barnett v dunn, et al. (state court cali) - notice of removal to federal court - defaultdms

8/9/2019 BARNETT v DUNN, et al. (STATE COURT CALI) - Notice of Removal to Federal Court - DefaultDMS

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B E N J A M I N B . W A G N E RUnited States AttomeyYOSHINORI H . T . HIMEL #66194Assistant U. S. Attomey501 I Street, Suite 10-10 0 BySacramento, Cal i fomia 95814Telephone: (916) 554-2760At tomeys for Federa l Defendant , the U .S . ELEC TION A SSISTA NC E COM ISSION

A U G 1 8 2 C 1 0JJVIAGDON/

D e p w y O l d i k

SUPERIOR COURT OF CALIFORNIACOUNTY OF SACRAMENTO

PAMELA BARNETT,Plaintiff,

v.DAM ON JERR ELL DUN N, etc., et al.,

Defendants.

NO . 34-2010-00077415

N O T I C E O F R E M O V A LT O F E D E R A L C O U R T

TO THE CLERK OF THE ABOVE-ENTITLED COURT, AND COUNSEL OFRECORD:PLEASE TAK E NOT ICE that the UNITED STATES OF AM ERICA today filed,

in the Office oft he Clerk oft he United States District Court for the Eastem District ofCalifomia, a Notice and Petition removing the above-captioned pend ing action to theUnited States District Court.

Under 28 U.S.C. 1446(d), the filing ofthe Pefifion for Removal with the clerk ofthe District Court together with the giving ofthis Notice "shall effect the removal and theState court shall proceed no fijrther unless and until the case is remanded" by the UnitedStates District Court for the Eastem District ofCa lifomia .NOTICE OF REMOVAL TO FEDERAL COURT Page 1


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Dated: August 17, 2010 BENJAMIN B . WAGNERUnited Stat^s^Anomey

-Y-OSHMORI^HrT. HIMELAssistant U. S. Attomey

NOTICE OF REMOVAL TO FEDERAL COURT Page 2


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CERTIFICATE OF SERVICE BY MAILThe undersign ed hereby certifies that she is an employee in the Office of theUnited S tates Attom ey for the Eastem District of Califomia and is a person of such ageand discretion to be com petent to serve papers.That on August 17, 2010, she served a copy of:

N O T I C E O F R E M O V A L T O F E D E R A L C O U R Tby placing said copy in an envelope addressed to the persons hereinafter named, at theplaces and addresses shown b elow, which are the last known addresses, and mailing saidenvelope and contents in the U .S. Mail in Sacramento, Califomia.Addressees:Ms. Pamela Bamett2541 Warrego WaySacramento, CA 95826

Nicholas S. Chrisos, County CounselWendy J. Phillips, Senior D eputy333 W. Santa Ana B lvd, Ste. 407P.O. Box 1379Santa Ana, CA 93702-1379

Brian T. Hildreth, Esq.Bell, McA ndrews & Hiltachk,455C apitolM aIl, Ste. 801Sacramento, CA 95814DAG Anthony P. O'Brien1300 I St., Ste. 125Sacramento, CA 94244-2550

PAMELA BEAU VAISJ U L ^ i ^ J O S ^

NOTICE OF REMOVAL TO FEDERAL COURT Page 3


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Case2:10-at- /0^ Document 1 Filed 08/17/1C age 1 of 134I2345678910111213141516171819202122232425262728

BENJAMIN B. WAGNERUnited States AttomeyYOSHINORI H. T. HIMEL #66194Assistant U. S. Attomey50 11 Street, Suite 10-100Sacramento, Califomia 95814Telephone: (916)554-2760Attomeys for Federal Defendant, the U.S. ELECTION ASSISTA NCE COM MISSION

IN THE UNITED STATES DISTRICT COURT FO R THEEASTERN DISTRICT OF CALIFORNIA

PAMELA BARNETT,Plaintiff,

V .DAM ON JERRELL DUN N, etc., etal.,

Defendants.

No.UNITED STATES ' NOTICE ANDPETITION FOR REMOVAL OF CIVILACTION FROM STATE COURTState Co urt N um ber ; 34-2010-00077415

TO: THE JUDGES OF THE UNITED STATES DISTRICT COURT FOR THEEASTERN D ISTRICT OF CALIFORNIA, AND COUN SEL OF RECORD:PLEASE TAKE NOTICE that the United States of America, through its

undersigned counsel, removes the civil action reflected in the attached pleading fi-om hecourt ofthe State ofCa lifomia where it was pending, and respectfiiUy represents asfollows:

1. Rem oval i^ jurisdictionally proper under 28 U.S.C . 1442(a)(1), becauseFederal Defendant U.S. ELECTION ASSISTANCE COMMISSION is an agency oftheUnited States.

UNITED STATES' NOTICE AND PETITION FOR REMOVAL OF CIVIL ACTION FROM STATE COURT Page 1


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Case2:10-at-. 201 Document 1 Filed 08/17/1G age 2 of 1341 2. This removal is timely because the United States first received the complaint,2 by service or otherw ise, on or after July 19, 2010, and this removal followed w ithin thirty3 days afterward.4 3. A copy ofth e pleadings received by the United States is attached hereto.5 4. The United States is requesting from the state court a copy of that court's6 pleading file, for filing under 28 U.S .C. 1447(b) with this Court's Clerk upon receipt7 from that court.8 WH EREF ORE , the United States prays that the captioned action, formerly9 pending in a court ofth e State ofCa lifom ia, proceed in This Honorable Court, and that

10 the proceedings be govem ed by the applicable federal mles and statutes.11

Dated: August 17, 2010 BENJA MIN B. WA GNE R12 United States Attom ey13 By: A / YHimelYOSHINORI H. T. HIMEL14 Assistant U. S. Attom ey151617181920212223242526272 o UNITED STATES' NOTICE AND PETITION FOR REMOVAL OF CIVIL ACTION FROM STATE COURT P a g C 2


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Case2:10-at-v 201 Document 1 Filed 08/17/10 age 3 of 134

Pamela Bamett, Pro Se P laintiff2541 Warrego W aySacramento. CA, 95826Telephone : (415)846-7170Pb_realestateyahoo.com

PAMELA BARNETT, IN PRO SE

FILED/ENDORSED

By_ L. GUTiLRRKDeputy Clerk

SUPERIOR COURT OF THE STATE OF CALIFORNIAFOR THE COUNTY OF SACRAMENTO

Pamela Bamett,'Plaintiff,

vs. .

Case No.: 34-2010-00077415NOTICE OF ERRATA REGARDINGFIRST AME NDED COMPLAINT

Damon Jerrell Dunn (aka Damon Dunn);Oebra Bowen individualiy and officially asThe California Secretary of State; NealKelley Ofllcially as the Orange CountyRegistrar of Voters and Individually;Edmund G. Brown Jr. (aka Jerry Brown)Officially as The California AttorneyGeneral and individually; U.S. E lectionAssistance Commission; and John Doe(s)and Jane Does,

J - Defendants

Judge:Action Filed:Trial Date:

UnknownMay 10,2010Not set

TO THE COURT:I, PAMELA BARNETT. subm it the following clerical corrections regarding the First

Amended Complaint Filed July 12 . 2010. A clerk^al error occurred with the F irst AmendedComplaint.

- 1 -NOTICE OF ERRATA REGARDING FIRST AMENDED COMPLAINT


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Case2:10-at-^ 201 Document 1 Filed 08/17 /10 age 4 of 134

Corrections are the follovnng:1. Page 5, Paragraph 15. Change "13" to "14"2. Page 12, Paragraph 43. Change "36" to '"42"3. Page 17, Paragraph 65. Insert J l after "Exhibit"4. Page 1 8. Paragraph 70 . Change "66" to "69"5. Page 21. Paragraph 80, C hange "76" to "79"6. Page 24. Paragraph 89. Change "74" to "88"7. Page 27 , Paragraph 101. Change "119" to "100"a. Page 36. Paragraph 136. Change "122" to "135"9, Page 32, Paragraph 121, Delete "94 through 103"10 . Page 39 is attachedI declare under penalty of perjury under the laws of the State of Ca lifomia that th e

foregoing is true and correct and that this Declaration was executed June 20.2 01 0, atSacramento, Califomia.

\ Pro Se

- 2 -NOTIQE OF ERRATA REGARDING FIRST AMENDED COMPLAINT


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Ca se2 :10 -a t -c 201 Docum ent 1 F i led 08/17/10 age 5 o f 134

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STA TE OF CALIFORNIA

V E R I F I C A T I O N

)} s s .C O U N T Y O F S A C R A ME N T O )Accord ing ly , I, PAM ELA BAR NET T, be ing du ly swom , depose and say under pena l ty o fperjury:

1. That I am the Plainti ff self represented w ithout being an a ttorney, over 21 years o fage w i th p lace for serv ice a t 2541 Warrego W ay Sacram ento, CA, 9582 6.

2 . I have read the above P la in ti ff F i rs t Am ended Com pla in t w i th E ig hyS ) Cause o fAct ion with dam ages in the amou nt of say $250,00 0.00 plus costs and pun it ivesanct ions, and I know i ts contents; the fects stated In the F irst Ame rtdedCom plaint herein are true to my own person al knowledg e, exce pt as to thematters therein stated to be al leged on information and bel ief, and as to thosematters i bel ieve i t to be true. The grou nds of my b e l i e f a s to all matters notstated upo n information an d be l ief are as fo l low s: 3"^ part ies, books and records,and p ersonal know ledge , exce pt as to those stated upon inform ation and be l ief,wh ich I bel ieve to be true .

