Richard S. MacNaughton, Esq. Lead Atty SBN 077258 Attorney ... · In making his March 9, 2015...

Richard S. MacNaughton, Esq. Lead Atty SBN 077258 Attorney at Law 1916 North Saint Andrews Place Hollywood, California 90068-3602 323/957-9588 * 310/273-5464 Phones 323/464-7066 * 310/274-7749 Faxes [email protected] email

Edward W. Pilot, Esq. Appearance Atty SBN 136812 EDWARD W. PILOT, A Professional Corporation 9107 Wilshire Boulevard, Suite 700 Beverly Hills, California 90210-5525 310/274-9602 Phone * 310/274-7749 Fax [email protected] Attorneys for Petitioners:

Hollywoodians Encouraging Logical Planning

LOS ANGELES COUNTY SUPERIOR COURT FOR THE STATE OF CALIFORNIA

CEQA CASE

SAVEHOLLYWOOD.ORG, et alia ) CASE # BS 138 370

) related cases BS138580, BS138369 Petitioners/Plaintiffs ) Dept G, Norwalk, Judge Torribio

vs. ) Filed: 7-18-12; Trial 9-16&17-12 )

THE CITY OF LOS ANGELES, et al) PETITIONER HOLLYWOODIANS

) ENCOURAGING LOGICAL PLAN-

Respondent/Defendants.) NING'S [HELP's] CODE OF CIVIL ) PROCEDURE, § 170.1, 170.3 DIS-

QUALIFICATION OFJUDGE JOHN AND RELATED ACTIONS TORRI BIO FOR BIAS

J AND

PREJUDICE WITH VERIFICATION

Severing itself from all other petitioners, all of who are still before the appellate

court and whose remittiturs will not issue until May 26, 2015, Petitioner Holly-

woodians Encouraging Logical Planning [HELP] brings its Verified Statement of

Disqualification of Judge John Torribio under Code of Civil Procedure, § 170.1, 170.3

due to his extreme bias and prejudices against HELP's attorney, Richard

MacNaughton.

Richard S. MacNaughton, Esq. Lead Atty SBN 077258 Attorney at Law 1916 North Saint Andrews Place Hollywood, California 90068-3602 323/957-9588 * 310/273-5464 Phones 323/464-7066 * 310/274-7749 Faxes [email protected] email

Edward W. Pilot, Esq. Appearance Atty SBN 136812 EDWARD W. PILOT, A Professional Corporation 9107 Wilshire Boulevard, Suite 700 Beverly Hills, California 90210-5525 310/274-9602 Phone * 310/274-7749 Fax [email protected] Attorneys for Petitioners:

Hollywoodians Encouraging Logical Planning

LOS ANGELES COUNTY SUPERIOR COURT FOR THE STATE OF CALIFORNIA

CEQA CASE

SAVEHOLLYWOOD.ORG, et alia ) CASE # BS 138 370

) related cases BS138580, BS138369 Petitioners/Plaintiffs ) Dept G, Norwalk, Judge Torribio

vs. ) Filed: 7-18-12; Trial 9-16&17-12 )

THE CITY OF LOS ANGELES, et al) PETITIONER HOLLYWOODIANS

) ENCOURAGING LOGICAL PLAN-

Respondent/Defendants.) NING'S [HELP's] CODE OF CIVIL ) PROCEDURE, § 170.1, 170.3 DIS-

QUALIFICATION OFJUDGE JOHN AND RELATED ACTIONS TORRI BIO FOR BIAS

J AND

PREJUDICE WITH VERIFICATION

Severing itself from all other petitioners, all of who are still before the appellate

court and whose remittiturs will not issue until May 26, 2015, Petitioner Holly-

woodians Encouraging Logical Planning [HELP] brings its Verified Statement of

Disqualification of Judge John Torribio under Code of Civil Procedure, § 170.1, 170.3

due to his extreme bias and prejudices against HELP's attorney, Richard

MacNaughton.

1 TABLE OF CONTENTS

2 HEADING PAGE

1. Overview of Disqualification 1

A. Judge Torribio's Intentional and Malicious Framing of SaveHywd's and HELP's Attorney for Monetary Penalties 1

B. Code of Civil Procedure, § 170.1 Permits a Party to Disqualify a Judge Who is Biased Against a Party or its Attorney 2

C. This Statement is Timely 3

2. C.C.P. § 170.1 Disqualification Is an Objective Standard 4

3. Related Parties in this Litigation: 5

4. Frank Angel's Breach of Fiduciary Duties, Breach of Duty of Loyalty, Violation of Rules of Professional, Rule 3-310(D) 6

5. Cover-ups Are Often Worse than the Original Crime 11

6. Judge Torribio Held a Sidebar from Which He Excluded Attorney MacNaughton When Judge Torribio and Opposing Counsel Had a Whisper Discussion about Attorney Mac Naughton's Work Product Document(s) 11

7. Judge Torribio's March 9, 2015 Order Intentionally and Maliciously Misrepresents Evidence, Conceals Material Evidence and Invents Evidence in Order to Frame Attorney MacNaughton for Misconduct in Order to Cover-up the Extreme Misconduct of Frank Angel and Judge Goodman 13

8. Due to the Great Weight Appeals Courts Give to a Trial Court's Finding of Facts, the Actual Facts in a Case Can Be Concealed and Distorted by a Trial Court Judge in Order to Make it Appear That His Order Is Supported by the Facts 14

9. Judge Torribio's Offering of Falsified Evidence as an Undisputed Fact. The 7-18-2012 Attorney Client Contract with SaveHywd

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1 TABLE OF CONTENTS

2 HEADING PAGE

1. Overview of Disqualification 1

A. Judge Torribio's Intentional and Malicious Framing of SaveHywd's and HELP's Attorney for Monetary Penalties 1

B. Code of Civil Procedure, § 170.1 Permits a Party to Disqualify a Judge Who is Biased Against a Party or its Attorney 2

C. This Statement is Timely 3

2. C.C.P. § 170.1 Disqualification Is an Objective Standard 4

3. Related Parties in this Litigation: 5

4. Frank Angel's Breach of Fiduciary Duties, Breach of Duty of Loyalty, Violation of Rules of Professional, Rule 3-310(D) 6

5. Cover-ups Are Often Worse than the Original Crime 11

6. Judge Torribio Held a Sidebar from Which He Excluded Attorney MacNaughton When Judge Torribio and Opposing Counsel Had a Whisper Discussion about Attorney Mac Naughton's Work Product Document(s) 11

7. Judge Torribio's March 9, 2015 Order Intentionally and Maliciously Misrepresents Evidence, Conceals Material Evidence and Invents Evidence in Order to Frame Attorney MacNaughton for Misconduct in Order to Cover-up the Extreme Misconduct of Frank Angel and Judge Goodman 13

8. Due to the Great Weight Appeals Courts Give to a Trial Court's Finding of Facts, the Actual Facts in a Case Can Be Concealed and Distorted by a Trial Court Judge in Order to Make it Appear That His Order Is Supported by the Facts 14

9. Judge Torribio's Offering of Falsified Evidence as an Undisputed Fact. The 7-18-2012 Attorney Client Contract with SaveHywd

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HEADINGS, continued PAGE

10. Judge Torribio Conceals Material Evidence —the August 25, 2012 Frank Angel Attorney-Client Contract with SaveHywd 18

11. Judge Torribio Conceals When Attorney MacNaughton Was Formally Retained 19

12. An Undisputed Fact which Judge Torribio's Ignores 20

13. Judge Torribio Presents Additional Facts "Which Are Not in Issue" 21

14. The Most Damaging Evidence Against Judge Torribio 22

15. The Role of Justice Paul Turner 24

16. Judge Torribio Has Not Finished with His Concealment and Manufacturing of Evidence with Respect to Robert Blue 25

17. Additional Material Misrepresentation by Omission 28

18. Frank Angel Was Fired on February 14, 2014 Due to His Outrageous Breach of Duties to SaveHywd 29

19. Summary 30

20. Conclusion 32

TABLE OF AUTHORITIES

AUTHORITY PAGES

Arizona v. Fulminante 499 U.S. 302, 309-310 (1991) 3

Datig v Dove Books (1999) 73 Cal.App.4th 964 7

///

HEADINGS, continued PAGE

10. Judge Torribio Conceals Material Evidence —the August 25, 2012 Frank Angel Attorney-Client Contract with SaveHywd 18

11. Judge Torribio Conceals When Attorney MacNaughton Was Formally Retained 19

12. An Undisputed Fact which Judge Torribio's Ignores 20

13. Judge Torribio Presents Additional Facts "Which Are Not in Issue" 21

14. The Most Damaging Evidence Against Judge Torribio 22

15. The Role of Justice Paul Turner 24

16. Judge Torribio Has Not Finished with His Concealment and Manufacturing of Evidence with Respect to Robert Blue 25

17. Additional Material Misrepresentation by Omission 28

18. Frank Angel Was Fired on February 14, 2014 Due to His Outrageous Breach of Duties to SaveHywd 29

19. Summary 30

20. Conclusion 32

TABLE OF AUTHORITIES

AUTHORITY PAGES

Arizona v. Fulminante 499 U.S. 302, 309-310 (1991) 3

Datig v Dove Books (1999) 73 Cal.App.4th 964 7

///

AUTHORITY, continued PAGES

Flatt v. Superior Court (Daniel) (1994) 9 Ca1.4th 275 8

Hickman v Taylor 329 U.S. 495 (1947) 13

In re United States (1st Cir. 1981) 666 F.2d 690 4

Pacific and Southwest Annual Conference v. Superior Court of San Diego Co. (1978) 82 Ca1.App.3rd 72 2

United Farm Workers of America v. Superior Court (Maggio, Inc.) (1985, 4th Dist) 170 Cal. App.3d 97 4

Urias v Harris (1991) 234 Cal.App.3rd 415 4

Brown Act Government Code, § 54950 et seq, 16

Public Records Act Government Code, § 6250 et seq, 16

CEQA Pub Res. Code, 21000 16

C.C.P. § 1021.5 16 Code of Civil Procedure, § 170.1 2, 4

Penal Code § 7 14

Rules of Professional Responsibility, Rule 3-310(D) 9

CACI 3114 14

The January 31, 2015 LA Times article, Us Judges See Epidemic of Prosecutorial Misconduct in State by Muara Dolan 11

AUTHORITY, continued PAGES

Flatt v. Superior Court (Daniel) (1994) 9 Ca1.4th 275 8

Hickman v Taylor 329 U.S. 495 (1947) 13

In re United States (1st Cir. 1981) 666 F.2d 690 4

Pacific and Southwest Annual Conference v. Superior Court of San Diego Co. (1978) 82 Ca1.App.3rd 72 2

United Farm Workers of America v. Superior Court (Maggio, Inc.) (1985, 4th Dist) 170 Cal. App.3d 97 4

Urias v Harris (1991) 234 Cal.App.3rd 415 4

Brown Act Government Code, § 54950 et seq, 16

Public Records Act Government Code, § 6250 et seq, 16

CEQA Pub Res. Code, 21000 16

C.C.P. § 1021.5 16 Code of Civil Procedure, § 170.1 2, 4

Penal Code § 7 14

Rules of Professional Responsibility, Rule 3-310(D) 9

CACI 3114 14

The January 31, 2015 LA Times article, Us Judges See Epidemic of Prosecutorial Misconduct in State by Muara Dolan 11

VERIFIED STATEMENT OF DISQUALIFICATION OF THE HONORABLE

JOHN TORRIBIO, JUDGE OF THE LOS ANGELES SUPERIOR COURT

1. Overview of Disqualification

A. Judge Torribio's Intentional and Malicious Framing

of SaveHywd's and HELP's Attorney for Monetary Penalties

Judge Torribio falsified evidence, manufactured evidence and concealed

material evidence in order to frame Petitioner HELP's attorney, Richard Mac aughton

[Attorney MacNaughton], for misconduct so that Judge Torribio could remove

Attorney MacNaughton from representing his client, SaveHollywood.Org, aka People

for Livable Communities, an unincorporated association, and to wrongfully levy

monetary sanctions against Attorney MacNaughton.

Since the wrongful conduct, Judge Torribio has shown extreme prejudice

against Attorney MacNaughton's other petitioner in this law, HELP. All of the other

related petitioners are still in front of the appellate court on an appeal. The only

petitioner whose remittitur has issued is HELP. Nonetheless, Judge Torribio has

solicited a Joint Status Report from all petitioners except for HELP. Judge Torribio

will not deal with another matter which HELP has had pending before his court since

the day the case was assigned to Judge Torribio, i.e. HELP's Objection to the

Respondent City's failure to File an October 2014 Return.

An attorney named Frank Angel is involved in this matter. The original judge

for these related cases was Allan Goodman and in January 2014 and again in

September 2014, Frank Angel wanted Judge Goodman to make him the attorney for

Petitioner SaveHywd in lieu of Attorney MacNaughton, but Judge Goodman declined

to do so. Judge Goodman did ignore the impropriety of Frank Angel's conduct and

allow him time to find more evidence to attack his client SaveHywd. [Exhibit #17]

Frank Angel does business with Attorney Jessica Cheng as Angel Law, an unknown

business form. Page 1 of 33

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VERIFIED STATEMENT OF DISQUALIFICATION OF THE HONORABLE

JOHN TORRIBIO, JUDGE OF THE LOS ANGELES SUPERIOR COURT

1. Overview of Disqualification

A. Judge Torribio's Intentional and Malicious Framing

of SaveHywd's and HELP's Attorney for Monetary Penalties

Judge Torribio falsified evidence, manufactured evidence and concealed

material evidence in order to frame Petitioner HELP's attorney, Richard Mac aughton

[Attorney MacNaughton], for misconduct so that Judge Torribio could remove

Attorney MacNaughton from representing his client, SaveHollywood.Org, aka People

for Livable Communities, an unincorporated association, and to wrongfully levy

monetary sanctions against Attorney MacNaughton.

Since the wrongful conduct, Judge Torribio has shown extreme prejudice

against Attorney MacNaughton's other petitioner in this law, HELP. All of the other

related petitioners are still in front of the appellate court on an appeal. The only

petitioner whose remittitur has issued is HELP. Nonetheless, Judge Torribio has

solicited a Joint Status Report from all petitioners except for HELP. Judge Torribio

will not deal with another matter which HELP has had pending before his court since

the day the case was assigned to Judge Torribio, i.e. HELP's Objection to the

Respondent City's failure to File an October 2014 Return.

An attorney named Frank Angel is involved in this matter. The original judge

for these related cases was Allan Goodman and in January 2014 and again in

September 2014, Frank Angel wanted Judge Goodman to make him the attorney for

Petitioner SaveHywd in lieu of Attorney MacNaughton, but Judge Goodman declined

to do so. Judge Goodman did ignore the impropriety of Frank Angel's conduct and

allow him time to find more evidence to attack his client SaveHywd. [Exhibit #17]

Frank Angel does business with Attorney Jessica Cheng as Angel Law, an unknown

business form. Page 1 of 33

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Judge Goodman's September 2014 statements were extremely important as they

showed that Frank Angel represented a non-party corporation and Attorney Mac

Naughton represented the petitioner SaveHywd. In making his March 9, 2015 Order,

Judge Torribio deliberately and maliciously concealed Judge Goodman's statements.

