I am trying to sue NYC in the supreme court as a pro se. I tried to get some legal references or laws regarding my claim, but they might not be accurate. Please, ADD, EDIT, Modify or Delete as you fit.

The City of New York, The New York City
Commission of Human Rights

Index No.

Complaint and Jury Demand
The venue is based on the location of the
plaintiff’s residence county to this action.

P E R S O N S:

PLEASE TAKE NOTICE that upon the annexed affirmation of Sultan Al Maruf., (the
“Plaintiff”), the exhibits annexed hereto and the prior proceedings herein, the undersigned will
move this Court on [ENTER DATE YOU WILL FILE THIS MOTION] or as soon thereafter as
counsel may be heard for Orders:

1. For a trial;
2. Jury Demand,

Dated: City of Queens, New York By:

Sultan Maruf
3605 29 th Street, Apt E9,
Long Island City, NY 11106
Phone: 929-451-2152

Sultan Maruf ("Plaintiffs") allege as follows:
1. Sultan Maruf is a resident of Queens County.
2. At all times mentioned, Defendant City of New York, was and is a municipal corporation duly
organized and existing by virtue of the laws of the State of New York.
3. Upon information and belief, Defendant New York City Commission of Human Rights (NYC
CCHR) is an agency of the City of New York, and created and organized by virtue of the laws of
the State of New York.
6. On or about the 8th day of October 2020, and within ninety (90) days after the claim herein
arose, the Plaintiffs served a Notice of Claim in writing sworn to on their behalf upon Defendant
City of New York, by delivering a copy thereof in duplicate to the officer designated to receive
such process personally, which Notice of Claim advised the Defendant City of New York, of the
nature, time, place, and the manner in which the claim arose, the items of damage and injuries
sustained so far as was then determinable.
7. At least thirty (30) days have elapsed since the service of the claim prior to the
commencement of this action and adjustment of payment thereof has been neglected or refused,
and this action has been commenced within one year and ninety days after the happening of the
event upon which the claims are based.
8. All conditions and requirements precedent to the commencement of this action have been
complied with.
9. The oral examination of Plaintiff has been conducted in compliance with Section 50-H of the
General Municipal Law.
10. Pursuant to CPLR Section 1602(2)(iv), Defendants are jointly and severally liable for all of
the Plaintiffs’ damages, including but not limited to Plaintiff non-economic loss.
ll. New York City Commission of Human Rights employees refer to employees and other
governmental officials who participated in the relevant facts but some identities and/or full
names are unknown. (John and Jane Doe collectively referred to as " Officers" or
”Defendant(s)"). Some of them are known are directly involved:

 Katherine Carroll
 Johanna C. Segal
 Martha Perez-Pedemonti
 Charles
 Boris
 Carmelyn P. Malalis -Chair and Commissioner of NYC CCHR
 Sapna V. Raj – Deputy Commissioner of NYC CCHR

12. Upon information and belief, at all times mentioned, Defendant employees, were and are,
officers of the Defendant City of New York, and at all times herein was acting in such capacity
as the agent, servant, and employees of the Defendant City of New York.

