NYC EMERGENCY MANAGEMENT ISSUES TRAVEL ADVISORY FOR SATURDAY AND SUNDAY

Winter Weather Advisory in effect from 6 a.m. Saturday through 6 a.m. Sunday

Alternate Side Parking Regulations suspended Saturday to facilitate snow removal; parking meters remain in effect citywide

  The New York City Emergency Management Department today issued a travel advisory for Saturday and Sunday. The National Weather Service has issued a Winter Weather Advisory for New York City from 6 a.m. Saturday through 6 a.m. Sunday. A total of 2 to 4 inches of snow is forecast, with locally higher amounts possible. The heaviest snow is expected to fall Saturday morning through Saturday evening. A Winter Weather Advisory for snow means periods of snow will cause travel difficulties. New Yorkers should prepare for snow covered roads and limited visibilities, and are advised to exercise caution when driving, walking, or biking. Alternate Side Parking regulations are suspended Saturday to facilitate snow removal. Payment at parking meters will remain in effect throughout the city.

“Winter has come early and we don’t want anyone to be caught off guard by this weekend’s forecast,” said NYC Emergency Management Commissioner Joseph Esposito. “It’s time to unpack your winter gear; have your boots, hats, and scarves ready. Give yourself extra time to travel as conditions could be difficult.”

NYC Emergency Management also advised New Yorkers to prepare for cold temperatures this weekend. Temperatures are forecast to hover around freezing on Saturday. High temperatures Sunday are forecast in the upper 30s, but return below freezing Sunday night, with lows in the upper 20s. Cold weather can cause or worsen health problems. Certain individuals, including the unsheltered homeless, people with disabilities and those with access and functional needs are at an increased risk for injuries, illness or death. Others at an increased risk also include people who drink heavily or use drugs and become incapacitated outdoors, or those who live in homes without heat, and:

·         Are 65 years of age or older.

·         Are infants.

·         Have certain medical conditions such as heart or lung disease, high blood pressure, diabetes.

·         Have serious mental health conditions or developmental disabilities.

·         Have disabilities or access and functional needs (e.g. limited mobility, trouble leaving home).

New Yorkers are also encouraged to check on neighbors, friends, and relatives. Please take the following precautions:

Safety Tips

For Motorists

• Make sure to have a mechanic check the following items: battery, antifreeze, windshield wipers and washer fluid, ignition system, thermostat, lights (headlamps and hazard lights), exhaust system, heater, brakes, defroster, and oil level (if necessary, replace oil with a winter oil or SAE 10w/30 variety).

·         Drive slowly. Vehicles take longer to stop on snow and ice than on dry pavement.

·         Four-wheel drive vehicles may make it easier to drive on snow-covered roads, but they do not stop quicker than other vehicles.

·         Use major streets or highways for travel whenever possible.

·         Know your vehicle’s braking system. Vehicles with anti-lock brakes require a different braking technique than vehicles without anti-lock brakes in snowy conditions.

·         If you are driving and begin to skid, ease your foot off the gas and steer in the direction you want the front of the car to go. Straighten the wheel when the car moves in the desired direction. If you have an anti-lock braking system (ABS), apply steady pressure to the brake pedal. Never pump the brakes on an ABS equipped vehicle.

·         Try to keep your vehicle’s gas tank as full as possible.

·         Keep the name and phone number of at least one local towing service in your car in case you break down or become stuck.

For Pedestrians

·         Exercise caution and avoid slippery surfaces; some ice may not be visible. Wear sturdy boots that provide traction to reduce slipping. Use handrails when using stairs.

·         Seniors should take extra care outdoors to avoid slips and falls.

·         Have heightened awareness of cars, particularly when approaching or crossing intersections.

·         If you have to go outdoors, wear dry, warm clothing and cover exposed skin. Keep fingertips, earlobes, and noses covered. Wear a hat, hood, scarf, and gloves.

·         Shivering is an important first sign that the body is losing heat. Shivering is a signal to return indoors.

·         Be careful when shoveling snow. Follow your doctor’s advice if you have heart disease or high blood pressure. Cold weather puts an extra strain on the heart.

·         Be safe at work. Workers who spend a lot of time outdoors are at risk for cold-related health impacts. If you are an employer, implement safe work practices, provide appropriate protective equipment, and train workers on how to stay safe during cold and winter weather.

