A Prayer for Judicial Reconsideration - Fraud Judicial Abuse

7/29/2019 A Prayer for Judicial Reconsideration - Fraud Judicial Abuse

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Att: Charles W. Mccoy Jr - Presiding Judge - Los Angeles Central Court - Stanley MoskCc: Governor Arnold Schwartznegger

Carmen A. Trutanich Los Angeles City AttorneyEdmund G. Brown Jr. - Attorney General

A Prayer for Judicial Reconsideration

With all due respect I believe the court made a grave error on August 26nd 2009 when itdismissed the ex-parte motion filed asking for dismissal without prejudice or to be taken offcalendar pending retention of counsel.( Evidence (1) pg 2-17). As such I believe all subsequentsanctions and actions are inappropriate

I pray for judicial discretion and reconsideration for this motion and the dismissal of the ordersdated November 30, 2009 (Ev (1), pg18-26) on the grounds that I have made multiple effortswith this court to communicate the fact that the release of information without counsel could

block the filing under False Claims Act and expose to respondent that I uncovered the newVehicle Licensing Fee fraud initiated in May of this year to replace the ACRF fee fraud stoppedonly after the filing of this case. This fraud was initiated immediately after the Governor enactedemergency legislation SBX2 10 (Oropeza) and it went into effect. This .5% fee increase of thecurrent VLF fee is an effort to offset Californias $21Billion deficit not to create another avenuefor fraud and greed for Mr Hennessay. Mr Hennessay is unaware of my knowledge of it. (SeeCurrent Fraud- 2009 on opposite page) Even to this day the court or any investigating agencycan become a victim by booking a car from either www.carrentals.com orwww.deluxerentacar.com

I further pray that the court order that a preservation order be placed on Deluxe Rent-A-Car as

their history of destroying evidence is apparent. In the forgery investigation they repeatedlyfailed to produce the original forged document submitted to my credit card company thatDetective Gipson requested. When he told them it was required for handwriting analysis theysuddenly lost the document and couldnt produce it then blamed a former employee for forging adocument that would produce no benefit for that employee. The district attorneys final statesFormer employee of Deluxe Rent A Car is being framed by her employer. PLEASE contactDetective Gipson at (310)-444-1574 for complete information that I am not privileged to. I alsorequest the same be issued for Carrentals.com as the partner in the nationwide advertisement andbooking agency for this criminal behavior and the previous fraud. (ev. (2) pg 11 )

History

I have asked the attorneys for John Hennessay three different times to remove this case offcalendar and my request have gone unanswered including the week prior to my 06/15/09appearance. On 6/15/2009 I appeared in court and attempted to have the case dismissed withoutprejudice or taken off calendar to retain counsel and to address the potential that the case wasfiled under the wrong jurisdiction. Judge Kronstadt would not allow me to speak to him withoutthe other party and I was unable to disclose the reason why. He refused saying I had plenty oftime. A date was set for 9/2/09 for case management with the case scheduled to start in Jan 5,2010. I remember clearly as I both wrote it down and put it in my phones reminder calendar. Ispoke to the clerk who said the request must be addressed Ex-Parte and to come back and file itbefore 8:30 am.


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I followed the instructions given and on 8/26/09 compiled a request including 30+ pages ofevidence and cases to support my request and appeared as told. Judge Kronstadt once againrefused to hear anything I had to say and would not look at the document and dismissed itstating that I did not have an impending court date. I in fact the court date was set for Sept 2nd.On 6/15/09 I was given a Sept 2nd Status Conference and a Jan 5th court date for the start ofthe trial. I put the dates into my cell phone and wrote it down in court when given, and was alsoconfirmed as being the same belief of opposing counsel by the filing of notice fortelephonic appearance for the Sep 2nd date on Sep.1st (ev (1), pg 27-28).3.670(g)(b) At least three court days before the appearance, notify the court and all other

parties of the partys intent to appear by telephone. If the notice is in writing, it

must be given by filing a Notice of Intent to Appear by Telephone with the court

at least three court days before the appearance by means reasonablycalculated to ensure delivery to the parties no later than the close of the nextbusiness day.

** Attorney Berkowitz violated of the rules of court - 3.670(g)(b)

I believe this to be an error of the court and as such I again request that my original motion bereviewed and the motion be granted in the interest of justice. This error wasted 3 days of timeplus money lost in filing fees gas and parking that I simply cannot afford due to my very limitedfinancial resources.(see Case # BC404167 - 2007-2009 FRAUD Airport Concession Recovery Fees)

Rule 3.714

I believe this case qualifies to be removed from calendar pending retention of

qualified counsel pursuant to Rule 3.714 for any and all of the following additional

reasons:

1) This case has impeccable merit and is relevant to our time I contend that summary judgmentcould be easily granted for the fraud charge based on the following FACTS :

a) Receipts from multiple consumers confirm that over the course of 2 years were rented carsand charged ACRF fees that are due to the LAWA at 13-27% of the rental rate.(ev (3) all)

b) Deluxe is not one of the 10 companies approved to pick their customers from LAX(ev (3) pg 7-10)

c) Deluxe has E-mailed mailers admitting to the fraud

(ev(3) pg 9-10)

d) It is a fact I rented the car, I live in California, and rented the car for the replacement of a carin the repair shop is established and rental cars companies are expressly prohibited fromcharging this and I was charged anyway

e) Deluxe committed Fraud and has now blamed an ex-employee. Detective Gipson writes.the District Attorney's final revealing this conclusion ."Former employee of Deluxe RentA Car is being framed by her employer. No evidence to indicate that defendant forged acustomer's signature. Detective Gipson has also stated .The Judge can call me atanytime (310-444-1574) (ev. (2) pg 11 )


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2) On May 20, 2009, President Obama signed into law the 2009 amendments to the Civil FalseClaims Act contained in the Fraud Enforcement and Recovery Act (FERA). The amendmentsexpand the scope of liability under the False Claims Act and give the government enhancedinvestigative powers. FERA specifies that an entity violates the False Claims Act if itknowingly and improperly avoids or decreases an obligation to pay money to the United States including an obligation based on an established duty . . . arising from the retention of anyoverpayment.

3) I intend to file a case under the applicable Whistleblower Laws of Federal, State and IRSlaws and the documentation requested could result in issues for the investigative authorities. Thisrequires a filing under seal and requires the AG to investigate within 60Days.

