UNITED STATES DISTRICT COURT

DISTRICT OF NEW JERSEY

______________________________________________________________________________
KARIN WOLF, individually & as the parent,
natural guardian and next friend on behalf of
D.C. and G.C.,
Plaintiffs,
-againstGERALD C. ESCALA, individually and as a
STATE actor Judge for the Bergen County
Family Court, EDWARD J. CRANE, PETER
VAN AULEN, ESQ., DR. JUDITH BROWN
GREIF, WILLIAM R. DELORENZO,
individually and as a STATE actor Judge for the
Bergen County Family Court, JUDGE BONNIE
J. MIZDOL, individually and as a STATE actor
Judge for the Bergen County Family Court,
JUDGE PETER DOYNE, individually and as a
STATE actor Judge for the Bergen County
Court, CHIEF JUSTICE STUART RABNER,
individually and as a STATE actor Judge for the
NJ SUPREME COURT, GOVERNOR CHRIS
CHRISTIE, individually and as STATE actor
Governor, STATE OF NEW JERSEY,
BERGEN COUNTY FAMILY COURT OF
THE SUPERIOR COURT OF NEW JERSEY;
OFFICE OF THE COUNTY COUNSEL,
APPELLATE DIVISION OF THE SUPERIOR
COURT OF NEW JERSEY, JUDGE WILLIAM
E. NUGENT, individually and as a STATE actor
Judge for the Appellate Court, JUDGE HARRY
G. CARROLL, individually and as a STATE
actor Judge for the Appellate Court, JUDGE
ELLEN L. KOBLITZ, individually and as a
STATE actor Judge for the Appellate Court,
JUDGE JOHN C. KENNEDY, individually and
as a STATE actor Judge for the Appellate Court,
JUDGE JEROME M ST. JOHN, individually
and as a STATE actor Judge for the Appellate
Court, JUDGE VICTOR ASHRAFI,

CASE NUMBER: 14-cv-5985

CIVIL INVESTIGATIVE
DEMAND PURSUANT TO
18 USC 1968 and
31 USC 3733

individually and as a STATE actor Judge for the

Appellate Court, JUDGE JOSEPH L.
YANNOTTI, individually and as a STATE actor
Judge for the Appellate Court, OFFICE OF
COURT ADMINISTRATION, BERGEN
FAMILY CENTER, CONSTANCE RITZLER,
JOHN CUTTITO, ALEXANDRA STREMLER,
ESQ., ROGER RADOL, ESQ., DIANA
MOSKAL, KATHY KATONA, ESQ., LISA
ESTRIN, DYFS n/k/a DCP&P, TARA HORNE,
SANDRA CRUZ, CRUZS SUPERVISOR,
PATRICK YAN, DEBBIE GOMEZ, ERIKA
FRANK, DIONOS BURGOS, IVAN NINA,
FULL CIRCLE, KRISTIN CIRELLI,
ADVISORY COMMITTEE ON JUDICIAL
CONDUCT, ATTORNEY GENERAL OF THE
STATE OF NEW JERSEY - BOARD OF
ETHICS, GOOD SHEPHERD LUTHERAN
CHURCH, THE REVEREND ROGER W.
SPENCER, JANET TENORE, LUCIANA
COUNTINHO, MARLENI COUNTINHO,
PLINIO COUNTINHO, BANK OF AMERICA
MERRILL LYNCH, a corporation, DOES,
Defendants.

