Motion,Ex Parte: TYRONE L. ADAMS VS. CHARLES L. EASLEY et al

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                                TYRONE L. ADAMS, IN PRO PER

P.O. BOX 981044 :

WEST SACRAMENTO, CALIFORNIA 95798
Telephone: (407) 716 0233

TYRONE L. ADAMS, Plaintiff, In Pro Per

SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO -

TYRONE L. ADAMS, ) Case No.: CGC-11-512166
Plaintiff, ) EX PARTE APPLICATION
v. . ) DECLARATION OF TYRONE L.
ADAMS IN SUPPORT OF PLAINTIFF’S,
CHARLES L. EASLEY, et. al. ) REPLY TO DEFENDANTS’
Defendants ) OPPOSITION TO PLAINTIFF’S
) EXPARTE APPLICATION AND
PLAINTIFF’S MOTION

) REQUESTING AN ORDER OF THE
) COURT TO FILE PLAINTIFF’S
SECOND AMENDED COMPLAINT
PRIOR TO DEFENDANTS’
) DEMURRER TO PLAINTIFF’S FIRST
) AMENDED COMPLAINT AND PRIOR
TO DEFENDANTS’ MOTION TO
DISMISS PLAINTIFF’S COMPLAINT
) AGAINST THEM WITH PREJUDICE IS
) HEARD ON TUESDAY,

AUGUST 11, 2020

Date: August 10,2020 Time: 9:00 a.m,
Dept.: 501
FAC Filed: June 26, 2020

DECLARATION OF TYRONE L. ADAMS IN SUPPORT OF PLAINTIFF’S REPLY TO
DEFENDANTS’ OPPOSITION TO PLAINTIFF’S EXPARTE APPLICATION AND
PLAINTIFF’S MOTION REQUESTING AN ORDER OF THE COURT GRANTING LEAVE TO
FILE PLAINITIFF’S SECOND AMENDED COMPLAINT. SAN FRANCISCO COUNTY
SUPERIOR COURT. CASE NUMBER: CGC-11-512166.

ORTEIVAL

PAGE ]SUPREME COURT OF CALIFORNIA

350 McAllister Street
San Francisco, CA 94102

June 11, 2020

In view of recent events in our communities and through the nation, we are at an
inflection point in our history. It is all too clear that the legacy of past injustices inflicted
on African Americans persists powerfully and tragically to this day.’ Each of us has a
duty to recognize there is much unfinished and essential work that must be done to make
equality and inclusion an everyday reality for all.

We must, as a society, honestly recognize our unacceptable failings and continue
to build on our shared strengths. We must acknowledge that, in addition to overt bigotry,
inattention and complacency have allowed tacit toleration of the intolerable. These are
burdens particularly borne by African Americans as well as Indigenous Peoples singled
out for disparate treatment in the United States Constitution when it was ratified. We
have an opportunity, in this moment, to overcome division, accept responsibility for our
troubled past, and forge a unified future for all who share devotion to this country and its
ideals.

We state clearly and without equivocation that we condemn racism in all its forms:
conscious, unconscious, institutional, structural, historic, and continuing. We say this as
persons who believe all members of humanity deserve equal respect and dignity; as
citizens committed to building a more perfect Union; and as leaders of an institution
whose fundamental mission is to ensure equal justice under the law for every single
person.

In our profession and in our daily lives, we must confront the injustices that have
led millions to call for a justice system that works fairly for everyone. Each member of
this court, along with the court as a whole, embraces this obligation. As members of the
legal profession sworn to uphold our fundamental constitutional values, we will not and
must not rest until the promise of equal justice under law is, for all our people, a living
truth.

Sincerely,

Tani Cantil-Sakauye, Chief Justice Mariano-Florentino Cuéllar, Associate Justice
Carol Corrigan, Associate Justice Leondra Kruger, Associate Justice

Ming Chin, Associate Justice Joshua Groban, Associate Justice

Goodwin Liu. Associate JusticeIN THIS INSTANT CASE, I, Pro Se Plaintiff, Tyrone L. Adams, attest, confirm, declare
under penalty of perjury under the laws of the State of California that based on personal
knowledge and personal experience, this EX PARTE APPLICATION is necessary to
avert irreparable harm, immediate danger of dismissal of my meritorious and legally
justiciable claims if the Court does not GRANT my MOTIONS AS REQUESTED.

See DECLARATIONS OF TYRONE L. Adams in REGISTRY OF ACTIONS (ROA)

IT IS IMPERATIVE THAT THIS EXPARTE APPLICATION AND PLAINTIFF’S
MOTION REQUESTING AN ORDER OF THE COURT TO FILE PLAINTIFF’ SECOND
AMENDED COMPLAINT BE HEARD ON MONDAY, AUGUST 10, 2020 PRIOR TO
the Defendants’ DEMURRER To Plaintiff's First Amended Complaint and
Defendants’ Motion to DISMISS Plaintiff's Complaint Against Them With Prejudice
is heard on TUESDAY, AUGUST 11, 2020.

DECLARATION OF PRO SE PLAINTIFF, TYRONE L. ADAMS

|, Tyrone L. Adams am the. Pro Se Plaintiff in Case Number: CGC-11-512166, and |
declare, attest, confirm, and verify under penalty of perjury under the laws of the State
of California that the following statements are true, complete, correct, accurate, and are
based on personal knowledge and personal experience. | am competent to testify to the
truthfulness and veracity of these statements if called upon as a witness.

As to those statement based on diligent legal research, stare decisis, controlling
California Supreme Court and California Appellate Court case law, including the laws,
statutes, codes, civil codes, government codes, and ordinances, | believe those to be
true also.

That my legal rights, and legal interests will be irreparably and prejudicially harmed if
the Court does not GRANT this Plaintiffs EX PARTE APPLICATION AND PLAINTIFF’S|
DECLARATION OF TYRONE L. ADAMS IN SUPPORT OF PLAINTIFF’S REPLY TO
DEFENDANTS’ OPPOSITION TO PLAINTIFF’S EXPARTE APPLICATION AND
PLAINTIFF’S MOTION REQUESTING AN ORDER OF THE COURT GRANTING LEAVE TO
FILE PLAINITIFF’S SECOND AMENDED COMPLAINT. SAN FRANCISCO COUNTY

SUPERIOR COURT. CASE NUMBER: CGC-11-512166.
PAGE 4MOTION REQUESTING an ORDER OF the Court To File PLAINTIFF'S SECOND
AMENDED COMPLANT. :

That my legal rights, and legal interésts will be irreparably and prejudicially harmed if
the Court does not GRANT this PLAINTIFF'S REQUEST THAT THE PLAINTIFF'S
THREE DISCOVERY MOTIONS BE HEARD FIRST ON AUGUST 11, 2020 PRIOR TO
HEARING THE DEFENDANTS’ DEMURRER TO PLAINTIFF’S FIRST AMENDED
COMPLAINT AND DEFENDANTS’ MOTION TO DISMISS PLAINTIFF'S FIRST
AMENDED COMPLAINT AGAINST THEM WITH PREJUDICE; and

That my legal rights, and legal interests will be irreparably and prejudicially harmed if
the Court does not GRANT Plaintiff's EX PARTE APPLICATION and MOTION
REQUESTING THAT THE COURT DELAY THE HEARING OF THE DEFENDANTS’
DEMURRER TO BE HEARD ON AUGUST 18, 2020.

(2) Attempt to determine whether the opposing party will appear to oppose the
application. '

On THURSDAY, August 6, 2020, the DEFENDANTS through their Attorney of Record
li Delforoush summarily refused to Stipulate to this Plaintiff's EX PARTE APPLICATION
and MOTION REQUEST. The Defendants’ attorney Ali Delforoush indicated by
telephone that he would OPPOSE this Plaintiff's EXPARTE APPLICATION and plaintiff's
motion. 4

! explained to Attorney Ali Delforoush of Porter Scott Law Firm the reasons for the
URGENCY and MANDATORY NECESSITY for this EXPARTE APPLICATION and
Plaintiff's Motion in ORDER TO AVERT and OBVIATE IRREPARABLE, PERMANENT,
IRREVERSIBLE, IRREVOCABLE,. HARM and PREJUDICE to this Plaintiff's case and
legal interest.

| explained to Attorney Ali Delforoush of Porter Scott Law Firm that this EXPARTE
APPLICATION MUST BE HEARD ON MONDAY, AUGUST 10, 2020, IN AN

DECLARATION OF TYRONE L. ADAMS IN SUPPORT OF PLAINTIFF’S REPLY TO
DEFENDANTS’ OPPOSITION TO PLAINTIFF’S EXPARTE APPLICATION AND
PLAINTIFF’S MOTION REQUESTING AN ORDER OF THE COURT GRANTING LEAVE TO
FILE PLAINITIFF’S SECOND AMENDED COMPLAINT. SAN FRANCISCO COUNTY

