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Dr Z Digitally signed by

Joseph H Zernik
Joseph Zernik, PhD DN: cn=Joseph H
Zernik, o, ou,
email=jz12345@ea
PO Box 526, La Verne, CA 91750; rthlink.net, c=US
Location: La Verne,
Fax: 323.488.9697; Email: jz12345@earthlink.net California
Date: 2010.03.06
11:33:06 -08'00'
Blog: http://inproperinla.blogspot.com/ Scribd: http://www.scribd.com/Free_the_Rampart_FIPs

March 6, 2010

Steven Goldman, Supervisor


White Collar Crime Squadron
Los Angeles FBI
Fax: 310 996 3359

Dear Supervisor Goldman and FBI Los Angeles:

Following are two records, combined, filed as complaint and request for investigation pertaining to real estate fraud, as
opined by decorated veteran FBI agent, James Wedick. Such fraud was committed by Countrywide Financial
Corporation (today part of Bank of America Corporation) and others against Dr Joseph Zernik. Request is also for return
of the robbed real estate property at 320 South Peck Drive, Beverly Hills, California, 90212, into possession of its lawful
owner – Dr Joseph Zernik.

Included are:

1) Addendum to complaint against Kenneth Kaiser - Assistant Director of FBI for criminal investigations filed with office of
Inspector General of US Department of Justice. The addendum again documents the facts related to real estate fraud
against Dr Zernik, which FBI so far refused to investigate.

2) New complaint against Brian Moynihan and Bank of America, for fraud in their response to Office of the Comptroller of
the Currency on the same matter.

I would be glad to answer questions or provide additional records to address any questions that you may have.

Truly,

Joseph Zernik, PhD


PO Box 526, La Verne, California 91750
Tel: 323.515.4583
Fax:323.488.9697
<jz12345@earthlink.net>
 Page 2/8 March 6, 2010

_______________________________
Document #1

10-03-04 Clarifications for complaint filed with office of DOJ-IG alleging fraud in responses of senior
US DOJ officers on US Congress.

US Department of Justice, Inspector General Glenn Fine


Attention: Pam, Investigations Division.
By fax: DOJ-IG 202.616.9898@metrofax.com 202.616.9881@metrofax.com

Dear Inspector General Fine:

Please accept this note and clarification for complaint first filed November 23, 2009, then re-faxed
December 2, 2009, which alleged fraud in responses of senior US DOJ officers on US Congress.
Listed below are the specific statements that I deemed false and deliberately misleading, and the
evidence for fraud.

Thank you for your consideration of this matter.

Truly,

Joseph Zernik, PhD


http://inproperinla.blogspot.com/
http://www.scribd.com/Free_the_Rampart_FIPs

Clarifications for Complaint to DOJ-IG

1) In August 2008, Dr Zernik requested assistance by US Congress in obtaining responses from FBI
and US Attorney General. Inquiries were issued by the Honorable Dianne Feinstein and the Honorable
Diane Watson on FBI and US Office of Attorney General - regarding refusal of such agencies to
respond on requests to enforce the law and provide Equal Protection in Los Angeles County,
California. i

2) In August-September 2008 responses were provided to US Congress by Kenneth Melson


Director of US Department of Justice, and Kenneth Kaiser Assistant Director of FBI for criminal
investigations.ii The responses dismissed Dr Zerniks complaints and requests for equal protection for
himself, and for all 10 million residents of Los Angeles County, California, with statements claiming
that:
a. Dr Zernik was complaining about procedures for real estate foreclosure cases,
b. Dr Zernik was complaining about being improperly fined, and
c. Dr Zernik provided insufficient facts to demonstrate a violation of federal law within our
investigative jurisdiction.
d. Dr Zernik provided insufficient facts to support the initiation of an FBI investigation.

