10 Billy Z. Farley P.A. 2144 Wembley Lane Corona, California 92881 ‘Telephone: 714-615-4956 Email: bze2101@aol.com Guven Uzun MD. 4712 Admiralty Way, Suite 930 Marina Del Rey, California 96259 ‘Telephone: 310-867-5556 Email: medicalexpert|@gmail.com Attorneys for Plaintiffs In Propria Persona, pro se Litigants UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA BILLY Z. EARLEY P. GUVEN UZUN M.D., Plaintiffs, v. EDMUND LD BROWN JR., Governor of California, in his Official Capacity; and XAVIER BECERRA, Attorney General of California, in his Official Capacity, and DOES 1 - 10 Defendants, NOTICE TO ALL INTERESTED PARTIES: Billy Z. Earley and Guven Uzun (“Plaintiffs”) hereby submit their Opposition to Edmund Gerald Brown and Xavier Becerra (“Defendants”) Motion to dismiss pursuant to 12(b)(6), and 12(b)(1). Plaintiffs CASE NO: 2:18-CV-0723-JAM PLAINTIFFS’ OPPOSITION TO DEFENDANTS MOTION TO DISMISS, MEMORANDUM OF POINTS AND AUTHORITIES AND DECLARATION OF BILLY Z. EARLEY AND GUVEN UZUN IN SUPPORT OF DENYING 12(B)(6)[1} Date: June 19, 2018 Time: 1:30 p.m. Courtroom 6: 14th Floor Judge Hon. John A. Mendez Trial Date: Not set Action Filed: April 2, 2018 JURY TRIAL DEMANDED declare the following facts and declarations in support of this Motion: PLAINTIFFS’ OPPOSITION TO 12(B\(6)-[1] MOTIONTABLE OF CONTENTS Page Introduction... Statement of Fact.. Xavier Becerra — Fact In Support Of Claim... Edmund Gerald Brown ~ Fact In Support Of Claim.. Argument... A. Congress Request To Investigate DOJ... B. Department of Justice Code of Silence... C. Department of Justice Criminal Rin; D. Memorandum of Points and Authorities........ Conclusion... Declaration of Billy Z. Earle P.A. 12 14 — A: November 3, 2014. Intemal Email, Gloria Castro, Senior Attorney General Declaration of Guven Uzun M.D. Ex! For Xavier Becerra. She states “We can’t investigate Dr. Uzun’s DOJ Criminal Ring complaint because it’s against our own people”, Castro writes “Protect Deputy Attorney General Collen MeGurrin and Brush-off Uzun’s complaint.” Send him back to MBC where Uzun will be subjected to Retaliation... 16,17 Exhibit — B: November 20, 2014, Castro writes “We received your complaint about your federal rights were violated (DOJ Criminal Ring).” We represent the MBC and DOJ; we will not respond (investigate) your complaint of [Police Abuse/Fraud]. “I am sending [your ‘Confidential Complaint’ to the perpetrators,” our clients!... 8.19 Exhibit — C: Policy clearly show that DOJ Must Investigate Citizens Complaints of police misconduct, but Becerra’s office is not doing this and retaliating. -20,21,22, PLAINTIFFS’ OPPOSITION TO DEFENDANTS MOTION TO DISMISS COMPLAINT (2:18-CV-00723-JAM)TABLE OF AUTHORITIES Page Cases Asherofi-v. Iqbal, 556 U.S. 662, 678, 129 S.Ct. 1937, 173 L.Ed.2d 868(2009), Beck v. Prupis, 529 U.S. 494, 498 (2000)... Bell Adantic Corp. v. Twombly. $50 US. 544, 555 (2007)... Boyd v. US 116 U.S. 616.. Brandon v. Holt, 469 U.S. 464, 471, (1985)... Bridge v. Phoenix Bond & Indem. Co.. 553 U.S. 639 (2008).. Buckheit v. Dennis, 713 F, Supp. 2d 910, 925 (N.D. Cal. 2010). Ex parte Young. 209 U.S. 123 (1908).. General Oil Co. v. Crain, 209 U.S. 211 (1908)... Harlow y. Fitzgerald, 457 U.S. 800 (1982 ii PLAINTIFFS’ OPPOSITION TO DEFENDANTS MOTION TO DISMISS COMPLAINT (2:18-CV-00723-JAM)Auk ew TABLE OF AUTHORITIES (continued) Page Cases Katrina Canal Breaches Litig. 495 F.3d 191, 205 (5th Cir. 2007)... ‘Marbury v. Madison, 5 US 137... Porter v. Warner Holding Co. 328 U.S. 395, 398 (1946)... Tinker v. Des Moines Independent community School District, 393 U.S. 503, 89 S. Ct. 733, 21 L. Ed. 2d 731 (1969)... United States v. Frega, 933 F. Supp. 1536 (SD Cal. 1996)... CONSTITUTIONAL PROVISIONS COURT RULES Fed. R. Civ. P. 12(b)(1)..-.- 12(b)(6).... STATUTES SUS.C.§ 7311... 8 U.S.C. § 1324b..... 18 U.S.C. § 1918......... 20U. . 1681. PLAINTIFFS’ OPPOSITION TO DEFENDANTS MOTITABLE OF AUTHORITIES (continued) 29 U.S.C. 794,. 42 U.S.C. § 1983.. 42 USC. 6101... CONSTITUTIONAL PROVISIONS 42 U.S.C. 2000d-7.. OTHER AUTHORITIES Assembly Bill Oe 540... Senate Bill 54...... Government Code 1360......... Government Code 1770(i).......... Executive Order 10450... iv PLAINTIFFS" OPPOSITION TO DEFENDANTS MOTION TO DISMISS COMPLAINT (2:18-CV-00723-JAM)T INTRODUCTION 1. Under common law - those injured by the tortious acts of a state employee can sue that employee for his personal liability, which is a right to sue. A plaintiff can sue every office through whom the state acts, from the Governor to the “Registrar- Recorder/County Clerk,” but not the state itself. The Court has upheld this rule laid down| by two 101-year-old companion cases. See Ex parte Young, 209 U.S. 123 (1908) and General Oil Co. v. Crain, 209 U.S. 211 (1908). 