SUPERIOR COURT. CASE NUMBER: CGC-11-512166.
PAGEATTEMPT TO RESCHEDULE THE HEARING OF THE DEFENDANTS’ DEMURRER
TO PLAINTIFF'S FIRST AMENDED COMPLAINT ON TUESDAY, AUGUST 11, 2020 in
DEPARTMENT 501 before Judge Charles F. Haines.
| further informed the Defendants’ Attorney Ali Delforoush, that IT IS NOT CLEAR ON
THE RECORD why Judge Charles F. Haines abruptly, chaotically, frantically, arbitrarily
and capriciously, ORDERED that the Defendants’ DEMURRER to the Plaintiff's First
Amended Complaint and Defendants’ MOTION TO DISMISS be heard on AUGUST 11,
2020 before hearing the Plaintiffs previously scheduled DISPOSITIVE and
SUBSTANTIALLY IMPORTANT THREE DISCOVERY MOTIONS.
| also informed Attorney Ali Delforoush, that TO PRESERVE THE COURT RECORD
FOR AN INTERLOCUTORY APPEAL or APPEAL of these proceedings, | will
aggressively OPPOSE the ORDER of the Court mandating the hearing of the
DEFENDANTS’ DEMURRER and MOTION TO DISMISS on AUGUST 11, 2020,
because this Plaintiff will be irreparably harmed and prejudiced. Furthermore, my
“SUBSTANTIALLY IMPORTANT and DISPOSITIVE” Three Discovery Motions will
become MOOT.

The Defendants Attorney Ali Delforoush indicated that he WOULD APPEAR to
oppose the Plaintiff's EX PARTE APPLICATION and oppose the Plaintiff's Motion To
Reverse the Court ORDER issued on JULY 28, 2020.

DECLARATION REGARDING NOTICE’

Defendants and their Attorney of Record will be formally served with written
notice by personal process of service on THURSDAY, AUGUST 6, 2020 at
350 University Avenue Suite 200 — Porter Scott Law Firm in Sacramento,
California 95825.

DECLARATION OF TYRONE L. ADAMS IN SUPPORT OF PLAINTIFF’S REPLY TO
DEFENDANTS’ OPPOSITION TO PLAINTIFF’S EXPARTE APPLICATION AND
PLAINTIFF’S MOTION REQUESTING AN ORDER OF THE COURT GRANTING LEAVE TO
FILE PLAINITIFF’S SECOND AMENDED COMPLAINT. SAN FRANCISCO COUNTY

SUPERIOR COURT. CASE NUMBER: CGC-11-512166.
PAGE 4DECLARATION OF URGENCY AND NECESSITY FOR THIS EX PARTE
APPLICATION and PLAINTIFF’S MOTION REQUESTING an ORDER OF THE
COURT TO FILE PLAINTIFF’S SECOND AMENDED COMPLAINT.

|, Tyrone L. Adams, am the Pro Se Plaintiff, in this civil action CGC-11-512166 in the
San Francisco County Superior Court.

|, Tyrone L. Adams, declare, attest, and confirm under penalty of perjury under the laws
of the State of California that if this Honorable Court does not GRANT this Plaintiff's
EXPARTE APPLICATION and Plaintiff's MOTION REQUESTING AN ORDER OF
THE COURT TO FILE PLAINTIFF’S SECOND AMENDED COMPLAINT.,

, that this PLAINTIFF’S THREE DISPOSITIVE and SUBSTANTIALLY IMPORTANT
DISCOVERY MOTIONS WILL NEVER BE HEARD because the plaintiff's Three
Discovery Motions will become MOOT if the Court DISMISSES the Plaintiff's First
Amended Complaint with Prejudice.

That on JULY 28, 2020 the Court proclaimed on a very acrimonious and frustrated
statement from the bench stating: | DO NOT KNOW WHAT IS GOING ON WITH THIS
CASE:

Subsequently, San Francisco County Superior Court Judge Charles F. Haines
announced in a very chaotic, vitriolic, capricious and arbitrary manner ruled that the
DEFENDANTS’ DEMURRER to the Plaintiff's First Amended Complaint and the
Defendants’ Motion to Dismiss the Plaintiff's First Amended Complaint Against
Them with Prejudice would be heard FIRST on AUGUST 11, 2020.

Pro Se Plaintiff, Tyrone L. Adams, proffers that there is no legal basis or statutory
bases supporting this arbitrary and capricious ruling of the Court and that the
Court’s ruling was not solicited by either party.

DECLARATION OF TYRONE L. ADAMS IN SUPPORT OF PLAINTIFF’S REPLY TO
DEFENDANTS’ OPPOSITION TO PLAINTIFF’S EXPARTE APPLICATION AND

PLAINTIFF’S MOTION REQUESTING AN ORDER OF THE COURT GRANTING LEAVE TO
FILE PLAINITIFF’S SECOND AMENDED COMPLAINT, SAN FRANCISCO COUNTY

SUPERIOR COURT. CASE NUMBER: CGC-11-512166.
PAGE §The motion hearing set for MONDAY, JULY 28, 2020, was for the specifically
DESIGNATED PURPOSE of HEARING THE Plaintiff's Three “SUBSTANTIALLY
IMPORTANT”, meritorious, and legally justiciable Discovery Motions.

DUE TO THE COVID 19 PANDEMIC, the Plaintiffs THREE DISCOVERY MOTIONS
had previously been CANCELED or RESCHEDULED FIVE (5) TIMES.

This has resulted in irreparable, irrevocable, permanent, irreversible, prejudicial,
Harm and Injury to my legal interests and legal claims.

The ruling by San Francisco County Superior Court Judge Charles F. Haines on
MONDAY, JULY 28, 2020, was made WITHOUT NOTICE, WITHOUT STATUTORY
OR LEGAL PRECEDENT and WITHOUT OPPORTUNITY TO BE HEARD IN ANY
MEANINGFUL MANNER. This prohibited action constitutes impermissible, biased, and
discriminatory ruling by the Court without any legal precedent or rationale; and has
resulted in permanent, irreparable harm my case leading to an UNJUST RESULT and a
JUDICIAL MISCARRIAGE OF JUSTICE. (CCP §475; §631) Cal. State Constitution
Article VI, §13. (Evidence Code §353; §354; §355; §623; §646; §668; §669).

In this instant case, the Court should reconsider the ORDER of the Court issued on
JULY 28, 2020, continuing the Plaintiff's Three Discovery Motions to AUGUST 18, 2020,
because the Plaintiff's Three Discovery Motions were FILED FIRST PRIOR TO THE
DEFENDANTS NOTICE OF DEMURRER and PRIOR TO DEFENDANTS’ MOTION TO|
DISMISS PLAINTIFF'S COMPLAINT AGAINST THEM WITH PREJUDICE.
Furthermore, if the DEFENDANTS’ DEMURRER TO PLAINTIFF’S FIRST AMENDED
COMPLAINT and DEFENDANTS’ MOTION TO DISMISS PLAINTIFF'S FIRST
AMENDED COMPLAINT AGAINST THEM WITH PREJUDICE is heard on AUGUST 11],
2020, the Plaintiff's Three Discovery Motions will NEVER BE HEARD.

DECLARATION OF TYRONE L. ADAMS IN SUPPORT OF PLAINTIFF’S REPLY TO
DEFENDANTS’ OPPOSITION TO PLAINTIFF’S EXPARTE APPLICATION AND
PLAINTIFF’S MOTION REQUESTING AN ORDER OF THE COURT GRANTING LEAVE TO
FILE PLAINITIFF’S SECOND AMENDED COMPLAINT. SAN FRANCISCO COUNTY
SUPERIOR COURT. CASE NUMBER: CGC-11-512166.

