organization:yolo county superior court

  • REDACTED COMMUNICATION SENT TO COUNSEL IN MATTER OF SUIT AGAINST MORRISON & FOERSTER ET AL ON AUGUST 7, 2015

    Dear Counsel:

    I hope you are well and are enjoying the summer.

    This will serve to discuss various matters dealing with the two above referenced actions. At times, each counsel is addressed individually and at times issues are addressed to all (or the majority of) counsel collectively, as follows:

    1. YOLO COUNTY SUPERIOR COURT JUDGES DAVID ROSENBERG AND DAVID REED — First, as to the part of this communication addressed to Messrs. Michael Fox, Keith Fink and Olaf Muller, please be informed that an upcoming federal action of Levi v. Girardi & Keese will include one cause of action seeking only equitable relief against “Yolo County Superior Court.” Since your clients (Judges David Rosenberg and David Reed) are part of the “Yolo County Superior Court”, I wanted to give you a heads-up of the upcoming action, as well as to inform you that it is unrelated to the topics which were previously the subjects of various agreements.

    Simply put, and as discussed in more detail below as events relate to other parties, there have been serious new developments dealing with: a) Yolo DA / AARP b) Michael Cabral / Yolo and Riverside DA’s offices/ SNR Dentons - Rod Pacheco - James Hsu / Yolo County’s Cache Creek Casino - Chief Marshall Mckay/ Mark Friedman / DLA Piper / Kapor Enterprises.

    As far as (a) — developments involving Yolo DA and AARP, etc, note that last week I learned that AARP — where George Davis (formerly a California Bar BOG member who voted to press false criminal charges against me with Yolo DA, president of AARP-California, and with strong financial ties to CCPF) and Barbara O’Connor (AARP and AARP Foundation Director, Link America Foundation Director - whom I caught in major alleged fraud re Washington DC party to celebrate the “linking” of the two Americas — which in actuality was a Barack Obama inauguration party - and employee of Sacramento-based Donna Lucas’s Public Affairs) — has bestowed an unusual grant of $40,000 on the Yolo County District Attorney (see attached press-release and HERE ) headed by Jeff Reisig and Jonathan Raven.

    As far as (b) — developments involving Yolo / Riverside Assistant District Attorney Michael Cabral — note that during the pendency of the criminal action against me, a very unusual theory was explored by which Cabral had been transferred from Riverside County DA to Yolo County DA for the sole reason of falsely and maliciously criminally prosecuting me in order to intimidate me into silence and otherwise confiscate incriminating evidence through the execution of an invalid search warrant.
    At that time, I looked into those facts and rejected the theory dealing with Cabral (See story HERE). About one month ago, I learned that Cabral is no longer with the Yolo DA, and has returned back home to the Riverside County District Attorney.

    As you may recall and as I stated previously, I agreed to a plea of no contest to a charge of misdemeanor attempted extortion as a stopgap measure since I was under duress on various fronts. As part of the plea bargain I agreed to, among other things, not contact the State Bar of California Board of Governors/Trustees directly, and other overreaching conditions.

    Both as a journalist and as a victim of the above alleged malfeasance, I am obviously interested in informing the State Bar of California Board of Governors/Trustees and the public vis-a-vis press releases, published articles, and by contacting other journalists of those events. However, per conditions imposed on me while under duress as part of the plea bargain in the criminal matter by Judge Reed, I am prohibited from directly contacting BOG members. As such, in addition to suing some of the above named and others in federal court, I plan to ask the same federal court for relief to allow me to freely exercise free speech.

    As such, if the attorneys for Judges Rosenberg and Reed believe that advancing an action against Yolo County Superior Court for equitable relief is not consistent with the spirit or language of our prior agreements, please let me know.

    Note that from my perspective past events are all forgotten history and there is absolutely no desire to rehash old claims against Rosenberg and Reed. In fact, as I mentioned to Rosenberg’s attorney (Mr. Fink) over the phone, I am a huge fan of Rosenberg and was recently disappointed that he was not appointed as a justice to the California Supreme Court given his outstanding judicial qualities, experience, and political background (i.e. former chief of staff to Governor Jerry Brown; Judicial Council member; mayor of Davis, etc).

    2. SERVICE OF BRIEF AND APPENDIX — California Rules of Court Rule 8.124 (e)(1)states that “a party preparing an appendix must: (A) Serve the appendix on each party, unless otherwise agreed by the parties....”

    As far as the service of the appendix, I am hoping that each party will agree to waive formal service and instead agree that the service of a searchable PDF Appendix via electronic mail is sufficient. Note that I will be advising the court of my request and the responses received from counsel, if any.

    Similarly, I am hoping that you will also agree to waive formal service of a hard copy of the appellant’s brief and to instead agree that the service of searchable PDF and/or Microsoft Word version of the brief via electronic mail is sufficient. I will also be letting the court know that I made this request of counsel and the responses received, if any.

    I would like to urge everyone to agree to the above in order to save a tree, costs, and the unnecessary labor of printing, copying, and binding thousands of pages.

    3. SETTLEMENT DISCUSSIONS — As applied to the two above referenced actions, I would like to remind everyone that the window to engage in settlement discussions has been closed, as was stated previously. As such, due to multitudes of reasons, in connection with the above two referenced actions, please refrain from extending any settlement offers, attempting to engage in settlement negotiations, or offering anything of value. The only exception will be if the undersigned originates a proposal.

    4. DOCKET — As far as the matter pending before the California Third District Court of Appeal, note that the docket maintained by the court contains many inaccuracies and is otherwise lacking. For example, a search for the last name of defendant/respondent “James Brosnahan” yields no result. Ditto defendants Freada Kapor Klein, Michael Cabral, Mark Friedman (only the name of the late distinguished Morton Friedman OBM appears), Fulcrum Property (only “Fulcrum Davis” appears, which I assume is associated with the Friedmans), Mary Cary Zellerbach, Martin Investment Management, Ronald Olson, Jeff Bleich, Chris Young, Kamala Harris, Douglas Winthrop, Holly Fujie, Ophelia Basgal, and others.

    As such, I ask that each of you contact the court of appeal on behalf of your respective clients — similar to the 4th entry of the docket by which the attorney for Darrel Steinberg independently wrote the court to advise that Steinberg is a respondent, see HERE — to inform the court of the problem and ask for it to be rectified.

    Moreover, please ensure that the name of your clients are spelled correctly i.e. “Munger,Tollis” or “Freada, Kapor, Klein” are not the correct spelling, at least based on my understanding.

    The attorney representing Ms. Kamala Harris is requested to inform the court to remove a comment by which the docket states that Ms. Harris was sued in her capacity as the attorney general or forward proof where I allege she was sued in such capacity.

    The attorney from Locke Lord representing defendants Cary Zellerbach and Martin Investment is asked to inform the court to correct the docket which does not mention either yourself, your firm, or your clients. Also with respect to your client that has thus far managed to avoid service, please be advised that the California statute of limitations is tolled and I intend to pursue claims against her either in state or federal court. REDACTED

    5. SKADDEN ARPS — ISSUES RE RAUOL KENNEDY REPRESENTATION OF CALIFORNIA JUDICIARY — Mr. Russell, as you may recall, in reply to my inquiry you wrote: "My colleague Raoul Kennedy does indeed represent Justice Robert Mallano in Mallano v. Chiang et al., LASC Case No. BC533770. As you may know, Judge Elihu Berle granted class certification in Mallano on January 15, 2015. The class members have not yet been identified because notice has not been circulated, nor has the period for opt outs occurred. Nevertheless, regardless of which judges or justices eventually become members of the class, pursuant to section 811.9 of the California Government Code, the “fact that a justice, judge, subordinate judicial officer, court executive officer, court employee, the court, the Judicial Council, or the Administrative Office of the Courts is or was represented or defended by the county counsel, the Attorney General, or other counsel shall not be the sole basis for a judicial determination of disqualification of a justice, judge, subordinate judicial officer, the county counsel, the Attorney General, or other counsel in unrelated actions.” Cal. Gov’t Code § 811.9. As a matter of law, there is no conflict. The statute is attached for your reference."

