09-01-13 Samaan v Zernik (SC087400) Bank of America-moldawsky Extortionist Second Supplemental Declaration-s

1 II BRYAN CAVB LLP
John W. Amberg (CA State Bar No. 108166)
2 lI]enna Moldawsky (CA State Bar No. 246109)
120 Broadway, Suite 300
3 II Santa Monica, California 90401-2386
Telephone: 310-576-2100
4 II Facslmile: 310-576-2200
5
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Attorneys for Non-Party COUNTRYWIDE HOME LOANS, INC.
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF LOS ANGELES, WEST DISTRICT
11 II NIVIE SAMA..A.N, et al.,
SECOND SUPPLEMENTAL
DECLARATION OF JENNA
MOLDAWSKY IN SUPPORT OF
COUNTRYWIDE HOME LOANS,
INC.'S MOTION FOR SANCTIONS
AND OTHER RELIEF AGAINST
DEFENDANT JOSEPH ZERNIK
Case No. SC087400
Date: January 13, 2009
Time: 8:45 a.m.
Place: WE]
Plaintiffs,
Defendants.
vs.
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15 II JOSEPH ZERNIK, et al.
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22 II I, J enna Moldawsky, declare as follows:
23 1. I am an attorney licensed to practice law in ,California. I am an associate in the
24 II law firm of Bryan Cave LLP, counsel of record for non-partY Countrywide Home Loans, Inc.
25 II ("Countrywide"). I have personal knowledge of the facts set forth in this Second
26 II Supplemental Declaration. I submit this Second Supplemental Declaration to present new
27 " evidence to support Countrywide's pending motion for monetary sanctions and for other
28 II relief against defendant Joseph Zernik ("Zernik").
SMOIDOCS715392.1
SECOND SUPPLEMENTAL DECLARATION IN SUPPORT OF
MOTION FOR SANCTIONS
Digitally signed
by Joseph Zernik
DN: cn=Joseph
Zernik, o, ou,
email=jz12345@e
arthlink.net, c=US
Date: 2010.05.12
13:56:07 +03'00'
2. On December 3,2008, Zernik sent a letter to Kenneth D. Lewis, President,
2 II Chief Executive Officer and Chairman of Bank of America Corporation, and Teresa M.
3 II Brenner, Associate General Counsel for Bank of America Corporation. In the letter Zernik
4 II demands that Bank of America Corporation "mitigate [his] damages" relating to the present
5 II action, and calls for "corrective action." Included in the letter is a purported "press release"
6 II in which Zernik alleges that Countrywide is guilty of "fraud," and accuses the Los Angeles
7 II Superior Court of "elaborate court fraud." A true and correct copy of this correspondence is
8 II attached to this declaration as Exhibit A and incorporated herein by reference.
9 3. On December 11, 2008, Zernik sent another letter to Mr. Lewis and Ms.
10 II Brenner, along with Timothy Mayopoulos, General Counsel for Bank of America
11 II Corporation, and WilliamJ. Mostyn III, Deputy General Counsel for Bank of America
18 II hearing on its Motion.
19 II I declare under penalty of perjury under the laws of the State of California that the
20 II foregoing is true and correct.
21 II Executed on January 9, 2009 at Santa Monica, California.
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Corporation. In the letter, Zernik claims that he is "a victirri of real estate fraud perpetrated by
I
Countrywide Home Loans, Inc." and accuses those involve1d in the present action of
"fabricat[ing] court records." Zernik demands a response tb his letter by December 16, 2008.
A true and correct copy of this correspondence is attached to this declaration as Exhibit B
and incorporated herein by reference.
4. Countrywide reserves its right to submit further evidence in advance of the
~ ~ A M F
J nna Moldawsky
SMOIDOCS715392.\ 2
SECOND SUPPLEMENTAL DECLARATION TN SUPPORT OF
MOTION FOR SANCTIONS
V .LIHIHXH
Joseph Zemik DMDPhD
Fax: (801) 998-0917 Email: jZ;[email protected]
Digitally signed by Joseph
Zemlk
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JJ DN: m",Joseph Z€!mik.
. . enlall=jz12345@earthUnk
net,.<,<US
Date:
..{)8'()O'
" Judge shaff be faithful to the law... "
Co<» .JudElhitls :tS(1)
"The rule of law must never be confused with tyranny of the courts"
Anonym<>US
TIME IS OF THE ESSENCE
December J, 2008
KENNETH D. LEWIS
Chainnan, Chief Executive Officer, and President
Bank of America Corporation
TERESA M. BRENNER
Associate General Counsel
Bank ofAmerica Corporation
100 North Tryon St
Bank of America Corporate Ccnter
Charlotte, North Carolina 28255
RE: DEMAND TO MITIGATE DAMAGES AND FOR CORRECTIVE ACTIONS
Mr Lewis. Ms Brenner:
My rec.ords show that in early February 2008, soon after your initial decision to takeover Countly\vide, I send you
"ffitten notices describing the c:onduct of Countrywide in COlIrt here in Los Angeles, relative to litigation in
Samaan. vZemik, SC087400, which started in October 2005, and is still going on today.
Enclosed is a press release dated December 3,2008, titled:
Who's inControl? Countrywide's Involvement in a Dubious Los Angeles Superior Court Case Continues even
afterTakeoverby Bank of America; U.S. Department of Justice has tolerated the runaway LA court in the past 8
years, and thousands (?) are falsely imprisoned by the same court for over a decade, ..
Also enclosed is a letter to various parties, please accept it as addressed personally to you with the demand for
immediate action to mitigate damages, to safeguard my civil rights. to return my borne to my possession, 10 stop
my harassment by Countrywide, and for compensation for harm to me by Countrywide*. .
immediately. but no later than Friday, December 12, 200S, 5:00pm inform me ofyourdccision in this
regard.

Joseph Zernik
*Countrywide here denotes Countrywide Financial Corporation (CFC) and all its subsidiaries and affiliates,
jointly and/or severally.
PRESS RELEASE
Digitally signed by
Joseph Zt!mik
"'::l.. IJ DN: cn=Joseph Zernlk,
) ,. .email=jZl234SIfi<>arthlin

Darc: 2008.12.03'
07:U:57 -08'00'
Title;
Who's in Control? Countrywide's Involvement in a Dubious Los Angeles
Superior Court Case Continues even after Takeover by Bank of America;
U.S. Department of Justice has tolerated the runaway LA court in the
past 8 years, and thousands (1) are falsely imprisoned by the same
court for over a decade...
Subtitle:
Defendant calls for the highest priority action by the Obama administration
regarding the collapsedjustice system of Los Angeles county..,
fu1:Qy;
Samaan v Zemik stems from a dispute over a real estate transaction, entered by the
parties in 2004 for purchase of Zetnik's Beverly Hills residence by Samaan, •She was 8
straw buyer, and everything sfart,i1g with herPre-qualification Letter and her Loan
Applications end continUIng in the lawsuit that was filed e year later was part of an
elaborate series of frauds, "states Zernlk. Indeed, an opinion letter by nationally
acclaimed fraud expert Robert Meister shows that the signatures on both the
prequalification letter and the loan applications were forged. Claims of such fraud and
other instances of fraud by Samaan, by Countrywide, and by the LA Superior Court,
were made by Zemik in court papers throughout the litigation. Regardless, on August 9,
2007 Judge Jacqueline Connor· best known for derailing the Rampart tnal in 2000-
held a summary jUdgment hearing, and rendered summary jUdgment in favor of.
Semaan. Zernik was required to sell the propertyto Samaan fbr over $1.8 million.
However, to this date, that judgment has never been entered. "Judge Connor and
Samaan's counsel (Sheppard Mullin) engaged in a convoluted fraud regarding the entry
of the jUdgment. Therefore, there was never a valid effectual jodgmentin this case". A
case with no jUdgment leaves Zernik exposed to unending litigation.
there been a valid enteredjudgmenf claims Zemik "It would have been the
foundation of Pasternak's appointment." Instead, court transcripts show that while
claiming to appoint Pasternak Receiver for execution of the judgment, neither Judge
Segal nor counsel for Samaan recognized the judgment as valid. Accordingly, the
judgment was never referenced as the legal basis for the appointment, neither was any
section of the code. "Judge Segal and Bamaen's counsel, in collusion with Pasternak,
iSSUed, but never entered, a fraudulent appointment order", says Zerhik "had there beeh
a valid judgment and a valid appointment, Pasternak would have issued a Writ of
Execution, and with that, he could have filed a genuine grantdeed. And had this been a
legitimate transfer of title by the court, Pestemak would have given me the money no
later than 30 days from the date of the sale, as required by law".
Zemik had moved out in November 2007, as was his plan ever since 2004, but also
under threat of use of force by JUdge Segal and David Pastemak. Samaan began
occupying the Zernik's residence in December 2007. Later, Zemik found out that
Pasternak filed a fraudulent grant deed transferring the ownership of property to
Samaan. James Wedick, a veteran agent and acclaimed fraud expert (best known
for his role in the probe where six members of Congress were found guilty oftaking
bnbes in 1981), confirmed the fraud in the execution of the grant deed by David
Pasternak, purportedly on behalf of the LA Superior Court.
In late January 2008, since he had notreceived any proceeds from the purported
escrow, Zemik brought a motion for the court to distribute to him his equity which
purportedly was he'ld by Pasternak following the safe of the property to Samaan. Judge
Friedman denied the motion and instructed Zemik never to bring such motion again or
face sanctions.