4) This case involves complex understanding of law and interpretations of obligation, tax, propertyunder Federal, State, IRS in regards whose jurisdiction this case falls. Also anti-trust and role ofgoverning entities of commissions also require a complex litigation approach and understandingthat I simply lack the understanding

5) I have had problems getting assistance from the agency responsible for the actions of Deluxe.Upon discovery of an internal audit it appears that the reason for the failure to truly assist me isthat this case represents the primary shortcoming and respective fallout of the LAWAs inabilityto monitor or effectively enforce the collection and management of the concession fees. It states:A control deficiency in LAWAs internal control over compliance exists. A significantdeficiency is a control deficiency that adversely affects the LAWAs ability to administer thepassenger facility charge program such that there is a more than remote likelihood thatnoncompliance . that is more than inconsequential will not be prevented or detected by theAuthoritys internal control. This Failure represents 1-2 million in lost revenue for theLAWA and is a significant failure that should have been caught by internal controls.

(ev(3) pg 1-3)

6) I am suffering from congestive heart failure on medication for this and high blood pressure. Thepressure from this case has raised my pressure and the stress of self representation is an unfairrisk to my life and undue loss of my time. My family has only had 3hrs of my time during the 5day Thanksgiving holiday and I averaged 3-4hrs of sleep per day. On the morning of 11/30/2009after having less than 2 hrs of sleep preparing for this case my blood pressure reached 162/101due to the stress of not being fully prepared to defend my case and I was feeling dizzy andunsafe to drive. I contacted the court to explain the situation but the court was unsympathetic andit is further not even noted in the docs. I have no intentions of pursuing this case unrepresentedor of giving up this case.

7) I was given ineffective council with self serving motives only later learning my attorney is thesubject of case law in APC v. Geller where the judge stated that he had a unusual much higherratio of cases filed and settled than most attorneys. The judge stated

.. Based on the record, there is an issue of whether the Geller defendants used our unfair

competition law to send out demand letters for purposes of a quick settlement. While there is

evidence that lawsuits were initiated, we note that most of the lawsuits were dismissed within

months of the complaints being filed. The number of actions initiated and then dismissed less

than one year thereafter raises an issue as to whether there was a pattern or practice of filing

complaints for settlement purposes.

(APC v. Law Offices of Geller, Stewart & Foley, LLP, 05 S.O.S. 5602)


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This became of note after questioning him about False Claims Act and cases, given incorrectinformation, and then was threatened was I will have the Judge take me off this case if youdont take this offer. I was uncomfortable with the demand that I never say anything negativeabout this company to any person in my life. I didnt accept their terms of a settlement whichhe claimed was twice the value of my case and sought qualified representation and after directlyaddressing opposing counsel we were offered 4x the amount but the issues with the terms of theagreement remained. While searching for an attorney ended up with attorneys Tom Easton andDr. John Levy of Alperian V. Vatican Bank and Levy v. CIA expressing a strong interest inmy case and agreed to send a retainer agreement once Geller was completely detached from it.

I have never received this notice as required by Rule 3.1385.

Attorney Tom Easton and Dr. John Levy of Alperian V. Vatican Bank had originally agreed totake my case but didnt want to be attached to the case with Michael Geller. I was advised thatthe filing was poorly construed, defective and potentially in the wrong venue. They wanted to besure my former counsel and co-litigant settled before we would sign retainer agreements Irequested that both Ashley and Michael Geller to inform me as soon as they completed thesettlement and I thought it was opposing counsels obligation to inform me of any change in thestatus of the case. They settled and to date I sill received no correspondence from either party.Unfortunately after 2mo. and due to the burden of the 10ys of this Vatican case and their out ofstate residence they reassessed the case and rescinded the commitment

8) The rental car industry is protected by a regulatory board due to the agreement to make thepayments on the bond issued to fund the expansion at LAX. This relationship creates specialissues regarding any activity that could potentially bar state action against the respondent as thenet effect could potentially cause the re-classification of the bond by the rating agencies. Thispublic/private association has created some sort of quazi-immunity in the state and as such this

issue needs potentially to be addressed by likely the FTC and the federal court system.

9) I believe I have been subject to abuse of process by attorney Berkowitz.

Sanctions & Abuse

I believe Attorney Berkowitz is guilty of Abuse of Process and is violating ethical standards of thebar. I did not enter this case nor wish to continue this action as a pro se litigant. This case has turnedout to be a complex litigation matter and potentially the wrong court for the action. I lack the legal

background to properly represent myself. I have asked this Beverly Hills law firm to terminate thecase without prejudice and them not to play attorney motion games since June 2009.

I have asked to dismiss this case without prejudice and have explained that I am unable to provideany answers of evidence without support of counsel. Please note that even the language on hismotion is confusing it stateson November 25th 2009 at 8:30 am, or as soon thereafter as thematter can be heard in department 30. This sounds like a request for a date not a firm date.


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It is my belief that the sanction against me is unjust - Defendants responses dated March 13th tomy interrogatories are written by Attorney Berkowitz and his firm and almost exclusively consist ofthefollowing evasive answers:

Defendant objects to this interrogatory on the grounds that the term incident is not defined,is overly broad, is vague and ambiguous, and seeks information which is not relevant nor

reasonably calculated to lead to discovery of relevant information

Defendants Request for Admissions state the following:

Defendant objects to this request on the grounds it is overly broad, is vague and ambiguous,

is unduly burdensome, is not full and complete in and of itself, in violation of Code of Civil

Procedure Section 2033.060(d), and seeks information which is not relevant nor reasonably

calculated to lead to discovery of relevant information

Please Note: This includes the questions: (ev (1) pg 40- 51)

Admit the following Evidence of Truth

that the respondent has charged ACRF fees - ev(3) pg 9-10, 12,16-22that they have never transmitted those fees to a government agency - ev(3) pg 13that they are not required to collect these fees - ev(3) pg 13that these fees were collected as extra profit - ev(3) pg 4-7that they rented cars with expired registration - ev(4) pg 1-16that it is against the law to operate a motor vehicle with expired tags ev(4) pg 1-16That they rented expired tag vehicles to persons other than plaintiffs - ev(4) pg-16

John Hennessay is a race car driver who runs a pyramid of corporations that includes Johnny Carswhich owns the 1400 cars rented by his other company Deluxe Rent-A-Car, and Johnny Park. Assuch he is in the car business and is well aware of the California vehicle laws. I wrote a letterinforming this same firm about the Illegal Fee being charged. This law firm did not advise themto cease the activity but rather advised the renaming and continuance of the fraud until my actualfiling of this case. This was then followed with the mass mailing of advertisement stating that they nolonger charge the illegal fee and is concrete proof intentional fraud by Mr. Hennessay. The obviousknowledge and the non-answers are evidence that Attorney Berkowitz is advising his client tobeing intentionally evasive

Misuse of the discovery process includes failing to respond or submit to authorizeddiscovery,providing evasive discovery responses.. [Citation.] (In re Marriage of Michaely(2007) 150 Cal.App.4th 802, 809, italics added.)

