United States Court District of Columbia

Joseph Zernik
1853 Foothill Blvd

LV, CA 91750
Tel: (310) 435 9107
Fax: (801) 998 0917
jz12345@earthlink.net
Pro Se Petitioner
UNITED STATES COURT

DISTRICT OF COLUMBIA
JOSEPH H ZERNIK
Petitioner CASE No 1:09-cv-00805
vs
KENNETH MELSON ET AL
Respondants
VERIFIED NOTICE #6: NOTICE #3 TO THE HONORABLE JEFF BOHME,

U.S. JUDGE, TX
PETITIONER FILES HEREBY NOTICE OF THE FOLLOWING RECORD:
NOTICE #3 FILED IN THE COURT OF THE HONORABLE JEFF BOHM, U.S.
JUDGE, TX.
Dated: May 18, 2009 Respectfully submitted, by:

Digitally signed by Joseph
Zernik
DN: cn=Joseph Zernik,
email=jz12345@earthlink.
net, c=US
Date: 2009.05.18 14:11:36
-07'00'
______________________
JOSEPH H ZERNIK
PRO SE PETITIONER
-1-
Joseph Zernik
1853 Foothill Blvd
LV, CA 91750
Tel: (310) 435 9107
Fax: (801) 998 0917
Pro Se Interested Party
UNITED STATES COURT

WESTERN DISTRICT OF PENNSYLVANIA
SHARON DIANE HILL CASE No 01-22574

Borrower
VERIFIED NOTICE #6: NOTICE #3 TO THE HONORABLE JEFF BOHME,

U.S. JUDGE, TX
PETITIONER FILES HEREBY NOTICE OF THE FOLLOWING RECORD:
NOTICE FILED IN THE COURT OF THE HONORABLE JEFF BOHM, U.S. JUDGE,
TX.
______________________
JOSEPH H ZERNIK
PRO SE INTERESTED PARTY
-2-
PRO SE PETITIONER in Zernik v Melson et al, U.S. Court, District of Columbia,
who is also Interested Party, case of Borrower Parsley, U.S. Court, Southern District of
Texas, and who is also requesting designation as Interested Party in case of Borrower
Hill, U.S. Court, Western District of Pennsylvania, hereby files1 Notice #6.
///
I.
TABLE OF CONTENTS
Alternative Cover Pages …………………………… 1-3
I. TOC …………………………… 4
II. List of Exhibits …….………..…………… 5
III. Request for Lenience by Pro Se Filer …………………………… 5
IV. Significance of the Records Noticed Herein …….………..……………. 6
V. Statement of Verification …….………..……………. 7
VI. Exhibits …….………..……………. 8
///
///
1
Copy is concomitantly filed with TARP Oversight Board, and with TARP Inspector General, as
a request for urgent investigation into matters related to TARP and the Bailout.
Copy is concurrently filed with Lawrence Summer, Director, U.S. President National Economic
Council
Copy is concurrently filed with Paul Volker, Chairman, U.S. President Economic Recovery
Advisory Board, as request for investigation of the allegation that widespread corruption in LA
County, California, involving Countrywide, gave rise, at least in part, to the sub-prime crisis.
Copy is concurrently filed with Carol E. Dinkins., Chairwoman, U.S. President Privacy and Civil
Liberties Advisory Board, as a request for investigation of alleged widespread corruption and
civil rights and human rights violation of historic proportions in LA County, California.
Copies are concomitantly filed with U.S. Congress, as a request for urgent hearings on
underlying matters.
Copy is concomitantly filed with the Israeli Embassy in Washington DC, with request for
monitoring and protection of the rights of dual citizen, Joseph Zernik, per Universal Declaration
of Human Rights, ratified International Law.
-3-
II.
LIST OF EXHIBITS IN CURRENT NOTICE
EXHIBIT 1. 09-04-15-NOTICE #3 FILED IN THE COURT OF THE HONORABLE
JEFF BOHM, U.S. JUDGE, TX.
///
///
III.
REQUEST FOR LENIENCE BY PRO SE FILER
While I make substantial efforts to comply with court procedures, and study
applicable law, I request special lenience as a pro se filer:
A document filed pro se is “to be liberally construed,” Estelle, 429 U. S.,
at 106, and “a pro se complaint, however inartfully pleaded, must be held
to less stringent standards than formal pleadings drafted by lawyers,”
ibid. (internal quotation marks omitted). Cf. Fed. Rule Civ. Proc. 8(f) (“All
pleadings shall be so construed as to do substantial justice”). (Erickson
v Pardus et al, 2007)
In particular, I am unqualified in assessing the validity of legal theories. I ask the
Honorable Court to ignore any irrelevant or erroneous legal theory I claim, and do take
into consideration the facts and the claims themselves, and if they can support some
other valid theory, assign such legal theory to them, and review them pursuant to such
valid legal theory (Haddock v Cal Board of Dental Examiner, 1985).
The Honorable Court is requested to entirely disregard my comments,
explanations, or legal arguments pertaining to such papers, when my writings appear to
be of the nature of legal theories, or legal arguments, and are deemed erroneous, or
irrelevant.
If it pleases the Honorable Court, let the Honorable Court act of its own volition
whenever permitted to do so by law:
a. To initiate action pursuant to the Code of Conduct of U.S. Judges, Canon
-4-
3B(3):
(3) A judge should initiate appropriate action when the judge
becomes aware of reliable evidence indicating the likelihood of
unprofessional conduct by a judge or a lawyer.
b. To act pursuant to Fed. Rule Civ. Proc. 8(f) “to do substantial justice” for
Plaintiffs who claim to have been inflicted substantial harms by the Los
Angeles justice system.
________________________
JOSEPH H ZERNIK
PRO SE PETITIONER
///
///
IV.
SIGNIFICANCE OF RECORDS NOTICED HEREIN
///
This notice provides more detailed evidence of the alleged frauds perpetrated by Countrywide,
and later – Bank of America. While this notice, #6 is only the cover text, it is followed by two
heavy volumes of records, Volume A – various letters, email, notes, and Volume B – which is
the group of 6 Key Records, which Petitioner alleges to be the essence of the fraud, and which
Mr Mozilo, Mr Samuels, Mr Lewis, and Mr Mayopoulos would not answer on, while making
any possible effort to harass, intimidate, and retaliate. The evidence is going to be deemed by
an objective overwhelming – yet FBI and USDOJ – for two years refused to provide me
protection, and allow such frauds to go on.
-5-
BY:_________________
JOSEPH H ZERNIK
PRO SE PETITIONER
Joseph Zernik
1853 Foothill Blvd
LV, CA 91750
Tel: (310) 435 9107
Fax: (801) 998 0917
///
///
V.
STATEMENT OF VERIFICATAION
I, Joseph H Zernik, have written and re-read the foregoing:

VERIFIED NOTICE #6: NOTICE #3 TO THE HONORABLE JEFF BOHM, U.S.
JUDGE, TX.
I know the content thereof to be true and correct. It is true and correct based on
my own personal knowledge, except as to those matters therein stated as based upon
information and belief, and as to those matters, I believe them to be true and correct as
well.
I make this declaration that the foregoing is true and correct under penalty of
perjury pursuant to the laws of the United States.
Executed here in La Verne, County of Los Angeles on this 18th day in May, 2009.
_____________________
JOSEPH ZERNIK
pro se Plaintiff
-6-
VI.
EXHIBITS
-7-
EXHIBIT 1
-8-
Case 05-90374 Document 258 Filed in TXSB on 05/08/09 Page 1 of 28
).~
, Tn,' COUR1S
UNITED SIe..,~,~a, ~ tEXAS
; Joseph Zernik, in pro se SOUTH"EoN f.'1\SiRICT
"'~',' ,,'\
0, , 5ig~ed
Digitally byJQsephZernik
: jJ() Box 526 FILE \,1 DN: cn~Jo5eph Zernik,
email~jZ12345@earthlink.net.
i La Verne, CA 9 1750
MA,Y l\~i q
t'
71'.,il,
09 c~us
Dat":2009.04.1513:54:10-07'00'
it rd : (310) 435 9 1 07
,i:nc (801) 998 0917

i !I:mail: j Z12345@earthlink.net
UNITED STATES BANKRUPTCY COURT

HOUSTO~T ,TP'Xl'r
i...
"VJLLIAMALLEN PARSLEY CASE, ,.tt: 05-90374

Borrower VERlF,lED NOTICE #3 TO HON JEFF
BOHM, PURSUANf TO MEMO, DOC
#24~, ,\iAR.CH 5, 2008, STATING:
., ... '
"THE OmRT WILL CONTINUE TO VERIFY

