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Page 1 of 38
Appeal No. 1-14-AP-001825, Dei Gratia v. WACHOVIA MORTGAGE FSB,
HI&RH Empress Aubre Regina Dei Gratia s
Objection to Judge Helen E. Williams for Disqualification for Cause
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destroys, or attempts to do so, or, with intent to do so takes and carries away any record,
proceeding, map, book, paper, document, or other thing, filed or deposited with any
clerk or officer of any court of the United States, or in any public office, or with any
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judicial or public officer of the United States, shall be fined under this title or imprisoned
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(b) Whoever, having the custody of any such record, proceeding, map, book, document,
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paper, or other thing, willfully and unlawfully conceals, removes, mutilates, oblitserates,
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falsifies, or destroys the same, shall be fined under this title or imprisoned not more than
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three years, or both; and shall forfeit his office and be disqualified from holding any
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office under the United States. As used in this subsection, the term office does not
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include the office held by any person as a retired officer of the Armed Forces of the
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United States.
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PLEASE TAKE NOTICE that HI&RH Empress Aubre Regina Dei Gratia, objects,
by Affidavit, to Judge Helen Elizabeth Williams, due to disqualification for cause, based
upon numerous reasons cited in the Affidavit below and the caption above. This motion is
made timely in that the judge is still in office and the clock does not start to run until the
public servant leaves office, pursuant to civil rights federal law Title 42 U.S.C. 1983,
1985, 1988, C.C.P. 170.1, 170.3; Title 28 U.S.C. 455, 455(a), 455(b)(1), 455(b)(3),
455(b)(5)(i), 455(b)(5)(iv), Canons 1, 2, 3.B.6, and 6; FRCP Rule 7(b), Fed. R. of Evid.,
Rule 201, CALIFORNIA PC 92, 93, Constitution of the California Republic, the
Page 2 of 38
Appeal No. 1-14-AP-001825, Dei Gratia v. WACHOVIA MORTGAGE FSB,
HI&RH Empress Aubre Regina Dei Gratia s
Objection to Judge Helen E. Williams for Disqualification for Cause
authorities cited in the memorandum herein, to recuse Judge Helen Elizabeth Williams.
Any opposition answer to this motion to recuse Judge Helen Elizabeth Williams, must
under C.C.P. 170 et seq., be served and filed 10 days from the filing and service date
STATE OF CALIFORNIA
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AFFIDAVIT OF TRUTH
Comes now your Affiant, HI&RH Empress Aubre Regina Dei Gratia, the natural
living woman, over the age of 18, who makes these statements under oath and after first
being duly sworn according to law, states that she is your Affiant, and she believes these
facts to be true to the best of her belief and knowledge.
1.
Your Affiant makes this affidavit in the CITY OF SAN JOSE, COUNTY OF
Your Affiant states that the facts described herein are true, complete and not
misleading
3.
Your Affiant states that the undersigned has first hand knowledge of all the facts
stated herein.
4.
Your Affiant states that the facts described herein describe events that have
Your Affiant states that HI&RH Empress Aubre Regina Dei Gratia, is a non-
corporate, a non-combatant and real, mortal, sentient, flesh and blood, natural born living
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woman, who is living, breathing, and a being, on the soil, with clean hands, rectus curia.
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reservation.
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Your Affiant states that the undersigned makes these statements freely, without
Page 3 of 38
Appeal No. 1-14-AP-001825, Dei Gratia v. WACHOVIA MORTGAGE FSB,
HI&RH Empress Aubre Regina Dei Gratia s
Objection to Judge Helen E. Williams for Disqualification for Cause
7.
8.
Your Affiant states that Empress Aubre Regina Dei Gratia, is your Affiant.
9.
Your Affiant states that Empress Aubre Regina Dei Gratia, is the Appellant in
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case from which the current appeal is appealed from, Civil Division Limited Jurisdiction,
Case 110-CV-178733.
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Your Affiant states that if the undersigned is compelled to testify regarding the
Your Affiant states that Empress Aubre Regina Dei Gratia, is the Plaintiff in the
Your Affiant states that Empress Aubre Regina Dei Gratia, is a Secured Party
Creditor.
12.
Your Affiant states that the standing of the undersigned as a Secured Party Creditor
is recognized through official acts of the STATE OF NEW YORK, pursuant to FRCP rule
9(d).
13.
Your Affiant states that the full faith and credit clause of the federal constitution
Your Affiant states that a Secured Party has standing above that of the incorporated
Your Affiant states that the status of the undersigned confers standing above that of
Your Affiant states that the standing of the undersigned is above that of Judge
Helen E. Williams.
17.
Your Affiant states that Pursuant to the Supreme Court of the United States, Re:
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Haines v. Kerner 404 U.S. 519 at 521 (1972), pro se/pro per pleadings MAY NOT be held
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to the same standard as a lawyers and/or attorneys; and whose motions, pleadings and
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all papers may ONLY be judged by their function and never their form.
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Your Affiant states that the undersigned is considered in pro per, also known as in
Page 4 of 38
Appeal No. 1-14-AP-001825, Dei Gratia v. WACHOVIA MORTGAGE FSB,
HI&RH Empress Aubre Regina Dei Gratia s
Objection to Judge Helen E. Williams for Disqualification for Cause
proper persona.
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exempt from dismissal for form not function and pro se Petitions cannot be dismissed
without the court allowing the opportunity for the pro se litigant to correct the Petition;
AND the court MUST inform the pro se litigant of the Petitions deficiency; AND
instruct the pro se litigant on the necessary instructions; AND the pro se litigant may
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complaint without instruction as to how the pleadings are deficient and how to repair the
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Your Affiant states that pro se litigants complaints, pleadings and other papers are
Your Affiant states that the Court errs if the court dismisses the pro se litigants
rights (given by God) are violated when courts depart from precedent, where parties
are similarly situated. See Anastasoff v. United States, 223 F.3d 898 (8th Cir. 2000)
Governing Rules of this Case
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paragraphs of this objection to judge for disqualification for cause as if those paragraphs
were fully set forth herein.
23.
Your Affiant states, In the name of God, with the gaze of Our Lord, that Empress
Aubre Regina Dei Gratia is appearing specially and not generally, vi et armis..
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Your Affiant states that your Affiant is claiming, exercising and invoking ALL
RIGHTS, including but not limited to God granted Rights, inalienable rights, human
Rights, and all Rights guaranteed and protected by the united States Constitution, the
California Constitution, the Universal Postal Union Treaty and other unspecified
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International Treaties.
