PETITION TO REHEAR MOTION TO VACATE

PETITION TO REHEAR MOTION TO VACATE

No. 164239P

STATE OF NEW YORK)
:ss.
COUNTY OF KINGS )

I, Samuel H. Sloan, being duly sworn, state under penalty of perjury:

1. I have just received the decision dated 6/5/2001 on my motion to vacate. Everything in this decision is wrong. None of it is true. It is all a lie.

2. For example, the decision states: "According to TLC records, he filed an application & was assigned TLC license # 5061483."

3. This is a lie. I never filed any such application. No such number was assigned to me. Not one word of this is true. I demand that you produce a copy of this application which you state that I filed. Nothing of the kind took place.

4. I have just been to the TLC Headquarters in Long Island City where I spoke to Roger Morgan, the supervisor in the applications section. He informed me that the number 5061483 was never assigned by the applications section to me or to any other person. This is not a case of mistaken identity. What is that case is that no such application exists, either from me or from anybody else.

5. Mr. Morgan told me that this number was not issued by anyone on the second floor of TLC. This number was issued by the third floor. The reason this number was issued was that the TLC had no record of anyone by that name having a TLC license. Therefore, in order to issue a ticket, a new number was created.

6. I went to the third floor. Mr. John (something) who is in charge of printouts told me that his office to has nothing to do with this case, either. In order to resolve this matter I must go back to JFK Airport, in other words, your office, he said.

7. Later, the decision states: "Notice of the hearing date scheduled (sent on 11/13/00) was sent to address on file with TLC via first class mail. Notice of hearing mailing was certified on 11/13/00."

8. None of this is true. No such address was on file with the TLC. I demand that you produce a copy of the file which has this address. There is none. Then, you state that the notice was sent by certified mail. In that case, you should have no trouble producing the signed certified mail receipt. I demand that you do so, because there is none. No such thing exists.

9. I hasten to point out that my case is no different that the cases of thousands of taxi drivers. More than ten thousand New York City Taxi drivers (10,000) have lost their licenses during the past two years, exactly because of decisions such as this one. Everybody knows that all taxi drivers are found guilty by the crooked TLC judges and there is no chance to be found not guilty. In order to feed their families, taxi drivers have been paying these unwarranted and illegal fines because unless the fines are paid they cannot drive a taxi. This is criminal extortion and I intend to demand a criminal investigation by the US Department of Justice, not only into my one case but into the thousands of similar cases where taxi drivers have been found guilty and forced to pay fines with no opportunity for a fair hearing.

10. In my case the fine is $280, an outrageous amount to pay, plus four points on my license, and the violations charges are trivial not even considering that I committed no offense and am completely not guilty.

11. You have stolen millions of dollars from the long suffering taxi drivers, almost all of whom are immigrants who lack the resources and the capability of fighting these illegal fines and many of whom do not even earn the minimum wage. However, I recommend that you not forget my name, because I will remember yours as soon as I find out what it is. (Your signature is illegible).

12. Now, I am going to be forced to pay this absolutely and completely illegal fine of $280 just so that I can work and earn a living for my family, but I can assure you that you have not heard the last of me because I intend to see you in jail.

_________________________

Samuel H. Sloan

Date: June 8, 2001

Sworn to before me this 8th
Day of June, 2001

--------------------------
Notary Public


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Contact address - please send e-mail to the following address: Sloan@ishipress.com