provinceorstate:california


  • Brain ‘15-second delay’ shields us from hallucinogenic experience – research — RT News
    http://rt.com/news/brain-neuroscience-visual-information-709

    A team of vision scientists at the University of California, Berkeley and Massachusetts Institute of Technology (MIT) revealed this secret of the human #brain: To save us from insanity induced by a constantly changing torrent of pictures, shapes and colors – both virtual and real world – the brain filters out information, failing in most cases to notice small changes in a 15-second period of time.

    It actually means that what we do see is, in fact, a mixture of past and present. According to the research, published in the journal Nature Neuroscience, stability is attained at the expense of accuracy.

    “What you are seeing at the present moment is not a fresh snapshot of the world but rather an average of what you’ve seen in the past 10 to 15 seconds,” said study author Jason Fischer, Ph.D., a neuroscientist at MIT.

    #attention #perception #neuroscience

    Although it has a 15-second delay in perception, the brain can also work incredibly fast. Neuroscientists from MIT recently found that even if the eye sees an image for as little as 13 milliseconds, the brain can still successfully process it.


  • Wealth inequality: Is it worse than we thought ?
    http://www.slate.com/blogs/moneybox/2014/04/02/wealth_inequality_is_it_worse_than_we_thought.html
    http://www.slate.com/content/dam/slatest/posts/2011/11/17/ows_day_of_action_protesters_head_to_the_new_york_stock_exchange/132920618.jpg.CROP.promo-mediumlarge.jpg

    Economists Emmanuel Saez, of the University of California–Berkeley, and Gabriel Zucman, of the London School of Economics, are out with a new set of findings on American wealth inequality, and their numbers are startling. Wealth, for reference, is the value of what you own—assets like housing, stocks, and bonds, minus your debts. And while it certainly comes up from time to time, it has tended to play second fiddle to income in conversations about America’s widening class divide. In part, that’s because it’s a trickier conversation subject. Wealth has always been far more concentrated than income in the United States. Plus, research suggested that the top 1 percent of households had actually lost some of its share since the 1980s.

    That might not really have been the case.

    Forget the 1 percent. The winners of this race, according to Zucman and Saez, have been the 0.1 percent. Since the 1960s, the richest one-thousandth of U.S. households, with a minimum net worth today above $20 million, have more than doubled their share of U.S. wealth, from around 10 percent to more than 20 percent. Take a moment to process that. One-thousandth of the country owns one-fifth of the wealth. By comparison, the entire top 1 percent of households takes in about 22 percent of U.S. income, counting capital gains.

    http://www.slate.com/content/dam/slate/blogs/moneybox/2014/04/02/wealth_inequality_is_it_worse_than_we_thought/chart_1.png.CROP.promo-mediumlarge.png

    While the super-rich have risen, the merely affluent have barely budged. As shown on this next graph from Saez and Zucman, the share of wealth belonging to the top 1 to 0.5 percent of households has remained about level. The 0.5 to 0.1 percent have tacked roughly an extra percentage point onto their piece of the pie. The relative gains have been eaten up by the elite—the 0.1 percent and even the 0.01 percent.

    http://www.slate.com/content/dam/slate/blogs/moneybox/2014/04/02/wealth_inequality_is_it_worse_than_we_thought/chart_2.png.CROP.promovar-mediumlarge.png

    This new batch of research is similar in spirit to Saez’s pioneering work quantifying income inequality, which he has published with French economist Thomas Piketty. (It’s probably no accident that this research is coming out around the same time that Piketty, Saez’s longtime collaborator, has published Capital in the Twenty-First Century, his highly touted book about capital accumulation—aka wealth.) Both projects substitute tax data analysis for older approaches that relied on government surveys, which tend to undercount the very rich. In this case, Saez and Zucman use taxes on investment income to reverse-engineer their wealth estimates. The results are still very preliminary and could change with further study.
    But they are basically in keeping with what has already been shown about income inequality. Occupy Wall Street trained Americans to frame the economic gap in terms of the 99 percent and 1 percent. But writers and economists have been pointing out for years that the biggest winners in today’s globalized, finance-heavy economy have been an even smaller band of super-rich. Tim Noah dubbed them “the stinking rich.” Chrystia Freeland went with “plutocrats.” No matter what you choose to name them, the largest economic gains have accrued to Americans at the very, very tiniest tip of the earnings pyramid. Here’s one dramatic illustration I’ve drawn from the World Top Incomes Database. The top 0.5 percent, with minimum household income of $551,000, have roughly tripled their share of the nation’s paycheck since 1978, to about 18 percent. The bottom half of the 1 percent, the work-a-day rich, have upped theirs only to around 4 percent.

    http://www.slate.com/content/dam/slate/blogs/moneybox/2014/04/02/wealth_inequality_is_it_worse_than_we_thought/1_percent_decomposed_2.png.CROP.promovar-mediumlarge.png

    urning income into wealth takes saving and investment. And over the years, wealth compounds. That’s why wealth inequality is always more severe than the income gap: The well-to-do can save relatively more to start, and then their advantage builds on itself. It may also explain why the super-rich are sprinting ahead while the ordinary affluent are more or less standing in place. The economy has treated small-business owners, corporate lawyers, and doctors well. But in order to keep up their lifestyles, they may need to spend relatively more of their income than, say, a Fortune 500 CEO or hedge funder.

    And so an exceptionally tiny circle of Americans is not only commanding a greater and greater share of pay, but—if Saez and Zucman are right—they are successfully consolidating their fortunes far faster than 99.9 percent of the country. At the risk of sounding a little melodramatic, this is how an aristocracy gets built.

    The #Shocking #Rise of #Wealth-Inequality: Is it #Worse Than We Thought?
    #again&again !


  • Remembering Cesar Chavez
    http://framework.latimes.com/2012/03/29/remembering-cesar-chavez

    March 31 is Cesar Chavez’s birthday and a holiday in California, Colorado and Texas.

    http://latimesphoto.files.wordpress.com/2012/03/fa_444_chavez970.jpg
    Feb. 2, 1979: Cesar Chavez speaks to members of the United Farm Workers during a rally in the Imperial Valley. The UFW was striking lettuce growers. During the bitter strike, one UFW striker, Rufino Contreras, was killed. PHOTOGRAPH BY: Steve Fontanini / Los Angeles Times


  • Sent: Monday, March 24, 2014 11:17 AM

    To whom it may concern:

    This will serve to provide notice of an ex parte hearing scheduled on Friday, March 28, 2014 at 9. a.m. in Department 2 of the Yolo County Superior Court, located at 725 Court Street, Woodland, California, before the Honorable Timothy L. Fall, to seek an order continuing the deadline by which service of the First Amended Complaint and related pleadings must be served on the defendants named in this case.

    Please let me know if you intend to oppose this application so that I can inform the Court.


    On Mon, Mar 24, 2014 at 2:27 PM, Dresser, Gregory P. <GDresser@mofo.com> wrote:

    Please forward your ex parte papers as soon as they are available.

    Gregory Dresser
    Morrison & Foerster LLP
    425 Market St. | San Francisco, CA 94105
    P: 415.268.6396 | F: 415.276.7527
    GDresser@mofo.com | www.mofo.com

    Sent: Wed, Mar 26, 2014 at 4:22 PM

    Mr. Dresser:

    1. This will serve to inform you that the ex parte hearing has been re-scheduled by the court to Tuesday, April 1st, at 1:30 p.m. in Department 1 of Yolo County Superior Court.

    Apparently, the entire Yolo County Superior Court bench, on its own, has disqualified itself from hearing this matter so it will be heard by a visiting judge from Napa County.

    2. This will also serve to memorialize yesterday’s events as far as service of process on Mr. James Brosnahan and Mr. Raj Chatterjee.

    Yesterday, around 2:30 p.m., a process server arrived to MoFo’s office in San Francisco. The process server informed MoFo’s receptionist that he needs to serve Mr. Brosnahan and Mr. Chatterjee with a suit in which they are named defendants. After a round of phone calls, the receptionist informed the process server that the two are not available and that no one is willing to accept service.

    Later, the process server attempted, once again, to serve Mr. Brosnahan and Mr. Chatterjee by leaving copies of the suit with personnel in MoFo’s mail room, and once again was rebuffed.

    Between 8 to 9 p.m., the process server visited Mr. Chatterjee’s residence in the Clairmont District of Oakland. The process server reported that upon arrival he noticed 2 cars (a passenger mini-van and a Nissan hatchback) parked in the front of the house, and the name “Chatterjee 2010” engraved on the cement of the sidewalk. The process server encountered a female who identified herself as the spouse of Mr. Chatterjee. She further stated that Mr. Chatterjee was not present. The process server informed Mrs. Chaterjee of the fact that he needs to serve Mr. Chatterjee with a lawsuit and asked her if she is willing to accept the papers. Mrs. Chatterjee answered in the affirmative, whereupon the process server handed her the envelope containing the pleadings and departed.

    Later, a similar scenario took place at the residence of the Brosnahans, whereupon Mrs. Carol Brosnahan agreed to accept service for her husband by instructing the process server to leave the envelope in the mail box.

    At this point, I have not conducted legal research as to whether a spouse can agree to accept service on behalf of the other spouse. However, it is clear from the facts described above that there was a meeting of the minds and full understanding as to the nature of the transaction by all those involved.

    3. As far as your request to forward you copies of the ex parte papers, please note that I plan to finalize those papers only on Tuesday, prior to going to court. As such, I will be more than happy to hand you a copy of the papers if you make an appearance.

    The purpose of the ex parte hearing is to ask the court to extend the time that I have to complete service on the other named defendants — primarily those defendants who reside outside of California and those who managed to evade service.

    My understanding is that a plaintiff normally has 60 days to serve from the date of the filing of the original suit or 30 days from the date of the filing of a first amended complaint. Because I filed an amended complaint very shortly after I filed the original suit, I am at a bit of a disadvantage as far as the timing, and as such will ask the court to extend the time. I asked for the hearing because I needed this issue to be addressed before the court does it for me.

    In any event, I obviously have no say whether you choose to show up or not, but am not sure why you would want to participate given that your client has already been served and is due to make an appearance on Friday, March 28, 2014.

    If you have any questions, please let me know.



  • The Raiders strike back at cheerleaders: You can’t sue us, ladies
    http://www.latimes.com/local/abcarian/la-me-ra-raiders-cheerleaders-lawsuit-20140318,0,1339483.story

    The allegations in the cheerleaders’ lawsuit are pretty straightforward: When it comes to working conditions for the Raiderettes, the Oakland Raiders routinely break California labor law.

    The women, who are professional dancers, earn less than minimum wage and are paid at the end of the season instead of every two weeks as required by California law. They earn $125 per game and are not paid for practices or meetings. They can be fined for being late to practice, or for not having the right hair color or for failing to appropriately polish their nails. They are required to make unpaid appearances on behalf of the team.

    The cheerleading squad, in short, operates under a paternalistic set of rules that not only infantilizes grown women, but also makes demands that no employer should have the right to make.


  • Industry Behind Anti-Wage-Hike Letter
    http://www.nytimes.com/2014/03/16/us/industry-tied-to-letter-against-new-wage.html

    WASHINGTON — The National Restaurant Association did not disclose upfront its role in helping draft and circulate a statement signed by more than 500 prominent economists, including four winners of the Nobel Prize, urging the federal government to reject the proposal by the Obama administration to increase the minimum wage to $10.10 an hour, interviews with signers of the letter showed.

    The statement was distributed to prominent economists nationwide under the name of Vernon L. Smith, a Nobel Prize-winning professor of economics and law at Chapman University in Orange, Calif., concluding that the minimum wage “is a poorly targeted antipoverty measure.”

    (...)

    Mr. Smith and several of the other economists who signed the statement said in interviews Friday that they had agreed to support it based on the merits of the argument, and that who had initiated it was unimportant.

    (...)

    The National Restaurant Association took several steps that in effect distanced it from the role it played in creating the statement. They included asking a former Treasury Department official, James E. Carter, to approach Mr. Smith at Chapman University, and then paying him to use a database of conservative economists that Mr. Carter maintains to ask them to sign the statement distributed in Mr. Smith’s name, participants involved in the effort said.

    Mr. Smith said he had been asked for input but had not written the statement , which was sent out with an opening that said, “Message from Vernon L. Smith.”

    (...)

    The restaurant industry statement is a reply, of sorts, to a similar statement signed by more than 600 economists endorsing the increase of the minimum wage. That statement was distributed by the Economic Policy Institute, a Washington research organization that receives about 30 percent of its funding from labor unions.

    But the institute was clear about its role in collecting signatures and promoting the statement once it was released in January. The statement became a target of lobbying against a wage increase; an advertisement in The New York Times by a nonprofit group run by a firm supported by the restaurant industry, Berman & Co., noted that some of the signers were, at least at some point, self-avowed Marxists.



  • The Billion-Dollar Telescope Race - Issue 11: Light
    http://nautil.us/issue/11/light/the-billion_dollar-telescope-race

    http://static.nautil.us/2828_b139aeda1c2914e3b579aafd3ceeb1bd.png

    When Warner Brothers animators wanted to include cutting-edge astronomy in a 1952 Bugs Bunny cartoon1 they set a scene at an observatory that looks like Palomar Observatory in California. The then-newly unveiled Hale Telescope, stationed at Palomar, had a 5-meter-diameter mirror, the world’s largest. In 1989, when cartoonist Bill Watterson included a mention of the world’s largest telescope in a “Calvin and Hobbes” cartoon,2 he again set the action at Palomar. Although computers had grown a million times faster during those 38 years, and eight different particle colliders had been built and competed for their field’s top ranking, astronomy’s king of the hill stayed perched on its throne. This changed in 1992, with the introduction of the Keck telescope and its compound, 10-meter mirror. (...)


  • The Face Behind Bitcoin - Newsweek
    http://mag.newsweek.com/2014/03/14/bitcoin-satoshi-nakamoto.html

    He’s wearing a rumpled T-shirt, old blue jeans and white gym socks, without shoes, like he has left the house in a hurry. His hair is unkempt, and he has the thousand-mile stare of someone who has gone weeks without sleep.