S w o m tobefore m e ^ T his ; r ^ d a v o f J u i k 2 0 10 ^ ^ - ^ " ^ r , r , , - , I 'l .1J- WALIA JtCOMM. #1705732 ANOTARYPUBUC-CAUFORNIA USACRAMENTO COUNTY T% Comm. Expires Nw. 22 ,2 01 0 .

Firs t Am ended Co mpla in t Page 39 o f 39


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C a s e 2 : 1 0 o | f c lO N i o c u m e n t 1 Filed 08/17/(CITACtON JUDICIAL)

NOTIQE TO DEFENDANT:( AV IS O A L O m A H D A D O ) :DamoQ Jfenreil Outm (A.K A. D sm on Du on)

YOU ARE BEING SUED BY PLAINTIFF:(LO E S T A t>mAN0AflOO BL D & I A m A f f r ^ :Pamela Bamet t

SUW-100isatonutAusoeetA ctuaet

FILED/ENDORSED

B w : .J U L 1 2 2 0 1 0

E MEDINAtepotyCfEdi 1NOT>Ct You have ben sunt The cou/t msy decnte agamstyob vnthoirt your being iNord unless you respond within 30 days R68d(heffnaianodrndsdits&r/8abid&me(tontiMecu^^ TraneompanrerrMgnwwnen de iacoita an f as ^ ^ u e is certapuedb (finecAarefcaso

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Case2:10-at- . ^01 Document 1 Filed 08/17/10 age 7 of 134 e..f*su|w-zg tf m& atlai:hment is itsea, insert the Coliowtod atatemeM m the piamtdf or ^iefi^ndant t>ox on ^ a summona 'Additional PartieaAttachment fonn la atia ched "List addit ional pa rttaa (Ched< mt y one Oox Use a separata paga fo r a s ^ typa of patfy)1 1 Plainttff \ 2 2 defendant [ ^ Cros^-Compfamant [ | Cross-Defendant

D eb ra B o w e o m


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Case 2:10-at- ^01 Document 1 Filed 08/17/1C age 8 of 134FJiJD/ENDORSEDame la Ba me tt, Pro se Plaintiff2541 Warrego W aySacramento, CA, 95826Telephone: (415)846-7170

SUPERIOR COURT OF CALIFORNIACOUNTY OF SACRAMENTO

J U L 1 2 2010P y E MEDINA

Deputy Clerjj^

-XPamela Bamett ) Case No. 34-2010-00077415Plaintiff, )V. ) FIRST AMEN DED COM PLAINTDam on Jerrell Dunn (A.K.A. Dam on Dun n); )Debra Bowen individually and officially as ) with CEC 201. 2150(a)(10Kb)The Cal i fomia Se aeta ry of State; ) 2153, 2154 related to NVRA / HAVANEAL KELLEY officially as The Orange ) Law and CEC 1820 3,Coun ty Registrar of Voters and individually; ) 1850 0 and 1850 1 violations virithEdmund G. Brown Jr. (A.K.A. Jerry Brown) ) r e q u ^ t for Jury tr ial on fects toOfficially as the Califomia Attom ey Gen eral ) determ ine d vi l dam agesand individually; U.S. Election Assistance )Com mission; John and Jane Doe(s) ) Priori ty In Trial Schedul ing und er

) CCP Code 4 4 , Ca lifornia Code -) Section 44 as pertains to Nove mb erDefen dants) 2010 Election

X

Plaintiff Pam ela Bam ett as a First Am ende d Com plaint alleges:

I - INTRODUCTIONP a r t i s

1. Defend ant Dam on Jerrell Dun n (a.k.a Dam on Dun n, Defendant D unn), is anatural person resident in Califomia (CA) at 3131 Michelson Unit 708W In/ine CA 92612with Em ail damondunn(S)vahoo.com ; and is questionably on the California Repu blicanParty primary ballot as a declared cand idate for the State of Califomia Repub lican PartyCand idate for Secretary of State of Califomia on Jun e 8,2010 and G eneral Elect ion.

First Amended Complaint Page 1 of 39


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1 2. Respond ent NEA L KEL LEY (Respondent Kelley, Registrar) is a natural person2 sued in his official capacity as Th e Orange County Registrar of Voters, with place of3 business located at Th e Orange County Registrar of Voters 1300 Sou th Grand Avenue4 Building C Santa Ana CA 92705 Telephone 714.567.7600; and sued individually.

3. That according to the CA L ELEC. CODE 2107.6 (a) Except as provided in subdivision (b), the county elections official shall7891011121314151617181920212223242526272829303132

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accep t affidavits of registration a t all times excep t during the 14 days imm ediatelypreceding any e lection, wh en registration shall cease for that election as toelectors residing in the territory within which the election is to be held. Transfersof registration for an election may be made from one p recinct to another precinctin the same co unty at any time w hen registration is in progress in the p recinct towhich the elector seeks to transfer.(b) Th e county elections official shall accept an affidavit of registration executedas part of a Califomia Voter R egistration F onn In the forthcoming election if theaffidavit is executed on or be fore the 15th day prior to the elec tion, and if any ofthe following appiy:(1) The affidavit is postm arked on or be fore the 15th day prior to the e lectionand received by m ail by the county elections official.(2) The affidavit is subm itted to the Depa rtment of Motor Vehicles or ac ceptedby any other pub lic agency de signated as a voter registration agency p ursuant tothe National Vote r Reg istration Act of 1993 (42 U.S.C. Sec. 1973gg) prior to theelection.(3) Th e affidavit Is delivered to the county elections official by m eans other thanthose d escribed in paragraphs (2) and (3) on or before the 15th day p rio rto theelection.4. Defendant Debra B owen (Defendant Bowe n, SOS), is a natural person sued in

her official capacity as the Secretary of State of the State of Califomia (SO S), with placeof business located at 1500 11^ Street, 5^ Floor Sacramento, CA, 95814 Fax (916) 653-3214 with CAL. ELEC. CO DE 10: Califomia Code - Section 10 is the chief of electionsofficer of the state, and has the powe rs and duties specified in Section 12172.5 of theGovemment Code; and is sued individually herein for breach of Fiduciary Duty.

5. Tha t Defendant Bowen is a statutory mem ber of the United States ElectionAssistance Com mission by the Help America to Vote Act of 2002 (HAV A).

First Am ended Complaint Page 2 of 39


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6. That according to the CAL. ELEC. COD E 10:the S ecretary of State is the chief of elections officer of the state, and has th epowers and duties specified in Section 12172.5 of the Govem men t Code .

7. That according to the CA L. ELEC. CODE 2155 .5.(a) The Secretary of State may, in coordination with county elections officialswh o choose to pa rticipate, and develop specific procedures to addresscom plaints related to voter registration, including procedures to promptlyreregister voters wh o believe their registration was ch anged improperiy.(b) The procedures ad opted pursuant to this section shall not provide anvexem ption to laws related to voter reeistration within the 15 davs orior to anelection. (Emph asis by Petitioner)

8. That according to the CAL . ELEC . CO DE 2156.The Secretary of State shall print, or cause to be prin ted, the blank forms of thevoter notification prescribed by Section 215 5. The S ecretary of State shall supplythe forms to the county elections official in quantities and a t time s requested bythe coun ty elections official. The Secretary of State may continue to sup ply, andthe coun ty elections officials m ay continue to use , existing voter notification formsprior to printing new or revised forms as required by any cha nges to Section2155.

9. Defendant Edm und G. Brown Jr. (A.K.A. Jerry Brown , Defendant Brown, AG ) is anatural person sued in his official capacity as The Ca lifornia Attom ey G eneral (AG ),with place of business located at California Departmen t of Justice Office of the Atto m eyGeneral 1300 " I " Street - Suite 125 Sacram ento, California 94244-2550 is the chief lawenforcement officer of the sfete with powers and duties specified with Govemment codeto prosecute e lection crime; and is sued individually herein for breach of Fiduciary Duty.

10 . Defendant The United Sfetes ELECTION ASSISTANCE COMM ISSION ("E AC ),Address U nited States Election Assistance Com mission with THOM AS R. WILKE Y asthe EAC Executive Director located at 1225 New Yoric Avenue N.W., Suite -1100Wash ington, DC 2000 5 Telephone (202) 566-3100 Toll Free (866) 747-1471 Fax (202)

First Am ended C omplaint Page 3 of 39


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566-3127 E-mail Address [email protected]: and that ttie EAC along with ttioseparticipating S tates that m aintain a voter reg istration list within the National VoterRegistration Act of 1993 and H AVA w ittiin the Voting Rights Act of 1965 as amen dedthereafter (VRA ) and that is incorporated into each p articipating State statutes by 200 4that shall create , maintain and safegu ard a centralized a national voter registration listdatabase witti in each S tate accessible to each State member of the EA C.

11. Plaintiff Pame la Ba me tt, is a natural person with place for service located at 25418 I Warrego Wa y, Sacramento, CA, 95826 Telephone: (415) 846-7170 Fax: (866) 908 -9 22 52, and wh o is duly registered to vote in Califomia and enrolled / affiliated m embe r of

10 the Califom ia Repub lican Party eligible to vote at the Califomia Repu blican Party11 Primary sched uled for June 8,2010 and at the General Election in 201 0.12 12. That Plaintiff is a Northem Califom ia Cam paign Manager (Non-paid position) for13 Dr. Oriy Taitz, Esq.'s candidacy for Califomia Secretary of State for ttie June 8,201014 primary and Novemb er 2010 Gene ral Election; however this action is not endo rsed or15 paid for by Dr. Taitz or her cam paign .16 13. Plaintiff brought this lavt^uit imme diately after realizing that the S ecretary of State17 wa s going to fail to act on her fraud complaint requesting to remove an ineligible,18 fraudu lent candidate for Secretary of Sfete , Damon Du nn, from the primary ballot, and to19 try to end a pattem of election fraud perpetrated by state elected officials Secrefery of20 State Bow en, Attome y General Brown and Orange County Registrar Neal Kelley.

