7-9-2024 -State Bar of California -Complaint Against Attorneys

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2216 Katzakian Way

Lodi, CA 95242
Phone: 209-687-1180
Fax: 209-729-5154
E-mail: jjw1980@live.com

July 9, 2024

Via FAX and US Priority Mail

The State Bar of California


OFFICE OF CHIEF TRIAL COUNSEL INTAKE
Los Angeles Office
845 South Figueroa Street
Los Angeles, CA 90017

SAN FRANCISCO OFFICE


180 HOWARD STREET
SAN FRANCISCO, CA 94105

Subject:
Complaints against Porter Scott Law Corporation and former and present Porter Scott
attorneys Michael William Pott, SBN 186156; David P. E. Burkett, SBN 300933; Lindsay A.
Goulding, SBN 227195; Derek J. Haynes, SBN 227195; and Karen M. Bray, SBN 175501; a
from Horvitz and Levy LLP

Dear Chief Trial Counsel:

I. INTRODUCTION

This cover letter is a short version of the enclosed Addendum to the State Bar of California
Attorney Misconduct Complaint Forms.

With this cover letter, I am enclosing five State Bar of California Attorney
Misconduct Complaint forms and an Addendum with 88 exhibits, which is a detailed
chronology of the alleged criminal misconduct by Porter Scott and Horvitz & Levy LLP
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Cover Letter – Complaint against Porter Scott and Horvitz and Levy Attorneys
attorneys between October 2018 and August 2023. These instances of misconduct are related
to their involvement in my wrongful termination case against the Regents of the University of
California (UC Regents), nine individual defendants, and my unemployment insurance
benefits case against the California Unemployment Insurance Appeal Board (CUIAB).

II. THE CRUX OF THIS COMPLAINT


This complaint is a detailed and documented factual case example of how these attorneys
acted with criminal intent, conspiring with judicial officers and court staff from
Sacramento County Superior and the Court of Appeal, Third Appellate Court (3DCA).
They operated to trample and denigrate justice by making sure their victims, at all times,
are denied fair and impartial judges and instead delivered a bought-off or blackmailed
biased judge or justice who produces unlawful court orders, judgments, and opinions.
In January or February 2021, the Porter Scott law firm and its attorneys, who
supposedly represented the Regents of the University of California in my wrongful
termination case, were informed that Sacramento County Superior Court Judge David I.
Brown, from Law and Motion Department 53, would be removed from the bench and forced
to resign.
The firm and its attorneys were also informed at the same time that Judge Brown, who
had presided over my wrongful termination case since September 2014, would be replaced by
Judge Shama Hakim Mesiwala and the former UC General Counsel Intern and former Porter
Scott attorney George Acero as a backup judge in Departments 53 and Department 54 (Law
and Motion). Acero had notoriously represented the UC Regents since 2003, until he was
installed as a Sacramento County Superior Court in June 2021. I am quite positive and sure
that it was George Acero who in January 2020 informed former Porter Scott attorney
Michael Pott and others about incoming changes in the Sacramento County Superior Court
Department 53 more than one year prior his appointment as Judge in the Sacramento Superior
Court .
Porter Scott attorneys Lindsay Goulding, Derek Haynes, Thomas Riordan, and two
former Porter Scott Attorneys, Michael Pott and David Burkett, who resurfaced in my

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Cover Letter – Complaint against Porter Scott and Horvitz and Levy Attorneys
wrongful termination case in August 2021, waited for more than one year, until Judges
Mesiwala and Acero were installed in Sacramento Superior Court, before launching in April
2021 a coordinated attack aimed at my wife and me, with the criminal intent of robbing my
wife of her life savings and ending my wrongful termination lawsuit against the UC Regents.
They did this by employing the corrupt Judge Thadd Blizzard and his clerk with a totally
fraudulent and unlawful MSA/MSJ motion granted to them on September 1, 2021 by Judge
Cristopher Krueger, from Law and Motion Department 54, who was perhaps blackmailed by
the Porter Scott attorneys because of his previous employment with the California Attorney
General’s office.
This happened because, in January 2020, Porter Scott and Horvitz & Levy attorneys
were informed that 3DCA’s Presiding Justice, VANCE RAYE, would be removed by a witch
hunt that had been launched in November 2020 under the direction of the Director and Chief
Counsel of the Commission of Judicial Performance (CJP) Gregory Dresser.
At some point between October 2017 and December 2019, Judge David I. Brown and
Presiding Justice Vance Raye became a problem and obstruction for Dresser and the
attorneys representing the UC Regents; thus, the decision was made to remove them.
After Judge Brown was expelled in January 2021 and Chief Justice Vance was
expelled on June 1, 2022, Michael Pott , David Burkett Derek Haynes , Lindsay Goulding,
Thomas Riordan, Karen Bray, and Thomas Watson were free to do whatever they desired in
pursuit of their goal of robbing my wife of her life savings and ending my wrongful
termination by employing corrupted judges and court staff to derail my appeal in 3DCA,
which never should have taken place.
I have detailed in my Addendum to the State Bar of California Attorney Misconduct
Complaint Forms the events surrounding this rigged appeal by the above-listed attorneys,
judicial officers, and staff from Sacramento County Superior Court and 3DCA.

III. PORTER SCOTT AND HOROWITZ & LEVY ATTORNEYS’ CRIMINAL


MISCONDUCT, WHICH MUST BE INVESTIGATED AND PROSECUTED BY
THE STATE BAR OF CALIFORNIA’S OFFICE OF THE CHIEF TRIAL

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Cover Letter – Complaint against Porter Scott and Horvitz and Levy Attorneys
COUNSEL (OCTC)

A. The July 2, 2021 Porter Scott attorneys’ attack on my wife, which resulted in
them extorting $22,284 from her.

My wife and her saving accounts became a point of interest to the Porter Scott attorneys
after I dismissed my drug-addicted attorney, Douglas Stein, from my wrongful
termination case on December 16, 2014 and one month after Michael Pott left the Porter
Scott firm. Pott conspired with Stein, and they used their friendship with a Sacramento
County Superior Court judge to terminate my lawsuit against the UC Regents in
December 2014. Stein was financially devastated at the time, so the opportunity
presented to him by Pott to make $300,000 for himself was irresistible. This was a token
amount, in comparison to the money attached to the overall scheme. The plan did not
work as they anticipated, however, and thereafter my wife became a target and blackmail
tool to convince or force me to drop my lawsuit against the UC Regents.

The first attack and vile threats aimed at my wife were delivered on February 27, 2015
by Douglas Ropel, on David Burkett’s behalf. This occurred in Sacramento County
Superior Court, prior to a hearing with Judge Shelleyane Chang in the Writ of
Mandamus Case No. 34-2013- 80001699, Jaroslaw Waszczuk v. California
Unemployment Insurance Appeal Board (CUIAB) and Real Party of Interest (RPii)-
The Regents of the University of California (UC Regents), which was filed on
December 2, 2013.

The second attack and vile threats aimed at my wife Porter Scott were delivered by David
Burkett himself on August 28, 2017 in 3DCA, after oral arguments in Waszczuk v. The
Regents of the University of California et al., Case No, C079524 (anti-SLAPP motion). In
reporting this incident to the Courts and the State Bar of California, I described it as follows:

On August 28, 2017 after oral arguments in Jaroslaw Waszczuk v. The


Regents of the University of California 3DCA Case No. C079524 Porter Scott

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Cover Letter – Complaint against Porter Scott and Horvitz and Levy Attorneys
attorney Burkett, infuriated by statements made by the Court of Appeals Justice
Vance W. Raye during the oral argument hearing and anticipating the Court’s
decision, snapped and unloaded his anger on me and my wife making vile threats
against us. I thought that Burkett’s unwarranted attack in the 3DCA building
would lead to fisticuffs. Burkett instead became angered to the brink of beating up
a 66-year-old old man right there in the halls of justice. Fortunately for me, I was
accompanied by a friend.

The third set of attacks occurred between October 2018 and February 2019. Unlike the
previous threats, these attacks were aimed at my wife’s bank account and life savings. David
Burkett and his new assistant, Daniel Bardzell, acted with criminal intent, bypassed Judge
Brown in Dept. 53, and employed a compromised judge, Christopher Krueger from
Department 54 (Law and Motion), and his friend Judge Jennifer Rockwell, from Department
37 (Order & Examination -OX), in an evil and orchestrated attempt to obtain unlawful
termination sanctions and information about my wife’s bank and 401(K) accounts with intent
to rob her of her life savings. Judges Krueger and Rockwell both worked for State of
California Attorney General Bill Lockyer on the case State v. All Persons, 152 Cal.App.4th
1386 (Cal. Ct. App. 2007). When this plan failed, the Porter Scott attorneys Burekett and his
assistant Daniel Bardzell spent a year bullying Judge Brown, in an attempt to force him to
sign an order for termination sanctions. Judge Brown refused to bend to their evil demands
and was removed from the bench and replaced by a judge more friendly to them, Judge
Shama Mesiwala and the former Porter Scott attorney George Acero as a back up Judge
in Sacramento County Superior Court Law and Motion Departments 53 & 54.

I noticed from the State Bar Case In the Matter of: John Charles Eastman Case No.
SBC-23-0-30029- YDR that Assistant Chief Trial Counsel Rachel S. Grunberg joined the
OCTC on June 3, 2024 as a Supervising Attorney under Duncan Carling to finalize the
prosecution and disbarment or Dr. John Eastman.
I am mentioning Ms. Grunberg here because she, together with State Bar General
Counsel Vanessa Holton and Director and CEO Leah T. Wilson, assisted me in 2019 in
dealing with the State Bar of California’s Client Security Fund (CSF) to recover money
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Cover Letter – Complaint against Porter Scott and Horvitz and Levy Attorneys
that was stolen from me by Douglas Stein in 2014. In the process of recovering this
stolen money, Grunberg, Wilson, and Holton were informed on many occasions about the
Porters Scott attorneys’ criminal activities in the courts and the attacks on my wife.
One of my letters addressed to Grunberg and Holton, dated May 4, 2019, was entitled
“REQUEST TO STOP PORTER SCOTT LAW FIRM FROM ATTACKING MY
FAMILY, ESPECIALLY MY 68-YEAR-OLD WIFE.” In it, I wrote:

With this inquiry, I am asking the State Bar of California to stop the
licensed California gangsters from the Porter Scott Law Firm, paid by the
UCOP mafia, led by Janet Napolitano since 2013 from attacking my family
and especially my 68-year-old wife. My family and especially my wife
have nothing to do with the University of California, UCOP, and the Porter
Scott Law Firm thugs
I am not only addressing further gross professional misconduct of
the above captioned attorneys employed by Porter Scott, but I am also
requesting proper action from the California State Bar enforcement to stop
UCOP thugs and prevent the another tragedy. I would like to remind the
State Bar that Douglas Stein’s friend, Todd Goerlich who replaced me at
the UC Davis Medical Center, was hung in Rancho Cordova Park in
December 2010 leaving behind a one-year-old daughter, Olivia, who never
got a chance to know her father.
In 2011 and 2012, my psychologist Dr. Franklin Bernhoft’s life was
devastated by UCOP in an attempt to provoke and harm his 68-year-old
wife who was framed in much the same way Senator Leland Yee was
framed.
By bringing Grunberg in this complaint, I am hoping that she, as an Assistant Chief Trial
Counsel, will be helpful in resolving my complaint, taking into account her knowledge
about my past struggles against clique of criminally minded Porter Scott attorney and
corrupted judicial officers and staff from two Sacramento Courts .

The fourth and final attack aimed at my wife occurred between April and July 2021 and
was carried out in coordinated action and conspiracy by Lindsay Goulding, Derek Hayes,
Michael Pott, David Burkett, Judge Thadd Blizzard and his clerk, and Judges Shama Hakim
Mesiwala and George Acero. This was a copycat attack of their actions between October

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Cover Letter – Complaint against Porter Scott and Horvitz and Levy Attorneys
2018 and February 2019. The difference this time was that different judges were involved in
the attempt to rob my wife of her life savings.
Another difference was that, in 2018, in addition to the UC Regents as a Defendant, five
individual defendants (UC Davis Medical Center employees) were included in my wrongful
termination lawsuit. They were Mike Boyd, Stephen Chilcott, Brent Seifert, Danseha Nichols,
and Cindi Ortopeza, the “FORMER DEFENDANTS” who demanded legal fees for the anti-
SLAPP award to individual defendants and sanctions paid to the UC Regents.
In October 2019, Bardzell and Burkett were informed that I had received $25,000 from my
wife to take care of their multiple extortion attempts, which began in 2015. The problem was
that they wanted me to write a check to the UC Regents; however, The Regents were not a party
of the anti-SLAPP motion and were prohibited by a court orders from cashing any check related to
the motion. It came to the point that, in a court hearing on December 13, 2019, Judge Brown
admonished Bardzell and ordered him to return the $1,300 sanction check that I had paid on
November 18, 2019 to The Regents. Judge Brown explained to Bardzell that The Regents
were not defendants in the anti-SLAPP motion and therefore not entitled to any money from
the anti-SLAPP motion. Bardzell returned the uncashed check on January 8, 2020 and soon
left the Porter Scott firm.

In January 2020 or thereabouts, Porter Scott’s attorneys were tipped off that Judge Brown
would be removed from Department 53 and replaced by Porter Scott’s attorneys friends.

As a part of their criminal intent to rob my wife of her life savings, they ambushed her with a
CIVIL SUBPOENA (DUCES TECUM) FOR A PERSONAL APPEARANCE AND
PRODUCTION OF DOCUMENTS and extorted from her $22,284, pretending to represent
“former defendants” in wrongful termination case no. 34-2013-00155479, Jaroslaw
Waszczuk v. The Regents of the University of California; Jaros/aw Waszczuk v. UC Davis,
UC Davis Health System, UC Davis Medical Center, The Regents of University of California,
Ann Madden Rice, Mike Boyd, Stephen Chilcott, Brent Seifert, Charles Witcher, Dorin
Daniliuc, Patrick Putney, Cindy Oropeza, which was filed on December 4, 2013. My wife

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Cover Letter – Complaint against Porter Scott and Horvitz and Levy Attorneys
had no idea what this subpoena meant. The full details of the ambush are in the attached
Addendum to the State Bar of California Attorney Misconduct Complaint Forms.

I recorded the July 2, 2021 ambush as follows:

On July 2, 2021, having no other choice, I arrived at Sacramento County Superior Court
in Dept. 43, per JUDGE THADD BLIZZARD’S altered and redacted Order dated May 7,
2021.
My wife, IRENA WASZCZUK, who has been the target of the Porter Scott attorneys’
criminal activities since February 2015, arrived with me and my good friend and former co-
worker from the UC Davis Medical Center, WILLIAM BUCKANS, who has been a witness
to GOULDING’S and Department 43 Clerk ‘s harassment and psychological assault aimed
at my my wife IRENA WASCZUK. My former coworker William BUCKANS has always
attended the court hearings in Sacramento Court with me, due to the previous vile threats by
Porter Scott’s attorneys in the Court against me and my wife. The threats have been reported
to the Court and the State Bar.
Upon arrival in Dept. 43, I noticed on the information board that Porter Scott attorney and
shareholder DEREK HAYES was the one who should conduct interrogation of my wife
IRENA WASCZUK . However, HAYES was not present in the Court Room Department
43. HAYES’s name appeared two replies to my December 4, 2019 opposition to Porter
Scott’s filed motion naming DANESHA NICHOLS, STEPHEN CHILCOTT, BRENT
SEIFERT, MIKE BOYD, and CINDY OROPEZA in their pleadings as FORMER
DEFENDANTS. One reply was filed on December 4, 2019 and entitled “Reply to No
Opposition” (Exhibit #9_. a second reply on December 6, 2019, (Exhibit #10 ) in this
addendum

Porter Scott’s attorney LINDSAY GOULDING appeared at the hearing and said she
was the one who was set and running whole interrogation on behalf of the UCOP. After
the bailiff checked the names of the participants in the Court hearing, the court clerk or

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Cover Letter – Complaint against Porter Scott and Horvitz and Levy Attorneys
judge’s assistant (an African-American woman whose name I do not know) became
very active and pushy to get my wife interrogated. Then, I asked what happened to
my Ex Parte Application for a continuance of the hearing submitted to the Court
on June 30, 2021. Clerk responded that she did not get the document and tried to begin
my wife’s interrogation. GOULDING was sitting there, but said nothing. Finally, I told
the CLERK that there would be no interrogation of my wife in this courtroom, and I
informed her that I have a check with me in the amount of $22,284 to pay whatever
should be paid. (EXHIBIT #39, on flash drive and DVD)

The CLERK did not like this and unprofessionally insisted on moving forward with
the interrogation of my wife . The CLERK tried to cut me out, stating that I was not a
party of the examination. I told her again that there would be no examination of my wife,
and I asked GOULDING to whom I should write the check. The CLERK interfered and
said that she does not know how to proceed. She then went to the judge’s chambers to get the
judge. After 10 minutes, Judge THADD BLIZZARD appeared on the bench completely
unprepared for the hearing and not knowing what the examination was to be about or
to control the damages he pretended that he does not know what is going on. JUDGE
BLIZZARD started looking with the clerk for a Polish translator for my wife, even though I
had written a check for $22,284. Porter Scott Attorney LINDSAY GOULDING , Department
43 CLERK and JUDGE BLIZZARD were totally unprepared for such outcome and they were
caught of guard. Finally, I forced GOULDING to look at the check, which I issued to the UC
Regents showed her my wife’s most recent Bank of America statement, which verified that
there were more than enough funds to cover the $22,284 check. GOULDING at first did not
want to take the check but he looked at JUDGE and CLERK left the court unhappy with the
$22,284 bluntly stolen from wife’s account. She was told loud and clear not to harass and
terrorize my 70 years old wife ever. . After I and my wife left court on that day , JUDGE
THADD BLIZZARD to further intimidate my wife ordered her to return on August 6, 2021
if the case is not settled :

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Cover Letter – Complaint against Porter Scott and Horvitz and Levy Attorneys
Hopefully, the OCTC will take seriously my complaint and convince the Porter Scott law
firm to return the money stolen from my wife.

IV. CONCLUSION

In light of the provided facts, events, and exhibits provided in this cover letter and the
Addendum to the State Bar of California Attorney Misconduct Complaint Forms, I am
respectfully requesting that the OCTC launch a full investigation against the Porter Scott
Professional Corporation and those attorneys listed in the complaint and that they be
prosecuted to the full extent of the law, on account of their professional and criminal
misconduct, which has included but is not limited to:
1. Conspiracy with corrupt or blackmailed judicial officers and court staff
from Sacramento County Superior Court and 3DCA to produce for them unlawful
court orders and opinions to end my wrongful termination lawsuit. Their criminal
misconduct and conspiracy with judicial officers and court staff violated my right
to equal access to justice and has caused to me irreparable damages amounting to
hundreds of thousands of dollars.
2. Conspiracy with corrupt or blackmailed judicial officers and court staff from
Sacramento County Superior Court, which resulted in the theft by extortion of
$22,284 from my wife on July 2, 2021.
3. Conspiracy with corrupt or blackmailed judicial officers and court staff from
Sacramento County Superior Court with the criminal intent of robbing my wife of
her life savings.
Furthermore, I am respectfully requesting that the State Bar OCTC investigate who, in
January 2020, informed the Porter Scott Professional Corporation and its attorneys that

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Cover Letter – Complaint against Porter Scott and Horvitz and Levy Attorneys
Judge David I. Brown from Department 53 would be removed from the bench at the end
of the year and replaced with Judge Shama Hakim Mesiwala and George Acero.
Such information, provided to these attorneys 11 months prior to Judge Brown’s removal,
led to my request for a court trial, which I submitted on March 3, 2020, being ignored.
The judicial process was delayed for more than one year and resulted that my wife was
attacked by criminals attempting to rob her of her life savings .
The disclosure of Judge Mesiwala’s and George Acero’s appointments to the bench
indicates a conspiracy and renders these judges illegitimate.

After I learned that Judge Mesiwala had replaced Judge Brown, I almost instantly
disqualified her from my case by a written peremptory challenge, based on CCP 170.6. It
did not help me much in the battle against the corruption orchestrated by the Porter Scott
attorneys in the Sacramento Courts. My wife and I are not the only victims of the Porter
Scott thugs and their friends from the Sacramento Courts, but that is not the subject of
this complaint.

Also , I am requesting that State Bar OTCT investigate who provided information
to Porter Scott and Horowitz and Levy attorneys in November 2020 or later that 3DCA
Presiding Justice Vance Raye is being investigated and is subject to be removed from his
post in 3DCA . Premature disclosure and believe unlawful information disclosure to
Porter Scott’s and Howrovitz and Levy’s attorneys about investigation aimed at Justice
Vance Raye lead to conspiracy between the Porter Scott ‘s , Horvitz and Levy’s attorneys
and corrupted judicial officers and courts staff witch resulted in rigged appeal and

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Cover Letter – Complaint against Porter Scott and Horvitz and Levy Attorneys
issuance totally nonsense and unlawful 3DCA opinion Waszczuk v. Regents of the Univ.
of Cal., No. C095488, which never should have been issued.

The details how the appeal was rigged by Porters Scott’s , Horvitz and Levy’s attorneys and
courts staff are provided in my Addendum to the State Bar of California Attorney
Misconduct Complaint Forms sent by US Priority Mail .

Porter Scott attorneys conspiracy with courts judicial officers and their criminal activities in
the court of law cost me hundred of thousand of dollars and devastation of my life . I am not
sure whether in course of the 10 years long litigations in Sacramento courts I was dealing
with the gang of drugs addicts with J.D degrees who are were preyed on vulnerable litigants
and their family members or just judicial system is totally corrupted .

Respectfully submitted on July 9, 2024.

_________________________
Jaroslaw Waszczuk

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Cover Letter – Complaint against Porter Scott and Horvitz and Levy Attorneys
THE STATE BAR OF CALIFORNIA
OFFICE OF CHIEF TRIAL COUNSEL INTAKE
LOS ANGELES OFFICE
845 SOUTH FIGUEROA STREET
LOS ANGELES, CA 90017

SAN FRANCISCO OFFICE


180 HOWARD STREET
SAN FRANCISCO, CA 94105

JAROSLAW JANUSZ WASZCZUK’S ADDENDUM TO THE ATTORNEY


MISCONDUCT COMPLAINT FORMS

JAROSLAW JANUSZ WASZCZUK’S COMPLAINT AGAINST PORTER


SCOTT LAW CORPORATION AND FORMER AND PRESENT PORTER
SCOTT ATTORNEYS, MICHAEL WILLIAM POTT, SBN 186156; DAVID P. E.
BURKETT, SBN 300933; LINDSAY A. GOULDING, SBN 227195; DEREK J.
HAYNES, SBN 227195; AND KAREN M. BRAY, SBN 175501 AND FROM
HORVITZ AND LEVY LLP

Jaroslaw Waszczuk
2216 Katzakian Way
Lodi, CA 95242
Phone: 209-687-1180
Fax: 209-729-5154
E-mail: jjw1980@live.com

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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


I.
INTRODUCTION
This complaint is related in some way to the recent complaint I submitted on September 25, 2023
to the State Bar of California’s Chief Trial Counsel (OCTC) against the State of California
Commission on Judicial Performance Director and Chief Counsel, GREGORY PAUL DRESSER,
SBN 136532, State Bar Case No. 23-O-23-272; former State Bar of California Deputy Trial
Counsel LAURA ANN HUGGINS, SBN 136532, State Bar Case No. 23- O-23273; and Senior
Trial Counsel ROBIN BRUNE. California Supreme Court Case No. S285262 (EXHIBIT #1 on
flash drive and DVD).
These five Attorneys, due to their criminal misconduct and criminal intent, do not deserve
to be licensed by the State Bar of California to practice law, and their licenses should be
revoked.

If the OCTC investigator reads this complaint, it will be clear that my wife of 53 years, Irena
Waszczuk, is a key subject of this complaint. She is in no way associated with any of my
legal matters or litigation against the Regents of the University of California, yet she was
harassed from February 2015 through July 2021 by Porter Scott attorneys in conspiracy and
collaboration with corrupt judicial officers and court staff in multiple attempts to steal her life
savings, which she accumulated over 31 years of employment with Nordstrom Corporation,
in Sacramento, CA, where the Porter Scott firm is located.

MICHAEL POTT, DAVID BURKETT, LINDSAY GOULDING, DEREK HAYNES and


KAREN BRAY from Horvitz &Levy and their collaborators’ professional and criminal
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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


misconduct is well documented in the courts’ files. Their brazen and Their brazen and
egregious criminality was so visible that one can only draw one conclusion: the court
orders, decisions, and appellate courts’ opinions were obtained by these attorneys’ collusion,
intimidation, bullying, coercion, blackmailing, extortion, possible bribery and racketeering,
and meddling in and tampering with the judicial process.
Since I filed my wrongful termination case Jaroslaw Waszczuk v. The Regents of the
University of California, Case No. 34-2013- 00155479, on December 4, 2013 in pro per
in Sacramento County Superior Court, instead of San Joaquin Superior Court, the case
eventually turned into battle between GOOD v. EVIL , JAROSLAW WASZCZUK V.
PORTER SCOTT’S attorneys and a group of corrupt judicial officers and staff from
Sacramento County Superior Court, the Court of Appeal’s Third Appellate District, and
the Supreme Court of California.
II.
COURT CASES RELATED TO THIS COMPLAINT

1. STATE BAR OF CALIFORNIA CASE NO.15-0-10110- LMA; CALIFORNIA


SUPREME COURT CASE IN RE STEIN, NO. S245982 (CAL. MAR. 1, 2018)

This case involved my former attorney, DOUGLAS EDWARD STEIN, SBN 131248;
State Bar of California Supervising Senior Trial Counsel ROBERT A. HENDERSON;
Investigator AMANDA GORMLEY; Senior Trial Counsel ROBIN BRUNE;
Investigator Supervisor LAURA L. SHAREK; Deputy Trial Counsel LAURA ANN

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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


HUGGINS; Assistant Chief Trial Counsel Deputy Chief Trial, Interim Chief Trial
Counsel, Acting Deputy Chief Trial Counsel, and Assistant Chief Trial Counsel
GREGORY PAUL DRESSER; and State Bar Judge MARIA LUCY ARMENDARIZ
(see https://www.scribd.com/document/621488012/01-28-2015-State-Bar-o-California-
Complaint-against-Douglas-E-Stein-Case-No-15-0-10110).
WRIT OF MANDAMUS - UNEMPLOYMENT INSURANCE BENEFITS
CASE,STATE BAR OF CALIFORNIA CASE NO.15-0-10110- LMA, Sacramento
County Superior Court Case No. 34-2013-80001699, Jaroslaw Waszczuk v. California
Unemployment Insurance Appeal Board (CUIAB) and Real Party of Interest (Rip)—The
Regents of the University of California (The Regents) was filed in the Court of Appeal on
December 2, 2013 and presided over by Judge SHELLEYANNE W. L. CHANG as
Third Appellate District Case No. C079254, Waszczuk v. CUIAB, California Supreme
Court Case Nos. S253713 & S245879, Waszczuk v. CUIAB.