In court papers Zernik claims that the elaborate court fraud in this case was based on
fraudulent records produced by Countrywide, where Samaan's husband was a "loan
originator". Indeed Countrywide has regularly appeared in this case - represented by Bryan
Cave, LLP. tn papers filed in court, Countrywide routinely referred to itself as "Non-Partyt', but
the court interchangeably designated Countrywide as ·Plaintiff', "Defendanf, "InteIVenot ,
"Cross-Defendanf, and more. "Fraud in court by Country't,/ide is not unusual at alf claims
Zemik "It was their routine aft over the U. S. The only unique feature here was the coflusion
by the court. Judge Friedman threatened tojail me if I ask his friend Sandy[Sandor Samuels
- formerly Chief Lega! Officer of Countrywide andPresident of Bet TZedek] anytilfng about
this fraud n. Indeed, a 72 page March 2008 opinion by U.S. District Court in Texas Judge
Boome rebuked Countrywide's legal practices in his court, and in courts around the U.S.
Since JUly 2008, Countrywide no longer exists as an independent entity. Control of
Countrywide is now by Bank of America, following a January 2008 stock market crash of the
Countrywide share, prompted by exposure of its legal practices in a Pennsylvania court.
'1I\Iflat took place in the Pennsylvania court is a Cllild's play in comparison
n
says Zemik, «And
it is not clear at all that Bankof America even knows what Countrywide is doing in Los
Angeles, even today". At present Bryan Cave, LLP refuses to disclose whom they represent.
•Judge Teny Friedman issued efraudulent notice for a November 21, 2008 proceeding,
where he concealed Countrywide's participation. This is no exception, • says Zemik "Judge
Connor and Judge Seg8! didjust the same. There is no way t6 explain this as a tmecourt
case" says Zernik. "Does Terry Friedman, have an assignment order? Does he·/J8ve any
authority in the case at af/? And for that matter, did Judge Segal have an assignment order?
Did Judge Connor have one? Was the November 21, 2008 notice; issued in the name 0'
Clerk Clarke an authentic Superior Court notice? Is the case as a whole, 8 true case of the
Califomia Superior Court system? Howis the court allowed to deny me for the fourth year in
arow access to myown litigation records? How could Samaan file papers for the
November 21 hearing, be deSignated 'Post-judgment Motion", when neither she nor the
court have ever acknowledged the August 9, 2007 judgment? The Presiding Judge of
the Court, the Clerk of the LA Superior COlJrt, their in-house attomeys and the outside
counsel they retained are refusing to answer any questions regarding this case for half a
year now. The court is taking the Fifth... 'f Inl;leed, both the Register of Actions, and also
the online Case Summary indicate that judgment inthis case is still pending.
"In fact, it is an Enterprise-track case" says Zemik"1f reflects comJption of the eMl division of
LA Superior Court that is the mirror image of eomJption of the crimina! division documented in
great detail in the Rampart scandal investigations. Howcould anybodyexpecfanylhing else?
fUsthe samejudges 8tler all... " Indeed, t h ~ protagonist - Jacqueline Connor - is one and
the same in both cases. The Blue Ribbon Report of the Rampart s.candal (July 2006),
showed that thase who were confirmed innocent in the initial Rampart scandal investigatiOn
by the Board of Inquiry (1998-2000), but had been falsely convicted and imprisoned by the
LA Superior Court were still falsely imprisoned in 2006. Most likely they number in the
thousands, and some of them also had confessions extracted through torture. Such crimes
were called "heinous", and "characteristic of the most repressive dictators and police
states"**". But the2006 report described in great details that LAPD, DA prosecutor'S, and LA
Superior Court judges were blocking the release of the victims of such <;:rirnes for ~ m o s t a
decade.
"TIle LA County Superior Court is still holdihg thousands of peop/o fa/sely imprisonecf
concludes Zemik •Most of fflem are likely to be black and minorities. It undermines any
claim of legitimacy by government in this country. The newadministrotion must not 1m
this stand!"
FOOTNOTES;
Countrywide here denotes Countrywide Financial Corporation, Inc, and any and all its subsidiaries and
affiliates, jointly an<j/or severally.
All referenced materials, including court records and correspondence with FBI and US DOJ can be
found at; http://inproperir1la.CQml. Listed Below are some 1)f the specific key references.
ENvin Chemerinsky. today Dean, irvine Law School, in: 57 Guild Pract. 121,2000
REFERENCES;
1) November 30, 2008
LeUer by defendant Zemik to Presiding Judge Czuleger and Clerk Clarke of LA Superior COlirt.
2) http://inproperinla.comlQ7-12-17-opinlon-letter-lraud-inilranl-<leeds-s.pdf Wedick's opinion letter re:
Pasternak's Grant Deed.
3) htto;l/inproperinla.com/04-09-07-opinion-letter-fraud-in-otegualificaion-ietter.S,pdf Meister's opinion
letter in re: Samaan's pre-qualilication letter.
4) hltp:llinproperinla. comJ04-09-27-opinlon-lctter"!raud-in-loan-applicationS=ljignalure-s,Pdf Meister's
opinion letter in re: signatures on Sarnaan's loan applications with Countrywide.
5) Detailed review
of frauds in Samaan's Joan applicalions with Countrywide in records filed in U.S. District Court.
6)
Meister's opinion letter in re: fraud in Countrywide's underwriting leiter.
7) U.S. District Court
filingdescnbihg the fraud in Countrywide's real.eslate contract record.
8) U.S. District
Court filing describing the fraud in Countrywide'S underwriting letter. .
9) hllp:/linproperinla.coml07-08-09-judgment&order-<[email protected] Augus19,
2007 Judgmenl by Judge Connor, rendered but never entered, and a corresponding order thet
served as the basis for the fraud by the court.
10) http://inproperinla,corrl108-09-08-conqressional-assistance-S.pdf Correspondence with FBI and
U.S. Dept of· Justice.
11) http://inproperinla. enlaI-of-access-book-of -mccoy-letters-s.pdf
Presiding Judge's refusal to answer regarding existence of judgment in (Samaan v Zemik).
12) hl.!P-:llinproperinla.com/oo-OQ-Oo-la-sup-ct-register-of-agions-sustain-08-11-14-certified-s.Qdf
November 14, 2008 Register of Actions in Samaan v Zemik (SC087400)
13) !l!!P.:i/inproperinla.comlQ!U.1:.30-case-summary-,s.p9.f November 30, 2008 Case Summary in
Samllan v.Zemik (SC087400)
14) http; llinproperinla.... com/OQ-QO..OO-rampart-blue-ribbon-rei!iew;f1anel-2006-report.QQf Slue Ribbon
Report of 2000, describing the failure to release lhose falsely imprisoned In LA County as part of
the Rampart scandal.
----------CON:.rACT-;-·---- -----------.----------
Dr Joseph Zemi:<
Tel: 310 435-9107
Email: [email protected]
.Joseph Zemik DMD PhD
Fax: (801) 998-0917 Email: [email protected]
"Judge shall be faithful to the law... "
cal Code J/Jd E1hJc$ 35(2)
"The rule of law must never be confused with tyranny of the courts'· .
Aool1)ll7lOUS'.
Alejandro Mayorkas ~ O'Melveny & Myers;
'Former U.S. Attorney, and Board Member of Bet: Tzedek.
Att Mitchell Kamin, President
For Bet TzedeK- House o.lJustice
John Fishel
For BoardofDirectors, Jewish Fedenz/ion q(Los Angeles
Bryan Cave, lLP
For &mdor Samuels. Angelo Mozilo, COUnffyll'ide Home Loans, CounJrywide Finarteial Corporation
Buchalter Nemer
For Mara Escrow. asuhsidiary alOldRepublic TiJle
Cummings, McClorcy, Davis, Acho and Associates, D. Bret Bianco
For LiJs Angeles Superior Court, Presiding Judge Stephen Czuleger, Clerk John Clarke. Judges: JacqtJ.e/lne
Connor, John Segal, Teny Friedman, Gerald Rosenberg, &ADR
Dan Loritz, Okom-Loritz, LLP
For USC Credit Union, GW)! Perez, Prl!sident/CEO
Pasternak, Pasternak, Jiatton
For David Pasremak
Barry Snicker, Mayor, and City Council of .Beverly lUlls
For the City ofBeverlyHill<;
Kenneth D. Lewis, Chairman, CEO, and President;
Teresa Brenner, Associate General Counsel
For Bank ofAmerica Corporation
Martin Berg,Editor
.For The Daizv Journal
Thc Honorable Ronald George, eldef Justice
California Supreme Coun
Kcnneth Kaiser, Assistant Director
FortheFBI
Kennetb Melson, Director
Michae Mukasey, Attorney General
For/he Us. Department ofJustice
TIME IS OF THE ESSENCE!
RESPONSE REQUESTED BY 5:00PM FRIDAY, DECEMBER 5, 2008!
RE: 1) Fraudulent conveyance of title and real estatefraud on real property commonly known as 320
Souih Peck Drive, Beverly Hills,.California,90212, 2) Samoan v Zernik (SC089400) fraUlfulent
litigation at the Los Angeles Superior Coort of the State ofCalifornia, 3) Racketeering in the Lus
• Page217
Novembet28,2008
Angeles Superior Court, 4) Thousands of innocent people fal"CIy imprisoned in Los Angeles County,
California.
Counsel and unrepresented parties:
I am an unrepresented individual, citizen of the United States, resident of the County of Los Angeles, Califomia
During the period relevant to events described below rwas also a resident of the city of BeverJy Hills.
A. Brief chronology of organized crime actions under the guise of LA Suocrior Court actions.
Since October 20()5 I have been severely abused and harassed under the guise of litigation in the Califomia
Superior Court in Samaan v Zernik (SC087400j in Santa Monica, CaJifomia. Ihave been repeatedJy called to
appear in court; my nonna) life routines were entirely lmdennined; [ have been forced to spend large. sums of
money on legal expenses; and I have been forced to spend most ofmy days studying the law and various other
fields for my own defense.