Canon 3C(5) Disciplinary ResponsibilitiesD(2) Whenever a judge has personal knowledge that a lawyer has violated any provision of the

Rules of Professional Conduct, the judge shall take appropriate corrective action.


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3.59 8) Sanctions Based on Motion for Sanctions

If a monetary sanction is authorized by any provision of this title, the court shall impose

that sanction unless the one subject to the sanction acted with substantial justification

or that other circumstances make the imposition of the sanction unjust. ( 2023.030 .The intent of the Legislature is for courts to vigorously use its sanctions authority to deterthat improper conduct or comparable conduct by others similarly situated. CCP 128.7(h).

This is an indicator and there is no Good Faith effort and no intent to answer these questionswithout dancing through the legal process. I could waste my time cutting and pasting the sameresponses but I believe this is a waste and an abuse of both my time and the courts. As such I contendthat it is improper to sanction a pro se litigant for not playing the attorney games that he is both ill-equipped to play and that waste the courts valuable time. Had I not been unnecessarily denied thedismissal without prejudice requested or leave of court, this exercise in abuse by an attorney of a non-represented party seeking leave of court for proper representation could have been avoided and I

would not be wasting the Presiding Judges valuable time today.Whenever one partys improper actions even if not willful in seeking or resisting

discovery necessitate the courts intervention in a dispute, the losing party presumptively

should pay a sanction to the prevailing party. (Fn. omitted)]; Kohan v. Cohan (1991) 229

Cal.App.3d 967, 971.) Sanctions were warranted here, as plaintiffs objection to the term

economic damages was without substantial justification and their responses to those

interrogatories were evasive. ( 2023.030, subd. (a), 2023.010, subds. (e) and (f).)

Attorney Berkowitz requested an $1850 sanction against me for what he has effectively done to me.This is unethical and is abuse of process and advantage, and a violation of my civil rights. I havemade repeated efforts to have this case not waste anyones time and my whole Thanksgiving

week was spent learning enough law to understand the few things I have been able to pick up.I pray that the court finds that sanctions are appropriate

Laborde v Aronson (2001) 92 CA4th 459, 467469, 112 CR2d 119, held that an in pro perattorney could recover attorneys fees on the basis that such an award furthers the policy ofdeterring frivolous filings. It relied on federal cases under Fed R Civ P 11 allowing attorneysfees to in pro per attorneys andAbandonato v Coldren (1995) 41 CA4th 264, 269, 48 CR2d 429,holding that in pro per attorneys could be awarded fees under CCP 128.5,

I realize I will never be able to be compensated for the irreplaceable loss of time with myfamily and children over this two year arbitrage much less this past holiday due to this, but Ipray that this matter be forwarded to the California Bar for disciplinary action. Should the court

decide that sanctions cannot or should not be awarded to me, I further request that sanctionsbe collected by the court in the amount originally requested by attorney Berkowitz with hismeritless claims to his time wasted.

Please keep in mind since the loss of my previous attorney there have been multiple courtdates that have wasted the courts valuable time since my first and subsequent requests to theattorney and court to have this case taken off calendar yet being unable to have my issues evenlooked at has ended up with me being fined $1000, now being in contempt of court, notspending time with my family, and risking my life with stress that has raised my blood pressuredespite the medication that normally keeps it in control.


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I realize I have attached an abundance of documentation but I lack the knowledge to knowwhat is appropriate and wish the court to know that despite the relative small sum of this fraud,this has been done to an estimated 1000 times per day for a documented three year period.This case is an indicator of how hard it can be for the people trying to find Justice in this socalled Justice System put in place to protect the people. Please accept the attacheddocuments as if not irrevocable proof, at least reasonable proof to cause great concern that thiscompany knowingly and intentionally conspired to defraud as many people as possible andcontinued to do so. This is despite the counsel who was informed of the crime are the sameattorneys representing them today. These attorneys were just granted $1K in sanctions againstthe victim in this case and apparently the only person in California who is actively trying to stopthis criminal behavior. Meanwhile . John Hennessey is still defrauding up to 1400 people perday only now under the guise of Californias Vehicle Licensing Fee.

VLF Fraud

Governor Schwarzenegger

John Hennessey has added insult to injury by using Governor Arnold Schwarzenegger andCalifornias fiscal crisis as the scapegoat and opportunity to once again defraud every customer itserves and then put those funds in his pocket.

http://reservations.deluxerentacar.com/policies/los-angeles-airport/

I have documented a 13.375% fee thru carrentals.com and a 16.34% fraud on thewww.deluxerentacar.com site.

The law clearly states : vehicle license fee above 0.65 percent of the value of the vehicle. Theincreased vehicle license fee shall be separately charged, clearly stated, and prorated at one-threehundred sixty-fifth of the fee increase inthe annual vehicle license fee actually paid

$1.7 billion from increasing the Vehicle License Fee (VLF) from the current rate of 0.65percent

to 1.15 percent, except for heavy vehicles. Revenue from the portion of the increase to 1 percent

will be retained by the General Fund ($121 million in 2008-09 and $1.2 billion in 2009-10) and

revenue from the additional increase of 0.15 percent will be transferred to a new special account

dedicated to funding local public safety programs ($82 million in 2008-09 and $502 million in 2009-

10). The VLF rate increase will become effective for registrations beginning May 19, 2009 and

expire June 30, 2013 The budget package also includes a bill that unbundles the VLF taxes charged

by this increase from rental car rates.