(EXHIBIT #1 is Judge John Torribio's March 9, 2015 Order)

On September 18, 2014, when Frank Angel asked to be made SaveHywd's

attorney, Judge Goodman held a hearing a few days later on September 24, 2014.

Judge Goodman declined to remove Attorney MacNaughton as SaveHywd's attorney.

Judge Torribio concealed this highly relevant statement so that the appeals court

would not see that Judge Goodman had already determined that Attorney Mac

Naughton was SaveHywd's attorney and Frank Angel represented a non-party.

EXHIBIT #2-A is the September 18, 2014 transcript and EXHIBIT #2-B is the

September 24, 2014 Judge Goodman Order.

B. Code of Civil Procedure, § 170.1 Permits a Party to Disqualify a Judge Who is Biased Against a Party or its Attorney

Code of Civil Procedure, § 170.1. (a) A judge shall be disqualified if any one or more of the following are true: ¶ (iii) A person aware of the facts might reasonably entertain a doubt that the judge would be able to be impartial. ¶ (iv) Bias or prejudice toward a lawyer in the proceeding may be grounds for disqualification.

A C.C.P., § 170.1 Disqualification Statement is not a motion, and C.C.P. §

170.3 does not set a page limit.

"Bias is defined as a mental predilection or prejudice; a leaning of the mind; a

predisposition to decide a cause or an issue in a certain way, which does not leave the

mind perfectly open to conviction." Pacific and Southwest Annual Conference v.

Superior Court of San Diego Co. (1978) 82 Cal.App.3rd 72, 76

Code of Civil Procedure, § 170.1 Statement of Disqualification Page 2 of 33

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Judge Goodman's September 2014 statements were extremely important as they

showed that Frank Angel represented a non-party corporation and Attorney Mac

Naughton represented the petitioner SaveHywd. In making his March 9, 2015 Order,

Judge Torribio deliberately and maliciously concealed Judge Goodman's statements.

(EXHIBIT #1 is Judge John Torribio's March 9, 2015 Order)

On September 18, 2014, when Frank Angel asked to be made SaveHywd's

attorney, Judge Goodman held a hearing a few days later on September 24, 2014.

Judge Goodman declined to remove Attorney MacNaughton as SaveHywd's attorney.

Judge Torribio concealed this highly relevant statement so that the appeals court

would not see that Judge Goodman had already determined that Attorney Mac

Naughton was SaveHywd's attorney and Frank Angel represented a non-party.

EXHIBIT #2-A is the September 18, 2014 transcript and EXHIBIT #2-B is the

September 24, 2014 Judge Goodman Order.

B. Code of Civil Procedure, § 170.1 Permits a Party to Disqualify a Judge Who is Biased Against a Party or its Attorney

Code of Civil Procedure, § 170.1. (a) A judge shall be disqualified if any one or more of the following are true: ¶ (iii) A person aware of the facts might reasonably entertain a doubt that the judge would be able to be impartial. ¶ (iv) Bias or prejudice toward a lawyer in the proceeding may be grounds for disqualification.

A C.C.P., § 170.1 Disqualification Statement is not a motion, and C.C.P. §

170.3 does not set a page limit.

"Bias is defined as a mental predilection or prejudice; a leaning of the mind; a

predisposition to decide a cause or an issue in a certain way, which does not leave the

mind perfectly open to conviction." Pacific and Southwest Annual Conference v.

Superior Court of San Diego Co. (1978) 82 Cal.App.3rd 72, 76


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The entire conduct of the trial from beginning to end is obviously affected by

. . . the presence on the bench of a judge who is not impartial." Arizona v. Fulminante,

499 U.S. 302, 309-310 (1991)

C. This Statement is Timely

Although Judge John Torribio's misconduct has been cumulative, recently it has

become clear that Judge Torribio's extreme bias against Attorney MacNaughton is

being visited upon his client, HELP, due to its having Attorney MacNaughton as its

attorney.

All the other related Petitioners in this multi-party litigation are not before this

trial court as their remittitur date is May 26, 2015, but HELP was remitted on February

26, 2015. The appellate court sent the Notice of Remittitur directly to the Superior

Court and HELP also filed Notice of its Remittitur with the Superior Court.

(EXHIBIT #3 is HELP's February 26, 2014 Remittitur)

Nonetheless, sometime in March or April 2015, Judge Torribio ordered the

related petitioners to submit a Joint Conference Report, but Judge Torribio excluded

HELP from that order, nor did Judge Torribio serve on HELP any copy of the orders.

Furthermore, Judge Torribio knows that HELP objected to Respondent City's

failure to file a CEQA Return in October 2014, but Judge Torribio is ignoring that

Objection.

It has been costly and extremely time consuming for HELP to prepare its

extensive verified Statement of Disqualification, but the Statement is timely since

Judge Torribio will not gain jurisdiction over any of the other petitioners until May 26,

2015. HELP's motion is timely since Judge Torribio has made no decision on any

HELP matter pending before him, except to ignore HELP, and the time for petitioners


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The entire conduct of the trial from beginning to end is obviously affected by

. . . the presence on the bench of a judge who is not impartial." Arizona v. Fulminante,

499 U.S. 302, 309-310 (1991)

C. This Statement is Timely

Although Judge John Torribio's misconduct has been cumulative, recently it has

become clear that Judge Torribio's extreme bias against Attorney MacNaughton is

being visited upon his client, HELP, due to its having Attorney MacNaughton as its

attorney.

All the other related Petitioners in this multi-party litigation are not before this

trial court as their remittitur date is May 26, 2015, but HELP was remitted on February

26, 2015. The appellate court sent the Notice of Remittitur directly to the Superior

Court and HELP also filed Notice of its Remittitur with the Superior Court.

(EXHIBIT #3 is HELP's February 26, 2014 Remittitur)

Nonetheless, sometime in March or April 2015, Judge Torribio ordered the

related petitioners to submit a Joint Conference Report, but Judge Torribio excluded

HELP from that order, nor did Judge Torribio serve on HELP any copy of the orders.

Furthermore, Judge Torribio knows that HELP objected to Respondent City's

failure to file a CEQA Return in October 2014, but Judge Torribio is ignoring that

Objection.

It has been costly and extremely time consuming for HELP to prepare its

extensive verified Statement of Disqualification, but the Statement is timely since

Judge Torribio will not gain jurisdiction over any of the other petitioners until May 26,

2015. HELP's motion is timely since Judge Torribio has made no decision on any

HELP matter pending before him, except to ignore HELP, and the time for petitioners


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to respond to The City's Final Return is several months away. Urias v Harris, (1991)

234 Cal.App.3rd 415, 424-425

2. C.C.P. § 170.1 Disqualification Is an Objective Standard

If the average reasonable person would entertain doubts about the judge's

impartiality, disqualification is required. When the public sees that a judge has

purposefully altered material facts and has intentionally concealed material facts, an

objective person would question the judge's impartiality. United Farm Workers of

America v. Superior Court (Maggio, Inc.) (1985, 4th Dist) 170 Cal. App.3d 97, 104,

216 Cal.Rptr 4

"To ensure that the proceedings appear to the public to be impartial and hence worthy of their confidence, the situation must be viewed through the eyes of the objective person." In re United States (1st Cir. 1981) 666 F.2d 690, 694

Conversely, when only issues of law are involved, there is less need to

disqualify a judge.

Various factors may impact on how the "average person on the street" views a judge's participation in a case. One court has perceptively recognized that all other things being equal, the need for disqualification decreases by the extent to which the judge's rulings in the case are limited to purely legal matters. (State of Idaho v. Freeman, supra, 507 F.Supp. at p. 728.) This is because a trial judge's factual findings are generally accorded considerable deference whereas legal rulings are subject to plenary appellate review. United Farm Workers of America, supra, 170 Cal. App.3d 97, 104-105

In this case, however, the law is not in question. Judge Torribio reveals his bias by his outrageous manipulation of evidence so that he turned the facts on their heads. The average reasonable man can read and he can see the gross and malicious


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to respond to The City's Final Return is several months away. Urias v Harris, (1991)

234 Cal.App.3rd 415, 424-425

2. C.C.P. § 170.1 Disqualification Is an Objective Standard

If the average reasonable person would entertain doubts about the judge's

impartiality, disqualification is required. When the public sees that a judge has

purposefully altered material facts and has intentionally concealed material facts, an

objective person would question the judge's impartiality. United Farm Workers of

America v. Superior Court (Maggio, Inc.) (1985, 4th Dist) 170 Cal. App.3d 97, 104,

216 Cal.Rptr 4

"To ensure that the proceedings appear to the public to be impartial and hence worthy of their confidence, the situation must be viewed through the eyes of the objective person." In re United States (1st Cir. 1981) 666 F.2d 690, 694

Conversely, when only issues of law are involved, there is less need to

disqualify a judge.

Various factors may impact on how the "average person on the street" views a judge's participation in a case. One court has perceptively recognized that all other things being equal, the need for disqualification decreases by the extent to which the judge's rulings in the case are limited to purely legal matters. (State of Idaho v. Freeman, supra, 507 F.Supp. at p. 728.) This is because a trial judge's factual findings are generally accorded considerable deference whereas legal rulings are subject to plenary appellate review. United Farm Workers of America, supra, 170 Cal. App.3d 97, 104-105

In this case, however, the law is not in question. Judge Torribio reveals his bias by his outrageous manipulation of evidence so that he turned the facts on their heads. The average reasonable man can read and he can see the gross and malicious


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manipulation of facts. As cited above, when the matters are factual, disqualification

is mandated.

3. Related Parties in this Litigation:

This case involves the June 19, 2012 Hollywood Community Plan Update. There are four (4) Petitioners in three (3) cases which were related before Judge Allan

Goodman, Department P, West District and then re-assigned to Judge John Torribio, Department G in Norwalk.

Petitioner Hollywoodians Encouraging Logical Planning, an unincorporated

association [HELP] and Petitioner SaveHollywood.Org, aka People for Livable

Communities, an unincorporated association [SaveHywd] are Petitioners in the same

Petition, with the case number BS 138370.

Petitioners HELP and SaveHywd have had the same lead attorney, Richard

MacNaughton [Attorney MacNaughton]. Attorney MacNaughton had started his work

on the Hollywood Community Plan in Spring of 2005. Petitioner SaveHywd signed

its formal written attorney-client agreement with Attorney MacNaughton on July 18,

2012 just prior to his filing the Petition. SaveHywd's governing body is called its

Legal Committee.

On August 25, 2012, Petitioner SaveHywd retained Angel Law [Frank Angel]

as a consultant to provide extra CEQA advice to Attorney MacNaughton at Attorney

MacNaughton's request. Frank Angel had no independent discretion to take any

action on behalf of SaveHywd as the 7-18-2012 contract with Attorney MacNaughton

vested in him the right to determine who may or may not speak on behalf of

SaveHywd. Frank Angel's contract with SaveHywd also acknowledged that Attorney

MacNaughton was Lead Attorney.

///


manipulation of facts. As cited above, when the matters are factual, disqualification

is mandated.

3. Related Parties in this Litigation:

This case involves the June 19, 2012 Hollywood Community Plan Update. There are four (4) Petitioners in three (3) cases which were related before Judge Allan

Goodman, Department P, West District and then re-assigned to Judge John Torribio, Department G in Norwalk.

Petitioner Hollywoodians Encouraging Logical Planning, an unincorporated

association [HELP] and Petitioner SaveHollywood.Org, aka People for Livable

Communities, an unincorporated association [SaveHywd] are Petitioners in the same

Petition, with the case number BS 138370.

Petitioners HELP and SaveHywd have had the same lead attorney, Richard

MacNaughton [Attorney MacNaughton]. Attorney MacNaughton had started his work

on the Hollywood Community Plan in Spring of 2005. Petitioner SaveHywd signed

its formal written attorney-client agreement with Attorney MacNaughton on July 18,

2012 just prior to his filing the Petition. SaveHywd's governing body is called its

Legal Committee.

On August 25, 2012, Petitioner SaveHywd retained Angel Law [Frank Angel]

as a consultant to provide extra CEQA advice to Attorney MacNaughton at Attorney

MacNaughton's request. Frank Angel had no independent discretion to take any

action on behalf of SaveHywd as the 7-18-2012 contract with Attorney MacNaughton

vested in him the right to determine who may or may not speak on behalf of

SaveHywd. Frank Angel's contract with SaveHywd also acknowledged that Attorney

MacNaughton was Lead Attorney.

///


In late October 2012, Attorney MacNaughton allowed Frank Angel to make

appearances on behalf of SaveHywd due to Attorney MacNaughton's serious illness

including cancer. Other than making appearances for SaveHywd, Frank Angel was

granted no additional authority over the litigation. The 7-18-2012 Attorney Mac

Naughton attorney-client contract with SaveHywd and the 8-25-2012 Frank Angel

attorney-client contract with SaveHywd remained unaltered. (EXHIBIT #4 is the 7-

18-2012 Attorney Client contract between Attorney MacNaughton and SaveHywd and

EXHIBIT #5 is the 8-25-2012 Attorney Client contract between Frank Angel and

SaveHywd)

4. Frank Angel's Breach of Fiduciary Duties, Breach of Duty of Loyalty, Violation of Rules of Professional, Rule 3-310(D)

In September 2013, Angel Frank wanted to become SaveHywd's attorney in

place of Attorney MacNaughton, but SaveHywd refused. The next day Frank Angel

went to a non-party, a corporation with a very similar name, savehyollywoodorg, a

501(c)(3) corporation which had been created solely to do fund-raising.

Frank Angel convinced two members of SaveHywd's Legal Committee, Fran

Reichenbach and George Abrahams, to cease to participate in the Legal Committee but

rather to pretend that the corporation was the rightful petitioner in the litigation. From

September 29, 2013 through the present Fran Reichenbach and George Abrahams

have refused to participate in SaveHywd's Legal Committee.

Starting in September 2013, SaveHywd began to object orally and in writing to

Frank Angel's undertaking representation of the corporation, but Frank Angel ignored

his client's objections.

In January 2014, Frank Angel filed a motion before Judge Allan Goodman

which ostensibly was to recuse Attorney MacNaughton as SaveHywd's attorney, but


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In late October 2012, Attorney MacNaughton allowed Frank Angel to make

appearances on behalf of SaveHywd due to Attorney MacNaughton's serious illness

including cancer. Other than making appearances for SaveHywd, Frank Angel was

granted no additional authority over the litigation. The 7-18-2012 Attorney Mac

Naughton attorney-client contract with SaveHywd and the 8-25-2012 Frank Angel

attorney-client contract with SaveHywd remained unaltered. (EXHIBIT #4 is the 7-

18-2012 Attorney Client contract between Attorney MacNaughton and SaveHywd and

EXHIBIT #5 is the 8-25-2012 Attorney Client contract between Frank Angel and

SaveHywd)

4. Frank Angel's Breach of Fiduciary Duties, Breach of Duty of Loyalty, Violation of Rules of Professional, Rule 3-310(D)

In September 2013, Angel Frank wanted to become SaveHywd's attorney in

place of Attorney MacNaughton, but SaveHywd refused. The next day Frank Angel

went to a non-party, a corporation with a very similar name, savehyollywoodorg, a

501(c)(3) corporation which had been created solely to do fund-raising.