PAGE 4This constitutes impermissible bias, discrimination, denial of equal protection
and denial of procedural due process by:

(a) Preventing any opportunity to have the Plaintiff's Three DISPOSITIVE,
SUBSTANTIALLY IMPORTANT, and CASE OUTCOME DETERMINATIVE Discovery
Motions be heard in a meaningful manner; and

(b) Blatantly permitting the Defendants to refuse to comply with legislatively mandated
DISCOVERY REQUESTS by affirming, ratifying, sanctioning, and endorsing the
DEFENDANTS’ obstreperous, intentional, and deliberate Abuse the Discovery Process;
(c) Deliberately permitting the Defendants to SUPPRESS EVIDENCE which they are
required to provide thus concealing dispositive, relevant, material, ultimate facts and
factual evidence which would REFUTE, REBUT, REPUDIATE, and summarily defeat
any claim of RES JUDICATA;

(d) Further demonstrating the fact that this Court engages in persistent institutionalized,
structural prejudice, and bias against this plaintiff in favor the Defendants as the Court
seeks to MANIPULATE, AFFECT, and INFLUENCE the outcome of this case;

(e) by NEVER PERMITTING A JURY TRAIL ON THE MERITS;

(f) by NEVER PERMITTING THIS CASE TO BE ADJUDICATED ON THE MERITS; and
(g) thus causing an UNJUST RESULT and a Judicial Miscarriage of Justice. (California
Evidence Code §353; §354; §355; §623; §646; §668; §669)

(Cal. CCP §475; §631) (Cal. State Const. Article VI, §13 — Judicial Miscarriage of
Justice.

Currently there has been a VIABLE FIRST AMENDED COMPLAINT before the Court
since JUNE 26, 2020, which mandates that the DEFENDANTS provide CODE
COMPLIANT RESPONSES TO Plaintiffs REQUEST FOR ADMISSIONS Set Number
ONE, REQUESTS FOR ADMISSIONS Set Number TWO, and REQUESTS FOR
ADMISSIONS Set Number THREE; and Plaintiffs Form Interrogatories Set Number
ONE.

DECLARATION OF TYRONE L. ADAMS IN SUPPORT OF PLAINTIFF’S REPLY TO
DEFENDANTS’ OPPOSITION TO PLAINTIFF’S EXPARTE APPLICATION AND
PLAINTIFF’S MOTION REQUESTING AN ORDER OF THE COURT GRANTING LEAVE TO
FILE PLAINITIFF’S SECOND AMENDED COMPLAINT. SAN FRANCISCO COUNTY
SUPERIOR COURT. CASE NUMBER: CGC-11-512166.

PAGE 7Plaintiff's Requests For Admissions Set Number ONE was served on FEBRUARY 5,
2020, prior to the Defendants’ Demurrer to the original complaint.

Therefore, at this time TERMINALS EQUIP. V. CITY & CTY. OF SAN FRANCISCO
(1990) 221 CAL. APP. 3D 234, 246-248 is INAPPOSITE and NOT DISPOSITIVE
because there was a “VIABLE COMPLAINT” before the Court on FEBRUARY 5, 2020,
and currently there is a “VIABLE FIRST AMENDED COMPLAINT” before the Court.
This Plaintiff's first meritorious, dispositive, case determinative, legally justiciable
“SUBSTANTIALLY IMPORTANT” DISCOVERY MOTION has been pending before this
Court since MAY 12, 2020. (See, Registry of Actions) (ROA):

2020-04-20 NOTICE OF MOTION AND PLAINTIFF'S MOTION TO DEEM MATTERS
ADMITTED AGAINST "DEFENDANTS" CHARLES L. EASLEY, ANDREW J. PAULSON,
PENSCO TRUST COMPANY, PENSCO INCORPORATED, PENSCO INC., TOM
ANDERSON, CHRIS RADICH, CYNTHIA WEAVER, KELLY RODRIQUES, ET AL;
DEFENDANTS HOMEPOINT PROPERTY MANAGEMENT, ROBERT MACHADO,
ANN FORD, AND EILEEN STEARMAN IN REFERENCE TO PLAINTIFF'S REQUESTS
FOR ADMISSION SET NUMBER ONE, PROOF OF SERVICE FILED BY PLAINTIFF
ADAMS, TYRONE L. HEARING SET FOR MAY-12-2020 AT 09:00 AM IN DEPT 302

2020-05-12 DISCOVERY, DEPT. 302, INRESPONSE TO THE COVID-19
OUTBREAK, THE HEARING DATES FOR ALL LAW AND MOTION AND DISCOVERY
MATTERS IN DEPARTMENT 302 FILED BEFORE JUNE 1, 2020 ARE OFF
CALENDAR PURSUANT TO THE COURT'S GENERAL ORDERS. TO RE-SCHEDULE|
THE HEARING, PLEASE REFER TO THE PUBLIC NOTICE TO RESTORE SERVICES|
ISSUED ON MAY 27, 2020 AVAILABLE ON THE COURT'S WEBSITE AT
HTTPS://SFSUPERIORCOURT.ORG/. (302/EPS)

DECLARATION OF TYRONE L. ADAMS IN SUPPORT OF PLAINTIFF’S REPLY TO
DEFENDANTS’ OPPOSITION TO PLAINTIFF’S EXPARTE APPLICATION AND
PLAINTIFF’S MOTION REQUESTING AN ORDER OF THE COURT GRANTING LEAVE TO
FILE PLAINITIFF’S SECOND AMENDED COMPLAINT. SAN FRANCISCO COUNTY

SUPERIOR COURT. CASE NUMBER: CGC-11-512166.
PAGE §2020-05-20 DISCOVERY, DEPT. 302, IN RESPONSE TO THE COVID-19
OUTBREAK, THE HEARING DATES FOR ALL LAW AND MOTION AND DISCOVERY
MATTERS IN DEPARTMENT 302 FILED BEFORE JUNE 1, 2020 ARE OFF
CALENDAR PURSUANT TO THE COURT'S GENERAL ORDERS. TO RE-SCHEDULE|
THE HEARING, PLEASE REFER TO THE PUBLIC NOTICE TO RESTORE SERVICES
ISSUED ON MAY 27, 2020 AVAILABLE ON THE COURT'S WEBSITE AT
HTTPS://SFSUPERIORCOURT.ORG/. (302/EPS)

2020-06-02 NOTICE OF ENTRY OF ORDER/NOTICE OF RULING FILED ON
DEFENDANTS' DEMURRER TO PLAINTIFF'S COMPLAINT (TRANSACTION ID #
100103542) FILED BY DEFENDANT EASLEY, CHARLES L. GOODRICH, CHARLEEN
BASS, JACK .

2020-06-08 AMENDED NOTICE OF MOTION AND PLAINTIFF'S MOTION TO DEEM
MATTERS ADMITTED AGAINST "DEFENDANTS" CHARLES L. EASLEY, ANDREW J
PAULSON, PENSCO TRUST COMPANY, PENSCO INCORPORATED, PENSCO INC.
TOM ANDERSON, CHRIS RADICH, CYNTHIA WEAVER, KELLY RODRIQUES, ET
AL; DEFENDANTS HOMEPOINT PROPERTY MANAGEMENT, ROBERT MACHADO,
ANN FORD, AND EILEEN STEARMAN IN REFERENCE TO PLAINTIFF'S REQUESTS
FOR ADMISSION SET NUMBER ONE FILED BY PLAINTIFF ADAMS, TYRONE L.
HEARING SET FOR JUN-30-2020 AT 09:00 AM IN DEPT 302

DECLARATION OF TYRONE L. ADAMS IN SUPPORT OF PLAINTIFF’S REPLY TO
DEFENDANTS’ OPPOSITION TO PLAINTIFF’S EXPARTE APPLICATION AND
PLAINTIFF’S MOTION REQUESTING AN ORDER OF THE COURT GRANTING LEAVE TO
FILE PLAINITIFF’S SECOND AMENDED COMPLAINT. SAN FRANCISCO COUNTY
SUPERIOR COURT. CASE NUMBER: CGC-11-512166.

PAGE 9a

2020-06-11 NOTICE OF MOTION AND PLAINTIFF'S MOTION TO COMPEL
FURTHER RESPONSES TO PLAINTIFF'S REQUEST FOR ADMISSIONS- SET
NUMBER TWO; PROPOUNDED TO DEFENDANTS CHARLES L. EASLEY, ANDREW
J. PAULSON, PENSCO TRUST COMPANY, PENSCO INCORPORATED, PENSCO
INC., TOM ANDERSON, CHRIS RADICH, CYNTHIA WEAVER, KELLY RODRIQUES,
ET AL; DEFENDANTS HOMEPOINT PROPERTY MANAGEMENT, ROBERT
MACHADO, ANN FORD, AND EILEEN STEARMAN; PURSUANT TO CCP
2033.290(A)(1);(B)(2) FILED BY PLAINTIFF ADAMS, TYRONE L. HEARING SET FOR
JUN-30-2020 AT 09:00 AM IN DEPT 302

2020-06-17 NOTICE OF MOTION TO DISMISS DEFENDANT GARY HOLBROOK
(TRANSACTION ID # 100104539) FILED BY DEFENDANT EASLEY, CHARLES L.
GOODRICH, CHARLEEN BASS, JACK HEARING SET FOR JUL-16-2020 AT 09:30
AM IN DEPT 501