2. In addition, plaintiffs are not suing defendants for money damages and therefore there are no hurdles of qualified immunity. See harlow v. Fitzgerald, 457 U.S. 800 (1982). Government officials performing discretionary functions are generally shielded from liability for civil damages insofar as their conduct does not violate clearly established statutory or constitutional rights of which a reasonable person would have known. In defendants’ case, this is not true; they were cognizant that their actions violated federal and state law; most violations were with knowledge and intent. is Federal Rule 12(b)(6) standard requires a complaint to “contain sufficient! factual matter, accepted as true, to state a claim for relief that is plausible on its face.”| Ashcroft v. Iqbal, 556 U.S. 662, 678, 129 S.Ct. 1937, 173 L.Ed.2d 868 (2009). 4, The defendants’ do not challenge any of the allegations, therefore, in considering a motion to dismiss for failure to state a claim, the district court must accept all well-pleaded facts as true, viewing the facts in the light most favorable to the plaintiff. See In re Katrina Canal Breaches Litig., 495 F.3d 191, 205 (Sth Cir. 2007). PLAINTIFFS’ OPPOSITION TO 12(B)(6)-[1] MOTIONat STATEMENT OF FACT 5, In Bell Atlantic Corp. v. Twombly 550 U.S. 544, 555 (2007), the U.S. Supreme Court considered what a complaint must contain to survive a motion to dismiss for failure to state a claim pursuant to 12(6)(6)-{1]. The court held, such a motion to dismiss should be denied unless it appears “beyond doubt” that the plaintiff could prove no set of facts in support of the claim that would entitle plaintiff to relief. This is not so. 6. The Supreme Court held that a state officer can be sued for attempting to enforce an “invalid” law. Official capacity suits is not a suit against the official but rather is a suit against the official’s office. See Brandon v. Holt, 469 U.S. 464, 471, (1985). IIA. Xavier Becerra — Fact in support of claim: a) Conspired with Imran Awan to conceal evidence from Capitol Police, b) Provided knowing and deliberate false evidence to Capitol Police, c) The willful and deliberate attempt to obstruct justice by interfering with al criminal investigation conducted by Capitol Police, d) Aiding and abetting with a criminal enterprise - the Awan’s family and| friends of their inner circle, e) Members of the Senate and Congress referred to the Imran scandal as a| National Security Threat, £) Violation of the California Constitution, Government Code 1360, and failure to register his Oath of Office with the Secretary of State, 2) Violation of Executive Order 10450, 5 U.S.C.§ 7311, and his Oath of Office by advocating the alteration of government by unconstitutional means, h) 18 U.S.C, 1918 provides removal of office for those in violation 5 U.S.C. § 7311, and Government Code 1770(i), and finally 2 PLAINTIFFS" OPPOSITION TO 12(B\6)-[I] MOTION=a The original complaint filed April 02, 2018 outlined the above facts and additional concerns regarding serious misconduct and unlawful activities involving] defendant Xavier Becerra. These factual allegations raised by plaintiffs supersedes any speculative level or threshold; clearly defending against Oppositions’ 12(b)(6) Motion. 8. This Court has jurisdiction pursuant to 18 U.S.C. § 1918, 5 U.S.C. § 7311, and pursuant to Government Code 1360 with respect to defendant Xavier Becerra; since most of the alleged actions arose in the State Capitol located in this jurisdiction. Defendants Motion to dismiss pursuant to 12(b)(1) also lacks authority and merit. In addition, it is apparent that defendants filed 12(b)(6)[1] Motion with some frivolous| intent, raising good cause for appropriate sanctions to be imposed by the Court, IIB. Edmund Gerald Brown — Fact in support of claim: a) Edmund Gerald Brown (“Brown”) has strong ties with CVS Health (“CVS”) and they were identified as one of Brown’s top campaign donors, b) In November of 2015, plaintiff requested Brown to investigate the Medical Board and CVS for corruption. A 75-page report with exhibits and direct evidence outlining corruption was sent; this was not just a certified letter. c) Brown and the DOJ was informed that CVS employees all over the US had confidential secret investigative records