09-01-13 Samaan v Zernik (SC087400) Bank of America-moldawsky Extortionist Second Supplemental...

8/9/2019 09-01-13 Samaan v Zernik (SC087400) Bank of America-moldawsky Extortionist Second Supplemental Declaration-s

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1 II BRYAN CAVB LLPJohn W. Amberg (CA State Bar No. 108166)2 lI]enna Moldawsky (CA State Bar No. 246109)120 Broadway, Suite 3003 II Santa Monica, California 90401-2386Telephone: 310-576-21004 II Facslmile: 310-576-220056 Attorneys for Non-Party COUNTRYWIDE HOME LOANS, INC.789

10

SUPERIOR COURT OF THE STATE OF CALIFORNIAFOR THE COUNTY OF LOS ANGELES, WEST DISTRICT

11 II NIVIE SAMA..A.N, et al.,

SECOND SUPPLEMENTALDECLARATION OF JENNAMOLDAWSKY IN SUPPORT OFCOUNTRYWIDE HOME LOANS,INC.'S MOTION FOR SANCTIONSAND OTHER RELIEF AGAINSTDEFENDANT JOSEPH ZERNIK

Case No. SC087400

Date: January 13, 2009Time: 8:45 a.m.Place: WE]

Plaintiffs,

Defendants.

vs.

12131415 II JOSEPH ZERNIK, et al.1617181920 ~ ' - - - - ~ - - ---'I21

III00C'l


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2. O n December 3,2008, Zernik sent a letter to Kenneth D. Lewis, President,2 II Chief Executive Officer and Chairman o f Bank of America Corporation, and Teresa M.3 II Brenner, Associate General Counsel for Bank of America Corporation. In the letter Zernik4 II demands that Bank o f America Corporation "mitigate [his] damages" relating to the present5 II action, an d calls for "corrective action." Included in the letter is a purported "press release"6 II in which Zernik alleges that Countrywide is guilty o f "fraud," and accuses the Los Angeles7 II Superior Court of "elaborate court fraud." A true and correc t copy of this correspondence is8 II attached to this declaration as Exhibit A and incorporated herein by reference.9 3. On December 11, 2008, Zernik sent another letter to Mr. Lewis an d Ms.

10 II Brenner, along with Timothy Mayopoulos, General Counsel for Bank o f America11 II Corporation, and William J. Mostyn III, Deputy General Counsel for Bank o fAmerica

18 II hearing on its Motion.19 II I declare under penalty o f perjury under the laws of the State o f California that the20 II foregoing is true and correct.21 II Executed on January 9, 2009 at Santa Monica, California.

(0(Xl(I)C)I

0-00(I)III Ol!: lgnodbyJ


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H .LIHIHX3:


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.JosephZemik DMDPhDF a x ~ (801) S9E-0917 Email: jz1:2345@earthlinknet

. D ~ t ~ l y ~ Q n e d

.by JoH-pha,tt ik-ON;cnoJc ph~ . Zcrnlk,..) . ~ / .....6'*'2345 ..t J ! t h 1 t n k . ~ t ;(aUSDale: 1OQ8.12:1111);J?;J6..oe'OO'

" Jurig.esha,'be fafthfulto tf1e Jaw ... '!CarCodt! Jud EtIJIcs.JfJ(l)"Therule ofJaw must neverbe C01Tfusedwfth tyranny of the courts"Anotwmu&