In November 2007 I was driven out of my home, the property listed above, in Beverly Hms. Ullder the threat of
violence by John Segal, pretending to act as ajudge of the Superior Court, and Att David Pasternak (former
president - }Iousc of Justice- Bet Tzedek) pretending to act as a court officer, whi Ie both knew all aJong that they
were acting with no authority at al.1, out ofcompliance and in violation ofthe law.
Sometime in late November 2007 Art committed forced entI)' into the property and "took possession"
ofit, with no legal foundation at aJl.
In December 2007 AU Pasternak suhjected my property to fraudulent conveyance of title'. and proceeded to
collect-some monies in exchange for the property from Nivie Samaan, and keeping the funds to himself, with no
legal foundation at all.
When I tried to stand for my rights, I was purportedly found in conteinpt ofthe court; I purportedly had sanctions
in the tens of thousands ofdollars set upon me; I had gag orders purportedly imposed upon mc- for the benefit of
large corporations - Countrywide, Old Republic Title, and United Title, through ex parte proceedings.
On July 6, 2007, I was subjected to the .first ofsuch procedures - initiated by Counttywide, and held in adark
courtroom in the Los Angeles Superior Court by Judge Jacqueline Connor (Best known for derailing the First
Rampart Trial in 2000), offthe calendar and off the record.
In November 2007. I had a fraudulent Receiver - Att David Pastentakappointed upon me by Judge John
through another shamlegal proceeding; with 4-day notice... Aft Pasternak was purportedly vested by John
Segal with unlimited powcrs to abuse. and harass, deriving his authority from neither a judgment notany section
of the California code. Beyond the theft of my property purportedly on behalfofthe Court, AttPastemak
fraudulently incurred me with hundreds ofthousaJldsOfdollars in tax liabilities, sirrcehe collected the full
p.roccedsofthe sale, and deferred the paymentofta.xes;
On December 7. 20071 was subjected to another ex parte procedure for gag orders, this tHne initiated by Aft
Pasternak, for thebenefrt ofMara Escrowand United Tine..
In I was fraudulently threatened with jail time by Judge Terry Friedman, trying to prevent me
from exposing the fraud in Countrywide involvement in thi.s ca<;e.
I received death threats a couple oftime, the first -in March2007 - when I located a former senior underwriter of
Countrywide in March 2007,\vhich Countrywide did not want me to ever locate...
Why?
By November-December 2006 I figured outtbe nature oftIle conduct ofSheppard Mullin,representingNivie
Samaal1, sufficiently well, to understand that they were fabricatingfraudule.ntclaims against me. in collusion
Judge Jacqueline Connor and Countrywide they were tirelessly tuBing to defraud me out ofmy home under
the bruise oflcg'dt action intbe Los Angeles Superior Court.
• Page3rT
November 28, 2008
I had no background and no fomlal training in the .law, economics, banking or mortgage lending, and yet by
Januaw2007, I figured out the business mooel of Countrywide and the nature of Angelo Mozilomld Sandor
Samuels' fuuJduleht c.onduct sufficiently we/! that 1filed complaints with the FBI, and thenalso with Banking
Regulators such as Office ofThrift Supervision and Office of Federal Trade Commission. rc1airnedthat
CoUiltrywide was involved in massive fraud against the U.S. Government and the American tax-payer.
By March 2007 I was able to come up v.'ith initial rough estimates, which indicated potential liability to the US.
Government in the hundreds of billions of dollars (in retrospect - a conservative estimate). ralso wrote a series of
open letters to the Board of Directors of the f louse ofJustice - Ikt Tz.edek. I warned them that an organimtion
that purports to be the "House of Justice" must never allow Sandor Samuels to be the President.of its Board of
Directors. 1warned them that he was personally involved in fraud against me, and that tens ofthousands of
families would lqosc their homes as a result of his business activities (in retrospect - a conservative estimat.e). Bet
Tze<lek Board of Dircetors never responded to my alarming messages. But C-ountrywide, Sandor Samuels, and
Angelo Mozilo did. They retained Bryan Cave, LLP, to harass me, to retaliate against me, to intimidate me, and
[0 supervise the perversion ofjustice under the guise of litib>ation in the Los Angeles Superior Court.
On Jnix 6_ 2007 slIch campaign was initiated with an ex parte appearance, for a gag order against me in the dllfk
courtroom of Judge Jacqueline Connor, who remained in chambers - nowhere to be seen - with no recogni7..abJe
clerk of the court in attendancc.
By mid- 2007 and more so by the beginning of.f008 r figured out the business model ofthe Los Angeles
Superior Court sufficiently well that 1understO<Xi that Samoan v Zemik (SC0874fJO), in fact never was a true
case of the Superior Court oflhe State ofCalifomia, but instead, a case of the "Enterprise Track" ofthe· Los
Angeles County judiciary, designated as sll<;h by Judge Jacqueline Connor even before the complaint was filed.
r graduaUyleamed more about Sustain, the Los Angeles Superior Court's computer system, realizing that such
system Was quintessential for the operations oftile Enterprise in the fann it is manifested today. 11lis system was
procured and installed arOUild out of compliance and in violation ofthe law, by a company by the same or
similar name (Sustain or Sustained), which is solely controlled by the Daily the largest legal newspaper
in Los Angles, a' fact that is apparently trnrecognized in the legal community. Around the same time. the
Honorable Ronald George, today Chief Justice of the California Supreme COllrt, held variQus leadership
positions it! the Los Angeles Superior Court
B. Beyond Real Estate Frauds - the Rampart Scandal
In recent rnbnths, I tried to better understand the scope ofopcrationsofthe Enterprise beyond real estate and
other litigation frauds, and the 1,!nique positionofJudge Jacqueline Connor relative to organiz..ed crime inLos
Angeles. I studied the history ofthe Rampart scandal (1998-2000),euphe1nistically named the Rampart-Area
Corruption Incident. The Blue RibhonRcview Pnncl report (July 2006), makes it ablUldantly clear that the
activities characteristic ofthat scandal were never limited to the Rampart area, and were and probably still are
endemic, not an isolated incident at all.
Furthermore, I soon realized what the main goal was of the 8lJtbors ofthat report: First - to document what they
called the "suhcult ofcriminality toletatedin tlte raflks' ofthe LA County justice system- and second, to
document how suchjustice system is preventing the release from long tenn false imprisonment ofthe thousands
of people, who were repeatedly confiffi1cd by several successive investigation committees as innocent but framed.
Even today, ten years after the scandal was exposed, nobody knows the exact scope of it.
Erwin Chemerinsky, today FOlmding Dean,]rvine LawSchool, described it already in 2000 as follows:
"Any analysis of the Rampart scandal must begin with an appreciation of the heinous nature
of what the officers did, This is conduct associated with the most repressive dictatol'$ and
police states, •
And David Burcham, Dean of the Loyola Law School, with Catherine Fisk wrote in 2000:
•...Judges tried and sentenced a staggering number of people for crimes they did not commit.
How could so many participants in the criminal justice system have failed either to rectY;.lnize
• Page4r7 November 28, 2008
or to instigate any meaningful scrutiny of such appalling and repeated perversions of
justice?"
C. The court's case management system as the enabling tool of the Enterprise.
My reading of the Blue Ribbon Review Panel is that the panel, like all invest.igation committees before it,
and like the public at large in LA County, were dellied access to public records that are the Books of Courts
ofLA County Superior COllrt. Such public Records, are critical for the safeguard of the integrity ofthe
courts. However, such Book of Court are since 1985 implemented in Sustain, and off limits to the pubic a
mass-scale routine and continuous abuse of civil rights of all who live in LA County, by the LA County
Court itself. Such abusc is tolerated by the U.S. Department of Justice, who fails to perfoffil its duties.
I also believe lilat the jack ofaccess to such public records is a main handicap in the operations of the oOice of the
Overseer ofcivil rights in LA, U.S. Judge Gal)' Feess, appointed pursuant to the Consent Decree of 2001. My
reading of the reports was that by 2004 he \-vas trying, unsuccC$sfully to establish acce..% to such data ba..'C"S, and
hi.. demands ignored by the LA COlmty justice system Needless to say, Tbelieve that the Overseer, in his seven
years in office., never freed even one singte person ofthe thousands who are falsely imptisoned.
Therefore, the failure of the U.S. Department ofJustice to enforce the basic civil right fur Books ofCourt that are
Public Records, free for the public to inspect and to copy, also paints u.s. law enforcement agencies as impotent
in LA O:mnty - since they cannot enforce the Consent Decree that was the outcome of the yielding of the City of
LA to the U.S. Government in 2001.
The proposed action -,- take-over ofcontrol ofthe LA County Superior Court's computers by Federal, Agencies, is a
relatively simple task. Jt was practiced repeatedly in recent months anytime the U.S. Government took over any major
failing financial iru.1itulion. Surely there ate units fully prepared in Department oft11e Treasury. It is all olX--'tdtion that
can be accompli.<;hed ovemight.. ,at minimal risk and and with miijor positive impact on the life of individual and
the luk oflaw' ioLA County.
D. lJnanswered Questions
I) LA Superior Court
1have been denied access to my own Utigationrecordsin SuStain throughout this purportedlitigation., and I bold
that had I been allowed access to Sustain, none of it could ever have bappened.
Since June 2008, the office of Presiding Judge ofthe Los Angeles Superior Court, Stephen Czlileger has been
refusing to answer the simplest questions:
• Is Sarnaan v Zernik (SC087400) a true case of the California Superior Court?