THAT ITS TRUST IS WELL-PLACED. "
KEY Rj~CORDS, PART OF INARTFUL
FILIN<! - AS EVIDENCE OF ALLEGED
WR<"-)NJDOING BY COUNTRYWIDE,
BRYAl\ CAVE, LLP, AND OTHERS.
, ,
IF IT· pr~EASES THE COURT, LET THE
! con Rl ACT OF ITS OWN VOLITION
"TO JoOSUBSTANTIAL JUSTICE"
FULlS D{SCLOSURE OF THE

ALLl'~GID CONDUCT DETAILED
HEREIN IS OF HIGH PUBLIC POll
SIGl\UFH;ANCE RELATIVE TO THE
TRU E NATURE OF THE SUB-PRIME
SCANDAl,ANDBAILOUT.
FILED UNDER SEPARATE COVERS:

1) EXHIBITS VOLUME A,
2) EXHIBITS VOLUME B
-~ ..
April 12, 2009; NOTICE #2, RE: CFC/BAC

William Allen Parsley, Borrower
Case # 05-90374
9/36
2 TO THE COURT OF THE HONORABLE JEFF BOHM, U.S. JUDGE, HOUSTON,
3 TEXAS, TO PARTIES AND COUNSEL:
4
5 I.
6
VERIFIED REQUEST FOR LENIENCE BY A PRO SE FILER
1) I Joseph Zernik, am resident of Los Angeles County, Califonria, and citizen of
7
the United States.
8
2) These notices I filed in pro se, not by choice. Therefore, I request special
9 lenience as a pro se filer:
10 A document filed pro se is ''to be liberally construed," Estelle, 429 U. S., at
106, and "a pro se complaint, however inarttully pleaded, must be held to less
11 stringent standards than tormal pleadings drafted by lawyers," ibid. (internal
quotation marks omitted). Ct. Fed. Rule Civ. Proc. 8(t) ("All pleadings shall be
12 so construed as to do substantial justice"). (Erickson v Pardus et al, 2007)
13
3) In particular, I am not qualified in assessing the validity of legal theories. I ask
14
the Honorable Court to ignore any irrelevant or erroneous legal theory I claim,
15
and do take into consideration the facts and the claims themselves, and if they
16 can support some other valid theory, assign such legal theory to them, and
17 review them pursuant to such valid legal theory (Haddock v Cal Board of
18 Dental Examiner, 1985).
19 4) This notice includes mostly records filed, mailed, or emailed by Countrywide,
Bank of America, and/or Bryan Cave, LLP. It is claimed that serious harms
20
were done to me through such papers.
21
5) The Honorable Court is requested to entirely disregard my comments,
22 explanations, or legal arguments pertaining to such papers, when my writings
23 appear to be of the nature of legal theories, or legal arguments, and are deemed
24 erroneous, or irrelevant.
25 6) If it pleases the Honorable Court, let the Honorable Court act of its own
volition:
26
a. To "continue to verify that its trust is well-placed".
27
b. To initiate action pursuant to the Code ofConduct of u.s. Judges,
28
Case # 05-90374
10/36
2 (3) A judge should initiate appropriate action when the judge becomes aware
of reliable evidence indicating the likelihood of unprofessional conduct by a ...
3 lawyer.
4 A copy of the California State Bar Association - Rules of
5 Professional Conduct is accordingly filed herein (Exhibit A13)).
6 c. To act pursuant to Fed. Rule Civ. Proc. 8(f) "to do substantial

7 justice" for an individual who has been allegedly looted and harassed for a
8 number of years by several giant corporations, for no fault of his own at all.
9
10 Submitted April 15, 2009, La Verne, California.
11
12
13
14
:!2?<----
Joseph Zernik
in pro per
15
16 II.
NOTICE TO THE HONORABLE COURT PURSUANT TO ITS MARCH 5,
17
2008 MEMORANDUM OPINION STATING: "THE COURT WILL
18 CONTINUE TO VERIFY THAT ITS TRUST IS WELL-PLACED."
19 7) I allege that Countrywide and its counsel, and/or those pretending to be its
counsel, in collusion with others, engaged in various wrongful schemes in order
20
to harm me. Some of the schemes were similar to those previously rebuked by
21
the Honorable Court in matters pertaining to Borrower Mr Parsley, and in
22 report of the U.S. Transtee in other courts.
23 8) Other of the schemes by Countrywide and its counsel, evidnced here, are similar
. 24 to those rebuked in a Pittsburgh, Pennsylvania Court, where Countrywide was·
25 found in January 2008 to have filed "Recreated Letters" as evidence in court.
9) I allege that such schemes amounted to willfull misconduct and severe abuse of
26
my rights. I was driven out of my home under the threat of force, my property
27
was taken for private use with no compensation at all, I hve incurred losses
28

Case # 05·90374
11/36
exceeding $2.0 millions, and I have endured extreme hardship and ongoing
2 harassment, to this date.
10) My rights per the First Amendment were severely abused, I had gag orders
3
imposed on me, to benefit large corporations, and I was even denied the right to
4
file counterclaims against Countrywide.
5 11) Needless to say my rights for Due Process and Possession were severely
6 abused.
7 12) My rights for Equal Protection were entirely disregarded.
8 13) I believe that the conduct described here would also be deemed upon review
severe abuse of Human Rights per Intenational Law, serious violations of the
9
Articles of the Universal Declaration ofHuman Rights. Articles 2,
10
& 12.
7,8,10,11
11 14)This notice is filed pursuant to March 5, 2008 Memorandum Opionion
12 by the Honorable Court, which stated:
13 "The Court will continue to verify that its trust is well-
placed."
14
15) The records provided herein, as Volume A, and Volume B, were intended as
15 companion to April 12, 2009 Notice #2 - Overview.
16 16) I allege that these records provide credible evidence that the Honorable Court's
17 turst was misplaced, and Countrywide and BAC continue to this date the same,
18 or variations on the same schemes, which were rebuked by this court in its
March 5, 2008 Memerandum Opinion.
19
III
20
III.
21 TABLE OF EXHIBITS
(in chronological order)
22
23 17)
VOLUMEA.
24 Letters."Email Notes & Miscellenaous
25 18)
26 A(l)a September 7, 2004 Nivie Samaan's Prequalification Letter
Purportedly faxed by Victor Parks, but in deposition, Samaan admitted that he
27
was not part of the process at all. The preponderance of the evidence indicates
28

Case # 05-90374
12/36
that this is the first example of one of the wire/fax schemes in this case, and
2 this record was never signed by Victor Parks and was never faxed by Victor
3 Parks.
4 hltp://in properinla.com/04-09-07-samaan-s-prequalification-Ielter.pdf
20)
A(2) July 10, 2006 Samaan's Deposition
Samaan admitted, among other things, that she and her husband alone
fabricated the loan applications, and that Parks had nothing to do with it at
all.
hltp://inproperinla.com/06-07-1 O-samaan-deposition.pdf
22)
a. That all email correspondence was omitted from the subpoena, and
b. That they did not know where the purported October 14, 2004
Underwriting Letter (Key Record #1} came from, since it was missing from
25
their subpoena, which purported to include all underwriting letters. Their
emphatic response in Meet & Confer was that if it had not been included in
26
27
the subpoena, it had not been part of the original loan underwriting file.
They later back-tracked such statements.
28

Case # 05-90374
13/36
Compare to July 11, 2007 Boock Declaration (Exhibit A(6)).