TIMELY RESPONSE REQUESTED) December 11, 2008, j Teresa M. BrennerAssociate General Cmmsel signer ofSEC filingsKenneth D. LewisPresident, CEO. ChairmanTimothy Mayopou)osBOA GeneralCom]j'e/William .JMostyn II IDeputyGeneral Counsel - Si}!;l1er qfstatements to share holdersBankQfAmerica CorporatioIi(Bm'lk:ofAmerica)100 N Tryon StNCI-007'-56-11Charlotte, NC 28255By FM; (704)370-3515By Email: ..AttentionBrenner.Lewis.Mayopoulos.Mostyn ..."Attention B r e n n e r , ~ w i s , M a y o p o u l o s ; M o s t y n i, HE: COUNTRYWIDE.RACKETEERING UNDERTHEGUISEOF LlTlGI,\TION IN LOS ANGELES.NOTICES, RF.QUESTSAND DEMANDS TO MlTlGATE DAMAGES.RESPONSE BY BANKOF AMERICA R E Q U " ' ~ S n ~ [ ) BY TUESOAY, DECEMBER 16,2008; 5:00PM.Madam & Sira,1am the viCtim ofteal estate fraud perpetrated by CountryWide Home Loans, Inc; SanRafaelBranch, CountrywideLegalDivision, and others, through fabrication of ~ o u r t records, whichstarted in early 2006. The. scope and severity ofwrongdoing in this case makes the report of"recreated letters" filed as evidence in Pennsylvania in Janmuy 200S I ) and the cases dOcumentedin judge JeffBohm's (U.S.Court; Texas) opinionfromMarch 2008,2 rebuking CountrywideLegal Division litigation practices, paleinc6inparisoiI.My attempts last week to establish who is tlUlyauthorizcd by Bank ofAmerica as -c6uriSeJ inmatters pertaining to me was unsuccessful, as noticed below. 'therefore, this comnllmication issent ~ the Lcgal'Departmentand ChairlPre:sidentfCEO.Belowplease seeNotices, to reliably infonn you ofpertinent issues in thismatter, as well asReqtiestsandDemands, expe.cted as part ofyour corrective actions and mitigation of damages.

.1 _Reports pertainIng to "recreated l e t t ~ r S ' filed as e V l d e ~ c e , by Cou.ntryWide in Pennsylvania court. ..' .h t l p : / f i n p r o p e n n l a . c o m l 0 8 - 0 4 c . Q 2 " - u s - d l s t - e t - l a 1 - r e q u e S l J u d I C l a l n o t i c e - a t t f j n ~ . J u d g e b o h m - r e c r e a t e d . . f e t t e r s s . p d f 2 Opinfon of JUdge Elohm (U.s. Court, Texas) rebuking Counti'ywide'slitigationpraclicesh t t p : / / i n p r o p e r i n 1 3 . e o m l 0 8 - 0 ( j ' - Q 2 - u s ~ i s t - e t - l a - 1 - r G q u e s t : i u d i c i a l - n o 1 i C 9 ' a t t . f i n 9 - : : j U d g e - b o h m - t e c r e a t e d . l e t t e r s . s . p d f


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Page2l12 D ~ m b e r 11,2008A. NOTICESL Please Take Notice: Harassment and Intimidation bv CountrywIde continues eventodav.

Having had rio business with CountryWide, and initially not even knowing aboutCountrywide's involvement in the case, it took till December 2006.before I discovered thefraud and requested directly ftom MrSandor Samuels and Mr Angelo Mozilo to stop it,which they refused to do.Instead, Countrywide started Ol t July 6. 2007 a campaign of harassment andint-imidation.Sand{)r Samuels dec)aredhimself"Parly ofinlerest in the case in early 2 0 0 8 ~ BtyanCave,L L P ~ wasretained to representCOimtIywide, and ~ u c h counsel startedappearing in this caseon arcgular basis, without any defined party designation. As it turned out; several o f th ejUdges of the LA Superior Court were


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Page 31102 December 11, 2000litigation byme against COlmtrywide, ancttherefore against BOA, which prevented further'direct c-ommwucationbetween.me and the BOALegal Department. lbetieve that such directcommunication could bring this travesty to an immediate end.SOO11 afterwards, I tried to conui.1Wlicate withMt Book, following instructions ofyour LegalDep


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Page4/12 D.ecember 11 . 2008c. Please Take Notice: Disqualification/recusal of Judge John Segal, prior to that, directlyinvolved Countrywide. 1n his recusal statement JJudge Segal claimed that Countrywide

was "merely a w'itness"in this case. But elsewhere in the same statement, Countr)'vridewas once designated Defendant, and another time yet another party designation.

d. Please Take Notice: Judge Segal, who held thecoUlt me in this case from October5,2007 to December 4. ~ - o 0 7 . and acted as presiding judge for all purposes; never had thecase duly assigned t( l him by order ohhe Supervising Judge, as required by law,

e. Please Take Notice: Judge Allan Goodman, who held the court file in this case from SeptI I, 2007 to Oct 3 , 2007, eventually recused citing his ". longstanding t;/ose personalrelationship willI tlleGeneral Counselo/Counlrywide4" - Sandor Samuels.f. Please Take-Notice: Judge Goodman, too, had no assignment order to this case.g. PleaseTake Notice: Judgewas first disqualified for a cause in open courton July 12,2007, and the causes listedmostly referred to her treatment ofCountrywide in the court,

beyond preferential - out of compliance and in Violation of the law. She deceitfullyignored theDisqualification for a Cause,ruling it "vas an untimelyPeremptol)' C h a n e n g e ~h; PleaseTake Notice: Judge Connor was disqua:Iified for a cause a second time on Sept 10,