3) Such statements were contrary to the facts in this matter, were false and deliberately misleading,
and were alleged as the core of the alleged fraud by senior US DOJ officers on US Congress:
a. No procedures for real estate foreclosure were involved in the case. Dr Zernik was never late
on any mortgage payment in his life, let alone party to any mortgage default, foreclosure or
bankruptcy. Such statement may be deemed upon review as groundless derogatory statement.
b. There never was any mention of being improperly fined in the complaints or the legal facts in
this matter.
c. Claims of insufficient facts to demonstrate a violation of federal law.., and insufficient
facts to support the initiation of an FBI investigation were directly contradicted by opinion
letter of James Wedick, iii fraud expert of the highest acclaim. Mr Wedick was an FBI veteran,
who had been decorated by US Congress, US Attorney General, and FBI Director. Mr Wedick
had been at the center of some of the highest profile FBI investigations of government
 Page 3/8 March 6, 2010

corruption in recent decades. Mr Wedick opined regarding conveyance of title on Dr Zerniks


Beverly Hills residence in December 2007, which was purportedly executed on behalf of the
Superior Court of California, County of Los Angeles fraud being committed and immediate
investigation should be instituted. [Italic emphasis in the original jz]
d. Claims of insufficient facts to demonstrate a violation of federal law.., and insufficient
facts to support the initiation of an FBI investigation were again directly contradicted in
August 21, 2008 email notice by Mr Wedick to Dr Zernik, iv In such notice, Mr Wedick
documented that he had been approached on that day by FBI agent LB Connoly, from the
mortgage fraud squad in Los Angels who was assigned to this case. Moreover, Mr Wedick
documented that FBI agent Connoly had looked at the documents and did think a fraud had
taken place.
e. In the same August 21, 2008 email notice by Mr Wedick to Dr Zernik, v Mr Wedick further
advised Dr Zernik, in what appeared as his conclusion from his discussion with FBI Agent LB
Connoly, that FBI would not investigate the case, if Dr Zernik would name judges of the
Superior Court of California, County of Los Angeles, as involved in the real estate fraud. In
fact, Mr Wedick was repeating advice that Dr Zernik had previously received from Mr Steven
Goldman, Chief of the White Collar Crime Squadron, FBI Los Angeles to file a complaint
(and invariably also declarations), where no involvement of judges in the fraud would be
mentioned. Dr Zernik considered such advise as coming close to inducing him to perjure
himself. There was no honest way to provide account of the real estate fraud in this case
without any mention of involvement of the judges of the Superior Court of California, County of
Los Angeles.
f. One should notice that the August 21, 2008 email notice, and related discussion between FBI
Agent Connoly and decorated veteran FBI Agent James Wedick took place on the very same
day that Kenneth Kaiser, Assistant Director of FBI for Criminal Investigations issued his letter to
the Honorable Diane Feinstein, including statements quoted above, which were the opposite of
what Mr Wedick reported as the understanding shared by him and Agent Connoly. Since there
seemed to have been no evidence of FBI investigation in this case either before or after that
date, it remained to be determined if there was a relationship between the issuance of the
letters to US Congress and the approach by FBI on Mr Wedick on that date.
g. One should notice that the August 21, 2008 email notice, and related discussion between FBI
Agent Connoly and decorated veteran FBI agent James Wedick took place prior to the
issuance by Kenneth Melson, Director of US Attorney Office of his letter to the Honorable
Diane Feinstein. [The letter itself, as provided, was undated, but it was estimated to have been
issued in early September 2008, based on first received stamp by Senator Feinsteins office,
dated September 9, 2008].

Links to records:
http://inproperinla.com/08-10-10-reply-modified-request-for-special-counsel-fbi-&-doj-as-filed-s.pdf
i August 2008 US Congress inquiries on FBI and US Attorney General Michael Mukasey in re: failure to respond to
complaints by Dr Joseph Zernik.
http://inproperinla.com/08-09-08-congressional-assistance-s.pdf
ii August-September 2008 responses by Kenneth Melson and Kenneth Kaiser to inquiries by US Congress on failure to
respond to complaints by Dr Joseph Zernik.
http://inproperinla.com/08-09-08-congressional-assistance-s.pdf
iii December 2007 Grant Deeds issued by Attorney David Pasternak on behalf of the Superior Court opinion letter of
fraud
expert, decorated FBI veteran James Wedick.
http://inproperinla.com/07-12-17-grant-deeds-wedick-s-opinion-s.pdf
iv August 21, 2008 FBI veteran, fraud expert James Wedicks email note to Dr Zernik, documenting that he was
approached
by FBI agent LB Connoly on that date:
http://inproperinla.com/08-08-21-refusal-to-investigate-fbi-wedick-letter-s.pdf
v August 21, 2008 FBI veteran, fraud expert James Wedicks email note to Dr Zernik, documenting that he was
approached
by FBI agent LB Connoly on that date:
http://inproperinla.com/08-08-21-refusal-to-investigate-fbi-wedick-letter-s.pdf