2 http://inproperinla.com/07-03-16-Counlrywide-meel-&-confer-s.pdf
3 24)
A(4) June 23, 2007 my Letters to Mozilo & Samuels
4
These letters were in response to solicitations that both advertised on the web
5
at that time for any concerned parties regarding fraud (included with Notice
6
#2). Mozilo's was specific regarding fraud in Countrywide. Samuels was
7
generalized, regarding any fraud whatsoever, in his capacity as President of
8
The House of Justice. Within 24 hours, the whole web site of the House of
9
Justice was down. When it came back up about a week later, there was
10
neither mention in it of Sandor Samuels nor of his campaign against frauds in
11
southern California. Within less than two weeks Bryan Cave, LLP appeared in
12
a "dark courtroom", off the record and off the calendar, for an application for
13
a "Protective Order" deemed by me a "Gag Order" (see below). That record is
14
now missing from court file (Exhibit B(S)).
15
hltp://inproperinla.com/07-07-03-moldawsky-notice-of-ex-parte-gag-order.pdf
16
25)
17 A(S) July 3, 2007 Att Jenna Moldawsky, Bryan Cave, LLP, Letter
18 Noticing me that she purportedly represented Countrywide. Now, neither AU
19 Moldawsky nor AU Amberg would answer any of my requests to clarify the identity
20 of clients that they purportedly represented in the past two years.
21 hltp://inproperinla.com!07-07-03-moldawsky-nolice-of-ex-parte-gag-order.pdf
22 26)
23 A(6) July u, 2007 Countrywide Legal Department Att Todd Boock
Declaration
24
This declaration repeats conduct that was the reason for the Honorable
25
Court's rebuke of Countrywide's litigation practices in March 2008:
26
27 a) Hearsay: AU Todd Boock's declaration is mostly hearsay, the type of
28 declaration by counsel rebuked by this Honorable Court in March 2008.

Case # 05-90374
14/36
28)
b) Subpoena: Att Todd Book stated relative to the subpoena production,
under penalty of perjury:
23. Countrywide fully complied with all four of Zernik's document subpoenas.
Countrywide did not engage in any deceptive practices with regard to Zernik's
document subpoenas.
29)
Please compare to the March 16, 2007 Meet and Confer letter (Exhibit
A(3)) above. As detailed in the Meet & Confer letter, Countrywide to this date
has never provided me with the email correspondence related to these 1003s.
In Meet & Confer Att Boock denied that any of the reports I requests existed at
all. If one is to take Att Boock's statements at face value, and indeed
Countrywide had none of the reports requested, including pipeline reports,
imaging reports, security alerts, internal audit reports, external audit reports
relative to Samaan's 1003S, then one must doubt whether Countrywide is a
genuine financial institution at all.
c) Sarbanes-Oxley Act (2002): The language used by Att Boock to describe

his compliance with the law, appears entirely divorced from the requirements
of the Sarbanes-Oxley Act (2002).
24. On many occasions, counsel for Countrywide attempted to meet and
confer with Zernik and to ensure that he was satisfied with Countrywide's
compliance with his document subpoenas, within the bounds of our legal
obligations and duties to Countrywide, and its officer [sic - in the singular-
jhz], employees and customers.
The emphasis on obligation to an officer appears unusual, and does not reflect
the duties of a counsel in a public corporation per Sarbanes-Oxley Act
(2002), Section 307. In contrast, duties to the share-holders, and to the
public at large are never mentioned.
The phrase "compliance with the law" is also conspicuously missing.

Case # 05-90374
15/36
d) Frazier: One of the main objectives ofthe purported July 23,2007

2 Protective/Gag Order (Exhibit B(6)) was to prevent me from any contact
3 with Diane Frazier, former Countrywide Senior Underwriter, Countrywide,
4 San Rafael Branch.
5
Please compare my account of the conversation (Notice #2, Overview),
6
where Frazier was happy to discuss with me the details of Samaan's 1003
7
underwriting, which she remembered two years after the fact in perfect detail,
8
since they cost her the job, where she had been employed since 1989.
9
10
She was clearly intimidated, warning me repeatedly: "You don't know who
11
you're dealing with," and "Nobody can touch Maria McLaurin".
12 36)
13 The man who answered my phone call in March 2007, issued the death threat:
14 "Ifyou ever call this number again, I will come down to LA and gun
15 you down".
16 37)
Here AU. Boock describes it as handling me "firmly". That man never said
17
that Frazier did not want to talk with me. He said that she had known that
18
Countrywide had not allowed her talk with me about this matter.
19
Indeed, after my first phone call with her, Frazier disappeared. My subpoena
20
deposition service people staked the house for several days 24 hours/day.
21
They reported to me and provided a declaration that she had never been seen
22
entering or leaving the house, and that the man who answered the door
23
claimed that she had moved away.
24
38)
25 A(7) October 2, 2007, October 15,2007, November 7,2008 AttAmberg,
26 Bryan Cave, LLP, Email Note in re: representation ofCountrywide
27
28

Case # 05-90374
16/36
This email is in response to my request for explanation, how Bryan Cave, LLP
2 got the July 6,2008 proceeding scheduled, which was conducted in a "dark
3 courtroom", off the record, off the calendar.
4 In response Att Moldawsky stated that it " •.• entirely proper".
5 http://MISSINGSSSinproperinla.com/o4-1o-25-doc-45-countrywide~fraud-contract-record.pdf
6 39)
A(8) October 2, 2007, October 15, 2007, November 7, 2008 Att Amberg,
7 Bryan Cave, LLP, Email Notes in re: representation of
8 Countrywide
9 a. October 2, 2007, In response to request for a list of papers and
10 appearances by Bryan Cave, LLP attorneys in the affair of Samaan v
11 Zernik (SCo87400), which he continues to refuses to provide to this
12 date, he stated:
"We decline to get further involved in this matter."
13
14 b. October 15, 2007, in response to direct question on representation:
"Our law firm continues to represent Countrywide."
15
16 c. October 16, 2007, referring to the same undisclosed, never seen order
17 that Att Todd Boock claims prohibits me from communicating with
18 him, Att Amberg states:

" ...order dated July 23, 2007 which ordered you to communicate solely
19
with Countrywide's designated counsel, either Todd Boock and Sandy
20 Shatz of Countrywide's legal department or Bryan Cave LLP."
d. November 5,2008, in response to direct question on representation:
21
"We continue to represent Countrywide and are counsel of record."
22
e. March-April 2009, Att John Amberg has been reusing to answer any
23
direct question regarding the nature of engagement between Bryan
24
Cave, LLP and Countrywide.
25
In contrast:
26
f. November, December 2008, and February-March 2009, the office of
27
BAC General Counsel, Timothy Mayopoulos in emphatically denied
28