    He stands not with defiance, but with the slackness of a person who has waged battle for a long time and now faces a grave loss.

    Two police officers from the Temple City, Calif., sheriff’s department flank him, looking puzzled. “So, what is it you want to ask this man about?” one of them asks me. “He thinks if he talks to you he’s going to get into trouble.”

    “I don’t think he’s in any trouble,” I say. “I would like to ask him about Bitcoin. This man is Satoshi Nakamoto.”

    #Bitcoin #Satochi_Nakamoto


  • REDACTED TEXT OF INTERACTIONS BETWEEN MYSELF AND MORRISON & FOERSTER PARTNERS DOUGLAS HENDRICKS AND ERIC COFFILL

    On Fri, Feb 28, 2014 at 8:20 AM

    Hello Mr. Hendricks:

    As you recall, around 2011 you wrote and introduced yourself as the associate general counsel of Morrison & Foerster .

    As you probably know by now, a suit naming, among others, Morrison & Foerster, Mr. Brosnahan, and Mr. Chatterejee was filed a few days ago in Yolo County Superior Court.

    Presently, I am in the process of causing the action to be served by a process server on the various defendants. As far as Morrison & Foerster defendants, however, I have learned from official records maintained by California Secretary of State Debra that Morrison & Foerster (entity number C0980795 ) is now DISSOLVED.

    I do know for a fact, however, that the Sacramento office is still operational and am wondering whether I can instruct the process-server to drop off the papers at the Sacramento office instead since the San Francisco office is now DISSOLVED.

    Please let me know ASAP because time is of the essence and I am being prejudiced by MoFo’s failure to maintain current records with California Secretary of State.

    Thank you for your time.

    Sent: Friday, February 28, 2014 8:43 AM
    To: Hendricks, Douglas L.
    Cc: Brosnahan, James J.; Chatterjee, Somnath Raj; Farman, Charles S.; Coffill, Eric J.
    Subject: Re Addendum: Morrison & Foerster ; Service of Process on Sacramento Office

    Mr. Hendricks:

    I just noticed that other entities associated with Morrison & Foerster use a service known as CSC - LAWYERS INCORPORATING SERVICE with an address of 2710 GATEWAY OAKS DR STE 150N, SACRAMENTO.

    Please inform if I I can send the process server to CSC.

    Thanks,

    On Fri, Feb 28, 2014 at 2:00 PM, Hendricks, Douglas L. <DHendricks@mofo.com> wrote:

    The Morrison & Foerster law firm operates as a California limited liability partnership and is in good standing with the appropriate authorities. CSC is not the agent for service of process for Morrison & Foerster LLP.

    Douglas L. Hendricks
    General Counsel
    Morrison & Foerster LLP
    425 Market St. | San Francisco, CA 94105
    P: 415.268.7037 | F: +415.276 7037 | C: 510.384.8994
    DHendricks@mofo.com | www.mofo.com

    Sent: Friday, February 28, 2014 2:56 PM
    To: Hendricks, Douglas L.
    Cc: Brosnahan, James J.; Chatterjee, Somnath Raj; Farman, Charles S.; Coffill, Eric J.
    Subject: Re: Re Addendum: Morrison & Foerster ; Service of Process on Sacramento Office

    Thank you for replying.

    A search for “Morrison & Foerster” at California Secretary of State’s Business Search database http://kepler.sos.ca.gov under “Corporation Name” yields:

    Entity Number Date Filed Status Entity Name Agent for Service of Process
    C0980795 04/21/1980 DISSOLVED MORRISON & FOERSTER DOUGLAS L HENDRICKS
    C1257410 09/21/1984 ACTIVE MORRISON & FOERSTER/GIRVAN PECK MEMORIAL FUND CORPORATION SERVICE COMPANY WHICH WILL DO BUSINESS IN CALIFORNIA AS CSC - LAWYERS INCORPORATING SERVICE
    C1532498 06/02/1986 ACTIVE THE MORRISON & FOERSTER FOUNDATION CORPORATION SERVICE COMPANY WHICH WILL DO BUSINESS IN CALIFORNIA AS CSC - LAWYERS INCORPORATING SERVICE

    However, a similar search under “Limited Liability Company” yields: Record not found.

    In essence, if I understand correctly, CSC is an agent for service of process for Morrison & Foerster Foundation and Morrison & Foerster Girvan Peck Memorial Fund only. While Morrison & Foerster was structured as a corporation, you were the registered agent for service of process. Presently, Morrison & Foerster is structured as an LLP and claims that it is in good standing with the appropriate authorities. At least according to California Secretary of State, which may or may not be an appropriate authority, Morrison & Foerster LLP does not exist and/or did not designate an agent for service of process.

    If not a bother, can you please write back with name and address of the agent for service of process for Morrison & Foerster LLP. ?

    Thank you.

    On Mon, Mar 3, 2014 at 11:30 AM, Hendricks, Douglas L. <DHendricks@mofo.com> wrote:

    I am sorry, but I am not in a position to assist you in your suit against my law firm.

    Doug Hendricks
    Morrison & Foerster LLP
    (415) 268-7037

    Sent: Monday, March 03, 2014 2:59 PM
    To: Hendricks, Douglas L.
    Cc: Brosnahan, James J.; Chatterjee, Somnath Raj; Farman, Charles S.; Coffill, Eric J.
    Subject: Service of Process on MoFo Perfected — Re: Re Addendum: Morrison & Foerster ; Service of Process on Sacramento Office

    Dear Mr. Hendricks:

    Thanks again for replying. I understand your predicament and accept your apology.

    In any event, the entire issue is now moot because service of process has been perfected on Morrison & Foerster (Sacramento Office) earlier today.

    My understanding is that the registered process server encountered both the receptionist and Mr. Coffill, and was told by Mr. Coffill that he can’t accept service on behalf of the individual defendants.

    If Messrs. Brosnahan and Chatterjee are willing to waive personal service, please let me know.

    On Tue, Mar 4, 2014 at 11:31 AM, Coffill, Eric J. <ECoffill@mofo.com> wrote:

    Please let me correct a statement below. Your statement below that “service of process has been perfected on Morrison & Foerster (Sacramento Office) earlier today” is factually incorrect. The individual who appeared in our office yesterday morning was told we could not and would not accept service of process on behalf of anyone other than Morrison & Foerster, and the individual then left. Service was not made and the individual left our office with the complete envelope of materials he arrived with.

    Regards,

    Eric

    Eric J. Coffill
    Managing Partner, SA
    Morrison & Foerster LLP
    400 Capitol Mall, Suite 2600
    Sacramento, CA 95814-4428
    P: 916.325.1324 | F: 916.448.3222
    ECoffill@mofo.com | www.mofo.com

    Tue, Mar 4, 2014 at 12:58 PM
    subject: Re: Service of Process on MoFo Perfected — Re: Re Addendum: Morrison & Foerster ; Service of Process on Sacramento Office

    Coffill, Eric J." <ECoffill@mofo.com>
    cc: “Hendricks, Douglas L.” <DHendricks@mofo.com>,
    “Brosnahan, James J.” <JBrosnahan@mofo.com>,
    “Chatterjee, Somnath Raj” <SChatterjee@mofo.com>,
    “Farman, Charles S.” <CFarman@mofo.com>

    Mr. Coffill:

    My understanding is that the process-server met and spoke with you and the receptionist.

    Furthermore, my understating is that you told the process-server that you will only accept service on behalf of Morrison & Foerster, that you can’t accept papers on behalf of Defendant James Brosnahan and Defendant Raj Chatterjee, and that subsequently the process-server served Morrison & Foerster only with one envelope containing summons, first amended complaint, ADR package, and notice of CMC.

    Personally, I view your version of events as not credible, suspect, implausible, as well as illogical. Please note that I have absolutely no reason to doubt the creditability of the process-server — who yesterday also served other defendants in Sacramento (such as Accenture, Fulcrum Properties, McGeorge, and others.) Also, why would a professional process-server would leave your office without serving Morrison & Foerster — an assignment which he was hired to complete ??!!

    On the other hand, to date, Morrison & Foerster has been understandably evasive, uncooperative, and motivated to lie due to the potentially catastrophic consequences stemming from allegations relating to Morrison & Foerster and James Brosnahan suspect interactions with governmental officials (such as Joe Dunn, Martha Escutia, Geoffrey Brown, Michael Peevey) on behalf of clients and related acts of grave misconduct surrounding California Energy Crisis.

    Please note that a failure to appear in a timely manner will result in the entry of a default judgment against Morrison & Foerster.


  • 12-year-old invents Braille printer using Lego set | MNN - Mother Nature Network
    http://www.mnn.com/green-tech/research-innovations/stories/12-year-old-invents-braille-printer-using-lego-set

    Shubham Banerjee, a seventh-grade student from Santa Clara, Calif., developed the Braille printer using toy construction Lego pieces. The low-cost invention could be an accessible solution for blind and disadvantaged people across the globe, Banerjee said.
     
    The printer, dubbed Braigo (short for Braille with Lego), was created from the Lego Mindstorms EV3 set, which retails for $349. Banerjee also added $5-worth of additional materials, which means the finished product costs about $350. This makes Braigo much more affordable than other Braille printers, which can retail for more than $2,000, according to Banerjee.

    http://www.mnn.com/sites/default/files/LEGOBraillePrinter_m_0219.jpg

    #braille #inventions #lego


  • The Search For Drinking Water In California Has Led To The Ocean
    http://www.npr.org/2014/02/26/281984555/the-search-for-drinking-water-in-california-has-led-to-the-ocean

    http://media.npr.org/assets/img/2014/02/26/drought_wide-eaa31c915dafca21d3d530dd939345674181b826-s40-c85.jpg
    On the coast in Carlsbad, Calif., construction workers are building what will be the largest seawater desalination plant in the Western Hemisphere. When finished in early 2016, it is expected to provide up to 50 million gallons of fresh drinkable water every day.

    “That’s enough water for 112,000 households here in the region,” says Peter MacLaggan with Poseidon Resources, the developer of this $1 billion plant.

    [...]

    He says desalination helps, but it’s not a cure-all. It’s expensive, it does take a lot of energy and it can treat only so much water at a time.

    His agency gets about 30 percent of its water from Northern California through the State Water Project. “To replace that supply would require a Carlsbad plant every 4 miles between LA and San Diego,” he says.

    That would be 25 plants in that stretch. Statewide, 17 desalination plants are in some stage of planning on the California coast.

    #Californie #eau #sécheresse #désalinisation



  • Les États-Unis privés de tomates, brocolis, et de salades (entre autres) en 2014 ?

    http://350.org/californias-drought-spells-disaster-for-your-favorite-foods-lettuce-and-tomatoe

    California’s drought won’t only affect Californians. “The Golden State” actually supplies nearly half of all U.S. fruits, veggies, and nuts, and in the midst of its driest year of the past half millenium, these eight foods might become really hard to get.

    http://media2.policymic.com/eae6030b5ec5c6a54cf4de5905e65bf9.gif

    http://www.zerohedge.com/news/2014-02-15/californias-new-dust-bowl-its-gonna-be-slow-painful-agonizing-death-farme

    At the local grocery store, fruit prices are up — but sales are down. The market was forced to lay off three employees — and many more throughout the town are packing their bags and leaving town.

    McDonald said farming communities like Firebaugh run the risk of becoming desolate ghost towns as local governments and businesses collapse

    “It’s going to be a slow, painful process — but it could happen,” McDonald said. “It’s not going to be one big tsunami where you’re gonna having something get wiped out in one big wave. It’s gonna be a slow, painful, agonizing death.”

    #états-unis #légumes #agriculture #climat #sécheresse #californie


  • State Bar of California ; Voice of OC ; Joseph Dunn ; Michael Cabral

    To: joseph.dunn@calbar.ca.gov, ‘Todd, Mary Ann’ <maryann.todd@mto.com>, schatterjee@mofo.com, Douglas.Winthrop@aporter.com, Alec.chang@skadden.com, nfineman@cpmlegal.com, echemerinsky@law.uci.edu Cc: ‘Robert.Hawley’ <Robert.Hawley@calbar.ca.gov>, ‘starr.babcock’ <starr.babcock@calbar.ca.gov>, Craig.Holden@lewisbrisbois.com, HRosing@klinedinstlaw.com, Luis.Rodriguez@calbar.ca.gov, krinskym@yahoo.com, ddean@riberalaw.com, jmendoza@theiplawfirm.com, djp@paslaw.com, mcolantuono@cllaw.us, mshem@bortonpetrini.com, hvera@publiccounsel.org, dtorres@lawtorres.com, pearlgmann@aol.com

    Dear Mr. Dunn and to whom it may concern:

    This will serve to address the following:

    1. Attached below for your reference is a courtesy PDF copy of a summons and civil complaint filed against your publication VOICE OF OC in Yolo County Superior Court.

    Please note that as an act of good faith and in order to protect the brand ‘State Bar of California’ and the reputation of the judicial system, I tried as much as possible to keep executives and directors of the California Bar out of the suit.

    Nevertheless, as you know very well, strong circumstantial evidence provides that the California Democratic Party took advantage of California’s Energy Crisis to enrich itself in lieu of prosecutions, and that the chosen forum to engage in various financial machinations has been the California Bar Foundation and related entities.

    This is the reason many utility lawyers, CPUC executives and operatives were appointed as members of the BOG and as directors of the California Bar Foundation, to wit: CPUC Commissioner Geoffrey Brown, CPUC Chief Legal Counsel Peter Arth, Gwen Moore of GeM Communications, George Davis of Davis Broadband (and secretly of AARP), Jeannine English (of AARP and lobbyist for Ross Perot Energy System), Dennis Mangers (on behalf of energy senator Darryl Stienberg, Kip Lipper, and Lipper’s sister Donna Lucas of Venoco Energy), Jeff Bleich and Bradley Phillips (on behalf of Southern California Edison, Verizon) , Douglas Winthrop of Howard Rice / Arnold & Porter (on behalf of PG&E), Annette Carnegie (on behalf of El Paso Energy), Howard Miller (on behalf of Girardi & Keese), and Nancy Fineman (on behalf of Cotchett, Pitre & McCarthy).

