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Daniel Cooper, In Propria Persona

Daniel Cooper 1836 10th Street #B Santa Monica, CA 90404 310-562-7668 IN PROPRIA PERSONA

SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES

12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Elia WEINBACH, an individual; Defendant. vs. Daniel COOPER, an individual; Plaintiff,

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Los Angeles County Case No.

COMPLAINT FOR DECLARATORY RELIEF AND FOR DAMAGES DEMAND FOR JURY TRIAL

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Table of Contents

INTRODUCTION..............................................................................................4 PARTIES..........................................................................................................4 JURISDICTION................................................................................................4 ASSIGNMENT AND VENUE...........................................................................4 GENERAL ALLEGATION...............................................................................5 FIRST CAUSE OF ACTION..........................................................................17 SECOND CAUSE OF ACTION.....................................................................18 THIRD CAUSE OF ACTION..........................................................................20 FOURTH CAUSE OF ACTION......................................................................21 FIFTH CAUSE OF ACTION...........................................................................22 SIXTH CAUSE OF ACTION..........................................................................23 SEVENTH CAUSE OF ACTION....................................................................26 PRAYER FOR RELIEF..................................................................................27 DEMAND FOR JURY TRIAL.........................................................................29

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APPENDIX 1 Documentation of payments to Elia WEINBACH......................A2 APPENDIX 2 Child Support Services Department Budget ............................A5 APPENDIX 3 Title IV-V Child Support Program Duties ...............................A11 APPENDIX 4 Trial Court Operations Budget Summary ...............................A16 APPENDIX 5 Text of SBX2 11.....................................................................A21 APPENDIX 6 Litigation Cost Manager Report, Public Summary .................A25

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Table of Authorities Cases Page

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Austin v. Smith, 312 F2nd. 337,343 (1962)...................................................................................7 Caperton v. A.T. Massey Coal Company, Inc., 566 U.S. ___ (2009) ...................................................................................13, 15 Carlson v. Eassa 54 CA4th 684,691, 62 CR2d 884, 888 (1997);....................................................7 Carr v. Kamins 151 CA4th 929, 933-934, 60 CR3d 196, 199 (2007)...........................................7 In Re Murchison, 349 U.S. 133, 136 (1955)..................................................................................13 Offutt v. United States, 348 U.S. 11, 14 (1954)......................................................................................15 Elliott v. Lessee of Piersol, 26 U. S. (1 Pet.) 328, 340 (1828).........................................................................6 Old Wayne Mut. Life Ass’n v. McDonough, 204 U.S. 8, 27 Sup.Ct. 236..................................................................................6 Residents for Adequate Water v. Redwood Valley County Water Dist. 34 CA4th 1801, 1805, 41 CR2d 123, 125 (1995)................................................7 Sturgeon v. County of Los Angeles, 167 Cal.App.4th 630, 84 Cal.Rptr.3d 242 (2008)..............................5, 12, 16, 26 Sturgeon v. County of Los Angeles ___Cal App.4th___(4th Dist.,Div. 1) (2010).................................................16, 26 U.S. v. Throckmorton, 98 U.S. 61 (1878)................................................................................................6 Vallely v. Northern Fire and Marine Co., 254 U.S. 348 (1920)........................................................................................6, 7 Wells, Res Adjudicata, Section 499................................................................................6

Statutes
California Code of Civil Procedure § ____ ............................11, 12, 14, 16, 23, 29 1997 Lockyer-Isenberg Trial Court Funding Act..............................................5, 12 U.S. Code Title 42, Chapter 7, Subchapter IV, Part D, Section 654......................8 U.S. Code Title 42, Chapter 7, Subchapter IV, Part D, Section 655................9, 11 U.S. Code Title 42, Chapter 7, Subchapter IV, Part D, Section 658a....................9 U.S. Code Title 42, Chapter 7, Subchapter IV, Part D, Section 666......................9

Other Authorities
California Senate Bill SBX2-11....................................................5, 6, 7, 12, 13, 14 California Code of Judicial Ethics............................................................11, 14, 22

Constitutional Provisions
California Constitution, Article I, Sec. 1.........................................................14, 23 California Constitution, Article I, Sec. 15.............................................................23 California Constitution, Article VI, Sec. 19.......................................................5, 12

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INTRODUCTION
1. This action arises from the divorce proceedings for Daniel Cooper and Maeve

Crommie. The presiding bench officers received bribes from L.A. County, did not disclose such, committed “fraud upon the court”, and still presided over the case. Plaintiff is suing for damages and for violations of his civil rights pursuant to 42 U.S.C. Section 1983.

PARTIES
2. Plaintiff, Daniel Cooer (“COOPER”), was at relevant times mentioned a resident of

the County of Los Angeles, State of California.
3. Plaintiff’s now ex-spouse, Maeve Crommie (“CROMMIE”) was formerly known as

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Maeve Cooper.
4. Defendant, Elia Weinbach (“WEINBACH)”, is employed by the State of California

as a Superior Court Judge, for the County of Los Angeles. WEINBACH has held that position since at least November 2007.

JURISDICTION 5. Plaintiff sues for violation of civil rights pursuant to 42 U.S.C. Section 1983.

ASSIGNMENT AND VENUE
6. The acts and omissions giving rise to Plaintiffs claims occurred in Los Angeles

County, California and therefore the appropriate venue for this action is Superior Court of California, Los Angeles County. Plaintiff seeks a judge who has not received “judicial benefits” and has no experience with Family Law, Title IV-D or Los Angeles County Domestic Violence programs.