    As a reply, I wrote in part that the statute applies only to one justice, and in the case at hand Mr. Kennedy represents (as of now and assuming none chose to opt out) the entire qualified panel of justices of the Third District and that, most importantly, per the statute, the representation must be the “sole” basis. Here, the representation of Skadden/ Kennedy is NOT the sole basis. Rather, there is an additional basis for the disqualification — which is the fact that Skadden itself is also a DEFENDANT in the “unrelated action.”

    In any event, this will serve to inform you that I intend to seek to disqualify any and all judicial officers who are clients of your firm. As such, I ask for you to please forward a list identifying the class members and all those who chose to opt-out of the litigation.

    6. MORRISON & FOERSTER: Mr. Besirof, associate Davis indicated that you replaced Mr. Dresser as the attorney in this matter. Please let me know if you have any questions or require certain clarification. Since you are new to the case and since it is summer, if you need extra time to catch up on materials as far as the filing of an appellate respondent brief, I am extending to you (and by extension everyone else) an additional 60 days in which to file your brief.

    7. DEFENDANT MARK FRIEDMAN / COUNSEL - BROTHER PHILIP FRIEDMAN — Mr. Friedman, in connection with events dealing with Michael Cabral / Yolo DA / Chache Creek Casino and SNR Dentons, can you please provide a list of all the partnerships between defendant Mark Friedman and the Rumsey / Yocha Dehe tribe which operates Cache Creek Casino in Yolo County?

    A lawsuit (attached) the tribe/casino filed against your brother and REDACTED lists the following: Government Property Fund,LLC; Government Property Fund II, LLC ; Government Property Fund III, LLC ; Government Property Fund IV, LLC ; 4330 Watt,LLC; Fulcrum Management Group LLC ; Fulcrum Friedman Management Group, LLC ; Illiniois Property Fund, GPF ; and Illinois LLC. Are these partnership still in effect ?

    Also, for purposes of determine potential conflicts of interest in the current pending matter as far as your ability to serve as legal counsel given your role as a potential witness, please inform me whether Paragraph 108 of the lawsuit which states: “The other Vectors partners included REDACTED and Opper, as well as Friedman, Friedman’s father and brother, and John Krasznekewicz (a Friedman friend)” refers to you, Philip Friedman. In essence, what I am asking is are you the Vector partner or is the brother alluded to someone else ? Also, starting in 2006 to the present, were you involved in any other partnership with the tribe and the casino ?

    8. MUNGER TOLLES & OLSON: Mr. Senator, if not a bother, I will appreciate if your firm would forward me the following:

    a - copy of the report prepared by your colleague Bart Williams dealing with alleged misconduct by Joe Dunn, especially in connection to a trip overseas by which Dunn was accompanied by Howard Miller of Girardi & Keese and Tom Layton. As you may be aware, accompanying the Yolo County District Attorney officers during the execution of the search warrant at my home was also Tom Layton — who served as liaison. As such, if said report is in the public domain, I will appreciate if you forward a copy.

    b - your colleague Jeffrey Bleich recently solicited as clients a group of UC Davis APA law students in connection with their bid to admit post-mortum an APA applicant to the State Bar of California. If not a bother, will it be possible for you to please forward to me a copy of the motion and all other pleading submitted to the California Supreme Court.

    9. FREADA AND MITCHELL KAPOR / LEVEL PLAYING FIELD INSTITUTE : Mr. Medina, at your earliest, I will appreciate if you please address the following:

    a. In order to determine your status as potential witness, can you please forward your employment history to date beginning from around 2006 ? Were you ever employed at the DLA Piper office in Sacramento ? If yes, can you please state the dates of your employment.

    b. Are you and your clients in a position to disclose who is paying Kapor and LPFI’s attorney’s fees? If it is DLA Piper who set you up to defend the two or otherwise is paying your attorney’s fees, please let me know. As you may know, DLA Piper managing partner Gilles Attia, daughter Sarah Attia, and partner Steve Churchwell played a huge role in CaliforniaALL / Obama for America. Also, separately and around the same time, there is an allegation that DLA Piper laundered $50,000 to “Obama Victory Fund” through defendant Level Playing Field Institute / Kapor Enterprises vis-a-vis the so called “Kapor Maneuver.”

    c. Recently, I have learned from a YOU-TUBE video featuring Mr. Kapor that he is heavily invested in what he refers to as “Ed-Tech” companies.

    It will be appreciated if you let me know if Mr. Kapor, his wife, or their entities have any business relationships with Steve Poizner or former California Bar Foundation treasurer Lindsay Lee — both of whom are also involved with Ed-Tech.

    d. Yesterday, just as I was about to send you settlement business proposals, much to my chagrin and indignation, I encountered the following article in USA Today. Under the heading of “Kapors pledge $40 million investment in tech diversity” it stated, among other things: “Mitch Kapor and wife Freada Kapor Klein will invest $40 million over three years in a set of initiatives designed to give women and underrepresented minorities a better shot at becoming technology entrepreneurs.” The article further stated that “Kapor Capital will make more than $25 million in investments in technology start-ups working to narrow the achievement gaps. At least half of the companies will have founders from underrepresented groups.” (See story http://tinyurl.com/p33dxlx )

    My understanding is that any and all non-profit and for-profits companies operated in the State of California are deemed to be “business establishments” that come within the purview of Civil Code Section 51 known as The Unruh Civil Rights Act.

    Be advised that the plan by the Kapors and Kapor Capital to “make more than $25 million in investments in technology start-ups working to narrow the achievement gaps. At least half of the companies will have founders from underrepresented groups” runs afoul of The Unruh Civil Rights Act which reads: “All persons within the jurisdiction of this state are free and equal, and no matter what their sex, race, color, religion, ancestry, national origin, disability, medical condition, genetic information, marital status, or sexual orientation are entitled to the full and equal accommodations, advantages, facilities, privileges, or services in all business establishments of every kind whatsoever.”

    In other words, Kapor Capital’s plan to pick and choose “founders from underrepresented groups” (based on the article, women and “underrepresented minorities”) is unlawful. If you or your clients disagree, please forward an explanation. Otherwise, I shall await word from you that there has been a change of plans.

    e. As you may be aware, starting around 2000, the former executive-director of the State Bar of California (Ms. Judy Johnson) secretly served as the president of the “California Consumer Protection Foundation” ("CCPF") an entity which obtained millions of dollars from class-action “cy pres” awards and from fines, settlements and payments the CPUC — during the time Michael Peevey and Geoff Brown served as commissioners — imposed on various utility companies. For example, anytime a merger took place i.e. between various cell-phone companies such as Verizon, millions were paid to CCPF.

    CCPF, in turn, funneled hundreds of thousands of dollars to entities in South-Central Los Angeles [with very close connection to State Bar of California BOG members Shrimpscam’s Gwen Moore and George Davis], a dubious entity in Venice for “Youth Radio”, an entity headed by Michael Shames, various Asian-American entities with close connections to State Bar officials (Holly Fujie and Madge Watai — Little Tokyo Service Center, etc.) and money to entities headed by associates of Justice Ming Chin.

    Based my estimation, around $3 million cannot be accounted for, and separately I alleged that CCPF submitted false reports to the IRS. Months before the execution of the search warrant, I complained to the IRS against CCPF as well as filed an ethics complaint against Judy Johnson and others with the State Bar of California. Later, as you may recall, the State Bar of California BOG voted to file criminal charges against me, alleging among other things, that the CCPF ethics complaint constituted criminal conduct which served as one basis for the search warrant.