    As you also know very well, clear and convincing circumstantial evidence provide that you, Martha Escutia , Tom Girardi and James Brosnahan launched VOICE OF OC with funds misappropriated (through the ad-hoc sham non profit CaliforniaALL) from the California Bar Foundation and in consideration for malfeasance by you and Martha Escutia stemming from California’s Energy Crisis by utility lawyers who were part of the California Bar Foundation/BOG such as Jeff Bleich (on behalf of Southern California Edison), James Brosnahan/Annette Carnegie (on behalf of El Paso Energy), Douglas Winthrop (on behalf of PG&E), non-lawyer/lobbyist Jeannine English (on behalf of Ross Perot System), and Thomas Girardi (on behalf of class-action lawyers who were prosecuting related litigation such as Pierce O’Donnell and Joe Cotchett in matters such as Continental Forge, El Paso, and SWEETIE’S).

    As you also know very well, in order to justify the existence of CaliforniaALL, you, Erwin Chemerinsky, Karina Hamilton, husband Robert Hamilton, and CaliforniaALL misled the public by various fraudulent means into believing CaliforniaALL was responsible for the launching of the Saturday Law Academy at UC Irvine (‘SALUCI’) in 2008, whereas SALUCI was actually launched in 2005.

    Later, as you also by now know very well , CaliforniaALL was also misused by various Obama for America actors (Jeff Bleich, James Brosnahan , Tony West, Kamala Harris, Laura Chick, and CHRIS YOUNG) as well as by the election campaign of Sacramento mayor Kevin Johnson by Jeannine English, Mark Friedman, and CHRIS YOUNG.

    2. This will serve to confirm and to place you and members of the BOG on notice of the fact that Yolo County Assistant District Attorney Michael Cabral has stated on multiple occasions to me and to on separate occasions to various attorneys words to the effect of, ‘The State Bar of California doesn’t really want you criminally prosecuted, they just want you to go away’. On a separate occasion he stated that he wants me prosecuted and to have ‘State Prison’ “hanging over my head” if I do not fulfill conditions of probation which will include not suing, complaining, or blogging against various wrongdoers. When I stated to him that this is an attempt to shut me up through misuse of the justice system and that it has no relations to any crime I committed, he stated ‘that’s the situation.’

    Michael Cabral has already stated to me, and later through my insistence to my attorney, that he ‘never’ spoke to Jeannine English, that he spoke ‘only once’ to Tom Layton, and that he only communicates with representatives from the State Bar of California.

    Mr. Cabral’s latest laughable and highly unethical offer, conveyed to me by my attorney, and which I caused to be placed on the court record, is that ‘if I want a misdemeanor’ I have to agree to a ‘stay away order’ not only against Jeannine English and Howard Dickstein, but also against all the people named in the search warrant, such as you, Tom Girardi, Holly Fujie, and others. When I inquired why would I have to agree to a ‘stay away’ from you and Girardi, for example, I was told it was a ‘special’ stay away order which would include conditions that for the next three years I have to agree to NOT FILE COMPLAINTS, ‘NOT SUE’ and ‘NOT BLOG’ about any of those mentioned in the search warrant and if I either file complaints, lawsuits or blog about those individuals, it would be considered a ‘probation violation.’

    3. This will serve to inform the State Bar of California Board of Trustees of the fact that I only recently discovered that former member George Davis has been secretly part of the AARP while concurrently serving as public member of the State Bar of California Board of Governors (‘BOG’). As you know, on June 12, 2011 I filed a complaint with the entire State Bar of California Board of Governors against then BOG member Jeannine English of AARP stemming from her conflicts of interest, self-dealing, breach of fiduciary duties, and failure to discloses a $900,000 Cy Pres award to AARP courtesy of Tom Girardi and Girardi & Keese during the time period the BOG was investigating my allegations dealing with the matter of In Re Girardi. As you know, the entire BOG took jurisdiction over of my complaint dealing with the matter of In Re Girardi, and once I discovered that the State Bar of California appointed Girardi’s own personal malpractice attorney (Jerome Falk of Howard Rice) as ‘special prosecutor’, the BOG ceased all communications with me.

    4. If not a bother, will it be possible for you to please make certain State Bar of California employee Teri Greenman respond to my request for documents previously submitted.

    Very truly yours,


  • Text of First Amended Complaint Against Lea Rosenberg, Yolo Lodge 169 Independent Order of Odd Fellows and Davis Rebekah Lodge; Grand Lodge of California; Independent Order of Odd Fellows; Davis Odd Fellows; Soroptimist International of Davis; Soroptimist International; Soroptimist International of the Americas; David Rosenberg; David Reed; Sheryl Cambron; Barbara Geisler; Virgil Smith; Robert Bockwinkel; Michael Cabral; Peter Martin, Keker & Van Nest, John Keker, Chris Young, Voice of OC, Erwin Chemerinsky, Skadden Arps, Mary Ann Todd , Munger Tolles & Olson, Jeff Bleich, Bradley Phillips, Ron Olson, Edison International, Berkshire Hathaway, Douglas Winthrop, Howard Rice, Holly Fujie, Buchalter Nemer, Raj Chatterjee, Morrison & Foerster, James Brosnahan, Thomas Girardi, Richard Tom , Southern California Edison , Wilson Sonsini, Mark Friedman, Fulcrum Properties, Mark Robinson, Geoffrey Brown, Arnold Porter, Mark Parnes, CaliforniaALL, Ruthe Catolico Ashley, Larissa Parecki, Morrison England, Torie Flournoy-England, Sarah Redfield, McGeorge School of Law, Cary Martin Zellerbach AKA Mary Ellen Martin Zellerbach, Martin Investment Management, Douglas Scrivner, Accenture, Freada Kapor Klein, Level Playing Field Institute, Ophelia Basgal, Pacific Gas & Electric Company, James Lewis, Verizon Communications, Darrell Steinberg, Kamala Harris, Michael Peevey, Steve Poizner, James Hsu, Sonnenschein Nath & Rosenthal and Does 1-100

    PART 1 — INTRODUCTION
    1. Plaintiff - an individual residing in Yolo
    County who is an investigative reporter and a Rabbi - has been subject
    to a campaign of systematic harassment ever since he uncovered
    corruption in various matters dealing with the California Public
    Utilities Commission; Democratic Party operatives; and Boyd Gaming
    Director, owner of various casinos, and class-action attorney Thomas
    Girardi (‘Girardi’) of Girardi & Keese in connection with financial
    corruption, obstruction of justice, and related acts of misconduct.

    2. For example, Plaintiff unearthed the fact that
    subsequent to being disciplined by the Ninth Circuit Court of Appeals
    stemming from an attempt to defraud the court by resorting to the ‘use
    of known falsehoods’, the State Bar of California appointed as
    ‘special prosecutor’ Girardi’s own private malpractice lawyer (Jerome
    Falk of Howard Rice) to prosecute Girardi on the State Bar’s behalf.
    (When later questioned about this matter, Falk asserted that his firm
    had represented the law firm of Girardi & Keese, but not Girardi
    himself.)
    3. Plaintiff also discovered corruption in a
    national class-action case (Fogel v. Farmers) in which Girardi - who
    represented the class of plaintiffs - never disclosed that the
    attorneys who represented defendant Farmers (Skadden Arps, Thomas
    Nolan, Raoul Kennedy) were concurrently representing Girardi himself
    in a separate legal matter. Very shortly after Plaintiff exposed the
    corruption, attorneys for Farmers approached, sought and obtained from
    the court a supplemental notice to the class of plaintiffs (consisting
    of 14 million Americans) indicating that if they cashed their
    settlement checks, they agreed to not sue Farmers or Girardi because
    of the undisclosed relationship.
    4. Plaintiff also unearthed corruption involving
    Girardi (who has a reputation of ‘bankrolling’ the California
    Democratic party) and individuals associated with the California
    Democratic Party with connections to the California Public Utilities
    Commission/Energy Commission (Michael Peevey, Tim Simon, Geoffrey
    Brown, Peter Arth, Joe Dunn, Martha Escutia, Darrell Steinberg) and
    utility lawyers involved in the ‘California Energy Crisis’ (Ron Olson
    and Jeff Bleich of Munger Tolles; James Brosnahan of Morrison &
    Foerster; John Keker of Keker & Van Nest; Jerry Falk and Douglas
    Winthrop of Howard Rice; Thomas Girardi of Girardi & Keese; Joe
    Cotchett of Cotchett, Pitre & McCarthy; Mark Robinson of Robinson
    Calcagnie Robinson; and the law offices of DLA Piper) to launder money
    from utility companies (SCE, PG&E, Verizon, AT&T) to various members
    of California’s Democratic Party (Joe Dunn, Martha Escutia, Kamala
    Harris, Jerry Brown, Kevin Johnson, Darrell Steinberg) and OBAMA FOR
    AMERICA via various non-profits (CaliforniaALL, Level Playing Field
    Institute, California Consumer Protection Foundation).
    5. Also involved in the various financial schemes were
    Cache Creek Casino, Sacramento-based developer Mark Friedman of
    Fulcrum Property, his business partner (gambling attorney Howard
    Dickstein), and Dickstein’s wife, Jeannine English, who was also
    acting on behalf of AARP to position Barack Obama in the White House
    and on behalf of Mark Friedman to position Kevin Johnson as the mayor
    of Sacramento. Additionally involved were Obama for America tech-guru
    Mitch Kapor and his wife, Freada Kapor Klein.
    6. In connection with the above discoveries,
    Plaintiff informed various law-enforcement agencies of these facts, as
    well as filed ethics complaints against some of the above named
    attorneys with the State Bar of California.
    7. Plaintiff was repeatedly warned that Girardi is
    ‘well-connected’ and will seek to silence Plaintiff as a result of
    Plaintiff’s discoveries and allegations.
    8. Indeed, very shortly after Plaintiff unearthed
    these events, a posse of eight armed investigators from the Yolo
    County District Attorney’s office executed an invalid search warrant
    at Plaintiff’s place of residence in Yolo County and confiscated all
    documents and computers in his home relating to, inter alia, various
    ethics complaints filed by Plaintiff on the ground that the ethics
    complaints were baseless.
    9. Plaintiff has been informed by credible sources,
    and therefore alleges, that David Rosenberg was one of those
    responsible for pressing criminal charges against him, that he
    ‘cleared the way’ for the search warrant, and that he is otherwise
    friendly with Howard Dickstein, Mark Friedman, Jerry Brown, Mark
    Robinson, and Chief Marshall McKay of Yocha Dehe Wintun Nation (all
    actors in CaliforniaALL — a sham non-profit launched for the purpose
    of laundering funds to finance the campaigns of various politicians,
    including President Obama, Kamala Harris, Kevin Johnson of Sacramento,
    and Governor Jerry Brown. )
    10. Venue in this case is proper in Yolo County because the acts and
    omissions of which Plaintiffs complain occurred in Yolo County.
    11. Plaintiff is unaware of the true names and capacities of the
    Defendants sued as Does 1 through 100, inclusive, and therefore sues
    these Defendants by such fictitious names. Plaintiff is informed and
    believes, and therefore alleges, that the Defendants herein designated
    as Does are legally responsible in some manner for the events and
    happenings referred to which caused the injuries to Plaintiff for
    which he now seeks damages. Plaintiff will amend this Complaint to
    allege their true names and capacities when ascertained.
    12. Plaintiff is informed and believes, and therefore alleges, that
    at all times mentioned herein, Defendants were the agents, servants,
    employees and/or joint venturers of the other Defendants and were at
    all times mentioned herein acting within the scope, course and
    authority of this agency, employment and/or joint venture. Plaintiff
    is further informed and believes and, therefore alleges, that each of
    the Defendants consented to, ratified, participated in, or authorized
    the acts of the remaining Defendants.
    PART 2: BACKGROUND OF FACTS UNDERLYING CLAIMS AGAINST LEA ROSENBERG
    AND RELATED INDIVIDUALS AND ENTITIES FOR VIOLATION OF CALIFORNIA’S
    BUSINESS & PROFESSIONS CODE § 17200 — PREDICATED ON 26 U.S. C. §
    6104(d)

