Council for Education

4625 West Nevo Drive Suite 2 & 3

Las Vegas, Nevada 89103
v. 800-307-1076 x 1| f. 877-459-7907
e. director@CforED.com
w. https://CforED.com

Sent via U.S. Mail

August 27, 2018 Diane Boyer-Vine,

Office of Legislative Counsel
State Capitol Building in Room 3021
Sacramento, CA 95814

Assembly Member Al Muratsuchi,

Chair of the Joint Legislative Audit Committee
Joint Legislative Audit Committee
1020 N Street, Room 107
Sacramento, California 95814

RE: NOTICE OF CIVIL TORT COMPLAINT

Dear Diane Boyer-Vine, Assembly Member Al Muratsuchi,

On January 24, 2018, Assemblymember Sharon Quirk‐Silva delivered a copy of the

Council for Education’s (CED) request letter for a state audit to the California Joint
Legislative Audit Committee (Committee). CED was requesting that the audit be done
for the purposes of providing greater oversight of the federal monies that were given
to the state of CA for Federal Student Aid programs. On February 26, 2018, the
Committee denied the CED’s request. JLAC’s failure to conduct the requested audit
harmed CED by prohibiting the Ninth Circuit Court of Appeals from reviewing public
records in support of the CED's federal lawsuit. See, CED v. IRS, 9th Cir. R. 42-1,
lead case No. 14-70825 (2014); member case No. 1456113 (Oct. 29, 2014, Dock. No.
10). The denial is an omission of public records in violation of Cal. Gov. Code § 910.

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(c) CED 2018| The Council for Education, ALL RIGHTS RESERVED
CED’s subscription members were damaged 1 in a civil action against the Regents of
0F

the University of California (Regents), and the Western Association of Schools and
Colleges, Senior Colleges and Universities (WSCUC) which totals more than
$20,000.

Sincerely,

_________________________
Council for Education (CED)
Director, Council for Education

1 See, Pickford v. Talbott, 225 U.S. 651 * 653 (1912), 32 S.Ct. 687, 56 L.Ed. 1240:
"The equitable jurisdiction is invoked upon the ground that after the conclusion of the
litigation at law the appellants discovered certain evidence which, if known at the
time, might and would have enabled them to make a different defense in the court of
law, and which it is alleged would assuredly have led to a different result there; it
being insisted that the appellants were not at fault in failing to discover the evidence
referred to."
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(c) CED 2018| The Council for Education, ALL RIGHTS RESERVED