In Re : DMR June 15 2015 to US Department of Education, NY HESC, US SSA, and filed to American Express v DMR in NY State Supreme Court Suffolk County Index # 061458/2013 via Efile and thereby associated with NY State Supreme Manhattan Index # 100156/2011

{Reference this Document "DMRJune152015toDOENYHESCSSAFederalStateFinancial" to

http://www.twentyfirstcenturydigital.com/DOEJune102015DMRosenblumAffirmationMay242015.php &

http://www.twentyfirstcenturydigital.com/DMRJune152015toDOENYHESCSSAFederalStateFinancial.php }

IN RESPONSE TO SECOND HALF 2014, FIRST HALF 2015 NOTICES RECEIVED BY DMR FROM DOE NYHESC AND SSA REGARDING FEDERAL AND STATE FINANCES, LIABILITIES, OBLIGATIONS, AND RELATED JURISPRUDENCE ASSOCIATED WITH MY PERSON, "DMR" {DANIEL M ROSENBLUM, THE UNDERSIGNED, BIRTH DATE MARCH 23 1969} //DMR June 15 2015//

  1. Written Response from Daniel M Rosenblum,  receiving mails at PO Box 3377 NY NY 10163, regarding US Dept of Education Account Number 1021981006 letter dated April 16 2015, alleging  default by DMR on total balances of  $131 ,083.05 (Principal Balance   $120,287.28  Interest   $10,795.77) plus  $49,460.41 (Principal balance $45,733.88 Interest $3,726.53). The DOE 4/16/2015 letter(s) signed by Dwight Vigna of US DOE states DMR should make checks payable to: U.S. DEPARTMENT OF EDUCATION and SEND PAYMENT TO: US DEPARTMENT OF EDUCATION NATIONAL PAYMENT CENTER PO BOX 105028 ATLANTA GA 30348-5028 for USDOE debts 24295148, 24295156, 24295153, 24295157, 24295151, 24302224, 24302229, 24295159, 24295164, 24302228, 24304133, 24304137. Here are copies of identifying letter(s) ; in addition to the above listed, DMR hereby also responds to related Notices regarding all related educational loan accounts which financed DMR at NYU Stern and New York Law School 2006-2011, displayed in the materials DMR attaches hereto below

    {{BELOW, PLEASE FIND 5 IMAGES OF USDOE IDENTIFYING CORRESPONDENCE, FOLLOWED BY 200+ PARAGRAPHS WRITTEN BY DMR, ROUGH DRAFT AS OF MEMORIAL DAY WEEKEND 2015 FOR EDIT VARIOUSLY }}:
  2. 1. Written Response from Daniel M Rosenblum, receiving mails at PO Box 3377 NY NY 10163, regarding US Dept of Education Account Number 1021981006 letter dated April 16 2015, alleging default by DMR on total balances of $131 ,083.05 (Principal Balance $120,287.28 Interest $10,795.77) plus $49,460.41 (Principal balance $45,733.88 Interest $3,726.53). The DOE 4/16/2015 letter(s) signed by Dwight Vigna of US DOE states DMR should make checks payable to: U.S. DEPARTMENT OF EDUCATION and SEND PAYMENT TO: US DEPARTMENT OF EDUCATION NATIONAL PAYMENT CENTER PO BOX 105028 ATLANTA GA 30348-5028 for USDOE debts 24295148, 24295156, 24295153, 24295157, 24295151, 24302224, 24302229, 24295159, 24295164, 24302228, 24304133, 24304137; in addition to the above listed, DMR hereby also responds to related Notices regarding all related educational loan accounts which financed DMR at NYU Stern and New York Law School 2006-2011, displayed in the materials DMR attaches hereto below]
  3. DMR has previously entered answer and reiterates same answer, in response to an allegation of default, and/or breach of contract, DMR enters, and has entered through ACS Xerox, Navient, and Sallie Mae, over the course of several years,  an answer of non-default to any contract, and, alleges counter suits of negligence and  other libelous both to the parties alleging against DMR and additional parties which disputes should be joined given the subject matter(s) of all parts as articulated by DMR variously to date please see eleven (11) "DMRJune152015toDOENYHESCSSAFederalStateFinancial" World Wide Web URLs listed below.
  4. 4. This letter also responds to alleged debt by DMR for any other debt listed in the name of DMR listed on NSLDS, DOE, NYHESC presently, which can be viewed in a rendition of accounts filed at NY State Supreme on ____ and available on webpage _____
  5. DMR alleges that

     DOE is of knowledge and or should be of knowledge , is aware, and or should be aware that DMR has of record denied default status of contract.

     DOE is of knowledge and or should be of knowledge , is aware, and or should be aware that DMR has of record denied default status of contract.

    DMR states that it is ludicrous  that it is not of record at DOE and HESC that DMR is of opinion and belief that  a judicial determination of the funds in question would be found in favor of DMR were there  jurisprudence applied to the allegation of default, and by way of which DMR has previously requested Review which has not taken place to date.

    The mere fact that it is not of record as part and parcel of the DOE 4/16/2015 Notice of Default that DMR is of the same opinion of this full filing  is proof, the mere fact that it is not of record is proof of DMRs argument that DOE HESC and their full portfolio is not subject to Jurisprudence in keeping with Federal or State Due Process   as it pertains to the allegation of default. The DOE / NYHESC  operational system in house, and, as it pertains to contracted tasks, and, the  operational systems of contracted task providers for servicing of  the full loan portfolio in question  for adjudications/ determination s of allegations of breach of contract  through default fails in rising to acceptable level of due process

    NYHESC, Navient, Sallie Mae, ACS Xerox , DOE is of knowledge and or should be of knowledge , is aware, and or should be aware that DMR has of record denied default status of contract.

  6. NYHESC should cease and desist from Wage Garnishment mechanism as it pertains to the person of Daniel M Rosenblum immediately.
  7. NYHESC should cease and desist from Wage Garnishment mechanism in full portfolio of accounts immediately.
  8. NYHESC should cease and desist from Wage Garnishment mechanism as it pertains to the person of Daniel M Rosenblum immediately, and, immediately refund to DMR monies garnished to date, plus interest.
  9. The degree of scrutiny in due process given the operational systems in place and contracts in place {link to Task Contracts at DOE} http://www.twentyfirstcenturydigital.com/DOENationalRecoveriesBaseContract78Pages.php as example of Base Task as per DOE at NYHESC and DOE are insufficient that such entities are privileged and entrusted to utilize the wage garnish mechanism bearing the authority of the State and Federal government. The entities should cease and desist immediately from utilizing the wage garnishment mechanism for any contracts such entities are providing services for presently, retroactively, and for perpetuity. The wage garnishment mechanism is appropriate following, for example, IRS determination of non-payment of taxes. IRS utilization of wage garnishment is not borne of a contractual item entered into by consumers in the marketplace with private entities. {Here also, insert link to Social Security Administration deliberation o foverpayment: in the case of SSA deliberation of overpayment of funds borne of SSI and SSD which subject matter is directly related to the defenses and joinder subject matter DMR raises, SSA has not moved forward with wage garnishment. SSA has a longstanding and well developed system of Administrative Law which DMR opines is more advanced and more in sync with due process than DOE and NYHESC systems. All the while, however, DMR states that both are lacking in advancement commensurate with digital progress in the marketplace. At the Federal and State levels in the US such advancement is necessary at such integral agencies as SSA and DOE if the US is to realize the full economic benefit of the digital era. To be certain, a very poignant example of part of the problematic evolution of secure data processing, related to DMRs critique of BHCs (insert link) is the notion that virtually all private telecom and financial services refer to the Social Security number as part of their security mechanisms for digital commerce. However, such entities pay no related internet tax, their telephone operators which utilize the SSA # are unlicensed, and, as in the lack of due process afforded by the "Tasked" Sallie Mae call centers, following credential verification using the Federal SSA ID, Americans have no way of relying upon warranties and guarantees nor varied facets of offer and acceptance which occurrences are verbal or online in a majority of commercial transactions utilizing internet technologies in 2015. There is a prevalent lack of manner to transfer data of such occurences - the instance of commercial transaction with associated warantees guarantees, and terms- to the judicial arena for weighing. An insignificant portion of revenues associated with these transactions are devoted, through proper taxation, to a continued evolution of judicial processes associated with such transactions. The same judicial processes would in turn contribute- through just adjudications- to competition in the marketplace and supply and demand of superior products and services .
  10. 11. Insert "with privity amongst parties such as consumers in the marketplace and private lenders " rather, its an obligation when it comes to the Federal Taxes. Note again that the Federal Tax ID is being utilized as if in the public domain for private banking and telecom all the while compromising Federal and State systems which generate such IDs for purposes other than the banking and telecom usage, and, the banking and telecom usage {which usage is part of operational policy at such entities} does not generate any State or Federal revenues allocated towards internet related technologies which would facilitate nexus to jurisprudence associated with t he same transaction types. This is error, and, harmful to commerce in general, and, compromises the marketplace in which DMR and contemporaries desire a fair efficient marketplace in which to transact business and enjoy basic rewards associated therewith.
  11. Relief sought :  DMR is certainly of opinion that presently, given income, no garnish of wages should be in effect. DMR is of opinion that DMR has not culpability in reneging on contract with party such that garnish of wages from DMRs  2015 wages is not a just resolution to any dispute or allegation of breach of contract. NYHESC should cease and desist immediately from the weekly collection of a garnish of wages by issuing a release to employer of DMR to whom garnish was instituted. DOE should not institute a wage garnish. DOE should instruct NYHESC to cease the current garnish.

  12. Matters of financial contract belong in courts of general jurisdiction where issues of jooinder can be heard, in accordance with CPLR, and rules of Evidence. As it stands presently, DMR states DOE and NYHESC are ill equipped to facilitate just results in matters of contract for the full US educational system for each individual  borrower. As a result, DMR states that DOE and NY HESC should cease and desist form the wage garnishment mechanism, which as to DMR is unjust result.