    13. Following the execution of the invalid search
    warrant on Plaintiff’s home, described above, Plaintiff began
    conducting research into David Rosenberg’s background and learned that
    he is a judge with the Yolo County Superior Court with a reputation of
    being a ‘political animal’.
    14. Plaintiff further learned, and thereupon
    alleges, that Judge David Rosenberg and his wife (Lea Rosenberg), as
    well as Judge David Reed and his wife (Sheryl Cambron), are deeply
    involved — as either officers or directors — with a web of
    non-profit entities worth millions of dollars known as Saratoga
    Retirement Community, Meadows of Napa Valley, Davis Odd Fellows, Odd
    Fellows Homes of California, Davis Rebekah Lodge, Soroptimist
    International of Davis, David Odd Fellows Hall, and others. Plaintiff
    is informed and believes and therefore alleges that Lea and David
    Rosenberg are individuals residing in Yolo County.
    15. Later on, Plaintiff also discovered a pattern by
    which Lea Rosenberg and Sheryl Cambron — as the wives of two judges -
    were energetically raising funds from various businesses for an entity
    known as Progress Ranch headed by the foreperson of the Yolo County
    Grand Jury, Barbara Sommer. (For example, Davis Odd Fellows
    repeatedly held events to benefit Progress Ranch known as ‘Breakfast
    with Santa’; Soroptimist International of Davis held an event to
    benefit Progress Ranch known as ‘Texas Hold ’Em’; Davis Rebekah Lodge
    held an event to benefit Progress Ranch known as ‘Crab Feed.’) During
    the time period that Barbara Sommer served as foreperson of the Grand
    Jury of Yolo County, the grand jury was investigating two prominent
    entities — Cache Creek Casino (a casino which is owned and operated
    by Yocha Dehe Wintun nation headed by Marshall Mckay) and ‘First 5
    Yolo’ (headed by Yolo County Board of Supervisors member Don Saylor).
    16. Judge Rosenberg’s judicial campaign treasurer, Victor
    Bucher, is a nationally renowned expert in the area of accounting and
    tax fraud, and also serves as the ‘treasurer’ of a separate non-profit
    entity launched by David Odd Fellows — Davis Odd Fellows Charities,
    Inc. — where David Rosenberg serves as president and Victor Bucher as
    Treasurer.
    17. On April 4, 2013 — consistent with the
    statutory framework put into place by 26 U.S.C. § 6104(d) — Plaintiff
    served a request for Davis Odd Fellows and Davis Rebekah Lodge (which
    Plaintiff is informed and believes and therefore alleges are
    tax-exempt organizations) to make available for inspection their IRS
    990 forms.
    18. A tax-exempt organization must make available
    for public inspection its application for tax exemption, three most
    recent 990 annual information returns, and schedules and attachments
    available, pursuant to 26 U.S.C. § 6104(d), which reads, in relevant
    part:
    ‘Public inspection of certain annual returns, reports, applications
    for exemption, and notices of status
    (1) In general
    In the case of an organization described in subsection (c) or (d) of
    section 501 and exempt from taxation under section 501 (a) or an
    organization exempt from taxation under section 527 (a)—
    (A) a copy of—
    (i) the annual return filed under section 6033 (relating to returns by
    exempt organizations) by such organization,
    (ii) any annual return which is filed under section 6011 by an
    organization described in section 501 (c)(3) and which relates to any
    tax imposed by section 511 (relating to imposition of tax on unrelated
    business income of charitable, etc., organizations),
    (iii) if the organization filed an application for recognition of
    exemption under section 501 or notice of status under section 527 (i),
    the exempt status application materials or any notice materials of
    such organization, and
    (iv) the reports filed under section 527 (j) (relating to required
    disclosure of expenditures and contributions) by such organization,
    shall be made available by such organization for inspection during
    regular business hours by any individual at the principal office of
    such organization and, if such organization regularly maintains 1 or
    more regional or district offices having 3 or more employees, at each
    such regional or district office, and
    (B) upon request of an individual made at such principal office or
    such a regional or district office, a copy of such annual return,
    reports, and exempt status application materials or such notice
    materials shall be provided to such individual without charge other
    than a reasonable fee for any reproduction and mailing costs.
    The request described in subparagraph (B) must be made in person or in
    writing. If such request is made in person, such copy shall be
    provided immediately and, if made in writing, shall be provided within
    30 days.
    (2) 3-year limitation on inspection of returns
    Paragraph (1) shall apply to an annual return filed under section 6011
    or 6033 only during the 3-year period beginning on the last day
    prescribed for filing such return (determined with regard to any
    extension of time for filing).’
    19. Plaintiff delivered the request through Lea
    Rosenberg because she was the common denominator between the various
    ‘Odd Fellows’ entities and Soroptimist, in that she served as an
    officer and/or director of the various ‘Odd Fellows’ entities, and as
    president of Davis Rebekah Lodge.
    20. Specifically, on April 4, 2013 Plaintiff
    delivered to Lea Rosenberg at learose@jps.net the following email
    request:
    ‘Re: Request for Production of IRS Form 990, Form 990 Schedule A,
    Form 1023 to entities associated with Lea Rosenberg, to wit:
    Soroptimist International of Davis, Davis Rebekah Lodge, Davis Odd
    Fellows

    Dear Mrs. Rosenberg:

    Consistent with U.S. Internal Revenue Service Regulations, please
    consider this communication a formal request to produce their IRS Form
    990, Form 990 Schedule A, as well Form 1023. This request is for all
    documents submitted to the IRS within the past three years, which
    generally means the three most recent returns.

    Said regulations require that these documents be produced within 30
    days. Soroptimist International of Davis , Davis Rebekah Lodge, Davis
    Odd Fellows are entitled to charge reasonable costs for any copying
    and mailing costs incurred in relation to this request. Alternatively,
    you can email the documents to me as PDF attachments. I prefer the
    latter method. However, if for some reason, you prefer to copy and
    mail the documents, please send them to the following address:

    [—address intentionally omitted—]

    I ask that you draw no conclusion or develop any concern from the mere
    fact that this request is being made about you, Soroptimist
    International of Davis , Davis Rebekah Lodge, Davis Odd Fellows or any
    other individual or entity.

    In addition, I ask that you please produce the following:
    1. A detailed and complete list of all other non-profit entities you
    were involved beginning in 2008 to the present.
    2. A detailed and complete list of all sums which were transferred
    amongst any and all organizations you were involved, beginning in 2008
    to the present. For example, if in 2009 Soroptimist International of
    Davis transferred money to Davis Odd Fellows either as donation or
    rent, I ask that such transaction be disclosed.
    3. A detailed and complete list of all direct or indirect transfers of
    funds from Soroptimist International of Davis, Davis Rebekah Lodge,
    Davis Odd Fellows to Progress Ranch and/or any other entity associated
    with Barbara Sommer from 2007 to the present.

    Thank you for your time and anticipated cooperation. If you have any
    questions, please do not hesitate to contact me.’
    21. Plaintiff is informed and believes and therefore alleges
    that Lea Rosenberg received Plaintiff’s email dated April 3, 2013.
    22. On April 24, 2013, Plaintiff delivered to Lea
    Rosenberg a notice of change of address.
    23. Plaintiff is informed and believes and therefore alleges
    that Lea Rosenberg received Plaintiff’s requests for the
    organizations’ IRS 990 forms, and while conspiring with other
    Defendants, chose to breach the duty to comply with 26 U.S.C. §
    6104(d).
    24. Plaintiff is further informed and believes and
    therefore alleges that Defendants have directly performed, or aided,
    abetted, counseled, commanded, induced, procured, encouraged,
    promoted, instigated, advised, willfully caused, participated in,
    enabled, contributed to, facilitated, directed, controlled, assisted
    in, or conspired in the commission of the above-described acts.
    25. Due to this failure to comply with Plaintiff’s
    request, Plaintiff spent considerable time and resources trying to
    obtain those documents elsewhere, to no avail. Plaintiff asked his
    paid research-clerk to conduct further research on the Internet in
    hope of locating a complete set of the desired documents, also to no
    avail.
    26. Still seeking a complete set of the requested
    documents, on September 24, 2013 Plaintiff sent Lea Rosenberg the
    following email:
    “RE: Davis Odd Fellow Hall; Davis Odd Fellow - Second Request for
    Production of IRS Documents

    Dear Ms. Rosenberg:

    The purpose of this communication is to address the following matters:

    1. Since you appear to have been involved with Davis Rebekah Lodge,
    Davis Odd Fellow, and Sophomoric, I had previously asked you to
    produce the IRS tax-returns for those entities.

    For reasons which I do not understand, rather than complying with this
    simple request (as you are required to do by law given the fact that
    those entities are allowed to operate on a ‘tax-exempt’ status), you
    have failed to respond. I am therefore reiterating my request that you
    comply with the request for these tax returns and produce them to me
    within the next 5 days.

    As you know, I am troubled by events surrounding the almost exclusive
    fundraising to ‘emancipated foster youth’, Barbara Sommer, Davis Odd
    Fellow members Jonathan Raven and Michael Cabral, Cache Creek Casino,
    Vic Bucher, and Progress Ranch.

    I am also troubled by the fact that Judge Rosenberg (and his Judicial
    Campaign CPA Vic Bucher) lends money to the judicial campaign of other
    judges (i.e. Tim Fall and Dan Maguire). Hence, I would like to get to
    the bottom of things, and need the requested tax forms to do so.

    2. In the previously submitted request, there was no mention of ‘Davis
    Odd Fellow Hall.’ My position and understanding is that Davis Odd
    Fellow Hall is part of Davis Odd Fellow.
    Nevertheless, please consider this communication a formal request to
    also provide copies of the last three tax return forms that ‘Davis Odd
    Fellow Hall’ had submitted to the IRS.

    3. Given that Davis Odd Fellow, David Odd Fellow Hall, and Davis
    Rebekah Lodge are under the exclusive control of you, your husband
    David Rosenberg, as well as David Reed and his wife Cheryl Cambron,
    and given that both David Rosenberg and David Reed are judges of the
    Yolo County Superior Court, I submit that these entities have a duty
    to operate at an even higher level of transparency than mandated by
    the IRS, and must comply with the common law duty of disclosure.

    Thus, in addition to inspecting and copying the documents authorized
    by the IRS, I request copies of detailed financial statements (i.e.
    income, expenditures, names of donors, names of businesses and amount
    of rent Davis Odd Fellow Hall charges its various tenants, identity of
    subcontractors, identity of those who have rented the Hall etc.) For
    example, my understanding is that David Greenwald (publisher of The
    People’s Vanguard of Davis and Vanguard Court Watch) entered into a
    contract with Davis Odd Fellow Hall. Given that Mr. Greenwald’s
    publications purport to report on misconduct and malfeasance in the
    local area, including the courts, it appears to me that there is a
    direct conflict between this stated mission and his decision to rent
    space from an entity whose Board is comprised of you, and two Yolo
    County Superior Court judges.

    I am looking forward to hearing from you and receiving the requested documents.”
    27. Later that day, Plaintiff received an email
    response from Lea Rosenberg stating only the following: ‘so he is at
    it again.’
    FIRST CAUSE OF ACTION
    Violation of California Business and Professions Code § 17200 Predicated on
    26 U.S.C. § 6104(d)
    (Against Defendants Lea Rosenberg, Yolo Lodge 169 Independent Order of
    Odd Fellows and Davis Rebekah Lodge; Grand Lodge of California;
    Independent Order of Odd Fellows; Davis Odd Fellows; Soroptimist
    International of Davis; Soroptimist International; Soroptimist
    International of the Americas; and Does 1 - 100)

    28. Plaintiff incorporates paragraph by reference paragraphs 1
    – 27 as though fully set forth herein.
    29. Despite Plaintiff’s repeated requests,
    Defendants failed to comply with 26 U.S.C. § 6104(d). This failure
    constitutes unfair and unlawful acts pursuant to California’s Business
    & Professions Code § 17200.
    30. Plaintiff is informed and believes that
    Defendants have directly performed, or aided, abetted, counseled,
    commanded, induced, procured, encouraged, promoted, instigated,
    advised, willfully caused, participated in, enabled, contributed to,
    facilitated, directed, controlled, assisted in, or conspired in the
    commission of the above-described acts.
    31. As a proximate result of the unfair and unlawful
    acts of Defendants, as alleged above, Plaintiff suffered injury in
    fact and has lost money or property in an amount to be proven at
    trial.
    SECOND CAUSE OF ACTION
    Negligence Per Se / Torts in Essence
    (Against Defendants Lea Rosenberg, Yolo Lodge 169 Independent Order
    of Odd Fellows and Davis Rebekah Lodge; Grand Lodge of California;
    Independent Order of Odd Fellows; Davis Odd Fellows; Soroptimist
    International of Davis; Soroptimist International; Soroptimist
    International of the Americas; and Does 1 - 100)

    32. Plaintiff incorporates paragraph by reference paragraphs 1
    – 31 as though fully set forth herein.
    33. Plaintiff is informed and believes and therefore
    alleges that Defendants were all aware of Plaintiff’s repeated
    requests for the above-described entities’ IRS Form 990 forms, as
    described in this Complaint.
    34. Plaintiff is further informed and believes and
    therefore alleges that Defendants were under a duty to ensure
    compliance, yet chose to breach a duty prescribed in 26 U.S.C. §
    6104(d). This failure to comply with the statutory requirements
    constitutes negligence per se. In the alternative, Plaintiff further
    alleges that the failure to comply with the statutory requirements of
    26 U.S.C. § 6104(d) constitutes ‘torts in essence’ as a matter of
    public policy, because the statute at issue was enacted to benefit
    individuals in Plaintiff’s position, and because implied in 26 U.S.C.
    § 6104(d) is a private right of action.
    35. As a proximate result of Defendants’ breach of duty,
    as alleged above, Plaintiff spent considerable time and resources
    trying to obtain those documents elsewhere, to no avail. Plaintiff
    asked his paid research-clerk to conduct further research on the
    Internet in hope of locating a complete set of the desired documents,
    also to no avail. Plaintiff suffered injury in fact and has lost
    money or property in an amount to be proven at trial.
    36. Plaintiff further alleges that Davis Odd Fellows
    owns a Hall (‘Davis Lodge Hall’), on a property adjacent to the two
    Lodges, and is the owner (and landlord) of rental property currently
    occupied by Hunan Chinese Restaurant and Coldwell-Banker Doug Arnold
    Real Estate.
    37. The ‘Hall Board Association’ is a California
    corporation, and is the actual owner of the Davis Lodge Hall, the
    adjacent property of the two Lodges, and the rental property currently
    occupied by Hunan Chinese Restaurant and Coldwell-Banker Doug Arnold
    Real Estate.
    38. The ‘Hall Board Association’ is composed of
    President David Rosenberg, Vice President David Reed, Secretary Lea
    Rosenberg, Treasurer Sheryl Cambron, and Barbara Geisler.
    39. The Davis Lodge Hall is available to rent by the
    general public for receptions, fund-raisers, dinners, conferences,
    trade shows, meetings, and other events.
    40. The Davis Lodge Hall is also used by Davis Odd
    Fellows for its own functions, such as Davis Odd Fellows Bingo and
    Master Balls.
    41. In approximately September 2013, and after the
    expenditure of considerable time, resources, and efforts, Plaintiff
    managed to ascertain that the actual legal name of Davis Odd Fellows
    and David Rebekah Lodge is ‘Yolo Lodge 169 Independent Order of Odd
    Fellows and Davis Rebekah Lodge.’ Plaintiff then managed to obtain
    partial copies of tax returns that ‘Yolo Lodge 169 Independent Order
    of Odd Fellows and Davis Rebekah Lodge’ had submitted to the IRS.
    42. Upon reviewing partial copies of the
    above-described IRS 990 forms from 2010 and 2011, Plaintiff noted that
    false information had been submitted to the IRS on two occasions that
    he was able to identify from the incomplete forms. Specifically,
    according to those 990 forms, in 2010 David Reed served as the
    president of Yolo Lodge 169; serving as the Treasurer of Yolo Lodge
    was Sheryl Cambron. Plaintiff is informed and believes and therefore
    alleges that Reed and Cambron are married to each other.
    43. However, this was not the information provided
    to the IRS. The 2010 IRS Form 990 submitted by Yolo Lodge asked, ’Did
    any officer, director, trustee, or key employee have a family
    relationship or a business relationship with any other officer,
    director, trustee, or key employee?’ The form submitted by Yolo Lodge
    states, ‘NO.’ Since two of the officers (Reed and Cambron) were
    actually married to each other, this is a misrepresentation.
    44. In 2011, Yolo Lodge officers submitted false
    information to the IRS again, this time involving a different set of
    actors — Lea and David Rosenberg, who are married to each other.
    Specifically, in 2011 David Rosenberg served as President of Yolo
    Lodge; his wife, Lea Rosenberg, served as ‘Secretary’ of Yolo Lodge,
    and David Reed served as a board member.
    45. The 2011 IRS Form 990 submitted by Yolo Lodge
    asked, ’Did any officer, director, trustee, or key employee have a
    family relationship or a business relationship with any other officer,
    director, trustee, or key employee?’ The form submitted by Yolo Lodge
    states, ‘NO.’ Since two of the officers (David Rosenberg and Lea
    Rosenberg) were actually married to each other, this is a
    misrepresentation.
    46. Plaintiff is informed and believes and therefore
    alleges that Virgil Smith is a CPA, a member of Davis Odd Fellows, and
    a co-conspirator in the submission of these fraudulent tax-returns.
    Plaintiff is further informed and believes and therefore alleges that
    also responsible for submitting these fraudulent tax-returns were
    Davis Odd Fellows officers and directors David Rosenberg, Lea
    Rosenberg, David Reed, Sheryl Cambron, Barbara Geisler, and Robert
    Bockwinkel.
    47. Plaintiff is informed and believes and therefore
    alleges that the fraudulent tax-returns were submitted because David
    Rosenberg, Lea Rosenberg, David Reed, Sheryl Cambron, Barbara Geisler,
    Virgil Smith and Robert Bockwinkel did not want the IRS and the public
    to become aware that Sheryl Cambron is married to David Reed, and
    because they were concerned that if such relationships (i.e. Lea
    Rosenberg is married to David Rosenberg) would be disclosed, it may
    trigger an IRS audit.
    THIRD CAUSE OF ACTION
    Civil Conspiracy to Violate 26 U.S.C. § 6104(d)
    (Against Defendants Lea Rosenberg, David Rosenberg, David Reed, Sheryl
    Cambron, Barbara Geisler, Virgil Smith; Robert Bockwinkel; and Does 1
    – 100)