    Based on my recollection, it also appeared that CCPF may have funneled money to entities established by the Kapors. Since all the materials have been confiscated by the Yolo DA and are otherwise inaccessible, at your earliest, I will appreciate the names of those entities and the dates / amounts each of these contribution.

    f. Please consider this a formal request for “Kapor Center for Social Impact” to produce its 3 last 990 forms submitted to the IRS. If you need me to request this information from the entity directly, please let me know.

    Thank you for your attention to these matters. Please let me know if you have any questions.

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

    RE: Message to Mr. Olivier Lewis Re Client Kamala Harris

    Mr. Lewis:

    1. As you recall, you represented to me in writing that the clerk of the Yolo County Superior Court rejected the demurrer you sought to file on behalf of your client Kamala Harris. Later, you stated in open court that the demurrer was timely and properly filed. Can you please email me a copy of the “filed” stamped demurrer as well as the proof of service for my records?

    2. My understanding is that California Senators Jerry Hill and Kevin Mullin, as well as San Bruno Mayor Jim Ruane, asked Ms. Harris to investigate CPUC corruption involving PG&E, Michael Peevey, and others ( http://sanfrancisco.cbslocal.com/2014/09/19/attorney-general-kamala-harris-called-on-to-investigate-secre ) .

    Is your client going to disqualify and otherwise recuse herself from conducting such an investigation given her own personal involvement with corruption involving PG&E, Ophelia Basgal, and Michael Peevey in the CaliforniaALL matter? Please let me know.

    3. If possible, I will appreciate a written explanation from you regarding why the Office of the California Attorney General assumed the representation of Ms. Harris for misconduct alleged to have taken place prior to her election as attorney general.

    Thank you for your prompt assistance regarding these matters.

  • 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.

  • Charles S. Painter, Esq.
    Ericksen Arbuthnot
    100 Howe Avenue, Suite 110 South
    Sacramento, CA 95825-8200

    Dear Mr. Painter:

    This will respond to your letter dated June 26, 2014.

    1. In that you were going to urge the clerk not to file my latest pleading (which it already did), please advise as to the outcome of your conversation with the Yolo County Superior Court clerk, .

    2. From my end, this will serve to memorialize that the clerk incorrectly “filed” stamped the pleading with the date of June 25, 2014, despite the fact that it was submitted for filing (at the drop-box) on June 24, 2014 at 2:20 pm. I plan to contact the clerk’s office to have the error corrected.

    3. In connection with the anti-Slapp motion you have advanced, this will serve to meet and confer whether or not you are amenable to allowing discovery to be propounded on your clients without a court order.

    As you are probably aware, upon the filing of an anti-slapp motion discovery is stayed pending the resolution of said motion. Nevertheless, Section 425.16(g) permits the judge to issue an order re-opening discovery.

    After conducting comprehensive research, I believe that in order to effectively oppose the anti-slapp motion I will need to conduct discovery. Specifically, I am interested in serving your clients with requests for admissions, as well as deposing Douglas Winthrop, Richard Tom, and Geoffrey Brown before the opposition is due.

    As such, my question to you is whether you would be willing to produce your clients for depositions and answer requests for admission without me approaching the court seeking an order authorizing discovery. In the alternative, I am amenable to working with you in good faith to enter into factual stipulations that I can present to the court in my opposition to the anti-slapp motion.

    If you have any questions, please feel free to contact me.

  • This will serve as an update of yesterday’s ex parte hearing to extend time to serve pleadings.

    Initially, this motion was scheduled for Friday, March 29, before Yolo County Superior Court Judge Timothy Fall. Later the clerk informed that the entire Yolo County Superior Court had disqualified itself, and that the matter will be heard on April 1st at 1:30 pm by a visiting judge from a neighboring county.

    Yesterday, prior to appearing before the visiting judge, I attempted to file the ex parte motion, but was told by the clerk that I need to pay the filing fee (which I did), but not yet file the motion itself because it contains a judge’s order, so the entire set can be filed only after the judge signs the papers.

    Later, once the hearing started, the judge stated that he read the FAC and is familiar with many of the actors. The judge then stated that the ex parte motion is premature because I have 3 years to serve the summons and complaint. I told the court that I was aware of that rule, but my understanding is that Yolo County utilized “fast track” rules which requires service within 30 days.

    The court then took a short recess to read the local rules, and it was confirmed that service must be completed within 30 days. The judge then read the ex parte motion, but concluded that because he is familiar with many of the actors, he would recuse himself — which he did.

    Please note that no papers were filed. Once more information is available, an update will be provided.

  • Munger Tolles & Olson ; Jeffrey Bleich — Service of Process

    Jeff.Bleich@mto.com,
    Jeff Bleich <JLBleich@gmail.com>,
    “Olson, Ronald” <ron.olson@mto.com>,
    “Todd, Mary Ann” <maryann.todd@mto.com>,
    “Phillips, Bradley” <Brad.Phillips@mto.com>

    Mr. Bleich:

    This will serve to memorialize and address events dealing with
    attempts to serve you and the law-offices of Munger Tolles & Olson
    with summons and complaint.

    On Tuesday, March 25, 2014 at around 4:00 p.m. a process-server
    visited Munger Tolles’ offices in San Francisco seeking to serve you
    and the law-firm.

    As far as service upon yourself, my understanding is that the
    process-server was told that you are out of the country.

    As far as service upon Munger Tolles, my understanding is that the
    process-server handed someone in your office an envelope containingthe summons, FAC, CMC order, and ADR package. When I inquired withthe process-server who that someone was, he stated that he informedthe receptionist of the purpose of his visit.

    Subsequently, the receptionist called a partner who opened the envelope, and read the pleadings. I asked the process-server if he had served the partner and he stated that at this point, because it took the partner a longtime to read the complaint, he (the process-server) was invited to eat some food left over from a birthday party held at your office that day, and by the time he returned the partner was no longer there.

    The long and the short of it is that I am not sure if service was
    effected on Munger Tolles, and would not want to misrepresent events by claiming that service was perfected if in actuality it was not.

    As you know, on Tuesday April 1, 2014 an ex-parte hearing will be held in Department 1 of Yolo County Superior Court at which I will seek an extension of time to serve the pleadings. As such, I will appreciate if you or someone from the San Francisco office would let me know your position so that I may inform the court as to the status of events and otherwise take the appropriate steps (ie, to attempt re-service thefirm). In any event, I am going to inform the court that an extension is needed because you are of the country, allegedly, and could not be served.

    Because service on you and your firm will be completed, I ask you and your firm to seriously consider waiving service altogether on all the Munger Tolles defendants.

    Lastly, would it be possible for your firm to appoint one point of
    contact who I can communicate with regarding this case in order to
    simplify matters and streamline events rather than having to write to the many attorneys who would otherwise be included in communications?

    Thank you for your cooperation regarding these issues. Please let me know if you have any questions.

  • 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.

  • 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,

  • 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

  • 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

  • REDACTED COPY OF SUIT FILED IN YOLO COUNTY SUPERIOR COURT

    Plaintiff,

    v.

    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; Jonathan Raven; Allison Zuvela; Michael Cabral; Tracie Olson; Kathleen White; and Does 1 through 100, inclusive,

    Defendants.

    COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF FOR:


    1. Plaintiff – an individual residing in Yolo County, an investigative reporter and a Rabbi — has been subject to a campaign of systemic harassment ever since he uncovered corruption in various matters dealing with Boyd Gaming Director, owner of various casinos, and class-action attorney Thomas Girardi (“Girardi”) of Girardi & Keese in connection with financial corruption involving California Democratic Party operatives.

