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Case No 09Case No 09Case No 09Case No 09----A827A827A827A827
IN THEIN THEIN THEIN THE
SUPREME COURT OF THE UNITED STATESSUPREME COURT OF THE UNITED STATESSUPREME COURT OF THE UNITED STATESSUPREME COURT OF THE UNITED STATES
________________________________________________________
RICHARD I. FINE,
Petitioner,
v.
SHERIFF OF LOS ANGELES COUNTY,
Respondent.
________________________________________________________
On Petition for Writ of Habeas Corpusto the Ninth Circuit Court of Appeals
________________________________________________________
AMENDED VERIFIED MOTION TO INTERVENE
JOSEPH ZERNIKIn Pro Se
1853 Foothill BlvdLa Verne, CA
Mail:PO Box 526La Verne, CA 91750Phone:323.515.4583Fax: 323.488.9697
Email:
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ii
"The basic principle of the Great Writ of habeas corpus is that, in acivilized society... if the imprisonment cannot be shown to conform withthe fundamental requirements of law, the individual is entitled to his
immediate release". Fay v Noia (1963)
Table of ContentsTable of ContentsTable of ContentsTable of Contents
Table of Contents ii
List of Appendices iii
Table of Authorities vi
Notice of Motion & Motion 1 1 1 1
A. Points & Authorities on Motion to Intervene 2 2 2 2
B. Points & Authorities on Intervention Per Se 6 6 6 6
C. Claims 16 16 16 16
D. Case Status 19 19 19 19
E. Request For Intervention & Prayer for Relief 20 20 20 20
Certificate of Compliance 23 23 23 23
Statement of Verification 24 24 24 24
Proof of Service & Certificates of Mailing 25 25 25 25
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iii
List of AppendicesList of AppendicesList of AppendicesList of Appendices
Appendix IAppendix IAppendix IAppendix I: Notices to parties of intent to intervene and attempts toNotices to parties of intent to intervene and attempts toNotices to parties of intent to intervene and attempts toNotices to parties of intent to intervene and attempts to conferconferconferconfer
a) Attorney Paul Beach - Notice and requests for clarifications
b) Sheriff Leroy D Baca Notice and attempt to confer
c) LASC Notice and attempt to confer
d)d)d)d) Richard I Fine Notice and attempt to confer
Appendix IIAppendix IIAppendix II Appendix II: Table form summary of cases of PetitioTable form summary of cases of PetitioTable form summary of cases of PetitioTable form summary of cases of Petitioner Richard I Fine andner Richard I Fine andner Richard I Fine andner Richard I Fine and
[Proposed] Intervenor Joseph Zernik[Proposed] Intervenor Joseph Zernik[Proposed] Intervenor Joseph Zernik[Proposed] Intervenor Joseph Zernik
Appendix IIIAppendix IIIAppendix III Appendix III: LA County Sheriffs DepartmentLA County Sheriffs DepartmentLA County Sheriffs DepartmentLA County Sheriffs Department: False arrest and booking: False arrest and booking: False arrest and booking: False arrest and booking
records re: Inmaterecords re: Inmaterecords re: Inmaterecords re: Inmate Richard I FineRichard I FineRichard I FineRichard I Fine, #, #, #, #1824367; Inmate Joseph Zernik,1824367; Inmate Joseph Zernik,1824367; Inmate Joseph Zernik,1824367; Inmate Joseph Zernik,
####2235341, numerous other inmates2235341, numerous other inmates2235341, numerous other inmates2235341, numerous other inmates
a)a)a)a) January 8, 2010 Records that were provided by the Sheriff in
response to inquiry by Los Angeles County Supervisor, the Hon
Michael Antonovich.
b)b)b)b) Los Angeles County Booking Records, re: Joseph Zernik, Booking
#2235341
c)c)c)c) Zerniks Complaint, filed with the Sheriffs Department, alleging
unlawful arrest and jailing and other violations of the law.
Appendix IVAppendix IVAppendix IV Appendix IV: LA County Sheriffs DepartmentLA County Sheriffs DepartmentLA County Sheriffs DepartmentLA County Sheriffs Department:::: Marina v LA CoutyMarina v LA CoutyMarina v LA CoutyMarina v LA Couty
(BS109420)(BS109420)(BS109420)(BS109420) false records pertaining to arrest and imprisonment offalse records pertaining to arrest and imprisonment offalse records pertaining to arrest and imprisonment offalse records pertaining to arrest and imprisonment of
Richard FineRichard FineRichard FineRichard Fine
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iv
a) March 4, 2009 Removal/Remand Order
b) March 4, 2009 Judgment and Order of Contempt
c)c)c)c) LA County Sheriffs Department -Removal Order for In Custody
Defendant blank form of
Appendix VAppendix VAppendix VAppendix V: LA County Registrar/RecorderLA County Registrar/RecorderLA County Registrar/RecorderLA County Registrar/Recorder: Recording of a: Recording of a: Recording of a: Recording of a Grant DeedGrant DeedGrant DeedGrant Deed
#20072759874, which was opined as fraud#20072759874, which was opined as fraud#20072759874, which was opined as fraud#20072759874, which was opined as fraud
Opinion Letter of highly decorated fraud expert, FBI veteran James
Wedick
Appendix VIAppendix VIAppendix VI Appendix VI: LASCLASCLASCLASC:::: Samaan v ZernikSamaan v ZernikSamaan v ZernikSamaan v Zernik(SC087400)(SC087400)(SC087400)(SC087400) false and deliberatelyfalse and deliberatelyfalse and deliberatelyfalse and deliberately
misleading judgment/appealable recordsmisleading judgment/appealable recordsmisleading judgment/appealable recordsmisleading judgment/appealable records
a) August 9, 2007 Judgment and August 9, 2007 Order Granting
Summary Judgment;
b)b)b)b) November 9, 2007 Order Appointing Pasternak Receiver;
c)c)c)c) November 21, 2007 Order like unlawful detainer after entry of
judgment
Appendix VIIAppendix VIIAppendix VII Appendix VII: LASCLASCLASCLASC:::: Samaan v ZernikSamaan v ZernikSamaan v ZernikSamaan v Zernik(SC087400)(SC087400)(SC087400)(SC087400) exerpts from Januaryexerpts from Januaryexerpts from Januaryexerpts from January
7, 2010 Register of Actions in Samaan v Zernik7, 2010 Register of Actions in Samaan v Zernik7, 2010 Register of Actions in Samaan v Zernik7, 2010 Register of Actions in Samaan v Zernik
Appendix VIIIAppendix VIIIAppendix VIIIAppendix VIII: LASCLASCLASCLASC: Correspondence with the Court re: Access to court: Correspondence with the Court re: Access to court: Correspondence with the Court re: Access to court: Correspondence with the Court re: Access to court
records and Rules of Court pertaining to Entry of Judgmentrecords and Rules of Court pertaining to Entry of Judgmentrecords and Rules of Court pertaining to Entry of Judgmentrecords and Rules of Court pertaining to Entry of Judgment
a. June 3, 2008 Letter by Assistant Presiding Judge Charles McCoy to Zernik
denial of access to Book of Judgments records of LASC.