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reference as if fully set forth herein, the entire SUPERIOR COURT OF CALIFORNIA,
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Your Affiant states that the undersigned adapts and incorporates herein by
Page 5 of 38
Appeal No. 1-14-AP-001825, Dei Gratia v. WACHOVIA MORTGAGE FSB,
HI&RH Empress Aubre Regina Dei Gratia s
Objection to Judge Helen E. Williams for Disqualification for Cause
GUANCIONE.
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reference as if fully set forth herein, the entire SUPERIOR COURT OF CALIFORNIA,
GUANCIONE.
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Your Affiant states that the undersigned adapts and incorporates herein by
Your Affiant states that the incorporation by reference is not limited to, all Minute
Your Affiant states that the undersigned submits the following facts, law and
Your Affiant states that the instant case is governed by, inter alia, the Federal Rules
of Civil Procedure and, inter alia, the Federal Rules of Evidence and, inter alia, the
United States Code and, inter alia, the united States Constitution of 1787 and, inter alia,
the amendments thereto including the original 13th Amendment and, inter alia, the
California Constitution and, inter alia, the Treaty of Paris of 1781 and, inter alia, the
Hague Convention and, inter alia, the Universal Postal Union Treaty and, inter alia, ALL
other human rights treaties and, inter alia, all estoppels on government agencies and/or
agents, and others and, inter alia. These Rules and Laws have not been abrogated.
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Your Affiant states that the incorporation by reference is not limited to, all Minute
STATEMENTS OF FACT
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the OFFICE OF THE DISTRICT ATTORNEY for the COUNTY OF SANTA CLARA,
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and the OFFICE OF THE STATE ATTORNEY GENERAL, each agreed that they DID
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Your Affiant states that in 2013, David H. Yamasaki, Court Clerk and CEO, and
Page 6 of 38
Appeal No. 1-14-AP-001825, Dei Gratia v. WACHOVIA MORTGAGE FSB,
HI&RH Empress Aubre Regina Dei Gratia s
Objection to Judge Helen E. Williams for Disqualification for Cause
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the OFFICE OF THE DISTRICT ATTORNEY for the COUNTY OF SANTA CLARA,
and the OFFICE OF THE STATE ATTORNEY GENERAL, each agreed that the
undersigned is a Secured Party, which is a status that has standing above that of all
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living man/woman.
Your Affiant states that in 2013, David H. Yamasaki, Court Clerk and CEO, and
Your Affiant states that the state court is a corporation, also known as the
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business name for the legal fiction incorporated in Washington, DC, as the JUDICIAL
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COUNCIL OF CALIFORNIA.
36.
Your Affiant states that the undersigned real and natural living woman Aubre
Guancione, also known as Empress Aubre Dei Gratia, does NOT hold the office of
person.
38.
Your Affiant states that the court may not disperse or assign the assets of the
Your Affiant states that the undersigned had filed the estate copyright notice into
Your Affiant states that Judge Helen Elizabeth Williams acted without
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jurisdiction in hearing the case sub judice, due to self recusal in case C1096307,
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Your Affiant states that Judge Helen Elizabeth Williams acted without
Page 7 of 38
Appeal No. 1-14-AP-001825, Dei Gratia v. WACHOVIA MORTGAGE FSB,
HI&RH Empress Aubre Regina Dei Gratia s
Objection to Judge Helen E. Williams for Disqualification for Cause
jurisdiction in hearing the case sub judice, due to self recusal in case C1103451,
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presumption of proof of the bias and prejudice of Judge Helen E. Williams against the
undersigned.
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the undersigned.
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Your Affiant states that Judge Helen E. Williams has been recused in at least two
Your Affiant states that the prior recusals of Judge Helen E. Williams establish a
Your Affiant states that Judge Helen E. Williams has a bias and a prejudice against
Your Affiant states that Judge Helen E. Williams HAS A BIAS AND A
corporate capacity.
46.
Your Affiant states that Judge Helen E. Williams HAS A BIAS AND A
PREJUDICE IN FAVOR OF
Your Affiant states that Judge Helen E. Williams HAS A BIAS AND A
PREJUDICE IN FAVOR OF
Your Affiant states that Judge Helen E. Williams has a BIAS AND PREJUDICE IN
FAVOR OF THE
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Your Affiant states that Judge Helen E. Williams has received and continues to
Your Affiant states that the payments that Helen E. Williams HAS RECEIVED
Your Affiant states that the term local judicial benefits is semantic deceit for bribes
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bribes pursuant to UNITED STATES SUPREME COURT case law, see federal case law
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establish the quid-pro-quo between Judge Helen E. Williams and the COUNTY OF
SANTA CLARA pursuant to UNITED STATES SUPREME COURT case law, see
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Your Affiant states that the payments that Helen E. Williams HAS RECEIVED
Your Affiant states that no other proof than proof of the payments is required to
Your Affiant states that the quid-pro-quo between Judge Helen E. Williams and
in favor of the case outcomes that favor or profit the COUNTY OF SANTA
CLARA.
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Your Affiant states that the COUNTY OF SANTA CLARA profits from every
Your Affiant states that the quid-pro-quo is present in the instant case between
Your Affiant states that bias or prejudice for or against a party are mandatory
Your Affiant states that the judges in the SUPERIOR COURT OF CALIFORNIA
are subject to the laws in Title 28 U.S.C. section 144 and Title 28 U.S.C. section 455.
59.
Your Affiant states that Judge Helen E. Williams agreed in 2013 that SHE HAS A
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Your Affiant states that Judge Helen E. Williams acted in fraud in the instant case
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PARTY.
Your Affiant states that Judge Helen E. Williams acted WITHOUT JURISDICTION,
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Your Affiant states that Judge Helen E. Williams denied the undersigned her civil
Page 9 of 38
Appeal No. 1-14-AP-001825, Dei Gratia v. WACHOVIA MORTGAGE FSB,
HI&RH Empress Aubre Regina Dei Gratia s
Objection to Judge Helen E. Williams for Disqualification for Cause
rights to both due process and equal protection under the law, by issuing rulings in the
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JUDGE,
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Your Affiant states that when a judge acts without jurisdiction, that is known as in
Your Affiant states that at the moment a judge performs an act or acts in violation
and WITHOUT THE IMMUNITY of their office.
Your Affiant states that a judge acting outside their office as judge, is acting in
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MATTER JURISDICTION
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Your Affiant states that Judge Helen E. Williams acted WITHOUT SUBJECT
at all times in the instant appeal.
