Stocking v. Newmark Knight Frank Valuation & Advisory, LLC

Filing 138

ORDER with respect to 135 Motion re: 135 MOTION PLAINTIFFS MOTION TO ADMIT DOCUMENT 85 AS EVIDENCE re: 85 Declaration in Support of Motion. Newmark is directed to respond by December 13, 2024. SO ORDERED. (Signed by Judge Edgardo Ramos on 11/25/2024) (jjc)

Case 1:22-cv-07347-ER

Document 135

Filed 11/22/24

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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
--------------------------------------------------------- X
MARIA STOCKING,
22 CV 07347 (ER)
Plaintiff,
-against-

Newmark is directed to respond by December 13,
2024.

NEWMARK KNIGHT FRANK

SO ORDERED.

VALUATION & ADVISORY, LLC,
Defendants.

Edgardo Ramos, U.S.D.J.
Dated: November 25, 2024
New York, New York

PLAINTIFF’S MOTION TO ADMIT DOCUMENT 85 AS EVIDENCE
Plaintiff, Maria Stocking, appearing pro se, respectfully moves this Court to admit Document 85
into evidence to support her claims in this case. Document 85 comprises Plaintiff’s sworn
declaration detailing allegations of collusion, conspiracy, obstruction of justice, and quid pro quo
bribery by Defendant, alongside evidentiary exhibits. This document is directly relevant to the
issues at the core of this litigation and is essential for substantiating Plaintiff’s claims.
Background
Document 85, filed under the docket as Doc. 85, is a declaration by Plaintiff, signed under penalty
of perjury, outlining following allegations and accompanying evidence.

Case 1:22-cv-07347-ER

Document 135

Filed 11/22/24

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1. Allegations of collusion and conspiracy between Defendant and third parties to interfere with
the fair administration of justice.
2. Acts of obstruction of justice, including the destruction of relevant evidence and the disclosure
of confidential witness identities.
3. Evidence of quid pro quo bribery, demonstrating preferential treatment by Defendant to
certain third parties in exchange for actions intended to prejudice Plaintiff’s case.
4. Document 85 includes supporting evidentiary exhibits that corroborate these allegations,
While Document 85 was previously filed as part of Plaintiff’s submissions, Plaintiff asserts that it
has not been formally entered into evidence. Plaintiff seeks to ensure its admission into evidence
so that it is properly considered during these proceedings. The Court is respectfully directed to
review Document 85 as previously filed on the docket.
LEGAL BASIS
Relevance: Under Federal Rule of Evidence 401, evidence is admissible if it has any
tendency to make a fact of consequence more or less probable. Document 85 directly
supports Plaintiff’s claims by providing detailed allegations and supporting evidence of
Defendant’s misconduct.
Authentication: Document 85 is authenticated by Plaintiff’s signature and sworn declaration
under penalty of perjury, as well as by the attached supporting exhibits, in accordance with
Federal Rule of Evidence 901(a).

Case 1:22-cv-07347-ER

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Filed 11/22/24

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CONCLUSION
Document 85 is central to Plaintiff’s case, as it details key allegations of misconduct by Defendant
and provides supporting evidence necessary for the fair adjudication of this matter. Plaintiff
respectfully requests that the Court admit Document 85 into evidence.
Dated: November 22, 2024
/s/Maria Stocking
Miami, Florida

Maria Stocking
888 Biscayne Boulevard, 57 th Floor
Miami, Florida 33132
786-857-3681
[e-mail]
Plaintiff

Case 1:22-cv-07347-ER

Document 135

Filed 11/22/24

Page 4 of 4

AFFIDAVIT OF AUTHENTICATION BY PLAINTIFF
I, Maria Stocking under penalty of perjury, declare as follows:
1. I am the Plaintiff in the above-captioned matter.
2. I have personal knowledge of the facts set forth herein.
3. Referenced is Document 85, which contains my sworn declaration detailing allegations of
collusion, conspiracy, obstruction of justice, and quid pro quo bribery by Defendant,
along with supporting evidentiary exhibits.
4. Document 85 is relevant to this matter because it provides detailed information and
evidence substantiating Plaintiff’s claims, including communications, court records, and
other records that demonstrate Defendant’s misconduct.
5. To the best of my knowledge and belief, Document 85 is authentic and has not been
altered in any way.
I declare under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct.
Dated: November 22, 2024
Miami, Florida
/s/Maria Stocking
Maria Stocking