about DEA operations, Medical Board access, and knowledge of local police activities, dating back to 2011, d) Brown and CVS relationship was further identified in Superior Court documents, CVS said, “We have a background relationship with state and federal government officials and we are pointing-out bad doctors,” ¢) Brown was advised that CVS employees were telling hundreds of doctors and thousands of patients that they were under criminal investigation by| Brown agencies. See original complaint, exhibit 2, pages 31 thru 36, 3 PLAINTIFFS’ OPPOSITION TO 12(B)(6}{1] MOTION,9. £) CVS exploited and used Brown’s office as a racket to control and influence the California Medical Board (“MBC”), the DEA, and other enforcement agencies under Brown’s control, a pattern recently identified in the news, g) CVS control over the DEA was identified by the Washington Post and 60| Minute investigation, entitled: “The drug distributors triumph over the DEA,” where 53 top DEA officials switched sides with Big Pharma, etc., h) Brown's relationship with CVS is a political-donor association. CVS lobbies for special interest agendas and provides lobbying and campaign funding to access special favors and resources under Brown’s control, Brown refusal to investigate CVS for having access to his regulatory agencies provides a nexus linking Brown's awareness to CVS; violation o California Anti-Trust and Competition Laws injuring millions of people, CVS use of Brown’s office is no different from that seen with their use and influence over the DEA that was nationally televised. The drug distributors led by CVS altered the US Controlled Substance Act using top DEA’ officials like David Barber, who now works for Big Pharma, and finally The evidence is clear and factual that CVS used wire and mail fraud to gain market shares of the community clinics with the explicit help of Brown’s office and other regulatory agencies under his control. The California DOJ, DEA, FBI, and the MBC were made aware of CVS having access to their agencies and confidential records and they disregarded these facts. The defendant's agencies had sufficient knowledge of CVS; unlawful practices using mail and wire fraud in California to run doctors out of business using Brown's agencies; a practice also seen happening across the country. The facts and evidence is beyond speculation and defendants Motion to dismiss pursuant to 12(b\(6)[1], lacks merit and standing with regard to CVS lobbying Brown and accessing his agencies. 4 PLAINTIFFS" OPPOSITION TO 12(B)(6)-1] MOTIONwk ew N mW ARGUMENT 10. The defendants’ position is that plaintiffs have no personal “stake” in this action and plaintiffs have only “generalized” grievances is farfetched and frankly just false. The defendants’ actions has led to severe injury by virtue of not allowing due| process and enforcing unconstitutional policies. This court must protect against any encroachment of constitutionally secured liberties, Boyd v. ULS., 116 US. 616 IITA. Congress Request to Investigate California DOJ: 1. Plaintiffs have identified two (2) important issues with respect to several of California’s regulatory agencies controlled by Brown and Xavier Becerra, On April 25, 2018, during a Congressional Briefing in Washington DC, Cannon Office Building, Room 122, plaintiffs (panelists) provided evidence to members and congressional legislative members demanding an investigation of California Department of Justice. 12. Plaintiffs’ organizations speak for hundreds of healthcare victims wrongfully targeted, harassed, and even murdered, like Anthony Jackson M.D., and then| his death was mocked by MBC officials. These acts violate the US Constitution and we are working with Congressional members to bring additional oversight. By abolishing ‘constitutional rights, the defendants are able to target Americans with police misconduct. IMB. Department of Justice Code of Silence: 13. Hundreds and thousands of doctors, patients, and healthcare providers have sent thousands of complaints to the California Department of Justice to report employee and enforcement misconduct without success. Plaintiffs have identified that the California 5 PLAINTIFFS" OPPOSITION TO 12(BX6)-1] MOTIONwoe Attorney General’s Office and their employees have activated a shadow policy that is not recognized by the Califomia Constitution, a code of silence. 