·         Limit alcohol intake. Drinking alcohol may make you feel warmer but it causes your body to lose heat faster. Alcohol also impairs your judgment which limits your ability to take appropriate precautions or remove yourself from a dangerously cold environment in time. As a result, alcohol actually increases your chances of hypothermia and frostbite.

Prolonged exposure to cold can lead to hypothermia, frostbite, and can worsen existing medical conditions such as heart and lung diseases.

Hypothermia occurs when the body temperature drops to a dangerously low level. It can lead to death. Symptoms include:

·         Intense shivering

·         Dizziness

·         Trouble speaking

·         Lack of coordination

·         Sluggishness

·         Drowsiness

·         Confusion

·         Shallow breathing

                                   

Frostbite occurs when parts of the body freeze, such as finger, toes, ears, nose, and cheeks. It can cause permanent damage. Symptoms include:

·         Red or painful skin

·         Pale skin

·         Unusually firm or waxy skin

·         Numbness

Call 911 and follow instructions, or go to the emergency room if you see symptoms of hypothermia or frostbite.

Homeless Services

A Code Blue Weather Emergency notice is issued when the temperature is forecast to drop to 32 degrees Fahrenheit or less between 4 p.m. and 8 a.m., including National Weather Service calculations for wind chill values.  No one who is homeless and seeking shelter in New York City during a Code Blue will be denied. Should you see an individual who appears to be homeless and in need out in the cold, please call 311 and an outreach team will be dispatched to offer assistance. During Code Blue Weather emergencies, experienced outreach teams work to connect homeless New Yorkers with the following resources:

·         Shelters: During a Code Blue, shelter is available system-wide to accommodate anyone who is reasonably believed to be homeless and is brought to a shelter by outreach teams. Accommodations are also available for walk-ins.

·         Drop-in centers: All drop-in centers are open 24-hours per day, including when Code Blue procedures are in effect, and will assist as many people as possible for the duration of the emergency. Drop-in staff and the dedicated outreach teams they work closely with each and every day can also make arrangements for homeless individuals at other citywide facilities.

·         Safe havens and stabilization beds: Chronically homeless individuals may be transported directly to these low-threshold housing programs.

·         Street homeless outreach: Teams will contact vulnerable individuals on their Code Blue Priority Lists a minimum of once every four (4) hours beginning at 8 p.m. during Code Blue Alerts and once every two (2) hours beginning at 8 p.m. for Enhanced Code Blue Alerts to encourage them to accept services, including transportation to a shelter placement. DHS coordinates borough-level Code Blue efforts directly with partner City agencies, including but not limited to NYPD, DSNY, and the Parks Department.

Safe Home Heating Tips

Improper use of portable heating equipment can lead to fire or dangerous levels of carbon monoxide. Take precautions to ensure you are heating your home safely.

Fire safety tips:

·         Make sure you have a working smoke alarm in every room. Test them at least once a month and change the batteries twice a year.

·         Use only portable heating equipment that is approved for indoor use. Space heaters are temporary heating devices and should only be used for a limited time each day.

·         Keep combustible materials, including furniture, drapes, and carpeting at least three feet away from the heat source. Never drape clothes over a space heater to dry them.

·         Never leave running space heaters unattended, especially around children. Always keep an eye on heating equipment. Turn it off when you are unable to closely monitor it.

·         Plug space heaters directly into a wall outlet. Never use an extension cord or power strip. Do not plug anything else into the same outlet when the space heater is in use. Do not use space heaters with frayed or damaged cords.

·         If you are going to use an electric blanket, only use one that is less than 10 years old from the date of purchase. Also avoid tucking the electric blanket in at the sides of the bed. Only purchase blankets with an automatic safety shut-off.

Prevent carbon monoxide poisoning:

·         Carbon monoxide comes from the burning of fuel. Therefore, make sure all fuel-burning devices such as furnaces, boilers, hot water heaters, and clothes dryers are properly vented to the outdoors and operating properly. If you are not sure, contact a professional to inspect and make necessary repairs.

·         Make sure you have a working carbon monoxide detector. Most homes and residential buildings in New York City are required by law to have carbon monoxide detectors installed near all sleeping areas. Owners are responsible for installing approved carbon monoxide detectors. Occupants are responsible for keeping and maintaining the carbon monoxide detectors in good repair.

·         If you have a working fireplace keep chimneys clean and clear of debris.