2. SACRAMENTO COUNTY SUPERIOR COURT WRONGFUL TERMINATION


CASE

Jaroslaw Waszczuk v. The Regents of the University of California, Case No. 34-2013-
00155479, filed on December 4, 2013, and the Court of Appeals ,Third Appellate District
(3DCA) Cases C079524( EXHIBIT #2 on flash drive and DVD. )
& C095488, Waszczuk v. The Regents of the University of California et al., California
Supreme Court Case Nos. S245508 and S281719, involved judges from the County of
Sacramento Superior Court DAVID I. BROWN, Law & Motion Department 53;
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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


CHRISTOPHER E. KRUEGER, Law & Motion Department 53; JENNIFER K.
ROCKWELL, Order of Examination (OX) Department 37; STEVEN H. RODDA, Law &
Motion Departments 53 & 54 (a retired judge on call); THADD A. BLIZZARD, Order of
Examination (OX), Department 43 ; SHAMA HAKIM MESIWALA, Law & Motion
Department 53; and GEORGE A. ACERO, Law & Motion Departments 53 & 54 backup.
3DCA Justices : VANCE RAYE - former 3DCA Presiding Justice ;ANDREA
LYNN HOCH, 3DCA Associate Justice (Retired) RONALD B. ROBIE, 3DCA
Associate Justice, Acting Presiding Justice (June 1, 2022–August 24, 2023), LAURIE M.
EARL, 3DCA Presiding Justice as of July 10, 2023, former Associate Justice and
Sacramento County Superior Court Judge , LOUIS MAURO, 3DCA Associate Justice
since 2010, JONATHAN K. RENNER, 3DCA Associate Justice since 2015
III
ATTORNEYS INVOLVED IN THE LITIGATION

This wrongful termination case involved my former attorney, STEIN, who was disbarred in
January 2020 for professional misconduct; 14 Porter Scott attorneys; and two Horvitz &

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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


Levitz LLP attorneys (listed below), in addition to myself as a pro per litigant. The following
have been involved since December 16, 2014:
1. CHARLES FURLONGE ROBINSON, SBN #113197, UC General Counsel
2. KAREN JENSEN PETRULAKIS, SBN #168732, Chief Deputy UC General
Counsel
3. MARGARET LOUISA WU, SBN 184167, Deputy UC General Counsel
4. CYNTHIA ANN VROOM, SBN 1394700, Deputy UC General Counsel
5. MICHAEL WILLIAM POTT, SBN 186156, Porter Scott attorney & shareholder
6. DOUGLAS LEE ROPEL, SBN 300486, Pott and Burkett’s assistant
7. DAVID P.E. BURKETT, SBN 300933, Porter Scott attorney & shareholder
8. CECILIA GUEVARA, SBN 307159, Burkett’s assistant
9. DANIEL J. BARDZELL, SBN 313993, Burkett’s assistant
10. NASIM SAHAR TOURKAMAN, SBN 300933, Burkett’s assistant
11. CHAMBORD V. BENTON-HAYES, SBN 278970, Burkett’s assistant
12. COURTNEY DE GROOF, SBN 319334, Burkett’s assistant
13. NANCY J. SHEEHAN, SBN 109419, Porter Scott attorney & shareholder
14. AMANDA I. ILER, SBN 300268, Porter Scott senior attorney
15. DEREK J. HAYNES, SBN 264621, Porter Scott attorney & shareholder
16. LINDSAY A. GOULDING, SBN 227195, Porter Scott attorney & shareholder
17. OLATOMIWA T. AINA, SBN 325566, Goulding’s assistant
18. THOMAS L. RIORDAN, SBN 104827, Porter Scott attorney & shareholder
19. KAREN M. BRAY, SBN 175501, Horvitz & Levy LLP attorney & shareholder
20. H. THOMAS WATSON, SBN 160277, Horvitz & Levy LLP attorney &
shareholder
THE CHRONOLOGICAL STATEMENT OF FACTS AND EVENTS
PORTRATING PORTER SCOTT ATTORNEYS MICHAEL POTT, DAVID
BURKETT, DERECK HAYNES, LINDSAY GOULDING, KAREN BRAY AND
THEIR COLLABORATORS’ PROFESSIONAL AND CRIMINAL
MISCONDUCT
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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


IV.
OCTOBER 23, 2019 PORTER SCOTT ATTORNEYS’ MOTION TO COMPEL
RESPONSES TO JUDGMENT DEBTOR INTERROGATORIES AND REQUEST
FOR PRODUCTION OF DOCUMENTS AND FOR MONETARY SANCTIONS,
SACRAMENTO COUNTY SUPERIOR CASE
Jaroslaw Waszczuk v. The Regents of the University of California, CASE NO. 34-2013-
00155479, FILED DECEMBER 4, 2013

A. THE OCTOBER 23, 2019 MOTION AND INDIVIDUAL DEFENDANTS IN


THE LAWSUIT

On October 23, 2019, Porter Scott attorneys NANCY SHEEHAN and DANIEL
BARDZELL filed the last MOTION TO COMPEL RESPONSES TO JUDGMENT
DEBTOR INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS
AND FOR MONETARY SANCTIONS.

The criminal intent and main goal of the attorneys was revealed in their filing of five similar
motions between October 3, 2018 and October 23, 2019, which were combined with the
filed APPLICATION AND ORDERS FOR APPEARANCE AND EXAMINATION with the
aim of terminating my lawsuit against the UC Regents that was filed on December 4, 2014,
extracting information about my wife’s bank and 401(K) accounts, stealing her life savings,
and completely destroying my life and marriage of 50 years.

In their motion filed October 23, 2023, the attorneys made reference to the anti-SLAPP
motion’s individual defendants DANESHA NICHOLS, STEPHEN CHILCOTT, BRENT
SEIFERT, MIKE BOYD, and CINDI OROPEZA by referring to them as “FORMER
DEFENDANTS” (EXHIBIT #3 on flash drive and DVD). This was the first time this
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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


happened since Sacramento County Superior Court Judge DAVID I. BROWN, who had
presided over my wrongful termination case since September 2014, signed on April 14, 2015
a Court Order granting an anti-SLAPP motion to four individual defendants and striking four
causes of action (COA) from my wrongful termination lawsuit. However, the April 14, 2015
order did not dismiss five individual Defendants, DANESHA NICHOLS, STEPHEN
CHILCOTT, BRENT SEIFERT, MIKE BOYD, and CINDI OROPEZA, from the lawsuit
(EXHIBIT #4 on flash drive and DVD).
I am requesting that the OCTC investigate whether these Porter Scott attorneys
represented any individual defendants or not in 2019-2023 listed in my wrongful
termination lawsuit Jaroslaw Waszczuk v. The Regents of the University of California,
CASE NO. 34-2013- 00155479, which was filed On December 4, 2013.
On November 15, 2019, I received correspondence from Porter Scott attorney
DANIEL BARDZELL (EXHIBIT #5 on flash drive and DVD) that was supposed to be a
reply to my October 31, 2019 letter regarding his SETTLEMENT OFFER
(EXHIBIT #6 on flash drive and DVD). In this letter, I was informed that Porter Scott
paralegal MARILYN GAMPER was not permitted to cash the $500 check I sent her on October
31, 2019, following the judgement for the anti-SLAPP motion fees and costs, by which

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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


she and three Porter Scott attorneys, MICHAEL POTT, DOUGLAS ROPEL, and DAVID
BURKETT, had been awarded $22,284 as follows:
Michael W. Pott, 25 hours at $260/hr (reduced from 31.5 hrs) for $6,500;
David P.E. Burkett, 1.2 hours at $260/hr (no reduction) for $312;
Douglas L. Ropel, 40 hours at $260/hr (as an attorney) (reduced from 61.7 hrs)
for $10,400;
Douglas L. Ropel, 30 hours at $100/hr (as a law clerk) (reduced from 43.2 hrs) for
$3,000;
Marilyn Gamper 5.2 hours at $100/hr (no reduction) for $512.
The hours awarded for the work associated with the anti-SLAPP motion and the instant
fee motion totaled 101.4, which had been reduced from 142.8 for a total of $20,724.
The Defendants were also entitled to $166.20 costs in connection with the anti-SLAPP
motion.
In addition, the Court awarded the Defendants an additional 3 hours at $260/hr for work
associated with the reply, for a total of $780.
The total award of costs and fees was $22,284.
The prevailing party was ordered to prepare a formal order for the Court’s signature
pursuant to C.R.C. 3.1312.
On October 31, 2019, I also paid a $520 sanction awarded unjustly to the Defendants by the
Court on 10/31/2018. The check was cashed by the Porter Scott attorneys.
DANIEL BARDZELL, in his threatening correspondence to me, demanded in bold letters
that I issue a check to pay all anti-SLAPP legal fees and costs payable to the Regents of the

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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


University of California, a Defendant not listed in the anti-SLAPP motion.
DANIEL BARDZELL and DAVID BURKETT were informed on August 9, 2019 that the
State Bar of California’s Client Security Fund had reimbursed me for $14,500, which was
stolen from me in 2014 by my attorney DOUGLAS STEIN in collaboration with Porter Scott
attorney MICHAEL POTT and Wells Fargo Bank.
DANIEL BARDZELL and DAVID BURKETT were also informed that, at the end of
October 2019, I received $25,000 from my wife to take care of their multiple extortion
attempts, which began in 2015, using my wife as a blackmail tool to force me to drop my
lawsuit against the REGENTS and nine individual Defendants.

In my November 21, 2019 Meet and Confer letter, I advised DANIEL BARDZELL
regarding the FORMER DEFENDANTS as follows (EXHIBIT #7 on flash drive and
DVD):

Dear Mr. Bardzell,

Please advise me if you want me to re-issue the $1,300 sanction


check to five former individual Defendants—DANESHA NICHOLS,
STEPHEN CHILCOTT, BRENT SEIFERT, MIKE BOYD, and CINDI
OROPEZA—instead of the UNIVERSITY OF CALIFORNIA
REGENTS.

As I advised you a few days ago, the UC Regents should not cash
the $1,300 check I sent to your office on November 18, 2019. The UC

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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


Regents are not the party of the anti-SLAPP motion filed by Porter
Scott’s former attorney Michael Pott on December 1, 2014.

I could write the checks to each former Defendant in the amount


of $260 and send them to your office if you represent them as you
claimed that you do. But are you sure that are the FORMER
DEFENDANTS? It would be better if you ask Judge Brown if they
are the former Defendants before you show up on December 13, 2019
Court hearing to argue whether DANESHA NICHOLS, STEPHEN
CHILCOTT, BRENT SEIFERT, MIKE BOYD, and CINDI OROPEZA
where dismissed from the lawsuit by the Court or by myself.
Porter Scott attorney and shareholder NANCY SHEEHAN, who replaced DAVID
BURKETT and co-authored a October 23, 2019 motion, was gravely ill and died on
November 23, 2019, exactly one month after another motion was filed in Sacramento
Superior Court Law and Motion Department 53 (see
https://www.legacy.com/obituaries/sacbee/obituary.aspx?n=nancy-joan-
sheehanandpid=194994093).

B. MY DECEMBER 4, 2019 OPPOSITION TO THE PORTER SCOTT


ATTORNEYS’ MOTION AND THEIR REPLIES

On December 4, 2019, I filed an opposition to the October 23, 2019 Porter Scott
attorneys’ motion (EXHIBIT #8 on flash drive and DVD). In it, I emphasized again that
the UC Regents were not the defendants in the anti-SLAPP motion and, therefore,

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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


not entitled to any legal fees. This was clearly affirmed by two previous court orders
issued by two different judges, STEVEN H. RODDA and DAVID I. BROWN.

DANIEL BARDZELL and two new attorneys, DEREK HAYES and AMANDA ILER,
filed two replies to my December 4, 2019 opposition to their motion naming DANESHA
NICHOLS, STEPHEN CHILCOTT, BRENT SEIFERT, MIKE BOYD, and CINDI
OROPEZA in their pleadings as FORMER DEFENDANTS. One reply was filed on
December 4, 2019 and entitled “Reply to No Opposition” (EXHIBIT #9 on flash drive
and DVD). On December 6, 2019, they filed a second reply to the opposition (EXHIBIT
#10 on flash drive and DVD).

On Page 5, Paragraph 4 of their December 6, 2019 reply, entitled “Defendant Regents are
Entitled to Payment of Sanctions Awards,” ILER demanded that legal fees be paid to the
UC Regents, in bold letters stating:

Judgment Debtor has cited no legal authority for his position that
the REGENTS are not entitled to the sanction payment. The REGENTS
has paid for the defense of the Judgment Creditors (Iler Deci. ¶ 6).
“A monetary sanction may be based not only on attorney’s fees and
costs, but also on any other reasonable expenses incurred.

Judgment Creditors respectfully request the Court clarify for


Judgment Debtor that the REGENTS is entitled to the payment of

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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


sanction awards so that Judgment Debtor does not continue to use
that as an excuse for not paying the amounts owed.
AMANDA ILER did not provide any court order, declaration, or copy of a Request for
Dismissal stating that DANESHA NICHOLS, STEPHEN CHILCOTT, BRENT
SEIFERT, MIKE BOYD, and CINDI OROPEZA had been dismissed from the lawsuit
and should be regarded as FORMER DEFENDANTS. She also provided no documents
supporting her demand that the REGENTS were entitled to the payment of sanction
awards or to an anti-SLAPP judgement.

It was a puzzle to me why the Porter Scott attorneys were pushing for legal fees for the
anti-SLAPP motion to be paid to the UC Regents, given that this was contrary to two
Court orders stating that The Regents were not a party of the anti-SLAPP motion or
entitled to be paid any money in relation to it.

I could only guess that the insurance company, Sedgwick CMS, which was handling The
Regents’ legal fees for the lawsuit, paid all legal fees due to Porter Scott. Perhaps this
happened after Sedgwick’s investigation department learned from me in May 20215 that
the anti-SLAPP motion filed by MICHAEL POTT on December 1, 2014, which was
initially approved by Sedgwick, was a total fraud that occurred due to a conspiracy with
him and my attorney, DOUGLAS STEIN,, so Sedgwick requested the return of the

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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


money paid as legal fees for the anti-SLAPP motion.

C. THE DECEMBER 13, 2019 COURT HEARING PRESIDED OVER BY


SACRAMENTO COUNTY SUPERIOR COURT JUDGE DAVID I. BROWN,
FROM LAW & MOTION DEPARTMENT 53

On December 12 , 2019, the Court (Judge DAVID I. BROWN) issued a Tentative Decision
granting a MOTION TO COMPEL RESPONSES TO JUDGMENT DEBTOR
INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS AND
FOR MONETARY SANCTIONS. The motion was filed with criminal intent by Porter Scott
attorneys to extort money from my wife (EXHIBIT #11 on flash drive and DVD).
In his Tentative Decision, Judge David I. Brown ruled as follows:

On April 14, 2015, the Court granted Judgment Creditors’ special


motion to strike Plaintiff’s causes of action and entered judgment in
favor of Judgment Creditors. The Court subsequently granted Judgment
Creditors’ motion for attorneys’ fees in the amount of $22,284

The July 19, 2019 order also imposed sanctions against


Plaintiff/Judgment Debtor in the amount of $1,300.

Judgment Debtor/Plaintiff is again ordered to serve Code-


compliant further verified responses to the Judgment Debtor
Interrogatories, Set One, and Request for Production, Set One, without
objections, on or before December 23, 2019.

Judgment Debtor/Plaintiff is also ordered to pay reasonable


monetary sanctions to the moving parties in the amount of $1,300 (5
hours at the hourly rate of $260), for the fees incurred since the Court’s
last order compelling further responses to the same discovery. The
opposition was filed without substantial justification. The monetary

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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


sanctions are to be paid on or before January 13, 2019. If those
sanctions are not paid by that date, the moving parties may prepare a
formal order on the sanction award, which may thereafter entered as a
separate judgment. (See Newland v. Superior Court (1995) 40
Cal.App.4th 608.)

In addition to the above, Judge DAVID BROWN admonished DANIEL BARDZELL during
a December 13, 2019 Court hearing and ordered him to return the $1,300 I paid to the UC
Regents as sanctions on November 18, 2019. Judge Brown explained again to DANIEL
BARDZELL that The Regents were not defendants in the anti-SLAPP motion, thus they were
not entitled to any money from it.

Judge Brown’s Tentative Decision did not address the Porter Scott attorney’s request
concerning whether THE REGENTS were entitled to the payment of sanction awards
or the anti-SLAPP Judgment.

On December 17, 2019, the Court affirmed the Tentative Decision dated December 12,
2019 (EXHIBIT #12 on flash drive and DVD). This was the last order ever issued by
Judge DAVID I. BROWN in my wrongful termination case.

D. AFTERMATH THE COURT HEARING ON DECEMBER 13, 2019 WITH


JUDGE DAVID I. BROWN AND THE DECEMBER 17, 2019 COURT ORDER
THAT GRANTED THE FIVE INDIVIDUAL DFFENDANTS’ MOTION TO
COMPEL RESPONSES TO JUDGMENT DEBTOR INTERROGATORIES AND
REQUEST FOR PRODUCTION OF DOCUMENTS AND FOR MONETARY

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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


SANCTIONS

I did not serve the Code-compliant further verified responses to the Judgment Debtor
Interrogatories, Set One, and Request for Production, Set One, without objections, on or
before December 23, 2019, or thereafter.

I did not pay $1,300 in monetary sanctions before January 13, 2019 or thereafter, as imposed
on me by the December 17, 2019 Court order. If those sanctions were not paid by that date,
the moving parties could have prepared a formal order on the sanction award, which may
thereafter have been entered as a separate judgment (see Newland v. Superior Court (1995)
40 Cal.App.4th 608).

Porter Scott Attorneys DANIEL BARDZELL, AMANDA ILER, and DEREK HAYNES did
not file another MOTION TO COMPEL RESPONSES TO JUDGMENT DEBTOR
INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS AND
FOR MONETARY SANCTIONS OR REMINATION SANCTIONS after December 23,

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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


2019.

After December 13, 2019, DANIEL BARDZELL, AMANDA ILER, and DEREK
HAYNES did not prepare and or submit to the court a formal order on the sanction awarded
them by Judge DAVID I. BROWN
On January 8, 2020, DANIEL BARDZELL returned to me an uncashed sanction check for
$1300.00 with a note that said (EXHIBIT #13 on flash drive and DVD):

Your issuance of this check plainly contradicts the position you


took in your November 21, 2019 email correspondence. However, in
accordance with the court’s guidance at the hearing on the most
recent motion to compel judgment debtor discovery, and to avoid any
uncertainty which may exist with respect to whether you consent to this
check being cashed by the Regents in satisfaction of the sanctions
awarded in connection with the Judgment Creditors’ second motion to
compel judgment debtor discovery, we are returning the check to you.
Enclosed you will find the uncashed subject check in the amount of
$1300 (check No. 139).
The uncashed check was related to the sanctions imposed on me by the Court order on
July 19, 2019.
Shortly thereafter, DANIEL BARDZEL left the Porter Scott firm and I never heard from him
again.
From October 2018 through December 2019, the DAVID BURKETT and DANIEL
BARDZELL bullied Judge DAVID I. BROWN with endless motions for termination

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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


sanctions to end my litigation against the Regents of the University of California and to extort
money from my wife.

E. MY FEBRUARY 18, 2020 MEET AND CONFER LETTER TO DEFENDANTS’


ATTORNEYS DEREK HAYNES and AMANDA ILER, RE: PROPOSED
DATES FOR COURT TRIAL IN MY WRONGFUL TERMINATION CASE
Jaroslaw Waszczuk v. The Regents of the University of California, Case No. 34-
2013- 00155479 Filed on December 4, 2013

On February 18, 2020, I sent a Meet and Confer letter to Defendants’ attorneys DEREK
HAYNES and AMANDA ILER and proposed Court Trial dates of September 1, 8, or 15,
and July 1, 2, or 6, 2020 as Mandatory Settlement Conference dates, in hopes of bringing
this case to trial and resolving it (EXHIBIT #14 on flash drive and DVD).
On February 28, 2020 DEREK HAYNES assistant AMANDA ILER send me e-mail and
in her vague statement she insisted to eventually set the trail date in January / February
2021.

In February 2020 the Porter Scott attorney and shareholder DEREK HAYES already
knew that Judge David I Brown would be removed from the bench and from the
Department 53 and he would be replaced by Judge SHAMA HAKIM MESIWALA in
January 2021 and by former Porter Scott attorney GEORGE ACERO as back-up judge in
Department 53 & 54 ( law and order ) . Any Porter Scott attorneys further effort in 2020
to end my lawsuit by termination sanction or by the motion for summary judgement in

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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


Department 53 with Judge DAVID BROWN would end with a same result as their 2018-
2019 desperate endless motions to end my lawsuit and rob my wife of her life saving .

On March 3, 2020 I submitted to the Court a Submission Form to set Trial Date on August
11 or 18, 2020 or September 28, 2020. EXHIBIT #15 on flash drive and DVD).

The Court did not bother to respond to my Submission to set Trial date .
Thereafter for over one year until April 2021 I heard nothing about the legal fees
or sanctions from AMANDA ILER or DEREK HAYNES . I learned later that
AMANDA ILER followed DAVID BURKETT and DANIEL BARDZELL and ended
her employment with Porter Scott .

V.
APRIL 12, 2021 CIVIL SUBPOENA (DUCES TECUM) FOR PERSONAL
APPEARANCE COMBINED WITH THE APPLICATION AND ORDER
FOR APPEARANCE AND EXAMINATION AND DEFENDANT’S
MOTION FOR SUMMARY JUDGMENT OR, IN THE ALTERNATIVE,
SUMMARY ADJUDICATION-CASE Jaroslaw Waszczuk v. The Regents of
the University of California, Case No. 34-2013- 00155479, filed December 4,
2013
A. CIVIL SUBPOENA (DUCES TECUM) FOR A PERSONAL APPEARANCE
AND PRODUCTION DOCUMENTS DATED APRIL 12, 2021

On April 22, 2021, after silence from the Porter Scott attorneys for 1 year and 4 months,
I was unexpectedly and surprisingly served by hand delivery a CIVIL SUBPOENA
(DUCES TECUM) FOR A PERSONAL APPEARANCE AND PRODUCTION OF
DOCUMENTS in relation to my Sacramento County Superior Court wrongful

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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


termination case Jaroslaw Waszczuk v. The Regents of the University of California, Case
No. 34-2013- 00155479, filed on December 4, 2013 (EXHIBIT #16 on flash drive and
DVD).

The subpoena, dated April 12, 2021, was issued by OLATOMIWA T. AINA, a Porter
Scott attorney previously unknown to me, and was served with an unsigned and undated
PROOF OF SERVICE. On its first page, it stated:
THE PEOPLE OF THE STATE OF CALIFORNIA, TO (name, address, and
telephone number of witness, if known):
IRINA WASZCZUK, 2216 Katzakian Way, Lodi, CA 95242
YOU ARE ORDERED TO APPEAR AS A WITNESS In this action at the date,
time, and place shown in the box below UNLESS your appearance is excused as
Indicated In box 3b below or you make an agreement with the person named In
Item 4 below.
Date: May 7, 2021 Time: 9:00 a.m. 11 Dept: 43 [ Div.: [] Room:
Address: 720 9th Street,, Sacramento, CA959I4

The subpoena for my wife IRENA WASZCZUK was accompanied by an APPLICATION


AND ORDER FOR APPEARANCE AND EXAMINATION and a DECLARATION OF
PORTER SCOTT ATTORNEY OLATOMIWA T. AINA, both dated April 12, 2021 (see
https://www.scribd.com/document/505164449/20210427-Meet-and-Confer-Order-to-Appear-

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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


for-Examination-O-Aina-Porter-Scott).

B. APRIL 12, 2021 APPLICATION AND ORDER FOR APPEARANCE AND


EXAMINATION ISSUED WITH CRIMINAL INTENT BY PORTER SCOTT
ATTORNEY OLATOMIWA T. AINA TO EXTORT MONEY FROM MY WIFE

The APPLICATION AND ORDER FOR APPEARANCE mandated that my wife, IRENA
WASZCZUK, appear on May 7, 2021 at 9:00 AM in Sacramento Superior Court, Department
43 before Judge THADD BLIZZARD (EXHIBIT #17 on flash drive and DVD).
The APPLICATION AND ORDER FOR APPEARANCE I received with a subpoena on
April 22, 2021 was not signed by Judge BLIZZARD prior to being served to my wife.
Furthermore, the two-page attachment contained 21 requests to produce documents upon
arrival for examination by Judge BLIZZARD. Some of the items requested suggested to me
that the Porter Scott attorneys knew more about my wife than I did, despite having been
married to her for more than 50 years.

My wife has never dealt with legal matters and had no clue what the subpoena meant or why
she was being dragged into court. Her ability to understand legal documents in English, on a
scale of 1–10 is around a “1.” I am not an attorney, and in 2021, I had no power to represent
her in filing a motion to quash the subpoena, which was issued with malice to rob my wife
of her life savings.

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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


C. DECLARATION BY OLATOMIWA T. AINA IN SUPPORT OF
JUDGMENT CREDITORS’ APPLICATION FOR APPEARANCE AND
EXAMINATION OF IRINA WASZCZUK
On Page 2 of her declaration, Porter Scott attorney OLATOMIWA T. AINA declared the
following:
I am an attorney at law licensed to practice before all courts in the
State of California and am a shareholder with the law firm of
PORTER SCOTT, attorneys of record for current Defendant
REGENTS OF THE UNIVERSITY OF CALIFORNIA (“Defendant”
or “UNIVERSITY’) and Judgment Creditors/FORMER
DEFENDANTS BOYD, CHILCOTF, NICHOLS, OROPEZA, and
SEIFERT (“anti SLAPP Defendants” or “Judgment Creditors”) in
the above-titled action. I make this declaration in support of
Judgment Creditors’ Application for Appearance and Examination
of Irina Waszczuk and in compliance with Code of Civil Procedure
section 491.110 and 708.120.
This declaration listed five defendants in my wrongful termination lawsuit. STEPHEN
CHILCOTT, DANESHA NICHOLS, CINDI OROPEZA, BRENT SEIFERT, and MIKE
BOYD are “FORMER DEFENDANTS,” and AINA represents, them thus she lied

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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


under the penalty of perjury, according to the laws of the State of California that “the
foregoing is true and correct.”

Perjury under California Penal Code Section 118 PC is a felony


offense that can carry prison sentences of up to four years and could
include substantial court fines.

Business and Professions Code section 6128 which provides that


an attorney is guilty of a crime who:

“(a) Is guilty of any deceit or collusion, or consents to any deceit


or collusion, with intent to deceive the court or any party.”
I noticed on the declaration’s caption page two email addresses,
nsheehan@porterscott.com and dbardzell@porterscott.com. These belonged to former
Porter Scott attorney NANCY SHEEHAN, who replaced DAVID BURKETT and was
assigned to my wrongful termination case on October 23, 2019, just before she died on
November 23, 2019. The second e-mail address belonged to former Porter Scott attorney
DANIEL BARDZELL, who was DAVID BURKETT’S assistant from October 2018
through October 2019, and then an assistant for NANCY SHEEHAN and, later, DEREK
HAYNES, after SHEHAN died. DANIEL BARDZELL resigned from Porter Scott, most
likely in February 2020.

