Lenore

Case 8:18-cv-00448-CJC-JDE Document 172 Filed 08/28/18 Page 1 of 97 Page ID #:1128
1
Lenore L. Albert
2
14272 Hoover Street #69
3 Westminster, CA 92683
Ph: 424-365-0741
4
Email: lenorealbert@msn.com
5 Plaintiff, pro per
6
UNITED STATES DISTRICT COURT
7 CENTRAL DISTRICT OF CALIFORNIA
8
LENORE ALBERT, an individual; CASE NO. 8:18-cv-00448-CJC-JDE
9
Plaintiff(s),
10 vs.
11 FIRST AMENDED COMPLAINT FOR
ANTHONY TROY WILLIAMS, an individual; RACKETEERING, CIVIL RIGHTS, AND UCL
12 COMMON LAW OFFICES OF AMERICA; VIOLATIONS
13 GEORGE OLIVO, an individual; SHERI [Demand for Jury Trial as to Part]
MOODY, an individual; VALERIE LOPEZ, an
14 individual; CYNTHIA L. BROWN, an Case related to personal bankruptcy filed by Lenore
15 individual; SHERRY HERNANDEZ, an Albert on 2/20/18 18-bk-10548; related to Ford Credit
individual; MONICA JONES, an individual;
16 v Albert 30-2015-00823254-CL-CL-CJC; JPP v Albert
PAM RAGLAND, an individual; CITIBANK, 30-2014-00738725-CU-DF-CJC; TRO Albert v Olivo;
17 N.A.; GREG DIAMOND, an individual; Albert v State Bar 14-cv-01905-DOC
BILLIE RENE POWERS, an individual;
18 WILLIAM WAGENER, an individual; KARIN
19 HUFFER, an individual; MARY SMITH, an
individual; JOANNE KENNEDY, an
20 individual; DEVIN LUCAS, an individual;
21 ORANGE COUNTY SUPERIOR COURT;
STATE BAR EMPLOYEE, an individual;
22 STATE BAR OF CALIFORNIA; TIMOTHY
23 BYER, an individual; ALEX HACKERT, an
individual; MARICRUZ FARFAN, an
24 individual; CAITLIN ELEN-MORIN, an
25 individual; STEVE BALLARD, an individual;
CATHERINE OLSEN, an individual; NIRA
26 WOODS, an individual; MAEGAN
27 DONOVAN NIKOLIC aka MAEGAN
NIKOLIC aka MAEGAN DONOVAN, an
28 individual; VERN NELSON, an individual;
NORMA WHITE, an individual; and DOES 4
through 50, inclusive,
Defendants.
1
FIRST AMENDED COMPLAINT
Albert v Williams, et al 8:18-cv-00448-CJC-JDE
1 Plaintiff LENORE ALBERT (referred to as “Plaintiff” or "Plaintiffs"), now amends her

2 complaint against the Defendants in the caption and alleges the following on information and belief,
3 except as to those allegations which pertain to the Plaintiff and are within her personal knowledge:
4 JURISDICTION
5 1. The Court has subject matter jurisdiction of this action under 28 U.S.C. §1331 (general
6 federal question jurisdiction); 18 USC §1965 (the Racketeer Influenced and Corrupt Organizations
7 Act); 42 USC §1981 (the Federal Civil Rights Act); and the court’s supplemental jurisdiction under 28
8 USC §1367.
9 2. The court has personal jurisdiction over the Defendants because the Defendants have
10 made minimum contacts with California. The court also has personal jurisdiction over the Defendants
11 because at least one Defendant is subject to personal jurisdiction in California under 11 USC §1965(d)
12 and/or 11 USC §1965(b) because the ends of justice require joinder of the co-Defendants. Butcher’s
13 Union Local No. 498 v SDC Investment, Inc. 788 F2d 535, 538-539 (9th Cir 1986).
14 3. Venue is proper under 28 USC §1391(b) because a substantial part of the events or
15 omissions giving rise to the claims occurred in this District or no jurisdiction exists where all
16 Defendants could be sued. Venue is also proper under 18 USC §1965(a) because either the Defendants
17 could be found or transacted their affairs in this district. McCracken v Automobile Club of So Calif, 891
18 F.Supp 559, 562 (D Ks 1995)(corporate Defendants can be sued anywhere with minimum contacts in
19 the United States re: RICO).
20 PARTIES
21 4. Plaintiff, Lenore Albert is, and at all times relevant was, a citizen of California residing
22 in Orange County, California.
23 5. Plaintiff is informed and believes and alleges thereon that Defendant, Anthony Troy
24 Williams (“Anthony T. Williams”) is currently incarcerated in Honolulu, Hawaii.
25 6. Plaintiff is informed and believes and alleges thereon that Defendant, Common Law
26 Office of America is organized and existing under the laws of the State of Hawaii and was doing
27 business out of a P.O. Box 1522, Newport Beach, Orange County, California. Plaintiff is further
28 informed and believes and alleges thereon that Common Law Office of America was an enterprise
defined as “any individual, partnership, corporation, association, or other legal entity, and any union or
group of individuals associated in fact although not a legal entity” operating in California.
2
1 7. Defendant, George Olivo is, and at all times mentioned herein relevant was, an
2 individual residing in Orange County, California and is currently in the Theo Lacy correctional facility
3 located in Orange County, California.
4 8. Defendant, Sheri Moody is, and at all times mentioned herein relevant was, an individual
5 residing in Orange County, California.
6 9. Plaintiff is informed and believes and alleges thereon that Defendant, Valerie Lopez is,
7 and at all times mentioned herein was, an individual residing in Orange County, California.
8 10. Plaintiff is informed and believes and alleges thereon that Defendant, Cynthia L. Brown
9 (Cynthia Louise Brown) is, and at all times mentioned herein relevant was, an individual residing in
10 Orange County, California.
11 11. Defendant, Sherry Hernandez is, and at all times mentioned herein relevant, was an
12 individual residing in Los Angeles County, California.
13 12. Defendant, Monica Jones is, and at all times mentioned herein relevant was, an
14 individual residing in Clark County, Nevada.
15 13. Defendant, Pam Ragland is, and at all times mentioned herein relevant was, an individual
16 residing in Orange County, California.
17 14. Defendant, Citibank N.A., is and at all times mentioned herein relevant was, a national
18 association qualified to do business and was a business entity operating in California.
19 15. Defendant, Greg Diamond is, and at all times mentioned herein relevant, was an
20 individual residing in Orange County, California.
21 16. Defendant, Billie Rene Powers (“Rene Powers” or “Billie Rene Lillian Francis Powers”)
22 is, and at all times mentioned herein relevant was, an individual residing in Orange County, California.
23 17. Plaintiff is informed and believes and alleges thereon that Defendant, William Wagener
24 is, and at all times mentioned herein, was an individual residing in Santa Barbara County, California.
25 18. Plaintiff is informed and believes and alleges thereon that Defendant, Karin Huffer is,
26 and at all times mentioned herein, was an individual residing in Clark County, Nevada.
27 19. Defendant, Mary Smith is, and at all times mentioned herein relevant, was a DOE
28 individual whom true identity needs to be discovered.
20. Plaintiff is informed and believes and alleges thereon that Defendant, Joanne Kennedy is,
and at all times mentioned herein relevant, was an individual residing in Pennsylvania.
3
1 21. Plaintiff is informed and believes and alleges thereon that Defendant Devin Lucas is, and
2 at all times mentioned herein relevant to this complaint was, an individual residing in Orange County,
3 California.
4 22. Defendant and Real Party in Interest Orange County Superior Court is a government
5 agency and only being sued for injunctive relief to the extent needed to bar the court from the practice
6 of allowing extremists to rule ex parte proceedings through an ADA scam that they have been running
7 for the past year. It is a nominal Defendant and could not be named as a Plaintiff.
8 23. Defendant State Bar Employee is an individual being sued as a Doe Defendant who is
9 the person that actually posted derogatory information on Plaintiff’s member page and was responsible
10 for giving Plaintiff Notice of her State Bar status and is being sued in his or her individual capacity and
11 is believed to reside somewhere in California.
12 24. Defendant and Real Party in Interest State Bar of California is a government agency and
13 only being sued for injunctive relief to the extent needed to bar the agency from violating Plaintiff’s
14 constitutional rights and continuing the use of sovereign citizen extremists to target Plaintiff.
15 25. Defendant, Timothy Byer is, and at all times mentioned herein relevant was, an
16 individual residing in California and is being sued in his individual capacity as an employee at the State
17 Bar.
18 26. Defendant, Alex Hackert is, and who at all times mentioned herein relevant was, an
19 individual residing in California and is being sued in his individual capacity as an employee at the State
20 Bar.
21 27. Defendant, Maricruz Farfan is, and who at all times mentioned herein relevant was, an
22 individual residing in California and is being sued in her individual capacity as an employee at the State
23 Bar.
24 28. Defendant, Caitlin Elen-Morin is, and who at all times mentioned herein relevant was, an
25 individual residing in California and is being sued in her individual capacity as an employee at the State
26 Bar.
27 29. Defendant, Steve Ballard is, and who at all times mentioned herein relevant was, an
28 individual residing in Orange County, California.
30. Defendant, Catherine Olsen is, and who at all times mentioned herein relevant was, an
individual residing in Orange County, California. Ms. Olsen is Mr. Ballard’s significant other.
4
1 31. Defendant, Nira Woods is, and who at all times mentioned herein relevant was, an
2 individual residing in Los Angeles County, California.
3 32. Doe 1’s name is corrected to Maegan Donovan Nikolic (“Maegan Donovan” or “Maegan
4 Nikolic”), who is believed to be now residing in Orange County, California, and has resided from time
5 to time with her aunt in Whittier, California.
6 33. Doe 2’s name is corrected to Defendant, Norma White is believed to residing in Santa
7 Ana, California.
8 34. Doe 3’s name is corrected to be Defendant, Vern Nelson is, and who at all times
9 mentioned herein relevant, was an individual residing in Orange County, California. Mr. Nelson writes
10 on the OrangeJuice Blog.
11 35. Third party, David Seal is an attorney residing in Orange County, California. Plaintiff
12 and Seal have ongoing litigation in state court on a defamation case that this case is related to regarding
13 the 4/6/15 Grand Theft Project described herein (JPP v Albert).
14 36. Third party, Paul Murray is believed to reside in Florida.
15 37. Third party, Federal National American Mortgage is believed to be non existent entity
16 with a PO Box in Washington, D.C. Investigation and discovery into this entity is continuing.
17 38. Third party, Mortgage Enterprise Institute is believed to be an entity with a PO Box in
18 Killeen, Texas but those proceeds, if any, that it would hold, would be directed to victims in Hawaii.
19 39. Third party, Equal Access Advocates, who at all times mentioned herein relevant to this
20 complaint, was a business entity operating in Colorado Springs, Colorado.
21 40. Third party Kimi VanDyke, resides in Santa Barbara County, California.
22 41. Third party, Donna Anderson, resides in New Jersey and runs the www.LoveFraud.com
23 website.
24 42. Third party, Lovefraud Education and Recovery a nonprofit located in Atlantic City,
25 New Jersey.
26 43. Plaintiff does not know the true name and capacity of the Defendants DOES 4 through
27 50, inclusive, and as such names said Defendants by such fictitious names. Plaintiff will amend the
28 complaint to state the true name and capacity of the DOE Defendant(s) when such information is
ascertained.
5
1 44. Plaintiff is informed and believes and alleges thereon that each Defendant is responsible
2 in some manner for the occurrences alleged in this complaint, and that Plaintiff’s damages were
3 proximately caused by the Defendants.
4 45. Plaintiff is further informed and believes and alleges thereon that each Defendant was the
5 agent, servant, representative, and/or employee of their co-Defendants, and in doing the things
6 hereinafter alleged were acting in the scope of their authority as agents, servants, representatives, and/or
7 employees, and with the permission and consent of their co-Defendants.
8 46. Additionally, Plaintiff is informed and believes and alleges thereon that each Defendant
9 conspired with their co-Defendants, acted in concert therewith, assisted, aided and abetted, adopted,
10 ratified, approved, or condoned the actions of every other Defendant and that each corporate Defendant,
11 if any, was acting as the alter ego of the other in the acts alleged herein.
12 FACTUAL BACKGROUND
13 47. Defendants used a scheme to confuse the public and divert clients and potential
14 homeowner clients away from Plaintiff’s business while a group of the Defendants were running a
15 sovereign citizen tactic homeowner fraud rescue scams as detailed below. Plaintiff’s business lost profit
16 and she incurred legal costs as a direct and proximate result.
17 48. Ms. Albert was a practicing trial lawyer in Orange County, California since on or after
18 December 5, 2000 without any record of State Bar discipline. During the financial crises, she
19 represented consumers in home loan or civil rights litigation in state and federal court obtaining six
20 figure settlements for clients. She helped people from time to time pro bono. She held a series of
21 weekend classes in or about the summer of 2013 wherein most of the Defendants first came into contact
22 with her law practice. Plaintiff started receiving complaints that seemed paranoid, then or about
23 September 25, 2013 someone completely smashed out Plaintiff’s back Ford SUV window in the middle
24 of the night at her home. A few weeks later her personal assistant’s fiancé, L.G., was found lifeless in
25 her mother’s garage. That December someone had depleted her bank account. Her office experienced
26 employee sabotage and her files, a laptop, access to the offices and office building in addition to her
27 vehicle had been stolen. A temporary employee went on a rage of violence and attempted to assault her
28 with a statue on July 11, 2014. She was receiving threats of blackmail or extortion for pay that was not
even being withheld or earned and that her employees and threats that her client’s cases would be
6
1 tanked if they did not abandon her. She received a restraining order against the employee, but it did no
2 good because an entire army of people stepped forward in his place.
3 49. It was later discovered many of the people were dabbling in sovereign citizen tactics and
4 defrauding other homeowners. They diverted clients and potential homeowner clients from Plaintiff’s
5 business while they recruited and radicalized desperate homeowners with their schemes. Defendants
6 tactics included violence or threats of violence, paper terrorism, mass bullying and exaggeration of their
7 education, skills and status.
8 50. Plaintiff was injured in her property and business as a direct and proximate result of
9 Defendants acts which included, mail and wire fraud, retaliation, impersonation, embezzlement,
10 extortion, forgery, recording false instruments, grand theft, solicitation, and conspiracy.
11 FIRST CAUSE OF ACTION
12 (RICO)
13 (Plaintiff Lenore Albert against All Defendants and Does 4-50)
14 51. Plaintiffs incorporate in this cause of action all of the allegations in paragraphs 1 through
15 50 as though set forth in full herein.
16 52. Defendants Anthony T. Williams, Common Law Office of America, George Olivo,
17 Sheri Moody, Valerie Lopez, Cynthia L. Brown, Sherry Hernandez, Monica Jones, Pam Ragland,
18 Citibank, N.A., Greg Diamond, Billie Rene Powers, William Wagener, Karin Huffer, Mary Smith,
19 Joanne Kennedy, Devin Lucas, Orange County Superior Court, State Bar Employee, State Bar of
20 California, Timothy Byer, Alex Hackert, Maricruz Farfan, Caitlin Elen-Morin, Steve Ballard, Catherine
21 Olsen, Nira Woods, Maegan Donovan Nikolic, Vern Nelson, Norma White, and Does 4 through 50,
22 inclusive, (collectively referred to as the “RICO Defendants”) have not undertaken the practices and
23 activities described in this complaint in isolation.
24 53. The RICO Defendants have done so as part of a common scheme and conspiracy, which
25 includes not only the RICO Defendants, but other attorneys, private attorney generals, and persons hired
26 to participate in Common Law Grand Juries or militia, as well.
27 54. All of the practices described herein are the competent part of RICO Defendants’ larger
28 scheme designed to maximize Defendants’ own profits and their own form of purportedly acting “in the
public interest” due to a preconceived distrust of “attorneys at law,” judges and the judicial system.
7
1 55. Each Defendant and all members of the conspiracy, with knowledge and intent agreed to
2 the overall objective of maximizing their own profit while acting “in the public interest” of the
3 conspiracy, agreed to commit acts of fraud, extortion, impersonation, and grand theft to wrongfully
4 obtain property and/or money from Plaintiff and her business and actually committed such acts, even if
5 all of the RICO Defendants were not knowledgeable about each and every scheme or project of their co-
6 Defendants.
7 56. Indeed, for the fraudulent scheme described herein to be successful, each Defendant and
8 other members of the conspiracy had to agree to enact and utilize various devices and fraudulent tactics
9 against Plaintiff to bring about the desired result.
10 57. Numerous common facts and similar activities, which reflect the above reality and imply
11 the existence of a conspiracy, exist among all of the Defendants and other members of the conspiracy,
12 including: (a) educating, solicitating, and then sending court notices or people with badges appearing at
13 Plaintiff’s home with regard to common law grand juries; (b) exposing Plaintiff’s vehicle, make, color
14 VIN number, sending emails that men with guns have been told Plaintiff hurts small children and to
15 shoot if they see her driving down their street, while planning to convince FMC they had a legitimate
16 reason to take the vehicle which enabled the Defendants to ambush her outside of a court hearing; (c)
17 filing false complaints and prosecuting them based on representations that the claimants can seek money
18 from the California State Bar. Part of the list of targeted acts over a four year period to cover up a
19 Defendant’s violent acts and to divert clients and potential homeowner clients from Plaintiff’s business
20 to Defendant’s homeowner fraud rescue scams is detailed below.
21 58. The acts and events prior to March 2014, if any, were concealed by Defendant’s deceit
22 and fraud. Thus, even with Plaintiff’s due diligence, she could not bring these claims until now. The
23 conspiracy was conducted through, and implemented by, Defendants and other violators.
24 THE ENTERPRISE
25 59. Defendants are all “persons” within the meaning of 18 U.S.C. §1961(3).
26 60. The Enterprise is primarily a group of individuals, associated in fact, although not a legal
27 entity, as well as a group of affiliated entities.
28 61. More specifically the enterprise includes, but is not limited to, the following associated
in fact individuals, trusts and/or associations:
62. Common Law Office of America
8
1 63. Mortgage Enterprise Investments

2 64. United States Law Office of the Private Attorney General
3 65. Federal Mortgage American Trust
4 66. Equal Access Advocates
5 67. Cal 18
6 68. Occupy Fights Foreclosures
7 69. California State Bar
8 70. Anthony Troy Williams
9 71. George Olivo
10 72. Sheri Moody
11 73. Valerie Lopez
12 74. Cynthia L. Brown
13 75. Sherry Hernandez
14 76. Monica Jones
15 77. Pam Ragland
16 78. Billie Rene Powers
17 79. William Wagener
18 80. Karin Huffer
19 81. Mary Smith
20 82. Joanne Kennedy
21 83. Devin Lucas
22 84. State Bar Employee
23 85. Timothy Byer
24 86. Alex Hackert
25 87. Maricruz Farfan
26 88. Caitlin Elen-Morin
27 89. Steve Ballard
28 90. Catherine Olsen
91. Nira Woods
92. Maegan Donovan Nikolic
9
Case 8:18-cv-00448-CJC-JDE Document 172 Filed 08/28/18 Page 10 of 97 Page ID
#:1137
1 93. Norma White

