Declaration of Rami Avraham

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1 NATAN AVRAHAM

2 1778 South Shenandoah Street


Los Angeles, CA 90035
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4 (310) 877-9115
5 Plaintiff Pro Se
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7 UNITED STATES DISTRICT COURT
8 CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION
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NATAN AVRAHAM, Case No.: CV17-05792 VAP (JCG)
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12 PLAINTIFF, SWORN AFFIDAVIT OF NATAN RAMI
AVRAHAM
13 v.
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Date:
15 PERSONAL REPRESENTATIVE Time:
16 OF THE ESTATE OF MATTHEW Place:
ST. GEORGE, COMMISSIONER
17 MATTHEW ST. GEORGE, LOS Court Room: As Assigned
18 ANGELES SUPERIOR COURT, Complaint Filed: August 4, 2017
AND STATE OF CALIFORNIA, District Judge: Hon. Virginia A. Phillips
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DEFENDANTS.
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DECLARATION OF NATAN RAMI AVRAHAM


1 AFFIDAVIT OF EVIDENCE NUMBER 2
2 I, Natan Rami Avraham, declare as follows:
3 1. I am a resident of the City of Los Angeles. My residence is 1778 South
4 Shenandoah Street, Los Angeles, CA 90035. If called as a witness, I would
5 and could testify competently to the information set forth herein.
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2. The following facts and events are regarding my ongoing case in front of
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Commissioner Matthew St. George (“St. George”). The purpose of sharing
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these facts is shed to light on the actions of the Superior Court of Los
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Angeles and the suffering and damage that has been caused by years of these
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actions.
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3. On September 3, 2015 St. George made statements while acting as a judge
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that clearly disqualify him from making fair decisions in my case. Superior
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Court Commissioner Matthew St. George stated that I was a threat to
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society, specifically saying “I want to let you know this. I am considering
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having sheriff patrols around my house because people like him are a threat
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to society. We’ve seen it in the news everyday. Everybody says, oh, they are

18 just a little crazy. Yeah, and the next thing you know they get a gun and

19 shoot a lot of people or kill [St. George’s} family.” (Court Transcript


20 September 3, 2015, Page 10, Lines 12-15)
21 4. Put simply, Commissioner Matthew St. George stated that I am crazy, that I
22 would get a gun and kill a lot of people, or that I would kill St. George’s
23 family.
24 5. These statements could not be farther from the truth, and not only do they
25 have a terrible effect on my life, my family, and my livelihood, but these
26 statements very clearly show that Commissioner Matthew St. George is in
27 no position to make fair decisions in my case and should have recused
28 himself. The record shows that at no point during this case has St. George

DECLARATION OF NATAN RAMI AVRAHAM


1 fair and unbiased decisions in my case, but these statements clearly show
2 that St. George is willing to damage my case directly and threaten me with
3 arrest. St. George must not make statements of this kind while acting as the
4 judge in my case and determining the future of me and my children.
5 6. If St. George wishes to make statements like these against myself and my
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family under his First Amendment freedom of speech, his is allowed to – he
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just cannot do so while acting as the judge in my case.
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7. In St. George’s position it is inappropriate for him to make these kinds of
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statements as the word of a judge can cause a tremendous amount of damage
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to a normal person’s life.
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8. St. George has not recused himself as a result of these actions, and yet
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instead continue to make important decisions against me.
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9. These actions have continued to destroy everything I have built, and because
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this trial has gone on so long for years and years I have not had the
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opportunity to build my life and rebuild from the damage that has been
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caused to myself and my children.

18 10. I run a business as a 24-hour plumber seven days a week, available to the

19 public to provide a service to society. I have worked since the age of


20 fourteen to build this trade and my business in order to create a future for
21 myself and my family, and the actions of the Court have destroyed
22 everything that I have built and that damage might be irreparable. I am not
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a threat to society, and moreover, I have never made anything even
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resembling a threat to anyone. By labeling me a threat to society, St. George
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has shown that he is prejudiced, biased, and is acting maliciously to hurt my
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case.
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DECLARATION OF NATAN RAMI AVRAHAM


1 11. I have made repeated attempts to have St. George recuse himself from my
2 case as he is legally required to do. I have repeatedly presented evidence
3 that represents more than enough abuse of power and malicious action to
4 have St. George recuse himself from my case, and yet he has continued to
5 refuse recusal.
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12. St. George has gone even further than ignoring the evidence that I have
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presented any my requests for recusal, accusing me of violence and
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continuing to abuse the law and my rights in this case. St. George continued
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to act inappropriately on September 3, 2015 when he made the ridiculous
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statements about me, took action against my attorney that caused a chilling
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effect in my case, and ignored my counsel Mr. Green’s evidence showing
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that there was no order for the sale of the property. In fact, both parties to the
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action objected to the sale of my property. All of these actions are sufficient
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for St. George to be required to recuse himself from my case in addition to
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the earlier actions that St. George illegally took. Not only have I presented
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this evidence to the Court, but I have made this evidence available at