I I -JURISDICTION14 . Ven ue is proper in ttie County of Sacram ento and this is the proper court for this

com plaint as the events complained of occurred wittiin this county because it involves

mailto:[email protected]:[email protected]


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Case2:10-at-L .01 Document 1 Filed 08/17/10 jg e 1 2 o f1 3 4

the Secrefery of Sfete of Califomia (SOS) and a candidate for Secrefery of State as isDefendant in the C alifornia sfetewide Republican P arty Direct Primary ^^\ and ttien theGen eral Election ballots with CA Election Code (CEC) 12; and at a Jury trial GeneralDamage s be assessed were the P rimary to proceed illegally, wo uld result in Defendantsliability to reimburse the c ost of the Republican primary and co sts incurred of anyopposing c andidate an d or Plaintiff herein along witti those similariy situated ; and th atjurisdiction shall be given preference in the CA Courts with CAL. CC P. CO DE 44^^^ttiat according to CEC 8800 : Califomia Code - Section 8800. No candidate whosedeclaration of candidacy has been filed for any primary election m ay withdraw a s acandidate at that primary election. Must be removed by Judicial Order.

Il l - BACKGROUND FACTSFIRST CAUSE OF ACTION

Defendant Dunn Maliciously Violated CEC 2150 (a)10. (b), CEC 20 1.15 . Plaintiff realleges each a nd every allegation contained in the ab ove paragraph s 1

through 13 with the sa me force a nd effect as though herein set forth at length omite it forbrevity.

16 . Plaintiff alleges that De fendant D unn's actions constituted a violation of C EC 2150 (a)(10) and (b). National Voter R egistration Act of 1993 (NVRA) a nd H elpAm erica to Vote Act of 2002 (HAVA) as incorporated in California E lection Cod e in that

^ CAL. ELEC. CODE 316: Califomia Code - Section 316. "Direct primary" is the primaryelection held on the first Tuesday after ttie firs t Monday in June in each even-numbered year, tonominate candidates to be voted for at the ensuing general election or to elect members of aparty central comm ittee.^. CA. CCP Code 44. California Code - Section 44. Appeals in probate proceedmgs, incontested election cases, and in actions for libel or slander by a person wno fields any electivepublic office or a candidate for any such office alleged to have occun-ed dunng the course of anelection campaign shall be given preference in hearing in the courts of appeal, and in theSupreme Court when transferred thereto. All these cases shall be placed on the calendar in theorder of their date of issue, next after cases In which the people of the state are parties.First Am ended Complaint Page 5 of 39


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Case2:10-at-L Jl Document 1 Filed 08/17/10 jg e 1 3 o f1 3 4

Mr. Dunn had at a ll times mentioned herein explicit knowledge of ttie law witti malice.17. The CEC requires ttiat to be e ligible to be a qualified candidate for Secretary of

3 I Sfete a declared and a nominated candidate shall under 201 of the Califomia E lections4 Code "b e a registered voter an d otiierwise qualified to vote for that office a t the time5 nomination papers are issued to the persorf\ and

18. That according to CEC 2100 it mandates:No pe ison sha ll be registered except as provided in this chapter except upon theo II production and filing of a certified copy of a judgment of the superior court9 I directing registration to be made.

19. That according to CEC and related law CEC 2150 requires that:(a) The affidavit of registt'ation shall show:(1) The facts necessary to establish the affiant as an elector.(2) The affiant's name at length, including his or her given name, and a middlename or initial, or if the inifial of the given name is customarily used, then theinitial and middle name. The affiant's given name may be preceded, at affiant'sopfion, by the designation of Miss, Ms., Mrs., or Mr.A person shall not t>e deniedthe righ t to register because of his or her failure to mark a prefix to the givenname and sha ll be so advised on ttie Califomia Voter Registration Form. Thissubdivision sha ll not be construed as requiring the printing of prefixes on anaffidavit of registration.(3) The affiant's place of residence, residence telephone number, if fum ished,and e-mail address, if fumished. No person shall be denied the right to registerbecause of his or her failure to fumish a telephone number or e-mail address,and shall t)e so advised on the Califomia Voter Registration Form.(4) The affiant's mailing address, if different from the p lace of residence.(5) The affiant's date of birth to esfeblish that he or she will be at least 18 yearsof age on or before ttie date of ttie next election. In ttie case of an affidavit ofregistration subm itted pursuant to subdivision (d) of Section 2102, the affiant'sdate of birth to establish that he or she is at least 17 years of age.(6) The state or country of ttie a ffianf s birtti.(7^ (Al In ttie case of an applicant who has been issued a cunrent andvaliddriver's license, the applicant's driver's license number.(B) In the case of any other applicant, other than an applicant to whomsubparagraph (C) applies, the last four digits of the applicant's sodal securitynumber.(C) If an applicant for voter registration has not been issued a current and validdriver's license or a sod al security number, the sfete shall assign the applicant anumber that will sen/e to identify the applicant for voter registration purposes. To



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1 the extent that ttie state has a com puterized list in effect under this subdivision234567891011121314151617181920212223242526272829303132

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and the list assigns unique Identifying n umbers to registrants, the num berassigned under this subparagraph sha ll be ttie unique identifying nu mberassigned under the list.(8) The affiant's political party affiliation.(9) That the affiant is cun'ently not im prisoned or on parole for the co nviction ofa felony.f1 0l A prior registration po rtion indicating whe ther the affiant ha s bee nregistered at anottier address, under another nam e, or as intending to a ffiliatewith ano ther party. If the affiant has been so re gistered, he or she shall give anadditional statement oivino that address, name, or partv.(b) The affiant sha ll certifv the content of the affidavit as to its truth an dcorrectness, under penaltv of periury. with the signature of his or her name andthe date of signing. If the affiant is unable to write he or she sh all sign witti a markor cross.(c) Th e affidavit of registtation sha ll also contain a space that wou ld enab le theaffiant to state his or her ethn idty or race, or both. An affiant may not be deniedthe ability to register because h e or she de dine s to state his or her ethnicity orrace.(d) If a person, including a deputy registirar, assisfe tiie affiant in completing ttieaffidavit, that person shall sign and da te the affidavit below the s ignature of theaffiant.(e) Th e affidavit of registration shall also contain a spa ce to p ermit the affiant toapply for pemianent vote by mail status.(f) The S ecrefery of State m ay continue to supply existing affidavits ofregistration to county elections officials prior to printing new or revised forms thatreflect the change s m ade to this section by the act that adde d this subdivision.(Emphasis by Petitioner)20. On March 1 3,20 09, Defendant Dunn fi led a Califomia Voter Registration Form

to tiy to b e qual'rfied to vote and to try to affiliate with the C alifomia Repu blican Party(see ExhibitA ).

21. That based upon a public records background check of Defendant Dunn andbased on Infonnation and belief on M arch 1 3,20 09, Defendant Dunn did not have avalid or current Califomia Drivers License as shown on Exhibit A, but instead ha d a validFlorida Driver's License.

22.That Defendant Dunn did not obtain a current Califomia Drivers License or validCalifomia Identification until 2010.



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Case2:10-at-t _01 Document 1 Filed 08/17/10 age 15 of 13423. That "Generaliv. vour dom icile isvMexQ your family lives, where you physicallyreside, the place you intend to return to whenever you are gone from it, wherevour driver's license savs vou reside, where you daim your homeowner'sproperty tax exemption or renter's fex credit, etc. (EC 349,2020-2034)24. That Defendant Dunn affimied the Voter Registration Form shown as Exhibit Adated witii the year March 15,1976.25. That Defendant Dunn use of tfie 1976 date to affirm t iie Voter Registration

Affidavit is an act of a serial liar and goes to the mens rea as with B ad Man Theory.26. That Mr. Dunn did not properiy execute the affidavit of Registration to vote and

was not a gualified voter at the time he received his nomination papers as required bvCEC $201 and conseguentiv he was not an affiliated Califomia Republican.

27. That Further, CEC and related law requires witti CEC 2151 ttiat:At the time of registering and of tansferring egistration, each e lector maydeclare the name of the political party with which he or she intends to affiliate atthe ensuing primary eledion. The name of that political party shall be sfeted inthe affidavit of registration and the index.The California Voter Registration Form shall inform the affiant that any electormay decline to sfete a political affiliation, but no person shall be entitied to votethe ballot of any political party at any primary eledion unless he or she has statedthe name of the party with which he or she intends to affiliate or unless he or shehas declined to state a party affiliation and the political party, by party rule dulynoticed to tiie Secretary of Sfete, authorizes a person who has dedined to state aparty affiliation to vote tiie ballot of that political party. The Califomia VoterRegistration Fonn shall include a listing of all qualified po litical parties.No person shall be permitted to vote the ballot of any party or for any delegatesto the convention of any party other than the party designated in his or herregistration, except as provided by Section 2152 or unless he or she has declinedto s tate a party afHIiation and the party, by party rule duly noticed to the Secreferyof Sfete, authorizes a person who has declined to state a party affiliation to votethe party ballot or for delegates to the party convention.