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Rental Rate $ 109.41

Coverage and Extra Charges

Car License Fee $ 27.18Sub Total $ 136.59

Taxes and Fees

SALES TAX $ 13.32

CAL TOURISM FEE $ 2.74

Free Mileage unlimited

Total Charges $ 152.65

THIS REPRESENTS : 16.34% fee added to the price of the rental very familiar to anyonereviewing the fraudulent nature of this company as it appears to be a replacement for the ACRF feepreviously charged. I have attached the other company rate fee sheets from carrentals.com In all ofthe other companys rates, some have the ACRF fees, and some indicate the allowable $10 fee ascodified under CALIFORNIA CIVIL CODE SECTION 1925-1936.5. However none of them havethe 2009 New California Car License Fee. Now while there is such a fee that has been increasedhowever

(1) Vehicle license fee has the same meaning as in Sections 10751 and 10752 of the Revenue and TaxationCode, as that fee existed on January 1, 2009.

(2) Increased vehicle license fee means the amount of the fee increase in the vehicle license fee above 0.65percent of the value of the vehicle. The increased vehicle license fee shall be separately charged, clearlystated, and prorated at one-three hundred sixty-fifth of the fee increase in the annual vehicle license feeactually paid on the particular vehicle being rented for each full or partial 24-hour rental day that thevehicle is rented. The total of all increased vehicle license fees charged to renters shall not exceed the feeincrease in the annual vehicle license fee actually paid for the particular vehicle rented.

(b) Notwithstanding subdivision (n) of Section 1936 or subdivision (b) of Section 1936.01, upon anincrease of the vehicle license fee above 0.65 percent of the value of the vehicle pursuant to legislationenacted with the Budget Act of 2009, the following provisions shall apply with respect to the increasedvehicle license fee:

(1) A rental company shall only advertise a rental rate that includes the entire amount, except taxes, the

increased vehicle license fee, a customer facility charge, if any, and a mileage charge, if any, that arenter must pay to hire or lease the vehicle for the period of time to which the rental rate applies.

(2) When providing a quote, or imposing charges for a rental, the rental company may separately statethe rental rate, taxes, the increased vehicle license fee, customer facility charge, if any, airportconcession fee, if any, tourism commission assessment, if any, and a mileage charge, if any, that arenter must pay to hire or lease the vehicle for the period of time to which the rental rate applies. Arental company may not charge in addition to the rental rate, taxes, the increased vehicle license fee,a customer facility charge, if any, airport concession fee, if any, tourism commission assessment, ifany, and a mileage charge, if any, any fee that must be paid by the renter as a condition of hiring orleasing the vehicle, such as, but not limited to, required fuel or airport surcharges other thancustomer facility charges and airport concession fees.


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Because of the presented info, I did research and discovered that there is no agency directlyregulating the rental car companies. This is perhaps why the following fraud has occurred. Im pretty

sure however that it should fall under 17200 statutes.

This is a .5% difference on the fee that is a chargeable prorated charge to the customer.

2008 Chrysler 300 Rental From Deluxe

DMV indicates based on a $25,000 car this VLF would be $163.00 but the of the % 1.10 fee only.5% is legally chargeable. This would amount to $70 and then 1/365 of that or only 19c./day or$1.35/ week. This would explain why the other companies simply choose not to charge this. Howeverwith the ACRF Fraud removed Deluxe and John Hennessy have found yet another opportunity to


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create a fraudulent revenue stream that nobody would be likely to discover. This means only $1.35 islegal of the $31.71 Car License Fee Fraud

Deluxe has overcharged this tax to every client by 2300% and committed Tax Fraud

During the investigation I notice the irregularity in the bill I overlooked with a ACRF fee. I did theinvestigation only to discover that this fee could only be charged to the 10 companies approved byLAWA. Deluxe is not one of them and had been pocketing the 11-27% they have illegally charged.Based on public records of $3-5M in receipts, this represents between $333,000 and $1.3 million /year in fraud and with a fleet of 1400 cars the number of victims is staggering. This is fullydocumented at http://www.deluxerentacar.info Deluxe has attempted to manipulate receipts withname changing and other acts to cover their trail. John Hennessy is intent on continuing his pattern ofdeceit and fraud.

Carrentals.com

Unlike the initial ACRF fraud which is a rental fee, this is a direct state tax and therefore definitelyenforceable under tax fraud statutes. Also do to the nature of this business and their relationships tocarrentals.com I believe that the nature of the site does not allow negative post and I believe thereviews on the site are fraudulent. Carrentals.com, as the number one rental booking company in theworld, should be aware of the advertisement posted and what the laws regarding the fees on its siteand is responsible for enacting checks that prevent the manipulation of the numbers to create fraud

CharacterJohn Hennessay as the person whose company defrauded me and then forged my name has

threatened to have me In court defending himself. Despite being the victim of this abusive

company and his team of attorneys, despite uncovering another ongoing fraud and having a DAwho says they are Framing an ex-employee for the forgery of my signature and the LAWAsaying they never had the right to charge the 13-27% fraud charge that I have documented tothe LAPD, DA, City Attorney, LAPD, FTC, Governor, Mayor, BBB and now this court thats whereI now find myself. - ( ev(5) pg 1 )

I recently was contacted by a former employee of Deluxe Rent A Car. ( ev(5) 2-7)

He writes of John Hennessey: No buddy, the owner is so freakin greedy , he wont give unothing, he give commission cuz as rental agent we sell insurances which I doubt he gotany , but all the rental company pays commission and if u were honest person as u

seem like it then i will stand with the truth. but there is no commission on ACRF , that

money is straight in his pocket , its suppose to be for LAX but Mr. John loves to steal andthat's why he has team of lawyers .

The reason i am with u on deluxe cuzthey ripped off 100s of customer and the greedyowner will never stop, so that's y i wanna stop him to rip off other people in the future.

About that employee forged the paper n lost it is all bullshit, employees has nothing to dealwith paper and contracts. its all there with managers and goes to corporate office.

During the investigation I notice the irregularity in the bill I overlooked with a ACRF fee. I didthe investigation only to discover that this fee could only be charged to the 10 companiesapproved by LAWA. Deluxe is not one of them and had been pocketing the 11-27% they have


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illegally charged. Based on public records of $3-5M in receipts, this represents between$333,000 and $1.3 million / year in fraud and with a fleet of 1400 cars the number of victims isstaggering. This is fully documented at http://www.deluxerentacar.info Deluxe hasattempted to manipulate receipts with name changing and other acts to cover their trail. JohnHennessy is intent on continuing his pattern of deceit and fraud.

