9-26-2023 - Reply To Commissioner Opposition Waszczuk v. IRS Commissioner USCA No.20-1407

USCA Case #20-1407 Document #2019046 Filed: 09/26/2023 Page 89 of 149
The State Bar OFFICE OF CHIEF TRIAL COUNSEL

of California
180 Howard Street, San Francisco, CA 94105
September 25, 2023
Jaroslaw Waszczuk
708 El Capitan Dr
Lodi CA 95242
RE: Case Number: 23-O-23272 Gregory Paul Dresser
Dear Jaroslaw Waszczuk:
We have received your complaint against one or more California attorney(s). We have assigned
the number shown above to this matter; please reference this number in your communications
with us.
Your complaint will first be reviewed by an attorney in the Intake Unit. If we need further
information, we will contact you. We will also advise you of any determination in this matter. If
you want to know the status of your complaint, you may contact us by calling the State Bar’s
toll-free complaint line at 800-843-9053.
Thank you for your patience.
Sincerely,
OFFICE OF CHIEF TRIAL COUNSEL/INTAKE
San Francisco Office Los Angeles Office

180 Howard Street 845 S. Figueroa Street
San Francisco, CA 94105 www.calbar.ca.gov Los Angeles, CA 90017
The State Bar OFFICE OF CHIEF TRIAL COUNSEL

of California
845 S. Figueroa Street, Los Angeles, CA 90017
September 25, 2023
Jaroslaw Waszczuk
708 El Capitan Dr
Lodi CA 95242
RE: Case Number: 23-O-23273 Laura Ann Huggins
Dear Jaroslaw Waszczuk:
We have received your complaint against one or more California attorney(s). We have assigned
the number shown above to this matter; please reference this number in your communications
with us.
Your complaint will first be reviewed by an attorney in the Intake Unit. If we need further
information, we will contact you. We will also advise you of any determination in this matter. If
you want to know the status of your complaint, you may contact us by calling the State Bar’s
toll-free complaint line at 800-843-9053.
Thank you for your patience.
Sincerely,
OFFICE OF CHIEF TRIAL COUNSEL/INTAKE
San Francisco Office Los Angeles Office

180 Howard Street 845 S. Figueroa Street
San Francisco, CA 94105 www.calbar.ca.gov Los Angeles, CA 90017
https://www.scribd.com/document/673359264/09-25-2023-State-Bar-
Complaint-Against-California-Director-of-Commision-on-Judicial-
Performance-Gregory-Dresser
THE STATE BAR OF CALIFORNIA

OFFICE OF CHIEF TRIAL COUNSEL INTAKE
LOS ANGELES OFFICE
845 SOUTH FIGUEROA STREET
LOS ANGELES, CA 90017
SAN FRANCISCO OFFICE

180 HOWARD STREET
SAN FRANCISCO, CA 94105
ADDENDUM TO THE ATTORNEY MISCONDUCT COMPLAINT

FORMS
TO THE STATE BAR OF CALIFORNIA CHIEF TRIAL COUNSEL
I.
INTRODUCTION
To Whom It May Concern:
With this complaint, I am respectfully requesting that the State Bar of California’s
Chief Trial Counsel’s Office open an investigation against former State Bar of California
Interim Chief Trial Counsel (April 2015–September 2017) Gregory Paul Dresser, SBN
136532, who is now Director-Chief Counsel at the State of California’s Commission on
Judicial Performance (Commission), and Laura Ann Huggins, SBN #136532, former State
Bar of California Deputy Trial Counsel, currently employed by Erin Joyce Law, PC in
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Complaint against Attorneys Gregory Dresser and Laura Huggins .
Pasadena, California, and her former superior, State Bar of California Senior Trial Counsel
Robin Brune.
II.
COURT CASES RELATED TO THIS COMPLAINT
1. STATE BAR OF CALIFORNIA CASE NO.15-0-10110- LMA; CALIFORNIA

SUPREME COURT CASE IN RE STEIN, NO. S245982 (CAL. MAR. 1, 2018)
The case involved : My former ATTORNEY DOUGLAS EDWARD STEIN , SBN

131248 , State Bar of California Supervising Senior Trial Counsel ROBERT A.
HENDERSON, Investigator AMANDA GORMLEY , Senior Trial Counsel ROBIN
BRUNE, Investigator Supervisor LAURA L. SHAREK , Deputy Trail Counsel
LAURA ANN HUGGINS , Assistant Chief Trial Counsel Deputy Chief Trial, Interim
Chief Trial Counsel , Acting Deputy Chief Trial Counsel., The Assistant Chief Trial
Counsel GREGORY PAUL DRESSER and State Bar Judge MARIA LUCY
ARMENDARIZ
https://www.scribd.com/document/621488012/01-28-2015-State-Bar-o-California-
Complaint-against-Douglas-E-Stein-Case-No-15-0-10110).
2. WRIT OF MANDAMUS - UNEMPLOYMENT INSURANCE BENEFITS CASE

STATE BAR OF CALIFORNIA CASE NO.15-0-10110- LMA Sacramento County
Superior Court Case No. 34-2013-80001699, Jaroslaw Waszczuk v. California
Unemployment Insurance Appeal Board (CUIAB) and Real Party of Interest (Rip)—The
Regents of the University of California (The Regents), filed in the Court of Appeal on
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December 2, 2013. Third Appellate District Case No. C079254 Waszczuk v. CUIAB,
California Supreme Court Case No. S253713 & S245879 Waszczuk v. CUIAB
3. THE SACRAMENTO COUNTY SUPERIOR COURT WRONGFUL

TERMINATION CASE
Jaroslaw Waszczuk v. The Regents of the University of California, Case No. 34-2013-
00155479, filed on December 4, 2013, and 3DCA Cases C079524 & C095488 Waszczuk v.
The Regents of the University of California et.al . California Supreme Court Case No.
S245508 , S281719 involved judges from the County of Sacramento Superior Court DAVID
I. BROWN, Law & Motion Department 53; CHRISTOPHER E. KRUEGER, Law &
Motion Department 53; JENNIFER K. ROCKWELL, Order of Examination (OX)
Department 37; STEVEN H. RODDA, Law & Motion Departments 53 & 54 (a Retired
Judge on call) ; THADD A. BLIZZARD, Order of Examination (OX), Department 37;
SHAMA HAKIM MESIWALA, Law & Motion Department 53; and GEORGE A.
ACERO, Law & Motion Departments 53 & 54 backup. This wrongful termination case
involved my former attorney, STEIN, SBN 131248, who was disbarred in January 2020 for
professional misconduct; 14 Porter Scott attorneys; and two Horvitz & Levitz LLP attorneys
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(listed below) in addition to myself as a pro per litigant. The following have been involved
since December 16, 2014:
1. MICHAEL WILLIAM POTT, SBN 186156, Porter Scott attorney & shareholder
2. DOUGLAS LEE ROPEL, SBN 300486, Pott and Burkett’s assistant
3. DAVID P.E. BURKETT, SBN 300933, Porter Scott attorney & shareholder
4. CECILIA GUEVARA, SBN 307159, Burkett’s assistant
5. DANIEL J. BARDZELL, SBN 313993, Burkett’s assistant
6. NASIM SAHAR TOURKAMAN, SBN 300933, Burkett’s assistant
7. CHAMBORD V. BENTON-HAYES , SBN 278970, Burkett’s assistant
8. COURTNEY DE GROOF, SBN 319334, Burkett’s assistant
9. NANCY J. SHEEHAN, SBN 109419, Porter Scott attorney & shareholder
10. AMANDA I. ILER, SBN 300268, Porter Scott senior attorney
11. DEREK J. HAYNES, SBN 264621, Porter Scott attorney & shareholder
12. LINDSAY A. GOULDING, SBN 227195, Porter Scott attorney& shareholder
13. OLATOMIWA T. AINA, SBN 325566, Goulding’s assistant
14. THOMAS L. RIORDAN, SBN 104827, Porter Scott attorney & shareholder
15. KAREN M. BRAY, SBN 175501, Horvitz & Levy LLP attorney & shareholder
16. H. THOMAS WATSON, SBN 16277, Horvitz & Levy LLP attorney & shareholder
III.
AGE AND IMMIGRATION STATUS
I noticed that the new State Bar of California’s Attorney Misconduct Complaint Form
contains three questions that apply to me and my wife.
Question No. 1: Does this complaint involve allegations of attorney misconduct where a
person 65 years of age or older was victimized?
As of today, I am 72 years old; my wife of 50 years, Irena Waszczuk, is also 72
years old.
Eight years ago, on February 27, 2015, Porter Scott attorney and shareholder David Burkett
sent his associate, Douglas Ropel, to a hearing before Judge Shelleyanne Chang in
Jaroslaw Jerry Waszczuk v. California Unemployment Insurance Appeals Board
(CUIAB)(ROA #28), Case No. 34-2013-80001699-CU-WM-GDS with the UC Regents as a
Real Party of Interest. Waszczuk v. Cal. Unemployment Ins. Appeals Bd., C079254 (Cal. Ct.
App. Dec. 27, 2018). Neither Ropel nor Burkett was counsel of record for this case in
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February 2015. Burkett sent Ropel to the court for the sole purpose of confronting and
attacking me prior to the hearing. Ropel made vile, despicable threats to go after my (then)
65-year-old wife if I did not agree to drop the litigation against the Defendants in exchange
for legal fees in connection to the anti-SLAPP motion. The legal fees never should be
awarded to The Regents because the anti-SLAPP motion filed on December 1, 2014 by
Porter Scott attorney Michael Pott was a result of the my former attorney Stein crime and
conspiracy between him and Stein and collusion with Sacramento County Superior Court
Judge David I Brown
On August 8, 2017, after oral arguments, Defendants’ attorney Burkett, infuriated by
statements made by the Court of Appeals Justice Vance W. Raye during the oral argument
hearing and anticipating the Court’s decision, snapped and unloaded his anger on me and my
wife making vile threats against us. I thought that Burkett’s unwarranted attack in the 3DCA
building would lead to fisticuffs. Burkett instead became angered to the brink of beating up a
66-year-old old man right there in the halls of justice. Fortunately for me, I was accompanied
by a friend.
My wife became a soft target for the attorneys from Porter Scott who were representing The
Regents and, from April–July 2021, she was traumatized and victimized by Porter Scott
attorney Lindsay Goulding and forced to pay a ransom of $22,284 before Judge Thadd
Blizzard and his clerk in an unsuccessful attempt to frame her for criminal prosecution and
clean out her accounts to convince me to drop the litigations against The Regents
Question No. 2: Does this complaint involve allegations of attorney misconduct

where a person who is incapacitated, infirm, disabled, incarcerated, an immigrant,
or a minor was victimized?
Yes. My wife, Irena Waszczuk, and I are immigrants from Poland. I am political refugee
who was forced by communist government along with my family, to leave Poland in 1982
due to my political activities against the communist regime.
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https://www.scribd.com/document/494446114/Solidarity-Anti-Communist-Movement-
Poland-1980-1982).
IV.
THE ALLEGATIONS AGAINST LAURA ANN HUGGINS SBN #136532 AND
GREGORY PAUL DRESSER SBN 136532
A. The Court of Appeal, Third Appellate District (3DCA) Rigged and Fraudulent
Unpublished Opinion Waszczuk v. Regents of Univ. of Cal., No. C079524 (Cal. Ct. App.
Oct. 10, 2017) Caused By Gregory Dresser’ and Laura Huggins’ Professional and
Criminal Misconduct .
With this complaint, I am alleging that , between September 2015 and October 2017 Dresser,
Huggins, and their collaborators’ professional misconduct, and criminal misconduct including
and not limited to bribery , racketeering and conspiracy with my former employer The
University of California (hereafter The Regents ) or The Regents agents ,or attorneys and
Sacramento Courts staff led to issuance by the 3DCA totally fraudulent and rigged by rubber
stamp justice unpublished opinion Waszczuk v. Regents of Univ. of Cal., No. C079524 (Cal.
Ct. App. Oct. 10, 2017) https://casetext.com/case/waszczuk-v-regents-of-the-univ-of-cal
(Attachment No.1 on Flash Drive & DVD ) The 3DCA opinion was due to my appeal from
the the Sacramento County Superior Court judgment in anti-SLAPP motion (California
Code of Civil Procedure( C.C.P section 425.16) in my wrongful termination case against the
Regents filed on December 4, 2013 Jaroslaw Waszczuk v. The Regents of the University of
California, Case No. 34-2013- 00155479
The compromised of 3DCA justices Vance Raye, Ronald B. Robie, and George Nicholson
unpublished opinion instead of condemning my former attorney the Unpublished Opinion
shamelessly commended my former attorney Douglas Stein—who was dismissed for gross
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criminal misconduct after misrepresenting me in two cases stealing my money and colluded
with The Regents legal counsel Michael Pott and Judge of Superior Court David Brown.
To the contrary, Stein was diligent and transparent—making

an ex parte application to assure the integrity of the document he
inadvertently filed during the briefest of suspensions for a minor
transgression unrelated to his professional performance. He should
be commended, not chastised, for his fervent representation of
plaintiff’s interests.
After such heinous offenses, Stein proceeded to steal the entire retainer paid to him by in
June 2014. Stein’s crimes and criminal misconduct behavior would not have been possible to
condone from October 2015 to October 2017 without Gregory Dresser’s decision to do so
who as the employee and decision making State bar of California Chief Trial Counsel Office
executive apparently had his personal interest to condone the Stein’s crime and rigg the
3DCA opinion .
B. The Gregory Dresser’ , Laura Huggins and State Bar Chief Trial Counsel Investigator
Laura Sharek Conspiracy Against Waszczuk in October 2015-October 2017 .
This complaint would not be needed if Dresser and Huggins, given all of the resources
and information available to them, which they received from Wells Fargo Bank in 2015, had
properly prosecuted my former attorney, Stein, or turned him to state or federal law
enforcement authorities for prosecution due to theft of money instead of conspiring with The
Regents or their agents or attorneys and with Courts staff to condone Stein’s criminal
misconduct from October 2015 to October 2017 until 3DCA issued on October 10, 2017
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rigged and fraudulent opinion in the anti-SLAPP motion in 3DCA Case C079524 Waszczuk
v. The Regents of the University of California.
The 10/101/ 3DCA opinion led to another two 3DCA rigged and fraudulent opinions and
travesty of justice served to me for another six years and another crime that resulted in The
Regents’ attorney from Porter Scott attacking my 70 years old wife and stealing $22,284
from her in July 2021.
C. The Further Allegations Against Gregory Dresser and Laura Huggins
1. Base on documents, facts, and events, I allege that LAURA ANN HUGGINS and
GREGORY PAUL DRESSER, who as State Bar of California employees and officials
participated in the investigation and prosecution of Stein, violated the California State Bar
Rules of Professional Conduct and knowingly assisted or induced another to do so through
the acts of another person. This caused irreparable harm to my litigations in two complaints
filed in Sacramento Superior Court in December 2013 , enormous financial harm to myself ,
and the devastation of my and my family’s lives beside the Cost the Sacramento County
Superior Court , 3DCA and Supreme Court of California incurred because Dresser and
Huggin criminal misconduct .
2. The Dresser’s work history (1997-to Present) with the Morrison Foerster LLP, State Bar
of California and the California Commission on Judicial Performance, disclosed on
LinkedIn (https://www.linkedin.com/in/gdresser) and other online sources left me no doubts
that Dresser was the one who, from April 2015 through October 2017, made or was involved
in the decisions in the State Bar investigation of my former attorney Stein, SBN 131248 to
condone Steins’s and other attorneys crimes and misconduct I reported to State Bar in the
time period of December 2014 through October 2017 .
3. The Dresser’s work history with State Bar of California and the California Commission on
Judicial Performance and other undisputed facts lead me to conclusion that Dresser was the
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one who in September 2015 with evil intention to harm me caused that State Bar
Investigator Amanda Gormley and her supervisor Senior Trial Counsel Robin Brune were
removed from handling my complaint against Stein docked in the State Bar as a Case
Number: 15-O-10110-LMA.
4. In September 2015 Dresser in conspiracy with others caused that my complaint against my
former attorney Stein vanished together with assigned to the complaint State Bar Investigator
Amanda Gormley and her supervisor Senior Trial Counsel Robin Brune who already
concluded the investigation against Stein and the case was ready to be submitted to the State
Bar prosecutor in October 2015. Gormley and Brune were assigned by then Supervising
Senior Trial Counsel Robert A. Henderson to the Stein’s case on January 14, 2015 three
month before Dresser was hired in April 2015 by the State Bar .
5. From September 2015 to October 2017 Dresser to harm me and my litigations conspired
and collaborated with others included and not limited to Deputy Trial Counsel Huggins and
Investigator Supervisor Laura L. Sharek (Sharek) and State Bar Court Judge Maria Lucy
Armendariz (Armendariz) openly interfered and meddled in the judicial process pending in
the Court of Appel Third Appellate District (3DCA ) and tampered with the administration
of justice.
6. Gregory Dresser’ and his collaborators indisputably involved far more than severe financial
damages caused to me and my family and irreparable harm to my litigations in the two
Sacramento County Superior Court cases against The Regents of the University of California
in the San Joaquin County Superior Court writ of mandamus case (unemployment insurance
benefits case ) Jaroslaw Waszczuk v. California Unemployment Insurance Appeal Board
(CUIAB) and Real Party of Interest (RPii)—The Regents of the University of California (The
Regents), filed in the Court of Appeal on December 2, 2013 and ther wrongful termination
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case Jaroslaw Waszczuk v. The Regents of the University of California, Case No. 34-2013-
00155479, filed on December 4, 2013
7. The Dresser’s , Huggins and their collaborators conspiracy against me , which involved
interference and meddle in judicial process , caused and led to abuse of court system by the
The Regents of the University of California and California Unemployment Insurance Appeal
Board and their attorneys of record , corruption in the in the courts and abuse of power by
judges and justices in the Sacramento County Superior Court , The Court of Appeal Third
Appellate District and the California Supreme Court which resulted in three totally
fraudulent and rigged unpublished opinions issued by 3DCA Waszczuk v. Cal.
Unemployment Ins. Appeals Bd., No. C079254 (Cal. Ct. App. Dec. 27, 2018) California
Supreme Court Case No. S253713 & S245879 Waszczuk v. CUIAB and Waszczuk v. Regents
of Univ. of Cal., No. C079524 (Cal. Ct. App. Oct. 10, 2017),
https://casetext.com/case/waszczuk-v-regents-of-the-univ-of-cal California Supreme Court
Case No. S245508 , Waszczuk v. Regents of Univ. of Cal., S245508 (Cal. Jan. 10, 2018)
https://casetext.com/case/waszczuk-v-regents-of-univ-of-cal, Waszczuk v. Regents of the
Univ. of Cal., No. C095488 (Cal. Ct. App. July 28, 2023)
https://casetext.com/case/waszczuk-v-regents-of-the-univ-of-cal-1
V.
OCTOBER 2015–OCTOBER 2017, DRESSER’S INTERFERENCE IN THE
STATE BAR OF CALIFORNIA COMPLAINT AGAINST MY FORMER
ATTORNEY DOUGLAS STEIN, CASE NO.15-0-10110- LMA
A. Notice of Appeal in Waszczuk v. The Regents of The University of California,

3DCA Case No. C079524
Gregory Dresser was deployed from Morrison Foerster LLP to the State of
California Chief Trial Counsel in April 2015, at relatively the same time two unlawful
judgments were filed against me in Sacramento County Superior Court; one was a Writ
of Mandamus, Case No. 34-2013-80001699, Jaroslaw Waszczuk v. California
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Unemployment Insurance Appeal Board (CUIAB) and Real Party of Interest (RPii)—The
Regents of the University of California (UC Regents), which legitimized the theft of my
unemployment insurance benefits. This was issued by Judge Shelleyanne Chang from
Department 23. The other unlawful judgement was in the Sacramento Superior Court
wrongful termination case Jaroslaw Waszczuk v. The Regents of the University of
California, Case No. 34-2013- 00155479, filed December 4. This was an anti-SLAPP
motion orchestrated by my former attorney, Stein, and involved conspiracy, collusion, the
theft of my $20,000 retainer, and—most likely—bribery and racketeering. Judge David I.
Brown, of Dept. 53, was its author (Attachment #2 on the flash drive and DVD).
On May 7, 2015 and June 14, 2015, I filed in 3DCA Notices of Appeal of both judgments
(Attachment #3 on the flash drive and DVD).
B. Proposed Third Amended Complaint (TAC) in Sacramento Superior Court

wrongful termination case Jaroslaw Waszczuk v. The Regents of the University
of California, Case No. 34-2013- 00155479, filed December 4,2013
My September 2015 300 Proposed THIRD AMENDED
COMPLAINT(Attachment #4 on the flash drive and DVD)
became a sole reason that State Bar of California Investigator Amanda Gormley and Senior
Trial Counsel Robin Brune vanished for two years in October 2015 together with my State
Bar complaint against my former attorney Douglas Stein Case.15-0-10110- LMA
In June and July 2015, I discovered why, in 2011, I was hunted down and why my
employment with UCDMC was terminated by The Regents in 2012, before which I was
portrayed by my employer like most wanted terrorist or criminal after 13 years of service. In
June and July, I reviewed my entire court file, work history, and my previous file related to
my past employer, Destec Energy/Dynegy in relation to the $240 million fraud that firm
committed against Pacific Gas and Electric Company in 1989–1997 and the $280 million
fraud perpetrated against the California taxpayers in May 2000–September 2001 due to the
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sophisticated $40 billion fraud known as the “California Energy Crisis.” I checked the
United States Federal Energy Regulatory Commission e-Library and found why I was
targeted, victimized, and eliminated by the UC Regents in a six-year-long vendetta, between
December 2006 and December 2012 at UCDMC and thereafter in the State of California
unemployment insurance benefits office and Sacramento County Superior Court. I decided to
amend the SAC that had been filed on September 30, 2014 by Stein for the sole purposes of
destroying my lawsuit and stealing my money.
In August 2015, I informed The Regents’ counsels of record, Douglas Ropel and
David Burkett, that I intended to file a Third Amended Complaint (TAC).
On September 15, 2015, Burket responded to my notice of intention to file the
TAC by saying that, if I would provide him with a copy of the proposed TAC for
approval, he would help and arrange to prepare the stipulation to get the court’s approval
of the agreement to file.
On September 16, 2015, The Regents’ counsel repeated his offer for TAC
stipulation via email correspondence, dated September 15 and September 16, 2015
On September 22, 2015, I sent the TAC draft to The Regents’ counsels. I
intended to file the TAC to replace the defective SAC that Stein had filed on September
30, 2014
C. Disappearance of My State Bar Complaint against My Former Attorney
Douglas Stein, Investigator Amanda Gormley and Senior Trial Counsel
Robin Brune -State Bar Case.15-0-10110- LMA-Attorney Douglas Stein’s
Criminal Misconduct and Theft of the $ 20,000
On September 25, 2015, sent an e-mail to State Bar Investigator Gormley asking her about
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the status of his complaint against Stein. That same day, she replied as follows:
Mr. Waszczuk:
Your file with be submitted to the prosecutor by October 9.
Please communicate with me via regular mail or via fax.
You will receive a letter from our office when the case is
submitted to the prosecutor.
You will be contacted by the prosecutor if she needs
additional information.
In reply, I sent to Gormley a draft of my 295-page-long TAC, which detailed and

described The Regents’ actions in 2005–2008 and 2011–2012. In the TAC, I focused on
the 2009 Settlement Agreement violation and calculated the resulting damages
After September 25, 2015, I never received an official letter from the State Bar stating
that Stein’s case had been submitted to the prosecutor. Gormley and Brune, who
directly supervised Gormley’s investigation against Stein, and Supervising Senior
Trial Counsel Robert A. Henderson vanished and disappeared together with my
complaints against Stein for another two years, just like my unemployment insurance
benefits, which were reinstated by the EDD on May 14, 2014. After I sent the TAC
draft to Gormley, I received on that same day an e-mail from Sacramento County
Superior Court that notified me that The Regents had filed a motion to block my TAC
from being filed.
On October 28, 2015 Judge Brown granted the motion to The Regents and the TAC,
which was never submitted to the Court, was blocked from filing.
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Since September 2015, for the next eight years, DRESSER became a TROJAN
HORSE in my litigation against The Regents, and my 2015 proposed 300-page-long
TAC became taboo in the courts and was never filed.
VI.
THE OCTOBER 12, 2017 CALIFORNIA COMMISSION ON JUDICIAL
PERFORMANCE ANNOUNCEMENT
A. Dresser’s Move from The State Bar to the Commission on Judicial Performance
On October 12, 2017, THE CALIFORNIA COMMISSION ON JUDICIAL

PERFORMANCE announced that DRESSER had moved from the prosecution of
California attorneys’ misconduct as the State Bar Chief Trial Counsel to the
prosecution of California judges and justices’ misconduct, serving as its new
Director-Chief Counsel for the Commission on Judicial Performance (Attachment #6 on
the flash drive and DVD).
This happened after Dresser and his subordinates, Investigators Laura Sharek and Laura
Huggins, collaborated for two years with The Regents’ attorneys or the Office of the UC
General Counsel and Court staff to condone Stein’s criminal misconduct to derail my 3DCA
Appeal in Case C097488, Waszczuk v. The Regents of The University of California. Their
meddling in the judicial process to harm me falls into the category of criminal misconduct
and, perhaps, conspiracy, bribery, and racketeering. The statement in the unlawful 3DCA
unpublished opinion on Waszczuk v. Regents of Univ. of Cal., No. C079524 (Cal. Ct. App.
Oct. 10, 2017) praising Stein speaks for itself. Instead of condemning Stein, The Regents’
attorneys Pott (SBN 186156) and Burkett (SBN 300933), and Judge Brown who engaged
himself in misconduct by covering up or participating in Stein’s crimes, conspiracy, and
collusion, the 3DCA opinion praised Stein as if he was some kind of icon and hero:
To the contrary, Stein was diligent and transparent—making

an ex parte application to assure the integrity of the document he
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inadvertently filed during the briefest of suspensions for a minor

transgression unrelated to his professional performance. He should
be commended, not chastised, for his fervent representation of
plaintiff’s interests.
Stealing $20,000 from a client was a minor transgression for the authors of the
opinion.
Since The Regents signed a Settlement Agreement with me on January 30, 2009, the owners
or co-owners of the 27-MW cogeneration plant located at the UCDMC lost approximately
200 million tax-free dollars, or perhaps more, due to the lack of contract to sell power for
tax free profit .
On September 25, 2015, when I sent a copy of the proposed TAC to Gormley. The question
must be asked, why was it Dresser’s business to insert himself into my litigation against The
Regents by interfering and meddling in the judicial process? Dresser’s interference did not
end with Huggins’ October 10 , 2017 deceptive stipulation
https://apps.calbar.ca.gov/courtDocs/15-O-10110-2.pdf with Stein signed on the same day
the 3DCA unlawful opinion in anti -SLAPP motion was issued by 3DCA Waszczuk v. Regents
of Univ. of Cal., No. C079524 (Cal. Ct. App. Oct. 10, 2017)
I do not believe that 3DCA Presiding Justice Raye had anything to do with the
unpublished opinion in Waszczuk v. Regents of Univ. of Cal., No. C079524 (Cal. Ct. App.
Oct. 10, 2017) (anti-SLAPP motion). The opinion was unlawfully fabricated by the friends of
the Porter Scott attorneys employed by 3DCA and stamped .
A year earlier, on July 29, 2016, 3DCA issued a certified opinion for publication in the
ant-SLAPP motion Un Hui Nam v. Regents of the Univ. of Cal., 1 Cal.App.5th 1176 (Cal. Ct.
App. 2016), by Justices Vance Raye, George Nicholson, and Kathleen Butz. That Opinion
was delivered saying:
The California anti-SLAPP statute was intended to counter the

“disturbing increase in lawsuits brought primarily to chill the valid
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exercise of the constitutional rights of freedom of speech and petition for

the redress of grievances.” (Code Civ. Proc., § 425.16, subd. (a).) It has
been suggested that “[t]he cure has become the disease—SLAPP
motions are now just the latest form of abusive litigation.” (Navellier
v. Sletten (2002) 29 Cal.4th 82, 96 (dis. opn. of Brown, J.) (Navellier).)
And the disease would become fatal for most harassment, discrimination,
and retaliation actions against public employers if we were to accept the
Regents of the University of California’s (University) misguided reading
of the anti-SLAPP law and reverse the trial court’s denial of its motion
to strike. We agree with plaintiff Un Hui Nam that defendant did not
sustain its burden to demonstrate that the gravamen of her claims for
sexual harassment and retaliation arose from defendant’s protected First
Amendment activity. The trial court’s order therefore is affirmed.”
I was also unaware in August and September 2016 that, after the 3DCA
issued its opinion in Nam, The UC Regents, on September 27, 2016, filed a request
with the California Supreme Court to rescind its publication. The request was denied
on November 22, 2016.
The Nam case is from same UCDMC, and Ms. Nam was terrorized and sexually
harassed by the order of the same gangsters in its human resources department who were
the Defendants in my wrongful termination case and 3DCA anti-SLAPP motion appeal.
After Justice Raye, on October 10, 2017, delivered to me his unpublished opinion that
was the opposite of the opinion in Nam’s anti-SLAPP motion, now way I can see how
Raye could praise the theft of $20,000 and describe it as a minor transgression. None
of the justices who delivered the opinion in Nam are working in 3DCA any longer.
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VII.
THE AFTERMATH OF THE REMITTITUR ISSUED ON JANUARY 18,
2018 IN WASZCZUK V. REGENTS OF UNIV. OF CAL., NO. C079524 (CAL. CT.
APP. OCT. 10, 2017) (ANTI- SLAPP MOTION )
A. Sacramento County Superior Court Judge Christopher Krueger, from Dept.

54, and Judge Jennifer Rockwell, from Dept. 37
For known reasons, two of The Regents’ attorneys, David Burkett and Daniel
Bardzell, bypassed Judge Brown from Department 53 to employ Judge Christopher
Krueger, from Dept. 54, and Judge Jennifer Rockwell, from Dept. 37, to end my
lawsuit against The Regents via motion for termination sanctions in October 2018.
On October 3, 2018, Burket and Bardzell a filed motion for termination sanction
in Dept. 54 (Attachment #7 on the flash drive and DVD) and simultaneously filed an
Application and Order for Appearance and Examination on October 11, 2018 in Dept 37,
to frame me for a bench warrant and extract information about my wife’s bank and
401(K) retirement accounts.
Judges Rockwell and Krueger are friends who knew each other before they were
appointed to the bench; they worked for California Attorney General Bill Lockyer in the
same office on State v. All Persons, 152 Cal.App.4th 1386 (Cal. Ct.App. 2007). Judge
Krueger’s wife, Kris Burks, is employed in 3DCA as a senior research attorney,
On November 7, 2018, Judge Rockwell, from Department 37, signed an
Application and Order for Appearance and Examination in violation of the 45-day
- 17 -
requirement (Civil Code of Procedure§§ 491.110, 708.110, 708.120, & Sacramento

Superior Court Local Rule 2.1, (Attachment #8 on the flash drive and DVD).
On October 14, 2018, I alerted Court Clerk by the letter in Department 53 about
The Regents evil intention to obtain termination sanctions from Judge Krueger
B. The Regents’ Attorneys Bullying Tactics Aimed at Judge David Brown from
Department 53 to Obtain Termination Sanctions November 2018- December
2019
After Burkett and Bardzell failed to eliminate my wrongful termination lawsuit by

termination sanctions by the Judge Krueger’s involvement and with a bench warrant from
Judge Rockwell, they launched unprecedented bullying tactics aimed at Judge Brown to
eliminate my wrongful termination lawsuit against The Regents, which had been pending
since December 4, 2013. They recklessly bullied Judge Brown with endless motions for
termination sanctions for 1 year and 1 months, until December 2019. Burkett resigned or
was fired by Porter Scott in October 2019. He was replaced by Nancy Sheehan, who had
been at Porter Scott for 34 years. Burkett had been a lead attorney in the case Waszczuk v.
Regents of Univ. of Cal., C079524 (Cal. Ct. App. Oct. 10, 2017) since January 23, 2015.
Sheehan’s name was added to the pleadings at a time when she was gravely ill with
metastatic breast cancer; she died on November 23, 2019, exactly one month after another
motion was filed by Bardzell (see
https://www.legacy.com/obituaries/sacbee/obituary.aspx?n=nancy-joan-
sheehanandpid=194994093).
In November 2019, two new attorneys, Amanda Iler and Derek Hayes, joined
the six-years-long battle. Iler and Bardzel left Porter Scott shortly after Judge Brown
ordered them to repay the sanctions they collected from me on The Regents’ behalf. From
October 2018 through December 2019, I attended many court hearings with Judge Brown
- 18 -
and saw that he did not like what the attorneys representing The Regents were doing to me
and how they tried to force him to give them what they wanted.
The Regents attorneys’ over one year long multiple attempts to eliminate me from
court through bullying tactics aimed at Judge Brown clearly show that The Regents had
no chance to prevail with Judge Brown in any Summary Judgement Motion they might
have filed. Apparently, Brown realized that he had been drawn into a dirty game against
me in 2014 by a Porter Scott attorney and my former attorney Stein’s old friendship to
end my wrongful termination lawsuit. If The Regents had lost a summary judgment
motion and filed an appeal, they would have had a slim chance to prevail in 3DCA before
Presiding Justice Raye after Raye ruled against them in Un Hui Nam v. Regents of the
Univ. of Cal., 1 Cal.App.5th 1176 (Cal. Ct. App. 2016, https://casetext.com/case/un-hui-
nam-v-regents-of-the-univ-of-cal).
A. Trial Date and Mandatory Settlement Conference Date Submission Form

On February 18, 2020, I acted on the Meet and Confer letter to The Regents’ new
attorneys, Haynes and Iler, and proposed September 1, 8, or 15, 2020 as court trial dates,
and July 1, 2, or 6, 2020 as Mandatory Settlement Conference dates to bring this case to
trial and resolve it.
Due to a disagreement on dates with Iler, on March 3, 2020, I submitted to the
Court a Submission Form to set Trial Date on August 11 or 18, 2020 or September 28,
2020 and July 1, 2, or 6, 2020 as Mandatory Settlement Conference dates to resolve this
case. I never received any response from the Court.
VIII.
THE REGENTS’ MOTION FOR SUMMARY JUDGEMENT IN THE
SACRAMENTO SUPERIOR COURT WRONGFUL TERMINATION CASE
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JAROSLAW WASZCZUK V. THE REGENTS OF THE UNIVERSITY OF

CALIFORNIA, CASE NO. 34-2013- 00155479, FILED DECEMBER 4, 2013
A. After the Regents Attorneys’ Multiple Unsuccessful Attempts to end my

Wrongful Termination by Bullying Judge David I. Brown to Obtain Termination
Sanctions
After Judge David I. Brown ordered attorney Daniel Bardzell to return a $1300
sanction check (returned on January 8, 2020), and after I submitted on March 3, 2020 a
Trial Date and Mandatory Settlement Conference Date Submission Form Attachment
#10 on the flash drive and DVD), everything became very quiet. There were no
motions, court hearings, ex-parte communications, or attorneys seemingly active in my
case. The silence lasted for one full year after The Regents’ attorney failed to remove my
wrongful termination case from the Courts by bullying Judge Brown with non-stop
termination sanctions motions for more than one year. It was unthinkable that they would
lose the case to a Polish immigrant who relayed every pleading he wrote to a proofreader
and who has resisted them for seven years, since the wrongful termination case was filed
on December 4, 2013. With basically no financial resources apart from my $1800
monthly Social Security check, it was a mission impossible to survive against a public
entity with a $40 billion annual budget. The Regents’ former attorneys’ egregious
misconduct in the Court of law, malice, and bullying tactics aimed at my wife and
Judges Brown and Rodda in October 2018–December 2019 did not work as they had
anticipated. Then, they sought help from the Director and Chief Counsel of the
Commission on Judicial Performance, GREGORY PAUL DRESSER.
B. The Regents’ Attorneys Attack on my Wife in an Attempt to Break into her

Bank and 401(K) Accounts and to Frame Her for Criminal Prosecution
On April 22, 2021, I was served, at my residence in Lodi, CA, the following hand-
delivered Court documents:
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• CIVIL SUBPOENA (DUCES TECUM) for Personal Appearance and Production

of Documents, Electronically Stored Information, and Things and Trial or
Hearing and Declaration Issued to IRINA WASZCZUK by Olatomiwa T. Aina
on April 22, 2021 (Attachment #11 on the flash drive and DVD)
• An unsigned by a judge APPLICATION AND ORDER FOR APPEARANCE
AND EXAMINATION with a court hearing date of May 7, 2021 at 9:00 A.M. in
Department 43 (Attachment #12 on the flash drive and DVD)
• DECLARATION BY OLATOMIWA T. AINA IN SUPPORT OF JUDGMENT

CREDITOR’S APPLICATION FOR APPEARANCE AND EXAMINATION OF
IRINA WASZCZUK
The above documents were served to me on April 22, 2021 with the name IRINA
WASZCZUK, of 95242, in relation to unlawful legal fees awarded in an anti-SLAPP
motion by Judge Brown in 2015. This was granted to The Regents after my former
attorney Stein conspired with The Regents’ attorney to end my litigation in December
2014. I have already provided information about what Dresser did in this matter, together
with Investigator Laura Sharek and Deputy Trial Counsel Laura Huggins in 2015–
2017. I responded to Aina’s request, which violated the 45 days rule, and sent a copy of
the response to Court Department 43. Aina resigned from her position at Porter Scott a
few days later (Attachment #13 on the flash drive and DVD).
After receiving a copy of my response to Aina, the Court Clerk altered the date on the
APPLICATION AND ORDER FOR APPEARANCE by hand and filed the stamped
application with Judge Thadd Blizzard on May 7, 2021 showing a new examination date of
July 2, 2021. The attorney could have simply written to my wife, Irena, and asked her to pay
the unlawfully awarded legal fees for the 2014 anti-SLAPP motion. In 2019, my wife gave
me $25,000 to pay these fees, but the attorneys did not want the money. They wanted
termination sanctions and to clean out her bank and 401(K) accounts. The attorneys had
already been paid the anti-SLAPP motion fees by The Regents’ insurance company,
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Sedgwick Claims Management Services, Inc., but the eight years of litigation involved more
than fraudulent anti-SLAPP motion fees.
C. April 26, 2021 The Regents’ Ex-Parte Application for Leave to Extend Page
Limit for Defendant’s Motion For Summary Judgment or, in The Alternative,
Summary Adjudication
On April 26, 2021, simultaneous to the attack on my wife and in a scenario similar to
October–November 2018, The Regents’ two new attorneys, Goulding and her assistant Aina,
submitted to the Court an ex parte application for leave to extend the page limit. I noticed that
Goulding did not provide the number of the court department or judge’s name on the
application. This immediately suggested to me that something unusual was going on. I
quickly found that Judge Brown, who had presided over my cases since September 2014,
had left Department 53 at the end of December 2020, three years before his term was to end,
and he had been replaced by Judge Shama Hakim Mesiwala. I responded to Goulding’s
letter reminding her what her colleagues Burkett and Bardzel did in October 2018, bypassing
Judge Brown in an attempt to obtain termination sanctions from Judge Christopher Kreuger
I did not at that time realize that Dresser had launched a witch hunt investigation aimed at
3DCA Presiding Justice Vance Raye and caused Brown’s resignation.
D. Judge Shama Hakim Mesiwala
The Judge Shama H. Mesiwala was a central staff attorney at 3DCA for 1.5 years, followed
by serving as a chambers attorney for Justice Robie for 11 years. She was appointed
commissioner in 2017 and, 10 months later, a judge in Sacramento County Superior Court
(January 2021) (https://www.courts.ca.gov/75426.htm).
On February 14, 2023, Judge Mesiwala was unanimously confirmed as an associate

justice of the 3DCA in Sacramento by the Commission on Judicial Appointments, which
- 22 -
included Chief Justice Guerrero (Chair), Attorney General Rob Bonta, and Acting Presiding
Justice Ronald B. Robie (see https://newsroom.courts.ca.gov/news/commission-confirms-
appointment-third-district-court-appeal).
E. The Regents’ May 14, 2021 Motion for Summary Judgment or, in The
Alternative, Summary Adjudication In the Wrongful Termination Case Jaroslaw
Waszczuk v. The Regents of the University of California
On May 14 , 2021, with the arrival of a new Judge Shama Mesiwala in Department 53,
Goulding filed a massive amount of papers that were supposed to be a motion for summary
judgment (MSJ). This was coordinated with an ambush aimed at my wife’s bank and 401(K)
accounts. The MSJ was filed for the SAC and remined me of the COAs crafted by my former
attorney to steal my money and end my lawsuit in December 2014 (Attachment #15 on the
flash drive and DVD).
F. June 18, 2021 Motion to Recall the Remittitur and Request for Judicial Notice in
Support in Waszczuk v. Regents of Univ. of Cal., No. C079524 (Cal. Ct. App. Oct. 10,
2017)
In response to Goulding’s MSJ and attack on my wife, on June 18, 2021 I filed a Motion to
Recall Remittitur (Attachment #16 on the flash drive and DVD) and Request for Judicial
Notice in Support (Attachment #17 on the flash drive and DVD) to modify the October 10,
2017 3DCA fraudulent and unlawful unpublished opinion in the anti-SLAPP motion
Waszczuk v. Regents of Univ. of Cal., No. C079524 (Cal. Ct. App. Oct. 10, 2017), which was
filed on December 1, 2014. As noted previously, this opinion never should have been issued.
However, Dresser’s interference and meddling in the judicial process in 2015–2017 made
it happen.
I forwarded a copy of the motion to recall remittitur and judicial notice with a cover letter to
the Clerk in Department 53 (Judge Mesiwala) with a request to file the copy (Attachment
#18 on the flash drive and DVD).
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G. Judge Shama H. Mesiwala’s Disqualification
On June 29, 2021, I filed a PEREMPTORY CHALLENGE (Code of Civil Procedure §

170.6) motion against Judge Mesiwala (Attachment #19 on the flash drive and DVD).
On June 18, 2021, I provided a copy of the motion to recall remittitur with an
explanatory cover letter to Judge Mesiwala, with the expectation that she would react and
look into Goulding’s deceptive MSJ. This did not happen, and I waited for the motion to
be filed by the 3DCA. My previous experiences in the Courts, including physical threats
against my wife by The Regents attorneys’, triggered the motion of the PEREMPTORY
CHALLENGE (Code of Civil Procedure § 170.6) against Judge Mesiwala.It was my
response to the lack of any news from 3DCA or Department 53 and my previous
experiences. The other factor to disqualify Judge Mesiwala was that she had been
employed in 3DCA as a senior research attorney during the time when my anti-SLAPP
motion appeal was pending there, in 2015–2017.
H. My and My Wife Irena Waszczuk’s Appearance on July 2, 2021 in

Sacramento County Superior Court Department 43, Per Court Order Dated
May 7, 2021
The terror aimed at my wife from April through July 2018 by the UC Regents’ attorneys
resulted in her literally being robbed of $22,284 by Goulding in Court Department 43.
This happened while appearing before the Hon. Thadd Blizzard and the Court Clerk,
after an unsuccessful attempt to set her up for an interrogation to break into her bank and
401(K) accounts. This was aimed to convince me to end my litigation against the
Regents, but did not work.
When I attended on July 2, 2021 in the Sacramento County Superior Court
Department 43 (Judge Thadd Blizzard, ) the Dept. 43 clerk in rude way tried to force my
wife into an interrogation per Judge Thadd Blizzard’s altered and redacted Order dated May
7, 2021.
- 24 -
My wife, IRENA WASZCZUK, who has been the target of the Porter Scott attorneys’
criminal activities since February 2015, arrived with me and my good friend and former co-
worker from the UC Davis Medical Center, WILLIAM BUCKANS, who has been a witness
to Goulding’s set attack aimed at my wife. Buckans has always attended the court hearings in
Sacramento Court with me, due to the previous vile threats by Porter Scott’s attorneys in the
Court against me and my wife. The threats have been reported to the Court and the State Bar.
Upon arrival in Dept. 43, I noticed on the information board that Porter Scott attorney
Derek Hayes was listed in this attack aimed at my 70 years old wife.. However, Hayes was
not present. The Regents Attorney Lindsay Goulding appeared at the hearing and said she
was the one who was set and running whole interrogation . After the bailiff checked the
names the court clerk or judge’s assistant whose name I do not know became very rude and
pushy to get my wife interrogated. Then, I asked her what happened to my June 30, 2021 Ex
Parte Application for a continuance of this interrogation. She rudely responded that she did
not get the document and tried to begin my wife’s interrogation. The Court received my Ex-
Parte application on June 30, 2021 a same day it was filed in the Court by Rapid Legal
Services https://rapidlegal.com/ Sacramento Superior Court Wrongful Termination Case No.
34-2013-00155479 Jaroslaw Waszczuk v. The Regents of the University of California)
Goulding was sitting there, but said nothing. Finally, I told the clerk that there would be
no interrogation of my wife in this courtroom, and I informed her that I had a check in the
amount of $22,284 to pay whatever should be paid. The court clerk did not like this and tried
to force my wife to be interrogated by Goulding anyway .She tried to cut me out, stating that
I was not a party of this proceeding . I told her again that there would be no interrogation of
my wife, and I asked Goulding to whom I should write the check. The clerk interfered and
said that she does not know how to proceed. She then went to the judge’s chambers to get the
judge. After 10 minutes, Judge Blizzard appeared on the bench completely disoriented and
unprepared for the hearing and not knowing what the interrogation was to be about. He
started looking with the clerk for a Polish translator for my wife, even though I had written a
- 25 -
check for $22,284.in my hand. Finally, I forced Goulding to look at the check, which I
issued to the UC Regents and showed her my wife’s most recent Bank of America statement,
which verified that there were more than enough funds to cover the $22,284 .. Goulding did
not expect such an outcome when trying to set up my wife for the Bench Warrant to frame
her for criminal prosecution and to break into her bank account and her 401(K) life savings.
Judge Blizzard had no idea about these events because, apparently his clerk did not give
him to read my June 30, 2021 Ex Parte Application for a continuance of the hearing, which
included a copy of the Motion to Recall Remittitur, a copy for Judicial Notice (without
exhibits), and other attachments relevant to the ant-SLAPP motion legal fees. Goulding left
the court with the $22,284 bluntly stolen from wife’s account. I warned her not to harass
my wife anymore. Judge Blizzard issued a Court order to further intimidate my wife by
ordering her to return on August 6, 2021 if the case is not settled. The return hearing was set
just two days after the scheduled Court Hearing in Dept. 54 for Motion for Summary
Judgment before Judge Krueger
After this ambush - appearance in Dept. 43 on July 2, 2021 at 9:00 A.M., where
my wife paid a $22,284 ransom to Goulding, I noticed that the Court Dept . 43 issued an
order which filed together with a court order stating that Judge Sharma H. Mesiwala had
been disqualified, pursuant to CCP Section 170.6.
The Court Order dated July 2, 2021 stated :
Requested Examinee, Irma Waszczuk, was present with the Plaintiff, Jaroslaw
Waszczuk. The Plaintiff provided a check to Defendant's counsel in court.
Counsel accepted the check.
This matter is continued to August 6, 2021 at 9:00 a.m. in Department 43, all
parties are ordered to return. If the matter is settled by that date, Defendant's
counsel will contact the Court to drop the hearing.
It was not coincident that The Regents friends in 3DCA waited 19 days to file
on July 7, 2021, my Motion to Recall Remittitur submitted to 3DCA on June 18, 2021 to stop
Regents attorneys uncontrolled criminals activities in the Sacramento Courts and to prevent
- 26 -
money theft from my wife .

I am quite confident that I and my wife are not the only victims of criminals activities who
infiltrated the Sacramento courts .
Also on July 2, 2021, my wrongful termination case and the MSJ previously set for
8/4/2021 in Department 53 at 1:30 pm was reset for 8/4/2021 in Department 54 at 9:00 a.m.
(before Judge Krueger). Krueger and Judge Rockwell, in October –November 2018, were
employed by The Regents’ attorney to eliminate my wrongful termination lawsuit by
termination sanctions and to frame me for criminal prosecution in the same scenario as they
attempted with my wife in April–July 2021.
IX.
JULY 26, 2021 NOTICE OF CHANGE OF HANDLING ATTORNEY
FILED BY THE REGENTS’ ATTORNEY LINDSAY GOULDING
On July 26, 2021, Goulding filed a NOTICE OF CHANGE OF HANDLING
ATTORNEY stating:
PLEASE TAKE NOTICE that effective immediately Lindsay A.

Goulding will become the handling attorney of this matter and David
P.E. Burkett, Esq., Michael W. Pott, Esq. and Derek J. Haynes, Esq.,
are to be removed from this matter. Please update your service lists
accordingly and direct all further pleadings, correspondence and any
inquiries regarding defendant REGENTS OF THE UNIVERSITY OF
CALIFORNIA to Lindsay A. Goulding as follows:
It was quite surprising for me to see Burkett and Pott mentioned in this note. Burkett
replaced Pott on January 23, 2015 and represented The Regents until October 2019. He and
Bardzell were the ones who bullied Judge Brown for more than one year, in 2018–2019,
trying to force him to award them termination sanctions and remove me from the court. To
- 27 -
my knowledge, Burkett has been employed by Knox, Lemmon & Anapolsky, LLP since
October 2019.
Pott previously cut a deal with my former attorney Stein to decimate my original complaint. I
fired Stein in December 2017, and Pott left his firm one month later. Since then, Pott has been
employed by PRISM, in Folsom, CA. I had no clue what he was doing listed in a filing on my
case in 2021 along with Burkett.
Derek J. Haynes was a Porter Scott attorney who briefly appeared in my case in 2019 along
with Amanda Iler. He still works for Porter Scott.
X.
THE SACRAMENTO COUNTY SUPERIOR COURT JUDGE GEORGE A. ACERO
A. August 4, 2021 Minute Court Order
DATE: 08/04/2021 TIME: 09:00:00 AM DEPT: 54

JUDICIAL OFFICER PRESIDING: GEORGE ACERO
CASE NO: 34-2013-00155479-CU-WT-GDS CASE INIT. DATE: 12/04/2013
CASE TITLE: Waszczuk vs. The Regents of the University of California CASE
CATEGORY: Civil – Unlimited
EVENT TYPE: Motion for Summary Judgment and/or Adjudication - Civil Law
and Motion - MSA/MSJ/SLAPP
APPEARANCES
Nature of Proceeding: Motion for Summary Judgment and/or Adjudication
TENTATIVE RULING
The Court affirmed the tentative ruling.
Motion for Summary Judgment and/or Adjudication - Civil Law and Motion –
MSA/MSJ/SLAPP continued to 09/01/2021 at 09:00 in this department.
It was even more surprising for me to see former Porter Scott attorney GEORGE
ACERO’s name on the Court Order from Department 54 as a County of Sacramento
Superior Court Judge. I still do not know why in this order the SLAPP was attached to an
- 28 -
MSA/MSJ Anti-SLAPP motion in this case, when it ended with a fraudulent unpublished
opinion praising my former attorney’s criminal misconduct and the theft of my money
(see Waszczuk v. Regents of Univ. of Cal., No. C079524 (Cal. Ct. App. Oct. 10, 2017)).
A. Judge George Acero
After I saw Acero’s name on the Court Order as a judge, I learned that he had been
appointed to the bench by Governor Gavin Newsom on March 25, 2021. This is why
Porter Scott’s attorneys ceased all activities in my litigation and attacks in my case. They
knew that The Regents were working very hard with Governor Newsom and Chief of
Commission on Judicial Performance Dresser to replace inconvenient for them Judge
Brown with Judge Mesiwala, adding Acero as a Law & Motion Backup, in Departments
53 & 54, and to reorganize the 3DCA & Supreme Court by saying good bye to 3DCA
Presiding Justice Vance Raye and Supreme Chief Justice Tani-Cantil Sakauye .
B. George Acero’s Interference in Waszczuk’s Employment with The University

of California, Prior to his Appointment to the Bench in Sacramento County
Superior Court
George Acero, from West Sacramento, is a former intern in the UC Office of General
Counsel and worked for the Porter Scott law firm from 2003–2008. In August 2005, in
preparation for litigation after the ill-planned termination of my employment with the
UCDMC, Acero and another Porter Scott attorney, Michael Pott, fabricated the most
fraudulent anti-SLAPP motion ever drafted since the California Code of Civil Procedure §
425.16 was enacted into law and came to be known as an “anti-SLAPP law.”
Acero and Pott’s anti-SLAPP motion appeared as Vergos v. McNeal, 146
Cal.App.4th 1387 (Cal. Ct. App. 2007). After the opinion in Vergos was issued, I was
witch-hunted and narrowly escaped termination. I was removed from the UCDMC’s 27-
MW cogeneration power plant, which was commissioned in 1998 for the sole purpose of
producing and selling power worth millions of tax-free dollars illegally, in violation of
- 29 -
the university’s tax-exempt status, Internal Revenue Code (IRC) 501(c)(3), and the State
of California Revenue and Taxation Code. From 2005–2008, a witch hunt was instigated
by UC Vice President Judith Boyette, an attorney who specializes in litigation regarding
tax-exempt entities. In 2008, Boyette left the University of California, but she resurfaced
in 2016 after being appointed by the Secretary of the Treasury to a three-year term, from
June 2016–June 2019, https://www.hansonbridgett.com/Our-Attorneys/judith-w-boyette,
to the IRS Advisory Committee on Tax Exempt and Government Entities. She made sure
that my whistleblower claim would not surface; please see my September 19, 2023
Motion to Recall the Mandate in the UNITED STATES COURT OF APPEALS FOR
THE DISTRICT OF COLUMBIA CIRCUIT, Jaroslaw Waszczuk v. Commissioner of
Internal Revenue Services Case No. No. 20-1407 (Attachment #20 on the flash drive
and DVD).
Acero resigned from Porter Scott in 2008, at relatively the same time that I defeated The
Regents in arbitration to restore my employment and position at the UCDMC’s 27-MW
cogeneration plant. Even though Acero was no longer affiliated with Porter Scott, he did not
stop representing the University of California’s administrators in the lawsuits brought against
them by aggravated employees who had been subject to wrongful termination.
Acero resurfaced in 2013, after my employment with UCDMC was terminated due to a
second witch hunt orchestrated by The Regents or, more precisely, by the white collar
criminals from the UC Office of the President (UCOP), in Oakland, CA.
On May 14, 2013, six months after my employment was terminated, Acero’s
friend from the UCDMC Risk Management Department, Analyst Maria Garcia,
forwarded to UCDMC Human Resources Labor Relations Department (HRLR) manager
Travis Lindsay some of my old writings on the Davis Vanguard blog about the UC
Davis’s unconstitutional pamphlet titled “UC Davis Principles of Community.” It has
notoriously been used to punish complaining employees or whistleblowers. Garcia was
heavily involved in my employment termination as early as March 2007, when she served
- 30 -
as a communicator between attorneys and management from Human Resources, the

UCOP, and the UC Office of the General Counsel regarding the progress of termination
of employment and, thereafter, the resulting litigation (Attachment #21 on the flash
drive and DVD).
Pott’s name resurfaced on April 2, 2013, in e-mail correspondence between UC Davis
Chief Compliance Officer Wendy Delmendo and HRLR manager Travis Lindsay.
Lindsay’s email stated (Attachment #22 on the flash drive and DVD):
I just left you a voice message. Jerry’s step 2 meeting is today at 1:00 at Davis
campus. Mike Boyd is the step 2 officer and Gina Harwood is attending on behalf
of HR.
I think we need to avoid giving Jerry the impression that we expect him to be
unsuccessful at step 2. Also, we have no guarantee that he will appeal to step 3. I
expect him to, but he didn’t appeal his previous suspension past step 2. Could you
say that the University is holding his whistle blower complaint in abeyance
pending the outcome of his PPSM 70 complaint, and if that complaint ends up at
step 3 the whistle blower complaint will we reviewed by the arbitrator?
Travis
P.S. If we end up at step 3 Michael Pott from Porter Scott will be the
University’s advocate. We expect Jerry to sue us at some point and thought it
would be a good idea to involve outside counsel prior to that point to put us in as
good of a position as possible.
Pott and Acero, working as the University’s advocates in 2005–2008, lost the arbitration in
2008 that Delmendo was worried about. The witch hunt of 2005–2008, especially in 2005–
2007, was almost identical to the one of 2011–2012, including but not limited to fabricated
accusations. Acero’s and Pott’s fingerprints were very visible in both efforts. In May 2013,
when Acero sent his e-mail to Garcia, he was representing The Regents in the wrongful
- 31 -
termination lawsuit filed by a UCDMC employee in Sacramento County Superior Court, Um

Hui Nam v. The Regents of the University of California, Case No. 34-2013-00138396-
CUWTGDS; see also Acero’s anti-SLAPP motion in this case (Attachment #23 on the flash
drive and DVD). Acero’s anti -SLAPP motion became a subject of 3DCA Presiding
Justice Vance Raye’s comments in the Un Hui Nam opinion, in which he said:
It has been suggested that “[t]he cure has become the disease—
SLAPP motions are now just the latest form of abusive litigation.”
(Navellier v. Sletten (2002) 29 Cal.4th 82, 96, 124 Cal.Rptr.2d 530, 52
P.3d 703 (dis. opn. of Brown, J.) (Navellier ).) And the disease would
become fatal for most harassment, discrimination, and retaliation actions
against public employers if we were to accept the Regents of the
University of California’s (University) misguided reading of the anti-
SLAPP law and reverse the trial court’s denial of its motion to strike.
This opinion was somehow forgotten by 3DCA in my appeal and in the 3DCA opinion
on Waszczuk v. Regents of Univ. of Cal., No. C079524 (Cal. Ct. App. Oct. 10, 2017),
which was fabricated by Michael Pott in conspiracy with my former attorney Stein and in
collusion with Judge Brown.
The anti-SLAPP motion concerning Waszczuk v. Regents of Univ. of Cal., No. C079524
(Cal. Ct. App. Oct. 10, 2017) was the second-most fraudulent and fabricated anti-SLAPP
motion The Regents’ attorneys filed. It was also the most expensive. My estimate is that,
from December 1, 2014, when Pott filed the motion, to July 2, 2021, when Lindsay
Goulding robbed my wife of $22,284 from her savings, The Regents or owners/co-
owners of the UCDMC’s 27-MW cogeneration plant lost approximately $100 million
in tax-free money, perhaps more. This all could have been avoided if The Regents or
University administrators in Oakland had not listened to Acero, Pott, Goulding, and
other criminally minded advocates like Gregory Dresser and allowed me to retire from
the university in 2017 as I had planned. Evidence of my plans can be found with my
- 32 -
signing with the Regents a Settlement Agreement on January 30, 2009, as it guaranteed
me a job with the university until my retirement.
After I addressed Acero in my August 13, 2021 Opposition to the Motion For Summary
Judgment (p. 21) (Attachment #24 on the flash drive and DVD), and in Declaration in
Support of the Memorandum of Points and Authorities Motion for Reconsideration (pp.
5–9) on September 22, 2021 (Attachment #25 on the flash drive and DVD). Acero’s
name never re-appeared in my wrongful termination case, which has now gone on for 10
years.
XI.
THE COURT HEARING HELD VIA ZOOM, SEPTEMBER 1, 2021, IN
SACRAMENTO COUNTY SUPERIOR DEPARTMENT 54 BEFORE HON.
CHRISTOPHER E. KRUEGER, MOTION FOR SUMMARY JUDGMENT
A. The court hearing

On August 31, 2021, Judge Christopher Krueger, from Department 54, issued a Tentative
Decision granting a Motion for Summary Judgment to The Regents. That same day, I
requested a Court hearing via Zoom with Judge Krueger for September 1, 2021. I expected
at least a one- or two-hour hearing for the case, which had been pending in three different
courts since December 4, 2013. Judge Krueger had just been appointed to the case, taking
over from Judge David Brown, who had presided over it since September 2014.
In an unprecedented way of serving justice, Judge Krueger denied my right to be heard
and to present and argue The Regents’ and my submitted documents with an MSJ/MSA. He
abruptly ended the hearing after 5–10 minutes, affirming in that way his August 31, 2021
tentative ruling, which was based on nothing, or more precisely on the remaining causes from
the SAC, which had been filed on September 30, 2014 by my former attorney, Stein, in
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conspiracy with The Regents’ attorney.
B. The Regents’ attorney from Porter Scott, Thomas Riordan
The Regents’ attorney Lindsay Goulding, who fabricated and filed the MSJ on May 14, 2014
and robbed my 70 years old wife of $22,284 did not appear at the September 1, 2021 MSJ
hearing. Another Porter Scott attorney, Thomas Riordan, appeared for her, despite not being a
legal counsel of record in the case. Throwing Riordan into the game was no coincidence.
During the short hearing, Judge Krueger and Riordan acted like old friends. Riordan’s
(https://www.porterscott.com/person/thomas-l-riordan/) record in the State Bar database
(http://members.calbar.ca.gov/fal/Licensee/Detail/104827) shows that he has quite a history
of professional misconduct, including multiple acts of violating court orders and findings of
contempt and harming the administration of justice (see
http://members.calbar.ca.gov/courtDocs/02-O-11078.pdf). Riordan worked for three years as
a research attorney with the 3DCA in Sacramento, where Judge Krueger’s wife, Kristine L.
Burks, is employed as a senior research attorney.
C. The Reason I was cut off after 10 minutes and denied being heard by Judge
Krueger -Re: The Regents Power Purchase Agreement with Sacramento
Municipal Utility District
I was cut off short during the hearing because I was ready to present exhibits about May 11–
31, 2012 events related to why someone from the UCOP had, at the last minute, made the
decision to keep me from returning to work on May 31, 2012, after a forced 10-month
absence. My return had been planned, and I had been ordered in a letter from my department
manager to report to work on May 31, 2012.
On May 31, 2012, The Regents finalized a power purchase agreement (PPA) with
Sacramento Municipal Utility District (SMUD) to resume the sale of surplus power from the
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UCDMC’s 27-MW cogeneration, which had ceased after The Regents signed a Settlement
Agreement with me on January 30, 2009 (see
https://www.scribd.com/document/622460131/2012-UCDMC-27-MW-Cogenaration-Plant-
Power-Purchase-Agreement-with-SMUD). This cost them, or the co-owners of the plant,
millions of tax-free dollars. Just before Judge Krueger cut me off and ended the hearing, I had
in my hand a copy of the PPA, which I wanted to discuss in relation to the termination of my
employment. Most likely, if the hearing had been taking place in a courtroom, perhaps it
would have been a different story, but via Zoom and visible on YouTube, it was inconvenient
for Judge Krueger to listen to my testimony about violations of the university’s tax-exempt
status, millions of dollars tax evasion, and fraud due to violation of IRC 501(c)(3).
D. The Court hearing on September 1, 2021 with Judge Christopher Krueger Never
Should Have Taken Place
First, as I have pointed out many times before, I never had any intention of dealing with The
Regents’ tax evasion and fraud. During the course of my employment with the UCDMC as an
operator of the 27-MW cogeneration power plant (June 1999–April 2007), as an Associate
Development Engineer (February 2009–December 2012), and for three years thereafter, it
never crossed my mind that I would be hunted down because of a power sale worth millions
of tax-free dollars (see https://www.scribd.com/document/666103401/Jaroslaw-Waszczuk-s-
Work-History-With-UC-Davis-Medical-Center-1999-2012).
The Court records show that, from June 1999 through September 2015, the power sale by the
UCDMC’s cogeneration plant was never mentioned until I wrote my 300-page-long Third
Amended Complaint (TAC) and forwarded a copy of it to State Bar Chief Trial Counsel’s
Office Investigator Amanda Gormley, on September 25, 2015. Then, Interim Chief Counsel
Gregory Dresser removed her from the complaint against my former attorney, Douglas
Stein. She and my complaint vanished together for another two years. From June 1999
through June 2015, I thought that the Public Utility Regulatory Power Act of 1978, known as
- 35 -
PURPA, did not apply to public entities like the University of California. I never thought, or
cared, about this. Most likely, even if I had known, I would have kept my mouth shut, due my
experiences with my previous employer, Destec Energy Inc. (1989–1998), see
https://www.scribd.com/document/489028741/February-1999-Fire-in-My-Daughter-s-
Apartment-San-Carlos-California.
Second, Dresser’s conspiracy against me on The Regents’ behalf in October 2015 might
have made sense, because the PPA signed on May 31, 2012 between The Regents and SMUD
was not used, and on March 27, 2014, The Regents registered themselves with the California
Public Utilities Commission as an Electric Service Provider (ESP). On December 22, 2014,
The Regents successfully completed the Congestion Revenue Rights registration process with
California Independent System Operator (CAISO). The full story is in my addendum to IRS
FORM 2011, which I submitted to the IRS Whistleblower Office on September 3, 2022
(Attachment #27 on flash drive and DVD,see
https://www.scribd.com/document/600581546/09-03-2022-IRS-WBO-ICE-FORM-211-
APPLICATION-FOR-AWARD-Polish-Refugee-v-University-of-California-White-Collar-
Crime).
Third, tax evasion amounting to millions of dollars is a serious crime. Dresser’s meddling in
and tampering with the judicial process by holding the executive position with the State Bar’s
Chief Trial Counsel office and serving as the Director and Chief Counsel of the Commission
on Judicial Performance is very troubling. Taking into consideration that Sacramento
Superior Court Judge David I. Brown was bullied for more than a full year (November 2018–
December 2019) by The Regents’ attorneys and then forced by Dresser to resign in 2020
because he refused to meet their demand to serve me with termination sanctions to end my
litigation against them, it is safe to say that summary judgments would never have been
granted to The Regents if Judge Brown had remained in Department 53. Furthermore, The
Regents’ attorneys would never have filed the motion for summary judgement if Brown had
- 36 -
been in charge of Department 53 in 2021. They waited for several years, until The Regents,
with Dresser’s help, installed two new judges in Sacramento County Superior Court, Shama
Hakim Mesiwala, who replaced Judge Brown, and George A. Acero, who as an attorney
specialized in destroying University of California employees’ lives if they dared to complain
about the university’s management. Acero was installed as a back-up judge in Law and
Motion Departments 53 and 54.
Fourth, the September 1, 2021 Zoom hearing would not have taken place if the June 18, 2021
Motion to Recall the Remittitur issued on January 18, 2018 and the Request for Judicial Notice
of the rigged and totally unlawful October 10, 2017 opinion in anti-SLAPP motion Waszczuk
v. Regents of Univ. of Cal., No. C079524 (Cal. Ct. App. Oct. 10, 2017) had not been filed. The
Motion was denied on July 15, 2021 by 3DCA Presiding Justice Vance Raye’s rubber stamp. I
did not know in July 2021 that Raye was under siege from Dresser and The Regents for removal
from his post in 3DCA. I found about that when my appeal of Judge Krueger’s August 31, 2021
MSJ, fabricated by a Porter Scott attorney’s order and October 10, 202 judgment was pending
in 3DCA. The appeal was rigged in 2022 by manipulation of the record on appeal.
XII.
MY INQUIRES WITH THE STATE OF CALIFORNIA COMMISSION ON
JUDICIAL PERFORMANCE IN 2021
In July 2021 after Porter Scott\s Attorney Lindsay Goulding who represents The Regents
ambushed my 70 years old wife and stole from her $22,284 in Sacramento County Superior
Court Department 43 in attempt to frame her for criminal prosecution and clean out her
accounts to convince me to drop the litigations against The Regents than I alerted
Commission on Judicial (Commission) performance about the crime because of involvement
- 37 -
in the crime Judge from Department 43 Thadd Blizzard and his clerk . My inquiry was not a
official complaint against Judge .
On September 16, 2021 I received a response to my worries from the Commission Secretary
to the Trial Counsel Ms. Michelle Kem.(Kem) . (Attachment # 28 on Flash Drive and
DVD). I replayed to Kem on October 8, 2021 (Attachment # 29 on Flash Drive and DVD).
In my reply to Kem I stated:
My inquiry with the CJP was triggered in the defense of my 70-year-old

wife who has nothing to do with my litigation against the University of
California, but who has nevertheless been threatened by gangsters with J.D.
degrees from the Porter Scott law firm since February 2015. On July 2, 2021, my
wife was literally robbed of $22,284 from her savings by Porter Scott attorney
Lindsay Goulding in Court Department 43. This happened while appearing
before Judge Thadd Blizzard and the Court Clerk, and after an unsuccessful
attempt to set up my wife for an interrogation to break into her bank and 401(K)
accounts. Judge Blizzard, the Clerk, and Goulding did not want to accept the
$22,284 check from my wife. I literally had to force Goulding to take the check,
which she had no right to cash, and I told her in front of this judge and clerk to
stop harassing my wife. I had a witness with me during this event in court. I
believe this was a coordinated criminal act by the two Court departments (Depts.
43 and 53 or 54 ) to extort money. These departments should be audited by
the State Auditor and the FBI.
I never received any response from Michelle Kem, but shortly after I found out
that the former Porter Scott Attorney Katherine Mola is new Senior Counsel in the
California State Auditor’s office.
In 2012 the timing of my employment termination with UCDMC by the UCOP was
precisely coordinated with the lawsuit Baker v. Katehi et al., Case No. No. 12-cv-
00450-JAM-EFB, which was filed on February 22, 2012 in the US District Court’s
Eastern District of California. (Attachment # 30 on Flash Drive and DVD).
https://www.scribd.com/document/673122794/09-26-2012-Most-Unwanted-Poster-
and-Pepper-Spray-Settlement-Agreement
- 38 -
The lawsuit was filed in relation to the 2011 student protest on the UC Davis campus, which
was used for an ill-crafted paper spray provocation to remove UC Davis Chancellor Linda
Katehi, UC Davis Police Chief Annette Spicuzza, Lt. John Pike, and Captain Joyce Souza
from their posts. The Baker case was filed three weeks after the January 31, 2012 raid on my
psychologist Franklin O. Bernhoft’s home in Lodi by the California Department of Social
Services in a witch hunt orchestrated by Dooley and his wife Diana Dooley, who was the
Secretary of California Health and Human Services.
(Attachment # 31 on Flash Drive and DVD).
Two weeks after I received the Letter of Termination, the parties in Baker v. Katehi et al.
filed a final proposed order to settle the case after a settlement agreement was stipulated on
September 26, 2012. The order had been signed by US District Court Eastern District of
California Judge John A. Mendez. My termination with UC Davis Medical Center was
precisely coordinated with the Baker case and settlement agreement by the UC General
Counsel’s office and three Porter Scott attorneys, Nancy J. Sheehan,
https://www.legacy.com/us/obituaries/sacbee/name/nancy-sheehan-
obituary?id=2059585Terence J. Cassidy,
https://www.legacy.com/us/obituaries/sacbee/name/terence-cassidy-
obituary?id=30483812 and Katherine Mola
https://apps.calbar.ca.gov/attorney/Licensee/Detail/264625 who represented the
Defendants in a lawsuit related to the November 18, 2011 pepper spray provocation to oust
Katehi and the three UC Davis police officers. At the UCDMC, the coordinators were Porter
Scott attorney Michael Pott https://www.prismrisk.gov/about-prism/news/new-prism-coo-
mike-pott/ and former Porter Scott attorney George Acero. https://law.ucdavis.edu/deans-
blog/george-acero-friend-king-hall-sworn-sacramento-superior-court-judge. . Both were
- 39 -
advising the UCDMC human resources department on how to proceed with the termination of
my employment.
XIII.
NOTICE OF APPEAL AND RECORD ON APPEAL IN THE 3DCA CASE
WASZCZUK V. THE REGENTS OF THE UNIVERSITY OF CALIFORNIA, NO.
C095488 - IN RELATION TO GREGORY DRESSER’S WITCH HUNT AIMED AT
3DCA PRESIDING JUSTICE VANCE RAYE AND RAYE’S REMOVAL FROM HIS
POST ON JUNE 1, 2022
A. Notice of Appeal
On December 23, 2021, I filed a Notice of Appeal concerning the October 28, 2021
Motion of Summary Judgment signed by Sacramento County Superior Court Judge
Christopher E. Krueger, from Department 54, which was docketed in 3DCA on
December 29, 2021 (Attachment #32 on flash drive and DVD).
B. Appellant’s Notice Designating Record on Appeal, Filed January 31, 2022
On January 31, 2022, I filed a Notice Designating Record on Appeal that requested the
production and transmittal to 3DCA 147 listed and described Court documents from the case
Jaroslaw Waszczuk v. The Regents of the University of California, Case No. 34-2013-
00155479, filed on December 4, 2013, and the cross-connected case Jaroslaw Waszczuk v.
California Unemployment Insurance Appeal Board (CUIAB) and Real Party of Interest
(RPii)—The Regents of the University of California (The Regents), Case No. 34-2013-
80001699. The notice also requested the production of the Court Reporter’s Transcript
from the September 1, 2021 Court hearing VIA Zoom before Judge Krueger, which lasted
- 40 -
only 10 minutes (Court hearing for Motion for Summary Judgment, Attachment #33 on
flash drive and DVD).
C. The Incomplete Record on Appeal and Wrongly Labeled Clerk’s Transcript

(CT) on Appeal I Received on June 28, 2022 from the Sacramento County
Superior Court’s Appellate Department
The incomplete, or more precisely decimated, record on appeal with a wrongly labeled
CT was sent to me on June 28, 2022, more than two months after it was certified by
Sacramento County Superior Court Appellate Department Clerk Kevin Michaud.
I took a closer look at the record and wrongly labeled CT to find that:
1) After I received on June 28, 2022 the 13 volumes of the CLERK’S TRANSCRIPT
ON APPEAL (CT), I noticed that the CT had the wrong judge’s name and wrong
attorney It said “CLERK'S TRANSCRIPT ON APPEAL FROM THE JUDGMENT OF
THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE
COUNTY OF SACRAMENTO HON. DAVID BROWN DOUGLAS ROPEL
#300486, 350 UNIVERSITY AVE., STE 200 SACRAMENTO, CA 95825 Attorney
Defendant/Respondent,” instead of HON. CHRISTOPHER E. KRUEGER and
Defendant’s Attorneys LINDSAY GOULDING, who is the Defendants’ Attorney of
Record on Appeal, or THOMAS RIORDAN, who attended the Motion for Summary
Judgment Court Hearing with Judge Krueger via Zoom on September 1, 2021.
2) The CT was certified on April 22, 2022 by Sacramento County Superior Court
Appellate Department CLERK KEVIN MICHAUD with his initials KM .
3) The DECLARATION OF MAILING, which should be dated and signed under penalty
of perjury by the Sacramento County Superior Court Clerk, most likely by KEVIN
MICHOUD, was left blank (undated and unsigned), rendering it basically invalid, and it
contained the wrong name of the Defendants’ attorney, Douglas Ropel, who does not
work for Porter Scott and has not represented the UC Regents since March 2016
- 41 -
(https://www.littler.com/lawyer-search?lawyer_auto=ropel,
4) The CRT from the September 1, 2021 Court Hearing with Judge Krueger, which was
due to be produced and transmitted to 3DCA by May 9, 2022, was not produced and
transmitted to 3DCA at all. The NOTICE to prepare CRT by the Court Reporter stated as
follows :
Appeal from the Honorable Judge DAVID BROWN instead of Judge
CHRISTOPHER KRUEGER
PLEASE TAKE NOTICE that you and each of you are hereby directed to
commence preparation of the REPORTER'S TRANSCRIPT on Appeal in the
above-entitled action. The Appeal is to the THIRD DISTRICT COURT OF
APPEAL and the transcript is to contain the following dates, as designated by the
APPELLANT/RESPONDENT:
COURT DATES (CSR) NUMBE COURT REPORTER'S NAM
09/01/ 89 T. Tavale
TRANSCRIPTS ARE DUE: 05/09/22
Please read all designations as Computer-Readable format may have been

requested.
Please notify the Appeals Unit in writing before the due date if no transcript
will be filed. Requests for an extension of time from the Third District Court of
Appeal should be filed prior to the due date.
I declare under penalty of perjury that this notice was sent to the aforementioned reporters
and the Court Reporter Supervisor via interoffice Email.
Executed on: April 8, 20 B Kevin M

Deputy Clerk
The above Notice to Prepare Court Reporter Transcript was supposedly sent by Clerk
- 42 -
KEVIN MICHAUD to Court Reporter TINA TAVALERO via interoffice mail with the
misleading statement that the Appeal was from Judge Brown, who resigned from
Department 53 in December 2020, and the CRT was from the September 1, 2021 hearing
with JUDGE CHRISTOPHER KRUEGER from Department 54.
On June 27–28, 2022 I learned via an e-mail chat between Executive Analyst from
the Court Reporter’s Board of California, Paula Bruning, and Sacramento County Superior
Court Reporters Valerie Haley and Tina Tavalero that Ms. Halley had not received any
appeal notice in Waszczuk v. the Regents of the University of California for the 9/1/2022
Court Hearing with Judge Krueger, but she produced the CRT for the Porter Scott
attorneys representing the UC Regents.
I examined again the April 8, 2022 Notice of Filing of Designation and Notice to
Reporters to Prepare Transcripts, which was sent by Deputy Clerk Kevin Michaud, from
Appeals Unit Room 102, under penalty of perjury, and discovered that a Notice was sent to
Ms. Tavalero with a due date to produce transcripts on appeal.
I forwarded Ms. Bruning’s e-mail to Ms. Tavalero, and Ms. Tavalero responded that she
had nothing to do with the CRT from the September 1, 2022 Court Hearing with Judge
Krueger. She stated in her email response:
I was not the court reporter for this case. My name was put on the appeal notice
by mistake. It had another court reporter's CSR No. and my name. I checked all
my notes and I was not the reporter on this. I sent a declaration to the 3DCA
stating that I was listed by mistake and I have no notes for any of the proceedings.
( See: Tina Tavalero Declaration in the case C095488 docket)
However, in her June 28, 2012 e-mail response, Ms. Tavalero did not state whether
she ever received the April 8, 2022 Notice of Filing of Designation and Notice to Reporters
to Prepare Transcripts, sent supposedly by Deputy Clerk Kevin Michaud, nor did she
comment on whether she had informed Michaud that she had nothing to do with the
September 1, 2021 hearing, or whether she advised Michaud that the notice had the wrong
Judge’s name on it.
- 43 -
How it is even possible for a Court Reporter to prepare a transcript on appeal per
notice from the Appellate Department with the wrong Judge on the notice? The above facts
of misconduct and raise serious questions that should be investigated and answered by
Sacramento County Superior Court Appellate Department Clerk KEVIN MICHAUD. This
is not a trivial matter. This is an obstruction of justice and unlawful interference with the
reviewing court’s proceedings.
Who FORCED OR COERCED the preparer of the CLERK TRANSCRIPT ON
APPEAL to deliberately and with malice and premeditation mislabel the CT with the wrong
judge’s name?
More precisely, who forced the CT preparer to replace JUDGE CHRISTOPHER
KRUEGER’S name with JUDGE DAVID BROWN from Department 53, and why? Judge
David Brown resigned in December 2020 two month after Commission on Judicial
Performance Director and chief Counsel Gregory Dresser launched witch hunt pseudo -
investigation against 3DCA Presiding Justice Vance Raye. Judge Brown had nothing to do
with The Regents Motion for Summary Judgment filed on May 14, 2021, which was
decided by JUDGE CHRISTOPHER KRUEGER on September 1, 2021 who to make
decision used the defective Second Amended Complaint which was filed on September
30,2014 in conspiracy of my former attorney Douglas stein with The Regents Attorney from
Porter Scott and to steal from me $ 20,000 and set me up for anti-SLAPP motion
Who forced KEVIN MICHAUD to certify the deliberately mislabeled and incomplete
CLERK TRANSCRIPT on appeal?
Who ordered KEVIN MICHAUD to withhold sending the CLERK TRANSCRIPT on
appeal to 3DCA for the next 68 days after its certification on April 22, 2022? The undated
and unsigned DECLARATION OF MAILING, which should have been signed by Michaud,
indicates that he perhaps did not want to deal with the orchestrated fraud, deception, and
unlawful interference with the reviewing court’s proceedings, and it needs to be investigated
who is behind this crime to derail the appeal process.
- 44 -
The superior court clerk must "promptly mail" to the Court of Appeal notification
of the filing of a notice of appeal. (Cal. Rules of Court, rule 8.304(c)(1).) "The
failure of a court reporter or clerk to perform any duty imposed by statute or these
rules that delays the filing of the appellate record is an unlawful interference with
the reviewing court's proceedings. . . ." ( Id., rule 8.23.) People v. Grimes, 172
Cal.App.4th 121 (Cal. Ct. App. 2009)
Each item in the rules has the force of law (Carlson v. Department of Fish &
Game (1998) 68 Cal.App.4th 1268, 1272).
I outlined the details concerning how my appeal to 3DCA in Case C095488 was rigged by the
corrupted Court staff by manipulating and altering the record on appeal in my August 29,
2023 Inquiry/Request titled “Request for the 3DCA Clerk’s Office to transmit the
Supplemental Clerk’s Transcript on Appeal and Clerk’s Transcript Volume 1 to the Supreme
Court of California in the above-captioned Case No. C095488,” which I submitted to 3DCA
Clerk/Executive Officer Colette M. Bruggman on August 29, 202. and to California Supreme
Court Senior Deputy Robert Troy on September 7, 2023, together with a Petition for Review
(Attachment #34 on flash drive and DVD). Copies of my inquires to 3DCA and the
Supreme Court were also provided to Sacramento County Superior Court Presiding Judge
Michael G. Bowman.
It is not difficult to conclude that, in Sacramento County Superior Court, the Appellate
Department Clerk Kevin Michaud by in April–June 2022, acted with malice to rig my
3DCA appeal by the orders of someone above him. Michaud was ordered to withhold the
incomplete and deceptively mislabeled record on appeal until the Director and Chief Counsel
of the Commission of Judicial Performance, Gregory Dresser, conclude his witch hunt
aimed at 3DCA Chief Justice Vance Raye. This finally happened on June 1, 2022 when
Raye was removed from office (Attachment #35 on flash drive and DVD,
- 45 -
https://cjp.ca.gov/wpcontent/uploads/sites/40/2022/06/Raye_DO_Pub_Admon_6-1-
22.pdf).
It is also not difficult to conclude that Dresser, or his office, communicated the progress of
the witch hunt aimed at Vance to the UCOP; UC Office of General Counsel; or Porter Scott
attorneys who are well connected with the staff, judges, and justices in the Sacramento
Courts.
After Raye was removed by Dresser, 3DCA Justice Ronald Robie was appointed, or
appointed himself, the 3DCA’s Acting Administrative Presiding Justice. He attached
himself to my appeal case C095488. Robie was on the panel of 3DCA Justices who
decided the anti-SLAPP motion appeal with the totally unlawfully issued opinion on
October 10, 2017 in Waszczuk v. Regents of Univ. of Cal., No. C079524 (Cal. Ct. App. Oct.
10, 2017), https://casetext.com/case/waszczuk-v-regents-of-the-univ-of-cal. This anti-
SLAPP motion, which never should have been issued, was the result of Dresser and Laura
Huggins tampering with and meddling in 3DCA’s judicial process between October 2015
and October 2017. This was repeated by Dresser in 2020–2023, and his interference in the
judicial process took a much more drastic form that included the removal Judge David I.
Brown from the Sacramento Superior Court, Justice Vance Raye from 3DCA, and the
resignation of Supreme Court of California Chief Justice Tani Cantil-Sakauye shortly after
Raye was removed on June 1, 2022.
XIV.
MY OCTOBER 2022–MARCH 2023 INQUIRES WITH THE STATE OF
CALIFORNIA’S COMMISSION (COMMISSION) ON JUDICIAL
PERFORMANCE SECRETARY TO TRIAL COUNSEL MICHELLE KEM
A. October 14, 2022 Inquiry with 3DCA Acting Administrative Presiding Justice
Ronald Robie
- 46 -
As previously noted, after my wife was ambushed by The Regents’ attorneys in July
2021, when they stole $22,284 from her, I sporadically sent information to the
Commission’s Trial Counsel, Michelle Kem, informing her of what the Sacramento
Court and The Regents’ attorneys were doing in my wrongful termination case, which
has been pending for almost 10 years three different state Courts. If I had received the
information from Wells Fargo in January 2015 that I received in October–
December 2022, it would be a very different story.
After I learned in October 2022 what the Gold Business Services Package account was about,
I sent more specific inquiries to Ms. Kem requesting intervention in my case. What the two
Courts’ staff members and judges and justices were doing in my appeal of 3DCA Case
C095488 in 2022 and 2023 to derail it before a decision was issued was both troubling and
unprecedented.
On October 14, 2022, I faxed to the Commission my inquiry to the 3DCA Acting
Administrative Presiding Justice Ronald Robie, who replaced Justice Vance Raye on June 1,
2022. The issue was my Appellant’s Opening Brief. I titled the fax: “Nothing got better in
3DCA since Chief Justice Vance Raye left 3DCA. The enclosed documents are for your
review and serious consideration.”
On November 1, 2022, I received a short response from the Commission’s Secretary to Staff
Counsel, Mary Harvey, stating:
We have read your communication. It does not pertain to the work of the Commission
on Judicial Performance, which is responsible for handling complaints against
California state court judges for judicial misconduct. Your complaint concerns court
personnel. This commission has no jurisdiction over court personnel. (Attachment #
36 on the flash drive and DVD)
- 47 -
B. November 10, 2022 Letter Addressed to Kem addressing Harvey’s Response,

Dated November 1, 2022
I addressed Harvey’s letter in same manner that, in 2016, I addressed my complaint against
Sacramento County Superior Court Judge Shelleyanne Chang. In 2015, a judgement by Judge
Chang legitimized the theft of my stolen unemployment insurance benefits, which were
reinstated on May 14, 2014, when I was still being represented by Douglas Stein
C. November 10, 2022 Inquiry Addressed to Kem Titled “REQUEST FOR
INTERVENTION”
In this 54-page-long inquiry with attachments, I detailed the events surrounding the 3DCA
Appeal Case No. C095488 and my cases in general, which have been pending for almost nine
years. My litigation in State of California Courts is an unprecedented example of denying
equal access to justice, the promotion of discrimination and bias, and extreme beyond
imagination prejudice toward self-represented litigants. It led to ill-orchestrated and
criminally minded attacks aimed at my wife. Since 2016, 1 have alerted the Commission
about these crimes on many occasions, as they involve the University of California
administrators’ attorneys from Porter Scott, and judges and clerks from Sacramento County
Superior Court Dept. 43, who are working in coordinated efforts with Departments 53 and 54
and 3DCA justices and staff. In my inquiries, I have asked the Commission to intervene and
send my complaints to directly to Robie and to Sacramento County Superior Court Presiding
Judge Michael Bowman (Attachment #38 on the flash drive and DVD).
D. November 18 , 2022 Inquiry Addressed to Kem Addressing the Augmented
Record Appeal
In this inquiry, I addressed 3DCA’s November 14, 2022 Court Order, which granted the
Appellant’s motion to augment the record on appeal in part and denied it in part. The
manipulated record on appeal clearly shows that the whole appeal was rigged and the results
- 48 -
of the appeal were known to The Regents’ attorneys long before the unpublished opinion was
issued on July 28, 2023 as Waszczuk v. Regents of the Univ. of Cal., No. C095488 (Cal. Ct.
App. July 28, 2023, Attachment #39 on the flash drive and DVD).
F. November 29 , 2022 Follow Up Inquiry Regarding my Request for Intervention
Addressed to Kem
This letter contained additional information following up on my Request for
Intervention and my response to the November 1, 2022 letter from Harvey, which was
submitted to Kem’s office on November 10, 2022 and November 18, 2002. I also enclosed a
copy of my request to open the 2011–2012 State of California Department of Insurance
Investigation (Claim CS13-6707505) into Liberty Assurance Company of Boston (acquired
by Lincoln National Life Insurance company on May 1, 2018), which wrongly denied my
2011 short-term/supplement disability claim #4154074. I provided an explanation in the letter
detailing why I had submitted a copy of my request to the State of California’s Department of
Insurance (Attachment #40 on the flash drive and DVD).
G. My January 10, 2023 Inquiry Addressed to Kem Regarding The Regents’

Attorney Karen Bray’s Request for an Extension of Time to File Respondent
Brief
In this informational letter, I addressed The Regents’ attorney Karen Bray’s request
for an extension of time to file a Respondent Brief in 3DCA Case C095488 (Appeal),
beyond an already granted 60-day extension of time. The case has been unlawfully
dragged out in the courts for more than nine years without resolution, perhaps with the
expectation that I will eventually die.I addition, I again addressed in the letter The
Regents’ attorneys actions against my wife and provided detailed information about
how she was terrorized and traumatized before $22,284 was stolen from her
- 49 -
H. My March 3, 2023 Follow Up Inquiry Addressed to Kem Further Addressing

Bray’s Respondent Brief
My letter, in which I commented, “This is How the Holocaust Happened. Evil
Prevails when Good Men and Women Do Nothing,” addressed Bray’s behavior
further.
On March 1, 2023, I sent a letter to Bray about the Respondent Brief that was due
to be filed on February 16, 2023, after an extra 30 days’ extension had been granted
above the 60-day extension she had already been granted. Bray used her mother’s
death as an excuse for her failure to file (Attachment #42 on the flash drive and DVD,
https://www.scribd.com/document/629 1 79226/03-01-2023-Letter-to-Karen-Bray-
Failure-to-File-Respondents-Brief).
On February 17, 2023, 3DCA should have sent her a notification about her failure to file
the brief in a timely manner. On February 22, 2023, 1 sent a reminder to the 3DCA clerk
about the Brief not being filed. That same day, the clerk reminded Bray about her failure
to file.
I. March 14 , 2023 Inquiry Submitted to Kem Addressing the Wells Fargo

Gold Business Services Package Account Opened June 2, 2014 by my
Former Attorney Douglas Stein for the Sole Purpose of Stealing my
Money
My March 14, 2023 inquiry was entitled “Irreparable Damage to my Litigation from 2014-
2023 Against The Regents of the University of California ( Regents), the California
Unemployment Insurance Appeal Board (CUIAB), and to my Life and Wellbeing at
Retirement Age, Caused by Wells Fargo Bank’s Unfair Business Practices and Misconduct.”
My letter addressed the copies of the 2014 Wells Fargo Bank documents and statements that
a Wells Fargo representative provided to me about the account my former attorney, Douglas
Stein, opened on June 2, 2014 under false pretenses with my $19,500. I gave Stein this money
as a retainer to represent me in my wrongful termination case against The Regents of the
University of California. The inquiry was similar in part to my complaint against former State
- 50 -
Bar Interim Chief Trial Counsel Gregory Dresser and Deputy Trial Counsel Laura Huggins.
In addition to faxing and mailing the letter with attachments to Kem, I e-mailed it
directly to the members of the Commission on Judicial Performance, due to lack of any
response from Kem since I responded to a letter from him in October 2021 (Attachment
#43 on the flash drive and DVD).
XV.
THE MARCH 15, 2023 LETTER FROM GREGORY PAUL DRESSER,
DIRECTOR-CHIEF COUNSEL OF THE COMMISSION ON JUDICIAL
PERFORMANCE
A. Dresser’s Letter
Dresser’s short letter was a response to my March inquiry sent to Kem and the
members of the Commission on March 14, 2023. It stated (Attachment #44 on the flash
drive and DVD):
This is in response to your March 14, 2023 email to members of

the Commission on Judicial Performance. Members of the commission do
not correspond individually with people who have filed complaints with
the commission but have authorized me to do so on their behalf.
I have reviewed your original submission and all of your

subsequent submissions. You have asked for this office’s assistance in
intervening with the Third District Court of Appeal and the Sacramento
County Superior Court to provide them with the complaint attached to the
email. Please be advised that the commission is unable to assist you with
your request.
The commission’s jurisdiction is limited to investigating and, when

appropriate, imposing discipline for judicial misconduct. Your complaint
concerns legal rulings made by a judicial officer. Ordinarily, individual
legal rulings are not a basis for review, by this commission. Even a judicial
- 51 -
decision or administrative act later determined to be incorrect is not itself

a violation of the Code of Judicial Ethics and is not misconduct.
Very truly yours

It is was no secret for the Courts that I submitted multiple inquiries to Kem asking for
intervention in Sacramento County Superior Court and 3DCA to invalidate the
corrupted court proceedings , including Court orders and opinions in my
wrongful termination and unemployment benefits insurance cases. This
happened after The Regents’ attorney, Goulding, in a desperate move, ambushed my wife in
Sacramento County Superior Court Dept. 43 on July 2, 2021, stealing $22,284 from her
savings in an attempt to break into her bank and 401(K) plan accounts and frame her
for criminal prosecution, in the desperate attempt of convincing me to drop his
litigation against. Dresser’s response to my multiple inquires of the Commission
requesting nullification of two 3DCA opinions, Waszczuk v. Cal. Unemployment Ins.
Appeals Bd., No. C079254 (Cal. Ct. App. Dec. 27, 2018) and Waszczuk v. Regents of Univ.
of Cal., No. C079524 (Cal. Ct. App. Oct. 10, 2017), was a surprise and unexpected.
Dresser’s name sounded familiar to me. I came across it in lawsuits that were pending in
Sacramento County Superior Court at relatively the same time as my wrongful termination
case with same judge, David Brown, presiding. Those cases were Dina Padilla vs.
Commission on Judicial Performance, Case No. 34-2018-00242031-CU-MC-GDS, and
3DCA case Chodosh v. Comm’n on Judicial Performance, Case No. C091221, in which
Dresser was an individual defendant.
In the January 10, 2023 inquiry to Kem, I addressed Chodosh v. Commission
on Judicial Performance et al., Number C091221, in relation to my Appellant’s
motion to recall the remittitur and request for judicial notice filed on June 18, 2021 in
3DCA case No. C079524, Waszczuk v. The Regents of the University of California.
The motion to recall the remittitur and request for judicial notice was denied on July
- 52 -
15, 2021 by 3DCA Presiding Justice Raye, who was under investigation by Dresser
for alleged judicial misconduct. This happened two weeks after my wife was
ambushed Goulding as detailed above.
B. SUBPOENA FOR PERSONAL APPEARANCE dated September 8, 2017
After I received the March 15, 2022 letter from Dresser, I searched my computer for
Dresser’s name. Surprisingly, it appeared in a State Bar of California Office of Chief Trial
Counsel SUBPOENA FOR PERSONAL APPEARANCE dated September 8, 2017
The front page of the Acknowledgement of Receipt of Receipt of Subpoena, contained the
following senders names
• STEVEN J. MOAWAD, SBN 190358– CHIEF TRIAL COUNSEL
• GREGORY DRESSER, SBN 136532-DEPUTY CHIEF TRIAL COUNSEL
• SUSAN CHAN, SBN 233229 -ASSISTANT CHIEF TRIAL COUNSEL
• ROBERT A. HENDERSON, SBN 173205 -SUPERVISING ATTORNEY
• LAURA HUGGINS , SBN 294148– DEPUTY TRIAL COUNSEL
In September 2017 I was unfamiliar with Steven J. Moawad . Susan Chan , Laura Huggins &
Gregory Dresser’s names . Only Robert A. Henderson’s name sounded familiar because he
on January 14, 2015 informed me that that Gormley had been assigned to investigate my
complaint under the direct supervision of Senior Trial Counsel Robin Brune
I looked at the subpoena and noticed Dresser’s name next to Chief Trial Counsel Steven J.
Moawad and Laura Huggins. What first came to mind were Gormley and Brune, who were
removed from Stein’s case in September 2015. The silence and lack of response from Kem
since October 2021, summarized by a meaningless half- page letter from Dresser on March
15, 2023, was nothing but repentance for the removal of Gormley and Brune in 2015 from
Stein’s case to cover up The Regents crimes amounted in the millions of dollars tax evasion
- 53 -
and fraud due to violation of the university exempt status IRC 501 ( c ) ( 3) and other state
and federal law .
I.
CONCLUSION
In light of the above facts and evidence, I am respectfully requesting that the State Bar
of California Chief Trial Counsel fully investigate the actions of October 2015–October
2017 by former Deputy Chief Trial Counsel Laura Huggins and her collaborators’
misconduct in relation to my complaint against my former attorney, Douglas Edward
Stein, and the crimes he committed, including but not limited to the theft of my retainer
money and the theft of unemployment insurance benefits.
In light of the above facts and evidence, I am respectfully requesting that the State Bar
of California Chief Trial Counsel fully investigate Gregory Dresser’s alleged criminal
misconduct, which includes and is not limited to tampering with and meddling in the
judicial process in my wrongful termination lawsuit of 2015–2018 and again in 2020–
2023, on behalf of The Regents of the University of California or executives from the
UCOP, as described in my complaint. Dresser’s actions have caused financial
devastation and a diminished quality of life in general for me and my family.
A complaint against several attorneys from the Porter Scott and Horvitz and Levy LLP
law firms will shortly follow this complaint.
Respectfully submitted on September 25, 2023.
_____________________
Jaroslaw Waszczuk
- 54 -
Evidence in the form of the attachments on the flash drive and DVD. Hard paper
copies are available upon request.
https://www.scribd.com/document/673359264/09-25-2023-State-Bar-Complaint-
Against-California-Director-of-Commision-on-Judicial-Performance-Gregory-
Dresser
CC:
State Bar of California Executives
Supreme Court of California –Jaroslaw Waszczuk v. The Regents of the University of
California, Case No. S281719
- 55 -
Filed 10/10/17 Waszczuk v. Regents of the University of California CA3
NOT TO BE PUBLISHED
California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for
publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication
or ordered published for purposes of rule 8.1115.
IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

THIRD APPELLATE DISTRICT
(Sacramento)
----
JAROSLAW WASZCZUK, C079524
Plaintiff and Appellant, (Super. Ct. No.

34201300155479CUWTGDS)
v.
REGENTS OF THE UNIVERSITY OF

CALIFORNIA et al.,
Defendants and Respondents.
Although Jaroslaw Waszczuk, a self-represented plaintiff, purports to appeal the

trial court’s order granting five individual employees of the University of California’s
special motion to strike (Code Civ. Proc., § 425.16) four causes of action arising from
their involvement in his termination, he does not argue the merits of the motion but
insists the judgment must be reversed because of systemic corruption including collusion
between his then lawyer, defense counsel, and the trial judge. He misunderstands his
burden on appeal, ignores the dispositive issues, provides no evidence of corruption or
untoward collusion, and fails to demonstrate either relevance or prejudice from the
1
shortcomings he cites. We need go no further than to answer the contentions he raises,
and in finding no merit in those claims, we affirm.
PRELIMINARY STATEMENT
Plaintiff, a Polish immigrant, feels deeply aggrieved by the University of
California (the University), his lawyer, the defense lawyer, and the trial judge. A brief
excerpt from a letter he sent to the general counsel for the University reflects his
bitterness as well as his belief that there is much more at stake than his mere wrongful
termination lawsuit. He wrote: “The stake in this lawsuit must be a lot bigger and more
important than the life of a 63-year-old Polish refugee who escaped communist
oppression and was promised protection from oppression in his new country by the US
government. Instead of protection from oppression, the Polish refugee received treatment
from the University of California that has been a lot worse than the treatment he received
in the Polish communist prison, where the communist’s prison guard was more respectful
to the political prisoners than UC management to its own employees.” His experience
has left him emotionally distraught. At the end of a hearing in the trial court, he
announced he was done and was going to go outside of the courtroom and shoot himself.
While plaintiff’s pain is clear, his legal analysis is not. We have carefully
scrutinized his briefs and the record in a diligent attempt to decipher his legal theories.
Much remains a mystery. We must reiterate what the trial court admonished plaintiff.
“At the outset, the Court would note that a self-represented party is to be treated like any
other party and is entitled to the same, but no greater consideration than other litigants
and attorneys. (Williams v. Pacific Mutual Life Ins. Co. (1986) 186 Cal.App.3d 941,
944.) Thus, as is the case with attorneys, self-represented litigants must follow correct
rules of procedure. Nwosu v. Uba (2004) 122 Cal.App.4th 1229, 1246-1247; see also
Rappleyea v. Campbell (1994) 8 Cal.4th 975, 984.” We add that plaintiff has an equal
responsibility to follow the California Rules of Court applicable to appeals, no matter
2
how sympathetic his claims may seem to himself or us. It is a responsibility he has
ignored to his peril.
Plaintiff’s most glaring and consistent violation of the rules is his failure to cite to
the record.1 He makes grandiose accusations against the University for illegally
generating and selling electric power and for tax evasion, but those allegations are not
supported by citations to the record and are not relevant to the special motion to strike.
Plaintiff fails to appreciate the limited scope of our review, which stands in stark contrast
to the wide-ranging allegations plaintiff lodges which are untethered to the second
amended complaint or the special motion to strike. We are compelled to ignore any
factual allegations that are not supported by citations to the record.
Plaintiff loses this appeal, but it is not the end of his lawsuit for wrongful
termination. The trial court reminded plaintiff at the hearing on the special motion to
strike that the Regents of the University of California (the Regents) were not protected if
they discriminated or retaliated against him and, therefore, “[i]ndependent of the five
individuals who are before the Court on this motion, [plaintiff] still retains his right to sue
the Regents because they are still in the lawsuit and he’s still the plaintiff.” In this
context, we recite the brief facts relevant to the issues plaintiff raises on appeal.
1 An “appellant must support all statements of fact in his briefs with citations to the
record [citation] and must confine his statement ‘to matters in the record on appeal.’
[Citation.]” (Pierotti v. Torian (2000) 81 Cal.App.4th 17, 29.) “[I]t is counsel's duty to
point out portions of the record that support the position taken on appeal.” (Del Real v.
City of Riverside (2002) 95 Cal.App.4th 761, 768.) The Court of Appeal must not search
the record on behalf of an appellant or serve as “backup appellate counsel.” (Mansell v.
Board of Administration (1994) 30 Cal.App.4th 539, 545-546.)
3
FACTS
Plaintiff worked in the University of California Davis Medical Center’s Plant
Operations and Maintenance Department for 13 years. He received many years of
favorable performance reviews. In 2007, however, he was given a disciplinary transfer
from the central plant to the HVAC/plumbing shop. He filed a grievance and ultimately
entered into a settlement agreement with the University whereby he agreed to the transfer
in exchange for a promotion to an exempt position with a more prestigious job title.
In 2011 the University again initiated an investigation of plaintiff based on
complaints that he had violated University policies by engaging in acts of ethnic
discrimination constituting hate incidents in the workplace. He was terminated in 2012.
He appealed the termination and ultimately filed a whistleblower retaliation complaint.
In this court, he fixates on his belief the University’s suspension, investigation, and
termination were nothing more than a “witch hunt” designed to remove him, preferably
by getting him to quit, and thereby enable the University to resume its alleged tax-free
illegal power sales. He asserts, again without citation to the record, the University
attempted to assassinate him.
Plaintiff filed his first complaint, in pro. per., in December 2013. The complaint
included six causes of action: wrongful termination; retaliation; the intentional infliction
of emotional distress; failure to prevent harassment, discrimination, or retaliation; breach
of the settlement agreement; and violation of the University’s Personnel Polices for Staff
Members (PPSM) 23. Plaintiff thereafter hired a lawyer, Douglas Stein, who filed a first
amended complaint on his behalf in June 2014. The first amended complaint set forth
eight causes of action, including a cause of action entitled “Breach of Written Contract.”
The written contract referred to the settlement agreement plaintiff reached with the
University to resolve his first grievance. The first amended complaint did not, however,
contain a cause of action for violation of PPSM 23.
4
In a meet and confer letter dated August 19, 2014, Michael Pott, representing the
Regents and the employees sued in their individual capacity, described a number of
deficiencies in the first amended complaint “that warrant the filing of a demurrer unless
they can be resolved by amendment.” Stein spent 10 hours reviewing the first amended
complaint and researching the law in light of the alleged deficiencies set forth in Pott’s
letter. By letter dated August 26, 2014, Stein agreed to amend the complaint in response
to those deficiencies he found legitimate and he explained why he rejected many others.
Stein prepared a second amended complaint with the same eight causes of action.
He signed the second amended complaint on September 8, 2014. Unbeknownst to him at
the time, his license to practice law was suspended on September 24, 2014, due to child
support issues that he resolved by October 7, 2014, but due to logistical aspects of the
process, the State Bar of California did not restore his license to an active status until
October 23, 2014. In the meantime, he filed the second amended complaint on
September 30, 2014.
On December 1, 2014, five defendants, Michael Boyd, Stephen Chilcott, Danesha
Nichols, Cindy Oropeza, and Brent Seifert (the individual defendants) filed a special
motion to strike the first four causes of action in the second amended complaint as a
strategic lawsuit against public participation (SLAPP) suit (hereafter referred to as the
anti-SLAPP motion). (Code Civ. Proc., § 425.16.) Stein, then unaware that plaintiff had
fired him, filed an opposition to the anti-SLAPP motion on plaintiff’s behalf. Plaintiff
did fire Stein, proceeded in pro. per., and requested an extension of time to file his own
opposition. Plaintiff filed his opposition late and exceeded the page limit. Nevertheless,
the trial court considered the entirety of plaintiff’s opposition and granted his request to
disregard the opposition filed by Stein.
On December 17, 2014, Stein filed an ex parte application for relief from the
potential defective filing of the second amended complaint. Stein explained to the court
that his license had been temporarily suspended because he had mistakenly paid the
5
wrong amount of child support for two or three months, a mistake that was quickly
rectified once he learned of it. The trial court granted Stein’s application and ruled that
the second amended complaint filed on September 30, 2014, “is deemed validly filed.”
In ruling on the individual defendants’ anti-SLAPP motion, the trial court
followed the requisite two-step process. First, the court examined the individual
defendants’ showing whether their acts were taken in furtherance of their constitutional
rights of petition or free speech in connection with a public issue. The court found the
individual defendants made a prima facie showing. The individual defendants’ speech,
the court ruled, was “made in connection with the processing, investigation, hearing and
deciding the workplace complaints filed by Plaintiff and others pursuant to University
policies.” Second, the court found that plaintiff did not sustain his burden of showing a
likelihood of prevailing on each of the elements of the four causes of action as well as
defeating the individual defendants’ affirmative defenses. The court, therefore, granted
the individual defendants’ anti-SLAPP motion.
Plaintiff appeals.
DISCUSSION
I
The Allegations
Plaintiff believes that his employer, defense counsel, the trial judge, and even his
own lawyer, are corrupt and colluded to destroy his life. These allegations, not the merits
of the anti-SLAPP motion, are at the heart of plaintiff’s appeal. He writes: “There is no
need for Waszczuk to base this appeal on the merit of the case which is important and
Clerk Transcript is speaking for itself, if the whole legal process in this case was
corrupted by the Defendants’ attorney, Michael Pott, and Waszczuk’s attorney, Douglas
Stein misconduct, and their actions against Waszczuk were approved by the Court on
September 22, 2014, and December 17, 2014.”
6
There is nothing we can decide in this appeal or write in this opinion that will
disabuse plaintiff of this fiercely held belief. He fails to understand that these very
serious allegations are not before us on appeal of the anti-SLAPP motion. We will
explain for his benefit what the record discloses to us—the utter absence of any evidence
to support even a colorable claim of misconduct by any of the lawyers or judicial officers
in this case. We will also briefly describe the procedural context in which the allegations
are made and the futility of pursuing his corruption theory against these individual
defendants. Despite the ferocity of plaintiff’s feelings to the contrary, the fact that the
second amended complaint did not contain what he hoped it would does not translate into
reversible error and the fact that his lawyer and defense counsel engaged in an interactive
process to avoid an unnecessary demurrer does not translate into corruption.
Let us begin with plaintiff’s focus on the second amended complaint. As best we
can decipher, his objection is twofold: (1) He is troubled that Stein did not pursue his
theories that the University breached the settlement agreement and failed to follow
internal policies by not providing him annual performance reviews for two years, and (2)
he accuses the trial court of improperly validating the filing when Stein’s license had
been temporarily suspended.
Both objections are irrelevant to the individual defendants’ anti-SLAPP motion,
which sought to strike only four of the eight causes of action stated in the second
amended complaint. Whether or not Stein would have expanded the second amended
complaint to include additional causes of action has no bearing on whether the four
causes of action were properly stricken. In any event, we are baffled by plaintiff’s
insistence that Stein refused to include a cause of action for breach of the settlement
agreement is belied by the language of the sixth cause of action for breach of a written
contract which appears to embody that very claim.
Plaintiff fails to cite any authority to support his claim that the trial court
improperly validated the filing of the second amended complaint. The claim lacks both
7
legal authority and evidentiary support in the record. Rather, Stein was forthright in his
disclosure to the court. When he filed the second amended complaint he was unaware
that his status with the State Bar had changed. The reason for his very brief suspension
was unrelated to his competency or ethics in the practice of law. Rather, as Stein
explained, he made an inadvertent error on the amount he paid in child support for two or
three months. His license to practice was reinstated within about two weeks of his
discovery of the suspension. On these facts, there is not the slightest hint of impropriety.
To the contrary, Stein was diligent and transparent—making an ex parte application to
assure the integrity of the document he inadvertently filed during the briefest of
suspensions for a minor transgression unrelated to his professional performance. He
should be commended, not chastised, for his fervent representation of plaintiff’s interests.
Yet plaintiff asserts that defense counsel colluded with Stein to file a second
amended complaint designed to rob him of meritorious claims. He also contends that
Stein bowed to defense counsel’s untoward pressure to amend the complaint and
subjected his pleadings to the anti-SLAPP motion. He adds the naked allegation that the
trial court acted improperly as well because the trial judge had known defense counsel for
a number of years. Plaintiff’s allegations are without evidentiary support.
The record discloses a cordial, thorough, and appropriate exchange between two
lawyers engaged in a meet and confer process designed to avoid an unnecessary
demurrer. The thoughtful letters exchanged by counsel described the legal issues
presented by the first amended complaint and the authorities upon which they relied to
support their positions. Stein relented on a few minor issues, but held steadfast as to the
viability of his theories. Plaintiff’s sheer speculation about the lawyers’ motives is totally
unsubstantiated; indeed, the record belies his accusations.
In summary, we conclude plaintiff’s accusations of misconduct, corruption, and
collusion between the lawyers and the trial court are unsubstantiated and unfounded. But
even more importantly, they are irrelevant to the sole issue properly before us on
8
appeal—whether the trial court erred by granting the five individual defendants’ anti-
SLAPP motion to strike four of the causes of action alleged against them. We turn,
therefore, to the only relevant issue presented.
II
The Merits
The anti-SLAPP statute provides: “A cause of action against a person arising
from any act of that person in furtherance of the person’s right of petition or free speech
under the United States Constitution or the California Constitution in connection with a
public issue shall be subject to a special motion to strike, unless the court determines that
the plaintiff has established that there is a probability that the plaintiff will prevail on the
claim.” (Code Civ. Proc., § 425.16, subd. (b)(1).) We review an order granting an anti-
SLAPP motion de novo. (Daniel v. Wayans (2017) 8 Cal.App.5th 367, 379.)
As explained above, the trial court engages in a two-step process in determining
whether to grant an anti-SLAPP motion. (Park v. Board of Trustees of California State
University (2017) 2 Cal.5th 1057, 1061.) In this case, the trial court found the individual
defendants made a prima facie showing to satisfy the first prong and plaintiff did not
challenge this finding in his opening brief. Belatedly in reply, he contends that the
defendants did not “show any record or evidence that the Defendants Nichols, Chilcott,
Boyd, Seifert, and Oropeza, who brought the anti-SLAPP motion to strike Waszczuk’s
first four causes of action, were made in connection with the processing, investigation,
hearing, and deciding of the workplace complaints filed by Waszczuk.”
In short, the court acknowledged that University policies and procedures have the
force and effect of a state statute (Kim v. Regents of University of California (2000)
80 Cal.App.4th 160, 165); statutory procedures qualify as official proceedings authorized
by law as contemplated by Code of Civil Procedure section 425.16 (Vergos v. McNeal
(2007) 146 Cal.App.4th 1387, 1399 (Vergos)); the constitutional right to petition includes
the act of seeking administrative action (Briggs v. Eden Council for Hope & Opportunity
9
(1999) 19 Cal.4th 1106, 1115); and investigations and investigatory reports prepared in
connection with an issue under consideration or review by an official body, such as a
public entity’s internal investigations, are protected activities under the anti-SLAPP
statute (Miller v. City of Los Angeles (2008) 169 Cal.App.4th 1373, 1383). Because the
speech of the individual defendants who were subject to the anti-SLAPP motion was
“made in connection with the processing, investigation, hearing and deciding the
workplace complaints filed by Plaintiff and others pursuant to University policies,” the
court concluded the individual defendants satisfied their burden and shifted it to the
plaintiff to demonstrate a likelihood of prevailing on the merits.
Plaintiff insists that Vergos, supra, 146 Cal.App.4th 1387, cited by the trial court,
does not support the granting of the anti-SLAPP motion. We disagree. In Vergos, an
employee of the University named the manager who denied his administrative grievance
as a defendant in his sexual harassment lawsuit in her individual capacity. (Id. at
p. 1390.) The manager filed a special motion to strike contending that her statements and
communicative conduct in handling the employee’s grievances were protected by Code
of Civil Procedure section 425.16 because “they (1) were connected with an issue under
review by an official proceeding authorized by law, and (2) furthered the right to petition
of the plaintiff and similarly situated employees.” (Vergos, at p. 1394.) We agreed and
affirmed the judgment.
We pointed out that the manager’s only conduct targeted in the complaint involved
her hearing, processing, and deciding the employee’s grievances. (Vergos, supra,
146 Cal.App.4th at p. 1396.) Similarly, here the trial court’s finding parroted our
conclusion in Vergos. And the court reviewed the allegations against each of the five
individual defendants and reported their involvement as follows:
“The allegations of the SAC [second amended complaint] against Nichols attack
her protected participation in the official investigations. The SAC specifically alleges
Nichols’ communications regarding the investigation and her investigative conclusions.
10
Nichols was appointed to investigate Plaintiff’s whistleblower complaints, and was also
appointed to conduct an investigation into complaints of workplace violence filed by
Putney and Daniliuc. All were protected petitioning activities.
“The allegations against Boyd and Chilcott are limited to their receipt of emails
from Nichols relating to the investigations, and Chilcott’s sending of an email relating to
the investigation of Plaintiff. The emails are protected speech in connection with an
investigation process.
“The allegations against Oropeza and Seifert are based upon their investigation
into the emails plaintiff sent to Nichols in April 2012. Oropeza and Seifert conducted
their investigation pursuant to the University’s grievance protocol and reached
conclusions documented in a report.
“Boyd acted as Complaint Resolution Officer (“CRO”) at Step II of the
University’s PPSM 70 process, hearing and deciding Plaintiff’s appeal of his
termination.”
In sum, each of the individual defendants, like the manager in Vergos, were
involved in the investigation, hearing, processing, and/or deciding plaintiff’s and his co-
workers’ grievances. We conclude, as in Vergos, their conduct was within the protective
ambit of Code of Civil Procedure section 425.16. Thus we must review the trial court’s
resolution of the second step in the analysis—whether plaintiff demonstrated a likelihood
of success on the merits.
Without citation to specific pages in the record or argument about the likelihood of
success of each element of the four causes of action or even a response to the trial court’s
thorough analysis, plaintiff invites us to review his 443-page opposition to the anti-
SLAPP motion and insists, again without analysis, that the evidence is “overwhelming.”
He falls miserably short of his duty on appeal to cite to the record, to present cogent
argument, and to support his argument with applicable legal authority. In this vacuum,
we turn to the trial court’s statement of decision wherein the court provides a brief and
11
apt rationale for finding plaintiff did not sustain his burden of showing a likelihood of
prevailing.
Plaintiff’s first cause of action for the intentional infliction of emotional distress
fails because the tort requires a showing of outrageous conduct beyond the bounds of
human decency. The court found “[w]hat plaintiff has alleged, and what his evidence in
opposition appears to support, are complaints concerning personnel management by
defendants. Pleading of personnel management activity is ‘insufficient to support a claim
of intentional infliction of emotional distress, even if improper motivation is alleged.’
(Janken v. [GM Hughes Electronic (1996)] 46 Cal.App.4th [55,] 80.)” We agree with the
trial court that none of the allegations against these individual defendants involved in the
investigation and resolution of the grievances constitutes the type of outrageous conduct
beyond the bounds of human decency necessary to prevail on a claim of the intentional
infliction of emotional distress.
Plaintiff is unable to surmount the basic principle of law that an employee or
former employee cannot sue a current or former supervisor or employee for interfering
with his or her prospective economic advantage by inducing the employer to terminate
the plaintiff’s employment. (Shoemaker v. Myers (1990) 52 Cal.3d 1, 24; Shepperd v.
Freeman (1998) 67 Cal.App.4th 339, 347.) On this basis, the trial court properly
concluded plaintiff failed to provide any countervailing authority or analysis as to why
the facts before the court show the likelihood of prevailing on his interference with
prospective economic advantage cause of action.
Plaintiff’s discrimination claim meets another definitive legal obstacle. Individual
defendants cannot be sued for discrimination under the Fair Employment and Housing
Act (FEHA), nor can they be sued for failing to prevent discrimination, retaliation, and
12
harassment. (Reno v. Baird (1998) 18 Cal.4th 640, 663-664;2 Janken v. GM Hughes
Electronic, supra, 46 Cal.App.4th at p. 63.) Plaintiff has not shown any likelihood of
surmounting this obstacle.
Finally, the trial court found that plaintiff did not establish that the individual
defendants’ conduct was in retaliation for his whistleblowing. The court explained: “The
mere fact that Nichols, Oropeza and Seifert conducted investigations and reached
conclusions with which Plaintiff does not agree with does not establish their investigatory
findings are an act of retaliation. Nor can Boyd’s decision to deny Plaintiff’s grievance at
the Step II level of PPSM 70 review be deemed to be a retaliatory action. Finally, there is
no allegation that Chilcott took any particular action against Plaintiff that could be
deemed to be a retaliatory action.” In the absence of any evidence or analysis provided
by plaintiff, we have no basis for reaching a finding at odds with the trial court. Plaintiff
has not shown a likelihood of prevailing on a whistleblower retaliation cause of action.
(Gov. Code, § 8547.10.)
III
Plaintiff maintains he should have been allowed to amend his complaint for the
third time. As support he cites cases involving demurrers, not special motions to strike a
SLAPP. His authorities, therefore, are inapposite. The anti-SLAPP statute makes no
provision for amending the complaint once the court finds the targeted conduct is
protected speech. (Simmons v. Allstate Ins. Co. (2001) 92 Cal.App.4th 1068, 1073.)
2 After Reno v. Baird, supra, 18 Cal.4th 640 was decided “the California Legislature
amended FEHA's harassment provision expressly holding individual employees liable for
their harassment.” (Scott v. Solano County Health & Soc. Orders Servs. Dep't (E.D. Cal.
2006) 459 F.Supp.2d 959, 966, citing Gov. Code, § 12940, subd. (j).) There is no
harassment claim targeted by the individual defendants’ anti-SLAPP motion.
13
DISPOSITION
The judgment striking the four causes of action against defendants Nichols,
Oropeza, Seifert, Boyd, and Chilcott is affirmed. The parties shall bear their own costs
on appeal. (Cal. Rules of Court, rule 8.278(a)(5).)
RAYE , P. J.
We concur:
NICHOLSON , J.
ROBIE , J.
14
ATTACHMENT # 2
1 JAROSLAW WASZCZUK,
2 Lodi, CA 95242
Telephone: (209) 663-2977
3 Facsimile: (209) 370-8281
E-Mail: ucdmclaborchat@att.net
4
Plaintiff IN PRO PER -JAROSLAW (“JERRY”) WASZCZUK
5
7 DRAFT
8
10 SUPERIOR COURT OF CALIFORNIA

11 IN AND FOR SACRAMENTO COUNTY
12 )
JAROSLAW (“JERRY”) WASZCZUK, ) Case No.: 34-2013-00155479
13 )
Plaintiff, ) Complaint- Wrongful Termination-
14 ) Employment:
vs. ) UNLIMITED CIVIL
15 )
THE REGENTS OF THE UNIVERSITY OF ) COMPLAINT FOR DAMAGES
16 CALIFORNIA, UNIVERSITY OF )
CALIFORNIA DAVIS HEALYH SYSTEM, ) 1) BREACH OF CONTRACT,
17 UC DAVIS MEDICAL CENTER, UC DAVIS, ) 2009- Settlement –Agreement
ANN MADDEN RICE, MIKE BOYD, ) 2) VIOLATION OF THE HEALTH &
18 STEPHEN CHILCOTT, CHARLES ) SAFETY CODE SECTION 1278.5
WICHTER, DANESHA NICHOLS, CINDY )
19 OROPEZA, BRENT SEIFERT, PATRICK ) JURY TRIAL DEMANDED
PUTNEY, DORIN DANILIUS, and does 1 )
20 through 50, inclusive, )
)
21 Defendant. )
)
22 )
)
23 )
24
25
I. PREAMBLE & NATURE OF THE CASE
26 A. The shocking facts of this case would continue to frustrate and anger
27 Plaintiff and for sure will surprise the Court and Jury after they learn from Plaintiff’s wrongful
28
WRONGFUL TERMINATION COMPLAINT-EMPLOYMENT

Page 1 of 2
1 termination complaint something completely different about the Defendant, the Regents of the
2 University of California (hereafter Defendant). The Court and the Jury will learn from Plaintiff’s,
3 Jaroslaw Waszczuk’s (pronounced Yaroslav Vashchook) (hereafter Plaintiff), wrongful
4 termination complaint that the perfect image of the University of California was created because
5 of the exceptional and outstanding education system that is globally recognized.
6 The Court and Jury also will learn from Plaintiff’s wrongful termination complaint
7 and will be shocked and surprised that the Defendant, to preserve this perfect, globally recognized
8 image of the University of California, would not hesitate to give orders to their officers and agents
9 to provoke and assassinate their own employee, the 61-year-old Plaintiff, using the university
10 police force. It happened on May 31, 2012, because Plaintiff became the subject of the Defendant’s
11 suspicious six-year-long paranoia that Plaintiff knew about the Defendant’s and the Defendant’s
12 agents and officers’ misconduct, corruption, unlawful business practices and criminally minded
13 activities in relation to the UC Davis Medical Center Central Plant operation, where Plaintiff
14 worked from 1999 to 2007, and that Plaintiff would disclose this information to federal authorities.
15
B. The Court and the Jury will freeze in stunned disbelief, mouths agape, when they
16
learn that the Defendant create, encourage, and maintain a climate and culture in which managers,
17
supervisors, human resource personnel, investigators, executive directors, police officers, and
18
senior officials consistently, invariably, and repeatedly undertake actions to retaliate, harass, abuse,
19
and bully any staff who formerly or informally reports misconduct, discrimination, harassment,
20
and/or abuse.
21
C. They act embolden and brazen in fabricating investigations, fabricating reasons for
22
the adverse employment actions, constructing biased reports with knowledge the report will be
23
considered evidence, not interviewing key witnesses even though reports refer to statements
24
(claimed to be destroyed) from those un-interviewed witnesses. Literally, Federal government
25
investigators, union presidents, human resource consultants, journalists, and many other credible
26
professionals have been and continue to be incensed, outraged, and frustrated by the climate and
27
culture at University of California that thumbs their noses at the very laws they are supposed to
28

Page 2 of 3
1 enforce. The unlawful conduct of these self-expressed guardians and protectors of the law is,
2 almost without exception, accepted, condoned, and/or ratified up through to the highest paid and
3 highest ranking positions within the UC system.
4 D. By all metrics and parameters, the cabal and actions of these ‘people’ in furtherance
5 of it against the liberty interests of Plaintiff, as well as the best interests of University of California
6 is heretofore without equal in the mounting number of wrongful termination cases filed against
7 Defendant . This case demonstrates Defendant, by and through its managers, supervisors, and more
8 senior officials, knowingly violate the mandate of their own procedures and intentionally deprive
9 employees of due process.
10 E. In this matter, they set about to emotionally harm and extract from the workplace
11 61 old Plaintiff who, from 1999 to approximately April 2011, supervisors, including the main
12 complainer, described as an outstanding, responsible, dependable, and loyal employee of the
13 University of California. His yearly evaluations invariably described him as a very valuable
14 employee, that he could be counted on to make the right operational decisions, that he is very
15 conscientious and thorough, and dedicated to the future success of the University of California .
16 Plaintiff performed his job flawlessly without every receiving a complaint of any kind
17 F. This case establishes that Defendant have, unilaterally and of their own volition,
18 abandoned and discarded their obligations, responsibilities, and mandated duties as set forth in the
19 written, but not followed, Policies and Procedures Staff Manual (PPSM) and the written, but not
20 followed, Whistleblower Protection Policy. The Defendant, unilaterally and of their own volition
21 rendered illusory and inactive the policies and procedures written and intended as a fair, impartial,
22 and reasonable process to resolve challenges to adverse employment actions. Therefore, any
23 public policy interests favoring Defendant’s policies and procedures are minimal at best. Whereas
24 the actions, behavior, and conduct of the Defendant, Defendant’s managers, supervisors, and
25 senior officials are so repugnant, so unlawful and so improper, that public policy and the interests
26 of a safe, healthy, and well run hospital facility heavily outweigh the policies and procedures does
27 not see fit to follow. A cursory review of civil complaints filed in Federal Court and State Court
28

Page 3 of 4
1 over the recent few years demonstrates a significant number of complaints, with every one of them
2 alleging the same thing, retaliation for whistleblowing without any meaningful, fair, impartial, or
3 just procedures that allows a finding that the people supposedly implementing the fair procedures
4 are actually undermining, discriminating, and retaliating against the whistleblower in abusive,
5 destructive, and deceitful ways. A message must be sent to Defendant to force the Defendant to
6 change, to force them to understand they cannot hold the law up in one hand and actually use an
7 unlawful, very harmful, and concealed weapon hidden in their other hand. Too many people have
8 been hurt, have died, and will die if the judiciary does not take this opportunity to change our
9 community, our City, our area, and out State for the better.
10 G. Plaintiff primary duties were no small or trivial matters. To the contrary, Plaintiff
11 was solely responsible from June 1999 to March 2007 for operation and maintenance of the 27
12 MW cogeneration power plant in which provides utilities for the UC Davis Medical Center ,
13 In February 2009 Plaintiff was promoted to the position of the Associate Development Engineer
14 in UC Davis Medical Center HVAC shop and was responsible for operating UC Davis Medical
15 Center Metises Control System which is used to monitor and dispatch critical alarms in the
16 Medical Center , to detect, identify, and locate malfunctioning, failed, and/or failing machinery
17 and equipment, such as air conditioning units, heating units, refrigeration units, freezer units,
18 elevators, generators, and a host of other machines necessary and vital to the health, safety, and
19 welfare of patients and . Beside the above Plaintiff was responsible to back up servers, repair
20 computers if needed and review and close the work orders for HVAC shop crew.
21 II. PARTIES
22 Plaintiff
23 1. Plaintiff JAROSLAW WASZCZUK , and was at all relevant times, a resident of
24 the City of Lodi, and County of San Joaquin, California.
25 Plaintiff has been a Polish citizen in exile since November 1982. Plaintiff has lived and
26 worked in the United States in four different states. Plaintiff is 64 years and has been married for
27 43 years. Plaintiff has never broken any laws in this country. Both of Plaintiff’s children have four-
28

Page 4 of 5
1 year college degrees. They have both received honorary awards from two different presidents of
2 the United States of America for superior achievement in school. Plaintiff daughter Joanna was
3 given an award by President Ronald Reagan, and Plaintiff’s son George received an award from
4 President Bill Clinton.
5 Plaintiff holds and two years college degree in power plant operations, electric power
6 generation and management, and Plaintiff was trained and certified over the course of his
7 employment in Poland and in three different states of the US to maintain and operate different
8 power plants. Plaintiff was trained and certified to maintain and operate power plants which using
9 different types of fuel, including coal fire, biomass, natural gas and diesel, and different types of
10 turbines, like frame and jet engines and steam turbines. Plaintiff also knows about plumbing trade
11 and knows how to repair computers. Plaintiff speaks and writes three different languages. Plaintiff
12 was forced to leave Poland, his native country, by the Polish communist regime due to Plaintiff’s
13 involvement in struggle and u uprising against communism and Soviet domination in 1980-1981.
14 Defendant
15
16 2. THE REGENTS OF THE UNIVERSITY OF CALIFORNIA are, and were

17 at all relevant times, the governing body of the University of California system, deriving its
18 creation, powers, and authority from the California Constitution. UC Davis, University of
19 California Davis Health System, and UC Davis Medical Center are not legally recognized as
20 entities separate from THE REGENTS UNIVERSITY OF CALIFORNIA and therefore cannot
21 be sued or sue in their own right. However, UC Davis is a sub-organization of THE REGENTS
22 UNIVERSITY OF CALIFORNIA that is, and was at all relevant times, tasked with, among
23 other responsibilities, implementing, supervising, and managing daily, short-term, and long-
24 term operations for the University of California Davis Health System, UC Davis Medical Center
25 and outpatient medical clinics. The University of California Davis Health System is a sub-
26 organization of THE REGENTS UNIVERSITY OF CALIFORNIA and UC Davis existing as
27 an administrative office tasked with implementing, supervising, and managing daily, short-term,
28

Page 5 of 6
1 and long-term operations for UC Davis Medical Center and outpatient medical clinics. UC
2 Davis Medical Center is a sub-organization of THE REGENTS UNIVERSITY OF
3 CALIFORNIA and UC Davis existing with responsibility for implementing, supervising, and
4 managing daily, short-term, and long-term operations for an in-patient and out-patient health-
5 care facility, regional trauma center, medical research facility, and teaching hospital. Each
6 sub-organization is structured and holds itself out to the public as separate but associated
7 entities. Therefore, allegations and references in this complaint to “Plaintiff’s employer”,
8 “employer”, “medical center”, UC Davis and/or UCD mean and include THE REGENTS OF
9 THE UNIVERSITY OF CALIFORNIA and its sub-organizations.
10 3. Defendant , the Regents of the University of California reside in Oakland ,
11 California.
12 4. The true names and capacities of DOES 1-50, inclusive, are presently unknown to
13 Plaintiff and therefore sues these Defendants by such fictitious names. Plaintiff will amend this
14 complaint to allege their true names and capacities when they have been ascertained.
15 5. Plaintiff is informed and believes, and based on such information and belief, alleges,
16 that Defendant sued herein, including DOE Defendants, were at times acting as the agent or
17 employee of each of the other Defendant and, in doing some of the acts alleged herein, was acting
18 within the course and scope of such agency and/or employment.
19 6. In doing the intentional acts herein alleged, the Defendants sued herein by real or
20 fictitious name were, at the time of the intentional acts, acting outside the course and scope of their
21 employment. The Defendants sued herein by real or fictitious name, in the commission or
22 intentional omission of the alleged intentional acts, were in the course and scope of pursuing the
23 ends of an agreed upon result, an express or implied agreement to achieve a desired injurious result,
24 and/or otherwise aided, abetted, cooperated with, and/or conspired with one another to do the acts
25 alleged herein.
26 COMES NOW PLAINTIFF, JAROSLAW PLAINTIFF, and alleges:
27
28

Page 6 of 7
1 III. JURISDICTION and VENUE
2
3 7. Plaintiff and Defendant, in February 2009, the Regents of the University of

4 California entered into a written contract entitled Settlement- Agreement. The Defendant, the
5 Regents breached and violated the signed Settlement-Agreement, as hereinafter alleged, within
6 Sacramento County.
7 8. Defendant, the Regents of the University of California, per the 2009 Settlement -
8 Agreement signed with Plaintiff, agreed to employ Plaintiff infinitely as an Associate
9 Development Engineer at the UC Davis Medical Center HVAC Shop with an annual salary of
10 $70,000.00.
11 9. The great majority of the acts alleged herein occurred or took place in Sacramento
12 County. The individuals sued herein by Doe committed the great majority of actionable and
13 intentional acts in Sacramento County.
14 10. As described and alleged herein, as early as April 2011, the Defendant without any
15 warning and in bad spirit disregarded breached and violated entirely the signed 2009 Settlement-
16 Agreement with Plaintiff.
17 11. As described and alleged herein, the Defendant in complete disregard to the signed
18 2009 Settlement- Agreement and with malice orchestrated a one-and-and-a-half year-long,
19 despicable and unthinkable to any normal person, witch hunt campaign against Plaintiff and his
20 coworkers
22 Settlement- Agreement with Plaintiff, Plaintiff’s outstanding employee record, Plaintiff’s age,
23 Plaintiff’s health condition, state and federal law, the University of California policies and
24 procedures, the Defendant in a maliciously orchestrated one and one and half year witch hunt
25 campaign, the Defendant and in their own madness and desperation to cover up their own
26 misconduct and wrongdoings made an attempt on May 31, 2012 to provoke and kill Plaintiff or
27 end Plaintiff’s employment at UC Davis Medical Center Trauma Unit # 11, by a specially
28

Page 7 of 8
1 assembled team nick named by Plaintiff in documents as HR Death Squad or the UC Davis Death
2 Squad.”
3 13. As described and alleged herein, the Defendant wrongfully terminated Plaintiff‘s
4 employment on December 7, 2012, with full disregard and violation of the signed Settlement-
5 Agreement after an unsuccessful attempt to provoke and kill Plaintiff on May 31, 2012.
6
14. As described and alleged herein, the actions made by the Defendant, in breeching
7
and violating the signed 2009 Settlement-Agreement, resulted in wrongful and unlawful
8
termination of Plaintiff’s employment on December 7, 2012, which additionally caused Plaintiff
9
enormous destruction of his livelihood and financial losses.
10
15 In the months of April, May, June, and July 2011, the Defendant with full disregard
11
of the February 2009 Settlement- Agreement signed by Plaintiff with Defendant and with full
12
premeditation and disregard of UC Davis Policy PPSM 23 and PPSM 62and UCDMC Policy 1616,
13
singled out Plaintiff for termination of employment by ordering that Plaintiff should not be
14
provided with the Annual Performance Review (Evaluation), outlining Plaintiff’s job performance
15
for 2010/2011 which was mandated by UC Davis Policy PPSM 23, , and deprived Plaintiff of any
16
possibility to utilize administrative remedies to resolve the dispute under UC Davis Policy PPSM
17
70.
18
The Annual Performance Reviews (Evaluations) are the most important documents in the
19
employee–employer relationship; Jensen v. Hewlett-Packard Co., 14 Cal. App. 4th 958, 18 Cal.
20
Rptr. 2d 83 (Cal. Ct. App. 1993)
21
16. As described and alleged herein, the Defendant, by despicably breaching and
22
violating the 2009 Settlement -Agreement signed with Plaintiff, ultimately waived and lost for
23
themselves all legal rights not to be sued in the State of California Courts of law, pursuant to
24
California law, for the laws violated by the Defendant as described and entitled in, but not limited
25
to, the included the Settlement-Agreement sections: PURPOSE OF AGREEMENT; LOST WAGE
26
CLAIM; RELEASE OF ALL CLAIMS RELEASED CLAIMS;COVENANT NOT TO SUE;
27
28

Page 8 of 9
1 WITHDRAWAL OF PENDING DISPUTES; SECTION 1542 RIGHTS WAIVED; OLDER
2 WORKERS BENEFITS PROTECTION ACT;
3 17. As described and alleged herein, the 2009 Settlement - Agreement was made and
4 entered into in the State of California and shall in all respects be interpreted and enforced in
5 accordance with California Law pursuant to the Settlement- Agreement, section No. 20.
6
18. As described and alleged herein, the Settlement-Agreement may not be modified
7
except by written amendment, characterized as such, and signed by the parties pursuant to the
8
Settlement-Agreement, section No. 16, which is entitled MODIFICATIONS IN WRITING
9
ONLY
10
Plaintiff complied, or substantially complied, with administrative processes and procedures then
11
in place for each cause of action associated with said administrative process or procedure. As to
12
each cause of action alleged herein pursuant to California’s “Whistleblower” statute, Plaintiff
13
alleges that he timely filed a complaint with the person identified by UC DAVIS as being the
14
person UC DAVIS designated to receive such complaints; UC DAVIS accepted the complaint;
15
UC DAVIS had 120 days to act on and/or issue a decision on Plaintiff’s complaint, unless UC
16
DAVIS notified Plaintiff that they extended the time; UC DAVIS issued two extensions of 60 days
17
each for UC DAVIS to act on the complaint; the most recent extension expired on January 31,
18
2014; it has been more than 120 days since the most recent deadline lapsed without a response
19
from UC DAVIS.
20
19. With respect to the remaining causes of action Plaintiff alleges he complied with,
21
complied, with administrative process or procedures and exhausted said administrative processes
22
or procedures. As an additional matter or as an alternate allegation, Plaintiff invokes the due
23
process clauses of the United States Constitution and the California Constitution. Plaintiff is
24
informed and believes and thereon alleges that the due process clauses excused Plaintiff from
25
initiating, continuing, and/or adhering to any and all aspects of the alleged administrative processes.
26
Plaintiff, as an employee of the UC DAVIS, had at all relevant times a “liberty” or “property”
27
interest in his job. Defendant denied Plaintiff his due process rights by virtue of ignoring,
28

Page 9 of 10
1 discarding, and/or disregarding critical aspects of their rules, processes, and procedures.
2 Defendant ignored, discarded, and/or disregarded their rules, processes, and procedures as they
3 concern a fair, impartial, and unbiased investigation, as they concern the retention and availability
4 of evidence, as they concern the prohibition against utilizing investigatory leaves as a subterfuge
5 to delay the process and to annoy, harass, and intimidate Plaintiff, and in other ways not yet known
6 or not yet knowable. These rules, processes, and procedures are, and were, in place to provide
7 employees, such as and including Plaintiff, a fair, equitable, and just opportunity to challenge or
8 contest the accusations leveled against him. By virtue of the foregoing, the allegations contained
9 herein, and the evidence adduced in court, Plaintiff’s due process rights require a finding that
10 Plaintiff is, and was, excused from initiating, following, and/or exhausting any employer
11 administrative policies and procedures for all actionable conduct in this action because defendants
12 with malice and complete disregard of it is own policies and rules deprived Plaintiff of available
13 administrative remedies to resolve the conflict.
14
IV. THE STATEMENT OF FACTS
15
16 The Perfect Image of the University of California

17
20. The University of California is governed by the Board of Regents. It has 10
18
campuses, a combined population of 238,700 students, 19,700 faculty members, 135,900 staff
19
members and over 1.6 million living alumni.. Seven of its undergraduate campuses are ranked
20
among the top 100, six among the top 50, and two among the top 25 U.S. universities for 2015,
21
public or private, according to U.S. News & World Report. Among public schools, two of its
22
undergraduate campuses are ranked in the top 5 (UC Berkeley at 1 and UCLA at 2), five in the
23
top 10 (UC San Diego at 8, UC Davis at 9, and UC Santa Barbara at 10), and all except the
24
newly opened UC Merced are in the top 100 (UC Irvine at 11, UC Santa Cruz at 35, UC
25
Riverside at 55, according to U.S. News & World Report rankings 2015[5]). UC Berkeley is
26
ranked third worldwide among public and private universities and two others—UCLA and UC
27
San Diego—are ranked among the top 15 by the Academic Ranking of World Universities
28

Page 10 of 11
1 21. Plaintiff was employed by the Defendant, the Regents of the University California
2 (hereafter “Defendant”) with the University of California, Davis, Medical Center in Sacramento,
3 California, from June 1999 as a cogeneration power plant operator and associate development
4 engineer. Plaintiff’s employment was wrongfully and without a valid cause terminated by the
5 Defendant in December 2012 after 13 years of service and at the age of 61.
6 22. Besides regular duties at the UC Davis Medical Center, Plaintiff occasionally
7 provided representation or assistance for non-union employees and, on two occasions, for union-
8 represented employees in their complaints filed under the provision of UC Davis Policy PPSM
9 70 and the UC Davis Whistleblowing Retaliation Protection Policy PPM 380-17.
10 23. Plaintiff, in the course of his employment with the UC Davis Medical Center,
11 noticed, observed, and experienced by representing other employees, many publications, and his
12 own experiences that the Defendant created two different climates and images of the University
13 of California campuses.
14 The perfect image of the University of California is the exceptional and
15 outstanding education system that is globally recognized.
16 The Different Image of the University of California
17 24. As early as 2000, a climate and culture existed at the employer’s medical center in
18 Sacramento and its university campus in Davis that subjected staff to a hostile work environment,
19 including but not limited to, sustained abuse, bullying, discrimination, retaliation for
20 whistleblowing, harassment of all kinds, intimidation, favoritism, nepotism, health and safety
21 violations, falsification of documentation, fear of retaliation for reporting misconduct, and research
22 misconduct.
23 25. As early as 2000, the employer published rules, procedures, and policies that
24 express, claim, and state that the employer is committed to a culturally diverse and otherwise
25 lawful and healthy environment. The employer’s rules, procedures, and written material espouse
26 cultural diversity, promotion of a safe workplace, no tolerance for bullying or abuse, no tolerance
27 for exclusion or discrimination, and open disclosure without retribution for reporting report waste,
28 fraud, abuse of authority, violation of law, or threat to public health.