28. Defendant Dunn still may not have a properiy executed registi-ation and mayhave voted illegally on ttie June 8,2010 Republican party ballot.

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29 . Defendant Dunn filed his Califomia Voter Registtation Fomn on March 13,2009,less tiien 8 months prior to his dedaration of candidacy when he filed his CandidateIntention Statement on November 5,2009;

30. Further, CEC and related law requires witti CEC 8001: (a) No dedaration ofcandidacy for a partisan office _. shall be filed, by a candidate unless (1) at the time ofpresentation of ttie dedaration and continuously for not less than three m ontiisimmediately prior to that ime,or for as long as he has been eligible to reg ister to vote inthe state, the candidate is shown by his affidavit of registration to be affiliated w itii thepolitical party the nomination of which he seeks, and (21 the candidate has not beenregistered as affiliated with a Qualified political oartv o tiier than that oolitical oartv thenomination o f which he seeks vinthin 12 months, or, in the case of an election govemedby Chapter 1 (commencing with Section 10700) of Part 6 of Division 10, within ttireemonths immediately prior to the ilingof the declaration. (b)The elections official sha llattach a certificate to tiie deciaration of candidacy showing the date on which thecandidate registered as intending to affiliate w itii the political party the nomination ofwhich he seeks, and indicating that the candidate has not been affiliated with any otherqualified political party for the period specified in subdivision (a) immediately precedingthe filing of the declaration. This section shall not apply to dedarations of candidacy filedby a candidate o fa political party partidpating in its first direct primary electionsubsequent to its qualification as a political party pursuant to Sed ion 5100. (Emphasisadded by PlaintifO

31. Because Defendant Dunn did not have a properiy executed voter registration dueto his en-ors and omissions, he also could not be enrolled / affiliated witti tiie Republican



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Case2:10-at-L _01 Document 1 Filed 08/17/10 age 17 of 134Party of Califomia. any State, and or National Republican Party affiliation for 3 or 12monttis as of November 13,2010 because his voter registration was not properiyexecuted and tiiere fore not a qualified voter.

32. On or about November 5,2009, Defendant Dunn iled he Candidate IntentionStatement fo r his candidacy at 2070 Business Center Drive Suite 140 Irvine CA 92612(See Exhibit Bl for ttie California Republican Party nomination D ire d Primary withDefendant Bowen and based on information and belief he received his nominationpapers soon after.

33 . That according to CEC 305: Califomia Code - Sed ion 305. (a)Xand idate," forpurposes of Section 2184, includes any person who declares in writing, under penatty ofperjury that he or she is a candidate, naming the office. (b)"Candidate," as used inArtide 1 (commendng with Section 20200) of Chapter 3 of Division 20, means anindividual listed on ttie ballot, or who has qualified to have write-in votes on his or herbehalf counted by election o fficials, for nomination or for e lection to any elective state orlocal office, or who receives a contribution or makes an expenditure or gives his or herconsent for any other person to receh/e a contribution or makes an expenditure with aview to bringing about his or her nomination or eled ion to any elective sfete or localoffice, whether or not the specific eledive office for which he or she will seek nominationor eled ion is known at the ime he conttibution is received or the expenditure is made.The term "candidate" indudes any officeholder who is subje d to a recall election. CECSection 305 (c)''Candidate for public office," as used in Chapter 5 (commencing withSection 20400) of Division 20 , means an indh/idual who has qualified to have his or hername listed on the ballot of any election, or who has qualified to have written votes on



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Case2:10-at-L .01 Document 1 Filed 08/17/10 age 18 of 134his or her behalf counted by election officials, for nomination for. or e led ion to , anysfete, regional, county, municipal, or dis trid office which is filled at an election.

34. Defendant Dunn iledas early as possible to maximize press coverage,donations, and endorsements to take advantage of being affiliated as a CA RepublicanParty Member.

35. Defendant Dunn sought out advice from John and Jane Doe(s) to violate CEC2150 (a) (10) and (b) in order to maximize advantage over any other affiliatedCalifomia Republican Party candidate if any were to file a declaration by say March2010 or the minimum available time before the primary election on June 8 ,2010.

36. Defendant Dunn knew were he properiy registered that by ilingeariy he wasviolating CEC 8001 as he thought he was only an affiliated Republican for about 8months and decided not to wait until say March 2010 to file the Declaration ofCandidacy, instead sought to conceal and expunge his Florida Democratic Partyaffiliation record as well as that in Texas. A certified copy of an original letter from JeanMarie Atkins, the F lorida Director of Voter Administtation stated "On July 10,2009, Mr.(Damon) Dunn contaded our office via telephone and asked for his ineligible voterregistration record to be removed from the Duval County dafebase."

37. That Defendant Dunn asked to have his voter record be deleted because hewanted to hide something. Dunn played the odds that no one would investigate hisCalifomia voter registtation form. It was more important for Dunn to m aximize hiscampaign contributions.

38.That Dunn knew he had registered to vote prior to swearing in California ttia t hewas registering to vote for the irst ime because why else would Dunn know to ca ll

24 Florida Eled ions.First Amended Complaint Page 11 of 39


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39. That Dun n also swore on his Deda ration of Candidacy in March 2010 that hehad "No Prior Regsitration" and on information and belief D unn has never tried tocorrect his O range C ounty affidavit of Voter Re gistration to reflect his priorregistration.

40. Tha t we re any person allowed to pa rtidpate in a Republican Primary Election orfor that matter In any ele dio n w ithout a prop erty exec uted affidavit o f Reg istration tovote Piain tiffs right to a reasona ble expecfetion of pa rticipation and success with l ike-minde d Party memb ers at the General Election would also be infringed . Without aproperiy executed affidavit of Registration to Vo te. Dunn w as never affil iated with theRepublican Party.

41 . Defendan t D unn . Kelley an d Bowe n by State Action injures Plaintiff along w iththose similariy situated suffered irreparable harm when Defendant Du nn was allowed byRespon dent Bow en and Kelley to partidpa te in the Repub lican Party primary as aRepubl ican Party e ledo r on June 8,2010 and General E ledion de spite t t ie expressrequirement of the law.

42. If Defendant Dunn had not co rred ed the improperiy executed affidavit ofregistration to vote sho wn a s Exhibit A before the 25"* of M ay 201 0, which is only 14days before the Primary eledio n of June 8,2010 he would not have been eligible tovote.

SECOND CAUSE OF ACTIONDefendante D unn / Kelley / Bowen Spoliation and Attemp ted Spoliation of Evidence43. Plaintiff realleges each an d every allegation contained in the above paragrap hs 1

through 36 with ttie sam e force and effect as thoug h he rein set forth at lengtti om its it for

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brevity.44 .Tha t base upon a public records check on Defendant Dunn, previous to m aking

an ap plication to vote in Califomia, based upo n information and belief that he ha dregistered to vote in both Texas and Florida and possibly Arizona under M otor Voter

45. That D efendant Dunn on M arch 13 ,20 09 had a valid Drivers License fi'omanother State and did not seek to ob tain a California Drivers License un til 2010.

46. That according to Defendant Bowen "vour domicile is... where vou r driver'sl icense savs v ou reside, mean ing that Defendant Dunn's License dom idle is out of Stateunti l he obtained a Califomia Driver's Ucen se on or about February 17 ,20 10 .

47 .Tha t on M arch 9, 2010 Defendant Kelley and or his agent "Alvarado" certif ied theOriginal executed affidavit of registration to vote shown as Exhibit A an d in doing s ocovered -up the affirmation section indu ding the Signature and affirmation da te.

48. On June 2 2, 20 10 , Plaintiff telephoned the Orange Coun ty Registrars Office tospeak w ith assisfent registrar "Alvarado" who h ad certif ied the copy shown as Exhibit Ato find out wha t was covered-up in the affirmation section ; and that Plaintiff was told bythe clerk "Christina" feking the call that "Alvarado" ha d been transfen-ed to anothersection of the Orange C ountry R egisttars Office and is not available for discussions asto the affidavit.

49. That whe n asked when Defendant Dunn had executed the Aff idavit ofRegistration to Vote "Christina" said "March 15 ,19 76 " but then sounded b ewildered an dsaid, "no , it must be 09 ." She also said it looked l ike 2006; and ti ien "Christina" askedPlaintiff to send a written req ues tfor the infomnation. ("Christina" oddly d isappeared offof the phone l ine after Plaintiff aske d her for her last name.)

50. That when a sked if Mr. Dunn had used a Califomia Drivers License (DL) or theFirst Am ende d Com plaint Page 13 of 39


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last four num bers of Dunn 's social security num ber. "Christina" said ttiat the O rangeCounty Registrar "rece ived a notification from DM V on February 17,2 010 ' as the date inwh ich Defendant Dunn m ust have gotten his CA DL and that at this point ttiere is anoriginal and an updated e xecuted Affidavit of Registration to Vote or som e otherame ndm ent attached to the original documenfetion for wh ich Plaintiff has a writtenrequest as of June 23 ,201 0.

51 . That D efendant K elley along with his agents in the Orange Cou nty RegistrarsOffice concealed evidence showing that Defendants Dunn and Kelley had not properlyexecuted the Affidavit of R egisttation to Vote before the M ay 2009 Califomia E led ion ,and that Mr. Dunn was no t properiy registered.

52. That Defendant Kelley concealed a crime when he transferred "Alvarado" toanother section of ttie Ora nge C ountry Registirars O ffice who is not available fordiscussions as to ttie affidavit shown as Exhibit A.

53.That Defendant Kelley concealed the last four numbers of Defendant Dunn'sSocial Security Number without notating what was concealed on the improperlyexecuted Voter AfRdavit of R egistration.