2020-06-19 HRG 7/20/20 NOTICE OF MOTION TO DISMISS DEFENDANTS
CHARLES L. EASLEY, CHARLEEN GOODRICH, JACK BASS, GEORGE TREFCER,
ANDREW PAULSON, PENSCO TRUST COMPANY, PENSCO, INC. CHRIS RADICH,
CYNTHIA WEAVER, KELLY RODRIQUES, TOM ANDERSON, HOMEPOINTE
PROPERTY MANAGEMENT, ROBERT MACHADO, ANN FORD (ERRONEOUSLY
SUED AS ANN FISHER) AND EILEEN STEARMAN, PROOF OF SERVICE
(TRANSACTION ID # 100104701) FILED BY DEFENDANT EASLEY, CHARLES L.
PAULSON, ANDREW J. PENSCO TRUST COMPANY RODRIQUES, KELLY RADICH,
CHRIS WEAVER, CYNTHIA ANDERSON, TOM PENSCO, INC. TREFCER, GEORGE
HOMEPOINTE PROPERTY MANAGEMENT MACHADO, ROBERT STEARMAN,
EILLEEN GOODRICH, CHARLEEN BASS, JACK FORD, ANN HEARING SET FOR
JUL-20-2020 AT 09:30 AM IN DEPT 501

ee
DECLARATION OF TYRONE L. ADAMS IN SUPPORT OF PLAINTIFF’S REPLY TO
DEFENDANTS’ OPPOSITION TO PLAINTIFF’S EXPARTE APPLICATION AND
PLAINTIFF’S MOTION REQUESTING AN ORDER OF THE COURT GRANTING LEAVE TO
FILE PLAINITIFF’S SECOND AMENDED COMPLAINT. SAN FRANCISCO COUNTY
SUPERIOR COURT. CASE NUMBER: CGC-11-512166.

PAGE 12020-06-26 1ST AMENDED COMPLAINT FILED BY PLAINTIFF ADAMS, TYRONE L|
AS TO DEFENDANT EASLEY, CHARLES L. PAULSON, ANDREW J. CGLS INC. 789
LIBERTY ROAD - PETALUMA, CA 94952, A.K.A., LEE ROAD INVESTORS LONG,
FRANCINE MYERS FAMILY TRUST PENSCO TRUST COMPANY RODRIQUES,
KELLY RADICH, CHRIS WEAVER, CYNTHIA ANDERSON, TOM PENSCO, INC.
SUPRE, PAUL TREFCER, GEORGE THELMA A. TURNER LIVING TRUST THELMA
A. TURNER TRE BARNES FAMILY TRUST CAROLINE H. BARNES TRE DALE M.
BARNES TRE JACK BASS & CHARLENE GOODRICH REVOC TRUST JACK BASS
TRE BATES, AMY M. CIANCIOLO REVOC TRUST CIANCIOLO, SHARON L.
SHARON L. CIANCIOLO TRE CHARLENE GOODRICH TRE HOLBROOK, GARY
DOES 1 - 50, INCLUSIVE JOHN JUDSON WAGGOMAN, A PROFESSIONAL LAW
CORPORATION BUTTACAVOLI, BRUCE BUTTACAVOLI INDUSTRIES FELTON,
DON CULLIGAN WATER SERVICES AND SYSTEMS OF SACRAMENTO
HOMEPOINTE PROPERTY MANAGEMENT MACHADO, ROBERT FISHER, ANN
STEARMAN, EILLEEN ATTORNEY JOHN JUDSON WAGGOMAN MYERS TRE,
CHRISTINE K. MYERS TRE, DONALD CIANCIOLO TRE, SHARON L

2020-06-26 NTC OF MTN AND MTN TO COMPEL RESPONSES TO FORM .
INTERROGATORIES SET NUMBER ONE PROPOUNDED TO DEFT'S; IN
REFERENCE TO FORM INTERROGATORUES SET NUMBER ONE, PROOF OF
SERVICE, DECLARATION FILED BY PLAINTIFF ADAMS, TYRONE L. HEARING SET|
FOR JUL-20-2020 AT 09:00 AM IN DEPT 302

2020-06-26 NTC OF MTN AND MTN TO DEEM MATTERS ADMITTED AGAINST
DEFT'S IN REFERENCE TO PLTF'S REQ.'S FOR ADMISSIONS SET NUMBER-
THREE, PROOF OF SERVICE, DECLARATION FILED BY PLAINTIFF ADAMS,
TYRONE L. HEARING SET FOR JUL-20-2020 AT 09:00 AM IN DEPT 302

A
DECLARATION OF TYRONE L. ADAMS IN SUPPORT OF PLAINTIFF’S REPLY TO
DEFENDANTS’ OPPOSITION TO PLAINTIFF’S EXPARTE APPLICATION AND
PLAINTIFF’S MOTION REQUESTING AN ORDER OF THE COURT GRANTING LEAVE TO
FILE PLAINITIFF’S SECOND AMENDED COMPLAINT. SAN FRANCISCO COUNTY
SUPERIOR COURT. CASE NUMBER: CGC-11-512166.

PAGE 1]2020-06-29 DISCOVERY 302, AMENDED NOTICE OF MOTION FOR PROTECTIVE
ORDER AND FOR SANCTIONS IS CONTINUED UNTIL AFTER THE COURT HAS
RULED ON THE MOTION TO DISMISS CURRENTLY SCHEDULED FOR JULY 20,
2020. IF THE COURT DENIES THE MOTION TO DISMISS, THE PARTIES SHALL
MEET AND CONFER THEREAFTER TO SELECT A NEW HEARING DATE FOR THE
INSTANT MOTION FOR A PROTECTIVE ORDER. IF EITHER PARTY CONTESTS
THE TENTATIVE RULING, THEY WILL BE HEARD ON JUL-13-2020 AT 9:00 A.M.,
IN DEPT. 302/DISCOVERY, A DATE MUTUALLY AGREED TO BY BOTH PARTIES.
JUDGE PRO TEM: TOM COHEN; CLERK: FELICIA GREEN; NOT REPORTED; DEPT].
302.

2020-06-30 LAW AND MOTION, DEPT. 302, JUL-28-2020 HEARING RE:
AMENDED NOTICE OF MOTION AND PLAINTIFF'S MOTION TO DEEM MATTERS
ADMITTED AGAINST "DEFENDANTS" CHARLES L. EASLEY, ANDREW J. PAULSON,
PENSCO TRUST COMPANY, PENSCO INCORPORATED, PENSCO INC., TOM
ANDERSON, CHRIS RADICH, CYNTHIA WEAVER, KELLY RODRIQUES, ET AL;
DEFENDANTS HOMEPOINT PROPERTY MANAGEMENT, ROBERT MACHADO,
ANN FORD, AND EILEEN STEARMAN IN REFERENCE TO PLAINTIFF'S
REQUESTS FOR ADMISSION SET NUMBER ONE IS TRANSFERRED FROM DEPT.
302, LAW & MOTION, TO DEPT. 501, REAL PROPERTY/HOUSING COURT TO BE
HEARD ON THE SAME DATE/TIME (9:30 A.M.). REASON: THIS IS A REAL
PROPERTY/HOUSING COURT CASE. (302/EPS)

2020-06-30 LAW AND MOTION, DEPT. 302, JUL-28-2020 HEARING RE: NOTICE
OF MOTION AND PLAINTIFF'S MOTION TO COMPEL FURTHER RESPONSES TO
PLAINTIFF'S REQUEST FOR ADMISSIONS- SET NUMBER TWO; PROPOUNDED
TO DEFENDANTS CHARLES L. EASLEY, ANDREW J. PAULSON, PENSCO TRUST
COMPANY, PENSCO INCORPORATED, PENSCO INC., TOM ANDERSON, CHRIS

DECLARATION OF TYRONE L. ADAMS IN SUPPORT OF PLAINTIFF’S REPLY TO
DEFENDANTS’ OPPOSITION TO PLAINTIFF’S EXPARTE APPLICATION AND
PLAINTIFF’S MOTION REQUESTING AN ORDER OF THE COURT GRANTING LEAVE TO
FILE PLAINITIFF’S SECOND AMENDED COMPLAINT. SAN FRANCISCO COUNTY
SUPERIOR COURT. CASE NUMBER: CGC-11-512166.