Case # 05-90374
17/36
1 such claims, and stated that Bryan Cave, LLP, was NOT authorized to
2 appear on behalf of BAC.
3 http://inproperinla. cornia? -1 0-02-bryan-berg-att-amberg-decl ine-to-get-further-involved-s.pdf
4 40)
A(9) In re: November-December 2007 Att David Pasternak's Grant
5 Deeds - Fraud Expert/Document Examiner report
6 Veteran FBI agent, decorated by u.s. Congress, by u.s. Attorney General, and
7 by FBI Director examined the November-December 2007 Grant Deeds issued
8 and filed by Att David Pasternak and concluded:
9 "Accordingly, based on above observations MR. WEDICK opines an
immediate investigation should be instituted in an effort to ascertain the
10 circumstances behind any fraud being committed so that appropriate local,
state, and federal authorities can be notified, including the appropriate court."
11
41) Of note, Att David Pasternak is the former President of The House of
12
Justice, Bet Tzedek, like Sandor Samuels, and also former President of the
13
Los Angeles County Bar Association.
14
42) The conduct of Att David Pasternak in the case of Gali{jie v Darwish
15
(SC052737), appears largely as following the same general schemes followed
16
in Samaan v Zernik (SCo87400), albeit it did not involve Countrywide. I
17
had a chance to review some of the records (I am denied access to court file),
18
and also located the defendants, Barbara Kramar Darwish and David Darwish,
19
and obtained declarations from the former regarding the conduct of that case.
20
There is good reason for concern regarding actions of Att David Pasternak in
21
that case as well.
22
43) I obtained certified copies of dozen of records from the office of Los Angeles
23
County Registrar/Recorder revealing numerous conveyances oftitles byAtt
·24
David Pasternak that would deserve careful review for the same reasons noted
25
by decorated FBI agent relative to the Grant Deed he filed on my property.
26
27
28

Case # 05-90374
18/36
44) Combined, it is more than likely that Att David Pasternak has been involved in
2 alleged wrongdoing in relationship to real property matters over a number of
3 years, and involving numerous properties.
4 http://inproperinla.com/07-12-17-wedick.memo.nolarized.deeds.zernik.2009.02.05-s.pdf
http://inproperinla.com/07-12-17-granl-deeds-wedick-s-opinion-s.pdf
5 45)
6 A(.1o) January 27,2008 Table: Countrywide's Party Designations
Countrywide routinely files papers in the LA Superior Court self-designated
7
"Non-Party", but the Court interchangeably uses "Plaintiff', "Defendant",
8
"Cross-Defendant", "Intervenor", "Real Parties [sic-jz] in Interest",
9
all with no legal foundation at all.
10
http://inproperinla.com/08-01-27-counlrywide-in-samaan-v-zernik-s.pdf
11
46)
12
A(.11) February 4, 2008, my letter to Kenneth Lewis III, President, BAC,
13 & February .12, 2008 response from Lewis's office
14 My letter noticed Mr Lewis and other members of the Board of Directors of
15 alleged material violations of the law at Countrywide:

I hold and believe that you owe your share-holders an in-depth investigation
16
of this case and underlying claims by Defendant against Countrywide.
17 Defendant was prevented from filing claims against Countrywide in this case
so far. Claims include, but are not limited to the following:
18 a) That the Legal Department of Countrywide deliberately and knowingly,
repeatedly produced false and misleading, fraudulent documents in response
19 to subpoenas by Defendant in Samaan v Zernik in 2006 and 2007. Key
contact in the Countrywide's Legal Department in this regard was Att Todd
20 Boock.
b) That such documents included, but were not limited to:
21 i. False and misleading blank, paper-based (as opposed to digital) San
Rafael Branch Conversation Log forms, which according to
22 information I obtained, had not been used in Countrywide since at
least 1989. Such blank forms deceptively substituted for the
23
deliberately omitted relevant email correspondence.
24 ii.. Uniform Residential Loan Application Forms (1003) with double "Date
Received" stamps, for which Countrywide refused to provide any
explanation at all, denying existence of any support documents
related to such adulterated documents.
LO iii. A loan file replete with false and deliberately misleading documents,
reflecting multiple levels of fraud, inclUding, but not limited to:
27 mortgage fraud, wire/fax fraud against a financial institution, wire/fax
fraud against an individual, and fraud attempt against Countrywide
share holders.

Case # 05-90374
19/36
In response I was informed:

"We now will have an opportunity to better serve customers and to enhance
future profitability. Countrywide customers will gain access to a broad set of
consumer products, including credit cards and deposit services. We believe
this is the right decision for customers, shareholders, and employees."
http://inproperinla.com/08-02-04-letter-to-otticers-of-bac-re-countrywide-s.pdf
http://inproperinla.com/08-02-12-bac-lewis- response-from-ottice-of-chai r-to-letter-re-cou ntrywide-s.pdf
" 47)
I 4(12} December 10,2008 Countrywide, Legal Department, Att Todd
Boock, Email note
In this email note In-House Counsel claims:
"The referral to me regarding this matter was in error... am
covered by the protective order prohibiting you from contacting
employees of Countrywide."
At the very same time, the office of BAC General Counsel claims that the
ONLY counsel authorized is Todd Boock, and that Bryan Cave, LLP, is NOT
authorized as counsel for Countrywide/BAC.
:1'8)
i! l8}California State Bar - Rules ofProfessional Conduct
As reference in re: Conduct of counsel in this affair.
http://inprooerinla.com /og-04-13-california-state-bar-rules professional-conduct-s.pdf
VOLUMEB.
Papers Filed in Court
Records" - that BAC Audit Committee is asked to either authenticate or
repudiate and withdraw from court records.
N)
F(l)a Purported October 14, 2004, or mid-October 2oo4fax
transmission by Countrywide ofan Underwriting Letter
Deemed Key Record #1. It was falsely represented as a valid underwriting
letter that was transmitted and received on October 14, 2004 or mid-October
2004. It was never adequately authenticated as to sender and receiver.
riO) Generally, the fact that Countrywide could make such false claims reflects
failure to conduct business based on "sound baning principles", or keep

Case # 05-90374
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banking records in compliance with UETA relative to electronic transactions.

It also stands in contrast to a sophisticated system of fax-servers developed at
Countrywide, which was supposed to ensure compliance. It also stands in
contrast with Countrywide's own Practice and Policy manuals relative to
the operation of fax machines.
http://inproperinla.com/04-10-26-countrywide-fraudulent-underwriting-letter-s.pdf
51)
IJ(l)b In re: Purported October 14,2004, or mid-October 2004fax
transmission fuJ. Countrywide ofan Underwriting Letter - Record
Examiner/Fraud Expert opinion
http://inproperinla.com/04-10-26-doc-44-eountrvwide-fraud-underwriting-letter.pdf
;2)
Oc In re: Purported October 14, 2004, or mid-October 2004fax
transmission fuJ. Countrywide ofan Underwriting Letter
http://inproperinla.com/04-10-26-opinion-letter-countrywide-underwriting-letter-oct-26-s.pdf
lJ)
:!)a Purported October 25, 2004fax transmission to Countrywide ofa
Real Estate Purchase Contract
Deemed Key Record #2. This banking record was falsely represented as the
product of fax transmission by Victor Parks from State of Washington to
Countrywide in San Rafael on October 25, 2004, at 5:03pm.
4) In fact, the fax header imprints on this record, showing the date and time
listed above, were part of a fax/wire scheme by Samaan and Countrywide, a
financial institution, across state lines. The transmission on that date and time
listed above was from Samaan in Los Angeles County to her husband Jae Arre
Lloyd (formerly Timothy Lloyd Morrow) also in Los Angeles County.
65) This record was never adequately authenticated as to the identity of sender
and receiver. The details in the fax header imprint, noticed above, contradict
declaration of Victor Parks in court, where he stated that he received the
transmission from Mara Escrow on Friday, October 22, 2004 in the morning,
and "immediately" faxed it to Countrywide. It also contradicts Samaan's