The simplest answer wouldhave wen to allowme access through Sustain to Ike Books of
Court. the Index ofAll Cases.. Calendar ofthe Courts. etc. Thai is still denied
• Is tbere or isn't there an entered, effectual Aug 9,2007 Judgment in Samaan vZernik?
1was robbed q(my homepurportedly pursuant to suchjudgment, But it is obviollS that no
such valideffectualjudgment exists.
• Is there or isn't there 8 judge duly assigned to SamRan v Zernik ?
Jud..r;e Terry Friedman still thefiZe. andcontinues his racketeering/rom the bench
2) Martin Berg- Da;]y Journal, and ROllakl GeIJrge - ChiefJust;ce ofthe California Supreme Gourf
Mr Martin Berg, Editor of the Daily and the Honordble Ronald George, ChiefJustiec, California
Supreme Court, have failed to respond as well. The questions addressed to them was and is:
• What was/is your role in the desigo, inslaUatioli, maintenance of Sustain in LA Superior Court?
-Doyou hold tbl; operation of Sustain, as seen today, in compliance \\ith the Jaw?
• Do you t'Onsider that a public disclosure on your part in this mafterls required?
• Page 5f7
November 28, 2008
3) CountrylVideand Bank ofAmerica
After the change ofcontro] in Countrywide, I expected that Bank of America Corporation would put an end to
this shameful of which J have infonned the board ofBank of America Corporation months in aqvance.
How\.,'VCr, even after the change ofcontrol, Bryan Cave, LLP has continued the harassment, as usual. And
yet, in recent days it has refused to answer a very simple question:
• What is the identity of the part)' represent by me in court in recent months?
COW1trywide 's party designalionhas all along been one a/the cardinal signs thai lhis
litigation waf fraud: Countrywide chose to be called "Non-Party", while lhe court used
party desif:,Tf1ations dujmlr - PlainrtfJ, Deftndant, Intervenor. Objector, etc.
Regardless: Bryan Cave must know who signedthe engagement, andwho is paying the
bills.
] therefore also ask the following from Bank ofAmerica Corporation:
• Would Bank of America Corpordtion ensure that no further abuse is perpetrated in the name of
Countrywide?
• Would Bank of America Corporation review the records and provide compensation for damages J
suffered through Countrywide's actions?
4) USCG'redit Union
TIle final steps in the theft ofmy home in December 20..Q1, could never have happened without help from v,ithin
USC Credit Union, for no reason at all, and in violation ofthe USC CU fiduciary duties to their depositor!
member.
• What was the justification if any, for the conduct onISC CU, in colluding in the theft of my home
by the Enterprise?
• Why is the USC CU refusing to implement basic standard procedure consistent with "'sound
banking principles"?
5) City OfBeverly Hills ami its Police Department
During the harassment that preceded the theft ofmy hOllse, I approached the Beverly Hills Police DepartmeJ1t for
protection, on several occasions. At all times, the Beverly HillsPoJice Dt.-partment absolutely refused tJ:) provide
protection, or to no matter how strong the evidence produced in support ofmy complaint was. This
mtmth I provided the Mayor and City Comcil a short overviewof the situation. TIle following questions are
addressed totOO Mayor and the City Council ofBevc:r1Y Hills:
• Regardless of the conduct of the Distrid Attorney, was therelis there any justification for tbe refusal
of the Beverly HiUs Police Department to protect me in this case?
• Would the Mayor and City Council tak-e immediate action to compel the poJice to perform its duties
and provide report of its investigation JiS soon as possible?
6) Bet Tzedek- the House ofJUj·tke
Three ofthe individuals who p'layed central roles in this story ofreal estate fraud, held the highest positions in Bet
Tzedek: Sandor Samuels - fonner president, David Pasternak- fonner president. Terry Friedman - fcmner
executive director. Together they can be seen as a representation ofthe type of wide-spread corruption that
undennines the justice systemin Los Angeles County -collusion ofcorrupt corporate lega] counse1s, corrupt
attorneys in private pnl.t,1ice, and conuptjudges.
• Would Bet Tzedek respond and inform me reg-.mJiog any internal procedure for dispute
resolution?
• Page6f7
November 28, 2008
E. The scope snd cost of the problem - organi7.ed crime in 21
st
century
Abuse of civil rights in Los Angeles County is on a scale that is beyond comprehension. "The only way to
rationalize the situation, is that Los Angeles County was abandoned by the U.S. Government. Federal
agencies lost control to the Enterprise.
Such conditions must not be allowed to persist. The cost of this Enterprise to society in SoutllernCalifomia
and the economy of the United States is prohibitive. J;he emergence of Countrywide as a corrupt
organization and the sub-prime crisis that followed, could not have taken place had it not been for the
generalized, fraud-friendly, crime-permissive conditions established in LA County by the Enterprise. And
the cost to the U.S. economy of the sub-prime crisis alone is in the trillions ofdollars.
This case shows .fudge Jacquelinc Connor, representing corrupt government, as tile controlling party in a
joint effort of Sandor Samuels and Countrywide -- a corrupt mega corporation, small time practitioners of
white collar crime such as Nivie Samaan, Jac Arre Lloyd, and Victor Parks, facilitated by large law firms
sllch as Sheppard Mullin and Bryan Cave, LLP. And in the face of such onslaught of a fraud machinery,
all others yield and join the winners in a frenzy of frauds: lawyers, escrow, registrar/recorder, realtors, and
consumer banks.
This is the true face of organized crime in the:21 Sl century in LA County. California. TIle coHaboratiOli of
Victor Parks,Jae Arre Lloyd and Countrywide in their fraud against the U.S. Government in submission
of loan applications, was coordinated through the computer networks of Pacific Mortgage Consultants,
and the mega fraud of Countrywide itself- in underv,rriting of unworthy 1()an applications, was
masterminded by Edge -- Countrywide's underwriting moniwring system, which in this case vvas seen
operating as the camouflage system for violation of banking regulations. And the overall coordination of
this consortium of crime was eKertedthrougb minute orders produced in Sustain the SuperiQr Court's case
management system, provided by the free press ... the Daily Journal.
Andt:1cing such massive power, United Title, Mara Escrow, Coldwell Banker and Michael Libow, and
USC Union, and the office of Registrar/Recorder, Att Charles Cummings, Art Zachary Schorr, and Att
Thomas Brown, all gave in, hoping to get some of the crumbs.
Jacqueline Connor derailed the rirst Rampart Trial in 2000, in public defiance of the Tule of law and the
power of the U.S. Government. Response of the U.S. Government was inadequate and simply non-existent.
The Consent Decree formulated under the watch of Alejandro Mayor,kas, then U.s; Attortley for Central
District ofCalifomla, falsely put the blame entirely on the LAPD, and left the LA Superior Court free to
continue the wrongs. Therefore. ineffectual office or the Overseer was made certain. As aresult, local
brdnched of U.S. agencies are powerless in LAtoday against the Enterprise.
F. Pro[}()sed Solutions:
Solution must come by way ofthe U.S. Government.
With belp from the courageous Honorable Diane Feinstein, Senator, and the Honorable Oiane Watson.
Congresswoman, I pressed the FBI and US Department of .Justice to take action. I argued that the
minimal, most effective way to approach this situation is to enf'Orce Common Law/First Amendment rights
in Los Angeles County, pursuant to Nix(jn y_ Warner [nc., 435 U.S. 589 (1978) where the
u.s. Supreme Court affirnied "the common-law rig17tto inspect and copyjudicial records rI. Los Angeles
County is unique, 1 hope, in the United States in concealing the Books of Court - the Index of All Cases, the
Calendar of the Courts, the Registers of Actions, and the Book ofJudgments. I believe that such a simple
step as seizing the computer system of the court and opening it for public acCt.'Ss, as required by law, for the
first time in over a quartet of century, would be sufficient to effect a majbr change in the administration of
justice in LA County. first and foremost -- to the freeing ofthose falsely imprisoned.
I also fiJed a proposal with the Judiciary Committees of the House and Senate, and with the U.s.
Department of Justice pertaining to computers ofthe courts in the United States, meant to ensure that such
problems are not seen in any court in this country again.
• Page 7[7 November 28, 2008
G. Response by U.S. Officers to ProUQsed Solutions:
Mr Ken neth Melson, Director, U.S. Department of Justice, finally responded and refused to take action,
claiming concern about interference with ongoing investigaiion by the FBI. Mr Kenneth Kaiser, Assistant
Director, Criminal Tnvestigation, FBI, finally responded and refused to institute an investigation,claimiug
iliat I have never demonstrated ''federal investigational jurisdiction"
R. R£Quest for your Immediate response:
Please let me know howyou would help mitigate damages, totaling over $2.0 miTIions today. The property is still
listed in my name, but wrongfi.llIy occupied by Nivic Samaan and Jae Arre Lloyd.
Public policy considemtions, underlying the personal matter discussed here, must ensure that the issues are placed
at thc highest priority with the incoming administration.
Beyond the property of an individual, this matterreprcsents the abuse of9.5 millions who live in LA County and
have been abandoned by the U.S. government in the past decade, allowing the LA Superior Court and its judges
to engage in abuse of LA County citizens, under colorofJaw. It is exactly this type ofabuse that is the duty o'fthe
U.S. Government and its officers to protect U.s. citizens against.
We who live in LA CoUllty are deprived of due process, deprived ofaccess to the courts, and deprived of'fair trial
for over a quarter ofa century.
The continued false imprisonment ofthosc who were shown to have been framed must not be allowed to
continue. It is a disgrace to allU.S. citizens, and all people ofgood faith.
