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GERAGOS f GERAGOS
A PROFESSIONAL CORPORATION LAWYERS HISTORIC ENGINE CO. NO. 28 644 SOUTH FIGUEROA STREET Los ANGELES, CALIFORNIA 9001 7-341 1 TELEPHONE (21 3) 625-3900 FACSIMILE (213) 625-1600 GERAGOS@GERAGOS.COM

MARK J. GERAGOS SBN 108325 Attorneys for RONALD S. CALDERON

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA, SACRAMENTO DIVISION RONALD S. CALDERON, Plaintiff/Petitioner v. UNITED STATES, Defendant/ Respondent NOTICE OF MOTION AND MOTION FOR ORDER TO SHOW CAUSE WHY GOVERNMENT SHOULD NOT BE HELD IN CONTEMPT FOR VIOLATION OF MAGISTRATE JUDGE'S ORDER SEALING FBI AFFADAVIT; MEMORANDUM OF POINTS AND AUTHORITIES; REQUEST FOR SANCTIONS TO BE FILED PUBLICLY NOT TO BE PLACED UNDER SEAL INITIATING DOCUMENT Trial Date: TBD Hearing Date: TBD Time: TBD Place: TBD CASE NO.:

IN RE: CRIMINAL VIOLATION OF COURT ORDER SEALING AFFIDAVIT

-1NOTICE OF MOTION AND MOTION FOR ORDER TO SHOW CAUSE WHY GOVERNMENT SHOULD NOT BE HELD IN CONTEMPT FOR VIOLATION MAGISTRATE JUDGE'S ORDER SEALING FBI AFFADAVIT; MEMORANDUM OF POINTS AND AUTHORITIES; REQUEST FOR SANCTIONS

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TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: PLEASE TAKE NOTICE that on a date and time to be determined by the abovecaptioned Court, located at 501 I Street, Sacramento, California 95814, moving party Senator Ronald S. Calderon will, and hereby does, move this Court for an Order to Show Cause as to why the United States Government, and its agents, should not be held in contempt for illegally leaking an affidavit, sealed pursuant to the orders of the Federal Magistrate Judge of this Honorable Court, to the media in an effort to defame and retaliate against Senator Calderon for not cooperating in its "sting" operation against Senator Darrell Steinberg and Senator Kevin de Leon. PLEASE TAKE FURTHER NOTICE that Senator Ronald S. Calderon will, and herby does, seek all appropriate sanctions against the United States Government, and its agents, for irreparably tainting future grand jury proceedings and causing irreparable harm to Senator Calderon's reputation. This motion is based on this Notice, the accompanying Memorandum of Points and Authorities, the attached exhibits, and such other argument and evidence as may be presented at the hearing on this Motion. DATED: November 13, 2013 GERAG AGOS, APC

By: MAR AGOS Attorneys fo Defendant RONALD S. CALDERON

-2NOTICE OF MOTION AND MOTION FOR ORDER TO SHOW CAUSE WHY GOVERNMENT SHOULD NOT BE HELD IN CONTEMPT FOR VIOLATION MAGISTRATE JUDGE'S ORDER SEALING FBI AFFADAVIT; MEMORANDUM OF POINTS AND AUTHORITIES; REQUEST FOR SANCTIONS

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MEMORANDUM OF POINTS AND AUTHORITIES I. INTRODUCTION Senator Ronald S. Calderon was approached on six separate occasions by high level agents of the Federal Bureau of Investigation and on two occasions by the Assistant United States Attorney for the Central District of California Doug Miller demanding that Senator Calderon participate in a sting operation against Senate President pro Tern Darrel Steinberg. The FBI agents requested that Senator Calderon wear a wire and secretly record his conversations with Senator Steinberg and Senator Kevin de Leon. The FBI was specifically interested in Senator Steinberg's financial activities with Michael Drobot, the former Chief Executive Officer of Pacific Hospital of Long Beach. Senator Calderon refused to continue participating in the FBI's sting operation, and rejected their demands to secretly record conversations with Senator Steinberg and Senator de Leon. Senator Calderon, through the law office of Geragos & Geragos, APC, returned the wire equipment supplied by the FBI to the agents working for United States Attorney's Office for the Central District of California. Attached hereto as Exhibit "A" is a true and correct copy of the "Acknowledgement of Receipt" signed by the FBI for the wireless transmitter-serial number P235, returned by Senator Calderon. Further, on June 4, 2013shortly after Senator Calderon refused the FBI's request to participate in its sting operationthe FBI conducted a raid on Senator Calderon's office. The media was alerted to the raid, as it was taking place, by sources at the FBI working for Assistant United States Attorney-Central District of California (AUSA-CDC). The FBI raid of Senator Calderon's office became a media spectacle with camera crews present for the entire ordeal. The FBI raid was conducted after the FBI presented an affidavit which included numerous false and defamatory allegations about Senator Calderon. The FBI

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-3NOTICE OF MOTION AND MOTION FOR ORDER TO SHOW CAUSE WHY GOVERNMENT SHOULD NOT BE HELD IN CONTEMPT FOR VIOLATION MAGISTRATE JUDGE'S ORDER SEALING FBI AFFADAVIT; MEMORANDUM OF POINTS AND AUTHORITIES; REQUEST FOR SANCTIONS

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affidavit omitted facts that just days before the affidavit was prepared, the FBI was attempting to use Senator Calderon as an informant against Senators Steinberg and de Leon. The FBI affidavit was ordered sealed by the Magistrate Judge of this Honorable Court. On October 30, 2013, the news outlet "Al Jazeera America" published an article which included the FBI's affidavit relating to the search warrant of Senator Calderon's office. The article included other confidential details concerning the FBI's investigation. Attached hereto as Exhibit "B" and "C" are true and correct copies of the Al Jazeera Article and FBI affidavit attached to the article. The source of the leaked affidavit could only have come from the FBI and/or the AUSA-CDC which was directing the FBI operation. The details of the FBI's investigation, the strategy and direction of the investigation, the potential charges being considered by the government, and the contents of the FBI's affidavit are all information that could be known only to those within the U.S. Attorney's office. The AUSA-CDC has a history of having confidential and sealed documents under the office's control leaked to the press. Specifically, the pattern of illegal leaks coming from the office of AUSA Doug Miller is troubling, with the media sensationalism created by those leaks bearing no relation to the ultimate facts and law. Here, it is clear that the FBI and/or AUSA-CDC engaged in a campaign to smear the reputation of Senator Calderon and convict him in the press and public before a grand jury was assembled and while it was hearing evidence. Short of that, they seek to have him removed from office. The egregious constitutional violations committed in this case were not motivated by the ends of justice, but were instead efforts by the AUSA-CDC to retaliate against Senator Calderon for derailing the FBI/AUSA sting operation on the California State Senate by refusing to participate as their informant.