Your Affiant states that Judge Helen E. Williams DELIBERATELY, WILLFULLY AND
sub judice.
68.
Your Affiant states that Judge Helen E. Williams has NO immunity to either civil
or criminal prosecution or law suit for her actions in violation of the undersigneds civil
rights, or that of the ROSALIE GUANCIONE estate or trust, based upon the fraud in the
instant case.
69.
Your Affiant states that Judge Helen E. Williams was given notice of all
Your Affiant states that judges are required to keep an up to date list of their
conflicts of interest.
71.
Your Affiant states that judges are required to know and inform themselves of their
conflicts of interest, personally and thru their relatives up to and including the third civil
familial degree.
72.
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Doanes Administraters, corporate courts can only interface and have jurisdiction over
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Party Creditor.
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Your Affiant states that in an official act by the STATE OF NEW YORK, the NEW
Your Affiant states that pursuant to Article IV Section I of the federal Constitution,
the Full Faith & Credit Clause, this state court must accept official acts, rulings and/or
laws of any other state.
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Your Affiant states that Judge Helen E. Williams conducts court from a closed
courtroom, in which she excludes all parties and only allows attorneys to enter.
77.
Your Affiant states that Judge Helen E. Williams conducts court proceedings that
are not open to the public, as required by the federal Constitution of 1787 and the
amendments thereto.
78.
Your Affiant states that Judge Helen E. Williams has knowingly, willfully and
wantonly failed to perform her duty to uphold her oath of office to support and faithfully
defend the Constitution of the UNITED STATES, and the civil rights of the undersigned,
thru either semantic deceit; the misapplication of a law; or thru the use of a law that is
repugnant to the Constitution regarding due process and equal protection, in application
of a time constraint on notice of appeal that ignores the legal right to notice.
79.
Your Affiant states that when a judge receives payments or payments in kind from
an individual or entity who is NOT his/her employer of record, those payments must be
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disclosed.
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instance, cannot supersede the state constitution because it VIOLATES THE STATE
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Your Affiant states that the state law SBX 211, giving judges immunity in this
Page 11 of 38
Appeal No. 1-14-AP-001825, Dei Gratia v. WACHOVIA MORTGAGE FSB,
HI&RH Empress Aubre Regina Dei Gratia s
Objection to Judge Helen E. Williams for Disqualification for Cause
CONSTITUTION
81.
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appeal.
Your Affiant states that the employer of record for state court judges is the
Your Affiant states that the payments from the COUNTY OF SANTA CLARA in
Your Affiant states that Judge Helen E. Williams acted on the quid-pro-quo by
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to hearing any cases in which the undersigned is a party, in her failure to answer an
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Affidavit served upon her and filed into the public record, as supported by the following
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Your Affiant states that Judge Helen E. Williams has agreed to her lifetime bar
case law.
85.
Your Affiant states that Judge Helen E. Williams declares that the undersigned can
Your Affiant states that Judge Helen E. Williams was noticed by unrebutted
Affidavit of the previous recusal of Judge Helen E. Williams and of the standing of the
undersigned as a Secured Party, with immunity to all state court jurisdiction.
87.
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Your Affiant states that the immunity of a Secured Party does apply to civil cases.
89.
Your Affiant states that the legal maxims, common law, case law, and civil rules
regarding the requirement to answer an Affidavit, and how to answer it, are contained in
the memorandum, for brevity herein.
90.
Your Affiant now objects to the jurisdiction of Judge Helen E. Williams in the
above entitled matter under C.C.P. 170.1, 170.3, 28 USCS Section 144 and Section
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455; and Marshall v Jerrico Inc.; 446 US 238, 242; 100 S.Ct. 1610; 64 L. Ed. 2d 182
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(1980).
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Page 12 of 38
Appeal No. 1-14-AP-001825, Dei Gratia v. WACHOVIA MORTGAGE FSB,
HI&RH Empress Aubre Regina Dei Gratia s
Objection to Judge Helen E. Williams for Disqualification for Cause
91.
FRCP Rule 7(b), Fed. R. of Evid., Rule 201, the case law and common law and maxims
of law set forth in the memorandum herein, and Judge Helen E. Williams admissions, as
set forth in judicially noticed evidence sets previously filed into the instant case, the trial
court case, other incorporated case records, and other federal cases, and incorporated
92.
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The grounds to recuse Judge Helen E. Williams are C.C.P. 170.1, 170.3,
Your Affiant states that "State courts, like federal courts, have a constitutional
Your Affiant states that RI Supreme Court Article VI and Canons 1, 2, and 3.B.6
Your Affiant states that Judge Helen E. Williams has in the past deliberately
violated other litigant's personal liberties, and/or, has wantonly refused to provide due
process and equal protection to all litigants before the court or has behaved in a manner
inconsistent with that which is needed for full, fair, impartial hearings.
95.
Your Affiant states that the undersigned is NOT a 14th Amendment, U.S. (UNITED
Your Affiant states that the undersigned is established and recognized as a Secured
Your Affiant states that the United States Constitution guarantees a neutral (an
unbiased) Judge who will always provide litigants with full protection of ALL RIGHTS.
98.
Your Affiant respectfully demands that Judge Helen E. Williams self recuse in
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incorporated herein, detailing previous recusals in cases involving the undersigned, prior
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unethical and/or illegal conduct or conduct which gives your Affiant good reason to
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believe Judge Helen E. Williams cannot hear the above case in a fair and impartial
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manner.
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Page 13 of 38
Appeal No. 1-14-AP-001825, Dei Gratia v. WACHOVIA MORTGAGE FSB,
HI&RH Empress Aubre Regina Dei Gratia s
Objection to Judge Helen E. Williams for Disqualification for Cause
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In the U.S. v. Kemp, 500 F.3d 257, 281 (3rd Cir.(Pa.),Aug 27, 2007) the court stated,
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The US SUPREME COURT has explained, in interpreting the federal bribery and
gratuity statute, 18 U.S.C. 201, that bribery requires a quid pro quo, which includes an
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v. Sun-Diamond Growers of Cal., 526 U.S. 398, 404, 119 S.Ct. 1402, 143 L.Ed.2d 576
(1999) (quoting 18 U.S.C. 201(b)). This may be contrasted to both a gratuity, which
may constitute merely a reward for some future act that the public official will take (and
may already have determined to take), or for a past act that he has already taken, and to a
noncriminal gift extended to a public official merely to build a reservoir of goodwill that
might ultimately affect one or more of a multitude of unspecified acts, now and in the
future. Id. at 405, 119 S.Ct. 1402. This discussion is equally applicable to bribery in the
honest services fraud context, and we thus conclude that bribery requires a specific
intent to give or re-ceive something of value in exchange for an official act. Id. at 40405, 119 S.Ct. 1402.