    A consideration of materials which should be before a court of law brought forth here by DMR, a consideration of such materials should make it glaringly evident that the collection firms, or, loan servicers in this instance have built data processing systems which do not facilitate just results insofar as the Answer on an allegation of default  nor the joining of issues of joinder where a contract is alleged to have been broken by a borrower. Presently all that is being done is a system built which functions in a manner which seeks to eliminate any and all evolution of legal associated with the commercial transactions in question. There are a gazillion transactioons utilizing this syetem, and, there is no evolution of associated law following disputes related to such contracts. The DOE and NYHESC seem to have the belief and understanding that their employees and system rises abov e the axiomatic facets of jsutice and commerce wherein they are capable of having knowledge of any and all factors which may effect a contract in the USA, and that they are equipped at the stroke of a pen  and a deliberation of a perhaps univeristy educated employee looking over a form making the decisions which courts of law cannot do- presumably because they havent risen to the same level of knowledge and understanding as DOE and NYHESC so  therefore must rely upon centuries of legal precedent . Here however, apparently, a borrower seeking to become educated in a field has no such rights in such contract. Further, on the sides of both the lender and recipient  of the loan monies, in this m arket, are not subject to any facet of commercial jurispruduence, any risk , any liability associated with commerical jursiprudence  or lack thereof. The educational institution is in receipt of monies associated with borrowers whom they have approved, and, the lenders are apparently guaranteed the interest rate  return without any fear whatsoever of actual default and or issues of joinder. The lending market is effected in a devestating manner given this and the the participation of such lenders and processors servicers in the credit reporting schemata. DOE and HESC should cease and desist immediately from making reports to CRAs, and, should immediately insist upon deletion by CRA of records provided to CRA by DOE and HESC to such CRAs during time period effected by loan servicer contract which circumvents due process.

  13. The foregoing eleven (11) "DMRJune152015toDOENYHESCSSAFederalStateFinancial"  URLs are hereby served to the SSA, DOE, and NYHESC June 15 2015 by DMR in response to 2015  Alleged Federal and State Liabilities incurred by and or for which DMR is alleged to be in default, at the addresses provided by DOE NYHESC and SSA in the Federal and State Notices to DMR (as is  displayed through images of such Federal and State Notices available for viewing on   these URLs provided by DMR to each Federal and State Agency:

http://www.twentyfirstcenturydigital.com/DOEJune102015DMRosenblumAffirmationIMAGES.php

and 

http://www.twentyfirstcenturydigital.com/MayJunePOBox3377NoticesfromDEONYHESCSSA.php

In addition the URLs and subject matter are provided to via email to Officers and Counsel and Directors at the Agencies, and similarly insofar as the intended joinder parties including corporate and partnerships to whom Notice and Process is served as listed above and in the NYSCEF  EFile.

 

 

JUNE 15 2015 eleven (11) "DMRJune152015toDOENYHESCSSAFederalStateFinancial"  URLs

"DMRJune152015toDOENYHESCSSAFederalStateFinancial":

 

  1. http://www.twentyfirstcenturydigital.com/DMRJune152015toDOENYHESCSSAFederalStateFinancial.php

 

  1. http://www.twentyfirstcenturydigital.com/DOEJune102015DMRosenblumAffirmationMay242015.php

 

  1. http://www.twentyfirstcenturydigital.com/DOEJune102015DMRosenblumAffirmationIMAGES.php

 

  1. http://www.twentyfirstcenturydigital.com/MayJunePOBox3377NoticesfromDEONYHESCSSA.php

 

  1. http://www.twentyfirstcenturydigital.com/January2015NYHESCFinancialSupplement.php

 

  1. http://www.twentyfirstcenturydigital.com/JPG2014IRSSSAAllPaychecks.php

 

  1. http://www.twentyfirstcenturydigital.com/dmr06102015linksindex.php

 

  1. http://www.twentyfirstcenturydigital.com/DOENationalRecoveriesBaseContract78Pages.php

 

  1. http://www.twentyfirstcenturydigital.com/January2015NYHESCFinancialSupplement.php

 

  1. http://www.twentyfirstcenturydigital.com/GarnishMaterialsNYHESCDecember2014.php

 

 

  1. http://www.twentyfirstcenturydigital.com/January282011DMRtoSSAAppealsCouncilFallsChurchVA.php

 

 

24. Relevant filings  previous to June 15 2015 to NYHESC, SSA, DOE, Navient, Sallie Mae, ACS Xerox as EFiled in NY State Supreme Court Amex v Dan:

 

  1. http://www.twentyfirstcenturydigital.com/LEGALSERVICEOFPROCESSANDINDEXEmail1August42014toSallieMaeACSXeroxAmexCiti.php  {DMR August 4 2014 to Sallie Mae Navient ACS Xerox NYHESC}

 

  1. http://www.twentyfirstcenturydigital.com/re_NYSHESCaccountnumber_900002888700_EMAIL1of2ColumbusDay201410132014.php {DMR October 2014 to Sallie Mae Navient ACS Xerox NYHESC}

 

  1. http://www.twentyfirstcenturydigital.com/LEGALNOTICEnovember2014NYHESCDANIELMROSENBLUMHESCACCOUNT900002888.php  {DMR November 2014 to Sallie Mae Navient ACS Xerox NYHESC}

 

  1. http://www.twentyfirstcenturydigital.com/LEGALNOTICE_February2015.php
  2. {DMR February 2015 to DOE Sallie Mae Navient ACS Xerox NYHESC}

 

  1. May 2015 Materials sent to DMR from US Social Security Administration :
  2. 2015 SSA Materials Alleging a Federal Liability and the below form dated October 2014, Form SSA-561 filed DMR October 19 2014
  3. http://www.twentyfirstcenturydigital.com/SSA2015FederalAllegedDMRLiability.php

 

  1. Please also see related items 1998-2005; and for example, http://www.twentyfirstcenturydigital.com/January282011DMRtoSSAAppealsCouncilFallsChurchVA.php

 

  1. 08-31-2011 SSA Hearing 26 Federal Plaza New York NY http://www.twentyfirstcenturydigital.com/08312011SSAHearing26FederalPlaza.php

 

 

25. PRESIDENTS DAY 2015 AFFIRMATION AFFIDAVIT

http://www.twentyfirstcenturydigital.com/AffidavitofServicePresidentsDay2015.php

http://twentyfirstcenturydigital.com/December032014SeriesI.php

http://www.twentyfirstcenturydigital.com/December032014SeriesA.php

http://www.twentyfirstcenturydigital.com/December032014SeriesR.php

http://www.twentyfirstcenturydigital.com/December032014SeriesC.php

http://www.twentyfirstcenturydigital.com/December032014SeriesD.php

http://www.twentyfirstcenturydigital.com/December032014SeriesE.php

http://www.twentyfirstcenturydigital.com/December032014SeriesF.php

26. These items can be downloaded are publically available through NYSCEF in E-File, American Express v Daniel M Rosenblum .  DMR states that all  Materials EFiled in New York State Supreme Court speak to the truth of the matter asserted by DMR in this June 15 2015 letter to DOE, SSA, and NYHESC and should be construed to be of the complete record of the deliberation of such subject matter today addressed by DMR brought forth to DOE, NYHESC, and SSA, as with Citi and Amex etc.

In response to an allegation of default, and/or breach of contract, and/or liabilities incurred by DMR to DOE, NYHESC, and / or SSA DMR enters, and has entered through DOE, NYHESC, ACS Xerox, Navient, Sallie Mae, and to SSA, over the course of several years, an answer of non-default to any contract which DOE presently alleges default as listed throughout this June 15 filing, and, DMR alleges counter suits of negligence and other libelous both to the parties alleging against DMR and additional parties which disputes should be joined given the subject matter(s) of all parts as articulated by DMR variously to date

27. These items can be downloaded are publically available through NYSCEF in E-File, American Express v Daniel M Rosenblum :

http://twentyfirstcenturydigital.com/Amex09152013DocList.php

Images of the full case as viewed on the NYSCEF system as of November 2014 can be viewed on this web page, which has live links to NYSCEF for most filed items:

 http://www.twentyfirstcenturydigital.com/9999_SupremeandCourtofClaimsDocumentListforAmexvDanNovember52014_9999.php

The full case can be viewed on the NYSCEF LIVE SYSTEM BY LOGGING IN AT : https://iapps.courts.state.ny.us/nyscef/Login

AND

29. The instant Notice, titled "June 15 2015 Notice to DOE, NYHESC and SSA by DMR " [carrying the above list of URLs as indicated emailed to each listed Officer at DOE {"@ed.gov" } and HESC etc, ] ONLY is mailed in hardcopy to DOE, NYHESC, and SSA, each of which seem to avoid, by deliberate operational policy,  receipt of Process and Notice  via electronic means.

 

 Please note that images of directions from DOE NYHESC and SSA to these physical addresses only for response to 60 Day Notice can be viewed at :

 

http://www.twentyfirstcenturydigital.com/DOEJune102015DMRosenblumAffirmationIMAGES.php

 

http://www.twentyfirstcenturydigital.com/MayJunePOBox3377NoticesfromDEONYHESCSSA.php

 

30.
Of great importance insofar as the adverse effect of each practice above listed is the detriment to productivity, efficiency and effectivensess in the product marketplace, including in the lending marketplace and in the institutional education marketplace, and to individual borrowers which individual borrowers are citizens in the USA, with rights  trodded upon and it is assumed that it is the belief of DOE and HESC that the systems built by Navient and ACS are built to be efficient and productive. However, there is no competition for building such systems for processing such data. The efficient effective productive system would allow for access to all prior cases in the subject matter area, and, all regulations, and a manner to file in dispute, citing such regulations with ease. Instead, the consumer credit reporting systems exist completely separate from the judicial data processing systems and have markings on a monthly basis making allegations regarding contracts which have never seen the light of a court of law but which are relied upon in contrast to ease of manner to economically rely upon national judicial system for weighing risk

 

31.

