Sf 'MONS (CITACION JUDICIAL

)

NOTICE TO DEFENDANT: (AVISO AL DEMANDADO):

Ame r i ca n College of Forensic Examiners Institute Does 1-100

YOU ARE BEING SUED BY PLAINTIFF: Emo.ct To..dv-Os. IV'-P· (LO EsrA DEMANDANDO EL DEMANDANTE):

;:'UIYI-IUU

FOR COURT USE ONL Y (SOLO PARA usa DE LA CORTE)

ORIGINAL FILED

JAN 102011 su~~Mb~G&t~

,.

i NOTICE! You have been sued. The court may decide against you without your being heard unless you respond within 30 days. Read the information

I below.

I You have 30 CALENDAR DAYS after this summons and legal papers are served on you to file a written response at this court and have a copy

!served on the plaintiff. A letter or phone call will not protect you. Your written response must be in proper legal form if you want the court to hear your I case. There may be a court form that you can use for your response. You can find these court forms and more information at the California Courts

I Online Self-Help Center (www.courtinfo.ca.gov/selfhe/p). your county law library, or the courthouse nearest you. If you cannot pay the filing fee, ask the court clerk for a fee waiver form. If you do not file your response on time, you may lose the case by default, and your wages, money, and property I may be taken without further warning from the court.

There are other legal requirements. You may want to call an attorney right away. If you do not know an attorney, you may want to call an attorney I referral service. If you cannot afford an attorney, you may be eligible for free legal services from a nonprofit legal services program. You can locate

I these nonprofit groups at the California Legal Services Web site (www/awhe/pcalifomia.org), the California Courts Online Self-Help Center

I (www.courtinfo.ca.govlselfhe/p). or by contacting your local court or county bar association. NOTE: The court has a statutory lien for waived fees and costs on any settlement or arbitration award of $10,000 or more in a civil case. The court's lien must be paid before the court will dismiss the case.

II· iAV/SO! Lo han demandado. Si no responde dentro de 30 dias, la corte puede decidir en su contra sin escuchar su version. Lea la informacion a

coniinuecion.

I Tiene 30 DfAS DE CALENDARIO despues de que /e entreguen esta citecion y papeles legales para presentar una respuesta por escrito en esta

" corte y hacer que se entregue una copia al demandante. Una carta 0 una /lamada teletonice no 10 protegen. Su respuesta par escrito tiene que ester en formato legal correcto si desea que procesen su caso en /a corte. Es posible que haya un formulario que usted pueda usar para su respuesta.

I Puede encontrar estos formularios de la corte y mas informacion en el Centro de Ayuda de las Cortes de California (www.sucorte.ca.gov). enla biblioteca de leyes de su condado 0 en la corte que Ie quede mas cerca. Si no puede pagar la cuota de presentecion, pida al secretario de la corte

que Ie de un formulario de exencton de pago de cuotes. Si no presenta su respuesta a tiempo, puede perder el caso par incumplimiento y la corte Ie poore quitar su sueldo, dinero y bienes sin mas advertencia.

Hay otros requisitos legales. Es recomendable que lIame a un abogado inmediatamente. Si no conoce a un abogado, puede /lamar a un servicio de remision a abogados. Si no puede pagar a un abogado, es posible que cumpla can los requisitos para obtener setvicios legales gratuitos de un programa de servicios legales sin fines de Iucro. Puede encontrar estos grupos Sin fines de lucro en e/ sitio web de California Lega/ Services,

I (www.lawhelpcallfornia.orq), en el Centro de Ayuda de las Cortes de California, (www.sucorte.ca.gov) 0 ponienaose en contacto con la corte 0 el

I colegio de abogados locales. A vIsa: Por ley, la corte tiene derecho a reclamar las cuotas y los costos exentos por imponer un gravamen sabre cualquier recuperaci6n de $10,0006 mas de valor recibida mediante un aeuerdo 0 una concesi6n de arbitraje en un caso de derecho civil. Tiene que pagar el gravamen de la corte antes de que la corte pueda desechar et caso.

The name and address of the court is: (EI nombre y diteccion de la corte es):

LA County Superior Court Pomona Courthouse South

400 Civic Center Plaza Pomona, CA 91766

The name, address, and telephone number of plaintiffs attorney, or plaintiff without an attorney, is:

(EI nombre, /a direccion y el numero de teletono del abogado del demandante, 0 del demandante que no tiene abogado, es):

EIVJAD TADROS MD

6943 Oriole Ave. La Verne CA 91750

DATE:

JAN 1 0 2 Clerk, by

(Fecha) (Secreta rio) -

JOHN A. CtARKE

, Deputy --- (Adjunto)

(For proof of service of this summons, use Proof of Service of Summons (form P S-010).)

(Para prueba de entrega de esta citaci6n use el formulario Proof of Service of Summons, (POS-010)).

NOTICE TO THE PERSON SERVED: You are served CASe ASSIGNeD FOR

1. !XI as an individual defendant ALL PURPOSES 'f0

2. 0 as the person sued under the fictitious name of (specify): .

JUDGE BRUCE MINTO

DEPT. H

I [SEAL] I

i

I

I

I

i

__________ J

3. 0 on behalf of (specify):

under: ~ CCP 416.10 (corporation)

CCP 416.20 (defunct corporation)

CCP 416.40 (association or partnership) other (specify).'

4. 0 by personal delivery on (date):

EI CCP 416.60 (minor)

CCP 416.70 (conservatee)

CCP 416.90 (authorized person)

._I'_a~of1

F"~~~i~-I~~in~~-f-~i~~~~i~~~use----·~-·-~~~--~--~----·-------sU-rvrlJONs-----~~'·-------------- --·--~-·-'----C-od~ of Civil Procedure §§ 412.20 465

SUM·100 [Rev JUly 1 20091

www courtmto.ce qov

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Emad Tadros, M.D. 6943 Oriole Ave

La Verne CA 91750 Plaintiff In-Pro-Per

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ORIGINAL "lLeo JAN 1 0 ZOn

su~~~

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA

IN AND FOR THE COUNTY OF LOS ANGELES

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Emad Tadros, M.D. Unknown and Un Named And

Unnoticed Plaintiff's 1-

10,000 to be named at a later date

Plaintiff's

vs.

American College of Forensic

Examiners Institute, and Does

1-100

Defendants.

/ I , I

II

KC060326

Case No. :
1. DEFENDANTS FRAUD IN FACT.
2. DEFENDANTS ACTUAL FRAUD.
3. DEFENDANTS FRAUD UPON THE
COURT.
4. DEFENDANTS INTERSTATE WIRE
AND MAIL FRAUD ACROSS STATE
LINES,
5. WITH THE INTENT TO DEFRAUD INTERFERE AND IMPACT

INTERSTATE COMMERCE.

6. DEFENDANTS FRAUD IN THE

COLLATERAL FRAUD.

7. CAUSE OF ACTION SECTION 17200-17210 OF THE

CALIFORNIA BUSINESS AND

PROFESSIONS CODE AND OTHER CAUSES OF ACTION,

8. WITH LEAVE TO AMEND.

THIS IS THE PROPER COURT AND VENUE FOR THIS CAUSE OF ACTION as

7 all of the transactions have taken place in California and the

3 Plaintiff's new official residence is 6943 Oriole Ave

4 La Verne CA. The Un-named, Un-Noticed, Un-Informed Plaintiffs

5 reside in the State of California. These Plaintiffs number into

6 the thousands and will be added as they become available.

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8 THIS CASE AND CAUSE OF ACTION BROUGHT IN THE NAME OF THE PUBLIC

q GOOD IS ONE OF THE MOST DIVISIVE, EMOTIONAL, SOCIAL, POLITICALLY

10 AND LEGALLY SENSITIVE OF ALL CIVIL ISSUES THAT THE COURT IS I I REQUIRED TO ADDRESS.

12 This establishes a need for the highest legislative, judicial,

1, and public scrutiny to assure that there are no illegal acts, or _,

14 actions that could, or would cause, or allow the illegal tainting of the courts Child Custody 730 Evaluation decisions. 15

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This is to expect and demand heightened protection in matters concerning fundamental, constitutionally protected rights.

