YINGHUA GUO ) SUPERIOR COURT OF NEW JERSEY
Plaintiff, ) CHANCERY DIVISION - FAMILY PART
) SOMERSET COUNTY
) DOCKET NO. FM-18-301-11
GANG LIU ) CIVIL ACTION
) Request Emergency relief and request the Court to investigate the
) correctness of the procedure for creating this case, etc.
1. I am Gang Liu, Pro Se for this case.
2. All the facts stated by me herein are true, correct and complete to the best of my knowledge and understanding.
3. Judge Thomas Miller hadn't handle the divorce case (docket number FM-18-301-11) fairly. Actually, Mr. Thomas Miller manipulated this case in early September 2010 in favor Yinghua Guo. In a motion Gang Liu submitted on March 26th, 2013, I listed some of the facts to show how Judge Thomas Miller handle this case unfairly to favor Yinghua Guo, and manipulated this case to persecute Gang Liu. That motion can be found at the following link:
4. This testimony will only list one fact to show how Judge Thomas C. Miller helped Yinghua Guo to create this divorce case through illegal process or procdure.
5. Somerset County Counsel Thoms C. Miller contacted with Yinghua Guo's Attorney via Fcacimile on June 23rd, 2010. As shown in Exhibit 1. This file shows that Judge Thomas Miller has known Elisa Guo before the divorce case created.
6. On September 2nd, 2010, Ms. Natalee Picillo, Gang Liu's ex-attorney, submitted the divorce complaint along with this file to the Somerset County Superior Court, as shown in Exhibit 2. This file clearly indicated that Gang Liu was the Plaintiff, while Yinghua Guo was the Defendant. However, County Counsel Thomas Miller and some other court staffs asked Ms. Natalle Picillo to wait for few days to submit the complaint, so that Yinghua Guo could submit the complaint first. Obviously, Mr. Thomas Miller and some court staffs had manipulated the case to favor Ms. Yinghua Guo.
7. On September 9th, 2010, right after the final trial for another case, Ms. Picillo asked Gang Liu to sign on the file named "Answer and Couner-claim". As shown in Exhibit 3.
8. Gang Liu had never been served with the original complaint. Gang Liu asked Ms. Picillo to provide the original complaint. Ms. Picillo told Gang Liu that Yinghua Guo's attorney would provide a copy once they submitted it to the court! Gang Liu's attorney had prepared the Counter-complaint before the original complaint was served! It must be the court staffs, especially Mr. Thomas Miller, who make the two attorneys work together on both original complaint and the counter-complaint, and to set up Gang Liu.
9. The court record file shows that the Plaintiff's original complaint was submitted on September 10th, 2010, which was one day behind the submitting date of the defendant's counter-complaint! It clearly shows that some staffs of the Somerset County Superior Court manipulated the case to have Gang Liu's attorney to work with Yinghua Guo's attorney to set up Gang Liu.
10. Once Gang Liu signed the Counter-complaint file at the court room, Ms. Picillo immediately met with Mr. Allen P Comba, who was representing Yinghua Guo at that time, and they submitted the original complaint and the Counter-complaint at the same time.
11. I believe the proper procedure to create this divorce case should be as following:
11.1. The plaintiff submits the original complaint to the court.
11.2. The plaintiff serves a copy to the defendant properly.
11.3. The court issues a notice to both sides and requests the defendant to response to the original complaint, the responding date should be at least 21 days.
11.4. The defendant tried to retain an attorney.
11.5. The defendant or his attorney to file Counter-complaint.
12. This divorce case, DOCKET NO. FM-18-301-11, was not created properly. It was created illegally and manipulated by some of the Court staffs, especially Mr. Thomas C. Miller.
13. The defendant had never been served with the original complaint. Gang Liu asked the court to provide evidences for the serving the original complaint to the defendant.
14. The court hasn't issue a court notice to the defendant regarding the original complaint. Gang Liu requests the Court to provide the copy of the notice and the evidences for serving that notice to the defendant.
15. Before the divorce complaint was created, Mr. Thomas C. Miller and Mr. Allen P Comba had approached Ms. Picillo to discuss how and when to submit the divorce complaint. It was Mr. Thomas C. Miller to arrange the two attorneys to meet privately. Both of the two attorneys violated the professional ethics.
16. The defendant requests the Court to investigate this case and see if the case created properly.
17. If this case was not created properly, the defendant requests the Court to subpoena all the relevant individuals, including Ms. Natalee Picillo, Mr. Thomas C. Miller and Mr. Allen P Comba. They should explain to the court why they manipulate this case, and who asked them to do so.
18. If the Court wanted to give a final trial for this case, the defendant request for a jury to give final trial for this case.
19. The major difficulty to have this case resolved is the discovery. In early September 2010, the defendant has submitted files to request the plaintiff to provide the discovery files, especially the bank statements for her 14 bank accounts. However, the plaintiff hadn't provided the requested files until 2013.
20. The Plaintiff provided some of the requested bank statements. However, the plaintiff provided only partial of the bank statements: only 3 bank accounts were provided, and many of the statements for these 3 bank accounts were missing! The plaintiff tried to cheat the court by providing partial bank accounts. The defendant request the court to subpoena Yinghua Guo to force her to provide all the requested bank account statements. The court shouldn't allow the plaintiff to cheat the court and to hide the asset to the court.
21. The defendant has listed more requests in his previous motion submitted on March 26, 2013. The defendant asked the Honorable Judge to reconsider the requests listed in that motion.
22 The Plaintiff had transferred large amount of cash from the joint accounts to her personnel accounts, about $280,000 in total. The transferred money need to be returned to the defendant.
23. The Defendant requests emergency relief. There are about $90,000 in the escrow account. The Defendant requests $45,000 from the escrow account for emergency relief, so that he can retain an attorney to resolve this case.
24. The Defendant requests the Court to have Mr. DeTommaso resigned as the legal Guardian of the Defendant.
On the day of July 22nd, 2013
Exhibit 1. Somerset County Counsel Thomas C. Miller contacted with Yinghua Guo's Attorney via Fcacimile on June 23rd, 2010. This file shows that Judge Thomas Miller has known Elisa Guo before the divorce case created.
Exhibit 2. On September 2nd, 2010, Ms. Natalee Picillo, Gang Liu's ex-attorney submitted the divorce complaint along with this file to the Somerset County Superior Court. This file clearly indicated that Gang Liu was the Plaintiff, while Yinghua Guo was the Defendant. However, County Counsel Thomas Miller and other court staffs asked Ms. Natalle Picillo to wait for few days to submit the complaint and let the wife submit the complaint first. Obviously, Mr. Thomas Miller and some court staffs had manipulated the case to favor Ms. Yinghua Guo.
Exhibit 3. On September 9th, 2010, Ms. Picillo submitted this "Answer and Counterclaim" to the Somerset County Superior Court. At the same time, Mr. Allen P Comba represented Yinghua Guo submitted the original divorce complaint to the Court. Obviously, it was Judge Picheca and County Counsel Thomas Miller arranged the two attorneys submitted Yinghua Guo's complaint and Gang Liu's Counter-complaint at the same time!
Exhibit 4. The court files indicated that the Plaintiff's original complaint was submitted on September 10th, 2010, which was one day behind the submitting date of the defendant's counter-complaint! It clearly shows that the some staffs of the Somerset County Superior Court manipulated the case to have Gang Liu's attorney to work with Yinghua Guo's attorney to set up Gang Liu.
Honorable Judge Michael F. O'Neill will handle this case starting from July 22nd, 2013. Hope he would give a fair trial to this case.
Honorable Judge Michael F. O'Neill.