2 94. Vern Nelson
3 95. and other persons or entities known or unknown to the Plaintiff.
4 96. Defendants Anthony T. Williams, Cynthia L. Brown, CLOA, MEI, USPAG, FNMAT,
5 Billie Rene Powers, Sheri Moody and Valerie Lopez shall be known as the “CLOA Enterprise.”
6 Defendants George Olivo, Greg Diamond, Sherry Hernandez, Vern Nelson, Norma White, and Maegan
7 Donovan Nikolic shall be known as the “Occupy Fights Foreclosures” Enterprise. Defendants Sherry
8 Hernandez, Cynthia L. Brown, Karin Huffer shall be known as the “Equal Access Advocates”
9 Enterprise. Defendants Alex Hackert, Maricruz Farfan, Timothy Byer, State Bar Employee and Caitlin
10 Elen-Morin shall be known as the “State Bar” Enterprise. Defendants Billie Rene Powers, William
11 Wagener, Joanne Kennedy and Pam Ragland shall be known as the “Cal 18” Enterprise.
12 97. The above listed members of the enterprises collaborated with one or more of the others
13 as principals and/or complicitors as part of a long term scheme and endeavor to initially attempt to
14 influence various California and other state based public servants, including California and Florida state
15 and municipal court judges, prosecutors, sheriffs, and other public officials who in their legal capacities
16 had responsibilities related to a legal matter which involved a member of this enterprise. For example, a
17 common triggering event for the subsequent behavior which serves as the foundation for this complaint
18 was when a member of the enterprise became a named party in a legal proceeding in either a state,
19 municipal or federal court which was presided over by a judge. Whether the legal proceeding was a
20 criminal matter being prosecuted by an elected District Attorney through that prosecutor's designated
21 Deputy District Attorney or was a civil matter; when the legal proceeding in question did not result in a
22 decision favorable to the member of the enterprise one or more members of the enterprise would then
23 engage in a methodical series of actions and statements specifically targeting Plaintiff, the trial court
24 judge, the bank, the assigned prosecutor, the local sheriff and other related public servants who had a
25 designated role of some form which was related to the subject litigation.
26 98. Typical actions employed by the enterprise at the initial stage of the chronology would
27 include a member of the enterprise making a grievance about the ruling being Plaintiff’s fault to the
28 court and filing a State Bar complaint against the Plaintiff, even if Plaintiff was not representing them.
The complainant would then have an expectation that the targeted Plaintiff would be the subject of a
demand, notice, order and/or a writ which was apparently designed to give the complainant a second
10
#:1138
1 chance in the legal action that was pending in a legitimate court or get their charges dismissed or jury
2 nullification. If the public servant(s) did not respond in such a manner, then various other documents
3 would then be filed and served upon the public servants by the enterprise, including but not limited to, a
4 "Deed of Trust" as well as a "UCC Finance Statement." Plaintiff would receive email notices to appear
5 in “court” and a call for Common Law Grand Jury would occur. On at least one occasion, two strange
6 men with a badge pulled up to her home after one call out for a common law grand jury.
7 99. As the enterprise continued its focus by making what appear to be legally defined "true
8 threats" towards or demands of the targeted public servants or Plaintiff, another tactic which was
9 employed against the Plaintiff was the enterprise choosing to work to incite Plaintiff’s clients, former
10 clients, opposing counsel to file “claims” for money against Plaintiff with the State Bar who would then
11 open investigations and file charges against her. So, Plaintiff’s potential clients were diverted away
12 from her office, leaving these homeowners vulnerable to the sovereign citizen rescue foreclosure scams
13 to the Defendants’ profit.
14 100. Although Plaintiff tried to warn law enforcement, the courts, the State Bar and the
15 financial institutions, the State Bar actively engaged in being the catalyst of paper terrorism against
16 Plaintiff and her office starting in 2014 through to the present. When Plaintiff confronted the State Bar
17 and spoke out publicly in 2015 criticizing the State Bar for jumping the gun based on the later discovery
18 that Plaintiff’s face was on a known Sovereign Citizen extremist website where State Bar complaints
19 were being solicited from, the State Bar retaliated against Plaintiff on December 15, 2015 by filing
20 charges against her and prosecuting her. The State Bar did not filter the complaints, and no matter how
21 outlandish, detailed and bizarre they were; the State Bar would press Plaintiff to answer the charges
22 completely and fully in a short time span, sometimes requiring Plaintiff to sort through and send off
23 approximately 4,000 pages in as few as a week or two - or demand Plaintiff pull files out of storage
24 repeatedly like a coach making a player run extra laps as the former client pulls a no show to pick them
25 up.
26 101. Plaintiff alleges that based on the context, timing and circumstances of the escalated
27 demands, that these actions were extortive, retaliatory and served as retribution against Plaintiff and/or
28 some of the public servants.
PATTERN OF RACKETEERING ACTIVITY
11
#:1139
1 102. Defendants Anthony Troy Williams, Common Law Office of America, George Olivo,
2 Sheri Moody, Valerie Lopez, Cynthia L. Brown, Sherry Hernandez, Monica Jones, Pam Ragland, Greg
3 Diamond, Billie Rene Powers, William Wagener, Joanne Kennedy, Catherine Olsen, Steve Ballard, and
4 Nira Woods and others known and unknown, and each of them, directly and in concert, engaged in,
5 attempted to engage in, conspired to engage in, or solicited another to engage in at least two predicate
6 acts, related to the conduct of the enterprise, with at least one of which took place in the State of
7 California and the last of the acts of racketeering activity occurring within ten years after a prior act of
8 racketeering activity.
9 103. The Defendants have engaged in a “pattern of racketeering activity,” as defined by
10 U.S.C. §1961(5), by committing or aiding and abetting in the commission of at least two acts of
11 racketeering activity, i.e., indictable violations as listed above and incorporated herein, discovered
12 within the past four years after being concealed by misrepresentations from Defendants.
13 104. In fact, each of the Defendants have committed or aided and abetted in the commission
14 of multiple acts of racketeering activity. Each act of racketeering activity was related, had a similar
15 purpose, involved the same or similar participants and method of commission, had similar results and
16 impacted similar victims, including Plaintiff.
17 105. On or about March 2014 and continuing through to the present in the State of California,
18 Anthony Troy Williams, Common Law Office of America, George Olivo, Sheri Moody, Valerie Lopez,
19 Cynthia L. Brown, Sherry Hernandez, Monica Jones, Pam Ragland, Greg Diamond, Billie Rene
20 Powers, William Wagener, Joanne Kennedy, Catherine Olsen, Steve Ballard, Nira Woods, Norma
21 White, Vern Nelson, Maegan Donovan Nikolic, Alex Hackert, Maricruz Farfan, Timothy Byer, and
22 Caitlin Elen-Morin, while employed by or associated with an enterprise, unlawfully, feloniously, and
23 knowingly conducted or participated, directly or indirectly, in the enterprise through a pattern of
24 racketeering activity including but not limited to paper terrorism, violence, mass bullying, and
25 exaggeration of education, experience or title resulting in a violation of mail fraud (18 U.S.C. §1341);
26 wire fraud (18 U.S.C. §1343); unauthorized access to a computer (18 U.S.C. §1030); retaliation (18
27 U.S.C. §1513(e) and (f)); impersonation of a federal officer (18 U.S.C. §912); impersonation of a
28 consulate or ambassador (18 U.S.C. §915); Embezzlement (Cal Penal Code §503); Extortion (Cal Penal
Code §); Forgery (Cal Penal Code §470); Attempt to Record False Instruments (Cal Penal Code §115);
grand theft (Cal Penal Code §487); solicitation (Cal Penal Code §653); and conspiracy (Cal Penal Code
12
#:1140
1 §182) – and/or conspired to do so. It became a vicious cycle where Defendants deceived and attacked
2 Plaintiff, Plaintiff exposed the attack, so Defendants attacked Plaintiff, Plaintiff exposed the attack and
3 deceit, and Defendants deceived and retaliated again.
4 106. The multiple acts of racketeering activity that Defendants committed and/or conspired to
5 commit, or aided and abetted in the commission of, were related to each other, and amount to and pose a
6 threat of continued racketeering activity, and therefore constitute a “pattern of racketeering activity” as
7 defined in 18 U.S.C. §1961(5).
8 RICO VIOLATIONS
9 107. Section 1962(c) of RICO provides that it “shall be unlawful for any person employed by
10 or associated with any enterprise engaged in, or the activities of which affect, interstate or foreign
11 commerce, to conduct or participate, directly or indirectly, in the conduct of such enterprise’s affairs
12 through a pattern of racketeering activity…”
13 108. Through the patterns of racketeering activities outlined herein, the Defendants have also
14 conducted and participated in the affairs of the State Bar Enterprise, Equal Access Advocates
15 Enterprise, Occupy Fights Foreclosure Enterprise, Cal 18 Enterprise, and the CLOA Enterprise.
16 109. Section 1962(d) of RICO makes it unlawful “for any person to conspire to violate any of
17 the provisions of subsection (a), (b) or (c), of this section.
18 110. Defendants’ conspiracy to secure property and/or money from Plaintiff for their own use
19 through the fraudulent scheme described above and then target and try to destroy her violates 18 U.S.C.
20 §1962(d).
21 111. Each of the Defendants agreed to participate, directly or indirectly, in the conduct of the
22 affairs of the five (5) Enterprises through a pattern of racketeering activity comprised of numerous acts
23 of mail fraud and wire fraud, and the other crimes listed above - and each Defendant so participated in
24 violation of 18 U.S.C. §1962(c).
25 112. Defendants used a scheme to defraud by means of false pretenses as particularly
26 described in the causes of action below.
27 113. Defendant’s actions entitle Plaintiff to actual damages, treble damages, attorney’s fees
28 and costs against the private Defendants and injunctive relief against the individuals and any state or
local agency.
13
#:1141
1 114. The acts of racketeering activity that the above-named persons committed,
2 attempted to commit, conspired to commit, or solicited, or coerced, or intimidated another
3 person to commit, include, but are not limited to the following predicate acts, including any
4 lesser included offenses, as follows:
5 PREDICATE ACTS
6 VIOLATIONS OF 18 U.S.C. §1341 and 18 U.S.C. §1343
7 115. The CLOA, Occupy Fights Foreclosures, State Bar, Equal Access Advocates and Cal 18
8 Enterprises are or were ongoing organizations that engage in, and whose activities affect, interstate
9 commerce by soliciting others to invest in their homeowner rescue schemes on real property throughout
10 the United States. None of these organizations were registered to do business in California although
11 they operated, in part, out of Orange County, California except as stated herein.
12 116. The State Bar Enterprise and Equal Access Advocates have an ascertainable structure
13 separate and apart from the pattern of racketeering activity in which the Defendants engage.
14 117. Plaintiff is informed and believes and alleges thereon that after George Olivo was
15 charged for DUI in Orange County, California and Anthony T. Williams was charged with various
16 felonies in Broward County, Florida, Defendant Cynthia L. Brown and others moved onto using the
17 Equal Access Advocates structure to maintain a foothold in the local court system.
18 118. Section 1961(1) of RICO provides that “racketeering activity” includes any act indictable
19 under 18 U.S.C. §1341 (relating to mail fraud) and 18 U.S.C. § 1343 (relating to wire fraud) amongst
20 the laundry list of others laid out below. As set forth herein, Defendants have engaged, and continue to
21 engage in conduct violating each of these laws to effectuate their scheme.
22 119. Additionally, in order to make their scheme effective, each of the Defendants sought to
23 and did aid and abet others in violating the above laws within the meaning of 18 U.S.C. §2. As a result,
24 their conduct is a violation under 18 U.S.C. §1341 and 18 U.S.C. §1343, on this additional basis.
25 120. "There are two elements in mail fraud: (1) having devised or intending to devise a
26 scheme to defraud (or to perform specified fraudulent acts), and (2) use of the mail for the purpose of
27 executing, or attempting to execute, the scheme (or specified fraudulent acts)." Schmuck v. United
28 States, 489 U.S. 705, 721 n. 10 (1989); see also Pereira v. United States, 347 U.S. 1, 8 (1954) ("The
elements of the offense of mail fraud under . . . § 1341 are (1) a scheme to defraud, and (2) the mailing
14
#:1142
1 of a letter, etc., for the purpose of executing the scheme."); Laura A. Eilers & Harvey B. Silikovitz, Mail
2 and Wire Fraud, 31 Am. Crim. L. Rev. 703, 704 (1994) (cases cited).
3 121. For the purposes of executing and/or attempting to execute the above described scheme
4 to defraud or obtain money by means of false promises, representations or promises, the Defendants, in
5 violation of 18 U.S.C. § 1341, placed in post offices and/or in authorized repositories matter and
6 findings to be sent or delivered by the Postal Service, caused matter and things to be delivered by
7 commercial interstate carriers, and received matter and things from the Postal Service or commercial
8 interstate carriers, including but not limited to fake DEEDS OF TRUST and NOTES, promotional
9 items, invoices, letters, quarterly reports, and State Bar correspondence or complaints. (It is
10 complicated, but basically homeowner payments went to Killeen, Texas based on nonsensical sovereign
11 citizen ideology homeowner rescue programs run by persons pretending to be federal attorney generals
12 while State Bar complaints against Plaintiff went to Los Angeles, California to divert business away
13 from Plaintiff and get her disbarred).
14 122. For the purpose of executing and/or attempting to execute the above described scheme to
15 defraud or obtain money by means of false pretenses, representations or promises, the Defendants, in
16 violation of 18 U.S.C. §1343, transmitted and received by wire, matter and things, including but not
17 limited to promotional materials, applications, UCC Finance Statements, agreements, manuals and
18 correspondence, and made or caused to be made false statements over the telephone, electronic mail,
19 and internet.
20 123. Defendants’ misrepresentations, acts of concealment and failures to disclose were
21 knowing and intentional and made for the purpose of deceiving third parties to the injury of Plaintiff’s
22 property or business and obtaining their money and/or property for Defendants’ gain.
23 124. Defendants either knew or recklessly disregarded the fact that the misrepresentation and
24 omission described above were material, and third parties relied upon the misrepresentations and
25 omissions as set forth herein to the injury of Plaintiff.
26 125. As a direct and proximate result, Plaintiff has been injured in her business or property by
27 the Defendants’ overt acts of mail and wire fraud, and by their conspiracy, or aiding and abetting each
28 other’s acts of mail and wire fraud.
THE CLOA/MEI HOMEOWNER RESCUE FRAUD
15
#:1143
1 126. Mortgage Enterprise Investments (MEI) was a business owned and operated by
2 Defendant, Anthony T. Williams, which was registered on or about June 24, 2013, with the State of
3 Hawaii, Department of Commerce and Consumer Affairs (DCCA) The application for registration of
4 trade name was filed by Anthony T. Williams, on June 1, 2013. The listed officers of MEI were
5 Anthony T. Williams, Chief Executive Officer (CEO), Founder, Partner and Barbara Williams, the
6 Chief Financial Officer (CFO). The application listed the purpose of MEI as mortgage and foreclosure
7 assistance.
8 127. According to its Web site, The Common Law Office of America (CLOA) was an office
9 that employs Private Attorney Generals (PAGs) and offers services to its clients that include, but are not
10 limited to: mortgage reduction, foreclosure assistance, UCC filings, document writing, and Power of
11 Attorney. Anthony T. Williams was the owner and operator of CLOA.
12 128. According to corporate documents filed with the State of Hawaii, the business address
13 for the Honolulu office of CLOA was P.O. Box 31285, Honolulu, Hawaii 96820. According to DCCA's
14 Business Registration Division records, CLOA was not a registered business in the State of Hawaii.
15 129. According to letterhead used by CLOA, it also had a business office location in Newport
16 Beach, California. The CLOA website listed the business address for the Newport Beach office of
17 CLOA as “P.O. Box 1522, Newport Beach, CA [zip code exempt].”
18 130. Defendant, Anthony T. Williams, would identify himself as a Private Attorney General.
19 He carried an identification card identifying himself as a Private Attorney General, from the United
20 States Office of the Private Attorney General, citing “42 USC 1988.” The identification also claimed
21 that the holder had diplomatic immunity and stated, “Do Not Detain-Do Not Arrest.”
22 131. Defendant, Anthony T. Williams, was identified as an attorney in fact on informational
23 materials for CLOA. In addition, Anthony T. Williams, utilized the email address,
24 awilliams@usacommonlaw.com when conducting business on behalf of MEI and CLOA. Anthony T.
25 Williams was not a licensed attorney in the State of California and other jurisdictions, nor was he
26 permitted to practice law and provide legal advice to clients.
27 132. Defendant, Anthony T. Williams, in California and various other states, introduced and
28 advertised MEI and CLOA, and the services and products they allegedly provided. Anthony T.
Williams would sign up new clients and look for recruiters who, through word of mouth, could bring in
additional clients to MEI and CLOA.
16
#:1144
1 133. In or about mid-2014, Defendant, Rene Powers, was a homeowner, a client of MEI, a
2 recruiter for MEI. Rene Powers signed on with the MEI program and later organized meetings and
3 brought new clients to the program. She and co-Defendant Cynthia L. Brown assisted in opening up a
4 CLOA office in California, too.
5 134. Plaintiff is informed and believes and alleges thereon that Rene Powers collected a fee
6 from MEI and/or Defendant, Anthony T. Williams, for bringing in new clients to MEI. Anthony T.
7 Williams referred to Rene Powers as his “business partner” in California.
8 135. Defendant Rene Powers identified herself as a representative of MEI. Defendant Rene
9 Powers was not a licensed mortgage broker in the State of California at the time she represented she was
10 a representative of MEI. She never obtained the required licenses pursuant to California finance or real
11 estate laws, to provide services as a: mortgage loan originator; mortgage loan originator company;
12 mortgage broker; mortgage servicer; or mortgage servicer for loan modifications.
13 136. Plaintiff is informed and believes and alleges thereon that in or about mid-2014,
14 Defendant, Cynthia Louise Brown, was a homeowner and client of MEI, who also became a recruiter
15 for MEI. Cynthia Louise Brown signed on with the MEI program and later organized meetings and
16 brought new clients to the program.
17 137. Plaintiff is informed and believes and alleges thereon that Defendant Cynthia Louise
18 Brown collected a fee from MEI and/or Defendant, Anthony T. Williams, for bringing in new clients to
19 MEI. Anthony T. Williams referred to Cynthia Louise Brown as one of CLOA’s “private attorney
20 generals” in California.
21 138. Defendant, Cynthia Louise Brown, would identify herself as a Private Attorney General
22 and/or as a “representative” of MEI. By on or about February 15, 2015, the CLOA website promoted
23 Ms. Brown, an Olympian, as “one of the PAG’s [private attorney generals] who will be managing the
24 state of California.”
25 139. Plaintiff is informed and believes and alleges thereon that Defendant, Cynthia Louise
26 Brown, was identified as an attorney in fact on informational materials for CLOA. Defendant Cynthia
27 Louise Brown was not a licensed attorney in the State of California and other jurisdictions, nor was she
28 permitted to practice law and provide legal advice to clients.
140. Defendant Cynthia Louise Brown also identified herself as a representative of MEI.
Defendant Cynthia Louise Brown was not a licensed mortgage broker in the State of California at the
17
#:1145
1 time she represented she was a representative of MEI. She never obtained the required licenses pursuant
2 to California finance or real estate laws, to provide services as a: mortgage loan originator; mortgage
3 loan originator company; mortgage broker; mortgage servicer; or mortgage servicer for loan
4 modifications.
5 141. Plaintiff is informed and believes and alleges thereon that Barbara Williams was a
6 resident of Killeen, Texas. MEI lists an address of P.O. Box 1215, Killeen, Texas, 76540, for the
7 mailing of documents and the submission of payments. Barbara Williams worked for MEI since 2012
8 from her Killeen, Texas residence and formed a partnership with Anthony T. Williams in 2013. Barbara
9 Williams opened an account at Extraco Bank in Killeen, Texas. On behalf of MEI, Barbara Williams
10 would send and receive emails, send and receive mail, make and receive phone calls, maintain MEI
11 paperwork, receive payments, make deposits, cash checks, and make withdrawals.
12 142. MEI and CLOA did business in California, Hawaii, Texas, Florida, and other states, at
13 the direction and under the control of Anthony T. Williams and Barbara Williams.
14 143. MEI, Anthony T. Williams and Barbara Williams, while conducting business in
15 California, never obtained the required licenses pursuant to California finance or real estate laws, to
16 provide services as a: mortgage loan originator; mortgage loan originator company; mortgage broker;
17 mortgage servicer; or mortgage servicer loan modification.
18 The Scheme and Artifice to Defraud
19 144. From a precise earlier date unknown, but by in or about May of 2013, and continuing
20 through on or about December 2016, in the state of California and elsewhere, Defendants, ANTHONY
21 T. WILLIAMS, CYNTHIA LOUISE BROWN, RENE POWERS, SHERI MOODY, VALERIE
22 LOPEZ, and others, with the intent to defraud, knowingly devised a scheme and artifice to defraud, and
23 to obtain money from others, by means of materially false and fraudulent pretenses, representations and
24 promises, as well as omissions of material fact, well knowing at the time that such pretenses,
25 representations, and promises, were false when made. Such false statements, representations, promises
26 and omissions of material fact included the following:
27 MEI and CLOA
28 145. Plaintiff is informed and believes and alleges thereon that from in or about May 2013, to
and including December of 2016, Defendant, Anthony T. Williams, on behalf of MEI and CLOA,
falsely told potential clients, that through MEI and CLOA, he could cut their mortgage balances by one-
18
#:1146
1 half, cut their monthly mortgage payments by one-half, and reduce the current mortgage loan payoff
2 terms by one-half. In truth and fact, MEI, Anthony T. Williams, Cynthia L. Brown, Billie Rene Powers,
3 and Barbara Williams, did not hold the licenses or have the ability, to provide a new mortgage, service a
4 pre-existing mortgage, or provide loan modification services to the homeowners.
5 146. Plaintiff is informed and believes and alleges thereon that Defendants, Anthony T.
6 Williams, Cynthia L. Brown, Billie Rene Powers, and Barbara Williams, through MEI, provided a
7 100% money back guarantee, that if they were not able to reduce the homeowner's payment by one-half
8 and the current loan payoff term by one-half, the homeowner would be refunded their initial file set up
9 fee if it was paid in full at the time of initiation of the file. In truth and fact, MEI, Anthony T. Williams,
10 Billie Rene Powers, Cynthia Louise Brown, and Barbara Williams, did not reduce the loan pay-off term
11 or the monthly payment because they converted the money paid by homeowners to their own use, and
12 they did not refund the homeowners money as promised when the original lender would seek to
13 foreclose as a remedy against the homeowner.
14 147. Defendants, Anthony T. Williams and Barbara Williams, through MEI, represented to
15 the homeowners that their original mortgage had been discharged or replaced and that a modified or
16 new lower cost loan was in place, which was held by MEI. Anthony T. Williams, Barbara Williams,
17 Cynthia L. Brown and/or Rene Powers instructed homeowners to make all future payments to MEI and
18 if their original lender contacted them to refer the matter to CLOA. In truth and fact, the original lenders
19 mortgage had not been discharged or replaced and MEI did not have an actual lower cost mortgage in
20 place.
21 148. All payments made to MEI were converted to the use of the Defendants and were not
22 used to pay the mortgage on the homeowner's property.
23 149. The homeowners were presented with the MEI "Homeowner Service Guarantee
24 Agreement" (HSGA), which placed into writing the 100% "Money Back Guarantee." The HSGA
25 guarantees that MEI will reduce the "monthly payment by one-half (1/2)" and reduce the "current
26 mortgage loan pay-off term by one-half (1/2)." It also states that the "100% Money Back Guarantee to
27 me as a ("Homeowner") is to ensure that I incur no risk if Mortgage Enterprise Investments ("MEI") is
28 unsuccessful in reducing my monthly payment and payoff time." In truth and fact, the HSGA is a false
document and no such guarantee can be made, as MEI was not a licensed mortgage company with the
ability to create, service, or modify loans, and MEI and the Defendants did not pay off the original
19
#:1147
1 mortgage. MEI and the Defendants merely began collecting half the original mortgage payment
2 and converted the money to their own use, causing the original mortgage to become increasingly
3 delinquent.
4 150. Plaintiff is further informed and believes and alleges thereon that the MEI application
5 included a "Homeowners Guaranteed Services" Form 330 (HGS Form 330), which promised free or
6 discounted legal services by CLOA. Anthony T. Williams, Billie Rene Powers, and/or Cynthia L.
7 Brown advised clients that if they receive any communication from their mortgage lender, notifying
8 them of delinquency of loan payments, to refer their lender to CLOA and their legal representative,
9 Anthony Williams and/or Cynthia L. Brown. When this occurred, CLOA would send a letter to the
10 lender and inform them that they are prohibited from contacting CLOA's client and that the lender will
11 be fined $1,000 for every contact moving forward. In truth and fact neither Anthony T. Williams nor
12 Cynthia L. Brown were licensed attorneys in the State of California (or Florida) and could not represent
13 the homeowner in legal matters. CLOA had no legal right to assess a fine of $1,000 to the original
14 lender.
15 151. Anthony T. Williams would instruct MEI clients to begin making all future mortgage
16 payments to MEI. CLOA prepared the fake Deeds of Trust, Affidavits, and Notes, and filed it or caused
17 it to be filed with the County Recorder’s office in the State of California and instructed the County
18 Recorder’s Office to mail the County Recorder’s recorded copy to MEI at P.O. Box 1215, Killeen,
19 Texas 76540, as MEI is alleged to be the new mortgage holder. The documents indicate that the original
20 loan had been discharged or replaced and made null and void. The alleged mortgagee on the Mortgage
21 document is MEI. In truth and fact MEI had not discharged or replaced the mortgage held by the
22 original lender, provided a new loan, or a modification of the terms of the original loan. MEI, Anthony
23 T. Williams, Billie Rene Powers, Cynthia L. Brown, and Barbara Williams were not licensed or
24 permitted to perform those services in the State of California.
25 152. In truth and fact, the original lender still held a valid mortgage on the homeowner's
26 property, which had not been discharged, replaced, or made null and void, and MEI had not created a
27 new mortgage or modified the loan.
28 153. Defendants represented that it was filing a UCC Financing Statement with the State of
California and Texas, making the homeowner a creditor – secured party. However, Defendants did not
file a UCC Financing Statement with the State of California (or said document was rejected). Instead,
20
#:1148
1 Defendants filed approximately 133 false documents for homeowners, entitled UCC Financing
2 Statement, with the State of Texas, indicating that the original loan had been discharged or replaced and
3 made null and void. The alleged mortgagee on the Mortgage document is MEI. In truth and fact MEI
4 had not discharged or replaced the mortgage held by the original lender, provided a new loan, or a
5 modification of the terms of the original loan. MEI, Anthony T. Williams, Billie Rene Powers, Cynthia
6 L. Brown, and Barbara Williams were not licensed or permitted to perform those services in the State of
7 California (or Florida or Hawaii).
8 154. Plaintiff is informed and believes and alleges thereon that it was custom and practice for
9 MEI to send a letter to the homeowner, which thanked them for "allowing us to procure your mortgage
10 to reduce your payment and your payoff time.” The MEI letter indicated that former mortgage company
11 no longer had an interest in the homeowner's property and that MEI "will litigate on your behalf to the
12 full extent of the law.” The letter further instructed the homeowner what amount to send as their new
13 monthly payment to MEI, P.O. Box 1215, Killeen, Texas, 76549. The notes recorded with the Deeds of
14 Trust in Orange County Recorder’s office contained the amount of their new monthly payment and
15 directed payment to MEI, P.O. Box 1215, Killeen, Texas, 76549.
16 155. In truth and fact, MEI did not procure the homeowner's mortgage and there would be no
17 reduction in payment or payoff time. The original mortgage company still had a security interest in the
18 homeowner's property. Neither Cynthia Louise Brown nor Anthony T. Williams could litigate on the
19 homeowner's behalf because they were not licensed attorneys in the State of California (or Florida).
20 MEI and the Defendants Anthony T. Williams, and others, began collecting half the original mortgage
21 payment and converted the money to their own use, causing the original mortgage to become
22 increasingly delinquent.
23 156. Plaintiff is informed and believes and alleges thereon that MEI, mailed and emailed, the
24 homeowners a false statement that the Defendants produced. The statements contained, among other
25 things, the balance of the purported mortgage and the amount of each monthly payment received by
26 MEI from the homeowner. In truth and fact, MEI did not procure a new mortgage or procure the
27 homeowner's original mortgage and reduce it, therefore all numbers provided were false. MEI, Anthony
28 T. Williams, Billie Rene Powers, Cynthia L. Brown and Barbara Williams are not licensed in the State
of California (or Florida or Hawaii) to create, service, or modify loans, and MEI and the Defendants did
not pay off the original mortgage.
21
#:1149
1 157. Plaintiff is further informed and believes and alleges thereon that MEI and Defendants
2 sent monthly billing statements via mail to the homeowners with payment stubs. Homeowners would
3 send checks for the new payment amount by mail to MEI, P.O. Box 1215, Killen, Texas 76549. The
4 Defendants failed to inform the homeowners that there was no MEI mortgage on their home and that the
5 original lenders mortgage was still valid, thereby causing the original mortgage to become increasingly
6 delinquent.
7 The Homeowners
8 158. Approximately 133 UCC Finance Statements were recorded in the State of Texas
9 naming MEI as the secured creditor from June 13, 2013 through October 18, 2015. Seventeen of the
10 debtors resided in California. Homeowners from California, Florida and Hawaii make up the majority
11 of UCC Finance Statements recorded in the State of Texas naming MEI during this time period. Not
12 every debtor in California showed a recorded UCC Finance Statement in Texas. For example,
13 Defendant Sheri Moody was a homeowner who used CLOA’s services. Her Note recited that “a UCC
14 LIEN Document Number 59024097002 was recorded in Texas on February 7, 2015” but that document
15 did not appear under the MEI UCC filing search in Texas.
16 159. Plaintiff is informed and believes and alleges thereon that in 2015, Sheri Moody, a
17 homeowner in Orange County, California, was told that her mortgage payment would be cut in half if
18 she enrolled in the MEI program. She paid CLOA and/or MEI for the program; completed the MEI
19 application and other documents; then on or about March 13, 2015, Defendants filed or attempted to file
20 a false UCC Financing Statement on behalf of Sheri Moody with the Texas Secretary of State.
21 Defendants also filed or caused to be filed a false Deed of Trust, Affidavit and Note on behalf of Sheri
22 Moody with the Orange County Recorder’s Office which was recorded on March 13, 2015. The false
23 documents indicated that Sheri Moody's former mortgage company no longer had an interest in her
24 property and that MEI "will litigate on your behalf to the full extent of the law." The deed of trust gave
25 her an alias name of “Shari” also.
26 160. The Note further instructed Sheri Moody to send her new monthly payment of $916.67
27 starting May 1, 2015 to MEI, P.O. Box 1215, Killen, Texas, 76549. Sheri Moody lost title to her home
28 on or about April 15, 2015 by way of foreclosure sale.
161. Prior to this sale, Sheri Moody also hired Anthony T. Williams to represent her in a
judicial foreclosure case in Broward County, Florida. On or about February 17, 2015 Defendant Sheri
22
#:1150
1 Moody and Anthony T. Williams, while in Florida, summoned a Common Law Grand Jury in Broward
2 County, Florida of approximately 25 people in court case number 2014-006212-CA-01 after giving
3 notice that Anthony T. Williams was her attorney.
4 162. Anthony T. Williams could not litigate on Sheri Moody’s behalf because he was not a
5 licensed attorney in the State of Florida. Yet, a notice was filed with the court representing Defendant
6 Anthony T. Williams was a “Private Attorney General” representing “Sheri P. Moody, Respondent, sui
7 generis, on behalf of Defendant, legal person, SHERI P. MOODY, and property owner Mortgage
8 Enterprise Investments”.. “as Common Law Counsel”… “by Common Law Office of America.”
9 163. The Notice of the Common Law Grand Jury filed by Defendants Sheri Moody and
10 Anthony T. Williams threatened the judge that “the grand jurors will be in attendance to ensure the
11 Respondents Constitutional rights are not violated. Anyone being observed violating their oath of office
12 or violating Respondents [sic] constitutional rights will be indicted by the Common Law Grand Jury
13 empaneled by the people…”
14 164. On January 21, 2015 Defendant Billie Rene Powers sent out an email requesting a
15 Common Law Grand Jury empaneled in both Los Angeles County and Orange County, California as
16 directed by Defendant Anthony T. Williams in retaliation for Orange County superior court judge
17 Schulte’s ruling in Cynthia L. Brown’s case. The callout also referred to Plaintiff as Brown’s “appeals
18 attorney.” The next day on January 22, 2015 two men in a Tundra truck pulled up to Plaintiff’s home
19 wearing badges and the passenger had a laptop. Thereafter, Plaintiff received notices to appear in
20 “court” with warnings that the “judge” would rule in her absence. At the time the men appeared with
21 their badges, Plaintiff was not aware of Rene Powers’ email requesting a Common Law Grand Jury.
22 165. Plaintiff is informed and believes and alleges thereon that in 2013 or 2014 Defendants,
23 Rene Powers and Valerie Lopez, homeowners in Orange County, California, were introduced to
24 Anthony T. Williams, who presented the MEI mortgage reduction program to them.
25 166. Plaintiff is informed and believes and alleges thereon that Defendants Anthony T.
26 Williams, Rene Powers, and Cynthia L. Brown opened up a local office in Newport Beach and allowed
27 CLOA to use Rene Powers Post Box as their CLOA California office address.
28 167. Defendants Cynthia Louise Brown, Anthony Troy Williams, Rene Powers and Valeria
Lopez went to work to figure out how to record and promote these false deeds of trust in the Orange
County Recorder’s office. Defendants made two videos of their recording attempts while inside the
23
#:1151
1 Orange County Recorder’s office then uploaded them to the internet to promote their success. One
2 video was referred to as the rejection and the second video was referred to as the successful recording of
3 the documents.
4 168. The videos show (or one can hear the voices of) Cynthia Louise Brown, Anthony Troy
5 Williams, Billie Rene Powers and Valerie Lopez attempting to get the wording right on the documents
6 and convince the County recorder’s office to record the false documents.
7 169. On or about November 26, 2014 Defendant Cynthia Louise Brown’s deed of trust was
8 recorded in the Orange County Recorder’s office which represented she was the senior lienholder. It
9 was prepared by CLOA in Hawaii and the recorded document was to be mailed to MEI in Texas. It
10 alleged that it made the 2005 deed of trust “null and void” and that Cynthia Louise Brown owed the
11 secured creditor $1.1 million dollars as secured by the UCC Financing Statement recorded in the State
12 of California. However, no such UCC Financing Statement was found for debtor Cynthia Louise Brown
13 as referred to in the Deed of Trust in California.
14 170. Beyond Defendant homeowners, other California homeowners were told that their
15 mortgage payment would be cut in half and the term of their loan could be reduced from 30 years to 15
16 years, if they enrolled in the MEI program or that they would get foreclosure defense from a private
17 attorney general.
18 171. In truth and fact, the documents are false documents and no such guarantees could be
19 made, as MEI, Cynthia Louise Brown, Billie Rene Powers, Anthony T. Williams, and Barbara
20 Williams, were not licensed in the State of California to create, service, or modify loans and Anthony T.
21 Williams and Cynthia Louise Brown were not licensed attorneys in the State of California and could not
22 represent the homeowner in legal matters.
23 172. This not only happened in California, it happened in other states around the country too.
24 Plaintiff is informed and believes and alleges thereon that on or about December 4, 2013, a false UCC
25 Financing Statement was filed on behalf of E.S. and A.S. with the BOC by MEI and the Defendants. On
26 or about May 8, 2015, E.S. and A.S., signed a document entitled "MORTGAGE," which was filed on
27 May 26, 2015 with the BOC. This false document states that it makes null and void the original
28 mortgage instrument recorded in the State of Hawaii, Bureau of Conveyance and any other instrument
preceding it. The document included a "NOTE" purporting to set out the terms of the loan and
24
#:1152
1 repayment to MEI. The mortgage and the note were notarized by Anabel Cabebe for a fee. E.S. and A.S.
2 mailed monthly checks for the new payment amount, to MEI, P.O. Box 1215, Killeen, Texas 76549.
3 173. The Defendants failed to inform E.S. and A.S. that there was no MEI mortgage on their
4 home and that the original lenders mortgage was still valid, thereby causing the original mortgage to
5 become increasingly delinquent.
6 174. On or about June 20, 2013, R.L and M.L., homeowners in Hawaii, met with Anthony T.
7 Williams, paid him a fee, and filled out the MEI application and documents that were provided to them.
8 The MEI application and documents offered a mortgage reduction program and were signed by
9 Anthony T. Williams. Anabel Cabebe collected a fee for notarizing several of the documents associated
10 with the application. The application included the HSGA and the HGS Form 330. In truth and fact, the
11 HSGA and HGS Form 330, are false documents and no such guarantees could be made, as MEI,
12 Anthony T. Williams, and Barbara Williams, were not licensed in the State of Hawaii, by the DCCA,
13 Division of Financial Institutions, to create, service, or modify loans and Anthony T. Williams was not
14 a licensed attorney in the State of Hawaii and could not represent the homeowner in legal matters.
15 175. On or about October 23, 2013, a false UCC Financing Statement was filed on behalf of
16 R.L. and M.L. with the BOC by MEI and the Defendants. On or about December 30, 2014, R.L. and
17 M.L., signed a false document entitled "MORTGAGE," which was filed on January 6, 2015 with the
18 BOC.
19 176. This false document states that it makes null and void the original mortgage instrument
20 recorded in the State of Hawaii, Bureau of Conveyance and any other instrument preceding it. The
21 document included a “NOTE” purporting to set out the terms of the loan and repayment to MEI. The
22 mortgage and the note were notarized by Anabel Cabebe for a fee. R.L. and M.L. paid their new
23 monthly mortgage payments, to MEI. The Defendants failed to inform R.L. and M.L. that there was no
24 MEI mortgage on their home and that the original lenders mortgage was still valid, thereby causing the
25 original mortgage to become increasingly delinquent.
26 177. In November of 2014, the MEI mortgage reduction program was presented to Defendant
27 Billie Rene Powers, a homeowner in Orange County, California and representative of MEI. Billie Rene
28 Powers was told that her mortgage payment would be cut in half, the term would be reduced by half,
and the program was 100% refundable.
25
#:1153
1 178. Defendant Billie Rene Powers signed up for the MEI mortgage reduction program. In
2 truth and fact, MEI and the Defendants could not offer a mortgage reduction program in California as
3 MEI, Anthony T. Williams, and Barbara Williams, were not licensed to do so.
4 179. On or about November 26, 2014, Defendant Billie Rene Powers signed a false document
5 entitled "DEED OF TRUST," which was filed on November 26, 2014, with the Orange County
6 Recorder’s Office. The document states that it replaces and makes null and void the original mortgage
7 instrument recorded in the State of California, Orange County Recorder’s Office and any other
8 instrument preceding it. The document included a “NOTE” purporting to set out the terms of the loan
9 and repayment. The mortgage and the note were notarized for a fee. Starting in January of 2015, Billie
10 Rene Powers was expected to pay MEI $1,030.00 monthly mortgage payments to be mailed to Killeen,
11 Texas.
12 180. On or about December 9, 2014, Defendant Valerie Lopez signed a false document
13 entitled "DEED OF TRUST," which was filed on December 9, 2014, with the Orange County
14 Recorder’s Office. The document states that it replaces and makes null and void the original mortgage
15 instrument recorded in the State of California, Orange County Recorder’s Office and any other
16 instrument preceding it. The document included a "NOTE" purporting to set out the terms of the loan
17 and repayment. The mortgage and the note were notarized for a fee. Starting in February of 2015,
18 Valerie was expected to pay MEI $1,441.46 monthly mortgage payments to be mailed to Killeen,
19 Texas.
20 181. Plaintiff is informed and believes and alleges thereon that Defendant Billie Rene Powers
21 introduced a homeowner living in San Diego County, California to the MEI mortgage reduction
22 program. The homeowner paid Billie Rene Powers and/or Anthony T. Williams $4,000.00 for the
23 program after being referred by a friend.
24 182. The homeowner signed a false document entitled "DEED OF TRUST", which was filed
25 with the San Diego County Recorder’s Office. The document states that it replaces and makes null and
26 void the original mortgage instrument recorded in the State of California, San Diego County Recorder’s
27 Office and any other instrument proceeding it. The document included a "NOTE" purporting to set out
28 the terms of the loan and repayment. The DEED OF TRUST and the NOTE were notarized for a fee.
The homeowner was required to pay all costs for recording and filing.
26
#:1154
1 183. The Defendants failed to inform the San Diego homeowner that there was no MEI
2 mortgage on their home and that the original lenders mortgage was still valid, thereby causing the
3 original mortgage to become increasingly delinquent.
4 184. Plaintiff is informed and believes and alleges thereon that this pattern repeated at least
5 one dozen times with similar “DEED OF TRUST” and “NOTE” documents being recorded in various
6 counties throughout California.
7 185. Plaintiff is informed and believes and alleges thereon that four (4) DEEDS OF TRUST
8 containing false statements with MEI as mortgager were recorded in the San Diego County Recorder’s
9 Office. Plaintiff is informed and believes that those homeowners in San Diego were not like the
10 Defendants who were part of opening up operations or a recruiter.
11 186. Defendants did not inform the homeowners that the original mortgages on the
12 homeowner's properties were not paid off and their loans were not modified as promised. The
13 Defendants did not inform the homeowners that the payments being made to MEI were being used to
14 pay the Defendants' personal expenses, and were deposited into a MEI bank account in Texas.
15 187. At all times during this scheme, Defendants failed to advise the homeowners that they
16 were not actually creating, servicing, or modifying the mortgage on their homes and that the document
17 entitled "Deed of Trust" and “Note” that was being filed with the County Recorder’s Offices in the State
18 of California was false.
19 188. This not only happened in CLOA/MEI scheme, it happened in Orange County,
20 California to other homeowners by similar loosely fitted organizations which resulted in retaliation
21 against Plaintiff. Plaintiff is informed and believes and alleges thereon that on or about May 12, 2008, a
22 false Deed of Trust was filed on behalf of N.K. and H.K. with the Orange County Recorder’s office by
23 First Coastal Mortgage, Gary A. Schneider, Francis B. Lantieri, and investors who would later refer to
24 themselves as 10675 S Orange Park Blvd, LLC. On or about May 12, 2008, N.K. and H.K., signed a
25 document entitled "DEED OF TRUST," which was filed on or about May 12, 2008 with the Orange
26 County Recorder’s Office. This false document states that it makes null and void the original mortgage
27 instrument recorded in the State of California and any other instrument preceding it. First Coastal
28 Mortgage presented N.K. and H.K. with a "NOTE" purporting to set out the terms of the loan and
repayment to First Coastal Mortgage. The Note that N.K. and H.K. signed was later swapped out by
27
#:1155
1 Defendants increasing the payment by $600,000.00. The Defendants failed to inform N.K. and H.K. that
2 they changed the terms of the Note.
3 189. The Defendants also failed to inform N.K. and H.K. that the original lenders mortgage
4 was still valid, thereby causing the original mortgage and/or all of the junior loans on their property to
5 become increasingly delinquent. The Defendants failed to inform N.K. and H.K. they made a secret deal
6 with the other lenders allowing them to pay off the other mortgages without recording the reconveyance
7 so that N.K. and H.K. could not use equity from their home, making it appear that there was none until
8 Defendants foreclosed and took the home at credit bid, although they were not in the first or even
9 second position creditor with a lien on the property as shown by the property recordings.
10 190. N.K. and H.K. were Plaintiff’s clients and on or about April 3, 2013 they filed a report
11 with law enforcement who opened up an investigation No. 13-061001 for possible penal code violation
12 484(2). A cancelled Notice of Restoration was altered and posted on the property and N.K. and H.K.
13 were ousted. Plaintiff kept pressing the issue of the altered documents and fraud, so Defendants
14 retaliated by preparing or causing to be prepared two Civil Harassment lawsuits against Plaintiff on
15 April 17, 2014 then actually filing or causing them to be filed against Plaintiff on August 29, 2014.
16 Defendants conspired with the CLOA Enterprise including Defendants Cynthia L. Brown, George
17 Olivo, Maegan Donovan Nikolic, Pam Ragland, Sheri Moody and David Seal in doing so.
18 191. Plaintiff is informed and believes and alleges thereon that on or about December 24,
19 2014 the property formally owned by N.K. and H.K. was sold for $1.7 million with the liens still
20 thereon and placed in the name of a construction contractor who later received regular multi-million-
21 dollar contracts from the Orange County Board of Supervisors from on or about May 2015 through to
22 the present.
23 192. When Plaintiff tried to report these schemes or the Defendants felt Plaintiff had
24 somehow slighted them or put their schemes at risk of exposure they retaliated against by filing or
25 causing others to file false police reports, false State Bar complaints, false requests for civil harassment
26 orders; or give false testimony in court; or make false allegations to the public; or commit or threaten
27 violence against her; or interfere with or take her property which directly and proximately caused
28 Plaintiff harm to her person and property. The discovery sanction charges used to retaliate against
Plaintiff that were filed with the State Bar came from the representation of N.K. and H.K. filed by the
same Lenders who filed for the civil harassment orders which the CLOA Enterprise was promoting.
28
#:1156
1 FIRST PREDICATE ACT (Mail Fraud, 18 U.S.C. §1341)

