09-10-25 More on Judge Jacqueline Connor, former Officer Rafael Perez, the Rampart scandal (1998-2000), FBI, and US Dept of Justice

LA-JR - from Rampart scandal (1998-2000) through Consent Decree (2001-2009) and beyond...

With federal agencies as patrons, sky is the limit...

RAFAEL PEREZ JACQUELINE CONNOR

Former LAPD Officer Judge, LA Superior Court. Key LA-JR figure

ALEJANDRO MAYORKAS

U.S. Attorney for Central California

(1998-2001)

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Open Questions:

1. Why was the Rampart scandal investigation left under Los Angeles District Attorney (part of the State system) and not removed to Federal agencies, as it should have been? It was the largest public corruption investigation in the history of the U.S.

2. Why was the investigation allowed to be concluded with no final report?

3. Why was there no effort on the part of Federal agencies to release the thousands of victims, the Rampart-FIPs?

4. Why are Federal agencies patronizing the LA-JR at a cost to the treasury so far of about $1 trillion?

5. Why are Federal agencies refusing to comply with ratified International Law:

• Fail to provide Equal Protection under the Law, as required by International Law.
• Fail to maintain Competent National Tribunals for the Protection of (a) Human Rights per international Law and (b) rights pursuant to the Constitution of this Country and its Amendments, as required by International Law,
• Fail to protect the Human Rights of the 10 millions who reside in LA County, as required by International Law,
• Allow residents of LA County to be subjected to the LA-JR

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JACQUELINE CONNOR

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THE RAMPART SCANDAL (1998-2000)

Judge of the Superior Court of California, County of Los Angeles, alleged as a key figure in the LA-JR (Alleged LA-Judiciary Racket).

· Started her career at the District Attorney’s Office.

· Was recognized as “tough on crime”.

· Was recognized as particularly close to RAFAEL PEREZ and other police from the Rampart Division of the LAPD.

· Such police had a reputation of lawlessness even before the onset of the Rampart scandal (1998-2000).

· Such officers often appeared in Judge JACQUELINE CONNOR’s courtroom as witnesses in criminal litigations.

· Such witnesses led to convictions of suspects and their sentencing to long prison terms.

· Later during the Rampart-scandal investigation, it was concluded that a large group of police officers from the Rampart Division engaged in routine framing of evidence, extraction of false confessions through torture, and appearances as false witnesses to falsely convict and falsely sentence a large number of suspect the Rampart-FIPs (Falsely Imprisoned Persons).

· RAFAEL PEREZ later told investigators that all such testimonies were fabricated. The suspects were framed.

· Such framings were the core of the Rampart-scandal.

· A couple of years prior to the scandal, Judge JACQUELINE CONNOR provided RAFAEL PEREZ with a glowing recombination letter, referring specifically to his performance in appearances as witness before her.

· After the eruption of the Rampart Scandal and after Rafael Perez signed a plea bargain, Judge JACQUELINE CONNOR appeared in a public functions where his family were seated in the audience. He was jailed. From the podium she made comments that were quoted in newspapers. Reading the comments today, they sound like a warning to RAFAEL PEREZ not to cooperate with the District Attorney investigators. These comments were said to raise eyebrows already then.

· Why would a judge object to a corrupt police deciding to cooperate with investigators?

· Later when the Fist Rampart Trial stated, she appeared as the Presiding Judge for the case. At that time newspapers were still reporting… and they express their amazement at the assignment. It was clear that the litigation involved directly conduct that took place in her courtroom.

· A report of interview with the Presiding Judge of the Court stated at the end that he got no response when repeating the question how could such assignment be considered reasonable, except that the Presiding Judge of the Court repeated each time: She is a very proper person.

· During the litigation newspaper reported that she appeared biased towards the Defense. Normally she was known to be the opposite.

· She ruled to exclude most of the Prosecution evidence, a ruling that appeared to observers uniquely biased. Some predicted then, that she managed to derail the trial, and that the jury would like find “not guilty”.

· At the end the jury surprised the observers, and convicted three of the four police on trial.

