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Dr Z

Joseph Zernik, PhD

PO Box 526, La Verne, CA 91750;
Fax: 323.488.9697; Email:
Blog: Scribd:

March 9, 2010

Bank of America Corporation - Beyond Financial Recklessness - Corruption of the


Brian Moynihan _ _ Kenneth Kaiser _ _ _ Kenneth Melson

President_ _ _ _ _ _ Assistant Director_ _ _ Former Director
Bank of America_ _ FBI_ _ _ _ _ _ _ _ _ _ _ Office of US Attorney General

Complaints alleging fraud and criminal conduct by all three are now pending before US agencies, with Congressional Inquiries by Senator Dianne
Feinstein, asking such agencies to respond on the complaints.

Starting early 2007 short notices were posted on public forums titled “Countrywide – Beyond financial recklessness –
corruption of the courts”. Today, three years later, the title can be slightly modified: “Bank of America – Beyond financial
recklessness – corruption of the courts”.

Complaints by Dr Joseph Zernik are today pending before Office of the Comptroller of the Currency (OCC) John Dugan,
and before the Office US Department of Justice Inspector General (DOJ-IG) Glenn Fine, the subject matter of both being
alleged criminality of senior management at Countrywide/Bank of America Corporation in matters that pertain to the
causes of the current US integrity/financial crisis, and cover up of the same by US banking regulators, US Courts, FBI,
and US Department of Justice. In both cases, Senator Dianne Feinstein issued inquiries on the respective US agencies
why they would not respond on the complaints.

The complaint to OCC #00971981 provided credible evidence of criminality by Brian Moynihan, President/CEO of Bank
of America Corporation, starting on December 11, 2008, less than 24 hours after his appointment to replace Mr Timothy
Mayopoulos as General Counsel of Bank of America. [1] The unusual circumstances surrounding the ouster of Mr
Mayopoulos were subject of investigation by NY State Attorney General and US Congress. Dr Zernik’s Complaint to OCC
provided evidence that Mr Moynihan was ready, willing, able to collude in criminality, which Mr Mayopoulos brought to
a halt. The evidence of criminal conduct by Brian Moynihan continued all the way to January 2010 – soon after his
appointment as President of Bank of America Corporation. At that time he allegedly engaged in fraud in response on the
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complaint to OCC – to cover up his alleged criminality in conduct as General Counsel of Bank of America in December

The complaint pending before DOJ-IG alleged fraud by two senior officers of the US Justice Department – Kenneth
Kaiser – Assistant Director for Criminal Investigations, and Kenneth Melson – then Director of the Executive Office of
US Attorney General. The alleged fraud was in responses that the two officers provided to US Congress, Senator Dianne
Feinstein and Congresswoman Diane Watson in August-September 2008, which effectively covered up criminal conduct
by Countrywide senior management and refused to provide Complainant Joseph Zernik equal protection under the law
against alleged criminal conduct by Countrywide and Bank of America Corporation.

Responses by US agencies to Congressional Inquiries are typically due within 30 days. In both cases described above the
agencies are late in their responses. Honest responses by either OCC or DOJ-IG on the pending complaints may mark a
noted departure in ending the cover-up and exposing the alleged criminality underlying the current US
integrity/financial crisis.


[1] Addendums to complaint against Bank of America Corporation and Brian Moynihan filed by Dr Joseph Zernik with
US Office of the Comptroller of the Currency.

[2] Addendum to complaint against Kenneth Kaiser and Kenneth Melson senior officers of US Department of Justice,
filed by Dr Joseph Zernik with US Office of the Inspector General of US Department of Justice

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