Page|1 FORMAL COMPLAINT OFFICE OF THE CHIEF TRIAL CONSEL/INTAKE, STATE BAR OF CALIFORNIA 845 SOUTH FIGUEROA STREET, LOS ANGELES, CALIFORNIA 90017-2515 Name of Attorney: Sandra Bonds Hickey _State Bar No. 215031 Law Firm: LAW OFFICE OF SANDRA BONDS HICKEY 580 Beech Avenue Suite C Carlsbad, CA 92008 p. 760.729.2327 £. 760.720.1043 e-mail sandravblh@ gmail.com Location of Court: Superior Court of California San Diego Probate Division Ctrm. 502 Dates of Incident; July 18, 2017 through April 2018 Name of Case. IN RE; OF SALVADOR BEDOLLA VILLAGOMEZ Case No.: 37-2017-00026098-PR-LA-CTL INTRODUCTION ‘This Complaint is filed because I believed attorney Sandra Bonds Hickey engaged in an egregious pattern of misconduct that infringed the constitutional and statutory rights of our 84- year-old dementia mother Maria ‘Trinidad Villagomez de Bedolla, my sister Margarita Bedolla Frias and my brother Jesus Bedolla and my own rights in the above named action. These said acts by attomey Bonds Hickey were not isolated; rather, they reflected a disturbing and persistent pattern of conduct that is completely at odds with the standards the California rules of professional conduct expected of licensed attorneys in the State of California. The above named attorney, violated the American Bar Association rules of professional conduct; violations under Business and Professions Code; violations under California Rules of Professional Conduct; California Civil Rules of Procedure; Local Court rules; codes of conduct and ethics that are required guidelines for Members of the American Bar Association. The above named attorney’s actions were negligent, in bad faith, and violated public confidence in the integrity and impartiality of the judiciary process. The Board of Governors has the power to discipline members as provided by law for a willful breach of any of these rules. also filed a complaint against presiding Judge Robert Longstreth as well for his conduct with the State of California Judicial Committee for his own actions in the violations of basic constitutional rights, denial of access to the courts, violations of due process and access the court and denial of access to justice or be heard and present grievances. 1[PagePage |2 ‘The exhibits attached to this complaint will support our Complaint and the facts stated in this. complaint as true and correct as to the events and proceedings. Constitutional, statutory rights, access to the courts, access to due process under the laws and denial of access to justice. ‘Attorney Sandra Bonds Hickey engaged in communications with every single person who had knowledge of the case to advance unsound theories lacking facts and prejudiced the facts in the case in bad faith and complete disregard of standards expected of attorneys in California ‘The conduct and actions of attorney Sandra Bonds Hickey were intertwined with the actions of presiding officer Judge Robert Longstreth. Presiding Officer Judge Longstreth denied “Judicial Review” in writing of every single document my sister Margarita filed in the Probate Division. Presiding judge Longstreth felt that as long as he allowed the documents to be posted on the ROA it was enough to give the appearance of due process and access to justice. Presiding Officer Judge Longstreth further accepted requests by attorney Sandra Bonds Hickey not to allow my sister Margarita to submit any moving documents because my sister’s moving documents were full of case law, burdensome, harassment and oppressive, presiding officer said, “You don't really expect the poor attorney to read this stuff do you? Stop harassing the attorney with all this case law.” Attorney Sandra Bonds Hickey submitted flawed theories, untruths, fraudulent documents as facts and presiding officer judge Longstreth accepted her documents and arguments as truths, since the entire moving documents my sister submitted were denied “Judicial Reviews” and at open hearings presiding judge Longstreth would not allow my sister to speak at one hearing there were probably about 15-interruptions by judge Longstreth with the exact statement, “you are not an attorney and you don't know anything, you don’t know what you are doing because you are not an attorney. You don't know what you are talking about. We tried to explain this to you and beat you over the head with this but you just don't get it” looking, towards the direction of attorney Sandra Bonds Hickey.’ For months my sister was harassed by attorney Sandra Bonds Hickey, with threatening phone calls, and emails, false accusations, intimidation, constant threats of lawsuits against my sister and her favorite word, “sanetions.”® Both presiding officer judge Longstreth and attomey Sandra Bonds Hickey used the exact threats and even the exact words and phrases, and it was not legal language. Giving me the impression and certainty that attorney Sandra Bonds was in close private communications with the Probate Examiners, clerks, and possibly even judge Longstreth. ‘The mock or the trial that never took place was a confirmation of this.> * Rule 1-110 Disciplinary Authority of the State Bar ‘A member shall comply with conditions attached to public or private reprovals or other discipline ‘administered by the State Bar pursuant to Business and Professions Code sections 6077 and 6078 and rule 9.19, California Rules of Court. (Amended by order of the Supreme Court, operative July 11, 2008.) 2 Rule 5-220 Suppression of Evidence (Rule Approved by the Supreme Court, Effective May 1, 2017) ‘A member shall not suppress evidence that the member or the member's client has a legal obligation to reveal or to produce. * Rule 5-300 Contact With Officials (A) A member shall not directly or indirectly give or lend anything of value to a judge, official, or employee of a tribunal unless the personal or family relationship between the member and the judge, offical, or employee is such that gifts are customarily given and exchanged. Nothing contained in this, 2|PagePagels ‘Attorney Sandra Bonds Hickey threats were made through phone calls and emails presiding judge Longstreth stated that it was just attorney lingo but since my sister was not an attorney she did not know anything about attorney communications. Attomey Sandra Bonds accused my brother and sister of fraud and lies but there were no facts to support her accusations and the judge believed her accusations as true because Sandra Bonds Hickey was an attorney and my brother and sister were not attorneys.* Therefore, they had no right to appear before the court, no right to be heard and no right to speak at courtroom hearings and even at the mock trial that never took place. When my sister tried to open her mouth at hearings presiding judge Longstreth would threaten my sister with sanctions, sanctions and more sanctions, and more sanctions. rule shall prohibit a member from contributing to the campaign fund of a judge running for election or confirmation pursuant to applicable law pertaining to such contributions, (B) A member shall not directly or indirectly communicate with or argue to a judge or judicial officer ‘upon the merits of a contested matter pending before such judge or judicial officer, except: (1) In open court; or (2) With the consent of all other counsel in such matter; or (3) In the presence of all other counsel in such matter; or (4) In writing with a copy thereof furnished to such other counsel; or (5) In ex parte matters, (© As used in this rule, "judge" and "judicial officer” shall include law clerks, research attorneys, or other court personnel who participate in the decision-making process. (Amended by order of Supreme Court, operative September 14, 1992.) Rule 5-200 Trial Conduct In presenting a matter to a tribunal, a member: (A) Shall employ, for the purpose of maintaining the causes confided to the member such means only as are consistent with truth; (B) Shall not seck to mislead the judge, judicial officer, or jury by an artifice or false statement of fact or law; (C) Shall not intentionally misquote to a tribunal the language of a book, statute, or decision; (D) Shall not, knowing its invalidity, cite as authority a decision that has been overruled or a statute that has been repealed or declared unconstitutional; and (E) Shall not assert personal knowledge of the facts at issue, except when testifying as a witness. Under California law, an attorney may only use methods “as are consistent with truth, and never to seck to mislead the judge or any judicial officer by an artifice or false statement of fact or law.” Cal. Bus. & Prof. Code § 6068(4). “In presenting a matter to a tribunal, a member: (A) Shall employ, for the purpose cof maintaining the causes confided to the member such means only as are consistent with truth; (B) Shall not seek to mislead the judge, judicial officer, or jury by an artifice or false statement of face or law; C) Shall not intentionally misquote to a tribunal the language of a book, statute, or decision; (D) Shall not, knowing its invalidity, cite as authority a decision that has been repealed or declared unconstitutional.” California Rules of Professional Conduct, Rule 5-200 (1992). Barquis v. Merchants Collection Assn. (1972) 7 Cal.3d 94, 107. 