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-4NOTICE OF MOTION AND MOTION FOR ORDER TO SHOW CAUSE WHY GOVERNMENT SHOULD NOT BE HELD IN CONTEMPT FOR VIOLATION MAGISTRATE JUDGE'S ORDER SEALING FBI AFFADAVIT; MEMORANDUM OF POINTS AND AUTHORITIES; REQUEST FOR SANCTIONS

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II. FACTUAL BACKGROUND A. The Leak On October 30, 2013, Al Jazeera America published an article written by Trevor Aaronson and Josh Bernstein which describes the allegations contained in the FBI's sealed affidavit. The article contains a downloadable copy of the FBI affidavit. The affidavit was ordered to be sealed and kept confidential by the Magistrate Judge for the United States District Court, Eastern District of California. Leaking the sealed affidavit to the press is expressly prohibited and illegal. The October 30, 2013 Al Jazeera article claims that the FBI's affidavit was provided to Al Jazeera America's Investigative Unit. The article contains descriptions of names of numerous potential witnesses, the nature of the purported allegations against Senator Calderon, the details of the investigation conducted by the FBI, purported conversations with Senator Calderon, and other blatant hearsay. All of this information was under seal. The article admits that the affidavit is "still under seal." The article continues by using completely false and fabricated information taken from the affidavit to smear Senator Calderon and his family. Al Jazeera claims that its attorneys redacted portions of the affidavit to protect the identities of the FBI agents involved in the raid. We have evidence that Al Jazeera reporters were in prior contact with FBI Public Information Officer Samora Ivera. Following the publication of the October 30 Al Jazeera article, the FBI announced an investigation into the unauthorized leak of the sealed affidavit'. On November 7, 2013 the

I FBI seeks investigation of source of leaked affidavit, The Sacramento Bee (November 1, 2013). at hap://blogs.sacbee.comicapitolalertlatest/2013110/fbi-seeks-investigation-of-source-oldeaked-affidavit.html. -5NOTICE OF MOTION AND MOTION FOR ORDER TO SHOW CAUSE WHY GOVERNMENT SHOULD NOT BE HELD IN CONTEMPT FOR VIOLATION MAGISTRATE JUDGE'S ORDER SEALING FBI AFFADAVIT; MEMORANDUM OF POINTS AND AUTHORITIES; REQUEST FOR SANCTIONS

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FBI released another statement refusing to comment on the pending investigation and confirming that the investigation into the source of the leak was referred to the Department of Justice.2 However, the FBI's "investigation into the illegal leak is little more than the fox guarding the proverbial henhouse since the likely source of the illegal leak is inside the Department of Justice where the so-called investigation has now been referred. B. Retaliation by the FBI and/or the AUSA-CDC The leaker in this case deliberately released the FBI's sealed affidavit to publicly disgrace Senator Calderon. The false information contained in the FBI affidavit, the illegal raid on Senator Calderon's office, and the most recent leak of the under seal affidavit were part of a calculated effort by the FBI and/or the AUSA-CDC to retaliate against Senator Calderon. Shortly before the FBI raid took place, Senator Calderon refused to participate in the sting operation planned by the FBI and AUSA Miller against Senator Steinberg. Senator Calderon was given a wire to wear and was asked to record his communications with Senator Steinberg and Senator de Leon. High level FBI agents met with Senator Calderon on six occasions and AUSA Miller met with Senator Calderon on two separate occasions to try and convince the Senator to participate in the sting operation targeting the financial dealings between Senator Steinberg and Michael Drobot and other donors to the Senate pro Tem' s political action committees. Senator Calderon refused to participate in the sting operation and returned the wire equipment to the FBI. In response, the FBI and AUSA Miller pursued frivolous and fabricated allegations against Senator Calderon and permitted such allegations

2 Randy Economy & Brian Hews, BREAKING: FBI Issues Statement on Al lazeera America Expose on The Calderons, Los Cerritos Community Newspaper (November 7, 2013). at http://www.Ioscerritotint wsJiet/20 13/ 1 0/3 I /breaking,- fbi-issues-statement-on-al-j ialkr(- 15/. a ica-expose-on-the-

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to leak to the press in violation of Court order. The AUSA-CDC has attempted to convict Senator Calderon in the press through an illegal disinformation campaign. While false information concerning Senator Calderon has been illegally leaked to the press, critical facts regarding the AUSA-CDC's activities have been omitted or misrepresented. For example, the Los Angeles Times reported that AUSA Miller subpoenaed Senator de Leon in connection with the investigation of Senator Calderon but "indicat[ed] that de Leon is not target of the investigation."3 However, this statement, in a letter to Senator de Leon's attorney signed by AUSA Miller, is demonstrably false since Senator Steinberg and Senator de Leon were the main targets of the investigation, for which Senator Calderon was requested to be the FBI's informant. C. Similar Leaks Have Plagued the Government's Investigations into Other Cases Handled by the AUSA-CDC The illegal leak of under seal records in this case is apparently the modus operandi for

14 how high profile and sensitive cases are handled by AUSA Miller's office. AUSA Miller 15 has been the common thread in a string of illegal leaks over the years. For example, AUSA 16 Miller was involved in the investigation into steroid use in major league baseball in 200317 2004. In June 2009, the New York Times published an article disclosing a name of a player 18 who purportedly appeared on the "positive results" lists in an under seal filing. The New 19 York Times Article quoted "an anonymous source" who did not want to be identified as 20 discussing matter because it was sealed with the court. See In re: GRAND JURY LEAKS, 21 2011 WL 2766956 (C.D. Cal 2011). Additionally, in 2011 AUSA Miller headed the 22 23 24
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See Federal prosecutor probing Calderon is used to high-profile cases , Los Angeles Times (November 1, 2013), at http://www.latimes.com/local/political/la-me-pc-ron-calderon-investigation-prosecutor20131101,0.3060451.story#axzz2kTDG9vSN
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-7NOTICE OF MOTION AND MOTION FOR ORDER TO SHOW CAUSE WHY GOVERNMENT SHOULD NOT BE HELD IN CONTEMPT FOR VIOLATION MAGISTRATE JUDGE'S ORDER SEALING FBI AFFADAVIT; MEMORANDUM OF POINTS AND AUTHORITIES; REQUEST FOR SANCTIONS