Page 11 of 12
1 26. In truth and in fact, the employer aided, helped, allowed, and/or directly caused a
2 climate and culture of harassment, abuse, intimidation, and retaliation. The employer did not
3 implement, follow, and/or adhere to the substance of the employer’s written procedures, rules, and
4 policies. Consequently, UC DAVIS’ lack of enforcement of their policies rendered their rules,
5 procedures, and processes ineffective, defective, and illusory.
6 27. The employer allowed and/or contributed to the illusion of a harmonious workplace
7 that promoted resolution of workplace disputes in a fair and reasonable manner without harassment,
8 abuse, intimidation, or retaliation. Further, the employer allowed and/or contributed to the illusion
9 that promoted open disclosure without retribution for reporting waste, fraud, abuse of authority,
10 violation of law, or threat to public health.
11 28. The following represents some of the evidence of the employer’s climate and
12 culture of sustained abuse, bullying, discrimination, retaliation for whistleblowing, harassment of
13 all kinds, intimidation, retaliation, favoritism, nepotism, health and safety violations, falsification
14 of documentation, fear of retaliation for reporting misconduct, and research misconduct;
15 a) In May 2000, Plaintiff became involved in a UC Davis Medical
16 Center Integrated Access Unit case as an advisor to employees who
17 were abruptly removed from their jobs. Four workers became the
18 target of vicious and unscrupulous retaliatory action by management
19 for complaining about the safety issues in the department. They
20 were escorted off campus, suspended without pay, and placed on
21 investigatory leave. One of the complaining workers was accused of
22 serious misconduct and received a letter of dismissal. Assembly
23 Member Sarah Reyes, State Senator Deborah V. Ortiz and
24 Assembly Member Darrell Steinberg intervened with UC Davis
25 Chancellor Larry Vanderhoef and brought four suspended
26 employees back to work;
27 b) In 2000, Plaintiff communicated to his manager that there were
28

Page 12 of 13
1 serious safety issues with risks of serious injury or death related to
2 safe operation of the central plant. Plaintiff ultimately had to report
3 the serious safety problems to CAL/OSHA. CAL/OSHA inspected
4 the plant and issued citations. The employer fixed the safety risks
5 only after CAL/OSHA issued citations. During the course of this
6 events, Plaintiff’s manager stated "Somebody will give this Polack
7 a bad evaluation and will fire him”
8
9 29. The other not-so-perfect image of the University of California that is far less
10 recognized is the violent, discriminating uprisings on the UC campuses. The violation of

employees’ civil and human rights is internally notorious although nobody externally would
11
believe it because of this entity’s outside image. It is a normal procedure for the University of
12
California administration and management to threaten workers beyond human decency if an
13
employee dares to complain about anything.
14
30. For fiscal year 2015–2016, the UC Regents allocated $24,742,000 for
15
employment practices liability to pay and conceal its discrimination and violation of employee
16
civil and human rights, rather than spending this huge amount of financial resources to hire
17
qualified job managers and supervisors and for proper training to supervise personnel. The list of
18
Defendant’ violations of employees’ civil and human rights, fraud, provocations, and unpunished
19
criminal activities and cover-ups is lengthy and has long history.
20
31. The enormous $22,500,000 fine for Medicaid and Medicare fraud committed by
21
five University of California medical centers
22
32. In 2003, tens of thousands of students were suddenly struck with tuition increases.
23
A class action lawsuit was filed on behalf of 56,864 students who enrolled prior to 2003 in
24
professional majors and students enrolled in the spring and summer 2003 sessions whose tuition
25
was raised after they had already received bills for a lower fee. The lawsuit claimed breach of
26
contract related to fee increases. A San Francisco judge has ruled that the University of
27
California must pay a $33.8 million class action settlement.
28

Page 13 of 14
1 33. In November 2003, $ 18 million settlement has been reached in the class action
2 lawsuit filed on behalf of 3,200 female employees that alleged that the controversial ranking
3 system for most of the lab's administrators, clerical staff and technicians was discriminatory, and
that they were working longer hours for less pay
4
34. In July 2004 a $1.3 million settlement has been reached in the discrimination
5
lawsuit filed by former medical intern David Dixon who alleged that he was dismissed from
6
UCLA's family medicine residency program in 1994 because he is black.
7
8
35. A class action lawsuit was brought against Los Alamos National Laboratory,
9
claiming that the University of California, which ran the laboratory from 1943 until 2006,
10 discriminated against women and Hispanics in pay, promotions, and educational opportunities.
11 As part of a settlement reached in mid 2007, a federal judge ordered a $16.4 million payout.
12 36. In 2007 Karen Moe Humphreys, a former Olympic gold medal swimmer who
13 became a coach and administrator at UC Berkeley, brought a gender discrimination lawsuit
14 against the university. The suit claimed that Humphreys, who worked at UC Berkeley from 1978
15 until she was laid off in 2004, allegedly lost her job in retaliation for complaining about the
16 treatment of women by the university's athletic department. The university denied Humphreys'
17 allegations. It also denied her claim that her layoff was unlawful, though it did agree to pay more
18 than $3.5 million to settle the gender discrimination lawsuit she brought against them. As part of
19 the agreement, Humphreys will be reinstated and then retire in January 2008 when she reaches
20 30 years with the university.
21 37. The imposed penalty $82,500 and proposed imposition of civil penalty in the
22 amount of $220,000 by the U.S. Department of Labor was for the establishment of an
23 unauthorized nuclear facility by the University of California-operated Los Alamos National
24 Laboratory.
25 38. In September 2005, the U.S. Department of Agriculture charged the university
26 with 61 violations of the Animal Welfare Act. The lawsuit claimed UC San Francisco
27 researchers kept animals in dirty cages and over bred them as well as improperly anesthetized
28

Page 14 of 15
1 sheep and kept poor records of monkey studies. The university has agreed to pay the U.S.
2 government a $92,500 fine for alleged violations
3 39. A lawsuit was filed in 2006 by the Coalition for Limiting University Expansion
4 and later joined by the city of Santa Cruz against the University of California, Santa Cruz. The
5 lawsuit accused the campus and its contractor of violating the federal Clean Water Act by
6 allowing water polluted with sediment to migrate from several construction sites into nearby
7 creeks, ponds and groundwater. In a settlement reached, the city and university agreed to revive a
8 stalled project to reduce sediment runoff into the city's Pogonip park, 640 acres of open space
9 below the campus, and ultimately into the San Lorenzo River. UCSC, under the agreement, will
10 pay $110,000 to restore damaged gullies in the Pogonip, UCSC's building company Devcon
11 Construction will contribute engineering and construction services valued at $40,000, and the
12 city will chip in $90,000.
13 40. Michael Burch worked as a wrestling coach for the University of California Davis
14 from 1995 through 2001. In April 2001, Arezou Mansourian and Chris Ng were removed from
15 the team. Burch publicly supported the two female wrestlers when they filed a claim with the
16 Department of Education's Office of Civil Rights. One month later, Burch was informed that he
17 would no longer be retained. He filed a wrongful termination lawsuit claiming the school failed
18 to renew his contract because of his outspoken support for the two female wrestlers. In 2005, the
19 Supreme Court found that the Title IX law protected whistleblowers from adverse action of
20 employers. Michael Burch will receive $725,000 from the University of California to settle the
21 retaliation lawsuit.
22 41. Further, the U.S. Department of Labor proposed the imposition of a civil penalty
23 in the amount of $159,375 for radiological contamination committed by the University of
24 California-operated Lawrence Livermore National Laboratory;
25 42. Anneliese Yuenger died in 1999 at age 82; her family donated her body to the
26 university's medical school. A month later, Yuenger's ashes were returned to the family in a
27 plastic bag. An investigation revealed the ashes came from miscellaneous body parts burned
28

Page 15 of 16
1 several months prior to Yuenger death. An internal review exposed that the university could not
2 determine the final destination of more than 300 bodies donated between January 1995 and
3 August 1999. The University of California Board Of Regents agreed to pay a $500,000
4 settlement to the Yuenger family. The former director's business partner, Christopher Brown, has
5 also agreed to pay the family a $200,000 settlement.
6 43. The amount of $ 5,113,098 was a settlement with the U.S. Department of Justice
7 for the University of California’s Art History Department discrimination against Meribeth
8 Graybill and violation of the Civil Rights Act of 1964. Donna McDaniel, who committed suicide
9 after years of enduring what she considered to be a hostile work environment at UC Davis,
10 44. In February 2001, the Sacramento News and Review (SN&R) article entitled
11 “Standing Up to Bullies” quoted University of California, Davis, employee Jackie Quigg’s letter
12 she sent to an SN&R editor: “I felt bullied, belittled, discriminated powerless and angry.” Jackie
13 Quigg wrote of her experience of working for 13 years in the Ophthalmology Department at the
14 UC.
15 Plaintiff commented with words from Jackie Quigg’s experience in his
16 letter to an SN&R editor dated: February 10, 2001
17 “ Th e ab u sive b e ha v io r mu st b e witn e sse d an d we ll d oc u me n ted
18 in order for this to work. The other issue is that coworkers may be hesitant to
19 testify in court against an employer, the same employer who provides them a
20 paycheck. The fear of a backlash against those who testify is real.
21
Unfortunately, this great dependency for this paycheck will inhibit justice from
22
ever being served and the employer knows this. The power of employer
23
intimidation with no recourse on the part of the employee is in and of itself, the
24
very foundation for an abusive UC employer-employee work relationship. I
25
would like to ask Ms. Quigg if this situation still exists or was it resolved. I
26
need to know because it is hard to believe that anybody could cope with this
27
abuse and humiliation for 13 years. Is this is a true story?”
28

Page 16 of 17
1 Plaintiff’s employment was abruptly terminated after 13 years of abuse and
2 humiliation five years before his retirement at age 61. Jackie Quigg’s 13-year
3 story of abuse was a true story. Unbelievable. The SN&R article also
4 mentioned another story about UC Davis employee Donna McDaniel, who
5
committed suicide after years of enduring what she considered to be a hostile
6
work environment at UC Davis.
7 Police say it was around 3 a.m. on March 16, 2000, when McDaniel stood in
the garden of her gated front yard, leaned the “UC Davis Burnout” sign
8 against a tree, placed the .38 to her right temple, and ended her life.
9
“In making the sign and in using a gun to kill herself (few women who commit
10
suicide use a gun), Dickerson and others say it seems clear that McDaniel
11
wanted to use her death to make a statement.”
12
29. UC Davis Medical Center cogeneration power plant worker Todd Goerlich’s
13
suicide in December 2010 caused by the hostile working environment in the UC Davis Medical
14
15 Center is still unresolved and never was investigated. Todd Georlich’s suicide ten years after UC
16 Davis employee Donna McDaniel tragically took her life is the path of destruction chosen by a
17 pathologically dysfunctional institution run by arrogant and ruthless administrators at the
18 University of California’s ten different campuses.
19 30. UC San Francisco employee Mary Efferen wrote of her "observations and
20 experiences of faculty-staff interactions that were textbook examples of how to humiliate
21 individuals in front of group.
22 31. The University of California, which has contributed so much to the education and
23 the wealth of the state of California and the global community, is a pathologically dysfunctional
24 institution run by arrogant and ruthless administrators," wrote former UC Davis graduate student
25 Leuren Moret.
26 32. The U.S. Department of Labor imposed a civil penalty in the amount of
27 $1,707,000 by the U.S. Department of Energy for multiple violations of law and federal
28 regulations in the Los Alamos National Laboratory. There was also a $9,350 penalty for violation

Page 17 of 18
1 of the Federal Toxic Substances Control Act (15 USC §§ 2601 et seq.) in the University of
2 California Los Angeles’
3 33. Deliberate and unlawful discharge of machine oil for seven years to the
4 Sacramento River via a city storm drain from defective gear boxes in the UC Davis Medical
5 Center’s cogeneration power plant facility.
6 34. CAL/OSHA imposed a penalty in the amount of $7, 385,00 for safety violations
7 in the UC Davis Medical Center’s cogeneration power plant facilities that were not related to the
8
unlawful machine oil discharge to the Sacramento River.
9
35. In 2008 the University of California settled a lawsuit brought by Officer Chang, a
10
gay man who was employed as a campus police offer, paying him $240,000.00.
11
36. The University of California has agreed to pay $375,000 to settle a 2008 lawsuit
12
stemming from the suicide of a prison inmate who was under the supervision of university
13
psychiatrists.
14
37. The pepper spray attack against protesting students on November 18, 2011,
15
resulted in a settlement in the amount of $1 million for victims and $250, 000 in legal fees.
16
38. The 2011, an illegal medical experiment conducted by two neurosurgeons at the
17
18 UC Davis Medical Center under the supervision of UC Davis Vice Chancellor Claire Pomeroy
19 resulted in the deaths of several patients.
20 39. In 2011, credit cards embezzlement in the UC Davis Medical Center was
21 uncovered and reported by two UC Davis employees and confirmed by auditor William
Prindible, who conducted an audit. The two employees who reported the credit card
22
embezzlement and 60-year-old auditor, Prindible, were fired from the job and the white-collar
23
UC Davis Medical Center criminals who committed the crime are still being employed by the
24
UC Davis Medical Center. The Prindible’s case ended in a January 2015 settlement in federal
25
court, Plaintiff is unaware of the amount of the sum that was paid to the victimized William
26
Prindible (Federal Court Case No. 2:13-cv-02256-KJM-EFB). On May 30, 2012 ,the University
27
of California administration has unsuccessfully attempted to provoke and kill t Plaintiff or end
28

Page 18 of 19
1 Plaintiff’s employment in the UC Davis Medical Center Trauma Unit # 11 after a witch hunt that
2 lasted more than a year.
3 40. The 2013 UC Davis Climate Survey conducted by Rankin & Associates showed
4 that 24% of UC Davis-surveyed employees (4,000 of 11,500) suffered while working in UC

5 Davis’s hostile and discriminatory work environment. The most recent survey conducted in all
6 UC campuses shows that situation in not better in other in campuses and percentage of
7 suffering , hostile and discriminatory work environment among employees is very high.
8 41. The October 2013 investigation report issued by former State of California
9 Supreme Court Justice Honorable Carlos Moreno stated that several high-profile incidents of
10 racial and ethnic bias and/or discrimination have occurred on the University of California Los
11 Angeles campus in recent years. The Defendant’s climate and culture of sustained abuse,
12 bullying, discrimination, retaliation for whistleblowing, harassment of all kinds, intimidation,
13 retaliation, favoritism, nepotism, health and safety violations, falsification of documentation, fear
14 of retaliation for reporting misconduct, and research misconduct was again publicized in 2014
15 42. In April 2014 the University of California regents agreed to pay $10 million to the
16 former chairman of UCLA's orthopedic surgery department, who had alleged that the well-
17 known medical school allowed doctors to take industry payments that may have compromised
18
patient care.
19
43. On August 11, 2014 a Sacramento jury found in favor of Janet Keyzer in
20
wrongful termination case against UC Regents and awarded damages to her in amount of
21
$730,000.00 plus Plaintiff’ attorney fees and cost amounted over $5,000,000.00.
22
44. Charges are pending in the discrimination case against UC Davis Medical Center
23
with the U.S Equal Employment Opportunity Commission filed in November 2014 by the UC
24
Davis Medical Center involving a 60-year-old worker who was attacked by UC Davis Medical
25
Center management during his mother’s funeral and upon his return from workers’ compensation
26
disability.
27
28

Page 19 of 20
1 45. The aforementioned examples are just a few of the incidents that illustrate the
2 despicably inhumane working environment the Defendant have created for its employees and how
3 many employees just live in dread of their bosses .
Plaintiff’s Employment with Dynegy Corporation 1989-1998
4
5 46. On October 2, 1989 Plaintiff was hired as a Power Plant Technician by the Power
6 Operating Company (POC) subsidiary of Power System Engineering Company (PSE, Inc.) from
7 Houston, Texas as an Operating Technician of the San Joaquin Cogeneration Power Plant
8 located in Lathrop, CA.
9
47. In 1990 the PSE, Inc. was acquired by the DOW Chemical Company’s subsidiary,
10
Destec Energy, Inc. and later by Dynegy Corporation, which was the competitor of Enron
11
Corporation in electric power generation in the USA.
12
48. The San Joaquin Cogeneration Power Plant was producing 50 MW of electricity
13
per hour and processing water to make high quality steam. The plant is selling electricity to the
14
Pacific Gas and Electric Company by contract and steam to the Auto Glass Manufacturer, Libby
15
Owens Ford, in Lathrop, CA.
16
49. The San Joaquin Cogeneration Power Plant was powered by the LM 5000
17
General Electric aeroderivative gas turbines.
18
19 The aeroderivative gas turbines are used in a variety of applications: - electrical power both for
20 utility baseload and peaking applications in both simple-cycle (gas turbine only) and combined-
21 cycle configurations. Simple-cycle refers to a gas turbine used alone; combined-cycle refers to an
22 application where the exhaust from the gas turbine is used to power a steam turbine to maximize
23 overall system efficiency - in-plant and independent power production and cogeneration (the
24 production of two forms of energy, usually steam and electricity from a single fuel source) in an
25 industrial or institutional facility - mechanical drive requirements, such as compressors, pumps
26 and other loads - marine propulsion of naval and commercial vessels. Industries that use
27 aeroderivative gas turbines include petroleum production, refining and pipeline operations,
28

Page 20 of 21
1 enhanced oil recovery, chemical, food and pulp/paper processing, and institutional electricity and
2 heating for universities, hospitals and prisons. The aeroderivative gas turbines benefit from
3 aircraft engine technology developed to meet the power and reliability.
4 50. The Dynegy’s San Joaquin Cogeneration Plant supposedly was a cogeneration
5 Qualified Facility, which was governed by the Public Utility Regulatory Power Act, known as
6 PURPA. The PURPA Act was enacted in 1978 by the U.S. Congress to promote conservation of
7 energy.
8 51. The San Joaquin Cogeneration Power Plant as a cogeneration Qualified Facility
9 benefited from this status by having a 25% discount on purchase of natural gas from the Pacific
10 Gas and Electric (PG&E) Company and a tax break on the PG&E ratepayers expenses.
11 52. The 1978 Public Utilities Regulatory Policies, which established the guidelines
12 for cogeneration facilities applied to San Joaquin Cogeneration facility, where Plaintiff was
13 employed. The San Joaquin Facility used natural gas as a fuel for a combustion jet engine to
14 produce electricity and exhaust heat to heat water and produce steam. From the beginning of the
15 operation, the San Joaquin Facility has violated PURPA and California Law requirements in
16 order to be a Qualified Cogenerate. The company management was forcing its own employees to
17 release a huge amount of steam into the atmosphere, which was through the PG&E meter to
18 cheat the PURPA requirements instead of utilizing the thermal energy as was required by law. In
19 1994 the company’s senior management was advised by the San Joaquin Plant Manager to
20 resolve the existing problem with the PURPA violation. In retaliation, the mentioned plant
21 manager was fired and escorted out.
22 53. In 1989 the former State of California Chief of Department of Standard Labor
23 Enforcement (DLSE) or State of California Labor Commissioner Jose Milan was allowed to
24 govern the wages and working conditions for the San Joaquin cogeneration power plant in
25 Lathrop and other Dynegy’s cogeneration plants in California using the wrong Industrial Welfare
26 Commission Order (IWC), which was IWC order 4-89 O instead of IWC order 1-89; thus 119
27 Dynegy employees were defrauded of a significant amount of overtime, to which they were
28

Page 21 of 22
1 entitled under IWC Order 1-89.
2 54. In 1985 DLSE Chief Jose Milan was the resident of California and earned a juris
3 doctorate from the University of Houston School of Law; from 1985-1987 Jose Millan was a
4 Field Examiner for the State of California Agricultural Relation Labor Board and Program
5
Coordinator for the State of California Public Utilities Commissioner. In 1987 Mr. Millan
6
became employed by the State of California Division of Labor Standards Enforcement.
7
55. In November 1995 all employees received a memo from the Headquarters in
8
Houston, TX. The memo stated that the employee’s Retirement and Savings Plan 401K was
9
mismanaged and that the Company would not make a Discretionary profit-sharing contribution
10
to the Plan for 1995 (5% percent of annual wages contribution).
11
56. Furthermore, the Independent Auditors’ Report performed on Plaintiff’s
12
employer’s behalf by the Deloitte & Touche LLP disclosed that the 401K Plan is lacking a
13
contribution to the employees’ accounts in the amount of $4,000,000,00 plus interest for the
14
15 years of 1991-1995.
16 57. After the 401K plan retirement fraud disclosure, Plaintiff asked his supervisor
17 about the unpaid overtime mandated by the Welfare Commission Order IWC 1-89 Part of unpaid
18 overtime shall be contributed to employees’ Retirement and Savings Plan 401K plus the
19 employer match contribution in the ratio dollar to dollar up to six percent of employee’s gross
20 annual income. Plaintiff did not have any intention to pursue the overtime issue but just asked
21 the question.
22 The overtime issue would never have surfaced if Plaintiff’s employer would have posted in the
23 Plant’s control room the IWC order 4-89 instead of IWC order 1-89.
24
58. The San Joaquin Cogeneration Plant Manager panicked and alerted the
25
Headquarters, and then IWC order 1-49 was posted on the information board next to IWC order
26
1-89. Shortly after, Plaintiff’s employer hired the prestigious law firm Pillsbury Madison &
27
Sutro LLP and Plaintiff received a letter from Sutro’s lawyer about the IWC order applicability
28

Page 22 of 23
1 for the San Joaquin cogeneration facility. The letter stated that State Labor Commissioner Jose
2 Milan permitted Plaintiff’s employer to utilize IWC Order 4-89 instead of IWC order 1-89.
3 Thereafter Plaintiff became a subject of retaliation and harassment without any reason because
4 Plaintiff had no intention to pursue the overtime issue outside. Plaintiff heard intimidating
5
statements from his supervisors that Hoffa disappeared and the president was killed in USA as
6
well. Plaintiff’s employment became quite unpleasant.
7
59. To stop the further retaliation and intimidation, Plaintiff had no choice but to ask
8
for help from the same state agency the State of California Department of Industrial Relations,
9
Division of the Labor Standard Enforcement, which permitted Dynegy to operate business in the
10
State of California under the wrong Industrial Welfare Commission order and Plaintiff filed a
11
claim with the Labor Commissioner Office in Stockton, CA for unpaid overtime.
12
60. On September 16, 1996, the DLSE Hearing Officer awarded Plaintiff $27,129.21,
13
which in 1996 was a significant amount of money. The Labor Commissioner from the Stockton
14
15 Office overturned his superior’s—the State Labor Commissioner Jose Milan’s—earlier decision
16 to permit Plaintiff’s employer to govern working conditions and pay by IWC order 4-89 instead
17 of IWC 1-89.
18 61. Right after the labor commissioner issued the decision in Plaintiff’s favor,
19 Plaintiff’s employer in retaliation suspended Plaintiff for almost two months without pay and
20 right away appealed the Labor Commissioner Decision in San Joaquin County Superior Court.
21 The Superior Court in Trial de Novo ruled in favor of Plaintiff’s employer.
22 62. Plaintiff appealed the IWC order 1-89 unfavorable the Superior Court Judgment
23 in the State of California Court of Appeal 3th Appellate District by representing himself in Pro
24
Per. The Court of Appeal reversed the Superior Court Judgment and Plaintiff received his unpaid
25
overtime. The other 119 of Plaintiff’s coworkers recovered partially unpaid overtime through the
26
settlement-agreement that Plaintiff’s employer signed with the Division of Labor Standard
27
Enforcement.
28

Page 23 of 24
1 63. Regardless of the fact that the Court of Appeal’s decision in Plaintiff’s case was
2 an unpublished decision, it caused the DLSE to restore the applicability of the IWC Order 1 to
3 govern working conditions and overtime pay for non-exempt employees working on an
4 alternative work schedule in all privately owned power plants in the State of California.
5
64. During the unpleasant dispute about unpaid overtime, the case took a different
6
turn and became a whistleblowing case due to fraudulent and unlawful operation of the San
7
Joaquin cogeneration facility by Plaintiff’s employer. The San Joaquin Cogeneration violated the
8
Federal Energy Regulatory Commission requirements to operate as a Qualified Facility (QF)
9
under the 1978 Public Utility Regulatory Power Act enacted by the U.S. Congress.
10
65. Based on Plaintiff’s information, The Pacific Gas & Electric Company in
11
September 2007 filed a lawsuit against Plaintiff’s employer for fraud and breach of contract and
12
unfair business practices. As the result of filing the lawsuit, PG&E recovered by settlement
13
$100,000,000 for its own ratepayers, of which Plaintiff was one.
14
15 66. In retaliation, Dynegy terminated Plaintiff’s employment in January 1998.
16
17 Plaintiff’s Employment with Genentech Inc., from November 1998 to June 1999
18
19 67. After almost one year of unemployment in November 1998, Plaintiff was hired as
20 Utility Operator by Genentech, Inc. located in the City of South San Francisco.
21 68. Genentech, Inc. was the best employer Plaintiff ever worked for in the United
22 States, taking into consideration benefits and treatment of employees by company management.
23 69. The almost 100 miles distance to Plaintiff’s residence in Lodi to South San
24
Francisco and Plaintiff’s wife’s employment in Nordstrom Inc., Sacramento were deciding
25
factors that led Plaintiff to apply for the Cogeneration Plant Operator position with the UC Davis
26
Medical Center in Sacramento, which was only 32 miles away from Lodi, CA.
27
70. Also the Cogeneration Plant Operator position was a factor to apply for the job
28

Page 24 of 25
1 with UC Davis Medical Center because the job was basically the same as Plaintiff’s job with
2 Dynegy Company in Lathrop, California, where Plaintiff worked for nine years.
3
4 Plaintiff’s Job Description and Employment in UC Davis Medical Center Cogeneration Power
Plant Named “Central Plant “
5
7
71. Defendant hired Plaintiff on June 28, 1999 as a non-exempt senior power
8 plant mechanic or cogeneration power plant operator (hereinafter “plant operator”) to maintain
9 and operate the newly built, state-of-the-art 27 megawatt cogeneration power plant at UC Davis
10 Medical Center, Sacramento, California.
11 72. Besides operating and maintaining the cogeneration facility, Plaintiff was
12 responsible for monitoring and dispatching critical alarms on the day shift at the UC Davis
13 Medical Center via the computerized Metasys system, which was also programmed to
14 continuously monitor and record how much electricity, steam, hot water, and chilled water was
15 being generated by the central plant. The Metasys system was also designed to start up and shut
16 down heating and air conditioning equipment (HVAC), as well as to adjust temperatures in the
17
administration and hospital patients’ rooms per request from working personnel at the UC Davis
18
Medical Center.
19
73. The UC Davis Medical Center’s cogeneration power plant, named the
20
“Central Plant,” includes a General Electric LM 2500—a 23 MW jet combustion gas turbine; a
21
heat recovery steam generator (HRSG)—a 4 MW back pressure steam turbine with capacity to
22
produce 89,000,00 pounds of steam per hour; four auxiliary steam boilers with 25,000-pound-
23
per-hour capacities for steam from each boiler; three centrifugal chillers; and three absorption
24
chillers that can produce 13,400 tons of chilled water per hour. The Central Plant also has five 2-
25
MW emergency diesel generators and other auxiliary heavy industrial-type machinery, including
26
27 a cooling tower, pumps, an ammonia injection system, a water demineralizer, a condenser, and a
28 chemical-injecting system.

Page 25 of 26
1 74. The UC Davis Medical Center’s peak load demand for electricity in
2 summer is 17 MW of electricity, 45,000 lb./hr. steam, and 10,000 tons/hr. of chilled water (spare
3 capacity: 10 MW of electricity).
4 75. The UC Davis Medical Center’s maximum load demand for electricity in
5
winter is 8 MW of electricity, 45,000 lb./hr. steam, and 10,000.00 tons/hr. of chilled water (spare
6
capacity: 19 MW of electricity).
7
76. The above numbers translated also of massive waste of energy, water,
8
extra and in huge amount of unnecessary emission of the two air pollutants carbon dioxide,
9
nitrous oxide beside of increasing the costs of the plant operation cost .
10
77. The California Air Resources Board (ARB) is the state agency
11
responsible for providing implementation mechanisms, regulatory guidance and enforcement of
12
Assembly Bill 32 (AB32). AB32 includes statutory requirements requiring inventorying,
13
reporting and verification of GHG emissions, depending upon size and source type. UC Davis is
14
15 subject to these reporting requirements. Facilities that emit 25,000 metric tons of carbon dioxide
16 or its equivalent (MTCO2e) are required to report their annual emissions to the USEPA, and both
17 the Davis and Sacramento campuses have facilities that emit over 25,000 MTCO2e.
18 78. The 10 MW of electricity not produced and not sold during the summer
19 peak equals millions of dollars of lost revenue over 17 years of the Central Plant’s operations.
20 However if 10 MW extra of electricity was produced and was sold during the summer than
21 peak equals millions of dollars in extra revenue over 17 years of the Central Plant’s operations ;
22 79. Prior to building the cogeneration plant, the UC Davis Medical Center
23 Campus sourced electricity from the local publically owned utility, Sacramento Municipal Utility
24
District (SMUD). The oversized cogeneration plant right before energy deregulation in California,
25
and during that turbulent period, the UC Davis Medical Center took advantage of the opportunity to
26
generate and sell power to SMUD. When the power market deregulation took place cogeneration
27
facility was selling power at for the on the open market for higher bid via California Independent
28

Page 26 of 27
1 System Operator . Manipulation of power market caused power shortage and blackout in California
2 and in some day’s prices of electricity went up 800%. As the California Public Utility Commission
3 changed rules about generating and selling, the UC Davis Medical Center cogeneration facility
4 stopped generating and selling power for the spot market. However, in order to operate the
5 cogeneration plant LM 2500 jet engine operational off peak hours the cogeneration plant still sends
6 power to SMUD
7
8 The Federal Law Requirements to Build and Operate Cogeneration Facility

9
10
80. The Federal Energy Regulatory Commission (FERC) and the Public
11
Utility Regulatory Policies Act of 1978 (PURPA) mandate that any cogeneration facility
12
certified and recognized by law as “the qualified cogeneration facility” must meet special
13
requirements in the ratio between electric energy production and thermal energy production.
14
A cogeneration facility is a generating facility that:
15
“sequentially produces electricity and another form of useful thermal energy
16
(such as heat or steam) in a way that is more efficient than the separate
17
production of both forms of energy. For example, in addition to the production
18
19 of electricity, large cogeneration facilities might provide steam for industrial
20 uses in facilities such as paper mills, refineries, or factories, or for HVAC
21 applications in commercial or residential buildings. Smaller cogeneration
22 facilities might provide hot water for domestic heating or other useful
23 applications. In order to be considered a qualifying cogeneration facility, a

24 facility must meet all of the requirements of 18 C.F.R. §§ 292.203(b) and
25 292.205 i5 for operation, efficiency and use of energy output, and be certified
26 as a QF pursuant to 18 C.F.R. § 292.207. There is no size limitation for
27 qualifying cogeneration facilities.”
28

Page 27 of 28
1 81. Plaintiff is familiar with the Federal Energy Regulatory Commission’s
2 regulation and PURPA because, prior to his employment with the UC Davis Medical Center,
3 Plaintiff worked for a private corporation with a similar cogeneration facility that did not meet
4 FERC and PURPA requirements to be certified as a “qualified cogeneration facility.” Plaintiff’s
5
previous employer committed enormous fraud against Pacific Gas and Electric Company
6
ratepayers and settled out of court for $100 million. The $100 million fraud occurred after only six
7
years of unlawful cogeneration facility operations similar to UC Davis Medical Center
8
cogeneration plant.
9
82. Based on the figures provided above regarding electricity, steam, and
10
chilled water production at the UC Davis Medical Center cogeneration plant, it is questionable
11
whether the UC Davis Cogeneration Facility operates according to FERC and PURPA law and
12
regulations.
13
83. Regardless of the $100 million fraud committed by Plaintiff’s previous
14
15 employer against Pacific Gas and Electric Company, Plaintiff’s previous employer was very
16 safety oriented and strictly enforced safety rules. It had outstanding safety rules and safety
17 training for employees. Plaintiff was hazmat certified and a first responder, and knew CPR.
18 Plaintiff had no problem adapting to UC Davis Medical Center, where safety rules and
19 regulations were disregarded and ignored by management and safety trainings were unknown
20 and viewed as unnecessary burdens and hassles.
21 84. UC Davis Medical Center’s state-of-the-art cogeneration facility, which
22 cost $70 million to build, was commissioned with many serious safety problems and hazards,
23 endangering working personnel and raising Plaintiff’s concern about his safety and that of his
24
coworkers, many of whom had little or no working experiences in power plant environments.
25
The State of California Law and International Law which Classified Cogeneration Power
26 Plants as a Manufacture and Industrial Facility
27 85. By State of California Industrial Welfare Commission Order #1, all power
28

Page 28 of 29
1 plants, including cogeneration facilities, are classified as manufacturing facilities and “Electricity
2 is a commodity which, like other goods, can be manufactured, transported and sold.” The Court
3 held in Baldwin-Lima-Hamilton Corp. v. Superior Court (1962) 208 Cal. App. 2d 803, 81 that
4 the sale of a commodity is regulated by international law.
5
86. It is a question of law whether the University of California, as a non-profit
6
organization, can deliberately build, own, and operate an oversized cogeneration facility for the
7
primary purpose of producing and selling electric energy (a commodity) for profit by the
8
contract to the municipal utilities company or on the open market without meeting the
9
qualifications and requirements of the Federal Energy Regulatory Commission as a “Qualified
10
Cogeneration Facility “
11
“Any applicant seeking QUALIFYING fACILITY ( QF)) status or
12
recertification of QF status for a generating facility with a net power
13
production capacity greater than 1000 kW must file a self-certification or an
14
15 application for Federal Energy Regulatory Commission(FERC) certification
16 of QF status, which includes a properly completed 14 pages long Form 556.
17 Certain lines in this form will be automatically calculated based on responses
18 to previous lines, with the relevant formulas shown. You must respond to all of
19 the previous lines within a section before the results of an automatically

20 calculated field will be displayed. Applicants are required to file their Form
21 556 electronically through the Commission's e-Filing website. Pursuant to
22 18 C.F.R. § 292.207(a)(ii), applicant must provide a copy of self-certification or request
23 for Commission certification to the utilities with which the facility will interconnect
24
and/or transact, as well as to the State regulatory authorities of the states in which your
25
facility and those utilities reside. An applicant submitting a self-certification of QF
26
status should expect to receive no documents from the Commission, other than
27
the electronic acknowledgement of receipt described above. Consistent with its
28

Page 29 of 30
1 name, a self-certification is a certification by the applicant itself that the
2 facility meets the relevant requirements for QF status, and does not involve a
3 determination by the Federal Energy Regulatory Commission as to the status
4 of the facility. “
5
87. On August 6, 2012 UC Davis Medical Center Associate Vice Chancellor for
6
Diversity and Inclusion Dr. Shelton Duruisseau gave an interview to the Sacramento-based
7
African-American magazine Sub Cultural Hub. The interview was conducted by Donna Michelle
8
Ramos on and was entitled “A Look Back.”
9
Dr. Shelton Duruisseau, by his statement, confirmed that the UC Davis Medical Center 27 MW
10
oversized cogeneration plant was built primarily to produce electric power for sale and profit
11
instead of to provide utilities for the UC Davis Medical Center.
12
13 88. Itis also a question of law whether the Defendant committed

14 negligent hiring, fraud and misrepresentation by employing Plaintiff and other UC Davis Medical
15 Center cogeneration plant personnel and failing to provide information that the cogeneration plant
16 was being operated in violation of the federal law and regulations and could be subject to shut
17 down and personnel could face unemployment if violations were disclosed.
18
89. It is also a question of law whether the University of California, Davis, Medical
19
Center, as a higher education school of medicine, hospital and nonprofit organization, violated the
20
State of California Revenue and Taxation Code by engaging in commercial operation of a
21
cogeneration power plant business based on an electric power agreement with public or private utility
22
companies and made millions of dollars in profit from seventeen years of operation.
23
90. It is also a question of law whether the University of California, Davis, Medical
24
Center, as a higher education school of medicine, hospital and nonprofit organization, violated the
25
Internal Revenue Service’s Code Section 501(c)(3) by engaging in commercial operation of a
26
cogeneration power plant business based on an electric power agreement with public or private utility
27
companies and made millions of dollars in profit from seventeen years of operation. An organization
28

Page 30 of 31
1 that produces unrelated business income as a result of its unrelated trade or business may have to
2 pay taxes on that income.
3 91. It is also a question of law whether the University of California, Davis, Medical
4 Center, as a higher education school of medicine, hospital and nonprofit organization, violated the
5 Internal Revenue Service’s Code Section 501(c)(3 by using the revenue from the commercial
6 operation of a cogeneration power plant business to increase and maintain salary for UC Davis
7 Medical Center executives, management and UC Davis Medical Center cogeneration plant
8 personnel.
9 92. For example, in 2011, UC Davis Medical Center Chief Executive Officer Ann
10
Madden Rice was granted a raise of nearly $259,000, bringing her compensation to $960,000 a
11
year. UC Davis Vice Chancellor Claire Pomeroy, who was in charge of the UC Davis Medical
12
Center School of Medicine, was given a raise of nearly $27,000, bringing her compensation to
13
$664,275.
14
Funding for Rice’s and Pomeroy’s salaries comes from hospital fees, not the state’s general fund.
15
93. In December 2010, an exclusive 12% pay raise for UC Davis Medical Center
16
cogeneration plant operation resulted in four cogeneration plant operators’ blackmail petition
17
submitted to UC Davis Medical Center management, which stated that operators can no longer
18
operate the plant if they will not get a pay increase.
19
20
UC Davis Health System Executive Director Stephen Chilcott’s salary was increased from
21 $208,000 to $274,000 in four years, from 2010 to 2014.
22 94. UC Davis Medical Center Plant Operation and Maintenance Manager Charles
23 Witcher, who is responsible for maintenance and operation of the cogeneration plant by his title
24 and position, received $64,000.00 in salary increase from his promotion to this position in 2007
25 to 2014. (Charles Witcher has a high school education only and has no qualification for this
26 position.)
28

Page 31 of 32
1 Witcher, who is responsible for the maintenance and operation of the cogeneration plant by his
2 title and position, received a $64,000 salary increase from his promotion to this position in 2007
3 through 2014. (Charles Witcher has a high school education and has no qualification for this
4 position.)
5
96. It appears from the accessible public documents from the Federal Regulatory Energy
6
Commission’s Library that the UC Davis Medical Center, Central Plant is not the PURPA’s
7
Qualified Cogeneration (QF) facility and is not certified by FERC for legal operation and power
8
sale. However, if the UC Davis Medical Center, Central Plant was certified by FERC by the
9
Defendant’s self-certification, then it was done by fraud by inserting false data into FERC’s
10
required self-certification form.
11
97. Furthermore, if the UC Davis Medical Center, Central Plant was certified by
12
FERC, then would not have a problem obtaining a power-sale contract with the Sacramento
13
Municipal Utility District or selling surplus electrical energy on the spot market via the
14
15 California Independent System Operator (ISO)
16 98. Contrary to the UC Davis Medical Center, Central Plant, the UC San Diego
17 Cogeneration Plant, which is owned and operated by the Defendant (like the UC Davis Medical
18 Center Central), has no problem selling surplus energy on the spot market. The UC San Diego
19
Cogeneration Plant filed self-certification with FERC on May 24, 2000 according to FERC’s
20
Docket No. QF 00-63-001.
21
99. In addition to the above, the UC San Diego Cogeneration Qualified
22
Facility in 2010 received a $2 million grant from the U.S. Department of Energy and installed
23
the world’s first microgrid master controller and related optimizer application. The Smart Grid
24
25 functions as a virtual power plant, scheduling energy self-generation, electricity imports, and
26 electric and thermal storage while factoring in the demand load and the variable price of
27
electricity to buy or sell.
28

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1 100. The question concerns why the UC Davis Medical Central Plant has no Smart
2 Grid and cannot generate the sale of the huge amount of energy sitting in the 70 million state-of-
3 the-art 27 MW cogeneration facility or transmit the surplus energy to the UC Davis campus,
4 which is entirely dependent on outside energy sources, which are very expensive.
5 101. The question also concerns why the Defendant decided to invest and build 70
6 million 27 MW cogeneration facility for the UC Davis Medical Center that cannot be operated at
7 full capacity, losing approximately $100 million over the last 10 years instead of building a
8 bigger cogeneration facility for the UC Davis campus, which is entirely dependent on outside
9 energy sources.
10 102. According to the 2014 University Of California Annual Report Of Sustainable
11 Practices, the UC became a registered Electric Service Provider (ESP). As an ESP, the university
12 is able to self-supply electricity to its direct-access accounts. The self-supply electricity began
13 being generated in 2015. The 2014 UC Report of Sustainable Practices is, for the most part,
14 misleading and fraudulent in regard to green-gas emission on the campuses, especially the UC
15 Berkeley campus, and it is related to the operation of the cogeneration facility not owned or
16 operated by the Defendant but rather located on the UC Berkeley campus.
17 103. The question is as follows: Why is the Defendant, who registered as an ESP,
18 unable to operate the UC Davis Medical, Center Plant at full capacity and provide the energy to
19 other UC campuses, especially the UC Davis campus, or sell the energy on the spot market via
20 ISO?
21 104. Instead of hunting down the Plaintiff like an animal since 2006 for no reason
22 with a criminally minded attempt to assassinate the Plaintiff on May 31, 2012 and destroy the
23 Plaintiff’s life and his livelihood, the Defendant should take care of business and get a contract
24 for the sale of power from the UC Davis Medical Center, Central Plant. The Defendant should
25
also take care of those who attacked Plaintiff and misinformed the Defendant for the own
26
personal financial gain that Plaintiff will harm University business in relation to the UC Davis
27
28

Page 33 of 34
1 Medical Center Central Plant operation and Plaintiff has to be destroyed what finally happened
2 in December 2012.
3
The Plaintiff’s Complaint with the State of California Division of Occupational Safety and
4 Health (DOSH), Better Known as Cal/OSHA in December 2000
5
6 105. The UC Davis Medical Center Cogeneration Power Plant/Central Plant
7 was commissioned in 1998 as a state- of-the-art facility, but for some reason was unfinished. As
8 a result, Central Plant equipment was unsafe to operate and posed life-threatening danger to
9 personnel. A power plant’s working environment is dangerous by nature, and if safety rules and
10 regulations are not followed, it will lead to disastrous consequences. Plaintiff came to Central
11 Plant from a very safety-oriented company and was shocked when, in 2000, Central Plant’s
12 manager said in front of other employees, “Somebody give this Polack a bad evaluation and
13 fire him,” after Plaintiff suggested some safety improvements. Plaintiff’s coworker Eduardo
14 Espinosa was so terrified by the Central Plant manager’s statement that he wrote a letter to UC
15 Vice President Judith Boyette and complained than quit his job. A Cal/OSHA intervention was
16 needed to convince the UCDMC Plant Operation and Maintenance (PO&M) Department
17 Management to improve the safety and fix some problems with unsafe equipment that should
18 have been fixed without Cal/OSHA intervention.
19 106. The arrogance of the PO&M Department Management was unbelievable
20 and unacceptable. The Cal/OSHA intervention fixed some minor problems, but major safety
21 problems in Central Plant went unnoticed or deliberately ignored by the Cal/OSHA inspector,
22 and there is not any record that Central Plant personnel were interviewed. The most dangerous
23 place was the oily cement floor underneath the cooling tower, which drained oil to the
24 Sacramento River via storm drain, but was unnoticed by the inspecting Cal/OSHA personnel.
25 Coincidently, when the Cal/OSHA inspection took place, Plaintiff was on his days off from
26 work.
27 107. In 2000, Plaintiff wrote in his Brief to Cal/OSHA:
28

Page 34 of 35
1 “Plaintiff believes that symbolic monetary penalties type ‘slap on the wrist’ is
2 a joke in contrary to the occurred safety violations and total ignorance of the
3 law by UCDMC Management. However, presence of the Cal/OSHA inspectors
4 in the facility had an “enormous impact and encouragement” for my employer
5 and direct supervisor to correct some problems with safety in the plant.”
6 108. Furthermore, Plaintiff wrote:
7 “The UCDMC like the other divisions of the UC System enjoys liberty and independence from
8 the State of California legislature and state agencies which enforcing wages and working
9 condition in private sector. This status was affirmed not only by the Government Codes but also
10 on many occasions by the Appellate Courts of the State of California. It is great that students and
11 professors, researchers and scientists have such unrestricted autonomy to freely work for the
12 good of people. The University of California has great prestige in this State as well in the nation.
13
However, it looks like the ordinary workers in this entity who provides services every day for
14
these great researchers, professors, students, and scientists keep them warm at winter time and
15
cool at summer time, these who keep this whole system running without failure have been
16
somehow forgotten and they are object of abuse, discrimination as well are being exposed to
17
unsafe working environment which is a subject of this response. It is unknown for me why the
18
workers are being treated this way in this high education prestigious school. I was very
19
concerned and worried seeing supervisors’ memos where he was calling his subordinates damn
20
or stupid or threatening others to fire them on spot in the place where employment is not at will.
21
Intimidation, ignorance, negligence, threats, power trip, unprofessional remarks toward
22
23 subordinates, lack of personal culture of the superiors replaced common sense, proper training,
24 normal working environment and human dignity and rights. The safety rules and laws were
25 replaced by intimidation, letters of warning, and suspension from work. Where is this
26 management’s philosophy coming from?”
27 109. Also, in 2000, four workers from the UCDMC Access Unit were
28 suspended for circulating a petition asking to discuss items related to workload, safety,

Page 35 of 36
1 ergonomics, and respect. California legislator intervention was needed, including but not limited
2 to State of California Assemblyman Honorable Darrel Steinberg, to bring these employees back
3 to work. Plaintiff was also asked to help these workers in regard to the despicable UCDMC
4 Management retaliation.
5 110. After Cal/OSHA issued the citation for negligence and safety violations in
6 the plant, UC Davis Plant Operation and Maintenance Department (PO&M) Manager Toni
7 Moddessette demoted Cogeneration Plant Superintendent Tom Kavanauch and replaced him
8 with Dan James, who was brought to the plant from the UC San Francisco Medical Center. The
9 situation in the plant changed for the better up until the present, but it has changed quickly for
10 the worse due to current plant manager Steve McGrath’s group of colleagues who came from his
11 previous plant near Jackson, CA. Two Central Plant operators, William Buckans and Rick
12 Tunello, became the target of constant harassment and were bullied by newly hired individuals
13 from the Jackson area. Shortly after they were hired, plant manager Dane James was coerced by
14 these individuals from Jackson to join them in attacks against Rick Tunello and William
15 Buckans. For some reason, these folks did not like Rick Tunello and William Buckans and were
16 pitting the Plant manager against them; trying to convince Dan James to fire Tunello and
17 Buckans.
18
111. In August 2003, Plaintiff’s coworker, Mike Murphy (who quit job in 2005), and
19 Plaintiff, received from the central plant maintenance supervisor Tom Kavanaugh a Preventive
20 Maintenance Work Order that required us to pressure wash all dirt and oil underneath the
21 Cooling Tower. We refused to pressure wash the oil to the storm drain. We took pictures using
22 Mike Murphy’s Sony Digital Camera and we told Tom Kavanaugh that we did not pressure wash
23 the oil to the storm drain. Several times Plaintiff approached an employee from the UC Davis
24 Medical Center’s Environmental Health and Safety Department (EH&S) who was visiting the
25 Central Plant frequently to sign Hazardous Work Permits (after a long time Plaintiff forgot his
26 name). The EH&S employee was not very anxious to discuss the oil problem under the Cooling
27 Tower and his response was, “Well if we get caught than we pay the price.”
28

Page 36 of 37
Violation of the State Health and Safety Code that require safe storage and disposal of
1 hazardous waste, Water Code and Fish and Game Code provisions that prohibit discharge of
hazardous waste or garbage into state waterways.
2
3 112. Some of the worst safety problems and environmental hazards in the
4 UCDMC state-of-the-art Central Plant were twenty-two (22) defective-by-design cooling tower
5 gearboxes.
6 113.. The defective cooling tower gearboxes were massively leaking machine
7 oil underneath the cooling tower and creating serious safety problems for the personnel working
8 underneath the cooling tower; in addition, the leaking machine oil created an enormous
9 environmental hazard. Every week, as usual, the Central Plant maintenance supervisor issued a
10 preventive maintenance work order to refill the cooling tower’s leaking gearboxes. The machine
11 leaked approximately 10 gallons of oil per week for seven (7) years, and the cooling tower floor
12 was washed out with water to the storm drain (river) or to the soil around the cooling tower when
13 the new cooling tower was under construction. Once a month or every three months, the Central
14 Plant maintenance supervisor (the same supervisor who said to Plaintiff that “Somebody
15 [should] give this Polack a bad evaluation and fire him”) also issued a preventive
16 maintenance work order to use a pressure washer to wash out the covered-by-oil gearboxes and
17 cooling tower underneath the floor and discharge everything to the City of Sacramento storm
18 drain connected to the Sacramento River.
19
114. It would cost $5,000/unit to replace the defective units, according to the
20 whistleblowing investigation report which copy of Plaintiff received in 2007 from UC Davis
21 Public Record Act Office. It was merely $110,000 and only 1/3 of the annual salary of UC
22 Davis Associate Vice Chancellor Shelton Duraisseau Ph.D whose idea was to build the 70
23 million dollar 27 MW cogeneration facility. However, UC Davis management’s solution to this
24 urgent safety and environment problem was a dilution, covering up the criminal activities and
25 retaliating against anybody who mentioned this problem. This safety and environment hazard
26 also created unbelievable hostility and an intolerable working environment. The working
27 environment of the Central Plant became very hostile and violent after the present Central Plant
28 manager brought a group of employees from his previous plant near Jackson, CA. The manager

Page 37 of 38
1 provided to them answers to the qualification test in order to cheat the hiring-qualification
2 requirements and to hire his friends. Not one of these folks would pass the qualification test for
3 this type of power plant. Beside the above issue, their qualifications do not match requirements
4 to be hired as the operators for the Central Plant. In exchange for such favor, these individuals
5 became undisputed and dedicated allies for the violating laws and regulations Plant Operation
6 and Maintenance Department and Central Plant management, attacking and bullying other
7 employees who were talking about safety or any problems related to work environment in the
8 Central Plant. These individuals without any hesitation added oil to the leaking gear boxes and
9 washed the leaking oil to the City of Sacramento storm drain Sacramento River. The hostility
10 created by management in the Central Plant lead to the suicide of one the Central Plant operators,
11 Todd Goerlich in December 2010.
12
The Accident and Injury Underneath Cogeneration Plant Cooling Tower
13
14 115. In 2002, one of Plaintiff’s coworkers, William Buckans, was inspecting
15 cooling tower fans, and Buckans fell on the cement floor because of the oily and slippery surface
16 underneath the cooling tower. As a result of this accident, Buckans was taken by ambulance to
17 the UCDMC emergency room with severe back pain. The accident was reported to the Central
18 Plant manager. However, the accident did not encourage management to take care of oil leaks
19 underneath the cooling tower, and every day, Central Plant operators were risking injury under
20 the cooling tower due to the daily routine duty of checking the oil level in leaking oil gear boxes
21 and the condition of the mechanical equipment.
22 After the above-mentioned accident, William Buckans asked plant managers and the
23 maintenance superintendent to apply a nonskid material to the work area where Buckans was
24 injured to prevent another—perhaps more serious—accident and injury. Buckans was absolutely
25 devastated when both supervisors said no to his request. It was unspeakable and unbelievable
26 that his superiors would force their subordinates to work in an extremely unsafe environment
27 without any hesitation. Beside his accident, three other workers got hurt working under the
28 cooling tower. The Central Plant manager, instead of taking care of safety problems, notoriously

Page 38 of 39
1 entertained himself by watching porn during working hours on a company computer and
2 harassing and bullying Buckans on any occasion he could find with his allies, nicknamed the
3 Jackson 5, who were fraudulently hired by him.
4 116. In August 2003, Plaintiff’ coworker Mike Murphy (quit job in 2005)) and
5 Plaintiff, received from the Central Plant maintenance supervisor Tom Kavanaugh, a Preventive
6 Maintenance Work Order which required us to pressure wash all dirt and oil underneath the
9 oil to the storm drain. Several times Plaintiff approached employee from UC Davis Medical
10 Center Environmental Health and Safety Department(EH&S) who was visiting very Central
11 Plant very often to sign Hazardous Work Permits. (Over long time Plaintiff forgot his name) .
12 EH&S employee was not very anxious to discuss the oil problem under Cooling Tower and his
13 response was “Well if we get caught than we pay the price”
14
15 The Whistleblowing Complaint with UC Davis Vice Chancellor Office UC Davis Policy &
16 Procedure Section 380-17, August 2005
17 117. In August 2005, Plaintiff’s coworker William Buckans asked Plaintiff help
18
him with a Whistleblowing Complaint in regard to safety and environmental hazard caused by
19
leaking machine oil in the cooling tower gear boxes pursuant to UC Davis Policy and Procedure
20
Section 380-17. Plaintiff helped Buckans to write a letter to University of California Human
21
Resources Vice President Judith Boyette, which was sent on August 7, 2005, with the actual
22
whistleblower complaint and some evidence.
23
24 118. The UC Davis Management quickly made determination that Plaintiff was
25 helping his coworker William Buckans with his whistleblowing complaint. In an August 7, 2005
26 Improper Activities Report cover letter submitted to the University of California Human
27 resources Vice –President Judith Boyette, William Buckans made reference to UC Vice
28 President Judith Boyette’s employment with a Sutro Madison law firm of which Plaintiff was

Page 39 of 40
1 familiar through previous employment. In addition to the Sutro reference, the copy of the
2 Complaint for Injunction filed with the Superior Court of California, County of San Bernardino,
3 by the Attorney General of the State of California against AUTOZONE Inc, dated June 22, 2005
4 was attached to the Improper Activities Report cover letter.
5
Apparently, the filed the whistleblowing complaint s leaked, and the central plant became a war
6
zone.
7 119. Every morning, a mandatory central plant crew meeting was turned by
8 plant management into a hostile meeting. The plant manager and superintendent, backed by the
9 indviduals from Jackson plant , and without any hesitation showed anger aimed at William
10 Buckans and Plaintiff, to the point that the plant manager told Plaintiff that he would “send the
11 Gestapo on his ass” and asked him to step outside with him for a physical confrontation to
12 resolve William Buckan’s whistleblowing complaint. Plaintiff refused to step out.
13 120. William Buckan’s disclosure of the 7-year gross violation of state and
14 federal environmental and safety law by the UC Davis Medical Center triggered despicable
15 retaliation action aimed at Plaintiff and Buckans The Plaintiff’ believed for many years ass it
16
was the reason for retaliation and witch hunt orchestrated by the Defendant
17
121. To control the situation and take care of William Buckans and Plaintiff,
18 the UC Davis Office of the Chancellor deployed to the UC Davis Medical Center Human
19 Resources Department an attorney, Stephen Chilcott, who was listed as Defendant in Plaintiff’s
20 in the First and Second Amended Complaint (SAC & FAC).The Defendant’s retaliation goal
21 was in order to fabricate false cause and terminate Plaintiff’s and Buckans’ employment.
22 122.. According to the documents Plaintiff received in July 2007 from the UC
23 Davis Public Record Act Office, the UC Davis Assistant Executive Vice Chancellor Robert
24 Loesseberg –Zahl , who was handling Buckan’s Whistleblowing Complaint, very quickly
25 concluded the investigation without even bothering to interview any employee from the Central
26 Plant—including William Buckans, who submitted the complaint and who was injured due to the
27 accident, and was taken to the UCDMC Emergency Room due to unsafe conditions of the
28

Page 40 of 41
1 cooling tower cement floor with leaking oil from the gear boxes. Basically, the Buckan’s
2 Whistleblowing Complain about unlawful machine oil discharge for seven years to the river was
3 swept under the carpet and was concluded around October 2005. The Central Plant supervisors
4 and their allies who were fraudulently hired in the Central Plant received a green light to attack
5 Plaintiff and Buckans as they desired.
6
Hostility In The Central Plant in 2005-2006
7
123. In January 2006, Plaintiff had open heart surgery and was absent from
8
9 work for three months. When Plaintiff was ready to come back to the plant after a few
10 months of illness, the plant manager Dan James was trying to block Plaintiff’s return under
11 the false pretenses that Plaintiff did not provide him or the main office with the requested
12 FEMLA documents for his short disability. When Plaintiff provided him with proof that
13 Plaintiff had provided all documents to the plant manager and to the main office, Plaintiff
14 was told that the documents were lost and that he needed to provide new documents signed
15 by a physician.
16 124. In March 2006, Plaintiff was neither aware nor imagined that the attempt of the
17 plant manager, Dan James, to block Plaintiff’s return to the plant after short-term disability
18
related to Plaintiff’s open heart surgery was a broader preemptive move. The Defendant’ action
19
against Plaintiff to remove Plaintiff from the central plant or fire Plaintiff from the job was for a
20
completely different reason than Plaintiff thought for many years thereafter. Plaintiff believed
21
22 that helping his coworker, William Buckans, with his whistle-blowing complaint about the
23 Defendant’ misconduct in unlawfully discharging machine oil into the Scaramanto River via a
24
city storm drain for seven years was the was the main reason why the Defendant sought to
25
remove Plaintiff from the central plant in an attempt to terminate Plaintiff’s employment.
26
125. In March 2006, it was most likely that Plant Manager Dan James did not know the
27
28 real reason why he was ordered to attack Plaintiff and Plaintiff’s coworker, Buckans.

Page 41 of 42
126. In March 2006, Plaintiff never would thought that one year later, in March 2007,
1
2 the Defendant would carry out ill and despicable plan and abruptly remove Plaintiff from the
3 central plant and reassign him to a different shop with threats of termination of employment
4
although he was the most experienced power plant operator.
5
127. Plaintiff does not remember exactly how this ended, but after Plaintiff came back
6
7 to work after short term disability than he then learned that his coworker William Buckans had
8 become a target of physical threats by other employees from Jackson 5 group. The situation in
9 the plant became so volatile that every morning’s operational meeting was like a war zone. One
10
of the Jackson 5 employees, Steve McGrath, was promoted to Central Plant maintenance
11
supervisor, which emboldened the Jackson group of employees to attack Plaintiff, William
12
13 Buckans and rick Tunello during the shift-turnover morning meetings. In September 2006.
14 Plaintiff coworker Rick Tunello was wrongly accused of missing a medical freezer alarm and
15
was served with unjustified suspension without pay. Plaintiff quickly found out that Rick Tunello
16
was groundlessly accused and was able to help Rick reverse the suspension decision, but Rick
17
Tunello was so fed up with being endlessly harassed and bullied by Jackson 5 group and plant
18
19 manager that he quit the job. This fact that Plaintiff helped Tunello turned the Plant Manager
20 and his Jackson allies entirely against Plaintiff , and they were furious that Plaintiff defended
21
Rick Tunello, whom they hated so badly and wanted fired him for reasons that were undescribed
22
and not understandable to Plaintiff and others workers.. They just hated him. Plaintiff’s loud and
23
24 clear complaint finally forced the Central Plant manager to advise his allies to stop attacks
25 against Plaintiff and Buckans. William Buckans was fed up with the attacks and in September
26 2006 reported the Central Plant manager Dan James for entertaining himself by viewing porn in
27
his cubicle on company time not knowing that reporting Dan James did not make any
28

Page 42 of 43
difference and Dan James would be forced be to quit anyway like Tony Moddessette who
1
2 brought him to Central Plant. The two high school educated individuals Charles Witcher and
3 Steve McGrath were already on the Stephen Chilcott’s and Director Robert Taylor’s list as a
4
replacements for Tony Moddessette’s and Dan James’ positions. .
5
6 The Central Plant Manager’s Porn Activities
7
128. The Human Resources attorney Stephen Chilcott, who was deployed to
8
UC Davis Medical in 2005 to carry out Defendant plan to remove Plaintiff and William
9
Buckans from the Plant conducted the investigation of Central Plant manager Dan James porn
10
activities in his cubicle on company time.
11
129. Shortly after the porn activities complaint was lodged against the central
12
plant manager, Plant Operation and Maintenance (PO&M) Department Manager Tony
13
Moddessette became a scapegoat and was forced to resign and Charles Witcher was assigned as
14
the interim PO&M department manager. The difference between Moddessette and Witcher was
15
16 education. Moddessette had an MBA and Witcher, who was high school educated, could not
17 write a simple memo without help from HR or his secretary, but was willing to do harm to others
18 without asking questions. Also, Witcher was no challenge for Director Robert Taylor. Plaintiff
19 believes that Moddessette refused to participate in hunting down Plaintiff and Buckans right after
20 Buckans filed his whistleblowing complaint in August 2005 and that this also was one of the
21 reasons why he had to end his employment with the UC Davis Medical Center.
22
23 The December 2006-March 2007 “WITCH HUNT” Aimed At Plaintiff and William Buckans
24
130. On November 26, 2006, Stephen Chilcott sent an e-mail to William
25
Buckans entitled “Hostile Work Environment” and informed Buckans that he had concluded
26
investigation without any information about the findings. On December 4, 2006, just eight days
27
after Stephen Chilcott concluded his investigation, the especially assigned “witch hunter” from
28

Page 43 of 44
1 UCDMC Equal Opportunity Committee, Bettye Andreos, was assigned to hunt down Plaintiff
2 and William Buckans to remove them from the Central Plant and Plaintiff became the primary
3 target of the Stephen Chilcott’s crafted despicable preemptive retaliatory action .
4 131. The orchestrated preemptive retaliatory action against Plaintiff and
5
William Buckans a was led and carried out by the UCDMC Equal Opportunity Committee,
6
Chief Executive, Professional Service Officer and UCDMC Equal Opportunity Committee
7
Affirmative Action Officer Dr. Shelton Duruisseau and the Divisional Representatives of this
8
committee: UCDMC Director of Facilities and Construction Mike Boyd; HR Equal Opportunity
9
Manager Cindy Oropeza, Chair of this committee and UCDMC Assistant Director Hospital and
10
Clinics who appointed Charles Witcher as a new UCDMC Plant Operation; and Maintenance
11
Department interim manager Charles Witcher, who had no qualification ad education for this
12
position.
13
132.. The four-month-long witch hunt did not go as anticipated by Stephen
14
15 Chilcott and other attackers. Even Plant Manager Dan James and Plant Superintendent Tom
16 Kavanaugh refrained themselves from attacking Plaintiff and Buckans during the orchestrated
17 Kangaroo Court pseudo-investigation conducted by assigned witch hunter Bettye Andreos from
18 the UCDMC Equal Opportunity Committee. The fabricated accusations were based on the
19 supposed statements taken from fraudulently hired employees, nicknamed the Jackson 5.
20 Plaintiff walked out of the second interview conducted by a appointed Communist “Stalin-type”
21 prosecutor and judge Bettye Andreos, who had no clue what she is doing but was instructed to
22 prosecute Plaintiff and Buckans and end their employment with UC Davis Medical Center.
23 Plaintiff expressed his feelings about Bettie Andresos’ interrogation skills very loudly on his way
24
out from the Pathology Building on February 27, 2007. Also, he expressed his view about this
25
investigation about physical threats toward William Buckans during a meeting with HR Labor
26
Relations Supervisor Mike Garcia.
27
The March 8, 2007 “Investigation Report
28

Page 44 of 45
1 133. On March 8, 2007, Bettye Andreos, a witch hunter assigned by Director
2 Shelton Durruiseau Ph. D, issued her pseudo - investigation report.
3 If somebody unfamiliar with the entire situation in the Central Plant would read Ms. Andreos’
4 report would probably would come to conclusion that Plaintiff is the Grand Wiz of the KKK for
5
Northern California or a leader of the Arian Nation, Neo-Nazi, or guard in a Nazi concentration
6
camp whose goal is to exterminate Jews.
7
134. The Bettye Andreos Report dated March 8, 2007, accused Plaintiff that
8
Plaintiff is the person who created hostile environment in the Central Plant.
9
“It is my conclusion that the work environment in the Central Plant is not
10
consistent with the University’s Principles of Community and violates the
11
principles embodied in the policy on violence in the workplace through the
12
creation of an intimidating, disruptive and threatening environment, i.e., a
13
hostile work environment. I find it more likely than not that the hostile
14
15 work environment is attributable to one employee, Jerry Waszczuk, who
16 consistently uses hate and biased-based comments when engaged with co-
17 workers. There is no evidence that I was able to obtain that indicates Central
18 Plant management was assertive in addressing the issue of hate and biased-
19 based comments in the workplace.”

20
The Retaliatory Letter of Expectation dated March 22, 2007
21
22
135. As a result of reporting safety hazards and seven years of unlawful
23
massive machine oil discharge to the Sacramento River via city storm drain from the UC Davis
24
Medical Center Central Plant, on March 22, 2007, William Buckans received a Letter of
25
26 Expectation.
27 136. The Letter of Expectation Buckans received was made up out of the blue,
28 and the Letter of Suspension and Notice of Reassignment was the shorter version of the March 8,

Page 45 of 46
1 2007, “Witch Hunter” report issued by Bettie Andreos with the same despicable slander,
2 accusations, and threats of terminating Plaintiff’s employment.
3 137. William Buckans appealed his Letter of Expectation under UC Davis
4 Whistleblowing Protection Policy, and the Letter of Expectation was removed from Buckan’s
5
departmental file by UC Davis Chancellor Larry Vanderhoeof on August 27, 2007, with the
6
words:
7
“Nevertheless, I am, by copy of this letter, asking Chief Executive Officer
8
Rice and Executive , UC Davis Medical Center HR Director Gloria Alvarado
9
to review this matter further to determine if any additional corrective actions
10
may be required.”
11
138. UC Davis Chancellor Larry Vanderhoeof, UC Davis Health System (UCDHS) Center
12
HR Director Gloria Alvarado and UC Davis Medical Center (UCDMC) Chief Executive Officer
13
Ann Madden Rice did not know why Stephen Chilcott was deployed to the UC Davis Medical
14
15 Center .
16 139. For his successful mission in 2007 to remove Plaintiff from the Central Plant,
17 Chilcott was promoted to USCDHS HR labor relations supervisor; in 2008 Chilcott replaced
18 USDHS HR Labor Relation Manager Michael Sheesley and, at the end of 2009, Chilcott
19 replaced Gloria Alvarado as UC Davis Health System HR Executive Director .

20 140. The UC Davis Chancellor Larry Vanderhoeof’s order was meaningless because
21 immediately after the Letter of Expectation, was removed by Chancellor order., Buckans became
22 the subject of vicious management retaliation and was bullied by the group of employees
23 fraudulently hired by UC Davis Medical Center Plant management. The attacks and retaliation
24
against William Buckans continued until May 2012.
25
26 The Retaliatory Unlawful Suspension and Reassignment to the UC Davis Medical Center
HVAC Shop
27
28

Page 46 of 47
1 140. On March 23, 2007, Plaintiff received the Letter Intent to Suspend and
2 Notice of Reassignment from the Central Plant to UC Davis Medical Center Plumbing
3 Shop/HVAC.
4 141. The Letter of Intent to Suspend and Notice of Reassignment defamed,
5
defaced, and portrayed Plaintiff as a bigot, racist, and violent employee, making him look like a
6
guard from a Nazi concentration camp or a KKK member and the letter was threating to
7
terminate Plaintiff’s employment, suspend, and reassigned Plaintiff to a different shop.
8
142. The March 23, 2007, Letter of Intent to Suspend and Notice of
9
Reassignment was based on the unofficial UC Davis Policy, which is the tool of the oppression
10
and tool to hunt down employees entitled “ The UC Davis’ Principle of Community.”
11
143. This UC Davis unconstitutional manifesto entitled “UC Davis Principle of
12
Community” is a UC Davis administration tool of oppression and malicious prosecution of
13
Christians, and any employee who has complained against the corrupted UC Davis
14
15 administration.
16 144. The scenario of attacking employees with this manifesto is simple. The
17 “accusation of racism, bigotry, violence”; then, Policy 1616 and Policy 380-15; then, the witch
18 hunt began with a witch hunter assigned by UC Davis administration executives . In charge of
19 the UC Davis manifesto entitled “Principles of Community” is Associate Executive Vice

20 Chancellor Rahim Reed. Rahim Reed is a very well-educated person. His only job for
21 $173,000.00 is to maintain and make sure that this unconstitutional tool is in motion, visible, and
22 inflicting fear in anyone who dares to criticize the UC Davis administration, point to a misuse of
23 university resources, or note a violation of law. In February 2008, this unconstitutional
24
manifesto and the tools of oppression were forcibly incorporated into UC Davis employees’
25
job description.
26
145.. In February 2011, Katehi, together with Rahim Reed, implemented an
27
unconstitutional (under both the Federal and California State Constitutions) policy incorporated
28

Page 47 of 48
1 into the “Principles of Community.” This “UC Davis Principle of Community” labeled
2 “CHRISTIANS AS A OPPRESSORS.” After the protest of the Alliance Defense Fund, a
3 Christian legal group, the definition of Christians as oppressors was removed from the manifesto
4 entitled “UC Davis Principle of Community.” However, Chancellor Katehi is still in power, and
5
Rahim Read still maintains the unconstitutional UC Davis Manifesto for $173, 000.00 per year,
6
spreading hate and intolerance across UC Davis. Labeling Christians as oppressors was nothing
7
else but Linda Katehi’s and Rahim Read’s ideological invitation for religious and political
8
cleansing in the UC Davis campuses .
9
146. The March 23, 2007, Letter of Intent to Suspend AND Notice of
10
Reassignment was signed by Interim Manager of the Plant Operation and Maintenance
11
Department Charles Witcher stated:
12
“You have a right to respond to this notice of intent to suspend either orally or
13
in writing. Such response must be received within eight (8) calendar days from
14
15 the date of issuance of such notice by your Official Reviewer — Robert
16 Taylor, Assistant Director, H&C. Mr. Taylor can be reached by telephone at
17 916-7342570. His mailing address is UCDMC, Administrative & Professional
18 Services, FSSB Suite 2100, and Sacramento, CA 95817.
19 In the event this intended action is taken, you will have the right to request
20 review of the action under Personnel Policies for Staff Members 70,
21 Complaint Resolution. If you wish to request review of the final action, you
22 must do so in writing as explained in the above policy, using the appropriate
23 complaint form. Your written request for review must be received in the
24
Employee & Labor Relations Office no later than 30 calendar days from the
25
date of the letter of suspension.”
26
147. Director Robert Taylor was one of the individuals who carry out
27
retaliation against Plaintiff and Buckans in December 2006 –March 2007. . On March 30, 2007,
28

Page 48 of 49
1 Plaintiff submitted to Director Robert Taylor his 59-page Appeal Letter from Witcher’s Letter of
2 Intent to Suspend and Notice of Reassignment. Director Taylor acted as Skelly Reviewer.
3 Director Taylor denied Plaintiff’s appeal on April 16, 2007. On the same day, Charles Witcher
4 signed a Letter of Three Days of Suspension Without Pay and Notice of Reassignment to
5
Plumbing/HVAC Shop beginning on April 20, 2007.
6
7 The 2007 Complaint - Step I and Step II under the UC Davis Personnel Policies for
Staff Members PPSM 70,
8
10 148. The University of California Personnel Policies for Staff Members PPSM
11 70, Complaint Resolution, or Administrative Remedies are main subject in the Palmer v.
12 Regents of the University of California, 107 Cal.App.4th 899, 132 Cal.Rptr.2d 567 (Cal.App.
13 Dist.2 04/08/2003) and Janet Campbell v. Regents of the University of California (Supra
14 S113275).
15 149. On April 19, 2007, Plaintiff filed Step I Complaint under PPSM 70 from
16 Witcher’s and Taylor’s decisions. Again, Director Robert Taylor was assigned as the Reviewer
17
for the Step I Complaint under PPSM 70 and denied Plaintiff’s Step I Complaint on May 10,
18
2007.
19
150. On April 20, 2007, after one month of administrative leave Plaintiff
20
reported himself to UCDMC Plumbing/HVAC Shop per Charles Witcher’s April 16, 2007,
21
Letter of Suspension and Notice of Reassignment. Plaintiff in HVAC shop was assign to monitor
22
and dispatch critical alarms on the day shift in UC Davis Medical Center via the computer
23
Metasys System. The Plumbing/HVAC shop Manager was Patrick Putney with Senior
24
Development Engineer and Shop supervisor was Dorin Daniliuc.
25
UCDMC Plant Operation & Maintenance Interim Manager Charles Witcher in his March 23,
26
27
2007
28 The 2006-2007 Annual Employee Performance Review

Page 49 of 50
1 151. Three months later, after Plaintiff was defamed, defaced, and portrayed as a bigot,
2 racist, and violent employee, making him look like a guard from a Nazi concentration camp or a
3 KKK member and after the letter which was threating to terminate Plaintiff’s employment,
4 suspend, or reassigned Plaintiff to a different shop on July 25, 2007, Charles Witcher signed
5 Plaintiff’s Employee Performance Review (Evaluation) for the 2006/2007 working period.
6 152. To Plaintiff’s disbelief, his Employee Performance Review grade was
7 “Meets Expectation” with comments that were better than what Plaintiff received in the previous
8 annual evaluations. This should have ended the story, Plaintiff’s suspension should have been
9 null and void, and Plaintiff should have been permitted to return to his normal duty in the Central
10 Plant. In Jensen v. Hewlett-Packard Co., 14 Cal. App. 4th 958, 18 Cal. Rptr. 2d 83
11 (Cal.App.Dist.4 03/30/1993) the Court ruled:
12
“In light of the multitude of laws designed to protect the employee from
13
14
oppressive employment practices,*fn2 evaluations serve the important
15 business purpose of documenting the employer’s hiring, promotion, discipline
16 and firing practices. Moreover, the laudable practice of evaluating employees
17 is to be encouraged for other important reasons. The performance review is a
18 vehicle for informing the employee of what management expects, how the
19 employee measures up, and what he or she needs to do to obtain wage
20 increases, promotions or other recognition. Thus, the primary recipient and
21 beneficiary of the communication is the employee.”
22
153. Plaintiff 2006/2007 Evaluation stated:
23
24 “Jerry is a very knowledgeable and effective central plant operator. He is very

25 thorough in his operation and maintenance performance. He assists the
26 maintenance personnel when requested to do so. . He can be trusted to make
27 the right operational decisions and keep management informed of the status of
28

Page 50 of 51
1 the plant. Jerry is committed to the success of the central plant and the medical
2 center. His communication skills and professionalism toward some of his co-
3 workers needs some improvement.
4 Jerry is talented, precise and his daily paper work is excellent. He
5 communicates very well and always passes on information from his shift,
6 leaving detailed messages with the Central Plant operators.
7
8
Jerry was very instrumental in the setup of the computer and office area for the
9
Building Automation Monitoring. He has shown a strong knowledge of
10
computer software and hardware. He has been able to solve many computer
11
problems and install software programs when needed.
12
13
His overall job performance is outstanding. He is always willing to accept
14
extra work and is very dependable.”
15
16
The Annual Employee Evaluation period in UC Davis is from July 1 to June 30 next year and
17
had three grade levels: “Exceeds Expectation,” “Meets Expectation,” “Does Not Meet
18
Expectation.” Meets Expectation it was what an employee gets because of pay raises related to
19
evaluations. Plaintiff also received his normal wage increase due to receiving “Meets
20
Expectation” annual review.
21
After several time extensions and unsuccessful attempts to mediate the conflict through the HR
22
Mediation Office, on August 31, 2007, Plaintiff submitted to HR a Labor Relation Step II Appeal
23
from Director Taylor I Step Decision HR Case No: 03-PPS-013-06107. According to the UC
24
PPSM 70-Step II Review by Complaint Resolution Officer, the Complaint Resolution Officer
25
26 must convene a Step II meeting within 20 calendar days of the appeal to Step II. According to
27 HR Labor Relation Supervisor Mike Garcia, HR had an enormous problem finding anyone to act
28 as Complaint Resolution Officer to conduct a Step II hearing, which was required to include an

Page 51 of 52
1 investigation and witnesses interview.
2
The 2007 Complaint Step II Review PPSM -70
3
4
154. On November 13, 2007, HR Labor Relation Supervisor Mike Garcia
5
assigned UCDMC Director Mike Boyd as Step II Compliant Resolution Officer (CRO) to hear
6
Plaintiff’s case of unlawful suspension and reassignment. Mike Garcia wrote in his letter to Mike
7
Boyd who was listed in FAC and SAC as an individual Defendant.
8
“The Office of Labor Relations received the enclosed complaint filed in
9
10
accordance with Personnel Policies for Staff Members (PPSM), Complaint
11 Resolution 70 (CR 70). Jaroslaw Plaintiff’s complaint was reviewed at the Step
12 I level and a Step Response was issued by Assistant Director, Robert B.
13 Taylor. Jaroslaw Plaintiff was not satisfied with the Step I Response and has
14 filed a timely appeal to Step II. “In accordance with CR 70 and UCD
15 Procedure 70.2, you have been appointed as the Complaint Resolution Officer
16 (CRO) for the Step II review of the above referenced matter. In accordance
17 with CR 70 and UCD Procedure 70.2, you have been appointed as the
18 Complaint Resolution Officer (CRO) for the Step II review of the above
19 referenced matter. As the CRO, you are charged with convening a Step Il
20
meeting. Please convene a Step II meeting on or before December 3, 2007.”
21
22 155. Mike Boyd in the period of 1998 to 2014 held the title of UC Davis
23 Medical Center Executive Director, Facilities Planning, Design and Construction. By his duty, he
24 was directly involved in construction of the Central Plant, commissioned in 1998. Director Boyd
25 is solely responsible, together with colleague UCDMC Director Robert Taylor, Director Shelton
26 Duruisseau PhD, UCDMC Plant Operation and Maintenance (PO&M) Manager and Defendant
27 Charles Witcher, and UCDMC PO&M Principal Engineer Mike Lewis for unlawful—under state
28

Page 52 of 53
1 and federal law—massive machine oil discharge to the Sacramento or American River via city
2 storm for seven years without any consequences and including effort to cover up the crime.
3 156. The scheduled Step II hearing with Director Mike Boyd took place on
4 December 7, 2007, and he issued the decision on December 18, 2007. Mike Boyd in his biased
5 and outrageous decision did not even bother to address Plaintiff’s abrupt removal from the
6 Central Plant and move Plaintiff to Plumbing/HVAC due to the retaliation and witch hunt
7 orchestrated by him, Shelton Durruisseau, Robert Taylor, Defendant Cindy Oropeza, and others.
8 In 2007, besides holding the Director position, Mike Boyd was Equal Opportunity Committee
9 Divisional Representative together with Director Shelton Duruisseau PhD and Defendant listed
10 as individual Defendant in FAC and SAC Cindy Oropeza.
11 157.. Director Boyd’s decision in the Step II Appeal was sent to Plaintiff
12 on January 2, 2008, with a cover letter from HR Labor Relation Supervisor Mike Garcia, which
13 was sent to Director Shelton Duruisseau Ph.D and Director Robert Taylor. Plaintiff was outraged
14 by Boyd’s decision after receiving a glowing 2006/2007 Employee Performance Review
15 (evaluation) and on January 28, 2008, Plaintiff responded to Boyd’s decision with a 24-page
16 letter. In his letter, Plaintiff wrote to Boyd citing Jensen v. Hewlett-Packard Co., 14 Cal.
17 App. 4th 958,18 Cal. Rptr. 2d 83 (Cal. Ct. App. 1993;
18 “I could only speculate that you and others are lacking any knowledge of UC
19 policies and procedures in regards to employer-employee relation. Your, and
20 others, complete disregard to the importance of the Annual Employee
21 Performance Review established by the UC and affirmed by the California,
22 and other states, appellate courts is very disturbing and unacceptable.
23 Your decision is very biased and is a continuance of the non written “witch
24 hunt “policy affirmed by some individuals from the UCDMC HR Department.
25 This case is not a court case. However, it looks like that this case won’t end
26 inside the UC system because of deliberate bias and lack of any good faith
27 from the UCDMC Management to end this case.”
28

Page 53 of 54
1 158. Plaintiff’s January 28, 2008, response to Boyd was CC’ed to Judith
2 Boyette. UC Vice President of HR; Robert J. Loessberg-Zahl, Assistant Executive Vice Chancellor
3 of UC Davis; Anna Orlowski, Health System Chief Counsel; Sh e lton Du ruisseau , Dire ctor
4 o f UCDMC; Robert Taylor, Director of UCDMC; Gloria Alvarado, Director of HR
5 at UCDMC; Michael Sheesley, Manager of HR at UCDMC; and Mike Garcia, Supervisor
6 LB HR at UCDMC; Bettye Andreos of the Pathology Dept.; Office of the Reagents and UC
7 General Counsel Office; and Charles Witcher, UCDMC PO&M Manager.
8 2007 Promotions
9 159. In addition to Plaintiff’s suspension and reassignment and his appeals,
10 individuals who were responsible, directly or indirectly, for the massive oil discharge to the
11
Sacramento River via city storm drain for the seven years enjoyed promotions and wages
12
increases. The individual Defendant listed in SAC and FAC Charles Witcher was promoted by
13
Director Robert Taylor to the permanent position of the UCDMC Plant Operation and
14
Maintenance Department Manager, Steve McGrath was promoted by Director Robert Taylor to
15
UCDMC Central Plant Manager position, Defendant Stephen Chilcott was promoted to a
16
UCDMC HR Labor Relation Manager position, Dennis Curry, participant in the 2005 cover-up
17
investigation related to the illegal oil discharge to the river, was promoted by Director Robert
18
Taylor to UCDMC PO&M Department Assistant Manager (Defendant Charles Witcher’s
19
Assistant). Dennis Curry was dismissed in June 2012 two weeks before he retired for taking
20
21 money from contractors. Dennis Curry was Plaintiff’s superior from 2007 to 2012.
22 Furthermore, in July 2007, UCDMC Plumbing/HVAC Shop Supervisor Dorin Daniliuc
23 (Defendant in this case), who operated his private HVAC business and his church business on
24 university time, disclosed to Plaintiff that he was given his supervisor position in UCDMC
25 HVAC shop by UCDMC Director Robert Taylor and Director Shelton Duruisseau Ph .D in
26 exchange for installing and maintaining heating and air-conditioning equipment in their private
27 residences. It was reported to UC Davis Chief Compliance Officer Wendy Delmendo in July
28

Page 54 of 55
1 2011.
2 The Complaint Step III–ARBITRATION–UC Davis Policy PPSM 70 Filed On January 29,
2008 Case No. : 03-PPS-013-06107
3
4 160. Outraged by Director Boyd’s Step II Decision, Plaintiff filed with

5 UCDMC HR Labor Relation the Step III Appeal on January 29, 2008, which was Arbitration.
6 Plaintiff in his request for Arbitration attached his 24-page response to Director Boyd’s Step II
7
Decision. Plaintiff deliberately chose the University of California arbitrator instead of an outside
8
arbitrator, showing the extent to which the university system is corrupted.
9
The Arbitration Step III Appeal hearing was set for November 3 & 4 2008, 1 ½ years after my
10
suspension and reassignment from the Central Plant to HVAC shop.
11
UC Davis assigned to the hearing two UC Davis Campus HR attorneys who were also -licensed
12
by the California State Bar: UC Davis HR Assistant Director Dawn M. Capp J.D and HR
13
Analyst VII, Danesha Nichols J.D (Danesha Nichols is listed a s an individual Defendant in this
14
FAC and SAC ).
15
161. As Arbitration Step III Appeal Hearing Officer, UC Davis assigned
16
17 Connie Melendy, Assistant Vice Provost from the UC Davis Academic Personnel Offices
18 of the Chancellor and Provost.
19 162. The coordinator on the UC Davis Medical Center site was the newly
20 promoted HR Labor Relation Manager and attorney at law listed defendant in FAC and SAC
21 Stephen Chilcott J.D.

22 163. In 2007 and 2008, Plaintiff had a very hard time understanding why the
23 three different appeals pursuant to UC Davis Complaint Resolution Policy PPSM 70 had to
24 continue after Plaintiff was provided with a good 2006/2007 evaluation. Plaintiff in 2008 made
25 an offer to settle the cases without demanding reassignment back to his previous position in the
26
Central Plant or a big monetary settlement. In preparation for the Appeal, Plaintiff reexamined
27
and reviewed all the documents he had and came to the conclusion that the point of dragging
28

Page 55 of 56
1 Plaintiff to the arbitration was to further humiliate him and that arbitration would end with same
2 result as Taylor’s and Boyd’s decisions in Step I and Step II Appeals. Thereafter, Plaintiff most
3 likely would be fired under false pretenses with an arbitrator slanderous decision as a backup.
4 For the arbitration hearing, Plaintiff ordered a sworn Court Reporter at his own all expense
5
because the university refused to share the cost.
6
164. In 2007 and 2008, Plaintiff did not know that his removal from the Central Plant
7
and reassignment to the HVAC shop served a different purpose than he suspected. Plaintiff also
8
did not know that, in January 2007, the Defendant hired Charles Robinson as the University of
9
California General Counsel. Robinson was previously employed as a General Counsel with
10
California Independent System Operator (ISO) and, apparently, the Defendant were hoping to
11
get a new contract for the sale of electric power with ISO by hiring him. The power sale contract
12
with Sacramento Municipal Utility District (SMUD) and ISO was lost in 2003 or 2004, causing
13
the University to lose millions of dollars in revenue. Robinson was the right person to take care
14
15 of business and bring the revenue back, regardless of the fact that the UC Davis Central Plant
16 was not legally qualified to sell power to SMUD via ISO.
17 165. To prepare himself for the arbitration hearing, Plaintiff reviewed the
18 University of California and UC Davis policies and was trying to find the University of
19 California policy that could allow management to remove and reassign an employee to the
20 different shop against that employee’s will and as a disciplinary measure.
21 166. The Personnel Policies for Staff Members (PPSM) 62 Corrective Action
22 Policy had no such option.
23 167. Plaintiff found only the Principles of Reassignment for the UC Davis
24
Medical Center on the UC Davis Website, which had nothing to do with disciplining employees,
25
but forgot to present it during the arbitration.
26
168. Plaintiff submitted by e-mail the mentioned UCDMC Principles of
27
Reassignment to Hearing Officer Ms. Connie Melendy on November 9, 2008.
28

Page 56 of 57
1 Ms. Melendy responded to Plaintiff e-mail with thanks for the Principles and cc’d my e-mail to
2 Defendant Danesha Nichols and Stephen Chilcott who from the beginning of the appeals process
3 together with Taylor and Boyd knew that the reassignment was unlawful and against any UC
4 Policies—especially Stephen Chilcott and Danesha Nichols, who were HR employees and
5
licensed by the State Bar with J.D. degrees. Chilcott was trying to control damages, but it did not
6
go far.
7
169. It was lucky for Plaintiff that he found the information and sent it to
8
Connie Melendy.
9
170. On December 19, 2008, Connie Melendy sent her Step III–Arbitration
10
decision to Plaintiff. The decision was not much different than the March 2007 “Witch Hunt”
11
decision issued by Bettie Andreos or Charles Witcher’s March 2007 Letter of Intent to Suspend
12
and Notice of Reassignment with exception of the following statement “The reassignment was
13
not for just cause. The remedy shall be to allow Mr. Plaintiff to return to Central Plant if he
14
15 desires.”
16 171. The Step III –Arbitration decision did not leave any doubt for Plaintiff that the
17 assigned University Hearing Officer would rule against Plaintiff if Plaintiff had not, by pure luck,
18 found the UC Davis Principles of Reassignment and sent it to Ms. Connie Melendy after the
19 Arbitration hearing. UC Arbitrator had no choice but to rule against the University and order the
20 University to let Plaintiff return to the central plant. To justify her decision against the University
21 and in favor of Plaintiff, Ms. Melendy, on pages 9 and 10 of her decision, explained in detail the
22 UC Davis Personnel Policies for Staff Members (PPSM) 62. Corrective Action —
23 Professional and Support Staff. These policies were well known prior to the arbitration for
24
witch hunter Bettye Andreos, Charles Witcher, Director Shelton Duruisseau, Director
25
Robert Taylor and Director Steven Chilcott, who hunted down Plaintiff and his coworker
26
William Buckans, and caused Plaintiff enormous humiliation, stress, anxiety, fear of losing
27
his employment and financial loss.
28

Page 57 of 58
1 Furthermore, Hearing Officer Melendy brought Waszczuk’s Employee Performance Reviews
2 into her decision as follows:
3 Mr. Waszczuk’s past record, in the form of his documented performance
4 history, is remarkable for a complete absence of problems regarding
5
threatening behavior or inappropriate language prior to the corrective action
6
(Exhibit J1/1/ 2). He received “very good” performance ratings in 2000 and
7
2001, and “outstanding” ratings in 2002 and 2003. Beginning with the 2004
8
review, the rating categories on the performance forms were changed to
9
eliminate the “outstanding” category and substitute with a “meets expectation”
10
or “does not meet expectation” option for the supervisor. Thereafter, Mr.
11
Waszczuk consistently received “meets expectations” ratings for each year
12
through 2008. Many positive comments appear for each year, such as the
13
following comment that was consistently made each year of his employment in
14
15 the Central Plant:
16 “Jerry can be counted on to make the right operational decisions regarding the
17 plant, and to keep his supervisor informed of the operational status of the plant
18 and its equipment. Jerry is a valuable employee committed to the future
19 success of the Medical Center.” (Performance reviews from 2000, 2001, 2003,
20 2004, 2005, 2006)
21 There are no comments regarding threatening behavior or inappropriate
22 language in any of the annual evaluations from the time of Mr. Waszczuk’s
23 first evaluation in 2000 and including the 2006 evaluation that was written
24
prior to the suspension and reassignment. The University presented no
25
evidence to show that there were verbal or written discussions or performance
26
appraisals intended to caution or warn Mr. Waszczuk about inappropriate
27
behavior prior to the October 2007 evaluation (University Exhibit 13), which is
28

Page 58 of 59
1 a cumulative review by three supervisors (Central Plant supervisors Tom
2 Kavanaugh, Steve McGrath and HVAC Plumbing supervisor Patrick Putney).
3 That review, while overall very positive, contains the following comment
4 about Mr. Waszczuk’s behavior: ‘His communication skills and
5
professionalism toward some of his co-workers needs some improvement.’ His
6
overall job performance for 2007 is rated outstanding, with notations that he is,
7
‘... a very valuable member of the staff since joining the section in April... is
8
talented... accepts extra work... is dependable.’”
9
10 The Settlement –Agreement with the Regents of the University of California, Signed in
February 2009
11
12
172. After prevailing in the arbitration process, Plaintiff did not go back to the Central
13
Plant where his position was already replaced and where a group of employees from the Jackson
14
area who were hired fraudulently were helping Directors Shelton Durrisuseau, Robert Taylor,
15
Mike Boyd, and Charles Witcher to hunt down Plaintiff and William Buckans, which did not
16
17 incentivize Plaintiff to go back to the Central Plant.
18 173. Further, UC Davis assigned arbitrator Connie Melendy; in her 2008 decision,
19 besides the slanderous and untrue accusation aimed at Plaintiff, she suggested and strongly advised
20 Plaintiff to consider very thoughtfully and seriously, whether the environment of the
21 HVAC/Plumbing Shop, with its current supervisor and colleagues, would be more conducive to
22 Plaintiff’s future success. Under the best of circumstances, it is difficult to return to a worksite
23 where there is “animosity,” as Connie Melendy described, instead referring to it as a hostile work
24 environment that caused later the suicide one of the Central Plant Operator Todd Goerlich .
25 In April 2007 Todd Goerlich was hired as a Plaintiff’s replacement.
26
174. Plaintiff seriously considered the Arbitrator, Connie Melendy’s, suggestions to stay
27
permanently in the HVAC shop and never expected that two and one-half years after Plaintiff
28

Page 59 of 60
1 signed Settlement-Agreement with Defendant that Plaintiff would be hunted down like an animal
2 by same perpetrators as in 2006–2007.
3 175. The newly promoted UCDMC HR Labor Relations Manager and listed individual
4 Defendant in this FAC and SAC , Stephen Chilcott, solicited to settle the case.
5
176. In exchange for not going back to the Central Plant, Plaintiff was “promoted” from
6
his Central Plant Operator position to an indefinite, exempt Associate Development Engineer
7
position with an increase in the annual base salary of $8,000.00 ($70,000.00/year), which sounded
8
good to Plaintiff, but the annual gross income turned out to be a lot less then Plaintiff was earning
9
as a shift worker in the Central Plant with swing shifts and night differential, holiday pay, and
10
overtime pay.
11
177. For example, Central Plant Operator Chris Gangl’s annual earnings in 2008 was
12
$84,000 in comparison with Plaintiff’s annual earnings $63,900 ; in 2009 his earnings was
13
$80,300 in comparison with Plaintiff’s annual earnings of $82,600( Plaintiff’s earning was
14
15 included $ 13, 500 one time extra pay Plaintiff received 2009 Settlement –Agreement) ; in 2010
16 it was $80,500 in comparison with Plaintiff’s annual earnings of $70,000 ; in 2011—after the 2010
17 blackmail pay-raise of 12% (a six steps pay-up pay raise and an additional step in May 2011),
18 Chris Gangl’s annual earnings jumped to $100,000; in comparison with Plaintiff’s annual earnings
19 of $ 63,300; in 2012, Gang’s earnings was $97,300 in comparison with Plaintiff’s annual earnings
20 of 70,000;( the last year of Plainiff’s employment) in 2013, it was $98,700; and in 2014, it was
21 $104,000.
22 178. This was the reason why in March 2011, Plaintiff sent a letter to UC Davis Medical
23 Center Plant Operation and Maintenance Department Head Charles Witcher and asked respectfully
24
for Charles Witcher to increase Plaintiff’s base salary accordingly, in one step (not six steps )
25
from Middle Step of $71,640/year to the 3rd Step of $80,922/year.
26
179. Plaintiff had no intention to pursue his request if denied because of the Settlement-
27
Agreement, which stated that Plaintiff was to be provided wages of $70,000/year. It was an error
28

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1 or misclassification in the Settlement-Agreement, because this was not a step in the Associate
2 Development Engineer title classification code 7182. The first step was $62,352/year and the
3 middle step was $71,640/year, which was closer to what Plaintiff was to receive pursuant to the
4 2009 Settlement-Agreement. Plaintiff’s wages were increased in May 2011 to $71,640.
5
180. If Plaintiff were still to be employed with UC Davis Medical Center, it would be
6
most likely that Plaintiff’s salary would change to $76,600/year without a step increase, because
7
the general classification of the Title Code 7182 has been changed for Middle Step, from
8
$71,640/year to $76,600/year.
9
181. The above example of Central Plant Operator Chris Gangl, who had a lot less
10
experience and no formal education in Power Plant operations, clearly proves the earning potential
11
that Plaintiff sacrificed in not going back to the hostile work environment created and permitted in
12
the Central Plant by the Defendant, not to mention that Central Plant Operator’s nonexempt
13
position is classified as lower than the exempt Associate Development Engineer position.
14
15 182. The other issue was that some Central Plant operators were hired 10 years after
16 Plaintiff was hired, and they received in December 2010 the 12% wage increase, and in May 2011,
17 the additional pay raise. Not one UC Davis skilled trade nonunion employee in December 2010
18 was dreaming to receive one penny in wage increase because of the strict budget constraint and
19 furlough of UC campuses. Some of employees were employed for more than 20 or 30 years and
20 were not considered for any wage increase in 2010.
21 183. Besides the $70.000.00 per year salary, Plaintiff received in the Settlement-
22 Agreement a small compensation in the amount of $13,500.00 for lost wages due to the witch hunt,
23 which resulted in suspension without pay and refinement in March 2007.
24
Shortly after Plaintiff signed the February 2009 Settlement-Agreement, the Regents of the
25
University of California UC Davis HR Assistant Director Dawn Capp, UC Davis attorney in
26
arbitration, lost her job. Most likely, Ms. Capp was fired or forced to quit a few months after
27
arbitration. The Hearing Officer, Ms. Connie Melendy, disappeared from the UC Davis landscape
28

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1 in 2010.
2
184. The 2009 Settlement-Agreement, Paragraph No. 19, states “CALIFORNIA LAW
3
This Agreement is made and entered into in the State of California and shall in all respects be
4
interpreted and enforced in accordance with California law.
5
6 185. At the time when Plaintiff signed the Settlement-Agreement, February 2009,
7 Plaintiff understood that the Defendant, if alleged of any violation of the Settlement-Agreement
8 by Plaintiff, would inform Plaintiff if Plaintiff had breached or violated the signed Settlement-
9 Agreement. Then, if Plaintiff disagreed, then the Defendant had the right to enforce the agreement
10 in a court of law. This was how Plaintiff understood this employee–employer contract. The
11 Defendant never alleged in one word anywhere that Plaintiff violated the signed Settlement-
12 Agreement, but freely slandered and defamed Plaintiff in at least six pseudo-investigation reports,
13 multi-investigatory leave letters, the April 2012 notice of intent to suspend without pay, the
14 September 2012 notice of intent to terminate Plaintiff’s employment, and the December 2012 letter
15
of employment termination.
16
The Working Environment In The UC Davis Medical Center Plumbing/HVAC
17
187. By title Associate Development Engineer title , Plaintiff basically became
18
Assistant for Plumbing/HVAC Shop Manager Patrick Putney who held the title of Senior
19
20
Development Engineer. Patrick Putney, who is also listed as the Defendant in this FAC and
21 SAC got very upset for reasons unknown to Plaintiff when he got news that Plaintiff settled the
22 case and became an exempt employee in his shop. Putney complained about to HR and started
23 pitting Shop Supervisor Dorin Daniliuc against Plaintiff .Daniliuc was given his supervisor job
24 in Plumbing job by Directors Robert Taylor and Shelton Durusseau in exchange for HVAC
25 service Daniluc provided to them in in their private residences by his private HVAC business
26 188. Everything settled down, and Plaintiff became very n isolated employee in
27 a small glass cage and was monitoring and dispatching UC Davis Medical Center critical alarms,
28

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1 reviewing and closing work orders, backing up servers, and assisting shop maintenances with
2 shutdown and start-up HVAC equipment in hospital via computer, making temperature
3 adjustments in hospital patients’ rooms. Plaintiff was never invited to morning crew meeting but
4 did not complain.
5
189. From the beginning of Plaintiff’s new assignment, Plaintiff noticed that
6
the working environment was quite strange and unusual. The HVAC shop looked akin to an
7
unsupervised junkyard with filthy bathrooms, no showers for plumbers who were being exposed
8
every day to the hospital environment, no locker room, and no lunch room or break room to
9
consume meals or take rest breaks. The term “housekeeping” did not exist in the HVAC shop
10
manager’s or his assistant’s vocabulary. Both individuals were more concerned with how to
11
make a few extra bucks on the company’s time. Patrick Putney was cheating his employer of the
12
parking fee by hiding his private vehicles inside the shop. He was bringing chickens, ducks,
13
goats, sheep, and roosters from his house in his car trunk and was selling them to UCDMC
14
15 employees. Putney was trapping pigeons on the UCDMC roofs, bringing his kids to the shop for
16 babysitting and schooling, and selling soda from his private vending machine that he brought to
17 the shop.
18 Plaintiff later described his new working environment as a gypsy village in Eastern Europe,
19 which closely resembled the one portrayed by Sasha Cohen in the movie Borat.
20 190.. Dorin Daniliuc, who was and still is Patrick Putney’s assistant,
21 concentrated most of his attention on his private HVAC business, which he operated on company
22 time via cell phone; he would often disappear for most of the day with his business-equipped
23 van. Daniliuc was also bringing some foreign workers (Romanian nationals) to the shop to repair
24
his private vehicles. Daniliuc did not care much about what people thought about his unrelated
25
employment activities in the workplace. Daniliuc installed and maintained HVAC equipment for
26
two important UCDMC directors in their private residences, which apparently assured him of his
27
importance; his understanding was, “It’s nobody’s business what I am doing on company time.”
28

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1 To make sure that I got his message about his important connection with the directors, he sent
2 Plaintiff an e-mail dated July 9, 2007, from Director Robert Taylor, inviting him to a Falkland
3 Island, South Georgia, and Antarctica brown bag luncheon presentation
4 Dorin Daniliuc also ran the Romanian Church business affairs on company time and did not have
5
much time to oversee the crew and take care of his duties.
6
. 191. Plaintiff did not much attention to his supervisor’s activities and only
7
once in a while reminded Daniliuc about his duty but had no major problem with Daniliuc,
8
Putney, or his coworkers in the shop until the events in March 2011, which were triggered by a
9
secret 12% wage increase in December 2010 provided by Associate Vice Chancellor Shelton
10
Durruiseau, Director Robert Taylor, Director Mike Boyd and HR Director Stephen Chilcott for
11
the UCDMC Central Plant Operators.
12
13
The December 2010 secret 12% Pay Increase for UCDMC Central Plant Operators,
14
192. Plaintiff’s employment with the UC Davis Medical Center would have
15
lasted longer, and most likely Plaintiff would retire from University at age of 66 without any
16
problems. In March 2011 Plaintiff was 60 years old and it was Plaintiff goal to retire from
17
18
University six years later. . It did not happen and Plaintiff’s employment was converted by the
19 Defendant’s several agents and officers into Hell on the Earth.
20 193. In September 2010, one of the UCDMC Central Plant Operators, Jeff
21 Lancaster, discovered on the Sacramento Bee Webpage (Salary for Public Employees in
22 California) that Plaintiff’s 2009 annual salary was $82,295.00, not knowing that Plaintiff’s 2009
23 salary was a combination of Plaintiff’s $70,000.00 base salary and $13,500.00 extra pay per
24 February 2009 Settlement –Agreement for Plaintiff’s lost wages due to Plaintiff’s unlawful
25 reassignment from the Central Plant to the Plumbing/HVAC Shop in March 2007.
26 194. Jeff Lancaster was one of the few from the Central Plant who in
27 2005/2007 was used by UCDMC directors, Shelton Duruisseau, Robert Taylor, Mike Boyd and
28

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1 others to help them hunt down Plaintiff and William Buckans in 2005–2007 and to remove
2 Plaintiff from the Central Plant.
3 195. In the September 2010 undated petition, four undersigned individuals
4 attacked Plaintiff by making false statements about Plaintiff’s wages in relation to Metasys
5
System Operation on the day shift.
6
196. These undersigned petition individuals were the same individuals who,
7
together with Charles Witcher, attacked me and my coworkers in 2006/2007 and helped him to
8
abruptly remove Plaintiff from the Central Plant. It is suspected that the author of the petition
9
was bullied and harassed his coworker, Todd Georgic, who committed suicide. His words in the
10
petition “It is miracle that nothing tragic has happened yet” sounded like a threat. Todd
11
Georlich’s death was something very tragic that happened soon thereafter.
12
197. This tragic event was never investigated by the Human Resource
13
Department investigators. It is worth mentioning that Todd Georlich was the former coworker
14
15 and fried of the Central Plant manager Steve McGrath from his previous employment. A few
16 years back, Steve McGrath’s first wife committed suicide; now, his friend and former coworker
17 After the Todd Georlich suicide traumatized Central Plant Manager Steve McGrath tried
18 unsuccessfully to get a job in the UCDMC Carpenter shop and later in the HVAC shop.
19 198. Jeff Lancaster agitated another three individuals, Chris Gangl, Timothy
20 Cooper and Greg Russ to write and sign a petition and demanding a $4.00/hour pay raise,
21 pointing at Plaintiff’s salary and stating in the petition that Plaintiff was paid $15,000.00 more
22 per year than Central Plant Operators. Beside Plaintiff’s wages, these individuals were very
23 dissatisfied that their help and sacrifices for directors. Shelton Duruisseau, Robert Taylor and
24
Mike Boyd did not do and good because Plaintiff and Buckans was not fired from their jobs in
25
2005-2007 due to a witch hunt, They constantly bragged about and bullied and harassed William
26
Buckans after Plaintiff left the Central Plant in 2007.
27
199. Plaintiff received the copy of the undated black –mail petition signed by
28

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1 them shortly after the petition was written. The petition was addressed to UC Davis Medical
2 Center Plant Operation and Maintenance Department Manager Charles Witcher who is the
3 defendant in FAC and SAC . Plaintiff showed the black –mail petition and gave a copy of it to
4 Charles Witcher’s assistant Dennis Curry, who visited Plaintiff’s new workplace.
5
200. Plaintiff briefly discussed the petition with Dennis Curry due to the fact
6
that there was a strict budget constraint on the University of California campuses and nobody
7
was getting a penny in wage increase. When Plaintiff later received the documents under the
8
Public Record Act related to this petition, Plaintiff found out that Charles Witcher’s, Director
9
Robert Taylor’s and others’ annual salaries were searched on the web by Lancaster, and the
10
search was submitted together with a petition to Witcher. The petition was the classic blackmail
11
demand for favors to cover up crime.
12
201. Shortly after the meeting with Dennis Curry , Plaintiff ignored and forget
13
about the whole petition. Dennis Curry was involved in the 2005 cover-up crime investigation
14
15 conducted by the UC Davis Chancellor’s office related to massive machine oil discharge to the
16 Sacramento River from the Central Plant.
17 202. However, Dennis Curry did not ignore Plaintiff’s discovery about the
18 blackmail pay increase petition and alerted Charles Witcher or Director Taylor a and the petition
19 for pay raise was rewritten and signed by 11 central Plant Operators .
20 203. The memo, letter, or petition, dated September 20, 2010, signed by 11
21 “Central Plant Operators” was addressed to CHARLES WITCHER, Manager of
22 PO&M,Department identified the subject matter as “…the monitoring of the Johnson Controls
23 Metasys Software program and dispatching of emergency and same day service calls to the Central
24 Plant during graveyard and weekend shifts.” In other words, the subject was the fact that the
25 Central Plant Operators covered shifts that Plaintiff did not work.
26 204. The memo, letter, or petition continued “…the Metasys and dispatching has
27 become a full time job to monitor and respond too (sic)...several years ago, we reached a point
28

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1 where we can no longer monitor these systems and operate, start, or stop the Central Plant. This
2 matter becomes critical when there is a casualty within the plant. We cannot troubleshoot and
3 respond to phone calls and Metasys alarms. It is a miracle that nothing tragic has happened
4 yet.” (Emphasis Added)
5 205. The letter, memo, and/or petition calculates the cost of “3 new employees”
6 to monitor the system for 24 hours over 3 shifts. .In their letter, memo, or petition, the plant
7 operators asked the employer to remove the Metasys monitoring obligation from the Plant, or in
8 the alternative, agree to give the plant operators raises of $4.00 per hour.
9 206.. CHARLES WITCHER sent the request to Director Robert Taylor ,
10 On November 18, 2010, ROBERT TAYLOR, the Assistant Director, Hospitals and Clinics, in the
11 Administrative and Professional Services arm of the employer, confirmed by email, that he was
12 just as knowledgeable of the situation as CHARLES WITCHER, and that he, MR. TAYLOR, was
13 in favor of the raise instead of addressing the serious issue raised in and by the petition.
14 Director Taylor did not address serious safety issue raised in the petition because was no serious
15 issue with the phone calls and Meatasys alarms.
16 207. The Central Plant Operation and the petition was just a black-mail
17 petition to get pay raise for something completely different than inability to operate the plant.
18 UCDMC Directors, Robert Taylor, Shelton Duruisseau Ph, D. Mike Boyd, Charles Witcher and
19 Stephen Chilcott did not have much choice. They bent to the petition demands and pay raise
20 most likely got approval from the UC Davis Chancellor’s office or the University of California
21 Office of the President due to the strict budget constraints and furlough on the campuses and the
budget crisis in the whole state, including State of California Courts.
22
23 208. The 12% pay raise for all Central Plant Operators was provided to all
24 Central Plant Operators. Some of them were hired a short time before the blackmail petition was
25 submitted, and it was unthinkable for anybody to get a 12% or six steps up pay raise as a non-
26 exempt union or non-union and even exempt University of California employee working only
27 for one or two years for University.
28

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1 209. The 12% instant pay raise for the 13-person crew was most likely
2 provided because the Defendant entered into negotiations with the Sacramento Municipal Utility
3 District and ISO for a new electric power sale contract, which it had lost in 2003 or 2004. The
4 Central Plant cogeneration facility was being operated at 1/3 of its capacity and was losing
5
millions of dollars every year and the Defendant did not take any chance that there could be any
6
disturbance in the power contract negotiation. Without any question, Defendant secretly
7
provided a 12% wage increase for the Central Plant crew, based on four operators’ blackmail
8
petition for a pay raise.
9
10
The Attorney Danesha Nichol’s Deployment From The UC Davis Campus to UC Davis Medical
11
Center Human Resources Department in October 2010
12
13
210. After Plaintiff’s conversation with Dennis Curry, UC Davis Health
14
System HR Executive Director Stephen Chilcott (defendant) requested that the UC Davis
15
Chancellor’s office deployed .Danesha Nichols, the listed Defendant in FAC and SAC to UC
16
Davis Medical Center to monitor the situation with the pay raise demanded by blackmail petition
17
for the Central Plant Operators.
18
211. Danesha Nichols was the UC Davis HR attorney who in 2007/2008 was
19
involved in Plaintiff’s Step III Appeal arbitration process against UC Davis Medical Center
20
management, and she was very familiar with the crime that was committed in the Central Plant
21
in the period of time spanning from 1998 to 2009 and Nichols was familiar with Plaintiff’s file .
22
212. Danesha Nichols arrived at UC Davis Medical in October 2010 with the
23
title of Investigation Coordinator in similar circumstances as Stephen Chilcott in 2005 and she
24
reported directly to Director Stephen Chilcott.
25
213. As Plaintiff stated previously, the UC Davis Medical Center’s newly built
26
in 1998 Cogeneration Power Plant/Central Plant was a pride and legacy left behind for former
27
UC Davis Chancellor Larry Vanderhoef and Shelton Duruisseau Ph.D., who was appointed to
28

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1 the Medical Board of California, Division of Medical Quality, by Governor Arnold
2 Schwarzenegger in 2004 and promoted in 2010 to Associate Vice Chancellor position. However
3 the Central Plant since 2003 did not generate millions of dollars in revenue as anticipated
4 because lack of power sale contract .
5
The December 2010 Central Plant Operator Locker Burglary
6
214. On December 17, 2010, Principal Engineer Mike Lewis who was in
7
charge of Central Plant issued a dramatic memo , stating,
8
“One of the Central Plant Operator’s locker was broken into and personal
9
effects were removed. This is a very serious offense and will not be tolerated.
10
This incident has been reported to UCDMC Police department and to UCDMC
11
Human Resources department for appropriate investigation and action. In my
12
entire career that consists of work at facilities both in the United States and
13
abroad I have never experienced an incident such as this. If the perpetrator is
14
15 found, appropriate action will be taken.”
16
215. Mike Lewis was Project Manager for Central Plant construction, start-up, and
17
commissioning. Mr. Lewis was the person who, by his title, position, and duty, was most responsible;
18
“he was obligated” to stop machine oil discharge from the leaking Cooling Tower gear boxes from
19
dispensing into the river and soil to prevent contamination of the natural environment. Mike Lewis, as
20
Principal Engineer, grossly neglected his duty and did not take any preventive measure to stop the oil
21
leak and discharge into the natural environment. Mike Lewis had no problem noticing William
22
23
Buckans’s feet elevated on the console and viewed it as disrespectful to him but was completely
24 unable to notice William Buckan’s accident underneath the cooling tower’s oily surface. Mike Lewis
25 also did not observe—for 7 years—the badly designed cooling tower gear boxes and unlawful massive
26 machine oil discharge into the nearby river and soil surrounding the cooling tower. Apparently, he was
27 ordered to do nothing about by Director Taylor or Director Shelton Duruisseau Ph.D or Director
28

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1 Boyd.
2
The Central Plant Operator, Todd Goerlich’s Suicide on December 22, 2010
3
4 216. Five days after the Principal Engineer Mike Lewis issued his dramatic
5 memo about the incoming investigation to find perpetrator Central Plant Operator, Todd
6 Goerlich committed suicide. Then, the rest of the Central Plant Operators received a 12% pay
7 raise despite strict UC budget constraints and furlough in UC Campuses and no power sale
8 contract . Thereafter, everything got quiet. Nobody was questioned by an HR investigator or the
9 UC Davis Police Department about locker burglary. No more comments were made by any
10 Central Plant supervisors about Jeff Lancaster’s burglarized locker, no more dramatic memos
11
from the Principal were issued and Todd Georlich’s tragic death was quickly forgotten.
12
13 The Secret 12 % Pay Raise For Central Plant Operators –March 2011
14
217. Around March 5, 2011, Plaintiff somehow got into a conversation with
15
the operator from the central plant William Buckans about the December 2010 12% pay raise,
16
and Plaintiff received from Buckans a copy of the UCDMC Plant Operation and the letter from
17
18
maintenance manager Charles Witcher dated December 20, 2010, which confirmed a 12% pay
19 raise for the central plant operators.
20 218. The December 2010 12% pay raise that was secretly provided to central
21 plant operators was discriminatory to other non-union employees of the UC Davis Medical
22 Center who did not get one penny in wage increase in the last three years due to strict budget
23 constraints in the whole University of California system. The disclosure about the secret pay
24 raise for small groups of employees became a subject of discussion among workers at the other
25 shops in the UC Davis Medical Center. Plaintiff confronted his shop manager Patrick Putney and
26 Plaintiff asked Putney why the HVAC shop staff did not get a pay raise. Putney’s response was
27 that he knew about the pay raise, but was told to be silent about it to avoid any turmoil among
28

Page 70 of 71
1 the other shops’ workers. Following the discussion with Patrick Putney, Plaintiff wrote an eight-
2 page letter to the department manager about the central plant operators’ December 2010 pay
3 raise that was no longer a secret, and he asked department head Charles Witcher for a one-step
4 wage increase.
5
6
The Restricted Access to the UC Davis Medical Center Central Plant
7 in March 2011
8
219. Consequently, right after Plaintiff asked his supervisors about the secret
9
12% pay raise for the Central Plant Operators, Department Principal Engineer Mike Lewis
10
issued a memo dated March 11, 2011, instructing Central Plant crew to do the following:
11
12 “Please inform all Central-Plant personnel that access to the Central Plant is
13 restricted to operators on duty and vendors performing work requested by the
14 University. All operators not on duty and other personnel with no direct reason
15 to be in the Central Plant shall not be granted access to the Central Plant. If
16 illegal access is gained to the Central Plant please call 4-2555 for a non-
17 emergency event or 911 for an emergency.
18 “If an employee not on duty or other individuals with no direct need to gain
19
access to the Central Plant request access to the Central Plant please contact
20
Charles Witcher, Mike Lewis, or Dennis Curry for direction. Thank you.”
21
That was a shocking memo. Never before had access to the Central Plant been restricted for off-
22
shift personnel.
23
24 The March 13, 2011, Plaintiff letter addressed to UCDMC Plant Operation and Maintenance
Manager Charles Witcher
25
26
27 220. A few days after Mike Lewis issued the memo about access to the Central
28 Plant, Plaintiff on March 14, 2011, sent a letter to Charles Witcher and asked him respectfully

Page 71 of 72
1 for a one-step salary increase; Plaintiff also brought to Witcher’s attention safety and hygiene
2 issues in the HVAC Shop and mentioned Tod Georlich’s suicide, who was Plaintiff’s
3
replacement in the Central Plant in March 2007, and he did not survive hostility created by UC
4
Davis Medical Center management through unwritten policies and its own rules .
5
The Defendant’s response to March 13, 2011 letter addressed to Charles Witcher was
6
letter of suspension for 10 days without pay in May 2012, Defendant’s criminally
7
minded but unsuccessful provocation to kill Plaintiff on May 31, 2012 , UC Police
8
Poster with Plaintiff’s photo and description which was closely akin to FBI posters for
9
“Most Wanted “ criminals and terrorists and termination of Plaintiff ‘s employment on
10
December 7, 2012 at Plaintiff ‘s age of 61 and half not to mention one and half year
11
12 long Defendant’s psychological terror aimed at Plaintiff by Defendant’s agents and
13 officers .
14 Dear Mr. Witcher:

15
I hope it's not any surprise for you that an employee is getting concerned after
16
he found out or discovered that one group of employees in the same
17
department got quite secretly a significant wage increase (over 10%) and he
18
was left behind and forgotten and did not receive a penny in this share of
19
dollars.
20
21 It is appears that Cogen Operators wages under Title Code 8094 for Non —
22 Represented were increased from level 5. to level 11.0. (Six levels up)
23
I would not write this letter but money talk and stirring people mind and saying
24
more simply I just feel discriminated in this share of goods.
25
26 At the best of my ability to write, I will try to explain why I feel discriminated
27 and left behind like an orphan in abandoned orphanage.
28

Page 72 of 73
1
2
Last year in August 2010 after I came back to work from vacation, my
3
coworker from HVAC shop, Bill Rabidoux asked me if I will be willing to
4
work swing shift because HVAC shop manager told him that second shift
5
would be created for the Metasys System operation outside the Central Plant.
6
7 I responded that it would be no problem.
8 However, whole conversation got my attention and I concluded that during my

9 vacation absence the Metasys Operation is still unresolved issue for somebody
10
inside the department and he is trying to fix something that is not broken.
11
My other thought was that Central Plant Operators submitted complaint and
12
they are asking to remove the Metasys Operation from the Central Plant
13
14 Shortly after, in September 2010, I received by copy of the undated but signed
15 petition by four Central Plant operators in regards to Metasys Operation
16
After I read the petition and attached to the petition the wages disclosure
17
printed from the Sacramento Bee website, the first my thought was that the
18
petition is a follow up to their earlier complaint which I thought they submitted
19
in August during my vacation absence. The petition itself alleged that Metasys
20
System operation has became full time job to monitor and it was my
21
understanding from the petition that the $ 4.00 /hour wage increase for them
22
would magically convert the full time Metasys Operation job to relaxing
23
leisure in nice resort.
24
25 Furthermore , the individuals who signed the petition alleging (without

26 mentioning my name) that I am making $ 15,000.00 more than they are( I
27 wish) earning and I am doing considerably less than they are .
28

Page 73 of 74
1 On top of this, petitioners are raising issue of three managers for twelve person
2 crew in the Central Plant.
3
I don't know how they omitted Mr. Mike Lewis in their calculations who
4
appears to be in charge of these three mentioned managers. I don't know if it is
5
lack of respect for Mr. Lewis or they are targeting Central Plant Maintenance
6
Supervisor who I as heard he became a salt in their eyes. Few days later after I
7
got the petition I have heard from source different than Central Plant that
8
Central Plant Manager Mr. Steve McGrath making accusations that I was
9
10
involved in writing this petition for Central Plant Operators.
11 I did not want to engage myself in any conflict or discussion with these
12 individuals who are attacking my wages and my duty and I did pass the copy
13 of the petition to Mr. Dennis Curry.
14
Thereafter I forgot about it and concluded this event as a "NEVER ENDING
15
TRAUMA IN THE CENTRAL PLANT " taking in consideration that the same
16
group of individuals viciously and recklessly attacked me and other people in
17
the past, caused me enormous stress, suspension, my departure from the
18
Central Plant and loss of thousands of dollars in my earning"
19
20 At the end of December 2010 I got e-mail from William about his pay raise
21 and I thought that he is joking and I wrote him back that I got five thousand
22 dollars raise, than he sent me congratulation etc. I did not believe him in spite
23 of State financial crisis, furlough, budget constraints and UC President memos
24
about the cuts and possibility of big lay off in IJC system. Basically, I ignored
25
William information and was no further discussion about the pay raise in the
26
Central Plant.
27
The other subject in December 2010 in discussion was the tragic death of the
28

Page 74 of 75
1 Central Plant employee who took his own life. Just day or two before it
2 happened, I was joking with Tods over the phone and such news was very
3 terrible and unprecedented news for me. I have a problem to get this tragic
4 event off my mind because Todd was working in the place where I have
5
experienced bully behavior toward, Rick Tunello and William Buckans and
6
later toward me from well known group of employees in Central Plant and
7
authors of the last year petition for wage increase and remarks toward me in
8
this petition.
9
10 The other December 2010 story from the Central Plant is a story of the Jeff
11 Lancaster burglarized locker and supposedly stolen photos from the Jeff's
12 locker protected by the secret lock combination.
13 UC DAVIS MEDICAL CENTER 2315 STOCKTON BOULEVARD

SACRAMENTO, CALIFORNIA 95817
14
December 17, 2010
15
Central Plant
16
One of the Central Plant Operators locker was broken into and personal
17
18
This incident has been reported to VICEMC Police department and to
19
20 UCDMC Human Resources department for appropriate investigation and
21 action.All lockers will have their locks replaced with new and the master file
22 will be kept confidential. Need to provide instructions on what they need to do
23 or how they will be notified.In light of the professional attitude and excellent
24 performance of the Central Plant team this incident is extremely disappointing.

25 If whoever was responsible for this would put the same effort into being a team
26 player and working with others on the Central Plant staff, the work
27 environment in the Central Plant could be that much better.In my entire career
28

Page 75 of 76
1 that consists of work at facilities both in the United States and abroad I have
2 never experienced an incident such as this. If the perpetrator is found,
3 appropriate action will be taken.
4 Mike Lewis
Principal engineer
5 Plant Operations and Maintenance
6 After I read the William's statement, talk to him and I read Mr. Lewis letter, I
7 understood that somebody supposedly opened Jeff's Lancaster locker and took
8 his personal photos.
9 As I remember the only Plant Manager had the list of all lockers codes and he
10
could only open somebody's locker. This whole story sound and looks like
11
total hoax made up for who knows what reason or for April 1s` fool's day.
12
Who want's somebody's family photos and for what reason?
13
Mr. Lewis stating that he never experienced an incident such as this, he
14
probably was not aware that in the past the former Central Plant Manager got
15
into people lockers without their presence to search for sleeping equipment
16
because he was informed that operators are sleeping on the night shift.
17
My Wages and Working Condition
18
Dear Mr. Witcher:
19
20
The wages subject came again to my attention last week because William did
21 mention again his raise and again I thought that he is trying to "pull my legs"
22 and is joking. and in light of budget cuts e.tc I did not believe what is William
23 telling me until he sent me copy of your memo which stated that he got the pay
24 raise.
25 I am working in UC Davis Medical Center almost 12 years. A lot longer then
26 many operators in the Central Plant.
27 With my departure from the Central Plant I received by the Settlement —
28

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1 Agreement $70, 000 per year salary and Associate Development Engineer
2 Position.
3 I am not sure how we got to this $70, 000.00 salary, because according to the
4 HR Salary Scale under Title Code 7182 as Non —Represented employee I
5
should be in the Middle Range or step with $ 71640.00 per year or $34.31/hr
6
which is closest to the $70,000.00 per year I got two years ago . No one step in
7
salary range under Title code 7182 is set at $70,000.00
8
The $ 70,000.00 partially compensated my overtime and other extras I was
9
receiving as Central Plant Operator. I am estimating that Central Plant
10
Operators wages with their new over 10% raise would be around $85-90 K per
11
year taking in consideration their overtime and other extra pay they are getting.
12
The next range for salary scale under Title Code 7182 is $ 80922.00 per year
13
which I believe it would comparable what the Central Plant Operators will
14
15 make after the December 2010 pay raise.
16 I wrote the introduction and I summarized the latest events in the Central in
17 this letter not without reason
18 The petitioners have the right to say in the petition whatever they want about
19 my job but I know how to operate the Central Plant and could go and do it if
20 really needed or requested by management
21 I am not sure if the petitioners would be so happy to work in the place
22 where no designated place to eat meal at lunch is or break, where they
23 would have to use filthy bathrooms, no warm and clean locker room to
24
change clothes at the winter time. I am happy for Central Plant operators
25
they got the wage increase. However, I am asking for fair and equal
26
treatment in regards to wages
27
It is my understanding from my job description that my position has primary
28

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1 responsibility for the operation and maintenance of the Central Plant.
2 It is also my understanding that Metasys System is integrated part of the
3 Central Plant and I have this duty for the full time.
4
5
Beside the Metasys Alarms I am doing other stuff requested by Patrick Putney
6
and I have well documented what I am doing beside the Metasys Operation.
7
Some days I am very busy and "dizzy" from the alarms but I don't have any
8
major problem to handle the job.
9
I don't take brakes with exception to lunch and I would like to have both
10
brakes integrated into lunch and take one hour lunch instead of two 15 minutes
11
brakes and 1/2 hour lunch. This would allow me to leave the shop to eat lunch
12
outside in cafeteria or walk around the campus to relax and get my blood
13
circulation normal
14
15 In conclusion I am respectfully asking and I would appreciate if my salary will
16 accordingly to next level under Title Code 7182 for Non —Represented
17 employees which I believe is a level 3.0
18 Sincerely
19 Jaroslaw Waszczuk
20
21 221. Plaintiff learned that prior to Todd Goerlich’s suicide, Goerlich frequently
22 complained to his friend Dereck Cole and his girlfriend that he had been harassed and bullied in
23 the Central Plant “by a person named Jeff.” That corresponds with William Buckans’s
24
observation how badly Todd Goerlich disliked Jeff Lancaster and, in particular, how different
25
and unapproachable Todd became when he worked a shift with Jeff Lancaster.
26
Dereck Cole was a newly hired HVAC Technician in a shop where Plaintiff worked. Cole was
27
hired just one month after Todd Georlich committed suicide, and Todd Georlich was the person
28

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1 who provided the recommendation for Dereck Cole to be hired as an HVAC Technician by UC
2 Davis Medical Center where Plaintiff had been working since 2007.
3 222. After access to the Central Plant was blocked and after Plaintiff sent his
4 letter to Charles Witcher on March 13, 2011, Charles Witcher’s secretary, Phyllis Reginelli,
5
showed up in the Central Plant with a hand-printed copy of UC Davis Policy 1616, for the UC
6
Davis Principle of Community, and attached to the policy’s roster was a handwritten Central
7
Plant Operator’s name and instructions on the roster to read and sign off on what you have
8
seen/read in these policies. That had never happened since the Central Plant was built in 1998:
9
that the secretary to the Department Head showed up with a request to read and sign a Violence
10
and Hate Policy and UC Davis Principle of Community, which was not a UC official policy. It
11
would be expected that after a suicide and locker burglary, somebody from the HR Department
12
would show up, do an investigation and provide the proper training on harassment, violence,
13
standing up to bullies, etc., for Central Plant personnel, knowing and being aware of how hostile
14
15 this place was and how it had contributed to an employee’s suicide.
16 223. The news about the pay raise got around, and in fear of turmoil, the UC
17 Davis Chancellor’s Office or UC Office of the President ordered a 2% pay raise to all UC Davis
18 Medical Center non-union employees, including to Central Plant Operators who had already
19 received a 12% pay raise. Normally, employees would receive a pay raise on July 1st if it were
20 approved after the Annual Performance Review to be given to employees for the 2010/2011
21 year. Plaintiff received the pay raise in May 2011 as well, and his salary increased from
22 $70,000.00 to $71,600 per year.
23 The April 2011 Retaliation
24
224. Instead of any response to my letter from Charles Witcher in April 2011,
25
Plaintiff’s manager, Patrick Putney, blatantly blamed him for missing and not dispatching a
26
hospital refrigerator critical alarm that resulted in a complaint against him by the hospital
27
pharmacy personnel. In a heated discussion, Putney humiliated Plaintiff in front of his teenage
28

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1 daughter, whom he had brought to the shop on that day. Plaintiff told Putney that he didn’t miss
2 such important alarms because Putney had made Plaintiff the perfect employee. The new facilities
3 were built in UCDMC and the new buildings were hooked up to the Metasys Monitoring System.
4 225. During the testing of the new building equipment, thousands of false alarms
5
from these buildings were coming to the Metasys Computer Monitoring System and Plaintiff had
6
to struggle to catch the real alarms and dispatch them. One day, when Plaintiff assumed shift from
7
the Central Plant Operators who were monitoring the alarms on others shifts, Plaintiff asked the
8
Central Plant operator why he did not clear these false alarms. Central plant operators surprised
9
Plaintiff with his response, as he said, “What are you talking about? We don’t have these
10
alarms on our computers.” Apparently, Plaintiff’s manager, Patrick Putney, with malicious
11
intent, was setting Plaintiff up to fail and to miss the real critical alarm in the jungle of thousands
12
of false alarms, which should have been disconnected from Plaintiff’s computer until the new
13
buildings were ready for service. When Plaintiff confronted Putney about it, he sarcastically
14
15 responded, “I am trying to make you perfect.” Plaintiff said ok and continued to train himself to
16 be perfect with these false alarms and not to miss the real one. Missing critical alarms and not
17 dispatching it could lead to enormous losses or even patient death in UC Davis Medical Center
18 Hospital.
19 226. Patrick Putney’s unfounded accusations about the missing refrigerator

20 critical alarm appeared to be a result of his and his assistant Dorin Daniliuc’s negligence to repair
21 the relevant refrigerator. After the alarm and complaint, it was discovered that the refrigerator was
22 due for repair, had an open work order, and the repair was not done. When Plaintiff proved that it
23 was their fault and that they had neglected their duty, they began to disrespect Plaintiff, showing
24
hostility towards Plaintiff; Plaintiff became the subject of vicious attacks, including and not limited
25
to stalking, intimidation, sabotaging Plaintiff’s job, provocations for physical confrontation and
26
unfounded accusations from these two individuals of being violent.
27
28

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1 227. In May and June 2011, Patrick Putney turned off the lights in his office and
2 positioned himself in the chair toward Plaintiff and stalked Plaintiff for hours every day. Once in
3 a while, Putney suddenly opened the door to Plaintiff’s office and yelled, “What are you doing?”
4 Plaintiff thought that Putney was crazy or on drugs.
5
No so long prior to Putney’s behavior—in March 2011—Plaintiff was making breakfasts for
6
Putney every morning and had quite a normal relationship with him and his assistant. Dorin
7
Daniliuc. Plaintiff never thought that the Putney’s behavior was staged and orchestrated by given
8
order from HR Director Stephen Chilcott and was related to UC Davis Central Plant data accessible
9
Via Matasys Alarm Control System
10
228.. Plaintiff was considering letting it go and even considering taking the blame
11
for this missing alarm just so he would not have to go through the hell he had experienced in
12
2006/2007. However, after Plaintiff saw that Charles Witcher’s assistant, Dennis Curry, got
13
involved in the missing alarm issue, Plaintiff did not take any chances of being convicted and
14
15 punished, as this had happened to one of his coworkers, Rick Tunello, in the central plant. Rick
16 Tunello had been wrongfully accused and wrongfully convicted by Dennis Curry, and wrongfully
17 suspended for a missing refrigerator alarm without pay. Plaintiff’s intervention in the case, and
18 proof that it not was not Tunello’s fault, reversed Dennis Curry’s conviction.
19 229. The behavior and vicious attacks of Patrick Putney, Dorin Daniluc, Dennis
20 Curry and Charles Witcher aimed at Plaintiff in March, April, May, June and July of 2011
21 reminded Plaintiff of the training class he attended in March 30, 2000.
22 230. The March 30, 2000 training course, “Labor Principles in Public
23 Employment” for UC Davis Medical Center supervisors exactly resembled Putney, Daniliuc,
24
Curry and Witcher’s approach to resolving the dispute. The abovementioned course for supervisors
25
was hosted by UC Davis Medical Center Human Resources Executive Director Gloria Alvarado.
26
Ms. Alvaradao’s course lecture had nothing to do with labor principles in public employment, but
27
was a class that coached supervisors how to inflict fear, to intimidate and silence employees who
28

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1 dare to complain. One of the course’s subjects was how to convince a subordinate that he is too
2 observant to demote himself. Plaintiff responded to Ms. Alvarado self-demotion instruction and
3 Plaintiff was told that this class is not for Plaintiff after Plaintiff told Ms. Alvarado that he is not a
4 supervisor but a central plant operator.
5
After a short discussion with Plaintiff, Ms. Alvarado changed subjects and ended instructing
6
supervisors who attended the class on how to take control of the crew by intimidation and fear.
7
231. Putney, Daniliuc, Curry and Witcher, regardless of who instructed them to
8
viciously and maliciously attack Plaintiff in March, April, May, June and July of 2011, were
9
perfectly aware that Plaintiff in February 2009 signed a Settlement-Agreement with the Regents
10
of the University of California and that they grossly violated the agreement by attacking and
11
harassing Plaintiff. Witcher was one of four who signed the Settlement-Agreement on Defendant
12
at the UC Regents’ behalf.
13
14
May 2011
15
232. In May 2011, Plaintiff held two separate meetings with Department Head ,
16
17 Charles Witcher, to clarify the issue with the missing refrigerator alarm, to discuss the unusual and
18 psychotic behavior of Patrick Putney toward me, which was not limited to stalking Plaintiff from
19 his dark office, suddenly opening his dark office door from the inside and screaming “What are
20 you doing?” Thereafter, within minutes Dennis Curry showing up in the shop and talking to
21 Plaintiff like Plaintiff did something wrong, they both laughed in Patrick Putney’s Office. .
22 233. In May 2011 Patrick Putney held meetings with the crew and in a
23 threatening manner told everybody how good he is at firing people from the job if they not behave
24 up to his standards. One of the new shop employees, Dereck Cole, became so frightened that he
25 asked Putney if he was aiming his threats at him. One year later, Dereck Cole became another
26
victim of Patrick’s Putney, Dennis Curry, and Charles Witcher’s schemes and yet another
27
candidate to look for new employment. He was unspeakably victimized and asked me to represent
28

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1 him with his complaints against Patrick Putney and Charles Witcher. Another Patrick Putney
2 victim is 72-year-old HVAC technician Richard Pawlaczyk. The Richard Pawlaczyk’s case was
3 pending with State of California Fair Housing and Employment. Sadly and unexpectedly Richard
4 passed away on February 10, 2013. Consequently in month of May 2011 Plaintiff’s manager
5
Patrick Putney denied Plaintiff’s access to his time cards , work orders system and to sabotage
6
Plaintiff job Putney denied Plaintiff’s access to many Metasys system future . Plaintiff failed to
7
understand what caused such Putney’s rage against Plaintiff. Plaintiff knows now that Putney
8
follow the order of his superiors and that decision was made to terminate Plaintiff employment.
9
234. Plaintiff documented the May 2011 events in two separate letters
10
addressed to Charles Witcher and to Gina Harwood, who was assigned HR Consultant
11
to the HVAC shop. The letter to Charles Witcher dated May 24, 2011 is the best
12
description what Plaintiff was going through.
13
“As I stated during our last meeting, I do not want to file a complaint against
14
15 Patrick Putney. I would prefer for the situation to improve somehow and for
16 everything to return to normal in the workplace .Unfortunately, it does not
17 appear that this will be the case. Patrick is still working very hard to get on my
18 nerves and to eventfully provoke me into a verbal confrontation. During my
19 unfortunate heated discussion with Patrick about the neglected refrigerator, he

20 humiliated and ridiculed me in front of his teenage stepdaughter. His kids often
21 stay in his office and do their school homework there. I have never had
22 anything against his bringing his kids to work, but in the situation of the heated
23 argument, he went overboard. After the incident, we returned to work on
24
Monday, and I tried to smooth out everything. I even offered him breakfast,
25
but my attempt to make peace with him did not work, and the situation still
26
does not look good.
27
Shortly afterward, Patrick in a retaliatory manner requested that I find all of the
28

Page 83 of 84
1 "unreliable alarms" in the Metasys . Without discussion, I found these unreliable
2 alarms for him. It took me almost a week to complete the task, after which Patrick
3 again displayed his vicious behavior and upset me so badly that I thought I was
4 suffering a stroke or a minor heart attack. Patrick basically ceased normal
5
communication with me, including not saying "good morning” or “bye” at the end
6
of the day. As you know, Department Head Assistant Dennis Curry came to the
7
heating, ventilation, and air conditioning (HVAC) shop, and then we talked
8
Patrick Putney’s behavior and missing refrigerator alarm As I had known Patrick
9
for quite a while and was aware of his 360-degree turnaround, I knew the situation
10
was not going to end with my meeting with Dennis. I wrote in an email to Dennis
11
that the situation would probably get worse before it got better.
12
After the situation where Patrick failed to appreciate my finding the unreliable
13
alarms, a furious Patrick came to my office, together with Dorin as a witness,
14
15 and dumped on my desk the policy and procedures for central plant operators,
16 which explains how to operate the Metasys system, plus my job description.
17 He clearly intended to intimidate me, speaking the following words: "Do you
18 understand what this policy is for?" I thanked him the next day for providing
19 me with the Metasys policy three years after I had joined the HVAC shop and
20 12 years after I had begun operating Metasys. To participate in his "game," I
21 decided to provide him with the link to the UC Davis Medical Center
22 (UCDMC) Parking and Transportation Services Office and to advise him to
23 pay for his parking permit. For the past three years, he had parked for free on
24
the UCDMC premises by hiding his car inside the shop and playing a little
25
"catch me if you can” game with the parking cops. On top of this, I decided to
26
make this comment to him "What kind of managerial example is he setting for
27
his crew by showing that it is okay to cheat and steal from the employer while
28

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1 at the same time having the ambition to became assistant PO&M [plant
2 operation and maintenance] manager after Dennis Curry retires?”
3 I had hoped that after I talked to you, he would eventually stop trying to
4 intimidate and mistreat me.
5
The peace, however, did not last long. Yesterday and today, Patrick started a
6
new "kids game." He turned off the light in his office, which is next to mine, and
7
decided to sit at another desk nearby and watch me from the dark background to
8
see what I was doing on my computer. This made me very uncomfortable to
9
work at my station. This happened all day yesterday and today when I was
10
reviewing work orders; he came into my office and, from behind, loudly asked
11
me what I was doing. I told him that I was looking at completed workers. Then,
12
he responded that I had no right to look at work orders because it was not my
13
job; he told me that my job was to watch the Metasys. I knew he was trying to
14
15 create a confrontation with me for any reason. I simply told him not to worry
16 and that I had been reviewing and closing all of the completed work orders for
17 almost two years using Putney’s name and password, which was, of course, a
18 violation of UC policy giving me his password and order me to do his job.
19 The previous incident and today's incident show clearly that Patrick has no
20 remorse about hunting me down. From my perspective, I do not have a choice but
21 to defend myself against his vicious and unpredictable aggression.
22 I was surprised and shocked today that I was kicked out of my office after 3:15
23 PM by Dennis per Patrick’s request and thus could not finish this letter then. I
24
still don't understand why I got kicked out. I did not park my car without a
25
permit, and I did not do private jobs in the company shop. I just wanted a few
26
minutes after work to finish my letter to the PO&M manager.
27
I am not sure how I will concentrate on and do my job tomorrow as required if my
28

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1 supervisor is doing everything possible to make my life miserable and hellish.
2 To avoid going through this hell and finally end Patrick’s hostility, I would be
3 glad to offer an apology to Patrick. However, I am not sure how and for what
4 reason I should apologize to him.
5
Should I apologize to Patrick by saying that I have been doing a good job for
6
the past three years and don't have a history of neglecting my duties and of
7
missing Metasys alarms at UCDMC?”
8
235. Plaintiff did not realize or know in May 2011 that the vicious attack
9
against Plaintiff was performed with the same goal as that of the attack of 2006/2007, which
10
resulted in Plaintiff’s brutal removal from the Central Plant and his moving to the HVAC Shop.
11
The goal in both attacks was to cut off Plaintiff from the source of information about the electric
12
power generation by the UC Davis Medical Center cogeneration facility called the Central Plant.
13
The Metasys Monitoring System and Work Order System provided Plaintiff with all of the
14
15 information about the Central Plant’s operation and electric power, steam, hot water, and chill
16 water production.
17 236. Plaintiff thought that the 2009 Settlement-Agreement that Plaintiff signed
18 with the Defendant, the Regents of the University of California, would protect Plaintiff from the
19 new attack if Plaintiff had not violated the Settlement-Agreement.

