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Charles E. Lincoln, III v Daylight Chemical, Taitz, et al. - 1 - Complaint 40095727 Lincoln v Daylight Taitz Etc

Charles E. Lincoln, III v Daylight Chemical, Taitz, et al. - 1 - Complaint 40095727 Lincoln v Daylight Taitz Etc

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Published by Jack Ryan
UNITED STATES DISTRICT COURT, CENTRAL DISTRICT OF CALIFORNIA (Southern Division - Santa Ana)
CIVIL DOCKET FOR CASE #: 8:10-cv-01573-AG -PLA

Charles Edward Lincoln III v. Daylight Chemical Information Systems Incorporated et al
Assigned to: Judge Andrew J. Guilford
Referred to: Magistrate Judge Paul L. Abrams
Cause: 18:1964 Racketeering (RICO) Act
Date Filed: 10/15/2010
Jury Demand: None
Nature of Suit: 470 Racketeer/Corrupt Organization
Jurisdiction: Federal Question
Plaintiff
Charles Edward Lincoln III represented by Charles Edward Lincoln III
603 Elmwood Place Suite 6
Austin, TX 78705
512-968-2500
PRO SE

V.
Defendant
Daylight Chemical Information Systems Incorporated
Defendant
Yosef Taitz
CEO of Daylight Chemical Information Systems Incorporated
Defendant
Appealing Dentistry
Defendant
Dr Orly Taitz
Esq., D.D.S., J.D.
Defendant
Defend Our Freedoms Foundation
Defendant
John Does
1-10
Defendant
Jane Does
1-10



10/15/2010 1 COMPLAINT against Defendants Appealing Dentistry, Daylight Chemical Information Systems Incorporated, Defend Our Freedoms Foundation, Yosef Taitz, Dr Orly Taitz, John Does and Jane Does. Case assigned to Judge Andrew J. Guilford for all further proceedings. Discovery referred to Magistrate Judge Paul L. Abrams.(Filing fee $ 350 Paid). Filed by Plaintiff Charles Edward Lincoln III.(lwag) (Entered: 10/15/2010)
UNITED STATES DISTRICT COURT, CENTRAL DISTRICT OF CALIFORNIA (Southern Division - Santa Ana)
CIVIL DOCKET FOR CASE #: 8:10-cv-01573-AG -PLA

Charles Edward Lincoln III v. Daylight Chemical Information Systems Incorporated et al
Assigned to: Judge Andrew J. Guilford
Referred to: Magistrate Judge Paul L. Abrams
Cause: 18:1964 Racketeering (RICO) Act
Date Filed: 10/15/2010
Jury Demand: None
Nature of Suit: 470 Racketeer/Corrupt Organization
Jurisdiction: Federal Question
Plaintiff
Charles Edward Lincoln III represented by Charles Edward Lincoln III
603 Elmwood Place Suite 6
Austin, TX 78705
512-968-2500
PRO SE

V.
Defendant
Daylight Chemical Information Systems Incorporated
Defendant
Yosef Taitz
CEO of Daylight Chemical Information Systems Incorporated
Defendant
Appealing Dentistry
Defendant
Dr Orly Taitz
Esq., D.D.S., J.D.
Defendant
Defend Our Freedoms Foundation
Defendant
John Does
1-10
Defendant
Jane Does
1-10



10/15/2010 1 COMPLAINT against Defendants Appealing Dentistry, Daylight Chemical Information Systems Incorporated, Defend Our Freedoms Foundation, Yosef Taitz, Dr Orly Taitz, John Does and Jane Does. Case assigned to Judge Andrew J. Guilford for all further proceedings. Discovery referred to Magistrate Judge Paul L. Abrams.(Filing fee $ 350 Paid). Filed by Plaintiff Charles Edward Lincoln III.(lwag) (Entered: 10/15/2010)

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Categories:Types, Research, Law
Published by: Jack Ryan on Oct 25, 2010
Copyright:Attribution Non-commercial

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02/03/2011

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Case 8:10-cv-01573-AG -PLA Document 1 Filed 10/15/10 Page 1 of 35 Page ID #:1
2
'"'
456789
10
11
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19
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23
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~
25
~
26
27
/
28
q
~~
Charles Edward Lincoln,
III
603 Elmwood Place, Suite
#6
Austin, Texas 78705Telephone: (512) 968-2500E-mail: charlcs.lincoln@;rockelmail.comPlain tiff
in
propia persona
FILED
2010
OCT
15
AM
10:
33
UNITED
STATES DISTRICT COURTCENTRAL DISTRICT OF CALIFORNIA.SANTAANA
Charles Edward Lincoln, III,Plaintiff,
v.
DayEght Chemical Information Systems,
Incorporated,
YosefTaitz,Appealing Dentistry,
Dr.
Orly Taitz, Esq.,
D.D.S.,].D.,
Defend
Our
Freedoms Foundation,
And
allJOHN
&JANE
DOES
1-10,Defendants.
§§§§§§§§
§§§§§
§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§
CIVIL
ACTION
NUMBER:
SACVIO-1573 AG(PLAx)
R.I.C.O.
18
U.S.C. §1964(c)Complaint
For
Damages forInjury to Business & PropertyTRIAL-BY
JURY
DEMANDED
COMPLAINT
FOR
RACKETEERING, 18 U.S.C. §§1961
et
seq.
TO
THE
HONORABLE
UNITED
STATES DISTRICT JUDGE:
1.
Comes now the Plaintiff,
vvith
this Complaint for Racketeering in violation
0
18
U.S.C. §§1961
et
seq.)
complaining
of
damages inflicted by Defendants herein
named
above,
as
well as other defendants whose identity
is
not presently known,identified only
as
DefendantsJohn
&Jane
Does 1-10.
2.
This
Court
has jurisdiction
as
authorized by
18
U.S.C. §1964(c), Civil
R.I.C.O.,
as
well
as
28 U.S.C. § 1334,
and
28 U.S.C. §1367 (SupplementalJurisdiction over inextricably intertwined California state claims, including
but
notlimited to breach
of
contract, breach
of
fiduciary duty, legal malpractice,
and
Charles
Edward
Lincoln
v.
DaylightChemical
Information Systems,
Inc.,et
al.
Cornplaintpursuant
to
18
U.S.C.
§§1961
et
seq.
 