2 193. Plaintiff re-alleges and incorporates herein by reference the allegations contained
3 in paragraphs 1 through 192, as if fully set forth herein.
4 Date Document Where Recorded
5 11/26/14 Cynthia Brown Deed of Trust Orange County, CA
6 11/26/14 Rene Powers Deed of Trust and Orange County, CA
7 Note
8 12/9/14 Valerie Lopez Deed of Trust Orange County, CA
9 and Note
10 3/13/15 Sheri Moody Deed of Trust and Orange County, CA
11 Note
12 3/30/15 2015000159968 Lis Pendens Orange County, CA
13 7/17/15 201500037314 Trust Deed Orange County, CA
14 3/10/16 2016000100408 Judgment Orange County, CA
15 5/05/16 2016000200308 Withdrawal Orange County, CA
16 2/02/15 A.E. San Diego County, CA
17 3/20/15 A.E. San Diego County CA
18 5/01/15 M.H. San Diego County CA
19
7/01/15 Z.M. San Diego County CA
20
194. On or about the dates stated, in the State of California and elsewhere, for the purposes of
21
executing or attempting to execute the above-described scheme and artifice to defraud, Defendants,
22
ANTHONY T. WILLIAMS, RENE POWERS, CYNTHIA L. BROWN and/or BARBARA
23
WILLIAMS, knowingly caused to be delivered by mail and a private and commercial interstate carrier
24
according to the direction thereon, the following matter, with each constituting a separate predicate act:
25
195. Plaintiff is informed and believes and alleges thereon that the following MEI documents
26
were mailed through the U.S. mails as a result and/or in furtherance of the fraudulent scheme by CLOA
27
and/or MEI.
28
196. Plaintiff is informed and believes and alleges thereon that said persons used the U.S.
mails to mail payments to MEI in Killeen, Texas and/or to Newport Beach, California (investigation
and discovery is continuing in this area).
29
#:1157
1 197. On or about the dates stated, in the State of California and elsewhere, for the purposes of
2 executing or attempting to execute the above-described scheme and artifice to defraud, Defendants,
3 ANTHONY T. WILLIAMS, RENE POWERS, CYNTHIA L. BROWN and GEORGE OLIVO,
4 knowingly used the mails for this purpose to divert clients away from Plaintiff’s business to their own
5 by using schemes as alleged elsewhere in this pleading. As a direct and proximate result, Plaintiff was
6 injured in her business and property.
7 198. Plaintiff is informed and believes and alleges thereon that all were in violation of
8 Title 18, United States Code, Section 1341.
9 SECOND PREDICATE ACT (Wire Fraud 18 U.S.C. §1343)
10 199. Plaintiff re-alleges and incorporates herein by reference the allegations contained in
11 paragraphs 1 through 198, as if fully set forth herein.
12 200. As to the CLOA/MEI homeowner foreclosure rescue scheme outlined above, Plaintiff is
13 informed and believes and alleges thereon that on or about the dates stated, within the State of
14 California and elsewhere, for the purpose of executing, and attempting to execute, the aforesaid scheme
15 and artifice to defraud, Defendants, ANTHONY T. WILLIAMS, RENE POWERS, CYNTHIA
16 LOUISE BROWN and BARBARA WILLIAMS, did knowingly transmit, and/or cause to be
17 transmitted, in interstate and foreign commerce, by means of wire communications, certain signs,
18 signals and sounds, that is, the following wirings, with each such wire communication constituting a
19 separate predicate act:
20
21 Date of E-filing of UCC Homeowner Initials From If UCC Finance Statement
Finance Statement to State of California Was Terminated within First
22
Texas Three Months (y)
23 7/18/13 E.B. & H.B. Y
24 7/27/13 M.A. Y
25 7/27/13 M.A. Y
26 7/27/13 J.T. Y
27 8/30/13 E.A. & J.A. Y
28 8/21/14 S.D. & K.D.
11/17/14 I.E. & C.E.
11/18/14 Defendant Billie Rene Powers
30
#:1158
1 11/25/14 Defendant Cynthia Louise

