person:michael peevey

  • 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,

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

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

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

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

    Dear Mrs. Rosenberg:

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

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

    [—address intentionally omitted—]

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

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

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

    Dear Ms. Rosenberg:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

  • 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

  • Martha Escutia, Jose Solorio Now Part of Inquiry into Sham Charity CaliforniaALL

    Orange County-based attorney Martha Escutia as well as Assemblymember Jose Solorio are under extreme scrutiny in matters relating to sham charity CaliforniaALL, The Leslie Brodie Report has learned.

    CaliforniaALL, a 501(c)(3) charitable entity, was the brainchild of Ruthe Ashley (a Diversity Officer at CalPERS and Vice-President of the State Bar of California), Visiting Professor Sarah E. Redfield, and Peter Arth Jr., Chief of Staff to CPUC President Michael Peevey.

    In its brief existence from 2008 to 2010, CaliforniaALL collected close to $2 million from utility companies (AT&T, PG&E, Verizon, Sempra), including a sub-rosa contribution of $769,247.00 from the State Bar of California Foundation (DBA California Bar Foundation.)

    CaliforniaALL was abruptly dissolved in June of 2010.

    Sources with knowledge of the investigation, speaking on condition of anonymity, maintain a red flag has been raised over Escutia and Solorio due to the overall circumstances surrounding Escutia’s law partner — Joe Dunn and his publication, “Voice of OC.”