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government' s investigation of professional athlete Lance Armstrong. In that case, multiple instances of sealed and confidential information being leaked to the press were identified. Mr. Armstrong's attorneys filed a sanctions motion against the government, and its agents, for the illegal leaks that tainted the grand jury procedures. See Id. The pattern of illegal leaks in cases handled by the AUSA-CDC has grown more brazen over the years culminating in the most flagrant and prejudicial violations yet with respect to Senator Calderon. There is a systematic and systemic pattern of contempt for secrecy rules in AUSA Miller's cases resulting in the complete corruption of the legal process and character assassination of his targets. This conduct is deeply disturbing given that AUSA Miller purports to represent the "public corruption" division within the AUSA's office. D. Irreparable Harm to Senator Calderon The inviolable secrecy of pre-indictment documents is derived from constitutional norms to preserve the presumptions of innocence. Although the government routinely holds press conferences and issues press releases to saturate the public with their version of events, in mostly all cases that conduct occurs after an indictment is issued and an individual is charged with a crime. Here, the prejudice caused to Senator Calderon is compounded because not only has Senator Calderon not been charged with a crime, but the illegal leaks have occurred while the Grand Jury is hearing evidence. The leaks of sealed records in this case are calculated to fast track and strong-arm a meritless case against Senator Calderon through the grand jury process and then apparently shame Senator Calderon into accepting a plea agreement. The release of the sealed records has prejudiced any future grand jury proceeding and irreparably tainted any future court proceedings involving Senator Calderon. The illegal leaks have also served to discredit and defame Senator Calderon in the

-8NOTICE OF MOTION AND MOTION FOR ORDER TO SHOW CAUSE WHY GOVERNMENT SHOULD NOT BE HELD IN CONTEMPT FOR VIOLATION MAGISTRATE JUDGE'S ORDER SEALING FBI AFFADAVIT; MEMORANDUM OF POINTS AND AUTHORITIES; REQUEST FOR SANCTIONS

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public before any proceedings have been held. Senator Steinberg, who was the target of the government's investigation for his conduct, has stripped Senator Calderon from his committee positions and, on November 12, 2013 proclaimed he "will be damned" if Senator Calderon harms the reputation of the California State Senate4. Assemblymember Christina Garcia and numerous news outlets have publicly called on Senator Calderon to resign.5 Despite the fact that no charges against Senator Calderon have been filed, Senator Calderon's reputation has been irreparably damaged by the selective and illegal leak of the fabricated FBI affidavit which was ordered sealed. The presumption of innocence has been turned on its head. III. ARGUMENT A. Leaking Sealed Records Is Illegal The Ninth Circuit has consistently recognized that "warrant materials during the preindictment phase of an investigation . . . warrant the highest protection." Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1185, fn. 23 (9th Cir. 2006). Public access to records, "while important, had to be tempered by the rule of secrecy because of the wellrecognized policies behind that rule." Times Mirror Co. v. U.S., 873 F.2d 1210, 1219 (9th Cir. 1989). These public policy considerations include preserving the presumption of innocence of an individual who is targeted, but not yet charged, by the government and avoiding taint in future grand jury proceedings or in the event charges are filed. Id.

4 Steinberg: 'Ti! Be Damned" If Scandal Taints Senate (November! 0, 2013), http://www.nbc I osange le s .com/new s/loc al/Darrell-ste inberg-senate-pro-tem-news-c onference-c a lderon231326421.html

State Sen. Ron Calderon must resign, right now: Editorial, Long Beach Press Telegram (November 5, 2013), http://www . pre sste legram. c om/opin ion/20131105/state-sen-ron-calderon-m ust-re s ign-right-noweditorial.

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Tampering with pre-indictment procedures, including leaking sealed documents, raises other concerns rising to the level of serious criminal violations. Specifically, 18 U.S.C.A. 1509Obstruction of Court Orders states: Whoever, by threats or force, willfully prevents, obstructs, impedes, or interferes with, or willfully attempts to prevent, obstruct, impede, or interfere with, the due exercise of rights or the performance of duties under any order, judgment, or decree of a court of the United States, shall be fined under this title or imprisoned not more than one year, or both. Additionally, the Unites States Code criminalizes acts of retaliation against witnesses or informants during pre-indictment procedures. 18 U.S.C.A. 1513Retaliating against a witness [or] an informant, provides: (e) Whoever knowingly, with the intent to retaliate, takes any action harmful to any person, including interference with the lawful employment or livelihood of any person, for providing to a law enforcement officer any truthful information relating to the commission or possible commission of any Federal offense, shall be fined under this title or imprisoned not more than 10 years, or both. (f) Whoever conspires to commit any offense under this section shall be subject to the same penalties as those prescribed for the offense the commission of which was the object of the conspiracy. (g) A prosecution under this section may be brought in the district in which the official proceeding (whether pending, about to be instituted, or completed) was intended to be affected, or in which the conduct constituting the alleged offense occurred. Here, the conduct of leaking sealed records to retaliate against Senator Calderon for his activity as a witness and informant against Senator Steinberg invokes both 18 U.S.C.A. 1509Obstruction of Court Orders and U.S.C.A. 1513Retaliating against a witness [or] an informant. Individuals responsible for leaking confidential pre-indictment documents and information have received severe punishments by Courts. For example, in U.S. v. Hall -10NOTICE OF MOTION AND MOTION FOR ORDER TO SHOW CAUSE WHY GOVERNMENT SHOULD NOT BE HELD IN CONTEMPT FOR VIOLATION MAGISTRATE JUDGE'S ORDER SEALING FBI AFFADAVIT; MEMORANDUM OF POINTS AND AUTHORITIES; REQUEST FOR SANCTIONS

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2011 WL 6291957 (D.Vt. 2011) a paralegal working for the U.S. Attorney's Office was caught leaking sealed documents to her boyfriend who was under investigation. The defendant in that case was charged with obstruction of justice. The defendant accepted a plea deal for three years of probation. At the sentencing of the defendant, the federal court explained, "This is an extremely serious offense . . . I've never seen anything like it before in my 16 years on the bench. . .You understand that what you did goes to the heart of what the criminal justice systems is about?6" Leaks of confidential pre-indictment material also violate the Department of Justice's own rules. The United States Attorney's Manual ("USAM") expressly recognizes the need for confidentiality and prohibits prosecutors from making public comments regarding the nature and progress of ongoing investigations; any statements made by a target or the failure of a target or subject to make a statement; and the identities of prospective targets, subjects, or witnesses. See USAM 1-7.111, 1-7.500, 1-7.530. The USAM also makes clear that "[a]t no time shall any component or personnel of the Department of Justice furnish any statement or information that he or she knows or reasonably should know will have a substantial likelihood of materially prejudicing an adjudicative proceeding." USAM 17.500. Leaking sealed pre-indictment records and affidavits also violates Federal Rules of Criminal Procedure 49.1 and Local. Rule 141. Both of these rules protect sealed documents from public disclosure. At a minimum, violating the Court's sealing orders subjects the violating party to contempt proceedings and sanctions. See In Matter of Respondent X, 1997 WL 90832 (Cal.Bar Ct., 1997) (acknowledging that attorney may be found in criminal contempt for violating a court's sealing order and imposing discipline on the violating attorney).