ANY ILLEGALLY TAINTED RESULTS HAS THE UNIVERSAL ABLITY TO TOUCH US ALL PERSONALLY SINCE THE DAYS OF KING SOlOMON:

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King Solomon's judicial efforts as to what was in the ~best interest" of the child whose custody was in dispute-offered a simple judicial order that courts follow even today-because of its policy of fairness. King Solomon ordered that the child was to be cut in half and to give each mother a half of the child. Even in this biblical dispute that was long ago between two

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mothers, who laid claim to the same child continues unabated

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today, between two parents who contest child custody. The

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legislature in its continuing search for ~Solomon" wisdom

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created 730 Evaluations out of the continuing need of the court,

and the trier of fact to act in

best interest of the child.

This satisfied the rightful parent, even as in those biblical

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days when the mother would rather give up the child than see it

7 be cut in half and destroyed. The issues in this case are

nature. The plaintiff does not want to be

3 metaphor in form

4 illeg~lly cut of from their children,see the body of justice

5 and truth be sacrificed before, during or after a 730 6 evaluation.

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8 THE ISSUES OF LEGAL FAIRNESS THAT ATTACH TO THE LEGAL PROCESS OF

9 CONTESTED CHILD CUSTODY EVALUATIONS MUST BE ABSOLUTELY UNTAINTED

10 AS HUMANLY POSSIBLE. This is because the orders that corne out of

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a 730 Evaluation attach and affect the constitutionally

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protected right to parent-the rights of due process of law along with the right to a fair and impartial hearing. Contested child custody evaluations become the final legal word of the court that makes life changing rUlings. These rulings affect the long term and short term "best interest" of the child custody that is at issue.

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THESE 730 EVALUATIONS ARE EXPLORED IN DEPTH IN THE NAME OF THE PUBLIC GOOD - FIT MOTHERS AND FATHERS HAVE BEEN ILLEGALLY DENIED THEIR RIGHTS BY THE PURPOSEFUL TAINTING OF THIS PROCESS:

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It is the application and use of false, invalid and fraudulent

degrees claiming ps

logical expertise, education and

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experiences that the Psychological Advance Degree Evaluator

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purchased from a diploma mill. This illegal practice creates not

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only fake, phony, degrees, it creates and maintains false and

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phony 730 Court Experts. It violates the 730 Evaluators quasi

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status as court officers and Court Experts in child custody

matters.

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:; Privilege of civil Code 47 and other quasi judicial Lmmun i ty.

THE FAMILY LAW COURTS AND JUDGES ARE FOR LACK OF A BETTER DESCRIPTION CAUGHT BETWEEN A LEGAL ROCK AND A HARD PLACE.

THE VERY SAME 730 EVALUATOR, WHILE CAUSING A FRAUD UPON THE

2 COURT AND THE LITIGANTS BY THE ILLEGAL USE AND PRESENTATION OF 3 FAKE, PHONY, DEGREES WILL IN THE SAME LEGAL BP~ATH DEMAND

4 PROTECTION FROM THEIR FRAUD UPON THE COURT under the Litigation

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If they rule against the 730 Evaluator who has been carrying out illegal and tainted 730 evaluations for 20 plus years - like

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stephen Doyne PhD of San Diego, and others then the court has to face the possibility of having to retry thousands of family law cases, that were tainted by him and the Diploma Mills like in the case at bar.

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THIS CASE AND CAUSE OF ACTION IS NOT COMPLICATED, OR COMPLEX.

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Falsification of education credits always without exception requires pre-litigation planning and acts of furtherance. This is to establish the fraud upon the court and the litigants before ever being appointed to a case as a 730 Evaluator.

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It is a physical and legal impossibility to use false perjured educational credentials any other way. This places these illegal acts and actions outside of the protection of the litigation privilege, making the conjoint fraud of the Diploma Mill and the 730 Evaluator who purchases these false and phony educational degrees outside of the protection of the litigation privilege

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and Anti-SLAPP Action. The prerequisite mens rea is present for

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both creator and payors of false and fraudulent degrees and

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diplomas, and their clients. These persons know when they are

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buying these false phony degrees that they are not valid,

and are being purchased for the purpose of committing a fraud on

the court, the litigants and knowing that this illegal act and

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7 diploma mill operator and the 730 Evaluator buyers enter into a

11 taint the legal outcome f the 730 Evaluation. The

iracy to defraud. There is no other purpose that can be

4 assigned to this type or kind of activity or action.

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6 THIS COMPLAINT EXPLORES THE ENTIRE INVOLVEMENT OF 730 EVALUATORS 7 AND THE DEFENDANT DIPLOMA MILL OPERATOR AND EXPOSES THE ENORMOUS 8 AMOUNT OF EMOTIONAL, FINANCIAL, AND LEGAL HARM THESE TYPES AND

9 KINDS OF OPERATIONS CAUSE:

10 This is by the one particular 730 Evalua r, which is being

11 presented as a case study of illegal activity and corruption of 12 a 730 Child Custody Evaluator; that individual being one Stephen 13 Doyne PhD "Stephen Doyne or 730 Evaluator" of San Diego and

14 Defendants the AJ'Ylerican College of Forensic Ex:aminers Insti t.iit:e "(ACFEI)" and it officers, board of directors and others.

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17 THERE IS NO HEAVY LEGAL LIFTING REQUIRED BY THE COURT IN THIS

18 CAUSE OF ACTION. All that is required is a honest look at the 19 cause and effect relationship of the tainted 730 Evaluations

20 that cause such €normous legal, social, financial and emotional

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harm to the legal machinery and legal integrity of the family law court and judges that populate those courts and the parents

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and children they serve.

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THE CITIZENS OF THIS STATE ARE TRULY BLESSED WITH AN HONEST, HARD WORKING, JUDICIARY THAT HAS HAD ITS MACHINERY LEGALLY HIJACKED BY 730 EVALUATORS:

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ThlS 1S 730 Evaluator's like Stephen Doyne with the aid of the

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diploma mill. This is the single opportunity for this court to

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make a difference by acting to put an end to this type and kind

of family law child cus

abuse and mlsuse for profit of 73

Evaluators with false and pnony e

ational credentials.

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WHY THIS CASE AND CAUSE OF ACTION IS IMPORTANT TO THE COURT AND PUBLIC AT LARGE:

These unjust illegally tainted child custody rulings destroy

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the public respect for the courts and the law. The law is the only single thing that separates us from the wild beast of the

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6 jungle. Justice and law create and preserve our society. This

7 makes this request for justice and relief right and proper as a 8 public issue for the parents and children living and those yet

9 to be born.

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THE PLAINTIFF EMAD TADROS, M.D IS A BOARD CERTIFIED PSYCHIATRIST WHO IS A NATURALIZED CITIZEN OF THIS COUNTRY. He has had the

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unpleasant experience of coming from a country where the rights of the many were illegally extinguished by the controlling few. Because of experiencing this illegal deprivation Emad Tadros ~Dr. Tadros" understands the importance of preserving the rights and privileges of the law that many ria t i ve born Ame r i can s completely disregard with clavier abandonment.

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PLAINTIFF EMAD TADROS IN HIS DAILY PRACTICE OF PSYCHIATRY

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experiences first hand the long and short term effects and damages caused by the illegal acts and actions in family law

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matters. He is pointedly aware of how these correctable unjust results contribute to the mental disease of his patients. He is aware in real world terms how the affected children who suffer

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from the unjust denial of the right and emotional need to have a

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good and fit parent and role model in their lives.