Frank Angel convinced two members of SaveHywd's Legal Committee, Fran

Reichenbach and George Abrahams, to cease to participate in the Legal Committee but

rather to pretend that the corporation was the rightful petitioner in the litigation. From

September 29, 2013 through the present Fran Reichenbach and George Abrahams

have refused to participate in SaveHywd's Legal Committee.

Starting in September 2013, SaveHywd began to object orally and in writing to

Frank Angel's undertaking representation of the corporation, but Frank Angel ignored

his client's objections.

In January 2014, Frank Angel filed a motion before Judge Allan Goodman

which ostensibly was to recuse Attorney MacNaughton as SaveHywd's attorney, but


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upon inspection, it became clear that the structure of Frank Angel's request was to

have his client, SaveHywd, removed from the lawsuit so that the corporation could

take its place and make Frank Angel the sole attorney for the new petitioner, the

corporation savehollywoodorg.

Frank Angel had two former members of SaveHywd's Legal Committee, Fran

Reichenbach and George Abrahams, sign declarations that they had abolished the

Legal Committee and that petitioner SaveHywd did not exist but it had been

superseded by the corporation. All those representations were proven to be materially

false. A look at a few of the documents filed in January 2014 shows the extreme

lengths to which Frank Angel, Fran Reichenbach and George Abrahams went in their

attempts to perpetrate the fraud upon the court that the corporation was the real

petitioner. EXHIBIT #6 is a portion of the January 2014 Frank Angel Motions and

declarations. The entire pleadings are on file in this case.

Furthermore, Frank Angel disclosed to Judge Goodman SaveHywd's confi-

dential material including Attorney MacNaughton's Attorney Work Product on how

to structure the case before Judge Goodman. Despite SaveHywd's objections, Judge

Goodman ignored SaveHywd's protestations and read all the confidential papers

including Attorney MacNaughton's Work Product.

Judge Goodman also ignored SaveHywd's objection that as a non-party the

corporation had no standing to bring any motion in this litigation. Judge Goodman

also ignored Frank Angel's serious and intentional misrepresentations and his pre-

senting materially false declarations to the court to the effect that petitioner SaveHywd did not exist. Datig v Dove Books (1999) 73 Ca1.App.4th 964, 980- 981

The material falsehoods in Fran Reichenbach's and George Abrahams' declarations have been laboriously covered elsewhere. One example will have to suffice. In his January 14, 2014 declaration, George Abrahams stated, "There is but one SaveHollywood.Org with


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upon inspection, it became clear that the structure of Frank Angel's request was to

have his client, SaveHywd, removed from the lawsuit so that the corporation could

take its place and make Frank Angel the sole attorney for the new petitioner, the

corporation savehollywoodorg.

Frank Angel had two former members of SaveHywd's Legal Committee, Fran

Reichenbach and George Abrahams, sign declarations that they had abolished the

Legal Committee and that petitioner SaveHywd did not exist but it had been

superseded by the corporation. All those representations were proven to be materially

false. A look at a few of the documents filed in January 2014 shows the extreme

lengths to which Frank Angel, Fran Reichenbach and George Abrahams went in their

attempts to perpetrate the fraud upon the court that the corporation was the real

petitioner. EXHIBIT #6 is a portion of the January 2014 Frank Angel Motions and

declarations. The entire pleadings are on file in this case.

Furthermore, Frank Angel disclosed to Judge Goodman SaveHywd's confi-

dential material including Attorney MacNaughton's Attorney Work Product on how

to structure the case before Judge Goodman. Despite SaveHywd's objections, Judge

Goodman ignored SaveHywd's protestations and read all the confidential papers

including Attorney MacNaughton's Work Product.

Judge Goodman also ignored SaveHywd's objection that as a non-party the

corporation had no standing to bring any motion in this litigation. Judge Goodman

also ignored Frank Angel's serious and intentional misrepresentations and his pre-

senting materially false declarations to the court to the effect that petitioner SaveHywd did not exist. Datig v Dove Books (1999) 73 Ca1.App.4th 964, 980- 981

The material falsehoods in Fran Reichenbach's and George Abrahams' declarations have been laboriously covered elsewhere. One example will have to suffice. In his January 14, 2014 declaration, George Abrahams stated, "There is but one SaveHollywood.Org with


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Judge Goodman also ignored Frank Angel's breach of fiduciaries duties, his

breach of loyalty, his beach of his duty to keep his clients papers confidential and his

violation of Rule 3-310(D) and Flatt v. Superior Court (Daniel) (1994) 9 Ca1.4th

275, 36 Cal.Rptr.2d 537, all to the extreme detriment of SaveHywd's legal position

in the case and to its attorney, Richard MacNaughton.

After Frank Angel was forced to withdraw his Motion on behalf of the

corporation, SaveHywd terminated Frank Angel on February 14, 2014 by written

notice. (EXHIBIT #7 is SaveHywd's February 14, 2014 letter terminating Frank

Angel's employment)

When SaveHywd made a motion in February 2014 before Judge Goodman that

the court stop accepting pleadings from Frank Angel as he had been fired, Judge

Goodman denied the request on March 25, 2014, stating "Motion denied with

prejudice," thereby precluding SaveHywd from raising the issue again. (EXHIBIT

#8 is the March 25, 2014 Judge Goodman Order)

Three days later on March 27, 2014, Judge Goodman signed an order paving the

way for Frank Angel to collect $1 /4 Million in unearned attorney fees from

Respondent City of Los Angeles. (EXHIBIT #9 is the March 27, 2014 Judge

Goodman Order)

On September 18, 2014 at SaveHywd's hearing on its Motion to Have the City

Issue a Notice of Preparation of the New Update to the Hollywood Community Plan,

one Board of Directors and no legal committee." Abrahams' 1-16-2014 Dec. 1:26-27. This is one of several places where Reichenbach and Abrahams boldly stated under penalty of perjury that there was no Legal Committee, thereby proving that they had abandoned it. Yet, Judge Torribio conceals each and every statement and other fact proving that Reichenbach and Abrahams had constructively resigned from the Legal Committee. Judge Torribio had to make this material deception in order to frame Attorney MacNaughton for misconduct by pretending that Reichenbach and Abrahams were members of the Legal Committee.


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Judge Goodman also ignored Frank Angel's breach of fiduciaries duties, his

breach of loyalty, his beach of his duty to keep his clients papers confidential and his

violation of Rule 3-310(D) and Flatt v. Superior Court (Daniel) (1994) 9 Ca1.4th

275, 36 Cal.Rptr.2d 537, all to the extreme detriment of SaveHywd's legal position

in the case and to its attorney, Richard MacNaughton.

After Frank Angel was forced to withdraw his Motion on behalf of the

corporation, SaveHywd terminated Frank Angel on February 14, 2014 by written

notice. (EXHIBIT #7 is SaveHywd's February 14, 2014 letter terminating Frank

Angel's employment)

When SaveHywd made a motion in February 2014 before Judge Goodman that

the court stop accepting pleadings from Frank Angel as he had been fired, Judge

Goodman denied the request on March 25, 2014, stating "Motion denied with

prejudice," thereby precluding SaveHywd from raising the issue again. (EXHIBIT

#8 is the March 25, 2014 Judge Goodman Order)

Three days later on March 27, 2014, Judge Goodman signed an order paving the

way for Frank Angel to collect $1 /4 Million in unearned attorney fees from

Respondent City of Los Angeles. (EXHIBIT #9 is the March 27, 2014 Judge

Goodman Order)

On September 18, 2014 at SaveHywd's hearing on its Motion to Have the City

Issue a Notice of Preparation of the New Update to the Hollywood Community Plan,

one Board of Directors and no legal committee." Abrahams' 1-16-2014 Dec. 1:26-27. This is one of several places where Reichenbach and Abrahams boldly stated under penalty of perjury that there was no Legal Committee, thereby proving that they had abandoned it. Yet, Judge Torribio conceals each and every statement and other fact proving that Reichenbach and Abrahams had constructively resigned from the Legal Committee. Judge Torribio had to make this material deception in order to frame Attorney MacNaughton for misconduct by pretending that Reichenbach and Abrahams were members of the Legal Committee.


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Frank Angel appeared and objected saying that he was SaveHywd's attorney and

Attorney MacNaughton was not. Judge Goodman then set forth who represented

whom. (See Exhibit # 2-A 2:22-3:8)

On September 18, 2014, Judge Goodman said Attorney MacNaughton

represented the "unincorporated association" and not the corporation (Exhibit# 2-A

2:22- 3:8). Judge Goodman reference to "last time we discussed this" shows that

Attorney MacNaughton was the attorney for the unincorporated association, i.e.

Petitioner SaveHywd and that he had not been removed.

Judge Goodman also stated that Attorney MacNaughton was not the attorney

for the corporation and if the corporation had become the petitioner, then Attorney

MacNaughton had no basis to bring the motion. (Exhibit# 2-A 3:6-8)

The context made very clear that Judge Goodman was recognizing Frank Angel

as the attorney for the corporation as the proper attorney in the case, but Judge

Goodman had erroneously assumed that some how the corporation had replaced

petitioner SaveHywd. It had not. Thus, Attorney MacNaughton was still SaveHywd's

attorney and Frank Angel was not.

On September 18th, Judge Goodman was prepared to remove Attorney

MacNaughton as the attorney of record in favor of Frank Angel as attorney for the

corporation, but provided Attorney MacNaughton until September 24, 2014 to show

that he should not be removed. Exhibit 2-A 3:22-25 ("I'm going to give you until the

22nd to file a declaration from an authorized representative of SaveHollywood that

says that you still represent them.")

At no time did Judge Goodman refer to Frank Angel as the attorney for Petitioner SaveHywd, and it is clear from the context, Judge Goodman saw Frank Angel as the attorney for the corporation. Judge Goodman was entertaining Frank


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Frank Angel appeared and objected saying that he was SaveHywd's attorney and

Attorney MacNaughton was not. Judge Goodman then set forth who represented

whom. (See Exhibit # 2-A 2:22-3:8)

On September 18, 2014, Judge Goodman said Attorney MacNaughton

represented the "unincorporated association" and not the corporation (Exhibit# 2-A

2:22- 3:8). Judge Goodman reference to "last time we discussed this" shows that

Attorney MacNaughton was the attorney for the unincorporated association, i.e.

Petitioner SaveHywd and that he had not been removed.

Judge Goodman also stated that Attorney MacNaughton was not the attorney

for the corporation and if the corporation had become the petitioner, then Attorney

MacNaughton had no basis to bring the motion. (Exhibit# 2-A 3:6-8)

The context made very clear that Judge Goodman was recognizing Frank Angel

as the attorney for the corporation as the proper attorney in the case, but Judge

Goodman had erroneously assumed that some how the corporation had replaced

petitioner SaveHywd. It had not. Thus, Attorney MacNaughton was still SaveHywd's

attorney and Frank Angel was not.

On September 18th, Judge Goodman was prepared to remove Attorney

MacNaughton as the attorney of record in favor of Frank Angel as attorney for the

corporation, but provided Attorney MacNaughton until September 24, 2014 to show

that he should not be removed. Exhibit 2-A 3:22-25 ("I'm going to give you until the

22nd to file a declaration from an authorized representative of SaveHollywood that

says that you still represent them.")

At no time did Judge Goodman refer to Frank Angel as the attorney for Petitioner SaveHywd, and it is clear from the context, Judge Goodman saw Frank Angel as the attorney for the corporation. Judge Goodman was entertaining Frank


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Angel's request that he be the attorney as SaveHywd had "merged into, subsumed or

superseded by the corporation" (Exhibit #2-A, 3:4-5)

The following September 24, 2014 after considering the documents which had been filed by Frank Angel (about 120 pages) and those filed by Attorney Mac Naughton, Judge Goodman declined to remove Attorney MacNaughton as Save-Hywd's attorney of record. (See Exhibit #2-B, page 2)

Of particular importance is that among the papers which Judge Goodman reviewed for the September 24, 2014 hearing were Frank Angel's representations that SaveHywd's Legal Committee had terminated Attorney MacNaughton on July 5, 2014. The exact same allegation which Frank Angel brought before Judge Torribio

when he filed his December 8, 2014 C.C.P, § 128.7 Motion 2:16-20; Memorandum

1:2-6, 16-23, 4:15-24, 11:3-11, 11:20-12:6. Despite having these same allegations and same declarations and exhibits before him, Judge Goodman declined to remove Attorney MacNaughton as SaveHywd's attorney. Judge Torribio, however, excludes this material part of the record from his March 9, 2015 Order. 2

On December 8, 2014, Frank Angel filed a Code of Civil Procedure, §128.7

Motion before Judge John Torribio, Department G Norwalk, that Attorney Mac

Naughton should pay twenty-seven thousand six hundred dollars [$27,600.00] to

Frank Angel because Attorney MacNaughton had said he was SaveHywd's attorney.

In filing his motion on December 8, 2014, Frank Angel concealed from the

court, the September 18 and September 24, 2014 hearings before Judge Goodman.

However, Attorney MacNaughton brought the evidence to the attention of Judge

Torribio who chooses to conceal it when writing his March 9, 2015 Order.

2

Judge Torribio's bias is further shown by his saying that the words "motion denied with prejudice" on March 25, 2014 are the law of the case in order to support his removal of Attorney MacNaughton, while Judge Torribio conceals from the appeals court the evidence of the September 18 and 24 hearings and the September 24, 2014 order.


Angel's request that he be the attorney as SaveHywd had "merged into, subsumed or

superseded by the corporation" (Exhibit #2-A, 3:4-5)

The following September 24, 2014 after considering the documents which had been filed by Frank Angel (about 120 pages) and those filed by Attorney Mac Naughton, Judge Goodman declined to remove Attorney MacNaughton as Save-Hywd's attorney of record. (See Exhibit #2-B, page 2)

Of particular importance is that among the papers which Judge Goodman reviewed for the September 24, 2014 hearing were Frank Angel's representations that SaveHywd's Legal Committee had terminated Attorney MacNaughton on July 5, 2014. The exact same allegation which Frank Angel brought before Judge Torribio

when he filed his December 8, 2014 C.C.P, § 128.7 Motion 2:16-20; Memorandum

1:2-6, 16-23, 4:15-24, 11:3-11, 11:20-12:6. Despite having these same allegations and same declarations and exhibits before him, Judge Goodman declined to remove Attorney MacNaughton as SaveHywd's attorney. Judge Torribio, however, excludes this material part of the record from his March 9, 2015 Order. 2

On December 8, 2014, Frank Angel filed a Code of Civil Procedure, §128.7

Motion before Judge John Torribio, Department G Norwalk, that Attorney Mac

Naughton should pay twenty-seven thousand six hundred dollars [$27,600.00] to

Frank Angel because Attorney MacNaughton had said he was SaveHywd's attorney.

In filing his motion on December 8, 2014, Frank Angel concealed from the

court, the September 18 and September 24, 2014 hearings before Judge Goodman.

However, Attorney MacNaughton brought the evidence to the attention of Judge

Torribio who chooses to conceal it when writing his March 9, 2015 Order.

2

Judge Torribio's bias is further shown by his saying that the words "motion denied with prejudice" on March 25, 2014 are the law of the case in order to support his removal of Attorney MacNaughton, while Judge Torribio conceals from the appeals court the evidence of the September 18 and 24 hearings and the September 24, 2014 order.