In the U.S. v. Kincaid-Chauncey, 556 F.3d 923, 78 Fed. R. Evid. Serv. 1185, (9th Cir.
(Nev.) Feb 20, 2009), the court stated,
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[W]e agree that at least an implicit quid pro quo is required. See Kemp, 500 F.3d at 281
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Page 14 of 38
Appeal No. 1-14-AP-001825, Dei Gratia v. WACHOVIA MORTGAGE FSB,
HI&RH Empress Aubre Regina Dei Gratia s
Objection to Judge Helen E. Williams for Disqualification for Cause
In the U.S. v. Kemp, supra, 500 F.3d at p. 281-282 the court stated in,
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United States v. Park, 421 U.S. 658, 674, 95 S.Ct. 1903, 44 L.Ed.2d 489 (1975). [ ]the
instructions proffered by the District Court repeatedly emphasized the critical quid pro
quo, explaining that [t]o establish such bribery the government must prove beyond a
reasonable doubt that there was a quid pro quo, ... that the benefit was offered in ex-
change for the official act. (App. at 9642.) The Court continued, where there is a stream
of benefits given by a person to favor a public official, ... it need not be shown that any
specific benefit was given in exchange for a specific official act. If you find beyond a
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reasonable doubt that a person gave an official a stream of benefits in implicit exchange
for one or more official acts, you may conclude that a bribery has occurred. (App. at
9643.) Finally, the Court explained,*282 [t]o find the giver of a benefit guilty, you must
find that the giver had a specific intent to give ... something of value in exchange for an
official act, that is, that the accused had the specific intent to engage in such a quid pro
quo exchange. (App. at 9643-44.) This instruction correctly described the law of bribery
And the court stated at p. 282,
whether a gift constitutes a bribe is whether the parties intended for the benefit to be
made in exchange for some official action; the government need not prove that each gift
was provided with the intent to prompt a specific official act. See United States v.
Jennings, 160 F.3d 1006, 1014 (4th Cir.1998). Rather, [t]he quid pro quo requirement is
satisfied so long as the evidence shows a course of conduct of favors and gifts flowing to
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a public official in exchange for a pattern of official actions favorable to the donor. Id.
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Thus, payments may be made with the intent to retain the official's services on an as
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needed basis, so that whenever the opportunity presents itself the official will take
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specific action on the payor's behalf. Id.; see also United States v. Sawyer, 85 F.3d 713,
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Page 15 of 38
Appeal No. 1-14-AP-001825, Dei Gratia v. WACHOVIA MORTGAGE FSB,
HI&RH Empress Aubre Regina Dei Gratia s
Objection to Judge Helen E. Williams for Disqualification for Cause
730 (1st Cir.1996) (stating that a person with continuing and long-term interests before
coax ongoing favorable official action in derogation of the public's right to impartial
official services). While the form and number of gifts may vary, the gifts still constitute a
bribe as long as the essential intent-a specific intent to give or receive something of value
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the United States, Secretary James C. Duff, wrote in Certificate and report to the House
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of Representatives, dated June 18, 2008, I refer to and incorp a true and correct copy.
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Judge Porteus willfully and systematically concealed from litigants and the public
financial transactions, including but not limited to those designated in (d:, by filing false
financial disclosure forms in violation of 18 U.S.C. 1001, 5 U.S.C. App. 4, and Canon
5(C)(6) of the Code of Conduct Of United States Judges, which require the disclosure of
income, gifts, loans, and liabilities. This conduct made it impossible for litigants to seek
recusal or to challenge his failure to recuse himself in cases in which lawyers who
appeared before him had given him cash and other things of value for the Fifth Circuit
Judicial Council and the Judicial Conference
In applying this case to cases involving the COUNTY OF SANTA CLARA, or its
employees, contractors, or agents, under authority of the laws that are in force and effect
Judge Helen E. Williams willfully concealed from litigants the public financial
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transactions including but not limited to those designated in (d, by filing false financial
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disclosure forms in violation of 18 U.S.C. 1001, 5 U.S.C. App. 4, and Canon 5(C)(6) of
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the Code of Conduct Of United States Judges, which require the disclosure of income,
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gifts, loans, and liabilities. This conduct made it impossible for litigants to seek recusal or
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Page 16 of 38
Appeal No. 1-14-AP-001825, Dei Gratia v. WACHOVIA MORTGAGE FSB,
HI&RH Empress Aubre Regina Dei Gratia s
Objection to Judge Helen E. Williams for Disqualification for Cause
to challenge her failure to recuse herself in cases in which partys who appeared before
RECUSAL COUNT #1
C.C.P. 170.1, 170.3(a)(1)
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99.
paragraphs of this objection to judge for disqualification for cause as if fully set forth
herein.
100.
Your Affiant states that CCP 170.3 states in relevant part (a)(1) If a judge
determines himself or herself to be disqualified, the judge shall notify the presiding judge
of the court of his or her recusal and shall not further participate in the proceeding, except
as provided in Section 170.4, unless his or her disqualification is waived by the parties as
provided in subdivision (b).
101.
Your Affiant states that the undersigned has NEVER WAIVED the disqualification
Your Affiant states that Judge Helen Elizabeth Williams has admitted through self
recusal that she was disqualified in case C1096307, PEOPLE v. GUANCIONE that
involved HI&RH Empress Aubre Regina Dei Gratia, also known as Rosalie Aubre
Guancione, as a party.
103.
Your Affiant states that Judge Helen Elizabeth Williams has admitted through self
recusal that she was disqualified in case C1103451, PEOPLE v. GUANCIONE that
20
involved HI&RH Empress Aubre Regina Dei Gratia, also known as Rosalie Aubre
21
Guancione, as a party.
22
104.
23
24
105.
25
26
complaint, that Judge Helen E. Williams has a lifetime bar to jurisdiction in all cases
27
28
Your Affiant states that this admission was made under the Doctrine of Silence is
Your Affiant states that Judge Helen E. Williams admitted pursuant to the doctrine
Page 17 of 38
Appeal No. 1-14-AP-001825, Dei Gratia v. WACHOVIA MORTGAGE FSB,
HI&RH Empress Aubre Regina Dei Gratia s
Objection to Judge Helen E. Williams for Disqualification for Cause
involving the following party: Rosalie Aubre Guancione also known as HI&RH
106.
both civil and criminal liability under Title 42 US Code 1983, 1988, and U.S.