The employee further states:

I am honest and straight forward guy and i think working in deluxe for months was therea lot. When we sell insurance the ACRF goes high and on some contracts the ACRF was over200$ and those poor international customer who came to Deluxe to get a cheaper andbetter deal the others which carrentals.com advertises would get ripped off in ACRF . I toldthe managers a few times about ACRF but even the general manager didn't do anything.

Deluxe Rent a Car eventually stopped its behavior because of the pressure exerted on them andmy impending lawsuit. This didnt stop the deceptive and false advertisement where they now

have a emailing campaign on how they a Special Agreement where they are no longerrequired to charge ACRF fees. LAWA confirms that this is a lie.

This former employee also says:

check this out another fraud, u were talkin about ACRF, now this car license Fee is thesame thing as ACRF but just the name is changed and this amount goes higher wheninternational customer or customer who buys insurance, Gps or other stuff, cuz i think itsover 25% . If u go to deluxerentacar.com and try to make reservation u will see it rightnow. plus do ur research on insurance requirement cuz the state of California do notrequires insurance for rent a car but on deluxe web site it says it is required.

The Dept of Insurance

requires that. the named applicant is trustworthy and competent to

act as its insurance agent . Deluxe lacks that requirement as indicated by the above frauds.Also employee reveals that John Hennessay routinely double charges customers insurance thatis not required. Customers who have automatic coverage by their gold cards are also chargedfor insurance never actually issued to the consumer.


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I pray that the court orders an injunction for John Hennessay to not violate 17200 withoutspecifying details as to the new fraud. This will allow him to be charged criminally for anyfuture rentals consisting of the fraud still being committed, today and in the future. As anhonest businessman this should not be a problem and will not affect his business in any way.He continues to believe that the court is powerless and that his attorneys are smarter thanthe judges and the legal system. He could then he can be criminally charged for eachsubsequent fraud against consumers after the order is in effect. This will bypass anyimmunity he may be currently protected with as the intentional commission of fraud and thecontempt of a court order will not fail the test.

If the court denies this request everyday will create another victim like Ashley and othersthat have contacted me. ( ev.(5) pg-8+ )

This case is not a simple case and issues regarding assignment of property rights,sovern immunity and private party immunity associated due to relationships is verycomplex and well beyond my ability to navigate. I intend to pursue false claims actionand have filed an IRS form 211 for its whistleblower statutes however due to thecomplexity of this fraud it is unclear if it meets the threshold required by the IRS. As aresult in the interest of justice I request a leave under all applicable statutes to correctly

file the False Claims and to review if the federal jurisdiction is the correct venue forthis action .


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Difficult Issues of LawThough the state action exemption may be "grounded in principles of federalism," a

bedrock principle of our political system, it is certainly also true that"the preservation ofthe free market and of a system of free enterprise without price fixing or cartels isessential to economic freedom."

F.T.C. v. Ticor Title Ins. Co., 504 U.S. 621, 632, 112 S.Ct. 2169, 2176, 119 L.Ed.2d 410(1992).

Because Deluxe Rent A Car and Johnny Park are part of a self-regulated industry with acommission granted control by the state there is a difficult matter of law. Deluxes fraud is notof question nor is the economic harm. The consumers right to chose is being violated basedon this fraud and may be seen on the surface as minimal. The deeper the issue at hand is theunintended immunity that allows a Fraudulent Individual the ability to scoff at the verygovernment that empowered him. This abuse is a violation of the judicial system anddiminishes public confidence in the judiciary and thereby does injury to the system of

government under law.

The litigation-spawning capabilities of state-sanctioned, anticompetitive bargains

have been prophesied and questioned. See Frank E. Easterbrook, Foreword: The Court &the Economic System, 98 Harv. L.Rev. 4, 18 (1984) ("Anticompetitive bargains embedded

in state legislation will become targets for challenge under the antitrust laws; the

deference due toward a statute that corrects 'market failures' is not due toward a statute

that creates them.").

. In California Retail Liquor Dealers Ass'n v. Midcal Aluminum, 445 U.S. 97, 100 S.Ct. 937, 63L.Ed.2d 233 (1980), the Supreme Court established a two-part test to determine whetheralleged anticompetitive conduct on the part of a private party is immunized under the stateaction immunity doctrine. First, "the challenged restraint must be 'one clearly articulatedand affirmatively expressed as state policy.' "Id. at 105, 100 S.Ct. at 943 (quoting City of

Lafayette v. Louisiana Power & Light Co., 435 U.S. 389, 410, 98 S.Ct. 1123, 1135, 55 L.Ed.2d 364(1978)). Second, "the policy must be 'actively supervised' by the State itself." Id. Application ofthis "rigorous" test ensures that Parker immunity is applied only where the "private party'santicompetitive conduct promotes state policy, rather than merely the party's individualinterests.

"Patrick v. Burget, 486 U.S. 94, 101, 108 S.Ct. 1658, 1663, 100 L.Ed.2d 83 (1988).

Several circuit and district courts have held that once a local government is determined to beimmune from antitrust liability, the same protection should be afforded to private parties actingunder its direction. Endorsing this view, the Second Circuit has held that where a private entityis engaged in cooperative conduct with a municipality and the participation of private parties


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was reasonably contemplated by the state legislature, the state need not supervise the conductfor immunity to attach.

Although the state action doctrine was conceived in the context traditional state actors, it soonbecame evident that immunity extends to qualified private parties who are authorized toimplement a states clearly expressed policy to displace competition.

Because private parties are not politically accountable in the same manner traditional politicalsubdivisions, however, an additional requirement of active supervision is imposed where thechallenged conduct exclusively involves private parties. What satisfies the active supervisionrequirement was most recently addressed in Federal Trade Commission v. Ticor Title.53

Federal Trade Commission v. Ticor Title.53 States, 471 U.S. 48, 56-57 (1985).

The Court first articulated the two-prong standard in California Retail Liquor Dealers Assn v.Midcal Aluminum, Inc., 445 U.S. 97 (1980), but denied immunity in that case because thechallenged conduct was not supervised by the state. Five years later the Court for the first timeconferred state action immunity on private parties who met the two-pronged standard. SeeSouthern Motor Carriers Rate Conference, 471 U.S. at 64. The test is designed to determinewhether a private party is acting as an instrument of the state, or whether that individual orentity is hiding behind a gauzy cloak of state involvement to pursue anticompetitive privateinterests antithetical to the antitrust laws. See Midcal, 445 U.S. at 106.

