Our client purchased a multiple dwelling in Brooklyn with the intention that he and his family would live in one of the apartments.

The subject apartment is occupied by a Palestinian woman from the West Bank. She has been in America since 1974 but nevertheless she does not speak a word of English (or so she says).

Under New York Rent Law, she has only two defenses to this eviction: Either she must be elderly or disabled.

As she is only 42 years old, she is clearly not elderly.

She has been on welfare since 1986, when she says her husband left her. We have not been able to find out the name of the husband.

In order to get out of Workfare, she has been to the Methodist Hospital innumerable times for tests. Unfortunately, from her point of view, none of these tests have shown anything wrong with her.

Her only ailment is obesity. She is 5 feet tall and weighs 224 pounds. The doctors she sees invariably prescribe exercise and weight loss.

Among many other things, she says that she cannot work, because Arab women do not work.

She cannot read or write. She says that she stopped her schooling at the age of 13, in accordance with Arab customs.

I need an Arabic speaking New York doctor as an expert witness, to examine her and to testify that she is capable of working.

Sam Sloan