Case # 05·90374
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1 deposition, where she indicated that all actions relative to the 1003S were by her
2 and her husband, and Mr Parks was not involved in it in the first place.
3 56) There is no way to ascertain based on Countrywide's subpoena production
4 when this record was inserted into the loan files. It is entirely missing from any
5 .other subpoena production by other parties, such as Samaan or Parks.
6 57) This record also reflects that general deficiency in the subpoena production -
7 the multiple records that are products of fax transmissions are likely to have
8 been inserted into the loan file at times that were entirely different from those
9 marked on anonymous fax header imprints, as seen here. In short - banking
10 records that are entirely unreliable. See also comments in re: Exhibit B(l),
11 above.
hllp://M ISSI NGSSSi nproperinla.com/04-1 0-25-doc-45-countrywide-fraud-contract-record. pdf
12
58)
13 B(2)b In re: Purported October 25, 2004 Fax Transmission to
Countrywide ofReal Estate Purchase Contract
14
hllp://inpropelinla.com/04-1 0-25-doc-45-counlrywide-fraud-conlract-record.pdf
15 59)
B(3) July 2006, Feb 8, 2007, April 2007 Countrywide's subpoena
16 productions
17 The five (5) subpoena productions in and of themselves hold over 400 pages
18 each, or a total of some 2000 pages, and were almost identical to each other.
19 Therefore they were deemed too voluminous to file as evidence.
20 60) The first production was in Summer 2006, and it came with no declaration of
21 custodian of records. Once I reviewed it, in December 2006, and realized its
22 deficiencies and the multiple alleged false records in it, I issued a repeat
23 subpoena notices in January 2007. In such notices I explicitly listed some of
24 . the missing records, and also some of those that were deemed false. ~egardless,
25 in February 2007 Countrywide's Legal Department repeated three (3) more
26 time the exact subpoena production. The January subpoena and the entire
27 February production are posted online at:
28 hllp:l/inproperinla.com/07-02-08-countrywide-fraudulenl-subpoena-production-c-s.pdf

Case # 05-90374
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61) Following the Meet & Confer of March 2007, Countrywide, of its own volition
2 repeated again the subpoena production, in April 2007. It is claimed that upon
3 review the repeat on April 2007 would be deemed false and deliberately
4 misleading, and was aimed to falsely represent the allegedly false banking
5 record shown here as the Underwriting Letter in Exhibit B(l), as part of the
6 original loan file.
7 62) In lieu of such subpoena production, selected records from the subpoenas are
8 presented here as Exhibits B(3) a, B(3)b, and B(3)c.
9 63)
B(3)a Samaan's Loan Applications (1003s)
10
The core record in this affair [SS # was redacted -jhz].
11
http://inproperinla.com/04-09-2Z-samaan-countrywide-fraudulent-Ioan-application.pdf
12 64)
B(3)b In re: Samaan's Loan Applications (1003s)- Record
13 examiner/fraud expert opinion letter
http://inproperinla.com 104 -og-2z-opinion-Ietter-fraud-in-loan-applications-signature-s.pdf
14
65)
15 B(3)c In re: Samaan's Loan Applications (1003s)
http://inproperinla.com/04-og-2z-doc-40-samaan-fraudulent-loan-applications-s.pdf
16
66)
17 B(4) November 9. 2006 Letter & Subsequent Declarations by
Countrywide, San Rafael Branch Manager Maria McLaurin
18
These declarations pertain to Samaan's loan applications and their
19
underwriting at Countrywide. McLaurin generated extensive declarations that
20
defy logic and are inherently inconsistent.
21
http://inproperinla.com/06-11-og-doc-38-1-countrywide-mclaurin-false-declarations.pdf
22 http://inproperinla.com /06-11-og-doc-38-2-countrywide-mclaurin-false-declarations.pdf
23 67)
~(s) Selection ofpapers filed by Bryan Cave, LLP
24
Additional records are provided here, beyond those noted in previous letters
25
and complaints to the BAC Audit Committee.
26
68)
27 B(s)a July 6, 2007 Ex Parte Applicationfor a Protective Order deemed
28 "Gag Order"

Case # 05-90374
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1 This ex parte application was conducted in a "dark courtroom" (both

2 literally and figuratively), off the record and off the calendar, with no clerk
3 present in the courtroom. Countrywide was listed in the special schedule
4 (which included only one item) as "Plaintiff." However, in the papers filed in
5 court on that day, Bryan Cave, LLP attorneys designated Countrywide as
6 "Non-Party." This key record is now missing from court file, and repeated
7 requests to Bryan Cave, LLP, to provide a conformed copy were left
8 unanswered.
9 http://inproperinla.com/oz-oz-o6-countl)TWide-gag-order-motion-in-full-s.pdf
10 69)
B(S)b March 7, 2008 Countrywide Applicationfor Sanctions and OSC
11 re: Contempt, filed by Bryan Cave, LLP
12 Practices previously rebuked by this court, are seen in this filing, including,
13 but not limited to:
14 I. Filing by Counsel, Bryan Cave, LLP, who now refuses to clarify who its
15 client wasjisjarejwere.
16 2. Motions supported by declarations by counsel only were repeated here.
17 3. Evidence was entered with no adequate authentication,
18 4. Countrywide requested "Declaratory Relief' - "Countrywide has no
19 obligation to respond further to Defendant Zernik regarding
20 this action".
21 The core of this OSC was based on an ex postfacto order: On January 11,
22 2008, with no motion or hearing, the July 23, 2007 order that never was, was ruled
23 "in full force and effect". By March 2008, I was convicted in a quasi-criminal
24 procedure for violations in 2007 of an order, whose purported existence was ruled in
25 2008!
26 Such practice is explicitly prohibited by the Universal Declaration ofHuman

27 Rights!
28 http://inproperinla.com/ Og-Ol-13-CW- motion-sanctions-osc-contempt-S.pdf

Case # 05-90374
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70)
B(S)c February 17, 2009, Motionfor a sanctions and OSC in re:
2 Contemptfiled Bryan Cave, LLP
3 Same practices as noted above were repeated here.
4 The main claim in this motion was absurd: That I was prohibited by an order
5 that had never been produced, and for all I know, had never existed, but was
6 purportedly issued and entered on July 23,2007, from any communication
7 with Bank of America. The reason: On July 1, 2008 Bank of America had
8 become an affiliate [sic - jhz] of Countrywide!
9 71) The fact that I was and am a share-holder, was and am a deposit account
10 owner, and was and am a victim of fraud by Countrywide, now BAC, made no
11 difference.
12 72) The fact that there is no way that anybody could tell on July 23,2007 that in
13 July 1, 2008 Countrywide would become a subsidiary of BAC did not make
14 any logical hurdle either.
15 In short - Bryan Cave, LLP, again sought and obtained quasi-
16 criminal conviction on an ex postfacto order. Such practice is
17 explicitly prohibited by the Universal Declaration ofHuman
18 Rights!
19 73) Such harassment, intimidation, and retaliation, was in response to my phone
20 calls with BAC Office of the General Counsel, in which I uncovered the alleged
21 false representations by Bryan Cave, LLP: BAC office of the General Counsel
22 repeatedly informed me that Bryan Cave, LLP was NOT authorized to appear
23 in court for BAC.
24 • So who was Bryan'Cave, LLP, appearing for?
25 • Sandor Samuels?
20
• Angelo Mozilo?
27 • For itself(

Case # 05-90374
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1 • On behalf of whom did Bryan Cave, LLP, receive payments of

2 over $30,000 in sanctions?
3 74) However, BAC Office ofthe General Cousnel never stopped the appearances
4 by Bryan Cave, LLP, in its name in the Los Angeles Courts, regardless of my
5 repeated notices to Mr Mayopoulos of the actions of Bryan Cave, LLP.
6 http://inproperinla.com/o9-01-13-moldawskv-notice-of-motion-sanctions-contempt.pdf
75)
7 B(6) A July 23,2007 purported Protective/Gag Order.
8 I have no such record in my possession, and have never been noticed or
9 serviced with such record either. There is no evidence that such record has
10 ever existed at all. I expect CFC/BAC Audit Committee to finally produce the
11 record, alternatively - withdraw any record where existence of such order was
12 implied or relied upon.
13 76) The court file includes instead:
1,1 a. Two proposed orders, marked by hand, in red pen, "DENIED"
b. One joint stipulation, signed by Att Amberg alone.
Ii c. On proposed order, unsigned.
IV.
EVOLUTION OF THE LIST OF "KEY RECORDS"
19
77)The list of "Key Records" was initially developed in requests addressed to
20
Angelo Mozlo and Sandor Samuels to authenticate or repudiate such records,
21
starting early 2007. At first the list included only "Key Record #1" - the
Underwriting Letter. Later "Key Records #1 & #2" - adding to it the
23 Purchase Contract. Both involved alleged wire/fax schemes against and/or by a
24 financial institution and across state lines.
':) Exhibit #5 in my April 12, 200gNotice #2, filed with this Honorable
Court, listed six records (or groups of records) that represent the current list of
such "Key Records" of the alleged wrongdoing by Countrywide.
27