18 justiceforavraham.weebly.com. Instead of recusing himself, St. George

19 made ridiculous claims about being afraid in his own home and considering
20 having police presence deployed around his home.
21 13. I believe that instead of actually fearing actions I might take, St. George
22 was responding to his fear that I would not allow his actions and prejudice
23 to go unnoticed by the authorities and the public.
24 14. Just moments before St. George said the statements that I am a danger to
25 society, he said, “Before we begin this hearing though, I do want to advise
26 both counsel and parties that this Court is well aware of a public
27 campaign being conducted by Mr. Avraham in which he seeks my – in
28 which he’s attempting to have me disqualify myself from this case.

DECLARATION OF NATAN RAMI AVRAHAM


1 Basically, by what one could interpret as a threat. He is driving around
2 with a truck with a placard which says that if Commissioner St. George –
3 Matthew Saint George doesn’t disqualify himself, Mr. Avraham will take –
4 bring the law to me.” (Court Transcript September 3, 2015, Page 9, Lines
5 23-26)
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15. At no point did the sign say that I would “bring the law to” St. George. I
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simply designed the sign to spread information about what was being done
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in my case to the public. St. George even admitted that the sign was a public
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campaign to get him to resign.
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16. Not only did St. George admit that his primary concern was the public
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concern that I have undertaken in order to draw the attention of the public
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and the authorities of the damage that St. George and his malicious action
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have done to my case, but even he could not twist the statements placed on
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my truck enough to make them into anything that could be considered a real
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threat. The “placard” to which I believe St. George was referring was a vinyl
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sign I had made and attached to my personal truck, which is my only vehicle

18 and is used for my plumbing business as well. The sign was looking for

19 support and attention from the public.


20 17. The sign stated:. “If Commissioner Matthew St. George is not going to
21 follow the law and disqualify himself from my case, I am going to do my
22 best to enforce the law on him. Justice for Avraham.” The sign also
23 provided my website, justiceforavraham.weebly.com, where I outlined the
24 evidence of abuse of this court. There were no threats here, and certainly no
25 threats of violence against St. George or anyone else.
26 18. I have simply tried to exercise my First Amendment rights to free speech
27 in order to protect my property and my rights from the abuses of the
28 Court. Not even St. George could deny this fact, stating “If he wants to

DECLARATION OF NATAN RAMI AVRAHAM


1 spend his time driving around town, he’s free to do so. He can put a placard
2 wherever he wants.” (Court Transcript September 3, 2015, Page 10, Lines 7-
3 9)
4 19. I am clearly not “free” to do this, as the Court has taken actions to punish
5 me for undertaking this campaign through St. George’s statements against
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me, his statements to my attorney, his sale of my property against my rights,
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his refusal to give me my legal reimbursements, his imposition of sanctions
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against me and in favor of Mr. Berman (Petitioner’s attorney), his charging
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of all the community property tax expenses to me alone, and leaving me
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without funds to even cover the capital gains expenses on the property.
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20. For St. George to admit that my actions are in no way illegal and at the
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same time to threaten me with punishment and accuse me of violence and
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criminal activity continues to clearly shows his bias and malice in regard to
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my case and demonstrates that his prejudice was increasing. St. George is
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looking for any way to get himself away from the abuse and malice actions
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he has done in this case. I have been repeatedly abused by this Court for

18 many years and deprived of my property and rights by St. George, and I

19 have simply attempted to protect my rights by reaching out to the public


20 and government.
21 21. I have been repeatedly denied my rights and my property and have been
22 given no relief, and I have decided to reach out to the public in order to
23 have my case set right. For St. George to make these statements accusing
24 me of violence and illegal activity simply for attempting to protect my rights
25 and my property against this court clearly demonstrates that St. George has
26 no interest in seeing justice served in this case and can do nothing except
27 recuse himself as the law requires.
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DECLARATION OF NATAN RAMI AVRAHAM


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2 I declare under penalty of perjury under the laws of the United States of
3 America that the foregoing is true and correct.
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6 Dated: December 5, 2019
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By:
Natan Rami Avraham
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11 ATTESTATION OF WITNESSES
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The undersigned have heard the plaintiff, Natan Avraham, read the
13 foregoing declaration and declare to us that the statements therein are true and
14 correct.
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Executed this ___ day of August, 2019.
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____________________________________
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19 address: ______________________________
______________________________
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____________________________________
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23 address:______________________________
______________________________
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DECLARATION OF NATAN RAMI AVRAHAM

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