On May 02, 2019 a
Motion,Ex Parte
was filed
involving a dispute between
Johnson, Valencia,
Wilfred, Vincent,
and
Wilfred, Vincent,
for Personal Injury Non-Motor Vehicle Unlimited
in the District Court of San Bernardino County.
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F D
supemon colutla'IE
0F CA
COUNTY or sm eennkggggm
VINCENT WILFRED
APR 1 6 202‘
6| l6 ROBERTS PLACE
_
t “WANDA. CA. 9l739
'
IQ
BY
909 30! 230| ABRMNNA RODRIGU
vikewilf@gmail.com
DEPUTY
SUPERIROR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN BERNARDINO
VALENCIA JOHNSON. Case No.; CIVDs I9I3142
Plaintiff.
vs. DEFENDANT VINCENT WILFRED NOTICE 0F
MOTION AND MOTION T0 DISQUALIFY
VINCENT WILFRED, COUNSEL VASUMATHI VIJAYRAGHAVAN
Defendant
VINCENT WILFRED. DATE: 05/13/2024
DEPARTMENT 528
Cross-Complalnant
TIME: 8:30 AM
HON. JUDGE SACHS
vs.
VALENCIA JOHNSON.
Cross-Defendant
T0 THE COURT AND PLAINTIFF, AND PLAINTIFF’S COUNSEL OF RECORD:
PLEASE TAKE NOTICE that at 8:30 a.m. on May 13. 2024. 0r as soon as the matter
may be heard in Dept. $28 of the San Bemardino Superior Court. at 247 W. Fourth Street, San
Bemardino. California. Defendant/Cross-Complainant hereby moves this Court for an order
disqualifying Vasumathi Vijayraghavan from representing Valencia Johnson or any other party
adverse t0 Vincent Ike Wilfred or his spouse Tracie Greathouse.
This Motion is made 0n the grounds that Vasumathi aka “VASU” agreed and accepted to
representation 0f Defendant and Tracie Greathouse being Defendant‘s spouse in a legal matter in
the San chardino Superior Coun Dept. $25 0f this Justice Center and then fabricated
falsehoods and slanderous statement to support her scheme to switched sides that as a result of
hcr slanderous disparaging statements made in furtherance ofa scheme camouflaged in this
DEFENDANTVINCENT WILFRED NOTICE OF MOTION AND MOTION TO DISQUALIFY COUNSEL
VASUMATHI VUAYRAGHAVAN [FILED CONCURRENTLY WITH REQUEST FOR JUDICIAL
NOTICE]DATE: 05/1 7/2024DEPARTMENT SZ8TIME: 8:30 AMHONORABLE JUDGE SACHS — l
frivolous lawsuit while still 0n the docket as their counsel. whereby counsel conspired with
IQ
Valencia Johnson to bring a lawsuit from which she desperately hopes to make large sums 0f
'4)
money as evidence 0f the numerous monetary sanctions she has filed is evident.
Attorney Vijayraghavan advised Vincent Wilfred and Tracie Greathouse and obtained
their confidential information. which Plaintiff‘s counsel has been using against Defendant/Cross-
Complainant Vincent Wilfred ever since.
The egregious conflicts are evidenced by authenticated emails and text message records
as well as Court records ofcase number CIVDSI7161 20 that was pending in Dept. 825 with
Hon. Judge Keith D. Davis at the same time counsel scheme was being hatched. Proper review
0f Declarations filed by Plaintiff‘s counsel Vasumathi Vijayraghavan under penalty 0f perjury
will show that she misrepresented facts before this Court by filing false affidavits and documents
in this case as will be revealed at the trial.
This Motion is made pursuant to Rules 0f Professional Conduct Rule 1.7. (a). (b). (c).and
3-3 O; and Business
1 & Professions Code § 6068. It is based on this Notice, the Memorandum of
Points and Authorities, Declarations. Exhibits thereto. all papers filed with the Court. including
Notices 0f Related Cases. and all oral 0r documentary evidence and argument presented at
hearing.
DATED: April l 1. 2024 By:
incent Ike Wilfred.