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GENERAL ALLEGATION

7. At the time the family law case, SD026673, was filed in Superior Court in 2008

and throughout the proceedings, Plaintiff was not aware that Judge WEINBACH was receiving payments from L.A. County. At no time from the commencement of the filing of the case through the present did Judge WEINBACH disclose that he was receiving payments from L.A. County. At no time did he disclose that the L.A. County Child Support Services Department (CSSD) received Title IV-D funds from the federal and state governments based upon a percentage of the disbursements ordered by the L.A. County judges plus an incentive for collections above an annual “floor”.
8. In mid-2010, COOPER became aware of the decision of Sturgeon v. County of

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Los Angeles, 167 Cal.App.4th 630 (2008) Rev. denied 12/23/08, which held that the L.A. County payments to L.A. Superior Court judges violated Article VI, Section 19 of the California Constitution and that the 1997 Lockyer-Isenberg Trial Court Funding Act did not “prescribe” the payments of “judicial benefits” by counties to Superior Court judges.
9. In December 2010 COOPER sent a letter to Greg Iverson, Countywide Payroll

Division Chief, Los Angeles County Auditor Controller requesting information on judicial benefits that might have been paid to the judges in his case. Appendix 1 contains the correspondence with the county and the auditor’s information.
10. Subsequent to the Sturgeon decision, on 2/20/09, SBX2 11 was passed by the

California legislature and acknowledged the unconstitutional and illegal nature of the L.A. County payments by granting retroactive immunity. The full text of SBX2 11 is included in Appendix 5. Section 5 of SBX2 11 limited the immunity to “any liability or be subject to prosecution or disciplinary action because of benefits
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provided to a judge” effective 5/21/09. This ex post facto immunity did not and could not restore Plaintiff’s California Constitutional guarantees of due process and equal protection lost during the proceedings of Plaintiff’s family law case SD026673 under Judge WEINBACH.
11. SBX2 11 granted immunity for monies received prior to July 2009. The bill also

stated that the judicial benefits are not state payments. The same payments, which received immunity prior to July 2009, no longer have criminal immunity. Defendant is also now liable for criminal charges for the bribes taken in 2010 and 2011.
12. Los Angeles County is not a sovereign entity and therefore its actual payments to

a judge are no different than payments (hypothetically) by Plaintiff. Both are bribes. Judge WEINBACH’s acceptance of the L.A. County bribes voided all his orders and judgments. Judge WEINBACH’s failure to disclose the county payments constituted an extrinsic “fraud on the court”.
13. Defendant’s acceptance of the L.A. County bribes and his sitting on a case in

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which L.A. County was an interested party voided all his orders and judgments. Extrinsic fraud is a basis for setting aside an earlier judgment. The U.S. Supreme Court stated in U.S. v. Throckmorton, 98 U.S. 61 (1878): “There is no question of the general doctrine that fraud vitiates the solemn contracts, documents and even judgments” The Court continued at page 66: “Fraud vitiates everything, and a judgment equally with a contract...” (citing Wells, Res Adjudicata, Section 499) The U.S. Supreme Court further stated in Vallely v. Northern Fire and Marine Co., 254 U.S. 348 (1920): “Courts are constituted by authority and they cannot [act] beyond the power delegated to them. If they act beyond that authority, and certainly in contravention of it, their judgments and orders are regarded as

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nullities. They are not voidable, but simply void, and this even prior to reversal. Elliott v. Lessee of Piersol, 26 U. S. (1 Pet.) 328, 340 (1828): Old Wayne Mut. Life Ass’n v. McDonough, 204 U.S. 8, 27 Sup.Ct. 236” Since “fraud on the court” vitiates the entire case, all orders from that court or any subsequent court are void as none of the courts had subject matter jurisdiction. No court has the lawful authority to validate a void order; a void order is void at all times, cannot be made valid by any judge, nor does it gain validity by the passage of time, Vallely, supra. The order is void ab initio.
14. The 9th Circuit has stated in the case of Austin v. Smith, 312 F2nd. 337,343

(1962): “If the underlying judgment is void, the judgment based upon it is also void.”
15. All of Defendant’s orders are void and were void ab initio. Plaintiff sought to

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achieve certainty under the law with a new judicial officer who had not taken the illegal bribes. Plaintiff filed a Writ of Mandate on January 28, 2011, seeking to void all Defendant’s orders and judgments as well as seeking his recusal. Appeal may be taken from an order denying a motion to vacate a void judgment because denial of the motion constitutes an order giving effect to a void judgment and thus is itself void and appealable. [Carr v. Kamins (2007) 151 CA4th 929, 933-934, 60 CR3d 196, 199; Carlson v. Eassa (1997) 54 CA4th 684,691, 62 CR2d 884, 888; Residents for Adequate Water v. Redwood Valley County Water Dist. (1995) 34 CA4th 1801, 1805, 41 CR2d 123, 125]. The Second Appellate Court in Los Angeles County denied Plaintiff’s Writ of Mandate. Each of the Appellate court Judges received the L.A. County bribes while serving in the Superior Court. Civil suits are also being prepared against each of them for not recusing themselves and committing their own “fraud on the court”.
16. SBX2 11 provided immunity to all those governmental persons associated with

the paying or receiving of judicial payments. SBX2 11 did not address “fraud on

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the court” because it did not address or acknowledge any of the biases bought by the bribes for the counties.
17. Plaintiff’s January 2011 motion seeking to void Defendant’s orders identified and

clarified the nature of the bias introduced by the illegal payments. The linkage of federal Title IV-D funding to the county budgets and the L.A. County Child Support Services Department (CSSD) partnership with Judges is sufficient evidence of real and probable judicial bias against Plaintiff, purchased by the county’s illegal payments. This linkage is also documented further here in succeeding paragraphs.
18. Los Angeles County is the largest user of the Superior Court of California, County

of Los Angeles services. There are approximately, 2.7 million new cases each year: about 1.7 million traffic tickets, 500,000 criminal cases, 120,000 family law cases, and 150,000 civil lawsuits. The Office of the County Counsel provides quarterly reports to the supervisors on the projected costs to the county from ongoing litigation. This report is confidential and thus protects strategic and tactical planning discussions from being exposed to the public. Appendix 5 contains the 2007 -2008 report signed by the Litigation Cost Manager.
19. Family Law cases involve a large potential liability for the county. Federal funding