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THIS COURT WOULD NOT STAND BY WHILE PERSONS PRETENDED TO BE JUDGES WHO WERE ILLEGALLY APPOINTED TO THE BENCH BASED ON THE USE AND APPLICATION OF FALSE AND PHONY EDUCATIONAL

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DOCUMENTATION. Nor wo u Ld t h i s court a Ll.ow these parties to

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continuously make absurd judicial rulings in the family courts, ~ that harmed the public and violated the law. It is the same type

and kind of motivation that would move a judge of the courts to

4 stop the destruction of the judiciary

t drives Dr. Tadros to

5 bring this suit for correction in the name of the public good.

6 The judges of the courts and Dr. Tadros share a commonality. They 7 are both in a position of power and public trust. This is

8 because each is mandated by the law and the moral right and

9 wrongs of humanity to do no harm to anyone. To always act in the 10 individual and collective public good. This court and the trier 11 of fact is now in possession of the "why" behind the "what" that 12 drives this litigation and the purpose of this litigation.

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THIS PLEADING SHOULD BE LIBERALLY CONSTRUED.

This cause of action is being brought by a private civil action

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• In The Name of the Public Good,

• The Public Interest,

• In Support of Public Policy.

19 The present, past and continuing injuries suffered by the 20 plaintiff and other Plaintiff's Un-named, Un-Noticed, Un-

21 Informed have suffered, and continue to suffer financial,

22 emotional and legal harm.

This is because all of the plaintiffs

are similarly situated individuals in this cause of action that

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have been victims of "Violations of Public Policy" and Equal

25 Protection Clauses of the Law and the

~c Policy that these

26 laws offer and guarantee. 27

28 By the Illegal Unabated Operation And Deception Of The Public:

29 ACFEI owns and operates an illegal diploma

11, wh i oh is

30 operated across state lines carrying on illegal interstate oomme r c e . The diploma mill did attempt to threaten Dr. Tadros

and thers by claiming they ( FEI) would file a $1 million law

7

suit against Dr. Tadros and others. ACFEI demanded that Dr.

2 Tadros and others shut down the public exposure of the ACFEI

diploma mill via the internet, or suffer a the major legal

4 consequences of a $1 million law suit that would be filed in the 5 improper, inconvenient legal forum of Hissouri. (See Exhibit

6 attached hereto and incorporated herein by reference)

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8 FIRST CAUSE OF ACTION - FRAUD IN FACT:

9 Actual fraud and deceit of ACFEI was and is the original illegal

lO qenesis

source. This caused the illegal judicial

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concealment- by example and as a reference point Stephen Doyne PHD of San Diego who caused the making and presentation of false educational documentation and false representation to the CA Family Law Court,and the Family Law Litigants. This illegal tendering of the false psychological enhanced degrees titled

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psychological diplomat status was done with the purposeful

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intent to defraud these parties by misrepresentation and presentation and claims of having and holding false educational credentials with supporting false documentation of these educational credits provided by defendant ACFEI. ACFEI knew or

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should have known because of the clear and foreseeable evil

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intent behind these illegal and false representations did cause ongoing harm and injury to the illegal affected Dr. Tadros and others similarly situated. ACFEI illegal acts and actions was

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carried out by and through the conscious choice accompanied by

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illegal plan of action with substantial actions to enter into a

"civil and criminal conspiracy" with the certain 730 Child

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Custody Evaluators namely Stephen Doyne PHD of San Diego

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California who is used as an example to contrast these illegal

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acts and actions. This fraud was created by and through the

creation, design, drafting, printi , illegal distribution, and

national promotion of false "

cational Credentials" for Doyne

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POSITION AS by never legally qualifying for that position by

PHD a 730 Child Cu s tOG)/ Ev e L ua tor and others by the Defendant

') FE I.

4 DOYNE MISUSED AND ABUSED THE POWER AND PRESTIGE OF HIS LEGAL

6 willful failure to follow the rules of court, and all of the

7 other mandated legal steps to be a bonafide child custody

8 evaluator. Doyne betrayed his position as the court expert by 9 using fraudulent, false and phony educational credentials as a

]0 means to perpetrate a continuing fraud upon the family law

II courts, the judges of those tourts and the family law litigants

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with the help and assistance of ACFEI. This fraud was carried out to by Doyne and others to command higher illegal evaluation fees and costs with the aid and comfort of ACFEI.

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THE ILLEGAL SCHEME OF PRESENTING FALSE CREDENTIALS TO THE PUBLIC AT LARGE WAS A PART OF A PRE-LITIGATION SCHEME. To put this pre-

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planned pre-litigation scheme in place it first required the assistance of an illegal actor ACFEI that did for a price offer fake, phony, fraudulent advanced degrees to anyone that had the price of adm.i s s Lon . The collusion and conspiracy of ACFEI and the preplanning efforts of the conspiracy by Doyne and others in league with ACFEI required an illegal catalyst to be injected. That illegal catalyst wa s the i l.l.eae L intent of the 730 Ch i.Ld. Custody Eva~uators ~ike Stephen Doyne PHD of San Diego. Doyne

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had to take the second overt illegal step and action of seeking

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out the ACFEI's illegal services.

Doyne and other 730

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Evaluators responding to the illegal offer, via the mails across state lines to promote, purchase the false and phony educational degrees from the p.CFEI Diploma I'1ill shows the illegal w i Ll f u I

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intent of ACFEI and Doyne.

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illegal attacks upon the legal integrity, the legal functions of the Family Law Courts 730 Evaluation Child Custody Processes across the state of CA including San Diego and other judicial districts across the state and nation.

ACFEI IN CONCERT WITH 730 EVALUATORS LIKE STEPHEN DOYNE PHD OF

') SAN DIEGO

ly, willingly caused direct and indirect

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8 THIS ILLEGAL CIVIL AND CRIMINAL ENTERPRISE WAS THE CONTINUING

9 RESULT OF THE CONJOINT, ILLEGAL EFFORT OF THE DIPLOMA MILL

10 OPERATOR ACFEI AND 730 EVALUATORS LIKE STEPHEN DOYNE PHD of San 11 Diego. By and through their combined illegal efforts they did 12 cause an attack that illegally perverted the final legal end

13 product of the family law court evaluations. Judges in San

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Diego and other counties across the State of California were also taken in by this fraud. This caused unnatural, absurd legal results that have affected family law victims that number into the thousands across the state of California, which transpired over a period of years. The acts of Stephen Doyne PHD of San Diego and other 730 Evaluators across the state are

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unconscionable and demands redress.

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SECOND CAUSE OF ACTION - ACTUAL FRAUD:

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1. Deliberate deception by ACFEI by use of trickery, or cheating intended to gain an economic and legal advantage over Dr. Tadros

and the public good.

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2. THE ACT OR INSTANCE OF SUCH DECEPTION WAS CARRIED OUT BY USING FALSE EDUCATIONAL DOCUMENTS AND CREDITS; that we r e

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designed, created, and printed by ACFEI to cause the continuing

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support of a false perception that the documents being presented

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were genuine. It is an act of fraud to falsely convey to any

7 person, court, judge, or litigant the barrier of educational

redentials as being legally and properly invested with having

4 and holding advanced degrees of education and training

5 necessary, to cause their continuing qualification as a cour~

6 expert in child custody evaluations. The collusion and

7 conspiracy of the paying ACFEI can best be illustrated by naming 8 a party like Doyne PHD as a recipient of false credentials of

9 ACFEI. This conjoint illegal, activity, with use of the mails

10 created an interstate commerce fraud.