2 Brown
3 11/26/14 Defendant Valerie Lopez Y
4 12/15/14 G.D.
5 1/12/15 C.Z.
6 3/15/15 G.C.
7 4/27/15 M.H.
8 6/19/15 Z.M.
9 7/02/15 J.O.
10 7/15/15 V.Y.
11 201. Plaintiff is informed and believes and additionally alleges thereon that emails were sent
12 or caused to be sent by Defendants Rene Powers, Cynthia Louise Brown and Anthony Troy Williams
13 regarding customers payments under the various CLOA programs during this time period constituting
14 additional wire communications with the intent to defraud as part of the homeowner rescue scheme.
15 (More investigation and discovery is needed in this regard).
16 Common Law Grand Jury and the Ventura Scheme
17 202. Furthermore, Defendants Anthony T. Williams, Rene Powers, George Olivo and Sheri
18 Moody advertised a homeowner event CLOA was hosting in Ventura County on the internet. On or
19 about February 21, 2015, within the State of California, for the purpose of executing, and attempting to
20 execute, the aforesaid scheme and artifice to defraud, Defendants, ANTHONY T. WILLIAMS, RENE
21 POWERS, CYNTHIA LOUISE BROWN, GEORGE OLIVO and WILLIAM WAGENER, did
22 knowingly transmit, and/or cause to be transmitted, in interstate and foreign commerce, by means of
23 wire communications, certain signs, signals and sounds, that is, the following wirings from the Crowne
24 Plaza Hotel located in Ventura, California, with each such wire communication the CLOA event “Stop
25 Judicial Corruption and Save our Homes.”
26 203. Plaintiff is informed and believes and alleges thereon that Defendants Rene Powers and
27 Anthony T. Williams created a Facebook event page: “You Are Invited to: Stop Judicial Corruption and
28 Save Our Homes”
31
#:1159
1 204. Plaintiff is further informed and believes and alleges thereon that Defendant George
2 Olivo created a similar event page on Facebook to advertise CLOA’s homeowner event in Ventura that
3 took place on February 21, 2015.
4 205. Defendant Rene Powers organized ‘satellite’ viewing for people who could not
5 physically travel to Ventura, California to participate in the event. On February 21, 2015, Paul Murray
6 and Defendant George Olivo participated by live streaming the event so others who could not make it to
7 the satellite locations could also view the event. On February 21, 2015 Defendants Cynthia Louise
8 Brown, William Wagener and Anthony T. Williams actively participated by speaking at the Ventura,
9 California Event. Defendant Anthony T. Williams represented that the people have a right to form their
10 own Common Law Grand Juries and solicited people in California to do so. Anthony T. Williams
11 discussed how people needed to organize their own militia to arrest judges who were not keeping their
12 oath of office if the sheriffs refused to arrest them based on a Common Law Grand Jury indictment. On
13 February 21, 2015 Defendant George Olivo recorded Anthony T. Williams for other viewers telling
14 homeowners in California and elsewhere that 12 to 23 people are needed for a Common Law Grand
15 Jury. He said 25 people are best because some people are not available when you need them in order “to
16 issue an indictment.” He told the people that “common law” and “federal common law” under “U.S. v
17 Williams” allows this to occur. He told the people that indictments were needed “especially” for
18 “judges” “to make sure they are not untouchable.” He informed the public that they have a Common
19 Law Grand Jury in Florida “indicting a judge” and that it “will make news” when they “prosecute.” He
20 explained there is a form that basically says “I will kill them” at the 9:58 mark of the video. He further
21 explained that CLOA has a “militia to execute the warrant” if the sheriff will not. He held himself out as
22 a Private Attorney General and gave the email address of awilliams@usacommonlaw.com.
23 206. Paul Murray’s job description with CLOA on the CLOA website stated he was
24 “Chief/PAG.” Plaintiff is informed and believes and alleges thereon that Paul Murray joined CLOA on
25 or about November 13, 2014. The CLOA website represented that Paul Murray was employed with the
26 “Dept. of Justice as a Deputy U.S. Marshall.” It goes on to talk about felony fugitives, hostages,
27 surveillance and weapons training. Plaintiff is informed and believes and alleges thereon that Paul
28 Murray was not a U.S. Marshall or other federal officer.
32
#:1160
1 207. Like the other co-Defendants of Anthony T. Williams, Paul Murray was a homeowner in
2 distress who apparently was recruited by CLOA. He signed up with MEI and a UCC Filing Statement
3 was recorded with him as debtor in the Secretary of State office in Texas on or about February 3, 2015.
4 208. The Ventura event was free but private. However, Plaintiff is informed and believes and
5 alleges thereon that there was a power point presentation portion that the attendee had to pay for or if
6 they desired services such as forms and that there was a payment associated with that as well. There is
7 no such thing as a legal Common Law Grand Jury and the event was a way to defraud homeowners and
8 others by luring them into the paid services of CLOA.
9 209. Plaintiff is informed and believes and alleges thereon that Defendants George Olivo,
10 Rene Powers, Cynthia L. Brown and Sheri Moody all told stories about how Plaintiff ruined their cases
11 or others that they knew. These acts directly and proximately caused loss of business and property of
12 Plaintiff occurred within the State of California and elsewhere, for the purpose of executing, and
13 attempting to execute, the aforesaid scheme and artifice to defraud to get homeowners to sign up with
14 PAGs instead of “attorneys at law.”
15 210. Defendants, ANTHONY T. WILLIAMS, RENE POWERS, and CYNTHIA LOUISE
16 BROWN, did knowingly transmit, and/or cause to be transmitted, in interstate and foreign commerce,
17 by means of wire communications, certain signs, signals and sounds, that is, the following wirings, with
18 each such wire communication constituting a separate predicate act to wit: Defendant Rene Powers sent
19 an email (with Defendant Anthony T. Williams and Defendants Cynthia Louise Brown and Valerie
20 Lopez in the cc line) dated January 21, 2015 to the NLA (a national association for sovereign citizens)
21 and others which read in part,
22 “I have been asked to get a grand jury together in Orange County and Los Angeles.
Anthony Williams, Private Attorney General, has said to put the word out now. Olympian
23
Cynthia Brown has been destroyed unlawfully by the court and today was the last straw.”
24 It went on to state: “She had an appeals attorney tank her case and today this judge ruled
unlawfully from her office.”
25
26 211. Plaintiff was the “appeals attorney” and ret. judge Schulte was the “court” referred to in
27 the January 21, 2015 email. The following day two strange men with badges and a laptop pulled up to
28 Plaintiff’s home.
212. The day before the request for a Common Law Grand Jury, on January 20, 2015 David
Seal, Karen Rozier, and Defendants Maegan Donovan Nikolic, Pam Ragland actively participated in a
33
#:1161
1 harassing, mass bullying string of emails that David Seal started against Plaintiff (73 email exchanges
2 based on a lie that David Seal was responding to a prior harassing email).
3 213. The following day after the request for a Common Law Grand Jury, on January 22, 2015
4 two strange men pulled up to Plaintiff’s home in an unmarked Tundra truck, with badges on their shirts
5 and the passenger had a laptop.
6 214. In or about 2015, Plaintiff also started receiving “court notices” in her email asserting
7 she needed to open up an attachment with notice because she was summoned to appear in court, the
8 implication and surrounding circumstances a Common Law Grand Jury may have been formed. The
9 court notices were false. They were not being sent from a real court or by a real court clerk. The emails
10 varied in their content, but each basically said she would be tried in her absence if she did not appear.
11 Two were saved:
12
13 Date Court Notice Court Date
14 6/18/15 Notice to Appear in Court 6/26/15
15 #00000757499 “The case will
be heard by the judge in your
16 absence if you do not come.”
17 Ken Peterson, Clerk of Court
8/21/15 Notice to Appear in Court 8/26/15
18 “Note: The case may be heard
19 by the judge in your absence
if you do not come.” Steve
20 Moon, District Clerk
21
22 215. Initially, Plaintiff deleted the emails, however, after the off-line activities escalated
23 against her, she decided to save one or two.
24 216. When Plaintiff alerted law enforcement to warn judge Schulte after she discovered the
25 email, on or about February 26, 2015 a fake profile popped up online and told Plaintiff over the internet
26 that Plaintiff was “a marked person” and she would be going to “prison.”
27 217. So, Plaintiff filed the January 21, 2015 email by Rene Powers with the federal court on
28 or about March 1, 2015 which caused further retaliation against Plaintiff’s business and her property in
violation of Title 18, United States Code, Section 1343.
The Monkey and the Snake Project
34
#:1162
1 218. When Defendant Anthony T. Williams learned that Plaintiff discovered their CLOA
2 scheme and reported it, in retaliation, he did knowingly transmit, and/or cause to be transmitted, in
3 interstate and foreign commerce, by means of wire communications, certain signs, signals and sounds,
4 that is, the following wirings, with each such wire communication constituting a separate predicate act.
5 219. Defendant Anthony Williams added or caused to be added to his Common Law Office of
6 America website Plaintiff’s name and likeness between and placed it between a photo of a Monkey and
7 a Snake on a web page captioned PUBLIC NOTICE which then read:
8 Lenore Albert has manifested her colossal ignorance by defaming the name and character
of Private Attorney General Anthony Williams and Common Law Office of America.
9
Lenore Albert is a bar card carrying criminal and scam artist who has defrauded many
10 consumers and have multiple open complaints against her by several citizens of
California with the State Bar. If you have been harmed by this blonde headed snake
11
please call the California State Bar to file a complaint.
12
Lenore Albert Blonde Headed Snake
13
The coral snake has red, black and yellow (blonde) colors and it is no coincidence that
14
Lenore Albert has the same colors on in this picture showing that she has characteristics
15 similar to a venomous coral snake.
16
Lenore Albert Monkeying Around With People's Rights
17
Lenore Albert continues to run a monkey business of a law firm and is under
18
investigation by the California State Bar. Don't let her monkey around with your money
19 or your case.
20
Why did I open my big mouth against Common Law Office of America? Why? Why?
21 Why?
22 [End of CLOA Website posting]
23 220. As a direct and proximate cause of this internet posting, it harmed Plaintiff in her
24 business and property. Plaintiff reported this to the California State Bar but the California State Bar
25 continued to accept State Bar complaints against Plaintiff, requiring Plaintiff to defend herself without
26 screening that they were not being generated from this activity, even when Plaintiff reported as much. In
27 fact, the State Bar took “tips” so as not to disclose their informants (like FMC) and started to label said
28 complaints as “State Bar investigations.” As such, the State Bar Defendants, Caitlin Elen-Morin, Alex
Hackert, Timothy Byer, Maricruz Farfan, State Bar Employee and the California State Bar aided and
abetted, acted jointly and severally, partnered with, acquiesced in having Anthony T. Williams as their
35
#:1163
1 agent, and/or conspired with Defendant Anthony T. Williams and other co-Defendants which directly
2 and proximately harmed Plaintiff in her business and property.
3 221. Unlike the California State Bar, when Anthony T. Williams scheme was reported in
4 Hawaii, he was charged with unlicensed practice of law. Additionally, after news reporter Carmel
5 Cafario received threats from Defendant Anthony T. Williams in Florida, on or about November 16,
6 2015 Anthony Troy Williams was arrested in Florida and charged with the unauthorized practice of law.
7 The following year, on or about March 2, 2016 Anthony T. Williams was sentence to 180 days jail and
8 22-years of probation for practicing law in Florida without a license.
9 222. In contrast, when Plaintiff complained to the State Bar that Defendant Cynthia L. Brown
10 was harassing Plaintiff by filing false complaints that she could not get her files and Plaintiff was going
11 to ship the files to the State Bar if Brown did not pick them up, on or about November 11, 2014 the
12 State Bar called Plaintiff’s office making it appear that Cynthia L. Brown was acting as an investigator
13 and agent for the State Bar and Sheri Moody as their witness which Cynthia L. Brown so represented
14 when she called the Huntington Beach Police Department and had them escort her to Plaintiff’s office
15 and then physically take the boxes of files out of the building.
16 223. Plaintiff is informed and believes and alleges thereon that what the Defendants are
17 actively participating in is a complex scheme of white collar activity that cannot be neatly tied into one
18 box with a bow. CLOA and Cal 18 were but a few of the organizations these Defendants operated in or
19 through using sovereign citizen tactics. Defendants Cynthia L. Brown and Anthony T. Williams were
20 also Private Attorney Generals for the “United States Office of the Private Attorney General,” P.O. Box
21 166091, Little Rock, Ark 72216 which Plaintiff is informed and believes and alleges thereon violator
22 Eric Stanberry operated. The “trustee” listed on the fake CLOA DEEDS OF TRUST recorded in
23 California was also a fake enterprise. “Federal Mortgage American Trust” is not located at 6230 3rd
24 Street, Washington, D.C. 20011 or anywhere else. It is the “Institute of Spiritual Enlightment” located
25 at that address. However, that organization appears to be tied to Defendant Anthony T. Williams via the
26 URL “IseenEnlightenment.” But, there was no licensing for “Federal Mortgage American Trust” to
27 legally operate through and none of the Defendants, Billie Rene Powers, Anthony T. Williams, or
28 Cynthia L. Brown had the proper licenses to sign as trustee. The Defendants move in and out of these
organizations and they use other organizations independently of each other. For example, Defendant
Cynthia Louise Brown filed another false UCC Finance Statement or caused said document to be filed
36
#:1164
1 with California Secretary of State on or about July 8, 2015 using “M.T. Law Group, Inc.” located at
2 11012 Ventura Blvd, #253, Studio City, CA 91604. There is no such law office registered with
3 California located at this address with attorneys licensed to practice law in the State of California.
4 Plaintiff is further informed and believes and alleges thereon that the “Moorish Temple Law Group,
5 Inc.” which was operated by David Bey was located at this address. Plaintiff is further informed and
6 believes and alleges thereon that David Bey was not licensed to practice law in the State of California.
7 Plaintiff is further informed and believes and alleges thereon that the documents filed by “M.T. Law
8 Group, Inc.” (approximately 50) had indicia of sovereign citizen ideology. For example, some were
9 “land patents” or they had copies of “coins” attached to the documents. Furthermore, the “Moors” is an
10 extension and/or type of sovereign citizen ideology like the latter name implies.
11 224. Defendants Greg Diamond and Vern Nelson did a similar thing to Plaintiff online to
12 disparage and discredit her in or about 2017 to 2018, but it did not have Monkeys and Snakes like the
13 CLOA website. Greg Diamond and Vern Nelson placed or caused to be placed a meme online with
14 Plaintiff’s profile photo and put on it that she threatened to decapitate people. They implied to others
15 over the internet that Plaintiff was suspended because she threatened decapitation to opposing counsel
16 and for hurting homeowners. This was in fact false however, it furthered the enterprises scheme to
17 defraud which proximately and directly caused injury to Plaintiff’s business and property. Greg
18 Diamond used his credentials as an attorney with an unblemished record in support of his conclusions
19 about Plaintiff. In fact from 2015 to the present, Greg Diamond has publicly posted to his audience
20 statements implying he had much “dirt” on Plaintiff that he was going to expose because she was going
21 to be suspended or disbarred for her actions against homeowners. As a direct and proximate result of
22 Defendant Greg Diamond’s active participation and conduct he materially assisted Defendants George
23 Olivo, Pam Ragland, Maegan Donovan Nikolic, Anthony T. Williams, Cynthia L. Brown, Sherry
24 Hernandez, Monica Jones, Rene Powers and Sheri Moody in their scheme to defraud. This conduct
25 harmed Plaintiff directly and proximately to her business and property. The online publications are on
26 the internet for the public to see. As a result, the danger is not that one of the named Defendants who
27 participated in the publication, but that unknown reader who may be incited to act out with violence
28 against Plaintiff or decide to research Plaintiff on the internet after being incensed over Defendants false
light statements of decapitation being attributed to Plaintiff and then watch the William Wagener videos
and believe it is their duty to follow through with a Common Law Grand Jury against Plaintiff and
37
#:1165
1 retaliate believing holding her for treason would be their civic duty. As such, these videos create a high
2 degree of risk to the health, welfare and safety of Plaintiff which is directly and proximately caused by
3 the Defendants.
4 225. This conduct, as alleged, was in violation of Title 18, United States Code, Section 1343.
5 The Grand Theft Project
6 226. Defendants Cynthia L. Brown, Pam Ragland, Maegan Donovan Nikolic, George Olivo,
7 Sheri Moody and Monica Jones knew Ms. Albert was in a dispute with her auto dealership over her
8 registration. The Defendants also knew Plaintiff was in litigation against Defendants Pam Ragland,
9 Maegan Donovan Nikolic, David Seal, Devin Lucas and others because in August 2014 she
10 characterized their conduct to be defamatory. So, the Defendants devised a scheme to convince the
11 finance company to commit auto grand theft under the guise of a repossession in retaliation or revenge
12 for exposing them as sovereign citizens and/or using sovereign citizen techniques.
13 227. Defendants, RENE POWERS, CYNTHIA LOUISE BROWN, MONICA JONES,
14 SHERI MOODY, GEORGE OLIVO and PAM RAGLAND, did knowingly transmit, and/or cause to be
15 transmitted, in interstate and foreign commerce, by means of wire communications, certain signs,
16 signals and sounds, that is, the following wirings, with each such wire communication constituting a
17 separate predicate act in furtherance of a plan they devised to take Plaintiff’s vehicle and personal
18 property therein while she was at court, which they accomplished on or about April 6, 2015 as an act of
19 revenge or retaliation. As a direct and proximate result of this scheme, Plaintiff was injured in her
20 business and property. She knew the Defendants were involved because they were outside the
21 courthouse to ambush her on that date but it was only through discovery in the case of Ford Motor
22 Credit v Albert that Plaintiff gained some evidence of the conspiracy which was in or about 2016.
23 228. On or about March 9, 2015 Lisa Brumfiel held a radio broadcast to educate others on
24 Common Law Grand Juries that Defendant Monica Jones shared with her friends and Defendant Pam
25 Ragland offered assistance if they wanted more speakers.
26 229. Then Defendants Monica Jones, Pam Ragland, Sheri Moody, Maegan Nikolic, Cynthia
27 Louise Brown and others coordinated the conspiracy by making contact with Plaintiff’s auto dealership,
28 Friendly Ford (“FF”) in Las Vegas, Nevada on March 9, 2015 by phone. Then she contacted Plaintiff’s
finance company Ford Motor Credit Company (“FMC”) before there was a repossession order on the
vehicle. She even had contact with their repossession unit, Dedicated Recovery (“DR”) as follows:
38
#:1166
1 230. [Table]
2 Date Caller/Receiver Subject of phone conversation
3 3/9/15 MJ to FF Information on Plaintiff’s vehicle. MJ
knows there are no plates.
4 3/9/15 FF to FMC Received phone call from Monica Jones
5 asking if we were looking for borrower’s
vehicle. She knows where it is.
6 3/18/15 Plaintiff to FMC Attempting to make vehicle payment.
7 3/25/15 FMC to MJ Please call us about Plaintiff
3/25/15 MJ to FMC MJ tells FMC that Plaintiff gets restraining
8 orders against people that MJ knows and
9 she knows criminals and other salacious
statements.
10 3/26/15 MJ to FMC MJ tells FMC where Plaintiff’s employee
11 11:15AM lives and also that the employee is her
driver and terrified of Plaintiff.
12 3/26/15 MJ to FMC MJ tells FMC Plaintiff’s next court date
13 13:01PM and recasts it as a new lawsuit against
RipOff Report.
14 3/26/15 MJ to FMC MJ tells FMC Plaintiff has court tomorrow
15 14:08PM
3/27/15 MJ to FMC MJ tells FMC Plaintiff’s court is
16 postponed to 3/30/15 and MJ is in contact
17 with former employee helping her.
3/28/15 MJ to FMC FMC gives MJ the direct phone number of
18 field representative (repossessor)
19 4/1/15 MJ to FMC FMC reminds of $300 finder fee
4/6/15 FMC to DR FMC says “adv per informant, vehicle is
20
parked at the courthouse…she’ll get ahold
21 of driver right away.”
4/6/15 DR to FMC “recovered by informant’s information”
22
4/7/15 DR to FMC and Finder Fee of $300.00 to Monica Jones
23 FMC to DR discussion
24
25 231. Plaintiff is informed and believes and alleges thereon that while Defendant Monica Jones
26 was in communication with FF and FMC, Defendant Sheri Moody was in telephone communication on
27 the Auto Theft Project with FMC’s attorneys, and Defendant Cynthia L. Brown was in telephone
28 communication with the Repossession company and/or its driver. On April 6, 2015 at the Orange
County Superior Courthouse, Sheri Moody, David Seal, Maegan Donovan Nikolic, Cynthia L. Brown,
Devin Lucas, were at the Orange County Superior Courthouse and had Plaintiff’s vehicle towed under
the false premise it was being “lawfully repossessed;” videotaped it; then waited for Plaintiff to exit the
39
#:1167
1 courthouse and photographed/videotaped her expression in seeing it not there. Then memes, photos and
2 videos were uploaded to the internet, and shared and discussed by the Defendants including but not
3 limited to Cynthia L. Brown, Maegan Donovan Nikolic, Pam Ragland, Norma White, George Olivo,
4 and Monica Jones. Because the individual Defendants were not parties to the state litigation between
5 Plaintiff and FMC, Plaintiff was not able to obtain discovery into the Defendants’ communications.
6 Plaintiff is informed and believes and alleges thereon that after Plaintiff is able to gain those
7 communications from Monica Jones, Sheri Moody, Maegan Donovan Nikolic, Norma White and
8 Cynthia L. Brown, the communications and overt acts will include the actors at trial that day, including
9 but not limited to attorneys David Seal, Devin Lucas, Mitchell Hannah; and Defendants George Olivo,
10 Anthony T. Williams, Sherry Hernandez and even possibly the attorneys of FMC or FF.
11 232. David Seal filed a false civil harassment lawsuit against Plaintiff in further of
12 Defendants’ goals which required Plaintiff to relinquish her firearm on or about February 23, 2015 until
13 the matter could be heard by the court.
14 233. Defendant Monica Jones said she did it out of revenge; Defendant Sheri Moody said she
15 did it to take Plaintiff down; and Defendant Cynthia L. Brown said she did it because it was funny and
16 her duty in violation of Title 18, United States Code, Section 1343.
17 Citibank Fraud
18 234. On or about October 31, 2017 Citibank unexpectedly froze her out of all of her bank
19 accounts. As a result of the freeze out she missed a dental appointment. Plaintiff does not drive and
20 depended on her app to summons a driver which would not work because the bank account was frozen.
21 235. Plaintiff went online to her online banking account to review her account but Citibank
22 had wrongfully locked her out of the account.
23 236. Plaintiff immediately called the phone number on the back of her debit card. Defendant
24 Citibank told her that her accounts were being closed. The Citibank representative could not tell her
25 when or why or even when the money remaining in the accounts would be mailed.
26 237. She went to the local branch where it was discovered that Citibank closed the accounts
27 due to “compliance.” However, none of her accounts had been reviewed and an account needs to be
28 reviewed to determine if it is in “compliance” or not. Plaintiff had been a customer of that branch for
over ten years so the local branch manager tried to implore with Citibank to reverse or rectify what was
going on but they would not. The review of what he could see was that no Citibank employee had
40
#:1168
1 actually went in to review Plaintiff’s account for a long time. Furthermore, nothing in the account
2 looked suspicious.
3 238. This was like trying to work with Ford Credit all over again.
4 239. Plaintiff complained and was suddenly left without a bank account and fearful that
5 another bank may not open an account for her due to some lingering false SAR report. Since a SAR
6 report was issued without an employee actually going into the account to review it, Plaintiff is informed
7 and believes and alleges thereon that Defendant Citibank wrongfully committed wire fraud on
8 Plaintiff’s regular account and a second count of wire fraud in closing and locking her out of her client
9 trust account.
10 240. The terms of the Citibank account did not state that Citibank could close Plaintiff’s
11 account without cause and notice or freeze her money.
12 241. Plaintiff is informed and believes and alleges thereon that Citibank’s co-Defendants were
13 able to communicate with Citibank and cause Plaintiff’s account to shut down, however discovery and
14 investigation is needed to identify which co-Defendants did it this time, like the discovery was needed
15 in the Ford case to prove the interference and discover Defendant Monica Jones was the point person,
16 while Sheri Moody was the contact person to Ford’s attorneys. Large financial institutions have policies
17 and procedures in place to prevent even the slickest con scheme from being played out and Plaintiff
18 believes that through a fraudulent scheme or device those policies and procedures were violated to the
19 injury of Plaintiff in violation of 18 USC §1343.
20 ADA – USDOJ Impersonation
21 242. Defendant, Karin Huffer did knowingly transmit, and/or cause to be transmitted, in
22 interstate and foreign commerce, by means of wire communications, certain signs, signals and sounds,
23 that is, the following wirings, with each such wire communication constituting a separate predicate act
24 in furtherance of a plan she devised to defraud others in the legal process.
25 243. Plaintiff is informed and believes and alleges thereon that Defendant Cynthia L. Brown
26 took Karin Huffer’s online program to learn how to gain access to the courts without being a licensed
27 attorney or party to the action. Neither Karin Huffer nor Cynthia L. Brown are licensed attorneys and
28 neither in fact work for the civil division of the U.S. Department of Justice.
244. Karin Huffer is a family therapist and advertises Equal Access Advocates company with
an address of PO Box 25250, Colorado Springs, CA 80936. According to her website she charges
41
#:1169
1 $250.00 per hour online. She has a book she sells for $59.95 captioned “Unlocking Justice.” Her site
2 advertises that it can help “save your business a lot of money and bad publicity.” Her resume represents
3 she received a doctorate from King’s International University. There is no accredited Postsecondary
4 institution under that name. A website King’s International University of Science & Technology, LLC
5 which is a company registered in Delaware offers online courses and Karin Huffer appears to be a
6 faculty member there. Karin Huffer has no other “doctoral” education listed on her resume.
7 245. Based on taking Karin Huffer’s course, Defendants Cynthia Brown and Sherry
8 Hernandez have now shown up in the Orange County Superior Court, with badges, under the guise of
9 enforcing ADA compliance. On November 17, 2017 Cynthia Brown wore a badge to court representing
10 she was the representative for Sheri Moody who was testifying in the criminal trial of Defendant George
11 Moody.
12 246. On or about November 20, 2017 Sherry Hernandez appeared with a court badge
13 representing to be Sheri Moody’s court representative under the ADA.
14 247. They were able to get Plaintiff taken out of the courtroom and told to stand at the end of
15 the hall which the other jurors were able to observe. Then Plaintiff was required to sit in the far corner
16 of the courtroom. Plaintiff tried to explain what was going on to the prosecuting assistant district
17 attorneys but either they didn’t understand or they didn’t care. As such, through this false pretense
18 Defendants Brown and Hernandez have found a way to communicate with the witnesses during trial as
19 their representative and condition the testimony and conduct of the court. The reach is beyond the
20 courtroom. Cynthia Brown and Sheri Moody have been able to evade responding to subpoenas using
21 their ADA positions and the techniques that Defendant Karin Huffer gave them on the purported
22 grounds it would trigger their PTSD to do so. Cynthia L. Brown has used the confidentially portion of
23 the ADA to place slanderous statements on the confidential forms concerning Plaintiff and then
24 confidentially file them with the judge – which Plaintiff is prohibited from knowing about or seeing or
25 defending against, because those forms are not meant to be used to assassinate the character of a party
26 to a proceeding. They are confidential because they are only supposed to contain the disability or
27 condition of the petitioner and the type of access they need.
28 248. Cynthia Brown said she is an “American Disability Level II Agent” under “Government
Code 1.100.” She also represented that this not only entitles her to confidential ex parte hearings, and to
42
#:1170
1 represent people in court, but also she is allowed to perform “investigations” because she took this
2 online program from Karin Huffer.
3 249. This is false. In fact, the only authority to ensure compliance with ADA access is the US
4 Department of Justice, civil rights division. Compliance issues are access to courtroom, hearing aids,
5 sign language interpreters for parties, attorneys, and the public who have a material interest in the case.
6 250. This device is being used to prevent plaintiff from getting everything she is entitled to
7 under the law and also is being used as a vehicle to confidentially send judges ex parte communications
8 disparaging plaintiff to the courts.
9 251. Defendant Karin Huffer’s website would be focused on ADA physical access to the court
10 for a person and not business reputation, as the purpose for obtaining the training.
11 252. Finally, with court looking badges, every time Plaintiff walks into the courthouse,
12 Plaintiff has to wonder what access Defendants may be able to gain in the court since this group of
13 Defendants were recently making a series of online communications in 2015 to hold a common law
14 grand jury against the judges and plaintiff.
15 253. As a direct and proximate result of this scheme, Plaintiff was injured in her business and
16 property.
17 The False Complaint Project
18 254. Plaintiff learned that Defendants Cynthia L. Brown, Anthony T. Williams, George Olivo,
19 Billie Rene Powers, Pam Ragland, William Wagener and others were involved in taping a series of TV
20 and video shows On Second Thought. On or about February 14, 2014, one of the videos called for
21 action against Plaintiff’s colleague and friend former California Department of Justice Deputy Attorney
22 General Leslie Westmoreland. The group called themselves the “Cal 18.” One member, Kimi
23 VanDyke, has since been indicted on multiple charges of the document schemes she employed in
24 another County in California. Like CLOA this group, led by Billie Rene Powers, incorporated sovereign
25 citizen tactics with homeowner foreclosure rescue scams.
26 255. Plaintiff not knowing at the time about Cynthia L. Brown or George Olivo’s leanings,
27 informed them about the videos. Rene Powers found out and tried to implicate Plaintiff in the death of
28 her personal assistant’s fiancé which had occurred in October 2013 by so implying by email to her
colleague Leslie Westmoreland on or about August 29, 2014. Plaintiff is informed and believes and
43
#:1171
1 alleges thereon that false criminal complaints were filed by Defendant Billie Rene Powers and State Bar
2 complainant Jodi Sisson with the Orange County Sheriff’s Department and Los Angeles Superior Court.
3 256. Defendants enacted a broad scheme to confuse the public and divert clients and potential
4 clients away from Plaintiff. As a part of that scheme to defraud, Defendants contacted Plaintiff’s current
5 clients, used the files Norma White stole from the office and contacted former clients as well as
6 opposing counsel and their clients. For example, On or about August 30, 2014 Defendant Cynthia L.
7 Brown called Norman Koshak and asked him to call Defendant George Olivo. On or about August 30,
8 2014, Norman Koshak, a current client of Plaintiff, called George Olivo. During that phone call George
9 Olivo told Norman Koshak to get another attorney because they would not stop attacking her. George
10 Olivo told Norman Koshak that Plaintiff lied to Norman Koshak about his case. On or about April 7,
11 2015 Plaintiff’s current client Steve Ballard affirmed that he was also contacted by the “tin hats” as he
12 referred to them and threatened that he would change sides if Plaintiff pressed for payment from him.
13 On or about September 27, 2014 Jennifer Needs, Esq. counsel for Edward Corey Rhodes, Mark
14 Sandford, 10675 S Orange Park Blvd, LLC, Gary A. Schneider and Francis B. Lantieri admitted she
15 also had received an email communication form Defendant Maegan Donovan Nikolic. A former
16 employee also contacted Plaintiff in 2014 and confirmed he started to receive phone calls from former
17 clients when he worked there representing that the office called them to inform them that Plaintiff had
18 botched their case. Even former client David Lovell received several voice mail messages from
19 opposing counsel, Mitchell Hannah telling him to fire Plaintiff and drop his appeal and sue Plaintiff
20 instead for legal malpractice. That occurred in or about March 26, 2014. Some clients filed State Bar
21 complaints. Some clients refused to pay Plaintiff or demanded money from Plaintiff. One client even
22 was so bold as to actually sue Plaintiff for legal practice and drug her through the court system for over
23 a year.
24 NORMAN KOSHAK: I need the future. My business is getting it to
trial and winning at trial. And I need Lenore to do that and I need her
25
on her toes. And I don’t need the restraints that the other people are
26 putting on her. She can’t defend me and defend herself against
anybody else at the same time.
27
GEORGE OLIVO: Okay, if you talk to another attorney you’ll find
28 that there is no way that you can win at trial.
NORMAN: Well
GEORGE: You’re not going to win. There’s not, there’s not a chance
in hell your house is gone.
44
#:1172
1 …
2 NORMAN KOSHAK: Just tell them to leave her alone. That is what
Norman Koshak would like them to do. If they respect me and they
3
feel sorry for me, just let them to do it what I asked them to do. Leave
4 her alone for a while.
GEORGE OLIVO: I would suggest you get another attorney because
5
we’re not going to leave her alone.
6
[Labor Day weekend 2014]
7
ZOEY NIKOLIC: Yes ma’am, hello, hi again, this is Zoey Nikolic the
8 ex-husband of Megan Nikolic and I needed to talk to you about some
business.
9
Um I was hoping -- can you please give me a call when you get a
10 chance I have some interesting information that might interest you.
I know for a fact that you have been followed and I got this from her
11
phone and I have some information that you might want to know and I
12 need some help from you so give me a call, [phone number] Thank
you, bye.”
13
[Voicemail left for Plaintiff on 3/06/2016]
14
257. This RICO activity directly and proximately caused injury to Plaintiff’s business because
15
her business lost clients and revenue as a result. As a further direct and proximate result, Plaintiff was
16
inundated with false State Bar complaints, civil harassment lawsuits, tax reporting, FTB reporting, and
17
the like causing more injury to her business and property because it cost a lot of money to defend the
18
barrage of accusations. As a further direct and proximate result Defendants RICO activity also caused
19
injury to Plaintiff’s business or property because they interfered with her business relationships with her
20
clients, with the courts that they would pop up and appear at, with giving information to the opposing
21
counsel and assisting the opposing side, by calling Plaintiff’s creditors to try to take property away from
22
Plaintiff and stealing keys, a laptop and filed from the office. Plaintiff also had to change the locks and
23
install security equipment at her home and office, too.
24
258. In retaliation, on or about May 9, 2014 Defendants Pam Ragland, Maegan Donovan
25
Nikolic and others such as Karen Rozier and Sheryll Alexander were calling for disbarment.
26
259. After Plaintiff obtained a civil harassment order and workplace violence order against
27
George Olivo for attempted assault of Plaintiff at her workplace on July 11, 2014, Defendants Sherry
28
Hernandez, Sheri Moody, George Olivo, Pam Ragland, Cynthia L. Brown, Monica Jones, David Seal,
Devin Lucas and others retaliated calling for complaints, too:
260. State Bar Complaints, not including all that were dismissed or at inquiry stage:
45
#:1173
1 ///
2 Date Person Number
3 7/28/14 Sherry Hernandez 14-O-04391
4 8/15/14 Marvin Baldwin 14-22630
5 9/16/14 Soledad Corona 14-O-05533
6 9/16/14 Cynthia L. Brown 14-O-05534
7 10/27/14 Billie Rene Powers 14-26084
8 11/5/14 David Seal, Esq. 14-29349
9 12/30/14 David Seal, Esq. 14-O-06222
10 2/20/15 Jodi Sisson 15-O-1131
11 3/26/15 Devin Lucas, Esq. 15-O-11810
12 3/26/15 Phil Green, Esq. 15-O-11708
13 5/04/15 State Bar 15-O-12260
14
6/09/15 State Bar 15-O-12917
15
6/29/15 Catarina Francisco 15-O-13331
16
1/27/16 Devin Lucas, Esq. 16-O-10548
17
2/23/16 Devin Lucas, Esq. 16-O-11310
18
4/18/16 Nira Woods 16-O-12958
19
4/18/16 Christine McCain (paralegal 16-O-12716
20 for Marvin Baldwin)
21 4/18/16 James Wohl, Esq. (attorney 16-O-12686
for Marvin Baldwin – aka
22 Dad is FBI agent in charge)
23 6/20/16 Vikki Hufnagel 16-O-1429
24 3/29/17 Marvin Baldwin 17-O-02039
25 8/18/17 David Bitzer 17-O-05418

26 10/23/17 Susan Uccelli 17-O-06722
27 12/15/17 Bonnie Kent 17-O-11088
28 3/26/18 State Bar 18-O-12945
3/29/18 Greg Diamond, Esq. 18-O-12595
4/2/18 State Bar 18-O-12596
46
#:1174
1 4/3/18 State Bar 18-O-13298