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of the Title IV-D programs covers many of the potential county costs but only if the state and county comply with federal guidelines. 20. L.A. County is an interested party in every divorce case because it receives Title IV-D money based upon the expenses of its Child Support Services Department with a “Floor” payment plus an incentive.
21. U.S. Code Title 42, Chapter 7, Subchapter IV, Part D, Section 654 states in

relevant part: A state plan for child and spousal support must – (1) Provide that it shall be in effect in all political subdivisions [counties] of the state;
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********** (4) provide that the state will -(a) Provide services relative to ....the establishment, modification, or enforcement of child support obligations... (b) Enforce any support obligation established with respect to -(1) A child with respect to whom the state provides services under the plan; or (2) the custodial parent of such child. ******* (7) Provide for entering into cooperative arrangements with appropriate courts and law enforcement officials... (a) To assist the agency administering the plan, including the entering into of financial arrangements with such courts and officials in order to assure optimum results under such program, and (b) with respect to any other matters of common concern to such courts or officials and the agency administering such plan ********* (13) Provide that the state will comply with such other requirements and standards as the secretary determines to be necessary to the establishment of an effective program for locating noncustodial parents, establish paternity, obtaining support orders and collecting support. 22. Title 42, Chapter 7, Subchapter IV, Part D, Section 655 sets forth the payments to the states and shows the amount of payments to the states. 23. Title 42, Chapter 7, Subchapter IV, Part D, Section 658a provides for incentive payments to the states. 24. Title 42, Chapter 7, Subchapter IV, Part D, Section 666 requires the states to have statutorily prescribed procedures to improve the effectiveness of child
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support enforcement.
25. A true and correct copy of the Fiscal Year 2005-2006 L.A. County Budget for

Child Support Services Department pages 59-62 is included in the Appendix 2 and is incorporated herein as if set forth in full. Such document shows the Child Support Services Department “establishes, modifies, and enforces financial and medical support obligations for children, enforces existing spousal support orders ... as required under federal and state law” (page 59). The Child Support Services Department received federal and state Title IV-D funding fiscal years 2003-2006 (pages 61-62).
26. Appendix 3, Guidelines Section 2 makes it clear that support orders must be

issued. (The callous disregard for paternity is an affront to, and blatant disregard to, the constitutional rights of a man receiving such a support order).
27. The L.A. County budget for the fiscal year 2005-2006 shows that the L.A. County

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Child Support Services Department received $103,083,000 Federal Tittle IV-D and $72,487,000 State Title IV-D for fiscal year 2003-2004; $125,545,000 Federal Tittle IV-D and $63,674,000 State Title IV-D budgeted for fiscal year 2004-2005, and $124,578,000 Federal Tittle IV-D and $62,475,000 State Title IV-D proposed for fiscal year 2005-2006. The budget shows that the Child Support Services Department has the Superior Court as a “collaborative partner” and that it “ establishes, modifies, and enforces financial and medical support obligations for children, enforces existing spousal support orders and determines parentage for children as required under Federal and state law.” Among the services it provides are “establishing parentage and child support orders”, “modify court orders” and enforce support obligations amongst others.
28. The L.A. County payments to the L.A. Superior Court judges influences the

judges to order higher support awards from noncustodial parents and establish mechanisms to require/enforce the ordering of higher support awards from noncustodial parents to enable L.A. County to receive greater monies under Title
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IV-D from the Federal and state governments to operate their Child Support Services Departments and foster care departments. The higher awards by the judges are made possible because there is no downside for the county. The higher awards reduce the likelihood that children and supported spouses will seek indigent aid from the county. The higher awards also increase the need and likelihood for enforcement. The punitive enforcement mechanisms and excessive interest rate increase the CSSD operations budget. Title IV-D sections 655 and 658 pay a percentage of the expenses related to support orders as well as incentives, related to a “floor” payment for a fiscal year. 29. Page 61 of the 2005-2006 L.A. County budget shows that the Title IV-D federal and state payments to L.A. County literally paid for the entire budget of Child Support Services Department for the fiscal years 2004-2006.
30. Since L.A. County is an interested party and since the judges receive bribes from

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the county, the judges must at a minimum inform parties that they are receiving such payments. Failure to do so is “FRAUD ON THE COURT”. 31. California Code of Judicial Ethics Canon 4D(1) prohibits a judge from engaging in any financial and business dealings that involve the judge in frequent transactions or continuing business relations with lawyers or other persons likely to appear before the judge or before the court in which the judge serves.
32. Canon 3E(2) requires the judge to disclose on the record information that is

reasonably relevant to the question of disqualification under Code of Civil Procedure (CCP) Section 170.1, even if the judge believes there is no actual basis for disqualification.
33. Canon 3E(1) requires a judge to disqualify himself or himself in any proceeding in

which disqualification is required by law. 34. CCP Section 170.1(a)(6)(A)(iii) states “A judge shall be disqualified if any one or more of the following is true: .... A person aware of the facts might reasonably entertain a doubt that the judge would be able to be impartial”.
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35. Defendant violated Canon 4D(1) by taking payments from L.A. County, violated

