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VOLUME II

REQUESTS & MOTIONS


IN STURGEON V LA COUNTY
{PROPOSED] INTERESTED PARTY
JOSEPH H ZERNIK
Attachments & Exhibits

Sturgeon v LA County (BC351286)


Interested Party Joseph H Zernik’s Requests for Interventions by State and
Federal Attorneys Generals, and Motions for Mistrial, alternatively – to
Vacate Judgments and for Orders to Initiate Corrective Actions

Executive Summary
A small selections is presented here, from a large volume of evidence of the
operations of an alleged cult of criminality1 among the judiciary in Los Angeles
County, California. It effectively controls the LA Superior Court, the largest
superior court in the U.S., which serves over 10 million residents. It is enabled
through computerized case management systems, which require immediate
attention by the public and the U.S. Congress. Combined with denial of access to
litigation records, the LA Superior Court is a court that must be deemed upon
review in severe violations of Civil Rights guaranteed by the U.S. Constitution and
the Amendment, as well as Human Rights, pursuant to ratified International Law.
Here is perhaps a first attempt to outline the scope of such allege corruption, by
brining together evidence from both civil and criminal courts, related LA County
agencies – the Sheriff Department and Office of the Registrar Recorder, and the
conduct of local, state, and federal (FBI) agencies who are fully aware of the
matter.
Federal agencies are not ready, willing, or able to take action against a large group
of the state of California judiciary, which is organized, widespread, and well-
established, and which managed to gain some support also in the U.S. Courts. The
outcome is of global and historic proportions, from the ongoing false imprisonment
of thousands of Rampart-FIPs (Falsely Imprisoned Persons) for over a decade, to
the colossal collapse of Countrywide, and inability of US agencies to enforce the
law there either. It is proposed that the most direct way to address the problem in
general is through enforcement of (a) Nixon v Warner Communications, Inc (1978)
and states and federal rules-making enabling laws. Specific review is demanded of
the alleged criminality of Judge Jacqueline Connor in both civil and criminal
courts, which will also lead to release at long last of the Rampart FIPs.

1
The reference is to the Blue Ribbon Review Panel (2006), which concluded that a “sub-cult of criminality” was
tolerated in the justice system in Los Angeles County, California. The attempt here is to review the system in its
wider scope – the LA Superior Court both criminal and civil divisions, its relationships with the California Court of
Appeals, 2nd District, with some, small minority of the judiciary at the U.S. District Court, LA, other LA County
agencies, State and U.S. law enforcement- particularly FBI, large corporations such as Countrywide. The claim
here is that “sub-cult”, as it was designated in the Blue Ribbon Review Panel report, was an unreasonable
diminution, since such cult, as demonstrated by the evidence here, controls the LA Superior Courts.

ATTACHMENTS & EHSIBITS 1


ATTACHMENTS
Attachment A: Vague and ambiguous Rules of Court in re: entry of judgment in LA
County, California - p7
Published rules bear no relationship to reality, and the unpublished rules are both
unpublished and out of compliance with California, U.S. and International Law.
Attachment B: Concerns & Proposal regarding computers at the courts – p12
The unregulated use of computers at the courts is identified a root cause, and
solution is proposed based on enforcement of state and federal Rule Making
Enabling Act, as well as Nixon v Warner Communications, Inc (1978).
Attachment C: Involvement of Countrywide, now Bank of America Corporation, in
alleged criminality at the LA Superior Court- p15
Attachment D: Involvement of Bryan Cave, LLP, Sheppard Mullin and the legal
profession p19
The legal profession in Los Angeles and alleged criminality at the courts

EXHIBITS
EXHIBIT 1. STURGEON V LA COUNTY (BC351286) EVIDENCE FOR
MISTRIAL -
Credible evidence demonstrates that the LA Superior Court denied and continues
to deny access to the true official litigation records – the Register of Actions in
Sustain – a public record by law, and false and deliberately misleading alternative
records are published by the court.
Exhibit 1-a: July 27-29. 2009 Denial of Access to Court Records - p21
Exhibit 1-b: Aug 9, 2009 Table of Available Document Images compared to data
available in “Case Summary” online – p43
Exhibit 1-c: August 6, 2009 online Case Summary p53

ATTACHMENTS & EHSIBITS 2


Unofficial, false and deliberately misleading court records.
Exhibit 1-d: January-February 2007 & July-August 2009 Justice James A Richman
Papers in Sturgeon v LA County- p62
All of these papers should be deemed of dubious authenticity, or at least as being
treated as such by the LA Superior Court.
Exhibit 1-e: February 2007–January 2009 – Cal Crt of App, 4th District – p129
Court of Appeals rulings fail to appear among LA Superior Court records, and it is
doubted that the LA Superior Court deems them as effectual.
Exhibit 1-f: August 6, 2009 Dr Zernik’s Requests for Verification/Corrections in re:
Litigation History – Sturgeon v LA County – p136
Addressed to Clerk Gregory Drapac and Executive Officer/Clerk of the Court
John A Clarke, to Judicial Watch, Los Angeles office, and to the office of Justice
Richman. No response received so far.
Exhibit 1-g: August 10, 2009 Letter to Mr Klunder - IT, and Mr Clarke - the Clerk, in re:
Computer systems verification.- p192
Requesting explanation regarding Google Chrome security warnings regarding the
court’s severs, which are found by such programs to bear a false verification
certificate.
EXHIBIT 2. MARINA V LA COUNTY (BS109420) – EVIDENCE OF
JUDGMENT FRAUD - p197
Current, indefinite, real estate litigation at the LA Superior Court, which
originated the false jailing of Att Richard Fine though alleged judgment fraud.
Exhibit 2-a: March 4, 2009 purported Judgment by Judge David Yaffe – p197
Exhibit 2-b: July 31, 2009 Letter to the Clerk of the U.S. Court, Terry Nafisi, Demand for
Investigation – p211
Demand is for investigation of credible evidence for tampering with litigation
records in custody of the Clerk of U.S. District Court, LA.

ATTACHMENTS & EHSIBITS 3


Exhibit 2-c: July 31, 2009 Letters of Meet and Confer - p213
Letter sent to parties in preparation for filing a motion for relief from judgment.

EXHIBIT 3. GALDJIE V DARWISH (SC052737) - EVIDENCE OF


JUDGMENT FRAUD p216
Alleged courtroom real estate fraud, based on alleged judgment fraud. Combined
analysis with Samaan v Zernik (SC087400), a twin case, would lead a reasonable
person to conclude that the litigation, even prior to the filing of the complaints
were almost certainly schemed by judges of the LA Superior Court.
Exhibit 3a- Requests for authentication - p216
Exhibit 3b- Evidence for Criminality in the Register of Actions - p222
Exhibit 3c- Alleged criminality in Conveyance of Title by Att David Pasternak –
p232
Exhibit 3d- Declaration of Darwish - p233
Exhibit 3e- “Equity Rights” and alleged frauds at the LA Superior Court – p240

Exhibit 4. SAMAAN V ZERNIK (SC087400) – EVIDENCE OF JUDGMENT


FRAUD p244
Alleged courtroom real estate fraud, based on alleged judgment fraud. Although
the case was most likely initiated from the exact same launching pad, and involved
some of the same players, the case took a different turn of events.
Exhibit 4-a: Denial of access to litigation records- p244
Exhibit 4-b: Evidence of Criminality in the Register of Actions p 1 – p247
Exhibit 4-c: Table: Minute Orders in paper court file compared to Minute Orders in
Sustain – p276
Exhibit 4-d: August 9, 2007 Judgment by Court per CCP §437c, by Judge Jacqueline
Connor, and Order Granting Summary Judgment Motion- p289

ATTACHMENTS & EHSIBITS 4


Exhibit 4-e: August 9, 2007 Minute Order – Motion for Summary Judgment– by Judge
Jacqueline Connor - p297
Exhibit 4-f: August 21. 2007 Minute Order – Samaan’s Ex Parte Application for Entry
of Judgment- by Judge Jacqueline Connor – p307
Exhibit 4-g: August 7-9, 2007 Judgments from the LA Superior Court’s Microfilm
Archive – p314
Exhibit 4-h: September 7, 2007 Retired Judge Gregory O’Brien Escrow Referee
Appointment papers-by Judge Jacqueline Connor - p352
Exhibit 4-i: Sept 10, 2007 Minute Order –Disqualification for a Cause of Judge Connor,
and Fictitious Hearing on Motion for Sanctions per CCP §128.7 –
By Judge Jacqueline Connor – p364
Exhibit 4-j: Nov 9, 2007 Order Appointing David Pasternak Receiver in motion
at 4-days notice – by Judge John Segal – p370
Exhibit 4-k: Nov 9, 2007 Hearing on 4-day Notice Motion for Appointment of
Att Pasternak Receiver – Court Reporter’s transcript – Court of Judge
John Segal - p378
Exhibit 4-l: November 21, 2007 Order “like Unlawful Detainer after issuing
Writ of Execution and Entry of Judgment” by Judge John Segal, at Att
David Pasternak’s request - p398
Exhibit 4-m: December 7, 2007 Gag Orders, Indemnity Agreement, approval
of false Grant Deed by Judge Patricia Collins - at Att Pasternak’s
Request - p405
Exhibit 4-n: December 7, 2008 and December 17, 2008 Grant Deeds – by Att
David Pasternak – with opinion letter by James Wedick, of “frauds being
committed”. p437

ATTACHMENTS & EHSIBITS 5


Exhibit 4-o: January 30, 2008 Minute Order – Defendant Dr Zernik’s Ex Parte
Application for release of funds held by Att David Pasternak – by Judge Terry
Friedman - p458
Exhibit 4-p: June 22, 2009 Att David Pasternak periodic report – at the Court
of Judge Terry Friedman - p627
Exhibit 4-q: August 21, 2008 – Veteran FBI Agent Jim Wedick’s Email Note – p639
Exhibit 4-r: August –September 2008 – Kenneth Melson – Director, U.S. Dept
of Justice, and Kenneth Kaiser – Assistant Director, FBI - Alleged Fraud in
Responses to Congressional Inquiries – p641-1
.
.
Exhibit 4-s: May 13, 2008 pages from complaint filed with US Attorney Office,
LA, and FBI, LA. p641-12
Exhibit 4-t: May 30, 2008 The Big Picture – Outline pf Criminality in re:
Samaan v Zernik filed with FBI, Los Angeles. p641-64

EXHIBIT 5. RAMPART –FIPS (Falsely Imprisoned Persons) – HUMAN RIGHTS


ABUSE OF HISTORIC PROPORTIONS.
Exhibit 5-a: PBS – Rampart False Imprisonments (2001, 2005, 2008) p642
Exhibit 5-b: Chemerinsky, Erwin – The criminal justice system of Los Angeles,
California, Guild Practitioner, 2000. p648
Exhibit 5-c: October 8, 2000 LA Times Remarks on Perez by Rampart Trial Judge
Raising Eyebrows p662
Exhibit 5-d: November 16, 2000 NYT: 3 of 4 Officers Convicted In Police Corruption
Case p670
Exhibit 5-e: December 23, 2000 LA Times- Rampart Verdicts Voided p671
Exhibit 5-f: December 24, 2000 LA Times The Judge’s Decision p675

ATTACHMENTS & EHSIBITS 6


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ATTACHMENT A
INTERESTED PARTY JOSEPH H ZERNIK’S MOTIONS FOR MISTRIAL/VACATE JUDGMENTS, ORDERS
Case No. BC351286
ATTACHMENTS & EHSIBITS 7
Joseph Zernik DMD PhD
Fax: (801) 998-0917 Email: jz12345@earthlink.net

Compliance with the U.S. Constitution, or lack thereof, in conditions now


prevailing in LA County & in published & unpublished Rules of Court of LA
County, Case Law from California Court of Appeal, 2nd District, relative to
Judgment Books, Entry of Judgment, and Notice of Entry of Judgment – an
Opinion1
Q: Are condition in Los Angeles County, where Book of Judgment is hidden, where the public is denied access
to the Register of Actions and all electronic court file records, where Notice of Entry of Judgment is
nebulous, or non existent, compatible with civil rights per the U.S. Constitution?
A: No!
.

1. Introduction
The initial framework as defined by the California Code and by the published Rules of Court is simple and
clear.
Cal Code of Civ Proc § 664 says:
If the trial has been had by the court, judgment must be entered by the clerk, in conformity to
the decision of the court, immediately upon the filing of such decision. In no case is a judgment
effectual for any purpose until entered.
Regarding the requirement to maintain a Book of Judgment, and the requirement for Entry of Judgment into the
Book of Judgments, and Notice of Entry, the LA Superior Court Rules say:
3.0 JUDGMENTS (See Also LASCR, rule 8.96)
a) Original and Copy.
Whenever a proposed judgment is submitted to the court, the original shall be accompanied by
a complete, legible copy.
And the same section continue (underline added):
(d) Entry of Judgments, Orders and Decrees.
Judgments, orders and decrees rendered by the court, which are required by law to be entered,
shall be entered by the clerk in judgment books kept by him/her either in the Public Services
Division, of the Central District, or the clerk’s office in each of the several districts. The
judgment, order or decree shall be entered in the judgment books in the district wherein the
same was rendered and no other entry thereof shall be required.
The section above also emphasized the critical significance of the clerk in this regard, and the immobility of the
Book of Judgments. Therefore, the location of the Book of Judgments is fixed, and clearly advertised, whereas
the court file may move from place to place, and its location in a give time may not be easily known by the
public at large.
Also the Cal Gov Code § 69844.7 clearly states such intent of the legislators:

1
The writer has no legal education. This writing was originally more as an internal memo, for lack of time to obtain true
expert opinion, it was posted online as an opinion, qualified as it is.

ATTACHMENTS & EHSIBITS 8


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Nothing contained herein shall eliminate the requirement for a judgment book where judgments
and decrees are required to be entered.

Is the framework thus prescribed by the Code and Local Rules of Court in compliance with the U.S
Constitution?
In accordance with the requirement of due process of law, the People are given notice of a judgment in a known
place before a judgment limits the rights of, or imposes a duty on, the People. The short and sufficient answer is
that the Cal Code Civ Proc §664 in and of itself is constitutional, for there is nothing that offends the sets of
rights and duties between We the People and the civil Officers in the Government by establishing a legal
requirement that for a judgment of an Officer of the judicial Power to be a valid order capable of being enforced
upon a member of the People such judgment has to be noted in the specific place identified as the Book of
Judgments. In fact, the facially discernible intent of the state law and the court rule is to ensure that, in
accordance with the requirement of due process of law, the People are given notice of a judgment in a known
place before a judgment limits the rights of, or imposes a duty on, the People. [Paragraph written by Dr
Cordero]
2. Historical background

Historically, the adoption of such instruments named Books of Court, including but not limited to the Book of
Judgments, Register of Actions, Calendar of the Courts, and Index of All Cases, and the creation of the status of
“Public Records” applied to such Books of Court, was a key mechanism to safeguard the integrity of the courts.
Any person, without knowing the specific caption and number of the particular case, and independent of the
location of the court file, could find the final outcome of any and all litigations decided in that particular court.
Any person could also find out if any other person was tried in a particular time period in any of the courts, and
also - what the sentence was in such case. Therefore, such Books of Court, although often underestimated for
their central place in safeguard of the integrity of the courts, are comparable in significance to the Habeas
Corpus, which is universally recognized for its enduring significance. Otherwise stated: It is doubtful that it
could be possible to effectively enforce the Habeas Corpus absent the Books of Court.2
Such mechanisms were also accompanied by the creation of the more clearly defined Ministerial Arm of the
court in the body of clerks. Separation of powers was created, where the judge could render judgments, orders,
and decrees, but none of these was effective until entered by the clerk. And the clerk was the only one
authorized to carry the seal of the court, required for the act of entering the judgments of orders.
Such separation of powers, and an independent Ministerial Arm of the Court, in the body of educated and
honest clerks are critical for the integrity of the courts today as ever before.
California Code of Civil Procedure says:
"Any act required or permitted to be performed by the clerk of a court may be performed by a
judge thereof."
But for our purpose – entry of judgment or order requiring entry into the Book of Judgments, one must also
consider the requirements of service and proof of service, which typically would not be executed by a judge3.