20 237.. The March 13, 2011, letter from Plaintiff to UC Davis Medical Center
21 Plant Operation and Maintenance Department (PO&M) Manager Charles Witcher raised red
22 flags, and the PO&M Department Management received an order from above that Plaintiff had
23 to be cut off from any source of detailed information provided to him by the Metasys Monitoring
24
System about the Central Plant and be removed from the premises at any means. The UC Davis
25
Medical Center PO&M Department Manager was the one of four UC Davis employees who
26
signed the 2009 Settlement –Agreement and Witcher was perfectly aware that unwarranted
27
attack against Plaintiff violates the signed Settlement –Agreement
28

Page 86 of 87
June 2011
1
2 238. Due to continuous harassment and sabotaging the Plaintiff’s job, the
3 condition of Plaintiff’s employment became intolerably stressful to the point that on June 22, 2011,
4 on short notification, Plaintiff asked Department Head Charles Witcher to give Plaintiff 3 days of
5 vacation to get away from Patrick Putney. The vacation days were granted and Plaintiff went home.
6
Regardless of the stress and feelings, in good faith and will, Plaintiff sent an email to Patrick
7
Putney and asked him to restore and normalize professional relationship.
8
239. Plaintiff did not get any response from Putney. Plaintiff did not know in June 2011
9
that a similar action to 2006/2007 action against Plaintiff was underway; a false complaint was
10
filed against Plaintiff with the HR Department and Plaintiff became the subject of second witch
11
hunt within two years taking into consideration date of the Settlement –Agreement Plaintiff signed
12
with the Regents of the University of California in February 2009. The month of June was the
13
month of annual employee performance review for the year 2010/2011 .In June 2011 Plaintiff did
14
not receive his employee performance review from his two supervisors Patrick Putney and Dorin
15
16 Daniliuc as it was mandated by the UC Davis Policy PPSM 23.
17 July 2011
18
240. On July 8, 2011, Plaintiff held a meeting with HR Labor Relation
19
Consultant Gina Harwood about the harassment and retaliation Plaintiff was experiencing. During
20
the meeting, Harwood deliberately failed to disclose the fact that the false and fabricated complaint
21
was filed by Plaintiff’s two supervisors, Patrick Putney and Dorin Daniliuc. A few days later,
22
Plaintiff was officially informed that the complaint has been filed against him and that an HR
23
investigator had been assigned to investigate the allegation. The assigned HR Investigator was HR
24
attorney Danesha Nichols, who was deployed from the UC Davis campus to UC Davis Medical
25
Center in October 2010 after Central Plant Operators submitted a black mail petition for pay raise.
26
27 241. Danesha Nichols was very familiar with the previous attack against Plaintiff
28 in 2006/2007 due to her involvement in Plaintiff’s arbitration process against the Defendant in

Page 87 of 88
1 2008, which resulted in Plaintiff’s February 2009 Settlement-Agreement with the UC Regents.
2 Nichols aggressively and as soon as possible tried to schedule an interrogation meeting with
3 Plaintiff. Plaintiff refused to meet with Nichols because HR refused to disclose to Plaintiff who
4 had filed the false complaint against Plaintiff, and Defendant’ new attack against Plaintiff was a
5
gross and despicable violation and breach of the Settlement-Agreement signed by Defendant.
6
242. Besides the investigation issues, Plaintiff on July 17 and July 24, 2011, sent
7
letters to UC Davis Chief Counsel Steven Drown and asked him to intervene to stop Danesha
8
Nichols and others from violating the 2009 Settlement-Agreement. UC Davis Chief Counsel
9
Steven Drown was one of four UC Davis employees who had signed the 2009 Settlement on the
10
UC Regents’ behalf. Plaintiff is not only suspecting but most likely that not that UC Chief Counsel
11
Steven Drown was the person who in 2005 dispatched Stephen Chilcott to UC Davis Medical
12
Center to remove Plaintiff and William Buckans from the Central Plant under false fabricated
13
accusations and allegations and terminate the Plaintiff ‘s employment if possible.
14
15 243.. As a result of Plaintiff’s complaints to UC Davis Chief Counsel Steven
16 Drown about the Settlement-Agreement violations by the Defendant, the UC Davis Chief
17 Compliance Director, Wendy Delemendo, contacted Plaintiff and tried to convince Plaintiff to
18 file the complaint under the UC Whistle Blowing Policy. Plaintiff refused due to his and his
19 coworker’s experience in 2006/2007 when he helped his coworker William Buckans with the
20 Whistle Blowing case related to massive machine oil discharge via a storm drain to the Sacramento
21 River.
22 244. On July 29, 2011, Plaintiff responded to Delmendo’s whistleblowing
23 complaint invitation by letter with many questions about HVAC shop supervisor Dorin Daniliuc’s
24
relationship with two UC Davis Medical Center directors, Robert Taylor and Shelton Duruisseau
25
The Daniliuc’ relation with these two directors was to provide them HVAC services in their
26
private residences in exchange for Daniluc’s supervisory position in the HVAC shop. The
27
questions were never answered by UC Davis Chief Compliance Officer Wendy Delmendo or any
28

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1 of five investigation reports written by Danesha Nichols in December 2011 and February 2012.
2 245. Plaintiff also asked Executive Director Mike Boyd, who is a listed
3 Defendant in FAC and SAC, for 30 days of administrative leave due to the ongoing assault on
4 Plaintiff. Plaintiff also asked HR Executive Director Stephen Chilcott to intervene in the case and
5
stop the retaliation and further harassment. Plaintiff did not get a response from the HR Director,
6
but Director Mike Boyd denied Plaintiff’s request for 30 days of administrative leave. However,
7
Director Mike Boyd, together with the HR Workers Compensation Manager, advised Plaintiff to
8
file a fraudulent Workers Compensation Claim to leave the premises.
9
246. Plaintiff later learned that an HR Director Stephen Chilcott assembled the
10
team that would lead to Plaintiff’s conviction and termination of Plaintiff’s employment in
11
September 2011.
12
247. Also in July 2011, one of the HVAC shop plumbers, Kenny Diede, walked
13
into Plaintiff’s office and complained to Plaintiff that that his coworker Bill Rabidaux’s son was
14
15 illegally accessing shop computers. Bill Rabidaux’s son was a twice-convicted child
16 pornography felon on probation; he was prohibited to have a computer at home by court
17 order and was not allowed access to any computer with Internet. He should not have been
18 allowed to enter the HVAC shop premises at all.
19 248. This individual was a frequent guest in the HVAC shop, and his presence
20 was tolerated by Patrick Putney and Dorin Daniliuc because Bill Rabidaux had a special
21 relationship with Charles Witcher’s assistant, Dennis Curry.
22 After Kenny Diede reported to Plaintiff that Bill Rabidaux’s son was accessing a company
23 computer, Plaintiff told Kenny Diede that Plaintiff would pass the information on to Patrick Putney
24
when he came back to his office. When Plaintiff told Putney about it, he got upset that Kenny
25
Diede had not waited for him with information and angrily asked Kenny whose side Kenny is s
26
on—“Jerry’s (Plaintiff’s) side or Putney’s side?” Kenny’s response was that he was not on
27
anybody’s side and that he was working in the shop and did not appreciate having a child
28

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1 pornography felon accessing shop computers. Thereafter Kenny Diede had to look for a new job
2 due to harassment and intolerable working conditions, as Patrick Putney, Dorin Daniliuc, and
3 Charles Witcher created hell for him.
4 249. In June or July 2011 Plaintiff did not receive his employee performance
5
review from his two supervisors, Patrick Putney and Dorin Daniliuc, as was mandated by the UC
6
Davis Policy PPSM 23.
7
250. In July 2011, UC Davis Health System HR Executive Director Chilcott,
8
with full disregard of the February 2009 Settlement-Agreement signed by Plaintiff with UC
9
Regents and full premeditation and disregard of UC Davis Policy PPSM 23 and PPSM 62 and
10
UCDMC Policy 1616, singled out Plaintiff for termination of employment by ordering that
11
Plaintiff should not be provided with the Annual Performance Review (Evaluation) mandated by
12
PPSM 23 outlining Plaintiff’s job performance for 2010/2011, thus depriving Plaintiff of any
13
14
15 70. Annual Performance Reviews (Evaluations) are the most important documents in the
16 employee–employer relationship; Jensen v. Hewlett-Packard Co., 14 Cal. App. 4th 958, 18 Cal.
17 Rptr. 2d 83 (Cal. Ct. App. 1993).
18 251. Only Stephen Chilcott as the HR Executive Director had the power to
19 order not to provide Plaintiff with his annual evaluation and deprive him of administrative
20 remedies under the UC Policy PPSM 70.
21 252.. In July and August 2011, UC Davis Health System HR Executive Director
22 Stephen Chilcott, in conspiracy with Director Michael Boyd and HR Workers Compensation
23 Manager Hugh Parker (Chilcott’s subordinate), made an attempt to remove Plaintiff from the
24
premises through the false and fraudulent Workers Compensation Claim. Plaintiff refused to file
25
a false claim, but a claim was filed on Plaintiff’s behalf anyway.
26
253. It is possible that UCDMC HR Workers’ Compensation Manager Hugh
27
Parker forged Plaintiff’s signature and filed the Workers’ Compensation claim on Plaintiff’s behalf,
28

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1 taking into consideration that on May 31, 2012, Hugh Parker coordinated ill-minded but
2 unsuccessful provocation to kill Plaintiff or end his employment in UCDMC Trauma Unit #11 by
3 an assembled UC Davis special team nicknamed in the documents “UC Davis Death Squad.”
4 254. At and of July 2011, Plaintiff’s private external hard drive in his office was
5
deliberately and “professionally” damaged when Plaintiff left his office for lunch. The external
6
hard drive circuit board was literally fried, most likely by high electric current and the damage was
7
invisible outside. When Plaintiff removed the cover, it was evident that the damage had been
8
caused by somebody who know how to do it—most likely Plaintiff’s manager, Putney, who by
9
trade had knowledge of what to do. Plaintiff summarized this incident in the Mistreatment
10
Complaint that he filed on August 30, 2011, with the UC Davis Medical Center HR Mistreatment
11
Office managed by HR Equal Opportunity Employment Manager Cindy Oropeza.
12
“I probably would not ask my doctor for stress leave on August 2, 2011,
13
but a few days prior I left for stress leave when my personal 500-GB,
14
15 USB-powered external hard drive (HD) had been fried/damaged by
16 somebody after I left it connected to the computer in my office and I left
17 my office for a one-hour lunch. This was a trigger point for my decision to
18 ask my doctor for a medical leave. The person who apparently fried my
19 hard drive with higher voltage knew what he was doing and how to do it. I
20 did not find any external physical damage to my hard drive but, after I
21 removed the cover, I found that the circuit board and motor had been
22 burned.
23 I am almost certain of who and why it was done, but I did not catch anybody by
24
hand. Therefore, I can only write and whine about this event. I did not take any
25
chances by remaining in my office any longer and getting electrocuted like my HD.”
26
255. It happened after over three months of nonstop attacks against Plaintiff including,
27
and not limited to, stalking and sabotaging Plaintiff’s job as orchestrated by the UC Davis Health
28

Page 91 of 92
1 System HR department, the UC Davis chief counsel, and the UC Davis chief compliance office
2 and was carried out by individuals such as Patrick Putney, Dorin Daniliuc, Dennis Curry, Charles
3 Witcher, Robert Taylor, Danesha Nichols, Gina Harwood and Shelton Duruisseau.
4 256. Defendant were perfectly aware that Plaintiff is 60 years old and had open-heart
5
surgery a few years ago. Plaintiff was using nine different prescription medicines to survive every
6
day, including and not limited to medicine for high blood pressure, anxiety, and depression.
7
8 August 2011
9
257. In July 2011, Plaintiff asked many times and begged for the harassment to stop, as
10
well as the sabotaging of Plaintiff’s duties and job, so as not to escalate the conflict. Plaintiff’s
11
appeals did not work, and Plaintiff had to evacuate himself from the job site due to enormous
12
emotional distress caused by PO&M, the HR department management, and HR investigators.
13
Plaintiff’s physician placed Plaintiff on work-related stress sick leave until September 1, 2011. By
14
going on work-related stress sick leave, Plaintiff was hoping that, during his absence from work,
15
everything would settle down and Plaintiff would be able to continue his employment. Plaintiff
16
17 was also hoping that the UCDM HR assigned investigator, Attorney Danesha Nichols, would
18 interview all Plaintiff’s coworkers from the shop and would clarify the issues of the false and
19 fabricated accusations against Plaintiff. Plaintiff forgot or did not know in August 2011 that
20 Danesha Nichols was involved in the previous Plaintiff’s case together with Stephen Chilcott and
21 that Danesha Nichols was deployed in October 2010 to UC Davis Medical Center to monitor the
22 situation with the black –mail pay raise for the central plant operators.
23 258. Plaintiff’s coworker, Kenny Diede, was slandered and defaced on his annual
24 evaluation by Patrick Putney for reporting a twice-convicted child pornography felon for
25 accessing company computers. Later on, Plaintiff represented Kenny Diede in his complaints
26
pursuant to UC Davis Complaint Resolution Policy PPSM 70 and Whistleblowing Retaliation
27
Policy to keep his job with UC Davis Medical Center.
28

Page 92 of 93
1 259. The August 2, 2011 was Plaintiff’s last physical presence and last working
2 day with the UC Davis Medical Center in Sacramento, California, and Plaintiff employment was
3 never restored as it was prior to the March 13, 2011 letter Plaintiff wrote to Charles Witcher and
4 prior to the incident with the critical missing refrigerator alarm.
5
260. On August 30, 2011, Plaintiff filed an official complaint against his
6
manager Patrick Putney with the UCDMC HR Mistreatment Office. The complaint was
7
incorporated into ‘Danesha Nichols’ phony investigation instead to be investigated separately by
8
the HR Mistreatment Office
9
261. Plaintiff was ready to go back to work on September 1st, 2011 and assume
10
his duty after 30 days of stress-related sick leave. Unexpectedly, on August 31, 2011, Plaintiff’s
11
last day of stress-related sick leave, Charles Witcher sent to Plaintiff a letter by e-mail that
12
informed Plaintiff that he was placing me on investigatory leave and that Plaintiff could not come
13
back to work. Furthermore, Charles Witcher informed Plaintiff is prohibited to contact university
14
15 employees and that the investigation would be finished in 14 days.
16 262. Plaintiff became very upset, stressed, and angry that could not go back to
17 work. Plaintiff got feeling that he would never get his job back, knowing that it was already
18 awarded to Bill Rabidaux, the father of the twice-convicted child pornography felon. Bill
19 Rabidoux should be punished, together with shop supervisors, for his participation in covering up
20 the parole violation of his sick-minded relative, instead of having the job granted to Plaintiff by
21 the Settlement-Agreement with the UC Regents. Also, Plaintiff would like to mention that when
22 Plaintiff was leaving the shop on August 2, 2011, Plaintiff had not had any problems with any of
23 his coworkers throughout the course of Plaintiff’s employment in the HVAC shop for four years.
24
25 September 2011
26
263. The UC Davis Medical Center PO&M Department Manager Charles
27
Witcher’s letter, dated August 31, 2011, placing Plaintiff on investigatory leave was an
28

Page 93 of 94
1 unsuccessful attempt to force Plaintiff to quit his job or to participate in the investigation against
2 himself. The orchestrated bogus investigation was based on fabricated and unfounded accusations-
3 - that had no paper trail or proof in Plaintiff personal HR or departmental file. Following the
4 Charles Witcher letter, on September 6, 2011, the UCDMC HR assigned investigator ‘Danesha
5
Nichols to send an e-mail to Plaintiff and basically ordered Plaintiff to meet her the next day in
6
the HR Office. The HR Personnel has no direct jurisdiction or power to give orders to employees
7
from different departments then Human Resources Department. Nichols did not follow the proper
8
procedure to schedule the investigatory meeting.
9
264. Plaintiff did not know at that point that Nichols had already interviewed the
10
assembled team for cause, conviction and Plaintiff employment termination. However, Plaintiff
11
suspected that something was not right because Plaintiff did not get any information from his
12
coworkers from the HVAC shop that any of them were interviewed by Nichols. It was a clear
13
indication that decision was made to terminate Plaintiff’s employment.
14
15 265. Plaintiff was informed by the UC Davis Public Record Act office that
16 Nichols’s report that was issued as a cause to terminate Plaintiff on September 23, 2011, was
17 destroyed and was not available to Plaintiff to obtain from Nichols. Nichols most likely lied to
18 Public Record Act personnel because Nichols provided the copy of the Report to HR Workers
19 Compensation Office Manager Hugh Parker who was coordinator in May 2012 to end Plaintiff’s
20 employment in the UC Davis Medical Center Trauma Unit.
21 266.. Plaintiff responded angrily to Danesha Nichols’ request and refused to
22 participate, similar to 2006/2007 UCDMC’s prosecution.
23 267. Plaintiff asked the Mistreatment Office Manager, Cindi Oropeza,(listed
24
Defendant in FAC and SAC) to add Danesha Nichols and Charles Witcher to Plaintiff’s
25
mistreatment complaint, which Plaintiff filed against Patrick Putney on August 30, 2011.
26
268. Following Danesha Nichols’ request for a meeting with her on September
27
12, 2011, Charles Witcher sent me a letter and accused me of inappropriate communication with
28

Page 94 of 95
1 Danesha Nichols, transmitting the same baseless accusation of violence and discrimination and
2 making threats to take disciplinary action against me if I would not cease my communication about
3 the investigation with my coworkers. Charles Witcher did not mention the 2009 settlement –
4 agreement in his rant aimed at Plaintiff. The letter was written by HR because Charles Witcher
5
was a only tool in the hands of HR Director Stephen Chilcott and Charles Witcher with education
6
did not know how to write memos and letters.
7
269. Plaintiff responded to Charles Witcher’s letter on September 16,
8
2011, with the following words:
9
“First, I am requesting that you in your managerial capacity make immediate
10
decision and stop holding me hostage in my own home under the umbrella of
11
"Investigatory Leave with Pay" and let me return to work unconditionally.
12
You and HR Director Steven Chillcot acted like terrorists and have enslaved
13
me in my own home and you are both torching me with psychological terror to
14
15 force me to confess to the crimes based on fabricated false and groundless
16 accusations and allegations.
17 I am not your and Mr. Chillcot’s hostage and you both have to end this hostage
18 game immediately. I have been an employee of the University of California for
19 over 12 years and I am requesting to be treated like an employee of the

20 University of California with dignity and respect, as is shown on my Employee
21 Performance Reports, which many have your approval signature.
22 The PO&M and HR Management shall not act like a terrorist network toward
23 workers if problems arise, but shall solve the problems in a objective and
24
diligent way without bias, prejudice, and discrimination.”
25
Second, as I previously stated in my multiple correspondences, you had a
26
chance in your management capacity to resolve the problem in May 2011 and
27
later, and you completely failed to do so. So please do not write me about your
28

Page 95 of 96
1 management capacity because it appears that your management capacity is not
2 in proper synchronization with your ability to act in the way you should as the
3 Department Head. You cannot and you shall not protect someone who is
4 misusing University property, stealing, cheating, stalking, harassing, and
5
abusing not only his own subordinates but also abusing animals and members
6
of his own family. You shall not protect those who are working part-time and
7
getting paid a full-time salary, regardless of whether or not if they installed air
8
conditioner equipment in Director Taylor’s private residence. You shall stop
9
attacking and threatening those who are trying to put a stop to such activities
10
mentioned above.”
11
12
270. Plaintiff was so stressed out and already was using antidepressant and
13
nitroglycerine, and escalation of the conflict by Defendant forced Plaintiff to seek a doctor and
14
15 psychologist’s help to cope with the enormous emotional stress and anxiety in relation to
16 employment situation.
17 272. On September 22, 2011, Plaintiff’s physician placed Plaintiff on the work
18 stress-related sick leave until January 5, 2012.
19 273. On September 23, 2011, Plaintiff received an e-mail from one of my

20 former Central Plant coworker William Buckans that Bill Rabidaux (father of the child porn
21 felon who was accessing UCDMC computers in the HVAC shop) announced to others that
22 Plaintiff was fired from job and that
23 274. Plaintiff was not going back and anticipated that this was going to happen.
24
Apparently, Plaintiff physician who placed Plaintiff on stress-related sick leave stopped the
25
execution. Plaintiff did not think that Bill Roubideaux lied or made up that my employment
26
termination took place. The Roubideaux’s special relationship with Dennis Curry and Patrick
27
Putney made Plaintiff believed that Dennis Curry or Patrick Putney leaked the information about
28

Page 96 of 97
1 Plaintiff’s employment termination before the termination letter was sent to Plaintiff .
2 275. Roubideaux was very happy to announce my termination because he was
3 awarded my job. For the record, I asked HR to investigate this event. Of course, HR denied that
4 Plaintiff was terminated. However, two days prior Plaintiff’s employment termination
5
announcement by Bill Rubidoux, the PO&M Manager Charles Witcher sent Plaintiff a letter
6
with threats to terminate Plaintiff’s employment and words that the Plaintiff will be escorted to
7
the conference room for interview on September 21, 2011. Apparently, the UC Davis Police was
8
in standby to escort Plaintiff in and out or for the same reason as on May 31, 2012. Also, at same
9
time Bill Rubidoux was permanently moved from downstairs to Plaintiff’s upstairs office.
10
276. On September 26, 2012, by letter Plaintiff asked University of California
11
Office of the President (UCOP) Vice President of Human Resources, Mr. Dwain Duckett, for
12
intervention and independent investigation of the case. In the letter to Mr. Duckett Plaintiff
13
wrote:
14
15 , “By this letter, I am respectfully requesting from your office intervention to
16 stop the constant assault, harassment and vicious vendetta against me for last
17 few months by UCDMC PO&M and HR Department Management. The
18 conspiracy against me to end my employment with University of California is
19 so unspeakable and deceptive that I have a problem to find words to properly

20 describe the deception and heinous vendetta against a 60-year-old Polish
21 immigrant and employee of 12 years with University of California.”
22 277. On September 27, Plaintiff filed a Short Disability Claim with Liberty
23 Mutual Insurance Company of Boston The Disability Claim itself is another chapter that is
24
connected to this case.
25
October 2011
26
27
278. On October 4, 2011, Plaintiff filed a complaint with the State Bar of
28

Page 97 of 98
1 California against UC Davis Medical Center’s two Human Resources Department Attorneys,
2 Executive Director of Human Resources Department in UC Davis Medical Center Stephen
3 Edward Chillcott, Bar # 196905 and Danesha Nicole Nichols, Investigation Coordinator in the
4 Human Resources Department and subordinate of Mr. Chillcott, who engaged in unethical
5
behavior, conspiracy against Plaintiff, and gross misconduct. State Bar Case No. 11-31088.
6
7 279. Due to constant unfounded accusations by Danesha Nichols, Charles
8 Witcher, and others, Plaintiff thought that maybe someone had filed the false complaint with the
9 UC Davis Police Department and accused me of violence and discrimination and other crimes
10 Plaintiff did not commit.

11 280. To clear this issue, on October 6, Plaintiff asked UC Davis Police Cpt.
12 Joyce Souza from the Professional Standard Unit to search my Police Record and check if any
13 record with my name was there.
14 Plaintiff, in his eight-page e-mail entitled “Request for Information in regards to the
15
unfounded accusation against me from UCDMC HR Attorneys and other individuals,”
16
pasted multiple examples of the despicable, unfounded, and defacing Plaintiff accusations. .
17
In his e-mail to UC Davis Police Cpt. Joy Souza with cc. to UC Davis Police Lt. John Pike (the
18
same Lt. John Pike who was pepper spraying protesting students on November 18, 2011 on the
19
UC Davis Campus).
20
281. Plaintiff wrote to Cpt. Joyce Souza on October 5, 2011 in his eight pages
21
e-mail letter:
22
“Dear Captain Souza:
23
I have been working for 12 years in the UC Davis Medical Center Plant
24
25 Operation and Maintenance, Sacramento Department. In last few months I
26 have been constantly accused by the UCDMC HR Attorney Danesha Nichols
27 and PO&M Department Manager Charles Witcher of being violent, making
28 discriminatory comments, etc. without any factual evidence in my employment

Page 98 of 99
1 record, like evaluation or written or verbal warning.
2 I would appreciate it if you would let me know if any complaint has been
3 filed by anyone against me with the UC Davis Police Department (UC
4 Campus or UC Medical Center) for the abovementioned fabricated
5
accusations and allegations for the period from
6
March 1, 2011 to the present time.
7
If so, then I would be glad to hear from the UC Davis Police Department
8
that the allegations against me are being investigated, and I will be glad to
9
answer any question related to the complaint. I would be glad to talk with
10
the UC Police Investigation Unit/Detectives instead of crooked HR
11
Attorneys from UCDMC.”
12
282. On October 6, 2011, Captain Joyce Souza from the UC Davis Police
13
Department responded to Plaintiff’s inquiries dated October 5, 2011, in regard to despicable and
14
15 unfounded accusations fabricated by the Defendant against Plaintiff. Captain Joyce Souza, in her
16 response, wrote:
17 Dear Mr. Waszczuk,

I have performed a check of our records system and there is nothing noting your name.
18 Please let me know if you need any further assistance.
Captain Joyce A. Souza
19 UC Davis Police Department
20 283. Plaintiff noticed that Captain Joyce Souza cc’d her e-mail response to her
21 superior, UC Davis Police Chief Annette Spicuzza, and UC Davis Chief Compliance Officer
22 Wendy Delmendo, who assigned, in July 2011, UC Davis attorney Danesha Nichols to conduct a
23 pseudo-investigation against Plaintiff to fabricate a cause for Plaintiff’s termination of
24 employment on September 23, 2011, which did not happen.
25
284. On the same day, October 6, 2011, in response to Captain Souza’s
26
information, Plaintiff replied to and thanked Captain Souza for information about Plaintiff’s
27
police record, and Plaintiff cc’d his response to Chief Annette Spicuzza; Lt. John Pike; UC Davis
28

Page 99 of 100
1 Chancellor Linda Katehi; UC Davis Medical Center CEO Ann Madden Rice; UC HR Vice
2 President Dwain Duckett; UC Davis Chief Compliance Officer Wendi Delmendo; UC Davis
3 Medical Center Directors Michael Boyd, Robert Taylor, Shelton Duruisseau and Stephen
4 Chilcott and investigator Danesha Nichols, who was fabricating, together with others, despicable
5
accusations against Plaintiff.
6
. 285. Also in October 2011, Plaintiff received a letter from the UCDMC HR
7
Disability Unit Counselor, Dennis Dark, who bragged in his correspondence about identifying
8
the job limitations and restrictions Plaintiff has. This made Plaintiff believe that Defendant had
9
10 changed course and were trying to find for Plaintiff a new place to work in UCDMC. Plaintiff
11 did not pay much attention to Mr. Dark’s proposition because his job in the HVAC shop as
12 Assistant Development Engineer fit Plaintiff perfectly and Plaintiff had no restrictions or
13 limitations to do the job with Plaintiff’s health and condition, with the exception of the stalking
14 and harassing by Plaintiff’s supervisors who made his life miserable and work conditions
15 intolerable.
16 286. On October 10, 2011, the UC Davis Medical Center HR investigator and attorney
17 Danesha Nichols sent to HVAC shop employee Kenneth Diede a threating and intimidating e-mail
18 message. Kenneth Diede was the employee who in July 2011 was reported to be a twice-convicted
19
child pornography felon on parole who had illegally accessed the HVAC shop computer and was
20
prohibited by court order to have or touch any commuter, especially one with Internet. Danesha
21
Nichols covered up the child porn criminal activities issue in her pseudo-investigation reports.
22
287. On October 11, 2011, Plaintiff filed a complaint against Defendant with
23
the U.S. Equal Employment Opportunity Commission for Harassment, Retaliation, and ongoing
24
conspiracy against Plaintiff in the University of California Davis Medical Center.
25
288. On October 25, 2011, Plaintiff sent a request to the UC Davis Public
26
record Act office and requested documents related to the UCDMC CENTRAL PLANT - JEFF
27
28

Page 100 of 101
1 LANCASTER'S BURGALIZED LOCKER ON DECEMBER 17, 2010 AND PAY RAISE FOR
2 UCDMC CENTRAL PLANT OPERATORS ON DECEMBER 20, 2010.
3 UCDMC CENTRAL PLANT - TODD GOERLICH'S SUICIDE ON DECEMBER 22,
4 2010.
5 289. On October 26, 2011, Plaintiff received a response from the University of
6 California Office of the President HR Director Christopher Simon, who informed Plaintiff that
7 UC Office of the President rejected Plaintiff’s inquiry to intervene in the case and conduct an
8
independent investigation.
9
“Dear Mr. Waszczuk:
10
This is in response to your faxes dated 9/25/2011 and 9/30/2011 to Vice
11
President Duckett in which you raised several concerns about management
12
actions at UC Davis Medical Center. I understand that these issues are
13
currently being investigated by the UC Davis Compliance Officer, Wendi
14
Delmendo.
15
The Office of the President provides oversight to the ten Campus University of
16
California system, while the Chancellor of each campus has responsibility for
17
18 the organization and operation of the campus. With the investigation by Ms.
19 Delmendo currently in progress, it would be inappropriate for the Office of the
20 President to intervene in this matter.
21 We have asked Ms. Delmendo to keep us apprised of the progress of this
22 investigation. We are confident that your serious concerns are being

23 appropriately addressed at this time.
24 Sincerely,
Christopher G. Simon
25 Director, HR Compliance
cc: Vice President Duckett
26 Compliance Director Delmendo
27 Director Epperson”
28 290. On October 29, 2011Plaintiff responded to UCOP HR Director Simon’s

Page 101 of 102
1 letter
2 “Christopher Simon
3 Director of HR Compliance
UNIVERSITY OF CALIFORNIA
4 HR-UCOP Human Resources
1111 Franklin St., 5th Floor
5 Oakland , CA 94007-1449
6 Re: Reponse To Your Letter Dated October 26, 2011-The Progress Of The
Investigation
7
Dear Director Simon:
8
I appreciate your time and your response on behalf of Vice President Duckett.
9
10 It is almost one month passed by since I asked Vice President Duckett for
11 intervention in this case .
12 I would like to mention that the previous UC HR Vice President Mrs. Judith
13 Boyette , had no any problem to intervene if needed and respond personally to
14 employees complaint letters .

15 In my response to your letter I would try not to repeat what I wrote already in
16 my multi correspondence to Vice President Duckett , Mrs. Delmendo and
17 others UC Officials but at some point I have to rely on the facts of events and
18 my record and it would be difficult not to mention again what did happen .
19
It would be unnecessary to ask Vice President Duckett for intervention and
20
send the
21
Open Letter to The Honorable Members of UC Davis Ethics and Compliance
22
Risk Committee and the California State Assembly Members,and The Regents
23
Of The University of California entitled: "I FEEL LIKE A HUNTED JEW
24
DURING THE HOLOCAUST"
25
if, after my respectful request on July 13, 2011, I sent to UC Davis Medical
26
Center HR Executive Director Mr. Stephen Chilcott to intervene in the case.
27
Director Chilcott's subordinate, Investigation-Coordinator, Danesha Nichols,
28

Page 102 of 103
1 would start her investigation or at least she start her investigation, after I sent a
2 lengthy letter dated July 31, 2011 to UC Davis Chief Compliance Officer Mrs.
3 Dalmendo than would it would not be necessary to alert UC Office of the
4 President.
5
Instead of the investigation, the UCDMC Plant Operation & Maintenance
6
Management with full back up and support of the UCDMC HR Department
7
organized safari to hunt Waszczuk down and destroy him.
8
I had to evacuate myself from my work place on August 3, 2011 due to
9
enormous stress inflicted by psychopath supervisor, Patrick Putney, who
10
apparently had been given green light by the Department Manager Charles
11
Witcher and his Assistant Dennis Curry to make my life miserable as possible.
12
Beside the attempt to sabotage my job, employees who witnessed Putney
13
stalking me from his office with lights off and suddenly opening doors with
14
15 loud voice, did not give me any choice but to evacuate myself from the shop
16 and ask my doctor for stress leave.
17 I never experienced such behavior from any of my supervisor or coworker in
18 my entire life and I am hoping to never see again in my work environment
19 another psychopath supervisor like Patrick Putney who victimized not only
20 myself but others too.
21 The question must be asked whether Patrick Putney is mentally sick or
22 unstable and UCDMC shall request psychiatric evaluation. Whether he should
23 be present around other employees not to mention supervising others. Beside
24
the stalking me, I observed that his hands are almost constantly shaking
25
especially when he got excited or mad or even for no reason.
26
Hypothetically, I wondering what would happen if instead of 60 years old Jerry
27
Waszczuk, a younger female employee would be working in the office and
28

Page 103 of 104
1 Patrick Putney would turn off lights in his office and would be stalking her as
2 he stalked Waszczuk.
3 The stalking would be witnessed and female employee would make complaint
4 as Waszczuk did to Department Head and HR that she being stalked and
5
harassed by supervisors.
6
Whether , after such complaint by female employee, Patrick Putney would be
7
removed instantly from his office to prevent sexual harassment and general
8
harassment lawsuit or UCDMC PO&M Department Management together
9
with the HR Department would organize the special safari to hunt her down
10
like an animal as they hunted Waszczuk?
11
Under the provision of the State of California Penal Code 646.9., stalking is a
12
criminal punishable offense. I think it is appropriate to ask hypothetical
13
question whether HR would call police and will get the restrain order against
14
15 Putney to protect stalked female employee or hunt her down for complaining
16 as it had been done to Waszczuk?
17 I sent my Open Letter To The Honorable Members of UC Davis Ethics and
18 Compliance Risk Committee, California State Assembly Members and The
19 Regents Of The University of California and Assembly Members and The

20 Regents Of The University of California on October 9, 2011 and miraculously
21 or coincidently next day on October 10, 2011 , the UCDMC Investigator
22 Danesha Nichols launched investigation and started interviewing all employees
23 from HVAC Shop and some employees from the Central Plant and
24
investigation is going on. The HVAC Shop social area experiencing
25
remodeling, painting and clean up. This very good and promising sign for
26
positive changes.
27
In conclusion of my letter as I wrote to UC Vice President, I strongly believe
28

Page 104 of 105
1 that Charles Witcher, Patrick Putney, Dennis Curry, Danesha Nichols, Stephen
2 Chilcot, Mike Garcia, Cindy Oropeza and Mike Boyd are responsible for
3 harassment, intimidation, abuse of power and conspiracy to fire me from the
4 job which was given me by the Settlement-Agreement signed with the UC
5
Regents in February 2009. The Settlement Agreement had been grossly
6
violated by the above mentioned individuals and I am expecting from my
7
employer to respect the signed Settlement -Agreement and let me return to
8
work .
9
I am not working for full three months. I don't have more sick leave hours . I
10
am actually using my vacation for my work stress related sick leave because
11
my short term disability have not been approved yet by Liberty Mutual
12
Insurance Company. My medical leave is nothing else but escape from the
13
harassment, mistreatment, vicious stalking by psychopath supervisor, and
14
15 unwarranted threats of termination of my employment by some of the above
16 listed individuals.
17 I need to go back to work as soon as possible and have normal work
18 environment without stalking me supervisor and without "Safari" .

21 My Psychologist Dr. Bernhoft wrote on the form for Liberty Mutual Insurance
22 Company: “Stress issues are due not to being back to work " and " Client
23 should be allowed to return to work ASAP" (attached)
24
If UC won't let me go back to work as soon as possible than I respectfully
25
requesting answer ASAP what is the other option because I don't know. I have
26
to pay my bills and mortgage and FMLA protection ends after 90 days . I don't
27
need additional stress and more pills with my health condition.
28

Page 105 of 106
1 I appreciate your prompt response in this matter and I am awaiting for
2 resolution to end this employer hostility against me .
3 Sincerely,
Jaroslaw Waszczuk
4
5
CC: Vice President- Dwaine Duckett
6 UC Davis Chief Compliance Officer - Wendy Delmendo
Director Epperson
7 Office of UC Regents .
8
Office of the President Yudof
Liberty Mutual”
9
November 2011
10
11 291. In November 2011, Plaintiff spent most of his time dealing with the
12 Liberty Life Assurance Company of Boston, which deprived Plaintiff of legitimate short-term
13 disability benefits. After Plaintiff used all his sick leave days and vacation days, Plaintiff was
14 basically left without income. The FMLA 90-day protection also ran out. UCDMC HR Labor
15 Relations Consultant Gina Harwood, for reasons unknown to Plaintiff, on November 14, 2011,
16 offered to Plaintiff an additional 12 weeks of supplemental FMLA time protection, which
17 Plaintiff declined. The short-term disability benefits had been denied to Plaintiff, so it was
18
nonsense to accept the FMLA protection extension to stay employed without the income.
19
292. In the response letter, dated November 23, 2011, to Gina Harwood,
20
Plaintiff wrote:
21
“At this point, I am not considering to file for an extension of my
22
medical leave under the Supplemental FMLA University Policy 2.210.
23
I am under enormous stress and pressure, and I have had enough. I was left
24
without a paycheck, so an extension of medical leave won’t help with at all.
25
The Settlement-Agreement I signed with the UC Regents in 2009 and my civil
26
rights were grossly violated by the University of California.
27
28
Contacting the benefits office regarding my current situation to discuss the

Page 106 of 107
1 effect of my health and welfare benefits makes no sense to me.
2 The University is fully responsible and legally liable for my current health
3 condition and the financial damages to me during this conflict.”
4 293. Thereafter, according to information Plaintiff received under Public
5
Records Act requests, the UC Davis chancellor requested from Danesha Nichols a confidential
6
report on Plaintiff, which was sent in November to Chancellor Linda Katehi. The exact day
7
when the confidential report was sent to Chancellor Katehi is unknown to Plaintiff because the
8
day was blacked out and removed by the UC Davis Public Record Act office. However, it
9
appears that the confidential report was sent prior to November 18, 2011, because Chancellor
10
Katehi deployed to the UC Davis Medical Center Lt. Matt Carmichael prior to November 18,
11
2011, to investigate Plaintiff. However, Plaintiff believes the main reason to deploy Lt. Matt
12
Carmichael to UC Davis Medical Center was to get Lt. Matt Carmichael out from the spotlight
13
of a premeditated pepper spray attack against protesting students on the UC Davis campus.
14
15 294. The premediated pepper spray attack ordered by Chancellor Katehi on November
16 18, 2011, was solely used to replace UC Davis Chief of Police Annette Spicuzza with Lt. Matt
17 Carmichael; fire from the job Lt. John Pike, who was ordered and used to casually and very visibly pepper
18 spray students; and force to retire UC Davis Captain Joyce Souza. Just after the premediated pepper spray
19 attack, Lt. Matt Carmichael, who on November 18, 2011, was in the UC Davis Medical Center, instantly,
20 as most likely planned, was assigned as the interim UC Davis chief of police. In May 2012, the new UC
21 Davis chief of police participated with Lt. James Barbour in the operation to provoke and kill or end
22 Plaintiff’s employment in the UC Davis Medical Center Trauma Unit #11.
23
24 295. On November 14, 2011, Plaintiff filed a complaint with the State of California
25 Department of Insurance against the Liberty Assurance Company of Boston for denying to
26 Plaintiff short-term disability benefits. The Liberty Assurance Company of Boston, without
27 conducting any reasonable investigation concerning its obligations under the contract,
28

Page 107 of 108
1 breached its contract, without good or sufficient cause, for reasons extraneous to the contract
2 and for the purpose of frustrating Plaintiff’s enjoyment of the benefits of the contract.
3 Accordingly, Liberty Assurance Company of Boston—complicit with the University of
4 California—breached its duty of good faith and fair dealing, treating Plaintiff differently and
5
applying different standards of conduct than with other claimants and other University of
6
California employees, without any legitimate justification. As a result of Liberty Assurance
7
Company of Boston’s breach and subsequent actions, Plaintiff has suffered and incurred (and
8
continues to suffer and incur) substantial losses of past and future earnings, compensation and
9
other benefits.
10
296. Three years later, in August and September 2014, the Liberty Assurance
11
Company of Boston made an attempt to settle the claim with Plaintiff for petty cash of $1,900.00.
12
Plaintiff declined such an offer, and the case is still unresolved.
13
297. November 2011 was a month of protests on University of California campuses,
14
and it was also the month when UC Davis Greek-born Chancellor Linda Katehi, nicknamed in
15
16 publications “Chemical Katehi,” on November 18, 2011, ordered gas attacks against peacefully
17 protesting students on the UC Davis Campus. In this way, Katehi observed and marked the 38th
18 anniversary of the student massacre at Athens Polytechnic by the Greek fascist military junta that
19 killed 25 people and injured over 1,000. In 1973, Linda Katehi was a student at Athens
20 Polytechnic.
21 298. A few days later, on November 23, 2011, UC Davis Vice Chancellor Claire
22 Pomeroy, who was in charge of UC Davis Medical Center School of Medicine, cried out in her e-mail
23 how the community was deeply shaken and disturbed by the pepper spraying of protesting students:
24
“Our university community is shaken by the deeply disturbing images we have
25
seen over the past few days. The video of the police action against peaceful
26
students stands in stark contrast to our deeply held commitments to freedom of
27
expression and to our UC Davis principles of community”
28

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1
299. Plaintiff responded to Vice Chancellor Pomeroy’s outcry with the following words:
2
Dear Ms. Pomeroy:
3
4
Can you do something about the National Socialism doctrine oriented and
5
entirely corrupted management in the UC Davis Medical Center, Plant
6
Operation and Maintenance and Human Resources Departments? The
7
8 Principles of Community does not exist in UCDMC and it is the empty slogan.
9 Your commitment to freedom of expression is also empty slogan as well. You
10 and others are receiving my letters for quite long and you and others don’t care
11 what the “UCDMC Gestapo” doing to me and how systematically is
12 destroying my and others livelihood and life. I am sending a few letters again
13 to you with hope that I will be heartened to see Ms. Pomeroy will order to
14 conduct a true investigation against the corrupted individuals in both
15 departments and restore a normal work environment in the UCDMC PO&M
16 Department.
17
Best regards and good luck with your commitment to freedom of expression.
18
JerryWaszczuk
19
Associate Development Engineer
20
21 300. Shortly after Plaintiff sent his message to Vice Chancellor Pomeroy cc’d to many
22 other University of California decision makers, Vice Chancellor Pomeroy was forced to resign due to
23 illegal medical experiments conducted under Pomeroy’s supervision for years by two UC Davis Medical
24 Center Dutch neurosurgeons, Dr. J. Paul Muizelaar and Dr. Rudolph J. Schrot, which caused
several patients’ deaths. So far, Plaintiff, with his words about the UC Davis Medical Center
25
National Socialism doctrine, was taking into consideration inhumane, illegal medical
26
experiments on humans in the Nazi concentration camp Auschwitz conducted on camp inmates
27
by the notorious Dr. Joseph Mengele.
28

Page 109 of 110
1 301. On November 23, 2011, the U.S. Equal Employment Opportunity
2 Commission informed Plaintiff that charges were filed against the University of California.
3
302. In addition to the above, on November 8, 2011, PO&M Manager Charles
4
Witcher, in his letter dated November 8, 2011, informed Plaintiff that he had denied Plaintiff
5
6 access to the university e-mail, with accusations that Plaintiff was sending inappropriate content
7 in his emails. Mr. Witcher also added a threat about the dismissal of Plaintiff’s employment if he
8 continued to communicate with others about the investigation and about hunting Plaintiff down.
9 Plaintiff responded to Mr. Witcher’s accusations and his denial of Plaintiff’s e-mail access with a
10 letter entitled “Gestapo on My Ass.” In Plaintiff’s response, he was making a “Gestapo”

11 reference to his previous UCDMC managers’ statements from the Central Plant. One manager
12 threatened Plaintiff with the words, “Somebody give this Pollack a bad evaluation and fire
13 him,” and another, in anger, was threatening Plaintiff that he would “Send the Gestapo on my
14 ass.”
15
303. Apparently, the UC Davis Medical Center Plant Operation and
16
Maintenance Department Manager Charles Witcher; his superior, Director Mike Boyd; and HR
17
Executive Director Stephen Chilcott forgot that Charles Witcher signed a February 2009
18
Settlement-Agreement with Plaintiff on behalf of the regents of the University of California, and
19
if Charles Witcher felt that Plaintiff violated any paragraph of the Settlement-Agreement, then
20
Charles Witcher was to inform the UC Davis Medical Center Legal Department and UC Davis
21
Chief Counsel Steven Drown, who also signed the Settlement-Agreement, to enforce the signed
22
Settlement-Agreement according to California law without threatening, humiliating, harassing
23
and discriminating against Plaintiff.
24
25 304. The conclusion of this chapter is that the Defendant with Liberty
26 Assurance Company of Boston, by their malicious conspiracy against Plaintiff, left Plaintiff
27 without any source of income, which they thought would be a very convincing argument to make
28 Plaintiff quit his job. When it was done, UC Davis Medical Center HR Benefits Manager John

Page 110 of 111
1 Peklar contacted Plaintiff by phone and was trying to convince Plaintiff to make an appointment
2 with him to retire from the university at the age of 60. Plaintiff declined this option as well due
3 to that Plaintiff was not even eligible for early Social Security at age of 61 1/2 benefits which
4 would be very little income in comparison with Plaintiff was earning.
5
December 2011
6
7 305. In December 2011, Defendant again forgot that in February 2009 they
8 signed a settlement-agreement with Plaintiff, and Defendant, through the settlement-agreement,
9 agreed to employ Plaintiff indefinitely. The agreement was to be enforced by the California
10 Court according to the state of California’s laws if violated by any party which signed the
11 settlement- agreement.
12 306. On December 5, 2011, Plaintiff’s superior Charles Witcher, to Plaintiff’s
13 disbelief, sent to Plaintiff another threatening letter during Plaintiff’s sick leave due to work-
14 related stress, in which Witcher ordered Plaintiff to go to an investigatory interview with
15
Danesha Nichols on December 12, 2011. Four years after this, Plaintiff is still in disbelief that it
16
actually happened, but taking into consideration that Plaintiff’s employment almost ended in UC
17
Davis Medical Center Trauma Unit #11 due to an unsuccessful provocation crafted by the same
18
management on May 30, 2012, then anything is possible at University of California.
19
307. To add another example, if one of workers for whom Plaintiff was
20
providing representation can be despicably attacked by the same UC Davis management during
21
his mother’s funeral, then employment at UC Davis Medical Center is full of surprises.
22
308. Plaintiff ignored Charles Witcher’s letter and his irresponsible threats to
23
dismiss Plaintiff from his employment during his stress-related sick leave. Removing Plaintiff
24
25 from sick leave unconditionally without Plaintiff’s physician’s permission and place Plaintiff on
26 unpaid leave was equal to suspension from work without pay.
27 309. Plaintiff was without income; the situation could not get any worse, and
28 Witcher’s threating letter was nothing else but ill-minded harassment and an attempt to

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1 intimidate Plaintiff and to make Plaintiff to quit his job voluntarily and wave his legal rights
2 outlined by the February 2009 Settlement –Agreement.
3 310.. On December 14, 2011, Plaintiff’s psychologist Dr. Bernhoft Ph.D., sent
4 an informational letter to Liberty Assurance Company of Boston, stating that Plaintiff’s mental
5
health significantly deteriorated due to the situation with Plaintiff’s employment and denial by
6
Liberty’s Short-Term Disability Benefits.
7
311. After the Defendant’s despicable action of removing Plaintiff from sick
8
leave, Plaintiff was expecting termination as the next Defendant step and Plaintiff had decided to
9
retrieve his private belongings from his UC Davis Medical Center HVAC shop office.
10
312. On December 19, 2011, Plaintiff sent a letter to HR Consultant Gina
11
Harwood stating that Plaintiff would be checking his personal file and that Plaintiff would like to
12
get his personal belongings from his HVAC shop office. Plaintiff asked Gina Harwood for UC
13
Davis police assistance to retrieve his private belongings, including, but not limited to, two
14
15 private computer hard drives.
16 313. Besides the above, Plaintiff informed Gina Harwood that Plaintiff was
17 willing to have a meeting with HR Investigator Danesha Nichols if she was willing to meet
18 Plaintiff on the same day that Plaintiff would be retrieving his personal file and his belongings
19 from his office. Gina Harwood responded that she set up the meeting with Danesha Nichols on
20 December 22, 2011, and that all Plaintiff’s belongings would be delivered to the HR building in
21 the morning and available for pick up at the time of Plaintiff’s appointment with Danesha
22 Nichols.
23 314. Gina Harwood also informed Plaintiff that the computers containing the
24
hard drives Plaintiff made reference to were deployed outside of the HVAC shop due to the
25
sensitive nature of the systems on those computers and the department being concerned about
26
removing the hard drives at that time. Also, Gina Harwood asked Plaintiff to provide receipts
27
showing the purchase of these hard drives, and the university would reimburse him for the cost.
28

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1 315. Plaintiff installed his private hard drives in the company computers as a
2 back up with his new manager Patrick Putney’s permission after he was abruptly removed from
3 the Central Plant to the HVAC shop in March 2007.
4 316. Plaintiff organized his office in the HVAC shop and not only installed his
5
private hard drives in two company PC computers but also purchased at his own expense a top-
6
of-the-line HP PC computer and installed it in his office to efficiently and professionally do his
7
job. The extra hard drives were installed for data backup.
8
317. In addition to the above, when Plaintiff arrived in HVAC shop in March
9
2007, Plaintiff noticed that the HVAC shop crew had no computers to do their time cards every
10
morning look their assignment and complete their work orders as well to have access to the
11
university policies and procedures via Internet and intranet and company e-mail. Every morning,
12
workers were lining up in the shop manager’s office to do their time cards and work orders on
13
one designated computer. It was an enormous waste of working time every day.
14
15 Plaintiff finally convinced two of his supervisor to bring used computers from the warehouse that
16 were already decommissioned and provide them to the crew for work orders and time cards.
17 Plaintiff cleaned, repaired and reprogrammed the old computers and provided them to HVAC
18 shop crew members to make their everyday job a lot easier and more efficient.
21 Plaintiff on the same day that he would be retrieving his personal file and his belongings from
22 his office.
23 319. Gina Harwood did set up an appointment with Danesha Nichols on
24
December 22, 2011.
25
320. When on December 22, 2011, Plaintiff arrived for the meeting with
26
Danesha in the UC Davis Medical Center HR building, a UC Davis police cruiser with officers
27
inside was on standby next to the building and Danesha Nichols had the assistance of a male
28

Page 113 of 114
1 person who disclosed to Plaintiff during the conversation that he had previously worked as a
2 security officer for the Littler Mendelson Law Firm in San Francisco on California Street, a place
3 which Plaintiff was very familiar with.
4 321. Meeting with Danesha Nichols was unproductive. However, later, Plaintiff
5
regretted that he got himself into this meeting because of her cover-up for management
6
misconduct and the child porn felon. ‘Danesha Nichols was pleasant at the meeting, but her clear
7
goals were to slander Plaintiff in her pseudo-investigation reports and get a pay raise, which she
8
did indeed receive regardless that Danesha Nichols received from Plaintiff 12 GIG of
9
information on the flash drive which Plaintiff provided to Danesha Nichols prior the meeting
10
with her. The only benefits from the meeting were that Plaintiff learned from Danesha Nichols’
11
report that she interviewed a hand-picked team she had picked in August and she crafted the
12
false cause for Plaintiff’s employment termination planned for September 23, 2011.
13
322. After meeting with Danesha Nichols, Plaintiff was placed again on
14
15 investigatory leave or administrative leave with pay. Plaintiff lost track of whether he was on
16 investigatory, investigation, administrative or other made-up leave by the UC Davis perpetrators.
17 323. The Defendant’ reckless and unwarranted attacks against Plaintiff in 2011
18 and gross violation of the 2009 settlement-agreement, along with harassment, retaliation,
19 enormous stress and anxiety, and the fear of losing employment, caused Plaintiff financial losses
20 in relation to his employment, which amounted to the approximate sum of $21,000.00, taking
21 into consideration accrued sick leave and vacation hours, which Plaintiff was forced to use due to
22 stress-related sick leave caused by the Defendant and the Defendant’ conspiracy with Liberty
23 Assurance Company of Boston, which resulted in Plaintiff’s short-term disability being denied.
24
25 January 2012
26
324. On or about January 10, 2012, Plaintiff noticed on his pay stub for the pay
27
period with an end date of 12/24/2011, that Plaintiff’s title had been changed without his
28

Page 114 of 115
1 knowledge, and for an unknown reason, from Associate Development Engineer to Programmer I,
2 which did not correspond in any way with Plaintiff’s title of Associate Development Engineer.
3 Plaintiff was promoted to Associate Development Engineer by the February 2009 Settlement-
4 Agreement that Plaintiff signed with the Defendant, the UC Regents of the University of
5
California. The Associate Development Engineer, under UC Davis Title Code 7182, was an
6
exempt position. Programmer I, under Title Code 7281, was a non-exempt employee title, with a
7
maximum earning of $30.69/hour, which translated to $3.62 less per hour than Plaintiff was
8
making under Title 7182 in Middle Step, with a Maximum Step earning of 43.20/hour for Title
9
Code 7182, translating to $12.51 less per hour for Title Code 7281 maximum earnings.
10
325. Plaintiff did not know why the job title change was made and could only
11
speculate that the Defendant made the decision to reassign Plaintiff to a different location.
12
However, Plaintiff failed to understand why nobody approached Plaintiff and made the
13
proposition to Plaintiff to find out if Plaintiff would be willing to make a change from the signed
14
15 2009 Settlement-Agreement, and work in a different shop.
16 326. If, in January 2012, Plaintiff would have known that the Defendant’ goal
17 was to separate Plaintiff from Metasys System and from any data and information related to the
18 UC Davis Medical Central Plant operation, then Plaintiff would most likely have taken a
19 different approach to the problem. Plaintiff would have attempted to renegotiate the signed
20 February 2009 Settlement-Agreement with the Defendant, regardless of the psychological terror,
21 harassment and despicable attacks on Plaintiff’s character and integrity that the Defendant
22 committed.
23 327. Plaintiff had no clue as to why this was done or who did it, but the
24
Defendant ignored the fact that according to the February 2009, the Settlement-Agreement,
25
Plaintiff’s position and work place cannot be changed without Plaintiff’s consent or a Court
26
Order.
27
328. On January 18 , 2012, Plaintiff noticed by looking at his pay stub dated
28

Page 115 of 116
1 January 18, 2012, that Plaintiff had been de-enrolled by the Defendant from the medical, dental
2 and vision insurance coverage plans.
3 329. On the same day, January 18, 2012, Plaintiff sent a letter to UC Davis
4 Medical Center Benefits Manager John Peklar, who tried in December 2012 to convince Plaintiff
5
to quit, and asked Mr. Peklar to immediately reinstate Plaintiff’s medical Benefits. Plaintiff
6
urgently needed to get his prescription medicine, and his medical lab had to be done soon, so the
7
Defendant de-enrolled Plaintiff from his medical insurance benefits.
8
Besides the above, Plaintiff mentioned to Mr. Peklar that Plaintiff’s job title had been changed
9
from Assistant Development Engineer to Programmer I, and asked Mr. Peklar to correct this
10
problem as well.
11
330. Due to conspiracy with the Defendant and fraudulent denial of
12
Plaintiff ‘s short term disability claim by the Liberty Life Assurance Company of
13
Boston , On January 24, 2012 the Plaintiff sent a letter to UC Davis Medical Center
14
15 HR Benefits Manager, John Peklar and requested to cancel Plaintiff’s Supplemental
16 Disability Insurance with the Liberty Life Assurance Company of Boston and Plaintiff
17 advised John Peklar that he make sure that that premium for this insurance will not be
18 collected anymore through the University of California payroll system.
19 331. On January 25, 2012, Plaintiff sent a letter to the UC Office President
20 liaison Mike Waldman, who was responsible for administrating the supplemental short-term
21 disability benefits, to intervene with Liberty Assurance Company Boston to pay Plaintiff’s
22 legitimate benefits, which were denied in November and December 2012. Plaintiff did not get
23 any response from Mr. Waldman.
24
332. At the end of January 2012, Plaintiff learned that his long-time physician,
25
who placed Plaintiff on stress-related sick leave for fourth months, wouldn’t provide any longer
26
medical service for Plaintiff and that Plaintiff’s psychologist’s residence in Lodi was raided by
27
the State of California Department of Social Services.
28

Page 116 of 117
1 February 2012
2
3 333. On February 8, 2012, UC Davis Medical Center HR Benefits & Equal

4 Employment Opportunity Manager Cindy G. Oropeza contacted Plaintiff by phone and asked
5 Plaintiff whether he was interested in informally resolving the conflict that had been long
6 ongoing and unresolved between Plaintiff and Defendant since April 2011. Plaintiff told Cindy
7
Oropeza that Plaintiff is always open to constructive discussion to informally resolve the
8
problem.
9
334. On the same day, February 8, 2012, Plaintiff confirmed receipt of an
10
invitation for informal dispute resolution via e-mail correspondence to Cindy Oropeza. Plaintiff
11
also confirmed his phone discussion with Ms. Oropeza and emphasized again that Plaintiff is
12
always open to discussion to find the best resolution for both sides of the conflict.
13
335. Furthermore, Plaintiff stated in his e-mail correspondence with Cindy
14
Oropeza that Plaintiff’s priority is to get his job back, granted and guaranteed, by the February
15
2009 Settlement –Agreement that Plaintiff signed with Defendant, the Regents of the University
16
17 of California.
18 336. Plaintiff in good faith also forwarded to Cindy Oropeza the latest e-mail
19 correspondence with Danesha Nichols, the investigator UC Davis Medical Center assigned to the
20 case, which stated that, if Plaintiff’s employer is looking for an informal resolution of the
21 problem, then Plaintiff would prefer not to see or read Danesha Nichols’ investigation findings
22 and the Defendant’ action based on Danesha Nichols’ findings. It would save Plaintiff’s and
23 others’ time and, if Plaintiff read the findings, would turn the ongoing conflict in a new direction
24 and open up a new, unpleasant dispute. Plaintiff also stated that he is very tired and very stressed
25 out from dealing with this conflict. Cindy Oropeza responded that UC Davis Medical Center’s
26
HR Labor Relation Manager will contact Plaintiff shortly and will set a meeting with Plaintiff to
27
discuss the possibility of resolving the conflict informally.
28

Page 117 of 118
1 337. . Plaintiff’s meeting with HR Labor Relations Manager, Mike Garcia, took
2 place in Mr. Garcia’s office in the HR Building on February 14, 2012. The meeting was fruitless
3 and Plaintiff was basically asked how much Plaintiff will ask, dollar-wise, to voluntarily quit his
4 job. During the discussion Plaintiff proposed that he will quit his job if Defendant will pay
5
Plaintiff his annual wages in a lump sum until Plaintiff is eligible for full Social Security
6
Benefits at age 66. Plaintiff, in February 2012, was close to 61 years old with his 61st birthday
7
coming up on May 30, 2012.
8
338. Plaintiff noticed during the meeting that Mike Garcia was stressed out;
9
Mr. Garcia told Plaintiff that he is very concerned about the whole situation, that it is very
10
unpleasant for him to deal with this problem and he is ready to retire from the University.
11
Plaintiff believes that Mike Garcia was, in 2012, similar to Plaintiff in age.
12
339. The meeting lasted approximately 30 minutes. Mike Garcia did not make
13
any promises or offers to Plaintiff during the meeting.
14
15 340. Plaintiff does not know why Plaintiff was asked to meet with Mike Garcia,
16 but Plaintiff believed that the Right to Sue Letter dated January 26, 2012, which Plaintiff
17 received from the U.S. Department of Justice, Civil Right Division and of which a carbon copy
18 was sent to the UC Davis Medical Center was one of the reason for explore possibility of
19 informal resolution.
20
341. In February 2012 and for a long time thereafter, Plaintiff had no intention
21
to sue the Defendant; instead, Plaintiff was hoping that the U.S. Equal Employment Opportunity
22
Commission (EEOC) would help him deal with his ongoing employment dispute with the
23
24
Defendant. However, when Plaintiff filed a complaint with U.S. EEOC against Defendant and
25 subsequently went to the EEOC’s San Francisco Office for an interview, Plaintiff was dismayed
26 to find that the EEOC intake officer was terrified of filing a complaint against the University of
27 California and dealing with UC attorneys. Plaintiff had no choice but to ask for a Right to Sue
28 Letter. Plaintiff could not find an attorney and was trying to get an extension of the Right to Sue

Page 118 of 119
1 Letter but his extension request was denied by the EEOC Director. Thereafter, Plaintiff was
2 almost killed by UC Davis police in the UC Davis Medical Trauma Unit # 11, after which his
3 employment ended due to the ill minded, heinous provocation and trap that was successfully set
4 by the criminally minded UC Davis administration.
5
342. Plaintiff believes the Defendant’ other reason for meeting with Plaintiff
6
and discussing informal resolution in February 2012 were Danesha Nichols’ pseudo
7
investigation reports, which Danesha Nichols already issued and signed but had not yet provided
8
to Plaintiff.
9
10 343. Defendant were perfectly aware that Plaintiff would be outraged by any
11 negative remarks in the reports about him. Plaintiff, since February 2009, was working for
12 Defendant under a Settlement – Agreement (the Contract) as an Associate Development
13 Engineer and had reminded the Defendant in almost every correspondence with them since April
14 2011 that they were breaching and violating the Settlement – Agreement they had signed with
15 Plaintiff.
16 344. In addition to the above, Plaintiff learned in February 2012 that HR Labor
17 Relation Manager Mike Garcia replaced HR Consultant Gina Harwood with experienced
18 attorney Jill Vandeviver to handle Plaintiff’s and Plaintiff’s coworkers’ complaints from the
19
same Department in which Plaintiff worked.
20
345. Besides the above, Plaintiff’s two coworkers, Kenny Diede from the
21
HVAC Shop and William Buckans from the Central Plant, asked Plaintiff to represent them in
22
their complaints pursuant to UC Davis Complaint Resolution Policy PPSM 70. Plaintiff agreed
23
to represent Kenny Diede and William Buckans with their complaints Step II appeals.
24
25
March 2012
26
27 346.. On March 7, 2012, Plaintiff received a two-page letter from UC Davis

28

Page 119 of 120
1 Chief Compliance Officer Wendi Delmendo, which informed Plaintiff that Danesha Nichols had
2 concluded the investigation in the whistleblowing complaint case #11-079, EP#2001, supposedly
3 assigned by Wendi Delmendo in July 2011. It was the complaint that Plaintiff never filed with
4 UC Davis Chief Compliance Officer Wendi Delmendo’s office.
5
On the contrary, in July 2011, Plaintiff sent two complaint letters to UC Davis Chief Counsel
6
Steven Drown, and Plaintiff was complaining to the UC Davis chief counsel about the 2009
7
Settlement-Agreement violations by the Defendant. UC Davis Chief Counsel Steven Drown
8
signed the 2009 Settlement-Agreement on the Defendant’, the Regents of the University of
9
California, behalf.
10
347. Plaintiff’s first letter to the UC Davis chief counsel, dated July 17, 2011,
11
was entitled “Settlement-Agreement Violations by UC Davis Medical Center PO&M
12
Department Supervisors and Managers as well by some of the HR Labor Relation Department
13
Personnel (Gina Harwood or Mike Garcia).”
14
15 348. Plaintiff’s second letter to the UC Davis chief counsel, dated July 24, 2011,
16 was entitled “Settlement-Agreement Violations, HR Department Personnel — Ms. Danesha Nichols
17 & Mrs. Gina Harwood, Invitation to Commit Fraud.”
18 349. In response to Plaintiff’s complaints to the UC Davis chief counsel about the
19 2009 Settlement-Agreement violation by the Defendant, on July 26, 2011, UC Davis Chief
20 Compliance Officer Wendi Delmendo sent Plaintiff an invitation to file a whistleblowing complaint.
21 350. On July 31, 2011, Plaintiff responded with a seven-page letter to UC
22 Davis Chief Compliance Officer Wendi Delmendo’s invitation and advised her that none of the
23 violations she outlined in her letter were qualified to file a claim against under the “UC
24 Whistleblower” policy.
25 351. Furthermore, the mentioned violations should have been be corrected
26 immediately by UC Davis Medical Center senior management through the administrative
27 process. The violations were so obvious and known by the general employee population in the
28

Page 120 of 121
1 UC Davis Medical Center PO&M Department. All Plaintiff letters were forwarded to UC Davis
2 Medical Center directors, and they should have taken care of business as the directors and
3 administrators. Plaintiff was aware that the UC Davis Chief Compliance Officer is dragging
4 Plaintiff in her deceptive whistleblowing complaint game.
5
Plaintiff also informed the UC Davis chief counsel that UC Davis Medical Center Plant
6
Opertaionand Maintenance management misconduct were addressed in Plaintiff’s response
7
dated July 15, 2011, addressed to HR Consultant Gina Harwood, who was handling the case
8
from the HR side.
9
10 352. In her March 7, 2012, letter entitled “Outcome of Whistleblower Investigation,

11 Case #11-079, EP#2001,” UC Davis Chief Compliance Officer Wendi Delmendo must have
12 forgotten about the Settlement-Agreement Plaintiff signed in 2009 with the UC regents. The UC
13 Davis chief compliance officer also forgot in her letter the real issues, problems and violations, which
14 were pointed out by Plaintiff in the letter dated March 13, 2011, addressed to UC Davis Medical
15 Center Plant Operation and Maintenance Department Head Charles Witcher and in Plaintiff’s letter
16 dated July 31, 2011. The serious matters which were reported by Plaintiff and which eventually
17 would fall in to category of whistleblowing complaints but never were investigated, including and
18 not limited to UC Davis Medical Center Central Plant operator Todd Goerlich’s suicide in December
19 2010, the burglary in the Central Plant locker room in December 2010, the secret 12% pay raise for
20 the Central Plant operators in December 2010 provided to them based on the blackmail petition,
21 child pornography activities in the UC Davis Medical Center HVAC shop, and UC Davis HVAC
22
Shop Supervisor Dorin Daniluc’s special relationship with two corrupted UC Davis Medical Center
23
directors, perhaps Robert Taylor and Shelton Duruisseau Ph.D, who besides holding director
24
positions in UC Davis Medical Center were appointed to the State of California Medical Board by
25
Governor Arnold Schwarzenegger in 2004.
26
353. On March 11, 2012, Plaintiff responded to Wendi Delmendo’s insulting conclusion
27
of Danesha Nichols’ pseudo-investigation, and Plaintiff pasted in his response the letter he wrote to
28

Page 121 of 122
1 Wendi Delmendo on July 31, 2011, to remind her about the real problems in the UC Davis Medical
2 Center.
3 354. On March 15, 2012, Plaintiff sent an open letter to the investigator Danesha Nichols,
4 assigned by Wendi Delmendo, and Plaintiff further addressed the outcome of Danesha Nichols’
5 investigation outlined in Wendi Delmendo’s letter dated March 7, 2012.
6 355. On March 15, 2012, Plaintiff sent a letter together with eight pages of statements
7 of facts to Leslie Moore, assistant director, Safety and Hospitality Service, who was assigned by
8
the UC Davis HR Department as the compliance resolution officer (CRO) to conduct a hearing
9
on the complaint step II appeal filed by Kenneth Diede against the HVAC shop manager Patrick
10
Putney pursuant to UC Davis Policy PPSM 70. Kenneth Diede, in July 2011, reported a twice-
11
convicted child pornography felon who was illegally accessing HVAC shop computers. The
12
shop manager, Patrick Putney, retaliated against Kenneth Diede for reporting the porn felon by
13
issuing a bad annual evaluation and made Kenneth Diede’s life miserable and working
14
conditions in the shop intolerable.
15
356. In response to Plaintiff’s letter addressed to CRO Leslie Moore, on March 21,
16
2012, UC Davis HR Labor Relation Manager Humberto “Mike” Garcia sent a letter to Plaintiff
17
18 stating that he understood that Plaintiff is representing William Buckans and Kenny Diede
19 through the PPSM 70 complaint appeal process. However, since Plaintiff was on paid
20 investigatory leave, Plaintiff would not be permitted to attend any procedural meetings with
21 (CRO) related to both of Plaintiff’s clients’ (as he stated) complaints until a decision was made
22 in the matter related to the allegations made against Plaintiff. Furthermore, Humberto Garcia
23 stated that the university was amenable to placing both the William Buckans and Kenny Diede
24 complaints in abeyance until a decision was made in the matter referenced above and that
25 Plaintiff may elect to submit his arguments to the CRO in writing or Plaintiff’s clients (as he
26 stated) may elect to be represented by someone else.
27
28 357. Plaintiff met Humberto Garcia on February 14, 2012 in the UC Davis

Page 122 of 123
1 Medical Center HR building to discuss the informal resolution of the ongoing dispute. HR
2 Investigator Danesha Nichols issued an investigation report and concluded her pseudo-
3 investigation on February 9, 2012. UC Davis Chief Compliance Officer Wendi Delmendo
4 confirmed by the letter dated March 7, 2012, that Danesha Nichols finalized her investigation,
5
and nothing in the chief compliance officer’s letter indicated that any other investigation was
6
going on that could justify keeping Plaintiff on investigatory leave instead of letting him come
7
back to work. William Buckans and Kenny Diede were not Plaintiff’s clients but Plaintiff’s
8
coworkers from the same UC Davis Medical Center department, and Plaintiff provided
9
representation to them in their administrative complaints. It is a mystery for Plaintiff why
10
Plaintiff was prohibited from attending the CRO meeting for William Buckans and Kenny
11
Diede if it was not a problem for Humberto Garcia to meet Plaintiff on February 14, 2012, in his
12
UC Davis Medical Center office.
13
14
358. Today, Plaintiff looks at Humberto Garcia’s e-mail letter dated March 21,
15
2012, differently than Plaintiff looked at it in March 2012. Today, Plaintiff looks at Humberto
16
Garcia’s e-mail letter, , as a letter that may have saved Plaintiff’s life, taking into consideration
17
who was in charge of the UC Davis Police Department in March 2012 and why Mathew
18
Carmichael was assigned as interim UC Davis Police Chief by UC Davis Administration.
19
Humberto Garcia and HR attorney and Humberto Garcia assistant Jill Vanderviver, did not
20
survive long after February 2012 attempt to resolve informally with Plaintiff ongoing dispute.
21
22 359. In addition to the above, on March 19, 2012, Plaintiff sent a letter to
23 University of California Senior Vice President Chief Compliance and Audit Officer Sheryl Vacca
24 and asked her for an independent investigation. Also, Plaintiff requested under the Public Record
25 Act provision all the documents related to Danesha Nichols and Wendi Delmendo’s pseudo-
26 whistleblowing complaint investigation, which concluded in February and March 2012.
27 April 2012
28 April 2012- The Stephen Chilcott’s Unsigned Letter

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1 360. Under the Public Record Act, Plaintiff received an unsigned letter dated
2 April 5, 2012, which was addressed to him. The letter was typed by or for UC Davis Health
3 System HR Executive Director Stephen Chilcott who, in 2009, solicited and most likely crafted
4 the Settlement-Agreement that Plaintiff signed with the Defendant, the Regents of the University
5
of California. The Agreement guaranteed Plaintiff’s indefinite employment with the University
6
of California as the associate development engineer.
7
361. Stephen Chilcott’s unsigned letter, dated April 5, 2012, stated that Plaintiff
8
is currently on UC Davis Health System administrative leave with pay while options for possibly
9
returning to work are being reviewed, which contradicts UC Davis Medical Center HR Labor
10
Relation Manager Humberto Garcia’s letter dated March 21, 2012, which stated that Plaintiff is
11
on investigatory leave and that Plaintiff is not permitted to attend any procedural meetings to
12
represent his coworkers in their complaints under UC Davis Policy PPSM70, the Step II appeals.
13
Furthermore, Stephen Chilcott’s letter stated that UC Davis Health System Labor Relations
14
15 would contact Plaintiff when the administrative review has been completed without any specifics
16 of what administrative review Stephen Chilcott had on his mind.
17
18 April 2012- The Complaint with U.S Department of Labor , OFCCP Office
19
20 362. Due to UC Davis Medical Center HR Labor Relation Manager Humberto

21 Garcia’s letter dated April 21, 2012, which prohibited Plaintiff from representing two of his
22 coworkers, Kenneth Diede and William Buckans, with their complaint under UC Davis Policy
23 PPSM 70, on April 9, 2012, Plaintiff sent by mail a complaint and request for intervention and
24
help to Regional Director of the U.S. Department of Labor for Office of Federal Contract
25
Compliance Programs (OFCCP) William D. Smitherman on William Buckan’s, Kenny Diede’s
26
and Plaintiff’s own behalf.
27
363. The University of California is a federal contractor, and Plaintiff was
28

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1 advised by the U.S. OFCCP in November 2011 that a complaint with U.S. OFCCP has to contain
2 more than one person to be considered, reviewed and pursued by OFCCP.
3 364. On April 12, 2012, Plaintiff received a response from U.S EEOC San
4 Francisco office to his, William Buckan’s, and Kenny Diede’s April 9, 2012, complaint with
5
information that the complaint was forwarded to the U.S. Equal Employment Opportunity
6
Commission (EEOC) and a comment stating that, upon review of the contents of the
7
correspondence, it became clear that Plaintiff mistakenly sent the complaint to the OFCCP
8
instead of to the EEOC, contrary to the already-mentioned November 2011 EEOC advice.
9
Plaintiff did not want to pursue the new claim with the EEOC after the previous EEOC intake
10
officer’s trauma of dealing with the University of California’s attorneys.
11
365. Also on April 12, 2012, Plaintiff, for unknown reasons, received a letter
12
from UC Davis HR Benefit Manager John Peklar about Plaintiff’s short-term disability benefits,
13
Liberty Assurance Company of Boston (Liberty) which in conspiracy with the Defendant was
14
15 denied in November and December 2011 to Plaintiff. . Further, Plaintiff’s complaint against
16 Liberty had been pending with the state insurance commissioner’s office since November 2011.
17 UC Davis HR Benefits Manager John Peklar was the person who disenrolled Plaintiff from
18 medical insurance in December 2011 without Plaintiff’s knowledge. Since Plaintiff did not want
19 to risk being left without medical insurance, he enrolled himself and his wife in medical
20 insurance with Nordstrom Corporation, where Plaintiff’s spouse has been employed since 1990,
21 paying an extra $200/month.
22
April 2012 – Letter Of Intent to Suspend with 10 Days without Pay
23
24
366. Instead of a response from the Defendant in regard to the informal
25
resolution initiated by the Defendant in February 2012, Plaintiff, on April 13, 2012, received
26
from the Defendant a Letter of Intent to Suspend signed by the UC Davis Medical Center Plant
27
Operation and Maintenance Department Head Charles Witcher—the same Charles Witcher who,
28

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1 on March 23, 2007, signed a very similar letter with intent to suspend Plaintiff using very similar
2 lies and unfounded accusations defacing and defaming Plaintiff. Charles Witcher’s 2007 Letter
3 of Intent to Suspend lead Plaintiff to obtain a promotion from the position of cogeneration plant
4 operator to associate development engineer with a $7,000.00 base salary increase and indefinite
5
employment with the University of California granted and guaranteed to Plaintiff by the
6
February 2009 Settlement–Agreement Plaintiff signed with the Regents of the University of
7
California after Plaintiff successfully defeated the Defendant in arbitration with an arbitrator
8
assigned by the UC Davis administration. Charles Witcher was one of four who signed the 2009
9
Settlement–Agreement on the Defendant’ behalf.
10
367. The Letter of Intent to Suspend informed Plaintiff that the Defendant
11
intended to suspend Plaintiff for a period of ten (10) working days commencing on April 25,
12
2012. The reasons that were given for the issuance of this letter were the Defendant’ lies and
13
unfounded accusations that Plaintiff continued inappropriate behavior in the workplace.
14
15 Specifically, the Defendant’ lies accused Plaintiff that his behavior was in violation of UCDHS
16 Policy 1616 — Violence and Hate Incidents in the Workplace and UC Davis Policy and
17 Procedure 380-15 Staff Complaints of Discrimination. Additionally, unfounded accusations and
18 lies in the letter implied that Plaintiff failed to adhere to specific instructions during the
19 investigation to refrain from engaging in email communications with witnesses, which interfered
20 with the investigation, as outlined in the report.
21 368. Furthermore, the unfounded allegations in the Letter of Intent to Suspend
22 were made that on March 8, 2011, April 21, 2011, and May 5, 20011, Plaintiff engaged in
23 behavior that violated UCDHS Policy 1616—Violence and Hate Incidents in the Workplace. It
24
was alleged that Plaintiff’s behavior was disruptive and intimidating to Dorin Daniliuc when he
25
allegedly pointed his finger in his face and used profanity on March 8, 2011. Further, on April
26
21, 2011, Plaintiff allegedly became disruptive and intimidating toward Patrick Putney during a
27
discussion regarding the Putney and Daniliuc ’s work performance as Plaintiff understood the
28

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1 letter. An investigation was conducted and both of these allegations were substantiated. At the
2 end of the statement, Plaintiff was advised to see attached report Issue #1, #2, and #3. If the
3 accusations were true, then the lies regarding the use of profanity and disruptive behavior in
4 March and April would have had an impact on Plaintiff’s 2010–2011 Employee Performance
5
Review(Evaluation ) because the alleged violations fell into the 2010–2011 evaluation period
6
(i.e., rather than the 2011–2012 period). Especially it would happen because Dorin Daniliuc and
7
Patrick Putney were Plaintiff’s supervisors and Plaintiff and Putney and Daniliuc would punish
8
Plaintiff right away by issuance of letter of expectation, written warning or even suspension from
9
work right after alleged incident by using UC Davis Progressive Discipline Policy PPSM 62. The
10
“does not meet expectation evaluation” for 2010-2011 work period would follow, It would be
11
done according to UC Davis progressive discipline Policy PPSM 62.
12
369. Since February 2009, Plaintiff has been employed by the Defendant by the
13
Settlement–Agreement (Contract), which is enforceable only by State of California law and the
14
15 State of California Court of Law, not by slanderous pseudo-investigation reports that financially
16 harm and defame Plaintiff (i.e., Witcher’s Letters of Intent to Suspend).
17 370. At the end of the letter, Plaintiff was instructed that Plaintiff has the right
18 to respond, either orally or in writing, to the notice of intent to suspend. Plaintiff’s response must
19 be received by the Skelly Reviewer, Michael Pansius (916-734-6572), within eight (8) calendar
20 days from the date of issuance of this letter.
21 371. The assigned Skelly Reviewer, Michael Pansius, was the subordinate of
22 UC Davis Medical Center Director Mike Boyd from the facilities construction and design
23 department.
24
372. In July 2011, Director Mike Boyd took charge of the UC Davis Medical
25
Center Plant Operation and Maintenance Department and became Charles Witcher’s superior.
26
373. Director Mike Boyd took charge of the UC Davis Medical Center Plant
27
Operation and Maintenance Department after his partner in crime, Director Robert Taylor, left
28

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1 his post one year before his retirement. The UC Davis Medical Center Directors Mike Boyd,
2 Robert Taylor and Shelton Durressau, Ph.D, were responsible for a massive, unlawful, and
3 deliberate machine oil discharge from defective cooling tower gear boxes to the Sacramento
4 River for seven years (i.e., from 1998 to 2005).
5
374. Never before had UC Davis Plant Operation and Maintenance belonged to
6
the Facilities Construction and Design Department of which Boyd was in charge. Construction
7
and Design is a strictly engineering department without maintenance personnel. Apparently, due
8
to the central plant operators’ blackmail petition for a 12% pay raise, the old crime related to the
9
central plant’s unlawful oil discharge to the river—for which Boyd was responsible—resurfaced
10
and Boyd was forced to take charge of the plant operation and maintenance department after
11
Robert Taylor left his post.
12
375. After Plaintiff received Witcher’s letter to suspend, Plaintiff was furious
13
and in disbelief that he was receiving such subhuman treatment by the Defendant. The
14
15 Defendant, in a gross violation of the 2009 Settlement–Agreement, caused Plaintiff significant
16 financial losses in 2011 and Plaintiff lost all accrued vacation and sick leave hours. Plaintiff’s
17 total financial losses in 2011 amounted to approximately $21, 000, due to the inhumane
18 treatment that Plaintiff received from the Defendant.
19
376. On April 15, 2012, Plaintiff requested from Defendant all available
20
documents related to the UC Davis Medical Center HR investigator pseudo-investigation. The
21
requested documents that were included were all generated by Danesha Nichols’ investigatory
22
reports.
23
24
377. On April 20, 2012, Plaintiff responded to the Defendant’s Letter Intent to
25 Suspend signed by Charles Witcher and, in his 26-page response, demanded from the assigned
26 Skelly reviewer, who did not know Skelly law, to entirely disregard and dismiss all lies and
27 unfounded accusations outlined in the Witcher suspension letter.
28 April 2012- “ Welcome to Romania Slide Show”

Page 128 of 129
1
2 378. In great disappointment over the investigatory reports and the unwarranted
3 attack on Plaintiff with the Letter of Intent to Suspend, on April 27, 2012, Plaintiff sent a short
4 email to Danesha Nichols expressing his feelings about her reports. Plaintiff attached to the e-
5
mail a video clip/slide show entitled “Welcome to Romania.” It shows post-communist
6
devastated Romania and some scenes in the slide show had lot in common with the landscape in
7
the HVAC shop supervised by Dorin Daniliuc and Patrick Putney.. Later, the “Welcome to
8
Romania” slide show was exploited and repeatedly used to attack Plaintiff and as cause and
9
pretext to terminate Plaintiff’s employment.
10
379. Danesha Nichols attempted to bully and intimidate Plaintiff, and she
11
received a proper response from Waszczuk. Waszczuk reported Nichols and Chilcott to the State
12
Bar in October 2011and 2013 and reported Nichols to UC Davis Police (Captain Souza and Lt.
13
Pike). If the UC Davis investigator was to investigate Nichols for anything, it would be Central
14
15 Plant Operator Todd Georlich’s suicide, which occurred on December 22, 2010; Central Plant
16 Operator Jeff Lancaster’s locker burglary; the secret 12% pay raise for central plant operators in
17 December 2010, based on blackmail petition; Daniliuc’s involvement in his private enterprise on
18 company time, as well the fact that he was employed by two UCDMC Directors—Robert Taylor
19 and Shelton Duruisseau—in their private residences in exchange for giving him a supervisor
20 position and access to free HVAC parts and equipment and presence in the HVAC shop, though
21 he was a twice-convicted child pornography felon who illegally was accessing the UCDMC
22 HVAC shop computer during his probation or parole time.
23 380. Danesha Nichols swept under the rug the child pornography felony matter
24
in her report instead of turning porn felon into authorities and obtaining a restraining order.
25
Instead, in her reports Nichols made Plaintiff look five times worse than , a twice-convicted child
26
pornography felon; thus, Nichols grossly violated law by not reporting a felon on probation to
27
authorities and grossly violating the 2009 Settlement–Agreement that Plaintiff signed with the
28

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1 Regents of the University of California by defacing and demeaning Plaintiff in her reports. The
2 Settlement–Agreement prohibited the Defendant from making any disparaging and untrue
3 statements aimed at Plaintiff. Further, Nichols, Seifert, and Oropeza’s fabricated reports are not
4 only disparaging to Plaintiff, but defame Plaintiff’s character and integrity and signify a gross
5
violation of his civil rights.
6
7 May 2012
May 2012- Defendant Preparation for the May 31, 2012 Provocation to Kill Plaintiff
8
9
381. In April and May 2012, Plaintiff did not know or was aware that the
10
Defendant were negotiating the new power sale contract with the Sacramento Municipal Utility
11
12 District (SMUD) and the UC Davis Medical Center Central Plant cogeneration facility. The
13 Defendant got very inpatient with Plaintiff’s continued presence on the Defendant’ payroll list.
14 382 .The psychological terror, abuse, harassment, and retaliation that Plaintiff
15 was subjected to for almost one year, which was orchestrated and carried out by the Defendant’
16 lawyers, managers, and psychologists at the UC Davis Medical Center HR Department with the
17 full support of the UC Davis Chancellor Office and the University of California Office of the
18 President did not work to force Plaintiff to quit voluntarily The decision was made to eliminate
19 Plaintiff by provocation and by means of a bullet from the pistol of UC Davis Police Lt. James
20 Barbour who was assigned by Defendant to carry out assassination on May 31, 2012.
21 383. On May 1, 2012, Plaintiff did not know how close Plaintiff was to being
22 killed or his employment ending in the UC Davis Medical Center Trauma Unit # 11 due to the
23 ill-crafted provocation of an especially assembled team, which Plaintiff later nicknamed in
24
documents “UC Davis Death Squad.”
25
384. The first stage of preparation to provoke and eliminate Plaintiff was the
26
February 14, 2012, fruitless meeting with Humberto Garcia from the UC Davis HR Department,
27
which was intended to informally resolve conflict or let Plaintiff return to work after six months
28

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1 of Plaintiff’s involuntary absence. The meeting was organized to identify how anxious or eager
2 Plaintiff was to leave his job and what pressure needed to be applied to make it happen.
3 385. The second preparation step to provoke and eliminate Plaintiff came in
4 March 7, 2012, with UC Davis Chief Compliance Officer Wendi Delmendo’s whistle-blowing
5
decisions about the chickens, roosters, ducks, goats, and sheep sale in the UC Davis Medical
6
Center HVAC shop by supervisors Patrick Putney and Dorin Daniliuc.
7
386. The third preparation step to provoke and eliminate Plaintiff came in March
8
21, 2012, when Plaintiff received a letter from Humberto Garcia of the UC Davis Medical Center
9
HR Labor Relations Department informing Plaintiff that Plaintiff was still on investigatory leave
10
and was prohibited from entering UC Davis Medical Center premises to represent his coworkers
11
in their complaints appeals hearings with a Compliance Resolution Officer. This happened after
12
all the pseudo-investigations conducted by UC Davis HR investigator Danesha Nichols were
13
finished and four pseudo-investigation reports were issued.
14
15 387. The fourth preparation step to provoke and eliminate Plaintiff was the April
16 13, 2012, Letter of Intent to Suspend Plaintiff without pay for 10 days during Plaintiff‘s already
17 nine (9) months forced absence from work. The letter of intent to suspend did not even say or
18 inform Plaintiff when Plaintiff was supposed to return to work
19 May 2012 – May 7, 2012 Events

20 388 On May 7, 2012, Plaintiff received information at a gathering of the UC
21 Davis Medical Center Plant Operation and Maintenance managers and supervisors at the UCDMC
22 Police Station. The gathering included but was not limited to the presence of Charles Witcher,
23 Dennis Curry, Sue Carter, Patrick Putney, Steve McGrath, and Dorin Daniliuc.
24
389. On May 7, 2012, to prime Plaintiff for May 31, 2012 provocation ,
25
ordered UCDMC HR assigned pseudo Skelly Officer Michael Pansius to sign “HIS” decision to
26
suspend and deprive Plaintiff of his 10 days of earnings. Plaintiff’s budget was already stretched
27
due to last year’s financial losses caused by the Defendant, and Plaintiff was not happy about it
28

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1 at all.
2 390. On May 7, 2012, the UC Office of the President’s Director of
3 Investigations John Lohse got involved in the conflict against Plaintiff by sending Plaintiff a
4 letter in which he defended the corrupt UC Davis Chief Compliance Officer Wendi Delmendo.
5 Afterwards, Plaintiff checked out John Lohse’s biography and found that:
6 “John A. Lohse is the Director of Investigations in the Office of the Senior
7 Vice President and Chief Compliance and Audit Officer of the Regents of the
8
University of California. He is responsible for coordinating, tracking,
9
managing and conducting investigations at the Office of the President and
10
system-wide. Mr. Lohse came to the University of California in January 2004
11
after a career with the Federal Bureau of Investigations (FBI), where he served
12
as a Special Agent, Associate Division Counsel and Chief Division Counsel
13
for the FBI’s San Francisco Division. In addition, the United States Attorney
14
for the Northern District of California appointed Mr. Lohse as a Special
15
Assistant United States Attorney. Prior to his service with the FBI, he was a
16
criminal prosecutor with the Maricopa County Attorney’s Office in Phoenix,
17
18 Arizona. Mr. Lohse is a member of the State Bars of California and Arizona.
19 He is also a Private Investigator, licensed by the State of California. He was at
20 relevant time is a Director of Association of Work Place Investigators (AWI).”
21 391. Plaintiff was very impressed with Director John Lohse professional career
22 and achievements. However, in the situation Plaintiff found himself in with respect to his
23 employment, Plaintiff was convinced that Director Lohse was coordinating unknown actions
24 against Plaintiff and that Director Lohse perfectly fit the profile of framing Plaintiff. Plaintiff
25 expressed his thoughts in a response letter to Director John Lohse dated May 14, 2012. After
26 Plaintiff responded to Mr. Lohse’s letter and sent to his office a few other documents related to
27 the case, Plaintiff never heard from Lohse again.
28

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1 392. May 7, 2012, was a very busy day. Plaintiff did not know at this point
2 whether there was a coordinated action against Plaintiff to elevate Plaintiff’s stress level to the
3 expectations of the conspirators.
4 May 2012- The May 11, 2012 Ten Days Suspension Letter Without Pay
5
6
393. On May 11, 2012, Charles Witcher was ordered to serve Plaintiff a 10-
7
day suspension without pay from May 16, 2012, to May 30, 2012. The letter was based on
8
unspecified and fabricated accusations and allegations that were never witnessed by anybody.
9
Plaintiff’s stress levels and blood pressure went up, and nitroglycerine and Lorazepam were very
10
helpful.
11
May 11, 2012
12
13
Jaroslaw Waszczuk
524 Swallow Lane
14 Lodi, CA 95240
15
RE: Letter of Suspension
16
The purpose of this letter is to inform you that I am suspending you for a
17
period of ten (10) working days without pay, commencing May 16, 2012
18
through May 30, 2012. The reason for this action is your continued
19
inappropriate behavior in the workplace. Specifically, your behavior is in
20
violation of UCDHS Policy 1616 — Violence and Hate Incidents in the
21
Workplace and UC Davis Policy and Procedure 380-15 Staff Complaints of
22
Discrimination. Additionally, your failure to adhere to specific instructions
23
during the investigation to refrain from engaging in email communications
24
25
with witnesses interfered with the investigation as outlined in the report.
26 The suspension will begin on Wednesday, May 16, 2012 and end on
27 Wednesday, May 30, 2012. You are expected to report to work at 8 a.m.
28 on Thursday, May 31, 2012 to Facilities Support Services

Page 133 of 134
1 Building, :4800 2 nd Avenue, Suite 1500, Sacramento, CA, to Charles
2 Witcher. No new information has been received to cause a change in the
3 action.
4 On an immediate and sustained basis, I expect you to:
5
Follow and abide by all UC Policies and Procedures
6
Show respect and remain professional at all times in the workplace
7
Follow the direct orders given to you by a superior
8
Attend classes as requested by management, specifically in regard to
9
communication and respectful treatment
10
Failure to meet my expectations may result in further corrective action up
11
to and including dismissal.
12
You have the right to request review of this action under Personnel
13
Policies for Staff Members 70 - Complaint Resolution. If you wish to
14
15 request review of this action, you must do so in writing, using the
16 appropriate complaint form. A written request must be received in the
17 Employee & Employee & Labor Relations office no later than thirty (30)
18 calendar days from the date of this letter.
19 Charles Witcher
20 Manager, Plant Operations and Maintenance
Attachments: Proof of Service
21 Skelly Decision
22
cc' [Department File]
[UCDHS Employee & Labor Relations w/attachment]
23 [UCDHS HR Records w/attachment]
24
25 394. In Charles Witcher’s Letter of Suspension, dated May 11, 2012, Plaintiff
26 was instructed to report to Charles Witcher’s office on May 31, 2012, at 8:00 a.m. Plaintiff was
27 not aware that just a day before, Charles Witcher had been instructed by Brent Seifert, Cindy
28

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1 Oropeza, or Stephen Chilcott from the HR Department to write and hand to Plaintiff the
2 investigatory leave note upon Plaintiff’s arrival, which, according to documents, should trigger
3 events which would end Plaintiff’s employment in the UC Davis Trauma Unit # 11 with Trauma
4 Unit Manager Karen Kouertas on standby to receive Plaintiff.
5
395. On May 14, 2012, Plaintiff filed a complaint under UC Davis Policy PPSM
6
70 against Defendant’ wrongful suspension
7
8 May 2012 – The Defendant Attack Aimed at Plaintiff Coworkers , Kenny Diede
and William Buckans
9
10
397. In further preparation to send Plaintiff to the trauma unit, on May 18 and
11
23, 2012, PO&M Manager Charles Witcher, Patrick Putney, Dennis Curry, and Mike Lewis, in a
12
retaliatory manner, attacked the two coworkers Plaintiff was representing in complaints against
13
some of the above-mentioned individuals. Within one week, Kenny Diede and William Buckans
14
were served with despicable Letters of Expectation, which were based on phony, unfounded, and
15
fabricated accusations.
16
17 May 2012- Plaintiff Protest Letter Entitled “ The Retaliation Isn’t Wise’
18 398. On May 24, 2012, Plaintiff issued a 13-page protest letter entitled, “The
19 Retaliation Isn’t Wise,” against management’s vicious attack on Kenny Diede and William
20 Buckans and sent it to the perpetrators and senior management and administration at UC Davis
21 and the UC Office of the President.

22 May 2012- The Stress Management Class
23 399. Per instruction in the Defendant’s letter of suspension, dated May 11, 2012,
24 on May 30, 2012, Plaintiff, with his two coworkers Kenny Diede and William Buckans, attended
25 voluntarily a stress management class at UC Davis Medical Center HR Building Tycon III.
26
Plaintiff signed for class one week before.
27
400. Just after Plaintiff had arrived and signed into the class, which was open to
28

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1 any UC Davis Medical Center employee who wanted to participate, Plaintiff was approached by
2 the class host HR Licensed Social Worker Marjorie Trogdon Shock and HR Workers
3 Compensation Manager Hugh Parker. To his disbelief, Plaintiff, after a short conversation with
4 Shock and Parker, was asked to leave the class and told that it was out of the question that Plaintiff
5
could stay and participate in the discussion. Plaintiff left the class and drove home without any
6
further incidents. Plaintiff did not know that or was aware on his 61st Birthday he was sentenced
7
to death by Defendant because on May 29, 2012 Defendant signed so long awaited power sale
8
contract with the Sacramento Municipal Utility District to sell surplus electrical energy from the
9
UC Davis Medical Center Central Plant cogeneration facility.
10
May 2012- May 30, 2012- Plaintiff’s 61st Birthday
11
12
401. May 30, 2012, was Plaintiff’s 61st birthday and on May 30, 2012, Plaintiff
13
did not know that the HR Workers Compensation Manager was a coordinator of the assembled
14
15 “UC Davis Death Squad” and planning to end Plaintiff’s employment with the University of
16 California on May 31, 2012 (the next day) at the UC Davis Medical Center Trauma Unit. Plaintiff
17 also did not know on his 61st birthday that the host of the stress management class Marjorie
18 Trogdon Shock was also a member of the assembled “UC Davis Death Squad,” the goal of which
19 was to end Plaintiff’s employment at the UC Davis Trauma unit # 11 because Defendant signed
20 power sale contract for UCDMC Central Plant with Scaramanto Municipal Utility Distict
21 on May 29, 2012.
22 402. On May 31, 2012, per Defendant’ suspension letter dated May 11, 2012,
23 Plaintiff was scheduled to return to work after 10 months of absence and report to Charles
24
Witcher’s office in Bldg. 68.
25
403. Plaintiff had heard from his coworkers that the carpenter shop was
26
building two extra offices on the first level of Building 68, and Plaintiff was hoping that
27
Defendant would eventually move Plaintiff from the HVAC shop to Bldg. 68 and that the
28

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1 conflict would end.
2 May 2012- The May 31, 2012 Defendant Provocation to Kill Plaintiff
3
4 404. On May 31, 2012, I drove to work and parked my car next to HVAC shop
5
as usual with a valid parking permit. Before Plaintiff reported to the Department Head Charles
6
Witcher’s office, Plaintiff went to the Marriott Hotel across from the HVAC shop to eat
7
breakfast in the cafeteria. I met my two coworkers, who joined me for breakfast.
8
405. Plaintiff was not expecting to be placed on investigatory leave again,
9
which Plaintiff hated, and Plaintiff wanted to go back to work after such a long period of absence
10
regardless of the fact that Plaintiff had been subjected by Defendant to more than one year of
11
psychological terror, harassment, retaliation, significant loss of income, and multiple threats of
12
employment termination. Plaintiff could expect anything but never expected that that highly
13
regarded University of California would assemble a “Death Squad” to resolve the dispute with
14
15 the employee by using the police force to end the employee’s career with the university at the
16 trauma unit.
17 406. On May 30, 2012, just one day before the ill-planned provocation, HR
18 Supervisor Brent Seifer sent an e-mail to HR Executive Director Stephen Chilcott stating that
19 Plaintiff’s superior Charles Witcher understands that Jerry (Plaintiff) will report to his office
20 tomorrow at 8 am. As soon as Jerry (Plaintiff) arrived, Charles would be issuing the
21 investigatory leave letter and directing him to meet with me.
22 407. On May 31, 2012, Plaintiff arrived at 8:00 a.m. at the Department Head
23 Charles Witcher’s office, and Charles Witcher handed Plaintiff a letter and sent him to the HR
24
Building Tycon III for an interview with HR Supervisor Brent Seifert. Maybe if Plaintiff had read
25
Charles Witcher’s letter in his office and found out that the Defendant were placing Plaintiff again
26
on investigatory leave and not letting him return to work after 10 days suspension, Plaintiff would
27
probably not have appreciated such actions. If Plaintiff had known that Defendant had maliciously
28

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1 attacked Plaintiff with a new phony investigation and that Plaintiff would be handed another
2 investigatory leave letter which could have been sent by e-mail or fax to Plaintiff, Plaintiff would
3 not even have bothered to go to UC Davis Medical Center on May 31, 2012. However, the
4 Defendant’ luring of Plaintiff to the workplace on May 31, 2012, was motivated by different goals
5
and reasons and involved deliberate premeditation not inform Plaintiff about the new investigatory
6
leave.
7
May 2012-I felt again like a Hunted Jew during the Holocaust.”
8
10
408. Plaintiff did not read the letter in Charles’ office and went straight to the
11
Human Resources Tycon Building for the meeting with Brent Seifert. HR Supervisor Brent Seifert
12
looked at Plaintiff upon his arrival like he wanted to ask Plaintiff what Plaintiff was doing in the
13
HR building meeting. At the end of the meeting—which was about phony, new, unfounded, made-
14
15 up, and out-of-the-blue accusations against Plaintiff and life in Romania, of which Brent Seifer
16 did not even know where it was located, Plaintiff asked Brent Seifert, “What’s next?” In response,
17 Brent Seifert said, “Didn’t you read the letter Witcher gave you? You are on investigatory leave
18 for the next two weeks.”
19 409. Plaintiff looked at the letter he received from Witcher, said ok, then left the
20 HR Building and Plaintiff went home. Plaintiff did not like the investigatory leave and Plaintiff
21 expressed his feelings thereafter in a letter entitled “I feel again like a Hunted Jew during the
22 Holocaust.” This is how the HR “Death Squad’s” plot to send Plaintiff the UC Davis Medical
23 Center # 11 failed.
24
410. Plaintiff on May 31, 2012, knew that something was wrong but Plaintiff
25
did not know any details about the malicious plan of the UC Davis Death Squad, “Kill Waszczuk,”
26
nor the unsuccessful provocation, until Plaintiff received relevant documents under the Public
27
Record Act Provision of November 2011. The documents are very clear as to what Defendant had
28

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1 planned for Plaintiff on May 31, 2012, the day after Plaintiff’s 61st birthday.
2
3 JUNE 2012
4 June 1,2012- Hugh Parker’s E-Mail to the Members of the ” UC Davis Death Squad”
5
6
411. On June 1, 2012, one day after falling ill and the maliciously crafted
7
provocation by the assembled UC Davis Death Squad, the coordinator of the provocation, HR
8
Workers Compensation Manager Hugh Parker, sent e-mail message to the other members of the
9
assembled UC Davis Death Squad members stating that
10
“Mr. Waszczuk (Plaintiff) had returned to work yesterday from his
11
suspension and was placed back on investigatory leave the same day. At
12
issue are writings sent by Mr. Waszczuk (Plaintiff) while on leave. Mr.
13
Waszczuk (Plaintiff) did not display any anger when told he was being
14
15 placed on investigatory leave.
16 412.. The Hugh Parker e-mail statement read: “At issue are writings sent by Mr.
17 Waszczuk (Plaintiff) while on leave. Mr. Waszczuk (Plaintiff) did not display any anger when
18 told he was being place on investigatory leave.” This translates to the following: that Plaintiff,
19 after almost one year of absence due to the Defendant’ psychological terror aimed at Plaintiff,
20 including threatening Plaintiff’s employment and livelihood by means of multiple investigatory
21 leave letters, which Plaintiff received from the Defendant as ill-planned provocations, should be
22 triggered to become angry and violent so that the UC Davis renegade Police Lt James Barbour,
23 bribed by means of a $35,000 wage increase by UC Davis Medical Center Trauma Unit # 11,
24
will do the job to eliminate Plaintiff from the UC Davis Medical Center landscape forever.
25
Apparently, UC Davis assembled Death Squad members underestimated Plaintiff and mistook
26
Plaintiff for somebody whose employment they had ended with UC Davis in this way.
27
28

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1 413. Plaintiff believes that similar provocation to end Plaintiff’s employment was
2 planned under the supervision and coordination of Hugh Parker on September 23, 2011, and that
3 this failed as well. According to Public Record Act documents received by Plaintiff, the report
4 crafted by Danesha Nichols to end Plaintiff’s employment on September 23, 2011, was
5
destroyed by the Defendant but Plaintiff believes that the report was not destroyed because
6
Danesha Nichols provided a copy of the report to Hugh Parker and the report should exist on the
7
Defendant’ servers if it was generated and saved and transmitted anywhere by means of
8
electronic mail.
9
414. Plaintiff looked at the assembled UC Davis Death Squad members’
10
names to identify who they are. The names of David Levine, Debra Schmidt, Marjorie Trogodon
11
Shock, Neil Speth, Carol Kirshnit, Karen Kouretas, Cindy Oropeza, Glynis Foulk, James
12
Barbour, and Travis Lindsay were all displayed on Hugh Parker’s e-mail message sent by Parker
13
on June 1, 2011. UC Davis Health System Executive Director Stephen Chilcott did not appear
14
15 among the eleven names of the assembled UC Davis Death Squad, but Stephen Chilcott’s name
16 appeared in the email dated May 30, 2012, which was sent by HR Supervisor Brent Seifert to
17 Stephen Chilcott in preparation for the ill-minded provocation and Plaintiff’s execution by UC
18 Davis Police.
19 June 1, 2012-The Members of the ” UC Davis Death Squad”

20
21 415. STEPHEN CHILCOTT J.D. – SBN # 1969905 Executive Director of

22 the UC Davis Health System Seventeen Human Resources Department and Services since
23 July 1, 2010, Superior of: Hugh Parker, Debra Schmidt, Marjorie Trogodon Shock, Neil Speth,
24
Carol Kirshnit, Cindy Oropeza, Brent Seifert, and Travis Lindsey.
25
416. Consequently, Stephen Chilcott, as the Executive Director of UC Davis
26
Health System (UCDHS), who was in charge of the Human Resources seventeen departments
27
and services, is responsible for the conspiracy, along with the other listed individuals, to cover up
28

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1 committed past unlawful activities committed by UCDHS directors and managers. He also
2 deprived Plaintiff of his employment with the University of California in the following manner:
3 417. HR Executive Director Stephen Chilcott, in January 2009, solicited
4 Plaintiff to sign a Settlement-Agreement with the Regents of the University of California, which
5
provided Plaintiff’s indefinite employment with the University of California as an Associate
6
Development Engineer. Two years later, Stephen Chilcott turned around and violated the
7
settlement-agreement and dismissed Plaintiff without valid cause and in violation of every
8
possible University policy that applies to employee-employer relations, not to mention Plaintiff’s
9
age and health condition.
10
418. HR. Executive Director Stephen Chilcott kept Plaintiff like a slave for
11
more than one year on investigatory administrative paid and unpaid leave, in violation of UC
12
Davis Policy PPSM 63 and any common sense and logic. This was approved by Stephen Chilcott
13
in an attempt to psychologically terrorize Plaintiff to force Plaintiff to quit the job that was
14
15 granted to him by the 2009 Settlement-Agreement signed with the UC Regents, which HR
16 Director Stephen Chilcott grossly solicited and supervised then violated and disregarded.
17 419. Stephen Chilcott, as the Executive Director, a licensed Attorney at Law,
18 and the Locally Designated Official (LDO), with full knowledge of wrongdoing, conspired in a
19 premeditated fashion with other Defendant and UC Davis Chief Compliance Officer Wendi
20 Delmendo to cover the others’ crimes and gross misconduct, deliberate interference, and
21 retaliation against Plaintiff for reporting management misconduct and violation of state and
22 federal law and established University of California Policies and Procedures.
23 420. HR Executive Director Stephen Chilcott, with malice and disregard for
24
state and federal law, conspired and dedicated himself to ending Plaintiff’s employment, doing
25
whatever it would take, and conspired with others, known and unknown, to kill Plaintiff or end
26
Plaintiff’s employment on May 31, 2012, in UC Davis Trauma Unit # 11, thus violating not only
27
Plaintiff’s civil rights but also, despicably, Plaintiff’s human rights to work and live.
28

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1 421. BRENT SEIFERT J.D. –SBN #249305, UC Davis Health System HR
2 Labor Relation Supervisor from April 2011 to March 2013, Stephen Chilcott’s subordinate in
3 2011–2012, likened attorney by the California State Bar.
4 422. Brent Seifert, as Employee and Labor Relations Supervisor for the
5
University of California at Davis Health System (“UCDHS”) from April 2011 to March 2013
6
and a labor law attorney with a J.D. degree, should know how “Personnel Policies for Staff
7
Members (PPSM) 62. Corrective Action — Professional and Support Staff” works instead
8
of participating in hunting down the 60-year-old Plaintiff like an animal and threatening
9
Plaintiff like a subhuman, thereby conspiring in a joint venture with his superior HR
10
Executive Director Stephen Chilcott and others, known and unknown, to kill Plaintiff or
11
end Plaintiff’s employment on May 31, 2012, in UC Davis Trauma Unit # 11, thus violating not
12
only Plaintiff’s civil rights but also, despicably, Plaintiff’s human rights to work and live.
13
423. CINDI OROPEZA- Human Resources Manager for Affirmative
14
15 Action/EEOC Real Title: Manager Benefits, EEO, Resident/Fellow Program HR Administrator,
16 Title IX Officer — Sexual Harassment, Mediation Services, ASAP, Early
17 Resolution/Inclusion in UC Davis Health System, HR Executive Stephen Chilcott’s
18 subordinate.
19 424. As early as 2006, Cindi Oropeza (hereinafter Oropeza), together with

20 Associate Executive Director Shelton Duruisseau, Ph.D., and Executive Director and
21 Defendant Mike Boyd and Pathology Department Manager Bettye Andreos, was a Divisional
22 Representative of the University of California, Davis Health System’s Equal Opportunity
23 Committee and held the position of chair of this Committee.
24
425. As the chair of this Equal Opportunity Committee, Oropeza was
25
responsible, together with Associate Executive Director Shelton Duruisseau, Ph.D., and
26
Executive Director Mike Boyd and Director Taylor, for assigning the “witch hunter” Bettye
27
Andreos, who was a member of this committee. The despicable massive witch hunt against
28

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1 Plaintiff and Plaintiff’s coworker William Buckans in 2006/2007, which intended to destroy
2 Plaintiff’s and Buckans’s livelihood, was retaliation for Buckan’s reporting on the unlawful
3 machine oil discharge from the Central Plant to the Sacramento or American River for seven
4 years via a city storm drain. The three above-mentioned directors were responsible for this
5
crime, as well as a few other criminally minded and corrupted individuals.
6
426. In 2011, Cindi Oropeza was in charge of the Mistreatment Office and UC
7
Davis Mistreatment Policy. Plaintiff filed a complaint on August 30, 2011, and a Mistreatment
8
Report against Defendant Patrick Putney and Defendant Danesha Nichols. Then, instead of
9
independently reviewing Plaintiff complaint, Oropeza conspired with HR Executive Director
10
Stephen Chilcott, thereby eliminating the Mistreatment Office and the Mistreatment Policy,
11
making them null and void. Oropeza gave Plaintiff’s complaint to HR attorney Danesha Nichols
12
for review, knowing that Nichols had already fabricated a report with a false accusations against
13
Plaintiff as a cause for Plaintiff’s termination, which was scheduled for September 23, 2011, of
14
15 which information was leaked out regarding the attempt to terminate Plaintiff, and Plaintiff did
16 not report to the UCDMC HR Building on this day. The Danesha Nichols Report for termination
17 was destroyed according to UC Davis Public Record Act office personnel.
18 427.. In February 2012, Oropeza called Plaintiff residence to arrange a meeting
19 with HR Labor Relation Manager Mike Garcia for informal conflict resolution. Plaintiff, in good
20 faith, held the meeting with Garcia and presented his proposition to resolve the conflict. Instead
21 of a counter offer or proposition to resolve, Plaintiff was suspended in May 2012 for 10 days
22 without pay, his two coworkers to whom Plaintiff provided representation came under vicious
23 attack, Garcia was replaced by a new HR Labor Relation Manager, and Garcia’s assistant Jill
24
Vandeviver was fired. Oropeza’s name is listed in a group of UC Davis employees who were
25
members of a specially assembled team nicknamed in the documents by Plaintiff “The UC Davis
26
Death Squad.”
27
428. On May 31, 2012, Plaintiff became the subject of an ill-crafted but
28

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1 unsuccessful provocation to kill Plaintiff by UC Davis Lt. James Barbour, who was bribed by
2 means of a $35,000 wage increase to end Plaintiff’s employment at the UC Davis Trauma Unit
3 No. 11.
4 429. The May 31, 2012, provocation to kill Plaintiff did not work as
5
anticipated; Oropeza then volunteered to craft, together with defendant Brent Seifert, a report
6
that defamed Plaintiff with false allegations in order to terminate Plaintiff on September 20,
7
2012. It was one year after Danesha Nichols had fabricated her report for Plaintiff’s termination
8
scheduled for September 23, 2011. Both reports are in gross violation of the 2009 Settlement
9
–Agreement signed by Plaintiff with Defendant.
10
430. Cindy Oropeza willfully participated in the plot to physically harm or
11
kill Plaintiff with full knowledge of the consequences of what she was doing, thus violating
12
not only Plaintiff’s civil rights but also despicably violating Plaintiff’s human rights to
13
work and live.
14
15 431. NEIL SPETH, DO—Medical Director of the UCDMC HR Employee
16 Health Services, HR Executive Director Stephen Chilcott’s subordinate.
17 Plaintiff met Neil Speth in 2005 through the course of his employment at the UCDMC Central
18 Plant. Dr. Neil Speth almost killed Plaintiff in 2005 by forcing Plaintiff to take a spirometer test
19 against Plaintiff’s will. As a result of Dr. Speth’s irresponsible actions, Plaintiff landed
20 unconscious in the UCDMC ER. Plaintiff informed Dr. Speth at the relevant time that because of
21 Plaintiff’s medical condition, Plaintiff could not take a spirometer test. Plaintiff intended to take
22 legal action against Dr. Speth, but a few months later, Plaintiff had open-heart surgery and dropped
23 the idea to take Dr. Speth to court.
24
432. Plaintiff is not sure what kind of assignment Hugh Parker, the coordinator
25
of the HR Death Squad action against Plaintiff, gave to Dr. Speth for May 31, 2012, but it is
26
apparent that Dr. Speth had an assignment to ensure that Plaintiff stop breathing in the Trauma
27
Unit after the Lt. James Barbour’s response to UC Davis Death Squad Coordinator Hugh Parker’s
28

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1 call on May 31, 2012.
2 433. GLYNIS FOULK—Emergency Preparedness Coordinator at UC Davis
3 Medical Center Glynis Foulk’s position title speaks for itself. The HR Death Squad assignment
4 for Glynis Foulk was probably to block the route to the trauma unit if he received a sign
5
from the Death Squad Coordinator Hugh Parker that Plaintiff was still breathing after Lt.
6
James Barbour’s response to Hugh Parker’s call on May 31, 2012.
7
434. DAVID LEVINE—UC Davis Health System Counsel.
8
Waszczuk never met this individual. However, the presence of the UCDMC Counsel in the “HR
9
Death Squad” war game is an undoubted indication that the plan to “disable” Plaintiff on May
10
31, 2012, was precise, covering every possible angle, including the legal angle.
11
12
435. CAROL KIRSHNIT, Ph.D, and MARJORE TROGODON SHOCK,
13
LCSW—Members of the UC DAVIS MEDICAL CENETR HR Academic and Staff Assistance
14
15 Program.
16 436. Carol Kirshnit is a licensed clinical psychologist and the coordinator of the
17 Academic and Staff Assistance Program at UC Davis Health System, and Marjorie Trogodon
18 Shock is a licensed clinical social worker with over 20 years of clinical experience.
19 Plaintiff believes that Carol Kirshnit, Ph.D, was the person who, as a doctor of psychology,
20 professionally advised her Superior HR Executive Director Stephen Chilcott and the UC
21 Davis Death Squad coordinator Hugh Parker as to whether Plaintiff was properly primed
22 and aroused to be provoked and killed on May 31, 2012, and whether Plaintiff’s
23 employment would end in the UC Davis Medical Center Trauma Unit .
24
437. Marjorie Trogodon Shock was the person who, on May 30, 2012,
25
together with the Death Squad Coordinator, removed Plaintiff from the stress management class.
26
Apparently, Shock was perfectly aware and informed about the ill-crafted provocation of May
27
31, 2012, to kill Plaintiff. Plaintiff believes that her participation in the plot was to comfort
28

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1 and consult staff after Plaintiff’s death or his being deadly harmed by UC Davis Police Lt
2 James Barbour, who was assigned to the provocation plot
3 438. HUGH PARKER—UC Davis Health Systems Manager, Workers’
4 Compensation, Ergonomics, Disability Management. HR Executive Director Stephen Chilcott’s
5
direct subordinate.
6
439. Plaintiff knew Hugh Parker since 2000 and met Hugh Parker two times
7
when Hugh Parker held a Consultant position in HR Labor Relations. Plaintiff never expected
8
that Hugh Parker, as HR Workers Compensation Manager, would become a Trojan Horse in
9
10 Plaintiff’s employment termination and that Parker would become a coordinator of the UC Davis
11 Death Squad and of the maliciously crafted provocation to kill Plaintiff on May 31, 2012, or end
12 Plaintiff’s employment at the UC Davis Medical Center. Plaintiff hopes that Hugh Parker
13 sooner or later, together with the co-conspirators, will get what he deserves according to
14 state and federal law.

15
440. TRAVIS LINDSEY licensed attorney at law—The New UCDMC HR
16
Labor Relations Manager who replaced Mike Garcia on May 1st 2012. Direct subordinate of HR
17
Executive Director Stephen Chilcott.
18
441. Travis Lindsey was the most active and notorious member of the
19
20 assembled UC Davis Death Squad. In May 2012 and thereafter, Lindsey was looking for any
21 reason she could use to terminate Plaintiff’s employment. Plaintiff looked at Lindsey’s job
22 history and credentials on the Web and it appears that Lindsey never advanced in his attorney
23 legal career beyond the position of associate attorney in four different law firms from January
24 2003 to May 2012. The working record also shows that Lindsey never worked in a Human
25 Resources department at any private enterprise or public employment, did not have any
26 supervisory or managerial experience, and had not directly handled any labor issues prior to
27 being hired by UC Davis Medical Center in 2012.
28

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1
2 442. LT. JAMES BARBOUR—UC DAVIS POLICE DEPARTMENT

3 Lt. James Barbour in May 2012 was assigned by the new UC Davis Police Chief Matt
4 Carmichael to kill or harm Plaintiff with a deadly weapon on May 31, 2012, in a maliciously
5
crafted unsuccessful provocation in exchange for a $35,000 wage increase. Multiple email
6
correspondences between the coordinator of the assembled UC Death Squad Hugh Parker shows
7
the Lt.’s Barbour dedication to attack Plaintiff by any means after the unsuccessful
8
provocation on May 31, 2012.
9
443.. KAREN KOUERTAS—R.N., M.S.N. Nurse Manager for UC Davis
10
Medical Center Trauma Nursing Unit (TNU) # 11
11
The Davis 11 Trauma Nursing Unit (TNU) is a 36-bed acute care
12 specialty and telemetry unit that primarily provides inpatient care and
treatment for patients who have sustained blunt or penetrating injury, as
13 well as those who may require surgical intervention. This includes care of
patients with suspected or confirmed intra-abdominal injuries, complex
14 wound management, orthopedic fractures, head/neck/face injuries, brain
trauma, chest trauma, and pulmonary injury.
15
16 444. By reading the purpose of Trauma Nursing Unit # 11 at UC Davis Medical
17 Center, it creates an unbelievably chilling picture of what the “HR Death Squad Members,”
18 including Karen Kouertas, had in their sick minds in relation to the meticulously and maliciously
19 crafted provocation of May 31, 2012, to eliminate Plaintiff from UC Davis Medical Center
20 landscape.
21 445. In July 2013, Plaintiff made an attempt to find out through the State of
22 California Board of Registered Nurses the capacity of Karen Kouretas’s involvement in the
23
activity of the assembled UC Davis Death Squad.
24
446. It is very important for the Board of Registered Nursing to know that the
25
board is issuing licenses not only to nurses who work very hard to take care of sick and ill people
26
but also to nurses, like Karen Kouretas, who collaborate and associate themselves with a group
27
of people whose goals are to provoke, kill, and deliver their victims to her unit for unspecified
28

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1 treatments. This is my main concern: whether Karen Kouretas should be eligible to hold an RN
2 license for such activities.
3 June 6, 2012 –Plaintiff’s Paystub
4 447. On June 6, 2012, Plaintiff received his paystub with pay period ending
5
May 26, 2012, with only $182.00 because the May 11, 2012, unwarranted suspension without
6
pay for 10 working days.
7
448. On June 6, 2012, one week after the unsuccessful provocation to end
8
Plaintiff’s employment at the UC Davis Medical Center Trauma Unit # 11, the UC Davis
9
Medical Plant Operation and Maintenance Assistant Manager Dennis approached Plaintiff’s
10
coworker Kenny Diede in a threatening manner and requested that Kenny Diede stay as far away
11
as possible from Plaintiff. Plaintiff, in 2012, provided representation to Kenny Diede about his
12
complaint under UC Davis Policy PPSM 70. Thereafter, Dennis Curry sent a threatening and
13
intimidating e-mail to Plaintiff with cc to many UC administrators and management.
14
15 449. Dennis Curry in June 2012 became subject to an investigation by the UC
16 Davis Compliance Office due to borrowing from contractors who were working in UC Davis
17 Medical Center and not giving them the money back.
18 450. Dennis Curry was removed from the premises just two weeks before he
19 retired from the University and after 35 years of service.

20 June 12, 2012- Plaintiff Letter to the UC Davis Medical Center Compliance & Privacy
Investigator Gina Guillaume-Holleman
21
22
451. On June 12, 2012, Plaintiff sent a 24-page letter to the UC Davis Medical
23
Center Compliance & Privacy Investigator Gina Guillaume-Holleman. The letter was entitled:
24
“THE SUMMARY OF THE FEW UNRESOLVED ISSUES IN UC DAVIS
25
26 MEDICAL CENTER PO&M AND HUMAN RESOURCES
27 DEPARTMENTS; POSITIONS AND WAGES; DENNIS CURRY &
28 CONTRACTOR(S); UCDMC DIRECTORS & DORIN DANILUC; SHORT

Page 148 of 149
1 TERM DISABILITY BENEFIT FRAUD; THE DECEMEBER 2010 PAY
2 RAISE FOR CENTRAL PLANT OPERATORS.
3 PATRICK PUTNEY & RAM SAMI NAIDU IN LIGHT OF DANESHA
4 NICHOLS’S RULING ON CHILD PORN ISSUE IN THE HVAC SHOP. “
5
The Center Compliance & Privacy Investigator Gina Guillaume-Holleman was investigating
6
Dennis Curry relation with contractors working in the UC Davis Medical Center.
7
8
June13, 2012 – The Investigatory Leave Extension
9
452. On June 13, 2012, UC Davis Medical Center Plant Operation and
10
Maintenance Department Head Charles Witcher sent an email letter to Plaintiff stating that
11
Plaintiff’s investigatory leave was being extended from June 14, 2012, through June 27, 2012.
12
Furthermore, the e-mail stated that Plaintiff was thereby relieved from all work duties for the
13
duration of this investigation. This duration was intended to allow additional time to collect
14
15 relevant information and determine the facts surrounding e-mails that Plaintiff sent, which were
16 believed to contain discriminatory content. Plaintiff would remain on pay status during that time.
17 During this leave, Plaintiff would not be allowed to have access to the work place. Plaintiff
18 would remain available during business hours should it be required that Plaintiff participate
19 in this investigation. There was no word in Witcher’s e-mail that Plaintiff violated the 2009
20 Settlement-Agreement signed by Plaintiff with the UC Regents.
21 June 14, 2012-The State of California’s Insurance Commissioner Office Decision
22
23 453. On June 14, 2012, two weeks after the unsuccessful provocation to end
24
Plaintiff’s employment at the UC Davis Medical Center Trauma Unit # 11, Plaintiff received a
25
decision from the State of California’s Insurance Commissioner Office in regard to the complaint
26
Plaintiff filed in November 2011 against the Liberty Assurance Company of Boston, which, in
27
conspiracy with the Defendant, denied Plaintiff Short Term Disability Benefits. The decision,
28

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1 issued after an eight-month investigation, stated that: “After reviewing the information provided,
2 we conclude that we are unable to assist you further with this matter. The issues involved with
3 your complaint indicate that there is a difference of opinion between you and the insurance
4 company that this Department, as outlined in California Insurance Code Section 12921.4(a), does
5
not have the authority to decide.” How convenient.
6
June 21, 2012 – Plaintiff’s Letter to UC Davis Police Captain Joyce Souza
7
454. On June 21, 2012, Plaintiff sent a summary and request for information
8
letter to UC Davis Police Captain Joyce Souza to whom Plaintiff, since October 2011, was
9
providing information about the ongoing situation at UC Davis Medical Center. Plaintiff sent a
10
letter to Captain Souza due to the unusual greeting Plaintiff received from UC Davis Police Lt.
11
James Barbour three weeks after Plaintiff was almost killed due to the ill-planned provocation.
12
As in October 2011, Plaintiff asked Captain Souza for information about any complaint that had
13
been filed against Plaintiff by anybody with the UC Davis Police Department (UC Davis
14
15 Campus or UC Davis Medical Center) from the period of November 1, 2011, to the present time.
16 455. Furthermore, in his letter to Captain Joyce Souza, Plaintiff stated that
17 based on multiple correspondences that Plaintiff forwarded to Captain Souza’s office, Captain
18 Souza was most likely aware that Plaintiff had not been working since August 2, 2011. Plaintiff
19 spent eight months of this period on administrative leave and investigatory leave plus 10 days of
20 suspension without pay as a retaliation. Plaintiff elaborated in his letter to Captain Souza that it is
21 not difficult for anyone to figure out that the eight months on administrative and investigatory
22 leave indicate that something went terribly wrong or is going to go terribly wrong for a long time
23 in the UC Davis Medical Center Plant Operation and Maintenance Department and Human
24
Resources Department.
25
The UC Davis Pepper Spray Incident investigation took only five months to issue the final
26
report. (From November 2011 to March 2012) and Plaintiff’s case has been going since
27
March 13, 2011.
28

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1 456. Plaintiff also asked Captain Souza whether she could give Plaintiff, under
2 the provision of the Government Code 6254(f), a copy of the report about UC Davis Medical
3 Center PO&M Management’s meeting with UC Davis Police on May 7, 2012. If this was
4 possible, Plaintiff would have been glad to send to Captain Souza’s office the signed Report
5
Request Form added by Plaintiff. As Plaintiff recalls, shortly after, Plaintiff received an e-mail
6
from Captain Souza informing Plaintiff that Captain Souza had retired from the University of
7
California and would no longer be responding to my requests.
8
June 22, 2012 – The HR Consultant Gina Harwood’s Announcement
9
457. On June 22, 2012, one of the most deceptive and dishonest UC Davis
10
Medical Center HR Consultant’s, Gina Harwood, announced with triumph by letter that the UC
11
Davis Medical Center HR Labor Relations Manager Humberto Garcia and attorney and HR
12
Consultant Jill Noel Vandeviver were no longer working for HR Labor Relations and that she
13
was taking over Plaintiff’s coworkers Kenny Diede and William Buckans’ complaints, which
14
15 were filed under Policy PPSM 70 and to whom Plaintiff was providing representation. Gina
16 Harwood was removed by Humberto Garcia in January or February 2012 to handle Plaintiff and
17 his coworkers’ complaints, which were assigned to HR consultant Jill Noel Vanderviver.
18 458. On June 24, 2012, Plaintiff responded to Gina Harwood’s announcement
19 about Humberto Garcia and Jill Noel Vandeviver’s departure from UC Davis Medical Center with
20 a 10-page letter.
21 June 27, 2012 – The Investigatory Leave Extension
22 459. On June 27, 2012, Plaintiff called UC Davis Medical Center Plant
23 Operation Manager Charles Witcher and asked him about Plaintiff’s status because the last
24
investigatory leave letter had expired on June 27, 2012. Thereafter, Charles Witcher sent Plaintiff
25
another routine two-weeks extension, stating that the letter confirmed that Plaintiff’s
26
investigatory leave was being extended from June 28, 2012, through July 11, 2012. Plaintiff was
27
hereby relieved from all work duties for the duration of this investigation. This would allow
28

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1 additional time to determine the facts surrounding e-mails Plaintiff was believed to have sent
2 containing discriminatory content and to collect relevant information. Plaintiff would remain on
3 pay status during this time.
4 During this leave, Plaintiff would not be allowed to have access to the work place. Plaintiff was
5
to remain available during business hours should they require his participation in the
6
investigation. This was exactly the same letter as the one Plaintiff had received on June 13, 2012.
7
June 27, 2012 – The Palintiff’s Response to The Investigatory Leave Extension
8
460. Not to let Charles Witcher think that Plaintiff liked staying at home or
9
10 enjoyed being UC Davis Medical Center management’s prisoner, sentenced to one year of home
11 arrest for unknown causes, Plaintiff responded to Witcher’s investigatory extension letter as
12 follows:
13 “Do you have any clue who is being investigated and why this investigation is
14 causing me this Investigatory Leave for such a long time?
15
Did you receive any threats against me and are you keeping me out of the
16
Medical Center for my safety or is it for a different reason?
17
I am just curious because it is weird and makes me very nervous that I am still
18
on the UC Payroll for so long and I can’t work. I am getting all kinds of
19
information and it makes me wonder what is going on behind the scenes of
20
your Investigatory Leave. I am not sure if all the information I am receiving is
21
true but, almost always, rumors and gossip contain 5% of the truth.
22
Today, I received information about the Director Taylor and Mike Pansius’
23
24
retirement. A few weeks ago, I heard about Dennis Curry’s suspension or
25 administrative leave just before his retirement. Last Friday, I received official
26 information about Mike Garcia and Jill Noel Vandeviver’s departure from the
27 HR Labor Relations Department.
28 Today, my Investigatory leave was forgotten. It was a very hard decision for

Page 152 of 153
1 me to call you about this investigatory leave, and I almost decided to drive to
2 work tomorrow, but I did not want to be approached by Dennis Curry or
3 UCDMC Lt. James Barbour after they sent me special email advise, not to
4 mention the possibility of meeting or being approached by or stalked by the
5
HVAC Shop chicken, ducks, and goats merchants manager. It is still blowing
6
my mind that this jerk is still there and is supervising people after what he has
7
done to me and after all the damages he has caused to the UCDMC working
8
environment. His behavior affected me and involved many other people in this
9
mess for no reason. Can’t you make the wise decision to move this guy from
10
the HVAC Shop to a different place and give a people a break.
11
I am also hearing all the time that people from the HVAC shop love to have
12
Steve McGrath or Corey from the PM shop as their supervisors. Don’t think
13
any of them are my friends. I know Steve quite well but I don’t know Corey
14
15 and I only built my positive opinion of Corey from the HVAC and PM shops
16 people, who I know and have good relations with.
17 Do you know who is in charge of the HR Labor Relations after Mike Garcia
18 left? I thought a few my months back that Jill Noel Vandeviver was going to
19 replace Mike with her very aggressive introduction to the ongoing matters
20 related to myself, Kenny Diede, and William Buckans, as well as associated
21 PO&M personnel. It is my understanding that an Investigatory Leave Letter
22 has to be approved by HR Labor Relation Chief.
23 Also, there is an issue with my employee evaluation for 2010/2011. I am still a
24
UC employee and would appreciate it if you provide me with the evaluation
25
for 2010/2011. At least for the period I was in the shop and was working until
26
August 2, 2011. The time for 2011/2012 evaluations is approaching, and I am
27
not sure how I should be evaluated when I am not working and due to a
28

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1 pending dispute. Please advise me, or should I direct this problem to the HR
2 Chiefs. Charles Witcher responded with another two Investigatory Leave
3 Extension and Notice of Termination of Plaintiff’s employment.
4
July 2012
5
6
July 3, 2012—HR Consultant Gina Harwood’s Letter Entitled
7 “Jerry Waszezuk Timeline/Summary”
8
9
461. On July 3, 2012, notoriously deceptive UC Davis Medical Center HR
10
Consultant Gina Harwood sent an e-mail to her supervisor, Brent Seifert, with the attached letter
11
(“Jerry Waszczuk Timeline /Summary”) described by Gina Harwood as “thrown together really
12
quick.” Besides, the mentioned summary was full of slanderous lies and unfounded, made-up
13
accusations about Plaintiff, which she began generating in 2011 and is repeating with demeaning
14
lies about Plaintiff in this summary. Gina Harwood also complained to Brent Seifert about
15
dismissed in June the HR Labor Relation Consultant, Jill Noel Vandrviver . HR consultant Jill
16
17
Noel Vandrviver was dismissed together with the HR Labor Relation Manger, Humberto Garcia
18 in June 2012. Gina Harwood was removed in January or February 2012, from handling Plaintiff
19 and Plaintiff’s coworker’s complaints against Plant Operation Maintenance Department
20 management misconduct, retaliation and harassment. It was most likely that Gina Harwood
21 contributed much of her effort to make Humberto Garcia and Jill Noel Vanedviver dismissed
22 from their jobs in retaliation for being removed from the assignment.
23 462. In her July, 2012, full-of-lies defacing-the-Plaintiff summary, Gina Harwood wrote:
24 Jerry Waszczuk Timeline/Summary
25 “Jaroslaw Waszczuk is an employee in the HVAC Shop as an Associate
26 Development Engineer, he has been employed for 13 years. He is responsible
27
for monitoring the Metasys system which monitors alarms throughout the
28

Page 154 of 155
1 health system. Ms. Waszczuk has the responsibility to act when an alarm goes
2 off in the system.
3 In April 2011, it was discovered that a refrigerator alarm had gone off several
4 times over an 11 day period. Mr. Waszczuk was approached about the missed
5
alarms and reacted inappropriately to management, it was reported he was
6
yelling and screaming at his supervisor. The Assistant Manager reported to the
7
workplace and removed Mr. Waszczuk from the workplace and calmed him
8
down. A similar incident of behavior from Mr. Waszczuk occurred in May
9
2011,
10
Mr. Waszczuk sent an email to Charles Witcher regarding issues he was
11
having in the workplace. Mr. Witcher had a meeting with him to discuss the
12
allegations. The department met with Principal Labor Relations Consultant
13
Gina Harwood regarding his behavior and the missed alarm. Ms. Harwood also
14
15 received a complaint letter from Mr. Waszczuk with. Multiple allegations, this
16 all took place at the end of May beginning of June. Mr. Waszczuk stated that
17 Mr. Witcher was handling his complaint. Ms. Harwood asked to meet with Mr.
18 Waszczuk as a follow up to his complaint, meeting took place the second week
19 of July. Prior to the meeting, Patrick Putney filed a violence in the workplace
20 incident related to the April and May incidents. Ms. Waszczuk made several
21 allegations in his email and during the meeting related to misuse of University
22 resources by his supervisors, Ms. Harwood sent the information to Wendi
23 Delmendo for review and Danesha Nichols was appointed to investigate the
24
allegations from Mr. Waszczuk and the Violence in the Workplace complaints.
25
During the investigation, Mr. Waszczuk was placed on investigatory leave. He
26
began a letter/email writing campaign to multiple UC employees. The email
27
communications were inflammatory and contained discriminatory comments
28

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1 as well as personal attacks on various staff in the department and HR. Mr.
2 Waszczuk sent his emails to UC employees at various locations and continued
3 to send them after being directed to communicate directly with the
4 department. During the investigatory process, he initially refused to meet with
5
the investigator. He eventually agreed to a meeting and participated in the
6
investigatory interview, The investigator issue 3 separate reports based on her
7
investigation. The report regarding Mr. Waszczuk substantiated that he
8
violated policy 1616 — Violence and Hate Incidents in the Workplace, 380-
9
15 Staff Complaints of Discrimination. Mr. Waszczuk was suspended for 10
10
days without pay. He has filed a formal complaint regarding the suspension
11
was denied at step 1. Step 2 appeal due July 16, 2012.
12
Mr. Waszczuk has had sporadic periods of medical leave throughout the
13
last year. He was provided information on workers compensation and
14
15 denied to file. He applied for Liberty Mutual and his claim was denied,
16 Throughout the entire process, he has continued to send inflammatory emails
17 regarding staff members to members of the UC community and outside parties.
18 He was placed on investigatory leave immediately following his suspension for
19 allegations that he continued to send emails with discriminatory language. He

20 currently has 2 formal PPSM complaints, one for his suspension and one for
21 his most recent investigatory leave. HR has received several complaints from
22 staff stating they do not wish to receive his emails, His supervisors have both
23 filed stress claims identifying his behavior as the cause. “
24
25
463. The Summary itself as no so much interesting but interesting is why HR
26
Labor Relation Supervisor Brent Seifert requested the summary on Plaintiff from Gina Harwood.
27
Brent Seifert listed in Hugh Parker’s e-mail chat dated June 1, 2012 about May 31, 2012 ill crafted
28

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1 but unsuccessful provocation which should end Plaintiff employment in UC Davis Medical Center
2 Trauma Unit # 11.
3 464. In May 2012 Brent Seifert also together with HR Equal Opportunity
4 Employment Manager Cindy Oropeza to fabricate cause for Plaintiff termination if planned and
5
ill crafted provocation to kill Plaintiff will fail on May 31, 2012.
6
465. It is appear from Gina Harwood’s summary that was some urgency to deal
7
with Plaintiff after Plaintiff sent letters on June On June 12, 2012 Plaintiff sent 24 pages letter to
8
the UC Davis Medical Center Compliance & Privacy Investigator Gina Guillaume-Holleman
9
2012 with new information about the UC Davis Medical Center Management misconduct, the
10
June 21, 2012 letter UC Davis Police Captain Souza and requested information about UC Davis
11
Management Plant Operation and Maintenance Department managers and supervisors gathering
12
in UC Davis Medical Center Police Station on May 7, 2012 . Also in the letter to Captain Souza
13
Plaintiff discussed his status of being kept on investigatory and administrative leave for one year
14
15 without knowing why and in contrary and in light of the widely publicized in media November
16 18 , 2011 pepper spray attack ordered by UC Davis Chancellor Linda Katehi and investigation of
17 this incident which concluded within five months . Plaintiff did not understand for what crime his
18 being kept hostage for one year on investigatory leave and why he is being investigated.
19 466. Beside the letters to Captain Souza and Compliance Investigator Gina
20 Gauilaumme –Holleman Plaitiff on June 27, 2012 sent letter to his Department Head Charles
21 Witcher and demanded answer why Plaintiff is kept on investigatory leave and why he is not
22 being permitted to go back to work and do his duty . Plaintiff never received response from Charles
23 Witcher to his inquiry.
24
July 3, 2012 – The Plaintiff’s , Kenny Diede ‘s and William Buckan’s Complaints under UC
25 Davis Policy Complaint Resolution Policy PPMS 70
26 467. On July 3, 2012 Plaintiff and his two coworkers Kenny Diede and William
27 Buckans received from HR Consultant Gina Harwood Decisions in Step I Complaints Plaintiff
28

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1 filed on his and two mentioned coworkers behalf in June 2012.
2 468. In May 2012 two Plaintiff’s coworkers Kenneth Diede and William
3 Buckans were attacked by their supervisors and served with despicable and maliciously crafted
4 letters of expectations. The letters of expectations were served to them not because they did
5
something wrong but to humiliate and harass them because Plaintiff was providing to them
6
representation in their complaints against management misconduct harassment and retaliation.
7
469. The Department Head Charles Witcher who was responsible this reckless
8
against Kenny Diede and William Buckans and routinely with help of HR Consultant Gina
9
Harwood further humiliated Kenny Diede and William Buckans and denied their Step I
10
Complaints
11
470. Plaintiff’s complaint filed in June 2012 was against Defendant for deny
12
Plaintiff right to attend open for every employee UC Davis Employee Appreciation Day (Picnic
13
type event with free food and music and other attraction) Also , complaint was against
14
15 Defendant for serving Plaintiff every two weeks for almost one year letters of Investigatory
16 Leave and denying Plaintiff right to work It was done in violation of UC Davis Policy PPSM 63
17 and 2009 Settlement-Agreement Plaintif signed with the Defendant. .
18 322. The other Plaintiff complaint Step I under UC Davis Policy PPSM 70 was still pending
19 against Defendant for 10 days suspension without pay.

