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Notions of Motions

Notions of Motions

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Published by StayOccupied
Judge Kenji Machida required that all motions be in by May 30, 2013 for the Small Claims Case #LAM-13M00544, "Melissa Balin v. The City of Los Angeles" he set for trial on October 10, 2013. Even though attorney's aren't supposed to be allowed to file on behalf of a client in Small Claims, Carmen Trutanich, does whatever he wants, so Balin had to respond to their unlawfully filed Motion to Quash Subpoenas with an Opposition to the Motion to Quash. In an attempt to further the already limited interests of judicial economy, by reducing the time to be consumed in trial, when the main issues at hand remain uncontested by the Defendant; Balin also filed a Notice of Motion and Motion for Summary Adjudication/Judgement in favor of the Moving Party. In her notarized Statement of Uncontroverted Facts (p. 79-89), we get a clearer sense of the prosecutorial misconduct levied against unpopular defendants in the City of Angels.
Judge Kenji Machida required that all motions be in by May 30, 2013 for the Small Claims Case #LAM-13M00544, "Melissa Balin v. The City of Los Angeles" he set for trial on October 10, 2013. Even though attorney's aren't supposed to be allowed to file on behalf of a client in Small Claims, Carmen Trutanich, does whatever he wants, so Balin had to respond to their unlawfully filed Motion to Quash Subpoenas with an Opposition to the Motion to Quash. In an attempt to further the already limited interests of judicial economy, by reducing the time to be consumed in trial, when the main issues at hand remain uncontested by the Defendant; Balin also filed a Notice of Motion and Motion for Summary Adjudication/Judgement in favor of the Moving Party. In her notarized Statement of Uncontroverted Facts (p. 79-89), we get a clearer sense of the prosecutorial misconduct levied against unpopular defendants in the City of Angels.

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Categories:Business/Law
Published by: StayOccupied on Jun 02, 2013
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08/23/2013

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OPPOSITION TO MOTION TO QUASH SUBPOENAS & MOTION FOR ANORDER TO COMPEL1MELISSA BALIN10153
½
Riverside DriveSuite 465Toluca Lake, CA 91602Pro Se, Plaintiff.
SUPERIOR COURT OF THE STATE OF CALIFORNIACOUNTY OF LOS ANGELES – CENTRAL DIVISION
MELISSA BALIN
Case No. LAM-13M00544Plaintiff, Plaintiffs, OPPOSITION TOMOTION TO QUASHSUBPOENAS & MOTION FOR AN ORDER TO COMPEL; &PETITION FOR WRIT OFPROHIBITION, QUOWARRANTO, MANDATE OR OTHER APPROPRIATESUMMARY JUDGEMENT.
v.CITY OF LOS ANGELES
Defendant.Plaintiff herein opposes the motion to quash subpoenas for appearance by LAPD Chief of Police Charlie Beck and Commander Andrew Smith, submitted by City AttorneysCarmen A. Trutanich, Carlos De La Guerra, and Jess J. Gonzalez, as one with no meritand utterly frivolous. The Motion is loaded with untrue and irrelevant material,representing mostly an attack on the Plaintiff and an attempt to prejudice the court againstthe Plaintiff. The Motion is vague and does not present any specific recognized justifiable reasons to quash the subpoena, and was intentionally and unethically submitted by attorneys inappropriately, in the one remaining venue of Small Claims Court that doesnot allow for the unfair advantage of attorney privilege within the allegedly invaginatedLos Angeles Superior Court System.For the reasons set forth in Plaintiffs Opposition To Motion to Quash Subpoenas &Motion For An Order To Compel (
denoted as EXHIBIT A
), the Attorneys for RealParties in Interest’s Motion should be denied as one without merit and frivolous; and
 
OPPOSITION TO MOTION TO QUASH SUBPOENAS & MOTION FOR ANORDER TO COMPEL2attorneys Carmen Trutanich, Carlos De La Guerra, and Jess J. Gonzalez should besanctioned for their abuse of the courts’ time, when ALL parties know full well thatattorneys are not allowed to present or be heard in Small Claims Court. The Plaintiff, on behalf of The Good People of California, request that the Court enter an order compellingthe Respondents to immediately produce the subpoenaed material and that a benchwarrant be issued by the Court for the testimonies of ALL Subpoeaned Public Servants,should they fail to appear again.
ARGUMENT
1.
 