2
These concepts are particularly important relative to the LA Superior Court, where it is universally agreed the many
people were sentenced to long prison terms, the number is likely to be in the thousands, as the result of framing by the
LAPD, prosecutors, and judges. In the ten (10) years since such facts were first disclosed, no investigative committee was
able to make any progress in resolving the situation, deemed “associated with the most repressive dictators and police
states. “ (Chemerinsky 57 Guild Prac. 121 2000). Careful reading of the reports suggests that none of the committees
had access to Books of Courts.
3
The case at hand provided a notable exception: On July 23, 2007, Judge Connor entered a Minute Order as response to
Disqualification for a Cause on July 12, 2007, that is – later than the time allowed by law. It was entered with a defective

ATTACHMENTS & EHSIBITS 9


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In conclusion: The spirit and the letter of the original law and rules relative to entry of judgment and notice of
entry of judgment was to make the entry of judgment, a clear, final, public, and indisputable manifestation of
the administration of justice, in a manner that its time and date are clearly recorded, and the record of such
transaction is kept in a fixed location in a public record, easily accessible to any person.

3. Definition Of The Problem

Various other sections of the California Codes and the California Rules of Court, LA County Local Rules of
Court, seemed to attempt to adjust the code and the rules of court to the changing technology, where the courts
are departing from paper-based documents, and moving to other means of record maintenance, but such
changes, combined with Case Law, particularly case law from California Court of Appeal, 2nd District,
described below, muddied the water.
The current state of affairs, as described in here, can be demonstrated by the 1995 published opinion of the
California Court of Appeal, 2nd District, residing in Los Angeles County, and counting a number of former
judges of the LA Superior Court among its ranks. It is important to keep such facts in mind, given that events
in Samaan v Zernik, which showed the same court, and the U.S. District Court, LA as well, denying defendant
in the LA Superior Court his right of access to trial court litigation records4, particularly – the LA Superior
Court’s Book of Judgments5, with no explanation at all. Moreover, the California Court of Appeal, 2nd also
initially allowed the LA Superior Court to file false and deliberately misleading records in lieu of Register of
Actions. That incident was not unique or result of an error, since the LA Superior Court engaged in the same
conduct – filing false and deliberately misleading records for the Register of Actions also in the U.S. District
Court, LA. And when Defendant file a motion to remove such from the record, the Court of Appeal – instead
of adjudicating on the motion before them, as required by the California Code of Judicial Ethics, eventually
asked the Clerk of LA Superior Court to withdraw such fraudulent records, without setting the record straight
on what took place in their court6. denying Defendant’s request for Judicial Notice of the true and correct Trial
Court litigation records – Minute Orders and Register of Actions, which combined clearly show the evidence
for racketeering in the LA Superior Court.
That case - Filipescu v. California Housing Finance Agency (App. 2 Dist. 1995) 48 Cal.Rptr.2d 736, 41
Cal.App.4th 738 - is summarized in West’s annotation of Cal Code of Civ Proc §668.5 as follows [underline
added – jz]:
Failure of register of actions to indicate that judgment was in fact entered did not preclude
running of 60-day time period for filing notice of appeal, where judgment was signed by law and
motion judge, since judgment was deemed entered on that date; moreover, in Los Angeles
County, which does not maintain a judgment book, entry of judgment occurs upon filing of
document, which occurred on date that file-stamped copy of judgment bearing facsimile
signature of judge was served. Filipescu v. California Housing Finance Agency (App. 2 Dist.
1995) 48 Cal.Rptr.2d 736, 41 Cal.App.4th 738, rehearing denied, review denied.
This decision is not one that stands on its own. Review of the legal status in Los Angeles County and
California shows a series of decisions in the last couple of decades, coincidental with the period of introduction
of court case management systems, and the transition from Book of Judgments which is paper-based to several
other technologies, including microfilm, tape image storage, word processors, and more recently – digital
imaging.

Proof of Service by a judge for self, purportedly indicating mailing only to one party, which denies ever receiving such
mail.
4
Denial of access to LA Sup Ct records by Ca Ct of Appeal, 2nd District:
5
Denial or access to LA Sup Ct Book of Judgments, by Ca Ct of Appeal, 2nd District and U.S. District Court, LA.
6
Filing of false records by LA Superior Court, motion to remove such records, and the Court of Appeal handling of the
situation are recorded in:

ATTACHMENTS & EHSIBITS 10


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While the code cited above implies that there must be a Book of Judgments in each County, and while Local
Rules of Court of LA County reinforce such notion, stating that a Book of Judgment must be kept in each
District of the County, the case law stated above - Filipescu v. California Housing Finance Agency – states as a
matter of fact, with no further explanation that:
“…Los Angeles County [which] does not maintain a judgment book…”
Conditions in LA County, relative to discrepancies between the codes and rules of court on the one hand, and
case law on the other hand, and discrepancies between California Rules of Court & LA County Local Rules of
Court, and the Court’s actual practice generate conditions that are vague and ambiguous.
Such conditions may be particularly misleading if judgment is filed as part of litigation records, during a period
where the parties are filing pleadings on such judgment prior to “entry”.
The conduct of the LA Superior Court in Samaan v Zernik was clear: It treated the case as one where no
judgment was entered. The clerks of the court were positive that no judgment was entered. Therefore no Writ
of Execution was issued, and eventually – fraudulent Grant Deed were recorded by David Pasternak. In fact,
there was no valid documentation on file to show service of the judgment, and only one party – Defendant -
acknowledged service of the judgment. Plaintiff claimed in open court that he would not consider this judgment
as valid, and that he had never been served with such judgment, and that he had never seen such judgment.
In contrast - the conduct of the California Court of Appeal 2nd District may be open to various interpretation,
but they are obviously irreconcilable with the conduct of the LA Superior Court. In particular, the California
Court of Appeal never clarified why it held the judgment as entered, in view of documentation provided by
Appellant that the judgment in question was never even served properly.
The concern is not only for the purpose of filing an appeal, which is most typically the context in which such
issue is discussed. As shown in Samaan v Zernik, the context is also the finality of a case. In an ambiguous
situation such as created in the LA County, the court could proceed and litigate and issue order at will after the
purported entry of judgment.
4. Opinion Rendered

Zernik opines that Such conditions as seen in Los Angeles County today are vague and ambiguous. The entry
of judgment as well as precise and clear definition of the date of entry of judgment are given unique
significance in the law. Samaan v Zernik shows two California Courts - the LA Superior Court and the
California Court of Appeal, 2nd District, through their judicial actions, treating the validity of entry of the Aug 9,
2007 judgment in diametrically opposite manners. There is no clear definition of the entry of judgment, and
with it, also date of entry of judgment becomes ill-defined. Even the existence of a specific place identified as
the Book of Judgments in Los Angeles County appears to be deliberately blurred, in part through conditions
described as denial of public access to public records that are the Books of Court. Such denial of public access
to Books of Court on its face appears as severe violation of Due Process. Therefore, combined, one must deem
conditions in LA County relative to the law on entry of judgment, and its practice by the LA Courts, in
violation of Constitutional rights of the 1st, 5th and 14th Amendment for Due Process of the Law.

ATTACHMENTS & EHSIBITS 11


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ATTACHMENT B
INTERESTED PARTY JOSEPH H ZERNIK’S MOTIONS FOR MISTRIAL/VACATE JUDGMENTS, ORDERS
Case No. BC351286
ATTACHMENTS & EHSIBITS 12
Joseph Zernik DMD PhD
Fax: (801) 998-0917 Email: jz12345@earthlink.net

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Concerns and Legislative Proposal –


Verification and Regulation of Case Management Systems (CMS’s) in the Courts
CMS’s- some of them quarter century old, or older, govern the court houses in the U.S. today
Starting in the early 1980’s many large public and private operations were rapidly computerized, following the
introduction of popular and effective programs for data base management such as dBase, in environment
including large central computers and multiple terminal stations. In the courts, such programs were called “Case
Management Systems” (CMS). Effectively, today, CMS’s – and not the paper files of the individual cases - are
the governing systems in most if not all courts in the U.S.A. A recent press release of the California Judicial
Council stated that in the California Superior Court system alone there are more than 70 different such
systems1.
CMS’s pose concerns and risks similar to those related to voting machines, but they have been flying under the
radar. Based on my limited experience, the qualify and integrity of such systems most likely widely varies
among the courts. But the integrity of such systems is key to the integrity of the courts themselves. CMS’s key
significance was somehow ignored all along – they have been flying under the radar for 2 decades or more…
My experience is based on review of Sustain, the CMS in Los Angeles County Superior Court. There is no
evidence of public oversight, or any reasonable opportunity for public comment and challenge during the
construction and installation of this system, although it amounted to a sea change in the rules of court.
Moreover, in some critical areas, the written rules of court were never adjusted to reflect the new reality –
where the CMS replaced the paper based “Books of Court”. Moreover, he system is not available for public
access, under the claims that it is:” privileged – for the court only”. The evidence shows that the program was
designed from the start to allow production of false and misleading court records on a routine basis , e.g. false
dates of entry of orders. Finally – there is no evidence of any type of quality assurance in data entry in the
courthouses, and the variations in integrity of the data entered among various cases is alarming. The evidence as
a whole clearly indicates that the CMS is the focus of wrongdoing in the court2,3.
The Press Release of the California Judicial Council announces that a new CMS – designed by the council is
now being installed in some court houses. Again, there is no evidence of any opportunity for public comment
and challenge.
Professional inspection of the computer systems in the court houses around the U.S. will most likely find major
deficiencies, and potentially other court houses where such system are abused - as is the case in Los Angeles
Superior Court. At the time that the systems were installed security concerns were often not even clearly
realized, for example. Surely there was no concern about security risks arising from remote access through
networks, for examples.
Proposal – verification and regulation of courts’ computer systems under the Rule Making Enabling Act.
Relative to new systems to be installed the legal framework may very well be in place under Rule Making
Enabling Act 28 U.S.C. §§ 2071 – 2077. Such systems must be subjected public review and challenge, as new
“rules of court”. Such review may be based on documentation produced by “logic verifiers” (e.g. M.Sc in
computer science/math with focus on logic), and such professional would develop over time “standard of care”

1
08-04-06 Press Release California Judicial Council
2
00-00-00 REPLY Heading #13 SUSTAIN- RACKETEERING’S ENABLING INSTRUMENT
3
00-00-00 REPLY Heading #14a PUBLISHED AND UNPUBLISHED RULES OF COURT LASUPCT

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for the documentation of the logical structure, its faithfulness in compliance with the law ( e.g. Code of Civil
Procedure), as well as certain guarantees regarding safeguard to prevent potential abusive and to secure the
integrity of the code over the years.
Existing systems may be much more difficult to verify and bring into compliance, but efforts must be made in
that direction by requiring such verification anytime such systems are upgraded in a significant way, either in
software or hardware.
The significance of public oversight of changes in CMS’s, reflecting today’s Rules of Court, for the safeguard
of the integrity of the courts, must not be ignored any longer.

ATTACHMENTS & EHSIBITS 14


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ATTACHMENT C
INTERESTED PARTY JOSEPH H ZERNIK’S MOTIONS FOR MISTRIAL/VACATE JUDGMENTS, ORDERS
Case No. BC351286
ATTACHMENTS & EHSIBITS 15
Joseph Zernik DMD PhD
Fax: (801) 998-0917 Email: jz12345@earthlink.net; PO Box 526, La Verne, CA 91750

00-00-00-us-dist-ct-sham-litigations-&-human-rights
09-08-07 Attachment C: Involvement of Countrywide, now Bank of America Corporation, in
alleged criminality at the LA Superior Court.
Countrywide was and is the driving force behind the alleged criminality in Samaan v Zernik
(SC087400). While Judge Connor denied any involvement in the case by Countrywide in
open court, she found the need to add an false notes on page 1 of the Register of Actions.
Identifying Countrywide Home Loans as Real Parties in Interest.

If initially the case was conceived by Samaan, or more likely by her fiancé at that time,
eventually the true Party in Interest was Countrywide Home Loans, Inc, as noted by Judge
Jacqueline Connor in page 1 of the Register of Actions in Sustain. Countrywide had no
interest in the property, but had and still has substantial interest in covering up criminality
against Dr Zernik, and beyond that – far greater criminality in the management of a sub-
prime lending institution, what later came to be known as the sub-prime crisis.
The records in Samaan v Zernik provided complete evidence of such alleged criminality by
Countrywide. To wit – already by January 2007 Dr Zernik filed complaints with the FBI Los
Angeles of fraud by Countrywide against the U.S. Government, and in a March 2007
Addendum, he projected rather adequately the liabilities to the U.S. government would end
up totaling hundreds of billions of dollars. The FBI has refused to investigate such allegations
ever since.
The detailed description of involvement of Countrywide and its top management in
criminality at the LA Superior Court, and later – Bank of America and its top management –
were detailed in papers filed with Bankruptcy Court in Houston, Texas, case of Borrower
William Parsley, case # 05-90374, well over 1000 pages of records were filed there. The
need to file I Texas arose, since the LA Superior Court and like it also the U.S. District
Court, LA, showed disregard for Due Process and their duties as courts to maintain court
records.
Countrywide’s role in the case was not pertinent to the main subject of the presentation, and
therefore, it was not mentioned in most places.
Notable exceptions:
1. The record of page 1 of the Register of Actions mentions Countrywide, since it was
pertinent for evidence of the criminal nature of Sustain – the case management
system of the court. Exhibit 4-b.
2. Recent financial report, June 22, 2009, Exhibit 4-q, by Att David Pasternak, still
notes Countrywide in relationship to Samaan v Zernik – as “Non-Party”.
Countrywide appeared for 2 years in the case, filed motions, but compulsory counter
claims were not allowed to be filed against it, all under the designation of “Non
Party”.
The following page provides a list of six records that the Audit Committee of Bank of
America Corporation was asked to authenticate or repudiate, but refuses to do either.