2 4/3/18 State Bar 18-O-13117
3 4/5/18 State Bar 18-O-13049
4 4/24/18 Judge Howard (unauthorized 18-O-13410
5 practice of law when no one
knew there was a suspension)
6 4/25/18 Ruben Escobedo, Esq. for 18-O-13188
7 Orange County Board of
Supervisor, Todd Spitzer
8 6/5/18 Sherry Hernandez 18-O-14181
9
10 261. Plaintiff is informed and believes and alleges thereon that Defendants Maegan Donovan
11 Nikolic, Sheri Moody, George Olivo, Cynthia L. Brown, Norma White, Greg Diamond, Anthony T.
12 Williams solicited Plaintiff’s clients, former clients, employees, former employees, opposing counsel,
13 former opposing counsel, opposing parties, and former opposing parties to create false State Bar
14 complaints and file them against Plaintiff. Plaintiff is further informed and believes and alleges thereon
15 that Defendant Billie Rene Powers had an affidavit she would sell to others which was a claim on an
16 attorney’s “bond” representing that the claimant could get money from the State Bar of California by
17 filing said complaint against Plaintiff.
18 262. Additionally, Plaintiff is informed and believes and alleges thereon Karen Rozier,
19 Soledad Corona, Edward Corey Rhodes, Mark Sandford, and David Seal filed nonsensical civil
20 harassment lawsuits against Plaintiff as a form of harassment.
21 263. Plaintiff is further informed and believes and alleges thereon that Defendants Pam
22 Ragland and David Seal filed false criminal complaints against Plaintiff in or about January 2015, too.
23 264. Defendant Rene Powers had a sovereign citizen type of claim form for requesting bonds
24 against attorneys which was represented as an ability for a homeowner to get a free home or money
25 from the State Bar restitution fund if you were able to get the attorney disbarred. On or about November
26 6, 2014 Plaintiff informed the California State Bar of this scheme because the amount of inquiries (not
27 included in the list above) was shutting down her practice due to the voluminous responses being
28 demanded by the State Bar. However, the State Bar did not listen and was complicit in the Defendants
actions. When Plaintiff learned of the CLOA connection, Plaintiff informed the State Bar and of the
unauthorized practice of law by Defendants Anthony T. Williams and Cynthia L. Brown and their
47
#:1175
1 solicitation of State Bar complaints against Plaintiff on the sovereign citizen website CLOA but the
2 State Bar did not act. On August 11, 2015 Plaintiff informed the State Bar again of the actions of the co-
3 Defendants, with links to the online videos so they could witness the solicitation for unauthorized
4 practice of law by this group of sovereign citizen extremists and their solicitation of others to report
5 Plaintiff to the State Bar. The State Bar Defendants, Caitlin Elen-Morin, State Bar employee, and those
6 acting in the State Bar knew or should have known that their continued pummeling of complaints
7 against Plaintiff was an act of paper terrorism on her and her office, but the State Bar continued to
8 knowingly process the claims, including claims submitted in a list of names that Plaintiff supplied the
9 State Bar in 2014 and thereafter as known to be the sovereign citizen extremists and supporters
10 harassing Plaintiff. By the State Bar of California, Caitlin Elen-Morin, Alex Hackert and Tim Byer
11 continuing in their actions against Plaintiff without legitimate cause, they have taken a step and overt
12 act in furtherance of their co-Defendant’s conspiracy and attempt to defraud.
13 265. This conduct, as alleged above, was in violation of 18 U.S.C. §1343.
14 Recruit, Radicalize & Retaliate Via Video
15 266. Finally, Defendants in furtherance of their scheme made promotional videos. The videos
16 were used to recruit people into using their services, joining their schemes or create Common Law
17 Grand Juries and retaliate against their perceived enemies.
18 267. On or about February 21, 2015 Defendants Cynthia L. Brown, William Wagener,
19 Anthony T. Williams, Billie Rene Powers held a Homeowner seminar in Ventura, California. Defendant
20 George Olivo livestreamed the event on his OC Crew channel over the internet. Defendant Anthony T
21 Williams spoke about the need for people in California to create Common Law Grand Juries and
22 militias in case the local sheriff would refuse to arrest the people demanded by the Common Law Grand
23 Juries to be indicted. He also had a second speaking part which targeted homeowner relief.
24 268. Defendants Anthony T. Williams made other videos with Defendants Cynthia L. Brown,
25 Valerie Lopez and Billie Rene Powers at the Orange County Recorder’s office recording the false
26 Deeds of Trust and Notes and then uploaded them to support the legitimacy of their “program.”
27 269. Plaintiff tried to tip off law enforcement about the Ventura seminar because there is a
28 closed portion with a power point presentation wherein the solicitation of money, Plaintiff is informed
and believes occurs.
48
#:1176
1 270. Other videos were produced by Defendants to harm Plaintiff and her business by inciting
2 other viewers. For example, Defendant William Wagener aired on more than occasion an interview with
3 George Olivo in or about April 21, 2015 calling out for a Common Law Grand Jury against Plaintiff
4 because George Olivo represented himself to be a person competent to determine the legal work going
5 on at her office when she briefly employed him and that she was hurting homeowners and other
6 untruthful representations. Defendants Cynthia Brown and Rene Powers were also on his show about
7 how Cynthia Brown’s attorneys allegedly failed her. There were common criticisms about Cal. DAG
8 Leslie Westmoreland sprinkled in there from time to time, too. The videos are on the internet for the
9 public to see. As a result, the danger is not that one of the named Defendants who participated in the
10 video, but that unknown viewer who may watch the video and believe it is their duty to follow through
11 with a Common Law Grand Jury against Plaintiff and retaliate believing holding her for treason would
12 be their civic duty. As such, these videos create a high degree of risk to the health, welfare and safety of
13 Plaintiff which is directly and proximately caused by the Defendants.
14 271. Defendant William Wagener made another video on December 15, 2015 calling for a
15 common law grand jury against Plaintiff on the purported grounds she screwed up the Koshak case.
16 (Discovery and investigation is continuing but there is something about that house where a substantial
17 portion of the fraud and schemes keep coming back to.) Plaintiff is informed and believes and alleges
18 thereon that these online videos are dangerous because one never knows the predisposition of that
19 random stranger who may watch them and decide they were ‘chosen’ to take Plaintiff out. The videos
20 are on the internet for the public to see. As a result, the danger is not that one of the named Defendants
21 who participated in the video, but that unknown viewer who may watch the video and believe it is their
22 duty to follow through with a Common Law Grand Jury against Plaintiff and retaliate believing holding
23 her for treason would be their civic duty. As such, these videos create a high degree of risk to the health,
24 welfare and safety of Plaintiff which is directly and proximately caused by the Defendants.
25 272. Yet other videos were made for and to intimidate and threaten Plaintiff. For example, on
26 or about July 12, 2014 George Olivo made a live stream video viewed by others representing he was
27 going to hold Plaintiff “accountable” to the “people” while erratically driving around in the
28 neighborhood.
49
#:1177
1 273. Plaintiff is informed and believes and alleges thereon that each type of these videos
2 assisted the Defendants in their scheme to defraud and this conduct as alleged above, in violation of
3 Title 18, United States Code, Section 1343.
4 THIRD PREDICATE ACT (Unauthorized Computer Access 18 U.S.C. §1030)
7 275. On or about April 18, 2014 Norma White took Plaintiff’s workplace laptop with files on
8 it in excess of authorization and refused to return it. Plaintiff is informed and believes and alleges
9 thereon that Maegan Donovan Nikolic, Norma White, George Olivo and others accessed the
10 information on the laptop without Plaintiff’s authorization to do so in violation of 18 U.S.C. §1030.
11 276. Thereafter, Plaintiff would receive random malware and virus attacks. Her computer
12 keys would randomly stop typing correctly. Sometimes files or emails would disappear. Plaintiff had an
13 online calendar and invoice system and calendared items would randomly disappear. On or about April
14 16, 2015 the online program, which was password protected by Plaintiff, showed every single former
15 client accessing the program at the same exact time, when in fact none of those former clients accessed
16 the program. Plaintiff is informed and believes and alleges thereon that Maegan Donovan Nikolic,
17 Karen Rozier, George Olivo and/or Norma White accessed or caused others to access Plaintiff’s online
18 password protected emails, programs or computers without her authorization in violation of 18 U.S.C.
19 §1030.
20 277. As a direct and proximate result of the unauthorized access, Plaintiff’s business and
21 property was harmed. She had to repeatedly invest in new computers, new software, new antivirus, new
22 VPNs, pay for staff to recreate lost calendars, lost work product and the like.
23 FOURTH PREDICATE ACT (Retaliation 18 USC §1513(e) and (f))
24 Anthony T. Williams, Billie Rene Powers, Cynthia L. Brown, CLOA, Valerie Lopez
27 279. On or about January 21, 2015, in the State of California, Anthony Troy Williams,
28 Common Law Office of America, Valerie Lopez, Cynthia L. Brown, and Billie Rene Powers
unlawfully, feloniously, and knowingly, as retaliation or retribution against Mary Fingal Schulte, a
judge who has served or is serving in a legal matter assigned to the judge involving the Defendant
50
#:1178
1 Cynthia L. Brown or a person on whose behalf the Defendant is acting made a credible threat or
2 committed an act of harm or injury upon a person or property against or upon Mary Fingal Schulte; in
3 violation of law. Cynthia L. Brown was a former client of Plaintiff when the threat was made.
4 Anthony T. Williams and Sheri Moody
5 280. On or about February 17, 2015, in the State of Florida, Anthony Troy Williams,
6 Common Law Office of America, and Sheri Moody unlawfully, feloniously, and knowingly, as
7 retaliation or retribution against judge Butchko who has served or is serving in a legal matter assigned
8 to the judge involving the Defendant Sheri Moody or a person on whose behalf the Defendant is acting
9 made a credible threat or committed an act of harm or injury upon a person or property against or upon
10 judge Butchko; in violation of law. Plaintiff is informed and believes and alleges thereon that the judge
11 Anthony T. Williams was referring to at the February 21, 2015 Ventura, California seminar was most
12 likely judge Butchko. Sheri Moody was a former client of Plaintiff in California, when the threat against
13 a Florida judge was made.
14 281. Defendant Sheri Moody and Anthony T. Williams caused a document containing the
15 following to be filed in the Broward County Florida court system while bringing approximately 6
16 Common Law Grand Jurors with them to court in the Bank of America v Sheri P. Moody matter:
17 COMES NOW Defendant, SHERI P. MOODY, a legal fiction, corporation or legal
person, erroneously mistaken for Respondent/Executor Sheri P. Moody, Petitioner, a
18
sentient living being, submits this Notice of Common Law Grand Jury to notice the court
19 that the grand jurors will be in attendance to ensure the Respondents constitutional rights
are not violated. Any one being observed violating their oath of office or violating
20
Respondents constitutional rights will be indicted by the Common Law Grand Jury
21 impaneled [sic] by the people as it was confirmed in the U .S. Supreme Court ruling,
United States v. Williams, 112 S.Ct. 1735, 504 U .S . 36, 118 L.Ed.2d 352 (1992).
22
23
Cynthia L. Brown, Sherry Hernandez, George Olivo and Sheri Moody
24
282. On or about dates unknown, but believed to be from on or about February 2017 to the
25
present, in the State of California, Defendants Cynthia L. Brown and Sherry Hernandez have
26
represented themselves to the Orange County Superior Court as ADA advocates, coordinators or
27
officers. Sheri Moody, George Olivo and violators David Berkley and Kirsten Walker-Probst actively
28
participated in this scheme in both Plaintiff’s FMC action and George Olivo’s criminal assault action
within the past year. Plaintiff is informed and believes and alleges thereon that Cynthia L. Brown,
Sherry Hernandez, George Olivo and Sheri Moody have used this ADA process unlawfully,
51
#:1179
1 feloniously, and knowingly, as retaliation or retribution against judges who has served or is serving in a
2 legal matter assigned to the judge involving the Defendant Sheri Moody, Cynthia L. Brown, George
3 Olivo and Lenore Albert or a person on whose behalf the Defendant is acting made a credible threat or
4 committed an act of harm or injury upon a person or property against or upon judge; in violation of law.
5 George Olivo, Sheri Moody, Pam Ragland, Maegan Donovan Nikolic, Sherry Hernandez,
6 Monica Jones, Greg Diamond, Billie Rene Powers, William Wagener, Joanne Kennedy
7 283. On or about July 14, 2014 through the present, in the State of California, George Olivo,
8 Sheri Moody, Cynthia L. Brown, Sherry Hernandez, Monica Jones, Pam Ragland, Greg Diamond,
9 Billie Rene Powers, William Wagener, and Joanne Kennedy unlawfully, feloniously, and knowingly, as
10 retaliation or retribution against Plaintiff, who after receiving a Workplace Violence Order/Civil
11 Harassment Order involving the Defendant George Olivo or a person on whose behalf the Defendant is
12 acting made a credible threat or committed an act of harm or injury upon a person or property against or
13 upon Plaintiff in violation of law as alleged above.
14 Karen Rozier and David Seal
15 284. Additionally, during the Grand Theft Project violator Karen Rozier (who represented on
16 William Wagener’s show as supposed to being this “Nation’s Chief Engineer for Air and Ground
17 Missles”) joined in by sending Plaintiff repetitive ‘go kill yourself’ emails while the enterprise was
18 sending her Notice to Appear in court emails. David Seal sent her poems about a bird getting stuck in a
19 tree and bleeding to death and representing she was the bird. This was after Karen Rozier and Maegan
20 Nikolic communicated threats to Plaintiff that they had revealed the make, model and VIN number of
21 her vehicle and told men with guns that she hurts little children to shoot on sight. Each time Plaintiff
22 tried to report something such as the threat against judge Schulte, the enterprise retaliated.
23 285. Evidence was then developed that when the Plaintiff did not respond to the earlier filings
24 additional State Bar filings were occurring in an escalating manner with not only Defendants but
25 opposing counsel and their clients. While the State Bar was demanding answers, the Defendants
26 continued with their threats now occurring in January/February 2015 included language that there were
27 men with “guns” who would “shoot” if they saw Plaintiff driving down the street and the State Bar was
28 threatening that failure by Plaintiff not to timely answer could result in a charge of misconduct or a
subpoena and their cases then being turned over for prosecution.
52
#:1180
1 286. On January 20, 2015, violator David Seal filed a false "Criminal Complaint" against
2 Plaintiff with the Huntington Beach police department, the city Plaintiff’s business was located, falsely
3 accusing Plaintiff of sending threats. He said that although the emails were only defamatory that he was
4 “afraid” because Plaintiff had friends who were “former convicts” making plaintiff appear to be the
5 dangerous person while Defendants were actually making a call out for a Common Law Grand Jury.
6 This complaint included language that the Plaintiff is now the accused person who has committed
7 offenses and should be arrested. Contemporaneous with David Seal’s criminal complaint was a TRO he
8 filed on or about March 18, 2015 disarming Plaintiff just prior to their ambush when they were in court
9 together on April 6, 2015 during the “Grand Theft Project.”
10 George Olivo, Pam Ragland, California State Bar, Sherry Hernandez, Greg Diamond, Maegan
11 Donovan Nikolic, and Nira Woods
12 287. Pam Ragland also represented that she filed a false criminal complaint against Plaintiff
13 with the Orange County Sheriff’s office and Nira Woods said she filed a criminal complaint against
14 Plaintiff in Torrance, California as well.
15 288. George Olivo was audio taped where he stated that the enterprise’s goal was to bury or
16 destroy Plaintiff, Lenore Albert and that they would destroy anyone in their way.
17 289. The Defendants did not have to put liens on Plaintiff’s property, they were able to use the
18 tactics with the State Bar to effectively put a lien on her license, thus preventing her from making any
19 income at all.
20 290. The enterprise Defendants had the State Bar do the dirty work for them of paper
21 terrorism. The most recent State Bar complaint filings were from Sherry Hernandez again in or about
22 June 2018. The first time she filed against Plaintiff was in or about July 2014. The State Bar has already
23 assigned a complaint number to the June 2018 allegations which were mainly a rehash of everything
24 they complained about in 2014 with the added complaint that Plaintiff responded to a defamatory post
25 Defendant Sherry Hernandez made on Yelp about Plaintiff. In or about October 2014 when Ms. Albert
26 temporarily lost her TRO against Defendant George Olivo, Defendant Sherry Hernandez responded by
27 posting a “crows pie” after Hernandez falsely testified against Plaintiff and implied that this is what
28 Plaintiff deserved for getting an order against her employee.
291. The false allegations made in the complaints were also made online in false Yelp
reviews, Rip Off report reviews, Maegan Donovan Nikolic created a State Bar webpage and plastered
53
#:1181
1 horrible things about Plaintiff on it while the State Bar was complicit in its creation. Plaintiff is
2 informed and believes and alleges thereon that the State Bar took complaints of Maegan Donovan
3 Nikolic who was never a client of Plaintiff’s and then added them other complaints or referred to them
4 as State Bar investigations, without questioning Maegan Donovan Nikolic’s motive. Blog articles like
5 those of Defendant Greg Diamond and Vern Nelson, and in emails distributed to third parties also added
6 to creating an impact of harm to Plaintiff based on retaliation because she sought an order to protect
7 herself from George Olivo who tried to physically assault her, extort her, blackmail her and threatened
8 to have her dog kidnapped and killed.
9 292. However, the greatest concern was the enterprise's constant accusations of Plaintiff
10 committing serious felonious crimes and soliciting Common Law Grand Juries as recourse to the call of
11 the general public online, not knowing who may view it and take action on it to the adverse health and
12 safety of Plaintiff.
13 FIFTH PREDICATE ACT (Impersonation of Federal Officer 18 U.S.C. §912)
14 Anthony T. Williams, Cynthia L. Brown, Sherry Hernandez, Karin Huffer, and Paul Murray
17 294. On or about November 2014 through 2016, violator Paul Murray unlawfully,
18 feloniously, and knowingly assumed a false or fictitious identity or capacity, legal or other, namely: U.S
19 Marshall, and in such identity or capacity performed an act with intent to unlawfully gain a benefit for
20 himself or another or to injure or defraud another; in violation of law (to carry out their scheme
21 described above).
22 295. Defendant, Anthony Troy Williams, a person not licensed or otherwise authorized to
23 practice law in the state of California held himself out to the public as qualified to practice law in this
24 state, or willfully pretended to be, or willfully took a title, addition, or description implying that he is
25 qualified or recognized by law as qualified, to practice law in this state, as a Private Attorney General
26 (“PAG”) in violation of the California Business & Professions Code and his impersonation violated 18
27 USC §912. Alternatively, On or about November 2014 to date unknown but at least for several years, in
28 the State of California and other states, Anthony T. Williams unlawfully, feloniously, and knowingly
assumed a false or fictitious identity or capacity, legal or other, namely: Private Attorney General, and
54
#:1182
1 in such identity or capacity performed an act with intent to unlawfully gain a benefit for himself or
2 another or to injure or defraud another; in violation of law (to carry out their scheme described above).
3 296. Defendant, Cynthia Louise Brown, a person not licensed or otherwise authorized to
4 practice law in the state of California held herself out to the public as qualified to practice law in this
5 state, or willfully pretended to be, or willfully took a title, addition, or description implying that he is
6 qualified or recognized by law as qualified, to practice law in this state, as a Private Attorney General
7 (“PAG”) in violation of the California Business & Professions Code and her impersonation violated 18
8 USC §912. Alternatively, On or about November 2014 to date unknown but at least for several years, in
9 the State of California and other states, Cynthia L. Brown unlawfully, feloniously, and knowingly
10 assumed a false or fictitious identity or capacity, legal or other, namely: Private Attorney General, and
11 in such identity or capacity performed an act with intent to unlawfully gain a benefit for himself or
12 another or to injure or defraud another; in violation of law (to carry out their scheme described above).
13 297. Both Defendants Anthony Troy Williams and Cynthia Louise Brown falsely
14 impersonated federal officers, to wit Attorney Generals when they represented that they were Private
15 Attorney Generals with the Common Law Office of America in California and with United States
16 Office of the Private Attorney General located in Little Rock, Arkansas which Plaintiff is informed and
17 believes and alleges thereon that violator Eric Stanberry oversaw.
18 298. After Anthony Troy Williams was incarcerated, Defendant Cynthia Brown continued to
19 work in the court system by gaining access with the title of ADA Coordinator or “American
20 Disabilities, Level II certified Agency member” or “Disabilities Level II Agent” under “Government
21 Code 1.100” representing she oversaw the Orange County Superior Court system for ADA compliance.
22 However, that responsibility is for the United States Department of Justice, Civil Rights Division. In
23 fact, Cynthia Brown did not work for the United States Department of Justice, Civil Rights Division and
24 her impersonation violated 18 USC §912.
25 299. Plaintiff is informed and believes and alleges thereon that Defendant Sherry Hernandez
26 joined Cynthia Louise Brown and started to work in the court system in or about February 2017 to the
27 present by gaining access with the title of ADA Coordinator or “American Disabilities, Level II
28 certified Agency member” or “Disabilities Level II Agent” under “Government Code 1.100” in the
Orange County Superior Court system for ADA compliance, too. However, that responsibility is for the
United States Department of Justice, Civil Rights Division. In fact, Sherry Hernandez did not work for
55
#:1183
1 the United States Department of Justice, Civil Rights Division and her impersonation violated 18 USC
2 §912.
3 300. Plaintiff is informed and believes and alleges thereon that Defendant Karin Huffer aided
4 and abetted Cynthia L. Brown, giving her the ability to falsely impersonate a real attorney that has the
5 actual authority of the USDOJ to enforce ADA compliance through the civil rights division for court
6 access.
7 SIXTH PREDICATE ACT (Impersonation of Consulate 18 U.S.C. §915)
8 Anthony T. Williams and Valerie Lopez
11 302. Defendants Valerie Lopez and Anthony T. Williams also falsely represented they were
12 ambassadors or consulates in violation of 18 USC §915, making them immune from the jurisdiction of
13 the courts, or tickets and Plaintiff is informed and believes and alleges thereon that in the past 10 years
14 Defendants Valerie Lopez and Cynthia Louise Brown held seminars that they charged people
15 approximately $325.00 to teach these fraudulent tactics about “jurisdiction” to people in debt.
16 SEVENTH PREDICATE ACT (Embezzlement Cal Penal Code §503)
17 Norma White
20 304. On or about April 18, 2014, violator Norma White fraudulently appropriated Plaintiff’s
21 laptop computer, office files, office keys, office building access card, vehicle keys, vehicle fob, which
22 was property entrusted to her as an employee of Plaintiff’s law office.
23 305. Plaintiff is informed and believes and alleges thereon it was employee sabotage and
24 Norma White conspired, aided and abetted the co-Defendants in their scheme based on some ill-
25 conceived act of revenge.
26 EIGHTH PREDICATE ACT (Extortion Cal Penal Code §518)
27 Steve Ballard and Catherine Olsen
in paragraphs 1 through 305, as if fully set forth herein.
56
#:1184
1 307. On or about April 11, 2015 through to the present, in the State of California Defendant,
2 Steve Ballard and Catherine Olsen unlawfully, feloniously, and with the intent to induce Plaintiff
3 against her will to perform and act or to refrain from performing a lawful act, made a substantial threat
4 to confine or restrain, cause economic hardship to, cause bodily injury to, damage the property of, or
5 damage the reputation of Plaintiff and the Defendants threatened to cause these results by performing an
6 unlawful act or causing an unlawful act to be performed in violation of law by refusing to pay for legal
7 services rendered and asserting if she withdrew for his nonpayment he would join the ‘tin hats’ which
8 they did join and then filed false documents disparaging her with the court and filed a false Yelp review.
9 George Olivo and Norma White
10 308. On or about July 11, 2014, in the State of California Defendant, George Olivo
11 unlawfully, feloniously, and with the intent to induce Plaintiff against her will to perform and act or to
12 refrain from performing a lawful act, made a substantial threat to confine or restrain, cause economic
13 hardship to, cause bodily injury to, damage the property of, or damage the reputation of Plaintiff and the
14 Defendants threatened to cause these results by performing an unlawful act or causing an unlawful act
15 to be performed in violation of law by falsely accusing her of withholding his paycheck to cover up his
16 assault against her. He also threatened to the kidnapping of her dog and said “skid burn” implying he
17 would kill the dog, he would “catch her on the flipside” and other such statements to extort Plaintiff.
18 309. Norma White on May 23, 2014 did a similar stunt telling the HBPD that she only took
19 the keys because she wasn’t paid a paycheck which was false. However, Plaintiff wanted the laptop and
20 keys back, so Plaintiff did write out a check over $1,000.00 as demanded and brought it to Norma
21 White’s home to deliver to her, but Norma White refused to answer the door to take it. So the HBPD
22 detective deleted the laptop as an item that was stolen and reduced the crime to a misdemeanor, petty
23 theft.
24 Anthony T. Williams, George Olivo and Sheri Moody
25 310. Defendants Sheri Moody and Anthony Troy Williams, did then and there simulate legal
26 process by filing legal documents with the Broward Clerk knowing or having reasons to know the
27 contents of any such documents or proceedings or the basis for any action to be fraudulent in violation
28 of 843.0855(a) of the Florida Statutes and did so with the intent to extort or attempt to extort the judge
into a favorable ruling in her case when they filed the Notice of Common Law Grand Jury with the
court in her case on or about February 17, 2015.
57
#:1185
1 311. Furthermore, Defendants Sheri Moody and Anthony Troy Williams solicited others to be
2 the Common Law Grand jurors and Plaintiff is informed and believes and alleges thereon that
3 approximately six (6) said persons appeared in court for Sheri Moody in Broward County, Florida.
4 312. Defendant George Olivo used this scheme to advertise CLOA and its services on the
5 internet to others.
6 Nira Woods
7 313. On or about April 1, 2016 through to the present, in the State of California Defendant,
8 Nira Woods unlawfully, feloniously, and with the intent to induce Plaintiff against her will to perform
9 and act or to refrain from performing a lawful act, made a substantial threat to confine or restrain, cause
10 economic hardship to, cause bodily injury to, damage the property of, or damage the reputation of
11 Plaintiff and the Defendants threatened to cause these results by performing an unlawful act or causing
12 an unlawful act to be performed in violation of law by unlawfully demanding $20,000.00 from Plaintiff
13 with the threat if she didn’t further represent Woods in some type of retaliation she wanted against
14 certain doctors and nurses. Nira Woods then filed a false claim for $20,000.00 from the State Bar when
15 Plaintiff refused.
16 Caitlin Elen-Morin and Devin Lucas
17 314. On or about March 16, 2016, in the State of California Defendant, Caitlin Elen-Morin
18 and Devin Lucas unlawfully, feloniously, and with the intent to induce Plaintiff against her will to
19 perform and act or to refrain from performing a lawful act, made a substantial threat to confine or
20 restrain, cause economic hardship to, cause bodily injury to, damage the property of, or damage the
21 reputation of Plaintiff and the Defendants threatened to cause these results by performing an unlawful
22 act or causing an unlawful act to be performed in violation of law.
23 California State Bar, Alex Hackert, Timothy Byer, and Maricruz Farfan
24 315. On or about December 15, 2015 through to the present, in the State of California
25 Defendant, California State Bar, Alex Hackert, Timothy Byer, and Maricruz Farfan unlawfully,
26 feloniously, and with the intent to induce Plaintiff against her will to perform and act or to refrain from
27 performing a lawful act, made a substantial threat to confine or restrain, cause economic hardship to,
28 cause bodily injury to, damage the property of, or damage the reputation of Plaintiff and the Defendants
threatened to cause these results by performing an unlawful act or causing an unlawful act to be
58
#:1186
1 performed in violation of law, one week after William Wagener’s video came out and one year after
2 Plaintiff filed a civil rights action against the State Bar.
3 NINTH PREDICATE ACT (Forgery Cal Penal Code §470)
4 Anthony T. Williams, Sheri Moody, Valerie Lopez, Billie Rene Powers and Cynthia L. Brown
7 317. On or about the dates as alleged above, in the State of California Defendants, Anthony T.
8 Williams, Sheri Moody, Valerie Lopez, Billie Rene Powers, and Cynthia L. Brown, with the intent to
9 defraud, unlawfully and falsely made, completed, altered, or uttered a written instrument, namely:
10 DEED OF TRUST; in violation of law.
11 TENTH PREDICATE ACT (Recording False Documents Cal Penal Code §115)
12 Anthony T. Williams, CLOA, George Olivo, Sheri Moody, Valerie Lopez, Cynthia L. Brown,
13 Billie Rene Powers
16 319. On or about March 23, 2014 through to the present, in the State of California Anthony
17 Troy Williams, Common Law Office of America, George Olivo, Sheri Moody, Valerie Lopez, Cynthia
18 L. Brown, and Billie Rene Powers, unlawfully, feloniously, and with intent to defraud, presented a Deed
19 of Trust, relating to or affecting real or personal property or directly affecting contractual relationships,
20 to a public office or a public employee, namely: the Orange County Clerk and Recorder, with the
21 knowledge or belief that the written instrument would be registered, filed, or recorded or become a part
22 of the records of that public office or public employee, and knowing that the written instrument
23 contained a material false statement or material false information.
24 Anthony T. Williams, CLOA, Billie Rene Powers, Cynthia Louise Brown, Valerie Lopez, and
25 Sheri Moody
26 320. On or about the dates stated above, Defendants Anthony Troy Williams, CLOA, Rene
27 Powers, Cynthia Louise Brown, Sheri Moody, and Valerie Lopez did then and there file, or direct a filer
28 to file, with the intent to defraud or harass another, an instrument to wit: a lien containing materially
false, fictitious, or fraudulent statements or representations that purport to affect the interest of an
owner, to wit: the first lienholders and/or the third party homeowner who paid for an MEI mortgage
59
#:1187
1 modification foreclosure rescue scam in the property described in the instrument, contrary to California
2 Penal Code §115 in various counties throughout California on the homes of others.
3 ELEVENTH PREDICATE ACT (Grand Theft Cal Penal Code §487)
4 Sheri Moody and Anthony T. Williams
7 322. Defendants Sheri Moody and Anthony Williams did then and there unlawfully and
8 knowingly obtain or endeavor to obtain the property of Bank of America NA to wit: the value of one
9 hundred thousand dollars or more ($100,000.00), with intent to either temporarily or permanently
10 deprive Bank of America NA of the right to the property or a benefit therefrom, or to appropriate the
11 property to his own use or the use of a person not entitled to the use of the property, contrary to Section
12 812.014(2)(a)1, Florida Statutes.
13 Sheri Moody, Anthony T. Williams, CLOA, MEI, Cynthia L. Brown, Valerie Lopez, Rene Powers
14 323. Defendants Sheri Moody, Anthony Williams, CLOA, MEI, Cynthia Louise Brown,
15 Valerie Lopez, and Rene Powers did then and there unlawfully and knowingly obtain or endeavor to
16 obtain the property of the banks located in Orange County, California that had a secured first deed to
17 their home to wit: the value of one hundred thousand dollars or more ($100,000.00), with intent to
18 either temporarily or permanently deprive the first lienholder of the right to the property or a benefit
19 therefrom, or to appropriate the property to his own use or the use of a person not entitled to the use of
20 the property, contrary to Section 487 of the California Penal Code. Plaintiff is informed and believes
21 and alleges thereon that Defendants Rene Powers and Anthony Troy Williams also solicited others in
22 California to do the same in violation of California Penal Code 653(f).
23 Monica Jones, Sheri Moody, Cynthia L. Brown, George Olivo, Pam Ragland, Maegan Donovan
24 Nikolic, Devin Lucas, and David Seal
25 324. On April 6, 2015 Defendants Monica Jones, Sheri Moody, Cynthia L. Brown, George
26 Olivo, Maegan Donovan Nikolic, Pam Ragland and David Seal and Devin Lucas aided and abetted
27 FMC in the grand auto theft of Plaintiff’s vehicle parked in the Orange County Superior Court parking
28 lot with intent to either temporarily or permanently deprive the Plaintiff of the right to the property or a
benefit therefrom, or to appropriate the property to his own use or the use of a person not entitled to the
use of the property, contrary to Section 487 of the California Penal Code.
60
#:1188
1 Norma White
2 325. On or about April 18, 2014 Defendant Norma White stole Plaintiff’s office laptop, office
3 files, vehicle keys, vehicle fob, office keys, and office building pass with intent to either temporarily or
4 permanently deprive the Plaintiff of the right to the property or a benefit therefrom, or to appropriate the
5 property to his own use or the use of a person not entitled to the use of the property, contrary to Section
6 487 of the California Penal Code.
7 Steve Ballard and Catherine Olsen
8 326. On or about April 18, 2015 Defendants Steve Ballard and Catherine Olsen stole legal
9 services with intent to either temporarily or permanently deprive the Plaintiff of the right to the property
10 or a benefit therefrom, or to appropriate the property to his own use or the use of a person not entitled to
11 the use of the property, contrary to Section 487 of the California Penal Code.
12 TWELFTH PREDICATE ACT (Solicitation Cal Penal Code §653(f))
15 328. Defendants, with the intent that the crime be committed, solicits another to offer, accept,
16 or join in the offer or acceptance of a bribe, or to commit or join in the commission of grand theft,
17 receiving stolen property, extortion, perjury, subornation of perjury, forgery, or, by the use of force or a
18 threat of force, to prevent or dissuade any person who is or may become a witness from attending upon,
19 or testifying at, any trial, proceeding, or inquiry authorized by law contrary to Cal Penal Code §653 to
20 wit: Anthony Troy Williams, Cindy Brown, Rene Powers, Sheri Moody and/or Valerie Lopez solicited
21 others at Ventura event and online to create common law grand juries in California, to create militias in
22 California for the purpose of seizing California judges if the sheriff refused to do so and as alleged
23 above, to record fake deeds of trust in California. Second, George Olivo, Maegan Nikolic, Sherry
24 Hernandez, Cindy Brown solicited others to commit extortion against Plaintiff like her former clients,
25 Norman Koshak, Steve Ballard and Catherine Olsen. Third, George Olivo Cindy Brown, Sherry
26 Hernandez, Sheryll Alexander Pam Ragland, Karen Rozier, Maegan Nikolic, Norma White attempted to
27 and/or solicited others to commit perjury, or subornation of perjury in the TRO cases. They used force
28 or threat of force against Plaintiff to try to persuade her or prevent her from becoming a witness to their
harassment in the JPP case by throwing out the go kill me threats et al when she had papers due by
Karen Rozier, Maegan Nikolic, Pam Ragland, David Seal. Defendants Monica Jones, Vern Nelson and
61
#:1189
1 Greg Diamond also falsely “warned” others that Plaintiff associated with ‘criminals’ and that people
2 around her were “afraid” or “terrified” of her, which the listener understood to mean she was dangerous
3 thus thwarting her attempts to be heard. Greg Diamond’s dissemination with his representation and
4 being a reputable attorney that Plaintiff threatened to decapitate counsel or such was meant to reinforce
5 what these others were saying.
6 329. Fourth, Defendants Cynthia L. Brown, Sheri Moody, George Olivo, Sherry Hernandez
7 used a program intended for ADA access to courtrooms as a way to have ex parte confidential hearings,
8 harass and intimidate Plaintiff and cut off her rights, and gain access in a way meant for lawyers.
9 Cynthia L. Brown received this certification and training from Karin Huffer. Plaintiff is informed and
10 believes and alleges thereon Karin Huffer knows how this certification is being abused. These meetings
11 in court have happened on more than one occasion in Plaintiff’s FMC case and once in George Olivo’s
12 assault trial. This also happened in trying to depose Cynthia L. Brown. When the photo of Billie Rene
13 Powers’ email requesting a common law grand jury for judge Schulte came up, Cynthia L. Brown was
14 allowed to end the deposition and not answer the question when Plaintiff was entitled to an answer.
15 330. Fifth, Plaintiff is informed and believes and alleges thereon that Defendants Sherry
16 Hernandez, Maegan Donovan Nikolic, Cynthia L. Brown and Sheri Moody appear to be serial State Bar
17 complaint filers – with some success. Investigation is still ongoing to determine if there is a true pattern
18 of extortion and/or marks here.
19 THIRTEENTH PREDICATE ACT (Conspiracy Cal Penal Code §182)
22 332. Defendants Anthony T. Williams, Sheri Moody, Cynthia L. Brown, Valerie Lopez, Pam
23 Ragland, Monica Jones, Greg Diamond, Vern Nelson, Maegan Donovan Nikolic, George Olivo,
24 William Wagener, Timothy Byer, Alex Hackert, Maricruz Farfan, Caitlin Elen-Morin, Karin Huffer,
25 Joanne Kennedy, Devin Lucas, Norma White, Billie Rene Powers, Sherry Hernandez, Steve Ballard,
26 Catherine Olsen and/or Nira Woods, with the intent to promise or facilitate the commission of the crime
27 of criminal extortion, unlawfully and feloniously agreed with one or more of the above named co-
28 Defendants and a person or persons to the prosecution that crime or an attempt to commit that crime, or
agreed to aid the other person or person in the planning or commission or attempted commission of that
62
#:1190
1 crime, and an overt act in pursuance of the conspiracy was committed by one or more of the
2 conspirators in violation of the law.
3 333. Defendants and each of them agreed with one more co-Defendant to commit at least two
4 of the predicate acts as fully alleged above, which constituted a crime and conspiracy. Defendants
5 Timothy Byer, Caitlin Elen-Morin, Nira Woods, David Seal, Devin Lucas, and Pam Ragland falsely and
6 maliciously attempted to indict Plaintiff for any crime, or to procure Plaintiff to be charged or arrested
7 for any crime. Defendants conspired with David Seal, Karen Rozier, Soledad Corona, Edward Corey
8 Rhodes, and Mark Sandford who falsely moved or maintained a suit, action, or proceeding against
9 Plaintiff to harass her. Defendants conspired with Devin Lucas, Bonnie Kent, Norma White, Nira
10 Woods, George Olivo, Steve Ballard and Catherine Olsen to cheat and defraud Plaintiff of any property,
11 by any means which are in themselves criminal, or to obtain money or property by false pretenses or by
12 false promises with fraudulent intent not to perform those promises. (5) Defendants, and each of them,
13 conspired together to commit an act injurious to the public health, to public morals, or to pervert or
14 obstruct justice, or the due administration of the laws. Defendants Sheri Moody, Anthony T. Williams,
15 Rene Powers, Cynthia Brown, George Olivo and Valerie Lopez conspired to commit a crime against a
16 judge.
17 334. Defendants Steve Ballard and Catherine Olsen threatened to join the enterprise if they
18 were being forced to pay their attorney fee bill. Defendant Nira Woods threatened to file a State Bar
19 complaint if Plaintiff refused to represent her further.
20 335. Instead of filing false liens against Plaintiff, their target, the enterprise was able to get the
21 State Bar to open real investigations and charges against Plaintiff without probable cause.
22 336. Defendants Rene Powers, Cynthia Louise Brown and Anthony Troy Williams, did then
23 and their act as a mortgage broker in the State of California, to-wit: engaged in a course of business
24 relating to the negotiation of a mortgage transaction with various California residents as stated above
25 without a current active mortgage broker’s license issued by the State of California in violation of
26 California’s finance and real estate laws. The other Defendants of the CLOA and Cal18 Enterprises
27 conspired with said Defendants.
28 COUNT 1
VIOLATION OF RICO 18 U.S.C. §1962(c)
63
#:1191
1 337. Plaintiff incorporates in this cause of action all of the allegations in paragraphs 1
2 through 336 as though set forth in full herein.
3 338. As set forth above, Defendants have violated 18 U.S.C. §1962(c) by conducting or
4 participating directly or indirectly in the conduct of the affairs of the Common Law Office of America
5 Enterprise, Occupy Fights Foreclosure Enterprise, Cal 18 Enterprise and/or Equal Access Advocates
6 Enterprise through a pattern of racketeering.
7 339. As a direct and proximate result, Plaintiff has been injured in her business or
8 property by the predicate acts which make up the Defendants’ patterns of racketeering activity.
9 340. The private Defendants’ actions entitle Plaintiffs to actual damages, treble
10 damages, attorney’s fees and costs under 18 U.S.C. §1964. Plaintiff is entitled to injunctive
11 relief against state or local agencies.
12 COUNT II
13 VIOLATION OF RICO 18 U.S.C. §1962(D)
14 CONSPIRING TO VIOLATE 17 U.S.C. §1962 (C)
15 341. Plaintiff incorporates in this cause of action all of the allegations in paragraphs 1 through
16 340 as though set forth in full herein.
17 342. As set forth above, in violation of 18 U.S.C. §1962(d), Defendants have, as set forth
18 above, conspired to violate 18 U.S.C. §1962(c) by conducting, or participating directly or indirectly in
19 the conduct of, the affairs of the four (4) or more Enterprises through a pattern of racketeering.
20 343. As a direct and proximate result, Plaintiff has been injured in her business or property by
21 the predicate acts which make up the Defendants’ patterns of racketeering activity.
22 344. Private Defendants’ actions entitle Plaintiff to actual damages, treble damages, attorney’s
23 fees and costs under 18 U.S.C. §1964. Plaintiff is entitled to injunctive relief against the individuals, and
24 any state and local agencies.
25 SECOND CAUSE OF ACTION
26 42 USC §1983 – RETALIATION AGAINST A BAR MEMBER
27 (Against California State Bar, Maricruz Farfan, Alex Hackert, Timothy Byer, State Bar
28 Employee and Does 4 through 50)
345. Plaintiff incorporates paragraphs 1 through 344, the Eleventh cause of action, and the
Exemplary Damages allegations as though fully incorporated herein.
64
#:1192
1 346. Defendants Alex Hackert, Maricruz Farfan, Caitlin Elen-Morin, and Timothy Byer were,
2 at all times mentioned in this cause of action, acting in the course and scope of his or her employment
3 with the California State Bar.
4 347. Defendants were, at all times mentioned in this cause of action, acting under color of
5 state law.
6 348. Defendants are sued in his or her individual capacity
7 349. Defendants Alex Hackert, Maricruz Farfan, Caitlin Elen-Morin, and Timothy Byer were,
8 at all times mentioned in this cause of action an agent of the State of California, employed with the
9 California State Bar.
10 350. On December 3, 2014 Plaintiff asserted her First Amendment right and filed a complaint
11 against the State Bar and several State Bar employees for violating her constitutional rights (Case No.
12 8:14-cv-01950). On December 11, 2014 she followed that up with an Anti-retaliation letter. On March
13 27, 2015 the case was dismissed.
14 351. After the case was dismissed, Plaintiff got a small group of attorneys together and they
15 were going to try to create a unionized force to protect attorney member’s interests with regard to the
16 State Bar, focusing on consumer attorneys. Plaintiff spoke out about antitrust violations and that the
17 State Bar should be split into two, its fixed cost sheet, and criticized the State Bar spending.
18 352. That following December 15, 2015, the State Bar retaliated against Plaintiff for speaking
19 out by charging her with the thinnest of thread. Those charges were brought in retaliation for Plaintiff
20 speaking out violation of her First Amendment and Fourteenth Amendment rights. The State Bar then
21 placed excessively vague charges that consisted of fabricated allegations against on her webpage even
22 though she was not on probation.
23 353. The State Bar prosecutor failed to prove three out of the four charges, and the one they
24 allegedly proved was based on an older 2012 void order which Plaintiff can always collaterally attack
25 because the motion never had her identified in the notice as a person who could have monetary
26 sanctions brought against her. At any rate, 10675 S Orange Park Blvd, LLC, Francis B. Lantieri and
27 Gary A. Schneider received a proverbial “win” but the court order said a 30 day suspension when
28 “probation” began.
354. Defendant Maricruz Farfan was in charge of probation. Defendant Maricruz Farfan
withheld Plaintiff’s start date of probation from Plaintiff during the entire 30-day period. It was not even
65
#:1193
1 on Plaintiff’s public profile and she received no notice from State Bar. It was not until March 20, 2018
2 that Maricruz Farfan notified Plaintiff that her probation started on February 14, 2018 – over 30 days
3 earlier.
4 355. Plaintiff demanded an explanation from Maricruz Farfan whom merely replied she was
5 not under a duty to tell Plaintiff when her suspension would start.
6 356. Defendants’ false charges, vague order with excessive punishment of suspension,
7 coupled with their filing false reports, hurt Ms. Albert’s reputation in the community and her future job
8 prospects, and taking her license to practice law away knowing she could never pay the large costs that
9 they were going to demand constituted adverse membership actions.
10 357. Defendants Pam Ragland, Maegan Donovan Nikolic, Greg Diamond reveled in the
11 vagueness falsely informing the public of the nature of the charges which they recast as much worse.
12 For example, the recast the sanctions charges as one for hurting her clients, but her clients were not the
13 ones who filed the complaint. Those attorney’s fees were awarded against her clients and payable to the
14 other side. Greg Diamond recast the newest Nira Woods charge as one of forgery.
15 358. After the State Bar took her license away by back dating it, the State Bar opened three
16 investigations against Plaintiff for practicing with a suspended license – knowing they never gave her
17 notice – basically entrapping her.
18 359. Plaintiff then demanded under FOIA, the policies and procedures for the State Bar’s
19 probation department. Initially, the State Bar responded that it was confidential. The State Bar was
20 served with this lawsuit and determined that they would comply under California Records Act.
21 360. Defendants at the State Bar, knowing what Plaintiff was searching for, redacted out the
22 relevant information which was a table or chart showing the probation department how to calculate start
23 dates for suspension.
24 361. Plaintiff immediately requested this information and an explanation why that information
25 was blacked out. The State Bar ignored Plaintiff’s request.
26 362. On March 16, 2018 Defendants Alex Hackert and Timothy Byer were asked about the
27 notice and the back dating and they refused to respond although they both work in the Chief Trial
28 Counsel’s office and on Plaintiff’s case but they did not respond.
363. Plaintiff is informed and believes and alleges thereon that the Defendants brought the
vague charges, recommended her license to practice law be suspended, backdated it to entrap her, and
66
#:1194
1 violated FOIA all in retaliation for her criticism and petition for her grievances about the State Bar in
2 2014, which occurred one year before the State Bar brought any charges.
3 364. Defendants continue to place more negative and fabricated items in Plaintiff’s Bar
4 membership record and on her webpage that consist of fabricated allegations against her. Defendants’
5 false reports, coupled with their attempts to garner more against Plaintiff, hurt Plaintiff’s reputation in
6 the community and her future job prospects.
7 365. Plaintiffs speech and right to petition to voice her concerns was protected speech and the
8 motivating factor behind the State Bar’s actions. There is no provision at the State Bar or State court to
9 seek this type of relief and as such, there is no state action.
10 366. In acting as alleged in this cause of action, Defendants Alex Hackert, Maricruz Farfan,
11 State Bar employee and Timothy Byer violated Plaintiff’s right to free speech and to petition for redress
12 of grievances, guaranteed by the First and Fourteenth Amendments to the United States Constitution.
13 367. As a direct and proximate result of Defendant’s actions, described in this complaint,
14 Plaintiff has suffered injury, loss, and/or damage in that it has so harmed Plaintiff’s reputation in the
15 community, she lost her license, lost her clients, lost her income and harmed her future job prospects
16 and political aspirations.
17 368. In acting as is alleged in this complaint, Defendant acted knowingly, willfully, and
18 maliciously, and with reckless and callous disregard for Plaintiff’s federally protected rights.
19 369. Plaintiff is entitled to injunctive relief.
20 370. Plaintiff is also entitled to compensatory damages, punitive damages, recover her costs
21 of suit, including reasonable attorney’s fees.
22 THIRD CAUSE OF ACTION
23 42 USC §1985 – CONSPIRACY
24 (Against Pam Ragland, Norma White Greg Diamond, Monica Jones, Cynthia Brown, Rene
25 Powers, Maegan Donovan Nikolic, Sherry Hernandez, Joanne Kennedy, and Does 4 through 50)
26 371. Plaintiff incorporates paragraphs 1 through 370 and the Exemplary Damages allegations
27 as though fully incorporated herein.
28 372. On or about March 16, 2018 Defendants Greg Diamond, Pam Ragland, Monica Jones,
Cynthia Brown, Rene Powers, Maegan Donovan Nikolic, Sherry Hernandez, Joanne Kennedy and even
Todd Spitzer, was notified directly or indirectly by the State Bar that Plaintiff was suspended from the
67
#:1195
1 practice of law. However, Plaintiff was not notified by the State Bar until March 20, 2018. In fact when
2 a friend told her that he saw the Defendants posting about her suspension online, Plaintiff immediately
3 contacted the State Bar but they refused to respond.
4 373. Defendants Greg Diamond, Pam Ragland, Monica Jones, Cynthia Brown, Rene Powers,
5 Maegan Donovan Nikolic, Sherry Hernandez, Joanne Kennedy and Norma White conspired with the
6 State Bar Defendants for the purpose of depriving, directly or indirectly, Plaintiff of the equal protection
7 of the laws, or of equal privileges and immunities under the laws
8 374. Defendants Greg Diamond, Pam Ragland, Monica Jones, Cynthia Brown, Rene Powers,
9 Maegan Donovan Nikolic, Sherry Hernandez, Joanne Kennedy did or caused to be done, an act in
10 furtherance of the object of that conspiracy, of creating and/or concealing the back dated suspension
11 date from Plaintiff, depriving Plaintiff of notice, whereby Plaintiff was injured in her person or
12 property, or deprived of having and exercising any right or privilege of a citizen of the United States.
13 375. The acts in furtherance of the conspiracy was creating blog posts, and social media posts
14 on March 16, 2018 by Defendants Greg Diamond, Pam Ragland which were shared by Defendants
15 Monica Jones, Cynthia Brown, Rene Powers, Maegan Donovan Nikolic, Sherry Hernandez, and Joanne
16 Kennedy.
18 Plaintiff has suffered injury, loss, and/or damage to her person and/or her property.
24 FOURTH CAUSE OF ACTION
25 42 USC §1983
26 (Against Defendants State Bar Employee, State Bar of California, Caitlin Elen-Morin, Timothy
27 Byer, Alex Hackert, and Maricruz Farfan)
28 380. Plaintiff incorporates paragraphs 1 through 379, the Eleventh cause of action and the
Exemplary Damages allegations as though fully incorporated herein.
68
#:1196
1 381. Defendant State Bar of California, State Bar Employee, Caitlin Elen-Morin, Alex
2 Hackert, Timothy Byer and Maricruz Farfan were, at all times mentioned in this complaint, acting
3 under color of state law. The individuals were acting in their individual capacity.
4 382. Defendants so named did not give Plaintiff notice that the State Bar suspended her
5 license to practice law on February 14, 2018 and failed to take the notation of suspension off of the
6 State Bar website on or after March 16, 2018 (thirty days later).
7 383. Defendants so named did not treat Plaintiff equally with other licensed attorneys and
8 targeted her each time she ran for election. There is no provision at the State Bar or State court to seek
9 this type of relief and as such, there is no state action.
10 384. After this complaint was filed on June 1, 2018 just days before the election, Defendants
11 took the suspension off Plaintiff’s record and back dated her active status to March 16, 2018 but it was
12 too late for the election cycle. Then a few weeks later, Defendants suspended Plaintiff again, without
13 justification. That is being litigated in the US Bankruptcy court because it is a bankruptcy issue (the
14 reason why they put the suspension back on).
15 385. Plaintiff is informed and believes and thereon alleges that she was subjected to a
16 violation of her right to equal protection and notice and due process under the First and Fourteenth
17 Amendments to the United States Constitution, as a result of the customs, practices, and policies of
18 Defendant State Bar of California.
19 386. Plaintiff is informed and believes and alleges thereon that the State Bar’s customs,
20 practices, and policies of conducting itself above-the-law led to the violation of the Plaintiff's rights.
21 For example, it has on three occasions from 2015 to the present in three different races published
22 derogatory information about Plaintiff as soon as she started her election campaigns.
23 387. The customs, practices, and policies of Defendant State Bar described in this complaint
24 amounted to deliberate indifference to the rights of persons, such as the Plaintiff, who are attorneys.
25 388. As a direct and proximate result of the customs, practices, and policies of Defendant
26 State Bar, described in this complaint, Plaintiff has suffered injury, loss, and damage, including loss of
27 her license, loss of business, emotional distress, pain, and suffering.
Plaintiff has suffered injury, loss, and/or damage to her person and/or her property.
69
#:1197
6 FIFTH CAUSE OF ACTION
7 42 USC §1983
8 Against Defendants State Bar Employee, State Bar of California, Caitlin Elen-Morin, and
9 Timothy Byer
10 393. Plaintiff incorporates paragraphs 1 through 392 and the Exemplary Damages allegations
11 as though fully incorporated herein.
12 394. Defendants State Bar Employee, Caitlin Elen-Morin, and Timothy Byer were, at all
13 times mentioned in this cause of action, acting in the course and scope of his or her employment with
14 the California State Bar.
15 395. Defendants were, at all times mentioned in this cause of action, acting under color of
16 state law.
17 396. Defendants are sued in his or her individual capacity.
18 397. Defendants State Bar Employee, Caitlin Elen-Morin, and Timothy Byer were, at all
19 times mentioned in this cause of action an agent of the State of California, employed with the California
20 State Bar.
21 398. There is no provision at the State Bar or State court to seek this type of relief and as
22 such, there is no state action.
23 399. On or about May 14, 2018 Defendant Caitlin Elen-Morin and Defendant Timothy Byer
24 charged Plaintiff with a crime of moral turpitude, purporting a declaration Plaintiff filed with the State
25 Bar Court and signed under penalty of perjury was false. The charge is to be tried before the State Bar
26 court on or around September 4, 2018.
27 400. On August 20, 2018 Plaintiff requested appointment of counsel and a jury trial.
28 Although such charges could result in Plaintiff’s incarceration and deprivation of liberty, appearing to
be a charge of perjury, the State Bar of California has refused Plaintiff her Sixth Amendment right to
70
#:1198
1 appointment of counsel and has given her notice to testify before the court in violation of her Fifth
2 Amendment right to remain silent (of self-incrimination). Her right to jury trial was denied, too.
3 401. In fact, there is no such provision in the California State Bar Rules of Procedure or Rules
4 of Practice and none is provided under California state law for appointment of counsel or jury trial and
5 there is no provision to seek a writ before a judge like other administrative hearings. However, the
6 perjury charge could result in a material deprivation of incarceration for longer than six months and
7 Plaintiff is already being retaliated against, leaving little doubt there will not be a fair trial in that forum.
8 402. Yet, Defendants refuse to abate action on the charge for criminal investigation or charges
9 to be filed first.
10 403. In acting as alleged in this cause of action, Defendants California State Bar, State Bar
11 employee Caitlin Elen-Morin and Timothy Byer are violating Plaintiff’s right to remain silent, right to
12 counsel, right to jury trial, and to be free from entrapment, or cruel and unusual punishment (seriously –
13 who does this?) guaranteed by the Fifth, Sixth and Eighth Amendments to the United States
14 Constitution.
15 404. Defendant Greg Diamond has told others that he has spoken to the State Bar and the
16 charge is for forgery which has a potential incarceration time of four (4) years. Defendant Timothy Byer
17 has denied that representation that Greg Diamond has spoken to the State Bar.
18 405. As a direct and proximate result of Defendants’ actions, described in this complaint,
19 Plaintiff is suffering an injury, loss, and/or damage to her person or property.
24 of suit, including reasonable attorney’s fees as to Defendants Caitlin Elen-Morin, State Bar Employee
25 and Timothy Byer only.
26 SIXTH CAUSE OF ACTION
27 DEFAMATION
28 Against Greg Diamond, Pam Ragland, Maegan Donovan Nikolic, Joanne Kennedy, Mary Smith,
Vern Nelson and Does 4 - 50
71
#:1199
1 409. Plaintiff incorporates paragraphs 1 through 408 and the Exemplary Damages section as
2 though fully incorporated herein.
3 410. Does 4 through 50 aided and abetted Greg Diamond in the defamation laid out below.
4 411. By way of background, in or about September 2011 Plaintiff received a call to action to
5 ask homeowners facing foreclosure to meet at certain times, dates and places to speak on particular
6 Wall Street issues in Oakland and San Francisco, California. Later, a similar call to action was made for
7 Los Angeles, California. This idea was to give a soapbox to struggling groups of the middle class.
8 Labor unions across the United States assisted in sponsoring this effort. The first direct action took
9 place in New York City. Out of that sprung the “Occupy” movement. It was a planned roll-out over a
10 six-week period.
11 412. Defendants George Olivo, Vern Nelson and Greg Diamond, Esq. created, assisted,
12 participated in and/or took credit for creating, assisting and/or participating in an unplanned action
13 called Occupy Irvine.
14 413. Greg Diamond, Esq. and Vern Nelson reported on some of the group’s activities in a
15 blog at www.Orangejuiceblog.com. Plaintiff is not exactly sure which defendant actually publishes the
16 comments or the articles on the internet so when the pleadings refer to one defendant publishing on the
17 internet, it could mean either Greg Diamond or Vern Nelson whom plaintiff is informed and believes
18 and alleges thereon actually control the comments that are posted as well as the articles that are posted
19 to the website.
20 414. Around this time period, Joe Roberts, Esq. approached Plaintiff and asked if she would
21 partner with him to run a series of 15 USC 1641g putative class actions with him. He had gathered
22 evidence from a database to support an assertion that the lenders were playing hide-and-seek in the US
23 Bankruptcy courts as to the true identity of the creditor when homeowners were being foreclosed upon.
24 415. One of the client’s referred from Joe Roberts’ office was Trang Che.
25 416. Trang Che agreed to try to seek damages relief under a relatively new TILA Statute 15
26 USC 1641(g) called the “Barbara Boxer” amendment. Ms. Albert filed suit on her behalf in a putative
27 class action on or about September 21, 2011.
28 417. Plaintiff was assured by attorney Joe Roberts that Ms. Che was counseled and advised
that this Statute would most likely not stop the foreclosure process or save her from eviction. Mr.
72
#:1200
1 Roberts represented that Ms. Che was likely going to surrender her home because she was not going to
2 fight the UD eviction.
3 418. On or about December 11, 2011 Defendant Vern Nelson published the following story
4 about Trang Che on the Orange Juice Blog:
5 “Trang has certainly been comforted by our ongoing presence, but what we are offering
her – and other homeowners who request our assistance – is support, solidarity,
6
knowledge, expertise. We have lawyers in our ranks – and not just Diamond!”
7 “But we know there are hundreds more of you out there, dozens of Orange County
residents being foreclosed and evicted every day. And if you want our help, you can
8
contact us here. And if we think we can help you, we’ll be there for you.”
9 “We want you to know that, even when our tent village is gone, we Occupy Orange
County more than ever. We want you to know we are your True Militia. We are the Tea
10
Party for Thinking.”
11
419. A reader who knew Plaintiff was representing Trang Che would interpret the story to
12
mean that Plaintiffs was another attorney “in their ranks” or that Trang Che was legally fighting her
13
eviction with Plaintiff’s office which it was understood that was not part of being a class representative.
14
420. Neither Greg Diamond nor anyone from the Occupy Irvine contingent was working on
15
Trang Che’s legal case with Plaintiff and Plaintiff was another attorney “in their ranks.”
16
421. On March 10, 2018 Defendant Greg Diamond published the following to others:
17
“No word yet, as best I can determine, from the California Supreme Court about its
18
accepting or rejecting the official recommendation for Lenore A-S’s suspension from the
19 practice of law, by the way. We will have so, so, so much more about Lenore A-S — and
anyone foolish enough to have made arrangements with her — between now and June!
20
We’ll also publish all of her demand letters to take down items like this — please don’t
21 imagine that they’re confidential, Lenore — although we’ll probably save our public
rebuttals for the anti-SLAPP motion.”
22
“Meanwhile, now that she’s SUCH a public figure, I’d like to hear from anyone who
23 hired Lenore AS to handle problems with their mortgages during the recent crisis —
when I referred poor Occupy Orange County project Trang Che to her based on
24
what I was told was Lenore A-S’s good reputation — by people who later recanted.
25 Note that nothing that Lenore A-S has done would justify anyone trying to take a
paperweight or ashtray or whatever and throw it at her or try to hit her over the head with
26
it — there are other, better, more legal ways to handle any grievances — which will also
27 be discussed.” [emphasis added]
422. Defendant Greg Diamond did not refer Trang Che to Plaintiff’s office for representation
28
and he knew or should have known that when he made the statement. Readers understood the statement
to bolster his prior comments and opinions about her legal work and her State Bar hearings.
73
#:1201
1 423. Readers also understood that the “ashtray” reference was about a July 11, 2014 incident
2 where convicted felon, George Olivo stormed into Plaintiff’s office, picked up a statue and proceeded to
3 try to hit Plaintiff over the head with it. George Olivo in an act of violence did pick up the statue and
4 try to hit Plaintiff over the head with it. Greg Diamond knew or should have known his statement was
5 not true because Plaintiff had previously served him a copy of the TRO she was granted against George
6 Olivo and requested Diamond to stop harassing her on his behalf.
7 424. Plaintiff demanded a retraction from Greg Diamond and Vern Nelson who run the
8 OrangeJuice Blog where the article appeared. In an email to Plaintiff and others, Greg Diamond
9 explained that the “powerful man” he was referring to was current Orange County District Attorney
10 Tony Rackauckus.
11 425. On or about March 10, 2018, Plaintiff demanded Greg Diamond retract his statements
12 because they were untrue and placing her in a false light, but he refused. These statements were libelous
13 on its face because it charged plaintiff with improper and immoral conduct and dishonesty and
14 incompetence in her profession. Alternatively, the statements were libelous on its face because it clearly
15 exposes plaintiff to hatred, contempt, ridicule, and obliquey. This was seen and read from an online
16 article by other people residing in Orange County, California. As a proximate result of the above-
17 described publication, plaintiff has suffered loss of her reputation, shame, mortification and hurt
18 feelings to her general damage. The above publication was published by the defendant with malice,
19 oppression, or fraud in that the circumstances as to what happened because it was Defendant Greg
20 Diamond’s friend, George Olivo who assaulted Plaintiff at her office with the statue. Second, neither
21 Trang Che nor the assault were newsworthy, the former occurred in 2011 and the latter occurred in
22 2014. Defendant was very much aware of the serious harm it could cause. The above described
23 publication was published by Defendant with malice, oppression and/or fraud as alleged in the RICO
24 claim above and the Exemplary damages section below and thus plaintiff seeks an award of punitive
25 damages.
26 426. Then on March 16, 2018 Defendant Vern Nelson published an article announcing
27 Plaintiff was suspended from practicing law.
28 “She made her mark, hurt the most people under the guise of helping them, and got
into the most trouble, during the rash of illegal foreclosures earlier in this decade, when
Occupy got involved. But, despite the nice-charitable-girl image she cultivated, she
almost never worked pro bono, unless there was some great publicity to be gained. Why
is she now running for OC District Attorney.”
74
#:1202
1 [emphasis added]
2
427. Joanne Kennedy aided and abetted Vern Nelson by commenting: “Rip Mrs. Kilgore and
3
Koshak family I hope you get some solace.”
4
428. However, the State Bar did not suspend Plaintiff for her representation of Ms. Kilgore or
5
the Koshak family or for her representation of any of her clients. Defendants Joanne Kennedy and Vern
6
Nelson knew or had reason to know that their statements were false and misleading when they made
7
them. These statements by Defendants Vern Nelson and Joanne Kennedy were libelous on its face
8
because it charged plaintiff with improper and immoral conduct and dishonesty. Alternatively, the
9
statements were libelous on its face because it clearly exposes plaintiff to hatred, contempt, ridicule, and
10
obliquey. This was seen and read from an online article by other people residing in Orange County,
11
California. As a proximate result of the above-described publication plaintiff has suffered loss of her
12
reputation, shame, mortification and hurt feelings to her general damage. The above publication was
13
published by the defendant with malice, oppression, or fraud in that the circumstances as to what
14
happened because the purported suspension was not due to a complaint by the Koshak family or Ms.
15
Kilgore’s family. It had nothing to do with Plaintiff’s clients or her representation of her clients’ cases
16
at all. Both Defendant Nelson and Kennedy knew that fact but intentionally concealed that material fact
17
from the readers and led them to believe a falsity. The death of Ms. Kilgore occurred in 2013 and the
18
Koshak family was evicted from their home in 2013 too, their stories were not hot news. Defendant was
19
very much aware of the serious harm it could cause. In fact, on June 1, 2018 the State Bar admitted it
20
was wrong and that plaintiff was licensed to practice law on the day that Defendant published this
21
article and commented on it. The above described publication was published by Defendant with malice,
22
oppression and/or fraud as alleged in the RICO above and the Exemplary damages section below and
23
thus plaintiff seeks an award of punitive damages.
24
429. Defendants Pam Ragland, Maegan Donovan aka Maegan Nikolic, Greg Diamond aided
25
and abetted Vern Nelson pushed the post up to the first page of Google by making a series of comment
26
on the article.
27
430. Pam Ragland wrote
28
This “attorney” Lenore Albert Sheridan who is no longer entitled to practice in CA — but
is RUNNING FOR DA IN OC — has cost me more than $40K, fighting a false
defamation claim against her. We just won in appeals court. Of course that cost me more
money. When she realized she would have to pay my fee award, Yelp, and Ripoff report
75
#:1203
1 fee awards — she filed for Chapter 13 Bankruptcy just this March, 2018. When she got
her car repossessed by Ford Motor Company, she blamed me and others stating we
2
“broke into her computer” and somehow did something or another to make her car not
3 registered in CA for 3 years (oh sorry, she did not admit that!!) and somehow messed up
her payments. Yet, Ford is moving for Relief from Stay in her Chapter 13 Bankruptcy for
4
the JUDGMENT they have against her for…WAIT FOR IT … not registering a vehicle
5 brought from Nevada into CA for 3 years, among other payment related issues. You need
only read Yelp and Ripoff report to see what her clients think of her. (Oh wait — after
6
being sued the did hide some of those… well clients, feel free to speak up here!!) When
7 the Bar first took action against her, Lenore sued the Bar so she could claim any future
action was retaliation. She lost. They started taking action. Here we are literally YEARS
8
later and the first of multiple actions has FINALLY been taken. So here you have a
9 woman with many unhappy clients, who has cheated the state of CA by not registering
her car, who has cheated Ford by not following their payment rules to the extent they
10
repossessed her unregistered for 3 years vehicle, who filed a defamation lawsuit against
11 people like me speaking out about her and attorneys who had gotten sanctions against her
(and lost), who filed for Bankruptcy and who is suspended by the Bar for misconduct.
12
(Oh, she blamed that on her clients, too. Are you kidding me?)
13 431. Pam Ragland knew the Plaintiff’s bankruptcy was filed on February 20, 2018 which was
14 two weeks before the appellate opinion affirming the SLAPP dismissal was published so she knew her
15 statement inferring that Plaintiff filed for bankruptcy because Pam Ragland was over $40,000.00 in
16 attorneys was false. Second, Pam Ragland filed a claim of $18,000.00 in attorney fees in Plaintiff’s
17 bankruptcy case, so the figure of $40,000.00 is one Pam Ragland knew or should have known was false.
18 Third, FMC has not went to trial yet and FMC moved for relief from stay in the US Bankruptcy court to
19 go to trial. Since FMC moved for relief from stay to try the case, Pam Ragland knew or should have
20 known her statement that they moved for relief on a judgment for not registering her vehicle and related
21 payments was false, also. Pam Ragland continues to tell others that Plaintiff never made a payment or
22 registered her vehicle for threes so it was repossessed, which is false and she knows or should know it
23 was false.
24 432. Due to the facts and circumstances known to the reader(s) of the statement(s), they
25 tended to injure Plaintiff in her occupation or to expose her to hatred, contempt, ridicule, or shame, and
26 to discourage others from associating or dealing with her.
27 433. Pam Ragland failed to use reasonable care to determine the truth or falsity of the
28 statement(s) about the status of the JPP case against her or whether the Koshaks filed a complaint
against Ms. Albert.
76
#:1204
1 434. These statements were false. In fact, Pam Ragland is still a Defendant in the JPP case.
2 The court of appeal did not determine that statements made by Pam Ragland in 2014 were true and Ms.
3 Albert filed for Chapter 13 bankruptcy protection on February 20, 2018 which was before March 6,
4 2018, the dates that the court of appeal opinion. Pam Ragland knew this last statement was absolutely
5 false because she was a creditor listed in the Bankruptcy petition. Ms. Albert was prevented from
6 receiving title from Ford so she could not register her vehicle which Pam Ragland had knowledge of.
7 These statements were libelous on its face because it charged plaintiff with improper and immoral
8 conduct. Alternatively, the statements were libelous on its face because it clearly exposes plaintiff to
9 hatred, contempt, ridicule, and obliquey. This was seen and read from an online article by other people
10 residing in Orange County, California. As a proximate result of the above-described publication,
11 plaintiff has suffered loss of her reputation, shame, mortification and hurt feelings to her general
12 damage. The above publication was published by the defendant with malice, oppression, or fraud in that
13 the circumstances as to what happened to Plaintiff’s car was not hot news because that occurred on
14 April 6, 2015 and this publication occurred three years later, and Defendant was very much aware of the
15 serious harm it could cause. The above described publication was published by Defendant with malice,
16 oppression and/or fraud as alleged in the RICO grand theft claim above and the Exemplary damages
17 section below and thus plaintiff seeks an award of punitive damages.
18 435. Maegan Donovan then took the posting and shared it to a Facebook event set up at Santa
19 Ana college for a candidate debate on the District Attorney race which Ms. Albert was participating in.
20 436. Meagan Donovan followed up with another post or about March 16, 2018 “How does
21 one become a DA without a license – where do I apply! LOL” as a caption to her post she shared. These
22 statements were libelous on its face because it charged plaintiff with improper and immoral conduct.
23 Alternatively, the statements were libelous on its face because it clearly exposes plaintiff to hatred,
24 contempt, ridicule, and obliquey. This was seen and read from an online article by other people residing
25 in Orange County, California. As a proximate result of the above-described publication, plaintiff has
26 suffered loss of her reputation, shame, mortification and hurt feelings to her general damage. The above
27 publication was published by the defendant with malice, oppression, or fraud in that the circumstances
28 as to what happened because it was Defendant Maegan Donovan Nikolic who had been trying to get
Plaintiff disbarred since 2014 although she was never a client of Plaintiff. Considering the day before
Plaintiff’s webpage said she was licensed to practice and then the next day said it was taken over thirty
77
#:1205
1 days deserved serious investigation due to the gravity of the charge, and Defendant was very much
2 aware of the serious harm it could cause. In fact, on June 1, 2018 the State Bar admitted it was wrong
3 and that plaintiff was licensed to practice law on the day that Defendant published this article and
4 commented on it. The above described publication was published by Defendant with malice, oppression
5 and/or fraud as alleged in the RICO grand theft claim above and the Exemplary damages section below
6 and thus plaintiff seeks an award of punitive damages.
7 437. Greg Diamond, Joanne Kennedy, Maegan Donovan Nikolic, Vern Nelson and Pam
8 Ragland did not disclose to the readers that they were working in concert.
9 438. Due to the facts and circumstances known to the reader(s) of the statement(s), they
10 tended to injure Plaintiff in her occupation or to expose her to hatred, contempt, ridicule, or shame, and
11 to discourage others from associating or dealing with her.
12 439. Defendants failed to use reasonable care to determine the truth or falsity of the
13 statement(s). These statements were false.
14 440. Defendant Greg Diamond and/or Vern Nelson has failed and refused to retract or correct
15 the statements made on his blog on March 10, 2018 and Greg Diamond and Vern Nelson failed and
16 refused to retract or correct the statements made on their blog on March 16, 2018. The statements are
17 still out there, widely disbursed in the public due to Greg Diamond and Vern Nelson’s false blog
18 postings of March 10, 2018 and March 16, 2018, and their adoption of statements made by each other
19 and others.
20 441. As a result, Plaintiff suffered harm to her property, business, profession or occupation
21 including money spent as a result of the statements. Plaintiff would have to spend thousands of dollars
22 to hire a social media professional to write the letters to the responsible internet hosts that clean
23 defamatory material off the internet.
24 442. The statements made by Vern Nelson, Greg Diamond and aider/abettors Joann Kennedy,
25 Mary Smith, Maegan Donovan, Pam Ragland and republished by various others were a substantial
26 factor in Plaintiff’s harm.
27 443. In making the statement(s), Greg Diamond, Vern Nelson and aider/abettors Maegan
28 Donovan, Pam Ragland acted with hatred or ill will toward her, showing these particular Defendants
willingness to vex, annoy, or injure her.
78
#:1206
1 444. Finally, Defendants Greg Diamond, Pam Ragland, Monica Jones, Cynthia Brown and
2 possibly others have been telling third parties that plaintiff is a sovereign citizen extremist, pointing the
3 papers Plaintiff has had to file in order to defend herself against their harassment. Although such words
4 are normally considered an nonactionable opinion, combining that with the unfounded falsity that
5 plaintiff is violent when it can be proven that plaintiff does not have a criminal history of violence,
6 combined together is defamatory and/or false light which defendants are intentionally and maliciously
7 doing in order to cast dispersions off of them.
8 445. Plaintiff is informed and believes and alleges thereon Greg Diamond, Vern Nelson and
9 aider/abettors Joann Kennedy, Mary Smith, Maegan Donovan and Pam Ragland are intentionally
10 defaming her in order to make Plaintiff appear not only unelectable as District Attorney, but as someone
11 who was unethical and being held accountable by the State Bar for hurting her own clients who were
12 facing foreclosure when in fact the entire State Bar case was about her clients who were facing
13 foreclosure failed to pay discovery sanctions and the lenders complained to the State Bar that they did
14 not get paid, thus entitling her to punitive damages.
15 446. Alternatively, Greg Diamond who is an attorney, Vern Nelson, and aider/abettors Mary
16 Smith, Joanne Kennedy, Pam Ragland and Maegan Donovan had no reasonable grounds for believing
17 the truth of the statement(s) they made.
19 448. The aforementioned conduct of Defendant(s) was an intentional misrepresentation,
20 deceit, or concealment of a material fact known to the Defendant(s) with the intention on the part of the
21 Defendant(s) of thereby depriving Plaintiff of property or legal rights or otherwise causing injury and
22 was despicable conduct that subjected Plaintiff to a cruel and unjust hardship in conscious disregard of
23 Plaintiff’s rights, so as to justify an award of exemplary and punitive damages.
24
25 SEVENTH CAUSE OF ACTION
26 FALSE LIGHT
27 (Against Defendants Greg Diamond, Vern Nelson, Mary Smith, Pam Ragland, Joann Kennedy,
28 Maegan Donovan Nikolic and Does 4 through 50)
449. Plaintiff incorporates paragraphs 1 through 448 and the Exemplary Damages section as
though fully incorporated herein.
79
#:1207
1 450. In the alternative, if the statements are not defamatory, then they put Plaintiff in a false
2 light. Defendants Greg Diamond, Vern Nelson, Pam Ragland, Joanne Kennedy, and Maegan Donovan
3 Nikolic aka Maegan Nikolic aka Meagan Donovan publicized information or material that showed
4 Plaintiff in a false light. They made it appear that Plaintiff’s clients, the Koshaks had filed the State Bar
5 complaint against Ms. Albert leading to her being disciplined by the State Bar. However, it was the
6 opposing counsel while they were in litigation that filed the complaint. The published statements made
7 the reader believe that Plaintiff was being disciplined for hurting her clients who were homeowners,
8 however that was not the case. It was the opposite. She was being disciplined for purportedly not paying
9 the lenders the homeowners opposed. Defendants, and each of them, knew the publication would create
10 a false impression about Plaintiff or acted with reckless disregard for the truth or Defendants, and each
11 of them, were negligent in determining the truth of the information or whether a false impression would
12 be created by its publication; Plaintiff sustained harm to her property, business, profession, or
13 occupation, including money spent as a result of the statement(s); and Defendants’ conduct was a
14 substantial factor in causing that harm.
15 451. Second Defendant Greg Diamond, Monica Jones, Pam Ragland, and others such as
16 David Seal and Nira Woods made it appear that Plaintiff was violent. As alleged above, the Defendants
17 told others plaintiff was a sovereign citizen extremist to cast dispersions away from their conduct. Greg
18 Diamond had a meme created about decapitation and others were passing it around along with a letter.
19 Monica Jones told FMC that people were terrified of Plaintiff. Nira Woods, Pam Ragland and David
20 Seal filed false police reports against Plaintiff. Nevertheless, on March 17, 2018 Defendant Vern Nelson
21 published the cartoon/meme on the OrangeJuice blog and circulated it which put plaintiff in false light.
22 Defendants publicized the information either by communicating it to the public at large or to so many
23 people that the information or material was substantially certain to become public knowledge.
24 452. The false light created by the publication would be highly offensive to a reasonable
25 person in Plaintiff’s position. Defendants Greg Diamond, Vern Nelson, Mary Smith, Pam Ragland,
26 Joanne Kennedy, and Maegan Donovan knew the publication would create a false impression about
27 Plaintiff or acted with reckless disregard for the truth; or Defendants Greg Diamond, Vern Nelson,
28 Mary Smith, Pam Ragland, Joanne Kennedy, and Maegan Donovan was negligent in determining the
truth of the information or whether a false impression would be created by its publication. As a direct
and proximate result of the false light, Plaintiff was harmed. Plaintiff sustained harm to her property,
80
#:1208
1 business, profession, or occupation, including money spent as a result of the statement(s); and
2 Defendants Greg Diamond, Vern Nelson, Mary Smith, Pam Ragland, Joanne Kennedy, and Maegan
3 Donovan conduct was a substantial factor in causing Plaintiff’s harm.
4 453. Defendants conduct, and each of them caused plaintiff emotional distress.
5 454. Plaintiff is entitled to compensatory damages, general damages, and injunctive relief.
11 EIGHTH CAUSE OF ACTION
12 TORTIOUS INTERFERENCE WITH A PROSPECTIVE ECONOMIC ADVANTAGE
13 (Against Defendants Anthony T. Williams, Cynthia L. Brown, Sheri Moody, George Olivo,
14 Norma White, William Wagener, Monica Jones, Devin Lucas, Sherry Hernandez, Joanne
15 Kennedy, Billie Rene Powers, Greg Diamond, Vern Nelson, Pam Ragland, Joanne Kennedy, and
16 Maegan Donovan Nikolic and Does 4 through 50)
17 456. Plaintiff incorporates in this cause of action all of the allegations in paragraphs 1 through
18 344 and the Exemplary Damages section as though set forth in full herein.
19 457. As outlined in the RICO cause of action, Defendants Anthony T. Williams, Cynthia L.
20 Brown, Sheri Moody, George Olivo, Norma White, William Wagener, Monica Jones, Devin Lucas,
21 Sherry Hernandez, Joanne Kennedy, Billie Rene Powers, Greg Diamond, Vern Nelson, Pam Ragland,
22 Joanne Kennedy, and Maegan Donovan Nikolic knew of Plaintiff’s attorney-client relationships through
23 the stolen files, access to the online calendaring program or the summer classes.
24 458. Defendants Anthony T. Williams, Cynthia L. Brown, Sheri Moody, George Olivo,
25 Norma White, William Wagener, Monica Jones, Devin Lucas, Sherry Hernandez, Joanne Kennedy,
26 Billie Rene Powers, Greg Diamond, Vern Nelson, Pam Ragland, Joanne Kennedy, and Maegan
27 Donovan Nikolic intended to disrupt these relationships or knew that disruptions of this relationship
28 between Plaintiff and her clients or prospective clients was certain to occur.
459. The relationships were disrupted by an independent tort.
81
#:1209
1 460. Plaintiff lost business and profits as a result of the tortious interference by the
2 Defendants.
3 461. Defendants Anthony T. Williams, Cynthia L. Brown, Sheri Moody, George Olivo,
4 Norma White, William Wagener, Monica Jones, Devin Lucas, Sherry Hernandez, Joanne Kennedy,
5 Billie Rene Powers, Greg Diamond, Vern Nelson, Pam Ragland, Joanne Kennedy, and Maegan
6 Donovan Nikolic were a substantial factor in causing that harm.
8 463. Plaintiff is also entitled to recover compensatory damages and punitive damages.
14 NINTH CAUSE OF ACTION
15 UCL §17200 VIOLATION
16 (Against Defendants Citibank, Anthony T. Williams, CLOA, George Olivo, Sheri Moody, Valerie
17 Lopez, Cynthia L. Brown, Sherry Hernandez, Monica Jones, Pam Ragland, Greg Diamond, Billie
18 Rene Powers, William Wagener, Karin Huffer, Mary Smith, Joanne Kennedy, Devin Lucas, Steve
19 Ballard, Catherine Olsen, Nira Woods, Maegan Donovan Nikolic, Vern Nelson, Norma White and
20 Does 4 through 50)
22 through 344 and the 3rd and 6th causes of action and the Exemplary Damages section as though
23 set forth in full herein.
24 466. Defendants have violated Cal Business & Professions Code §17200, et seq., with the
25 conduct as alleged above.
26 467. Each Defendant knew or had reason to know of these facts, and as such are jointly and
27 severally liable.
28 468. Beginning at an exact date unknown to Plaintiffs but at least in the past 4 years,
Defendants Anthony T. Williams, CLOA, George Olivo, Sheri Moody, Valerie Lopez, Cynthia L.
Brown, Sherry Hernandez, Monica Jones, Pam Ragland, Greg Diamond, Billie Rene Powers, William
82
#:1210
1 Wagener, Karin Huffer, Mary Smith, Joanne Kennedy, Devin Lucas, Steve Ballard, Catherine Olsen,
2 Nira Woods, Vern Nelson, Maegan Donovan Nikolic, Norma White and Does 4 through 50 have
3 committed acts of unfair competition, as defined by Business & Professions Code §17200, by engaging
4 in the following practices:
5 469. Defendants Anthony T. Williams, CLOA, Cynthia L. Brown, and Billie Rene Powers,
6 and Does 4 through 50 committed or attempted to commit acts made with the intent to defraud others to
7 the injury of Plaintiff through various schemes as outlined above in violation of 18 U.S.C. §1341 (mail
8 fraud), and consequently, constitutes an unlawful business act or practice within the meaning of
9 Business & Professions Code §17200.
10 470. Defendants Anthony T. Williams, CLOA, George Olivo, Sheri Moody, Valerie Lopez,
12 Powers, William Wagener, Joanne Kennedy, Devin Lucas, Steve Ballard, Citibank, Catherine Olsen,
13 Nira Woods Vern Nelson, Maegan Donovan Nikolic, Norma White and Does 4 through 50 committed
14 or attempted to commit acts made with the intent to defraud others to the injury of Plaintiff through
15 various schemes as outlined above in violation of 18 U.S.C. 1343 (wire fraud), and consequently,
16 constitutes an unlawful business act or practice within the meaning of Business & Professions Code
17 §17200.
19 Cynthia L. Brown, Sherry Hernandez, Monica Jones, Pam Ragland, Greg Diamond, Maegan Donovan
20 Nikolic, Billie Rene Powers, William Wagener, Karin Huffer, Joanne Kennedy, Steve Ballard,
21 Catherine Olsen, Nira Woods and Does 4 through 50 committed or attempted to commit acts made with
22 the intent to defraud others to the injury of Plaintiff through various schemes as outlined above in
23 violation of 18 U.S.C. §1513 (retaliation), and consequently, constitutes an unlawful business act or
24 practice within the meaning of Business & Professions Code §17200.
25 472. Defendant Norma White and Does 4 through 50 committed or attempted to commit acts
26 made with the intent to defraud others to the injury of Plaintiff through various schemes as outlined
27 above in violation of 18 USC §1030 (unauthorized access to a computer), and consequently, constitutes
28 an unlawful business act or practice within the meaning of Business & Professions Code §17200.
473. Defendants Anthony T. Williams, Valerie Lopez, Cynthia L. Brown, Sherry Hernandez,
and Does 4 through 50 committed or attempted to commit acts made with the intent to defraud others to
83
#:1211
1 the injury of Plaintiff through various schemes as outlined above in violation of 18 USC §912
2 (impersonation of a federal officer), and 18 USC §915 (impersonation of an ambassador or consulate)
3 and consequently, constitutes an unlawful business act or practice within the meaning of Business &
4 Professions Code §17200.
5 474. Plaintiff is informed and believes and alleges thereon that Defendants George Olivo,
6 Norma White, Sheri Moody, Cynthia L. Brown, Sherry Hernandez, Pam Ragland, and Does 4 through
7 50 used the information Norma White obtained from embezzlement from Plaintiff’s office and
8 committed or attempted to commit acts made with the intent to defraud others to the injury of Plaintiff
9 through various schemes as outlined above in violation of Cal Penal Code §503 (embezzlement), and
10 consequently, constitutes an unlawful business act or practice within the meaning of Business &
12 475. Defendants Anthony T. Williams, George Olivo, Sheri Moody, Norma White, Devin
13 Lucas, Steve Ballard, Catherine Olsen, Nira Woods and Does 4 through 50 committed or attempted to
14 commit acts made with the intent to defraud others to the injury of Plaintiff through various schemes as
15 outlined above in violation of Cal Penal Code §518 (extortion), and consequently, constitutes an
16 unlawful business act or practice within the meaning of Business & Professions Code §17200.
17 476. Defendants Anthony T. Williams, Sheri Moody, Valerie Lopez, Cynthia L. Brown, Billie
18 Rene Powers, and Does 4 through 50 committed or attempted to commit acts made with the intent to
19 defraud others to the injury of Plaintiff through various schemes as outlined above in violation of Cal
20 Penal Code §470 (forgery) and consequently, constitutes an unlawful business act or practice within the
21 meaning of Business & Professions Code §17200.
23 Cynthia L. Brown, Billie Rene Powers, and Does 4 through 50 committed or attempted to commit acts
24 made with the intent to defraud others to the injury of Plaintiff through various schemes as outlined
25 above in violation of Cal Penal Code §115 (recording false instruments), and consequently, constitutes
26 an unlawful business act or practice within the meaning of Business & Professions Code §17200.
28 Cynthia L. Brown, Monica Jones, Pam Ragland, Billie Rene Powers, Devin Lucas, Steve Ballard,
Catherine Olsen, Nira Woods, Maegan Donovan Nikolic, Norma White and Does 4 through 50
committed or attempted to commit acts made with the intent to defraud others to the injury of Plaintiff
84
#:1212
1 through various schemes as outlined above in violation of Cal Penal Code §487 (grand theft), and
2 consequently, constitutes an unlawful business act or practice within the meaning of Business &
5 Cynthia L. Brown, Monica Jones, Vern Nelson, Meagan Donovan Nikolic, Norma White, Karin Huffer,
6 Pam Ragland, Greg Diamond, Billie Rene Powers, William Wagener, Maegan Donovan Nikolic,
7 Norma White, Vern Nelson and Does 4 through 50 committed or attempted to commit acts made with
8 the intent to defraud others to the injury of Plaintiff through various schemes as outlined above in
9 violation of Cal Penal Code §653(f) (solicitation), and consequently, constitutes an unlawful business
10 act or practice within the meaning of Business & Professions Code §17200.
13 Powers, William Wagener, Karin Huffer, Mary Smith, Joanne Kennedy, Devin Lucas, Steve Ballard,
14 Catherine Olsen, Nira Woods, Norma White, Vern Nelson, Maegan Donovan Nikolic and Does 4
15 through 50 committed or attempted to commit acts made with the intent to defraud others to the injury
16 of Plaintiff through various schemes as outlined above in violation of Cal Penal Code §182
17 (conspiracy), and consequently, constitutes an unlawful business act or practice within the meaning of
18 Business & Professions Code §17200.
19 481. The harm to Plaintiff and to members of the general public outweighs the utility of
20 Defendant’s policy/practice, and consequently, Anthony T. Williams, CLOA, George Olivo, Sheri
21 Moody, Valerie Lopez, Cynthia L. Brown, Sherry Hernandez, Monica Jones, Pam Ragland, Greg
22 Diamond, Billie Rene Powers, William Wagener, Karin Huffer, Mary Smith, Joanne Kennedy, Devin
23 Lucas, Steve Ballard, Catherine Olsen, Nira Woods, Vern Nelson, Norma White, Maegan Donovan
24 Nikolic, and Does 4 through 50 practices constituting the sovereign citizen schemes laid out above
25 which resulted in diverting customers away from Plaintiff and her business and into a fraudulent scheme
26 like this constitutes an unfair business act or practice within the meaning of Business & Professions
27 Code §17200.
28 482. Defendant Anthony T. Williams, CLOA, George Olivo, Sheri Moody, Valerie Lopez,
Cynthia L. Brown, Sherry Hernandez, Monica Jones, Pam Ragland, Greg Diamond, Billie Rene
Powers, William Wagener, Karin Huffer, Mary Smith, Joanne Kennedy, Devin Lucas, Steve Ballard,
85
#:1213
1 Catherine Olsen, Nira Woods, Norma White, Vern Nelson, Maegan Donovan Nikolic and Does 4
2 through 50 policy/practice are also likely to mislead the general public, and consequently, constitutes a
3 fraudulent business act or practice within the meaning of Business & Professions Code §17200.
4 483. The unlawful, unfair, and fraudulent business practices as described above, present a
5 continuing threat to members of the public warranting an injunction, freezing of assets and accounting,
6 as well as restitution.
7 484. As a result of the aforementioned acts, Plaintiff lost money or property and suffered
8 injury in fact as more fully detailed in the complaint above (interference with business, lost profits, lost
9 license, fees and costs incurred due to defending the paper terrorism and trying to protect her license).
10 485. Finally, stopping this practice furthers the public interest. Plaintiff is therefore entitled
11 to reasonable attorney's fees under section 1021.5 of the California Code of Civil Procedure. (Plaintiff
12 intends to have trial lawyers try this case)
13 486. Plaintiff is entitled to restitution and injunctive relief.
14 TENTH CAUSE OF ACTION
15 AIDING AND ABETTING VIOLATION OF §17200
16 (Against Defendants Anthony T. Williams, CLOA, George Olivo, Sheri Moody, Valerie
17 Lopez, Cynthia L. Brown, Sherry Hernandez, Monica Jones, Pam Ragland, Greg
18 Diamond, Billie Rene Powers, William Wagener, Karin Huffer, Mary Smith, Joanne
19 Kennedy, Devin Lucas, Steve Ballard, Catherine Olsen, Nira Woods, Maegan Donovan
20 Nikolic, Karin Huffer, Norma White, Vern Nelson and Does 4 through 50)
22 through 486 as though set forth in full herein.
23 488. Defendants Anthony T. Williams, CLOA, George Olivo, Sheri Moody, Valerie
24 Lopez, Cynthia L. Brown, Sherry Hernandez, Monica Jones, Pam Ragland, Greg Diamond,
25 Billie Rene Powers, William Wagener, Karin Huffer, Mary Smith, Joanne Kennedy, Devin
26 Lucas, Steve Ballard, Catherine Olsen, Nira Woods, Maegan Donovan Nikolic, Norma White,
27 Vern Nelson, Karin Huffer, and each of them including Doe 1 through 50 knew and were aware
28 of their co-Defendants’ unlawful, unfair or deceptive business practices and untrue and
misleading conduct alleged above but continued with the scheme for their own profit.
86
#:1214
1 489. Defendants aided and abetted/induced these violations by their co-Defendants in that
2 they commanded or conducted the conduct. For example, Defendant Anthony Troy Williams placed
3 Plaintiff’s photo on his CLOA Website said she was a scammer and solicited the public to file false
4 reports with the State Bar for his own profit. If anyone crossed him, he would do the same to him.
5 490. As a result of the aforementioned acts, Plaintiff lost money or property and suffered
6 injury in fact as more fully detailed in the complaint above (interference with business, lost profits, lost
7 license, fees and costs incurred due to defending the paper terrorism and trying to protect her license).
8 491. Finally, stopping this practice furthers the public interest. Plaintiff is therefore entitled
9 to reasonable attorney's fees under section 1021.5 of the California Code of Civil Procedure. (Plaintiff
10 intends to have trial lawyers try this case)
11 492. Plaintiff is entitled to restitution and injunctive relief.
12 ELEVENTH CAUSE OF ACTION
13 DECLARATORY RELIEF THAT CALIFORNIA STATUTES ARE
14 UNCONSTITUTIONAL
15 (Against the California State Bar)
16 493. Plaintiff incorporates the allegations of paragraphs 1 through 344 and the 2nd, 4th, and 5th
17 causes of action as though set forth herein.
18 494. A current case and controversy exists between Plaintiff, Lenore Albert and Defendant
19 State Bar of California aka California State Bar.
20 495. Plaintiff has standing to bring this claim because the State Bar has charged plaintiff with
21 a crime of moral turpitude (perjury) under Business & Professions Code §6106 which will be tried on or
22 about September 19, 2018. Although the charge has a potential, if proven referral to the D.A.’s office
23 for prosecution that could result in 3 or 4 year prison term, the State Bar has denied the Plaintiff a right
24 to trial by jury or appointing counsel for her defense. There is no res judicate or collateral estoppel that
25 could prevent a prosecution for perjury because no law enforcement agency has charged her with a
26 crime and the statute of limitations on such charge has not run. Plaintiff also has been effectively denied
27 her right to remain silent under the 5th amendment and the State Bar has used its Notice of Trial in lieu
28 of subpoena power compelling Plaintiff to testify on matters where she is being effectively charged with
the crime of perjury by them. There is no provision in Business & Professions Code §6106 which
prevents the State Bar from compelling a Bar member from testifying without appointment of counsel
87
#:1215
1 or a jury in defense of a charged crime without first referring the matter to be tried by the D.A.
2 first. Consequently, Plaintiff is requesting this court to declare Cal Bus & Prof Code §6106
3 unconstitutional on the grounds it violates the Fourth, Fifth and Sixth Amendment rights of the
4 accused and join the State Bar in their efforts to prosecute Plaintiff under that Code section.
5 496. Plaintiff is also requesting the court declare Cal Bus & Prof Code §6085 which
6 only allows the attorney a right to have counsel but does not have a provision requiring the
7 agency to appoint counsel to an indigent defendant that the State Bar may charge with a crime in
8 their trial court. Plaintiff has been charged with the crime of perjury by the State Bar to be tried
9 on or about September 19, 2018 and is indigent. However, the State Bar has refused to appoint
10 counsel for Plaintiff or transfer venue to a court that can appoint counsel. Plaintiff alleges that
11 this Code section is unconstitutional because Plaintiff has a constitutional right to the
12 appointment of counsel when she is being charged with a crime that could result in a sentence
13 over six months. State Bar is allowed to work in tandem with law enforcement on prosecutions
14 and criminal investigations, yet the accused is not allowed the right to an attorney to be
15 appointed so long as it stays in that forum and the accused has no right to stay the action until
16 there is a criminal conviction or dismissal. Consequently, Plaintiff is requesting this court to
17 declare Cal Bus & Prof Code §6085 unconstitutional on the grounds it violates the Fourth, Fifth
18 and Sixth Amendment rights of the accused and join the State Bar in their efforts to prosecute
19 Plaintiff under that Code section.
20 497. These provisions also violate Plaintiff’s First and Fourteenth Amendment rights
21 because Cal Bus & Prof Code §6106 does allow the State Bar to take away a license to practice
22 law based on a crime of moral turpitude, even if the lawyer has not yet been charged or
23 convicted by any law enforcement agency.
24 498. Wherefore Plaintiff requests declaratory and injunctive relief.
25 499. Plaintiff also requests attorney fees and costs if successful.
26 EXEMPLARY DAMAGES
27 500. Defendants, Anthony T. Williams, CLOA, George Olivo, Sheri Moody, Valerie Lopez,
Powers, William Wagener, Karin Huffer, Mary Smith, Joanne Kennedy, Devin Lucas, Steve Ballard,
Catherine Olsen, Nira Woods, Maegan Donovan Nikolic, Norma White, Vern Nelson and Does 4
88
#:1216
1 through 50 conduct is so vile, base, or contemptible that it would be looked down on and despised by
2 reasonable people.
3 501. Defendants, Anthony T. Williams, CLOA, George Olivo, Sheri Moody, Valerie Lopez,
6 Catherine Olsen, Nira Woods, Maegan Donovan Nikolic, Norma White, Vern Nelson and Does 4
7 through 50 intentionally misrepresented or concealed a material fact as specifically alleged throughout
8 this complaint.
9 502. When plaintiff temporarily hired Defendant Norma White on January 3, 2014 she relied
10 on Norma White’s representation that she needed the job to make some money to help her mother who
11 was diagnosed with cancer. In reliance on that representation, plaintiff hired Norma White and
12 entrusted her with an office laptop, client files, keys to the office, keys and fob to Plaintiff’s vehicle,
13 and an all access pass to the building in addition to her own office space. The reliance was justifiable
14 because Norma White’s mother worked as a courtroom interpreter for the Orange County family law
15 court system. In reliance on that representation plaintiff was harmed because Norma White sabotaged
16 Plaintiff’s business on April 18, 2014 and stole files, papers, the office laptop, client lists, keys to the
17 office, keys and fob to Plaintiff’s vehicle and the all access pass to the office building.
18 503. When plaintiff temporarily hired Defendant George Olivo on or about May 28, 2014
19 she relied on George Olivo’s representation that he needed the job to make some money and could
20 help box up files to take to storage and drive her around and such because Plaintiff had sprained her
21 right hand fingers and fractured her left wrist/arm. In reliance on that representation, plaintiff hired
22 George Olivo and entrusted him with client files to take to storage, keys to the office, keys and fob to
23 Plaintiff’s vehicle. The reliance was justifiable because George Olivo represented his retired mother
24 used to clerk for a judge at the Orange County Superior Court. In reliance on that representation
25 plaintiff was harmed because George Olivo sabotaged Plaintiff’s business, attempted to assault her on
26 July 11, 2014 and then spread lies about the office operations confusing the public and then diverting
27 people away from her business.
28 504. The conduct constituting malice, oppression, or fraud by Defendants, Anthony T.
Williams, CLOA, George Olivo, Sheri Moody, Valerie Lopez, Cynthia L. Brown, Sherry Hernandez,
Monica Jones, Pam Ragland, Greg Diamond, Billie Rene Powers, William Wagener, Karin Huffer,
89
#:1217
1 Mary Smith, Joanne Kennedy, Devin Lucas, Steve Ballard, Catherine Olsen, Nira Woods, Maegan
2 Donovan Nikolic, Norma White, Vern Nelson and Does 4 through 50, was authorized by one or more
3 officers, directors, or managing agents of the California State Bar.
4 505. Alternatively, one or more officers, directors, or managing agents of the California
5 State Bar knew of the conduct constituting malice, oppression, or fraud and adopted or approved that
6 conduct from Defendants, Anthony T. Williams, CLOA, George Olivo, Sheri Moody, Valerie Lopez,
9 Catherine Olsen, Nira Woods, Maegan Donovan Nikolic, Norma White, Vern Nelson and Does 4
10 through 50 after it occurred. They adopted each and every act, including Plaintiff being placed on the
11 CLOA website to solicit State Bar complaints from to Plaintiff being placed on a fake State Bar
12 webpage to be humiliated and ridiculed.
13 506. The aforementioned conduct of Defendants, Maricruz Farfan, Timothy Byer, Alex
14 Hackert, Caitlin Elen-Morin and State Bar Employee, was malicious and/or an intentional
15 misrepresentation, deceit, or concealment of a material fact known to the California State Bar with the
16 intention on the part of the Defendants, Maricruz Farfan, Timothy Byer, Alex Hackert, Caitlin Elen-
17 Morin and State Bar Employee to thereby deprive Plaintiff of property or legal rights or otherwise
18 causing injury, and was despicable conduct that subjected Plaintiff to a cruel and unjust hardship in
19 conscious disregard of Plaintiff’s rights, so as to justify an award of exemplary and punitive damages.
20 507. Defendants, Maricruz Farfan, Timothy Byer, Alex Hackert, Caitlin Elen-Morin and
21 State Bar Employee’s conduct is so vile, base, or contemptible that it would be looked down on and
22 despised by reasonable people.
23 508. Defendants, Maricruz Farfan, Timothy Byer, Alex Hackert, Caitlin Elen-Morin and
24 State Bar Employee, and Does 4 through 50 intentionally misrepresented or concealed a material fact
25 as specifically alleged throughout this complaint.
26 509. The malice, oppression, or fraud by Defendants, Maricruz Farfan, Timothy Byer, Alex
27 Hackert, Caitlin Elen-Morin and State Bar Employee, was conduct of one or more officers, directors,
28 or managing agents of the California State Bar.
90
#:1218
1 510. Alternatively, the conduct constituting malice, oppression, or fraud by Defendants,