54. That Defendant Kelley and or his agents concealed Defendant Dunn's updatedVoter Registration (from DMV) and/or amendments tiiat based upon infonnation andbelief was executed in 2010.

55.Th at Defendant Kelley or his agents never attempted to con ta d D unn to verifythat he was no t registered to vote previously especially because he didn 't have aCalifomia identification card.

56. In law, spoliation of evidence is tiie intentional or negligent withholdin g, hiding,alteration or destruction of evidence relevant to a legal proceed ing. It is a criminal act in



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Case2:10-at-C J l Document 1 Filed 08/17/10 age 22 of 134ttie United States under Federal and most State law. Spoliation has two consequences:first, the a d is criminal by statute and may result in fines and incarceration for the partieswho engaged in tiie spoliation, secondly case law has established that proceedingswhich might have been altered by the spoliation may be interpreted under a spoliationinference. The spoliation inference is a negative evidentiary inference that a inderoffa d can draw from a party's destiuction of a document or thing that is relevant to anongoing or reasonably foreseeable d yj i or criminal proceeding: The inderof fa d canreview all evidence uncovered in as strong a light as possible against the spoliator andin favor of the opposing party.

57. That after Defendant Dunn made his application for Registration with the OrangeCounty Registrar as shown witi i Exhibit A, wherein Section 16 was intentionally leftblank to cover-up a prior registtation in another State, based on information and beliefDefendant Dunn in conjunction with other John and Jane Ooe(s) had expunged hisregisttation for tiie State of Texas (Exhibit J l Public Records check.) and called Floridaelections to expunge the record of his registration in order to conceal tiie evidence of hisfraud perpetrated on the Registration shown as Exhibit A and in preparation for hisintent of candidacy shown as Exhibit B and inallyon his Dedaration of Candidacy asExhibit K.

58 . That based upon infonmation and belief and according to a certified copy of anoriginal letter written April 13,2010 by Jean Marie Atkins Diredo r of VoterAdm inisttation of the Duval County Board of Elections and obtained in person by Dr.Oriy Taitz while In Florida (see Exhibit C), on July 10,2009, Defendant Dunn contadedthe Florida Board of Eled ions to have any record of enrollment or affiliation w ith theFlorida Democratic Party in the Duval County database expunged from the offidal



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record.59.That the Florida Board of Elections database in Duval County records show that

Defenda nt Dunn registered in Florida (see Exhibit D l affiliated with the Dem ocraticParty.

60. Th at based upon infom iation and belief the Florida Board of Elections Officialwith ttie fiduciary duty to safeguard the records of the Board of Elections including those

7 of Defendant Dunn , refused to expunge the records when he asked on July 10.2 00 9,891011121314151617

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and proves that Defendant Dunn was a Florida Dem ocrat prior to Defendant D unnded aring his intent of candidacy in California on November 5 ,20 09 .

61. Tha t Defendan t Kelley along with those similariy situated in control of the Vo terRegistration data base including Defendant Bowen as a member of the EAC chargedwith such responsibility, were Mr. Dunn's egregious commissions available to theCalifomia affiliated Republican Party members and his Endorsers before the June 8,2010 vote many wou ld have not endorsed or voted for him or contributed funds to thecampaign and such Sfete actions represent an outtageous spoliation and interferencevirith P laintiff an d those sim ilariy situated as affiliated mem bers of the Califom iaRepublican Party.

62. That Defendant Kelley's spoliation of Defendant Dunn's released voterregisttation form gave two t>enefits to Dun n. The spoliation hid that fa d that Du nn did

20 not have a California driver's license or ID and Dunn wrongfully dated his signature by212223

using his birth date . By information and belief many GO P voters wo uld not have votedfor Defendant Dunn because they would have wondered why a candidate for aCa lifomia sfetew ide office did not have a Califomia identification card or driver's license,

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1 and why a candidate for Secretary of State , ttie Head officer of elections, could not even2 com plete tiie signature date cor red ly on his voter registration fomn.3 63. For the purpose of adhering to ti ie CEC 2150, 215 3. 2154 and 80014 requirement. Defendant Dunn in effect was affiliated wi tii the Dem ocratic Party in Florida5 prior to Novem ber 5,2009 whe n he filed his intent for declaration of candidacy and6 intends to fite nom ination papers with CEC 804 0, acted in bad fait ii to falsify the7 California Election Record and drcu m ven t requirements of NVRA and HAVA requiring8 State to Sfete notification of chan ge.9 64. Defendant Dunn violated NVRA and HAVA with the fil ings shown as Exhibit A, B

10 and K thereby injuring Plaintiff along with those similariy situated.11 65. Moreover, Defendant Dunn committed voter fraud according to statutes CEC12 18203 and 18500 by intentionally omitting infonnation on his Califomia Voter13 Registration Form as he wa s previously registered to vote as a Democrat Party affiliate14 in Florida and Tex as and that he maintained a cunrent out of State drivers license, and15 maliciously om itted required information at Section 16 of the form shown as Exhibit A.16 Because Dunn was previously registered in Florida, Texa s and based upon infom iation17 and belief Arizona whe re he owns property (Exhibit backgroun d), and thereby concealed18 evidence of a crime Defendant Dunn intended to comm it to become Califomia SOS and19 solicit cam paign fund s under false pretense.20 66 . Plaintiff is a supporter and contributor to the candidacy of Dr. Oriy Taitz, DDS21 J.D. Esq., wh o wa s a duly declared candidate on the ballot at the Califom ia Repub lican22 Party Primary that wa s sched uled for June 8.2010 for the nomination by the Califomia23 Repu blican Party as the Republican Candidate for the Califomia Secretary of Sfete at

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Case2:10-at-C J l Document 1 Filed 08/17/10 age 25 of 134tiie November 2010 General Election; and that Dr. Taitz's only opponent is DefendantDunn at the Republican Nomination at the Primary other than write-in candidates, andwere Mr. Dunn removed from the Primary Baltot as demanded in this legal ad ion , Dr.Taitz as runner-up would be ttie Republican candidate for SOS at tiie General Eled ionof November 2010.

6 67. Defendant Dunn fadlifetes Defendants Kelley and Bowen who are interfering as7 Democrats to Infringe Plaintiffs First Amendment rights to proteded speech and8 assodation along with those similariy situated as an enrolled affiliated member of the9 California Republican Party with CEC 8001 and CEC 2150 required witti HAVA.

10 68. Defendant Dunn solid ts campaign funds from Republicans under false pretense11 I and along with the Defendant Califomia Secretary of State Bowen and Defendant12 Registrar Kelley whose State Actions have infringed Republican Party Affiliation righ ts13 ahd success at the elections, and have infringed Plaintiffs righ t to a reasonable14 expecfetion of participation and success with like-minded Party members at tiie15 Elections.

69. Because o f the violation of Law by Defendant Dunn, Plaintiff is damagedfinanc ially and will suffer irreparable harm were Defendant Dunn allowed by DefendantBowen and or the SOS agents to remain on tiie General Eledion ballot and that time isoff the essence in order to prevent irreparable harm at the November 2010 Election.

THIRD CAUSE OF ACTION Defendants Bowen. Kelley, Dunn Violated CEC 2150,2153 and2154 and related law70. Plaintiff realleges each and every allegation contained in the above paragraphs 1

through 66 w ith the same force and effe d as though herein set fortti at length omife it forbrevity.



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71. Plaintiff alleges tiiat D efendants Bowe n, Kelley, Dunn along with those yetunnam ed ad io ns constittJted a violation of CEC 2150 and related code including theNational Voter R egistration Act of 1993 (NVRA) and Help America to Vote Act of 2002(HAVA) in that Respondents Bowen, Kelley and Dunn had at all times mentioned hereinwith explicit knowledge of the law act with malice.

6 72. That according to CEC and related law CEC 21 50 requires tiiat:(a) The affidavit of registration shall show :(10) A prior registration portion indicating wh ether the affiant h as bee nregistered at another add ress, under another na me , or as intending to affiliatewith an other partv. If the affiant has been so re gistered, he or she shall give an

additional statement giving that addres s, name , or oartv.(b) The affiant shall certifv the content of the affidavit as to its truth andcorredness. under penaltv of periury. with the signature of his or her name andttie date of signing. If the affiant is unable to write he or sh e shall sign with a markor cross. (Emphasis by Petitioner)73. That Defendant Dunn on tiie Affidavit of Registration form show n as Exhibit A

om itted the prior name, add ress. State, and party affiliation of a prior registration asshow n on Se ction 16 to hide his prior registration as a D emocrat.

74. Tha t Responden t D unn had previously filed a registration to vote with the F loridaBoard of Eled ion database in Duval County and the records show that RespondentDunn registered in Florida shown as Exhibit D affiliated with the De mocratic Party.

75. That the CEC indusion of the HAVA provisions within recuires anv previousregistration within or without the State of Califomia to be disclosed bv M r. Du nn.

76. Tha t Further, CEC and related law requires with CEC 2153 ttiat:26 (a) Except as provided in Sed io n 215 4, the affidavit of registration shall show27 I all the fa d s reguired to be stated.28 I (b) If the affidavit does not contain all o ft h e information reguired. but the29 telephone numb er of the affiant is legible, the countv elections official shall30 telephone the affiant and attempt to collect the missing information.