_______________________________
 Page 4/8 March 6, 2010

Document #2

10-03-06 Complaint and request for investigation by FBI, alleging criminal conduct including, but not limited to
fraud, by Brian Moynihan, President/CEO of Bank of America Corporation related to real estate fraud against Dr
Joseph Zernik at 320 South Peck Drive, Beverly Hills, CA 90212

Overview

The office of Attorney General of the State of New York was focused on pursuing alleged securities fraud by senior
officers of Bank of America Corporation (BAC) surrounding the December 2008 merger with Merrill Lynch, chaperoned
or coerced by senior US officers. In the midst of negotiation of that merger, on December 10, 2008, Mr Timothy
Mayopoulos, then BAC General Counsel was ousted and escorted out of the BAC corporate headquarters by security.
He was replaced by Brian Moynihan - today BAC President and CEO. The ouster of Mr Mayopoulos was subject of
intense scrutiny by US Congress, by office of Mr Andrew Cuomo, Attorney General of NY State, and Judge Jed Rakoff,
US District Court,NY, under SEC v BAC (1-09-cv-06829).

The evidence provided below alleged that the transformation of BAC into an allegedly corrupt organization took place
much earlier, between January 8 and January 11, 2008, in the decision to merger BAC with Countrywide Financial
Corporation (CFC), also chaperoned or coerced by senior US officers.

The collapse of CFC on January 8, 2008 followed publication in the NYT of the filing of "recreated letters" as evidence in
US Bankruptcy Court in Pittsburgh, Pennsylvania. [1] Financial markets were reported under "tremors". It should be
noted that investors did not distinguish between fraud in financial reports and fraud against individuals. The realization
that the Legal Department of CFC was engaged in fraudulent conduct in court undermined investors' confidence.
Neither does Sarbanes Oxley Act (2002) make any such distinction.

It is claimed that the merger announced on January 11, 2008 could not be honestly accepted by senior officers and the
Board of Directors of BAC consistent with the investors' interests. Agreement was to purchase CFC for stock exchange
at over $4 billions, whereas the true value of CFC was in the negative many billions of dollars. Additionally, it is claimed
that the transaction harbored substantial criminal liabilities for BAC and its officers, which could not escape the notice of
General Counsel Timothy Mayopoulos. Such criminal liabilities stemmed from conduct of the underwriting department of
CFC, which had been engaged in false underwriting and funding of government-backed residential loans for years, and
in the litigation practices of the Legal Department of CFC. Such litigation practices were documented in great detail
during the due diligence period, in the March 5, 2008 Memorandum Opinion of Judge Jeff Bohm, US Bankruptcy Court,
Houston Texas. [2]

Of particular interest in Judge Bohm's opinion were the detailed description of the false appearances by false outside
counsel for CFC, who was not Counsel of Record, and who was employed with "no communications with client" clause.
Additionally, the opinion cited a year-long study by the US Trustee, conducted in conjunction with investigation by Judge
Bohm of CFC's litigation practices across the US. It is alleged that the evidence in that opinion should have been
sufficient for indictment of Sandor Samuels and the CFC Legal Department as a corrupt organization, for looting of home
owners across the US, and for securities fraud, stemming from failure to disclose such corrupt practices to investors and
to the Audit Committee of CFC.