ATTACHMENTS & EHSIBITS 16


Joseph Zernik DMD PhD
Fax: (801) 998-0917 Email: jz12345@earthlink.net

09-04-17. Six Key Records that BAC/CFC Audit Committee was and is
requested to either authenticate or repudiate.
Below is the list as copied verbatim from letters and complaints sent to the Audit Committee
of BAC:

“Listed below are key records of the alleged fraud by CFC/BOA against JOSEPH ZERNIK in litigation of Samaan
v Zernik (SC087400) at the LA Superior Court:
1) Underwriting Letter misrepresented as a fax transmission of mid-October 2004, from
Countrywide, San Rafael to VICTOR PARKS, State of Washington. [1]
INTRODUCED REPEATEDLY IN COURT. MOST RECENTLY FOR A MOTION NOTICED FOR
NOVEMBER 2008. ALLEGED KEY FRAUD RECORD.
2) Real Property Purchase Contract misrepresented as a fax transmission of October 25,
2004, 5:03pm from VICTOR PARKS, State of Washington, to Countrywide, San Rafael.
[2]
INTRODUCED REPEATEDLY IN COURT. MOST RECENTLY FOR A MOTION NOTICED FOR
NOVEMBER 2008. ALLEGED KEY FRAUD RECORD.
3) Set of a letter and declarations by CFC/ MARIA MCLAURIN, Branch Manager, San
Rafael, California. [3]
INTRODUCED REPEATEDLY IN COURT. KEY FRAUD RECORD.
4) Subpoena Production of Countrywide in Samaan v Zernik. [4]
About 400 pages, produced by the Legal Department a total of 5 times from
August 2006 to April 2007. Deemed fraud in its entirety - since it included loan
files that were recreated after the fact, and records that are the product of
wire/fax fraud and bear false and deliberately misleading fax header imprints,
when in fact there is nothing in this production that allows to determine where
and when such records appeared from. It was part of a concerted effort by
SAMAAN,
MCLAURIN AND THE LEGAL DEPARTMENT OF CFC TO FABRICATE FALSE HISTORY FOR
SAMAAN'S LOAN APPLICATIONS IN 2004,
5) Records showing CFC and even more recently CFC/BOA appearing in court for almost
two years under the party designation of "NON-PARTY", while the court
interchangeably designates it "DEFENDANT", "PLAINTIFF", "INTERVENOR", "ROSS-
DEFENDANT", "REAL PARTY IN INTEREST", etc. [5]
Such appearances are deemed false and deliberately misleading and have no
basis in the law of the U.S. or California, Therefore they place the entire
litigation in a real that is outside the law.
6) July 23, 2007 Protective/Gag Order by Judge JACQUELINE CONNOR [6].
Such purported order led to two judgment of quasi-criminal nature being entered
by Judge Terry Friedman against me, both at the request of CFC, The second one
- in February 2009, at the requests of CFC/BOA. I have no valid court record of
that nature, and the court and CFC/ BOA so far have failed to produce this record
either.”

The numbers in square brackets in the text of the letters and the complaints to the Audit Committee referred

to records, which were posted online at the URLs listed below. Such lists were provided in the letters and

complaints to the BAC Audit Committee as well.

ATTACHMENTS & EHSIBITS 17


z Page 2/2 April 17, 2009

[1]
http://inproperinla.com/04-10-26-countrywide-fraudulent-underwriting-letter-s.pdf
http://inproperinla.com/04-10-26-doc-44-countrywide-fraud-underwriting-letter.pdf
http://inproperinla.com/04-10-26-opinion-letter-countrywide-underwriting-letter-oct-26-s.pdf
[2]
http://inproperinla.com/04-10-25-doc-45-countrywide-fraud-contract-record.pdf
[3]
http://inproperinla.com/06-11-09-doc-38-1-countrywide-mclaurin-false-declarations.pdf
http://inproperinla.com/06-11-09-doc-38-2-countrywide-mclaurin-false-declarations.pdf
[4]
http://inproperinla.com/07-02-08-countrywide-fraudulent-subpoena-production-c-s.pdf
[5]
http://inproperinla.com/09-01-13-cw-motion-sanctions-osc-contempt-S.pdf
http://inproperinla.com/09-01-13-moldawsky-notice-of-motion-sanctions-contempt.pdf
http://inproperinla.com/09-01-13-document-1.pdf
http://inproperinla.com/09-02-17-document-1.pdf
http://inproperinla.com/09-02-17-document-2.pdf
http://inproperinla.com/09-02-17-document-3.pdf
[6]
I have no such record. I expect CFC/BAC to produce the record.

ATTACHMENTS & EHSIBITS 18


1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
ATTACHMENT D
INTERESTED PARTY JOSEPH H ZERNIK’S MOTIONS FOR MISTRIAL/VACATE JUDGMENTS, ORDERS
Case No. BC351286
ATTACHMENTS & EHSIBITS 19
Attachment D
Records pertaining to Attachment D were in themselves of high volume, and
beyond the direct subject of this motion.
The evidence can be found in filing by Dr Joseph Zernik, as Interested Party in
U.S. Bankruptcy Court, Houston, Texas, case of Borrower William Allen
Parsley (05-90374)

ATTACHMENTS & EHSIBITS 20


1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
2421
25
26
27
EXHIBIT 1-a
28

INTERESTED PARTY JOSEPH H ZERNIK’S MOTIONS FOR MISTRIAL/SETTING ASIDE


Case No. BC351286
ATTACHMENTS & EHSIBITS 21
Joseph Zernik DMD PhD
Fax: (801) 998-0917 Email: jz12345@earthlink.net; PO Box 526, La Verne, CA 91750

00-00-00-us-la-sup-ct-sturgeion-v-county-09-07-28-drapac-access –to –records


09-07-28- In re: Sturgeon v County (BC351286), request to access judicial records to inspect and to
copy pursuant to Nixon v Warner Communications, Inc (1978)

Gregory Drapac
Superior Court of California
Administrator II
gdrapac@lasuperiorcourt.org

Mr Drapac:

The San Francisco Court of Justice Richman informed me that you are the local coordinator for
Sturgeon v LA County (BC351286). As such, I request that you coordinate direct access to
electronic litigation records of Sturgeon v LA County (BC351286) pursuant to Nixon v Warner
Communications, Inc (1978), where the U.S. Supreme Court re-affirmed the Common Law and
First Amendment rights of public access to judicial records to inspect and to copy.

Please let me know as soon as possible of the time and place where I will be provided such
access. Request is for access to inspect and to copy electronic records of Sturgeon v LA County
(BC351286) in Sustain, which are:
1) Register of Actions/Case History in Sustain, including Audit Data;
2) Minute Orders of the case – as they appear in Sustain;
3) Book of Judgments – if any exists in LA County, and in its absence – entry of judgment
registration in the Register of Actions/ Case History in Sustain, including Audit Data;
4) Index of All Cases – in Sustain;
5) Calendars of All Courts – in Sustain.

Furthermore, in order to allow reasonable reading of such records in Sustain, additional request
is for access to inspect and to copy the following LA Superior Court records:
1) Rules of Court, published in compliance with the law, which explicitly provide the Local
Rules of LA County Superior Court, today in force and effect in LA Superior Court, for
Entry of Judgment and for Notice of Entry of Judgment;
2) Rules of Court, published in compliance with the law, or in their absence – Sustain Manual,
which explicitly provide lists of words, or “Dictionary” for Sustain, i.e. which values are
valid entries for the various variables (E.g. Motion, Order, etc). In other words – which are
the valid menu options, recognized as valid entries by Sustain for the various field which are
variable for data entry.
3) Rules of Court, published in compliance with the law, or in their absence – Sustain Manual,
which explicitly provide explanation for the meaning of Date of Entry of Minutes such as
“00/00/00” or “33/33/33”.
4) Rules of Court, published in compliance with the law, or in their absence – Sustain Manual,
which explicitly provide rules under which the LA Superior Court is allowed to modify or
alter the Case History/Register of Actions in Sustain, and notice to parties, if any, of such
nunc pro tunc alterations.
5) Rules of Court, published in compliance with the law, or in their absence – Sustain Manual,
which explicitly provide rules under which some cases at the LA Superior Court will lists
monies paid by parties as: “Filing Fees”, “Motion Fees”, “Stipulation Fees”, etc, while in
other cases, all such moneys are listed as “Journal Entry”. It is further requested that Rules

ATTACHMENTS & EHSIBITS 22


z Page 2/3 July 28, 2009

of Court be provided as to the final disposition of funds that were originally designated
“Journal Entry”.
6) Rules of Court, published in Compliance with the law, or in their absence – Sustain Manual,
which explicitly provide rules under which some cases at LA Superior Court will list each
action with its corresponding termination, while other cases at the LA Superior Court will
allow all actions to remain unterminated.

Joseph Zernik

____________________
By: Joseph Zernik
Pro Se Party in Interest
Tel: 323 514 4583
Fax: 801 998 0917
Email: jz12345@earthlink.net

CC:

Court of Justice Richman:

Suzanne ORourke Scanlon


Judicial Assistant to th Hon. James A. Richman
(415) 865-7232
"ORourkeScanlon, Suzanne" <Suzanne.ORourkeScanlon@jud.ca.gov>

Parties and Counsel in Sturgeon v County (BC351286):

Paul J. Orfanedes, Esq.


JUDICIAL WATCH, INC.
501 School Street, SW
Suite 500
Washington, DC 20024
Tel: (202) 646-5172
Fax: (202) 646-5199
Attorneys for Plaintiff

Sterling E. Norris, Esq.


JUDICIAL WATCH, INC.
2540 Huntington Drive
Suite 201
San Marino, CA 91108
Tel.: (626) 287-4540
Fax: (626) 237-2003
Attorneys for Plaintiff

ATTACHMENTS & EHSIBITS 23


z Page 3/3 July 28, 2009

Elwood Lui, Esq.


Brian Hershman, Esq.
DAY JONES
555 South Flower Street
50th Floor
Los Angeles, CA 90071
Telephone: (213) 489-3939
Facsimile: (213) 243-2539
bhershman@jonesday.com
Attorneys for Defendants

Theodore J. Boutrous Jr., Esq.


Kahn A. Scolnick, Esq.
GIBSON, DUNN & CRUTCHER LLP
333 South Grand Ave
Los Angeles, CA 90071-3197
Tel: (213) 229-7000
Fax: (213) 229-7520
Attorney for Intervenor

MM

ATTACHMENTS & EHSIBITS 24


2009-Ju1-28 1258 PM LOS ANGELES SUPERlOR COURT 2136253964 1/2

Superior Court of California.


County of Los Angeles
Court Counsel
111 North Hill Street, Suite 546
Los Angeles, California 90012
Telephone (213) 893-1224
Facsimile (213) 625-3964

FAX COVER SHEET

DATE: 7/28/09 TOTAL PAGES (including coversheet): d:l--

TO: JOSEPH ZERNICK FAX NO.: (801) 998-0917

FROM: FREDERICK R. BENNETT


Court Counsel

RE: Electronic Access - Sturgeon v. County of Los Angeles

Please see attached.

IF YOU DO NOT RECEIVE ALL PAGES, PLEASE TELEPHONE US


IMMEDIATELY AT THE NUMBER LISTED ABOVE.
confidontlatlty Notlce~ This m~ssaga, Includlna anyetmchmeme, 15 lbr till:sole mil: of lhCl Intended Nclphmt(s) and mayCORwin confidcntiEl.1 lind
privilcJI,od information. Anyunauthorized review, usa,disclosure or di!ltributlon Isprohibited. Iryou are not tha intended reclplcnt, please
c:ontnet thesenderanddestroy nilcopies altho original message,

