IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

SECOND APPELLATE DISTRICT, [Division No. P]

Lalonne EX/BENE, et al
Plaintiffs and Appellants
v. Court of Appeal No. B312976

NEW REZ LLC et al Superior Court No. BC707310

Defendants and Respondents

Document received by the CA 2nd District Court of Appeal.

Judge Robert B. Broadbelt

MOTION TO RECONSIDER

NOTICE OF LIABILITY Accounting/Breach Of Trust

Lalonne, Juliet Executor/Beneficiary

JULIET LALONNE ESTATE
16750 SE Tong Road
Damascus, Oregon
Non Domestic
(323)252-8487
julietlalonneestate@gmail.com

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 Table of Contents

Page

I Memorandum of Law 3
II Introduction/Background 5
III Argument 7
IV Summary 15
V Relief 19
VI Affirmation 19
VII Proof of Service by Mail and Electronic Service 20
VIII EXHIBITS IN SUPPORT:
a) Motion To Strike Motion To Recuse by: Robert B
Broadbelt
b) Directory Evidencing Robert B. Broadbelt in the

Document received by the CA 2nd District Court of Appeal.

Torrance Courthouse Next Door to Laura Ellison
c) Receipt of Timely efiling Designation of Record at LASC
d) Notice of Liability

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I. Memorandum of Law/Court Of Appeals/Void Judgments

1. When rule providing for relief from void judgments is applicable, relief is
not discretionary matter, but is mandatory, Orner. V. Shalala, 30 F.3d
1307 (Cob.1994).
2. Judgment is a void judgment if court that rendered judgment lacked
jurisdiction of the subject matter, or of the parties, or acted in a manner
inconsistent with due process, Fed. Rules Civ. Proc., Rule 60(b)(4), 28
U.S.C.A., U.S.C.A. Const. Amend. 5 Kiugh v. U.S., 620 F.Supp. 892
(D.S.C. 1985).
3. Title 28 United States Code § 455, Disqualifications of justice, judge or
magistrate. (a) Any justice, judge or magistrate judge of the United States

Document received by the CA 2nd District Court of Appeal.

shall disqualify himself in any proceeding in which his impartiality might
reasonably be questioned. (b) He shall also disqualify himself in the
following circumstances: (1) Where he has a personal bias or prejudice
concerning a party, or personal knowledge of disputed evidentiary facts
concerning the proceeding;
4. The test for reasonable apprehension of bias requires the reviewing judge to
consider whether a reasonable person, with knowledge of all the
relevant circumstances, including "the traditions of integrity and
impartiality that ... judges swear to uphold" would apprehend that there was
bias. http://criminalnotebook.ca › Reason...Reasonable Apprehension of
Bias - Criminal Law Notebook
5. The Court Has A Responsibility To Correct a Void Judgment: The statute
of limitations does not apply to a suit in equity to vacate a void
judgment. (Cadenasso v. Bank of Italy, p. 569; Estate of Pusey, 180 Cal.
368, 374 [181 P. 648].)

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6. The law is well-settled that a void order or judgement is void even before
reversal", VALLEY v. NORTHERN FIRE & MARINE INS. CO., 254 U.S.
348,41 S. Ct. 116 (1920)
7. "Courts are constituted by authority and they cannot go beyond that power
delegated to them. If they act beyond that authority, and certainly in
contravention of it, their judgements and orders are regarded as nullities;
they are not voidable, but simply void, and this even prior to reversal."
WILLIAMSON v. BERRY, 8 HOW. 945, 540 12 L. Ed. 1170, 1189 (1850).
8. It is not necessary to take any steps to have a void judgment reversed,
vacated, or set aside, it may be impeached in any action direct or,
collateral. Holder v. Scott, 396 S.W.2d 906, (Tex.Civ.App., Texarkana,
1965, writ ref., n.r.e.).

Document received by the CA 2nd District Court of Appeal.

9. A court cannot confer jurisdiction where none existed and cannot make a
void proceeding valid. It is clear and well established law that a void
order can be challenged in any court, OLD WAYNE MUT. L. ASSOC. v.
McDONOUGH, 204 U. S. 8,27 S. Ct. 236 (1907).
10. When appeal is taken from a void judgment, the appellate court must
declare the judgment void, because the appellate court may not address
the merits, it must set aside the trial court's judgment and dismiss the
appeal. A void judgment may be attacked at any time by a person whose
rights are affected. See El-Kareh v. Texas Alcoholic Beverage Comm'n,
874 S.W.2d 192, 194 (Tex. App.—Houston [14th Dist.] 1994, no writ); see
also Evans v. C. Woods, Inc., No. 12-99-00153-CV, 1999 WL 787399, at *1
(Tex. App.—Tyler Aug. 30, 1999, no pet. h.).
11. A Party Affected by VOID Judicial Action Need Not APPEAL. State ex rel.
Latty, 907 S.W.2d at 486.

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 12. It is entitled to no respect whatsoever because it does not affect, impair, or
create legal rights." Ex parte Spaulding, 687 S.W.2d at 745 (Teague,
J.,concurring). If an appeal is taken, however, the appellate court may
declare void any orders the trial court signed after it lost plenary power
over the case, because a void judgment is a nullity from the beginning and
is attended by none of the consequences of a valid judgment.
13. Since the trial court's dismissal "with prejudice" was void, it may be
attacked either by direct appeal or collateral attack Ex parte Williams,
No. 73,845 (Tex.Cnm.App. 04/11/2001).
14. Federal court has jurisdiction on void judgment and issues. 28 U.S.C. § 1254
(1). There is diversity of citizenship between the parties and the amount in
controversy exceeds the sum of $75,000. The district court had jurisdiction

Document received by the CA 2nd District Court of Appeal.

under 28 U.S.C. § 1332(a).