Ex-paralegal sentenced for Burlington grand jury leak (May 15, 2012) http://www.burlingtonfreepress.com/article/20120515/NEWS02/120514026/

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NOTICE OF MOTION AND MOTION FOR ORDER TO SHOW CAUSE WHY GOVERNMENT SHOULD NOT BE HELD IN CONTEMPT FOR VIOLATION MAGISTRATE JUDGE'S ORDER SEALING FBI AFFADAVIT; MEMORANDUM OF POINTS AND AUTHORITIES; REQUEST FOR SANCTIONS

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The violations committed here are thus criminal, contemptible, procedural, and a violation of the Department of Justice's own rules. B. The Government Should be Held in Contempt for Violating the Magistrate Judge's Order to Seal the FBI's Affidavit In a contempt proceeding, the "moving party has the burden of showing by clear and convincing evidence that the contemnor violated a specific and definite order of the court." F.T.C. v. Affordable Media, 179 F.3d1228, 1239 (9th Cir. 1999), (quoting Stone v. City and County of San Francisco, 968 F.2d 850, 856 n.9 (9th Cir. 1992)); see also In re Crystal Palace Gambling Hall, Inc., 817 F.2d 1361, 1365 (9th Cir. 1987) ("If a person disobeys a specific and definite court order, he may be properly adjudged in contempt.") citing Shuffler v. Heritage Bank, 720 F.2d 1141, 1146 (9th Cir. 1983). If the moving party meets its burden, the burden is then on the violator to demonstrate why he has not complied with the order. See Affordable Media, 179 F.3d at 1239. Here, the Magistrate's Order to seal the FBI affidavit followed the historical and sacrosanct judicial and constitutional precedent of maintaining strict confidentiality of preindictment documents and records. The FBI affidavit was only possessed by the FBI and the AUSA-CDC. The FBI investigation was conducted under the auspices of the AUSA-CDC. Other than referring the investigation over its own misconduct to itself, the government has provided no explanation why the affidavit was furnished to Al Jazeera America. The leak in this case follows a history of leaks in high profile cases handled by AUSA Miller. The fact that the affidavit was leaked, when only the government had access to the document, inherently implicates the government as the source of the leak and shifts the burden to the government to answer for its conduct. The Fifth Circuit Court of Appeal' s analysis regarding leaks is instructive. The Court has held that an inference is made that the - 12 NOTICE OF MOTION AND MOTION FOR ORDER TO SHOW CAUSE WHY GOVERNMENT SHOULD NOT BE HELD IN CONTEMPT FOR VIOLATION MAGISTRATE JUDGE'S ORDER SEALING FBI AFFADAVIT; MEMORANDUM OF POINTS AND AUTHORITIES; REQUEST FOR SANCTIONS

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government was the source of the leak when some variation of the following information is published: (i) the name of "a specific witness...to be called," and "a specific question which the witness will be asked;" (ii) "specific types of criminal conduct which the grand jury was focusing upon;" (iii) "the contents of documents presented to the grand jury;" (iv) "information learned by the grand jury;" and (v) particular entities "whose activities were being investigated. In re: Grand Jury Investigation (Lance), 610 F.2d 202, 218 n. 12. (5th Cir. 1980). See also U.S. v. Flemmi, 233 F.Supp.2d 113, 117-18 (D.Mass 2000) (ordering government to submit affidavits proving it was not the source of the leak where a single news article, citing "sources familiar with the investigation," was "susceptible to the interpretation that it reports on evidence that is not part of the public record, but which was presented to the grand jury or was provided to investigators acting as the grand jury's agents.") Here, the information released in the Al Jazeera article is precisely the type of information only the government had access to. Indeed, the leak in this case exceeds the mere inference that the government leaked the records since the actual affidavit was delivered to the press. C. Since The Government Is The Source Of The Leak, The Court Should Impose Sanctions. This Court has the inherent power to enforce compliance with its lawful orders through contempt. Shillitani v. United States, 384 U.S. 364, 370 (1966); See also 18 U.S.C. 401 (1982); Young v. United States, 481 U.S. 787, 793 (1987); In re Crystal Palace, 817 F.2d at 1364; see also Fed R. Civ. P. 70. The court's powers in contempt proceedings are broad, Spallone v. United States, 493 U.S. 265, 276 (1990), and include the authority to impose sanctions to coerce compliance with a court order, Int'l Union, United Mine Workers - 13 NOTICE OF MOTION AND MOTION FOR ORDER TO SHOW CAUSE WHY GOVERNMENT SHOULD NOT BE HELD IN CONTEMPT FOR VIOLATION MAGISTRATE JUDGE'S ORDER SEALING FBI AFFADAVIT; MEMORANDUM OF POINTS AND AUTHORITIES; REQUEST FOR SANCTIONS

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of America v. Bagwell, 512 U.S. 821, 829 (1994), and to compensate affected persons and entities for losses caused by the contemnor's actions. Transact Technologies, Inc. v. Isource Worldsite, 406 F.3d 851, 855 (7th Cir. 2005). Sanctions may be imposed to coerce defendants into compliance with the court's order, or to compensate the party pursuing the contempt action for losses sustained as a result of the contemptuous behavior, or both. United States v. United MM Workers, 330 U.S. 258, 303-304 (1947); United States v. Bright, 596 F.3d 683, 696-697 (9th Cir. 2010) The government has demonstrated contempt for the Court's Order to seal the FBI's affidavit. Based on the clear and convincing evidence presented in this motion, Senator Calderon respectfully requests the Court order the government to show cause why it should not be held in contempt and subject to all appropriate sanctions.

12 IV. CONCLUSION. Based on the foregoing, California State Senator Ronald S. Calderon respectfully requests that the Court issue an Order to Show Cause why the United States, and its agents, such not be held in contempt for leaking sealed and confidential records and irreparably prejudicing Senator Calderon.

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DATED: November 13, 2013

GERAG00 " .7 4

S, APC

By: MARK J. OS Attorneys for D fendant RONALD CA DERON

- 14NOTICE OF MOTION AND MOTION FOR ORDER TO SHOW CAUSE WHY GOVERNMENT SHOULD NOT BE HELD IN CONTEMPT FOR VIOLATION MAGISTRATE JUDGE'S ORDER SEALING FBI AFFADAVIT; MEMORANDUM OF POINTS AND AUTHORITIES; REQUEST FOR SANCTIONS

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EXHIBIT A

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GERAGOS f GERAGOS
A PROFESSIONAL CORPORATION LAWYERS 644 SOUTH FIGUEROA STREET LOS ANGELES, CALIFORNIA 90017-341 1 TELEPHONE (2 1 3) 625-3900 FACSIMILE (2 1 3) 625-1600 GERAGOS@GERAGOS.COM

ACKNOWLEDGMENT

I, the undersigned, acknowledge having received on June 13, 2013, a wireless transmitter identified by a serial number beginning with P235, from Geragos & Geragos, APC.