13. On or about October 8, 2020, in the vicinity of their office, County of New York, City, and
State of New York, the Defendants jointly and severally in their capacity of officers, committed
retaliatory actions upon Plaintiff.
14. On the above-mentioned date, Johanna C. Segal, Esq., while on duty as an Officer for
Agency Attorney of Law Enforcement Bureau (LEB), New York City Commission on Human
Rights, 22 Reade Street, New York, NY 10007, -issued a closure letter at the Plaintiffs for
administrative cause after tormenting plaintiff for about 1394 days (3 years 9 months and 5
15. Sultan Maruf the Plaintiffs as he was exercising his constitutionally protected rights under
Federal, State, and NYC law including NYC Charter to get the proper justice in the court of law
regarding landlord’s racist remarks that he recorded where landlord’s manager berated and
taunted, “… Bangladeshi, Indian, and Pakistani people brought bedbugs in this country…”.
16. Complaint was lodged January 3, 2017, and a probable cause letter was issued March 12,
2019. It took the NYC Commission of Human Rights 798 days (2 years, 2 months, and 9 days)
to issue a probable cause letter whereas the audio recording length was only 15 minutes and 48
seconds long. Any reasonable person would conclude within a few minutes that (recorded
conversation) landlord’s remarks were racist and degrading to the Bangladeshi, Indian, and
Pakistani communities.
 January 4, 2016: Landlord’s manager harassed plaintif.In the audio reding,
manager was berating, tauting, and harassing plaintif by saying that Bangladeshi,
Indian, and Pakistani people brought bedbugs in this country. The recorded
conversation was about 15 minutes and 48 seconds.
 January 3, 2017: Plaintiff lodged a formal complaint to the NYC Commission of
Human Rights.
 March 12, 2019: Katherine Carroll issued Probable Cause Letter.
 August 29, 2019: Katherine Carroll tried to cover up her probable cause letter by
saying, “… As for your case when we met I expressed that we were trying to settle
the case and we were going to issue probable cause but that it would be waiting
for a new attorney to be assigned for that process, I’m sorry to say that a new
attorney has not yet been assigned. We should have it assigned in the next month
with more progress being made from there.”
 August 30, 2019: Plaintiff informed Katherine Carroll that a probable cause letter
was already issued by her and showed her the letter.
 December 5, 2019: plaintiff filed an official complaint email to the commissioner
and deputy commissioner about Katherine Carroll. Excerpt of the email, “I’m
submitting formal complaint against your staff members (especially about Ms.
Katherine Caroll) who are delaying, stonewalling, and harming my harassment
complaint – MHN-17-1035824. She does not respond after countless email, voice
message, and office visit. And whenever I call direct agency phone number, I got

usual responses, such as, she was in a meeting…” Plaintiff never received any
responses from the commissioners and deputy commissioner.
 May 15, 2020: NYC CCHR forced the plaintiff to attend a settlement conference
via zoom meeting even though the plaintiff repeatedly declined to accept any
settlement offer. Katherine Caroll showed up and told the judge that NYC
Commission of Human Rights has a settlement offer ($5000) and it would not go
to the trial.
 October 8, 2020: Johanna C. Segal issued a closure letter

17. NYC CCHR’s employees went on vengeance rampant against Sultan Maruf due to his
complaint against employees.
18. Commissioner and Deputy commissioner never answered or responded to the plaintiff’s
complaints about their employees.
19. Commissioner and deputy commissioner’s inaction emboldened employees to take
retaliatory actions.
20. While tormenting the plaintiff for about 3 years and 10 months, employees assessed a $5,000
settlement from the landlord as reasonable while the plaintiff always wanted a court issue justice
that would restore the reputation and dignity of his communities, race, and nationality and never
accepted any amount of money. NYC CCHR engaged in professional misconduct through
harassment and coercion, such as, not replying to emails, stonewalling process, not replying to
phone calls, and constantly coercing to accept the $5000 settlement.
21. Pre-trial settlement conference was held on May 15, 2020. However, Katherine Carroll
showed up settlement conference and took over the proceeding, and stated that the commission
may not take it to the court. It was beyond the conflict of interest when her actions were
vengeful since she was mentioned in the plaintiff’s complaint letter to the commission. The case
was already handled by another employee (Johanna C. Segal) and her supervisor, but Catherine
Caroll interfered in the settlement conference and determined the decision of the commission.
Furthermore, the determination letter falsely claimed,
“The Law Enforcement Bureau is closing your case for administrative cause. The Law
Enforcement Bureau in its discretion may close cases for “administrative cause” when it
declines to complete its investigation for reasons described in the City Human Rights Law at § 8-
113(a) of the Administrative Code of the City of New York.”
Fact was, they already completed the investigation and issued the probable cause letter (see
Probable Cause Letter). Probable cause letters are issued when they complete the investigation
and are in the process of taking the case to trial. Furthermore, every human being will conclude
after listening plaintiff’s recorded conversation with the landlord that it was discriminatory.
After issuing the ‘Probable Cause’ letter, NYC CCHR employees covered up the probable cause
letter and again engaged in stonewalling the case by transferring the case to another person. (see
email conversation evidence)