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v
b. July 28-30, 2009 Zerniks correspondence with office of the Clerk and Court
Counsel regarding denial of access to records, false local rules of courts, failure
to maintain books of judgments.
c. October 15, 2009 Zerniks request for honest, valid, effectual local rules of
court of LASC re: Entry of judgment-
d. October 28, 2009 Court Counsel Bennetts response to Dr Zernik re: Denial of
Access to Records, Registers of Actions, Books of Judgments.
Appendix IX: LASC Microfilm Judgment Archive records
a. 08-07-28-la-sup-ct-judgments-copied-from-archives-s
b. 10-04-16 declaration request for help by judgment microfilm room and records
found.
Appendix XAppendix XAppendix XAppendix X: LASC and USDCLASC and USDCLASC and USDCLASC and USDC----CADCCADCCADCCADC: False Appearances by Counsel: False Appearances by Counsel: False Appearances by Counsel: False Appearances by Counsel
a) March-April 2010 Correspondence with California Judicial Council,
in attempt to ascertain the nature of involvement of Attorney Kevin
McCormick as counsel in Fine v Sheriff(2:09-cv-01914), and
Attorney Sarah Overton as counsel in Zernik v Connor et al(2:08-cv-
01550).
b)b)b)b) Complaints filed with Office of Comptroller of the Currency against
Bank of America Corporation regarding false appearance of counsel.
c)c)c)c) April 2010 Refusal of California Judicial Council to respond on any
questions pertaining to retainer of Attorney Sara L Overton in
Zernik v Connor et al(2:08-cv-01550)
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vi
Appendix XI:Appendix XI:Appendix XI:Appendix XI: USDCUSDCUSDCUSDC---- CACCACCACCAC
a) March 14, 2010 Repeat complaint filed with Clerk of the Court, Terry
Nafisi
b) March 25, 2010 Complaint filed with Chief Judge Audrey Collins
c) February 19, 2010 Notice of investigation by Court Counsel, Lydia
Yurtchuk.
Table of AuthoritiesTable of AuthoritiesTable of AuthoritiesTable of Authorities
California Code of Civil Procedure, 664 10 10 10 10
California Government Code 69844.7 10 10 10 10
California Government Code, 6250 - 6276.48
(California Public Records Act) 6 6 6 6
California Rules of Court, Rule 1.4 11111111
County of Los Angeles, Local Rules of Court, Rule 3.0: 10 10 10 10
Fay v Noia(1963) 3,15 3,15 3,15 3,15
Federal Rules of Civil Procedure, Rule24 1,2,4,5 1,2,4,5 1,2,4,5 1,2,4,5
General Order08-02, USDC CAC 14 14 14 14
Nixon v Warner Communications, Inc(1968) 4 4 4 4
US Rule Making Enabling Act, 28 USC 2071-7 4,21 4,21 4,21 4,21
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PRO SE FILER JOSEPH ZERNIKPRO SE FILER JOSEPH ZERNIKPRO SE FILER JOSEPH ZERNIKPRO SE FILER JOSEPH ZERNIKS NOTICE OF MOTION & VERIFIED MOTIONS NOTICE OF MOTION & VERIFIED MOTIONS NOTICE OF MOTION & VERIFIED MOTIONS NOTICE OF MOTION & VERIFIED MOTION
TO INTERVENETO INTERVENETO INTERVENETO INTERVENE
TO THE COURT AND TO PARTIES please notice Joseph Zerniks Motion to
Intervene in Richard I Fine v Sheriff of Los Angeles County et al(09-A827), filed
herein pursuant to FRCivP, Rule 24, and Supreme Court Rules, Rule 21.
Concomitantly filed under separate covers, with and in support of the Motion to
Intervene:
1. Motion to Intervene;
2. Request for Lenience by Pro Se Filer;
3. Request for Corrections in US Supreme Court Records;
4. Request for Incorporation by Reference, and
5. Appendices
Respectfully submitted,
Dated: April 18, 2010 Joseph Zernik
By: ______________________Joseph Zernik[Proposed] Intervenor
In Pro SePO Box 256La Verne California 91750Tel: 323.515.4583Fax: 323.488.9697E-Mail:[email protected]
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[PROPOSED] INTERVENOR JOSEPH ZERNIKS MOTION TO INTERVENE[PROPOSED] INTERVENOR JOSEPH ZERNIKS MOTION TO INTERVENE[PROPOSED] INTERVENOR JOSEPH ZERNIKS MOTION TO INTERVENE[PROPOSED] INTERVENOR JOSEPH ZERNIKS MOTION TO INTERVENE
A.A.A.A. POINTS AND AUTHORITIESPOINTS AND AUTHORITIESPOINTS AND AUTHORITIESPOINTS AND AUTHORITIES PERTAINING TO MOTION TO INTERVENEPERTAINING TO MOTION TO INTERVENEPERTAINING TO MOTION TO INTERVENEPERTAINING TO MOTION TO INTERVENE
1. Zernik claims Intervention of Right pursuant to FRCivP 24(a)1. Zernik claims Intervention of Right pursuant to FRCivP 24(a)1. Zernik claims Intervention of Right pursuant to FRCivP 24(a)1. Zernik claims Intervention of Right pursuant to FRCivP 24(a)
a) Joseph Zernik ( Zernik) claims timely Intervention of Right: Zernik was
informed by Clerk Counsel Danny Bickell on April 12, 2010, that filing was
timely and permitted as long as the Application was pending.