ATTACHMENTS & EHSIBITS 25


2009-Ju1-28 1258 PM LOS ANGELES SUPERlOR COURT 2136253964 2/2

4Liis~i""""
/;:'''''I-*'''~~'.lii.N{l~,'~ FReoeRICK R. BeNN8T
I~''';~ ,'1;",<., COUIlTCOUN5el Superior Court of California
~~~ ~," ~\~ i'ii'NO:::R::IH':":H':::ll':"'lS::m::e::ET~.S~UIT::e-=54':":6~-------~----::::-"":""':"'_-~:----fo"":"-::---
"',I.~ I /.i!5 lOSANGclc5,CA90012.3014 Oounty of Los A~eles
"<>... ,,;W 12131 693-1224 Fex: (2131 625·3964
'<~~:.~~~Y

July 28, 2009

Joseph Zernik Via Facsimile to (801) 998-0917

Re: Request for electronic access to pleadings in Sturgeon v. County of Los Angeles,
LASC Case number BC351286..

Dear Mr. Zernik:

Yourfacsimile and email to Los Angeles Superior Court Clerk Gregory Drapac was referred
to me for response.

Motions in pending cases must be filed in writing in accordance withthe California Rules of
Court. California Rule of Court 2.118 provides that the clerkof the courtmustnot accept for filing
or file any papers that do not comply with the California Rules of Court, Rules 2,I00 to 2.119.
California Rule of Court 2.118(a). California Rules of Court may be accessed at:
http://www.courtinfo.ca.gov/rules/

Similarly, requests for court documents should be made in person 01' by letter. I do not
respond to email requests from other than court personnel. Such requests should also be submitted
in writing.

With regard to yourrequest for electronic access to pleadings in the Sturgeon litigation,
access to the court's electronic records aregoverned by California Rules of Court, Rule 2.500, and
following. Under those Rules the court may, but is not required to permit access to scanned
pleadings. When access to scanned pleadings is provided, Rule 2.506 permits the Court to impose
fees for such access,

In implementing these Rules, the Los Angeles Superior Court permits free access without
fee to paper files and available scanned pleadings at the courthouse where they are on file without
fee. Printed copies of either thepaperfiles or electronic copies are provided for a fee of fifty cents
a page. Alternatively, and as a convenience, you may view the court's registers of actions and
summaries of cases without fee on line at the court's web page, and may review, download and print
pleadings in most Central District Civil cases, including the Sturgeon case, by registering and
paying the fee therefor: httll://www.1asuperiorcourt,org!

rederick R. Bennett
Court Counsel

c: Gregory Drapac

ATTACHMENTS & EHSIBITS 26


Joseph Zernik DMD PhD
Fax: (801) 998-0917 Email: jz12345@earthlink.net; PO Box 526, La Verne, CA 91750

00-00-00-us-la-sup-ct-sturgeion-v-county-09-07-28-drapac-access –to –records


09-07-28- In re: Sturgeon v County (BC351286), 2nd request to access judicial records to inspect
and to copy pursuant to Nixon v Warner Communications, Inc (1978)

Gregory Drapac
Superior Court of California
Administrator II
gdrapac@lasuperiorcourt.org
Tel: 213 974 5201
Fax: 213 625 8536
(by fax and by email)

Mr Drapac:

This is the second request to access the electronic Register of Actions of Sturgeon v County
(BC351286) in Sustain the Court’s case management system. You informed me today that Mr
Bennett , Counsel for the Court, responded on your behalf to my request earlier today.

That is not the case.

Mr Bennett wrote extensively regarding scanned pleadings, etc, but nowhere in his letter did he
address the issue of access to Register of Actions in Sustain, the official litigation record of the
LA Superior Court in Sturgeon v LA County.

I again request that you inform me when and where I would be able to access litigation records
in Sturgeon v LA County (BC351286), which are the Register of Actions, Book of Judgments (If
any exists), Calendars of the Courts, and Minute Orders in Sustain, the electronic case
management system of the LA Superior Court.

Joseph Zernik

____________________
By: Joseph Zernik
Pro Se Party in Interest
Tel: 323 514 4583
Fax: 801 998 0917
Email: jz12345@earthlink.net

CC:

ATTACHMENTS & EHSIBITS 27


z Page 2/3 July 28, 2009

Court of Justice Richman:

Suzanne ORourke Scanlon


Judicial Assistant to th Hon. James A. Richman
(415) 865-7232
"ORourkeScanlon, Suzanne" <Suzanne.ORourkeScanlon@jud.ca.gov>

Parties and Counsel in Sturgeon v County (BC351286):

Paul J. Orfanedes, Esq.


JUDICIAL WATCH, INC.
501 School Street, SW
Suite 500
Washington, DC 20024
Tel: (202) 646-5172
Fax: (202) 646-5199
Attorneys for Plaintiff

Sterling E. Norris, Esq.


JUDICIAL WATCH, INC.
2540 Huntington Drive
Suite 201
San Marino, CA 91108
Tel.: (626) 287-4540
Fax: (626) 237-2003
Attorneys for Plaintiff

Elwood Lui, Esq.


Brian Hershman, Esq.
DAY JONES
555 South Flower Street
50th Floor
Los Angeles, CA 90071
Telephone: (213) 489-3939
Facsimile: (213) 243-2539
bhershman@jonesday.com
Attorneys for Defendants

Theodore J. Boutrous Jr., Esq.


Kahn A. Scolnick, Esq.
GIBSON, DUNN & CRUTCHER LLP
333 South Grand Ave
Los Angeles, CA 90071-3197
Tel: (213) 229-7000
Fax: (213) 229-7520
Attorney for Intervenor

MM

ATTACHMENTS & EHSIBITS 28


2009-Ju1-29 1007 AM LOS ANGELES SUPERlOR COURT 2136253964 1/7

---------_ .. _--_._..
Superior Court of California
County of Los Angeles
Court Counsel
III North Hill Street, Suite 546
LosAngeles, California 90012
Telephone (213) 893-1224
Facsimile (213) 625-3964

FAX COVER SHEET

DATE: 7/29/09 TOTAL PAGES (including coversheet): -r


TO: JOSEPH ZERNICK FAX NO.: (801) 998-0917

FROM: FREDERICK R. BENNETT


Court Counsel

RE: Request forAccess to Records - Sturgeon v. County of Los Angeles

Please see attached.

IF YOU DO NOT RECEIVE ALL PAGES, PLEASE TELEPHONE US


IMMEDIATELY AT THE NUMBER LISTED ABOVE.
Canndenthillty Notice; This massagQ,lncludlng any enacbmeus, Isfur tho solousaof till' Intended reclplent(s) and may contain confldentlaland
privileged inforrnation. Anyunauthorized review, USQ, disclosure ordistribution Isprohibited. If youare nottheintended recipient, please
contact the .ender 'nd de.troy .lIeopie. orthe origin.1 m....go.
ATTACHMENTS & EHSIBITS 29
2009-Ju1-29 1007 AM LOS ANGELES SUPERlOR COURT 2136253964 2/7

FREDERICK R. BENNETT
COUIlT COUNSEL Superior Court oj California
111 NORTH HILL smm. SUITE 546
lOSANGELES. CA90012·3014
County oj'Los AngeZr-
es -
(2131893·1224 FOX: (2131 625·3964

July29, 2009

Joseph Zernik Via Facsimile to (801) 998-0917

Re: July28,2009, Request for access to litigation records in Sturgeon v. County of Los Angeles,
LASC Case number BC351286, and other cases.

Dear Mr. Zemik:

Your attached facsimile to Los Angeles Superior Court Clerk Gregory Drapac was referred to me for
response.

In this communication, yourequest thatyoube provided direct access to electronic litigation records in
Sturgeon v, County of Los Angeles, Los Angeles Superior COUlt casenumber BC3S1286, andothercases
under claimed Common Law andconstitutional rights of access to court records. You seekto inspect andcopy
thecourt's entire Sustain electronic databaserelated to the Register of Actions/Case history, Minute Orders,
Book of Judgements, Index and Calendars of all courts. Finally, you ask forpublished copies of'theRules of
Court, or in their absence, a copy of the Sustain Manual to assist you in understanding the Sustain electronic
databaseyou have requested.

These requests for court records arenot matters thatcan be resolved by the clerk forthejudicial officer
handling a specific case. Rather, public records requests such as yours should be directed to the custodian of
therecords, which is the Executive Officer/Clerk of theCourt, who hasrequested that I respond to your
requests on hisbehalf.

In responding to this inquiry, I have become aware thatyouhave made a number of othersimilar
requests relating to other cases overthe pasttwo years, many of which have been responded to by my
colleague, D. Brett Bianco. I also notethat youhave many pending cases in the Los Angeles Superior Court,
the Court of Appeal for the State of California, Second Appellate District, and at least one case pending in the
U.S. District Court against a number of Los Angeles Superior Court judges, personnel andothers, thatmay
relate in various ways to many of yourrequests. Reviewing the U.S. District Court docket forJoseph Zernik v.
Judge Jacqueline Connor, et al., U.S.D.C., Central District of California casenumber, CY08-I550, it appears
thatthe U.S. Magistrate recommended dismissing thataction on March 31, 2009, thatthe recommendation was
accepted by the District Court Judge on April 24,2009, andthatJudgement was entered on thatsame date
dismissing yourfederal claims withprejudice, andyourstateclaims without prejudice.

I have reviewed these matters to see if I could distill down more specifically whatyou were seeking
from the court so that I might be able to determine a feasible way to getyou what you are seeking.

Sturgeon documents: All of the pleadings, minute orders, andotherorders in the Sturgeon litigation
are public documents available for inspection andcopying by the public. A review of the matter does not
indicate thatanypleadings or orders have been sealed. Thepaper file for this case should be available for
inspection andcopying at the courthouse when the fileis not in useby thejudge, his clerk, or other members of
the public. In addition, those court records have also been scanned into electronic format and areviewable over
thepubllc electronic access terminals at thecourthouse, and copies of the pleadings maybe ordered. Finally, as
a convenience, you can also access the Register of Actions forthiscaseon line at the Court's web site,
LASuperiorCourt.org, which also presents a summary of all of thepleadings, orders and hearings in the case,

ATTACHMENTS & EHSIBITS 30


2009-Ju1-29 1007 AM LOS ANGELES SUPERlOR COURT 2136253964 3/7

Joseph July 28,2009, Request for access to litigation records in Sturgeon v. County of Los Angeles,
LASC Case number BC35 1286, andother cases.
July 29, 2009
Page: 2

andby registering andpaying the fee permitted by the California Rules of Court, youmay download andprint
copies ofthe pleadings andorders.

Inreviewing some of your pastcommunications to the court, it appears thatthere may be some
confusion as to the nature ofthe scanned electronic copies of thepleadings thatthe court makes available at the
public Sustain terminals andoverthe Internet, These documents were not electronically filed as permitted by
California Rules of Court Rules 2.250, and following. Thedocuments were filed as paper documents, andthen,
as is the practice formost civil cases in the Central District of the Court, butnot for other Districts, the paper
documents were scanned into electronic fermat, Asa result, andcontrary to a contention youhave made in
prior communications, these documents andcourt records are not governed by the provisions of California Rule
of'Court 2.254, or other provisions of Chapter 2 or Division 2 of the California Rules of Court. With certain
case specific exceptions permitted in certain complex litigation, which does not include the Sturgeon case, the
only pleadings thatare filed electronically in the Los Angeles Superior Court arecertain small claims actions.

Electronic court records generally aregoverned by Chapter 2 of Division 4 of the California Rules of
Court, Rules 2.500 andfollowing. Unlike Rille 2.254, which deals with pleadings electronically filed by the
parties in lieu of paper pleadings, these rules deal with themore general subject of electronic records,
regardless of themanner in which It has been computerized. See Rule 2.502(2).

These Rules of Court generally require thatall electronic records be made "reasonably available to the
public in some form, whether in electronic or in paper form, except those thatare sealed or made confidential
by law." Rule 2.503(a). TheRules of Court do notrequire electronic records to be made available In all forms.
In fact, the Rules mandate thatmany electronic records be made available only at the courthouse andnot over
the Internet. Rule 2.503(c).

Generally, registers of actions, calendars, and indexes arerequired to be made available overthe
Internet "to the extent it is feasible to do so." Rille 2..503(b). "Feasible" is defined to mean thata court is
required to provide such access "to the extent thatit determines it has theresources and technical capacity to do
so." This Court has done thatandthese matters areavailable to the extent the court has determined it has the
resources and technical capacity to do so on the Court's web site: LASliperiorCourt.org.

Bulkaccess to electronic records: With regard to bulk access to electronic court records such as you
have requested, the Rules of Court provide thata court "may" but is not required to provide such access. Rule
2.503(g). In this regard, this court generally follows the holding of Westbrook v. County ofLos Angeles (1994)
27 Cal.AppAth 157. As thatcaseholds, there is a qualitative difference between obtaining information
from a hand search of court files, and obtaining information from electronic data. It is the aggregate
and easily collated and manipulated nature of electronic data that warrants its difference in treatment
from access to court files.

None of the cases or authorities thatyou have provided require the court to provide youelectronic
access to therecords youhave described. Nordo such authorities give youdirect access to the court's Sustain
system or bulk distribution of all or a significant subset of the court's electronic records. Accordingly, your
request in this regard is denied.

ATTACHMENTS & EHSIBITS 31


2009-Ju1-29 1007 AM LOS ANGELES SUPERlOR COURT 2136253964 4/7

