Plead Paper Flow BK Pleading Paper Statement Disqualification Cramin

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Antoine Bacha 25 Auvergne Newport Coast, California 92657 Telephone Number: (949) 887-9073 In pro se
SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF ORANGE, SOUTH HARBOR JUSTICE CENTER
PD PROPERTY INVESTMENTS Plaintiff, vs.
LLC
ANTOINE BACHA; and DOES I TO V inclusive, Defendant(s).
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) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )
Case No.: 30-2011-00489164 VERIFIED STATEMENT OF DISQUALIFICATION UNDER THE AUTHORIZATION OF SECTION 170.3 OF THE CODE OF CIVIL PROCEDURE OF THE STATE OF CALIFORNIA
TO CLERK OF THIS COURT AND TO ALL PARTIES TO THIS ACTION. Antoine Bacha files this disqualification for cause under the
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VERIFIED STATEMENT OF DISQUALIFICATION UNDER THE AUTHORIZATION OF SECTION 170.3 OF THE CODE OF CIVIL PROCEDURE OF THE STATE OF CALIFORNIA.
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Authorization of Section 170.3 of the Code of Civil Procedure of the State of California. This statement is based on the attached points and authorities, the attached declaration, attached exhibits, and the complete file and records of Case Number: 30-2011-00489164
Dated:
February 2, 2012
____________________________ Antoine Bacha In pro per
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POINTS AND AUTHORITIES