Karin Wolf
P.O. Box 473
New York, NY 10163
Tel. 201-450-2192
Fax 646-786-3347
karinelenawolf@gmail.com
CIVIL INVESTIGATIVE DEMAND
To: All Defendants

Pursuant to the authority granted to Karin Wolf as a private attorney general under the provisions
of 18 USC 1964 of the Federal RICO Act, 18 USC Chapter 96, you are hereby directed to
produce the documentary material specified herein.
You are to make available the documentary material described herein on or before February 28,
2015. You may forward the responsive material via courier or certified mail to Karin Wolf at
P.O. Box 473, New York, NY 10163, if the information is no bigger than a large envelope and
can be sent to a P.O. box. If documentary evidence is in the form of a package or other large
container, you must notify Karin Wolf when the materials are ready to arrange for receipt.
The Civil Investigative Demand is relevant to the subject matter of an investigation of the abovenamed Defendants for racketeering pursuant to the provision of law coded at 18 USC Chapter
96, otherwise known as the RICO Act of 1972, for allegedly running a corrupt Enterprise via the
New Jersey Family Courts.
If you are not named above, you may have been identified as a racketeer, aid, and/or abettor.
The nature of the conduct constituting the alleged racketeering violation is, but not limited to,
unlawfully rigging family court proceedings for profit and pleasure of harming others, Kids for
Cash, fraud, fraud upon the court, honest services fraud, bribery, human trafficking, child
prostitution, child pornography, civil conspiracy to deprive others of rights and liberties,
discrimination against a class of persons, Title 9, Title 4D, obstruction of justice, tampering with
a witness, victim or informant, misprison of felonies, false advertising, false claims, sedition,
treason, and the averments as set forth in the Plaintiffs RICO Complaint filed with the U.S.
District Court, District of New Jersey, Newark, Wolf v. Escala, case no. 14-cv-5985. Further
alleged conduct will be alleged in Plaintiffs upcoming Amended Complaint and Supplemental
Pleadings, in which you may be named as a Defendant.
Please be advised that any person who attempts to avoid, evade, or prevent compliance, in whole
or in part, with this directive by removing, concealing, withholding, destroying, mutilating,
altering, or by any other means falsifying any documentary material may be guilty of a crime
punishable, upon conviction, by fine or by confinement, or both.
Please be advised that the following is a preliminary list and further investigative discovery may
be demanded or required.

MATERIALS DEMANDED
1. All of your tax returns for the past 10 years.
2. All of your bank and other financial information for the past 10 years, including, but not
limited to 401Ks, investments accounts, offshore accounts, mortgages, campaign
contributions, donations and other monies given and/or received, etc.
3. All correspondence by any means between you and Defendants for the past 10 years,
including internal court emails and messages.
4. Full disclosure and records of all real estate, car, boat, and other major properties owned
by you in whole or part for the past 10 years, where they are located, and how they were
purchased.
5. Full disclosure and records of all businesses owned by you in whole or part in the past 10
years, where they are located, and how they were purchased.
6. All child custody evaluations in the past 20 years in which you were involved.
7. All Court orders in the past 20 years concerning child custody, child abuse, adoption and
termination proceedings in which you were involved.
8. All ethics and other complaints against you or submitted to you regarding Defendants in
the past 20 years.
9. Disclosure of all lawsuits you have been involved in for the past 20 years.
10. All phone logs between you and other Defendants for the past 10 years.
11. All audio, video, and other recordings made by you of the Plaintiffs and/or of which they
are in possession, for the past 10 years.
12. All audio, video, and other recordings of any child(ren) made by you and/or of which you
are in possession, for the past 10 years.
13. All medical, dental, psychological, religious, and school records of D.C. and G.C. you
have and/or to which you have access. If access is unattainable to you, state person(s) or
entities who is/are in possession.
14. All reports and data concerning D.C. and G.C.
15. Transcripts of all court proceedings for Bergen County Docket # FM-02-439-07.
16. Full disclosure of all organizations, programs, clubs, societies, institutions, politics, etc.
to which you belong, attend, donate to, and/or otherwise participate, now and over the
past 20 years (i.e. golf, Freemasons, political campaigns, etc.); the nature of which, where
they are located, when they meet, when you attended, where and how they are funded.
17. Full disclosure of any knowledge you have about the Defendants ownership of items as
listed and as applicable above, such as properties and businesses they own or have owned
in the past 10 years or documentation of which they are in possession or have access.
ISSUED THIS 17th day of February, 2015

Designated Persons:
Rachel Alintoff

_____________________________________
Karin Wolf
Private Attorney General