· On December 22, 2000, in the evening, from home, she ruled to void the trial. The ruling was described in media as ”unprecedented”. Others found only room for praise – how often would you find a judge admitting an error?

· It is not clear what her standing in the LA-JR was prior to the First Rampart Trial, but there is no doubt that after it, she was a central figure. Not only was she smarter than most of them ( let’s admit it – she was by far the smartest of any that I met), but on top, she had the gut to stay in the kitchen, when it got really hot.

· Then again – others say – she was the one who had to most to lose – therefore – she had to stay in the kitchen.

Anecdotes:

· Re: “errors”, I claim that after review of her performance in the civil court in Samaan v Zernik a reasonable person would be hard pressed to accept any error by Judge JACQUELINE CONNOR as naïve. Instead, the errors would be recognized as her signature con method, which is rather sophisticated.

· Just as a primer on errors by Judge JACQUELINE CONNOR: on her first ever appearance in Samaan v Zernik she presided over hearing of a demurrer pursuant to Statute of Frauds. At that time she was herself launching a statute of frauds fraud.

· In cataloging frauds, I designate Statute of Frauds Fraud in the category of Overarching. It took almost 2 years from start to finish, in contrast with Short Term, or Intermediate. Planning and executing an Overarching Fraud, I consider also a trademark of a Pro. Most guys are built for the Short Term frauds only. It requires character, planning, troubleshooting… confidence, experience…

· The records found for the demurrer showed that she in “error” generated records for the demurrer that day that included: “OVERRULED”, “GRANTED”, and “DISPOSED”, simultaneously. Well – the DISPOSE was a must, the OVERRULED was for the paper file, and the GRANTED was in case of Petition to the court of appeals? Or maybe just for fun…

· On the same date she also issued in “error” a fake assignment Order that was three months back-dated, under the name of Linda Lefkowitz.

· And to top it off – she ran on the same day an “off the record” Initial Case Conference, which is of course a must in any ET (Enterprise Track) case, but good practice is not to have Initial Caes Conference in any case, just for a good measure

· SI was once trying to count how many frauds she was running simultaneoulsly in early July 2007 in my case alone... I believe I got to 10 or something aroudn that. But then again - maybe I never figured out some of them...

· Sometimes she tries to have an act with the Clerk- Vivian Jaime, but it really does not fly... Jaime is not into the performing arts... Maybe she could train, basically - she needs a sidekick...

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RAFAEL PEREZ

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THE RAMPART SCANDAL (1998-2000)

Former undercover narcotics Police Officer of the Rampart Division of the LAPD.

· Judge JACQUELINE CONNOR was recognized as particularly close to him and other police from that division.

· Such police had a reputation of lawlessness even before the onset of the Rampart scandal (1998-2000).

· Such officers often appeared in Judge JACQUELINE CONNOR’s courtroom and provided testimonies in criminal litigations – to convict suspects and sentence them for long prison terms – the RAMPART-FIPs (Falsely Imprisoned Persons).

· RAFAEL PEREZ later told investigators that all such testimonies were fabricated. The suspects were framed.

· Such framings were the core of the Rampart-scandal.

· A couple of years prior to the scandal, Judge JACQUELINE CONNOR provided RAFAEL PEREZ with a glowing recombination letter, referring specifically to his performance in appearances as witness before her.

· After the eruption of the Rampart Scandal and after Rafael Perez signed a plea bargain, Judge JACQUELINE CONNOR appeared in a public functions where his family were seated in the audience. He was jailed. From the podium she made comments that were quoted in newspapers. Reading the comments today, they sound like a warning to RAFAEL PEREZ not to cooperate with the District Attorney investigators. These comments were said to raise eyebrows already then.

· Why would a judge object to a corrupt police deciding to cooperate with investigators?

· Later when the Fist Rampart Trial stated, she appeared as the Presiding Judge for the case. At that time newspapers were still reporting… and they express their amazement at the assignment. It was clear that the litigation involved directly conduct that took place in her courtroom.