Case 8:10-cv-01573-AG -PLA Document 1 Filed 10/15/10 Page 2 of 35 Page ID #:2
2
3
4
5
67
8
9
10
11
12
13
14
15
1617
18
19
malicious prosecution against Orly Taitz (individually
and
dba
a RacketeeringEnterprise known as the Law Office
ofOrly
Taitz),
and
Defend
our
FreedomsFoundations, Inc., as well as Tortious Interference with
Contract and
Advantageous Business Relationship against YosefTaitz, Daylight ChemicalInformation,
and
Appealing Dentistry, which latter two defendants are the true
primary
sponsors
of
the
RICO
enterprise known
as
the Law Office
of
Orly
Taitz).
3.
Venue
is
proper
because a large majority
of
the transactions and occurrencesgiving rise to this lawsuit took place in
or
were orchestrated from
Orange
County,within the Southern Division
of
the
United
States District
Court
for the CentralDistrict
of
California. Furthermore, both
named
individual defendants reside in
Orange
County
and
the
named
defendant entities have their headquarters
or
principal place
of
business in
Orange
County.
4.
Plaintiff reserves the right to
amend and
add additional causes
of
action tothis complaint by regular
amendment pursuant
to Rule
15
of
the Federal Rules
of
Civil Procedure as
may
be necessary to
bring
all issues before the
Court
concerningthe properties legal services were promised in California, Florida, Idaho,Massachusetts,
and
Texas,
among
others.
BACKGROUND
&
HISTORY OF
THE
CASE
20
5.
Plaintiff Charles
Edward
Lincoln was introduced to Dr. Orly Taitz by
Kathy
21
22
2324252627
28
Garcia-Lawson via telephone
on
Saturday,
May
30, 2009,
and
afterwards washired by Defendant Dr.
Orly
Taitz
to work as law clerk
or
litigation assistant in
her
offices in Mission Viejo
and RanchoSanta
Margarita, California, starting
on
June
9, 2009,
on
behalf
of
both
herself, individually and
dba
Lavv
Office
of
Orly Taitz,
and
Defend
our
Freedoms Foundations,
Inc
.
6.
Plaintiffs original agreement with Dr. Taitz was to be paid $10,000.00 toserve as
her
law clerk
or
litigation assistant in research, drafting, and support on
Charles
Edward
Lincoln
v.
Daylight
Chemical
Information Systems,
Inc.,
et
al.
Complaintpursuant
to
18
U.S. C.
§§1961
et
seq.
2
 
Case 8:10-cv-01573-AG -PLA Document 1 Filed 10/15/10 Page 3 of 35 Page ID #:3
2
3
4
5
67
Dr.
Taitz'
defense against a suit by one Philip
J.
Berg, Lisa Liberi,
and
Lisa Ostellafiled in the Eastern District
of
Pennsylvania.
7.
Somehow
Dr. Taitz quickly reduced this amount, without Plaintiffs actualor implied consent or agreement, to $7,500.00,
of
which Plaintiff was expected
to
pay
his hotel bills in Mission Viejo while working with Dr. Taitz.
8.
Nevertheless, Dr.
Taitz
rapidly piled on additional work, requesting
that
Plaintiff review
her
submissions to the United States Supreme Court, U.S. District
8
Judge
David
O.
Carter,
and
Plaintiff found himself working
24/7
almost without
910
11
12
13
14
15
16
17
18
19
20
21
22
sleep for Defendants Taitz et
al.
during this initial week.
9.
On
or
aboutJune
24, 2009, Plaintiff flew to meet Taitz in Philadelphia for ahearing before the
Honorable Eduardo
C.
Robreno,
United States DistrictJudgefor the E.D. Pennsylvania.
10.
By this time, Defendants Dr. Taitz
et
al.
had
enlisted Plaintiff Lincoln in all
0
their litigation projects, for although the monetary compensation was not initiallyincreased, the Plaintiffs
and
Defendant's relationship
had
begun a surprisingevolution which led to
Defendant
Dr. Orly
Taitz'
ultimate infliction
of
extremeemotional distress
on
the Plaintiff. Lincoln also accompanied Dr. Taitz to Missourithe last week in
June,
2009
and
to New York City
inJuly
for
an
interview withSteve Colbert
and
again in mid-October,
but
Dr. Taitz invited Lincoln to
accompany
her
on
many
other trips for various purposes during July, September,
and
October
2010.
23
11.
The
Plaintiff Charles
Edward
Lincoln
and
Defendant Dr. Orly Taitz
had
24
25
2627
28
originally agreed reasonable legal support/litigation law clerk's fee
of
$1
0,000.00,although never actually paid, would already have been more
than
used up
and
exhausted by the approximately 250+ hours Plaintiff spent working for Dr.
Taitz
and
Defend
our
Freedoms Foundations, Inc., between
June
9
andJune
31, 2010.
Charles
Edward
Lincoln
v.
Daylight
Chemical
Inforrnation
Systems)
Inc.)
et
al.
3
Complaint
pursuant
to
18
U.
S.
C.
§§1961
et
seq.

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