101 Cal, Rptr. 745, 496 P.2d 817) “Misuse of the courts in this manner contributes to an undermining of confidence in the judiciary by reinforcing the unfortunate image of courts as distant entities, available only to wealthy ot large interests," and leads consumers "to conclude that the legal system is merely a ‘rubber stamp! for the improper practices utilized by predatory agencies.” (Barguis v. Merchants Collection Assn., supra, at p. 108.) 3|PagePagels Presiding Judge Longstreth further sanctioned my sister Margarita $ 15,000* dollars for asking, attorney Sandra Bonds Hickey for a copy of our mother Living Will and Complete Trust over 10-times through discovery. Afier the attomey denial of said document in violation of discovery rules my sister filed about four subpoenas which were ignored by attorney Sandra Bonds Hickey. My sister then filed the motion to compel a copy or our mother’s entire Trust that is when presiding judge Longstreth sanctioned her for bothering the attorney and asking for such discovery documents because he said they were not, “relevant” according to attorney Sandra Bonds Hickey objective argument, My sister asked for an itemized bill and attorney Sandra Bonds Hickey said she did not have to provide it, it was attomey client privilege. “About a week after my sister was sanction for asking for our mother’s entire Trust and her exhibits that proved her request was “relevant” but was denied judicial review. Attorney Sandra Bonds Hickey filed a trial brief with the exact same exhibits that were judicially denied review for my sister by judge Longstreth. ‘The documents became suddenly relevant when an “attorney” filed them. My sister made written objections and cited what was specifically wrong with each submission of exhibits by attorney Sandra bonds Hickey. So at the trial day of April 16, 2018 attorney Sandra Bonds Hickey shows up to court with mock folders of trial briefs. When asked for a copy of the trial brief to exchange with my sister's trial brief Attorney Sandra first denied she had a trial brief When the presiding officer judge Longstreth appeared she handed my sister over a folder that appeared to be a brief, Inside the folder were three exhibits two that were exactly the same and one that was partial with a lot of missing papers of what was presumed to be our mother’s Power of Attorney but lacked authentication, there were three different names no legal signature and not even notarized. Our mother who was scheduled as her only witness did not show up at the trial. She later added my sisters Alejandra and Graciela along with our brother Roberto. Presiding officer Longstreth presided for the trial, there was no trial not even an appearance of a trial, He spent a good 15-plus-minutes with nonstop harassment threats of more sanctions against my sister, and kept saying, “/ need to find a way to sanction you.” Which, | will go into detail and I will include the exhibits and ROA in this complaint. On April 19, 2018 I called the Probate San Diego Division 1100 Union Street to get a copy of the trial transcripts I was told there were no trial transcripts. I asked for an audio recording of the trial and I was told there are no audio recordings of such procedures. | find this shocking to the mind and void of any legal precedence or logic. There are documented complaints against Presiding Officer Robert Longstreth for his vitriolic behavior, conduct, bias, against pro per ‘women and he makes these emotions well known in his courtroom, Presiding Officer Judge Robert Longstreth uses pro se women as bate dogs® for attorneys like Sandra Bonds Hickey who have no trial experience in litigation or apparently unable to decode ‘case law and consistently relies on her close association with court personal. An attomey who does not rely on law and basic human rights and constitutionality but on lies, unsound theories 5 One for a motion to compel interrogatories that were answered two times with the same answer and no production of documents because Attomey Sandra Bonds was holding stolen documents relevant to the ccase. After he sign the order of around over $11,000 or so in sanctions. © With the exception that the bate dog in this case was legally blind and disabled. 4|PagePage|5 not supported by law or logic, bully tactics, threats, intimidation, harassment and her favorite words are “I am going to sue you” and “I am going to sanction you.” Based on our personal experience in Judge Longstreth courtroom we believe and declare that neither attorney Sandra Bonds Hickey nor Judge Longstreth follow the spirit or intent of the law and the Judiciary Code of Conduct and Ethics and the American Bar Association Rules of Professional Conduct. Presiding officer judge Longstreth did not maintain professional competence in judicial administration, Judge Longstreth did not cooperate with other judges and court officials in the administration of court business. Instead judge Longstreth criticized Hon. Judge Harry Powasek for granting judicial review of our 2010 case which ruling was relevant to this case. Judge Longstreth stated, “Judge Powasek made a bad decision in allowing you to proceed, I would not have done that. We in this court have an understanding with the other judges, judge Kelety and Judge Bostwik we are all on the same page on this one."” Fle was referring to not allowing pro se’s access to the courts or meaningful review of documents.* Further, judge Longstreth stated that attomey Sandra Bonds Hickey worked for him [attorney Bonds Hickey was not a court appointed attorney she was our brother's personal David attorney] and so did all of the examiners and clerks, they all worked for him. Presiding Officer Judge Longstreth actions were negligent, in bad faith, and violated public confidence in the integrity and impartiality of the judiciary. Based on the fact that | [Silvia Bedolla Peters] was refused the transcripts of the trial proceedings by Judge Longstreth Probate staff. I do declare, that the account of the events is true and correct to the best of my recollections. The exhibits attached to this complaint will support my Complaint and the facts stated in this complaint as true and correct as to the event and proceedings 7 The fundamental rights to be heard were trampled by the hearing procedures employed. “4 litigant in civil proceedings is entitled 10 a fair hearing, imbued with the protections of due process.” See A.B. v. Y.Z., 184 NJ. 599, 604 (2005); ILESS. v. J.CS., 175 N.J. 309, 321-23 (2003). “The due process guarantee expressed in the Fourteenth Amendment to the United States Constitution requires assurance of fundamental fairness during legal proceedings. U.S. Const. amend. XIV, § 1. This includes the ‘opportunity to be heard and requires “procedural safeguards including the right to cross-examine adverse witnesses and the right to call witnesses”... .” Peterson v. Peterson, 374 N.J. Super. 