PAGE 13RADICH, CYNTHIA WEAVER, KELLY RODRIQUES, ET AL; DEFENDANTS
HOMEPOINT PROPERTY MANAGEMENT, ROBERT MACHADO, ANN FORD, AND
EILEEN STEARMAN; PURSUANT TO CCP 2033.290(A)(1);(B)(2) IS TRANSFERRED
FROM DEPT. 302, LAW & MOTION, TO DEPT. 501, REAL PROPERTY/HOUSING
COURT TO BE HEARD ON THE SAME DATE/TIME (9:30 A.M.). REASON: THIS ISA
REAL PROPERTY/HOUSING COURT CASE. (302/EPS)

2020-06-30 DISCOVERY 302, PLAINTIFF TYRONE ADAMS' AMENDED MOTION
TO DEEM MATTERS ADMITTED AGAINST "DEFENDANTS" CHARLES L. EASLEY,
ANDREW J. PAULSON, PENSCO TRUST COMPANY, PENSCO INCORPORATED,
PENSCO INC., TOM ANDERSON, CHRIS RADICH, CYNTHIA WEAVER, KELLY
RODRIQUES, ET AL; DEFENDANTS HOMEPOINT PROPERTY MANAGEMENT,
ROBERT MACHADO, ANN FORD, AND EILEEN STEARMAN IN REFERENCE TO
PLAINTIFF'S REQUESTS FOR ADMISSION SET NUMBER ONE IS CONTINUED TO
JULY 28, 2020, AT 9:30 A.M., INDEPARTMENT 302, LAW & MOTION, BASED ON
THE AUTHORITY OF THE JUDGE PRO TEM ACTING IN THE CAPACITY AS
HEARING OFFICER. PLAINTIFF DOES NOT STIPULATE TO THE MATTER BEING
HEARD BY THE JUDGE PRO TEM. DEFENDANT TO PREPARE THE PROPOSED
ORDER CONTINUING THE MOTION. JUDGE PRO TEM: STEVEN STEIN; CLERK:
FELICIA GREEN; NOT REPORTED; DEPT. 302.

2020-06-30 DISCOVERY 302, PLAINTIFF TYRONE ADAMS' MOTION TO COMPEL
FURTHER RESPONSES TO PLAINTIFF'S REQUEST FOR ADMISSIONS- SET
NUMBER TWO; PROPOUNDED TO DEFENDANTS CHARLES L. EASLEY, ANDREW
J. PAULSON, PENSCO TRUST COMPANY, PENSCO INCORPORATED, PENSCO
INC., TOM ANDERSON, CHRIS RADICH, CYNTHIA WEAVER, KELLY RODRIQUES,

ET AL; DEFENDANTS HOMEPOINT PROPERTY MANAGEMENT, ROBERT
ne
DECLARATION OF TYRONE L. ADAMS IN SUPPORT OF PLAINTIFF’S REPLY TO
DEFENDANTS’ OPPOSITION TO PLAINTIFF’S EXPARTE APPLICATION AND
PLAINTIFF’S MOTION REQUESTING AN ORDER OF THE COURT GRANTING LEAVE TO
FILE PLAINITIFF’S SECOND AMENDED COMPLAINT. SAN FRANCISCO COUNTY
SUPERIOR COURT. CASE NUMBER: CGC-11-512166.

PAGE |MACHADO, ANN FORD, AND EILEEN STEARMAN; PURSUANT TO CCP
2033.290(A)(1);(B)(2) IS CONTINUED TO JULY 28, 2020, AT 9:30 A.M., IN
DEPARTMENT 302, LAW & MOTION, BASED ON THE AUTHORITY OF THE JUDGE
PRO TEM ACTING IN THE CAPACITY AS HEARING OFFICER. PLAINTIFF DOES
NOT STIPULATE TO THE MATTER BEING HEARD BY THE JUDGE PRO TEM.
DEFENDANT TO PREPARE THE PROPOSED ORDER CONTINUING THE MOTION.
JUDGE PRO TEM: STEVEN STEIN; CLERK: FELICIA GREEN; NOT REPORTED;
DEPT. 302.

2020-07-08 SECOND AMENDED NOTICE OF MOTION AND MOTION TO DEEM
MATTERS ADMITTED AGAINST DEFENDANTS CHARLES L. EASLEY, ANDREW J.
PAULSON, PENSCO TRUST COMPANY, PENSCO INCORPORATED, PENSCO INC.
TOM ANDERSON, CHRIS RADICH, CYNTHIA WEAVER, KELLY RODRIQUES, ET
AL; DEFENDANTS HOMEPOINT PROPERTY MANAGEMENT, ROBERT MACHADO,
ANN FORD, AND EILEEN STEARMAN IN REFERENCE TO PLAINTIFF'S REQUESTS|
FOR ADMISSION SET NUMBER - ONE FILED BY PLAINTIFF ADAMS, TYRONE L.

2020-07-13 DISCOVERY 302, DEFENDANT CHARLES EASLEY, ANDREW
PAULSON, PENSCO TRUST COMPANY, KELLY RODRIQUES, CHRIS RADICH,
CYNTHIA WEAVER, TOM ANDERSON, PENSCO, INC., GEORGE TREFCER,
HOMEPOINTE PROPERTY MANAGEMENT, ROBERT MACHADO, EILLEEN
STEARMAN, CHARLEEN GOODRICH, JACK BASS, ANN FORD'S AMENDED
MOTION FOR PROTECTIVE ORDER AND FOR SANCTIONS. THE MOTION IS
CONTINUED UNTIL AFTER THE COURT HAS RULED ON THE MOTION TO
DISMISS CURRENTLY SCHEDULED FOR JULY 20, 2020. SEE, TERMINALS EQUIP.
V. CITY & CTY. OF SAN FRANCISCO (1990) 221 CAL. APP. 3D 234, 246-248. IF THE
COURT DENIES THE MOTION TO DISMISS, THE PARTIES SHALL MEET AND
CONFER THEREAFTER TO SELECT A NEW HEARING DATE FOR THE INSTANT
[DECLARATION OF TYRONE L. ADAMS IN SUPPORT OF PLAINTIFF’'SREPLYTO —_—|
DEFENDANTS’ OPPOSITION TO PLAINTIFF’S EXPARTE APPLICATION AND
PLAINTIFF’S MOTION REQUESTING AN ORDER OF THE COURT GRANTING LEAVE TO
FILE PLAINITIFF’S SECOND AMENDED COMPLAINT. SAN FRANCISCO COUNTY

SUPERIOR COURT. CASE NUMBER: CGC-11-512166.
PAGE 14MOTION FOR A PROTECTIVE ORDER. JUDGE PRO TEM: THOMAS COHEN,
CLERK: M. GOODMAN, NOT REPORTED. =(302/JPT)

2020-07-20 DISCOVERY, DEPT. 302, AS TO TH JUL-20-2020 HEARING RE:
PLAINTIFF TYRONE ADAMS'S MOTION TO COMPEL RESPONSES TO FORM
INTERROGATORIES SET NUMBER ONE PROPOUNDED TO DEFT'S; IN
REFERENCE TO FORM INTERROGATORUES SET NUMBER ONE, THE PLAINTIFF
DOES NOT STIPULATE TO THE MATTER BEING DECIDED BY THE PRO TEM
JUDGE. THE MATTER IS CONTINUED TO JULY 28, 2020 AT 9:30 A.M. IN DEPT.
501 - REAL PROPERTY/HOUSING COURT. JUDGE PRO TEM ROBERT KANE TO
PREPARE A REPORT & RECOMMENDATION. JUDGE PRO TEM: ROBERT KANE;
CLERK: SEAN KANE; NOT REPORTED. (302/JPT)

2020-07-20 DISCOVERY, DEPT. 302, AS TO THE JUL-20-2020 HEARING RE:
PLAINTIFF TYRONE ADAMS'S MOTION TO DEEM MATTERS ADMITTED AGAINST|
DEFT'S IN REFERENCE TO PLTF'S REQ.'S FOR ADMISSIONS SET NUMBER-
THREE, THE PLAINTIFF DOES NOT STIPULATE TO THE MATTER BEING DECIDED}
BY THE PRO TEM JUDGE. THE MATTER IS CONTINUED TO JULY 28, 2020 AT
9:30 A.M. IN DEPT. 501 - REAL PROPERTY/HOUSING COURT. JUDGE PRO TEM
ROBERT KANE TO PREPARE A REPORT & RECOMMENDATION. JUDGE PRO
TEM: ROBERT KANE; CLERK: SEAN KANE; NOT REPORTED. (302/JPT)

2020-07-24 AMENDED NOTICE OF MOTION AND PLAINTIFF'S MOTION TO
COMPEL FURTHER RESPONSES TO PLAINTIFF'S REQUEST FOR ADMISSIONS-
SET NUMBER TWO; PROPOUNDED TO DEFENDANTS CHARLES L. EASLEY,
ANDREW J. PAULSON, PENSCO TRUST COMPANY, PENSCO INCORPORATED,
PENSCO INC., TOM ANDERSON, CHRIS RADICH, CYNTHIA WEAVER, KELLY

DECLARATION OF TYRONE L. ADAMS IN SUPPORT OF PLAINTIFF’S REPLY TO
DEFENDANTS’ OPPOSITION TO PLAINTIFF’S EXPARTE APPLICATION AND

PLAINTIFF’S MOTION REQUESTING AN ORDER OF THE COURT GRANTING LEAVE TO
FILE PLAINITIFF’S SECOND AMENDED COMPLAINT. SAN FRANCISCO COUNTY

SUPERIOR COURT. CASE NUMBER: CGC-11-512166.
PAGE 15RODRIQUES, ET AL; DEFENDANTS HOMEPOINT PROPERTY MANAGEMENT,
ROBERT MACHADO, ANN FORD, AND EILEEN STEARMAN; PURSUANT TO CCP
2033.290(A)(1);(B)(2) FILED BY PLAINTIFF ADAMS, TYRONE L.