·         Never heat your home with a gas stove or oven, charcoal barbecue grill, kerosene, propane, or oil-burning heaters. Kerosene heaters and propane space heaters are illegal in New York City.

·         The symptoms of carbon monoxide poisoning are non-specific and include headache, nausea, vomiting, dizziness, sleepiness, trouble breathing, and loss of consciousness. Severe poisonings may result in permanent injury or death.

If a carbon monoxide detector goes off in your home get outside immediately and call 911. If you suspect carbon monoxide poisoning, get outside immediately and call 911. For more fire safety information, visit FDNYsmart.org.

What to Do if You Lose Heat or Hot Water at Home

Building owners are legally required to provide heat and hot water to their tenants. Hot water must be provided 365 days per year at a constant minimum temperature of 120 degrees Fahrenheit. Heat must be provided during the “Heat Season”, between October 1 and May 31 under the following conditions:

·         Between the hours of 6 a.m. and 10 p.m., if the outside temperature falls below 55 degrees, the inside temperature is required to be at least 68 degrees Fahrenheit.

·         Between the hours of 10 p.m. and 6 a.m., if the outside temperature falls below 40 degrees, the inside temperature is required to be at least 55 degrees Fahrenheit.

Any New York City tenant without adequate heat or hot water should first speak with the building owner, manager, or superintendent. If the problem is not corrected, tenants should call 311. For the hearing impaired, the TTY number is (212) 504-4115. The center is open 24-hours a day, seven-days a week. You may also file a complaint via mobile app, 311MOBILE, or online at 311ONLINE.

The Department of Housing Preservation and Development (HPD) will take measures to ensure that the building owner is complying with the law. This may include contacting the building’s owner and/or sending an inspector to verify the complaint and issue a violation directing the owner to restore heat and hot water if appropriate. If the owner fails to comply and does not restore service, HPD may initiate repairs through its Emergency Repair Program and bill the landlord for the cost of the work. HPD may also initiate legal action against properties that are issued heat violations, and owners who incur multiple heat violations are subject to litigation seeking maximum litigation penalties and continued scrutiny on heat and other code deficiencies.

Take measures to trap existing warm air and safely stay warm until heat returns, including:

Insulate your home as much as possible. Hang blankets over windows and doorways and stay in a well-insulated room while the heat is out.

Dress warmly. Wear hats, scarves, gloves, and layered clothing.

If you have a well-maintained working fireplace and use it for heat and light, be sure to keep the damper open for ventilation. Never use a fireplace without a screen.

If the cold persists and your heat is not restored call family, neighbors, or friends to see if you can stay with them.

Do not use your oven or fuel-burning space heaters to heat your home. These can release carbon monoxide, a deadly gas that you cannot see or smell.

Open your faucets to a steady drip so pipes do not freeze.

If You Need Emergency Heating Assistance

The Human Resources Administration (HRA) administers the federal Home Energy Assistance Program (HEAP), which can help low-income renters and homeowners with heating bills and other energy expenses. For information on HEAP, click here. HEAP can help with:

·         Regular heating bills from a variety of heat sources (even if heat is included in your rent or you live in subsidized housing).

·         Emergency payments to keep you from losing your heat.

·         Replacing damaged furnaces, boilers and heating units.

For more information, visit nyc.gov/emergencymanagement. New Yorkers are encouraged to sign up for Notify NYC, the City’s free emergency communications program. To sign up for Notify NYC, download the free mobile application, visit NYC.gov/NotifyNYC, call 311, or follow @NotifyNYC on Twitter.

What You Should Know By State Senator Rev. Rubén Díaz

Oscar Rivera Lopez & Mark Gjonaj’s Assembly District 

You should know that since Assemblyman Mark Gjonaj, has been elected to the seat previously occupied by Council Member Jimmy Vacca, has created a vacancy and there is already a brawl brewing about who will occupy his vacant seat in the New York State Assembly. 

It is important for you to know that Mr. Mark Gjonaj has been representing the 80^th Assembly District, which encompasses Allerton, Bedford Park, Morris Park, Mosholu Parkway, Norwood, Pelham Gardens and Van Nest areas in the Bronx. 

These are multi-cultural neighborhoods.  Its residents are honest, responsible and hard working African Americans, Hispanics, Whites, Albanians, Bangladeshi, as well as others who love this country.  I know this because I formerly represented them as their New York State Senator.  I’m very familiar with these neighborhoods and its residents. 