Your Affiant states that a failure to sustain this recusal action is a violation that has
RECUSAL COUNT #2
C.C.P. 170.1, 170.3(b)(2)(A)
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
107.
paragraphs of this objection to judge for disqualification for cause as if fully set forth
herein.
108.
Your Affiant states that CCP 170.3(b) states in relevant part: (2) There shall be no
waiver of disqualification if the basis therefore is either of the following: (A) The judge
has a personal bias or prejudice concerning a party. Emphasis added.
109.
Your Affiant states that Judge Helen E. Williams has a personal bias and / or,
prejudice against the undersigned party, see judicially noticed Affidavits of Truth,
Exhibits B thru F.
110.
Your Affiant states that Judge Helen E. Williams HAS A BIAS OR PREJUDICE
because she has accepted bribes from the COUNTY OF SANTA CLARA that
established a quid -pro-quo relationship between her and the Plaintiff in the instant
case. See section above on Title 18 U.S.C. 201 Bribery; 18 U.S.C. 1346, and related
SUPREME COURT case law provided above, see judicially noticed Email from OFFICE
22
23
111.
24
the court record that was clear proof, and prima facie evidence, that the undersigned
25
possesses immunity to all state incorporated courts in civil proceedings, including the
26
27
28
Your Affiant states that Judge Helen E. Williams was provided with evidence in
Page 18 of 38
Appeal No. 1-14-AP-001825, Dei Gratia v. WACHOVIA MORTGAGE FSB,
HI&RH Empress Aubre Regina Dei Gratia s
Objection to Judge Helen E. Williams for Disqualification for Cause
112.
Your Affiant states that the undersigned is an American National pursuant to Title
8 U.S.C. 1101(a)(21).
113.
Aubre Regina Dei Gratia, the natural living woman and the undersigned, is formally
114.
Judge Helen Elizabeth Williams to hear cases in which the undersigned is a party.
115.
Your Affiant states that Rosalie Aubre Guancione, also known as, Empress
Your Affiant states that the undersigned has NEVER waived the disqualification of
Your Affiant states that pursuant to the full faith and credit clause of the federal
10
STATE OF NEW YORK has recognized the secured party status of HI&RH
11
Empress Aubre Regina Dei Gratia in an official act, pursuant to FRCP 9(d) and Fed.
12
13
116.
14
RECUSED
15
117.
16
17
118.
18
19
20
21
22
23
24
25
Your Affiant states that Judge Helen E. Williams has PREVIOUSLY SELF
in Case #C1096307, PEOPLE v. GUANCIONE.
Your Affiant states that Judge Helen E. Williams has PREVIOUSLY SELF RECUSED
Your Affiant states that Judge Helen E. Williams has acted under color of law in
119.
Your Affiant states that Judge Helen Elizabeth Williams was acting in racketeering
26
27
28
Page 19 of 38
Appeal No. 1-14-AP-001825, Dei Gratia v. WACHOVIA MORTGAGE FSB,
HI&RH Empress Aubre Regina Dei Gratia s
Objection to Judge Helen E. Williams for Disqualification for Cause
120.
rights (given by God) are violated when courts depart from precedent, where parties
are similarly situated. See Anastasoff v. United States, 223 F.3d 898 (8th Cir. 2000);
121.
agreement between herself and the COUNTY OF SANTA CLARA. See section above on
Title 18 U.S.C. 201 Bribery; 18 U.S.C. 1346, and related SUPREME COURT case law.
122.
Your Affiant states that Judge Helen E. Williams ignored the precedents, referred
Your Affiant states that this departure from precedent by Judge Helen E. Williams
10
purposely resulted in denial of civil rights of Appellant Empress Aubre Regina Dei
11
12
123.
13
CV-189409, SFPCU v. Stewart and cross complaint, that she each had a lifetime bar to
14
jurisdiction over ALL cases involving Rosalie Aubre Guancione, also known as
15
Empress Aubre Dei Gratia, the natural woman, a Secured Party, as a party to any case.
16
124.
17
both civil and criminal liability under Title 42 US Code 1983, 1988, and U.S.
18
Your Affiant states that Judge Helen E. Williams, admitted in 2013 in case #107-
Your Affiant states that a failure to sustain this recusal action is a violation that has
19
21
RECUSAL COUNT #3
Title 28 U.S.C. 455(a)
125. Your Affiant repeats, re-alleges, and incorporates by reference the foregoing
22
23
126.
24
section 455(a) have been satisfied by Judge Helen E. Williams. See judicially noticed
25
26
127.
20
27
28
Your Affiant states that all of the required elements for violation of Title 28 U.S.C.
Your Affiant states that the attached Exhibit of payments from the County Auditor,
Page 20 of 38
Appeal No. 1-14-AP-001825, Dei Gratia v. WACHOVIA MORTGAGE FSB,
HI&RH Empress Aubre Regina Dei Gratia s
Objection to Judge Helen E. Williams for Disqualification for Cause
RECUSAL COUNT #4
Title 28 U.S.C. 455(b)(1)
128. Your Affiant repeats, re-alleges, and incorporates by reference the foregoing
4
5
129.
section 455(b)(1) have been satisfied by Judge Helen E. Williams. See judicially noticed
See UNITED STATES SUPREME COURT case law on bribery, quid pro quo, and
10
11
RECUSAL COUNT #5
4 , 5 and 14 Amendments of the federal Constitution of 1787,
As Perviewed thru the 14th Amendment and
California Constitution Article 1 1, 7
12
th
13
14
15
16
17
18
Your Affiant states that all of the required elements for violation of Title 28 U.S.C.
130.
th
th
Your Affiant states that the federal Constitution of 1787 and each of the
Your Affiant states that the federal Constitution of 1787 and all of the amendments
19
thereto is an enforceable contract for protection of the inalienable God given civil rights
20
of the undersigned.
21
133.
22
enforceable contracts for protection of the inalienable God given civil rights of the
23
undersigned.
24
134.
25
Your Affiant states that each of the three state constitutions for California are
Your Affiant states that the undersigned has an inalienable God given civil right to
26
27
28
Page 21 of 38
Appeal No. 1-14-AP-001825, Dei Gratia v. WACHOVIA MORTGAGE FSB,
HI&RH Empress Aubre Regina Dei Gratia s
Objection to Judge Helen E. Williams for Disqualification for Cause
135.