2020-07-28 REAL PROPERTY/HOUSING MOTION 501, DEFENDANT CHARLES
EASLEY, ANDREW PAULSON, PENSCO TRUST COMPANY, KELLY RODRIQUES,
CHRIS RADICH, CYNTHIA WEAVER, TOM ANDERSON, PENSCO, INC., GEORGE
TREFCER, HOMEPOINTE PROPERTY MANAGEMENT, ROBERT MACHADO,
EILLEEN STEARMAN, CHARLEEN GOODRICH, JACK BASS, ANN FORD HRG
7/20/20 NOTICE OF MOTION TO DISMISS DEFENDANTS CHARLES L. EASLEY,
CHARLEEN GOODRICH, JACK BASS, GEORGE TREFCER, ANDREW PAULSON,
PENSCO TRUST COMPANY, PENSCO, INC. CHRIS RADICH, CYNTHIA WEAVER,
KELLY RODRIQUES, TOM ANDERSON, HOMEPOINTE PROPERTY MANAGEMENT,
ROBERT MACHADO, ANN FORD (ERRONEOUSLY SUED AS ANN FISHER) AND
EILEEN STEARMAN IS CONTINUED TO AUGUST 11, 2020 TO BE HEARD WITH
OTHER PENDING MOTIONS. DEFENDANT TO GIVE NOTICE. JUDGE: CHARLES F.
HAINES; CLERK: J. MURPHY; NOT REPORTED. (D501)

2020-07-28 REAL PROPERTY/HOUSING MOTION 501, DEFENDANT CHARLES
EASLEY, CHARLEEN GOODRICH, JACK BASS NOTICE OF MOTION TO DISMISS
DEFENDANT GARY HOLBROOK IS CONTINUED TO AUGUST 11, 2020 TO BE
HEARD WITH OTHER PENDING MOTIONS. DEFENDANT TO GIVE NOTICE.
JUDGE: CHARLES F. HAINES; CLERK: J. MURPHY; NOT REPORTED. (D501)
2020-07-28 REAL PROPERTY/HOUSING MOTION 501, PLAINTIFF TYRONE
ADAMS NTC OF MTN AND MTN TO COMPEL RESPONSES TO FORM
INTERROGATORIES SET NUMBER ONE PROPOUNDED TO DEFT'S; IN
REFERENCE TO FORM INTERROGATORUES SET NUMBER ONE IS CONTINUED

DECLARATION OF TYRONE L. ADAMS IN SUPPORT OF PLAINTIFF’S REPLY TO
DEFENDANTS’ OPPOSITION TO PLAINTIFF’S EXPARTE APPLICATION AND
PLAINTIFF’S MOTION REQUESTING AN ORDER OF THE COURT GRANTING LEAVE TO
FILE PLAINITIFF’S SECOND AMENDED COMPLAINT. SAN FRANCISCO COUNTY
SUPERIOR COURT. CASE NUMBER: CGC-11-512166.

PAGE 16TO AUGUST 18, 2020 TO BE HEARD WITH OTHER PENDING MOTIONS.
DEFENDANT TO GIVE NOTICE. JUDGE: CHARLES F. HAINES; CLERK: J.
MURPHY; NOT REPORTED. (D501)

2020-07-28 REAL PROPERTY/HOUSING MOTION 501, PLAINTIFF TYRONE
ADAMS NOTICE OF MOTION AND PLAINTIFF'S MOTION TO COMPEL FURTHER
RESPONSES TO PLAINTIFF'S REQUEST FOR ADMISSIONS- SET NUMBER TWO;
PROPOUNDED TO DEFENDANTS CHARLES L. EASLEY, ANDREW J. PAULSON,
PENSCO TRUST COMPANY, PENSCO INCORPORATED, PENSCO INC., TOM
ANDERSON, CHRIS RADICH, CYNTHIA WEAVER, KELLY RODRIQUES, ET AL;
DEFENDANTS HOMEPOINT PROPERTY MANAGEMENT, ROBERT MACHADO,
ANN FORD, AND EILEEN STEARMAN; PURSUANT TO CCP 2033.290(A)(1);(B)(2)IS
CONTINUED TO AUGUST 18, 2020 TO BE HEARD WITH OTHER PENDING
MOTIONS. DEFENDANT TO GIVE NOTICE. JUDGE: CHARLES F. HAINES; CLERK:
J. MURPHY; NOT REPORTED. (D501)

2020-07-28 REAL PROPERTY/HOUSING MOTION 501, PLAINTIFF TYRONE
ADAMS AMENDED NOTICE OF MOTION AND PLAINTIFF'S MOTION TO DEEM
MATTERS ADMITTED AGAINST "DEFENDANTS" CHARLES L. EASLEY, ANDREW J.
PAULSON, PENSCO TRUST COMPANY, PENSCO INCORPORATED, PENSCO INC.
TOM ANDERSON, CHRIS RADICH, CYNTHIA WEAVER, KELLY RODRIQUES, ET
AL; DEFENDANTS HOMEPOINT PROPERTY MANAGEMENT, ROBERT MACHADO,
ANN FORD, AND EILEEN STEARMAN IN REFERENCE TO PLAINTIFF'S
REQUESTS FOR ADMISSION SET NUMBER ONE IS CONTINUED TO AUGUST 18,
2020 TO BE HEARD WITH OTHER PENDING MOTIONS. DEFENDANT TO GIVE
NOTICE. JUDGE: CHARLES F. HAINES; CLERK: J. MURPHY; NOT REPORTED.
(D501)

DECLARATION OF TYRONE L. ADAMS IN SUPPORT OF PLAINTIFF’S REPLY TO
DEFENDANTS’ OPPOSITION TO PLAINTIFF’S EXPARTE APPLICATION AND
PLAINTIFF’S MOTION REQUESTING AN ORDER OF THE COURT GRANTING LEAVE TO
FILE PLAINITIFF’S SECOND AMENDED COMPLAINT. SAN FRANCISCO COUNTY
SUPERIOR COURT. CASE NUMBER: CGC-11-512166.

PAGE 17THIS ARBITRARY and CAPRICOUS, prejudicial, biased, UNFAVORABLY,
ADVERSELY DISPOSITIVE, potentially devastating and CASE OUTCOME
DETERMINATIVE ORDER BY THE COURT ISSUED ON JULY 28, 2020 blatantly
manifest bias and discrimination against this Pro Se Plaintiff by denying equal protectio
and procedural due process to have my “SUBSTANTIALLY IMPORTANT”
DISCOVERY MOTIONS HEARD BEFORE the DEFENDANTS’ DEMURRER TO
PLAINTIFF’S FIRST AMENDED COMPLAINT and DEFENDANTS’ MOTION
TODISMISS PLAINTIFF'S FIRST AMENDED COMPLAINT AGAINST THEM WITH
PREJUDICIE.

There is NO LEGAL BASIS, OR ANY JUST, FAIR, IMPARTIAL, UNBIASED,
RATIONALE FOR THIS DISCRIMINATORY ACTION which deprives this plaintiff of
ANY OPPORTUNITY TO HAVE MATTERS DEEMED ADMITTED IN REFERENCE TO
Plaintiff's REQUESTS FOR ADMISSIONS SET NUMBER ONE.

Furthermore, this Court is permitting the Defendants to DEFY any legal duty, obligation,
or legislative mandate to provide code compliant responses to REQUEST FOR
DISCOVERY, REQUEST FOR ADMISSIONS, or FORM INTERROGATORIES.

This Court is impermissibly allowing the Defendants to willfully, deliberately, wentonay
obstreperously, and defiantly refuse to provide any code compliant responses to
REQUESTS FOR DISCOVERY which would summarily REFUTE, REBUT, DEFEAT,
REPUDIATE, and NULLIFY any ruling of RES JUDICATA.