Joseph July28,2009, Request fur access to litigation records in Sturgeon v, County of Los Angeles,
LASC Case number BC351286, andother cases.
July29,2009
Page: 3

Rules of Court: California Rules of Court may be accessed at: htto://wWW.coul1info.ca.govlrules/ The
Local Rules of the Court are available at: http://lasuperiorcourt.org/

Motions in Sturgeon or other cases: Motions, including ex parte motions, andmotions to intervene
in pending cases must be filed in accordance with the California Rules of Court andthe statutory fees must be
paid. California Rule of Court 2.118 provides thatthe clerk of the court must not accept for filing or file any
papers thatdo notcomply with the California Rules of Court, Rules 2.100 to 2.119. California Rule of Court
2.118(a).

Very truly yours,

~:::~
Court Counsel

c: John A. Clarke
Gregory Drapac
D. Brett Bianco

ATTACHMENTS & EHSIBITS 32


2009-Ju1-29 1007 AM LOS ANGELES SUPERlOR COURT 2136253964 5/7

To: Pas.SofS 2000.07-2" 12:41:20 (GMT) Prom: Joeeph zernlk

Joseph Zemik DMDPhD


Fax: (801) 998-0917 Email: jl12346@earthlink.net; ~O Box 626, La verne. CA91760

OO.OO·OO-us-la••up.ct-sIu'll.lon-v-<:ounty-09-01-28-d",pa.,.access -to - reCOI'II.


09-07-28- In re: StIU'geon V COlUlty (BC351286), request to access judicialrecords to Inspect and to
copy pursuant to Nixon v Wamer Communications, Inc (1978)

GregoryDrapac
Superior Court ofCalifomill
AdministmtorII
gdrapac@1l1/Juperiorco\ut.org

Mr Drapac:

TheSanFrancisco Court ofJustice Richman informed methatyou arethe local coordinator for
Sturgeon v LAConnty (BC35 1286). As such, I request thatyou coordinate direct access to
electronic litigation records ofSturgeon v LACounty (BC35 1286) pursuant to Nixon v Warner
Communications. Inc(1978), where the U.S. Supreme COUlt re-affirmed the Common Law and
FirstAmendment rights of public access tojudicialrecords to inspect andto copy.

Please let meknow as soon as possible of thetime and place where I willbe provided such
access. Request is for access to inspect and to copy electronic records ofSturgeon v LACounly
(BC351286) in Sustain, which are:
1) Register of Actions/Case History in Sustain, including Audit Data;
2) Minute Orders of the ease - as they appear in Sustain;
3) Bookof Judgments - if anyexists in LA County, andin its absence - entry ofjudgment
registration in theRegister of Aotionsl Case History in Sustain, including Audit Data;
4) Index of AllCases - in Sustain;
5) Calendars of All Courts - in Sustain.

Furthennore, in order to allow reasonable reading ofsuch records in Sustain, additional request
is for access to inspect and to copy thefollowing LA Superior COUlt records:
I) Rules of Court, published in compliance withthe law, which explicitly provide tile Local
Rules ofLACounty Superior Court, today inforce and effect in LA Superior Court, for
Entry of Judgment and for Notice of Entry of Judgment;
2) Rules ofCour!, published in compliance with thelaw, or in tlleU' absence - Sustain Manual,
which explleitly provide lists ofwords, or"Dictionary" for Sustain, i.e. which values are
valid entries forthevarious variables (E.g. Motion, Order, etc). In other words - which are
thevalidmenu options, recognized asvalid entries by Snstain for thevarious field which are
variable fordata entry.
3) Rules ofCour!, published in compliance with thelaw, or in their absence - Sustain Manual,
which explicitly provide explanation for themeaning ofDateof Entry of Minutes such as
"00/00/00" or "33133/33".
4) Rules of Court, published in compliance withthelaw. or in their absence - Sustain Manual,
which explicitly provide rules under which the LASuperior Court is allowed to modify or
altertheCase HistorylRegister of Aotions in Sustain, and notice to parties, if any, ofsuch
nunc pl'O tunc alterations.
5) Rules of'Court, published in compliance with the law, or in their absence - Sustain Manual,
which explicitly provide rules under which some cases at theLA Superior Court will lists
monies paid byparties as: ''FilingFees", "Motion Fees", "Stipulation Fees", etc, while in
other cases, all such moneys are listed as "Journal Entry". It is further requested tlmt Rules

ATTACHMENTS & EHSIBITS 33


PAQ!3f5 R Rcve AT71.2812DOII 5:44:25 AM [pIC Ina Daylight Time] R SVR:1..A..!AX011O * ONIS:6520 * CSIO: * DURATION (mmoss):02.1l4
2009-Ju1-29 1007 AM LOS ANGELES SUPERlOR COURT 2136253964 6/7

']"0: ~age 4 or5 From: Joseph Z.rnrk

• Page213 July 28, 2008

of Court be provided as to the final disposition offundsthetwere originally designated


"Journal Entry",
6) Rules of Court, published in Compliance with the law, or in their absence - Sustain Manual,
which explicitly provide rules under which some cases at LA Superior Court will list each
action with its corresponding termination, while other cases at the LA Superior Court will
allow all actions to remain unterminated.

JosephZemik
:"', IJtD11DllJ ~lllncd by
~ , JlIlitllhH :t::Rmlk
VCN~O\.'Il$~phHUIT\\1i.
o,t1u,
.." J1 151nliJI11j15G'11flh1l1l
) . ~L. toe-US
,_" 'd~i\I'~trle.
CalifornIa ,.,,;
C1al~2009.o7.2.8
05:29:110-oroo'

By;Joseph Zemik
Pro SC PlUiy inInterest
Tel: 3235144583
Fa.'\:; 801 9980917
Email: jz l2345@eartblinknet

cc:
Com"! ofJusticeRichman;

Suzanne ORourke Scanlon


JudioialAssistanttothHon. James A, Richman
(415) 865.7232
"ORourkeSoanlon, Suzanne" <Suzanne.ORourkeSoanlOl@iudoa.gov>

Partiesand Counsel in Sturgeon v County (BC351286):

Paul J. Orfanedes, Esq.


JUDICIAL WATCH, INC.
501 School Street, SW
Suite 500
Washington, DC 20024
Tcl: (202) 646-5172
Fax: (202) 646-5199
Attorneys/or Plaintiff
Sterling E. Norris, Esq.
JUDICIAL WATCH, INC.
2540 Huntington Drive
Suite 201
San Marino, CA91108
Tel.: (626) 287-4540
Fax: (626) 237-2003
Attorneysfor Plaintiff

ATTACHMENTS & EHSIBITS 34


PAGI!!! 4/5 R FlCVD AT 712812D08 5:44:25 AM [paCIfiC DayllgntTIm.]" SVR:LAJAXD1/0R DNIS:1I520 R CSID: R DURATION (mm-II):D2-64
2009-Ju1-29 1007 AM LOS ANGELES SUPERlOR COURT 2136253964 7/7

2OOll-07-2812:41::l; (GMT) From: JCMpl'l ZlImlk

• Pag93/3 July 28, 2009

Elwood Lui, Esq.


Brian Hershman, Esq.
DAY JONES
555 South Flower Street
SOthFloor
Los Angeles, CA90071
Telephone: (213) 489-3939
Facsimile: (213) 243-2539
bhsnhman®jonss4ay.com
Attorneysfor Defendants

Theodore J. Boutrous Jr.,Esq.


Kahn A. Scolnick, Esq,
GillSON, DUNN & CRUTCHER LLP
333 South Grand Ave
Los Angeles, CA90071-3197
Tel: (213)229-7000
Fax: (213) 229-7520
Attormyfor ~

MM

ATTACHMENTS
PAOI m I RCW AT 7121120016:":26 AM ['de: D8YI1gtIt Tlme) I & EHSIBITS
8VR:I...A-'~D11O" DMI:U62D" 35):oa:a
CBlD: DURATIOr4 (mm...
Il
Joseph Zernik DMD PhD
Fax: (801) 998-0917 Email: jz12345@earthlink.net; PO Box 526, La Verne, CA 91750

00-00-00-us-la-sup-ct-sturgeion-v-county-09-07-28-drapac-access –to –records


09-07-29- In re: Sturgeon v County (BC351286), 3rd request to access judicial records to inspect
and to copy pursuant to Nixon v Warner Communications, Inc (1978)

Gregory Drapac
Superior Court of California
Administrator II
gdrapac@lasuperiorcourt.org
Tel: 213 974 5201
Fax: 213 625 8536
(by fax and by email)

Mr Drapac:

This is the third request to access the electronic Register of Actions of Sturgeon v LA County
(BC351286) in Sustain the Court’s case management system. I received today by fax yet another
lengthy letter from Mr Bennett , Counsel for the Court, who responded on your behalf to my 2nd
request to access court records in Sturgeon v LA County.

Mr Bennett’s 1st response, dated July 28, 2009, just skirted the issue, and never addressed the
request to access the Register of Actions, the official litigation record of Sturgeon v LA County.

Mr Bennett’s 2nd response, dated July 29, 2009, again engaged in the same pattern, for example,
discussing at length the issue of access over the Internet, when in fact, I never requested Internet
access to records, I explicitly asked when and where I would be able to access the records,
willing to appear at any location of the court for that purpose.

Mr Bennett in his 2nd response went further than that, and included false and misleading
statements:
Finally, as a convenience, you can also access the Register of Actions
for this case on line at the Court's web site, LASuperiorCourt.org,
which also presents a summary of all of the pleadings, orders and
hearings in the case, and by registering and paying the fee permitted
by the California Rules of Court, you may download and print copies
of the pleadings and orders.

As you are fully aware, the Register of Actions of Sturgeon v LA County, or any other case
of the LA Superior Court, is NOT available online at LASuperiorCourt.org. The
information that is provided there, under the title “Case Summary”, is prefaced by a
Disclaimer by the Court, explicitly stating that the records presented online are NOT official
court records. Moreover, the information provided in such records online is vastly different
from the information in the Register of Actions in Sustain.

The Clerk of LA Superior Court attempted such misleading misuse of records in the past in
two other instances:

ATTACHMENTS & EHSIBITS 36


z Page 2/4 July 29, 2009

1) At California Court of Appeals, 2nd District, in case of Zernik v LA Superior Court


(B203063), the LA Superior Court filed the “Case Summary” from
LASuperiorCourt.org in lieu of the Register of Actions in Sustain. I then filed an
objection. The California Court of Appeals, 2nd District, then issued an order on the
Clerk of the LA Superior Court to withdraw that filing, in fact accepting my
objection.
2) At U.S. District Court, LA, in case of Zernik v Connor et al (2:08-cv-01550), the
LA Superior Court filed the record called “Case Summary” from
LASuperiorCourt.org in lieu of the Register of Actions in Sustain. I then filed an
objection, and OSC Contempt, for attempted fraud on the U.S. Court by the LA
Superior Court. However, the U.S. District Court refused to rule on the matter, no
matter how much I pressed for a hearing and ruling. That Court claimed that the
issue was not material to the matter at hand…

Given such history, it is likely that Mr Bennett’s most recent response, and his statement
about the Register of Actions of Sturgeon v LA County being available online at
LASuperiorCourt.org, upon review by a competent court of jurisdiction, be deemed false
and deliberately misleading.

I again request that you inform me when and where I would be able to access litigation records
in Sturgeon v LA County (BC351286), which are the Register of Actions, Book of Judgments (If
any exists), Calendars of the Courts, and Minute Orders in Sustain, the electronic case
management system of the LA Superior Court, to inspect and to copy, pursuant to Nixon v
Warner Communication, Inc (1978), where the U.S. Supreme Court re-affirmed the Common
Law and First Amendment right to access judicial records to inspect and to copy.

Joseph Zernik

____________________
By: Joseph Zernik
Pro Se Party in Interest
Tel: 323 514 4583
Fax: 801 998 0917
Email: jz12345@earthlink.net

P.S.
Court Counsel Bennett 2nd Response can be viewed at:
http://inproperinla.com/00-00-00-la-sup-ct-sturgeon-v-la-county-09-07-29-court-counsel-bennett-response-
no2--req-access-to-records.pdf

ATTACHMENTS & EHSIBITS 37


z Page 3/4 July 29, 2009

CC:

John A Clarke,
Executive Officer/Clerk of the Court
Phone: 213 974 5050
Fax: 213 621 7952
jclarke@lasuperiorcourt.org

Court of Justice Richman:

Suzanne ORourke Scanlon


Judicial Assistant to th Hon. James A. Richman
(415) 865-7232
"ORourkeScanlon, Suzanne" <Suzanne.ORourkeScanlon@jud.ca.gov>

Parties and Counsel in Sturgeon v County (BC351286):

Paul J. Orfanedes, Esq.


JUDICIAL WATCH, INC.
501 School Street, SW
Suite 500
Washington, DC 20024
Tel: (202) 646-5172
Fax: (202) 646-5199
Attorneys for Plaintiff

Sterling E. Norris, Esq.


JUDICIAL WATCH, INC.
2540 Huntington Drive
Suite 201
San Marino, CA 91108
Tel.: (626) 287-4540
Fax: (626) 237-2003
Attorneys for Plaintiff

Elwood Lui, Esq.


Brian Hershman, Esq.
DAY JONES
555 South Flower Street
50th Floor
Los Angeles, CA 90071
Telephone: (213) 489-3939
Facsimile: (213) 243-2539
bhershman@jonesday.com
Attorneys for Defendants

Theodore J. Boutrous Jr., Esq.


Kahn A. Scolnick, Esq.
GIBSON, DUNN & CRUTCHER LLP

ATTACHMENTS & EHSIBITS 38


z Page 4/4 July 29, 2009

333 South Grand Ave


Los Angeles, CA 90071-3197
Tel: (213) 229-7000
Fax: (213) 229-7520
Attorney for Intervenor

MM

ATTACHMENTS & EHSIBITS 39


Joseph Zernik DMD PhD
Fax: (801) 998-0917 Email: jz12345@earthlink.net; PO Box 526, La Verne, CA 91750

00-00-00-us-la-sup-ct-sturgeion-v-county-09-07-30-drapac-req-#3-addendum
09-07-30- In re: Sturgeon v LA County (BC351286), Addendum to Request #3 to access judicial
records to inspect and to copy pursuant to Nixon v Warner Communications, Inc (1978)

Gregory Drapac
Superior Court of California
Administrator II
gdrapac@lasuperiorcourt.org

Mr Drapac:

Please accept the following as addition to my request #3: Mr Bennett, Court Counsel, made
some false and misleading statements in re: Litigation records. It also appears that Plaintiff,
which is Judicial Watch, Inc, is yet to gain access to the true litigation records in Sturgeon v LA
County (BC351286). Therefore, let me provide some clarification in re: Litigation records at
the LA Superior Court.

In Samaan v Zernik (SC087400), purported to be matter heard at the LA Superior Court, the
following records are available for viewing online:

1) The record that Counsel Bennett falsely and misleadingly referred to as the “Register of
Actions” at lasuperiorcourt.org, or “Case Summary”, can be viewed at:
http://inproperinla.com/00-00-00-la-sup-ct-case-summary-courtnet-08-11-30-s.pdf
