICT COURT'S ORDER ON
SUMMARY JUDGMENT "NEWLY DISCOVERED" AFTER ISSUANCE
OF THE SUMMARY JUDGMENT ORDER ON APPEAL;
FRAUD THAT HAS BEEN CONCEALED FROM BOTH THE US DISTRICT COURT
AND NOW THIS 7TH CIRCUIT US COURT OF APPEALS DESPITE APPELLANT'S REQUEST OF FLORIDA 15TH JUDICIAL CIRCUIT JUDGE SCHER
TO NOTIFY ALL PROPER AUTHORITIES "
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