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(cl If the affidavit does not contain all of the information reguired. and thecountv e led ion s official is not able to collect the m issing inform ation bvtelepho ne, but the ma iling address of the affiant is legible, the countv e led ion sofficial shall inform the affiant of the reason for re ied ion an d shall send to ttieaffiant a new Califomia Voter Registration Fonn. (Emphasis by Petitioner)77.That Further, CEC and related law requires with CEC 2154 ttiat:

8 In the event tiiat the countv ele dio ns official receives an affidavit of registration9 that does not include portions of the information for which space is provide d, the10 coun tv ele dio ns offid al voters shall applv the following rebuttable presum ptions:11 (a) If no middle nam e or initial is sho wn , it shall be presumed12 that none exists. >13 (b) If no party affiliation is sho wn , it shall be presume d ttiat the affiant has no14 party affiliation .15 (c) If no execution date is sho wn, it shall be presumed tiiat the affidavit was16 execu ted on or before the 15th day prior to the election, provided that (1) the17 affidavit is received by the county elections official on or before the 15th day prior18 to the election, or (2) the affidavit is postmartced on or before the 15th day prior to19 the ele dio n and received by ma il by the county ele dio ns official.20 (d) if ttie affiant fails to identify his or her state of birth within the United State s,21 it shall be presum ed that the affiant was bo m in a state or territory of the United22 Sfetes if ttie birthplace of ttie affiant is show n as "United Sfetes," "U.S.A.," or23 other recognizable term designating the United States. (Emph asis by Petitioner)24 78. That Defendant Bowen and Kelley or their agents have no rebuttable

presumption that would omit the requirement to seek a prior registtation address fromMr. Dunn or demand a properiy executed Voter Affidavit of Registration.

79. That Defendants Kelley and Bowen dkl not seek a prior registtation address fromMr. Dun n as required with CEC a nd only after Plaintiff and Dr. Oriy Taitz, Re publicanSecretary of Sfete Candidate, complained did Defendant Bowen start an investigationwh ich is still ongoing and therefore m ay not use Laches or Estoppe l as an affirmativedefense, in f a d have waive such defense. Defendant Kelley's office was notified via fax(Exhibit O )and called by Plaintiff regarding D efendant Du nn's prior voter registrationomission, but Plaintiff is unaw are of any investigation or corrective action that Defend antKelley or his agents have taken . Mr. Justin Berardino, assigned by ttie Orange C ounty



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Registrar's office to validate voter registrations, seeme d completely unco ncerned aboutttie fraud perpettated by Defendant Dunn and basically said that he wasn't going to doanything abo ut the omission - that it happened all of the time and they (Th e O rangeCounty R egistrar's Office) catch repeat registrations from their database. Mr. Berardinodid not say how that Orange County Registrar processes registrations when someone isnot in the California sfete H AVA database and tiiey do not have a California ID - that thisis how mu ltiple state voting fraud occurs. Mr. Berardino did say tiiat Orange C ountyRegistrar does not co n ta d affiants that have left tiie prior registration ( Se dio n 16) blank .

FOURTH CAUSE OF ACTIONDefendante B owen, Kelley. Dunn, Brown A d C ontrary fe Public P olicy/Interest80. Plaintiff realleges ea ch and every allegation confeined in the above paragraphs 1

ttirough 76 with the same force and e ff ed as thoug h herein set forth at length omite it forbrevity.

81. That Defendante Bowen as a member o fth e EAC with responsibilities and dutiesunder HA VA to create, mainfein and safeguard the "Nationa l" Vote r registrationdafeba se in Florida. Texa s, Arizona a s well as Califomia that is centralized by the EA Cfor each S fete's dafebase which is available to Defendant Kelley along with ttioseofficials similariy situated under Califomia Code (that has incorporated both tiie NVRA.HAV A and VRA ) have failed in their ministerial duties. Defendant Brown was noticedwith Dun n's attempt to concea l his Califom ia voter registration fraud (Exhibit C ) , andinstead of starting a criminal investigation of D efendant Dunn h e ignored the fraud an dthen m isinterprete Califomia Election Law with a Judicial Notice filed with the court.

82. That in regard to Defendant Dun n, Defendante B rown, Bowen an d Kelley havecommitted egregious commissions in support of Defendant Dunn's voter fraud and have



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ad ed ultra vires as affiliated Califomia Party Members In interference with the intemalaffairs of the Califomia Republican Party and Plaintiff along with those similariy situated.

83. Plaintiff alleges ttiat Defendante Bowen, Kelley, and Brown's eilure o ascertainttie State of Mr. Dunn's prior registtation and serious acte and omissions, especially inlight of the complainte filed first by Dr. Taitz and then by Plaintiff a d contrary to CECand public policy and is a breach of public trust causing serious disenfranchisement andharm to the integrity of Califomia eledions as well a real monefery hamn to S.O.S. GOPcampaign contributors which was p radically sanctioned by the state agendes of theDOJ and the SOS under the leadership of Defendant Brown and Defendant Bowen.

84. In regard to the 2008 Presidential election, Bowen was notified of potential fraudcommitted by the campaign of Barack Hussein Obama on the voters of CalifomiaDecemt)er 8, 2008, and Bowen failed to follow the Voter Complaint guidelines (ExhibitP) of the HAVA Compliance Manual as Plaintiff never received a "final determination" asrequired by law.

85. Plaintiff followed up March 2010 (Exhibit I) and receh/ed a letter sfeting thatBowen did not have to investigate the qualifications of P residential candidates. Bowencompletely ignored the affidavite filed in various courts from document experts thatoutiined the fraudulent elements of Obama's online posted "Hawaii Certification of LiveBirth". This online Obama "birth document" creation was used as "pro of by Obama'scampaign to persuade Califomia voters as well as voters across the nation that Obamawas bom in the United States which is one of the requiremente of being a Natural BomCitizen virfiich is required by Artide II. Sedion 1, Clause 5, of ttie U.S. Constitution to bePresident. American case law, as well as Senate Resolution 511, requires both parents



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Case2:10-at-G.-.01 Document 1 Filed 08/17/10 age 30 of 134to be American citizens at the time of the child's birth. Plaintiff had also requested aninvestigation into whetiier Obama met ttie definition of a Natural Bom Citizen, butBowen, to reiterate, daimed no responsibility to vet the qualifications of Presidentialcandidates tiiat she allowed to be included on the 2008 California e ledion balfet.

86.That as a pattern of Debra Bowen covering up fraud. Dr. Oriy Taitz, candidate forSecretary of State, told Plaintiff that when Dr. Taitz reported fraud problems wit ii BarackHussein Obama's Constitutional eligibility a year and a half ago. Defendant Bowen andor agents were supposed to call Dr. Taitz back and schedule an administtative hearingand never did.

87. That Bowen instead of doing her job to investigate potential election fraud thatwas reported to her office by Dr. Taitz, she instead effedlve ly calls Dr. Taitz, aconcemed qualified Califomia voter, a "conspiracy theorisf in a fundraising email to hersupporters. (Exhibit F) That comments like these give true insight into what's imporfentto Bowen and prosecuting potential voter fraud does not seem to be on her list ofpriorities as SOS.

88. Plaintiff filed a criminal complaint against Defendant Bowen with DefendantBrown's Department of Justice, to ask for an investigation Into Bowen for ignoring andeffedively covering up Obama's birth document fraud, and Defendant Brown's officenever contacted Plaintiff to let her know tiia t an investigation was done or wasplanned.Consequently, we have another sfete agency under ttie control of Defendant Brownignoring potential voter fraud and with Brown acting ultra vires to t)enefit the Democratparty.



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Case2:10-at-0,^Jl Document 1 Filed 08/17/10 . . g e 31 of 134FIFTH CAUSE OF ACTION

Defendante Bowen and Kelley Ad ed with Undue influence in that Itefendant DunnMalidously Violated CEC 2150 (a) (10) / (b) witti ttie NVRA / HAVA and related iaw89. Plaintiff realleges each and every allegation contained in the above paragraphs 1through 74 with the same force and e ffed as though herein set forth at leng tii omits it for

brevity.90.That Defendants Bowen and Kelley aded witti undue infiuence against ttie

candidacy of Dr. Taitz and Plaintiff in that Defendant Dunn Malidously Violated CEC8001 with CEC 2150 non-compliance witfi NVRA / HAVA and related law, favoringthe Campaign of Defendant Dunn while damaging the campaign of Dr. Taitz to includePlaintiff and tfiose similariy situated.

91. Plaintiff alleges that Defendants Bowen, Kelley and Dunn's actions constitute aviolation of California Civil Code 2150 (a) (10) / (b), 2153, 2154 as apply to 8001with NVRA / HAVA and related law in that Defendante Bowen and KelOey acted with Mr.Dunn (Defendante) after March 13.2009 and especially after November 5, 2009 at alltimes mentioned herein with explicit knowledge of the law and a d w ith malice in regardsthe [Declaration of Candidacy Dr. Taitz and those affiliated with the Republican Party.

92. That as a pattem. Dr. Taitz told Plaintiff that when Dr. Taitz reported fraud andother eligibility issues regarding Barack Hussein Obama a year and a half ago,Defendant Bowen and or agente were supposed to cali Dr. Taitz back and schedule anadministi ative hearing and never did.