The disclaimers that come with that record can be viewed at:
http://inproperinla.com/00-00-00-la-sup-ct-case-summary-online-disclaimers-s.pdf
2) The record that is the true Register of Actions in Sustain, is shown at:
http://inproperinla.com/00-00-00-la-sup-ct-register-of-actions-case-history-s-v-z-sustain-08-11-14-
certified-s.pdf
3) The differences between records 1) and 2) are summarized in a table form, as filed at the
California Court of Appeals, 2nd District (B203063 ), can be viewed at:
http://inproperinla.com/00-00-00-computers-&-the-courts-false&deliberately-misleading-court-records-
s.pdf
Additional discussion of the Register of Actions, and false records in it, can be viewed at:
http://inproperinla.com/00-00-00-computers-&-the-courts-register-of-action.pdf
4) The Minute Orders, as seen in paper court file, can be viewed at:
http://inproperinla.com/00-00-00-la-sup-ct-minute-orders-s-v-z-paper-court-file-s.pdf
5) The Minute Orders, as seen in Sustain, or electronic court file, can be viewed at:
http://inproperinla.com/00-00-00-la-sup-ct-minute-orders-electronic-case-file-08-11-14-full-certif-s.pdf
6) The differences between the records in 4) and 5) are summarized in a table form in the
following record, which can be viewed at:
http://inproperinla.com/00-00-00-la-sup-ct-minute-orders-table-summary-s-v-z-s.pdf
7) Short discussion of false and deliberately misleading litigation records at the LA Superior
Court, can be viewed at:
http://inproperinla.com/00-00-00-computers-&-the-courts-abstract-&-figures.pdf

Joseph Zernik

ATTACHMENTS & EHSIBITS 40


z Page 2/3 July 30, 2009

____________________
By: Joseph Zernik
Pro Se Party in Interest
Tel: 323 514 4583
Fax: 801 998 0917
Email: jz12345@earthlink.net

CC:

Court of Justice Richman:

Suzanne ORourke Scanlon


Judicial Assistant to th Hon. James A. Richman
(415) 865-7232
"ORourkeScanlon, Suzanne" <Suzanne.ORourkeScanlon@jud.ca.gov>

Parties and Counsel in Sturgeon v County (BC351286):

Paul J. Orfanedes, Esq.


JUDICIAL WATCH, INC.
501 School Street, SW
Suite 500
Washington, DC 20024
Tel: (202) 646-5172
Fax: (202) 646-5199
Attorneys for Plaintiff

Sterling E. Norris, Esq.


JUDICIAL WATCH, INC.
2540 Huntington Drive
Suite 201
San Marino, CA 91108
Tel.: (626) 287-4540
Fax: (626) 237-2003
Attorneys for Plaintiff

Elwood Lui, Esq.


Brian Hershman, Esq.
DAY JONES
555 South Flower Street
50th Floor
Los Angeles, CA 90071
Telephone: (213) 489-3939

ATTACHMENTS & EHSIBITS 41


z Page 3/3 July 30, 2009

Facsimile: (213) 243-2539


bhershman@jonesday.com
Attorneys for Defendants

Theodore J. Boutrous Jr., Esq.


Kahn A. Scolnick, Esq.
GIBSON, DUNN & CRUTCHER LLP
333 South Grand Ave
Los Angeles, CA 90071-3197
Tel: (213) 229-7000
Fax: (213) 229-7520
Attorney for Intervenor

MM, KW

ATTACHMENTS & EHSIBITS 42


1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
EXHIBIT 1-b
28

INTERESTED PARTY JOSEPH H ZERNIK’S MOTIONS FOR MISTRIAL//SETTING ASIDE


Case No. BC351286
ATTACHMENTS & EHSIBITS 43
Joseph Zernik DMD PhD
Fax: (801) 998-0917 Email: jz12345@earthlink.net; PO Box 526, La Verne, CA 91750

09-08-07 Civil Case Document Images – Document List

Civil Case Document Images


Document List

This site is best viewed using Internet Explorer 5 or higher.

Disclaimer:

The Los Angeles Superior Court and the County of Los Angeles declare that information
provided by and obtained from this site, intended for use on a case-by-case basis, does not
constitute the official record of the Court and cannot be used as evidence in Court.

Any user of the information and data is hereby advised that they are being provided "as-is"
without warranty of any kind, and that they may be subject to errors or omissions. To the
extent permitted by applicable law, the Los Angeles Superior Court disclaims all warranties,
including, without limitation, any implied warranties of merchantability, accuracy and fitness for
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Los Angeles Superior Court nor the County of Los Angeles is liable in any way whatsoever for
the accuracy or validity of the information provided.

Specific copyright and other proprietary rights may apply to information in a case file obtained
from this site, absent an express grant of additional rights by the holder of the copyright or
other proprietary right, use of such information is permissible only to the extent permitted by
law or court order, and any use inconsistent with proprietary rights is prohibited.

For questions or assistance, contact onlineServices@lasuperiorcourt.org.

Case Number: BC351286


Case Title: HAROLD P STURGEON VS LOS ANGELES COUNTY ET AL
Case Type: Injunct Relief-not Dom/Harrassmt (General Jurisdiction)
Filing Date: 4/24/2006

The following documents are available electronically.

Click on the corresponding checkbox to select a document to download. You may select up to
10 documents for each download.

Click on the "Submit" button to continue.

Nu
mb
er
Select Date Filed Document Cost
f

ATTACHMENTS & EHSIBITS 44


Joseph Zernik DMD PhD
Fax: (801) 998-0917 Email: jz12345@earthlink.net; PO Box 526, La Verne, CA 91750

09-08-09 Sturgeon v LA County et al (BC351286) – Available Document Images, and comparison


to Case Summary and other litigation records
Comments:

1. Table, columns #1-4 were copied from the Court’s web site – List of Available Images.

2. Google Chrome issued security warnings regarding the server – bearing false
verification certificate. Request for explanation forwarded to IT Executive Mr Klunder
and Clerk Clarke.

3. Columns #5 – gives reference to the record number of records copied in exhibit 1a


(Justice Richman’s rulings, orders, and respective minute orders).

4. Column #6 was added for comparison to data in the Case Summary record. Such
comparison immediately identifies the bias in Case Summary: Elimination of any
possible mention of Justice Richman and his actions in this case.

5. Given the large discrepancy and contradictions among litigation records that are open to
the public, one can only guess how far off the overt reality of the litigation, the covert
litigation records diverged.

Notes:

1. Image #73 (Document #2 in Exhibit 1a) January 9, 2007 Order Granting Summary
Judgment Motion- by Justice Richman.

2. Image #72, (Document #4 in Exhibit 1a) January 9, 2007 Minute Order in re: Court
Order Granting MSJ, issued by Clerk in dept 1- Martin Godderz for Justice
Richman. Concern was raised with Mr Drapac regarding the conduct of Mr Godderz,
since all minute orders that he issued for Judge Richman, failed to bear his name under
the signature line in certificate of mailing an notice of entry, making it of dubious validity.
Moreover, it requires further investigation, since it is likely to indicate operation of Sustain
relative to the issuance of Minute Orders for Justice Richman that was dishonest, and
may not be deemed valid by the court.

3. Image #71, (Document #1 in Exhibit 1a) January 16, 2007 Notice of Lodging
Proposed Judgment - appears as a false and misleading record. Similar to the
manipulation involving Att Keshavarzi in Samaan v Zernik (SC087400), the record
seems to confuse the Judgment and Order Granting Summary Judgment Motion. The
end-result is defective notice and entry of both the judgment and the order. It appears
highly unlikely that such was a naïve error.

4. Image #70, (Document #6 in Exhibit 1a) February 7, 2007 Minute Order in re:
Judgment, issued by Clerk in Dept 1 – Martin Godderz for Justice Richman. Same
concern as noted above, of a Minute Order of dubious validity, which may entirely
undermine the validity of the Judgment itself.

ATTACHMENTS & EHSIBITS 45


z Page 2/2 August 10, 2009

5. Image #69, (Document #5 in Exhibit 1a) February 7, 2007 Judgment by Justice


Richman. Concern, as noted above, is regarding the Minute Order that was supposed
to be the Certificate of Service.

6. Image #67, (Document #7 in Exhibit 1a) February 7, 2007 Notice of Entry of Order,
Justice Richman. Concern, as noted above, is regarding the appearance of confusion
between the Judgment and Order Granting MSJ. Here the Notice of Entry of Judgment
was referring to the Order, and likewise the Proof of Service for the Notice, making them
invalid.

7. Image #2, (Document #9 in Exhibit 1a) July 27, 2009, Order Granting Summary
Judgment, by Justice Richman. Concern, as noted above, is that the Case Summary
explicitly refutes that Justice Richman is assigned to the case.

8. Image #1, (Document #10 in Exhibit 1a) July 30, 2009, Minute Order in re: Order
Granting Summary Judgment, by Justice Richman. Concern, as noted above, is that
all minute orders issued by clerk Martin Godderz for Justice Richman may be deemed
defective.

In general, the concerns seen here were regarding repeat of the same
manipulations that were employed in Marina v LA County, in Galdjie v Darwish, and
in Samaan v Zernik. In all such cases the court generates judgments that were not
adequately entered. The advantage of such judgments is that while the court can
pretend to execute them, it deems them unappeasable, and so does the California
Court of Appeals, 2nd District. Regardless, under such circumstances, the California
Court of Appeal would pretend to hear an appeal or petition, but deny it. Examples
include the habeas Corpus petition of Att Richard Fine, 7 petitions filed by Dr Zernik,
and 2 appeals by Ms Barbara Darwish.

Case BC351286
Number:
Case Title: HAROLD P STURGEON VS LOS ANGELES COUNTY ET
AL
Case Type: Injunct Relief-not Dom/Harrassmt (General
Jurisdiction)
Filing Date: 4/24/2006

The following documents are available electronically.

1 2 3 4 5 6

# Date Document # Compared to


# of
Price Exh Case Summary
Pages
1a Data

1. 10 Actions of Justice Richman failed to


be listed as of Aug 6, 2009. The
information provided regarding
7/30/2009 MINUTE ORDER 3 $7.50
litigation history for July 30, 2009,
would most likely be deemed upon
review false and misleading data:

ATTACHMENTS & EHSIBITS 46


z Page 3/2 August 10, 2009

_______________________
07/30/2009 at 10:00 am in
Department 1, ELIHU M. BERLE,
Presiding
Ruling on Submitted Matter - Denied

2. 7/27/2009 ORDER 18 $8.06 09

3. Actions of Justice Richman failed to


be listed as of Aug 6, 2009.
The information provided regarding
litigation history for July 13, 2009,
would most likely be deemed upon
review false and misleading data:
________________________
07/13/2009 at 10:00 am in
7/13/2009 MINUTE ORDER 1 $7.50
Department 45, Reference Judge(not
case assignmt), Presiding
Motion for Summary Judgment -
Submitted
07/13/2009 at 08:30 am in
Department 1, ELIHU M. BERLE,
Presiding
Motion for Summary Judgment -
Transferred to different department

4. 7/13/2009 MINUTE ORDER 1 $7.50

5. 7/13/2009 MINUTE ORDER 1 $7.50

6. 7/10/2009 ORDER ON MEDIA REQUEST TO PERMIT COVERAGE 1 $7.50

7. Actions of Justice Richman failed to


be listed as of Aug 6, 2009.
The information provided regarding
litigation history for July 2, 2009,
would most likely be deemed upon
7/2/2009 MINUTE ORDER 1 $7.50 review false and misleading data:
_________________________
07/02/2009 at 10:00 am in
Department 1, Reference Judge(not
case assignment), Presiding
Motion for Summary Judgment
((THREE)) - Matter continued

8. 6/23/2009 MINUTE ORDER 3 $7.50

9. Actions of Justice Richman failed to


be listed as of Aug 6, 2009.
STIPULATION AND ORDER RESETTING HEARING DATE ON PARTIES _________________________
6/23/2009 5 $7.50 06/23/2009 Stipulation and Order
MOTIONS FOR SUMMARY JUDGMENT
(CONTINUING MSJ'S SET FOR 7/2/09
TO 7/13/09 )
Filed by Clerk

10. REPLY IN SUPPORT OF LOS ANGELES SUPERIOR COURTS MOTION


6/15/2009 11 $7.57
FOR SUMMARY JUDGMENT

11. DEFENDANTS REPLY BRIEF IN SUPPORT OF DEFENDANTS MOTION


6/15/2009 15 $7.85
FOR SUMMARY JUDGMENT

12. PLAINTIFFS REPLY TO DEFENDANTS OPPOSITION TO MOTION FOR


6/15/2009 8 $7.50
SUMMARY JUDGMENT

13. PLAINTIFFS REPLY TO INTERVENORS OPPOSITION TO MOTION FOR


6/15/2009 9 $7.50
SUMMARY JUDGMENT

14. DEFENDANTS MEMORANDUM OF POINTS AND AUTHORITIES IN


6/5/2009 19 $8.13
OPPOSITION TO PLAINTIFFS MOTION FOR SUMMARY JUDGMENT

15. PLAINTIFFS RESPONSE TO INTERVENORS SEPARATE STATEMENT


6/5/2009 OF UNDISPUTED FACTS; PLAINTIFFS STATEMENT OF ADDITIONAL 8 $7.50
MATERIAL FACTS

ATTACHMENTS & EHSIBITS 47


z Page 4/2 August 10, 2009

16. DEFENDANTS RESPONSE TO PLAINTIFFS SEPARATE STATEMENT


6/5/2009 OF UNDISPUTED MATERIAL FACTS IN SUPPORT OF PLAINTIFFS 6 $7.50
MOTION FOR SUMMARY JUDGMENT

17. PLAINTIFFS RESPONSE TO DEFENDANTS SEPARATE STATEMENT


6/5/2009 OF UNDISPUTED FACTS; PLAINTIFFS STATEMENT OF ADDITIONAL 10 $7.50
MATERIAL FACTS

18. DEFENDANTS RESPONSE TO PLAINTIFFS SEPARATE STATEMENT


6/5/2009 OF UNDISPUTED MATERIAL FACTS IN SUPPORT OF PLAINTIFFS 6 $7.50
MOTION FOR SUMMARY JUDGMENT

19. PLAINTIFFS OPPOSITION TO INTERVENORS MOTION FOR


6/5/2009 18 $8.06
SUMMARY JUDGMENT

20. PLAINTIFFS OPPOSITION TO DEFENDANTS MOTION FOR SUMMARY


6/5/2009 15 $7.85
JUDGMENT

21. DECLARATION OF PAUL J. ORFANEDES IN OPPOSITION TO


$12.1
6/5/2009 DEFENDANTS AND INTERVENORS MOTION FOR SUMMARY 76
2
JUDGMENT

22. INTERVENOR LOS ANGELES SUPERIOR COURTS SECOND REQUEST


6/5/2009 FOR JUDICIAL NOTICE IN OPPOSITION OF PLAINTIFFS MOTION 18 $8.06
FOR SUMMARY JUDGMENT

23. INTERVENOR LOS ANGELES SUPERIOR COURTS OPPOSITION TO


6/5/2009 18 $8.06
PLAINTIFFS MOTION FOR SUMMARY JUDGMENT

24. INTERVENOR LOS ANGELES SUPERIOR COURTS RESPONSE TO


6/5/2009 PLAINTIFFS SEPARATE STATEMENT OF UNDISPUTED MATERIAL 5 $7.50
FACTS IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT

25. DEFENDANTS NOTICE OF MOTION AND MOTION FOR SUMMARY


4/21/2009 3 $7.50
JUDGMENT