    48. Plaintiff incorporates paragraph by reference paragraphs 1
    – 47 as though fully set forth herein.
    49. Plaintiff is informed and believes and therefore
    alleges that subsequent to Plaintiff’s request to obtain copies of the
    relevant IRS forms 990 delivered to Lea Rosenberg as described above,
    Defendants Lea Rosenberg, David Rosenberg, David Reed, Sheryl Cambron,
    Robert Bockwinkel, Barbara Geisler, and Virgil Smith willfully and
    knowingly conspired and agreed among themselves to a scheme by which
    they agreed to violate Plaintiff’s legal rights by not complying with
    26 U.S.C. § 6104(d) because they were concerned he would discover the
    tax-fraud perpetrated on the IRS, as described above; that two Yolo
    County judicial officers (Rosenberg and Reed) and an attorney employed
    by Yolo County (Cambron) almost exclusively raised funds to support an
    entity headed by the Foreperson of the Yolo County Grand Jury; and the
    appearance that Davis Odd Fellows has been misused to indirectly curry
    favors with the foreperson of Yolo County Grand Jury.
    50. Plaintiff is further informed and believes and therefore
    alleges that as further overt acts (both lawful and unlawful) by
    which to advance the objective of said conspiracy, committed by one or
    more of the conspirators pursuant to their common design, were: (a) an
    agreement between Defendants to intentionally violate 26 U.S.C. §
    6104(d); (b) an agreement to ignore Plaintiff’s repeated requests for
    information sought pursuant to this statute; (c) a lawful overt act to
    belittle Plaintiff by sending him an email which reads, ‘so he is at
    it again’’ and (d) an agreement by Defendants to mislead and defraud
    Plaintiff by means of a plan they conceived and executed in which
    David Reed falsely stated in writing ‘TO MY KNOWLEDGE DAVIS ODD
    FELLOWS HAVE NEVER MADE CONTRIBUTIONS OR PARTICIPATED IN FUND-RAISING
    FOR PROGRESS RANCH’. (emphasis added)
    51. Plaintiff is further informed and believes and therefore
    alleges that Defendants have directly performed, or aided, abetted,
    counseled, commanded, induced, procured, encouraged, promoted,
    instigated, advised, willfully caused, participated in, enabled,
    contributed to, facilitated, directed, controlled, assisted in, or
    conspired in the commission of the above-described acts.

    PART 3 — Factual Background Dealing with In Re Girardi, Fogel v.
    Farmers, CaliforniaALL, Voice of OC
    3.1: IN RE GIRARDI
    52. In 2010, the United States Court of Appeals for the Ninth Circuit
    issued its final ruling in the disciplinary matter of In Re Girardi by
    imposing close to $500,000 in sanctions on Walter Lack of Engstrom
    Lispcomb & Lack and Thomas Girardi of Girardi & Keese stemming from an
    attempt to defraud the court and cause injury to Dole Food Company in
    the underlying litigation. Defending Girardi in the matter of In Re
    Girardi was Skadden Arps.
    53. The court ruled that Walter Lack (who stipulated to Special
    Prosecutor Rory Little that his prolonged acts of misconduct were
    intentional) and Thomas Girardi intentionally and recklessly resorted
    to ‘the persistent use of known falsehoods,’ and that the ‘false
    representations’ were made ‘knowingly, intentionally, and recklessly’
    during years of litigation.
    54. The Ninth Circuit suspended Lack, reprimanded Girardi, and
    ordered Girardi and Lack to report their misconduct to the State Bar
    of California.
    55. The State Bar of California disqualified itself from handling the
    matter since Howard Miller (of Girardi & Keese) served at that time as
    its president, and had also made the decision to hire then-chief
    prosecutor, James Towery.
    56. Plaintiff is informed and believes and thereon alleges that both
    Joe Dunn (Chief Executive of State Bar of California and a long time
    friend and protégé of Girardi) and Chief Justice Ronald George (father
    of Eric George — at the time co-counsel with Girardi and Lack in
    major class-action cases as part of an ongoing scheme by which Girardi
    was bestowing benefits on George) conspired to appoint as ‘Special
    Prosecutor’ Jerome Falk of Howard Rice, who they knew would
    ‘exonerate’ Girardi and Lack.
    57. Around the same time, renowned criminal defense attorney Doron
    Weinberg opined in the media as follows on the matter of In Re
    Girardi: ‘Prosecutors can admit the 9th Circuit’s disciplinary order,
    along with the entire record underpinning it’. ‘The State Bar
    generally respects the findings and conclusions of other
    jurisdictions’.
    58. Mr. Falk, in turn, exercised ‘prosecutorial discretion’ and
    concluded that he did not believe Lack acted intentionally and that no
    charges will be brought against the two attorneys — despite the fact
    that Lack had previously stipulated in writing that he acted
    ‘intentionally.’
    59. Within days of Mr. Falk’s decision, Plaintiff filed an ethics
    complaint with the State Bar of California against Jerome Falk, James
    Towery, Howard Miller, and Douglas Winthrop (managing partner of
    Howard Rice and then-elected president of the California Bar
    Foundation), alleging that it was improper for Mr. Towery to appoint
    Mr. Falk given the close personal relationship between Howard Miller
    and Douglas Winthrop. Specifically, Howard Miller — in his capacity
    as president of the State Bar — had appointed Douglas Winthrop as
    president of the California Bar Foundation.
    60. State Bar of California Deputy Executive director Robert Hawley
    contacted Plaintiff and informed him that he (Hawley) has been
    appointed as ‘contact person,’ and that the matter will be handled by
    the entire State Bar of California Board of Governors because one of
    the named actors was chief prosecutor James Towery.
    61. Specifically, on 12/27/2010 Robert Hawley wrote to Plaintiff in part:
    ‘On behalf of the State Bar of California its staff and its Board, I
    acknowledge receipt of your email message below and the one separately
    sent to James Towery, both on December 23, 2010.
    In your email message to Mr. Towery you state that you have sent a
    written letter of complaint to the Office of the Chief Trial Counsel
    (OCTC) Intake Unit. As we have previously advised your colleague
    Leslie Brodie, we provide status reports on pending matters involving
    OCTC only to individuals who provide verifiable identification
    information, including an address. I assume that your written
    complaint provides this information. If not, we will not be able to
    provide you with further status information on the subject of your
    email messages.’
    62. At or about that time, Plaintiff was unaware of the fact that
    several other Board members had business relationships with Girardi or
    other conflicts of interest which they were required to disclose
    pursuant to a statute.
    63. After several months, Mr. Hawley wrote Plaintiff, informing him
    the investigation was closed.
    64. A few weeks later, Plaintiff, while researching a separate topic,
    discovered that Howard Rice (the firm of Jerome Falk) actually
    represented Girardi & Keese and Engstrom Lipscomb & Lack in a
    malpractice action only two years prior (Copple v. Astrella & Rice).
    65. On August 29, 2011 Plaintiff informed Robert Hawley and the
    entire Board of Governors (consisting of, among others, Laura Chick,
    Gwen Moore, Dennis Mangers, Jeannine English, George Davis, Alec Chang
    of Skadden Arps, Gretchen Nelson of Kreindler & Kreindler, Jon
    Streeter of Keker & Van Nest, and Joe Dunn of Voice of OC about the
    recent discovery in order to re-open the investigation. Plaintiff is
    informed and believes and therefore alleges that, pursuant to an
    ongoing conspiracy to obstruct justice in the matter of In Re Girardi
    and an ongoing conspiracy to violate Plaintiff’s due process and equal
    protection rights, Hawley never replied to Plaintiff’s inquiries, nor
    did any member of the Board of Governors.
    66. Plaintiff is informed and believes and therefore alleges that
    said conspiracy was motivated in part by Democratic Party operatives
    such as Joe Dunn and Jeannine English to protect Thomas Girardi
    because of financial contributions to the Democratic Party, because
    Girardi arranged close to one million in cy pres awards to California
    AARP (where Jeannine English served as president), and because several
    BOG member had similar conflicts of interest, such as Alec Chang of
    Skadden Arps.
    67. Plaintiff is informed and believes and therefore alleges that the
    various wrong-doers became extremely concerned of the fact that
    Plaintiff discovered that Falk represented Girardi & Keese and Walter
    Lack, and because of Plaintiff’s whistle-blowing activities and robust
    use of his free-speech rights. As such, on December 7, 2011, out of
    the blue, Falk - Plaintiff alleges in an attempt to mislead Plaintiff
    –- wrote to Plaintiff:
    ‘I received your November 13 email, sent to me and many others,
    concerning my participation in the State Bar’s investigation of Walter
    J. Lack, Thomas V. Girardi and other attorneys. It is filled with
    disparaging characterizations, all of which seem to stem from your
    allegations that I or my firm have represented Mr. Lack and Mr.
    Girardi.
    Your allegations are false.
    I have never represented either person, or their firms. Neither has
    Douglas Winthrop. Nor has my firm ever represented Mr. Lack or Mr.
    Girardi. From 2006-2008, my firm represented several law firms,
    including Engstrom, Lipscomb & Lack and Girardi & Keese, in a
    litigation matter. The public records of that litigation show that
    neither Mr. Winthrop nor I had nothing to do with that representation;
    in fact, I was unaware of it. The public records also show that my
    firm represented the law firms, but did not represent Mr. Girardi or
    Mr. Lack. The attorney responsible for that representation had left
    Howard Rice and taken the files with him before I was asked to serve
    as Special Deputy Trial Counsel in the State Bar matter.
    You are on notice that your allegations are false. The falsity of
    those allegations can be determined from the public records of the
    litigation in question. Do not make them again.’
    4.2: FOGEL VS. FARMERS:
    68. The day after the Ninth Circuit issued the published decision in
    the matter of In Re Girardi, respondents’ counsel (Skadden Arps and
    Thomas Nolan) moved to redact their names from the decision. The
    court rejected the request, noting that redaction was not merited.
    69. The peculiar nature of the motion to redact the names of
    respondents’ counsel from the published decision of this court
    prompted Plaintiff to look into the matter further. Plaintiff then
    discovered that, beginning in 2003, Girardi & Keese and Engstrom
    Lipscomb & Lack were prosecuting a class action case against Farmers
    Insurance Company, which was represented by Skadden Arps. This was a
    nationwide class action with estimated damages of close to $15 billion
    that had originally been filed by Texas Governor Rick Perry.
    70. In March, 2011 Plaintiff submitted an ethics complaint to the
    State Bar of California against Skadden Arps and Girardi & Keese for
    various acts of misconduct in connection with Fogel v. Farmers Group,
    Inc. and the matter of In Re Girardi.
    71. The complaint alleged ethical violations stemming from collusion
    between the law offices of Girardi & Keese and Skadden Arps based on
    the fact that while the matter of Fogel vs. Farmers Group was pending,
    the law offices of Skadden Arps and Girardi & Keese entered into a
    wholly separate agreement by which Skadden Arps agreed to represent
    Girardi & Keese in the matter of In Re Girardi without informing the
    class of plaintiffs (consisting of 14 million Americans), nor the
    courts (the Ninth Circuit in the matter of In Re Girardi and the Los
    Angeles County Superior Court in the matter of Fogel vs. Farmers) of
    the concurrent representation by which Skadden Arps represented
    Girardi & Keese (in the Ninth Circuit matter), while at the same time
    defending Farmers against Girardi and Keese’s clients (in the Fogel
    vs. Farmers matter).
    72. Shortly after Plaintiff filed this ethics complaint, Skadden Arps
    moved ex parte (which, not surprisingly, was unopposed) to amend the
    settlement agreement in the Fogel matter and the notice to the class
    of 14 million Americans throughout the country to include a proviso by
    which members of the class would be prohibited from suing anyone due
    to the concurrent representation described above. Nevertheless, the
    State Bar of California decided not to take any action on this ethics
    complaint.
    73. In or around August of 2011, Plaintiff submitted an informal
    objection to the proposed Fogel v. Farmers settlement based on the
    reasoning described above and contemplated filing an appeal (if
    possible) or informally alerting the Court of Appeal of the collusive
    arrangement.
    4.3: CALIFORNIAALL / VOICE OF OC / OBAMA FOR AMERICA / QUADRIPLEGIC
    UC DAVIS LAW STUDENT SARA GRANDA / SEARCH- SEIZURE BY YOLO COUNTY
    DISTRCIT ATTORNEY
    CaliforniaALL — Voice of OC:
    74. While researching the relationship of Girardi & Keese and Howard
    Rice and the appointment of Douglas Winthrop as president of the
    California Bar Foundation by Howard Miller of Girardi & Keese,
    Plaintiff reviewed the California Bar Foundation’s annual reports to
    familiarize himself with the names of the Foundation’s board of
    directors. Plaintiff stumbled upon the fact that the Foundation ended
    2008 close to $500,000 in the negative. Specifically, the Foundation
    reported to the IRS that REVENUE LESS EXPENSES in 2007 equaled plus
    +$373.842.00. However, in 2008, the Foundation reported to the IRS
    that REVENUE LESS EXPENSES equaled minus -$537,712.
    75. Plaintiff discovered that the money had been transferred to a
    newly-created Section 501(c)(3) non-profit entity (headed by Ruthe
    Catolico Ashley — close friend and confidant of Chief Justice Tani
    Cantil-Sakayue) known as CaliforniaALL, which obtained hundreds of
    thousands of dollars from utility companies PG&E, SCE, AT&T, and
    Verizon.
    76. In addition to Ruthe Catolico Ashley, CaliforniaALL was
    compromised of the following: Larissa Parecki, Morrison England,
    Torie Flournoy-England, Sarah Redfield of McGeorge School of Law,
    Cary Martin Zellerbach AKA Mary Ellen Martin Zellerbach of Martin
    Investment Management, Douglas Scrivner of Accenture, Freada Kapor
    Klein of Level Playing Field Institute, Ophelia Basgal of Pacific Gas
    & Electric Company, James Lewis of Verizon Communications, Darrell
    Steinberg, Kamala Harris, Michael Peevey, Steve Poizner, an James Hsu
    of Sonnenschein Nath & Rosenthal-Dentons.
    77. Plaintiff is informed and believes and therefore alleges that
    CaliforniaALL funneled some portion of the money to the UCI Foundation
    –- where State Bar of California Executive Director Joe Dunn, Judicial
    Council member Mark Robinson, and Erwin Chemerinsky served as trustees
    for the purpose of launching a new entity known as Saturday Law
    Academy at UCI. (‘SALUCI’)
    78. Plaintiff is informed and believes and therefore alleges that
    SALUCI was actually already created in 2005 and was fully operational
    before CaliforniaALL arrived on the scene.
    Plaintiff further alleges that repeated claims by CaliforniaALL,
    including the following, were knowingly false, misleading, and
    fraudulent: ‘Our first funded pipeline, the Saturday Academy of Law,
    graduated its first class on March 7’; ‘An inspirational welcome
    given by Dean Erwin Chemerinsky as 200 guests gathered at the Delhi
    Community Center to recognize the first graduating class of the UC
    Irvine Saturday Academy of Law. The six-week program, created by UCI’s
    Center for Educational Partnerships was made possible by a grant from
    CaliforniaALL.’
    FOURTH CAUSE OF ACTION
    Violation of California Business and Professions Code § 17200
    (Against defendants CaliforniaALL, Ruthe Catolico Ashley, Larissa
    Parecki, Morrison England, Torie Flournoy-England, Sarah Redfield,
    McGeorge School of Law, Cary Martin Zellerbach AKA Mary Ellen Martin
    Zellerbach, Martin Investment Management, Douglas Scrivner, Accenture,
    Freada Kapor Klein, Level Playing Field Institute, Ophelia Basgal,
    Pacific Gas & Electric Company, James Lewis, Verizon Communications,
    Darrell Steinberg, Kamala Harris, Michael Peevey, Steve Poizner, James
    Hsu, Sonnenschein Nath & Rosenthal-Dentons and Does 1-100)

