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JOSEPH LEWIS AGUIRRE

P.O. Box 154 Trabuco Canyon 92678


The CotoBuzz Journal

Tel: 949-NEW-WEBO

http://www.cotobuzz.com
March 8, 2014
Office of the Chief Trial Counsel/Intake
State Bar of California
1149 South Hill Street
Los Angeles, California 90015-2299
The Orange County Sheriffs Department
The Orange County District Attorneys Office
The CotoBuzz Journal
Fish & Associates

CC.

Re: Formal Bar Complaint Against Fish & Associates, Mei Tsang #237959 and Joseph A.
Andelin #274105
Dear Chief Trial Counsel, California Bar:
This is my formal Bar complaint against the law firm Fish & Associates, California-licensed
attorneys Mei Tseng and Joseph A. Andelin, who as legal representatives for the CZ Master
Association board of directors composed of Robert Varo, Xochitl Yocham, Phillip Mitchell Robert
Curran and Lyle Schielder (the Association) enable the Association to engage with impunity in
questionable practices such as the ones listed below:
I am 20+-year resident in the common interest development managed by the, and publisher of
the CotoBuzz Journal, a journal of general circulation and ardent critic of the Associations board
of directors under Mr. Varos watch..
Some of the questionable practices include:

Harassment
Abuse of power
Depraved Indifference
Extortion
Activity deemed a crime in violation of Corporations Code 7231.5 & Sarbanes Oxly Act
(SOX) 18 USC Section 1519 See Exhibit G
Censorship - Strategic lawsuit against public participation (SLAPP)
Possible violation of the RICO Act
Claiming in word and deed that the Association is beyond the jurisdiction of local, state
and federal law.
Violations of IRS 990 regulations

Support for this argument includes complaints filed by Joseph Morabito, William Kirkendale,
Edward Caruso and other residents of the CZ Master Association These complaints include
California Bar Complaints, Complaints to the California Attorney General, Complaints to
numerous California government entities and more than 300,000 pieces published in the
CotoBuzz Journal (www.cotobuzz.com)
The CotoBuzz Journal is a digital newspaper focused on public safety, education, elder abuse,
politics and common interest development (HOA/CID) published as a public service. The
Cotobuzz Journals regular contributors include Los Angeles Times columnist and Author Donnie
Vanitizian, HOA advocate George K Starpoli, Christs Street, Michel& Associates, P.C. Education
Activist Larry Sand and Education activist Dr. Bill Evers, an advisor to Presidential Candidate Mitt
Romney.
Re: Formal Bar Complaint Against Mei Tsang and Joseph Andolin

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JOSEPH LEWIS AGUIRRE


P.O. Box 154 Trabuco Canyon 92678
The CotoBuzz Journal

Tel: 949-NEW-WEBO

http://www.cotobuzz.com
Motive:
The motive is simple: A personal vendetta by Mr. Robert Varo, who as a member of the CZ
Master Association board of directors, together with his associates have ruled the association
with an iron fist and have terrorized the community for more than a decade, and because of their
depraved indifference, three preventable, traffic fatalities have occurred, the last one, just this
January 31, 2014! Refer to open letter to the Association requesting the directors resignation,
titled 3rd traffic death in Coto de Caza in this board's watch Time for CZ Board of
Directors to step down: http://cotobuzz.blogspot.com/2014/02/3rd-traffic-death-in-coto-de-cazain.html
Mr. Varo took control of the association over ten years ago and transformed it from a bucolic,
peaceful, community to the most litigious homeowners association in Southern California with the
worse public safety record of similar communities and who has not hesitated to use legal
resources funded by the associations own residents to silence them. Refer to Exhibit F The
CZ Master Association the most litigious HOA in Southern California
The Associations Depraved Indifference
One week before my next door, then 15-year old neighbor Rhyanna Woolsey, was involved in a
fatal traffic accident two miles from my home, I begged Mr. Varo, the California Attorney General,
Keystone Pacifics Carey Treff, the associations property manager and anyone who would listen,
to take immediate action due to a high incidence of traffic accidents directly associated with Mr.
Varos firing of the California Highway Patrol (CHP) I did not even get a response.
Three months later, 75 year old Morteza Manian was killed by a teen driver, 1.5 miles from my
house. Finally, I drove local public opinion against the beheaded decision to fire the CHP, and
the Association was coerced into rehiring the CHP shortly thereafter.
A few months later, the CHP patrol hours were significantly reduced with a predictable increase
in traffic accidents. Again, I raised my concerns, which went unheeded with yet a third fatality.
Refer to Exhibit E Depraved Indifference Traffic fatalities as a function of time spend on
proactive traffic patrol. To be clear, this is not a money issue. Mr. Varo has publicly
expressed his disgust for law and order and his dislike for CHP management, which he called in
an open public meeting, extortionists. While the Association spends roughly $100,000 per year
for proactive CHP patrol, it spends close to $1.5 million dollars in a a private security company
used as a glorified meter maid and as personal courier by the Associations directors.
In addition to Mr. Varos personal disdain for law and order, director Xochtil Yocham called a
septuagenarian resident a neglected child, and another with a disabled daughter an old
misogynist. Just standard operating procedure
Associations Abuse of Power Refer to EXHIBIT H Abuse of Power- Mr. Kirkendales
Draft Candidacy Statement
In addition to all the threatening legal letters I have received from the Association over the last ten
years, Mr. Varo and his associates have transformed the Coto de Caza community into their own
private fiefdom. While by statue, the association is required to repair, replace and maintain, it is
now using 1/3 of the yearly budget, to subsidize Mr. Varos friends, while punishing those who
dare to criticize their lack of concern for the rule of law and fiscal irresponsibility. Directors have
threatened to withhold services if they complain to the press, including the CotoBuzz Journal.