The above-mentioned email addresses indicate that the declaration signed by OLATOMIWA
T. AINA was written in October or November 2019 by DANIEL BARDZELL or NANCY
SHEEHAN for the purpose of extorting money from my wife. As the STATE BAR OCTC

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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


investigator will find in Chapter IV of this addendum, on pages 11–12, on November 21,
2019, in my Meet and Confer letter, I advised DANIEL BARDZELL to clarify with Judge
DAVID I. BROWN whether or not STEPHEN CHILCOTT, DANESHA NICHOLS, CINDI
OROPEZA, BRENT SEIFERT, and MIKE BOYD were former defendants, or if they were
still considered defendants in the lawsuit (see EXHIBIT #7).

It appears that OLATOMIWA T. AINA, in April 2021, was working with Porter Scott attorney
and shareholder LINDSAY GOULDING and as her subordinate and was ordered to sign and
serve court documents with false information and lies. However, a perjurer’s lack of
knowledge of materiality is no defense to the crime (Pen. Code, 123).
During the Court Hearing on February 6, 2015, I requested that the Court (Judge DAVID I.
BROWN) dismiss all individual defendants from the lawsuit. The Court responded as follows
(Court Reporter Transcript pages 17, 19–28, EXHIBIT #18 on flash drive and DVD).
THE COURT:

You can’t do that with respect to you, Mr. Waszczuk, maybe you could have
worked something out with defense before this, but there is case law specifically on
that

All right Here is what I’m going to do, Mr Waszczuk, I’m going to take the
matter under, submission and let you know. If you want to work something out with

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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


Mr. Ropel and his firm, that is fine, and then we can proceed as to the Regents as
to the remainder.—
See also Exhibit 12 in this addendum package.

In September 2015, I intended to file a Third Amended Complaint (TAC) with basically one
Cause of Action that would serve as a Breach of Written Contract or Violation of the
January 2009 Settlement Agreement, with only the Regents of the University of California
as a Defendant. The TAC would have taken care of the Defendants MICHAEL BOYD,
STEPHEN CHILCOTT, DANESHA NICHOLS, CINDY OROPEZA, and BRENT
SEIFERT, and they would have been dismissed.
However, in September, DAVID BURKETT and DOUGLAS ROPEL blocked my effort to
file the TAC using a Motion for Automatic Stay or, in the alternative, Motion for a
Discretionary Stay, which they filed on September 25, 2015. The Porter Scott firm and
attorneys kept the defendants MICHAEL BOYD, STEPHEN CHILCOTT, DANESHA
NICHOLS, CINDY OROPEZA, and BRENT SEIFERT as HOSTAGES in my case until
October 2019, hoping for big ransom from the UC Regents.

D. REQUEST FOR PRODUCTION OF DOCUMENTS ATTACHED TO THE


ORDER FOR APPEARANCE AND EXAMINATION (OX), ISSUED ON APRIL
12, 2021 BY ATTORNEY OLATOMIWA T. AINA WITH CRIMINAL INTENT
BY TO EXTORT MONEY FROM MY WIFE, IRENA WASZCZUK

As noted above, the attached REQUEST FOR DOCUMENTS to the APPLICATION AND
ORDER FOR APPEARANCE contained 21 oppressive requests for production of documents

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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


(EXHIBIT #19 on flash drive and DVD). It mandated that my wife, IRENA WASZCZUK,
appear on May 7, 2021 at 9:00 AM in Sacramento Superior Court, Department 43 before
Judge THADD BLIZZARD. The APPLICATION AND ORDER FOR APPEARANCE I
received with a subpoena on April 22, 2021 was not signed by JUDGE BLIZZARD prior to
being served. The short time between receiving the OX and the examination scheduled for
May 7, 2021 shows that Porter Scott attempted to catch me off-guard, scare me, frame my
wife for criminal prosecution, and rob her of her life savings.

THE REQUEST FOR PRODUCTION OF DOCUMENTS NO. 9


ALL federal and state corporate tax returns YOU have filed from 2012 to the
present time.In 2021, as now, I had no idea why Porter Scott attorneys requested my and
my wife tax returns from 2012.The year 2012 was the worst year for me in United States
since I was forced to leave Poland by its communist government in 1982. In 2015 I lost
my employment five years before my retirement, lost the home we had purchased in
2003, and thereafter lost more than $1 million in wages and benefits (see
https://www.scribd.com/document/666943450/Home-Swallow-Lane-Lodi-Taken-by-
UCOP-Mafia-in-2012
https://www.scribd.com/document/481243073/Damages).

On December 7, 2012, my employment with the University of California was officially


terminated after an unsuccessful attempt to provoke me and end my employment with the
UCDMC. After a heinous act of provocation on May 31, 2012, UCDMC management

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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


pressed or blackmailed by Porter Scott attorneys launched actions against me in preparation
to frame and deport me.

On June 6 , 2012, a UCDMC executive signed Penal Code 626 order to arrest me if I
appeared on the UCDMC premises, followed by an attempt to frame me with the Lodi Police
Department.

On June 21, 2012, UC Davis Police Department Sergeant Garcia Jennifer informed UCDMC
management by e-mail:

“Jerry” is clear any warrants, has no guns registered and no


current dealer of sales for guns and has negative criminal
history. Lodi PD informed they have nothing on him.
On September 26, 2012, I received by overnight mail a Notice of Intent to Dismiss for
Serious Misconduct dated September 25, 2012. In a continuous attempt to frame me for
deportation, the perpetrators of my employment termination decided that the UC Davis
Police should distribute a poster bearing my photo and the verbiage “PERSON NOT
AUTHORIZED ON PROPERTY,” which was similar to an “FBI’s Most Wanted
criminals and terrorists” poster.

My employment termination in 2012 and attempts to frame me for deportation were


precisely coordinated with the lawsuit Baker v. Katehi et al., Case No. 12-cv-00450-
JAM-EFB. This case was filed on February 22, 2012 in the U.S. District Court’s
Eastern District of California.

The former Porter Scott attorneys Pott, Acero, and current Porter Scott attorneys Sheehan,
Cassidy, and Katherine Mola, SBN 264625, were handling the pepper spray lawsuit
Baker v. Katehi et al. in Federal District Court (see

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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


https://www.scribd.com/document/673122794/09-26-2012-Most-Unwanted-Poster-and-
Pepper-Spray-Settlement-Agreement
https://www.scribd.com/document/622347546/12-05-2012-Letter-of-Termination-and-01-09-
2013-Pepper-Spray-Settlement-Final-Order).

On November 14, 2012, I alerted my children to what was going on with my


employment at the UCDMC:
From: Jerry Waszczuk <jerrywaszczuk@yahoo.com>
Sent: Wednesday, November 14, 2012 4:59 AM
To: JOANNA WASZCZUK <Z3E1ite@aol.com>; George Waszczuk
<gwaszczukgmail.com> Subject: Fw: Brief for Oral Response -Notice Intent to
Dismiss. - UCDMC HR Death Squad

Hi Kids ;

To make a long story short. On. May 31, 2012 1 was scheduled to report to work after 10
months of work.
My Employer UC Davis Medical Center had a different plan for me. They just
crafted quite good plot to kill me or to send me to Medical Center Trauma Unit
disabled or death. It is just got discovered and I am not sure how it is going to
turn out. Something is very big behind this, but I am not sure what is it
If something happens to me then take care of mama and go to court to sue this
UC Is over 300 K on my UC account than if something, go wrong than mama
will cash the money and use it to get good lawyer. They got with me in war
game with Police forces.
That it. If something than contact my two friends Kenny Diede 1-916-812-3408
or William Buckans 1-916541 1738
I am representing them and other guy against my employer in 8 different cases.
They have my file also and they are scared.
Other than that, I don’t like to bother you. J.

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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


As mentioned above, Nancy Sheehan died in November 2019, Terence Cassidy died in
October 2021 (see
https://www.legacy.com/us/obituaries/sacbee/name/terence-cassidy-obituary?id=30483812).
Katherine Mola went on to become senior staff counsel for the California State Auditor.

REQUEST FOR PRODUCTION OF DOCUMENTS NO. 16

• All DOCUMENTS relating to any transfer of over $500 made to or


from YOU from October 4, 2015, to present.
The Porter Scott attorneys’ request for production No. 16 is another puzzle, especially its date
of October 4, 2015. Why October 4, 2015, not January 1, 2015 or any other day? The
Declaration by AINA, which I received with a subpoena and an unsigned APPLICATION
AND ORDER FOR APPEARANCE on April 22, 2021 did not support or provide any clue
why the request was made or why they were interested in my wife, knowing that I wanted in
2019 to pay the judgment to the creditors and that I had the money to do so.

The date October 4, 2015 corresponded only with when OCTC investigator Amanda
Gormley was removed from the investigation against my former attorney, Stein, and my
complaint vanished for another two years (State Bar of California Case No.15-0-10110-
LMA; California Supreme Court Case In Re Stein, No. S245982 (Cal. Mar. 1, 2018)).

The year 2015 was full of surprises and events related to my two pending Sacramento County
Superior Court cases, No. 34-2013-80001699, Jaroslaw Waszczuk v. California
Unemployment Insurance Appeal Board (CUIAB) and Real Party of Interest (Rip)—The

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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


Regents of the University of California (The Regents) and Jaroslaw Waszczuk v. The Regents
of the University of California, Case No. 34-2013- 00155479.
In the summer of 2015, I learned why my employment with the UCDMC was
terminated in December 2012. On September 25, 2015 I informed State Bar OCTC
investigator Amanda Gormley on September 25, 2015 about by sending to her A copy
of my proposed Third Amended Complaint (TAC).

E. MY APRIL 27, 2021 RESPONSES TO PORTER SCOTT ATTORNEY


OLATOMIWA T. AINA’S APPLICATION AND ORDER FOR APPEARANCE
AND EXAMINATION OF MY WIFE, IRENA WASZCZUK

In my April 27, 2021 response to Porter Scott attorney OLATOMIWA T. AINA, I


advised her, among other things, to properly file and resubmit the APPLICATION AND
ORDER FOR APPEARANCE AND EXAMINATION. Also I advised AINA that my
legal Polish name is JANUSZ JAROSŁAW WASZCZUK, and my wife’s legal Polish
name is IRENA WASZCZUK. (EXHIBIT # 20 on Flash Drive and DVD )

We are both Polish refugees and citizens of the Republic of Poland who have been
living in exile in the USA since November 1982

Shortly after AINA received my response she quit her employment with Porter
Scott and joined the Phisher Philipps law firm in San Francisco thus for now I
excluded her from this complaint . However attorney AINA should be questioned by the
State Bar OCTC investigator due to her involvement in the malicious and evil criminal
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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


intent to harm my wife which was orchestrated by the group of Porter Scott attorneys ,
judicial officers and court staff . (https://www.fisherphillips.com/people/tomiwa-
aina.html?tab=overview).
F. THE LETTER TO CLERK OF THE SACRAMENTO COUNTY
SUPERIOR COURT DEPARTMENT 43 – JUDGE THADD A. BLIZZARD

On the same day April 27, 2021 I submitted a letter to Clerk of the Sacramento County
Superior Court Department 43 – Judge Thadd A. Blizzard with the copy of my April 27,
2021 letter to Porter Scott’s attorney OLATOMIWA T. AINA and copies of all
documents I received from Aina with the subpoena on April 22, 2021. (EXHIBIT # 21
on Flash Drive and DVD ). I pointed out in my letter that Porter Scott ‘s attorney
OLATOMIWA AINA, violated the 45 days notification court rule by submitted to
the court the APPLICATION AND ORDER FOR APPEARANCE AND
EXAMINATION and perjurious Declaration in Support which falsely informed Court
that MICHAEL BOYD, STEPHEN CHILCOTT, DANESHA NICHOLS, CINDY
OROPEZA, AND BRENT SEIFERT are the FORMER DEFENDANTS in the lawsuit .
The Court Department 43 instead of rejecting the OX application which violated 45 days
notification rule , the document was re-dated by hand writing with the date for the
examination of my wife set for July 2, 2021 at 9:00 A.M. (just prior to the long 4th of
July weekend). (EXHIBIT # 22 on Flash Drive and DVD ).
The APPLICATION FOR APPEARANCE AND EXAMINATION was stamped with
name of Judge THADD A. BLIZZARD from Dept. 43. I was not informed by Porter
Scott attorneys LINDSAY GOULDING or OLATOMIWA AINA of the date change, and

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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


I did not see on the Court’s public access website that anything new had been filed. As a
result, I was ready with my wife to appear in Court Dept . 43 before the JUDGE
THADD BLIZZARD on May 7, 2021 at 9:00 A.M. However, I called Dept. 47 and spoke
to the clerk, who told me that the date for the hearing had been changed, without letting
me know, to July 2, 2021.
This was a copycat scenario of events from October 2018–February 2019, when Porter
Scott attorneys DANIEL BARDZELL and DAVID BURKETT attempted to terminate
my lawsuit in Dept. 54 with Judge CHRISTOPHER KRUEGER by bypassing JUDGE
DAVID I BROWN in Dept. 53 who was presiding over my case since September 2014
and filing and refiling OX application in Department 37. Judge JENNIFER ROCKWELL
(EXHIBIT # 23 on Flash Drive and DVD)

G. THE PORTER SCOTT’S ATTORNEY LINDSAY A. GOULDING’S


APRIL 26, 2021 EX PARTE APPLICATION FOR LEAVE TO EXTEND
PAGE LIMIT FOR DEFENDANT’S MOTION FOR SUMMARY
JUDGMENT OR, IN THE ALTERNATIVE, SUMMARY ADJUDICATION
https://www.scribd.com/document/505146196/202210427-Meet-and-Confer-Ex-
Parte-l-Goulding-Porter-Scott
On April 26, 2021 simultaneously with the APPLICATION AND ORDER FOR
APPEARANCE AND EXAMINATION OF IRINA WASZCZUK not known to me
Porter Scott attorney, LINDSAY A. GOULDING, served to me via e-mail an EX PARTE
APPLICATION FOR LEAVE TO EXTEND PAGE LIMIT FOR DEFENDANT’S
MOTION FOR SUMMARY JUDGMENT OR, IN THE ALTERNATIVE, SUMMARY

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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


ADJUDICATION with attached Declaration and Proposed Order (EXHIBIT # 24 on
Flash Drive and DVD)
On the same day April 26, 2021 I questioned GOULDING’s why her ex -parte, not state
or why she failed mark on the pleading in which department the ex parte application
would be filed, or which judge would handle the ex- parte application per California
Rules of Court Rule 3.1110 (b)(1)
It caught my attention because on October 3, 2018 by Porter Scott attorneys DANIEL
BARDZELL and DAVID BURKETT, who attempted to obtain termination sanctions against
me in a different setting, Dept. 54 with presiding JUDGE CHRISTOPHER KRUEGER, by
bypassing JUDGE DAVID I. BROWN in Dept. 53. The Porter Scott attorneys’ deceit in
October 2018 failed; they were caught a few days after filing the motion for termination
sanction under false pretenses. The lacking department and judge name , the GOULDING’s
ex-parte application was filed by the Superior Court Clerk ERICA MEDINA who in same
manner deliberately filed on October 3, 2018 in the wrong department the Porter Scott’s
attorneys DAVID BURKETT’s and DANIEL BARDZELL motion for termination sanctions
. The October 3, 2018 motion for termination sanctions were simultaneously filed with
APPLICATION AND ORDER FOR APPEARANCE AND EXAMINATION to extract
information about my wife bank account and 401K account to steal her life saving .
(EXHIBIT # 25 on Flash Drive and DVD) It was done in the same malicious manner to
harm my lawsuit and my spouse as the OX application , subpoena and ex-parte application

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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


filed in April 2021 by two Porter Scott’s Attorneys LINDSAY A. GOULDING and
OLATOMIWA AINA.
On April 27, 2021 I sent Meet and Confer Letter to Porter Scott’s Attorney Lindsay
Goulding regarding her ex -parte application submitted to the court on April 26, 2021.
(EXHIBIT # 26 on Flash Drive and DVD)
The key issue in my meet and confer were five individual defendants STEPHEN
CHILCOTT, DANESHA NICHOLS, CINDI OROPEZA, BRENT SEIFERT, AND
MIKE BOYD in the lawsuit which were not even mentioned in the GOULDING’s
pleadings as the FORMER DEFENDANTS in contrary to her assistant OLATOMIWA
AINA’s OX application and declaration .
On the caption first pages of the pleadings LINDSAY GOULDING appeared as a
“Attorney for Defendant REGENTS OF THE UNIVERSITY OF CALIFORNIA”

In the DECLARATION OF LINDSAY A. COULDING IN SUPPORT OF DEFENDANT'S


EXPARTE FOR LEAVE TO FILE MOTION FOR SUMMARY JUDGMENT THAT
EXCEEDS 20 PAGES , LINDSAY A. GOULDING declared under penalty of perjury under the laws
of the State of California that :

I, Lindsay A. Goulding, declare as follows:

1. I am an attorney at law licensed to practice before all courts


in the State of California
and am a partner with the law firm of Porter Scott, attorneys of record
for Defendant REGENTS OF THE UNIVERSITY OF
CALIFORNIA ("Defendant" or "UNIVERSITY"). I state the facts

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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


herein of my own personal knowledge and, if called upon as a witness. I
could and would competently testify thereto.

The omitted, missed or excluded Defendants by GOULDING’s in her pleadings STEPHEN


CHILCOTT, DANESHA NICHOLS, CINDI OROPEZA, BRENT SEIFERT, AND MIKE
BOYD were a key perpetrators who actively participated and conspired with the Porter
Scott’s attorneys especially MICHAEL POTT , GEORGE ACERO and NANCY SHEEHAN
in 2005-2009 and 2011-2012 in inhumane and merciless witch hunts to terminate my
employment with University of California , UC Davis Medical Center and to frame me and
deport me to my native country Poland .

In my April 27, 2021 Meet and Confer sent to GOULDING I addressed the excluded
unlawfully from the lawsuit the five individual defendant as follow:

In concluding this Meet and Confer letter, I would appreciate if


you would clarify with the Court the status of the four individuals
STEPHEN CHILCOTT, MIKE BOYD, DANESHA NICHOLS, AND
BRENT SEIFERT. Please clarify whether these individuals are still
Defendants or whether they were dismissed by the anti-SLAPP motion
in 2015 together with first four COAs. Porter Scott Attorneys once
brought them back in their pleading as Defendants and another time
classed them as former Defendants, stating that they are being
represented by Porter Scott.

I noticed that in your April 26, 2021 Ex Parte Application for


Leave to Extend the Page Limit for the Defendant's Motion For
Summary Judgment or, in the Alternative, Summary Adjudication, you
did not mention STEPHEN CHILCOTT, MIKE BOYD, DANESHA
NICHOLS, and BRENT SEIFERT at all, which is in contrast to

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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


Burkett Bardzell's and other Porter Scott's lawyers pleadings of 2018-
2020. I am quite sure that Stephen Chilcott, Mike Boyd, Danesha
Nichols, and Brent Seifert do not want to hear about this lawsuit or about
Porter Scott's Attorneys anti-SLAPP motion dirty money attached to
violation of my human rights and endless harassment of 70 years old
wife . Your first show off in this case did not go well for you Ms.
Goulding . You are dirty and unprofessional lawyer as same as your
Porter Scott's predecessors with JD degree and licenses from the State
Bar of California .

On November 13, 2018 Porter Scott’s attorney DANIEL BARDZELL in his letter to the
court clerk wrote: (EXHIBIT # 27 on Flash Drive and DVD)

Dear Court Clerk:

Our office represents Defendant Regents of the University


of California in the above matter. We also represent the
remaining Defendants, including in part, MIKE BOYD,
STEPHEN CHILCOTT, BRENT SEIFERT, CINDY
OROPEZA AND DANESHA NICHOLS.

On October 24, 2018, Defendants BOYD, CHILCOTT,


SEIFERT, OROPEZA AND NICHOLS submitted an
Application and Order for Appearance and Examination of
Plaintiff Jaroslaw Waszczuk on behalf of Defendants
BOYD, CHILCOTT, SEIFERT, OROPEZA AND
NICHOLS. The Application was deemed filed on
November 7, 2018. The Examination was set for December
14, 2018.

Defendants request that the December 14, 2018


Examination of Plaintiff Jaroslaw Waszczuk be taken
off calendar. Defendants anticipate refiling for a later
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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


examination date to ensure compliance with statutory
notice requirements.
Very truly yours,

Daniel Bardzell

The above-mentioned letter from DANIEL BARDZELL is the best proof that STEPHEN
CHILCOTT, MIKE BOYD, DANESHA NICHOLS, BRENT SEIFERT, and CINDY
OROPEZA were never dismissed from my wrongful termination lawsuit and that no
court record can be found declaring that they were dismissed.
It is also worth mentioning that, on October 1, 2015 with a REQUEST FOR DISMISSAL, I
dismissed from my wrongful termination lawsuit four of the nine individual defendants,
CHARLES WITCHER, PATRICK PUTNEY, DORIN DANILIUC, and ANN MADDEN
RICE (EXHIBIT #28 on flash drive and DVD).
Porter Scott attorney LINDSAY GOULDING unlawfully usurped the power of the
Courts and judges to dismiss STEPHEN CHILCOTT, MIKE BOYD, DANESHA
NICHOLS, BRENT SEIFERT, and CINDY OROPEZA from my wrongful termination

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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


suit. I am not sure why she did this, as since October 2019 the firm had falsely
maintained that these people were FORMER DEFENDANTS.
The April 27, 2021 order that granted GOULDING’s ex-parte application should never
have been granted, given GOULDING’s deception by filing this application without
including in the pleading these five individual defendants.
The order was stamped with the name of Judge SHAMA MESIWALA, from Law and
Motion Department 53.
This is how I learned that JUDGE DAVID I. BROWN, who had presided over my case since
September 25, 2014 and over Dept. 53 since 2008, had been replaced on January 1, 2021 by
JUDGE SHAMA H. MESIWALA, per Governor Gavin Newsom’s appointment, three years
before JUDGE BROWN’s term was due to end, in 2023. After I learned that Judge BROWN
was gone, I realized that I was at the mercy of GOD alone in dealing with the ruthless Porter
Scott attorneys and their friends and collaborators from Sacramento County Superior Court
and Court of Appeal, Third Appellate District (3DCA).

In April 2021, I did not yet know that former UC Office of the General Counsel intern and
Porter Scott attorney GEORGE A. ACERO had been appointed by Newsom as a judge in
Sacramento Superior Court. Most likely, GEORGE ACERO was installed by a
recommendation from UCOP General Counsel Charles Robinson, or former California
Attorney General Xavier Becerra.
ACERO was a key player and coconspirator with defendants STEPHEN CHILCOTT, MIKE
BOYD, DANESHA NICHOLS, BRENT SEIFERT, and CINDY OROPEZA in the 2005–

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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


2007 and 2011–2012 witch hunts to terminate my employment with the UC Davis Medical
Center .
Also in April 2021, I did not know that, in November 2020, the Director and Chief Counsel
of the California Commission on Judicial Performance had launched a politically motivated
crusade to remove Sacramento County Superior Judge DAVID I. BROWN and 3DCA
Presiding Justice VANCE W. RAYE from the bench.
I suspect that the Porter Scott attorneys had known as early as January 2020 about the coming
changes in Law and Motion Department 53 and that this is why they put on hold for more
than one year their assault to finish me and rob my wife of her life savings.

VI.
MAY 14, 2021 DEFENDANT’S PORTER SCOTT’S S MOTION FOR SUMMARY
JUDGMENT (MSJ) OR, IN THE ALTERNATIVE, SUMMARY ADJUDICATION
FILED BY PORTER SCOTT’S ATTORNEY LINDSAY GOULDING .
CASE Jaroslaw Waszczuk v. The Regents of the University of California, Case No. 34-
2013- 00155479, FILED ON DECEMBER 4, 2013

A. THE MOTION FOR SUMMARY JUDGMENT


Porter Scott’s Attorney LINDSAY GOULDING ignored my Meet and Confer letter I sent to
her on April 27, 2021 and my warning -requests in the letter about five Defendants
STEPHEN CHILCOTT, MIKE BOYD, DANESHA NICHOLS, BRENT SEIFERT and
CINDY OROPEZA unlawfully excluded by her pleadings.
On May 14, 2021, Attorneys Goulding without any hesitation by her (MSJ) unlawfully
excluded defendants STEPHEN CHILCOTT, MIKE BOYD, DANESHA NICHOLS,

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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


BRENT SEIFERT and CINDY OROPEZA from the lawsuit. GOULDING bluntly lied
in the Memorandum of Points and Authorities on page No.3 (EXHIBIT # 29 on Flash
Drive and DVD) that these Defendants were dismissed from the lawsuit without
providing date of the dismissal information who dismissed them and why or providing
the copy of the Request for Dismissal:
On page 3 GOULDING lied as follow :

Plaintiff filed this action against the UNIVERSITY as well as


individual Defendants MIKE BOYD, STEPHEN CHILCOTT,
DANESHA NICHOLS, CINDY OROPEZA, BRENT SEIFERT, ANN
MADDEN RICE, CHARLES WITCHER, PATRICK PUTNEY and
DORIN DANILIUC. BOYD, CHILCOTT, NICHOLS, OROPEZA and
SEIFERT (herein "anti-SLAPP Defendants") filed a Special Motion to
Strike the causes of action pled against them. (Goulding Decl., ¶ 3.) The
Court granted that Motion. (Id.) Plaintiff then dismissed the four
remaining individual Defendants-RICE, WITCHER, PUTNEY, and
DANILIUC. (Id.) As a result, the UNIVERSITY is the only
Defendant remaining.
See the Exhibit No 18 & 27 in this addendum which shows that these individual Defendants
were not dismissed from the complain , thus GOULDING deceived the Court and her
pleadings shall not be accepted by Judge SHAMA MESIWALA who replaced Judge
DAVID I . BROWN .

The massive MSJ 475 pages of documents were included with the Defendant’s
Notice of Motion and Motion for Summary Judgment or, in the Alternative, Summary
Adjudication were full slander and lies aimed at me . When I received a copy of the motion

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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


for summary judgment, the picture became quite clear that the Porter Scott attorneys, in their
scheme of fraud, had prearranged the result of the Court Hearing set for the motion to be
heard on August 4, 2021 in Dept. 53 and to pay for this by defrauding my wife in Dept. 43
The Porter Scott attorneys’ scam Motion for Summary Judgment was most likely
fabricated by attorneys November 2018, but they were unable to break in into my wife’s bank
and 401(K) savings accounts in 2018. Porter Scott Attorney Daniell Bardzell, in his meet and
confer memo dated November 20, 2018 threatened to file a Motion for Summary Judgment,
but he never did. DAVID BURKETT AND DANIEL BARDZELL were a not brave enough
to file a Motion for Summary Judgment in Dept. 53, with Judge DAVID BROWN.
Following their malicious actions, they attempted to bypass Judge BROWN and Dept. 53 and
filed a Motion for Termination Sanction on October 3, 2018 in Dept. 54, with Judge
CHRISTOPHER KRUEGER. They were caught and their criminal conduct was exposed .