II. Introduction andBackground

1. The Quiet Title at issue (BC707310) is void on its face for numerous
reasons, most notably for the replacement of a randomly selected sitting
judge with a biased judge with conflicts of interest prior to our first hearing.
2. The biased judge further went on to evidence his bias by spoliating the
proofs of service done by Vanessa Martinez the manager at NATIONWIDE
LEGAL.
3. A preponderance of evidence exists to prove the biased judge tampered with
witness Vanessa Martinez from NATIONWIDE LEGAL who performed
personal service of summons and complaint on defendants/respondents.

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4. We Appellants/Plaintiff requested the witness be subpoenaed to testify as to
the personal service of summons and complaint on defendants/respondents
but our requests fell on deaf ears.
5. conspiring to take the property at issue in the case during the first hearing on
the matter,
6. The trial court condoned defendants/respondents willful failure to answer or
appear, while scheduling to take the property at issue during the first hearing
t defendants/respondents were personally summoned to appear and answer
which defendants/respondents did neither.
7. The trial court denied us the plaintiffs/appellants the relief of default
judgement we had won fair and square against defendants/respondents in the
action.

Document received by the CA 2nd District Court of Appeal.

8. We the plaintiffs/appellants were then physically assaulted by plainclothes
officers outside courtroom as we left the first hearing and we the
plaintiffs/appellants were kidnapped and falsely imprisoned without just
cause, while the property/land at issue was being trespassed and illegally
seized by the defendants/respondents.
9. Defendants/respondents had just proven themselves incapable of proving
their interest in the property without a valid interest in the land/property at
issue.
10. Defendants/respondents and public officers committed fraud on the court,
and modern-day slavery, conspiring against two innocent people for reasons
of discrimination and racism.
11. The plaintiffs/appellants, myself Lalonne, Juliet EX/BENE and Benavidez,
Gabriel EX/BENE two innocent people, in propria persona sui juris, who
rightfully won the case at issue (BC707310) were falsely imprisoned,
without just cause, and without bail while our property/land was being
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 stolen, by defendants/respondents while encouraged and incentivized for this
behavior by the trial court.
12. Further delay in obtaining relief is another tortuous irreparable harm because
it gives us no option but to file in another court a collateral attack.
13. We should not be required to have more procedural hurdles placed in our
way gatekeeping relief long overdue as we will prove with facts and
evidence in this motion, that are uncontested.
14. We have experienced obstruction of justice, as well as, trouble with our
electronic devices, access to the internet, financial accounts, ability to
contract for access to living expenses, and access to credit, that have not
been in our benefit.
15. Irreparable harms caused as result of this case have significantly lowered our

Document received by the CA 2nd District Court of Appeal.

standard of living broadly and generally causing us substantial irreparable
harm.
16. We do not deserve to be punished for exercising our rights civilly while
observing the written law while the defendants/respondents act consistently
above the law, maliciously creating an environment of lawlessness.

III. Argument

17. It is an inequitable miscarriage of justice to deny us relief from a case that is

wrought with fraud on the court by a judge (Robert B. Broadbelt) who
concealed his bias concerning a close colleague (Laura Ellison) in his
motion to strike our motion to recuse himself.

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18. Robert B. Broadbelt did acknowledge a relationship with a former partner
Marc Drier, that we felt was a conflict of interest, in his motion to strike,
with a plain denial without any facts or evidence to back up his denial of our
conflict of interest claims.
19. Marc Drier is an attorney who was convicted of securities fraud by the
Securities And Exchange Commission for a scheme carried out during his
partnership with Robert B. Broadbelt, prior to Robert B. Broadbelts
appointment as a judge by former governor Jerry Brown.
20. Although, Robert B. Broadbelt acknowledged his relationship to Marc Drier.
That was questioned in our motion to recuse, Robert B. Broadbelt failed to
acknowledge the other relationship questioned in the motion to recuse prior
to striking it, as exhibited in his motion to strike (exhibit) that of his

Document received by the CA 2nd District Court of Appeal.

relationship to Laura Ellison.
21. In Robert B. Broadbelts motion to strike our motion to recuse himself he
failed to acknowledge his questioned relationship to Laura Ellison, the
“judge” who granted a writ to seize our property in the Unlawful Detainer
(18STUD03390) despite our contested ownership claim pending in the Quiet
Title case (BC707310) at issue, that was requested for consolidation to
decide ownership prior to possession.
22. Laura Ellison is the judge whose ruling was under suspicion for depriving us
of a fair trial of ownership of our land as requested, prior to ruling on
possession, by denying consolidation with the Unlawful Detainer case she
sat on with the Quiet Title at issue.
23. The Quiet Title at issue (BC707310) already had a sitting judge (Howard
Halm).
24. Howard Halm was replaced prior to the first hearing by Robert B. Broadbelt,
without just cause.
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25. It was discovered later that Robert B Broadbelt had been neighbors with
Laura Ellison at the small Torrance Courthouse where our South Pasadena
property's unlawful detainer was litigated against our will with Laura
Ellison.
26. Robert B. Broadbelt had just moved to the Los Angeles Superior Courthouse
where a large pool of potential judges without biases or conflicts of interests
exists to choose from.
27. It is reasonable therefore to presume it is not mere coincidence that Robert
B. Broadbelt just happened to replace Howard Halm after the Los Angeles
Superior courthouse judges refused to renew a writ returned by the sheriffs
department for errors, originally granted by Laura Ellison.
28. It is not random this occurred after she was petitioned as the last resort after