Another fabricated claim,
“WHAT DOES THIS MEAN? The closure of a case for administrative cause means that the Law
Enforcement Bureau has not made a determination one way or the other as to the merits of the
complaint. This also means you can now file the same claim in court or in another forum.”
They already made the determination about the facts after completing the investigation and the
finding was meritorious. (see attached probable cause letter.)
Also, the landlord sent a sworn statement that the incident never happened. But the audio
recording clearly proved the facts. So, it was another covered-up and misleading by NYC CCHR
employees that it was not meritorious.
NYC CCHR dismissed my complaint based on the following reasons. However, they abused
their discretion power since they engaged in retaliatory actions.
§ 8-113. Dismissal of complaint.
a. The commission may, in its discretion, dismiss a complaint for administrative
convenience at any time prior to the taking of testimony at a hearing. Administrative
convenience shall include, but not be limited to, the following circumstances:
1. Commission personnel have been unable to locate the complainant after diligent
efforts to do so;
2. The complainant has repeatedly failed to appear at mutually agreed upon
appointments with commission personnel or is unwilling to meet with commission
personnel, provide requested documentation, or to attend a hearing;
3. The complainant has repeatedly engaged in conduct which is disruptive to the
orderly functioning of the commission;
4. The complainant is unwilling to accept a reasonable proposed conciliation
5. Prosecution of the complaint will not serve the public interest; and
6. The complainant requests such dismissal, 180 days have elapsed since the filing
of the complaint with the commission and the commission finds (a) that the complaint has
not been actively investigated, and (b) that the respondent will not be unduly prejudiced

NYC CCHR employees violated the following New York City Charter and also violated New
York State laws:
§ 389. Internal controls, rule-making, contracting.

a. In accordance with the policies and procedures established by the mayor for this purpose,
heads of mayoral agencies shall maintain an internal control environment and system which is
intended to maximize the effectiveness and integrity of agency operations and to reduce the
vulnerability of the agency to fraud, waste, abuse, error, conflict of interest, and corruption.
b. Except as otherwise provided by law and in accordance with the provisions of the charter and
other law, heads of mayoral agencies shall have the power to adopt rules to carry out the powers
and duties delegated to the agency head or the agency by or pursuant to federal, state or local
c. Heads of mayoral agencies may, subject to the requirements of the charter, other law, and rules
promulgated pursuant to them, and within appropriations therefore, enter into contracts and make
purchases to fulfill the duties assigned to them.
§ 1116. Fraud; neglect of duty; willful violation of law relative to office.
a. Any council member or other officer or employee of the city who shall wilfully violate or
evade any provision of law relating to such officer’s office or employment, or commit any fraud
upon the city, or convert any of the public property to such officer’s own use, or knowingly
permit any other person so to convert it or by gross or culpable neglect of duty allow the same to
be lost to the city, shall be deemed guilty of a misdemeanor and in addition to the penalties
imposed by law and on conviction shall forfeit such office or employment, and be excluded
forever after from receiving or holding any office or employment under the city government.
b. Any officer or employee of the city or of any city agency who shall knowingly make a false or
deceptive report or statement in the course of duty shall be guilty of a misdemeanor and, upon
conviction, forfeit such office or employment.
§ 1128. Interference with investigation.
a. No person shall prevent, seek to prevent, interfere with, obstruct, or otherwise hinder any
study or investigation being conducted pursuant to the charter. Any violation of this section shall
constitute cause for suspension or removal from office or employment.
New York State Human Rights Law
§ 296. Unlawful discriminatory practices. Retaliations: 7. It shall be an unlawful
discriminatory practice for any person engaged in any activity to which this section applies to
retaliate or discriminate against any person because he or she has opposed any practices
forbidden under this article or because he or she has filed a complaint, testified or assisted in any
proceeding under this article.

16. As a result, Defendants vengefully retaliated against Plaintiff for years, causing him physical
pain and mental suffering. At no time did the Defendants have legal rights to take retaliatory
actions against the Plaintiffs, and nor did the Plaintiff consent to withdraw the case.
25. the Defendant City of New York is a municipality duly incorporated under the laws of
the State of New York.
28. The direct and proximate results of the Defendants’ acts are that Plaintiffs have suffered, and
continue to suffer, severe and permanent injuries of a physical and psychological nature. He was
forced to endure pain and suffering for countless months, all to his detriment. His psychological
treatment hospital records will prove his claim.
29. Plaintiffs repeat each and every allegation in this Complaint as though fully set
forth at length herein.
30. Defendant city of New York has grossly failed to train and adequately supervise its
employees in the fundamental law of defending residents of New York City residents without
prejudice. Instead, the plaintiff faced retaliation for reporting misconduct, corruption, conflicts of
interest, gross mismanagement and abuse of authority.

WHEREFORE, Plaintiff demands judgment against the Defendants, together with the medical
costs and disbursements of this action and costs of bringing this case and punitive damages.
Plaintiff hereby demands a jury trial on all triable issues.

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