Re: Formal Bar Complaint Against Mei Tsang and Joseph Andolin

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JOSEPH LEWIS AGUIRRE


P.O. Box 154 Trabuco Canyon 92678
The CotoBuzz Journal

Tel: 949-NEW-WEBO

http://www.cotobuzz.com
Other violations by the Association
Other violations include the CZ Master Associations disdain for the IRS Form 990 Regulation,
Californias SB61 and 1560 requiring direct elections, criminal violations of Sarbanes-Oxley Act,
Violations of California Law anent Oak tree removal, routine violations of California Civil Code
sections 1365 and continued mockery of the USPTO Trademark Process
Under Mr. Varos management, the association is the most litigious association in Southern
California See Exhibit F
Specific Complaints against Fish & Associates, Mei Tsang and Joseph A. Andelin
Rule 1-120. Assisting, Soliciting, or Inducing Violations
In a threatening letter dated February 28, 2014 Mei Tsang asserts that our client has expended a
great deal of time and money to build up considerable recognition and goodwill in its trademark
which includes a CZ logo having Registration Number 4,413,608 It also references an Exhibit
A. There are many problems with the statement: Refer to Exhibit A Letter from Mei Tsang
A. For months, I have been invoicing the association for trademark infringement. Not only has
the Association refused to pay, it also has never been able to produce any evidence that it owns
any trademarks. Refer to Exhibit B Intent to File Small Claims Regarding Refusal to Pay Late
Invoices
B. A search for CZ Logo Registration number, in the US Trademark and Patent Offices
Trademark Electronic Search System (TESS, as described in Ms. Tsengs letter, returns the
following : No TESS records were found to match the criteria of your query
Likewise for the registration 4,413,608
C. Since the letter does not include the referenced Exhibit A, and the registration number is not
found in TESS, I assume that Mei Tsang refers to the CotoBuzz Journal mark 3,259,879 which I
properly registered with the USPTO Refer to Exhibit C The CotoBuzz Journals Logo, properly
registered with the USPTO
D. The only time and money the association has spent pertaining to trademarks is the legal fees
buying intellectually dishonest legal counsel to exhort my properly registered trademarks. For
example, I followed the USPTO process to properly register mark 3,243,122. The Coto de Caza
Golf Club, a for profit organization, among others, is using a similar mark, however the
Association, a non-profit organization that by statue is supposed to focus on repair, maintain and
replace, only uses legal resources to sabotage my properly registered intellectual property, yet
does not lift a finger against the use of a similar mark by the Coto de Caza Golf Club and other for
profit organizations. Refer to Exhibit D Properly registered Mark CotoLifeStyle 3,243,122.
The Association has certainly failed to produce documentation over the last ten years to
substantiate it has properly registered intellectual property.

Arguing that the Association is beyond local, state and federal jurisdiction
In addition to numerous state, local and federal law regulations by the Association, Mr. Andlin, on
the Associations behalf, mocks the USPTO trademark process first by stating that the so-called
CZ logo is owned by the Association. The USPTO trademark Certificate of Registration is clear:
The registration shall remain in force for then years, unless terminated earlier as provided by law
and subject to compliance with the provisions of Section 8 of the Trademark Act of 1946, as
amended. - While I firmly believe I have followed the USPTO registration process for all of my
trademarks, Mr. Varo and his associates have had a chance to challenge the USPTO process
Re: Formal Bar Complaint Against Mei Tsang and Joseph Andolin