Document received by the CA 2nd District Court of Appeal.

numerous denials at LASC, to renew the writ when the attorney Wayne Abb,
who failed miserably came all the way back to Torrance desperate for a
renewed writ of execution from her while Wayne Abb had brought a known
deficient case ab initio
29. Then we see Robert B. Broadbelt replace the sitting judge Howard Halm in
the case.
30. The lack of access to the filing system at THE STANLEY MOSK
COURTHOUSE, reveals a pattern of covert gatekeeping of access to justice
at THE STANLEY MOSK COUTHOUSE
31. In this situation, I cannot physically reach the court and I have no currency
of exchange while surviving serious emergency situations.
32. GATEKEEPING is the means to perpetuate ongoing OBSTRUCTION OF
JUSTICE to prevent detection and an appeal or collateral attack
33. My problems with meeting my living expenses (work as a skilled advanced
practice nurse), housing, and transportation; are direct result of this case.
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34. I have been in communication several times with the Stanley Mosk
Appellate Division were not helpful at all while attempting to efile a
proposed record I had already prepared and served on all parties and the
court of appeals last summer.
35. Evidence of timely efiling of the Designation of the Record at THE
STANLEY MOSK COURTHOUSE using an approved 3rd party provider
(borrowing money to do the efiling prior to leaving for Oregon) on
November 30, 2021 (Exhibit ).
36. The justices in the court of appeals are supposed to be tasked with the non-
discretionary duty to relieve parties adversely affected by void judgments at
any time, without a bill in equity in the federal court.
37. Collateral attack of void judgments is not strictly governed by ordinary

Document received by the CA 2nd District Court of Appeal.

appellate procedure and statutes of limitations, but a void judgment can
be corrected at any court at any time and sua sponte using this court's
equitable authority to prevent miscarriages of justice that could result from a
denial of rights, from lower courts who acted outside of their jurisdiction by
denying a party of due process.
38. Good cause is evident requiring the rulings in case BC707310 to be rendered
VOID, sua sponte at this time, as a non-discretionary duty.
39. Equity is above statute and its power is INTENDED to stop unintended
outcomes that create miscarriages of justice when conforming to statutes and
their inflexibility in matters.
40. Sufficient facts and evidence prove the judge concealed his bias in the
motion to strike he filed in response to our request to recuse himself,
rendering all of his actions void as there is no due process with a biased
judge, just a simulation of the legal process.

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41. I am still haunted by an active warrant to silence and destroy me and my life,
career, and happiness.
42. I am irreparably harmed and I feel in present danger, as a result of my good
faith attempt to expose our broken system of justice.
43. Robert B. Broadbelt failed to disclose his relationship (concealment/ fraud)
to the UD judge (Laura Ellison) in the related UD case (18STUD03390), his
neighbor when Robert B. Broadbelt was a judge at the 4 judge TORRANCE
COURTHOUSE, this neighbor (Laura Ellison) denied consolidation of the
UD with contested ownership with the higher jurisdiction Quiet Title at issue
(BC707310) on appeal.
44. Defendants/respondents did not appear to want or need to prove ownership
while it was contested, which in itself is a contradiction to the UD statutory

Document received by the CA 2nd District Court of Appeal.

remedy that presumes ownership as uncontested.
45. We won the case fair and square. We gave them notice and they bribed a
judge to spoliate the proofs of service that were professionally done, and this
is uncontested.
46. A preponderance of evidence exists now indicating that respondents likely,
bribed Ellison who used her colleague Broadbelt, now at LASC to replace
our sitting judge Halm, right before the first hearing.
47. It is likely to any reasonable person that judge Robert B. Broadbelt was
enlisted by a bribed judge (Ellison) to replace our properly randomly
assigned judge (Halm) at LASC to conceal the illegal taking of our house
and land without due process.
48. A court directory (EXHIBIT ) clearly evidences Robert B. Broadbelts
former tenure at the small TORRANCE COURTHOUSE where judge
Laura Ellison had been his next-door neighbor.

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49. Its with a reasonable suspicion we allege Robert B. Broadbelts replacement
was no coincidence, as LASC had already randomly assigned a judge
(Howard Halm), and Robert B. Broadbelts replacement in light of his
violations of due process he perpetuated while sitting on the case at issue, as
well as Robert B. Broadbelts prior conflicts of interest regarding
involvement in law practices involving a partner engaged in mortgage and
securities fraud gives us strong evidence indicating that he failed in his duty
to disclose his potential bias to parties, especially when plaintiffs/appellants
had motioned him to recuse himself.
50. Robert B. Broadbelts motion to strike entered on our motion to recuse
himself {EXHIBIT }.
51. Judges are supposed to disclose all potential biases that could lead a

Document received by the CA 2nd District Court of Appeal.

reasonable person to believe they acted out of impropriety.
52. When Broadbelt motioned to strike our request to recuse, one could say such
a duty to disclose would attach. Broadbelt instead conceals his relationship
with Ellison, after discovered by a plaintiff that alleges his spoliation of
evidence of professionally done proofs of service, likely witness tampering,
and fraud on the court.
53. The facts and evidence prove the defendants knew, the date and time of the
trial by the scheduling of the seizure of the house with the sheriff’s
department on the date and time of the first hearing.
54. Giving defendants/respondents possession to our land and property at issue
prior to ownership rights being proven, at the exact time of the first hearing,
instead of properly compelling defendants/respondents to appear to the first
hearing at the time summoned to prove their right and title superior to our
own claimed vested fee simple title.

