September 5, 2019

Billy Earley
2144 Wembley Lane
Corona, California 92881
Telephone: 714-615-4956
Email: bze123.fccf@gmail.com

Complaint for Judicial Misconduct

Complaint filed against:
Judge Andre Birotte Jr.,
Central District Court

Statement of facts claiming Misconduct:

1. Andre Birotte engaged in massive corruption when he headed the United States Attorney’s
Office (“USAO”) Central District and he led a Team of USAO employees he supervised and
non-USAO employees to illegally spy, surveille, illegal representation, and they launched
frivolous investigations into wealthy people and political targets to get Government Job
promotions and to drive millions and millions of dollars to their family and friend’s Law Firms:

a. Andre Birotte’s Team included i). Dorothy C. Kim, Assistant USAO Chief (now an
Appellate Judge), ii). Beong Kim, USAO Chief Fraud Division, iii). Jeffrey Rutherford,
California DOJ/FBI Attorney (the husband of Dorothy C. Kim), and iv). Numerous DOJ,
FBI, and Medical Board of California corrupt individuals took played a part.

b. Andre Birotte’s Team was captured launching frivolous investigations into Dr. Michael
Drobot, Dr. Guven Uzun, and former Senator Ronald Calderon. The investigations were
fraudulently conspired because JEFFREY RUTHERFORD and Birotte’s Team were the
ATTORNEYS for these wealthy targets.

c. Birotte’s Team used the Government USAO’s office as a Criminal Cabal and they made
millions of dollars for providing fraudulent Attorney Representations by their friends
and families, including massive Abuse of Power and locking innocent people in jail.

2. Billy Earley is a healthcare advocate and he was briefed by Dr. Guven Uzun (a target of
Birotte’s team) of how he was befriended by Attorney Jeffrey Rutherford and then his wife
Dorothy C. Kim and her brother Beong Kim, launched a frivolous investigation into Dr. Uzun
for billing fraud:

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COMPLAINT FOR JUDICIAL MISCONDUCT AGAINST ANDREW BIROTTE JR.
 a. Dr. Uzun paid Attorney Jeffrey Rutherford approximately $1,000,000 over three years
to represent him. Jeffrey did not tell Dr. Uzun that his wife and his brother-in-law were
responsible for launching the investigation.

b. Dr. Uzun fired Attorney Jeffrey Rutherford after three years and hired Attorney
Thomas O’Brien, who accidently exposed an email showing that Jeffrey Rutherford was
the husband of Dorothy C. Kim and brother-in-law of Beong Kim. More disturbing,
Thomas O’Brien worked at the same USAO’s office and he was replaced by Andre
Birotte.

3. Billy Earley, a Physician Assistant clinic owner; filed a federal complaint against the DOJ,
Administrative Judge Chief, and the Medical Board of California (“MBC”)for corruption and
massive Constitutional violations of both State and Federal law. The DOJ said they knew the
Federal Judges and re-assigned the case to Andre Birotte:

a. Billy Earley led a group of protesters along with Dr. Uzun in front of the Department of
Justice Headquarters in Downtown Los Angeles several times, protesting Judicial
Corruption and seeking federal investigation into the DOJ and MBC.

b. The DOJ attorney spoke candidly with Billy Earley after he filed his original complaint
for redress. She said, “What judge is on this case?” Then she said, “You know we know
all the judges!” The DOJ removed the judge and placed Andre Birotte as the new
judge. Mr. Earley documented this finding in his complaint.

4. Billy Earley sought to remove the Magestrate Judge Steve Kim because several companies that
he managed received over $100 million dollars in grant awards from the DOJ. The Magestrate
Judge also allowed the owner of one of these companies to represent the NFL, a case
involving California disgraced Attorney Michael Avenatti. The Plaintiffs filing the Class Action
lawsuit had no knowledge of this relationship and it was not disclosed:

a. Andre Birotte tampered with evidence by changing the statute that was required to
successfully remove Magestrate judge and then Birotte refused to correct the error
after Billy Earley sought to have the recusal revised and corrected.

b. Billy Earley requested Magestrate’s Judge Steve Kim Oath of Office, Delegation of
Authority, and a copy of his Bribery Bonds, documented in a Court filed Affidavit.

c. Billy Earley also demanded that Andre Birotte conduct a thorough investigation into
how the Court was conducting its business. This demand was also documented in a
Court document addressed to Andre Birotte.

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COMPLAINT FOR JUDICIAL MISCONDUCT AGAINST ANDREW BIROTTE JR.
5. One week after Billy Earley requested the Magistrate bonds and oath, Mr. Earley went to the
Riverside Court and he noticed this statement written on the Clerks computer screen:
“PLAINTIFF REQUESTED JUDGES OATH OF OFFICE CASE CLOSED.”