Received By: Print name: Date:

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EXHIBIT B

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(/)

Exclusive: Hollywood sting


October 30, 2013

9:00PM ET

FBI investigation of a California political dynasty uncovers alleged bribery and corruption in the shadows of Tinseltown
View comments

Watch Part 2 of Al Jazeera's investigation here (/watch/shows/america-tonight/2013/10/capitolcorruptioninsideanfbistingparttwo.html). By Trevor Aaronson (http://america.aljazeera.com/profiles/a/trevor-aaronson.html) and Josh Bernstein (http://america.aljazeera.com/profiles/b/josh-bernstein.html) LOS ANGELES Ronald Calderon is a powerful state senator in California who holds sway over the glamorous Hollywood movie industry. He is also, according to the Federal Bureau of Investigation, a politician on the take.

A hefty 56-year-old Democrat with salt-and-pepper hair, Calderon has been a red-carpet star in California

Case 2:13-at-01311 Document and 1-2 now Filed 11/13/13 Page 3 of 19 suburban Los politics for more than a decade. As an assemblyman a state senator representing
Angeles, he has established a well-earned reputation for spending campaign money and taxpayer funds on himself. Hes used campaign cash to cover the finer things in life plush golf outings, lavish trips to Cuba and Las Vegas, meals at exclusive restaurants and hotels. When California offered to purchase cars for the states elected officials, Calderon chose the most expensive one: a $54,830 Cadillac STS V8 luxury sedan. But his days as a big spender may soon be over. The FBI is hot on his trail in an investigation that could become Californias biggest legislative scandal in more than two decades and could signal the downfall of a political dynasty. The FBI employed an undercover sting for more than a year that ended when agents raided the senators office in Sacramento in June. Al Jazeeras Investigative Unit subsequently learned of the secret operation. This account is based on a 124page affidavit, still under seal, filed by the FBI in U.S. District Court in Sacramento in support of a search warrant used in the raid. The names of several other senators, including the Senate president and the chair of the California Latino Legislative Caucus, have surfaced in the case, although none has been implicated. The document lays out a sordid tale of alleged bribery and corruption. Undercover FBI agents posed as independent movie executives interested in taking advantage of a program in which films with budgets of $1 million or more are eligible for special tax credits. The agents, focusing on Calderon, asked the senator to help lower the budget threshold to $500,000. Calderon, who chairs the Senate Select Committee on California's Film and Television Industries, agreed to help lower it to $750,000 but wanted financial assistance provided to his grown children, the affidavit says.
(http://america.aljazeera.com/articles/calderondynasty.html)
Click for more on The Calderon Dynasty

READ THE AFFIDAVIT


FBI affidavit supporting search of Calderon offices (/articles/2013/10/30/sealed-fbiaffidavitsupportingsearchofcalderonoffices.html)

Case 2:13-at-01311 Document 1-2 Filed 11/13/13 Page 4 of 19

On June 21, 2012, for instance, in a restaurant in Pico Rivera, Calif., outside Los Angeles, Calderon said he could lower the budget threshold if the movie executive would hire his daughter, Jessica. There might be a play, you know, to lower the tax credit. He went on: Any help you could do for my kids is you know, thats diamonds for me. The agent agreed to hire Calderons daughter for $3,000 a month if the senator could help reduce the movie budget threshold sooner rather than later. They had a deal. Calderons wife, Ana, would draw up an employment agreement for Jessica and the movie executive. That written agreement, Calderon said, was to keep it legit. The FBI summarized his thinking in the court document: You never take money directly from people and you have to be careful about a tit-fortat relationship. In reality, the record says, the arrangement was tit-for-tat: There was no work for Jessica, and payments to her were linked to Calderons efforts to sponsor favorable legislation. Over the course of the sting operation, the affidavit says, the FBI provided $60,000 to Calderon, much of it through his two children. For the senator, such arrangements werent unusual. Separately, the FBI court filing says, Calderon also used his son, Zachary, to accept kickbacks from a hospital executive, Michael D. Drobot (/articles/2013/10/30/fbi-california-statesenatoraidedallegedmultimilliondollarfraud.html), whose companies have received more than $161 million in state insurance payments. The state has sued Drobot, alleging he was behind multiple fraudulent schemes. RELATED FBI: California state senator aided alleged multimillion-dollar fraud (/articles/2013/10/30/fbicalifornia-statesenatoraidedallegedmultimilliondollarfraud.html)

State Sen. Ronald Calderon accepted bribes from a

Case 2:13-at-01311 Document 1-2 Filed 11/13/13 Page 5 of 19 Southern California hospital executive who ran an
alleged workers compensation scheme that brought the executive tens of millions of dollars, according to a sealed FBI affidavit obtained by Al Jazeeras Investigative Unit. Read more (/articles/2013/10/30/fbi-californiastatesenatoraidedallegedmultimilliondollarfraud.html)
(/articles/2013/10/30/fbi-californiastatesenatoraidedallegedmultimilliondollarfraud.html)
Pacific Hospital of Long Beach, Calif. Al Jazeera's Investigative Unit

Ronald Calderon is part of a California political dynasty that has controlled powerful state legislative committees for decades. During that time, the Calderons have been sharply criticized in the California media for using campaign cash for personal benefit. Indeed, politics and money are the lifeblood of the Calderon family. According to the affidavit, Ronald and his older brother Thomas, who previously held a seat in the California State Assembly, have collected more than $1 million in payments from people who have wanted to shape California laws to their benefit. In some cases, the Calderons used Californians for Diversity, a nonprofit organization connected to the Latino caucus, as their personal slush fund. James J. Wedick, a former FBI special agent, reviewed the court document at the request of Al Jazeera. Wedick is an expert on undercover sting operations. In 1988, his agents set up a front company in California and paid bribes in a case that led to the conviction of four elected officials and 10 legislative aides. This time around, he said, voters in California can expect to see another shake-up of politics and government. Its going to be an ugly scene when this information comes to light, Wedick said. That, in fact, you have elected officials taking money in exchange for legislation. It undermines our democracy.

Building a dynasty
The story of the Calderon political dynasty begins in 1982, when Charles Chuck Calderon won the District 59 seat in the California State Assembly. In 1988, he led a group of five assemblymen in unsuccessfully challenging the leadership of powerful Speaker Willie Brown. The speaker stripped the challengers of their committee chairmanships and removed them from their choice offices. But Calderon was not deterred. In 1990, he won a seat in the state Senate and would later become Senate president, the first Latino to hold the position in California. At the same time, he was dogged by ethics charges. In 1994, the state fined him $15,000 for spending campaign funds on personal expenses.