20 July 18, 2012- Mark Montoya’s Interview with Gina Gaullaume-Holleman from UC Davis
Medical Center Chief Compliance Office
21
22 471. On July 18, 2012, Investigator Gina Gaullaume-Holleman from the UC

23 Davis Medical Center (UCDMC) Chief Compliance Office interviewed one of my coworkers
24 from the HVAC shop. Mark Montoya
25 322.Mark Montoya, Plumber from the Plumbing /HVAC where Plaintiff was surprised that he was
26
called unexpectedly to be interviewed with Gina Guillaume-Holleman.
27
472. Mark Montoya was even more surprised when Gina Gaulliuaum -Hollmann
28

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1 showed him a Plaintiff ‘s photo and asked Mark Montoya whether Plaintiff was and is a threat
2 for him and without any hesitation she attempted to solicit it from Mark Montoya confirmation
3 signature on the affidavit which stated that Plaintiff is treat for him and dangerous individual.
4 Mark Motoya refused and left the Gina Gaulliuaume –Hollmann’ s Office
5
473. After Mark Montoya left Gina Gaulliuaume –Hollmann’ s Office than
6
immediately he told his coworker Kenny Diede about and disclosed the information. Mark
7
Montoya had no clue why he was picked –up as only person from HVAC shop for this Defendant’s
8
malicious and criminally minded attempt to frame Plaintiff.
9
474. Plaintiff has general idea why and by who Mark Montoya was singled out
10
for this Defendant conspiracy to frame Plaintiff after untuneful May 31, 2012 provocation to kill
11
Plaintiff by assembled UC Davis Death Squad. Kenny Diede called Plaintiff on same day and
12
disclosed Mark Montoya’s revelation to Plaintiff.
13
475. In July 2012 Plaintiff did get stress out so much about Mark Motoya’s
14
15 interview revelation and his disclosure about conspiracy to frame Plaintiff because in July 2012
16 Plaintiff did not know at that time anything about May 31, 2012 provocation to kill him or end
17 Plaintiff’s employment in the UCDMC Trauma Unit # 11 .
18 476. Plaintiff suspected that something was wrong but did have any evidence to
19 proof anything bedside that he was removed from stress management class on May 30, 2012 and
20 was served with Investigatory Leave letter on May 31, 2012 and was not permitted to work by
21 Defendant.
22 477. Few days later mark Montoya called Plaintiff and confirmed what Kenny
23 Diede told Plaintiff about his interview with Gina Gaulliuaume –Hollmann’on July 18, 2012.
24
325. On July 23, Plaintiff decided for the record to write few additional words to Gina
25
Gaulliuaume –Hollmann’as follow;
26
“Dear Ms. Guillame -Holleman:
27
For the record and in addition to my previous e-mail I would like to inform
28

Page 159 of 160
1 you that the person to whom you show my photo and asked him if am a threat
2 for him confirmed the fact. The interviewed person called me last Saturday and
3 told me about your " I am looking for Jerry Waszczuk Most Wanted Bandit by
4 the University of California"
5
The initial information I received was from the second hand. The interviewed
6
person also disclosed information to me that he had been questioned by Patrick
7
Putney just after meeting with you about the interview subject and what you
8
was asking him during the interview. Also, I have learned that you asked the
9
interviewed person whether anybody in HVAC shop is honest. I could answer
10
your question as follow: Beside the Patrick Putney and Dorin Daniliuc the
11
HVAC shop employees are honest people. However, I found out in Danesha
12
Nichol's Report that some of them were coerced by Putney, Curry and Daniluc
13
and they said some things which no makes sense or logic. I know what the
14
15 reason was behind for their statements but I don't care much it because I never
16 had any problem with any of my coworkers in the HVAC shop during my
17 employment from March 2007- to August 2, 2012 and will not have any
18 problem if I eventually comeback to work .
19 I will not make big deal about my" photo and your question “Apparently you
20 was instructed by somebody to find cause for my employment termination. I
21 like to mention that at first I got outraged about your interview with my
22 coworker but after the interviewed person called me about than I told my to
23 myself: . Why I have to stress myself for something I have no control over
24
until the whole case go to court. "
25
You as an employee of UCDMC Compliance office shall follow Canons of
26
Ethic during the interview. By showing my photo and trying makes me like
27
most wanted at large bandit is not going to help my employer in any way but
28

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1 for sure it will help me in the court proceeding . If anybody could be dangerous
2 in the HVAC shop than the person is Patrick Putney who according to
3 information I am receiving, he is acting lately very erratically and he snapping
4 and his hands are shaking like a wheel with bad alignment . This guy lost his
5
only support who was Dennis Curry . Dorin Daniluc is not in shop to help him.
6
Dorin is probably scare to be there by knowing Patrick, behavior and his
7
weapon arsenal he has in his compound on the country.
8
Attached is the print out of the Habanero Hot Restaurant in Lodi where
9
Patrick Putney and Dennis Curry have enjoyed free meals thanks to Tech - Mar
10
Contractor "hospitality and generosity" .
11
I think that such things should be the subject of your investigation instead
12
of looking whether 61 old Jerry Waszczuk is candidate for the Poster of
13
the "Most Wanted and Dangerous Bandits at Large"
14
15 I addition attached is the printout of the "AAPC Code Of Ethics" as an
16 reminder.
17 Jerry”
July 25, 2012 – HR Director Stephen Chilcott’s e-mail
18 to HR Labor Relation Manager Travis Lindsey
19
20 479. Apparently after Plaintiff send inquires to UC Davis Police Department,

21 Investigator Gina Gaullaume-Holleman, the UC Davis health System Executive Director
22 Stephen Chilcott was alerted and requested on July 25, 2012 from his subordinate, the new HR
23 Labor Relation Manger Travis Lindsey to provide him with a summary of the UC Davis
24 Medical Center Plant Operation and Maintenance Department matter as a rationale for
25
early assignment of defense counsel that they can provide to UC Davis Health System Chief
26
Counsel Anna Orlowski.
27
July 31, 2012 Step II Appeals , UC Davis Policy PPSM 70
28

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1 480. On July 31, 2012 Plaintiff filed Step II appeals with UC Davis Medical
2 Center HR Department on behalf on his two coworkers Kenny Diede and William Buckans who
3 were denied Step I complaints on July 3, 2012 by Department Head Charles Witcher and HR
4 Consultant Gina Harwood for their complaints against their supervisors which attacked the and
5
serve them with unwarranted letters of expectations.
6
AUGUST 2012
7
August 1, 2012- The Extension of Investigatory Leave
8
9
481. On August 1, 2012, Defendant sent Plaintiff another two-week extension of
10
the Investigatory Leave. This time the Plant Operation and Maintenance Manager Charles Witcher,
11
who routinely signed the investigatory leave letter, which was at this point close to the one-year
12
anniversary of the first investigatory leave letter that Witcher signed on September 1, 2011.
13
14
August 2, 2012 – The UC Davis Chief Compliance Officer Wendy Delmendo’s e-mail
15 to Kenney Diede
16 482. On August 2, 2012 the UC Davis Chief Compliance Officer Wendy
17 Delmendo sent an e-mail to the Plaintiff’s coworker Kenney Diede, attempting to drag Kenny
18 Diede into a deceptive and useless whistleblowing complaint, just as she had attempted to do
19 with Plaintiff in July 2011. Plaintiff was almost killed on May 31, 2012, due to Wendy
20 Delmendo’s effort and dedication to destroy the UC Davis employees life’s and livelihoods
21 instead of providing help to them .
22 483. In her August 2, 2012, email letter to Kenny Diede (whom Plaintiff was
23 successfully representing in his complaints against management misconduct under the UC Davis
24 Policy PPSM 70), Wendy Delmendo wrote:
25
“I recently learned that you have filed a grievance in which you allege you
26
have been subject to retaliation. I am writing to inform you that your allegation
27
of retaliation may also be eligible for review under the University’s
28

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1 Whistleblower Protection Policy. If you believe you were retaliated against
2 because you made a protected disclosure, you may file a complaint of
3 whistleblower retaliation by sending me a signed, sworn statement of your
4 complaint using the form available at (Web site).”
5
484. Kenny Diede was the person who had had the courage, in July 2011, to
6
report a twice-convicted child pornography felon to the federal court parole; this felon was often
7
a guest at the UC Davis Medical Center HVAC shop and was accessing the shop commuters.
8
The felon was prohibited by court order from touching any computer with access to the Internet
9
regardless of whether it was his home computer or an outside computer.
10
485. The UC Davis Chief Compliance Officer Wendy Delmendo was the
11
person who in July 2011 assigned HR investigator Danesha Nichols and ordered her to fabricate
12
a cause for Plaintiff’s employment termination and to cover up in her pseudo-reports the
13
unlawful child pornography felon activities taking place on the premises, as well as management
14
15 misconduct, harassment, retaliation, abuse of power, violation of state and federal law, and
16 Delmendo openly participating in Plaintiff’s employment termination in 2012 and almost getting
17 Plaintiff killed with her help.
18 486. As Kenny Diede’s representative, Plaintiff advised Kenny Diede to
19 decline Wendy Delmendo’s deceptive and misleading offer with the following words in
20 response:
21 Dear Ms. Delmendo:
22 I appreciate your concern. However, I am not sure what you are referring to in
23 your letter in regard to my complaints.
24
For your information, I filed two complaints against my manager Patrick
25
Putney’s vendetta and retaliation. (I believe that you are very familiar with this
26
person’s name). I am not only a victim of Patrick’s Putney behavior. My two
27
complaints against Patrick Putney are pending and problems probably would
28

Page 163 of 164
1 not exist if HR Department would be more persistent in dealing with this
2 vindictive and horribly terrifying behavior in the work place.
3 One complaint I filed is related to my 2010/2011 evaluation and has been
4 pending unresolved by the UCDMC HR for almost one year. The other
5
complaint is pending since June 2012 and is related to the Letter of
6
Expectation, which is based on ridiculous and unfounded accusations and
7
which I received in May 2012. Both complaints are in the Appeal II process
8
and being handled by Mrs. Gina Harwood from the HR Labor Relations
9
Department.
10
I am being represented in both complaints by my coworker Jerry Waszczuk.
11
I would like to thank you again for writing to me but I believe that an
12
independent arbitrator or court of law is a better way to deal with managers
13
such as Patrick Putney.
14
15 If you have any additional questions or concerns please contact my complaints
16 representative Jerry Waszczuk, who will be glad to answer any of your
17 questions.
18 His phone number is 209-663-2977.
19 E-Mail: ucdmclaborchat@comcast.net “
20 487. In addition to the UC Davis Chief Compliance Officer Title, on February 2, 2014,
21 Wendy Delmendo accrued the “Lead Discrimination Officer” title per order of the University of
22 California President Janet Napolitano after an enormous discrimination scandal on the University
23 of California, Los Angeles campus.
24
The Lead Discrimination Officer title fits Wendy Delmendo perfectly. She advanced herself in
25
her skill in how to discriminate and hurt employees while advising UC Davis administration
26
without leaving a trace of discrimination and harassment.
27
28

Page 164 of 165
1 August 9, 2012- The HR Consultant Gina Harwood’s Letter to Kenny Diede
2
3 488. After UC Davis Chief Compliance Officer Wendi Delmendo’s

4 unsuccessful attempt to drag Kenny Diede into her whistleblowing complaint trap, the HR
5
Consultant Gina Harwood sent a letter to Kenny Diede and informed him that this letter serves as
6
confirmation that the above Kenny Diede’s complaint had been filed under UC Davis Policy
7
PPSM 70 and will be placed in abeyance pending Mr. Waszczuk’s (Plaintiff’s) ability to
8
attend a Step 2 meeting as Kenny Diede’s representative. When Waszczuk (Plaintiff) was
9
free to serve as Kenny Diede’s representative at the meeting, Gina Harwood would remove the
10
complaint from abeyance and a meeting would be scheduled.
11
489. From Gina Harwood’s letter, Plaintiff learned that Defendant were in
12
violation of all rules, law, and the 2009 Settlement-Agreement by prohibiting Plaintiff from
13
not only working but also representing his coworkers in their complaints. The other
14
15 Plaintiff’s coworker William Buckans, to whom Plaintiff was providing representation, received
16 a similar letter from Gina Harwood.
17 August 9, 2012 – The Letter of Expectation served to HVAC Technician Dereck Cole .
18
490. Following the UC Davis Chief Compliance Officer Wendi Delmendo’s
19
invitation to her whistleblowing “Russian Roulette” game and Gina Harwood’s letter prohibiting
20
Plaintiff from working and representing his coworkers, Defendant attacked another coworker of
21
Plaintiff called Dereck Cole.
22
23 491. On August 9, 2012, Plaintiff’s coworker and HVAC Shop technician

24 Dereck Cole was attacked by means of a maliciously crafted Letter of Expectation that gave
25 Plaintiff goose bumps. The letter of expectation by UC Davis Policy PPSM 62 should not even
26 be considered disciplinary action and should be served to employees as a tool for performance
27 and behavior improvement.
28

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1 491. The letter of expectation was issued to Dereck Cole by HR and was signed
2 by Dereck Cole’s shop Manager Patrick Putney. It was closely akin to a Notice of Intent to
3 terminate his employment and was issued for the purpose of terrifying him and other employees
4 and silencing them.
5
492. Dereck Cole was attacked in a similar manner and style to the way Plaintiff
6
and two other coworkers were attacked by department management and Human Resources Labor
7
Relation staff.
8
493. Shortly after Dereck Cole was served with a malicious letter of expectation,
9
a “Does Not Meet Expectation” annual employee performance review was served to Dereck as a
10
clear message that he was being singled out for termination.
11
494. Dereck Cole was Plaintiff’s coworker who, in February 2011, had
12
disclosed to Plaintiff that the UC Davis Medical Center Central Plant Operator Todd
13
Goerlich, who had committed suicide on December 22, 2010, was harassed and bullied in the
14
15 work place prior to taking his own life. In March 2011, Plaintiff brought this information to the
16 Defendant’ attention.
17 494. Todd Goerlich, who replaced Plaintiff in April 2007, was Dereck Cole’s
18 best friend since high school and he left behind a one-year-old child.
19 495. Shortly after this, Dereck Cole was attacked and turned to Plaintiff for help.
20 Plaintiff agreed to represent him in his complaint under UC Davis Policy PPSM 70, regardless of
21 the fact that Plaintiff had little time and was very busy with his own defenses and those of his two
22 coworkers against harassment and the Defendant’ retaliation. Plaintiff had to sacrifice a lot to take
23 on and handle another retaliation and harassment case against the vicious, unscrupulous, malicious,
24
and vindictive UC Davis management and administration.
25
August 16, 2012-The Extension of the Investigatory Leave
26 (August 16, 2012-September 28, 2012)
27 496. On August 16, 2012, the Defendant sent Plaintiff another extension of the
28

Page 166 of 167
1 investigatory leave. However, this time the investigatory leave letter, which was routinely signed
2 by Plaintiff’s department head Charles Witcher, stated that the investigatory leave was extended
3 for one month and half from August 16, 2016, to September 28, 2012, instead of the routine two-
4 week period. Such a long-term extension caught Plaintiff’s attention and, at first, Plaintiff
5
thought it was a misprint and should be August 28, 2012 instead of September 28, 2012.
6
497. To clarify the investigatory leave letter date issue, Plaintiff sent, on the
7
same day, an e-mail to Charles Witcher and asked him whether September 28, 2012, was the true
8
date. In response, Charles Witcher confirmed that it was the true date and cc-ed his response to
9
UC Davis HR Director Stephen Chilcott and HR Labor Relation Supervisor Brent.
10
Plaintiff thanked Charles Witcher for clarification and then forwarded the mail conversation to
11
UC Davis Medical Center CEO Ann Madden Rice, UC Davis Chief Compliance Officer Wendi
12
Delmendo, UC HR Vice President Dwain Duckett, and UC HR Director Christopher Simon, as
13
well as the UC Regents Office and UC Chancellor Office, with only one comment: “For your
14
15 review and consideration.”
16 498. This long extension of investigatory leave passed the one-year anniversary
17 of the September 1, 2011, first investigatory leave letter, which the Defendant had served
18 Plaintiff. Plaintiff became very concerned that something more drastic was going on with
19 Plaintiff’s employment due to the vicious attack against Plaintiff’s coworker Dereck Cole, as
20 well as Wendy Delmendo and Gina Harwood’s letters to Plaintiff’s coworker, Kenny Diede, and
21 the endless pseudo-investigations conducted by the assigned Defendant, two of “UC Davis Death
22 Squad’s” members, Brent Seifert and Cindy Oropeza, from the UC Davis Medical Center HR
23 Department.
24
499. Plaintiff was not mistaken that that something more drastic was going on
25
and finally uncovered it after Plaintiff, in November 2011, received a bulk e-mail
26
correspondence exchange between the perpetrators, who were plaining another provocation to
27
deliver Plaintiff to the UC Davis Medical Center # 11 to silence Plaintiff forever. Plaintiff was
28

Page 167 of 168
1 not sure and did not know why Defendant were trying to provoke and kill Plaintiff. Nothing was
2 making any sense and Plaintiff was very concerned about what he had stepped into that was
3 causing such unknown and unheard actions against employees, including the permission to use
4 deadly force to end an employee’s employment by ending the employee’s life.
5
500. On the same day, August 16, 2012, HR Director Stephen Chilcott and the
6
remaining HR Labor Relations Manager Travis Lindsey reminded Plaintiff that his coworkers’
7
cases, which Plaintiff was representing, were being placed in abeyance. Travis Lindsey
8
responded that Charles Witcher had already sent to Plaintiff an investigatory leave extension.
9
10
11 August 28, 2012–The Letter to Compliance and Privacy Program Investigator

Gina Guillaume-Holleman
12
13 501. On August 28, 2012, Plaintiff sent a letter to Compliance and Privacy
Program Investigator Gina Guillaume-Holleman about the unfair overtime distribution in the
14
HVAC shop with following information and concerns.
15
16 “I am sending you the copy of the letter of expectation issued for HVAC
17 Technician Dereck Cole by Patrick Putney on August 9, 2012. I would prefer
18 not to explicitly elaborate on the allegations in the letter”
19 However, I would appreciate if you would interview Dereck Cole, and

20 he will describe in his own words why he was victimized by Patrick
21 Putney. I spoke with Derek briefly on the phone on two occasions after
22 he received the mentioned letter of expectation on August 23, 2012.
23 According to the information he gave me, the accusations in the letter are
24
fabricated and untrue, and the letter of expectation is the retaliation for
25
complaining about the unfair and preferential overtime distribution by Patrick
26
Putney. A few months ago, and in one of my letters, I warned Charles Witcher
27
that the preferential and unfair overtime distribution in the HVAC shop is the
28

Page 168 of 169
1 fast brewing conflict among employees. Dereck Cole is the fourth person in
2 HVAC shop to be victimized by Patrick Putney with Charles Witcher's
3 blessing because of workers’ legitimate complaints.
4 If you consider the moral side of Patrick Putney and his "knowledge and
5
disregard for UC Policies, law, and Principle of Community," which he
6
is referring to in the letter of expectation, then the whole picture is quite
7
clear, and Mr. Putney should receive so many letters of expectations
8
that he could use them as wallpaper to cover the walls in his office and
9
still have some left over. I would like to point out that the letter of
10
expectation received by Dereck Cole is dated August 9, 2012 and was received
11
by Dereck Cole on August 23, 2012, one month after Dereck Cole's alleged
12
misbehavior on July 24, 25, and 26. Also, Patrick Putney described Dereck
13
Cole as a plumber. As I know, Dereck Cole is a HVAC technician and not a
14
15 plumber.”
16
502. The subject of the unfair overtime distribution was one of the HVAC shop
17
technicians, George Ursu, who is the friend the HVAC shop supervisors Dorin Daniliuc. It was
18
most likely that the excessive overtime was a fraud and George Ursu never worked most of the
19
20
overtime but got paid the same as Dorin Daniliuc, who was officially working full time, though
21 he actually employed himself in his private HVAC business and private church more than 50
22 percent during company time.
23 503. After the complaint was made by Dereck Cole, George Urusus’s overtime
24
dropped $10,000 in 2013, and after Dereck Cole, in retaliatory action against him, was removed
25
from the HVAC shop, George Urus’s overtime bounced back with $11,000 in 2014.
26
27
August 28, 2012–E-mail from UC Davis Health System HR Workers' Compensation,
28 Ergonomics, Disability Manager Hugh Parker

Page 169 of 170
1
2 504. On August 28, 2012, Plaintiff received an e-mail from HR Workers’

3 Compensation, Ergonomics, and Disability Manager Hugh Parker. Hugh Parker
4 requested that Plaintiff remove him from the e-mail list as follows:
5
Mr. Waszczuk,
6
Please remove me from your e-mail mailing list as I am not interested in
7
receiving information related to employee and labor relations issues.
8
Thank you.
9
Hugh R. Parker, Manager
10
Workers' Compensation, Ergonomics, Disability Management;
11
505. Plaintiff was surprised with such a request from Hugh Parker because
12
Plaintiff knew Hugh Parker for quite some time, and Plaintiff thought that Hugh Parker was the
13
replacement for HR Labor Relation Manger Humberto Garcia who was dismissed in June On
14
15 August 28, 2012, Plaintiff did not know who replaced Humberto Garcia, and HR Consultant
16 Gina Harwood was unresponsive when Plaintiff asked her who her manager was after she sent
17 information to Plaintiff on June 22, 2012 that Humberto Garcia and Jill Noel Vandeviver were
18 no longer employees of the UC Davis Medical Center HR Labor Relations.
19 506. On August 28, 2012, Plaintiff did know that Hugh Parker was the
20 coordinator and conductor for the assembled group of UC Davis employees, nicknamed by
21 Plaintiff in the documents as “The UC Davis Death Squad,” which on May 31, 2012, in the ill-
22 planned provocation, attempted to kill or end Plaintiff’s employment at the UC Davis Medical
23 Center Trauma Unit #11. From the Public Act Records documents, Plaintiff learned about Hugh
24
Parker’s special assignment that had coordinated an assault on Plaintiff to terminate his
25
employment through ill-minded and orchestrated provocation on May 31, 2012.
26
507. In July and August 2011, Plaintiff exchanged with Hugh Parker his
27
opinion about the UC Davis Medical Center fraudulently using the Workers Compensation
28

Page 170 of 171
1 system to remove from the premises employees complaining about management misconduct,
2 harassment, and retaliation against employees. In July 2012, Hugh Parker, most likely with his
3 superior, HR Executive Director Stephen Chilcott—together with UC Davis Medical Center
4 Facilities and Construction Executive Director Mike Boyd—attempted to convince Plaintiff to
5
file a fraudulent Workers Compensation Claim. When Plaintiff refused, the Workers
6
Compensation Claim was filed on Plaintiff’s behalf anyway, but Plaintiff rejected the fraud and
7
filed a complaint with the State of California Workers Compensation Department Fraud
8
Division.
9
508. When the fraudulent Workers Compensation Claim did not work to
10
remove Plaintiff from the premises, Plaintiff was placed on bogus investigatory leave on
11
September 1, 2011 by the UC Davis administration until Plaintiff’s employment was terminated
12
on December 7, 2012 by the Letter of Termination dated December 5, 2012, which was signed
13
by the UC Davis Medical Center Plant Operation and Maintenance Manager Charles Witcher.
14
15 509. In May 2012, Plaintiff learned from the Public Record Act documents he
16 received that Hugh Parker had requested the investigation report on Plaintiff from HR
17 Investigator Danesha Nichols, which was fabricated for the purpose of the ill-planned
18 termination of Plaintiff’s employment on September 23, 2011.”
19 The information about the planned attempt to terminate Plaintiff’s employment was leaked and
20 the plan failed. HR Investigator Danesha Nichol’s report, which Hugh Parker requested from her,
21 was destroyed according to the UC Davis Public Record Office, and a copy was never provided
22 to Plaintiff.
23 Plaintiff is not certain”, but it appears that September 23, 2011 was the Defendant’s first
24
attempt to provoke the physical confrontation from Plaintiff, physically hurt him, and then
25
dismiss him with accusations that he was violent.
26
510. Plaintiff’s opinion is based on the fact that, two days prior to September
27
23, 2011, he received a letter from his Department Head Charles Witcher stating that he would
28

Page 171 of 172
1 be escorted to the HR Investigator office when he arrived at the UC Davis Medical Center that
2 day. In November 2012, Plaintiff learned from the Public Record Act documents that Hugh
3 Parker was the conductor and coordinator of the assembled team nicknamed by Plaintiff in the
4 documents as “The UC Davis Death Squad,” which attempted to kill or end Plaintiff’s
5
employment on May 31, 2012 at the UC Davis Medical Trauma Unit #11.
6
August 29, 2012-The Letter from Compliance and Privacy Program Investigator
7 Gina Guillaume-Holleman
8
511. On August 29, 2012, Plaintiff received a letter from the Compliance and
9
Privacy Program Investigator Gina Guillaume-Holleman.
10
512. By means of this letter, Plaintiff was notified that the UCD Davis Health
11
System (UCDHS) Compliance Department had completed its investigation of allegations and
12
was advising of possible policy violations regarding a PO&M manager who allegedly accepted
13
money from vendor(s) for personal use and a PO&M supervisor allegedly using a paintball gun
14
on university premises. Both matters had been investigated and no proof of violations was
15
provided by Plaintiff or obtained during the investigation.
16
17 513. Gina Guillaume-Holleman was the Defendant’ investigator who, on July
18 18, 2012, interviewed one of Plaintiff’s coworkers from the UCDHS HVAC shop, Mark Montoya.
19 During the interview, Gina Guillaume-Holleman showed Mark Montoya Plaintiff’s photo and
20 asked him whether Plaintiff was a threat to him and, thereafter, she made an attempt to solicit Mark
21 Montoya to sign an affidavit that Plaintiff was dangerous. Outraged by her demand, Mark Montoya
22 left the interview and went to the HVAC shop and mentioned what had happened to one of
23 Plaintiff’s other coworkers, who called Plaintiff and disclosed the information about Mark
24 Montoya’s interview. A few days later, Mark Montoya personally confirmed the information about
25 Gina Guillaume-Holleman’s demand.
26
514. At the end of August 2012, Plaintiff was not worried about any investigation
27
but was worried about his own status due to the almost year-and-a-half-long, ongoing, vicious,
28

Page 172 of 173
1 despicable, and unthinkable witch hunt by Defendant against Plaintiff and his coworkers. Plaintiff
2 constantly was on the verge of a nervous breakdown, having dealt with repeated violations of his
3 civil and human rights caused by the Defendant’ psychological torture and the fact that he did not
4 know what was going to happen to him from one day to the next, not to mention the fact that
5
Plaintiff was 61 years old, had open-heart surgery, and was on nine different medications.
6
515. Deeply stressed due to the Defendant’ outrageous behavior and his
7
unknown day-to-day employment status, Plaintiff asked Bank of America for permission to sell
8
his house on short sale. Plaintiff lost his house, which was supposed to be his retirement home,
9
adding more stress to his spouse and himself and worsening his mental health. Plaintiff’s lost
10
enjoyment for life.
11
12 SEPTEMBER 2012
13 September 4, 2012—Kenneth Diede’s Letter to Department Head Charles Witcher.
14
516. On September 4, 2012, Plaintiff’s coworker from the HVAC shop to
15
whom Plaintiff was providing representation under the UC Davis Policy PPSM 70, submitted a
16
17 complaint letter against HVAC shop manager and supervisor Patrick Putney and Dorin Daniliuc.
18 These two individuals attacked Kenneth once again and converted his 2012 annual employee
19 evaluation into retaliation documents.
20 517. Since July 2011, Patrick Putney and Dorin Daniliuc had been making
21 Kenneth Diede’s life miserable and his working conditions intolerable after Kenneth Diede
22 reported twice-convicted child pornography felon, Sean Robideaux , who was illegally
23 surfing the web on the HVAC shop commuters with Patrick Putney’s knowledge and permission.
24 Being on parole for his second child pornography strike Sean Robideaux , was not allowed to
25 touch a computer connected to the Internet per federal court order (Case: 2: 6 –cr- 00418-LKK,
26
The United States of America v. Sean Christopher Robideaux, United States District Court, Eastern
27
District of California, Indictment Violation(S) 18 U.S.C § 2252 () (4)(B) –Possession of Visual
28

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1 Depiction of Minors in Sexually Explicit Conduct ).
2 518. In the conclusion of his complaint letter to Charles Witcher, Kenneth
3 Diede wrote:
4
‘It is your responsibility to change the intolerable working condition in the
5
shop and stop Putney’s vicious and menacing attacks on me and others. I am
6
7 requesting, by this letter, that this be done immediately.’
9
September 9, 2012—Plaintiff Letter to Brent Seifert—UC Davis Medical Center HR Labor
10 Relation Supervisor and Principal Labor Relation Consultant
11
519. For over one year, the Defendant subjected Plaintiff to malicious
12
13
psychological terror, persecution, civil and human rights violations, enormous stress and worries
14 as a result of losing his home and, most likely, his employment at the age of 61 and a slim
15 chance to find any employment due to his age and health.
16 520. Due to unknown means regarding the ways in which the Defendant intended to do
17 Plaintiff further harm on September 9, 2012, Plaintiff sent a letter to UC Davis Medical Center HR
18 Labor Relation Supervisor Brent Seifert with an inquiry to update Plaintiff about his bogus
19 investigation against Plaintiff to which he was assigned in May 2012. Plaintiff wrote the following
20 in his September 9, 2012, letter: The original letter was edited by the Professional Proof Reader
21 for the purpose to avoid confusion about merit in the letter-Original upon request)
22
“Dear Mr. Seifert:
23
24 By this letter I am requesting that you provide me with information on the
25 status of the phony investigation you have been conducting since May 31,
26 2012. I am not sure if you remember that you have been assigned to investigate
27 to determine the facts surrounding the e-mails I supposedly sent that were
28

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1 believed to contain discriminatory content and to collect relevant information
2 (see attached copy of Charles Witcher’s letter dated May 31, 2012, entitled
3 “Investigatory Leave”).
4
I am more than sure that Charles Witcher’s “Investigatory Leave” letter
5
dated May 31, 2012, was a precisely crafted provocation by the human
6
7 resources department with probable help from the former FBI Agent
8 employed by the UC Office of the President Mr. John Lohse and HR
9 psychologists from the UCDMC ASAP club. Unexpectedly Mr. Lohse,
10 contacted me shortly before my suspension in May 2012.
11
When I read it on the Association of Workplace Investigators web page, I
12
choked and said to myself, “This guy with such an impressive background
13
career and connections that he is a perfect guy to frame me.”
14
15 The May 31, 2012, provocation followed Witcher’s and the HR department’s
16 cowardly and ill-crafted action that placed me on ten days’ suspension without
17 pay after Danesha Nichols’ phony investigation and my five-month
18 administrative/investigatory leave.
19
It is not coincidental that the Mr. Lohse got involved to help cover up the UC
20
21
Davis and UC Davis Medical Center management’s corrupted and unlawful
22 activities, which are happening in every pointed place and involving UC Davis
23 “chiefs and Indians” including, but not limited to, HR Chief Stephen Chilcott;
24 UC Investigators Danesha Nichols, Gina Guillaume-Holleman, and her boss,
25 Teresa Porter; internal audits chief and UC Davis police officers such as Lt.
26 James Barbour, who once gave me special advice with former U.S. President
27 Ronald Reagan regarding the U.S. Marines. UC Davis Chief Compliance
28

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1 Officer Mrs. Wendy Delmendo, who needs another Chief compliance officer
2 to replace herself, in compliance with state and federal law and UC policies is
3 leading the pack of “chiefs and Indians” corrupt circle.
4
The May 31, 2012, precise and ill-crafted provocation had one goal: Make
5
Jerry Waszczuk mad, hostile, and snap by handing him another investigatory
6
7 leave letter and launch another phony investigation against him. If he will snap
8 and get hostile, then Lt. Barbour will take care of him and he will be done.
9
What a mistake. Jerry Waszczuk never became hostile and never snapped.
10
Instead, Jerry Waszczuk used his pen and computer to defend himself and
11
others abused and harassed by vicious, vindictive, corrupt, and criminally
12
minded UCDMC chiefs.
13
14 Furthermore Plaintiff wrote in his letter to Brent Seifert :

15
Almost three and a half months have passed since we met in HR Tycon II
16
building. We did not have too much talk about anything because you were
17
completely unprepared for the meeting since you did not expect that I would
18
ever get to your office after Witcher executed the investigatory letter that
19
should have ended the issue with Jerry Waszczuk.
20
21 The meeting that you improvised was about the country of Romania,
22
Romanians, and Reggae. I have summarized the meeting in the letter I wrote to
23
you the day after we met and there is no need to elaborate further about it.
24
25 The reason why I am writing to you is to determine the status of this “after
26 unsuccessful provocation” and phony investigation for which you had been set
27 up by the corrupted upper-circle UCDMC chiefs.
28

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1 In the conclusion of my letter, I ask you again to provide me with the status
2 of this phony investigation that is not only causing me this endless “home
3 arrest” in the form of investigatory leave, but also uncertainty regarding my
4 further employment.
5
The situation is taking a toll on my wife and family. I am forced to short
6
7 sell my house and if it does not go through, then I will let the house be
8 foreclosed. The Bank of America is aware of what my employer is doing to
9 me and leaning toward a short sale instead of a foreclosure. After I
10 stabilize my situation with my house, I will make sure that my employer
11 will pay the bill for this reckless harassment and assault on me and I will
12 pay for a new house of my choice.”
13
521. The September 9, 2012, Plaintiff’s letter to Brent Seifert was the first time that
14
Plaintiff informed the Defendant of Plaintiff’s awareness that the May 31, 2012, reckless Defendant
15
action against Plaintiff was nothing but the Defendant’ malicious and ill-crafted provocation to harm
16
Plaintiff.
17
522. On September 9, 2012, Plaintiff did not have any evidence or documents proving
18
that for the May 31, 2012, provocation, the Defendant assembled a special team nicknamed in
19
Plaintiff’s document “The UC Davis Death Squad” to kill Plaintiff or end his employment in the UC
20
Davis Medical Center Trauma Unit # 11. Plaintiff based his opinion on observed event facts,
21
information from his coworkers, the Defendant’ reckless attacks in May 2012 aimed at Plaintiff and
22
his coworkers to whom Plaintiff was providing representation, and by removing Plaintiff from the
23
stress management class one day before the provocation on May 30, 2012.
24 “
September 12, 2012—The e-mail entitled “Review of the Waszczuk Investigation”
25
26 523. On September 12, 2012, at 9:36 PM, the UC Office of General Counsel
27 Senior Legal Counsel Mia Belk sent an e-mail to UC Davis Medical Center HR Labor Relation
28

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1 Manager Travis Lindsey with attachment entitled “Review of the Waszzsczuk investigation-
2 CONFIDENTIAL COMMUNICATION (misspelled Plaintiff’s name ). Mia Belk’s e-mail
3 message to Travis Lindsey was blacked out by the UC Davis Public Record Office before it was
4 delivered to Plaintiff in November 2012 .
5
524. On the same day—September 12, 2012—at 10:38 PM, HR Labor Relation
6
Manager Travis Lindsey forwarded Mia Belk’s review of the Waszczuk Investigation to UC Davis
7
Health System (UCDHS) HR Executive Director Stephen Chilcott with a cc to HR Supervisor
8
Brent Seifert who, in May 2012, was assigned with HR Employment Opportunity and Diversity
9
Manager Cindi Oropeza to fabricate a false report on Plaintiff as the cause for the termination of
10
his employment if planned provocation would not work.
11
525. On September 13, 2012, at 7:50 AM, the HR executive director replied to
12
Travis Lindsey’s e-mail and instructed the HR labor relations manager to share Mia Belk’s
13
“Review of the Waszczuk Investigation” with UC Davis Chief Compliance Officer Wendi
14
15 Delmendo, UC Davis Health System Chief Counsel Anna Orlowski and UC Davis Health System
16 Chief Compliance Officer Teresa Porter and to let them know that the HR department was
17 proceeding with Waszczuk’s (Plaintiff’s) termination as planned.
18 526. Furthermore, HR Executive Director Stephen Chilcott instructed Travis
19 Lindsey to make suggested revisions and finalize the documents and letter of intent to terminate
20 the issue as soon as possible. In addition to the letter of intent to terminate, HR Executive Director
21 Stephen Chilcott instructed Travis Lindsey to discuss the assignments of the Skelly officer with
22 Plaintiff’s superior, UC Davis Medical Center Executive Director Mike Boyd.
23 527 The UCDHS HR Executive Director Stephen Chilcott’s confidential
24
communication response is interesting because it shows that HR Equal Employment Opportunity
25
and Diversity Manager Cindi Oropeza was not copied on Stephen Chilcott’s e-mail. Cindi Oropeza
26
was assigned with Brent Seifert to fabricate a bogus report as the cause for Plaintiff’s termination
27
of employment.
28

Page 178 of 179
1 528. As Plaintiff knows, Cindi Oropeza was an old friend of prior HR Labor
2 Relations Manager Humberto Garcia, who attempted to informally resolve an ongoing dispute
3 with Plaintiff informally in February 2012; thereafter, Garcia was replaced by Travis Lindsey. It
4 makes Plaintiff wonder whether Cindi Oropeza was on same list as Humberto Garcia and opposed
5
Plaintiff’s termination, but was forced as well—under the threat of termination—to craft a false
6
and slanderous report as a cause to terminate Plaintiff’s employment.
7
529. The other interesting fact in HR executive director’s reply to Travis
8
Lindsey is that the UC Office of the President (UCOP), Office of the General Counsel made the
9
decision to terminate Plaintiff’s employment, contrary to UCOP HR Director Christopher
10
Simon’s response to Plaintiff’s September 2011 inquiry for intervention in the case.
11
On September 25, 2011, Plaintiff sent the inquiry for help and to intervene in the case
12
to the UC HR Senior Vice Chancellor Dwain Duckett’s .
13
530. On October 26, 2011, The UCOP HR Director Christophe Simon
14
15 responded to Plaintiff September 2011 inquiry on UC HR Senior Vice President Duckett’s
16 behalf, stating that:
17
“This is in response to your faxes dated 9/25/2011 and 9/30/2011 to Vice
18
19
20
21
Delmendo.The Office of the President provides oversight to the ten Campus
22
University of California system, while the Chancellor of each campus has
23
responsibility for the organization and operation of the campus. With the
24
investigation by Ms. Delmendo currently in progress, it would be
25
26 inappropriate for the Office of the President to intervene in this
27 matter.We have asked Ms. Delmendo to keep us apprised of the progress of
28 this investigation. We are confident that your serious concerns are being

Page 179 of 180
1 appropriately addressed at this time.”
2
531. One year later, UC Davis Chief Counsel Wendy Delmendo again assigned
3
two HR investigators, Cindi Oropeza and Brent Seifert, to fabricate another report for a cause to
4
terminate Plaintiff’s employment. However, it is not UC Davis or UC Davis Medical Center
5
administration that decided to terminate Plaintiff’s employment; rather, the UC Office of the
6
President and UC Office of the General Counsel decided Plaintiff ‘s fate in contrary to UCOP
7
8
Director Christopher Simon letter.
9 532. UC Senior Counsel Mia Belk disappeared from the University of California
10 landscape two months after she issued her confidential review of Waszczuk’s investigation. Mia
11 Belk was not the only individual who disappeared from the University of California landscape
12 after involvement in Plaintiff’s dispute with the university.

13 533. The question is whether the 2009 Settlement–Agreement with the Regents
14 of the University of California signed by Plaintiff was a part of the reason why nobody at UC
15 Davis wanted to make the final decision to terminate Plaintiff’s employment and passed it to the
16 UC Office of the President and UC General Counsel Office or it was a different more serious
17 reason.
18
19 September 13, 2012—The UC Davis Death Squad Preparation for Plaintiff’s Final Departure
from the University of California. (By documents received from UC Davis Public Record Act
20 Office)
21
534. Following the September 12, 2012, University of California Office of the
22
General Counsel’s decision to terminate Plaintiff’s employment the UCDHS HR Executive
23
Director Stephen Chilcott sent on September 13, 2012, the information about Plaintiff’s planned
24
employment termination to the UC Davis police and assembled a group of UC Davis
25
representatives (nicknamed in Plaintiff’s documents as the UC Davis Death Squad, due to an ill-
26
crafted provocation by the Defendant on May 31, 2012, to kill Plaintiff or end his employment in
27
the UC Davis Medical Center Trauma Unit.
28

Page 180 of 181
1 535. From the bulk of documents Plaintiff received from the UC Davis Public
2 Record Act office in November 2012, Plaintiff learned, as follows, that
3 361. On September 13, 2012, UC Davis police sent an e-mail to the UC Davis Death Squad
4 coordinator, HR Workers Compensation Manager Hugh Parker, and HR Labor Relations Manager
5
Travis Lindsey with a cc to UC Davis Police Chief secretary Willette Roy stating,
6
“Hugh, I have talked with Chief Carmichael, and we should get the violence
7 in the workplace group together sometime to discuss a threat assessment on
Jerry (Plaintiff). Travis, is that acceptable to you? Jim.
8
Travis Lindsey responded that he agreed.
9 536. Furthermore, on the same day UC Davis Police Lt. James Barbour wrote
to Hugh Parker:
10
Chief Carmichael said there is a psychologist on retainer that helps with this? (Dr. White?)
11
(with question mark at the end of the sentence).
12
13
536. On September 14, 2012, UC Davis Death Squad Coordinator Hugh
14 Parker’s secretary, Sonia Guerrero-Rodriguez, sent an e-mail invitation for a meeting to other
15 UC Davis Death Squad members with the following subject in the e-mail: “Threat Assessment -
16 J. Waszczuk.” The message read, “Please provide me with the best time and date, from the
17 options below, to discuss the item in subject. I’d like to send out a meeting invitation as soon as
18 possible.” The message was ended with Muriel Strode’s quote “Do not follow where the path
19 may lead. Go instead where there is no path and leave a trail.”
20 537. Sonia Guerrero-Rodriguez sent her message to the following member
21 members of the UC Davis Death Squad: Brent Seifert, the UCDMC Labor Relations Supervisor;
22 UC Davis Police Lt. James Barbour; UCDMC HR Equal Employment Opportunity and Diversity
23
Manager Cindi Oropeza;UC Davis Health System Counsel David Levine; UC Davis Risk
24
Management Department employee Debra Schmidt; UC Davis Medical Center Emergency
25
Preparedness Coordinator Glynis Foulk; Manager of Workers’ Compensation, Ergonomics, and
26
Disability Hugh Parker, who wanted to see Plaintiff in July 2011 on workers compensation leave
27
and, in May and September 2012, wanted to see Plaintiff disabled in UC Davis Medical Center
28

Page 181 of 182
1 Trauma Unit #11; R.N., M.S.N. Nurse Manager Karen Kouretas, who was in charge UCDMC
2 Trauma Nursing Units (TNU) # 11,
3 “Trauma unit is a 36-bed acute care specialty and telemetry unit that
4 primarily provides inpatient care and treatment for patients who have
5
sustained blunt or penetrating injury, as well as those who may require
6
surgical intervention. This includes care of the patient with suspected or
7
confirmed intra-abdominal injuries, complex wound management,
8
orthopedic fractures, head/neck/face injuries, brain trauma, chest trauma,
9
and pulmonary injury.”
10
538. Additional recipients of the email included Marjorie Trogdon-Shock, an
11
HR licensed clinical social worker who, together with Hugh Parker on May 30, 2012, removed
12
Plaintiff from the stress management class she hosted; Carol Kirshnit, Ph.D. who, like Marjorie
13
Trogdon-Shock L.C.S.W, was a member of the UCDMC HR Academic and Staff Assistance
14
15 Program; Neil Speth, D.O., the medical director of UCDMC HR Employee Health Services; and
16 Travis Lindsay, the new UCDMC HR labor relation manager who replaced MikeGarcia in May
17 2012.
18 539. The proposed dates for the UC Davis Death Squad’s meeting were
19 September 18, 2012, from 10 to 11 AM; September 20, 2012, from 1 to 2 PM, and September 21,
20 2012, from 9 to 10 AM.
21 540. UC Davis Police Lt. James Barbour responded that he was available for the
22 meeting on Tuesday, September 18, 2012. Plaintiff does not know when the meeting took place
23 because 21 pages of e-mail chat between UC Davis Death Squad Members that Plaintiff received
24
from the UC Davis Public Record Act Office were blacked out in same manner as the e-mail chat
25
of this group for the May 31, 2012, provocation to send Plaintiff to the UC Davis Medical Trauma
26
Unit.
27
541. The presence and participation in this group including the UC Davis
28

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1 Medical Center Trauma Unit manager, police, psychologists, legal counsel, medical director of
2 HR health services and others is speaking for itself that this group is closely akin to a terrorist
3 organization that operated with full knowledge under the umbrella of the Regents of the University
4 of California to provoke, kill, and cover up the cause of employee death. It is more likely than
5
not that similar terrorist groups operate on other UC campuses and are sponsored and
6
employed by the Regents of the University of California.
7
8 September 23, 2012—Letter to Charles Witcher
9 542. Plaintiff, who was subjected to psychological terror by the Defendant, was
10 put under extreme stress after being forced again to leave the premises for the month-and-a-half-
11 long investigatory leave, which was issued and served to Plaintiff on August 16, 2012.
12 543. On September 23, 2012, Plaintiff wrote an open letter to his
13 Department Head, UC Davis Medical Center Plant Operation and Maintenance Manager Charles
14 Witcher, entitled
15 A FEW WORDS ABOUT THE LATEST COMPLAINTS UNDER THE PPSM 70 AGAINST
16
STEVE McGRATH AND PATRICK PUTNEY. (OPEN LETTER).
17
Plaintiff wrote the letter just two days before Witcher was ordered by HR Executive Director
18
Stephen Chilcott to sign the Notice to Intent to Dismiss (Plaintiff) for Serious Misconduct.
19
544. Aside from Plaintiff’s latest complaints about coworkers, made under UC Davis
20
Policy Complaint Resolution Policy PPSM70, the, Plaintiff elaborated about the previous
21
Department Head, Tony Moddessette, who was forced to leave in 2006 and was replaced by
22
Charles Witcher. This happened shortly before Plaintiff and his coworker William Buckans were
23
subject to the vicious attack and persecution orchestrated by the Defendant, which resulted in
24
Plaintiff’s suspension in March 2007 and his abrupt removal from the UC Davis Medical Center
25
26 Cogeneration Power Plant (“Central Plant”), where Plaintiff had been employed since June 1999.
27 Plaintiff’s suspension and reassignment in March 2007 was affirmed by Charles Witcher, who
28 was then the interim manager of the Plant Operation and Maintenance Department. While

Page 183 of 184
1 Witcher’s predecessor Tony Moddessette had an MBA degree and was not friends with anybody,
2 Charles Witcher was an electrician with only a high school diploma, but he was friends with one
3 very important person, UC Davis Medical Center Director Robert Taylor.
4 545. Plaintiff, in his letter to Charles Witcher, stated:
5
(This letter was edited by a professional proofreader to avoid confusion and
6
misunderstandings.)
7
Dear Charles:
8
INTRODUCTION
9
Besides the formal complaints under PPSM 70, which already have
10
been filed with HR against Steve McGrath and Patrick Putney by
11
various employees, I would like to address some of my concerns in
12
relation to the previously mentioned complaints.
13
I remember when Tony Moddessette was the manager of the Plant Operation
14
15 and Maintenance Department. At the time, there were problems within the
16 Central Plant in relation to shift differential pay and other labor/management
17 issues.
18 Moddessette was “rough and tough” and sometimes was unpleasant, but he did
19 not ever hesitate to come to the Central Plant, sit at the center of the control
20 room, and have an open discussion about the problems within in the plant.
21 Tony Moddessette did not hesitate to tell me, “Jerry, I don’t give a f...k what
22 you say,” but he would listen and fix the problems.
23 Tony Moddessette had no problem reversing the Plant Manager’s unjustified
24
decision to issue a written warning to one of the Central Plant operators. He
25
also did not hesitate to tell Jeff Lancaster that he was not hired to wash his
26
personal cars on company time.
27
Tony Moddessette did not hesitate to remove Tom Kavanaugh from his Central
28

Page 184 of 185
1 Plant manager position because of poor behavior toward his subordinates and
2 safety problems in the Central Plant. An indisputable fact is that Moddessette
3 never persecuted workers like Charles Witcher did.
4 I am not sure what caused Moddessette’s fall in the UC Davis Medical Center.
5
I can only guess that his departure from UCDMC was partly due to a colleague
6
from the Navy whom he hired as Central Plant Manager. Dan James basically
7
was overpowered by the Central Plant folks from the Jackson Area, who gave
8
him a false and unusual sense of security.
9
Unlike Tony Moddessette, Charles Witcher never advised Patrick Putney that
10
employees are obligated to pay their parking fees if they are parking on the
11
company premises.
12
Unlike Tony Moddessette, Charles Witcher never told Patrick Putney that the
13
HVAC and Plumbing Shop was meant to provide support and services for the
14
15 hospital/campus and was not a place to illegally park his personal vehicle,
16 chase roosters, or sell ducks and other livestock in the shop.
17 Unlike Tony Moddessette, Charles Witcher never told HVAC Shop Supervisor
18 Dorin Daniliuc that he had to work 8 hours every day, that company time
19 should not be used to run a private business, or that he should not bring his
20 personal auto mechanics in and use the UCDMC shop for his private HVAC
21 business.
22 Unlike Tony Moddessette, Charles Witcher immediately began to torment
23 others after taking over the department from Tony Moddessette in 2006. Six
24
years later, Witcher’s persecution continues.
25
The last six years speak for themselves. Those who have engaged in this
26
persecution must love to watch other people suffer and live in misery.
27
THE COMPLAINTS
28

Page 185 of 186
1 What I am most concerned about concerning the latest complaints filed under
2 PPSM 70 is the William Buckans complaint, which will open old wounds
3 related to Steve McGrath and former Plant Manager Dan James, who passed
4 away not so long ago, may he rest in peace.
5
William Buckan’s last complaints against Steve McGrath and Mike Lewis will
6
force me to bring Dan James’ name into this whole mess. At the relevant time
7
in 2006, Witcher did not have a clue as to what was going on in the Central
8
Plant and without any reason, Witcher orchestrated your harassment of
9
William Buckans and me. It is unfortunate that Dan James was the plant
10
manager at that time, and he got involved in the whole mess.
11
I may have had some objections to Dan James holding the position of plant
12
manager, but I would hate to bring his name back into this ongoing mess
13
because Steve McGrath cannot control his buddies. Steve McGrath is
14
15 retaliating against William for no particular reason.
16 Dan James and Tony Moddessette were Vietnam War veterans. I have a lot of
17 respect for their sacrifices and their choice to risk their lives for the greatest
18 country on Earth.
19 Apparently Steve McGrath and Mike Lewis did not think or did not care that
20 harassing, bullying, and constantly retaliating against William for years in an
21 effort to make him quit his job would bring Dan James back into the mess that
22 they have created and participated since 2006.
23 You probably don’t know that William Buckans and Rick Tunello had a very
24
good relationship with Dan James because of their common life experiences.
25
However Dan James was quickly overpowered by the Jackson clique, and he
26
turned on Rick and William because the Jackson clique hated them. You
27
probably don’t know that William Buckans had a very good relationship with
28

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1 Dan James because both served their country. Dan James served in the US
2 Navy from 1967 to 1991; he operated the ship’s power plant and a LM2500 jet
3 engine like we have in the Central Plant.
4 Unlike the clique that Steve McGrath brought from his previous plant, William
5
Buckans did not have to cheat to pass his UCDMC test and get hired as an
6
operator. He passed his test because he had a lot of previous knowledge and
7
experience.
8
In addition to Dan James’ issues, I am very hesitant to bring Steve McGrath’s
9
personal life issues into William’s defense. I really hate to do it. I would prefer
10
to see Steve stop his retaliatory habits and leave William alone.
11
It is up to you and Steve McGrath to stop further action under PPSM 70.
12
Together, you can correct the problems and you will not have to reintroduce
13
the name of Dan James, who should be resting quietly in peace.
14
15 I would like to mention that, not so long ago, Hugh Parker from HR sent me an
16 email and wrote that he is not interested in labor relations issues. Mr. Parker
17 was an HR labor relations consultant, and one of the complaints I am handling
18 is strictly related to him. He will soon be dealing again with the labor relations
19 issues related to the peaceful Workers’ Compensation Office.

20 The latest complaints under PPSM 70 were filed with HR by Dereck Cole and
21 Kenny Diede against Patrick Putney (Letters of Expectations and Evaluation).
22 I will not elaborate about the merit of the mentioned complaints because they
23 are specifically outlined in the related documents.
24
At this point, I would like to only mention again the overtime distribution in
25
the HVAC shop, which was the subject of Patrick Putney’s retaliation against
26
Dereck Cole (who complained about it).
27
I will officially ask Gina Guillaume-Holleman from the Compliance & Privacy
28

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1 Investigations Department to investigate these issues and to make a
2 determination about whether there re discrepancies in overtime distribution.
3 The allegations were brought against George Ursu, who is not a plumber or an
4 HVAC technician in the HVAC shop but has nevertheless apparently been
5
given a lot of overtime that belonged to the plumbers and HVAC technicians.
6
I saw George Ursu’s overtime income earned for 2010 and 2011 on the official
7
UC webpage. It is no wonder that people are concerned when his overtime is
8
10 times higher than other workers’.
9
I can’t look myself at George Ursu’s work orders to determine whether his
10
earned overtime is legitimate or not. I would like to remind you that I was
11
denied access to the work order system last year. I am far from accusing
12
George of any wrongdoing because of his overtime earnings, but they must be
13
investigated to clear the air and to prevent any more hostility or retaliation
14
15 related to this subject. I have nothing against George as a person or a coworker
16 regardless of his statements in the Danesha Nichols report. I am just
17 representing my coworkers in their complaints and trying to do my job as best
18 as I can with the limited resources I have after being banned and isolated from
19 the HVAC shop for over a year.

Regards,
20
Jaroslaw Waszczuk
21 Representative for William Buckans, Kenny Diede and Dereck Cole
CC: TO WHOM IT MAY CONCERN
22
September 25, 2012—Notice of Intent to Dismiss for Serious Misconduct
23
24
546. As Plaintiff anticipated that something would happen to him during the
25
one-and-a-half month investigatory leave and the lack of response from HR Labor Relations
26
Supervisor Brent Seifert’s investigation, on September 26, 2012, Plaintiff received by overnight
27
mail the Notice of Intent to Dismiss for Serious Misconduct dated September 25, 2012. It was
28

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1 routinely similar to other documents that Plaintiff received in the past by the UCDMC Plant
2 Operation and Maintenance Department Manager Charles Witcher.
3 The notice stated that:
4 “Re: Notice Intent to Dismiss for Serious Misconduct
5
“The purpose of this letter is to inform you that I intend to dismiss you
6
7 from your position as a Sr. Development Engineer in Plant Operations and
8 Maintenance. The reason for this action is your failure to adhere to UC Davis
9 Policy and Procedure 380-15, Staff Complaints of Discrimination, UCDHS
10 1616, Violence and Hate Incidents in the Workplace and the Principles of
11 Community.
12
On or about April 27, 2012, you sent an e-mail to Danesha Nichols,
13
UCDHS Investigations Coordinator stating your disagreement with an
14
investigation report she had issued dated February 9, 2012. The report found
15
that it was more likely than not that you had violated UCDHS Policy 1616
16
(Violence and Hate Incidents in the Workplace) ("1616"), UC Davis Policy
17
18 and Procedure Manual, Section 380-15 (Staff Complaints of Discrimination)
19 ("38015"), and engaged in insubordinate behavior in relation to the
20 investigation. Based on these findings I issued you a letter on or around April
21 13, 2012, informing you that I intended to suspend you without pay for ten
22 days. Attached to your April 27, 2012 e-mail was a video slideshow entitled
23 "Welcome to Romania". Based on the subject matter and content of the
24 communication, an investigation was requested to determine if the
25 communication violated University policies and procedures. During this time
26 you were placed on investigatory leave-.
27
Brent Seifert, Employee and Labor Relations Supervisor and Cindy Oropeza,
28

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1 EEO Manager conducted the investigation. During the investigation they
2 learned of additional e-mails you had sent to co-workers and other UC
3 employees that were alleged to be discriminatory and disruptive. As a result,
4 these communications were included in the investigation.
5
While the investigation was pending you sent additional e-mails to co-workers
6
7 and other UC employees that contained inappropriate and discriminatory
8 language (see attached e-mails). The following are excerpts from these e-mail
9 communications:
10
May 10, 2012 - "Somebody will give this Pollack bad evaluation and fire him
11
or will send Gestapo on his Ass"
12
13 June 6, 2012 - "because you will go straight to Hell for what you have done to
14 me in the last 12 months together with psychopath Putney , Witcher and HR

15 "Devil Advocates." and "GO TO HELL ALL OF YOU AND BURN THERE
16 UNTIL YOU EVAPORATE IN SHAME FOR WHAT YOU HAVE DONE
17 TO ME AND OTHERS
18
June 22, 2012 — PDF attachment to email titled "20120613 to Gina
19
Gaullaume-Holleman" - "I don 't know why but the Patrick Putney's working
20
21
environment culture in the HVAC shop is closely akin to the culture of Eastern
22 Europe Gypsy Village from the Borat's movie or Flea market in
23 Galt."September 10, 2012 — "..Dorin Danuliuc brought the Gypsy's culture
24 from Romania, cheating and stealing from his employer..."
25
Mr. Seifert and Ms. Oropeza concluded their investigation and issued a report
26
dated September 20, 2012, which is attached to this Notice. The investigation
27
report substantiated that you sent disruptive and intimidating e-mail
28

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1 communications regarding Mr. Daniliuc's national origin in violation of 1616.
2 In addition, it was substantiated that you sent harassing communications
3 regarding Mr. Daniliuc that were in violation of 380-15.
4
As discussed above, on or around April 13, 2012, prior to your e-mail to Ms.
5
Nichols, you were issued a Letter of Intent to Suspend for ten (10) days for
6
7 violation of 1616, 380-15, and insubordinate conduct. The letter outlined my
8 expectations that you abide by all UC policies and procedures, show respect
9 and remain professional at all times in the workplace, and follow the direct
10 orders given to you by a supervisor. After the Skelly process was completed
11 you were issued a Letter of Suspension on May 11, 2012 outlining the
12 expectations noted above. Additionally, you were provided the pertinent text
13 from UCDHS policy 1616 and UC Davis P&P Chapter 380-15 as part of the
14 investigation report issued by Ms. Nichols, and attached to the Letter of Intent
15 to Suspend.
16
Despite my repeated efforts to address your inappropriate and discriminatory
17
18 communications, you continue to send e-mails to numerous UC Staff
19 containing offensive and discriminatory language directed at several protected
20 classifications. Your failure to follow direct orders and the expectations set for
21 you is unacceptable and will not be tolerated. Your actions imply that you
22 believe you are above the rules and I cannot subject staff and your co-workers
23 to your continued discriminatory comments. Your blatant disregard for the
24 policies and procedures of this University, combined with your failure to
25 follow directives has left me with no alternative but to dismiss you from
26 University employment.You have the right to respond to this notice of intent to
27
dismiss for Serious Misconduct either orally or in writing. Your response must
28

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1 be received by the Skelly Reviewer, Allen Tollefson, Assistant Vice
2 Chancellor, and Facilities Management. Mr. Tolleffson can be reached at the
3 following: UC Davis, Facilities Services Building, Davis, CA 95616, 530-752-
4 5418 within eight (8) calendar days from the date of issuance of this letter. You
5
will remain on paid administrative leave until a final determination is made.”
6
547. Apparently, after Plaintiff sent the letter on September 9, 2012, to HR Labor
7
8
Relation Supervisor Brent Seifert and let him know that Plaintiff was aware that May 31, 2012,
9 was the date of the maliciously and ill-crafted provocation by the Defendant, somebody had the
10 idea to lure Plaintiff to the premises and hand Plaintiff the Notice of Intent to Dismiss with such
11 outrageous and sickening accusations in an attempt to provoke Plaintiff and expose him to the
12 UC Davis Death Squad’s attack.

13 September 26, 2012 – UC Davis Police Department Poster
“ PERSON NOT AUTHORIZED ON PROPERTY”
14
15
548. Instead of luring Plaintiff to the premises, the UC Davis Death Squad decided that
16
the UC Davis Police would issue a poster bearing Plaintiff’s photo and the verbiage “PERSON
17
NOT AUTHORIZED ON PROPERTY,” which was similar to the “FBI’s Most Wanted”
18
signage.
19
20 549. The UC Davis Police Poster stated:
21
“Jaroslaw Waszczuk is currently on administrative leave from
22
employment with the UC Davis Med Center. Mr. Waszczuk is not
23
authorized to be on UC Davis property without a legal reason or a medical
24
emergency.
25
26 Mr. Waszczuk is described as an older white male with brown and gray
27 hair. He is approximately 5’8” and 190 lb.

28

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1 If Mr. Waszczuk is seen trespassing on University of California Davis
2 properties, please contact the Davis Police Department immediately at
3 916-734-1555.”
4
5
550. The UC Davis Police poster that said “PERSON NOT AUTHORIZED
6
ON PROPERTY” and included Plaintiff’s photo and description was distributed around the UC
7
Davis Medical Center Campus and most likely was sent to managers and UC Davis employees
8
by electronic mail. UC Davis Police did not inform Plaintiff that he was not authorized on UC
9
Davis premises, and Plaintiff did not know what UC Davis Police would do if Plaintiff
10
11 unexpectedly showed up at the UC Davis Medical Center or the UC Davis Campus.
12 551. Plaintiff spent over one year on investigatory leave, under which he was
13 prohibited from being on the UC Davis premises, and Plaintiff never intended to go uninvited to
14 UC Davis Medical Center when he was on investigatory leave. Plaintiff did not understand why
15 the Defendant issued such a humiliating and disparaging Plaintiff poster.

16 552. In addition, the Defendant did not inform Plaintiff that the poster was
17 issued and distributed. The question is this: What were the Defendant’ intentions?
18 553. After the Defendant’ ill-minded but unsuccessful provocation to kill
19 Plaintiff or end his employment at the UC Davis Medical Center Trauma Unit, Plaintiff
20
experienced terrifying thoughts that never left his mind. Plaintiff is still terrified to think what
21
would have happened to him on May 31, 2012, if the criminally minded Defendant’ provocation
22
had been successful or what would happen if Plaintiff showed up unexpectedly at UC Davis
23
Medical Center for medical treatment, not knowing that a poster was distributed around campus
24
and that UC Police had been instructed to attack Plaintiff upon his arrival.
25
554. Plaintiff was informed about the Defendant’ “PERSON NOT
26
AUTHORIZED ON PROPERTY” poster by a coworker who took a picture of the poster with
27
his cellular phone and sent the photo to Plaintiff.
28

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1 555. Plaintiff was outraged when he was informed about the poster. Even a
2 felon who was twice convicted for child pornography and who was illegally accessing UC
3 Davis’s Medical Center HVAC shop computer was not awarded with such recognition.
4 Plaintiff, on the other hand, was a University of California employee for 13 years and had an
5
outstanding employee record.
6
556. The child porn felon motto “Silence or I Kill You” on the social media
7
Facebook page closely resembled the Defendant’s behavior after the which assembled a special
8
group of employees—nicknamed by Plaintiff the “UC Davis Death Squad”—with the purpose of
9
silencing Plaintiff forever in an unsuccessful and criminally minded provocation on May 31,
10
2012.
11
557. Plaintiff responded to the Defendant’ disparaging, humiliating and
12
terrifying behavior with a seven-page open letter dated September 30, 2012, which Plaintiff
13
addressed to UC Davis Police Chief Matt Carmichael. Plaintiff also sent an inquiry to the UC
14
15 Davis Public Record Act office for documents related to another of the Defendant’ acts of
16 psychological terror, which Plaintiff had been subjected to for over one year.
17
18 September 26, 2012 - The War Like Hysteria and Propaganda
19
20 558. The Defendant war-like hysteria and propaganda did not end with
21 placing the “Persona Non Grata” poster complete with Plaintiff’s photo and description around
22 UC Davis Medical Center.
23 559. On September 26, 2012, the UC Davis Health System HR Executive
24
Director Stephen Chilcott, who directly communicated the operation to the UC Office of the
25
President, sent an e-mail entitled “Confidential – Jerry Waszczuk (Plaintiff)” to the HR Labor
26
Relations Department Manager Travis Lindsey to ask the UC Davis Police department to offer to
27
speak to any of the supervisors or employees of the Plant Operation and Maintenance
28

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1 Department Head Charles Witcher about safety at work and the relevant agencies that should be
2 contacted according to the location they live in, as well as guidance in terms of safety
3 precautions, etc.
4 560. Furthermore, Travis Lindsey was instructed by Stephen Chilcott to ask
5
for police patrols to start immediately and to include the Ticon 3 Human Resources
6
Building. He was also instructed to ask UC Davis Police to continue patrols through 10/31 at
7
which time the patrols would be reassessed.
8
Also, Travis Lindsey was instructed by Chilcott to ask UC Davis Police what resources the
9
UC Davis Police Department might need and could be assigned by Chilcott, the Skelly
10
reviewer, and the Assistant Vice Chancellor Allen Tollefson from the UC Davis Campus.
11
561. UC Davis Police Department Lt. James Barbour responded to Travis
12
Lindsey’s request and said he had assigned Police Officer Thomas McGee to the UC Davis
13
Assistant Vice Chancellor Allen Tollefson’s Office.
14
15 562. UC Davis Police Lt. James Barbour was reassigned from the UC Davis
16 Campus to the UC Davis Medical Center, which represented an enormous demotion and
17 involved a decrease to his salary, after the November 18, 2011, pepper spray attack against
18 protesting students on the UC Davis Campus. Documents show that Lt. James Barbour got
19 sucked into the action against Plaintiff by the “UC Davis Death Squad,” most likely not knowing
20 what the case was about. Apparently, he was promised that his salary would be restored to its
21 normal level. By reading the Public Record Acts documents, one can see that Lt Barbour was
22 dedicated to attacking Plaintiff in 2012 by any means.
23 September 26, 2012 – The Confidential Investigation Report
24
563. On September 26, 2012, Plaintiff received the Confidential Investigation
25
26 Report from the Defendant; it was attached to a Notice of Intent to Dismiss for Serious
27 Misconduct.
28

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1 564. The Confidential Investigation Report Regarding Allegations
2 Concerning Jaroslaw Waszczuk (Plaintiff) Plant Operations and Maintenance–HVAC
3 Shop was prepared by HR EEO Manager Cindi Oropeza and HR Labor Relations
4 Supervisor Brent Seifert.
5
565. The unfounded accusations and allegations in the report were fabricated based on
6
the previous reports and were basically copied and pasted from the March 2007Bettye Andreos
7
8
Report and December 2011 and February 2012 Danesha Nichol’s reports. The only difference
9 was that Romanians were used in the reports instead of Jews to make Plaintiff look like a KKK
10 member or Nazi concentration guard.
11 566. Plaintiff, outraged by the Defendant’ sickening, fabricated accusation in
12 the report, responded to Cindi Oropeza and Brent Seifert with an open letter dated September 28,
13 2012.
14 567. In addition to the open letter response, Plaintiff sent an inquiry to the UC
15 Davis Public Record Act office for all documents related to the Defendant’ Notice of Intent to
16 Terminate Plaintiff.
17 OCTOBER 2012
18
19
October 1, 2012—Open Letter to the UC Davis Police Chief
20
21
568. Plaintiff was outraged by the UC Davis Police Department’s humiliating and
22
disparaging “PERSON NOT AUTHORIZED ON THE PROPERTY” poster, which was
23
issued and distributed around UC Davis campus on September 26, 2012.
24
569. On October 1, 2012, Plaintiff wrote an open letter to new UC Davis Police Chief
25
Matt Carmichael, who replaced Annette Spicuzza and to Chancellor Katehi, who ordered the
26
firing of his colleague, Lt. John Pike, in August 2012.
27
28 570. In September 2011, Plaintiff asked a UC Davis Police captain Joyce Souza for

Page 196 of 197
1 help due to the Defendant’ despicable, unfounded and fabricated allegations against Plaintiff,
2 which were distributed around by Plaintiff’s department head and by HR staff. Since then,
3 Plaintiff has sent information from the UC Davis Medical Center to UC Davis Police Captain
4 Souza (along with Lt. John Pike and UC Davis Police Chief Annette Spicuzza). All three lost
5
their jobs with the UC Davis Police Department in 2012, as did Plaintiff, UC Davis HR
6
Labor Relations Manager Humberto Garcia and his assistant Jill Noel Vandeviver, who
7
attempted to resolve the dispute with Plaintiff informally.
8
571. Plaintiff wrote the following open letter entitled “OPEN LETTER TO
9
UC DAVIS POLICE CHIEF MATT CARMICHAEL IN RE: UC DAVIS POLICE
10
WARRANT AGAINST WASZCZUK”
11
Dear UC Davis Police Chief:
12
To this open letter, I have attached for your review the copies of my previous
13
correspondence with the UC Davis Police Department. I have also attached a
14
15 few more current photos of myself. My photo on the UC Davis Police Warrant
16 is outdated and was taken probably 10 years ago, prior to my 2006 open heart
17 surgery and left eye surgery. HR has a newer photo, which was taken when I
18 changed positions in February 2009 from central plant operator to assistant
19 development engineer.
20 I have no doubt that the UC Davis Police bulletin with my outdated photo was
21 issued to humiliate me, as it sounds like an arrest warrant. This is an
22 outrageous abuse of authority by the UC Davis Medical Center Plant Operation
23 and Maintenance Department (UCDMC PO&M), the HR Department and the
24
UC Davis Police Department. Such management actions were taken to cause
25
Waszczuk severe emotional distress, and they were done with a willful and
26
conscious disregard of both the law and UC policies.
27
The conduct of UCDMC management and the UC Davis Police Department
28

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1 caused Waszczuk to suffer severe emotional distress, humiliation, anguish,
2 stress and depression. The conduct of UCDMC management and the UC Davis
3 Police Department also caused other incidental and consequential damages and
4 expenses.
5
The conduct shown by UCDMC management and the UC Police Department is
6
outrageous and was done in a malicious, fraudulent and oppressive manner to
7
injure Waszczuk. This spite was caused by management’s failure to adequately
8
represent Waszczuk, and it was done in conscious disregard of Waszczuk’s
9
employee and civil rights.”
10
Jaroslaw Waszczuk
11
572. The Defendant’ distribution of the poster with Plaintiff’s photo on and
12
their choice to make Plaintiff look like a most-wanted terrorist amounts to malicious and
13
despicable defamation of Plaintiff’s character and integrity.
14
15 573. The Defendant have not mentioned in any previous document this
16 “PERSON NOT AUTHORIZED ON THE PROPERTY” poster, which defaced and
17 humiliated Plaintiff.
18 October 1, 2012—Extension of Time to File Response with Skelly Reviewer
19 574. On October 1, 2012, Plaintiff received an extension to file a

20 response/appeal with the assigned Skelly reviewer, UC Davis Associate Vice Chancellor Allen
21 Tollefson. The extension was in regard to the Notice of Intent to Dismiss for Serious
22 Misconduct, which Plaintiff received from the Defendant on September 25, 2012. In an e-mail
23 dated October 1, 2012, Charles Witcher wrote:
24
Good afternoon Mr. Waszczuk,
25
This e-mail is to inform you that you have received an Extension of Time to
26
File Response. The University will place the action in abeyance pending the
27
response on your request for information. You will be provided (8) calendar
28

Page 198 of 199
1 days to respond to the Letter of Intend to Dismiss once the University responds
2 to your information request. If you have any questions please contact me.
3 Sincerely,
4 Charles Witcher, Manager
5
Plant Operations & Maintenance
6
575. Plaintiff briefly responded to the Charles Witcher e-mail as shown below.
7
Note: to avoid any confusion or misunderstanding, Plaintiff’s response to Charles Witcher
8
was corrected by a professional proofreader.
9
Thank you, Mr. Witcher, and I appreciate your prompt response
10
regardless of our differences.
11
I would also like to mention that the Notice of Intent to Dismiss and the
12
insulting investigatory report have caused me to experience enormous stress
13
and a nervous breakdown.
14
15 I had to see my physician to get the extra medicine I needed to maintain my
16 stability. This is an additional reason to provide me with the time extension for
17 filing my response with the Skelly reviewer.
18 I believe that you are aware that I am already on nine different prescription
19 medicines.
20 I am assuming that you have read my last open letter to Mrs. Oropeza and that
21 you or Brent Seifert will question Dorin Daniliuc about his (and others’) lies,
22 which were inserted into the report.
23
24
Sincerely,
25
Jerry “
26
27
576. In addition to Plaintiff’s response to Charles Witcher’s extension, on October 3,
28

Page 199 of 200
1 Plaintiff sent another letter to the authors of the fabricated investigatory report, which was used
2 as cause to terminate Plaintiff’s employment. Plaintiff read the Cindi Oropeza and Brent Seifert
3 Investigation and Confidential Report, dated September 20, 2012, and Plaintiff still had no clue
4 why he was being kept off of campus on investigatory leave for over one year. Even if the
5
unfounded allegations in the report were true, this action would still not be legal. By UC policy,
6
such actions are not qualified as causes for employee termination when the employment is not at
7
will.
8
October 4, 2012—Letter from the UCDHS HR Workers’ Compensation Office
9
577. Following the October 1, 2012, letter that Plaintiff sent to UC Davis Police Chief
10
Matt Carmichael, the UC Davis HDHS HR Workers’ Compensation Office sent Plaintiff the
11
following letter with the attached workers’ compensation claim.
12
13 October 1, 2012
14
RE: Workers’ Compensation Stress/Psychiatric related claim
15
Dear Mr. Waszczuk:
16
17 In an e-mail we received dated 10/01/2012 you indicate that you have suffered
18 “severe emotional distress” from your employment at the UC Davis Health
19
System. As such, if you wish to pursue a psychiatric injury claim, related
20
to your employment at UC Davis Health System, please fill out the
21
enclosed DWC-1 Form and return to our office at:
22
23 UC Davis Health System
24
Workers’ Compensation Dept.
25
26
27 Sincerely,
28 Michael Tyler

Page 200 of 201
1 579. There would be nothing unusual about this letter if UC Davis Health System
2 Workers Compensation Office Manager Hugh Parker was not also one of the many people who
3 were causing Plaintiff severe emotional pain, depression, humiliation and psychological terror
4 for over one year.
5
580. In July and August 2011, on the order of HR Executive Director Stephen Chilcott,
6
Hugh Parker and UC Davis Medical Center Facility Director Mike Boyd attempted to remove
7
Plaintiff from the premises by offering to file a fraudulent workers’ compensation claim. When
8
Plaintiff rejected and refused such resolution, someone from the HR Workers’ Compensation
9
Office filed a fraudulent workers’ compensation claim on Plaintiff’s behalf. Plaintiff reported the false claim
10
to the State of California Department of Insurance Fraud Division.
11
581. Hugh Parker participated in an unsuccessful attempt to terminate
12
Plaintiff’s employment on September 23, 2011. Based on the record, Plaintiff believes that this
13
was the first attempt to terminate Plaintiff coordinated by Hugh Parker.
14
15 582. On May 30, 2012, Hugh Parker removed Plaintiff from stress management
16 class instead of encouraging Plaintiff to attend such classes, despite knowing what Plaintiff was
17 going through in his dispute with his employer
18 583. On May 30, 2012, Plaintiff did not know that Hugh Parker was a
19 coordinator for the Defendant’ specially assembled group of UC Davis employees, which
20 Plaintiff nicknamed the “UC Davis Death Squad” in the officially generated document
21 584. On May 31, 2012, and in September 2012, Hugh Parker (as conductor of
22 the aforementioned group) coordinated a malicious but unsuccessful provocation involving UC
23 Davis Chief of Police Matt Carmichael and Lt. James Barbour to ambush and kill Plaintiff or
24
otherwise end his employment at the UC Davis Medical Center Trauma Unit #11.
25
585. Plaintiff rejected the Defendant’ offer to file a false workers’
26
compensation claim. Apparently the Defendant attempted to escape enormous legal liability
27
using frequent workers’ compensation claims to further attack and distract Plaintiff from the real
28

Page 201 of 202
1 cause of Plaintiff’s employment termination. After one-and-a-half years of psychological terror,
2 Plaintiff and his family life had been turned upside-down.
3
4 October 22, 2012—HR Consultant Gina Harwood’s Letter to Plaintiff.

5
6
586. One month after the Notice of Intent to Terminate was issued, on October 22, 2012,
7
Plaintiff received an interesting letter from HR Consultant Gina Harwood, who replaced Jill Noel
8
Vandviver on June 22, 2012. Gina Harwood’s letter stated:
9
Re: Service as PPSM Complaint Representative
10
Dear Mr. Waszczuk:
11 This letter is to inform you that due to the completion of the investigation, you
12 are no longer on investigatory leave. Your leave status has changed to
13 administrative leave with pay while the personnel action is pending.
14 Due to the change in your status, you will be permitted to serve as the
15 representative in complaint meetings for Kenneth Diede, William Buckans
16 and Dereck Cole. The following complaints will be removed from abeyance
17 and a Complaint Resolution Officer will be appointed:

William Buckans — Complaint #: 03-PPS-011-11/12, 03-PPS-024-11/12, 03-
18
PPS-023/11/12 Kenneth Diede — Complaint #: 03-PPS-025-11/12, 03-PPS-
19
017-11/12
20
In addition, I am in receipt of your appeal to Step 2 for Dereck Cole’s
21
Complaint, 03-PPS-003-12/13 and a Complaint Resolution Officer will be
22
assigned.
23 As the representative on file for the above referenced complaints, you will
24 receive copies of the appointment letters for the Complaint Resolution Officer.
25 Please let me know if you have any questions.
26 Sincerely,
27 Gina Harwood, SPHR “
28

Page 202 of 203
1 587. This first time UCDHS HR Labor Relations stated that Plaintiff
2 was permitted to serve as the representative for other University of California
3 employees, his status changed from the investigatory leave to administrative leave. The
4 Defendant placed Plaintiff on investigatory leave several times over one-and-a-half
5
years, and Plaintiff fount it outrageous that he could be prohibited from entering the
6
university’s property for meeting with hearing officer. Every University of California
7
employee has the right to the representation of his or her choice. Even organized labor
8
employees represented by unions have the right to be represented by a nonunion
9
representative. Plaintiff knows this because he was helping union employees in their
10
complaints against UC Davis Medical Center’s management.
11
588. Gina Harwood’s letter did not specify how Plaintiff was supposed to represent his
12
three coworkers at hearings at the UC Davis Medical Center or the UC Davis campus. Plaintiff
13
was scheduled to meet with assigned a HR Compliance Resolution Officer (CRO) after the UC
14
15 Davis Police Department issued and distributed the poster with Plaintiff’s photo and
16 description, which prohibited Plaintiff from being on the premises.
17 589. In a letter to Gina Harwood dated October 17, 2012, Plaintiff asked Gina
18 Harwood specific questions that she, as the Defendant’ representative, failed to answer in her
19 response dated November 22, 2012,.

20 590. Plaintiff’s questions to Gina Harwood were:
21
Do the employees I represent have the right to have me as their representative
22
after I am no longer employed by UC?
23
24 If the answer is “yes,” the next question is whether the University of

25 California will let me enter UCDMC premises for appeals hearings, and if
26 that is not the case, whether UCDMC will move the hearings outside of
27 UCDMC premises.
28

Page 203 of 204
1 It is my understanding that according to PPSM 70, grievant have the right to
2 the representation of their choice.
3 It is also my understanding that UCDMC Management, in cooperation with the
4 UC Davis Police Department, issued a warrant that prohibits my presence on
5
UC Davis’s property, if not all of the University of California’s premises. The
6
warrant does not state whether I will be arrested or shot if I enter the UC
7
premises uninvited or if I walk on Stockton Boulevard, next to the HR
8
Building. I am just curious.
9
I and the represented employees would like to know as soon as possible how
10
UCDMC HR Labor Relations will handle the problem that their representation
11
has been jeopardized by the warrant issued against Waszczuk.”
12
591. Obviously, Gina Harwood was advised by the Defendant’ attorney not to
13
elaborate on her response about the humiliating poster of Plaintiff issued by UC Davis Police on
14
15 September 26, 2012. Gina Harwood knew that Plaintiff had, in February 2009, signed the
16 Settlement-Agreement with the Regents of the University of California. Gina Harwood and other
17 perpetrators knew that the UC Davis Police poster was an indefensible breach of the Settlement-
18 Agreement signed by the Defendant and Plaintiff. The Defendant’ poster went beyond
19 disparaging Plaintiff. It was an act of malice beyond of human decency aimed at Plaintiff, and it
20 alone can be the subject of litigation against the Defendant.
21 October 30, 2012-The UC Davis Medical Center HVAC Shop Supervisors Patrick Putney and
Dorin Daniluc’s Attempt to Provoke Dereck Cole for Physical Confrontation
22
23
592. Just two days after Plaintiff wrote a letter to Director Boyd about UC Davis
24
management’s despicable retaliation and vendetta against HVAC shop technician Dereck Cole
25
26 on October 30, 2012, two of Dereck Cole’s supervisors, Patrick Putney and Dorin Daniliuc,
27 approached him in the hospital cafeteria during his break and verbally assaulted him in front of a
28 surveillance camera with clear intention to provoke him into physical confrontation and end

Page 204 of 205
1 Dereck’s employment.
2 593. Dereck Cole did not fall into Putney and Daniliuc’s or their superiors’ plan to be
3 eliminated through provocation and walked away from them. In tears, he went straight to the
4 office of HR Labor Relation Manager Travis Lindsey.
5
594. Dereck described his meeting with Travis Lindsey in an aftermath e-mail he sent
6
to Lindsey on October 30, 2012.
7
Travis,
8
I wanted to thank you for the time you gave me to present the harassment and
9
vindictive actions once again inflicted by Patrick Putney. I’m a little
10
embarrassed and usually don’t tear up at work but this behavior from
11
Patrick has caused a lot of anxiety and fear for my job as well as my
12
health. It has broken me down to the point where I feel threatened and
13
attacked since the appeal on my Letter of Expectation.
14
15 Thanks again for your support and consideration,
16 Respectfully,
17 Dereck
18 595. After meeting with Lindsey, Dereck Cole was removed from the HVAC shop and
19 reassigned to the preventive maintenance shop. The surveillance footage from the hospital
20 cafeteria should be checked, and appropriate disciplinary action should be taken against Patrick
21 Putney and Dorin Daniliuc. Dereck Cole was a victim of two UC Davis medical supervisors
22 supported by Department Head Charles Witcher, HR Labor Relations staff, corrupt UC Davis
23 Chief of Police Matt Carmichael, and his lieutenant James Barbour. If Dereck Cole had called
24
UC Davis police right after incident in the cafeteria, then he would most likely be accused and
25
investigated instead of Patrick Putney and Dorin Daniliuc.
26
597. Plaintiff represented Dereck Cole in his complaints against these two supervisors
27
in a retaliation complaint pursuant to UC Davis Policy PPSM 70. Right after the confrontation in
28

Page 205 of 206
1 cafeteria occurred, Plaintiff requested from the UC Davis Public Record Act office .
2 a copy of the surveillance tape from the cafeteria in relation to this attack against Dereck
3 Cole.
4 598. The UC Davis Public Record Act office informed Plaintiff on two occasions that
5
the surveillance tape from UC Davis Medical Center Hospital Cafeteria for October 30, 2012
6
was destroyed and unavailable.
7
8
NOVEMBER 2012
9
November 2, 2012 – Public Record Act Request
10
11
599. On November 2, 2012, Plaintiff received a response from the UC Davis Public
12
Record Act (PRA) office to his request for PRA documents related to the Defendant’s Notice
13
Intent to Dismiss for Serious Misconduct dated September 25, 2012.
14
15 600. Plaintiff briefly reviewed the received PRA documents and several pages of e-
16 mail correspondence dated June 1, 2012, which were sent by the UC Davis Health System
17 (UCDHS) HR Workers Compensation, Ergonomic and Disability Manager Hugh Parker to
18 David Levine, Debra Schmidt, Marjorie Trogodon Shock, Neil Speth, Carol Kirshnit, Karen
19 Kouretas, Cindy Oropeza, Glynis Foulk, James Barbour, and Travis Lindsay.
20 601. On the first page of the e-mail with subject “Jaroslaw ‘Jerry’ Waszczuk –PO&M
21 employee,” Hugh Parker wrote:
22
23 “Mr. Waszczuk returned to work yesterday from his suspension and was
placed back on investigatory leave the same day. At issue are writings sent by
24 Mr. Waszczuk while on leave. Mr. Waszczuk did not display any anger when
told he was being place on investigatory leave.”
25
26 602. After Plaintiff read Hugh Parker’s e-mail message, checked Hugh Parker’s
27 recipients, and found out who these people were, Plaintiff got goosebumps realizing that this e-
28

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1 mail was about the May 11, 2012 Letter of Suspension, which was maliciously crafted to lure
2 Plaintiff onto the premises.
3 603. When Plaintiff found out that Karen Kouretas, the UC Davis Medical Center
4 Trauma Unit # 11 manager, was listed on the e-mail, Plaintiff got very nervous and uncertain
5
about who was behind his employment termination.
6
7
604. Plaintiff combined Karen Kouretas’s name with Neil Speth, James
8
Barbour, Glynis Foulk, and David Levine with what happened to Plaintiff on May 30, 2012 and
9
what Plaintiff wrote in his letter dated September 9, 2012 to Brent Seifert and the UC Davis
10
Police. On September 26, 2012, a defaming “Persona Non Grata” poster with Plaintiff’s photo
11
and description surfaced. Plaintiff had no any doubt that May 31, 2012 was a maliciously crafted
12
provocation to kill Plaintiff or end his employment in UC Davis Medical Center Trauma Unit
13
No. # 11.
14
15 605. Plaintiff already covered this subject in the Statements of Facts, June
16 2012 chapter.
17
18 November 5, 2012 – Letter to Charles Witcher
19
20 606. On November 5, 2012, Plaintiff sent an inquiry to UCDHS PO&M

21 Department Manager Charles Witcher and requested that the Defendant reimburse Plaintiff for a
22 parking permit and two computer hard drives. Charles Witcher was the person who signed the
23 September 25, 2012 Notice Intent to Terminate Plaintiff.
24 (Note: to avoid any confusion or misunderstanding, Plaintiff’s response to Charles Witcher
was corrected by a professional proofreader.)
25
Re: PARKING FEE AND REIBURSEMENT OF TWO COMPUTER HARD DRIVES
26
28

Page 207 of 208
1 By this letter, I am respectfully requesting that my employer, UC Davis
2 Medical Center, reimburse me the parking fee deducted from my paychecks
3 every two weeks for the period from August 2, 2012 to the current payday
4 November 7, 2012.
5
As we both know, I have not parked my car on company premises since
6
7 August 2, 2011, with exceptions of the few hours to interview with ‘Danesha
8 Nichols in December 2011, a half-hour during a meeting with Humberto
9 Garcia in February 2012, and maybe 2 hours during the interview with Brent
10 Seifert on May 31, 2012. Total reimbursement should equal approx., $768.00;
11 see attached pay stubs.

12
Besides the above, I am still waiting for the two computer hard drives (HDs),
13
which should be returned to me. One HD was 1T and the other was 500 Gig.
14
Both HDs were installed with Putney’s permission on the company computers
15
as a backup for servers and other things. Gina Harwood wrote to me stating the
16
both computers were taken away from my office, and she asked me whether I
17
18 have receipts for the disks. I don’t, but I need my HDs back or need to be
19 reimbursed approx.$150.00.
20 Sincerely,
22
607. The Defendant never reimbursed Plaintiff for the parking permit or the
23
two hard drives.
24
November 12, 2012- The Brief for Oral Response Submitted by Plaintiff to Assigned Skelly
25 Reviewer. UC Davis Associate Vice Chancellor Allen Tollefson
26
27 608. On September 12, 2012, Plaintiff submitted the chronological, 23-page

28

Page 208 of 209
1 long brief for a yet- to -be -scheduled meeting with assigned Skelly Reviewer Allen Tollefson
2 with a short cover letter that explained the purpose of the brief prior the meeting.
(Note: to avoid any confusion or misunderstanding, Plaintiff’s letter to Allen
3 Tollefson was corrected by a professional proofreader.)
4
Re: Brief for Oral Response. The Notice Intent to Dismiss
5
6 Dated September 25, 2012 by “The UC Davis Medical Center ‘HR Death
7 Squad’”
8
Dear Vice Chancellor Tollefson:
9
10 Besides the yet-to-be-scheduled meeting with you, I am sending you a short

11 brief as a helpful tool so you and I may have a productive discussion, if any.In
12
addition to the mentioned brief, I would like to let you know that I have
13
become very hesitant to go to the Davis campus or UCDMC campus for any
14
meetings after I read the documents that I received under the Public Record
15
Act provision. For the above reason, I am asking you for permission to bring
16
one or two of my trusted coworkers to the meeting.
17
18 It clearly appears from the bulk of the e-mail correspondence that certain
19 individuals from the UCDMC HR department, led by HR Executive Director
20 Stephen Chilcott, new Labor Relation Manager Travis Lindsay, Cindy
21 Oropeza, and others, were planning to carry out their malicious and well-
22 crafted, evil conspiracy plot to provoke me and kill or send me to the UCDMC
23
Trauma Unit with severe blunt or penetrating injury on May 31, 2012. From
24
now on, I will call them the “HR Death Squad.” The explanation for the name
25
given to these individuals is located in the brief.
26
27 The assigned executor to carry out the plot to send me to my death or send me
28 to the UCDMC trauma unit to meet Karen Kouretas was the UC Police Lt.

Page 209 of 210
1 James Barbour, who apparently loves “War-Games” and bloodshed. I am
2 assuming that this did not happen without the permission of the new UCDPD
3 Chief Matt Carmichael and the top guns in the UC Davis and UCDMC
4 campus. It is a very chilling and disturbing matter to deal with, but what other
5
choices do we have not to deal with the “HR Death Squad”? I am still waiting
6
for more documents under the Public Record Act provision to have more
7
insight into the UCDMC “HR Death Squad” activities against victimized
8
workers and some supervisors.
9
10 I am hoping that eventually the FBI and district attorney will step in and break
11 this vicious and unscrupulous “HR Death Squad” into pieces.

12
Besides my own safety, I am very concerned about my coworkers’ safety, to
13
whom I am providing representations with their complaints. Patrick Putney’s
14
latest vicious attack on Dereck Cole was very disturbing and scary.
15
Sincerely,
16
Jaroslaw Waszczuk
17
18 609. The letter to Allen Tollefson was the first time Plaintiff nicknamed the assembled
19 Defendant group “HR Death Squad,” which in criminally minded, unsuccessful provocation
20 attempted to end Plaintiff’s employment at UC Davis Medical Center Trauma Unit # 11. Later,
21 Plaintiff changed the nickname from “HR Death Squad” to the “UC Davis Death Squad” due to
22 the involvement of the UC Davis police in the ill-planned assaults on Plaintiff.
23 610. On November 13, 2012, Skelly Reviewer Allen Tollefson responded to Plaintiff’s
24
letter and scheduled the meeting with Plaintiff on November 16, 2012 on the UC Davis campus.
25
611. On November 16, 2012, Plaintiff attended the meeting with assigned Skelly
26
Reviewer and UC Associate Vice Chancellor Allen Tollefson to discuss Plaintiff’s unwarranted
27
and without-valid-cause employment termination.
28

Page 210 of 211
1 612. Plaintiff arrived at the meeting with his trusted coworker from the UCDHS
2 HVAC shop, Kenneth Diede, as a witness. Plaintiff did not notice any UC Davis police presence
3 near his and his coworker’s office, where the meeting took place.
4 613. The meeting with Skelly Reviewer Allen Tollefson was cordial and pleasant.
5
Plaintiff focused on the issues he outlined in the brief, which Plaintiff sent to Tollefson on
6
November 12, 2012. Plaintiff especially focused on his employee performance reviews
7
(evaluations) for years 2010–2011 and 2011–2012, which are mandated by the UC Davis Policy
8
PPSM 23 and without providing Plaintiff evaluations for these years, the termination of
9
employment shall should be considered void, not to mention the February 2009 Settlement-
10
Agreement Plaintiff signed with the regents of the University of California. The meeting lasted
11
approximately one or one and half hour. Plaintiff did not have high expectations regarding the
12
outcome of the meeting, but Plaintiff followed the UC policies and held onto a little hope that the
13
UC Davis Assistant Vice Chancellor would change Plaintiff’s fate and give Plaintiff his job
14
15 back. Plaintiff was unaware on November 16, 2012 and a long time after the meeting that
16 Plaintiff’s fate was already decided a long time before the meeting with Allen Tollefson’ by the
17 Regents of the University of California the UC Office of the President,(UCOP) and the UC
18 Office of the General Counsel for a completely different reason. Plaintiff thought he was being
19 hunted down like an animal or subhuman by the UC Davis administration’s designated thugs.
20 614. On November 18, 2012, Plaintiff sent to Skelly Reviewer Allen Tollefson the
21 meeting summary letter entitled “Our Meeting on November 16, 2012. -The Notice Intent to
22 Dismiss Dated September 25, 2012 BY “The UC Davis Medical Center “’HR Death
23 Squad.’”
24 (Note: to avoid any confusion or misunderstanding, Plaintiff’s letter to Allen
Tollefson was corrected by a professional proofreader.)
25
Re: Our Meeting on November 16, 2012.
26
The Notice of Intent to Dismiss dated September 25, 2012.
27
28

Page 211 of 212
1 Thank you for the opportunity and time to meet with you to discuss my
2 employment termination.
3 For the record, the meeting took place on the UC Davis Campus, at the
4 location of 1050 Extension Center Drive, Davis, CA 95616 on November 16,
5
2012, at 9:00 A.M.
6
Besides your and my presence at the meeting, Mr. Kenneth Diede attended
7
the meeting as my trusted coworker and witness to the meeting. Mr.
8
Kenneth Diede did not participate in our approximately one-hour
9
discussion. The purpose of this letter is not to summarize our one-hour
10
meeting but to capture what was not discussed at the meeting. In my brief
11
for the oral response that I sent to your office on November 13, 2012, I
12
have skipped almost one year of facts from the “battlefield” between me
13
and the UCDMC “HR Death Squad.” I assumed that you would be strictly
14
15 focused on Charles Witcher’s notice of intent to dismiss dated September
16 25, 2012. The notice not say too much besides some quotes taken out of
17 context from my letters that I wrote due to the vicious and unscrupulous
18 war against me, which has lasted over one year and is still going.
19
The very powerful forces from the UCDMC Human Resources Department
20
and the UC Davis campus, as well as the involvement of the director of the
21
investigation sent from the UC Office of the President against me in May
22
2012, make me believe that the reason or reasons to harm me were not
23
my reporting of Patrick Putney’s chickens, roosters, goats, sheep and
24
other animals for sale in the UCDMC HVAC shop. I do not believe
25
26 that it was due to me reporting Patrick Putney’s habit to cheat his
27 employer out of the parking fee for four years by hiding his car inside
28 the shop. I don’t believe reporting Dorin Daniluc’s private and

Page 212 of 213
1 notorious activities while on company time was the reason to attack me
2 with such brutal impact. Even writing about Dorin Daniluc’s provided
3 services for Director Robert Taylor at his private residence would not
4 justify such an assault.
5
I was thinking that, most likely, the reasons “to kill” could be due to the
6
7 writing in the letter dated March 13, 2011, referring to the central plant
8 operator Todd Georlich’s tragic suicide that took place in December 2010
9 as well as the secret and fraudulent 12% pay raise the central plant
10 operators received in December 2010. But I am not so sure.
11
The other reason that I was thinking it could be is the child pornography
12
issue reported in August 2011 by my coworker Kenny Diede in his
13
2010/2011 employee evaluation complaint under the PPSM 70. The
14
complaint is still unresolved. Kenny Diede became a subject of retaliation
15
by Patrick Putney with Charles Witcher’s support and approval. I am
16
representing Kenny with his complaints under PPSM70. It is very bizarre
17
18 that the child pornography issue was completely ignored by Danesha
19 Nichols in her investigation report, but the graphic video clip about the
20 devastation of Romania by the communist regime that I sent to her became
21 a pretext to use as a “secret weapon” to attack me and terminate my
22 employment regardless of the fact that the mentioned video is widely

23 accessible to anyone on the Web. Another bizarre fact is Mr. Hugh
24 Parker’s involvement with the “HR Death Squad” operation that took place
25 against me on May 30 and May 31, 2012. Mr. Hugh Parker is not a
26 UCDMC HR labor relations team member. Mr. Hugh Parker is the
27
UCDMC HR workers’ compensation department manager. On May 30,
28

Page 213 of 214
1 2012, Mr. Hugh Parker, together with Mrs. Marjorie Trogdon Shock, the
2 licensed clinical social worker from the HR Academic and Stuff Assistance
3 Program, was hosting the “Class on Stress Management.”
4
The “Class on Stress Management” enrollment document dated May 23, 2012,
5
stated that “Participants will learn how to identify their anger triggers,
6
7 including thoughts. The class will describe effective responses to anger,
8 including coping thoughts and relaxation techniques.
9
Although stress and anger affect everyone, anger can be problematic if people
10
use it to gain control and express it unprofessionally.”
11
12 I received information about the class on May 23, 2012, from my former
13 central plant coworker William Buckans, who on the same day received a letter
14 of expectation (subject of unresolved complaint under PPSM 70), and the

15 information about the “Class on Stress Management” was attached.
16
I decided to enroll in the class, and I encouraged Kenny Diede and William
17
Buckans to do the same.
18
19 I showed up to class on time with my two colleagues. Before the class had
20 begun, Hugh Parker, with the help of Licensed Clinical Social Worker Mrs.
21 Marjorie Trogdon Shock, kicked me out of the class.
22
It was quite a surprise to me because I was constantly being accused that I
23
24
am angry, hostile etc. Such a class would be appropriate for a person who
25 is accused of not controlling his anger.
26
If I knew that Mr. Hugh Parker, along with Mrs. Trogdon Shock and the
27
other members of the “HR Death Squad,” had planned to send Jerry to the
28

Page 214 of 215
1 UCDMC trauma unit or to funeral home the next day, May 31, 2012, then I
2 would have never enrolled myself in the “Class on Stress Management” and
3 would have encouraged my coworkers not to either. It sounds like a Russian
4 roulette game to me.
5
Two days later, on June 1, 2012, Mr. Hugh Parker wrote in his e-mail
6
7 addressed to the other UCDMC “Death Squad” members:
8
“Mr. Waszczuk returned to work yesterday from his suspension and was
9 placed back on investigatory leave the same day. At issue are writings sent by
Mr. Waszczuk while on leave. Mr. Waszczuk did not display any anger when
10 told he was being place on investigatory leave.
11
Hugh R. Parker, Manager”
12
13
Could you imagine what would or could have happened if Mr. Parker,
14
along with Mrs. Shock, would not have “shocked” me and did not kick me
15
16
out from the “Class on Stress Management” on May 30, 2012?
17 I imagined that after attending the “Class on Stress Management,” I would

18
kiss and hug Mr. Charles Witcher and probably add him to my Christmas list
19
to send him presents every year as appreciation for again placing me on
20
investigatory leave, contrary to what I was writing about in my letters. I would
21
probably send flowers to Danesha Nichols, Wendy Delmendo, Gina
22
Harwood, Teresa Porter, and Gina Holleman and apologize to them
23
because I did not see how hard they were working to cover up the scum,
24
conspiracy, retaliation, fraud, and revenge of HR and the Plant Operation
25
and Maintenance managers’ outrageously vindictive behavior toward
26
workers.
27
28

Page 215 of 216
1 Mr. Hugh Parker, in his e-mail dated August 28, 2012, wrote the following
2 to Waszczuk:
3 From: Hugh Parker [mailto:hugh.parker@ucdmc.ucdavis.edu]
4 Sent: Tuesday, August 28, 2012 8:59 AM
5
To: Jaroslaw “Jerry” Waszczuk
6
Subject: Re: Dereck Cole -Letter of Expectation dated August 9, 2012
7 Mr. Waszczuk,
8
9 Thank you.
Hugh R. Parker, Manager’Workers’ Compensation, Ergonomics, Disability
10 Management
As we spoke on Friday, I am sending to you the letter entitled I FEEL LIKE
11
A HUNTED JEW DURING THE HOLOCAUST that I wrote on October 9,
12 2011, which I addressed to the honorable members of the UC Davis Ethics and
Compliance Risk Committee, California State Assembly members, and the
13 regents of the University of California, plus the other relevant documents.
14
Prior to the above letter, I sent the e-mail to Danesha Nichols with the
15
request to interview all of my coworkers from the HVAC shop in regard to
16
the allegations against me and my allegations against Dorin Daniluc and
17
Patrick Putney.
18
19 The interviews did not happen until October 10, 2012 after I sent the letter
20 to the members of UC Davis Ethics and Compliance Risk Committee.
21
In addition to, I am forwarding to you an e-mail which I sent l to UC Davis
22
23 Police Captain Joyce Souza in spite of the transmission of Danesha
24 Nichols’ false accusations against me, which alleged that I am violent and
25 make discriminatory comments. I thought that somebody had filed some
26 kind of phony report to the police and that Danesha Nichols was in
27 possession of the document and making noise in her irresponsible

28

Page 216 of 217
1 correspondence. I think that the correspondence with Captain Souza is
2 a very important piece of evidence that proves that everything against
3 me has been fabricated along with the (still unknown to me) reason to
4 fire me from the job without cause.
5
In conclusion, I still don’t know why and am very concerned about the real
6
7 reason for UCDMC “Death Squad” to physically harm or kill me on May
8 31, 2012. I am wondering what these conspiring individuals had in their
9 minds by believing that they could set me up and make me seem violent
10 and dangerous. Hypothetically, I understood their plan: After Mr. Witcher
11 handed me another investigatory-leave letter just after suspension from

12 work, I would attack Mr. Witcher—who was not warned about their plan—
13 would become a casualty of the “HR Death Squad” war, and I would be
14 finished. This is very sick and unbelievable.
15
At this point, I am not sure whether we are dealing with a child-porn ring
16
within UCDMC, workers-compensation fraud, or massive short-term disability
17
18 fraud.
19 It seems to me that Mr. Chilcott was trying to train his crew on how to deal
20
with “rebellious” workers, knowing that I would not give up so quickly, and he
21
was trying to find out how long I would resist the attacks and his blitzkrieg.
22
23 Maybe it was a bit of everything and at some point got so out of control and
24 had so many people involved for no reason; now, somebody must pay the cost
25 of the whole operation.

26
I will cease any further action and correspondence until I receive the final
27
employment-termination notice. I have no time to deal with this since I have to
28

Page 217 of 218
1 find a place to live due to my house was sold on short sale due to my uncertain
2 employment situation I have to prepare myself for several hearings in regard to
3 the PPSM 70 appeals due at the end of this month and the beginning of the
4 next month.
5 However, if you have any questions, need any additional documents or
6 information, or you would like to meet with me again, I am always ready to
7 cooperate in this final solution.
8 Sincerely,
9 Jaroslaw Waszczuk
10 Enclosed:
11 Eduardo Espinosa’s letter dated October 09, 2009 to UC Vice

12 President Judith Boyette. The letter clarifies the statement “Somebody
13
tell me to give this Polack a bad evaluation and fire him” in Waszczuk
14
letters,Hugh Parker’s letter with invitation to file the fraudulent worker’s
15
compensation claim, which Waszczuk refused to do;letter dated July 22,
16
2011 and addressed to UC Davis Chief Counsel Steven Drown in regard
17
to the 2009 settlement-agreement violation;E-mail dated October 03,
18
2011 to Danesha Nichols with request to interview all workers from the
19
HVAC shop plus Manuel Saldana, Dorin Daniluc’s previous supervisor,
20
who had similar problems with Dorin Daniliuc’s habit of using company
21
time for his private business. Danesha Nichols did not interview Manual
22
23 Saldana and acquitted Dorin Daniliuc from all allegations regardless of
24 Daniliuc’s obvious, everyday misconduct,. Letter dated October 9, 2011
25 to UC Davis Ethics and Compliance Risk Committee, UC Regents and
26 State of California Assembly members; Letter dated October 06, 2011 to
27 UC Davis Police Captain Joyce Souza with request to check whether

28

Page 218 of 219
1 anybody filed a complaint or reported Waszczuk to the UCDPD due to
2 constant, unfounded accusations against him transmitted by the HR
3 attorneys and other individuals; Letter dated November 9, 2012 to
4 Charles Witcher. The letter clarifies the Waszczuk “Gestapo on my ass”
5
statement in outgoing correspondence; Letter dated November 23, 2011
6
to Gina Harwood. In the letter, Waszczuk has declined Gina Harwood’s
7
offer to file a request for extension of his medical leave under
8
Supplemental FMLA University Policy 2.210;
9
Pay stub with period end date 12/24/2011. The pay stub shows that
10
position title has been changed without Waszczuk’s knowledge from
11
assistant development engineer to programmer I. No clue why; the Class
12
on Stress Management invitation dated May 23, 2012;The e-mail from
13
Hugh Parker dated August 28, 2012 requesting his removal from the e-
14
15 mail mailing list; Letter dated September 9, 2012 to Brent Seifert with
16 request for investigation status update. In that letter, on the pages 2 and
17 3, Waszczuk has perfectly described ill-crafted provocation against him
18 on May 31, 2012, not knowing anything about the involvement of so
19 many people from the HR department, UCDPD police, trauma unit, and
20 UCDMC counsel until Waszczuk received documents under the Public
21 Record Act Provision in October 2012; Letter dated September 23, 2012
22 (Two days before the notice intent to terminate issued by Charles
23 Witcher on September 25, 2012 followed by the “Most Unwanted” Lt.
24
James Barbour’s warrant); October 4, 2012 e-mail from Michael Tyler as
25
an acknowledgment that I decline the offer for the workers-compensation
26
claim. I don’t file fraudulent claims.
27
CC: To Whom It May Concern
28

Page 219 of 220
1 615. In the post-meeting letter to Allen Tollefson, Plaintiff clearly pointed
2 out that there must be a different reason for why Plaintiff was being pursued with such
3 force and was nearly killed in the criminally minded provocation. However, Plaintiff
4 still had no clue what it was about. Plaintiff survived the Soviet Union and Communist
5
prisons for his political activities and struggled against the Communist regime in Soviet-
6
dominated Poland; yet, what he was experiencing at the University of California went
7
beyond Plaintiff’s imagination.
8
616. Besides Plaintiff’s meeting with the Skelly reviewer, on November 14, 2012,
9
Plaintiff sent a short e-mail to former UCDHS HR Labor Relation Consultant Jill Noel
10
Vandeviver, who was dismissed on June 22, 2012 together with her boss and manager of
11
HR Labor Relation Humberto Garcia. Jill Noel Vandeviver and Humberto Garcia were
12
handling Plaintiff and Plaintiff’s coworkers’ complaints to whom Plaintiff was providing
13
representation. Humberto Garcia was replaced by Travis Lindsey and Jill Noel Vandeviver
14
15 was replaced by Gina Harwood. Plaintiff was searching for clue as to what triggered the
16 Defendant’ brutal and merciless action against Plaintiff. In his letter to Jill Noel Vandeviver,
17 Plaintiff wrote:
(Note: to avoid any confusion or misunderstanding, Plaintiff’s e-mail to Jill Noel
18 Vandeviver was corrected by a professional proofreader.)
19
Re: Brief for Oral Response -Notice Intent to Dismiss. - UCDMC “HR Death
20
Squad”
21
Good Morning Ms. Vandeviver:
22
I am writing a few words to you because it appears that my employer, UC
23
Davis Medical Center made an attempt to frame me, provoke me, and kill me
24
25 or send me to the trauma unit in bad shape in May of 2012. Somehow, it did
26 not work out for the UCDMC “HR Death Squad.” I perfectly described the
27 whole provocation in my letter addressed to Brent Seifert on September 10,
28 2012, not knowing anything about it until I got a PRA request almost one

Page 220 of 221
1 month after I wrote the mentioned letter.
2 You were employed in May 2012 and you were in charge of the cases related
3 to my coworker and me. At some point, I thought that you would replace Mik
4 Garcia as a manager of Labor Relation because of your experience and
5
education. I was very surprised that you left after Gina Harwood sent me a
6
“Happy Announcement” that you and Mike Garcia were gone. (Attached). I
7
am not expecting you to give me any feedback about what happened or what
8
why the “HR Death Squad” wanted to send me to the trauma unit or the
9
cemetery. I am just giving you this information because I did not see any
10
documents where you or Mike Garcia participated in the plot to kill me or
11
send me to the trauma unit badly injured.
12
Best Regards,
13
Jerry Waszczuk
14
15 617. In November 2012, Jill Noel Vandeviver worked for the State of
16 California Hospitals after she left UC Davis Medical Center.
17
18 DECEMBER 2012
19 December 5, 2012 –The Letter of Termination

20 618. On December 5, 2012, UCDHS Plant Operation and Maintenance
21 Manager Charles Witcher sent to Plaintiff the Letter of Termination effective December 7,
22 2012 by e-mail with the attached Skelly Reviewer decision dated December 3, 2012. The
23 Witcher e-mails stated:
24
Dear Jerry:
25
Attached below is a letter informing you that I am dismissing you from your
26
position as a Sr. Development Engineer, Plant Operations and Maintenance at
27
UC Davis Health System effective December 7, 2012. Skelly Officer’s
28

Page 221 of 222
1 recommendations dated December 5, 2012 and Proof of Service are also
2 included. This Letter of Termination and attachments has also been sent to you
3 in US Mail today.
4 Sincerely,
5
Charles Witcher
6
432. The attached Letter of Termination stated:
7
Re: Letter of Termination
8
9 The purpose of this letter is to inform you that I am dismissing you from your
10 position as a Sr. Development Engineer in Plant Operations and Maintenance
11 at UC Davis Health System effective December 7, 2012. The reason for this
12 action is your failure to adhere to UC Davis Policy and Procedure 380-15,
13 Staff Complaints of Discrimination, UCDHS Policy and Procedure 1616,

14 Violence and Hate Incidents in the Workplace and the UC Davis Principles of
15 Community as outlined in my Letter of Intent to Dismiss for Serious
16 Misconduct dated September 25, 2012. The Skelly Review process provided
17 no new information that would cause me to change this intended action. You
18
are to immediately return all University property, including but not limited to:
19
ID badge, keys, equipment (computers, books, cell phones, disks/manuals),
20
uniforms and work product (electronic/paper files), etc. You have the right to
21
request review of this action under Personnel Policies for Staff Members 70
22
Complaint Resolution. If you wish to request review of this action, you must
23
do so in writing, using the appropriate complaint form. A written request must
24
be received in the UCDHS Employee & Labor Relations office no later than
25
thirty (30) calendar days from the date of this letter. You should immediately
26
contact the UCDHS Benefits Office at (916) 734-8099 to make an appointment
27
28 with a benefits counselor to determine the effect of this action on your benefits.

Page 222 of 223
Sincerely
1
Charles Witcher,Manager, Plant Operations & Maintenance
2 UCDHS
3 Attachment: Proof of Service;Skelly Officer's recommendations dated
December 5, 2012
4
Cc: Mike Boyd (w/o attachments); Department File; Personnel File/Records
5 Department (via E&LR Consultant);Employee and Labor Relations Consultant
(2);Unemployment Insurance Coordinator-Davis Campus HR w/attachment
6
7
619. The Skelly Reviewer , UC Davis Associate Vice Chancellor Allen
8 Tollefson’s decision dated December 3, 2012 and Charles Witcher’s Letter of Termination were
9 just formalities. No outstanding work history or performances outlined in Plaintiff’s employee
10 performance review (evaluations) were mentioned. Neither decision mentioned the February
11 2009 Settlement-Agreement Plaintiff signed with the regents of the University of California,
12 which guaranteed Plaintiff a job with the University as the Associate Development Engineer.
13
“December 3, 2012
14 Travis Lindsey
Manager
15 Employee & Labor Relations
University of California, Davis, Health System
16
Re: Letter of Intent to Dismiss--Jaroslaw Waszczuk
17
18 Dear Mr. Lindsey,

19
I have completed my review of the intended action regarding Mr. Waszczuk.
20
Mr. Waszczuk exercised his Skelly rights and requested a meeting and
21
provided to me additional written documentation in support of his argument. I
22
held the Skelly meeting on November 16, 2012 at 9:00am. Those in attendance
23
were Mr. Waszczuk, Kenny Diede (witness), and me .Mr. Waszczuk did not
24
deny the information contained in the September 25, 2012 Notice of Intent to
25
Dismiss and in the documentation attached to the notice. He stated that his
26
27
actions were taken out of context and that he has the right to voice his opinion
28 about the wrong doings of the Department. Mr. Waszczuk has a very negative

Page 223 of 224
1 opinion about the department and the management team's behavior, along with
2 the UCDI-IS Human Resources department. While some of the circumstances
3 Mr. Waszczuk presented are concerning, this does not excuse his aggressive
4 conduct towards individuals in the Department. Ills failure to follow direct
5
instructions and ignore University policy is not excused by his perceived
6
retaliation. After meeting with him and my careful review of the documents
7
provided to me, I find that there are reasonable grounds to believe Mr.
8
Waszczuk engaged in the conduct as charged and that the proposed action
9
should be upheld.
10 Sincerely,
Assistant Vice Chancellor
11 University of California, Davis
cc: Charles Wichter
12
620. Regardless of Tollefson’s motivation and order he got from the
13
Defenadats , he grossly violated the Skelly Law, depriving Plaintiff the opportunity to find any
14
employment.
15
16
“In Skelly v. State Personnel Board (1975) 15 Cal. 3d 194, the California
17 Supreme Court ruled that:
18
‘as part of constitutionally guaranteed due process, public employees are
19 entitled to certain procedural safeguards before discipline, which is
sufficiently severe to constitute a deprivation of a liberty or property right is
20 imposed on them. The constitutionally protected liberty interests requiring
Skelly protections arise whenever the allegations against an employee are
21 sufficiently onerous to seriously impact the employee’s ability to find future
work in his/her chosen career.’”
22
23
621. Skelly Reviewer Allan Tollefson held a meeting with UCDHS HR Labor
24
Relation Manager Travis Lindsey on September 24, 2012 and was coached on what decision
25
was expected from him in Plaintiff’s case.
26
622. Just before Plaintiff’s loss of employment, Plaintiff lost his house on a short sale
27
28
and rented a house so as not to deal with a mortgage company during his unemployment.

Page 224 of 225
1 December 18, 2012- Plaintiff’s Benefits upon Termination of Employment
2
3 623. On December 18, 2012, Plaintiff sent an e-mail inquiry to USDHS HR Labor
4 Relation Consultant Gina Harwood for clearance to enter the HR building on December 20,
5
2012 to take care of his remaining benefits upon termination of employment:
6
Subject: Meeting with Janette Manuel in the Ticon III Bldg. on 12/20/2012 at 9:00
7
Hi Gina:
8
Would you please provide me clearance with UCDPD to go to Ticon III
9
Bldg. on 12/20/2012 at 9:00 a.m. for a meeting with Janette Manuel?It
10
came to my attention that the UCDPD “Most Unwanted” police warrant
11
with my photos is still hanging in the HVAC shop and probably in other
12
UCDMC places. I don’t want be shot by in the back by Lt. James
13
Barbour’s forces for entering the Ticon III Bldg. to discuss my benefits
14
15 upon termination of my employment.
16 I appreciate your prompt response in this matter.
17 Jerry
18 436. Gina Harwood responded,

19 “Hi Jerry: There is no problem with you attending a meeting on Thursday
20
in HR. Please let me know if you have any other questions.
21
Gina”
22
624. On December 20, 2012, Plaintiff, who was not yet eligible for early Social
23
Security benefits at age sixty one and half , signed all necessary documents to cash out and
24
transfer to an IRA account his University Retirement money. Plaintiff estimated that it will let
25
him get by for another three years, without additional income equal to what Plaintiff was making
26
as a University of California employee.
27
28

Page 225 of 226
December 16, 2012 – Plaintiff’s Application for Unemployment Insurance Benefits with State
1 of California Employment Development Department
2
625. Nine days after receiving a letter of employment termination, Plaintiff filed an
3
application for unemployment insurance benefits with the State of California Employment
4
Development Department (EDD).
5
626. The Defendant in outrageous disregard of the February 2009 Settlement–
6
7 Agreement signed with Plaintiff and in disregard of Plaintiff’s outstanding working record ,
8 slandered and defamed Plaintiff with the Employment Development Department, thus causing
9 denial of Plaintiff’s unemployment insurance benefits by EDD.
10 627. By the reckless, despicable and inhumane Defendant’ continuous attack aimed at
11 Plaintiff, the Defendant caused Plaintiff additional enormous stress, anxiety and financial harm
12 in the period when Plaintiff was not eligible yet for earlier Social Security Benefits and was
13 awaiting to cash out his University Retirement money and transfer it to an IRA account.
14 628. Plaintiff’s unemployment insurance benefits case is pending in the State of
15 California Court of Appeal 3rd Appellate District, Case Caption Waszczuk v. California
16
Unemployment Insurance Appeal Board No. C079254, the County of Sacramento Superior
17
Court Case No. 34201380001699CUWMGDS.
18
JANUARY 2013
19
20 January 3, 2013- Plaintiff’s Step I Complaint Pursuant to the UC Davis Complaint Resolution
Policy PPSM 70.
21
22 629. On January 3, 2013, Plaintiff filed the Step I Complaint pursuant to the UC Davis
23 Complaint Resolution Policy PPSM 70. The Step I complaint was the initial appeal from the
24 Defendant’ decision terminating Plaintiff’s employment on December 7, 2012.
25 630. The termination letter stated that Plaintiff has rights to request review of the
26 Defendant’ employment action under Personnel Policies for Staff Members 70 - Complaint
27
Resolution.
28

Page 226 of 227
1 631. Plaintiff at first did not have the intention to file a complaint under the UC Davis
2 Policy PPSM due to the fact that Plaintiff already sent a 23-page brief to the Skelly Reviewer in
3 December and made a complaint wherever it was possible and the another complaint would have
4 the same effect as the previous one.
5
632. Plaintiff was on the edge of a major nervous breakdown and was worried about
6
getting a heart attack after Plaintiff lost his employment income, house medical insurance and
7
other benefits and felt that filing another complaint just nonsense and futile.
8
633. Since February 2009, Plaintiff was employed by the Defendant pursuant to the
9
Settlement–Agreement that the Defendant signed with Plaintiff after the Defendant were
10
defeated by Plaintiff in the 2008 arbitration process. The Defendant not only violated and
11
breached the Settlement-Agreement they signed with Plaintiff, but despicably violated Plaintiff’s
12
constitutional rights, employee, civil and human rights beyond anyone’s imagination and beyond
13
the signed Settlement-Agreement.
14
15 634. Plaintiff’s mind was and still is constantly and unstoppably occupied by the
16 Defendant’ criminally minded May 31, 2012 provocation. Undoubtedly it was the Defendant’
17 goal to kill Plaintiff or end his employment in the UC Davis Medical Center Trauma Unit # 11.
18 Plaintiff is still obsessively thinking about and can’t get it out of his mind because the Defendant
19 never in one word in any document address their own disgraceful, despicable and criminally
20 minded action against their own employee, who provided service for the Defendant for 13 years
21 and almost ended his employment in death.
22 635. Plaintiff expressed and emphasized his feelings about the Defendant’ way to
23 resolve the labor dispute with Plaintiff in the cover letter to the Step I Complaint Plaintiff sent to
24
UCDHS HR Labor Relation Consultant Gina Harwood on January 2, 2013.
25
636. Together with a cover letter, Plaintiff sent to Gina Harwood a copy of the
26
February 2009 Settlement–Agreement, the copy of Plaintiff’s Brief for Oral Arguments sent by
27
Plaintiff to Skelly Reviewer, UC Davis Associate Vice Chancellor Allen Tollefson, on
28

Page 227 of 228
1 November 12, 2012, copies of complaint letters dated July 17, 2011 and July 24, 2011 that
2 Plaintiff sent to UC Davis Chief Counsel Steven A. Drown, who signed the February 2009
3 Settlement–Agreement with Plaintiff on the Regents of the University of California’s behalf. In
4 the cover letter to Gina Harwood, Plaintiff wrote:
5
(Note: to avoid any confusion or misunderstanding, Plaintiff’s letter Gina Harwood was
6 corrected by a professional proofreader.)
7
Re: The Letter of Termination Dated December 5, 2012- Request
8 for Review under PPSM 70.
9 Dear Mrs. Harwood:
10
The Letter of Termination issued by Mr. Witcher states:
11
“You have the right to request review of this action under Personnel Policies
12
for Staff Members 70 - Complaint Resolution. If you wish to request review of
13
this action, you must do so in writing, using the appropriate complaint form. A
14
written request must be received in the UCDHS Employee & Labor Relations
15
office no later than thirty (30) calendar days from the date of this letter.”
16
I did not have any intention to follow the Letter of Termination advice and file
17
a request for review with the HR Labor Relation Office, which has caused the
18
termination of my employment with University of California after 13 years of
19
20 service.
21 I was sure that filing a request for review under PPSM 70 would be
22 unnecessary and a redundant action on my part, since I already submitted a 23-
23 page brief for the Oral Response to The Notice Intent to Dismiss dated
24 September 25, 2012, which includes hundreds of pages of exhibits to UC

25 Davis Skelly Reviewer Mr. Allen Tollefson.
26 My detailed objection and direct explanation in the meeting with Mr. Tollefson
27 as to why my employment is subject of wrongful termination did not change
28

Page 228 of 229
1 anything, and my employment was terminated anyway.
2 After I received the final Letter of Termination of my employment, my intent
3 was to write a Letter of Condemnation to the Skelly Reviewer & UC Davis
4 Assistant Vice Chancellor Mr. Allen Tollefson for his “Sergeant Shultz, I see
5
nothing, I hear nothing, I read nothing” decision (reference to the “Hogan’s
6
Heroes” TV serial about WW II).
7
The multiple complaints I filed and complaint letters I wrote to various UC
8
officials in the period of more than one year, as well as the abovementioned
9
brief I submitted to the Skelly Reviewer, caused me to believe that I
10
completely exhausted the University administrative remedies other than taking
11
further legal court action against UC Regents for wrongfully terminating my
12
employment.
13
However, during my preparation to the wrongful termination court action
14
15 against the University of California, I reviewed the State of California and
16 Federal Court cases in relation to employees’ wrongful terminations.
17 Three of the cases that I reviewed caught my attention, and this is why I have
18 decided to file a request for review under the PPSM 70. I have to be certain
19 that I would not be precluded to file the wrongful termination lawsuit or else I
20 will be defeated like the two Plaintiffs in Janet Campbell v. Regents Of The
21 University of California S113275; Ct.App.1/1 A097560; San Francisco Super.
22 CT. No. 312736 and Patricia M. Palmer v. Regents Of The University of
23 California 2nd App. Div.7 B154868; Los Angeles County Super. Ct. No.BC
24
187036.
25
The third case is the newest wrongful termination lawsuit, which is interesting
26
because of the astronomical jury verdict for Plaintiff. The Ani Chopourian v.
27
Catholic Healthcare West wrongful termination case in Federal Court included
28

Page 229 of 230
1 nasty and intolerable working conditions, sexual harassment, and a violation of
2 section 1278.5 of California’s Health and Safety Code.
3 The astronomical $167 million dollar jury verdict against the defendant in the
4 case, as well as the lawsuit itself, have no relation to the University of
5
California or my employment termination”?
6
However, the astronomical jury verdict sent the strong message to the other
7
employers who are violating the law as well as their own established policies,
8
which outline that abusing power, harassing, and retaliating against employees
9
with legitimate complaints could result in stiff and astronomical penalties
10
The Ani Chopourian v. Catholic Healthcare West case makes me wonder how
11
severe the jury verdict would have been if, besides the wrongful termination
12
and sexual harassment, Ani Chopourian’s employer set a trap to provoke, kill,
13
or send her to the hospital’s trauma unit badly injured like my employer
14
15 planned to do with me on May 31, 2012.
16 The date of May 31, 2012 constantly occupies my mind with unanswered
17 questions and thoughts in relation to the ill-planed UCDMC HR “Death
18 Squad” provocation and assault me with deadly force.
19 Would I have survived or would have been disabled for the rest of my life if I
20 survived? If I was taken to the UCD Trauma Unit, would my IV be filled with
21 toxic doses of drugs that could have contraindicated the medicines I am
22 currently taking, since the UCD wouldn’t know my medical history? Would I
23 become part of a deadly and illegal medical experiment? Ani Chopourian is
24
not asking herself these questions. I do not wish anybody to have his/her mind
25
occupied by such trauma that the UC Davis Medical Center Human Resources
26
Department caused me. “Sometimes I think that I should have never asked for
27
the documents that I received under the Public Record Act because of how
28

Page 230 of 231
1 close to the cemetery or UC Davis Medical Center Trauma Unit I actually
2 came.”
3 The two abovementioned lawsuits for wrongful terminations against The UC
4 Regents have addressed a lot of mandatory administrative remedies and
5
damages mitigation with UC. I surely exhausted all remedies by complaining
6
about the violation of public policies by my employer. I am unsure how I will
7
mitigate anything with my employer, who signed with me a Settlement–
8
Agreement in 2009. Two years later, the signed Settlement–Agreement was
9
trashed by my employer, and the special safari to hunt down and kill a 60-year-
10
old employee in April 2011 began. It is horrible to think about.
11
The outrageously fabricated and malicious accusations, lies, allegations, and
12
assertions against me by the HR Investigators show how meaningless the UC
13
Policies are for those who are unscrupulously and cruelly violating the laws
14
15 and human and employee rights; they are also abusing the power given to them
16 by the UC System
17 The UCDMC HR Investigators’ malicious lies were converted into accusations
18 in the Letter of Suspension. The May 31, 2012 death trap, the Notice Intent to
19 Dismiss, and, finally, the Letter of Termination dated December 5, 2012

20 further proved the UCDMC management’s malice and outrageous abuse of
21 power in dealing with labor relation issues and violations of law and UC
22 Policies.”
23 The UCDMC and UC Davis Campus Compliance and Internal Audits Offices
24
covered up and gave the green light for UCDMC Management to abuse its
25
power and violate the law and UC Policies. This is so obvious and well
26
documented in this case that the jury will have no problems reaching a verdict
27
and providing a special message to the UC Regents.
28

Page 231 of 232
1 “The “Wedge Extractor” (Gerry Preciado) was hired by the “HR Death Squad”
2 leader , UCDHS HR Executive Director Stephen Chillcot after the Notice of
3 Intent to Terminate my employment, which was only a desperate act to
4 downplay, minimize, and apply the smoke screen for the serious problems
5
caused by the UCDMC PO&M and HR Department regarding Labor Relations
6
issues and matters.”
7
I read the “Wedge Extractor’s” Report which is a perfect reason to file another
8
complaint under the UC meaningless Whistle Blowing Policy for misuse and
9
abuse of UC resources and monies to cover up the UCDMC management’s
10
abuse of power and public policies violation.
11
Instead of hiring a “Wedge Extractor,” Mr. Chillcot should extract himself
12
from his office, along with other HR “Death Squad” members who willfully—
13
and without the pressures from their superiors—participated in the ill-minded
14
15 and planned deadly assault on Waszczuk May 31, 2012. Without a doubt, it
16 would help UC Regents avoid costly litigations in the future.
17 Attached is the Complaint/Request for Review – Letter of Termination,
18 dated December 5, 2012.
19 Sincerely,
Jaroslaw Waszczuk
20
CC: UC President Mark Yudof, UC Regents, UC Davis Chancellor Lynda Katehi,
21 and UC Davis Vice Chancellor Ralph Hextler.
22
23
January 3, 2013 –Addendum to the Wrongful Termination Complaint PPSM 70 Step I Appeal
24
638. In the Step I Complaint and the addendum to the complaint, Plaintiff
25
alleged as follows.
26
27 a) University policy or procedure violated (if any).

28

Page 232 of 233
1 Nondiscrimination in Employment (PPSM 12); the University of California
2 "JUST CAUSE" doctrine. PPMS 380 Section 17(E). Improper Governmental
3 Activities/Whistleblower Protection. Abuse and wrongfully applying the
4 doctrine of “Preponderance of Evidence". UCDHS Policy 1616 and 380-15
5
In addition to the already mentioned violation of the UC Policies the
6 UCDMC Management violated the following State and California and
Federal Law by wrongfully firing Waszczuk
7
Fair Employment and Housing Act, Government Code 12900; National Labor;
8
Title VII. Civil Rights Act of 1964: 42 U.S.C. 2000e-3(a) Relations Act, 29
9
U.S.C. 158(a)(4); Fair Labor Standards Act of 1938: 29 U.S.C.
10
215(a)(3);Occupational Safety and Health Act of 1970 OSHA; 29 U.S.C.
11
12 660(c);Fair Employment and Housing Act (FEHA) Anti-Retaliation
13 Provisions: Gov. Code Section 12940(3);California Occupational Safety and
14 Health Act of 1973 (CaU0SHA) Anti Retaliation Provisions;Labor Code
15 Sections 6310-6312; Right of employees to disclose information to
16 government or law enforcement agency; Labor Code Section 1102.5 and Right
17 of state employees to blow whistle Gov. Code Sections 10543.
18 ADDENDUM TO THE WRONGFUL TERMINATION COMPLAINT
19 De sc r i be y o ur c o m p la i n t i n de ta i l , i nc l u d i ng t he fo l lo w i ng
fiv e po i n ts . Atta c h a d di tio na l s he e t s if ne e de d .
20
3. How did the management act violate policy or procedure?
21
22 The termination of Waszczuk’s employment is a malicious and gross
23 violation of law and is pure and undisputable retaliation against Waszczuk for
24 exposing and reporting University of California Davis Medical Center managers
25 and supervisors who were suspected of committing illegal activities, as he called

26 attention to their unspeakable violations of University of California policies as
27 well as of state and federal law. Waszczuk’ May 2012 suspension without pay
28

Page 233 of 234
1 and his subsequent termination of employment is based on the fabricated lies
2 and accusations of his supervisors, some of Mr. Waszczuk’ coerced coworker
3 and UCDMC human resource (HR) investigators along with Mr. Waszczuk’
4 taken-out-of-context statements in his correspondence with various UC
5
managers, executives, and investigators.
6
2009 SETTLEMENT- AGREEMENT VIOLATION BY THE UCDMC
7 MANAGAMENT
8 The UCDMC management by firing Waszczuk from his job breached and
9
violated the 2009 Settlement-Agreement between Waszczuk and the Regents
10
of the UC. As early as of July 2011. Waszczuk submitted two letters of
11
complaint to the UC Davis campus Chief Counsel Mr. Steven A. Drown and
12
asked him to advise violators of the signed Settlement-Agreement to stop
13
assaulting Waszczuk and to restore order in Waszczuk’ workplace. The letters
14
dated July 17 and 24, 2011 are self-explanatory, and no reason exists to
15
elaborate further about my employment malice in relation to the settlement –
16
agreement. It is only appropriate to mention that Mr. Drown as the UC Davis
17
chief counsel signed the mentioned agreement on behalf of the UC Regents.
18
19 Mr. Drown was obligated to act to prevent further violation of the agreement,
20 unthinkable harassment, and retaliation which almost ended in UC Davis
21 Police’s assaulting Waszczuk with a deadly weapon on May 31, 2012, as well
22 as Waszczuk’ unwarranted employment termination on December 7, 2012.
23 The UC “Just Cause” Doctrine

24 The UC Davis Health System (UCDHS) Web Page States:
http://www.ucdmc.ucdavis.edu/hr/hrdepts/labor_relations/just_cause.html
25
"Just cause" is the guiding principle that we utilize as a public employer
26
27 whenever we engage in some form of corrective action or progressive discipline
28 for our employees. Supervisors are always expected to have "just cause" when

Page 234 of 235
1 disciplining an employee.
2 My Response :
3 I am not sure as to whether the supervisors who have caused me so much pain
4 and suffering since April 2011 understands the meaning of the “just cause”
5
doctrine, taking into consideration that they covered up their severe
6
misconduct, including and not limited to dishonesty misappropriation of
7
university property, and acts to endanger others.
8
Furthermore, the doctrine of just cause requires that management rules, orders,
9
and disciplinary actions be applied in a consistent and nondiscriminatory
10
manner. I do not know how any employee could expect nondiscriminatory
11
discipline action from a manager or supervisor who is stalking his subordinate
12
from a dark office and with a company camera or who his violently attacking
13
his subordinate in a university cafeteria.
14
15 I will leave to my attorney the further interpretation of the UCDHS just cause,
16 Preponderance of Evidence Doctrine PPSM 23 and other policies in relation to
17 my employment termination on December 7, 2012.
18 Besides the above, the UCDMC is accredited by The Joint Commission, a
19 not for-profit organization dedicated to raising the level of safety and

20 quality of care in all health care settings.
21 The UC Davis Center for Professional Practice of Nursing pamphlet “What's
22 New in 2011” states that “[t]he Medical Center does not take disciplinary
23 action or retaliate against an employee for bringing forward quality of care
24
and patient safety concerns.”
25
In the same year Waszczuk on July 11,2011wrote to UCDMC HR Director
26
Stephen Chillcot:
27
“I was not aware that Gina Harwood gave unintentionally the green light and
28

Page 235 of 236
1 blessing to my managers for alternation of my duty and the sabotage of my job.
2 Her decision added so much high BTU fuel to the fire, and this fire needs to be
3 extinguished as soon as possible for the benefits of UCDMC, involved parties
4 in the conflict, and especially for the benefit of the hospital patients who can't
5
be put at risk because the war is going on in PO&M Department HVAC
6
[Heating, Ventilation, and Air Conditioning] Shop. I really don't care what is
7
going to happen to me, but I am really concerned about hospital patients’ care
8
in relation to my duty.”
9
One year later, the same Mr. Chillcot with his new “henchman on the block,”
10
Travis Lindsey, not only retaliated against an employee who reported UCDMC
11
management’s wrongdoing but also engaged in activities as a UCDMC HR
12
“Death Squad” leader in an effort to commit a heinous crime for the sake of
13
protecting UCDMC management’s false image as well as to protect the fat
14
15 paychecks that he and others were receiving regardless of their qualifications
16 to lead.
17 I am so traumatized when I think about the UCDMC trauma unit, which was
18 ready for me on May 31, 2012.
19 However, today I am less surprised about Mr. Chillcot’s war game, after the
20 newspapers and television (TV) news have announced that under the
21 supervision of humanitarian off the Year, Mrs. Claire Pomeroy and UCDMC
22 CEO Mrs. Ann Madden Rice, the UCDMC created an oasis for neurosurgeons
23 whose activities were closely akin to Dr. Mengele’s from the Auschwitz Death
24
Camp—characterized by ill-minded illegal medical experiments. The only
25
difference was that Dr. Mengele was declared a war criminal and sentenced to
26
death in absentia. The two UCDMC “Mengeles” were fired from their jobs,
27
and Mrs. Pomeroy resigned from her position under false pretenses. Mrs. Rice
28

Page 236 of 237
1 still maintains her throne.
2 If I read today the statement about The Joint Commission in Director Robert
3 Taylor’s e-mail dated July 11, 2009, entitled “Antarctica Presentation” and his
4 unusual and reported past relationship with Dorin Daniliuc , which still awaits
5
clarification, I sometimes think that it was the reason I came under vicious
6
attack in 2011 and was fired in December 2012.
7
If I think today about Mr. Hugh Parker’s action in the Managing Stress
8
classroom on May 30, 1951, I understand today why I had to leave the
9
classroom. It was impossible for Mr. Parker to let me stay in the classroom
10
with my two coworkers: It would screw up his and others’ plans for an ill-
11
planned provocation and my departure to the UCDMC trauma unit one day
12
later. It is worth mentioning that Mr. Parker is an HR workers compensation
13
manager who helps employees who are hurt on the job. I did not know that Mr.
14
15 Parker was dedicated to helping me to acquire disability and to serving me his
16 workers compensation papers in the UCDMC trauma unit.
17 I am not sure what more should I write in this final complaint under PPSM 70.
18 I am so traumatized and stressed out, but thanks to God, I escaped the May 31,
19 2012, attack unharmed and I am still alive.

20 Should I write about Lt. James Bolfour’s and Mr. Dennis Curry threatening e-
21 mail; Ms. Danesha Nichol’s , Mr. Brent Seifert’s, and Ms. Cindy Oropeza’s
22 libelous and full-of-lies reports; my coworkers’ complaints about the same
23 managers; the letters of recognition that Mr. Dereck Cole received; and finally
24
the documents I received under the California Public Records Act? I think I
25
covered most everything in my previous correspondence and complaints, and
26
the rest I will leave to be resolved in a court of law if my employer will not
27
mitigate and resolve this wrongful termination of my employment before I file
28

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1 the lawsuit. So far, I do not see any good will or faith on the part of UC to
2 make any move in the right direction and to end the conflict. For the record, I
3 deny and condemn all allegations in the PO&M manager Mr. Charles
4 Witcher’s intent-to-dismiss notice dated September 25, 2012; the Skelly
5
Reviewer Mr. Tollefson’s opinion dated December 3, 2012; and the
6
termination letter dated December 5, 2012, as baseless, groundless, malicious,
7
acts of oppression and unthinkable in work place retaliation.
8
5. How were you adversely affected?
9
The termination of Waszczuk’ employment after 13 years of service and five
10
years prior to his Social Security retirement were done with the malicious
11
intention of causing Mr. Waszczuk financial harm and severe emotional
12
distress and were done with a willful and conscious disregard of the likelihood
13
of causing Waszczuk such distress.
14
15 The conduct of management especially stalking Waszczuk and holding him
16 hostage in his own home by abusing the UC Investigatory Leave Policy;
17 suspending Waszczuk without pay; plotting to kill or severely harm Waszczuk
18 on May 31, 2012; and finally terminating his employment on December 7,
19 2012 did, in fact, cause Waszczuk to suffer severe emotional distress,

20 embarrassment, humiliation, pain and anguish, stress, and depression. The
21 conduct of management further caused Waszczuk’s loss of present and future
22 income, significant decreases in his UC retirement fund, and other incidental
23 and consequential damages and expenses, not to mention the enormous stress
24
that Mr. Waszczuk’s wrongful termination has caused his spouse as well.
25
The conduct of management was extreme and outrageous; was done in a
26
malicious, fraudulent, and oppressive manner; was intended to injure
27
Waszczuk; was executed with an improper and evil motive amounting to
28

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1 malice and spite stemming from management's failure to adequately
2 represent Waszczuk and was done in conscious disregard of Waszczuk's
3 employee and civil rights. The Settlement-Agreement that Waszczuk
4 signed with the UC Regents in February 2009 became a worthless piece of
5
paper. The position and job duty outlined in the Settlement-Agreement was
6
given to a person who was a relative of the reported child pornography
7
felon who illegally and in violation of his parole accessed the UCDMC
8
computer. In this matter, the HVAC shop supervisors openly and with full
9
knowledge participated in allowing the felon who was convicted twice of
10
child pornography to violate his court parole by letting him access a
11
company computer on UCDMC premises. The mentioned individual
12
previously was fired from UCDMC and should be restrained from being
13
present on UCDMC premises without a valid reason. Instead, the UCDMC
14
15 investigator has ignored and covered up the entire issue in her report.
16 Waszczuk’s coworker experienced outrageous retaliation for reporting the
17 presence of a child pornography felon on company premises, and
18 Waszczuk believes that the father of the convicted child pornography felon
19 was promised to have Mr. Waszczuk’s job and position a long time before
20 April 2011. This was yet another reason to retaliate against and harass
21 Waszczuk as well as to later terminate his employment.
22 6. Resolution Requested
23
24
Waszczuk is requesting in good faith the following resolution to end the
25
conflict without further costly litigations.
26
After receiving and reviewing my request/complaint, the UC immediately
27
shall restore my employment in the spirit of the signed 2009 Settlement-
28

Page 239 of 240
1 Agreement with the UC Regents with an increased salary to $82,000/year
2 and all of the benefits that Mr. Waszczuk had prior to the termination of
3 his employment.
4 For the enormous amount of emotional distress inflicted on Waszczuk as a
5
result of the malicious and ill planned provocations and planned May 31,
6
2012, assault on Waszczuk with deadly force, which will probably occupy
7
his mind for the rest of his life, Waszczuk is requesting from the UC
8
compensation in the amount of $10,000,000 dollars (10 million dollars).
9
The amount of the requested compensation looks and sounds big.
10
However, if taking into consideration the astronomical jury award in the
11
Ani Chopourian v. Catholic Healthcare West lawsuit and the reason
12
behind the astronomical compensation for harassment and retaliation in
13
that case, Waszczuk should be awarded at least twice what Plaintiff was
14
15 awarded in Ani Chopourian v. Catholic Healthcare West in his wrongful
16 termination case goes to court.

Respectfully Submitted on January 3, 2013
17 Jaroslaw Waszczuk - Grievant
CC: UC Regents, UC President Mark Yudoff, UC Davis Chancellor Linda Katehi,
18 UC Davis Vice Chancellor Ralph Hexter
19 639. Plaintiff’s Grievance was confirmed by UCDHS HR Labor Relations on
20 January 8, 2013 with assigned Case No. 03-PPS-014-12/13.
21 January 19, 2013- UC Davis PPSM Step II Decisions in the unwarranted Letters of
Expectation Plaintiff’s coworkers William Buckans, Kenny Diede and Dereck Cole were
22 attacked by UC Davis Management in May and August 2012.
23 640. On or around January 19, Plaintiff received from UCDHS HR Labor
24 Relation the Step II Appeal- decisions for the complaints Plaintiff filed on his three coworkers,
25 Kenneth Diede, William Buckans and Dereck Cole were served in May and August 2012.
26 Plaintiff provided representation for the mentioned coworkers pursuant to UC Davis Compliant
27 Resolution Policy PPSM 70.
28

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1 641. The Step I Appeals were denied for Kenneth Diede, William Buckans and
2 Dereck Cole by UCDHS Plant Operation and Maintenance Manager Charles Witcher, who
3 signed the Letter of Termination of Plaintiff’s employment, which was served to Plaintiff on
4 December 5, 2012.
5
642 On December 4, 2012, Plaintiff as a representative held a Step II appeal
6
meeting on the UC Davis Campus with the UCDHS HR assigned Compliant Resolution Officer
7
(CRO), retired UC Davis HR Director Elizabeth A. Mayer.
8
643. Magically, Elizabeth A. Mayer reversed Charles Witcher’s decision
9
who denied the Step I Appel and Meyer ruled in favor of Kenneth Diede, William Buckans and
10
Dereck Cole.The letter of expectation served to Dereck Cole which was very similar to the
11
Notice of Employment termination. The Elizabeth Mayer’s decisions made Plaintiff believe that
12
the Defendant successfully manipulated Plaintiff, to distract him by attacking Plaintiff’s
13
coworkers to divert Plaintiff’s attention from the Defendant’ more serious misconduct and
14
15 violation of law, for which disclosure would have more serious consequences.
16 February 2013
17
18 February 1, 2013- PPSM 70 Step I Appeal Decision in Plaintiff’s Dismissal
19 Case No. 03-PPS-014-12/13

20 644.. On February 1, 2013 Plaintiff received from UDHS HR Labor Consultant
21 Gina Harwood PPSM the Step I appeal decision in Plaintiff’s dismissal Case No. 03-PPS-014 -
22 12/13. Gina Harwood’s cover letter stated:
23 Grievant: Jaroslaw Waszczuk
File Number: 03-PPS-014-12/13
24 Issue(s): Dismissal
Please consider this the University's Step I response to the above referenced
25
26 complaint. The complaint alleges that your dismissal from employment was a
27 violation of University policy and did not follow the just cause standard. The
28 requested remedy is reinstatement to your position with a salary increase and

Page 241 of 242
1 compensation in the amount of $10,000,000.
2 Your complaint was submitted to Thomas Rush, Manager, Facilities Design
3 and Construction for review at Step I. Mr. Rush has reviewed the complaint
4 and supporting documentation and has issued his response, see attached. Ms.
5
Rush did not find that your dismissal was a violation of University Policy and
6
finds that your dismissal was appropriate. The complaint and requested
7
remedies are denied.
8
You have the right to appeal this decision to Step II of the Complaint
9
Resolution Process. Your written appeal must be received in our office within
10
30 days from the date of this response. If you choose not to submit an appeal,
11
the complaint will be closed based on this response.
12 Sincerely,
Gina Harwood, SPHR
13 Attachment: Step I response
Proof of Service
14 Cc: Complaint File
Charles Witcher
15
16
645. The actual three-page Step I Appeal Review was signed by USDHS
17
18 Manager of Facilities Design and Construction Thomas Rush, whom Plaintiff never heard of or
19 met. Normally Step I Appeal is reviewed by the Department Head, which was Charles Witcher,
20 who signed the termination letter. In such a situation, HR, by writing the review, had to insert a
21 different name than the Department Head name.
22 646. Thomas Rush was a subordinate and colleague of the USDHS Facilities
23 Design and Construction Executive Director Mike Boyd, who in July 2011 also became Director
24 for the UC Davis Medical Center Plant Operation and Maintenance Department and became the
25 direct superior of Charles Witcher and indirectly Plaintiff superior. It was no coincidence that
26 Thomas Rush’s name was selected for Step I review. It is the second time Mike Boyd’s
27
subordinate was assigned to review Plaintiff’s appeal. First was Michael Pansious in May 2012,
28

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1 to review the 10 days’ suspension without pay served to Plaintiff, as a lure to provoke and kill
2 Plaintiff, on May 31, 2012.
3 647. If Thomas Rush actually wrote the decision in Step I, then he
4 somehow forgot to mention in his decision the supportive documents that Plaintiff provided with
5
his Step I Appeal, which included the February 2009 Settlement–Agreement that Plaintiff signed
6
with the Regents of the University of California (Defendant), the copy of Plaintiff’s Brief for
7
Oral Arguments sent by Plaintiff to Skelly Reviewer, UC Davis Associate Vice Chancellor Allen
8
Tollefson on November 12, 2012, and copies of complaint letters dated July 17, 2011 and July
9
24, 2011 that Plaintiff sent to UC Davis Chief Counsel Steven A. Drown, who signed the
10
February 2009 Settlement–Agreement with Plaintiff on the Regents of the University of
11
California’s behalf. It is possible that Gina Harwood did not bother to provide the mentioned
12
documents to Thomas Rush. It would probably not make any difference anyway and he would
13
write what he was told to write, or it was written for him by Gina Harwood or HR’s other
14
15 attorney. The Thomas Rush decision is even worth to be pasted into this amended complaint.
16
17 February 28, 2013- Plaintiff’s Step II Appeal PPSM 70-Dismisal
18
19 648. On February 28, 2013, Plaintiff filed a Step II Appeal from the December 7, 2012
20 Employment Termination Pursuant to UC Davis Policy PPSM 70 asking $10,000,000 for the
21 unthinkable psychological tortures that Plaintiff experienced from the Defendant in one year and
22 a half of inhumane prosecution and attempts to provoke and kill Plaintiff. In his 19 –page
23 appeal , Plaintiff just vented out his stress and anger knowing that any appeal will not do Plaintiff
24
any good after the Defendant attempted to provoke and kill Plaintiff and UC Davis Police issued
25
and distributed around UC Davis Campuses the “Most Unwanted Persona Non Grata” poster
26
with Plaintiff’s photo and description on it.
27
649. In conclusion of the Step II Appeal request, Plaintiff wrote:
28

Page 243 of 244
1 “CONCLUSION
2 In conclusion, I would like to say that I survived communism, a

3 communist prison, and Witcher’s assault on me in 2007, and I will survive
4 this wrongful and unjustified employment termination after 12 years of
5
service.”
6
7
MARCH 2015
8
9
March 7, 2013 – Plaintiff’s Whistleblowing Retaliation and Interference Complaint with UC
10
Davis Vice Chancellor and Provost Office
11
12 650. On March 7, 2013, Plaintiff filed a Whistleblowing Retaliation and
13 Interference Complaint with the UC Davis Vice Chancellor’s Office due to Plaintiff’s protected
14 activities by the GOVERNMENT CODESECTION 8547-8547.13, which states:
15 8547.10. (a) A University of California employee, including an officer or
16 faculty member, or applicant for employment, may file a written complaint
17 with his or her supervisor or manager, or with any other university officer
18 designated for that purpose by the regents, alleging actual or attempted acts of
19
reprisal, retaliation, threats, coercion, or similar improper acts for having made
20
a contents of the written complaint are true, or are believed by the affiant to be
21
true, under penalty of perjury. The complaint shall be filed within 12 months of
22
the most recent act of reprisal complained about.
23
(b) Any person who intentionally engages in acts of reprisal, retaliation,
24
threats, coercion, or similar acts against a University of California employee,
25
including an officer or faculty member, or applicant for employment for
26
having made a protected disclosure, is subject to a fine not to exceed ten
27
thousand dollars ($10,000) and imprisonment in the county jail for up to a
28

Page 244 of 245
1 period of one year. Any university employee, including an officer or faculty
2 member, who intentionally engages protected disclosure, together with a sworn
3 statement that the in that conduct shall also be subject to discipline by the
4 university.
5
6
651. Plaintiff with his Whistleblowing Retaliation and Interference complaint
7
form submitted to the UC Davis Vice Chancellor’s office a 35-page brief, 1500 pages of
8
supportive documents and a cover letter, which stated:
9 ‘March 7, 2013
The Honorable Ralph J. Hexter
10 Provost and Executive Vice Chancellor
Mrak Hall, Fifth Floor
One Shields Avenue
12 Davis, CA 95616
13 Re: Retaliation and Interference Complaint
14 Dear Vice Chancellor Hexter,Enclosed is a copy of my Retaliation and
15 Interference Complaint against certain individuals who are managing the UC
16 Davis Medical Center in Sacramento, California, where I was employed for
17 over thirteen years and where my employment was abruptly and without valid
18
and legitimate reason terminated on December 7, 2012.
19
In addition to the managing officers at the UC Davis Medical Center, who are
20
included in the complaint, UC Davis Chief of Police Matt Carmichael and his
21
subordinate, Lieutenant James Barbour, are included in the complaint for
22
alleged act(s) of provocation and conspiracy with other individuals listed in the
23
complaint in an attempt to murder me on May 31, 2012 or send me to the UC
24
Davis Medical Center Trauma Unit in a state of extreme harm.
25
It is very disturbing—even unthinkable—that UC Davis leaders should
26
use the UC Davis Police Department to resolve labor disputes with
27
28 employees who are making complaints. The original Retaliation and

Page 245 of 246
1 Interference Complaint included approximately 1,500 pages of documents and
2 photos that I sent to your office yesterday by U.S. Certified Mail.
3 I would like to inform you that I am representing myself in this matter until
4 such time as I decide to hire an attorney at law.
5
If you have any questions or concerns, the University of California Legal
6
Counsel or other investigators may contact me at their convenience in the
7
event that you decide to review the complaint and investigate the allegations.
8 Best Regards
Jaroslaw Waszczuk
9 CC: UCDMC Principal; HR Labor Relations Consultant Gina Harwood; UC
President Mark Yudof; UC Regents Office; UC Davis Chancellor Linda Katehi”
10
11 652. In June 2013, Plaintiff Whistleblowing Retaliation and Interference Complaint

12 was transferred from the UC Davis Vice Chancellor’s and Provost office to the UC Office of the
13 President (UCOP) Ethics, Compliance and Audit Services.
14 653. The UC Office of the President Principal Investigator Judith Rosenberg was assigned
15 to investigate Plaintiff’s Whistleblowing Retaliation and Interference Complaint.
16 654. The investigation was presided over by two UC Senior Vice Presidents, Sheryl
17
Vacca and Daniel Dooley.
18
655. Plaintiff met UCOP Investigator Judith Rosenberg twice. Plaintiff’s coworker
19
William Buckans witnessed the meetings. Investigator Judith Rosenberg was not very anxious to
20
investigate and she showed her feelings about. The UCOP Principal Investigator probably knew
21
that the Regents, Office of the President and UC Office of the General Counsel were responsible
22
for Plaintiff’s termination without knowing the cause.
23
656. One year later in June 2014, Judith Rosenberg issued her investigation Report,
24
which had nothing to do with any investigation. Judith Rosenberg repeated the defaming and
25
defacing statements made about Plaintiff by three previous investigators, Danesha Nichols, Brent
26
27 Seifert and Cindi Oropeza who portrayed Plaintiff far worse, as a two time convicted child
28 pornography felon who was illegally accessing UC Davis Medical Center HVAC shop

Page 246 of 247
1 computers while on parole.
2 657. In the one letter after the meeting with Judith Rosenberg, Plaintiff asked
3 her not to copy Danesha Nichols, Brent Seifert and Cindi Oropeza in her investigation and said
4 that Plaintiff liked to remember Rosenberg as a good person. This did not happen.
5
659. On September 10, 2014 more than 18 months after Plaintiff filed his 35-
6
page long Whistleblowing and Interference Complaint with 1500 supportive documents, Plaintiff
7
received a half-page decision signed by the UC Senior Vice President Daniel Dooley.
8
660. UC Senior Vice President Daniel Dooley wrote in his decision:
9 September 10, 2014
10 Re: Your Whistleblower Retaliation Complaint
11
Dear Mr. Waszczuk:
12
In my role as the Locally Designated Official (LDO) for the University of
13
14 California System, I have carefully reviewed the investigation report prepared
15 by Judith Rosenberg, who investigated your allegations of whistleblower
16 retaliation under the University's Whistleblower Protection Policy. While Ms.
17 Rosenberg found that you had made protected disclosures under the
18 Whistleblower Policy, she concluded that the preponderance of the evidence

19 did not substantiate your allegation that your protected disclosures were a
20 contributing factor in the University's decision to suspend you without pay
21 from May 16 to May 30, 2012, or in the University's subsequent decision to
22 terminate your employment. She further concluded that the University's
23
decision to place you on investigatory leave and the California Employment
24
Development Department's denial of unemployment benefits did not constitute
25
adverse employment actions.
26
I agree with Ms. Rosenberg's analysis and conclusions. In light of the
27
foregoing, it is my decision that you have failed to meet your burden of
28

Page 247 of 248
1 demonstrating by a preponderance of the evidence that you were subjected to
2 adverse employment action as a result of engaging in conduct protected by the
3 Whistleblower Protection Policy. I am therefore closing the University's file
4 with regard to your complaint.
5
Thank you for cooperating with the University's investigation.
6 Sincerely,
7 Daniel M. Dooley
Senior Vice President
8 Locally Designated Official
cc: Senior Vice President Vacca
9 Chief Compliance Officer Delmendo
10
11 661. The question is whether the UC Senior Vice President, who was overseeing Judith
12 Rosenberg, was aware of all the details of the case and why Plaintiff became a subject of such a
13 vicious retaliation from the Defendant, which lasted for more than a year and half and was
14 continued by the Defendant after Plaintiff’s termination through the State of California
15
Employment Development Department and the California Unemployment Insurance Appeal
16
Board than in State of California Sacramento of Sacramento Superior Court Department 23 with
17
Presiding Judge Hon. Shaleyanne Chang.
18
662. The University of California Office of the President (UCOP) Principal
19
Investigator Judith concluded her pseudo-investigation in Plaintiff’s Whistleblowing Retaliation
20
and Interference Complaint on June 23, 2013, which was a year and four months since Plaintiff
21
filed the complaint on April 7, 2013 with UC Davis Provost and Vice Chancellor Office.
22
663. Judith Rosenberg’s Confidential Investigation Report issued on June 23, 2014
23
was more or less a summary of the previous several fabricated reports as a cause for Plaintiff’s
24
25 May 2012 ten-day suspension without pay and employment termination on December 7, 2012.
26 664. Judith Rosenberg’s investigation report has nothing to do with any investigation
27 and was basically based on slanderous and libelous fabrication issued by UC Davis Health
28 System HR-assigned investigators, Danesha Nichols, Brent Seifert and Cindi Oropeza.

Page 248 of 249
1 665. The Judith Rosenberg Investigator Report was basically expanded Notice Intent to
2 Dismiss and the Skelly Reviewer, UC Davis Associate Vice Chancellor Allen Tollefson’s
3 decision, which provided for the Defendant’ false and outrageous justification for Plaintiff’s
5
666. Judith Rosenberg was the first University of California Official who mentioned
6
the February 2009 Settlement-Agreement that Plaintiff signed with the Regents of the University
7
of California, and the Settlement-Agreement guaranteed employment for Plaintiff as the
8
Associate Development Engineer; due to that, the Defendant were defeated by Plaintiff in the
9
arbitration process in 2008.The previous case or dispute arose for exactly the same reason as this
10
ongoing litigation with the difference that, in the previous dispute, Plaintiff was slandered
11
defamed, defaced, wrongly accused and wrongfully suspended and resigned by the Defendant.
12
667. The present litigation arose when Plaintiff was slandered, defaced,
13
defamed and wrongfully suspended and terminated by the Defendant.
14
15 668. Judith Rosenberg, in her investigation report on page 19, described in a
16 misleading way the February 2009 Settlement-Agreement that Plaintiff signed with the Regents
17 of the University of California as a cash settlement.
18 669. Judith Rosenberg, as the University of California Principal Investigator
19 and experienced attorney at law, was perfectly aware what the 2009 Settlement-Agreement was
20 about and how grossly and unscrupulously it was violated by the Defendant.
21 670. Judith Rosenberg was perfectly aware that the Defendant defamed,
22 defaced and libeled Plaintiff by issuing, two months before he was terminated, the “PERSON
23 NOT AUTHORIZED ON PROPERTY” poster. Plaintiff’s photo and description were also
24
included on the poster, which was distributed around the UC Davis Medical Center Campus and,
25
most likely, sent to managers and UC Davis employees by electronic mail. Plaintiff was still a
26
University employee and received treatment like a “Most Wanted” criminal by the FBI.
27
671. Plaintiff is not certain whether Judith Rosenberg was aware or knew prior
28

Page 249 of 250
1 to writing and signing the investigation report what this case was really about. As an experienced
2 attorney at law and UC Principal Investigator, Judith Rosenberg knows for certain that the
3 allegations against Plaintiff, whether false or true, did not warrant keeping Plaintiff on
4 investigatory and administrative leave for over one year with pay or without pay and ten days
5
suspension without pay as well as terminating his employment.
6
672. Plaintiff believed that Judith Rosenberg discovered why Plaintiff became the
7
subject of unthinkable and despicable retaliation and employment termination after he submitted
8
the seven-page long letter to Rosenberg on the March 11, 2013 post-meeting with her. The letter
9
in 2015 was submitted to the court as an exhibit and was vigorously objected by the Defendant’
10
counsel. Plaintiff, representing himself, did not have a clue why the Defendant’ attorney objected
11
so aggressively to this exhibit.
12
673. Also, in 2013, Plaintiff did not know that his fated separation from the University
13
was decided by the Regents of the University of California, the University of California Office of
14
15 the President and the University of California Office of the General Counsel or that the very
16 narrow group of the University officials knew what this case was about.
17 674. The 2009 Settlement-Agreement Plaintiff signed with the Regents of the
18 University of California was not mentioned in by UC Senior Vice President Daniel Dooley in his
19 decision.
20 675. UC Senior Vice President Daniel Dooley resigned or was forced to resign from
21 his $400,000 job with the University of California shortly after he signed the decision in
22 Plaintiff’s Whistleblowing Retaliation Complaint.
23 676. UC Senior Vice President Daniel Dooley from November 2011-April 2012 was a
24
member of the Task Force Team, which investigated a pepper spray attack ordered by UC Davis
25
Chancellor Katehi against protesting students on November 18, 2011. The Task Force Team, of
26
which UC Senior Vice President Daniel Dooley was a member, caused unemployment for UC
27
Davis Police Captain Joy Souza , Lt. John Pike and UC Davis Police Chief Annette Spicuzza
28

Page 250 of 251
1 who was replaced by corrupted Matt Carmichael.
2 The Task Force Team investigation and Lt. John Pike and Annette Spicuzza firing from job with
3 war like propaganda all over r the media was nothing else but the smoke screen to protect
4 corrupted and rotten to the bones the University of California administration and system.
5
APRIL 2013
6
7 April 3, 2013 – The letter to UC Davis Health System Executive Director Mike Boyd
Termination of Plaintiff’s Employment – PPSM 70 Step II Appeal Hearing on April 2, 2013
8
677. On April 2, 2013, the Step II Appeal hearing took place in Plaintiff’s employment
9
termination pursuant to the UC Davis Policy PPSM 70 with the presiding Complainant
10
Resolution Officer at the hearing, UC Davis Health System Executive Director Mike Boyd, who
11
was Plaintiff’s indirect superior and, by the position and title, was responsible for Plaintiff’s
12
employment termination.
13
678. Plaintiff followed the instruction in the Letter of Termination dated December 5,
14
2012 and filed the complaint pursuant to the UC Davis Policy PPSM 70.
15
16 679. In 2013, Plaintiff was uncertain whether he should pursue his employment
17 termination complaint under the UC Davis Policy PPSM 70 or file the lawsuit to enforce the
18 February 2009 Settlement-Agreement that the Defendant i.e., the Regents of the University of
19 California signed with Plaintiff
20 700. Plaintiff, by filing the complaints pursuant to UC Davis Policy PPSM, had little
21 hope that his employment and position, provided to him by the 2009 Settlement-Agreement,
22 would be eventually restored without litigation or knowing that the decision to terminate him
23 came from the Defendant’ Headquarters in Oakland, CA and was carried out by Director Boyd
24 and others.
25
701. Plaintiff summarized the April 2, 2013 Step II Appeal Hearing as follows:
26 April 3, 2013
27 “Mike Boyd, Executive Director

Facilities Planning, Design and Construction
28 UC Davis Medical Center

Page 251 of 252
Sacramento, CA 95817
1
Re: Termination of Employment – PPSM 70 Step II Appeal Hearing
2 on April 2, 2013
3 Dear Director Boyd:
4
Thank you for the opportunity to meet you and discuss my employment
5
termination matter during yesterday’s Step II Appeal Hearing, which took
6
place in UC Davis Campus HR Building. It was my understanding from our
7
discussion that you don’t have a clear picture about the taken-out-of-context
8
9 statements that were outlined in the Notice Intent to Dismiss for Serious
10 Misconduct.
11 I recently filed an Appeal with the California Insurance Appeal Board in
12 relation to my unemployment benefits, which shall not be denied by my
13 employer during the pending internal appeals under the PPSM 70appeals.
14 The abovementioned appeal with the California Insurance Appeal Board is
15 similar to my PPSM Step II Appeal, but is more focused and specifically
16 addresses the out-of-context statement written in Charles Witcher’s Notice
17 Intent to Dismiss dated September 25, 2012.
18
Together with this letter, I am sending you a copy of my Appeal Brief and the
19
relevant exhibits I submitted to the California Insurance Appeal Board.
20
I hope that the enclosed documents and your careful review of Oropeza and
21
Seifert’s Investigatory Report, which is based on lies, false statements and
22
fabricated accusations by a handful of people, will help you understand that
23
this case will not end with your hearing or in arbitration but, instead, will
24
ultimately be pursued in a court of law and justice will be served.
25
Besides the above, I am respectfully asking you for help on behalf of my
26
HVAC shop coworker, Kenny Diede, whose life and working conditions in the
27
28 HVAC shop became miserable and intolerable due to harassment and

Page 252 of 253
1 retaliation by Patrick Putney and Dorin Daniliuc after Kenny reported child
2 pornography twice-convicted felon on shop premises. Kenny would be very
3 grateful if you would use your executive power as a director to help him to
4 move him to different department and away from Patrick Putney and Dorin
5
Daniluc’s harassment. I am representing Kenny in his complaints against
6
Patrick Putney and Dorin Daniliuc and I know that he has all the qualifications
7
and experience to work at either the UC Davis Campus or the UC Davis
8
Medical Center Fire Department. If a formal request from Kenny is needed to
9
move him from the HVAC shop, then he will submit one immediately. I
10
believe that relocating Kenny will contribute to healing the ongoing conflict,
11
ease the tension in the HVAC shop, and enable him to withdraw his complaint.
12
To conclude this letter, I would like to repeat my statement from the hearing
13
that I am always open to and ready for constructive discussion that will end the
14
15 conflict without having to involve lawyers and litigation.
16 Best Regards,
Jaroslaw Waszczuk
17 CC: HR, Charles Witcher , Vice Chancellor Ralph Hexter, Kenny Diede .
18
MAY 2013
19 May 2, 2013 – UC Davis Health System Executive Director Mike Boyd’s – PPSM 70 Step II
Appeal Decision In Plaintiff’s Employment Termination Complaint
20
702. On May 2, 2013, UC Davis Health System Executive Director Mike Boyd
21
issued a decision in Plaintiff’s Step II Appeal employment termination complaint as follows
22
703. Plaintiff’s hope that Director Boyd, with his executive power, would find
23
a different solution was broken like a soap bubble”?
24
May 5, 2013 – Plaintiff’s Response to Director Boyd’s Step II Decision
25
26
27 704. Regardless of Plaintiff’s feelings about the retaliation and employment
28 termination, Plaintiff respected Director Boyd as a UC Davis Medical Center educated

Page 253 of 254
1 professional. However, after Plaintiff read in disbelief Director Boyd’s Step II Appeal Decision,
2 he was outraged by Boyd’s out-of-touch decision. Plaintiff could not curb his emotions and
3 expressed his feeling about Boyd in his letter dated May 5, 2013 as follows:
4
May 5, 2012
5
Mike Boyd, Executive Director
6 Facilities Planning, Design, and Construction
UC Davis Medical Center.
7 4800 2nd Avenue,
8
Subject: Response to your decision dated May 2, 2013—Response to Step 2 Appeal
9 (File #03-PPS- 014-12/12) regarding my employment termination.
10 Mr. Boyd:
On April 2, 2013, we held a meeting on the UC Davis Campus. On the same-day, UC
11
12 Davis Chief Compliance Officer Wendy Delmendo wrote me a letter and informed me
13 that she had accepted my complaint under the university’s Whistleblower Protection
14 Policy.
15
16 Furthermore, Ms. Delmendo explained that my whistleblower retaliation

17 complaint was put on hold and stay in abeyance until the final step of the 70
18 PPSM complaint process and until my PPSM 70 complaint proceeded to the
19 hearing, where the hearing officer will review my whistleblower retaliation
20 complaint along with my PPSM70 complaint. In her letter, Ms. Delmendo
21
failed to explain what would happen with my whistleblower retaliation
22
complain if I did not appeal your PPSM70 Step II decision.I view your
23
decision as a further malicious retaliation, full of lies and misstatements,
24
following the termination of my employment. This is not the first time we have
25
met, and it is not the first time I am responding to your decision, which makes
26
me sick to my stomach. I find it suspicious and inappropriate that the person
27
who is responsible for the termination of my employment and who has
28

Page 254 of 255
1 previously issued biased decisions against me has been assigned as the CRO to
2 review the case. As I recall, in March of 2012, you were removed from your
3 assignment as a Compliant Resolution Officer from Case No. 03-PPS-017-
4 11/12 due to Kenneth Diede’s objection.
5
I did not object to your assignment in the termination case. You should have
6
figured out on your own that you should not have participated in review of my
7
employment termination process as the assigned CRO and as the person
8
directly responsible for my employment termination. In fact, I am wondering
9
what compelled you to take this assignment. I believe that it is your and
10
Witcher’s revenge for being defeated in 2008, or that you are perhaps a
11
member of the circle of the corrupt UCDMC establishment, which (under the
12
umbrella of empty UC Davis “Principles of Community” slogans) viciously
13
and vindictively attacks anybody who points out “serious misconduct” and the
14
15 criminal-minded activities of those who were given supervisor and manager
16 positions by directors like yourself.
17 Decision Dated May 2, 2013
18 Page No. 1
19
Boyd: “During the meeting, Mr. Waszczuk asserted that the
termination was an act of retaliation that is linked to complaints he
20 made about his supervisors and management staff within PO&M when
working at the Central Plant from 1999 to 2007 and more recent
21 allegations and concerns that he raised in 2010 and 2011. This assertion is
consistent with similar assertions he made in his Step I Appeal and in the
22 documentation provided in the Step II Appeal submittal. He also maintains
that the disciplinary actions have been taken represent a breach of the
23 2009 Settlement-Agreement between him and the University.”
24 My response: The above statement of Boyd’s is a lie. During the meeting, I

25 did not make any assertion that my termination was an act of retaliation linked
26
to the complaint I made about my supervisors and management when working
27
at the Central Plant from 1999 to 2007. I did not file any formal complaint
28

Page 255 of 256
1 against any manager or management when I was working in the Central Plant,
2 and I am not asserting anything what happened prior the signed agreement
3 settlement-agreement in February 2009. I view the period from April 2011 to
4 December 2013 as a time of unspeakable harassment, retaliation, malice,
5
intolerable working conditions, and believe that my suspension from work and
6
the termination of my employment are the result of a vendetta on the part of
7
Witcher and yourself that began in 2006. Furthermore, your decision is a
8
continuance of this vendetta and a gross violation by you and others of the
9
February 2009 signed Settlement-Agreement.
10
11 During our discussion, I pointed out to you the following fragment from
12 Seifert and Oropeza’s report, in order to help you understand how Seifert and
13 Oropeza crafted cause for you to terminate my employment.
14
15 “Mr. Putney reported that Mr. Waszczuk's volume of unprofessional

emails, his filming of employees in the workplace without their consent,
16 the volatile outbursts of anger, and the repeated ethnic slurs towards Mr.
Daniluc's ancestry and the ethnicity of other employees Of Romanian
17 descent created an intolerable, threatening, and harassing work
environment.”
18
19 After I read you this fragment from Oropeza and Seifert’s report, I asked you
20 the following question in relation to Putney’s lies:
21
“Mr. Boyd, you were born in and have lived your entire life in the USA,
22
right?” You answered, “yes.” I then asked you, “Do you know or did you
23
ever hear any ethnic slurs in this country directed against Romanians,
24
similar to nigger, Pollack, wetback, or other such slurs?” You responded
25
26
that you didn’t know, and that you never heard any slurs directed
27 towards Romanians. I responded, “I don’t know either. Did you ask
28 Putney whether he or Daniliuc know any ethnic slurs about Romanians, not to

Page 256 of 257
1 mention Daniluc’s comparison of Mexicans to cockroaches?” This is only one
2 of Putney’s multiple lies, which I provided to you as an example of how the
3 false cause for termination of my employment was built by Nichols, Seifert,
4 and Oropeza upon the request of you and other rotten individuals. My response
5
to Step I of the Appeals process was very detailed and to the point. In addition
6
to my Step II Appeal detailed request and response, after the meeting I sent
7
you the brief and exhibits I wrote and prepared for the California
8
Unemployment Insurance Appeal Board, because you were quite unprepared
9
for the meeting on April 2, 2013.
10
11 I have already decided to spend my entire UC retirement, if necessary and live

12 on my Social Security for the purpose to teach corrupt individuals like you,
13 Witcher, Chillcott, Nichols, Oropeza, Seifert, Lindsey, and a few others an
14 unforgettable lesson in court about the American justice system. In contrast to
15 you and others like you, I believe strongly in the American justice system, and
16
justice must be served. This is my promise, and I always keep my promises. I
17
will make sure you are first in line for deposition out of all the members of this
18
corrupt UCDMC clique, and I will attempt to cause you to change your name
19
and behavior from “Director Boyd” to “Director Void.” For the attempt to
20
provoke me and kill me on May 31, 2011, I will not allow the UCDM HR
21
Death Squad to escape the consequences of this crime.
22
23 Additionally, I am quite surprised that you reduce yourself to the level of

24 people like Daniliuc, Putney, Witcher, and the liars from HR with J.D. degrees.
25 Apparently abused and harassed workers, a twice-convicted child
26 pornography felon accessing company computers, mutilated sheep, goats,
27
ducks, roosters, and defecation on the HVAC shop premises and the Central
28

Page 257 of 258
1 Plant worker suicide does giving you some kind thrill and occasion to be
2 noticed a visible. It really makes me wonder what common ground you
3 Chillcot and Witcher could have with people like Putney, Daniliuc, Curry and
4 child porn convict etc.
5 Revenge and retaliation isn’t wise.
6 See you in court.
Jaroslaw Waszczuk
7 Enclosure:
CC: Ralph Hexter, Linda Katehi, Ann Rice, Mark Yudof , UC Regents , Wendy
8 Delmendo ; Travis Lindsey , Gina Harwood
9
705. Plaintiff met Director Boyd one more time after his employment
10
termination due to a scheduled hearing on December 5, 2013 for the Step II Appeal pursuant to
11
12
UC Davis’ Policy PPSM 70.
13 706. On December 5, 2013, exactly one year after the Defendant terminated
14 Plaintiff’s employment, Plaintiff held a meeting with Boyd in the UC Davis Medical Center.
15 Boyd was assigned as the Compliant Resolution Officer (CRO) Step II Reviewer in the Case No.
16 03-PPS-011-12/13. During the meeting, Plaintiff was representing HVAC Technician Dereck
17 Cole in his complaint under UC Davis Policy PPSM 70 for his 2011/2012 “Does Not Meet
18 Expectation Employee Performance Review (Evaluation).” The “Does Not Meet Expectation
19 Evaluation” was basically the last step for the employee to be terminated if he did not improve
20 his performance and behavior and achieve the goals for the next evaluation period, as outlined by
21
the supervisors or managers in the employee evaluations.
22
23 707. Mike Boyd, as Executive Director and Complaint Resolution Officer, and
24 as Plaintiff’s superior, knew that the Employee Performance Reviews (evaluations), mandated by
25 UC Davis Policy PPSM 23, are the most important documents to make a decision in any adverse
26 employer action against an employee, including suspension and employee termination.