Canon 3E(2) by not disclosing such payments on the record, and violated Canon 3E(1) and CCP Section 170.1(a)(6)(A)(iii) by not disqualifying himself.
36. The L.A. County payments to L.A. Superior Court judges were held to violate

Article VI, Section 19 of the California Constitution in the case of Sturgeon, supra. SBX2 11 did not change the California Constitution, did not make the judicial benefits a state obligation, and therefore continuing payments also violate the Constitution.
37. Appendix 4 incorporates herein as if set forth in full a true and correct copy of the

L.A. County Fiscal Year 2010-2011 Proposed Budget Trial Court Operations pages 60.1 to 60.4. Such section shows that the “judicial benefits” are required to be paid under the 1997 Lockyer-Isenberg Trial Court Funding Act. This is a false statement as the Sturgeon case held that the 1997 Trial Court Funding Act did not “prescribe the payment of judicial benefits by counties under Article VI, Section 19 of the California Constitution”. All of the L.A. County budgets from 1998 onwards contain the same false statement.
38. Senate Bill SBX2 11 gave retroactive immunity because of benefits provided to a

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judge under the official action of a governmental entity. Senate bill SBX2 11 did not give retroactive immunity to judges who had received the county payments, did not disclose such and then presided over cases in which the county had an interest.
39. Defendant is not alone in committing “fraud on the court” by refusing to disclose

the L.A. County payments and refusing to disqualify himself in cases in which L.A. County was a party or had an interest and in violating Canons 4D(1), 3E(2), 3E(1) and CCP Section 170.1(a)(6)(A)(iii). It appears to be a tacit agreement amongst all of the L.A. Superior Court Judges and Court Judges, who have received L.A. County payments, and L.A. County and L.A. County’s attorneys, to conceal such payments from opposing parties and commit “fraud on the court” in any case in
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which L.A. County is a party or has an interest.
40. This type of action has been held to be a denial of due process in the U.S.

Supreme Court case of Caperton v. A.T. Massey Coal Co., Inc., 556 U.S. ___ (2009). The court stated at Slip Opinion page 16: .....just as no man is allowed to be a judge in his own cause, similar fears of bias can arise when, without the consent of the other parties, a man chooses the judge in his own cause.
41. The County-Auditor’s letter in Appendix 1, combined with the 2010-2011 L.A.

County proposed budget Trial Court Operations section in Appendix 4, demonstrates that L.A. County has “bought” the L.A. Superior Court without the consent of the “other party” opposing them. The L.A. County interest and partnership with the court is clearly documented in Appendix 2 for all Family Law cases.
42. Defendant’s actions of taking the bribe and of “fraud on the court” have denied

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COOPER due process by denying him the right to an impartial tribunal. In Re Murchison, 349 U.S. 133, 136 (1955).
43. SBX2 11 was passed by the California legislature and acknowledged the

unconstitutional and illegal nature of the L.A. County payments by granting immunity. Section 5 of SBX2 11 limited the immunity to “any liability or be subject to prosecution or disciplinary action because of benefits provided to a judge”. This unconstitutional ex post facto immunity did not and could not restore Plaintiff’s California Constitutional guarantees of due process and equal protection lost during the proceedings of Plaintiff’s family law case SD026673 under Defendant, WEINBACH.
44. The parties require legal certainty to continue their lives. COOPER needs due

process and his Constitutional rights restored.
45. This case seeks damages for the injuries done to Plaintiff. Plaintiff seeks a

divorce judgment consistent with the California Constitution; especially Article 1
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Section 1. The “fraud on the court” has caused this case to be vitiated and the parties to be in “legal limbo”. This case needs finality and certainty, which it presently lacks. The case needs to be completed, finalized and legal certainty achieved to avoid problems in the future for the parties who are the victims of Defendant Elia WEINBACH’s “fraud on the court”, violations of the Canons of the Code of Judicial Ethics and violation of the California Code of Civil Procedure.
46. In addition to the “fraud on the court”, Defendant also violated California Code of

Judicial Ethics Canon 4D(1), which prohibits a judge from engaging in any financial or business dealings with a person who is likely to appear before the court upon which the judge serves; Canon 3E(2) which requires the judge to disclose on the record information that is reasonably relevant to the question of disqualification under CCP section 170.1, even if the judge believes there is no actual basis for disqualification; Canon 3E(1) which requires a judge to disqualify himself in any proceeding in which disqualification is required by law and CCP Section 170.1(a)(6)(A)(iii) which states:” A judge shall be disqualified if any of the following are True.... A person aware of the facts might reasonably entertain a doubt that the judge would be able to be impartial.
47. Senate bill SBX2 11 did not give immunity to a judge who did not disclose the

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county payments and then presided over a case in which the county had an interest or was a party. Here the L.A. County Child Support Services Department is an interested party as it “establishes financial ...support obligations for children, enforces existing spousal support orders... as required under federal and state law” and is a “collaborative partner” with the Superior Court (see Appendix 2, pages 59-60).
48. The L.A. County Payments are “bribes” as they “influence” Judges to award

unequal custody and thus by CSSD guidelines establish higher custody payments from noncustodial parents. The L.A. County Child Support Services Department “establishes financial .... support obligations for children... as required under
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federal and state law” and works as a “collaborative Partner” with the Superior Court. The payment of money by L.A. County, to the judge who rules on the amount of child support (which taken in the aggregate) directly determines the expenses of the L.A. County Child Support Services Department. The amount of those expenses then directly determines the amount of money that the L.A. County Child Support Services Department receives in Title IV-D federal and state funds. 49. The higher the number and monetary amount of support orders against noncustodial parents, the higher the expenses of the L.A. County Child Support Services Department, the higher the amount of Title IV-D federal and state funding. L.A. County has a direct interest in the judge setting the greatest number and the highest monetary child support orders. L.A. County is a “real party in interest” in every divorce case as it reaps a financial benefit.
50. The payments by L.A. County to the judge in a divorce case have no purpose