Case # 05-90374
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79) The Bank of America Corporation (BAC) Audit Committee was repeatedly
requested to address this list of "Key Records", to authenticate or repudiate
them, but failed to do so to this date.
80) In fact, the BAC Audit Committee to this date failed to even acknowledge
receipt of my complaints and letters.
81) Below is the list as copied verbatim from letters and complaints sent to the
Audit Committee of BAC:
"Listed below are key records of the alleged fraud by CFC/BOA against JOSEPH
ZERNIK in litigation of Samaan v Zernik (SC087400) at the LA Superior Court:
I} Underwriting Letter misrepresented as a fax transmission of mid-
October 2004, from Countrywide, san Rafael to VICTOR PARKS, State
of Washington. [1]
Introduced repeatedly in court. Most recently for a motion noticed for November
2008. Alleged key fraud record.
2} Real Property Purchase Contract misrepresented as a fax transmission
of October 25, 2004, 5:03pm from VICTOR PARKS, State of
Washington, to Countrywide, San Rafael. [2]
Introduced repeatedly in court. Most recently for a motion noticed for November
2008. Alleged key fraud record.
3} set of a letter and declarations by CFC/ MARIA MCLAURIN, Branch
Manager, san Rafael, California. [3]
Introduced repeatedly in court. Key fraud record.
4} Subpoena Production of Countrywide in Samaan v Zernik. [4]
About 400 pages, produced by the Legal Department a total of 5 times from
August 2006 to April 2007. Deemed fraud in its entirety - since it included loan
files that were recreated after the fact, and records that are the product of
wire/fax fraud and bear false and deliberately misleading fax header imprints,
when in fact there is nothing in this production that allows to determine where
and when such records appeared from. It was part of a concerted effort by
SAMAAN,
McLAURIN and the Legal Department of CFC to fabricate false history for
SAMAAN's loan applications in 2004,
5} Records showing CFC and even more recently CFC/BOA appearing in
court for almost two years under the party designation of "NON-
PARTY", while the court interchangeably designates it "DEFENDANT",
"PLAINTIFF", "INTERVENOR", "ROSS-DEFENDANT", "REAL PARTY IN
INTEREST", etc. [5]
SUCH APPEARANCES ARE DEEMED FALSE AND DELIBERATELY MISLEADING AND HAVE NO BASIS
IN THE LAW OF THEU.s. OR CALIFORNIA, THEREFORE THEY PLACE THE ENTIRE LmGATION IN
A REAL THAT IS OUTSIDE THE LAW.
6} JULY 23, 2007 PROTECTIVE/GAG ORDER BY JUDGE JACQU'ELINE CONNOR [6].
Such purported order led to two judgment of quasi-criminal nature being entered
by Judge Terry Friedman against me, both at the request of CFe, The second
one - in February 2009, at the requests of CFC/BOA. I have no valid court record
of that nature, and the court and CFe/ BOA so far have failed to produce this
record either."
82) The numbers in square brackets in the text of the letters and the complaints to
the Audit Committee referred to records, which were posted online at the URis
Case # 05-90374
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listed below. Such lists were provided in the letters and complaints to the BAC
2 Audit Committee as well.
3 [1]
http://inproperinla.com/04-10-26-countrywide-fraudulent-underwriting-letter-s. pdf
4 http://inproperinla.com/04-10-26-doc-44-countrywide-fraud-underwriting-letter. pdf
http://inproperinla.com/04-10-26-opinion-letter-countrywide-underwriting-letter-oct-26-
s.pdf
5 [2]
http://inproperinla.com/04-10- 25-doc-45-countrywide-fraud-contract-record.pdf
6 [3]
http://inproperinla.com/06-11-09-doc-38-1-countrywide-mclaurin-false-declarations.pdf
7 http://inproperinla.com/06-11-09-doc-38-2-countrywide-mclaurin-false-declarations. pdf
[4]
8 http://inproperinla.com/07-02-08-countrywide-fraudulent-subpoena-production-c-s. pdf
[5]
9 http://inproperinla.com/09-01-13-cw-motion-sanctions-osc-contempt-S. pdf
http://inproperinla.com/09-01-13-moldawsky-notice-of-motion-sanctions-contempt.pdf
10 http://inproperinla.com/09-01-13-document-1.pdf
http://inproperinla.com/09-02-17-document-1.pdf
http://inproperinla.com/09-02-17-document-2.pdf
11 http://inproperinla.com/09-02-17-document-3.pdf
[6]
12 I have no such record. I expect CFC/SAC to produce the record.
13 83) The same records are provided herein as evidence, as noted in the Table of
14 Exhibits, above, with the following changed:
15 a. Due to its large volume, ofthe Countrywide subpoena production (#4),
16 was replaced with a record organizing key documents from that
17 production that demonstrated the false nature of Samaan's loan
18 applications and the false nature of their underwriting by Countrywide.
19 It also facilitates contrasting such records with the false and deliberately
20 misleading declarations by Countrywide Branch Manager Maria
21 McLaurin.
22 b. Fraud expert/record examiners opinion letters were added, where
23 applicable.
24 c. Additional Biyan Cave, LLP were 'provided, which I believe make it
25 easier to detect the false and deliberately misleading nature of their
26 conduct.
27 III
28

Case # 05-90374
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-
1 V.
THOSE WHO WOULD NOT RESPOND AT ALL
2 III
3 Countrywide's Monlo and Samuels
4 84) For over two years, while I have been allegedly harassed and abused by
5 Countrywide, Bryan Cave, LLP, and others, Angelo Mozilo - Chair & CEO and
6 Sandor Samuels - Chief Legal Officer, refused to provide any assistance in
7 preventing the fraud being allegedly perpetrated against me. Instead, they
8 arranged a campaign of increased harassment by Bryan Cave, LLP. At the same
9 time they advertised on the web their full commitment to fight frauds and to
10 ethically conduct the business of their corporations, as seen in Exhibits 1-4 to
11 my April 12, 2008 Notice #2 to this Honorable Court.
12 85) In fact, particularly harsh retaliation started once I acted upon such web-
B advertisements and left a request at the offices of The House of Justice-
14 Bet Tzedek, where Sandor Samuels served as president at that time. Such
15 request was in response to Mr Samuels own solicitation for fraud victims to call
16 him for help (Exhibit #2, my April 12, 2009 Notice #2). My request for
17 help was filed in a brown sealed envelope, addressed to the "President of The
18 House of Justice - Bet Tzedek", Sandor Samuels, and was also marked
19 "Personal & Confidential." In it, I requested that he authenticate or
20 repudiate "Key Record #1", Exhibit B(l) in this filing.
21 Bank ofAmerica: General Counsel. President & Audit Committee
22 86) Multiple requests for help and protection were filed with Bank of America
23 Corporation, starting February 2008.
24· 87) No response at all was ever received, except for the letter of February 2008,
25 Exhibit A(l1) in instant filing.
26 Current President - Mitchell Kamin, and Board of Directors of The
House ofJustice
27
28