This email follows a transmission to the same parties and intended parties to actions in two jurisdictions, Manhattan County and Suffolk County, both actions with title American Express v Daniel M Rosenblum, to whom I Daniel M Rosenblum emailed legal papers last on Presidents Day 2015 2/2015. The Suffolk action was commenced by Amex 2013, and is an Efile case in NY State Supreme Court with Index #    . The Manhattan action was commenced by Amex in 2011, and is a hard copy case. The subject matter in both cases is identical. My answer to the subject matter was filed in hard copy in 2011 in Manhattan, which answer is therefore answer to the Suffolk matter as per the CPLR. The CPLR requires Judicial discontinuance by order upon motion, or judicial decision, or stipulation amongst the parties for any just resolution to any litigation commenced in NY State Supreme Court. Subject matters related to controversy at bar in litigation in subject to Joinder under the CPLR. Here, all parties and intending joinder parties are given notice to subject matter here contained. Intended Joinder parties, as described variously throughout my filings in Manhattan and Suffolk, include but are not limited to the firms Jaffe and Asher, Zwicker PC, NYHESC, US Department of Education, Navient, Sallie Mae, Citigroup, et. al. . Regarding Citigroup, it has been my preference over years to serve papers giving notice of an unresolved dispute to Board Members and Senior Corporate Officers electronically. However, it is difficult to obtain email addresses for appropriate electronic service of notice. Therefore, presently, in addition to the Citigroup attorneys and staff to whom my Notice is directed regarding Joinder Issues to American Express v Daniel M Rosenblum, henceforth I have added the electronic address of Citigroup’s soon to be newest Board Member, Peter Blair Henry, for the purpose of giving continued Notice to Citigroup. Mr. Blair is Dean of NYU Stern School of Business, from where I graduated with an EMBA with the A11 cohort during June of 2011. NYU Stern School of Business (and NY Law School) received funds administered and/or serviced by US Dept. of Education, NYHESC, Sallie Mae, Navient, and/or ACS Xerox___. Presently in 2015, 15% of my weekly wages of $ 15.50 per hour for driving a truck to deliver shower door glass are garnished by NYHESC  as the only source of payment towards over $ 750,000.00 accumulated debt which financed my Juris Doctorate and Masters of Business Administration. I have not  yet taken any Bar exam in any State. My primary purpose in adding Dean Peter Henry Blair is to give Notice of the alleged unresolved controversy(ies) with Citigroup which subject matter(s), inter alia, I allege should be joined to the subject matter at Bar in Amex v Dan. Citigroup announced on February 17th 2015 that Dean Blair was elected as a new independent director with his service to  commence July 1, 2015. While Mr. Blair’s tenure has not yet begun at the time of transmission of  today’s Notice, I have added Dean Blair presently to facilitate Notice to Citigroup both presently by way of J C Armstrong et al, and, by continuing way of the Citigroup Board July 2015 and thereafter

On March 23, 2015 I DMR did file

On April 15, 2015 I did file

PDF and URL, therefore two copies of each.

  1. Regarding NYU Stern, Citigroup, and email to Dean  Peter Henry Blair sent email at  phenry@stern.nyu.edu; peter.henry@stern.nyu.edu June 15 2015 see also above Paragraph insofar as Citigroup announced on February 17th 2015 that Dean Blair was elected as a new independent director with his service to  commence July 1, 2015, and otherwise.

    Willumstad, and his contemporaries for Notice Cc and Claim on Assets from time period:

    CITIGROUP INC. at 399 PARK AVENUE NEW YORK, NY 10043 as per the ADDRESS OF PRINCIPAL EXECUTIVE OFFICES OF CITIGROUP INC. {(INCORPORATED IN THE STATE OF DELAWARE)[referred to as “The Corporation,” below]}, IRS EMPLOYER IDENTIFICATION NO. 52-1568099, indicated as such in Citigroup Inc.’s UNITED STATES SECURITIES AND EXCHANGE COMMISSION FORM 10-Q COMMISSION FILE NUMBER 1-9924 ( form pursuant to Section 13 or 15(d) of the Securities Exchange Act of 1934) for the quarterly period ended MARCH 31ST 2002

    Citigroup Inc. Board of Directors 1. C. Michael Armstrong 2. Alain J.P. Belda  3. Kenneth J. Bialkin, Esq.

    4.Kenneth T. Derr 5. John M. Deutch  6. Alfredo Harp Helu  7. Roberto Hernandez Ramirez

    8.Ann Dibble Jordan 9. Robert I. Lipp  10.Reuben Mark 11.Michael T. Masin 12.Dudley C. Mecum

    13. Richard D. Parsons 14.Andrall E. Pearson 15.Robert E. Rubin  16.FranklinA Thomas 17.Sanford I. Weill

    18.Arthur Zankel   Other Citigroup Inc. Officers, Executives 20. Thomas W. Jones : Chairman and CEO, Global Investment Management& Private Banking Group, Chairman and CEO, Citigroup Asset Management 21. Charles O. Prince III : Chief Operating Officer; Corporate Secretary, Chief Operating Officer, Emerging Market 22. Todd S. Thomson : Executive Vice President; Chief Financial Officer, Principal Financial Officer, Head of Global Investments 23. Joan Guggenheimer : General Counsel, Corporate and Investment Bank Planning Group, Member Of Citigroup Management Committee 24. William R. Rhodes : Senior Vice Chairman Citigroup/Citicorp/Citibank 25. Robert B. Willumstad : President, President, Citigroup, Director, Citicorp/Citibank N.A., Chairman & CEO, Global Consumer, Consumer Planning Group; Citigroup Management Committee; Internet Operating Group 26. Sir Deryck C. Maughan : Vice Chairman, Chairman, Internet Operating Group, Head, Citigroup Mergers and Acquisition, Chairman, Cross-Marketing Group; Chairman, Citigroup Japan 27. Stephanie B. Mudick : co general counsel, General Counsel, Member, Citigroup Management Committee, Member, Consumer Planning Group 28. Irwin R. Ettinger : Principal Accounting Officer, Tax and Accounting 29. William P Hannon : Principal Accounting Officer, Citigroup Controller, Business Services

    31. Here, to be certain NYHESC and DOE has attempted to utilize the same vocabulary as the IRS Federal Tax 'Obligation". As written into the Master Promissory Note . DMR states that the MPN is inappropriate and that the semantics which NYHESC and DOE are utilizing are simply that: semantics in an effort to justify a tax on future earnings of a large percentage of Americans. In particular such revenues going to call centers which ignore due process obligations as per " tasked contracts".
  2. 34.
  3. 17. {every contract under the MPNs administered by NYHESC and DOE have written into them several years of "servicing" charges which are revenues to entities such as Sallie Mae, ACS Xerox, and their share holders and executive officers. DMR alleges that such revenues collected by the "tasked" entities {insert link to task} are monies paid for frivolous, insignificant tasks which allege to comport with a very important facet of the due process associated with the commercial transaction under analysis which results in a "taking" by such entities, which commercial entities should be held liable for varied forms of negligence, and, without correction, larceny, in due course.
  4. 18.

 