6. Billy Earley was retaliated against and harassed by Andre Birotte and his Magistrate Steve Kim
office. Mr. Earley filed a complaint against Mr. Cooper and Jurisdiction was designated for the
Southern District Court. Mr. Earley was informed on the telephone by the Court Clerk that he
could file the complaint in the Riverside Court and they would send it to the Southern District
Court:

a. Billy Earley arrived at the Riverside District Courthouse and was informed that the case
would be filed for the Southern District.

b. The Clerk was acting strange while looking at the computer screen and then she got on
the phone and called somebody, Mr. Earley, believes she called Andre Birotte’s office.

c. The Clerk informed Mr. Earley to make a correction on one of the pages and Billy
noticed that the Clerk had filed the case to be heard by Judge Andre Birotte.

d. The Clerk tried to collect the $450 filing fee and Billy Earley said no! The Clerk said, “I
have spoken to the Court and you cannot see any other judge except Andrew Birotte.”

e. The Clerk threatened to call the police if Billy Earley did not pay the $450 filing fee,
since she had already assigned the case to Andre Birotte, without Mr. Earley’s
knowledge.

f. Billy Earley told the Clerk that she committed fraud and to call the police. Mr. Earley
filed his case with the Riverside Superior Court and Mr. Cooper later removed it to the
District Courthouse in Santa Ana. Mr. Earley was given the run-around with respect to
complaining about the retaliation and harassment by Andre Birotte’s office and his
Clerk.

7. Andre Birotte intentionally and unlawfully refuse to remove Defendant Kamala Harris from
the complaint that was properly filed with the Court to be removed shortly after Billy Earley
filed the original complaint in October of 2016:

a. Andre Birotte, his Staff, and the DOJ Attorneys, intentionally left Kamala Harris as a
Defendant to thwart due process and further review of the complaint. Kamala Harris
was not mentioned or described in the Complaint because she was not a Defendant.

b. Billy Earley submitted a motion to the Ninth Circuit to REMOVE Kamala Harris because
she was not a defendant. They refused to remove her and stated that I should talk to

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COMPLAINT FOR JUDICIAL MISCONDUCT AGAINST ANDREW BIROTTE JR.
 the District Court. The District Court Clerk said Mr. Earley should seek removal from
the Ninth Circuit – This was unlawful and it was done intentionally.

c. The Ninth Circuit assigned judges violated Appellate Protocol by not reviewing
evidence that was addressed in the District Court and they refused to address Mr.
Earley’s challenge of Jurisdiction.

d. Billy Earley was also informed that Andre Birotte would make sure that Mr. Earley’s
appeal fail because he would make sure the complaint was heard by one of his friends
in the Ninth Circuit. Andrew Birotte was admitted to practice for the Ninth Circuit in
1995 and Ninth Circuit Judge Wallace A. Tashima is one of the Judges that Birotte used
to allegedly unlawful dispose of Mr. Earley’s Appeal that showed 100% corruption was
done by the DOJ, FBI, MBC, OAH, and other corrupt Government actors. A fact that is
well-known to the Public today.

8. Billy Earley called the Ninth Circuit Clerk to get information on how to file a complaint. The
Circuit Clerk had Mr. Earley file a complaint directly with the Chief Judge Thomas, sent
certified mail on May 15, 2019. The complaint was not answered and no response was sent to
Mr. Earley.

9. Billy Earley, submitted a certified complaint to the Senate Judiciary Committee and then to
the House Judiciary Committee requesting impeachment and investigation into Andre Birotte
and all the other co-conspirators identified.

10. Billy Earley, on behalf of Dr. Uzun, filed a complaint with the FBI for Wire Fraud and Public
Corruption against Andre Birotte. Dr. Uzun email was hacked and AETNA insurance main law
firm, which was headed by JEFFREY RUTHERFORD Submitted Fraudulent Documents Under
Seal to Judge Birotte and the emails between them and Dr. Uzun suggest fraud and collusion
committed by Birotte and others. These emails also identify disgraced FBI employee Peter
Norrell who was convicted and charged with threatening fraudulent investigations on people.

Relevant Evidence & Proof Unlawful Misconduct:

A. EXIBIT #1 - July 2, 2019. United States House of Representative The Judiciary Committee.

 See link November 3, 2014, Inter-Agency DOJ email. Proof that Birotte, Dorothy,
Jeffrey, Beong, Dougdale, Bowers, and other USAO employee tried to cover-up crimes.

 See link February 29, 2016. Dr. Uzun’s $10 million dollar lawsuit against Jeffrey
Rutherford and Birotte’s Team. Much of the corruption was concealed by legal jargon.

 See link May 23, 2018, FBI complaint was filed revealing Andrew Birotte, Jeffrey
Rutherford, his wife Judge Dorothy Kim, and many other individuals.

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COMPLAINT FOR JUDICIAL MISCONDUCT AGAINST ANDREW BIROTTE JR.
B. EXIBIT #2 – January 28, 2019. Affidavit filed with Andre Birotte requesting an investigation
into his Court room:

 Page 2 – Birotte and Magestrate Judge allows DOJ and OAH Chief Judge to commit
fraud on the court by virtue of Perjury and False Statements.

