Document Sample
					                              STATE OF NEW HAMPSHIRE
BELKNAP COUNTY, SS.                                               SUPERIOR COURT

               SN SERVICING CORPORATION as agent for Ingomar, LP


 Jean Elizabeth Allan, aka Jean Elizabeth Allan Sovik, fka Jean Elizabeth Allan Vorisek
  Quinn, fka Jean E. Quinn, individually, and as Trustee of the Jean E.Vorisek Family

                           Affidavit attached to Amended Motion


   I, Jean Elizabeth Allan [Sovik] being duly sworn, states as follows:

   1. I Jean Elizabeth Allan [Sovik] have personal knowledge of the facts recited herein
and in the attached Amended Motion, and I am competent to testify thereto:
   2. I am the mother of two sons, Fritz Edward and Kurt William Vorisek, the mother-in-
law of Fritz’s wife Shawchyi, and the grandmother of their daughter Asha.
   3. I am the daughter of Agnes S. Allan [deceased] and executrix of her will and heir
to her estate, which is pending the final disposition of the cause of her death and
location of her remains.
   4. I, Jean E. Allan, am the Trustee of the Jean E. Vorisek Family Trust [Trust], which
is the title holder to property currently owned by the Trust located in Center Harbor,
New Hampshire. The Trust was formed in 1981 shortly after my divorce from Robert E.
Vorisek. The purpose of the Trust was for estate planning for my two sons and my
mother, Agnes S. Allan. When I moved to Durham, New Hampshire, the family home
on 7 Hoitt Drive, was owned by the Trust. This property was valued at $145,000 when it
was foreclosed upon on April 1, 1991. The proximate cause of the foreclosure can be
directly linked to the crimes against the Trust, its companies, and Jean E. Allan
   5. The Trust and Jean E. Allan also own the rights to all unlitigated assets that may
be realized from actions yet to be taken by it against those parties who are found to
have perpetrated crimes against it, its Trustee, its companies, and all its beneficiaries,
causing great damages and untold suffering.
   6. During the period in which they were ongoing businesses, the Trust was sole
owner of the stock of Business Assets Management, Inc and its subsidiary companies

Senter Cove Development Company, Inc., and INAMAN INC. , New Hampshire
   7. Business Assets Management, Inc., since its inception, was a Real Estate
brokerage and consulting firm. It held title to property located on High Street,
Portsmouth, New Hampshire. This property was valued at approximately $300,000 when
it was foreclosed upon in 1989. Other business properties, worth several hundred
thousand dollars, owned by Business Assets were also foreclosed upon during that time
period. Business Assets was eventually put out of business. The proximate cause of the
damages to Business Assets can be attributed to the crimes against the Trust, its
companies, and Jean E. Allan.
   8. INAMAN, INC. was a NASD DPP Broker Dealer. INAMAN, INC. was licensed to
sell real estate partnerships and mutual funds. INAMAN, INC. was put out of business
due to crimes against the Trust, its companies, and Jean E. Allan.
   9. Senter Cove Development Company, Inc.[Senter] owned two parcels of land
located in No. Woodstock, New Hampshire, on Route #3 that it had purchased in 1987.
In 1988 - which Senter found out about later in discovery during a civil law suit that it had
filed - a fraud had been committed upon it, by its engineers, among others. The fraud
ruined the planned real estate project that the property had been permitted to build. The
property had been financed by Richard A. Cabral and BankEast. In order to mitigate
damages to creditors, arrangements were made by Senter to make the creditors whole.
Those arrangement included expending $400,000 to correct the deed fraud, and to
enter into an agreement to sell the permitted development. All creditors entered into a
superseding agreement with Senter in 1991. The buyer defaulted. The liquidated
damages that the creditors agreed to accept, along with other collateral in pending law
suits, was also proven to be fraudulent. Several years later six of the fruadsters were
convicted by the organized crime task force prosecutors of the Eastern District of
Pennsylvania. I testified against the defendants at that trial, in the spring of 1997.
   In September 1993, springs were recognized by me to be located on Senter’s land. I
now know that others were aware of the springs several years before, due to their
access to a groundwater study report that had gone missing, and has never been seen
by me. Although I have a record that Senter paid for it in 1987.
   By 1994, in order to create a new business on its land, Senter performed the
necessary engineering and then filed for permits with the State of New Hampshire in
order to be able to commercially extract the spring water. The State of New Hampshire