5. Cover-ups Are Often Worse than the Original Crime

Perhaps the best way to describe the overall character of the sorry state of affairs

to which the Los Angeles Superior Court has sunk is an analogy to Watergate, where

the original transgression while wrongful was nothing compared to the Cover-Up

which became a national disgrace. The same pattern has replicated itself in this case.

The manner in which Judge Goodman not only covered up Frank Angel's

outrageous breach of duties to his client SaveHwyd, left the City of Los Angeles no

alternative but to pay Frank Angel $114 Million to which he was not entitled. This

misconduct is nearly insignificant compared to the extensive cover-up which has been

launched to conceal Judge Goodman's behavior within his March 25th and 28th orders.

As Judge Kozinski charged on January 28, 2015, California courts have an

epidemic of attorney misconduct because California judges look the other way. In this

case, Judge Goodman did not only look the other way, but he was also key in coercing

the City of Los Angeles to give Frank Angel $114 Million to which he was not

entitled. Judge Torribio's behavior is a significant portion of the cover-up, but he is

not alone. (The January 31, 2015 LA Times article is Exhibit #14)

6. Judge Torribio Held a Sidebar from Which He Excluded Attorney MacNaughton When Judge Torribio and Opposing Counsel Had a Whisper Discussion about Attorney Mac Naughton's Work Product Document(s)

On February 10, 2015 during the first hearing with respect to Frank Angel's

CCP § 128.7 Motion, Judge Torribio conducted a sidebar with opposing counsel,

Frank Angel, where Judge Torribio and Frank Angel had a whispered discussion about

Attorney Work Product. Although Attorney MacNaughton vigorously objected, Judge

Torribio did not allow Attorney MacNaughton to attend the sidebar nor did he allow

Attorney MacNaughton to see which specific documents he and opposing counsel


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5. Cover-ups Are Often Worse than the Original Crime

Perhaps the best way to describe the overall character of the sorry state of affairs

to which the Los Angeles Superior Court has sunk is an analogy to Watergate, where

the original transgression while wrongful was nothing compared to the Cover-Up

which became a national disgrace. The same pattern has replicated itself in this case.

The manner in which Judge Goodman not only covered up Frank Angel's

outrageous breach of duties to his client SaveHwyd, left the City of Los Angeles no

alternative but to pay Frank Angel $114 Million to which he was not entitled. This

misconduct is nearly insignificant compared to the extensive cover-up which has been

launched to conceal Judge Goodman's behavior within his March 25th and 28th orders.

As Judge Kozinski charged on January 28, 2015, California courts have an

epidemic of attorney misconduct because California judges look the other way. In this

case, Judge Goodman did not only look the other way, but he was also key in coercing

the City of Los Angeles to give Frank Angel $114 Million to which he was not

entitled. Judge Torribio's behavior is a significant portion of the cover-up, but he is

not alone. (The January 31, 2015 LA Times article is Exhibit #14)

6. Judge Torribio Held a Sidebar from Which He Excluded Attorney MacNaughton When Judge Torribio and Opposing Counsel Had a Whisper Discussion about Attorney Mac Naughton's Work Product Document(s)

On February 10, 2015 during the first hearing with respect to Frank Angel's

CCP § 128.7 Motion, Judge Torribio conducted a sidebar with opposing counsel,

Frank Angel, where Judge Torribio and Frank Angel had a whispered discussion about

Attorney Work Product. Although Attorney MacNaughton vigorously objected, Judge

Torribio did not allow Attorney MacNaughton to attend the sidebar nor did he allow

Attorney MacNaughton to see which specific documents he and opposing counsel


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were reviewing. (EXHIBIT #10 are the pertinent portions of the February 10, 2015

hearing) The salient comments related to the sidebar are:

(1) Frank Angel says he wants to show Judge Torribio something and then

makes the following statement:

He filed an affidavit of prejudice against you. There is no judge in the world -- I think, when he knocks at heaven's door, he'll refuse Jesus Christ. Feb 10, 2015 Transcript 22:2-4

After this rather bizarre statement about Attorney MacNaughton, who happens

to be Jewish, Judge Torribio allows Frank Angel to approach the bench, but he does

not permit Attorney MacNaughton to attend the sidebar.

(2) from counsel table, Attorney MacNaughton says:

It may be -- he gives attorney work product privileged to the Court freely. I don't what he's showing you. It may be more attorney work documents that he's showing to the Court. I object. Feb 10, 2014 Transcript 22:11-14

As one can tell, Attorney MacNaughton cannot see what papers Frank Angel

is showing the judge since Attorney MacNaughton is left at the counsel table;

otherwise, he'd know for certain what Frank Angel was showing Judge Torribio.

(3) Judge Torribio's response to Attorney MacNaughton's objection is:

Excuse me, Mr. MacNaughton, it was filed with his papers, so if you wanted to object, you had ample time to object. [Exhibit 10 Feb 10, 2015 Transcript 22:18-20]

Judge Torribio's "excuse me" was said with annoyance as if Attorney Mac

Naughton was being rude by complaining about the private sidebar.


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were reviewing. (EXHIBIT #10 are the pertinent portions of the February 10, 2015

hearing) The salient comments related to the sidebar are:

(1) Frank Angel says he wants to show Judge Torribio something and then

makes the following statement:

He filed an affidavit of prejudice against you. There is no judge in the world -- I think, when he knocks at heaven's door, he'll refuse Jesus Christ. Feb 10, 2015 Transcript 22:2-4

After this rather bizarre statement about Attorney MacNaughton, who happens

to be Jewish, Judge Torribio allows Frank Angel to approach the bench, but he does

not permit Attorney MacNaughton to attend the sidebar.

(2) from counsel table, Attorney MacNaughton says:

It may be -- he gives attorney work product privileged to the Court freely. I don't what he's showing you. It may be more attorney work documents that he's showing to the Court. I object. Feb 10, 2014 Transcript 22:11-14

As one can tell, Attorney MacNaughton cannot see what papers Frank Angel

is showing the judge since Attorney MacNaughton is left at the counsel table;

otherwise, he'd know for certain what Frank Angel was showing Judge Torribio.

(3) Judge Torribio's response to Attorney MacNaughton's objection is:

Excuse me, Mr. MacNaughton, it was filed with his papers, so if you wanted to object, you had ample time to object. [Exhibit 10 Feb 10, 2015 Transcript 22:18-20]

Judge Torribio's "excuse me" was said with annoyance as if Attorney Mac

Naughton was being rude by complaining about the private sidebar.


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Judge Torribio's idea that there is no need to show Attorney MacNaughton the

document because it allegedly had been provided earlier does not solve the problem.

Attorney MacNaughton had been complaining, since January 2014, that Frank Angel

was divulging Attorney MacNaughton's work product. Judge Torribio's duty was to

stop looking at the documents as soon as the Attorney Work Product Objection was

made. Hickman v Taylor 329 U.S. 495 (1947) 3 Judge Torribio's excluding Attorney

MacNaughton from his whispered sidebar with Frank Angel evidences a high degree

of bias against Attorney MacNaughton.

Judge Torribio never had Frank Angel show Attorney MacNaughton exactly

which papers they were discussing at their private sidebar. The February 10, 2015

Transcript is attached so that the entire episode can be read, except the court reporter

retained by Frank Angel does not identify the sidebar as such. From what is being

said, it is clear that Attorney MacNaughton is still at the counsel table. It is unknown

where the court reporter could hear the whispering. In any event, she only transcribed

the conversations between the bench and counsel table.

7. Judge Torribio's March 9, 2015 Order Intentionally and Maliciously Misrepresents Evidence, Conceals Material Evidence and Invents Evidence in Order to Frame Attorney MacNaughton for Misconduct in Order to Cover-up the Extreme Misconduct of Frank Angel and Judge Goodman

Judge Torribio's extensive misrepresentations, distortion of evidence and

concocting of false evidence are so blatant that they are done with malice with the

intent to harm Attorney MacNaughton by framing him for misconduct which he did

not commit.

3

An attorney's thoughts, heretofore inviolate, would not be his own. Inefficiency, unfairness, and sharp practices would inevitably develop in the giving of legal advice and in the preparation of cases for trial. The effect on the legal profession would be demoralizing. And the interests of the clients and the cause of justice would be poorly served." Hickman 329 U.S. at 511


Judge Torribio's idea that there is no need to show Attorney MacNaughton the

document because it allegedly had been provided earlier does not solve the problem.

Attorney MacNaughton had been complaining, since January 2014, that Frank Angel

was divulging Attorney MacNaughton's work product. Judge Torribio's duty was to

stop looking at the documents as soon as the Attorney Work Product Objection was

made. Hickman v Taylor 329 U.S. 495 (1947) 3 Judge Torribio's excluding Attorney

MacNaughton from his whispered sidebar with Frank Angel evidences a high degree

of bias against Attorney MacNaughton.

Judge Torribio never had Frank Angel show Attorney MacNaughton exactly

which papers they were discussing at their private sidebar. The February 10, 2015

Transcript is attached so that the entire episode can be read, except the court reporter

retained by Frank Angel does not identify the sidebar as such. From what is being

said, it is clear that Attorney MacNaughton is still at the counsel table. It is unknown

where the court reporter could hear the whispering. In any event, she only transcribed

the conversations between the bench and counsel table.

7. Judge Torribio's March 9, 2015 Order Intentionally and Maliciously Misrepresents Evidence, Conceals Material Evidence and Invents Evidence in Order to Frame Attorney MacNaughton for Misconduct in Order to Cover-up the Extreme Misconduct of Frank Angel and Judge Goodman

Judge Torribio's extensive misrepresentations, distortion of evidence and

concocting of false evidence are so blatant that they are done with malice with the

intent to harm Attorney MacNaughton by framing him for misconduct which he did

not commit.

3

An attorney's thoughts, heretofore inviolate, would not be his own. Inefficiency, unfairness, and sharp practices would inevitably develop in the giving of legal advice and in the preparation of cases for trial. The effect on the legal profession would be demoralizing. And the interests of the clients and the cause of justice would be poorly served." Hickman 329 U.S. at 511


According to California Penal Code § 7, the words "malice" and "maliciously" import a wish to vex, annoy, or injure another person, or an intent to do a wrongful act, established either by proof or presumption of law.

Under CACI 3114 "Malice" means that [name of defendant] acted with intent to cause injury or that [name of defendant]' s conduct was despicable and was done with a willful and knowing disregard of the rights or safety of another. A person acts with knowing disregard when he or she is aware of the probable dangerous consequences of his or her conduct and deliberately fails to avoid those consequences.

"Despicable conduct" is "conduct that is so mean, vile, base, or contemp-tible that it would be looked down on and despised by reasonable people." CACI 3114

A superior court judge's intentional framing an innocent attorney in order to imposition monetary sanctions against the attorney is conduct which the average citizen would find vile, base and contemptible. The average reasonable person would be more outraged to find out that a trial court's determinations of fact become the virtual truth on appeal, and that due to judicial immunity, a trial court judge may manipulate the judicial machinery in order to harm innocent people.

8. Due to the Great Weight Appeals Courts Give to a Trial Court's Finding of Facts, the Actual Facts in a Case Can Be Concealed and Distorted by a Trial Court Judge in Order to Make it Appear That His Order Is Supported by the Facts

Because of the great weight which appeals courts give to the trial court judges evaluation of evidence, it is an extremely serious matter when a trial court judge intentionally, purposefully, and maliciously alters the evidence. Whatever


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According to California Penal Code § 7, the words "malice" and "maliciously" import a wish to vex, annoy, or injure another person, or an intent to do a wrongful act, established either by proof or presumption of law.

Under CACI 3114 "Malice" means that [name of defendant] acted with intent to cause injury or that [name of defendant]' s conduct was despicable and was done with a willful and knowing disregard of the rights or safety of another. A person acts with knowing disregard when he or she is aware of the probable dangerous consequences of his or her conduct and deliberately fails to avoid those consequences.

"Despicable conduct" is "conduct that is so mean, vile, base, or contemp-tible that it would be looked down on and despised by reasonable people." CACI 3114

A superior court judge's intentional framing an innocent attorney in order to imposition monetary sanctions against the attorney is conduct which the average citizen would find vile, base and contemptible. The average reasonable person would be more outraged to find out that a trial court's determinations of fact become the virtual truth on appeal, and that due to judicial immunity, a trial court judge may manipulate the judicial machinery in order to harm innocent people.

8. Due to the Great Weight Appeals Courts Give to a Trial Court's Finding of Facts, the Actual Facts in a Case Can Be Concealed and Distorted by a Trial Court Judge in Order to Make it Appear That His Order Is Supported by the Facts

Because of the great weight which appeals courts give to the trial court judges evaluation of evidence, it is an extremely serious matter when a trial court judge intentionally, purposefully, and maliciously alters the evidence. Whatever


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a judge writes as the evidence becomes the evidence for all practical purposes. The intentional manufacturing of false evidence is never seen by an appeals court that never looks behind the scenes. When the trial court judge conceals the evidence altogether, there is no way for an appeals court to know what evidence is missing or even that the court had de facto destroyed material evidence.

Considering the great deference an appeals court gives the trial court, atrial judge stands in the same position to the appeals court as the attorney stands to the trial court judge when the attorney knowingly and maliciously presents perjured testimony and falsified evidence to the trial court. The real difference is that the trial judge has immunity and may suffer no penalty for engaging in the same maliciously fraudulent behavior as would result in the attorney's disbarment.

9. Judge Torribio's Offering of Falsified Evidence as an Undisputed Fact -- The 7-18-2012 Attorney Client Contract with SaveHywd

In his March 9, 2015 order, Judge Torribio falsified the July 18, 2012 contract where Attorney MacNaughton was officially hired to be SaveHywd's Attorney. According to Judge Torribio, SaveHywd hired Frank Angel on July 18, 2012 to be its CEQA Attorney. Judge Torribio never has to show anyone the contract. As the judge, whatever he says the facts are become the facts. Thus, the official record now states as an "Undisputed Fact" that SaveHywd hired Frank Angel and not Attorney MacNaughton. (Exhibit #1, page 2)

Judge Torribio's Undisputed Fact # 4 stated:

"July 18, 2012 the legal committee hires ALF [Frank Angel] as its CEQA attorney." (March 9, 2015 Order page 2)

Exhibit #4 is the July 18, 2012 contract, which is not between Frank Angel


a judge writes as the evidence becomes the evidence for all practical purposes. The intentional manufacturing of false evidence is never seen by an appeals court that never looks behind the scenes. When the trial court judge conceals the evidence altogether, there is no way for an appeals court to know what evidence is missing or even that the court had de facto destroyed material evidence.

Considering the great deference an appeals court gives the trial court, atrial judge stands in the same position to the appeals court as the attorney stands to the trial court judge when the attorney knowingly and maliciously presents perjured testimony and falsified evidence to the trial court. The real difference is that the trial judge has immunity and may suffer no penalty for engaging in the same maliciously fraudulent behavior as would result in the attorney's disbarment.

