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Barnett Dunn Motion for Reconsideration

Barnett Dunn Motion for Reconsideration

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Published by raicha98
Motion for reconsideration of denial of ex parte application to shorten time to hear application for writ.
Motion for reconsideration of denial of ex parte application to shorten time to hear application for writ.

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Categories:Types, Research, Law
Published by: raicha98 on Jun 11, 2010
Copyright:Attribution Non-commercial

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01/15/2013

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Pamela Barnett, Pro Se Plaintiff2541 Warrego WaySacramento, CA, 95826Telephone: (415)846-7170Pb_realestate@yahoo.comPAMELA BARNETT, IN PRO SE
IDORSED
JUN
- 7
2010
A. WOOD:
SUPERIOR COURT OF THE STATE OF CALIFORNIAFOR THE COUNTY OF SACRAMENTOPamela Barnett,Plaintiff,
VS.
Damon Jerrell Dunn (aka Damon Dunn);Debra Bowen individually and officially asThe California Secretary of State; Edmund
]
G. Brown Jr. (aka Jerry Brown) Officiallyas The California Attorney General andindividually; and John Doe(s) and JaneDoes,DefendantsCase No.: 34-2010-00077415EXPARTE APPLICATION FOREMERGENCY RECONSIDERATION OFHEARING TO ADJUDICATE WHETHERVOTES SHOULD BE COUNTED FORDAMON QLINN JUNE 8. 2010Requested Hearina: ^Date: June 8, 2010Time:1:45 p.m.Dept: 54Judge: Hon. Shelleyanne W.L. ChangAction Filed:Trial Date.May 10,2010Not setJO THE COURT:^ PAMELA BARNETT, declare as follows:' 1. I am the pro se Plaintiff in this action.
2.
Request hearing June 8, 2010 to determine whether votes should be counted forDarnon Dunn for Secretary of State June 8, 2010. The Court has been dulynotified that Damon Dunn has done the following actions:
EX PARTE REQUEST FOR RECONSIDERATION OF HEARING
 
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a. Dunn left Block 16 blank on his voter registration form on March 13, 2009 whereaccording to election code he is to fill out his prior registration information eventhough Florida has confirmed he was registered as a Democrat there;b. Contacted Florida Election Officials to try to erase his voter registration record inJuly 10, 2009. This action confirms Damon Dunn's knowledge of his priorvoter registration (CEC 18203,18500);c. Instead of correcting his voter registration form to comply with the NVRA andHAVA State to State notification of change after speaking with the Florida electionofficials in July, Dunn then goes on to signing his Candidate Intention StatementNovember 13, 2009 with a perjured and effectively void Voter Registration Formon file. Dunn at this point can no longer use the excuse that he didn't know thathe was registered before;
d.
Some time after Nov. 13, 20009, Dunn begins to accept donations and solicitnomination signatures based on a fraudulent Candidate Intention Statement CALELEC CODE 18203;e. Dunn is required to be a registered voter able to vote for the position of Secretaryof State at the time he receives his nomination paperwork. CAL ELEC Code 201.Dunn still has not corrected his California Voter Registration Form on file withOrange County.3. Dunn does NOT meet this qualification to be on the ballot for Secretary ofState under Statute for CAL ELEC CODE
201,
and does not meet the requirement to be aRegistered Republican for either the 3 or 12 month requirements based on his perjured voidvoter registration on file under CEC
8001
(a)2.
However he was also last registered as aDemocrat and would need 12 months as a registered Republican under the law.
4.
This is a vitally important matter before the court, because if the court allowsthe count ofthe votes to occur for an ineligible candidate, Damon Dunn, that did thepreceding actions, will the court be complicit in breaking Cal. Elec. CODE 18500 and 18501codes'? This would put a dark cloud on the honorable court and the integrity of the electionsin California, and would cause major disenfranchisement of a large group of voters whichwould then open up the doors to many lawsuits against the State of California. You can'tput a price on the breach of trust of the California electorate.
- 2 -
EX PARTE REQUEST FOR RECONSIDERATION OF HEARING
 
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5 PlaintifTs Ex Parte request for a hearing June 2, 2010 was erroroneously deniedby Judge Shelleyanne W.L. Chang, and subsequently, so was Plaintiffs request for ahearing June 4, 2010 to decide whether to remove Damon Dunn from the ballot and/or nothave votes counted for him as a Secretary of State candidate.6 Judge Chang stated in the Order "No explanation is given for why plaintiff waitedseveral monttis after tfie candidate filed tiis requisite papers before seeking an OST for anOrder to Sfiow Cause RE- Injunctive Relief"; to which Plaintiff contends is contrary to thefacts that:a. Plaintiff only had a tentative confirmation that Damon Dunn's Declaration ofCandidacy and California Voter Registration Form were erroneous andfraudulent, on or about April 13 when Plaintiff received a copy of the letter fromJean Mane Atkins, Director of Voter Administration, Office ofthe Supervisor ofElections, Florida, confirming that Damon Dunn had a prior voter registration as aDemocrat in Florida and tried to get the Florida elections department to erase hisvoter registration record;b. Plaintiff filed a formal complaint with the Secretary of State's Office May 3, 2010,as the proper channel for voter, ballot, and election fraud. While waiting for ananswer from the Secretary of State's Election Fraud Division (that came by mailafter May 12, 2010 while I was out of
town.).
Plaintiff filed her complaint againstDamon Dunn, Debra Bowen, and Edmund G. Brown May 10, 2010;c. Plaintiff, a pro se party did research how to get an expedited hearing on removingDamon Dunn from the ballot. While Plaintiff attended an important matter in NewYork from May 12, 2010 through May 20, 2010. Plaintiffdid assign an agent,Shirley Freemen, assigned to file plaintiffs proposed Order to Show Cause (OSC)for an expedited hearing in conformance with any such request for injunctive
relief,
but the OSC was rejected by the Clerk ofthe Court 4 days before plaintiffre-filed the Proposed Order to Show Cause for injunctive Relief May
21,
2010requesting a expedited hearing to have Damon Dunn removed from the ballot andnot have any votes be counted for him.
d.
Plaintiff was then denied two more times by Court officials despite Plaintiffcompliance with each phone line request authonzed according to the Superior
- 3 -EX PARTE REQUEST FOR RECONSIDERATION OF HEARING

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