27 708. Plaintiff could not find one word about his Employee Performance
28

Page 258 of 259
1 Reviews from 201/2011 and 2011/2012 or about any Performance Reviews from 1999–2012 in
2 Boyds, and his two subordinates, Rush and Pansious, decisions of Plaintiff’s complaint–appeals
3 from the unlawful suspensions and the unlawful employment termination
4 709. Director Boyd should know as Complaint Resolution Officer that Plaintiff
5
advised him in his 24-page letter dated January 28, 2008 how important an Employee
6
Performance Review is in employer-employee relations, as citted in the letter Jensen v. Hewlett-
7
Packard Co., 14 Cal. App. 4th 958, 18 Cal. Rptr. 2d 83 (Cal.App.Dist.4 03/30/1993).
8
710. Regardless of the 2009 Settlement-Agreement that Plaintiff signed with
9
the Defendant, which was despicably violated, breached and disregarded by the Defendant,
10
Director Boyd’s decision in the Step II Appeal further shows that Plaintiff was not given the
11
same chance as Plaintiff’s coworker, Derecek Cole, to whom Plaintiff was provided
12
representation.
13
711. The Defendant simply singled out Plaintiff for termination and did not
14
15 provide him with evaluations for the last two years of his employment mandated by UC Davis
16 Policy PPSM 23, thus maliciously depriving Plaintiff of the UC Davis administrative remedies
17 under UC Davis Policy PPSM 23 and violating his employment and civil rights to be treated
18 equally beside the breaching and violating 2009 Settlement –Agreement
19
20 Plaintiff’s 1999-2010 Employees Performance Review

21
22
YEAR COMMENT SUPERVISOR
23
1999-00 “…performance very good” Kavanagh
24 “has become a very knowledgeable and effective central, plant
operator” --
25 “very conscientious and thorough” --
“can be counted on to make the right operational decisions” --
26 “valuable employee” --
“committed to the future success of the Medical Center” --
27 VERY GOOD often exceeded expectations and standards --
28 2000-01 Same or similar to 1999-2000 A. Moddesette

Page 259 of 260
1
2 YEAR COMMENT SUPERVISOR

3 OUTSTANDING consistently exceeded expectations and
2001-02 standards DAN JAMES
4
2002-03 “Performance… outstanding” --
5 “can be counted on to keep management informed status of the
plant and equipment” --
6 “very valuable employee” --
7 2003-04 Same or similar to 2002-03, meets expectations DAN JAMES
9 2005-06 Sane or similar to 2002-03, meets expectations DAN JAMES
10 “…Tom Kavanagh and Steve McGrath…” supervisors until
2006-07 4/27/2007 McGRATH
11 “…PUTNEY…” Supervisor beginning 4/27/2007 --
“has been a very valuable member of our staff” PUTNEY
12 “performance has been excellent” PUTNEY
“have not been any problems with missed alarms” PUTNEY
13 “…is talented, precise and his daily paper work is excellent.” PUTNEY
“…communicates very well…” PUTNEY
14 “…instrumental in the setup of the compute…r” PUTNEY
“…instrumental… office area for the Building Automation
15 Monitoring.” PUTNEY
“…strong knowledge of computer software and hardware.” PUTNEY
16 “…overall job performance is outstanding…” PUTNEY
“…very dependable…” PUTNEY
17
2007-08 “…a very valuable member of our staff…” PUTNEY
19 “…overall job performance is outstanding.” PUTNEY
“…has improved his communication skills and interactions with
20 co-workers.” WITCHER
21 2008-09 “…a very valuable member of our staff…” PUTNEY
“performance has been excellent” PUTNEY
22 “have not been any problems with missed alarms” PUTNEY
“…also helping with closing work orders…” PUTNEY
23 “…maintaining the Work Order System back log…” PUTNEY
“…overall job performance is outstanding.” PUTNEY
24 “OUTSTANDING. Exceeds Expectations. PUTNEY
25 2009-10 “OUTSTANDING. Exceeds Expectations. PUTNEY
“…Helping…managing the work order system…providing
27 computer support…” PUTNEY
“helpful…providing BMS…information to senior staff PUTNEY
28

Page 260 of 261
1

during…investigation”
3 “...very instrumental...monitoring...alarm/ status of critical
equipment...” PUTNEY
4 503. Plaintiff’s evaluations2010-2011and 2011-2012 are missing.
5
7 May 7 , 2013 – The Right to Sue Notice
9 712. On May 7, 2013, Plaintiff obtained the Right To Sue Notice from the State
10 of California Department of Fair Employment and Housing DFHH Matter: 112740-49836-R
11 after losing hope that the wrongful termination and discrimination that the Defendant caused him
12 could be resolved without litigation.
13 DECEMBER 2013
14 December 4, 2013 – Plaintiff’s Wrongful Termination Complaint Against the Defendant with
the State of California County of Sacramento Superior Court
15
16
713. On December 4, 2013, Plaintiff in Pro Per filed in State of California,
17
County of Sacramento Superior Court the Wrongful Termination Complaint.
18
714. On December 2, 2013, Plaintiff simultaneously filed in the State of
19
California, County of Sacramento Superior Court a Petition for a Writ of Mandamus,
20
Administrative Mandamus (CCP § 1085;1094.5) to order the California Unemployment
21
Insurance Appeal Board (CUIAB) and/or The Employment Development Department (EDD) to
22
calculate and provide unemployment benefits to Plaintiff or a remand for a rehearing to award
23
such benefits related to Plaintiff’s December 7, 2012, employment termination.
24
715. Defendant in further despicable violation and breach of the February
25
2009Settlement-Agreement, with an evil spirit, defaced and defamed Plaintiff with the State of
26
California Employment Development Department for the purpose of denying Plaintiff ‘s
27
unemployment benefits after terminating Plaintiff’s employment.
28

Page 261 of 262
1 716. It happened just after Defendant kept Plaintiff out of premises for over a
2 year and a half on a bogus paid investigatory and administrative leave only to psychologically
3 terrorize Plaintiff and try to force Plaintiff to quit his job.
4 717. Plaintiff’s unemployment insurance benefit case is still pending in the
5 State of California Court of Appeal Third Appellate District, Case Caption Waszczuk v.
6 California Unemployment Insurance Appeal Board No. C079254, the County of Sacramento
7 Superior Court Case No. 34-2013-80001699-CU-WMGDS.
8
In Writ of Mandamus against CUIAB and Real Party in Interests (Defendants), Plaintiff was
9
represented by an attorney, Douglas Stein, until Plaintiff dismissed Douglas Stein for gross
10
misrepresentation in December 2014.
11
March 2014
12
13
718. On March 11, 2014, Plaintiff sent a letter to the University of California
14
Office of the President (UCOP) Principal Investigator Judith Rosenberg, who had been handling
15
Plaintiff’s whistleblowing retaliation complaint since June 2013. Plaintiff filed the
16
whistleblowing retaliation complaint with the UC Davis Provost and Vice Chancellor’s Office on
17
18 March 7, 2013, after Plaintiff’s employment was terminated by Defendants.
19 719. The purpose of Plaintiff’s March 11, 2014, 10-page-long letter to Judith
20 Rosenberg was to summarize Plaintiffs’ meeting with her, which took place in Defendants’
21 Headquarters in Oakland, California, on February 19, 2014.
22 720. In his letter to Judith Rosenberg, Plaintiff mentioned the interview the UC
23 Davis Assistant Vice Chancellor Dr. Shelton Du ru issea u ga ve to Sacramento African-
24 American magazine Sub Cultural Hub. The interview was conducted by Donna Michelle Ramos
25 on August 6, 2012, and was entitled “A Look Back.”
26 721. Dr. Shelton Du ru isseau wa s o ne o f De fe nda n ts and p e rpe tra tors
27
who pa rtic ip a ted in the d esp ica b le re ta lia to ry p re em p tive ac tion a ga in st Pla intiff
28

Page 262 of 263
1 in 2 006 –20 08 a nd 20 11– 201 2 .
2 722. Plaintiff in his March 11, 2014, letter to UCOP Investigator Judith
3 Rosenberg wrote:
4
“Shortly after Assistant Vice Chancellor Dr. Shelton Du ru isse au retired, he
5
6 threw a retirement party in his Eldorado Hill residence. The two guests of
7 honor at the party were Mayor of Sacramento Mr. Kevin Johnson and Mr.
8 Shelton Duruisseau’s colleague, UC Davis Medical Center Director Robert
9 Taylor. Besides the lavish retirement party, Dr. Duruisseau gave an interview
10 to Sacramento African-American magazine Sub Cultural Hub. The interview

11 was conducted by Donna Michelle Ramos on August 6, 2012, and was entitled
12 “A look back.”
13
14 While reading the “A look back” interview with Dr. Duruisseau, a few
15
statements caught my attention. The first statement that caught my attention
16
was:
17
18 “Internally, I convinced the university to build its own central plant

because we recognized our patients come into the hospital on ventilators,
19 etc. They couldn’t be disrupted, so by having our own central plant the
health system doesn’t depend on any central outfit to supply water, power,
20 etc. SMUD, PG&E are backup systems for us. We sold enough power to
the State for the central plant to be paid for in the first four years. Lots of
21 energy companies like Enron all around the country caused prices to go
up. The plant provides stable power for the campus without interruption
22 and without blackouts. This plant was built out for 50 years capacity; we
are only using 9%, so we have lots of room built in for growth.”
23
24
25
26 I am very skeptical about Dr. Duraisseau’s statement that the Central Plant sold
27
enough energy in its first four years of operation to cover the cost of building
28

Page 263 of 264
1 the Central Plant. As I recall, the contract to sell power to the electrical grid
2 was in limbo, and at that point the Central Plant did not make much money
3 from power sale. At night time we were giving away 2 MW of power for free
4 to SMUD to keep Central Plant’s 25 MW gas engine operational. The
5
statement that the plant was built for 50 years of capacity and that we are using
6
9% of it translate into the fact that UC invested $70 million or more, yet a large
7
part of this investment is frozen for many years to come. This is obviously an
8
enormous waste of millions of dollars to build something that can’t be utilized
9
fully. Apparently, the decision makers whose names appear on the plaque
10
located in the entry to the Central Plant did not have any clue what UC Davis
11
Medical needed with regard to demand for electric and thermal energy. The
12
names mentioned on the plaque are UC Davis Chancellor Larry N. Vanderhoef
13
(retired), UC Davis Medical Center Director Hospital and Clinic Frank J.
14
15 Lodge, Associate Director Shelton Duruisseau Ph. D., Manager of Plant
16 Operation and Maintenance Department Tony Moddessette MBA, Project
17 Manager and Principal Engineer Mike Lewis, Construction Manager David
18 DeRusso, and Principal Engineer from Brown and Caldwell James L. Bartlett.
19
20 Apparently, in 1998 Dr. Duraisseau and Project Manager Mr. Mike Lewis had
21 no clue what a cogeneration facility stands for and what criteria such a facility
22 must meet to be in compliance with federal law (FERC).
23
24
By reading the 2012 “A look back” interview and seeing Dr. Duraisseau’s
25
name on the plaque in the Central Plant, it is not difficult to conclude that the
26
Central Plant for him and others was like a sacred and untouchable place built
27
for future generations to remember “great” UC Davis leaders. However, the
28

Page 264 of 265
1 Central Plant lacked safety for employees and caused massive contamination
2 of the natural environment by discharging leaking machine oil from defective
3 leaking cooling tower gearboxes to the city storm drain (river) for seven years.
4 ‘From the Dr. Duraisseau’s interview was not difficult for Plaintiff to
5
determine and conclude that the UC Davis 27 MW cogeneration power plant
6
named Central Plant by the Defendants did not meet requirements of Federal
7
Energy Regulatory Commission (FERC) and the Public Utility Regulatory
8
Policies Act of 1978 (PURPA) which mandated that any cogeneration facility
9
certified and recognized by law as “the qualified cogeneration facility” must
10
meet special requirements in the ratio between electric energy production and
11
thermal energy production.
12
723. When UCOP Investigator Judith Rosenberg, as a ve ry ex pe rien ced
13
a ttorney and in ve stiga tor read Plaintiff’s letter and statement about the UC Davis Assistant
14
15 Vice Chancellor Dr. Shelton Du ru isse au ’s in te rv ie w, she had no p rob lem figu rin g ou t
16 why in Ma rc h 20 07 Pla in tiff was remo ve d fro m the Cen tra l Pla nt why De fe nda n ts
17 sign ed Se ttlem en t-Ag ree men t with Plain tiff in Feb ru ary 200 9 , an d why Pla intiff
18 wa s a tta ck ed a ga in in 201 1 an d fire d fro m th e job in De ce mbe r 2 012 . Th e
19 m illio ns of do lla rs o f reve nue fro m the produ c tion and sa le of ele c trica l e ne rg y
20 b y the UC Dav is Me d ica l Cen tra l Pla n t was th e issu e an d b ig p ro b lem
22 (FERC’s) regulation and the Public Utility Regulatory Policies Act of 1978 (PURPA) because
23 prior to his employment with UC Davis Medical Center, Plaintiff worked for a private corporation
24
with a similar cogeneration facility that did not meet FERC and PURPA requirements to be
25
certified as a “qualified cogeneration facility.” Plaintiff’s previous employer committed enormous
26
fraud against Pacific Gas and Electric Company ratepayers and settled out of court for $100
27
million. The $100 million fraud occurred after only six years of unlawful cogeneration facility
28

Page 265 of 266
1 operations similar to those of UC Davis Medical Center’s cogeneration power plant.
2 725. It was also not difficult to determine for UCOP Principal Investigator
3 Judith Rosenberg that the UC Davis Medical Center cogeneration’s primary purpose was
4 providing utility for UC Davis Medical Center because instead of to generate millions of dollars
5
in profit from the sale of electric power to the public utilities companies or an on-the-spot sale in
6
the open market .
7
8
726. Besides the letter to the UCOP Investigator, on March 17, 2014, Plaintiff
9
sent a six-page letter to Sac Cultural Hub Senior Staff Writer/News Reporter Donna Michelle
10
Ramos about her August 6, 2012, interview with UC Davis Assistant Vice Chancellor Dr.
11
Shelton Du ru isseau .
12
13 “A few days ago, I wrote letters to two UC Office of the Presidents’ officials,
14 Principal Investigator Ms. Judith Rosenberg and UC Senior Vice President
15
Dan Dooley, and I mentioned your interview with Mr. Shelton Duruisseau in
16
my letter because Mr. Shelton Duruisseau made a statement about the UC
17
Davis Medical Center Central Plant where I was employed for several years. I
18
am enclosing both letters for context.”
19
727. Even after the reading Dr. Shelton Du ruisse au ’s u n in te ntiona l
20
c on fe ssion du rin g the in te rv ie w a bou t th e en ormo us p ro fit th e Ce ntra l Plan t
21
g ene ra ted and after writing a Ma rc h 11 , 2014 , le tte r to UCOP In ve stiga to r Jud ith
22
Ro se nbe rg , Pla in tiff d id no t th in k tha t th e De fen da nts’ v ic ious re ta lia tion
23
strik es ag ainst Pla in tiff wa s a pree mp tiv e we ll-orche stra te d De fend an ts ac tio n
24
25 re la ted in direc tly o r to the $ 100 ,0 00 ,0 00 fraud co mm itte d by Pla in tiff’s prev iou s
26 e mp lo ye r in re la tion to FERC regulations and PURPA law.
27 728. Plaintiff during his employment with UC Davis Medical Center was not
28 interested in ever looking into the issue of whether or not the Central Plant was being operated

Page 266 of 267
1 according to the FERC regulations law and PURPA requirements. Plaintiff was concern about
2 safety in the first few years of his employment in Central Plant because the plant in some areas
3 was unsafe for operating personnel.
4 729. Plaintiff lost employment for one year after reporting his previous
5
employer for fraud during a dispute involving $27,000 in unpaid overtime wages due to Plaintiff.
6
The dispute caused Plaintiff and his family a lot of suffering and bankruptcy.
7
730. Furthermore, the UC Davis Medical Center cogeneration facility was built
8
and commissioned in 1998, at a time when the electric power market in the State of California
9
had become the subject of deregulation, and Plaintiff never would have thought that the FERC
10
and PURPA law and regulations were still applicable to the UC Davis Medical Central Plant’s
11
electric power production and sale.
12
731. Besides the above, Plaintiff thought the FERC regulations and PURPA
13
law were not applicable to the University of California because of the University’s great
14
15 autonomy and independence from the state and federal laws and regulations.
16 732. Even if Plaintiff would have thought about the Central Plant’s PURPA
17 qualification, Plaintiff was not willing to spend his own $10,000 and lose his job again at his
18 age for the purpose of filing a complaint with FERC in an attempt to nullify the Central Plant
19 certification issued by FERC and obtained by Defendants in the self-certification process (if
20 any). Also, it would never would crossed Plaintiff’s mind that Defendants committed fraud
21 against another entity in the same manner that Plaintiff’s previous employer did because Central
22 Plant was built to provide utility for UC Davis Medical Center and that surplus energy should be
23 sold because electric energy cannot to be stored like the other product.
24
733. The previous Plaintiff’s employer committed an enormous $100,000,000
25
fraud against Pacific Gas and Electric Company ratepayers in 1989–1996, violating the PURPA
26
mandated requirements for operating a cogeneration facility.
27
734. The March 11, 2014, letter to the UCOP Principal Investigator Judith
28

Page 267 of 268
1 Rosenberg was the first time Plaintiff had thought of and suspected Defendants’ violation of
2 FERC regulations and PURPA law, but Plaintiff was so quickly distracted by Defendants, the
3 State of California Attorney General Deputy Ashante Norton who was legal counsel for CUIAB
4 and by his own attorney, Douglas Stein, that Plaintiff even did not think to check FERC
5
website to find out whether the UC Davis Medical Center Central Plant was certified and
6
considered a Qualified Facility (QF) under FERC regulations and PURPA law. The Central Plant
7
lost power sale contract in 2003 or 2004 and was losing millions of dollars every year because
8
could not sell surplus power.
9
735. When Plaintiff was hired by Defendants in June 1999 as a UC Davis
10
Medical Central Plant Operator, the plant was unsafe for personnel to operate because it was
11
commissioned unfinished, and Plaintiff only cared about his own safety and that of his
12
coworkers. Plaintiff did not want to get hurt or see his coworker die because the plant was unsafe
13
to operate and the belligerent department management completely ignored safety suggestions to
14
15 improve situation and Plaintiff was threatened with employment termination when Plaintiff
16 asked his manager to do something about.
17 After the Letter
18 736. After Plaintiff wrote the letter to UCOP Investigator Judith Rosenberg on
19 March 11, 2014, and Sac Cultural Hub Senior Staff Writer/News Reporter Donna Michelle
20 Ramos on March 17, 2014, Defendants reacted sharply and went viral to divert Plaintiff’s
21 attention from the huge 70 million profits generated by the Central Plant from electrical energy
22 sale in 1999-2003 which was disclosed by UC Davis Assistant Vice Chancellor Dr. Shelton
23 Du ru isseau in h is in te rv ie w with Donn a Ram os.
24
737. On March 20, 2014 Plaintiff received e-mail correspondence from UC
25
Davis Health System Human Resource (HR) Labor Relations Manager Travis Lindsey. More
26
than two years after Plaintiff’s employment termination, attempted to advise Plaintiff of where
27
Plaintiff should send information about Defendants and where not to send it. Plaintiff responded
28

Page 268 of 269
1 to Travis Lindsey’s advice by explaining that he belonged to the Federal Penitentiary Facility for
2 what he had done with other individuals like him to Plaintiff and Plaintiff’s co-workers in 2012.
3 However, in March 2014, Plaintiff did not connect Travis Lindsey’s strange e-mail
4 correspondence to the UC Davis Assistant Vice Chancellor Dr. Shelton Duru isseau ’s
5
in tervie w with Do nna Ram os and Pla in tiff’s le tte r to h er.
6
735. In March 2014, Plaintiff was not aware that Superior Court Judge Hon.
7
Shelleyanne W.L. Chang was signed to the Plaintiff Writ of Mandamus Case just a few days
8
after Plaintiff wrote the letter to Judith Rosenberg.
9
736. Even Plaintiff would know in March 2014 about Hon. Shelleyanne
10
Chang’s assignment to Plaintiff’s Writ of Mandamus case that it would not make any difference
11
for Plaintiff because Plaintiff was represented by an attorney in Writ of Mandamus case, and
12
Plaintiff did not know many other facts that were negatively impactful or were damaging to
13
Plaintiff’s court complaints against Defendants.
14
15 737. In March 2014, Plaintiff was also not aware of the fact that on February
16 24, 2014, the attorney in the unrelated Plaintiff’s wrongful termination case pending in the same
17 Sacramento Superior Court (Janet Keyzer v. The Regents of the University of California, Case
18 No. 34-2010-00079869-CU-WT-GDS) filed a Plaintiff’s Peremptory Challenge (CCP § 170.6)
19 against Judge Shelleyanne Chang in which Attorney Mary -Alice Coleman declared that:
20
“The Honorable Shelleyanne W. L. Chang, the Judge before whom the
21
trial in the aforesaid matter is pending or to whom the aforesaid trial is
22
assigned, is prejudiced against me or Plaintiff so that Plaintiff cannot or I
23
believe that Plaintiff cannot have a fair and impartial hearing before this
24
25 Judge.”
26 It is happened shortly prior Hon. Shelleyanne Chang’s assignment to Plaintiff’s
27 Writ of Mandamus Petition case.
28 738. Hon. Shelleyanne Chang has been the subject of a Peremptory Challenge

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1 in Janet Keyzer’s wrongful termination case against the same Defendant as in Plaintiff’s
2 wrongful termination case and the Real Party of Interest in the Writ of Mandamus case.
3 739. Besides the Judge Shelleyanne Chang was not only judge in the
4 Scaramanto Superior Court to handle Writs of Mandamus. The three other judges from the
5
Sacramento Superior Court were handling Writs of Mandamus in the County of Sacramento
6
Superior Court: Hon. Timothy M. Frawley from Department 29, Hon. Michael P. Kenny from
7
Department 31, and Hon. Christopher E. Krueger.
8
740. Furthermore, nothing would be unusual or suspicious about reassigning
9
Plaintiff’s Writ of Mandamus case to Judge Shelleyanne Chang if Hon. Judge Shelleyanne
10
Chang and CUIAB Administrative Law Judge (ALJ) Marylyn Tays would not work
11
together in the Office of Legal Affairs of Governor Gray Davis.
12
741. Administrative Law Judge Marilyn Tays was outrageously biased against
13
Plaintiff during the conducted hearing on March 13, 2013. ALJ Marilyn Tays’ disrespectful
14
15 attitude toward Plaintiff and his witnesses could best be described with her statement after
16 Plaintiff made a statement about his coworker’s suicide, caused by Defendants’ hostile working
17 environment. ALJ Marilyn Tays responded: “All right, I guess he is not here.” When Plaintiff
18 heard this, I had no doubt where ALJ Marilyn Tays was going with her hearing.
19 742. Furthermore, Hon. Shelleyanne Chang, besides working together with

20 ALJ Marilyn Tays in the Office of the Legal Affairs of Governor Gray Davis, graduated from
21 the same University of the Pacific McGeorge School of Law as ALJ Marilyn Tays in the same
22 time period of 1991, Both were admitted to the State Bar of California six months apart.
23 743. Furthermore, Hon. Shelleyanne Chang graduated in the same time period
24
of 1991 from the same University of the Pacific George School of Law as UC Davis Health
25
System and UC Davis Medical Center Chief Counsel Anna Orlowski. Both Hon. Shelleyanne
26
Chang and Chief Counsel Anna Orlowski were admitted to the State Bar of California in
27
December 1991.
28

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1 744. After Hon. Shelleyanne Chang in March 2015 denied Plaintiff’s Writ of
2 Mandamus Petition after Plaintiff’s oral arguments, the victimized Plaintiff had no doubt that
3 Hon. Shelleyanne Chang’s ruling had nothing to do with State of California justice system but
4 rather to support the Defendants attempted to escape liability for not only Plaintiff’s wrongful
5
termination .
6
April 2014
7
8
745. Following the March 2014 Hon. Shelleyanne Chang reassignment, Travis
9
Lindsey’s email correspondence, and Plaintiff’s letters to UCOP Investigator
10
Judith Rosenberg ,the California Deputy Attorney General Ashante L. Norton, who represents
11
CUIAB as a Legal Counsel , filed on April 1, 2014, a frivolous Notice of Demurrer in Plaintiff’s
12
Writ of Mandamus case to distract Plaintiff and made Plaintiff forget about UC Davis Assistant
13
Vice Chancellor Dr. Shelton Du ru isse au ’s in te rv ie w with Donn a Ram os.
14
15 746. On April 17, 2014, Defendants as the Real Party in Interest in the Writ of
16 Mandamus case filed in the court a Joinder supporting CUIAB’s legal counsel Notice of
17 Demurer. Defendants’ Joinder supporting CUIAB Demurer would perhaps not been strange to
18 Plaintiff if the four top-notch attorneys from the UC Office of the General Counsel had not
19 appeared on Joinder pleading, including Charles F. Robinson, UCOP General Counsel; Karen J.
20 Petrulakis, UCOP Chief Deputy General Counsel; Cynthia A. Vroom, UCOP Senior Counsel;
21 and Margaret L Wu, UCOP Managing Counsel.
22 747. Writ of Mandamus for the unemployment insurance benefits is not the
23 million-dollar case that required the involvement of the four top-notch legal counsels from the
24
UC Office of the General Counsel, especially the UC General Counsel Charles F. Robinson,
25
reports directly to UC Regents.
26
748. In addition to the above, in January 2015, Plaintiff filed an Objection to
27
the Defendants’ Anti-SLAPP Motion and included the Assistant Vice Chancellor Dr. Shelton
28

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1 Du ru isseau ’s b iog raph y an d the Ma rch 11 , 20 14 , le tte r add re ssed to the UCOP
2 Prin cipa l Inv estiga to r Jud ith Ro se nbe rg , wh ich a dd re ssed Dr. Shelton Du ru isseau ’s
3 2 012 in terv ie w ab ou t th e UC Da vis Med ic a l Cen tra l Plan t with Sacramento African-
4 American magazine Sub Cultural Hub.
5
749. Defendant objected Plaintiff’s abovementioned exhibits. However, the
6
Court overruled Defendants’ objection. It is worth mentioning that Dr. Shelton Duru isse au ,
7
b eside h is po sition as an Asso cia te Vic e Cha nce llor, wa s a lso ap po in te d by Sta te
8
o f Ca lifo rn ia Go ve rn or Arno ld Sch warzen egg e r to the Ca lifornia Med ica l Bo ard .
9
750. In April 2014, Plaintiff was not aware that UC General Counsel Charles
10
Robinson, prior to joining the University in January 2007, served as Vice President, General
11
Counsel, and Corporate Secretary for the California Independent System Operator Corporation
12
(ISO), California’s wholesale electric transmission operator, based in Folsom, California, in
13
2000–2007. It is worth mentioning that the California Independent System Operator Board of
14
15 Governors members and the members of the Board of University of California Reagents are
16 nominated by the governor of California and confirmed by the State of California Senate.
17 751. In 1999–2003 ISO was the distributor of electric power sold by UC Davis
18 Medical Center Central Plant on the open market. Plaintiff was employed in the UC Davis
19 Medical Center Central Plant by Defendants from June 1999 to March 2007.
20 752. The UC Davis Medical Center Central Plant in 1999–2003 was selling
21 power at the highest bids on the spot in the market via ISO exactly in same way as Enron or
22 former Plaintiff employer Dynegy, manipulating power and causing a rolling shortage of energy
23 in the State of California and rolling blackouts.
24 753. Defendant were manipulating the electric power sale on a small scale in
25 comparison to Enron or Dynegy, but even selling 15 MW was enough to provide electricity for
26 15,000 people. In 2002, the former Plaintiff employer Dynegy and 10 other energy suppliers that
27 contributed to California’s energy crisis and rolling blackouts were fined with small fines in the
28

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1 amount of $122 million dollars. Dynegy and others probably would not pay the fines if their
2 Board of Director members would be nominated by the State of California Governor, like ISO’s
3 Board of Governors and members of the Board of University of California Regents.
4
754. At the same time in January 2007, when Charles Robinson joined the
5
University, Plaintiff became a subject of Defendants’ despicable attacks, not knowing why he
6
was being attacked, and in March 2007, Plaintiff was suspended from work and was abruptly
7
removed from the Central Plant and reassigned to the UC Davis Medical Center HVAC shop
8
with the threat of employment termination. Three months later, Plaintiff received his annual
9
10 employee performance review (evaluation) for 2006–2007, and Plaintiff’s evaluation looked
11 nothing like what happened in 2006–2007 in contrary to the suspension and reassignment March
12 2007 letter that defaced and defamed Plaintiff.
13 755. In January 2007, Charles Robinson joined the University as the General
14 Counsel, and he knew all of the secrets about the UC Davis Medical Center 27 MW cogeneration
15 facility’s electric power production, distribution, and sale via California Independent System
16 Operator (ISO).
V. CONCLUSION
17
18
19 756. The reason for Defendant’ despicable conspiracy against Plaintiff did not
20 cross Plaintiff’s mind until June 2015 during Plaintiff’s preparation to file Plaintiff’s Opposition
21 to the Defendant’ Legal Fees and Cost in relation to Defendant’ Anti- Strategic Lawsuit Against
22 Public Participation (SLAPP) Motion.
23 757. Plaintiff did not had a clue that Plaintiff’s victory in 2008 arbitration
24 against Defendant —which ended with the 2009 Settlement-Agreement that Plaintiff signed with
25 Defendant—was signed by Defendant in evil spirit and bad faith. The arbitration and the
26 Settlement –Agreement was just a short and unexpected delay for the Defendant before the
27 Defendant exercised and launched a second preemptive retaliatory strike against Plaintiff to end
28 Plaintiff’s employment with the University of California which orchestrated by UC Davis Health

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1 System Human Resourced Executive Director Stephen Chilcott and few other and UC Office
2 of the President officials including and not limited to UC General Counsel Charles Robinson
3 and his Deputy Steven Drown who signed the Settlement- Agreement on behalf of UC Regents
4 in February 2009.
5
6 VI. FIRST CAUSE OF ACTION

[BREACH OF WRITTEN CONTRACT]
7
8 759. The First Cause of Action in this THIRD AMENDED COMPLAINT is

9 the PRIMARY CAUSE OF ACTION, which is a violation and breach of contract by the
10 Defendant, THE REGENTS OF THE UNIVERSITY OF CALIFORNIA (UC) (hereafter
11 Defendant). The February 2009 contract was entitled by the Defendants the SETTLEMENT
12 AGREEMENT AND GENERAL RELEASE.
13 760. In February 2009, Defendants solicited and signed Settlement Agreement
14 with the Plaintiff, JAROSLAW WASZCZUK, (hereafter Plaintiff). Per Settlement Agreement,
15 the Defendant agreed to employ Plaintiff in the exempt position of Associate Development
16 Engineer with an annual base salary of $70,000.00 (seventy thousand dollars) since February
17 2009.
18 761. In 2009, Defendants erroneously misclassified Plaintiff’s salary in the
19 signed Settlement –Agreement, stating that they would instead provide Plaintiff with a salary of
20 $71,640/year pursuant to UC Davis Title Code 7182, the Middle Step Salary Grade. The
21 Defendant provided to Plaintiff with a salary to the amount of $70,000/year, which does not
22 exist in the UC Davis Title Code 7182.
23 762. In March 2011, Plaintiff asked the Defendants for a one-step pay increase
24 under the UC Davis Title Code from the Middle Step of $71,640 to the 3rd Step Salary Grade of
25 $80,922.00.
26 763. However, it is for the Court and Jury to decide whether Plaintiff was
27 entitled to a salary increase according to the UC Davis Title Code 7182 for the Associate
28

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1 Development Engineer position or whether Defendant was not obligated to increase the
2 Plaintiff’s salary according to the UC Davis or University of California pay policies and Title
3 Codes or by the Settlement-Agreement is governing the Plaintiff’s salary.
4 764. In May 2011, the Defendants corrected Plaintiff’s salary pursuant to UC
5 Davis Title Code 7182, Middle Salary – Grade $71, 600 /year without correcting the Settlement -
6 Agreement or retroactively altering the pay difference from February 2009 to May 2011 instead
7 of the 3rd Step Salary Grade of $80,922.00.
8 765. Instead of the 3rd Step Salary Grade Increase, Plaintiff, in May 2011,
9 experienced an unthinkable attack by the Defendants, including sabotaging Plaintiff’s job and
10 having a manager stalk Plaintiff in an attempt to force Plaintiff to quit his job and to prepare for
11 the termination of the Plaintiff’s employment at the HVAC Shop.
12 766. Per the Settlement Agreement, Plaintiff agreed to work at the UC Davis
13 Medical Center, Heating, Ventilation, and Air Conditioning (HVAC) shop in good faith and
14 agreed not to sue Defendants for the adverse unlawful retaliatory actions that the Defendants
15 took against Plaintiff between 2006 and 2008.
16 767. However, the Defendants in 2011–2012 entirely disregarded, breached,
17 and violated the signed settlement, turning Plaintiff’s livelihood into a living hell and terminating
18 Plaintiff without a valid reason on December 7, 2012, thus causing Plaintiff enormous financial
19 losses estimated at approximately one million dollars in wages and benefits alone, not to
20 mention other damages to which Plaintiff is entitled as a result of the suffering caused by the
21 inhumane adverse actions of Defendant against Plaintiff during the course of Plaintiff’s
22 employment with the University of California and after Plaintiff’s employment termination.
23 768. Plaintiff refers to the allegations contained in the paragraphs, including
24 subparagraphs 1 through 760, inclusive, and incorporates each by reference as though fully set forth at
25 length herein.
26 769. The contract between the Plaintiff and the Defendants is and was at all relevant
27 times a written contract. The written contract is attached to this complaint as Exhibit 1. Plaintiff hereby
28

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1 incorporates into this complaint each term, condition, and paragraph of the contract as required by law.
2 Pursuant to the contract entitled SETTLEMENT- AGREEMENT, Defendants promised Plaintiff an
3 exempt position in the UC Davis Medical Center HVAC /Plumbing Shop with the title of Assistant
4 Development Engineer after Plaintiff prevailed in November 2008 in the arbitration process against
5 Defendants after Defendant made an attempt to terminate unsuccessfully Plaintiff’s employment in 2007.
6 770. In 2009, Plaintiff understood and still understands that by signing the
7 Settlement –Agreement with the Defendant, any differences or problems which arose during the
8 course of the Plaintiff’s employment with Defendants would be resolved in good faith by both
9 parties and that the parties would inform each other about any suspected, occurred, alleged, or
10
implied violation or breach of the signed Settlement – Agreement before the parties exercise
11
legal remedies to enforce the Settlement Agreement or change the venue of the Settlement
12
Agreement pursuant to §16. MODIFICATIONS IN WRITING ONLY.
13
771. This document may not be modified except by written amendment,
14
characterized as such and signed by the parties.; § 20 CALIFORNIA LAW This Agreement is
15
made and entered into in the State of California and shall in all respects be interpreted and
16
enforced in accordance with California law and § 21 BINDING EFFECT. This Agreement
17
shall bind the heirs, personal representatives, successors, and assignments of each party and inure
18
to the benefit of each party its heirs.
19
20 772. Plaintiff in November 2008 did not realize that the prevailing, in
21 arbitration, and signing the Settlement – Agreement in February 2009 in good faith with the
22 Defendant was only a short time before Defendants would carry out their evil-spirited plan to
23 terminate the Plaintiff’s employment. The Plaintiff outlined and described the extreme,
24 outrageous, atrocious, and utterly intolerable conduct of the Defendants in paragraphs and
25 subparagraphs 1 through 144.
26 773. The Defendant, the Regents of the University of California, by and through its
27 own employees, agents, and officers, kept Plaintiff out of the workplace for over one year for no apparent
28

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1 reason. Defendants placed Plaintiff on Investigatory Leaves, Administrative Leaves, yet the evidence
2 shows, beyond a shadow of a doubt that UC DAVIS was intentionally keeping plaintiff out of the work
3 location promised in the contract and was waiting to find a pretext or basis to terminate Plaintiff’s
4 employment. This happened for only one reason: because Defendant negotiated the long-awaited power
5 sale contract for UC Davis Medical Center Central Plant with the Sacramento Municipal Utility District.
6 The Defendants apparently were falsely informed through their employees, agents, and officers that
7 Plaintiff was an imminent threat to their obtaining the long awaited and profitable power sale contract.
8 774. After keeping Plaintiff out of the work place for almost one year, the Defendants
9 could not find the pretext or basis to terminate Plaintiff because there were none. They then ordered their
10 own employees, agents, and officers to exercise the criminally minded plan to provoke and assassinate
11 Plaintiff on May 31, 2012, using the UC Davis Police force.
12 775. The Defendants plan failed. The Defendant then made the attempt to repeat the
13 May 31, 2012, heinous plan to kill Plaintiff in September 2012 but the plan was canceled because Plaintiff
14 warned Defendant and Defendant’s agents and officers on September 10, 2012 that Plaintiff was aware
15 that May 31, 2012, was the date that the Defendants’ unsuccessful provocation was ill crafted to harm
16 Plaintiff.
17 776. According to the Settlement-Aagreement, §19 MUTUAL NON-
18 DISPARAGEMENT neither the Plaintiff nor the Defendants were to disparage each other. Plaintiff at all
19 times expressed his good faith beliefs in the truth. When, in reality, Plaintiff was a valuable employee,
20 who had the best interests of the hospital always in mind, the Defendants not only disparaged Plaintiff
21 but made Plaintiff look like the most-wanted criminal.
22 777. In September 2012, two month before Plaintiff’s employment termination, the
23 Defendant ordered own officers, agents, and UC Davis Police to issue a poster similar to the FBI’s “Most
24 Wanted” criminals posters with Plaintiff’s photo and description on. The issued UC Davis Police
25 poster was distributed around UC Davis Campuses without informing Plaintiff about it. The Defendants
26 wrongfully terminated Plaintiff’s employment on December 7, 2012.
27 778. The written Settlement - Agreement contains an implied covenant of good
28

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1 faith and fair dealing or an understanding that neither party will do anything unlawful and/or take
2 action that undermines and/or deprives plaintiff of one or more of the benefit of the bargain.
3 Further to this, as long as Plaintiff performed his duties in a manner that met or exceeded
4 expectations, he would be entitled to work and remain in the job until his retirement age.
5 779. The Defendants breached this contract by subjecting the 60-year-old
6 Plaintiff to a hostile work environment and psychological terror. This terror was carried out and
7 orchestrated by the Defendant’s own agents and officers for over one year, including keeping
8 plaintiff away from the workplace for over one year, retaliating for no reason whatsoever against
9 Plaintiff, and terminating his employment without one single statement, word ,allegation, or
10 notification in the April 2012 Notice of Intent to Suspend, the May 2012 Letter of Suspension, the
11 September 25, 2012 Notice of Intent to Terminate Plaintiff Employment, the December 5, 2012
12 Letter of Termination, and five bogus pseudo investigation reports that the Defendants’ officers
13 fabricated as a cause for Plaintiff employment termination without one word in reports that
14 Plaintiff breached the signed contract thereby defacing and defaming Plaintiff.
15 The aforementioned acts constitute material breaches of the contract.
16 780. Plaintiff seeks and is entitled to all special and consequential damages as allowed
17 by law, including but not limited to lost income, benefits, that Plaintiff would have enjoyed as an exempt
18 employee under the written contract. The contract provides for and Plaintiff seeks costs as well as
19 attorney fees.
20 781 Due to breach and violation of the contract and wrongful termination of Plaintiff
21 employment, Plaintiff prays for the Judgment against the Defendants for monetary and punitive damages
22 due to Plaintiff as follows:
23 The 2011 Plaintiff’s Losses Due to Breach and Violation of the Contract by Defendants
24
782. The 2011 Plaintiff’s annual base salary was $71,600 and Defendant paid
25
26 to Plaintiff only $63,271.60.
27
783. The Plaintiff loss of 2011 base salaries earnings were $8,328.40 plus 10% daily
28

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1 compound interest for the time period until the Defendants pay the damages. The Plaintiff’s loss of
2 income in the above-mentioned amount occurred and are due to Plaintiff because of the Defendants’
3 despicable retaliatory action against Plaintiff by keeping Plaintiff out of the premises on administrative
4 leave without pay and denying him short-term disability benefits in conspiracy with Liberty Assurance
5 Company of Boston.
6 784. In addition to the base $ 8,328.40 salary loss, Defendant shall compensate
7 Plaintiff for 158.69 hours of accrued sick leave and 163 hours of vacation at the rate of $34.31/hour in
8 the amount of $11,037.00 plus 10% daily compound interest for the time period until the Defendants pay
9 the damages. Plaintiff would have used his accrued sick leave and vacation hours due to the enormous
10 infliction of emotional distress caused by the Defendants’ despicable and inhumane harassment.
11 THEREFORE, Plaintiff prays that Defendants pay total due to Plaintiff for 2011 in sum of
12 $19,365.58 plus 10% daily compound interest for the time period until the Defendants pay to Plaintiff
13 the requested amount.
15
16 785. The Plaintiff’s loss due to breach of contract in 2012 involved base salary
17 earnings of $8,882.00 plus 10% daily compound interest for the time period until the Defendants pay to
18 Plaintiff the requested amount.
19 44.28 hours at a rate of $34.31/hour were accrued or would have been accrued in sick leave if
20 the Defendants had not breached the contract and if Plaintiff had been employed by the Defendants.
21 44.28 hour x $34.1 = $1,519.20 plus 10% daily compound interest for the time period until the
22 Defendants pay Plaintiff the requested amount.
23 THEREFORE, Plaintiff prays that Defendants pay total due to Plaintiff for
24 2012 in sum of $10,401.20 plus 10% daily compound interest for the time period until the Defendants
25 pay to Plaintiff the requested amount.
26
27 The Plaintiff’s Employment Termination by the Defendant Five Years prior to the Plaintiff’s
28

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full Social Security Retirement at Age 66 on May 30, 2017 or December 31, 2017.
1
2 786. The Plaintiff’s base salary earning from January 1, 2013, to December 31, 2017,
3 would be $358,200 if the Defendants had not breached the contract, and Plaintiff would have earned the
4 above amount until Plaintiff retired at the age of 66 and a half on December 31, 2017, as Plaintiff planned
5 to do.
6 787. The Plaintiff’s earning would be higher if Plaintiff were to receive pay raises in
7 this period or if the Defendants would reclassify Plaintiff’s annual salary. The Middle Salary Grade for
8 Associate Development Engineer pursuant to the UC Davis Title Code 7182 has been changed
9 effective July 1, 2014 from $ 71,640.00 to $76,600.00 annually.
10 $71,640 base annual salary x 5 years = $358,200. Plaintiff would earn this if
11 employed by the Defendants plus 10% daily compound interest for the time period until the Defendants
12 pay the requested amount.
13 THEREFORE, Plaintiff prays that Defendants pay total due to Plaintiff in sum of
14 $358,200 plus 10% daily compound interest
15 788. The 221.4 hours of accrued sick leave and 886.2 hours of accrued vacation
16 at a pay rate of $34.31 = $38,001.00. Plaintiff would earn this if employed by the Defendant plus
17 10% daily compound interest for the time period until the Defendants pay the requested amount.
19 $38.001 plus 10% daily compound interest
20
21 The Plaintiff’s University of California Retirement Income and Plaintiff Social

Security Benefits Income
22
23
789. Defendants breached the signed contract with Plaintiff and unlawfully
24
terminated Plaintiff on December 7, 2012 at the age of 61 and a half. The Plaintiff, at age 61 and
25
a half, was not eligible to receive even the earlier Social Security income benefits for which
26
Plaintiff could apply in May 2013. For the full Social Security income benefit would have work
27
until year 2017.
28

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1 790. Besides the Social Security income, Defendant slandered and defaced
2 Plaintiff with State Of California Employment Development, and Plaintiff was denied
3 Unemployment Insurance benefit, thus the Defendant left Plaintiff without any income. The
4 Defendant caused Plaintiff to be denied unemployment insurance benefits for only one reason: to
5 justify retaliation against Plaintiff. However, Defendants forgot about the signed contract that
6 governed Plaintiff’s employment since February 2009 and which was grossly breached by the
7 Defendant.
791. Besides breaching the contract, the Defendants violated the Skelly Law
8
9 and terminated the 61-and-a-half-year-old Plaintiff without the possibility of the Plaintiff being
10 hired by any employer at his age, thus depriving Plaintiff of any income until Plaintiff received
11
earlier retirement Social Security income benefit at age of 62 or the University Retirement
12
Benefits.
13
14 In Skelly v. State Personnel Board (1975) 15 Cal. 3d 194, the California

15 Supreme Court ruled that: "as part of constitutionally guaranteed due process,
16 public employees are entitled to certain procedural safeguards before discipline
17
which is sufficiently severe to constitute a deprivation of a liberty or property
18
right is imposed on them. The constitutionally protected liberty interests
19
requiring Skelly protections arise whenever the allegations against an employee
20
are sufficiently onerous to seriously impact the employee's ability to find future
21
work in his/her chosen career."
22
23 792. By Breaching contract and violating the Skelly Law, the Defendants
24 terminated Plaintiff without the possibility of finding other employment at his age and with his
25 health. They denied Plaintiff’s unemployment insurance benefits, thus Plaintiff was left without
26 any income, health insurance, or life insurance.
27 793. n such a situation, Plaintiff was forced to cash out a lump sum from his
28

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1 taxable University Retirement Benefits to the amount of $300,000 to maintain his and his spouse’s
2 life at as normal a level as possible for the next few years.
3 794. If the Defendant had not terminated Plaintiff’s employment in December
4 2012 and had employed Plaintiff until 2017, Plaintiff would have had a monthly income to the
5 amount of $2,521 from his University Retirement, which would combine with his $2,105 Social
6 Security income.
7 795. If Plaintiff had been employed until the age of 66, he would have decided
8 to cash out his University Retirement in a lump sum of cash to the amount of $349,057 or more,
9 and accordingly, $397,510, if Plaintiff had been employed until the age of 70.
10 796. The University of California retirees are eligible for medical, dental,
11 vision, legal, and AD&D benefits if they opt into the monthly income retirement benefit instead
12 of receiving a lump sum cash out.
13 Furthermore, any University employee is eligible for retirement benefits in the form of a monthly
14
income or lump sum cash out if employed with the University for least five years and is 59 and a
15
half years old. The Defendants unlawfully terminated Plaintiff’s employment five years prior to
16
his being fully eligible for Social Security Retirement.
17
THEREFORE, Plaintiff prays that Defendants shall compensate Plaintiff to an
18
amount that is equal to the retirement benefits for five years of employment, or $97,510,
19
whichever is greater.
20
797. The Defendants, due to their breaching contract, unlawfully terminating
21
Plaintiff in December 2012, and forcing Plaintiff to take Social Security benefits income at age
22
62.
23
THEREFORE, Plaintiff prays that Defendants , shall pay Plaintiff the difference
24
between the Plaintiff’s earlier Social Security income and Plaintiff’s full Social Security income
25
to the amount of $591/ month since June 2013 and until Plaintiff dies or in lump sum for 25 years
26
or 300 months, which is equal to $177, 300, whichever is more convenient for the Defendants to
27
pay.
28

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1 The Plaintiff’s Health and Dental Insurance
2
3 798. In 2011, Defendants grossly and despicably breached the contract and
4 performed inhumane harassment of the Plaintiff in an attempt to terminate Plaintiff or force him
5 to quit. The Defendant, through town agents and officers, de-enrolled Plaintiff from the Medical
6 and Dental Health Insurance benefits and denied Plaintiff’s Short Term Disability Insurance
7 benefits when Plaintiff was on stress-related sick leave caused by the Defendants’ agents and
8 officers.
9 799. When Plaintiff noticed in January 2012 that the Defendants had de-enrolled
10 Plaintiff from the Health and Dental Insurance and changed Plaintiff’s position without the
11 Plaintiff’s knowledge from an Associate Development Engineer to Programmer I (Demotion),
12 Plaintiff thought that Plaintiff would be terminated soon and so Plaintiff’s spouse enrolled Plaintiff
13 in her employer Nordstrom’s Corporation Health and Dental Insurance Benefits in January 2012.
14 Thanks to Plaintiff’s wife’s employer, Plaintiff has Health and Dental Insurance coverage
15 including medicine.
16 800. The Defendants re-enrolled Plaintiff into the Health and Dental Plan in
17 January 2012 but Plaintiff did not de-enroll himself from his spouse’s employer health insurance
18 and dental plan because he would be not able to re-enroll if Defendants terminated Plaintiff’s
19 employment, which occurred in December 2012.
20 801. Since February 2012, Plaintiff maintained his health and dental insurance
21 with his spouse’s employer Nordstrom Corporation, and this insurance would be maintained until
22 Plaintiff’s spouse’s retirement in September 2017. This increased the Plaintiff’s spouse’s monthly
23 premium for health and dental insurance from $94.00/month to $382.00/month. The difference
24 in premium, which is $288/month.
25 THEREFORE, Plaintiff prays that Plaintiff , shall be compensated by the Defendants
26 from February 2012 to September 2017 until Plaintiff’s wife retires from Nordstrom at age 66,
27 which is 56 months x 288= $16,128.00 total sum due to Plaintiff
28

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1
The Plaintiff’s Supplemental Life Insurance, Accidental Death and
2
Dismemberment, and Dependents Life Insurance
3
4 802. For 13 years of employment with the University of California, Plaintiff was
5 paying premiums every paycheck to the amount of $149.90 for Supplemental Life Insurance, A&D,
6 and Dependents Life Insurance, totaling $23,384 in premiums alone for 13 years. Plaintiff was
7 insured by Supplemental Life Insurance to the amount of $280,000, by Accidental Death and
8 Dismemberment Insurance to the amount of $500,000, and by Dependents Life Insurance to the
9 amount of $100,000.
10 803. The Defendants erased the above-mentioned Plaintiff’s benefits due to their
11 reckless violation of a signed contract with Plaintiff and unlawfully terminating Plaintiff’s
12 employment on December 7, 2012, at the of age 61 and a half, knowing that the Plaintiff had had
13 open-heart surgery and other health problems and that Plaintiff, at his age and health, would either
14 not be able to obtain Life Insurance, Accidental Death and Dismemberment, and Dependents Life
15 Insurance at all or, if so, that the premiums would be so high that Plaintiff wouldn’t even be able
16 to dream about having Life Insurance.
17 804. Due to their breach and violation of the signed February 2009 contract with
18 Plaintiff, the Defendants are liable for paying his spouse the mentioned benefits if Plaintiff dies.
19 THEREFORE, Plaintiff prays that Defendants pay the mentioned benefits to his
20 spouse if the Plaintiff dies.
21 805. The other option is that Plaintiff will find an insurance company that would be
22 willing to provide these benefits to Plaintiff and Defendant will pay the premiums until the
23
Plaintiff dies. EXAMPLE: Banner Life Insurance Company-
24
Semi-Annually: 4,720.05Quarterly:2,406.30Monthly (EFT):809.81
25
26 The Plaintiff’s House in Lodi, California.

27
28

Page 284 of 285
1 806. In 2003, Plaintiff bought a four-bedroom, two-bathroom house with a brand
2 new built-in 10” deep swimming pool for the price of $315,000 when house market prices were
3 being manipulated by Banks and Mortgage Companies.
4 807. Plaintiff was able to maintain the high monthly mortgage payment working
5 in the UC Davis Medical Central Plant as an operator with overtime, holiday pay, and shift
6 deferential pay as an extra income.
7 808. In March 2007, the Defendants abruptly and unlawfully removed Plaintiff
8 from the Central Plant and reassigned Plaintiff to UC Davis Medical Center HVAC Shop, thinking
9 that Plaintiff would be interfering with the Defendants efforts to negotiate and obtain millions of
10 dollars from an electric power sale contract with the Sacramento Municipal Utility District
11 (SMUD). The Defendants lost their previous contract in 2003 or 2004 and, since then, have lost
12 millions of dollars in revenue because the surplus energy from the Central Plant was no sold.
13 809. In 2009, Plaintiff signed the Settlement – Agreement (contract) with the
14 Defendants and, in good faith, agreed to work permanently at the UC Davis Medical HVAC shop
15 as an exempt employee and was given an Associate Development Engineer Position by contract.
16 810. In 2011 and 2012, the Defendants recklessly violated and breached the
17 signed contract. In fear and panic after losing his job, Plaintiff sold his house on short sale in fall
18 2012, informing the Defendants about prior to the sale on September 10, 2012 by letter to Brent
19 Seifert ( See page No .171-172) The Defendants did not care about devastating Plaintiff’s or
20 Plaintiff’s spouse’s livelihood or emotions, and the Plaintiff’s spouse had wanted to keep this
21 house for the rest of her life.
22 811. Plaintiff was lucky that two weeks prior to the termination, Plaintiff was
23 able to rent a home with a monthly rent of $1,765.
24 812. Due to losing his house, Plaintiff has no tax deduction and is paying huge
25 amounts of taxes, draining his University Retirement instead of having a tax return.
26 813. Due to the breach of contract and unlawfully terminating Plaintiff’s
27 employment, the Defendants are fully liable for the Plaintiff’s lost house and the fact that he and
28

Page 285 of 286
1 his spouse are devastated financially and emotionally.
2 THEREFORE, Plaintiff prays that Defendants pay $450,000 for inflicted damages in
3 relation to Plaintiff’s house so that Plaintiff can buy new house and restore his and his spouse’s normal
4 life they had have the prior reckless breach of contract by the Defendant .
5 814. Plaintiff refers to the allegations of breach of the Settlement Agreement with
6 evil spirit by the Defendant the paragraphs, including subparagraphs 1 through 813, inclusive, and
7 incorporates each by reference as though fully set forth at length herein.
8 815. Defendant breached the 2009 Settlement –Agreement by acting in concert
9 with intent to cause Plaintiff severe emotional distress. The evidence is clear and convincing, at
10 the least, that the Defendant, with premeditation, undertook acts that denied the reality of the abuse
11 experienced by Plaintiff and fabricated nature of the “complaints” made about Plaintiff.
12 816. The acts and omissions as alleged herein, separately and taken together, are
13 so extreme and outrageous that the Defendant, and each of them, acted outside the course and
14 scope of their employment with the University of California . The depth, length of time, and nature
15 of the acts are so extraordinary that no reasonable person can conclude such acts and omissions
16 are within the course and scope of duties as a manager, supervisor, or officer of a public entity
17 such as and including University of California .
18 817. Defendant’ breach of signed contract with evil spirit and bad faith as herein alleged
19 do, and did, constitute extreme and outrageous conduct.
20 818. Defendant’ by breaching the contract acted with intent of causing, or with reckless
21 disregard for the probability of causing, severe emotional distress to Plaintiff.
22 WHEREFORE Plaintiff prays for judgment as proximate result of breaching the contract
23 the acts alleged herein Plaintiff suffered severe or extreme emotional distress, entitling Plaintiff to
24 damages, including but not limited to, medical expenses, lost income, other special damages,
25 general damages, and exemplary damages, all in an amount to be proven at trial.
26
Breach of the Settlement –Agreement by the Defendant and Infliction of Emotional Distress
27 to Harm Plaintiff
28 819. To be sure, Defendant, and Defendant’s agents sand officers knew Plaintiff is, and

Page 286 of 287
1 was at all relevant times, precise in his work, could be counted on to keep management informed
2 of the status of the plant and equipment, committed to the future success of the Medical Center,
3 and rightfully and lawfully expected that no person, let alone supervisors, managers, Human
4 Resource personnel, and others would be dishonest, fabricate stories about him, disregard evidence,
5 disregard policies and practices for impartial investigations, disregard Defendant’ actions on
6 Plaintiff’s well-being, and/or set about to cause him emotional harm, all with the intent to ensure
7 that Plaintiff never returned to work again.
8 820.. Defendant and Defendant’s officers and agents by breaching and disregarding the
9 signed Settlement –Agreement alleged in ( knew that their actions, including but not limited to
10 the actions described herein, as well as their actions issuing investigatory leaves in violation of
11 policies and procedures, would cause and did cause Plaintiff to suffer severe emotional distress,
12 especially when not one person left employed by University of California looked at, considered,
13 and/or analyzed the actual evidence.
14 821. The only conclusion that is more likely than not, actually clear and
15 convincing, considering all the evidence, outlined in Plaintiff’s referred allegations contained in the
16 paragraphs, including subparagraphs 1 through 760, inclusive, and incorporates each by reference as
17 though fully set forth at length herein.
18 822. Defendant and Defandant’s agents and officers and each of them,
19 coordinated their actions, conferred with each other, and otherwise had a common goal and/or
20 understanding to either force Plaintiff to quit and/or force him to act or behave in ways that would
21 provide them a subterfuge for his termination. Meanwhile, Defendant, and Defendant’ s agents
22 and officers set about to extricated Plaintiff from his employment because Plaintiff was a
23 suspected whistleblower, and a significant percentage of employees who report misconduct suffer
24 retaliation, abuse, harassment, and ultimately separation from their employment.
25 823. Plaintiff by signing the Settlement-Agreement in February 2009 with Defendant
26 had a reasonable expectation that his employment would be available for him to work, plus benefits,
27 and all other compensation due under the law so long as Plaintiff continued to do his work and
28

Page 287 of 288
1 perform at the workplace as he had since 1999.
2 824. Defendant engaged in the conduct alleged herein with the intent to harm Plaintiff
3 financially and to induce Plaintiff and to violate the Settlement-Agreement, and/or to take away
4 Plaintiff’s property rights in his employment without the benefit of the processes, procedures, and
5 safeguards provided for such things under the law, including the University of California own
6 policies and rules.
7 825. As a proximate result of the breach of the Settlement –Agreement and conduct of
8 Defendant actions and omissions described herein, as well as based on evidence not disclosed
9 herein, Plaintiff was damaged, and continues to experience damages, in an amount that excess
10 $75,000.00 per year, for no less than 5 years, and/or the number of years from the date Plaintiff
11 last received his income to the date Plaintiff intended to retire. When Plaintiff has ascertained the
12 full amount of its damages, it will seek leave of Court to amend this Complaint and/or by evidence
13 at the time of trial provide proof accordingly.
14 826. Plaintiff alleges that Defendant by breaching and violating the signed Settlement
15 –agreement acted with reckless disregard for Plaintiff’s rights and/or failed to perceive, observe,
16 and act as a reasonable person under the same or similar circumstances. Further, said reckless
17 disregard for Plaintiff’s rights and/or negligence were substantial factors in the damages Plaintiff
18 sustained.
19 827. The conduct of on the Defendant as described herein was purposeful and intentional
20 violation and breach of the signed Settlement –Agreement with Plaintiff and Defendant was
21 engaged in for the purpose of depriving Plaintiffs of property or legal rights or otherwise causing
22 injury, and was despicable conduct that subjected to cruel and unjust hardship in conscious
23 disregard of its rights, and was performed with fraud, oppression or malice.
24 828. Plaintiff is informed and believes and thereon alleges that Defendant and
25 Defendant agents , and each of them, by violating and breaching the signed Settlement –
26 Agreement coordinated, cooperated, and/or agreed to misuse, abuse, and/or disregard University
27 of California polices and protections so that they could disregard Plaintiff’s rights to return to
28

Page 288 of 289
1 work intentionally created and caused scenarios that they knew would cause Plaintiff to suffer
2 from anxiety, anger, and emotional distress, because the Defendant knew, based on Plaintiff’s
3 own admissions and the Defendant’ experience that Plaintiff would manifest and/or alleviate his
4 anxiety, anger, and emotional distress by writing and sending letters or emails, which, to the
5 uninformed and/or malice minded person, might seem harsh. However, Defendant, and each of
6 them, knew Plaintiff did not have any history of violence, did not have any history of racism, did
7 not have any history of any discrimination, and his letters and writings misrepresented who
8 Plaintiff is as a person.
9
Government Code Section 12940 provides “It is an unlawful employment practice, (a) For an
10
employer, because of the…national origin, ancestry…mental disability, medical condition… of
11
any person…to bar or to discharge the person from employment or from…to discriminate
12
against the person in compensation or in terms, conditions, or privileges of employment.”
13
WHEREFORE Plaintiff prays for judgment so as to justify an award of exemplary or punitive
14
damages against such Defendant in an amount according to proof at trial.
15
16 The Violation and Breach of Settlement –Agreement by the and Defendant’s Discrimination
against Plaintiff Base on his Mental and Medical Condition
17
18
829. Defendant and Defendant’s agents and officers by breeching and violating the
19
2009 Settlement –Agreement, further discriminated against Plaintiff based on his mental
20
disability and medical condition as described herein.
21
22 830. Defendant and its agents, managers and employees, by violating and breaching the
23 signed Settlement –Agreement with Plaintiff violated California Government Code §12940, by failing
24 to adequately supervise, control, discipline, and/or otherwise penalize the conduct, acts, and failures to
25 act as described herein. As such, Defendant and the Individual Defendant failed to fulfill their statutory
26 duty to take all reasonable and necessary steps to prevent discrimination, harassment, and retaliation from
27 occurring in the workplace, as required by California Government Code §12940(k).
28 831.. Despite Plaintiffs complaints about violation and breach of 2009 Settlement Agreement

Page 289 of 290
1 by Defendant’s agents and Officers, Defendant failed to take steps to prevent the harassment,
2 discrimination and retaliation and to stop breach and violation of the signed contract with Plaintiff.
3 832.. Plaintiff knew he did nothing wrong. Plaintiff initially believed that Defandant would
4 easily determine that fabricating false complaints where none existed for years beforehand. It is
5 undisputed that Plaintiff attempted to persuade Defendant and Defendant’s agents and officers as early
6 as in May 2011 , to settle, resolve, and/or put an end to whatever acrimony might have existed on the
7 part of Defendant, and Defendant’s agents and officers , at the workplace. Defendant, and Defendants
8 agents and officers, never responded to or reacted to Plaintiff’s attempts to live and let live, and to get
9 Plaintiff back to his employment.
10 833. Defendant and Defendant’s agents by purposely and with evil spirit and faith violating
11 and breach the 2009 Settlement –Agreement knew that Plaintiff became distressed, angry, and upset
12 with each and every adverse unfounded adverse employment action, such as but not limited to, a biased,
13 one-sided, and incomplete investigation reports, the lack of meaningful investigation into the misconduct
14 Plaintiff actually reported, or, handing Plaintiff a Notice of Investigatory Leave in September 2011 when
15 Plaintiff believed he was returning to work, or, handing Plaintiff another Notice of Investigatory Leave
16 on May 31, 2012, with a crisis team on stand-by, or, being instructed not to communicate with employees
17 even though Plaintiff represented them.
18 834. Defendant and Defendant’s agents and officers by purposely and with evil spirit violated
19 and breached the signed 2009 Settlement –Agreement with Plaintiff as part and parcel of their ongoing,
20 continuing, and repeated retaliation, harassment, for the purpose to cover up and conceal their
21 misconduct misconduct, violation of state and federal law ,engaged in a course of action that constituted,
22 separately and cumulatively, discrimination, harassment and retaliation because of national origin,
23 ancestor, mental condition, and/or medical condition.
24 835. The discrimination, harassment and retaliation are continuous and persist to date against
25 Plaintiff.
26 836. As a result of violation and breach of 2009 Settlement –Agreement by Defendant and
27 Defendant’ and Defendant’s agents and officers failure to take reasonable steps to prevent the
28

Page 290 of 291
1 discrimination, harassment and retaliation, Defendant and Defendant’s agents and officers every day and
2 week occupied themselves with new harassing, retaliatory plans to drive Plaintiff out of out of University
3 of California, disparage him, or take compensation from him. Plaintiff has suffered substantial economic
4 losses in wages and benefits, damages to reputation, credit and other financial injuries in an amount to
5 be determined at trial.
6 834. As a result of Defendant’ breach and violation of the 2009 Settlement –Agreement signed
7 with Plaintiff harassment and discrimination and the failure to prevent and/or take reasonable steps to
8 prevent discrimination and harassment,
9 THEREFORE, Plaintiff prays that Defendants Plaintiff requests the award of attorneys’ fees against
10 Defendant under pursuant to California Government Code §12965.
11
The Purposed Violation and Breach of Settlement –Agreement by the
12
Defendant’s ,Retaliation and Discrimination against Plaintiff for the reason to Cover Up and
13 Condone Defendant’s Officers and Agents Unlawful Activities , Frauds and Corruption
Reported by Plaintiff is Violation of the Government Code Section 8547 et. seq
14
835. Plaintiff’s disclosures and reports concerned, or Plaintiff had a good faith belief that his
15
disclosures concerned, activity by and/or conditions existing due to misconduct, including but not limited
16
to waste, fraud, abuse of authority, violation of law, or threat to public health.
17
836. Plaintiff’s reports include, but are not limited to, reports of the coordinated efforts to deny
18
him his employment as well as the apparent ratification and/or complicity of officers of the UC system.
19
837. The outrageous conduct of the Defendant described above was done with malice, fraud
20
and oppression and with reckless disregard for the rights of Plaintiff.
21
838. Plaintiff seeks all available damages including punitive damages for breach of the
22
settlement agreement and retaliation against Plaintiff as for reporting Defendant and Defendant’s agent’s
23
waste and misuse of University’s resources, misconduct and violation of the state and federal laws and
24
regulations
25
THEREFORE, Plaintiff prays that requests the assessment of exemplary and punitive damages
26
against Defendant, in an amount appropriate to punish and make an example of Defendant. .
27
28

Page 291 of 292
The Violation and Breach of Settlement –Agreement by the Defendant in Regards to § No. 7
1
and § No 8. of the settlement –agreement
2
3
839. Defendant and Defendant’s agents and officers purposely and with evil spirit
4
violated and breached the signed 2009 Settlement –Agreement with Plaintiff as part and parcel
5
6 of their ongoing, continuing, and repeated retaliation, harassment, for the purpose to cover up
7 and conceal their misconduct, violation of state and federal law ,engaged in a course of action
8
that constituted not be released from liability under § No. 7 and § No 8. of the settlement –
9
agreement to be sue for and Defendant is liable for violation of not limited to the Immigration
10
Reform and Control Act; the Family Medical Leave Act and the Higher Education Employer-
11
12 Employee Relations Act, Title VII of the Civil Rights Act of 1964, as amended by the Civil
13 Rights Act of 1991, the California Fair Employment and Housing Act, the Americans with
14
Disabilities Act, the Equal Pay Act of 1963, the Age Discrimination in Employment Act), the
15
law of contract and tort; the Age Discrimination in Employment Act of 1967.
16
17 VII. SECOND CAUSE OF ACTION

18 [VIOLATION OF THE HEALTH & SAFETY CODE SECTION 1278.5]]
19 COMES NOW Plaintiff, and for a Second Cause of Action, alleges against Defendant,
20 THE REGENTS OF THE UNIVERSITY OF CALIFORNIA, UNIVERSITY OF CALIFORNIA
21 and Does 1 through 50, as follows:
22 840. Plaintiff refers to the allegations contained in paragraphs, including subparagraphs, 189
23 through 760, inclusive, and incorporates each by reference as though fully set forth at length herein.
24
841. Selling live animals goats, ducks, sheep, roosters, chickens from the HVAC shop
25
by Defendant officers and having the animal’s defecation around the HVAC Plumbing Shop
26
was not only misuse of a University property and resources but serious disregard of the hygiene
27
28

Page 292 of 293
1 and violation of the health and safety code not to mention that UC Davis Medical Center is a flea
2 market to sell goats an chicken but is it well respected medical facility not mention animal cruelty
3
Plaintiff observed.
4
842. Not one of the more than 12 executives, managers, supervisors, or officers that
5
reviewed the matter recognized that the liability issues alone are substantial enough to warrant
6
severe and serious consequences. Not one of the more than Defendant 12 executives, managers,
7
supervisors, or officers that reviewed the matter so much as mentioned the risk that employees,
8
who interact with the hospital environment, without scrubbing, might be exposed to animal and
9
avian bacteria.
10
11 843. The California Legislature enacted Health & Safety Code Section 1278.5 because
12 “… it is the public policy of the State of California to encourage patients, nurses, members of the
13 medical staff, and other health care workers to notify government entities of suspected unsafe
14 patient care and conditions. The Legislature encourages this reporting in order to protect patients
15 and in order to assist those accreditation and government entities charged with ensuring that health
16 care is safe. The Legislature finds and declares that whistleblower protections apply primarily to
17 issues relating to the care, services, and conditions of a facility and are not intended to conflict
18 with existing provisions in state and federal law relating to employee and employer relations…”
19 (Emphasis Added)
20 844. Section 1278.5(b) (1) provides “No health facility shall discriminate or retaliate, in
21 any manner, against any patient, employee, member of the medical staff, or any other health care
22 worker of the health facility because that person has…Presented a grievance, complaint, or report
23 to the facility, to an entity or agency responsible for accrediting or evaluating the facility, or the
24 medical staff of the facility, or to any other governmental entity…” (Emphasis Added)
25 845. Section 1278.5(d)(1) states (d) (1) There shall be a rebuttable presumption that
26 discriminatory action was taken by the health facility, or by the entity that owns or operates that
27 health facility, or that owns or operates any other health facility, in retaliation against an employee,
28

Page 293 of 294
1 member of the medical staff, or any other health care worker of the facility, if responsible staff at
2 the facility or the entity that owns or operates the facility had knowledge of the actions,
3 participation, or cooperation of the person responsible for any acts described in paragraph (1) of
4 subdivision (b), and the discriminatory action occurs within 120 days of the filing of the grievance
5 or complaint by the employee, member of the medical staff or any other health care worker of the
6 facility”
7 846. Section 1278.5(d)(2) provides “…For purposes of this section, discriminatory
8 treatment of an employee…includes, but is not limited to, discharge, demotion, suspension, or any
9 unfavorable changes in, or breach of, the terms or conditions of a contract, employment, or
10 privileges of the employee.”
11 847. Defendant, and each of them, were well aware of Plaintiff’s disclosures to the
12 facility of deficiencies and problems within the HVAC Plumbing Shop as well as the function and
13 operation of the Metasys alarm monitoring system. Each disclosure by Plaintiff related to and
14 concerned matters that directly impacted, or reasonably and foreseeable would impact, the safe
15 and healthy condition of the hospital.
16 848. Each of Plaintiff’s disclosures occurred within 120 days of Plaintiff notifying
17 and/or complaining to the Defendant
18 .
19
WHEREFORE, Plaintiff prays for Judgment against Defendant, as follows:
20
1. for general and compensatory damages according to proof;
21
2. For lost salary, both front and back pay, bonuses, benefits and any other benefits to which
22
Plaintiff would have been entitled to by reason of his employment with Defendant UC
23
REGENTS, according to proof;
24
3. Punitive and exemplary damages against Defendant;
25
4. Damages and attorney fees as allowed under the Labor Code;
26
5. for prejudgment interest at the maximum rate allowed by law;
27
7. For costs of suit incurred herein;
28

Page 294 of 295
1 8. Damages for retaliation in to Government Code 8547 including punitive damages
2 against Defendant, and Attorney’s fees;
3 9. Breach of contract damages, including costs and attorney fees;
4 10. Damages, Costs, attorney fees, and all other allowable damages and relief
5 authorized under Health & Safety Code § 1278.5
6 11. For other and further relief as the Court deems just and proper.
7
8 DATED:
9
10 By: _________________________
11
13 Plaintiff In Pro Per

14
15
16
17
18
19
20
21
22
23
24
25
26
27
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Page 295 of 295
1 P O R T E R I S C O T T
2 A PROFESSIONAL CORPORATION FILED/ENDORSED

David P. E. Burkett, SBN 241896 ,
3 Daniel J. Bardzell, SBN 313993
350 University Avenue, Suite 200 OCT - 3 2018
4 Sacramento, Califomia 95825
TEL: 916.929.1481
5 FAX: 916.927.3706 By: E, Medina
Deputy Clerk
dburkettfgjporterscott.com
6
7 Attorney for Defendant
8 REGENTS OF THE UNIVERSITY OF CALIFORNIA
9 Exempt From Filing Fees Pursuant to Government Code § 6103
10 SUPERIOR COURT OF CALIFORNIA, COUNTY OF SACRAMENTO
11 JAROSLAW ("JERRY") WASZCZUK, CASE NO. 34-2013-00155479
12
o
o Plaintiff, DEFENDANT'S POINTS AND
tN 13 AUTHORITIES IN SUPPORT OF
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VD DEFENDANT'S MOTION TO COMPEL
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VERIFIED RESPONSES TO REQUESTS
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ON ON FOR PRODUCTION OF DOCUMENTS
u
t/3 OV Cv OF CALIFORNIA, UNIVERSITY OF SET ONE, SPECIAL
b- J X .16 CALIFORNIA. DAVIS HEALTH INTERROGATORIES SET ONE, FORM
oI w <
f- tu SYSTEM, UC DAVIS MEDICAL INTERROGATORIES - GENERAL SET
17 CENTER, UC DAVIS, ANN MADDEN
o ONE, FORM INTERROGATORIES -
18 RICE, MIKE BOYD, STEPHEN EMPLOYMENT SET ONE; TO DEEM
CHILCOTT, CHARLES WITCHER, REQUEST FOR ADMISSIONS
19 DANESHA NICHOLS, CINDY ADMITTED; AND FOR MONETARY
OROPEZA, BRENT SEIFERT, AND TERMINATING SANCTIONS
20 PATRICK PUTNEY, DORIN
21 DANILIUC, and Does 1 through 50, Date: October 31, 2018
inclusive. Time: 9:00 a.m.
22 Dept.: 54
23 Defendants.
Complaint Filed: December 4, 2013
24 Amended Complaint Filed: June 16, 2014
SAC Filed: September 30, 2014
25
26
27
28
{01892012.DOCX}
DEFENDANT'S POINTS AND AUTHORITIES IN SUPPORT OF DEFENDANT'S MOTION TO
COMPEL VERIFIED RESPONSES
Defendant REGENTS OF THE UNIVERSITY OF CALIFORNIA (the "UNIVERSITY" or
"DEFENDANT") respectfully submits the following memorandum of points and authorities in
support of its motion to: (1) compel Plaintiff JAROSLAW ("JERRY") WASZCZUK's verified
4 responses to Requests for Production of Documents (Set One), Special Interrogatories (Set One),
5 Form Interrogatories - General (Set One), Form Interrogatories - Employment (Set One.); (2) deem
6 Defendant's Request for Admissions (Set One) admitted; (3) award monetary sanctions in the
amount of $5,200.00 to retum Defendant to the position it would have been had the subject
discovery responses been timely provided; (4) issue terminating sanctions against Plaintiff as a
result of Plaintiffs pattem of vexatious litigation tactics and failure to engage in the discovery
10 process; and (5) impose a deadline for Plaintiff to seek leave to file a Third Amended Complaint.
I.
11
INTRODUCTION
12 Defendant served Plaintiff with Requests for Production of Documents (Set One), Special
13 Interrogatories (Set One), Form Interrogatories - General (Set One), Form Interrogatories -
^ ^ ~
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14 Employment (Set One) and Requests for Admissions (Set One) on April 25, 2018. Responses were
> ^ ov ov
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16 provide responses to the requests. Plaintiff has completely failed to respond to any written
17 discovery and responses are overdue.
18 Defendant respectftilly requests the Court issue an Order to (1) compel Plaintiff to provide
19 verified responses to Defendant's Requests for Production of Documents (Set One), Special
21 Employment (Set One) and Request for Admissions (Set One); (2) deem Defendant's Request for
22 Admissions (Set One) admitted; (3) issue monetary sanctions against Plaintiff in the amount of
23 $5,200.00 for Defendant's fees and costs incurred in bringing this motion; and (4) issue the sanction
24 of termination of the present action as a result of Plaintiffs failure to provide responses to the
25 Defendant's written discovery despite receiving an extension of time to do so and in light of
26 Plaintiffs pattem of vexatious litigation tactics throughout the course of this litigation. Moreover, if
27 the Court is not willing, at this stage, to terminate the action, it should impose a reasonable deadline
28 of two weeks for Plaintiff to seek leave to file a Third Amended Complaint, if Plaintiff intends to
{01892012.DOCX} ' • 1
1 further amend his complaint.
2 II.
STATEMENT OF FACTS AND PROCEDURAL HISTORY
3
4 Defendant UNIVERSITY served Plaintiff with Requests for Production of Documents (Set
5 One), Special Interrogatories (Set One), Form Interrogatories - General (Set One), Eorm
6 Interrogatories - Employment (Set One), and Requests for Admissions (Set One) on April 25, 2018!
7 (See Declaration of Daniel Bardzell in Support of Motion to Compel ("Bardzell Decl."), ^ 2 and
8 Exhibit A.) By correspondence dated May 22, 2018, Plaintiff requested an extension of time to
9 respond to all such requests on the basis that he was sick. (See Bardzell Decl., 3 and Exhibit B.)
10 Defendants responded by email correspondence dated May 23, 2018 granting Plaintiff an extension
11 of time to respond until June 20, 2018. (See Bardzell Decl., Tl 4 and Exhibit C.) Plaintiff completely
12 failed to respond to any such request by June 20, 2018 and same are currently overdue. (See
o
o
13 Bardzell Decl., H 4.)
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14 On Septernber 24, 2018, counsel for Defendant served a meet and confer correspondence
o g-=ôv Ovov ^
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15 upon Plaintiff regarding the outstanding discovery responses wherein defense counsel indicated:
VD
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•b p-J X 16 [P]lease provide complete responses to all such outstanding requests no later than September 28,
UJ <
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o
17 2018. If we do not have your complete responses by that date, we will file a niotion to compel
1^
18 responses and request monetary as well as terminating sanctions from the Court." (See Bardzell
19 Decl., H 5 and Exhibit D.)
20 By incoherent email correspondence also dated September 24, 2018, Plaintiff indicated, in
21
part:
22 Thank you for news about the Request for Production of Documents and Special
Interrogatories , I appreciate but I not sure yet what I am going to . I am waiting for
23 answers from the federal authorities in this matter.
I will let know . I mean time you can entertain yourself with my affirmative defense
24
of Judge Brett Kavanaugh. As Jeanine Pirro stated not so long ago , . UC Regent wife
25 Senator Feinstein's Unhinged Demon Rats attacking Judge Kavanaugh as I was
attacked and wasted by her husband and other unhinged UC demon , rats . Same
26 people only different is that I have no 1 penny on my account and I am for my SS
check on 28^*^ than I could buy ink for my printer and do eventually interrogatories.
27
(See Bardzell Decl., TI 6 and Exhibit E.)
28
{01892012.DOCX}
Plaintiff failed to respond to any of the outstanding discovery requests by September 28,
2018 and same remain outstanding. (See Bardzell Decl., Tl 7.)
3 On October 1, 2018, Plaintiff submitted an email correspondence to Defendant stating: "I
4 am working on the Interrogatories and other papers. Pleas give one more week to finish. Attached is
a part of interrogatories to show you that I am working on ." (See Bardzell Decl., Tl 8 and Exhibit
F.) Included was a rambling apparent partial draft response to Defendant's Special Interrogatories,
Set One without a verification. (See id.)
The course of litigation in this matter is lengthy and complex. The following is a brief
summary: Plaintiff filed the operative Second Amended Complaint ("SAC") on September 30,
10 2014. Among the several claims in the SAC are four causes of action against all named
11 Defendants': (1) intentional infiiction of emotional distress ("IIED"); (2) tortious interference with
12 economic advantage; (3) FEHA harassment and failure to prevent harassment, discrimination,
13 retaliation in violation of Govemment Code § 12940(a); and (4) whistleblower/unlawful retaliation
t 1 S3 _ VO
t/1 u~, 00 o in violation of Govemment Code §§ 8547 e/. ê^.
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.
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Each of these causes of action arises out of Plaintiffs employment with Defendant at the
Od •< o" ^ S '
c o^ 5^ University of Califomia at Davis Medical Center. In addition to Defendant UNIVERSITY^, these
17 causes of action were plead against Defendants ANN MADDEN RICE, MIKE BOYD, STEPHEN
18 CHILCOTT, CHARLES WITCHER, DANESHA NICHOLS, CINDY OROPEZA, BRENT

19 SEIFERT, PATRICK PUTNEY, and DORIN DANILIUC for their participation in investigations
20 and disciplinary actions that ultimately resulted in Plaintiffs termination of employment with the
UNIVERSITY.
21
22 On December 1, 2014, Defendants BOYD, CHILCOTT, NICHOLS, OROPEZA, and
23 SEIFERT ("anti-SLAPP Defendants") filed a Special Motion to Strike Plaintiffs causes of action
24 as pleaded against them. (See Bardzell Decl., Tl 9.) The anti-SLAPP Defendants contended that
25 Plaintiffs causes of action against them arose from protected activities pursuant to Code of Civil
26 Procedure-' section 425.16; namely, their participation in the processing, investigation, hearing and
27 ' The First and Second Causes of Action in the Second Amended Complaint do not specifically identify Defendant UNIVERSITY
but do refer to employment with UC DAVIS within the cause of action.
28 2 See id., fn. I .
^ Unless otherwise indicated, all further statutory references in this Motion are to the California Code of Civil Procedure.
(01892012.DOCX} . 3
deciding of complaints filed by Plaintiff and others pursuant to the policies and procedures of the
Defendant UNIVERSITY. (See id.)
On April 14, 2015, the Court issued an Order granting the Special Motion to Strike finding
that Plaintiff failed to establish a probability of prevailing on the causes of action pleaded against
the anti-SLAPP Defendants as required by section 425.16 and entering judgment in favor of the
anti-SLAPP Defendants. (See Bardzell Decl., Tl 10 and Exhibit G.)
Plaintiff subsequently filed a request for dismissal with prejudice of the four remaining
individual Defendants RICE, WITCHER, PUTNEY, and DANILIUC. (See Bardzell Decl., Tl 11 and
Exhibit H.) The UNIVERSITY is the only Defendant remaining in the case.
10
On May 11, 2015, the anti-SLAPP Defendants filed a Motion for Fees and Costs pursuant to
11
CCP § 425.16, subdivision (c) and the Court's Order dated April 14, 2015 on Defendant's Special
12
Motion to Strike. (See Bardzell Decl., Tl 12.) The motion sought recovery of approximately $33,000
13
• = S—OO VOo in fees and costs incurred by the anti-SLAPP Defendants in connection with the Special Motion to
, 1/5.. ov
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14
Strike.
0^
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ov ov
b c -i X 16 On June 29, 2018, the Court entered an Order granting Defendants' Motion for Fees and
UJ <
a- c « f - Lu
. o 17 Costs in the amount of $22,284 against Plaintiff (See Bardzell Decl., Tl 13 and Exhibit I.)
m
18 Plaintiff has represented that he will seek leave of the court to file a Third Ame;nded
19 Complaint. (See Bardzell Decl., Exhibit B.) At the outset ofthe appeal of the anti-SLAPP motion-
20 well over a year ago - Plaintiff provided Defendants with a draft of his Third Amended Complaint.
21 It is nearly three hundred pages long and includes meritless allegations of a conspiracy to cover-up
22 illegal power sales that purportedly involves all levels of state government, the University of
23 Califomia system, and local jurisdictions, including the Sacramento Municipal Utility District. To
24 date. Plaintiff has not sought leave of the Court to file a Third Amended Complaint.
25 III.
PLAINTIFF SHOULD BE ORDERED TO PROVIDE RESPONSES TO SPECIAL
26 INTERROGATORIES (SET ONE). FORM INTERROGATORIES - GENERAL (SET
ONE) AND FORM INTERROGATORIES - EMPLOYMENT (SET ONE)
27
A party to whom interrogatories have been propounded shall respond in writing under oath
28
{01892012.DOCX} .4
1 separately to each interrogatory by any of the following: an answer containing the information
2 being sought to be discovered, an exercise of the party's option to produce writings, or an objection
3 to the particular interrogatory. (CCP § 2030.210(a).) If a party to whom interrogatories are directed
4 fails to serve a timely response, the party propounding the interrogatories may move for an order
5 compelling response to the interrogatories. (CCP § 2030.290(b).) The party also waives objections
6 to the interrogatories (including those based on privilege and work product) by failing to respond
7 by the deadline. (CCP § 2030.290(a).)
8 Unlike a motion to compel further responses, a motion to compel responses is not subject to
9 a 45-day time limit, and the propounding party does not have 'to demonstrate either good cause or
10 that it satisfied a meet-and-confer requirement. {Sinaiko Healthcare Consulting, Inc. v. Pacific
11 Healthcare Consultants (2007) 148 Cal. App. 4"^ 390, 411.) A separate statement is not required
12 when no response has been provided to the request for discovery. (Rules of Court, rule 3.1345(b).)
o
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i i ir, 13 In our case. Defendant has not received plaintiffs verified responses to Special
^ 00 — VO
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-U "
(= < Ov
00 (S M
Di < d ov ov 15 Employment (Set One). These interrogatories were properly served on Plaintiff on April 25, 2018.
vb VD
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_) X 16 (Bardzell Decl., Tl 2 and Exhibit A.) Plaintiffs responses were due on or before May 30, 2018. By
H £:
o
17 correspondence dated May 22, 2018, Plaintiff requested an extension of time to respond to all such
18 requests on the basis that he was sick. (Bardzell Decl., Tl 3 and Exhibit B.) Defendant responded by
19 email correspondence dated May 23, 2018 granting Plaintiff an extension of time to respond to
20 June 20, 2018. (Bardzell Decl., Tl 4 and Exhibit C.) Plaintiff did not respond to this discovery by
21 June 20, 2018, has not offered a valid excuse for his failure to respond and all such responses
22 remain outstanding. Defendant requires these discovery responses in order to properly defend itself
23 in this case and to determine the validity of plaintiffs claims.
24 Accordingly, Defendant respectfully request an Order compelling Plaintiff to provide
25 verified responses to Defendant's Special Interrogatories (Set One), Form Interrogatories - General
26 (Set One), and Form Interrogatories - Employment (Set One) without objections.
27 ///
28 ///
{01892012.DOCX) 5
IV.
PLAINTIFF SHOULD BE ORDERED TO PROVIDE RESPONSES TO REQUESTS FOR
PRODUCTION OF DOCUMENTS (SET ONE)
If a party to whom a demand for inspection is directed fails to serve a timely response, the
party propounding the demand may move for an order compelling responses to the demand. (CCP
§ 2031.300(b).) In addition, a party who fails to respond waives any objections he otherwise could
have raised to the demand. (CCP § 2031.300(a).)
Defendant served Plaintiff with a Request for Production of Documents (Set One) on April
25, 2018. (Bardzell Decl., Tl 2 and Exhibit A.) Plaintiffs responses were due on or before May 30,
2018. Plaintiff requested and received an extension of time in which to respond yet failed to
10 respond by the extended deadline. (Bardzell Decl., Tl 4 and Exhibit C.) Plaintiffs responses remain
11 overdue and outstanding. (See id.)
12 Therefore, Defendant respectfully requests an Order compelling Plaintiff to provide
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13 responses to Defendant's Request for Production of Documents (Set One), without objections.
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0-; < Q- VD ^ 1J DEFENDANT'S REOUEST FOR ADMISSIONS (SET ONE) SHOULD BE
DEEMED ADMITTED
5 g g --i X 16
o.|is< The party to whom requests for admission have been directed shall respond in writing under
o
17 oath separately to each request. (CCP § 2033.210(a).) Each response shall answer the substance of
18
the requested admission, or set forth an objection to the particular request. {Id.)
19
20 "If a party to whom requests for admission are directed fails to serve a timely response
[. . .] The party to whom the requests for admission are directed waives any objection to
21 the requests[. . . .] The requesting party may move for an order that the genuineness of
22 any documents and the truth of any matters specified in the requests be deemed
admitted, as well as for a monetary sanction[. . . . ] It is mandatory that the court impose
23 a monetary sanction [. . .] on the party or attorney, or both, whose failure to serve a
timely response to requests for admission necessitated this motion." (CCP §
24 2033.280(a-c).)
25 Defendant served Plaintiff with a Request for Admissions (Set One) including nineteen
26 requests on April 25, 2018. (Bardzell Decl., Tl 2 and Exhibit A.) Plaintiffs responses were due on
27 or before May 30, 2018. Plaintiff requested and received an extension of time in which to respond
28 yet failed to respond by the extended deadline. (Bardzell Decl., Tl 4 and Exhibit C.) Plaintiff s
{01892012.DOCX} 6
1 responses remain overdue and outstanding. (See id.)
. 2 Therefore, Defendant respectfully requests an order that the tmth of all matters specified in
3 Defendant's Request for Admissions, Set One be deemed admitted pursuant to CCP § 2033.280.
4 VL
.5 MONETARY SANCTIONS SHOULD BE AWARDED
Code of Civil Procedure § 2023.030(a) provides, in relevant part, that:
6
7 The court may impose a monetary sanction ordering that one engaging in the misuse
of the discovery process, or any attomey advising that conduct, or both pay the
8 reasonable expenses, including attoniey's fees, incurred by anyone as a result of that
9 conduct [. . .] If a monetary sanction is authorized by any provision of this title, the
court shall impose that sanction unless it finds that the one subject to the sanction
10 acted with substantial justification or that other circumstances make the imposition of
the sanction unjust;
11
12 CCP §§ 2030.290(c), 2031.300(c) and 2033.280(c) provide that a court shall impose a ,
13 monetary sanction on any party who unsuccessfully opposes a motion to compel responses to
r- 3 00 — VO
(— </5 m 00 o
O .. Ov -a- 14 interrogatories, request for production of documents or request for admissions.
— > v j a^ ov
< o" >o vd 15- Defendant has extended Plaintiff every opportunity to avoid court intervention in this
U ^ . S ov 5;
matter by providing Plaintiff with an extension of time to respond to all of the aforementioned
3
17 requests to which Plaintiff still failed to provide any response. Plaintiff has completely ignored
18 Defendant's discovery requests.
19 Plaintiffs attempt to evade his obligation to provide responses to discovery has made the
20 current motion necessary, despite being afforded opportunities to avoid the need for same.
21 To date. Defendants have incurred $3,900 in fees as a result of Plaintiff s failure to respond
22 to Requests for Production of Documents (Set One), Special Interrogatories (Set One), Form
23 Interrogatories - General (Set One), Form Interrogatories - Employment (Set One.) and Request for
24 Admissions (Set One.) (Bardzell Decl., Tl 15.) Defendant anticipates incurring an additional $1,300
25 to review Plaintiffs Opposition, prepare a reply and attend a hearing. (See id.) Therefore, sanctions
26 are proper. Moreover, even if Plaintiff serves responses upon notice of this motion in order to avoid
27 a court order. Defendant has nevertheless been forced to incur the expense of moving to compel
28 Plaintiffs compliance with his discovery obligations, despite efforts to achieve a cooperative
{01892012.DOCX} ' ' • 7 .
1 result. As such, sanctions in the amount of $5,200 are appropriately awarded against Plaintiff for
2 the time and expense incurred by Defendant in filing this otherwise unnecessary motion.
VII.
TERMINATING SANCTIONS ARE ALSO APPROPRIATE
The Code of Civil Procedure provides that the Court may impose sanctions on any party
who engages in conduct that constitutes misuse ofthe discovery process. (CCP § 2023.030(a).)
•6
Misuses ofthe discovery process includes "failing to respond or to submit to an authorized method
7
of discovery" and "disobeying a court order to provide discovery." (CCP §§ 2023.010(d), (g).)
8
When a party fails to respond to an authorized method of discovery and/or fails to obey a court
9
order to provide discovery, the Court may impose monetary sanctions, terminating sanctions, or
10
both. (CCP § 2023.030(a), (d), (g).)
11
Courts have long held that terminating sanctions are appropriate where there is a willful
o.
12
o failure to comply with court orders, and should be issued where it appears that lesser sanctions
tN
f-^ •- 0 0^
13
L - 3 . VO
H CT) 1/-, OO O would not bring the offending party into compliance. {R.S. Creative, Inc. v. Creative Cotton, Ltd.
o d-=^ 2: P; 14
> U ov ov ., (1999) 75 Cal.App.4th 486, 496.) Terminating sanctions are especially appropriate where a party
< o" vd ^ 1J
W c o^ o^
f— • — " .. fails to respond to discovery requests and ignores court orders. {See Kahn v. Kahn (1977) 68
Cal.App.3d 372, 383.)
17
Terminating sanctions are appropriate in this case. Plaintiff has failed to provide any
18
verified responses to the Defendant's written discovery despite receiving an extension of time to do
19
so.
20
It is evident that Plaintiffs conduct is nothing more than a delaying tactic to prevent the
21
Defendant from engaging in basic discovery. Requiring Defendant to continue wasting time,
22
money, and Court resources to compel Plaintiff to litigate this case would be categorically unjust.
23
The aforementioned conduct has also prejudiced Defendant's ability to prepare for trial and will
24
interfere with the Court's ability ascertain the tmth in this case. It has thus become apparent that no
25
action will compel Plaintiff to comply with his discovery obligations, making terminating sanctions
26
appropriate.
27
Additionally, Plaintiffs pattem of vexatious litigation tactics throughout the course of this
28
{01892012.DOCX} 8
litigation further indicates the need for terminating sanctions. Recently, Plaintiff engaged in
vexatious litigation tactics in connection with his opposition to Defendants' Motion for Fees and
Costs Pursuant to CCP § 425.16(c). The Court recognized Plaintiffs repeated improper filings in
its Tentative Ruling on Defendants' Motion for Fees and Costs dated June 7, 2018, affirmed and
adopted by its Order Granting Defendants' Motion for Fees and Costs Pursuant to CCP § 425.16(c)
dated June 29, 2018. (Bardzell Decl., Exhibit I.) The Court's Tentative Ruling, in part, provided:
"First the Court must note that the opposition memorandum exceeds the 15 page limit
set forth in California Rules of Court Rule 3.1113 and Plaintiff failed to obtain an order
8 pursuant to CRC Rule 3.1113(e) permitting an oversized meinorandum. The Court has
9 previously admonished Plaintiff for failing to comply with this mle."
[.-..]
10
Plaintiffs "notice of objection" to Defendants' supplemental declaration does nothing
11
more than repeat the issues discussed above related to his previous counsel and the'
12 alleged collusion with Defendants' counsel in addition to alleging that Defendants'
o
o counsel had attempted to provoke him into a physical confrontation. [. . .] There was no
tN
13 basis to file an'objection.'"
J 00 — VO
^ oo o
I/-J oo
O <J °^ 2 14 (Bardzell Decl., Exhibit I , Tentative Ruling on Defendants' Motion for Fees and Costs
> U ov ov _
cc; < o vd VD 1 J dated June 7, 2018, pg. 2-4.)
UJ ^ c 5; 5;
S g i -i X 16 Plaintiff has repeatedly filed multiple lengthy documents and pleadings and continues to
17 engage in tactics to delay the case and to force Defendant to expend additional funds in the defense
rn
18 of the action. Accordingly, Defendant requests that the Court grant terminating sanctions and issue
19 an Qrder dismissing the complaint against the remaining Defendant in its entirety, with prejudice.
20 VIH.
IF TERMINATING SANCTIONS ARE NOT GRANTED. THE COURT SHOULD
21 IMPOSE A DEADLINE FOR PLAINTIFF TO SEEK LEAVE TO F I L E A THIRD
22 AMENDED COMPLAINT, IF AT A L L
23
As discussed supra. Plaintiff has represented that he will seek leave of the court to file a
24
Third Amended Complaint. At the outset of the appeal of the anti-SLAPP motion- well over a year
25
ago - Plaintiff provided Defendants with a draft of his Third Amended Complaint. It is nearly three
26
hundred pages long and includes allegations of a conspiracy to cover-up illegal power sales that
27
involves all levels of state govemment, the University of Califomia system, and local jurisdictions,
28
including the Sacramento Municipal Utility District. To date, Plaintiff has not sought leave of the
(0I892012.DOCX} ^ 9
1 Court to file a Third Amended Complaint. In light of Plaintiffs vexatious litigation tactics
2 identified supra, if the Court is not willing, at this stage, to terminate the action, it should impose a
3 reasonable deadline of two weeks from the issuance of an Order on the present Motion to Compel
4 for Plaintiff to seek leave to file a Third Amended Complaint. This would eliminate the specter of
5 additional voluminous and unnecessary pleading amendments from further delaying the case and
6 causing Defendant urmecessary fees and costs.
7 IX.
8 CONCLUSION
9 Defendant has made every effort to allow for the cooperative exchange of information,
10 however Plaintiff has failed to provide verified responses to Defendant's Requests for Production of
11 Documents (Set One), Special Interrogatories (Set One), Form Interrogatories - General (Set One),
12 Form Interrogatories - Ehiployment (Set One.) and Request for Admissions (Set One.) Defendant
o
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13 is left with no option other than to file the instant motion. As such, Defendant seeks an Order (1)
fN
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»o oo 14 compelling Plaintiff to provide verified responses, without objections, to Defendant's Requests for
O CJ ov
venu
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15 Production of Documents (Set One), Special Interrogatories (Set One), Form Interrogatories -
5 ^ § -J X 16 General (Set One) and Form Interrogatories - Employment (Set One.); (2) deeming Defendant's
:D C/) 17 Request for Admissions, Set One admitted; (3) awarding sanctions in the amount of $5,200.00 to
o
18 return Defendant to the position it would have been had responses been timely provided; (4) issue
19 terminating sanctions against Plaintiff as a result of Plaintiff s pattern of vexatious litigation tactics
20 and failure to engage in the discovery process; and (5) altematively, if termination is not granted, to
21 impose a two week deadline for Plaintiff to seek leave to file a Third Amended Complaint, if at all.
22
Dated: October 3, 2018 PORTER SCOTT
23 A PROFESSIONAL CORPORATION
24
25 David P. E. Bhrkett
26 Daniel J. Bardzell
Attomeys for DefendEint
27
28
{01892012.DOCX} 10
Waszczuk V. Regents ofthe University of California, et ai
1
Sacramento County Superior Court, Case No. 34-2013-00155479
2
PROOF OF SERVICE
3
4 At the time of service, I was over 18 years of age and not a party to this action. My business
address is 350 University Avenue, Suite 200, Sacramento, California 95825.
5
On the date below, I served the following document:
6
7 DEFENDANT'S POINTS AND AUTHORITIES IN SUPPORT OF DEFENDANT'S MOTION TO
COMPEL VERIFIED RESPONSES TO REQUESTS FOR PRODUCTION OF DOCUMENTS SET
8 ONE, SPECIAL INTERROGATORIES SET ONE, FORM INTERROGATORIES - GENERAL SET
ONE, FORM INTERROGATORIES - EMPLOYMENT SET ONE; TO DEEM REQUEST FOR
9 ADMISSIONS ADMITTED; AND FOR MONETARY AND TERMINATING SANCTIONS
10
BY MAIL: I placed the envelope for collection and mailing, following our ordinary business practices. I
11 am readily familiar with this business' practice for collecting and processing correspondence for mailing.
On the same day that correspondence is placed for collection and mailing, it is deposited in the ordinary
12 course of business with the United States Postal Service, in a sealed envelope with postage fully prepaid.
o
o
BY PERSONAL SERVICE: I caused such document to be personally delivered to the person(s)
tN
13 addressed below. (1) For a party represented by an attomey, delivery was made to the attomey or at the
.,- ^ — VD
attomey's office by leaving the documents, in an envelope or package clearly labeled to identify the
•~ tN
t- 3 00 00 o
attomey being served, with a receptionist or an individual in charge of the office, between the hours of
o OV 1^ 14
u I)
ov t-: nine in the moming and five in the evening. (2) For a party, delivery was made to the party or by leaving
00 53
— g<
> tN f N
ov OV
15 the documents at the party's residence with some person not younger than 18 years of age between the
o '^S vd hours of eight in the moming and six in the evening.
f-
o: J X 16 BY OVERNIGHT DELIVERY: I enclosed the documents in an envelope or package provided by an
o UJ < ovemight delivery carrier and addressed to the person(s) listed below. I placed the envelope or package
17 for collection and ovemight delivery at my office or a regularly utilized drop box of the ovemight
delivery carrier.
18 BY FAX TRANSMISSION: Based on an agreement of the parties to accept service by fax transmission,
I faxed the documents to the persons at the fax numbers listed below. No error was reported by the fax
19 machine that 1 used. A copy of the record of the fax transmission, which I printed out, is attached
BY ELECTRONIC SERVICE: Based on a court order or an agreement of the parties to accept service
20 by electronic transmission, 1 caused the documents to be sent to the persons at the electronic notification
address listed below.
21
Jaroslaw Waszczuk
22
2216 Katzakian Way
23 Lodi, CA 95242
24 I declare under penalty of perjury under the laws of the State of Califomia that the
foregoing is tme and correct. Executed at Sacramento, Califomia on October 3, 2018.
25
26
Wendy Strasser
27
28
{0I892012.DOCX} II
SUBMITTED ON 3/3/2020
ATTACHMENT# 11
V.
‘ .
CR).
_
SUBP-002
OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY
ATTORNEY
Lindsay A. Goulding, SBN 227195 ,
Olatomiwa Aina, 325566

6927-3 706
‘
TELEPHONEN0.: 916-929-1481 FAX no: 91

,
E-MAIL ADDRESS: - .
ATTORNEY FORWame”
.
1
goulding@porterscott.com
Michael B0 (1 Ste hen
Chilcott Danesha Nichols et al. _
.
NAME OF COURT:
Superior Court of California, County of Sacramento
STREET ADDRESS:
.
720 9th Street

MAILING ADDRESS:
720 9th Street
C'TY AND 2'P CODE:
Sacramento 958 14
BRANCH NAME:
PLA|NT1FF/ PETiTiONERZ Jal-Oslaw WaSZCZUk

DEFENDANT/RESPONDENT: Regents of the University of California, et al.
CIVIL SUBPOENA (DUCESTECUM) for Personal Appearance and CASE NUMBER:
.
Production of Documents, Electronically Stored Information, and Things at 34-2013-00155479

Trial or Hearing and DECLARATION
THE PEOPLE OF THE STATE OF CALIFORNIA, TO (name, address, and telephone number of witness, if known):
Irina Waszczuk, 2216 Katzakian Way, Lodi, CA 95242

1. YOU ARE ORDERED TO APPEAR AS A WITNESS in this action at the date, time, and place shown in the box below
UNLESS your appearance is excused as indicated in box 3b below or you make an agreement with the person named in
item 4 below.
a. Date: 7, 2021
May Time: 9:00 am. Dept: 43 [—__—| Div.: 1:1 Room: |:| .
b.Address: gt _
.-
J“ 1"... A' t l
2. IF YOU HAVE BEEN SERVED WITH THIS SUBPOENA AS A CUSTODIAN OF CONSUMER OR EMPLOYEE RECORDS
UNDER CODE OF CIVIL PROCEDURE SECTION 1985.3 OR 1985.6 AND A MOTION TO QUASH OR AN OBJECTION HAS
BEEN SERVED ON YOU, A COURT ORDER OR AGREEMENT OF THE PARTIES, WITNESSES, AND CONSUMER OR
EMPLOYEEAFFECTED MUST BE OBTAINED BEFORE YOU ARE REQUIRED TO PRODUCE CONSUMER OR EMPLOYEE
RECORDS.
3. YOU ARE (item a orb must be checked):
a. Ordered to appear in person and to produce the records described in the declaration on page two or the attached
declaration or affidavit. The personal attendance of the custodian or other qualified witness and the production of the?
Code sections 1560(b), 1561, and
original records are required by this subpoena. The procedure authorized by Evidence '
1562 will not be deemed sufficient compliance with this subpoena.

b. [I] Not required to appear in person if you produce (i) the records described in the declaration on page two or the attached
declaration or affidavit and (ii) a completed declaration of custodian of records in compliance with Evidence Code sections
the original
1560, 1561, 1562, and 1271. (1) Place a copy of the records in an envelope (or other wrapper). Enclose
declaration of the custodian with the records. Seal the envelope. (2) Attach copy a of this subpoena to the envelope or
write on the envelope the case name and number; your name; and the date, time, and place from item in the box above. 1
outer seal and mail it to the clerk of the court at the address in item 1.
(3) Place this first envelope in an envelope, it,
(4) Mail a copy of your declaration to the attorney or party listed at the top of this form.
4. IF YOU HAVE ANY QUESTIONS ABOUT THE TIME OR DATE YOU ARE TO APPEAR, OR IF YOU WANT TO
BE CERTAIN
THAT YOUR PRESENCE IS REQUIRED, CONTACT THE FOLLOWING PERSON BEFORE THE DATE ON WHICH YOU ARE
.
TO APPEAR: ,
a. Name ofsubpoenaing party or attorney: Olatomiwa T. Aina b. Telephone number: 916-929-1481
5. Witness Fees: You are entitled to witness fees and mileage actually traveled both ways, as provided by law, if you request them
at the time of service. You may request them before your scheduled appearance from the person named in item 4.
DISOBEDIENCE OF THIS SUBPOENA MAY BE PUNISHED AS CONTEMPT BY THIS COURT. YOU WILL ALSO BE LIABLE
FOR THE SUM OF FIVE HUNDRED DOLLARS AND ALL DAMAGES RESULTING FROM YOUR FAILURE TO OBEY.
Date issued:
4/12/21 * f" '
Olatomma T, Ama
. .
) 056sz J. M '
(SIGNATURE OF PERSON ISSUING SUBPOENA)

(TYPE OR PRINT NAME)
Attorney for Defendants

(TITLE) Page 1 of3
(Declaration in support of subpoena on reverse)
Form
Adopted for Mandatory_Use
CIVIL SUBPOENA (DUCESTECUM) for Personal Appearance and Code ofCivii Procedure.
suggggg;fggfg'aflugfyq’fg'gu,
Production of Documents, Electronically Stored Information, and Things at wwwiljffsggfggv'
'4————-———_m
I- .
x .
SUBP-OOZ
CASE NUMBER
PLAINTIFF/PETITIONER:Jaroslaw Waszczuk
. . . 34—2013-00155479
of the UanCI'Slty of California, et al.
.
DEFENDANT/RESPONDENT:Regents
The production of the documents, electronically stored information, or other things sought by the subpoena on page one is supported ‘
by (check one):
|:| the attached affidavit or the following declaration:
DECLARATION IN SUPPORT OF CIVIL SUBPOENA (DUCES TECUM) FOR PERSONAL APPEARANCE AND
PRODUCTION OF DOCUMENTS, ELECTRONICALLY STORED INFORMATION,AND THINGS AT TRIAL OR HEARING
(Code Civ. Proc., §§ 1985,1987.5)
1. I, the undersigned, declare I am the I: plaintiff L___| defendant |:| petitioner D respondent
attorney for (specify): defendant |:| other (specify):
‘
in the above-entitled action.
‘
2. The witness has possession or control of the documents, electronically stored information, or other things listed below, and shall
produce them at the time and place specified in the Civil Subpoena for Personal Appearance and Production of Records at
Trial or Hearing on page one of this form (specify the exact documents or other things to be produce; if electronically stored
information is demanded, the form or forms in which each type of information is to be produced may be specified):
See Attachment 2
Continued on Attachment 2.
3. Good cause exists for the production of the documents, electronically stored information, or other things described in paragraph 2
for the following reasons:
Judgment creditors have submitted an application to examine Irina Waszczuk to determine if she has assets
that will satisfy the judgment against her spouse. Good cause exists to produce the requested documents as
they have pertinent infomation about the Witness' financial status. They will assist the court and judgmen
creditors in determining how the judgment against judgment debtor can be satisfied.
i: Continued on Attachment 3.
4. The documents, electronically stored information, or other things described in paragraph 2 are material to the issues involved in this
case for the following reasons:
The documents have relevant information that will be used in the examination of Irina Waszczuk to
determine if she has assets that will be used to satisfy the judgment against her spouse, the judgment debtor.
i: Continued on Attachment 4.
‘
I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
Date: 4/12/21
fifafiaflwfla J,f.
1 0
. .
’ dam
Olatomiwa T. Ama _______________________
(TYPE OR PRINT NAME) (SIGNATURE or [3 SUBPOENAINGPARTY [I] éiiixgbhéhhfiRp/NRTY)
Requestfor Accommodations
Assistive listening systems, computer~assisted real-time captioning, or sign language interpreter services are available ,
if you ask at least five days before the date on which you are to appear. Contact the clerk's office or go to
www.courts.ca.gov/forms for Request for Accommodations by Persons With Disabilities and Response (form MC-410).
(Civil Code, § 54.8.)
(Proof of service on page 3)
SUBP-ooz [Rem January 1. 20121 CIVIL SUBPOENA (DUCESTECUM) for Personal Appearance and Pa9e20f3
Production of Documents, Electronically Stored Information, and Things at
. , 4
t
SUBP-002
PLAINTIFF/PETITIONER: CASE NUMBER:
Jaroslaw Waszczuk
34-2013-00155479
Regents of the Umversfiy of Callforma, et al,
. . . .
DEFENDANT/RESPONDENT:
PROOF OF SERVICE OF CIVIL SUBPOENA (DUCESTECUM) for Personal Appearance and Production of
Documents, Electronically Stored Information, and Things at Trial or Hearing and DECLARATION
1. Iserved this Civil Subpoena (Duces Tecum) for Personal Appearance and Production of Documents, Electronically Stored -
Information, and Things at Trial or Hearing and Declaration by personally delivering a copy to the person served as follows:
a. Person served (name):
b. Address where served:
0. Date of delivery:
d. Time of delivery:
.
e. Witness fees (check one):
(1) l: were offeredor demanded

and paid. Amount: $
. . . . . .
(2) C] were not demanded or paid.
f. Feeforservice:................ $
2. I received this subpoena for service on (date): Q
3. Person serving:
a. 1:
Not a registered California process server.
»
b. D
California sheriff or marshal.
c. I: Registered California process server.
d. I: Employee or independent contractor of a registered California process server.
e. D Exempt from registration under Business and Professions Code section 22350(b).
f. l:Registered professional photocopier.
9- Exempt from registration under Business and Professions Code section 22451.
|___—| ‘
h. Name, address, telephone number, and, if applicable, county of registration and number:
Ideclare under penalty of perjury underthe laws of the State of (For California sheriff or marshal use only)
California that the foregoing is true and correct. Icertify that the foregoing is true and correct.
Date:
Date:
>______________ (SIGNATURE)
>_________________ (SIGNATURE) .
__________________________________.__-————-———— Pagan”
SUBP-ooziRev. January 1. 20121 CIVIL SUBPOENA (DUCESTECUM) for Personal Appearance and
w—«_
J -'.
AT-138/EJ-125
OR PARTY ATTORNEY: STATE BAR N04 FOR COURT USE ONLY
ATTORNEY WITHOUT
NAME:
Lindsay A. Goulding, SBN 227195
FIRM NAME: Porter Scott
STREET ADDRESS: 350 University Avenue .
CITY: Sacramento STATE: CA ZIP CODE: 95825

1 TELEPHONE No.: (916) 929—1481 FAX ND:
(916) 927-3706
E-MAILADDRESS: Igoulding@porterscott.com, oaina@porterscott.com
ATTORNEY FOR (name): Defendants Boyd, Chilcott, Seifert, Oropeza, and Nivhols -
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SACRAMENTO

STREET ADDRESS: 720 9th Street
720 9th Street
‘
MAILING ADDRESS:
CITY AND ZIP CODE: Sacramento 95814
BRANCH NAME:
'
PLAINTIFF JAROSLAWWASZCZUK
DEFENDANT REGENTS OF THE UNIVERSITYOF CALIFORNIA,et al.
APPLICATION AND ORDER FOR APPEARANCE AND EXAMINATION CASE NUMBER.
ENFORCEMENT OF JUDGMENT C] ATTACHMENT (Third Person) 34-2013—00155479

|:| JudgmentDebtor [Il Third Person
ORDERTO APPEAR FOR EXAMINATION
1. TO (name): IRINA WASZCZUK
2. YOU ARE ORDERED TO APPEAR personally before this court, or before a referee appointed by the court, to
a. E] furnish information to aid in enforcement of a money judgment against you.
»
b. answer concerning property of the judgment debtor in your possession or control or concerning a debt you owe the ’
judgment debtor.
c. I: answer concerning property of the defendant in your possession or control or concerning a debt you owe the defendant
that is subject to attachment.
Date: MAY 7, 2021 Time:9:00 A.M. Dept. or Div.:43 Rm.:
Address of court is shown above |:| is:
3. This order may be served by a sheriff, marshal, registered process server, or the following specially appointed person (name):
Date:
________________________
JUDGE
This order must be served not less than 10 days before the date set for the examination.
IMPORTANT NOTICES ON REVERSE
APPLICATION FOR ORDERTO APPEAR FOR EXAMINATION
4. Original judgment creditor I: Assignee of record I: Plaintiff who has a right to attach order
applies for an order requiring (name): IRINA WASZCZUK
debt.
to appear and furnish information to aid in enforcement of the money judgment or to answer concerning property or
5. The person to be examined is '
,
a. [j the judgment debtor.

or the defendant or (2) who
b. a third person (1) who has possession or control of property belonging to the judgment debtor
owes the judgment debtor or the defendant more than $250. An affidavit supporting this application
under Code of Civil
Procedure section 491.110 or 708.120 is attached.
6. The person to be examined resides or has a place of business in this county or within 150 miles of the place of
examination.
entered or only) the court that issued the writ of
7. |:| This court is not the court in which the money judgment is (attachment
is attached.
attachment. An affidavit supporting an application under Code of Civil Procedure section 491.150 or 708.160
another examination
8. |:] The judgment debtor has been examined Within the past 120 days. An affidavit showing good cause for
is attached.
State of California that the foregoing is true and correct.
'
I declare under penalty of perjury under the laws of the

.
Date: April 12 2021

(fleetamuuaJr Claw,
u a
Olatomiwa T. Aina } ..
(SIGNATURE OF DECLARANT)
of2
(Continued on reverse) Page 1
APPLICATION AND ORDER FOR 11111111, 11113113°§§r1tt°1°§sr161

531t1zdszsiii°g1tzrsizzur
AT-138/EJ-125jRev. January 1, 2017] APPEARANCE AND EXAMINATION www.couns.ca.gov
(Attachment—Enforcement of Judgment)
,,__ ___—._.________===_-==
v1», ’
'
AT-138/EJ-125
Information for Judgment Creditor Regarding Service
_
If you want to be able to ask the court to enforce the order on the judgment debtor or any third party, you
must have a copy of the order personally served on the judgment debtor by a sheriff, marshal, registered
process server, or the person appointed in item 3 of the order at least 10 calendar days before the date of
the hearin and have a roof of service filed with the court.
IMPORTANT NOTICES ABOUT THE ORDER

'
APPEARANCE OF JUDGMENT DEBTOR (ENFORCEMENTOF JUDGMENT)

NOTICE TO JUDGMENT DEBTOR If you fail to appear at the time and place specified in this order,
you may be subject to arrest and punishmentfor contempt of court, and the court may make an
order requiring you to pay the reasonable attorney fees incurred by the judgmentcreditor in this
proceeding.
‘
APPEARANCE OF A THIRD PERSON (ENFORCEMENT OF JUDGMENT)
(1) NOTICE TO PERSON SERVED If you fail to appear at the time and place specified in this order,
.
order requiring you to pay the reasonable attorney fees incurred by the judgmentcreditor in this
proceeding.
(2) NOTICE TO JUDGMENT DEBTOR The person in whose favor the judgmentwas
entered in this
action claims that the person to be examined under this order has possession or control of property
that is yours or owes you a debt. This property or debt is as follows (describe the property or debt):
Communityproperty of Plaintiff/JudgmentDebtor
Irina Waszczuk’s employmentwages _
.
2000 Mercedes 320

Any and all community property owned by Plaintiff and Irina Waszczuk
If you claim that all or any portion of this property or debt is exempt from enforcement of the money
judgment, you must file your exemption claim in writing with the court and
have a copy personally
served on the judgmentcreditor not later than three days before the date set for the examination. '
You must appear at the time and place set for the examination to establish your claim of exemption
or your exemption may be waived.
APPEARANCE OF A THIRD PERSON (ATTACHMENT)

NOTICE TO PERSON SERVED If you fail to appear at the time and place specified in this order, you
and the court may make an order
may be subject to arrest and punishmentfor contempt of court,
,
requiring you to pay the reasonable attorney fees incurred by the plaintiff in this proceeding.
.
APPEARANCE OF A CORPORATION, PARTNERSHIP,

ASSOCIATION, TRUST, OR OTHER ORGANIZATION
It is your duty to designate one or more of the following to appear and be examined: officers,
and debts.
directors, managing agents, or other persons who are familiar with your property
real-time captioning, or Sign

Request for Accommodations. Assistive listening systems, computer-assisted
ask at least 5 days before your hearing. Contact the clerk’s
language interpreter services are available if you
office for Request for Accommodation (form MC-4IO). (Civil Code, § 54.8.)
,
of2
_
Page 2
AT-138/EJ-125 (Rev. January 2017]
1. APPLICAT'ON AND ORDER FOR
APPEARANCE AND EXAMINATION
w
MC-025
CASE NUMBER:
SHORT TITLE:
Jaroslaw Waszczuk v. Regents of the University of California, et al. 34-2013-00155479
ATTACHMENT (Number): 2
(This Attachment may be used with any Judicial Council form.) .
1. All DOCUMENTS sufficient to IDENTIFY YOUR current residence, including but not limited to
DOCUMENTS identifying YOUR ADDRESS, how long YOU have lived there, whether YOU own or rent
the residence, and the amount of YOUR rent or monthly mortgage payment.
‘
All DOCUMENTS relating to any real estate in which YOU have an ownership interest, and any income
2.
YOU derive therefrom, whether directly or indirectly, including but not limited to real property deeds
3. All DOCUMENTS relating to any real estate in which YOUR spouse has an OWnership interest, and any ‘
income YOU or YOUR spouse derive therefrom, whether directly or indirectly, including but not limited to
real property deeds.
4. All DOCUMENTS relating to any business entity in which YOU have an ownership interest.
5. All DOCUMENTS relating to any business entity in which YOUR spouse has an ownership interest.
6. All DOCUMENTS relating to any property in which YOU have an ownership interest, including but not
limited to (i) all checking and savings accounts; (ii) jewelry; (iii) motor vehicles or watercraft; (iv) debts or .
notes owed by another to YOU; (v) stocks, bonds, and other securities; and (vi) life insurance policies.
7. All DOCUMENTS relating to any property in which YOUR spouse has an ownership interest, including but
not limited to (i) all checking and savings accounts; (ii) jewelry; (iii) motor vehicles or watercraft (including
but not limited to vehicle ownership certificates); (iv) debts or notes owed by another to YOUR spouse; (v)
stocks, bonds, and other securities; and (Vi) life insurance policies.
8. All DOCUMENTS relating to any safe or safety deposit box YOU or your spouse own or use and the
‘
contents therein.
9. All federal and state corporate tax returns YOU have filed from 2012 to the present.
10. All DOCUMENTS relating to any of YOUR property held by third parties.
ll. All DOCUMENTS relating to any of YOUR spouse’s property held by third parties.
12.All DOCUMENTS relating to any benefits YOU have received or currently receive, including by not ,
limited to any pension, disability compensation, or retirement pay.
13. All DOCUMENTS relating to any vested fliture interest YOU have in any property or in the payment of
any money.
item that this Attachment concerns is made under penalty ofperjury, all statements in this
(If the Page _1_ of _:2_
Attachment are made under penalty of perjury.) (A d d pages as required)
_____________________________________.______—-—— ”g
ATTACHMENT
Frattiaxsfié-32932iza'ite
MCflzstRev. July 1.2009] to Judicial Council Form
lLED>teNDORSED
Jaroslaw "Jfeny" Waszczuk, Plaintiff in Pro Per
2216Katzakian Way APR 2 8 2021
Lodi, CA 95242
Phone: 209-663-2977
BAvJiAQan Deputy Clerk
Fax: 209-787-3131
Email: jjwl980@live.com
April 27, 2021
Clerk of the Sacramento County Superior Court

Department 43 - Hon, Thadd A. Blizzard
720 9^ Street, 6* Floor
Subject: Case no. 34-2013-00155479, Jaroslaw Waszczuk v. The Regents of the

University of Califomia Arm Madden Rice, Mike Boyd, Stephen Chilcott, Charles
Witcher, Danesha Nichols, Cindy Oropeza, Brent Seifert, Patrick Putney, Dorin
Daniliuc
RE: APPLICATION AND ORDER FOR APPEARANCE AND EXAMINATION

of Irina Waszczuk with Court Hearing set for May 7, 2021 at 9 a.m. in Department
43
RE: DECLARATION OF OLATOMIWA T. AINA IN SUPPORT OF

JUDGMENT CREDITOR'S APPLICATION FOR APPEARANCE AND
EXAMINATION OF IRINA WASZCZUK.
Dear Clerk of the Court,
Please provide the copy of the enclosed April 27, 2021, Meet and Confer
Correspondence addressed to the defendant's attomey from Porter Scott Law
Corporation to the Hon. Thadd A. Blizzard for the review and consideration and
please file it for the record . This correspondence relates to Olatomiwa T. Aina,
who, in violation of the 45 days notificatipn court rule submitted to the court an
Application and Order for Appearance and Examination V.

outdated 2019 Application and Order For Appearance and Examination and
Declaration in Support with the wrong addressee name. This is not the first time
this has happened.
Please advise Porter Scott's attomeys to follow the court rules and properly
schedule an Appearance for Examination with a correctly written name on the
application.
Sincerely,
I
/
4J
Jarosliw Waszczuk, Plaintiff in Pro Per
Enclosxire
Application and Order for Appearance and Examination

Jaroslaw "Jerry" Waszczuk, Plainliff iii Pro Per
2216 Katzakian Way
Lodi, CA 95242
Phone: 209-663-2977
Fax: 209-787-3131
Email: iiwl980@live.com
April 27, 2021
Olatomiwa T. Aina, Attorney

Porter Scott Law Firm
350 University Avenue, Suite 200
The Regents of the University of Califomia

1111 Franklin St., 12th floor
Oakland, CA 94607
Subject: Subpoena and Application and Order for Appearance and Examination
Case no. 34-2013-00155479, Jaroslaw Waszczuk v. The Regents of the
University of California, Ann Madden Rice, Mike Boyd, Stephen
Chilcott, Charles Witcher, Danesha Nichols, Cindy Oropeza, Brent
Selfeit, Patiick Putiiey, aiid Doriii Daiiilluc
Dear Ms. Aina:
1 am requesting that you clarify with the Court why, on April 22, 2021, at
approximately 2:00 P.M., I was served, at my residence in Lodi, CA, the following
Court documents:
• CTVIT. SURPOF.NA (DIJCRS TECUM) for Personal Appearance and

Production ofDocuments, Electronically Stored Information, and Things
-1 -
Subpoena and Application and Order for Appearance and Examination
and Trial or Hearing and Declaration Issued lo IRINA WASZCZUK
Olatomiwa T. Aina on April 22, 2021. (ATTACHMENT 1)
• APPLICATION AND ORDER FOR APPEARANCE AND
EXAMINATION with Court Hearing Date May 7, 2021 at 9:00 A.M. in
Department 43. (ATTACHMENT 2)
• DECLARATION OF OLATOMIWA T. AINA IN SUPPORT OF
EXAMINATION OF IRINA WASZCZUK. (ATTACHMENT 3)'
The above documents were filed in court and served to me on April 22, 2021 with the
name IRINA WASZCZUK. The person IRINA does not live at 2216 Katzakian Way,
Lodi, CA 95242.
I assume that the documents were meant to be served to my wife of 49 years

IRENA WASCZUK. IRENA is a Polish first name. IRINA is a Russian and Ukrainian
first name. If this is about money, then her bank account and 401 K are under the name
IRENA WASZCZUK. 1 am sure you understand the consequences of trying to get
money from her bank account with the name IRINA instead of IRENA.
For the above reason alone, I am advising yOu to properly fill out and resubmit
the documents to the Court. Also, for your information, my legal Polish name is
JANUSZ JAROSLAW, and my wife's legal Polish name is IRENA WASZCZUK. We
are both Polish refugees and citizens of the Republic of Poland who have been living
in exile in the USA since November 1982 (ATTACHMENT 4). In 1982, we escaped
communist oppression only to be ruthlessly and endlessly oppressed and harassed by
the National -Socialists at the University of Califomia and their servants from the law
firm Porter Scott Attorneys.
-2-
hllps://www.scribd.cuni/documeril/494446114/Sulidarily-Anli-Conimunisl-Muvemeril-
Poland-1980-1982
Furthermore, I am scratching my head as to why or who made you serve me the

old Subpoena and Application and Order for Appearance and Examination, and
Declaration in Support drafted by former Porter Scott Attorneys Nancy Sheehan and
Daniel BardzcU at the end of October 2019. Looking at Nancy Sheehan and Daniel
Bardzell's email addresses on thefirstpage of your Declaration and reading
information in the Declaration about Judgment Debtor and Mrs. Waszczuk's health
insurance through Mrs. Waszczuk's employment at Nordstrom that it was not difficult
determine that document was drafted in October or early November of 2019.
My wife is not working at Nordstrom since March 2020, because she was laid
off and Nordstrom in Sacramento Arden Mall was permanently closed permanently
shortly after . She was employed for 31 years by Nordstrom as a seamstress-fitter.
' My wife and I are both on Medicare Insurance and Social Security. If you need any
documents from Nordstrom, you will have to subpoena them directly from Nordstrom.
I found it inappropriate and upsetting because you served me Nancy Sheehan's

old drafted court documents. Nancy Sheehan, Porter Scott's employee of 34 years,
died of metastatic breast cancer on November 23, 2019 shortly after she and Bardzell
drafted the Subpoena, Application and Order for Appearance and Examination, and
Declaration in Support, which never served to me. Most likely you did not work Porter
Scott in October 2019.
https://www. legacy.com/obituaries/sacbee/obituarv.aspx?n=nancv-ioan-
sheehan&pid= 194994093
-3 -
Nancy Sheehan's premature death saddened me because my wife's sister died a
few years ago of metastatic breast cancer in Poland, and Nancy Sheehan's e-mail
address on your Declaration reminded me of what my wife Irena was going through
after her sister's death.
VIOLATION OF STATUTORY NOTICE REQUIREMENT OF 45 DAYS TO

F I L E A F F L l C A i i O N AND ORDER FOR APPEARANCE AND
EXAMINATION
In addition to the wrong addressee name filed on April 22, 2021, the Application
and Order for Appearance and Examination violates the statutory 45 days' notice
requirement for filing the Application and Order Appearance and Examination.
For your convenience, I am attaching a copy of the Sacramento County Superior

Court Law Library Debtor's Examination, which will help you properly file the
Application and Order for Appearance and documents with the Court Clerk Office
(ATTACHMENT 5).
I here are two separate periods to consider when choosing your heanng date:
• Your hearing date must be at least 45 days after the date you file your papers.
• The Judgment Debtor must be served at least 10 days prior to the hearing
date Califomia Code of Civil Procedure (CCP) $ 708.110(d).
Accordingly, your Court hearing date (counting 45 days from April 22, 2021) should
be set on Friday, June 11, 2021 due to Orders of Examination currently being heard in
Department 43 on Fridays at 9:00 A.M.
-4-
Not following the statutory notice requirements in filing the Application and
Order for Appearance and Examination will lead to the same result as the filing of
the Application and Order for Appearance and Examination submitted on October
24, 2018 by your predecessor, Daniel Bardzell, who did not comply with the
statutory notice requirements. The Application and Order submitted by Bardzell
was signed by the Judge from Department 37, Hon. Jennifer Blackwell, on
November 7, 2018, and the debtor's examination had to be rescheduled, which
delayed the legal process (ATTACHMENT 6).
YOUR DECLARATION IN SUPPORT OF JUDGMENT CREDITOR'S AND

CIVIL SUBPOENA (DUCES TECUM) FOR PERSONAL APPEARANCE OF
IRINA WASZCZUK DATED APRIL 12, 2021
Besides mentioning Nancy Sheehan's e-mail in your Declaration, the front

page of your Declaration contains the following statement: "Attorneys for
Defendant REGENTS OF THE UNIVERSITY OF CALIFORNIA Attomeys for
Judgment Creditors/Former Defendants MICHAEL BOYD, STEPHEN
CHILCOTT, DANESHA NICHOLS, CINDY OROPEZA, and BRENT
SEIFERT."
Since Porter Scott Attomeys' Daniel Bardzell was teamed with Nancy
Sheehan in October 2019, in their pleadings. Porter Scott Attorneys is making
reference to Defendants Mike Boyd, Stephen Chilcott, Danesha Nichols, Cindy
Oropeza, and Brent Seifert as Former Defendants (ROA No.222- 245). I
addressed this issue with the Court in my PLAINTIFF JAROSLAW
WASZCZUK'S NOTICE OF OBJECTION TO THE COURT ORDER DATED
DECEMBER13 8c 17, 2019 AND PLAINTIFF REQUEST FOR COURT
ORDERS MODIFCATION - RE: OPPOSITION TO JUDGMENT CREDITORS'
-5-
FURTHER MOTION TO COMPEL RESPONSES TO JUDGMENT DEBTOR
INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS
AND MONETARY SANCTIONS filed December 27, 2019 (ROA No. 244)
(ATTACHMENT 7).
Prior to October 23, 2019, Mike Boyd, Stephen Chilcott, Danesha Nichols,
and Cindy Oropeza are Defendants. See Daniel Bardzell's November 13, 2018
letter to Clerk o f the Court ( A t t a c h m e n t 6), in which Bardzell requested that
December 14, 2018 Examination of Plaintiff Jaroslaw Waszczuk be taken off

calendar due to a violation of the statutory 45 days' notice requirement.
One year later, the Defendants Mike Boyd, Stephen Chilcott, Danesha
Nichols, Cindy Oropeza, and Brent Seifert became Former Defendants. Porter
Scott Attomeys have had more than one year since my last Court filing dated
December 27, 2019 to clarify with the Court why Defendants Milce Boyd, Stephen
Chilcott, Danesha Nichols, Cindy Oropeza, and Brent Seifert suddenly became
Former Defendants in October 2019.
CONCLUSION
Legal documents, especially the Application and Order for Appearance and
Examination and the Civil Subpoena (Duces Tecum) for Personal Appearance and
Production of Documents, must be filed properly and with the proper legal name.
Otherwise, they are null and void. Because you are from Louisiana and a newly
licensed attorney by the State Bar of Califomia, I would like to advise you to
familiarize yourself with this case, which has been pending in the Sacramento
County Superior Court since December 2, 2013, before you submit faulty
documents to the Court Clerk and send them to my residence.
-6-
This case is interconnected with the pending United States Court of Appeals for
the District of Columbia Circuit whistleblower case Jaroslaw Janusz Waszczuk v.
Commissioner of Internal Revenue Services Case No.: 20-1407, which I have to attend
to in addition to responding to Porter Scott Attorneys' negligence and deception.
https://www.scribd.com/document/495490868/Jaroslaw-Waszczuk-v-lRS-
Commissioner-UNITED-STATES-COURT-OF-APPEALS-FOR-THE-
DISTRICT-OF-COLUMBIA-CIRCUIT
As an attomey, you are an officer of the court who took an oath to uphold the
law. I assume you lake responsibility as seriously as anyone else; you musi adhere lo
those rules and even report attomeys or people you see violating the rules. As a State
Bar Member, you are obligated, at the risk of serious consequences imposed by the
State Bar, to protect and preserve the courtrooms and the validity of any matter filed
with the clerk.
My former attorney Douglas Edward Stein (SB #131248) who was coerced
with a $300,000 bribe from former Porter Scott Attorneys Michael Pott, Douglas
Ropel, and David Burkett (Read: White Collar Criminals from the University of
California) to conspire with them against me and was used by them to harm me, was
disbarred by the State Bar for his crimes against me and his other clients
(ATTACHMENT 8).
If you read my March-May 2019 e-mail correspondences with State Bar of

California Executives, then you will understand that 1 am not taking Porter Scott
Attorneys' legal gangsterism lightly.
https://www.scribd.com/document/504977994/20190320-State-Bar-Audit-
Request-for-Review '
-7-
haps://www.scribd.com/ducument/504978933/20190329-Reuuesi-for-Review-
Additional-lnformation-and-Documents-Vanessa-Holton-Rachel-Grunberg
https://www.scribd.com/document/504979363/20190409-Request-to-Expedite-
Reimbursement-of-the-Theft-State-Bar-CEO-Leah-T-Wilson
https://www.scribd.com/document/504979845/201905i5-Leah-Wilson-State-Bar-
Ceo-Reimbursement
In 2019,1 recovered the money stolen from me by Douglas Stein and the
money stolen in 2011 by the University of Califomia gangsters, namely my Short
Term Disability Insurance Benefits. I am still working on recovering the money
stolenfromme in 2014, namely my Unemployment Insurance Benefits. However ,
because of the COVID 19 pandemic is not an easy task to deal with state of
federal agencies .
Finally, I am asking you to reschedule my wife's court hearing examination

in Department 43 to June 2021.1 am awaiting a second shot of the Moderna
COVID-19 vaccine. 1 am scheduled to be vaccinated on May 13, 2021 As we
know, this vaccine is not bulletproof, has not been approved by the FDA, and may
produce severe side effects for some people. At 70 years old, I am taking nine
different medications, and I am unsure of how I will be affected by the Modema
vaccine thus I need some time for recoveryfromvaccine side effects if any to
attend the court hearing with my wife .
I must attend the court hearing with my wife because her level of English is
insufficient for her to be questioned by lawyers without proper translation and/or
question interpretation.
-8-
If you have'any questions, please do not hesitate to contact me at your
i'
convenience.
Sincerely,
Jaroslaw Waszczuk
-9-
Mailing List
Re: Waszczuk v. Regents of the University ofCalifomia et al.

