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2018.05-23 Lisa Does It 1 More Time
2018.05-23 Lisa Does It 1 More Time
RECEIVED
MOLLY C. DWYER, CLERK
CASE No. 17-35742 US. COURT OF APPEALS
MAY 23 2018
PILED
DOCKETED
DATE INS
On Appeal from the Superior Court Co. of Los Angeles, GP013952, GP015351
The Hon. Debre Katz Weintraub, David Cowan, Yolanda Orozco, Judge(s)
After a decision by the Federal District Court of Oregon
The Hon. Michael H. Simon, U.S. Dist. Judge, Case No.3:17-cv-1075-SI
INTRODUCTION
Procedural Justice, Fairness, & Substantial Justice
2. As of today, May 20, 2018, this Honorable Court has yet to legally respond
to the Petition with a Statement of Decision or with the Court's Opinions
supported by case law, statutes, ordinances, codes and whatever the court
clerks rely upon to deny this Petition where attorneys in the Superior Court
have basically prematurely stolen property from the Estate.
5. This Probate case, the Estate of Castaneda is, and will the only case in the
whole entire United State of America with nothing in it. THIS SHALL
SET PRECEDENT! What disbarred attorney files a Probate Case with
Nothing in it? Please explain with legal points and authorities if you find
one case in the archives of our legal history. To commit a much larger and
bigger crime besides Perjury, Subornation of Perjury, Falsifying evidence,
This will constitute the formal opposition to Mandate sent to Plaintiff, and
executor of the Estate of Castaneda by court clerk and now justice of the court
Rhonda Roberts. This will also be a demand for a document, signed document by
all judges, justices involved in this matter.
PROOF OF SERVICE
STATE OF CALIFORNIA, COUNTY OF LOS ANGELES
ESTATE OF CASTANEDA v Disbarred Jack K. Conway & Jan Walls Anderson
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 home address is 596 Douglas Street, Pasadena, CA 91104
On May 20, 2018 I served the foregoing documents described as: AMENDED TO ALSO
OPPOSED MANDATE OF 5-10-2018 PETITION FOR COURT'S LEAVE FORA FEDERAL
COURT'S ORDER TO JUDGE DEBRE K. WEINTRAUB TO ORDER ATTORNEYS FOR
THE RETURN OF PROPERTY PREMATURELY TAKEN FROM THE ESTATE OF
CASTANEDA
On the interested parties in this action by placing a true copy thereof enclosed in a sealed
envelope with postage thereon fully prepaid in the United States mail at Pasadena, California,
addressed and emailed ** as follows:
1) Stephen Rykoff, 11355 W Olympic Blvd Ste 100 Los Angeles, CA 90064 **
2) Jack K. Conway Esq., P.O. Box 81112, San Marino, CA 91118 **
3) Ivan Shomer Esq., 2202 S. Figueroa St., L.A. CA 90007 **
4) Sonia Mercado - Sam Paz Esq., 5711 W. Slauson Ave, Rm 10, Culver City, CA 90230**
5) Sarah Overton Esq., 3801 University Ave., Ste. 560, Riverside, CA 92501**
6) Lisa M. MacCarley Esq., 700 N Brand Blvd Ste 240 Glendale, CA 91203-3271 **
7) RoseAnn DeRosa, US Trust, B of America515 S Flower St. Fl 28 L.A, CA 90071-2204**
8) Emahn Counts Esq., 790 E Colorado Blvd Fl 9 Pasadena, CA 91101-2193**
9) Susan Formaker OofAH, 320 W 4th St. Ste 630, Los Angeles, CA90013 **
10) Jan Walls Anderson, 347 SW Oak St Hillsboro, OR 97123 **
11) Wayne Bohele 6242 Westchester Pkwy Ste 200 Los Angeles, CA 90045 **
12) Robert Gomez, I W Hellman Ave Ste 10 Alhambra, CA 91803-4044 **
13) Oscar A Acosta 3452 East Foothill Blvd. Suite 532 Pasadena, CA 91107 **
14) Manuel Hidalgo 5220 E Beverly Blvd Los Angeles, CA 90022-2076 MAIL
15) Robert Mallano, 300 S Spring St L.A., CA 90013 (B229512 Fraud Upon Court)MAIL
16) Frances J. DeVanon 653 Welsh Partridge Cir Biltmore Lake, NC 28715-8965 **
17) James R. Felton 16000 Ventura Blvd Ste 1000Encino, CA 91436 **
18) Justice Ruth Bader Ginsburg US Supreme Court, 1st NE Washington, DC 20543 MAIL
19) 9th Cir Court of App. No. 17-35742, P.O. Box 193939, San Fco. CA 94119-3939
[ X ] E-MAIL. I electronically served the document * above described and file a POS-050EFS
I declare under penalty of perjury under the laws of the State of California that the above
is true and correct. ** DENOTES SENT BY -: AIL 177
Dated: May 18, 2018 t'! 0~✓`~ ..