14. This is the same type of code of silence seen within the California Los Angeles Police Department and other enforcement agencies, but worse. The Department of Justice primary function is public safety and to investigate charges against corrupt and dishonest police officers in the state of California, but this is not the case, 15. Plaintiffs have uncovered evidence showing that the DOJ will not investigate any complaints of misconduct made against any of its clients and employees, regardless of the severity or egregiousness of the complaint, This has led to al constitutional crisis; stripping due process and civil rights away from California citizens unlawfully and with the intent to harm, injure, and reap havoc on those affected. 16. Exhibit A and B is undeniable proof that DOJ high senior officials have adopted policies of covering-up police and DOJ misconduct and other criminal delinquencies by not investigating these serious crimes against healthcare providers and other California citizens complaining. See Exhibit C, which shows absolute proof that DOJ, headed by Becerra, is violating the law by not investigating. Congress has held that any law that repugnant the constitution is null and void. Marbury v. Madison, 5 US 137. 17, Gloria Castro instructs three DOS officials to protect their own employees and their clients and to brush-off serious complaints of state police misconduct. Instead of | investigating, they deliberately send the confidential complaints to the perpetrators. This misconduct tears away at the fabric of all Citizen Complaint laws against bad police. 6 PLAINTIFFS? OPPOSITION TO 12(B)(6)-[1] MOTIONTHC. Department of Justice Criminal Ring: 18. Plaintiff, Doctor Guven Uzun, he attended school for 12 years and he is} considered one of the top Neurologists in the state of California. He has practiced| medicine without one single patient complaint after 20 years. Plaintiff Billy Earley PA, attended school for 7 years and he practiced as a PA for over 17 years, with only one patient complaint made against him. 19. Plaintiffs have a combined total history of 37 years providing outstanding| healthcare services to patients with compassion and care. Doctor Uzun, identified a criminal ring operating out of the Department of Justice, see original complaint, page 18 and 19. Plaintiffs believe that these types of criminal rings within the DOJ targeting innocent doctors for personal wealth and greed are very common, 20. Plaintiffs are requesting that Congress investigate this type of fraud that is injuring innocent doctors and healthcare providers that have done nothing wrong but catch the eye of some greedy, crooked, and corrupt officials that can use their title and| our government agency to launch bogus investigations and pursue manufactured criminal charges against healthcare providers. This complaint is not about a generalized grievance: these DOJ employees are taking in millions of dollars by virtue of fraud and deception. 21. Plaintiffs seek Congressional Hearing and investigation into the California} Department of Justice because constitutional, state, federal, civil, and procedural due process rights have been completely abolished by defendants and their regulatory agencies, in violation of 42 U.S.C. § 1983. The Court should not grant dismissal. PLAINTIFFS’ OPPOSITION TO 12(B)(6)-[1] MOTIONIv MEMORANDUM OF POINTS AND AUTHORITIES 22. The defendants’ assertion that plaintiffs lack standing because they have no personal stake in this cause of action is simply not true. Most standing issues arise over the enforcement of allegedly unconstitutional statutes, ordinance, or policies. Plaintiffs are seeking Congressional investigation into these issues and plaintiffs may challenge a law or policy on constitutional grounds if they can show that enforcement of the law or implementation of a policy infringes on an individual constitutional right, such as Freedom of Speech. See Tinker v. Des Moines Independent community School District, 393 U.S. 503, 89 S. Ct. 733, 21 L. Ed. 2d 731 (1969). 23. The defendants contend that Eleventh Amendment Bars RICO allegations against defendant Brown and it Bars the cause of action against defendant Xavier Becerra, this is not true. Xavier Becerra does not have an oath of office filed with the Secretary of State, and there is no Bribery Bonds on file, in violation of the California| Constitution Government Code 1360, and 10450: he should not have been appointed. 