· Rafael Perez was scheduled to take the stand in the first Rampart Trial. But that was surely undesirable. Well, then his girlfriend was first arrested and held as some kind of threat against him. Then she was purported to tell investigators that he killed someone and buried the body some place. And it happened right on time for his time to take the stand – and his attorney had to advise him not to do that, so that he would not be asked about the murder issue and incriminate himself.. Later it turned out that there was no murder to start out. But it worked like a charm… and the Trial ended without his taking the stand.

· Of course – a question of interest is what he told or did not tell the District Attorney regarding the LA-JR.

· My bet is that he did tell them something, in disregard of the warning he got from Judge CONNOR in her comments in the public function. Accordingly, he later suffered retribution. The interesting thing to examine, is how such retribution was meted. He was subjected to the “Federal option” – criminal Federal prosecution that both he and his attorney later claimed they were misled to believe was part of the plea bargain. It was later determined to not be the case, and Rafael Perez was convicted and served time also in Federal prison.

· In contrast – although some discussion was heard of the “Federal option” relative to the four police who were the Defendants in the First Rampart Trial (2000) derailed by Judge CONNOR, it was never applied to them,

· More over, one may reasonably state that at the bottom line the Defendants of the First Rampart Trial (2000) should consider their decision not to cooperate with investigators a prudent one – they collected an award of $15 millions through the courts, which was subjected to final review by the 9^th District Court of Appeals.

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U.S. Dept of JUSTICE, FBI

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The Rampart Scandal (1998-2000)

A. Appearances of Non-Engagement

Purportedly - Federal agencies left it to State of California agencies to work out the case. Therefore, the investigation and prosecution were under the charge of California Department of Justice, Los Angeles County District Attorney, with the end result of prosecution at the LA Superior Court, what came to be known as the First Rampart Trial (2000), where Judge JACQUELINE CONNOR appeared as Presiding Judge. The trial was derailed, and with that - an end came to the prosecutions of the Rampart scandal culprits, and also an end to any attempt to release the thousands of victims.

The Blue Ribbon Review Panel Report (2006) reviewed such events, and concluded that LA County Justice system could not investigate itself, prosecute itself, and adjudicate itself. It recommended an "Outside Investigation". However, one can argue that even from the perspective of 1998, or 1999, or 2000 - years during which Mayorkas was key decision maker for the U.S. Dept of Justice on the matter - it was clear that the scope of the corruption was such that required removal of the investigation from State to Federal Jurisdiction:

• It was the biggest corruption investigation in the history of the U.S. with 200 investigators assigned to it for 2 years.
• In the year 2000, Prof Erwin Chemerinsky described it as the worst abuse of Civil Rights by police in the history of the U.S. He also characterized it as typical of "police states and most repressive regimes".
• The Blue Ribbon Review Panel Report (2006) concluded that the investigation was deliberately restricted to prevent it from exposing the full scope of the corruption, which was much wider than represented in any of the available reports.

The Blue Ribbon Review Panel Report (2006) also explained at the outset the reason that it was commissioned in 2003: When LAPD Chief Bratton assumed his position, he was expected to lead the LAPD out of the scandal and to implement measures that reflect lessons learned from the scandal. However, there was no Report issued at the end of the Rampart scandal investigation. The Panel in its Report explains that it refused to issue such report, since it concluded that the investigation, massive as it was, was a failure, and the Panel concluded that we did not know the basic facts about the scandal yet.

B. Involvement in Cover Up

1. Rewards and Punishments

a. Although "The Federal Option" was discussed at the time in media as a likely way to resolve the outrage after the derailing of the First Rampart Trial, it was never applied to the 4 police who were charged with corruption in that prosecution.

b. "The Federal Option" was applied on RAFAEL PEREZ - after he signed a plea bargain with the District Attorney, but was presumably wanred by Judge JACQUELINE CONNOR not to cooperate with the investigation.