Sacramento County No. 34201300155479CUWTGDS

Department 43 - Hon. Thadd A. Blizzard
720 9lh Street 6"^ Floor
The Regents of the University of Califomia

Oakland, CA 94607
Donna Hershkowitz - The State Bar of Califomia Interim Executive Director

Vanessa Holton - The State Bar of Califomia Interim Executive Director
Review Unit Office of General Counsel

80 Howard Street
San Francisco, CA 94105-1617
-10-
ATTACHMENT # 1
SUBP-002
ATTORNEY OR PARTY WITHOUT ATTORNEY (Hame, State Bar number, and addiess): FOR COUKT use ONLY
Lindsay A. Ooulding, SBN 227195
Olatomiwa Aina, 325566
TELEPHONENO. 916-929-1481 F'^No- 916-927-3706
E-MAIL ADDRESS: igouIding@porterscott.eom
ATTORNEY FOR pva».«i Mighael Bovd. Stephen Chilcott. Danesha Nichols, et al.
NAME OF COURT: Superiot CouTt of Califomia, County of Sacrainento
STREETADDRESS: 9 t h Street
MWUNG ADDRESS: 'J2Q 9 t h S t r e e t
^^^""^""^"^ Sacramento 95814
BRANCH NAME:
PUMNTIFF/PETITIONER; jafoslaw WaszczuR
DEFENDANTR/ ESPONDENT: Regcnts of the University of California, et al.
CIVIL SUBPOENA (DUCES TECUM) for Personal Appearance and CASE NUMBER:
Production of Documents, Electronically Stored Information, and Things at 34-2013-00155479
THE PEOPLE OF THE STATE OF CALIFORNIA, TO (name, address, and telephone numberof witness. If known):
Irina Waszczuk, 2216 Katzakian Way, Lodi, CA 95242
1. YOU ARE ORDERED TO APPEAR AS A WITNESS in this action at the date, time, and place shown in the box below
UI4LESS your appearance is excused as indicated In box 3b below or you make an agreement with the person named in
Item 4 beiow.
a. Date: May 7,2021 Time: 9:00 a.m. I I Dept: 43 • Div.: I I Room:
b. Address: 79.0 Qth StrftP.t. .Sar.rnmp.ntn CA 9<>R14
2. IF YOU HAVE BEEN SERVED WITH THIS SUBPOENA AS A CUSTODIAN OF CONSUMER OR EMPLOYEE RECORDS
UNDER CODE OF CIVIL PROCEDURE SECTION 1985.3 OR 1986.6 AND A MOTION TO QUASH OR AN OBJECTION HAS
BEEN SERVED ON YOU, A COURT ORDER OR AGREEMENT OF THE PARTIES, WITNESSES, AND CONSUMER OR
EMPLOYEE AFFECTED MUST BE OBTAINED BEFORE YOU ARE REQUIRED TO PRODUCE CONSUMER OR EMPLOYEE
RECORDS.
3. YOU ARE (item a orb must be checked):
a. I / I Ordered to appear in person and to produce the records described In the declaration on page two or the attached
declaration or affidavit. The personal attendance of the custodian or other qualified witness and the production of the
original records are required by this subpoena. The procedure authorized by Evidence Code sections 1560(b), 1561, and
1662 will not be deemed sufficient compliance with this subpoena.
b. • Not required to a p p e a r in pF)r.<>nn if yni i prnHi inp (I) the records described in the declaration o n page t w o or the attached
declaration or affidavit and (ii) a completed declaration of custodian of records in compliance with Evidence Code sections
1560,1561, 1562, and 1271. (1) Place a copy ofthe records in an envelope (or other wrapper). Enclose the original
declaration of the custodian with the records. Seal the envelope. (2) Attach a copy of this subpoena to the envelope or
write on the envelope the case name and numtier; your name; and the date, time, and place from item 1 In the box above.
(3) Place this first envelope in an outer envelope, seal It, and mail it to the clerk of the court at the address in item 1.
(4) Mail a copy of your declaration to the attomey or party listed at the top of this fomn.
4 IF YOU HAVE ANY QUESTIONS ABOUT THE TIME OR DATE YOU ARE TO APPEAR, OR IF YOU WANT TO BE CERTAIN
THAT YOUR PRESENCE IS REQUIRED, CONTACT THE FOLLOWING PERSON BEFORE THE DATE ON WHICH YOU ARE
TO APPEAR:
a. Name of subpoenaing party or attomey: Olatomiwa T . Aina b. Telephone number. 916-929-1481
5. Witness Fees: You are entitled to witness fees and mileage actually traveled both ways, as provided by law, ifyou request them
at the time of service. You may request them befbre your scheduled appearance from the person named in item 4.
DISOBEDIENCE OF THIS SUBPOENA MAY BE PUNISHED AS CONTEMPT BY THIS COURT. YOU WILL ALSO BE LIABLE
FOR THE 3UM OP FIVE HUNDRED DOLLARS AND ALL DAMAGES RESULTING FROM YOUR FAILURE TO OBEY.
Date Issued: 4/12/21

Olatomiwa T. Aina
(TYPE OR PRINT NAME) (SIGNATURE OF PERSON ISSUING SUBPOENA)
AttorneyforDefendants
(Declaration in support of subpoena on rovorso) aiTLE)
Page 1 of 3
l-orm Adoptsd for Mandatory Use CIVIL SUBPOENA (DUCES TECUM) for Personal Appearance and
Judicial Coundl of California Code of Clva Procedure,
SUBP4)02 (Rev. January 1,2012] Production of Documents, Electronically Stored Information, and Things at §18aS etseq.
wwM.ooiirts.ca.gav
SUBP-002
CASE NUMBER:
_ PLMNTIFF/PETITIONER: Jaroslaw Waszczuk
34-2013-00155479
DEFENOANT/RESPONDENT:Regents of the University of Califomia, et al.
The production of the documents, electronically stored infonnation, or other things sought by the subpoena on page one Is supported
by (check one):
I I the attached affidavit or | / | the following declaration:
DECLARATION IN SUPPORT OF CIVIL SUBPOENA (DUCES TECUM) FOR PERSONAL APPEARANCE AND
PRODUCTION OF DOCUMENTS, ELECTRONICALLY STORED INFORMATION, AND THINGS AT TRIAL OR HEARING
(Code Civ. Proc, §§ 1985,1987.5)
1. I, the undersigned, declare I am the I I plaintiff I I defendant I I petitioner i I respondent

U 2 attomey for (specify): defendant C Z I other (specify):
in Uie above-entitied action.
2. The witness has possession or control of tiie documents, electronically stored information, or other things listed below, and shall
produce them at the time and place specified in the Civil Subpoena for Personal Appearance and Production of Records at
Trial or Hearing on page one of ttiis fomn (specify the exact documents or other things to be produce; if electronically stored
inforrnation ia demanded, the form orfonna in which each type of information is to be produced may be specified):
See Attachment 2
3. Good cause exists for Uie production of tiie documents, electronically stored Infomiation, or otiier things described in paragraph 2
for the following reasons:
Judgment creditors have submitted an application to examine Irina Waszczuk to determine i f she has assets
that will satisfy the judgment against her spouse. Good cause exists to produce the requested documents as
they have pertinent infomation about the witness' financial status. They will assist the court and judgment
creditors in determining how the judgment against judgment debtor can be satisfied.
4. The documents, electronically stored Infomiation, or other things described in paragraph 2 are material to the issues involved In this
case for the following reasons:
The documents have relevant infonnation that will be used in the examination of Irina Waszczuk to
determine if she has assets that will be used to satisfy the judgment against her spouse, the judgment debtor.
1 declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
Date: 4/12/21
Olatomiwa T. Aina
(TYPE OR PRINT NAME) •(SIQIMATURE OF ( j SUBPOENAING PARTY
I • I AHORNEYFOR
— SUBPOENAING PARTY)
Request for Accommodations

Assistive listening systems, computer-assisted real-time captioning, or sign language interpreter services are available
if you ask at least five days before the date on which you are to appear. Contact the clerk's office or go to
www.couns.ca.gov/torms tor Request for Accommodations by Persons With Disabilities and Response (form MC-410).
(Civil Code, § 54.8.)
(Proof of service on page 3)
1
0UDPÔ02 [nov. January 1, £012] CIViL SUBPOENA (DUCES TECUM) for Personal Appearance and Page 2 of 3
SUBP-002
_ PLAINTIFF/PETITIONER: Jaroslaw Waszczuk CASE NUMBER:
34-2013-00155479
DEFENDANT/RESPONDENT: Regcttts of the Unlversity of California, et al.
PROOF OF SERVICE OF CIVIL SUBPOENA (DUCES TECUM) for Personal Appearance and Production of
Documents, Electronically Stored Information, and Things at Trial or Hearing and DECLARATION
1. I sen/ed this Civil Subpoena (Duces Tecum) for Personal Appearance and Production of Documents, Electronically Stored
Information, and Things at Trial or Hearing and Declaration by peraonally delivering a copy to the peraon aerved as fbllows:
a. Person served (name):

b. Address where served:
c. Date of delivery:
d. Time of delivery:
e. Witneee fees (ohook ono):

(1) I I were offered or demanded
and paid. Amount ^
(2) I I were not demanded or paid.
f. Fee for service: $
2. I received this subpoena for service on (date):
3. Person serving:
a. I I Not a registered Califomia proceee server.
b. I I California sheriff or marshal.
c. I I Registered California process server.
d. I I Employee or Independent conb-actor of a registered California process server.
e. I I Exempt from regisb'ation under Business and Professions Code section 22350(b).
f. I I Registered professional photocopier.
9-1 I Exempt from registration under Business and Professions Code section 22451.
ll. Name, uauiuss, leleptiorie number, and, irapplicaDle, county or registration ano number
I declare under penalty of penury under the laws of the State of (For California sheriff or marshal use only)
California that the foregoing is tme and con-ect. I certify that the foregoing is true and corror.t.
Date: Date:
• (SIGNATURE)
(SIGNATURE)
SUBP.002 |Rav. January 1,2012]

CIVIL SUBPOENA (DUCES TECUM) for Personal Appearance and Page 3 or 3
ATTACHMENT # 2
(HtCClYfp (^-^ ^/Z2/201/ rTT ^ AT-138/EJ-125
ATTORNEY OR PARTY WITHOUT ATTORNEY: STATE BAR NO.: FOR COQKTl/SE ONLY
NAME LlndsayAGouldlng. SBN 227195
FIRM NAME Porter Scott
STREETADDRESS: 350 Unlverslty AvBHue
CITY: Sacramento STATE CA apcooE 95825
TELEPHONENO.: (016)920-1481 FAXNOJ (016)027-3706
E-MAIL ADDRESS: Igouldlngigporterscott.com, oainatgporterscotLcom
ATTORNEY FOR (name); Defendants Boyd, Chilcott, Seifert, Oropeza, and Nivhols
SUPERIOR COURT OF CALIFORNIA. COUNTY OF SACRAMENTO
STREETADDRESS: 720 9tii Street
MAUi NQ ADDRESS: 720 9th Street
OTY AND ap CODE Saoamento 95814
BRANnH NAME-
PLAINTIFF JAROSLAW WASZCZUK

DEFENDANT REGENTS OF THE UNIVERSITY OF CALIFORNIA, et al.
APPLICATION AND ORDER FOR APPEARANCE AND EXAMINATION CASENUMBER:
i~x1 ENFORCEMENT OF JUDGMENT ATTACHMENT (Third Person) 34-2013-00155479
I I Judgment Debtor | x | Third Person
ORDER TO APPEAR FOR EXAMINATION
a. furnish information to aid in enforcement of a money judament aaainst you.
b. answer conceming property of tiie judgment debtor In your possession or control or conceming a debt you owe the
c. I judgment debtor. property of ttie defendant In your possession or control or concerning a debt you owe the defendant
I answer conceming
Date:iWAY 7. 2021 Time: 9:00 AIW. Dept or Div.: 43 Rm.:
Address of court n n is shown above | | is:
3. I hls order may be served by a shentr, marshal, registered process server, or the following specially appointed person (name):
Date:
JUDGE
APPLICATION FOR ORDER TO APPEAR FOR EXAMINATION
4. I X I Original judgment CTedltor I I Assignee of record I I Plaintiff who has arightto attach order
to appear and fijmieh information to aid in enforcement o f t h e money j u d g m e n t or to answer concerning property or d e b t
5. The person to be examined is
a. I I the judgment debtor.
b. I X I a third person (1) who has possession or control of property belonging to tiie judgment debtor or ttie defendant or (2) who
owes the judgment debtor or the defendant more tiian $250. An affidavit supporting this application under Code of Civil
The person to be examined resides or has a place ofbusiness in this county or within 150 miles ofthe place of examination.
I I ThiG court ie n o t the oourt In w h i c h t h e money j u d g m e n t le entered or (attachment only) the court that issued the writ of
attachment. An affidavit supporting an application under Code of Civil Procedure section 491.150 or 708.160 Is attached.
I I The judgment debtor has been examined within the past 120 days. An affidavit showing good cause for another examination
is attached.
I declare under penalty of perjury under the laws of the State of California that ttie foregoing Is true and correct.
Date: April 12 2021
Olatomiwa T. Aina
)k (PiatomiwuO'.Cliiui
(SIGNATURE OF DECLARANT)
(Continued on reverse) Page 1 ot 2
Form Adopled for Mandatoiy Use Coda of CMI Procedure,
Judicial Council of CalHomla APPLICATION AND ORDER FOR S§ 491.1-10, 708.110,70S.120, 70ai70
AT-13a/EJ-12S [Rev. January 1, 2017) APPEARANCE AND EXAMINATION www.eourts.ea.gov
AT-138/EJ-125
Information for Judgment Credttor Regarding Service
If you want to be able to ask the court to enforce tine order on tiie judgment debtor or any third party, you
must have a copy ofthe order personally served on the judgment debtor by a sheriff, marshal, registered
process server, or the person appointed in item 3 ofthe order at least 10 calendar days before the date of
the hearing, and have a proof of service filed with the court.
APPEARANCE OF JUDGIVIENT DEBTOR (ENFORCEIVIENT OF JUDGIUENT)
NOTICE TO JUDGIVIEI^ DEBTOR If you fail to appear at the time and place specified in this order,
you may be subject to arrest and punishment for contempt of court, and the court may malce an
order requiring you to pay the reasonable attorney fees Incurred by the Judgment creditor in this
proceeding.
APPEARANCE OF A THIRD PERSON (ENFORCEIVIENT OF JUDGMENT)

you may be subject to arrest and punishment for contempt of court, and the court may make an
order requiring you to pay the reasonable attorney fees incurred by the Judgment creditor in this
proceeding.
(2) NOTICE TO JUDGMENT DEBTOR The person In whose favor the judgment was entered in this
that Is yours or owes you a debt. This prbperty or debt is as follo\As (describe the property or debt):
Community property ,of Plaintiff/Judgment Debtor
Irina Waszczuit's employment wages
2000 Mercedes 320
Any and all community property owned by Plaintiff and Irina Waszczulc
judgment, you must file your exemption claim in writing with the court and have a copy personally
served on the Judgment creditor not later than three days before the date set for the examination.

NOTICE TO PERSON SERVED If you fall to appear at the time and place specified in this order, you
may be subjeet to arreet and punishment for contempt of court, and the court may malce an order

it is your duty to designate one or more of the following to appear and be examined: officers,
directors, managing agents, or other persons who arc familiar with your property and debts.
Request for Accommodations. Assistive listening systems, computer-assisted real-time captioning, or sign
language interpreter services are available ifyou ask at least 5 days before your hearing. Contact the clerk's
office for Request for Accommodation (form MC-410). (Civil Code, § 54.8.)
AT-138/EJ-12S [Rev. January 1,2017] Page 2 of 2
APPLICATION AND ORDER FOR
(Attachment—Enforcement ofJudgrnent)
MC-025
SHORT TITLE: CASE NUMBER: ^
Jaroslaw Waszczuk v. Regents of the University ofCalifomia, et al, 34-2013-00155479

ATTACHMENT (Number): 2_
(This Attachment may be used with any Judicial Council form.)
14. All DOCUMENTS relating to any money or property held in trust for YOU.
15. All DOCUMENTS relating to any money or property held in trust for YOUR spouse.
16. All DOCUMENTS relating to any transfer of over $500 made to orfromYOUfromOctober 4,2015 to
present.
17. All DOCUMENTS relating to any transfer of over $500 made to orfromYOUR spousefromOctober 4,
2015 to present.
18. All DOCUMENTS relating to any COMMUNITY PROPERTY held by YOUR spouse.
19. All DOCUMENTS relating to any retirement account held by Y O U .
20. A11 DOCUMENTS relating to any retirement account held by YOUR spouse.
21. All DOCUMENTS relating to any payroll stubs indicating eamingsfromany employment you have
engaged infrom2016 to the present
(Ifthe item lhat this Attachment concems is made under penalty ofpeijury, all statements in this Page 2 of 2
Attachment are made under penalty of perjury.) (Add pagoa oa roguirod)
Fomi Appnwed (orOptional Use ATTACHMENT «ww.eoiiiflnlb.cs.flOir
Judicial Council or California
M&026lRev. July 1,2008) tO J u d l c i a l C O U n c l i F O H H
^ MC-025
SHORT TITLE: CASE NUMBER:
Jaroslaw Waszczuk v. Regents of the University ofCalifomia, et al, 34-2013-00155479

ATTACHiWENT (Number): 2_
(This Attachment may be used with eny Judldal Council fbrm.)
1. All DOCUMENTS sufficient to IDENTIFY YOUR current residence, including but not limited to
the residence, and the amount of YOUR rent or monthly mortgage payment
2. All DOCUMENTS relating to any real estate in which YOU have an ownership interest, and any income
3. All DOCUMENTS relating to any real estate in which YOUR spouse has an ownership interest, and any
4. All DOCUMENTS relating to any business entity in which YOU have an ownership interest
6. All DOCUMENTS relating to any property in which Y O U have an ownership interest, including but not
limited to (i) all checking and savings accounts; (ii) jewelry; (iii) motor vehicles or watercraft; (iv) debts or
7. All DOCUMENTS relating to any property in which YOUR spouse has an ownership interest including but
not limited to (i) all checking and savings accotmts; (ii) jewehy; (iii) motor vehicles or watercraft (including
but not limited to vehicle ownership certificates); (iv) debts or notes owed by another to YOUR spouse; (v)
stocks, bonds, and other securities; and (vi) life insurance policies.
8. All DOCXJMENTS relating to any safe or safety deposit box YOU or your spouse own or use and the
contents therein.
9. All federal and state corporate tax retums YOU havefiledfrom2012 to the present
10. All DOCUMENTS relating to any of YOUR property held by third parties.
11. All DOCUMENTS relating to any of YOUR spouse's property held by third parties.
12. All DOCUMENTS relating to any benefits YOU have received or currently receive, including by not
13. All DOCXJMENTS relating to any vested future interest YOU have in any property or in the payment of
auy money. •
(Ifthe item that this Attachment concems is made under penalty ofpeijury, all statements in this Page 1 of 2
Attachment are m a d e u n d e r p e n a l t y o f perjury.) /AMH • wi
\/\Q0 pages as reQuireo)
Fomi Approved tor optional Use ATTAfHIUIPNT www.oouiVnli).ce.gov
Judldal Councll of California " ' '"^niVICn I
Mc^HsiRev. July 1.2008] to Judlclal Councli ForiTi
ATTACHMENT # 3
PORTER I S C O T T
A PROFESSIONAL CORPORATION
Olatomiwa T. Aina, SBN 325566
Sacramento. Califomia 95825
TEL: 916.929.1481
FAX: 916.927.3706
nsheehan(3).porterscott.com
dbardzellfeQporterscottcom
7
Attomeys for Defendant
8
REGENTS OF THE UNIVERSITY OF CALIFORNL^
9
Attomeys for Judgment Creditors/Former Defendants
10
MICHAEL BOYD, STEPHEN CHILCOTT, DANESHA NICHOLS, CINDY OROPEZA, and
11 BRENT SEIFERT
13 SUPERIOR COURT OF CAT-TFORNIA, COUNTY OF SACRAMENTO
I - '3 S
H " " 00 o
O 14
OS S
Mis CN M
ON O)
Ov OS
15 JAROSLAW ("JERRY') WASZCZUK, CASE NO. 34-2013-00155479
^ 16
m
CU c a
17
v.
Plaintiff, DECLARATION OF OLATOMIWA T.
AINA IN SUPPORT OF JUDGMENT
CREDITOR'S APPLICATION FOR
APPEARANCE AND EXAMINATION OF
D <zi
o
>o
18
m tHE REGENTS OF THE UNIVERSITY OF IRINA WASZCZUK
19 CALIFORNIA, UNIVERSITY OF
CALIFORNIA DAVIS HEALTH SYSTEM, Date: May 7,2021
20
UC DAVIS MEDICAL CENTER, UC Time: 9:00 a.m.
21 DAVIS, ANN MADDEN RICE, MIKE Dept.: 43
BOYD. STEPHEN CHILCOTT, CHARLES
22 WITCHER, DANESHA NICHOLS, CINDY
23 OROPEZA, BRENT SEIFERT, PATRICK Complaint Filed: December 4,2013
PUTNEY. DORIN DANILIUC, and Does 1 Amended Complaint Filed: June 16.2014
24 through 50, inclusive, SAC Filed: September 30,2014
25 Defendants.
26
27 III
28 III
(0240671 S.DOCX) 1
DECLARATION OF OLATOMIWA T. AINA IN SUPPORT OF JUDGMENT CREDITOR'S
APPLICATION FOR APPEARANCE AND EXAMINATION OF IRINA WASZCZUK
A
I, Olatomiwa T. Aina, declare as follows:
2 1. I am an attomey at law licensed to practice before all courts in the State of Califomia
3 and am a shareholder with the lawfirmof PORTER SCOTT, attomeys of record for current
4 Defendant REGENTS OF THE UNIVERSITY OF CALIFORNL\ C'Defendant" or
5 "UNIVERSITY") and Judgment Creditors/former Defendants BOYD, CHILCOTT, NICHOLS,
6 OROPEZA. and SEIFERT ("anti-SLAPP Defendants" or "Judgment Creditors") in the above-titled
7 action. I make this declaration in support of Judgment Creditors' Application for Appearance and
8 Examination of Irina Waszczuk and In compliance with Code of Civil Procedure section 491.110
9 and 708.120.
10 2. On December 1, 2014, Judgment Creditors BOYD, CHILCOTT, NICHOLS,
11 OROPEZA, and SEIFERTfileda Special Motion to Strike Judgment Debtor/Plaintiff JAROSLAW
o
12 WASZCZUK'S (herein "Judgment Debtor" or "PlaintifP') causes of action as pled against them.
o
(S
am 13 The Judgment Creditors contended that Judgment Debtor's causes of action against them arose from
1- "3 a _ vo
H o 00 o
8 S"^^^ 14 protected activities pursuant to Code of Civil Procedure § 425.16; namely, their participation in the
_ > U o, OS
processing, investigation, hearing and deciding of complaintsfiledby Judgment Debtor and others
^1. 17
pursuant to the policies and procedures of the Defendant UNIVERSITY.
D CO
3. On April 14, 2015, the Court issued an Order granting the Special Motion to Strike
18 finding that Judgment Debtor failed to establish a probability of prevailing on the causes of action
19 pled against the anti-SLAPP Defendants/Judgment Creditors as required by section 423.16 and
20 entering judgment in favor ofthe anti-SLAPP Defendants/Judgment Creditors. Attached as Exhibit
21 A is a true and correct copy of the Court's April 14, 2015 Order Granting anti-SLAPP
22 Defendants/Judgment Creditors' Special Motion to Strike.
23 4. On May 11, 2015, the anti-SLAPP Defendants/Judgment Creditorsfileda Motion
24 for Fees and Costs pursuant to CCP § 425.16, subdivision (c) and the Court's Order dated April 14,
25 2015 on anti-SLAPP Defendants/Judgment Creditors' Special Motion to Strike.
26 6. On June 29, 2018, the Court entered an Order granting anti-SLAPP
27 Defendants/Judgment Creditors' Motion for Fees and Costs in the amount of $22,284 against
28 Judgment Debtor. Attached as Exhibit B is a true and correct copy ofthe Court's June 29, 2018
Order Granting anti-SLAPP Defendants/Judgment Creditors' Motion for Fees and Costs and
{02406715.D0CX} 2
1 Tentative Ruling approved of therein.
2 7. The Judgment Creditors served Judgment Debtor with Judgment Debtor Requests for
3 Production ofDocuments (Set One) and Judgment Debtor Interrogatories (Set One) on October 9,
4 2018. Attached as Exhibit C is a tme and correct copy nf Judgment Creditors' Judgment Debtor
5 Requests for Production of Dociunents (Set One) and Judgment Debtor Interrogatories (Set One) to
6 Judgment Debtor.
7 8. On September 6, 2019, Judgment Debtor served verified responses to the Requests
8 for Production ofDocuments (Set One) and Judgment Debtor Interrogatories (Set One). According
9 to Judgment Debtor's responses, Judgment Debtor and his spouse, Irina Waszczuk have lived in a
10 home together since December 2012. Mrs. Waszczuk contributes $2,075 to the monthly rent.
11 Further, Judgment Debtor and Mrs. Waszczuk joindy own a 2000 Mercedes 320. Judgment Debtor
o
12 and Mrs. Waszczuk have health insurance through Mrs. Waszcztik employment with Nordstrom. In
o
(N
13 his response. Judgment Debtor alleged he had no further information about Mrs. Waszczuk's
H -p a
H CO V I 00 ^
O ^-1 c n 14 financial assets. Attached as Exhibit D is a true and correct copy of Judgment Debtor's unverified
0 \ OS
vd vo 15 responses to Judgment Creditors' Judgment Debtor Requests for Production ofDocuments (Set One)
ill 3 CO
i-i
I 16 and Judgment Debtor Interrogatories (Set One).
10. On information and belief, Irina Waszczulc, as the Judgment Debtor's spouse, is in
o
v\ 17
cn
18 possession of other community property that will satisfy the judgment against Judgment Debtor.
19 I make this Declaration on my own personal knowledge except to the facts stated on
20 information and belief as to such facts, 1 believe them to be true. If called upon to do so, I could and
21 would competently testify about the matters asserted herein.
22 I declare imder the penalty of perjury under the laws of the State of Califomia that the
23 foregoing is true and correct and that this Declaration was executed on the 12th day of April. 2021
24 at Sacramento, Califomia.
25
(PCatonuwu (Una
26
27 Olatomiwa T. Aina
28
(0240671S.DOCX}
DECLARATION OF OLATOMIWA T. AINA IN SUPPORT OF JUDGMENT CREDITOR'S v
Waszczuk V. Regents of the University of California, et aL
1
Sacramento Coumty Superior Court, Case No. 34-2013-00155479
2
PROOF OF SERVICE
3
4 At the time ofservice, I was over 18 years of age and not a party to this action. My busmess
address is 350 University Avenue, Suite 200, Sacramento,"Califomia 95825.
5
6 On the date below, I served the following document:
7 DECLARATION OF OLATOMIWA T. AINA IN SUPPORT OF JUDGMENT CREDITOR'S

8
9 am readily familiar with this business' practice for collecting and processing correspondence for maiiing.
On the same day tliat correspondence is placed fbr collection and mailing, it is deposited in the ordinary
10 course ofbusiness with the United States Postal Service, in a sealed envelope with postage fully prepaid.
BY PERSONAL SERVICE: I caused such document to be personally delivered to the person(s) addressed
11 below. (1) For a party represented by an attomey, delivery was made to the attomey or at the attomey's
office by leaving the documents, in an envelope or package clearly labeled to identify the attomey being
12 served, with a receptionist or an individual in charge of the office, between the hours of nine in the moming
o
o
n and five in the evening. (2) For a party, delivery was made to the party or by leaving the documents at the
13 party's residence with some pereon not younger than 18 years of age between the hours of eight in the
CO m 00 moming and six in the evening.
u 14 BY OVERNIGHT DELIVERY: I enclosed the documents in an envelope or package provided by an
5 <: OS
CO ? U OV ovemight delivery carrier and addressed to the person(s) listed below. I placed the envelope or package for
1^ 15 collection and ovemight delivery at my office or a regularly utilized drop box of the ovemight delivery
6 g 5;
i carrier.
16
BY FAX TRANSMISSION: Based on an agreement of the parties to accept service by &x transmission, I
t 3 CO faxed the documents to the persons at the fax numbers listed below. No error was reported by the fax
o 17
machine that I used. A copv of the record ofthe fax transmission, which I printed out, is attached
18 BY ELECTRONIC SERVICE: Based on a court order or an agreement ofthe parties to accept service by
electronic transmission, I caused the documents to be sent to the persons at the electronic notification address
19 listed below.
2216 Katzakian Way
21 Lodi, CA 95242
22
I declare under penalty of perjury under the laws of the State of Califomia that the foregoing
23
is true and correct. Executed at Sacramento, Califomia on April 12,2021.
24
25
Virginia yiia
26
Virginia Yao
27
28
(0240g713J3OCX)

ATTACHMENT # 4
ATTACHMENT # 5
SACRAMENTO Sacramento County Public Law Library
COUNTY & Civil Self Help Center
PUBLIC-LAW
L 609 9th St.
ALERT: COVID-19 has terhporarily changed the way courts are iacramento, CA 95814
saclaw.org providing services. Our guides do not reflect these temporary
changes. Contact the court directly for the most up to date infbmration (916) 874-6012
on .court processes and procedures. www.saccourt.ca.Qov
DEBTOR'S EXAMINATION
Discover the Judgment Debtor's Assets
This Guide includes instructions and sample forms. Links to download the fillable forms are at the e
of this Guide. Additional copies of this Guide can be accessed at sac/aw.ora/debtor-exatn.
BACKGROUND
Related Legal Research Guide
A debtor's examination, also known as an order of
examination, is often a preliminary step before initiating • Enforcement of Judgments
collection efforts. This examination is a formal court
proceeding in which the judgment creditor may question the
debtor to obtain information about the location and value of the judgment debtor's assets, including
paychecks and other sources of income, bank accounts, stocks and other investments, and personal
and real property. This procedure may also be used to (question a third party who may be in
possession of the judgment debtor's assets, or owe debts to the judgment debtor.
STEP-BY-STEP INSTRUCTIONS
The Judicial Council form used in this procedure is:

• Application and Order for Appearance and Examination (Ej-125)
www.courts.ca.aov/documehts/ei125.pdf
To examine a third party (someone who is not a named party in the case), you must attach a
declaration indicating that you believe the third party is in possession of the debtor's assets or is
indebted to the judgmeht debtor in an amount exceeding two hundred fifty dollars ($250), and
describing the basis of your belief. You may write your declaration on this Judicial Council form:
• Attached Declaration (MC-031)
www.courts.ca.aov/documents/ej125.pdf
The declaration must be attached to your application.
In Sacramento County, hearing dates for orders of examination are self-selected. This means you, as
the person requesting the hearing, are responsible for selecting the hearing date. Orders of
examination are cun-ently heard in Department 43 on Fridays at 9:00 a.m. Write the date you choose
on the Application and Order for Appearance and Examination (EJ-125); you do not need to reserve
the time with the court.
Disclaimer: This Guide Is Intended as general information only. Your case may have factors requiring
different procedures or forms. The information and instructions are provided for use in the
Sacramento County Superior Court. Please keep In mind that each court may have different
requirements. If you need further assistance consult a lawyer. ..
saclawôrg Debtor's Examination
There are two separate time periods to consider when choosing your hearing date;
• The Judgment Debtor must be served at least 10 days prior to the hearing date Califomia
Code of Civil Procedure (CCP) S 708.116(d).
Be sure to select a date that will allow enough time for service.
StejiirFjie^y^^ , '. \ ...
To obtain your Order for Appearance and Examination, file the following items with the court:
• Application and Order for Appearance and Examination (EJ-125), inciuding the Attached
Declaration (MC-031), if needed (original -•• 2 copies).
• A file-endorsed (stamped) copy of your Judgment, if entered prior to November 13, 2007, If
you do not have a copy of the judgment, you may obtain one from the court. See
www.saccourt.ca.qov/civil/file^status.aspx for more Information.
• Filing fee (currently $60 per application; see www.saccourt.ca.qov/fees/docs/fee-schedule.pdf
for current fees).
• Self-addressed, stamped envelope. If you would like the cierk to mall you a signed copy of the
order.
You may file these documents in person in Room 102 ofthe Gordon D. Schaber Courthouse, located
at 720 Ninth Street. You may also file by mail. If you file by mall, please allow extra time for
processing your paperwork.
After receiving your documents, the clerk will forward them to the judge for signature. Once signed,
the clerk will mall you a copy, if you provided a self-addressed, stamped envelope. Otherwise, you
may print a copy of the signed Application and Order for Appearance and Examination (EJ-125) from
the court's website.
The examinee must be personally served at lieast 10 calendar days prior to hearing. If examining a
third party, ybu must also serve notice on the judgment debtor, either personally or by mall, at least
10 calendar days prior to the hearing. Calendar days Include weekends and holidays.
If you want the option of having a bench warrant issued if the examinee does not appear, service
must be made in person by a sheriff or a registered process server, unless the court specially
appointed a different server (CCP S 708.170). To have your documents siBrved by the Sacramento
County Sheriffs Department, subrtiit the following documents to the Sheriffs Civil Bureau at 3341
Power Inn Road #313:
• Original Sheriff Instructions (available at
httDs://www.sac3heriff.com/docurrients/7483%20Form%20049A-
lnstructions%20to%20the%20Sheriff%20Rev%2007-18.Ddf
• Application and Order for Appearance and Examination (EJ-125) signed by the judge (original
+ 1 copy)
• Fee for service (cun*ently $40, see
https://wvyw.sacsheriff.com/docunfients/2020%20Fee%20Schedule.pdf for current fees)
saclaw.ora/debtor-exarri
saclaWiiOrg Debtor's Examination
After serving your documents, the Sheriff will mail the proof of service to you. If you hire a registered
process server, ask that the proof of service be returned to you, rather than the court. You must file
the proof of service In Department 43 on the day of your hearing (Local Rule 2.10).
Step^4:^/^rld>th^^^ ^ / . •
When you anive at the courthouse, check in with the S a m p l e q u e s t i o n s to ask the d e b t o r
clerk in Department 43, and tum in your proof of
service. The judgment debtor or third-party
examinee will be given an oath, and the examination California Courts Self-Help Website -
will be conducted privately between the parties. Sample Questions to Ask a Debtor
There Is no court reporter provided for this type of ;Www.courts.ca.qov/11328.htm
hearing, but you may provide one if you wish. Court How to Collect When You Win a Lawsuit
reporters can be found in the yellow pages under in California KFC 1065 .Z9 H69 Appendix
"Court Reporters" or "Legal Services," or from the
National Court Reporters Association's online Enforcing Civil Money Judgments
directory at www.ncrasourcebook.com. KFC 1065 .065 Appendix D
Electronic Access: On the Law Library's
Be sure to have questions prepared ahead of time, computers, using OnLaw.
to ensure you don't forget anything.
^|8Pi5riMliiJB{|im^ 11 _
If you have filed a proper proof of service showing that the examinee was served In a timely manner
by a sheriff or registered process server, the court will order the issuance of a bench warrant for the
examinee's failure to appear (CCP 708.170(a)(1)(A). 708.170(a)(1)(B)). To have the warrant
issued, you must submit the following Sacramento County local fomis to the court;
• Civil Bench Wanrant (CV/E-127A) (original + 2 copies)
• Instructions to Serve Civil Bench Wan-ant (GV/E-127B) (original + 2 copies)
• Sheriffs fee for service (currently $50 or $140 per warrant, depending on the court's order, see
httPs://www:sacsheriff.com/documents/2020%20Fee%20Schedule.pdf)
• Self-addressed, stamped envelope, if you would like a copy retilrned to you
After receiving your documents, the clerk will have the warrant signed by the judge, and will fonward
the original to the Sheriffs Department for service. Once the wan-ant is served, the court will set a
hearing date for the debtor to respond to his or her failure to appear at the priginally scheduled
hearing, and will notify you of the hearing date. You will need to appear at that hearing to conduct the
debtor examination.
Once you have obtained information about the judgment debtor's assets, you may begin your
collection efforts. There are numerous ways a judgment creditor may collect from a judgment debtor.
The method(s) used depend on the judgment debtor's assets. For more infonnation about collection
methods, see our series of Step-by-Step guides on Collecting Judgments on our website at
saclaw.org/law-l 01/collectinq-resistinq-iudaments-topic.
saclaw.ora/debtor-exam
saclaw.org Debtor's Examination
FOR HELP
Sacramento County Public Law Library Civil Self Help Center
609 9th Street, Sacramento 95814
saclaw.Orq/self-help/civil-self-help-center
Services Provided: The Sacramento County Public Law Library Civil Self Help Center provides
general information and basic assistance to self-represented litigants on a variety of civil legal issues.
Appointments will be made beginning at 8:30 a.m. Patrons who are present at 8:30 a.m. will be
entered into a random drawing to determine the order their case will be evaluated. If an appointment
is appropriate, it will be made for later in the day. You are encouraged to arrive by 8:25 a.m. to
participate In the appointment setting drawing.
Eligibility: Must be a Sacramento County resident or have a aualifvina case in the Sacramento County
Superior Court.
FOR MORE INFORMATION
On the Web:
California Courts Self-Help Website - Get Information aboiit the Debtor's Assets
www.courts.ca.gov/11187.htm
Califomia Courts Self-Help Website - Sample Questions to Ask a Debtor
www.courts.ca.aov/11328.htm
Sacramento County Superior Court - Orders of Examination
www.saccourt.ca.gov/civil/orders-of-examination.aspx
At the Law Library:

California Forms of Pleadino and Practice KFC 1010 .A65C3 (Ready Reference) Chap. 254
Electronic Access: On the Law Library's coniputers, using Lexis Advance.
California Practice Guide: Enforcing Judgments and Debts KFC 1065 .A9 S3 Chap. 6G
Electronic Access: On the Law Library's computers, using WestlawNext.
Debt Collection Practice in California KFC 256 .C83 Chap. 8
Electronic Access: On the Law Library's computers, using OnLaw.
Enforcing Civil Money Judgments; Here's How and When to Do It KFC 1065 .065
Electronic Accesis: On the Law Library's computers, using OnLaw.
How to Collect When You Win a Lawsuit KFC 1065 .Z9 S25 Chap. 6
Matthew Bender Practice Guide. California Debt Collection and Enforcement of Judgments
KFC 1065 .E5 M38 Chap. 10 ,
Electronic Access: On the Law Library's computers, using Lexis Advance.
Witkin's California Procedure KFC 995 .W58 (Ready Reference) Chap. 10
Electrdriic Access: On the Law Library's computers, using WestlawWex/.
IF YOU HAVE QUESTIONS ABOUT THIS GUIDE. OR IF YOU NEED HELP FINDING OR USING THE
MATERIALS LISTED. DONT HESITATE TO ASK A REFERENCE LIBRARIAN. •
H;\public\LRG-SBS\SbSs\Debtor's Examination\DebtorExam.docx updated 09/19 mi^
4
sactaw.org/debtor-exam
saclaw;6rg Debtor's Examination
ATTACHMENTS: FORMS AND INSTRUCTIONS

The Judicial Council form commonly used in this procedure is:
• Application and Order for Appearance and Examination (EJ-125)
vtfww.courts.ca.dov/documents/ei125.pdf
Sample filled-ln fomis with instructions are available at the end of this Guide.
saclaw.Org/debtor-exam
saclaWôrg Debtor's Examination
AT-138mj.128
ATTORNEY OH PARTV wmiOUT ATTORNEY:. RU) COURT USE OKLY
Your name, address, and
CaMn J. Creditor
phone number. In Pro Per
MRWNAUE:
means you're representing
6TBECT Aooncs6:203e Oonfwr Orlvfl
yourself. Check the box next
CITY: Sacramento
TEUPHONE NO.: 916-i 23-4567 to "Judgment Creditor:"
E4IAIL ADDRESS: ccredltortaieiTiall.oom
ATTORNtv roft in Pro Per
£ U e g B t 0 R COURT OF CAUFORNIA, COUKTV OF Sacramento
AODRESS: 720 Ninth street
Check
AODRESS'720 Ninth Street Court name, address, and branch.
Enforcement of ziPcooE:Sacramento. CA 95814
Judgment and ICH NAME: Civil
Judgment
Debtor or Third NTIFFCalvin J. Creditor
DAMTDoua J. Debtor PlaintifTs and Defendant's names
Person, as
as they appeared on the Complaint. Case Number.
appropriate. PLICATION AND ORDER FOR QUtNUUSER. .
i m t l ENFORCEMENT OF JUOGHEMT I 1 ATTACHMENT (ThW Person) 34-2009-00012345
I K I JudflntentPefatof r I Third Person
TO (name): I}oua J. Detitbr
YOU ARE ORDERED TO ARI inally t Name of the I referee appointed by Vne court, to
(umlshj Bfiimtlofi person tb be ainsi you.
answer asffiIhsjudi examined, and
iceming property of the purpose of BSion or control or conceming a debt you owe the
I I JudgmenI debtor property of the deft
answer ooriceming the examination.
(hat is subject lo attachment. y contitol or conceming a debt you owe the defiendant
Date: 2/6/2013 Time: 9 am Dept. or Div.: 37' Rm.:
Address of court l l is shown above I I is:
3. This order may be served by a sheriff, marshal, registered process serT
Enter the date, time, and location of the examination.
Date:
This order must be served rtot less than 10 days before the date set for the examination.
Check judgment Creditor 1 IMPORTANT NOTICES ON REVERSE
— — — APPUCATION FOR ORDER TO APPEAR FOR EXAMINATION
EUD Original Judgment creditor Assignee of record I I PlaintW who has a right to attach order
applies tor on order requiring (name): Doua J. Debtor ^ ^ ^ ^ ^ ^ J " " " " " ^ " " ,
tp appear and lumish Infonnation to aid In enforcement of the money ji^gment or to f Name of the person to be examined.
a. I K I Ihe Judgment debtor.
b. I I a third person (1) who has possessioh or control ABBBSdl^tBlQBOiOftttUllÛdflBfi&Utfitor br the defendant or (2) who
owes the Judgment debtor < ' Check the box describing I > P « « « " " "nder Code of Civil
Procedure section 491.110 orTOS.lZO ls at
6. The person to be examined resides pr has a place of busin
the person to be examined:
he place of examination.
I I This coon IS not me court in which Ihe money judgment is entered or iatlectiment only) the court that issued the wm ol
attachmenL An affidavil supportitq an appiicatiati under Code of Civil Procedure sectipn 491; 150 or 708.160 is attached.
8 1 I The judgment debtor has been examined within the past 120 days. An aNidavIt showing good cause for another examination
Is attached.
I declare under penalty of pei)ury under the laws of tne State of Caiifttmla that tne foregoing Questions 7 and 8 apply only in rare
Date: situations. Ched( the box only if the
entire statement is true.
CaMn J Creditor
(TYPE OR m m NAME) (ffiCNATKRE OF OEClARAKn
(Continued on revenie)
Fan AdemM )v Mmduory Uw CodoolCiviip
Juffldai CouxH ot Cailotr*a
Ar.|3IVEJ.I2StR». JBluvy 1.301T1
Enter your name, date and sign. fCSLiio. Tst.Ma Toa.tn, rs&tTo
(Auiitiiiiiujii"m!.iiiuimiiium w uuuyiimiim
sactaw.org/debtor-exam
ATTACHMENT # 6
P ORTE I S CO T T
ATTORNEYS
November 13,2018
Author's e-maii: clbardze]l(^ponerscott:com
VIA HAND DELIVERY

Sacramento County Courthouse NOV 1 3 2018
720 9* Street 350 Iniversity Avenue
Sulie 200
Sacramento.CA 95814 By Cristin. Clia'pi), Deputy ^lefksaai mento, CA9S82S
blerk ofthe Court, Dept. 37 TEL: .916.929.1481
FAX 9X6:927:3706
Re: Waszczuk V. Regents ofthe University of Gaiifoniia.et al.
Sacramento Superior Court Case No. 34-2013-001S5479 www:pbrterscott.com
jExiehipt From Filing Fees PitrisudM to Government Code § 6103
Re: Application and Order for Appearahce and Examination

Date: December 14,2018
Dear Gpurt Clerk:

Our office represents Defendant Regents ofthe Uhiiversity of Califorhia in the
above matter. We also represent the remaining Defendants, including in part,
N4ike Boyd, Stephen Chilcott, Brent Seifert, Cindy Oropeza and Dwes^
Nichols.
On October 24,2018, Defendants Boyd, Chilcott, Seifert, Oropeza;and>Nichols

submitted an Application and Order for Appearance and Examination of
Plaintiff Jaroslaw Waszczuk on behalf of Defendants Bfoyd. Chilcott, Seifert.
Oropeza and Nichols. The Application was deemed filed on November 7,
2018. The Examination was set for December 14,2018.
Defendants requeist that the December 14, 2018;Exaniinati6n of Plaintiff

Jaroslaw Waszczuk be taken off calendar. Defendtmts anticipate refiling for
a later examination date to ensure compUance with statutory notice
requirements.
Very truly yours,
PORTER SCOTT
A PROFESSION/^ eORPORATlON
By
Daniel, J. Bardzell
DPEB/DJB:wes
(Oi«d726.DOGX)
V3 - ..AH
AT-138/EJ-125
ATTORNeY OR PARTY WTMOUT ATTORNEV: STATE GAR NO.: FOIt COURT USE ONLY
NAMF' David p. E. Burtc6tt, SBN 241B96 / Daniel J. Bardzell, SBN 313993
FIRMNAME; PorterScott '
STREET ADDRESS: 350 University Avenue, Suite 200
CITY: Sacramento STATE: CA ZIP CODE: 95825
TELEPHONENO: 916.929.1481 fAXNO: 916.927.3706
E.MAI1.AODRESS: dburkett@porterscott.eom / dbardzell@porter8cott.com
ATTORNEY FOR (nams): Defendants Boyd, Chilcott, Seifert, Oropeza and Nichols
SUPERIOR COURT OF CALIFORNIA, COUNTY OF 3ACRAIVIENTO
STREETADDRESS: 720 9th Street
MAIUNGADDRESS: 720 Qth Street
CITV AND ZIP CODE: Sacramento, 95814
BRANCH NAME
PLAINTIFF JAROSLAW ("JERRY") WASZCZUK

DEFENDANT Boyd, Chilcott, Seifert, Oropeza and Nichols
APPLICATION AND ORDER FOR APPEARANCE AND EXAMINATION CASE NUMBER:
m ENFORCEMENT OF JUDGMENT O ATTACHMENT (Third Person) 34-2013^155479
I X I Judgment t>ebtor I I Third Pereon
1. TO Enamel JAROSLAW ("JERRY") WASZCZUK
a. I X I furnish information to aid in enforcement of a money judgment against you.
b. I I answer concerning property of the judgment debtor in your possession or control or concerning a debt you owe the
judgment debtor.
c. I i answer concerning property of the defendant in your possession or control or conceming a debt you owe the defendant
Date:December 14, 2016 Time:9:00 a.m. Dept or Div.:37 Rm.;
Address of court I x I is shown above | j is:
3. This order may be served by a sheriff, marshal, registered process senirer, or the fbllowing specially appointed person (name):
Dale:
JUDGE
n n Original judgment creditor .I I Assignee of record I I Plaintiff who has a right to attach order
applies for an order requiring (name): JAROSLAW ("JERRY") WASZCZUK '
to appear and furnish information to aid in enforcement of the money judgment or to answer conceming property or debt.
The person to be examined is
a. I X I the judgment debtor
b. . I I a third person (1) who has possession or control of property belonging to the judgment debtor or the defendant or (2) who
owes the judgment debtor or the defendant more than $250. An affidavit supporting this application under Code of Civil
The pereon to be examined rosidee or hoa a place of busineaa In this county or within 160 miles ofthe place of examination.
I ] This court is not the cogrt in which the money judgment is entered or (attachment only) the court that Issued the writ of
attachment. An affidavit supporting an application under Code of Civil Procedure section 491.150 or 708.160 is attached.
I ^ The judgment debtor has been examined within the past 120 days. An affidavit showing good cause for another examination
is attached.
I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct
Date: 10/24/2018
Daniel J. Bardzell
(TYPE OR PRINT NAME) (SIGNATURE OF i^CLARANT)
(Continued on reverse) PBHItlBf?

lendaloiy Uie Coda of CM Pmcmtuis,
lomie APPLICATION ANO ORDER FOR §J 491.110. 708.110, 708.120. 70S.170
IV. jQrtufl/y 1. 2017) APPEARANCE AND EXAMINATION mmMuit3.ea.gov
AT-138/EJ>12S
, Information for Judgnient Creditor Regarding Service
If you want to be able to aek the court to enforce the order on the judgnnent debtor or any third party, you
the hearing, and have a proof of servicefiledwith the court. ^
APPEARANCE OF JUDGMENT DEBTOR (ENFORCEMENT OF JUDQMENT)
NOTICE TO JUDGMENT DEBTOR If you fall to appear at the time and place specified In this order,
you may be subject to arrest and punishment for contempt of court, and the court may malte an
order requiring you to pay the reasonable attorney fees Incurred by the Judgment creditor In this
proceeding.
(1) NOTICE TO PERSON SERVED If you fail to appear at the time and place specified In this order,
order requiring you to pay the reasonable attomey fees incurred by the Judgment creditor in this
proceeding.
(2) NOTICE TO JUDGMENT DEBTOR The person In whose favor the Judgment was entered In this
action claims that the person to be examined underthis order has pbssession or control of property
that is yours or owes you a debt. This property or debt is as follows (describetfieproperty or debt):
If you claim that ail or any portion of this property or debt is exempt from enforcement of the money
Judgment you must flte your exemption claim in writing with the court and have a copy personally
served on the Judgment creditor not later than three days before the date set for the examination.

NOTICE TO PERSON SERVED If you fall to appear at the time and place specified in this order, you
may be subject to arrest and punishment for contempt of court, and the court may malte an order
requiring you to pay the reasonable attorney fees incurred by the plaintiff In this proceeding.

ASSOCIATION. TRUST, OR OTHER ORGANIZATION
it ie your duty to designate one or more ofthe following to appear and be examined: effieere,
directors, managing agents, or other persons who are familiar with your property and debts.
language interpreter services are available ifyou ask at least 5 days before your hearing. Contact the clerk's
office for Request for Accommodation (form MC-410). (Civil Code. § 54.8.)
AT-i38«j-i25iR«». jsnuanr 1. J017] APPLICATION AND ORDER FOR Pfto
APPEARANCE AND EXAMINATION .
RECEIVED
C i v i l DROf' BOX
2018 OCT 2t* PM2:26

G05SC COURTHOUSE
SUPERIOR COURT
Or CALIFORNIA
SACRAMENTO COUNTY
31
AT«138/EJ-126
ATTORNEY OR PARTY WTH0UTATTORf«V; STATE BAH NO.:
PDA cotmr use ONLV
MAME: David P. E. Burfceftl. SBN 241896 / Daniel J. Bardzell. SBN 313993
FIRMNAME. Porter Scott
STREETADDRESS: 350 Univorsity Avenue, Suite 200
CITV: Sacramento STATE: CA ZIP CODE: 95825
TELEPHONENO.: 916.929.1481 FAXNO.: 916.927.3706
E.MAII. ADDRESS: dburl(ett@pofterscotLconi / dbar(lzell@porterscotLcom
ATTonNSv FoniKiHMi: Oofendonts Boyd, Chilcott, Selfeit, Oropeza and Nichols
SUPERIOR COURT OF CALIFORNIA. COUNTY OF SACRAMENTO NOV - 7 2018
STREET AOORESS: 720 9th Street
MAIUNO ADDRESS 720 9th Street
CITY AND BP CODE: Sacramento, 95814
BRANCHNAME:
ByCfistin Cliapo, Deputy Clerk
PLAINTIFF JAROSLAW C J E R R r ) WASZCZUK
DEFENDANT Boyd. Chilcott, Seifert, Oropeza and Nichols
A P P U C A T I O N A N D ORDER FOR A P P E A R A N C E A N D EXAIUINATION CASE NUMBER

n n ENFORCEMENT OF JUOOMENT O ATTACHMENT (Third Person) 34-2013-00155479
n n JudBmont Debtor r ~ 1 TWird Person
ORDER TO APPEAR FOR EXAIMINATION

1. TO rname/JAROSLAW ("JERRY*) WASZCZUK
3. YOU ARE ORDERED TO APPEAR personally before this oourt, or before a referee appointed by the oourt, to
a. I X I fumish infonnation to aid In enforcement of a money Judgment against you.
b. I I answer concerning property of the judgment debtor in your possession or control or conceming a debt you owe the
judgment debtor.
c. I I answer conceming property of the defendani In your possession or control or concerniny a det)t you owe tiie defendant
Date:December 14,2018 Time:9:00 a.m. Depl orOiv.:37 Rm.:
Address of coiirt I K I is shown above | | Is:
3. This order mey be sen/ed by a sheriff, marshal, registered rver, or the following specially appointed pereon (name):
Oate:
Thia order muat be served not less than

IMPORTANT NOTICES ON
A P P L I C A T I O N FOR ORDER T O A P P E A R FOR EXAMINATION
I X I Original judgment creditor •I I Assignee of record I I Plaintjff who has e nght to attach order
applies for an order requiring (name): JAROSLAW ('JERRY*) WASZCZUK
to appear and fumish information to aid In enforcement of the money judgment or to answer concerning property or debt
5. The person to be examined Is
a. I X I the judgment debtor.
b. I I a third person (1) who has possession or control of property belonging to the judgment debtor or the defendant or (2) who
owes the Judgment debtor or the defendant more than $250. An affidavit supporting this application under Code of Civil
Procedure secUon 491.110 or 708.120 is attached.
The person to be examined resides or has a place of business in this county or vvithin 150 miles of the place of examination.
I 1 This court is not the court In which the money judgment is entered or (attachment only) the court that issued the writ of
attachment. An affidavit supporting an application under Code of Civil Procedure sectipn 491.150 or 708.160 is attached.
I 1 The Judgment debtor has been examined within the past 120 days. An affidavit showing good cause for another examination
is attached.
I declare under penalty of perjury under the laws of the State of Caiifbrnia that the foregoing is true and correct
Date: 10/24/2018
Daniel J. Bardzell
(TVPE OR PRINT NAME) (SIONATURe OF OECIARANT]
(Continued on reverse) Pl||« t o f i

tar MgrdBUnr Uas A P P U C A T I O N A N D ORDER FOR Coda el CMI *-
cfCBMonHa H 491.110.708.110. TDS.IM. 708.170
Jofua/y 1.2017) A P P E A R A N C E A N D EXAMINATION WMW.Mvitt.««.gpv
(Attaehment-~Enforeeroent of Judgment)
• AT-138/EJ'12S
information for Judgment Creditor Regarding Service
must have a copy of the oi-der personally served on the judgment debtor by a sheriff, marshal, registered
APPEARANCE OF JUDGMENT DEBTOR (ENFORCEMENT OF JUDGMENT)
NOTICE TO JUDGMENT DEBTOR If you fall to appear at the time and place specified In this order,
proceeding.
you may be subjeet to arrest and punishment for contempt of court, and the oourt may make an
proceeding.
(2) NOTICE TO JUDGIVIENT DEBTOR The person In Whose favor the Judgment was entered In this
that is yours or owes you a debt. This property or debt Is as follows (describe the property or debt):
If you claim that all or any portion of this property or debt Is exempt from enforcement of the money
Judgment, you must file your exemption claim In writing with the court and have a copy personally
served on the judgment creditor npt later than three days before the date set for the examination.

NOTICE TO PERSON SERVED If you fall to appeal' at the time and place specified in this order, you
maybe subject to arrest and punishment for contempt of court, and the court may make an order
requiring you to pay thereasonableattorney fees incurred by the plaintiff in this proceeding.
APPEARANCE OF A CORPORATION. PARTNERSHIP,

It is your diity to designate one or more of the folloviring to appear and be examined: officers,
directors, managing-agents, or other pereons who are familiar with your property and debts.
language interpreter services are available if you asic at least 5 days befon your hearing. Contact the cleric's
ofTice for Request for Accommodation (form MC-410). (Civil Code, § 54.8.) '
AT.ija«j.i26iRevj.nuan, 1,20171 APPUCATION AND ORDER FOR "^BeJofJ
APPEARANCE AND EXAIMINATION
7
1 7,arQslaw Waszczuk, In Pro per
DEC 27 2019
2
Lodi, GA 95242 By; • S. Khorn.
• 3 Phpfte: .209-663^2977 ': Depuiy Clerk
• 4
Email: jjAvl 9"8b@liye!'cotii.
5
7 SUPERIOR COURT OF THEE STATE OF CALIFORNIA

9 iFOR THE COUNTY OF SACRAMENTO
. 9
lo-
JARdSLAW WASZCZUK ) CaseNo. 34-2013-00155479
11 )
PLAiNTIFF ) PLAINTIFF JAROSLAW WASZCZUK'S
12 ) NOTICE OF OBiECTlGN TO THE COURT
13 •
I .ORDER DATEB! DECEMBER 13 & 17, 2019,
) AND PLAINTIFF'S REQUEST FOR COURT
14 THE^REGENTS dF.THE; UNiyERSr^ ) ORDER MOpiiFiCATlON - RE:
OPPOSITION, TO JUObMENT CREDITORS'
•15 FURTHEW.MOtlON TO COMPEL
MriCEiBd.YD; STEPHEljj CHI'LCOTT,
CHARLES;'wlXeH£Rvb RESPONSEiS> j b JUDGMENT DEBTOR"S
16
NlCHOLS.'cm^^Y 6kQPEZA-,.B^ INTERROd^TOklES AND REQUEST FOR
17 SEIPERT, PATRlGk PUTTJI^Y, DORIN PR:0I).Udtjb?y :6F DOCUMENTS AND
DANTLiuC, AND 1X)ES 1^50, inclusive MONEtARY SANCTIONS
18
19 DEFENDANTS ) HON. DA.yiD.I. BROWN

. < Conipfaiht.fiii&d .I>eceitiber. 14,2013
20 • Amended cbrhpl.aint tiled June 16, 2014
21
22
23 L
24 INTRGIDUCtlON
?.S
26
For the Record, JAROSLAW WASZCZUK (Hereafierthe Plaintiff), respectfully submits the
followinjg NOTICE OF OBJECTION TO THE (COURT ORtJER. DATED DECEMBER 17,2019
27
AfJD PLAmTIFF J^QUEkr FM^^^^^ ORDER MODIFICATION - RE: JUDGMENT
28
CREDITORS' FURTHER MOTION TO COMPEL RESPONSES TO JUDGMENT DEBTOR
- 1 - • ... • . '
NOTICE OF OBJECTION AND REQUEST FO?l CbURT ORDER MODIFICATION
1 INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS AND
2 MONETARY SANCTIONS for the following reason (s).
3
FIRST: The two Court Orders in this matter dated December 13, 2019, and December 17,
4
2019 (EXHIBIT # I ) (ROA 241 & 242) do not correspond with PlaintifTs Opposition to Judgment
5
Creditors' Further Motion to Compel Responses to Judgment Debtor Interrogatories and Request for
6
7 Production ofDocuments and Monetary Sanctions filed on December 4, 2019.
8 SECOND: The December 17, 2019, Court Order, which was supposed to address the Court
9
Hearing and Oral Argument on December 13, 2019, at 2:00 In Department S3 before Hon. David 1.
10
Brown, did not say a word about what was said during the oral arguments and what Judge David 1.
11
Brown told Porter Scott's attomey Daniel Bardzell who is pretending or claiming, along with another
12
13 attorneys uf Purler Scull's, thai lliey rcprcscnl ihe furmer Defendanls and ur empluyccs uflhc
14 University of Califomia Davis Medical Center, Mike Boyd, Stephen Chilcott, Danesha Nichols,
15 Cindy Oropeza, and Brent Seifert.
16
THIRD: The Plainliff is filing this NOTICE OF OBJECTION TO THE COURT ORDER
17
DATED DECEMBER 17, 2019 AND PLAINTIFF REQUEST FOR COURT ORDER
18
19 MODIFICATION instead of the Motion for Reconsideration pursuant to the Code of Civil Procedure
20 § 1008 because it would be futile for the Plaintiff to file Motion for Reconsideration only to find out
21 that the Motion was denied and the Plaintiff was denied a hearing by the Court as it happened in 2018
22
in this matter.
23
More specifically, on June iS, 2018, the Plaintifffileda MOTION FOR RECONSIDERA TION
24
OF ORDER FOR GRANTING LEGAL FEES AND COST PURSUANT TO C.C.P. 425.16 (C) with
2S
Court Hearing scheduled on July 19,2018, in Department 53 before Hon. David 1. Brown (ROA 137
26
& 138).
2/
28
- 2 -
NOTICE OF OBJECTION AND REQUEST FOR COURT ORDER MODIFICATION
1 TheCourt on June 29,2018,.ten days before the scheduled Court Hearing on Plaintiffs Motion
2 for Reconsideration and'three days before Defendants' attorneys filed their Opposition on July 3,
3
2'018,to PlaintifTs Motion for Redpnsidei^tipn (ROA # 145); the-Gpurt signed the JUDGMENT
4 •
PURSUANT Tp ORDER G.RA MOTION FOR FEES. AND COSTS PURSUANT TO C.C.P
5
§-/25;/<J (C) and OtlDERiGRANTrNG DEFENDANTS' M O T I O N FOR FEES A N D COSTS
6
7 PURSUANT TO G.C.P.^fS: 425;l6(c) (ROA # 143,144,146)! Thereafter, die Court denied Plaintiffs
8 Motion, for Reconsideration by a Tentative Ruling pn July 18, 2018 and denied Plaintiff a Hearing on
9,
July 19, 2018.
10
<
. •.' .
11
12
13
14
15 ^ THE G O U R T HEAlbNG .ON. p PM AT DEPARTMENT S3

BEFORE JUDiSE DAiyiDl. TO
16
After: reading the Cpurt Tentative Ruling dn December 12,2019^ Plaintiff noticed that the Tentative
17
ruling is merely redacted 'of the Cburt ruling dated July 19.2019; emd does correspond with the
18
information Plaintiff provided in his December 4, 201 S>, Opposition to FURTHER MOTION TO
19 COMPEL RESPONSES ;rO JUDGMENT DEBTOR INTERROGATORIES AND REQUEST FOR
20 PRODUCTION OF DOCUMENTSAND MONETARY SANCTIONS. Plaintiff then decided to
21 request a Court hearing for the next day December 13.2019. by 2:00 at Dept. 53 before Hon. David I.
22 Brown.
23 During the Court-Hearing, Plaintiff ba.<;ically prnvided the .same information he provided in
24 his opposition to the Defendants* motion (ROA # 235) along vvith sonie additional information that
2!S
was completely disregarded by the Coiirt Order dated December 17,2019 (ROA # 240-243).
26
During'the Oral Argument on;December 13, 2019, Plaintiff infohTi'ed the Court that since the July 19,
ZI
2019 CourtprdiBr;(ROA # 219) P^ following action after the Court mandated Plaintiff
28
to pay $ 1300'in .sanctions and to serve further verified responses to the Judgment Debtor
Interrogatories and Judgment Debtor Requests for Production, without objections, on or before July
29, 2019. The Court.cautioned Judgrnent Debtor/Plaintiff that compliancc with Coiirt Order is
mandatory.
- 3 - .
NOTICE OF OBiiEGtlON AND REQUEST FOR COURT ORDER MODIFICATION
1 1. Plaintiff, during the December 13, 2019, Court Hearing, informed the Court again that
2 he had no access to his wife's personal bank account or her 401 k and that he cannot provide any
information to Porter Scott's attomeys about his wife's accounts. Furthermore, Plaintiff provided
3
information to the Court that confronted his wife about herfinancesand confronted her employer of
4
30 years, the Nordstrom Incorporation located in Sacramento Arden Mall.
5
In response to PlaintiflTs statement about his wife, the Judge presiding over the Court Hearing, Hon.
6
David I. Brown, turned to attomey Daniel Bardzell who was pretending to represent five former
7 Defendants, employees ofthe University ofCalifomia, and told Bardzell to subpoena Plaintiffs
8 wife's record from Nordstrom. Daniel Bardzell did not like Judge Brown's advice and his response
9 was not clear as to whether he would subpoena Plaintiffs wife's record from Nordstrom or from the
10 Bank.
11 The Court Order dated December 19,2019, did not say a word about the above discussion
between Plaintiffs and the Court and between the Court and UC Regents's attomey Daniel Bardzell.
12
Plaintiff determined from the ongoing situation in the Court and from the meet and confer
13
correspondence with Porters Scott's attorneys , who are using Plaintiffs wife as a blackmail and
14
extortion tool, knows more about Plaintiffs wife's employment in Nordstrom and herfinancesthan
15
Plaintiff himself. Nordstrom Store has existed in Sacramento Arden Mall for 30 years and is the
16 subject of litigations in the.Sacramento Superior Court. Since many attorneys know each other and
17 knowing how Porter Scott's attomeys operate, Plaintiffhas little doubt that Porter Scott's attomeys
18 have all information about Plaintiffs wife, and they are ruthlessly harassing and blackmailing
19 Plaintiff with the Court looking on.
20 The fear of the unknown and what further harm the Court together with Porter Scott's
attorney representing the Regents of University of Califomia will do to Plaintiff caused Plainliff lo
21
land in the Lodi Memorial Hospital's ER on September 30, 2018, at 12:30 AM with his blood
22
pressure around 200/105, pain in the chest, and an enormous headache on the left side of his head.
23
(Af\er several hours, the ER staff stabilized Plaintiffs blood pressure and pain with the diagnosis that
24
he did not have a heart attack or stroke. After Plaintiff was released from the ER, his wife stayed with
25 him in the hospital until he was released at 05:43 AM.)
26
27 In fear ofthe unknown and what further harm the Court together with Porter Scott's attorney
28 representing the Regents of University of California would do to Plaintiff, Plaintiff was left with no
- 4 -
1 choice than to confront his wife about herfinances,and on October 11, 2019, and to confront her
2 employer of 30 years, the Nordstrom Incorporation, with a 16-page inquiry regarding his wife's
unusual friendship with her female coworker, a former military operative in the Soviet Union's
3
largest military base in Poland during the Soviet Union's domination of Plaintiff s native country
4
Poland.
5
Shortly after Plaintiff confronted his wife's employer Nordstrom Inc., Porter Scott's attorneys
6
representing UC Regents filed, on October 23, 2019, another FURTHER MOTION TO COMPEL
7 RESPONSES TO JUDGMENT DEBTOR INTERROGATORIES AND REQUEST FOR
8 PRODUCTION OF DOCUMENTS AND MONETARY SANCTIONS totaling 233 pages (ROA #
9 222-226). Plaintiff noticed that Porter Scott's attomey David Burkett's who was leading the case
10 since January 23, 2015, not listed as an attomey in the filed motion and he is no longer employee of
11
Porter Scott's lawfirm. In 2011 and 2012 David Burkett together with his friend , participated in
the operation with his friend Cori A. Dutra, Staff Attorney from California Social Services to
12
frame and hurt Plaintiff's Psychologist from Lodi Dr .Franklin O. Bernhoft and his family .
13
See: PLANTIFF' DISAPPROVAL OF THE PROPOSAL ORDER AND JUDGMENT GRANTING
14
LEGAL FEES AND COST TO DEFENDANTS IN ANTI-SLAPP MOTION
15 C.C.P 425.16 (C) Page No. 6-87(ROA # 148)
16 Also. David Burkett attempted on provoke Plaintiff into a physical confrontation in the Court of
17 Appeal, Third Appellate building just after a scheduled Oral Argument that took place on August 28,
18 2017 at 9:30a.m.. See : PLAINTIFF'S OBJECTION TO THE DEFENDANTS' SUPPLEMENTAL
19
DECLARATION OF DAVID P E. BURKETT IN SUPPORT OF DEFENDANTS' PREVIOUSLY
FILED MOTION FOR FF.F.S'.AND COSTS PI )RSl I ANT TO C.C.P § 425.16(C) filed on May 18,
20
2018 Page #3-4. (ROA # 132)
21
22 2. Plaintiff on December 13, 2019 Court Hearing informed the Court lhat since the
23 previous Court Hearing on July 19, 2019 (before Hon. David I. Brown), on October 31, 2019,
24
Plaintiff sent Defendants' attomey a check in the amount of $ 520 to resolve the sanctions
awarded to UC Regents by a Court Order dated October 31, 2018, and repeated by a Court
?S
Order dated November 14, 2018, so that the Plaintiff could remove UC Regents from Porter
26
Scott's attomey's fraudulent anti-SLAPP motion and to resolve the issue of these unwarranted
27
sanctions. The Regents cashed the $ 520 sanction check on November 20, 2019.
28
- 5 -
1 The Court Order dated December 19,2019, did not mention in one-word Plaintiffs
2 information about the S 520.00 check cashed by UC Regents. This information was provided to the
3
Court on December 4, 2019 by the Plaintiffs opposition to the Defendants' Motion to Compel was
also filed on this date.
4
5
3. Plaintiff, during the December 13, 2019 Court Hearing, also informed the Court that
6
on October 31, 2019, Plaintiff sent another $ 520 to Porter Scott's paralegal employee Mari lyn
7
Camper who was awarded $ 520 by the Court Order dated June 7, 2018 (ROA # 136) and that Porter
8 Scott prohibited Marilyn Gamper from cashing the check awarded her by the Court. However, the
9 uncashed check was not retumed to Plaintiff. This information was provided to the Court on
10 December 4, 2019. The Plaintiffs opposition to the Defendants' Motion lo Compel was also filed on
11 this date. The Court Order dated December 19, 2019, did not mention a word of Plaintiffs account of
the $ 520.00 sent to Porter Scott's paralegal employee Marylin Gamper.
12
13 4. On November 19, 2019, the Court signed Order (ROA #230) (Hon. David I . Brown)
14 which "ORDERED that the Judgment Creditors' Motion for Monetary Sanctions is GRANTED"
However, UC Regents are not the Judgment Creditor in the anti-SLAPP motion, and Porter
15
Scott's attomey Daniel Bardzell and others, by using UC Regent in lieu of Danesha Nichols, Brenl
16
Seifert, Mike Boyd, Ctndi Oropeza, and Stephen Chilcott, are committing a crime by attempting to
17
extort money from Plaintiff for themselves, which per the Court Order dated June 7, 2018 (ROA
18
#136) legally belongs to three former attomeys of Porter Scott, Michael Pott in the amount of $
19 $6,500, Douglas Ropel in the amount of $13,400, and David Burkett in the amount of $312. Porter
ZQ Scott's present employee Marilyn Gamper is entitled to $ 520.
21 The Defendants, Judgment Creditors, the University of Califomia Davis Medical Center, the
22 present and former employees in the anti-SLAPP motion, Danesha Nichols, Brent Seifert, Mike
23 Boyd, Cindi Oropeza. Stephen Chilcott's per Court Order dated June 7,2018 are entitle s $ 166.20.
See also the DEFENDANTS' MEMORANDUM OF POfNTS AND AUTHORITIES IN SUPPORT
24
OF MOTION FOR FEES AND COSTS PURSUANT TO C.C.P. §425.16(c) filed on May 11, 2015,
25
Page No. 8, 16-27 (ROA #86).
26
27 Also, the Court Order dated June 7, 2018, stated that the Court "will award Defendants an
28 additional 3 hours al $260/hr for work associated with the reply for a total of $780" without specifying
- 6 -
1 what future reply the Court had in mind.
2
3
5. Plaintiff during the December 13, 2019 Court Hearing also informed the Court lhat
Plaintiff sent to Porter Scott the check for the $ 1300 sanction awarded to Defendants by the Court
4
Order dated July 19, 2019. The $ 1300 check was issued to UC Regents.
5
Plaintiff became especially suspicious that something was wrong after Porter Scott's attomey,
6
Daniel Bardzell, sent a letter to Plaintiff on November 15, 2019, and demanded in a bold font that
7
Plaintiffs sanctions and anti-SLAPP fees be paid to the Regents of the University of Califomia. In
8 response. Plaintiff advised Daniel Bardzell that, per Court Orders dated April 26, 2019 (ROA #
9 2011) and July 19, 2019 (ROA #2019), the Regents ofthe University of California are not party to
10 the ant-SLAPP motion and cannot cash the checks.
11 Furthermore, on November 21, 2019, Plaintiff wrote to Daniel Bard7ell on this matter as
follows.
12
13 Dear Mr. Bardzell,
14 Please advise me if you want me lo re-issue the $1,300 sanction check to five
former individual Defendants—Danesha Nichols, Stephen Chilcott, Brent Seifert,
15 Mike Boyd, and Cindi Oropeza—instead of the University of California Regents.
As I advised you a few days ago, the UC Regents should not cash ihe $1,300 check
16
I sent to your office on November 18, 2019. The UC Regents are not the party of
17 the anti-SLAPP motion filed by Porter Scott's former attorney Michael Pott on
December I, 2014.
18
I could write the checks to each forhter Defendant in the amount of $260 and send
19
them to your office if you represent them as you claimed that you do. But are you
20 sure that Danesha Nichols, Stephen Chilcott, Brent Seifert, Mike Boyd, and Cindi
Oropeza are the former Defendants? It would be better if you ask Judge Brown if
21 they are the former Defendants before you show up on December 13, 2019 Court
hearing to argue whether Danesha Nichols, Stephen Chilcott, Brent Seifert, Mike
22 Boyd, and Cindi Oropeza were dismissed from the lawsuit by the Court or by
23
myself.
24
Defendants' attorney, Daniel Bardzell, did not respond to Plaintiffs November 21,2019,
Meet and Confer Correspondence.
25
The Court during the December 13, 2019 hearing told Defendant's attomey Daniel Bardzell
26
to retum the $ 1300 check issued for UC Regents, but the Court did not clarify to whom Plaintiff
27
should re-issue the check but imposed on Plaintiff another $ 1300, disregarding Plaintiffs statement
28
that Defendants' attorney Bardzell and others using were Plaintiffs wife as a bait and extortion tool
- 7 -
1 in an anti-SLAPP motion to extort money (legal fees) that were not awarded to them and do not
2 belong to them.
3
The Court Order dated December 19, 2019, did not mention a word about Plaintiffs account
about ofthe $ 1300 sanction check Plaintiff sent to Porter Scott's attomey Daniel Bardzell in
4
November 2019 and did not clarify who got the sanction money, leaving Plaintiff in limbo. Thus, the
5
December 17, 2019, Court Order shall be modified, and the Court should clarify whether the
6
pleadings last filed by Porter Scott's attorneys Daniel Bardzell, Nancy Sheehan, Derek Haynes and
7 Amanda Her represent Defendants in the anti-SLAPP motion, Danesha Nichols, Stephen Chilcott,
8 Brent Seifer, Mike Boyd and Cindi Oropeza or whether they only represent the Regents of the
9 University of Califomia and they are pretending to represent the five individuals listed above in an
10 attempt to extort money to which they are not entitled from Plaintiff. Plaintiff will not hesitate to ask
31
ihe District Attomey and the State Bar of Califomia lo investigate what Porter Scott's attorneys have
been up to in Court.
12
III.
13
"ATTORNEYS FOR JUDGMENT CREDITORS/FORMER DEFENDANTS"
14 MICHAEL BOYD, STEPHEN CHILCOTT, DANESHA NICHOLS, CINDY
OROPEZA, AND BRENT SEIFERT"
15
16 In the FURTHER MOTION TO COMPEL RESPONSES TO JUDGMENT DEBTOR

17 INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS AND
1R MONETARY SANCTIONS (ROA # 222-226) filed on October 23. 2019. Defendants' allomey from
19 Porter Scott's law firm, Nancy Sheehan and Daniel Bardzell, emphasized on the front and last pages
Zi)
of the pleading, except for the last page of Daniel Bardzell's Declaration in Support ofthe Motion,
that Ihey are "ATTORNEYS FOR JUDGMENT CREDITORS/FORMER DEFENDNATS." What
21
caught Plaintiffs attention the most was the fact that Daniel Rardzell and Nancy .Sheehan are
22
attorneys for former DEFENDANTS. Plaintiff never saw such statements on Porter Scott's attorney's
23
pleadings, which made Plaintiff suspicious that Defendants Michael Boyd, Stephen Chilcott, Danesha
24
Nichols, Cindy Oropeza and Brent Seifert were only automatically dismissed from Plaintiffs Second
25 Amended Complaint (SAC) in relation to the first Four Causes of Action (COA's).
26 Plaintiff became suspicious about Porter Scott's attomey's other Motions after Porter Scott's
27 leading attorney in the case and shareholder David Burkett became a former employee of Porter
Scott's Professional Law Corporation's and was replaced by two of Porter Scott's other shareholders
28
)
- 8 -
1 in the case, Nancy Sheehan and Derek Haynes, who was added to the.case on November 12,2019
2 (ROA#2!28) •
3
PIaintiff,lile<:aiiirii.e^^^^ suspicibiis'that something was wrong after Porter Scott's attomey,
DanieJ ,Bar(JzeIl;;sent a letter to Plaintiff on November 15, 2010, and defnahded in a bold font that
4
Plaintiffs: sanctions and anti-SLAPP fees be paid.to the Regents'of theUniversity of California.
5
ThereaftiB^ Plaintiff examined Porter Scott's attorney'sfiledpleadings tofindout whether
6
Porter.ScQtt's^ttdmeys.p^ inade any references in their pleadings stating that they are
.7
I
"ATTORNEY^ for F ^ if they announced on thefirstand last pages of
•8' the:abo.vemen'tiohed pleading docuhientsfiledin the Court on October 23, 2019.
On palge No. 2 (lV25) in Defehdahts' MEMORANDUM OF POfNTS AND AUTHORITIES
ib IN SUPPORT OF JUDGMENT CREDitORS' FURTHER MOTION TO COMPEL RESPONSES
11 •. TO JUDGiy^T DEBTOR iN REQUEST FOR PRODUCTION OF
DQcUMENiiS AND:Mp Defendants' attomey wrote as follows in relation
12
to the former Defendants .iiROA #223).
13'
14 On ApniX4,,2pi$, thejCourf^ an Order granting the Special Motion to Strike

finding that Judgment-Debtor/Plaind to establish a'probability of prevailing
15 oii the:cai!ises of action'ple^^^ required by section
425.1*6 ahi^^nfei'lhgjudgtTieht'in^^ Creditors. (Id. al 13 and
16 Exhibit A.)J.iid'gment.p.e^^^ a;request for dismissal
17 with prejudice.(sf the^jfour rerhaihing individual Defendiants'RICE, WITCHER,
PUTNEY. anifeNiLIUC. (Jd.' at 14 and,Exhibit B.) flie UNIVERSITY is the
18 only Defendant remaining in the^caise.
19 Plaintiff read the April 14, 2015, Court Order written by Defendants (i.e., the attorney David
20 Durkctt or Douglas Ropel) (ROA;# 80'^81), which was signed by | Ion. David Drown, and found that
21
the April 14,2015, Court prd^r djd ript srtate that the Defendants "MICHAEL BOYD, STEPHEN
CHILCOTT, DANESHA NICHOLS, CINDY OROPEZA, ANEi BRENT SEIFERT' were dismissed
22
from the Second Amended Cornplaint. The Court Order-dated April 14,2015, slates as follows.
23
24 IT IS tHER£F0I^:.Q6a)£REp that the Special MotiontoStrike the four causes

of actipn eniimwated,al>dve.,<as pleiide.d against Defend Plaintiffs Second
25 Amended Complaint, is hereby G R A N T E b ; Page T^p.' (26-^28)
26
IT IS:Fi;R;rHE;R ORDERED that Judgment be, and hereby is, entered in favor of
2/ Defendants'MIKE BOYDI iite^^^^ NICHOLS,
C I N D Y OROPEZA; and BRENT SEIFERT, and agiihst Plaintiff JAROSLAW
28
- 9 -
1 WASZCZUK forthe four causes of action asserted against them in the Second
Arifiehdey Complaiint. Page No.9 (1-4)
2
3 ITÎS FURTHER .GRDERE^^ their Costs and the

:. attorriey?s'.fees. incurred in cbhjijnctipri With the Speciaj'Motion to Strike pursuant
4 fo'Codeipf.Civil;Procjedure se^^ 4iz5.l6; subdivisiofi (C;)(l). Uet(sndants shall tile
a separate motion to detemiihe the anioiiht tb .b^ awarded; Page No. 9 (5-10)
5
6 IT lis SO ORDERED.
7
• ' During'the Cdurt Hearing on February 6, 2015, Plaintiff asked the Court to
•...8.
. dismiss-all;individual defehdiants from the lawsuit, and then the Court responded as
9.
follpWs (GOurt^kepd'm 19-28).
10 \. THE iC^ can't doTthat. With respect to you,:Mr. Waszczuk, maybe you
.' could hdye' wplrked someth^ out w|th'defe'nse'-before this, but there is case law
11
spixif1ci%'o
12 / AlI rightl^Here. is what I'm going to do,;.Mr; Waszczuk, I'm goingtotake the matter
:. - iinder submission and let you kn6^y.. If you want to work something out with Mr.
13 Roperand his fimn, that.iis fine, arid then we can proce^d as to the Regents as to Ihc
. rernainder/
14
15
The Court did not cite case law which specifically applies to dismissing. Defendants from the lawsuit.
16 la September 2015, Pjaihtiff intendedtofilea Third Amended Complaint (TAC) with

17 basically one Cause of Actiori-that would serve as Breech of Written Contract or Violation of the
18
January !2009 Sehlement'Agreem^ only the Regents ofthe University ofCalifomia as
Defendants. The T A C would take care of the Defehdahts Michael Boyd, Stephen Chilcott, Danesha
19
Nichols, Cindy Oropeza; arid Brent.'S'eifertj>and tiiey would :be dismissed.
20
However, in Septiernberi Defendants' attbrneysiDavid Biirkett and Douglas Ropel blocked
21
Plaintiffs effort tofileTAC by their Motion-for Automatic Stay or, in the altemative. Motion for a
22
Discretionary Stayfiledin September^ 2015 (ROA'#104). The Motion for Automatic Stay or, in the
23 Alternative, Motion for a Discretionary Stay .was granted to Defendants by the Court on October 28,
24 2015, and it raised the cjuestioh of whether Michael Boyd, .Stephen Chilcott, Danesha Nichols, Cindy
?.S Oropeza, and Brent Seifert were.dismissed from the lawsuit entirely in 2015 or are still attached to
26 the remaining Four Causes of Actibn, especial ly.tb the Sixth Cause of Action "Breach of Written
11
Contract."
28
- 10 -
NOTICE OF OBJECTlbN AND REQUEST FOR COURT ORDER MODIFICATION
1 If Michael Boydi Stephen Chilcott, Danesha Nichols, Cindy Oropeza, and Brent Seifert were
2 idisrnissed fr.om the lawsuit entirely iri 2015 by the April 14, 2015, Court Order, then they cannot
3
resurfafce as FORMERiDEFENbANTS demanding money from ^Plaintiff under the Regents of the
.University of Califomia:riame.-Thatis,a great fraud going on since October 2018.
4
For the.Cburt'siinfbriTiatiori-, Michael Boyd retired from the university system in 2015 and
5
Cindi Oropeza in 20I6/and;b!bth h£iveribthirigmore to do with the University of Califomia, UC
6
Regents, or Plairitiff. if they Porter Scott's Daniel Bardzell or Amarida Iler claims them as a former
' 7
attonieys. • .
8 IV.
9 DECLARATION okAMANoX-LjlLER IN SUPPORT OE:REPLY TO OPPOSTTION TO
MO-tlON TO .CQMPyEL RESPONSES T dtlDGMENT DEOT INTERROGATORIES
10 \/iND REQUfest FO^^^ FOR MbNETARY
11 SANCTibNiS
12
Porter Scott's new Attorney in this proceeding, . Amanda Iler, in her December 6, 2019
13
bECLARATlON OF AMANDA L. ILER IN SUPPORT. OF REPLY TO OPPOSITION TO
14
MOTION TO COMPEL RESPONSES TO JUDGMENT DEBTOR. INTERROGATORFES AND
15
REQUEST FOR , PRODUCTION OF DOCUMENTS;. AND FOR MONETARY
16
SANCTIONS,(ROA# 237) iinplying'that Amanda Iler represents FORMER DEFENDANTS Michael
17
Boyd, Stephen Chikott, DaneshaNichbls,-Cindy Oropeza, and:Brent Seifert, on Page Nos. 2 § 6 under
18
the penalty of perjury declared as follows.
19
"Although Judgment^Debtor insinuates that the REGENTS js not entided to ihe
20 ' sanction payments prgîously'awarded.and that'lhe are the
21 proper recijiients, the REGENTS haSpaid for the defense ofthe Judgment
Creditors. TKe;REGENTS;.has incurred the ex Sp'eciial Motion to Strike
22 and subsequent discoyery proceedings associated w\th colleiiting'the judgment;"
23 Amanda Iler's above statement that "the REGENTS.has incurred the expense of the Special
24 Motion to Strike an'd ûbseqiient discoVery proceedings associated with collecting the judgment." is
25 untrue and deceptive . ..'
First, Amanda ilei* did not provide any proof to the Court.to back up her statement that Regent
26
incurred the expenses ofthe Special Molion to Strike and isiibsequierit discovery proceedings
27
associated with col lecting the judgment.
28
NOTICE OF OBJECTifON AND REQUEST FOR COURT ORDER MODIFICATION

1 Second, a Special Motion to Strike was approved in 2014 and paid by the Sedgwick Claims
2 Management Services, Inc. and not UC Regent. Porter Scott's former attorney Douglas Ropel
claimed a lol of hours in his legal fees dealing directly with Sedgwick Claims Management Services,
3
Inc. in 2014 and 2015 to get approval by the Sedgwick Claims Management Services, Inc. See:
4
Exhibit "F" in the DECLARATION OF DOUGLAS L. ROPEL IN SUPPORT OF MOTION FOR
5
FEES AND COSTS PURSUANT TO C.C.P. § 425.16(c) filed on May 11, 2015 (ROA # 86).
6
Most likely than not. Porter Scott's former attorneys Douglas Ropel, Michael Poll, and David
7 Burkett were paid their legal fees for the anti-SLAPP motion filed by Sedgwick Claims Management
8 Services, Inc. Last year Plaintiff pointed out to the Court that Douglas Ropel and Michael Pott should
9 provide a Declaration to the Court that they are being represented by David Burkett to recover their
10 legal fees.
11
Amanda Her was employed by Porter Scott from December 2014 to May 2018; thus she
worked with Douglas Ropel in Porter Scott's law firm from December 2014 to March 2016 until
12
Doulas Ropel quit and was hired by Littler Professional Law Corporation in Sacramento Office,
13
From May 2018 to November 2019, Amanda Her was employed by Littler Professional Law
14
Corporation in its Sacramento office and worked again with Douglas Ropel for this period, and il
15 appears that she came back in November 2019 to Porter Scott and resurfaced in the Plaintiffs case
16 with her lies in a Declaration she signed under the penalty of perjury. Amanda Iler was perfectly
17 aware of who paid for the anti-SLAPP motion, but she decided to deceive the Court by her lies in her
18 Declaration.
19 Amanda Iler needs some advice'from the Court and the State Bar of California not to lie under
20
the penalty of perjury in Declarations.
21
22
ARGUMENT
23
24
Porter Scott's attomeys representing the Regents of the University of California using
25 Plaintiff's wife as bait and black mail tool to intimidate Plaintiff to extort money from Plaintiff
26 committing a crime and engaging themselves in a serious invasion of privacy and breaching the
27 social norms underlying the right to privacy (See Hill. v. National Collegiate .Athletic .4ssn. (1994) 7
28 Cal.4ih 1,37).
- 12 -
1
2 Under the Califomia Constitution, there is a right to privacy (See Cal. Const, art. 1, § 1). The
right to privacy, protected by the California Constitution, Articie 1, Section 1, is a ftindamental
3
liberty interest and extends to details of one's personal life (City of Santa Barbara v. Adamson (1980)
4
27 Cal.2d 123, 130; Valley Banic of Nevada v. Superior Court (1985) 15 Cal.3d 652, 656).
5
Accordingly, it is well-established in Califomia that, where privacy rights are involved, the party
e seeking discovery must show far more lhan mere legal relevance or likelihood to lead to admissible
7 evidence. The propounding party must establish that the information sought is nol only "directly
8 relevant" to the parties' claims but also "essential" to a fair resolution of the lawsuit (See, e.g., Alcii v.
9 Superior Coun (2008) 165 Cal.App.4th 1412, 1432-1433). Additionally, to pass constitutional
10 scmtiny, any discovery into matters deemed private must be "narrowly tailored" to obtain only the
"essential" information and the party seeking discovery must show there is no less intrusive means to
11
obtain this information (See, e.g., Tien v. Superior Court (2006) 139 Cal.App.4th 528, 539540; In re
12
Marriage of Harris (2004) 34 Cal.4th 210, 244). Even where these prerequisites are met, there is still
13
no categorical right to conduct discovery on private matters, as the trial court is still required to
14
carefully balance the rights and interests involved before permitting the proposed invasion of privacy.
15 (See, e.g., Alch, 165 Cal.App.4th at 1423-1425.) When privacy rights are involved, the protected
16 information should not be produced unless therequestingparty "can show a compelling need for the
17 particular documents and that the information cannot reasonably be obtained through depositions or
18 from nonconfidential sources" (San Diego Trolley, Inc v. Superior Court (2001) 87 Cal.App.4th
1083, 1097-1098).
19
20
Porter's attorneys' attempt to break into Plaintiffs wife 401k account and her bank account by
21
blackmailing Plaintiff .s wife and Plaintiff i.<; nn different fmm in 2014 when they blackmailed
22
Plaintiffs attomey Douglas Stein who stmggled to survive by becoming addicted to dmgs. Porter
23
Scott's attomey completely destroyed Stein's life by forcing him to collaborate with them against
24 Plaintiff.
25 http://nieinher«;.calhar ca.g0v/fal/Licen5ee/Detail/l 31248
26 In Flatley v. Mauro 39 Cal.4lh 299 (Cal. 2006), cited 799 times the Califomia Supreme Court,
described the crime of extortion as follows. "Extortion is the obtaining of property from another, with
27
28
- 13 -
. 1 his consent... indiiiced by a wrorigful use of force or fear..." (Pen. Code, § 518). That is exactly what
2 Plaintifffhas bee.n.deailjng with since December 2016.
3
. ' VI. .
4
CONCLUSION
5
6 , Given the facts-presented above and in the light of Oral Argument made during the December
.7 13, 2019 Cburt Hearingi Plaintiff is'urging; the Court to modify the Court Order by voiding the
8'.-
sanctiori'.imposed oh ^^^^^^^^ the Court Orders dated Jiily 19,2019, and December J 7,2019, and
tb'prphibit.Pbrter S.c'btys:attonieys Daniel^ Amanda Iler, Derek Haynes, and Nancy Sheehan
9
from u.siri'g PlairitifTs.'spo'use.as a bait and 'tpol of blackmail to eXtort money from Plaintiff under
10
false pretenses.
11
12 Plaintiff alsorespectfullyurges the Cbiirt to bring this case^' which has been pending for five
13 and a half years, to a trial ; br niandatbry settlement.
14
I declare under.thepehalty of perjury under the laws of the State ofCalifomia that the
15
foregoing is .true and Cbrrect; '
16
17 Executed on Decernber •26,!2019; Lodi, CA.

18
19
20
21
22
Jaroslaw Waszczuk
Plaintiff in Pro Per
23
24
25
•26
27
28
14
1
2
TABLE OFCONTENTS
3
L INTRODUCTION. .1
4
Hi , THE:CpURT HEAWNG,ON DECEMBER 13,20li) AT 2:Q0 PM AT DEPARTMENT
5.
^3:BEF0ld: JUDGE D A V I D L B R O W 3
6^
III. . , AlT.0RNEyS FOR JrUDGMENT C i ^
7 , • MlGHiiiEL BOVD/'STEPHENiCH DANESHX NICHOLS, CINDY
\ • . ' -i" .;• • • _^ • ' :• \ •' t' . " ^ f *^ \ • • -
.'8
9 TV;;a.DECLARATION OF AMANDA L;:IL REPLY TO OPPOSIIION

T 6 M O T I O N ^ T O CplV^^^ DEBTOR
•10 iNTERROGATOEUES AND'M OF DOCUMENTS AND
' T FORMONETARY^V^NG^^ 11
11
12
V. . AR^GyMENT...... , 12
13 VI. CONCLUSllON 14
14 • VIL TABLE OF AUTHORITIES.....vi 16
15
16 VIH. EXHIBITS 17
17
IX. PROOF O F SERVICE BY US M A I L ..1 18
18
19
20
21
22
23
24
25
26
27
28
IS -
1
2
TABLE OF AUTHORITIES
3 I
4 Caês:
•5 I. .Hjil. y. Haiiong^^^^ (,1994)7 Car.4th 1,37) 13

• 2. CityofSpntaBai^Baray::A^ 12'3, 130; Valley jBank of Nevada v.
6
.Superioir[Court(\'^Z5] 15 Cai:3d.652,656).!; 13
.7
3. Alchv. Superior Court (20^^^^ 165 Gai;App.4th 1412, 1432-143. 13
8'
4. -Tieh v. '-Stiperiqr CiWff* (2006) 13'? Cal.App:4tli 528,539540 13
9. * . 5. ' Marriage pf Harris (26o4) 34 Cal;4th 210, 244 13
ao , • .6.. Alch y. Superior CoiuX (2008) 165 Cal.App.4* at 1.423-1425. .. 13
11 7. Sqrt Diego troile^^^^ 1083, 1097-1098) 13
. 8: Fldtley y. Mauro 39 CaUth 299 (Cal. ,2006 14
13
'Statiites:
15 1. ;:Califbmia Cbnstitutiohi Article 1, Section 1 13
16
2. CalifpimiaPehal Code § 518 14
e
'17
18
19
20
21
22
23
24
25
26
27
28
16 -
1 EXHIBITS
2 1. The Court'Orders dated December 13.2019 and December 17,2019 . Hon. David Brown
Re:'M0tibn'4b.Compel :
3
4
5
6'
7.
9'
10
11
12
13
14
15
16-
17
18
19
20
21
22
23
24
25
26
27
28
17 -
PROOF OF S E R V I C E BY US MAIL
2
Re: Jaroslaw Waszczuk v. The Regents of the University of Califomia
3
Case No.: 34-2013-00155479
4
5 I, IRENA WASZCZUK the undersigned, declare that 1 am over 18 years of age and not a party to the
within cause; my address is 2216 Katzakian Way, Lodi, CA. On December 26,2019 I served a true
6 copy of the attached each of the following.
By placing the same copy in an envelope or envelopes addressed respectively as follows:
7
PLAINTIFF JAROSLAW WASZCZUK'S NOTICE OF OBJECTION TO T H E COURT
8 ORDER DATED DECEMBER 13 & 17, 2019, AND PLAINTIFF'S REQUEST FOR COURT
ORDER MODIFICATION - RE: OPPOSTTION TO JUDGMENT CREDITORS' FURTHER
9 MOTION TO COMPEL RESPONSES TO JUDGMENT DEBTOR''S INTERROGATORIES
AND REQUEST FOR PRODUCTION OF DOCUMENTS AND MONETARY SANCTIONS
10
11
12 Daniel J. Bardzell ; . . .
PORTER/SCOTT LAW FIRM
13 350 University Avenue, Suite 200
14
15
Michael W. Pott
CSAC-EIA
16 75 Iron Point Circle, Suite 200
Folsom, CA 95630
17
18
Douglas L. Ropel
Littler Professional Law Corporation
19 500 Capitol Mall, Suite 2000
Sacramenlo, CA 95814
20
21
David Pontus Eugene Burkett
Knox Lemmon & Anapolsky Law Corporation
22 2339 Gold Meadow Way, Ste 205
Gold River, CA 95670-6307
23
24
Steve Chilcott
25 Executive Director, Workforce Strategies
HR Administration Building
26
University of Califomia, Davis
27 One Shields Avenue
Davis, CA 95616
28
- 18 -
1. bane'sha Nichols, Director
^.Harassme^ntvand Discrimination Assistance and Prevention Program
2..' UniyereiiÂofjGalifdm Davis
3 ^07 3Ki^sireet,.!SUite^2iQ
!pavis,'GA!956j6
4
Brent, Sêifert'-Assis^^ Personnel
.5 • U.ni'yersityôf.Ca^ , UC DSvis Medical Center
Schodl bf Mciilicihc ' '.
6
W O X S t r ^ Suited 3104,
7 Sacramerito,-eA'S''58n
• 9"';
I declare j^^^ penalty OfJperjuiy'.bf the jaVvs of the State of C.aliforriia that
io' the fbregbihg-'isUrue arid correct. Executed bn December 26j 2019 , at Lodi CA
11
12
•13 .
//
14 IRENA WASZCZUK
15
16
17
1B
19
20
21
22
23
24
2 .5 '
26
2/
28
- 19
.' I
/—
EXHIBH
SUPERIOR COURT OF CALIFORNIA,
COUNTY OF SACRAMENTO
GORDON D SCHABER COURTHOUSE
MINUTE ORDER
DATE: 12/13/2019 TIME: 02:00:00 PM DEPT: 53
JUDICIAL OFFICER PRESIDING: David Brown
CLERK: E.Brown
REPORTER/ERM:
BAILIFF/COURT ATTENDANT: R. Mays, Alvi, N.
CASE NO: 34-2013-00155479.CU-WT-GDSCASE INIT.DATE; 12/04/2013

C A S E T I T L E : W a e z c z u k v s . T h e R e g e n t s of the U n i v e r s i t y of C a l i f o r n i a
CASE CAI EGORY: Civil - Unlimited
EVENT TYPE: Motion to Compel - Other - Civil Law and Motion
APPEARANCES
Jaroslaw Waszczuk. self represented Plaintiff, present.
Daniel J. Bardzell, counsel present for judgment creditors
Nature of Proceeding: Motion to Compel Interrogatoriesand Production of Documents
TENTATIVE RULING
Judgment Creditors Boyd. Chilcott. Nichols. Oropeza. and Seifert (collectively. "Judgment Creditors")
move to compel further responses from Plaintiff/Judgment Debtor Jaroslaw (Jerry) Waszczuk to
requests for production, set one, and interrogatories, set one. Judgment Creditors also request
sanctions in the amount of $5,460. The motion is ruled upon as follows.
As outlined in the Court's prior order of July 19, 2019, on April 14, 2015, the Court granted Judgment
Creditors' special motion to strike Plaintiffs causes of action and entered judgment in favor of Judgment
Creditors. The Court subsequently granted Judgment Creditors' motion for attorneys' fees in the amount
Of $22,284. (See ROA 219.)
Judgment Creditors served the underlying discovery on October 9. 2018. The Court previously granted
motions to compel related to the discovery on April 26, 2018. and July 19, 2019. In both rulings,
Judgment Debtor was ordered to provide further verified responses, without objections. The July 19,
2019 order also imposed sanctions against Plaintiff/Judgment Debtor in the amount of $1.300.
Judgment Debtor/Plaintiff attempted to provide further responses by email on the Court deadline of July
29, 2019. (Bardzell Decl. U 22, Exh. P.) Counsel for Judgment Creditors sent correspondence on August
5, 2019, raising the issue of improper service and stating that the further responses "appearfed] identical
to the responses . . . previously provided with the only difference being that you executed a verification."
(Id. H 23. Exh. Q.) The parties continued to meet and confer. Judgment Debtor served verified responses
on September 6, 2019, which Judgment Creditor alleges again "appear identical to his previously
provided responses with the only difference being thai he provided a properly executed verification for
each response." (Mot. at 8. citing Bardzell Decl. H 26, Exh. T.) The parties continued to meet and confer
but no further responses have been received.
Judgment Creditors move to compel Judgment Debtor/Plaintiff to serve further Code-compliant verified
DATE: 12/13/2019 MINUTE ORDER Pagel

DEPT: 53 Calendar No
C A S E T I T L E : .Vyaszczuk v s . T h e R e g e n t s of the C A S E NO: 3 4 - 2 0 1 3 - 0 0 1 5 5 4 7 9 - C U - W T - O D S
• - .Uhiver3ity:Of G.<Q'lifpriila^ . ,
responses; wifhouit bbjec^^^
< ;Jodghfient Deb.tQr/Plaintiff s^ opposition to the motion but it largely does not address
. . i:v. the-releya does jhclude-.s iri >eleyaht part: "The Plaintiff has.no
': • • furth^r-ar^Cime'n^^^^ Plaintiff already provided to the Gourt in his. previous
. pppo6itib.n.^60 opp'ositi.on.'cspecially in the: Plairiti.ff's.Noveinber 18,
26;i9, resjpphse liile^^ 11/11/2019."
Judgment Creditors " &re entitled % th^ previously-ordered ftirther CodeTCompliant verified responses,
f withb.ut'objectibn.
Conclusion, '
• \ - Judgment bebtor/Plairitiff verified responses to the
> Ju.dgrnept, Debtor Interrogatories;'Set^6nei -a^^ ProdLiclion',-Set One, without objections, on
"or bfefpre December-2^^^
,The/GQui^ yet againic^^ with a facially-valid
couk.prder is nfiandatoiyK (Se^^^^^^ 19, 28-32; see also In re Berry
(1968)V;68:Cal.'2d f 3 7 , 1.47;) . "
Judgment Pebtpr/PiaihU^^^ to the moving parties in

•the amniihf pf.;$1r3^^^ rate'of'$260);. fo.rthe^^^ since the Court's last
drder^compelllog :furt.he
'^^^^^^^ to tHe saif»6 discbye^ry. The oppdsjtion w filed without
wit'—' substantial
- —
justification.- The^riiohetany Sanbiidrii are '.to' bis paid: on^'br biefore"-January 13i 2019. If those sanctions
are not piaid'by thjat dal'e^^ parties niay^prepare a fdrihrial.oi'cler on the sanction award, which
. may tn^re'îrt'er'ehterbd ai^s; a 'separate judgr1heritî[see^^w^ cotvrr p999) 40 cai.App.4tn
608.) •••
The minute order is° Effective Immediately. No formal order pursuant to C R C Rule 3.1312 or further
notice is required.
COURT RULING
The matter was argued and submitted.
The Court takes this matter under submission.
DATE: 12/13/2019 MINUTE ORDER : Page 2

DEPT: 53 Calendar No.
SUPERIOR COURT OF CALiFORNIA,
COUNTY OF 8ACRAMENTO
GORDON D SCHABER COURTHOUSE ,

MINUTE ORDER
DATE: 12/17/2019 TIME: 02:00:00 PM DEPT: 53
CLERK: E. Brown
REPORTER/ERM:
BAILIFF/COURT ATTENDANT:
CASE NO: 34-2013-00155479-CU-WT-GDSCASE INIT.DATE: 12/04/2013

C A S E T I T L E : W a s z c z u k v s . T h e R e g e n t s o f t h e U n i v e r s i t y of C a l i f o r n i a
C A S E C A T E G O R Y : Civil - U n l i m i t e d
APPEARANCES
Nature of Proceeding: Ruling on Submitted Matter (Motion to Compel Interrogatories and
Production of Documents) taken under submission on 12/13/2019
TENTATIVE RULING
Judgment Creditors Boyd. Chilcott. Nichols. Oropeza. and Seifert (collectively. "Judgment Creditors")
Creditors' special motion to strike Plaintiffs causes of action and entered judgment in favor of Judgment
Creditors. The C o u r t s u b s e q u e n t l y g r a n t e d J u d g m e n t Creditors' m o t i o n for a t t o r n e y s ' f e e s in the a m o u n t
Of $22,284. (See ROA 219.)
Judgment Creditors served the underlying discovery on October 9, 2018. The Court previously granted
motions to compel related to the discovery on April 26, 2018, and July 19, 2019. In both rulings.
2019 order also imposed sanctions against Plaintiff/Judgment Debtor in the amount of $1,300.
Judgment Debtor/Plaintiff attempted to provide further responses by email on the Court deadline of Juiy
29. 2019. (Bardzell Decl. ^ 22, Exh. P.) Counsel for Judgment Creditors sent correspondence on August
5, 2019, raising the issue of improper service and stating that the further responses "appear[ed] identical
[Id. U 23, Exh. Q.) The parties continued to meet and confer. Judgment Debtor served verified responses
provided responses with the only difference being thai he provided a properly executed verificalion for
each response." (Mot. at 8, citing Bardzell Decl. ^ 26, Exh. T.) The parties continued to meet and confer
DATE: 12/17/2019 MINUTE ORDER Pagel

DEPT: 53 Calendar No
C A S E T I T L E : W a s z c z u k v s . T h e R e g e n t s of the C A S E NO: 34-2013-00155479-CU-WT-QDS
University.of California.
responses;.witho.iit Objection subject discovery.
Jucigment Dielitpr/Plairitiff subriiltted a . late-filed .opposition to thie- motion but it:l^rgely does not address,
the; releyahtjissU^^^^ in the mptiph;.; jHe opposition dbes Miiclude.^îii. relevant p^ Plairitlff'^has ho
ftirther^ârgument'pl: 6^ the Plaintiff.al.ready 'prov^ C'ourt.-in his; previous
opposition .sand [sic]-iri: the ,exhibits!,att'a to this.oppb>itjon":espe&^^ Plaintiffs November 18,
2019, responê'Utled Re; Blackmail 'Sane'tionsW Porter Scott Attorney DanierSardzisll 11/11/i2bl9."
Jijidgmerit C.redit6i^r>are "entit^^ further Cbdeycompliaht verified responses,

withbut'pbjectipri.' .' ;, . ' '
.Conclusion '
f. Judghfieht Debtor/Ptaintif^^^ aijgaih ordered/tQ, sery^^ CodjS-compii^ht fUiiher verified responses to the
Judgment;Debtpr.vlritei;rogator|es;^^^^^ and Request for Productibhf Ser'O withbut objections, on
br>efore decenibei'23^ 201-9.
Thte Court'yet. a g a i n ' t h a t iicompllance with a facially-valid

co.urtô'rderjs mandatoryv: (Seer<f.gM^/n iê.'6 192 Cal. 19, 28-32; see also In re Berry
(1968) 68 C4l.2d ,137, :H.47^^^^ '
JDdgment.-^^btdr/Plalntiff isâlsb j^ the moving parties in

the ..amoufi't~V. $1,.30P ",(5 hours, at ..the; hobrl/ ra^^ of $260);Vifor |the. fe.es incurred since the Court's last
prd^r-c6mp6|iing furjther; resp.onses! tb the same discoyery-rjKe.'op^ was filed without substantial
jdstificatiOn. The .mpnetar^^ 13, 2019. If those sanctions
are hot'âid'by thatdate. tlje'mbving.parties.'may^ on the sanction award, which
may inerearter entered'ais a separate'judgmentr (see Arew/aho i/. superior court (1995) 40 cai.App.4tn
608.) ;•, • ' '
T h e minute , order is .effective imrhedlately. No formal'order pursuant to C R C Rule 3.1312 or further
notice is required.'
COURT RULING
The matter was argued and sut>mitted! The matter Was taken.uhde.r submission.
Having taken the matter under,subrriission on 12/13/2019, the Court now rules as follows:
SUBMITTED MATTER ROLllsiG

The Court affinned the tentatiyb ruling.
JAROSLAW .WASZCZUK
2216 KATZAklAKi WAY
LODI, CA 95242
DANliu J . BARDZELL
PORiTER.SCOt-t
350 UNIVERSlfV AVE:, SUITE 200
S A G R A A ! I E N T 6 , G A 95825
DATE: 12/17/2019 MINUTE ORDER ' Page 2

D E P T : 53 ) C a l e n d a r No.
ATTACHMENT # 8
4/25/2021 .- - Douglas Edward Stein #131248-Attomey Licensee Search-
© The State Bar of California
Douglas Edward Stein #131248

License Status: Disbarred
This licensee is prohibited from practicing law in California by order of the California Supreme Court.
Address: 4601 P St, Sacramento, CA 95819-4446

Phone:(916)745-5529 | Fax: Not Available '
Email: desquire1962@hotmail.com | Website; Not Available
More AboutThis Attorney •

Below you will find all changes of license status due to both non-disciplinary administrative matters and disciplinary
actions.
Date License Status Discipline Administrative Actibn
Present Disbarred
1/10/2020 Disbarred Disbarment 18-N-16452
Not Eligible To Practice Law in M-i^yico
8/15/2019 Ordered inactive 18-N-16452
California
Not Eligible To Practice Law in ^ . .. ,0 .co
2/7/2019 Ordered inactive 18-N-16452
California
Disciplinary charges filed in State Bar Court
12/20/2018
18-N-16452
Not Eligible To Practice Law in • i- / * 1 -,irîr,i-in
3/31/2018 California Discipline w/actual suspension 15-0-10110
Not Eligible Tc Practice Law in . r - j j r i j ^ n f
9/1/2017 Suspended, failed to pay Bar fees
California
Not Eligible To Practice Law in Admin Inactive/MCLE
9/1/2017
California Disciplinary charges filed in State Bar Court noncompliance
5/9/2017
15-0-10110
10/23/2014Active
Not Eligible To Practice Law in Suspended/Child & Fam Supp
9/24/2014 ,.
California noncompliance
4/3/2013 Active
Not Eligible To Practice Law in Suspended/Child & Fam Supp
2/27/2013 ,.
California noncompliance
12/11/1987Admitted to The State Bar of California
State Bar Court Cases

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be available using the State Bar Court Search for a Case feature.
Effective Date Case Number Description
2/7/2019 18-N-16452 Order re Entry of Default [PDF]
3/31/2018 15-0-10110 Stipulation [PDF]
Pending 18-0-16529 Initiating Document [PDF]
members.calbar.ca.gov/fal/Llcensee/Detail/131248 1/2
4/25/2021 Douglas Edward Stein # 131248 - Attomey Licensee Search
Additional Information:
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• Copies of official licensee discipline records are available upon request
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members.calbar.ca.gov/fal/Licensee/Detail/131248 2/2
RECtlVED
CIVIL DROP BOX
201BOCT2U PM 2:26
COUnTHOUSE-
SUPERIOR COURT
OF CALIFORNIA
SArnAMFWTo r.oi.'wrv
juroslaw "Jerry" Waszczuk, Plaintiff in Pro Per
2216 :Katzakian Way
Lodi,CA95242 |
Phone: 209-663-2977
Fax: 209-787-3.131 j ED
Email: iiwI980@live,cOm
APR 2 8 2021
April 27, 2021 E. Medina
. Deputy Clerk
Lindsay h: QQ\x\d\x\%, Attorney

Sacramento, C A 95825
I, . -
The Regents of the University of Caiifomia

ll'U Franklin St., 12th floor
Oakland, C A 94607
Subject: Case No. 34-2013-00155479, Jqroslaw Wgszczuk v. The Regents of the

University^df:California,Avvci}AaddenK^ Chilcott,
fChorleo WjitcHer, DoneaHa Nichols, Cindy Orop'ezdi Brent Seifert, Patrick
Putney, Dorih Dahiliuc
Re: Defendants-Ex Parte Application for Leave to Extend Page Limit for Defendant's
Motion For Suminary Judgnieiit or, in The Alterha.tive, Summary
Adjudication !
Dear Ms, Goulding,
Yesteriiay, 1 asked you in which Court Department you filed yoiir Ex Parte
Application for Leave to Extend Page Limit because you did riot mark on the front
piage of yOur pleadings which Court Department or which Judge \ybuld w6
1-
Ex Parte Application
handle your application. You are obliged to inform the opposite party what you are
filing and when and where you are filing it. What you have done is very
unprofessional.
As you probably know from the Court file, in October 2018, your
predecessors in this case, two former Porter Scott attomeys, David Biirkett and
Daniel Bardzell, with the evil intention of ending my wrongful termination lawsuit
against the Regents of the University of Caiifomia, bypassed Judge David Brown
in Department 53 and filed, on October 3, 2018 in Department 54, their deceptive
DEFENDANT'S NOTICE OF MOTION AND MOTION TO COMPEL
VERIFIED RESPONSES TO REQUESTS FOR PRODUCTION OF
DOCUMENTS SET ONE, SPECIAL INTERROGATORIES SET ONE, FORM
INTERROGATORIES GENERAL SET ONE, FORM INTERROGATORIES -
EMPLOYMENT SET ONE; TO DEEM REQUEST FOR ADMISSIONS
ADMITTED; AND FOR MONETARY AND TERMINATING SANCTIONS
(ROA 150-153) in an attempt to obtain an Order from Judge Christopher E.
Krueger or a stamped Order with Judge Krueger's name.
Burkett and Bardzell were caught, and their evil plan failed. If you look at
the Burkett and Bardzell's Notice of Motion and Motion (ATTACHMENT #1) of
October 3, 2018 and your Ex Parte Application for Leave to Extend the Page Limit
(ATTACHMENT #2) filed on April 26, 2021, you will see that both Court
Documents were filed/endorsed by the same Deputy Clerk named E. Medina,
It seems to me that history is repeating itself and that Porter Scott's new team of
Super Lawyers, Ms. Lindsay A. Goulding and Olatomiwa A. Aina, are rushing to
file a Motion for Summary Judgment in the same way that David Burkett and
-2-
Daniel Bardzell rushed to file the Termination Sanctions in Department 54 instead
of Department 53 three years earlier.
YOUR MEMqRA:]NDUM OF POINTS AND AUTHORITIES IN SUPPORT

OF EXTENSION OF PAGE LIMIT
In general; as a Plairitiff, I have no problem with the Ex Parte Application for

Extension oif the Page Lirnit. However, I took a closer look at your application to
- : I. • • , _
identify your justification for the Extension of the Page Limit,
Your Memorandum of Points is interesting in relation to the Second
Amended Complaint (SAC) Eight Causes of Action (COA) (ATTACHMENT
#3), which reaids as follows:
Defendant innends to move for surrimary judgment or, in the alternative,
sumrriary adjudication as the following causes of action:
1) harassment in violation of FEHA and failure \to prevent harassment,
discrimination, and retaliation in violation of Government Code § 12940(a)
The above No, 1 Cause of Action in your Memorandurn Of Points and Authorities
is actually the THIRD. CAUSE of ACTION in the SAC (Page Nos. 48-49) and
does iiot^require an Extensioii of the Page Limit because the THIRD COA was
removed from the SAC in 2015 by the Anti-SLAPP Motion, C C P § 425,16
granted by the Court to the Defendants, Danesha Nichols, Mike Boyd, Stephen
Chilcott, and Brent Seifert,
2) whistleblower/urilawfiil retaliation in violation of Govemment Code §
8547
The above No. 2 COA in yoiir Memorandum of Points and Authorities is actually
the FOURTH CAUSE OF ACTION in the SAC (Page Nos, 55-57) and does not
require an Extension of the Page Limit because FORTH COA was also removed
from the SAC in 2015 by the Anti-SLAPP Motion, CCP, § 425.16, granted by the
Court to the Defendants, Danesha Nichols, Mike Boyd. Stephen Chilcott, and Brent
Seifert,
3) retaliation under Health and Safety Code § 1278,5
This is actually the FIFTH CAUSE OF ACTION in the SAC (Page Nos. 55-
57) and does not require an Extension of the Page Limit because I have no intention
of pursuing this Cause of Action but I could change my mind in filing Third
Amended Complaint which was blocked in October 2015 to be file by Burkett,
Bardzell and Judge David Brown's Order
4) breach of written contract
This is actually the SDCTH CAUSE OF ACTION in the SAC, and it is the
most important COA in the entire Second Amended Complaint besides the age
discrimination and witch hunt of March 2011-December 2012, which has caused
me losses of approximately $1,000,000 in wages and benefits between December
2012 and the present.
5) wage and hour misclassification
This is actually the SEVENTH CAUSE OF ACTION in the SAC. My
Attorney, Douglas Stein, did not understand or did not have any knowledge about
the University of Califomia's pay policies and employee classification. I was
perfectly happy with my classification and wages, but U.S Senator Feinstein's
husband, Richard Blum, hunted me down for a different reason, which is pending
in the United States Coun Of Appeals For The District Of Columbia Circuit
whistleblower case Jaroslaw Janusz Waszczuk v. Commissioner of Internal
-4-
Revenue Services Case No. 20-1407
(https://www.scribd.com/document/495490868/Jaroslaw-Waszczuk-v-lRS-
Commissioner-UNITED-STATES-COURT-QF-APPEALS-FOR-THE-
DISTRICT-OF-COLUMBlA-CIRCUm.
6) rescission - unlawful contract
This is actually the EIGHTH CAUSE OF ACTION in the SAC, Regardless
of whether the Settlement Agreement of January 2009 was lawful or unlawful, the
Settlement Agreement was violated and breached by UC Regents, my human rights
were violated, and I was disposed of at the age of 62 like a piece of garbage and
subjected to an assassination attempt on May 31, 2012 by the UC Davis Death
Squad,
I disagree with your statement that the Motion for Summary
Judgment/Adjudication will necessarily require a detailed discussion of the nature
of the Plaintiffs employment relationship with Defendant.
I have all my employee performance reviews, which show that I was a good
employee and had a normal relationship with my employer. 1 was hunted down by
regents for a completely different reason than the one you are implying in your Ex
Parte Application,
1 fail to understand why Porter Scott's attorney is making attempts to bring back
into the lawsuit the Causes of Action dismissed from the SAC by the Anti-SLAPP
motion granted by the Court, Previously, David Burkett brought back the four dismissed
COAs into his requests for Production of Documents and Interrogatories. Now, you are
attempting to relitigate COAs that were already litigated for several years and are no
longer part of the Second Amended Complaint.
In concluding this Meet and Confer letter, I would appreciate if you would clarify
with the Court the status of the four individuals Stephen Chilcott, Mike Boyd,
Danesha Nichols, and Brent Seifert, Please clarify whether these individuals are
still Defendants or whether they were dismissed by the anti-SLAPP motion in 2015
together with first four COAs. Porter Scott Attomeys once brought them back in
their pleading as Defendants and another time classed them as former Defendants,
stating that they are being represented by Porter Scott.
1 noticed that in your April 26, 2021 Ex Parte Application for Leave to Extend
the Page Limit for the Defendant's Motion For Summary Judgment or, in the
Alternative, Summary Adjudication, you did not mention Stephen Chilcott, Mike
Boyd, Danesha Nichols, and Brent Seifert at all, which is in contrast to Burkett
Bardzell's and other Porter Scott's lawyers pleadings of 2018-2020. I am quite sure
that Stephen Chilcott, Mike Boyd, Danesha Nichols, and Brent Seifert do not want to
hear about this lawsuit or about Porter Scott's Attorneys anti-SLAPP motion dirty
money attached to violation of my human rights and endless harassment of 70 years
Old wife . Your first show off in this case did not go well for you Ms, Goulding , You
are dirty and unprofessional lawyer as same as your Porter Scott's predecessors with
J.D degree and licenses from the State Bar of Caiifomia .
Sincerely,
Jaroslaw Waszczuk,
-6
Mailing List
Re: Waszczuk v. Regisnts of the University of California et al.

Sacramento County No. 3420I300155479CUWTGDS
Hon, Clerk of the Côurt

Sacramento Countyj Superior Court
DeparlmeiTt 53 — Huri, .Shairia H, Mesiwala
813 6th Street, .2nd Floor
The Regents of the University of Califoriiia

111 1 Frariklin St,, l|2th floor
Oakland, CA 94607
Donna Hershkbwitz - The State Bar of Caiifomia Interim Executive Director

Vanessa Holton - The State Bar of Caiifomia Interim Executive Director

80 Howard Street
David P. E. Burkett, SBN 241896
FILED/ENDORSED
4 Sacramento, Caiifomia 95825 OCT -3 2018
TGL: 910.929:1481
5 FAX: 916.927.3706
dburkett(5),porterscott.com By:. E. Medina
Deputy Citrk
6
11
o
o
13 Plaintiff. DEFENDANT'S NOTICE OF MOTION
•5 a - vo AND MOTION TO COMPEL VERIFIED
o */>
u uc <^ 2
00 o 14 V. RESPONSES TO REQUESTS FOR
< (wf
o"o^vb
0> 15 PRODUCTION OF DOCUMENTS SET
THE REGENTS OF THE UNIVERSITY ONE, SPECIAL INTERROGATORIES SET
S 15: 16 OF CALIFORNIA, UNIVERSITY OF ONE, FORM INTERROGATORIES -
CALIFORNIA DAVIS HEALTH GENERAL SET ONE, FORM
o 17 SYSTEM, UC DAVIS MEDICAL INTERROGATORIES - EMPLOYMENT
18 CENTER, UC DAVIS, ANN MADDEN SET ONE; TO DEEM REQUEST FOR
RICE, MIKE BOYD, STEPHEN ADMISSIONS ADMITTED; AND FOR
19 CHILCOTT, CHARLES WITCHER, MONETARY AND TERMINATING
DANESHA NICHOLS, CINDY SANCTIONS
20 OROPEZA, BRENT SEIFERT, PATRICK
21 PUTNEY, DORIN DANILIUC, and Does Date: October 31,2018
I through 50, inclusive. Time: 9:00 a.m.
22 Dept.: 54
Defendants.
23
24 Complaint Filed: December 4,2013
Amended Complaint Filed: June 16,2014
25 SAC Filed: September 30, 2014
26
27
28 {0189I977.DOCX) 1
DEFENDANT'S NOTICE OF MOTION AND MOTION TO COMPEL VERIFIED RESPONSES TO
REQUESTS FOR PRODUCTION OF DOCUMENTS SET ONE, SPECIAL INTERROGATORIES SET ONE,
FORM INTERROGATORIES - GENERAL SET ONE, FORM INTERROGATORIES - EMPLOYMENT SET
ONE; TO DEEM REQUEST FOR ADMISSIONS ADMITTED; AND FOR MONETARY AND TERMINATING
SANCTIONS
TO PLAINTIFF:
PLEASE TAKE NOTICE that on the above date, time and department of this Court,
Defendarit REGENTS OF THE UNIVERSITY OF CALIFORNIA .(the "UNIVERSITY" or
"DEFENDANT"), will move the Court lo Compel Plaintiff JAROSLAW ("JERRY")
WASZCZUK's verified responses to Requests for Production of Documents (Set One), Special
7 Employment (Set One.); (2) deem Defendant's Request for Admissions (Set One) admitted; (3)
8 award monetary sanctions in the amount of $5,200.00 to retum Defendant to the position it would
9 have been had the subject discovery responses been timely provided; (4) issue terminating
10 sanctions against Plaintiff as a result of Plaintiffs pattern of vexatious litigation tactics and failure
II to engage in the discovery process; and (5) impose a deadline for Plaintiff to seek leave tofilea
12 Third Amended Complaint.
g
" Ml 13 This Motion is made on the grounds that good cause exists to cornpcl Plointiffs verified
H " n oo o
o « <^ 2 5:; 14 responses to Requests for Production of Documents (Set One), Special Interrogatories (Set One),
—p.- ^ ^ ^ I c
ttJ < O >£) >0 1 J Form Interrogatories - General (Set One), Form Interrogatories - Employment (Set One;); (2)
uj i< C OS s:
deem Defendant's Request for Admissions (Set One) admitted; (3) award monetary sanctions in
17 the amount of $5,200.00 to retum Defendant to the position it would have been had the subject
18 discovery responses been timely provided; (4) issue terminating sanctions against Plaintiff; and (5).
19 Impose a deadline for Plaintiff to seek leave to file a Third Amended Complaint because Plaintiff
20 has completely failed to respond to any such discovery request and responses remain outstanding
21 and overdue despite significant meet and confer efforts by Defendant.

22 Moreover, the sanction of termination of the present action is warranted as a result of
23 Plaintiffs failure to provide responses to the Defendant's written discovery despite receiving an
24 extension of time to do so and in light of Plaintiffs pattern of vexatious litigation tactics
25 throughout the course of this litigation.
26 If the Court is not willing, at this stage, to terminate the action, good cause exists for the
27
I0I89I977.DOCX) • 2 .
28 DEFENDANT'S NOTICE OF MOTION AND MOTION TO COMPEL VERIFIED RESPONSES TO
' REQUESTS FOR PRODUCTION OF DOCUMENTS SET ONE, SPECIAL INTERROGATORIES SET ONE,
FORM INTERROGATORIES-GENERAL SET ONE, FORM INTERROGATORIES - EMPLOYMENT SET
SANCTIONS
1 Court to impose a reasonable deadline of two weeks for Plaintiff to seek leave to fdc a Third
2 Amended Complaint, if Plaintiff intends toftirtheramend his complaint, so as to prevent
3 voluminous and unnecessary pleading amendments from further delaying the case and causing
4 Defendant unnecessary fees and costs.
5 This motion is based on this Notice of Motion, the Declaration of Daniel J. Bardzell,
6 Memorandum of Points and Authorities in support of the Motion, the pleadings and papers on file
7 in this action, and any evidence that may be submitted at the time of the hearing. A proposed form
8 of Order is also included.
9 Pursuant to Local Rule 1.06 (A), the court will make a tentative ruling on the merits of
10 this matter by 2:00 p.m., the court day before the hearing. The complete text of the tentative
II rulings for the department may be downloaded from the Court's public access site. If you do not
12 have online access, you may call the dedicated phone niimber for the department as referenced in
CN
13 the local telephone directory, between the hours of 2:00 p.m. and 4:00 p.m. on the court day before
, • - CM
n1 14 the hearing and listen to the tentative ruling. If you do not call the court and the opposing party by
. ^
vei ^ 15 4:00 p.m. the court day before the hearing, no hearing will be held.
OS OS
III
O
<
H u:
lO
17
18 By.
19 David P. E. Burkett
Daniel J. Bardzell
20 Attomeys for Defendant
21
22
23
24
25
26
27
(0189I977.DOCX}
28 DEFENDANT'S NOTICE OF MOTION AND MOTION TO COMPEL VERIFIED RESPONSES TO
FORM INTERROGATORIES-GENERAL SET ONE, FORM INTERROGATORIES - EMPLOYMENT SET
SANCTIONS
Waszczuk V. Regents of the University of California, et al
3 PROOF OF SERVICE
4
At the time o f service, I was over 18 years o f age and not a party to this action. M y
5 business address is 350 University Avenue, Suite 200, Sacramento, Caiifomia 95825.
7
DEFENDANT'S NOTICE OF MOTION AND MOTION TO COMPEL VERIFIED
8 RESPONSES TO REQUESTS FOR PRODUCTION OF DOCUMENTS SET ONE,
9 SPECIAL INTERROGATORIES SET ONE, FORM INTERROGATORIES - GENERAL
SET ONE, FORM INTERROGATORIES - EMPLOYMENT SET ONE; TO DEEM
10 REQUEST FOR ADMISSIONS ADMITTED; AND FOR MONETARY AND
TERMINATING SANCTIONS
11 BY MAIL: 1 placed the envelope for collection and mailing, following our ordinary business practices. I
am readily familiar with this business' practice for collecting and processing correspondence for mailing.
12 On the same day that correspondence is placed for collection and mailing, it is deposited in the ordinary
g course of business with the United States Postal Service, in a sealed envelope with postage fiilly prepaid.
13 BY PERSONAL SERVICE: 1 caused such document to be personally delivered to the person(s)
H 3 S _ SO
H T l oo o addressed below. (1) For a party represerited by an attomey, delivery was made to the attomey or at the
O u <^ 2: K 14 attomey's office by leaving the documents, in an envelope or package clearly labeled to identify the
attomey being .served, with a receptionist or an individual in charge of the office, between the hrihra of
ai <: o" ^ 2 15 nine in the moming and five in the evening. (2) For a party, delivery was made to the party or by leaving
the documents at the party's residence with some person not younger than 18 years of age between the
16 hours of eight in the moming and six in the evening.
BY OVERNIGHT DELIVERY; 1 enclosed the documents in an envelopte or package provided by an
o 17 overnight delivery carrier and addressed to the person(s) listed below. 1 placed the envelope or package
•n
for collection and ovemight delivery at my office or a regularly utilized drop box of the ovemight
18 delivery carrier.
BY FAX TRANSMISSION: Based on an agreement of the parties to accept service by fax transmission,
19 1 faxed the documents to the persons at the fax numbers listed below. No error was reported by the fax
machine that I used. A copy of the record of the fax transmission, which I printed out, is attached
20 BY ELECTRONIC SERVICE: Based on a court order or an agreement of the parties to accept service
by electronic transmission, 1 caused the documents to be sent to the persons at the electronic notification
21 address listed below.
2216 Katzakian Way
23 Lodi, CA 95242
24
I declare under penalty of perjury under the laws of the State of Caiifomia that the
25 foregoing is true and correct. Executed at Sacramento, Caiifomia on October 3,2018.
26
27 Wendy Strzisser
(01891977 DOCX} I
28
DEFENDANT'S NOTICE OF MOTION AND MOTION TO COMPEL VERIFIED RESPONSES TO
FORM INTERROGATORIES - GENERAL SET ONE, FORM INTERROGATORIES - EMPLOYMENT SET
SANCTIONS
I P O R T E R I S C O T T
3 Daniel J. Bard2xll, SBN 313993
4 Sacramento, California 95825
TEL: 916.929.1481
5 FAX: 916.927.3706
dburkett(5iporterscott.com
6
II
g
13 Plaintiff [PROPOSED] ORDER ON DEFENDANT'S
MOTION TO COMPEL VERIFIED
o
u . 2 14 RESPONSES TO REQUESTS FOR
«/5
U Ov Ov
15 PRODUCTION OF DOCUMENTS SET
THE REGENTS OF THE UNIVERSITY ONE, SPECIAL INTERROGATORIES SET
S
o S
> SiS•-<
>>16
< OF CALIFORNIA, UNIVERSITY OF ONE, FORM INTERROGATORIES -
CALIFORNIA DAVIS HEALTH GENERAL SET ONE, FORM
O 17 SYSTEM, UC DAVIS MEDICAL INTERROGATORIES - EMPLOYMENT
18 CENTER, UC DAVIS, ANN MADDEN SET ONE; TO DEEM REQUEST FOR
RICE, MIKE BOYD, STEPHEN ADMISSIONS ADMITTED; AND FOR
19 CHILCOTT, CHARLES WITCHER, MONETARY AND TERMINATING
DANESHA NICHOLS, CINDY SANCTIONS
21 PUTNEY, DORIN DANILIUC, and Does Date: October 31, 2018
1 through 50, inclusive. Time: 9:00 a.m.
22 Dept.: 54
Defendants.
23
Complaint Filed: December 4,2013

Amended Complaint Filed: June 16, 2014
{0I8920I7.DOCX) 1
[PROPOSED] ORDER ON DEFENDANT'S MOTION TO COMPEL VERIFIED RESPONSES TO
REQUESTS FOR PRODUCTION OF DOCUMENTS SET ONE, SPECIAL INTERROGATORIES
SET ONE, FORM INTERROGATORIES - GENERAL SET ONE, FORM INTERROGATORIES -
EMPLOYMENT SET ONE; TO DEEM REQUEST FOR ADMISSIONS ADMITTED; AND FOR
MONETARY AND TERMINATING SANCTIONS
1 On October 31, 2018, Defendant REGENTS OF THE UNIVERSITY OF CALIFORNIA
2 ("Defendant") brought a Motion to Compel Plaintiff JAROSLAW ("JERRY") WASZCZUK's
3 verified responses to Requests for Production of Documents (Set One), Special Interrogatories
4 (Set One), Form Interrogatories - General (Set One), Form Interrogatories - Employment (Set
5 One.); (2) deem Defendant's Request for Admissions (Set One) admitted; (3) award monetary
6 sanctions in thie amount of $5,200.00 to retum Defendant to the position it would have been had
7 the subject discovery responses been timely provided; (4) issue terminating sanctions against
8 Plaintiff as a. result of Plaintiffs pattern of vexatious litigation tactics and failure to engage in the
9 discovery process; and (5) impose a deadline for Plaintiff to seek leave to file a Third Amended
10 Complaint.
11 Upon consideration of the arguments on file, the Court rules as follows:
12 GOOD CAUSE APPEARING THEREFORE, IT IS HEREBY ORDERED that:
S! m 13
.i— >n 00 p
1. Defendant's Motion to Compel Plaintiffs verified responses to Requests for
Production of Documents (Set One), Special Interrogatories (Set One), Form
o « 2: 14
^
—
i - <?jK
^ w ^ I ^
Interrogatories - General (Set One) and Form Interrogatories - Employment (Set
< o"
UJ £. c. 5^ 5^
'5 One) is GRANTED.
2. Plaintiff i.s ordered to provide verified responses to Defendant's Requests for

17 Production of Documents (Set One), Special Interrogatories (Set One), Form
Interrogatories - General (Set One) and Form Interrogatories - Employment (Set
18 One) without objection by November 7, 2018.
19
Defendant's Request for Admissions (Set One) are deemed admitted in ftjll by
20 Plaintiff.
21
Monetary sanctions in the amount of $5,200.00 are awarded against Plaintiff and in
22 favor of Defendam REGENTS OF THE UNIVERSITY OF CALIFORNIA related
to the present Motion.
23
24 Defendants' Motion for Termination Sanctions is GRANTED and all causes of
action against the remaining Defendants are dismissed with prejudice.
25
26 Plaintiff shall seek leave from the Court to file a Third Amended Complaint within
two weeks of date of this Order. If Plaintiff fails to seek leave to amend by this
27
101892017.DOCX)
28 (PROPOSED) ORDER ON DEFENDANT'S MOTION TO COMPEL VERIFIED RESPONSES TO
RF.QIIF.STS FOR PRODlirTION OF DOCUMENTS S E T ONE, .SPECIAI. INTERROGATORIES
SET ONE, FORM INTERROGATORIES - GENERAL SET ONE, FORM INTERROGATORIES -
EMPLOYMENT SET ONE; TO DEEM REQUEST FOR ADMISSIONS ADMITTED; AND FOR
MONETARY AND TERMINATING SANCTIONS
date, he shall be precluded from flirthering amending his Complaint.
1
• . 2
IT IS SO ORDERED.
3
• 4
• 5 JUDGE OF THE COURT
8
9
10
11
12
o- . ' .
a VI • 13
1_- <M -
..O ^'^:;rR,/l4.
17
• .sirs 18
-19
20
21
22
•23
'24
25
26
27
{0i8920l7;bbCX> . „3,,
28; [PROPOSED] ORDER ON DEFENDANT'S MOTIQN TO COMPEL VERIFIED RESPONSES TO

REQUESTS F.ORPRODUGTION OF DOCÛMENTS SET ONEVSP^^^^
SET ONE, FORM INTERROGATORIES - GENERAL SET ONE, FORM INTERROGATORIES^
EMPLOYMENT SET ONE; TO DEEM REQUEST FOR ADMISSIONS ADMHTED; AND FOR
MONETARY AND T E R M I N A T I N
1 PORTER I S C O T T
2
Lindsay A Goulding. SBN 227195
FfLED/EMDORSED
3 Olatomiwa T. Aina, SBN 325566 APR 2 6 2021
TEL: 916.929.1481 ^•
5 FAX: 916.927.3706 Deputy Clerk
6
Attomey for Defendant
7
REGENTS OF THE UNIVERSfTY OF CALIFORNU
8
Exempt From Filing Fees Pursuant to Government Code § 6103
9
10
II
JAROSLAW ("JERRY") WASZCZUK, CASE NO. 34-2013-00155479
12
Plaintiff. EX PARTE APPLICATION FOR L E A V E
13 TO EXTEND PACE LIMIT FOR
t/i ao V. DEFENDANT'S MOTION FOR
o : K 14 SUMMARY JUDGMENT OR, IN T H E
u 15 15 THE REGENTS OF THE UNIVERSITY OF ALTERNATIVE, SUMMARY
U
H
9. CALIFORNIA, UNIVERSITY OF ADJUDICATION
Oi 16 CALIFORNIA DAVIS HEALTH SYSTEM,
2 UC DAVIS MEDICAL CENTER, UC
17 DAVIS, ANN MADDEN RICE, MIKE
18 BOYD, STEPHEN CHILCOTT, CHARLES
WITCHER, DANESHA NICHOLS, CINDY
PUTNEY, DORIN DANILIUC, and Does 1
20 through SO, inclusive. Complaint Filed: December 4, 2013
21 Amended Complaint Filed: June 16,2014
Defendants. SAC Filed: September 30, 2014
22
23
24
25
26
27
28
(03'1139S2.DOCX| 1
MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF DEFENDANT'S EXPARTE FOR
LEAVE TO FILE MOTION FOR SUMMARY JUDGMENT THAT EXCEEDS 20 PAGES
1 1.
2 EX PARTE APPLICATION
3 Defendant THE REGENTS OF THE UNIVERSITY OF CALIFORNIA ("UNFVERSITY")
4 hereby submits this Ex Parte Application for permission to file a Memorandum of Points and
5 Authorities in support of its Motion for Summary Judgment or, in the altemative, Summary
6 Adjudication in excess of twenty pages pursuant to Rules 3.1113(e) and 3.1200 ei stiq. of the
7 California Rules of Court. Rule 3.1113(e) allows a party to apply to the court for permission to file a
8 longer memorandum if the argument cannot be made within the stated page limit. Due to the lengthy
9 facts, multiple causes of action, and complex legal issues in this case, it is necessary that Defendant's
10 Memorandum of Points and Authorities exceed twenty pages to adequately address the factual and
II legal issues presented by the motion.
12 IL
o
a ^. 13 MEMORANDUM OF POINTS AND AUTHORJTIES i
(- 3 So - *
r - to " OO S IN SUPPORT OF EXTENSION OF PAGE LIMIT
p
*
—
6
:> w
»N c; 14
,_
Oi < o' ^ 15 Defendant intends to move for siunmary judgment or, in the altemative, siunmary
Q U e w < ^" adjudication as the following causes of action: I) harassment in violation of FEHA and failiu-e to
n
prevent harassment, discrimination, and retaliation in violation of Govenunent Code § 12940(a); 2)
18 whistleblower/unlawful retahation in violation of Govemment Code § 8547; 3) retaliation under
19 Health and Safety Code § 1278.5; 4) breach of written contract; 5) wage and hour misclassification;
20 and 6) rescission-unlawfiil contract. (Declaration of Lindsay A. Goulding in support of Defendant's
21 EJiParte Motion for Leave to File Motion for Summary Judgment that Exceeds 20 Pages ("Goulding
22 Decl. % 3.) The Motion for Stunmary Judgment/Adjudication will necessarily require a detailed
23
discussion of the nature of Plaintiffs employment relationship with Defendant, the alleged
24
harassment of Plaintifffirom2006 to 2013, as well as the individual defenses applicable thereto.
25
{Id.) The circumstances surrounding the allegedly harassing conduct will also require a detailed
26
discussion regarding the nature of the conduct, the timing, and the speakers and recipients of the
27
alleged harassment. (Id.) Further, a lengthy legal analysis will be required to address Plaintiffs
28
|02-»l.^952.DOC.X) 2
1 previous settlement agreement with Defendant. {Id.)
2 In order to address the lengthy facts, legal authority, and legal arguments regarding each of
3 Plaintiff s causes of action. Defendants' Memorandum of Points and Authorities in support of its
4 Motion for Summary Judgment/Adjudication will need to exceed twenty pages. Therefore,
5 Defendants respectfully request Ihat the court, pursuant to Rules 3 .113(e) and 3 .1200 et seq. of the
6 Caiifomia Rules of Coun, allow it to submit a Memorandum of Points and Authorities in excess of
7 twenty pages, but not to exceed forty pages. Defendant will make a good faith effort to keep the
8 motion as concise as possible.
9 III.
10 CONCLUSION
11 For the reasons set forth above. Defendant has demonstrated good cause for an expansion
12 of the page limit and move this Court to permit Defendant to submit a memorandum of up to 40
o
©
CN
13 pages in support of their Motion for Summary Judgment.
. 1/1 5f»00 ^
O tr<7v
f^ 2 — n 14
r 1 ^
15 Dated April 22, 2021 PORTER SCOTT

U< 6
16
o 17
18
19
By. m
Lindsay A. Goulding
Attorneys for Defendant
20
21
22
23
24
25
26
27
28
(02413952.DQCX)
I
Sacramepto County Superior Court, Case No. 34-2013-00155479
2
3 PROOF OF SERVICE
address is 350 University Avenue, Suite 200, Sacramento, Caiifomia 95825.
5
7 MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF DEFENDANT'S

EXPARTE FOR LEAVE TO FILE MOTION FOR SUMMARY JUDGMENT THAT
8 EXCEEDS 20 PAGES
9
XX BY MAIL: I placed the envelope for collecton and mailing, following our ordinary business practices. I
10 am readily familiar with this business* practice for collecting and processing correspoDdence for mailing.
On the same day ihat correspondence is placed for coliectioD and mailing, it is deposited in the ordinary
II course of business with the United States Postal Service, in a sealed envelope with postaRC fiiUv prepaid,
BY PERSONAL SERVICE: I caused such documeni lo be personally delivered lo the person(s) addressed
12 below. (1) For a party represented by an attorney, delivery was made to the attomey or at the attomey's
o
o office by leaving the documents, in an envelope or package clearly labeled to identify the attomey being
13 served, with a receptionist or an individual in charge of the office, between the hoiurs of nine in the moming
ir"- It ' i " -oc So and five in the evening. (2) For a party, delivery was made to the party or by leaving the documents at the
14 party's residence with some person not yoimger than 18 years of age between the hours of eight in the
o «• r momihft and six in (he evening.
— :> w OS (7-
< d ^ £ 15 BY OVERNIGHT DELIVERY: I envlusicU the Uucumcnls in sin mvelope ur package provided by an
ovemight delivery carrier and addressed to the person(s) listed below. I placed the envelope or package for
Bfi £ £ ^ % 16 collection and ovemight delivery at my office or a regularly utilized drop box of the overnight delivery
o S 2 5ii < carrier.
o 17 BY FAX TRANSMISSION: Based on an agreement of the parties to accept service by fax transmission, I
faxed the documents to the persons at the fiU niunbers listed below. No error was reported by the fax
18 machine that I used. A copy of the record of die fax transmission, wliich I printed out, is attached
DY ELECTRONIC SERVICE: Based ou a court ordci or an agiceinciil of (lie parlies lo accept service by
19 electronic transmission. I caused the documents to be sent to the persons at the electronic notification address
listed below.
20
2216 Katzakian Way
22 Lodi, CA 95242
JJWI980@LIVE.COM
23
24 I declare under penalty of perjury under the laws of the State of Caiifomia that the foregoing
is true and correct. Executed at Sacramento, Caiifomia on April 26, 2021.
25
26
27
28 Virginia Yao
(0j41.^052.DOCX)
Lindsay A. Goulding. SBN 227195
3 Olatomiwa T. Aina, SBN 325566
TEL: 916.929.1481
5 FAX: 916.927.3706
6
X Attomey for Defendant
7
REGENTS OF THE UNTVERSfFY OF CALIFORNIA
8
9
10
12
Plaintiff, [PROPOSED] ORDER ON
13 DEFENDANT'S EX PARTE
Ml ?! APPLICATION FOR LEAVE TO
o _ 14 EXTEND PAGE LIMIT FOR
CM El
a: < 15 THE REGENTS OF THE UNIVERSITY OF DEFENDANT'S MOTION FOR
CALIFORNL\, UNIVERSITY OF SUMMARY JUDGIMENT OR, IN THE
16 CALIFORNIA DAVIS HEALTH SYSTEM, ALTERNATIVE, SUMMARY
a. UC DAVIS MEDICAL CENTER, UC ADJUDICATION
5 .55 17 DAVIS, ANNi MADDEN RICE, MIKE
o

19 OROPEZA, BRENT SEIFERT, PATRICK Complaint Filed: December 4,2013
PUTNEY, DORIN DANILIUC, and Does 1 Amended Complaint Filed: June 16, 2014
20 through 50, inclusive, SAC Filed; September 30, 2014
21
Defendants.
22
23
24 /
25 An Ex Parte Application for an order peraiitting Defendant THE REGENTS OF THE
26 UNFVERSITY OF CALIFORNIA to file a Memorandum of Points and Authonties m Suppon of

their Motion for Stmimary Judgment or, in the Altemative Stmimary Adjudication exceeding 20
pages in length was filed with this Court on the above date and time. The Court has reviewed the
{024l45iz.DOCX) 1
id I WOFOStUJ OKUEK OIN DtMSNUAN I'S KX PAK I E APPLIL'A I IUN TO EX I END PAGE
LIMIT OF DEFENDANT'S MOTION FOR SUMMARY JUDGMENT OR, IN THE
ALTERNATIVE, SUMMARY ADJUDICATION
1 Ex Parte Application and found good cause to grant Defendant's fequest for a page extension.
2 IT IS TkEREFORE ORDERED; THAT Defendant THE R£GENTS OF THE
3 UNIVERSITY OF CALIFORNL\ shall be permitted to file a Memorandum of Points aid '
. 4 Authorities in Support of its Motion for Summary Judgment, or in the Altemative, Summary
"5 Adjudication in exceiss of 20,pages, butnot to exceed 40 pages.
6
7 bated;: ,
JUDGE OF THE SUPERIOR COURT
8
9
10
11
12
cs,
13
l i p a6
= 17
m
18
19
20
21
22
23
24
25
26
27
28
{024l45J2.pOCX)
IPROPOSED ORDER ON DEFENDANT'S EX PARTE APPLICATION TO EXTEND PAGE

LIMIT OF DEFENDANT?^S MOTION FOR SUMMARY JUDGMENT OR, IN THE
ALTERNATIVE, SUPilMARÂbjUDICATlON
2
TEL: 916.929.1481
5 FAX: 916.927.3706
6
Attorney for Defendant
7
REGENTS OF THE UNIVERSITY OF CALIFORNIA
8
9
10

12
o Plaintiff DECLARATION OF LINDSAY A.
o
CN
i _ •- <N
13 GOULDING IN SUPPORT OF
— vO
[— C/5 V. D E F E N D A N T ' S E X P A R T E FOR L E A V E
n „- _ rn 14
u OS r^' TO FILE M O T I O N FOR SUMMARY
i < OS Os THE REGENTS OF THE UNIVERSITY OF J U D G M E N T T H A T EXCEEDS 20 PAGES
on 15
oi
C OS OS CALIFORNIA, UNIVERSITY OF
16 CALIFORNIA DAVIS HEALTH SYSTEM,
E S UC DAVIS M E D I C A L CENTER, UC
o 17
DAVIS, A N N M A D D E N RICE, M I K E
18 BOYD, STEPHEN CHILCOTT, CHARLES Complaint Filed: December 4, 2013
WITCHER, DANESHA NICHOLS, CINDY AnicnJcd Coniplainl Filed. June 10,2014
19 OROPEZA, BRENT SEIFERT, PATRICK SAC Filed: September 30, 2014
PUTNEY, DORIN D A N I L I U C , and Does 1
20
through 50, inclusive,
21
Defendants.
22 /
23 I, Lindsay A. Goulding, declare as follows:
24 1. I am an attorney at law licensed to practice before all courts in the State of California
25
and am a partner with the law firm of Porter Scott, attorneys of record for Defendant REGENTS OF
26
THE UNIVERSITY OF CALIFORNIA ("Defendant" or "UNIVERSITY"). I state the facts herein
27
of my own personal knowledge and, i f called upon as a witness, 1 could and would competently
28
testify thereto.
102413956 DOCX 1 1
DECLARATION OF LINDSAY A. GOULDING IN SUPPORT OF DEFENDANT'S EXPARTE FOR LEAVE
TO FILE MOTION FOR SUMMARY JUDGMENT THAT EXCEEDS 20 PAGES
1 2. The Second Amended Complaint alleges the following causes of action: 1)
2 intentional infliction of emotional distress; 2) tortious interference with economic advantage; 3)
3 harassment in violation of FEHA and failure to prevent harassment, discrimination, and retaliation
4 in violation of Government Code § 12940(a); 4) whistleblower/unlawful retaliation in violation of
5 Government Code § 8547; 5) retaliation under Health and Safety Code § 1278.5; 6) breach of written
6 contract; 7) wage and hour misclassification; and 8) rescission-unlawful contract.
7 3. Defendant intends to move for summary judgment or, in the alternative, summary
8 adjudication as to the following causes o f aciion; 3) harassment in violation o f FEHA and failure to
9 prevent harassment, discrimination, and retaliation in violation of Government Code § 12940(a); 4)
10 whistleblower/unlawful retaliation in violation of Government Code § 8547; 5) retaliation under
12 and 7) rescission-unlawful contract. The Motion for Summary Judgment/Adjudication will
o
o
13 necessarily require a detailed discussion of the nature of Plaintiffs employment relationship with
3 oc — so
H u-i 3C O
•a-
0 o<=^ — 14 Defendant, the alleged harassment of Plaintiff from 2006 to 2013, as well as the individual defenses
<> r--
OS OS
01 < d SO s^ 15 applicable thereto. The circumstances surrounding the allegedly harassing conduct will also require
OS OS
^ 1- C -i X 16 a detailed discussion as to the nature of the conduct, the timing, and the speakers and recipients of
O ^2
ft. c
o 17 the alleged harassment. Further, a lengthy legal analysis will be required to address Plaintiffs
o-j
m
18 previous settlement agreement with Defendant.
19 4. In order to address the lengthy facts, legal authority, and legal arguments regarding
20 each of Plaintiffs causes nf action. Defendants' Memorandum of Points and Authorities in support
21 of its Motion for Summary Judgment/Adjudication will need to exceed twenty pages.
22 5. 1 contacted Plaintiff to inform him of this Application via telephone and email on
23 April 26, 2021 at approximately 9:02 a.m. Attached hereto as Exhibit A is a true and correct copy
24 of my email correspondence to Plaintiff regarding Defendant's request to exceed the page limit.
25 I declare under penalty of perjury under the laws of the State of California that the foregoing
26 is true and correct. Executed this 26th day of April 2021, at Sacramento, California.
27
28
m
Lindsay A. Goulding
102413956 DOCX 1
64 A
0I054547:WI'U
From: VirQinia Yao
To: -iiwigRntai TVF.rnM
Cc: Lindsav'A. GouTdina: Tomi Aina
Subject: Waszczuk v. Regents
Date: "- , iMondayJ April,'26, 2021 8:59:00 AM
'Attachments: imaQeOOl.ohQ"
Dea r M r'. Waszczu k:
This Is just to confirm our conversation this morning thaf our office is filing an Exparte
today on, the papersj to request a page extension to the Motion for Summary of
Judgment that we will be filing? Thank you.
Virginia Yao
Legal;Assjstaht to Lindsay A. Goulding
350 University Avehue j Suite.20b j Sacramento, CA 95825
T| 916.929.1481 x 331 F| 916.927.3706 '
vvwvv'Porterscott.com
Waszczuk V. Regents of the University of California, et a l
1
2
PROOF OF SERVICE
3
5
7 D E C L A R A T I O N OF L I N D S A Y A. G O U L D I N G I N SUPPORT O F
D E F E N D A N T ' S E X P A R T E FOR L E A V E T O F I L E
8 M O T I O N FOR S U M M A R Y J U D G M E N T T H A T EXCEEDS 20 PAGES
9
XX BY M A I L : I placed the envelope for collection and mailing, following our ordinary business practices. 1
10 am readily t'amiliar with this business' practice tor collecting and processing correspondence tor mailing.
11 course o f business with the United States Postal Service, in a sealed envelope with postage fully prepaid.
B Y P E R S O N A L S E R V I C E : I caused eiich d o c u m e n t t o be p e r s o n a l l y d e l i v e r e d to the perEon(s) addressed
12 below. (1) For a party represented by an attorney, delivery was made to the attorney or at the attomey's
o office by leaving the documents, in an envelope or package clearly labeled to identify the attorney being
o
ii m 13 served, with a receptionist or an individual in charge o f the office, between the hours o f nine in the moming
I-
= s _^
C/3 V I 00 o
and five in the evening. (2) For a party, delivery was made to the party or by leaving the documents at the
- ON
o 14 party's residence with some person not younger than 18 years o f age between the hours o f eight in the
< Ci morning and six in the evening.
u ^
o' •£> ^
O
15 DY O V E R N I G H T DELIVERY: 1 enclosed the d o c u m e n t s i n an e n v e l o p e o r package p r o v i d e d b y an
[/)
1-
C OS O overnight delivery carrier and addressed to the person(s) listed below. 1 placed the envelope or package for
t> , .
O
E -) X 16 collection and ovemight delivery at my office or a regularly utilized drop box o f the overnight delivery
n UJ <
c o H n. carrier.
3 (/3
O 17 BY F A X T R A N S M I S S I O N : Based on an agreement o f the parties to accept service by fax transmission, 1
faxed the documents to the persons at the fax numbers listed below. No error was reported by the fax
18 machine that 1 used. A copy o f the record o f the fax transmission, which 1 printed out, is attached
XX b v t L t c l K U l N i c S l i K V l c t : based on a court order or an agreement of the parties to accept service by
19 electronic transmission, 1 caused the documents to be sent to the persons at the electronic notification address
listed below.
20
2216 Katzakian Way
22 Lodi, CA 95242
JJW1980(fl)LIVE.COM
23
25 is true and correct. Executed at Sacramento, California on April 26, 2021.
26
27
28 Virginia Yao
102413956 DOCX!
1 ANN MADDEN RICE (CEO UCD Health Services), MIKE BOYD, STEPHEN CHILCOTT
2 (Executive Director, Human Resources), CHARLES WITCHER, DANESHA NICHOLS,

3 CINDY OROPEZA, BRENT SEIFERT, PATRICK PUTNEY, DORIN DANILIUC, and Does
4 I through 20, as follows:
5 IV. FIRST CAUSE OF ACTION

fINTENTIONAL INFLICTION OF EMOTIONAL DISTRESS]
6
101. Plaintiff refers to the allegations contained in paragraphs, including subparagraphs, I
7
through 100, inclusive, and incorporates each by reference as though fully set forth at length herein.
8
102. Defendants, and each of them, acted in concert with intent to cause Plaintiff severe
9
emotional distress. The evidence is clear and convincing, at the least, that the defendants, with
10
premeditation, undertook acts that denied the reality of the abuse experienced by the Plaintiff and
11
fabricated nature of the "complaints" made about the plaintiff
12
103. The acts and omissions as alleged herein, separately and taken together, are so
13
extreme and outrageous that the defendants, and each of them, acted outside the course and scope
14
of their employment with UC DAVIS. The depth, length o f time, and nature o f the acts are so
15
extraordinary that no reasonable person can conclude such acts and omissions are within the
16
course and scope of duties as a manager, supervisor, or officer of a public entity such as and
17
including UC DAVIS.
IS
104. Defendants' actions as herein alleged do, and did, constitute extreme and
19
outrageous conduct.
20
105. Defendants' acted with intent of causing, or with reckless disregard for the
21
probability o f causing, severe emotional distress to Plaintiff.
22
106. As a proximate result of the acts alleged herein Plaintiff suffered severe or
23
extreme emotional distress, entitling plaintiff to damages, including but not limited to, medical
24
expenses, lost income, other special damages, general damages, and exemplary damages, all in
25
an amount to be proven at trial
26
WHEREFORE, Plaintiff prays for judgment as hereinafter set forth
27
COMES NOW Plaintiff and for a Second Cause of Action, alleges against Defendants,
28
I'agc 49 of 63
( , ' n t l C"t) tiipln r 11 (-1, 111 p i n v i n e II (
ANN MADDEN RICE, MIKE BOYD, STEPHEN CHILCOTT, CHARLES WITCHER,
2 DANESHA NICHOLS, CINDY OROPEZA, BRENT SEIFERT, PATRICK PUTNEY, DORIN

3 DANILIUC, and Does I through 20, as follows:
4 V. SECOND CAUSE OF ACTION

[TORTIOUS I N T E R F E R E N C E WITH ECONOMIC ADVANTAGE]
5
107. Plaintiff refers to the allegations contained in paragraphs, including subparagraphs, 1
6
7
108. At all relevant times. Defendants ANN MADDRN RICR, MIKF. ROYD,
8
STEPHEN CHILCOTT, CHARLES WITCHER, DANESHA NICHOLS, CINDY OROPEZA,
9
BRENT SEIFERT, PATRICK PUTNEY, DORIN DANILIUC, DOES 1 through 20, knew of the
10
existence of the settlement agreement between plaintiff and UC DAVIS and/or plaintiffs
11
property rights in his public employment with UC DAVIS described herein.
12
109. At all relevant times. Defendants, and each of them, knew that managers and
13
supervisors, including defendants PUTNEY and WITCHER, evaluated plaintiff as a "very
14
valuable employee", "OUTSTANDING. Exceeds Expectations", "...performance has been
15
excellent...", "...overall job performance is outstanding...", "...have not been any problems with
16
missed alarms...", "...very instrumental...monitoring...alarm/ status of critical equipment...",
17
"...Helping...managing the work order system...providing computer support...", "...also
IS
helping with closing work orders...", "...is talented, precise and his daily paper work is
19
excellent...", "...can be counted on to keep management informed status of the plant and
20
equipment...", and "...committed to the future success of the Medical Center..."
21
110. At all relevant times, Defendants, and each of them, knew that no employee, co-
22
employee, manager, supervisor, including defendants PUTNEY, DANILIUC, CURRY and
23
WITCHER, and/or administrator ever complained about, had to investigate or consider concerns
24
regarding, and/or so much as heard rumors that plaintiff engaged in discriminatory acts, made
25
discriminatory statements, and/or presented a disruptive or violent risk within the work place.
26
111. To be sure. Defendants, and each of them, knew plaintiff is, and was at all relevant
27
times, precise in his work, could be counted on to keep management informed of the status of the
28
I'ligf 50 of 63
( . i i i l <"ompt-iiii(-r,inpl)t_t invnt
1 plant and equipment, committed to the future success of the Medical Center, and rightfully and
2 lawfully expected that no person, let alone supervisors, managers. Human Resource personnel,
3 and others would be dishonest, fabricate stories about him, disregard evidence, disregard policies
4 and practices for impartial investigations, disregard defendants' actions on plaintiffs well-being,
5 and/or set about to cause him emotional harm, all with the intent to ensure that plaintiff never
6 returned to work again.
7 112. Defendants, and each of them, knew that their actions, including but not limited
8 to the actions described herein, as well as their actions issuing investigatory leaves in violation
9 of policies and procedures, would cause and did cause plaintiff to suffer severe emotional distress,
10 especially when not one person left employed by UC DAVIS looked at, considered, and/or
I I analyzed the actual evidence, such as the work orders showing PUTNEY and DANILILIC falsely
12 accused the plaintiff of missing a critical alarm, plaintiffs evaluations written by PUTIMEY,
13 surprising plaintiff twice with re-issued investigatory leaves when plaintiff believed he was
14 returning to work, instructing plaintiff not to send emails to anyone other than WITCHER even
15 though WITCHER as well as every other manager or supervisor never responded in a serious
16 manner to plaintiff, the employees considering plaintiffs PPSM 70 complaints were copied on
17 emails from the other defendants from an early point in the sequence of events, the conclusions
IS o f a group of attorneys and e.xperienced managers on the misconduct disclosed by plaintiff were
19 absurd and unbelievable, and the sudden and not previously an issue discipline issued against co-
20 employees plaintitf represented challenging the discipline.
21 113. The only conclusion that is more likely than not, actually clear and convincing,
22 considering all the evidence, including the examples described herein, is that defendants, and
23 each of them, coordinated their actions, conferred with each other, and otherwise had a common
24 goal and/or understanding to either force plaintiff to quit and/or force him to act or behave in
25 ways that would provide them a subterfuge for his termination. Meanwhile, defendants, and each
26 of them, set about to extricated plaintiff from his employment because plaintiff was a
27 whistleblower, and a significant percentage of employees who report misconduct suffer
V-Afiv 51 of 63
(.'ivil <'oii)pl.iiii(-I''ni|ili>i'incnt
1 114. PlaintifThad a reasonable expectation that his employment would be available for
2 him to work, earning an hourly rate, plus benefits, and all other compensation due under the law
3 so long as plaintiff continued to do his work and perform at the workplace as he had since 1999.
4 115 Defendants engaged in the conduct alleged herein with the intent to harm Plaintiff
5 financially and to induce plaintiff and/or UC DAVIS to violate the Settlement Agreement, and/or
6 to take away plaintiffs property rights in his employment without the beneFu of the processes,
7 procedures, and safeguards provided for such things under the law, including UC DAVIS' own
9 116. As a proximate result of the conduct of Defendants actions and omissions

10 described herein, as well as based on evidence not disclosed herein, plaintiff was damaged, and
I I continues to experience damages, in an amount that excess $75,000.00 per year, for no less than
12 6 years, and/or the number of years from the date plaintiff last received his income to the date
13 plaintiff intended to retire. When Plaintiff has ascertained the full amount of its damages, it will
14 seek leave of Court to amend this Complaint and/or by evidence at the time of trial provide proof
15 accordingly.
16 117. Plaintiff alleges that one of more of the defendants acted with reckless disregard
17 for plaintiffs rights and/or failed to perceive, observe, and act as a reasonable person under the
IS same or similar circumstances. Further, said reckless disregard for plaintifPs rights and/or
19 negligence were substantial factors in the damages plaintiff sustained.
20 118. , I'he conduct of one or more of the Defendants as described herein was purposeful
21 and intentional and was engaged in for the purpose of depriving Plaintiffs of property or legal
22 rights or otherwise causing injury, and was despicable conduct that subjected to cruel and unjust
23 hardship in conscious disregard of its rights, and was performed with fraud, oppression or malice
24 so as to justify an award of exemplary or punitive damages against such Defendants in an amount
25 according to proof at trial.
26 WHEREFORE, Plaintiff prays for Judgment against Defendants as hereinafter set forth:
27 COMES NOW Plaintiff, and for a Third Cause of Action, alleges against Defendants,
28 THE REGENTS OF THE UNIVERSITY OF CALIFORNIA, ANN MADDEN RICE, MIKE
Vnov 52 of 63
(~^^ il tiipirt r 11 ( - ICniplii^ iiic n t
1 BOYD, STEPHEN CHILCOTT, CHARLES WITCHER, DANESHA NICHOLS, CINDY
2 OROPEZA, BRENT SEIFERT, PATRICK PUTNEY, DORIN DANILIUC, and Does 21

3 through 40, as follows:
4 VL THIRD CAUSE OF ACTION

[HARASSMENT and F A I L U R E TO PREVENT HARASSMENT, DISCRIMINATION,
5 RETALIATION: Government Code § 12940 (a)]
6 119. PlaintitT refers to the allegations contained in paragraphs, including subparagraphs, 1
8 119a. Government Code § 12940(a) provides "It is an unlmvful employment
9 practice...VoTan employer, because o/the...national origin, ancestry...mental disability, medical
10 condition... of any person...to bar or to discharge the person from employment or from...to
I I discriminate against the person in compensation or in terms, conditions, or privileges of
12 employment."
13 120. Plaintiff is informed and believes and thereon alleges that Defendants, and each
14 of them, coordinated, cooperated, agreed, and/or had an understanding to misuse, abuse, and/or
15 disregard California law, the REGENTS' polices, and UC DAVIS' procedures to deny plaintiffs
16 rights to return to work. Furthermore, Defendants, and each of them, coordinated, cooperated,
17 agreed, and/or had an understanding to utilize plaintiffs national origin and ancestry against him,
IS inter alia, Plaintiff, born and raised into adulthood in Poland under the communist rule o f the
19 Soviet Union, arrived in America as an asylum seeker and was granted political asylum.
20 Defendants knew that plaintiff personified cultural diversity with undisputed differences and
21 difficulties expressing himself in English. Defendants, and each of them, knowingly ignored
22 Plaintiffs culturally diverse characteristics and traits, and, attempted to judge, evaluate, and
23 critique Plaintiff utilizing narrow, shallow, and discriminatory standards, such as, but not limited
24 to, UC DAVIS' Standards of Community. Multiple scholars and civil rights experts have advised
25 UC DAVIS that the Standards of Community express and espouse discriminatory and
26 unconstitutional standards.
27 120a. Further, defendants, and each of them, intentionally created and caused scenarios
28 that they knew would cause plaintiff to suffer from anxiety, anger, and emotional distress.
l':ine 53 of 63
( ' i v i l <7i)nipLi i lit- r.inplfi,^ m e r i t
1 because the defendants knew, based on plaintiffs own admissions and the defendants'
2 experience that plaintiff would manifest and/or alleviate his anxiety, anger, and emotional
3 distress by writing and sending letters or emails, which, to the uninformed and/or malice minded
4 person, might be unorthodox. However, defendants, and each of them, knew plaintiff did not
5 have any history of violence, did not have any history of racism, and did not have any history of
6 any discrimination.
7 121. Defendants, and each of them, further discriminated against plaintiff based on his
8 mental disability and medical condition as described herein.
9 122. Defendants and its agents, managers and employees, violated Caiifomia Govemment
10 Code §12940, by failing to adequately supervise, control, discipline, and/or otherwise penalize the
I I conduct, acts, and failures to act as described herein. As such. Defendant and the Individual Defendants
12 failed to fulfill their statutory duty to take all reasonable and necessary steps to prevent discrimination,
13 harassment, and retaliation from occurring in the workplace, as required by Caiifomia Govemment
14 Code§12940(k)
15 123. Beginning in approximately April for 2011, Defendants fabricated and conjured up
16 false accusations, false reports, and feigned complaints, and, undertook oppressive, abusive, and
17 discriminatory acts that continued up to and through December 7,2012, the effective date of plaintiffs
IS termination.
19 124 .In truth and in fact. Plaintiff did not do anything wrong. It is undisputed that plaintiff
20 attempted to persuade defendants, and each of them, to settle, resolve, and/or put an end to whatever
21 acrimony might have existed on the part of defendants, and each of them, at the workplace. Defendants,
22 and each of them, never responded to or reacted to plaintiffs attempts to live and let live, and to get
23 plaintiff back to his employment.

