in all material respects in this part of the Order to be no more than a simple
"copy and paste" by the Court of False statements and arguments submitted by
Plaintiffs' attorney Adam Simon which have been regurgitated into an official
federal Court Order with no evidence, proof or documents in support, a
"fraud within a fraud" in an ongoing series of frauds.
21. Plaintiffs and their attorney Adam Simon had wholly failed to submit ANY Order
or Judgment from Florida showing Appellant was not a Beneficiary in the Estate of
Simon Bernstein and lacked standing in the Estate of Simon Bernstein. Of course,
legally, the Plaintiffs and Adam Simon could not submit such an Order as No Such
Order exists as this never happened in the Florida state Courts but instead
Plaintiffs and Counsel Adam Simon simply knowingly "stated False Facts" to
the US District Court that this was the case and such an Order existed in efforts
to wholly remove Plaintiffs Constitutionally protected Due Process and Procedure Rights .
22. The US District Court below appears to have bought into this fraud "hook, line
and sinker" without requiring any Proof or evidence as the Order on Appeal not
only makes reference to these False Facts stated by Adam Simon but instead of
Citing to some actual Order or Judgment document from Florida provided in the
Summary Judgment filings, the District Court simply cites to the Statement of
Facts submitted by Counsel Adam Simon for Plaintiffs.
23. For example, the US District Court states in the Order on Appeal, "First, Eliot
cannot sustain cognizable damages related to the disposition of the Estate or the
testamentary trust in light of the Probate Court's rulings. The Probate Court found,
inter alia, that Simon Bernstein's "children - including Eliot - are not
beneficiaries" of the Will of Simon Bernstein or the related testamentary trust.
 at 11." See, US District Court Order Docket No. 273 pages 7-8. The US
District Court had made it clear in FOOTNOTE 1 that, "
The facts are taken from the parties' Local Rule 56.1 statements and the Court's previous rulings [106, 220[. (240[ refers to Plaintiffs' statement of material facts." Thus, the US District Court simply ruled based upon a section of False Statement of Facts from Plaintiffs citing to Plaintiffs Statement of Facts [2401 at 11 that had NO Orders attached or submitted used to provide the Findings and language that the District later gives "preclusive effect to" and thus, a fraud within a fraud, a lie within a lie. "