In addition to above on May 27, 2021, Porter Scott attorney LINDSEY GOULDING filed a
new declaration in support of the (altered on May 7, 2021) March 12, 2021 APPLICATION AND
ORDER FOR APPEARANCE AND EXAMINATION OF MY WIFE, IRENA with a scheduled
examination in Dept. 43 on July 2, 2021 at 9: 00 A.M. before Judge THADD BLIZZARD
(EXHIBIT #30, on flash drive and DVD ).GOULDING in her Declaration repeated and still
maintain her lies that Defendants MIKE BOYD, STEPHEN CHILCOTT, DANESHA
NICHOLS, CINDY OROPEZA, BRENT SEIFERT are FORMER DEFENDANTS Most likely
she never met one of these individuals. Most of them were not employed any more by university.
GOULDING did not provide any declaration from them stating
they are FORMER DEFANDNATS and they are being represented by GOULDING
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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


GOULDING’s Assistant OLATOMIWA T. AINA quit her job at Porter Scott after she was
informed in April 2021what kind mess she was dragged into by LINDSDAY GOULDING. ,
At the same time former intern of the UC Office of the General Counsel and former Porter Scott
Attorney GEORGE A. ACERO was sworn as the Sacramento County Superior Court Judge and
was installed as a BACK -UP JUDGE in the LAW and MOTIONS DEPARTMENTS 53 & 54
(EXHIBIT #31, on flash drive and DVD )
B. THE MOTION TO RECALL REMITTITUR AND MOTION FOR
THE JUDICIAL NOTICE FILED IN 3DCA IN ATTEMPT TO STOP
THE STEAL OF MY WIFE LIFE SAVING BY PORTER’S
SCOTT’S ATTORNEYS

On June 18, 2021 I submitted via TrueFiling to 3DCA a very detailed Motion to Recall
Remittitur . See my Ccover letter and Declaration in Support : (EXHIBIT #32, on flash
drive and DVD )from the 10/10/2017 3DCA unpublished opinion in the Waszczuk v.
Regents of University of California C079524 (Cal. Ct. App. Oct. 10, 2017). Trial Court
Case -Jaroslaw Waszczuk v. The Regents of the University of California, Ann Madden
Rice, Mike Boyd, Stephen Chilcott, Charles Witcher, Danesha Nichols, Cindy Oropeza,
Brent Seifert, Patrick Putney, Dorin Daniliuc, Case No. 34-2013-00155479

The Motion for Recall Remittitur and Motion for Judicial Notice was my response
to Porter Scott’s attorneys assault aimed at my wife IRENA WASZCZUK and my
effort to protect my wife from Porter Scott’s attorneys criminal intent to rob her of her
life saving and frame her for criminal prosecution as they did to my psychologist
FRANKLIN O . BERNHOFT Ph.D wife DOROTHY BERNHOFT in 2011-2012 .
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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


See my correspondence in this matter sent to the former Berhnhoft’s attorneys on August
17, 2023. (EXHIBIT #33, on flash drive and DVD my Second Amended Complaint to
generate a large amount of legal fees and extort money from me and my wife. Goulding’s
Motion was an intentional and unrelenting pattern of misconduct by the Defendants and
their attorneys and showed disregard for the Court’s benevolence in granting them the
anti-SLAPP motion on April 14, 2015, as affirmed by the Court of Appeal, Third
Appellate District (3DCA) on 10/10/2017.
I worked on the Motion to Recall Remittitur non-stop for one month to prevent the Porter
Scott attorneys’ further conspiracy against my wife and their criminal activities in the Court
of Law.

C. JUNE 18, 2021 MEET AND CONFER LETTER TO PORTER SCOTT


ATTORNEY LINDSAY GOULDING

With my June 18, 2021 letter, I submitted to Porter Scott attorney LINDSAY
GOULDING copies of the Motion to Recall the Remittitur and the Motion for Judicial
Notice. This was sent via by U.S. Priority Mail, along with copies of the Declaration in
Support and Waszczuk v. Regents of University of California, C079524 (Cal. Ct. App.
Oct. 10, 2017). (EXHIBIT #34, on flash drive and DVD)
By my letter I pointed to GOULDING as follow :

I noticed that your partner, Olatomiwa T. Aina, is no longer listed in the


Porter Scott directory. I was hoping to meet her in the courtroom of
Department 43, but perhaps Porter Scott’s management is worse than that

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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


of the University of California system, prompting Ms. Aina to move to
Fisher Phillips after her short tenure with Porter Scott.
Based on my understanding drawn from other instances of litigation
against the Regents of the University of California and other clients,
Porter Scott deserves to be disqualified by the Court, as there seems to be
no other way to end Porter Scott’s attorneys’ gangsterism in the Courts of
Law.
In addition to the above, I am asking you to remove from the court
calendars the examination of my wife in Department 43 scheduled for
July 2, 2021. You only need to ask me for documents. I have all of her
records. As you read my Motion to Recall the Remittitur, you will find
that my wife gave me $25,000 to pay the anti-SLAPP legal fees and costs,
but no one who was listed on the Court Order dated June 7, 2018 wanted
the money apart from David Burkett and Daniel Bardzell, who wanted it
for themselves, and Bardzell was not the one listed on 06/07/2018 order.
Furthermore, in 2019, the State of California reimbursed me for the
monies stolen by my lawyer, Douglas Stein, to whom I had paid a
retainer. I sent a letter to former Porter Scott attorneys Michael Pott and
Douglas Ropel and asked them if they wanted the money but received no
answer. I sent a check to Porter Scott Paralegal Marilyn Gamper.
I did not receive a response to my letter from LINDSAY GOULDING .
D. JUNE 18, 2021 COVER LETTER AND COPY OF MOTION TO
RECALL THE REMITTITUR AND COPY OF THE MOTION) FOR
JUDICIAL NOTICE IN Waszczuk v. Regents of University of
California, C079524 (Cal. Ct. App. Oct. 10, 2017) SUBMITTED TO

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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


THE SACRAMENTO SUPERIOR COURT DEPT . 53, JUDGE
SHAMA HAKIM MESIWALA

On June 18, 2021 I sent via U.S. Priority Mail to the Sacramento Superior Court
Dept. 53, JUDGE SHAMA HAKIM MESIWALA, a paper copy of my Motion to
Recall Remittitur and Motion for Judicial Notice. Both documents were assembled
according to the Court Rules with bottom exhibits tabs. In my cover letter (EXHIBIT
#35, on flash drive and DVD)

By mu cover asked the Dept. 53 Court Clerk to provide a copy of the Motion for Recall
the Remittitur with 46 attached exhibits and a copy of the Motion for Judicial Notice with
only Exhibit 47 to JUDGE SHAMA HAKIM MESIWALA,. Furthermore, I asked the
Court Clerk to file for the record a copy of my Motion to Recall Remittitur and a copy of
the Motion for Judicial Notice without exhibits along with this letter and the attached
Meet and Confer letter to Defense Attorney Lindsay A. Goulding dated June 18, 2021..
The submitted document never has been filed by the clerk in Dept. 53.
E. JUNE 25, 2021 LETTER TO THE 3DCA CLERK

One week after I submitted the Motion to Recall Remittitur, on June 25, 2021, I sent a
short letter to 3DCA clerk, via TrueFiling and e-mail, stating the following (EXHIBIT
#36, on flash drive and DVD)

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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


Dear Clerk:
I am a Plaintiff representing myself in pro per in the above-captioned
case.
I would appreciate if the Court could inform me why my Motion to
Recall the Remittitur and Motion for Judicial Notice submitted to the
Court via TrueFiling on June 18, 2 02 1, is not filed yet. If it is a pay
issue for the motions, please charge the credit card in TrueFiling, and
kindly file the motions. If there is another reason the motions were not
filed one week after submission, please let me know as well.
I appreciate the Court's prompt response in this matter.

I received an automatic response from 3DCA by e-mail that stating that my


question would be answered within 5 days.

F. JUNE 29, 2021, A WRITTEN PEREMPTORY CHALLENGE


PURSUANT TO CCP 170.6 TO DISQULIFY SACRAMENTO
CAOUNTY SUPERIOR COURT JUDGE SHAMA MESIWALA
FROM

None of my documents had been filed by any court 11 days after I submitted my Motion
to Recall Remittitur and Motion for Judicial Notice, and copies were sent to California
Supreme Court and Sacramento County Superior Court Dept. 53, SHAMA HAKIM
MESIWALA, who replaced the JUDGE DAVID BROWN. I have also had no response
from any court or from Porter Scott Attorney LINDSAY GOULDING about the
scheduled examination of my wife in Sacramento County Superior Court Dept. 43 before
JUDGE THADD BLIZZARD.

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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


I new that my wife IRENA WASZCZUK became a subject to frame and to be robbed
of her life saving by group of gangsters from Porters Scott and their collaborators from
Sacramento County Superior Court and 3DCA. This situation pushed me to file, on
June 29, 2019 in Sacramento Superior Court, PLAINTIFF'S PEREMPTORY
CHALLENGE Code of Civil Procedure § 170.6 to disqualify Judge Mesiwala in Case
No. 34-2013-00155479-CU-WT-GDS, Jaroslaw Waszczuk v. The Regents of the
University of California (EXHIBIT #37, on flash drive and DVD)

“I, Jaroslaw Waszczuk, the self-represented Plaintiff in the


above-captioned case, declare as follows:

The Honorable Shama Hakim Mesiwala, the judge before


whom the Defendant's Motion for Summary Judgment or, in the
Alternative, the Summary Adjudication regarding the aforesaid
matter is pending, or to whom the aforesaid motion is assigned, is
prejudiced against me. Consequently, I believe that I cannot have a
fair and impartial hearing for this motion before this Judge.”

JUDGE MESIWALA was brought to Sacramento Superior Court from 3DCA in


February 2017 and was sworn in as a Court Commissioner by Sacramento Superior Court
Presiding Judge Kevin Culhane (https://www.indiawest.com/news/global_indian/shama-
mesiwala-sworn-in-as-sacramento-superior-court-commissioner/article_fe5e9686-facf-
11e6-9d64-af5e5da34004.html).

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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


JUDGE MESIWALA was employed in 3DCA, for 13 years as a judicial research
attorney for ASSOCIATE JUSTICE RONALD B. ROBIE, whom she praised as her
mentor. 3DCA JUSTICE B. ROBIE was one of justices who coauthored the
unpublished opinion in Waszczuk v. Regents of Univ. of Cal., C079524 (Cal. Ct. App.
Oct. 10, 2017), which praised my drug-addicted (now former) attorney DOUGLAS
STEIN, who was most likely forced by Porter Scott attorneys to empty my Wells Fargo
retainer account one day after an anti-SLAPP motion was filed on December 1, 2014.
Stein most likely intercepted my unemployment insurance benefits in May 2014, with the
Porter Scott attorneys’ blessing.

G. JUNE 30, 2021 EX PARTE APPLICATION TO CONTINUE THE


APPEARANCE AND EXAMINATION OF MY WIFE IRENA
WASZCZUK UNTIL AUGUST 27, 2021, OR AFTER AUGUST 27,
2021

My 70-year-old wife, IRENA WASZCZUK , who after 31 years of service was laid
off by Nordstrom at the Arden Mall, in Sacramento, CA, due to COVID-19 and the
subsequent closure of her place of employment, became terrified and traumatized to
go to Court and be interrogated as I had been on February 8, 2019 by Porter Scott
attorney DANIEL BARDZELL about her and our children.

On June 30, 2021, two days before the scheduled examination of my wife in Dept. 43
before JUDGE THADD BLIZZARD, I submitted via Rapid Legal Services an
emergency Ex Parte Application to postpone the July 2, 2021 examination of my wife

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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


until September 3, 2021. (EXHIBIT #38, on flash drive and DVD)
I was expecting money in August 2021 from Poland, and I could then pay
the UC Regents whatever should be paid if the Court orders such a payment. The UC
Regents were not named as a Defendant in the anti-SLAPP Motion, thus the former
judge from Dept. 53, JUDGE DAVID I. BROWN, decided in 2019 that THE
REGENTS were not entitled to legal fees or sanctions related to the anti-SLAPP
motion. I explained IT in great detail this addendum an in my June 18, 2021 Motion
to Recall Remittitur what happened in 2018–2019 regarding the anti-SLAPP legal
fees.
As I provided information in my Motion to Recall the Remittitur in 2019 A, I could
pay the anti-SLAPP legal fees because my wife provided me $25,000 for this purpose, but no
one wanted the money. On November 18, 2019, I paid $1300 in sanctions to the Regents in
relation to the anti-SLAPP motion, but Judge Brown ordered Porter Scott attorney DANIEL
BARDZELL to return the check to me, and he did so on January 8, 2019.
My wife has no knowledge whatsoever about the American or Polish legal systems or laws.
She worked as a seamstress at Nordstrom for 31 years and enjoyed her life in America. She
did not want to be dragged into court by the University-hired thugs from Porter Scott. She
was ready to write a check for these legal fees, but no one wanted her check to pay the anti-
SLAPP motion’s imposed fees. She has become a blackmail tool for Porter Scott gangsters
since February 2015 and their efforts to make to push me back and drop all litigation against
the UC Regents because of the stolen unemployment insurance benefits, my disability
benefits, my retainer, and–most likely–drug dealing or use by my former attorney, Douglas
Stein, with the involvement of Porter Scott attorneys and Court staff.
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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


My June 30, 2021 emergency Ex Parte Application to postpone the examination was
delivered to the court before 11:00 A.M., and I was expecting that it would be no problem for
the Court to accommodate my request for a continuance.
I wrote in my Ex Parte Application on pp. 3& 4
On June 18, 2021 Plaintiff sent the meet and confer letter to the Defendant’s new
Attorney from Porter Scott Law Corporation (Porter Scott) Lindsay Goulding.
Plaintiff sent to her copies of the Motion to Recall the Remittitur and the Motion
for Judicial Notice along with copies of the Declarations in Support of his motion
in the case Waszczuk v. Regents of University of California, C079524 (Cal. Ct.
App. Oct. 10, 2017), which is a subject of this Ex Parte. By the June 18, 2021
letter Plaintiff asked Defendants Attorney LINDSEY GOULDING to remove
from the court calendars the examination of Plaintiff’s wife in Department 43
scheduled for July 2, 2021 and informed her that Plaintiff could send her all the
documents she needs without examination.
The Plaintiff's wife, Irena Waszczuk is financially capable of paying the anti-
SLAPP motion legal fees and cost if suitable has enough money in her bank
account to write the check today for the anti-SLAPP motion legal fees and
cost if suitable but the Court must decide who shall be paid.
On December 6, 2019, Amanda her, the Defendants' former attorney from
Porter Scott, replied to the Plaintiff's December 4, 2019 opposition to her motion
(ROA 238). On page 5, paragraph 4 of her December 6, 2019 reply entitled
"Defendant Regents is Entitled to Payment of Sanctions Awards," Porter Scott
attorney Amanda Iler, who was not listed in the June 7, 2018 Court Order,
demanded that legal fees be paid to the Regents of UC in bold letters:

“Judgment Debtor has cited no legal authority for his position the
REGENTS are not entitled to the sanction payment. The REGENTS
has paid for the defense of the Judgmen Creditors (her Deci. ¶
6).” (See Exhibit 9 and 10 in this addendum )

This was not the Plaintiff's (Judgment Debtor) position. It was decided by Hon.
David I. Brown and Hon. Steven H. Rodda that the Regents were not the
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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


Defendants in the anti-SLAP!' motion and that they were not entitled to any legal
fees from the anti-SLAPP motion. Due to pressure from Porter Scott attorney
Daniel Bardzell on November 18, 2019, the Plaintiff sent a $1300 sanction check
payable to the Regents, and Judge David I. Brown ordered Bardzell to return the
uncashed check to the Plaintiff. Bardzell returned the check on January 8, 2020.

I sent a copy of the Ex Parte Application to Porter Scott attorney Goulding by e-mail, fax,
and U.S. Priority Mail. My Ex Parte Application was not filed on June 30, 2021. The next
day, on July 1, 2021, my Ex Parte Application showed up on the Court Public Access but
I could not access the document to find whether the Judge from Dept. 43, JUDGE
THADD BLIZZARD, had signed the order or not. On same day, I was trying to reach the
clerk in Dept. 43 to find out the fate of my Ex Parte Application. After my the apprentice
in the Court Department 43 on July 2, 2021 I had no doubt that the Court Clerk and
Judge THADD BLIZZARD were collaborating with Porter Scotts’ attorneys to set up
my wife and harm her.

H. EVIL ORCHSTATED AMBUSH BY PORTER’S SCOTT’S


ATTORNEYS AND THE SACRAMENTO COUNTY SUPERIOR
COURT STAFF FROM DEPARTMENT 53 AND 43 TO TERRORIZE
AND TRAUMTIZE MY 70-YEAR-OLD WIFE, IRENA WASZCZUK,
ON JULY 2, 2021 IN ATTEMPT TO ROB HER OF LIFE SAVING .
On July 2, 2021, having no other choice, I arrived at Sacramento County Superior Court
in Dept. 43, per JUDGE THADD BLIZZARD’S altered and redacted Order dated May 7,
2021.
My wife, IRENA WASZCZUK, who has been the target of the Porter Scott attorneys’

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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


criminal activities since February 2015, arrived with me and my good friend and former co-
worker from the UC Davis Medical Center, WILLIAM BUCKANS, who has been a witness
to GOULDING’S and Department 43 Clerk ‘s harassment and psychological assault aimed
at my my wife IRENA WASCZUK. My former coworker William BUCKANS has always
attended the court hearings in Sacramento Court with me, due to the previous vile threats by
Porter Scott’s attorneys in the Court against me and my wife. The threats have been reported
to the Court and the State Bar.
Upon arrival in Dept. 43, I noticed on the information board that Porter Scott attorney and
shareholder DEREK HAYES was the one who should conduct interrogation of my wife
IRENA WASCZUK . However, HAYES was not present in the Court Room Department
43. HAYES’s name appeared two replies to my December 4, 2019 opposition to Porter
Scott’s filed motion naming DANESHA NICHOLS, STEPHEN CHILCOTT, BRENT
SEIFERT, MIKE BOYD, and CINDY OROPEZA in their pleadings as FORMER
DEFENDANTS. One reply was filed on December 4, 2019 and entitled “Reply to No
Opposition” (Exhibit #9_. a second reply on December 6, 2019, (Exhibit #10 ) in this
addendum

Porter Scott’s attorney LINDSAY GOULDING appeared at the hearing and said she
was the one who was set and running whole interrogation on behalf of the UCOP. After
the bailiff checked the names of the participants in the Court hearing, the court clerk or
judge’s assistant (an African-American woman whose name I do not know) became
very active and pushy to get my wife interrogated. Then, I asked what happened to

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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


my Ex Parte Application for a continuance of the hearing submitted to the Court
on June 30, 2021. Clerk responded that she did not get the document and tried to begin
my wife’s interrogation. GOULDING was sitting there, but said nothing. Finally, I told
the CLERK that there would be no interrogation of my wife in this courtroom, and I
informed her that I have a check with me in the amount of $22,284 to pay whatever
should be paid. (EXHIBIT #39, on flash drive and DVD)

The CLERK did not like this and unprofessionally insisted on moving forward with
the interrogation of my wife . The CLERK tried to cut me out, stating that I was not a
party of the examination. I told her again that there would be no examination of my wife,
and I asked GOULDING to whom I should write the check. The CLERK interfered and
said that she does not know how to proceed. She then went to the judge’s chambers to get the
judge. After 10 minutes, Judge THADD BLIZZARD appeared on the bench completely
unprepared for the hearing and not knowing what the examination was to be about or
to control the damages he pretended that he does not know what is going on. JUDGE
BLIZZARD started looking with the clerk for a Polish translator for my wife, even though I
had written a check for $22,284. Porter Scott Attorney LINDSAY GOULDING , Department
43 CLERK and JUDGE BLIZZARD were totally unprepared for such outcome and they were
caught of guard. Finally, I forced GOULDING to look at the check, which I issued to the UC
Regents showed her my wife’s most recent Bank of America statement, which verified that
there were more than enough funds to cover the $22,284 check. GOULDING at first did not
want to take the check but he looked at JUDGE and CLERK left the court unhappy with the
$22,284 bluntly stolen from wife’s account. She was told loud and clear not to harass and
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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


terrorize my 70 years old wife ever. . After I and my wife left court on that day , JUDGE
THADD BLIZZARD to further intimidate my wife ordered her to return on August 6, 2021
if the case is not settled :
The July 2, 2021 Court Order stated . EXHIBIT #40 on flash drive and DVD)
EVENT TYPE: Order of Examination - OX Calendar
APPEARANCES
Jaroslaw Waszczuk, self represented Plaintiff, present. Irina Waszczuk, wife of
Plaintiff
Lindsay Goulding, counsel, appearing for Defendant(s).
Nature of Proceedings: Hearing on Order of Examination of Judgment Debtor
The above entitled cause came before this court for hearing on Order of
Examination of Judgment Debtor this date with the above indicated parties
present.
Requested Examinee, Irina Waszczuk, was present with the Plaintiff, Jaroslaw
Waszczuk. The Plaintiff provided a check to Defendant's counsel in court. Counsel
accepted the check.
This matter is continued to August 6, 2021 at 9:00 a.m. in Department 43, all
parties are ordered to return. If the matter is settled by that date, Defendant's
counsel will contact the Court to drop the hearing.

SLAPP The return hearing was set just two days after the scheduled Court Hearing in
Dept. 54 for Porter Scott attorneys’ Motion for Summary Judgment before Judge
CHISTOPER KRUEGER .
I. THE JULY 2, 2021 THE COURT ORDER DISQULIFIYING
SACRAMENTO COUNTY SUPERIOR COURT JUDGE SHAMA
MESIWALA DEPARTMENT 53 LAW AND ORDERS.
After the appearance in Dept. 43 on July 2, 2021 at 9:00 A.M., where my wife paid a

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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


$22,284 ransom to attorney GOULDING, I noticed on the Court’s public access website that,
at 1:30, my June 30, 2021 ex parte application to continue the hearing in Dept. 47 until
September 3, 2021 was filed together with a court order stating that Judge SHAMA H.
MESIWALA had been disqualified, pursuant to CCP Section 170.6. The Order stated
:(EXHIBIT #41 on flash drive and DVD)
Nature of Proceedings: Minute Order re: Disqualification Purs. CCP
170.6
PLAINTIFF FILED A WRITTEN PEREMPTORY CHALLENGE
PURSUANT TO CCP 170.6 ON 6/29/2021. THE COURT FINDS
THIS FILING AS TIMELY. JUDGE SHARMA H. MESIWALA
HAVING BEEN DISQUALIFIED PURSUANT TO CCP SECTION
170.6 BY PLAINTIFF THIS MATTER IS ORDERED
TRANSFERRED TO DEPARTMENT 54 FOR THE HEARING OF
ALL FUTURE LAW AND MOTION MATTERS.
Th Department 54 and Judge CHRTOPHER KRUEGER are the Law and Motion department
where Porter Scott attorneys DAVID BURKETT and DANIEL BARDZELL prearranged on
October 3, 2018 to obtain termination sanctions with JUDGE KRUEGER, bypassing Judge
DAVID I. BROWN in Dept. 53. Their criminal intent to bypass Judge BROWN and to
terminate my lawsuit and rob my wife of her life saving with corrupted or black mailed judge
KRUEGER did not work as they anticipated . They got caught and their criminal misconduct
was reported .

J. THE JULY 15, 2021 3DCA ORDER THAT DENIED MY FILED ON JUNE
18, 201 MOTION TO RECALL REMITTITUR AND REQUEST FOR

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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


JUDICIAL NOTICE IN THE CASE Waszczuk v. Regents of Univ. of Cal.,
C079524 (Cal. Ct. App. Oct. 10, 2017), FILED ON JUNE 18, 2021
As noted in subchapter B, on June 18, 2021, I filed a Motion for Recall Remittitur and
Motion for Judicial Notice in the above captioned case (anti-SLAPP motion) in 3DCA. These
were my responses to the Porter Scott attorneys’ assault aimed at my wife, IRENA
WASZCZUK, and my effort to protect her from their criminal intent of robbing her of her life
savings and framing her for criminal prosecution.
On July 15, 2021, two weeks after my wife paid a $22,284 ransom to LINDSAY
GOULDING, my request for judicial notice and motion to recall the remittitur, which had
been issued on January 16, 2018, was denied by 3DCA’s rubber stamp justice under
Presiding Justice VANCE RAYE (EXHIBIT #41 on flash drive and DVD).
In July 2021, Presiding Justice VANCE RAYE was under siege due to a politically
motivated witch hunt aimed at removing him from 3DCA carried out by GREGORY
DRESSER.
I noticed from the 3DCA Docket filings in Chodosh v. Commission on Judicial
Performance et al., Case Number C091221, that, contrary to my motion to recall remittitur
in Case No. C079524, Chodosh’s request for judicial notice filed on April 28, 2021 was
denied by a three-justice panel from 3DCA, with the clerk adding the following notification:

Appellant’s motion for judicial notice is denied. The material attached to the
motion will be disregarded. BLEASE, Acting P.J.; RENNER, J.; KRAUSE, J.
Contrary to Chodosh v. Commission on Judicial Performance et al.
Number C091221, my motion for judicial notice in Case No. C079524 was denied not by a
panel of three justices, but with the rubber stamp of 3DCA Presiding Justice Raye, despite
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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


him being under investigation by GREGORY DRESSER. I find it most likely that Justice
VANCE RAYE had nothing to do with denying my motion to recall the remittitur or my
request for judicial notice. The question is, who in 3DCA used Justice RAYE’S identity and
his stamp to erase my motions two weeks after my wife was robbed of $22,284 by Porter
Scott’s attorneys in collaboration or conspiracy with the Court Clerk and Judge THADD
BIZZARD from Sacramento County Superior Court Department 43?

K. JULY 15, 2021 NOTICE OF CHANGE OF HANDLING ATTORNEY


SUBMITTED TO SACRAMENTO COUTY SUPERIOR COURT ON JULY 26,
2021 BY PORTER SCOTT ATTORNEY LINDSAY GOULDING in Jaroslaw
Waszczuk v. The Regents of the University of California, CASE NO. 34-2013-
00155479, FILED ON DECEMBER 4, 2013

Porter Scott Attorney and shareholder LINDSAY GOULDING surfaced for the first time in
my wrongful termination case as a leading attorney, along with her assistant, OLATOMIWA
T. AINA, in April 2021. Their names appeared on the APPLICATION AND ORDER FOR
APPEARANCE AND EXAMINATION filed with the court in an attempt to rob my wife of
her life savings.
Two weeks after GOULDING robbed my wife of $22,284, on July 15, 2021, she
submitted a NOTICE OF CHANGE OF HANDLING ATTORNEY that removed three Porter
Scott attorneys from the handling of my wrongful termination case (EXHIBIT #43 on flash
drive and DVD).I am asking the State Bar’s OCTC investigator to give this notice the
utmost attention, due to the apparent criminal intent involving LINDSAY GOULDING’s
and conspiracy with two former Porter Scott attorney MICHAEL POTT and DAVID

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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


BURKETT to rob my wife of her life savings.

GOULDING’S NOTICE OF CHANGE OF HANDLING ATTORNEY stated:

PLEASE TAKE NOTICE that effective immediately Lindsay


A. Goulding will become the handling attorney of this matter and David
P.E. Burkett, Esq., Michael W. Pott, Esq. and Derek J. Haynes, Esq.,
are to be removed from this matter.