b) Zernik claims an interest that is the subject of the action, based on his
allegations of schemes employed at the Los Angeles Superior Court (LASC), as
outlined in Appendix IIAppendix IIAppendix IIAppendix II, which were almost identical in the case of Richard I
Fine (Fine) pertaining to the Deprivation of Liberty (Appendix IIIAppendix IIIAppendix IIIAppendix III), and in
the case of Zernik pertaining to the Deprivation of the Right to Property
(Appendix VAppendix VAppendix VAppendix V). Through such schemes, Fine was arrested on March 4, 2009, and
is held to this date by Respondent Sheriff of Los Angeles County (Sheriff), with
no honest, valid, and effectual records to support the arrest and holding.
Likewise, Zernik was forced in 2007 to leave his home, and his property was
taken for private use with no compensation at all, with no honest, valid, and
effectual record to support the taking. Such schemes are the core claims that
Zernik wishes to bring to the Honorable Courts attention in both cases, and
pertaining to which the Court is requested to provide relief.
c) Furthermore, Zernik was recently twice subjected to arrests and jailing by
Sheriff, which upon review would be found to have been conducted with no
honest, valid, and effectual warrants, similar to treatment that Fine was and is
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subjected to, to this date (Appendix III bAppendix III bAppendix III bAppendix III b).
d) Zernik further claims that no party adequately represents his interests. His core
claims were not brought up by Fine, perhaps because Fine had no access to key
records. Bringing such records to the attention of the Court, is the primary
purpose of Instant Motion. Zernik therefore claims that he is so situated that
disposing of the action may, as a practical matter, impair or impede his ability to
protect his interest to protect his fundamental Human, Constitutional, and
Civil Rights.
e) Beyond his individual interest, Zernik claims that his intervention is in the
public interest and in the interest of the furtherance of justice:
i. Instant Motion to Intervene provides critical records pertaining to instant
Application, absent which the Court may err in its judgment (Appendix III,Appendix III,Appendix III,Appendix III,
IV, V, VI, VII, VIII, IX, XIV, V, VI, VII, VIII, IX, XIV, V, VI, VII, VIII, IX, XIV, V, VI, VII, VIII, IX, X)
ii. Instant Motion to Intervene also pertains to the alleged deprivation of
various Human, Constitutional, and Civil Rights of numerous other inmates
in the Los Angeles County jails, who were and are held by Respondent Sheriff
with no records that conform with the fundamentals of the law to provide the
foundation of their holding, Fay v Noia(1963).
iii. Instant Motion to Intervene also pertains to the alleged deprivation of
various Human, Constitutional, and Civil Rights of all 10 million residents of
the County of Los Angeles, California: Relative to conditions instituted by
Respondent LASC, where First Amendment Right to Access Court Records
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to inspect and to copy - pursuant to Nixon v Warner Communications, Inc
(1968), is routinely denied; Relative to the Due Process Right to Service and
Notice, which is routinely waived by the Court, and relative to Local Rules
of Court, which are false and deliberately misleading particularly relative
to entry of judgment.
iv. Instant Motion to Intervene also pertains to the alleged deprivation of
various Human, Constitutional, and Civil Rights at the US courts concerning
the design and operations of the public access (PACER) and case
management (CM/ECF) systems: Relative to failure to establish the
foundation of the new practices and procedures of the courts, which are
inherent in such systems, in the Local Rules of Courtpursuant to US Rule
Making Enabling Act28 USC 2071-7; Relative to denial of Public Access to
Court Records to inspect and to copy the authentication records NEFs
(Notices of Electronic Filings) and NDAs (Notices of Docket Activity);
Relative to denial of Notice and Service of authentication records on pro se
filers.
f) Zernik further alleges that when he previously attempted to address his
grievances in US courts he was effectively denied access to the courts, through
further dishonest schemes at the US Courts, as outlined above. Therefore, if he
is denied the right to intervene in instant action, he may be deprived of the
ability to protect his interests and his fundamental rights.
2. Alternatively, Zernik claims Permissive Intervention pursuant to FRCivP 24(b)2. Alternatively, Zernik claims Permissive Intervention pursuant to FRCivP 24(b)2. Alternatively, Zernik claims Permissive Intervention pursuant to FRCivP 24(b)2. Alternatively, Zernik claims Permissive Intervention pursuant to FRCivP 24(b)
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Zernik alternatively claims that the Court should allow Permissive Intervention,
since Zernik shares with Fine the main claims of abuse of rights by Respondent
LASC, and failure of the US District Court, Central District of California (USDC-
CAC), and US Court of Appeals, 9th Circuit (CCA9th), national tribunals for
protection of rights, to protect his rights (Appendix IIAppendix IIAppendix IIAppendix II). Therefore, there is
commonality of law and of facts in instant [Proposed] Intervention and current
action under the caption ofFine v Sheriff(09-A827).