[x] Martin De La one
17-35742
Estate of Castaneda
596 Douglas St.
Pasadena, CA 91104
Case: 17-35742, 05/23/2018, ID: 10886851, DktEntry: 19, Page 6 of 16
V.
Defendants - Appellees.
The judgment of this Court, entered November 16, 2017, takes effect this
date.
This constitutes the formal mandate of this Court issued pursuant to Rule
MOLLY C. DWYER
CLERK OF COURT
RECEIVED
UMOLLY C. DWYER, CLERK
.S. COURT OF APPEALS
CASE No.
SEP 082017
-1LEO
DOCKETED ______________
~'iti
INi AL
On Appeal from the Superior Court Co. of Los Angeles, GPO13952, GP015351
The Hon. Debre Katz Weintraub, David Cowan, Yolanda Orozco, Judge(s)
After a decision by the Federal District Court of Oregon
The Hon. Michael H. Simon, U.S. Dist. Judge, Case No.3: 17-cv- 1075-SI
PETITION FOR COURT'S LEAVE FOR FEDERAL COURT'S ORDER PURS. §§850-859
Case: 17-35742, 05/23/2018, ID: 10886851, DktEntry: 19, Page 8 of 16
Case 3:17-cv-01075-SI Document 18 Filed 09/14/17 Page 2 of 10
property belonging to the probate estate of Felicitas Castaneda. The Estate proceedings
are pending before the Los Angeles Superior Court, as the decedent was a resident of Los
Angeles County at the time of her death. As clearly and abundantly stated, petition and
pleaded to the Los Angeles Superior Court at Pasadena and Los Angeles before matter(s)
of Civil Proceedings and Probate had been closed due to the ongoing court corruption at
Pasadena. The Respondents and Defendants are holding, illegally and against the law,
property that undeniably belongs to the Estate and who are corporations who are
registered to do business in California and are therefore subject to the jurisdiction of this
Court. This Hon. Ninth Circuit Court therefore has jurisdiction over the subject matter of
the petition and the parties, and venue is proper in this Court.
for the Estate of Felicitas Castaneda, deceased, and brings this action in such capacity. At
no time whatsoever the estranged siblings of Mrs. Castaneda ever contested nor appear in
person to opposed to the Estate Proceedings properly filed and noticed by now disbarred
(S221442) attorney Jack Kenneth Conway SB#45063. Instead, 25 days prior to the
21 PETITION FOR COURT'S LEAVE FOR FEDERAL COURT'S ORDER PURS. §§850-859
Case: 17-35742, 05/23/2018, ID: 10886851, DktEntry: 19, Page 9 of 16
Case 3:17-cv-01075-SI Document 18 Filed 09/14/17 Page 3 of 10
Conservatorship of the Person and of the Estate Petition Case GP013531 intended to
cover-up the looting and theft of funds from Mrs. Castaneda's accounts.