Your Affiant states that the undersigned had a reasonable expectation of the
136.
137.
189409, SFPCU v. Stewart and cross complaint, to the truthfulness of the facts that the
138.
10
Stewart and cross complaint, that she knew of her lifetime bar to presiding in cases
11
12
139.
13
appeal, though Judge Helen E. Williams has previously admitted to having a lifetime bar
14
15
140.
16
recusal that she was disqualified in case C1096307, PEOPLE v. GUANCIONE that
17
involved HI&RH Empress Aubre Regina Dei Gratia, also known as Rosalie Aubre
18
Guancione, as a party.
19
141.
20
recusal that she was disqualified in case C1103451, PEOPLE v. GUANCIONE that
21
involved HI&RH Empress Aubre Regina Dei Gratia, also known as Rosalie Aubre
22
Guancione, as a party.
23
142.
24
recused from a case involving a litigant that the judge is deemed disqualified in all other
25
cases involving the same litigant, which satisfies a mandatory self recusal requirement.
Your Affiant states that Judge Helen E. Williams has admitted that she has no
Your Affiant states that Judge Helen E. Williams has admitted in case #107-CV-
Your Affiant states that Judge Helen E. Williams has, as shown by her tacit
Your Affiant states that Judge Helen E. Williams issued orders in the instant
Your Affiant states that Judge Helen Elizabeth Williams has admitted through self
Your Affiant states that Judge Helen Elizabeth Williams has admitted through self
Your Affiant states that the publics general presumption is that once a judge is
26
27
28
Page 22 of 38
Appeal No. 1-14-AP-001825, Dei Gratia v. WACHOVIA MORTGAGE FSB,
HI&RH Empress Aubre Regina Dei Gratia s
Objection to Judge Helen E. Williams for Disqualification for Cause
143.
Your Affiant states that Judge Helen E. Williams has wantonly ignored a duty to
self recuse from the instant state involving the undersigned as a litigant.
144.
violation of the undersigneds civil rights to both due process and equal protection under
145.
instant appeal case and worked in concert with other judges to violate both the
due process and equal protection under the law, and in corum non judice, and including
Your Affiant that Judge Helen E. Williams is presiding in the instant appeal, in
Your Affiant states that when Judge Helen E. Williams accepted jurisdiction of the
10
11
146.
12
of court or otherwise in the instant appeal case and when she signed any order in the
13
instant appeal case, that Judge Helen E. Williams, did so in conspiracy with other judicial
14
15
16
147.
17
the current presiding judge, Judge Ris Jones Pichon; former presiding judge, Judge
18
Brian Walsh; the Court CEO, David H. Yamasaki; the Civil Court Director Alicia Vojnik,
19
20
148.
21
case without jurisdiction, in corum non judice, in violation of the 4th, 5th, and 14th
22
23
Constitution of the California Republic, and Title 42 U.S.C. 1986 and the undersigneds
24
25
149.
26
involving the undersigned as a party, it was without jurisdiction, in corum non judice, in
27
28
Your Affiant states that when Judge Helen E. Williams conducted any simulation
Your Affiant states that Judge Helen E. Williams was insufficiently supervised by
Your Affiant states that Judge Helen E. Williams issued orders in the instant appeal
Your Affiant states that when Judge Helen E. Williams was assigned to cases
Page 23 of 38
Appeal No. 1-14-AP-001825, Dei Gratia v. WACHOVIA MORTGAGE FSB,
HI&RH Empress Aubre Regina Dei Gratia s
Objection to Judge Helen E. Williams for Disqualification for Cause
1
2
3
4
violation of Title 42 U.S.C. 1986 and the undersigneds civil rights, and in corum non
judice.
RECUSAL COUNT #6
Judge Helen E. Williams has Accepted Unreported and Undisclosed Bribes in
Violation of Penal Code 93 and 18 U.S.C. 1346
150.
151.
152.
10
wantonly disregarded her duty to report to litigants in cases that she presided in, and to
11
disclose the payments that she received from the COUNTY OF SANTA CLARA on
12
annual financial disclosure Form 700. See exhibit email, attached, documenting
13
14
CONTROLLER. See section above on Title 18 U.S.C. 201 Bribery; 18 U.S.C. 1346, and
15
16
153.
17
undersigned, the payments that she received from the COUNTY OF SANTA CLARA.
18
154.
19
that public funds would not be used to bribe Judge Helen E. Williams.
20
155.
21
22
called local judicial benefits. See Exhibits from SANTA CLARA COUNTY AUDITOR.
23
See section above on Title 18 U.S.C. 201 Bribery; 18 U.S.C. 1346, and related
24
25
156.
26
other funds including: the POLICE OFFICERS ASSOCIATION FUND; the SANTA
27
28
Your Affiant states that Judge Helen E. Williams did not disclose, to the
Your Affiant states that the undersigned had a reasonable expectation to believe
Your Affiant states that the public funds used to bribe Judge Helen E. Williams
Your Affiant states that Judge Helen E. Williams has also received bribery through
Page 24 of 38
Appeal No. 1-14-AP-001825, Dei Gratia v. WACHOVIA MORTGAGE FSB,
HI&RH Empress Aubre Regina Dei Gratia s
Objection to Judge Helen E. Williams for Disqualification for Cause
CLARA COUNTY SHERIFFS FUND; the JUDGES TRUST FUND; the COUNTY OF
SANTA CLARA LAW LIBRARY FOUNDATION; and numerous other slush funds.
157.
taxes paid by the undersigned were used by the COUNTY OF SANTA CLARA to bribe
Judge Helen E. Williams. See section above on Title 18 U.S.C. 201 Bribery; 18 U.S.C.
158.
property transfer made in this county thru property transfer tax, and increased property
Your Affiant states that a portion of the COUNTY OF SANTA CLARA property
Your Affiant states that the COUNTY OF SANTA CLARA profits from every real
10
159.
11
OF SANTA CLARA to each of the judges working in the COUNTY OF SANTA CLARA
12
buys and insures good will from the judges, as a quid-pro-quo payment. See section
13
above on Title 18 U.S.C. 201 Bribery; 18 U.S.C. 1346, and related SUPREME COURT
14
case law.
15
160.