Before 1984 Section 170 of the Code of Civil Procedure of the State of California was based on an actual bias/ bias in fact. After 1984 the Section
170.1 was amended by the Legislature to add Section 170.1(a)(6)(C). Section 170.1(a)(6)(C) of the Code of Civil Procedure of the State of California provides: A person aware of the facts might reasonably entertain a doubt that the judge would be able to be impartial. In Catchpole v. Brannon (1995) 35 Cal.App.4th 237 [42 Cal.Rptr.2d 440] to determine the appearance of bias and partiality, the court applied the Canons of the Code of Judicial Conduct as the objective test to make that determination. In Rose v. Superior Court, (2000) 81 Cal.App.4th 564, 96 Cal.Rptr.2d 843, the court reversed the trial court on the ground of appearance of partiality where the trial judge inter alia disregarded an appellate order to conduct a hearing on a habeas corpus petition, denied the petition without a statement of reasons, and filed its own return to the appellate court's subsequent order to show cause, thereby assuming the appearance of an adversary rather than a neutral. Canon 2, Subdivision A. of the Code of Judicial Ethics, Appendix, Division II, Rules of Court of the State of California provides: A judge shall respect and comply with the law* and shall act at all times in a manner that promotes public confidence in the integrity and impartiality of the judiciary. Canon 3, Subdivision B. Paragraph (2) of the Code of Judicial Ethics, Appendix, Division II, Rules of Court of the State of California provides: A judge shall be faithful to the law* regardless of partisan interests, public clamor, or fear of criticism, and shall maintain professional competence in the law.*
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In Oberholzer v. Commission on Judicial Performance (1999) 20 Cal.4th 371, 398 [84 Cal.Rptr.2d 466], the Supreme Court of the State of California held, a judge who commits legal error which, in addition, clearly and convincingly reflects bad faith (Broadman v. Commission on Judicial Performance, supra, 18 Cal.4th 1079, 1091-1092), bias (Kennick v. Commission on Judicial Performance (1990) 50 Cal.3d 297, 327-331 [267 Cal.Rptr.293, 787 P.2d 591, 87 A.L.R. 4th 679]), abuse of authority (Spruance v. Commission on Judicial Qualifications (1975) 13 Cal.3d 778, 786-795 [119 Cal.Rptr. 841, 532 P.2d 1209]), disregard for fundamental rights (Kloepfer v. Commission on Judicial Performance, supra, 49 Cal.3d 826, 849-854), intentional disregard of the law (Cannon v. Commission on Judicial Qualifications, supra, 14 Cal.3d 678, 695-698), or any purpose other than the faithful discharge of judicial duty (Ryan v. Commission on Judicial Performance (1988) 45 Cal.3d 518, 545-546 [247 Cal.Rptr. 378, 754 P.2d 724, 76 A.L.R 4th 951]), is subject to investigation In Cannon v. Commission On Judicial Qualifications, 14 Cal.3d 678, pp. 694-695, 537 P.2d 898, 122 Cal.Rptr. 778 (Cal., Jul 10, 1975) the court stated, Petitioner completely ignored proper procedures in punishing for a contempt committed in the immediate presence of a court, as provided in Code of Civil Procedure section 1211. [FN15] This, without more, constituted an act of bad faith in each instance. Petitioners explanation that she cannot be deemed to have failed to comply with section 1211 because that section does not provide a time when the order is to be made is without merit. (See In re Jones (1975) 47 Cal.App.3d 879, 881 [120 Cal.Rptr. 914].) It does not appear in any instance that petitioner made any effort to make a proper order at any time at or after the time the attorneys were cited. (4) Compliance with section 1211 is a jurisdictional requirement, and an order which assumes to punish summarily a direct contempt of court is void unless it shows on its face facts sufficient to constitute a legal contempt. FN15 Section 1211 provides in pertinent part: When a contempt is committed in
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the immediate view and presence of the court, or of the judge at chambers, it may be punished summarily; for which an order must be made, reciting the facts as occurring in such immediate view and presence, adjudging that the person proceeded against is thereby guilty of a contempt, and that he be punished as therein prescribed. Arthur v. *Superior Court, supra, 62 Cal.2d 404, 409.) Petitioner was an experienced judge, with more than nine years on the bench before the Ridgeway matter, and she had at hand reference works which dealt with proper contempt procedures. (Cf. Spruance v. Commission on Judicial Qualifications, supra, 13 Cal.3d 778, 800-801.) *695 The term bad faith implies that the judge intentionally committed acts which he knew or should have known were beyond his lawful power. (Citation.) As so used, bad faith entails actual malice as the motivation for a judges acting ultra vires. The requisite intent must exceed mere volition; negligence alone, if not so gross as to call its genuineness into question, falls short of bad faith. Bad faith also encompasses acts within the lawful power of a judge which nevertheless are committed for a corrupt purpose, i.e., for any purpose other than the faithful discharge of judicial duties. In sum, bad faith is quintessentially a concept of specific intent, requiring consciousness of purpose as an antecedent to a judges acting maliciously or corruptly. (Spruance v. Commission on Judicial Qualifications, supra, 13 Cal.3d 778, 795--796, 119 Cal.Rptr. 841, 853, 532 P.2d 1209, 1221.) The foregoing record compels the conclusion in the instant case that petitioners primary concerns were first to inflict a completed punishment before the deputies were afforded a due process determination that punishment was warranted and, second, to accomplish her objectives in a manner to insure that such conduct would be insulated from judicial review and collateral attack. It is manifest that such a planned subversion of justice and misuse of the judicial power could be undertaken only in bad faith. I refer to and incorporate the Order Striking Challenge for Cause And Verified Answer of Judge Corey S. Cramin filed on January 26, 2012 a true and correct copy is attached hereto as Exhibit A, and incorporated herein by this reference.
