Motion-Secondary: WILSON VS COOKSEY

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4 e ee.

1 paca GEARY WILSON

2 | B18 Tampico, Walnut Creek, CA 94598

3 | (925) 270-6017

4 ichaelgearywilson@hotmail.com

5 Le eepeesenere

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8 SUPERIOR COURT OF CALIFORNIA

9 COUNTY OF CONTRA COSTA
10 | MICHAEL GEARY WILSON, (Case Number: MSC19-01816
li Plaintiff, |WILSON’S OPPOSITION TO
n v. IDEFENDANTS’ DEMURRER

[Department: 39
13 | DEBORAH A. COOKSEY (SBN 118197), Tudge: Hon. Edward George Weil
14 ‘LLIE EILEEN MEYER,
15 | DEBRA MASON,
16 | [OANNE DURKEE,
17 | BRIAN LAWRENCE, and.
18 | LINDA MAYO, all in their official and
19 | {ndividual capacities,
20 Defendants.
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12/04/2019
WILSON’S OPPOSITION TO DEFENDANTS’ DEMURRERoOo YN DH PB Ww NY KR

RP xR YR YR RNR BB Be Be Be eB ee eB
eoraans BSS SFB WXADAAR GBH SS

My first opportunity to locate, open and review DEFENDANTS’ DEMURRER and the
documents in support of it was earlier tonight at about 8:30 PM. As I read them, I determined.
that the author, KEVIN ELLSWORTH GILBERT, is guilty of multiple counts of intentionally
deceiving this Court and me, which are criminal violations of Business and Professions Code
Section 6128(a), He should be arrested and prosecuted immediately.

GILBERT’s “FACTUAL BACKGROUND” section of HIS MEMORANDUM OF
POINTS AND AUTHORITIES is both nonfactual and counterfactual. It is beneath further
analysis. :

GILBERT’s “ARGUMENT” section of HIS MEMORANDUM OF POINTS AND
AUTHORITIES is garbage. For just one example, his citation to Filipoff v. Superior Court,
(1961) 56 Cal. 2d 443 (Filipoff) ignores the fact that Code of Civil Procedure Section 1992 was
amended effective 1/1/2006 to “revise that forfeiture provision to apply to any person failing to

appear pursuant to a subpoena or court order”

which rendered Filipoff inapposite. At least since then, a party has not been required to “bring
the alleged disobedience of the witness to the attention of the trial court.” (Filipoff, supra, 56
Cal. 2d at p. 450.) For example, in Crawford v. JPMorgan Chase Bank, NA (2015) 242 Cal.
App. 4th 1265 (Crawford), the plaintiff did not follow Filipoff and instead filed separate actions
pursuant to Section 1992. There, the trial court refused to dispose of those actions at the
defendant’s request (Crawford, supra, 242 Cal. App. 4th at p. 1268), and the appellate court
affirmed. Although the trial court in Crawford consolidated those Section 1992 actions with an
underlying action (id. at p. 1274), there was evidently no issue about whether a jury trial was
possible in that consolidated action. Here, no right to a jury trial existed in the underlying
actions that had been consolidated, which I viewed as a major problem. One of my main
reasons for pursuing a separate Section 1992 action was to exercise my right to a jury trial. That
is partly because I want other members of my community to know as much as possible about

the disgusting conduct that DIABLO and its agents engage in at taxpayer expense.

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‘WILSON’S OPPOSITION TO DEFENDANTS’ DEMURRERwR YP RH YR RNY Be Be ew ew Be ew ew Be es
eI AOR GOH SF SF Ge DA ARE BES

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Even if Filipoff applied to this case, I impliedly alleged that I brought the alleged
disobedience of the witnesses to the attention of the trial court. Even if that implied allegation

did not suffice, I can easily and truthfully add an explicit allegation to that effect.

Thave neither fully and fairly litigated nor waived any aspect of this Section 1992 action. ;
GILBERT lied.

Crawford is an awful person. (Crawford, supra, 242 Cal. App. 4th at pp. 1265-1275.)
GILBERT is worse. As this Court may recall, GILBERT entered into a secret agreement with
and otherwise protected a convicted child molester on behalf of DIABLO in order to gain
advantages over their victims. His conduct thus far in this case is no less horrifying. He has
done all of those things at taxpayer expense. More people need to know about him.

For the foregoing reasons, this court must either overrule DEFENDANTS’
DEMURRER or grant me leave to amend.

Respectfully submitted,
._ My os Digitally signed by Michael Geary Wilson
/ / Bate: 2019.12.04 23:48:23 -08'00'
MICHAEL GEARY WILSON
Plaintiff
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WILSON’S OPPOSITION TO DEFENDANTS’ DEMURRER