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55. Defendants/respondents are proven to be no more than third-party
interlopers, acting as trustees and servicers to a undisclosed beneficiary
claiming a future interest by way of testamentary gift granted at the closing
of the mortgage loan process.
56. Broadbelt brought up the tender rule regarding our recission for fraud in
factum, we informed him we would love to tender the negative debt
“loaned” to us after funding the loan with book-entry, securities, or newly
created debt “money”, to which no party was proven to have lost from a
bank account evidencing it's prior having been earned, held and loaned out,
substantiating a right to claim to be an injured party.
57. The audit shows an irreparably broken chain of title even prior to the
bankruptcy of Amtrust Bank the alleged “lender”.

Document received by the CA 2nd District Court of Appeal.

58. MERS is a mere alibi, a patented computer-based system that appears to
grant lenders the ability to claim authority as an official of MERS to transfer
an alleged obligation into an accommodating parties alleged portfolio of
debt, but their consideration of “good and valuable consideration” without
naming any actual consideration in their internal assignments proves no
tangible investment of currency of exchange to claim to be an injured party.
59. I allege defendants/respondents claim a defective future expected interest in
the distribution of trust assets by acting as an heir or beneficiary with
entitlement and not a contractual duty of care.
60. The defendants/respondents already forfeited their opportunity to object
nevertheless and this stands as the proven fact on this record.
61. A testament has no contractual duties; disclosure, mutual consideration, nor
a meeting of the minds.
62. An heir expects a disbursement of an inheritance.

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63. We also allege they had involvement in hastening hardship to us to cause an
alleged default as the loan/refinance is calculated to fail.
64. Defendants/respondents slandered our title by proceeding to record liens and
notices in the public record without answering a proof of claim to justify
standing to do so, only evidencing criminal conversion of a counterfeit copy
of a promissory note.
65. Defendants/respondents had no interest in our satisfaction of a “loan”, but
only had an incentive to irreparably harm us and it is believed they bribed
judge Laura Ellison to grant the unlawful detainer to their third-party insider
posing as a legitimate buyer to keep the nature of this extortion scheme
concealed and to get rid of evidence.
66. Defendants/respondents are hiding in the beneficiary role in a trust

Document received by the CA 2nd District Court of Appeal.

arrangement, where we are the grantors.
67. This is undue influence corrupting our access to the means to survive
promised to us in this fiat money system which creates money (debt) each
time a “loan” is given.
68. This misunderstanding in the testament is opposite to the intent of the
grantor, who because of words of art was led to believe he is getting a loan
he must repay, principal and interest, to satisfy the party who provides the
money to him who loses something of value if not repaid.
69. Not that the lender is just an accommodating party for access the creation of
debt to which sweat equity, hard earned money of exchange is an expected
benefit paid to “lenders” whose only claim is as an “heir” and who intends
for the “borrower” to “default” as the “lender” as “beneficiary” without any
real provable investment into this scheme greedily and maliciously intends
to take land “real estate” with incentive not to be satisfied which would
thereby merge titles to allodial or fee simple, or to “ give back” the “legal
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 title”/beneficiary position back to the grantor/ trustee merging legal and
equitable title upon satisfaction.
70. Just access the most basic level means of survival constituting a shelter and a
roof over your head, money/credit/debt/securities is created by way of fiat
currency.
71. And we, the people are extorted of our time and labor by greedy malicious
parties whose intent is corrupted and cruel and unusual punishment.
72. In this case the testament is revocable evidenced by the trustee role of the
grantor being retained which makes this trust revokable.
73. Plaintiffs/appellants demanded a rescission for undue influence and fraud in
factum expressing this for the record and a “demand for lawful money per
title 12 USC section 411+ 412, NO USUFRUCT, NUN PRO TUNCT”.

Document received by the CA 2nd District Court of Appeal.

74. An adverse possession affidavit meeting the 5 prerequisites exists in the LA
Assessors office, filed in August of 2018.
75. Evidencing our undisputed vested fee simple title undefeated by the
defendants/respondents who committed a trespass when they stole our land,
property, and imprisoned us.
76. Should defendants/respondents be rewarded and incentivized for their
behavior?

IV.SUMMARY

77. Benavidez, Gabriel EX/BENE paid hard earned money of exchange for 20
years of sweat equity.
78. Defendants/respondents have proven no rightful interest whatsoever.

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79. Further, defendants/respondents claim no contractual duty of care consisting
in mutual consideration, meeting of the minds, full disclosure, or even the
implied covenant of good faith and fair dealing.
80. Instead, defendants/respondents treated Benavidez, Gabriel EX/BENE as if
they were his heirs having a future expectant interest in his “real estate” with
reliance Benavidez, Gabriel EX/BENE’s disbursements they claim he owes
them for accommodating their fiat currency to obtain a piece of land that he
could “own”?
81. Such unconscionable contracts, in my opinion can be called only concealed
modern-day involuntary slavery.
82. Defendants/respondents without a single legitimate claim and producing
only an incomplete xerox of loan documents, anyone can go and copy from

Document received by the CA 2nd District Court of Appeal.

