On June 01, 2022 a
Motion,Ex Parte
was filed
involving a dispute between
Parafeinik, Oxana,
and
Does 1-2,
Strong Bridge Management Llc,
Voita, Carol,
for Other PI/PD/WD Unlimited
in the District Court of San Bernardino County.
Preview
FILED
SUPERIOR COURT
COUNTY OF SANBBER
SAN 35”“ F’WNO 0%???Cfio
‘
Oxana Parafeinik
26200 Redlands Blvd — Unit 33 JAN 2 0 2023
Redlands, CA 92373
(909) 213-3170
BY
CUAUHTEMOC , EPUTY
Plaintifi‘ - Pro-Per
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN BERNARDINO, SAN BERNARDINO DISTRICT
10 OXANA PARAFEINIK
ll
Plaintiff Case No. CIVSB22106OO
12 Honorable Joseph T. Ortiz
vs Dept. Sl7
13
1) CAROL VOITA (INDIVIDUAL) MOTION TO RECUSE, DISQUALIFY
l4
2) CAROL VOITA(INDIVIDUAL)— JUDGE JOSEPH T. ORTIZ CCP SECTION
15 SOLE MEMBER/MANAGER 170.1
STRONG BRIDGE
l6 MANAGEMENT LLC
17
3) STRONG BRIDGE
MANAGEMENT LLC
18
Defendants
l9
20 Now comes Oxana Parafeinik Petitioner and moves to recuse, disqualify Judge Joseph T. Ortiz from
21 the above entitled matter under 28 USCS Sec.455, and Marshall v, Jerrico 446 WS 238,242 100 S.Ct.
22 CCP Section 170.1. “The neutrality requirement helps to
1610, 64 L. Ed. 2d 182 (1980), and
23 or property will not be taken on the basis of an erroneous or distorted
guarantee that life, liberty,
24
conception of the facts or the law.”
25
The above is applicable to this court by application of Article VI of the United States Constitution
26
and Stone v. Powell, 428 US 465,483 n. 35,96 S.Ct. 3037, 49 L. Ed. 2d 1067 (1976). State courts,
27
like federal courts, have a constitutional obligation to safeguard personal liberties and to uphold
28
1
DOCUMENT TITLE (e.g., COMPLAINT FOR DAMAGES)
federal law.”
The above mentioned Judge has in the past deliberately violated this litigant’s personal liberties and
wantonly refused to provide due process and equal protection t0 this litigant before the court, and has
behaved in a manner inconsistent with needed for full, fair, impartial hearings. The United States
Constitution guarantees an unbiased Judge who will always provide litigants with full protection of
All Rights. Therefore, Petitioner respectfully demands said judge recuse himself and/or Court
recuse, disqualify the Judge in light of the evidence attached and Declaration of Petitioner Oxana
Parafeinik detailing prior unethical and illegal conduct or conduct which gives Petitioner good reason
to believe the above Judge cannot hear the above case in a fair and impartial manner.
lO
ll
STATEMENT OF FACTS
12
Born in Ukraine, Plaintiff Oxana Parafeinik has been a United States Citizen since 2005. She is
13
highly educated with an advanced academic degree, and her English is readily understandable. No
l4
Pro-Bono legal representation is available for an unlimited civil case of this type despite Oxana
15
Parafeinik being disabled and low-income. Representing herself Pro-Per, she has consulted with
l6
l7 various experienced present and retired oflicers of the court both prior t0 and after the drafting of
l8 documents filed and submitted to this Court. As compared to the Defendants’ Carol Voita, et a1.,
l9 whose legal representation is presumably being paid for by an insurance company, American Modern
20 Insurance Group, not Carol Voita personally; Oxana Parafeinik should not be discriminated against
21 because she cannot afford to pay tens of thousands of dollars to have an attorney represent her as the
22 Victim in this matter. Unfortunately,. Judge Ortiz has chosen to discriminate against Ms Parafeinik
23 on this basis. If the judge has a personal prerequisite and bias that all parties appearing in his Court
24 before him MUST have attorney representation in order to receive equal justice and fairness, then he
25 absolutely must recuse himself on this basis alone.