3. Zernik fulfilled requirement for Notice and Service pursuant to FRCivP 24(c)3. Zernik fulfilled requirement for Notice and Service pursuant to FRCivP 24(c)3. Zernik fulfilled requirement for Notice and Service pursuant to FRCivP 24(c)3. Zernik fulfilled requirement for Notice and Service pursuant to FRCivP 24(c)
a. Zernik provided Notice of Intent to Intervene (AppenAppenAppenAppendix Idix Idix Idix I), and also attempted
to Confer with Petitioner Fine, Respondents Sheriff and LASC.
b. Zernik served instant Motion to Intervene and related papers on parties
pursuant to the Service List, below, and a Certificate of Service and Proof of
Mailing, which are provided herein.
c. Zernik claims that evidence provided in Appendix IAppendix IAppendix IAppendix I and XXXX, and additional
discovery would lead this Court to rule that counsel that were listed in various
records as counsel for Respondents Sheriff and LASC in instant action at the
Supreme Court of the US, were not true Counsel of Record for respective parties
in the case at hand. Therefore, service was executed on parties Sheriff and LASC
themselves.
d. Therefore, the Clerk of the Court must not refuse to file instant Zerniks papers,
even if not in the form prescribed by FRCivPor by a local rule or practice.
5. Zernik should be permitted by the Court to intervene in Fine v Sheriff5. Zernik should be permitted by the Court to intervene in Fine v Sheriff5. Zernik should be permitted by the Court to intervene in Fine v Sheriff5. Zernik should be permitted by the Court to intervene in Fine v Sheriff (09(09(09(09----A827)A827)A827)A827)....
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c. Respondent Sheriff refused to correct such false records. Respondent Sheriff
continues to deny access to the California public records, which are the arrest
and booking papers of Fine and other inmates. Moreover, Respondent Sheriff
provided false and deliberately misleading records as response to inquiry by the
Hon Michael Antonovich. Respondent Sheriff explicitly stated such false
information in the November 4, 2009 letter received through Supervisor
Antonovitch with the January 8, 2010 letter.
The November 4, 2009 letter stated:
Mr. Richard Fine was arrested by the Los Angeles County SheriffsDepartment (LASD) on March 4, 2009, at IIIIIIII :05 a,m., in San PedroCourt Municipal Division 86, He was booked by LASD personnel onthe same date, San Pedro Court, at 12:23 p.m.Mr. Fine's confinement to the Sheriff's Custody is the result of a courtremand order dated March 4, 2009, case number 135109420.
e. No such entity as the San Pedro Municipal Court existed for almost a decade.
Moreover, media and other witnesses provided evidence that Fine was arrested
on March 4, 2009 at the Superior Court of California, County of Los Angeles, the
Central District Courthouse, North Hill St, City of Los Angeles. The same
information was listed in the Remand Order (see below).
f. Booking at the Municipal Court of San Pedro could not possibly take place, for
the same reason. Moreover, Zernik is informed and believes that the Superior
Court of California, County of Los Angeles, San Pedro Annex, has no booking
facility. The Sheriff Deputy on location denied that Richard Fine was ever
booked there.
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g. The printout from the online Inmate Information Center, which was attached to
the November 4, 2009 letter, repeated the same false and deliberately
misleading information.
h.h.h.h. The unverified, unauthenticated online Inmate Information Center printouts
could not possibly be deemed true and valid State of California and/or County of
Los Angeles arrest and booking records. (As to form - see example of Los Angeles
County Booking record Re: Joseph Zernik, Inmate #2235341 Appendix III bAppendix III bAppendix III bAppendix III b).
i.i.i.i. Such false arrest and booking records were employed for execution of an invalid
judgment and warrantless arrest on Petitioner Fine (see below). They paralleled
the grant deed in Samaan v Zernik(SC087400), which was employed to execute
an invalid judgment on Zernik, and was opined as fraud. (Appendix VAppendix VAppendix VAppendix V)
j.j.j.j. Therefore, the Honorable Court should find the records produced by the Sheriff
in response to request for arrest and booking records of Fine as false records,
void, not voidable, and likewise the grant deed recorded on Zerniks property
as a false grant deed void, not voidable.
2)2)2)2) Records (Dkt #16Records (Dkt #16Records (Dkt #16Records (Dkt #16----2) titled (i) March 4, 2009 Remand/Removal Order, and (ii)2) titled (i) March 4, 2009 Remand/Removal Order, and (ii)2) titled (i) March 4, 2009 Remand/Removal Order, and (ii)2) titled (i) March 4, 2009 Remand/Removal Order, and (ii)
March 4March 4March 4March 4, 2009 Judgment and Order of Contempt, (Appendix IV), 2009 Judgment and Order of Contempt, (Appendix IV), 2009 Judgment and Order of Contempt, (Appendix IV), 2009 Judgment and Order of Contempt, (Appendix IV) which were filedwhich were filedwhich were filedwhich were filed
in the habeas corpus petition at USDCin the habeas corpus petition at USDCin the habeas corpus petition at USDCin the habeas corpus petition at USDC----CACCACCACCAC Fine v SheriffFine v SheriffFine v SheriffFine v Sheriff(2:09(2:09(2:09(2:09----cvcvcvcv----01914) were01914) were01914) were01914) were
false and deliberately misleading records, void not voidable.false and deliberately misleading records, void not voidable.false and deliberately misleading records, void not voidable.false and deliberately misleading records, void not voidable.
a. Such records were filed by Attorney Kevin McCormick, appearing on behalf of
Respondents LASC and Judge David Yaffe in the action referenced above.
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Attorney McCormick failed to file certification as Counsel of Record, required by
local Rules of Court of USDC-CAC. Moreover, correspondence with California
Judicial Council, Administrative Office of the Courts (Appendix XaAppendix XaAppendix XaAppendix Xa), revealed
that he was retained under a false case caption.
b. Attorney McCormick failed to file any declaration by his clients. He filed only a
declaration by counsel, who was not a competent fact witness in the case.
c. Attorney McCormick failed to file the foundation record for the documents in
Dkt #16Dkt #16Dkt #16Dkt #16----2222, which was the Register of Actions (California civil docket) in Marina
Strand Colony II Homeowners Assn. vs County of L.A. Marina v LA County
(BS109420). In fact Respondent LASC to this date denies access to the
Register of Actions in the case. (Appendix VIIIAppendix VIIIAppendix VIIIAppendix VIII). Zernik managed to gain limited
access to the Register of Actions ofSamaan v Zernik(SC087400) (Appendix VIIAppendix VIIAppendix VIIAppendix VII),
which is alleged as evidence of criminality under the pretense of court action.