2. Consent Decree

a. The Consent Decree (2001) was framed on an artificially narrow basis:

ALEJANDRO MAYORKAS lead the U.S. prosecution and drafted the Consent Deceree, entered in July 2001 in U.S. v City of LA et al at the U.S. District Court, LA. For reasons that were never explored, the Consent Decree was framed only under the section of the code that pertains to the abuse of rights of juveniles under the color of law (42 USC § 14141), and omitted the section that pertains to abuse of rights of others, such as adults under the color of law (42 USC §1983 ).

The section used as foundation for the consent decree, 42 USC § 14141, states:

(a) Unlawful conduct

It shall be unlawful for any governmental authority, or any agent thereof, or any person acting on behalf of a governmental authority, to engage in a pattern or practice of conduct by law enforcement officers or by officials or employees of any governmental agency with responsibility for the administration of juvenile justice or the incarceration of juveniles that deprives persons of rights, privileges, or immunities secured or protected by the Constitution or laws of the United States.

(b) Civil action by Attorney General

Whenever the Attorney General has reasonable cause to believe that a violation of paragraph (1) [1] has occurred, the Attorney General, for or in the name of the United States, may in a civil action obtain appropriate equitable and declaratory relief to eliminate the pattern or practice.

b. The Overseer for Civil Rights pursuant to the Consent Decree (2001-2009) had limited effect.

There is no doubt that the LAPD under Chief Bratton made substantial efforts, as reviewed in the Blue Ribbon Review Panel Report (2006), and achieved substantial progress, and such efforts were facilitated by the mandate of the Consent Decree, which forced the city to provide the means for such efforts. However, reviewing the effect of the Overseer as such, one may conclude that the effect of the office was limited. Key provisions in the Consent Decreee were never implemented, as far as could be determined today. Primarily - the key provision of periodic financial disclosures by undercover narcotic officers such as RAFAEL PEREZ, was never implemented. One should note that in the early 2000's several such Overseers for Civil Rights were appointed by the Bush administration, including one for the Detainees at Guantanamo Bay, and another one - for the healthcare of Prisoners in California. In all three cases, in retrospect, one may conclude that the appointment of Overseers was more of a Public Relations action that one that was intended, or resulted in improvement in the underlying matters.

One may wonder or at least entertain the doubt that factors foreign to the furtherance of justice were involved in the decision not to remove the investigation from State to U.S.

3. Rampart-FIPs

No Federal agency made any attempt to release the victims.

In a pone call and letter to the Consent Decree Bureau in 2008, towards the end of the tenure f the Overseer, staff had no idea of any attempt past or present to release the FIPs, and the letter remained unanswered.

B. Patronizing LA-JR

1. All conduct of Federal agencies listed above is consistent with patronizing the LA-JR.

2. An unusual e-mail note from veteran FBI agent JAMES WEDICK in August 2008, explains the refusal of FBI to investigate real estate fraud by the LA-JR, as related to FBI refusal to investigate the judges of the LA Superior Court.

3. STEVE GOLDMAN, Chief of the White Collar Crime Squad of FBI, in fact attempted to induce this writer to file a complaint where the role of judges was not mentions. This writer considered any filing of declaration under penalty of perjury, where the most pertinent facts were to be avoided, as a major liability, and as of little chance of success.

4. Responses of KENNETH KAISER and KENNETH MELSON to congressional inquiries regarding the refusal of FBI and US Dept of Justice to investigate, must be found as fraud upon review by a competent court. There is no reasonable explanation for such official letters other than patronizing the LA-JR.

5. Refusal to engage in the current situation. In the face of overwhelming evidence. FBI never engaged in the current situation.

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Early Life: Born in Havana, Cuba, Alejandro "Ali" Mayorkas' family fled from the country in 1960 when Mayorkas was barely a year old. The family entered the United States as refugees and settled in California. In his testimony before the Judiciary Committee, Mayorkas shared how significant this move was for his family:

"My father lost the country of his birth, and my mother, for the second time in her young life, was forced to flee a country she considered home. But our flight to security gave us the gift of this wonderful new homeland. I know how very fortunate I am."