You should know that when Mark Gjonaj leaves for the City Council, a special election will be held to fill the vacancy.   Rumor has it that there are two women interested in filling the position in the Assembly.   

 One of them is Nathalia Fernandez.   Ms. Fernandez is well known in the district and in the Assembly because she has worked as Mark Gjonaj’s Chief of Staff.  Ms. Fernandez is well qualified educated, experienced, and well versed in the needs, problems, and the expectations of the residents of the district.   As a result some say that Ms. Fernandez is the right person to replace Mark Gjonaj in the Assembly due to her vast knowledge and experience within the district.   

But surprise, surprise, the other woman who is interested in the position is none other than Lorraine Cortez Vazquez, presently the President of the National Puerto Rican Parade, who just this year she brought shame and disgrace to the parade when she made the controversial decision to honor Mr. Oscar Lopez Rivera, as a “Hero of Liberty”, “Heroe De La Libertad” which resulted in disunity within the Puerto Rican Community.     

You should know that Oscar Lopez Rivera, according to Wikipedia is known to many as a “terrorist”.   He is one of the leaders of the clandestine paramilitary organization “The Fuerzas Armadas De Liberacion Nacional Puertorriquena” known as the terrorist group the “F.A.L.N.”.    This organization is devoted to the independence of Puerto Rico and they carried out more than 120 bomb attacks on the United States between 1974 and 1983 which resulted in the killing of six (6) people.   

On August 11, 1981 Mr. Lopez was found guilty of  “Seditious Conspiracy”, use of force to commit robbery,interstate transportation of firearms and ammunitions to aid in the commission of a felony.    He is released from prison and Ms. Lorraine Cortez Vazquez  hails him as a Hero of Liberty.   

Her association and close friendship with Oscar Lopez Rivera will not sit well with the district she hopes to represent.  Already many are commenting on their apprehension of having Lorraine Cortez-Vazquez as the person to fill Mark Gjonaj’s vacant seat.  Others are saying that the honest, hardworking residents of the 80^th Assembly district will not cast a vote for Ms. Vazquez.   

As you can see my dear readers, two well prepared, well educated women will be competing to fill the vacancy for the 80^th Assembly district.  This will be a very interesting and very divided contest, as was this years the National Puerto Rican Day Parade….. thanks to Oscar Lopez Rivera, and the actions taken by Ms. Lorraine Cortez Vazquez.   

This is Senator Ruben Diaz and this what you should know.

EDITOR'S NOTE:

 Is this another ploy by Assemblyman Luis Sepulveda in his quest to become the new "REVEREND SENATOR LUIS SEPULVEDA" by chasing away another formidable contender for the soon to be vacant 32nd State Senate seat? Why is it that current Councilwoman Anabelle Palma who was to have switched seats with State Senator Ruben Diaz Sr. (since she was term limited out at the end of this year) was taken out of the running when Assemblyman Luis Sepulveda announced his intention to run for the 32nd State Senate seat?

 Now, why is it that Assemblyman Sepulveda wants another woman who would be as good if not better a candidate than Ms. Palma out of the way? What is the connection between Anabelle Palma, Lorraine Cortez-Vazquez, and Assemblyman Luis Sepulveda? The answer is Mayor Bill de Blasio. Mayor de Blasio has hired Ms. Palma to be Assistant Commissioner of the DHS, while Ms. Cortez-Vazquez currently works for Mayor Bill de Blasio. 

 Are Luis Sepulveda and Mayor Bill de Blasio playing Bronx politics? That should be left up to the Bronx Democratic County Leader Assemblyman Marcos Crespo, or do Mayor de Blasio and soon to be State Senator Sepulveda have other plans for Assemblyman Crespo?

Chanukah Celebration with the Bronx Borough President

NEWS FROM KRVC

Join Us this Saturday in Marble Hill 
for the Holiday Trolley of Fun!

krvcdc.org/news

krvcdc.org/events

Office of Alcoholism and Substance Abuse Services - Young Adult Recovery Forum in the Bronx, 12/14

  Under Governor Andrew M. Cuomo’s leadership, New York State is taking bold and aggressive action to tackle the heroin and opioid crisis, and develop initiatives that promote the enhancement of the state’s nation-leading prevention, treatment, and recovery services model.