Based on a number of Registers of Actions that Zernik managed to gain access
to, Zernik believes that it is very likely that the Register of Actions ofMarina v
LA County(BS109420), likewise, once discovered, would provide evidence of
criminality.
d. The record that was titled March 4, 2009 Remand/Removal Order could not
possibly be a valid authority for the arrest of Petitioner Fine. Appendix IV cAppendix IV cAppendix IV cAppendix IV c is a
form obtained by Zernik in the course of his jailing, titled LA County Sheriffs
Department -Removal Order for In Custody Defendant. The title, in and of
itself, explicitly states that such order is applicable only to in custody
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defendant. Zernik claims that upon additional discovery the same would be
found true for Removal Orders. Fine was not in custody defendant on March 4,
2009. Therefore, such order was not applicable to Fine on March 4, 2009.
e. The record that was titled March 4, 2009 Remand/Removal Order was never
listed among the court file record, images of which are provided online by the
LASC.
f. The record that was titled March 4, 2009 Judgment and Order of Contempt
could not possibly be an honest, valid, and effectual court judgment, since it was
stamped FILED with the date of March 4, 2009 on its face, and was verified by
the hand-signature of Judge David Yaffe on the final page, with the hand
inscribed date of March 24, 2009.
g. Both records failed to be adequately authenticated. Such defect paralleled the
defect in August 9, 2007 Judgment and November 9, 2007 Order Appointing
Receiver in Samaan v Zernik(SC087400). (Appendix VIAppendix VIAppendix VIAppendix VI)
h. LASC failed to enter the purported March 4, 2009 Judgment in Marina v LA
County(BS109420) in a manner that would have rendered it effectual for any
purpose, pursuant to Cal Code Civ Proc664. Such conduct paralleled the
failure to enter the August 9, 2007 Judgment and November 9, 2007 Order in
Samaan v Zernik(SC087400) (Appendix VIAppendix VIAppendix VIAppendix VI) . (See 3, below)
i. Therefore, the Honorable Court should find the records under Dkt #16Dkt #16Dkt #16Dkt #16----2222 in Fine v
Sheriff (2:09-cv-01914) as false records, void, not voidable.
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3)3)3)3) No judgment was ever entered in eitherNo judgment was ever entered in eitherNo judgment was ever entered in eitherNo judgment was ever entered in either Marina v LA CountyMarina v LA CountyMarina v LA CountyMarina v LA County(BS109420) or(BS109420) or(BS109420) or(BS109420) or
Samaan v ZernikSamaan v ZernikSamaan v ZernikSamaan v Zernik(SC087400). The judgment records were v(SC087400). The judgment records were v(SC087400). The judgment records were v(SC087400). The judgment records were void, not voidable.oid, not voidable.oid, not voidable.oid, not voidable.
a. Cal Code Civ Proc 664 says:
" ... In no case is a judgment effectual for any purpose until entered."
b. Cal Gov Code 69844.7 permitted the use of alternative media for the
traditional paper Books of Judgments. However, Cal Gov Code 69844.7 clearly
stated:
Nothing contained herein shall eliminate the requirement for ajudgment book where judgments and decrees are required to beentered.
c. Los Angeles County Local Rules of Court. Rule 3.0 (d) states to this date:
(d) Entry of Judgments, Orders and Decrees.Judgments, orders and decrees rendered by the court, which arerequired by law to be entered, shall be entered by the clerk in
judgment books kept by him/her either in the Public Services Division
of the Central District, or the clerks office in each of the severaldistricts. The judgment, order or decree shall be entered in thejudgment books in the district wherein the same was rendered and noother entry thereof shall be required.
d. Los Angeles County Local Rules of Court. Rule 1.4(e)16(e) states to this date:
1.4 EXECUTIVE OFFICER/CLERK OF THE SUPERIOR COURT(e) Powers and Duties. Pursuant to Section 69898 of the GovernmentCode and Rule 10.610 Superior Court of California County of LosSuperior Court of California County of LosSuperior Court of California County of LosSuperior Court of California County of Los
AngelesAngelesAngelesAngeles Ch. 1 Pg. 5 of the California Rules of Court, the court declaresthat, under the direction of the Presiding Judge, the powers and dutiesof the Executive Officer shall include:
(16) To exercise and perform all of the powers, duties andresponsibilities of the County Clerk and Clerk of the Superior Court
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required or permitted by this Court to be exercised or performed by theExecutive Officer in connection with judicial actions, proceedings andrecords under subdivision (d) of Section 69898 of the GovernmentCode. Such powers, duties and responsibilities include:
e) To enter orders, findings, judgments and decrees; to acceptconfessions of judgment for filing; to authenticate records; to certifyabstracts of judgment; to keep a judgment book or its equivalent.
e. Zernik repeatedly attempted to access the LASC Books of Judgments in the past
three years. In all cases, he was informed by Clerks Office Supervisors that no
Books of Judgments existed at the LASC in the past quarter century, since case
management systems (CMSs) were introduced in the court.
f. Numerous complaints were filed by Zernik with the LASC Clerk of the Court
and Presiding Judge and also requests to update the Local Rules. LASC refused
to update the Local Rules to this date.
g. In October 16, 2009 letter to Presiding Judge McCoy (Appendix VIIIcAppendix VIIIcAppendix VIIIcAppendix VIIIc), Zernik
requested disclosure of the Local Rules of Court pertaining to entry of judgment.
h. In October 28, 2009 response, LASC Court Counsel Frederick Bennett (AppendixAppendixAppendixAppendix
VIIIdVIIIdVIIIdVIIId) stated:
Judgement Book [sic jz]Prior to 1974, all judgements of the superior, municipal, and justicecourts were entered in a "Judgement Book." Code of Civil Proceduresection 668. Although courts in some counties continue to enter
judgments in a judgment book, section 668 no longer provides the
exclusive means of entry. Code of Civil Procedure section 668.5authorizes alternatives, including making a microfilm copy of theindividual judgement, as is done in the Los Angeles Superior Court.