The SUMMARY JUDGMENT in the Sutter County Superior Court was granted in the
Defendants’ favor based SOLELY on MATTERS DEEMED ADMITTED against this
plaintiff and Hate Crime Victim in direct irreparable, prejudicial, reversible, structural
error per se in violation of the California State Constitution, Article I, §1, §2; § 3 (a) The
people have the right to instruct their representatives, petition government for redress of|
grievances, and assemble freely to consult for the common good.

DECLARATION OF TYRONE L. ADAMS IN SUPPORT OF PLAINTIFF’S REPLY TO
DEFENDANTS’ OPPOSITION TO PLAINTIFF’S EXPARTE APPLICATION AND
PLAINTIFF’S MOTION REQUESTING AN ORDER OF THE COURT GRANTING LEAVE TO
FILE PLAINITIFF’S SECOND AMENDED COMPLAINT. SAN FRANCISCO COUNTY

SUPERIOR COURT. CASE NUMBER: CGC-11-512166.
PAGE 18(b)(4) Nothing in this subdivision supersedes or modifies any provision of this
Constitution, including the guarantees that a person may not be deprived of life, liberty,
or property without due process of law, or denied equal protection of the laws, as
provided in Section 7.

SEC. 7. (a) A person may not be deprived of life, liberty, or property without due
process of law or denied equal protection of the laws;

SEC. 16; SEC. 26; Section 28: MARSY’S LAW: Victims’ Bill of Rights;(a)(1-8);(b)(1-4);
(b)(5): To refuse an interview, deposition, or discovery request by the defendant, the
defendant’s attorney, or any other person acting on behalf of the defendant, and to set!
reasonable conditions on the conduct of any such interview to which the victim consents.
(b)(13)(A)(B)(C): Victim Restitution.

(c) (1) AVICTIM, the retained attorney of a victim, a lawful representative of the victim,
or the prosecuting attorney upon request of the victim, may enforce the rights
enumerated in subdivision (b) in any trial or appellate court with jurisdiction over
the case as a matter of right. The court shall act promptly on such a request.

(e) AS USED IN THIS SECTION, A “VICTIM” is a person who suffers direct or
threatened physical, psychological, or financial harm as a result of the commission or
attempted commission of a crime or delinquent act.

California State Constitution Article VI, Section — 13 Judicial Miscarriage of Justice.

(f) In addition to the enumerated rights provided in subdivision (b) that are personally
enforceable by victims as provided in subdivision (c), victims of crime have additional
rights that are shared with all of the People of the State of California. These collectively
held rights include, but are not limited to, the following:

(2) Right to Truth-in-Evidence; (5) Truth in Sentencing.

DECLARATION OF TYRONE L. ADAMS IN SUPPORT OF PLAINTIFF’S REPLY TO
DEFENDANTS’ OPPOSITION TO PLAINTIFF’S EXPARTE APPLICATION AND
PLAINTIFF’S MOTION REQUESTING AN ORDER OF THE COURT GRANTING LEAVE TO
FILE PLAINITIFF’S SECOND AMENDED COMPLAINT. SAN FRANCISCO COUNTY
SUPERIOR COURT. CASE NUMBER: CGC-11-512166.

PAGE 19IN THIS INSTANT CASE, this Court is actively permitting the Defendants to evade
legislatively mandated REQUEST FOR DISCOVERY, REQUESTS FOR ADMISSIONS;
RESPOND TO FORM INTERROGATORIES; and permitting the Defendants and their
Attorneys to engage in ABUSE OF THE DISCOVERY ACT; engage in willful
SUPPRESSION of relevant, material ultimate facts and factual evidence which would
SUMMARILY REPUDIATE ANY CLAIM OF RES JUDICATA.

The ORDER of this Court issued on JULY 28, 2020 blatantly discriminates against this
plaintiff legislatively mandated rights to REQUEST SUBSTANTIALLY IMPORTANT,
DISPOSITIVE, CASE OUTCOME DETERMINATIVE, relevant, material DISCOVERY in
order to repudiate the Defendants’ claims of RES JUDICATA.

The ORDER of this Court on JULY 28, 2020 permits the Defendants to defiantly
obfuscate their legal duty and obligation to provide code compliant, truthful, complete,
straightforward, honest, non-evasive responses to REQUEST FOR DISCOVERY.
Furthermore, the three prior Federal Court cases listed by the Defendants were NOT
ADJUDICATED or DISMISSED on the MERITS. The dismissals were PENALTY
DISMISSALS and NOTHING WAS EVER DECIDED ON THE MERITS.

Additionally, The ORDER of this Court on JULY 28, 2020, conflicts with the ORDER OF
THE PRESIDING JUDGE GARRETT WONG: All changes to operations are reflected in
the Presiding Judge's General Order in response to the COVID-19 pandemic:
General Order of the Presiding Judge (April 30, 2020)

General Order of the Presiding Judge (April 13, 2020)

General Order of the Presiding Judge (April 1, 2020)

DECLARATION OF TYRONE L. ADAMS IN SUPPORT OF PLAINTIFF’S REPLY TO
DEFENDANTS’ OPPOSITION TO PLAINTIFF’S EXPARTE APPLICATION AND
PLAINTIFF’S MOTION REQUESTING AN ORDER OF THE COURT GRANTING LEAVE TO!
FILE PLAINITIFF’S SECOND AMENDED COMPLAINT. SAN FRANCISCO COUNTY
SUPERIOR COURT. CASE NUMBER: CGC-11-512166.

PAGE 2Additionally, The ORDER of this Court on JULY 28, 2020, conflicts with the ORDERS of
the Presiding Judge as authorized by emergency orders or a statewide order by the
Chief Justice of California and Chair of the Judicial Council.

Emergency Order of the Chief Justice (May 27, 2020)

Statewide Order of the Chief Justice (April 29, 2020)

Emergency Order of the Chief Justice (April 10, 2020)

Statewide Order of the Chief Justice (March 30, 2020)

The ORDERS of the Presiding Judge Garrett Wong and Judge Ethan Schuman in
Department 302 instructed the parties THEMSELVES to meet and confer to select and
determine the dates and times for RESCHEDULING MOTION hearings CANCELED or
CONTINUED due to the COVID19 Pandemic.

The Order of this Court issued on JULY 28, 2020, deprives the parties THEMSELVES
of ability to meet and confer to determine the sequence in which to proceed with
dispositive motions which are OUTCOME DETERMINATIVE of this case.

(C) This Court CAN NOT discriminate against this plaintiff by REFUSING TO HEAR
the plaintiffs’ SUBSTANTIALLY IMPORTANT, DISPOSITIVE, and OUTCOME
determinative DISCOVERY MOTIONS until AUGUST 18, 2020. The Plaintiff's
SUBSTANTIALLY IMPORTANT and DISPOSITIVE discovery motions will be MOOT
and will NEVER BE HEARD.

THE GRAVAMEN of this civil action is malicious, audacious, spiteful, criminal
misdemeanor HATE CRIMES committed against this African-American, male, tenant,
United States citizen, and resident of the State of California in violation of the California
Fair Employment; Housing ACT (Government Code Section 12955 et. seq); the Federal
Fair Housing ACT (Section 3617); the California Unruh Civil Rights ACT, the Ralph Civil
Rights ACT, and in reference to Defendant John Judson Waggoman, civil claims for
ASSAULT and BATTERY and criminal violation of the Tom Bane ACT.

DECLARATION OF TYRONE L. ADAMS IN SUPPORT OF PLAINTIFE’S REPLY TO
DEFENDANTS’ OPPOSITION TO PLAINTIFF’S EXPARTE APPLICATION AND
PLAINTIFF’S MOTION REQUESTING AN ORDER OF THE COURT GRANTING LEAVE TO
FILE PLAINITIFF’S SECOND AMENDED COMPLAINT. SAN FRANCISCO COUNTY
SUPERIOR COURT. CASE NUMBER: CGC-11-512166.

PAGE 2]e e
The Fair Housing Amendments Act (FHAA). The Act amends Title VIII of the Civil
Rights Act of 1968, which prohibits discrimination on the basis of race, color, religion,
sex or national origin in housing sales, and rentals.
Violation of the California Health and Safety Code Sections 17920.3 et. seq.;
§25249.6 — §25249.7; §26147 constitute CRIMINAL MISDEMEANORS as a matter of
law. §17995: Any person who violates any of the provisions of this part, the building
standards published in the State Building Standards Code relating to the provisions of
this part, or any other rule or regulation promulgated pursuant to the provisions of this
part is GUILTY OF A MISDEMEANOR, punishable by a fine not exceeding one
thousand dollars ($1,000) or by imprisonment not exceeding six months, or by both
such fine and imprisonment.
Violation of California Government Codes §25132 and §36900 constitute CRIMINAL
MISDEMEANORS.
See, MARTINEZ v. CALIFORNIA, 444 U.S. 277, 281-282 (1980), the Court noted that
“[a]rguably," a state tort claim is a "species of ‘property’ protected by the Due Process
Clause."