24 125. Defendants knew plaintiff became distressed, angry, and upset with each and every
25 false accusation, false report, and feigned complaint, and, with each unfounded adverse employment
26 action, such as but not limited to, a biased, one-sided, and incomplete investigation report, or, the lack
27 of meaningful investigation into the misconduct plaintiff actually reported, or, notifying plaintiff of an
28 Notice of Investigatory Leave one day before his post-stress leave return to work on September 1,2011,
I'ngc 54 of 63
(îvil Ouiiiplii i iH - K i i i p l i i y i n r n t
1 or, personally handing an unsuspecting plaintiff, who expected to start work, another Notice of
2 Investigatory Leave on May 31, 2012, with a crisis team on stand-by, or, being instructed not to
3 communicate with employees even though plaintiff represented them and there was no indication
4 plaintiff was disrupting an investigation.
5 126.. Defendants, and each of them, as part and parcel of their ongoing, continuing, and
6 repeated retaliation, harassment, and abuse for whisileblowing about misconduct, engaged in a course
7 of action that constituted, separately and cumulatively, discrimination, harassment and retaliation
8 because of national origin, ancestor, mental condition, and/or medical condition.
9 127. The discrimination, harassment and retaliation are continuous and persist to date
10 against Plaintiff
I I 128. As a result of Defendants' failure to take reasonable steps to prevent the discrimination,
12 harassment and retaliation. Regents have allowed WITCHER and the other defendants to continue to
13 harass and retaliate against Plaintiff in compensation and terms of employment. Every day and week
14 there is some new harassing, retaliatory plan to drive Plaintiffout ofout of UCD, disparage him, or take
15 compensation from him. Plaintiff has suffered substantial economic losses in wages and benefits,
16 damages to reputation, credit and other financial injuries in an amount to be determined at trial.
17 129. As a result of Defendants' harassment and discrimination and the failure to prevent
IS and/or take reasonable steps to prevent discrimination, harassment and retaliation. Plaintiff suffered
19 compensatory damages, consisting of mental anguish, humiliation, alienation, emotional distress and
20 embarrassment in a sum according to proof at the time of trial.
21 130. Pursuant to Caiifomia Govemment Code §12965, Plaintiff requests the award of
22 attorneys' fees against Defendants under this cause of action.
24 COMES NOW Plaintiff, and for a Third Cause of Action, alleges against Defendants,
25 THE REGENTS OF THE UNIVERSITY OF CALIFORNIA, ANN MADDEN RICE, MIKE
26 BOYD, STEPHEN CHILCOTT, CHARLES WITCHER, DANESHA NICHOLS, CINDY

27 OROPEZA, BRENT SEIFERT, PATRICK PUTNEY, DORIN DANILIUC, and Does 21
28 through 40, as follows:
Pasc 55 of 63
( . ' i v i l ( .n i i i p l . 1 i i i t - K i i i p l o y i i i r l i t
I VII. FOURTH CAUSE OF ACTION
2 ]WHISTLEBLOWER/UNLAWFUL RETALIATION IN VIOLATION OF

GOVERNMENT CODE §§ 8547 et. seq.]
3
131. Plaintiff refers to the allegations contained in paragraphs, including subparagraphs, 1
4
5
132. Govemment Code §8547.10 states (a) A University of California employee,
6
including an officer or faculty member, or applicant for employment may file a written complaint
7
with his or her supervisor or manager, or with any other university officer designated for that
8
purpose by the regents, alleging actual or attempted acts of reprisal, retaliation, threats, coercion,
9
or similar improper acts for having made a protected disclosure, together with a sworn statement
10
that the contents of the written complaint are true, or are believed by the affiant to be true, under
11
penalty of perjury.
12
133. The complaint shall be filed within 12 months of the most recent act of reprisal
13
complained about. §8547.10. provides "(a) A University of California employee, including an
14
officer or faculty member, or applicant for employment may file a written complaint with his or
15
her supervisor or manager, or with any other university officer designated for that purpose by the
16
regents, alleging actual or attempted acts of reprisal, retaliation, threats, coercion, or similar
17
improper acts for having made a protected a protected statement that the contents of the written
IS
complaint are true, or are believed by the affiant to be true, under penalty of perjury. The
19
complaint shall be filed within 12 months of the most recent act of reprisal complained about.
20
Plaintiffs disclosures and reports concemed, or plaintiff had a good faith belief that his disclosures
21
concerned, activity by and/or conditions existing due to misconduct, including but not limited to waste,
22
fraud, abuse of authority, violation of law, or threat to public health."
23
134. Plaintiffs reports include, but are not limited to, reports of the coordinated efforts to
24
deny him his employment as well as the apparent ratification and/or complicity of officers of the UC
25
system.
26
135. The outrageous conduct of the Defendants described above was done with malice,
27
fraud and oppression and with reckless disregard for the rights of the Plaintiff Accordingly, Plaintiff
28
V-AgQ 56 of 63
( J ^ ' i l ( 'n n i p l i i i II I -1~ i i i p l i i V inv lit
1 requests the assessment of exemplary and punitive damages against Defendants, in an amount
2 appropriate to punish and make an example of them.

3 136. Plaintiff seeks all available damages including punitive damages for retaliation against
4 him as a whistleblower under the Caiifomia Whistleblower Protection.
6 COMES NOW Plaintiff, and for a Sixth Cause of Action, alleges against Defendants,
7 THE REGENTS OF THE UNIVERSITY OF CALIFORNIA, and Does 21 through 50, as

8 follows:
VHI. FIFTH CAUSE OF ACTION
9 [HEALTH & SAFETY CODE § 1278.5|
I I throLigh 136, inclusive, and incorporates each by reference as though fully set forth at length herein.
12 138. The California Legislature enacted Health & Safety Code § 1278.5 because "... it
13 is the public policy of the State of California to encourage patients, nurses, members of the
16 and in order to assist those accreditation and government entities charged with ensuring that
17 health care is safe. The Legislature finds and declares that whistleblower protections apply
I8 primarily to issues relating to the care, services, and conditions of a facility' and are not intended
19 to conflict with existing provisions in state and federal law relating to employee and employer
20 relations..." (Emphasis Added)
21 139. § 1278.5(b) (1) provides "No health facility shall discriminate or retaliate, in any
22 manner, against any patient, employee, member of the medical staff, or any other health care
23 worker of the health facility because that person has...Presented a grievance, complaint, or
24 report to the facility, to an entity or agency responsible for accrediting or evaluating the facility,
25 or the medical staff o f the facility, or to any other governmental entity..." (Emphasis Added)
26 140. § 1278.5(d)(1) states "There shall be a rebuttable presumption that discriminatory

27 action was taken by the health facility, or by the entity that owns or operates that health facility,
28 or that owns or operates any other health facility, in retaliation against an employee, member of
Piigc 57 of 63
{ 'i\'il ( I D p i II i I I t - r . I l l p i n V l i l t - I I I
1 the medical staff, or any other health care worker of the facility, if responsible staff at the facility
2 or the entity that owns or operates the facility had knowledge of the actions, participation, or
3 cooperation of the person responsible for any acts described in paragraph ( I ) of subdivision (b),
4 and the discriminatory action occurs within 120 days of the filing of the grievance or complaint
5 by the employee, member of the medical staff or any other health care worker of the facility"
6 141. § 1278.5(d)(2) provides "...For purposes of this section, discriminatory treatment
7 of an employee...includes, but is not limited to, discharge, demotion, suspension, or any
8 unfavorable changes in, or breach o f the terms or conditions of a contract, employment, or
9 privileges of the employee."
10 142. Defendants, and each of them, were well aware of plaintiffs disclosures
I I concerning the deficiencies and problems w i t h i n the H V A C P l u m b i n g Shop as w e l l as the
12 function and operation of the Metasys alarm monitoring system. Each disclosure by plaintiff
13 related to and concerned matters that directly impacted, or foreseeably would impact, the safe

15 143. Each retaliatory action occurred, or, started and thereafter continued, or had its
16 roots in actions begun, within 120 days of plaintiff notifying and/or complaining to the
17 defendants, and each of them.
IS 144. P l a i n t i f f is entitled to all damages authorized and recoverable under Health &
19 Safety Code § 1278.5.

20 WHEREFORE Plaintiff prays for judgment as hereinafter set forth.
21 COMES NOW Plaintiff and for a Sixth Cause of Action, alleges against Defendants,
22 THE REGENTS OF THE UNIVERSITY OF CALIFORNIA, and DOES 41 through 50, as
23 follows:
24 IX. SIXTH CAUSE OF ACTION
[BREACH OF WRITTEN CONTRACT)
25
26 145. Plaintiff refers to the allegations contained in paragraphs, including subparagraphs, I

28 146. The contract between plaintiff and defendant is, and was at all relevant times, a written
58 of 63
( .'^^'il < III plii i II I - lil i t i p i d v i n e It I
1 contract. The written contract is attached to this complaint as Exhibit 1. Plaintiff hereby incorporates
2 into this complaint each term, condition, and paragraph of the contract as required by law. Pursuant to
3 the contract, defendant promised plaintiff an exempt position inside the HVAC Plumbing Shop with a
4 title of Development Engineer. Plaintiff accepted the position under the agreement and was installed
5 at the location with PUTT^lEY as his supervisor and WITCHER his manager.
6 147. At some point, currently unknown to plaintiff, UC DAVIS agreed, allowed, and/or
7 ratified DANILIUC as plaintiffs supervisor even though DANILIUC had the same or lower
8 classification accepted by plaintiff under the contract.
9 148. According to the agreement, plaintiff nor UC DAVIS were to disparage each other.
10 Plaintiff at all times expressed his good faith beliefs of the truth. However, CHILCOTT in an email
I 1 disparaged plaintiff creating the impression plaintiff was a problem, when in reality plaintiff was a
12 valuable employee, who had the best interests of the hospital always in mind, and was the victim of an
13 outrageous but actual coordinated effort to cause him emotional distress.
14 149. UC DAVIS, by and through its employees, agents, and officers, kept plaintiffout of the
15 workplace for no apparent reason. Defendant placed plaintiff on Investigatory Leaves, Administrative
16 Leaves, yet the evidence shows, beyond a shadow of a doubt, UC DAVIS was intentionally keeping
17 plaintiff out of the work location promised in the contract, and, waiting to find a pretext basis to
IS terminate plaintiff
19 150. UC DAVIS promised and plaintiff accepted an exempt position. However, plaintiffs
20 job duties did not change in any appreciable manner from his position as a non-exempt employee. In
21 addition, inserting DANILIUC as plaintiffs supervisor extinguished any appearance or actual

22 discretion or other characteristics of an exempt position.
23 150a. The written agreement contains an implied covenant of good faith and fair dealing,
24 or, an understanding that neither party will do anything unlawful and/or take action that
25 undermines and/or deprives plaintiff of one or more o f the benefit o f the bargain. Further, that,
26 provided plaintiff performed his duties in a manner that met or exceeded expectations, he would
27 be entitled to work and remain on the job until his retirement age. Further, that defendants, and
28 each of them, could terminate plaintiffs employment only with just cause.
Pane 59 of 63
( . ' i t ' t l ( ' n n i p 111 i II I -1'~ i i t p l i i v i i i c i t
1 150b. Defendants, and each of them, breached the contract by subjecting plaintiff to a
2 hostile work environment, keeping plaintiff away from the workplace, retaliation against plaintiff,
3 and terminating his employment.
4 151. The aforementioned acts constitute material breaches of the contract.
5 152. Plaintiff seeks and is entitled to all special and consequential damages as allowed by
6 law, including but not limited to lost-income, hourly wages for the missed lunch and break time plaintiff
7 would have enjoyed as a non-exempt employee. The contract provides for and plaintiff seeks costs as
8 well as attorney fees.
10 COMES NOW Plaintiff, and for a Seventh Cause of Action, alleges against Defendants,
12 follows:
13 X. SEVENTH CAUSE OF ACTION
[DFEH/LABOR CODE (Age Discrimination, Failure of Interactive Process, Medical
I Discrimination, Retaliadon, wage and hour)]
16 through 152, inclusive, and incorporates each by reference as though fully set forth at length herein
17 154. The contract provision attempting to set plaintiffs job as an exempt position is void as
IS against public policy, or, voidable as a direct result of defendants' failure to provide a truly e.vempt
19 position.
20 155. Defendants, and each of them, misled and lied to plaintiff and kept the tmth from
21 plaintiff concerning the true nature of his position as well as his rights under the law. Regardless,
22 plaintiff filed a DFEH complaint and received a Right to Sue Letter.
23 156. Plaintiffs position was not an exempt position. Plaintiffs duties as alleged herein were
24 substantially the same before the contract and after the contract.
25 157. With respect to wage and hour. Plaintiff seeks damages at the rate of $70,000.00 per
26 year, divided by 50 weeks, divided by 40 hours, multiple by 1.5 hours per day, multiple by 5 days per
27 week, multiple by 50 weeks per year, multiple by 5.5 years, equals $103,125.00, plus all treble or
28 punitive damages allowed by law.
I'use 60 of 63
( ^ i \ i l d ) i n p l < L i i i l - r . i i i p l d y i i i f 111
1 157a. Plaintiff was over-40 years old when defendants undertook their coordinated
2 assault on plaintiffs right to work. Plaintiffs protected activities and disclosures were also a
3 substantial factor in defendants' harassment, discrimination, and retaliation. Defendants, and
4 each of them, knowingly and intentionally denied plaintiff the benefit of the good faith interactive
5 process mandated by law, even though plaintiff made several attempts for defendants to reverse
6 their abhorrent behavior. Plaintiff was a quadruple bypass surgery survivor and taking
7 approximately 12 medications during the time defendants committed their acts described herein.
8 UC DAVIS, as part of a plan to hand plaintiff another Notice of Investigatory Leave upon his
9 return for work on May 31, 2012, assembled a crisis team, which demonstrates that UC DAVIS
10 knew, believed, and/or intended their actions would harm plaintiff, and potentially other innocent
11 people, but that did not stop them
12 158. Plaintiff seeks all damages, including costs and attomey fees as allowed by law.
14 COMES NOW Plaintiff and for an Eighth Cause of Action, alleges against Defendants,
16 follows:
17 XI. EIGHTH CAUSE OF ACTION
^^ [RESCISSION-UNLAWFUL CONTRACT]
20 through 158, inclusive, and incorporates each by reference as though fully set forth at length herein
21 160. Plaintiffs acceptance of the "exempt" classification for the job title taken
22 pursuant to The Settlement Agreement was a material aspect of the contract. An employer cannot
23 contract around Labor Laws with respect to wages, hours, meals, and breaks without running
24 afoul of the law and voiding the contract.
25 161. The contract is void as against public policy, and, the subject matter of the contract
26 is unlawful.
27 162. Defendant knew, or should have known, at the time the parties signed the contract
28 that the contract was void. Further, defendants knew, or should have known, that plaintiff relied
I'ai;*; 61 of 63
(.'i%'it Co nip I.I i ill -1~ iiiplf »y m r n t
1 on defendants to believe the contract was valid and enforceable. Defendants, to the present time,
2 have misled plaintiff into believing the contract was valid and enforceable.
3 163. In or about May 2014, plaintiff discovered the truth, that the contract was void as
4 against public policy and unlawful subject matter.
5 164. Defendants' are estopped to assert any technical defense in light of the actions
6 and omissions described herein.
7 165. As a direct and proximate result of the rescission of the contract, plaintiff has
8 been damaged in an amount equal to his hourly wage multiplied by the number of hours of lunch
9 and breaks he missed.

10 WHEREFORE, Plaintiff prays for Judgment against Defendants, and each of them, as follows:
11 1. for general and compensatory damages according to proof;
12 2. For lost salary, both front and back pay, bonuses, benefits and any other benefits to
13 which Plaintiff would have been entitled to by reason of his employment with Defendant UC
14 REGENTS, according to proof;

15 3. Punitive and exemplary damages against Individual Defendants;
16 4. Damages and attorney fees as allowed under the Labor Code;
17 5. for prejudgment interest at the maximum rate allowed by law;
I8 7. for costs o f suit incurred herein;
19 8. Damages for whistleblower retaliation under Govemment Code 8547 including

20 punitive damages against all Defendants, and Attorney's fees;
21 9. Breach of contract damages, including costs and attomey fees;

22 ///
23 ///
24 ///
25 ///
26 ///
27 ///
28 ///
I'jige 62 of 63
(!i%'il < '<» i n p h i i l i t - I ^ i n p l o > i n n i t
3 11. Rescission of the contract and for such other and further relief as the Court deems
4 jijst and proper.
5
6 DATED: September 2, 2014 La>y Ofllce of Douglas E . Stein
7
8 By:
DOUGLAS E , STEIN
9 Attbrriey for Plaintiff
JAROSLAW WASZCZUK
10
11
12
13
14
15
16
17
IS
19
20
21
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Page 63 of 63
(7ivil C o m p l » i nt-IHiiipInyincnt
1 P O R T E R I S C O T T >
Lindsay A. Goulding, SBN 227195 FlLED/ES^DSIRSED
Sacramento, Califomia 95825 MAY 1 h 2021
4 TEL: 916.929.1481
FAX: 916.927.3706 By: S. Cade
5
6 Attomey for Defendant
REGENTS OF THE UNIVERSITY OF CALIFORNIA,
7 MICHAEL BOYD, STEPHEN CHILCOTT, DORIN DANILIUC, DANESHA NICHOLS,
CINDY OROPEZA, PATRICK PUTNEY, ANN MADDEN RICE
8 BRENT SEIFERT, and CHARLES WITCHER
9
10
12
o
o
P ,2 00 — ^
t-H 0^ " / I oo O 14 MEMORANDUM OF POINTS AND
o a> 2 P; Plaintiff,
> w ON 0>
15 AUTHORITIES IN SUPPORT OF
DEFENDANT'S MOTION FOR
UJ 16 SUMMARY JUDGMENT OR, IN THE
3 (/3
1 s- THE REGENTS OF THE UNIVERSITY OF ALTERNATIVE, SUMMARY
17 ADJUDICATION
o CALIFORNIA, UNIVERSITY OF
UC DAVIS MEDICAL CENTER, UC DATE: August 4, 2021
19 DAVIS, ANN MADDEN RICE, MIKE TIME: 1:30 p.m.
BOYD, STEPHEN CHILCOTT, CHARLES DEPT: 53
20
WITCHER, DANESHA NICHOLS, CINDY Reservation No.: 2563128
PUTNEY, DORIN DANILIUC, and Does 1 Complaint Filed: December 4, 2013
22 through 50, inclusive. Amended Complaint Filed: June 16, 2014
23
Defendants.
24
25
26
27
28
{0241338S.DOCX}
MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF DEFENDANT'S MOTION FOR
SUMMARY JUDGMENT OR, IN THE ALTERNATIVE, SUMMARY ADJUDICATION
1 TABLE OF CONTENTS
2 Page
3
4 L INTRODUCTION 1
5 IL PROCEDURAL STATUS 2
6
IIL FACTUAL BACKGROUND 5
7
A. General Backgroimd 5
8 B. Plaintiff Suspended for Inappropriate Behavior 5
9 C. August 2011 Investigation Confirms PlaintifF Engaged in Intimidating and
Discriminatory Conduct 6
10 D. September 2011 Investigation Confirms Additional Discriminatory and
Intimidating Conduct by Plaintiff 7
11 E. PlaintifTs Termination 8
12
IV. PLAINTIFF'S HARASSMENT CLAIM (THIRD CAUSE OF ACTION) FAILS
13 BECAUSE PLAINTIFF ADMITS HE WAS NOT HARASSED AND
— »o
oo O PERSONNEL MANAGEMENT DECISIONS DO NOT QUALIFY AS
14
<^ M& HARASSING ACTS 9
CN
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.•S (U a! o\ A. Issue 1: Plaintiff Admits He was Not Harassed Based on a Protected Status 9
a; J
w <
>< 16 B. Issue 2: Personnel Management Activities Do Not Qualify as Actionable
O
OH
3 Harassment 9
o 17
C. Issue 3: Defendant Had Legitimate Reasons for Taking the Actions it Took 10
18
V. PLAINTIFF'S CLAIM FOR FAILURE TO PREVENT HARASSMENT,
19 DISCRMINIATION, AND RETALIATION (THIRD CAUSE OF ACTION)
FAILS BECAUSE THERE WAS NO UNDERLYING UNLAWFUL CONDUCT ... 11
20
21 A. Issue 4: Plaintiffs Failure-to-Prevent Harassment Cause of Action Fails
Because He Cannot Prove an Underlying Claim of Harassment 11
22 B. Issue 5: Plaintiffs Failure-to-Prevent Discrimination Cause of Action Fails
23 Because He Carmot Prove an Underling Claim of Discrimination 11
1. Plaintiff Cannot Establish a Prima Facie Case of Discrimination 11
24 2. The Regents Had a Legitimate Non-Discriminatory Reason for Disciplining
Plaintiff and Terminating His Employment - Admitted Policy Violations 12
25 3. Plaintiff Cannot Show Pretext 13
26 C. Issue 6: Plaintiffs Failure-to-Prevent Retaliation Cause of Action Fails Because
He Cannot Prove an Underling Claim of Retaliation 13
27 1. Plaintiff Cannot Prove a Prima Facie Case of Retaliation 13
2. The Regents Had Legitimate, Non-Retaliatory Reasons for the Adverse Actions
28 and Plaintiff Cannot Prove Pretext 13
{0241338S.DOCX} 1
D. Issue 7: Plaintiffs Failure-to-Prevent Cause of Action Fails Because the University
1
Took Reasonable Steps to Prevent Harassment, Discrimination and Retaliation 14
2
VI. PLAINTIFF'S RETALIATION CLAIMS UNDER GOVERNMENT CODE§ 8547
3 AND HEALTH & SAFETYCODE § 1278.5 FAIL BECAUSE HE ADMITS
4 THAT HIS DISCIPLINE AND TERMINATION WERE BASED ON HIS
WRONGFUL CONDUCT 15
5
A. Issue 8: PlaintifF Cannot Establish a Prima Facie Case of Retaliation Under
6 Govemment Code § 8547 or Health & Safety Code § 1278.5 15
7 1. Plaintiff Cannot Establish a Prima Facie Case of Retaliation Under Govemment
Code § 8547 15
8 2. Plaintiff Cannot Establish a Prima Facie Case of Retaliation Under Health &
Safety Code § 1278.5 16
9 i. PlaintifF Did not Work at a Protected Health Facility 16
10 ii. The Regents Did not Take any Adverse Actions Against PlaintifF
Because of Protected Activity 16
11 B. Issue 9: The University had Legitimate, Non-Retaliatory Reasons for the Adverse
Actions Taken Against PlaintifF 17
12
o
o
C. Issue 10: Plaintiff Cannot Prove Pretext 17
13
5
oo — vo VII. PLAINTIFF CANNOT RECOVER ON HIS SEVENTH CAUSE OF ACTION
O oo O
J:;
14 FOR "MISCLASSIFICATION" 18
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A. Issue 11: "Misclassification" is Not a Cause of Action 18
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16 B. Issue 12: Plaintiff Was Properly Classified as Exempt 18
oil S- u. C. Issue 13: Plaintiff Executed A Settlement Agreement for Claims Related to his
PH c ta 17 Classification 19
o
18 D. Issue 14: Plaintiffis Estopped from Having the Settlement Agreement Declared
Unenforceable Because He Accepted a Tangible Benefit Under the Agreement 21
19
VIII. PLAINTIFF'S SIXTH CAUSE OF ACTION FOR BREACH OF WRITTEN
20 CONTRACT FAILS BECAUSE HE CANNOT PROVE A PRIMA FACIE CASE
21 AND HIS EMPLOYMENT IS STATUTORY 22
22 A. Issue 15: Plaintiff Cannot Establish a Prima Facie Case for Breach of Contract 22
1. Placement on Investigative Leave 23
23 2. Exempt Position 23
24 3. Non-Disparagement Provision 23
i. The non-disparagement clause specifically excludes the investigation issue 25
25 ii. PlaintifF admitted to engaging in the misconduct that Formed the basis
oF the disciplinary action against him 26
26 iii. The University is immunefromliability under Govemment Code §§ 820.2
27 and 821.6 27
iv. Communications related to litigation are absolutely privileged under
28 Civil Code §47 28
4. Implied Covenant oF Good Faith & Fair Dealing 29
{0241338S.DOCX} U ,
B. Issue 16: PlaintiFf s Breach oFContract Claim Must Further Fail Because Public
1
Employment in CaliFomia is Heal by Statute Rather than Contract and ThereFore
2 Contract-base Claims Cannot be Asserted by PlaintiFF 30
3 IX. PLAINTIFF'S EIGHTH CAUSE OF ACTION FOR RESCISSION, MUST FAIL
4 BECAUSE RESCISSION IS NOT A STANDALONE CLAIM AND CONTRACT-
BASED EMPLOYMENT CLAIMS CANNOT BE ASSERTED BY PUBLIC
5 EMPLOYEES 31
6 A. Issue 17: Rescission is Not a Cause oF Action 31
7 B. Issue 18: Contract-Based Employment Claims are Not Viable Against
University 31
8 C. Issue 19: PlaintiFf s Rescission Argument is Contrary to the Terms oF the
Agreement 32
9
10 X. CONCLUSION 32
11
12
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13
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14
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15
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18
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21
22
23
24
25
26
27
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{02413385.DOCX} 111
T A B L E OF AUTHORITIES
CASES Page No.
Acoustics, Inc. v. Trepte Construction Co.,

(1971) 14 Cal. App. 3d 887 22
Andrews v. Mobile Aire Estates,
(2005) 125 Cal.App.4th 578 29

Armin v. Riverside Community Hospital,
(2016)5Cal.App.5th810 17
10 Beck Development Co. v. Southern Pacific Transportation Co.,
11 (1996) 44 Cal. App. 4th 1160 22
12 Blix Street Records, Inc. v. Cassidy,

o
o
fN
13 (2010) 191 Cal.App.4th 39 21
—
P ,2 =0 oo vo
o
E-H GO « ^
— rn 14 Boeken v. Philip Morris USA, Inc.,
Îs Ov
CN
0\
vd
I-^
rvi
Ov
vd 15 (2010) 48 Cal.4th788 31
Oi < 6 Ov Ov
16 Caldera v. Department of Corrections and Rehabilitation,

2-11 H tL.
(2018)25 Cal.App.5th 31 9
O
17
California Correctional Peace Officers' Assn. v. State of California,
18
(2010) 188 Cal.App.4th 646 18
19
City of Hollister v. Monterey Ins. Co.,
20
(2008) 165 Cal.App.4th 455 21
21
Comunale v. Trades & General Ins. Co.,
22
(1958) 50 Cal. 2d 654 29
23
Fahlen v. Sutter Central Valley Hospitals,
24
(2014) 58 Cal.4th655 16
25
Flait V. North American Watch Corp.,
26
(1992) 3 Cal.App.4th 467 13
27
///
28
{0241338S.DOCX} IV
1 Guz V. Bechtel National Inc.,
2 (2000) 24 Cal.4th317 12
3 Jadwin v. County of Kern,
4 610 F.Supp.2d 1129 (E.D. Cal. 2009) 16
5 Jones V. Department of Corrections & Rehabilitation,
6 (2007) 152 Cal.App.4th 1367 9
7 Kelley v. The Conco Companies,
8 (2011) 196 Cal.App.4th 19l' 11
9 Kemmerer v. County of Fresno,
10 (1988) 200 Cal.App.3d 1426 27
11 Kim V. Regents of University of California,
12 (2000) 80 Cal.App.4th 160 30
13 Lachtman v. Regents of the University of California,
00 —
oo
O a ov ^ 14 (2007) 158 Cal.App.4th 187 30, 31
on § < ov
rv rJ
U ov
— > O ^
15 Marden v. Bailard,
c Ov Ov
o .> ^ 16 (1954) 124 Cal.App.2d 458 31

OH C
tu
D
17 Mendiondo v. Centinela Hosp. Medical Center,
18 521 F.3d 1097 (9th Cir. 2008) 16
19 Miklosy v. Regents of University of California,

20 (2008) 44 Cal. 4th 876 25
21 Miller v. State of Califomia,

22 (1977) 18Cal.3d 808 30
23 Nakash v. Superior Court,

24 (1987) 196 Cal.App.3d 59 (citing Civ. Code § 1689.) 31
25 Nazirv. United Airlines, Inc.,

26 (2009) 178 Cal. App. 4th 243 13
27 Raderv. Thrasher,
28 e t a l (1972) 22 Cal. App. 3d 883 28
{02413385.DOCX} V
Regents of University of California v. City of Santa Monica,
(1978) 77 Cal.App.3d 130 30

Reno V. Baird,
(1998) 18Cal.4th640 10
5 Roby V. McKesson Corp.,
6 (2009) 47 Cal.4th686 10
7 Ross V. San Francisco Bay Area Rapid Transit District,
8 (2007) 146 Cal.App.4th 1507 27
9 Scotch V. Art Institute of California,
10 (2009) 173 Cal.App.4th 986 12
11 Serri v. Santa Clara University,
12 (2014) 226 Cal.App.4th 830 14,17
o
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CN
13 Slatkin v. Univ. of Redlands,
H (/3 5i — vo
oo o
J:; 14 (2001) 88 Cal.App.4th 1147 12
0^
CN
ti
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Ov o v , ^
ptj <: o' ^ ^ i Wang V. Heck,
ov ov
Sti ui^ 16 (2012) 203 Cal.App.4th 677 28, 29
211 17 Wills V. Superior Court,
3 c/2
o
18 (2011) 195 Cal.App.4th 143 12
19 Yanowitz v. L'Oreal USA, Inc.,
20 (2005) 36Cal.4th 1028 13, 14
21 Young V. Flickinger,
22 (1925) 75 Cal.App. 171 31
23 Zelasko-Barrett v. Brayton-Purcell, LLP,
24 (2011) 198 Cal.App.4th 582 18
25 STATUTES
26
27 Cal. Gov. Code § 815.2 27
28 Civil Code § 3300 , 22

Civil Code § 47 27
{0241338S.DOCX} vj
Civil Code § 47, subdivision 2 28
Govemment Code, § 8547.8(d)-(e) 17
3 Govemment Code § 8547.2(c), (e) 15
4 Govemment Code §§ 820.2 and 821.6 26, 27
5 Govemment Code §811.2 18
6 Govemment Code§ 8547 passim
7 Health & SaFety Code § 1250 16
8 Health & SaFety Code § 1278.5(b) 16
9 Health & SaFety Code § 1278.5 passim
10 REGULATIONS
11
Cal. Code Regs. tit. 22, § 1256-1 28
12
o
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13 Cal.Code Regs., tit. 8, § 11040, subd. 1(B)
CN 18, 20
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14 OTHER AUTHORITIES
o ov
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OV O ; ^ ,
vo ^ 1J CACI 303 22
Ov Ov
2-1 i 16 CACI 4601 '. 15

o 17 CACI 4606 16
18
19
20
21
22
23
24
25
26
27
28
{02413385.DOCX} Vll
INTRODUCTION
Pro per PlaintiFf JAROSLAW WASZCZUK brings this employment action against THE
REGENTS OF THE UNIVERSITY OF CALIFORNIA (hereinafter "UNIVERSITY") claiming he
was terminated for improper reasons. In fact, the undisputed evidence, based on Plaintiffs own
admissions, is that Plaintiff was terminated because of repeated acts of discriminatory, intimidating,
and hateful conduct that PlaintifF directed at his co-workers.
The Following seven causes oF action are the only ones remaining from the operative Second
Amended Complaint ("SAC")': (a) Third Cause oF Action For harassment and Failure to prevent
10 harassment, discrimination, and retaliation in violation oF the Fair Employment and Housing Act
11 (FEHA)^; (b) Fourth Cause oF Action For whistleblower/unlawful retaliation in violation oF
o
12 Govemment Code § 8547 et. seq. (c) Fifth Cause oF Action For retaliation under Health and SaFety
o
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13 Code § 1278.5'*; (d) Sixth Cause oF Action For breach oF written contract; (e) Seventh Cause oF
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14 Action For wage and hour misclassification; and (f) Eighth Cause oF Action For rescission-unlawfiil
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15 contract.
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ill 16 Plaintiffs Third Cause of Action, for harassment and failure to prevent harassment,
o
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17 discrimination and retaliation fails because the undisputed evidence is that there was no underlying
m
18 harassment, discrimination or retaliation. Plaintiffs harassment claim is based on alleged
19 investigatory and disciplinary actions against him. These are personnel management activities
20 which, as a matter of law, do not constitute "harassing" acts. There was no underlying discrimination
21 or retaliation because the undisputed evidence, based on Plaintiffs own admissions, is that he was
22
' The SAC's First Cause of Action for intentional infliction of emotional distress and Second Cause of Action for
23 tortious interference with economic advantage are only pled against a group of fonner individual Defendants. These
Defendants were all dismissed from the matter and/or such causes of action were adjudicated in their favor pursuant to
24 a Special Motion to Strike. Therefore, they are not addressed in this Motion.
^ Plaintiff improperly pled this as a single cause of action. The cause of action is pled against the UNIVERSITY and
25 the former individual Defendants. As discussed supra, the individual Defendants were all dismissed and/or this cause
of action was adjudicated in their favor pursuant to the Special Motion to Strike.
26 ' See fn.2, supra, (same as to the Fourth Cause of Action). Moreover, the Fourth Cause of Action for
whistleblower/unlawful retaliation in violation of Govemment Code § 8547 is misidentified in the body of the SAC as
27 the "Third Cause of Action" although it is labeled as the "Fourth Cause of Action" in the heading related to the claim.
This claim will be referred to herein as the "Fourth Cause of Action".
28 The SAC's Fifth Cause of Action for Health and Safety Code 1278.5 retaliation is misidentified in the body of the
SAC as the "Sixth Cause of Action" although it is labeled as the "Fifth Cause of Action" in the heading related to the
claim. This claim will be referred to herein as the "Fifth Cause of Action".
{02413385.DOCX} 1
disciplined and ultimately terminated for repeated violations of the UNIVERSITY'S policies against
discriminatory and hatefiil conduct.
Plaintiffs Fourth and Fifth Causes oF Action, For retaliation under Govemment Code § 8547
and Health and SaFety Code § 1278.5, Fail For the same reason. The undisputed evidence based on
Plaintiffs own admissions is that PlaintifF was terminated For legitimate, non-retaliatory reasons.
The Health and SaFety Code § 1278.5 claim also Fails because the statute only applies to "health
Facilities" and PlaintifF did not work at such a Facility.
Plaintiffs Sixth Cause oF Action is For breach oF contract. Specifically, PlaintiFF claims the
UNIVERSITY breached terms oF a Settlement Agreement the parties previously reached by
10 disparaging him, intentionally keeping him out oF the work location the Agreement promised him,
11 maintaining his non-exempt job duties when he had been promised an exempt position, and violating
12 the covenant oF good Faith and Fair dealing. This claim Fails because PlaintifF cannot establish the
o
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13 prima Facie elements oF a breach oF contract claim and, as a UNIVERSITY employee. Plaintiffs
.5 oo — s
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14 employment was statutory and not by contract.
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vo vo 15 Plaintiffs Seventh Cause oF Action alleges PlaintifF was misclassified as an exempt
C ov Ov
^ 16 employee. This cause oF action Fails because the statutes PlaintiFF claims were violated do not apply
tl.
o 17 to public employees and Plaintiff was properly classified as exempt. Even if he was not properly
18 classified, the parties already executed a Settlement Agreement in which PlaintifF released that
19 claim.
20 Lastly, Plaintiffs Eighth Cause of Action is for "rescission." That, however, is a remedy,
21 not a cause of action.

22 For these reasons, the UNIVERSITY respectfully requests summary judgment in its favor.
23 In the event the Court finds any of the causes of action viable, the UNIVERSITY respectfiilly
24 requests summary adjudication of all other causes of action.
25 II.
26 PROCEDURAL STATUS
27 PlaintifF filed his initial Complaint in this matter on December 4, 2013. (Declaration oF
28 Lindsay A. Goulding in support oFDeFendant's Motion For Summary Judgment or, in the altemative,
{02413385.DOCX} 2
1 Summary Adjudication ("Goulding Decl."), TI 2.) He thereafter amended the Complaint two times.
2 The SAC is the operative pleading. (Goulding Decl., 12; Exhibit ("Exh.") A.)
3 PlaintifFfiledthis action against the UNFVERSITY as well as individual DeFendants MIKE
4 BOYD, STEPHEN CHILCOTT, DANESHA NICHOLS, CINDY OROPEZA, BRENT SEIFERT,
5 ANN MADDEN RICE, CHARLES WITCHER, PATRICK PUTNEY and DORIN DANILIUC.
6 BOYD, CHILCOTT, NICHOLS, OROPEZA and SEIFERT (herein "anti-SLAPP DeFendants")
7 filed a Special Motion to Strike the causes oFaction pled against them. (Goulding Deck, ^3.) The
8 Court granted that Motion. (Id.) PlaintifF then dismissed the Four remaining individual DeFendants-
9 RICE, WITCHER, PUTNEY, and DANILIUC. (Id.) As a result, the UNFVERSITY is the only
10 DeFendant remaining. On April 25, 2018, the UNFVERSITY served Plaintiff with Requests for
11 Admission (Set One). (Goulding Deck, 4; Exh C, Requests for Admission.) PlaintifF did not
12 respond to those Requests by the deadline. (Id. at ^ 5.) The UNIVERSITY subsequently filed a
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13 discovery motion seeking to have the Requests For Admission deemed admitted. (Id.) The Court
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15 PlaintifF. (Id.) As a result, PlaintifF has admitted the Following:
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(- tl. • PlaintifF agreed to be an exempt employee; (RFA #1; Goulding Decl., ^ 6, Exhs. C
C CQ
3 t/3 17 and D (UNIVERSITY'S Request For Admissions, Set One and Court's final mling
o
on UNIVERSITY'S Motion to deem Request For Admissions, Set One, admitted.)
18 • Plaintiff s agreement to be an exempt employee was part of a Settlement Agreement;
19 (RFA #2; Goulding Deck, 1 6, Exhs. C and D (UNIVERSITY'S Request For
Admissions, Set One and Court's final ruling on UNIVERSITY'S Motion to deem
20 Request For Admissions, Set One, admitted.)
• PlaintifF agreed to be classified as an exempt employee per the Settlement Agreement
21 Plaintiff executed on January 30, 2009; (RFA #8; Goulding Decl., H 6, Exhs. C and
22 D (UNIVERSITY'S Request For Admissions, Set One and Court's final ruling on
UNIVERSITY'S Motion to deem Request For Admissions, Set One, admitted.)
23 • Plaintiff received a salary increase as part of the Settlement Agreement PlaintifF
executed on January 30, 2009; (RFA #9; Goulding Deck, K 6, Exhs. C and D
24 (UNIVERSITY'S Request for Admissions, Set One and Court's final ruling on
25 UNIVERSITY'S Motion to deem Request for Admissions, Set One, admitted.)
• Plaintiff agreed to a permanent assignment in the HVAC/Plumbing Shop as part of
26 the Settlement Agreement he executed on January 30, 2009; (RFA #6; Goulding
27 Deck, II 6, Exhs. C and D (UNIVERSITY'S Request for Admissions, Set One and
Court's final ruling on UNIVERSITY'S Motion to deem Request for Admissions,
28 Set One, admitted.)
• PlaintifF received $13,500 pursuant to the Settlement Agreement he executed on
{02413385.DOCX} 3
January 30, 2009; (RFA #7; Goulding Deck, H 6, Exhs. C and D (UNIVERSITY'S
1 Request for Admissions, Set One and Court's final mling on UNIVERSITY'S
2 Motion to deem Request for Admissions, Set One, admitted.)
The University found in March 2007 that Plaintiff had committed violations of the
3 UC Davis Health System Policy 1616, and the Principals of Community, and that
Plaintiffs conduct created a hostile work environment in the Cenfral Plant; (RFA #3;
4
Goulding Deck, ^ 6, Exhs. C and D (UNIVERSITY'S Request For Admissions, Set
5 One and Court's final ruling on UNIVERSITY'S Motion to deem Request For
Admissions, Set One, admitted.)
6 PlaintifF made derogatory comments in the workplace about Jewish people, African-
7 Americans, Hispanics, and/or homosexuals; (RFA #4; Goulding Deck, ^ 6, Exhs. C
and D (UNIVERSITY'S Request For Admissions, Set One and Court's final mling
8 on U N I V E R S I T Y ' S Motion to deem Request For Admissions, Set One, admitted.)
On April 16, 2007, PlaintiFF was notified that he would be suspended and reassigned
9 based on thefindingsthat PlaintifF violated the UC Davis Health System Policy 1616,
10 the Principals oF Community, and created a hostile work environment in the Cenfral
Plant; (RFA #5; Goulding Deck, 1 6, Exhs. C and D (UNIVERSITY'S Request For
11 Admissions, Set One and Court's final ruling on UNIVERSITY'S Motion to deem
Request For Admissions, Set One, admitted.)
12
O
o In April 2011, PlaintifF missed an alarm in Metasys, the building automation system,
n
(U 13 that had been signaled since April 11, 2011; (RFA #10; Goulding Deck, ^ 6, Exhs.
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(/3 oo O C and D (UNIVERSITY'S Request For Admissions, Set One and Court's final ruling
o — ^ 14 on UNIVERSITY'S Motion to deem Request For Admissions, Set One, admitted.)
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W c 5^ o^ related to violence and hate incidents in the workplace and ethnically discriminatory
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o I H tL. for Admissions, Set One and Court's final mling on UNIVERSITY'S Motion to
17 deem Request for Admissions, Set One, admitted.)
18 In Febmary 2012, the University found that Plaintiff was insubordinate by continuing
to contact witnesses during an investigation after being instmcted not to do so; (RFA
19 #12; Goulding Deck, H 6, Exhs. C and D (UNIVERSITY'S Request for Admissions,
20 Set One and Court's final mling on UNIVERSITY'S Motion to deem Request for
21 On April 13, 2012, Plaintiff was given notice that he was being suspended based on
thefindingsissued in Febmary 2012; (RFA #13; Goulding Deck, ^ 6, Exhs. C and D
22 (UNIVERSITY'S Request for Admissions, Set One and Court's final ruling on
23 UNIVERSITY'S Motion to deem Request for Admissions, Set One, admitted.)
On April 27, 2012, PlaintifF sent an email to Danesha Nichols titled "Welcome to
24 Romania."; (RFA #14; Goulding Deck, ^ 6, Exhs. C and D (UNIVERSITY'S
Request For Admissions, Set One and Court's final mling on UNIVERSITY'S
25 Motion to deem Request For Admissions, Set One, admitted.)
26 The email PlaintifF sent on April 27, 2012 to Danesha Nichols was as slide-show
containing photographs depicting people openly deFecating in the street, and a couple
27 having sex in a car with a young child in the backseat watching; (RFA #15; Goulding
Deck, 1 6, Exhs. C and D (UNIVERSITY'S Request For Admissions, Set One and
28 Court's final ruling on UNIVERSITY'S Motion to deem Request For Admissions,
{02413385.DOCX}
Set One, admitted.)
• In September 2012, PlaintifF was given a Notice oF Intent to Dismiss; (RFA #17;
Goulding Deck, H 6, Exhs. C and D (UNIVERSITY'S Request For Admissions, Set
One and Court's final ruling on UNFVERSITY's Motion to deem Request For
o The Notice oF Intent to Dismiss PlaintifF was based on the findings issued in
September 2012; (RFA #18; Goulding Deck, TI 6, Exhs. C and D (UNIVERSITY'S
Motion to deem Request For Admissions, Set One, admitted.)
• PlaintifF did not leam oF the alleged illegal power sales until after [PlaintiFf s]
termination. (RFA #19; Goulding Deck, \ 6, Exhs. C and D (UNFVERSITY's
Motion to deem Request For Admissions, Set One, admitted.) (See UMF Nos. 11-
17.)
HI.
10
FACTUAL BACKGROUND
11
A. General Background
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o The UNFVERSITY hired Plaintiff as a Power Plant Operator at the UC Davis Medical
rs
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Adjudication ("Witcher Decl."), ^ 2.) Plaintiffs primary duties involved operating the Metasys
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software program, which monitors certain infrastmcture systems for malfunctioning equipment,
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m such as refrigeration, elevators, and machinery. (Id.) PlaintifF worked in the Central Plant From
18
1999 until 2007. (M)
19
B. Plaintiff Suspended for Inappropriate Behavior
20
On April 16, 2007, PlaintifF received a 3-day disciplinary suspension, and his work location
21
was reassigned to the HVAC/Plumbing shop after an investigation confirmed that PlaintiFf violated
22
UC Davis Health System Policy 1616 and the Principals of Community by creating a hostile work
23
environment in the Central Plant. (UMF No. 1). Specifically, the discipline was based on the
24
investigative determination that PlaintifF commonly used intimidating and disrespectful language
25
when conversing with his co-workers; treated his supervisors with disrespect; and repeatedly made
26
derogatory comments about the race, religion, ethnic background, or other immutable characteristics
27
of his co-workers. (Id.)
28
PlaintifF grieved the disciplinary action. (Exh. A, SAC at TI 19; Exh. H at ^ 6.) The suspension
{0241338S.DOCX} 5
was upheld, but his reassignment was set aside at an appeal hearing in 2008. (Id. at Exh. 1 attached
to SAC, p. 1.) On January 30, 2009, Plaintiff and the UNFVERSITY executed a Settlement
Agreement in which PlaintifF agreed to a permanent assignment in the HVAC/Plumbing Shop.
(UMF No. 2). In retum, PlaintifF was placed in an Associate Development Engineer position. (Id.)
PlaintifF agreed that, as an Associate Development Engineer, he was correctly classified as an
exempt employee For minimum wage and overtime purposes. He also received $13,500 and a salary
increase as part oF the settlement. (UMF No. 3). PlaintifF further agreed to release the UNIVERSITY
from liability for any then-existing legal claims. (Exh. A, SAC ^ 20, Exh. 1 attached to SAC p. 3.)
Plaintiff began work in his new position in Febmary 2009. (Exh. A, SAC ^ 20; Exh. H at 7.)
10 C. August 2011 Investigation Confirms Plaintiff Engaged in Intimidating and
11 Discriminatory Conduct
12 In August 2011, the UNIVERSITY initiated an investigation into additional allegations oF
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13 misconduct levied against PlaintifF. (Id. at ^ 62) (UMF No. 4; Exh. S Investigative Report by
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3 c/3
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18 Assistant Supervisor DANILFUC on March 8,2011 by pointing his finger in DANILIUC's Face and
19 using proFanity. (UMF Nos. 4-5).
20 While investigating the aForementioned allegations, the UNIVERSITY also received
21 additional complaints that PlaintifF made discriminatory comments in the workplace. (UMF No. 4).
22 On or about September 1, 2011, the UNIVERSITY placed PlaintiFF on leave during the
23 pendency oF the investigation. (SAC at ^ 74; Witcher Decl. H 11.) PlaintiFf claims that while he was
24 on investigatory leave, his doctor then placed him on stress leave until January 2012. (SAC at TI
25 75.)
26 PlaintifF refused to participate in an interview as part oF the investigation in December 2011.
27 Thus, the UNIVERSITY extended his investigative leave further in order to complete the
28 investigation. (Id. at ^ 76.; Declaration of Gina Harwood ("Harwood Deck") ^ 5; Exh. U December
{02413385.DOCX} 6
SUMMARY JUDGMENT OR, ES THE ALTERNATIVE, SUMMARY ADJUDICATION
12, 2011 correspondence from Gina Harwood to PlaintifF.)
On Febmary 9, 2012, the UNIVERSITY issued a fmal investigative report sustaining the
following allegations against PlaintifF:
(1) He was dismptive and intimidating towards PUTNEY on May 5, 2011 in violation of
UNFVERSITY Policy 1616-Violence and Hate Incidents in the Workplace;
(2) He was dismptive and intimidating towards PUTNEY on April 21, 2011 when discussing
work performance issues in violation of UNIVERSITY Policy 1616-Violence and Hate
Incidents in the Workplace;
(3) He became dismptive and intimidating towards DANILIUC on March 8, 2011 by pointing
his finger in DANILIUC's Face and using proFanity in violation oF UNIVERSITY Policy
8 1616-Violence and Hate Incidents in the Workplace;
9 (4) He made discriminatory comments regarding several protected classes in the workplace in
' violation oFUNFVERSITY policy PPM Section 380-IS-StaFFComplaints oFDiscrimination;
10 (5) He interFered with the investigation by contacting witnesses and outside parties despite being
told to cease all such communications.
11 (Nichols Decl. H 6; Exh. S.)
12 On April 27, 2012, PlaintifF sent a document to UC Davis Health System Investigations
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2:5:; 14 against PlaintifF, as well as Plaintiffs own complaint oF retaliation. The document PlaintifF sent Ms.
ov ov ^ ^
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16 people openly deFecating in the street, and a couple having sex in a car with a young child in the
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17 backseat watching. (UMF No. 6).
18 PlaintifF was given a disciplinary 10-day suspension in May 2012 based on the
19 aForementioned findings of the investigation and his Failure to adhere to specific instmctions during
20 the investigation to refrain From sending emails to witnesses. (SAC at ^ 77; see also Witcher Deck
21 TI 11; Exh. M May 11, 2012 correspondence From Charles Witcher to PlaintifF regarding Notice oF
22 Intent to Suspend.) On May 31, 2012, Plaintiff was placed back on investigative leave after
23 retuming to work due to further discriminatory emails he sent. (SAC at ^ 79; Witcher Decl. at ^ 13;
24 Exh. N.)
25 D. September 2011 Investigation Confirms Additional Discriminatory and Intimidating
26 Conduct bv Plaintiff
27 A further investigation was conducted regarding additional allegations oF wrongfiil conduct
28 by PlaintiFf. Specifically, it was alleged that: (1) the April 27, 2012 emails Plaintiff sent to Ms.
{02413385.DOCX} 7
1 Nichols regarding the investigation report and disciplinary action, which included the slideshow
2 entitled "Welcome to Romania," were offensive and harassing; and (2) during the investigation into
3 these allegations. Plaintiff disseminated other email communications to coworkers and various
4 individuals throughout the University of Califomia system expressing his disagreement with the
investigation report and disciplinary action. It was alleged that Plaintiffs communications were
dismptive and discriminatory in nature; and abusive and harassing against PUTNEY and
7 DANILIUC (lOE, Exh. Y Oropeza Decl. 1| 4; Exh. W Seifert Decl. ^ 4; Exh. X, September 20,2012
8 investigation report.)
9 On September 20, 2012, UNFVERSITY investigators Cindy Oropeza and Brent Seifert
10 issued an investigative report sustaining the following allegations: (1) Plaintiffs email
11 communications regarding DANILIUC's national origin constitute dismptive and intimidating
12 behavior in violation of UNIVERSITY Policy 1616 - Violence and Hate Incidents in the Workplace;
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employees of Romanian descent were in violation of UNIVERSITY Policy PPM 380-15 - StafF
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Complaints oF Discrimination. (UMF No. 7).
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E. Plaintiffs Termination
o PlaintifF was given a Notice oFIntent to Dismiss on September 25, 2012. (UMF No. 8.) The
D</. 18 Notice oF Intent to Dismiss was based on the UNIVERSITY'S investigative findings issued in
17
19 September 2012. (Id.)
20 PlaintiFF challenged the proposed termination through the Skelly process, but the termination
21 was upheld, eFfective December 7, 2012. The termination letter made it clear that PlaintifF was
22 terminated For violating UNIVERSITY policy, including the Principles oFCommunity and policies
23 prohibiting discrimination and violence and hate incidents in the workplace, as detailed in the
24 September 2012 investigation findings. (See UMF Nos. 8-9). Plaintiff remained on investigatory
25 leave until the termination became effective. (SAC at T| 81.)
26 In March 2013, Plaintiff filed an intemal whistleblower retaliation complaint with the
27 UNFVERSITY alleging harassment and retaliation culminating in his termination. (SAC at ^ 97.)
28 (UMF No. 10).
{0241338S.DOCX} 8
IV.
PLAINTIFF'S HARASSMENT CLAIM (THIRD CAUSE OF ACTION) FAILS BECAUSE
PLAINTIFF ADMITS HE WAS NOT HARASSED AND PERSONNEL MANAGEMENT
DECISIONS DO NOT OUALIFY AS HARASSING ACTS
To prevail on his harassment claim. Plaintiff must prove: (1) he belongs to a protected class;
(2) he was subject to unwelcome harassment; (3) the harassment was based on his protected status;
(4) the harassment was sufficiently severe or pervasive to alter the terms and conditions of
employment and create an abusive working environment; and (5) respondeat superior. (Jones v.
Department of Corrections & Rehabilitation (2007) 152 Cal.App.4th 1367, 1377.) PlaintiFf cannot
10 satisfy multiple elements of his claim.
11 A. Issue 1: Plaintiff Admits He was Not Harassed Based on a Protected Status
12 PlaintifF pleads in his SAC that he was harassed based on his national origin/ancestry and
13 medical condition/disability. (SAC ^ 120). However, in responding to discovery regarding the basis
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ON
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a\ ON
16 because oF PlaintifF [^/c] mental or medical condition." (UMF No. 16; Exh. B Goulding Deck, ^ 7;
o1 S- t i .
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17 Exh. E Plaintiffs First Amended Response to DeFendant Regents oF the University oF CaliFomia
18 Special Interrogatories, Set One, Responses to Special Interrogatory Nos. 2 and 4.)
19 PlaintifF then went on in discovery to admit: "DeFendant did not harass PlaintifF." (Id.) PlaintifF
20 has not asserted harassment based on any other protected status. (See generally SAC) ThereFore,
21 based on Plaintiffs own admissions, his claim For harassment Fails because "DeFendant did not
22 harass PlaintiFf and any harassment that did occur was not based on any protected characteristic.
23 B. Issue 2: Personnel Management Activities Do Not Oualifv as Actionable Harassment
24 "The law prohibiting harassment is violated '[w]hen the workplace is permeated with
25 discriminatory intimidation, ridicule and insult that is 'sufficiently severe or pervasive to alter the
26 conditions oF the victim's employment and create an abusive working environment.'" (Caldera v.
27 Department of Corrections and Rehabilitation (2018) 25 Cal.App.5th 31, 38-39.) The harassing
28 conduct must be "severe or pervasive." (Id.)
{02413385.DOCX} 9
1 Not just any acts constitute actionable harassment. "'[HJarassment consists oF conduct
2 outside the scope oF necessary job perFormance." (Roby v. McKesson Corp. (2009) 47 Cal.4th 686,
3 706-07, as modified (Feb. 10, 2010) (quoting Reno v. Baird (1998) 18 Cal.4th 640, 645-47 (fiirther
4 citation omitted.)) It is "conduct presumably engaged in For personal gratification, because oF
5 meanness or bigotry, or For other personal motives." (Id.)
6 Personnel management activities, as a matter oF law, do not constitute actionable harassing
7 acts. "[C]ommonly necessary personnel management [. . .] actions [. . .] do not come within the
8 meaning oFharassment [...] These actions may retrospectively be Found discriminatory iFbased on
9 improper motives, but in that event the remedies provided by the FEHA are those For discrimination,
10 not harassment[.]"' (Id. (emphasis added).)
11 According to the allegations in PlaintiFf s SAC, his harassment cause of action is based on
12 personnel management activities. Specifically, he cites the Fact that he was investigated For policy
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13 decisions and denied the "rights to retum to work." (SAC ^ 120, 123, 125; see Exh. V PlaintiFf s
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211 16 The appropriate remedy For that conduct under the FEHA is a claim For discrimination, not
o 17 harassment. (Roby, supra, 47 Cal.4th at 706-07.)
18 ThereFore, Plaintiffs harassment cause of action fails because personnel management
19 activities are not harassing acts.

20 C. Issue 3: Defendant Had Legitimate Reasons for Taking the Actions it Took
21 Even if the personnel management decision were actionable as harassment, which they are
22 not, those decisions were made for legitimate reasons. PlaintifF admits that he made derogatory
23 comments in the workplace about Jews, AFrican-Americans, Hispanics, and/or homosexuals; that
24 he was suspended and reassigned based on the UNIVERSITY'Sfindingsthat he violated UC Davis
25 Health System Policy 1616, and the Principals oF Community; and that his conduct created a hostile
26 work environment in the Central Plant. (UMF Nos. 1, 4-9, 11-12, 14-15; Goulding Deck, ^ 6; Exhs.
27 C and D, RFA Set One, No. 4-5.) He also admits that he was suspended and terminated as result oF
28 multiple violations oF UNIVERSITY policies prohibiting ethnic discrimination and hate incidents
{02413385.DOCX} 10
1 in the workplace. (UMF Nos. 1,4-9, 11-12, 14-15)
2 ThereFore, For the reasons set Forth above, summary adjudication oF PlaintiFf s harassment
3 cause oF action should be granted.
4 V.
5 PLAINTIFFIS CLAIM FOR FAILURE TO PREVENT HARASSMENT.
6 DISCRIMINATION. AND RETALIATION (THIRD CAUSE OF ACTION) FAILS
7 BECAUSE THERE WAS NO UNDERLYING UNLAWFUL CONDUCT
8 Plaintiffs Third Cause of Action also includes a claim for failure-to-prevent harassment,
9 discrimination and retaliation under the FEHA. Specifically, he alleges the UNIVERSITY Failed to
10 fijlfill its duty to take all reasonable and necessary steps to prevent discrimination, harassment, and
11 retaliation from occurring in the workplace.
12 Employers cannot be liable For Failing to prevent harassment, discrimination or retaliation
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13 without plaintiffs first proving that they suFFered underlying harassment, discrimination or
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16 claim).) Plaintiffs claim Fails For this very reason. He caimot prevail on any underlying claim For
EL:
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o 17 harassment, discrimination or retaliation. Even iF he could, DeFendant took all reasonable steps
18 necessary to prevent that conduct.
19 A. Issue 4: PlaintifPs Failure-to-Prevent Harassment Cause of Action Fails Because He
20 Cannot Prove an Underlying Claim of Harassment
21 PlaintifF cannot prevail on his underlying claim For harassment For the reasons set Forth above
22 in Section FV and hereby incorporated by reference. (UMF Nos. 1, 4-9, 11-12, 14-17.) ThereFore,
23 his Failure-to-prevent harassment cause oF action also necessarily Fails. (Kelley, 196 Cal.App.4th at
24 208.)
25 B. Issue 5: PlaintifPs Failure-to-Prevent Discrimination Cause of Action Fails Because He
26 Cannot Prove an Underling Claim of Discrimination
27 1. PlaintifF Cannot Establish a Prima Facie Case of Discrimination
28 To establish a prima facie case of discrimination under the FEHA, PlaintifF must show: (1)
{0241338S.DOCX} 11
he was a member oF a protected class; (2) he was perForming competently in the position he held;
(3) he suFfered an adverse employment action; and (4) some other circumstances suggesting a
discriminatory motive. (Guz v. Bechtel National Inc. (2000) 24 Cal.4th 317, 355.) At the prima
Facie stage, PlaintifF must offer evidence showing the UNIVERSITY suspended and terminated him
because of his protected characteristic. (Id.) PlaintifF cannot meet this burden because there is
absolutely no evidence oF a discriminatory motive.
Here, the undisputed evidence based on PlaintiFf s own admissions is that he was not
suspended or terminated because oF a protected characteristic. PlaintiFF admits he was suspended and
terminated because he violated UNIVERSITY policies prohibiting discrimination and hate incidents
10 in the workplace. (UMF Nos. 1, 4-9, 11-12, 14-17). ThereFore, he cannot prove discrimination
11 because he cannot carry his prima Facie burden oF proving the UNFVERSITY suspended and
12 terminated him because oF a protected characteristic.
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13
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simply shifts to the UNIVERSITY to ofFer evidence oF a legitimate, non-discriminatory reason For
p< < u ^ 16 its employment decisions. (Scotch v. Art Institute of California (2009) 173 Cal.App.4th 986, 1004.)
tL.
o 17 An employer's legitimate reasons "need not necessarily have been wise or correct." (Slatkin v. Univ.
18 of Redlands (2001) 88 Cal.App.4th 1147, 1157.) All that matters is that the employer's reasons are
19 Facially unrelated to plaintiffs protected status. (Id., at 1157-58.)
20 Employers meet their burden if they make personnel decisions based on information obtained
21 in an investigation even if that information tums out to be false or incorrect. (Wills v. Superior Court
22 (2011) 195 Cal.App.4th 143, 171-72.)
23 Here, Plaintiff admits the UNIVERSITY investigated allegations against him and that those
24 investigations confirmed that he violated UNIVERSITY policies prohibiting discrimination and hate
25 incidents in the workplace. (UMF Nos. 1, 4-9, 11-12, 14-17). He ftirther admits that the
26 UNIVERSITY suspended and terminated him For those violations - not For any discriminatory
27 reasons. (Id.)
28 Ill
{02413385.DOCX} 12
3. PlaintifF Cannot Show Pretext
Once a deFendant sets Forth evidence oFa legitimate reason For the adverse action, the burden
shifts back to plaintiFF to "present specific detailed Factual evidence" demonstrating that the reason
proffered by the defendant "was pretext and that the actual reason was discriminatory." (Nazir v.
United Airlines, Inc (2009) 178 Cal. App. 4th 243, 271.) Again, Plaintiff cannot carry his burden
here because he admits the UNIVERSITY suspended and terminated him because he violated
UNIVERSITY policies prohibiting discrimination and hate incidents in the workplace. (UMF Nos.
1,4-9, 11-12, 14-16; Goulding Deck, Exhs. C and D, RFA Set One, No. 11-18).
ThereFore, PlaintiFf s Failure-to-prevent discrimination cause oF action Fails because he

10 cannot prove an xmderlying claim oF discrimination.
11 C. Issue 6; PlaintifTs Failure-to-Prevent Retaliation Cause of Action Fails Because He
12 Cannot Prove an Underling Claim of Retaliation
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B 13 1. PlaintifF Cannot Prove a Prima Facie Case of Retaliation
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14 To prove an underlying claim of retaliation under the FEHA, PlaintifF must show: (1) he
Ov
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15 engaged in protected activity; (2) the UNIVERSITY subjected him to an adverse employment
01 < 6
16 action; and (3) there is a causal link between the protected activity and the adverse action. (Flait v.
iti t - tu
17 North American Watch Corp., (1992) 3 Cal.App.4th 467, 476.) Courts analyze retaliation claims
211
18 under the same burden-shifting approach as discrimination claims, discussed above. (Yanowitz v.
19 L'Oreal USA, Inc (2005) 36 Cak4th 1028, 1042.)
20 The initial prima Facie burden is on PlaintifF to prove that he engaged in protected activity,
21 he suffered an adverse action and there is some evidence of a causal connection between the two.
22 (Yanowitz v. L'Oreal USA, Inc (2005) 36 Cal.4th 1028, 1042.) Plaintiff cannot meet that burden
23 because the undisputed evidence is that the UNIVERSITY disciplined him because of his admitted
24 history of violating UNIVERSITY policies prohibiting ethnic discrimination and hate incidents in
25 the workplace. (UMF Nos. 1, 4-9, 11-12, 14-15).
26 2. The REGENTS Had Legitimate. Non-Retaliatory Reasons for the Adverse Actions
27 and PlaintifF Cannot Prove Pretext
28 Even assuming, arguendo, that PlaintifF can show a prima Facie case oF retaliation, then the
{02413385.DOCX} 13
burden simply shifts to the UNIVERSITY to oFFer evidence oF legitimate, non-retaliatory reasons
For taking the adverse actions. {Yanowitz, 36 Cal.4th at 1042.) That burden is met easily here as
PlaintifF admits the UNIVERSITY disciplined him because oF his history oF violating
UNIVERSITY policies prohibiting ethnic discrimination and hate incidents. (UMF Nos. 1, 4-15;
Goulding Deck, \ 6; Exhs. C and D, RFA Set One, Nos. 11-13-16-18).
PlaintifF also cannot carry his burden to prove pretext For the same reason - he admits the
UNIVERSITY disciplined him For legitimate, non-retaliatory reasons. (UMF Nos. 1, 4-9, 11-12,
14-15; Goulding Deck, \ 6; Exhs. C and D, RFA Set One, Nos. 11-13-16-18.) (Serri v. Santa Clara
University (2014) 226 Cal.App.4th 830, 865 (Plaintiffs burden is to produce "substantial evidence
10 that the [deFendant's] reason For terminating [him] were pretextual or False or used merely to veil an
11 unlawful act.").)
12 ThereFore, Plaintiffs Failure-to-prevent retaliation cause oF action also Fails because he
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13 cannot prove an underlying claim oF retaliation.
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o Issue 7: Plaintiffs Failure-to-Prevent Cause of Action Fails Because the UNIVERSITY
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— >O VD ^ 15 Took Reasonable Steps to Prevent Harassment. Discrimination and Retaliation
oi <
Even iF PlaintifF could establish underlying claims For harassment, discrimination, or
li ^ 16
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3 17 retaliation, his Failure-to-prevent claim still Fails because he cannot prove the UNIVERSITY Failed
18 to take reasonable steps to prevent such unlawful conduct. Indeed, PlaintifF has been unable to
19 articulate what fiuther preventative steps the UNIVERSITY should have taken. The UNIVERSITY
20 adopted and implemented policies prohibiting harassment, discrimination and retaliation. (UMF
21 Nos. 11-12). It also investigates and takes corrective action when there are reports oF any such
22 conduct. (Id.)
23 ThereFore, summary adjudication oF PlaintiFf s Failure-to-prevent cause oF action is
24 appropriate.
25 ///
26 ///
27 ///
28 ///
{02413385.DOCX} 14
1 VI.
2 PLAINTIFF'S RETALIATION CLAIMS UNDER GOVERNMENT CODE S 8547 AND
3 HEALTH & SAFETY CODE S 1278.5 FAIL BECAUSE HE ADMITS THAT HIS
4 DISCIPLINE AND TERMINATION WERE BASED ON HIS WRONGFUL CONDUCT
5 Plaintiffs Fourth Cause oF Action is For retaliation under Govemment Code § 8547. His Fifth
6 Cause oF Action is For retaliation under Health & SaFety Code § 1278.5. Both are analyzed under the
same generalframework.PlaintifF must establish a prima Facie case oF retaliation. IF he does so, the
burden then shifts to the UNIVERSITY to offer evidence of a legitimate reason for taking adverse
actions against Plaintiff. That then shifts the burden back to Plaintiff to prove pretext.
10 A. Issue 8; Plaintiff Cannot Establish a Prima Facie Case of Retaliation Under
11 Government Code S 8547 or Health & Safety Code S 1278.5
o
12 1. Plaintiff Cannot Establish a Prima Facie Case of Retaliation Under Govemment Code
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13 § 8547
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14 To establish a prima facie case of retaliation under Govemment Code § 8547 et seq., PlaintifF
ON ON
Qi< 6 SO ^ 15 must prove: (1) he made a protected disclosure/communication; (2) his communication demonstrated
III ^-1
16 an intent to disclose improper govemmental activity or a condition that could significantly threaten
oil 17 the health or saFety oF employees or the public; (3) he made the disclosure in good Faith For the
3 c«
o 18 purpose oF remediating the health or saFety condition; (4) the UNIVERSITY took an adverse action
vo
19 against him; and (5) Plaintiffs protected disclosure was a contributing Factor in the UNIVERSITY'S
20 decision to take the adverse action. (CACI 4601; Gov Code § 8547.2(c), (e).)
21 Here, even iF PlaintiFf s complaints constituted protected disclosures, he cannot satisfy his
22 burden to prove those complaints were a contributing Factor in the disciplinary actions taken against
23 him. As set Forth above, the undisputed evidence based on PlaintiFf s own admissions is that the
24 UNIVERSITY took the disciplinary actions against PlaintifF because oF PlaintiFf s history of
25 violating UNIVERSITY policies, not because oF any complaints PlaintifF made. (Goulding Decl, ^
26 6; Exhs. C and D, RFA Set One, Nos. 11-18.) ThereFore, PlaintiFF caimot establish a prima Facie
27 case oF retaliation under Govemment Code § 8547 et. seq.
28 Ill
{02413385.DOCX} 15
2. Plaintiff Cannot Establish a Prima Facie Case of Retaliation Under Health & Safety
Code § 1278.5
PlaintifF caimot establish a prima Facie case under Health & SaFety Code § 1278.5 because
he did not work at a covered "health Facility" and the UNIVERSITY did not take any actions against
Plaintiff because Plaintiff engaged in protected activity.
i. Plaintiff Did Not Work at a Protected Health Facility
The purpose oFHealth & SaFety Code § 1278.5 is to "encourage medical staFFand patients
to notify govemment entities oF 'suspected unsaFe patient care and conditions.'" (Mendiondo v.
Centinela Hosp. Medical Center 521 F.3d 1097, 1105 (9th Cir. 2008); see Fahlen v. Sutter Central
10 Valley Hospitals (2014) 58 Cal.4th 655, 667.) Thus, the statute only prohibits limited Forms oF
11 retaliation at a "health Facility." (Health & SaFety Code § 1278.5(b).) Health & SaFety Code § 1250
12 defines "health Facility" as a Facility "that is organized, maintained, and operated For the diagnosis,
o
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fc J ~ - 14 rehabilitation and including care during and after pregnancy [.]" (Health & SaFety Code, § 1250.)
H oo o
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Pi < o' vd vd
16 Central Plant and later in the HVAC/Plumbing Shop. The "diagnosis, care, prevention and treatment
o 17 oFhuman illness" is not perFormed at either one oFthose locations. (Witcher Deck, ^12.) ThereFore,
m
18 Health & SaFety Code § 1278.5 is inappHcable.
19 ii. The REGENTS Did Not Take Any Adverse Actions Against Plaintiff Because
20 Of Protected Activity
21 PlaintifF also cannot establish the remaining prima Facie elements For retaliation under Health
22 and SaFety Code § 1278.5. To establish a prima Facie case, he must prove: (1) PlaintifF was an
23 employee; (2) PlaintiFF presented a grievance or complaint to DeFendant related to the quality oF
24 care, services, or conditions at DeFendant's health care Facility or initiated, participated, or
25 cooperated in an investigation/administrative proceeding related to the quality oF care, services, or
26 conditions at DeFendant's health care Facility that was carried out by an entity or agency responsible
27 For accrediting or evaluating the Facility or its medical staFF; (3) DeFendant took an adverse action
28 against PlaintifF; and (4) PlaintiFf s whistleblowing action was a substantial motivating reason For
{024I3385.DOCX} 16
1 the adverse action. (CACI 4606; see Jadwin v. County ofKern 610 F.Supp.2d 1129, 1144 (E.D. Cal.
2 2009) (citing Mendiondo v. Centinela Hosp. Med. Ctr., 521 F.3d 1097, 1105 (9th Cir.2008).)
3 PlaintifF did not engage in protected activity under Health and SaFety Code § 1278.5 because
4 he did not make a complaint regarding patient saFety or the care provided to patients. Even iFhe did,
5 there is no evidence that any such complaints "substantially motivated" the UNIVERSITY'S
6 disciplinary actions. Indeed, the undisputed evidence based on Plaintiffs own admissions is that
7 his history of violating UNIVERSITY policies prohibiting ethnic discrimination and hate incidents
8 resulted in his termination. (UMF Nos. 1, 4-9, 11-12, 14-15; Goulding Decl. \ 6, Exhs. C and D,
9 RFA Set One, No. 11-13, 16-18). Accordingly, he cannot meet his prima Facie burden.
10 B. Issue 9: The UNIVERSITY had Legitimate. Non-Retaliatorv Reasons for the Adverse
11 Actions Taken Against Plaintiff
12 IF Plaintiff meets his prima Facie burden under Govemment Code § 8547 or Health & SaFety
O
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13 Code § 1278.5, then the burden shifts to the UNIVERSITY to offer evidence oF legitimate reasons
vo
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00
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O oT ov 14 For taking the adverse actions. The burden then shifts back to PlaintiFF to prove pretext. (Armin v.
venu
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15 Riverside Community Hospital (2016) 5 Cal.App.5th 810, 830 ("a prima Facie showing . . . shifts
iity A
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< 16 the case into the classic McDonnell Douglas burden-oF-prooF ping pong [. . . wherein] the hospital
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17 would [have to show . . . ] the reason For the [adverse action] was [...] legitimate.").) Once rebutted,
m
18 the presvunption oF retaliation disappears and the plaintifF must show the deFendant's reasons were
19 pretextual. (Id; Gov. Code, § 8547.8(d)-(e).)
20 Again, here, the undisputed evidence based on PlaintiFf s own admissions is that the
21 UNIVERSITY had legitimate, non-retaliatory reasons For taking the actions it took. PlaintiFF admits
22 the UNIVERSITY disciplined him because oF his history oF violating UNIVERSITY policies
23 prohibiting ethnic discrimination and hate incidents. (UMF Nos. 4-9, 11-15; Goulding Decl. H 6,
24 Exh C and D, RFA Set One, No. 11-13, 16-18).
25 C. Issue 10: Plaintiff Cannot Prove Pretext
26 As set Forth above, the UNIVERSITY'S evidence oF legitimate reasons For taking
27 disciplinary action shifts the burden to Plaintiff to prove pretext. That requires that Plaintiff submit
28 "substantial evidence" proving the UNIVERSITY'S reasons for taking disciplinary action are "false
{02413385.DOCX} 17
or used merely to veil an unlawful act." (Serri v. Santa Clara University (2014) 226 Cal.App.4th
830, 865.) Plaintiff cannot meet that burden because his own admissions are the evidence
establishing that the UNIVERSITY had legitimate reasons for the actions it took. PlaintifF admitted
that the UNIVERSITY took the adverse action because of his history of violating the
5 UNIVERSITY'S policies prohibiting ethnic discrimination and hate incidents. (UMF Nos. 4-9, 11-
6 15; Goulding Decl. H 6, Exh C and D, RFA Set One, No. 11-13, 16-18).
7 Based on the foregoing, the Court should grant DeFendant's Motion For Summary
8 Adjudication oF Plaintiff s Fourth Cause of Action for retaliation under Govemment Code § 8547
9 and Fifth Cause of Action for retaliation under Health & Safety Code § 1278.5.
10 VII.
11 PLAINTIFF CANNOT RECOVER ON HIS SEVENTH CAUSE OF ACTION FOR
12 "MISCLASSIFICATION^'
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13 A. Issue 11: "Misclassification" is Not a Cause of Action
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14 Plaintiffs Seventh Cause oF Action is simply titled as "Non-Exempt Wage and Hour." His
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5 15 specific allegation is that the UNIVERSITY misclassified him as an exempt employee. (SAC, HI 56.)
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16 However, there is no cause oF action For "misclassification." A failure to properly classify an
CO
3
o employee may result in other wage-and-hour violations, but PlaintifF does not allege any such
17
violations.^ He simply asserts a claim for "misclassification." Therefore, his Seventh Cause of
18
Action should be dismissed.
19
B. Issue 12: Plaintiff Was Properly Classified as Exempt
20
Moreover, Plaintiff was properly classified as an exempt employee. IWC Wage Order No.
21
4-2001 "specifies that its provisions goveming minimum wages, overtimes wages, and other
22
employment conditions do not apply to employees falling within exemptions for persons employed
23
in administrative, executive, or professional capacities, as defined in the wage order[.]" (Zelasko-
24
Barrett V. Brayton-Purcell, LLP (2011) 198 Cal.App.4th 582, 585-86.) hi the present case. Plaintiff
25
qualifies for an exemption as a professional employee.
26
27 ' Even had Plaintiff pled other wage-and-hour violations, they would not be viable as the majority of the wage-and-hour
laws do not apply to public employees. (See California Correctional Peace Officers' Assn. v State of California (2010)
28 188 Cal.App.4th 646,651-54; Cal.Code Regs., tit. 8, § 11040, subd. 1(B).) Pursuant to Govemment Code § 811.2, "the
Regents of the University of Califomia" is specifically included within the definition of "[p]ublic entity."
{02413385.DOCX} 18
1 An employee is exempt under the "professional exemption" as long as the following are
2 satisfied:
(a) The employee is either "primarily engaged in the practice of... engineering" or primarily
3
engaged in a leamed profession such as "work requiring knowledge of an advanced type in
4 a field or science or leaming customarily acquired by a prolonged course of specialized
intellectual instmction and study";
5 (b) The employee customarily and regularly exercises discretion and independent judgment;
6 and
(c) The employee eams a monthly salary of no less than double minimum wage.
7
(Cal. Code Regs., tit. 8, § 11040, FWC Wage Order No. 4-2001.) (3)(b)-(d).)
8
PlaintifF undoubtedly satisfied those requirements. He perFormed engineering services in the
9
position oF Associate Development Engineer. In that role, he was responsible For "the operation,
10
maintenance, service, and repair oFbuilding, grounds, machinery, and utility systems at UCDMC."
11
(See Witcher Deck, ^ 2; Exh. A2.) Those duties required regular exercise oF discretion and
12
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o independent judgment regarding how to repair and maintain the UNIVERSITY'S systems. (UMF
CN
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OO — vo Nos. 1-3; Witcher Deck, ^ 2.) In that role, he eamed a salary oF $70,000, which is well over double
* n OO
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u minimum wage. (UMF Nos. 1-3; Witcher Deck, T| 2; Exh. K January 30, 2009 settlement
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^ 16
tL. Accordingly, PlaintiFF was properly classified as exempt.
3
17 C. Issue 13: Plaintiff Executed A Settlement Agreement for Claims Related to his
18 Classification
19 Additionally, PlaintifF actually confirmed his classification as an exempt an employee and
20 released associated claims in exchange for a monetary payment.
21 On January 30, 2009, PlaintifF entered into a Settlement Agreement with the UNFVERSITY.
22 (Goulding Decl. H 6, Exh. C, RFA Set One, No. 6; Exh. D Court's final ruling on UNIVERSITY'S
23 Motion to deem Request For Admissions, Set One, admitted.) The Agreement provides, in part:
24
Upon execution oF this Agreement, the University will complete an upward reclassification
25 For Mr. Waszczuk's job classification reclassifying him from CoGen Operator to Associate
Development Engineer. Said upward reclassification is contingent on Mr. Waszczuk
26 executing a new position description, reflecting the new classification as Associate
27 Development Engineer[....]
Said upward reclassification to Associate Development Engineer will result in a
28 salary increase to $70,000.00 per year[. . . .] Mr. Waszczuk acknowledges and understands
that an Associate Development Engineer position is an exempt (salaried) position that is not
{02413385.DOCX} 19
eligible For terms and conditions that are available to non-exempt (hourly) employees
1
including, but not limited to overtime pay, shift diFFerential pay and weekend diFFerential
2 pay[. . . .]
Mr. Waszczuk hereby Forever releases and discharges the University and its Regents,
3 [. . .] employees, and all other representatives (hereafter collectively referred to as
4 ("University Releasees"), from any and all causes oF action, judgments, liens, indebtedness,
damages, losses, claims (including attorneys' Fees and costs), liabilities and demands oF
5 whatsoever kind and character that Mr. Waszczuk may now or hereafter have against
University Releasees arising from incidents or events occurring on or beFore the EfFective
6 Date oFthis Agreement. (Witcher Deck, ]| 7; Exh. K January 30,2009 settlement agreement.)
Pursuant to the position description PlaintifF signed. Plaintiffs duties as an Associate
Development Engineer involved the operation, maintenance, service, and repair oF building,
grounds, machinery, and utility systems at UCDMC. PlaintifF also had primary responsibility For the
10 operation and maintenance oF the central plant. (See Witcher Deck, ^ 2; Exh. A2 signed position
11 description.) Sixty percent oF the position's functions included:
12
o
o A-1 Provide monitoring, troubleshooting, testing and assist in the calibration oF Building
fN
B vn 13 Management System (BMS) components. BMS components include hardware, software and
H c/3 oo o mechanical devices that are a critical utility, instrumental to the support oF UCDMC Facilities
o « 2: 14 operations. [. . .]
y c < o< 15 A-2 Operate and maintain the BMS in a saFe and proficient manner providing UCDMC with
Pi < o' vd vd the above mentioned services while optimizing campus energy perFormance. [. . .]
e 15^ ^ A-3 Demonstrate proficiency in the operation and maintenance oF Energy Management
Systems, both Metasys and Andover.
17 A-4 Monitoring BMS includes the ability to acknowledge and perForm operational
18 adjustments as required to address condition alarms For electrical equipment, hydronic
equipment, HVAC equipment, medical gases, domestic water, and power generation
19 equipment.
A-5 Notify [. . .] staff and management required to respond to urgent and emergent
20 equipment, system anomalies utilizing department authorized means.
21 A-6 Produces specialized Trend Reports from the BMS (Metasys) System.
22 (See Witcher Deck, ^ 2; Exh. A2, signed position description.)

23 PlaintifF was heavily involved in the development and application oF advanced theoretical
24 and/or mathematical engineering concepts, which fall within the ProFessional Exemption. (Witcher
25 Deck, 12.) (Cal. Code Regs., tit. 8, § 11040, FWC Wage Order No. 4-2001 (3)(b)-(d).)
26 In sum, PlaintiFf executed the Settlement Agreement and position description confirming that
27 these are his duties and that they qualify him as an exempt employee. In that Agreement, he
28 specifically released all associated claims. (Witcher Deck, TI^ 2, 7; Exh. K January 30, 2009
Settlement Agreement.) He Further "promise[d] never to file or cause oF be filed a lawsuit... to
{02413385.DGCX} 20
assert any Released Claim." (Witcher Deck, ^ 7; Exh. K January 30, 2009 Settlement Agreement.)
He now brings this action doing just that - challenging his classification as exempt. The terms oF the
Settlement Agreement prohibit such an action. ThereFore, the UNIVERSITY'S Motion should be
granted.
D. Issue 14: Plaintiff is Estopped from Having the Settlement Agreement Declared
Unenforceable Because He Accepted a Tangible Benefit Under the Agreement.
As discussed supra, PlaintifF executed a Settlement Agreement confirming his proper
classification as an exempt employee. PlaintifF received afinancialbenefit as part oF that Agreement.
(Goulding Decl. ^ 6, Exhs. C and D, RFA Set One, No. 6-9, and Court's final mling on
10 UNIVERSITY'S Motion to deem Request For Admissions, Set One, admitted.) As a result, he is now
11 estopped From taking a different position. Otherwise, iF PlaintifF was permitted to pursue his current
o
12 misclassification claim then he would have received the financial benefit oFthe settlement payment
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13 without being bound by the terms oF that Settlement Agreement.
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1 14 It is tme that the wage and hour laws generally do not permit employees to just agree that
3 Ov t—
OS OV
fei< 6 ^ —
S 15 they are exempt. However, here, PlaintifF not only admits that he agreed that his exempt
" ON Ov
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16 classification was proper, but that he also received a significant monetary benefit in retum. (Goulding
&- c « f - tu
3
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t/3 17 Decl. H 6, Exhs. C and D, RFA Set One, No. 6-9, and Court's final mling on UNIVERSITY'S Motion
18 to deem Request For Admissions, Set One, admitted.)
19 "The doctrine oF equitable estoppel may estop a party from denying the enforceability oF a
20 contract." (Blix Street Records, Inc v. Cassidy (2010) 191 Cal.App.4th 39, 50.) "'Estoppel is not
21 dependent on the potential merits oF a claim but depends on the manner in which a claim is raised
22 or not raised.'" (Id.) The elements oFequitable estoppel include: "(1) The party to be estopped has
23 engaged in blameworthy or inequitable conduct; (2) that conduct caused or induced the other party
24 to suffer some disadvantage; and (3) equitable considerations warrant the conclusion that the first
25 party should not be permitted to exploit the disadvantage he has thus inflicted upon the second
26 party." (City of Hollister v. Monterey Ins. Co. (2008) 165 Cal.App.4th 455, 488.)
27 All oF the elements are met here. PlaintifF engaged in the inequitable conduct oF accepting a
28 financial benefit in retum for agreeing to the job classification he now seeks to dispute. (Goulding
{02413385.DOCX} 21
Decl. H 6, Exhs. C and D, RFA Set One, No. 6-9, and Court's final mling on UNIVERSITY'S Motion
to deem Request For Admissions, Set One, admitted.) That agreement induced the UNIVERSITY to
pay significantfinancialcontributions to PlaintifF - a lump sum payment, as well as a salary increase.
(Goulding Decl. TI 6, Exhs. C and D, RFA Set One, No. 6-9, and Court's final mling on
UNIVERSITY'S Motion to deem Request For Admissions, Set One, admitted.) Allowing PlaintifF to
pursue legal action challenging the exempt classification would be wholly inequitable as it would
result in PlaintifF receiving the benefit oF the bargain (significant financial payments) without
binding him to the agreement he made in exchange For those payments.
ThereFore, all three elements oF equitable estoppel are met and For that reason, PlaintifF
10 should be barred from pursuing a claim based on his purported misclassification as an exempt
11 employee.
12 VIII.
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13 PLAINTIFF'S SIXTH CAUSE OF ACTION FOR BREACH OF WRITTEN
— vo
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15 EMPLOYMENT IS STATUTORY
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-> X 16 Plaintiffs Sixth Cause oF Action is For breach oF contract. This claim must Fail because (1)
o ic «
f - ta.
3
o
t/3 17 he cannot satisfy the prima Facie elements; and (2) contract-based employment claims generally
>r>
m
18 cannot be asserted by public employees in CaliFomia.
19 A. Issue 15: Plaintiff Cannot Establish a Prima Facie Case for Breach of Contract.
20 To recover For breach oF contract, a plaintiFF must prove the existence oF a contract, that
21 plaintifF perFormed the terms oF the contract, that deFendant breached the contract by Failing to do
22 something that was required or by doing something that was prohibited by the contract and that
23 plaintiFF was harmed by the deFendant's breach. (Acoustics, Inc. v. Trepte Construction Co. (1971)
24 14 Cal. App. 3d 887, 913; CACI 303.) For the plaintiFF to succeed on a breach oF contract action,
25 the record must contain suFficient evidence to support a finding in its Favor on each element oF the
26 claim. (BeckDevelopment Co. v. Southern Pacific Transportation Co. (1996) 44 Cal. App. 4'*' 1160,
27 1205.) Damages are not presumed to flow from the Fact that a party breached a contract. The
28 plaintifF must establish the causal connection between the breach and damages sought. (Civ. Code
{02413385.DOCX} 22
1 § 3300.)
2 Although unclear. Plaintiffs claim is seemingly based on his allegation that the
3 UNIVERSITY breached the Settlement Agreement the parties executed back in January 2009
4 through 4 purported acts: (1) placing PlaintifF on leave during investigations into his wrongdoing;
5 (2) the UNIVERSITY allegedly Failing to provide him with an exempt position; (3) the
6 UNIVERSITY allegedly breaching the non-disparagement provision in the Agreement; and (4)
7 breach oFthe implied covenant oF good Faith and Fair dealing. Each is discussed below.
8 1. Placement on Investigative Leave
9 PlaintifF first claims the UNFVERSITY breached the Agreement by placing him on
10 investigative leave while investigating allegations oFhis wrongdoing. (SAC, Til49.) Yet, there is
11 nothing in the Settlement Agreement prohibiting the UNIVERSITY from placing PlaintifF on
12 investigative leave. (See generally, Exh. K, January 30,2009 Settlement Agreement). As such, there
o
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H a g _ vo
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p « 2: P; 14 2. Exempt Position
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0^ < o' vd VD I D PlaintifF next claims the UNIVERSITY breached the Agreement by purportedly Failing to
giigg 16 place him in an exempt position. (SAC, 11150.) Yet, the UNIVERSITY did place him in an exempt
D t .
O position, as set Forth above in Section VII, and incorporated herein by reference. (See UMF Nos. 1-
18 3). PlaintifF also released his right to pursue any claims based on his classification and is estopped
19 From bringing any such argument, again as set Forth above in Section VII and incorporated herein
20 by reFerence.
21 3. Non-Disparagement Provision
22 In his discovery responses, PlaintifF alleged that the UNIVERSITY breached the non-
23 disparagement provision oF the Settlement Agreement on a number oF occasions, specifically by
24 publishing the Following:
25 . 8/31/11-WITCHER'S Investigatory Leave Notice (Goulding Deck, 1 7, Exh. E
26 UNIVERSITY'S Special Interrogatories, Set One and PlaintiFf s First Amended
Response to UNIVERSITY'S Special Interrogatories, Set One, Response to Special
27 Interrogatory No. 30.)
. 8/31/11-An email from NICHOLS (Goulding Deck, H 7, Exh. E UNIVERSITY'S
28 Special Interrogatories, Set One and Plaintiffs First Amended Response to
UNIVERSITY'S Special Interrogatories, Set One, Response to Special Interrogatory
{02413385.DOCX) 23
No. 30.)
9/15/11-An "email letter" from Stephen Chilcott regarding Nichols' investigation
(Goulding Deck, 1 7, Exh. E UNFVERSITY's Special Interrogatories, Set One and
Plaintiffs First Amended Response to UNIVERSITY'S Special Interrogatories, Set
One, Response to Special Interrogatory No. 30.)
9/21/11 -A letterfromWITCHER extending Plaintiffs investigatory leave (Goulding
Deck, H 7, Exh. E UNIVERSITY'S Special Interrogatories, Set One and Plaintiffs
First Amended Response to UNIVERSITY'S Special Interrogatories, Set One,
Response to Special Interrogatory No. 30.)
12/5/11-Another email from WITCHER "in attempt to remove me from disability
without physician clearance." (Goulding Deck, H 7, Exh. E UNIVERSITY'S Special
Interrogatories, Set One and Plaintiffs First Amended Response to UNIVERSITY'S
Special Interrogatories, Set One, Response to Special Interrogatory No. 30.)
12/5/11-Nichols' investigation report regarding concems raised by PlaintifF.
(Goulding Deck, ^ 7, Exh. E UNIVERSITY'S Special Interrogatories, Set One and
10 Plaintiffs First Amended Response to UNIVERSITY'S Special Interrogatories, Set
One, Response to Special Interrogatory No. 30.)
11 2/8/12-Nichols' investigation report regarding allegations against PlaintifF (Goulding
Deck, H 7, Exh. E UNIVERSITY'S Special Interrogatories, Set One and Plaintiffs
o
12 First Amended Response to UNIVERSITY'S Special Interrogatories, Set One,
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13 Response to Special Interrogatory No. 30.)
B
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O 4/13/12-Plaintiffs Notice of Intent to Suspend (Goulding Deck, ^ 7, Exh. E
f - i t/3 «ri 14 UNIVERSITY'S Special Interrogatories, Set One and PlaintifPs First Amended
CN f v i
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15 Response to UNIVERSITY'S Special Interrogatories, Set One, Response to Special
vd vd
Ov ov Interrogatory No. 30.)
if!
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16
17
5/11/12-Plaintiffs Letter of Suspension (Goulding Deck, ^ 7, Exh. E
UNIVERSITY'S Special Interrogatories, Set One and Plaintiffs First Amended
m

9/20/12-hivestigation report issued by OROPEZA and SEIFERT (Goulding Deck, ^
19 7, Exh. E UNIVERSITY'S Special Interrogatories, Set One and Plaintiffs First
Amended Response to UNIVERSITY'S Special Interrogatories, Set One, Response
20
to Special Interrogatory No. 30.)
21 9/25/12-Plaintiff s Notice of Intent to Dismiss for Serious Misconduct (Goulding
Deck, II 7, Exh. E UNIVERSITY'S Special Interrogatories, Set One and Plaintiffs
22 First Amended Response to UNIVERSITY'S Special Interrogatories, Set One,
9/26/12-UC Davis Police Department bulletin regarding Plaintiff not being
24 authorized to be on UC Davis property (Goulding Deck, 17, Exh. E UNFVERSITY's
Special Interrogatories, Set One and Plaintiffs First Amended Response to
25 UNIVERSITY'S Special Interrogatories, Set One, Response to Special Interrogatory
26 No. 30.)
9/26/12 Email correspondencefromCHILCOTT to HR Labor Relations Department
27 Manager Travis Lindsay regarding safety precautions and police patrols (Goulding
28 Deck, H 7, Exh. E UNIVERSITY'S Special Interrogatories, Set One and PlaintifPs
Response to Special Interrogatory No. 30.)
{02413385.DOCX} 24
• 12/5/12-Plaintiffs letter of termination (Goulding Deck, H 7, Exh. E
1
UNIVERSITY'S Special Interrogatories, Set One and Plaintiffs First Amended
2 Response to UNIVERSITY'S Special Interrogatories, Set One, Response to Special
Interrogatory No. 30.)
3 • 6/25/14-Investigation report regarding Plaintiffs allegations of retaliation (Goulding
4 Deck, H 7, Exh. E UNIVERSITY'S Special Interrogatories, Set One and Plaintiffs
• Documents provided by UC Davis Unemployment Insurance Analyst Holly Sochor
6
to "deny PlaintiFf unemployment benefits" (Goulding Deck, ^ 7, Exh. E
7 UNIVERSITY'S Special Interrogatories, Set One and PlaintifPs First Amended
9 • Pleadings filed by attomeys for the UNIVERSITY from December 2, 2014 through
the present. (Goulding Deck, ^ 7, Exh. E UNIVERSITY'S Special Interrogatories,
10 Set One and Plaintiffs First Amended Response to UNIVERSITY'S Special
Interrogatories, Set One, Response to Special Interrogatory No. 30.)
11
12 i. The non-disparagement clause specifically excludes the investigations at issue
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14
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fvi Ji! disparagement provision in question contains a carve-out For investigations. The clause specifically
ov ov ^ g .
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Ov OV
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18
The investigations in question were conducted by the UNIVERSITY in accordance with its
19
intemal policies and procedures. (Harwood Decl. 7-8; Exh. Z UCDHS Policy 1616; Exh. A l
20
UCDHS PPM section 380-15.) Pursuant to the CaliFomia Constittition, the UNFVERSITY is a
21
govemmental entity with fiill powers oF organization and govemment. (Miklosy v. Regents of
22
University of Califomia (2008) 44 Cal. 4'^ 876, 889-890 ["We have observed that 'Article IX,
23
section 9, grants the [R]egents broad powers to organize and govem the university and limits the
24
Legislature's power to regulate either the university or the [R]egents . . . The Regents may also
25
exercise quasi-legislative powers, subject to legislative regulation. Indeed, 'policies established by
26
the Regents as matters oF intemal regulation may enjoy a status equivalent to that oF state
27
statutes.'"].) As the vast majority oF the communications Plaintiff claims "disparaged" him were
28
part oF UNIVERSITY investigations into allegations raised by and against PlaintifF, the non-
{02413385 DOCX} 25
disparagement clause is inapplicable as it explicitly excludes participation in such investigations
from its purview.
//. Plaintiff admitted to engaging in the misconduct that formed the basis of the
disciplinary action against him
The communications PlaintiFF relies on For his allegation that the UNIVERSFTY disparaged
him were not disparaging given PlaintifF admits they were tme.
As set Forth above, PlaintifF admitted to engaging in misconduct and that the misconduct
was the basis For the investigations and the disciplinary action against him. (UMF Nos. 2-16;
Goulding Decl. TI 6 , Exhs. C and D, RFA Set One, Nos. 11-18, and Court's final mling on
UNIVERSITY'S Motion to deem Request for Admissions, Set One, admitted.) The misconduct
10 PlaintifF admitted to—including sending the "Welcome to Romania" slideshow to Nichols—
11 resulted in his termination, as well as the UC Davis Police Department issuing the bulletin regarding
o
12 PlaintiFf not being allowed on campus property. The UCDPD issued this bulletin on September 26,
o
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13 2012—the same day Plaintiff received the Notice of Intent to Terminate—out of concem that
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s- 2; The relevant provision of the Settlement Agreement states that the parties will "say nothing
oi
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3 1/3
O
18 19.) The term "disparaging" is not defined in the Agreement itself Merriam-Webster Dictionary
19 defines "disparaging" as "meant to belittle the value or importance of someone or something."
20 (Merriam-Webster Diet., https://www.merriam-webster.com/dictionarv/disparaeing) The intent of
21 the bulletin was not to belittle PlaintifF in any way; rather, the bulletin was an extra precaution taken
22 as a result oF the increasingly aggressive conduct PlaintifF has admitted to engaging in. (Harwood
23 Decl. H 6.) Moreover, there is nothing about the content oF the bulletin itselF that that is belittling.
24 (Exh. A3 Bulletin) It does not state why PlaintiFF is not allowed on the property or contain any
25 information about Plaintiffs employment. There is also nothing false about the bulletin and the
26 information contained therein. The same is tme for the other communications that Plaintiff contends
27 are disparaging. They were not meant to belittle Plaintiffs value or importance, but rather, were
28 part of the UNIVERSITY'S efforts to determine the truth of allegations made by and against
{02413385.DOCX} 26
1 Plaintiff. While Plaintiff may not like the fact that the UNFVERSrTY was investigating allegations
2 against him and that he was ultimately terminated (For conduct he has admitted to engaging in, no
3 less). Plaintiffs dislike does not convert such actions into disparagement.
4 As such, PlaintifF cannot establish that any oF the aForementioned communications were
untme, damaging, or disparaging in any way.
The UNIVERSITY is immune from liability under Govemment Code sections
820.2 and 821.6
Even iF PlaintiFF could establish that the communications he cites "disparaging" were
actually untme or damaging to him in some way, the UNIVERSITY is immunefromliability.
Govemment Code section 820.2 states that "[e]xcept as otherwise provided by statute, a
10 public employee is not liable For an injury resulting From his act or omission where the act oF
11 omission was the result oFthe exercise oFthe discretion vested in him, whether or not such discretion
12 was abused." Section 821.6 provides: "A public employee is not liable For injury caused by his
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v Courts have routinely held that these sections immunize public employees From all liability
5^ associated with complaints and investigations into personnel issues. In Ross v. San Francisco Bay
OH C S
o 17 Area Rapid Transit District (2007) 146 Cal.App.4th 1507 the Court explained: "The gravamen oF
18 these claims is that, acting out oF discriminatory and retaliatory motives, BART employees initiated
19 and prosecuted administrative proceedings to discipline or discharge Ross based on accusations they
20 knew to be False. Such acts by employees are immune from liability imder section 821.6 .. .." (Id.
21 at 1516.)
22 That immunity extends to conduct associated with any investigation that leads to the
23 discipline. Kemmerer v. County ofFresno (1988) 200 Cal.App.3d 1426,1435 [an investigation is an
24 essential step in instituting disciplinary action and is thereFore "cloaked with immunity."].) The
25 employees are immune From liability For "any acts done to institute and prosecute disciplinary
26 proceedings." (Id. at 1437.) Given the UNIVERSITY employees involved in that conduct are
27 immune, so too is the UNFVERSITY. (Cal. Gov. Code § 815.2.)
28 ///
{0241338S.DOCX} 27
IV. Communications related to litigation are absolutely privileged under Civil Code
§47
As set Forth above, PlaintiFf also asserts that the pleadings filed on behalf of the
UNIVERSITY From December 2014 through the present violate the non-disparagement provision
oF the Settlement Agreement. Although PlaintifF does not specify which statements within the
pleadings he contends are disparaging, this ambiguity is oF no matter because all oF the statements
within the pleadings are protected by absolute privilege.
7 Civil Code § 47, subdivision 2 provides, "A privileged publication or broadcast is one made
8 . . . In any (1) legislative or (2) judicial proceeding, or (3) in any other official proceeding authorized
9 by law . . . ." The courts have clarified and reaFfirmed that such statements are entitled to absolute
10 protection. "Publications that are made in the course oF a judicial proceeding are [a]bsolutely
11 privileged under the provisions oF subdivision 2 oFsection 47... .The absolute privilege attaches to
12 any publication that has a reasonable relation to the action and is permitted by law iF made to achieve
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13 the objects oFthe litigation " (Rader v. Thrasher, et al. (1972) 22 Cal. App. 3d 883, 887.)
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CN
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S ^§ Ov tjv
2-11H ta. The immunity also extends to documents filed in response to Plaintiffs filing for
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17 unemployment benefits. Again, PlaintiFF does not specify which statements within the documents
18 he believes to be disparaging, but, as with the pleadings discussed above, this Failure is
19 inconsequential. The litigation privilege applies to any communication (1) made injudicial or quasi-
20 judicial proceedings; (2) by litigants or other participants authorized by law; (3) to achieve the
21 objects oFthe litigation; and (4) that [has] some connection or logical relation to the action. (Wang
22 V. Heck (2012) 203 Cal.App.4''' 677,683.) "The phrase, "judicial or quasi-judicial proceedings," has
23 been "defined broadly to include 'all kinds of truth-seeking proceedings,' including administrative,
24 legislative and other oFficial proceedings." (Id. at p. 684 [emphasis added].)
25 Providing inFormation to the Employment Development Department (EDD) when an
26 employee makes a claim For unemployment benefits is a tmth-seeking function. An employee is
27 only eligible For such benefits iF he or she is unemployed through no Fault oF his or her own. (See
28 Cal. Code Regs. tit. 22, § 1256-1.) Thus, in requesting inFormationfroman employer regarding why
{02413385.DOCX} 28
1 an employee claiming unemployment is no longer employed, the EDD is seeking to ascertain the
2 tmth behind an employee's termination.
3 The administrative proceeding in Wang v. Heck (2012) 203 Cal. App. 4* 677 [hereinafter
4 "Wang"] is analogous. In Wang, a physician was sued after certifying to the DMV that her patient,
5 who suFFeredfromepilepsy, was fit to drive. (Id. at p. 681.) The court determined that the litigation
6 privilege applied, as the certification Form was part oF an administrative proceeding (i.e. a "truth-
7 seeking" proceeding) wherein the DMV was deciding whether to reinstate driving privileges. (Id.
8 at pp. 685-686.) In the instant matter, and as set Forth above, the UNIVERSITY'S purpose, as
9 Plaintiffs employer and through UC Davis Unemployment Insurance Analyst Holly Sochor (who
10 was authorized to act on behalF oF the UNIVERSITY), was to provide tmthflil inFormation to the
11 EDD regarding Plaintiffs termination For purposes oFEDD's consideration in determining whether
12 to approve or deny PlaintiFf s unemployment insurance benefits. As in Wang, the inFormation was
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f - i t/3 m 00 '
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^ 16 regarding Plaintiffs claim For unemployment insurance and, as such, the statements made to EDD
CL, C ta.
D t/3
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17
4. Implied Covenant of Good Faith & Fair Dealing
18
PlaintifF also claims the UNIVERSITY breached the implied covenant oF good Faith and Fair
19
20 dealing provided under the Settlement Agreement. Under a good Faith and Fair dealing standard,
21 each party will not do anything to unFairly interFere with therightoF any other party to receive the
22 benefits oFthe contract. (Comunale v. Trades & General Ins. Co. (1958) 50 Cal. 2d 654, 658.) "[T]o
23 put it another way, the 'implied covenant imposes upon each party the obligation to do everything
24 that the contract presupposes they will do to accomplish its purpose.'" (Andrews v. Mobile Aire
25 Estates (2005) 125 Cal.App.4* 578, 589. [intemal citations omitted].)
26 PlaintifF received the benefits oF the Settlement Agreement he entered into with the
27 UNIVERSITY. He admitted that he received $13,500 and a salary increase pursuant to the
28 Agreement. (Goulding Decl. ^ 6, Exhs. C and D, RFA Set One, Nos. 7, 9, and Court's final mling
{02413385.DOCX} 29
on UNIVERSITY'S Motion to deem Request For Admissions, Set One, admitted.) Additionally,
PlaintifF was promoted to Associate Development Engineer pursuant to the Agreement and does not
dispute receiving this benefit either. (Goulding Decl. TI 7, Exh. E, PlaintiFf s Responses to Special
Interrogatories, Set One, Interrogatory No. 35.) Plaintiffcontends that he was disparaged in violation
of the Agreement, but this is simply not the case for the reasons discussed above.
In sum, PlaintifF admitted that he received the benefits oF the Agreement he entered into with
the UNFVERSITY and, thereFore, has no basis For his claim that the UNIVERSITY breached the
implied covenant oF good Faith and Fair dealing.
9 B. Issue 16: Plaintiffs Breach of Contract Claim Must Further Fail Because Public
10 Employment in California is Held bv Statute Rather than Contract and Therefore
11 Contract-based Claims Cannot be Asserted bv Plaintiff.
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12 PlaintifF seemingly argues that his Settlement Agreement guaranteed him certain
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13 employmentrights.This assertion Fails because "[p]ublic employment in the State oF CaliFomia is
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< ''v
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01 < 1 Ov
16 158 Cal.App.4th 187,207-08 citing Miller v. State ofCalifomia (1977) 18 Cak3d 808, 813) ("Since
ii 17 [plaintifF] was an employee oF the University oF CaliFomia, his employment was held by statute, not
18 by contract, and his remedies For breach were limited to those afforded by statute and the
19 University's rules and policy.")
20 To the extent that Plaintiff asserts that, by voluntarily executing the Settlement Agreement,
21 the UNIVERSITY created contractual obligations relating to his employment, this argument also
22 fails. For the UNIVERSITY to alter the statutory terms and conditions of an employee's
23 employment, the UNIVERSITY must have a policy that allows it to do so. (Kim v. Regents of
24 University of California (2000) 80 Cal.App.4th 160, 165 ("The [. . .] Regents have mlemaking and
25 policymaking power in regard to the University; their policies and procedures have the force and
26 effect of statute[.]"); Regents of University of California v. City of Santa Monica (1978) 77
27 Cal.App.3d 130, 135 ("policies established by the Regents as matters of intemal regulation may
28 enjoy a status equivalent to that of state statutes.") Plaintiff has shown no such policy exists.
{024I3385.DOCX} 30
1 IX.
2 PLAINTIFF'S EIGHTH CAUSE OF ACTION. FOR RESCISSION. MUST FAIL
3 BECAUSE RESCISSION IS NOT A STANDALONE CLAIM AND CONTRACT-BASED
4 EMPLOYMENT CLAIMS CANNOT BE ASSERTED BY PUBLIC EMPLOYEES
5 Plaintiffs Eight Cause of Action is titled "rescission-unlawful contract." Specifically, he
6 claims the provision in the Settlement Agreement that declares him as an exempt employee renders
7 the entire Agreement void as unlawful. (SAC ^ 159-165.) However, "rescission" is not a cause of
8 action; employment contract claims are not viable against the UNFVERSITY and Plaintiffs
9 argument is also contrary the terms of the Agreement.
10 A. Issue 17: Rescission is Not a Cause of Action
11 A cause of action is "the right to obtain redress for a harm suffered, regardless ofthe specific
12 remedy sought or the legal theory (common law or statutory) advanced." (Boeken v. Philip Morris
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13 USA, Inc (2010) 48 Cal.4th 788, 798 (fiirther citation omitted)). "The seeking of different kinds of
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5^ uc <
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Here, Plaintiff labeled his Eighth Cause of Action "rescission-unlawful contract."
"Rescission," however, "is not a cause of action; it is a remedy." (Nakash v. Superior Court (1987)
D f/3
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18 196 Cal.App.3d 59, 69-70 (citing Civ. Code § 1689.).) Rescission means to "restore the parties to
19 their former position[.]" (Young v. Flickinger (1925) 75 Cal.App. 171, 174.) Plaintiffs rescission
20 claim sounds in breach of contract. Thus, his cause of action for rescission must fail because
21 rescission is merely a remedy for breach of contract, not a cause of action.
22 B. Issue 18: Contract-Based Employment Claims are Not Viable Against the
23 UNIVERSITY
24 Plaintiffs "recission-unlawful contracf claim is fiirther barred because, as discussed supra
25 in Section VIII(B), contract-based employment claims cannot be asserted by UNFVERSITY
26 employees given their employment terms are set by statute, not contract. (Lachtman v. Regents of
27 the University ofCalifomia (2007) 158 Cal.App.4th 187, 207.)
28 ///
{0241338S.DOCX} 31
C. Issue 19: PlaintifPs Rescission Argument is Contrary to the Terms ofthe Agreement
PlaintifPs argument that the exemption classification is unlawful and the Settlement
3 Agreement is void for that reason is also contrary to the terms of the Agreement. (See UMF Nos. 1 -
4 3). The Agreement contains a severability clause, which specifically states:
5
"Should it be determined by a court that any term of this Agreement is unenforceable, or
6 should any term of this Agreement be contraty to state or federal law or regulation, that term
shall be deemed to be deleted. However, the validity and enforceability of the remaining
7 terms shall not be affected by the deletion of the unenforceable term."
8 (Exh. K, January 30, 2019 Settlement Agreement)
9 Therefore, even if the provision declaring PlaintiFf s position as exempt was improper, the
10 appropriate remedy would be to deem that provision as deleted, not rescind the entire Agreement.
11 X.
12 CONCLUSION
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Oi < 6 15 alleged protected characteristics. Given there was no underiying harassment, PlaintifPs claim
a^ ON
III 16 failure-to-prevent harassment also fails.
2-11
O 17 PlaintifPs retaliation causes of action and failure-to-prevent discrimination and retaliation
D t«
18 causes of action fail because the undisputed evidence is that the UNrVERSITY took adverse action
19 against PlaintifF because PlaintiFf admittedly and repeatedly violated UNIVERSITY policies
20 prohibiting ethnic discrimination and hate incidents in the workplace, not because oF any unlawful
21 animus.
22 Plaintiffs "misclassification" cause of action fails because there is no such cause of action
23 and the undisputed evidence is that he was classified appropriately. The breach of contract claim
24 should be summarily adjudicated because there was no underlying breach and employment-based
25 contract claims are not viable by public employees.
26 Lastly, Plaintiffs "rescission" cause of action fails because there is no such cause of action
27 and Plaintiffs assertion is contrary to the terms of his Settlement Agreement.
28 For these reasons, the UNIVERSITY respectfully submits that summary judgment or, in the
{02413385.DOCX} 32
1 altemative, summary adjudication, should be granted.
2
3 Dated: May 13, 2021 PORTER SCOTT
4
5
6 By.
Lindsay A. Goulding
8
9
10
11
12
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18
19
20
21
22
23
24
25
26
27
28
{02413385.DOCX} 33
SUMMARY JUDGMENT OR, EM THE ALTERNATIVE, SUMMARY ADJUDICATION
PROOF OF SERVICE
At the time of service, I was over 18 years of age and not a party to this action. My business
address is 350 University Avenue, Suite 200, Sacramento, CaliFomia 95825.
On the date below, I served the Following document:
MEMORANDUM OF POINTS AND AUTHORITIES I N SUPPORT OF DEFENDANT'S MOTION

FOR SUMMARY JUDGMENT OR, IN THE ALTERNATIVE, SUMMARY ADJUDICATION
XX BY MAIL: I placed the envelope for collection and mailing, following our ordinary business practices. I
office by leaving the documents, in an envelope or package clearly labeled to identify the attomey being
12 served, with a receptionist or an individual in charge of the office, between the hours of nine in the moming
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13 party's residence with some person not younger than 18 years of age between the hours of eight in the
'3 So — vo moming and six in the evening.
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14 BY OVERNIGHT DELIVERY: I enclosed the documents in an envelope or package provided by an
55 § < a ovemight delivery carrier and addressed to the person(s) listed below. I placed the envelope or package for
>
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'£ 15 collection and ovemight delivery at my office or a regularly utilized drop box of the ovemight delivery
Oi < 9 Ov
carrier.
2ii^ ^ ta.
16 BY FAX TRANSMISSION: Based on an agreement of the parties to accept service by fax transmission, I
D t/3
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XX BY ELECTRONIC SERVICE: Based on a court order or an agreement of the parties to accept service by
18 electronic transmission, I caused the documents to be sent to the persons at the electronic notification address
listed below.
19
2216 Katzakian Way
21 Lodi, CA 95242
JJW1980(a),LIVE.COM
22
23 I declare under penalty oF perjury under the laws oF the State oF CaliFomia that the Foregoing
is tme and correct. Executed at Sacramento, CaliFomia on May 13, 2021.
24
25
26
27 Virginia Yao
28
{02413385.DOCX} 34
Court of Appeal, Third Appellate District
Andrea K. Wallin-Rohmann, Clerk
Electronically
Electronically
RECEIVED
RECEIVED
on 6/18/2021
on 6/18/2021
by T. Eyster,
at 4:30:22
Deputy
PM Clerk
Jaroslaw Waszczuk , Plaintiff

2216 Katzakian Way
Lodi, CA 95242
Phone: (209) 663-2977
Fax: (209)787-3131
jjw1980@live.com
Clerk of Court of Appeal, Third Appellate District

914 Capitol Mall
June 18, 2021
Re: Motion to Recall the Remittitur and the Motion for Judicial Notice in the
Waszczuk v. Regents of University of California, C079524 (Cal. Ct. App. Oct. 10,
2017)
Dear Clerk:
I am a Plaintiff representing myself in pro per in the above-captioned case. With
this letter, I am submitting, via TrueFiling, to the Court of Appeal Third Appellate
District (3DCA) a Motion to Recall the Remittitur declaration and exhibits in support of a
reinstatement of the appeal, or alternatively a modification of the 3DCA’s 10/10/2017
erroneous unpublished opinion in Case Waszczuk v. Regents of University of California,
C079524 (Cal. Ct. App. Oct. 10, 2017). The remittitur was issued by 3DCA on January
16, 2018.
In addition to the Motion to Recall the Remittitur, I am submitting a Motion for
Judicial Notice with the declarations and exhibits which should be judicially noticed. I
was forced by the Defendants in this case to file both motions because of the Defendants’
attorneys’ acts of criminal extortion and blackmail before the trial court. They are
notoriously and vexatiously relitigating dismissed cases via an anti-SLAPP motion
stemming from my Second Amended Complaint. The 3DCA affirmed the trial court’s
decision via the 10/10/2017 unpublished opinion, but the Defendants disregarded,
disrespected and defamed the trial court’s judgment and 3DCA unpublished opinion in an
Motion to Recall Remittitur 1

unprecedented manner, reviving the dismissed and decided matters dealt with by three
previous courts just after the remittitur was issued on January 16, 2018.
Both motion documents are bookmarked; however, I had a problem linking or
hyperlinking some of the cited authorities, court cases and statutes using Adobe Acrobat
from the premium legal network Castext, which I am using for research in my litigation.
Sincerely,
________________________________
Jaroslaw Waszczuk - Plaintiff in Pro Per
Attached :
June 18, 2021 Meet and Confer Letter/ attachment addressed to the
Defenddants Attorney from Porter Scotts’ Law Firm Lindsay A. Goulding
Motion to Recall Remittitur 2

ATTACHMENT
2216 Katzakian Way
Lodi, CA 95242
Phone: 209-663-2977
Fax: 209-787-3131
Email: jjw1980@live.com
Lindsay A. Goulding, Attorney

The Regents of the University of California

Oakland, CA 94607
June 18, 2021
Subject: Case No. 34-2013-00155479, Jaroslaw Waszczuk v. The

Regents of the University of California, Ann Madden Rice, Mike Boyd,
Stephen Chilcott,Charles Witcher, Danesha Nichols, Cindy Oropeza,
Brent Seifert, Patrick Putney, Dorin Daniliuc
Re: Copy of Motion to Recall the Remittitur and copy of the Motion
for Judicial Notice in the Waszczuk v. Regents of University of
California, C079524 (Cal. Ct. App. Oct. 10, 2017)
Dear Ms. Goulding:
With this letter, I am submitting to your office copies of the Motion to Recall the
Remittitur and the Motion for Judicial Notice, along with copies of the Declaration in
Support and Waszczuk v. Regents of University of California, C079524 (Cal. Ct. App.
Oct. 10, 2017).
The 47 exhibits, together with copies of the Motion to Recall the Remittitur and
Motion for Judicial Notice, have been downloaded to the enclosed flash drive, in an effort
to be environmentally sustainable. Both enclosed motions include the same 46 exhibits,
-1-
Meet and Confer – Lindsay A. Goulding Re: Motion to Recall the Remittitur
with the exception of Exhibit 47, has been added to the Motion for Judicial Notice.
I noticed that your partner, Olatomiwa T. Aina, is no longer listed in the Porter
Scott directory. I was hoping to meet her in the courtroom of Department 43, but perhaps
Porter Scott’s management is worse than that of the University of California system,
prompting Ms. Aina to move to Fisher Phillips after her short tenure with Porter Scott.
Based on my understanding drawn from other instances of litigation against the Regents
of the University of California and other clients, Porter Scott deserves to be disqualified
by the Court, as there seems to be no other way to end Porter Scott’s attorneys’
gangsterism in the Courts of Law.
With this letter I am also asking you to voluntarily remove, without the Court’s
intervention, all materials related to the stricken by anti-SLAPP motion Causes of Action
(COAs), especially those materials related to the causes No. 3 & 4.
In addition to the above, I am asking you to remove from the court calendars the
examination of my wife in Department 43 scheduled for July 2, 2021. You only need to
ask me for documents. I have all of her records. As you read my Motion to Recall the
Remittitur, you will find that my wife gave me $25,000 to pay the anti-SLAPP legal fees
and costs, but no one who was listed on the Court Order dated June 7, 2018 wanted the
money apart from David Burkett and Daniel Bardzell, who wanted it for themselves ,
and Bardzell was not the one listed on 06/07/2018.
You are not liste as beneficiary of the Junes 7, 2018 Court order and you don’t
represent former three Porter Scott attorney Michael Pott , Douglas Ropel and David
Burkett or Marilyn Gamper. This is what you are doing is scam and extortion criminal
activities. These money don’t belong to you or to Regents of the University of California.
Michael Pott , Douglas Ropel , David Burkett and Marylin Gamper got paid legals
fees by Sedgwick Insurance in 2015.
Furthermore, in 2019, the State of California reimbursed me for the monies stolen
by my lawyer, Douglas Stein, to whom I had paid a retainer. I sent a letter to former
Porter Scott attorneys Michael Pott and Douglas Ropel and asked them if they wanted the
money, but received no answer. I sent a check to Porter Scott Paralegal Marilyn Gamper
-2-
in the amount of $520. She was prohibited from cashing the check. The former judge
from Department 53, David I . Brown, who was replaced in January 2021 by the Hon.
Shama Hakim Mesiwala, left behind two court orders with sanctions against me totaling
$1300 each, or $2600 in all. In 2019, Daniel Bardzell attempted to cash the $1300 check
using the Regents of the California name, but Judge Brown ordered him to return the
check. Please let me know who is entitled to or eligible to receive the legal fees and
sanctions awarded in the anti-SLAPP motion proceeding. I would like to resolve this
without playing games in Court by relitigating COAs dismissed by the anti-SLAPP
motion in 2015.
In addition to the above, on June 28, 2021, I have scheduled a video conference
with a Criminal Court in Poland for compensation for my repression and incarceration in
an internment camp by communists between 1981 and 1982. Between 1980 and 1981, I
was one of the leaders of the anti-communist labor movement “Solidarity.” The
communist repression was acknowledged by the post-communist era government of the
Republic of Poland as crimes against humanity (see attachment).
https://www.scribd.com/document/494446114/Solidarity-Anti-Communist-
Movement-Poland-1980-1982
What the Regents of the University of California, with the aid of those employed
by Porter Scott, did to me and my family in the US is also a crime against humanity.
I am expecting that, in August 2021, I will receive compensation from Poland.
Then, I will no longer need to use my wife’s money to deal with the litigation against the
Regents of the University of California, but you must let me know to whom I have to
write any necessary checks. I am giving you until June 21, 2021 to decide what you want
to do and to let me know who should be the beneficiary of the June 7, 2018 Court Order.
Sincerely,
Jaroslaw Waszczuk
Enclosure
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Mailing List
Re: Waszczuk v. Regents of the University of California et al. Sacramento County No.
34201300155479CUWTGDS
Court Sacramento County Superior Court

Hon. Shama H. Mesiwala - Department 53
813 6th Street, 2nd Floor

Oakland, CA 94607
Donna Hershkowitz – The State Bar of California Interim Executive Director

Vanessa Holton -The State Bar of California General Counsel
80 Howard Street
Jorge E. Navarrete
Supreme Court Clerk/Administrator
California Supreme Court
350 McAllister St.
San Francisco, CA 94102
Clerk of Court of Appeal, Third Appellate District

914 Capitol Mall
-4-
ATTACHMENT
MS/201909038339/Waszczuk
District Court in Krosno
II Criminal Division
ul. Sienkiewicza 12
38-400 Krosno
Mailing date: May 17, 2021

File reference number: II Ko 186/19
Please state the date and file reference number in your response
Date: June 28, 2021, at 08:00, room 107
Mr.
Jarosław Waszczuk
address for service
Mateusz Stefaniak, Attorney Trainee
ul. Danusi 2a/1
80-434 Gdańsk
NOTICE
The District Court in Krosno notifies you as the applicant that the main hearing in case II
Ko 186/19 for compensation for internment will be held on June 28, 2021, at 08:00, room 107
in the local court at 12 Sienkiewicza Street.
At the same time the Court informs you that during this hearing (i.e. on June 28,
2021, at 8:00 a.m. Polish time) you will be heard in your place of residence, through
technical devices allowing the transmission of sound and image, therefore you should be at
the Court's disposal at that time.
Senior court clerk

[signature]
Renata Walczak-Wójcik
INFORMATION
due to the spread of the SARS-Co V-2 virus across the country.
The Court informs that the parties, participants of the court proceedings and attorneys
will be admitted to the District Court building in Krosno not earlier than 15 minutes before the
planned date of a session or hearing.
There is an obligation to use personal protective equipment - shields or masks by the
parties and attorneys during open hearings.
An obligation is introduced for participants of public hearings, their attorneys, and the
public to disinfect their hands before each entry into the courtroom and to wear disposable
gloves.
An obligation is introduced to keep a distance of 2 meters between persons present in
court corridors.
File reference number II Ko 186/19
DECISION
On May 12, 2021
District Court in Krosno, II Criminal Division, composed of:

Presiding Judge: District Court Judge Janusz Szarek
Court clerk: Senior court clerk Renata Walczak-Wójcik
having examined, at a session held on May 12, 2021, on the application of Jarosław Waszczuk
for compensation for internment related to the Act of February 23, 1991, on declaring invalid the
judgments against persons repressed for activities for the benefit of the independent state of
Poland - compensation.
on resumption of suspended proceedings
pursuant to Article 22 § I of the Code of Criminal Procedure.
decides
- to resume the suspended proceedings in the present case.
STATEMENT OF REASONS
In connection with the need to interview applicant Jarosław Waszczuk in this case, the
Krosno District Court requested the Consulate General of the Republic of Poland in Los Angeles
to interview the applicant at that consular post. Due to the COVID 19 pandemic, to date, the
Polish consular post has failed to interview the applicant.
In this situation, the applicant will be interviewed by means of technical equipment
enabling this action to be conducted remotely with simultaneous transmission of sound and
images. This circumstance causes the reason for suspension of the proceedings within the
meaning of Article 22 § 1 of the Code of Criminal Procedure to cease.
[stamp] [round seal with Polish emblem]

[stamp]
INSTRUCTIONS DISTRICT COURT IN KROSNO
Proper signatures
This decision may be appealed to the Court *2* on the
original.
of Appeals in Rzeszów by the District Court For
compliance:
in Krosno within 7 days as of the date of
Senior court clerk
receiving this decision.
[signature]
Renata Walczak-Wójcik
Court of Appeal, Third Appellate District Court of Appeal, Third Appellate District
Andrea K. Wallin-Rohmann, Clerk Andrea K. Wallin-Rohmann, Clerk
Electronically RECEIVED on 6/18/2021 at 4:30:22 PM Electronically FILED on 6/18/2021 by T. Eyster, Deputy Clerk
Jaroslaw Waszczuk
2216 Katzakian Way
Lodi, CA 95242
Phone: 209-663-2977
Fax: 209-370-3131
E-mail: jjw1980@live.com
Appellant, In Pro Per
Jaroslaw Waszczuk Court of Appeal No. C079524

Plaintiff and Appellant,
Sacramento County Superior Court
v. No. 34-2013-00155479-CU-WT-GDS
The Regents of the University of Notice of Appeal Filed on June 11, 2015
California, UC Davis, UC Davis
Medical Center, UC Davis Health Remittitur Issued on January 16,2018
System, Ann Madden Rice, Mike
Boyd, Stephen Chilcott, Charles APPELLANT’S DECLARATION IN
Witcher, Danesha Nichols, Cindy SUPPORT OF THE
Oropeza, Brent Seifert, Patrick APPLICATION/MOTION TO RECALL
Putney, Dorin Daniliuc and Does REMITTITUR
1– 50,
DECLARATION IN SUPPORT
I, JAROSLAW WASZCZUK, Plaintiff and Appellant,

(hereafter Waszczuk) declare the following:
1. Waszczuk was employed by the University of California, UC
Davis Medical Center (UCDMC) from June 1999 to February 2009 as a
central plant operator/power plant technician and from February 9, 2009, to
August 31, 2011 as the assistant development engineer.
1
DECLARATION IN SUPPORT OF MOTION TO RECALL REMITTITUR
2. On August 31, 2011, Waszczuk’s employer UCDMC
permanently removed Waszczuk from the premises and on December 7,
2012 formally terminated Waszczuk’s employment.
3. On December 4, 2013, Waszczuk filed a wrongful
termination complaint in pro per against the Regents of the University of
California, (UC Regents), UC Davis Health System, UC Davis, UC
Davis Medical Center and nine of its employees who terrorized or
ordered others to terrorize and harass him. (See: Motion to Recall the
Remittitur Page 29 Exhibit 46)
4. Waszczuk’s December 2013 wrongful termination complaint was
simply and liberally construed. Waszczuk based the complaint on six causes of
action, which included a violation and breach of the 2009 Settlement
Agreement that Waszczuk had signed in good faith with the Regents of the
University of California and UC Davis Policy PPSM 23, which is the employee
annual performance review (evaluation) policy.
Waszczuk considered these two causes of action (COAs) the most
important in the complaint and were the bases to prevail in the lawsuit against
the Defendants.
4. On June 16, 2014, Waszczuk’s attorney, Douglas Stein filed
the First Amended Complaint (FAC) with eight causes of action, and by
amendment he changed the venue of the Waszczuk initial complaint by
removing the two most important COAs Nos. 5 and 6 from Waszczuk ‘s
initial 12/4/2013 complaint.
5. On September 30, 2014, Attorney Stein, while under suspension
of his license to practice law, filed the SAC, which was identical to the FAC
with regard to the COAs. In his briefs on the appeal, the Waszczuk provided
specific information about how the SAC filing by Stein and the defendants’
attorney, Michael Pott played out in court (see Appellant’s Reply Brief, page
no. 26, and Appellant’s Petition for Rehearing, page nos. 29–34).
2
7. On December 1, 2014, five days after the Waszczuk visited Stein,
Defendants’ Attorney from Porter Scott law firm Michael Pott filed a frivolous
and fraudulent Special Motion to Strike the anti-SLAPP Motion, CCP § 425.16,
against the first four COAs to end Waszczuk’s lawsuit. The subjects to strike
were the four causes of action from Waszczuk’s defective SAC COAs. The
defendants’ anti-SLAPP motion is devoid of meaningful factual analysis,
invokes general statements of law, and mischaracterizes the quintessence of
Waszczuk’s action.
8. On or about December 15, 2014, Wells Fargo Bank informed the
Waszczuk that the retainer’s special bank account opened by Stein with the
Appellant’s $20,000 was empty and had been over-drafted. The Waszczuk
questioned Stein about this, dismissed him from both cases, and submitted a
complaint about him to the State Bar of California.
9. From the State Bar investigation In re Stein, S245982 (Cal. Mar.
1, 2018) http://members.calbar.ca.gov/courtDocs/15-O-10110-2.pdf Waszczuk
learned that between June 2, 2014, and December 2, 2014, the respondent
issued 14 checks and initiated 31 debits directly from the trust account, totaling
$4,991.82, for personal transactions. He also learned that on December 3, 2014,
the client’s trust account had a negative balance of $-194.33.
Stein had rejected the $20,000 that Waszczuk offered him on
November 25, 2014, but instead withdrew approximately $15,000 from the
trust account on December 3, 2014, two days after the defendants’ attorney,
Pott, filed the anti-SLAPP Motion. If Stein had told Waszczuk in
November 2014 that he needed money because he was in a difficult
financial situation, Waszczuk would have lent him $10,000. However.
taking money from the trust account without informing Waszczuk and not
objecting to the anti-SLAPP motion gave the Waszczuk no choice but to
dismiss Stein from both cases.
10. In December 2014 Waszczuk was planning a trip to Poland
for the Christmas and New Year holidays to visit his family. Waszczuk
3
canceled the trip when he learned that on December 1, 2014, Defendants’
attorney filed the anti-SLAPP motion and observed Stein’s peculiar
approach to the filed motion. Since then, Waszczuk has not visited his
native country for fear of being placed on a “no-fly” list by UC President
Janet Napolitano’s colleagues from the U.S Department of Homeland
Security and then being barred from returning to the USA, just as had
happened to Yonas Fikre who was barred from air travel for over six years
for refusing to be an informant to the FBI. Fikre v. Fed. Bureau of
Investigation, 904 F.3d 1033 (9th Cir. 2018)
11. On December 15 or 16, 2014, during a phone conversation, Stein
told the Waszczuk that he would get a lot of money in the new year and would
return the stolen retainer to Waszczuk.
12. On January 23, 2015, Waszczuk filed his Plaintiff’s Opposition to
the Defendants’ anti-SLAPP Motion. A half an hour after the court clerk
endorsed and filed the Appellant’s Opposition, the defendants’ leading attorney
and Porter Scott shareholder, Pott, informed the Waszczuk by e-mail that
January 23, 2015, was his last day of employment with Porter Scott. Pott was
replaced by another Porter Scott shareholder, David Burkett, and associate
attorney, Douglas Ropel.
THE DEFENDANT’S FORMER ATTORNEY AND

SHAREHOLDER OF THE PORTER SCOTT LAW FIRM DAVID
PONTUS EUGENE BURKETT J.D SBN # 241896
13.. David Burkett, the Defendants’ former attorney, employee

and shareholder of the Porter Scott law firm for 13 years, left Porter Scott
in October 2019. He was immediately replaced in this case by another
Porter Scott attorney, Nancy Sheehan. Gravely ill Nancy Sheehan died one
month later on November 23, 2019
https://www.legacy.com/obituaries/sacbee/obituary.aspx?n=nancy-
joan-sheehan&pid=194994093
4
14. David Burkett had not wanted to be associated with Waszczuk’s
case, but he was somehow forced into a four-year involvement with the
fraudulent and frivolous anti-SLAPP motion left for him by Michael Pott.
Burkett left Porter Scott law firm and this case with $320 legal fees awarded to
him by a court order dated June 7, 2018.
15. The Defendants’ Attorney David Burkett did everything possible
to make Waszczuk end all litigation against the Regents of the University of
California and five individual defendants Michael Boyd, Stephen Chilcott,
Danesha Nichols, Brent Seifert and Cindi Oropeza or reverse the trial Court
Order dated February 9, 2015 (Hon. David I. Brown).
16. On February 27, 2015, David Burkett sent his associate, Douglas
Ropel, to a hearing before Judge Shelleyanne Chang in Jaroslaw Jerry
Waszczuk v. California Unemployment Insurance Appeals Board
(CUIAB)(ROA #28) Case No. 34-2013-80001699-CU-WM-GDS with the UC
Regents as a Real Party of Interest. Waszczuk v. Cal. Unemployment Ins.
Appeals Bd., C079254 (Cal. Ct. App. Dec. 27, 2018) Neither Ropel nor Burkett
was counsel of record for this case in February 2015.
Burkett sent Ropel to the court for the sole purpose of confronting and
attacking Waszczuk prior the hearing. Ropel made vile, despicable threats to go
after Waszczuk’s wife if he would not agree to drop the litigation against the
Defendants in exchange for legal fees in connection with the anti-SLAPP
motion. In February 2015, legal fees were not awarded to any party. ( See:
Waszczuk Petition for Rehearing in Waszczuk v. Regents of Univ. of Cal., C079524
(Cal. Ct. App. Oct. 10, 2017) Page No. 14. )
Defendants’ former attorneys from Porter Scott, Michael Pott, David
Burkett, Douglas and most likely Thomas L. Riordan and Attorney Ashante
Norton from the California Attorney General’s office know all details of what
happened to Waszczuk’s unemployment benefits that were reinstated by the
EDD in May of 2014. Waszczuk will further address this issue subsequent to
5
this Motion to Recall Remittitur for the Waszczuk v. Cal. Unemployment Ins.
Appeals Bd., C079254 (Cal. Ct. App. Dec. 27, 2018) case. Stealing the
unemployment insurance benefits from somebody is a serious crime. ( See
Exhibit # 22 in Motion to Recall Remittitur) This serious crime which was
covered up needs to be uncovered. The bottom line is that the Waszczuk’s
unemployment insurance benefit was stolen in May 2015.
12. After Judge David I. Brown issued a final order granting the
Special Motion to Strike the four COAs from Waszczuk’s defective SAC on
4/14//2015 (ROA # 80), Defendants’ Attorneys Burkett and Ropel filed a
motion for grossly inflated legal fees and costs on May 11,2015 for the anti-
SLAPP motion. Porter Scott shareholder and leading attorney David Burkett in
the case declared (ROA 85) that he had only worked on the anti-SLAPP motion
for 1.2 hours, at a rate of $260 per hour, thus totaling $312 of the $32,738 of
fees that the defendants’ attorney was claiming. The legal fees show that
Burkett did not participate because he knew more than he wanted to know
about this fraudulent motion.
13. On May 19, 2015, just one month after the defendants obtained
the favorable decision to strike the COAs from the Waszczuk SAC and eight
days after they filed the Motion for Fees and Cost, unexpectedly, their attorney,
Burkett, asked the Waszczuk by e-mail what his settlement offer was.
Waszczuk outlined the settlement offer in his eight-page reply, dated May 21,
2015 (see Motion to Recall Remittitur, Exhibit No. 28). The Waszczuk recalls
that Burkett repeated his question about the settlement in exchange for anti-
SLAPP motion legal fees in July or August 2015.
14. On June 11, 2015, due to a lack of response from Burkett about
the Appellant’s settlement offer, the Waszczuk filed a timely Notice of Appeal
from the April 14, 2015 order by Judge Brown that granted the defendants a
special motion to strike the four COAs from the Appellant’s SAC.
15. On July 25, 2016, Defendants’ Attorney David Burkett
deliberately filed a defective Respondent Brief (RB ). Burkett’s RB did not cite
6
any court record but was a desperate attempt to receive a negative decision
from the Court of Appeal reversing the trial Court Order and Judgement
granting the anti-SLAPP motion to the Defendants by striking the first four
causes of action. Defendant’s Attorney Burkett, by his faulty RB filed on
07/25/2016, was begging the Court of Appeal to reverse the trial Court Order
dated April 14, 2015. For some reason somebody in the Porter Scott law firm
and somebody in the Court of Appeal made a different decision, and on
November 9, 2016 the Court, by its own motion, ordered that the RB filed July
25, 2016 be stricken for “failure to support any reference to a matter in the
record by a citation to the volume and page number of the record where the
matter appears.” (Cal. Rules of Court, rule 8.204(a)((1)(c).) The Court ordered
Respondent to refile the RB on or before December 15, 2016, instead of
rewarding Burkett and reversing the trial court’s April 14, 2015 Order and
Judgment which granted Defendants’ anti-SLAPP motion.
17. On August 8, 2017, after oral argument, Defendants’
Attorney David Burkett, infuriated by statements made by the Court of Appeal
Justice Panel during the oral argument hearing and anticipating the decision of
the Court of Appeal, snapped and unloaded his anger on Waszczuk and
Waszczuk’s wife with vile threats. Waszczuk thought that Burkett’s
unwarranted attack in the 3DCA building would lead to fisticuffs. Instead of
being happy to win the appeal, Burkett instead became angered to the brink of
beating up 66-year-old Waszczuk right there in the halls of justice. Fortunately
for Waszczuk, he was accompanied by a friend. Unbelievable.
18. Waszczuk’s Application/Motion to Recall Remittitur shows the
pattern of Defendants’ Attorney David Burkett’s obsession with the four
stricken COAs from Waszczuk’s defective SAC which needs to be amended.
David Burkett and his successors’ relitigating of the four stricken COAs using
the fraudulent, oppressive anti-SLAPP motion after the remittitur was issued on
January 16, 2018 is an unprecedented abuse of the court system. Waszczuk
estimated that five consecutive, voluminous motions for monetary and
7
terminating sanctions filed in 2018–2019 by Burkett and his successors in cost
five times more than the anti-SLAPP motion filed by the Defendants on
December 1, 2014.
19. In addition to the prohibited-by-law prelitigation of matters which
have already been litigated, the filed motions to compel monetary and
terminating sanctions show how grossly inflated the $32,738 the claimed legal
fees and costs were for the anti-SLAPP motion by Burkett and the associated
Douglas Ropel. For the similar and even more time-consuming motions to
compel monetary and terminating sanction, Defendant’s attorneys were
demanding to be paid $5,000 for each filed motion. This is quite a different
number than $32,738 for one motion.
CONCLUSION
20. Waszczuk concluded his 12/04/2019 opposition to the
Defendant’s 10/23/2019 to the Judgment Creditors’ Further Motion to
Compel Responses to Judgment Debtors’ Interrogatories and Request for
Production of Documents as follows: (See: Motion to Recall Remittitur
Exhibit No. 31)
This anti-SLAPP motion, filed on December 1,

2014, against Plaintiff Waszczuk is most likely the most
expensive and most-time-consuming anti-SLAPP for the
Regents of the University California and for their notorious
advocates from Porter Scott Law corporation based in
Sacramento, CA since the California Legislature enacted
its anti-SLAPP law, California Code of Civil procedure §
425. 16, in 1992.
The Regents of the University of California or real
owners of the UC Davis Medical Center 27 MW
cogeneration power plant were stripped from
approximately or at least $35,000,000 tax-free, cash since
their advocates from Porter Scott filed the anti-SLAPP
motion on December 1, 2014. $35,000,000 tax-free, cash is
lot of money to pay for an anti-SLAPP motion.
In Un Hui Nam v. Regents of the Univ. of Cal., 1 Cal.App.5th 1176
(Cal. Ct. App. 2016) the Court ruled that: “The California anti-SLAPP
8
statute was intended to counter the “disturbing increase in lawsuits brought
primarily to chill the valid exercise of the constitutional rights of freedom
of speech and petition for the redress of grievances.” (Code Civ. Proc.,
§ 425.16, subd. (a).) It has been suggested that “[t]he cure has become the
disease—SLAPP motions are now just the latest form of abusive
litigation.” (Navellier v. Sletten (2002) 29 Cal.4th 82, 96 (dis. opn. of
Brown, J.) (Navellier).) And the disease would become fatal for most
harassment, discrimination, and retaliation actions against public employers
if we were to accept the Regents of the University of California’s
(University) misguided reading of the anti-SLAPP law and reverse the trial
court’s denial of its motion to strike.”
Waszczuk is still wondering why Un Hui Nam v. Regents of the
Univ. of Cal., 1 Cal.App.5th 1176 (Cal. Ct. App. 2016) is omitted from
Waszczuk ‘s 10/10/217 3DCA unpublished opinion. The anti-SLAPP
motion in Waszczuk’s litigations with the University of California is a
classic example of abusive litigation brought by UC Davis Medical Center
by whom both Un Hui Nam and Waszczuk were employed.
I declare under the penalty of perjury under the laws of the State of
California that the foregoing is true and correct and that this Declaration
was executed on the 18th day of June 2021 at Lodi, California.
________________________________
Jaroslaw Waszczuk,
Plaintiff and Waszczuk In Pro Per
9
CERTIFICATE OF COMPLIANCE
Pursuant to California Rules of Court, rule 8.360(b)(1), I certify that

this Declaration in Support to Recall the Remittitur in Case Waszczuk v.
Regents of Univ. of Cal., C079524 (Cal. Ct. App. Oct. 10, 2017) contains
2599 words, based on the word- count feature of my word-processing
program.
DATED: June 18, 2021
__________________________
Jaroslaw Waszczuk
Plaintiff & Appellant, In Pro Per
10
Proof of Service by US Mail and TrueFiling
Re:Waszczuk v. Regents of Univ. of Cal., C079524 (Cal. Ct. App. Oct. 10,
2017)
Re: 3DCA Case : Jaroslaw Waszczuk v. The Regents of the University of
California- Case No.: 34-2013-00155479
I, IRENA WASZCZUK the undersigned, declare that 1 am over 18

years of age and not a party to the within cause; my address is 2216
Katzakian Way, Lodi, CA. 95242. On June 17, 2021, I served a true copy
of the attached each of the following,
By placing the same copy in an envelope or envelopes addressed
respectively as follows: Plaintiff and Appellant Jaroslaw Waszczuk’
Declaration in Support the Motion to Recall Remittitur
Lindsay A. Goulding -Via U.S Mail

Clerk of the Sacramento County Superior Court Via U.S Mail

Department 53 – Hon. Shama Hakim Mesiwala
Jorge E. Navarrete - Via TrueFiling

350 McAllister St.
I declare under penalty of perjury of the laws of the State of

California that
the foregoing is true and correct. Executed on June 18, 2021 , at
Lodi CA
_____________________________________________________
IRENA WASZCZUK
11

JAROSLAW WASZCZUK, Court of Appeal Case No. C079524
Plaintiff and Appellant, C.C.P § 425.16
v. (Super. Ct. No. 34-2013-34-2013-00155479)

Notice of Appeal filed June 11, 2015
THE REGENTS OF THE Remittitur Issued January 16, 2018
UNIVERSITY OF CALIFORNIA:
Ann Madden Rice, Mike Boyd,
Stephen Chilcott, Charles Witcher,
Danesha Nichols, Cindy Oropeza,
Brent Seifert, Patrick Putney, Dorin
Daniliuc,
Appeal from an Order

Of The Superior Court, County of Sacramento
Hon. David I. Brown, Judge
APPELLANT’S MOTION TO RECALL THE REMITTITUR AND

REINSTATE THE APPEAL OR ALTERNATIVELY MODIFY THE
UNPUBLISHED OPINION
Jaroslaw Waszczuk
2216 Katzakian Way
Lodi, CA 95242
Phone: 209-663-2977
Fax: 209-787-3131
TO THE HONORABLE VANCE W. RAYE, PRESIDING JUSTICE,

AND TO THE ASSOCIATE JUSTICES OF THE COURT OF APPEAL
OF THE STATE OF CALIFORNIA, THIRD APPELLATE DISTRICT:
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TABLE OF CONTENTS
TABLE OF AUTHORITIES ………………………………..…………..3
INTRODUCTION ………………………………………………………12
THE REASON FOR THIS MOTION………………………………….13
PROCEDURAL AND FACTUAL BACKGROUND…………,,,……..15
STATEMENTS OF FACTS AFTER ISSUANCE OF THE

REMITTITUR ON JANUARY 16, 2018 BY THE COURT OF
APPEAL THIRD APPELLATE
DISTRICT………………………………………………………………..16
I. DEFENDANTS’ VEXATIOUS, MALICIOUS, AND NEFARIOUS

RELITIGATING OF THE DISMISSED CAUSES OF ACTION .16
II. NEW ATTORNEYS FOR THE DEFENDANTS FROM PORTER

SCOTT: LINDSAY A. GOULDING AND
OLATOMIWA T. AINA……………………………………… …28
MEMORANDUM OF POINTS AND AUTHORITIES AND

ARGUMENT……………………………………………………..………31
I. THE REMITTITUR MUST BE RECALLED AND THE

ERRONEOUS UNPUBLISHED OPINION FILED ON
OCTOBER 10, 2017 in Waszczuk v. Regents of University. Of
California C079524 (Cal. Ct. App. Oct. 10, 2017) MUST BE
MODIFIED……………………………………..………………….30
II. THE REMITTITUR MUST BE RECALLED TO STOP THE

MALICIOUS ABUSE OF THE JUDICIAL SYSTEM BY THE
DEFENDANTS ……………………………………………………35
III. THE COURT OF APPEAL MUST RECALL THE REMITTITUR

TO PRECLUDE THE FURTHER DEFENDANTS’ EGREGIOUS
MISCONDUCT………………………………………….…………37
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CONCLUSION ………………………………………………………….39
CERTIFICATE OF COMPLIANCE………………………….……….41
PROOF OF SERVICE ………………………………………………….42
.......43
EXHIBITS 1-46..................................................................................
CASES
Bryan v. Bank of America, 86 Cal.App.4th 185 (Cal. Ct. App. 2001)…….13
In re Stein, S245982 (Cal. Mar. 1, 2018)………………… …,…………….15

Sporn v. Home Depot USA, Inc. (2005) 126 Cal.App.4th 1294, 1300 [ 24
Cal.Rptr.3d 780]…………………………………………………,…………29
In re Grunau, 86 Cal.Rptr.3d 908, 169 Cal.App.4th 997 (Cal.App. Dist.6

12/30/2008)…………………………………………….. ………….…… …32
In re Rothrock (193 9) 14 Cal. 2d 34, 38-39 [92 P.2d 634]………………….32
In re McGee (195 1) 37 Cal. 2d 61 8-9 [229 P.2d 780])…………….……….32
In re Rothrock, 14 Cal.2d 34 (Cal. 1939)……………………….……………32
Weikel v. TCW Realty Fund II Holding Co. (1997) 55 Cal.App.4th 1234,

1245……………………………………………………..……..……………..34
Flatley v. Mauro 39 Cal.4th 299 (Cal. 2006),…………………..…………….35
Stenehjem v. Sareen, 226 Cal.App.4th 1405 (Cal. Ct. App. 2014)……………...35
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Cheveldave v. Tri Palms Unified Owners Ass’n, 238 Cal. Rptr. 3d 792
(Cal. Ct. App. 2018)……………………………………………… …..…35,36
Superior Court (1990) 51 Cal.3d 335, 341, fn. 3, 272 Cal.Rptr. 767, 795 P.2d
1223.)…………………………………………………………………..……35
Lucido v. Superior Court (1990) 51 Cal.3d 335, 341, fn. 3, 272 Cal.Rptr.
767, 795 P.2d 1223……………….28
Mycogen Corp. v. Monsanto Co. (2002) 28 Cal.4th 888, 896, 123 Cal.Rptr.2d
432, 51 P.3d 297……………………………………………………………….36
Lucido v. Superior Court, supra, 51 Cal.3d at p. 341, 272 Cal.Rptr. 767, 795
P.2d1223.)………………………………………………………….………36,37
F.E.V. v. City of Anaheim, 15 Cal.App.5th 462 (Cal. Ct. App. 2017)………...36
Panos v. Great Western Packing Co. (1943) 21 Cal.2d 636, 637, 134 P.2d
242………………………………………………………………………….….36
Roos v. Red (2005) 130 Cal.App.4th 870, 887, 30 Cal.Rptr.3d

446……………………………………………………………………..………37
Younan v. Caruso (1996) 51 Cal.App.4th 401, 407, 59 Cal.Rptr.2d 103.)……37
Chambers v. Nasco, Inc., 501 U.S. 32 (1991)…………………..……………..37
Hazel-Atlas Glass Co. v. Hartford-Empire Co., 322 U.S. 238, 64 S.Ct. 997, 88
L.Ed. 1250 (1944)………………………………………….…………….……38
Universal Oil Products Co. v. Root Refining Co., 328 U.S. 575, 580, 66 S.Ct.
1176, 1179, 90 L.Ed. 1447 (1946)………………………………………...…..38
In Peat, Marwick, Mitchell Co. v. Superior Court, 200 Cal.App.3d 272
(Cal. Ct.App.1988)…………………………………………...………………..38
Burton v. Sosinsky (1988) 203 Cal. App. 3d 562, 573 [250 Cal.Rptr.
33]………………………………………………………………….…………..38
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California Satellite Systems, Inc. v. Nichols (1985) 170 Cal. App. 3d
56, 70 [216 Cal.Rptr. 180]………………..30
Buchanan Home and Auto Supply Co v Firestone Tire and Rubber Co., 544
F.Supp. 242, 244-245 (D SC, 1981………………………………………...….38
Mas v Coca-Cola Co., 163 F.2d 505, 507 (CA 4, 1947)…………………...….38
STATUTES
California Code of Civil Procedure Section 425.16 ………………...….13,15,35
Government Code § 12940(a)………………………………..……………..17,
California Government Code §§ 8547 et. Seq……………………………………………..…17
California Code of Civil Procedure Section C.C.P. § 916(a)………………….33
California Penal Code § 518…………………………………………..……….35
California Health and safety Code sec. 1278.5(6) …………..………………..15
COURT RULES
California Rules of Court, rule 8.272(c) ………………………..…………..…12
California Rules of Court -Rule 3.1110 (b) (1)…………………………….18,29
MISCELLANEOUS AUTHORITIES
Waszczuk v. Regents of Univ. of Cal., California Supreme Court, Case No.