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k. In a visit to the underground archives of the LASC on July 28, 2008, almost a
year after the August 9, 2007 Judgment in Samaan v Zernik(SC087400) was
falsely stated to have been entered, Zernik found no entry of such judgment in
the West District Microfilm Judgments reels. (Appendix IXaAppendix IXaAppendix IXaAppendix IXa)
l. In a visit to the underground archives of the LASC on April 16, 2010, over a year
after the March 4, 2009 Judgment and Order of Contempt Re: Richard I Fine in
Marina v LA County (BS109400) was falsely executed on Fine, Zernik found no
entry of such judgment in the Central District Microfilm Judgments reels.
(Appendix IXbAppendix IXbAppendix IXbAppendix IXb) On April 16, 2010, again, no entry was found for either the
August 9, 2007 Judgment, or the November 9, 2007 Order Appointing Receiver
in Samaan v Zernik(SC08740), both of which were executed on Zernik.
m. Therefore, the Honorable Court should find that in neither Samaan v Zernik
(SC087400) nor Marina v LA County(BS109420), were the judgments ever
entered, in both cases such records were ineffectual court records, void, not
voidable.
n. Therefore, the Honorable Court should find that in both the cases of Fine and
Zernik, LASC judgments in the respective cases, were falsely executed.
(Appendix III,IV,VAppendix III,IV,VAppendix III,IV,VAppendix III,IV,V)
4)4)4)4) Both Fine and Zernik attempted to protect their rights through actions at theBoth Fine and Zernik attempted to protect their rights through actions at theBoth Fine and Zernik attempted to protect their rights through actions at theBoth Fine and Zernik attempted to protect their rights through actions at the
USDCUSDCUSDCUSDC----CAC.CAC.CAC.CAC. Such efforts were frustrated through false conduct and false recordsSuch efforts were frustrated through false conduct and false recordsSuch efforts were frustrated through false conduct and false recordsSuch efforts were frustrated through false conduct and false records
at the USDCat the USDCat the USDCat the USDC----CAC.CAC.CAC.CAC.
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O. Certification of Electronic DocumentsO. Certification of Electronic DocumentsO. Certification of Electronic DocumentsO. Certification of Electronic Documents. Pursuant to Federal Rules ofCivil Procedure 44(a)(1) and 44(c), the method of electronic certificationdescribed herein is deemed proof of an official court record maintainedby the Clerk of Court.
The NEF contains the date of electronic distribution and identificationof the United States District Court for the Central District ofCalifornia as the sender. An encrypted verification code appears in theelectronic document stamp section of the NEF. The electronicdocument stamp shall be used for the purpose of confirming theauthenticity of the transmission and associated document(s) with theClerk of Court, as necessary. When a document has been electronicallyfiled into CM/ECF, the official record is the electronic recording of thedocument kept in the custody of the Clerk of Court. The NEF providescertification that the associated document(s) is a true and correct copyof the original filed with the court.
i. Pursuant to General Order08-02, such minutes, orders, and judgments in the
cases of Fine and Zernik at USDC-CAC, which were issued with no encrypted
verification code, failed to be adequately authenticated they lacked the
verification necessary for ... the purpose of confirming the authenticity of the
transmission and associated document(s).
j. Such unauthenticated minutes, orders, and judgments, could not possibly be
deemed honest, valid, and effectual records of the USDC-CAC.
k. Zernik filed repeated complaints with Clerk of the Court, Terry Nafisi, and Chief
Judge Audrey Collins, and an investigation was noticed as instituted. (AppendixAppendixAppendixAppendix
XIIXIIXIIXII)
l. Therefore, the Honorable Court should find all actions of the USDC and CCA9th
pertaining to the cases of Fine and Zernik as void, not voidable.
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4)4)4)4) There was and there is no valid record to provide theThere was and there is no valid record to provide theThere was and there is no valid record to provide theThere was and there is no valid record to provide the legal foundation for thelegal foundation for thelegal foundation for thelegal foundation for the
holding of Petitioner Fine that conform with the fundamentals of the law. Fine isholding of Petitioner Fine that conform with the fundamentals of the law. Fine isholding of Petitioner Fine that conform with the fundamentals of the law. Fine isholding of Petitioner Fine that conform with the fundamentals of the law. Fine is
entitled to his immediate release.entitled to his immediate release.entitled to his immediate release.entitled to his immediate release.
a. The above Points and Authorities documented that there was and there is no
valid record to provide the legal foundation for the arrest and holding of
Petitioner Fine.
b. In Fay v Noia(1963) the Court stated:
"The basic principle of the Great Writ of habeas corpus is that, in acivilized society... if the imprisonment cannot be shown to conformwith the fundamental requirements of law, the individual is entitled tohis immediate release".
c. Therefore, the Honorable Court should find that Petitioner Fine is entitled to his
immediate release.
WHEREFORE, Zernik respectfully requests that the Court grant Fines petition,
and immediately release the prisoner, and grant Zernik the relief he requested,
including, but not limited to the return of his lawful property to his possession.
C. CLAIMSC. CLAIMSC. CLAIMSC. CLAIMS
[Proposed] Intervenor Zerniks core claims are:
1) Respondent LASC: In Marina v LA County(BS109420) and Samaan v Zernik
(SC087400), Fine and Zernik, respectively, were subjected to execution of
judgments, which were never entered, and therefore - were never effectual for
any purpose. Such judgments were and are void, not voidable.