Career:Mayorkas served as an Assistant U.S. Attorney for the Central District of California from 1989 to 1998. During this time, he served as Chief of the Office's General Crimes Section, where he trained and mentored Assistant U.S. Attorney new hires.From 1998 until 2001, Mr. Mayorkas was the United States Attorney for the Central District of California. At 39 years old, Mayorkas was the youngest U.S. Attorney in the nation at that time. From 2001 until his USCIS appointment, Mr. Mayorkas had been a partner with the law firm of O'Melveny & Myers. Mayorkas holds a J.D. from Loyola Law School and a B.A. from the University of California at Berkeley.

USCIS Director: Nominated by President Barack Obama on April 24, 2009 and unanimously confirmed on August 7th by the Senate, Mayorkas was sworn in as USCIS' third director on August 12, 2009. Mayorkas accepted the appointment, saying:

"The USCIS mission is rooted in the vision of our founding fathers. My family, like millions of others, came to this country to pursue our dreams in a land of liberty and opportunity. I am committed to administering our country’s immigration and naturalization laws efficiently and with fairness, honesty, and integrity."

Personal: Mayorkas was named as one of the "50 Most Influential Minority Lawyers in America" in 2008 by the National Law Journal. He serves on the Board of Directors of Bet Tzedek Legal Services, a non-profit organization dedicated to providing the disadvantaged with access to justice. He also serves on the Board of Directors of United Friends of the Children, a non-profit organization devoted to the well-being of foster youth in Los Angeles County. Mayorkas and wife Tanya have two young daughters, Giselle and Amelia.

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ALEJANDRO MAYORKAS was the key person in this regard, as U.S. Attorney for Central California (The Federal Central District of California includes Los Angeles) at the time. Of interest in his resume above, is his service at Bet Tzedek. The man who was in charge of U.S. Department of Justice operation in Central California 1998-2001, was listed by 2007, as President Elect of BET TZEDEK, where he was to succeed:

a) Atty SANDOR SAMUELS - Associate General Counsel of Bank of America Corporation, formerly Chief Legal Officer of Countrywide Financial Corporation, a key figure in organized crime - and

b) Atty DAVID PASTERNAK - an attorney who was opined by highly decorated FBI veteran JAMES WEDICK as the perpetrator of Fraud Grant Deeds, likewise, he was evidenced to engage in racketeering at the LA Superior Courts in collusion with Judge JOHN SEGAL in Samaan v Zernik and Galdjie v Darwish, and under whose name numerous defective Grant Deeds were found in the office of Los Angeles County Registrar/Recorder, issued on behalf of the courts, and demonstrating at least some of the features that led JAMES WEDICK to opine fraud in re: Grant Deeds in Samaan v Zerni. In a phone call in 2007 Atty Mayorkas denied that he was President Elect, and indeed he never succeeded Samuels.

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09-10-25 THE BRANDEIS BRIEF & THE PROSPECT OF RICO INDICTMENTS AT THE LA SUPERIOR COURT

A. Alleged Racketeering at theLA Superior Court, and the use of Brandeis Brief type arguments in RICO prosecution...

The Brandeis Brief avoided arguments based on legal theories. Instead - Louis Brandeis used health statistics and pure statistical arguments to conclude the destructive effects of sweatshop work practices on workers health.

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Obviously, I am not an attorney, not even by a long shot, therefore, I do not know the law. However, I do know a bit of statistics... and therefore - my fondness for the Brandeis Brief...With that, in discussing racketeering, one must recall the four basic elements stated in the law as required for adjudication, which were continuously reshaped by decisions of the U.S. Supreme Court.

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B. Racketeer Influenced & Corrupt Organizations Act (RICO) 18 USC § 1961–8

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RICO was written in broad terms. To state a claim, a plaintiff must allege four elements: (1) conduct (2) of an enterprise (3) through a pattern (4) of racketeering activity.[1] Each element of a RICO claim requires additional analysis: an “enterprise” is marked by association and control; a “pattern” requires a showing of “continuity”—continuous and related behavior that amounts to, or poses a threat of, continued criminal violations; and “racketeering activity” involves the violation of designated federal laws.[2]

In addition, a civil RICO litigation plaintiff must allege that he was injured in his business or property “by reason of” a violation of RICO’s substantive provisions.[3] This “by reason of” language provides the basis for the proximate cause requirement, established by the Supreme Court in Holmes and amplified in Anza [4]and Mohawk Indus [5].