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At P. 4,
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line 3, Corey S. Cramin makes a false statement of law, quotes and falsely attributes as the authors statement in Rothman in California Judicial Conduct Handbook, A judge is not disqualified simply because a participant in a cased complains to the Fair Political Practices Commission while proceedings are pending, See Rothman, California Judicial Conduct Handbook 7.60 citing California Judges Association, Judicial Ethics Update (2001) p.4 I refer to and incorporate Rothman, California Judicial Conduct Handbook 7.60 at p. 372 a true and correct copy is attached hereto as Exhibit B and incorporated herein by this reference. Rothman states A judge is not disqualified in a matter where an attorney has complained to the Commission on Judicial Performance about the judge, 285 unless the judge is actually biased against the lawyer of the party as a result of the actions. Making false statements of law, by falsely attributing statements by an author is engaging in bad faith willful misconduct due to intentional disregard of the law in this pleading and a predetermined disposition to rule against the movant. In Webber v. Webber, 33 Cal.2d 153, 155, 199 P.2d 934 (Cal.,Dec 03, 1948) the court stated, Plaintiff commenced this action for divorce on the ground of extreme cruelty. Defendant answered and filed a cross-complaint, but at the trial he offered no evidence in support thereof. Plaintiff was awarded an interlocutory decree of divorce, the custody of the seventeen-year-old son of the parties, and one-half of the community property, consisting of $50 of postal savings bonds. She has appealed from the interlocutory judgment, directing her complaint to those portions' thereof which denied (her) * * * provision for her support and maintenance and * * * attorney's fees for prosecuting said action, as * * * prayed for. As her principal ground for reversal, plaintiff claims that the trial court committed prejudicial error in denying her a fair trial on these specified issues. [1][2][3] Whether or not the error complained of has produced substantial injury to the appellant is always a proper question for consideration upon appeal. Peters v. Peters, 156 Cal. 32, 37, 103 P. 219, 221, 23 L.R.A., N.S., 699; see, also, Arnold v. Arnold, 76 Cal.App.2d 877, 880, 174 P.2d 674. While a judgment should not be reversed unless, after an examination of the entire record, it appears that the alleged error has resulted in a miscarriage of justice (Calif.Const., art. VI, sec. 4-1/2), such is the situation here as evinced by the declared attitude of the trial judge during the presentation of plaintiff's case. So pertinent is the following language from Pratt v. Pratt, 141 Cal. 247, at page 252, 74 P. 742, at page 744:
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At the trial of the case, The following colloquy then ensued: The Court: They do not deed to waive alimony. The Court will waive it for them. Mr. Murstein (plaintiff's counsel): What is that, your Honor? The Court: I say they do not have to waive it; the Court will waive it himself. Mr. Murstein: This woman has been married for 37 years: I think she is entitled to be supported. The Court: Go ahead and wash your dirty linen. I won't stop you. A short time later in declaring adjournment for the day, the court stated: All right; we will continue washing the *157 dirty linen tomorrow morning * * * I will instruct all witnesses in this case to return tomorrow at 10:30, and I think after that I will exclude the witnesses. There is no necessity of having them listen to the washing of the dirty linen. The next day plaintiff resumed her testimony, directed to the issue of support and maintenance as correlated with her estimate of necessary expenses' for living and medical needs, **but the court kept complaining of the waste of time. Later in the proceedings when plaintiff's counsel, concerned with (the matter of) support for the plaintiff, expressed the desire to recall her to the witness-stand, **the court stated: I have told you that I am not going to award any support. I have told you that several times * * * I wish you would please stop wasting the Court's time. Defendant rested his case without putting on any evidence, (Webber v. Webber, supra, 33 Cal.2d at p. 156) And the court stated, In these circumstances it was vitally important to plaintiff that she be accorded the fullest opportunity to convince the trial judge of the propriety of some allowance for her support and maintenance. But instead, plaintiff was faced with the handicap of his predetermined disposition of that issue regardless of what her proof thereon might be. Thus at the time of his announcement that he would waive alimony on behalf of plaintiff, **the trial judge had heard plaintiff's case only to the extent of testimony from defendant (Code Civ.Proc. sec. 2055) on the issue of his ability to pay, and her own recital of the acts of cruelty on which she based her divorce, as well as reference to her meagre receipts from her own industry since the parties had separated. He then did not know what would be the nature of plaintiff's showing as to her needs and health condition as affecting the vital point of a suitable support allowance, and he had no right, in advance of hearing her testimony, to formulate a fixed concept on that phase of her case (Webber v. Webber, supra, 33 Cal.2d at p. 158) In Peacock Records, Inc. v. Checker Records, Inc., 430 F.2d 85, 89, (7th Cir.