    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” to 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, seeking to mislead Plaintiff, told Plaintiff 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) whereas Girardi – who represented the class of plaintiffs – never disclosed that the attorney who represented defendant Farmers was concurrently representing Girardi 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 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 has been 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 thereon 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 Dicsktein, 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.
    PART II: 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)

    10. 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”.
    11. Plaintiff further learned, and thereupon alleges, that David Rosenberg and his wife (Lea Rosenberg) 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, and others.
    12. Plaintiff also discovered that Lea Rosenberg — as the wife of a judge – was energetically raising funds from various businesses. Plaintiff is informed and believes and thereon alleges that Lea Rosenberg is an individual residing in Yolo County.
    13. 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 serve as president and Bucher as Treasurer.
    14. 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 to make available for inspection their IRS 990 forms, which Plaintiff is informed and believes and thereon alleges are tax-exempt organizations.
    15. 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).”
    16. 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.
    17. 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.”

    18. Plaintiff is informed and believes and thereon alleges that Lea Rosenberg received Plaintiff’s email dated April 3, 2013.
    19. On April 24, 2013, Plaintiff delivered to Lea Rosenberg a notice of change of address.
    20. Plaintiff is informed and believes and thereon 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).
    21. Plaintiff is further 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.
    22. 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.
    23. 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."

    24. 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)

    25. Plaintiff incorporates paragraph by reference paragraphs 1 – 24 as though fully set forth herein.
    26. 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.
    27. 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.
    28. 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
    (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; Lea Rosenberg; and Does 1 - 100)

    29. Plaintiff incorporates paragraph by reference paragraphs 1 - 28 as though fully set forth herein.
    30. Plaintiff is informed and believes and thereon alleges that the Defendants named above were all aware of Plaintiff’s repeated requests for the information described in this Complaint — the entities’ IRS Form 990 forms.
    31. Plaintiff is further informed and believes and thereon 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.
    32. 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.
    33. 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.
    34. 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.
    35. The “Hall Board Association” is composed of President David Rosenberg, Vice President David Reed, Secretary Lea Rosenberg, Treasurer Sheryl Cambron, and Barbara Geisler.
    36. The Davis Lodge Hall is available to rent by the general public for receptions, fund-raisers, dinners, conferences, trade shows, meetings, and other events.
    37. The Davis Lodge Hall is also used by Davis Odd Fellows for its own functions, such as Davis Odd Fellows Bingo and Master Balls.
    38. 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.
    39. 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 thereon alleges that Reed and Cambron are married to each other.
    40. 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.
    41. 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.
    42. 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.
    43. Plaintiff is informed and believes and thereon 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. Also responsible for submitting these fraudulent tax-returns were David Rosenberg, Lea Rosenberg, David Reed, Sheryl Cambron, Barbara Geisler, and Robert Bockwinkel.
    44. Plaintiff is informed and believes and thereon 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.
    45. 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.

    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)

    46. Plaintiff incorporates paragraph by reference paragraphs 1 - 45 as though fully set forth herein.
    47. Plaintiff is informed and believes and thereon alleges that Defendants Lea Rosenberg, David Rosenberg, Sheryl Cambron, Robert Bockwinkel, David Reed, 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.
    48. Some of the overt acts (both lawful and unlawful) that gave rise to this conspiracy, committed by one or more of the conspirators pursuant to their common design, were: (a) an agreement 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; and (c) a lawful overt act to belittle Plaintiff by sending him an email which reads, “so he is at it again.”
    49. Plaintiff is further informed and believes and thereon 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.
    50. Plaintiff is also informed and believes and thereon alleges that David Odd Fellows / Yolo Lodge 169 / Odd Fellows Hall and related entities are and were almost exclusively overseen for years by judges and selected attorneys appearing before the Yolo County Superior Court who misuse Yolo 169 and Odd Fellows Hall as a convenient forum to meet, collude, and engage in ex parte communications in a secluded and non-public setting, as well as to raise funds by lending the prestige of their offices.
    51. Said individuals include primarily Judge David Rosenberg, Judge Kathleen White, Judge David Reed, Yolo County Counsel Sheryl Cambron, District Attorney Jeff Reisig, Yolo County Chief Deputy District Attorney Jonathan Raven, Chief Deputy District Attorney Michael Cabral, Yolo County Public Defender Tracey Olson, attorneys Allison Zuvela, Rodney Beede and wife Christina Zambrano Beede, and Fran McGuire (wife of judge Dan McGuire). A typical event, for example, was described on May 23, 2013 in the Davis Enterprise:

    “This year, the Davis Odd Fellows Lodge took over running the popular ’A Taste of Davis’ and we are delighted to report that the event on April 18 was a great success for all concerned.

    We wish to thank the fine restaurants, wineries and breweries that treated our 250 guests to delightful food and drink: Applebee’s, Berryessa Gap Winery, Caffé Italia’s Brick Wall Pizza, California Vintage Specialties, Davis Food Co-op, Davis Farmers Market, Ding How, Dos Coyotes, Maria’s Cantina, Nugget Markets, Osteria Fasulo, Our House, Paesanos, Putah Creek Winery, Renaissance Wines, Route 3 Wines, Seasons, Senders Wines, Seka Hills Wines, Sudwerk, Sundstrom Hill Winery, Woodstock Pizza, Z Specialty Foods and Zindagi Indian Bistro.

    We thank our sponsors who helped make this event so successful. First and foremost, we offer a big “thank you” to our major sponsor, Hanlees Toyota-Chevrolet-Nissan of Davis. And we also appreciate our other sponsors: The Davis Enterprise, California Vintage Specialties, Comstock Mortgage, Davis Downtown, Cunningham Engineering, Our House Restaurant and Lounge, the Davis Chamber of Commerce, Abaton Consulting, Law Offices of Poulos and Fullerton, Attorney Raquel Silva, the Law Offices of J.B. Dath, and Cache Creek Resort Casino.

    Thank you to many individual sponsors: County Supervisors Jim Provenza and Don Saylor, Mayor Joe Krovoza, and Davis City Council members Dan Wolk, Rochelle Swanson, Brett Lee and Lucas Frerichs, as well as Tracie Olson, Dr. Arun Sen and Bob Schelen.

    Special thanks to Stewart Savage of Abaton Consulting, who put together a terrific slide show that was shown on a continuous loop at the event.

    Finally, we offer a big thank you to the committee that worked with us to plan and execute this successful event: Margie Cabral, Sheryl Cambron, Robin Dewey, Bill Grabert, Nancy Sue Hafer, Lewis Kimble, Steve Lopez, Fran Maguire, Amanda Maples, Joyce Puntillo, Dave Rosenberg, Raquel Silva, Robin Souza and Christopher Young. What a great, hard-working group.”