24. The contention is further predicated exclusively upon the provisions of] Government Code section 1770, subdivision (i), which specify: “An office becomes| vacant on the happening of any of the following events before the expiration of the term: (i) His ot her refusal or neglect to file his or her required oath or bond within the time! prescribed. Xavier Becerra lack authority for his office and there is no immunity for those whose office is vacant and without oath of office filed, violation of 5 U.S.C. § 7311, and| his appointment violated Executive Order 10450, all undeniable facts. 8 PLAINTIFFS" OPPOSITION TO 12(B)(6){1] MOTION25. Defendants wrongfully stated that the cause of action against Brown is barred which is not true or correct. No privilege or immunity is a defense to racketeering. See United States v. Frega, 933 F. Supp. 1536 (SD Cal. 1996). Where a defendant's, racketeering (Brown) - including fraud on a third party (Patients) - causes foreseeable property loss to another (Doctors), the injured party has standing to sue under RICO. Beck v, Prupis, 529 U.S. 494, 498 (2000); Bridge v. Phoenix Bond & Indem. Co., 553 U.S. 639 (2008). Plaintiff have provided all of the predicates and how the RICO has injured and harmed, not just them, but thousands of citizens of California. 26. The plaintiffs have established a prima facie case substantiated by sufficient| facts that points in the direction of misconduct and unlawful acts commitied by defendants. In addition, the Supreme Court has purposely ruled that where “the public interest is involved... those equitable powers assume an even broader and more flexible| character than when only a private controversy is at stake.” Porter v. Warner Holding Co,, 328 U.S. 395, 398 (1946). 27. The injury to the public and private sectors are catastrophic with respect to federal and constitutional rights. California DOJ and government workers acting in bad faith and upholding unconstitutional and even protecting criminal misconduct are ripping- off the public and private areas of our republic and denying due process rights. Further, state immunities are never a defense to liability for constitutional violations. See Buckheit v. Dennis, 713 P, Supp. 2d 910, 925 (N.D. Cal. 2010). Defendants Motion to dismiss and theory fails to allege sufficient facts required for a 12(b)(6)[1] motion to prevail. 9 PLAINTIFFS? OPPOSITION TO 12(B)(6)-[1] MOTION28. The sanctuary laws adopted by defendants are “invalid” and “unconstitutional” and many cities throughout the state of California are rejecting these laws, including Huntington Beach, Orange County, and other cities. Foreign Medical Graduates are common in U.S. California residency programs, especially in the primary care specialties of internal medicine, where foreign students fill 43 percent of the slots, family medicine (36 percent) and pediatrics (24 percent), according to Accreditation Council for Graduate Medical Education (“ACGME”). 29. Plaintiffs license and careers where taken by use of fraud and| unconstitutional methods. Plaintiffs have firm belief that defendants, who also regulates| the California Labor Board, MBC, and the Attorney General’s office, have adopted al policy of targeting American healthcare providers unlawfully and acquiring Jnternational| Medical Graduates (“IMG”) who are paid half the salaries of American doctors. 30. Assembly Bills 103 and 450, including the Senate Bill 54, violates the| American First Policy and 8 U.S.C. § 1324b. Plaintiffs are protected individuals pursuant to sub-division 3(a). The statute provides that prohibition of discrimination on national origin or citizenship status. The defendants RICO and unconstitutional enforcement} policies are designed to take innocent American Doctors out of the healthcare system and| replace them with cheap, non-American Doctors, in violation of 8 U.S.C. § 1324b(1). 31. The defendants or their agents have accessed plaintiffs’ personal mortgage account and interfered with federal assistance and they have clearly discriminated against ethnic doctors of color and against healthcare providers by not investigating their 10 PLAINTIFFS! OPPOSITION TO 12(8}6)(1] MOTIONawk OK ethnic doctors of color and against healthcare providers by not investigating their complaints, violation of civil rights, and conspiring to revoke their license with the intent to hire and acquire non-American healthcare workers. States are Not “immune under the Eleventh Amendment” for Discrimination. Title 42 U.S.C. 20004-7 provides: “(1) A State shall not be immune under the Eleventh Amendment of the Constitution of| the United States from suit in Federal court for a violation of section 504 