Please update your service lists accordingly and direct all further
pleadings, correspondence and any inquiries regarding defendant
REGENTS OF THE UNIVERSITY OF CALIFORNIA to Lindsay A.
Goulding as follows:

Lindsay A. Goulding
lgoulding@porterscott.com
PORTER SCOTT
350 University Avenue, Suite 200
Sacramento, CA 95825
Telephone: (916) 929-1481
Fax: (916) 927-3706
In July 2021 I was, and remain, unsure why GOULDING submitted this notice letting
me know that she had removed from the wrongful termination case MICHAEL POTT
and DAVID BURKETT who not in any way should be attached to the case since t after
they were fired from Porter Scott law firm .. MICHAEL POTT in January 2015 and
DAVID BURKETT in October 2019. DEREK HAYNES in July 2021 was employed
by Porter Scott and is he is employed today .
Was LINDSAY GOULDING’s notification designed to throw MICHAEL POTT,
DAVID BURKETT, and DEREK HAYNES under the bus and convince me that she was

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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


not responsible for what she had done to my wife on July 2, 2021 in Sacramento Superior
Court Department 43, in collaboration with Judge THADD BLIZZARD and the Court
Clerk?
VII.
THE COURT HEARING HELD VIA ZOOM, SEPTEMBER 1, 2021, IN
SACRAMENTO COUNTY SUPERIOR DEPARTMENT 54 BEFORE HON.
CHRISTOPHER E. KRUEGER, MOTION FOR SUMMARY JUDGMENT IN
SACREMANTO COUNTY SUPERIOR COURT WRONGFUL TERMINATION CASE
Jaroslaw Waszczuk v. The Regents of The University Of California, Mike Boyd, Stephen
Chilcott, Danesha Nichols, Cindy Oropeza, Brent Seifert, Ann Madden Rice, Charles
Witcher, Patrick Putney and Dorin Daniliuc. a CASE NO. 34-2013- 00155479 FILED ON
DECEMBER 4, 2013

A. THE AUGUST 4, 2021 SACRAMENTO COUNTY SUPERIOR COURT


ORDER BY JUDGE GEORGE ACERO, DEPARTMENT 54

One month after I disqualified Judge SHAMA MESIWALA (Cal. Code Civ. Proc. § 170.6),
the former intern for the UC Office of General Counsel and former Porter Scott attorney

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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


GEORGE ACERO surfaced in my wrongful termination case as the Sacramento County
Superior Judge issuing a minute order (EXHIBIT #45 on flash drive and DVD).
The order stated: DATE: 08/04/2021 TIME: 09:00:00 AM DEPT: 54

JUDICIAL OFFICER PRESIDING: GEORGE ACERO


CASE NO: 34-2013-00155479-CU-WT-GDS CASE INIT. DATE: 12/04/2013
CASE TITLE: Waszczuk vs. The Regents of the University of California CASE
CATEGORY: Civil – Unlimited
EVENT TYPE: Motion for Summary Judgment and/or Adjudication - Civil Law
and Motion - MSA/MSJ/SLAPP
APPEARANCES
Nature of Proceeding: Motion for Summary Judgment and/or Adjudication
TENTATIVE RULING
The Court affirmed the tentative ruling.
Motion for Summary Judgment and/or Adjudication - Civil Law and Motion –
MSA/MSJ/SLAPP continued to 09/01/2021 at 09:00 in this department.

The key co-conspirators in my employment termination from the UCDMC were Porter Scott
attorneys and shareholders MICHAEL POTT, DAVID BURKETT, DEREK HAYNES,
LINDSAY GOULDING, and THOMAS RIORDAN, who waited patiently for more than one
year, from December 2019 through April 2021, until SHAMA MESIWALA and GEORGE
ACERO were installed as judges in Department 53. There was no other way for them to
resume their criminal activities in the court to rob my wife of her life savings and to end my
wrongful termination case against the UC Regents and five UCDMC directors and managers,
MIKE BOYD, STEPHEN CHILCOTT, DANESHA NICHOLS, CINDY OROPEZA, and
BRENT SEIFERT, who were responsible for the inhumane and destructive to my life
harassment and my employment termination with UCDMC five years before my planned

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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


retirement from the university. The Porter Scott attorneys were perfectly aware that their
shameful and fraudulent MSA/MSJ/SLAPP motion, filed on May 14, 2021 without five
individual Defendants in the pleading, would not go forward and would not survive if Judge
DAVID I. BROWN was still presiding over my wrongful termination case. GEORGE
ACERO knew on August 4, 2021 that the MSA/MSJ motion filed by GOULDING was a
fraud, should not be allowed to proceed, and should instantly be rejected by the Court after its
filing.
I addressed ACERO (now a judge) in my September 25, 2023 complaint against three former
State Bar employees, GREGORY DRESSER, Case No. 23-0-23272; LAURA HUGGINS,
Case No. 23-0-23273; and ROBIN BRUNE. Case No. 23-0-2332, on Pages 3, 27, 28, 29, 30,
31, 32, 36, & 38 (EXHIBIT #46 on flash drive and DVD).
B. AUGUST 24, 2021 FILED NOTICE OF OBJECTION TO THE
DEFENDANTS’ (I.E., THE REGENTS OF THE UNIVERSITY OF
CALIFORNIA, MIKE BOYD, STEPHEN CHILCOTT, DANESHA
NICHOLS, CINDY OROPEZA, AND BRENT SEIFERT; THEREAFTER
“DEFENDANTS”) EVIDENCE PROFFERED IN THE PLAINTIFF’S
OPPOSITION TO THE DEFENDANTS’ MOTION FOR SUMMARY
JUDGMENT OR, IN THE ALTERNATIVE, SUMMARY
ADJUDICATION

Seven days before the MSA/MSJ Court Hearing, I filed a Notice of Objection to
LINDSAY GOLULDING’s August 20, 2021 objection to my evidence (EXHIBIT #47
on flash drive and DVD). In it, I demanded that the Court reject and deny the
Defendants’ Motion for Summary Judgment, due to fraud upon the court committed by

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Lindsay Goulding who unlawfully excluded from the lawsuit five individual defendants
who were perpetrators of my employment termination. On Page 1 of the notice, I wrote:
The Defendants' attorney, Lindsay Goulding, unlawfully and with corrupt
intentions, excluded the five Defendants, Nichols, Chilcott, Oropeza, Seifert, and
Boyd, from the Defendants’ Objection to the Plaintiff’s Evidence, and Goulding
maintains that these individuals were dismissed from the Plaintiff’s lawsuit in the
same way she did for the Motion for Summary Judgment for all pleadings. The
Plaintiff is respectfully asking the Court to address Attorney Lindsay
Goulding’s misconduct and reject and deny the Defendants’ Motion for
Summary Judgment. The Defendants’ fraud and abuse of the court system
should not be legitimized by the Court. The Plaintiff did not sue Nichols,
Chilcott, Oropeza, Seifert, and Boyd because of the four stricken Causes of Action
(COAs) from the Plaintiff’s Second Amended Complaint (SAC) to the
Defendants’ Special Motion to Strike (anti-SLAPP motion C.C. P 425.16). The
Plaintiff sued these five highly skilled University of California employees for their
violation of the January 30, 2009 Settlement Agreement and violation of the
Plaintiff’s civil and human rights and his rights to live and work in the United
States of America without oppressive witch hunts aimed at him and his family.
Since April 25, 2018, the Defendants’ attorneys, including Lindsay
Goulding, have fraudulently pretended that these individuals were dismissed from
the lawsuit and that the Regents of the University of California are the only
remaining Defendants. After April 25, 2018, the Defendants’ attorney notoriously
and unlawfully relitigated the dismissed by the anti-SLAPP Motion the COAs
from the Plaintiff’s SAC. The Defendants’ Motion for the Summary Judgment or,
in the Alternative, adjudication is the best example of the Defendants’ and the
Defendants’ attorneys’ gross deception, fraud, and professional misconduct.
This should have been the end of the story, and Judge CHRISTOPHER KRUEGER or newly
installed Judge GEORGE ACERO should not have allowed the proceedings to continue, due
to GOULDING’S fraud and deception. GOULDING’S MSA/MSJ should have been
rejected and denied, and the judge should have held her in contempt for her crimes and turned

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her in to the State Bar for her criminal and professional misconduct, pursuant to Rules of
Professional Conduct, and Judicial Canon 3(D)(2).

C. THE SEPTEMBER 1, 2021 MSA/MSJ COURT HEARING


On August 31, 2021, Judge Christopher Krueger, from Department 54, issued a Tentative
Decision granting a Motion for Summary Judgment to The Regents. That same day, I
requested a Court hearing via Zoom with Judge Krueger for September 1, 2021. I expected
at least a one- or two-hour hearing for the case, which had been pending in three different
courts since December 4, 2013. Judge Krueger had just been appointed to the case, taking
over from Judge David Brown, who had presided over it since September 2014.
In an unprecedented way of serving justice, Judge KRUEGER denied my right to be
heard and to present and argue The Regents’ and my submitted documents with an
MSJ/MSA. He abruptly ended the hearing after 5–10 minutes, affirming in that way his
August 31, 2021 tentative ruling which was redacted fragments from the Porter Scott attorney
LINDSAY GOULDINF’s fraudulent MSA/MSA GEORGE ACERO . Judge KREUGER is a
same a Judge who in October 2018 with Judge JENNIFER ROCKWELL was employed by
Porter Scott attorney DAVID BURKETT to obtain termination sanction end my lawsuit and
rob my wife of her life saving .

D. THE REGENTS’ ATTORNEY FROM PORTER SCOTT, THOMAS


RIORDAN
The Porter Scott attorney LINDSAY GOULDING, who fabricated and filed the fraudulent
MSJ on May 14, 2014 and robbed my 70 years old wife of $22,284 did not appear at the
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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


September 1, 2021 MSJ hearing. Another Porter Scott attorney, THOMAS RIORDAN,
appeared for hearing despite not being a legal counsel of record in the case. Throwing
RIORDAN into the game was no coincidence. During the short hearing, Judge KRUEGER
and RIORDAN acted like old friends. THOMAS RIORDAN’s
(https://www.porterscott.com/person/thomas-l-riordan/) record in the State Bar database
(http://members.calbar.ca.gov/fal/Licensee/Detail/104827) shows that he has quite a history
of professional misconduct, including multiple acts of violating court orders and findings of
contempt and harming the administration of justice (see
http://members.calbar.ca.gov/courtDocs/02-O-11078.pdf). Riordan worked for three years as
a research attorney with the 3DCA in Sacramento, where Judge KRUEGER’S wife,
KRISTINE L. BURKS, is employed as a senior research attorney.

E. SEPTEMBER -OCTOBER 2021 CORRESPONDENCE FROM AND TO


STATE OF CALIFORNIA COMMISSION ON JUDICIAL
PERFORMANCE

On September 16, 2021 I received a response to my worries from the Commission Secretary
to the Trial Counsel Ms. MICHELLE KEM.(Kem) .. I replayed to KEM on October 8, 2021
(EXHIBIT #48 on flash drive and DVD)

In my reply to Kem I stated:

My inquiry with the CJP was triggered in the defense of my 70-year-old


wife who has nothing to do with my litigation against the University of
California, but who has nevertheless been threatened by gangsters with J.D.
degrees from the Porter Scott law firm since February 2015. On July 2, 2021, my
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wife was literally robbed of $22,284 from her savings by Porter Scott attorney
Lindsay Goulding in Court Department 43. This happened while appearing
before Judge Thadd Blizzard and the Court Clerk, and after an unsuccessful
attempt to set up my wife for an interrogation to break into her bank and 401(K)
accounts. Judge Blizzard, the Clerk, and Goulding did not want to accept the
$22,284 check from my wife. I literally had to force Goulding to take the check,
which she had no right to cash, and I told her in front of this judge and clerk to
stop harassing my wife. I had a witness with me during this event in court. I
believe this was a coordinated criminal act by the two Court departments (Depts.
43 and 53 or 54 ) to extort money. These departments should be audited by
the State Auditor and the FBI.
I never received any response from MICHELLE KEM, but shortly after I found
out that the former Porter Scott Attorney KATHERINE MOLA is new Senior Counsel
in the California State Auditor’s office.

F. SEPTEMBER 10, 2021 MOTION FOR RECONSIDERATION FRO


SEPTEMBER 1, 2021 COURT ORDER WHICH GRANTED TO THE
DEFENDANTS THE MOTION FOR SUMMARY JUDGMENT OR, IN
THE ALTERNATIVE, SUMMARY ADJUDICATION AND REQUEST
THAT PLAINTIFF MOTION FOR RECONSIDERATION BE
THREADED AS A MOTION FOR NEW TRIAL CAL. CIV. PROC. CODE
§ 1008

On September 10, 2022, I submitted Motion for Reconsideration of Judge


KREUGER'S 09/01/2021 order. EXHIBIT #49 on flash drive and DVD) The motion
was filed by the Court Clerk S.KHORN on September 22, 2021 after a long travel
journey via UPS Express Mail from Lodi, CA to the UPS Distribution Center in West
Sacramento and finally to Sacramento Superior Court, on 9th (40 miles) Street (12 days).

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See my September 19, 2022 Request for Investigation sent to the UPS Customer Service
Center at the West Sacramento Distribution Center (EXHIBIT #50 on flash drive and
DVD)

My motion for reconsideration included copy of August 24, 2021 Notice of Objection to
Porter Scott’s Attorney LINDSAY GOLULDING’s filed on August 20, 2021 objection to my
Evidence in which pointed to the Court that GOULDING’s MSA/MSJ was a fraud filed with
unlawfully removed from the lawsuit five individual defendants MIKE BOYD, STEPHEN
CHILCOTT, DANESHA NICHOLS, CINDY OROPEZA, and BRENT SEIFERT.
Judge Christopher Krueger who presided over the September 1, 2021 ignored my request to t
reject and deny GOULDING’s filed MSA/MSJ and granted the motion anyway.
On the same day September 22, 2021 my motion for reconsideration was filed received e-
mail notification from the Court that my motion for reconsideration was rejected by the . I
retrieved the rejection notice by Court public access which was filed by the different Court

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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


Clerk ERICA MEDINA . Rejection Notification stated: (EXHIBIT #51 on flash drive and
DVD)
We are unable to process the attached papers for the reasons indicated below:
Document Rejected: Motion for Reconsideration
Pursuant to the Civil Public Notice dated 4/29/20, parties must call and request to
reserve a hearing date for Department 54 in advance of filing your documents.
Contact the calendar clerk at 916-874-7848 for reservations.
It is the responsibility of the filing party to review any applicable statute,
California Rules of Court, California Code of Civil Procedure, and Sacramento
Superior Court Local Rules prior to submitting documents.
This form is to be returned if documents are resubmitted for processing.
Papers returned to: Jaroslaw Waszczuk

Clerk of the Court,


/s/ E. Medina

I scheduled/reserved a court hearing with clerk for October 13, 2021 and it was clearly
marked on the motion. Normally the rejected for any reason or discrepancy document by the
clerk would be returned by the US mail within three day by party in litigations and would be
resubmitted with rejection notice .
However , September 23, 2021 one day after my motion for reconsideration was filed and
rejected by Court Clerk ERICA MEDINA the Judge CHRISTOPHER KRUEGER signed
formal ORDER GRANTING DEFENDAN’S MOTION FOR SUMMARY JUDGMENT
(EXHIBIT #52 on flash drive and DVD) . The proposed order was submitted on September
15, 2021 by Porter Scott attorney LINDSAY GOULDING five days after I sent my motion
for reconsideration by UPS from Lodi to Sacramento on September 10, 2021. The signed by

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Judge KRUEGER formal order granting motion for summary judgment before the motion for
reconsideration was decided stated :
On September 1, 2021, Judge Christopher Krueger of the above-entitled court
presiding, after considering the evidence and arguments of the parties, as well as
oral argument following the tentative ruling, granted Defendants' motion for
summary judgment. The reasons of the Court are set forth in the Minute Order
attached hereto as Exhibit A.
IT IS SO ORDERED. Hon. Christopher Krueger
Date: September 23, 2021

Apparently that Judge CHRISTOPHER KRUEGER was informed by clerk ERICA


MEDINA that my motion for reconsideration was rejected because I did not schedule a court
hearing and Judge CHRISTOPHER KRUEGER signed the order . The formal order was
appealing.
ERICA MEDINA is very experienced and well-educated Clerk employed by Sacramento
County Superior Court since 2008. She has a bachelor’s degree in criminal justice. She lives
in West Sacramento where former Porter Scott attorney and now Sacramento County
Superior Court Judge GEORGE ACERO lives . They are similar age.
On October 13,2021 Judge KRUEGER by minute order denied my motion for
reconsideration which was filed on September 22, 2021 and rejected on the same day by
Clerk ERICA MEDINA after already formal Court Order granting MSA/MSJ to UC

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Regents was signed on September 23, 2021 by Judge CHRITOPHER KRUEGER.
(EXHIBIT #53 on flash drive and DVD)
On October 15, 2021 Porter Scott Attorney filed the NOTICE OF ENTRY OF
JUDGMENT of the September 23, 2021 formal Court Order granting MSA/MSJ to UC
Regents. (EXHIBIT #54 on flash drive and DVD)
On October 28, 2021 Judge Christopher Krueger signed JUDGMENT FOLOWING
ORDER GRANTING DEFENDANT’S MOTION FOR SUMMARY JUDGMENT
which sounded slightly different than signed Court Order dated September 23, 2021.
(EXHIBIT #55 on flash drive and DVD
On September 23, 2021, Judge Christopher Krueger of the above-entitled court
presiding, after considering the evidence and arguments of the parties, as well as
oral argument following the tentative ruling, granted Defendant's motion for
summary judgment. A true and correct copy of the filed Order is attached hereto
as Exhibit A.
On October 13, 2021, Judge Krueger denied Plaintiff's motion for reconsideration
from the order granting the summary judgment motion.
IT IS HEREBY ORDERED, ADJUDGED AND DECREED that Judgment be
entered in favor of Defendant Regents of the University of California and against
Plaintiff Jaroslaw Waszczuk. Defendant is entitled to costs as the prevailing
party pursuant to section 1032 of the Code of Civil Procedure.
Date: October 28, 2021 Hon. Christopher Krueger
Approved as to form:
Jaroslaw Waszczuk
Porter Scott attorney did not file NOTICE OF ENTRY OF JUDGMENT from this
Judgment and confused me from which order I should file an appeal in Court of Appeals ,
Third Appellate thus I decided to file an appeal from October 28, 2021 JUDGMENT

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FOLOWING ORDER GRANTING DEFENDANT’S MOTION FOR SUMMARY
JUDGMENT
In contrary to September 23, 2021 signed order , the October 28, 2021 Judgment stated
that Defendant is entitled to costs as the prevailing party pursuant to section 1032 of
the Code of Civil Procedure.
On October 28, 2020, Judge KRUEGER'S signed judgment was of the September 1,
2021, (EXHIBIT #49 on flash drive and DVD Court Minute Order (CT Vol. 13, pp.
3754--3761) issued right after the Court Hearing in which Judge Krueger, on September
1, 2021, cut off Plaintiff after approximately 10 minutes depraving Plaintiff to be heard
and present his rebuttal to the September 1, 2021, Court Minute Order on the case that
has been pending since December 4, 2013
The September 1, 2021, Minute Court order is the short version of the Defendant's
counsel, despicable lies about Plaintiff filed in the May 14, 2021, Memorandum of Points
and Authorities in Support of the Defendant's Motion for Summary Judgment (MSJ) or in
the Alternative Summary Adjudication (MSA) (CT Vol. 9, pp. 2459-2500) and the
August 20, 2021, Respondent's Reply Memorandum of Points and Authorities in Support
of Defendants Motion for MSJ or in the Alternative MSA (CT Vol. 12, pp. 3397-3402)

G. THE SEPTEMBER 1, 2021 MSA/MSJ COURT HEARING

On August 31, 2021, Judge CHRISTOPHER KRUEGER, from Department 54, issued a
Tentative Decision granting a Motion for Summary Judgment to The Regents. That same day,
I requested a Court hearing via Zoom with JUDGE KRUEGER for September 1, 2021. I
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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


expected at least a one- or two-hour hearing for the case, which had been pending in three
different courts since December 4, 2013. Judge KRUEGER had just been appointed to the
case, taking over from Judge DAVID BROWN, who had presided over it since September
2014.
In an unprecedented way of serving justice, Judge KRUEGER denied my right to be
heard and to present and argue The Regents’ and my submitted documents with an
MSJ/MSA. He abruptly ended the hearing after 5–10 minutes, affirming in that way his
August 31, 2021 tentative ruling which was redacted fragments from Porter Scott attorney
LINDSAY GOULDING’S fraudulent MSA/MSA before GEORGE ACERO. Judge
KREUGER was the same judge who, in October 2018, along with Judge JENNIFER
ROCKWELL, was employed by Porter Scott attorney DAVID BURKETT to obtain
termination sanctions to end my lawsuit and rob my wife of her life savings.

H. THE REGENTS’ ATTORNEY FROM PORTER SCOTT, THOMAS


RIORDAN
LINDSAY GOULDING, who fabricated and filed the fraudulent MSJ on May 14, 2014 and
robbed my wife of $22,284, did not appear at the September 1, 2021 MSJ hearing. Another
Porter Scott attorney, THOMAS RIORDAN, appeared for the hearing, despite not being a
legal counsel of record in the case. Throwing RIORDAN into the game was no coincidence.
During the short hearing, Judge KRUEGER and RIORDAN acted like old friends. THOMAS
RIORDAN’s record in the State Bar database (https://www.porterscott.com/person/thomas-l-
riordan/, http://members.calbar.ca.gov/fal/Licensee/Detail/104827) shows that he has quite a
history of professional misconduct, including multiple acts of violating court orders and
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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


findings of contempt and harming the administration of justice (see
http://members.calbar.ca.gov/courtDocs/02-O-11078.pdf). Riordan worked for three years as
a research attorney with the 3DCA in Sacramento, where Judge KRUEGER’S wife,
KRISTINE L. BURKS, is employed as a senior research attorney.

I. SEPTEMBER–OCTOBER 2021 CORRESPONDENCE TO AND FROM


THE STATE OF CALIFORNIA’S COMMISSION ON JUDICIAL
PERFORMANCE

On September 16, 2021, I received a response to my worries from the Commission’s


Secretary to the Trial Counsel, MICHELLE KEM. I replied to KEM on October 8, 2021
(EXHIBIT #48 on flash drive and DVD). In that reply, I said:

INSERT QUOTE

My inquiry with the CJP was triggered in the defense of my 70-year-old


wife who has nothing to do with my litigation against the University of
California, but who has nevertheless been threatened by gangsters with J.D.
degrees from the Porter Scott law firm since February 2015. On July 2, 2021, my
wife was literally robbed of $22,284 from her savings by Porter Scott attorney
Lindsay Goulding in Court Department 43. This happened while appearing
before Judge Thadd Blizzard and the Court Clerk, and after an unsuccessful
attempt to set up my wife for an interrogation to break into her bank and 401(K)
accounts. Judge Blizzard, the Clerk, and Goulding did not want to accept the
$22,284 check from my wife. I literally had to force Goulding to take the check,
which she had no right to cash, and I told her in front of this judge and clerk to
stop harassing my wife. I had a witness with me during this event in court. I
believe this was a coordinated criminal act by the two Court departments (Depts.

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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


43 and 53 or 54 ) to extort money. These departments should be audited by
the State Auditor and the FBI.

END QUOTE
I never received a response from KEM, but shortly thereafter I learned that the
former Porter Scott Attorney KATHERINE MOLA was the new Senior Counsel in the
California State Auditor’s office.

J. SEPTEMBER 10, 2021 MOTION FOR RECONSIDERATION OF


THE SEPTEMBER 1, 2021 COURT ORDER THAT GRANTED TO
THE DEFENDANTS THE MOTION FOR SUMMARY JUDGMENT OR,
IN THE ALTERNATIVE, SUMMARY ADJUDICATION AND REQUEST
THAT PLAINTIFF MOTION FOR RECONSIDERATION BE
THREADED AS A MOTION FOR NEW TRIAL CAL. CIV. PROC. CODE
§ 1008

On September 10, 2022, I submitted a Motion for Reconsideration of Judge


KREUGER’S 09/01/2021 order (see EXHIBIT #49 on flash drive and DVD). The
motion was filed by the Court Clerk, S. KHORN, on September 22, 2021 after a long
travel journey via UPS Express Mail from Lodi, CA to the UPS Distribution Center in
West Sacramento, and finally to Sacramento Superior Court, on 9th Street (40 miles over
12 days). Please also see my September 19, 2022 Request for Investigation, which I sent

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to the UPS Customer Service Center at the West Sacramento Distribution Center
(EXHIBIT #50 on flash drive and DVD).
My motion for reconsideration included a copy of the August 24, 2021 Notice of
Objection to LINDSAY GOLULDING’s August 20, 2021 objection to my Evidence, in
which I pointed out to the Court that GOULDING’s MSA/MSJ was a fraud, as it had been
filed with an unlawful removal from the lawsuit five individual defendants: MIKE BOYD,
STEPHEN CHILCOTT, DANESHA NICHOLS, CINDY OROPEZA, and BRENT
SEIFERT.
Judge CHRISTOPHER KRUEGER, who presided over the September 1, 2021
hearing, ignored my request to reject and deny GOULDING’s filed MSA/MSJ and granted
the motion anyway.
On the same day my motion for reconsideration was filed, September 22, 2021, I
received an e-mail notification from the Court that it had been rejected. I retrieved the
rejection notice via the Court’s public access service. It was filed by a different Court Clerk,

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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


ERICA MEDINA. The Rejection Notification stated (EXHIBIT #51 on flash drive and
DVD):

We are unable to process the attached papers for the reasons indicated below:
Document Rejected: Motion for Reconsideration
Pursuant to the Civil Public Notice dated 4/29/20, parties must call and request to
reserve a hearing date for Department 54 in advance of filing your documents.
Contact the calendar clerk at 916-874-7848 for reservations.
It is the responsibility of the filing party to review any applicable statute,
California Rules of Court, California Code of Civil Procedure, and Sacramento
Superior Court Local Rules prior to submitting documents.
This form is to be returned if documents are resubmitted for processing.
Papers returned to: Jaroslaw Waszczuk

Clerk of the Court,


/s/ E. Medina

I scheduled/reserved a court hearing with the clerk for October 13, 2021, and it was clearly
marked on the motion. Normally, a document rejected by the clerk for any reason or
discrepancy would be returned by US Mail within three days, so the parties in the litigation
would be able to resubmit their documents. However, on September 23, 2021, one day after
my motion for reconsideration was filed and rejected by ERICA MEDINA, Judge
CHRISTOPHER KRUEGER signed a formal ORDER GRANTING DEFENDANT’S
MOTION FOR SUMMARY JUDGMENT (EXHIBIT #52 on flash drive and DVD). The
proposed order was submitted on September 15, 2021 by LINDSAY GOULDING, five days
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after I sent my motion for reconsideration via UPS from Lodi to Sacramento. Judge
KRUEGER’S formal order granting the motion for summary judgment before the motion for
reconsideration was decided stated:
On September 1, 2021, Judge Christopher Krueger of the above-entitled court
presiding, after considering the evidence and arguments of the parties, as well as
oral argument following the tentative ruling, granted Defendants’ motion for
summary judgment. The reasons of the Court are set forth in the Minute Order
attached hereto as Exhibit A.
IT IS SO ORDERED. Hon. Christopher Krueger
Date: September 23, 2021

Apparently, Judge CHRISTOPHER KRUEGER was informed by Clerk ERICA MEDINA


that my motion for reconsideration had been rejected because I did not schedule a court
hearing and Judge CHRISTOPHER KRUEGER signed the order.
ERICA MEDINA is a very experienced and well-educated Clerk who has been employed by
Sacramento County Superior Court since 2008. She holds a bachelor’s degree in criminal
justice. She lives in West Sacramento, where former Porter Scott attorney now Sacramento
County Superior Court Judge GEORGE ACERO lives. They are of similar age.