(Ill.),Aug 06, 1970)The court stated, While the fact that a trial judge has formed opinions based on the evidence at the first trial, does not disqualify him from hearing the retrial of the case, see e.g., United States v. Bolden, 355 F.2d 453, 456 (7th Cir. 1965); Tucker v. Kerner, 186 F.2d 79, 84-85 (7th Cir. 1950), such opinions must be based on direct evidence introduced at the first trial and not based on mere speculation unsupported by the record. Findings by
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a trial judge unsupported by the record are evidence that the judge has relied on extrajudicial sources in making such determinations indicating personal bias and prejudice. Cf. United States v. Grinnell, 384 U.S. 563, 583, 86 S.Ct. 1698, 16 L.Ed.2d 778 (1966). We find nothing in the record of the first trial which is supportive of the judge's determination that the recantation of the three Blind Boys was suborned by the defendants and, therefore, perjured. Lawrence Abram's pre-trial deposition was on behalf of plaintiffs, not defendants, and we find the record of the first trial insufficient to support any conclusion that the subsequent recantation of his testimony was suborned perjury by defendants. In addition, the fact that defendants admitted in the first trial that two witnesses were paid to testify for defendants (Roscoe Robinson and James Clay Jackson) and that Wilmer Broadnax was paid to make a pre-trial sworn statement does not in any way establish the trial judge's finding that three different witnesses (Abram, Clinkscales and Woodard) were paid by defendants to recant their testimony and admit to having committed perjury in open court even after the court had warned them of their constitutional rights and had appointed counsel for them. There is a substantial difference between admissions that witnesses were paid to testify for a party, not indicating whether the testimony was true or false, and evidence supporting a finding that witnesses were paid to admit to having committed perjury. We find such admissions by defendants not supportive of the trial judge's finding that the three Blind Boys' recantations were perjury suborned by defendants. In addition, the trial judge indicated in direct contravention of this court's mandate in Peacock Records, Inc. v. Checker Records, Inc., supra, that he would consider anew in the second trial all the evidence he heard at the first trial, consequently including the testimony at the first trial of the three Blind Boys (Abram, Clinkscales and Woodard). The trial judge indicated his intention to consider the testimony introduced at the first trial despite this court's finding in Peacock Records, Inc. supra, that the sworn statements by the three Blind Boys was unimpeached and clearly supportive of their declaration that perjury was committed at the first trial and should not have been disregarded by the trial judge. Consequently, we hold that defendants' affidavit alleging the trial judge's prejudgment, without any basis in the record of the first trial, that the new testimony by the three Blind Boys was suborned perjury and the trial judge's intention to consider all the evidence of the first trial anew in the second trial in direct violation of this court's de novo remand in Peacock Records, Inc., supra, (thus including the original testimony of the three Blind Boys) indicated whether consciously or not a personal bias and prejudice which renders invalid any resulting judgment in favor of the party so favored. Knapp v. Kinsey, 232 F.2d 458, 466 (6th Cir. 1956). In U.S. v. Garrudo, 869 F.Supp. 1574, 1580, (S.D.Fla.,Sep 09, 1994)The court stated, [5][6] The government next argues that it was technically impossible for Judge Moore to influence the United States Attorney's Office*1581 in New York. Public officials, such as judicial officials, who come under scrutiny by the government are often investigated by the Public Integrity Section of the Department of Justice. The court can accept for the purposes of this decision that any rulings made by Judge Moore in Miami cases could have no impact on the grand jury investigation in New York and/or on Public Integrity investigations in Washington, D.C. However, the inquiry into one's