    79. Plaintiff incorporates paragraph by reference paragraphs 1
    – 78 as though fully set forth herein.
    80. The knowingly false, misleading and fraudulent
    claims by which executives and directors of CaliforniaALL took credit
    and falsely advertised that CaliforniaALL was instrumental in
    launching SALUCI which ‘graduated its first class’ constitutes
    unfair and unlawful acts pursuant to California’s Business &
    Professions Code § 17200 since SALUCI already came into existence in
    2005.
    81. Plaintiff is informed and believes and therefore
    alleges that Defendants have directly performed, or aided, abetted,
    counseled, commanded, induced, procured, encouraged, promoted,
    instigated, advised, willfully caused, participated in, enabled,
    contributed to, facilitated, directed, controlled, assisted in, or
    conspired in the commission of the above-described acts.
    82. As a proximate result of the unfair and unlawful
    acts of Defendants, as alleged above, Plaintiff suffered injury in
    fact and has lost money or property in an amount to be proven at
    trial.
    83. On February 28, 2011, Plaintiff informed the State Bar Board of
    Governors and officially requested an investigation into alleged
    fraudulent transactions, financial irregularities, and unlawful
    conduct in connection with circumstances surrounding CaliforniaALL.
    Later that day, State Bar of California Foundation Director and CPUC
    Commissioner Geoffrey Brown sent Plaintiff the following:
    ‘I am named in the email with the purpose of tying my tenure at the
    CPUC and the Foundation to some alleged nefarious activity. The author
    of the email is herewith put on notice that I will pursue legal action
    if he persists in a claim that I have anything to do with illegal
    activity. He is further on notice that I am in no way connected with
    the recipient named in the article.’
    84. Plaintiff is further informed and believes and therefore alleges
    that during his tenure as California Bar Foundation Director, Geoffrey
    Brown, as well as Jeff Bleich and Bradley Phillips of Munger Tolles &
    Olson, Douglas Winthrop of Howard Rice-Arnold Porter, Holly Fujie of
    Buchalter Nemer, and Mark Parnes of Wilson Sonsini caused the
    following false and misleading advertisement to appear in the annual
    report: California Bar Foundation supported the launching of
    CaliforniaALL and, as the project filed for incorporation and
    501(c)(3) tax-exempt status, served as CaliforniaALL’s fiscal
    sponsor. A collaboration between the California Public Employment
    Retirement System, the California Public Utilities Commission, the
    California Department of Insurance, and the State Bar of California,
    CaliforniaALL was created in an effort to close the achievement gap
    among California students from preschool to the profession and,
    specifically, to bolster the pipeline of young people of diverse
    backgrounds headed for careers in law, financial services, and
    technology. Once CaliforniaALL obtained its tax-exempt status and was
    able to function as a fully independent nonprofit organization, the
    Foundation granted the balance of funds raised for the project -
    totaling $769,247 - to the new entity. We thank the following
    corporations for their gifts in support of CaliforniaALL: AT & T
    ,Edison International ,PG & E Corporation Foundation , and Verizon.
    85. Plaintiff is further informed and believes and therefore alleges
    that the California Bar Foundation never served as the ‘fiscal
    sponsor’ of CaliforniaALL. Plaintiff is further informed and believes
    and therefore alleges that that AT&T, Edison International, PG & E
    Corporation Foundation, and Verizon never used the California Bar
    Foundation as a ‘fiscal sponsor’, and any and all funds from AT & T,
    Edison International, PG & E Corporation Foundation, and Verizon went
    directly to CaliforniaALL.
    FIFTH CAUSE OF ACTION
    Violation of California Business and Professions Code § 17200
    (Against Defendants Geoffrey Brown, Jeff Bleich , Bradley Phillips,
    Munger Tolles & Olson, Douglas Winthrop, Howard Rice, Arnold Porter,
    Holly Fujie, Buchalter Nemer, Mark Parnes, Wilson Sonsini and Does
    1-100)

    86. Plaintiff incorporates paragraph by reference paragraphs 1
    – 85 as though fully set forth herein.
    87. The knowingly false, misleading and fraudulent
    claims by which executives and directors of the California Bar
    Foundation falsely asserted that $769,247 originated from AT&T, Edison
    International, PG & E Corporation Foundation, and Verizon constitute
    unfair and unlawful acts pursuant to California’s Business &
    Professions Code § 17200.
    88. Plaintiff is informed and believes that
    Defendants have directly performed, or aided, abetted, counseled,
    commanded, induced, procured, encouraged, promoted, instigated,
    advised, willfully caused, participated in, enabled, contributed to,
    facilitated, directed, controlled, assisted in, or conspired in the
    commission of the above-described acts.
    89. As a proximate result of the unfair and unlawful
    acts of Defendants, as alleged above, Plaintiff suffered injury in
    fact and has lost money or property in an amount to be proven at
    trial.