In September 2014 ERICA MEDINA helped my former attorney DOUGLAS STEIN


and Porter Scott’s attorney MICHAEL POTT to direct the altered (not amended ) by

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them my wrongful termination complaint to Judge DAVID I . BROWN in Sacramento
Superior Court Department 53 for proceeding without Leave of Court.
DOUGLAS STEIN was a financially devastated drugs addict and Porter Scott attorneys
took advantage of STEIN addiction and his financial situation and utilized his long time
friendship with Judge DAVID I. BROWN to eliminate my presence in the court .
My December 4, 2013 wrongful termination complaint filed in pro per had six Causes
of Action,(COA) which included Wrongful Suspension and Wrongful Termination;
Violation and Breach of the 2009 Settlement Agreement which I signed with the Regents
of the University of California in good faith; and the violation of UC Davis Policy PPSM
23, which is the employees’ annual performance review (evaluation) policy
STEIN decimated MY original wrongful termination complaint altering it and named as
First Amended Complaint (FAC) filed on June 16, 2014 and refiled by stipulation with POTT
as a Second Amended Complaint (SAC) on September 30, 2014. He did this by removing two
crucial COAS, wrongful suspension and violation of the PPSM 23 employee evaluation
policy, and adding two COAs that were damaging to the lawsuit, wage and hour
misclassification and rescission of contract

I dismissed STEIN on December 16, 2014 and he was disbarred for his gross misconduct in
January 2020 instead to be disbarred in 2015 or early in 2016. (see
https://apps.calbar.ca.gov/attorney/Licensee/Detail/131248, In re Stein, No. S245982 (Cal.

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Mar. 1, 2018)).
MICHEL POTT who in conspiracy with STEIN dragged Judge DAVID I. BROWN in to
dirty game against me in 2014 was fired by Porter Scott on January 23, 2015 and
magically resurfaced in my wrongful termination case six years later on July 15, 2021.
See : page 58 &59. July 15, 2021 Notice of Change Of Handling Attorney submitted to
Sacramento Couty Superior Court on July 26, 2021 by Porter Scott Attorney LINDSAY
GOULDING

Furthermore the mentioned above court clerk ERICA MEDINA in collaboration with
Porter Scott attorney DAVID BURKETT deliberately filed the motion for termination
sanction with Department 54 -Judge CHRISTOPHER KRUEGER instead of
DEPARTMENT 53-Judge DAVID I. BROWN .
Porter Scott attorney DAVID BURKETT who was fired by his employer in October 2019
magically resurfaced two years later as well on July 26, 2021
in my wrongful termination case together with MICHAEL POTT

On April 26, 2021 court clerk filed Porter Scott’s attorney LLINDSAY GOULDING’s
EX PARTE APPLICATION FOR LEAVE TO EXTEND PAGE LIMIT FOR
DEFENDANT’S MOTION FOR SUMMARY JUDGMENT OR, IN THE
ALTERNATIVE, SUMMARY ADJUDICATION. The ex-parte pleading was not
marked which court department and which judge in the Sacramento County Superior
would be handle the GOULDING’s ex -parte. It was done deliberately with evil
intention not let me find out that Judge DAVID I. BROWN who was handling my case
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since September 2014 was replaced on January 2, 2021 by Judge SHAMA MESIWALA
who granted the GOULDIN’s ex-parte without a court hearing .
On October 13, 2021, Judge KRUEGER issued a minute order denying my motion for
reconsideration that was filed on September 22, 2021 and rejected that same day by Clerk
MEDINA, after already issuing a formal Court Order granting the MSA/MSJ to the UC
Regents. KRUEGER signed it on September 23, 2021 (EXHIBIT #53 on flash drive
and DVD).

On October 15, 2021, Porter Scott Attorney LINDSAY GOULDING filed the NOTICE
OF ENTRY OF JUDGMENT of the September 23, 2021 formal Court Order granting the
MSA/MSJ to the UC Regents (EXHIBIT #54 on flash drive and DVD).

On October 28, 2021, Judge Christopher KRUEGER signed a JUDGMENT


FOLLOWING ORDER GRANTING DEFENDANT’S MOTION FOR SUMMARY
JUDGMENT, which sounded slightly different than the Court Order dated September 23,
2021 (EXHIBIT #55 on flash drive and DVD).

INSERT QUOTE

On September 23, 2021, Judge Christopher Krueger of the above-entitled court


presiding, after considering the evidence and arguments of the parties, as well as
oral argument following the tentative ruling, granted Defendant's motion for

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summary judgment. A true and correct copy of the filed Order is attached hereto
as Exhibit A.
On October 13, 2021, Judge Krueger denied Plaintiff's motion for reconsideration
from the order granting the summary judgment motion.
IT IS HEREBY ORDERED, ADJUDGED AND DECREED that Judgment be
entered in favor of Defendant Regents of the University of California and against
Plaintiff Jaroslaw Waszczuk. Defendant is entitled to costs as the prevailing
party pursuant to section 1032 of the Code of Civil Procedure.
Date: October 28, 2021 Hon. Christopher Krueger
Approved as to form:
Jaroslaw Waszczuk

Porter Scott attorney LINDSAY GOULDING did not file at all a Memorandum of Cost
California per Rules of Court, rule 870(a)(1e) after the NOTICE OF ENTRY OF
JUDGMENT was filed .

VIII.
THE RIGGED OR FIXED APPEAL - CALIFORNIA COURT OF APPEALS, THIRD
APPELLATE DISTRICT (3DCA) CASE JAROSLAW WASZCZUK V. THE REGENTS
OF THE UNIVERSITY OF CALIFORNIA ET AL., NO. C095488, AND TRIAL COURT
CASE JAROSLAW WASZCZUK V. THE REGENTS OF THE UNIVERSITY OF
CALIFORNIA, CASE NO. 34-2013- 00155479, FILED ON DECEMBER 4, 2013
(SHORT TITLE)

PERPETRATORS AND CO-CONSPIRATORS WHO, WITH CRIMINAL INTENT,


RIGGED OR FIXED THE APPEAL IN 3DCA CASE NO. C095488 W

1. LINDSAY A. GOULDING, SBN 227195, Porter Scott attorney & shareholder


2. THOMAS L. RIORDAN, SBN 104827, Porter Scott attorney & shareholder
3. KAREN M. BRAY, SBN 175501, Horvitz & Levy LLP attorney & shareholder

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4. H. THOMAS WATSON, SBN 160277, Horvitz & Levy LLP attorney &
shareholder
5. KEVIN MICHOUD, Clerk, Sacramento County Superior Court Appellate
Department
6. COLETTE M. BRUGGMAN, 3DCA Clerk/Executive Officer
7. ANDREA LYNN HOCH, 3DCA Associate Justice (Retired)

8. RONALD B. ROBIE, 3DCA Associate Justice, Acting Presiding Justice (June 1,


2022–August 24, 2023), former Sacramento County Superior Court Judge
9. LAURIE M. EARL, 3DCA Presiding Justice as of July 10, 2023, former
Associate Justice and Sacramento County Superior Court Judge
10. LOUIS MAURO, 3DCA Associate Justice since 2010, former Sacramento
County Superior Court Judge
11. JONATHAN K. RENNER, 3DCA Associate Justice since 2015

In January or February 2021, the Porter Scott law firm and its attorneys, who supposedly
represented the UC Regents in my wrongful termination case, were tipped off or informed
that Sacramento County Superior Court Judge DAVID I. BROWN, from the Law and Motion
Department, would be removed from the bench and forced to resign. The firm and its
attorneys were also informed that Judge BROWN, who had presided over my wrongful
termination case since September 2014, would be replaced by Judge SHAMA HAKIM
MESIWALA and the former Porter Scott attorney GEORGE ACERO as a backup judge in
Departments 53 and Department 54 (Law and Motion).
Porter Scott attorneys LINDSAY GOULDING, DEREK HAYNES, THOMAS RIORDAN,
and two former Porter Scott Attorneys, MICHAEL POTT and DAVID BURKETT, waited

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for more than one year, until MESIWALA and ACERO were installed in Sacramento
Superior Court before launching in April 2021 a coordinated attack aimed at my wife and me,
with the criminal intent of robbing my wife of her life savings and ending my wrongful
termination lawsuit against the UC Regents. They did this using by the totally fraudulent and
unlawful MSA/MSJ motion which was granted to them on September 1, 2021 by Judge
CRISTOPHER KRUEGER, from Law and Motion Department 54, who was most likely
blackmailed or bribed by Porter Scott attorneys.
The Porter Scott attorneys and shareholders LINDSAY GOULDING and THOMAS
RIORDAN, and two Horvitz & Levy LLP attorneys and shareholders, KAREN BRAY and
THOMAS WATSON, conspired with Sacramento County Superior Appellate Department
Clerk KEVIN MICHAUD and 3DCA’s justices and staff to continue their criminal activities
in the courts and to rig my appeal of the unlawful MSA/MSJ Judgment signed on October 28,
2021 by Sacramento County Superior Court Judge CHRISTOPHER KRUEGER from
Department 54.

This happened because, in 2021 or early 2022 Porter Scott and Horvitz & Levy attorneys
were informed that the 3DCA’s Presiding Justice, VANCE RAYE, would be removed from
his position and from the 3DCA by a witch hunt launched in November 2020 that was
orchestrated by the Director and Chief Counsel of the Commission of Judicial Performance,
GREGORY DRESSER.

After Chief Justice RAYE VANCE was expelled on June 1, 2022, LINDSAY GOULDING,
THOMAS RIORDAN, KAREN BRAY, and THOMAS WATSON were free to do whatever
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they desired in pursuit of their goal of derailing my appeal, which never should have taken
place.

Below, I have detailed the events surrounding this rigged and fixed appeal by the above-listed
attorneys, judicial officers, and staff from Sacramento County Superior Court and 3DCA.

A. THE NOTICE OF APPEAL FROM THE UNLAWFUL OCTOBER 28, 2021


SCAREMENTO COUNTY SUPERIOR COURT JUDGE CHRISTOPHER
KRUEGER’S JUDGMENT FOLLOWING AN ORDER GRANTING
DEFENDANT’S MOTION FOR SUMMARY JUDGMENT IN THE
WRONGFUL TERMINATION CASE Jaroslaw Waszczuk v. The Regents of the
University of California, No. 34-2013-00155479 (Short Title)

On December 23, 2021, I filed a Notice of Appeal concerning the totally unlawful October
28, 2021 Judgement in Motion of Summary Judgment (MSA/MSJ), which was perpetrated by
LINDSAY GOULDING and THOMAS RIORDAN in conspiracy with JUDGE
CHRISTOPHER E. KRUEGER and his staff (EXHIBIT #56 on flash drive and DVD).
As noted previously, LINDSAY GOULDING, without informing me, usurped for herself the
Court’s power and unlawfully removed five individual Defendants, DANESHA NICHOLS,
STEPHEN CHILCOTT, BRENT SEIFERT, MIKE BOYD, and CINDI OROPEZA, from the
MSA/MSJ, falsely claiming that they had been dismissed by the anti-SLAPP motion
granted to them on February 6, 2015 by the Sacramento County Superior Court Judge
DAVID I. BROWN.

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The original lawsuit complaint against the UC Regents and nine individual defendants
had eight Causes of Action. I dismissed four of the nine individual defendants on
October 1, 2015 but DANESHA NICHOLS, STEPHEN CHILCOTT, BRENT SEIFERT,
MIKE BOYD, and CINDI OROPEZA were not among them, as they were the key
perpetrators and co-conspirators with the Porter Scott attorneys in the 2005–2008 and
2011–2012 efforts to witch hunt me and terminate my employment with the UC Davis
Medical Center and to deport me to my native country Poland .
The Motion of Summary Judgment filed by LINDSAY GOULDING on May 14, 2021
would never have been approved and granted if Judge DAVID I. BROWN was still in
charge of Department 53 (Law and Motion).
It was my understanding that LINDSAY GOULDING demonstrated a deliberate and
premeditated failure to file a Memorandum of Cost, per California Rules of Court rule
870(a)(1e), after the NOTICE OF ENTRY OF JUDGMENT was filed. She was hoping that
I would not pursue the case and that I would not file an appeal.

B. APPELLANT’S NOTICE DESIGNATING RECORD ON APPEAL, FILED ON


JANUARY 31, 2022

On January 31, 2022, I filed a Notice Designating Record on Appeal that included a request
to produce and transmit to 3DCA the Court Reporter’s Transcript from the September 1, 2021
Court hearing with Sacramento County Superior Court Judge Christopher E. Krueger, of
Department 54 (Court hearing for Motion for Summary Judgment, (EXHIBIT #57 on flash
drive and DVD).
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C. NOTICE OF DEFAULT -THE FIRST ATTEMPT TO DERAIL OR DISMISS
MY APPEAL

On March 1, 2022, I received a Notice of Default from the Sacramento Superior Court,
Appellate Unit clerk KEVIN MICHAUD (attached with correspondence to 3DCA clerk ),
which stated: (EXHIBIT #58 on flash drive and DVD).

You are hereby notified that you are in default for failure to:

[X] Deposit the Court Reporters fee for preparation of the Reporter's Transcript

In addition to the Superior Court trust hold fee of $50 (payable as separate
checks) as required by C.R.C. 8.130(b)(1) or substitute for cost of transcript
under C.R.C. 8.1130(b)(3).

[IX] As an Appellant your appeal may be dismissed by the reviewing court if


you fail to perform the act(s) necessary to procure the record as enumerated
in this notice within 15 days of the date of the mailing of this notice.
On the bottom of the Notice of Default, you could read in bold italic letters:

TO: THIRD DISTRICT COURT OF APPEAL


/7 APPELLANT has failed to relieve the above matter from default.
The Appeals Unit of the Sacramento Superior Court is requesting a dismissal of
the above referenced case on appeal.
DATED:
Deputy Clerk
Superior Court of California

Nothing would be unusual about this NOTICE DEFAULT if I would not pay . However
, on August 31, 2021 the Court Order granted me Waiver which was filed together with
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my January 31, 2022 APPELLANT’S NOTICE DESIGNATING RECORD ON APPEAL in
Sacramento Superior Court, Appellate Unit and clerk KEVIN MICHAUD knew about.
However. Thie clerk was instructed by somebody to harass me , knowing that I would
have a problem to pay living on Social Security pension and eventually I would have
problem to pay for Reporter Transcript and appeal would be dismissed .
The August 31, 2021, granted Court Fee Waiver by the Court and included:

• Filing papers in Superior Court


• Making copies and certifying copies
• Sheriff's fee to give notice
• Court fee for phone hearing
• Reporter's fee for attendance at hearing or trial, if reporter provided by the
court
• Assessment for court investigations under Probate Code sections 1513, 1826,
or 1851
• Preparing, certifying, copying, and sending the clerk's transcript on appeal
• Holding in trust the deposit for a reporter's transcript on appeal under rules
8.130 or 8.834
• Making a transcript or copy of an official electronic recording under rule
8.835
• Sending papers to another court
• Court-appointed interpreter in small claims court

The August 31, 2021, Court Order on Court Fee Waiver was clear and waived the
reporter's fee for attendance at hearing or trial and preparing, certifying, copying,
and making a transcript or copy of an official electronic recording under rule 8.835.
Regardless of the August 31, 2021, Court Order on Court Fee Waiver I borrowed $
375.000 from my wife who was robbed on July 2, 2021 of $22,284 by Porter Scott

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attorneys I collaboration and conspiracy with Court Clerk and Judge THADD
BLIZZARD from Sac. County Superior Court Department 43.
On March 9, 2022, I submitted two separate checks for $50 and $325 to clear the alleged
default and avoid having my appeal dismissed, according to California Rules of Court
8.130(b)(1) and 8.130(b)(1)(b)(i). The checks both cleared on March 17, 2022; the $375 and
I should be reimbursed by the Court .

D. THE LATE, INCOMPLETE AND WRONGLY LABELED CLERK


TRANSCRIPT ON APPEAL

On March 23, 2022 the Regents of the University of California added two attorneys.
attorney H. THOMAS WATSON and attorney KAREN M. BRAY from Horvitz and
Levy LLP , the prestigious appellate law firm based in Burbank , CA .

On April 11, 2022 I was notified by the Sacramento Superior Court Clerk , Appellate
Department KEVIN MICHAUD that the cost to the APPELLANT for preparing and certifying
the clerk's transcript on appeal is $5777.

On April 15, 2022 I replied to clerk KEVIN MICHAUD (EXHIBIT #59 on flash drive
and DVD) I advised him that Court, 8/31/2021 order, waived my court fees and costs
for preparing, certifying, copying, and sending the clerk's transcript on appeal.
In addition to the above, I advised KEVIN MICHAUD that the NOTICE OF FILING OF
DESIGNATION AND NOTICE TO REPORTERS TO PREPARE TRANSCRIPTS
Judge DAVID BROWN is wrongfully listed as the Judge who caused this appeal. Judge
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CHRISTOPHER KROEGER from Dept 54.was the Judge that granted MSA/MSJ on
September 1, 2021 Also , his notifications listed DOUGLAS ROPEL SB #300486 as the
Defendant’s counsel in this case. DOUGLAS ROPEL quit working for the Porter Scott
law firm in March 2016 and had nothing to do with filed MSA/MSJ by LINDSAY
GOULDING on May 14, 2021. Within 30 days from clerk KEVIN MICHAUD”s
notification I should receive the Clerk Transcript on Appeal (CT) approximately around
May 15, 2022. and copy should be transmitted to 3DCA (CRC rules 8.122(d),
8.150(a).) However, I received the 13 volumes of CT on June 28, 2022.

E. A CLOSER LOOK AT THE INCOMPLETE AND WRONGLY LABELED


TRANSCRIPT ON APPEAL

1) After I received on June 28, 2022 the 13 volumes of the CLERK’S TRANSCRIPT
ON APPEAL (CT), I noticed that the CT had the wrong judge’s name and wrong
attorney (EXHIBIT #60 on flash drive and DVD)
2) It said “CLERK'S TRANSCRIPT ON APPEAL FROM THE JUDGMENT OF THE
SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE
COUNTY OF SACRAMENTO HON. DAVID BROWN DOUGLAS ROPEL
#300486, 350 UNIVERSITY AVE., STE 200 SACRAMENTO, CA 95825 Attorney
Defendant/Respondent,” instead of HON. CHRISTOPHER E. KRUEGER and
Defendant’s Attorneys LINDSAY GOULDING, who is the Defendants’ Attorney of
Record on Appeal, or THOMAS RIORDAN, who attended the Motion for Summary
Judgment Court Hearing with Judge CHRISTOPHER KRUEGER via Zoom on
September 1, 2021.

3) The CT was certified on April 22, 2022 by Sacramento County Superior Court
Appellate Department CLERK KEVIN MICHAUD with his initials KM (EXHIBIT
#61 on flash drive and DVD)

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4) The DECLARATION OF MAILING, which should be dated and signed under
penalty of perjury by the Sacramento County Superior Court Clerk, most likely by
KEVIN MICHOUD, was left blank (undated and unsigned), rendering it basically
unlawful, invalid and it contained the wrong name of the Defendants’ attorney,
DOUGLAS ROPEL, who did not work for Porter Scott and has not represented the
UC Regents since March 2016 (https://www.littler.com/lawyer-
search?lawyer_auto=ropel, (EXHIBIT #61 on flash drive and DVD)
5) The CRT from the September 1, 2021 Court Hearing with JUDGE CHRISTOPHER
KRUEGER, which was due to be produced and transmitted to 3DCA by May 9, 2022,
was not produced and transmitted to 3DCA at all.

After I received an incomplete and deliberately mislabeled CT, I scratched my head,


wondering how it was even possible for a court reporter to prepare a transcript on appeal per
notice from the Appellate Department with the wrong Judge listed on the notice. Today, I
know that no one but the Porter Scott attorneys coerced or bribed Sacramento County
Superior Court Appellate Department Clerk KEVIN MICHAUD to help them to derail the
appeal after their criminal misconduct in Superior Court. This was not a trivial matter. This
was, and still is, an obstruction of justice and unlawful interference with the reviewing
court’s proceedings.
It is still unknown who FORCED OR COERCED the preparer of the CLERK
TRANSCRIPT ON APPEAL to deliberately, maliciously, and with premeditation mislabel
the CT with the wrong judge’s name.
More precisely, who forced the CT preparer to replace JUDGE CHRISTOPHER
KRUEGER’S name with that of JUDGE DAVID BROWN, from Department 53, and why
did they do this?
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Judge DAVID BROWN resigned in December 2020 and had nothing to do with
LINDSAY GOULDING’S MSA/MSJ filed on May 14, 2021, which should have been
rejected and never decided by JUDGE CHRISTOPHER KRUEGER on September 1,
2021.
Who forced KEVIN MICHAUD to certify the deliberately mislabeled and incomplete
CLERK TRANSCRIPT on appeal?
Who ordered KEVIN MICHAUD to withhold sending the CLERK TRANSCRIPT on
appeal to 3DCA for the next 68 days after its certification? The undated and unsigned
DECLARATION OF MAILING, which should have been signed by MICHAUD, indicates
that he perhaps did not want to deal with the orchestrated fraud, deception, and unlawful
interference with the reviewing court’s proceedings. It needs to be investigated who is behind
this crime to derail the appeal process.

The superior court clerk must “promptly mail” to the Court of Appeal notification of
the filing of a notice of appeal. (Cal. Rules of Court, rule 8.304(c)(1).) “The failure of
a court reporter or clerk to perform any duty imposed by statute or these rules that
delays the filing of the appellate record is an unlawful interference with the
reviewing court’s proceedings. . . .” ( Id., rule 8.23.) People v. Grimes, 172
Cal.App.4th 121 (Cal. Ct. App. 2009)
Each item in the rules has the force of law (Carlson v. Department of Fish &
Game (1998) 68 Cal.App.4th 1268, 1272).

On July 5, 2022, I submitted to the Sacramento County Superior Court Appellate


Department a NOTICE OF OMISSION or request to produce the omitted items in the
Clerk’s Transcript on Appeal and to prepare the CRT from the September 1, 2021
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hearing with Judge CHRISTOPHER KRUEGER(EXHIBIT #62 on flash drive and
DVD)
Also, on July 5, 2022 due to an incomplete and deceptive record on appeal, I submitted
to 3DCA an APPLICATION FOR EXTENSION OF TIME TO FILE BRIEF due to an
incomplete and deceptive record on appeal, on July 5, 2022, I submitted to 3DCA an
APPLICATION FOR EXTENSION OF TIME TO FILE BRIEF with declaration and
cover letter addressed to 3DCA Clerk/Executive Officer ANDREA K. WALLIN-
ROHMANN (EXHIBIT #63 on flash drive and DVD)

On July 5, 2022 3DCA Executive Officer WALLIN-ROHMANN was perfectly aware


and she knew what happened to Sacramento County Superior Judge DAVID I BROWN
and 3DCA Presiding Justice VANCE RAYE . She also knew that it was unlawful how
the clerk from Sacramento Superior Court , Appellate Department KEVIN MICHAUD
handled the Clerk Transcript on Appeal and Reporter Transcript .
. The Defendants’ new attorney from Horvitz & Levy LLP, KAREN BRAY, added her
stipulation to the application with condition, stating:

We will stipulate to a 60-day extension of time for your opening brief, so


long as any such stipulation also includes a reciprocal 60-day extension
for our respondent’s brief
The application for extension of time was granted that same day, July 5, 2022, by the Court
with Appellant’s Opening brief due October 10, 2022.

F. THE CLERK’S SUPPLEMENTAL TRANSCRIPT ON APPEAL


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On July 13, 2022 in the response to my July 5, 2022 Notice of Omission, I received
only one volume of the CLERK’S SUPPLEMENTAL TRANSCRIPT ON APPEAL,
https://www.scribd.com/document/597295235/3DCA-Clerk-s-Suplemental-Transcript-on-
Appeal-Waszczuk-v-UC-Regents-Et-Al-Case-No-C095488) and 13 pages of the new cover
page with Judge CHRISTOPHER KRUEGER’S name replacing the wrongfully labeled front
page of the 13-volume Clerk’s Transcript on Appeal, which had listed Judge DAVID
BROWN’S name. I had received that on June 28, 2022. There was no record or note from the
3DCA Clerk that the first page in the 13-volume Clerk’s Transcript on Appeal was replaced
with the correct first page showing Judge CHRISTOPHER KRUEGER’S name and the
correct Defendants’ attorney name, LINDSEY GOULDING or THOMAS RIORDAN
The CLERK’S SUPPLEMENTAL TRANSCRIPT ON APPEAL contained the most
important Court-filed document for this Appeal, which shall be submitted to 3DCA as a
CLERK’S TRANSCRIPT ON APPEAL Volume No. 1 instead of CLERK’S
SUPPLEMENTAL TRANSCRIPT ON APPEAL

1) My (Plaintiff and Appellant’s) ORIGINAL WRONGFUL TERMINATION


COMPLAINT filed in Sacramento County Superior Court on December 4, 2014.
2) The FIRST AMENDED COMPLAINT (FAC) filed on June 16, 2014 in fact was
not the FIRST AMENDED COMPLAINT but the maliciously altered my ORIGINAL
WRONGFUL TERMINATION COMPLAINT by my former attorney DOUGLAS STEIN
guided by the Porter Scott’s Attorney MICHAEL POTT . Altered FAC decimated my
original December 4, 2014 wrongful termination complaint and it caused that that the
complaint became worthless piece of paper .

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3) NOTICE OF FILING PARTY: On September 10, 2014, Court Clerk ERICA
MEDINA rejected Stein’s defective FAC deliberately submitted without Leave of Court as
an SAC in conspiracy with Defendants’ attorney MICHAEL POTT from Porter Scott to be
redirected to Sacramento County Superior Court Judge DAVID I BROWN and to be filed
by DOUGLAS STEIN and MICHAEL POTT by Ex Parte stipulated application .
4) EX PARTE APPLICATION FOR LEAVE TO FILE FAC as SECOND AMENDED
COMPLAINT (SAC) BY STIPULATION & ORDER THERON. This application was
approved by Judge DAVID BROWN, from Department 53, on September 22, 2014.
DOUGLAS STEIN Judge DAVID BROWN were friends for 20 years and Porter Scott
attorneys used Stein’s grave financial situation , his drugs addiction and his friendship with
Judge DAVID I BROWN to end remove me from to end my lawsuit in December 2014.

The above four items were listed in the January 31, 2022 Appellant’s Notice Designating
Record on Appeal as item No. 8-1 were crucial for the Appeal . It show a difference
between my deliberately and with malice altered original wrongful termination complaint
by my drugs addicted attorney DOUGLAS STEIN and Porter Scott attorney MICHAEL
POTT and should included in the Original Clerk Transcript on Appeal as VOLUME NO.
1, not as the CLERK’s SUPPLEMENTAL TRANSCRIPT (CST) ON APPEAL.
(EXHIBIT #64 on flash drive and DVD)
The CST should be filed in 3DCA in April 2022 not at the end of June 2022 one month
after the 3DCA Presiding Justice RAYE VANCE was removed from the 3DCA by
politically motivated witch hunt orchestrated by the CJP Director and Chief Counsel
GREGORY DRESSER .