This also makes ACFEI

11 jointly civilly and criminally liable for the electronic

12 transfer of monies across state lines, in conjoint seamless

13 interstate illegal conunerce of false and fraudulent documents 14 and diplomas with the intent to defraud Family Law Courts,

15 Family Law Judges, Family Law Litigants and the Public at large.

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THE FALSE DIPLOMA DENIED THE LITIGANTS THE ABLITY TO RECEIVE THE VALUE FOR WHICH THEY BARGAINED FOR: because of the fraud by the 730 litigants, by example like PHD Doyne as the public was forced to pay over inflated fees for 730 Child Custody

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Evaluations. The Fees charged by example of PhD Doyne were not

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commensurate with the valid educational expertise of the

offending fraudulent 730 Evaluators, like Stephen Doyne PHD who

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was a star participant in this illegal scheme in San Diego County and other counties where he lectured and taught classes

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to other 730 Evaluators and their staffs.

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3. USE OF FALSE CLAIMS WAS A FRAUD BY CLAIMING THAT THE

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EDUCATIONAL CREDENTIALS WERE NOT FRAUDULENT. }\CFEI wa s very

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masterful at creating very authentic looking and sounding names

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lomas, certificates, and the other

for its fake and

2 s educational documentations. This is clearly explained in

3 the complete overview to follow of the operations

4 of FEI and other diploma mills standard operating procedures.

5 THIRD CAUSE OF ACTION - FRAUD UPON THE COURT:

6 In the U.S., when Stephen Doyne PHD acting as a quasi officer of

7 the court is found to have fraudulently presented facts to 8 court, so that the court wa s impaired in the impartial

9 performance of its legal task, the act, known as "fraud upon the

10 court" is a crime and civil wroriq deemed so severe and

11 fundamentally opposed to the operation of justice, that it is 12 not subject to any statute of limitations.

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OFFICERS AND QUASI OFFICERS OF THE COURT INCLUDE: Lawyers,

Judges, and those appointed as 730 Evaluators under special appointment under the CA Evidence Code 730, whose influence lS a

part of the judicial mechanism.

"FRAUD UPON THE COURT" has been defined by the 7th Circuit Court

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of Appeals to "embrace that species of fraud which doe s , or

attempts t.o r rde i i Le the court i t.s e l i , or is a fraud perpetrated

by officers of

e court so that the judicial machinery cannot

perform i.n the usual manner its impartial task of adjudging

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cases tha tare presen ted for adjudi ca tion. "

Please see Kenner

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v. C.l.R., 387 F.3d 689 (1968); Moore's Federal Practice, 2d ed., p. 512, <J[ 60.23 In Bulloch v. United States, 763 F.2d 1115,

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1121 (10th Cir. 1985) ,the court stated "Fraud upon the court is

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fraud which is directed to the -judicial machinerv itself.

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FOURTH CAUSE OF ACTION ~ FRAUD IN THE INDUCEMENT:

This occurs when Dr. Tadros and the public were forced

court order to enter into an agreement with ACFEI and 730

4 Evaluators (by example and legal contrast of

PhD) know i nq

5 that it is supposed to be a contract and (at least having a 6 rough idea what the terms and conditions were) what the

7 agreement is about, but the reason Dr. Tadros and the public

family law litigants signed/made the agreement was because of the false information that ACFEI and the 730 evaluator Doyne

gave to Dr. Tadros and the public, as it related to Doyne and

other 730 Evaluator's Educational qualifications. Because of the Fraud of ACFEI that was carried out, prior to Doyne's appointment and other 730 Evaluator's was the result of prelitigation planning. Thus the plaintiff can and does plead "fraud in the inducement." Preplanning prior to the appointment in attachment to the cause of action causes this fraud to be

exempt from the litigation privilege as defined in Civil Code

47.

FIFTH CAUSE OF ACTION - INTRINSIC FRAUD:

This is an intentionally false representation of ACFEI that goes

to the heart of what this lawsuit is about. In other words,

fraud was used to procure the 730 Evaluation transactions by the use, abuse and presentation of false and perjured educational

documents. (The transaction was fraudulent, therefore it does

not have the legal status of a contract.) Any contracts signed

by Dr. Tadros and other members of the public, because of the

fraud is null and void. This opens the door f r possible

complete refund of any and all funds paid to any offending 730

Evaluatbr who worked in collusion and created a conspiracy with

that 730 Evaluator and defendant ACFEI.

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INTRINSIC FRAUD THAT WAS USED BY ACFEI IS DISTINGUISHED FROM 2 EXTRINSIC FRAUD (A/K/A COLLATERAL FRAUD) wh i ch was and is a

3 deceptive means used by ACFEI of keeping Dr. Tadros, the public 4 and the Court from discovering and/or enforcing Dr. Tadros' and

5 other members of the publics legal rights. In the case at bar 6 there is the positive existence of intrinsic and extrinsic

7 frauds caused and created by ACFEI.

8

9 THE USE OF EXTRINSIC FRAUD (A/K/A COLLATERAL FRAUD) caused

10 unjust interference and denial of constitutionally protected

11 rights to parent. The illegal interference with that protected 12 right to parent was and is the result of the individual and

13 collective illegal acts and actions of ACFEI in providing phony 14 false credentials to 730 Evaluators (by example Doyne PHD) in

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the state of California and other states to justify the illegal 730 extortion of higher, unjustified evaluation fees based upon the use and false presentation of these false educational

credentials.

SIXTH CAUSE OF ACTION FRAUD WITH THE INTENT INTENTIONAL DECEPTION:

The fraud of ACFEI was and is an intentional deception made for personal gain. This is with the intent to cause damage to

the Dr. Tadros' and other members of the public legal rights of

due process of law. ACFEI individually and collectively

illegally promoted the creation, use, interstate dissemination

of false and fraudulent educational credentials by and through

the operation of a diploma mill.

// //

SEVENTH CAUSE OF ACTION IS BROUGHT UNDER SECTION 17200-17210 OF

2 THE CALIFORNIA BUSINESS AND PROFESSIONS CODE, legal consumers of

3 the state of CA such as Dr. Tadros and other members of the

4 public, as private individual citizens may file suit against the

5 defendants and other 730 court appointed Evaluators because they

6 have a continuing legal right to take legal action against a 730 7 Evaluation business enterprise that engag~s in pre-litigation

8 planning that uses fraudulent and/or misleading false

9 advertising, false educational credentials to illegally promote 10 and dominate the 730 Evaluation Market Share illegally across

11 state lines. This amounts to a non-communicative act.

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GIVEN THE LIMITED SCOPE OF FIRST AMENDMENT PROTECTIONS FOR

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COMMERCIAL SPEECH, determining whether an expression is

cOllL.'llercial or noncommercial can be a key issue, and the

legislature has carved out an exception for this key ingredient.

EIGHTH CAUSE OF ACTION - THE PLAINTIFF AND MEMBERS OF THE PUBLIC AS QUASI ATTORNEYS IN PRO-PER CAN SUE ACFEI WHO OWNS AND OPERATES A DIPLOMA MILL BUSINESS IN THE STATE OF MISSOURI.

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It is because this business and its illegal enterprises have affected the public good, public safety, and public policy of good faith and fair dealing, as ACFEI cornmitted vicarious fraud

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upon the court under the comm.ercial speech clause. ACFEI cannot

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find refuge in claiming that the false statements, creation and

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use of false unverified and fraudulent diploma mill documents

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enj oys any protection uncler the First p..J.'11endment of the U. s.

Constitution.

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PLEASE NOTE: ACFEI, its board of directors, management owners

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and operators, and others associated with the illegal

1 ~ .)

Enterprise is individually and jointly as agents and employees,

7 or associates

tted fraud in the inducement by the use of

false credentials for 730 evaluators and others in family

4 law matters related to the contest of custody, visitation, and

5 contact that wa s court ordered fa~~s under commercia~ speech 6 making them subj ect to California's consumer protection

7 statutes, prohibiting false and misleading advertising, which is 8 actionable as an operator of a diploma mill .... (also known as a 9 degree mill) ACFEI is an organization that is owned and operated

10 and who awards academic degrees and diplomas with no academic

II study being required. The Defendant diploma mill operator issues 12 these degrees without recognition of official educational

~ accrediting body's including state, local or national. The L,

14 purchaser can then claim to hold an academic degree, and the

15 organization is motivated by making a profit wi thout supporting

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any inquires to the validity of these false degrees, which makes them part of a civil and criminal enterprise that is operated over and across state lines by ACFEI. The degrees of ACFEI are awarded based on vaguely construed life experiences and claimed

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accredi ta Lion

non-recognized/unapproved accrediting bodies.

