FAMILY COURT OF THE STATE OF NEW YORK
COUNTY OF WESTCHESTER
.......................................................
................
In the Matter of a Proceeding
Under Article six of the Family Court Act              
Docket No: X-820-99
                                        File #    53516
          
PHOTIUS COUTSOUKIS,                                    
     
          Petitioner,                   PETITIONER'S
AFFIDAVIT                                    IN SUPPORT
OF MOTION 
     - against -                        FOR THE
RETENTION      
                                   OR REINSTATEMENT
SUSAN SAMORA,                      OF COURT APPOINTED
          Respondent                    ATTORNEYS
_______________________________nycour40.doc       


I, PHOTIUS COUTSOUKIS, being first duly sworn, depose
and state:

1.   I am the Petitioner in this matter.

2.   Judges Braslow and Cooney of Westchester Family
Court were recused in an irregular manner, transferring
the case to Judge Sweeny of Putnam County, while
retaining Westchester County Jurisdiction, in an
apparent attempt to prejudice my case by, among other
effects, offering the two court appointed attorneys,
Mr. Marc Domicello, assigned counsel for Susan Samora,
the Respondent in this matter, and Ms. Robin Cotler,
Law Guardian, cover for past misdeeds and the
opportunity to go without exposing the judges.

3.   The irregularities involved in the transferring of
the case to the Putnam judge are described in Exhibit
1, my "Petitioner's Affidavit in Support of Motion to
Recuse the Judge", dated July 7, 1999.

4.   Mr. Domicello previously resigned when I uncovered
ex parte plotting between him and judge Braslow. This
time he is resigning via an affirmation which also
contains scurrilous and sham characterizations of me
and he should be present in court so that I can answer
them for the record. I cannot question Mr. Domicello,
but the Judge can, if he is present.

5.   It is also important that Mr. Domicello, who has
been a player in my forced separation from my daughter
Theodora and her subsequent destruction, to face up to
his responsibilities and to the part he played,
including false statements that he made "under the
penalties of perjury", in covering up his client's and
the judge's misdeeds.

6.   The Court must consider my and my daughter's
plight and not allow Mr. Domicello off the hook, just
because his Camp Rehoboth (gay beach) timeshare is up.

7.   Similarly, Ms. Cotler's excuse that it would be
inconvenient for her to schlep to Putnam should not be
considered, when I am being forced to do so to comply
with the plots hatched by two crooked White Plain
judges.

8.   Ms. Cotler resigned via an Affirmation, with a
zing, a vitriolic misstatement of facts and
characterizations of me. Letting her go, would allow
this vicious attempt to distort the facts and to damage
my case from behind a locked door, quintessentially
cowardly, to succeed, and that would be prejudicial to
me.

8.   Additional facts and arguments regarding these
resignations and how they came about are included in my
aforesaid Exhibit 1.

9.   Finally, these two lawyers must not be allowed to
quit, so as to prevent further exposure of serious
irregularities and judicial misconduct in the White
Plains court.


     

_____________________________
PHOTIUS COUTSOUKIS


               SUBSCRIBED AND SWORN TO before me
_______________, 1999



                                   
                         
____________________________________
                              NOTARY PUBLIC FOR NEW
YORK 
                              My commission expires:








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