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Such conduct was enabled through:
a. False and deliberately misleading employment of the LASCs online public
access and case management systems.
b. Failure and refusal to establish the Courts practice and procedures
pertaining to entry of judgment in the Local Rules of Court, for over a quarter
century.
c. Ongoing denial of access to court records to inspect and to copy, such as
electronic records in the Courts case management system.
d. Routine waivers by the Court of the right for Notice and Service.
e. Allowing appearances by false counsel:
In Samaan v Zernik(SC087400) Bryan Cave, LLP, has been appearing for 2.5
years for Countrywide, later Bank of America, while not Counsel of Record,
under false party designation Non Party. Similar schemes were employed
by Countrywide elsewhere in the courts, and which were described in detail
in the case ofBorrower William Alan Parsley(05-90374), Dkt #248 -
appearances by counsel who was not counsel of record, with no
communications with client clause. Other conduct of Countrywide and Bank
of America at the Los Angeles Courts, which was alleged as racketeering was
detailed in Zerniks filing under Borrower Parsley(05-90374), Dkt #256-260.
In Marina v LA County(BS109420) the same is likely to be true regarding
appearances of Attorney Joshua L Rosen for two large private developers, one
whose name was omitted from the online records, and the other, whose
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name was falsely listed, both under party designation of Real Parties in
Interest.
3. Respondent Sheriff In Marina v LA County(BS109420) and Samaan v Zernik
(SC087400), Respondent Sheriff was employed by the Respondent LASC to affect
the execution of void, not voidable judgments.
a. In Marina v LA County(BS109420) Respondent Sheriff has been willfully
colluding with the LASC in the false holding of Petitioner Fine.
b. In Samaan v Zernik(SC087400) Respondent Sheriff was employed to exert a
threat of force, unlawful, but credible, to take Zerniks property with no
foundation in the law.
c. Respondent Sheriff like the courts, has established dual systems, which are
the case management system Los Angeles Booking Records, and online
public access records the Inmate Information Center, which facilitate the
false arrests and holding of thousands of persons in Los Angeles County.
3. USDC-CAC in Fine v Sheriff(2:09-cv-01914) and in Zernik v Connor et al(2:09-
cv-1550), Fine and Zernik, respectively, were subjected to dishonesties and false
conduct at the USDC-CAC. Such conduct was employed to effectively deny them
access to national tribunals for protection of rights, and as collusion with LASC
and Sheriff in deprivation of rights.
Such false conduct and effective denial of access to the court were enabled
through:
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a. False and deliberately misleading employment of the USDC-CACs dual
systems - the online public access system PACER, and the case
management system - CM/ECF.
b. Failure to establish the Courts practice and procedures pertaining to PACER
and CM/ECF in the Local Rules of Court, for over a quarter century.
c. Ongoing denial of access to court records to inspect and to copy, such as
electronic records in the Courts case management system NEFs (Notices of
Electronic Filings).
d. Routine failure of the court to keep Notice and Service to pro se filers that is
identical to that provided to others.
e. Allowing appearances by false counsel:
In Fine v Sheriff(2:09-cv-01914) false appearance of Attorney Kevin
McCormick for Respondents LASC and Judge David Yaffe (Appendix XAppendix XAppendix XAppendix X).
In Zernik v Connor et al(2:09-cv-1550) appearance of Bryan Cave, LLP for
Bank of America, and most likely also appearance of Sarah L Overton for
LASC (California Judicial Council would not answer any questions in this
regard- Appendix XAppendix XAppendix XAppendix X).
4. LA County Office of Registrar Recorder colluded with LASC in condut of the
real estate fraud against Zernik, through the recording of records that were
opined as fraud by the highest reputation fraud expert (Appendix VAppendix VAppendix VAppendix V), and refusal
to take any corrective actions, even after discovery of the fraud.
D. CASE STATUSD. CASE STATUSD. CASE STATUSD. CASE STATUS
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The only litigation that Zernik is purported to be currently involved in is Samaan v
Zernik(SC087400) at LASC. It is claimed that upon review of the matter, the
Honorable Court would conclude that such caption was never a true court action of
LASC. None of the conduct in the purported litigation conformed with the law of
California and/or the US.
E.E.E.E. [PROPOSED] INTERVENOR ENTERS HIS REQUEST FOR INTERVENTION[PROPOSED] INTERVENOR ENTERS HIS REQUEST FOR INTERVENTION[PROPOSED] INTERVENOR ENTERS HIS REQUEST FOR INTERVENTION[PROPOSED] INTERVENOR ENTERS HIS REQUEST FOR INTERVENTION
AND PRAYER FOR RELIEF:AND PRAYER FOR RELIEF:AND PRAYER FOR RELIEF:AND PRAYER FOR RELIEF:
WHEREFORE [PROPOSED] INTERVEWHEREFORE [PROPOSED] INTERVEWHEREFORE [PROPOSED] INTERVEWHEREFORE [PROPOSED] INTERVENOR PRAYSNOR PRAYSNOR PRAYSNOR PRAYS this honorable Court
issue equitable relief as follows:
1. Declaratory relief that Respondent LASC March 4, 2009 Oder and Judgment of
Contempt re: Richard I Fine in Marina v LA County(BS109400) was void, not
voidable.
2. Declaratory relief that Respondent LASC August 9, 2007 Judgment, and
November 9, 2007 Order Appointing David Pasternak Receiver in Samaan v
Zernik(SC08700) were both void, not voidable.
3. Declaratory relief that March 4, 2009 Remand/Removal Order generated by
Respondent LASC, and arrest and booking records that were generated by
Respondent Sheriff pertaining to Richard I Fine were fraud on their face.