2 Maricruz Farfan, Timothy Byer, Alex Hackert, Caitlin Elen-Morin and State Bar Employee, was
3 authorized by one or more officers, directors, or managing agents of the California State Bar.
4 511. Alternatively, one or more officers, directors, or managing agents of the California
5 State Bar knew of the conduct constituting malice, oppression, or fraud and adopted or approved that
6 conduct after it occurred. They adopted each and every act, including sending Plaintiff a redacted
7 probation policy and procedure sheet that blacked out the guidelines for when suspension is supposed
8 to start.
9 512. The aforementioned conduct of Defendants, Maricruz Farfan, Timothy Byer, Alex
10 Hackert, Caitlin Elen-Morin and State Bar Employee, was malicious and/or an intentional
13 Morin and State Bar Employee to thereby deprive Plaintiff of property or legal rights or otherwise
14 causing injury, and was despicable conduct that subjected Plaintiff to a cruel and unjust hardship in
15 conscious disregard of Plaintiff’s rights, so as to justify an award of exemplary and punitive damages.
16 513. The aforementioned conduct of Defendants, Anthony T. Williams, CLOA, George
17 Olivo, Sheri Moody, Valerie Lopez, Cynthia L. Brown, Sherry Hernandez, Monica Jones, Pam
18 Ragland, Greg Diamond, Billie Rene Powers, William Wagener, Karin Huffer, Mary Smith, Joanne
19 Kennedy, Devin Lucas, Steve Ballard, Catherine Olsen, Nira Woods, Maegan Donovan Nikolic,
20 Norma White, Vern Nelson and Does 4 through 50, was malicious and/or an intentional
23 Morin and State Bar Employee or Defendants, Anthony T. Williams, CLOA, George Olivo, Sheri
24 Moody, Valerie Lopez, Cynthia L. Brown, Sherry Hernandez, Monica Jones, Pam Ragland, Greg
25 Diamond, Billie Rene Powers, William Wagener, Karin Huffer, Mary Smith, Joanne Kennedy, Devin
26 Lucas, Steve Ballard, Catherine Olsen, Nira Woods and Does 4 through 50 to thereby deprive Plaintiff
27 of property or legal rights or otherwise causing injury, and was despicable conduct that subjected
28 Plaintiff to a cruel and unjust hardship in conscious disregard of Plaintiff’s rights, so as to justify an
award of exemplary and punitive damages.
///
///
91
#:1219
1 PRAYER FOR RELIEF