Signed on Thanksgiving Day, the 27
th
of Novemher, 2008, in Los Angeles County.

"'v"IIly>lgnodbyJ<><opnZ,mJlt

) • .:;:-/l1'J4S4ll<""...."""""
100$.1 t.18 ·()i'W
.Joseph Zemik
TIME IS OF THE ESSENCE!
RESPONSE REQUIRED BY 5:00PM, FRIDAY, DECEMBER5, 2008
, Copies of the grant deeds produced by.Att David Pastemak,former president of House of JuStice - Bet Tzedek.
purportedly approved by the LA Superior Court, and then filed in the·office of RegistrartRecorder, can 'beviewed at
http://www.inprot>erinla.comlO7-12-17-oplnion-!etter-fraud-in·want-deeds-s.Qdf
The fraud in such actions was confirmed by an opinion letter of Veteran FBI agent, James WOOicl<, commended bytheU-s
Congress, the U.S. Attorney General,and the Director of the FBI, for his contribution to stemming public COmJption in
Califomia government.
CC:
James WediCk
Judiciary Committee ofthe U.S. House ofRepresentatives
Judiciary Conunittee ofthe U.S. Senate
Office ofPresident Elect
Office{)fVice President Elect
H .LIHIHX3:
.Joseph Zemik DMDPhD
(801) S9E-0917 Email: jz1:2345@earthlinknet
.
. by JoH-ph a,ttik-
ON;cnoJc••ph
Zcrnlk,..
) . .....6'*'2345..

(aUS
Dale: 1OQ8.12:11
11);J?;J6..oe'OO'
" Jurig.esha,' be fafthfulto tf1e Jaw... '!
Car Codt! Jud EtIJIcs.JfJ(l)
"The rule ofJaw must never be C01Tfusedwfth tyranny of the courts"
Anotwm<>u&
TIMELYRESPONSE REQUESTED
) December 11, 2008
,j Teresa M. Brenner
Associate General Cmmsel· signer ofSECfilings
Kenneth D. Lewis
President, CEO. Chairman
Timothy Mayopou)os
BOA General Com]j'e/
William .J Mostyn III
Deputy General Counsel - Si}!;l1er qfstatements to share holders
BankQfAmerica CorporatioIi(Bm'lk: ofAmerica)
100 N Tryon St
NCI-007'-56-11
Charlotte, NC28255
By FM; (704)370-3515
By Email: ..AttentionBrenner.Lewis.Mayopoulos.Mostyn ..<[email protected]>.
"Attention i, <[email protected]>
HE: COUNTRYWIDE. RACKETEERING UNDERTHEGUISE OF LlTlGI,\TION IN LOS ANGELES.
NOTICES, RF.QUESTS AND DEMANDS TO MlTlGATE DAMAGES.
RESPONSE BY BANK OF AMERICA BY TUESOAY, DECEMBER 16,2008; 5:00PM.
Madam & Sira,
1am the viCtimofteal estate fraud perpetrated by CountryWide Home Loans, Inc; San Rafael
Branch, Countrywide Legal Division, and others, through fabrication of records, which
started in early 2006. The. scope and severity of wrongdoing in this case makes the report of
"recreated letters" filed as evidence in Pennsylvania in Janmuy 200S
I
) and the cases dOcumented
in judge Jeff Bohm's (U.S.·Court; Texas) opinionfrom·March 2008,2 rebuking Countrywide
Legal Division litigation practices, paleinc6inparisoiI.
My attempts last week to establish who is tlUlyauthorizcd by Bank of America as-c6uriSeJ in
matters pertaining to me was unsuccessful, as noticed below. 'therefore, this comnllmication is
sent the Lcgal'Departmentand ChairlPre:sidentfCEO.
Below please seeNotices, to reliably infonn you ofpertinent issues in thismatter, as well as
Reqtiestsand Demands, expe.cted as part of your corrective actions and mitigation ofdamages.
. 1 _Reports pertainIng to "recreated filed as by Cou.ntryWide in Pennsylvania court. ..' .

2 Opinfon of JUdgeElohm (U.s. Court, Texas) rebuking Counti'ywide'slitigationpraclices

• Page2l12 11,2008
A. NOTICES
L Please Take Notice: Harassment and Intimidation bv CountrywIde continues eventodav.
Having had rio business with CountryWide, and initially not even knowing about
Countrywide' s involvement in the case, it took till December 2006. before I discovered the
fraud and requested directly ftom MrSandor Samuels and Mr Angelo Mozilo to stop it,
which they refused to do.
Instead, Countrywide started Olt July 6. 2007 a campaign of harassment andint-imidation.
Sand{)r Samuels dec)aredhimself"Parly ofinlerest in the case in early BtyanCave,
was retained to represent COimtIywide, and counsel started· appearing in this case
on arcgular basis, without any defined party designation. As it turned out; several of the
jUdges ofthe LA Superior Court were <;Usa Mr Samuels' personal friends.
I trust that BOAwould never knowingly continue in such conduct as took place under
previous leadership of Cotmtrywide. I am eager to bring this sordid tale to an end and move
on with my life. Therefore I am again \vriting to notice you and demand your attention to
this serious matter, nowunder your watch.
flooked forward to the takeover by BOA, sinee Iexpeeted it to be tbeend·of my
harassment and abuse. I therefore also sent Ms Brenner, Mr Lewis, Mr Mostyn Hl, and
others on the Boardpersonal notices in early Febroary1008; alerting you to the situation in
this matter, and requesting that you take eareofthis matter as soon as change ofconttolwas
completed.
In response, I received a non·specific letter,dated Feb 18.2008, signed by Regina Parker.
staffofthe Chairman's o'fficc.i
2. Please Take Notice: Currentdintradietions regar.ding identity o{couflSel (ot C01Jnt!lrwide,
whichmlistbe feso/vet!
And once the change. ofcontrol Was· completed, harassment and abuse continued, just as
before, under the guise 'Oflegalacclon in LA Superior Court. . .
lwould stin Hketo believe thatwhat is taking place in recent months ,is without your
knowledge, and there were gOod feaS:On to su:Spectso, because the court, among its most- .
recentftauds, was again trying to hide the involvement of COUritrywide, by deleting the list of
parties and counsel from formal eourt notice,s, out of compliance and in violation of the law.
at the end of last week I caHedtheoffices bfMrMayopoulosandotherS in the
Legal Depart:ni.ent. inan attempt to con:f1rtn whether those who represented themselves as
CQunsei for DOA, while going on with racketeering in the eourtroomin LA - Art John
Amberg andlenna Mbldawsky, bfBryanCave, LLP- are indeed authorized by BOA.
Indeed,. your Legal Department had no knowledge· ofengagement ofBiyan Cave for
representation ofBOA inthis matter. your Legal Department mstI1.lcted me that only
Mr Todd Book ofCountrywide Legal Division was authorized toiepresentBOA inthis
matter. Your legal departmentalsoert'ooeoUsly noted that there was.pending matter-
2 LeUer by Regina Parker, dated Ft:b 1'8, 2008. Offoce Qr Bank of Nneik;a Chair;

• Page 31102
December 11, 2000
litigation by me against COlmtrywide, ancttherefore against BOA, which prevented further'
direct c-ommwucationbetween.me and the BOALegal Department. lbetieve that such direct
communication could bring this travesty to an immediate end.
SOO11 afterwards, I tried to conui.1Wlicate with Mt Book, following instructions of your Legal
Dep<utment. Mr Book responded by!1l1se1y claiming lha.t a) I wal) pruhibiloo by a purportcd
court order from commuriicating with him. Stich condition would ofcourse be absurd, ;Since
this was protected speech, him being Counsel for Countrywide designated by BOA. Legal
Deparum:nt, and Tam a pro :st: deJendanL in this case. Mr Book -also purportedthat I was only
allowed to commW1icatc with Bryan Cave, LLP.
Obviously, Mr Book'semail, which came within 24 hours from my phone cotiUTIunications
with your Legal Department was diametrical Iy the opposite of what I was instructed by your
offices.
a. Please Take Notice: All three individuals listed above: Todd JaM Amberg, and
leona Moldawsky Were deeply involved in the racketeering against me in recent years,
under Countryside's previous leadership. Accorgingly,all three oftbem major
conflicts of interest in tbls case, since they ate likely to be personally liable pursuaIit to
both civil and penal codes (both Caiifomia and U.S.) in this matter-Moreover; all t:bree
have allegiances with Mr Samuels, Who personally led tbe racketeering in this case, and
who still lists himself as "Person in Intcrcst
lJ
• He probably has the highcst liability in this
case. I consider the conduct ofTodd Book,. fohn Amberg; lenna Motdawsky, and Sandor
Samuels as at present an attempt to keep-their turfregardless ofllie change ofcontrol and
the ehange of guiding policies that carne with it. r doubt that they best se.tve the interests
ofBOA in this matter.
b.Please Take Notice: I hold that continued assignment of f\11Y ofthese individuals to
represent BOA in my case 1S inconsistent wjth the stated poliCies of the BOA Legal
.Department, -claiming adb:e:renceto ethical conduot,
3.Th!!! in fhif 'ndruling-Judge Friedman, WhOplitpotfs authoritv in
this case at ptesent;had been tie(lto Samuels, andwitliout exception. had1t.O valid
(lSsignmelltqrde1'S. as requitedbylaw..
a. Please Take The purported Judge hi this case, Terry Friedman, is an old friend of
Mr Samuels. hut to djsquali:fy,.and also refusesto'plPv1de any
statement on tbe.record,.asrequired by California Code:ofJudicial Ethics. Canon 3E(2);
relative to the nattireofhis relationship with Samuels ahdarty rmanciaJ
benefits that neor farnilymembers with him-may bave received from Samuels
and/or Countrywide.
b,Please Take Notice: Judge.Friedman, who is holding the court me in this casefor almost
a year now and acting as presidingjudge for all purposes, is doing so with noassignmenr
order,like all otherjudges in this caSe. out of compliance and in violationof the law.