In Logan v. Zimmerman Brush Co. (1982) 455 U.S. 422, 428 — 431 (LOGAN),
the United States Supreme Court held the right to use statutory adjudicatory procedures
provided by state law constitutes a type of property protected by the due process clausg.

The Court traditionally has held that the Due Process Clauses protect civil litigants who
seek recourse in the courts, either as defendants hoping to protect their property or as
plaintiffs attempting to redress grievances. In Societe Internationale v. Rogers, 357 U.S.
197 (1958), for example — where a plaintiff's claim had been dismissed for failure to
comply with a trial court's order — the Court read the "property" component of the Fifth
Amendment's Due Process Clause to impose "constitutional limitations upon the power
of courts, even in aid of their own valid processes, to dismiss an action without affording
a party the opportunity for a hearing on the merits of his cause." /d., at 209. See

DECLARATION OF TYRONE L. ADAMS IN SUPPORT OF PLAINTIFF’S REPLY TO
DEFENDANTS’ OPPOSITION TO PLAINTIFF’S EXPARTE APPLICATION AND
PLAINTIFF’S MOTION REQUESTING AN ORDER OF THE COURT GRANTING LEAVE TO
FILE PLAINITIFF’S SECOND AMENDED COMPLAINT. SAN FRANCISCO COUNTY
SUPERIOR COURT. CASE NUMBER: CGC-11-512166.

PAGE 22also Hammond Packing Co. v. Arkansas, 212 U.S. 322, 349-351 (1909) (power to enter
default judgment); Hovey v. Elliott, 167 U.S. 409 (1897) (same); Windsor v. McVeigh, 93
U.S. 274 (1876) (same). Cf. Wolff v. McDonnell, 418 U.S. 539, 558 (1974). Similarly, the
Fourteenth Amendment's Due Process Clause has been interpreted as preventing the
States from denying potential litigants use of established adjudicatory procedures, when|
such an action would be "the equivalent of denying them an opportunity to be heard
upon their claimed right[s]."" Boddie v. Connecticut, 401 U.S. 371, 380 (1971).2 [455 U.S.
430]

The relationship between these opinions and the right to procedural due process at
issue in the instant case is made clear in Boddie, which relied in large part on the
analysis of Mullane v. Central Hanover Bank & Trust Co., 339 U.S. 306 (1950), and its
guarantee "to all individuals [of] a meaningful opportunity to be heard." Boddie, 401 U.
S., at 379; see also id., at 377-378, 380, 382. Mullane v. Central Hanover Bank & Trust
Co., 339 U.S. 306 (1950); The first question, we believe, was affirmatively settled by
the Mullane case itself, where the Court held that a cause of action is a species of
property protected by the Fourteenth Amendment's Due Process Clause. [455 U.S.
429]

As our decisions have emphasized time and again, the Due Process Clause grants the
aggrieved party the opportunity to present his case and have its merits fairly judged.
Thus it has become a truism that "some form of hearing" is required before the owner is
finally deprived of a protected property interest. Board of Regents v. Roth, 408 U. S., at
570-571, n. 8 (emphasis in original). And that is why the Court has stressed that, when
a "statutory scheme makes liability an important factor in the State's determination... ,
the State may not, consistent with due process, eliminate consideration of that factor in
its prior hearing." Bell v. Burson, 402 U. S., at 541. To put it as plainly as possible, the
State may not finally destroy a property interest without first giving the putative owner an
opportunity to present his claim of entitlement. [455 U.S. 434]

DECLARATION OF TYRONE L. ADAMS IN SUPPORT OF PLAINTIFF’S REPLY TO
DEFENDANTS’ OPPOSITION TO PLAINTIFF’S EXPARTE APPLICATION AND
PLAINTIFF’S MOTION REQUESTING AN ORDER OF THE COURT GRANTING LEAVE TO
FILE PLAINITIFF’S SECOND AMENDED COMPLAINT, SAN FRANCISCO COUNTY

SUPERIOR COURT. CASE NUMBER: CGC-11-512166.
PAGE 23ATTACHMENT

a A
DECLARATION OF IMMEDIATE URGENCY AND NECESSITY - PLAINTIFF’S EXPARTE. *
APPLICATION AND PLAINTIFF’S MOTION REQUESTING AN ORDER OF THE COURT To
FILE PLAINTIFF’S SECOND AMENDED COMPLAINT. SAN FRANCISCO COUNTY i
SU PERIOR COURT. CASE NUMBER: CGC-11-512166. PAGE: {PLAINTIFF'S APPENDIX OF EXHIBITS
PAGE 129: EXHIBIT I
True, correct, complete copy of written twenty-four month residential lease
contract for SUBJECT PROPERTY located at 188 Lee Road in Nicolaus, California
PAGE 139: EXHIBT.
True, correct, complete copy of CERTIFIED AND FIRST CLASS MAIL
Sutter County Criminal Misdemeanor Citation — APRIL 20, 2011
PAGE 140: EXHIBIT Ill
True, correct, complete copy of Sutter County Superior Court — Civil Division
TYRONE L. ADAMS ANSWER TO RETALIATORY UNLAWFUL DETAINER
EVICTION ACTION: CASE NUMBER CVCM-11-0655
PAGE 141: EXHIBIT [V
True, correct, complete copy of CERTIFIED AND FIRST CLASS MAIL
Sutter County Criminal Misdemeanor Citations APRIL 10, 2010 - MARCH 11, 2011
. . PAGE 142: EXHIBIT V
Sutter County Building Safety Code Violation Pre-Complaint Questionnaire
PAGE 143: EXHIBIT VI -
True, correct, complete copy of CERTIFIED AND FIRST CLASS MAIL

| Sutter County Criminal Misdemeanor Citation — 12/23/2009 — 4/20/2011

. PAGE 144: EXHIBIT VII
True, correct, complete copy of Sutter County District Attorney Office Criminal
Misdemeanor Charging Affidavit — Sutter County District Attorney Carl V. Adams

PAGE 145: EXHIBIT VIII
True, correct copy of Sutter County Superior Court — Criminal Misdemeanor
Division Arraignment and Prosecution of Charles L. Easley & Andrew J. Paulson
‘ PAGE 146: EXHIBIT IX .

Sutter County Sheriff Department OFFENSE REPORT AND AFFIDAVIT —
Requesting Charging Attorney John Waggoman with ASSAULT & BATTERY

PLAINTIFF’S APPENDIX OF EXHIBITS; EXHIBITS !-IX Tyrone L. Adams v, Charles L.
Easley, et al.; Case Number CGC-11-512166 PAGE 128ro

C.

MC-030
FOR COURT USE ONLY

ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, uber, and address):

| “TYRONE L. ADAMS, IN PRO PER
P.O. BOX 981044
WEST SACRAMENTO, CALIFORNIA 95798

retepHovenos (407) 7160233 FAXWo. (opnay

E-MAIL ADDRESS (Optional):
ATTORNEY FOR (Name): .

SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO
strestanoress: 400 McALLISTER STREET - DEPT 302
wauncanoréss: 400 McALLISTER STREET - DEPT 302
oryano ze cone: SAN FRANCISCO, CALIFORNIA 94102

srancu name: CIVIL DIVISION - UNLIMITED DAMAGES
PLAINTIFFIPETITIONER: Tyrone L. Adams, INPRO PER

DEFENDANT/RESPONDENT: Charles Easley, Andrew Paulson, Pensco Inc., et al

CASE NUMBER:

DECLARATION

CGC-11-512166

EXHIBIT

I, TYRONE L. ADAMS, declare, attest, and confirm that the following DOCUMENT is a TRUE, CORRECT,
ACCURATE, COPY OF THE ORIGINAL and is based on personal knowledge and personal experience.

| declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.

Date: DECEMBER 12, 2019

TYRONE L. ADAMS, IN PRO PER

Loken
LL ifgne

(TYPE OR PRINT NAME) (SIGNATURE OF DECLARANT)
Attorney for [4] Plaintiff Petitioner [7] Defendant
Respondent Other (Specify):
Satta Gounet of Caomia DECLARATION / 2 9 Pago 404

MC-030 [Rev. January 1, 2008)INTH-TO-MONTH RENTAL A
(C.A.R. Form LR, Revisad 4/04,

irew Paulson xt, 30

fe (Lenora) and
Tyrone Adam

6.

G.

i. PROPERTY: .

(Tanent’) egres es follows:
Landlord rents