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JOSEPH LEWIS AGUIRRE


P.O. Box 154 Trabuco Canyon 92678
The CotoBuzz Journal

Tel: 949-NEW-WEBO

http://www.cotobuzz.com
from the day I started the registration process, but have failed to do so. Instead it has used
significant legal resources, including Southern California law firms Knobbe Martens Olsoen &
Bear, Cane Walker & Harkins LLP, Fish & Associates and attorneys Steve Zipperman, James
Harkins, Diane Reed, Joseph Andelin and Mei Tsang for example in an attempt to intimidate me
into submission.
In fact, on or about March March 21, 2007, Mr, Varo and his associates worked with Orange
County Register reporter Mark Eades (meads@ocregister.com) to turn public opinion against my
registration of the ,386 Mark but also DOVE CANYON(3,181,975) COTO DE CAZA (3,137,363)
RANCHO SANTA MARGARITA (3,072,319) and others. Refer to Article published Wednesday
21, 2007 titled Coto resident trademarks local community names. The article was actively
pushed nationally by Mr. Eades and the Orange County Register. Another example of Mr. Varo
and associations trying to make a mockery of the USPTO trademark process.
While I will remove the properly registered The CotoBuzz Journal trademark from the
cotobuzz.com website without prejudice, as Mei Tsang has demanded in the letter in Exhibit A,
should the Bar decide not to proceed with sanctions, I reserve the right to pursue other avenues
to make Fish and Associates, Joseph Andolin, Mei Tsang and the Association, accountable.
Please note that I am planning to publish this letter, along with the Bars response, in the
CotoBuzz Journal.
Let me know if you need additional information as I am looking forward to hearing from you at
your earliest convenience.

Joseph Lewis Aguirre


Publisher, The CotoBuzz Journal
http://www.cotobuzz.com
Email Buzz@cotobuzz.com

Re: Formal Bar Complaint Against Mei Tsang and Joseph Andolin

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JOSEPH LEWIS AGUIRRE


P.O. Box 154 Trabuco Canyon 92678
The CotoBuzz Journal

Tel: 949-NEW-WEBO

http://www.cotobuzz.com
Exhibit A Letter from Mei Tsang

Re: Formal Bar Complaint Against Mei Tsang and Joseph Andolin

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JOSEPH LEWIS AGUIRRE


P.O. Box 154 Trabuco Canyon 92678
The CotoBuzz Journal

Tel: 949-NEW-WEBO

http://www.cotobuzz.com
Appendix A Letter from Mei Tsang Continued

Re: Formal Bar Complaint Against Mei Tsang and Joseph Andolin

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JOSEPH LEWIS AGUIRRE


P.O. Box 154 Trabuco Canyon 92678
The CotoBuzz Journal

Tel: 949-NEW-WEBO

http://www.cotobuzz.com
Exhibit B Intent to File Small Claims Regarding Refusal to Pay Late Invoices

Re: Formal Bar Complaint Against Mei Tsang and Joseph Andolin

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JOSEPH LEWIS AGUIRRE


P.O. Box 154 Trabuco Canyon 92678
The CotoBuzz Journal

Tel: 949-NEW-WEBO

http://www.cotobuzz.com
Exhibit C the CotoBuzz Journals Logo, properly registered with the USPTO

Re: Formal Bar Complaint Against Mei Tsang and Joseph Andolin

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JOSEPH LEWIS AGUIRRE


P.O. Box 154 Trabuco Canyon 92678
The CotoBuzz Journal

Tel: 949-NEW-WEBO

http://www.cotobuzz.com
Exhibit D Properly registered Mark CotoLifeStyle 3,243,122 and use of similar mark by for
profit organization, Coto de Caza Golf Club.

Re: Formal Bar Complaint Against Mei Tsang and Joseph Andolin

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JOSEPH LEWIS AGUIRRE


P.O. Box 154 Trabuco Canyon 92678
The CotoBuzz Journal

Tel: 949-NEW-WEBO

http://www.cotobuzz.com
Exhibit E Depraved Indifference Traffic fatalities as a function of time spend on
proactive traffic patrol.

Re: Formal Bar Complaint Against Mei Tsang and Joseph Andolin

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JOSEPH LEWIS AGUIRRE


P.O. Box 154 Trabuco Canyon 92678
The CotoBuzz Journal

Tel: 949-NEW-WEBO

http://www.cotobuzz.com
EXHIBIT F The CZ Master Association the most litigious HOA in Southern California

Consider that Since 2007, the CZ board Master Association board has filed 165 cases with the
Orange County Small Claims Court, while the much larger SAMLARC has filed zero complaints,
the Dove Canyon association has filed 15 cases filed for the same period and five for Ladera
Ranch. SAMLARC comprises roughly 13,000 units and maintains most streetscapes, medians,
parks and trails within the community. Dove Canyon is a private residential community located in
eastern Rancho Santa Margarita with approximately 1,200 homes and 5,000 residents. The CZ
Master Association consists of approximately 3,400 homes.
Clearly, there is something wrong, and Mr. Varo is at the center.
For additional details, refer to: http://cotobuzz.blogspot.com/2012/10/litigious-coto-de-cazahomeowners.html

