Timely response requested, by Tuesday, September 8, 2009
RE: Alleged material violations of the law by CFC, and later Bryan Cave under
the name of BoA in Samaan v Zernik (SC087400) at the LA Superior Court*
Dear Officer, Director, or Independent Auditor:
This letter is addressed to you as one of the individuals who hold the duty to
safeguard the integrity of operations at BoA. Integrity of operations of U.S. financial
institutions today are more important than ever before. However, the past two years
generated challenges to the integrity of operations the like of which have never been
encountered by BoA before.
It is exactly for that reason that it is critical for BoA “to do the right thing”. Requests
that are elaborated in the attached papers, are elementary, but they make a clear
distinction between right and wrong. During the past two years, in Los Angeles,
deceitful court proceedings were conducted, which were initiated by CFC, but
lingered under the BoA name, where Bryan Cave, LLP continued to appear,
claiming to be counsel of record for BoA, which it was not. It also falsely selfdesignated
as “Non Party” for the past 2 years – while the court interchangeably
designated it “Plaintiff”, “Defendant”, “Intervenor”, “Real Party in Interest” and other
designations, with no legal foundation at all.
Request is that BoA respect the rights of the residents of LA County, CA, and that it
prohibit conduct in LA that it would never have allowed in Charlotte, NC, since it
violated both the BoA Code of Ethics1 and the BoA Outside Counsel Procedures. 2
Otherwise, it is requested that BoA state who is assigned to communicate with Dr
Zernik on this matter, and have the Audit Committee review the CFC involvement in
this case, claimed to have been material violation of the law: It directly involved
Mozilo and Samuels and the CFC Legal Department. It is alleged to have involved
the production of hundreds of pages of false banking records, a full set of false
declarations and the fabrication of loan underwriting histories. Such efforts were all
for the cause of perpetrating real estate fraud on Dr Joseph Zernik, who had no
business with CFC whatsoever.
This letter is also copied to others who concern themselves with the integrity of BoA
during these trying times, from analysts, to the Basel Committee, the NY District
Court, U.S. Congressional Committees, and last but not least - the Charlotte
Observer.
Trusting that you “do the right thing”,
___/s/______
Joseph Zernik
1 http://inproperinla.com/00-00-00-bank-of-america-00_09-08-22-bac_code-of-ethics-cover-text-a.pdf
2 http://inproperinla.com/00-00-00-bank-of-america-08-12-20-outside-counsel-procedures-s.pdf
A copy of the complete letter can be viewed at:
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