93.That gn November 17,2009, community organizer Damon Dunn candidate forthe Republican nom ination for Califomia Secretary of State was inten/iewed by BryanSuite at 7:30 PM on KFl AM 640 (http://ittjnes.apple.conn/us/podcast/kfi-am-640-bn/an-

http://ittjnes.apple.conn/us/podcast/kfi-am-640-bn/anhttp://ittjnes.apple.conn/us/podcast/kfi-am-640-bn/an


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Case2:10-at-c .01 Document 1 Filed 08/17/10 age 32 of 134I suits/id2726901961, during the inten/iew stated he: "Cast flrst vote May 2009" is a "ragsto ichesdemoaat story.." "Family vote as democrat.." The Sentinel Newspaper anAfrican America newspaper... community service is my entire life...Make a WishFoundation...ttie Latino Education Attainment Initia tive..." and as for his own family inTexas when asked "why are they stiii living in tiie traile r? " said "teach ttiem to fish.." atStanford his Mentor "is Condoleezza Rice at Stanford University" and when asked as tohis ability to w in he said "Barack Obama got record numbers of people to vote forhim....people follow people not parties..."

94. That on January 11.2010 Defendant Dunn was inten/iewed (see Exhibit E l byMark DeVaughn a contiibuting writer at the Bootieg or\ Scout.com w th FoxSporte.comoutiet who reported that Mr. Dunn as saying:

On non-football topics, Dunn speaks in excited and vibrant tones. Diversepo litical heroes include Martin LutiierKino. Barack Obama and Govemor PeteWilson. He remains a political novice, having never run for office pre\^ousiy. Hefirst registered to vote as a Democrat a decade ago but never adua liy went to thepolls until May of 2009. As he told tfie Los Angeles Times, "Who better to reach anon-voter than a recovering non-voter?" (Emphasis added by Plaintiff)95. On or about March 16.2010, the authorized Campaign for Defendant Debra

Bowen sent a campaign contiibution solicifetion throughout the Sfete atfecking Dr. Taitzas a fringe member of the Califomia Republican Party (see Exhibit Fl and therein defersto tiie "wealthy developer" Defendant Dunn as if a mainstream "right-wing" RepublicanParty candidate on the primary ballot and after Defendant Bowen was notified Mr. Dunnlike Barack Hussein Obama is also ineligible to run for office in the solicitation states:

As you know, wealthy developer Damon Dunn, who says he got into ttie race atKari Rove's urging, is also running for the Republican nomination. Whoeverprevails m the primary MUST be taken seriously t)ecause of ttieir ab ility to raisemoney and d istort the Issues through their national ight-wingnetwortcs.

http://scout.com/http://foxsporte.com/http://foxsporte.com/http://scout.com/


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Case2:10-at-0.^J l Document 1 Filed 08/17/10 .. .g e 33 of 134

Please contribute today to help Debra sfend against rightwing kleolog ues likeOriy Taitz. and continue sen/ing the people of CaiifomiaiOrly Taitz' candidacy wou ld be am using if it weren 't so serious. Her prima ryreason for running is to challenge President Obama's dtizenship and invalidatethe 2008 election. In f a d , Taitz has sued Debra twice to try to invalidate Obam a'svictory.W e ca n t let fringe conspiracy theoriste use ttiis office to get a foot in the door andundermine our demo cracy.Debra's opponents are well con ne ded , and have ttie abil ity to raise large sum s ofmoney from across the country. We must make sure she has the resources tobeat them .Please contribute today to help Debra sfend against right-wing ideologues likeOriy Taitz, and continue sen/ing the people of California!W e can't underestimate the im portance of this race. Th e Secretary of Sfete is theone person in sfete gove mm ent w ho is responsible for the integrity of our21 I ele dion s. As we saw in Florida in 2000 and in Ohio four years later, we need22 I public sen/ants we trust in this position, not people with a political age nda .Debra has long sen/ed the people of Califomia with integrity. We need her in theSecretary of State's office, not a conspiracv the orist like Oriy Ta itz.

96. However, contrary to the authorized Bowen Cam paign Statement shown asExhibit F as to Defendan t Dunn that wa s released on or about M arch 16 , 2010 a nd thatcoin dde d with the release oft i ie Friday March 5,2010 Democrat love-fest inten/iew ofDefendant Dunn and Defendant Bowen on ti ie Califomia Focus Syndicated Column, atwice-weekly syndicated newspaper column on Califomia public affairs, by Thomas D.Elias in his article "A Down-The-Ticket Rac e Witit Two Likelv W inner^ (see Exhibit G lreported Defendant D amon Dunn saying of IDefendant Debra Bowe n that:

"She gete credit for restoring som e integrity to the process ," Dunn said in aninten/iew, refemng to Bowen's review of electtonic voting machines and theresulting retijm to large-scale use of paper ballots. In fa d , she gets so m uchcredit that as of eariy March, Dunn was tfie only dedared Republican candidaterunning against her. There wa s stili a possibility that another m ight jum p in: OriyTaitz, another Orange Co unty figure who is a leader of the "birther" m ovem entthat questions whe ther President Obama is eligible for his job .First Am ended Co mplaint Page 26 of 39


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Case2:10-at-0.^J1 Document 1 Filed 08/17/10 . ^ g e 34 of 134

But Dunn, the oniy Republican now campaigning, enthusiastically andunequivocally says h e will win this fall and becom e Califom ia's first African -American statewide officeholder since Men/yn Dymaliy was lieutenant govemorin the late 1970s.An d further in tfie article, Mr. Elias continues to report tfie rebuttal of Defendant Bowenfrom his inten/iew with her saying that:

"One thing Bo wen doesn't buy is the notion that Du nn's candidacy is the productof a plot devised by Republican sttategist K ari Rove, long the chief politicaladviser to former President George W, Bush, for tfie GOP to take control of thenational eledio n process at the sfete level.Bow en scoffs at tiie idea of a Rovian plot. "I'm not much for conspiracy th eories,"she said. "Bes ides. I don't think Kari Rove wo uld exactiy be an asset inCalifomia."

97. That it is in Defenda nt Bo wen's b est interest to run against a Repu blicanoppon ent D unn who h as eligibility issues regarding being on the ballot legally.

98.Th at D efendant Dunn and Bowen have woriced together in complementing ea chothers' campaigns so m uch as to suggest that Defendant Dunn is a D emocrat P artyplant to ensure that Bowen remains Secretary of Sfete of the state with ttie m ostele do ral votes in the country.

99. Defendant Bowen has no opponents in the Dem ocratic Primary June 8, 20 10 .100. Defendant Bow en chose to take sides and interfere into the intema l

campaign of the two candidates for the Republican Party nomination Defendant Dunnand O riy Taitz.

SIXTH CAUSE OF ACTIONDefendant Bow en, Brown. Kelley Breach of Fidudary Duty

101. Plaintiff realleges each a nd every allegation contained in the above p aragraphs 1through 119 with the same force an d ef fe d as ttiough herein set fortti at lengtti om its itfor brevity.

First Amende d Com plaint P age 27 of 39


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Case2:10-at-C _01 Document 1 Filed 08/17/10 age 35 of 134

102. That in regards to tfie Eldridge V. Cleaver ballot removal case (Cleaver v. Jordan(1968) 393 U.S. 810) in which he was removed from tfie ballot by ttie then CA SOS, theCalifornia Secretary of State as the Chief elections officer of Califomia (CEC 12172).

4 This duty requires that Bowen oversee all elections in the state and ensure that noelection law is violated. In order to fulfill tiiis duty, tiie Secrefery of State websitecontains information for all persons seeking eieded office, in particular the requirementefor eligibility that must be met in order to qualify for the ballot. This also includesinformation for presidential candidates.(http://www.sos.ca.gov/eledions/election 2008/gualifications/wi ores nov2008.Ddfl.This information sheet includes the three requiremente for e ligibility under U.S. Const.Artide 11, Sedion 1, Clause 5 , which are (1) be a natural bom citizen of ttie UnitedSfetes, (2) be at least 35 years of age, and (3) be a resident of the United Sfetes for atleast 14 years. Unless these requiremente are merely placed on the infomiation sheetfor the sole purpose filling space in the document, it is reasonable to infer tiiat theSecrefery of State should verify that a Presidential candidate meets said requirementsbefore pladng that candidate on the ballot, since the Secretary of State is under a dutyto verify the eligibility of all those who run for any state office as well as those who runfor the United Sfetes Congress. In f ad , the Secretary of State not oniy has such a dutyto verify the eligibility of a Presidential candidate, prior Secrefery of States haveexercised this duty, in 1968, Eldridge Cleaver ran for President of the United States onthe Peace and Freedom Party ticket, but was removed by then Secrefery of Sfete,Frank M. Jordan. Eldridge Cleaver did not meet tiie minimum age requirement for theoffice. Eldridge Cleaver challenged his removal, which was upheld by CalifomiaSupreme Court, whose dedsion was affimned by the Supreme Court of the UnitedSfetes, who reftjsed to review the decision (Cleaver v. Jordan {19681393 U.S. 810).

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Case2:10-at-0._01 Document 1 Filed 08/17/10 age 36 of 134

Finally, even if this remedy is not availabie for application to the 2008 PresidentialEledion, it is available for a il future e ledions and it is witiiin the power of ttiis Court tocompel the Secretary of State to perform this duty. Thus, the Secrefery of State shouldbe compelled to verify the eligibility of all fotu re presidential candidates on the Califomiaballot.

103. Plaintiff a lleges that Defendant Brown's inaction constitutes a v iolation ofCalifornia Civil Code 18501 in effect is aiding and abetting Defendant Dunn andBowen when Bowen aded with a con flid of interest in regards to the incompleteRegistration shown as Exhibit A as to the prior registration address in F lorida whicheffeded the intent of Candidacy filed after November 5,2009 shown as Exhibit B andDeclaration of Candidacy filed after February 24,2010 shown as Exhibit K.