26 Judge Ortiz assessed Discovery monetary sanctions called for by Defendants’ attorneys based upon
27
Defendants’ contention Plaintiff had a “frivolous case” with “frivolous motions” While not requiring
28
2
DOCUMENT TITLE (e.g., COMPLAINT FOR DAMAGES)
Document Filed Date
January 20, 2023
Case Filing Date
June 01, 2022
Category
Other PI/PD/WD Unlimited
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FILED SUPERIOR COURT COUNTY OF SANBBER SAN 35”“ F’WNO 0%???Cfio ‘ Oxana Parafeinik 26200 Redlands Blvd — Unit 33 JAN 2 0 2023 Redlands, CA 92373 (909) 213-3170 BY CUAUHTEMOC , EPUTY Plaintifi‘ - Pro-Per SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO, SAN BERNARDINO DISTRICT 10 OXANA PARAFEINIK ll Plaintiff Case No. CIVSB22106OO 12 Honorable Joseph T. Ortiz vs Dept. Sl7 13 1) CAROL VOITA (INDIVIDUAL) MOTION TO RECUSE, DISQUALIFY l4 2) CAROL VOITA(INDIVIDUAL)— JUDGE JOSEPH T. ORTIZ CCP SECTION 15 SOLE MEMBER/MANAGER 170.1 STRONG BRIDGE l6 MANAGEMENT LLC 17 3) STRONG BRIDGE MANAGEMENT LLC 18 Defendants l9 20 Now comes Oxana Parafeinik Petitioner and moves to recuse, disqualify Judge Joseph T. Ortiz from 21 the above entitled matter under 28 USCS Sec.455, and Marshall v, Jerrico 446 WS 238,242 100 S.Ct. 22 CCP Section 170.1. “The neutrality requirement helps to 1610, 64 L. Ed. 2d 182 (1980), and 23 or property will not be taken on the basis of an erroneous or distorted guarantee that life, liberty, 24 conception of the facts or the law.” 25 The above is applicable to this court by application of Article VI of the United States Constitution 26 and Stone v. Powell, 428 US 465,483 n. 35,96 S.Ct. 3037, 49 L. Ed. 2d 1067 (1976). State courts, 27 like federal courts, have a constitutional obligation to safeguard personal liberties and to uphold 28 1 DOCUMENT TITLE (e.g., COMPLAINT FOR DAMAGES) federal law.” The above mentioned Judge has in the past deliberately violated this litigant’s personal liberties and wantonly refused to provide due process and equal protection t0 this litigant before the court, and has behaved in a manner inconsistent with needed for full, fair, impartial hearings. The United States Constitution guarantees an unbiased Judge who will always provide litigants with full protection of All Rights. Therefore, Petitioner respectfully demands said judge recuse himself and/or Court recuse, disqualify the Judge in light of the evidence attached and Declaration of Petitioner Oxana Parafeinik detailing prior unethical and illegal conduct or conduct which gives Petitioner good reason to believe the above Judge cannot hear the above case in a fair and impartial manner. lO ll STATEMENT OF FACTS 12 Born in Ukraine, Plaintiff Oxana Parafeinik has been a United States Citizen since 2005. She is 13 highly educated with an advanced academic degree, and her English is readily understandable. No l4 Pro-Bono legal representation is available for an unlimited civil case of this type despite Oxana 15 Parafeinik being disabled and low-income. Representing herself Pro-Per, she has consulted with l6 l7 various experienced present and retired oflicers of the court both prior t0 and after the drafting of l8 documents filed and submitted to this Court. As compared to the Defendants’ Carol Voita, et a1., l9 whose legal representation is presumably being paid for by an insurance company, American Modern 20 Insurance Group, not Carol Voita personally; Oxana Parafeinik should not be discriminated against 21 because she cannot afford to pay tens of thousands of dollars to have an attorney represent her as the 22 Victim in this matter. Unfortunately,. Judge Ortiz has chosen to discriminate against Ms Parafeinik 23 on this basis. If the judge has a personal prerequisite and bias that all parties appearing in his Court 24 before him MUST have attorney representation in order to receive equal justice and fairness, then he 25 absolutely must recuse himself on this basis alone. 26 Judge Ortiz assessed Discovery monetary sanctions called for by Defendants’ attorneys based upon 27 Defendants’ contention Plaintiff had a “frivolous case” with “frivolous motions” While not requiring 28 2 DOCUMENT TITLE (e.g., COMPLAINT FOR DAMAGES)