While the state action defense may shield private actors from antitrust scrutiny when theiractivities are conducted pursuant to state authority, a state may not simply provide a defenseto those who violate the Sherman Act by authorizing them to violate it, or declaring that their

action is lawful. Parker v. Brown, 317 U.S. at 351. The state must instead substitute its owncontrol of the activity for that of the market the private activity must be both authorized bythe state andsupervised by the state.

Congress intended that the plaintiffs burden in bringing an injunctive suit readjust thelitigation advantages and disadvantages more equitably for local government defendants anddeter frivolous actions. Accordingly, injunction actions under the antitrust laws are to betreated in the federal courts in the same way as other equitable actions within the districtcourts jurisdiction. Under the Federal Rules of Civil Procedure, the plaintiff must show (1)immediate or irreparable harm and (2) probable success on the merits.

In addition to protecting states, Eleventh Amendment immunity also extends to entitiescreated by state governments that operate as instrumentalities of the state. Notably, thisimmunity does not extend to protect the activities of municipalities. Nevertheless, [b]etweenarms of the state and local municipalities . . . lies a wide range of unconventional government-chartered entities that possess attributes of both political subdivisions and state agencies. Thiscreates fertile ground for the Eleventh Amendment to emerge as a shield against antitrustimmunity where state action immunity is not available. The formidable strength of EleventhAmendment immunity is a relatively recent phenomenon that began with the Supreme Courtsdecision in Seminole Tribe of Florida v. Florida. Seminole Tribe held that the Commerce Clausedoes not serve as a source for Congress to validly abrogate states sovereign immunity underthe Eleventh Amendment. Accordingly, Congress ability to trump Eleventh Amendment


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immunity is severely limited to where it acts under section five of the Fourteenth Amendmentto ensure states compliance with the Federal Constitution. . See Seminole Tribe of Florida v.Florida, 517 U

Dollar relies on Airline Car Rental v. Shreveport Airport Authority, 667 F.Supp. 303 (W.D. La.1987), to support its contention that the Commission is acting as a market regulator when itassesses concession fees. In Airline Car Rental, the airport authority imposed a fee on rental carbusinesses that transported customers from the airport to the businesses' off-site facilities. Thefee was calculated as seven percent of gross business receipts derived from the rental of cars topassengers picked up at the airport by the off-site rental car businesses. The court held the

airport authority was not a market participant because it had only created a suitablemarketplace for rental car services rather than entering the market itself. Id. at 306. Dollar'ssituation differs, however, from that of an off-site rental car business because Dollar actuallyoperates from the airport terminal itself and rents counter space and parking spaces from theCommission.


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STATE LICENSING BOARDS AND THELIMITS OF STATE ACTION IMMUNITY

by Meredyth Smith Andrus

This article presents a summary of antitrust analysis with respect to issues that affect state licensing boards.Antitrust concerns create potential problems for state licensing boards under both state and federal law. This

article addresses some of those concerns, including the types of activities likely to trigger antitrust scrutiny andwhether or not those activities would be immune from liability pursuant to the state action doctrine.

DEFINING THE PROBLEM

Licensing boards are a creation of state law. The statutes governing licensed professions frequently provide forregulation and oversight of the states licensees through appointment of members of the profession to licensingboards, often by the governor. The board is charged with ensuring that the licensees maintain high standards ofprofessionalism and quality of care to safeguard public health and safety. Boards draft regulations, disciplinelicensees and respond to consumer complaints. Typically, a board has statutory authority to sanction licenseesfor unprofessional and/or unlawful conduct, by way of reprimand, suspension or revocation of a license.

Because the majority of members of any state licensing board are usually competitors of the individuals theyregulate, agreements among board members to adopt policies that restrain trade may raise antitrust issues. See

American Socy of Mechanical Engr v. Hydrolevel Corp., 452 U.S. 937 (1982) (activity by professionalassociation, through its members, that barred a competitors product from the market violated the antitrust laws).State attorneys general need to be aware of these issues because they may be called upon to act asprosecutors, counselors, or both in responding to perceived abuses of statutory authority by licensing boards.Often, state attorneys general can resolve potential antitrust problems through an advisory opinion, or throughthe legislative and/or regulatory process, permitting a board to operate in a manner that protects the health orwelfare of the public, but without posing the antitrust risk. If a licensing board is alert to possible antitrustproblems, it can seek state authorization prior to taking action. For example, the Maryland State Board of DentalExaminers sought state authority to put restrictions on dentists advertising various practice components such asorthodontics, periodontics and prosthodontics where dentists were not certified as specialists by the Board. TheAttorney Generals opinion stated that restrictions on truthful advertising were unauthorized but, the Board waspermitted to require that dentists place disclaimers in their ads that they were not Board-certified to practice thatspecialty. See79 Op. Atty Gen. __ (Nov. 10, 1994).

Frequently, however, licensing board members are either unaware of the applicability of the antitrust laws tothem or inadequately educated to recognize the type of actions that may expose them to antitrust risk. SeeNational Socy of Profl Engr v. United States, 435 U.S. 679 (1978). Even if board members believe thatcompetition-restraining policies are necessary to ensure high professional standards, quality services or qualitypatient care, a court may find that the circumstances do not justify the restraint of trade. In FTC v. Indiana Fednof Dentists, 476 U.S. 447 (1986), the Court found that a group of conspiring dentists were not justified in refusingto release patients' x-rays requested by dental insurers for evaluating benefit claims. The opinion does suggest,however, that the concern for quality of patient care might, under some circumstances, justify a restraint of trade,but only if the defendant can demonstrate that patients have been harmed in fact.

ENFORCEMENT BACKGROUNDIn the past two decades, the Federal Trade Commission has been very active in prosecuting antitrust violations


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by professional boards, particularly those regulating the health professions. In 1988, the FTC sued theMassachusetts Board of Optometry for prohibiting truthful advertising of discounts and affiliation with commercialestablishments, as well as truthful advertising that contains testimonials or that is "sensational" or "flamboyant."See Massachusetts Board of Registration in Optometry, 110 F.T.C. 549 (1988). Other FTC consent orders have

involved the Wyoming State Board of Registration in Podiatry, 107 F.T.C. 19 (1986) (advertising); the RhodeIsland Board of Accountancy, 5 Trade Reg. Rep. (CCH) 22,308 (1986) (solicitation); and the Louisiana StateBoard of Dentistry, 106 F.T.C. 65 (1985) (advertising).