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ACFEI set up non-recognized/unapproved accrediting bodies for the purposes of providing a false appearance of a legal veneer of authenticity to support the intestate fraud of this civil and criminal activity of ACFEI.

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DIPLOMA MILLS LIKE ACFEI ARE FREQUENTLY NAMED TO SOUND CONFUSINGLY SIMILAR TO THOSE OF PRESTIGIOUS ACCREDITED

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ACADEMIC INSTITUTIONS. Despite the fact that trademark law is

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intended LO prevent this situation, diploma mills like ACFEI

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con tinue to employ var ious methods to avoid legal recourse. An

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example of this is the defendants ACFEI. In their ma r ke t i.riq and

') advertising campaigns, the defendant mill offers the

3 misleadingly claim to be "accredited" when, in fact, they have

4 been found to have been endorsed by "dummy" accreditation

5 boards set up by defendant company affiliates of ACFEI.

6 The defendants attempt to appear more legitimate to the public.

7 Acc r ed i t a t i on mills like ACFEI are based in the United states 8 and th€ defendant's diploma mill models their websites after 9 real accrediting agencies oVerseen by the Council for Higher

10 Education Accreditation (CHEAl. Many of the mills like ACFEI

11 even advertiSe services for transcript, notation and diploma 12 verification in order to seem more legitimate. Another typical

I'" fraudulent ploy is for mills like ACFEI to claim to be

_,

14 internationally recognized by organizations such as UNESCO.

UNESCO, however, has no authority to recognize or accredit 15

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higher education institutions or agencies, and has published warnings against education organizations that claim UNESCO recognition or affiliation.

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AS DIPLOMA MILLS LIKE ACFEI ARE TYPICALLY ALSO LICENSED TO DO

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BUSINESS, it is common practice within the industry to

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misrepresent their business license as indicating government

approval of the institution. Compared to legitimately accredited

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institutions, diploma mills like ACFEI tend to have drastically

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Lowe r ed requirements or like ACFEI no requirement for academic

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coursework, with the defendant mill eVen allowing their students

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to purchase credentials without any education.

STUDENTS LIKE STEPHEN DOYNE PHD IS USED FOR JUDICIAL LEGAL

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CONTRAST - who are not required to purchase textbooks, take

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tests, and submit homework, but degreeS are nonetheless

conferred by the defendant diploma mill ACFEI after little or no

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fraud the court

DEGREES AND DIPLO~AS ISSUED BY THE DEFENDANT DIPLOMA MILL ACFEI HAVE BEEN ILLEGALLY USED TO OBTAIN EMPLOYMENT AS A COURT EXPERT

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AND 730 EVALUATOR: as in the case at bar. Even if issuing or receiving a diploma mill qualification is legal, passing it off

6 as an accredited one for personal gain, and to

7 and the public. (by example for judicial contrast Stephen Doyne 8 PHD and the Diploma Mill ACFEI.) This supports a civil wrong

9 that is actionable and possible criminal action in California

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jurisdictions. The Defendant Diploma mill ACFEI is also guilty of fraud, fraud, collusion and conspiracy to cormnit fraud across

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state lines because they caused the legal consumers to be misled into believing that the qualifications are accredited or recognized. This false representations causes the legal consumer to accept and have false reliance upon the false credentials,

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which causes the unjust payment of money to ACFEI on the basis of the claims and misrepresentations of the defendant diploma

mill ACFEI that participated in the interstate fraud of the

legal consumers in the family law courts.

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THE DEFENDANT DIPLOMA MILL ACFEI WILL NO DOUBT LIKE ALL UNACCREDITED INSTITUTIONS INCLUDE LEGAL DISCLAIMERS IN RESPECT OF ACCREDITATION IN THE SMALL PRINT OF THEIR CONTRACTS: which

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will be presented as a defense by the defendants. This cannot and will not stand constitutional muster as the same disclaimer

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was never disclosed to the legal consumers of the California Superior Court who suffered a fraud as a result of the conjoint conspiracy of the defendants ACFEI individually and

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collectively_

/ j I /

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II

THROUGH THE EXPOSURE OF THE LEGAL ABUSES OF STEPHEN DOYNE PHD 2 WHICH IS USED AS A JUDICIAL EXAMPLE TO 'GIVE THE COURT FACTUAL

LEGAL CONTRAST OF THESE LEGAL TIME BOMBS are nov] going off

4 within fami~y law cases, that were heard years ago, with dire 5 legal and financial consequences, that were truly no fault of

6 the family law judiciary. Note the family law judiciary and the 7 state were no doubt aware of the magnitude, of the problem, that 8 has been caused. There has been irreparable harm to the legal

9 consumers who have become victims of this lilegal act and action 10 of the defendants ACFEI. The people like the defendant diploma

11 mill operator ACFEI, who sells fake degrees, will probably never 12 suffer at all, because these types and kinds of operations are

]3

set up to allow for their instant disappearance. This

. +-

lS ,--0

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avoid any further recourse like ACFEI. The people who we r e and

are the leqal consumers of 730 evaluations (of Stephen Dovne PHD

15 - -'

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by example for judicial contrast) will continue to suffer

nn

tily. This is because of the false and fraudulent

"degree(s)" that were used against their mental health causing

them to be seriously harmed legally, financially and

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emotionally.

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UNDER THE TERMS OF THE HIGHER EDUCATION ACT OF 1965, AS AMENDED, THE U.S. SECRETARY OF EDUCATION: is required by law to pUbli5h a

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list of nationally recognized accrediting agencies that the Secretary determines to be reliable authorities on the quality

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of education or training provided by the institutions of higher

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education that thev accredit. Defendant degree mills like ACFEI

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naturally will have taken advantage of the EstablLshment Clause

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and Free ExercLse Clause of the FLrst Amendment by representing

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themselves as sem~naries, since in many jurisdictions religious

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institutions can legally offer degrees ~n reliaious subjects

! w i.t.riout: gO\Ternlnent rec a I e t i on .

4 THE US DEPARTMENT OF EDUCATION LAUNCHED ITS DATABASE OF

5 ACCREDITED POSTSECONDARY INSTITUTIONS AND PROGRAMS WEBSITE TO 6 COMBAT THE SPREAD OF FRAUDULENT DEGREES.

7 A number of states including California have passed bills and 8 are planning to restrict the ability of organizations like the 9 Defendant ACFEI to awa r d degrees w i thout accredi tation or

10 approved study programs.

II

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NINTH CAUSE OF ACTION IS BASED UPON THE LEGAL PROPOSITION THAT IT IS JUST AND LEGALLY PROPER FOR DR. TADROS AND MEMBERS OF THE

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14 15 16 17 18 19

PUBLIC TO SUE a company in another state that illegally operates

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a diploma mill, its officers, and individual members who created a public fraud upon the family law courts of the state o£ California and the family law litigants by entering into a plan of action, with acts of furtherance, to accomplish the following legal acts and actions, with the wanton and willful disregard for the constitutionally protected rights of due process of law of the affected family law litigants. The defendant diploma mill did cause and create unlicensed unaccredited educational private

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party's that does the following;

a. allows any individual, including a house cat named Zoe to be awarded a PhD and Diplomatic status as a Doctorate in Counseling Psychology and a M.S. in Clinical Hypnotherapy.

