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SIXTEENTH CODE 67

CAUSE OF ACTION AND CHARGES:

VIOLATION Conway

OF PENAL stating
THEM,

&

68, OFFERING,
"I

&

TAKING A BRIBE. Attorney

CASE
GO AWAY,

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to Plaintiff:
AND THEY IN

CAN MAKE THIS

YOU FORGET ABOUT

TURN FORGET ABOUT

YOU" As Attorney

Conway was forcing Conway says

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me to accept to me:

the Injunction,

after I refused Attorney

"THEY HATE YOU WITH A VENGANCE AND SEEK

REVENGE".

For proof, 13, 2009, on court "HE

ORDER"

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See Reporter and April

Transcripts

of February

4, 2009, the January

13, 2009. Please take note of ALL the statements of Attorney

DID

record and confession

Sam R. Paz as he states:

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FORCED OUR HAND, 12 WE JUST WHAT WE HAD TO DO TO GET THIS

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Sadly, and more the MERITS!

importantly,

this is HOW Sam R. Paz wins cases on and being a corrupt attorney. What and

By lying, cheating,

is more puzzling accepts

to me is, if Ivan Shomer goes into chambers even asking

the deal without

for my input or tells me what into chambers This is

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is going on? I never hired this fool, why is he going

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with Drewry making

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a deal for me without

my permission?

crazy and mad! and almost

In the Paz case the lie was to win a free speech a million dollars. Again, IF, and only IF, Sam Paz
ABSOLUTELY

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states and admits

in court record:

"THERE IS

NO QUESTION

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violate

my rights! How can I lose a case and then be sanctioned dollars? Yet, per Attorney Paz statements, I AM
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almost a million

PLAINTIFF'S

MOTION

& OPPOSITION

TO ILLEGAL ORDER OF 3/28/2012

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THE PREVALING party

PARTY! Let me understand

something,

the prevailing Superior

loses, and the losing party wins! The Los Angeles as some attorneys

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court is a mad house, straight-jackets

should be on Judicial conduct 1n

to restrain

their less than honorable

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court! gative

In fact, a PBS report on SOCAL CONNECTED findings found that the Los Angeles That's

in its investiCourt has the States! ATTORNEYS THE IS TREASON. to of to

Superior

most filings

in the Nation!

the whole United

SEVENTEENTH THAT PAID BRIBES,

CAUSE OF ACTION AND CHARGES:

AGENTS,

OR OFFICERS

OF THE COURT, THAT VIOLATE

11 CONSTITUTION
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OF THE UNITED

STATES DAILY OR CONTINUOSLY,

THE attorneys Defend

are SWORN Officers

of the court, with a pledge

and Protect

the Constitution

of the U.S. and the Rights Their acts amount

the People of the United treason when the purchase

States of America. decisions

from the bench,

and should be

charged with treason!

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EIGHTEENTH
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CAUSE OF ACTION

AND CHARGES:

VIOLATION

OF PENAL TO

CODE 487, GRAND THEFT, USING THE COURT AS A TOOL OR INSTRUMENT STEAL FROM THE PEOPLE OF CALIFORNIA. United enforce citizens States Constitution The 14th Amendment of the

states that: No State shall make or the privileges or immunities any of law; of

any law which shall abridge of the United States;

nor shall any State deprive without due process

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person
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of life, liberty,

or property,

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nor

deny

to

any person

within

its jurisdiction

the equal protection of

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of the laws. IT IS ABUNDANTLY

CLEAR, and with the abundance

PLAINTIFF'S MOTION

& OPPOSITION TO ILLEGAL ORDER OF 3/28/2012

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evidence

already

on Court Record

IN MY CASES, presently THAT ACCEPTED

in the

files, or removed by the Court Clerk's prejudiced ME, and VIOLATE

A BRIBE TO No

MY Constitutional

and Civil Rights. DOES NOT give

one is above the law, no one! The Constitution

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IMMUNITY

to Judges or to those who are sworn to uphold "in the performance

it, but they

break these same laws everyday, sworn duties" a Hearing Shomer, for a bribe.

of their legal Drewry held Ivan

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For Proof, WHEN Commissioner 13, 2009, with Attorney

in Chambers

on January

and On April

13, 2009 with Attorneys

Paz and Conway, the Brown Act Law. by the Court

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Commissioner
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Drewry was violating were rehearsing

and breaking

All the parties Transcripts F. DeVanon February

their lines, as proven example,

of asaid dates. Another states

is WHEN Judge Joseph 26, 2010, and this is and

in Court Transcripts

at the January

22, 2010 the word NEVER,

and "LET ME GET SOME",

solicitation,
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under Penal Code 653(f},

and he was violating In addition, Judge

breaking
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the law and his Oath of Office. at trial on February

DeVanon,

22, 2010 states: was falling

"I DID NOT HEAR THE a sleep in Court; MacCar1ey for a illegally

OBJECTION" Devanon kickback

as Lisa Marie MacCarley

was not neutral

and was helping Attorney of the Property Castaneda.

from the profits

that was seized The exchange

from the Estate of Felicitas

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from the

above was preceded

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by question

for Evelyn Ramirez

as to when Lisa the False to Sonia

Marie MacCarley Declaration

was hired.