In addition, the FTC has conducted investigations, inter alia, of the Mississippi State Board of Dental Examiners,File No. 841-0213 (1984) (advertising); the Connecticut Board of Landscape Architects, File No. 851-0022(1985) (services without compensation); the Iowa State Board of Dental Examiners, File No. 842-3204 (1984)(advertising); the Wisconsin Medical Examining Board, File No. 841-0211 (1984) (antisolicitation rules); and theIdaho State Board of Optometry, File No. 851-0069 (1985) (regulations). The FTC has also commented onproposed regulations of the Virginia State Board of Dentistry (FTC Staff Letter, April 3, 1986); the Virginia Boardof Veterinary Medicine (FTC Staff Letter, April 10, 1986); and the South Carolina Boards of Pharmacy, MedicalExaminers, Nursing and Chiropractic Examiners (FTC Staff Letter, February 26, 1992).

The Justice Department has also sued state licensing boards. In United States v. Texas State Board of Pub.Accountancy, 464 F. Supp. 400 (W.D. Tex. 1978), modified, 592 F.d. 919 (5th Cir. 1979), for example, the courtheld that the state accounting board was subject to the antitrust laws when it promulgated a rule prohibitingaccountants from making competitive bids for professional services. The board's enabling statute did not expressa policy concerning competition that would permit such a rule. Promulgation of the rule, therefore, constituted anagreement among competitors that unreasonably restrained trade, and thus violated the antitrust laws.

Competitors in the market for health care services have also sued licensing and regulatory boards on antitrustgrounds. For example, the Maryland Chapter of American Massage Therapy Association brought suit against theState, the State Board of Physical Therapy Examiners and individual board members alleging, inter alia, that theBoard illegally restrained competition in the market for "massage therapy" or "therapeutic massage" byintimidating and obtaining cease and desist concessions from massage practitioners to refrain from using theterm "therapy" in advertising their services. See The Maryland Chapter of the American Massage Therapy

Association Inc. v. State of Maryland, Case No. 91309083/CE 139731 (filed November 5, 1991 in Circuit Courtfor Baltimore City) and Civil Action No. B-89-3367 (filed December 8, 1989 in United States District Court for theDistrict of Maryland). See also Parker v. Kentucky Board of Dentistry, 818 F.2d 504 (6th Cir. 1987) (dentistsuccessfully challenged the Kentucky Board of Dentistry's advertising restrictions that prohibited the use of termssuch as "orthodontics", "braces" and "brackets" in advertisements by general dentists.).

APPLICABLE LAW - STATE ACTIONDespite the history of government scrutiny and private civil litigation, most licensing boards mistakenly believethat they are entirely exempt from antitrust liability. The Supreme Court has indicated that state regulatoryagencies are not, by virtue of their status alone, immune from the antitrust laws. See, e.g., Goldfarb v. VirginiaState Bar, 421 U.S. 773 (1975). State regulatory agencies, including licensing boards, may be exempt fromantitrust laws, however, by fulfilling the requirements of the "state action immunity doctrine."

State action immunity is a doctrine created by the Supreme Court which exempts from prosecution under theantitrust laws certain activities undertaken in specific areas where the state has decided to regulate, rather thanallow the marketplace to discipline itself. Actions of the state itself are not subject to the Sherman Act. Parker v.Brown, 317 U.S. 341 (1943). The state action immunity doctrine further exempts from antitrust scrutiny thoseactivities which are undertaken in the implementation of state policy, provided that the policy is clearly articulatedand the actions are adequately supervised by the state. In California Retail Liquor Dealers Assn. v. MidcalAluminum, 445 U.S. 97 (1980), the Supreme Court set out a two-pronged test for determining whether the stateaction immunity doctrine will protect anticompetitive conduct of private parties, directed by a state regulatoryprogram. Midcalrequires that the anticompetitive actions of private parties be taken (1) pursuant to a clearlyarticulated and affirmatively expressed policy by the state to supplant competition with regulation; and (2) subjectto active state supervision.


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Even after Midcal, however, questions remained regarding how definitively "the state" had to authorizeanticompetitive conduct, the degree of supervision required and the treatment of political subdivisions.Subsequently, Hoover v. Ronwin, 466 U.S. 558 (1984), Town of Hallie v. City of Eau Claire, 471 U.S. 34 (1985),and Southern Motor Carriers Rate Conference, Inc. v. United States, 471 U.S. 48 (1985), clarified the application

of the state action doctrine to sovereign bodies, political subdivisions and private parties. In Hoover v. Ronwin,the Supreme Court made plain that only the activity of the sovereign itself -- the state's legislature or highestcourt -- is completely immune from federal antitrust laws. The following year, in Town of Hallie v. City of EauClaire, the Court considered a situation in which a municipality's anticompetitive activities were not expresslymandated by the state. The Court, using the Midcaltest, held that when the statute shows that "the legislaturecontemplated the kind of acts complained of," the first prong of the Midcaltest is met. Town of Hallie, 471 U.S. at44. This has been interpreted as a foreseeability test. See, e.g., Cine 42nd St. Theater v. Nederlander Org., 790F. 2d 1032 (2d Cir. 1986). Basically, the type of anticompetitive action under consideration must be foreseeableunder the state grant of authority governing the particular subdivision, agency or regulatory board.

The Supreme Court, reviewing a collective rate-making system, held in Southern Motor Carriers, that "a statepolicy that expressly permits, but does not compel, private anticompetitive conduct may be 'clearly articulated'within the meaning of Midcal." Southern Motor Carriers, 471 U.S. at 61. The Court also held that "if the state'sintent to establish an anticompetitive regulatory program is clear. . . the state's failure to describe theimplementation of its policy in detail will not subject the program to the restraints of the federal antitrust laws." Id.at 65. Despite the broad language of Southern Motor Carriers, however, a general unspecified grant of power bythe legislature to a state licensing board alone is insufficient to immunize the board from liability for specificanticompetitive actions. Cf. Community Communications Company v. City of Boulder, 455 U.S. 40 (1982) (statedelegation of powers to city through a "home rule" amendment to the state constitution was insufficient to exemptan ordinance enacted by the city from antitrust scrutiny under the state action doctrine). State action immunityrequires either an act by the state in its sovereign capacity or municipal action in furtherance or implementationof clearly articulated and affirmatively expressed state policy. Id.