9. Judge Torribio's Offering of Falsified Evidence as an Undisputed Fact -- The 7-18-2012 Attorney Client Contract with SaveHywd

In his March 9, 2015 order, Judge Torribio falsified the July 18, 2012 contract where Attorney MacNaughton was officially hired to be SaveHywd's Attorney. According to Judge Torribio, SaveHywd hired Frank Angel on July 18, 2012 to be its CEQA Attorney. Judge Torribio never has to show anyone the contract. As the judge, whatever he says the facts are become the facts. Thus, the official record now states as an "Undisputed Fact" that SaveHywd hired Frank Angel and not Attorney MacNaughton. (Exhibit #1, page 2)

Judge Torribio's Undisputed Fact # 4 stated:

"July 18, 2012 the legal committee hires ALF [Frank Angel] as its CEQA attorney." (March 9, 2015 Order page 2)

Exhibit #4 is the July 18, 2012 contract, which is not between Frank Angel


and SaveHywd as Judge Torribio falsely states as his Undisputed Fact #4. If an

appeals court were to look at the 7-18-2012 contract, they would see that on July

18, 2012 the Legal Committee hired Attorney MacNaughton to be its CEQA

Attorney.

The first two paragraphs of the 7-18-2012 contract state:

This Agreement ("Agreement") is between SAVEHOLLY-WOOD.ORG aka People for Livable Communities (Client) on the one hand, and Richard S. MacNaughton, Esq. (Attorney), on the other, for legal services with respect to the litigation concerning the Hollywood Community Plan (The Plan). Client recognizes that there will be a co-Petitioner-Complainant, Hollywoodians Encouraging Logical Planning (HELP)

10. Services to Be Provided. The legal services to be provided by Attorney to Clients are as follows drafting, filing, and litigating the lawsuit against the City of Los Angeles, The City Council, and The City Attorney Office and others over The Plan including but not limited to causes of action under The Brown Act Government Code, § 54950 et seq, under Public Records Act Government Code, § 6250 et seq, and under CEQA Pub Res. Code, 21000 (C.C.P. § 1021.5) and all ancillary work incident thereto

Judge Torribio de facto removes Attorney MacNaughton from the 7-18-

2012 contract which expressly retains Attorney MacNaughton as its CEQA

attorney and he de facto inserts Frank Angel's name into the contract. Judge

Torribio conceals the actual contract from the appeals court. Because Judge

Torribio had both of the attorney client contracts before him and because he also

falsifies the statements in Sieglinde (Ziggy) Kruse's Declaration, Judge

Torribio's Undisputed Fact #4 is not only false, but it is knowingly and

maliciously false.


and SaveHywd as Judge Torribio falsely states as his Undisputed Fact #4. If an

appeals court were to look at the 7-18-2012 contract, they would see that on July

18, 2012 the Legal Committee hired Attorney MacNaughton to be its CEQA

Attorney.

The first two paragraphs of the 7-18-2012 contract state:

This Agreement ("Agreement") is between SAVEHOLLY-WOOD.ORG aka People for Livable Communities (Client) on the one hand, and Richard S. MacNaughton, Esq. (Attorney), on the other, for legal services with respect to the litigation concerning the Hollywood Community Plan (The Plan). Client recognizes that there will be a co-Petitioner-Complainant, Hollywoodians Encouraging Logical Planning (HELP)

10. Services to Be Provided. The legal services to be provided by Attorney to Clients are as follows drafting, filing, and litigating the lawsuit against the City of Los Angeles, The City Council, and The City Attorney Office and others over The Plan including but not limited to causes of action under The Brown Act Government Code, § 54950 et seq, under Public Records Act Government Code, § 6250 et seq, and under CEQA Pub Res. Code, 21000 (C.C.P. § 1021.5) and all ancillary work incident thereto

Judge Torribio de facto removes Attorney MacNaughton from the 7-18-

2012 contract which expressly retains Attorney MacNaughton as its CEQA

attorney and he de facto inserts Frank Angel's name into the contract. Judge

Torribio conceals the actual contract from the appeals court. Because Judge

Torribio had both of the attorney client contracts before him and because he also

falsifies the statements in Sieglinde (Ziggy) Kruse's Declaration, Judge

Torribio's Undisputed Fact #4 is not only false, but it is knowingly and

maliciously false.


Judge Torribio's adulteration of the facts is highly prejudicial to Attorney MacNaughton as it falsely states that SaveHywd had retained Frank Angel to be its CEQA counsel. The reality is that at no time did SaveHywd retain Frank Angel to be its CEQA attorney. Judge Torribio's false Undisputed Fact #4 is an intentional invention of Judge Torribio as he needs this undisputed facts in order to frame Attorney MacNaughton for misconduct in order to support Judge Torribio's removal of Attorney MacNaughton as SaveHywd's attorney.

Paragraph #3 of the 7-18-2012 contract contains an important provision vesting in Attorney MacNaughton the right to determine who speaks for Save-Hywd as to the litigation.

Client agrees that Attorney shall be the sole spokesperson for anything to do with litigation but Attorney in his discretion may authorize certain members of Client to also make public statements about the litigation and Attorney may that other attorneys who have been retained by Client to also speak on Client's behalf in private and/or in public.

As Judge Torribio knew from the evidence before him, starting in Septem-ber

2013, Attorney MacNaughton had directed Frank Angel to cease making any

statements on behalf of SaveHywd, but Frank Angel ignored Attorney Mac

Naughton's express instructions and went so far as to file a motion to have Attorney

MacNaughton removed and to remove SaveHywd as petitioner from its own lawsuit.

(September and October 2013 pleadings are in the file)

Judge Torribio, like Judge Goodman, remains silent about Frank Angel's breach

of duty of loyalty, about Frank Angel's breach of his fiduciary duties, about his duty

to not to disclose his client's confidential information and about Frank Angel's

disclosing Attorney MacNaughton's work product. As was shown above, Judge

Torribio did not need to read the file to know that Frank Angel was disclosing attorney

work product information since Judge Torribio held the sidebar without Attorney


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Judge Torribio's adulteration of the facts is highly prejudicial to Attorney MacNaughton as it falsely states that SaveHywd had retained Frank Angel to be its CEQA counsel. The reality is that at no time did SaveHywd retain Frank Angel to be its CEQA attorney. Judge Torribio's false Undisputed Fact #4 is an intentional invention of Judge Torribio as he needs this undisputed facts in order to frame Attorney MacNaughton for misconduct in order to support Judge Torribio's removal of Attorney MacNaughton as SaveHywd's attorney.

Paragraph #3 of the 7-18-2012 contract contains an important provision vesting in Attorney MacNaughton the right to determine who speaks for Save-Hywd as to the litigation.

Client agrees that Attorney shall be the sole spokesperson for anything to do with litigation but Attorney in his discretion may authorize certain members of Client to also make public statements about the litigation and Attorney may that other attorneys who have been retained by Client to also speak on Client's behalf in private and/or in public.

As Judge Torribio knew from the evidence before him, starting in Septem-ber

2013, Attorney MacNaughton had directed Frank Angel to cease making any

statements on behalf of SaveHywd, but Frank Angel ignored Attorney Mac

Naughton's express instructions and went so far as to file a motion to have Attorney

MacNaughton removed and to remove SaveHywd as petitioner from its own lawsuit.

(September and October 2013 pleadings are in the file)

Judge Torribio, like Judge Goodman, remains silent about Frank Angel's breach

of duty of loyalty, about Frank Angel's breach of his fiduciary duties, about his duty

to not to disclose his client's confidential information and about Frank Angel's

disclosing Attorney MacNaughton's work product. As was shown above, Judge

Torribio did not need to read the file to know that Frank Angel was disclosing attorney

work product information since Judge Torribio held the sidebar without Attorney


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1 MacNaughton where Judge Torribio and Frank Angel had a whispered discussion

about Attorney MacNaughton's work product.

If Frank Angel had been retained under the 7-18-2012 contract, then he would

have been in the position to make these decisions. Thus, with his de facto falsification

of the 7-18-2012 contract, Judge Torribio is cleansing himself of his reviewing of

Attorney MacNaughton's attorney work product at a sidebar.

10. Judge Torribio Conceals Material Evidence — the August 25, 2012 Frank Angel Attorney-Client Contract with SaveHywd

In his recitals of Undisputed Facts, Judge Torribio conceals from the appeals

court, the actual contract which Frank Angel had with SaveHywd. Judge Torribio had

a copy of this contract before him.

The Frank Angel August 25, 2012 contract [Exhibit #5] has these words, which

directly rebut Judge Torribio's false Undisputed Fact #4.

At this time, ANGEL LAW's services consist of consulting with, and assisting, Mr. MacNaughton in reviewing, revising, editing, or drafting legal arguments for any filings in the Lawsuit, as Mr. MacNaughton may from time to time request of ANGEL LAW. Exhibit #5

The August 25, 2012 contract also states:

SAVEHOLLYWOOD.ORG may wish, in the future, that ANGEL LAW appear as associate counsel of record in the Lawsuit. If so, we may negotiate and agree upon a mutually acceptable, written amendment to this Agreement. Exhibit #5

This Agreement does not provide for representation in any future administrative proceedings, or other court proceedings, including Court


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1 MacNaughton where Judge Torribio and Frank Angel had a whispered discussion

about Attorney MacNaughton's work product.

If Frank Angel had been retained under the 7-18-2012 contract, then he would

have been in the position to make these decisions. Thus, with his de facto falsification

of the 7-18-2012 contract, Judge Torribio is cleansing himself of his reviewing of

Attorney MacNaughton's attorney work product at a sidebar.

10. Judge Torribio Conceals Material Evidence — the August 25, 2012 Frank Angel Attorney-Client Contract with SaveHywd

In his recitals of Undisputed Facts, Judge Torribio conceals from the appeals

court, the actual contract which Frank Angel had with SaveHywd. Judge Torribio had

a copy of this contract before him.

The Frank Angel August 25, 2012 contract [Exhibit #5] has these words, which

directly rebut Judge Torribio's false Undisputed Fact #4.

At this time, ANGEL LAW's services consist of consulting with, and assisting, Mr. MacNaughton in reviewing, revising, editing, or drafting legal arguments for any filings in the Lawsuit, as Mr. MacNaughton may from time to time request of ANGEL LAW. Exhibit #5

The August 25, 2012 contract also states:

SAVEHOLLYWOOD.ORG may wish, in the future, that ANGEL LAW appear as associate counsel of record in the Lawsuit. If so, we may negotiate and agree upon a mutually acceptable, written amendment to this Agreement. Exhibit #5

This Agreement does not provide for representation in any future administrative proceedings, or other court proceedings, including Court


of Appeal proceedings concerning any trial court order or judgment in the Lawsuit. For such legal representation, SAVEHOLLYWOOD.ORG and ANGEL LAW must sign a new or a written amendment to this Agreement. Exhibit #5

If the Lawsuit concludes by a court decision at least partially favorable to SAVEHOLLYWOOD.ORG or if there is a settlement, and ANGEL LAW has become associate counsel of record in the Lawsuit (Richard MacNaughton being lead counsel of record), ANGEL LAW may file a motion for an award against the City (and any possible intervenor) of all fees and out-of-pocket expenses incurred by ANGEL LAW. Exhibit #5

Judge Torribio needed to hide the existence of the August 25, 2012 contract

because it revealed his Undisputed Fact #4 to be a fraud, i.e. manufactured for the

purpose to materially deceive. Attorneys who intentionally conceal material evidence

from the trial court may be disbarred, but trial court judges who similarly mislead the

appeals court suffer no penalty.

The terms of the August 25, 2012 contract make clear that Attorney Mac

Naughton is the lead attorney and that Frank Angel was not retained to be Save-

Hywd' s CEQA attorney, but rather he was hired as a consultant to operate under

Attorney MacNaughton's directions.

Judge Torribio's false Undisputed Fact #4 is sufficient to show his extreme bias

against Attorney MacNaughton, but Judge Torribio's March 9, 2015 Order had

additional materially altered facts and omissions which cannot be overlooked.

11. Judge Torribio Conceals When Attorney MacNaughton Was Formally Retained

As Undisputed Fact #2 Judge Torribo states:

"MacNaughton is the attorney for SH.ORG [SaveHywd]"


of Appeal proceedings concerning any trial court order or judgment in the Lawsuit. For such legal representation, SAVEHOLLYWOOD.ORG and ANGEL LAW must sign a new or a written amendment to this Agreement. Exhibit #5

If the Lawsuit concludes by a court decision at least partially favorable to SAVEHOLLYWOOD.ORG or if there is a settlement, and ANGEL LAW has become associate counsel of record in the Lawsuit (Richard MacNaughton being lead counsel of record), ANGEL LAW may file a motion for an award against the City (and any possible intervenor) of all fees and out-of-pocket expenses incurred by ANGEL LAW. Exhibit #5

Judge Torribio needed to hide the existence of the August 25, 2012 contract

because it revealed his Undisputed Fact #4 to be a fraud, i.e. manufactured for the

purpose to materially deceive. Attorneys who intentionally conceal material evidence

from the trial court may be disbarred, but trial court judges who similarly mislead the

appeals court suffer no penalty.

The terms of the August 25, 2012 contract make clear that Attorney Mac

Naughton is the lead attorney and that Frank Angel was not retained to be Save-

Hywd' s CEQA attorney, but rather he was hired as a consultant to operate under

Attorney MacNaughton's directions.

Judge Torribio's false Undisputed Fact #4 is sufficient to show his extreme bias

against Attorney MacNaughton, but Judge Torribio's March 9, 2015 Order had

additional materially altered facts and omissions which cannot be overlooked.

11. Judge Torribio Conceals When Attorney MacNaughton Was Formally Retained

As Undisputed Fact #2 Judge Torribo states:

"MacNaughton is the attorney for SH.ORG [SaveHywd]"


By relegating Attorney MacNaughton's retention to some time in the past with

no written contract and no specification of duties, Judge Torribio evades the likely

question, "How did Attorney MacNaughton become involved?"

The purpose of attributing Attorney MacNaughton's retention to the past is to

allow Judge Torribio to mislead others to believe that while Attorney MacNaughton

may have been an attorney, he was never the CEQA Attorney. When anyone begins

a representation, he may not conceal the most important part of the scenario, e.g.

Attorney MacNaughton was formally retained on 7-18-2012 to be SaveHywd's CEQA

attorney. Also, Attorney MacNaughton had worked on the Hollywood Community

Plan Update since 2005 and had done all the administrative work and all the legal

work on the case, except for court appearances due to cancer.

12. An Undisputed Fact which Judge Torribio's Ignores

As his Undisputed Fact # 5, Judge Torribio states:

"5, On August 29, 2012 a corporation was formed named SAVE- HOLLYWOODORG. No dot. ¶ This corporation's sole purpose was fundraising. The SH.ORG's [SaveHywd's] legal committee continued."

Undisputed Fact #5 shows that Judge Torribio is aware of the two entities:

petitioner SaveHwyd and the non-party corporation. Yet, Judge Torribio conceals the

extensive misconduct of Frank Angel's representation of the corporation from

September 2013 into February 2014. Judge Torribio's March 9, 2015 Order has to

cover-up Frank Angel's extensive outrageous violations of his ethical duties to his

client SaveHywd as Judge Torribio has to cover-up Judge Goodman' s prior concealing

of the misbehavior in order to coerce the City of Los Angeles to pay Frank Angel $114

Million. That is the nature of judicial misbehavior. What may start as an insignificant

break-in to the Democrat National Committee Headquarters can grow into a cancer on

the Presidency or a cancer on the California judicial system.