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THE ONLY REQUIREMENT FOR RECEIVING THIS TYPE OF LOFTY EDUCATIONAL ACHIEVEMENT IS FOR THE APPLICANT TO HAND OVER

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THE REQUIRED CASH PAYMENT, no study, 1~10 education is

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required. ACFEI did not request certiflcates, transcripts

from the universities the housecat supposedly attended or

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any licenses to practice psychology, social workJ or counseling. l\s Dr. Eichel quoted, "The AP]\ and ACFEI does

not seem to find these necessary to elevate a person (or a

cat) to the lofty status of "Diplomate." Needless to say,

no examination (not even by a vet) was required."

b.) THE FOLLOWING IS THE ISSUE BEFORE THIS COURT: lS it

unjust or illegal for court-appointed 730 child custody evaluators to do any of the following:

1. Purchase false educational credentials from the

defendant's diploma mill like ACFEI, with the intent and purposes of using these false documents for convincing the public at large and 730 evaluation clients that the evaluator has and holds advanced

degrees in forensic psychological evaluations of children?

2. Would It Not Be A True Finding Of Fact (For Judicial Example And Legal Contrast Of Stephen Doyne Phd As A 730 Evaluator For The Court) and fraud upon the Court to knowingly and willingly purchase false and fake educational credentials from ACFEI for use in

the 730 family law Evaluation process to convince prospective clients that he (Doyne) held advanced degrees, which would justify the higher expenses of

upwards to $30,000 more or less for psychological evaluations of the entire family?

a.) Would it not be a fraud upon the family litigants

and upon the court (Doyne PHD which is used as a true

fact and illustration to make a contrast between the

right and wrong of the situation) to do the following:

to fa_Isel}' impersonate to the family Law court, his

730 clients and others of him having and holding

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diplomatic status as a fOTensic child custody

e"\faluator h"-_1~en sue]] deg-Ye2S h7ere the result of false

c i edetit.i e l s produced by defendant ACFEI?

b.) That the documentation and presentation of this

5

claim was the illegal result of a conspiracy to

defraud the family law court and the family law litigants of the reasonable and valid expectation of reliance upon the 730 evaluations that were purchased

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in good faith?

c.)Is a 730 evaluation client invested legally with a

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reasonable legal expectation of fair dealing, honesty, and complete and full disclosure of any material facts that could or would affect the outcome of the 730

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evaluations - related to the factual ability of the

evaluator to make an untainted, unbiased report to the court based on factual earned credentials and valid

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psychological experience?

d.)Wouldn't any purposeful failure in this effort by

the 7:30 evaluator and the co-conspirator ACFEI

naturally invoke violation of the fair business

practlces act?

3. IT IS A FACT THAT STEPHEN DOYNE PHD DID PURCHASE FAKE AND

PHONY EDUCATIONAL CREDENTIALS FROM ACFEI:

This was not with the intent to use them for novelty purposes.

It is a fact that Doyne PHD purchased false credentials with the

purposeful intent of defrauding the court and the family law

litigants in 730 evaluations and made good upon that purposeful

intent with defined acts of furtherance in

unction w.i th

defendant ACFEI.

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12

1

7 4. STEPHEN DOYNE PHD EXHIBITS THE MOTIVE NECESSARY AND THE

3 MEANS, and all the action steps to cause a fraud upon the court,

4 the family and the litigants for the purpose of satisfying a

5 joint conspiracy wi

the diploma mill operator ACFEI, which lS

6 brought for legal contrast of a factual comparison for the

7 courts consideration in and throughout this pleading.

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9 5. THE DEFENDANT DIPLOMA MILL OPERATOR ACFEI had as its motive

10 financial gain through the use of fraud that has been defined in II the foregoing text causing the thing to speak for itself.

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14 6. THE DIPLOMA MILL AND OPERATORS like ACFEI cannot find any 15 refuge in claiming no motive for supplying false and perjured,

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educational credentials to Stephen Doyne PHD and other 730

Evaluators for novelty and entertainment purposes only. This

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very defendant did contact Dr. Tadros and others and attempted to threaten them to shut down the public exposure of the diploma mill, or suffer a $1 million law suit, that would be filed In

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Missouri. It is most interesting in matters of civil and criminal deceit how it is always the illegal perpetrator and operators of criminal enterprises who seek the refuge of the law - this case is no exception.

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7. BY WAY OF FACT AND EXAMPLE OF A TRUE CONTRAST BETWEEN RIGHT p~D WRONG THIS COURT CAN CLEARLY UNDERSTAND THE FINANCIAL

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MOTIVATION OF STEPHEN DOYNE PHD wh e n complete family 730

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evaluations cost up to $30,000 per evaluation. This is based

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process will clearly prove these evaluations are also a fraud.

'") Through

scovery it will be proven that these evaluations are

3 110

ng more then quickly adapted cut-and-paste cookie-cutter

4 evaluations, causing the prices that were charged to be a

5 continuing part of the fraud

example of true facts for

6 judicial contrast of the issues as they relate to the Defendant

7 ACFEI and Doyne the defendants co-conspirator. This examination 8 of the 730 Evaluations can clearly be accomplished by rejecting 9 the names of the parties and supplying copies of all 730

10 evaluations performed by Stephen Doyne PHD over the past five

II years.

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8. THE DIPLOMA MILL ACFEI WAS FORCED TO MAKE AND TAKE PROTECTIVE

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MEASURES to avoid any and all inquiries as to the validity of

15 the educational credentials held by defendant Doyne. (This lS

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used as an example). Like all fraudulent schemes disclosure of any type or kind, word could cause a fraud to be exposed. The defendant diploma mill ACFEI by protecting the fraudulent educational holder of the false credentials refused to give any information about the educational process based upon the claim that Stephen Doyne PHD has a right to privacy and this information cannot and will not be released without his

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permission. By and through the process of discovery is confident

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that that the actual fraud of the defendant diploma mill operation ACFEI w i Ll be exposed as a co-conspirator of Doyne

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PHD.

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AS STATED IN THE BEGINNING OF THIS COMPLAINT -THIS CAUSE OF ACTION IS BEING BROUGHT BY A PRIVATE CIVIL ACTION IN THE NAME OF

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THE PUBLIC GOOD THE PUBLIC INTEREST, as present conditions and

injuries suffered by Dr. Tadros and other members of the public

~ in this cause of action violates public policy

equal

3 protection clauses. THE PROLOGUE TO THE U.S. CONSTITUTION STATES

4 THAT ensuring domestic tranquility is an objective of

5 government. Ci 1 Rights laws that have been violated in the

the defendants promotes an ethical, as well as

6 case at bar,

7 legal comm i tment for public redress, wh en the public interest is 8 endangered and equal rights and protections of the law are

9 continuously being denied, through no fault of the litigants.

10 II 12

THE COYRTS ARE REQUIRED AND MANDATED UNDER AND IN THE LAW TO RESOLVE STRONG ETHICAL DILEMMAS IN SOCIETY THAT AFFECT THE PRESENT AND FUTURE WELL-BEING OF THE CITIZENS OF THIS STATE AND

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THIS SOCIETY: such as the 6nes defined herein. The controversial

15

issues defined in this complaint are brought to preserve, protect and defend the legal interests of the people of the state of California.

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THE COURT IS NOTICED THAT OTHER INDIVIDUALS WILL BE ADDED AS PLAINTIFFS AS THIS MATTER PROGRESSES.

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The court is also noticed that there remains an unnamed,

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unnoticed and uninformed cognizable group of legally

disenfranchised individual family Law litigants that numbers

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into the thousands upon thousands in the state of California and

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other states.

By and through the process of discovery these

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unnamed, unnoticed, unaware plaintiffs will be located, noticed

27

and given an opportunity to join this case and cause of action

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in the Name Of The Public Interest, Public Good . Those that are

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pres

ly aware and those that are unaware and unnoticed should

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not be forced to unwillingly suffer continued deprivation of

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'")')
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,
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I their constitutionally protected rights as defined in the first, fifth and 14 Arnendments under The Equal Protection Clause Of

The U.S. Constitution and corresponding clauses statutes and

codes in California Constitution because of continuing ignorance

and failure of notice of those violations.