the county clerks office stole Benavidez, Gabriel EX/BENE’s family home
of 20 years when he became disabled prior to Benavidez, Gabriel
EX/BENE’s hard earned retirement, not to mention other horrendous
tortuous interferences that have yet to be discovered.
83. Deputies plan execution of writs of attachment in advance, is it perhaps
reasonable to presume defendants/respondents, who were present at the writ
executed at the exact date and time of the first hearing, were noticed in time
to petition the court, answer, and/or appear in court as summoned?
84. The time of the first hearing was used to effect the writ of attachment by
defendants/respondents intentionally because they knew we the
plaintiffs/appellants would not be on the land and property at the time, but
instead we would be in court attempting to follow the rule of law in good
faith.
85. Defendants/Respondents failure to answer the complaint or appear as
summoned was willful and by choice.
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86. Meanwhile the co-plaintiff and myself were imprisoned during the seizure
without warrants, charges, or just cause, except obstruction of justice.
87. My right arm was broken while falsely imprisoned, to retaliate against me
for exercise of my reserved constitutional rights.
88. My advanced practice nursing career was destroyed with a felony charge,
that has no complaint or evidence on file I can see, not a single document
presented to me for my records that clearly states what I did wrong. Just an
interference intended to retaliate and prevent my redress in this case.
89. While defendants/respondents enjoy only protection incapable of doing
wrong in the eyes of the court, and never being punished or corrected.
90. Why am I denied reasonable accommodation in my difficult situation
perpetuated by hardships intentionally inflicted by the

Document received by the CA 2nd District Court of Appeal.

defendants/respondents?
91. I had a prepared record and brief already served on all parties, but due to my
ignorance as am not schooled in law (Hanes vs. Kerner) I filed this evidence
with court of appeals first before the trial court, (photos of the oversized
envelopes to all parties with postage exhibited on them proves this), sent out
PRIOR to being guided to file the document with the trial court, which I did
and they denied during the holidays while I was stranded in the sierra
mountain range in a snowstorm travelling to safety at my family home in
Oregon.
92. The fact that efiling was done timely and they refused it knowing of my
hardship I disclosed to them lends credence to the trial court being
unaccommodating and obstructing justice (not to mention other chargeable
crimes committed against us in their ongoing fraud on the court)

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93. The pattern of gatekeeping is reasonable with the facts and evidence
presented, showing parties having to present their case without an attorney at
law’s assistance are prevented from access to justice.
94. I am in law, not “at law” I am intended to access the law system to correct
this broken system and I demand access.
95. Gatekeeping the access to the rights, protection, and remedies available, by
procedural hurdles, that are foreseeable vulnerabilities that are unnecessarily
hardest on those in most need of remedies or filing assistance after a loss.
96. This is a priority matter, involving an ongoing serious miscarriage of justice,
fraud on the court, spoilation of evidence by a biased judge, tampering with
a witness whose testimony should have replaced the alleged “lost” evidence
that had been spoliated by the replacement judge, suspected bribery,

Document received by the CA 2nd District Court of Appeal.

malicious prosecution, emotional distress, trespass, etc..
97. I control a 30% interest in the compensation of this case which includes the
land and houses that are the substance of the “real estate” at issue, and I am a
party affected by this VOID judgment.
98. Forgive me for my procedural irregularities, I cannot possibly do this all
correctly while under extreme stress. I am not schooled in the legal
profession nor was I created with innate knowledge of the rules of
procedure.
99. I appreciate reasonable procedural guidance to make my communication
with the court effective when I need something done to carry out my living
will as executor and beneficiary of the estate.

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 Relief Requested

When appeal is taken from a void judgment, the appellate court must
declare the judgment void, because the appellate court may not address
the merits, it must set aside the trial court's judgment and dismiss the
appeal. A void judgment may be attacked at any time by a person whose
rights are affected. See El-Kareh v. Texas Alcoholic Beverage Comm'n,
874 S.W.2d 192, 194 (Tex. App.—Houston [14th Dist.] 1994, no writ); see
also Evans v. C. Woods, Inc., No. 12-99-00153-CV, 1999 WL 787399, at *1
(Tex. App.—Tyler Aug. 30, 1999, no pet. h.).

Document received by the CA 2nd District Court of Appeal.

Affirmation

I affirm,

I am, the claimed and intended executrix/beneficiary of the ens legis estate of
JULIET LALONNE ESTATE. I have an interest in the lands and property at
issue in this case. THE STATE OF CALIFORNIA as fiduciaries and former
administrators of the property at issue is sought to perform according to trust and
to account for the breaches present in this case.

I am subject to the will (Bible) of our God in heaven and in trust I consent to the
authority of the supreme law of our Republic Nations united in trust stated in
“Declaration of Independence (1776)” and the “Bill of Rights (1791)”

It is my intention to correct errors and irregularities present in the estate I control

and to claim my standing as a competent wo-man capable of handling my legal

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affairs, securities, and business without unwanted interference from
trustees/fiduciaries acting in my living will, rights, and intent.

I am sound in mind, body, and spirit.

I affirm my truth to be contained in this writing by my hand, with God as my

witness.

Without prejudice.

Lalonne, Juliet Executrix/Beneficiary

Document received by the CA 2nd District Court of Appeal.

JULIET LALONNE ESTATE

Proof of service

I am 18 years of age or older and unrelated to this case

I placed the document “motion for reconsideration” with attached exhibits in the mail to the
respondents listed below, for pickup at the post office with postage paid.
I affirm this fact to be true and correct with God as my witness. Without prejudice.

Name: Bijan Masoumpanah Address: 16750 SE TONG RD

DAMASCUS, OR 97089

Date: 02/25/2022 Signature:

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1. FEDERAL HOME LOAN MORTGAGE CORPORATION AKA (FREDDIE MAC) -
Defendant/ Respondent 8200 Jones Branch Drive, Mclean, VA 22102·3110

2. MORTGAGE ELECTRONIC REGISTRATION SYSTEM AKA (MERS) ·

Defendant/ Respondent 1818 Library St Suite 300, Reston, VA 20190

3. NEW PENN FINANCIAL LLC DBA SHELLPOINT MORTAGE SERVICING ·

Defendant/ Respondent P.O. Box 10826, Greenville, SC 29603·0826

4. AMTRUST BANK (FDIC as receiver) -Defendant/ Respondent 1601 Bryan Street,

Dallas, TX 75201-3430

5. JPMORGAN CHASE BANK -Defendant/ Respondent 7610 Washington ST. FLl,

Indianapolis, IN 46231

6. FHLMCVPC189777 (MULTICLASS CERTIFICATES/SERIM 3487 TRUST) . 8100

Document received by the CA 2nd District Court of Appeal.