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By relegating Attorney MacNaughton's retention to some time in the past with

no written contract and no specification of duties, Judge Torribio evades the likely

question, "How did Attorney MacNaughton become involved?"

The purpose of attributing Attorney MacNaughton's retention to the past is to

allow Judge Torribio to mislead others to believe that while Attorney MacNaughton

may have been an attorney, he was never the CEQA Attorney. When anyone begins

a representation, he may not conceal the most important part of the scenario, e.g.

Attorney MacNaughton was formally retained on 7-18-2012 to be SaveHywd's CEQA

attorney. Also, Attorney MacNaughton had worked on the Hollywood Community

Plan Update since 2005 and had done all the administrative work and all the legal

work on the case, except for court appearances due to cancer.

12. An Undisputed Fact which Judge Torribio's Ignores

As his Undisputed Fact # 5, Judge Torribio states:

"5, On August 29, 2012 a corporation was formed named SAVE- HOLLYWOODORG. No dot. ¶ This corporation's sole purpose was fundraising. The SH.ORG's [SaveHywd's] legal committee continued."

Undisputed Fact #5 shows that Judge Torribio is aware of the two entities:

petitioner SaveHwyd and the non-party corporation. Yet, Judge Torribio conceals the

extensive misconduct of Frank Angel's representation of the corporation from

September 2013 into February 2014. Judge Torribio's March 9, 2015 Order has to

cover-up Frank Angel's extensive outrageous violations of his ethical duties to his

client SaveHywd as Judge Torribio has to cover-up Judge Goodman' s prior concealing

of the misbehavior in order to coerce the City of Los Angeles to pay Frank Angel $114

Million. That is the nature of judicial misbehavior. What may start as an insignificant

break-in to the Democrat National Committee Headquarters can grow into a cancer on

the Presidency or a cancer on the California judicial system.


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13. Judge Torribio Presents Additional Facts "Which Are Not in Issue"

5-A. Non Issue #1: Judge Torribio states:

1. MAC [Attorney MacNaughton] asserted that Abrahams and Reichenbach constructively resigned form the SH.ORG's [SaveHywd's] legal committee in February 2012 ¶ This is disputed by Abrahams and Reichenbach. Abraham declaration, paragraph 6. Reichenbach declaration Paragraph 3, exhibits 1 and 2

This purported fact is false. Attorney MacNaughton asserted that Abrahams and

Reichenbach constructively resigned and abandoned SaveHywd's Legal Committee

starting in September 2013, not February 2012. Also, Judge Torribio's allusion to

declarations and exhibits is meaningless as he never identified which declaration or

exhibits as Fran Reichenbach and George Abrahams had submitted hundreds of pages

of declarations and exhibits. Citing a declaration or exhibit gives the false impression

that the alleged fact has evidentiary support.

This false fact can serve one purpose. It misleads the appeals court about the

constructive resignation and abandonment in September 2013 in order to conceal

Frank Angel's breach of duties to his client.

The evidence that Fran Reichenbach and George Abrahams constructively

resigned and abandoned the Legal Committee is overwhelming. By intentionally

misrepresenting the date, Judge Torribio creates more confusion than an appellate

court could hope to unravel.

SaveHywd submitted hundreds of Bates stamped pages from the prior pleadings

to facilitate Judge Torribio's task in considering Frank Angel's C.C.P., § 128.7

Motion, but Judge Torribio has ignored these documents. This verified statement of

disqualification is already lengthy. Whoever reads and considers the disqualification


13. Judge Torribio Presents Additional Facts "Which Are Not in Issue"

5-A. Non Issue #1: Judge Torribio states:

1. MAC [Attorney MacNaughton] asserted that Abrahams and Reichenbach constructively resigned form the SH.ORG's [SaveHywd's] legal committee in February 2012 ¶ This is disputed by Abrahams and Reichenbach. Abraham declaration, paragraph 6. Reichenbach declaration Paragraph 3, exhibits 1 and 2

This purported fact is false. Attorney MacNaughton asserted that Abrahams and

Reichenbach constructively resigned and abandoned SaveHywd's Legal Committee

starting in September 2013, not February 2012. Also, Judge Torribio's allusion to

declarations and exhibits is meaningless as he never identified which declaration or

exhibits as Fran Reichenbach and George Abrahams had submitted hundreds of pages

of declarations and exhibits. Citing a declaration or exhibit gives the false impression

that the alleged fact has evidentiary support.

This false fact can serve one purpose. It misleads the appeals court about the

constructive resignation and abandonment in September 2013 in order to conceal

Frank Angel's breach of duties to his client.

The evidence that Fran Reichenbach and George Abrahams constructively

resigned and abandoned the Legal Committee is overwhelming. By intentionally

misrepresenting the date, Judge Torribio creates more confusion than an appellate

court could hope to unravel.

SaveHywd submitted hundreds of Bates stamped pages from the prior pleadings

to facilitate Judge Torribio's task in considering Frank Angel's C.C.P., § 128.7

Motion, but Judge Torribio has ignored these documents. This verified statement of

disqualification is already lengthy. Whoever reads and considers the disqualification


will have to obtain not only the Bates stamped documents for the February 27, 2015

hearing, but also will have to review the original pleadings and declarations in the case

file starting in September-October 2013 in order to unravel the cover-up which Judge

Torribio has perpetrated.

14. The Most Damaging Evidence Against Judge Torribio

Judge Torribio's most malicious falsifications occur with respect to co-founder

of SaveHywd, Robert (Bob) Blue. Judge Torribio states:

The fulcrum issue in this matter is simply, "Did Blue resign from the Legal Committee on January 15, 2013 when he sent his letter of resignation?" Attached hereto as Exhibit 1 is the E-mail resignation that is in issue. If he did, the action of the MAC Legal Committee are illegal as it lacked a quorum. Only two of the required three members were present when the action to terminate ALF was voted on. (Exhibit #1 March 9, 20156 Order p 3, ¶ 1)

Then, Judge Torribio takes out a huge eraser and wipes away all the evidence

which establishes beyond any doubt that Robert Blue did NOT resign from the Legal

Committee. In place of the actual evidence, Judge Torribio manufactures utter

nonsense which makes a mockery out of the judicial system.

(1) Judge Torribio invents words and puts them into the mouth of Judge

Goodman, saying that Judge Goodman's terse denial of the motion to have Frank

Angel cease filing documents mean that Judge Goodman had found that Robert Blue

had resigned from the Legal Committee.

4We shall leave aside the fact that 2 is a quorum of a 3 member committee, which means whether or not Bob Blue was part of the committee the firing of Frank Angel was proper.


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will have to obtain not only the Bates stamped documents for the February 27, 2015

hearing, but also will have to review the original pleadings and declarations in the case

file starting in September-October 2013 in order to unravel the cover-up which Judge

Torribio has perpetrated.

14. The Most Damaging Evidence Against Judge Torribio

Judge Torribio's most malicious falsifications occur with respect to co-founder

of SaveHywd, Robert (Bob) Blue. Judge Torribio states:

The fulcrum issue in this matter is simply, "Did Blue resign from the Legal Committee on January 15, 2013 when he sent his letter of resignation?" Attached hereto as Exhibit 1 is the E-mail resignation that is in issue. If he did, the action of the MAC Legal Committee are illegal as it lacked a quorum. Only two of the required three members were present when the action to terminate ALF was voted on. (Exhibit #1 March 9, 20156 Order p 3, ¶ 1)

Then, Judge Torribio takes out a huge eraser and wipes away all the evidence

which establishes beyond any doubt that Robert Blue did NOT resign from the Legal

Committee. In place of the actual evidence, Judge Torribio manufactures utter

nonsense which makes a mockery out of the judicial system.

(1) Judge Torribio invents words and puts them into the mouth of Judge

Goodman, saying that Judge Goodman's terse denial of the motion to have Frank

Angel cease filing documents mean that Judge Goodman had found that Robert Blue

had resigned from the Legal Committee.

4We shall leave aside the fact that 2 is a quorum of a 3 member committee, which means whether or not Bob Blue was part of the committee the firing of Frank Angel was proper.


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Judge Goodman never uttered those words. The only words which Judge

Goodman uttered concerning who was SaveHywd's attorney and who was the attorney

for the non-party corporation came on September 18, 2014 and then on September 24,

2014. In purporting to divine what Judge Goodman intended, Judge Torribio commits

what in most legal systems would be an unpardonable sin -- he covers up the most

material evidence.

As explained supra, on September 18, 2014, Judge Goodman explained that

Attorney MacNaughton was the attorney for SaveHywd and by the context it was clear

that Judge Goodman considered Frank Angel to be the attorney for the corporation.

When Frank Angel wanted to be recognized as SaveHywd's attorney rather than

Attorney MacNaughton, Judge Goodman set a hearing for September 24, 2014 after

which he declined to remove Attorney MacNaughton as SaveHywd's attorney. Judge

Goodman had just reviewed all of Frank Angel's allegations about the July 5, 2014

firing of Attorney MacNaughton. Despite reviewing these allegations and supporting

documentation, Judge Goodman did not agree that Attorney MacNaughton had been

removed as SaveHywd's attorney. Because Judge Goodman had been the judge during

the problems with Frank Angel's dual representation and Frank Angel's attempts to

remove Attorney MacNaughton, Judge Goodman's thoughts on this matter should not

have been withheld from the appeals court.

Judge Torribio's concealing of this vital evidence is malicious in that there is

no way that Attorney MacNaughton could be acting wrongfully in saying he repre-

sented SaveHywd when Judge Goodman agreed with him. Unless this evidence were

concealed, Judge Torribio could not rule:

Mr. MacNaughton filed his [July 16, 2014] NOP motion primarily for the improper purpose of needlessly increasing litigation costs to and harassing petitioner. (Exhibit #1 page 4)

///


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Judge Goodman never uttered those words. The only words which Judge

Goodman uttered concerning who was SaveHywd's attorney and who was the attorney

for the non-party corporation came on September 18, 2014 and then on September 24,

2014. In purporting to divine what Judge Goodman intended, Judge Torribio commits

what in most legal systems would be an unpardonable sin -- he covers up the most

material evidence.

As explained supra, on September 18, 2014, Judge Goodman explained that

Attorney MacNaughton was the attorney for SaveHywd and by the context it was clear

that Judge Goodman considered Frank Angel to be the attorney for the corporation.

When Frank Angel wanted to be recognized as SaveHywd's attorney rather than

Attorney MacNaughton, Judge Goodman set a hearing for September 24, 2014 after

which he declined to remove Attorney MacNaughton as SaveHywd's attorney. Judge

Goodman had just reviewed all of Frank Angel's allegations about the July 5, 2014

firing of Attorney MacNaughton. Despite reviewing these allegations and supporting

documentation, Judge Goodman did not agree that Attorney MacNaughton had been

removed as SaveHywd's attorney. Because Judge Goodman had been the judge during

the problems with Frank Angel's dual representation and Frank Angel's attempts to

remove Attorney MacNaughton, Judge Goodman's thoughts on this matter should not

have been withheld from the appeals court.

Judge Torribio's concealing of this vital evidence is malicious in that there is

no way that Attorney MacNaughton could be acting wrongfully in saying he repre-

sented SaveHywd when Judge Goodman agreed with him. Unless this evidence were

concealed, Judge Torribio could not rule:

Mr. MacNaughton filed his [July 16, 2014] NOP motion primarily for the improper purpose of needlessly increasing litigation costs to and harassing petitioner. (Exhibit #1 page 4)

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The concealing of this determinative evidence shows not only Judge Torribio's

malicious bias against Attorney MacNaughton but also a reprehensible disregard for

the rule of law. Judge Torribio, however, has not finished his trampling of all decency

out of the legal system.

15. The Role of Justice Paul Turner

Judge Torribio then makes reference to Appeals Court Justice Paul Turner's

involvement in this case. As is Judge Torribio's custom, his statement contains a

material falsehood.

Second, an appeal of sorts arose in the appellate Court. It was briefed, declarations filed and Justice Turner also found that ALF [Frank Angel] was attorney for SH.ORG [SaveHywd]. Exhibit #1 p3 ¶ 4

As Judge Torribio knew, Justice Turner had no jurisdiction and Justice Turner

provided no due Process. With no basis, Justice Turner decided to issue an order

removing Attorney MacNaughton as SaveHywd's attorney and making Frank Angel

SaveHywd's attorney. The reality is that there had been no "appeal of sorts" and

hence Justice Turner had no jurisdiction. As Judge Torribio knew, there had been no

motion on the appellate level. Thus, there had been no Due Process.

What existed at the appellate level was Judge Goodman's sitting on special

assignment in Division 5, the same Division over which Justice Turner presided.

While HELP cannot know what, if anything, Judge Goodman and Justice Turner

discussed concerning the SaveHywd case, we do know what occurred soon after Frank

Angel filed his C.C.P., § 128.7 Motion before Judge Torribio.

On December 26, 2014, Justice Turner issued an order removing Attorney Mac

Naughton as SaveHywd's attorney and making Frank Angel SaveHywd's attorney.

This order was without jurisdiction and without any due process. There was no


The concealing of this determinative evidence shows not only Judge Torribio's

malicious bias against Attorney MacNaughton but also a reprehensible disregard for

the rule of law. Judge Torribio, however, has not finished his trampling of all decency

out of the legal system.

15. The Role of Justice Paul Turner

Judge Torribio then makes reference to Appeals Court Justice Paul Turner's

involvement in this case. As is Judge Torribio's custom, his statement contains a

material falsehood.

Second, an appeal of sorts arose in the appellate Court. It was briefed, declarations filed and Justice Turner also found that ALF [Frank Angel] was attorney for SH.ORG [SaveHywd]. Exhibit #1 p3 ¶ 4

As Judge Torribio knew, Justice Turner had no jurisdiction and Justice Turner

provided no due Process. With no basis, Justice Turner decided to issue an order

removing Attorney MacNaughton as SaveHywd's attorney and making Frank Angel

SaveHywd's attorney. The reality is that there had been no "appeal of sorts" and

hence Justice Turner had no jurisdiction. As Judge Torribio knew, there had been no

motion on the appellate level. Thus, there had been no Due Process.

What existed at the appellate level was Judge Goodman's sitting on special

assignment in Division 5, the same Division over which Justice Turner presided.

While HELP cannot know what, if anything, Judge Goodman and Justice Turner

discussed concerning the SaveHywd case, we do know what occurred soon after Frank

Angel filed his C.C.P., § 128.7 Motion before Judge Torribio.

On December 26, 2014, Justice Turner issued an order removing Attorney Mac

Naughton as SaveHywd's attorney and making Frank Angel SaveHywd's attorney.

This order was without jurisdiction and without any due process. There was no


indication that it even applied to the trial court. Justice Turner's unwarranted intrusion

into this matter changed everything. It is reasonable to believe that had Justice Turner

remained silent, that Judge Torribio or any other trial court judge would have followed

Judge Goodman's pattern of not removing attorney MacNaughton, but once the

appellate court had spoken, even without jurisdiction, the trial court knew what was

wanted.