Active supervision by the state has also been discussed by the Supreme Court. The Supreme Court recognizedthe importance of the active state supervision requirement in the situation where private parties are engaged inanticompetitive activity, because of the danger that the private parties would act to further their own interestsrather than the governmental interests of the state. See Patrick v. Burget, 486 U.S. 94 (1988). Burgetinvolved anantitrust claim brought by a physician whose hospital privileges were revoked as a result of a peer review. TheCourt held that the reviewing physicians were not immune under the state action doctrine because the statutoryscheme which established the peer review process did "not establish a state program of active supervision." Id.at 102.

It is generally agreed that, following Parker, Midcaland subsequent state action cases, state agencies, politicalsubdivisions and regulatory boards must meet the first prong of the Midcaltest, namely, clear articulation of astate policy to supplant competition with regulation. That test is met to the extent that the board is operatingwithin the parameters of its statutory authority. On the other hand, the second prong, active supervision isprobably not necessary to prove with respect to political subdivisions including regulatory boards andcommissions. See Four Ts, Inc. v. Little Rock Mun. Airport Commn, 1997-1 Trade Cas. (CCH) 71, 743 (8thCir. 1997) (municipal airport commission acted as agency of municipality and was therefore immune fromantitrust attack without need for active state supervision). There are at least two possible rationales for this.Either active state supervision is achieved by the activities of the board itself in compliance with its enablingstatute, or the board, like a political subdivision or municipality, is presumed to act in the public interest absent ashowing to the contrary. See Town of Hallie v. City of Eau Claire, 471 U.S. at 45 (1985). But seeWashingtonState Elec. Contractors Assn v. Forrest, 930 F. 2d 736, 737 (9th Cir.), cert. denied502 U.S. 969 (1991)(apprenticeship council that set and enforced minimum wage rates for apprenticeships is not a state agencybecause "(t)he council has both public and private members and the private members have their own agendawhich may or may not be responsive to state labor policy").

RECENT DEVELOPMENTSThe most recent Supreme Court case involving state action immunity, FTC v. Ticor Title Ins. Co., 504 U.S. 621(1992) is important because it raises questions about the degree of state supervision necessary to conferantitrust immunity over private anticompetitive action which might be related to or relied upon by a licensing


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board or commission. In Ticor, the Supreme Court clarified that the active supervision requirement of the Midcaltest assures that the state has exercised sufficient "independent judgment and control" to make theanticompetitive activity the product of "deliberate state intervention". Ticor, 504 U.S. at 634. In other words, themere potential for supervision is inadequate; there must be active supervision in fact. Id. at 638. The Court also

said that both elements of the Midcaltest are closely related. Both ensure that particular restraints exist as aresult of "deliberate and intended" state policy. Id. at 636. Both are necessary to ensure that the state hasapproved particular anticompetitive conduct. Thus, even if active state supervision is not necessary to conferimmunity on board members themselves (assuming the board is operating within its statutory authority), to theextent that a board seeks to rely upon anticompetitive behavior by private, non-board member actors, thoseactivities would not only have to be legislatively authorized, they would also have to pass the active supervisionprong of Midcalto immunize the private actors from potential antitrust liability. For example, some boards mayenlist the assistance of non-board member licensees to conduct inspections and/or investigations of competitors'facilities. These activities must be actively monitored and reviewed, not merely "rubber-stamped" by the board.

There are some surprising post-Ticordevelopments in the courts. Recently, the Tenth Circuit interpreted Town ofHallie, to confer immunity on private actors without imposing the "active supervision" prong of Midcal, where theprivate parties are acting without discretion and at the direction of a municipality whose immunity has beenestablished. See Zimomra v. Alamo Rent-A-Car,1997-1 Trade Cas. (CCH) 71,780 (10th Cir. 1997). TenthCircuit Judge Henry noted in his concurring opinion, the application of the "Town of Hallie test" in this case, led toan anomalous result, suggesting that the state action doctrine needs to be re-examined.

Given the uncertainty surrounding the definition and application of "active state supervision," it is prudent policyto have a licensing board's counsel involved in an advisory role with respect to certain activities undertaken bythe board that involve private actors or non-board member licensees. Certain activities, especially competitorcomplaints and disciplinary proceedings might be deemed anticompetitive and therefore the board needs tounderstand and comply with the limits of its statutory authority. This added level of state involvement shouldprovide a cushion for the board and any private, non-board member actors against possible allegations ofanticompetitive behavior. While supervision of the board is probably not necessary for state action immunity, it isstill unclear what degree of supervision of private parties would suffice under Ticor. As a general rule, the degreeof supervision required is proportional to the amount of discretion exercised by private parties.

CONCLUSIONIn summary, members of a licensing board who are practitioners in the industry they regulate may be consideredparticipants in a conspiracy to restrain trade if they adopt anticompetitive policies that are outside the scope ofthe board's authority as defined by the statute governing that profession. Under such circumstances, boardmembers may be personally liable under the antitrust laws. Even board members who are not licensed topractice (and therefore not competitors) can be held to the same degree of culpability as the licensee members.This is especially significant in states where no statutory limits have been placed on a government (or quasi-government) employees liability for antitrust violations. See, e.g., Local Government Antitrust Exemption Act, 50I1.C.S. 35-1 (E) (Illinois statute limiting antitrust liability of local government to injunctive relief). See alsoLocalGovernment Antitrust Act, 15 USC 34-36 (1984) (local governments afforded immunity from damages inantitrust litigation under federal law). Presumably, state licensing boards need not submit to active statesupervision to ensure the boards state action immunity, but the Supreme Court has yet to definitively addressthis issue. Regardless of whether the board itself requires active state supervision, any private individuals actingat the direction of the board must submit those actions to board review and approval. The current uncertaintysurrounding the limits of state action immunity as it applies to board members regulating licensed professionsargues in favor of antitrust counseling where the boards authority is debatable and where a boards actions arelikely to have an adverse impact on competitors, thereby inviting an antitrust challenge.

COPYRIGHT 2000. Rights to copy and distribute this publication are hereby granted to members of theCouncil on Licensure, Enforcement and Regulation (CLEAR), providing credit is given to CLEAR and

copies are not distributed for profit.

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