Analysis of the records in the case of Dr Joseph Zernik, resident of Los Angeles County, California - home base of CFC,
allowed to draw entirely novel conclusions regarding events related to the merger of CFC and BAC, which was
announed on January 11, 2008, and was concluded on July 1, 2008, and also regarding the ouster of Timothy
Mayopoulos on December 10, 2008:

1) Period from July 1, 2008 (takeover of CFC by BAC) to December 10. 2008 (ouster of Mr Mayopoulos)

Based on conduct of the office of General Counsel of BAC under Mr Mayopoulos's leadership, from July 1, 2008
(takeover of CFC by BAC) to December 10. 2008 (ouster of Mayopoulos), on the one hand, and conduct of the various
US law enforcement agencies, on the other, a reasonable person would conclude that secret agreements were reached
between BAC leadership - particularly Mayopoulos, and senior US officers, regarding the alleged criminality at CFC. It is
claimed that such agreements were reached with no authority by the senior US officers involved, and that such
agreements stood contrary to the rule of law and the US Constitution. Such agreements were never disclosed to
investors or to the US Congress.
 Page 5/8 March 6, 2010

During this period noted above, Dr Zernik repeatedly called the office of Mr Mayopoulos, and spoke with senior staff of
that office. Dr Zernik also left voice mail messages with Mr Mayopoulos himself, and also messages with his secretary.
In all such interactions, it was clearly stated by senior staff of the office of BAC General Counsel that Bryan Cave, LLP
was NOT authorized to appear at the Los Angeles Superior Court under caption of Samaan v Zernik (SC087400).
Conduct of Bryan Cave, LLP, under that caption was alleged by Dr Zernik as malicious litigation by CFC and others,
amounting to serious violations of Human Rights of Joseph Zernik, and evidence of criminality by Mr Sandor Samuels -
then Chief Legal Officer of CFC, and others.

In all such interactions of Dr Zernik with office of BAC General Counsel during the period noted above, it was clearly
stated that Mr Todd Boock, in-house counsel of the former CFC Legal Department, was the only counsel authorized as
Counsel of Record for BAC in Samaan v Zernik (SC087400).

Therefore, review of the records in the period noted above revealed that Mr Mayopoulos prevented further alleged
criminality by the Legal Department of CFC, who had engaged in false employment of outside counsel in Dr Zernik's
case, similar to what was described in opinion of Judge Bohm. However, Mr Mayopoulos refused to take corrective
actions regarding fraud conducted by CFC prior to July 1, 2008. Complaints, which were filed by Dr Zernik with the Audit
Committee of BAC pursuant to Sarbanes Oxley Act (2002) were not reviewed. No disclosures were made to the Audit
Committee regarding fraud by management (Sandor Samuels - Chief Legal Officer of CFC, by then - Associate General
Counsel of BAC), and false certifications were signed by BAC officers pursuant to Sarbanes Oxley Act (2002) in periodic
reports to SEC.

US law enforcement agencies would not enforce the law at BAC and CFC. No matter how credible the evidence of
criminality was in records that were filed by Dr Zernik with such agencies. No US agency would take any action against
these financial institutions. Such conduct also amounted to refusal to provide Dr Joseph Zernik Equal Protection under
the law.

Such absurd position was also evidenced in the litigation of SEC v BAC (1-09-cv-06829) at the US District Court, NY.

2) Period from December 10, 2008 (replacement of Timothy Mayopoulos by Brian Moynihan as General Counsel
at BAC) and to this date

Upon review of records in Dr Zernik's case, a reasonable person would conclude that BAC, starting December 10, 2008,
abandoned any notion of compliance with the law, which was attempted under the leadership of Timothy Mayopoulos at
the office of General Counsel. With the appointment of Brian Moynihan as General Counsel on December 10, 2008,
BAC started flaunting of its alleged criminality. On the other hand - US law enforcement agencies continued their position
of refusal to enforce the law at BAC.

a) Resumption and flaunting of alleged criminality within 24 hours from ouster of Timothy Mayopoulos.

Dr Zernik was not aware at the time of the ouster of Mr Mayopoulos. However, he was astonished on December 11,
2008, with the resumption of alleged criminalities by BAC - alleged retaliation, intimidation and harassment of a victim/
witness/informant through renewed false appearances by Bryan Cave, LLP. [3]

The actions that were falsely taken by Bryan Cave, LLP and BAC at that time were seen as flaunting of criminality: Brian
Cave, LLP filed ex parte application for shortened notice hearing on OSC contempt and serious sanctions against Dr
Zernik. The main claim being that Dr Zernik was guilty of contempt in calling the office of BAC General Counsel
Mayopoulos and finding out that Bryan Cave, LLP was engaged in alleged criminalities at the court in Los Angeles. [4]