• Page4/12 D.ecember 11 . 2008
c. Please Take Notice: Disqualification/recusal of Judge John Segal, prior to that, directly
involved Countrywide. 1n his recusal statement JJudge Segal claimed that Countrywide
was "merely a w'itness"in this case. But elsewhere in the same statement, Countr)'vride
was once designated Defendant, and another time yet another party designation.
d. Please Take Notice: Judge Segal, who held thecoUlt me in this case from October 5,
2007 to December 4. and acted as presiding judge for all purposes; never had the
case duly assigned t(l him by order ohhe Supervising Judge, as required by law,
e. Please Take Notice: Judge Allan Goodman, who held the court file in this case from Sept
I I, 2007 to Oct 3, 2007, eventually recused citing his ".• longstanding t;/ose personal
relationship willI tll·eGeneral Counselo/Counlrywide
4
" - Sandor Samuels.
f. Please Take-Notice: Judge Goodman, too, had no assignment order to this case.
g. Please Take Notice: Judge was first disqualified for a cause in open courton July 12,
2007, and the causes listed mostly referred to her treatment of Countrywide in the court,
beyond preferential - out of compliance and in Violation of the law. She deceitfully
ignored the Disqualification for a Cause,ruling it "vas an untimelyPeremptol)'
h; Please Take Notice: Judge Connor was disqua:Iified for a cause a second time on Sept 10,
2007, agaitl,- roUGh ofthe Statement ofDisqual i fication referredto her treatment of
Countrywide in court.
l. Please Take Notice: On Sept 11, 1007., a day after her second disqualification fora cause,
and. teCusal, Judge Comiot dooeitfully entered a minute order of a fictitious hearing that
was never a ruling that to the effect that there was no fraud in
Countrywide's fraudulent subpoena productionS.
j. Please Take Notice: Judge COMor,too, had no assignment order to this case.
k.. Please Take Notice: [appeared before each and every one of these judges with a request
that they notice me oftheirassignmcntorder to establish their jurisdictional authority. All
denieq such rcquest&. ..
1. Please Take Notice: several times before Supervising Judge Rosenberg with a
request that he duly issue Assignment Order to judges presiding in this case, as required
by law,but he denied, all such requests. . .
3 JUdge Segal's fra udulent RecusalStatement can be viewed at pages -183- at seq of the compiled minute orders of
$amaan v Zernlk (page number 4#,. refers to number right of each page of the record). Such statement opened with
a fraudulent claim: 'Although judgment was entered on the complaint in lhisaction "afore this actionwas assigned to
the undersigned judge... '. In fact even today, tho office· pf Presiding Judgo and the Offioo of the Clerk ofthe Court
refuse to certify the eXistence cif an entered jUdgment in this case, and also refuse to certify the non-exiSlenteOf
entered jUdgment In this case. The true facts in this ma'tt&r are that LA County Supl9rior Court 01) ionger keeps a Baok
ofJudgments (either electronic or paper-based), in violation ofthe law, and also in violationofits own L06alHules of
Coort.
.
JUdge Goodman ReclIsalstafement",...ambe vlewedcat page-9S- et seq (jf records.hnked In3) above..
$ Fraudulent minute order entered l:lyJud.ge Connor tlrJ Sepi 11, 2007. after disqualification and recusel Or:lsel1t10. '2007,
purporting to reoord.a fictitious hearing ahd fictifiousrulJngthat fouoo·nofraud in Couhtrywide'ssubpoenarecords; pages-
81- of linked in 3) above
• Page 5112 December 11 , 2008
4. Please Take Notice: No active litigatwnand!or pending nuztters ,exist bv Zernik against
BOA/COWl1lVwide at present in either ofCaJifnrma .orCl..:.({. court... .contrary to what
BOA waS probably misleadinglvinfonned.
I repeatedly heard it stated by phone by individuals in your Legal Depart:n:i.ent that I was
involved inlitigalion agdinstCuuntrywide and/or Bank of Arnerica. Such are false
statements that I wanted tooorrect.
Please be infonncd that currently there is no valid litigation by Joseph Zemik against Bank
of America and/or its subsidiary Countrywide Home Loans, Inc in either California
Superior Court or in U.S. District COllrt:
a) Samatin v Zernik (SC087400) was all along an"Enldrprise Case" of the Judiciary, and
not a genuine California SUperior Courtcase
,
as indicated by the evidenee. The office of
Presiding Judge and the Office of the Clerk. of the Court, as well as their counsel refuseto
answer any questions on th.issubject in recent months, in fact confinning such designation
ofthis case. Hadthe case been a true Superior Court Case, no valid CHL litigation would
have been in existence either, sin.cc CHL corruptly assumed the designationof"Non-
Party", under which the Judges allowed it to bring actions against Zcmik,butdcnicdZcrriik
the right to bring actions against CH1. Such obviously could norbe validlitigation ofany
US. court system.
kJ Zernik v Connor (2:2008CV015SOJ Litigation in U.S. District Court, LA, was
invalidated from day one, when thepro sa clerk refused to accept and-sign valid summons,
and instead, In violation of the Rules (jfCOUi1,..utsisted puproducing and signing hiSQ\vn
summohS - which were defective; When Z:ernik caughttbis dishcmesty,and tried to present
thecleik with valld slirritnohs for the second time, same clerk again tefusedto issue the
to dQ sounder order of Magistrate Judge Obviously
litigation with no valid swtUnCinScannot be vaiid litigation. Other defects noted in this
litigation, .whiCh indicate tlmt Judge Phillips and Judge Woehrle never cons-ideted it true
valid litigation are: .
- Failure to conduct initial case conference
- Failure to list corporate entities as requke bylaw
- Failure to acljudicate motions.
- Gag order set on aUZernik's filings incourt.
5. Please TakeNotice: The ofCHL ;ninatfef-desij!Jtafea
Samaan v Zernik was founded in fraud andObstrllctionIPerversionofJustice from
begifming to emL
'Lbe fIrst appearance ofCHL inSamoan vZemik was onJuly 6; 2007, for a gag order., in aft
exparte application by Bryan Cave, LLP
I
filed with Judge Jacqueline Connor, and heard
when the court was dark, off the record and (lff the calendar,. In its papers Bryan LLP
listed Countrywrdeas ''NOH-Party'', but the court: listed it on that day as "Plaintiff'.
• PageG/12
December 11 , 2008
The most recent scheduledhe.aring in Samaan V Zernik was on November 21,2008, and
there too, CHL appearance was part of fraud by the court, aimed at Obstruction/Perversion
ofJustice, In this latestproceediilg, the coUrt sent notice to only 3 parties: Samaan, Zemik,
andCHL. Two other parties were omitted, out ofcomptiance with thelaw. And emwas
added, also out ofcC)mpliancewith the .Iaw,and this time was designated as "J)efendant."
To hide the fact that CHL was noticcdas such fraudulent party, the Court used defective
notice fanTIs, and omittc(j the mailing list required by law in valid notice.
For the past year and a half the court .has engaged in such fraudulent litigation practices
relative to Cm...
6.PJease Take Notice: Shamlitigation under the designation Samoan VZernik in the LA
Superior Coy.rl was-and lY the outcome o(ex/etrsive conspiracy by CHL San Rafael
Bral1.ch and its Manager -Maria McLaurin, Counflywide's Legal Divisiott, includingAtt
Sandor SamuelsandAll Todd Book. Bryan COJle, LLP {counsel (Pr putpd11ed "Noil"C"
Counirvwide). Samnan lourpol1edplai;lti(f) ,.KeshavamlCo.unst!/ for purported
plairiiiffl• .JliiIges CONnor, SegaL FriednulIt, andRosenberg judges in
litigatiOn ofthe CaliforniaSuperilJr COidtJ. pworfedCourt OffICers Da.vidPasfernak,
Gregory 0 'Brien, and others.
A reasonable case as ""hole, wOljlq mo$t likely conclude that Judge
Connor participatedin the design of this fraud even before the complaint was
the complaint was made to tnatebJudge Coru;lor's fraud on enUy ofjudgment,anU it isnpt.
likely that the attomey inVolved, Jay Steih,was familiar with all the technical details (jfthe
fraud. Onthe oilier hahd,already in the first proceedinl;, on J3i:n.iary 30,2006, Judge
Connpr was in extensiveproducljo:nof fraud\;llent litigation records,. for her own
Assigrtrtlent Order (backdated by 3tnonths), for Denmrrer(secretly disposed/voided), and
for Ihitial Case offthe record).
While the jUdiciary was engaging in obstructionJpetversion ofjustice, they were
colltiuuouslyinvoIved in attempts to pufblame on me. Fromthe second' time I came to
c(jurt. at least<>ne sheriff, sometimes t\yQ, and once - a sheriff with a Germahshepherd
were escorting. me everywhere in the cotltt:, asafonn ofharassment.
7. Please Take Notice: UpO;! review bv a ()()ntpetent court it is practiCallv certaIn tltat
various QS(1!!-cJs ofthe· conspiracy in Samaan vZernik, and in the (ailed TeNestate
tninsadio.n that precedcditils well. be deemed asviolation o(multfple-secuoirs of
.C«J;fortlw.Iln:dti,e us. Penal codesbv Ihe variOlIs incfudingsach
sectwhS where the.vibLatiohS ate countedas PreditatedActs pet RICO- '18 USC§1961"
1968.