16. Judge Torribio Has Not Finished with His Concealment and Manufacturing of Evidence with Respect to Robert Blue

Justice Torribio invents a whopper of a falsehood. He states:

His [Robert Blue's] letter of resignation was sent to SH.ORG [the legal committee] and not savehollywoodorg [the corproation]. Ex #1 p3113

Judge Torribio ignores all the facts.

(1) Robert Blue expressly resigned from the corporation by using the word

"Board." Even Judge Torribio recognizes that Bob Blue knows the difference between

the two entities, yet, Judge Torribio pays no attention that Robert Blue resigned only

from the Board with no mention of the Legal Committee.

(2) Judge Ton-ibio conceals the evidence that all members of the Legal

Committee recognized Bob Blue as a member in good standing of the Legal

Committee after his January 15, 2013 resignation from the corporation's Board. Judge

Torribio had before him emails proving that Bob Blue had not resigned from the Legal

Committee since he continued to participate in all of its activities without any objec-

tion from anyone.

(3) Judge Torribio conceals the fact that under the corporation's By Laws a

board member's resignation needs to be sent to corporation's President, who was


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indication that it even applied to the trial court. Justice Turner's unwarranted intrusion

into this matter changed everything. It is reasonable to believe that had Justice Turner

remained silent, that Judge Torribio or any other trial court judge would have followed

Judge Goodman's pattern of not removing attorney MacNaughton, but once the

appellate court had spoken, even without jurisdiction, the trial court knew what was

wanted.

16. Judge Torribio Has Not Finished with His Concealment and Manufacturing of Evidence with Respect to Robert Blue

Justice Torribio invents a whopper of a falsehood. He states:

His [Robert Blue's] letter of resignation was sent to SH.ORG [the legal committee] and not savehollywoodorg [the corproation]. Ex #1 p3113

Judge Torribio ignores all the facts.

(1) Robert Blue expressly resigned from the corporation by using the word

"Board." Even Judge Torribio recognizes that Bob Blue knows the difference between

the two entities, yet, Judge Torribio pays no attention that Robert Blue resigned only

from the Board with no mention of the Legal Committee.

(2) Judge Ton-ibio conceals the evidence that all members of the Legal

Committee recognized Bob Blue as a member in good standing of the Legal

Committee after his January 15, 2013 resignation from the corporation's Board. Judge

Torribio had before him emails proving that Bob Blue had not resigned from the Legal

Committee since he continued to participate in all of its activities without any objec-

tion from anyone.

(3) Judge Torribio conceals the fact that under the corporation's By Laws a

board member's resignation needs to be sent to corporation's President, who was


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George Abrahams and the resignation from the Board was sent to George Abrahams.

The By Laws were before Judge Torribio, but he chose to overlook them.

7.4.3 Resignations Any Director may resign by giving written, verbal, or electronic notice to the Chairperson, the President, the Secretary, or the Board. (Exhibit # 11 page 5)

(4) There is no provision in the corporation's By Laws that a resignation from

the corporation Board becomes transmuted into a resignation from the Legal

Committee because Bob Blue sends copies to other people.

(5) Judge Torribio has no idea of the process by which Robert Blue could resign

from the Legal Committee. It most certainly would not be by sending a copy of his

resignation from the corporation's Board with no mention of the Legal Committee.

(6) Bob Blue's resignation from the Board was directed to the Board because

he resigned over the corporation's President's, George Abrahams', handling of the

fund raising letter to The Sierra Club.

(7) Robert Blue's references to the way the corporation was being run were

directed solely at George Abrahams as the balance of the email demonstrated.

Everyone involved with the litigation knew that the Legal Committee controlled the

litigation and that as lead attorney, Richard MacNaughton, and not George Abrahams,

was controlling the litigation. It would be ludicrous in the extreme for Bob Blue to

resign from the Legal Committee where Attorney MacNaughton was making the

decisions.

(8) Judge Torribio ignores that the fund raising letter is on the stationery for the

corporation and not on the stationery for the Legal Committee.


George Abrahams and the resignation from the Board was sent to George Abrahams.

The By Laws were before Judge Torribio, but he chose to overlook them.

7.4.3 Resignations Any Director may resign by giving written, verbal, or electronic notice to the Chairperson, the President, the Secretary, or the Board. (Exhibit # 11 page 5)

(4) There is no provision in the corporation's By Laws that a resignation from

the corporation Board becomes transmuted into a resignation from the Legal

Committee because Bob Blue sends copies to other people.

(5) Judge Torribio has no idea of the process by which Robert Blue could resign

from the Legal Committee. It most certainly would not be by sending a copy of his

resignation from the corporation's Board with no mention of the Legal Committee.

(6) Bob Blue's resignation from the Board was directed to the Board because

he resigned over the corporation's President's, George Abrahams', handling of the

fund raising letter to The Sierra Club.

(7) Robert Blue's references to the way the corporation was being run were

directed solely at George Abrahams as the balance of the email demonstrated.

Everyone involved with the litigation knew that the Legal Committee controlled the

litigation and that as lead attorney, Richard MacNaughton, and not George Abrahams,

was controlling the litigation. It would be ludicrous in the extreme for Bob Blue to

resign from the Legal Committee where Attorney MacNaughton was making the

decisions.

(8) Judge Torribio ignores that the fund raising letter is on the stationery for the

corporation and not on the stationery for the Legal Committee.


(9) Judge Torribio manufactures complete nonsense in order to pervert the Bob

Blue resignation from the corporation. Judge Torribio writes:

The only logical conclusion is that Blue resigned from the Legal Committee of SH.ORG. Blue's dispute over the handling of the request to have the Sierra Club join the action financially and with the litigation, makes no sense re resigning from the fundraising arm, but makes complete sense from the litigation angel. (Exhibit #1 p 3 ¶5)

(10) As the declarations of Ziggy Kruse and Bob Blue made clear, The Legal

Committee played no role whatsoever in the Sierra Club letter and Attorney Mac

Naughton was in control of the litigation. (Exhibit #12)

(11) All the meetings for the Sierra Club letter were held by the corporation and

none by the Legal Committee. (Exhibit # 13)

(12) The letter expressly asked for money from the Sierra Club. The corporation

handles the fund raising as it is the 501(c)(3) organization. The non- 501(c)(3)

organization would not do the fund raising. That would completely defeat the purpose

of the 501(c)(3) corporation.

(13) Judge Torribio manufactured evidence on how the Sierra Club letter was

structured. The idea that SaveHywd wanted the Sierra Club to actually intervene as

a separate party in the lawsuit is absurd, yet it served a beneficial fund raising

objective. It is common to ask for something significant and difficult and then present

a fall back request that is much easier. Intervening into major litigation is very costly

and extremely time consuming and the likelihood of the Sierra Club's intervening was

not only slim, but highly undesirable. If the Sierra Club intervened, all its money

would go to itself and none of its money would go to help pay SaveHywd's litigation

expenses.


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(9) Judge Torribio manufactures complete nonsense in order to pervert the Bob

Blue resignation from the corporation. Judge Torribio writes:

The only logical conclusion is that Blue resigned from the Legal Committee of SH.ORG. Blue's dispute over the handling of the request to have the Sierra Club join the action financially and with the litigation, makes no sense re resigning from the fundraising arm, but makes complete sense from the litigation angel. (Exhibit #1 p 3 ¶5)

(10) As the declarations of Ziggy Kruse and Bob Blue made clear, The Legal

Committee played no role whatsoever in the Sierra Club letter and Attorney Mac

Naughton was in control of the litigation. (Exhibit #12)

(11) All the meetings for the Sierra Club letter were held by the corporation and

none by the Legal Committee. (Exhibit # 13)

(12) The letter expressly asked for money from the Sierra Club. The corporation

handles the fund raising as it is the 501(c)(3) organization. The non- 501(c)(3)

organization would not do the fund raising. That would completely defeat the purpose

of the 501(c)(3) corporation.

(13) Judge Torribio manufactured evidence on how the Sierra Club letter was

structured. The idea that SaveHywd wanted the Sierra Club to actually intervene as

a separate party in the lawsuit is absurd, yet it served a beneficial fund raising

objective. It is common to ask for something significant and difficult and then present

a fall back request that is much easier. Intervening into major litigation is very costly

and extremely time consuming and the likelihood of the Sierra Club's intervening was

not only slim, but highly undesirable. If the Sierra Club intervened, all its money

would go to itself and none of its money would go to help pay SaveHywd's litigation

expenses.


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There were already five (5) petitioners and all the issues had been distributed

among the petitioners. No issue was uncovered and there was no need for the Sierra

Club and its wilderness expertise to be involved.

Because of the carefully structured nature of the Sierra Club letter, the express

instruction to George Abrahams was to sign and return it to Ziggy Kruse who had the

personal contact with the Sierra Club. Rather, like a bull in a china shop, George

Abrahams himself sends off the letter to the Sierra Club. By depriving Ms. Kruse of

the opportunity to present the letter through the correct channels in order to obtain

financial support, George Abrahams doomed the entire fund raising effort.

Following is the pattern which Ms. Kruse and Mr. Blue had structured for the

January 15, 2013 letter to the Sierra Club:

A) The Sierra Club will lend its support to SaveHollywood.org by requesting an intervention regarding the environmental aspects of the case

B) The Sierra Club will lend its support to SaveHollywood.org by helping our organization raise funds to sustain the lawsuit

This format is the classic large difficult request followed by the much easier

smaller request, which is the actual goal — money!

Robert Blue's resignation from the corporation's Board was reasonable in light

of the manner in which George Abrahams was running the corporation and had

nothing at all to do with the way Attorney MacNaughton was running the litigation.

17. Additional Material Misrepresentation by Omission

Judge Torribio's Fact Not In Issue # 11 is false. It states: "08/20/14" SH.ORG

files this motion for Sanctions pursuant to CCP 128.7"


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There were already five (5) petitioners and all the issues had been distributed

among the petitioners. No issue was uncovered and there was no need for the Sierra

Club and its wilderness expertise to be involved.

Because of the carefully structured nature of the Sierra Club letter, the express

instruction to George Abrahams was to sign and return it to Ziggy Kruse who had the

personal contact with the Sierra Club. Rather, like a bull in a china shop, George

Abrahams himself sends off the letter to the Sierra Club. By depriving Ms. Kruse of

the opportunity to present the letter through the correct channels in order to obtain

financial support, George Abrahams doomed the entire fund raising effort.

Following is the pattern which Ms. Kruse and Mr. Blue had structured for the

January 15, 2013 letter to the Sierra Club:

A) The Sierra Club will lend its support to SaveHollywood.org by requesting an intervention regarding the environmental aspects of the case

B) The Sierra Club will lend its support to SaveHollywood.org by helping our organization raise funds to sustain the lawsuit

This format is the classic large difficult request followed by the much easier

smaller request, which is the actual goal — money!

Robert Blue's resignation from the corporation's Board was reasonable in light

of the manner in which George Abrahams was running the corporation and had

nothing at all to do with the way Attorney MacNaughton was running the litigation.

17. Additional Material Misrepresentation by Omission

Judge Torribio's Fact Not In Issue # 11 is false. It states: "08/20/14" SH.ORG

files this motion for Sanctions pursuant to CCP 128.7"


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Frank Angel filed nothing on August 20, 2014. The CCP 128.7 Motion which

Judge Torribio heard was filed on December 8, 2014. It appears that one reason Judge

Torribio falsely placed the filing of the motion as occurring in August and not

December was to cover-up the fact that in September 2014, Judge Goodman had stated

that Frank Angel was not SaveHywd's attorney but that Attorney MacNaughton was

SaveHywd's attorney.

By omitting this crucial fact from his CCP 128.7 motion, Frank Angel

committed a fraud on the appeals court. Judge Torribio's altering the facts to conceal

Frank Angel's misconduct is depreciable behavior. It also highlights the disregard

which Judge Torribio has for the judicial system. He knows that anyone who looks at

the case Summary will see that Frank Angel filed nothing on August 20, 2014, but he

does not care that he is making materially false representations whose falsehood can

be quickly revealed.

18. Frank Angel Was Fired on February 14, 2014 Due to His Outrageous Breach of Duties To SaveHywd

Judge Torribio's distortions of the record are not only reprehensible but now

that they are revealed, Judge Torribio's own logic shows that Frank Angel was fired

by SaveHywd on February 14, 2014 due to his extreme breaches of ethical duties.

Robert Blue did not resign from the Legal Committee but Fran Reichenbach and

George Abrahams had constructively resigned (abandoned) the Legal Committee

starting in September 2013 at the same time Frank Angel began his dual representation

of SaveHywd and the corporation. These facts, which Judge Torribio conceals, are

established beyond any doubt by the declarations and exhibits which Frank Angel,

Fran Reichenbach and George Abrahams filed with the court.

As stated above, the Reichenbach and Abrahams declarations and exhibits run

hundreds of pages and SaveHywd had presented many of them in highlighted fashion


Frank Angel filed nothing on August 20, 2014. The CCP 128.7 Motion which

Judge Torribio heard was filed on December 8, 2014. It appears that one reason Judge

Torribio falsely placed the filing of the motion as occurring in August and not

December was to cover-up the fact that in September 2014, Judge Goodman had stated

that Frank Angel was not SaveHywd's attorney but that Attorney MacNaughton was

SaveHywd's attorney.

By omitting this crucial fact from his CCP 128.7 motion, Frank Angel

committed a fraud on the appeals court. Judge Torribio's altering the facts to conceal

Frank Angel's misconduct is depreciable behavior. It also highlights the disregard

which Judge Torribio has for the judicial system. He knows that anyone who looks at

the case Summary will see that Frank Angel filed nothing on August 20, 2014, but he

does not care that he is making materially false representations whose falsehood can

be quickly revealed.

18. Frank Angel Was Fired on February 14, 2014 Due to His Outrageous Breach of Duties To SaveHywd

Judge Torribio's distortions of the record are not only reprehensible but now

that they are revealed, Judge Torribio's own logic shows that Frank Angel was fired

by SaveHywd on February 14, 2014 due to his extreme breaches of ethical duties.

Robert Blue did not resign from the Legal Committee but Fran Reichenbach and

George Abrahams had constructively resigned (abandoned) the Legal Committee

starting in September 2013 at the same time Frank Angel began his dual representation

of SaveHywd and the corporation. These facts, which Judge Torribio conceals, are

established beyond any doubt by the declarations and exhibits which Frank Angel,

Fran Reichenbach and George Abrahams filed with the court.

As stated above, the Reichenbach and Abrahams declarations and exhibits run

hundreds of pages and SaveHywd had presented many of them in highlighted fashion


with bates stamps to Judge Torribio, but he ignored everything that did not support his

pre-determined goal to frame Attorney MacNaughton for misconduct which did not

occur.

19. Summary

While no jurist should excuse Judge Goodman's helping Frank Angel breach

his duties to his client SaveHywd in order to secure $114 Million to which Frank

Angel was not entitled, Judge Goodman's original judicial misbehavior is nothing

compared to the cover-up which it brought upon the entire judicial system.

When Judge Kozinski blamed the California courts for the extreme level of

attorney misconduct, it was clear that he was referring to all levels of the California

judiciary. Judge Fletcher and Judge Wardlaw also commented on the illicit practices

which had plagued the California judiciary for many years. Too many California

judges have become habituated to doing favors for their friends and for pushing cases

in the direction which benefitted the judges' careers. This proclivity among the

California judiciary was responsible for the Ramparts Scandal, but as those who were

involved in the criminal courts in the 1990's knew, the judges made certain that no

liability would attach to them for their roles in judicial misconduct.