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ability to influence an investigation is not the inquiry mandated by the law. Section 455(a) does not ask whether it is possible to exert one's influence but instead asks whether one's impartiality might reasonably be questioned. This court finds that an objective lay observer would have questioned Judge Moore's impartiality. [7] Section 455(a) focuses on the appearance of impartiality, as opposed to the existence in fact of any bias or prejudice. The statute does not give a judge discretion as to whether to recuse himself but states that a judge shall disqualify himself in any proceeding in which his impartiality might be questioned. 28 U.S.C. 455(a) (emphasis added). The statute does not allow a judge to disqualify himself if he thinks he could be affected by external matters, such as being close friends with a witness or being under investigation. Rather, the statute tells him to disqualify himself if the public may perceive him, or his rulings, as being affected. See U.S. v. Kelly, 888 F.2d 732, 74445 (11th Cir.1989) (holding that the district court judge should have recused himself as his spouse was a friend of the defense witness' wife). Thus, a judge faced with a potential ground for disqualification ought to consider how his participation in a given case looks to the average person on the street. Potashnick, 609 F.2d at 1111 (1980). Section 455(a) requires judges to resolve any doubts they may have as to whether they should hear a case in favor of disqualification. It seems clear to this court that the average person on the street will believe that if a federal judge is the subject of a pending grand jury investigation, then that individual cannot conduct criminal trials impartially. Any member of the public, upon hearing that someone is a subject of an investigation, is going to believe that the individual is being investigated. In fact, while one is a subject and has not yet been indicted, the public could perceive that there is even more temptation to try to avoid the indictment by using whatever influence possible. After an indictment has been issued, it is too late to try to convince the government not to indict. [8] The parties agree that Judge Moore was the subject of a grand jury investigation as of November 11, 1992. The parties agree that the standard for applying 28 U.S.C. 455(a) is that of the objective lay person. The parties agree that it was appropriate for Judge Moore to recuse himself at some point during the investigation; they only disagree as to when this recusal should have occurred. The government argues that Judge Moore properly recused himself in October 1993 when he was told he was the target of an investigation. The defendants allege that Judge Moore should have recused himself in November 1992 when he was interviewed by the F.B.I. and told he was the subject of an investigation. The issue, thus, is whether 455(a) required Judge Moore to recuse himself at an earlier date. This court finds, for the above stated reasons, that it does. The court will not deal in vague nuances of words and their meanings. Quite simply and quite universally, recusal [is] required whenever impartiality might reasonably be questioned. Liteky v. United States, 510 U.S. 540, , 114 S.Ct. 1147, 1154, 127 L.Ed.2d 474 (1994). When a member of the federal judiciary is under criminal investigation, he should recuse himself from hearing criminal matters, as the public might perceive him to be biased. In Young v. U.S., 316 Fed.Appx. 764 (10th Cir.(Colo.) Mar 12, 2009) The court stated, [3] The second action presents the threshold question of whether Judge Weinshienk should have recused herself from the case because she was a named defendant. Under 28 U.S.C. 455(b)(5)(i), a judge must recuse herself when she is a party to the
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proceeding, and this mandatory provision required Judge Weinshienk to recuse herself from the second action. On February 1, 2012, I delivered a criminal complaint to the Orange County Grand Jury. On January 31, 2012 I filed a Civil Right Cause Of Action against Corey Scott Cramin, Steven D. Silverstein and PD Property Investments ,LLC Case No. CV 12 -875PSG[SHX]. On February 1, 2012 I filed a Complaint For Damages With The County of Orange against Corey Scott Cramin. On February 1, 2012 I filed a letter seeking investigation and the enforcement of crimes against Corey Scott Cramin, Steven D. Silverstein and PD Property Investments.
Dated:
February 2, 2012
___________________________ Antoine Bacha In pro per
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DECLARATION I, Antoine Bacha, declare, if called to testify I could competently testify on the basis of my own personal knowledge. 1. I refer to and incorporate the Criminal Complaint with the Orange County Grand Jury, a true and correct copy is attached hereto as Exhibit A, and incorporated herein by this reference. 2. I refer to and incorporate the Civil Right Cause Of Action against Corey
Scott Cramin, Steven D. Silverstein and PD Property Investments, LLC Case No. CV 12875PSG[SHX], a true and correct copy is attached hereto as Exhibit B, and incorporated herein by this reference. 3. I refer to and incorporate the Complaint For Damages With The County of
Orange against Corey Scott Cramin, a true and correct copy is attached hereto As Exhibit C, and incorporated herein by this reference. 4. I refer to and incorporated Letter seeking investigation and the enforcement of crimes against Corey Scott Cramin, Steven D. Silverstein and PD Property Investments of which true and correct copies are attached hereto as Exhibit D, and are incorporated herein by this reference. And I request the court to take judicial notice under the authorization of Section 451 and 452 of the Evidence Code of the State of California. I declare under penalty of perjury under the laws of the State of California, that the foregoing is true and correct.
Date and Place:
February 2, 2012, Newport Beach, California
____________________________ Antoine Bacha Declarant

