facility:yolo county superior court

  • Oliver Lewis
    Deputy Attorney General
    Department of Justice, State of California
    1300 I Street, Suite 125
    Sacramento, California 94244

    Re: Defendant Kamala Harris

    Dear Mr. Lewis:

    1. In a letter dated July 3, 2014, you informed me that your office is representing defendant Kamala Harris in the action I have filed in Yolo County Superior Court. Please note that I strongly object to such representation because Ms. Harris has been sued in her capacity as a private individual for misconduct which took place before she assumed the position of Attorney General of the State of California — specifically, misconduct she undertook together with her brother-in-law (Tony West), who was employed at that time at Morrison & Forester (alongside James Brosnahan and Chris Young) in her capacity as a member of Obama for America.

    As such, I believe that your office’s representation of Ms. Harris under these circumstances is inappropriate, and ask that your office cease from representing Ms. Harris. If you disagree with my position, I would appreciate if you can forward an explanation.

    2. Your letter also states that on July 3, 2014 you attempted to file a demurrer to the complaint, to be heard on July 25, but were told by the clerk of the court that it will not assign a hearing date. My understanding is that the last day to file any motion for a hearing date of July 25 was June 27, 2014 (for service by mail). As such, the clerk was correct in rejecting your papers.

    Nevertheless, as a courtesy, I will not seek entry of default judgment against Ms. Harris, and will await word from the Court as to when it will hear your demurrer.

    If you have any questions, please don’t hesitate to contact me.

  • 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.

  • 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,

  • CPUC’s General Counsel Frank Lindh Informed of Suit Against CPUC President Michael Peevey

    To: frl@cpuc.ca.gov, jzr@cpuc.ca.gov, mpo@cpuc.ca.gov

    Dear Mr. Lindh:

    Attached below for your reference is a courtesy copy of summons and civil complaint filed against President Peevey in Yolo County Superior Court.

    Could you please let me know if he is amenable to accept service by signing a Notice and Acknowledgment of Receipt ? If yes, the form (POS-015 ) can be downloaded from http://www.courts.ca.gov/forms.htm?filter=POS

    Please observe that I want to move quickly and will need the signed Acknowledgment sent to me by email within the next few days.

    Also, at your earliest, I will need to schedule an informal interview with you in order to ascertain your own personal involvement with CaliforniaALL, PG&E, Ophelia Basgal, and James Brosnahan as applied to Geoffrey Brown and Joe Dunn.

    Very truly yours,