116, 124 (App. Div. 2005) ‘The Fourteenth Amendment to the U.S. Constitution provides that [n]o state shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States; nor shall any State deprive any person of life, liberty, or property, without due process of law; nor deny to any person within its jurisdiction the equal protection of the laws. © My sister Margarita Bedolla Frias had a right to self-representation that was trampled upon in judge Robert Longstreth courtroom, Section 35 of the Judiciary Act of 1789, 1 Stat. 73, 92, enacted by the First Congress and signed by President Washington one day before the Sixth Amendment [422 U.S. 806, 813]. That right is codified in 28 U.S.C. 1654. Bounds v. Smith (430 U.S. 817, the 1977; (430 US. 817, the 1977; Ex Parte Hull, 312 U.S. 546, (1941); Burns v. Ohio, 360 U.S, 708 (1961) 5|PagePage |6 Fundamental human rights are violated and recorded often in the San Diego Family Court and Probate Court but these complaints fall on deaf ears. Not having tape recordings and transcriptionist to record the hearings or trials at a courtroom only gives judges the freedom to abuse pro per litigants, threaten them, sanction them and doctor the record on the minute orders. This Complaint is not only against judge Longstreth, attomey Sandra Bonds Hickey but also the untrained and or badly trained employees be Examiners, clerks, and personal who consistently mistreat self-represented litigants, are biased, personal who witness the abusive practices by judicial officers and remain silent. These court clerks and examiners don’t believe pro per persons are human being with basic constitutional rights and view pro per’s are only burdensome to society. ? HISTORY AND EVENTS THAT LEAD TO THIS COMPLAINT Our father David Lemus Bedolla and mother Maria Trinidad Villagomez de Bedolla were married for 58-years. Together they had 9-biological children Salvador being our oldest brother who purchased a home located at 918 Emma Drive Cardiff CA in 1974. On the Deed of Trust Salvador added our mother and father as, “Joint Tenants.” In 1994 the home was refinanced and the Deed of Trust maintained the same names as, “Joint Tenants.” Our father died on February 2010 after his death we found out that our youngest sister Alejandra Bedolla had created an illegal trust in which she gifted our father’s 1/3 according to her of the Emma Drive property to herself. All relevant documents are filed and Honorable judge Harry L. Powasek found that my sister’s Alejandra’s documents were not valid CASE No-: 37-2010-00150342-PR-TR-NC filed on July 15, 2010. Based on Probate 48 we were all heirs but our mother had first rights per California marriage code right of survivorship. 5 US. CONST. amend. XIV § 1; see also Mathews v. Eldridge, 424 US, 319, 332 (1976) (“Procedural due process imposes constraints on governmental decisions which deprive individuals of ‘liberty’ or “property” interests within the meaning of the Due Process Clause of the Fifth or Fourteenth ‘Amendment.”). The Due Process Clause is derived from the Magna Carta, which read in relevant part: “No freemen shall be taken and imprisoned or diseased or exiled or in any way destroyed, nor will we go upon him nor send upon him, except by the lawful judgment of his peers or by the law of the land.” MAGNA CARTA, § XXXIX (1215), available at http://www.constitution.org/eng/magnacar htm; see also Bank of Columbia v. Okely, 17 U.S. (4 Wheat.) 235, 244 (1819) See, e-g., Prater v. City of Burnside, Ky., 289 F.3d 417, 431 (6th Cir, 2002) (“This Clause clothes individuals with the right to both substantive and procedural due process.") (citation omitted). 19 See Fieger v. Ferry, No. 04-60089, 2007 U.S, Dist, LEXIS 71274, at *16-18 (E,D. Mich, Sept. 26, 2007) (The Due Process Clause provides three types of protections.”); see also Daniels v. Williams, 474 U.S. 327, 337 (1986) (Stevens, J., concurring) (“[T]he Due Process Clause of the Fourteenth Amendment . is the source of three different kinds of constitutional protection.”). 20 This is the rationale behind § 1983 claims. See Zinermon v. Burch, 494 U.S, 113, 125 (1990) (“First, the [Due Process] Clause incorporates many of the specific protections defined in the Bill of Rights.”). 21 1d. (quoting Daniels v. Williams, 474 U.S. 327, 331 (1986)). This substantive guarantee extends to many areas of law. See, €.g., Griswold. Connecticut, 381 U.S, 479, 484 (1965) (privacy); Meyer v. Nebraska, 262 U.S, 390, 392 (1923) (education in foreign languages). 22 See, g,, Mathews, 424 U.S. at 332 (explaining that procedural due process prevents government from freely depriving individuals of liberty of property). 6iPagePagel? Our brother Salvador suddenly died on May 27, 2017 and so two of the legal, “Joint Tenants” have died leaving our 84-year old mother Maria Trinidad Villagomez de Bedolla as the sole survivor of the Joint Tenancy. The entire case law and legality of the Joint Tenancy, right to survivorship and California marital property was litigated for over a year and a half in the above ‘mentioned case. ‘There was an extensive Summary Judgment Ruling in our favor with all the case law included. Alejandra was not a legal owner of the above mentioned property. [At this point we believed the issue was settled but my sister Alejandra took out a $60,000 Rider ‘against the property and she placed her name on some phony applications she did with Wells Fargo. On December 31, 2012 Alejandra went to Wells Fargo and basically filed an application to take out a second on the property. She put herself as, “a Joint Tenant” on the application for ‘SIXTY-THOUSAND-DOLLARS ($60,000) plus interest. She took Salvador and our mother to file the application for the second loan on the property and finally our mother signed the second ‘on the loan while she was incapacitated with dementia ‘There was a recording requested by Wells Fargo Document Number 2013-0011976 of a Full Reconveyance WF Home Equity # 68204221181998. “BEDOLLA” On September 22, 2016 there was a Full Reconveyance document # 2016-0503174 for a “ull Reconveyance title going back to American Security Company as present trustee, DAVID ‘LEMUS BEDOLLA and TRINIDAD VILLAGOMEZ BEDOLLA HUSBAND AND WIFE and SALVADOR VILLAGOMRZ BEDOLLA a single man, ALL AS JOINT TENANTS as trustor ‘and recorded on 2/11/1994 as Instrument Document No. 1994-009738, Book N/A, Page 1875, of the Official Records in the Office of the County Recorder of San Diego County, California having been requested in writing by the beneficiary of the obligation secured by said Deed of Trust, to reconvey the estate granted to Trustee under said Deed of Trust, does hereby, recovery of the person or persons legally entitled thereto, without warranty all the estate, title and interest acquired by the trustee under said Deed of Trust.” AMERICAN SECURITIES COMPANY JAGRUTIK. SHAH Vice President Loan Documentation.” After the death of our brother Salvador we consulted at least five well known and respected attorney who said that there was no need for probate and one attorney said, “Let me look at the ‘San Diego County Assessor's Office and do a title search into the Cardiff property. He called back the next day and verified what the other attomeys had said that there was no need to do anything at the courts but rather to take the death certificates and have our mother remove the names of our father and brother. He also suggested we hire a title company and clear title. Our brother David took our mother’s Trust without her consent and went to see attorney Sandra Bonds Hickey who told him that the property was not under Joint Tenancy that there was a broken chain link and consistently presented to the court flawed deeds of trusts filed by our sister Alejandra as true deeds with the Probate Court as evidence to support her broken chain link theory. Even though the deeds attorney Sandra Bonds filed in the court read at the bottom with TIPagePage|8 large bold capitalized letters", “THIS DEED IS PREPARED WITHOUT TITLE EXAMINATION”. ‘The deeds submitted by attomey Sandra Bonds Hickey were found to be fraudulent, not just by the San Diego Probate Court in 2010 but by an investigation from Wells Fargo and documented in the San Diego County Assessor's Office. It would lead a reasonable person to ask are. fraudulent deeds valid? Attorney Sandra Bonds Hickey believed that they were and wrote on her trial brief and all moving documents they were valid when all