104. On April 2, 2010, Plaintiff complained to Defendant Brown of Defendant Bowenwho had responded on March 23, 2010 to the complaint shown as Exhibit H in thematter of the ineligibility of Barack Hussein Obama specifically a to the forensic proof ofthe fraud proven done by Mr. Obama and or his agente for the dedaration w ith CEC8001 for ballot access to the November 2008 General E ledion (see Exhibit I)

105. Defendant Bowen ad s under color of CEC 8800 without fulfilling the ministerialduty to investigate the fraud or filing a Judidal ad ion to remove [Defendant Dunn.

106. Defendant Brown has not responded to the filing shown as Exhibit I.107. That Defendant Brown was aiso served with the charge against Defendant Dunn

and Defendant Bowen in tiie matter of the November 13,2009 filing of tiie Declarationshown as Exhibite A,B, and C as a violations of the NVRA and HAVA.

108. That Plaintiff on May 3,2010 faxed a complaint ietter witti attachmente to t tieCalifomia Board of Election Chief and followed up w ith a trip to the Office and requiresexpedited handling by the Court herein; see a copy of Plaintiffs cover letter with fax



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Case2:10-at-0 al Document 1 Filed 08/17/10 ge 38 of 134a Declaration of Candidacy for Defendant Dunn located at 3131 Michelson Unit708W In/ine CA 92612 pursuant to Eledions Code Section 200 .8020 and 8040.certified it on March 10,2010 and iledon March 15 ,2010 by Defendant Bowenbased upon the March 13 ,2009 iniproperiy executed Voter Affidavit ofRegistration shown as Exhibit A for ttie Republican Party Direct Primary Electionto be held June 8,2010 (see Exhibit K).

113. Because the Registtation shown as Exhibit A is Fraudulent until Mr. Dunnamended a properiy executed Affidavit of Registration to Vote in 2010, the November 5,2009 Intent for Candidacy shown as Exhibit B is null and void abng with the March 15,2010 filed Declaration of Candidacy in that Mr. Dunn had not been affiliated witti theCalifomia Republican Party for 3 montiis required with 8001(a) by the amendment.

114. That on page two of the Declaration of Candidacy shown as Exhibit KRespondent Dunn and or the Notary / agent of Neal Kelley Registrar of Voters affirmedin the BOX provided for prior registration that as to Party Affiliation "No PriorRegistratiorf existe; and

115. That on March 15,2010, the time stamp shows that Defendant Bowenand or her agent deputy filed the Certified Dedaration of Candidacy shown on Exhibit Kfirst page.

116. That on March 30,2010 Duval County Supennsor of Elections JerryHolland wrote a letter to Mark Loren Chief Investigator of tiie Election Fraudinvestigation Unit of Secretary of State that confirmed Mr. Dunn had a prior registtationat 10135 Gate Partway, North #1111, Jacksonville Florida (see Exhibit L).

117. That after May 12,2010 Plaintiff received a letter from Marie Loren Chief



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confirmed Mr. Dunn had a prior registtation in F lorida and admitted that Mr. Dunn was innon-compliance witfi CEC 2150 (a) (10); however alleged that without evidence tfieomission was intentional no criminal sanctions for non-compliance exist (see Exhibit M l.

118. That according to Exhibit A, Mr. Dunn intentionally left the Section 16 blank toconceal the prior registtations in both Texas and Florida in conjundion w ith his intendedcandidacy for CA SOS and lied in ttie affirmation by using "March 15,1976".

119. That according to Exhibit C Defendant Dunn attempted to spoliate his registrationrecord in Florida and Texas in conjunction with his candidacy for CA SOS; and basedupon Infomiation and belief Mr. Dunn was successful in expunging the registt'ationrecord in Texas to no avail did tum up in the background check shown as Exhibit J-1that had been sent to Marie Loren Chief Investigator of the Election Fraud investigationUnit of tiie Secrefery of Sfete Office.

120. That according to Exhibit K page two, Defendant Dunn lied under oath taken byDefendant Kelley or his agent had "no prio r registraO'ori' based upon the March 13, 2009improperiy executed Voter Affidavit of Registration shown as Exhibit A.

121. That the evidence referenced in above paragraphs 94 through 103 is dear andconvindng evidence indicating that the crime is proved as highly probable or reasonablecertain for CEC 18203 and 18500 sanction of Defendant Dunn by Defendant Bowenand Defendant Brown.

122. That according to CAL. ELEC. CODE 18203: Any person who files or submitefor filing a nomination paper or declaration of candidacy knowing that it o r anv part o f ithas been made falseJv\s punishable by a fine not exceeding one tiiousa nd dollars($1,000) or by imprisonment In the state prison for 16 months or two or three years or by



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both the fine and imprisonm ent. (Em phasis by P etitioner)123. That accordingly to CAL. ELEC . CODE 18500: Any person who commite fraud

or attempte to comm it fraud, and any person wh o aids or abets fraud or attemp ts to aidor abet fraud, in eonn edio n w ith any vote cast, to be cast, or attemp ted to be cast, isguilty of a felony, p unishable by imprisonm ent for 16 monttis or two or three ye ars.

124. That Defendants D unn, Kelley and Bowen along with those yet namedmaliciously concealed and en tered false statements into the pu blic record with intentionof fraudulentiy obtaining votes.

125. That accordingly to CAL. ELEC . COD E 18501: Any public offidal whoknowingly violates any of the provisions of this chapter, and thereby a ids in any way tiieillegal casting or attemp ting to cast a vote , or wh o connives to nullify any of theprovisions of this chapter in order that fraud may b e perpetrated, shall forever bedisqualified from ho lding office in this state and upon conviction shall be sentence d to astate prison for 16 months or two or three years.

126. That Defendant Kelley and Bowen along with those public officials yet namedhave ma liciously breache d tiie fidudary du ty to aid and abet tiie violation of law tofurther concea l and enter false statemente into the public record with Intention offraudulentiy o bfeining votes othennrise a d individualiy by ultra vires,.

127. That based upon the foregoing series of complainte and response by DefendantBowen, shown a s Exhibit M, Ms . Bowen ha s not only a conflict of interest in this ma tterbut fails to adhe re to her fiduciary duty, is an admission against interest.

128. Inreparable harm to Plaintiff along witti those similariy situated include s: (i) thedenial of Repu blican Party voters an accurate ballot and represen fetion according to thelaw; (ii) the denial of an honest trustworthy S OS on tfie ba llot for ttie G eneral Voters a t

First Amende d Com plaint Page 33 of 39


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Case2:10-at-0,-.j1 Document 1 Filed 08/17/10 .ge 41 of 134the Election were Mr. Dunn somehow to defeat SOS Candidate Orly Taitz at theRepublican Primary; (iii) Republicans were solicited by Defendant Dunn for funds underfalse pretenses and (iv) cause tfie need for launching a petition effort for an independentcandidate ballot access were Dr. Taitz, who is the oniy qualified d edared candidate forthe Republican candidacy for the SOS.

129. After March 30,2010 and at all imesmentioned herein Defendant Kelley andBowen have explicit knowledge of tiie Dunn non-conformance w ith the law and with ttiemalice involved induding the spoliation and attempt to spoliate public records.

130. That as to a pattem of Defendant Bowen's negled of duty espedally as tocandidate eligibility matters ttie prior Califomia Secretary of State Kevin Shelleyintention to enforce the presidential candidate requiremente going into tiie March 2,2006 Primary (see Exhibit Ql: whereas Defendant Bowen did not make such a pledgeand when Plaintiff challenged tiie Nattjral Bom Citizen status of Democratic CandidateObama as in the L ightioot et a l VBowen case. Defendant Bowen ariDitrariiy refosed toact as was done by previous Califomia Secreferies of Sfete as with Cleaver v. Jordan(1968) 393 U.S. 810.

131. That in September 2009 Defendant Bowen issued a Fraud Document ProtectionHandbook (see Exhibit Rl: that at page 4 a question as to answered the question as tothe significance of a "Driver's License" as to tfie domicile of residence:"I own a home on the coast that is three hours from my job in the city. I also own atownhouse in the city where i reside during the week, but I retum home on theweekends to be with my family. From which residence address am I legally entitied toregister and vote?in this type of situation, the dedsion as to where you register and vote is up to you, butyou must choose one. Generally vour domicile isyA\exe your family lives, where youphysically reside, the place you intend to retum to whenever youare gone from it, wherevour driver's license savs vou reside, where you daim your homeowner's property fexexemption or renter's fex credit,etc. (EC 349, 2020-2034)"

First Amended Complaint Page 34 o f 39


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132. Plaintiff alleges tiiat Defendant Kelley and Bowen's ad ion s constitute a violationof Califomia C ivil Code 18501 in that Defendant Kelley and Bowen aded with a conflictof interest after November 13,2009 at all times mentioned herein under color of law withexplicit knowledge of tfie law with malice when after itwas shown tiiat the DefendantDunn's Voter registration form shown as Exhibit A was incomplete as to his priorregistration address in Florida which effected ttie Intent of Candidacy filed afterNovember 5, 2009 shown as Exhibit B and Dedaratton of Candidacy filed after February24,2010 shown as Exhibit K.

133. That based on infomiation and belief the SOS office under the leadership ofDebra Bowen has advised Califomia registrars that follow-up does not need to be takenon registration forms where the prior registtation section is blank.

134. That Bowens Fraud Handbook advises affiants basically to not worry if tieydonot fill out or attempt to fill out prior registration information. (Exhibit R)

135. That Kelley as Orange County Registtar has a h istory of withholding informationwhen he had a fidudary du

barnett v dunn, et al. (state court cali) - notice of removal to federal court - defaultdms

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