--.
a. Conduct that is explicitly listed as Predicated Acts per RICO:
b. Rela1ing to maiffraud - 18 USC§1341
• Page7/12 December 11 , 2008
C. Relating to wire fraud - 18USC §1343 ,
d. Relating to financial in<:;tihltion fraud -lKTJSC §1344
c. Relating to obstrUction ofjustice - 18 USC §
f. Relating to tampering with a witness, victim, or aninfonl1ant - 18 USC §15J 2
g. Relating to retaliating against a witness, victim, or an infonnant - 18 USC §J 513
h. Relating to racketeering - 18 USC §1952
i. Relating to the laundering ofmonetary instruments IS USC §1956
j. Relating to engaging in monetary transactions in property derived from specified
unlawful activity -18 USC§1957
8. Plell$e Take Notice: CHL engagedin producfionof(raudulentrecords in te:oponse to a
legalsubnoena fiJrpfoduclioil ()fbattking records ;'11 Samtlan v Zernik-such subpoem!
purported to produce valid Underwriting@es o(Samaan's loan applications. while no
validloan applications existed in Countrywide.
a) Samaan failed to ever produce valid loan applications with Countrywide:
i. She refused to produce new loan applications \vith "reasonable explanation" for the
fraud inemployment data;
ri. She refused to add the loan fees, as required by Sernor Underwriter Diane Frazier's
Underwriting Letter ofOet 14, 2004, as required by Program Rules, and as
required by Corporate Underwriting Support (Mr Gadi);
iii. As demonstrated in Countrywide'ssubpoena, 8amaan faHed to ever obtain
Broker's Certification of Records. even when the loan applications werepreserit-ed
tot funding by CountIywide Bank in Jan1.ul:iy 2005. Fundulg was summarily
denied Samaan also admitted in deposition in2006
7
that Parks, purported Loan
Broker had nothing to do with such loan applications, She and her husband, lae
Arre .Lloyd took care Separately, already in October 2004, my
realtor discovered that Samaan was impersonating Parks infax corrummications,
and that, together with her failure to 6btain loan approval was the reason I c:an.ceUed
the transaction priortocompletiol1, Infact; in the whole CountryWide loan
applic3tionftle nota single authentic signature QfPatks can be' fOWld. Instead, the
loan shows two types off6rgedsignatures, which I designated a)
Northetn.,. and b) Southern California forgeries.
b) Through such fraudUlent subpoena pmduction, the Legal Division attemptedto create
fraudulent history Of Samaari's loan applicaiiolls.
8 Subpoena production by CHL can be viewed at:

i Sarnaan's deposition in 2006, Subpoena page40-41et seq in reference tathe role of Parks',·CHL's stated loan broker, or
lacKthereof in Samaan's loan Please note lhatin $amaah falsely stated that her huSband wase
loan brokeraswell,which he was not He was a "Ioanoriglriator".
htlp:lJinproperinla.comf06-07-1 .pdf
• PageB/12
December 11,2008
c) In such fraudulent subpoena production and in subsequent conduct; CliL was
deliberately and knowingly engaged inObstrtlction and PerverSion ofJustice, to
faciHtate real estate fraud by Samaan against Zeroik
d) Review of records from Subpoena production, which constituted the foundation for the
fraud in sham litigationofSamaan v Zemik -Specific Records
1. Real Property PurChase Agreement -falsely misrepresented as faxed by Parks
to COlmtrywide on Oct 25, 2004, 5:03pm.
8
jj. UnderwritingLefter - falsely misrepresented as faxed by Countrywide to Parks
on Oct 14, 2004,. or mid Octobcr2004
9
.
iii. Samaan's loan applications - falsely misrepresented as received for the first
time in CHL San. Rafael on October 12,2004'°.
iv, Underwriting records ofthe above loan applications - falsely misrepresented as
having arrived in CHI., San Rafael at times indicated in fraudulent fax header
imprints, which are part of the faxlwircfraud by Samaan
ll
•
9. Please Take Notice: Maria McLaurin '5 fraudulent letter and declaratiorn
12
filed;" L4
Superior Court to assist in Sanuiall's real esto.te fraud against Zerhik, were crucial for
success offhe conspifacv.
Maria McLaurin's letter andde.clarationsin Sarnaanv Zemik can be viewed at the link
be with annotations. without knowledge of the firte details, any with
minimaIlevel of underStandingofbanking procedures would fmd tile declarations fraudulent
on their faces.
B. REQUES1'8 & /)EMANDS
1. .Demand: Please take immediate action to mitigate damages in marterspertaining 1.0

Bank ofAmerica receivedfrrs! notieeofthis matter inearly February 2008!
8 Fraooulent RealPropeny PllfChaseAgresmenf .
hlfp;/Jinpropertnla.comI04-10-25-d0045,{;()Untrywide'-fraud-wnti"aet-regmipdr.
9 Fraudulent Undel"M"itir;JgLetter -
hl:tp:lliliproberjnla. cum/04-1Cl--26-countrtwide.fi>audulerit-uriderwriting-Ietter-s.pdf
.htfp:IJinprooerinla.comI04'1
tytgJfinprooerinla.com/()4..1Q-26:oDinion-letter-<:ounbywlde.underwriting-letter-oct-26-s.pdf
. Lpan . . .

-<i0c-40-samaari-fraudu!ent-loan-,applicalions-s.pdf
htlp:llinproperinla.com/04-09-27-opinion"letter-fraud-ln-loan-applications-signature-s.odf
ti Fraudulent underwriting records as part of wireffax fraud For examples see pages In CHL;s
sUbpoena production at·
hftp:[email protected]!l1tb7,.{)2-08=d>Unlrywide--fraUduleril-subpoena"productioh-ci§ Pdf
12. Fraudulent Mclaurin's letter Declarations;
ht1p;/linproperinlaco!'!V06-11-o9-doc-3a-'-¢OlJDfr:VWide-mClatltiMal$fBledaratiCinsodf
http://inprooerinlaGOm/06-11-00<!oc-3a:.2-count!VWide-mclaurin-:false-declaratiOl1s.pdf
• Page 9/12
December 11 i 2008
2. Demand & establish the identity ofcounsel for Country/wide in matters
pertaining to Jo.seph Zgrnik.
Such counsel must bewiJling to cotnmunicate with me. 1request that such counsel be an
individual who has not been involved in theracketeering in this case, under previousconttol
uf Cuunlrywide. who such cuunsel is. Doing su would allow immediate
resolution of the dispute between Joseph Zernik and Bank of America.. employing the
individuals listed above will not a\low such resolution to move forward, albeit - it is most
likely at the best interest ofBOA, Joseph Zcmik. Itrnay be fur Ule benefit of;ill who live
in LA County. if BOA supports steps requested byme below.
3. Demand: Pletl$e immediately withdraw the entire subpoena production orCHL,repudiate
ilas fraudulent on its race, and notive ti,e court andparties accordingly;
Although not every single page in the subpoena production was fraudulent:, the.package as a
whole was designed and organized to deliberately mislead the reader a1)d present the
subpoena as the true history ofSamaan's loans appIicationsand their underwriting.
4. Dt!l11imd: Please immediately withdraw tillY and a/IJJtfll.!./'S tJ!..ed in this ltUitter, which were
generated hI' MarklMcLaurin, COL San Rafael Branch Manager, and noticeihe court
and parties accordinglv.
Such papers are em frauds as detailed above and in footnoted paper filed in court.
Pleas'e wit/It/rawllnv andalloff1,OJJers filed bv· eR!, li party with neitlter
desigftlItum nor Iegalstandingt from die LA SuperiorCourl'sshamlitigation. designated
''Samoan v Zerhik", andnoticep,artles andtheCourtaccordinglv.
BankofAmerica Corporatibnmustl1ot be engaged in mcketcerirtg activities whereCHL
appears in Court with no deftned partydesigmttion, in sham litigation where the ofthe
Presiding Judge and the. Clerk ofthe Court, as well as intemaland external counselretained
for this matter. have all refused to answer in recent months· such bask qucstiOtiS as:·
a) Is Samnan v Zemik. a true case duly registered and indexed, as required by law for a
case heard by the Superior Court ejfCalifornia?
b) Is Saniaan v Zernik aease listed in the Calendar ofthe Courts, as'required bylaw fora
ease heard by the Superior Court ofCalifomia?
c) Is there a judge. duly assigned to this case, 113 required by law for a case heard by the
Superior Court ofCalifomia?
d) Is there a valid, entered judgment in this easel altertili:tivcly - is there no valid, entered
judgment in this case?
6. Demand: Please institute iTtletiUJUmdexterntlI review ofthis matter asreqllired by
banking andregulations. andtllso report 10 the aathoriti'e.r tegardingtlteCOnauclor
individllal$. when requiredto do so bylaw.
• Pago 10/12 December 11 • 2008
I will fully cooperate with investigative procedures duly instituted in compliance with the
la\-v.
7. Demand: Please issue to Zerhik declaratory statement. to the effect that:
a) BOA will take. immediate action tomitigate damages.
b) BOA will aSsunie responsibility for compensating Zemik for damages resulting froni
the past and present conduct of CHt,
c) BOA, in coordination with Zernik, will employ all necessary .legalll1easures to vacate
any and aU orders, decrees. judgments that appear in the record, and were purportedly
the products of litigation in the Superior C,ourt of California,
d) BOA, in coordination with Zemik, will employ aU necessary.legal measures to remove
,fium the records in the Office of LA County Registrar/Recorder the Grant
Deed 13fiJedthere by David Pasternak,Officer of the Court, on behalf of the LA
Superior Court.
e) BOA, in coordination with Zemik, will employ all necessary legal to
:immediately return thc property commonly known as '320 South Peck Drive, Beverly
Hills, 90212 to Zetnik's possession, and to compensate him for the unlawful
occupancy of his property since November 2007, and any and all damages related to
the use of the property or its condition vpon repossession.
f) BOA will ente.r with Zetnik inre:compensation for any inoidental
damages andreso]utionofthedispute stemming from Samaan v Zernik.