It was intended submitted

to prove

of Susana Castaneda

and provided

PLAINTIFF'S

MOTION

& OPPOSITION TO ILLEGAL ORDER OF 3/28/20l2

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Mercado,

which proves

conspiracy!

This proves my Claim,

Complaint

and Charges

that the Declaration

was filed in BC 402096 and BS the Last will and

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118244 by Sonia Mercado Testament of Felicitas

and Sam Paz to challenge Castaneda. by Lisa MacCarley's of a purported

In the Declaration
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provided claimed

client,

Susana ON

Castaneda,

falsely

Uvisit" to a hospital Castaneda.

8 IIJanuary 4, 2008 to see her mother

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Felicitas

At the time,

1) Felicitas Huntington

Castaneda

WAS NOT even hospitalized

as proved by in

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Hospital

Records,

and the fact, and 2) upon testimony she had been absent

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the court by Susana Castaneda,
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since late 2005, placing names

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or the early part of January

2006; after fraudulently

of her kids on title of house at 1377 Rutan Way, which was illegal. Susana successfully stole my mother's house with the assistance of

Lisa MacCarley.

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TO: ALL PARTIES AND THEIR ATTORNEY YOU ARE HEREBY PLACED ON NOTICE

OF RECORD

that on May 15, 2012, at 8:30 a.m.

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PLAINTIFF'S

MOTION

& OPPOSITION

TO ILLEGAL ORDER OF 3/28/2012

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or as soon thereafter Judge, Pursuant

as the matter may be hear in the Presiding

to Cal. Civ. Proc. Section

391.7.

(b) "the

presiding

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Judge shall permi t the filing Mosk Courthouse, California,

of

such li tigation ... " at the Stanley Los Angeles, does move this for all and Rule

located at 111 N. Hill Street, Plaintiff

90012, Also,

will, and hereby

Court for an Order Consolidating

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the following

actions

purposes 3.350

under rule 42 of the Federal

of civil Procedure of Cases:

(a) (1) (A) (B) (C) (2) (A) (B) (C) Consolidation

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Additionally, illegally fraudulent

Plaintiff

moves

this court to Reverse

the Order

signed by Judge on March and manufactured herein.

28, 2012, which was based on that CIVIL

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cases as proven by the Exhibits and PURSUANT TO CALIFORNIA

are enclosed PROCEDURE ORDERED, 13

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Furthermore,

CODE SECTION THE PLAINTIFF

391.4 THAT READS IN PART:

"PRIOR TO BEING NOTICE AND

AT ISSUE MUST HAVE BEEN PROVIDED

AN OPPORTUNITY PROCESS Section

TO BE HEARD IN CONFORMITY Plaintiff moves

WITH HIS OR HER DUE and pursuant to

CIVIL RIGHTS"

this Court,

391.7 (b) "The presiding

Judge may permit

the filing ... " that will be

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at the Hearing

of May 15, 2012: 1) All Parties as evidence

attending

sworn to give testimony will present

in this matter,

2) Defendants

proof that Cases GC 039743 and YS 017992 were filed by Jose Castaneda in this matter. If cases were not Claim and Charges Justice, that the

the Plaintiff,
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filed by Plaintiff,
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this act proves my Complaint,

that the Defendants, wanted to maliciously

and with the Intent to Obstruct Prosecute

me with False Evidence, accepted

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Court, knowingly, Factual

willingly

and wantonly,

as True and

on its face of the Documents

In addition,
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the filings by ALL parties

prove the Conspiracy 1714.10

charge

Pursuant
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to the Code of Civil Procedure Showing