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other than to influence the judge’s decision to create a non-custodial parent and high child support order, thus protecting the county interests.
51. The U.S. Supreme Court has stated in the case of Offutt v. United States, 348

U.S. 11, 14 (1954): “A judge receiving a bribe from an interested party over which he is presiding does not give the appearance of justice.” In essence, by making all L.A. Superior Court judges “eligible” for the L.A. County payments, L.A. County has “bought the L.A. Superior Court”. The U.S. Supreme Court stated in the case of Caperton v. A.T. Massey Coal Co., Inc., 566 U.S. ___ (2009) at Slip Opinion page 16 in relevant part: ……..just as no man is allowed to judge his own cause, similar fears of bias can arise when, without the consent of the other parties, a man chooses a judge in his own cause. 52. By making the payments available to every L.A. Superior Court judge, no party in a divorce case received a fair trial, as the judge was biased to rule to benefit the
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L.A. County Child Support Services Department over the interests of the “parties” to the case.
53. The Sturgeon case showed that L.A. County had been making illegal payments to

L.A. Superior Court judges since the late 1980s. From that time through the present, L.A. County and the L.A. Superior Court judges and court Judges who received such illegal payments committed “fraud on the court”, by not disclosing such. The L.A. Superior Court judges and Judges also committed fraud upon the court by not disqualifying themselves. They also violated Canons 4D(1), 3E(2), 3E(1) and CCP Section 170.1(a)(6)(A)(iii). 54. The result of these actions is that all cases were vitiated and all orders and judgments in the cases were void. The parties are left in a “legal limbo” without any certainty. An entire legal system was corrupted.
55. This civil complaint seeks damages against Defendant for his denial of Plaintiff’s

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civil rights. The current court partnership, built over 25 years of county bribes and federal incentives, is corrosive to the State of California’s due process and equal protection guarantees and even to its fundamental constitutional guarantee that, SECTION 1. All people are by nature free and independent and have inalienable rights. Among these are enjoying and defending life and liberty, acquiring, possessing, and protecting property, and pursuing and obtaining safety, happiness, and privacy.
56. The Fourth Appellate Court’s decisions in the Sturgeon, supra , and Sturgeon v.

County of Los Angeles, __Cal App.4th___(4th Dist.,Div. 1) (2010), the so-called “Sturgeon I and II”, cases clearly stated that the judicial payments were unconstitutional. The legislature confirmed the payments were illegal by giving the judges limited immunity due to the bribes. Plaintiff’s case was heard during this time in L.A. Superior Court. Plaintiff has established the nature of the bias “bought” by the county. The orders and judgments in case SD026673 are void. Judge WEINBACH has refused to recuse himself.

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57. Plaintiff is seeking a jury trial on the issues. Plaintiff is also seeking an award for

consequential damages and for denial of his civil rights.

FIRST CAUSE OF ACTION (Denial of due process in domestic violence allegations)
58. Plaintiff COOPER re-alleges and incorporates by reference paragraphs 1 through

57, inclusive, of this Complaint (including all paragraphs of the Appendix and all paragraphs of all preceding causes of action, if any) as if the same were fully set forth herein.
59. Defendant’s practices and conduct have violated Plaintiff’s freedom,

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independence and inalienable rights guaranteed under the Constitution of the State of California.
60. On or about October 2008, a false allegation of domestic violence by CROMMIE

led to a Temporary Restraining Order (TRO) that forced Plaintiff to move out of the marital home and leave his children.
61. On or about June 2010, Defendant failed to provide Plaintiff due process in

resolving competing allegations of domestic violence. Defendant failed to notify the District Attorney’s Family Violence Division, which handles cases in Downtown Los Angeles and the surrounding areas. The District Attorney’s Office will file criminal charges whenever there is legally sufficient evidence of a family violence crime. No referral was made to the District Attorney, no public defender was appointed to represent Plaintiff for the domestic violence charges. No criminal convictions were sought or obtained.
62. Defendant’s refusal to insist on criminal prosecution for domestic violence

allegations reduced the workload of the District Attorney’s Office and thus reduced L.A. County costs. The L.A. County bribe worked! Based on the administrative review of the COOPER and CROMMIE domestic violence filings
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and statements, Defendant sided in favor of CROMMIE, ordered Plaintiff to remain away from the marital home and denied Plaintiff equal access to his children.
63. Defendant consented to Title IV-D incentives to accept into family court a criminal

allegation because a hearing in Family Court provided justification for a lop-sided custody award and increased child support order to meet Title IV-D incentives.
64. Plaintiff seeks $500,000 in damages for the emotional distress of being treated

like a criminal when in fact he was innocent.