Case # 05-90374
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88) The House of Justice, Bet Tzedek, is possibly the most visible Jewish
2 and/or Legal Charity in Los Angeles. Its Board of Directors lists partners from
3 many of the best recognized, largest law-firms in the U.S.
4 89) The House of Justice, Bet Tzedek provides free legal services - a worthy
5 . cause.
6 90) The Los Angeles County Consumer Affairs Bureau referred me to The
7 House of Justice- Bet Tzedek - as particularly known for its expertise in re:
8 real estate frauds.
9 91)The House of Justice, Bet Tzedek should be held doubly accountable: Not
10 only did Sandor Samuels serve as its President, but also David Pasternak, signer
11 of the Grant Deeds, deemed fraud by decorated veteran FBI agent/fraud expert.
12 92) Regardless, its Board of Director, its current President and Executive refuse
13 multiple requests to answer a simple question:
14 Does the House ofJustice have bylawsfor handling
grievances against its officer(s)?
15
The Jewish Federation ofLos Angeles
16
93) Requests for help regarding the lack of response from The House of Justice
17
were also forwarded to the President of the Jewish Federation of Los Angeles,
18
with whom The House of Justice is affiliated.
19
94) No response was ever received to multiple requests for assistance.
20
Copies of this record are filed also with following parties
21
95) This record is also filed with the following parties, as a request for urgent
22
corrective actions:
23
a. BAC Audit Committee as an entirely new complaint by an individual
24
seriously harmed by BAC and Countrywide, by a share-holder and by
25
deposit account owner. I hope and expect that the BAC Audit
26
Committee would at least acknowledge receipt of this record.
27
28

Case # 05-90374
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b. President and the Board of Directors, The House of Justice, Bet Tzedek,
Los Angeles.
c. President and Board of Directors, Jewish Federation of Los Angeles,
with whom the House of Justice is affiliated.
'{,espectfully submitted, April 15 2009, La Verne, California,
Joseph Zernik
inprose
VI.
VOLUMEA.
Letters. Email Notes & Miscellenaous
TABLE OF EXHIBITS
,( 'J)a September 7, 2004 Nivie Samaan's Prequalification Letter
A-5
htlp://inproperinla.com/04-09-07-samaan-s-pregualification-Ietter.pdf
,Vl)b In re: September 7, 2004 Nivie Samaan's Prequalification Letter

- Fraud Expert/Record Examiner report A-8
htlp://inproperinla.com/04-09-07-opinion-letler-fraud-in-pregualificaion-Ietter-s.pdf
"(2) July 10,2006 Samaan's Deposition A- 2 5

http://inproperinla.com/06-07-10-samaan-deposilion.pdf
.~. (~) March 16; 2007 my Meet & Confer Letter ................. A-55
htlp://inproperinla.com/07-03-16-Countrywide-meet-&-confer-s.pdf
t.~ 4) June 23, 2007 my Letters to Mozilo & Samuels A-63

http://inproperinla.com/07-07-03-moldawsky-notice-of-ex-parte-gag-order.pdf
5) July 3, 2007 Att Jenna Moldawsky, Bryan Cave, LLP, Letter

Case # 05-90374
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· A-lll
" http://inproperinla.com/07-07-03-moldawsky-notice-of-ex-parte-gag-order.pdf
A(6) July 11, 2007 Countrywide Legal Department Att Todd Boock
Declaration A-114
http://inproperinla.com/07-07-11-countrywide-boock-declaration-for-motion-july-23-2007-for-protective-gag-order-
s.pdf
4 (7) October 22, 2007 Att Moldawsky, Bryan Cave, LLP, Email Note
••••..••....••.•• A-120
http://inproperinla.com/07-1 0-22-brvan-cave-moldawsky-on-appearance-enli rely-proper-s. pdf
.![I
,A(8) October, 2007- Att John Amberg, Bryan Cave, LLP, Email note
I
....••••.......•• A-122
http://inproperinla.com/07-10-02-brvan-berg-att-amberg-decline-lo-gel-further-involved-s.pdf
(9) In re: November-December 2007 Att David Pasternak's Grant

Deeds - Fraud Expert/Document Examiner report
................. A-128
http://inproperinla.com/07-12-17-wedick.memo.nolarized.deeds.zemik.2009.02.05-s .pdf
http://inproperinla.com/07-12-17-grant-deeds-wedick-s-opinion-s. pdf
10) January 27,2008 Table: Countrywide's Party Designations

............. A- 1 57
http://inproperinla.com/08-01-27-countrywide-in-samaan-v-zemik-s.pdf
• l 17) February 4, 2008, my letter to Kenneth Lewis III, President, BAC,

& February 12,2008 response from Lewis's office ......• A-163
http://inproperinla.com/08-02-04-letter-to-officers-of-bac-re-countrywide-s.pdf
http://inproperinla.com/08-02-12-bac-lewis-response-from-office-of-chair-to-Ietter-re-countrywide-s.pdf
Ii (12) December 9, 2008 Countrywide, Legal Department, Att Todd

Boock, Email note .••........•....• A-167
http://inproperinla.com/08-12-09-counlrywide-todd-boock-refusal-to-respond-december-2008-to-march-2009-
s.pdf
;(13)California State Bar - Rules ofProfessional Conduct

................. A- 1 79
I
http://inproperinla.com I og-04-13-california-state-bar-rules professional-conduct-s.pdf
I

Case # 05-90374
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1 VII.
VOLUMEB.
2 Papers Filed in Court
3 "Key Records" - that BAC Audit Committee is asked to either authenticate or
repudiate and withdraw from court records.
4
5 TABLE OF EXHIBITS
6
7 B(l)a Purported October 14, 2004, or mid-October 2004fax
transmission 1m Countrywide ofan Underwriting Letter.. B-S
8
B(2)a Purported October 25, 2004fax transmission to Countrywide ofa
9 Real Estate Purchase Contract ................• B-60
http://inproperinla.com/04-1 0-25-contract-from-cfc-subpoena-parks-s.pdf
10
B(2)b In re: Purported October 25, 2004 Fax Transmission to
11 Countrywide ofReal Estate Purchase Contract
12 http://inproperinla.com/04-1 0-25-doc-45-countrywide-fraud-contract-record.pdf
13 B(3) July 2006, Feb 8, 2007, April 2007 Countrywide's subpoena

productions ................• B-I0S
14 http://inproperinla.com/07-02-08-countrywide-fraudulent-subpoena-production-c-s.pdf
15
B(3)a Samaan's Loan Applications (1003s)
16 http://inproperinla.com 104 -09-2z-sarnaan-countrywide-fraudulent-loan-application.pdf
17 B(3)b In re: Samaan's Loan Applications (1003s)- Record

http://inproperinla.com/04-09-2z-opinion-Ietter-fraud-in-1oan-applications-signature-s.pdf
18 B(3)c In re: Samaan's Loan Applications (1003s)
http://inproperinla.com/04-oq-2z-doc-4o-sarnaan-fraudulent-Ioan-applications-s.pdf
19
B(4) November 9. 2006 Letter & Subsequent Declarations by
20 Countrywide, San Rafael Branch Manager Maria McLaurin
21 ................. B-289
http://inproperinla.com/o6-11-og-doc-38-1-countrywide-rnclaurin-false-declarations.pdf
22 http://inproperinla.com/o6-n-oq-doc-38-2-countrywide-rnclaurin-false-declarations.pdf
23 B(5) Selection ofpapersfiled by Bryan Cave, LLP ....••.........•• B-347
. 24 B(5)a July 6, 2007 Ex Parte Applicationfor a Protective Order deemed
"Gag Order" in a "dark court room" B-348
http://inproperinla.com/oz-oz-o6-countJYWide-gag-order-rnotion-in-full-s.pdf
26 B(5)b March 7, 2008 Countrywide Applicationfor Sanctions and OSC
27 re: Contempt,fi'ed by Bryan Cave, LLP B-4S8
htt;p:llinproperinla.com/oq-0l-13-cw-rnotion-sanctions-osc-conternpt-S.pdf
28