It was alleged that such conduct, taking place less than 24 hours after the ouster of Mr Mayopoulos and his replacement
by Mr Moynihan, could not have taken place absent permission, or at least cognizance by Mr Moynihan. It was further
alleged that upon discovery it would be found that Mr Moynihan in fact permitted Mr Sandor Samuels to resume the
alleged criminal practices of the former CFC Legal Department, in fact relieving the CFC Legal Department from
requirements publicly stated in the BAC Outside Counsel Procedures, which purported to guarantee investors and the
public at large honest conduct by the office BAC General Counsel. [5]

b) Flaunting by the former CFC Legal Department their exemption from procedures of the BAC General
Counsel

The flaunting of alleged criminality in appearances of Bryan Cave, LLP, and exemption of the former CFC Legal
 Page 6/8 March 6, 2010

Department from supervision by the BAC office of General Counsel procedures was particularly noted in March 18, 2009
email notice by Todd Boock, [6] in-house counsel of the former CFC Legal Department, to Dr Zernik. Mr Boock was
repeatedly noted by BAC office of General Counsel as the ONLY counsel authorized as Counsel of Record in Samaan
v Zernik (SC087400). The email was addressed to Dr Zernik and copied to Phil Wertz of the BAC General Counsel
Office, stating falsely that Bryan Cave, LLP should be addressed by Dr Zernik in matters pertaining to Samaan v Zernik,
and that Zernik should ignore all information he had previously received to the contrary from office of the BAC General
Counsel in that matter.

c) False and deliberately misleading responses by office of Brian Moynihan to the US Office of Comptroller of
the Currency on Zernik's complaint (#00971981)

In late September 2009 Dr Zernik filed complaint against BAC with US Office of the Comptroller of the Currency
(#00971981).

Three main issues were noted in the complaint:


1) Refusal of BAC and its Audit Committee to pronounce on hundreds of false banking records produced by
CFC and false court actions that were conducted by CFC and later BAC, and were subject of repeated
complaints by Dr Zernik to the Audit Committee of BAC.
2) False appearances by Outside Counsel which was not Counsel of Record - Bryan Cave, LLP. A clear
statement was requested by authorized person at BAC, whether Bryan Cave LLP was Counsel of Record in
Samaan v Zernik (SC087400), and if so - to specify the date of such engagement.
3) Collection of funds by parties that were related to CFC or BAC, purported as sanctions against Dr Zernik,
from Attorney David Pasternak, falsely representing himself as "Receiver" for enforcement of judgment that
never existed as a valid entered judgment, and who failed to obtain valid appointment order as Receiver, as
required by law. Such conduct by CFC and BAC was alleged as money laundering, or monetary transactions in
funds derived from specified prohibited conduct.
By January 1, 2010, the date of appointment of Brian Moynihan as President and CEO of BAC, BAC failed to respond at
all on Dr Zernik's complaint to OCC, over 2 months earlier, in disregard of standard time-frames stated by OCC.
Moreover, by that time OCC claimed to have twice "escalated" the complaint.

Such state of affairs was reported by Dr Zernik, starting late December 2009 to both Brian Moynihan, by then
announced as the newly appointed CEO/President of BAC, and to Mary Schapiro, Chair of SEC. Both Schapiro and
Moynihan acknowledged receipt of Dr Zernik's notices. In such notices Dr Zernik claimed that the refusal of BAC to
respond on complaint filed with OCC, alleging fraud by BAC management, must be deemed material deficiency in itself,
given the seriousness of the allegations. Therefore, Dr Zernik claimed that the refusal to respond on the complaint to
OCC must be accordingly disclosed to the BAC Audit Committee, and also in periodic reports to SEC and investors.

Consequently, on January 8, 2010, response letter was issued on the complaint to OCC (#00971981) [7] [8] by the
office of BAC CEO/President Brian Moynihan. Two copies were provided below of such response. One [7] is the copy
which was mailed to Dr Zernik, and the other was the copy which was faxed to OCC, and was obtained by Dr Zernik
through FOIA-request. [8] Both copies show the same feature - although they were noted in the body of the response as
transmitted from Charlotte, North Carolina, office of Brian Moynihan, President & CEO, they passed on the way through
California, presumably at the former CFC Legal Department, prior to being forwarded to their final destinations.