IT IS NECESSARY TO DEFINE THE PUBLIC GOOD AS IT IS USED IN THIS

CAUSE OF ACTION. Local, state, and federal regulatory acts

influence and control the conduct of professions of psychology

and acting as a 730 evaluator in family law matters in the name

of the public good. The legal and ethical issues in conducting the day-to-day affairs as a psychologist as a 730 evaluator who has falsified their credentials, with preplanning prior to litigation opens the legal door and allows the application of

law that holds the plaintiffs accountable for their fraudulent

actions

in tainted 730 evaluations as will has been explained

If correction is not forthcoming from the court then the

damage to the public at large and individual litigants will continue unabated. Any failure to cause correction would cause and create irreparable harm to the interests and public reputation and prestige of the family law courts in the reputation of the judges that populate those courts.

THIS COURT WOULD NEVER ALLOW THE CREATION OF A SPECIAL CLASS OF PERSONS OR LITIGANTS WITH UNEQUAL RIGHTS AND PROTECTIONS UNDER IN THE LAW.

This is because such a creation of a special class of persons

who have UNequal rights and protections under and in the law

wo u l d violate the 14 r fifth and first amendments of the U. s.

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Constitution and corresponding constitutional provisions

2 in California law.

5

THI$ COURT WOULD NOT ALLOW ANYONE TO USE FALSE CREDENTIALS TO PRACTICE LAW BEFORE THIS COURT: on any legal matter that is

6 7 8 9

10 11

pending before this court. The court also would not allow anyone to knowingly and willingly pretend to be an airline pilot when they presented credentials from a diploma mill that granted them the right to fly passengers around the country in an airplane, while pretending to be a bona fide pilot with the proper certification, expertise and education to legally fill that role as an airline pilot. Using the reasonable judge and reasonable person standard no one would put anyone they cared for on an airplane to be flown by someone who had credentials from a diploma mill. That would not satisfy the public safety, public policy, or the need to protect the public from the illegal acts and actions and preplanning collusion, and conspiracy that transpired between the imposter airline pilot and a diploma mill to the risk and detriment of all. There is little or no

12

difference in the acts and actions of false credentials of the airline pilot in the actions taken by Stephen Doyne PHD and his co-conspirator defendant diploma mill.

THE COURT CANNOT AND SHOULD NOT ALLOW ANY 730 EVALUATOR TO BE ILLEGALLY PLACED IN A POSITION OF POWER INSIDE OF A FAMILY LAW

LITIGATION that addresses contested concerns of

child custody,

visitation and contact; when that 730 evaluator arrived at that

position of judicial power by the illegal use and abuse of

presenting false, educational credentials to maintain a larger

market share, and to increase his income by buying credentials

27

from a diploma mill and presenting them as being verified and

, bona fide results of required study to obtain the required

degrees. Before the court to rely upon the 730 evaluator's

4 report the court must have confidence in the evaluator that he 5 or she will follow the ethical and legal standards established 6 by the law, which requires the 730 evaluator at all times to be 7 completely truthful and forthcoming with the court and the

8 litigants.

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10 11

THIS BEGS THE QUESTION WHY WOULD A 730 EVALUATOR NAMELY STEPHEN DOYNE PHD FIND IT NECESSARY TO ENTER INTO A PRE-PLANNING MODE WITH THE DEFENDANT WHO OWNS AND OPERATES A DIPLOMA MILL;

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and purchase false and forged degrees from that diploma mill prior to the litigation and evaluation? Once again it could not be r e a s o nab Ly argued that Stephen Doyne PHD wa s being completely forthcoming and honest with the trier of fact and the litigants by not disclosing that he presented false educational credentials to maintain his position as the court expert, in 730 matters.

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THIS DISCLOSURE WAS NOT NATURALLY AND NORMALLY MADE BECAUSE IT WAS NECESSARY TO HIDE THE FACT OF THE FRAUD, which by failure of

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disclosure is confirmed as a part of the fraudulent process to maintain power and control as a court expert and 730 evaluator

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by simply writing a check to a diploma mill.

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THE REAL QUESTION WHEN DEALING WITH FALSIFICATION OF EDUCATIONAL QUALIFICATIONS AS A COURT EXPERT AND 730 EVALUATOR BEGS AN EVEN MORE IMPORTANT QUESTION.

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Using the reasonable person and the reasonable judge standard:

9

would any reasonable judge or any reasonable person place their

2 trust or continue to employ the services of a 730 evaluator who

3 declared ope n I y t.tie t: l1.e just presented false crecielltials to the

4 court and the litigants. Then if that 730 evaluator further

< explained that this wa s done as a part of preplanning and

6 prelitigation acti ties to maintain a larger market share and

7 hTas designed to be eb.l e to command higher fees for the 730

8 eval 11a ti on?

10 II 12

ONCE AGAIN THE REASONABLE JUDGE AND A REASONABLE PERSON STANDARD WILL CLEARLY STATE THAT 730 EVALUATOR AND HIS OR HER SERVICES WOULD NO LONGER BE REQUIRED BY THE COURT. This wou l.d be because the court could not justify the continued use of untrustworthy nature and acts or actions of the 730 evaluator.

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THE UNTRUSTWORTHY NATURE AND ACTS OR ACTIONS OF THE 730 EVALUATOR WOULD CLEARLY INDICATE USING THE REASONABLE PERSON AND

A REASONABLE JUDGE STANDARD THAT; the 730 evaluator was w.i thout a doubt mentally and psychologically damaged and impaired to the point he or she had a need to falsify their credentials. This speaks volumes to the credibility and to the mental stability of

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that evaluator causing their automatic

squalification. The

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trier of fact and the litigants would not naturally proceed with

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the evaluation of fear that once this information was known to

them this would be a legal ground for causing any evaluation

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results to be set aside based upon the mental instability and

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the fraud of the individual 730 evaluator.

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THE ISSUE OF CREDIBILITY: at the risk of being redundant Dr.

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Tadros hereby brings to the court's attention that the 730

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9 10 11

evaluator like Dr. Doyne is not and has not been completely

~ forthcoming with all material facts to the trier of fact and the

litigants as a quasi officer of the court, which was and is the

4 result of preplanning and entering into a conspiracy to falsely

5 enhance their academic standing, to the dollar value, that they 6 may charge for psychological evaluations and cause domination

7 and control of the market share of psychological evaluations 8 upon reports and reco~~endations.

ONCE AGAIN RETURNING TO THE REASONABLE JUDGE AND REASONABLE LITIGANT

STANDARD; each and every litigant that was in the 730 evaluation with

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Dr. Doyne or any other 730 evaluation where the evaluator used false credentials would have a legal right to be informed by the court or others that their constitutionally protected right to parent without government interference or unwarranted intrusion may have been tainted. This is because of the fraud upon the court, the litigants and the litigant's children by the fraudulent representations and misrepresentations of educational credentials that were illegally purchased across state lines that have materially affected the constitutional right to parent.

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EXAMPLE: there has been a great hue and cry across this nation by civil rights advocates now that it has been revealed that black men with syphilis were selected and allowed to go untreated and suffer catastrophic physical, emotional and mental failures. This was

because they were not informed that a simple round of injections of penicillin would have prevented their premature death, disability and

emotional and physical distress. This is a violation of the civil

rights of the targeted individuals and is a good example

f abu s e o f

reliance on the government and the courts to be truthful and

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II I

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of Dr. Doyne and other"730 evaluators that have illegally used

forthcoming with all litigants when their rights have been

~ transgressed upon. The civil rights advocate becomes completely upset

because of the emotional and physical suffering of the uninformed ctims. There is no real difference between the uninformed victims

6 perjured credentials to become a public court expert by pretense and 7 fraud. Because of the enormous scope and nature of the number of

8 litigants that have been harmed over a ten-year period, only the

9 process of discovery can or will suffice in establishing the scope !O and depth of the damages caused by this conspiracy, and preplanning, II and prelitigation actions that have tainted thousands upon thousands 12 of 730 evaluations in the state of California and other states.