[1] See Kenda Corp. v. Pot O’Gold Money Leagues, Inc., 329 F.3d 216, 233 (1st Cir. 2003).

[2] See Giulliano v. Fulton, 399 F.3d 381, 388 (1st Cir. 2005).

[3] 18 USC § 1964(c).

[4] Anza v. Ideal Steel Supply Corp., 2006 DJDAR 6857 (June 5, 2006)

[5] Mohawk Indus., Inc. v. Williams126 S. Ct. 2016 (2006).

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Fortunately, one can also find today Prosecutor's Handbook and Prosecutor's Workbooks for organizing RICO evidence and RICO Briefs. Therefore, even a layperson could get some idea of what it takes to indict and prosecute on RICO charges. With all that - It appears that there is high likelihood that a professional prosecutor, upon review of such cases and such evidence as is now available against judges of the LA Superior Court, would find the LA Superior Court and its judges a case that has merit, and high public policy interest in immediate investigation and prosecution. In that respect, there is no doubt that Att RICHARD FINE's insistence on his principles, and the advertising that he generated for alleged corruption at the LA Superior Court, already generated substantial results, connections were formed, and more victims came forward than ever before...

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After all, the stated policy of FBI, announced most recently in December 2008, in New York, in relationship to the indictment of a former NY State Supreme Court Justice Spargo was as follows:

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"This case should demonstrate that the FBI will pursue all allegations of judicial corruption vigorously, as public corruption violations are among the most serious of all criminal conduct and can tear at the fabric of a democratic society".

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No reasonable honest person would challenge that statement...

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In discussing the issue with attorneys, one who claimed to study RICO under a professor who helped draft the law, stated with full confidence that by law, RICO could never be applied against judges or any government agency. That was of course untrue.

Judge Richard LeFevour was sentenced to twelve

years in prison for his role in the Greylord scandal,

which revealed corruption within Cook County's

court system. He was convicted of taking thousands

of dollars in bribes to fix traffic cases. (Tribune

photo by Frank Hanes)

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Judges were indicted and prosecuted pursuant to RICO both in San Diego - Robert Aguilar - former Presiding Judge of the U.S.District Court, and and in San Diego, California - two former San Diego California State judges - G. Dennis Adams and James Malkus, and a prominent lawyer were indicted of federal racketeering and mail fraud, while the former Presiding Judge entered a plea bargain.

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Judges and attorneys were indicted and prosecuted per RICO also in Cook County (Chicago) Illinois - in Operation Greylord. A total of 92 people were indicted, including 17 judges, 48 lawyers, ten deputy sheriffs, eight policemen, eight court officials, and a member of the Illinois Legislature. Most recently - in Pennsylvania, two judges were indicted per RICO in relationship to false convictions of juveniles for kickbacks from juvenile hall.

And even here, in Los Angeles, in the wake of the Rampart scandal, U.S. District Court, LA, allowed civil RICO litigations against police. In fact, the larger claim underlying the case of Atty RICHARD FINE and all the rest of them - is that the Rampart scandal involved the court to no lesser degree than the LAPD. However, in absurd that is documented in detail by now, Judge JACQUELINE CONNOR, who is alleged as one of the Central figures of the LA-JR, presided in the First Rampart Trial (2000),. In fact, derailing that trial is probably what she is best known for. When you read the reports from the period, knowing what you know today, you must wonder about the role that she played in the Rampart-scandal and the false convictions and sentencing in that case.