  1. 21. Discovery request: Explanation of privity and responsibility between the task orders, and the Sallie Mae interaction with the party privy to the task order's performance
  2. 22.
  3. 23.
  4. 24.
  5. 25. DMR demands immediate, voluntary affidavit issued by DOE and HESC stating knowledge and pledging correction within a time frame
  6. 26.
  7. 27.
  8. 28.
  9. 29.
  10. 30. Where an operational policy by design is found to limit freedom of speech on the technological platform which is the nexus between the enterprise, the consumer, and the judicial system for commercial purposes . Where it is found that the operational system of such commercial entities constitutionally limits freedom of speech, such enterprise shall be found to be negligent and in a time period, gross negligence, and after a time period once knowledge of flaw established, intentional negligence, criminal negligence.
  11. 31.
  12. 32.
  13. 33. 34.
  14. 35. DMR here gives Notice to the party(ies) instituting a governmental wage garnish or contemplating such garnish, DMR states that such parties, as DOE and NYHESC should have Notice and are hereby given Notice of the information that any action against DMR on this debt (reference to all loans for specific purpose and listed as such in single data base ) should be brought as action in a court of general jurisdiction by {list all, including banks } if they want to sue, if the parties seek some sort of judicial order on the contracts, then, they must go to courts of general jurisdiction and cease and desist from otherwise implementing or attempting to initiate any judicial mechanism . Note here that it should be extraordinarily evident that all items in the list of contracts subject to dispute are indubitably eligible for joinder in any consideration of adjudication on alleged breach of contract. Yet, presently in the instant case, line items are being handled as if the other line items do not exist , or as if the parties are not aware of the others and their judicial actions will be separate, without regard to defenses and/or joinder issues brought forth on the identical contract form, and which, terms of contract form afre cited by any of the parties alleging breach. Here, not only the contract form is cited in allegation of breach, but, the identical contract, purportedly administered under the same task orders by the State and Federal agency, without heed to defenses or joinder subject matter brought to knowledge of the Agencies over a term of 5 years variously by virutue of the performance by the tasked servicers while in the performance of such task. The result is absurd, and contributes in no manner whatsoever to adequate due process nor to just adjudications nor to supply, demand, efficiency, nor productivity.
  15. 36.
  16. 37. NOTE: toll on statutes of limitations as per EH Toll motion
  17. 38.
  18. 39.
  19. 40.
  20. 41.
  21. 42.
  22. 43.
  23. 44. CC is to remainder of email list including all Amex and including NYU Stern Dean re Citi Board upcoming appointment
  24. 45.
  25. 46. State in first few paragraphs (of webpage as well) that the item is filed within a 60 day period of a Notice of Default from DOE on educational loans but there is related subject matter as articulated throughout to the Amex v Dan matter as has been articulated to Navient, Sallie Mae, and ACS Xerox since the inception of the loan contracts in 2006 and through the present. Note importantly that facts and circumestances were definitively articulated at application and inception. None of such facts and circumstances articulated even at inception and continuing remain of record at Notice of Default even though all such items DMR states should be of record and under consideration, and easily accessible as data associated with the full portfolio of contracts serviced by the service providers according to performance of State and Federal contracts (if not in the contract, then, Fed and State fall short of facilitating due process requirement) at generation of Notice of Default by the Administrative Agency which purports to have a substitute process for courts of general jurisdiction. To be certain, the Administrative Agency is on Notice of Request for Administrtiv e Review giv en such data, to the extent that it would be wholly improper to garnish wages without full in detail review in accordance with a CPLR and standard of review of which the parties are fully knowledgeable, including public record of all such cases adjudicated prior thereto, as in courts of general jurisdiction.
  26. 47.
  27. 48.
  28. 49.
  29. 50. It may be that the system to have been built in accordance with DOE mandate sought to be an adequate substitute to due process afforded by courts of general jurisdiction. And, it may be that broken down into composite sections that various portions of operational policy at DOE, NYHESC, Sallie Mae, Navient, ACS Xerox, tasked entities under base contracts, it may be that their individual operational policiies comport or attempt to comport with jurisprudence and some semblance of a due process which is an adequate substitute for the jurisprudence resultant the rules and regulations embedded in courts of general jurisdiction…however, DMR states that the actual operational system resultant, where there is no record whatsoever at the calendar date of the default allegation, of all utterances bearing weight on the alleged default for examination by the administrative agency and for review in general by bank, borrower, law enforcement agencies entities participants, courts - it bears no semblance whatsoever to desired actual jurisprudence , which, in the USA, there is in fact a system built- the judicial arm of the US in a balance of powers which includes judicial executive and legislative, but, here, the system fails in approaching par.
  30. 51.
  31. 52.
  32. 53. 54.
  33. 55. The DOE NYHESC Navient schemata in operational system is directly analogous to the operational systems which does not permit a writing to be submitted in a manner which can be easily verified and is available to jurisprudence be it administrative or court of general jurisdiction or to other enquiring entities (the DOE schemata relies upon Credit Reporting Agency data for certain information, and for consequences related to certain procedural practices, both for in house practices and policies as well as as such data pertains to third parties, and, the CRAs profit handsomely in processing such data which data in fact is data pertaining to contract maintenance or alleged breach of contract. However, its at the level of jurisprudence that data pertaining to private contracts should be public, not at the level of CRA. Again, it’s a s if the operational policy in a paper world did not allow for submission of a writing to a party to a contract, or, as if, in the paper world, there was an ink utilized which could not be Xeroxed. Could you imagine if the paper utilized by the entity allowed for reading of the paper but there was not manner to take a picture of it, or to photocopy it because of the ink type or some quality of the paper or ink or technology allowing for copying. It is similar as well to there being no physical address for a corporation doing business on the corporations articles of incorporation (note, above, notion of the technology utilized for communications which technology is the nexus with jurisrudence and commerce- the physical address on the articles of incorporation are for writing paper technology, not for intenrnet technology, and do not suffice as substitute). Here, we are talking about ease of several years of correspondence between the parties privy to a contract which contract is purportedly being scrutinized, or, breach of such contract or default of such contract are purportedly in an arena of jurisprudence where the Administrative Agency rises above or to the level of Courts of General Jurisdiction. Here it is nonsensical, it is not extant. The quality does not rise to par; there is no semblance of jurisprudence given or in light of the DMR statements here put forth to such agencies for the knowledge of such agencies.
  34. 56.
  35. 57.
  36. 58. 21st Century Digital® advocates to the Fed : compare and contrast the "book cover" available via CRA data being "judged" as compared to actually adjudicated contractual dispute data available via State and Federal Courts; consider in light of BHC Act Section 106 (1970) (Anti-tying) and 12 USC 1843 4(c)(8) (Permissible Activities) as these pertain to FHCs and BHCs with data processing revenues and earnings
    See Federal Reserve Blog on LinkedIn: https://www.linkedin.com/pulse/dont-judge-book-its-cover-kim-lusk-phr-cir-cdr
  37. 59.
  38. 60.
  39. 61. DOE and/or NYHESC is knowledgeable, and/or should be knowledgeable, given articulations made to loan servicers under contract to NYHESC and DOE are knowledgeable should be knowledgeable that DMR has put forth substantive matters which question the legitimacy of the allegation of default and the legitimacy of the contract, and has put forth defenses and issues of joinder. Again, should be knowledgeable of these substantive issues. In making a wage garnishment, such judicial determination requires a finding, a holding, that, either there exist no such issues which have any meritorious facets to them, or, that there has been a holding, a finding that there exist no substantive issues, and that the contract is valid, and that the debt is valid following due process. Here, DMR asserts that such assertation by the governmnetal agency is a perjury, and that such perjury is written into operational policy with the purported safeguard to continued error being the continued assertations by the defendant party to the contract after the perjurious assertation. (Note, however, that many such corrective utterances made by parties the contract type serviced per operational policy may be made following 60 days from Default Notice, notwithstanding 5 year record of same statement, and, because of the lapse past the one 60 day period are determined to be time barred) .
  40. 62.
  41. 63. This also is an analogous to the operational policy at Citi which has the Citi Branch manager perjuring non-permission following granting permission. Both have the perjury built into operational policy, and neither is a one-off. Such perjury is dangerous and there should be punitive action against such operational policy.
  42. 64.
  43. 65. 21
  44. 66. This is a very serious allegation by DMR. The allegation is that the finding of default when it is uncertain as to whether there is legitimacy to the allegation of default, or uncertainty as to whether alleged defaulting party has put forth defenses or articulated desire for administrative review, or, it is uncertain as to whether the record fo subject matter relating to review is a complete record of subject matter which has been brought to the attention of the servicers acting in agency for the Fenderal oor State entity during a several year period, and, part of such uncertainty is as a result of operational policy
  45. 67. By the servicers which purports to perform a task on contract which includes the preparation o f and the maintanence of due process during the course of the years that the account is in their possession. Take it a step further and note that there are a host of analogies in the conduct of Zwicker, in work for Amex. And, in their behavior in the courts. It is very important here to allege perjury, and put forth that continuing of the same perjurious statements as part of an operational policy which the entities are hereby given knowledge by DMR as DMR here asserts that the operational policies are flawed and that such entities should cease and desist from similar perjury. In months to come and in years to come, continuing operations under the same policies is performed is performed by the enitites with the knowledge that corrections must be made and therefore if corrections are not made, then DMR states there should be punitive actions for such perjuries bhy the officers at the agencies, whom should be held accountable, and this goes hand in hand with the degrees of negligence in continuing operations with these flaws which are depriving individuals of rights and compromising the marketplace.
  46. 68.
  47. 69. Note that DMR states that by nature of problem at hand, the 60 day period which allows for ahardcopy writing only to an address never before provided is an inadequate substitute to a record of several years of verified dialogue and correspondence by servicers.
  48. 70.
  49. 71.
  50. 72.
  51. 73. 22
  52. 74. Jurisprudence in the USA requires Due Process. Courts of General Jurisdiction have evolved as a result of the requirements of such Due Process. When other forms of adjudication substitute for Courts of General Jurisdiction, the Due Process clause remains. The DOE and NYHESC schemata is not an adequate substitute for Courts of General Jurisdiction in providing Due Process for disputes in commerce in the USA.
  53. 75.
  54. 76. 23
  55. 77. Missed part of statement rehash: in regards to several facets, with a conclusion that this is no trivial matter. The failure of Due Process in this marketplace is no trivial matter. It is not a trivial marketplace, and, the ramifications of lacking process extend tremendously throughout the economy for several reasons and with myriad less than favorable results (in particular, as compared to the favorable results throughout when in fact Due Process and appropriate adjudication of commercial dispute as evolved in keeping with State and Federal expectations in Courts of General Jurisdiction as such expectation pertains to rules of evidence, rules of procedure, and records associated therewith). It is not a trivial marketplace, and, the critique of due process pertains not only to the analysis of dispute, but, to the manner of dispersement- to the institution not to the individual- the manner of qualification etc coupled with the Promissory Note form, and lack of due process rising to the axiomatic principals of courts of general jurisdiction whose rules of evidence and rules of civil procedure are guaranteed coupled contribute.
  56. 78.
  57. 79.
  58. 80. Important is the actual dollar amount in the loan, the beneficiary of monetary value, and the liability for the dollar amount in the years after the disbursement if there is some failure to achieve success of contract.
  59. 81.
  60. 82
  61. 83. DMR alleges scienter can be deemed to exist on the part of DOE in possession of funds possessed by virtue of misappropriation from custodian of such funds, and, owner of such funds, when DOE or NYHESC has appropriated such funds through garnish of wages with Due Process commensurate to such appropriation of funds throughh custodian. - once knowledge of manipulative flaw is established if the parties do not quit such action of larceny by fraud built into the system which purports to qualify as just adjudication through due process. The party here has represented to Congress that it has developed an administrative system which is adequate as substitute for a Court of General Jurisdiction, and, the party here performs all contracts to be so adjudicated . Here, payments made to call centers presently where such call centers do not affirm per individual with indubitable certainty that during a several year period of servicing loan, servicer has not been party to any uteerance from the adverse party which utterance should be deemed a defense in contract but thereafter DOE or NYHESC garnished wages upon belief that adverse party had failed to put forth defense therefore conducted no on the record administrative evaluation bearing in mind the alleged defense, and proceeded without trial or inquiry or expectation of joinder issue. This, with the expectation that the full portfolio of accounts could not possibly have any record whatsoever of the several year term of utterances, including such utterances at the processing of deferments and other legal mechanisms by call centers entrusted to uphold during performance all facets of contract, which, in turn, is the contract Sallie Mae Navient ACS provide to NYHESC or USDOE as proof that there has been no record of such utterance due to the manner in which DOE has structured the contract and acceptable operational policies which comport with performance of such contractual requisites.
  62.  
  63. These items can be downloaded are publically available through NYSCEF in E-File, American Express v Daniel M Rosenblum

    84. 2015 Documents begin

  64. www.December 2014/AFFIDAVITOFSERVICE/AffidavitofServicePresidentsDay2015.php

  65. 89. C:\Users\Dan Rosenblum\Documents\2015 Documents begin December 2014\2015NYSCEFfilingbeginMarch232015\April15201560CentreFiling

  66. 85. NYSCEF_Certificate_of_Signature_Amex_v_Rosenblum_Suffolk_NY_12032014_Affidavit.pdf
  67. 86. NYSupreme_Manhattan_PaperFiling_Amex_v_Rosenblum_04152015_for_12032015Affidavit.pdf
  68. 87. NYSCEF_Certificate_of_Signature_Amex_v_Rosenblum_Suffolk_NY_12032014_Affidavitxxxxxx
  69. 88. Public Notice Published President's Day Monday February 16 2015
  70. 90. C:\Users\Dan Rosenblum\Pictures\april 15 2015 60 centre street

DOE MATERIALS DMR SEEKS TO ENTER INTO EVIDENCE:

  1. Privacy Impact Assessment For Debt Management and Collection System (DMCS) Date: June 30, 2014 Point of Contact: Consuelo Johnson Consuelo.Johnson@ed.gov System Owner: Keith Wilson Keith.Wilson@ed.gov a. http://ifap.ed.gov/presentations/attachments/04EACSession09.pdf
  2. b. http://www2.ed.gov/notices/pia/pia-nco-031909.pdf
  3. c. Dwight.vigna@ed.gov Cynthia.battle@ed.gov and Gary.hopkins@ed.gov
  4. d. \Privacy Impact Assessment for the NCO Financial Systems (NCO) Date: 03/19/2009 Contact Point System Owner: Rich Amos Author: Paul Lagacey Information Owner: Dwight Vigna, U.S. Department of Education, Federal Student Aid System Security Officer: Greg Plenty, U.S. Department of Education, Federal Student Aid
  5. 2009
  6. f. 2. Why is this information being collected? All information received from the Department is used for the sole purpose of contacting the consumer and collecting owed funds on behalf of the Department of Education. NCO Financial Systems will utilize the information to (1) Facilitate the repayment of the loan, and (2) Identify the current status of the borrower.
  7.  