    90. Plaintiff is informed and believes and therefore alleges that a
    significant portion of the $769,247 from the California Bar Foundation
    to CaliforniaALL ended up financing a newly-created online publication
    which Joe Dunn had launched with the help of Thomas Girardi, James
    Brosnahan of Morrison & Foerster (attorney for CaliforniaALL) and
    Erwin Chemerinsky — this online publication is known as "Voice of OC.
    91. Plaintiff requested that Voice of OC provide him with copies of
    its IRS 990 forms. Voice of OC did not comply with applicable IRS
    regulations in that it failed to reply to Plaintiff’s request for
    copies, whereupon Plaintiff filed a complaint against Voice of OC and
    Joe Dunn with the IRS.
    92. The IRS promptly sent Plaintiff notice acknowledging the
    complaint against Voice of OC.
    93. Very shortly after Plaintiff had complained to the IRS, the FBI
    arrested Kinde Durkee — CPA for Voice of OC — on unrelated charges.
    94. Plaintiff is informed and believes and therefore alleges that
    CaliforniaALL was also misused to finance the election campaigns of
    Kevin Johnson, Kamala Harris, Jerry Brown, and Barack Obama,
    specifically by the following actors:
    Morrison & Foerster: James Brosnahan (self-proclaimed ‘mastermind’
    behind the Democratic Party; member of OBAMA FOR America’s California
    Finance Committee; Legal Counsel for CaliforniaALL ); Tony West (OBAMA
    FOR America’s Chair of California’s Finance Committee); Chris Young —
    later of Keker & Van Nest (OBAMA FOR America’s Northern California
    Deputy Finance Director); Annette Carnegie (former director of the
    California Bar Foundation during the transfer of the approximately
    $780,000 to CaliforniaALL).
    Munger Tolles & Olson: Jeffrey Bleich (president of the State Bar of
    California, director of the California Bar Foundation, and founding
    member and Chair of OBAMA FOR America’s National Finance Committee);
    Brad Phillips (2007- 2008 Director of the California Bar Foundation
    which served as a ‘financial sponsor’ to CaliforniaALL on behalf of
    Verizon Wireless and Southern California Edison, both clients of
    Munger Tolles & Olson); Ron Olson (member of OBAMA FOR AMERICA;
    Berkshire Hathaway and Edison Director).
    Wilson Sonsini: Mark Parnes (2007-2008 director and Secretary of the
    California Bar Foundation); John Roos (former CEO of Wilson Sonsini
    and member of OBAMA FOR America’s National Finance Committee).
    DLA Piper: Steven Churchwell of DLA Piper in Sacramento (Treasurer,
    draft committee of OBAMA FOR AMERICA; firm where CaliforniaALL
    resided free of charge); Gilles Attia.
    Laura Chick (member of the State Bar of California Board of Governors
    and OBAMA FOR AMERICA).
    Kamala Harris (Co-Chair, OBAMA FOR AMERICA and member of
    CaliforniaALL Advisory Council).
    Freada Klein Kapor (member of CaliforniaALL board of directors; OBAMA
    FOR America’s phone bank located at The Kapor Center).
    Chris Young, Mark Friedman of Fulcrum Properties, and business
    partner Marshall McKay of Cache Creek Casino on behalf of Barack
    Obama.
    Chris Young, Mark Friedman of Fulcrum Properties on behalf of Kevin Johnson.
    ETHICS COMPLAINT IN RE UC DAVIS LAW STUDENT SARA GRANDA:
    95. In May 2009, U.C. Davis School of Law quadriplegic law student
    Sara Granda graduated from and hoped to sit for the July 2009 bar
    exam.
    96. The California’s Department of Rehabilitation paid the exam fee
    for Granda with a check, and Granda was assured that she was properly
    registered. However, the State Bar of California never processed
    Granda’s application because the Department of Rehabilitation paid the
    fee with a check, rather than a credit card.
    97. Granda filed a suit in federal court seeking an injunction
    directing the State Bar of California to allow her to sit for the bar
    exam. The action was titled Sara Granda v. the State Bar of
    California (Case Number 2:09-cv-02015-MCE). The State Bar of
    California was represented by Mark Torres Gil, Rachel Grunberg, and
    Lawrence Yee. The matter was adjudicated by Judge England of the
    Eastern District of California, who promptly dismissed it.
    98. During the course of presiding over the Granda case, Judge
    England never disclosed to Granda that he and his wife (Torie
    Flournoy-England) are part and parcel of an entity known as
    CaliforniaALL — which had just obtained close to $800,000 from the
    State Bar of California — headed by executive-director Judy Johnson,
    who is also part of CaliforniaALL. Similarly neither did the State
    Bar of California, Judy Johnson, Mark Torres Gil, Rachel Grunberg, or
    Lawrence Yee provide this information to Granda.
    99. On May 31, 2011, Plaintiff advanced an ethics complaint against
    State Bar of California attorneys Lawrence Yee, Mark Torres-Gil,
    Rachel Grunberg, Judy Johnson, and Holly Fujie.
    100. The complaint alleged misconduct due to the failure of the
    above-named attorneys to disclose to Plaintiff Granda the nature of
    the close personal relationship between the State Bar of California,
    CaliforniaALL, Judy Johnson, Judge England and his spouse — Terrie
    Flournoy-England.
    101. Plaintiff alleges the entire complaint filed by him was
    factually accurate, truthful, and was brought in good faith.
    Accompanying the complaint dated May 31 2011 were 11 exhibits in
    support.
    102. Plaintiff is informed and believes and therefore alleges that
    the State Bar of California received said complaint and rather than
    assign an outside investigator due to the fact it was against their
    own attorneys, summarily dismissed it.
    103. On July 28, 2011, State Bar employee Jill Sperber wrote to
    Plaintiff informing him that:
    ‘I have determined that your complaint fails to present stuffiest
    facts to substantiate an investigation.’
    “The State Bar had no involvement with CaliforniaALL once it was
    incorporated and operating.”
    ‘Several of the informational items that you list are not factually
    accurate a) CaliforniaALL and State Bar are partners and B) a sub-rosa
    transfer of funds from State Bar to CaliforniaALL took place.’
    104. Sperber never alleged that the complaint filed by Plaintiff was
    frivolous or ‘without merit.’
    105. Plaintiff submits that the 11 exhibits accompanying his
    complaint showed beyond any doubts that the California Bar and
    CaliforniaALL were partners, and that State Bar executive directors
    (Judy Johnson) and employee Patricia Lee were part of CaliforniaALL.
    As such, Plaintiff is informed and believes and thereon alleges that
    the claim by Ms. Sperber that ‘The State Bar had no involvement with
    CaliforniaALL once it was incorporated and operating’ is false, that
    the State Bar Board of Governors continued to appoint directors to
    CaliforniaALL, and that CaliforniaALL never acknowledged the
    approximate $780,000 it obtained from the California Bar Foundation,
    demonstrating that the transfer was sub-rosa.
    Search-Seizure of CaliforniaALL Evidence By Investigators From Yolo
    County District Attorney
    106. On February 23, 2012, eight armed investigators from the Yolo
    County District Attorney’s office arrived at Plaintiff’s place of
    residence, searched the premises, and confiscated two computers, flash
    drives, and documents pursuant to an invalid search warrant issued by
    Yolo County Superior Court Judge Timothy Fall.
    107. The invalid search warrant listed the names of Joe Dunn (of
    Voice of OC) ,Thomas Girardi (of Voice of OC, In Re Girardi) , Judy
    Johnson, Holly Fujie, Alec Chang of Skadden Arps, James Towery,
    Howard Dickstein, Jeannine English, and State Bar attorneys Mark
    Torres Gil, Lawrence Yee, and Rachel Grunberg.
    108. Plaintiff is informed and believes, and therefore alleges that
    accompanying the DA officers was a private citizen named Tom Layton.
    109. Plaintiff was told that by the investigators and Michael Cabral
    that the State Bar Board of Governors was pressing criminal charges
    against Plaintiff for, among other things, violations of B & P
    Section 6043.5 (filing false and malicious ethics complaints) because
    of the ethics complaint Plaintiff submitted in connection with U.C.
    Davis School of Law quadriplegic law student Sara Granda.
    110. Plaintiff is informed and believes, and therefore alleges that,
    in approximately early 2011, once Plaintiff unearthed the various acts
    of misconduct described above — such as In Re Girardi, Fogel v.
    Farmers, Voice of OC, and especially fraud dealing with CaliforniaALL
    (an entity Plaintiff is informed and believes and therefore alleges
    was launched, represented, directed, or benefited by extremely
    powerful politicians such as California Attorney General Kamala
    Harris, Jerry Brown, Darrel Steinberg, Kevin Johnson, Joe Dunn, and
    Obama for America; governmental officials such as CPUC’s Michael
    Peevey, Geoffrey Brown; powerful law firms such as DLA Piper, Morrison
    & Foerster, Munger Tolles, Dentons, and Girardi & Keese; major utility
    companies such as PG&E, Verizon, and Southern California Edison; major
    corporations such as Accenture, Fulcrum Property/Mark Friedman, Cache
    Creek Casino/Marshall McKay, LPFI/ Freada Kapor; and members of the
    California Judicial Council (such as Mark Robinson, Tani Cantil), an
    understanding was reached to silence Plaintiff at any cost, to
    retaliate against him because of his speech-related activates, to try
    to intimidate him, and to confiscate all the incriminating evidence he
    had gathered.
    111. Plaintiff is also informed and believes and therefore alleges
    that Jon Streeter of Keker & Van Nest — a ‘bundler’ for Barack Obama
    who served as president of the State Bar of California and was aware
    of Plaintiff’s discovery of CaliforniaALL due to the fact that
    Plaintiff requested documents and sought an investigation —
    immediately informed Keker & Van Nest, John Keker and associate Chris
    Young of Plaintiff’s discoveries.
    112. Plaintiff is informed and believes and therefore alleges that
    Keker & Van Nest associate Chris Young — who caused the launching of
    CaliforniaALL two years prior while serving as Obama for America
    California Deputy Finance Director, and who later worked with Jeffrey
    Bleich as White House Adviser, and who later worked with Mark
    Friedman on the election campaign of Kevin Johnson — panicked. As
    such, Chris Young’s attorney profile was quickly removed from the
    KVN.COM web-site. This fraud was only discovered by Plaintiff months
    later.
    Specifically, Plaintiff is informed and believes and therefore alleges
    that State Actor Streeter, who also served as a Director of the
    California Bar Foundation, conspired with nongovernmental agents of
    CaliforniaALL, original actors Freada Kapor and Mary Ann Todd of
    Munger Tolles (on behalf of Jeff Bleich, Bradley Phillips, Ron Olson,
    Edison International, Berkshire Hathaway), Douglas Winthrop of Howard
    Rice, Holly Fujie of Buchalter Nemer, Raj Chatterjee of Morrison &
    Foerster, and Richard Tom of Southern California Edison to injure
    Plaintiff, to retaliate against him because of his speech-related
    activates, and to confiscate all the incriminating evidence he had
    gathered.
    113. Plaintiff is informed and believes and therefore alleges that
    Streeter — who served as a ‘bundler’ for Barack Obama’s campaign —
    was also motivated to silence Plaintiff lest information he possessed
    would cause President Obama to lose his re-election bid.
    114. Plaintiff is also informed and believes and therefore alleges
    that Joe Dunn reached an understanding with Erwin Chemerinsky of
    Voice of OC, as well as original Voice of OC directors Thomas Girardi
    and James Brosnahan of Morrison & Forester, to misuse his authority as
    a state actor to silence and retaliate against Plaintiff.
    115. Plaintiff is also informed and believes and therefore alleges
    that James Brosnahan of Morrison & Foerster and Jon Streeter of Keker
    & Van Nest met with Judicial Council members Tani Cantil, David
    Rosenberg, Angela Davis, and Mark Robinson to discuss potential
    courses of action. Plaintiff is further informed and believes and
    therefore alleges that, during said meeting, an agreement was reached
    by which David Rosenberg — who also serves as a judge with the Yolo
    County Superior Court — would ‘clear the way’ for the issuance of a
    search warrant of Plaintiff’s home lacking in probable cause.
    Moreover, Plaintiff is also informed and believes and therefore
    alleges that due to concerns of leaks by disc rental Judicial Council
    employees expressed by Tani Cantil, Rosenberg agreed to unlawfully
    arrange for the search warrant to also include the names of Joseph
    Dunn and Starr Babcock in order to ascertain Plaintiff’s sources of
    information, if any.
    116. As such, Plaintiff is informed and believes and therefore
    alleges that, acting to serve their own financial interest and on
    behalf of CaliforniaALL actors named above and pursuant to a
    widespread conspiracy between private citizens and state actors, and
    while acting under color of state law, the entire State Bar of
    California Board of Governors (including Jon Streeter of Keker & Van
    Nest — acting also pursuant to a separate conspiracy with KVN, John
    Keker, Chris Young, Mark Friedman of Fulcrum Property), and California
    Bar Foundation directors Mary Ann Todd , Holly Fujie, Douglas
    Winthrop; Joe Dunn of Voice of OC, Jeannine English and George Davis
    of AARP, Laura Chick of Obama for America, Alec Chang of Skadden Arps
    –- acting on behalf client Tom Girardi, Gretchen Nelson of Kreindler &
    Kreindler) chose to adopt a plan by which they would unlawfully use
    the fact that they are also clothed with the authority of state law to
    knowingly and maliciously press false criminal charges against
    Plaintiff for the alleged violation of California Business &
    Professions 6043.5 which reads:
    (a)Every person who reports to the State Bar or causes a complaint to
    be filed with the State Bar that an attorney has engaged in
    professional misconduct, knowing the report or complaint to be false
    and malicious, is guilty of a misdemeanor.
    (b)The State Bar may, in its discretion, notify the appropriate
    district attorney or city attorney that a person has filed what the
    State Bar believes to be a false and malicious report or complaint
    against an attorney and recommend prosecution of the person under
    subdivision (a).
    117. Plaintiff is informed and believes and therefore alleges that
    the objective of the conspiracy was to knowingly and maliciously
    submit a false criminal complaint to the Yolo County District Attorney
    against Plaintiff, and for a search/seizure to be executed on
    Plaintiff’s home to confiscate all evidence he had gathered in regard
    to the above-described matters, and in order to retaliate and
    intimidate him into silence, especially in matters dealing with In Re
    Girardi, Fogel v. Farmers, Voice of OC, and CaliforniaALL.
    118. Plaintiff is informed and believes and therefore alleges that
    around February of 2012, as an overt act in furtherance of said
    conspiracy, representatives of the State Bar of California knowingly,
    maliciously, and without probable cause pressed false criminal charges
    against Plaintiff alleging, inter alia, violation of California
    Business & Professions 6043.5
    SIXTH CAUSE OF ACTION
    Violation of California Business and Professions Code § 17200
    Predicated on California Penal Codes 148.5 and 182
    (Against Defendants Keker & Van Nest, John Keker, Chris Young, Voice
    of OC, Erwin Chemerinsky, Skadden Arps, Freada Kapor Klein, Mary Ann
    Todd, Munger Tolles, Jeff Bleich, Bradley Phillips, Ron Olson, Edison
    International, Berkshire Hathaway, Douglas Winthrop, Howard Rice,
    Holly Fujie, Buchalter Nemer, Raj Chatterjee, Morrison & Foerster,
    James Brosnahan, Richard Tom, Southern California Edison, Wilson
    Sonsini, Mark Friedman, Fulcrum Properties, Mark Robinson, and Does 1
    – 100)

    119. Plaintiff incorporates paragraph by reference paragraphs 1 - 118
    as though fully set forth herein.
    120. Plaintiff is informed and believes and therefore
    alleges that Defendants willfully and knowingly conspired and agreed
    among themselves to a scheme by which they agreed to violate
    Plaintiff’s legal rights in violations of California Penal Codes 148.5
    and 182. This constitutes unfair and unlawful acts pursuant to
    California’s Business & Professions Code § 17200.
    121. Plaintiff is informed and believes that Defendants have directly
    performed, or aided, abetted, counseled, commanded, induced, procured,
    encouraged, promoted, instigated, advised, willfully caused,
    participated in, enabled, contributed to, facilitated, directed,
    controlled, assisted in, or conspired in the commission of the
    above-described acts.
    122. As a proximate result of the unfair and unlawful acts
    of Defendants, as alleged above, Plaintiff suffered injury in fact and
    has lost money or property in an amount to be proven at trial.
    __________________________________

    123. Plaintiff is informed and believes and therefore alleges that on
    February 21, 2012 Chief Investigator of Yolo County District Attorney
    Bruce Naliboff presented to Yolo County Superior Court Judge Timothy
    Fall an invalid and meaningless ‘Statement of Probable Cause’ in
    support of a search warrant stating, inter alia, that a search of
    Plaintiff’s residence and vehicle may reveal both written and
    electronically recorded information of criminal conduct because
    Plaintiff’s ethics complaint dealing with Sara Granda constituted a
    misdemeanor in violation of B & P Section 6043.5, filing false and
    malicious ethics complaints.
    124. Plaintiff is informed and believes and therefore alleges that in
    seeking to obtain a search warrant in connection with the ethics
    complaint, Naliboff was acting pursuant to false advice and
    information he obtained from Assistant District Attorney Michael
    Cabral, who knew no probable cause existed in support of this claim.
    125. Plaintiff is informed and believes and therefore alleges that
    Cabral knew that no probable cause existed to seek a search warrant in
    connection with the ethics complaint filed by Plaintiff and, further,
    that he knew that the ethics complaint submitted by Plaintiff were (a)
    valid, truthful, and meritorious; (b) protected by the First
    Amendment; (c) did not constitute a crime warranting the search and
    seizure of Plaintiff’s property; and (d) did not contain any facts
    whatsoever to suggest that they were ‘false and malicious’.
    126. Plaintiff is informed and believes and therefore alleges that
    Cabral intentionally misled Naliboff, who in turn, misled Judge Falk
    into believing there had been a WRITTEN criminal complaint originating
    from the State Bar of California against Plaintiff when no such
    WRITTEN complaint existed.
    127. Plaintiff is informed and believes and therefore alleges that,
    nevertheless, Cabral deliberately and maliciously instructed Naliboff
    to seek a search warrant while misleading Naliboff and by giving him
    false legal advice that probable cause existed to support the warrant,
    despite the fact that there was absolutely no corroborating evidence
    in support of probable cause.
    128. Plaintiff is informed and believes and therefore alleges that
    Cabral allowed investigators to bring along a private citizen (Tom
    Layton) during the execution of the warrant on February 23, 2012.
    129. During the search, which lasted approximately three hours,
    Cabral constantly called the deputies executing the warrant with
    questions and instructions. Plaintiff is informed and believes and
    therefore alleges that Cabral also directed, participated, and
    controlled the actual search and seizure.
    130. During the search of Plaintiff’s home, investigator Peter Martin
    stated to Plaintiff that all documents referring to the State Bar of
    California will be confiscated. Despite protests from Plaintiff,
    Martin confiscated documents sent to Plaintiff by the IRS in
    connection with a complaint he had made against Voice of OC and
    CaliforniaALL.
    131. Plaintiff asked Martin why he was taking all those documents,
    and Martin stated that any and all documents referencing or relating
    to the State Bar of California are being confiscated. When Plaintiff
    pointed out to him that the document issued by the IRS mentions
    neither the State Bar of California nor any person listed on the
    warrant, Martin stated that the document would be confiscated
    nevertheless.
    132. During the interaction with Martin, Plaintiff felt intimidated
    and threatened, and retaliated against because Plaintiff exercised his
    First Amendment right to complain against Voice of OC to the IRS.