2 WHEREFORE, Plaintiffs pray for judgment against Defendants, and each of them, as
3 follows:
4 First Cause of Action
5 1. For a preliminary and permanent injunction, including a take down order of all videos,
6 streams, memes, posts, blogs or other material calling for dangerous conduct such as the
7 common law grand jury requests against Plaintiff;
8 2. Restitution and/or damages;
9 3. Treble Damages;
10 4. Costs;
11 5. Attorney fees:
12 6. Any further relief the court would deem appropriate and just.
13 Second through Fifth Cause of Action
14 1. For a preliminary and permanent injunction against individual Defendants and the
15 State Bar;
16 2. Damages from individual Defendants only;
17 3. Costs
18 4. Fees
20 Sixth Causes of Action
21 1. For a preliminary and permanent injunction, including an order to take defamatory
22 material down from the internet;
23 2. For actual damages;
24 3. For general damages;
25 4. Costs;
26 5. Attorney fees;
27 6. Punitive Damages;
Seventh Cause of Action
92
#:1220
1 1. For a preliminary and permanent injunction; including a take down order of all videos,
2 streams, memes, posts, blogs or other material placing Plaintiff in a false light. for
5 4. Costs;
6 5. Attorney fees;
9 Eighth Cause of Action
10 1. For a preliminary and permanent injunction;
13 4. Costs;
14 5. Attorney fees;
17 Ninth and Tenth Cause of Action
18 1. Pursuant to Business and Professions Code sections § 17203 and §17535, and pursuant to the
19 equitable powers of this Court, Plaintiff prays that the Defendants be preliminarily and
20 permanently enjoined from committing any acts of unlawful, unfair competition in violation
21 of § 17200, including, but not limited to, the violations alleged herein
22 2. Pursuant to Business and Professions Code sections § 17203 and §17535, and pursuant to the
23 equitable powers of this Court, Plaintiff prays that the Defendants are ordered to restore to
24 the general public all funds or property acquired by means of any act or practice declared by
25 this Court to be unlawful or fraudulent or to constitute unfair competition under Business &
26 Professions Code §17200 et seq., or untrue or misleading advertising under §17500 et seq.
27 3. Mandatory injunction including take down orders of materials found to violate this section;
28 4. Restitution;
5. Disgorgement of profits;
6. Costs;
93
#:1221
1 7. Attorneys’ fees;
2 8. Such other and further relief as this Court finds necessary and proper.
3 Eleventh Cause of Action
4 1. Declaration that Cal Business & Profession Code §6106 is unconstitutional;
5 2. Declaration that Cal Business & Professions Code § 6085 is unconstitutional;
6 3. Permanently enjoining the California State Bar from prosecuting members of the Bar
7 with a violation of §6016;
8 4. Costs and attorney fees;
9 5. Such other and further relief as this Court finds necessary and proper.
10
11 DEMAND FOR JURY TRIAL
12 Plaintiffs hereby demand a jury trial as to those issues that are not equitable in nature.
13 Dated: August 24, 2018
14 By: s/Lenore L. Albert_______________
LENORE L. ALBERT
15
Plaintiff pro per
16
17
18
19
20
21
22
23
24
25
26
27
28
94
#:1222
1 PROOF OF SERVICE
2
STATE OF CALIFORNIA, COUNTY OF ORANGE:
3 I declare that I am over the age of 18 years, and I am employed in Orange County, California; my
business address is 14272 Hoover Street #69, Westminster, California 92683.
4
5 On August 28, 2018, I served a copy of the following document(s) described as:
6 FIRST AMENDED COMPLAINT FOR RACKETEERING, CIVIL RIGHTS, AND UCL
VIOLATIONS
7
On the interested parties in this action as follows:
8 See attached Mailing List
9
[x] BY CM/ECF* – I caused such document(s) to be transmitted to the office(s) of the addressee(s)
10 listed above by electronic mail at the e-mail address(es) set forth pursuant to FRCP 5(d)(1). (State Bar
11 Defendants and Greg Diamond)
[x] BY EMAIL – I caused such document(s) to be transmitted to the office(s) of the addressee(s) listed
12 above by electronic mail at the e-mail address(es) set forth herein. (Nira Woods and Pam Ragland)
13 [x] BY US MAIL – I caused such document(s) to be transmitted to the office(s) of the addressee(s)
listed above by regular U.S. mail at the mail address(es) set forth herein. (All Defendants Except for
14 Greg Diamond and the State Bar Defendants)
15 [ ] BY FAX – I caused such document(s) to be transmitted facsimile from the offices located in
Westminster, California this business day to the aforementioned recipients.
16 I declare under penalty of perjury under the laws of the State of California and the United States of
17 America that the foregoing is true and correct.
18 Dated: August 28, 2018
19 s/ Ed Garza______________________________
Ed Garza *
20 *Ed Garza for US mailing. Lenore Albert ECF for filing and ECF service.
21
22
23
24
25
26
27
28
95
#:1223
1 MAILING LIST
Gregory A Diamond*
2
Law Office of Gregory A Diamond Timothy Byer
3 920 Steele Drive Suzanne Grandt, Esq.
Brea, CA 92821 California State Bar
4
714-782-4734 Ofc of General Counsel
5 Email: gad20@columbia.edu 180 Howard Street
San Francisco, CA 94105
6
Nira Woods Suzanne.grandt@calbar.ca.gov
7 2550 PCH #68
Torrance, CA 90 505 State Bar Employee
8
310-326-6174 Suzanne Grandt, Esq.
9 Email: niraschwartzwoods@yahoo.com California State Bar
Ofc of General Counsel
10
State Bar of California 180 Howard Street
11 Suzanne Grandt, Esq. San Francisco, CA 94105
California State Bar Suzanne.grandt@calbar.ca.gov
12
Ofc of General Counsel
13 180 Howard Street Pam Ragland
San Francisco, CA 94105 PO BOX 761
14
Suzanne.grandt@calbar.ca.gov TRABUCO CANYON, CA 92678
15 Phone: (949)734-0374
Maricruz Farfan Email: Pmt@AimingHigher.com;
16
Suzanne Grandt, Esq. PamIamM2@gmail.com
17 California State Bar
Ofc of General Counsel George Olivo
18
180 Howard Street Theo Lacy #3067214
19 San Francisco, CA 94105 501 City Drive South
Suzanne.grandt@calbar.ca.gov Orange, Ca. 92868
20
21 Caitlin Elen-Morin Anthony Troy Williams
Suzanne Grandt, Esq. FDC Honolulu #5963-0122
22
California State Bar P.O. Box 30080
23 Ofc of General Counsel Honolulu, HA 96820
180 Howard Street
24
San Francisco, CA 94105 Common Law Office of America
25 Suzanne.grandt@calbar.ca.gov FDC Honolulu #5963-0122
P.O. Box 30080
26
Alex Hackert Honolulu, HA 96820
27 Suzanne Grandt, Esq.
California State Bar Karin Huffer
28
Ofc of General Counsel 3236 Mountain Spring Road
180 Howard Street Las Vegas, NV 89146
San Francisco, CA 94105
Suzanne.grandt@calbar.ca.gov Monica Jones
96
#:1224
1 149 Cologne Court