With his political star rising, Calderon laid the path for his

Case 2:13-at-01311 Document siblings to join the family business of politics. In 1998,1-2 Filed 11/13/13 Page 6 of 19
Thomas won a seat in the Assembly and was handed the plum chairmanship of the Insurance Committee. In 2002 he ran unsuccessfully for state insurance commissioner. Meanwhile, Ronald, the youngest brother, ran for and claimed Thomas former Assembly seat. Ronald moved to the state Senate in 2006, and Charles, having lost an earlier bid to be state attorney general, reclaimed the seat in the Assembly. What makes the Calderons unique is that they are passing on a baton within the same family, within the same surname, said Louis DeSipio, a political science professor at the University of California, Irvine, who studies California politics. Its not at all uncommon for an elected official whos leaving office, particularly after a long term of service, to designate a successor With the Calderons, though, the desire seems to have been to maintain the influence within the same family. Ronald, the least polished of the three brothers, rose in power and influence after joining the state Senate. He was appointed to the California Film Commission, which allocates $100 million in annual state tax credits to various film projects. He also became active in the increasingly powerful Latino caucus and, by 2011, was appointed its vice chairman. The next year, Ronald Calderon met an independent movie executive who was eager to see the state tax credit requirements changed. Calderon did not realize that the friendly movie executive was an FBI undercover agent.
State Sen. Ronald Calderon's district office is located in Montebello, Calif., outside Los Angeles. Al Jazeera's Investigative Unit

Inside the FBI sting


The FBI affidavit provides rich details on the sting. It indicates that an unidentified legislative aide introduced Ronald Calderon to an undercover agent at a lunch event in Los Angeles on Feb. 24, 2012. The agent presented himself as an independent movie executive with a studio in downtown L.A. Calderon described the movie tax credit program and also mentioned that his daughter, Jessica, was interested in the film industry. Over a subsequent lunch meeting, the legal document says, Calderon and the agent brokered their deal: The movie studio would hire Jessica, and Calderon would sponsor legislation that would change the movie budget requirements for a tax credit from $1 million to $750,000. On July 17, 2012, about a month after that lunch meeting, Calderon visited the agents apartment in Los Angeles. The agent told him that paying Jessica a monthly retainer was not the industry standard, according to the FBI account. The agent said he wasnt paying to hire Jessica he was hiring the senator. The affidavit describes this conversation:

Money is not an object, the undercover agent said. I mean, Im ready to write a check for the next year if

Case thats what you want 2:13-at-01311 Document 1-2 Filed 11/13/13 Page 7 of 19
Right, right, Calderon said, interjecting. For everything. Thats not the issue. And its never been an issue. Uh, huh, Calderon said. Jessicas talent, uh, her acumen thats not even an issue. That the whole concept behind this was we have a relationship. We have a professional relationship. We have a business relationship. And to put it in very blunt terms, me hiring Jessica was not about her talents, right? It was more about accommodating something that you needed. And you needed me to take care Right. Helping your children, the agent finished. Right, Calderon said. RELATED FBI undercover 'stings': Catching politicians red-handed (/articles/2013/10/30/fbi-undercoverstingscatchingpoliticiansredhanded.html) An all-expenses-paid trip to Napa Valley; a wad of cash, carefully counted out, laid on a desk and tucked into a suit pocket; a suitcase filled with money picked up at an airport hotel. These are just a few ways bribe money has been handled by politicians in which political favors are peddled for hard cash. Read more (/articles/2013/10/30/fbi-undercoverstingscatchingpoliticiansredhanded.html)
(/articles/2013/10/30/fbi-undercoverstingscatchingpoliticiansredhanded.html)
Rep. Richard Kelly as he w as filmed by the FBI in the course of its 1980s ABSCAM investigation. AP

By August 2012, according to the affidavit, Jessica had not performed any work for the fictitious movie studio but had received $27,000 in payments. The FBI document says that when a check arrived at Calderons ranch-style house in Montebello, where Jessica also lived, Calderon emailed the agent using coded language: Package received. Calderon invited the agent to attend the Imagen Awards ceremony, honoring Latino entertainers, with him at the Beverly Hilton hotel on Aug. 10, 2012, the filing says. Calderon and his wife attended, and the agent came with a date of his own, another FBI operative who played the part of his girlfriend and an aspiring model. At the awards dinner, Calderon described how he planned to introduce an amendment in the Senate

to lower the movie tax credit requirements. Nobody will ever know that the reason this happened is because

2:13-at-01311 Document 1-2 I Filed 11/13/13 8 of 19 of you, he told theCase agent, according to the FBI document. would not have Page pushed this hard if it wasnt for
you. But his amendment hit a roadblock. A legislative aide soon informed him that the amendment would require a two-thirds vote, a near impossibility. We are screwed! Calderon wrote to the undercover agent, according to the affidavit. This is bullshit, Ron. We gotta make this work, the agent replied by email. Even if the proposed amendment is shot down, we win. If we dont even propose the amendment, then Im done. The pair met for dinner in Pico Rivera, Calif., to reassess their situation. The agent got right to the point, according to the court record: He asked if Calderon would be willing to write a letter for the movie studios investor stating his commitment to introducing legislation that would lower the threshold for the tax credit legislation to $750,000. Calderon agreed, but for the sake of appearances, he suggested writing the letter to a group, not an individual or company. The next day, on Sept. 11, 2012, he emailed the undercover agent with several suggestions for names. So which name do you like? he wrote. The agent responded with the name of a fictitious group, United Pacific Independent Producers of California. In its account, the FBI says that Calderon took the bait. The senator wrote and mailed the letter of support to the FBI undercover agents, addressed to a group that didnt exist and whose name a federal agent simply made up.

A special fund: $50,000


The affidavit describes how Calderons cash-for-favors relationship with the undercover agent continued even after the movie tax credit legislation stalled. Over dinner on Oct. 16, 2012, the undercover agent asked if Calderon could hire his girlfriend, the aspiring model who was also an undercover federal agent, for a state job in Sacramento. Trouble was, the undercover agent admitted, his girlfriend didnt have any skills or relevant experience for legislative work. The affidavit lays out the following exchange: She comes with, you know, issues, the undercover agent said. Yeah, Calderon said. It is not a big thing, the agent said. But if you are willing to take that on Every girl has issues, Calderon interrupted. The agent told Calderon hed make hiring his girlfriend worthwhile. He explained that he had padded his movie budgets to give him an extra $50,000 to play with cash he could make available to a helpful senator. Oh, nice, Calderon said.