2007, agaitl,- roUGh ofthe Statement ofDisqual ification referred to her treatment ofCountrywide in court.l. Please TakeNotice: On Sept 11, 1007., a day after her second disqualification fora cause,and. teCusal, Judge Comiotdooeitfully entered aminute order of a fictitious hearing that

was never h e a r d ~ d a ruling that w a s n e v ~ r r u l e d , to the effect that there was no fraud inCountrywide'sfraudulent subpoena productionS.j. Please Take Notice: Judge COMor,too, had no assignment order to this case.k.. Please Take Notice: [appeared before each and every oneof these judges with a requestthat they notice me oftheirassignmcntorder to establish their jurisdictional authority. Alldenieq such rcquest&. . .. Please Take Notice: r a p p e ~ several times beforeSupervising Judge Rosenberg with arequest that he duly issue Assignment Order to judgespresiding in this case, as requiredby law,but he denied,all such requests. . .

3 JUdge Segal's fra udulent RecusalStatement can be viewed at pages -183- atseq of the compiled minute orders of$amaan v Zernlk (page number 4#,. refers to number a l ~ right of each page of the record). Such statement opened witha fraudulent claim: 'Although judgmentwas entered on the complaint in lhisaction "afore this actionwas assigned tothe undersigned judge... '. In fact even today, tho office pf Presiding Judgo and the Offioo of the Clerk ofthe Courtrefuse to certify the eXistence cifan entered jUdgment in this case, and also refuse to certify the non-exiSlenteOfentered jUdgment In this case. The t rue facts in this ma'tt&r are that LA CountySupl9riorCourt 01 ) ionger keeps a BaokofJudgments (either electronic or paper-based), in violation of the law, and also in violationofits own L06alHules ofCoort.~ : l l i n p r o p e r i n l a . C O m l O O - O ~ l a - s u p : c t " D 1 i n u t ~ r d e r s - e l e c t r o n i o - c a ~ - l i l e - 0 8 - 1 1 - 1 4 ~ f u l I ~ r t i r - $ ~ , p d f .JUdge Goodman ReclIsalstafement",...ambe vlewedcat page-9S- et seq (j f records.hnked In3) above.$ Fraudulent minute order entered l:lyJud.ge Connor tlrJ Sepi 11, 2007. after disqualification and recusel Or:lsel1t10. '2007,purporting to reoord.a fictitious hearing ahd fictifiousrulJngthat fouoonofraud in Couhtrywide'ssubpoenarecords; pages81- of ~ r d s linked in 3) above


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Page 5112 December 11 , 20084. Please Take Notice: No active litigatwnand!or pending nuztters ,existbv Zernik againstBOA/COWl1lVwide at presentin either S t ofCaJifnrma .orCl..:.({. court... .contrary to what

BOA waS probably misleadinglvinfonned.I repeatedly heard it stated by phone by individuals in your LegalDepart:n:i.ent that I wasinvolved inlitigalion agdinstCuuntrywide and/or Bank ofArnerica. Such are falsestatements that I wanted tooorrect.Please be infonncd thatcurrently there is no valid litigation by Joseph Zemik against BankofAmerica and/or its subsidiary CountrywideHome Loans, Inc in either CaliforniaSuperior Court or in U.S. District COllrt:a) Samatin v Zernik (SC087400) was all along an"Enldrprise Case" of the Judiciary, andnot a genuine California SUperior Courtcase, as indicated by the evidenee. The office ofPresiding Judge and the Office of the Clerk. of the Court, as well as their counsel refusetoanswer any questions on th.issubject in recent months, infact confinning such designationof this case. Had the case been a true SuperiorCourt Case, no valid CHL litigation wouldhave been in existence either, sin.cc CHL corruptly assumed the designationof"Non-Party", under which the Judges allowed it to bring actions against Zcmik,butdcnicdZcrriikthe right to bring actions againstCH1. Such obviously could norbe validlitigation ofanyUS. court system.kJ Zernik v Connor (2:2008CV015SOJ Litigation in U.S. District Court, LA, wasinvalidated from day one, when thepro sa clerk refused to acceptand-sign valid summons,and instead, In violation of the Rules (jfCOUi1,..utsistedpuproducing and signing hiSQ\vnsummohS - which were defective; When Z:ernik caughttbisdishcmesty,and tried to presentthecleik with valld slirritnohs fo r the second time, same clerkagain tefusedto issue thev a I i d s t u n m o n s , ~ l a i m i n g to dQ sounder order ofMagistrate Judge W o e h r l ~ . Obviouslylitigation with no valid swtUnCinS cannot be vaiid litigation. Other defects noted in thislitigation, .whiCh indicate tlmt Judge Phillips and JudgeWoehrle never cons-ideted it truevalid litigation are: .