Case # 05-90374
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B(S)c February 17, 2009, Motionfor a sanctions and OSC in re:

Contemptfiled Bryan Cave, LLP B-660
2
http://inproperinla.com/o9-01-13-moldawskv-notice-of-motion-sanctions-contempt.pdf
3 B(6) A July 23, 2007 purported Protective/Gag Order.
4 ................. 8-827
5
6
VIII.
STATEMENT OF VERIFICATION
7
I, Joseph Zernik, have writtn and re-read the foregoing:
8
Notice #3 To Hon Jeff Bohm, Pursuant To Memorandum Opinion, Doc #248,
9 March 5, 2008, Stating: "The court will continue to verify that its trust is well-
10
placed" - records filed as evidence.
I know the content thereof to be true and correct. It is true and correct based
11
on my own personal knowledge, except as to those matters therein stated as based
12
upon information and belief, and as to to those matters, I believe them to be true
13
and correct as well.
14
The exhibits provided with this record as listed in the foregoing "Table of
15
Exhibits" as Volume A and Volume B, are true and correct copies of records in
16
my possession, except for Exhibit B6, which I do not have in my possession, never
17
had in my possession, and I do not believe has ever existed in the first place. It is
18
listed here only since Countrywide and its counsel hve repeatedly claimed it
19
existed, but never produced it. Its listing here is meant as a request for the Audit
20
Committee to either authenticate and produce such records; aleternatively - to
21
repudiate any claims for its existence.
22
I make this declaration that the foregoing is true and correct under penalty of
23
perjury pursuant
.
to the laws of the United
.
States.
24
Executed here in La Verne, County of Los Angeles, California on this 15th day
25
in April, 2009.
26
27
Joseph Zernik
28 znpro se

Case # 05-90374
34/36
NAME. ADDRESS AND TELEPHONE NUMBER OF ATTORNEY(S)

Joseph Zernik, DMD, PhD
PO Box 526 La Verne California 91750
Tel: 310435 9107 Fax: 8019980917
Email: jzI2345@earthlink.net
UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA
WILLIAM ALLEN PARSLEY Borrower CASE NUMBER
PLAINTIFF(S) , 05-903-74
v.
PROOF OF SERVICE - ACKNOWLEDGMENT

OF SERVICE
DEFENDANT(S).
I, the undersigned, certify and declare that I am over the age of 18 years, employed in the County of
Los Angeles • State of California. and not a
party to the above-entitled cause. On APRil 15 ,20 09 , I served a true copy of
NOTICE #3, PURSUANT TO MARCH 5, 2008 MEMORANDUM OPINION.
by personally delivering it to the person (s) indicated below in the manner as provided in FRCivP 5(b); by
depositing it in the United States Mail in a sealed envelope with the postage thereon fully prepaid to the following:
(list names and addresses for person(s) served. Attach additional pages if necessary.)
Place of Mailing: ---::L:-::A=-=-:V=-:E::-RN---::-E=--,_CA_L_I_F_O-::RN:-::-I_A ::-:-----:::-::== _

Executed on APRIL 15 ,20- 09 at LA VERNE
------- - - - - - - - - -,California
Please check one of these boxes if service is made by mail:
D I hereby certify that I am a member of the Bar of the United States District Court. Central District of
California.
D I hereby certify that I am employed in the office of a member of the Bar of this Court at whose direction the
service was made.
D I hereby certify under the penalty of perjury that the foregoing is true and correct.
Signature of Person Making Service
ACKNOWLEDGEMENT OF SERVICE
I, , received a true copy of the within document on _
Signature Party Served
CV-40 (01/00) PROOF OF SERVICE - ACKNOWLEDGMENT OF SERVICE
35/36
36/36

United States Court District of Columbia

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Joseph Zernik

1853 Foothill Blvd

UNITED STATES COURT

VERIFIED NOTICE #6: NOTICE #3 TO THE HONORABLE JEFF BOHME,

Dated: May 18, 2009 Respectfully submitted, by:

UNITED STATES COURT

SHARON DIANE HILL CASE No 01-22574

VERIFIED NOTICE #6: NOTICE #3 TO THE HONORABLE JEFF BOHME,

Dated: May 18, 2009 Respectfully submitted, by:

Dated: May 18, 2009 Respectfully submitted, by:

I, Joseph H Zernik, have written and re-read the foregoing:

,i:nc (801) 998 0917

UNITED STATES BANKRUPTCY COURT

"VJLLIAMALLEN PARSLEY CASE, ,.tt: 05-90374

"THE OmRT WILL CONTINUE TO VERIFY

FULlS D{SCLOSURE OF THE

FILED UNDER SEPARATE COVERS:

April 12, 2009; NOTICE #2, RE: CFC/BAC

2 TO THE COURT OF THE HONORABLE JEFF BOHM, U.S. JUDGE, HOUSTON,

3 TEXAS, TO PARTIES AND COUNSEL:

6 c. To act pursuant to Fed. Rule Civ. Proc. 8(f) "to do substantial

April 12, 2009; NOTICE #2, RE: CFC/BAC

April 12, 2009; NOTICE #2, RE: CFC/BAC

April 12, 2009; NOTICE #2, RE: CFC/BAC

Compare to July 11, 2007 Boock Declaration (Exhibit A(6)).

April 12, 2009; NOTICE #2, RE: CFC/BAC

c) Sarbanes-Oxley Act (2002): The language used by Att Boock to describe

The phrase "compliance with the law" is also conspicuously missing.

April 12, 2009; NOTICE #2, RE: CFC/BAC

d) Frazier: One of the main objectives ofthe purported July 23,2007

April 12, 2009; NOTICE #2, RE: CFC/BAC

10 appearances by Bryan Cave, LLP attorneys in the affair of Samaan v

11 Zernik (SCo87400), which he continues to refuses to provide to this

17 that Att Todd Boock claims prohibits me from communicating with

18 him, Att Amberg states:

April 12, 2009; NOTICE #2, RE: CFC/BAC

April 12, 2009; NOTICE #2, RE: CFC/BAC

14 My letter noticed Mr Lewis and other members of the Board of Directors of

15 alleged material violations of the law at Countrywide:

April 12, 2009; NOTICE #2, RE: CFC/BAC

In response I was informed:

April 12, 2009; NOTICE #2, RE: CFC/BAC

banking records in compliance with UETA relative to electronic transactions.

April 12, 2009; NOTICE #2, RE: CFC/BAC

April 12, 2009; NOTICE #2, RE: CFC/BAC

April 12, 2009; NOTICE #2, RE: CFC/BAC

1 This ex parte application was conducted in a "dark courtroom" (both

26 Such practice is explicitly prohibited by the Universal Declaration ofHuman

April 12, 2009; NOTICE #2, RE: CFC/BAC

April 12, 2009; NOTICE #2, RE: CFC/BAC

1 • On behalf of whom did Bryan Cave, LLP, receive payments of

April 12, 2009; NOTICE #2, RE: CFC/BAC

April 12, 2009; NOTICE #2, RE: CFC/BAC

April 12, 2009; NOTICE #2, RE: CFC/BAC

April 12, 2009; NOTICE #2, RE: CFC/BAC

,( 'J)a September 7, 2004 Nivie Samaan's Prequalification Letter

,Vl)b In re: September 7, 2004 Nivie Samaan's Prequalification Letter

"(2) July 10,2006 Samaan's Deposition A- 2 5

t.~ 4) June 23, 2007 my Letters to Mozilo & Samuels A-63

5) July 3, 2007 Att Jenna Moldawsky, Bryan Cave, LLP, Letter

April 12, 2009; NOTICE #2, RE: CFC/BAC

(9) In re: November-December 2007 Att David Pasternak's Grant

10) January 27,2008 Table: Countrywide's Party Designations