Jones Branch Drive MS B13, Mclean, VA 22102-3110

7. CLEAR RECON CORP Defendant/ Respondent/self-proclaimed Trustee 818 West

Seventh Street Suite #930, Los Angeles, CA 90017

8. NELA DEVELOPMENT LLC, I -Defendant/ Respondent (principle of 9·10, and

service done on NELADEVELOPMENT LLC, I, in care of SEPULVEDA ARMANDO
and SOLIS MARISSA as self-proclaimed agents ) Notice to principle is notice to agent.
2222 Foothill Blvd#e 214, La Canada, CA 91011 9. SEPULVEDA ARMANDO -
Defendant/ Respondent 2222 Foothill Blvd #e 214, La Canada, CA 91011

10. SOLIS MARISSA -Defendant/ Respondent 2222 Foothill Blvd #e 214, La Canada,
CA 91011

11. ABB WAYNE-Defendant/ Respondent 21601 ~St, STE 208, Canoga Park, CA 91303

12. BRANDON DIMOND-Defendant/ Respondent 27489 Agoura Rd STE 102, Agoura

Hills CA 91301-2481

13. e-sevice truefiling

Page 21 of 22
 Yu, Jordan None Verified Yu / Mohandesi LLP jyu@yumollp.com

14. e-service truefiling

Brown, Attorney (CA) Yu Mohandesi

Verified sbrown@yumollp.com
Sharon (176706) LLP

15. e-service truefiling

Ekmekchyan, Attorney (CA) Yu/Mohandesi

Verified pavel@yumollp.com
Pavel (223222) LLP

Document received by the CA 2nd District Court of Appeal.

.

Page 22 of 22
8|Page
Document received by the CA 2nd District Court of Appeal.
9|Page
Document received by the CA 2nd District Court of Appeal.
10 | P a g e
Document received by the CA 2nd District Court of Appeal.
11 | P a g e
Document received by the CA 2nd District Court of Appeal.
6|Page
Document received by the CA 2nd District Court of Appeal.
SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES
Branch Name: Stanley Mosk Courthouse
Mailing Address: 111 North Hill Street
City, State and Zip Code: Los Angeles CA 90012

SHORT TITLE: GABRIEL BENAVIDEZ ET AL VS AMTRUST BANK ET AL CASE NUMBER:

BC707310
NOTICE OF COURT REJECTION OF ELECTRONIC FILING

The electronic filing described by the summary data below was reviewed and rejected by the Superior Court of
California, County of LOS ANGELES.

E-Filing Summary Data

Electronically Submitted By: Legal Connect
Transaction Number: 21LA04411526
Court received Date: 11/30/2021
Court received Time: 11:39 am
Notice Generated Date: 12/01/2021
Notice Generated Time: 12:28 pm

Documents Electronically Rejected

Appeal - Ntc Designating Record of Appeal APP-003/010/103

Document received by the CA 2nd District Court of Appeal.

This electronic filing was rejected based on the following reason(s)
Reject Reason Other: documents are illegible, there is no selection for a Record of Documents filed, on #2.b.(3)
both (b) and (c) are selected which contradict eachother, separate the documents and submit individually, app-
004 is filed with Court of Appeal

02/09/2017 E-FILING REJECTION NOTICE Page: 1

 Notice of Intent- Fee Schedule

Dear Sir/Madam:
This is a “NOTICE OF LIABILITY AND OPPORTUNITY TO CURE”, failure to admit or deny to
any specific charges {yellow highlighted or underlined} is a willful dishonor and is evidence of
known liability/entering into a binding covenant/contract with the creditor Lalonne, Juliet
EX/BENE, by silent acquiescence (silent/uncontested acceptance to the terms here instated).

The charges are as compensation deemed fair by the creditor for intentional harms/ tortuous
injuries to her body/mind/spirit and/or person/property and/or assigns/heirs/agents, to which this
fee schedule is agreed as fair compensation to her, contractually agreed on by the parties, in
this binding commercial/contractual arrangement, without contest by the parties, unless an
evidenced response is returned to the creditor, signed under penalty of perjury disputing the
charges and/or satisfactory evidence of the contracted activity is ceased and desisted.

The annexed Notice of Intent – Fee Schedule is a schedule of mandatory fees instated
by the Secured Party Creditor, Lalonne, Juliet EX/BENE Authorized Signatory Attorney-in-fact
on behalf of JULIET LALONNE ESTATE, Ens Legis.
I am Lalonne, Juliet EX/BENE, and I do hereby set forth fees to be instated in any
business dealing with JULIET LALONNE™ , JULIET LALONNE ESTATE and/or any attached

Document received by the CA 2nd District Court of Appeal.