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After 3 DCA Presiding Justice VANCE RAYE was removed by CJP Director GREGORY
DRESSER, 3DCA Justice RONALD ROBIE became 3DCA’s Acting Administrative
Presiding Justice (P.J.), Justice ROBIE attached himself to my appeal case, C095488, in
July 2022. This raised my suspicion that Justice ROBIE has a personal interest in my
case. He was on the panel of 3DCA justices who decided the anti-SLAPP motion appeal
that resulted in the totally nonsense opinion dated October 10, 2017 in Waszczuk v.
Regents of Univ. of Cal., No. C079524 (Cal. Ct. App. Oct. 10, 2017). This anti-SLAPP
motion opinion, which never should have been issued, was the result of interference by
former State Bar Interim Chief Trial Counsel GREGORY DRESSER and his deputies,
LAURA HUGGINS and ROBIN BRUNE between October 2015 and October 2017.
GREGORY DRESSER’s misconduct took a much more drastic form that included the
removal Judge DAVID I. BROWN from the Sacramento Superior Court, Justice VANCE
RAYE from 3DCA, and the resignation of Supreme Court of California Chief Justice TANI
CANTIL-SAKAUYE shortly after Justice VANCE RAYE was removed from 3DCA, on
June 1, 2022.
A. THE CERTIFICATION AND DECLARATION OF MAILING OF CLERK’s
SUPPLEMENTAL TRANSCRIPT (CST) ON APPEAL SIGNED BY KEVIN
MICHAUD.

Upon closer examination of the CST received on July 13, 2022, I noticed that the CST was
certified on July 6, 2022 by Sacramento County Superior Court Appellate Department Court
Clerk KEVIN MICHAUD, the day after I submitted my Court Department the Notice of
Omission

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The Declaration of Mailing signed by KEVIN MICHAUD was originally dated July 7,
2022, but this was altered in pen and changed to July 11, 2022(EXHIBIT #65 on flash
drive and DVD)

The CST was filed by the 3DCA Clerk on July 22, 2022, 16 days after the CST was
certified, on July 6, 2022. The Sacramento County Superior Court Building is located 1 mile
from the 3DCA Court building. The process on appeal was, again, deliberately delayed for
at least another 14 days by the Court staff.

The certification and Declaration of Mailing dates basically shows that Sacramento
County Superior Court Appellate Department Clerk KEVIN MICHAUD had the CST
prepared a long time before he received my Notice of Omission most likely in April 2022 .
However, KEVIN MICHAUD by conspiring with Porter Scott attorneys and 3DCA staff
they meddled unlawfully and with malice interfered in the appeal process and put delivery
of the completed CT on hold for more than 60 days until 3DCA Presiding Justice VANCE
RAYE was removed from DCA due to politically motivated witch hunt .

The Sacramento Superior Court Deputy Clerk from the Appeal Unit KEVIN
MICHAUND in his July 11, 2022 Declaration, stated:

As to the minor type-o 's on the cover pages of the Original Clerks
Transcript; Cover pages have been supplied to swap out for all 13
volumes. Nothing was omitted.

I did not care to receive CT a new cover pages with Judge CHRISTOPHER KRUEGER’s
and Porter Scott attorneys LINDSAY GOULDING . I cared that 3DCA staff which

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handled my appeal would recognize that the former Superior Court Judge DAVID I.
BROWN and former Porter Scott attorney DOUGLAS ROPEL were not responsible for this
appeal. I cared that Judge BROWN and former Porter Scott attorney DOUGLAS ROPEL
had nothing do with the LINDSAY GOULDING’s and her collaborators criminal activities
in the court . The GOULDING’s and her collaborators April -July 2021 assault aimed at my
70 years old wife and the filed by her fraudulent and totally unlawful MSA/MSJ lead to
travesty of justice resulted in the court judgment against me signed on October 28, 2021 by
compromised Judge CHRISTOPHER KRUEGER who was most likely bribed or black-
mailed by the Porter Scott attorneys .

These “ were not “minor type-o’s on the cover pages.”. This was an deliberate
attempt to remove JUDGE CHRISTOPHER KRUEGER’S from the appeal proceeding and
blame entirely his judicial misconduct the JUDGE DAVID I BROWN who was forced to
quit his job in Sacramento Superior Court in December 2020 and the former Porter Scott’s
attorney DOUGLAS ROPEL who quit Porter Scott in March 2016 and since then is working
for Littler Mendelson

The above-listed documents were not included in the original CLERK’S


TRANSCRIPT ON APPEAL, which was certified on April 22, 2002. They should have
been provided to me and 3DCA as Volume No. 1 of the CLERK’S TRANSCRIPT ON
APPEAL, not as the CLERK’S SUPPLEMENTAL TRANSCRIPT ON APPEAL. In that
case, I would have had to file a Petition in the Supreme Court, so that only Volume No.1
would have been transmitted to the Supreme Court. In 2018, I did not know that only
Volume No. 1 was subject to transmittal to the Supreme Court if a Petition for Review is
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filed on the Decision of Appellate District Court. I, in March 2018, asked 3DCA
CLERK ANITA KENNER why only one volume of the Clerk’s Transcript on Appeal
was submitted to the Supreme Court (SLAPP Motion Appeal 3DCA Case No. C079524).
Ms. Kenner responded to my inquiry with a letter dated March 20, 2018, stating: (EXHIBIT #66 on
flash drive and DVD)

It is standard procedure for this court to TRANSMIT ONLY THE


FIRST VOLUME of a record to the Supreme Court when a Petition
for Review has been filed

From what was sent to the State Supreme Court, the Supreme Court reviewers would be not
able learn how my now former drug-addicted attorney, DOUGLAS STEIN, worked in
conspiracy with Porter Scott attorney MICHAEL POTT to maliciously alter my original
wrongful termination complaint in June 2014. They went on to collude with one with another
in September 2014 and December 2014 and dragged Judge DAVID I. BROWN into their
dirty game against me to get Judge BROWN’S approval of the unlawfully filed and altered
complaint as a Second Amended Complaint (SAC). DOUGLAS STEIN filed the altered
complaint as an SAC on September 30, 2014 while working with a suspended attorney’s
license; thus, no one court order or judgment issued in the favor of the Defendants in my
wrongful termination lawsuit after September 30, 2014 should be considered valid or
legitimate by any court.

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G. JULY 20, 2022 SECOND NOTICE OF OMISSION RE: DESIGNATED
RECORD ON APPEAL- CAL. RULES OF COURT- RULE 8.155 (B)(1)

On July 20, 2022, I submitted to the Sacramento County Superior Court a Second Notice of Omission: Re:
Designated Record on Appeal (EXHIBIT #67 on flash drive and DVD), which was filed on July 26, 2022

In my Second Notice of Omission, I requested, among other things, that:

1) The Sacramento County Superior Court Appeal Unit, without further delay, issue a
new Notice of Filing of Designation/Notice to Reporters for Court Reporter Valerie Haley,
who had already transcribed the September 1, 2021 Court Hearing presided over by Judge
CHRISTOPHER E. KRUEGER (not Judge DAVID I. BROWN) and the Defendants’
attorney from the Porter Scott law firm, THOMAS L. RIORDAN (not DOUGLAS ROPEL
or LINDSAY GOULDING). The new Notice of Filling of Designation/Notice to Reporters
should resolve the problem with the Court Reporter.
2) I pointed out that Volume 8 is completely missing, or has been deliberately
omitted, in the Chronological and Alphabetical Index for the 13-volume Clerk Transcript on
Appeal and must be corrected In response to my Second Notice of Commission, the
Sacramento County Superior Court Appellate Department Clerk KEVIN MICHAUD, in a
created by him and others CIRCUS OF DECEPTION AND DELAY, submitted to 3DCA
another meaningless declaration. Following MICHAUD’s Declaration, 3DCA staff tried to
run me in circles. The 3DCA staff responded to my Second Notice of Commission with the
Court Order dated August 11, 2022 and stamped by 3DCA Acting Administrative
Presiding Justice, RONALD B. ROBIE, stating (EXHIBIT #68 on flash drive and
DVD)
BY THE COURT:

Appellant's Second Notice of Omission in the Record on Appeal" is


treated as a motion to correct the record, and in light of the subsequent
filing of the supplemental record on appeal, the motion is denied. If there
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are further corrections sought, appellant may file a motion in this court
addressing the specific corrections he seeks to have this court direct the
trial court to correct.

ROBIE, Acting P.J.

I. MOTION TO AUGMENT RECORD


3) On September 23, 2022, I filed a Motion to Augment Record on Appeal, which was
basically a redundant repetition of my two Notices of Omission, which were submitted to
Sacramento County Superior Court with no known results I was well aware that I was being
played by the corrupt staff from two Courts. This game has been going on for almost nine
years, but I am doing my best to beat the odds as a self-represented litigant for whom English
is a second language. (EXHIBIT #69 on flash drive and DVD)

On September 28, 2022, the 3DCA Clerk filed my Motion to Augment Record on
Appeal after five days’ delay.

J. COURT REPORTER TRANSCRIPT (CRT)

On September 27, 2022, four days after I submitted to 3DCA my motion to augment
record on appeal, I received from Court Reporter VALERIE HALEY an electronic version
of the COURT REPORTER TRANSCRIPT (CRT) from the September 1, 2021 Court
Hearing with Judge CHRISTOPHER KRUEGER from Department 53 The CRT was
provided to me via YesLaw, which shows that the CRT from the September 1, 2021 Court
hearing was uploaded to YesLaw by VALERIE HALEY on March 21, 2022, but never
provided to me or transmitted to 3DCA by Sacramento County Superior Court Clerk
Appeal Department Unit Clerk KEVIN MICHAUD.
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I was expecting that the CRT, which was sent to me on September 27, 2022 would be
certified and transmitted to 3DCA and that I could use it for my APPELLANT OPENING
BRIEF (AOB), which was due to be filed on October 10, 2022.
For the above reason, on October 3, 2022, I submitted to 3DCA an Application for 30
days’ extension to file my AOB with a new due date of November 10, 2022
On October 10, 2022, I was struggling to finish my AOB and to send it 3DCA, waiting until
the last minute with hope that 3DCA would provide me the 30 days’ extension of time
because of the 3DCA clerk’s conflicting and unclear statement in the case docket, which did
not state whether my motion for an extension of time was filed, granted or not granted, or
rejected. I did not take any chances and submitted my AOB to 3DCA very early in the
morning on October 11, 2022, at 4:36 A.M. The AOB was written based on an incomplete
record on appeal and not knowing whether the extension of time to file the AOB had been
granted or not.

K. OCTOBER 7, 2022 KAREN M. BRAY’S FROM HORVITZ & LEVY LLP


OPPOSITION TO MY SEPTEMBER 23, 2022 MOTION TO AUGMENT
THE RECORD ON APPEAL.

4) On October 10, 2022, instead of receiving the extension of time to file the AOB, I
received a 3DCA e-mail notification that my AOB was due. I looked at the case docket and
noticed that, on October 7, 2022, the UC Regents attorney KAREN BRAY filed an
opposition to the my (Plaintiff’s) September 23, 2022 motion to augment the record on
appeal.Attorney KAREN BRAY submitted her opposition via TrueFiling on October 7,
2022 at 12:53 P.M., and the opposition was filed on the same day by 3DCA Deputy Clerk T.
EYSTER (EXHIBIT #70 on flash drive and DVD)

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. However, the KAREN BRAY’s opposition was not served to me for five days, arriving on
October 11, 2022. On the same day, I asked the KAREN BRAY, via e-mail why she had not
served their opposition to my motion for five days after their opposition was filed. On that
same day, I received a response from KAREN BRAY , stating:

Mr. Waszczuk,

Attached is a copy of the opposition to motion to augment that we filed


on Friday. We attempted to serve it upon you through TrueFiling using
your registered email address, but just noticed that there was a server
error message, which we have copied below. Our understanding is that
other filings have been served upon you at this email address, so we
aren’t sure why service failed in this instance.
In her response, KAREN BRAY stated that she “just noticed” there was a server error. I
responded to her that there was nothing wrong with my e-mail. I have never had a
problem submitting my documents via TrueFiling. If there was something wrong with my
e-mail, the TrueFiling Server operator would have notify me instantly that I was blocked.
By working for the UCDMC as an associate development engineer, I have backed up
servers for entire hospitals, and I do not believe that TrueFiling’s server for the entire
California Court System is less critical to protect from viruses or spam attacks than the
UCDMC hospital server, or that its and system is less sophisticated than the UCDMC
computer system was 10 years ago. Instead, I think that my documents were not being
processed by the clerks and filed for many days after being submitted via TrueFiling. I
notified the TrueFiling Service on October 11, 2022 of the problem and received a
response that there should not be any further problems. Supposedly, some spam had been

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attached to my registered e-mail, which kept me from being served for five days.
However, I should also have received text messages on my phone, 209-687-1180, as
usual, which documents that something was filed, but no such messages were sent.
Furthermore, I noticed in the case’s Register of Action (ROA) on October 11, 2022,
the KAREN BRAY filed a Supplemental Proof of Service five days after the opposition was
filed. I never received from the KAREN BRAY a copy of this supplemental proof of
service.

F. OCTOBER 13, 2022 MY REPLY TO KAREN BRAY’s OPPOSITION TO


MY MOTION FOR THE RECORD ON APPEAL AUGMENTATION AND
CORRECTION.

Being, again, manipulated and prejudiced against by the UC Regents attorneys from
Porter Scott and Horvitz & Levy and the 3DCA Clerks, on October 13, 2022, I submitted to
3DCA via TrueFiling the Reply to the Defendants’ Opposition to Plaintiff’s Motion for the
Record on Appeal Augmentation and Correction (EXHIBIT #71 on flash drive and DVD)
The reply was more of a complaint than a reply to opposition due to being subject to gross
prejudice by the Sacramento County Superior Court Appellate Department, which
deliberately delayed the processing of my appeal in a blunt approval of wrongdoing by the
3DCA staff.
On the same day, October 13, 2022, I submitted my reply to the Defendants’ opposition
to my motion, the 3DCA granted me an extension of time to file my AOB, which I had
already submitted to 3DCA on October 11, 2022 via TrueFiling. What nonsense. The

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extension was granted without granting or denying my motion to augment and correct record
on appeal (another bit of nonsense).
I examined the granted Application for Extension of Time and found that the order was
stamped with 3DCA’s Acting Presiding Justice RONALD ROBIE’S name, but the order
was not dated. It is unknown whether the extension was granted before October 10, 2022 or
three days after I submitted my AOB
G. THE APPELLANT’S OPENING BRIEF

On October 19, 2022, I submitted a corrected AOB via TrueFiling with a cover letter
addressed to 3DCA Clerk/Executive Officer ANDREA K. WALLIN-ROHMANN.
(EXHIBIT #72 on flash drive and DVD)
I noticed that 3DCA, by filing my AOB Brief, did not make an entry in the case ROA
showing when the Respondent Brief is due now after my AOB was filed.
H. MARCH 10, 2023 MOTION FOR SANCTIONS AGAINST UC REGENTS
ATTORNEY’S KAREN BRAY , THOMAS WATSON AND LINDSAY
GOULDING DUE TO UNTIMELY FILED RESPONDENT BRIEF(RB) –
3DCA CASE C095488

On March 1, 2023, at 2:10 p.m., I sent a letter to UC Regents attorney KAREN BRAY r
about the RB that was due to be filed on February 16, 2023, after an extra 30 days’
extension had been granted above the 60-day extension she had already been granted.
KAREN BRAY used beside other reasons her mother’s death as an excuse to obtain
the extra 30 days extension to delay the process of appeal.

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After sent my letter to KAREN BRAY, on March 1, 2023 at 2:10 p.m., she replied at
3:52 p.m. by sending me a copy of the RB. (EXHIBIT #73 on flash drive and DVD)
which was merely a redacted LINDSAY GOULDING’s fraudulent MSA/MSJ and a
racially motivated piece of slander aimed at me which most likely was authored by the
Porter Scott attorneys, LINDSAY GOULDING, who ambushed my wife in April–July
2021, and stole $22,284 from her on July 2, 2021 in conspiracy and collaboration with
Sacramento County Superior Court Clerk from Dept 43 and Judge THADD BLIZARD .
On March 10, 2023 I filed in 3DCA Motion to Impose Sanctions against Defendant and
Defendants’ Attorneys Karen M. Bray, H. Thomas Watson, and Lindsay A. Goulding
due to Untimely Filed Respondent Brief and Admonish the Defendants’ Attorneys of
Record. Points and Authorities and Declaration in Support. California Rules of Court,
Rule 8.276
(EXHIBIT #74 on flash drive and DVD)
On March 28, 2023 the motion for sanctions was denied by the 3DCA Acting P.J
RONALD ROBIE with words : (EXHIBIT #75 on flash drive and DVD)

The filing of respondent's opposition to appellant's motion for sanctions


is ordered stricken pursuant to California Rules of Court, rule 8.276(d).
The clerk of this court is directed to strike the March 13, 2023, filing of
respondent's opposition.

Appellant's motion for sanctions is denied.

On March 14, 2023 in my inquiry addressed to the CJP Secretary to Trial Counsel

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MICHELE KEM which was titled “IRREPARABLE DAMAGE ’TO MY
LITIGATION FROM 2014–2023 AGAINST THE REGENTS OF THE UNIVERSITY
OF CALIFORNIA (UC REGENTS), THE CALIFORNIA UNEMPLOYMENT
INSURANCE APPEAL BOARD (CUIAB), AND TO MY LIFE AND WELLBEING
AT RETIREMENT AGE, CAUSED BY WELLS FARGO BANK’S UNFAIR
BUSINESS PRACTICES AND MISCONDUCT “ I wrote about Levi & Horowitz
attorney KAREN BRAY late RB and her misconduct . (EXHIBIT #76 on flash drive
and DVD)

Also with this inquiry, I am enclosing a copy of my March 10, 2023


Appellant’s Motion to Impose Sanctions against Defendants the Regents
of the University of California and Defendants’ Attorneys Karen M.
Bray, H. Thomas Watson, and Lindsay A. Goulding, due to an Untimely
Filed Respondent Brief (RB) and Admonish the Defendants’ Attorneys
of Record per Points and Authorities and Declaration in Support,
California Rules of Court, Rule 8.276

As I pointed out in my motion, the UC Regents had the full right to elect
not to file an RB; however, in this appeal and case, the regents’ attorneys
elected to use dilatory tactics to drag out the case in trial court and in this
appeal for as long as possible, exhausting all of my resources, which are
limited to my $1800 Social Security pension, to pursue my desire for
justice, or waiting for my death after almost 10 years of bizarre litigation
in California’s three Courts. Karen Bray, without any remorse or shame
in her dilatory tactics, used own mother’s death to deceive me and the
court to obtain an extension of time to file beyond the statutory extension
allowed for an Respondent Brief (RB) ) (Rule 8.212(b)), which was due
for filing on January 16, 2023.

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In this matter, I am respectfully requesting that the CJP intervene with
3DCA to convince the court clerk to serve me a stamped and filed copy
of the RB. Two weeks have passed and clerk has not served me via
TrueFiling the late RB supposedly filed on March 1, 2023. I must file
my Appellant RB by March 20, 2023 and I do not even know whether
the brief Bray supposedly submitted is the same one I received from her
on March 1, 2023 via e-mail and hard copy four days later. I should have
been notified by the 3DCA clerk on March 1, 2023 that RB had been
filed. This is how things happened last year with other documents
submitted to 3DCA and this year with the Defendants’ application for an
extension of time to file the RB. Bray’s application for an extension of
time was filed on January 9, 2023, and I was served the filed copy by the
clerk on January 23, 2023. I would appreciate it if the CJP would
intervene with the 3DCA clerk to file my Motion for Sanctions, which I
submitted on March 10, 2023. It is sickening what I have been
experiencing in Sacramento’s two courts from the appointed judges and
justices for almost 10 years.
After several inquiries with the CJP in 2022 and 2023 addressed to MICHELLE KEM and a
lack of any response, I determined that someone at the CJP had instructed her not to respond
to any of my inquires. I came to the conclusion that this is a similar situation as with my
complaint in 2014–2017 against my former attorney DOUGLAS STEIN with the OCTC and
the disappearance of it and OCTC Investigator AMANDA GORMLEY in September 2015.
On March 14, 2023, I decided to send my inquiry, along with detailed information about the
2014 Wells Fargo account and Stein’s crimes related to this account, to MICHELLE KEM
and to copy other CJP members in the correspondence.

On March 15, 2023, CJP Director GREGORY DRESSER reacted or overreacted to


control the damages with a reply to my March 14, 2023 letter. Dresser did not react
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because I sent this information to other CJP members. He reacted because he is corrupt
and was got caught off guard when he was reminded what had been done to me in
2015–2017 being employed by State Bar OCTC and thereafter the CJP (EXHIBIT #77
on flash drive and DVD)

On March 22, 2023 I filed my Appellant Reply Brief (ARB) in which I concluded my
wrongful termination case : (EXHIBIT #78) on flash drive and DVD)

CONCLUSION

In this, there are no winners. Waszczuk, due to The Regents’ reckless,


unlawful, and merciless witch hunts, which resulted in the termination of
his employment on December 5 , 2012 at his retirement age, has suffered
enormous losses exceeding $1 million in wages and benefits and the
devastation of his life. By contrast, The Regents, since the second witch
hunt action aimed at Waszczuk, from March 2011–December 2012, have
lost approximately $100 million in tax-free revenue by not selling to
SMUD surplus power from the UC Davis Medical Center’s cogeneration
plant, after being advised by some unknown person that Waszczuk
would blow the whistle on their shady power-generation business, a
topic about which Waszczuk did not care at all or have a clue concerning
in 2011–2012 when the witch hunt began.

As set forth above and in light of the presented reply to the concurrently
filed RB by The Regents, Waszczuk is requesting that the Court of
Appeal, Third Appellate District reverse the trial court Judgment dated
October 28, 2021, which granted The Regents’ MSJ/MSA and direct
Waszczuk’s lawsuit back to Department 53 with a new judge in charge
of the Department after HON. MESIWALA was elevated to the
Associate Justice in 3DCA
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Mentioned in my ARB conclusion the Sacramento County Superior Court Judge SHAMA
HAKIM MESIWALA replaced on January 2, 2021 Judge DAVID I. BROWN in Department
53. Judge BROWN was forced to resign by CJP Director GREGORY DRESSER . Judge
MESIWALA had been disqualified, pursuant to CCP Section 170.6. in my wrongful
termination case on July 2, 2021.

On July 10, 2023 3DCA Justice LAURIE EARL was unanimously confirmed and
sworn in today as Presiding Justice of the Third District Court of Appeal.
Justice LAURIE EARL, of Sacramento County, served as a judge on the Sacramento
Superior Court bench from 2005 to 2021. She was elevated to the Third District Court of
Appeal in January 2022 by Gov. Gavin Newsom five months before 3DCA Presiding
Justice RAYE VANCE was chased out from 3DCA by CJP Director GREGORY
DRESSER . After Judge LAURIE EARL was elevated to 3DCA her son wrote a text
message to family and friends

, "January 6, 2021 rioters broke through the glass doors to gain access
to our nation's capital. January 6, 2022 Laurie M. Earl broke through the
glass ceiling to gain access to the California Court of Appeal," recounted
Earl. "I accept my role in history as being first and am honored to claim
January 6 not as that day but as my day."

However, after the 3DCA Presiding Justice RAYE VANCE was removed 3DCA on June 1,
2022 than the Justice LAURIE EARL’s sworn ceremony for the 3DCA Presiding Justice
post had been placed in abeyance for one year because Mayor of City of Sacramento ,
(former California Senate President pro tempore applied ) applied for this position in 3DCA .
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I. APPELLANT’S MOTION TO CONSIDER NEW EVIDENCE ON APPEAL IN
THE 3DCA CASE Waszczuk v. The Regents of the University of California, Case
No. C095488, SUBMITTED, FILED, AND DENIED ON JULY 20, 2023 BY
3DCA ACTING PRESIDING JUSTICE RONALD ROBIE AND JUSTICE
LOUIS MAURO.

https://www.scribd.com/document/665922099/07-20-2023-Motion-for-New-Evidence-on-
Appeal-Waszczuk-v-The-Regents-of-the-University-of-California-3DCA-Case-No-
C095488
My motion for new evidence to consider on appeal included, but was not limited to,
Wells Fargo Bank documents and statements that precisely show how my former attorney
was stealing my money without any desire to represent me. (EXHIBIT #79) on flash
drive and DVD)

In September -December 2022 I received unexpected and surprising detailed information


from Wells Fargo Bank about circumstances how my former attorney in June -December
2014 stole my $ 20, 000 given to him to represent me in wrongful termination lawsuit against
the UC Regenst .
The Wells Fargo Bank Representative MISTY LEMAY’S specific disclosure about Stein’s
crime led me to submit a Public Record Acts Request with the State of California’s
Controller’s Office, to obtain documents related to the short term disability (SDI) insurance
benefits denied to me in November 2011 by Liberty Assurance Company of Boston (Liberty),
in conspiracy with The Regents’ attorneys. These benefits resurfaced as unclaimed property
in the amount of $4,546.08, along with another amount of $272,037.51 in the State
Controller’s Office in December 2018. On November 26, 2022, I submitted an inquiry to the
California Insurance Commissioner’s office requesting copies of the 2011–2012 State of

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California Department of Insurance investigation (claim csb-6707505) into Liberty’s actions
as they related to my former attorney, Stein, between August and October 2014. At that time,
he was working with a suspended attorney’s license, filed a defective SAC, and cut a deal
with Liberty regarding my denied SDI benefits. He did all of this without my authorization.
I raised the SDI benefits issue before the trial Court, appellate Courts, and State Bar; thus, the
court should accept the additional evidence to have a full picture of what happened in 2014–
2015, and as a means of investigating why the two previous appeals and this appeal are
needed.
J. THE JULY 21, 2023 ORAL ARGUMENTS IN THE CASE Waszczuk v. The
Regents of the University of California, Case No. C095488

The Oral Arguments for a Motion for Summary Judgment, which were held almost 10
years after this case was filed in December 2013, speak for itself that something is
terribly wrong with the handling of this case by the trial Court and 3DCA. The argument
hearing was held before the three-justice panel of RONALD B. ROBIE, LOUIS
MAURO, and JONATHAN K. RENNER. I had expected Justice RONALD ROBIE to
recuse himself from this case, as he coauthored the October 10, 2017 fraudulent
unpublished opinion in the anti-SLAPP motion Waszczuk v. Regents of Univ. of Cal., No.
C079524 (Cal. Ct. App. Oct. 10, 2017), which glorified my former attorney Stein and his
collaborators, despite their criminal and professional misconduct.