SECOND CAUSE OF ACTION (Refusal to grant equal 50% custody)

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65. Plaintiff COOPER re-alleges and incorporates by reference paragraphs 1 through

57, inclusive, of this Complaint (including all paragraphs of the Appendix and all paragraphs of all preceding causes of action, if any) as if the same were fully set forth herein.
66. Plaintiff has an inalienable right to raise his children. Each parent has an equal

50% right to their children. Defendant’s custody order is capricious and without merit and designed solely to generate the largest Title IV-D support payment possible.
67. On or about April 2009, Defendant’s final trial judgment made permanent the

temporary custody arrangement created by the TRO. Plaintiff was permanently forced out of his house and forced to leave his children. Defendant provided CROMMIE with de facto primary custody.
68. The responsibility to support children is also shared equally by each parent.

Defendant never asserted that responsibility to CROMMIE. Instead, Defendant, allowed CROMMIE to go to school rather than work full-time in her profession as a specialty nurse. Full time earnings would have reduced child support owed by
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Plaintiff. Plaintiff was thus left to conclude that Defendant intended to order Plaintiff to assume an unequal share of the parental financial responsibility.
69. The support order was generated using the Title IV-D influenced support

calculator promulgated by the Los Angeles County Child Support Services Department (CSSD). Plaintiff’s current income was clearly shown as zero. Defendant, however, used the monthly average income for support calculation. Defendant’s bias was further evident when CROMMIE became agitated at Defendant that support was too low. Defendant prompted CROMMIE for para 4062 childcare expenses. Plaintiff’s stated that such payments were fully reimbursed by the State and demanded evidence of net childcare expenses by CROMMIE. CROMMIE screamed at Defendant about the level of child support and was then forcibly removed from the Court. Defendant ignored the apparent perjury and then ordered the highest possible child support, in keeping with Title IV-D biases. The very next day Plaintiff, with no income, was in default on his child support payments.
70. Defendant’s partnership with the CSSD made him aware that CSSD would

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vigorously prosecute the defaulted child support. The first step by CSSD is to revoke a driver’s license. Defendant could easily foresee the situation that Plaintiff would have no vehicle insurance and no driver’s license but be attempting to search for work. The L.A. County bribes clearly influenced Defendant’s decisions.
71. Defendant also indicated he was in a big hurry to decide the case. 72. Plaintiff seeks damages in the amount of $500,000 for the alienation and

emotional distress of being deprived of his inalienable right to raise his children and enjoy stable and safe parental relations with his children as protected by the 14th Amendment to the United States Constitution.

73. Plaintiff seeks damages in the amount of $750,000 for the emotional distress and

injury of being placed in a “debtors prison” condition.
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THIRD CAUSE OF ACTION (Failure to exercise fiduciary responsibility for family assets) (By WEINBACH against COOPER)

74. Plaintiff COOPER re-alleges and incorporates by reference paragraphs 1 through

57, inclusive, of this Complaint (including all paragraphs of the Appendix and all paragraphs of all preceding causes of action, if any) as if the same were fully set forth herein.
75. Defendant failed his fiduciary responsibility by allowing uncontrolled legal

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expenses, not consistent with the marital lifestyle, assets or income and by failing to provide proper guidance for the parties in settling property claims.
76. Defendant failed his fiduciary responsibility by allowing CROMMIE to remain in

the marital home without the income to support the mortgage payments. CROMMIE’s gross monthly income was stated as $2,800. The mortgage payments totaled approximately $3,500 monthly. Defendant failed to monitor the parties home mortgage situation closely. 77. While failing to monitor CROMMIE’s progress fully supporting the family, Plaintiff is ordered to report weekly job searches directly to the Court.
78. Paragraph 14 of Defendant’s Final Judgment in SD026673 gave CROMMIE 120

days from July 8, 2009 to refinance the home. After 18 months CROMMIE had not completed the refinancing or a loan assumption. COOPER received no notification, communication or notices from an escrow company or Bank of America on the pending refinance. COOPER was aware that CROMMIE was not making the loan payments. CROMMIE’s default was the biggest impediment to getting the loan refinanced. 79. On about January 20, 2011 Plaintiff sought to protect his credit rating and future
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employability by seeking court authorization to allow him to sell the home. Defendant ignored Plaintiff’s claim and transferred the marital home to a biased third party without any admonition to protect Plaintiff’s credit rating. 80. Defendant’s irresponsibility caused a destruction of family assets far greater than any child or spousal support awards. Defendant’s irresponsibility cost the State and Federal government far more in education and retirement costs than could possibly have been saved by L.A. County welfare costs.
81. Defendant allowed the transfer of marital assets to one of the lawyers with whom

he had frequent contact, in violation of Canon 4D(1).
82. Plaintiff seeks $800,000 in compensatory damages for lifetime damage to his

credit rating.
83. Plaintiff seeks $200,000 in damages for allowing CROMMIE to remain in a home

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which she could not afford and thus diminishing the value of community property.
84. Plaintiff seeks $100,000 in damages for allowing CROMMIE to hire counsel,

which she could not afford and deplete community assets contrary to the marital lifestyle.

FOURTH CAUSE OF ACTION (Legal Fees)

85. Plaintiff COOPER re-alleges and incorporates by reference paragraphs 1 through

58, inclusive, of this Complaint (including all paragraphs of the Appendix and all paragraphs of all preceding causes of action, if any) as if the same were fully set forth herein.
86. Plaintiff broke no laws. Plaintiff had no need for a lawyer prior to divorce. Plaintiff’s

marital lifestyle and income level were not consistent with significant expenditures on legal fees. Plaintiff only needed the administrative services of the court and the principles of fairness that are typically associated with the Small Claims Court.
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87. On or about April 2009, Defendant indicated that he was in a hurry to decide the

dissolution case because the parties had been to court about 20 times.
88. California Code of Judicial Ethics Canon 4D(1) prohibits a judge from engaging in

… continuing business relations with lawyers or other persons likely to appear before the judge or before the court in which the judge serves. There were approximately 25 dates on which court proceedings took place. Using a cost of approximately $12,000 per day per courtroom, Defendant’s rush to justice cost the state (approximately 1/3 day on average per appearance) about $100,000. This does not include the state costs of the appellate court.
89. Since all orders in Plaintiff’s dissolution case are void, Plaintiff must now re-litigate

his marital dissolution to remove and compensate for Title IV-D biases and for any influence of L.A. County interests. This new litigation is estimated to easily exceed $300,000.
90. Plaintiff seeks $300,000 for injury and $250,000 in punitive damages.