  8. g. 4. Will this information be shared with any other agency or entity? If so, with which agency or agencies/entities? Relevant information will be shared with NCO’s dedicated software providers, credit history providers, letter printing providers and data scrubbing providers: - Ontario Systems LLC: Muncie, Indiana 3rd Party software supplier of Collections Systems Software (FACS), Supplies core application code and enhancements - First Data Resources: Denver, Colorado, 3rd Party "data scrubbing" - TransUnion: Chicago, IL., 3rd party Credit Reporting - PSC Info Group: Oaks, PA., 3rd party print and mail solutions - Lexus Nexus: Miamisburg, Ohio, 3rd Party "data scrubbing" Privacy Impact Assessment FEDERAL STUDENT AID (FSA) PRIVATE COLLECTION AGENCY NCO Financial Systems 20 March 2009 page 3 US Department of Education - Corporation: St. Louis, Missouri, verify employment - Central Research: Lowell, AR, gather/verify incarceration information.
  9.  
  10.  
  11. 92. http://www2.ed.gov/notices/pia/pia-nco-031909.pdf
  12. 93. 27 See also:
  13. 94. Publication Date: May 31, 2012
  14. 95. Posted Date: May 31, 2012
  15. 96. Subject: Privacy Act of 1974, as Amended; Renewal of Computer Matching Program Between the U.S. Department of Education and the Internal Revenue Service.FR Type: Notice[Federal Register Volume 77, Number 105 (Thursday, May 31, 2012)] [Notices][Pages 32085-32086] From the Federal Register Online via the Government Printing Office [www.gpo.gov] [FR Doc No: 2012-13105] <http://ifap.ed.gov/fregisters/FR053112ComputerMatchIRSED.html>
  16. 97. And http://www.ifap.ed.gov/dlbulletins/attachments/DLB0502.pdf

  17. 98. And http://www2.ed.gov/about/offices/list/ogc/ogcethics.html
  18. 99. UNITED STATES DEPARTMENT OF EDUCATION OFFICE OF INSPECTOR GENERAL AUDIT SERVICES May 8, 2013 FINAL ALERT MEMORANDUM To: James W. Runcie Chief Operating Officer Federal Student Aid From: Patrick J. Howard /s/ Assistant Inspector General for Audit Subject: Verbal Complaints Against Private Collection Agencies Control Number ED-OIG/L06M0012
  19. 100. http://www2.ed.gov/about/offices/list/oig/auditreports/fy2013/l06m0012.pdf
  20. 101. Handling of Borrower Complaints Against Private Collection Agencies FINAL AUDIT REPORT ED-OIG/A06M0012 July 2014
  21. 102. http://www2.ed.gov/about/offices/list/oig/auditreports/fy2014/a06m0012.pdf
  22. 103. Paragraph:
  23. 104. ¶ system built by contract; requisites and performance of contract relied upon in several ways by agency, and/or BHC , and, in dispute, by courts. Cite part in Amex v Dan
  24. 105. ¶accountability in person with official responibilities of office associated with such commercial activity, for example, Dwight Vigna. The deliberate operational decisions are made following extensive career {insert recommendation/experience from LinkedIn.} Anyone in such office is purportedly in the Office with knowledge of responsibility in commerce to facilitate "just results" in Operational Policy as a whole. There are rewards associated with having risen to the experience to handle such office- the appointment o the position or the rise to such office does not reward such individual given the manner by which the position can be manipulated; the appropriate rewards and honors associated with such elevated corporate or public office come at a price- and the full benefit is due only if the entity functions appropriately in the market, including at the nexus to the public, and the justice system.
  25. 106. For example, in DOE department ENB:
  26. 107. ENB Business Operations, ENB, Chief Business Operations Officer, William Leith, 111I1, UCP, 5138, 377-3676
  27. 108. ENB Chief of Staff, Tim Branner 111G5 UCP 5138 377-4012
  28. 109. ENBG Program Management Services Group, Sue O’Flaherty 64E1 UCP 5453 377-3393 ENBG2
  29. 110. Default Division, Dwight Vigna 41F2 UCP 5320 377-3436
  30. 111. USDepartmentofEducationorg_directory.doc>
  31. 112. ¶
  32. 113. ¶

 

 

DMR STATEMENT REGARDING OFFICE OF DWIGHT VIGNA AS IT PERTAINS TO CODE OF PROFESSIONAL RESPONSIBILITY, CORPORATE LIABILITY, COURTS OF GENERAL JURISDICTION, ADMINISTRATIVE LAW, DUE PROCESS, CONGRESSIONAL INTENT

THE ALLEGATION OF BREACH OF CONTRACT, ALLEGATION OF DEFAULT SIGNED BY MR VIGNA

  1. 114. Mr. Vigna as ENBG2 has signed the HE2142-BV (07/2-014) for a variety of reasons, states here June 15 2015.
  2. 115. ¶ In one very strong regard, Mr. Vigna signs the HE2142-BV (07/2-014) so that DOE can affirm to IRS and DOJ that Notice has been given. Thereafter, if DOE does not receive an item of record from contractee within 60 days, DOE will assert "right" of wage garnish or IRS offset etc, plus, will make adverse reports to CRA. However, Mr. Vigna's signature, in the ENGBG2 Office at the US Department of Education must also assert positive knowledge that in fact DOE is indubitably knowledgea ble that contractee has not put forth defenses to allegation of breach of contract in a Court of General Jurisdiction, be it State or Federal, subject to Rules of Evidence, Discovery, Issues of Joinder, Statutes of Limitations, Rules of Civil Procedure
  3. 116. ¶ The contracts listed below should in fact allocate funds to a system of public case adjudications on defaults in the Educational Loan Market, and or any related subject matter, at a click of a button, as if any member of the public had walked into the appropriate court of general jurisdiction's library.
  4. 117. {see also Vigna Las Vegas presentation}
  5. 118.
  6. I. ¶Current Wages of Daniel M Rosenblum, include all expenses, include accounting of effect on garnishment at current wages, and, of additional from DOE. Statement that but for instant DMR inquiry, none of data put on record by DMR during 60 day period following Dwight Virgil
  7. d
  8. DMR hereby makes June 15 2015 Motion to move into evidence regarding the current allegation of default  or allegation of breach of contract made by DOE and NYHESC, motion to move in to evidence certain materials associated with the instant June 10  2015 by DMR, including the items with follow the Dwight Virgil bio and title for purposes of demonstrating that the Offices of Dwight Virgil should be knowlegable, and is here given Notice of the same, that, the Operational Systems and Policies in place effectuated by the Task Orders do not assure Dwight Virgil  as to whether there is subject matter relevant to the allegation of default (which Virgil signs, as if Virgil is aware and has deliberated all such subject matter and made determination as would have a Court of General Jurisdiction with Rules of Evidence and CPLR ) brought to the attention of Sallie Mae, Navient, or other "Processor" during correspondence while ervicer was under contract to receive such information and performed legal duties associated with the debt alleged to be in default by Mr. Virgil. Here, also in evidence for purposes of demonstrating that the Offices of Mr. Virgil exercised and exercises control over, and makes decisions over operational policy and the tasks. That such Office has made deliberate decisions which contribute to lack of due process, and are knowledgeable of the same. Entry into evidence, discuss that these are elemental facets of jurisprudence, that, upon an allegation of breach of contract, there is an entitlement to enter an answer, and to put forth items which substantiate such answer and comport with the rules of evidence and procedure. This, in defense of an alleged breach. These motions at Suffolk Level, and, in keeping with flawed DOE and NYHESC operational policies  which have Dwight Virgil  apparently of the impression that due process has been carried out prior to him putting his signature on the Notice of Default. Mr. Virgil  should not sign without being of the impression that due process had been carried out prior thereto by the agency in keeping with, and , the terms of the 60 day response, and how all data over the five or six years of existence of the loan are handled operationally as they relate to this paragraph, whether properly functioning as intended by Congress, stop payments to call centers, refer to paragraphs speak of same.
  9. bbb
  10. Move into evidence  PDFs webs associated with office, state movement into evidence is insofar as the allegation that such office fails in monitoring due process by operational  system and same office exercises relative control over such portion of the operational system, and that the office holders must be held to be knowledgable that the system fails in rising to the occasion of due process. Such office holders should indicate presently that they are not knowledgeable, and, DMR brings to the attention of the Office that the operational process(es) it oversees and is responsible for and relies upon  and controls to the extent that such office can correct, and is liable and accountable for its malfunction. Can correct using budget allocations. Again, should cease and desist from allocation of budgetary disbursements to call center operations in Philipines, Detroit, wherever- where unlicensed callers operate out of call centers as referred to in various paragraphs by DMR to date in the instant subject matter of educational loans 2006-20011 DMR. Cite phone records and characterization, monies allocated to such call centers have nothing to do with due process and therefore nothing to do with performance of the tasked contract citing links to tasked contracts.
  11. The DOE schemata is flawed and dangerous in multiple ways. Here, important matter, is circumventing due process in two ways, number one there is no statute of limitations on term. Further, one justification for theory of statute of limitations is 'swift resolve'. Swift resolve given facts and circumstances. At the time when the item is supposed to be taken care of. Here, the typical  defenses for breach of contract are being applied to deferment legal mechanism solely to grant defement, which is interruping a defense in contract not only effecting the contract in question, but the full portfolio of accounts. The schemata is calculated, DMR alleges that a significant percentage of deferments processed in the DOE portfolio during the life of the portfolio should not have been deferred but should have been processed as defenses on alleged breach, with a significant percentage of such occasions rightfully should have been determined in favor of defendants alleged to have breached with valid defenses. In processing the deferment, it is a legal transaction which should be of record at the time the Notice of Default is generated. The manner of applying and facilitating certain rules and procedures by the Agency   and not others is by design arbitary and capricious. It is not as if there are not other responsibilities the Agency has in setting operational  procedure.
  12. v
  13. Notice of Discovery Regarding Operational Policy and Budget Allocation to Perform Contracted Tasks and DOE Offices

    Regarding Department of Educational Offices of Dwight Virgil: description of control by office on operational policy as it relates to tasked obligations/ performed services, and related contractual budget obligations or allocations made by DOE to contractors. This, insofar as twofold: negligence in due process of operational system in place,  not comporting with Congressional intent of legislation granting authority to garnish wages as administrative action not subject to courts of general jurisdiction; to determine as to whether there is a benefit to the holder of the office related to such negligence.

