Fraudulent Claim* False Statements* Intent to Commit Insurance Fraud
" STOP the Animal Neglect in Columbia County, N.Y" would like discuss Nussinow's Federal complaint filed against the County of Columbia, Columbia Greene Humane Society (CGHS), Ronald Perez, President and Animal Investigator CGHS, and Lee DeLisle, former Police Officer, and Chief Animal Cruelty Investigator at CGHS.
We can try to separate FACTS from FICTION taken directly from Nussinow's complaint.
Feel free to join the discussion with any corrections, or additional information. We can cover Nussinow's complaint in which she is demanding 15 million dollars in damages over the course of the next few days.
ALL of the relevant FACTS for the Defense have not been reflected in ANY of the responses made by County of Columbia attorneys so far, and false statements made by Nussinow under oath during depositions have not been challenged by Defense Counsel, or Defendants Columbia County, Columbia Greene Humane Society, Ronald Perez, and Lee DeLisle. That is odd, isn’t it ?
Wouldn’t you think the County of Columbia, with a deficit estimated to be approximately 13-20 million dollars would be aggressively defending themselves against a 15 million dollar “fraudulent” lawsuit, and File a Motion with the Court requesting all legal fees and expenses be paid by Nussinow to reduce the financial liability of the County, and its Agent CGHS, and gather all relevant facts to dispute Nussinow’s false assertions, and protect the Government, and its Agent from “paying” out a fraudulent claim at the expense of the already struggling Taxpayers that will undoubtedly experience further financial hardships this winter, and higher taxes due to the COVID pandemic and higher tax premiums ?
Opinion: Columbia Greene Humane Society, Ronald Perez, and Lee DeLisle and Counsel have not thoroughly investigated, interviewed, deposed, gathered discovery evidence for their defense, or Filed a Motion to Dismiss the case. What? Does their insurance carrier know that? Who is CGHS Insurance Carrier, and why aren't they defending themselves against a multi-million-dollar fraudulent claim against CGHS, the lead Animal Cruelty Investigative Agency in Columbia County, and Agent of Columbia?
Nussinow's sworn testimony:
According to Plaintiff, from April 2017 until June 2017, she rescued approximately ten horses, all of which were in very poor physical shape, underweight for their size, had poor muscle and skin tone, and overall showed evidence of severe neglect, which is characteristic of horses caught up in the slaughter auction process. See id. at ¶ 25.
Response: "between 4/17 to 6/17 Nussinow often solicited money and property (auction horses) from the Public on the Internet, apparently misrepresenting the care she would provide the horses. Nussinow shipped or caused to ship the horses intrastate with apparently with the intent to defraud the public. Nussinow instructed members of the Public to "wire" her money to her PayPal account Info@ xxxxxxxxxxxxltd.com.
It is unknown if Nussinow, in Chapter 12 Bankruptcy Protection since 10/2015, declared the monies/and income of the donated property ( horses) as income for the ten (10) horses ( property ) that she obtained custody of through donations from the public, or the income derived from the same property ( horses) upon the sale of the said property ( horses) to the Chapter 12 Trustee, or the IRS. "It is our opinion once Nussinow gained custody of the rescue horses she would often neglect and starve them". Nussinow testified under oath See id 25: " all of which were in very poor physical condition, shape, underweight for their size, and overall evidence of severe neglect."
RESPONSE FOR DEFENSE OF COUNTY OF COLUMBIA, CGHS, PEREZ, AND DELISLE.
Fact: 4/17: Nussinow obtained custody of HORSE # 094, a grey QH mare approximately 7 years old in good physical condition, weight was average or above average, and showed no signs of neglect. HORSE # 094 was so chubby when she arrived at BS Farm, Nussinow said she "thought she may be pregnant".
FACT: 4/17 According to Nussinow FB postings, she solicited money on the Internet from the public to gain custody of 3 horses. The Public, "eager" to help save the horses from slaughter "wired" money as instructed to Nussinow's PayPal account so Nussinow could obtain custody of the 3 horses she promised to provide for and "save" them from slaughter. Nussinow shipped or caused to ship the same 3 horses intrastate. The 3 horses Nussinow shipped intrastate on or about 4/17/17 included a dark Thoroughbred type horse, a roan pony mare, and a red mini mule. Nussinow posted pics of the 3 newly "donated" horses upon their arrival at BS Farm in the evening on/about 4/17/17. Each horse/mule appeared to be in very good health, were average or above average weight, and showed no outward signs of neglect i.e. wounds, slashes, or obvious injuries.
Nussinow kept the roan pony mare called "Lilly" from 4/17 to 10/18 or 19 months before advertising to sell "Lilly" on or about 10/17. Nussinow obtained custody of Lilly 4/17 in good body condition, with average or above average weight, with no obvious outwards signs i.e. wounds, slashes, or injuries and sold Lilly approximately 19 months later 10/18 "fully emaciated" to a Catherine R. from Milford, Connecticut. According to Catherine R. she was instructed to "pay" for Lilly in advance by "wiring" money or "mailing" money to Nussinow. According to Catherine R., Nussinow promised Catherine R. she would provide Catherine R. a negative Coggins test and health certificate for " Lilly", both requirements to ship a horse intrastate from New York to Connecticut. Catherine R. said she was instructed to arrive after 9pm at BS Farm to pick up "Lilly" despite protests from Catherine R. Catherine R. wanted to travel in the daylight, especially trailering a "new horse" in unfamiliar territory. Nussinow was adamant the pick-up of " Lilly" must be after 9pm.
Catherine R. picked up the roan pony she had purchased from Nussinow and paid for the property ( horse) Nussinow gained custody of the roan pony named "Lilly" in 4/17 in very good physical condition, average to above average weight without any outward signs of neglect 19 months earlier by "wiring" funds to Nussinow, or "mailing" the funds to Nussinow using the postal service. Catherine R. stated she arrived to pick up "Lilly" in early November 2018 and was "horrified" by the emaciated condition of the roan mare she purchased over the Internet, paying by "wiring money" or using the "postal service" to pay for "Lilly" in advance as required by Nussinow. Nussinow provided Catherine R. a current Coggins test performed by Gonzalo Diaz, DVM from SmartEq, but failed to provide Catherine R. the required and agreed upon health certificate. Catherine R. decided to transport " Lilly" out of BS Farm because she "feared for the pony's life". Subsequently, the Connecticut Animal Control performed an examination of the sick and emaciated roan pony named "Lilly" Catherine R. just purchased the day before from Nussinow, and wrote an incident report about the description of the emaciated roan pony Catherine R. just purchased from Nussinow and the lack of valid Health Certificate required to ship a horse intrastate. A formal complaint was filed with the NYSP re: Animal Cruelty at BS Farm and the Connecticut Animal Control.
So far, we've only covered the first page of Nussinow's 15 million dollar complaint filed against the County of Columbia and there is already undisputed evidence Nussinow gave false testimony under oath. Sworn testimony is evidence given by a witness who has made a commitment to tell the truth. If the witness is later found to have lied whilst bound by the commitment, they can often be charged with the crime of perjury.
See id. at ¶ 25. "she rescued approximately ten horses, all of which were in very poor physical shape, underweight for their size, had poor muscle and skin tone, and overall showed evidence of severe neglect" is a FALSE STATEMENT.
There are several more pages to go, and likely there will be several more FALSE Statements made by Nussinow under oath identified.