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C. Applying a Brandeis Brief in Marina v LA County to argue racketeering by JOSHUA ROSEN, on behalf of DEL REY VENTURE, and DEL REY VENTURE NORTH, by Judge DAVID YAFFE, Deputy Clerk CONNIE HUDSON, and Clerk of the Court JOHN A CLARKE - Beyond reasonable Doubt.

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Each of the 8 papers with the defective or non-existent Proofs of Service, was filed by either an experienced licensed attorney, or by a Judge, and was reviewed by a Deputy-Clerk of the LA Superior Court. Some of these papers were later the foundation for other papers, and one must assume that they were then reviewed again. Some of these papers were then filed with a secondary court, and surely had to be reviewed again by Deputy-Clerks, and Law Clerks, and Judges... However, here, we examine only the initial review at the time of filing.

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Initially, attempt would be made to assess the situation based on my personal experience, but comments would be most welcome: My chance to file a paper with no POS, or with mismatched dates of POS and the paper, or title of the paper and the POS was close to none... Zilch. Nada. The clerks were no lawyers, and therefore, and they never tried to assess my arguments when I came to file papers in court. They would engage mostly in inspection of the paper On Its Face - First the cover page - did I list the correct caption, did I list the correct department and date of a hearing, did I list the correct party designations... Second - once they inspected the cover page, they would immediately flip to the two pages with signatures - the brief and the declaration, to inspect that they were original "wet" signatures in my name, Thirs - from there they would flip straight to the POS - to check the title, date, and signature on it.

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I never tried to file with no POS, but it would be sufficient to present to the clerk the copy instead of the original of the POS, where the signature was not "wet" - to have a paper denied filing. In short - my chance to get away with such defects was infinitesimally small. But for argument sake, let's assume that the average chance was 1:10... That is - if a person tried 10 times, that person would be able to get away with it once, or if 10 different persons tried, only one would accomplish the task.

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And as for the chance of pulling it off, eight (8) times in a row... It's 1:10E8, or 1:10x10x10x10x10x10x10x10, which is the same as 1:100,000,000, or one in one hundred millions. I'd argue - that is Beyond Reasonable Doubt. Please be reminded that the odds of pulling off after that the filing by attorney who was not attorney of record, of false record in the U.S. Court - by Atty KEVIN MCCORMICK, which compounded the odds, was not at all accounted for. I would argue that on statistics alone, racketeering could be proven relative to conduct of the parties listed above.

Some of the case that RICO was prosecuted over the years involved reliance on Mail Fraud or on Deprivation of the Implied Rights for Honest Services as Predicated Acts. Some criticism was raised regarding overuse of such claims by public prosecutors. That is not the case here. The claims are of a textbook racket... Of course there was alleged mailfraud anytime notices were mailed out. But even without that you could find here plenty of predicated acts of various kinds.

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D. Application of a Brandeis Brief in Samaan v Zernik to argue racketeering by Atty JOHN AMBERG, Atty JENNA MOLDAWSKY (Bryan Cave, LLP) Country Financail Corporation (CFC), Bank of America Corporation (BAC), SANDOR SAMUELS - Associate General Counsel,BAC, Judge JACQUELINE CONNOR, Judge JOHN SEGAL, Judge TERRY FRIEDMAN, and Clerk of the Court - JOHN A CLARKE - Beyond Reasonable Doubt.

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In Samaan v Zernik (SC087400) CFC, and later BAC appeared in court easily 20 times, and they may appear additional times in the near future... In all these instances, they filed papers under the invalid party designation "Non Party", while the court designated it interchangeably "Defendant", "Plaintiff", "Cross Defendant", "Real Parties in Interest", "Intervenor", and more... I actually asked the Clerk once, for an explanation for this discrepancy, why the court constantly changes the party designations of Countrywide/Bank of America.... He was honest enough to tell me the reason: When entering the the party designations, he had to choose a party designation from the menu offered to him by Sustain, the case management system... and "Non Party" was not one of them, since it was a fictitious party designation... Therefore, each time selected a different party designation from the menu to file the Countrywide/ Bank of America papers...