It was alleged that upon discovery, it would be found that such response amounted to fraud, which was tightly
coordinated by Mr Brian Moynihan himself and Mr Sandor Samuels and/or Mr Todd Boock at the former CFC Legal
Department.

The nature of the fraud was three-fold:


1) Regarding the alleged fraud in CFC banking records that had been produced in response to legal
subpoenas, BAC refused to make any pronouncement. Instead, it made a false and deliberately misleading
statement that it would not produce loan records to Dr Zernik. Dr Zernik never requested production of loan
records. All such loan records had already been produced. Instead, Dr Zernik only requested review by the
Audit Committee of his claims of large scale fraud in banking records that had already been produced and
falsely represented as true and valid loan records..
2) Regarding authorization of Bryan Cave, LLP, if any, as Outside Counsel of Record under caption of Samaan
v Zernik (SC087400), BAC failed to make any explicit, valid statement by an authorized person. Neither did
BAC state a date of enlargement. However, BAC did make in its response a statement pertaining to Bryan
Cave, LLP, that should be deemed upon review as fraud.
 Page 7/8 March 6, 2010

3) BAC failed to respond on the issue of monetary transactions conducted with Attorney David Pasternak. BAC
never disclosed who the recipients of the funds were, and what the designation of such transactions in BAC
accounting was.
It should be noted that at least two such transactions were recorded by the false "Receiver" Attorney David Pasternak,
who was and is a close personal friend of Mr Sandor Samuels. [9], [10]

It should also be noted that in a phone call by Dr Joseph Zernik to OCC on March 5, 2010, he was informed that OCC
had not made any determination on his complaint against BAC (#00971981) to that date. Such delay was inexplicable,
and fell outside any of the stated time frames for response by OCC on complaints by individuals against national banks,
as stated by OCC staff.

In sum:

The state of affairs stemming from the 2008 merger of BAC with an alleged corrupt organization that was CFC, which
was chaperoned/coerced by senior US officers, was that BAC top management was flaunting alleged criminality, while
US law enforcement agencies were consistent in their refusal to enforce the law. Such state of affairs was inconsistent
with the rule of law, with the US Constitution, with the Basel Accords on international banking, and with investors'
interests.

Links:

[1] January 8, 2008 Three recreated letters and a transcript from Case of Borrower Sharon Diane Hill (01-22574).
Publication of the story by the NYT on January 8, 2008 caused the collapse of Countrywide Financial Corporation, and
"tremors" to financial markets.
http://www.scribd.com/doc/25003494/08-01-08-Countrywide-Recreated-Letters-Transcript-in-case-of-Borrower-Hill-
Pittsburgh-PA-s

[2] March 5, 2008 Memorandum Opinion of Judge Jeff Bohm, in case of Borrow William Alan Parsley (05-90374).
The opinion provided detailed analysis of the malicious litigation practices of Countrywide Financial Corporation in courts
across the United States. Of Particular interest was Judge Jeff Bohm's analysis of the practice involving employment of
false counsel who was not counsel of record and who was employed with "no communications with clients" clause. The
opinion was based in part on a year-long study by the US Trustee of litigation practices of Countrywide Financial
Corporation across the United States.
http://www.scribd.com/doc/25001966/08-03-05-Countrywide-Judge-Jeff-Bohm-s-rebuke-of-litigation-practices-Case-of-
Borrower-Parsley-Houston-Texas-Dkt-248-re-Countrywide-s-false-ou

[3] December 11, 2008 - false notice by Bryan Cave, LLP on behalf of Non Party Countrywide Home Loans, Inc barely
24 hours after the ouster of Timothy Mayopoulos as General Counsel of Bank of America Corporation resumption of
obstructionist/malicious conduct by false counsel, who was not counsel of record under caption of Samaan v Zernik
(SC087400) at the Superior Court of California County of Los Angeles. Bryan Cave, LLP attorney deliberately made
such notices defective on their faces, nevertheless, the intended harm was affected. The case number in the notice is
false, and the signature was invalid - not even in the name of an attorney, let alone counsel of record.
http://www.scribd.com/doc/27932293/08-12-11-Bryan-Cave-LLP-Notice-of-Ex-Parte-Appearance-on-Behalf-of-Non-
Party-Countrywide-Home-Loans-Inc