The agent and Calderon began to refer to the $50,000 as a special fund. On Nov. 2, 2012, Calderon

2:13-at-01311 1-2 Filed 11/13/13 Page of son, 19 Zachary. asked the agent toCase pay $5,000 to Berklee Document College of Music in Boston for tuition for9 his
Maybe we can get a $5,000 check to Berklee College of Music and Zach just turns it in, he said. The agent agreed to pay the tuition, but said $5,000 would make only a small dent in the $50,000 special fund. According to the affidavit, Calderon said they could deposit the rest into other accounts, including Californians for Diversity, a nonprofit organization controlled by Thomas Calderon. Ronald and Thomas Calderon used the nonprofit as a slush fund, the FBI alleges: We have this nonprofit. It is called Californians for Diversity, Ronald Calderon told the agent. So, we are gonna build this thing up and then, Tom and I down the road, we build that up, we can pay ourselves. Just kind of make, you know, part of a living. Calderon hired the undercover agents girlfriend as a member of his Senate staff, despite not having an open position. The hiring required the approval of Senate President Pro Tem Darrell Steinberg. The Senate leader declined to comment in a brief interview with Al Jazeera other than to say, Let the investigation run its course. The cash and gifts kept flowing, but Calderon failed to report them on his state ethics disclosure forms, state records show. In late October, for example, the undercover agent reserved a table for Calderon at The Bank, a nightclub inside the Bellagio in Las Vegas. Calderon and a friend went to the nightclub and, according to the affidavit, racked up a $3,939.56 bill at the agents expense. Calderon took a photograph of himself with rappers Nelly and T.I. and emailed it to the agent. Two months later, the undercover agent purchased a $5,000 ticket for Calderon to attend a fundraiser for state Sen. Kevin de Leon, who represents a Los Angeles district. The event was held during a Manny Pacquiao fight in Las Vegas. More money and perks flowed from the undercover agent, including a $25,000 payment to Californians for Diversity and $3,200 for Calderon to fly to Miami and meet with the undercover agent and his supposed investor. Calderon advised the investor who was also an undercover agent that he should hire his brother Thomas as a consultant. The investor then asked if Calderon still supported the tax credit legislation. Absolutely, he said, according to the court document. You have my support even if you dont hire Tom.
In September, Californians for Diversity, a nonprofit run by Thomas Calderon, hosted a fundraiser at Pebble Beach Resorts. Major supporters included Walmart Stores, the Clorox Co., Shell Oil Co. and Farmers Insurance. Al Jazeera's Investigative Unit

In Miami, the FBI says, the undercover agents agreed to pay $10,000 per month $3,000 purportedly for

Case 2:13-at-01311 Document 1-2 Filed taxes 11/13/13 Page 10 have of 19to pay on the Jessica, $5,000 for Thomas and the additional $2,000 to cover Thomas would
income. The investor drove Ronald Calderon to Miami International Airport and handed the senator a white envelope containing $3,000 in cash. Future payments, Calderon said, should go to Californians for Diversity.

RELATED STORIES
Members of the Calderon political dynasty (/articles/2013/10/30/members-ofthecalderonpoliticaldynasty.html) The Calderon Dynasty: 30 years of political power (/articles/2013/10/30/thecalderondynasty30yearsofpoliticalpower.html)

The next day, Calderon called the investor. There was a problem. His plan of having the movie studio pay $10,000 per month to Californians for Diversity wouldnt work, he said. State Sen. Ricardo Lara, chair of the Latino caucus, was taking greater control of nonprofits associated with the caucus. Californians for Diversity is tied into the Latino Caucus in terms that its being sanctioned by them, and thats why Im able to raise the money for the purpose of promoting numbers in the caucus, Calderon said, according to the affidavit. So the bylaw was changed that hes (Sen. Lara) got authority on any consultants that are hired that are paid over $5,000 a month. Wait, who has authority? Tom or you? the agent asked. No, the chair of the caucus. In other words, he has to authorize anything over $5,000. So right now, Tom is already getting $5,000 a month from the caucus, from our committee. For us to add to that number one, its going to bring too much attention to us in what were doing and right now were in fundraising mode. And number two, then I have to go and get permission from the chair to get more, and I dont want to do that.

The good life: Pebble Beach


Calderons relationship with the generous movie producer came to an abrupt end in early June when FBI agents raided his Capitol offices in Sacramento. Soon after, he set up a legal defense fund and issued a brief statement to reporters. My family and I have gone through a lot the last several days, he said. Its been very stressful, very hard on all of us. Were all anxious to put this behind us and carry on a normal life. Despite their troubles, the Calderon money machine continues running on high octane. In September, the senator attended a two-day fundraising event at Pebble Beach Resorts for Californians for Diversity, the nonprofit run by his brother Thomas. Major supporters included Walmart Stores, the Clorox Co., Shell Oil Co., Farmers Insurance and Edelstein Gilbert, a prominent California lobbying firm. Calderon golfed with industry lobbyists and then shared fireside drinks with them in the cool evening hours. A few days later, Al Jazeeras Investigative Unit caught up with him at a luxury golf resort in Orange County.

The conversation was abrupt.

Case 2:13-at-01311 Document 1-2 Filed 11/13/13 Page 11 of 19


Asked about the FBI investigation as he lifted clubs from the trunk of his Cadillac, Calderon said: Im not really going to discuss any of that. He then walked into the pro shop, refusing to answer additional questions. Al Jazeera Investigative Unit
State Sen. Ronald Calderon, attending the Californians for Diversity event in September, enjoys a cigar during an evening party. Al Jazeera's Investigative Unit

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Michael Boyd
Shocking!

2 days ago

REPLY
MJRydsFast
4 days ago

"Calderon did not realize that the friendly movie executive was an FBI undercover agent." The oxymoron should

have made it obvious- "friendly"? "Movie executive"? In the same breath? Hmmm.... I believe I hear David Geffen laughing now. Case 2:13-at-01311 Document 1-2 Filed 11/13/13 Page 12 of 19

REPLY
Richard Rider
5 days ago

Over the last 40 years, two trends have become apparent in California politicians' criminal corruption cases. 1. The cases USUALLY involve Democrats. But not always. 2. A more consistent trend is for the culprits to be political veterans. In the state legislature, I don't think anyone charged with crimes since 1970 (and there have been quite a number) had less than 8 years seniority in the legislature (we instituted generous term limits in the 1990's, I believe). In my 35+ years dealing with politicians at every level of government, I must say that this seniority correlation seems to be universal. It's a telling case for term limits.