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OK, let's look at it... what would be my chance to file a paper under party designation "Swamp-fox", or "Cat-bird", and have the Clerk knowingly choose a different party designation to enter it under... and get away with it... I never tried it, but I would say... NO CHANCE IN A LIFETIME... For argument sake, let's assume that the average chance was 1:10... That is - if a person tried 10 times, that person would be able to get away with it once, or if 10 different persons tried, only one would accomplish the task.

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And as for the chance of pulling it off, twenty (20) times in a row...It's 1:10E20, or 1:10x10x10x10x10x10x10x10x10x10x10x10x10x10x10x10x10x10x10x10, which is the same as 100,000,000,000,000,000,000, or one in one hundred million millions. I forgot the name for a million millions. Regardless, I'd argue - that is Beyond Reasonable Doubt. Please be reminded that the odds would be even smaller, since here again, we had attorneys who were not Counsel of Records falsely filing as Counsel of Record, and we had all executable orders filed with no POS, or mismatched dates of POS..., all the fingerprints of the LA-JR...and all of which would compound the odds, but were not at all accounted for...I would argue that on statistics alone, racketeering could be proven relative to conduct of the parties listed above.

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E. How do these cases compare?

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I was asked at times to compare the racket that I allege in the LA Superior Court to the precedents. However, once you start reading and studying these cases, you realize that there is much more to them than was published, both prior to indictment and after indictment. Typically, there are many more people involved in various levels than the number of people that are eventually indicted. Moreover, it is often the leaders of the racket that get away with plea bargains... for various reasons,,,

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With all these disclaimers stated once could grade the cases relative to the scope of corruption as follows:

1) San Jose, California - only one judge indicted, and it was not clear that any other judge was involved.

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2) Pennsylvania - the recent case in Pennsylvania is stunning in its criminality - false convictions and sentencing of juveniles for cash. However, one should recall that similar situations were part of the Rampart scandal. They are difficult to find in the written reports. However, one must notice that the Consent Decree was framed around Deprivation of Civil Rights- of Juveniles - under the Color of Law, not the standard Deprivation of Rights under the Color of Law (42 USC § 14141 and 42 USC §1983, respectively). The difference between Pennsylvania and California, though, is that in Pennsylvania panels were immediately instituted to initiate corrective action. IN California - the Rampart FIPs are still falsely imprisoned...

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3) San Diego, California - Many more were involved than the two judges who were indicted, The Presiding Judge, who ran the operation, for example, was the one who signed the plea bargain...

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4) Cook County, Illinois - in Cook County, we move to the National League, here there was a large number of judge and other personnel involved. They streamlined anything from Parking Tickets to Capital Cases.

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5) Los Angeles County, California- the case in Los Angeles Califonia would be described as "New Vistas in Corruption":

a) The main difference - it relied on computers. Therefore, it was at a much higher level of sophistication, much more elaborate, included more people...

b) The biggest difference is that all the alleged crimes were registered in court records... There is no need and there would be no need for any uncover sting operation. The LA Superior Court is hiding the dockets for the past 25 years for a reason - they read as uncatalogued of alleged criminalities. Line by line. For example - the conduct of Judge JOHN SEGAL and all those who colluded with him in Galdjie v Darwish I did need to interview BARBARA DARWISH to figure out the scope of the alleged criminality. However, even if I never managed to meet her - there was no way to explain that docket (Register of Actions) as based on honest conduct of the judiciary... in that case alone, there were probably a dozen judges involved...

c) The true story of the Rampart Scandal will finally be exposed once and for all...

d) It would also I believe be the first ever prosecution of a network based Organize Crime - loosely organized white collar crime.

e) It involved large corporations, including Countrywide and Bank of America.

f) In short - it is a humongous affair compared to anything ever dealt with in the U.S.

Here too - Atty RICHARD FINE must be remembered - because it would be his case that would not allow the FBI and U.S. Dept of Justice to continue the cover up. He could leave his jail any day, but submitting to alleged corrupt Judge DAVID YAFEE and Commissioner MURRAY GROSS. However, he protested by not getting out of jail, but sticking it out.