I requested the oral arguments to avoid any misunderstanding that I was expecting the
3DCA Court to remand the case back to Trial Court. I wanted to be allowed to amend the

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defective SAC filed by Stein on September 30, 2014 in conspiracy with The Regents
attorney MICHAEL POTT .
K. THE JULY 28, 2023 3DCA UNPUBLISHED OPINION IN Waszczuk v. Regents
of the Univ. of Cal., No. C095488 (Cal. Ct. App. July 28, 2023), APPEAL OF THE
JUDGMENT BY SUPERIOR COURT OF CALIFORNIA COUNTY OF
SACRAMENTOJUDGE CHRISTOPHER E. KRUEGER, AND DEFENDANT’S
MOTION FOR SUMMARY JUDGMENT

Seven days after the oral arguments led by Acting Administrative Presiding JUSTICE
RONALD B. ROBIE, 3DCA Justice LOUIS MAURO joined with Justice JONATHAN
K. RENNER to deliver an unpublished and senseless opinion designed to harm me further
and to condone additional criminal conduct by my former attorney, DOUGLAS STEIN;
MICHAEL POTT; DAVID BURKETT; DANIEL BARDZELL; DEREK HAYNES;
LINDSAY GOULDING; THOMAS RIORDAN; KAREN BRAY; and THOMAS WATSON
and their collaborators from Sacramento’s two courts (see
https://casetext.com/case/waszczuk-v-regents-of-the-univ-of-cal-1).
Justice LOUIS MAURO was the justice who delivered the fraudulent July 28, 2023
opinion in Waszczuk v. Regents of the Univ. of Cal., No. C095488, which never should
have been issued (EXHIBIT #80) on flash drive and DVD).
It was no coincidence that 3DCA Acting Presiding Justice RONALD ROBIE teamed up
with Associate Justices LOUIS R. MAURO and JONATHAN K. RENNER to legitimize
the Porter Scott attorneys’ conspiracy in 2021 with Sacramento County Superior Court
judges and staff from Departments 43, 53, & 54, which resulted in stealing $22,284 from
my wife and attempting to rob her of her life savings and end my litigation against the

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UC Regents by September 1, 2021 via a fraudulent and unlawful court order issued by
Judge CHRISTOPHER KRUEGER. This order granted The Regents’ MSA/MSJ when it
should have been rejected for fraud. Judge CHRISTOPHER KRUEGER is an old friend
3DCA Associate Justices LOUIS MAURO, JONATAHAN RENNER, STACY
BOULWARE EURIE, and former 3DCA Associate Justice ANDREA LYNN HOCH
who, on January 27, 2022, as an Acting P.J., ruled that the case was not eligible for
mediation (EXHIBIT #81 on flash drive and DVD).

Before his appointment to the bench, Judge CHRISTOPHER KRUEGER was employed
in the California Attorney General’s office (under AGs BILL LOCKYER and EDMUND
G. BROWN, JR), alongside LOUIS MAURO, JONATAHAN RENNER, STACY
BOULWARE EURIE, and ANDREA LYNN HOCH.
See their presence in the following litigation involving the California AG’s Office:

Esther v. City of Los Angeles, 158 Cal.App.4th 1093 (Cal. Ct. App. 2008)

Bill Lockyer and Edmund G. Brown, Jr., Attorneys General, Louis R. Mauro and Stacy
Boulware Eurie, Assistant Attorneys General, Christopher E. Krueger, Jonathan K.
Renner and Hiren Patel, Deputy Attorneys General, for Defendants and Respondents
Attorney General of California and California Department of Justice

Cruz v. Superior Court, 120 Cal.App.4th 175 (Cal. Ct. App. 2004)

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Bill Lockyer, Attorney General, Manuel M. Medeiros, State Solicitor General, Andrea
Lynn Hoch, Chief Assistant Attorney General, Louis R. Mauro, Assistant Attorney
General, Kenneth R. Williams, Michelle Mitchell Lopez and Douglas J. Woods, Deputy
Attorneys General

Consulting Engineers & Land Surveyors of California, Inc. v. Professional Engineers


in California Government, 42 Cal.4th 578 (Cal. 2007)

Bill Lockyer and Edmund G. Brown, Jr., Attorneys General, James M. Humes, Chief
Deputy Attorney General, Louis R, Mauro and Stacy Boulware Eurie, Assistant
Attorneys General, Christopher E. Krueger, Catherine A. Van Aken, Vickie Pochelle
Whitney and Leslie R. Lopez, Deputy Attorneys General, for California Department of
Transportation as Amicus Curiae on behalf of Plaintiffs and Respondents

It was no coincidence that Judge CHRISTOPHER KRUEGER, on September 1, 2022,


cut short a court hearing where I was ready to present exhibits about the events of May
11–31, 2012 related to my return to work on May 31, 2012, after a forced 10-month
absence. My return had been planned, and I had been ordered in a letter from my
department manager to report to work on May 31, 2012.

On May 31, 2012, The Regents finalized a power purchase agreement (PPA) with
Sacramento Municipal Utility District (SMUD) to resume the sale of surplus power from
the UCDMC’s 27-MW cogeneration, which had ceased after The Regents signed a
Settlement Agreement with me on January 30, 2009 (EXHIBIT #82 on flash drive and
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DVD, see https://www.scribd.com/document/622460131/2012-UCDMC-27-MW-
Cogenaration-Plant-Power-Purchase-Agreement-with-SMUD). This cost them, or the co-
owners of the plant, millions of tax-free dollars. Just before Judge KRUEGER cut me off
and ended the hearing, I had in my hand a copy of the PPA, which I wanted to discuss in
relation to the termination of my employment. Most likely, if the hearing had been taking
place in a courtroom, perhaps it would have been a different story, but via Zoom and
visible on YouTube, it was inconvenient for Judge KRUEGER to listen to my testimony
about violations of the university’s tax-exempt status, millions of dollars tax evasion, and
fraud due to violation of IRC 501(c)(3). Perhaps Judge KRUEGER, who was employed
by the Attorney General’s office, was perfectly aware of The Regents’ crimes and that
was why attorneys DAVID BURKETT and DANIEL BARDZELL employed him and
Judge JENIFFER ROCKWELL in their first attempt, in October 2018, to end my lawsuit
by termination sanctions and to rob my wife of her life savings.
Perhaps judges CHRISTOPHER KRUEGER, JENIFFER ROCKWELL, and 3DCA justices
LOUIS MAURO and ANDREA LYNN HOCH, and Justice JONATHAN RENNER were
beneficiaries of the illegal power sale from the UCDMC from 1998 through 2009, which
resulted in millions of dollars of tax evasion and fraud. Had the Porter Scott attorneys learned
of their activities and blackmailed them to make them end my lawsuit against the UC
Regents?

F. AUGUST 12, 2023 APPELLANT’S PETITION FOR REHEARING AND


AUGUST 14, 2023 APPELLANT’S MOTION/REQUEST FOR JUDICIAL
NOTICE IN SUPPORT OF THE APPELLANT’S PETITION FOR
REHEARING.
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On August 12, 2023, I submitted via TrueFiling the Appellant Petition for Rehearing
showing my total disagreement with the unpublished opinion in Waszczuk v. Regents of the
Univ. of Cal., No. C095488 (Cal. Ct. App. July 28, 2023)

https://www.scribd.com/document/665926013/08-11-2023-Appellant-Petition-for-Rehearing-
Waszczuk-v-The-Regents-of-the-University-of-California-3DCA-Case-No-C95488

Two days later, I submitted an Appellant Request for Judicial Notice in support of the
Petition for Rehearing.

https://www.scribd.com/document/665924019/08-14-2023-Appellant-s-Request-for-Judicial-
Notice-Waszczuk-v-The-Regents-of-The-University-of-California-3DCA-Case-No-C095488

Excerpt From My Appellant’s Petition for Rehearing

In my Appellant’s Petition for Rehearing, which was backed up by the Motion and
Request for Judicial Notice and included very important evidence, I wrote:

The opinion issued and delivered on July 28, 2023 by three 3DCA
justices, former Acting Presiding Justice Hon. Ronald B. Robie, Hon.
Louis Mauro, & Hon. Jonathan K. Renner, was done in bad faith and
spirit. This appeal, and the two previous appeals captioned above, never
should have been needed, due to the crimes involved and judicial
misconduct; thus, these opinions should be deemed null and void.

Waszczuk respectfully requests that this Court, on its own motion,


recall the remittiturs and nullify the unpublished opinions Waszczuk

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v. Regents of Univ. of Cal., No. C079524 (Cal. Ct. App. Oct. 10, 2017)
https://casetext.com/case/waszczuk-v-regents-of-the-univ-of-cal and

Waszczuk v. Cal. Unemployment Ins. Appeals Bd., No. C079254 (Cal.


Ct. App. Dec. 27, 2018) https://casetext.com/case/waszczuk-v-cal-
unemployment-ins-appeals-bd. On remand, any ruling issued in these
two cases by Sacramento Superior Court Judges SHELLEYANNE
CHANG

It is no secret that Waszczuk submitted multiple inquiries to the


State of California’s Commission on Judicial Performance (CJP)
Secretary to Trial Counsel MICHELLE KEM (Kem) asking for
intervention in Sacramento County Superior Court and 3DCA to
invalidate the corrupted court proceedings in his wrongful
termination and unemployment benefits insurance cases. This
happened after The Regents’ attorney, Goulding, in a desperate move,
ambushed Waszczuk’s wife in Sacramento County Superior Court Dept.
43 on July 2, 2021, stealing $22,284 from her savings in an
attempt to break into her bank and 401(K) plan accounts and
frame her for criminal prosecution, in hopes of convincing
Waszczuk to drop his litigation against The Regents.
On August 21, 2023 I submitted to the newly sworn 3DCA Administrative Presiding
Justice LAURIE M. EARL “Request for Intervention “ in this appeal which was
rigged by Porters Scott’s attorneys and their collaborators from two Sacramento courts.
On August 24,2023 my petition for rehearing and request for judicial notice in support
thereof were denied by 3DCA Justices RONALD ROBIE, Acting P.J., (EXHIBIT #83)
on flash drive and DVD) . Normally it should be denied by Justice LOUIS MAURO
who authored and delivered the unpublished opinion of rigged appeal Waszczuk v.
Regents of the Univ. of Cal., No. C095488 (Cal. Ct. App. July 28, 2023)
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On the same day August 24, 2023 my request for intervention in the appeal sent to
Administrative Presiding Justice LAURIE M. EARL was denied as well.

G. PETITION FOR REVIEW SUBMITTED TO CALIFORNIA SUPREME


COURT, Jaroslaw Waszczuk v . The Regents of the University of California,
CASE NO. S281719, 3DCA CASE NO. C095488

On August 29, 2023, I sent a request to 3DCA Clerk/Executive Officer COLETTE M.


BRUGGMAN to transmit the Supplemental Clerk’s Transcript on Appeal and Clerk’s
Transcript Volume 1 to the Supreme Court of California. The inquiry was filed on the
same day (EXHIBIT #84 on flash drive and DVD).
With this 31-page-long inquiry and attachments, I requested that, after my Petition
for Review was submitted to the Supreme Court of California, the 3DCA clerk’s
office must transmit to the Supreme Court the Supplemental Clerk’s Transcript
(Supp. CT), Volume 1 of 1, and the Clerk’s Transcript (CT), Volume 1 of 13,
docketed in 3DCA. Originally, the Supp. CT and part of CT Volume 1 should have
been produced by the trial court’s Appellate Department and transmitted in April
2022 to 3DCA as a CT Volume 1of 13, and it should have contained 300 pages.
As I learned from 3DCA Clerk Anita Kenner’s March 20, 2018 correspondence, it
is standard procedure for 3DCA to transmit only the first volume of a record
to the Supreme Court when a Petition for Review has been filed.
I presented, once again, the events surrounding the RECORD ON APPEAL in this
case. There was no doubt in my mind that the exclusion of the 12/04/13
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COMPLAINT, 06/16/14 FIRST AMENDED COMPLAINT, 09/10/14 NOTICE
TO FILING PARTY, 09/24/14 EX PARTE APPLICATION FOR LEAVE TO
FILE and SECOND AMENDED COMPLAINT BY STIPULATION AND
ORDER THEREON from the original CT Volume 1 of 13 was a premeditated act
of deception and conspiracy among LINDSAY GOULDING, THOMAS
RIORDAN, KAREN BRAY, THOMAS WATSON, and KEVIN MICHAUD to
deceive me and the Supreme Court of California and to obtain a Supreme Court of
California order to deny my Petition for Review if I filed one.

On September 6, 2023, I submitted a Petition for Review to the California Supreme


Court. The petition was filed on the same day and docketed as Jaroslaw Waszczuk v. the
Regents of the University of California, Case No. S281719 (EXHIBIT #85 on flash
drive and DVD).

On September 13, 2023, I received an e-mail from the California Supreme Court Clerk /
Senior Deputy ROBER R. TOY that stated (EXHIBIT #86 on flash drive and DVD):

From: Toy, Robert <Robert.Toy@jud.ca.gov>

Sent: Wednesday, September 13, 2023 10:48 AM

To: jjw1980@live.com

Subject: S281719 - WASZCZUK v. REGENTS OF THE


UNIVERSITY OF CALIFORNIA

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Hello Mr. Waszczuk,

Just wanted to let you know that I received your petition for review hard
copies, and the transcript. We have all the records from the Court of
Appeal when your petition was filed.
Robert R. Toy Senior Deputy
California State Supreme Court
(415) 865-7022

After I received the e-mail from ROBERT TOY, I checked the 3DCA Docket in Case
C095488. On September 13, 2023, it had no, and still has no clerk entry stating that the
record on appeal was sent to the Supreme Court as I requested in my August 28, 2023
inquiry to DCA Clerk/Executive Officer COLETTE M. BRUGGMAN.
Contrary in my 3DCA appeal case Waszczuk v. The Regents of the University of California et
al., Case No. C079524 (anti-SLAPP motion), the docket stated regarding the record on
appeal: “11/20/2017 Record transmitted to Supreme Court. Vol 1.”

On September 28, 2023, I submitted a letter to ROBERT TOY regarding my concerns


about the record supposedly transmitted by 3DCA on September 6, 2023 to the California
Supreme Court, Case C095488 (EXHIBIT #87 on flash drive and DVD).
In that letter, I outlined my concerns about the transmitted record on appeal as follows:

Dear Mr. Toy:

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On August 29, 2023 priors I submitted petition for review , I sent to 3DCA
Clerk/Executive Officer Colette M. Bruggman Inquiry/Request titled
“Request for the 3DCA Clerk’s Office to transmit the Supplemental
Clerk’s Transcript on Appeal Volume 1 of 1 and Clerk’s Transcript
Volume 1 of 13 to the Supreme Court of California in the above-captioned
3DCA Case No. C095488. You received the copy of my inquiry to Ms.
Bruggman thus no need to be attached.
On September 13, 2023 you informed me by email that the Supreme Court
received all the records from the Court of Appeal when my petition was
filed. The Supreme Court Docket in Case No . S281719 that the Court
received the record from 3DCA on September 6, 2023 same day I
filed the petition
In 3DCA docket Case N. The 3DCA Docket has no entry that record
was submitted to the Supreme Court at all I am not sure how the 1
Volume the Clerk Transcript (300 pages ) and Supplemental
Transcript on Appeal (169 pages ) were transmitted from 3DCA to the
Supreme Court on the same day in contrary that the CT from the
Sacramento County Superior Appellate Department to the 3DCA (
one mile away) traveled 68 days after it was certified on April 22,
2022 beside that the record was grossly altered and decimated (
incomplete).
I guess that that 3DCA sent on September 6, 2023 469 pages of the
record in electronic format to the Supreme Court by compressing
469 pages of CT.
If so, I would appreciate it if you forward to me electronically what
exactly Supreme Court received from the 3DCA Clerk office.
Especially, I am concerned whether 3DCA Clerk office sent the CT
Volume 1 of 13 has proper label and whether Supplemental Clerk’s
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Transcript on Appeal Volume 1 of 1 which was most important
record on appeal and which was not deliberately and with malice not
produced with the CT to rig the appeal and tampering with judicial
process .
More precisely decimated, record on appeal with a wrongly labeled CT was
sent to me on June 28, 2022, more than two months after it was certified by
Sacramento County Superior Court Appellate Department Clerk Kevin
Michaud.
I took a closer look at the record and wrongly labeled CT to find that:
After I received on June 28, 2022 the 13 volumes of the CLERK’S
TRANSCRIPT ON APPEAL (CT), I noticed that the CT had the wrong
judge’s name and wrong attorney It said “CLERK'S TRANSCRIPT ON
APPEAL FROM THE JUDGMENT OF THE SUPERIOR COURT OF THE
STATE OF CALIFORNIA IN AND FOR THE COUNTY OF
SACRAMENTO JUDGE DAVID BROWN – ATTORNEY DOUGLAS
ROPEL #300486, 350 UNIVERSITY AVE., STE 200 SACRAMENTO, CA
95825 Attorney Defendant/Respondent,” instead of HON.
CHRISTOPHER E. KRUEGER and Defendant’s Attorneys LINDSAY
GOULDING, who is the Defendants’ Attorney of Record on Appeal, or
THOMAS RIORDAN, who attended the Motion for Summary Judgment
Court Hearing with Judge Krueger via Zoom on September 1, 2021.
On June 28, 2022 , I knew already that Judge David I Brown whose name
appeared on the cover page of the 13 volumes of CT resigned in December
2020 and replaced my Judge Shama Hakim Mesiwala who I
disqualified(C.C.P 170.6)in June 2021 from my case .

However on June 28, 2022 I did not know yet that that the Director and
Chief Counsel of the Commission on Judicial Performance Gregory Paul

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Dresser witch hunted 3DCA Presiding Justice Vance W. Raye and
removed him from 3DCA on June 1, 2022.

This is was a main reason that the decimated and altered record on appeal
(CT ) was sent to me 68 days late because Dresser in misconduct and
malice tempering and meddling with justice communicated his witch
against 3DCA Justice Vance W . Raye with The Regents attorney from
Porter Scott Law firm and Horvitz and Levy and they took care of rest not
deliver the record on appeal o to 3DCA and tom me until after 3DCA
Justice Vance W . Raye will be gone and replaced.
Details in my September 25, 2023 complaint against Gregory Dresser with
State Bar of California Chief Trial Counsel office
https://www.scribd.com/document/673359264/09-25-2023-State-Bar-
Complaint-Against-California-Director-of-Commision-on-Judicial-
Performance-Gregory-Dresser

On September 23, 2022, I filed a Motion to Augment Record on Appeal

By THE 3DCA ORDER DATED NOVEMBER 14, 2022 -RE:


AUGUMENTED RECORD ON APPEAL Acting Presiding Justice Ronald
Robie denied my request to relabel the transcript stating : “Appellant’s
request to relabel the transcript is denied as unnecessary.”
I think it is very necessary for the Supreme Court to know that is Judge
Christopher Krueger is responsible for this appeal not Judge David I
Brown and why .
Thus, why I am requesting to send me information what Supreme Court
received on September 6, 2023 from the 3DCA in regards to Court record
on appeal .

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As I pointed in complaint against Gregeory Dresser , this appeal and
petition never would happened if Judge Brown and Justice Raye would be
not witch hunted by Dresser and they would not be forced to resign

I appreciate your prompt response to my inquiry.

Sincerely ,
________________
Jaroslaw “Jerry “ Waszczuk
Plaintiff & Appellant in Pro Per

CC:
Honorable Laurie M. Earl
Administrative Presiding Justice
The Court of Appeals, Third Appellate District

Honorable. Michael G. Bowman ,Presiding Judge


SUPERIOR COURT OF CALIFORNIA

The State Bar of California


Office of Chief Trial Counsel

On October 11, 2023 I received notification by e-mail from the California Supreme
Court that my Petition for Review was denied in the Case No. S281719
On October 12, 2023 one day after the California Supreme Court notification I
expressed my thoughts about in the letter addressed to the new California Supreme Chief
Justice Hon . PATRICIA GUERRERO: (EXHIBIT #88) on flash drive and DVD)
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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


INSERT LETTER
Re: October 11, 2023 e-mail notification stating that my September 6, 2023
Petition for Review was Denied and Record on Appeal Transmitted by
3DCA to the Supreme Court of California on September 6, 2023

Re: Motion to place my petition in abeyance due to a pending complaint


with the State Bar against the Director and Chief Counsel of the
Commission on Judicial Performance, Gregory Dresser

Dear Chief Justice Guerrero:

Yesterday, October 11, 2023, I received an e-mail from the Supreme Court
of California informing me that my Petition for Review, which I filed on
September 6, 2023 in the above-captioned case, S281719, had been denied
(ATTACHMENT #1). However, I neither received a copy of the Court’s
En Banc order nor a decision via TrueFiling denying my petition.
I am writing this letter to you because I was just ready to submit a Motion
to Place the Petition for Review in Abeyance until my September 25, 2013
complaint to the State Bar of California Chief Trial Counsel against
Director and Chief Trial Counsel of the Commission on Judicial
Performance, Gregory Paul Dresser, was resolved and decided by the State
Bar of California Chief Trial Counsel or the State Supreme Court.
https://www.scribd.com/document/673875662/9-25-2023-State-Bar-
Complaint-Against-Gregory-P-Dresser-Director-of-the-California-
Commission-on-Judicial-Performance
Mr. Dresser, as the former State Bar of California Chief Trial Counsel and
Director of the Commission on Judicial Performance, condoned the real
crimes of my former attorney, Douglas Stein, and meddled in and tempered
with the judicial process, which led not only to the issuance of unlawful
opinions by 3DCA, but also to the legitimization by one of those opinions,
3DCA Case No. C079254, Supreme Court Case Nos. S253713 & S245879,
the theft of my unemployment insurance benefits, and the theft of $22,284
from my wife by The Regents’ attorneys in collaboration with Sacramento
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Addendum to the State Bar of California Attorney Misconduct Complaint Forms.


County Superior Court judicial officers and staff. All of this was an attempt
to frame her for criminal prosecution and to steal her life savings from her
bank and 401(K) retirement accounts.

Furthermore, in preparation to file the motion to place my petition for


review in abeyance, I submitted on September 28, 2023 an inquiry to
Supreme Court Senior Deputy Robert T. Troy requesting that he provide
me with specific information concerning the record on appeal that was
transmitted by the 3DCA Clerk on September 6, 2023 to the Supreme Court
of California to decide the case (ATTACHMENT #2).

Mr. Troy neither provided me the requested information nor made any
entry in the docket for Supreme Court Case S281719 indicating that the
Court had received or filed my inquiry about the record on appeal
(ATTACHMENT #3). Looking at the docket entries and case disposition
entry, I have come to the conclusion that my Petition for Review, like the
previous petitions for review I have submitted in the past, were decided by
the Supreme Court’s rubber stamp justice and that none of the Supreme
Court Justices even knew that my petition for review in Case S281719 had
ever been filed or existed.

In my September 28, 2023 inquiry, I made reference to my 32-page-long


request regarding that record on appeal, which I submitted on August 28, 2023
to 3DCA Clerk/Executive Officer Colette M. Bruggman (ATTACHMENT
#4). The inquiry/request, titled “Request for the 3DCA Clerk’s Office to
transmit the Supplemental Clerk’s Transcript on Appeal Volume 1 of 1 and
Clerk’s Transcript Volume 1 of 13 to the Supreme Court of California in the
above-captioned 3DCA Case No. C095488,” clearly and indisputably shows
how the record on appeal in this case was manipulated by the Court staff and
the process of appeal was compromised. The decision on appeal was known by
my adversaries for a long time before the totally unlawful unpublished opinion
in Waszczuk v. Regents of the Univ. of Cal., No. C095488 (Cal. Ct. App. July
28, 2023) was issued, legitimizing the crime and corruption I have dealt with
over the past 10 years.
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My wrongful termination case is interconnected with my whistleblower case,
Jaroslaw Waszczuk v. Commissioner of the Internal Revenue Service, Case No.
USCA 12-1407, which is pending in the United States Court of Appeals (see
my Appellant-Petitioner’s Reply to Appellee’s Opposition -Re: Appellant’s
Motion To Recall The Mandate, Reinstate the Appeal, and Reopen the Case
filed on September 26, 2023, ATTACHMENT #5). The whistleblower case in
the Federal Court was and is precisely coordinated by lawyers with this case. I
am receiving similar treatment and being served similar justice in the Federal
Court as I have in the State of California’s three Court levels.

I would like to mention that, since December 16, 2023, I have been
representing myself in the above-captioned Jaroslaw Waszczuk v. The
Regents of the University of California, Case No. 34-2013- 00155479, a
wrongful termination case that has been pending since December 4, 2013. I
was forced to represent myself due to my now-former attorney Douglas
Edward Stein’s criminal misconduct and conspiracy with my adversaries’
attorneys (see the Supreme Court Minute Order In re Stein, No. S245982,
Cal. Mar. 1, 2018, https://casetext.com/case/in-re-stein-2011). This Minute
Order needs to be recalled due misleading and false information provided
to the Supreme Court in 2007 by former State Bar Deputy Trial Counsel
Laura Huggins, who is the subject of my September 25, 2023 complaint to
the State Bar, Case No. 23-O-23273.

With my Petition for Review, I expected that the Supreme Court of


California would look at case and investigate why it has been pending for
ten years and not brought to trial or dismissed. I am a Polish immigrant
with very limited legal knowledge representing myself, yet I have occupied
the courts for ten years.

If this letter does nothing more, I would at least like to state for the record
that this case will return to the Supreme Court after the motion to recall the
remittitur is denied by the 3DCA, and as a Walker petition if the State Bar
of California’s Chief Trial Counsel’s office closes my complaint without
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investigation against Dresser and the other perpetrators licensed by the
State Bar of California.
Sincerely,

________________
Jaroslaw “Jerry” Waszczuk
Plaintiff & Appellant in Pro Per

CC:

Honorable Laurie M. Earl


Administrative Presiding Justice
The Court of Appeals ,Third Appellate District

Honorable Michael G. Bowman, Presiding Judge


County of Sacramento Superior Court
The State Bar of California
Office of Chief Trial Counsel

IX.
CONCLUSION

In light of the above facts and evidence, I am respectfully requesting that the State Bar
of California Chief Trial Counsel’s office fully investigate the alleged professional and
criminal misconduct of the Porter Scott law firm, based in Sacramento, California, and its
attorneys MICHAEL POTT, DAVID BURKETT, DANIEL BARDZELL, DEREK
HAYNES, LINDSAY GOULDING, and; and attorney KAREN BRAY from Horowitz
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& Levy LLP, based in Burbank, California. Their criminal misconduct from 2019–2023,
which included but was not limited to tampering with and meddling in the judicial
process in my wrongful termination lawsuit against the UC Regents by conspiring or
blackmailing judicial officers and staff from the Sacramento County Superior Court
Departments 43, 53,and 54, Appellate Department 102, and 3DCA forced them to
collaborate. These firms’ conspiracy with judicial officers and staff in two Sacramento
courts have led to a miscarriage and travesty of justice in the courts, rigged judicial
processes, and the extortion of $22,284 from my wife in July 2021 with criminal intent to
set her up for criminal prosecution and to rob her of her life savings.
The irreparable financial loses and devastation of my life caused by the Porter Scott
attorneys’ conspiracy with the five defendants listed in my lawsuit to terminate my
employment with UC Davis Medical Center in 2012 and their later 2014–2023
conspiracy with my former attorney DOUGLAS STEIN, judicial officers, and staff in
two Sacramento Court has cost me more than $1 million and is something I cannot just
ignore and let it go.

Respectfully submitted on July 9, 2024,

_____________________
Jaroslaw Waszczuk
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Enclosed: 88 supporting EXHIBITS, on the flash drive and DVD

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