Henderson, Nevada 89074
2
3 Defendant Citibank, N.A.:
Citibank, N.A.
4
Wendy Barcenas
5 2677 N. Main Street
Santa Ana, CA 92705
6
7 President of Citibank N.A.
Citibank, N.A.
8
701 East 60th Street North
9 Sioux Falls, SD 57104
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
97

Lenore

Hochgeladen von

Dokumentinformationen

Originaltitel

Copyright

Verfügbare Formate

Dieses Dokument teilen

Dokument teilen oder einbetten

Freigabeoptionen

Stufen Sie dieses Dokument als nützlich ein?

Sind diese Inhalte unangemessen?

Copyright:

Verfügbare Formate

Lenore

Hochgeladen von

Copyright:

Verfügbare Formate

Case 8:18-cv-00448-CJC-JDE Document 172 Filed 08/28/18 Page 1 of 97 Page ID #:1128

1 Plaintiff LENORE ALBERT (referred to as “Plaintiff” or "Plaintiffs"), now amends her

1 63. Mortgage Enterprise Investments

1 93. Norma White

1 FIRST PREDICATE ACT (Mail Fraud, 18 U.S.C. §1341)

1 11/25/14 Defendant Cynthia Louise

23 against her, she decided to save one or two.

24 3/29/17 Marvin Baldwin 17-O-02039

25 8/18/17 David Bitzer 17-O-05418

1 4/3/18 State Bar 18-O-13298

1 510. Alternatively, the conduct constituting malice, oppression, or fraud by Defendants,

1 PRAYER FOR RELIEF

1 149 Cologne Court

Das könnte Ihnen auch gefallen