WADIS 1.41 09 SIV MULULIIOCIIL Vo PUY Veiuriocwt □□□ ee Prrann TUNA i 8 bie “iy a &_ 7 Vika Liviu wl Le 6 |)" , a □ Ue □□□ UNITED STATES DISTRICT COURT yw on! lod a SOUTHERN DISTRICT OF NEW YORK Tw 4 DP A fet ener a ‘ I People of the State of New York, et. al., Case No. 21-cv-322 (CM)(GWG) p* □□ vs Plaintiff, _ ion for reconsideration to Seay innterveni ; against == USPCSDNY Nm DOCUMENT V / The City of New York, etal., || ELECTRONICALLY FILED Wy yk DOC #: fe A □ | Defendan i Vy DATE FILED:_21 V0 J □□□ PLEASE TAKE NOTICE that pursuant to Federal Rule of Civil Procedure (“FRCP”) Rule 60, □□ a) Whalen v. County of Fulton, 126 F.3d 400 (2d Cir. 1997), b) Roman Catholic Diocese of Brooklyn v. Cuomo, 592 §. Ct. (U.S. 2020), ¢) Calvary Chapel Dayton Valley v. Sisolak, 140 S. le Ct. 2603 (U.S. 2020), d) In re Kaiser, 722 F.2d 1574 (2d Cir. 1983), e) In re Fitch, Inc., 330 F.3d □ 104 (2d Cir. 2003), and other applicable law, I, Towaki Komatsu, am submitting this motion to □□ be granted the following immediate relief in this case: cet □ An order that grants me reconsideration of the order that U.S. District “Judge” fy Colleen McMahon issued on 4/28/21 in this case in which she denied me the od opportunity to intervene in this case or otherwise appear as an intcrested party as she fr J impermissibly relied on a) baseless and erroneous assumptions and irrelevant points □□ instead of b) strictly pertinent matters of fact and law to reach that determination. □□ 2. An order that immediately authorizes me to intervene in this case or otherwise appear h as an interested party. C \ □□□ / a An order that explicitly states that the only matters that will be dealt with and yy v otherwise considered by this Court in this consolidated case will be those that □ Case 1i21-Cv-UUs22-CM Document □□□ Filed O3/U4iz1l Page < occurred during the demonstrations that occurred during the Summer of 2020 in New York City that were specifically part of demonstrations and protests that took place then against the NYPD, other law-enforcement entities, and other government entities and personnel about matters that were closely-related to that as this means that this Court will not deal with matters that took place outside of that specific time period and/or were about other matters to apply comparable narrow-mindedness that this Court has applied to my application to intervene in this case to its parties, their counsel, and other intervenors and interested parties in this case in accordance with my First Amendment and Fourteenth Amendment rights. This motion to intervene is supported by the following: 1. The attached memorandum of law dated May 4, 2021. 2. My 3/31/21 submission in this case. 3. My 2/4/21 motion to intervene that I eibmitied in this case. 4. The letters motions dated 1/29/21 and 1/30/21 that I submitted via e-mail for acceptance and diligent review in this case by “Judge” McMahon to the Pro Se Intake Unit on 1/29/21 at 9:47 am and 1/30/21 at 6:37 pm in accordance with applicable rules for such e-mail submissions by pro se litigants. From, ‘Date: May 4, 2021 Towaki Komatsu /Towaki Komatsu 802 Fairmount Pl., Apt. 4B Bronx, NY 10460 Tel: 347-316-6180 E-mail: Towaki Komatsu@yahoo.com ii