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FIFTH CAUSE OF ACTION (Undeclared bribes from Los Angeles County caused fraud and bias)

91. Plaintiff COOPER re-alleges and incorporates by reference paragraphs 1 through

58, inclusive, of this Complaint (including all paragraphs of the Appendix and all paragraphs of all preceding causes of action, if any) as if the same were fully set forth herein.
92. L.A. County Auditor records clearly document, in Appendix 1, the payments to

Defendant. The payments are bribes, paid by L.A. County to influence the courts and reduce L.A. County liability.
93. Defendant also filed to campaign for a judicial office in 2010. The Form 700 did

not list Los Angeles County judicial payments. This constitutes electoral fraud.
94. Petitioner seeks punitive damages equal to all the bribes taken. The county
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auditor records show this total of $153,822

SIXTH CAUSE OF ACTION (Denied Constitutional Guarantees)

95. Plaintiff COOPER re-alleges and incorporates by reference paragraphs 1 through

58, inclusive, of this Complaint (including all paragraphs of the Appendix and all paragraphs of all preceding causes of action, if any) as if the same were fully set forth herein.
96. Defendant denied Plaintiff his 5th and 14th Amendment rights under the United

States Constitution and his similar rights under Article 1, Section 1 and Section 15 from the Constitution of the State of California.
97. Defendant’s payments from L.A. County from 2007 to 2010 are documented in

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Exhibit 1. Defendant heard Plaintiff’s case in 2009. No disclosure of the payments was made as required by CCP. This constituted “fraud on the court”. 98. Defendant filed papers to seek election as judge. The Fair Political Practices Commission (FPPC) requires filing of a Form 700 Statement of Economic Interests. The L.A. County payments are not included on that form as required by the FPPC. Failure to reveal such information constituted electoral fraud.
99. Defendant is sworn to uphold the laws and Constitutions of the United States and

the State of California. Defendant is assigned to hear Family Law cases in Los Angeles County. Litigants in his courtroom have a right to expect that any ruling will uphold all three bodies of law. The bribes from L.A. County call into question Defendant’s ability and willingness to “hold the balance nice, clear and true”, Tumey v. Ohio, 273 U.S. 510, 532 (1927). The bribes denied Plaintiff his right to due process of law in his courtroom. 100. The taking of money by a judge who does not “throw the case” is still corrupt.

Justice Posner of the 7th Circuit stated in his remarks relating to Sir Francis
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Bacon, that the judge who does not fulfill the “bargain” after he has taken the money is equally as corrupt as the judge who takes the money and fulfills the “bargain”.
101.

Defendant chose those portions of the law that favored L.A. County because

of its bribe. L.A. County maintains a General Relief program and a Family and Social Services program. In order to reduce the potential number of recipients and thus the costs, Defendant used child support provisions of family law to shift the potential burden of CROMMIE and the children from L.A. County onto Plaintiff. The Title IV-D calculations, used by Defendant, are not based on California and U.S. constitutional principles but rather on transferring the county’s welfare policy to a related/convenient single individual earner.
102.

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Full remediation of Plaintiff’s civil rights likely includes, at a minimum, the

complete separation of the family courts from all the county’s Title IV-D funded agencies. The current court partnership, built over 25 years of county bribes and federal incentives, is corrosive to the State of California’s due process and equal protection guarantees and even to its fundamental constitutional guarantee that, SECTION 1. All people are by nature free and independent and have inalienable rights. Among these are enjoying and defending life and liberty, acquiring, possessing, and protecting property, and pursuing and obtaining safety, happiness, and privacy.

103. Divorce is the action of separating two parties and returning them to their pre-

marriage status as free and independent individuals. L.A. County’s bribes guarantee that Plaintiff is not, and will never be, free and independent from his exspouse following his L.A. County divorce. Defendant did not select the law that upheld Plaintiff’s freedom and liberty.
104. Defendant’s Status order of 10-10-2003 changed the legal marital status of the

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parties CROMMIE and COOPER to separate individuals and removed any prior contractual obligations between CROMMIE and COOPER. Defendant failed to return each party to their full constitutional status prior to marriage, required in a “No Fault” divorce. By issuing inflated and unnecessary support orders between the parties, Defendant was solely protecting the interests of L.A. County.
105. California Family Law §4336 (b) states in relevant part “…..Nothing in this

subdivision precludes a court from determining that a marriage of less than 10 years is a marriage of long duration.“ This represents a lifetime penalty on Plaintiff that is without precedent outside of Family Law. It is patently unconstitutional but is written into the family law code and enforced because of the bribes by L.A. County and the Title IV-D funding incentives from the Federal Government, through the state, to Los Angeles County. Plaintiff has no confidence such a provision would not be invoked in the future by Defendant or other bribed judge. 106. The supported party in a divorce can enjoy any post-divorce self-betterment

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by the supporting party. Every salaried pay raise, every sales bonus raises the fear of a support modification hearing. Thus, the risk and reward tradeoff for any investment in one’s self or a business venture is seriously and negatively impacted. Any supporting spouse has a fiduciary responsibility to future business partners to disclose the adverse impacts of a possible CA Family Law §3651 proceeding.
107.