- Failure to conduct initial case conference- Failure to list corporate entities as requke by law- Failure to acljudicate motions.- Gag order set on aU Zernik's filings incourt.

5. Please TakeNotice: The a p p ~ t l N l l l c e a f t { t p ( i 1 t k i p a 1 i o nofCHL ;ninatfef-desij!JtafeaSamaan v Zernik was founded in fraudandObstrllctionIPerversionofJustice frombegifming to emL'Lbe fIrst appearance ofCHL inSamoan vZemik was onJuly 6; 2007, for a gag order., in aftexparte application by Bryan Cave, LLP I filed with Judge Jacqueline Connor, and heardwhen the court was dark, offthe record and (lff the calendar,. In its papers Bryan C a v e ~ LLPlisted Countrywrdeas ''NOH-Party'', but the court: listed it on that day as "Plaintiff'.


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PageG/12 December 11 , 2008The most recent scheduledhe.aring in Samaan V Zernik was on November 21,2008, andthere too, CHL appearance was part of fraud by the court, aimed at Obstruction/Perversionof Justice, In this latestproceediilg, the coUrt sentnotice to only 3 parties: Samaan, Zemik,andCHL. Two other parties were omitted, out ofcomptiance with thelaw. And em wasadded, also out ofcC)mpliancewith the .Iaw,and this time was designated as "J)efendant."To hide the fact thatCHL was noticcdas such fraudulent party, the Court used defectivenotice fanTIs, and omittc(j the mailing list required by law in valid notice.For the past year and a half the court .has engaged in such fraudulent litigation practicesrelative to Cm...

6.PJease TakeNotice: Sham litigation under the designation Samoan VZernik in th e LASuperior Coy.rl was-and lY the outcome o(ex/etrsive conspiracy by CHL San RafaelBral1.ch and its Manager -MariaMcLaurin, Counflywide's Legal Divisiott, includingAttSandorSamuelsandAll Todd Book. Bryan COJle, LLP {counsel (Pr putpd11ed "Noil"C"P a r t v ~ ' Counirvwide). Samnan lourpol1ed plai;lti(f) ,.KeshavamlCo.unst!/ for purportedplairiiiffl .JliiIges CONnor, SegaL FriednulIt, andRosenberg ( p u " ' b o r l ~ d l v judges inlitigatiOn ofthe California SuperilJr COidtJ. pworfedCourt OffICers Da.vidPasfernak,Gregory 0 'Brien, an d others.A reasonable p e r s o n r e v i ~ w i n g , t h i s case as ""hole, wOljlq mo$t likely conclude that JudgeConnorparticipated in the design of this fraud even before the complaint was f i l e d ~ s i t i c ethe complaintwas made to tnatebJudge Coru;lor's fraud on enUy ofjudgment,anU it isnpt.likely that the attomey inVolved, Jay Steih,was familiar with all the technical details (jfthefraud. On the oilierhahd,already in the first proceedinl;, on J3i:n.iary 30,2006, JudgeConnpr was i n v o l ~ in extensiveproducljo:nof fraud\;llent litigation records,. fo r he r ownAssigrtrtlentOrder (backdated by 3tnonths), for Denmrrer(secretly disposed/voided), andfor Ihitial Case C o n f e ~ e t ' t C e ( c ( ) r t d u c t e d of f the record).While the jUdiciary was engaging in obstructionJpetversion ofjustice, they werecolltiuuouslyinvoIved in attempts to pufblame on me. From the second' time I came toc(jurt. at leastne sheriff, sometimes t\yQ, and once - a sheriffwith a Germahshepherdwere escorting.me everywhere in the cotltt:, asafonn ofharassment.