3. To further cement and continue with the "fraudulent and corrupt activities" by
these so called Judicial "Officers of the Court" on April 16, 2008, both attorney Conway
and MacCarley appeared in Dept. "S" at the Pasadena Superior Court to "dismiss" case
Abuse" of Mrs. Castaneda that5 Mrs. MacCarley had already sent settlement agreements
to former Attorney Chad Pratt, that instead of informing client(s) the Castaneda's, he,
Attorney Pratt was demanding $10,000.00 dollars more in addition of the initial $7,500
already paid to him with no bill of particulars provided to clients. On April 16, 2008
Judge Jean Plume "Order All Matters to Probate" as proven by the Minute Order by the
4. Again, On April 23, 2008, the same "Judicial Corrupt Shenanigans" continue
when Attorney Jack Kenneth Conway appeared with attorney Susan Formaker to
dismissed the case GC039473, Castaneda v. CHASE Bank Et Al, a Declaratory Relief
case of an "investment" that had been partially discovered after the testimony of attorney
Sonia Maria Mercado that all of a sudden suffers amnesia and "forgets" where Mercado
banks, what the name of the her bank is, or her Bank Account Number or her Signature
on checks paid to Attorney Mercado and cashed as Retainer for the Murder of Luis
Castaneda while in custody at Men's Central Jail. The case settled for $400k when
3 PETITION FOR COURT'S LEAVE FOR FEDERAL COURT'S ORDER PURS. §§850-859
Case: 17-35742, 05/23/2018, ID: 10886851, DktEntry: 19, Page 10 of 16
Case 3:17-cv-01075-SI Document 18 Filed 09/14/17 Page 4 of 10
millions are still missing from the Estate. Did attorney Flanagan or Attorney Anderson
5. On January 9, 2009, Attorney Lisa Marie MacCarley illegally and corruptly filed
Case GC042105, titled Ramirez v. Castaneda, a "Partition" case against the Executor of
the Estate of Castaneda. The Matter was assigned to former Judge DeVanon in Dept "S"
On January 26, 2009, Court Proceedings, the court had information and was
Conway. At said hearing, the Executor of the Estate stipulated to the court the necessity
Solicitation of a Bribe by Judge DeVanon when he stated in open court and on the record:
"Let Me Get Some" Thereafter, an after "informing" the Presiding Judge Mary House
DeVanon, the judicial corrupt Shenanigans began by the "hiding" or removing of an MC-
50 Substitution of Attorney filed by Emahn Counts purportedly as told to the State Bar
of California on Friday, February 19, 2010. The removal was intended to deny the Estate
and the Executor Due Process and Equal Protection under the 14`' Amendment of the US
Constitution. Attorney Emahn Counts, who was a willing participant of the Fraud to steal
from the Estate, instead falsely claimed to be "a Judicial Error" and blamed Judge
DeVanon. Counts absence in court on 2/22/2010 proves he was part of the scam.
PETITION FOR COURT'S LEAVE FOR FEDERAL COURT'S ORDER PURS. §§850-859
41
Case: 17-35742, 05/23/2018, ID: 10886851, DktEntry: 19, Page 11 of 16
Case 3:17-cv-01075-SI Document 18 Filed 09/14/17 Page 5 of 10
6. For proof of his participation in the Judicial R.I.C.O., A) on February 22, 2010,
attorney Emahn Counts used the "Bait and Switch" of Attorney by sending Attorney
Sevag Nigoghosian and then informing State Bar investigator Leilane Lasola: "that
attorney Steve Levy appeared at the hearing and that the Judge reuse to continue the
matter. " Which lie is the truth Mr. Counts? [See State Bar Complaint 15-12406].
7. In fact, no continuations were where ever neither afforded nor provided to the
Estate. B) Yet, Attorney MacCarley continues to intentionally lied multiple times to the
Court as she had already had purchased a decision for "Partition" from Judge DeVanon.
On 2122/2010, MacCarley stated on the record re: the missing/hidden MC-50 that Counts
stated he filed on 2/19/2010: "I am the easiest human being in the planet to get a hold
off, I can be reached by email. cell Phone, fax Mr. Counts never contacted me."
legally "forced" to respond to this question? Did Counts faxed to you the MC-50 SOA?