evidence pointed to the contrary. ‘Was David's Petition to Administer the Estate of Salvador flawed and premature? Since our ‘mother was the only survivor of the Joint Tenancy and our brother was never married and never had any children, ‘Yes, Salvador along with our mother Maria and our late father were all, “Joint Tenants” in the 918 Emma Drive property. Petitioner David has always known they have been Joint Tenants and the property was and has always been titled under “Joint Tenancy.” So if the 918 Emma Drive property is held under Joint Tenancy why did Petitioner and his attorney file this Petition? The facts are that the decedent's Salvador [and late father’s] 918 Emma Drive property would be passed on to Maria our mother not just as the next of kin but through “Joint Tenancy”. The principal characteristic of a joint tenancy is the right of survivorship. (Estare of Propst (1990) SO Cal.3d 448, 455.) When one joint tenant dies, the entire estate automatically belongs to the other tenant. (Grothe v. Cortlandt Corp. (1992) 11 Cal.App.4th 1313, 1317.) The right of survivorship is an interest that exists from the moment the joint tenancy is created. (Rupp v. Kahn (1966) 246 Cal.App.2d 188, 196.) So the essence of the entire proceedings were basically that the issue was not ripe for probate because our 84-year-old mother is still alive and is the only survivor of this Joint Tenancy and that the property would automatically be passed on to her. ‘The jurisdiction belonged to the ‘County Assessor's Office and the Title Company without any facts, assessment and final title investigations the court lacks jurisdiction over this matter. Therefore, at this time the court lacked jurisdiction and subject matter jurisdiction. Presiding officer judge Longstreth denied judicial review all of the relevant documents that were submitted by my sister Margarita Bedolla Frias. In fact he denied review of all documents submitted by my sister Margarita and accepted all the flawed documents submitted by attorney Sandra Bonds Hickey. ‘At the March 23 motion to compel hearing attorney Sandra Bonds Hickey asked for about $15,000 in sanctions against my sister Margarita because Margarita asked for a copy of our mother’s Living Trust that attorney Sandra was legally required to provide in discovery but refused to do so.'' The Tentative Ruling states the requests for Judicial Notice (ROA 134) are 1 There are a lot of these deeds filed with the County Assessor's Office by Alejandra, She knows they are illegal but she keeps filing them. The only person who believes are legal is attorney Sandra Bonds Hickey and judge Longstreth without any judicial review but takes her word for it because she is an attomey and works for him, © Rule 5-220 Suppression of Evidence (Rule Approved by the Supreme Court, Effective May 1, 2017) BIPagePage|® denied as the matter therein are either not judicially noticeable or are irrelevant. Citing (Evidence Code Section 452; People v. Townsel (2016) 63 Cal. 4" 25, 42, fn 2,). Sanctions were granted by judge Longstreth, The court cited People v. Townsel to support the sanctions. The entire case of People v. Townsel is about a prisoner Townse! with an 1Q of 59 and 66 being tried for murder “A person cannot be tried or adjudged to punishment while mentally incompetent."(§ 1367, subd. (a).) A defendant is mentally incompetent if, as a result of a mental disorder or developmental disability, he or she is unable 10 understand the nature of the criminal proceedings or to assist counsel in the conduct ofa defense in a rational manner. (Ibid.)'| (People v. Koontz (2002) 27 Cal.4th 1041, 1063) — Both the due process clause of the Fourteenth Amendment to the United States Constitution and state law require a trial judge to suspend proceedings and conduct a competency hearing whenever the court is presented with substantial evidence of incompetence, that is, evidence that raises a reasonable or bona fide doubt concerning the defendant's competence to stand trial.'| (People v. Halvorsen (2007) 42 Cal.4th 379, 401; see also § 1368, subds. (a), (b); People ¥. Pennington (1967) 6 Cal.2d 508, 518,)” In a competency trial, —[ilf i is suspected the defendant ts developmentally disabled, the court shall appoint the director of the regional center {for the developmentally disabled... 0 examine the defendant.\ (§ 1369, subd. (a).)[63 Cal.4th 377722 Well, the Judicial Officer Longstreth court did not apply its own advice that of the quotation of Townsel above because our mother was on the witness list as the only witness on behalf of attomey Sandra Bonds client my brother David Bedolla. Our mother has dementia and there was no competency hearing to determine if she was able to testify at trial. Attorney Sandra Bonds Hickey said on multiple times when this issue came up in oral hearings or writings on file in the Probate court. Attorney Sandra Bonds Hickey said, “She is competent” at the March 23° hearing and the judge Longstreth looked at my sister and said, “She is competent.” Whereby my sister submitted a lot of evidence stating otherwise. Our sister asked that the court appoint an attorney to represent our mother since her property is in jeopardy through the churning of billable hours and she is on Medical and SSI and cannot afford to pay second’s or leans on the property and she does not speak English cannot read or write English or Spanish and is 100% percent dependent. The court denied my sister’s request each and every time and said that our ‘A member shall not suppress evidence that the member or the member's client has a legal obligation to reveal or to produce. *2 The Fourteenth Amendment to the United States Constitution prohibits a state from depriving any person of property without due process of law. fn. 3 This mandate has been interpreted to require, at a ‘minimum, that “absent a countervailing state interest of overriding significance, persons forced to settle their claims of right and duty through the judicial process must be given a meaningful opportunity to be heard." (Boddie v. Connecticut (1971) supra, 401 U.S. at p. 377 [28 L.Ed.2d at pp. 118-119].) Thus, the United States Supreme Court has long recognized a constitutional right of access to the courts for all persons, including prisoners. (Procunier v. Martinez (1974) 416 U.S. 396, 419 [40 L. Ed, 2d 224, 243, 94 S. Ct 1800]; Cruz v. Beto (1972) 405 U.S. 319, 321 [31 L. Ed. 2d 263, 267-268, 92 S. Ct. 1079]; Johnson vy. Avery (1969) 393 U.S. 483, 487 [21 L. Ed. 2d 718, 722, 89 S, Ct. 747]; Price v, Johnston (1948) 334 USS. 266 [92 L. Ed. 1356, 68 S. Ct, 1049].) oIPagePage |10 mother can make that petition herself. This was not physically, mentally or in any way shape or form possible our mother could not do so with the advanced dementia and all other matters. The court did not review Margarita’s Judicial Notices with the exhibits attached and the citation of People v. Townsel cited by the court is relevant to the issue of our 84-year-old mother who does not have the capacity to make decisions, sign contracts, convey real estate properties, care for herself, does not have the mental capacity to make decisions, cannot read or write either English or Spanish and needs someone to care for her 24/7. Yet attomey Sandra Bonds claimed ‘our mother signed the Waver of Bond for our brother. Why didn’t our brother David who is also ‘on Medical and Disability sign his own Waver of Bond and put his own house on the table? So the person who should be having an attorney to protect her property is our mother however it is our brother who has been involved in a scheme to take the properties in Mexico belonging to or late brother by fraud who secures himself and attorney and a Waver of Bond presumably signed by our mother who does not have the capacity to sign such document. So how did our brother David Bedolla who is on state disability and Medical secure himself an attorney like Sandra Bonds Hickey? Very simple to explain, attorney Sandra Bonds Hickey saw an illiterate greedy 62-year-old man and an 84-year-old-women with a Beach Property Estate and she saw a whole lot of $8SS. ‘The Tentative Ruling states on page 1, “In order to prevail in a motion to compel, the moving ‘party must establish that the matter sought is relevant to the subject matter involved in the ‘pending action or to the determination of any motion made in the action or to the determination ‘of any motion made in that action, and that the matter either is itself admissible in evidence or appears reasonably calculated to lead to the discovery of admissible evidence (CCP section 2017.010.)" First the Tentative Ruling states that Margarita’s Judicial Notice (ROA 134) is denied as the matter therein are either not judicially noticeable or are irrelevant. Margarita submitted these Exhibits in her Judicial Notice to establish RELEVANCE and to reply to the opposition by David who brought out the issue of RELEVANCE. So it would have not been impossible to establish relevance if the court will not review the document she filed in this court. ‘Yet, when Margarita submitted her memorandum and Judicial Notices with Exhibits the court decline to review them in violation of her due process rights.'