Defendant Pro Se
[)EFENDANTVINCENT WILFRED NOTICE OF MOTION AND MOTION TO DISQUALIFY COUNSEL
VASUMATHI VIJAYRAGHAVAN [FILED CONCURRENTLY WITH REQUEST FOR JUDICIAL
NOTICElDATE: 05/l7/2024DEPARTMENT SZ8TIME: 8:30 AMHONORABLE JUDGE SACHS 2 —
Document Filed Date
April 16, 2024
Case Filing Date
May 02, 2019
Category
Personal Injury Non-Motor Vehicle Unlimited
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F D supemon colutla'IE 0F CA COUNTY or sm eennkggggm VINCENT WILFRED APR 1 6 202‘ 6| l6 ROBERTS PLACE _ t “WANDA. CA. 9l739 ' IQ BY 909 30! 230| ABRMNNA RODRIGU vikewilf@gmail.com DEPUTY SUPERIROR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN BERNARDINO VALENCIA JOHNSON. Case No.; CIVDs I9I3142 Plaintiff. vs. DEFENDANT VINCENT WILFRED NOTICE 0F MOTION AND MOTION T0 DISQUALIFY VINCENT WILFRED, COUNSEL VASUMATHI VIJAYRAGHAVAN Defendant VINCENT WILFRED. DATE: 05/13/2024 DEPARTMENT 528 Cross-Complalnant TIME: 8:30 AM HON. JUDGE SACHS vs. VALENCIA JOHNSON. Cross-Defendant T0 THE COURT AND PLAINTIFF, AND PLAINTIFF’S COUNSEL OF RECORD: PLEASE TAKE NOTICE that at 8:30 a.m. on May 13. 2024. 0r as soon as the matter may be heard in Dept. $28 of the San Bemardino Superior Court. at 247 W. Fourth Street, San Bemardino. California. Defendant/Cross-Complainant hereby moves this Court for an order disqualifying Vasumathi Vijayraghavan from representing Valencia Johnson or any other party adverse t0 Vincent Ike Wilfred or his spouse Tracie Greathouse. This Motion is made 0n the grounds that Vasumathi aka “VASU” agreed and accepted to representation 0f Defendant and Tracie Greathouse being Defendant‘s spouse in a legal matter in the San chardino Superior Coun Dept. $25 0f this Justice Center and then fabricated falsehoods and slanderous statement to support her scheme to switched sides that as a result of hcr slanderous disparaging statements made in furtherance ofa scheme camouflaged in this DEFENDANTVINCENT WILFRED NOTICE OF MOTION AND MOTION TO DISQUALIFY COUNSEL VASUMATHI VUAYRAGHAVAN [FILED CONCURRENTLY WITH REQUEST FOR JUDICIAL NOTICE]DATE: 05/1 7/2024DEPARTMENT SZ8TIME: 8:30 AMHONORABLE JUDGE SACHS — l frivolous lawsuit while still 0n the docket as their counsel. whereby counsel conspired with IQ Valencia Johnson to bring a lawsuit from which she desperately hopes to make large sums 0f '4) money as evidence 0f the numerous monetary sanctions she has filed is evident. Attorney Vijayraghavan advised Vincent Wilfred and Tracie Greathouse and obtained their confidential information. which Plaintiff‘s counsel has been using against Defendant/Cross- Complainant Vincent Wilfred ever since. The egregious conflicts are evidenced by authenticated emails and text message records as well as Court records ofcase number CIVDSI7161 20 that was pending in Dept. 825 with Hon. Judge Keith D. Davis at the same time counsel scheme was being hatched. Proper review 0f Declarations filed by Plaintiff‘s counsel Vasumathi Vijayraghavan under penalty 0f perjury will show that she misrepresented facts before this Court by filing false affidavits and documents in this case as will be revealed at the trial. This Motion is made pursuant to Rules 0f Professional Conduct Rule 1.7. (a). (b). (c).and 3-3 O; and Business 1 & Professions Code § 6068. It is based on this Notice, the Memorandum of Points and Authorities, Declarations. Exhibits thereto. all papers filed with the Court. including Notices 0f Related Cases. and all oral 0r documentary evidence and argument presented at hearing. DATED: April l 1. 2024 By: incent Ike Wilfred. Defendant Pro Se [)EFENDANTVINCENT WILFRED NOTICE OF MOTION AND MOTION TO DISQUALIFY COUNSEL VASUMATHI VIJAYRAGHAVAN [FILED CONCURRENTLY WITH REQUEST FOR JUDICIAL NOTICElDATE: 05/l7/2024DEPARTMENT SZ8TIME: 8:30 AMHONORABLE JUDGE SACHS 2 —