Please join Commissioner Arlene González-Sánchez of the New York State Office of Alcoholism and Substance Abuse Services (OASAS) for a breakfast roundtable discussion on treatment and recovery supports for young adults and at-risk youth.

 Date: Thursday, December 14, 2017

 Time:              11:30 a.m. – 1:00 p.m.

 Location:       Odyssey House Recovery Center

Davidson Community Center

2038 Davidson Avenue

Bronx, New York

The Commissioner will discuss the state’s efforts support treatment and recovery supports for young adults and at-risk youth in New York State.   She will also look for input on the development of a statewide recovery network for young adults. This event is an opportunity to share your recommendations with representatives from New York State and community stakeholders.  

 R.S.V.P. to Tracey Collins at Tracey.Collins@oasas.ny. gov

MEETING BETWEEN MAYOR DE BLASIO AND NEW JERSEY GOVERNOR-ELECT MURPHY

  New York City Mayor Bill de Blasio and New Jersey Governor-elect Phil Murphy met this afternoon at Gracie Mansion in New York City. The Mayor and Governor-elect offered each other congratulations on their respective November election victories, before discussing a host of issues important to New York and New Jersey. The Mayor and Governor-elect outlined a shared vision for the region that includes an expansion of universal pre-K, upgraded transportation and infrastructure, and a focus on mental health investment and progressive taxation. The two pledged immediate cooperation in combating the Republican tax plan and in supporting grassroots progressive organizing locally and nationally. The meeting lasted 65 minutes. A portion of the meeting was attended by New York City First Lady Chirlane McCray.

EDITOR'S NOTE:

Could it be that Mayor Bill de Blasio is thinking of moving to New Jersey?

Two Men Charged In Theft Of Over $2 Million In Stock Certificates From Deceased Manhattan Woman

  Joon H. Kim, the Acting United States Attorney for the Southern District of New York, and William F. Sweeney Jr., Assistant Director-in-Charge of the New York Field Office of the Federal Bureau of Investigation (“FBI”), announced today the unsealing of an Indictment charging STEPHEN DECKER and LUIS MERCADO with conspiracy to commit wire fraud, wire fraud, and aggravated identity theft in connection with a scheme to steal more than $2 million in stock certificates from the apartment of a deceased Manhattan woman, and then use those stolen assets to attempt to purchase over $2 million worth of gold coins.  DECKER and MERCADO were arrested this morning in Manhattan.  The defendants will be presented before U.S. Magistrate Judge James L. Cott in Manhattan federal court this afternoon.  The case has been assigned to U.S. District Judge Lewis A. Kaplan.   

Acting Manhattan U.S. Attorney Joon H. Kim said:  “As alleged, these defendants preyed on a deceased New Yorker’s estate by stealing millions in stock certificates from her home.  Then, in an attempt to cover their tracks, the defendants allegedly sold the certificates and tried to purchase more than $2 million in gold coins so that the ill-gotten gains couldn’t be traced to them.  Thanks to the outstanding investigative work of the FBI, the defendants will now be held accountable for their brazen actions.”

FBI Assistant Director William F. Sweeney Jr. said:  “As alleged, when Decker and Mercado cashed out on stolen stock certificates, their right to ownership was nothing more than fool’s gold.  Not only did the certificates not belong to them, their rightful owner was an elderly deceased woman with no representatives to stake her claim.  Taking advantage of those who are powerless to defend themselves or their legacy has always been, and will always be, an inexcusable crime.”

According to the Indictment[1] unsealed today in federal court:

From March 2016 to February 2017, DECKER and MERCADO engaged in a scheme designed to steal over $2 million from a deceased Manhattan woman (the “Victim”).  As part of the scheme, DECKER and MERCADO stole stock certificates valued at over $2 million from the Victim’s Manhattan apartment after the Victim’s death in March 2016.  In August 2016, based on false representations made by DECKER and MERCADO, a financial institution (“Company-1”) opened a brokerage account (the “Account”) in the Victim’s name.  DECKER and MERCADO then deposited the stolen stock certificates into the Account.  In September 2016, based on additional false representations made by DECKER and MERCADO, Company-1 sold the shares in the brokerage account opened in the Victim’s name, resulting in a cash balance in the Account of more than $2 million.  DECKER and MERCADO then attempted to purchase over $2 million in gold coins using the assets in the Account.            