16
payments from the COUNTY OF SANTA CLARA, an undisclosed party to the traffic
17
court case, constitute bribes, that resulted in denial of due process as guaranteed by the
18
4th, 5th, and 14th Amendments of the federal Constitution of 1787, to the undersigned.
19
161.
20
payments from the COUNTY OF SANTA CLARA, an undisclosed party to the traffic
21
court case, constitute bribes that resulted in denial of due process as guaranteed by Article
22
23
162.
24
payments that constitute bribes, resulted in denial of equal protection under the law as
25
26
undersigned.
27
28
Your Affiant states that the payments of local judicial benefits from the COUNTY
Your Affiant states that Judge Helen E. Williams bias due to acceptance of
Your Affiant states that Judge Helen E. Williams bias due to acceptance of
Your Affiant states that Judge Helen E. Williams bias due to acceptance of
Page 25 of 38
Appeal No. 1-14-AP-001825, Dei Gratia v. WACHOVIA MORTGAGE FSB,
HI&RH Empress Aubre Regina Dei Gratia s
Objection to Judge Helen E. Williams for Disqualification for Cause
163.
Your Affiant states that Judge Helen E. Williams bias due to acceptance of
payments that constitute bribes, resulted in denial of the right to private property
undersigned.
164.
CLARA, and are listed below (request judicial notice of attached email from the auditor):
Your Affiant states that county payments to Judge Helen E. Williams were
8
9
10
Calendar
Year Paid
Wages (Other
Compensation)
11
2012
$0.00
$328.85
12
2013
$1,394.74
$9,025.12
13
2014
$1,412.70
$9,025.12
14
2015
$676.17
$3,800.05
15
Grand
Total
$3,483.61
$22,179.14
16
17
165.
18
payments that constitute bribes which resulted in violation of the undersigneds civil
19
rights.
20
166.
21
the threshold for a felony payment or bribe in the year 2013 pursuant to PC 92/93.
22
23
Your Affiant states that Judge Helen E. Williams bias is due to acceptance of
Your Affiant states that the payments received by Judge Helen E. Williams exceed
Prayer
Petitioner, the undersigned Affiant, prays that:
24
Judge Helen E. Williams self recuse in the instant case, and the clerk notify the Judicial
25
Council to appoint another judge to preside over the instant appeal, or in the alternative
26
27
28
Page 26 of 38
Appeal No. 1-14-AP-001825, Dei Gratia v. WACHOVIA MORTGAGE FSB,
HI&RH Empress Aubre Regina Dei Gratia s
Objection to Judge Helen E. Williams for Disqualification for Cause
2.
Judge Helen E. Williams give statutory consent to recusal, and the court clerk
notify the Judicial Council to assign another judge to preside over the instant appeal, or in
the alternative
3.
that has not been previously recused in any case involving the undersigned as a party, to
Judge Helen E. Williams notify the Judicial Council to appoint a neutral judge,
A judge may not pass on her own recusal. Attempts to strike this lawful and legal
action will be deemed an attempt by the judge to pass on the judges own recusal, in
violation of the law, done in bad faith, and a further attempt to deny the undersigneds
10
11
civil rights.
Opposition to an Affidavit must be in Affidavit form, with point for point answer,
12
13
summary judgment strike. Any attempt to strike this affidavit will be both non-responsive
14
to this action and stricken by the undersigned pursuant to the rules of Admiralty, and
15
FRCP rule 12(f) as scandalous, as Judge Helen E. Williams has admitted to having no
16
17
18
19
20
21
22
23
24
25
26
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VERIFICATION
167.
The signer certifies that to the best of his/her knowledge, information, and belief,
it is not being presented for any improper purpose, such as to harass, cause
the claims, defenses, and other legal contentions are warranted by existing law or
will likely have evidentiary support after a reasonable opportunity for further
Page 27 of 38
Appeal No. 1-14-AP-001825, Dei Gratia v. WACHOVIA MORTGAGE FSB,
HI&RH Empress Aubre Regina Dei Gratia s
Objection to Judge Helen E. Williams for Disqualification for Cause
(4)
4
5
6
7
the denials of factual contentions are warranted on the evidence or, if specifically
WHEREFORE, your Affiant, prays that this objection to judge for disqualification
8
9
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13
15
By:
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Page 28 of 38
Appeal No. 1-14-AP-001825, Dei Gratia v. WACHOVIA MORTGAGE FSB,
HI&RH Empress Aubre Regina Dei Gratia s
Objection to Judge Helen E. Williams for Disqualification for Cause
1
2
3
10)
1787, and the SUPREME COURT ruling in Marbury v. Madison both establish that
the federal Constitution and UNITED STATES SUPREME COURT rulings are the
11)
Your Affiant states that the Supremacy Clause of the federal Constitution of
Your Affiant states that UNITED STATES SUPREME COURT rulings are
10
12)
11
12
13
practical consequence.
14
13)
15
16
14)
17
Affidavit form that the undersigned was never noticed of a final order in the trial court
18
19
15)
20
evidence that refuted any presumption of mailing of the final order by the clerk of the
21
court.
22
16)
23
24
17)
25
26
27
28
Your Affiant states that UNITED STATES SUPREME COURT ruling in 339
Your Affiant states that the undersigned was not given proper notice of any final
Your Affiant states that the undersigned provided uncontroverted evidence in
Page 29 of 38
Appeal No. 1-14-AP-001825, Dei Gratia v. WACHOVIA MORTGAGE FSB,
HI&RH Empress Aubre Regina Dei Gratia s
Objection to Judge Helen E. Williams for Disqualification for Cause
18)
Your Affiant states that the denial of the undersigneds civil rights by Judge Mary
E. Arand, and in collusion with Judge Helen E. Williams, rises from the level of mere
19)
Helen E. Williams and Mary E. Arand to issue a fraudulent summary judgment to dismiss
20)
party.
Your Affiant states that your Appellant is damaged by the conspiracy of Judges
Your Affiant states that Judge Helen E. Williams agreed to recusal, in 2013, in
10
21)
11
12
party.
13
22)
14
for failure to reply or rebut when she agreed to the recusal in 2013 in case
15
16
23)
17
for failure to reply or rebut when she agreed to the recusal in 2013 in case #C1103451,
18
19
24)
20
With Prejudice.
21
25)
22
affidavits is necessary to make the prima facie case. United States v. Kis, 658 F.2nd,
23
526, 536 (7th Cir. 1981); Cert. Denied, 50 US LW 2169; S. Ct. March 22, 1982.