of the Rehabilitation Act of 1973 [29 U.S.C. 794], title IX of the Education Amendments o 1972 [20 U.S.C. 1681 et seq}, the Age Discrimination Act of 1975 [42 U.S.C. 6101 et| seq.], title VI of the Civil Rights Act of 1964 [42 U.S.C. 2000d et sea.], or the provisions of any other Federal statute prohibiting discrimination by recipients of Federal financial assistance.” CONCLUSION For the foregoing reasons, the defendants motion should be denied and the court should grant plaintiffs the opportunity to amend, seek protective orders, and correct any defects deemed appropriate by this Court. The defendants have confessed to multiple charges, admitted knowledge to others, and failed to deny any; this proves beyond a reasonable doubt that all claims are valid and the record is substantiated by the fact. May 10, 2018 Respectfully Submitted, arley In Propria Persona Guven Uzun In Propria Persona i PLAINTIFFS’ OPPOSITION TO 12(B)(6-[1] MOTIONBilly Z. Earley P.A. 2144 Wembley Lane Corona, California 92881 Telephone: 714-615-4956 + |) Email: bze2101@aol.com 2 |/Guven Uzun M.D. 4712 Admiralty Way, Suite 930 3 || Marina Del Rey, California 96259 ‘Telephone; 310-867-5556 Email: medicalexpertl@gmail.com Attorneys for Plaintiffs In Propria Persona, pro se Litigants UNITED STATES DISTRICT COURT ae FOR THE EASTERN DISTRICT OF CALIFORNIA. 1 BILLY Z. EARLEY P.As GUVEN UZUN MD., ie CASE NO: 2:18-CV-0723-JAM ag Plaintiffs, DECLARATION OF BILLY Z. EARLEY IN SUPPORT OF PLAINTIFFS’ OPPOSITION TO DEFENDANTS? 12(B)(6)[1] vs. ) ) ) ) > > : of California, in his Official Capacity; and ) ) ) ) ) > ) ) ) 16 EMUND GERALD BROWN JR., Governor MOTION TO DISMISS XAVIER BECERRA, Attorney General of Date: June 19, 2018 ia || California, in his Official Capacity, and Time: 130 pm. ‘Il DOES 1-10, Courtroom 6: 14th Floor a Judge: Hon. John A. Mendez Trial Date: None Set 20 Defendants, Action Filed: April 2, 2018 ae DEMAND FOR JURY TRIAL 22 2 DECLARATION 24 IIT am a healthcare advocate and I have exclusive knowledge of how American healthcare 2s providers are wrongful targeted by defendants guided agencies. The influx of foreign doctors and 26 nurses into the state of California is soaring; American doctors and healthcare provider’s licenses 27 2g |} are being taken and revoked for trivial reasons, including because of their ethnic color. 2 DECLARATION OF BILLY Z. EARLEY OPPOSITION TO 12(B)(6)[1] MOTION10 a 2 ua 15 1s vv 25 26 7 28 I declare, 1. The California Department of Justice presently under the control of Brown and Becerra has implemented an unlawful unconstitutional policy of not investigating misconduct within their regulatory enforcement agencies, a fact clearly established, 2. Thousands of doctors and nurses complaints have fallen on death-ears because Brown and Becerra have encouraged enforcement misconduct within their agencies, referting to the “Bad Cops” and DOJ employees as their clients, an established fact. 3. Brown's office, the California DO's office, and Becerra’s office, were all informed in writing, of CVS having access to their agencies and they were showed proof, using CVS own documents and patient testimonies. They all looked the over way. 4, Becerra was appointed by Brown knowing that he was engaged in unlawful misconduct in Washington DC, what Congress members referred to as a National Security threat to the country. 10450 preclude Becerra from holding AG position in CA. 5. CVS is the number one employer of PA’s and NP’s, Brown helped CVS to. reach this milestone by giving them access to MBC, DEA, DOJ, and other enforcement agencies under his and Becerta’s control. This explains why CVS stated in court documents that they have a “Background” relationship with state and federal officials. 6. Brown and Becerra’s sanctuary state law makes it easy for their regulatory agency, the Labor Board and MBC, to hire and obtain more non-American healthcare ‘workers and target American healthcare workers by fines, ridicule, and by forfeitures. Tt appears that many employees in the DOJ have knowledge of these criminal acts against private citizen including DOJ attorneys. By covering-up crimes against the people of California, they have chilled the United States Constitution of America. I declare under penalty of perjury of the laws of the State of California that the foregoing statements are true and correct, Signed and swom to this 10th day of May, 2018, at Los Angeles, California Dated: May 10, 2018 S L a DECLARATION OF BILLY Z. EARLEY OPPOSITION TO 12(B)(6)[1] MOTION