The Indictment charges DECKER, 59, of Secaucus, New Jersey, and MERCADO, 53, of Manhattan, New York, each with one count of conspiracy to commit wire fraud and one count of wire fraud, each of which carries a maximum sentence of 20 years in prison; and one count of aggravated identity theft, which carries a mandatory sentence of two years in prison.  The maximum potential sentences in this case are prescribed by Congress and are provided here for informational purposes only, as any sentencing of the defendants will be determined by the judge.

Mr. Kim praised the outstanding investigative work of the FBI.

The charges contained in the Indictment are merely accusations, and the defendants are presumed innocent unless and until proven guilty.

 

[1] As the introductory phrase signifies, the entirety of the text of the Indictment and the description of the Indictment set forth below constitute only allegations and every fact described should be treated as an allegation.

Five Defendants Arrested In Bottle-Return Bust

Group Allegedly Used False Invoices and Kickbacks to Transform 5¢ Recycling Deposit Into Lucrative Fraud

  Joon H. Kim, the Acting United States Attorney for the Southern District of New York,  William F. Sweeney Jr., Assistant Director-in-Charge of the New York Field Office of the Federal Bureau of Investigation (“FBI”), Leon Hayward, Acting Director of the New York Field Office of U.S. Customs and Border Protection (“CBP”), and James P. O’Neill, the Commissioner of the New York City Police Department (“NYPD”), announced that ELDAR RAKHAMIMOV, NASIM RAKHAMIMOV, VLADIMIR ZABRODIN, RUSLAN KADIROV, and JOSEPH FINNERAN were taken into federal custody today for participating in a scheme to defraud beverage bottling companies and the State of New York.  The defendants were presented this afternoon before U.S. Magistrate Judge James L. Cott.

According to the allegations in the Complaint filed today in Manhattan federal court:[1]

From September 2016 to December 4, 2017, ELDAR RAKHAMIMOV, NASIM RAKHAMIMOV, ZABRODIN, KADIROV, and FINNERAN conspired to defraud bottling companies and the State of New York through a scheme involving recyclable containers.

The defendants’ scheme exploited recycling incentives created by New York State’s Returnable Container Act (the “RCA”).  The RCA created a $.05 deposit on bottled soft drinks, beer, and water sold in New York State to promote the recycling of bottles and cans by bottlers, beverage distributors, and container redemption centers.  Under the RCA, the first bottler, distributor, or dealer to collect the required deposits on beverage containers is required to reimburse the $.05 deposit to redeeming individuals or entities and to pay a handling fee of $.035 per empty beverage container redeemed by redemption centers.

ELDAR RAKHAMIMOV and NASIM RAKHAMIMOV managed a bottle collection company (“Company-1”) that focused on aggregating recyclable containers and delivering them, in exchange for payment, to redemption centers in the New York City area.  ELDAR RAKHAMIMOV and NASIM RAKHAMIMOV, along with ZABRODIN, KADIROV, and FINNERAN, worked together to falsely inflate the number of bottles delivered by Company-1 to induce redemption centers to overpay bottle deposits and handling fees to Company-1.

Using an assortment of deceptive techniques, ranging from doctored invoices to “redeeming” the same bottles twice to impermissibly collecting bottles from New Jersey to paying (or receiving) kickbacks, the defendants extracted hundreds of thousands of dollars from victim companies – and, ultimately, the State of New York.

ELDAR RAKHAMIMOV, 46, of Brooklyn, New York, NASIM RAKHAMIMOV, 46, of Brooklyn, New York, ZABRODIN, 32, of Staten Island, New York, KADIROV, 32, of Brooklyn, New York, and FINNERAN, 64, of Bay Shore, New York, are each charged with one count of conspiring to commit mail and wire fraud, which carries a maximum penalty of 20 years in prison.  The maximum potential sentences in this case are prescribed by Congress and are provided here for informational purposes only, as any sentencings of the defendants will be determined by the judge.

Mr. Kim praised the outstanding work of the FBI, the CBP, and the NYPD for their investigative efforts and ongoing support and assistance with the case.

The charges contained in the Complaint are merely accusations, and the defendants are presumed innocent unless and until proven guilty.

 [1] As the introductory phrase signifies, the entirety of the text of the Complaint, and the description of the Complaint set forth herein, constitute only allegations, and every fact described should be treated as an allegation.