® The Courts Tentative Ruling citation of Department of Forestry to support sanctions against Margarita and denial of review of her moving documents filed in court violates her Due Process Clause and denied her access to the court under the US Constitution and California Constitution, In the Department of Forestry case its states, “For, ifa plaintiff's case is dismissed without due process, that party's right of access to the courts is infringed. (See generally Payne v. Superior %3 (Lee v. Placer Title Co. (1994 ) 28 Cal. App.4th 503, $10; see Cordova v. Vons Grocery Co. (1987) 196 Cal. App.3d 1526, 1531; see also Wilson v. Sunshine Meat & Liquor Co. (1983) 34 Cal.3d 554, 561, fn. 7.) Citations from Department of Forestry Page 18 10|PagePage|" Court (1976) 17 Cal.3d 908, 914,)” In this case Margarita’s due process rights have been infringed and denial of access to the court when the ROA were filed but not reviewed. Further the court states in its analysis, “A party may obtain discovery regarding any matter, not privileged, that is relevant to the subject matter involved in the pending action or to the determination of any motion made in the action.” Yet, when Margarita submitted her ‘memorandum and Judicial Notices with Exhibits the court decline to review them in violation of her due process rights then sanctioned her on or about $15,000 on the April 23° motion hearing. ‘At the hearing presiding judge Longstreth kept pointing out the fact that he could not read the date on a subpoena when the date was clear there where so many errors clerical errors by both the court and attorney Bonds Hickey but he accepted them and he kept saying over and over to iy sister, “you don't know anything, you are not qualified and you are not an attorney, you need 10 get yourself an attorney because you know nothing, you don’t understand anything.” ‘At the March 23" hearing judge Longstreth must have told my sister Margarita that she was not attorney and she did not know anything over and over and when my sister tried to say something. or tried to make any legal citation judge Longstreth would say, “You don’t want to go there! You don't want to go there! Do you want to go there? You are not an attorney, we tried to beat you ‘over and over the head with this, don’t you get it you are not an attorney. You don’t know ‘anything you just don't understand,” Judge Longstreth said, “all right Iam ready to make my decision now.” My brother Jesus asked Judge Longstreth, “You are not going to make a decision now at a motion hearing are you?” “Judge asked what do you want to do?” Jesus answered, “/ want to make a motion to stay so that I can get an attorney. ” Judge Longstreth became angry and said, “What? Why do you want a motion to stay do you even know what it means?” My brother Jesus said, “7 want fo go to trial.” Judge Longstreth was very angry and asked attorney Sandra Bonds Hickey, “how long do you think the trial is going 10 take?” ‘Attorney answered, “I don't think it’s going to take more than an hour.” Judge Longstreth sarcastically said, “/t's going to take me less than 15-minutes to make a ruling.” ‘The minute orders are not a true reflection or what actually happened in the courtroom or facts in submission and a lot of this stuff in the minute orders did not take place. Like presiding judge Longstreth stated that Margarita and Jesus my brother presented a motion to stay proceedings so that he could go get an attorney. There was no motion before the court on March 23" and no motion to stay proceedings was scheduled or denied on that day. ROA 175 and ROA 172 there were minute orders on a “Court Trial” when no court trial ever took place. Most of the rulings ‘and minute orders were doctored to support the documents that were filed by Sandra Bonds Hickey. There was zero judicial review of documents submitted by my sister Margarita. Our mother 84-year-old never consented to these proceedings and she never had an attomey to represent her in the unnecessary churning of billable hours against her property without her prior consent, W1PagePage |12 THE MOCK TRIAL OF APRIL 16, 2018 When we arrived at court attorney Sandra Bonds Hickey said, so are you guys ready to concede? Are you ready to concede? My brother Jesus said, “/ am ready for this to be over today I am ready for the trial.” Attorney Sandra Bonds Hickey had added three additional witness names our brother Roberto who showed up wearing jeans, our sister Grace who worked for the San Diego Court for over 30-years who showed up wearing her Pj's. Our sister Alejandra did not show up and either did our mother. My sister Margarita had a trial brief ready for attorney Sandra Bonds Hickey and I asked her if she had a tral brief for my sister and she said she did not and she did not have to give my sister one. ‘After I serve her with the Trial Brief for my sister attorney Sandra Bonds Hickey asked my brother and sister to go outside. While they were outside she was really laud and the conversation could be overheard inside the courtroom. Attorney Sandra Bonds Hickey said, “This is very serious you guys are in big trouble if we tried to admit your mom's medical files. Do you know what HIPPAA means... [Medical records were filed under seal that proved mom has dementia] you don't know that if we put this in court it will be public record and she is going 1o come afier you and sue you and you are in deep trouble. My brother Jesus said, “Sandra you put exhibit documents that were incomplete you put documents that are cropped up and pasted together with pages missing to confirm your view ‘point of what you think it is.” She denied it and Jesus said, “! don't see David's signature on ‘anything or even notarized” and she said, “He has not accepted yet.” So Jesus asked, “Sandra, “why is he acting as my mom's power of attorney?” Sandra said, “Oh well he can say, he can do it anytime he wants to.” Not true Jesus submitted signed documents to accept to be our mother’s Trustee in 2009 not Jonny come lately David with phony doctored documents and stolen sections of our mother’s Trust. Attomey Sandra submitting stolen documents as exhibits. ‘Attorney Sandra Bonds Hickey kept blaming my sister Margarita and Jesus for the proceedings at this point Jesus said, “Your client is the one who started this we had an agreement before he started this we sat together at Starbucks and discussed how to take care of mom and since my name was on moms Trust as Trustee and Executor David and I agreed that we would make decisions together then he went out and got an attorney and changed his phone manber.” Attorney Sandra Bonds Hickey said, “You missed the facts. Silvia was the one who advised him 10 get an attorney.” Jesus answered, “No I don't care what Silvia has to say, I was there and you were not so you cannot tell me what happened, because I was there!” ‘Attorney Sandra Bonds Hickey said, “Your mom is coherent.” Jesus response, “no she is not I go there once a week and I can tell you that she is not don't stand there and say that she cannot remember anything past 15-minutes.” Sandra says, “Your mom was ok a year ago she was coherent when she signed the Waver of Bond, I do this for a living, I can ‘ell you when someone is competent and when they are not.” Jesus said, “You are not a medical doctor Sandra.” Sandra said, “ know when someone is coherent.” Jesus said, “No you don't, you are not a ‘medical doctor.” Attorney Sandra Bonds Hickey said to Jesus, “you don't know what you are talking about you are not lawyers you are mixing the facts." 