7. Please TakeNotice: UpO;! review bv a ()()ntpetent court it is practiCallv certaIn tltatvarious QS(1!!-cJs ofthe conspiracy in Samaan vZernik, and in the (ailedTeNestatetninsadio.n that precedcditilswell. be deemed asviolation o(multfple-secuoirs o f.CJ;fortlw.Iln:d ti,e us. Penalcodes bv Ihe variOlIs c ~ c o n s p i r a t o r s t incfudingsachsectwhS where the.vibLatiohS ate countedas PreditatedActs pe tRICO- '18USC1961"1968.- - .a. Conduct that is explicitly listed as Predicated Acts per RICO:b. Rela1ing to maiffraud - 18 USC 1341


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Page7/12 December 11 , 2008C. Relating to wire fraud - 18USC 1343 ,d. Relating to financial in


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PageB/12 December 11,2008c) In such fraudulentsubpoena production and in subsequent conduct; CliL wasdeliberately and knowingly engaged inObstrtlction and PerverSion ofJustice, tofaciHtate real estate fraud by Samaan against Zeroikd) Review of records from Subpoena production, which constituted the foundation for thefraud in sham litigationofSamaan v Zemik -Specific Records

1. Real Property PurChase Agreement -falselymisrepresented as faxed by Parksto COlmtrywide on Oct25, 2004, 5:03pm.8jj. UnderwritingLefter- falsely misrepresented as faxed by Countrywide to Parkson Oct 14, 2004,. or midOctobcr20049 .iii. Samaan's loan applications - falsely misrepresented as received for the firsttime in CHL San.Rafael on October 12,2004'.

iv, Underwriting records ofthe above loanapplications - falsely misrepresentedashaving arrived in CHI., San Rafael at times indicated in fraudulent fax headerimprints, which are part of the faxlwircfraud by Samaan ll

9. Please TakeNotice: Maria McLaurin '5 fraudulent letter and declaratiorn12 filed;" L4Superior Court to assist in Sanuiall's real esto.te fraud againstZerhik, were crucial forsuccess offhe conspifacv.MariaMcLaurin's letter andde.clarationsin Sarnaanv Zemikcan be viewed at the linkbe l o w ~ with annotations. n u t ~ v e n without knowledge of the firte details, any ~ c withminimaIlevel ofunderStandingofbankingprocedures would fmd tile declarations fraudulenton their faces.

B. REQUES1'8& /)EMANDS1. .Demand:Please takeimmediate action to mitigate damages in marterspertaining 1.0

J o s e D h . Z ~ r n i k :Bank ofAmerica received frrs! notieeofthis matter in early February 2008!8 Fraooulent RealPropeny PllfChaseAgresmenf .hlfp;/Jinpropertnla.comI04-10-25-d0045,{;()Untrywide'-fraud-wnti"aet-regmipdr.9 FraudulentUndel"M"itir;JgLetter -hl:tp:lliliproberjnla.cum/04-1 Cl--26-countrtwide.fi>audulerit-uriderwriting-Ietter-s.pdf.htfp:IJinprooerinla.comI04' 1 ~ 2 6 - d r 0 4 4 - c o u n t r y w i d e - f r a u c k J n d e r w r j U n g , ! e t t e r . p d ftytgJfinprooerinla.com/()4..1Q-26:oDinion-letter-


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Page 9/12 December 11 i 20082. Demand & R e q l 1 e s t : P { ~ a s e establish the identity ofcounsel for Country/wide in matterspertaining to Jo.sephZgrnik.

Such counselmust bewiJling to cotnmunicate with me. 1 request that such counsel be anindividual who has not been involved in theracketeeringin this case, under previousconttolu f Cuunlry wide. P I ~ e n u t i f y m e who such cuunsel is. Doing su would allow immediateresolution of the dispute between JosephZernik and Bank o f America.. employing theindividuals listed above will not a\low such resolution to move forward, albeit - it i s m os tlikely a t the best interest o f BOA, Joseph Zcmik. Itrnay a l ~ o be fur Ule benefit of;ill who livein LA County. if BO A supports steps requested b y me below.