Mercado's bank, Mrs. Mercado filed a declaration submitted under the penalty of perjury:
"I never had anything to do with HOW Mrs. Castaneda spent her settlement money,
had no involvement with WHERE she invested it, or WHAT she did with it." Mrs.
Mercado shall be forced to answer WHO was involved in the "telephonic withdrawals"?
D) Disbarred attorney Conway by far will top the list of liars and perjurers before any
court. First of all, what attorney with any legal standing intentionally dismissed two cases
PErrnON FOR COURT'S LEAVE FOR FEDERAL COURT'S ORDER PURS. §0850-859
51
Case: 17-35742, 05/23/2018, ID: 10886851, DktEntry: 19, Page 12 of 16
Case 3:17-cv-01075-SI Document 18 Filed 09/14/17 Page 6 of 10
Conversion, Elder Abuse GC039459, Castaneda v. Ramirez that had been proven beyond
a reasonable doubt and the preponderance of evidence that financial Elder Abuse of Mrs.
Castaneda occurred! How can Mrs. Castaneda spend well over $130,000.00 in a matter of
Castaneda, exited with Mr. Conway exit the courtroom of Judge Miller as Conway
I was not aware that telling the truth to a Judge was humiliating? Fact is that Mr. Conway
had knowingly lied about when he was retained for the matter Mercado v. Castaneda. In
essence, the Entry of Default that Mr. Paz had "gamed" with Conway to "force" me to
settle had backfired on them. Mrs. Castaneda and I possess an Attorney's Contract
Agreement dated January 4, 2008 for the 2 Cases GC039459 and GC049743; and
subsequently, I rehired him on December 17, 2008 for the Mercado v. Castaneda that
After the Court Clerk administered the Oath to Mr. Conway, he was asked: When
were you retained for this case? Conway: "You honor, I was retained on February Z,
February 3" ACLU former Vice-president would provide this honorable court all
communication had with Mr. Conway from December 3, 2008 until the present to further
prove that Mr. Conway lied to the Court, lied to the Judge, lied to his clients for a profit.
9. This Court should find this matter appropriate for decision without any Oral
Arguments for that it is a "straight forward" where the attorneys stole my inheritance; a
61 PETITION FOR COURT'S LEAVE FOR FEDERAL COURT'S ORDER PURS. ¢§850-859
Case: 17-35742, 05/23/2018, ID: 10886851, DktEntry: 19, Page 13 of 16
Case 3:17-cv-01075-SI Document 18 Filed 09/14/17 Page 7 of 10
lien has been filed in the Probate Case and would like to pay Attorney Paz. Based on the
pleadings submitted to the Oregon Court, this Probate Case addresses noncompliance
with a Probate Court refusal to entertain an 850 — 859 Motion for the Return of property
prematurely taken from the Estate in 2012, this clearly will fall within the purview of
administering the Estate of Felicitas Castaneda and, therefore places it under the Probate
For the foregoing reasons, the Executor of the Estate prays and hopes this
Honorable court will grant Leave for an Order to Judge Weintraub to enforce the law.
Plaintiff,
V.
Defendants.
Plaintiff purported to remove this case to this Court from a California state court. Under
28 U.S.C. § 1441(a), the removal of a civil action pending in state court must be "to the district
court of the United States for the district and division embracing the place where [the state]
action is pending." This Court sits in Oregon and lacks removal jurisdiction over this case.
IT IS SO ORDERED.
PAGE I — ORDER
Case: 17-35742, 05/23/2018, ID: 10886851, DktEntry: 19, Page 15 of 16
Plaintiff, JUDGMENT
V.
Defendants.
PAGE I — JUDGMENT
Case: 17-35742, 05/23/2018, ID: 10886851, DktEntry: 19, Page 16 of 16
Case 3:17-cv-01075-SI Document 18 Filed 09/14/17 Page 10 of 10
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