24
26)
25
26
27
28
Your Affiant states that Judge Helen E. Williams agreed to recusal, in 2013, in
Your Affiant states that a Nihil Dicit was taken against Judge Helen E. Williams
Your Affiant states that a Nihil Dicit was taken against Judge Helen E. Williams
Your Affiant states that Silence can only be equated with fraud where there is
Page 30 of 38
Appeal No. 1-14-AP-001825, Dei Gratia v. WACHOVIA MORTGAGE FSB,
HI&RH Empress Aubre Regina Dei Gratia s
Objection to Judge Helen E. Williams for Disqualification for Cause
27)
failure to file it within the deadline, may be deemed consent to the granting or denial
of the motion. United States District Court, Central District of California, L.R. 7-12.
28)
29)
points. It is not possible for the district judge to weight the affidavits in order to
resolve disputed issues; accept in those rare cases where the facts alleged in an
Your Affiant states that The failure to file any required document, or the
Your Affiant states that Court of Appeals may not assume the truth of
Your Affiant states that Where affidavits are directly conflicting on material
10
the affidavit, the district judge has not basis for determination of credibility. Data
11
Disc, Inc v Systems Tech. Assocs., Inc. 557 F. 2d 1280 (9th Cir. 1977)
12
30)
13
14
the truth of the matter. Legal Maxim: "He who doesn't deny, admits."
15
31)
16
17
18
affidavits wherein the points remaining unrebutted in the end stand as truth and
19
20
32)
21
point-for-point. And any rebuttal must have evidence provided to the Affiant to
22
demonstrate why the Affiants point isnt true, and the Respondent needs to provide
23
his/her rebuttal in sworn affidavit form. Now as long as you have your believed truth
24
on the affidavit, they are NOT going to rebut your facts with their fiction,
25
guaranteed!
Your Affiant states that A Maxim of Law states, An affidavit must be rebutted
26
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Page 31 of 38
Appeal No. 1-14-AP-001825, Dei Gratia v. WACHOVIA MORTGAGE FSB,
HI&RH Empress Aubre Regina Dei Gratia s
Objection to Judge Helen E. Williams for Disqualification for Cause
33)
true.
34)
affidavit.
35)
Power, LLC, No. 07-C-10 (E.D.Wis. 04/13/2007) (defendant's affidavit presumed true,
Your Affiant states that Morris v National Cash Register, 44 S.W. 2d 433,
Your Affiant states that Group v Finletter, 108 F. Supp. 327 Allegations in
Your Affiant states that Orion Construction Group, LLC v. Berkshire Wind
10
36)
11
12
37)
13
14
38)
15
Admissions by silence, in relevant part his failure to speak has traditionally been
16
17
39)
18
unrebutted Affidavit is an admission of the truth of all of the facts stated in the
19
Affidavit.
20
Your Affiant states that Glass v. Pfeffer, 849 F.2d 1261, 1267 (10th Cir. 1988)
Your Affiant states that An unrebutted Affidavit stands as a bar by estoppel to
Your Affiant states that Blacks Law Dictionary, 6th Edition, page 48, defines
Your Affiant states that each of the previous case laws cited indicates that an
21
22
23
24
25
26
27
28
Page 32 of 38
Appeal No. 1-14-AP-001825, Dei Gratia v. WACHOVIA MORTGAGE FSB,
HI&RH Empress Aubre Regina Dei Gratia s
Objection to Judge Helen E. Williams for Disqualification for Cause
1
2
3
By:
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Page 33 of 38
Appeal No. 1-14-AP-001825, Dei Gratia v. WACHOVIA MORTGAGE FSB,
HI&RH Empress Aubre Regina Dei Gratia s
Objection to Judge Helen E. Williams for Disqualification for Cause
1
2
3
4
5
6
7
8
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EXHIBIT A
PRIMA FACIE EVIDENCE OF BRIBERY
EMAIL CONTAINING AMOUNTS OF PAYMENTS FROM
COUNTY OF SANTA CLARA TO JUDGE HELEN E. WILLIAMS
WHICH ESTABLISHED THE QUID PRO QUO
1
2
Attached you will find the information responsive to your California Public Records Request made to the
County of Santa Clara in an email to Susana Lee, Administrative Support Officer with Employee Services
Agency, dated May 27, 2015. There is no cost for these documents as we are able to provide them to you
electronically.
5
6
7
8
9
10
11
12
13
Calendar
Year Paid
Wages (Other
Compensation)
14
2012
$0.00
$328.85
15
2013
$1,394.74
$9,025.12
16
2014
$1,412.70
$9,025.12
17
2015
$676.17
$3,800.05
18
Grand Total
$3,483.61
$22,179.14
19
20
21
22
23
24
25
----------------------
Original Message
26
27
Dear Ms Lee,
28
Pursuant to the provisions of the California Public Records Act, a request is hereby made for
documents showing all payments from Santa Clara County commonly known as:
1
2
3
4
5
6
7
8
9
10
11
12
Thank you in advance for your attention to this most urgent matter. Your efforts are greatly
appreciated.
13
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1
2
3
4
5
6
7
8
9
10
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12
13
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15
)
)
)
)
)
)
)
)
16
17
HI&RH Empress Aubre Dei Gratia, the natural living woman, has filed and
18
served an objection to Judge Helen E. Williams for cause for disqualification, that
19
includes two previous self recusals of Judge Helen E. Williams in Cases C1096307,
20
21
notarized Affidavits of Bias of Judge Helen E. Williams against the Plaintiff by case
22
non-parties who are members of the public. The Plaintiff seeks to recuse Judge Helen
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E. Williams from the instant case, under a presumption of bias based on two previous
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self recusals, public perception of bias by Judge Helen E. Williams, and pursuant to
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C.C.P. 170.1, 170.3; violations of due process and equal protection: 4 th, 5th, 14th
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recusal of Title 28 455; violations of right to private property and due process
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STEWART and cross complaint, regarding Judge Helen E. Williams admission as truth
the fact that Judge Helen E. Williams has a lifetime bar to hear any cases involving
Plaintiff Empress Aubre Regina Dei Gratia, the natural living woman and Secured
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Good cause appearing, the motion of HI&RH Empress Aubre Regina Dei Gratia, to
recuse Judge Helen E. Williams from the instant case is sustained, and
By order of the Court, Judge Helen E. Williams is recused from the instant appeal, and
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another appellate judge that has not been recused in any previous case involving
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Date: ____/____/20___
_____________________________
SUPERIOR COURT JUDGE