3. Demand: Pletl$e immediately withdraw the entiresubpoena production orCHL,repudiateilas fraudulent on its race, and notive ti,e court and partiesaccordingly;Although notevery single page in the subpoena production was fraudulent:, the.package as awhole was designed an d organized to deliberately mislead th e reader a1)d present thesubpoena as the true history ofSamaan's loans appIicationsand their underwriting.

4. Dt!l11imd: Please immediately withdraw tillY and a/IJJtfll.!./'S tJ!..ed in this ltUitter, which weregenerated hI' MarklMcLaurin, COL San Rafael Branch Manager, and notice ihe courtand parties accordinglv.Such papers are b a ~ e d em frauds as detailed above and in footnoted paper filed in court.

5 . D e m a n d . ~ Pleas'e wit/It/raw llnv and alloff1,OJJers filed bveR!, l i party with neitlterdesigftlItum nor Iegalstandingt from die LA SuperiorCourl'ssham litigation. designated' 'Samoan v Zerhik", andnoticep,artles and theCourtaccordinglv.Bank ofAmericaCorporatibnmustl1ot be engaged in mcketcerirtg activities whereCHLappears in Courtwith no deftnedpartydesigmttion, in sham litigation where the O f f i c ~ o f thePresiding Judge and the.Clerk o f the Court, as well as intemaland externalcounselretainedforthis matter. have all refused to answer in recent months such bask qucstiOtiS as:

a) Is Samnan v Zemik. a true case duly registered an d indexed, as required by la w for acase heard by the SuperiorCourtejfCalifornia?

b) Is Saniaan v Zernikaease listed in the Calendar ofthe Courts, as'required bylaw foraease heard by the Superior Court ofCalifomia?

c) Is there a judge.duly assigned to this case, 113 required by law for a caseheard by theSuperior Court ofCalifomia?

d) Is there a valid, entered judgment in this easel altertili:tivcly - is there no valid, enteredjudgment in this case?6. Demand: Please institute iTtletiUJUmdexterntlI review ofthis matterasreqlliredbybanking l a w ~ ' and regulations. andtllso report10 the aathoriti'e.r tegardingtlteCOnauclorindividllal$. when required to do so by law.


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Pago 10/12 December 11 2008I will fully cooperate with investigative procedures duly instituted in compliance with thela\-v.

7. Demand: Please issue to Zerhik declaratory statement. to the effect that:a) BOA will take. immediate action tomitigate damages.b) BOA will aSsunie responsibility for compensating Zemik for damages resulting froni

th e past an d present conduct o f CHt,c) BOA, in coordination with Zernik, will employ all necessary .legalll1easures to vacate

a ny a nd aU orders, decrees. judgments that appear in the record, and were purportedlyth e products o f litigation in the SuperiorC,ourt o f California,

d) BOA, in coordinationwith Zemik, will employ aU necessary .legal measures to remove,fium the records in theOffice o f LA County Registrar/Recorder th e f i ' a u d u l e n ~ GrantDeed 13fiJedthere by DavidPasternak,Officer of the Court, on behalf of the LASuperior Court.e) BOA, in coordination with Zemik, will employ all necessary legal m e a s u r ~ to:immediately return thc property commonly known as '320 South Peck Drive, BeverlyHills, 90212 to Zetnik's possession, and to compensate him for the unlawfuloccupancy ofhis property since November 2007, and any and all damages related to

the us e of the property or its condition vpon repossession.f) BO A will ente.r n t l g o t ~ a t i o n s with Zetnik inre:compensation for any inoidentaldamages andreso]utionofthedispute stemming from Samaan v Zernik.

8. Request: Pteaseloin andfullv support requests already advanced by Zernik that theJudiciary Committees ofboth House andSenate initiate in the upcomiltgSl!Sswn o r u ; s ~COngreSS urgent hearin.gs regarding: ..a) Ongoing failure o f t h e j u ( ; t i c e s y ~ t c ' m in LA C'..ounty, from the Rampart toCountrywide.b) Wide-spread pUbl1ccorrupti(}n and wide..-spreadabuse o fcivil rights in LA Cooory;c)' Actions required in attempt to restore an adequate justice syst'effi inLA Countyd) Actions required to enforce t h e B i I l o f ~ g h t s , as wel l as CommonLaw rights fo.taccess to judicial Records pe r Nixon v Warner Communications.e) Actions require4 to affect immediate release of an those w ho w er e c o nf m ne d asinnocent> but are falsely imprisoned in LACounty since before the Rampart scandal(1998).