  14. Motion to move in to evidence materials listed below n this June 15  2015 by DMR, including the items with follow the Dwight Virgil bio and title for purposes of demonstrating that the Offices of Dwight Virgil should be knowlegable, and is here given Notice of the same, that, the Operational Systems and Policies in place effectuated by the Task Orders do not assure Dwight Virgil  as to whether there is subject matter relevant to the allegation of default (which Virgil signs, as if Virgil is aware and has deliberated all such subject matter and made determination as would have a Court of General Jurisdiction with Rules of Evidence and CPLR ) brought to the attention of Sallie Mae, Navient, or other "Processor" during correspondence while ervicer was under contract to receive such information and performed legal duties associated with the debt alleged to be in default by Mr. Virgil. Here, also in evidence for purposes of demonstrating that the Offices of Mr. Virgil exercised and exercises control over, and makes decisions over operational policy and the tasks. That such Office has made deliberate decisions which contribute to lack of due process, and are knowledgeable of the same. Entry into evidence, discuss that these are elemental facets of jurisprudence, that, upon an allegation of breach of contract, there is an entitlement to enter an answer, and to put forth items which substantiate such answer and comport with the rules of evidence and procedure. This, in defense of an alleged breach. These motions at Suffolk Level, and, in keeping with flawed DOE and NYHESC operational policies  which have Dwight Virgil  apparently of the impression that due process has been carried out prior to him putting his signature on the Notice of Default. Mr. Virgil  should not sign without being of the impression that due process had been carried out prior thereto by the agency in keeping with, and , the terms of the 60 day response, and how all data over the five or six years of existence of the loan are handled operationally as they relate to this paragraph, whether properly functioning as intended by Congress, stop payments to call centers, refer to paragraphs speak of same.

  15. movement into evidence is insofar as the allegation that such office fails in monitoring due process by operational  system and same office exercises relative control over such portion of the operational system, and that the office holders must be held to be knowledgable that the system fails in rising to the occasion of due process. Such office holders should indicate presently that they are not knowledgeable, and, DMR brings to the attention of the Office that the operational process(es) it oversees and is responsible for and relies upon  and controls to the extent that such office can correct, and is liable and accountable for its malfunction. Can correct using budget allocations. Again, should cease and desist from allocation of budgetary disbursements to call center operations in Philipines, Detroit, wherever- where unlicensed callers operate out of call centers as referred to in various paragraphs by DMR to date in the instant subject matter of educational loans 2006-20011 DMR. Cite phone records and characterization, monies allocated to such call centers have nothing to do with due process and therefore nothing to do with performance of the tasked contract citing links to tasked contracts.

  16. A portion of budgetary allocations to the performers of the task order includes purposeful performance- the tasks contracted to be performed have a utility to them - related to - amongst  other things- DUE PROCESS. The Call Centers are not performing the contract, with the ramifications as stated above. THE AGENCIES DOE AND NYHESC SHOULD CEASE AND DESIST IMMEDIATELY FROM MAKING PAYMENTS TO ANY CALL CENTER NOT IN COMPLIANCE, AND OTHERWISE,  SUCH RECEIPT BY SUCH CALL CENTERS IN NON PERFORMANCE CONSTITUTES A TAKING FROM THE FEDERAL AGENCY CONTRARY TO CONGRESSIONAL INTENT.
  1.  
  2. ED-FSA-09-0-0021
    Base Contract
    https://studentaid.ed.gov/sa/sites/default/files/fsawg/datacenter/library/contracts/WindhamBaseContract.pdf
    President and CEO Erin WS Zaldastani 2009 $ 1 .00 contract

    b. West Asset Management, Inc.
  3.  
  4. ED-FSA-09-0-0019
    Base Contract
    https://studentaid.ed.gov/sa/sites/default/files/fsawg/datacenter/library/contracts/WestAssetBaseContract.pdf

    i. See Wage Determination
  5.  
  6.  
  7.  
  8. Attachment B

    c. The CBE Group, Inc.
  9.  
  10.  
  11. ED-FSA-09-0-0018
    Base Contract
    https://studentaid.ed.gov/sa/sites/default/files/fsawg/datacenter/library/contracts/TheCBEGroupBaseContract.pdf
    President CEO Thomas Penaluna 4/7/2009

    d. Progressive
  12.  
  13.  
  14. ED-FSA-09-0-0017
    Base Contract
    https://studentaid.ed.gov/sa/sites/default/files/fsawg/datacenter/library/contracts/ProgressiveFinancialServicesBaseContract.pdf
    Robert J. Pres CEO 4/7/2009

    e. Premiere Credit of North America, LLC
  15.  
  16.  
  17. ED-FSA-09-0-0016
    Base Contract
    https://studentaid.ed.gov/sa/sites/default/files/fsawg/datacenter/library/contracts/PremiereBaseContract.pdf

    f. Pioneer Credit Recovery, Inc.
  18.  
  19.  
  20. ED-FSA-09-0-0015
    Base Contract
    https://studentaid.ed.gov/sa/sites/default/files/fsawg/datacenter/library/contracts/PioneerBaseContract.pdf

    g. Van Ru Credit Corporation
  21.  
  22.  
  23. ED-FSA-09-0-0007
    Base Contract
    https://studentaid.ed.gov/sa/sites/default/files/fsawg/datacenter/library/contracts/VanRuCreditBaseContract.pdf


    h. National Recovery
  24.  
  25.  
  26. https://studentaid.ed.gov/sa/sites/default/files/fsawg/datacenter/library/contracts/NationalRecoveriesBaseContract.pdf

    i. National Recovery Contract Page 41:
  27.  
  28.  
  29.  
  30. "Prepare Eligible Cases for administrative resolution"
    Private Collection Agency Task Order No. ED-FSA-09-0-0025

    INTRODUCTION
    Attachment A - Statement Qj Work Private Sector Collection Activity For Student Related Debts

    The U.S. Department of Education (ED), Federal Student Aid, performs collection and administrative resolution activities on debts resulting from non-payment of student loans made under the Federal Family Education Loan (FFEL) Program: Stafford Loans (formerly the Guaranteed Student Loan Program and including Federally Insured Student Loans), Supplemental Loans for Students, PLUS Loans (formerly Parental Loans for Undergraduate Students), and Consolidation Loans; the William D. Ford Federal Direct Student Loan (Direct Loan) Program (formerly known as the Federal Direct Student Loan Program): Federal Direct StaffordIFord Loan Program, Federal Direct Unsubsidized StaffordIFord Loan Program, Federal Direct Consolidation Loan, and Federal Direct Plus Loans; and Federal Perkins Loans (formerly National Direct/Defense Student Loans). ED conducts similar collection and administrative resolution activities on debts resulting from a student's failure to fulfill grant requirements under the Pell Grant Program, the Supplemental Educational Opportunity Grant Program, the Academic Competitiveness Grant (ACG) and the National Science and Mathematics Access to Retain Talent (National SMART) grant. [Background information on each of these programs may be found in the website library http://fsacollections; or at http://ifap.ed.gov.]

    ii. Document begins with Section B...
  31. iii. {{SECTION B - SUPPLIES OR SERVICES AND PRICES/COSTS
  32. iv. B.l GENERAL
  33. v. This Task Order is issued in accordance with the General Services Administration's (GSA)
  34. vi. Financial and Business Solutions (F ABS) Schedule under Special Item Number (SIN) 520-4 for private collection services.
  35. vii. B.2 TYPE OF CONTRACT
  36. viii. This is a Performance-Based, Firm Fixed Price Task Order award, with provisions for pricing arrangements.
  37. ix. B.3 ORDERING PERIODS
  38. x. The first Ordering Period for the Task Orders will be from July 1,2009 (the effective date)through twenty-four (24) months, with multiple, optional ordering periods. The total Ordering Period, excluding any award term(s) earned, will not exceed 60 months from the date of initial data transfer, or October 22,2009. This is not a multiyear contract as defmed in FAR 17.1 .
  39.  
  40.  
  41.  

  42. xi. In addition, each contractor shall continue to work on accounts it retains during the InRepayment Retention Period. Upon expiration of the Ordering Period(s) of this Task Order, the in-repayment retention period will begin. If the Government exercises one or more Optional Ordering Periods, the In-Repayment Retention Period shall begin subsequent to the last Optional Ordering Period exercised. The in-repayment retention period will run for twenty-four (24) months, except that upon return, recall or transfer of all accounts from this
  43.  
  44.  
  45.  

  46. xii. Task Order, the in-repayment retention period will end. During the in-repayment retention period, the Contractor may retain, except as provided in paragraph (3) below, accounts that remain in repayment in accordance with the SOW. No transfer of accounts to the Contractor will occur during the in-repayment retention period.
  47.  
  48.  
  49.  

  50. xiii. 2) Prior Private Collection Agency (PCA) Task Orders-}}
  51.  
  52.  
  53.  



  54. xiv. {{
  55. xv. National Recovery Contract Page 41:
  56.  
  57.  
  58.  