26. DEFENDANTS MEMORANDUM OF POINTS AND AUTHORITIES IN


4/21/2009 22 $8.34
SUPPORT OF MOTION FOR SUMMARY JUDGMENT

27. DEFENDANTS SEPARATE STATEMENT OF UNDISPUTED MATERIAL


4/21/2009 FACTS IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT OR, IN 6 $7.50
THE ALTERNATIVE, FOR SUMMARY ADJUDICATION

28. PLAINTIFFS MEMORANDUM OF POINTS AND AUTHORITIES IN


4/21/2009 22 $8.34
SUPPORT OF PLAINTIFFS MOTION FOR SUMMARY JUDGMENT

29. PLAINTIFFS SEPARATE STATEMENT OF UNDISPUTED MATERIAL


4/21/2009 FACTS IN SUPPORT OF PLAINTIFFS MOTION FOR SUMMARY 6 $7.50
JUDGMENT

30. PLAINTIFFS REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF $13.6


4/21/2009 98
PLAINTIFFS MOTION FOR SUMMARY JUDGMENT; ETC. 6

31. DECLARATION OF STERLING E. NORRIS IN SUPPORT OF


4/21/2009 11 $7.57
PLAINTIFFS MOTION FOR SUMMARY JUDGMENT

32. 4/21/2009 DEFENDANTS REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF


15 $7.85
MOTION FOR SUMMARY JUDGMENT

33. 4/21/2009 INTERVENOR LOS ANGELES SUPERIOR COURTS NOTICE OF


MOTION AND MOTION FOR SUMMARY JUDGMENT; MEMORANDUM 12 $7.64
OF POINTS AND AUTHORITIES IN SUPPORT OF MOTION

34. 4/21/2009 DECLARATION OF SERVICE 3 $7.50

35. PLAINTIFFS NOTICE OF MOTION AND MOTION TO STRIKE


4/8/2009 3 $7.50
INTERVENORS DEMAND FOR ATTORNEYS FEES

36. PLAINTIFFS MEMORANDUM OF POINTS AND AUTHORITIES IN


4/6/2009 8 $7.50
SUPPORT OF MOTION TO STRIKE INTERVENORS DEMAND FOR

ATTACHMENTS & EHSIBITS 48


z Page 5/2 August 10, 2009

ATTORNEYS FEES

37. 4/6/2009 PLAINTIFFS ANSWER TO COMPLAINT IN INTERVENTION 4 $7.50

38. STIPULATION REGARDING SCHEDULE FOR MOTIONS FOR


4/1/2009 3 $7.50
SUMMARY JUDGMENT; ORDER

39. 3/20/2009 DECLARATION OF SERVICE 3 $7.50

40. NOTICE OF INTENTION TO FILE A MOTION AND SEEK SANCTIONS


3/18/2009 UNDER CODE OF CIVIL PROCEDURE SECTION 128.5 AND 128.7 4 $7.50
AND TO CURE

41. ORDER GRANTING LOS ANGELES SUPERIOR COURTS MOTION FOR


3/13/2009 2 $7.50
LEAVE TO INTERVENE

42. 3/13/2009 COMPLAINT IN INTERVENTION 13 $7.71

43. 3/13/2009 MINUTE ORDER 3 $7.50

44. 3/10/2009 REMITTITUR 46


$10.0
2

45. 3/6/2009 MINUTE ORDER 1 $7.50

46. REPLY IN SUPPORT OF LOS ANGELES SUPERIOR COURTS MOTION


3/3/2009 18 $8.06
FOR LEAVE TO INTERVENE; ETC.

47. PLAINTIFFS MEMORANDUM OF POINTS AND AUTHORITIES IN


2/25/2009 24 $8.48
OPPOSITION TO MOTION TO INTERVENE

48. 2/10/2009 MINUTE ORDER 3 $7.50

49. DEFENDANT LOS ANGELES COUNTY’S REQUEST FOR STATUS


2/6/2009 6 $7.50
CONFERENCE

50. PLAINTIFFS MEMORANDUM OF POINTS AND AUTHORITIES IN


2/3/2009 SUPPORT OF PLAINTIFFS MOTION FOR A PRELIMINARY 7 $7.50
INJUNCTION

51. DECLARATION OF PAUL J. ORFANEDES IN SUPPORT OF PLAINTIFFS $10.7


2/3/2009 57
MOTION FOR A PRELIMINARY INJUNCTION 9

52. PLAINTIFFS NOTICE OF MOTION AND MOTION FOR A PRELIMINARY


2/3/2009 3 $7.50
INJUNCTION

53. CORRECTED MEMORANDUM OF POINTS AND AUTHORITIES IN


2/3/2009 7 $7.50
SUPPORT OF PLAINTIFFS MOTION FOR PRELIMINARY INJUNCTION

54. DECLARATION OF PAUL J. ORFANEDES ACCOMPANYING


2/3/2009 CORRECTED SUBMISSIONS FOR PLAINTIFFS MOTION FOR A 3 $7.50
PRELIMINARY INJUNCTION

55. 2/3/2009 PLAINTIFFS NOTICE OF FILING AMENDED PROOFS OF SERVICE 6 $7.50

56. DECLARATION OF KAHN A. SCOLNICK IN SUPPORT OF LOS $16.8


2/2/2009 144
ANGELES SUPERIOR COURTS MOTION FOR LEAVE IN INTERVENE 8

57. NOTICE OF MOTION AND MOTION FOR LEAVE TO INTERVENE;


2/2/2009 23 $8.41
ETC.

58. 1/15/2009 MEMO OF COSTS ON APPEAL 16 $7.92

59. 1/15/2009 MEMO OF COSTS ON APPEAL 14 $7.78


The November 7, 2008 Modification to the
The November 7, 2008 Modification to the Ruling of California Court
11/07/2008 Ruling of California Court of Appeals, 4th
of Appeals, 4th District, entirely failed to be mentioned
District, entirely failed to be mentioned.

The October 10, 2008 Ruling by California


The October 10, 2008 Ruling by California Court of Appeals, 4th
10/10/2008 Court of Appeals, 4th District, entirely failed
District, entirely failed to be listed with images of litigation records.
to be mentioned.

60. 6/12/2008 RESPONDENTS NOTICE OF OMISSION IN CLERKS TRANSCRIPT 31 $8.97

ATTACHMENTS & EHSIBITS 49


z Page 6/2 August 10, 2009

[CAL. RULES OF COURT, RULE 8.155(B)]

61. 5/23/2007 NOTICE TO PARTIES RE FEE FOR CLERK’S TRANSCRIPT ON APPEAL 2 $7.50

62. AMENDED NOTICE TO REPORTERS TO PREPARE TRANSCRIPT ON


3/16/2007 2 $7.50
APPEAL

63. 3/15/2007 NOTICE TO REPORTERS TO PREPARE TRANSCRIPT ON APPEAL 2 $7.50

64. RESPONDENTS DESIGNATION OF ADDITIONAL DOCUMENTS FOR


2/28/2007 3 $7.50
CLERKS TRANSCRIPT

65. 2/15/2007 NOTICE DESIGNATING RECORD ON APPEAL 5 $7.50

66. 2/8/2007 NOTICE TO ATTORNEY IN RE NOTICE OF APPEAL 1 $7.50

67. 07 Repeat of the misleading listing of


Notice of Entry of Judgment as
Notice of Entry of Order:
2/7/2007 NOTICE OF ENTRY OF ORDER 6 $7.50 ____________________________
02/07/2007 Notice (of entry of order)
Filed by Attorney for Defendant/
Respondent

68. 2/7/2007 NOTICE OF APPEAL 3 $7.50

69. 05 Again, actions by Justice Richman,


2/7/2007 JUDGMENT 3 $7.50 and with it the Judgment itself, fail to
be noted.

70. 06 No mention at all of the service by


2/7/2007 MINUTE ORDER 2 $7.50 Clerk Godderz of Justice Richman
actions.

71. 01 Action by Counsel is noted, but the


word Judgment, referring to action by
Justice Richman was deleted.
1/16/2007 NOTICE OF LODGING OF PROPOSED JUDGMENT 31 $8.97 ___________________________
01/16/2007 Notice of Lodging Filed
by Attorney for Defendant/Respondent

72. 04 Again, actions by Justice Richman,


1/9/2007 MINUTE ORDER 2 $7.50 and with it the Ruling on MSJ itself,
fail to be noted.

73. 02 Again, actions by Justice Richman,


1/9/2007 ORDER GRANTING MOTION FOR SUMMARY JUDGMENT 28 $8.76 and with it the Ruling on MSJ fail to
be noted.

74. 11/20/200
MINUTE ORDER 1 $7.50
6

75. DEFENDANTS REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF


11/13/200 $17.5
REPLY BRIEF IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT, 153
6 1
ETC.

76. DEFENDANTS REPLY BRIEF IN SUPPORT OF MOTION FOR


11/13/200
SUMMARY JUDGMENT OR, IN THE ALTERNATIVE, FOR SUMMARY 12 $7.64
6
ADJUDICATION

77. DEFENDANTS OBJECTIONS TO EVIDENCE SUBMITTED BY


11/13/200 PLAINTIFF IN SUPPORT OF HIS OPPOSITION TO DEFENDANTS
4 $7.50
6 MOTION FOR SUMMARY JUDGMENT OR, IN THE ALTERNATIVE,
FOR SUMMARY ADJUDICATION, AND [PROPOSED] RULINGS

78. DEFENDANTS RESPONSE TO PLAINTIFFS SEPARATE STATEMENT


11/13/200 OF OTHER MATERIAL FACTS SUBMITTED IN SUPPORT OF HIS
15 $7.85
6 OPPOSITION TO DEFENDANTS MOTION FOR SUMMARY JUDGMENT
OR, IN THE ALTERNATIVE, FOR SUMMARY ADJUDICATION

79. PLAINTIFFS RESPONSE TO DEFENDANTS SEPARATE STATEMENT


11/6/2006 OF UNDISPUTED MATERIAL FACTS AND SEPARATE STATEMENT OF 6 $7.50
OTHER MATERIAL FACTS

ATTACHMENTS & EHSIBITS 50


z Page 7/2 August 10, 2009

80. PLAINTIFFS MEMORANDUM OF POINTS AND AUTHORITIES IN


11/6/2006 OPPOSITION TO DEFENDANTS MOTION FOR SUMMARY JUDGMENT 25 $8.55
OR, ETC

81. PLAINTIFFS APPENDIX OF AUTHORITIES IN SUPPORT OF


$10.4
11/6/2006 OPPOSITION TO DEFENDANTS MOTION FOR SUMMARY JUDGMENT 52
4
OR, ETC

82. DECLARATION OF PAUL J. ORFANEDES IN SUPPORT OF PLAINTIFFS


$40.0
11/6/2006 OPPOSITION TO DEFENDANTS MOTION FOR SUMMARY JUDGMENT, 554
0
ETC

83. 10/20/200
MINUTE ORDER 1 $7.50
6

84. 10/20/200
ORDER GRANTING DEFENDANTS MOTION FOR PROTECTIVE ORDER 2 $7.50
6

85. 10/18/200
DEFENDANTS APPENDIX OF NON-CALIFORNIA AUTHORITY 9 $7.50
6

86. 10/18/200 DEFENDANTS NOTICE OF MOTION AND MOTION FOR PROTECTIVE


27 $8.69
6 ORDER

87. PLAINTIFFS MEMORANDUM OF POINTS AND AUTHORITIES IN


10/18/200 $28.0
OPPOSITION TO DEFENDANTS MOTION FOR PROTECTIVE ORDER, 303
6 1
ETC.

88. 10/13/200
MINUTE ORDER 1 $7.50
6

89. DEFENDANTS EX PARTE APPLICATION FOR ORDER SHORTENING


10/12/200
TIME ON HEARING FOR DEFENDANTS MOTION FOR PROTECTIVE 18 $8.06
6
ORDER, ETC.

90. DEFENDANTS MEMORANDUM OF POINTS AND AUTHORITIES IN


9/6/2006 SUPPORT OF MOTION FOR SUMMARY JUDGMENT OR, IN THE 22 $8.34
ALTERNATIVE, FOR SUMMARY ADJUDICATION

91. DEFENDANTS NOTICE OF MOTION AND MOTION FOR SUMMARY


9/6/2006 JUDGMENT OR, IN THE ALTERNATIVE, FOR SUMMARY 3 $7.50
ADJUDICATION

92. DEFENDANTS SEPARATE STATEMENT OF UNDISPUTED MATERIAL


9/6/2006 FACTS IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT OR, IN 3 $7.50
THE ALTERNATIVE, FOR SUMMARY ADJUDICATION

93. DEFENDANTS APPENDIX OF AUTHORITIES IN SUPPORT OF MOTION


9/6/2006 FOR SUMMARY JUDGMENT OR, IN THE ALTERNATIVE, FOR 32 $9.04
SUMMARY ADJUDICATION

94. 9/1/2006 MINUTE ORDER 2 $7.50

95. ORDER GRANTING VERIFIED APPLICATION OF PAUL J ORFANEDES


9/1/2006 1 $7.50
TO APPEAR AS COUNSEL PRO HAC VICE FOR PLAINTIFF

96. VERIFIED APPLICATION OF PAUL J. ORFANEDES TO APPEAR AS


8/23/2006 6 $7.50
COUNSEL; ETC.

97. STIPULATED BRIEFING AND HEARING SCHEDULE FOR


8/18/2006 DEFENDANTS MOTION FOR SUMMARY JUDGMENT OR IN THE 3 $7.50
ALTERNATIVE, FOR SUMMARY ADJUDICATION AND ORDER

98. 8/16/2006 MINUTE ORDER 3 $7.50

99. DEFENDANTS ANSWER TO PLAINTIFFS UNVERIFIED COMPLAINT


8/11/2006 4 $7.50
FOR DECLARATORY AND INJUNCTIVE RELIEF

100 7/14/2006 MINUTE ORDER 3 $7.50

101 7/14/2006 MINUTE ORDER 3 $7.50

ATTACHMENTS & EHSIBITS 51


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102 5/3/2006 NOTICE OF COURT ORDER RE OUT-OF-COUNTY TRANSFER 5 $7.50

103 5/1/2006 MINUTE ORDER 1 $7.50

104 5/1/2006 MINUTE ORDER 2 $7.50

105 5/1/2006 PROOF OF SERVICE SUMMONS 1 $7.50

106 5/1/2006 PROOF OF SERVICE SUMMONS 1 $7.50

107 5/1/2006 PROOF OF SERVICE SUMMONS 1 $7.50

108 5/1/2006 PROOF OF SERVICE SUMMONS 1 $7.50

109 5/1/2006 PROOF OF SERVICE SUMMONS 1 $7.50

110 5/1/2006 PROOF OF SERVICE SUMMONS 1 $7.50

111 5/1/2006 PROOF OF SERVICE SUMMONS 1 $7.50

112 5/1/2006 PROOF OF SERVICE SUMMONS 1 $7.50

113 4/27/2006 PROOF OF SERVICE OF SUMMONS 1 $7.50

114 4/24/2006 SUMMONS 2 $7.50

115 COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF;


4/24/2006 14 $7.78
DEMAND FOR JURY TRIAL

Only case documents that have been imaged are available for download from this web site.

ATTACHMENTS & EHSIBITS 52


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8
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EXHIBIT 1-c
28

INTERESTED PARTY JOSEPH H ZERNIK’S MOTIONS FOR MISTRIAL/SETTING ASIDE


Case No. BC351286
ATTACHMENTS & EHSIBITS 53
Joseph Zernik DMD PhD
Fax: (801) 998-0917 Email: jz12345@earthlink.net; PO Box 526, La Verne, CA 91750

00-00-00-
09-08-06 Case Summary – Sturgeon v LA County (BC351286)

Case Summary

Please make a note of the Case Number.

Click here to access document images for this case.


If this link fails, you may go to the Case Document Images site and search using the case number displayed
on this page.
Case Number: BC351286
HAROLD P STURGEON VS LOS ANGELES COUNTY ET AL
Filing Date: 04/24/2006
Case Type: Injunct Relief-not Dom/Harrassmt (General Jurisdiction)
Status: DO NOT USE-Trans to Sup Crt Oth Co 05/01/2006

Future Hearings
None

Documents Filed | Proceeding Information


Parties

ANTONOVICH MICHAEL D. - Defendant/Respondent

BOUTROUS THEODORE J. JR. ESQ. - Attorney for Intervenor

BURKE YVONNE B. - Defendant/Respondent

GONZALEZ LARRY - Defendant/Respondent

JANSSEN DAVID E. - Defendant/Respondent

JONES DAY - Attorney for Defendant/Respondent

KNABE DON - Defendant/Respondent

LOS ANGELES COUNTY - Defendant/Respondent

LOS ANGELES SUPERIOR COURT - Intervenor

LUI ELWOOD G. ESQ. - Attorney for Defendant/Respondent

MCCAULEY J. TYLER - Defendant/Respondent

MOLINA GLORIA - Defendant/Respondent

NORRIS STERLING E. ESQ. - Attorney for Plaintiff/Petitioner

STURGEON HAROLD P. - Plaintiff/Petitioner

ATTACHMENTS & EHSIBITS 54


z Page 2/2 August 6, 2009

YAROSLAVSKY ZEV - Defendant/Respondent

Case Information | Party Information | Proceeding Information


Please make a note of the Case Number.

Click here to access document images for this case.


If this link fails, you may go to the Case Document Images site and search using the case number displayed
on this page.

Documents Filed (Filing dates listed in descending order)

Click on any of the below link(s) to see documents filed on or before the date indicated:
02/28/2007

06/23/2009 Stipulation and Order (CONTINUING MSJ'S SET FOR 7/2/09 TO 7/13/09 )
Filed by Clerk

06/15/2009 Reply to Motion (REPLY IN SUPPORT OF LOS ANGELES SUPERIOR COURT'S MOTION FOR
SUMMARY JUDGMENT )
Filed by Attorney for Interveor

06/15/2009 Reply to Motion (REPLY TO INTERVENOR'S OPPOSITION TO MOTION FOR SUMMARY


JUDGMENT )
Filed by Attorney for Plaintiff/Petitioner

06/15/2009 Reply to Motion (REPLY TO DEFTS OPPOSITION TO MOTION FOR SUMMARY JUDGMENT )
Filed by Attorney for Plaintiff/Petitioner

06/15/2009 Brief-Reply (IN SUPPORT OF DEFTS MOTION FOR SUMMARY JUDGMENT )


Filed by Attorney for Defendant/Respondent

06/05/2009 Response (TO DEFTS SEPARATE STATEMENT OF UNDISPUTED FACTS; PLNTFS STATEMENT OF
ADDITIONAL MATERIAL FACTS )
Filed by Attorney for Plaintiff/Petitioner

06/05/2009 Declaration (OF PAUL J. ORFANEDES IN OPPOSITION TO DEFTS AND INTERVENOR'S MOTION
FOR SUMMARY JUDGMENT )
Filed by Attorney for Plaintiff/Petitioner

06/05/2009 Opposition Document (TO PLNTFS MOTION FOR SUMMARY JUDGT )


Filed by Attorney for Intervenor

06/05/2009 Opposition Document (TO DEFTS MOTION FOR SUMMARY JUDGT )


Filed by Attorney for Plaintiff/Petitioner

06/05/2009 Points and Authorities (IN OPPOSITION TO PLNTFS MOTION FOR SUMMARY JUDGMENT )
Filed by Attorney for Defendant/Respondent

06/05/2009 Response (TO INTERVENOR'S SEPARATE STATEMENT OF UNDISPUTED FACTS; PLNTFS


STATEMENT OF ADDITIONAL MATERIAL FACTS )
Filed by Attorney for Plaintiff/Petitioner

06/05/2009 Response (TO PLNTFS SEPARATE STATEMENT OF UNDISPUTED MATERIAL FACTS IN SUPPORT
OF MOTION FOR SUMMARY JUDGMENT )
Filed by Attorney for Interveor

06/05/2009 Opposition Document (TO INTERVENOR'S MOTION FOR SUMMARY JUDGMENT )