    52. Plaintiff is further informed and believes and thereon alleges that Davis Odd Fellows’ officers, directors, and members who are otherwise private actors — David Rosenberg, Lea Rosenberg, Kathleen White, David Reed, Sheryl Cambron, Jonathan Raven, Tracie Olson, Allison Zuvela, Michael Cabral, Rodney Beede and Christina Zambrano Beede — conspired amongst themselves to fraudulently conceal the fact that Sheryl Cambron is married to Judge David Reed and is otherwise an attorney employed by Yolo County Counsel and is in a confidential attorney-client fiduciary relationship with Odd Fellows’ members Jeff Reisig, Michael Cabral, and Jonathan Raven on the account of representing them and/or their office in matters such as Gore v. Reisig, In Re Garcia, and Yilma v. Agonofer.
    53. Plaintiff is further informed and believes and thereon alleges that as part of a common scheme and conspiracy to defraud in order to advance said conspiracy, in the hundreds of articles written and published by Davis Odd Fellows/Davis Rebekah Lodge (or about the activities of Davis Odd Fellows by outside publications such as the Davis Enterprise or Daily Democrat), the fact that Reed and Cambron are actually married to each other, that Reed is a judge, and Cambron is an attorney with Yolo County Counsel is never mentioned, in order to mislead and defraud the public and litigants by means of a plan they conceived and executed.
    54. Plaintiff is further informed and believes and thereon alleges that as a further overt act by which to advance the objective of said conspiracy, Sheryl Cambron conceals from the public her association with Yolo County Counsel by causing numerous legal web-sites to misrepresent her employment status. Most, if not all, of those web-sites state that Sheryl Cambron is in fact in private practice representing litigants in matters dealing with bankruptcies, family law, and criminal law.
    55. Plaintiff is informed and believes and thereon alleges that private actors Yolo Lodge 169, David Rosenberg, Lea Rosenberg, David Reed, Sheryl Cambron, Jonathan Raven, Allison Zuvela, Tracey Olson, Michael Cabral, and Kathleen White and Does 1 - 100 willfully and knowingly conspired and agreed among themselves to a scheme by which they agreed to conceal from the public and Plaintiff Cambron’s employment as an attorney with Yolo County Counsel, that she is the spouse of David Reed, as well as the confidential fiduciary relationship between Cambron on one hand and Reisig, Cabral and Raven on the other hand.
    56. Plaintiff further alleges that private actors Rosenberg, Reed, Raven, and Zuvela conspired to fraudulently conceal the fact that Zuvela is an Odd Fellow by intentionally removing her name from the web-site davislodge.org — which yields a zero return when a search is performed for her name . Additionally, Plaintiff is informed and believes and thereon alleges that David Rosenberg, David Reed, and Allison Zuvela conspired to further delete from the web-site davislodge.org all articles which mentions Zuvela’s name.
    57. These conspiratorial acts were substantial factors in causing Plaintiff monetary losses and damages in an amount to be established at trial.
    FOURTH CAUSE OF ACTION
    Fraudulent Concealment
    (Against Private Actors Defendants Yolo Lodge 169; David Rosenberg; Lea Rosenberg; David Reed; Sheryl Cambron; Jonathan Raven; Allison Zuvela; Michael Cabral; Tracie Olson; Kathleen White; and Does 1 - 100 )

    58. Plaintiff incorporates paragraph by reference paragraphs 1 - 57 as though fully set forth herein.
    59. Plaintiff is informed and believes and thereon alleges that Defendants committed the above described acts and omissions with intent to defraud the public and Plaintiff and deprive him of other interests he was entitled to. In particular, Defendants affirmatively concealed the existence of a marital relationship between Reed and Cambron, the fact that Cambron is an employee of Yolo County Counsel, and the fact that Allison Zuvela is an Odd Fellow member by affirmatively deleting her name from Odd Fellow web-site.
    60. Plaintiff is further informed and believes and thereon 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.
    61. Plaintiff reasonably relied upon the statements, acts, and omissions of Defendants to his detriment.
    62. As a proximate result of Defendants’ conduct, as alleged above, Plaintiff suffered injury in fact in an amount to be proven at trial.
    FIFTH CAUSE OF ACTION
    42 U.S.C. § 1983
    (Against State Actors Defendants David Rosenberg, Sheryl Cambron, Jonathan Raven, Allison Zuvela, Tracie Olson, Michael Cabral and Does 1 - 100)

    63. Plaintiff incorporates paragraph by reference paragraphs 1 - 62 as though fully set forth herein.
    64. Plaintiff is informed and believes and thereon alleges that state actors David Rosenberg, Sheryl Cambron, Jonathan Raven, Tracie Olson, Allison Zuvela and Michael Cabral and Does 1 - 100 willfully and knowingly conspired and agreed among themselves to a scheme by which they agreed to conceal from Plaintiff Cambron’s employment as an attorney with Yolo County Counsel, that she is the spouse of David Reed, the confidential fiduciary relationship between Cambron on one hand and Cabral and Raven on the other hand, and that Allison Zuvela is an Odd Fellow member, by among other things, deleting her name from the Odd Fellow web-site.
    65. Plaintiff is further informed and believes and thereon 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.
    66. Plaintiff reasonably relied upon the statements, acts, and omissions of Defendants to his detriment.
    67. As a proximate result of Defendants’ conduct, as alleged above, Plaintiff’s state and federal civil rights were violated and resulted in legal damages in an amount to be established 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 4, 2014

  • January 15, 2014

    VIA EMAIL AND US MAIL

    Jayne Kim, Chief Trial Counsel
    Office of the Chief Trial Counsel/Intake
    State Bar of California
    1149 South Hill Street
    Los Angeles, California 90015-2299

    RE: ETHICS COMPLAINT AGAINST CALIFORNIA STATE BAR MEMBER SHERYL ANN CAMBRON (#202741) FOR MULTIPLE ACTS OF FRAUD AND DECEIPT

    Dear Ms. Kim:

    This communication is intended to serve as a formal complaint against California State Bar member #202741, Sheryl Ann Cambron (AKA Sheryl A. Cambron or Sheryl Cambron), for gross acts of misconduct involving tax fraud, fraud, misrepresentation, deceit, and for deceiving the public in areas dealing with her place of employment and her relationship to her husband — Yolo County Superior Court Judge David Reed — so as to allow litigants the opportunity to seek disqualification of her husband (through either peremptory or for cause challenges).

    INTRODUCTION AND GENERAL BACKGROUND:

    Ms. Cambron is a 1999 graduate of Lincoln Law School in Sacramento. She is currently employed as an attorney by the County of Yolo, and is highly involved with entities known as Davis Odd Fellows/Davis Rebekah Lodge, which are located in Yolo County in the city of Davis.

    Ms. Cambron is married to her former law partner David Reed ("Reed"), who presently served as a judge with the Yolo County Superior Court.

    Reed and Cambron, together with Yolo County Superior Court Judge David Rosenberg (and his wife Lea Rosenberg), have been extensively involved with Davis Odd Fellows for many years, while in the process committing income tax fraud in order to mislead the IRS and the public, conspiring to refuse a request to share with me their IRS returns as mandated by IRS rules and regulations, as well as accepting donations from suspect entities such as Yocha Dehe Wintun Nations — the native American tribe which owns and operates Cache Creek Casino. (See http://davislodge.org/breakfast-with-santa-delivers-lots-of-fun ) Most, if not all, of the financial proceeds of David Odd Fellows goes to support “Emancipated Foster Youth,” in part, through a separate non-profit entity headed by David Rosenberg and his Judicial Campaign CPA, Victor Bucher (aka Vic Bucher).

    MISCONDUCT BY CAMBRON:

    I. Fraud and deceit in connection with Cambron’s marital and employment status.

    Any member of the public who researches the background of Judge David Reed will be hard pressed to ascertain that he is married to Cheryl Cambron. For example, in the tens of articles published by Davis Odd Fellows/Davis Rebekah Lodge (or about the activities of Davis Odd Fellows by outside publications such as the Davis Enterprise), the fact that Reed and Cambron are actually married to each other is not mentioned.

    Moreover, even in official returns submitted to the IRS during the time David Reed and Sheryl Cambron served concurrently as president and Treasurer of Davis Odd Fellows, a representation was made that they are not married to each other. (See attached Exhibit 1 — 2010 IRS Form 990: ‘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 Davis Odd Fellows states, ‘NO.’) Since two of the officers (Reed and Cambron) were actually married to each other, this is a misrepresentation to the IRS.

    The misconduct by Reed/Cambron did not end by just misleading the IRS and the public through the filing of inaccurate tax returns and the hiding from the public that they are married to each other. It appears that Cambron and Reed may have also conspired with each other to mislead the public as to the fact that Ms. Cambron is employed as an attorney by the County of Yolo.