13

IT WILL BE PROVEN THAT 730 CHILD CUSTODY EVALUATIONS ARE ROUTINELY RUBBERSTAMPED BY FAMILY LAW COURT JUDGES causing and creating a

condition where the judicial decision remains not in the hands of the

trier of fact, but in the hands of the 730 evaluator.

This becomes

an important fact and factor to consider whe n evaluators like Dr. Doyne and others enter into conspiracy, with the intent to defraud the court and the litigants to maintain their position as a court expert by and through the preplanning and prelitigation process. This clearly indicates that Dr. Doyne would not have even been considered for this position of power and recommendation to cause life-changing events in the lives of the children of the parents if the court had been aware of his perjury, collusion, prelitigation planning and

falsification of documents. This takes on even greater meanings when

these 730 Evaluations are used by the California Child Support

Guidelines. These federally mandated guidelines are required to

.r1 ' ueCl

the amount of financial remuneration that each parent must

pay, in the form of child support, under the federal influence and

3 J

7

de creating absurd legal

mandates. These child-support calculations are almost universal

2 across the 50 states of this nation and its territories. Therefore

the use and abuse of false diploma mill credentials finds its way

4 into child-support calculations nati

5 results by through collusion, conspiracy, and the tainting of child

6 custody evaluations nationwide.

8 CHILD SUPPORT: child support is calculated by using the incomes and 9 the timeshares of the parents. When the timeshare of one parent

10 changes, or that parent, because of the 730 evaluation, has been

II tainted and given 10 time share or no time share at all - that

12 targeted parent will be forced to pay a higher rate of child support, 13 than a parent that has a 60 time share more or less. Now if you were

14

a parent that had a 730 evaluation with Dr. Doyne and you lost time share and your child supp-ort was increased: would you not have the legal right to know that the report was tainted because of the fact that Dr. Doyne's child custody evaluation cannot be relied upon, because it has been tainted by his perjury and the presentation of false and educational documents and documentation to maintain his

15

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position as a court expert and to maintain and to grant him hi fees for that evaluation process.

r

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ONCE AGAIN USING THE REASONABLE JUDGE AND A REASONABLE LITIGANTS STATUS THAT LITIGANT WOULD HAVE THE LEGAL RIGHT AND NEED TO BE

INFORMED THAT; his or her constitutionally protected rights of equal

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protections under and in the law, and for a fair and just and

equitable legal result was in question. This is because of the

perjury and the failure of 730 Evaluators, like Dr. Doyne who

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obtained false credentials from defendants, to be forthcoming. Thus the public has a right to be informed that they may be suffering from

32

an illegal act or action that may require the child custody matter L

2 be retried and having the judgment be set aside.

4, THE NEGATIVE EFFECTS: the question is who becomes responsible for

5 damages suffered by the tainted child custody rulings when it affects

6 the children, the parents, the additional unnecessary costs to the

7 court to retry the custody issues, and the attending attorneys fees 8 and costs for re-adjudication of the issues of child custody, child 9 support, visitation and contact. These issues would have to re-tried

10 because of violations of the equal protection clauses of the 5- and

1 J 14 Amendments violations. It could not fairly and honestly be

12 claimed that when the 730 evaluator is presenting perjured

13 educational credentials that any of the litigants ever got a fair 14 hearing. It is well-established in fact and law that time once lost

15

with children during their formal years can never be regained. How does one place a dollar value on the illegal loss of child custody, visitation or contact, or the overpayment or under payment of child

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17 18 19 20

support, or the loss of companionship of a child, or the emotional, financial, and legal abuse of process that is result of the direct and indirect actions of the defendants perjury, collusion, fraud upon the court, the litigants, and the litigants children.

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THESE INJURED PARTIES HAVE A LEGAL RIGHT OF REDRESS AND TO BE OFFERED A LEGAL OPPORTUNITY TO BE MADE WHOLE: to have their the

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continuing constitutionally protected right to parent preserved?

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The answer is yes!

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ANY FAILURE ON THE PART OF THIS COURT TO ALLOW THESE UNNOTICED, UNNAMED, UNINFORMED INJURED PARTIES: from being made awa r e that

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their civil rights, legal rights, constitutional rights, and

3

had s

rl ts to a fair trial and/or hearing

t may have been

~ violated would be no different than demanding that the black men

ilis be denied continuing care or be

informed of

4 their illness and a cure.

5

6 THIS COURT ONCE IT KNEW AND UNDERSTOOD THAT THE INFECTED PERSONS

7 COULD BE MADE WHOLE BY SIMPLE COURSE AND TREATMENT OF

8 ANTIBIOTICS WOULD NOT CAUSE THAT TREATMENT TO BE WITHHELD. If 9 the court would cause the treatment to be withheld it would be

10 an abuse and loss of one's civil rights. It would also violate 11 the public poli ,a denial of the public's right to know, and 12 the right of each and every injured individual to be made aware

I~ of the possible injuries to their legal rights and causes of ~

14 15

action. The damages caused by 730 Evaluators, like Stephen Doyne PHD who obtained false credentials from the defendant's need to

16

made whole, just like the infected men with syphilis needs the injection of sunlight to address the corruption and disease to

17 18 19 20

that body of law and the litigants that suffer from the illegal results of the tainted cases.

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IT IS CLEARLY UNDERSTOOD BY DR. TADROS IN THIS CAUSE OF ACTION

22

THAT THE COURT WOULD NOT WELCOME OR ENTHUSIASTICALLY EMBRACE THE EXPENSES AND THE PROBLEMS THAT WOULD FLOW FROM THIS LITIGATION:

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and the notic

and retrying possibly thousands upon thousands

25

of cases that involve 730 evaluations made by Dr. Doyne and

26

others. The job of the court is to act and preserve the public

27

good no matter what its cost or how treacherous or torturous the

28

path to justice may be. If this were not the case then this

29

would make a mockery of our laws and reduce the Constitution and

30

laws of this State and nation to empty words and the

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._

II

7

Consti tution to nothing more than pretty empty wo r d s on the page

, with no force and effect of law. It is upon this legal backdrop

3 that Dr. Tadros now comes to this court requesting relief for

4 themselves and the individuals known and unknown in the name f

5 the public good, the public welfare, public policy, and public

6 protection.

8 THE COURT IS FURTHER INFORMED THAT WHILE OTHER LITIGATION HAS

9 BEEN ONGOING the issue of the false credentials from Doyne's colO conspirator has remained an unknown litigated issue and is not

11 res Judicata.

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13

14

COMPLAINT SUBMITTED WITH LEAVE TO AMEND

This complaint is made and tendered with a reasonable

15 expectation and right of a one time amendment without leave of

16 17 18 19

,20 21

22

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the court. The court is noticed that an amended complaint may

issued in the very near future as other facts become known by

and through the process of discovery that will be effective immediately on the defendants in this cause of action.

VERIFICATION OF PLEADING

THE PLAINTIFF HEREBY DECLARES IF CALLED TO TESTIFY IN THE ABOVE-

ENTITLED MATTER he would individually and collectively testify

competently and truthfully from his own personal knowledge of the events and charges found in this complaint. This declaration is submitted into evidence pursuant to Code of Civil Procedure

2009.

The plaintiff swears and affirms the foregoing is true

II

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6 7 8 9

10 11

, state of California.

and correc~ under the laws of perJury and under the laws of the

Enfad)Tadros M.D.

Plaiht1ff In Pro Per

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J 5

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4 Executed this day on January 02, 2011

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