4. Declaratory relief that conveyance of title executed on behalf of Respondent
LASC on Zerniks property at 320 South Peck Drive, Beverly Hills California,
90212 was fraud on its face, as opined by highly decorated fraud expert, FBI
veteran James Wedick.
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5. Order Respondent Sheriff to immediately release Petitioner Richard I Fine.
6. Ordedr Respondent Sheriff to immediately return Intervenor Joseph Zerniks
property at 320 South Peck Drive, Beverly Hills, California 90212 to his
possession.
7. Declaratory relief that the public access and case management systems, which
were implemented by Respondent Sheriff are false and deliberately misleading.
8. Order Respondent Sheriff to implement public access and case management
systsems for the Los Angeles jails, which were subjected to publicly accountable
validation (certified, functional logic verification).
9. Order Respondent Sheriff to immediately initiate review of all records that
support the holding of inmates in LA County, and release all those who have no
valid records to support the arrests and jailing.
10. Declaratory relief that the the public access and case management systems,
which were implemented by Respondent LASC are false and deliberately
misleading.
11. Order Respondent LASC to implement public access and case management
systsems in the courts, which were subjected to publicly accountable validation
(certified, functional logic verification).
12. Order Respondent LASC to respect First Amdndement Rights to Access Court
Records to inspect and to copy.
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13. Order Respondent LASC to respect Due Process Rights for Notice and Service
of all Court minutes, orders and judgments, and cease the practice of waiving
such rights of parties in litigations.
14. Order Respondent LASC to implement Books of Judgments, pursuant to
Califonria Code, which is a public record, to which reasonable access must be
allowed.1
15. Order Respondent LASC to implement an Index of All Cases, Registers of
Actions, and Caledar of the Courts, that are true and correct, and where public
access is allowed, as required by California and US Law.
16. Order Respondent LASC to update its Local Rules of Court to reflect the true
procedures and practices of the Court today.
17. Enter mandate to lower US courts - to implement public access and case
management systems in the courts, which were subjected to publicly
accountable validation (certified, functional logic verification), and were
honestly founded in the Local Rules of Court.
18. Enter mandate to lower US Courts to respect First Amendment Rights to
Access Court Records to inspect and to copy including, but not limited to
authentication records in CM/ECF (NEFs and NDAs).
19. Enter mandate to lower US Courts to respect Due Process Rights for Notice
and Service particularly ofpro sefilers, who must be served all authentication
1At present only one location underground archives downtown LA. On recent visit obtaining copy of a
judgments, or finding out that no such copy existed took a total of about three hours, out of which 2.5 hourswere waiting in line. No online access is provided. No access in court locations is provided.
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records received by other parties in litigation, in a manner that does not deprive
pro sefilers of any information inherent in such records.
20. Enter mandate to lower US Courts to respect the Rule Making Enabling Act
and update their local Rules of Court to reflect the changes in court practice and
procedure related to electronic public access and case management systems.
WHEREFOREWHEREFOREWHEREFOREWHEREFORE, Plaintiff, Joseph Zernik respectfully asks the Honorable
Court to grant him such declaratory, injunctive, mandate and other relief as it
deems just and proper.
Respectfully submitted on April 18, 2010 by:
Joseph Zernik
By: _______________________________[Proposed] IntervenorIn Pro Se
PO Box 256La Verne California 91750Tel: 323.515.4583Fax: 323.488.9697E-Mail:[email protected]
CERTIFICATE OF COMPLIANCE
I certify that the MOTION TO INTERVENE is proportionately spaced, has a type face of 12points, and contains 5,302 words according to the Word 2000, the word processing system on
which it was prepared. The words counted are those on pages 1-23, excluding this Certificate of
Compliance.
Executed on this date, April 18, 2010, in La Verne, County of Los Angeles, California
Joseph Zernik
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By: ______________
JOSEPH ZERNIK1853 Foothill Blvd.
Tel: 323.515.4583
Fax: 323.488.9697E-Mail:[email protected]
STATEMENT OF VERIFICATION
Motion to Intervene
I, Joseph Zernik wrote and read instant Motion to Intervene, and I know the content thereof to
be true and correct, it is true and correct based on my own personal knowledge, except as to
those matters therein stated as based upon information and belief, and as to to those matters, I
believe them to be true and correct as well.
I make this declaration that the foregoing is true and correct under penalty of perjury pursuant
to the laws of California and the United States.
Executed here in La Verne, County of Los Angeles, on this 18th day in April, 2010.
____________________Joseph Zernik
PROOF OF SERVICE
&
CERTIFICATES OF MAILING AND/OR E-MAILING
I, the undersigned Joseph Zernik, served the documents described as:
Notice of Motion and Motion to Interveneon parties in this action by depositing a true copy thereof, which was enclosed in a sealed
envelope, with postage fully prepaid in the United States Mail, addressed as follows:
1) Richard I Fine Petitioner
Inmate RICHARD I. FINE (1824367)
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LOS ANGELES COUNTY JAIL
450 Bauchet St.Los Angeles, CA 90012
2) Sheriff of Los Angeles County -RespondentLeroy D Baca, Sheriff
Los Angeles County Sheriff's Department
4700 Ramona Blvd.
Monterey Park, CA 91754Phone: 323 526 5000
Fax:
Email: "Baca, Leroy D."
3) Superior Court of California, County of Los Angeles and Judge David Yaffe -
Respondents
John A Clarke, Clerk/Executive OfficerStanley Mosk Courthouse
111 North Hill StreetLos Angeles, CA 90012
Phone 213 974 5401
Fax: 213 621 7952
Email:
I certify and declare, under penalty of perjury under the laws of the UnitedStates of America and the State of California, that the foregoing is true and
correct.
Executed this date, April 18, 2010, in La Verne, County of Los Angeles, California
Joseph H Zernik
By: ______________
JOSEPH H ZERNIK
1853 Foothill Blvd
La Verne California 91750
Tel: 323.515.4583Fax: 323.488.9697
E-Mail:[email protected]