(a) "Reasonable alleging a 2

Probability"

that the Court may allow a pleading

PLAINTIFF'S

MOTION

& OPPOSITION

TO ILLEGAL ORDER OF 3/28/2012

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cause of action attorney's

for an attorney-client to contest

conspiracy,

based on the

attempt

OR COMPROMISE

A CLAIM or dispute, to file a pleading that the

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only after it determines has established

that the party

seeking

that there is a reasonable

probability

party will prevail

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in the action. After the Court of Record having Plaintiff's proposed pleading it

been presented
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with false evidence,

is legally

sufficient

and the evidentiary

showing

to support

makes a Prima Facie Showing, evidence

and will be supported

by sufficient

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to "warrant affirmance

on appeal. [Burstscher v. Burstscher

(1994) 26 Cal. App. 4th 720, 725 - 726, 31 Cal. Rptr. 2d 682; Hung v. Wang (1992) 8 Cal. App. 4th 908, 929 - 930 11 Cal. Rptr. 113 VLS version of statute)]

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(decided under pre-1991 FURTHERMORE:

The pre-filing

Order that this Court of Record has to assist ALL Defendants, "The pre-filing as Order

ignored and removed

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from the Docket

INDEPENDENT requirement

DUTY TO PLAINTIFF

reads in part:

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of Civil Code Section an attorney

1714.10 DOES NOT APPLY

to a cause

of action a~ainst her client, Plaintiff Berger,

for a civil conspiracy

with his or

if the attorney

has an independent 1714.10 (c )i Simon

legal duty to the v.

[Civil Code Section

See, e.g., Shafer

Kahn, Shafton,

Moss, Figler,

&

Gladstone

(2003) 107

Cal App. 4th 54, 84 131 Cal. Rptr. 2d 777 (attorney for insurance company had independent
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legal duty to provide coverage)

policy

claimants

with

TRUTFUL attorney

information

about policy

It is clear, that and wantonly lied to

Jack K. Conway knowingly,

willingly,

Judge Rita Miller's

Court at the May 8, 2009 hearing for the series of intentional I was sanctioned

to escape Judicial

being held accountable Conspiracy dollars.

in the case where stating,

almost a million of perjury by

Conway's

under oath and under penalty

that he had been hired on Feb. 2, Feb. 3 is and was lie, proven the Attorney
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Client

contract

of December

l7, 2008! It is not the "Declaration

acceptable
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that Judge Rita Miller

was accepting

Errata"

of Sonia Mercado

filed on around May 3, 2008, and the

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PLAINTIFF'S

MOTION

& OPPOSITION

TO ILLEGAL ORDER OF 3/28/2012

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testimony attorneys

of Jack Conway as true, but it was a lie! For that both CANNOT be telling the truth because Conway was lying to the truth

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the Court and to the Judge on the bench.

if on December

Who was telling

5, 2008, Conway was present lies to Judge Rita Miller

at the Probate Hearing Court as to when that proves Conway lied

and yet, Conway

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When Conway was retained! and was hired on December

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I have a contract 17, 2008.

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IIMOTION TO CONSOLIDATE

CASES:

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Castaneda v. DeVanon Et Ai GC 047300 05/02/11 Plaintiff: Jose Castaneda ("Castaneda"), Defendant(s): Joseph Frank DeVanon, Lisa Marie MacCarley, Jack K. Conway, Emahn Counts, Charles Love, Ivan Shomer, James R. Felton, & Leon J. Owens Castaneda v Estate Berke Et Ai GC 466737 08/03/11 Plaintiff: Jose Castaneda ("Castaneda"), Defendant(s): Estate of Robert Berke, Richard Sam Paz, Sonia Maria Mercado, Lisa Marie MacCarley, Jack K. Conway, Rita "Sunny" Miller, Comm. Anthony B. Drewery, Sevag Nigoghosian, Note: Joseph F. DeVanon, Rita Miller and Anthony B. Drewry are sued in their individual capacity as traitors of the Constitution!!! ADDITIONAL CASES THAT SHOULD BE CONSOLIDATED MOTION HIDDEN BY COURT: Plaintiff moves this court of record, BUT WERE NOT LISTED IN

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and Pursuant

to Order

issued

by Court on May 28, 2012, that the following 017992 be consolidated

cases GC 039743 and YS

with the cases above, per Federal Rule 42

and State Rule 3.350 Law

MEMORANDUM OF POINTS AND AUTHORITIES JUDGE HICKOK:

1. RULE 42 OF THE CODE OF CIVIL PROCEDURE

AND NEW CASE LAW PER

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~LAIN!lFFrs MOTION

& OPPOSITION TO ILLEGAL ORDER OF 3/28/2012

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{a} Consolidation. If actions before the court involve a common question of law or fact, the court may:

(1) join for hearing

3 "actions;
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or trial any or all matters

at issue in the

{2}

consolidate

the actions; orders

or cost or delay. or to

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{3} issue any other

{b}

to avoid unnecessary

Separate

Trials.