    Indeed, it took the undersigned months of research into the background of Judge David Rosenberg to ascertain the extensive involvement of Judge Rosenberg (and his wife Lea Rosenberg) with various non-profit entities, which then led to Judge David Reed, which then led to Cambron, which ultimately led to the facts that Cambron is the wife of Reed, and is otherwise employed as an attorney by Yolo County.

    Despite the fact that Ms. Cambron is employed by the Yolo County, legal web-sites misrepresent her employment status. Most, if not all, of those web-sites state that Sheryl Cambron is in fact in private practice representing litigants in matter dealing with bankruptcies, family law, and criminal law.

    For example:

    http://www.manta.com/c/mmgy1fs/sheryl-a-cambron-law-office

    http://www.martindale.com/Sheryl-A-Cambron/2309804-lawyer.htm

    http://ebusinesspages.com/Sheryl-A-Cambron-Law-Office_262w6.com

    http://www.lawyerratingz.com/ratings/832508/Lawyer+Sheryl-Cambron.html

    http://lawyers.legalhelpmate.com/ca-lawyer-sheryl-cambron-81030.aspx

    https://www.sbn.com/California/Woodland/Listing/SHERYL-A-CAMBRON-LAW-OFFICE/_L1xsJt

    http://www.yourcriminallawyers.net/woodland-ca1.html

    http://web.awesomebusinesspages.net/category-1379876-0.htm

    http://web.awesomebusinesspages.net/detail-292310860.htm

    http://www.youinweb.com/profiles/95776/sheryl-a-cambron-law-office_361344348.htm

    http://www.manta.com/c/mt4l6tc/sheryl-a-cambron-attorney

    https://www.bizshark.com/person/551561541

    http://lawyers.legalhelpmate.com/CA-Lawyer-Sheryl-Cambron-81030.aspx

    http://www.lawyerratingz.com/ratings/832508/Lawyer+Sheryl-Cambron.html

    http://lawyers.justia.com/lawyer/sheryl-ann-cambron-72195

    http://www.justia.com/lawyers/criminal-law/california/woodland

    The above examples, attached as exhibits, are part of a scheme devised by the Reed and Cambron to mislead the public into believing that Cambron is in private practice, and not an employee of Yolo County, which then affords Judge Reed the opportunity to rule against litigants in matters dealing with, for example, unlawful searches and seizures, ipso facto absolving the county from civil liability while at the same time not disclosing the existence of a conflict of interest based on his wife’s employment with the County.

    Thank you for your time and prompt attention to this matter

  • Commission on Judicial Performance
    455 Golden Gate Ave.
    San Francisco, CA 94102

    RE: COMPLAINT AGAINST YOLO COUNTY SUPERIOR COURT JUDGES DAVID ROSENBERG AND DAVID REED

    To whom it may concern:

    In lieu of using a form complaint, this communication serves as an official judicial misconduct complaint against Yolo County Superior Court judges David Rosenberg and David Reed for violations of Canons of Judicial Ethics due to their (and their respective spouses, Lea Rosenberg and Sheryl Cambron) involvement with an entity known as Davis Odd Fellows, which discriminates on the basis of religion in violation of Canon(2)(C).

    GENERAL BACKGROUND:

    Yolo County Superior Court judge David Rosenberg (AKA Dave Rosenberg) and his wife Lea Rosenberg are heavily involved in an entity known as “Yolo Lodge 169 Independent Order Odd Fellows and Davis Rebekah Lodge” ( which also advertises itself as Davis Odd Fellow / David Rebekah Lodge/ and other related entities).

    The operation owns various pieces of real estate which are leased to various business establishments in the City of Davis, California. As will be shown in future complaints, there is more than meets the eye here, as overall transactions involving Davis Odd Fellows appear to involve suspicious and secretive financial transactions, racketeering, income tax fraud, and related acts of misconduct.

    Over the years, both the Rosenbergs (David and Lea) and Judge Reed and his wife (Cheryl Cambron - an attorney employed by Yolo County) have been extensively involved in this organization. At various times, Rosenberg/Reed/Cambron served as president and vice-president interchangeably.

    Presently, Dave Rosenberg is also the membership committee chairman (see: http://davislodge.org/how-to-join ).

    Anyone who is interested in becoming a member must be sponsored by another member and must be “loyal to his or her country and believes in a Supreme Being, the creator and preserver of the Universe, is eligible for membership.” (See http://davislodge.org/how-to-join )

    Additionally, the Odd Fellows Valediction reads as follows: “I AM AN ODD FELLOW: I believe in the Fatherhood of God, and the Brotherhood of Man.” (See: http://davislodge.org/odd-fellows-valediction)

    MISCONDUCT:

    As mentioned above, both Judge Rosenberg and Judge Reed are judges of the Yolo County Superior Court and both are members and directors of Davis Odd Fellows. As such they must adhere to the canons of judicial ethics.

    Canon 2(C) reads: “A judge shall not hold membership in any organization that practices invidious
    discrimination on the basis of race, sex, gender, religion, national origin, ethnicity, or sexual orientation. This canon does not apply to membership in a religious organization or an official military organization of the United States.”

    The Independent Order of Odd Fellows (IOOF) in general, and the Davis Odd Fellows in particular, are not “religious organization” per se (ie, churches). Rather they are considered a fraternity. (See: http://www.ioof.org )

    Davis Odd Fellows describes itself as follows:

    "The Davis Odd Fellows Lodge was chartered in 1870 and currently has over 200 members, making it one of the largest Odd Fellows Lodges in the nation. The Odd Fellows Lodge is a fraternal order, dedicated to community projects of all kinds. The Davis Odd Fellows put on Taste of Davis, Breakfast with Santa, Breakfast with the Bunny among other community events and projects. The Lodge also hosted the “DogtoberFest” which raised funds to purchase a new K-9 for the Davis Police Department, and set a Guinness World Record for the longest single line of bicycles which raising over $15,000 for the Davis Schools during the “World’s Greatest Bicycle Parade.”

    In that David Odd Fellows owns real estate which it rents to the highest bidder, it qualifies as a “business establishment” which must comply with statutory and constructional bodies of California law protecting the civil rights of its citizens.

    In view of the foregoing, both Odd Fellows members Judge Rosenberg and Judge Reed should be disciplined for their involvement in the organizations, as it is clear that Davis Odd Fellows is not a “religious organization.” The improper involvement is particularly heightened for Judge Rosenberg, the membership committee chairman, who via his position requires that all new members believe in a “Supreme Being” and the “Fatherhood of God.”

    Thank you for you time and attention to this matter.

  • IRS Asked to Investigate Non-Profit Entity Headed by Yolo County Superior Court Judges David Rosenberg and David Reed

    September 29, 2013

    Internal Revenue Service
    Exempt Organizations Unit
    1100 Commerce St.
    Dallas, TX 75242-1198

    Via E-Mail and U.S. Mail

    Re: A referral against exempt organization YOLO LODGE 169 INDEPENDENT ORDER OF ODD FELLOWS AND DAVIS REBEKAH LODGE (EIN Number 23-7417292) and officers David Reed, Sheryl Cambron, David Rosenberg, Lea Rosenberg, and Virgil Smith

    To whom it may concern:

    In lieu of using the IRS’s Tax Exempt Organization Referral Form 13909, please consider this communication a formal complaint ("referral") against YOLO LODGE 169 INDEPENDENT ORDER OF ODD FELLOWS AND DAVIS REBEKAH LODGE ("Yolo Lodge") for fraud and deceit. Specifically, officers and directors of Yolo Lodge repeatedly misrepresented to the IRS (and the public) the nature of their familial relationship.

    FRAUD BY YOLO LODGE PRESIDENT DAVE REED AND HIS TREASURER WIFE SHERYL CAMBRON

    In 2010, serving as the president of Yolo Lodge was David Reed; serving as the Treasurer of Yolo Lodge was Sheryl Cambron.