42|PagePage |13 ‘Attomey Sandra Bonds Hickey considered herself an expert on determining if someone has a ‘mental capacity, even though she is not a medical doctor but she is an expert that knows. Therefore, there is no need for the court to follow both, “the due process clause of the Fourteenth Amendment to the United States Constitution and state law require a trial judge to suspend proceedings and conduct a competency hearing whenever the court is presented with ‘substantial evidence of incompetence, that is, evidence that raises a reasonable or bona fide doubt concerning the defendant's competence to stand trial.’ | (People v. Halvorsen (2007) 42 Cal.4th 379, 401: see also § 1368, subds. (a), (b); People v. Pennington (1967) 66 Cal.24 508. $18,” Presiding Judge Longstreth agreed with attomey Bonds Hickey when she stated that our ‘mother had the capacity at the March 23 hearing, he tumed to my sister Margarita and brother Jesus and said, “She has the capacity.” When my brother and sister along with attomey Sandra Bonds Hickey came back to the ‘courtroom judge Longstreth repeated the exact same things attorney Sandra Bonds Hickey had said, It was almost like if they got together and planed the mock trial together, no I am not kidding, Judge Longstreth said, “You know this thing I don't understand why you guys continue this we ‘all want the same thing to turn this over to your mother but somehow you think that your brother is going to do something nefarious!and he cannot do it because the court is going to oversee that. You have been dragging this forever. You are just throwing racks at your mother's house." ‘Judge Longstreth must have repeated the exact same phrases over 15-times “You are not an “attorney, we tried to beat you over and over the head with this, and don't you get it you are not dan attorney. You don't know anything you just don’t understand.” Judge Longstreth, turned to ‘Jesus and said, “Jesus I am going to deny your petition because you came here and represented ourself and you did not use good judgment. Your brother [David] on the other hand he got himself a lawyer he used good judgment. Because you did not hire a lawyer you are the bad choice. David had a lawyer and he was the right person” Judge Longstreth, “you guys are the ones who keep putting off the decision making, you guy's Ihave a personal vendetta against your sister who is the Joint Tenant in this property.” Under Business and Professions Code sections 6075 and 6076, State Bar procedures for providing hearings and determining accusations against members of the State Bar are coordinated with the disciplinary authority of the Supreme Court: “The rules of professional conduct adopted by the board, when approved by the Supreme Court, are binding upon all members of the State Bar. [{] For a wilful breach of any of these rules, the board has power to discipline members of the State Bar by reproval, ‘public or private, or to recommend to the Supreme Court the suspension from practice for a period not exceeding three years of members of the State Bar.” (Bus. & Prof. Code, §§ 6077, 6086.7.) 15 Yes, he has been in the process of taking our brother's 3-homes and commercial lots for years. They are not even mentioned in the application for Administration that David submitted to the cout. This was ‘another thing that Sandra submitted only the so called 1/3 Cardiff property on the Application to ‘Administer the Estate and did not include the 18k- in cash David took from Salvador's safe along, with many documents and deeds to the rest of his properties. These entire proceedings were a shock to any reasonable mind. 1B[PagePage|14 This statement is scary because she is not a Joint Tenant with our mother late brother Salvador and our father and even attorney Sandra Bonds Hickey advanced the “chain link theory” as to why the property was not under joint tenancy and therefore she needed to come in and file the Letters of Administration in the Probate Court. Judge Longstreth said, “You said it is as simple as going to the county assessor's office and bring in your brother's death certificate. It’s not that simple because the property is in joint tenancy and half would be going 10 your sister you don't think that is fair do you?” It was very clear at this point that Judge Longstreth did not understand and was not familiar with any of the facts as to this property and was making dangerous decisions that would have dire consequences for our mother. Sandra's argument all along was that the property was not under joint tenancy and there was a “broken chain link” therefore this allowed her to come in as an attorney. Neither one of these ‘arguments were correct. The true and correct Joint Tenancy as documented in the County ‘Assessor’s Office. The Joint Tenancy was between our later father David Lemus Bedolla our mother Maria Trinidad Villagomez de Bedolla and our late brother Salvador with our mother surviving our father and late brother Salvador as the only survivor in the “Joint Tenancy.” “Margaret tried to show the documents from judge Powasek and Judge Longstreth asked, “What are you talking abou?” Margarita said, “the judgment from the court that said Alejandra did not have a third or was a joint tenant in case No CASE No.: 37-2010-00150342-PR-TR-NC filed on July 15, 2010.” Judge Longstreth asked gain, “What are you talking about” ‘Attorney Sandra Bonds Hickey answered, “It’s the Summary Judgment they won against “Alejandra”. ‘Then judge Longstreth said, “oh well I don't agree with another's judge bad decision he made a bad decision." Then he said, “But I am at the same level that he is, so 1 cannot overrule his bad judgment.” Then, he said he would not make that ruling and no judge in the probate court neither Judge Kelety or Judge Boswick would have ruled in our favor of someone representing themselves. Judge Longstreth said, “WWe all have the same agreement.” Judge swayed into saying that, “David does not have the right to change anything because I will oversee him and his attorney works for me and I have a lot of people working for me like ‘examiners and clerks. You just don't understand and I cannot get it through your head, we keep beating this through your head that you are not lawyers so you don't understand and you don't know what I am talking about because you are not lawyers." Judge Longstreth said, “Jesus you don’t have a lawyer that is the reason why I would never pick ‘you. You don't have a lawyer and you did not get a lawyer and all the paper work that you filed ‘prolonged the entire hearing and you are just throwing rocks at your mom's house. Everything that you file she is going to respond to it and you are just throwing rocks at your mother house you are wasting time.” Judge Longstreth had previously said at the March 23" hearing that David’s bond was not valid and then he accepted the waver of bond and he just automatically took the arguments that attorney Sandra bonds Hickey gave him in the private ex parte communications between the 14|PagePage (15 attomey and court employees and most likely judge Longstreth himself because he repeated everything Sandra had told us and he was actually representing her against us at every hearing. Every time my sister Margarita opened her mouth judge Longstreth threatened her with sanctions Judge Longstreth kept saying to Margarita, “i shere was a way I could sanction you I would I ‘am going to find a way to sanction you. Your sister pul you up (0 this she put you upfront because she did not want to face the sanctions. If she were up here I would sanction her. 1 am ‘going to find a way to sanction you. | am going to try fo figure out a way fo sanction you. ” In the trial brief submitted a week before the trial attorney Sandra Bonds Hickey presented to the court she place the exhibits Margarita introduced