granted permits to Senter to extract up to approximatele one million gallons per dat, of
extremely pure spring water. The market value of a gallon of water, at that time, was
approximately $.02/gallon. The reserve capacity of the aquifer recharge area has been
estimated at up to ten million gallons per day. By using the value gap method, a method
that is used in the market place in order to estimate oil reserves, the value of Senter’s
two parcels, to its owners, can be calculated in the many millions, if not billions of
   The easterly parcel where the main production, and several monitoring wells, were
located was sabotaged with a cocktail of chemicals to include heavy metals and other
carcinogens, on September 11, 1997. The westerly parcel’s one - very well hidden
monitoring well - was sabotaged several weeks later with other chemicals. The major
springs and aquifer recharge area, making it the most valuable of the two parcels, were
located on the westerly parcel. The State of New Hampshire decommissioned the main
production well in 1998, thus canceling the permits it had granted to Senter. The State
of New Hampshire did not do a thorough and complete investigation of the sabotage -
even after a federal judge, in jurisdictional deference, abstained from hearing the civil
RICO case I filed against Martha HW Crowninshield, FDIC, and Richard A. Cabral. She
cited, among other reasons that New Hampshire ‘wanted to police its own environmental
problems’, referencing the High Birches Springs. A federal investigator from US EPA
told me that New Hampshire determined that US EPA services were not required.
Shortly thereafter, New Hampshire closed the investigation file into the contaminations,
citing no suspects.
   Then, in August 1999, the State of New Hampshire released the contaminated sites
- the two parcels - during the hearing to enjoin the foreclosure just days before the
foreclosure action was scheduled by Martha HW Crowninshield, and her solely owned
company Bridgeton Corp. No surprise. Bridgeton Corp. was the only qualified bidder at
the foreclosure auction. According to New Hampshire law the auction was illegal. The
bid was for approximately $500,000, a price that did not consider the spring’s value at
all. Yet, the State of New Hampshire declared just days before the auction that the site
was deem to now be uncontaminated. The westerly upper gradient spring aquifer
recharge area where the majority of the springs were located never had been
contaminated, in the first place.
   On the day that Justice Thayer threatened to ‘blow up’ the New Hampshire Supreme
Court, the Court accepted my appeal on the High Birches foreclosure. The Court

eventually ruled in favor of Crowinshield. Jean E. Allan, on behalf of the Trust , its
beneficiaries, and its companies has filed a Hobbs Act violation complaint on behalf of
Senter, among other complaints with other jurisdictions.
   10. Jean E. Allan [Sovik] was sole stockholder of NetMark International, Inc.
[NetMark] during the period it was an ongoing business. Netmark was the retail
company for the brand High Birches Mountain Spring Water. The High Birches brand’s
first product - spring water- was being sold nationally via direct mail to private
customers. The High Birches Mountain Spring Water brand Starts Pure - Stays Pure;
The Sustainable Source brand was in its nascent stages - much like the beginnings of
Ben & Jerry’s ice cream, when its sole fully permitted water source - High Birches
Springs - was sabotaged. Both NetMark and Senter were forced to abandon its
businesses leaving its creditors in the lurch. Jean E. Allan, on behalf of the Trust , its
beneficiaries, and its companies has filed a Hobbs Act violation complaint on behalf of
   11. Jean E. Allan [Sovik] is general partner of the Gaia Family Limited
Partnership,[Gaia] a New Hampshire partnership. Fritz and Kurt Vorisek are the only two
limited partners. The partnership at one time owned all the assets of the dental business
Oral HealthCare Management, Inc. Those assets were stolen in November 1996, and
the business ceased to exist. Jean E. Allan filed criminal charges against the employee
Dr. Reginald P. Danboise that was responsible for the theft. The probable cause hearing
files have been expunged from the records according to Massachusetts Revenue
Department spokesperson. No action was taken by prosecutors against Danboise. Now,
Gaia only owns the furniture and other belongings located at 309 Waukewan Road,
along with a 2000 Jeep Cherokee. Gaia has no reportable income.
   12. The personal pain and suffering that my family and I have experienced for almost
two decades is incalculable. Many, if not all, of the personal physical attacks against us
have been already reported to the proper authorities. The list of complaints is long and
the suffering and pain is great and ongoing.

Dated:_______________                              ________________________________
                                                         Jean Elizabeth Allan [Sovik]
State of New Hampshire
Belknap County

   On August _____, 2005, Jean Elizabeth Allan personally appeared before me and
made oath that the foregoing stated by her is true and accurate to the best of her
knowledge and belief.


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