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DECLARATION I, Carrie Stand, declare if called to testify I could competently testify on the basis of personal knowledge to the following January 17, 2012 Court Silverstein and Antoine were called by Judge Cramin. The Judge acknowledged Ex Parte motion by Silverstein and Silverstein handed copy of motion to Antoine. Silverstein immediately went into why he called the ex parte. He immediately began speaking about Antoines case being remanded to state court. Silverstein held up a copy of what was supposed to be a copy of the bankruptcy court docket. As he was waiving it in the air he stated he had a copy of the docket remanding the case to state court. At no time did Judge Cramin inspect the document or give Antoine a chance to inspect the document. Judge Cramin did not even bother to look at or inquire as to the document Silverstein was waiving around. Antoine had trouble getting a word in edgewise but he did state that there was NO SIGNED ORDER. SHOW ME AN ORDER. Antoine objected that a
docket was not a signed order. At this time the judge talked about not being clear on the intricacies of rules of orders and federal or bankruptcy judges. But that it did not matter to him because he works off of proposed orders and dockets all the time. Therefore the federal and bankruptcy rules do not apply. Again, Judge Cramin did not even glance at the document Silverstein was holding up nor did he make any positive statement that he checked the docket or confirmed the docket with Pacer. Antoine tried to speak but the judge kept stopping him. Antoine finally did get the judge to acknowledge him and he asked judge to take a copy of his notes that he would be reading from. Antoine mentioned he was afraid his English would not be good enough for the judge to understand. The judge would not look at Antoines notes. The Judge said he could understand him and for him to go ahead and read his notes. Antoine started reading the part challenging the validity of the ex parte being brought before the court. What was the irreparable harm done to PD Investments? The Judge
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shook his head and said no, nothese issues do not apply here.
Antoine continued to
read off his notes. The judge did have difficulty understanding him. He did not say this but you could tell by the way he was straining to hear and understand him. Silverstein then attempted to stop Antoine from stating his rights and case proving there was no remand. Silverstein raised his voice and said Antoine had pulled every trick in the book that Antoine needs to have his day in court. Judge Cramin said Mr. Silverstein I am trying to help you here. The Judge had no apparent interest in anything Antoine said or presented. Antoine then explained the rules of proposed order by Art I bankruptcy judges needing to be signed by an Art III federal district bankruptcy judge before it could actually be issued as an order Antoine finished his argument asking for sanctions against Silverstein for bringing an unnecessary motion before the court. Judge did not even bother to comment. The judge merely looked at Antoine and stated that I set the MSJ for 1/19/2012 instead of 2/2/2012. I declare under penalty of perjury under the laws of the State of California, that the foregoing is true and correct.
Date and Place:
February 2, 2012, Newport Coast, California
_______________________________ Carrie Strand Declarant
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VERIFICATION I, Antoine Bacha am the defendant in the above named action. I have read the foregoing, VERIFIED STATEMENT OF DISQUALIFICATION UNDER THE AUTHORIZATION OF SECTION 170.1 OF THE CODE OF CIVIL PROCEDURE OF THE STATE OF CALIFORNIA and know of the contents thereof. The same is true of my own knowledge, except as to those
matters which are therein alleged on information and belief, and as to those matters, I believe it to be true.
I declare under penalty of perjury under the laws of the State of California, that the foregoing is true and correct.
Date and Place:
February 2, 2012, Newport Beach, California
____________________________ Antoine Bacha, Declarant
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EXHIBIT A,
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EXHIBIT B,
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EXHIBIT C,
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EXHIBIT D,
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PROOF OF SERVICE STATE OF CALIFORNIA, COUNTY OF ORANGE: I reside in the County of Orange, State of California. I am over the age of 18 and a party to the action; my address is 99 Parkcrest, Newport Coast, California 92657. On February 2, 2012 I served the foregoing document described as:
VERIFIED STATEMENT OF DISQUALIFICATION UNDER THE AUTHORIZATION OF SECTION 170.3 OF THE CODE OF CIVIL PROCEDURE OF THE STATE OF CALIFORNIA on the SUPERIOR COURT OF THE STATE OF CALIFORNIA, COUNTY OF ORANGE, HARBOR JUSTICE CENTER, NEWPORT BEACH FACILITY, COREY S. CRAMIN 23141 MOULTON PARKWAY lAGUNA HILLS, CALIFORNIA 92653
STEVEN D. SILVERSTEIN, ATTORNEY AT LAW, BAR NO.: 86466 14351 REDHILL AVENUE, SUITE G TUSTIN, CALIFONRIA 92780
in this action by personal service. And by placing true copies thereof enclosed in (a) sealed envelope(s) addressed as follows I deposited this envelope in the mail at Newport Beach, California. The envelope was mailed with postage thereon fully prepaid I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
____ Carrie Strand__ Type or Print Name
___________________________ Signature

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PD PROPERTY INVESTMENTS Plaintiff, vs.

ANTOINE BACHA; and DOES I TO V inclusive, Defendant(s).

____________________________ Antoine Bacha In pro per

POINTS AND AUTHORITIES

___________________________ Antoine Bacha In pro per

Date and Place:

February 2, 2012, Newport Beach, California

____________________________ Antoine Bacha Declarant

Date and Place:

February 2, 2012, Newport Coast, California

_______________________________ Carrie Strand Declarant

Date and Place:

February 2, 2012, Newport Beach, California

____________________________ Antoine Bacha, Declarant

__ Carrie Strand Type or Print Name

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