 Page 4 – DOJ attorney Rosemary Luzon claimed to know the judges and Mr. Earley
filed objection to unlawful “Lottery” assignment of judge Birotte.

 Page 5 – Evidence that shows Birotte’s Magestrate Judge Steve Kim received millions
from DOJ Contracts when he managed several large Cyber-security companies.

 Page 6 – Mr. Earley clearly identified an illegal lottery in the case of Greg Herric v.
National Football League (2:16-cv-06324). Magestrate’s ex-boss subs into the case for
the NFL without notice to the Class Action Plaintiffs and Birotte does nothing to
intervene since it involves “BIG” bucks. Michael Avenatti’s office refused to comment.

 Page 10 – Mr. Earley informs Andre Birotte that the Judicial System was corrupted and
he request an Investigation into the corruption identified.

C. EXHIBIT #3 – Jeffrey Rutherford and USAO Tyree Bowers filing showing NOT ONLY Dorothy
Kim’s husband represented Dr. Michael Drobot, but also a USAO employee Tyree Bowers. This
is absolute corruption and massive Abuse of Power by corrupt Government employees. Tyree
is mentioned in the DOJ Inter-Agency email chain in Exhibit #1.

D. EXHIBIT #4 – Law firm showing USAO chief officer Robert E. Dugdale who was identified in the
DOJ inter-agency email accidently sent to Dr. Uzun, he joins Jeffrey Rutherford and Jeffrey’s
partner Janet I. Levine, who also got paid for unlawful attorney services rendered to Dr.
Michael Drobot. Dugdale is mentioned in the DOJ Inter-Agency email chain.

E. EXHIBIT #5 – Federal Bar Association, Janet I. Levine was former President 2006. Members
included Andre Birotte, Jeffrey Rutherford, former President in 2011. Levine and Jeffrey Law
Firm represented Dr. Uzun and Dr. Drobot while Birotte, Dorothy, and her brother Beong
press the unsuspecting doctors for jail time and big bucks to their family and friends law firms.

F. EXHIBIT #6 – A CVS ring-leader picture given to the FBI, a rally in front of the DOJ
headquarters, and this video link where Mr. Earley harassed by Birotte’s Clerk:
https://youtu.be/DLieK_jx0Bs

G. EXHIBIT #7 – A very large list of Law Clerks that served with Andre Birotte and hired by Jeffrey
Rutherford and Janet I. Levine. Megan Maitia, Andrew Holmer, Sigourney Haylock, Dylan
Burstein, and the list goes on.
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COMPLAINT FOR JUDICIAL MISCONDUCT AGAINST ANDREW BIROTTE JR.
 H. EXHIBIT #8 – May 15, 2019. Certified letter requesting Chief Judge Thomas of the Ninth Circuit
to conduct an internal investigation for Unlawful Abuse of Power Government Enforcement
Agencies. The Ninth Circuit Clerk informed Mr. Earley that the complaint had to be filed in this
manner. There was no response and no reply given to Mr. Earley.

Conclusion

Billy Earley was the targeted by corrupt DOJ and Judicial Officers because he identified corruption and
protested in front of the DOJ headquarters multiple times with concerned people living in California.
Mr. Earley’s clinic was the target of discrimination and racism perpetrated by the DOJ and MBC police
officials who tampered with evidence and lied to the Courts. The United States must prevent this type
of corruption from targeting innocent business owners and people living in the U.S. Andre Birotte has
violated every rule in the book and he has targeted hundreds and perhaps thousands of Americans
with fraudulent investigations designed to enrich his friends and Team players. The fact that these
Government Agencies are launching investigations and providing for-hire Attorney Representation for
the “Targets” is very disturbing and criminal. The United States Court’s System must allow a Pathway
were innocent Americans can file for legal redress when both State and Federal Judicial Systems are
compromised. Mr. Earley was a Congressional Briefing Panelist in 2018 on DOJ corruption, a fact that
has been proven by present DOJ and FBI investigations today. Judge Birotte is engaged in the worsts
type of Abuse of Power by using his office to direct criminal and unlawful activities that cannot and
must not be tolerated on any state or federal level. Please remove and investigate this judge ASAP to
protect American safety and Constitutional protections that Americans are guaranteed.

Respectfully,

I declare under penalty of perjury under the laws of the United States of America that I am a citizen of
the State of California and if called to testify, I would give competent testimony regarding the
information and data provided herein on this Day of September 05, 2019. I declare that the foregoing
is true and correct.

Executed on: September 5, 2019

Signed by: Billy Earley, in Corona California

______________________________
Billy Earley

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COMPLAINT FOR JUDICIAL MISCONDUCT AGAINST ANDREW BIROTTE JR.