iterations of this Estate/ testament/c’estui que vie trust/social securities (administered for my
benefit prior to my claim of status and competency to handle securities in my best interest (31
CFR 363.6 minor defined) as the sole known beneficiary and/or executor/next-of-kin to the
decedent (in re: Bolans taxpayers are c’estui que trusts not men or women), for any business
conducted relevant to this schedule. Fees are due and MUST be paid before said business can
commence. In the event that invoicing becomes necessary, invoiced amounts are due fifteen
days after day of receipt. If said fees are not met, it is the right of the Secured Party Creditor,
Lalonne, Juliet EX/BENE, to refuse or void any form of business interaction and/or transaction.
Fees are subject to change at any time without prior notice. Secured Party Creditor, Lalonne,
Juliet EX/BENE, is the only authorized personnel to alter, void, and/or enforce said fees and
may do so at any time. Without Prejudice.
Lalonne, Juliet EX/BENE, Oregonian, American National.
Without prejudice, without recourse.
In accordance with Title 8 U.S.C § 1101(a)(21).
Pursuant to Title 12 U.S.C. Section 411 + 412.
NO USUFRUCT. NUN PRO TUNCT.
The Grantor/Executrix/Director/Heir/
Sole Shareholder/Chief Executive Officer
for the JULIET LALONNE ESTATE

By: ________________________________________

JL-FS-1977 Page 1 of 8
 Notice of Intent- Fee Schedule

Acknowledgement

STATE OF )
COUNTY OF )

SUBSCRIBED and SWORN (or affirmed) to before me on this _____day of ______________, 2022, a
Notary, that Lalonne, Juliet EX, personally appeared and known to me to be the woman whose name
subscribed to the within instrument and acknowledged to be the same.

Signature of Notary Public: _____________________________________________________

My Commission expires: _______________________________________________________

Private Easements Schedule

Penalty for Private Use $250000.00

Public Easements Schedule

Penalty for Public Use $250000.00

These fees will be mandated upon the informant listed on the traffic citation ticket(s), arrest

Document received by the CA 2nd District Court of Appeal.

warrants, detention orders, seizure orders.

Produce trade name materials:

a. Name $ 50000.00
b. Drivers License Number $ 50000.00
c. Social Security Number $ 100000.00
d. Retinal Scans $ 5000000.00
e. Fingerprinting $ 200000.00
f. Photographing $ 200000.00
g. DNA $ 5000000.00
1. Mouth swab $ 5000000.00
2. Blood samples $ 5000000.00
3. Urine samples $ 5000000.00
4. Breathalyzer testing $ 5000000.00
5. Hair samples $ 5000000.00
6. Skin samples $ 5000000.00
7. Clothing samples $ 5000000.00
8. Forced giving of fluids/samples $ 5000000.00

Issue Traffic citations and tickets of any traffic nature:

a. Citations $ 60000.00

b. Warning issued on Paper Ticket $ 25000.00

Appearance in court because of traffic citations:

JL-FS-1977 Page 2 of 8
 Notice of Intent- Fee Schedule

a. Time in court $ 75000.00/hr with 1 hour

min.

b. If Fine is imposed $ 500000.00

Car / Personal Property Trespass, Carjacking, Theft, Interference with Commerce,

a. Agency by Estoppel $ 50000.00

b. Color of Law $ 150000.00

c. Implied Color of Law $ 150000.00

d. Criminal Coercion $ 500000.00

e. criminal Contempt of court $ 500000.00

f. Estoppel by Election $ 350000.00

g. Estoppel by Laches $ 350000.00

h. Equitable Estoppel $ 500000.00

Document received by the CA 2nd District Court of Appeal.

i. Fraud $ 1000000.00

j. Fraud upon the court $ 2000000.00

k. Larceny $ 250000.00

l. Grand Larceny $ 250000.00

m. Larceny by Extortion $ 1000000.00

n. Larceny by Trick $ 1000000.00

o. Obstruction of Justice $ 100000.00

p. Obtaining Property by False Pretenses $ 1000000.00

q. Simulating Legal Process $ 1000000.00

r. Vexatious Litigation $ 5000000.00

s. Trespass upon Motor Conveyance $ 100000.00

t. Unauthorized Relocation of Motor Conveyance $ 100000.00

u. Seizure of Motor Conveyance $ 100000.00

v. Theft of License Plate $ 10000.00

w. Unlawful Lien on Motor Conveyance $ 50000.00

JL-FS-1977 Page 3 of 8
 Notice of Intent- Fee Schedule

Use of trade name protected material under threat, duress, and/ or coercion:

a. Name written by the informant $ 250000.00

b. Drivers License written by informant $ 150000.00

c. Social Security Number written by informant $ 150000.00

d. Miscellaneous Material written by informant $ 500000.00

Produce any personal information/property for any kind of business interaction:

a. Financial Information $ 100000.00

b. Property inside of motor vehicle $ 150000.00

Time Usage for traffic stops:

a. 30 minutes $ 5000.00/30 minutes

minimum
b. 60 minutes $ 10000.00
c. 90 minutes $ 15000.00

Court Appearance Schedule

Document received by the CA 2nd District Court of Appeal.

These fees MUST be paid immediately after my case is finished. Failure to pay fines and
fees will have an additional fee of $5000.00 for breach of contract.

Demand for Appearance in court:

a. My Appearance

a. under protest and duress: $ 75000.00/hour

b. Voluntarily $ 10000.00/hour

Use of trade name material

a. Name

a. under protest and duress: $ 25000.00

b. Voluntarily $ 10000.00

b. Drivers License

a. under protest and duress: $ 25000.00

b. Voluntarily $ 10000.00

c. Social Security Number

a. under protest and duress: $ 25000.00

JL-FS-1977 Page 4 of 8
 Notice of Intent- Fee Schedule

b. Voluntarily $ 10000.00

d. Miscellaneous Material $ 25000.00

e. Produce any personal information for any kind of business interaction:

a. Financial Information $ 10000.00

b. Drivers License $ 10000.00

c. Social Security Number $ 250000.00

d. Any documents produced by me $ 10000.00 per document

Time usage for court appearances:

a. 30 minutes

a. Under Protest and Duress $ 33500.00

b. Voluntarily $ 10000.00

b. 60 minutes

Document received by the CA 2nd District Court of Appeal.