REPLY
Robert DeAlmeida
5 days ago

POLITICAL CORRUPTION, CALDERON STYLE

REPLY
Robert DeAlmeida
5 days ago

Itemize the items on the $3,900 dinner in Las Vegas so that us dumb taxpayers can understand how he could spend that much money for two people in one night. Help me understand.

REPLY
Almee_eq2
5 days ago

We have the best government money can buy in America.

REPLY
Delbert Lammers
5 days ago

+3

I live in Northern, California (Santa Clara County) where the Calderon Brothers own a chain of tire stores that launder millions of dollars of illegal drug money every year...

REPLY

1 reply

allison_salnews

5 days ago

What proof can you offer?

Case 2:13-at-01311 Document 1-2 Filed 11/13/13 Page 13 of 19

REPLY
Chenille Matillisse

5 days ago

http://www.vete ranstoday.com/2 013/10/29/the-p laying-field-is -clear-part-1/ Even more extra o r di nar y was the behav ior of the FBI, which (con trary to legal pro ce dure) con fis cated evi dence that had been kept by Seal in the trunk of his Cadil lac. That evi dence con s isted of tapes of Seal talk ing with his han dlers, who appar ently included ele m ents of the CIA and then Vice-President George Bush. When one of Seals attor neys prod ded Seal for more infor m a tion about whom he was work ing for, Seal handed him the phone and told him to call a num ber that he gave to his coun s el. When Unglesby (the lawyer) called the num ber, he got VicePresident Bushs office. When Seal attempted to pre vail on Bush to inter vene on his behalf with the IRS, Seal was mur dered. Much of the pro gram deals with Seals his tory in the world of covert operations

REPLY
Roy Rutherford
5 days ago

+1

Sure, that's a great story, well done, important, informative and thorough but.. if you want to learn how to make a hat out of soybeans or a delicious yogurt desert, there is still CNN :)

REPLY
Lenny Sita

1 reply

+6

5 days ago

@Roy, Good one! I'm still laughing!

REPLY
realBKW

+1

5 days ago

How ironic that he sets up a "defense fund" for donations to cover his legal fees. His defense team better make sure they get paid upfront, with CLEAN money! Politicians like this are scum and the bane of democracies everywhere. Yet stupid voters keep electing them. I guarantee the Calderon dynasty will continue. Just keep them in state, please. No national office for them.

REPLY
Angela Kolios
5 days ago

+1

I used to live in L.A. I attended Los Angeles High school and was a member of Saint Sophia Greek Orthodox church on Pico and Normandie. My mother had a duplex on Beachwood and Melrose across from Desilu studios. That was a very long time ago. I went back only once in 1983 and was so scared walking on Hollywood blvd I never went back. Nothing surprises me about California politics they were corrupt then as they are now. could not get a teaching job in LA. district unless you knew a politician. That's why I left.

REPLY Case 2:13-at-01311 Document 1-2 Filed 11/13/13 Page 14 of 19


Lawrence Dickerson
5 days ago

Keep up the good work.This is a start and I can only hope that all of the elected officials will take notice and abandon their quest for personal riches over representing their constituents.I too would like to see these types of investigations pointed at the very heart of the US government.That 's a tough cookies to crumble but I can still dream per chance.

REPLY
Michael Boyd
5 days ago

+1

This is a start. A start comparing the size of a snow cone to an iceberg the size of Greenland.

REPLY
Lenny Sita

1 reply

+1

5 days ago

True, but still a start.

REPLY
Rafe Husain
great breaking story

5 days ago

REPLY
Richard Columbare
5 days ago

O.K. so you have caught up to just one of our corrupt politicians. Now the justice system has to follow through by taking away through fines most of his money and most importantly giving him a very long prison sentence and not in some minimum security prison. Do not do one without the other. Perhaps in America we are not allowed to give them the death penalty but I do not want them to get a fine and a slap on the wrist . Instead I would like a strong signal given to the rest of the corruptibles do not do likewise or the same will happen to you!

REPLY

2 replies

+1

Delbert Lammers

5 days ago

I agree, a fine, and a slap on the wrist would send a clear signal to most Americans that the whole thing was just for show. There should be five or six hundred of these guys shackled up doing the perp walk into a federal court house! Now that would be a good start!

REPLY

1 reply

Sita 5 Document days ago CaseLenny 2:13-at-01311 1-2 Filed 11/13/13 Page 15 of 19
I'd like to see the real culprits behind "this show." He's probably just a fall guy or he angered someone much more powerful than him. But we'll never know who the big fish truly are.

REPLY
mksiddiki

5 days ago

Like the report. He is a very small fish, catch the big fishes.

REPLY
Quake Lollerama
5 days ago

+1

Now write one on the Clinton's, I dare you.

REPLY
Vincent Finelli
5 days ago

+2

Great article and reporting on political abuse. Keep following through and pressing politicians to be held to a higher standard. No other major new source is covering this very important issue.

REPLY
Dean Borchert
5 days ago

+2

The truly sad part is that this is just ONE politician. His defense is that he believes it is "not a criminal act" and it is "just normal business practice". In one sense, he is correct. It IS a normal business practice (among politicians). They have been doing it so long that they truly believe it is "OK". Everyone else operates that way.

REPLY
Stephen Laudig
5 days ago

+4

In some ways the Chinese criminal justice system, which allows for, and, indeed, imposes executions as a penalty for corruption is admirable. Execution for public corruption, what's a few dead politicians, more or less?

REPLY
J.E. King
6 days ago

+4

Have thought I was following this on LATimes. Clearly you do have the details that haven't yet hit the fan. This is

so sickening, right after the Bell-Robert Rizzo scandal. We don't have enough FBI to conduct stings against all the bad politicians out2:13-at-01311 there, or even enough honest people power to do their own true16 jobof as19 public servants. Case Document 1-2 in Filed 11/13/13 Page Thanks for this scoop, I'll be back here for my local news now too.

REPLY
Jan gil
6 days ago

+1

I would be more impressed with the subject of this article, but the reality is, the Latino political faction is not known for its members money. However, they are known for their numbers. The Calderons are not that big of political fishes It's not that I condone any of their illegal activities, it's just that I know there are bigger, more powerful political fish out there..

REPLY
Ali Chami

3 replies

+1

5 days ago

Like Jane Harman conspiring with Haim Saban ?

REPLY
Amy Anderson

5 days ago

Maybe this guy is just one more out of the way before they get to the biggies.

REPLY
Delbert Lammers

5 days ago

One of those big fish is California Senator Diane Feinstein from San Francisco. Who for many years now has head the committee in Washington that hands out lucrative military contracts, while her husband is one of those military contractors. This conflict of interest between them, has made them extremely wealthy.

REPLY
Jon York

+1

6 days ago

In this story the FBI is doing the same thing as what they call "lobbying" in Washington

REPLY

+2

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