For convenience,

to avoid prejudice,

7 lIexpedite and economize,

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the court may order a separate cross claims, a separate

trial of one or

separate

issues, claims,

counterclaims,

third-party reserve

claims. When ordering

trial, the court must

~py federal right to a jury trial.

suits in admiralty and damages separation for trial of the

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In certain

issues of liability other than damages, conducive statutory

(or of the extent of liability average) because has been of the (which

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such as salvage and general and economy, especially

to expedition

right to interlocutory

appeal

in admiralty While

cases

is of course preserved
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by these Rules).

separation

of issues that it Cf.

for trial is not to be routinely be encouraged Weinstein, where experience Bifurcation

ordered,

it is important its worth.

has demonstrated of Negligence

Routine

Trials,

14 Vand.L.Rev.

831 (1961)
In cases maritime (including some cases within the admiralty and

jurisdiction)

in which the parties

have a constitutional of issues may give

or statutory

right of trial by jury, separation

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to problems. See e.g., United Air Lines, Inc. v. Wiener, 286 F.2d 302 (9th Cir. 1961). Accordingly, the proposed change in Rule the mandate of Rule 38 respecting preservation of the

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42 reiterates

right to jury trial.

"2.

RULE 3.350

OF THE CODE OF CIVIL

PROCEDURE

PLAINTIFF'S

MOTION

& OPPOSITION TO ILLEGAL ORDER OF

3/28/20~2

1 II.ule 3.350.
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Consolidation
of motion of motion

of cases:
must:

(a) Requirements (I) A notice

to consolidate

(A) List all named parties in each case, the names of those who have appeared, and the names of their respective attorneys of record; (B) Contain the captions with the lowest numbered

of all the cases sought to be consolidated, case shown first; and

(C) Be filed in each case sought to be consolidated. (2) The motion to consolidate:

(A) Is deemed a single motion for the purpose of determining the appropriate filing fee, but memorandums, declarations, and other supporting papers must be filed only in the lowest numbered case;

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(B) Must be served on all attorneys of record and all non12 II represented parties in all of the cases sought to be consolidated; and
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(C) Must have a proof of service

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filed as part of the motion. 1, 2007; adopted effective July

(Subd (a) amended

effective

January

1,1999.)
(b) Lead case Unless otherwise provided in the order granting the motion to consolidate, the lowest numbered case in the consolidated case is the lead case. (Subd (b) amended effective January 1, 2007; adopted effective July

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1, 1999.)
(c) Order An order granting or denying all or part of a motion to consolidate must be filed in each case sought to be consolidated. If the motion is granted for all purposes including trial, any subsequent document must be filed only in the lead case. (Subd (c) amended effective January

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I,

2007; adopted

effective

July

I,

1999.)

(d) Caption
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and case number

-------------------------:,2'
PLAINTIFF'S MOTION

& OPPOSITION TO ILLEGAL ORDER OF 3/28/2012

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All documents filed in the consolidated case must include the caption and case number of the lead case, followed by the case numbers of all of the other consolidated cases. (Subd (d) amended effective January I, 2007; adopted effective July

I,

1999.)

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Rule 3.350 amended and renumbered effective January I, 2007; adopted as rule 367 effective January I, 1984; previously amended effective July I, 1999.

IN CONCLUSION: WHEREFORE, an Evidentiary Plaintiff Hearing asks, request, and moves this Court for presented in

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based on the false evidence

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court to violate Bribe;

rights of the People,

that was based on a Judicial the cases as the

and to grant this

"Order to CONSOLIDATE"

law requires.
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DEMAND

FOR CONSOLIDATION The Motion

OF "ALL" CASES THAT THE COURT PROVIDED. "All" the cases used in the to get to the "Whole" and

In

addition, hearing;

to Consolidate

should be granted

as pleaded

"Real" truth will be allowed;

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and stop the lies and the corruption, decision to the

based on a Judicial opposing parties

Bribe to sell courtroom

by presenting

false evidence

and lies.

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REQUESTING

THE COURT TO DO OR GRANT THE FOLLOWING:

for once, and stop using Fictitious Decisions, Evidence to

1) To be honest "Engineered" a Judicial

Purchased

that was "Constructed" Verdict or Decision Attorneys,

to receive

bribe,

and a Purchased

by the court. FBI, and All and an

2) To refer this case to the State District

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appropriate

Law Enforcement

Agencies

for Criminal this "proper"

Charges

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II Investigation,

as your duty demands

action by the

3 PLAINTIFF'S MOTION

& OPPOSITION TO ILLEGAL ORDER OF 3/28/20~2