8. Request: Pteaseloin andfullv support requests already advanced by Zernik that the
Judiciary Committees ofboth House andSenateinitiate in the upcomiltgSl!Sswn
COngreSS urgent hearin.gs regarding: ..
a) Ongoing failure in LA C'..ounty, from the Rampart to
Countrywide.
b) Wide-spread pUbl1ccorrupti(}n and wide..-spreadabuse ofcivil rights inLA Cooory;
c)' Actions required inattempt to restore an adequate justice syst'effi in LA County
d) Actions required to enforce as well as Common Lawrights fo.t
access to judicial Records per Nixon v Warner Communications.
e) Actions require4 to affect immediate release of an those who were confmned as
innocent> but are falsely imprisoned in LACounty since before the Rampart scandal
(1998).
13 Fraudulenl deed wasfifed on Dec 17. 2007 by David Pastemak. without ever issuing Writ of Execution or Abstra<;t of
Judgmenl The fraud In SUd'l GraJ'ltDeed was confirrtled in notariZed opinion lelter of veteran FBI agent,
decorated byU.S. Cohgress, Far Director, and U,S. Attorney Geneml _Please viewat
httpJ6nprOOerinla.<;:omf07-12-17-opinion-letter.fraud-in:granl-deeds-s. pdf .
• Page 11/12
C. CONCLUSION
1·1, 2008
I h9ld th.at in due course itwould be fully recognized that Countrywide and some at the LA
Superior Court were the dominamforcesin.organized crime in LA County in recent decades.
Thatmuch can be gleaned even from the little evidenced in this letter. Such conditions are.
inherently tied to the installment of a fraudulent case management system at the LA Superior
Court circa 1985, and the concomitant elimination of Books of Court that are public records, as
required by law
l4
. I hope that BOA recognize such{acts and take appropriate actions, as part of
its control of Countrywide,and as part of its corporate
lhope that this dispute will be expediently concluded with efforts for the benefit of all those who
liVe in LA County, and particularly for whose basic rightS and Ii berties in
re.cent decades by the court and police. With the passage oftiinc such goal became
fur me, since it was the onlyexplanation Jcould fmd for thisefltlrely crazed cond,uct of senior
managemenl in u[lheSupenur Cuurt, anti: COUllScl from somt:: oflhc::
large.st law turns in the world - that it was aU meant to bring about the release o{those who were
falsely imprisoned and were and are the weakest and most vulnerable of all.
1hOpe that all issues related to Sainaan vZernikbe expediently resolved in amanner that would
also be hailed as a prime example f61' the contribution of one of'the.]argest corpOrations in the
U.S. to the resolution ofmajor public policy problems.
Sincerely,

Joseph Zetnik:
cc:
b. u.s. 'HoOse an.i:! Senate
14 The oo11usion of the <A>urt of Judge Connorsncl CHL In the perversion and obstructi.o!1ofjustice-, the pT"Oduetipn of
fraUdulent trial court litigation records, the role of the fraudulent management system and the denial of public
llccess to books of oourt,areall fully demonstrated In the Register of Connor prominently posted on
July 24; 2007 a l10tedeslgnating 'CHL ·REAL·PARnES IN' INTEREST", whiJeCountrywide- even today absurdlydeims to
be 'Non-Party', At the same tii'ne·Judge Connor tbrtly daims in d;>urt - .CHl. wasbehinp 1hi$ as
'C<lnsplratOlial Theory". That note was fraudufently back<latedto the absurd filing of July prior to the filing of
the c:omplaint lano my counsel wete denied aceess to any paper or electronic cburtrecords for:almos12 Years. Once'!wa$
allowedlo see copy of the Register of Actions (I am stilideniecHhe right to lnspectsndto copyeYen today), I discovered this
and many other frauds by the court in litigation records. as lseJsewhere documented. After I· documented this p8r!ieular fraud
bylhe OOurt·in papers filed in bOth the SupeiforCouitand in U.S.bislJidC6uit $udi ilbtesdisappeared from the Register of
Actions, with no notation. no (lune profuriCOfder. aI\dno notice·topar!ies.
htfp:iflnoroperinla.com/OO"bo-OO.la-sUp-d"register-cif-actions"s.,v"z.adulererations-QO=Page-one-sustain:-s:pdf
The overall criminal natute ofthe conduct of the court In this case, and its deliberate engagement in real estate. frauds,
Where L County Is routlnelylisted as first in the U.S., [spest evlde.riced by thefraudulant coveyanceof tiUeon JM.
protpertyby David Pasternak, by tl1a court
htlp:flihpropeiinla.<:omlb7-12
• Page 12/12. December 11 , 2008
on the JQdiciary, Subcommittees on Oversight and Administration of the Cowts, Senate Banking
and the House Fi.nancial Services Committee, Congressman/women representing LA County. This
letter is intended as part ofongoing requests to institute hearings on the tailed justice system ofLA County
Senator Joseph Biden
Senator Barbara Boxer
Senator Russell D Feingold
Senafor Diane Feinstein
Senator Patrick Leahey
Senator Charles Schumer
Senator Christopher Dodd
Reprtlseulalive Xavit:r BeiXfTd
Representative Howard Bennan
Conyers Jr
Representative David Drier
Representative Jane Hantlan
Representative Howard McKeon
Represcntative Grace Napolitano
Hilda Solis
Represcntlitive Maxine Waters
Representative Drane Watson
Representative Henry Waxman
c. Office of Federal TradeCommission
Complaint related the ofCountrywide described below, wa<;first filed in January 2007 with both Office
of 'Jh!if! Supervision and Office of Federal Trade Commission. Office of ThriftSupervisiou, compJetedits
investigatlon, against Countrywide theontyaffiliate under their jurisdiction in March 2007: The-Office of
Thrift Supervision cleared Countrywide Bank of any wrongdoing, since the Bankdenicd Samaan'sloan
immediately lIpan receipt. But the Office of Thrift Supervision, during it" investigation uncovered
substantial issues of concem with CHL,and accordingly fileed on its own vQlition, ac()mp.1aint with Qfficeof
Federal Trade Commission.
FromMarch 2007 and on, it was impossible to get any indication from Office of Trade Cotnmissi6n regarding
the dispositiQnof the investigation.:. Freedom oflnfonnation requestS were not honored eitber... 1he office was
obviously engaging. in sul>stantiat effort to conceal infonnation that by taw the complainant was .aHowed to
receive.
With this letter, I request thattne Officeoff;ederal TradeCom:missionprovide me with a copy oflhe complaint($)
in 2007. arid the final report of the respective investigations. [also request that the current letter $erveas my
complaiotligainst CRL, for severe abuse ofmycivil rights. for fraudulent conduct, and violations of
the law listed below.
d.. SeeUiities andE:xchllnge
Relative to matterS described above, whicht believe must be reported as material violations of law per Slitbanesc
Oxley Act of 2002, § 307. andtnc SEC Rule promulgated thero under 17
Alexa Kim
Executed on January 9, 2009, at Santa Monica, California.
Moe Keshavarzi, Esq.
Sheppard Mullin Richter & Hampton, LLP
333 South Hope Street, 48th Floor
Los Angeles, CA 90071-1448
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PROOF OF SERVICE
I am employed in the County of Los Angeles, State of California. I am over the age of 18
and not a party to the within action. My business address is 120 Broadway, Suite 300, Santa
Monica, California 90401-2305.
On January 9, 2009, I served the foregoing document(s), described as SECOND
SUPPLEMENTAL DECLARATION OF JENNA MOLDAWSKY IN SUPPORT OF
COUNTRYWIDE HOME LOANS, INC.'S MOTION FOR SANCTIONS AND OTHER
RELIEF AGAINST DEFENDANT JOSEPH ZERNIK, on the interested party(s) in this action,
as follows:
Joseph Zernik
2415 Saint George Street
Los Feliz, California 90027
[gJ (BY OVERNIGHT DELIVERY) I deposited in a box or other facility maintained
by Federal Express, an express carrier service, or delivered to a courier or driver authorized by
said express carrier service to receive documents, a true copy (or original) of the foregoing
document to the party listed above, in an envelope designated by said express service carrier, with
delivery fees paid or provided for.
David J. Pasternak
Pasternak, Pasternak & Patton, LLP
1875 Century Park East, Suite 2200
Los Angeles, California 90067-2523
Robel1 J. Shulkin, Esq.
The Law Department
Coldwell Banker Residential
Brokerage Company
27271 Las Ramblas
Mission Viejo, CA 92691
IZl (BY MAIL) I placed a true copy of the foregoing document in a sealed envelope
addressed to each interested party as set forth above. I placed each such envelope for collection
and mailing at Bryan Cave LLP, Santa Monica, California. I am readily familiar with Bryan Cave
LLP's practice for collection and processing of correspondence for mailing with the United States
Postal Service. Under that practice, the correspondence would be deposited, with postage thereon
fully prepaid, with the United States Postal Service on that same day in the ordinary course of
business.
I declare under penalty of perjury under the laws of the United States of America and the
State of California that the foregoing is true and correct.
SMOIDOCS715392.1 3
SECOND SUPPLEMENTAL DECLARATION IN SUPPORT OF
MOTION FOR SANCTIONS