    David Reed and Sheryl Cambron are married to each other. However, Reed and Cambron chose to mislead the IRS and the public as to the true nature of their relationship. More specifically, Reed and Cambron failed to disclose, as they were required to do, to the IRS that they were married to each other while serving as officer of Yolo Lodge.

    For example, 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.

    FRAUD BY YOLO LODGE PRESIDENT DAVID ROSENBERG AND HIS SECRETARY WIFE LEA ROSENBERG

    In 2011, Yolo Lodge officers perpetrated the same lie with a different set of actors, namely Lea and David Rosenberg, who are married to each other.

    Specifically, In 2011, serving as President of “Yolo Lodge” was David Rosenberg; his wife, Lea Rosenberg, served as “Secretary” of Yolo Lodge, and Dave Reed served as a board member.

    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.

    It is important to note that both David Rosenberg and David Reed are judges of the Yolo County Superior Court, and such misrepresentations are extremely serious. This is especially true when viewed in conjunction with the circumstances described in a prior complaint the undersigned submitted to the IRS dated May 23, 2013 (see exhibit A), which is incorporated herein by reference.

    ADDITIONAL MISCONDUCT BY LEA ROSENBERG, DAVID ROSENBERG, AND DAVID REED.

    On September 24, 2013, the undersigned sent Lea Rosenberg an email which read as follows:

    "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 Camberon, 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."

    Rather than complying with my request to produce the relevant 990 Form, as she was required to do, Ms. Rosenberg sent me an email which reads, in its entirety, “so he is at it again.”

    As such, the undersigned requests that the IRS also investigate and impose appropriate sanctions on “Davis Odd Fellows Hall” officers David Rosenberg, David Reed, and Lea Rosenberg as it is clear from Ms. Rosenberg’s latest communication to me, cited above, that she ( David Rosenberg and David Reed) do not plan to comply with the request to produce the requested 990 form. In fact, if anything, Ms. Rosenberg’s email response makes clear that she views my legitimate requests as nothing more than a nuisance, rather than a legitimate request authorized by the IRS Code.

    Thank you for your assistance with this matter. Please do not hesitate to contact me if you have any questions or need further information.

  • BREAKING NEWS: Yolo County Superior Court Judge David Rosenberg and Former Foreperson of Yolo County’s Grand Jury Barbara Sommer Face Scrutiny

    In the midst of a growing controversy over Lea and David Rosenberg, the former foreperson of Yolo County’s Grand Jury has been identified as a potential wrongdoer in a civil inquiry into the peculiar circumstances surrounding familiar faces and a familiar casino in the context of a relatively unknown Davis-based non-profit entity, Progress Ranch.

    Barbara Sommer (who currently serves as the president of Progress Ranch; President of California Grand Jurors’ Association - Yolo County Chapter) is being looked into for indications of whether she may have been the recipient of questionable gifts during a time period when she served concurrently as Treasurer of Progress Ranch and Foreperson of Yolo County’s Grand Jury in order to influence the outcome of various legal proceedings, and especially a Grand Jury investigation of Cache Creek Casino located in Yolo County.

    The rapidly expanding multi-prong civil inquiry, conducted by TLR’s confederate — Yolo County’s YR —also views Yocha Dehe Wintun Nation, Chairman Marshall McKay, and attorney Howard Dickstein as parties who may potentially have a played a role in the scheme, although this investigation is continuing.

    A source familiar with the situation, speaking on condition of anonymity, maintains that evidence shows that for a period of several years, four or five non-profits commandeered by Lea and David Rosenberg (Soroptimist International of Davis , Davis Rebekah Lodge, Davis Odd Fellows, Davis Odd Fellows Charities, Inc., and possibly Davis Sunrise Rotary Club) devoted unusual and, indeed, exclusive attention to financially benefit “foster youth” and/or “emancipated foster youth” in Yolo County.

    For example, Lea and David Rosenberg (at times, with the assistance of Judge David Reed and CPA Victor Bucher) raised funds to support foster youth by mobilizing Davis Odd Fellows ("Breakfast with Santa"), Soroptimist International of Davis ("Texas Hold ’Em" ), Davis Rebekah Lodge ("Crab Feed"), and Davis Odd Fellows Charities, Inc. ("Orphan Scholarship Fund").

    Also being looked into are Gretchen Peralta and Allison and Robert Woolley. Both Peralta and Robert Wooley are directors of Progress Ranch. Allison Wooley sold tickets to “Texas Hold’ Em”.

    Please continue @: http://tinyurl.com/d6ytujl

  • Alphabetical List of Organizations / Individuals That Are of Interest to The Leslie Brodie Report — Year 2013

    For updates, please see @:

    http://lesliebrodie.blog.co.uk/2013/01/01/the-leslie-brodie-report-2013-people-of-interest-15372924

    A.

    AARP - American Association of Retired Persons;

    Peter Arth of CPUC;

    Accenture;

    Robert Adler of Southern California Edison, formerly of Munger Tolles;

    Marty Africa of Lindsey Major & Africa;

    Allen Matkins;

    Ruthe Catolico Ashley (aka Ruthe Ashley);

    Lance Astrella of Astrella & Rice;

    B.

    Starr Babcock of State Bar of California;

    Ophelia Basgal, formerly of PG&E;

    Gibor Basri of UC Berkeley Foundation/ CaliforniaALL;

    Jeremy Ben Ami of J. Street;

    Bet Tzedek Legal Services of Los Angeles;

    Jeffrey Bleich of Munger Tolles & Olson/ Obama for America;

    Richard Blum;

    Geoff Brown of CPUC;

    Frederick Brown of Gibson Dunn;

    Boyd Gaming;

    James Brosnahan of Morrison & Foerster / Obama for America;

    Ron Burkle of The Yucaipa Companies;

    John Burton of California Democratic Party;

    C.

    CaliforniaALL;

    California Forward;

    California Emerging Technology Fund;

    California Consumer Protection Foundation ("CCPF");

    California Supreme Court Historical Society;

    California Endowment;

    Annette Carnegie of Morrison & Foerster;

    CB Richard Ellis;

    Center for Asian Americans United for Self Empowerment (CAUSE);

    Alec Chang of Skadden Arps;

    Raj Chatterjee of Morrison & Foerster;

    Erwin Chemerinsky of UCI School of Law;

    Ming Chin, Associate Justice of California Supreme Court;

    Steve Churchwell of DLA Piper;

    CityView:

    Richard Claussen of Goddard Claussen;

    CleanTECH;

    Joe Cotchett of Cotchett Pitre & McCarthy

    Dick Costolo of Twitter / Posterous;

    D.

    Angela Davis of US Attorney’s office in Los Angeles/ Judicial Council

    Howard Dickstein ;

    Jeannine Dickstein (aka Jeannine English);

    Jack Dorsey of Twitter/Posterous;

    DLA Piper;

    Duke Energy;

    Joe Dunn;

    Kinde Durkee;

    E.

    Edison International

    Judge Morrison England;

    Torie Flournoy-England;

    Jeannine English (aka Jeannine Dickstein);

    EPIC Church at 543 Howard;

    Martha Escutia;

    F.

    Jerome Falk of Arnold & Porter(formerly of Howard Rice);

    Timothy
    Judge Tim Fall of Yolo Couty Superior Court (image:courtesy photo)

    Judge Timothy Fall (aka Tim Fall) of Yolo County Superior Court;

    Nancy Fineman of Cotchett Pitre & McCarthy;

    James Brosnahan, Jeff Bleich, Willie Fletcher
    From left James Brosnahan, Unknown, Jeffrey Bleich, and Judge Willie Fletcher (Image: courtesy photo)

    William Fletcher : FOB — Friend of Bill Clinton;Democratic Party Operative; Judge with Ninth Circuit Court of Appeals; UC Berkeley;

    For People of Color, Inc. — entity associated with MTO;

    Mark Friedman of Fulcrum Property;

    Holly Fujie;

    Fulcrum Property;

    G.