[4] December 15, 2008 Ex parte application by Non Party Countrywide for short notice hearing on contempt and
sanctions against Dr Zernik. Such court actions were alleged retaliation/intimidation/harassment against
witness/victim/informant and also obstruction/perversion of justice. The application was deemed as an act of flaunting
criminality, since it was based on a claim of contempt related to Dr Zernik contacting the office of BAC General Counsel
and obtaining information that Bryan Cave,LLP was NOT authorized to appear in court under Samaan v Zernik
(SC087400).
http://www.scribd.com/doc/27932188/08-12-15-Countrywide-Ex-Parte-Application-for-a-Short-Notice-Hearing-on-Motion-
for-OSC-Contempt-and-Sanctions

[5] April 2008 the published BAC Outside Counsel Procedures. Obstructionist conduct by outside counsel is strictly
prohibited. Outside Counsel is not allowed to appear unless authorized by BAC office of the General Counsel, and
Outside Counsel is required to report per Sarbanes Oxley Act (2002) section 307. Bryan Cave, LLP, and the former
CFC Legal Department, headed by Sandor Samuels were exempted from all such procedures starting December 11,
2008, under Bryan Moynihan.
 Page 8/8 March 6, 2010

http://www.scribd.com/doc/27932516/08-12-11-Bank-of-America-Outside-Counsel-Procedures-s

[6] March 18, 2009 email notice by Todd Boock, in-house counsel of the former CFC Legal Department, addressed to
Dr Joseph Zernik and copied to Phil Wertz from the BAC office of General Counsel. While Todd Boock was the truly
listed counsel of record in Samaan v Zernik (SC087400) according to the General Counsel of BAC, he refused to
communicate on the matter, and referred it to false counsel Bryan Cave, LLP. He copied the notice to Wertz, to negate
the opposite information, repeatedly provided by Mr Wertz to Dr Zernik, but with no legal foundation.
http://www.scribd.com/doc/27932604/09-03-18-Samaan-v-Zernik-SC087400-Email-notice-by-Bank-of-America-In-
house-Counsel-Todd-Boock-to-Joseph-Zernik-s

[7] January 8, 2010 copy of response from office of Brian Moynihan, BAC CEO & President on complaint to OCC
(#00971981) - as mailed to Dr Zernik. It was alleged that such response should be deemed as fraud, tightly coordinated
by office of Mr Brian Cave and the former CFC Legal Department - Mr Sandor Samuels and/or Mr Todd Boock.
http://www.scribd.com/doc/27932742/10-01-08-Bank-of-America-Response-letter-by-office-of-President-CEO-Brian-
Moynihan-to-Office-of-Comptroller-of-the-Currency-on-Zernik-s-Complaint-0

[8] January 8, 2010 copy of response from office of Brian Moynihan, BAC CEO & President on complaint to OCC
(#00971981) - as faxed to OCC. It was alleged that such response should be deemed as fraud, tightly coordinated by
office of Mr Brian Cave and the former CFC Legal Department - Mr Sandor Samuels and/or Mr Todd Boock.
http://www.scribd.com/doc/27932890/10-01-08-Bank-of-America-Response-letter-by-office-of-President-CEO-Brian-
Moynihan-to-Office-of-Comptroller-of-the-Currency-on-Zernik-s-Complaint-J

[9] January 14, 2009 Report by David Pasternak, listing payment on December 2, 2008 of $7,500 to Countrywide Home
Loans. Neither BAC nor Bryan Cave, LLP would answer regarding the identity of the party that collected such funds and
their designation.
http://www.scribd.com/doc/27933024/09-01-14-Samaan-v-Zernik-SC087400-Attorney-David-Pasternak-s-false-
fourteenth-interim-report-s

[10] February 24, 2009 Pasternaks Report, listing payment of $5,564 50 to Countrywide Home Loans.
http://www.scribd.com/doc/27933161/09-02-24-Samaan-v-Zernik-SC087400-Attorney-David-Pasternak-s-false-16th-
interim-report

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