  59. xvi. "Prepare Eligible Cases for administrative resolution"
  60.  
  61.  
  62.  

  63. xvii. Private Collection Agency Task Order No. ED-FSA-09-0-0025
  64.  
  65.  
  66.  

  67. i. " Prepare eligible cases for administrative resolution, Administrative Wage Garnishment (AWG) and litigation, based on the criteria in the Task Order, and meet established goals set by ED. The Contractor shall be responsible for obtaining documentation in accordance with administrative resolution procedures [as outlined in the Procedures Manual], or as requested by ED, and the forwarding of all such materials upon request." }}
  68.  Here, the typical  defenses for breach of contract are being applied to deferment legal mechanism solely to grant defement, which is interruping a defense in contract not only effecting the contract in question, but the full portfolio of accounts. The schemata is calculated, DMR alleges that a significant percentage of deferments processed in the DOE portfolio during the life of the portfolio should not have been deferred but should have been processed as defenses on alleged breach, with a significant percentage of such occasions rightfully should have been determined in favor of defendants alleged to have breached with valid defenses. In processing the deferment, it is a legal transaction which should be of record at the time the Notice of Default is generated. The manner of applying and facilitating certain rules and procedures by the Agency   and not others is by design arbitary and capricious. It is not as if there are not other responsibilities the Agency has in setting operational  procedure.
  69. Here, importantly, relying on the operator in the Philipines whose auto dialer happened to call the party to a contract during the time period that the issue at bar is not "stale" - here, utilizing the word 'stale' in the legal context used by DOE when seeking to justify why it is that the 60 day period following the Notice from DOE time bars litigation on the Garnishment effectuated following such 60 day period which follows, allegedly by DMR, 100 such 60 day periods wherein Notice by party to contract DMR has been given to DOE regarding fact of non-payment and related issues such as non-enforceablility of contract.

  70. . DMR states that DOE has demonstrated inability to build system which upholds rights of parties to contract, should cease and desist from avoidance of Courts of General Jurisdiction for dispute of contract, including allegations of non-payment and/or default. Note in addition that the Notice of Default states feasible increase of 25% of principal in collection costs. Such revenues should be, where meritorious, revenues associated with the State and Federal Judicial systems if indeed the task at hand in to actually adjudicate non performance on contract in the US Economy. The DOE should cease and desist in payments on contract resulting in illegality immediately. The call centers utilized by the Processors in the Student Loan market deserve no revenues from Student Loan Market and DOE should cease and desist from provision of revenues from adjudications and garnishments to such Call Centers which cannot make the affirmation that systems are designed to make of record information received by such processor verbally and digitally which information responds to Paragraph ____ of National Recoveries Contract during the time period that National Recoveries is purportedly fulfilling the performance requirements of the Omnibus Contract here cited. In the Case of DMR, it appears that presently DOE would assume DMR had not previously presented defenses on contract et al if DMR were not to respond to the Dwight Virgil April 16 2015 materials sent with signature to PO Box 3377 NY NY 10163.

  1. i. NCO
  2. ED-FSA-09-0-0014
    Base Contract
    https://studentaid.ed.gov/sa/sites/default/files/fsawg/datacenter/library/contracts/NCOFinancialBaseContract.pdf
    SVP Michael Noah

    j. National Recoveries
  3. ED-FSA-09-0-0025
    Base Contract
    https://studentaid.ed.gov/sa/about/data-center/business-info/contracts/collection-agency#national>
    Steven Cundiff CEO 4-07-2009

    k. Immediate Credit Recovery Inc.
  4. ED-FSA-09-0-0024
    Base Contract
    Felipe Yanes CEO March 26 2009, april 7 2009 Mike Wisher Contracting Officer
    https://studentaid.ed.gov/sa/sites/default/files/fsawg/datacenter/library/contracts/ImmediateRecoveryBaseContract.pdf



    l. GC Services
  5. ED-FSA-09-0-0012
    Base Contract
    https://studentaid.ed.gov/sa/sites/default/files/fsawg/datacenter/library/contracts/GCServicesBaseContract.pdf
    Linda Spellicy, Mike Wisher

    m. FMS Investment Corp
  6. ED-FSA-09-0-0011
    Base Contract
    https://studentaid.ed.gov/sa/sites/default/files/fsawg/datacenter/library/contracts/FMSBaseContract.pdf
    Balaji Rajan Mike Wisher

    n. Financial Asset Management Systems, Inc. (FAMS)
  7. ED-FSA-09-0-0010
    Base Contract
    https://studentaid.ed.gov/sa/sites/default/files/fsawg/datacenter/library/contracts/FinancialAssetManagementBaseContract.pdf

    Jenny Hozar ?? MW ?

    o. Enterprise Recovery Systems, Inc.
  8. ED-FSA-09-0-0020
    Base Contract
    https://studentaid.ed.gov/sa/sites/default/files/fsawg/datacenter/library/contracts/EnterpriseRecoverySystems.pdf



    p. Performant formerly known as Diversified
  9. ED-FSA-09-0-0009
    Base Contract
    https://studentaid.ed.gov/sa/sites/default/files/fsawg/datacenter/library/contracts/Performant_FKADiversifiedCollection_BaseContract.pdf
    Lisa Im CEO

    q. Delta Management Associates, Inc.
  10. ED-FSA-09-0-0023
    Base Contract
    https://studentaid.ed.gov/sa/sites/default/files/fsawg/datacenter/library/contracts/DeltaBaseContract.pdf
    Christopher Riordan CEO April 2009



    r. Con Serve
  11. ED-FSA-09-0-0004
    Base Contract
    https://studentaid.ed.gov/sa/sites/default/files/fsawg/datacenter/library/contracts/ConServeBaseContract.pdf

    Mark Davitt CEO


    s. Collecto, Inc. dba Collection Company of America (EOS)
  12. ED-FSA-09-0-0007
    Base Contract
    https://studentaid.ed.gov/sa/about/data-center/business-info/contracts/collection-agency#collecto

    t. Collection Technology, Inc.
  13. ED-FSA-09-0-0008
    Base Contract
    https://studentaid.ed.gov/sa/sites/default/files/fsawg/datacenter/library/contracts/CollectTechnologiesBaseContract.pdf


    u. Coast Professional, Inc.
  14. ED-FSA-09-0-0022
    Base Contract
    https://studentaid.ed.gov/sa/sites/default/files/fsawg/datacenter/library/contracts/CoastalBaseContract.pdf



    v. Iqor
  15. Formerly known as Allied
    ED-FSA-09-0-0013
    Base Contract
    https://studentaid.ed.gov/sa/sites/default/files/fsawg/datacenter/library/contracts/Iqor_FKAAlliedInterstate_BaseContract.pdf





    w. Account Control Technology, Inc.
  16. ED-FSA-09-0-0005
    Base Contract
    https://studentaid.ed.gov/sa/sites/default/files/fsawg/datacenter/library/contracts/AccountControTechBaseContract.pdf









    NOTE: Discovery Notice. DMR states that it is necessary to review the Sallie Mae, Navient, ACS Xerox and NYHESC contracts which are analogous and or privy to the above referenced servicing contracts items ¶§§¶ above as information collected and docuemented above in ¶§§¶ Affidavits etc displays. DOE should have already began and recognized that DMR has put forth defenses to breach of contract, both in writing, and articulated verbally to contractors presumably under “Task” Base Contracts which DMR alleges such contractors fail to perform such tasks and DOE and HESC are knowledgeable of such failure and/or are given notice hereby of such failure in performance for the full portfolio under such task arrangements which tasks are carried out in the manner they were in servicing of DMRs accounts by Navient, Sallie Mae, and ACS during 2006-2015.

    122.
  17. May 13 2015 NYT Articles emailed DMR to DMR Five felony Guilty Pleas by Bank Holding Companies

    Compare and contrast the nature in the judicial system of the felony guilty plea and the ramifications to the  entity, utilizing benchmarks such as severity of economic effect of judicial holding on a matter of contract in violation of law in jurisprudence, compare and contrast to effect of missed payment on credit report, which is part and parcel of what DMR alleges pertains to monopoly or antitrust issue, refer to default on educational loan, and, ability of person individual to enter into mortgage agreement which by nature in contrast to financial subject matter in jurisprudence has an anchor in property, the loan agreement itself is one that lenders should desire to enter into given collateral of property. The educational loan master promissory note is one mechanism which obfuscates the loan market as it is invalid manner to shore up risks in lending in the manner that mortgage guarantees against risk of lending. Knowedge of house and property  as safeguard as compared to education. Weigh against The Holding Company with felony mark. Do the scales of jurisprudence have some sort of parity ?

    2 of 9

    /refer to analysis of allocation of resources relied upon in Amex case- allocation of resources at the collector is relied upon by the hired firm. The hired firm is relied upon by the BHC, but the allocation of resources that the collection firm or loan servicer  in this instance- as processor- the allocation of resources is not only insufficient, but, is unjust, and results in unjust issues such as the response to Notice of the Lendee. In other words at Sallie Mae there is protestation which articulates the response to any purported Notice from DOE presently. DOE will say that presently it is Notice, but, the Sallie Mae records should indicate glaringly- if resource allocation was commensurate with actual contract performance- to DOE and to Justice System if a case were to eventuate- the record should indicate succinctly that there has already been a protestation, there has already been an objection, there have already been defenses in contract put forth.

    3 ofo 9
    But  as in Zwicker Thuotte phone recorded evidence line item, there's funding in operation of dial out items, callcenter items in Philipines, but, the primary function is collection of accurate information and operationally to have chosen to ensure no ease of impartial accurate record is a deliberate choice which results in unjust results and which non-performance implicates the servicer and the DOE when the DOE has knowledge of such non-performance, or comprehends that the systems in place cannot possibly result in upholding rights of parties to contract sponsored by the governmental agency.
     


    123. OIG re NCO and NYHESC
  18. 124. http://www2.ed.gov/about/offices/list/oig/invtreports/ny082005.html
  19. 125. UNITED STATES v. BARBARA SZCZUBLEWSKI

  20. 126. Acting United States Attorney Kathleen M. Mehltretter announced that Barbara Szczublewski, 43, of Lancaster, New York, was sentenced yesterday by United States District Judge William M. Skretny to three months home detention, four years probation and ordered to make restitution in the amount of $25,394.