in the Judicial Notice (ROA 134) Margarita brings up the question of the court allowing attorney Sandra Bonds Hickey to bring a copy of the partial trust that the court ruled it was irrelevant documentation and asked, “You sanctioned me for asking for a copy of the entire trust?” Judge Longstreth then asked attorney ‘Sandra Bonds Hickey, “Why did you not sent them a copy of the entire trust? Give them a copy of the trust” and Sandra answered, “J don't have to." ‘The judge said “ok.” Throughout the entire proceedings Judge Longstreth acted as assistant on behalf of Sandra Bonds Hickey and as her own personal attorney. In the end judge Longstreth turned to my brother Jesus and very sarcastically said, “Oh by the way your Fee Waver has been approved.""” ‘Attomey Sandra Bonds Hickey had previously lied to Jesus several times and told him that his name was not anywhere in the Trust in an email and he was not entitled to have a copy of the trust in which Jesus answered, “my name is all over the Trust I know because | signed the documents to be our mother's Trustee and Executor after Salvador in 2009. Don’t tell my name is not in the Trust my name is all over the Trust." Not only is Jesus named in the Trust as a ‘Trustee but as an heir to the Estate. However, Judge Longstreth believe that Jesus is not entitled to be heard and not entitled to get a copy of a Trust that was illegally obtained by attorney Sandra Bonds Hickey because he was not an attorney and was not represented by an attorney. * ‘© Rule 5-220 Suppression of Evidence (Rule Approved by the Supreme Court, Effective May 1, 2017) ‘A member shall not suppress evidence that the member or the member’s client has a legal obligation to reveal or to produce. 17 While, Canon 3C states that a judge should recuse when “the judge’s impartiality may reasonably be questioned.” Case law states a judge should be disqualified when “a reasonable man knowing all the circumstances would have doubts about the judge’s ability to rule... in an impartial manner. ‘McClendon v. Clinard, 38 N.C. App. 353, 356, 247 S.E.2d 783, 785 (1978). In State v. Fie, 320 N.C. 626, 628, 359 S.E.2d 774, 776 (1987). 18 Jn re Watson upheld its state's canon under strict scrutiny, observing that “[jJudges must apply the law faithfully and impartially —they are not elected to aid particular groups, be it the police, the prosecution or the defense bar. Campaign promises that suggest otherwise gravely risk distorting public perception of the judicial role.” In re Watson, 794 N,E,2d at 1 ‘Medina v. California $05 U.S. 437 (1992). and Weiss v. United States, 510 U.S. 163 (1994), Both the protections of procedural due process and the First Amendment are important individual rights that cannot defer to one another as a matter of law in the same way that certain interests may yield to the deference of the military. Instead of creating rigid rules, the tension between procedural due process and the First ‘Amendment is best settled through a flexible balancing approach under the circumstances. 181PagePage |16 Attomey Sandra Bonds Hickey violated the American Bar Association rules of professional conduct; violations under Business and Professions Code; violations under California Rules of Professional Conduct; California Civil Rules of Procedure; Local Court rules; codes of conduct and ethics that are required guidelines for Members of the American Bar Association. The above named attorney's actions were negligent, in bad faith, and violated public confidence in the integrity and impartiality of the judiciary process. The Board of Governors has the power to discipline members as provided by law for a willful breach of any of these rules. ‘Attomiey Sandra Bonds Hickey knew and should have known that her wrongful, willful and prejudicial misconduct violated the constitutional rights of Margarita Bedolla Frias, Jesus Bedolla and our mother Maria Trinidad Villagomez de Bedolla, If attorney Bonds Hickey client had provided a copy of our mother’s Trust before her court filing and after the initial filing; if attorney Sandra Bonds Hickey had complied with the rules of evidence California rules of discovery and evidence a provided a copy of our mother’s Trust that was stolen by her client these whole proceedings would not have been filed. Rule 5-220 Suppression of Evidence (Rule Approved by the Supreme Court, Effective May 1, 2017) “A member shall not suppress evidence that the member or the member’s client has a legal obligation to reveal or to produce.” ‘Attorney Sandra Bonds Hickey only interest in this matter is of self-enrichment through churning of billable hours, regardless of the cost, how much she had to lie and falsify evidence or have private impermissible expate’s. Where did she think our 84-year-old mother on SSI and Medical ‘was going to get the money to pay for this? By tacking on the cost to our mother’s home. Barquis v. Merchants Collection Assn, (1972) 7 Cal.34 94, 107, 101 Cal, Rpt. 745, 496 P.2d 817) "Misuse of the courts in this manner contributes 10 an undermining of confidence in the judiciary by reinforcing the unfortunate image of courts as ‘distant’ entities, available only to ‘wealthy or large interests," and leads consumers "to conclude that the legal system is merely a ‘rubber stamp’ for the improper practices utilized by predatory agencies." (Barguis v. Merchants Collection Assn., supra, at p. 108.) I, Silvia Bedolla Peters declare; Lam the sister of descendent Salvador Bedolla. Except as to those matters I state on information and belief, and as to those matters I believe them to be true, if called before this Court, I could and would testify competently from my own personal knowledge as to the facts stated herein. | declare under penalty of perjury according to the laws of the State of California that the foregoing is true and correct that this declaration was executed on April 23, 2018. =. Silvia Bedolla Peters 1 certify that this Complaint contains 19-pages == Silvia Bedolla Peters 181P acePage |17 DECLARATTION OF JESUS BEDOLLA. 1, Jesus Bedolla, was a Petitioner in this matter. I have personally reviewed and am familiar with the records, files and proceedings described in and the subject of the present complaint herein ‘and know the facts set forth to be true and correct to the best of my recollection. My basic constitutional rights to the courts, due process and justice was denied and violated because I was not a lawyer by judge Longstreth. Attorney Sandra filed many lies, fraudulent papers with the court and in my personal conversations and emails she lied over and over. She presented partial stolen documents to court and documents found not to be valid from the San Diego County Assessor's Office. Judge Longstreth accepted her documents and theories because I was not a lawyer and said so many times in open court ‘Attomey Sandra Bonds Hickey denied many times before, during discovery, and in many subpoenas @ copy of our mother’s Living Trust that was stolen by my brother David Bedolla. Attomey Sandra Bonds Hickey said my name was not even mentioned on it. She lied I signed the documents to be our mother’s Trustee after our late brother Salvador in 2009 and I am the heir of my mother’s Estate in question. David did not sign a single document and he did not even know that our mother had a trust. I had the right to protect and defend my inheritance in court as well as maintain my mother’s Estate intact. Judge Longstreth took away my rights to defend my mother’s and my future property by denying me access to the courts and access to justice because I was not a lawyer. had more than 10-declarations in support of my credibility, integrity, a man of honor, principles and devotion to my family and steadfast and unshakable love and devotion to my mother. Judge Longstreth took away my inherit constitutional rights, denied my very existence as a human being, and humiliated me in open court simple because I was not a lawyer and this made me a bad choice and someone he would never choice and consider for anything. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct and if called to testify I would do so from my own personal knowledge of the events. April 23, 2018 P: 760-622-0787 Jesus Bedolla 17|PagePage [18 DECLARATTION OF MARGARITA BEDOLLA FRIAS |, Margarita Bedoll Fras, was a Petitioner inthis matter. Ihave personally reviewed and am familiar with the records, ile and proceedings described in andthe subject ofthe present complaint herein and know the facts set forth to be true and correct tothe best of my recollection ofthe events that took place in this mater inthe above entitled complaint My basic constitutional rights tothe courts, due process and justice was denied and violsted because I was not a lawyer by judge Longstreth. Attomey Sandra fled many lies, fraudulent papers with the court and in my personal conversations and emails she lied over and over. She presented partial stolen documents to the court and documents found not be valid from the San Diego County Assessor's Office. Judge Longstreth accepted her documents and theories because I was not a lawyer and the submission of my documents were denied Judicial Review and he said so many times in open court. ‘Attomey Sandra Bonds Hickey denied many times before, during discovery, and in many subpoenas a copy of our mother’s Living Trust that was stolen by my brother David Bedolla. ‘After the denials I filed a Motion to Compel the production of our mother entire Living Trust ‘Attomey Sandra Bonds Hickey objected stating that it was irrelevant among other theories, Judge Longstreth denied judicial review of my entre filings including the exhibits that proved attomey Bonds Hickey was wrong and had filed documents that were found to be fraudulent by the San Diego County Assessor's Office. At the March 23" hearing judge Longstreth sanctioned me on or about $15,000 for asking for our mother’s Living Trust and presumably not answering exact same interrogatories that I had previously answered twice. The finalized minute order had sanctions of about $11,000-plus dollars against me for asking for my mother’s Living Trust. ‘At each and every hearing judge Longstreth kept telling me that I was not an attorney and T did not know what I was talking about, that I did not know anything because I was not an attorney and he was going to find a way to sanction me he repeated this over and over and over. Attomey Sandra Bonds Hickey consistently called me, emailed me, harassed me, bullied me mostly stated on court documents that I lied and committed some sort of fraud which was a lie. 18|PagePage |19 Judge Longstreth said it was ok because it was attorney lingo and this is the way attorneys communicate but I wouldn’t know because I was not an attorney and did not know anything, Judge Longstreth took away my inherit constitutional rights, denied my very existence as human being, and humiliated me in open cout simple because I was not a “lawyer.” 1 am legally blind, disabled as defined by the ADA I am on Disability and Medical and I was treated as subhuman by both attomey Sandra Bonds Hickey and judge Longstreth, Judge Longstreth sanctioned me without due cause or due process first about $15,000 and then lowered to ubout over $11,000 simply because I was not an attorney, refused to review my moving documents and to set me as an example of what will happen to a person coming before him representing themselves in court without an attorney. Judge Longstreth made it clear in open court atthe April 16% hearing that he would never review or make a decision in favor of someone representing themselves and that the Probate judges all had this agreement. He said attomey Sandra Bonds Hickey worked for him and all the ‘examiners and clerks worked for him as well and they all have the same understanding. ‘At this same April 16" hearing every time I made an attempt to speak Judge Longstreth would interrupt abruptly and he kept repeating, “7 want to sanction you, I am going to find a way to sanction you, I want to sanction you, I am going to find a way to sanction you.” I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct and if called to testify 1 would do so from my own personal knowledge of the events. April 23, 2018 Aged WA 760-681-8639 ‘Margarita Bedolla Frias 19|PecePage |18 DECLARATTION OF MARGARITA BEDOLLA FRIAS I, Margarita Bedolla Frias, was a Petitioner in this matter. I have personally reviewed and am familiar with the records, files and proceedings described in and the subject of the present complaint herein and know the facts set forth to be true and corret to the best of my recollection of the events that took place in this matter in the above entitled complaint. My basic constitutional rights tothe courts, due process and justice was denied and violated because I was not a lawyer by judge Longstreth. Attomey Sandra filed many lies, fraudulent papers with the court and in my personal conversations and emails she lied over and over. She presented partial stolen documents to the court and documents found not tobe valid from the San Diego County Assessor's Office. Judge Longstreth accepted her documents and theories because I was not a lawyer and the submission of my documents were denied Judicial Review and he said so many times in open court. Attomey Sandra Bonds Hickey denied many times before, during discovery, and in many subpoenas a copy of our mother’s Living Trust that was stolen by my brother David Bedolla. ‘After the denials I filed a Motion to Compel the production of our mother entire Living Trust. ‘Attomey Sandra Bonds Hickey objected stating that it was irrelevant among other theories. Judge Longstreth denied judicial review of my entire filings including the exhibits that proved attomey Bonds Hickey was wrong and had filed documents that were found to be fraudulent by the San Diego County Assessor's Office. At the March 23" hearing judge Longstreth sanctioned ‘me on or about $15,000 for asking for our mother’s Living Trust and presumably not answering, ‘exact same interrogatories that I had previously answered twice. The finalized minute order had sanctions of about $11,000-plus dollars against me for asking for my mother’s Living Trust. ‘At each and every hearing judge Longstreth kept telling me that I was not an attorney and I did not know what I was talking about, that I did not know anything because I was not an attorney and he was going to find a way to sanction me he repeated this over and over and over. ‘Attorney Sandra Bonds Hickey consistently called me, emailed me, harassed me, bullied me mostly stated on court documents that I lied and committed some sort of fraud which was a lie. 181P agePage |19 Judge Longstreth said it was ok because it was attomey lingo and this i the way atfomeys communicate but I wouldn't know because I was not an attomey and did not know anything. Judge Longstreth took away my inherit constitutional rights, denied my very existence as & human being, and humiliated me in open court simple because I was not a “lawyer.” 1am legally blind, disabled as defined by the ADA Lam on Disability and Medical and I was treated as subhuman by both attorney Sandra Bonds Hickey and judge Longstreth. Judge Longstreth sanctioned me without due cause or due process first about $15,000 and then lowered to about over $11,000 simply because I was not an attorney, refused to review my moving documents and to set me as an example of what will happen to a person coming before him representing themselves in court without an attorney. Judge Longstreth made it clear in open court at the April 16% hearing that he would never review or make a decision in favor of someone representing themselves and that the Probate judges all had this agreement. He said attomey Sandra Bonds Hickey worked for him and all the examiners and clerks worked for him as well and they all have the same understanding. ‘At this same April 16" hearing every time I made an attempt to speak Judge Longstreth would interrupt abruptly and he kept repeating, “ want 10 sanction you, I am going to find a way to sanction you, I want to sanction you, I am going to find a way to sanction you." I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct and if called to testify I would do so from my own personal knowledge of the events. April 23, 2018 £ i ) rr P: 760-681-8639 Margarita Bedolla Frias 191Page