Human Rights Alert
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10-07-06 Complaint against Brian Moynihan, Bank of America, and Attorneys Jenna Moldawsky and JohnAmberg - for public corruption and financial institution fraud, relative to their conduct in Samaan vZernik (SC087400) at the Superior Court of California, County of Los Angeles.
Andre Birotte Jr., US Attorney, Central District of California.221 N Figueroa St, Los Angeles, CA 90012By certified mail, by fax: 213-894-6269, 213-894-0141
TO US ATTORNEY, CENTRAL DISTRICT OF CALIFORNIA: Please accept instant Citizen’sComplaint against Brian Moynihan, Sandor Samuels, Bank of America Corporation, and Attorneys JennaMoldawsky and John Amberg for alleged criminal conduct detailed below.
Complaint was filed July 6, 2010, with the US Attorney Office, Central District of California, against Brian Moynihan – President/CEO,Sandor Samuels – Associate General Counsel, Bank of America Corporation, and Attorneys Jenna Moldawsky and John Ambergalleging:(a)
Financial Institution Fraud
relative to their conduct in
Samaan v Zernik
(SC087400) at the Superior Court ofCalifornia, County of Los Angeles pursuant to various acts, including, but not limited to the
Fraud Enforcement and Recovery Act (2009)
;(b) Large-scale fraud on the US government and the US taxpayer in funding government-backed uniform (sub-prime) residential loanapplications with no underwriting at all in violation of
Regulation B of the Federal Reserve
and “sound banking principles” asevidenced in records produced in the same caption;(c) Consequent violations of
False Claims Act –
in seeking hundreds of billions of dollars in bailout funds from the USgovernment for the large-scale default of such loans, which were funded in violation of the law, and(d) Large-scale securities fraud pursuant to the
Securities Exchange Act (1934)
Sarbanes Oxley Act
relative to falsecertification signed starting January 1, 2010 by Brian Moynihan as President/CEO of Bank of America Corporation in periodicreports to the Securities and Exchange Commission, failure to report fraud by corporate counsel and by management to the AuditCommittee, and refusal to allow review complaints by the Audit Committee.Combined, their conduct is alleged as involving numerous predicated acts in the past three years, and satisfying the elements requiredfor prosecution for racketeering pursuant to RICO – the
Racketeer Influenced and Corrupt Organization Act (1970).
The July 6, 2010 complaint relied in part on previous complaints:(a) June 11, 2010 complaint against Brian Moynihan and Bank of America Corporation, filed with the Office of Comptroller of theCurrency and the Securities and Exchange Commission;(b) June 21, 2010 complaint, filed with the US Attorney Office, Central District of California against Attorney David Pasternak, formerPresident of the Los Angeles Bar Association, alleging public corruption and deprivation of rights under the color of law relative toreal estate fraud under the caption referenced above, as opined by one of the best known fraud experts in the US and FBI agentassigned to the case, and(c) May 11, 2010 complaint, filed with FBI against Nivie Samaan and others for real estate fraud and other violations of the law.US banking regulators and the US Justice Department repeatedly promised the US Congress, the people of the US, and theinternational community to investigate any criminality that may have caused the current economic crisis, inflicting harm on workers andinvestors world-wide. The case at hand documents in great detail such alleged criminality. Therefore, the US Attorney, Central Districtof California, was called upon to perform his duties and provide equal protection to complainant Dr Joseph Zernik, to shareholders ofBank of America Corporation, and to all who reside in the United States pursuant to the
and ratified international law – the
Universal Declaration of Human Rights.
Conduct documented in the July 6. 2010 complaint was not unique at all, only its scale and the evidence of involvement of seniormanagement were. Examples were provided of similar conduct in other cases. It also documented the central role of allegedwidespread corruption of the legal profession in undermining US financial systems
and corporate governance
, and failure of USlaw enforcement and the courts to enforce provisions of the
Sarbanes Oxley Act (2002),
which were specifically enacted to addresssuch conduct by counsel. The continued dysfunctional state of US banking regulation poses risks to the US economy that are difficultto assess.
Digitally signedby Joseph Zernik DN: cn=Joseph