    SEVENTH CAUSE OF ACTION
    BANE ACT, CAL. CIV. CODE § 52.1
    (Against defendants Keker & Van Nest, John Keker, Chris Young, Voice
    of OC, Erwin Chemerinsky, Skadden Arps, Freada Kapor Klein, Mary Ann
    Todd , Munger Tolles, Jeff Bleich, Bradley Phillips, Ron Olson,
    Edison International, Berkshire Hathaway, Douglas Winthrop, Howard
    Rice, Holly Fujie, Buchalter Nemer, Raj Chatterjee, Morrison &
    Foerster, James Brosnahan, Thomas Girardi, Richard Tom , Southern
    California Edison , Wilson Sonsini, Mark Friedman, Fulcrum Properties,
    Mark Robinson, and Does 1 - 100 )

    133. Plaintiffs reallege and incorporate here the allegations in
    Paragraphs 1-132 above, as
    though fully set forth.

    134. Defendants’ above-described conduct constitute interference, by
    threats, intimidation, and coercion, with Plaintiffs’ exercise and
    enjoyment of his freedom of expression rights secured by the
    Constitution and laws of the United States and California, in
    violation of California Civil Code § 52.1. Specifically, defendants
    set in motion a course of action with the intent to retaliate,
    intimidate, and suppress Plaintiff exercise of those rights.

    135. Plaintiff is informed and believes that Defendants have directly
    performed, or aided, abetted, counseled, commanded, induced, procured,
    encouraged, promoted, instigated, advised, willfully caused,
    participated in, enabled, contributed to, facilitated, directed,
    controlled, assisted in, or conspired in the commission of the
    above-described acts.

    136. As a proximate result of the unfair and unlawful acts of
    Defendants, as alleged above, Plaintiff suffered injury in fact and
    has lost money or property in an amount to be proven at trial.
    Plaintiff is informed and believes and thereon alleges that David
    Rosenberg conspired with Michael Cabral to add the names of Starr
    Babcock and Joseph Dunn to the search warrant in order to also
    intimidate and silencePlaintiff. Plaintiff had never committed any
    alleged crimes against Joseph Dunn or Starr Babcock, and there was no
    probable cause to include the names of Starr Babcock and Joseph Dunn
    in the search warrant.

    137. Plaintiff is informed and believes and thereon alleges that, if
    Judge Falk had not been misled and had been presented with the
    complete truth when the DA’s office was seeking the search warrant for
    Plaintiff’s home, Judge Falk would not have signed the search warrant
    in connection with the ethics complaint or with the names of Starr
    Babcock and Joseph Dunn.

    EIGHTH CAUSE OF ACTION
    42 U.S.C. § 1983 - Violation of First Amendment/Free Speech Rights
    (Against Defendants Keker & Van Nest, John Keker, Chris Young, Voice
    of OC, Erwin Chemerinsky, Skadden Arps, Freada Kapor Klein, Mary Ann
    Todd , Munger Tolles, Jeff Bleich, Bradley Phillips, Ron Olson,
    Edison International, Berkshire Hathaway, Douglas Winthrop, Howard
    Rice, Holly Fujie, Buchalter Nemer, Raj Chatterjee, Morrison &
    Foerster, James Brosnahan, Thomas Girardi, Richard Tom , Southern
    California Edison , Wilson Sonsini, Mark Friedman, Fulcrum Properties,
    Mark Robinson, and Does 1 - 100 )

    138 Plaintiff incorporates paragraph by reference paragraphs 1 -
    137 as though fully set forth herein.

    139. Defendants’ above-described conspiracies between state and
    private actors, as well as the misuse of state power, and the attempt
    to silence Plaintiffs constitute interference with his freedom of
    expression rights secured by the Constitution and laws of the United
    States and California, in violation of 42 USC 1983. .

    140. Plaintiff is informed and believes that Defendants have directly
    performed, or aided, abetted, counseled, commanded, induced, procured,
    encouraged, promoted, instigated, advised, willfully caused,
    participated in, enabled, contributed to, facilitated, directed,
    controlled, assisted in, or conspired in the commission of the
    above-described acts.

    141. As a proximate result of the unfair and unlawful acts of
    Defendants, as alleged above, Plaintiff suffered injury in fact and
    has lost money or property in an amount to be proven at trial.
    Plaintiff is informed and believes and thereon alleges that David
    Rosenberg conspired with Michael Cabral to add the names of Starr
    Babcock and Joseph Dunn to the search warrant. Plaintiff had never
    committed any alleged crimes against Joseph Dunn or Starr Babcock, and
    there was no probable cause to include the names of Starr Babcock and
    Joseph Dunn in the search warrant.

    142. Plaintiff is informed and believes and thereon alleges that, if
    Judge Falk had not been misled and had been presented with the
    complete truth when the DA’s office was seeking the search warrant for
    Plaintiff’s home, Judge Falk would not have signed the search warrant
    in connection with the ethics complaint or with the names of Starr
    Babcock and Joseph Dunn.

    NINTH CAUSE OF ACTION
    42 U.S.C. § 1983 - Predicated on Fourth Amendment Rights/Unreasonable
    Search and Seizure
    (Against Defendants Michael Cabral, Peter Martin, David Rosenberg,
    and Does 1-100)

    143 Plaintiffs reallege and incorporate here the allegations in
    Paragraphs 1-142 above, as
    though fully set forth.

    144. Defendants’ above-described conduct has violated and continues
    to violate Plaintiffs’ right to be free from unreasonable searches and
    seizures under the fourth amendment to the US Constitution..
    As a result of Defendant’s actions, Plaintiff has been injured in an
    amount to be proven at trial.

    WHEREFORE, Plaintiff respectfully requests judgment
    against Defendants as follows:
    1. For general and special damages under all causes of action where
    available by law;
    2. For costs of suit;
    3. For prejudgment interest;
    4. For an injunction directing Defendants to comply with 26 U.S.C. §
    6104(d); and
    5. For such other and further relief as the Court may deem just and proper.
    Plaintiff also demands a jury trial in this matter.
    DATED: February 24, 2014


  • List of Defendants Named in First Amended Complaint Filed on February 24, 2014 in Yolo County Superior Court

    Lea Rosenberg, Yolo Lodge 169 Independent Order of Odd Fellows and Davis Rebekah Lodge; Grand Lodge of California; Independent Order of Odd Fellows; Davis Odd Fellows; Soroptimist International of Davis; Soroptimist International; Soroptimist International of the Americas; David Rosenberg; David Reed; Sheryl Cambron; Barbara Geisler; Virgil Smith; Robert Bockwinkel; Michael Cabral; Peter Martin, Keker & Van Nest, John Keker, Chris Young, Voice of OC, Erwin Chemerinsky, Skadden Arps, Mary Ann Todd , Munger Tolles & Olson, Jeff Bleich, Bradley Phillips, Ron Olson, Edison International, Berkshire Hathaway, Douglas Winthrop, Howard Rice, Holly Fujie, Buchalter Nemer, Raj Chatterjee, Morrison & Foerster, James Brosnahan, Thomas Girardi, Richard Tom , Southern California Edison , Wilson Sonsini,
    Mark Friedman, Fulcrum Properties, Mark Robinson, Geoffrey Brown, Arnold Porter, Mark Parnes, CaliforniaALL, Ruthe Catolico Ashley, Larissa Parecki, Morrison England, Torie Flournoy-England, Sarah Redfield, McGeorge School of Law, Cary Martin Zellerbach AKA Mary Ellen Martin Zellerbach, Martin Investment Management, Douglas Scrivner, Accenture, Freada Kapor Klein, Level Playing Field Institute, Ophelia Basgal, Pacific Gas & Electric Company, James Lewis, Verizon Communications, Darrell Steinberg, Kamala Harris, Michael Peevey, Steve Poizner, James Hsu, Sonnenschein Nath & Rosenthal and Does 1-100


  • World Map Finder - Multilingual Global Mapping Service - PR.com

    http://www.pr.com/press-release/539808

    World Map Finder - Multilingual Global Mapping Service

    With a wide range of unique features, World Map Finder helps people avoid getting lost, find their destinations quickly and even get an A in their geography class.

    Los Angeles, CA, January 31, 2014 —(PR.com)— World Map finder recently announced that it has launched a multilingual global mapping service that is not only designed for travelers and business people but also for students who are having a hard time in their geography classes. This is done by providing them with a wide range of features that can help them determine where a place is in a convenient manner through the use of their laptops and other devices.

    #cartographie #bibliothèques_de cartes #ressources #ressources_cartographiques


  • Seven things you need to know about maps | Optus Zoo News

    http://news.optuszoo.com.au/2014/02/03/seven-things-you-need-to-know-about-maps

    ha ha ha ! sacrés cartographes qui vont jusqu’à fausser leurs propres cartes pour piéger les plagieurs. Mais heureusement, on fait plus du tout ça aujourd’hui, c’était seulement avant.

    Mapmakers included fake towns to catch forgers

    Ever been to the town of Agloe in New York State? Whitewall in California? Or Relescent in Florida?

    While these towns are clearly marked on a number of antique maps of the United States, they don’t actually exist.

    “Paper towns” were fake places added to maps by early mapmakers in order to dupe forgers into copying them, thereby exposing themselves to charges of copyright infringement.

    http://resources.news.com.au/images/2014/02/03/1226816/686753-8f4f9da0-8c6c-11e3-836d-02ea2adb9f0a.jpg

    in « Seven things you need to know about maps », Feb 03, 2014 4:00PM, MAPS can be beautiful and good ones can be great investments.

    #cartographie #cartes_anciennes


  • Rising sea levels threaten Los Angeles | Climate News Network

    http://www.climatenewsnetwork.net/2014/02/rising-sea-levels-threaten-los-angeles

    As much of California and the western US endures a severe drought, the city of Los Angeles is at increasing risk from rising sea levels, researchers say.

    LONDON, 22 February – Los Angeles, City of the Angels in southern California, sits on a flat shelf of the Pacific coast of America, with a view of the sea. And if climate scientists are right, it could soon have an even closer view of the sea.

    The city of more than 12 million people occupies 12,000 square kilometres of land, much of it no more than three metres above sea level. By 2050, rising sea levels could pose a threat to the infrastructure, museums and historic buildings of this great capital of entertainment, education, business, tourism and international trade, according to a new study by the University of Southern California.

    #climat #californie


  • Rick Boyles - Grand Master of Grand Lodge of California — Asked to Comment on Alleged Perjury by David Reed (husband of Sheryl Cambron) Concerning Financial Contributions from Davis Odd Fellows to Progress Ranch / Barbara Sommer

    Hello Mr. Boyles:

    I hope you are well, and thanks for replying to my email the other day.

    Do you by any chance know why Dave Reed stated — falsely — under penalty of perjury that “DAVIS ODD FELLOWS HAVE NEVER MADE CONTRIBUTIONS OR PARTICIPATED IN FUND-RAISING FOR PROGRESS RANCH.”

    As you know, Reed is a judge of the Yolo County Superior Court and Progress Ranch is an entity controlled by Barbara Sommer — foreman of Yolo County Grand Jury.

    As you also know, because of the almost exclusive financial contributions to “emancipated foster youth,” I suspected that Lea and David Rosenberg misused Davis Odd Fellows to launder money to Barbara Sommer on behalf of Cache Creek Casino — an entity which Sommer was investigating in her capacity as foreman of the Yolo County Grand Jury.

    Recently, much to my chagrin, I came across various articles which clearly state that Davis Odd Fellows — during the time period Dave Reed serve as president — repeatedly made financial contributions to Progress Ranch.

    If you know why Dave Reed chose to defraud the court and myself, please let me know.

    You can obtain more information about this topic by clicking on following link:

    bit.ly/1d7r58B

    Thank you


  • Blondie Bennett, Barbie-Obsessed Woman, Uses Hypnotherapy To Make Herself ’Brainless’
    http://www.huffingtonpost.com/2014/02/19/blondie-bennett-barbie-woman-hypnotherapy-stupid_n_4815495.html?ncid

    A California woman who describes herself as Barbie-obsessed says she uses hypnotherapy sessions in the hopes that it will decrease her IQ.

    “I just want to be the ultimate Barbie. I actually want to be brainless,” Blondie Bennett, 38, told Barcroft TV. “I don’t like being human, if that makes sense... Natural is boring... I would love to be like, completely plastic.”

    #réification #femmes @beautefatale
    #gorafi_encore_plagié


  • Study Finds Greater Income Inequality in Nation’s Thriving Cities
    http://www.nytimes.com/2014/02/20/business/economy/study-finds-greater-income-inequality-in-nations-thriving-cities.html

    The single biggest increase in inequality over that period occurred in San Francisco, where earnings for the typical low-income household dropped $4,000 and soared $28,000 in inflation-adjusted dollars for a high-income household. But in most other places, inequality intensified because the poor got poorer, including in Cleveland, Sacramento, Tucson and Fresno, Calif.

    “High-income households did not lose much ground during the recession,” Mr. Berube of Brookings said. “Low-income households lost ground and haven’t gained it back. And the pressures around cost of living are higher at the low end than they are at the high end.”

    Researchers say local inequality trends are related to national inequality trends, but are not the same. Any individual city’s earnings ratios might be more defined by who can afford to and wants to live there — whether a family of relatively low-skilled new immigrants, or a computer programmer in high demand or a financier from abroad — than by tidal economic trends like unionization and technological change.

    #inégalité #pauvreté #Etats-Unis