On the civil side, similar misconduct is likewise habitual. Attorneys with

experience with the Los Angeles Superior Courts always inquire about the judges to

whom they have been assigned. Consumer attorneys know that many judges are

defense judges and the likelihood of obtaining a fair hearing is between slim and none.

Although no one wants to admit it, one reason all attorneys get one C.C.P. § 170.6 is

to ease the pressure for reform.

Thus, it should surprise no one that Judge Goodman would favor an attorney

whom he knew, Frank Angel, and would want to save Frank Angel from his own


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with bates stamps to Judge Torribio, but he ignored everything that did not support his

pre-determined goal to frame Attorney MacNaughton for misconduct which did not

occur.

19. Summary

While no jurist should excuse Judge Goodman's helping Frank Angel breach

his duties to his client SaveHywd in order to secure $114 Million to which Frank

Angel was not entitled, Judge Goodman's original judicial misbehavior is nothing

compared to the cover-up which it brought upon the entire judicial system.

When Judge Kozinski blamed the California courts for the extreme level of

attorney misconduct, it was clear that he was referring to all levels of the California

judiciary. Judge Fletcher and Judge Wardlaw also commented on the illicit practices

which had plagued the California judiciary for many years. Too many California

judges have become habituated to doing favors for their friends and for pushing cases

in the direction which benefitted the judges' careers. This proclivity among the

California judiciary was responsible for the Ramparts Scandal, but as those who were

involved in the criminal courts in the 1990's knew, the judges made certain that no

liability would attach to them for their roles in judicial misconduct.

On the civil side, similar misconduct is likewise habitual. Attorneys with

experience with the Los Angeles Superior Courts always inquire about the judges to

whom they have been assigned. Consumer attorneys know that many judges are

defense judges and the likelihood of obtaining a fair hearing is between slim and none.

Although no one wants to admit it, one reason all attorneys get one C.C.P. § 170.6 is

to ease the pressure for reform.

Thus, it should surprise no one that Judge Goodman would favor an attorney

whom he knew, Frank Angel, and would want to save Frank Angel from his own


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horrible breach of duties to his client. Judge Goodman did not know Attorney

MacNaughton, since he had been ill with cancer for so long. To Judge Goodman,

Attorney MacNaughton was dispensable, a Nobody. Judge Goodman did not know

or care that Attorney MacNaughton had worked on the Hollywood Community Plan

Update since Spring 2005. Nor, did Judge Goodman know or care that Attorney

MacNaughton had placed into the administrative record the materials which allowed

Judge Goodman to see that the HCP Update was "fatally flawed" and based on

"wishful thinking."

It is probable that Judge Goodman never bothered to read the papers which

Attorney MacNaughton submitted on behalf of petitioner SaveHywd in January and

February 2014. Judge Goodman knew that he was going to ignore Frank Angel's

transgressions and that he was going to make certain that Frank Angel obtained

significant attorney fees from the City. It probably never occurred to Judge Goodman

that he was doing anything wrong when he manipulated the March 25 and March 27,

2014 orders so that the City had no choice but pay Frank Angel $1/4 Million.

One irony is that SaveHywd and Attorney MacNaughton followed Judge

Goodman's order not to again raise Frank Angel's misconduct and hence bring to light

Judge Goodman's role in getting the $1/4 Million from the City.

It was Frank Angel who kept placing Judge Goodman into danger. Even after

Judge Goodman identified Frank Angel as the attorney for the corporation and refused

to remove Attorney MacNaughton, Frank Angel still raised the matter by placing his

C.C.P, § 128.7 Motion on calendar.

If Justice Turner had not interjected himself into the matter in a reprehensible

manner, it is likely that Judge Torribio would have followed Judge Goodman's lead

and once again not ruled in Frank Angel's favor.


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horrible breach of duties to his client. Judge Goodman did not know Attorney

MacNaughton, since he had been ill with cancer for so long. To Judge Goodman,

Attorney MacNaughton was dispensable, a Nobody. Judge Goodman did not know

or care that Attorney MacNaughton had worked on the Hollywood Community Plan

Update since Spring 2005. Nor, did Judge Goodman know or care that Attorney

MacNaughton had placed into the administrative record the materials which allowed

Judge Goodman to see that the HCP Update was "fatally flawed" and based on

"wishful thinking."

It is probable that Judge Goodman never bothered to read the papers which

Attorney MacNaughton submitted on behalf of petitioner SaveHywd in January and

February 2014. Judge Goodman knew that he was going to ignore Frank Angel's

transgressions and that he was going to make certain that Frank Angel obtained

significant attorney fees from the City. It probably never occurred to Judge Goodman

that he was doing anything wrong when he manipulated the March 25 and March 27,

2014 orders so that the City had no choice but pay Frank Angel $1/4 Million.

One irony is that SaveHywd and Attorney MacNaughton followed Judge

Goodman's order not to again raise Frank Angel's misconduct and hence bring to light

Judge Goodman's role in getting the $1/4 Million from the City.

It was Frank Angel who kept placing Judge Goodman into danger. Even after

Judge Goodman identified Frank Angel as the attorney for the corporation and refused

to remove Attorney MacNaughton, Frank Angel still raised the matter by placing his

C.C.P, § 128.7 Motion on calendar.

If Justice Turner had not interjected himself into the matter in a reprehensible

manner, it is likely that Judge Torribio would have followed Judge Goodman's lead

and once again not ruled in Frank Angel's favor.


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Justice Turner, however, did insert himself, but without his having jurisdiction

or using due process. Hence, Justice Turner had no judicial immunity for his

December 26, 2014 order. That bit of personal hubris threw the entire system into

panic. (Exhibit # 13 is Justice Turner's December 26, 2014 Order)

So now it comes down to Judge Torribio and a corrupt judicial system desperate

for a decision to cleanse not only Judge Goodman's misconduct but also Justice

Turner's misconduct which fell outside the limits of judicial immunity.

Judge Torribio delivered his order like a dutiful soldier just following orders,

but his deceptions are so facile that they are clear for anyone who looks at them. The

days when the judiciary could keep its foul deeds a secret by locking up attorneys in

coercive confinement are over. With Twitter, Facebook, internet blogs, etc., the true

nature of the California judiciary is becoming known to not only Californians and

other Americans but also to the entire world.

20. Conclusion

Judge Torribio's extreme bias against Attorney MacNaughton which has lead

Judge Torribio to behave in a disgraceful fashion is now being exhibited against HELP

by Judge Torribio's refusal to even acknowledge that HELP is one of the petitioners

in this lawsuit when in fact HELP is the sole petitioner whose remittitur has issued.

Judge Torribio is hereby disqualified from this case.

Dated: May 9, 2015

Law Offices of Richard Mac on

By TZ.c_CL-)cpc Attorney for Hollywoodians Encouraging Logical Planning HELP]


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Justice Turner, however, did insert himself, but without his having jurisdiction

or using due process. Hence, Justice Turner had no judicial immunity for his

December 26, 2014 order. That bit of personal hubris threw the entire system into

panic. (Exhibit # 13 is Justice Turner's December 26, 2014 Order)

So now it comes down to Judge Torribio and a corrupt judicial system desperate

for a decision to cleanse not only Judge Goodman's misconduct but also Justice

Turner's misconduct which fell outside the limits of judicial immunity.

Judge Torribio delivered his order like a dutiful soldier just following orders,

but his deceptions are so facile that they are clear for anyone who looks at them. The

days when the judiciary could keep its foul deeds a secret by locking up attorneys in

coercive confinement are over. With Twitter, Facebook, internet blogs, etc., the true

nature of the California judiciary is becoming known to not only Californians and

other Americans but also to the entire world.

20. Conclusion

Judge Torribio's extreme bias against Attorney MacNaughton which has lead

Judge Torribio to behave in a disgraceful fashion is now being exhibited against HELP

by Judge Torribio's refusal to even acknowledge that HELP is one of the petitioners

in this lawsuit when in fact HELP is the sole petitioner whose remittitur has issued.

Judge Torribio is hereby disqualified from this case.

Dated: May 9, 2015

Law Offices of Richard Mac on

By TZ.c_CL-)cpc Attorney for Hollywoodians Encouraging Logical Planning HELP]


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Verification

Verification

Verification

Verification

Verification of Code of Civil Procedure, § 170.1 Statement of Disqualification

Due to the facts set forth in the verified statement of disqualification and due

to the facts in the my declaration and exhibits submitted concurrently herewith and in

addition to my personal witnessing of Judge Torribio's biased conduct, especially his

conducting a private side bar with opposing counsel while he and opposing counsel

reviewed documents which Judge Torribio would not allow me to see despite my

objection that I had grounds to believe that they were my attorney work product, I

verify under penalty of perjury of the laws of the state of California my good faith

reasonable belief that I and no client whom I present can receive a fair hearing on any

issue before Judge Torribio.

I, Richard MacNaughton, declare that have I have written and I have read and

I know the contents of the foregoing the verified Statement of Disqualification against

Judge John Torribio under Code of Civil Procedure, §§ 170.1 and 170.3, and I verify

and declare under penalty of perjury of the laws of the State of California and based

on my own personal knowledge that the facts therein are true and correct, except to the

extent where the context required them to be on the basis of information and belief,

and as to those facts, I believe the this verified Statement of Disqualification to be true

and correct.

Signed on May 10, 2015 at Hollywood, i ornia: e-------) r

1 .----toinr'elc32--__. By Richard MacNaughton


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Verification of Code of Civil Procedure, § 170.1 Statement of Disqualification

Due to the facts set forth in the verified statement of disqualification and due

to the facts in the my declaration and exhibits submitted concurrently herewith and in

addition to my personal witnessing of Judge Torribio's biased conduct, especially his

conducting a private side bar with opposing counsel while he and opposing counsel

reviewed documents which Judge Torribio would not allow me to see despite my

objection that I had grounds to believe that they were my attorney work product, I

verify under penalty of perjury of the laws of the state of California my good faith

reasonable belief that I and no client whom I present can receive a fair hearing on any

issue before Judge Torribio.

I, Richard MacNaughton, declare that have I have written and I have read and

I know the contents of the foregoing the verified Statement of Disqualification against

Judge John Torribio under Code of Civil Procedure, §§ 170.1 and 170.3, and I verify

and declare under penalty of perjury of the laws of the State of California and based

on my own personal knowledge that the facts therein are true and correct, except to the

extent where the context required them to be on the basis of information and belief,

and as to those facts, I believe the this verified Statement of Disqualification to be true

and correct.

Signed on May 10, 2015 at Hollywood, i ornia: e-------) r

1 .----toinr'elc32--__. By Richard MacNaughton


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Proof of Service By US Mail

STATE OF CALIFORNIA COUNTY OF LOS ANGELES

I am employed in the County of Los Angeles, State of California and I am over the age of eighteen (18) years and I am not a party to this within action. My business address is 1916 North Saint Andrews Place, Hollywood, CA 90068

On Monday, May 11, 2015, I served the following documents:

1. PETITIONER HOLLYWOODIANS ENCOURAGING LOGICAL PLAN-NING'S [HELP's] CODE OF CIVIL PROCEDURE, § 170.1, 170.3 DISQUALI-FICATION OF JUDGE JOHN TORRIBIO FOR BIAS AND PREJUDICE WITH VERIFICATION

2. DECLARATION OF RICHARD MacNAUGHTON, ESQ AND EXHIBITS FOR VERIFIED STATEMENT OF DISQUALIFICATION [C.C.P., § 170.1, 170.3 et seq]

on all interested parties by Mailing via US mail a true and correct copy as indicated below:

see attached list

I declare under penalty of perjury of the laws of the State of California that the foregoing is true and correct. Executed at Hollywood, California on May 11, 2015

Proof of Service By US Mail

STATE OF CALIFORNIA COUNTY OF LOS ANGELES

I am employed in the County of Los Angeles, State of California and I am over the age of eighteen (18) years and I am not a party to this within action. My business address is 1916 North Saint Andrews Place, Hollywood, CA 90068

On Monday, May 11, 2015, I served the following documents:

1. PETITIONER HOLLYWOODIANS ENCOURAGING LOGICAL PLAN-NING'S [HELP's] CODE OF CIVIL PROCEDURE, § 170.1, 170.3 DISQUALI-FICATION OF JUDGE JOHN TORRIBIO FOR BIAS AND PREJUDICE WITH VERIFICATION

2. DECLARATION OF RICHARD MacNAUGHTON, ESQ AND EXHIBITS FOR VERIFIED STATEMENT OF DISQUALIFICATION [C.C.P., § 170.1, 170.3 et seq]

on all interested parties by Mailing via US mail a true and correct copy as indicated below:

see attached list

I declare under penalty of perjury of the laws of the State of California that the foregoing is true and correct. Executed at Hollywood, California on May 11, 2015

Michael Bostrom, Esq. Siegmund Shyu, Deputy City Attorney 200 North Main Street, 701 City Hall East Los Angeles, California 90012-4131

Edward Klein, Esq. Liner LLP 1100 Glendon Avenue, 14th Floor Los Angeles, CA 90024-3503

Robert P. Silverstein, Esq. 215 North Marengo Avenue, 3 rd Floor Pasadena, CA 91101-1504

Beverly Grossman Palmer STRUMWASSER & WOOCHER LLP 10940 Wilshire Boulevard, Suite 2000 Los Angeles, California 90024

Email: [email protected] Email: [email protected] Telephone: (213) 978-8231, 213/978-8106 Facsimile: (213) 978-8090

E-mail: [email protected]

Email: [email protected] Phone: 626/449-4200 Facsimile No.: (626) 449-4205

E-mail: bpalmer strumwooch.com Telephone: (310) 576-1233 Facsimile: (310) 319-0156

Angel Law Frank P. Angel, Esq. Jessica Cheng, Esq. 2601 Ocean Park Boulevard, Suite 205 Santa Monica, CA 90405

Attys for Savehollywoodorg, a Calif Corp Email: [email protected] Email: [email protected]

Michael Bostrom, Esq. Siegmund Shyu, Deputy City Attorney 200 North Main Street, 701 City Hall East Los Angeles, California 90012-4131

Edward Klein, Esq. Liner LLP 1100 Glendon Avenue, 14th Floor Los Angeles, CA 90024-3503

Robert P. Silverstein, Esq. 215 North Marengo Avenue, 3 rd Floor Pasadena, CA 91101-1504

Beverly Grossman Palmer STRUMWASSER & WOOCHER LLP 10940 Wilshire Boulevard, Suite 2000 Los Angeles, California 90024

Email: [email protected] Email: [email protected] Telephone: (213) 978-8231, 213/978-8106 Facsimile: (213) 978-8090

E-mail: [email protected]

Email: [email protected] Phone: 626/449-4200 Facsimile No.: (626) 449-4205

E-mail: bpalmer strumwooch.com Telephone: (310) 576-1233 Facsimile: (310) 319-0156

Angel Law Frank P. Angel, Esq. Jessica Cheng, Esq. 2601 Ocean Park Boulevard, Suite 205 Santa Monica, CA 90405

Attys for Savehollywoodorg, a Calif Corp Email: [email protected] Email: [email protected]

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