a. Under Protest and Duress $ 75000.00

b.. Voluntarily $ 20000.00

c. 90 minutes or more

a. Under Protest and Duress $ 100500.00

b. Voluntarily $ 30000.00

Transgressions-Fee Schedule

Transgressions by public official(s), police officer(s), judge(s), attorney(s), and all other who
desire to contract:

a. Failure to honor God Given Rights $20000.00

b. Failure to honor Oath of Office $50000.00

c. Failure to honor Constitutional Oath $50000.00

d. Failure to honor Written and/or Oral Word $ 5000.00

e. Silence/Dishonor/Default $ 5000.00

JL-FS-1977 Page 5 of 8
 Notice of Intent- Fee Schedule

f. Failure to honor /No Bond $ 5000.00

g. Phone call to telephone number used by Secured

Party including from alleged debt collectors $ 5000.00 each

h. Telephone message left on Secured Party phone

Service or equipment $ 5000.00 each

i. Use of Street Address/Mailing location of Secured Party $ 5000.00 each

j. Time Waiting for Scheduled Service $ 1000.00 Minimum or

per hour

k. Detention from Free Movement and/or cuffed $ 75000.00 Minimum or

per hour

l. Incarceration $ 75000.00 Minimum or

per hour

m. Failure to Follow Federal and/or State Statutes,

Document received by the CA 2nd District Court of Appeal.

Codes, Rules and/or Regulations $ 50000.00

n. Failure to State a Claim upon which

Relief Can Be Granted $250000.00

o. Failure to Present a Living Injured Party $100000.00

p. Failure to Provide Contract Signed by the Parties $100000.00*

q. Failure to Provide IRS 1099OID(s), and Other

IRS Reporting Form(s) Requirements upon Request $100000.00*

r. Default By Non Response or Incomplete Response $100000.00*

s. Fraud $1000000.00*

t. Racketeering $1000000.00*

u. Theft of Public Funds $1000000.00*

v. Dishonor in Commerce $1000000.00*

w. Failure to pay Counterclaim in full within (30) Thirty

Calendar Days of Default as set forth herein $1000000.00**

x. Perverting of Justice Judgment $ 1000000.00*

JL-FS-1977 Page 6 of 8
 Notice of Intent- Fee Schedule

y. Use of Common-law Trade-name/Trade-mark

After One Warning (per each occurrence) $ 50000.00 Each

w. Forcing psychiatric evaluations $ 500000.00 per day

x. Refusal to provide adequate and proper nutrition

while incarcerated $ 50000.00 per day

y. Refusal to provide proper exercise while

incarcerated $ 50000.00 per day

z. Refusal to provide proper dental care while

Incarcerated $ 50000.00 per day

aa. Forced giving of body fluids $ 5000000.00 per day

bb. Forced injections/inoculations, vaccines $ 5000000.00 per day

Document received by the CA 2nd District Court of Appeal.

cc. Forced separation from marriage contract $ 160000.00 per day

dd. Confiscation/kidnapping of a body not a US

Citizen $ 1600000.00 per day

ee. Corporate State continuing a mortgage for more

Than five years in violation of Banking Act of

1864 which takes precedence over current

Statutes at large $ 1600000.00 per day

Attempted extortion of funds from birth certificate

account, Social security account or any other

associated accounts by fraud, deception and

or Forgery by any agent, entity or corporation $ 6000000.00 per count or

charge

ff. Attempted extortion of signature $ 6000000.00 per count or charge

gg. Attempted forgery of signature $ 6000000.00 per count or charge

JL-FS-1977 Page 7 of 8
 Notice of Intent- Fee Schedule

*Per Occurrence and Includes any Third Party Defendant

** All claims are stated in US Dollars which means that a US Dollar will be defined, for this purpose as a
One Ounce Silver Coin of .999 pure silver or the equivalent par value as established by law or the
exchange rate, as set by the US Mint, whichever is the higher amount, for a certified One Ounce Silver
Coin (US Silver Dollar) at the time of the first day of default as set forth herein; if the claim is to be paid in
Federal Reserve Notes, Federal Reserve Notes will only be assessed at Par Value as indicated above.
Title 12 U.S.C. Section 411+412. No usufruct. NUN PRO TUNCT.

Total damages will be assessed as the total amount of the damages as set forth herein times three (3)
for a total of all damages as set forth in subsections a-w added to three (3) times the damages for
punitive or other additional damages.

Kidnapping (If an alleged officer removes free soul

more than 5 feet from free soul’s property without
just cause, it IS kidnapping) $ 5000000.00
Services to others and/or Corporation(s):
a. Studying $ 500.00 per hour
while under threat, duress, coercion $ 75000.00 per hour

b. Analyzing $ 500.00 per hour

Document received by the CA 2nd District Court of Appeal.

while under threat, duress, coercion $ 75000.00 per hour

c. Research $ 500.00 per hour

while under threat, duress, coercion $ 75000.00 per hour

d. Preparing Documents $ 500.00 per hour

while under threat, duress, coercion $ 75000.00 per hour

e. Answering Questions $ 500.00 per hour

while under threat, duress, coercion $ 75000.00 per hour

f. Providing Information $ 500.00 per hour

while under threat, duress, coercion $ 75000.00 per hour

If invoiced, payment is due 15 days after receipt date.

Make all payments to:

JULIET LALONNE™
c/o Lalonne, Juliet EX
16750 SE Tong Rd
Damascus, Oregon
[zip code-exempt]

(323)252-8487

JL-FS-1977 Page 8 of 8