CA Family Law §3651 also applies to the success of this complaint. Plaintiff

therefore is requesting that any awards be placed in a blind charitable trust benefitting Plaintiff’s children and such non-profits as Plaintiff may designate.
108.

Plaintiff seeks $2,000,000 in compensatory damages and $1,000,000 in

punitive damages for violations of his constitutional rights.

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SEVENTH CAUSE OF ACTION (JURY TRIAL)

109.

Plaintiff COOPER re-alleges and incorporates by reference paragraphs 1

through 58, inclusive, of this Complaint (including all paragraphs of the Appendix and all paragraphs of all preceding causes of action, if any) as if the same were fully set forth herein.
110.

The Sturgeon, supra, case is an example of judges judging judges. Under the

best of circumstances this process upholds the rule of law. Introduction of bribes corrupts the process. Payment of “judicial benefits” to 80% of California judges over a 20-year period not only corrupts the individuals but also the entire system.
111.

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Plaintiff’s first choice was to have this matter fully addressed, decided and

remedied by the Appellate Courts. The Fourth Appellate Court, Fourth Division, in its December 28, 2010 ruling on “Sturgeon II” refused to order additional actions to eliminate the unconstitutional county payments. The court did not in any way rescind or modify its prior determination that the bribes were illegal. Therefore, the Fourth Appellate Court, Fourth Division noted that, following its Sturgeon II ruling, it anticipated additional challenges and remedies by taxpayers. The court, on its own, would not uphold Plaintiff’s constitutional rights.
112.

Individual judges and the court system will not stop this corruption and denial

of civil rights. Plaintiff, therefore, seeks a jury trial to achieve declaratory relief, compensatory relief and also punitive relief.
113.

Plaintiff seeks remediation of his impaired civil rights. The county’s welfare

biases introduced by the bribes can be partially ameliorated with an un-bribed judge. However, finding an un-bribed judge who is also un-biased by over 25 years of county-participation in Title IV-D funding incentives will be difficult. Plaintiff is seeking his constitutional rights, not easy solutions.

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PRAYER FOR RELIEF

WHEREFORE, Plaintiff prays as follows with regard to each of the above causes of action: AS TO THE FIRST CAUSE OF ACTION:
1. For general and specific compensatory damages of $500,000; 2. For attorneys’ fees and costs of suit herein according to proof; 3. For orders voiding all orders and judgments in case SD026673 4. For interest as allowed by law

AS TO THE SECOND CAUSE OF ACTION:
1. For general compensatory damages Plaintiff seeks an amount of $500,000

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for the alienation and emotional distress of being deprived of his inalienable right to raise his children.
2. For general compensatory damages Plaintiff seeks an amount of $750,000

for the emotional distress and injury of being placed in a “debtors prison” condition 3. For attorneys’ fees and costs of suit herein according to proof;
4. For orders voiding all orders and judgments in case SD026673

5. For interest as allowed by law

AS TO THE THIRD CAUSE OF ACTION:
1. Plaintiff seeks $800,000 in compensatory damages for lifetime damage to

his credit rating.
2. Plaintiff seeks $200,000 in damages for allowing CROMMIE to remain in a

home which she could not afford and thus diminishing the value of community property.
3. Plaintiff seeks $100,000 in damages for allowing CROMMIE to hire
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counsel, which she could not afford 4. For attorneys’ fees and costs of suit herein according to proof;
5. For orders voiding all orders and judgments in case SD026673

6. For interest as allowed by law

AS TO THE FOURTH CAUSE OF ACTION:
1. For general and specific damages, Plaintiff seeks compensatory damages

of $600,000 and $250,000 in punitive damages; 2. For attorneys’ fees and costs of suit herein according to proof;
3. For orders voiding all orders and judgments in case SD026673

4. For interest as allowed by law

12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 AS TO THE SEVENTH CAUSE OF ACTION: 1. A judge who has not received any county-provided judicial benefits 2. A jury trial 3. For attorneys’ fees and costs of suit herein according to proof;
4. For orders voiding all orders and judgments in case SD026673
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AS TO THE FIFTH CAUSE OF ACTION:
1. For general and specific punitive damages of $153,822;

2. For attorneys’ fees and costs of suit herein according to proof; 3. For interest as allowed by law

AS TO THE SIXTH CAUSE OF ACTION:
1. For general compensatory damages in the amount of $2,000,000.00; 2. For punitive damages in the amount of $1,000,000

3. For attorneys’ fees and costs of suit herein according to proof; 4. For interest as allowed by law

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5. For interest as allowed by law
6. For such ancillary orders and decrees as may be necessary to implement,

effectuate, carry out, and enforce said judicial determination; 7. For such other and further relief as the court deems just.

AS TO ALL CAUSES OF ACTION ABOVE:
1. For any awards to be placed in a charitable trust benefitting Plaintiff’s children

and such non-profit organizations as he may designate. CA Family Law §3651 still applies to the success of this complaint. 2. For attorneys’ fees and costs of suit herein according to proof;
3. For orders voiding all orders and judgments in case SD026673

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4. For interest as allowed by law 5. For such other and further relief as the court deems just and proper.

DEMAND FOR JURY TRIAL In accordance with California Code of Civil Procedure Section 631, Plaintiff hereby demands a jury trial for all issues triable by jury.

Dated:

March 21, 2011 By: __________________________ Daniel COOPER In Pro Per

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