Attorneys for the Defendant state that: “A. Neither Chief Beck nor Commander Smith have any connection with plaintiff’s case nor are they percipient witnesses to any events in plaintiff’s case and B. Chief Beck is ahigh level official and General Manager of the Los Angeles PoliceDepartment (“LAPD”) with supervisory responsibility over more than 13,000sworn and civilian personnel.”2.
 
Attorneys for the Defendant claim that, “It is Chief Beck’s responsibility to protect the health, safety and welfare of the citizens of the City of LosAngeles.” They also claim, making an inferential leap that is understandable, but incorrect, that “To compel him to testify in this proceeding will distractand remove him from these primary duties all to the detriment of the publicsafety.” It is indeed relevant and of material importance, if the policies andorders of the Chief of Police are in fact, placing the public in danger of continuing Constitutional violations; then his giving of testimony IS a primaryduty and keeping Chief Beck OR Commander Smith from testifying in ANYcourt of law, would be the real detriment to public safety.3.
 
City attorneys Trutanich, De La Guerra and Gonzalez go on to perjurethemselves under oath, when they state to the Court, “Real Parties in Interesthave no connection to the case whatsoever, they are not percipient witnessesto any events in the case and do not possess information relevant to theunderlying case, except as to that which they may have learned from their subordinates.” This is patently untrue, as evidenced by multiple international
 
OPPOSITION TO MOTION TO QUASH SUBPOENAS & MOTION FOR ANORDER TO COMPEL3television news cameras that were at the scene of the alleged InternationalTort on November 29
th
and 30
th
, 2011, placing Chief Beck, Mayor Villaraigosa AND Commander Smith as first-hand witnesses to theunconstitutional military operation conducted against its own peacefullyassembled citizens exercising their First Amendment Rights as protected bythe Constitution, from inside the walls of City Hall itself (
denoted asEXHIBIT B
).4.
 
City attorneys Trutanich, De La Guerra and Gonzalez, claim that “Chief Beck and Commander Smith have no relevant testimony to offer, do not personallyknow the plaintiff and the circumstances surrounding her Small Claimslawsuit.” The attached photograph of Chief Beck and the plaintiff taken thefirst week of November 2011 (
denoted as EXHIBIT C
), and multipletelephone conversations betweem the plaintiff and Commander Smith, wouldindicate that they most certainly DID personally know the plaintiff and thecircumstances surrounding her Small Claims lawsuit.5.
 
The City Attorneys’ office, in an abuse of taxpayer resources of the ink and paper to print such lies willfully and intentionally crafted to suppress evidenceof a malfeasance of Justice; in such a manner as is unbecoming a member of the California State Bar, under the guise of acting under Color of Law, boldlystate, “The subpoenas served on Chief Beck and Commander Smithdemonstrates a blatant example of plaintiff’s abuse of the court’s subpoena power and should not be countenanced.”6.
 
It is in fact, the City Attorneys’ office’s bald and unapologetic perjury under oath, that should not be countenanced, and should be discouraged with anappropriate order to compel discovery and sanctions against theaforementioned City Attorneys for their interference In Justice For All inorchestrated prosecutorial misconduct amounting to continuing violations of the Constitution for the United States of America and The California StateConstitution of 1849, worthy of Federal investigation, just in case anybody inCongress or the Department of Justice or that third governing body that aresupposed to provide a checks and balance for these sorts of things, is actually

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