  21. 127. Assistant U.S. Attorney Gregory L. Brown stated that on April 6, 2005, Szczublewski pled guilty to participating in a scheme that falsely consolidated $3.8 million in defaulted federal student loans and in doing so, earned bonus compensation from her employer, NCO Financial Systems, Inc, (NCO), located in Getzville, New York.



  22. 128. Pasted from <http://www2.ed.gov/about/offices/list/oig/invtreports/ny082005.html>









  23. 129. UNITED STATES v. BARBARA SZCZUBLEWSKI

  24. 130. Acting United States Attorney Kathleen M. Mehltretter announced that Barbara Szczublewski, 43, of Lancaster, New York, was sentenced yesterday by United States District Judge William M. Skretny to three months home detention, four years probation and ordered to make restitution in the amount of $25,394.

  25. 131. Assistant U.S. Attorney Gregory L. Brown stated that on April 6, 2005, Szczublewski pled guilty to participating in a scheme that falsely consolidated $3.8 million in defaulted federal student loans and in doing so, earned bonus compensation from her employer, NCO Financial Systems, Inc, (NCO), located in Getzville, New York.



  26. 132. Pasted from <http://www2.ed.gov/about/offices/list/oig/invtreports/ny082005.html>







  27. 133. Privacy Impact Assessment for the BFrame Collection System (PCA-BCS) Providing Private Collection Agency Services on behalf of the: US Department of Education Federal Student Aid
  28. 134. http://www2.ed.gov/notices/pia/pia-bframe-063009.pdf

  29. II. Insert Section
  30. The  June 15  2015 content by DMR to the US Department of Education, NYHESC, SSA, Citi, SallieMae, Navient, Amex, et. al.,  by Daniel M Rosenblum ("DMR" below") is also available for review via the following  World Wide Web URLs:

    1. http://www.twentyfirstcenturydigital.com/DOENationalRecoveriesBaseContract78Pages.php
    2. http://www.twentyfirstcenturydigital.com/DOEJune102015DMRosenblumAffirmation.php
    3. http://www.twentyfirstcenturydigital.com/DOEJune102015DMRosenblumAffirmationIMAGES.php
    4. http://www.twentyfirstcenturydigital.com/January2015NYHESCFinancialSupplement.php
    5. http://www.twentyfirstcenturydigital.com/JPG2014IRSSSAAllPaychecks.php
    6. http://www.twentyfirstcenturydigital.com/dmr06102015linksindex.php
    7. http://www.twentyfirstcenturydigital.com/January2015NYHESCFinancialSupplement.php
    8. http://www.twentyfirstcenturydigital.com/GarnishMaterialsNYHESCDecember2014.php
    9. http://www.twentyfirstcenturydigital.com/MayJunePOBox3377NoticesfromDEONYHESCSSA.php
    10. http://www.twentyfirstcenturydigital.com/January282011DMRtoSSAAppealsCouncilFallsChurchVA.php
    11. DMR August 4 2014 to Sallie Mae Navient ACS Xerox NYHESC:
    12. http://www.twentyfirstcenturydigital.com/LEGALSERVICEOFPROCESSANDINDEXEmail1August42014toSallieMaeACSXeroxAmexCiti.php
    13. DMR October  2014 to Sallie Mae Navient ACS Xerox NYHESC:
    14. http://www.twentyfirstcenturydigital.com/re_NYSHESCaccountnumber_900002888700_EMAIL1of2ColumbusDay201410132014.php
    15.  

    16. DMR November   2014 to Sallie Mae Navient ACS Xerox NYHESC:
    17. http://www.twentyfirstcenturydigital.com/LEGALNOTICEnovember2014NYHESCDANIELMROSENBLUMHESCACCOUNT900002888.php
    18. DMR February   2015 to DOE  Sallie Mae Navient ACS Xerox NYHESC:
    19. http://www.twentyfirstcenturydigital.com/LEGALNOTICE_February2015.php
    20. May 2015 Materials sent to DMR from US Social Security Administration :
    21. 2015 SSA Materials Alleging a Federal Liability and the below form dated October 2014, Form SSA-561 filed DMR October 19 2014
    22. http://www.twentyfirstcenturydigital.com/SSA2015FederalAllegedDMRLiability.php
    23.  Please also see related items 1998-2005; and for example, http://www.twentyfirstcenturydigital.com/January282011DMRtoSSAAppealsCouncilFallsChurchVA.php
    24. 08-31-2011 SSA Hearing 26 Federal Plaza  New York NY
    25. http://www.twentyfirstcenturydigital.com/08312011SSAHearing26FederalPlaza.php
    26. PRESIDENTS DAY 2015 AFFIRMATION AFFIDAVIT
    27. http://www.twentyfirstcenturydigital.com/AffidavitofServicePresidentsDay2015.php
    28. http://twentyfirstcenturydigital.com/December032014SeriesI.php
    29. http://www.twentyfirstcenturydigital.com/December032014SeriesA.php
    30. http://www.twentyfirstcenturydigital.com/December032014SeriesR.php
    31. http://www.twentyfirstcenturydigital.com/December032014SeriesC.php
    32. http://www.twentyfirstcenturydigital.com/December032014SeriesD.php
    33. http://www.twentyfirstcenturydigital.com/December032014SeriesE.php
    34. http://www.twentyfirstcenturydigital.com/December032014SeriesF.php
    35. These items can be downloaded are publically available through NYSCEF in E-File, American Express v Daniel M Rosenblum
    36. PAYCHECKS96Weeks012013to112014EFILEDNYSCEF.pdf
    37. DMR112014IRSTaxBinder2004to2014HESCNYSCEF11032014.pdf
    38. DMRSSABenefitLetterEFILEDNYSCEF 10132014.pdf
    39. DMR states that all  Materials EFiled in New York State Supreme Court speak to the truth of the matter asserted by DMR in this June 15 2015 letter to DOE, SSA, and NYHESC and should be construed to be of the complete record of the deliberation of such subject matter today addressed by DMR brought forth to DOE, NYHESC, and SSA, as with Citi and Amex etc.
    40. Materials filed to date at Efile can be accessed in several ways:
    41. These items can be downloaded are publically available through NYSCEF in E-File, American Express v Daniel M Rosenblum
    42. http://twentyfirstcenturydigital.com/December032014SeriesA.php
    43. PAYCHECKS96Weeks012013to112014EFILEDNYSCEF.pdf

    DMR112014IRSTaxBinder2004to2014HESCNYSCEF11032014.pdf

    DMRSSABenefitLetterEFILEDNYSCEF 10132014.pdf

    1. 89. C:\Users\Dan Rosenblum\Documents\2015 Documents begin December 2014\2015NYSCEFfilingbeginMarch232015\April15201560CentreFiling

    2. 85. NYSCEF_Certificate_of_Signature_Amex_v_Rosenblum_Suffolk_NY_12032014_Affidavit.pdf
    3. 86. NYSupreme_Manhattan_PaperFiling_Amex_v_Rosenblum_04152015_for_12032015Affidavit.pdf
    4. 87. NYSCEF_Certificate_of_Signature_Amex_v_Rosenblum_Suffolk_NY_12032014_Affidavitxxxxxx
    5. 88. Public Notice Published President's Day Monday February 16 2015
    6. 90. C:\Users\Dan Rosenblum\Pictures\april 15 2015 60 centre street

    1.  

    2. These items can be downloaded are publically available through NYSCEF in E-File, American Express v Daniel M Rosenblum :

    3. In response to an allegation of default, and/or breach of contract, and/or liabilities incurred by DMR to DOE, NYHESC, and / or SSA DMR enters, and has entered through DOE, NYHESC, ACS Xerox, Navient, Sallie Mae, and to SSA, over the course of several years,  an answer of non-default to any contract, and, alleges counter suits of negligence and  other libelous both to the parties alleging against DMR and additional parties which disputes should be joined given the subject matter(s) of all parts as articulated by DMR variously to date please see http://www.twentyfirstcenturydigital.com/dmr06102015linksindex.php

    4. http://twentyfirstcenturydigital.com/Amex09152013DocList.php
    5.  

    6. Images of the full case as viewed on the NYSCEF system as of November 2014 can be viewed on this web page, which has live links to NYSCEF for most filed items: http://www.twentyfirstcenturydigital.com/9999_SupremeandCourtofClaimsDocumentListforAmexvDanNovember52014_9999.php
    7. The full case can be viewed on the NYSCEF LIVE SYSTEM BY LOGGING IN AT : https://iapps.courts.state.ny.us/nyscef/Login
    8. www.December 2014/AFFIDAVITOFSERVICE/AffidavitofServicePresidentsDay2015.php

    9. http://www.twentyfirstcenturydigital.com/AffidavitofServicePresidentsDay2015.php

    10.  


    11. The content of this  June 10  2015 email to the US Department of Education by Daniel M Rosenblum ("DMR" below") is also available for review via the following 4 World Wide Web URLs:

       

 

 

additional images and links to information regarding the above subject matter including 21st Century Digital, and,  my New York NY hard copy and Suffolk NYSCEF filings in the matter of American Express v Daniel M Rosenblum are available via Dan's website at the filing web pages:

http://www.twentyfirstcenturydigital.com/December032014SeriesI.php

http://www.twentyfirstcenturydigital.com/ThursdayDecember51996.php

http://www.twentyfirstcenturydigital.com/TTSMay1996toMay2012.php

http://www.twentyfirstcenturydigital.com/December_9_1996_Twenty_First_Century_Digital.php

http://www.twentyfirstcenturydigital.com/MondayDecember9199621stCenturyDigitalestablished.php

http://www.twentyfirstcenturydigital.com/amex.php

http://www.twentyfirstcenturydigital.com/Amex09152013DocList.php

http://www.twentyfirstcenturydigital.com/DMROriginalApril142011answer.php

http://www.twentyfirstcenturydigital.com/April51999.php

http://www.twentyfirstcenturydigital.com/Beach2000-2005.php

http://www.twentyfirstcenturydigital.com/TheLawTheBankAndTheBeach.php

http://www.twentyfirstcenturydigital.com/TTSDocket19961997.php

http://www.twentyfirstcenturydigital.com/9999_SupremeandCourtofClaimsDocumentListforAmexvDanNovember52014_9999.php

 

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