For additional details, refer to: http://cotobuzz.blogspot.com/2012/10/litigious-coto-de-cazahomeowners.html

Re: Formal Bar Complaint Against Mei Tsang and Joseph Andolin

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JOSEPH LEWIS AGUIRRE


P.O. Box 154 Trabuco Canyon 92678
The CotoBuzz Journal

Tel: 949-NEW-WEBO

http://www.cotobuzz.com
EXHIBIT G Fabricating Evidence
March 4, 2007
VIA POST AND EMAIL

Wendy Peterson
KMOB
2040 Main Street, 14th Floor
Irvine, CA 92614

Mrs. Peterson:
FYR:
I trust KMOB did not participate with the CZ Master Board of directors in their
intent to acquire my intellectual property under false pretenses, and it was mostly
an issue of incompetence on KMOB's part.
Regards

Sincerely

Joseph Lewis Aguirre

Re: Formal Bar Complaint Against Mei Tsang and Joseph Andolin

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JOSEPH LEWIS AGUIRRE


P.O. Box 154 Trabuco Canyon 92678
The CotoBuzz Journal

Tel: 949-NEW-WEBO

http://www.cotobuzz.com
James Harkins, IV jharkins@linkline.com
Cane, Walker & Harkins LLP
17821 East Seventeenth Street, Suite 140
Tustin, CA 92780
c.c. CZ Master Association BOD: Szipperman; Xochitl Yocham; wjmezger@cox.net;
robert.r.varo@mail.sprint.com; Ctref@Keystonepacific. Com

c.c. Cary Treff


Ctref@Keystonepacific. Com
Keystone Pacific

29883 Santa Margarita Parkway, Suite 600


Rancho Santa Margarita, CA 92688
Infringement upon @WEBOs Intellectual Property by the CZ Association
Given the boards vicious and ethically challenged attempt at getting control of my properly
acquired intellectual property, you and the board are hereby placed on notice the CZ Master
Association does not have permission to use any of my intellectual property, including any
copyrighted material and uncancelled, unrevoked federally registered trademarks. Had the
associations motives been noble in this latest attack, a good faith approach would have
been to establish a dialogue after all, an attorney who sits on the board of directors
is within shouting distance from me!

Therefore, I expect that by March 15, 2007 the CZ Master Association will take the
necessary steps to assure that the community is not infringing upon my intellectual property
rights.
This specifically includes:
Mezgers use of the mark Coto de Caza, as well as the use of any and all my trademarks
used by service providers, such as UPS, Keystone and GateWorks, for instance.
The use on any and all of my intellectual property as used by CotoVoice and the Trabuco
Canyon News
The use of any sales collateral used by any real estate agent operating in the community
I will also hold the board of directors responsible collectively and individually for any infringement,
interference with any and all my intellectual property interests and further attempts at intimidation.
I expect to hear from you no later than March 7, 2007, otherwise I can only assume that the board
is not inclined to respect my intellectual property and will proceed accordingly.

Sincerely

Joseph Lewis Aguirre


Re: Formal Bar Complaint Against Mei Tsang and Joseph Andolin

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JOSEPH LEWIS AGUIRRE


P.O. Box 154 Trabuco Canyon 92678
The CotoBuzz Journal

Tel: 949-NEW-WEBO

http://www.cotobuzz.com
EXHIBIT H Abuse of Power- Mr. Kirkendales Draft Candidacy Statement
To: CZ Master board:
March 6, 2014
Re: My Candidacy and qualifications to be a candidate for the association board of
directors.
Ladies and Gentlemen:
You folks are well acquainted with me as a result of a number of arguments and disputes
we've had over the years about how you treat residents who disagree with you. One of you
even referred to me one time as "An old misogynist" .....meaning old woman hater.
Now aside from those kinds of uncalled for remarks I have had a good relationship with
several of your employees who have always treated me with kindest and respect. This
notwithstanding the fact that your rude and arrogant association lawyer constantly threatens
and abuses me for his own warped and misguided reasons. The fact is he doesn't like me
and I don't like him. I am willing to bury the hatchet; however, for the best interests of the
association if he would agree to cease all his abuse and harassment.
My strengths are 50 years in the insurance and banking business that I could bring to the
management of association issues.
I am also a resident of Coto and member of the Coto Golf & Racquet Club. Additionally I am
also a fund raiser for the Shea Therapeutic riding center and United Cerebral Palsy.
I look forward to meeting with you.
Bill Kirkendale
31345 Summerhill Ct.
CDC
949-981-5400

Re: Formal Bar Complaint Against Mei Tsang and Joseph Andolin

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