13 Fraudulenl g ~ n t deed wasfifed on Dec 17. 2007 by David Pastemak.without ever issuingWrit of Execution or Abstra


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Page 11/12C. CONCLUSION

D e c e m ~ r 11, 2008

I h9ld th.at in due course itwould be fully recognized that Countrywide and some at the LASuperior Court were the dominamforcesin.organized crime in LA County in recent decades.Thatmuch can be gleaned even from the little evidenced in this letter. Such conditions are.inherently tied to the installment of a fraudulent case management system at the LA SuperiorCourt circa 1985, and the concomitant elimination of Books ofCourt that are public records, asrequired by law l4 . I hope that BOA recognize such{acts and take appropriate actions, as part ofits control of Countrywide,and as part of its corporate r e s p o n s i b i l i t i e s ~lhope that this disputewill be expediently concluded with efforts for the benefit of all those wholiVe in LA County, and particularlyfor t h o ~ whose basic rightS and Iiberties w ~ r e a b u s e d inre.cent decades by the court and police. With the passage oftiincsuch goal became i t n p e r a t i ~furme, since it was the onlyexplanation Jcould fmd for thisefltlrely crazed cond,uct of seniormanagemenl in C o u n l r y w i d ~ . J u t l : g ~ ~ u[lheSupenur Cuurt, anti: COUllScl from somt:: oflhc::large.st law turns in the world - that it was aU meant to bring about the release o{those who werefalsely imprisoned and were and are the weakest and most vulnerable of all.1hOpe that all issues related to Sainaan vZernikbe expediently resolved in amanner that wouldalso be hailed as a prime example f61' the contribution of one of'the.]argest corpOrations in theU.S. to the resolution ofmajor public policy problems.Sincerely,

) . ~ iJoseph Zetnik:cc:b. u.s. 'HoOse an.i:! Senate

14 The oo11usion of the urt of Judge Connorsncl CHL In the perversion and obstructi.o!1ofjustice-, the pT"Oduetipn offraUdulent trial court litigation records, the c e n t r a ~ role of the fraudulent ~ s management system and the denial ofpublicllccess to books of oourt,areall fully demonstrated In the Register of A c t i o n s ~ . w f 1 e r e J u d g e Connor prominently posted onJuly 24; 2007 a l10tedeslgnating 'CHL REALPARnES IN' INTEREST", whiJeCountrywide-even today absurdlydeims tobe 'Non-Party', At the same tii'neJudge Connor r ~ f e l T e d tbrtly daims in d;>urt - t h .CHl. wasbehinp 1hi$ i i ~ ~ O h as'C


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Page 12/12. December 11 , 2008C o m m i U e ~ s on the JQdiciary, Subcommittees on Oversight and Administration of the Cowts, Senate BankingC o m m i t t ~ . and the House Fi.nancial Services Committee, Congressman/women representing LA County. Thisletter is intended as part ofongoing requests to institute hearings on the tailed justice system ofLACounty

Senator Joseph BidenSenatorBarbara BoxerSenator Russell D FeingoldSenaforDiane FeinsteinSenator Patrick LeaheySenator Charles SchumerSenator Christopher DoddReprtlseulalive Xavit:r BeiXfTdRepresentative Howard BennanR e p r e s e n t a ~ v e J o h ~ Conyers JrRepresentative David DrierRepresentative Jane HantlanRepresentative HowardMcKeonReprescntative GraceNapolitanoR e ~ s e n t a t T v e Hilda SolisReprescntlitiveMaxine WatersRepresentative Drane WatsonRepresentativeHenry Waxman

c. Office of Federal TradeCommissionComplaint related the ~ o n d u c t ofCountrywide described below, wa


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Alexa Kim

Executed on January 9, 2009, at Santa Monica, California.

Moe Keshavarzi, Esq.Sheppard Mullin Richter & Hampton, LLP333 South Hope Street, 48th FloorLos Angeles, CA 90071-1448

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09-01-13 Samaan v Zernik (SC087400) Bank of America-moldawsky Extortionist Second Supplemental...

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