    Ronald George;

    Eric George;

    Girardi & Keese;

    Thomas Girardi;

    Golden Pacific Bank;

    Joilene Wood Grove;

    David Grove ;

    Jasmine Guillory;

    H.

    Karina Hamilton of UC Irvine;

    Robert Hamilton of Allen Matkins;

    Leslie Hatamiya;

    Kamala Harris;

    William Hauck of Goddard Claussen;

    Robert Hawley of State Bar of California;

    Tony Haymet of Scripps Institution of Oceanography ;

    James Hsu

    I.

    Institute on Aging;

    J.

    Judy Johnson;

    K.

    Raoul Kennedy of Skadden Arps;

    Freada Klein Kapor;

    Mitchell Kapor;

    Keker & Van Nest;

    John Keker of Keker & Van Nest;

    Brenda Kempster of LINK AMERICAS Foundation

    Pat Fong-Kushida

    Stewart Kwoh

    L.

    Walter Lack of Engstrom Lipscomb & Lack;

    David Lash;

    Tom Layton of State Bar of California / Los Angeles Sheriff’s Department;

    Patricia Lee

    Richard Lehman of Lehman Levi Pappas & Sadler;

    Larry Lessig;

    Level Playing Field Institute;

    David Lira;

    Little Tokyo Service Center;

    Donna Lucas of Lucas Public Affairs

    Greg Lucas

    M.

    Susan Mac Cormac of Morrison & Foerster;

    Nancy McFadden of PG&E / UC Berkeley’s Goldman School of Public Policy / Jerry Brown’s

    Dennis Mangers;

    Manika Jewelry;

    Patrice McElroy;

    Nancy McFadden of PG&E;

    Sunne McPeak;

    Howard Miller of Girardi & Keese;

    Victor Miramontes of CityView / CaliforniaALL;

    Gwen Moore of GEM Communications / Shrimpscam/ State Bar of California;

    Munger Tolles & Olson;

    N.

    Bettina Neuefeind;

    Tom Nolan of Skadden Arps;

    Bill Novelli of AARP/Porter Novelli;

    O.

    Barbara O’Connor of AARP, Lucas Public Affairs;

    Pierce O’Donnell

    Ron Olson of Munger Tolles & Olson / Berkshire Hathaway / Southern California Edison

    P.

    Pacific Gas & Electric Company;

    Larissa Parecki;

    Mark Parnes of Wilson Sonsini;

    David Pasternak of Pasternak Pasternak & Patton ;

    Bradley Phillips of Munger Tolles & Olson;

    Michael Peevey of CPUC;

    Pegasus Capital;

    Roman Porter;

    Porter Novelli;

    Q.

    R.

    Sarah E. Redfiled of UNH School of Law;

    Jeff Reisig ;

    Reliant Energy;

    JoAnn Remke;

    Mark Robinson of Robinson Calcagnie Robinson/Judicial Council;

    Richard Robinson

    John Roos, formerly CEO of Wilson Sonsini;

    Alan Rothenberg of 1st. Century Bank;

    Fred Rowley of Munger Tolles;

    Dave Rosenberg of Yolo County Superior Court / Judicial Council;

    Bonnie Rubin of 1st. Century Bank / State Bar of California Legal Services Trust Fund Commission

    S.

    Scripps Institution of Oceanography;

    Douglas Scrivner of Accenture

    Thomas Silk;

    Larry Sonsini

    Southern California Edison;

    State Bar of California Legal Services Trust Fund Commission

    Station Casinos;

    Jon Streeter of Keker & Van Nest;

    Aaron Swartz;

    T.

    Mary Ann Todd of Munger Tolles & Olson / California Bar Foundation

    Richard Tom of Southern California Edison / California Bar Foundation

    U.

    UC Irvine School of Law;

    UC Irvine Foundation;

    UC Berkeley Foundation;

    UC Berkeley’s Goldman School of Public Policy

    University of Phoenix;

    V.

    Venoco;

    Verizon Communications

    Voice of Orange County

    W.

    James Wagstaffe of Kerr & Wagstaffe;

    Monica Walsh of Manika Jewelry;

    David Washburn of Voice of OC;

    Madge Watai

    Henry Weissmann of Munger Tolles & Olson

    David Werdegar of Institute on Aging;

    Kathryn Werdegar, Associate-Justice of California Supreme Court;

    Matthew Werdegar of Keker & Van Nest;

    Tony West of United States Department of Justice;

    Steve Westly;

    Anita Westly

    Wilson Sonsini

    Douglas Winthrop of Arnold & Porter(formerly of Howard Rice), California Bar Foundation;

    X.

    Y.

    Christopher Young of Keker & Van Nest
    Christopher Young of Keker & Van Nest (image: courtesy)

    Christopher Young of Keker & Van Nest

    Z.

    Carry Zellerbach (aka Mary Ellen Zellerbach);

    Daniel Zingale;

    Zurich Financial Services / Zurich Insurance;

  • Correction: Yolo County Superior Court Judge Dave Rosenberg / Yolo County Superior Court Judge Dan Maguire / Yolo County Deputy District Attorney Clinton Parish

    In TLR’s recently published article concering Yolo County Judge Dave Rosenberg inappropriate conduct (see http://tinyurl.com/cbx26cb ), we erroneously stated “Judge Rosenberg also promised to retaliate against Parish and issued a thinly veiled threat against him. This sort of phlegm tends to backfire. It flies back in the face of the expectorant.”

    In fact, what we should have written is “Judge Rosenberg also promised to retaliate against Parish by issuing a thinly veiled threat against him, to wit: This sort of phlegm tends to backfire. It flies back in the face of the expectorant.”

  • Clint Parish — Yolo County Deputy District Attorney — Hereby Asked to Opine On Presiding Judge Dave Rosenberg Inappropriate Role As Political Advocate of Yolo County Superior Court Judge Dan Maguire

    Consistent with The Leslie Brodie Report’s commitment to integrity and adherence to the highest level of ethical journalism, and in order to report on both sides of a controversy, Mr. Clint Parish — Yolo County Deputy District Attorney — is hereby being asked to opine whether Yolo County Presiding Judge Dave Rosenberg highly inappropriate role as spokesperson/political advocate of Yolo County Superior Court Judge Dan Maguire — may be in violation of California’s Cannon of Judicial Ethics

    Specifically, in response to a recent controversy concerning a mailer sent by the Clint Parish’s campaign which sought to portray Judge Maguire as Arnold Schwarzenegger “bagman,” and being part of Schwarzenegger’s “inner circle” which recommended the release of convicted murderer Esteban Nunez, the son of former Assembly Speaker Fabian Nunez — a highly perturbed Judge Rosenberg launched an unprecedented attack on Parish. This, despite knowing full well that California Canons of Judicial Ethics permit a judicial officers to only “endorse” candidates for judicial office.

    Specifically, and consistent with his new role, Judge Rosenberg resorted to sending a robocall out to many voters “to set the record straight” of what he called, “a nasty political hit piece” which “contains flat out lies and deceptions about a highly respected Judge here in Yolo County, Judge Dan Maguire.”

    Judge Rosenberg also promised to retaliate against Parish and issued a thinly veiled threat against him. “This sort of phlegm tends to backfire. It flies back in the face of the expectorant,” Rosenberg stated.

    Please observe that, rather than contacting Mr. Parish directly, the query is being delivered publicly, here and now.

    Any comments,opinion or observation can be sent to lesliebrodie@gmx.com