ATTACHMENTS & EHSIBITS 55


z Page 3/2 August 6, 2009

Filed by Attorney for Plaintiff/Petitioner

06/05/2009 Request for Judicial Notice (SECOND REQUEST FOR JUDICIAL NOTICE IN OPPOSITION OF
PLNTFS MOTION FOR SUMMARY JUDGMENT )
Filed by Attorney for Interveor

04/21/2009 Req for Special Notice (IN SUPPORT OF PLNTF'S MOTION FOR SUMMARY JUDGMENT )
Filed by Attorney for Plaintiff/Petitioner

04/21/2009 Statement of Facts (SEPARATE STATEMENT OF UNDISPUTED MATERIAL FACTS IN SUPPORT


OF PLNTF MOTION FOR SUMMARY JUDGMENT )
Filed by Attorney for Plaintiff/Petitioner

04/21/2009 Points and Authorities (IN SUPPORT OF PLNTFS MOTION FOR SUMMARY JUDGMENT )
Filed by Attorney for Plaintiff/Petitioner

04/21/2009 Motion to Strike


Filed by Attorney for Plaintiff/Petitioner

04/21/2009 Request for Judicial Notice (IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT )
Filed by Attorney for Defendant/Respondent

04/21/2009 Statement of Facts (SEPARATE STATEMENT OF UNDISPUTED MATERIAL FACTS IN SUPPORT


OF MOTION FOR SUMMARY JUDGMENT OR, IN THE ALT., SUMMARY ADJUDICATION )
Filed by Attorney for Defendant/Respondent

04/21/2009 Points and Authorities (IN SUPPORT OF MOTION FOR SUMMARY JUDGT )
Filed by Attorney for Defendant/Respondent

04/21/2009 Motion to Strike


Filed by Attorney for Defendant/Respondent

04/21/2009 Declaration (OF SERVICE )


Filed by Attorney for Intervenor

04/21/2009 Request for Judicial Notice (IN SUPPORT OF MOTION FOR SUMMARY JUDGT )
Filed by Attorney for Intervenor

04/21/2009 Statement of Facts (SEPARATE STATEMENT OF UNDISPUTED MATERIAL FACTS IN SUPPORT


OF MOTION FOR SUMMARY JUDGT )
Filed by Attorney for Intervenor

04/21/2009 Declaration (OF STERLING E. NORRIS IN SUPPORT OF PLNTF'S MOTION FOR SUMMARY
JUDGMENT )
Filed by Attorney for Plaintiff/Petitioner

04/12/2009 Motion for Summary Judgment


Filed by Attorney for Intervenor

04/06/2009 Points and Authorities


Filed by Attorney for Plaintiff/Petitioner

04/06/2009 Motion to Strike ( PLTF'S NOTICE OF MOTION AND MOTION TO STRIKE INTERVENOR'S
DEMAND FOR ATTY'S FEES )
Filed by Atty for Deft and Cross-Complnt

04/03/2009 Answer (TO COMPLAIT IN INTERVENTION )


Filed by Attorney for Plaintiff/Petitioner

ATTACHMENTS & EHSIBITS 56


z Page 4/2 August 6, 2009

04/01/2009 Stipulation and Order (STIPULATION REGARDING SCHEDULE FOR MOTIONS FOR SUMMARY
JUDGMENT AND ORDER FILED JOINTLY BY BOTH PARTIES)
Filed by Attorney for Deft/Respnt

03/20/2009 Declaration (of service )


Filed by Attorney for Intervenor

03/13/2009 Order (GRANTING LOS ANGELES SUPERIOR COURT'S MOTION FOR LEAVE TO INTERVENE )
Filed by Attorney for Intervenor

03/13/2009 Complaint in Intervention


Filed by Attorney for Intervenor

03/03/2009 Reply to Motion (REPLY IN SUPPORT OF LOS ANGELES SUPERIOR COURT'S MOTION FOR
LEAVE TO INTERVENE )
Filed by Attorney for Intervenor

02/25/2009 Points and Authorities (IN OPP. TO MOTION TO INTERVENE )


Filed by Attorney for Plaintiff/Petitioner

02/25/2009 Points and Authorities (in opposition to motion to intervene )


Filed by Attorney for Plaintiff/Petitioner

02/06/2009 Request (FOR STATUS CONFERENCE )


Filed by Attorney for Defendant/Respondent

02/03/2009 Notice of Filing (AMENDED PROOFS OF SERVICE )


Filed by Attorney for Plaintiff/Petitioner

02/03/2009 Declaration (OF PAUL J. ORFANEDES IN SUPPORT OF PLTFF'S MOTION FOR A PRELIMINARY
INJUNCTION )
Filed by Attorney for Plaintiff/Petitioner

02/03/2009 Notice of Motion (AND MOTION FOR A PRELIMINARY INJUNCTION )


Filed by Attorney for Plaintiff/Petitioner

02/03/2009 Declaration (OF PAUL J. ORFANEDES ACCOMPANYING CORRECTED SUBMISSIONS FOR PLTFF'S
MOTIONF OR PRELIMINARY INJUNCTION )
Filed by Attorney for Plaintiff/Petitioner

02/03/2009 Points and Authorities (MEMO OF POINTS & AUTHORITIES IN SUPPORT OF PLTFF'S MOTION
FOR A PRELIMINARY INJUNCTION )
Filed by Attorney for Plaintiff/Petitioner

02/03/2009 Points and Authorities (CORRECTED MEMORANDUM OF POINTS AND AUTHORITIES IN


SUPPORT OF PLTFF'S MOTION FOR A PRELIMINARY INJUNCTION )
Filed by Attorney for Plaintiff/Petitioner

02/02/2009 Notice of Motion (AND MOTION FOR LEAVE TO INTERVENE; MEMO OF P & As IN SUPPORT
THEREOF )
Filed by Attorney for Plaintiff/Petitioner

02/02/2009 Declaration (OF KAHN A. SCOLNICK IN SUPPORT OF LOS ANGELES SUPERIOR COURT'S
MOTION FOR LEAVE TO INTERVENE )
Filed by Attorney for Plaintiff/Petitioner

01/15/2009 Memo of Costs on Appeal ($2,290.48 OK PER ART ACEVEDO 3/5/09 COPY OF MEMO TO
SCANNING 3/5/09 (Done) )

ATTACHMENTS & EHSIBITS 57


z Page 5/2 August 6, 2009

Filed by Attorney for Pltf/Petnr

06/12/2008 Notice (NOTICE OF OMISSION IN CLERK'S TRANSCRIPT )


Filed by Attorney for Defendant/Respondent

05/23/2007 Notice ( Notice to Parties Re Fee for Clerk's Trans on Appeal )


Filed by Atty for Deft and Cross-Complnt

03/16/2007 Ntc to Reptr/Mon to Prep Transcrpt (AMENDED NTC )


Filed by Clerk

03/15/2007 Ntc to Reptr/Mon to Prep Transcrpt


Filed by Clerk

Click on any of the below link(s) to see documents filed on or before the date indicated:
TOP 02/28/2007

02/28/2007 Designation of Record on Appeal (DESIGNATION OF ADDITIONAL DOCUMENT S FOR CLERK'S


TRANSCIRPT )
Filed by Defendant

02/15/2007 Designation of Record on Appeal


Filed by Plaintiff

02/08/2007 Ntc to Atty re Notice of Appeal


Filed by Clerk

02/07/2007 Notice (of entry of order )


Filed by Attorney for Defendant/Respondent

02/07/2007 Notice of Appeal


Filed by Plaintiff

01/16/2007 Notice of Lodging


Filed by Attorney for Defendant/Respondent

11/13/2006 Brief-Reply (reply brief iso msj )


Filed by Attorney for Defendant/Respondent

11/13/2006 Response (response to pltf's separate statem ent of facts in opp to msj )
Filed by Attorney for Defendant/Respondent

11/13/2006 Request for Judicial Notice


Filed by Attorney for Defendant/Respondent

11/13/2006 Objection Document (obj. to evidence submitted by pltf iso opp to defendant's msj )
Filed by Attorney for Defendant/Respondent

11/06/2006 Response ( PLTF'S RESPONSE TO SEPARATE STATEMENT )


Filed by Attorney for Plaintiff/Petitioner

11/06/2006 Points and Authorities (IN OPP TO MSJ )


Filed by Attorney for Plaintiff/Petitioner

11/06/2006 Miscellaneous-Other (APPENDIX OF AUTHORITIES )


Filed by Attorney for Plaintiff/Petitioner

11/05/2006 Declaration (dec of PAUL J. ORFANEDES ISO OPP TO MSJ )


Filed by Attorney for Plaintiff/Petitioner

ATTACHMENTS & EHSIBITS 58


z Page 6/2 August 6, 2009

10/20/2006 Order (ORDER GRANTING DEFENDANTS' MOTION FOR PROTECTIVE ORDER REGARDING
DEPOSITION OF SUPERVISOR DON KNABE )
Filed by Judge

10/18/2006 Points and Authorities (in opp to mot/protective order )


Filed by Attorney for Plaintiff/Petitioner

09/06/2006 Miscellaneous-Other (APPENDIX OF AUTHORITIES IN SUPPORT OF MOTION FOR SUMMARY


JUDGMENT OR, IN THE ALTERNATIVE, FOR SUMMARY ADJUDICA )
Filed by Attorney for Defendant/Respondent

09/06/2006 Points and Authorities (MEMO OF P & A )


Filed by Attorney for Defendant/Respondent

09/06/2006 Statement of Facts (DEPTS' SEPARATE STATEMENT OF UNDISPUTED MATERIAL FACTS IN


SUPPORT OF MOTION FOR SJ )
Filed by Attorney for Defendant/Respondent

09/06/2006 Motion for Summary Judgment (FILED )


Filed by Attorney for Defendant/Respondent

09/01/2006 Order (ORDER GRANTING VERIFIED APPLICATION OF PAUL J. ORFANEDES TO APPEAR AS


COUNSEL PRO HAC VICE FOR PLAINTIFF; )
Filed by Judge

08/23/2006 Miscellaneous-Other (VERIFIED APPLICATION OF PAUL J ORFANEDES TO APPEAR AS COUNSEL


PRO HAC VICE FOR PLAINTIFF )
Filed by Attorney for Plaintiff/Petitioner

05/03/2006 Notice (OF COURT ORDER RE OUT-OF-COUNTY TRANSFER )


Filed by Attorney for Plaintiff/Petitioner

05/01/2006 Proof-Service/Summons (PARTY SERVED: GLORIA MOLINA )


Filed by Attorney for Plaintiff/Petitioner

05/01/2006 Proof-Service/Summons (PARTY SERVED: DAVID E. JANSSEN )


Filed by Attorney for Plaintiff/Petitioner

05/01/2006 Proof-Service/Summons (PARTY SERVED: DON KNABE )


Filed by Attorney for Plaintiff/Petitioner

05/01/2006 Proof-Service/Summons (PARTY SERVED: ZEV YAROSLAVSKY )


Filed by Attorney for Plaintiff/Petitioner

05/01/2006 Proof-Service/Summons (PARTY SERVED: YVONNE B. BURKE )


Filed by Attorney for Plaintiff/Petitioner

05/01/2006 Proof-Service/Summons (PARTY SERVED: LARRY GONZALEZ )


Filed by Attorney for Plaintiff/Petitioner

05/01/2006 Proof-Service/Summons (PARTY SERVED: J. TYLER MCCAULEY )


Filed by Attorney for Plaintiff/Petitioner

05/01/2006 Proof-Service/Summons (PARTY SERVED:MICHAEL D. ANTONOVICH )


Filed by Attorney for Plaintiff/Petitioner

04/27/2006 Proof-Service/Summons
Filed by Attorney for Plaintiff/Petitioner

ATTACHMENTS & EHSIBITS 59


z Page 7/2 August 6, 2009

04/24/2006 Complaint

Click on any of the below link(s) to see documents filed on or before the date indicated:
TOP 02/28/2007

Case Information | Party Information | Documents Filed


Proceedings Held (Proceeding dates listed in descending order)

07/30/2009 at 10:00 am in Department 1, ELIHU M. BERLE, Presiding


Ruling on Submitted Matter - Denied

07/13/2009 at 10:00 am in Department 45, Reference Judge(not case assignmt), Presiding


Motion for Summary Judgment - Submitted

07/13/2009 at 08:30 am in Department 1, ELIHU M. BERLE, Presiding


Motion for Summary Judgment - Transferred to different departmnt

07/02/2009 at 10:00 am in Department 1, Reference Judge(not case assignmt), Presiding


Motion for Summary Judgment ((THREE)) - Matter continued

03/13/2009 in Department 1, Reference Judge(not case assignmt), Presiding


Ruling on Submitted Matter (Justice James A. Richman) - Court makes order

03/06/2009 at 11:00 am in Department 1, Reference Judge(not case assignmt), Presiding


Motion (TO INTERVENE) - Case Taken Under Submission

02/10/2009 at 03:00 pm in Department OFFICE, ELIHU M. BERLE, Presiding


Telephonic Conference - Matter continued

02/07/2007 at 02:15 pm in Department 1, Lee Smalley Edmon, Presiding


Court Order - Completed

01/09/2007 at 10:45 am in Department 1, Lee Smalley Edmon, Presiding


Ruling on Submitted Matter - Granted

11/20/2006 at 08:30 am in Department 1, Charles W. McCoy, Presiding


Motion for Summary Judgment ((2) Further Status ConferenceC/F 10-18-06;To Be Heard by Justice James
A.Richman;) - Submitted

10/20/2006 at 11:00 am in Department 1, Charles W. McCoy, Presiding


Motion for Protective Order - Granted

10/13/2006 at 09:00 am in Department 1, Charles W. McCoy, Presiding


Ex Parte Motion - Granted

09/01/2006 at 04:00 pm in Department 1, Charles W. McCoy, Presiding


Court Order - Court's ruling and order entered

08/16/2006 at 03:30 pm in Department 1, Charles W. McCoy, Presiding


Court Order - Court makes order

07/14/2006 at 09:00 am in Department 1, RALPH W. DAU, Presiding


Telephonic Conference - Court makes order

07/13/2006 at 02:00 pm in Department 1, Reference Judge(not case assignmt), Presiding


Court Order - Court makes order

05/01/2006 at 10:45 am in Department 1, Charles W. McCoy, Presiding

ATTACHMENTS & EHSIBITS 60


z Page 8/2 August 6, 2009

Court Order - Transferred to different departmnt

05/01/2006 at 08:30 am in Department 45, Mel Red Recana, Presiding


Court Order - Completed

Case Information | Party Information | Documents Filed | Proceeding Information

ATTACHMENTS & EHSIBITS 61


1
2
3
4
5
6
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9
10
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Note for Exh 1-e:
18
Please notice items #12 and 13 on the following page,
19
which are copies of minute orders from an unrelated
20 case. Such minute orders are provided for comparison
with the minute orders generated by Mr Martin Godderz,
21
where the Certificate of mailing is deemed dishonestly
22 generated. JHZ
23
24
25
26
27
EXHIBIT 1-d
28

INTERESTED PARTY JOSEPH H ZERNIK’S MOTIONS FOR MISTRIAL/SETTING ASIDE


Case No. BC351286
ATTACHMENTS & EHSIBITS 62
Joseph Zernik DMD PhD
Fax: (801) 998-0917 Email: jz12345@earthlink.net; PO Box 526, La Verne, CA 91750

09-08-04 Minute Orders, Orders, Judgments from Justice James A Richman in Sturgeon v
County of Los Angeles

In this collection are minute orders, written orders, and judgments mailed by Justice
Richman to parties.
1. NOTICE of LODGING PROPOSED JUDGMENT --------------------------------- 2
a. Stamped FILED January 16, 2007,
b. by JONES DAY
2. ORDER GRANTING MSJ --------------------------------- 4
a. by Justice Richman's.
b. Above order executed by Justice Richman January 8, 2007 ---------- 31
3. POS of NOTICE OF LODGING OF PROPOSED JUDGMENT
a. By JONES DAY ------------- 32
4. Jan 9, 2007 MINUTE ORDER IN RE: COURT ORDER GRANTING MSJ
a. Order was issued this date.
b. Minute Order was presumably prepared by Martin Godderz,. Dept 1 (Judge
Berle), missing clerk’s name under the signature line ------------ 33
5. Feb 7, 2007 JUDGMENT. ------------------------------- 35
a. Above judgment verified by Justice Richman Feb 7, 2007 _______ 36
b. Jan 16, 2007 POS PROPOSED JUDGMENT ------------- 37
6. Feb 7, 2007 MINUTE ORDER RE: JUDGMENT
7. Feb 7, 2007 NOTICE OF ENTRY OF JUDGMENT---------------------------- 45
8. Feb 7, 2007 POS of NOTICE OF ENTRY OF ORDER --------------------- 46
a. JONES DAY
9. July 27, 2009 ORDER -------------- 47
a. Above order was verified by Justice Richman July 27, 2009 -------------- 63
10. July 30, 2009 MINUTE ORDER in re: RULING ON MSJ. ------------------------- 64
a. With defective certificate by clerk.
11. Divider page: Comparable Minute Orders from another case
12. Sept 20 MINUTE ORDER Samaan v Zernik ------------ 68
13. Oct 10-2007 MINUTE ORDER Samaan v Zernik ------------ 71

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