S245879……………………………………………………………………..…16
7 Witkin, Cal. Procedure (4th ed. 1997) Judgment, § 280, p.820……………..34

EXHIBITS
Number and Title of the Exhibit: Page Number.
1. Remittitur to Trial Court Clerk, dated 01/16/20182.

10/10/2017- 3DCA unpublished opinions in the case
Waszczuk v. Regents of Univ. of Cal., C079524 (Cal. Ct. App. Oct.
10, 2017)
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3. 02/09/2015- Court Order granting an anti-SLAPP motion to
Defendants Mike Boyd, Stephen Chilcott, Danesha Nichols, Brent
Seifert, and Cindi Oropeza in Sacramento County Superior Court Case
No: 34-2013-4. 00155479-CU-WT-GDS Waszczuk vs. The Regents of
the University of California, Hon. David I. Brown.
4. 04//25/2018- Defendant Regents of the University of California's

Request for Production of Documents to Plaintiff, set one
5. 10/03/2018- Defendants' Memorandum of Points and Authorities in
Support of Defendants' Motion to Compel Verified Responses for
Monetary and Terminating Sanctions, filed in the wrong Court,
Department 54
6. 10/11/2018- Waszczuk’s letter to Court Clerk in Department 54, Re:
Defendants’ 10/03/2018 Motion to Compel, monetary, and
terminating sanctions
7. 10/31/2018- Court Order sanctioning Waszczuk with $520. Re:
Defendants’ Motion to Compel, monetary and terminating
sanctions, Hon. David I. Brown
8. 11/14/2018- Duplicative Court Order sanctioning Waszczuk with
$520. Re: Defendants’ Motion to Compel, monetary and
terminating sanctions, Hon. David I. Brown
9. 02/08/2019- Court Order Re: Hearing on Order of Examination of
Judgment Debtor (Waszczuk) in Dept. 43, Hon. Thadd A. Blizzard
10. 02/10/2019- Waszczuk’s correspondence sent to Defendants’
Attorneys Daniel Bardzell and David Burkett, Re: Appearance and
Examination on February 8, 2019 at 9:00 a.m. at Department 43.
Hon. Thadd A. Blizzard, Case No. 34-2013-00155479, Jaroslaw
Waszczuk v. The Regents of the University of California- Meeting
summary with Bardzell
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11. 02/11/2019- Defendants’ Attorneys Daniel Bardzell and David
Burkett, Memorandum of Points and Authorities in Support of
Defendant's Motion to Compel Further Verified Responses to
Special Interrogatories Set One, Form Interrogatories - General Set
One, Form Interrogatories - Employment Set One, and for
monetary and terminating sanctions
12. 03/11/2019- Waszczuk’s ex parte application for an order permitting
him to file late the Plaintiff's opposition to Defendants' Motion to
Compel and for monetary and terminating sanctions
13. 03/13/2019- Order Determining Disposition of 03/11/2019 of
Waszczuk Ex Parte Application, Re: Defendants’ Motion to Compel
and for monetary and terminating sanctions
Defendants', Motion to Compel Responses to Judgment Debtor
Interrogatories and Request for Production of Documents, and for
15. 04/12/2019- Waszczuk’s Opposition to the Defendants’, the Regents
of the University of California, frivolous and unwarranted Motion to
Compel for monetary and terminating sanctions
16. 04/26/2019- Court Order sanctioning Waszczuk with $1300, Hon.
Steven H. Rodda, Dept. 53, Re: Defendants’ Motion to Compel for
17. 04/26/2019- Court Reporter Transcript from the Court hearing with
Hon. Steven H. Rodda, Dept. 53. Defendants’ Motion to Compel for
monetary and terminating sanctions18. 06/12/2019-
Defendants’ Attorneys Daniel Bardzell and David Burkett,
Memorandum of Points and Authorities in Support of Defendants',
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Motion to Compel Responses to Judgment Debtor Interrogatories and
Request for Production of Documents, and for monetary and
terminating sanctions19. 07/05/2019- Waszczuk’s Opposition to
the 06/12/2019 Defendants’ Motion to Compel Responses to
Judgment Debtor Interrogatories and Request for Production of
Documents, and for monetary and terminating sanctions20.
07/05/2019- Waszczuk’s correspondence sent to the anti-
SLAPP motion Defendants’ former Attorneys Michael Pott and
Douglas Ropel, Re: legal fees awarded to them by the June 7, 2018
Court Order, Hon. David I. Brown, Dept. 5321. 05/22/2019 &
06/05/2019- Waszczuk’s inquiry sent to the State of California
Controller’s Office, Re: Waszczuk’s short-term disability benefits,
which were denied by Defendants in November 2011 but resurfaced
on March 21, 2019 as unclaimed property valued at $4,545.08.
22. 05/14/2014- State of California Employment Development
Department (EDD) notification informing Waszczuk that his
unemployment insurance benefits was reinstated after previously
being denied in 2013 by EDD, and Waszczuk’s Inquiry with EDD
dated May 25, 2014.
23. 08/08/2019- The California State Bar Decision and a copy of check
No. 01844793 in the amount of $14,500 issued to Waszczuk by the
California State Bar Client Security Fund as a reimbursement for the
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retainer stolen in 2014 from Waszczuk by his attorney Douglas
Stein. See Case : In re Stein, S245982 (Cal. Mar. 1, 2018)
24. 07/19/2019- Court Order sanctioning Waszczuk with $1300. Hon.
David I. Brown, Dept. 53, Re: Defendants’ 06/12/2019 motion to
compel for monetary and terminating sanctions
Hon. David I. Brown, Dept . 53, Re: Defendants’ 06/12/2019 motion
to compel for monetary and terminating sanctions
26. 10/23/2019- Defendants’ Attorneys Daniel Bardzell and Nancy
Sheehan, Memorandum of Points and Authorities in Support of
monetary sanctions
27. 10/24/2019- Defendants’ Attorney Daniel Bardzell’s e-mail
correspondence, Re: Defendants’ (the Regents of the University of
California) settlement offer
28. 05/21/2015- Waszczuk’ Response to the Defendants’ Attorney
David Burkett’s e-mail inquiry, dated May 19, 2015—Settlement
Offer
29. 11/15/2019- Defendants’ Attorney Daniel Bardzell’s correspondence
demanding Waszczuk pay the Regents of the University of
California the anti-SLAPP motion legal fees and monetary
sanctions
30. 11/18/2019- Copy of Check No. 139 in the amount of $1300 issued
by Waszczuk to the Regents of the University of California, with
attached 07/19/2018 Court Order which sanctioned Waszczuk with
$1300, Hon. David I. Brown
31. 12/04/2019- Waszczuk’s Opposition to 10/23/2019, Defendants’
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Attorneys Daniel Bardzell and Nancy Sheehan’s Motion to Compel
Responses to Judgment Debtor Interrogatories and Request for
Production of Documents; and for monetary sanctions
32. 12/04/2019- Defendants’ new Attorneys Amanda Iler, Derek Hayes,
and Daniel Bardzell’s reply to 12/04/2019, Waszczuk’s Opposition to
10/23/2019- Defendants’ Attorneys Daniel Bardzell and Nancy
Sheehan’s Motion to Compel Responses to Judgment Debtor
monetary sanctions
and Daniel Bardzell’s second reply to 12/04/2019, Waszczuk’s
Opposition to the 10/23/2019, Defendants’ Attorneys Daniel Bardzell
and Nancy Sheehan’s Motion to Compel Responses to Judgment
Debtor Interrogatories and Request for Production of Documents, and
for monetary sanctions
34. 12/13/2019- Court Order Tentative Ruling sanctioning Waszczuk
with $1300, Hon. David I. Brown, Dept. 53, Re: 10/23/2019
Defendants’ Motion to Compel and for monetary sanctions
35. 12/17/2019- Court Order affirming 12/13/2019 Tentative Ruling,
Hon. David Brown, Dept. 53, Re: 10/23/2019 Defendants’ Motion to
Compel and for monetary sanctions
36. 12/27/2019- Waszczuk’s Notice of Objection to the 12/13/2019 and
12/17/2019 Court Orders, Hon. David I. Brown, Dept. 53, Re:
10/23/2019 Defendants’ Motion to Compel and for monetary
sanctions
37. 04/26/2021- Defendants’ Ex Parte Application for Leave to Extend
Page Limit for Defendant's Motion for Summary Judgment or, in the
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Alternative, Summary Adjudication filed in violation of California
Rules of Court, Rule 3.1110 (b)(1) and under false pretenses.
38. 04/27/2021- Waszczuk’s meet and confer correspondence sent to
Defendants’ Attorney Amanda Goulding, Re: 04/26/2021,
Defendants’ Ex Parte Application for Leave to Extend Page Limit
for Defendant's Motion for Summary Judgment or, in the
Alternative, Summary Adjudication
39. 04/12/2021- Application and Order for Appearance and Examination
of Irina Waszczuk filed by the new Defendants’ Attorney Olatomiwa
T. Aina in Department 43, Hon. Thadd Blizzard.
40. 04/27/21- Waszczuk’s meet and confer correspondence with
attachments sent to the Defendants’ Attorney Olatomiwa T. Aina,
Re: 04/26/2021, Re: Subpoena and Application and Order for
Appearance and Examination Case No. 34-2013-00155479,
Jaroslaw Waszczuk v. The Regents of the University of California
41. 05/14/2021- Defendants’ Memorandum of Points and Authorities in
Support of Defendants' Motion for Summary Judgment or, in the
Alternative, Summary Adjudication relitigating dismissed COA’s
from Waszczuk SAC by Defendants’ anti-SLAPP motion, granted to
them on 04/14/2015
Support of Defendant's Motion for Automatic Stay, filed pursuant to
C.C.P. §916(a), or in the Alternative, Motion for a Discretionary
Stay. Motion was filed by Defendants to block Waszczuk’s proposed
Third Amended Complaint (TAC). 43. 10/28/2015- Court Order
granting Defendants’ Motion for Automatic Stay, filed pursuant to
Stay. The Court Order blocked Waszczuk’s proposed TAC, which
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was never was submitted to and reviewed by the Court, Hon. David
I. Brown, Dept. 53.44. 09/03/2015- Copy of Waszczuk’s
proposed TAC sent to Defendants’ Attorney Douglas Ropel for
stipulation to file, and his 09/25/2015 negative response.
45. 09/30/2015- Waszczuk’s Request for Dismissal of four individual
defendants, Charles Witcher, Ann Maiden Rice, Dorin Daniliuc, and
Patrick Putney, from the Case No. 34-2013-00155479, Jaroslaw
Waszczuk v. The Regents of the University of California et al., filed on
10/01/2015.
46. 12/04/2013- Waszczuk’s initial Wrongful Termination with six
causes of action, which included: 5. Violation and Breach of the
2009 Settlement-Agreement, 6. Violation of UC Policy PPSM
(Employee Evaluation Policy). Complaint was docketed on December 4,
2013 in Sacramento County Superior Court as Jaroslaw Waszczuk v. The
Regents of the University of California Ann Madden Rice, Mike Boyd,
Stephen Chilcott, Charles Witcher, Danesha Nichols, Cindy Oropeza,
Brent Seifert, Patrick Putney, and Dorin Daniliuc.
INTRODUCTION
Under the California Rules of Court, rule 8.272(c), the plaintiff and
appellant, Jaroslaw Waszczuk (pronounced “Vashchook”), hereby moves to
recall the remittitur issued on January 16, 2018 (Exhibit 1) in the trial court
register of action (ROA 128) and to reinstate his appeal, or alternatively, to
modify the erroneous unpublished opinion issued by the Court on
October 10, 2017 (Exhibit 2) and remand the new decision with
instructions for the trial court to vacate or void the trial court’s April 14,
2015 order and judgment (Exhibit 3) (ROA 57, 80and81). The 04/14/2015
trial court order and judgment granted the special motion to strike (anti-
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SLAPP) pursuant to California Code of Civil Procedure Section 425.16 five
individual defendants Mike Boyd, Danesha Nichols, Stephen Chilcott,
Cindy Oropeza and Brent Seifert (hereafter Defendants) striking from
Waszczuk’s Second Amended Complaint (SAC) the first four causes of
action (COAs) which were: 1.) intentional infliction of emotional distress,
2.) tortious interference with economic advantage, 3.) harassment, failure to
prevent harassment, discrimination, and retaliation under FEHA,
Government Code § 12940(a), and 4.) whistleblower/unlawful retaliation
California Government Code §§ 8547 et. seq .
Waszczuk cannot find a better authority than Bryan v. Bank of America, 86
Cal.App.4th 185 (Cal. Ct. App. 2001) to justify filing a motion to recall the
remittitur more than two years after the remittitur was issued. In Bryan v.
Bank of America’s “Recall of the Remittitur” discussion, the Court
explained:
If the remittitur issues by inadvertence or mistake, or as a
result of fraud or imposition practiced on the appellate court,
the court has inherent power to recall it and thereby reassert
its jurisdiction over the cause. This remedy, though described
in procedural terms, is actually an exercise of an
extraordinary substantive power. Correction of the clerk’s
clerical or other mistakes in the remittitur is a very minor
aspect of the proceeding; its significant function is to permit
the court to set aside an erroneous judgment on appeal
obtained by improper means. In practical effect, therefore, the
motion or petition to recall the remittitur may operate as a
belated petition for rehearing on special grounds, without
any time limitations. [Citations.]” (Id. § 736, p. 765, italics
in original.)
THE REASON FOR THIS MOTION
The crux of and reason for this motion is not to attempt to relitigate
or delay the legal process which has been endlessly and maliciously
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delayed by the defendants and their attorneys in filing the anti-SLAPP
motion on 12/01/2014. Rather, this motion seeks to end the intentional and
unrelenting pattern of misconduct by the defendants and their attorneys in
disregard of the Court’s benevolence in granting them the anti-SLAPP
motion on April 14, 2014, as affirmed by the Court of Appeal, Third
Appellate District (3DCA) 10/10/2017 in an unpublished opinion known as
Waszczuk v. Regents of University of California C079524 (Cal. Ct. App.
Oct. 10, 2017).
The 3DCA 10/10/2017 is erroneous itself and needs to be remanded
to the trial court with instructions to vacate or void the April 14, 2015 court
order and judgment which granted the defendants’ anti-SLAPP motion.
After the remittitur was issued on January 16, 2018, the anti-SLAPP motion
defendants and the Regents of the University of California have been
maliciously relitigating the four stricken COAs of the anti-SLAPP motion
in an attempt to terminate the Waszczuk lawsuit against the UC Regents
and to extort money from Waszczuk and his wife.
Waszczuk does not see any other way to stop the defendants and their
attorneys’ despicable harassment, misconduct, malice, and abuse of the
system than to file this motion to recall remittitur and return the four
stricken COAs to the defendants because they have been begging for
almost two years to have them back.
The trial court has erred by granting the anti-SLAPP motion to the
defendants instead of allowing Waszczuk to cure the defective SAC in
December 2014 and in September 2015 by amendment and dismissing all
individual defendants. The defective SAC was filed on September 30, 2014
against Waszczuk’s will by his drug-addicted attorney, Douglas E. Stein,
on September 30, 2014. Stein was dismissed by Waszczuk on December
16, 2014 for stealing Waszczuk’s retainer and failing to object to the anti-
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SLAPP motion. Awarded by the 10/10/2017 3DCA unpublished opinion in
Waszczuk v. Regents of Univ. of Cal., C079524 (Cal. Ct. App. Oct. 10,
2017) Waszczuk’s attorney, Douglas E. Stein SBN 13248 was disbarred on
January 10, 2020 for gross professional misconduct in relation to In re
Stein, S245982 (Cal. Mar. 1, 2018) and other crimes not related to his
representation of Waszczuk.
http://members.calbar.ca.gov/fal/Licensee/Detail/131248
PROCEDURAL AND FACTUAL BACKGROUND
This case was filed by Waszczuk representing himself on December 4,

2013 in the Sacramento County Superior Court, Register of Action (ROA 1),
case title: Jaroslaw Waszczuk v. The Regents of the University of California,
Case No. 34-2013-00155479-CU-WT-GDS.
On December 1, 2014, five individual defendants listed in Waszczuk’s
9/30/2014 SAC filed a special motion to strike pursuant to the California Code of
Civil Procedure, Section 425.16. (C.C.P §425.16) On April 14, 2015, this Court
entered an order granting Defendants Danesha Nichols, Mike Boyd, Cindi
Oropeza, Brent Seifert, and Stephen Chilcott Special Motion to Strike (anti-
SLAPP Motion CCP § 425.16). Four COA’s were stricken from Second
Amended Complaint and judgment was entered in Defendants’ favor. ( See:
Exhibit 3) (ROA 75–81) The second amended complaint set forth eight causes of
action:
1.) intentional infliction of emotional distress, 2.) tortious interference with
economic advantage, 3.) harassment, failure to prevent harassment,
discrimination, and retaliation under FEHA, 4.) whistleblower/unlawful
retaliation, 5.) violation of Health and Safety Code, sec. 1278.5, 6.) breach of
written contract, 7.) wage and hour violations, and 8.) rescission – unlawful
contract.
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Before Waszczuk’s four causes of action were stricken by the Court
from the Second Amended Complaint, the Court had denied the plaintiff’s
Motion for Reconsideration (ROA 59) on 4/10/2015 and Waszczuk’s
motion to dismiss the defendants’ anti-SLAPP motion for violation of the
discovery stay by the defendants’ attorneys. (ROA 64) (CCP § 425.16 (g)
On September 10/10/17, the Court of Appeal, in an unpublished
opinion in Waszczuk v. Regents of Univ. of Cal., C079524 (Cal. Ct. App.
Oct. 10, 2017) affirmed the 4/14/2015 trial court judgment striking the first
four COAs from the Waszczuk’s SAC.
On November 9, 2017, the Court of Appeal denied Waszczuk’s
petition for rehearing filed on October 25, 2017. A petition for review
was filed with the California Supreme Court, Case No. S245879 and was
denied on January 10, 2018. The remittitur was issued by the Court of
Appeal on January 16, 2018.
STATEMENTS OF FACTS AFTER ISSUANCE OF THE
REMITTITUR ON JANUARY 16, 2018 BY THE COURT OF
APPEAL THIRD APPELLATE DISTRICT
I. DEFENDANTS’ VEXATIOUS, MALICIOUS, AND
NEFARIOUS RELITIGATING OF THE DISMISSED CAUSES
OF ACTION
Just after the remittitur was issued on January 16, 2018, the defendants,
empowered by the fraudulent 3DCA unpublished opinion in Waszczuk v.
Regents of Univ. of Cal., C079524 (Cal. Ct. App. Oct. 10, 2017) caused the
stricken COAs by the anti-SLAPP motion became the subject of a frivolous
relitigating with the goal of terminating Waszczuk’s lawsuit against UC
Regents and dismissed COAs became a tool for defendants’ attorney’s
criminal activity in the court of law to extort money from Waszczuk and his
wife.
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On April 25, 2018, Attorney David Burkett sent Waszczuk the
request for production of documents (Set 1) (Exhibit 4), If the Court
examines Exhibit 3, requests 1–8 on pages 3–4, it will be clear that
Attorney Burkett’s demand for documents regarding COA No. 3 which was
stricken from Waszczuk’s SAC pertaining to harassment and failure to
prevent harassment, discrimination, and retaliation, was in violation of
Government Code § 12940 (A).
Request No. 9 was regarding COA No. 4 which was stricken from the SAC
and pertained to whistleblower/unlawful retaliation, in violation of
Government Code § 8547 et seq. Request 9 stated, “Please produce any
and all DOCUMENTS supporting YOUR contention that YOU were
subjected to retaliation for engaging in protected activities, in violation of
Government Code § 85547 et seq., exactly as it stated in stricken COA’s 4
from SAC ”
Waszczuk was forced by the defendant’s attorney’s frivolous and vexatious
motions and by the monetary sanction imposed by court order and threats
of a terminating sanction against UC Regents to produce thousands of
documents for the dismissed COAs.
On October 3, 2018, the defendants’ attorneys from Porter Scott,
David Burkett, and Daniel Bardzell, filed a motion to compel verified
responses to requests for production of documents (Set 1), for monetary and
terminating sanctions. The motion was deliberately filed in Department 54
(Exhibit 5) (ROA 163–180) and bypassed Judge Brown in Department 53
in a fraudulent attempt to obtain an order for monetary and terminating
sanction from Judge Christopher E. Krueger in Department 54. Judge
Krueger was unfamiliar with Waszczuk’s case, which had been pending for
four years, because he had never presided over it.
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The Defendants did not even mention the four remining COAs in their
motion, which should have been one of the motions key subjects. Attorneys
Burkett and Bardzell were caught, and their evil, deceptive plan failed to
persuade Judge Krueger to terminate Waszczuk’s lawsuit.
On October 11, 2018, Waszczuk informed the court clerk in
Department 54 about the misconduct of the attorneys for the defendants
(Exhibit 6).
On October 17, 2018, the defendants’ attorneys, Burkett and
Bardzell, refiled the motion with Department 53. Judge Brown scheduled a
hearing for November 14, 2018. However, in a surprising turn of events on
October 31, 2018, Judge Brown issued an order to Waszczuk with $520 in
monetary sanctions (Exhibit 7), ROA 166). The court order stated:
The notice of motion provides the incorrect time and location
for the hearing. This matter has been assigned to Department
53 for law and motion purposes, and Department 53 hears law
and motion matters at 2 p.m. Moving counsel is directed to
immediately provide notice to Plaintiff of the correct time and
location of the hearing.
On October 14, 2018, Judge Brown issued a second court order for
the same motion to compel monetary and terminating sanction,
admonishing Burkett and Bardzell as follows due to their despicable
violation of California Rules of Court -Rule 3.1110 (b) (1) (Exhibit 7,
ROA 178):
The Court must point out Defendant’s procedural errors that
have rendered an otherwise simple motion confusing and
created unnecessary work for the Court. Defendant initially
noticed this motion for October 31, 2018, but included the
incorrect law and motion department on the notice. It then
apparently filed the identical motion and noticed it for hearing
on November 13 and 14, in this department.
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The Court acknowledged Waszczuk’s November 12, 2018 correspondence
(ROA 178) that had been sent to the court by overnight mail, prior to the
scheduled November 14, 2018 hearing. Judge Brown noticed that
Defendants’ motion had been filed in the wrong department and that
Burkett and Bardzell slandered Waszczuk; thus, the Court admonished
them with the words in the duplicated October 31, 2018 court order, dated
November 14, 2018 (Exhibit 8, ROA 175, 176):
Further, while Defendant references Plaintiff’s “vexatious”
conduct in this action, that conduct has nothing to do with the
instant motion and, in any event, is not a basis for discovery
sanctions. Such ad hominem comments serve no useful
purpose in educating the court as to the party’s position
and distract more than they advocate. In short, they are
more cathartic than tactical.
However, in the two orders, dated October 31, 2018, and November
14, 2018, the Court failed to address Burkett and Bardzell’s evil attempt to
terminate the Waszczuk lawsuit by relitigating the COAs that had been
stricken through the anti-SLAPP motion.
On February 11, 2019, three days after Waszczuk met Defendants’
Attorney Daniel Bardzell in the cafeteria of Department 43, Bardzell and
Burkett filed another motion to compel, demanding monetary and
terminating sanction. The 2/08/2019 meeting between Waszczuk and
Bardzell in Department 43 was memorialized by the 2/08/2019 court order
(Exhibit 9) (ROA 189) and Waszczuk’s meet and confer letter which was
sent to Bardzell on 2/10/2019 (Exhibit 10).
The Defendants’ motion, which amounted to 396 pages of pleadings and
exhibits (Exhibit 11) (ROA 189–186), was almost identical to the motion
Attorneys Burkett and Bardzell deceptively filed in the wrong department
on October 3, 2018 in evil attempt to terminate Waszczuk’s lawsuit
- 19 -
On March 11, 2019, Waszczuk filed the ex parte application for late
opposition to the defendants’ motion to compel monetary and terminating
sanctions (Exhibit 12)(ROA 198). Waszczuk requested that the Court
dismiss the defendants’ motion entirely for the reasons outlined on pages 2
and 3 of the ex parte application by informing the Court that the attorneys
from Porter Scott were tampering with the administration of justice to
injure Waszczuk and that the first four causes of action stricken from the
Waszczuk SAC by the anti-SLAPP motion granted to Defendants on April
14, 2015 must be completely excluded from the Defendants’ discovery
process.
By a March 13, 2019, court order (Exhibit 13, ROA 203), Judge
David I. Brown from Department 53 declined oral argument on
Waszczuk’s ex parte request. The Court also declined to dismiss the
defendants’ motion, which brought back into litigation the four dismissed
COAs stricken from Waszczuk ‘s SAC. Judge Brown did not impose
monetary and termination sanctions on Waszczuk, and in an order dated
3/13/20119, the Court ruled:
There has only been one previous discovery motion by
Defendant to compel responses. Plaintiff complied with that
order and provided responses, albeit some which Defendant
deemed insufficient in certain respects and, for that reason,
brought a motion to compel further responses. The Court will
not at this time find an abuse of the discovery process.
Contrary to the ruling, Judge Brown completely ignored fact that the
defendants relitigating the dismissed COAs, and, in the same manner as in
October and November 2018. Notorious Defendants Attorneys Burkett and
Bardzell, did not give up.
On March 20, 2019, just seven days after Judge Brown denied them
monetary and terminating sanctions, they filed another motion to compel
- 20 -
for monetary and terminating sanctions. This was almost identical to their
previous motions (Exhibit 14, ROA 205–211). Again , Burkett and
Bardzell bluntly mixed apple and oranges (UC Regents with anti-SLAP
motion defendants ) in evil attempt to terminate Waszczuk lawsuit .
On April 12, 2019, Waszczuk filed his opposition to Bardzell and
Burkett’s motion (Exhibit 15) (ROA 209).
The motion was finalized by a tentative court order, which instead of
imposing sanction against Defendants and their attorneys for a frivolous
motion and for the malicious relitigating of dismissed COAs, the Court
reimposed sanctions on Waszczuk. Thus, Waszczuk requested the court
hearing in Department 53.
A different judge, The Hon. Steven H. Rodda, presided over the hearing on
April 26, 2019 in Department 53. Judge Rodda ruled by court order
(Exhibit 16, ROA 2011):
Terminating Sanctions
The motion for terminating sanctions is denied. The post

judgment discovery at issue here was served by judgment
creditors, not Regents. Moving parties have already
obtained a judgment of dismissal in this case, as well as an
attorney fees award on the anti-SLAPP motion. Thus, it is
unclear why they are seeking a “terminating sanction” in
this context.Regents are not a party to the underlying
discovery or this motion, and, therefore, the Court will
not grant terminating sanctions to Regents. To the extent
Final Court Ruling
After hearing oral argument, the Court affirmed its tentative

ruling with the following modification: The order for
monetary sanctions was vacated.
At the end of the hearing with Judge Rodda, Waszczuk asked the Court
what he was supposed to provide to the defendants’ attorneys, because they
- 21 -
had already received everything. Judge Rodda responded, “You will have
to figure that out yourself” (court reporter’s transcript, page 8, Exhibit
17). Waszczuk figured out that the Defendants were trying to terminate
Waszczuk’s lawsuit by using dismissed COAs, which amounted to an
abuse of the court system and a bullying or blackmailing of the judges.
On June 12, 2019, Defendants Attorneys Burkett and Bardzell, filed
another motion for monetary and terminating sanctions, vexatiously and
maliciously using again the four dismissed COAs (Exhibit 18, ROA 213–
2019). Attached is Bardzell’s memorandum to support the frivolous
motion, which is almost identical to the previous motion. Waszczuk
opposed Defendants’ motion on July 5, 2019 (Exhibit 19)(ROA 2017). On
page 5 of his opposition, Waszczuk pointed out the following to the Court:
The Court does not need to read Defendants’ attorney Daniel
Bardzell’s Declaration or Memorandum of Point and
Authorities to find out how deceptive Porter Scott’s attorney
is. In his pleadings, Bardzell’s complete disregard of the
April 26, 2019, Court Order (Hon. Rodda) ROA 211, which
states in bold black letters that, “Regents are not a party to
the underlying discovery or this motion, and, therefore,
the Court will not grant terminating sanctions as to
Regents.”
Prior to the scheduled hearing on July 3, 2019, Waszczuk sent an inquiry

by e-mail, U.S. mail, and fax to the former attorneys (2014–2015) for the
Defendants, Michael Pott, and his partner in crime Douglas Ropel (Exhibit
20) who were beneficiaries of the court order dated June 7, 2018. In his
inquiry to Pott and Ropel Waszczuk stated:
I am working hard to recover the retainer stolen by my former
attorney, Douglas Stein, along with my short-term disability
insurance benefits of 2011–2012, which I eventually found
after seven years in the state controller’s office as unclaimed
property (Exhibit 21) as well as my unemployment insurance
benefit, which was reinstated by the California Employment
- 22 -
Development Department in May 2014 and then mysteriously
disappeared. (Exhibit 22) I am working on recovering this
money so I can pay your legal fees regardless of if I believe
or not if these fees should be awarded to you or not. Please let
me know where you stand on this matter. Whether you like to
be associated with these fees and with UCOP organized
crime.
None of them responded to Waszczuk’s inquiry. On June 21, 2019, the

California State Bar informed Waszczuk that he was qualified for
reimbursement of the money stolen from him in December 2014 by
Douglas Stein, who was disbarred in January 2020.
On August 8, 2019, Waszczuk was reimbursed $14,500 by the State
Bar Client Security Fund (Exhibit 23) giving him the ability to pay some of
the legal fees awarded to the Defendants former attorneys Michael Pott and
Douglas Ropel, present attorney David Burkett, and Porter Scott paralegal
Marylin Gamper pursuant to the June 7, 2018 Court Order.
On July 19, 2019, the 6/12/2019 motion by the Defendants was
heard by Judge Brown on. In his decision (Exhibit 24, ROA 219), Judge
Brown repeated Judge Rodda’s statement from the previous order dated
April 26, 2019:
The motion for terminating sanctions is denied. The post
judgment discovery at issue here was served by Judgment
Creditors, not The Regents of the University of California
(Regents). Moving parties have already obtained a judgment
of dismissal in this case, as well as an attorneys’ fees award
on the anti-SLAPP motion. Thus, it is unclear why they are
seeking a “terminating sanction” in this context.
It was quite clear to Waszczuk that something was going terribly wrong
with his case in Department 53 when he looked at the facts and saw that the
judges were noticing the malice and gross misconduct of the Defendants
- 23 -
attorneys but were punishing Waszczuk with sanctions and letting the
attorneys harass him as much and as long as they wished.
Judge Brown, by his July 19, 2019 order, awarded $1,300 in sanctions
against the Defendants for their attorneys’ misconduct and fraud. During
that hearing on July 19, 2019, Judge Brown questioned Bardzell in his
statement, which can be found as follows on pages 5 and 6 of the RT
(Exhibit 25):
THE COURT: This is post judgment discovery. What are
you terminating? There’s already a judgment against Mr.
Waszczuk.
MR. BARDZELL: The motion is filed on behalf of the anti-

SLAPP defendants, but we’re okay with the tentative ruling at
this point.
THE COURT: So, he is okay with it.
Bardzell, who, with Burkett, filed five motions, which amounted to

thousands of pages of documents, maliciously harassing Waszczuk to
extort money from him and his wife, stated that he is now “okay with the
tentative ruling.” It is still a great mystery to Waszczuk as to how Judge
Brown justified a sanction of $1,300 dollars against Waszczuk, stating
“I’m not saying they can collect them. I’m saying that they are entitled
to them procedurally,” after Waszczuk mentioned his $1,500 Social
Security income (CRT, pages 11, 20–22).
On October 23, 2019, Defendants’ attorneys filed a Further Motion to
Compel Responses to Judgment Debtor Interrogatories and Request for
Production of Documents; Monetary Sanctions, which totaled 235 pages of
documents (Exhibit 26, ROA 222–227). In contrast with other motions,
after four attempts, Defendants did not demand terminating sanctions.
- 24 -
The difference in the October 23, 2019 motion to the previous four motions was
that that Defendants’ Attorney Burkett was replaced with another Porter Scott
shareholder and attorney, Nancy Sheehan, who had been an employee at Porter
Scott for 34 years. Burkett was a leading attorney in the case Waszczuk v.
Regents of Univ. of Cal., C079524 (Cal. Ct. App. Oct. 10, 2017) since January
23, 2015. Nancy Sheehan’s name was added to the pleadings at a time when
she was gravely ill with metastatic breast cancer; she died on November 23,
2019, exactly one month after another evil-spirited motion was filed by
Defendant’s attorney Bardzell.
(https://www.legacy.com/obituaries/sacbee/obituary.aspx?n=nancy-joan-
sheehanandpid=194994093).
Furthermore, what caught Waszczuk’s attention in the October 23, 2019
motion pleadings was that Porter Scott’s attorneys are “attorneys for
judgment creditors/former defendants,” in contrast with previous
pleadings in which the judgment creditors were not the former defendants.
On October 24, 2019, Waszczuk received an e-mail from Daniel
Bardzell who now representing “former Defendants” with a “settlement
offer.”
On October 31, 2019, Waszczuk briefly responded to Bardzell’s
offer assuming that David Burkett on his way out told Bardzell to send it.
David Burkett had sent a similar offer to Waszczuk in May 2015, and again
in August 2015 (Exhibit 28).
On November 12, 2019, another Porter Scott attorney and
shareholder, Derek Haynes was added to Jaroslaw Waszczuk v. The
Regents of the University of California, Case No. 34-2013-00155479 (ROA
228).
On November 15, 2019, Defendant’s attorney Bardzel in his weird
and threatening correspondence (Exhibit 29) informed Waszczuk that
- 25 -
Porter Scott paralegal Marilyn Gamper was not permitted to cash out the
$520 from Waszczuk sent her on October 31, 2019 (legal fees awarded to
her by the 6/07/2018 court order in anti-SLAPP motion proceeding).
Waszczuk also paid $520 sanction awarded unjustly to the Defendants by
the Court on 10/31/2018. Check was cashed by Porter Scott’s attorneys.
Furthermore, Defendants’ Attorney Daniel Bardzell in his threatening scam
correspondence demanded from Waszczuk in bold letters that Waszczuk
must issue a check to pay all anti-SLAPP legal fees and costs payable to
the Regents of the University of California, the Defendant which is not
listed anti-SLAPP motion.
Defendants’ attorneys Bardzell and Burkett were informed that, on August
9, 2019, the State Bar of California Client Security Fund reimbursed
Waszczuk in amount of $14,500, stolen from him in December 2014, by his
attorney, Stein.
Bardzell and Burkett were also informed that on October 1, 2019,
Waszczuk received $25,000 from his wife to take care of Bardzell and
Burkett’s multiple extortion attempts, which began in 2015, using
Waszczuk’s wife as a blackmail tool to force Waszczuk to pay them the
anti-SLAPP legal fees.
Following Bardzell’s November 15, 2019 threatening letter, on November
18, 2019, Waszczuk issued a check in the amount of $1,300 to pay the
sanction imposed by the 7/19/2019 Court Order. However, in a short letter
dated November 21, 2019, Waszczuk asked Bardzell whether he would
prefer to reissue the $1,300-sanction check to the five former individual
defendants—Nichols, Chilcott, Seifert, Boyd, and Oropeza—instead of to
the Regents of UC. Furthermore, Waszczuk advised Bardzell that he should
ask Judge Brown to make sure that Nichols, Chilcott, Seifert, Boyd, and
Oropeza are the former defendants, as he claimed in his motion to
- 26 -
compel and for monetary sanctions filed on October 23, 2019, and in his
recent correspondence.
On December 4, 2019, Waszczuk filed his opposition to the Defendants’
October 23, 2019 further motion to extort money from Waszczuk or his
wife (Exhibit 31, ROA 235), emphasizing again that the Regents of UC
were not the defendants in the anti-SLAPP motion and, therefore, that they
were not entitled to any legal fees. This was clearly affirmed by two
different judges, The Hon. Rodda and The Hon. Brown, in different court
orders ( See: Exhibit 25, ROA 2011, and Exhibit 29, ROA 19).
Attorney Bardzell, and two new attorneys, Derek Hayes, and Amanda Iller,
filed two replies to Waszczuk’s December 4, 2019 opposition to their
motion. One reply was filed on the same day, December 4, 2019, entitled
“Reply to No Opposition” (Exhibit 32), and on December 6, 2019, they
filed a second reply to the opposition (Exhibit 33), (ROA 238).
On page 5, paragraph 4 of their December 6, 2019 reply, entitled
“Defendant Regents Is Entitled to Payment of Sanctions Awards,”
Porter Scott Attorney Amanda Iller, who was listed in the June 7, 2018
Court Order, demanded that legal fees be paid to the Regents of UC, in bold
letters stating.
Judgment Debtor has cited no legal authority for his position
that the REGENTS are not entitled to the sanction payment.
The REGENTS has paid for the defense of the Judgment
Creditors (Iler Deci. ¶ 6). “A monetary sanction may be
based not only on attorney’s fees and costs, but also on any
other reasonable expenses incurred.
Judgment Creditors respectfully request the Court clarify

for Judgment Debtor that the REGENTS is entitled to the
payment of sanction awards so that Judgment Debtor
does not continue to use that as an excuse for not paying
the amounts owed.
- 27 -
Waszczuk did not understand what the Defendant’s Attorney Amanda Iller
was talking about after Waszczuk sent two sanctions checks to Porter Scott,
one on October 31, 2019 in the amount of $520, and a second check on
November 18. 2019 for $1300 and wanted to pay legal fees to the former
Defendants attorneys from Porter Scott law firm listed in the 6/07/2018
court order.After Waszczuk read the Court’s tentative decision, issued on
December 12, 2019, and, to his disbelief, found out that Judge Brown
slammed Waszczuk with additional monetary sanctions of $1,300,
Waszczuk called the court clerk and requested a hearing on December 13,
2019 at 2:00 p.m.
At the court hearing, the defendants were represented by Attorney Bardzell.
Judge Brown admonished Bardzell and ordered the return of the $1,300
paid on November 18, 2019 to Waszczuk, and explained again to Bardzell
that that the Regents of UC were not defendants in the anti-SLAPP motion.
On December 27, 2019, Waszczuk filed a Notice of Objection to the Court
Orders Dated December 13 and 17, 2019(Exhibit 34and35)(ROA 241
and242), and Plaintiff’s Request for Court Order Modification.
Waszczuk submitted his Notice of Objection and the Request for
Modification of the court order (Exhibit 36) (ROA 244) because nothing
was in the December 17, 2019 court order that had been argued or said at
the December 13, 2019 hearing.
In his Notice of Objection, Waszczuk focused on the issue of the
defendants in the anti-SLAPP motion. He asked the Court to clarify
whether Chilcott, Nichols, Oropeza, Seifert, and Boyd had been dismissed
by the anti-SLAPP motion or whether they were still the defendants in the
lawsuit.
- 28 -
II. NEW ATTORNEYS FOR THE DEFENDANTS FROM
PORTER SCOTT: LINDSAY A. GOULDING AND
OLATOMIWA T. AINA
Two new defendants Attorneys Goulding and Aina resumed their dirty
game with Waszczuk and with the new judge in Department 53.
one year and half after Waszczuk filed his Notice of Objection to the court
orders of December 14 and17, 2019, On April 26, 2021, Defendants’ Attorney
Lindsay A. Goulding, in violation of California Rules of Court Rule 3.1110 (a)
(1), served Waszczuk by e-mail an Ex-Parte Application for Leave to Extend
Page Limit for Defendant’s Motion for Summary Judgment or, in the
Alternative, Summary Adjudication in violation of California Rules of Court -
Rule 3.1110 (b) (1) without stating or marking on the pleading in which
Department the ex parte application would be filed or which judge would
handle the ex parte application. (Exhibit 37) (ROA 247–249)
Not letting the opposing party know which judge or department will make the
decision is gross professional misconduct and extrinsic fraud. “Extrinsic fraud
occurs when one party prevents the other from having his day in court.
Extrinsic fraud only arises when one party has in some way fraudulently been
prevented from presenting his or her claim or defense.” Sporn v. Home Depot
USA, Inc. (2005) 126 Cal.App.4th 1294, 1300 [ 24 Cal.Rptr.3d 780
Attorney Lindsay A. Goulding brought into her Ex Parte Application three
Stricken COAs by anti-SLAPP motion granted to the Defendants by the
Court on 4/14/2015 by the fraudulent and frivolous anti-SLAPP motion.
Lindsay Goulding’s deceptive Ex Parte Application should not have been
accepted and granted by the Court on the same day April 26, 2021 by the
Honorable Shama Hakim Mesiwala’s stamp, but in fact it was.
- 29 -
Waszczuk addressed the Attorney Amanda Goulding’s Ex Parte in the meet and
confer letter dated April 27, 2021, which was filed in the Court on April 28,
2021 (Exhibit 38) (ROA 250).
Simultaneously, another Porter Scott Attorney, Olatomiwa T. Aina, in
coordinated action with Amanda Goulding, served on Waszczuk a Subpoena
and Application and Order for Appearance and Examination filed in
Department 43 (Exhibit 39) (ROA 251-259) in attempt to break into
Waszczuk’s wife bank account and 401(k) plan to extort money from in a
similar manner to other Porter Scott attorneys attempts in 2019 who were not
awarded any legal fees in the anti-SLAPP motion and they were prohibited by
the Court to cash any check using the Regents of the University of California
name because Regents were not a party in the anti-SLAPP motion. Waszczuk
addressed the Olatomiwa T. Aina scam in the meet and confer letter dated April
27, 2021(Exhibit 40) (ROA 251).
On May 14, 20210 Defendants’ Attorneys Amanda Goulding and Olatomiwa
T. Aina filed in their scam to extort money from Waszczuk and his wife the 475
pages of documents with the defendant’s notice of motion and motion for
summary judgment or, in the alternative, summary adjudication (Exhibit 41)
(ROA 254-258). Seventy-five percent of the filed motion was the third and
fourth COAs stricken from Waszczuk’s SAC. Apparently, the defendants new
attorneys Goulding and Aina have high expectations that the new judge in
Department 53 would rule in their favor and that they would be able to extort
money from Waszczuk by relitigating the fraudulent anti-SLAPP motion COAs
by Motion for Summary Judgment .
Defendants attorneys perpetrated crime did not work as they anticipated with
Judge David I Brown from Dept. 53 in 2014-2019 and Judge Thadd A.
Blizzard from Dept. 43 and will not work this time with Judge Thadd A.
- 30 -
Blizzard from Dept. 43 and the new Judge Shama Hakim Mesiwala from Dept
53.
MEMORANDUM OF POINTS AND AUTHORITIES AND
ARGUMENT
I. THE REMITTITUR MUST BE RECALLED AND THE
ERRONEOUS UNPUBLISHED OPINION FILED ON OCTOBER
10, 2017 in Waszczuk v. Regents of University. Of California
C079524 (Cal. Ct. App. Oct. 10, 2017) MUST BE MODIFIED
The false and harmful statement from page 3 of the opinion misled
Waszczuk into believing that five anti-SLAPP motion defendants, Nichols,
Seifert, Boyd, Oropeza and Chilcot were entirely dismissed from the
lawsuit and that the Regents of the University of California were the only
remaining defendants to the lawsuit.
“Plaintiff loses this appeal, but it is not the end of his lawsuit
for wrongful termination.” The trial court reminded plaintiff
at the hearing on the special motion to strike that the Regents
of the University of California (the Regents) were not
protected if they discriminated or retaliated against him and,
therefore, “[i]ndependent of the five individuals who are
before the Court on this motion, [plaintiff] still retains his
right to sue the Regents because they are still in the lawsuit
and he’s still the plaintiff.” In this context, we recite the brief
facts relevant to the issues plaintiff raises on appeal.”
Waszczuk in his December 27, 2019 Notice of Objection to the 12/12/2019

and 12/17/2019 (Exhibit 36) Court Orders (Exhibit 36) asked the trial court
to clarify the status of the five anti-SLAPP motion Defendants in the
Waszczuk ‘s lawsuit to stop Defendants Attorneys criminal extortion
activities in the Court. Waszczuk did not get the clarification from the trial
court and the attorneys for the defendants resumed their criminal extortion
activities after a year and a half by relitigating the dismissed by anti-SLAPP
motion COAs to scam money from Waszczuk in the motion for summary
judgment filed on 5/14/2021.
- 31 -
In re Grunau, 86 Cal.Rptr.3d 908, 169 Cal.App.4th 997 (Cal.App. Dist.6
12/30/2008) The Court ruled that traditionally a remittitur could be recalled
only if the appellate judgment was the product of fraud or mistake (e.g., In
re Rothrock (193 9) 14 Cal. 2d 34, 38-39 [92 P.2d 634]), or inadvertence
(e.g., In re McGee (195 1) 37 Cal. 2d 61 8-9 [229 P.2d 780]).
The harmful false statement in the 3DCA opinion awarding Waszczuk’s
drug-addicted attorney who stole his client’s money and telling Waszczuk
that defendants were dismissed from the lawsuit is also a legitimate reason
for the 3DCA to recall the remittitur and reinstate the appeal or modify the
opinion and remand it to the trial court to vacate or void the April 14,2015
court order and judgment and other fraudulent orders which caused much
harm to Waszczuk and the integrity of the judicial system.
In re Rothrock, 14 Cal.2d 34 (Cal. 1939) the basis for the motion to recall
the remittitur was that the judgment of the court was improvidently granted
under a mistake of fact.
After attorneys for the defendants filed the Motion for Summary Judgment
in May 2019 relitigating COAs dismissed by the anti-SLAPP motion,
Waszczuk reviewed the trial court record and record on appeal and found
out through the Court Order dated 10/10/2017 how such a false and harmful
fact or mistake found its way to the 3DCA opinion in Waszczuk v. Regents
of Univ. of Cal., C079524 (Cal. Ct. App. Oct. 10, 2017) contrary to the
4/14/2015 anti-SLAPP motion Court Order and Judgment. It is difficult to
remember all facts when one unresolved motion is pending in court for
almost seven years due to the defendants’ deception and relitigating of
matters that had been previously resolved by three different courts.
Waszczuk determined that the harmful false statement in the 3DCA opinion
originated from the Waszczuk Augmented Record on Appeal, submitted to
3DCA on 2/22/2016. More specifically from the September 25, 2015
- 32 -
defendants’ motion for automatic stay pursuant to C.C.P. § 916(a), or in the
alternative, motion for a discretionary stay (Exhibit 42) (ROA 105) and the
October 28,2015 Court Order which granted Defendants motion for
automatic stay (Exhibit 43) (ROA 118) which blocked Waszczuk from
filing the Third Amended Complaint (TAC) which he submitted to the
attorneys for the defendants by a stipulation to do so (Exhibit 44).
Defendants initially agreed to stipulation to file the TAC but quickly then
changed their positive approach to Waszczuk intention. By filing TAC
Waszczuk’s intention was to withdraw the appeal from 3DCA and amend
the SAC with only two COAs and without naming individual defendants in
the lawsuit. Waszczuk, in his 2015 TAC, focused on almost $1,000 000
monetary damages caused to him by his employers due to the violation
and breach of the January 30, 2009 Settlement Agreement the UC Regent
signed with him (TAC pages number 274–287). After the attorney for the
defendant filed the motion for automatic stay, Waszczuk dismissed four
other individual defendants (Ann Madden Rice, Charles Witcher, Patrick
Putney and Dorin Daniliuc) by filing a Notice of Dismissal on 10/01/2015
(Exhibit 45) (ROA 109-110). However, Waszczuk did not include anti-
SLAPP motion defendants Danesha Nichols, Stephen Chilcott, Mike Boyd,
Cindi Oropeza and Brent Seifert in this notice. The April 14, 2015 court
order and judgment granting Defendants’ anti-SLAPP motion stated that
only the first four COAs were stricken from the SAC. In contrary the
9/25/2015 Defendants’ Motion for Automatic Stay and the 10/28/2015
court order stating that anti-SLAPP defendants are dismissed from the
entire lawsuit. . Waszczuk would like to emphasize that he did not sue
individual defendants in relation to the first four COAs in the defective
SAC but for violation and breach of the 2009 Settlement Agreement, The
Waszczuk’s drug-addicted attorney Douglas Stein blackmailed or bribed by
- 33 -
Defendant Porter Scott attorneys collaborated with them and changed the
venue of Waszczuk’s initial 12/04/2013 complaint.. The SAC was a fraud
and Defendants’ anti-SLAPP motion was a fraud; thus, the 10/10/2017
unpublished opinion in Waszczuk v. Regents of Univ. of Cal., C079524
(Cal. Ct. App. Oct. 10, 2017) is fraudulent, and remittitur must be recalled
and the 4/14/2015 trial court order and judgment must be reversed to allow
Waszczuk to amend the defective Second Amended Compliant.
The defendants’ attorneys from Porter Scott ceased for one years and half
their almost two-year string of criminal money extortion activities after
Waszczuk, on December 27, 2019, filed a Notice of Objection to the Court
Order dated December 13 and 17, 2019, and Plaintiff’s Request for Court
Order Modification (see Exhibit 39, ROA 244).
In addition to the above on pages 8–11 of same document, Waszczuk
addressed five anti-SLAPP motion defendants in the context of whether
Defendants Danesha Nichols, Michael Boyd, Cindy Oropeza, Brent Seifert,
and Stephen Chilcott are former Defendants as Porter Scott attorney
labeled them in the last filed in 2019 motion on 10/23/2019.
In the May 14, 2021 Motion For Summary Judgment filed by the
Defendants, 75 percent of the 531 pages of the motion (ROA 254–259)
were documents unrelated to the 3th and 4th COAs that were stricken from
Waszczuk’s defective SAC by anti-SLAPP motion.
“Res judicata precludes piecemeal litigation by splitting a
single cause of action or relitigation of the same cause of
action on a different legal theory or for different relief.”
(Weikel v. TCW Realty Fund II Holding Co. (1997) 55
Cal.App.4th 1234, 1245.) A predictable doctrine of res
judicata benefits both the parties and the courts because it
“seeks to curtail multiple litigation causing vexation and
expense to the parties and wasted effort and expense in
judicial administration.” (7 Witkin, Cal. Procedure (4th ed.
1997) Judgment, § 280, p.820.)
- 34 -
Flatley v. Mauro 39 Cal.4th 299 (Cal. 2006), cited 799 times by the
California Supreme Court, described the crime of extortion as follows:
“Extortion is the obtaining of property from another, with his consent...
induced by a wrongful use of force or fear...” (Pen. Code, § 518). This is
exactly what Plaintiff has been dealing with since December 2014, and the
Court must acknowledge this fact.
Filing the fraudulent and frivolous anti-SLAPP motion to obtain a favorable
judgment to relitigate a favorable decision with the goal of extorting money
from the opposing party by blackmail, threatening the adverse party and
bullying judges to destroy somebody’s life and livelihood are not protected
by the anti-SLAPP statute C.C.P 425.16 or any other law. Stenehjem v.
Sareen, 226 Cal.App.4th 1405 (Cal. Ct. App. 2014)
II. THE COURT OF APPEAL MUST RECALL THE

REMITTITUR TO PRECLUDE THE FURTHER MALICIOUS
ABUSE OF THE JUDICIAL SYSTEM BY THE
DEFENDANTS
The defendants’ notorious relitigating of stricken causes shows that the

defendants’ anti-SLAPP motion filed seven and a half years ago on
December 1, 2014 had a purpose other than furtherance of their rights of
petition and free speech under the United\ States or California Constitution
in connection with a public issue. Thus, the Court of Appeal must urgently
intervene by recalling the remittitur and precluding further malicious abuse
of the judicial system and Waszczuk by the defendants and their attorneys.
In Cheveldave v. Tri Palms Unified Owners Ass’n, 238 Cal. Rptr. 3d 792
(Cal. Ct. App. 2018) the Court explained that: “the doctrine of collateral
estoppel is one aspect of the concept of res judicata.” citing (Lucido v.
Superior Court (1990) 51 Cal.3d 335, 341, fn. 3, 272 Cal.Rptr. 767, 795
P.2d 1223.) “Collateral estoppel, or issue preclusion, ‘precludes relitigating
- 35 -
of issues argued and decided in prior proceedings.’ “ (Mycogen Corp. v.
Monsanto Co. (2002) 28 Cal.4th 888, 896, 123 Cal.Rptr.2d 432, 51 P.3d
297.)
Furthermore, the Court explained collateral estoppel has five requirements:
“First, the issue sought to be precluded from relitigating must
be identical to that decided in a former proceeding. Second,
this issue must have been actually litigated in the former
proceeding. Third, it must have been necessarily decided in
the former proceeding. Fourth, the decision in the former
proceeding must be final and on the merits. Finally, the party
against whom preclusion is sought must be the same as, or in
privity with, the party to the former proceeding.” (Lucido v.
Superior Court, supra, 51 Cal.3d at p. 341, 272 Cal.Rptr. 767,
795 P.2d 1223.)
Cheveldave v. Tri Palms Unified Owners Ass’n, 238 Cal. Rptr. 3d 792 (Cal.
Ct. App. 2018) is the authority that exactly applies to the Defendants
misconduct and abuse of the court system since remittitur was issued on
January 16, 2018. Defendants’ legal gangsterism in the court must be
stopped by the Court of Appeal which erroneously affirmed the trail court
judgment dated April 14, 2015.
In F.E.V. v. City of Anaheim, 15 Cal.App.5th 462 (Cal. Ct. App. 2017)
Court explained that the
“doctrine of res judicata rests upon the grounds that the party
to be affected, or some other with whom he is in privity, has
litigated, or had an opportunity to litigate the same matter in a
former action in a court of competent jurisdiction, and should
not be permitted to litigate it again to the harassment and
vexation of his opponent. Public policy and the interest of
litigants alike require that there be an end to litigation.”
(Panos v. Great Western Packing Co. (1943) 21 Cal.2d 636,
637, 134 P.2d 242.)
The public policies underlying collateral estoppel are preserving the

integrity of the judicial system, promoting judicial economy, preventing
- 36 -
inconsistent judgments, and protecting litigants from vexatious litigation.
(Lucido v. Superior Court, supra, 51 Cal.3d at p. 343, 272 Cal.Rptr. 767,
795 P.2d 1223 ; Roos v. Red (2005) 130 Cal.App.4th 870, 887, 30
Cal.Rptr.3d 446 ; Younan v. Caruso (1996) 51 Cal.App.4th 401, 407, 59
Cal.Rptr.2d 103.)
The only way to stop the Defendants and their attorneys from further
relitigating of the already litigated and dismissed four causes of action is to
recall the remittitur, reinstate the appeal, modify the 10/10/2017
unpublished opinion and remand it to the trial court with instructions to
vacate the April 14, 2015 Court Order and Judgment.
III. THE REMITTITUR MUST BE RECALLED TO STOP THE

DEFENDANTS’ EGREGIOUS MISCONDUCT .
As the attached exhibits show, the litigation tactics of the defendants and
their attorneys from Porter Scott and their egregious misconduct
incapacitated bullied judges in trial court Department 53 and prevented
them from restoring the order and meaning of law in Department 53 and
generally in the trial court in this case. The Court of Appeal must act to
restore order and justice in this case by recalling the remittitur and vacate
and void the harm done to Waszczuk and the integrity of the justice system.
The trial court orders and decisions were obtained by the powerful Regents
of the University of California by intimidation, bullying, blackmailing,
extortion and possible bribery and racketeering. The stakes must be a lot
bigger in this case as the Court noticed on page 2 in the preliminary
statement of the unpublished opinion dated 10/10/2017. (See Waszczuk ‘s
Declaration in Support of this motion to recall remittitur.)
In Chambers v. Nasco, Inc., 501 U.S. 32 (1991) the Court noted that the
alleged sanctionable conduct was that the defendants had “(1) attempted to
deprive the Court of jurisdiction by acts of fraud, nearly all of which were
- 37 -
performed outside the confines of this Court, (2) filed false and frivolous
pleadings, and (3) attempted, by other tactics of delay, oppression,
harassment and massive expense to reduce plaintiff to exhausted
compliance.” This is exactly what Defendants are doing in the courts in this
case.In Hazel-Atlas Glass Co. v. Hartford-Empire Co., 322 U.S. 238, 64
S.Ct. 997, 88 L.Ed. 1250 (1944). See also Universal Oil Products Co. v.
Root Refining Co., 328 U.S. 575, 580, 66 S.Ct. 1176, 1179, 90 L.Ed. 1447
(1946) Courts ruled :The “historic power of equity to set aside fraudulently
begotten judgments,” is necessary to the integrity of the courts, for
“tampering with the administration of justice in [this] manner... involves far
more than an injury to a single litigant.”
In Peat, Marwick, Mitchell Co. v. Superior Court, 200 Cal.App.3d 272
(Cal. Ct. App. 1988) California decision on the inherent authority of courts,
affirmed that judges are empowered to act when a party seeks to take unfair
advantage of “the integrity of the judicial system.” This decision directly
addressed the fact that a court’s inherent powers include the authority to
terminate a case for litigation.
Under the “unclean hands” doctrine, a party is barred from relief if engaged
in any unconscientious conduct directly related to the transaction or matter
before the court. Burton v. Sosinsky (1988) 203 Cal. App. 3d 562, 573 [250
Cal.Rptr. 33]; California Satellite Systems, Inc. v. Nichols (1985) 170 Cal.
App. 3d 56, 70 [216 Cal.Rptr. 180].
The authority to dismiss a lawsuit for litigant misconduct is a creature of
the “clean hands doctrine” and is applicable to both equitable and legal
damages claims. Buchanan Home and Auto Supply Co v Firestone Tire and
Rubber Co., 544 F.Supp. 242, 244-245 (D SC, 1981). See also Mas v Coca-
Cola Co., 163 F.2d 505, 507 (CA 4, 1947).
- 38 -
Waszczuk comes before the Court with clean hands; the defendants and
their attorneys do not. They have engaged in extreme and abusive litigation
misconduct. First, they took advantage of Waszczuk’s drug-addicted
attorney, Douglas Stein. in 2014 and his friendship with Judge David I.
Brown, and then they took advantage of Waszczuk’s self-representation
after he dismissed Stein for gross misconduct in December 2014. The Court
should not aid or reward Defendants for their egregious misconduct in the
Court of Law.
CONCLUSION
On December 4, 2013, Waszczuk filed a wrongful termination lawsuit, in

pro per (Exhibit 46) (ROA 1)., Waszczuk sued the Defendants because
they violated, breached, and trashed the January 30, 2009 Settlement
Agreement they signed with Waszczuk. In the same way and manner
Defendants disregarded, disrespected, and trashed the April 14, 2015 Court
Order and Judgment granting them a Special Motion to Strike pursuant to
C.C.P 425.16 and in the same way they disregarded, disrespected and
trashed the 3DCA 10/10/2017 unpublished opinion in Waszczuk v. Regents
of Univ. of Cal., C079524 (Cal. Ct. App. Oct. 10, 2017) which affirmed the
April 14, 2015 trial court judgment.
In light of the above presented facts, Waszczuk’s Declaration in Support,
and Waszczuk’s Request for Judicial Notice Waszczuk praying that the
relief sought by him should be granted and that the remittitur should be
recalled, the appeal should be reinstated or, alternatively the 3DCA
10/10/2017 unpublished opinion should modified. and remanded to the trial
court with instructions to vacate the April 14, 2015 Court Order and
Judgment which granted the anti-SLAPP motion to the Defendants.
Furthermore, Waszczuk prays the 3DCA award legal fees on the appeal and
- 39 -
sanction of the Defendants for the frivolous and fraudulent anti-SLAPP
motion filed on December 1, 2014.
Respectfully submitted on June 18, 2021 by the TrueFiling
___________________________________
Jaroslaw Waszczuk, Plaintiff & Appellant
- 40 -

this Motion for Recall the Remittitur contains 8147 words, based on the
word- count feature of my word-processing program.
Jaroslaw Waszczuk
_______________________
Plaintiff & Appellant , In Pro Per
- 41 -
Re: Waszczuk v. Regents of Univ. of Cal., C079524 (Cal. Ct. App. Oct. 10,
2017)
I, IRENA WASZCZUK the undersigned, declare that 1 am over 18 years of

age and not a party to the within cause; my address is 2216 Katzakian Way,
Lodi, CA. 95242. On June 18, 2021, I served a true copy of the attached
each of the following,
Motion to Recall Remittitur.



350 McAllister St.

California that the foregoing is true and correct. Executed on June 17, 2021
, at Lodi CA
_____________________________________________________
IRENA WASZCZUK
- 42 -
EXHIBITS
1-46
- 43 -
EXHIBIT # 1
EXHIBIT # 2
NOT TO BE PUBLISHED

(Sacramento)
----

34201300155479CUWTGDS)
v.

CALIFORNIA et al.,

1
2
3
FACTS
4
September 30, 2014.
5
Plaintiff appeals.
DISCUSSION
I
The Allegations
6
7
8
II
The Merits
9
10
termination.”
11
prevailing.
12
(Gov. Code, § 8547.10.)
III
13
DISPOSITION
RAYE , P. J.
We concur:
NICHOLSON , J.
ROBIE , J.
14
EXHIBIT # 3
MINUTE ORDER
DATE: 02/09/2015 TIME: 09:37:00 AM DEPT: 53
CLERK: K. Pratchen
REPORTER/ERM:
CASE NO: 34-2013-00155479-CU-WT-GDS CASE INIT.DATE: 12/04/2013

CASE TITLE: Waszczuk vs. The Regents of the University of California
CASE CATEGORY: Civil - Unlimited
EVENT TYPE: Motion to Strike (SLAPP) - Civil Law and Motion - MSA/MSJ/SLAPP
APPEARANCES
Nature of Proceeding: Ruling On Submitted Matter (Motion to Strike (SLAPP)) Taken Under
Submission 2/6/2015
TENTATIVE RULING
Defendants Michael Boyd, Stephen Chilcott, Danesha Nichols, Cindy Oropeza and Brent Seifert's
Special Motion to Strike the First through Fourth Causes of Action of Self-represented Plaintiff's Second
Amended Complaint is GRANTED.
This motion was continued to today's date to permit the self-represented plaintiff to file his own
opposition to the motion. Although no substitution of attorneys has yet been filed with the Court, the
court accepts the representation of plaintiff in his Dec. 29, 2014 Declaration in which declared that he
terminated Douglas Stein as his counsel of record on Dec. 16, 2014. A substitution of attorneys
signed by both former attorney and the plaintiff is still required to be filed with the Court by
plaintiff.
At the plaintiff's request, the Court has considered none of the papers filed by his former attorney
Douglas E. Stein in opposition to this motion. The Opposition papers filed by the self-represented
plaintiff were filed and served by US Mail on Jan. 23, 2015, instead of on Jan. 21, 2015, as ordered by
the Court. Further, the service was by US Mail, rather by personal delivery, facsimile transmission,
express mail, or other means reasonably calculated to ensure delivery to the other party or parties not
later than the close of the next business day after the time the opposing papers are filed, as required by
Code Civ. Proc. § 1005(b). Moving party has therefore been deprived of at least three business days in
which to prepare their reply.
Additionally plaintiff's opposing Memorandum of Points and Authorities exceeds the 15 page limit
provided in California Rules of Court, Rule 3.1113. Despite this failure to comply with the California
Rules of Court, the Court has read and considered the entire 34 page document. In future filings, absent
ex parte order permitting a longer memorandum, the self-represented plaintiff is admonished to abide by
the page limitations.
DATE: 02/09/2015 MINUTE ORDER Page 1

CASE TITLE: Waszczuk vs. The Regents of the CASE NO: 34-2013-00155479-CU-WT-GDS
University of California
As noted, despite these failures to comply with the Court order and the applicable statutes, the Court has
considered plaintiff's opposition papers.
The Court declines to consider plaintiff's 17 page "Response to Defendant's Reply Brief" with attached
filed on Feb. 2, 2015, as there is no statutory right to such a supplemental brief.
Defendants' Evidentiary Objections are OVERRULED.
At the outset, the Court would note that a self-represented party is to be treated like any other party and
is entitled to the same, but no greater consideration than other litigants and attorneys. (Williams v.
Pacific Mutual Life Ins. Co. (1986) 186 Cal. App. 3d 941, 944) Thus, as is the case with attorneys,
self-represented litigants must follow correct rules of procedure. Nwosu v. Uba (2004) 122 Cal. App. 4th
1229, 1246-1247; see also Rappleyea v. Campbell (1994) 8 Cal. 4th 975, 984.
Second Amended Complaint
Plaintiff's Second Amended Complaint sets forth eight causes of action: the 1st for intentional infliction of
emotional distress, 2nd for tortious interference with economic advantage, 3rd for harassment, failure to
prevent harassment, discrimination and retaliation under FEHA, 4th for whistleblower/unlawful
retaliation, 5th for violation of Health & Safety Code, sec. 1278.5, 6th for breach of written contract, 7th
for wage and hour violations and 8th for rescission - unlawful contract.
Moving party defendants move to specially strike the 1st through 4th causes of action, only, as each
arises out of acts in furtherance of the right of petition or free speech in connection with a public issue
and plaintiff cannot establish a likelihood of success on the merits.
Anti-SLAPP procedure
The Court must follow a "two-step process for determining whether an action is a SLAPP." Navellier v.
Sletten (2002) 29 Cal.4th 82, 88. First, whether the defendant has made a threshold prima facie
showing that the defendant's acts, of which the plaintiff complains, were ones taken in furtherance of the
defendant's constitutional rights of petition or free speech in connection with a public issue. If the court
finds that such a showing has been made, then the plaintiff will be required to demonstrate that "there is
a probability that the plaintiff will prevail on the claim." The defendant has the burden on the first issue,
the threshold issue; the plaintiff has the burden on the second issue. Kajima Engineering & Construction,
Inc. v. City of Los Angeles (2002) 95 Cal.App.4th 921, 928. "Only a cause of action that satisfies both
prongs of the anti-SLAPP statute--i.e., that arises from protected speech or petitioning and lacks even
minimal merit--is a SLAPP, subject to being stricken under the statute." Navellier v. Sletten (2002)29
Cal.4th 82, 89.
Petition or Free Speech
Code Civ. Proc. § 425.16 (e) provides: "As used in this section, "act in furtherance of a person's right of
petition or free speech under the United States or California Constitution in connection with a public
issue" includes: (1) any written or oral statement or writing made before a legislative, executive, or
judicial proceeding, or any other official proceeding authorized by law, (2) any written or oral statement
or writing made in connection with an issue under consideration or review by a legislative, executive, or
judicial body, or any other official proceeding authorized by law,..."
The California legislature enacted Code of Civil Procedure section 425.16, known as the anti-SLAPP
statute, to provide a procedural remedy to dispose of lawsuits and causes of action that are brought to
chill the valid exercise of the constitutional rights to free speech and to petition the government for

redress of grievances.(See Rusheen v Cohen (2006) 37 Cal.4th 1048, 1055-1056. These provisions
apply to SLAPP suits brought against public entities and public employees. See San Ramon Valley Fire
Prot Dist v Contra Costa County Employees' Ret Ass'n (2004) 125 Cal.App.4th 343, 353; see also City of
Cotati v. Cashman (2002) 29 Cal. 4th 69.
It is well established that the policies of Defendant University, including the Personnel Policies for Staff
Members ("PPSM") and UC Davis Policy and Procedure Manual ("PPM"), have the force and effect of
state statute. (Kim v. Regents of University of California (2000) 80 Cal.App.4th 160, 165.)
Statutory procedures qualify as official proceedings authorized by law for section 425.16 purposes.
(Vergos v. McNeal (2007) 35 Cal.App.4th 1387, 1399.) The constitutional right to petition includes the
act of seeking administrative action. (Briggs v. Eden Council for Hope & Opportunity (1999) 19 Cal.4th
115.) Investigations and investigatory reports prepared in connection with an issue under consideration
or review by an official body, such as a public entity's internal investigations, are protected activities
under the anti-SLAPP statute. (See Miller v. City of Los Angeles (2009) 169 Cal App.4th 1373, 1383;
Hansen v California Dept of Corrections and Rehabilitiation (2008) 171 Cal.App.4th 1537, 1544; Briggs v.
Eden Council for Hope & Opportunity (1999) 19 Cal. 4th 1106.)
In this case, the speech by Chilcott, Boyd, Oropeza, Seifert, and Nichols that is at issue were made in
connection with the processing, investigation, hearing and deciding the workplace complaints filed by
Plaintiff and others pursuant to University policies.
The allegations of the SAC against Nichols attack her protected participation in the official investigations.
The SAC specifically alleges Nichols' communications regarding the investigation. (SAC, paras. 70 (l),
(o), (q), (s), (x), (AA)) and her investigative conclusions (SAC para. 70 (v), (KK)). Nichols was appointed
to investigate Plaintiffs whistleblower complaints, and was also appointed to conduct an investigation
into complaints of workplace violence filed by Putney and Daniliuc. All were protected petitioning
activities.
The allegations against Boyd and Chilcott are limited to their receipt of emails from Nichols relating to
the investigations, and Chilcott's sending of an email relating to the investigation of Plaintiff (SAC, para.
70(m), (x), (AA).) The emails are protected speech in connection with an investigation process.
The allegations against Oropeza and Seifert are based upon their investigation into the emails plaintiff
sent to Nichols in April 2012. Oropeza and Seifert conducted their investigation pursuant to the
University's grievance protocol and reached conclusions documented in a report.
Boyd acted as Complaint Resolution Officer ("CRO") at Step II of the University's PPSM 70 process,
hearing and deciding Plaintiff's appeal of his termination. In Vergos, supra, 146 Cal.App.4th at
1399-1400, the Court held that defendant reviewer was entitled to the protection of the anti-SLAPP
statute for denying the grievance. Specifically, in Vergos, a state university employee pursued an
internal grievance against his supervisor for sexual harassment. In an administrative proceeding
authorized by the Regents of the University of California, the hearing officer denied the grievance. The
employee then filed a civil rights suit against the hearing officer, alleging that her decision had failed to
protect him from future harassment. (Id. at pp. 1390-1392, 1396-1397.) The hearing officer filed a
special motion to strike, contending that her communications were made in connection with an issue
under consideration in an official proceeding. (See § 425.16, subd. (e)(2).) The trial court denied the
motion. The Court of Appeal reversed because "[t]he gravamen of plaintiff's [claim] is [the hearing
officer's] communicative conduct in denying plaintiff's grievances. The hearing, processing, and
deciding of the grievances (as alleged in the complaint) are meaningless without a communication of the
adverse results." (146 Cal.App.4th at p. 1397.) Thus, Vergos recognized that the anti-SLAPP statute

applies where liability is based on protected speech. (See Id. at pp. 1397-1399)
Moving parties have established that their speech and writings are protected as made in connection with
an issue under consideration or review by an official proceeding authorized by law. The burden
therefore shifts to plaintiff to show that he will prevail.
Probability That Plaintiff Will Prevail
Plaintiff must show a likelihood of prevailing on each of the elements of his causes of action, and must
also show a likelihood of defeating any applicable affirmative defenses. (Wilcox v. Superior Court (1994)
27 Cal.App.4th 809, 820, 824; see also Paul of Council v. Hanyecz (2001) 85 Cal.App.4th 1356, 1367,
overruled on other grounds in Equilon Enterprises v. Consumer Cause, Inc. (2002) 29 Cal.4th 53, 68.)
The test to use to determine Plaintiffs probability of prevailing is similar to the standard applied to
evidentiary showings in motions for summary judgment, and the supporting facts must be demonstrated
by way of competent, admissible evidence. (Church of Scientology v. Wollersheim (1996) 42 Cal.App.4th
628, 654-655.) The difference between summary judgment and anti-SLAPP is that the burden is on the
opposing party plaintiff to show the likelihood of prevailing.
In order to establish the necessary probability of prevailing, plaintiff was required both to plead claims
that were legally sufficient, and to make a prima facie showing, by admissible evidence, of facts that
would merit a favorable judgment on those claims, assuming plaintiff's evidence were credited. The court
does not, however, weigh the parties' evidence, in terms of either credibility or persuasiveness. Rather,
the defendant's evidence is considered with a view toward whether it defeats the plaintiff's showing as a
matter of law, such as by establishing a defense or the absence of a necessary element. 1-800
Contacts, Inc. v. Steinberg (2003) 107 Cal. App. 4th 568, 584-585.
1st For Intentional Infliction of Emotional Distress
An essential element of pleading a claim for intentional infliction of emotional distress is a showing of
outrageous conduct beyond the bounds of human decency. Managing personnel is not outrageous
conduct beyond the bounds of human decency, but rather conduct essential to the welfare and
prosperity of society. A simple pleading of personnel management activity is insufficient to support a
claim of intentional infliction of emotional distress, even if improper motivation is alleged. If personnel
management decisions are improperly motivated, the remedy is a suit against the employer for
discrimination. Janken v. GM Hughes Electronics (1996) 46 Cal. App. 4th 55, 80.
What plaintiff has alleged, and what his evidence in opposition appears to support, are complaints
concerning personnel management by defendants. Pleading of personnel management activity is
"insufficient to support a claim of intentional infliction of emotional distress, even if improper motivation is
alleged." (Janken, supra.)
Plaintiff has failed to provide any legal authority or analysis as to why the facts before the court show the
likelihood of his prevailing on this cause of action.
2nd Tortious Interference with Economic Advantage
Plaintiff's claim tortious interference with economic advantage against Defendants. An employee or
former employee cannot sue a current or former supervisor or employee for interfering with his or her
prospective economic advantage by inducing the employer to terminate the plaintiff's employment.
(Shepperd v. Freeman (1998) 67 Cal.App.4th 339, 347; Shoemaker v. Myers (1990) 52 Cal.3d 1, 24.)


3rd for Discrimination
In the third cause of action, Plaintiff alleges violation of FEHA, both Section 12940(a) which prohibits
discrimination and Section 12940(k) which addresses the failure to prevent discrimination.
These claims are not properly pleaded against the individual Defendants as individuals cannot be sued
for discrimination under the FEHA, nor can they be sued for failing to prevent discrimination, retaliation,
and harassment. (Reno v. Baird (1998) 18 Cal.4th 640, 663- 664; see, also Janken, supra, at p. 63.) In
Janken the Supreme Court noted the "fundamental distinction" between the way the FEHA treats
harassment, on the one hand--for which supervisors may be held personally liable, and discrimination on
the other hand--for which, Janken held, individuals are not personally responsible.
4th for Whistleblower/Unlawful Retaliation

Plaintiff's Fourth Cause of Action brought pursuant to Gov. Code § 8547.10 for whistleblower retaliation.
Plaintiff has not established that moving defendants' conduct was in retaliation for plaintiff's
whistleblowing.
The mere fact that Nichols, Oropeza and Seifert conducted investigations and reached conclusions with
which Plaintiff does not agree with does not establish their investigatory findings are an act of retaliation.
Nor can Boyd's decision to deny Plaintiffs grievance at the Step II level of PPSM 70 review be deemed
to be a retaliatory action. Finally, there is no allegation that Chilcott took any particular action against
Plaintiff that could be deemed to be a retaliatory action.
As a matter of law, Plaintiff has not shown that he can prevail on any of his four causes of action against
moving party defendants. Given the Court's determination the Court need not address the Regents'
other arguments based on Gov't Code 821.6. It bears noting, however, that immunity extends to
investigations even if there is a later decision not to institute administrative proceedings or to initiate a
prosecution. See Ingram v Flippo (1999) 74 Cal.App.4th 1280, 1293.
The anti-SLAPP motion is therefore granted as to moving defendants Michael Boyd, Stephen Chilcott,
Danesha Nichols, Cindy Oropeza and Brent Seifert only, as to the 1st through 4th causes of action, only.
The Discovery Stay is ordered lifted.

Prevailing defendants on a motion to strike must file a separate motion to recover their attorneys' fees
and costs.
The prevailing parties shall prepare a formal order for the Court's signature pursuant to C.R.C. 3.1312.

COURT RULING
The matter was argued and submitted. The matter was taken under submission.
SUBMITTED MATTER RULING

Having taken the matter under submission on 2/6/2015, the Court now rules as follows:
The Court affirms the tentative ruling.

MINUTE ORDER
DATE: 04/14/2015 TIME: 02:00:00 PM DEPT: 53
CLERK: E. Brown
REPORTER/ERM:

EVENT TYPE: Motion - Other - Civil Law and Motion
APPEARANCES
Nature of Proceeding: Ruling on Submitted Matter (Motion for Reconsideration of the 2/9/2015
Order) taken under submission on 4/10/15
TENTATIVE RULING
Self-represented Plaintiff's Motion for Reconsideration of Order Dated Feb. 9, 2015 Anti-SLAPP Motion
is DENIED.
A self-represented party is to be treated like any other party and is entitled to the same, but no greater
consideration than other litigants and attorneys. (Williams v. Pacific Mutual Life Ins. Co. (1986) 186 Cal.
App. 3d 941, 944) Thus, as is the case with attorneys, self-represented litigants must follow correct rules
of procedure. Nwosu v. Uba (2004) 122 Cal. App. 4th 1229, 1246-1247; see also Rappleyea v. Campbell
(1994) 8 Cal. 4th 975, 984.
Plaintiff's motion for reconsideration was filed and served by US Mail on Feb. 20, 2015. No hearing date
appeared on the Motion papers. On Feb. 25, 2015, an Amended Notice of Motion reflecting the hearing
date of March 6, 2015 was filed and served by US Mail. That notice, counting backwards from March 6
to Feb. 20, allowed only 10 court days' notice instead of the required16 court days' notice, and allowed
none of the five additional calendar days for service by mail, as required by C.C.P., sec. 1005 and 12c.
The hearing date was continued to today's date at the request of the moving party.
Defendant's opposition to the motion for reconsideration objects to the untimely notice and further
asserts that moving party has failed to meet the requirements of a motion for reconsideration under
C.C.P., sec. 1008.
A motion for reconsideration must be made (i) within 10 days after service upon the party of written
notice of entry of the order and (ii) based upon new or different facts, circumstances, or law, and (iii) to
the same judge or court that made the order. C.C.P. section 1008(a). C.C.P. section 1008 is the
exclusive means for modifying, amending or revoking an order. That limitation is expressly jurisdictional.

Morite of California v. Superior Court (1993) 19 Cal. App. 4th 485, 490.
Moving party fails to base his motion for reconsideration upon any new or different facts, circumstances,
or law. Instead, plaintiff contends that the Court failed to read his opposition and attached exhibits to the
anti-SLAPP motion. Moving party contends that the Court should have accepted his supplemental brief,
which argues that the SLAPP motion violated an earlier stipulation between the parties to permit the
filing of a second amended complaint, that some unidentified new authority applies to the anti-SLAPP
motion in an unidentified manner and that the Court erred in its anti-SLAPP ruling.
None of these contentions is sufficient to satisfy the statutory requirements that the motion for
reconsideration be "based upon new or different facts, circumstances, or law."
A trial court has no jurisdiction to reconsider a prior order on the basis of different facts, circumstances
or law in the absence of a satisfactory explanation for the failure to present them earlier. Baldwin v.
Home Savings of America (1997) 59 Cal. App. 4th 1192, 1200. Further, if the plaintiff is not required to
explain the failure to earlier produce pertinent legal authority that was available, the ability of a party to
obtain reconsideration would expand in inverse relationship to his competence. Without a diligence
requirement the number of times a court could be required to reconsider its prior orders would be limited
only by the ability of the party to belatedly conjure a legal theory different from those previously rejected,
which is not much of a limitation. Baldwin v. Home Savings, supra, 59 Cal. App. 4th 1192, 1199.
The Court has read and considered plaintiff's objections to the formal order. The Court will sign the
formal order submitted on the anti-SLAPP motion.
COURT RULING
The matter was argued and submitted. The Court affirmed the tentative ruling.

Declaration of Mailing
I hereby certify that I am not a party to the within action and that I deposited a copy of this document in
sealed envelopes with first class postage prepaid, addressed to each party or the attorney of record in
the U.S. Mail at 720 Ninth Street, Sacramento, California.
Dated: April 14, 2015
E. Brown, Deputy Clerk _____s/ E. Brown_____
JAROSLAW WASZCZUK
2216 KATZAKIAN WAY
LODI, CA 95242

DAVID P.E. BURKETT

PORTER SCOTT
350 UNIVERSITY AVE., SUITE 200
SACRAMENTO, CA 95825

OEPAR
P O R T E R I S C O T T APR 1 4 •
Douglas L. Ropel, SBN 300486
Sacramento, California 95825
TEL: 916.929.1481
FAX: 916.927.3706
dburkettfalporterscott.com
6
7
CINDY OROPEZA. PATRICK PUTNEY, ANN MADDEN RICE,
10
Exempt from Filing Fees Pursuant to Government Code § 6103
11
^ 12 SUPERIOR COURT OF CALIFORNIA, COUNTY OF SACRAMENTO
13
H 3 S _ VD
^ tn m OO ^
o 2 P; 14
> U O; Os JAROSLAW ("JERRY") WASZCZUK, CASENO. 34-2013-00155479
15
: 0\ ON
Plaintiff, ' -feROPeSBDi- ORDER GRANTING
DEFENDANTS BOYD, CHILCOTT,
3
17 NICHOLS, OROPEZA AND SEIFERT'S
SPECIAL MOTION TO STRIKE FIRST
18 THE REGENTS OF THE UNIVERSITY THROUGH FOURTH CAUSES OF
19 OF CALIFORNIA, UNIVERSIW OF ACTION OF PLAINTIFlP'S SECOND
GALIFORNL\ DAVIS HEALTH SYSTEM, AMENDED COMPLAINT
DAVIS, ANN MADDEN RICE, MIKE DATE: February 6,2015
21 BOYD, STEPHEN CHILCOTT, CHARLES TIME: 2:00 P.M.
22 WITCHER DANESHA NICHOLS. CINDY DEPT: 53
OROPEZA, BRENT SEIFERT, PATRICK
23 PUTNEY. DORIN DANILIUC, and does I
through 50. inclusive. Complaint Filed: December 12,2013
24
25 Defendants SAC Filed: September 30,2014
26
///
27
28 ///
{01362378.OOCX} 1
(PROPOSED! ORDER GRANTING DEFENDANTS BOYD, CHILCOTT, NICHOLS, OROPEZA AND
SEIFERT'S SPECIAL MOTION TO STRIKE FIRST THROUGH FOURTH CAOSES OF ACTION OF
PLAINTIFF'S SECOND AMENDED COMPLAINT
1 Defendants MIKE BOYD, STEPHEN CHILCOTT, DANESHA NICHOLS, CINDY
2 OROPEZA, and BRENT SEIFERT ("Defendants") filed a Special Motion to Strike four causes of
3 action, as pleaded against them, from PlaintifTs Second Amended Complaint pursuant to Code of
4 Civil Procedure section 425.16. Specifically, Defendants brought the Motion to strike Plaintiffs
5 causes of action against them for: (1) Intentional Infliction of Emotional Distress; (2) Tortious
6 Interference with Economic Advantage; (3) Discrimination and Failure to Prevent Harassment,
7 Discrimination, and Retaliation under Government Code section 12940, subdivisions (a) and (k);
S and (4) Whistleblower Retaliation under Govemment Code section 8547 et seq.
9 On Febmary 5, 2015, the Court issued a Tentative Ruling, which is incorporated as
10 Exhibit A, granting Defendants' Motion.,; Pursuant to PlaintifPs request, the Motion was heard
11 before the Honorable Judge David I. Brown on Febmary 6, 2015. After hearing from the parties
12 and taking the matter under submission, the Court affirmed its Tentative Ruling vîth the issuance
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a in 13 of a Minute Order on Febmary 9, 2015. The Court's Minute Order ruled as follows:
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14 Defendants Michael Boyd, Stephen Chilcott, Danesha Nichols, Cindy
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1J V 'Oropeza and Brent Seifert's Special Motion to Strike the First thfough
Fourth Causes of Action of Self-represented Plaintiffs Second Amended
W >. c ^ >< 16 Complaint is GRANTED.
fell ^ 5: ,
211 17 This motion was continued to permit the self-represented plaintiff to file
o his own opposition to the motion. Although no substitution of attorneys
18 has yet beenfiledwith the Court, the Court accepts the representation of
I plaintiff in his Dec. 29, 2014 Declaration in which declared that he
19
terminated Douglas Stein as his counsel of record on Dec. 16, 2014. A
20 substitution of attorneys signed by both former attorney and the
plaintiff is still required to befiledwith the Court by piaintifT.
21
22 At the plaintiffs request, the Cpurt has considered none of the papers filed
by his former attomey Douglas E. Stein in opposition to this motion. The
23 Opposition papers filed by the self-represented plaintiff were filed and
served by US Mail on January 23, 2015, instead of on January 21,2015, as
24 ordered by the Court. Further, the service was by US Mail, rather by
25 personal delivery, facsimile transmission, express mail, or other means
reasonably calculated to ensure delivery to the other party or parties not
26 later than the close of the next business day after the time the opposing
papers are filed, as required by Code Civ. Proc. § 1005(b). Moving party
27 has therefore been deprived of at least three business days in which to
28 prepare their reply.
I0I362378.DOCX} 2_
jPROPOSEDj ORDER GRANTING DEFENDANTS BOYD, CHILCOTT, NICHOLS, OROPEZA AND
SEIFERT'S SPECIAL MOTION TO STRIKE FIRST THROUGH FOURTH CAUSES OF ACTION OF
\
Additionally, plaintiff's opposing Memorandum of Points and Authorities
exceeds the 15 page limit provided in Califomia Rules of Court, Rule
2 3.1113. Despite this failure to comply with the Califomia Rules of Court, ^
the Court has read and considered the entire 34 page document. In future
3 filings, absent ex parte order pemiitting a longer memorandum, the self-
4 represented plaintiff is admonished to abide by the page limitations.
5 As noted, despite these failures to comply with the Court order and the
applicable statutes, the Court has considered plaintiffs opposition papers.
6 The Court declines to consider plaintiffs 17 page "Response to
7 Defendant's Reply Brief filed on Feb. 2, 2015, as there is no statutory
right to such a supplemental brief.
8 f
9
10 At the outset, the Court would note that a self-represented party is to be
treated like any other party and is entitled to the same, but no greater
II consideration than other litigants and attomeys. (Williams v. Pacific
Mutual Ufe Ins. Co. (1986) 186 Cal. App. 3d 941, 944) Thus, as is the
12
o case with attomeys, self-represented litigants must follow correct rules of
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a in 13 procedure. Nwosu v. Uba (2004) 122 Cal. App. 4th 1229, 1246-1247; see
[ _
3 0 0 — >o also Rajjpleyea v. Campbell (1994) 8 Cal. 4th 975, 984.
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O 5 < >- Second Amended Complaint
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>6 «> 16 Plaintiffs Second Amended Complaint sets forth eight causes of action:
o r- u. (1) intentionaL infliction of emotional distress; (2) tortious interference
17 with economic advantage; (3) harassment, failure to prevent harassment,
ex. discrimination and retaliation under FEHA; (4) whistleblower/unlawful
18
retaliation; (5) violation of Health & Safety Code section 1278.5; (6)
19 breach of written contract; (7) wage and hour violations; and (8) rescission
- unlawful contract.
20
21 Moving party defendants move to specially strike the 1st through 4th
causes of action, only, as each arises out of acts in furtherance of the right
22 of petition of free speech in connection with a public issue, and plaintiff
cannot establish a likelihood of success on the merits. '
23
24 Anti-SLAPP procedure
25 The Court must follow a "two-step process for determining whether an

action is a SLAPP." Navellier v. Sletien (2002)' 29 Cal.4th 82, 88. First,
26 whether the defendant has made a threshold prima facie showing that the
27 defendant's acts, of which the plaintiff complains, were ones taken in
furtherance of the defendant's constitutional rights of petition or free
28 speech in connection with a public issue. If the court finds that such a
(0I362378.DOCX)
(PROPOSEDI ORDER GRANTING DEFENDANTS BOYD, CHILCOTT, NICHOLS,' OROPEZA AND
showing has been made, then the plaintiff will be required to demonstrate
that "there'is a probability that the plaintiff will prevail on the claim." The
defendant has the burden on the first issue, the threshold issue; the
plaintiff has the burden on the second issue. Kajima Engineering
Construction. Inc. v. City of Los Angeles (2002) 95 Cal.App.4th 921, 928.
"Only a cause of action that satisfies both prongs of the anti- SLAPP
statule--i.e., that arisesfi-omprotected speech or petitioning and lacks
even minimal merit-is a SLAPP, subject to being stricken under the
statute." Navellier v., Sletten (2002)29 Cal.4th 82, 89.
6
7 Petition or Free Speech
8 Code Civ. Proc. § 425.16 (e) provides: "As used in this section, "act in
furtherance of a person'srightof petition orfi-eespeech under the United
9 States or Califomia Constitution in connection with a public issue"
10 includes: (1) any written or oral statement or writing made before a
legislative, executive, or 'judicial proceeding, or any other official
11 proceeding authorized by law, (2) any written or oral statement or writing
made in coruiection with an issue under consideration or review by a
12 legislative, executive, or judicial body, or any other official proceeding(
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" 14 The Califomia legislature enacted Code of Civil Procedure section 425.16,
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> W o\ Icnown as the anti-SLAPP statute, to provide a procedural remedy to
OC < o" ^ 2 15 dispose of lawsuits and causes of action that, are brought to chill the valid
.— o .
16 exercise of the constitutional rights to free speech and to petition the
govemment for redress of grievances.(See Rusheen v Cohen (2006) 37
o 17 Cal.4th 1048, 1055-1056. These provisions apply to SLAPP suits brought
against public entities and public employees. See San Ramon Valley Fire
18 Prot Dist V Contra Costa County Employees' Ret Ass'n (2004) 125
19 Cal.App.4th 343, 353; see also City ofCotati v. Cashman (2002) 29 Cal.
4th 69.
20
21 It is well established that the policies of Defendant University, including
the Personnel Policies for Staff Members ("PPSM") and UC Davis Policy
22 and Procedure Manual ("PPM"), have the force and effect of state statute.
(Kim V. Regents of University of California (2000) 80 Cal.App.4th 160,
23 165.) "1
24
Statutory procedures qualify as official proceedings authorized by law for
25 section 425.16 purposes. {Vergos v. McNeal (2007) 35 Cal.App.4th 1387,
1399.) The constitutional right to petition includes the act of seeking
26 administrative action. {Briggs v. Eden Council for Hope & Opportunity
27 (1999) 19 Cal.4th 115.) Investigations and investigatory reports prepared
in connection with an issue under consideration or review by an official
28 body, such as a public entity's internal investigations, are protected
<01362378.DOCX}
(PROPOSEDI ORDER GRANTING DEFENDANTS BOYD, CHILCOTT, NICHOLS, OROPEZA AND
activities under the anti-SLAPP statute. {See Miller v. City of Los Angeles
(2009) 169 Cal ARp.4th 1373, 1383; Hansen v California Dept of
Corrections and Rehabilitiation (2008) 171 Cal.App.4th 1537, 1544;
Briggs V. Eden Council for Hope & Opportunity (1999) 19 Cal. 4th 1106.)
In this case, the speech by Chilcott, Boyd, Oropeza, Seifert, and Nichols
that is at issue were made in cormection with the processing, investigation,
hearing and deciding the" workplace complaints filed by Plaintiff and
others pursuant to University policies.
The allegations of the SAC against Nichols attack her protected

participation in the official investigations. The SAC specifically alleges
Nichols' communications regarding the investigation. (SAC, ^ 70 (1), (o), ,
(q)> (s), (x), (AA)) and her investigative conclusions (SAC, ^ 70 (v),
(KK)). Nichols was appointed to investigate Plaintiffs whistleblower
10 complaints, and was also appointed to conduct an investigation into
complaints of workplace violencefiledby Putney and Daniliuc. All were
II protected petitioning activities.
12 The allegations against Boyd and Chilcott are limited to their receipt of
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lVi i n 13 emails from Nichols relating to the investigations, and Chilcott's sending
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of an email relating to the investigation of Plaintiff (SAC, ^ 70(m), (x),
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14 (AA).) The emails are protected speech in connection with an
u
ce: 15
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16 The allegations against Oropeza and Seifert are based upon their
OC 1^ 2 y <
investigation into the emails plaintiff sent to Nichols in April 2012.
o =5 W
17
OL. Oropeza and Seifert conducted dieir investigation pursuant to the
University's grievance protocol and reached conclusions documented in a
18 report.
19
Boyd acted as Complaint Resolution Officer ("CRO") at Step II of the
20 University's PPSM 70 process, hearing and deciding PlaintifPs appeal of
his termination. In Vergos, supra, 146 Cai.App.4th at 1399-1400, the
21
Court held that defendant reviewer was entitled to the protection of the
22 anti-SLAPP statute for denying the grievance.,Specifically, in Vergos, a
slate university employee pursued an intemal grievance against his
23 supervisor for sexual harassment. In an administrative proceeding
24 authorized by the Regents of the University of California, the hearing
officer denied the grievance. The employee then filed a civil rights suit
25 against the hearing officer, alleging that her decision had failed to protect
him from future harassment. (Id. at pp. 1390-1392, 1396-1397.) The
26 hearing officer filed a special motion to strike, contending that her
27 conaniunications were made in cormection with an issue under
consideration in an official proceeding. (See § 425.16, subd. (e)(2).) The
28 trial court denied the motion. The Court of Appeal reversed because "[t]he
i0136237g.DOCX>
gravamen of plaintiffs [claim] is [the hearing officer's] communicative
1 conduct in denying plaintiffs grievances. The hearing, processing, and
2 deciding of the grievances (as alleged in the complaint) are meaningless
without a communication of the adverse results." (146 Cal.App.4th at p.
3 1397.) Thus, Vergos recognized that the anti-SLAPP statute applies where
liability is based on protected speech. (See Id. at pp. 1397-1399)
4
5 Moving parties have established that their speech and writings are
protected as made in connection with an issue under consideration or
6 review by an official proceeding authorized by law. The burden therefore
7 shifts to plaintiff to show that he will prevail.
8 Probability That Plaintiff Will Prevail

9 Plaintiff must show a likelihood of prevailing on each of the elements of
10 his causes of action, and must also show a likelihood of defeating any
applicable affirmative defenses. (Wilcox v. Superior Court (1994) 27
II Cal.App.4th 809, 820, 824; see also Paul of Council v. Hanyecz (2001) 85
Cal.App.4th 1356, 1367, overmled on other grounds in Equilon
12 Enterprises v. Consumer Cause, Inc. (2002) 29 Cal.4th 53,68.) The test to
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V <n 13 use to determine Plaintiffs probability of prevailing is similar to the
i_ O)
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standard applied to evidentiary showings in motions for summary
Is 14 judgment, and the supporting facts must be demonstrated by way of
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15
competent, admissible evidence. (Church of Scientology v. Wollersheim
tc < 6 ve ^ (1996) 42 Cal.App.4th 628, 654-655.) The difference between summary
tu >. c Ov Cv
J >< 16 judgment and anti-SLAPP is that the burden is on the opposing party
l -^ S plaintiff to show the likelihood of prevailing.
13 </i
17
In order to establish the necessary probability of prevailing, plaintiff was
18 required both to plead claims that were legally sufficient, and to make a
19 prima facie showing, by admissible evidence, of facts that would merit a
favorable judgment on those claims, assuming plaintifPs evidence were
20 credited. The court does not, however, weigh the parties' evidence, in
terms of either credibility or persuasiveness. Rather, the defendant's
21
evidence is considered with a view toward whether it defeats the plaintiffs
22 showing as a matter of law, such as by establishing a defense or the
absence of a necessary element. (1-800 Contacts, Inc. v. Steinberg (2003)
23 107 Cal. App.4th 568, 584-585.)
24
1*' For Intentional Infliction of Emotional Distress
25
An essential, element of pleading a claim for intentional infliction of
26 emotional distress is a shovnng of outrageous conduct beyond the bounds
27 of hunian decency. Managing personnel is not outrageous conduct beyond
the bounds of human decency, but rather conduct essential to the welfare
28 and prosperity of society. A simple pleading of personnel management
0
(OI362378.DOCX>
|PROPOSED| ORDER GRANTING DEFENDANTS BOYD, CHILCOTT, NICHOLS, OROPEZA AND
activity is insufficient to support a claim of intentional infliction of
1
emotional distress, even if improper motivation is alleged. If personnel
2 management decisions are improperiy motivated, the remedy is a suit
against the employer for discrimination. (Janhen v. GM Hughes
Electronics (1996) 46 Cal.App.4th 55, 80.)
What plaintiffhas alleged, and what his evidence in opposition appears to

5 support, are complaints conceming personnel management by defendants.
Pleading of personnel management activity is "insufficient to support a
6 claim of intentional infliction of emotional distress, even if improper
motivation is alleged." (Janken, 46 Cal.App.4th at p. 80.) Plaintiff has
7
failed to provide any legal authority or analysis as to why the facts before
8 the court show the likelihood of his prevailing on this cause of action.
9 2"** Tortious Interference with Economic Advantage
10
Plaintiffs claim tortious interference with economic advantage against
II Defendants. Ah employee or former emjiloyee cannot sue a current or
former supervisor or employee for interfering with his or her prospective
o
12 economic advantage by inducing the employer to terminate the plaintiff's
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13 employment. (Shepperd v. Freeman (1998) 67 Cal.App.4th 339, 347;
L,
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Shoemaker v. Myers (1990) 52 Cal.3d 1, 24.)
14
H i6gs Plaintiff has failed to provide any legal authority or analysis as to why the
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15 facts before the court show the likelihood of his prevailing on this cause of
16 action. ^
in
17 3"" for Discrimination
18 In the third cause of action, Plaintiff alleges violation of the FEHA, both
19 section 12940(a), which prohibits discrimination, and Section 12940(k)
which addresses the failure to prevent discrimination.
20
These claims are not properly pleaded against the individual Defendants as
21
individuals cannot be sued for discrimination Under the FEHA, nor can
22 they be sued for failing to prevent discrimination, retaliation, and
harassment. (Reno v. Baird (1998) 18 Cal.4th 640, 663-664; see, also
23 , Janken, supra, 46 Cal.App.4th at p. 63.) In .lanken the Supreme Court
noted the "ftindamental distinction" between the way the FEHA treats
24
harassment, on the one hand—for which supervisors may be held
25 personally liable, and discrimination on the other hand~for which, Janken
held, individuals are not personally responsible.
26
27 Plaintiffhas failed to provide any legal authority or analysis as to why the
facts before the court show the likelihood of his prevailing on this cause of
28 action.
(OI36237g.DOCX}
(PROPOSED} ORDER GRANTING DEFENDANTS BOYD, CHILCOTT, NICHOLS, OROPEZA AND
4'" for Whistleblower/Unlawful Retaliation
1
Plaintiffs Fourth Cause of Action brought pursuant to Government Code

section 8547.10 for whistleblower retaliation.
Plaintiff has not established that moving defendants' conduct was in

retaliation for plaintiffs whistleblowing.
1
The mere fact that Nichols, Oropeza and Seifert conducted investigations
and reached conclusions with which Plaintiff does not agree v\dth does not
establish their investigatoryfindingsare an act of retaliation. Nor can
Boyd's decision to deny Plaintiffs grievance at the Step II level of PPSM
70 review be deemed to be a retaliatory action. Finally, there is no
allegation that Chilcott took any particular action against Plaintiff that
could be deemed to be a retaliatory action.
10
Plaintiff has failed to provide any legal authority or analysis as to why the
action.
12
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13 As a matter of law. Plaintiff has not shown that he can prevail on any of
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~ ee 'o his four causes of action against moving party defendants. Given the
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p u 2 P; 14 Court's determination the Court need not address the Regents' other
(J
> u o» o> arguments based on Govemment Code section 821.6. It bears noting,
oi < o" vb vo 15 however, that immtmity extends to investigations even if there is a later
16 decision not to institute administrative proceedings or to initiate a
prosecution. (See Ingram v Flippo (1999) 74 Cal.App.4th 1280, 1293.)
o 17
•n
The anti-SLAPP motion is therefore granted as to moving defendants
18
Michael Boyd, Stephen Chilcott, Danesha Nichols, Cindy Oropeza and
19 Brent Seifert only, as to thefirstthrough fourth causes of action.
20 The Discovery Stay is ordered lifted.

21
Prevailing defendants on a motion to strike mustfilea separate motion to
22 recover their attorneys' fees and costs.
23 The prevailing parties shall prepare a formal order for the Court's
24 signature pursuant to C.R.C. 3.1312.
25
IT IS THEREFORE ORDERED that the Special Motion to Strike the four causes of
26
action enumerated above, as pleaded against Defendants, from Plaintiff's Second Amended
Complaint is hereby GRANTED.
28
(OI36237g.DOCX) 8
IT IS FURTHER ORDERED that judgment be, and hereby is, entered in favor of
Defendants MIKE BOYD, STEPHEN CHILCOTT, DANESHA NICHOLS, CINDY OROPEZA,
and BRENT SEIFERT, and against Plaintiff JAROSLAW WASZCZUK for the four causes of
action asserted against them in the Second Amended Complaint.
5 ^ IT IS FURTHER ORDERED that Defendants are awarded their costs and the attorney's
6 fees incurred in conjunction with the Special Motion to Strike pursuant to Code ofCivil Procedure
7 section 425.16, subdivision (c)(1). Defendants shall file a separate motion to determine the
8 amount to be awarded.
9 IT IS SO ORDERED.
10 Dated: ,2015
11
12 JUDGE OF THE SUPERIOR COURT
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DAVID I. BROWN
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UJ >. c 9\ Ov Dated: February _,2015 By.
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<OI36237g.DOCX)
•• • \
EXHIBIT # 5

TEL: 916.929.1481
5 FAX: 916.927.3706 By: E, Medina
Deputy Clerk
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{01892012.DOCX}
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UNIVERSITY.
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appropriate.
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7 IX.
8 CONCLUSION
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PROOF OF SERVICE
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Jaroslaw Waszczuk
22
2216 Katzakian Way
23 Lodi, CA 95242
25
26
Wendy Strasser
27
28
{0I892012.DOCX} II
EXHIBIT # 6
EXHIBIT # 7
MINUTE ORDER
DATE: 10/31/2018 TIME: 02:00:00 PM DEPT: 53
CLERK: E. Brown
REPORTER/ERM:
BAILIFF/COURT ATTENDANT: R. Mays, M. Oreschak

APPEARANCES
Nature of Proceeding: Motion to Compel 1) Production 2) Special 3) Form-Gen. 4) Form-Empl. 5)

Admissions
TENTATIVE RULING
Defendant Regents of the University of California's unopposed motion to compel responses and to deem
requests for admission admitted is granted as set forth below.
Interrogatories and Request for Production

The motion is granted.
No later than November 21, 2018, Plaintiff Jarolsaw Waszczuk shall serve verified responses, without
objections, to Plaintiff's form and special interrogatories (sets one) and requests for production (set one).
The Court received a letter from Plaintiff purportedly attaching his answers to special interrogatories.
The Court simply notes that no responses to form interrogatories or request for production were
attached to the letter and in any event, service of responses after the motion was filed does not moot the
motion. Defendant is still entitled to an order. To be clear, a motion is "made" when it is filed and
served. (CCP § 1005.5.) However, to the extent that any responses served after the motion was filed
comply with the above order, they need not be re-served.
Defendant's request for sanctions in connection with the motion to compel responses is denied as the
motion was unopposed. Although California Rules of Court, Rule 3.1348 purports to authorize sanctions
if the motion is unopposed, the Court declines to do so, as the specific statutes governing this discovery
authorize sanctions only if the motion was unsuccessfully made or opposed. Any order imposing
sanctions under the C.R.C. must conform to the conditions of one or more of the statutes authorizing
sanctions. Trans-Action Commercial Investors, Ltd. v. Firmaterr, Inc. (1997) 60 Cal.App.4th 352, 355.
However, repeated conduct of failing to comply with discovery obligations may lead the Court to find an
abuse of the discovery process and award sanctions on that basis. Laguna Auto Body v. Farmers
Insurance Exchange (1991) 231 Cal. App. 3d 481.

Request for Admissions
Defendant's unopposed motion to deem matters in the requests for admission admitted is granted,
unless Plaintiff Jarolsaw Waszczuk serves, "before the hearing on the motion," proposed
responses that are in substantial compliance with CCP § 2033.220. (CCP § 2033.280(c).)
Defendant's request for mandatory monetary sanctions is connection with the motion to deem matters
admitted is granted. (CCP § 2033.280(c).) However, the requested amount of $5,200 for this
straightforward discovery motion is plainly excessive. Plaintiff Jarolsaw Waszczuk shall pay to
Defendant a mandatory monetary sanction in the amount of $520 ($260/hr x 2 hrs). The monetary
sanction is to be paid on or before December 1, 2018. If the sanction is not paid by that date, Defendant
may prepare for the Court's signature a formal order granting the sanctions, which may be enforced by a
separate judgment. (Newland v. Superior Court (1995) 40 Cal.App.4th 608, 615.)
The Court denies Defendant's alternate requests for issue, evidentiary, and/or terminating sanctions at
this time. The sanctions the court may impose are such as are suitable and necessary to enable the
party seeking discovery to obtain the objects of the discovery he seeks but the court may not impose
sanctions which are designed not to accomplish the objects of the discovery but to impose punishment."
(Caryl Richards, Inc. v. Superior Court (1961) 188 Cal. App. 2d 300, 304.) "The penalty should be
appropriate to the dereliction, and should not exceed that which is required to protect the interests of the
party entitled to but denied discovery. (Deyo v. Kilbourne (1978) 84 Cal. App. 3d 771, 793) The
discovery sanction cannot put the propounding party in a better position than they would have been in if
they had received the discovery. (Puritan Insurance Co. v Superior Court (1985) 171 Cal. App.3d 877,
884.)
Here, given that this is the first order with respect to the subject discovery, the drastic remedy of
terminating sanctions would be punitive. Further, while Defendant references Plaintiff's "vexatious"
conduct in this action, that conduct has nothing to do with the instant motion and in any event, is not a
basis for discovery sanctions. Such ad hominem comments serve no useful purpose in educating the
court as to the party's position, and distract more than they advocate. In short, they are more cathartic
than tactical.
Finally, the Court declines Defendant's requests that the Court impose a deadline for Plaintiff to seek
leave to file a third amended complaint. Defendant indicates that Plaintiff has represented that he
intends to seek leave to file a third amended complaint which is represented as being nearly 300 pages
long. Plaintiff's decision to seek leave or not seek leave is his to make and the Court will not impose a
deadline as part of this discovery motion.
The notice of motion provides the incorrect time and location for the hearing. This matter has been
assigned to Department 53 for law and motion purposes and Department 53 hears law and motion
matters at 2 p.m. Moving counsel is directed to immediately provide notice to Plaintiff of the correct time
and location of the hearing.
The minute order is effective immediately. No formal order pursuant to CRC Rule 3.1312 or further
notice is required.
COURT RULING
There being no request for oral argument, the Court affirmed the tentative ruling.

EXHIBIT # 8
MINUTE ORDER
DATE: 11/14/2018 TIME: 02:00:00 PM DEPT: 53
CLERK: E. Brown
REPORTER/ERM:

APPEARANCES
Nature of Proceeding: Motion to Compel 1) Production 2) Special 3) Form-Gen 4) Form-Emp 5)

Admissions
TENTATIVE RULING
At the outset, the Court must point out Defendant's procedural errors that have rendered an otherwise
simple motion confusing and created unnecessary work for the Court. Defendant initially noticed this
motion for October 31, 2018 but included the incorrect law and motion department on the notice. It then
apparently filed the identical motion and noticed it for hearing on November 13 and 14 in this
department. Defendant wrote a letter to the Clerk requesting that the Clerk drop the November 13,
hearing, but never requested that the Clerk drop the October 31, 2018 hearing. (ROA 164). As a result,
the Court issued a ruling for the October 31, hearing. Subsequently, the Court received correspondence
from Defendant indicating that it believed the October 31, 2018 ruling was in error because it requested
the clerk drop that hearing. The only request received by the Clerk was the letter requesting that the
November 13, 2018 hearing be dropped. Nevertheless, despite the fact that the instant motion was
essentially filed three times for three separate hearing dates, it appears that Defendant intended to have
the matter heard on today's date. As a result, the Court vacates the ruling issued in connection
with the October 31, 2018 hearing. Though as seen below, the ruling will be essentially the same.
No later than December 12, 2018, Plaintiff Jarolsaw Waszczuk shall serve verified responses, without

sanction is to be paid on or before December 14, 2018. If the sanction is not paid by that date,
Defendant may prepare for the Court's signature a formal order granting the sanctions, which may be
enforced by a separate judgment. (Newland v. Superior Court (1995) 40 Cal.App.4th 608, 615.)
884.)
than tactical.
deadline on a hypothetical motion as part of this discovery motion.

notice is required.
COURT RULING

EXHIBIT # 9
MINUTE ORDER
DATE: 02/08/2019 TIME: 09:00:00 AM DEPT: 43
JUDICIAL OFFICER PRESIDING: Thadd A. Blizzard
CLERK: S. Newsom
REPORTER/ERM: None
BAILIFF/COURT ATTENDANT: R. Singh

EVENT ID/DOCUMENT ID: ,16681756

EVENT TYPE: Order of Examination - OX Calendar
CAUSAL DOCUMENT/DATE FILED: Order for Appearance and Examination Jaroslaw "Jerry"
Waszczuk, 12/07/2018
APPEARANCES
Jaroslaw Waszczuk, self represented Plaintiff, present.
Dan Bardzell, counsel, present for Defendant(s).
Nature of Proceedings: Hearing on Order of Examination of Judgment Debtor
The above entitled cause came before this court for hearing on Order of Examination of Judgment
Debtor this date with the above indicated parties present.
Judgment Debtor, Jaroslaw Waszczuk was sworn and examined.

The examination was concluded and the parties were released.

EXHIBIT # 10
Jaros-Law@outlook.com
From: Jaros-Law@outlook.com
Subject: FW: Case No. 34-2013-00155479, Jaroslaw Waszczuk v. The Regents of the University of California. -
SUMMARY OF OUR MEETING IN THE COURT CAFETERIA ON FEBRUARY 8, 2019
Attachments: 00000-IN PRO PER.pdf; 0000-20190208-COURT ORDER APPEARANCE .pdf; 001-20180718- LETTTER
TO CLERK.pdf; 002-20181113- JUDGE BROWN BROWN.pdf; 003-ADM-2-2009- SETTLEMENT-
AGREEMENT (29-40).pdf; 004- REIBURSEMENT- STATE BAR.pdf; 005-20140718 LT DES to Coombs
(2).pdf; 006-20190129- SUPREME COURT CUIAB FILED.pdf; 007-12-15-2018 US TAX COURT.pdf;
FREEDOM OF SPEECH (004).jpg
From: Jaroslaw Waszczuk <jjw1980@live.com>

Sent: Sunday, February 10, 2019 3:58 PM
To: dbardzell@porterscott.com; Wendy Strasser <wstrasser@porterscott.com>; cdegroof@porterscott.com;
charles.robinson@ucop.edu; regentsoffice@ucop.edu; President@ucop.edu; 'David Burkett'
<dburkett@porterscott.com>
Cc: jregulska@ucdavis.edu; katehi@ucdavis.edu; gary.may@ucdavis.edu; Alexander.Bustamante@ucop.edu;
hexter@ucdavis.edu; Senator.Galgiani@senate.ca.gov; Erica.Myers@sen.ca.gov; judith.rosenberg@ucop.edu;
jatollefson@ucdavis.edu; wjdelmendo@ucdavis.edu; daoffice@sacda.org; sheriffcivil@sjgov.org; eversteeg@lodi.gov;
dalubarsky@ucdavis.edu; sblandford@lodi.gov; tjlindsey@UCDAVIS.EDU; whistleblower@judiciary‐rep.senate.gov;
losangeles.polishconsulate@msz.gov.pl; washington.amb@msz.gov.pl; ExecutiveDirector@calbar.ca.gov;
StateBarCourt@calbar.ca.gov; GC@calbar.ca.gov; CTC@calbar.ca.gov; antonia.darling@calbar.ca.gov;
Vanessa.Holton@calbar.ca.gov; WhistleblowerProtection@tigta.treas.gov.; Dwaine.Duckett@ucop.edu;
losangeles.legal@msz.gov.pl; ckerosky@polishconsul.com; margaritaf@auditor.ca.gov
Subject: Case No. 34‐2013‐00155479, Jaroslaw Waszczuk v. The Regents of the University of California. ‐SUMMARY OF
OUR MEETING IN THE COURT CAFETERIA ON FEBRUARY 8, 2019
Jaroslaw “Jerry” Waszczuk, Plaintiff in Pro Per

2216 Katzakian Way
Lodi, CA 95242
Phone: 209-663-2977
Fax: 209-833-7080
February 10, 2019
Sent by e-mail
Daniel Bardzell, J.D.

1
Subject: Appearance and Examination on February 8, 2019 at 9:00 a.m. at Department 43. Hon. Thadd
A. Blizzard, Case No. 34-2013-00155479, Jaroslaw Waszczuk v. The Regents of the University of
California.
RE: SUMMARY OF OUR MEETING IN THE COURT CAFETERIA ON FEBRUARY 8, 2019
Dear Mr. Bardzell,
For the record, I would like to briefly summarize our meeting that took place on February 8,
2019 in the Sacramento County Superior Court Cafeteria on the sixth floor at 9:30 a.m.
I and my witness, William Buckans (UC Davis Medical Center employee), viewed the meeting
as unpleasant, provocative, and hostile. William and I noticed that you were very nervous and
uncomfortable during the meeting. At some point when you started bringing my wife and children into
the terror I have been experiencing for the last 12 years from the University of California Office of the
President (UCOP) mob, William, who was sitting at the next table, turned his chair toward you and
looked at you. You did not know that William was my former coworker from the UC Davis Medical
Center 27 MW cogeneration plant where I worked from June 1999 to April 2007. You were also
informed previously that two Porter Scott attorneys attempted to provoke me into physical
confrontation outside the court room in February 2015 and in August 2017.
From your redundant and provocative questions about my wife, children, landlord, and the
insurance on my rental house, it was not difficult to conclude that Janet Napolitano is looking to inflict
a different type of harm to me and my family than to enforce the unlawful judgment (see the Letter to
the Clerk filed on July 18, 2018 and the Letter to Judge Brown filed on November 16, 2018).
Your questions about insurance on the rental house clearly indicate that UCOP mob led by
Janet Napolitano is planning a raid on my home with involvement from the Lodi Police or San Joaquin
Sheriff’s Department to terrorize me and my family by ransacking my house to cause psychological
trauma. As you probably read in court documents, I have been terrorized and hunted like a Jew during
the holocaust by the UCOP mob since January 2007, and I don’t see it ending soon while I’m still
alive.
During our meeting on February 8, 2019, I provided you with the following documents as potential
assets:
1. A copy of the January 31, 2009 Settlement Agreement by UC Regents and myself plus the
calculated damages of approximately $1,000,000 caused by UC Regents due to breach and
violation of this Settlement Agreement (attached).
2. The March 1, 2018 copy of the California Supreme Court decision, which ordered that I be paid
back my stolen retainer money in the amount of $14,694.33 plus 10% interest that I paid to my
2
former attorney, Douglas Stein, for representation. Stein on Discipline Case No. S245982
(attached).
3. The unfinished case with Liberty Assurance Company of Boston, which is in conspiracy with
UC Regents that denied my short disability benefits in 2011. Minimum value $4,546 (attached).
4. The unfinished unemployment insurance benefits case pending in the California Supreme Court,
Waszczuk v. California Unemployment Insurance Appeal Board 3DCA Case No. C079254,
Supreme Court Case No. – Value $25,000 if prevail.
5. Whistleblower case pending in the U.S. Tax Court, Waszczuk v. United States Commissioner of
Internal Revenue Services, Docket No. 023105. The IRS whistleblower case is about an
enormous amount of unlawful power sales by regents in conspiracy with Enron and the
California Independent System Operator and related to multimillion dollars in tax fraud. Fraud
was disclosed in August 2012 by UC Davis Assistant Vice Chancellor Dr. Shelton Duruisseau
in this interview with Sac Cultural Hub (attached). http://www.sacculturalhub.com/headlines/a-
look-back
“THE BLACKSMITH WAS GUILTY, BUT THE GYPSY WAS HANGED.” - Polish
proverb
In addition, after the meeting I forwarded to you my current bank statement from Rabobank and
an e-mail from Citibank with information about the account I have no access to. I believe that the
amount of $14,694.33 plus interest for five years should cover the judgment obtained by the Court by
David Burkett in violation of California Court Rules 3.1312 b, which states:
“That the prevailing party must, upon expiration of the five-day period provided for approval,
promptly transmit the proposed order to the court together with a summary of any responses of
the other parties or a statement that no responses were received pursuant to California Rule of
Court 3.1312(b).”
Defendants’ attorney David Burkett bluntly violated the California Rule of Court 3.1312(b) and did not
transmit to the Court the PLAINTIFF’S 90-page DISAPPROVAL OF THE PROPOSED ORDER
AND JUDGMENT GRANTING LEGAL FEES AND COSTS TO DEFENDANTS IN ANTI-SLAPP
MOTION C.C.P. 425.16 (c).
2018 David Burkett’s violation of Rule 3.1312(b) is a copycat scenario of the March 2015
PLAINTIFF’S DISAPPROVAL OF THE PROPOSED ORDER AND JUDGMENT GRANTING
DEFENDANTS’ ANTI-SLAPP MOTION C.C.P. 425.16 (ROA #73).
Very truly yours,
3
____________________________
Jaroslaw Waszczuk
CC: Sacramento County Superior Court Judge Hon. Thadd Blizzard, sent by U.S. Priority Mail on
February 11, 2019.
California Senator Cathleen Galgiani
State Bar of California
Lodi Police Department (Fax)
San Joaquin County Sheriff Department (Fax )
California Governor Office Hon. Gavin Newsom (FAX)
Consulate General of Polish Republic of Poland
Attachment:
4
EXHIBIT # 11
2
350 University Avenue, Suite 200 FILED/ENDORSED
TEL: 916.929.1481 FEB I I 2019
•5 FAX: 916.927.3706
dburkett(a),pbrterscott.com By:
6 £• Medina
dbardzellfolporterscott.com ueputy ciert«
7
10
11
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13 Plaintiff, DEFENDANT'S MEMORANDUM OF
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15 TO COMPEL FURTHER VERIFIED
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THE REGENTS OF THE UNIVERSITY RESPONSES TO SPECIAL
glig^ 16 OF CALIFORNIA, UNIVERSITY OF INTERROGATORIES SET ONE, FORM
CALIFORNIA DAVIS HEALTH INTERROGATORIES - GENERAL SET
o 17 SYSTEM, UC DAVIS MEDICAL ONE, FORM INTERROGATORIES -
CENTER, UC DAVIS, ANN MADDEN EMPLOYMENT SET ONE; AND FOR
18
RICE, MIKE BOYD, STEPHEN MONETARY AND TERMINATING
19 CHILCOTT, CHARLES WITCHER, SANCTIONS
DANESHA NICHOLS, CINDY
20 OROPEZA, BRENT SEIFERT, Date: March 13,2019
21 PATRICK PUTNEY, DORIN Time: 2:00 p.m.
DANILIUC, and Does 1 through 50, Dept.: 53
22 inclusive,
23 Defendants. Amended Complaint Filed: June 16,2014
25
26
27
28
(01965098.DOCX}
DEFENDANT'S MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF
DEFENDANT'S MOTION TO COMPEL FURTHER VERIFIED RESPONSES
TABLE OF CONTENTS
1
2
Page
3
4 I. INTRODUCTION 1
5 II. STATEMENT OF FACTS AND PROCEDURAL HISTORY 2

6 A. Plaintiff Ignores Defendant's Initial Meet-and-Confer Efforts 3
7
B. Motion to Compel 3
8
C. Plaintiff Again Ignores Defendant's Meet-and-Confer Efforts 4
9
10 D. Plaintiff Failed to Pay Monetary Sanctions 4
11 III. PLAINTIFF'S RESPONSES TO SPECIAL INTERROGATORIES

(SET ONE), FORM INTERROGATORIES - GENERAL (SET ONE)
12
o AND FORM INTERROGATORIES - EMPLOYMENT (SET ONE)
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13 ARE EVASIVE, INCOHERENT AND INCOMPLETE 5
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OV i3v
Instances He Provided No Substantive Response Whatsoever 6

o .> I S ^ 16
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17 C. Plaintiff Responded " I don't know" to Some Interrogatories
18 Without Describing Efforts to Provide a Response 7
19
IV. DEFENDANT IS ENTITLED TO MONETARY SANCTIONS 8
20
V. TERMINATING SANCTIONS ARE ALSO APPROPRIATE 10
21
22 VI. CONCLUSION ; 11
23
24
25
26
27
28
{0196S098.DOCX}
Page
State Court Cases
Calcor Space Facility, Inc. v. Superior Court

(1997) 53 Cal.App.4"' 216, 221 9
6
Deyo V. Kilbourne
7
(1978) 84 Cal.App.3d 771, 782-783 5, 6, 8
8
Kahn v. Kahn
9 (1977) 68 Cal.App.3d 372, 383 11
10
Mannino v. Superior Court
11 (1983) 142 Cal.App.3d 776 9
12 R.S. Creative, Inc. v. Creative Cotton, Ltd.
o
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13 (1999) 75 Cal.App.4"^ 486, 496 : 11
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(N f N (2008) 159 Cal.App.4"^ 316, 333 9
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17 212 So.2d 315, 317(1) (Fla.App. 1968) •. 6
18 Statutes
19
Califomia Rules of Court, Rule 3.1348 , 9
20
Califomia Rules of Court, Rule 3.1348(a) 9
21
22 Code ofCivil Procedure § 2023.010(d) 10
23 Code ofCivil Procedure § 2023.010(g) '. 10

24 Code ofCivil Procedure § 2023.030(a) 8, 9, 10
25
Code ofCivil Procedure § 2023.030(d) 10
26
27 Code ofCivil Procedure § 2030.210(a) 5
28 Code ofCivil Procedure § 2030.220 5, 8
(0I965098.DOCX} iii
Code ofCivil Procedure § 2030.220(a) 5
Code ofCivil Procedure § 2030.220(c) 5, 8
Code ofCivil Procedure § 2033.280 9

6
7 Govemment Code § 8547 2
8 Govemment Code § 12940(a) ; 2

9 Other Authority
10
4A Moore's Federal Practice (2d Ed. 1975)
11 Section 33.25(1), pp. 33-131- 33-132 6
12 Califomia Civil Discovery Practice, Section 8.55
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23
24
25
26
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28
{0I96S098.DOCX}
DEFENDANT'S MEMORANDUM OF POEVTS AND AUTHORITIES IN SUPPORT OF
3 support of its motion to: (1) compel Plaintiff JAROSLAW ("JERRY") WASZCZUK to provide
4 further verified responses to Special Interrogatories (Set One), Form Interrogatories - General (Set
5 One), Form Interrogatories - Employment (Set One); (2) award monetary sanctions in the amount
6 of $5,460 to retum Defendant to the position it would have been had the subject discovery
7 responses been timely and completely provided; (3) issue terminating sanctions against Plaintiff as
8 a result of Plaintiffs repeated failure to engage in the discovery process.
9 1.
10 INTRODUCTION
11 Defendant served Plaintiff with Special Interrogatories (Set One), Form Interrogatories -
o
12 General (Set One), Form Interrogatories - Employment (Set One) on April 25, 2018'. Responses
o
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B -r. 13 were due on or before May 30j 2018. Defendant provided Plaintiff with an extension to June 20,
VD
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14 2018 to provide responses to the requests. Plaintiff then failed to provide responses to any of
<N rvi
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vb ^ 15 Defendant's requests, requiring Defendarit to file a Motion to Compel. The Court granted that
Ov 0\
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oi
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a. o 17 pay Defendant monetary sanctions by December 14, 2018 related to Plaintiffs failure to respond to
18 requests for admission.
19 After the initial Motion to Compel, Plaintiff ultimately served his responses to special
20 interrogatories on October 15, 2018 and responses to form interrogatories - general and form
21 interrogatories - employment on December 13, 2019. These responses were mostly incomplete.
22 Defendant has attempted to meet-and-confer with Plaintiff regarding these deficiencies, but
23 consistent with his practice throughout this litigation, Plaintiff has refused to sufficiently and
24 coherently respond. As a result. Defendant now respectfully requests a further Order compelling
25 Plaintiff to cure the deficiencies raised in this Motion. Defendant also requests sanctions, pursuant
26 to 2030.290(c), in the amount of $5,460 for the fees and costs incurred as a result of Plaintiffs
27 continued disregard for the discovery process.
28
' Additional discovery requests outside the scope of the present motion were also served by Defendant at that time.
{01965098.DOCX} 1 ^
1 Defendant respectfully requests the Court issue an Order to (1) compel Plaintiff to provide
2 fiarther verified responses, without objection, to Defendant's Special Interrogatories (Set One),
3 Form Interrogatories - General (Set One), and Form Interrogatories - Employment (Set One); (2)
4 issue monetary sanctions against Plaintiff in the amount of $5,460 for Defendant's fees and costs
5 incurred in bringing this motion; and (3) issue the sanction of termination of the present action as a
6 result of Plaintiff s pattern of failing to comply with his discovery obligations. .
7 II.
8 STATEMENT OF FACTS AND PROCEDURAL HISTORY
9 The course of litigation in this matter is lengthy and complex. The following is a brief
10 summary: Plaintiff filed the operative Second Amended Complaint ("SAC") on Septehiber 30,
12 Defendants^: (1) intentional infliction of emotional distress ("IIED"); (2) tortious interference with
B "n 13 economic advantage; (3) FEHA harassment and failure to prevent harassment, discriminafion,
h '= 00 - vo
f— c/^ «-> 00 o
o u 2: P; 14 retaliation in violation of Government Code § 12940(a); and (4) whistleblower/unlawful retaliation
< § g 15
> ^ Ov Ov in violafion of Govemment Code §§ 8547 et seq.
< o" ^
o > i e < ^" Each of these causes of action arises out of Plaintiffs employment with Defendant at the
D 00
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17 University of Califomia at Davis Medical Center. In addition to Defendant UNIVERSITY^, these
20 SEIFERT, PATRICK PUTNEY, and DORIN DANILIUC for their participation in investigafions
21 and disciplinary actions that ultimately resulted in Plainfiffs terminafion of employment with the
22 UNIVERSITY. The UNIVERSITY is the only Defendant remaining in the case.
23 Defendant UNIVERSITY served Plaintiff with Special Interrogatories (Set One), Form
24 Interrogatories - General (Set One), and Form Interrogatories - Employment (Set One) on April 25,
25 2018. (See Declarafion of Daniel Bardzell in Support of Mofion to Further Compel ("Bardzell
26 Decl."), 2 and Exhibit A.) By correspondence dated May 22, 2018, Plainfiff requested an
27
^ The First and Second Causes of Action in the Second Amended Complaint do not specifically identify Defendant UNIVERSITY
28 but do refer to employment with UC DAVIS within the cause of action.
^ S e e f n . 1.
{01965098.DOCX} 2
extension offimeto respond to all such requests on the basis that he was sick. (See Bardzell Decl., |
3 and Exhibit B.) Defendant's counsel responded by email correspondence dated May 23, 2018
granfing Plaintiff an extension of fime to respond until June 20, 2018. (See Bardzell Decl., 4 and
Exhibit C.)
5 A. Plaintiff Ignores Defendant's Initial Meet-and-Confer Efforts
6 On September 24, 2018, counsel for Defendant served a meet and confer correspondence
8 [P]lease provide complete responses to all such outstanding requests no later than September 28,
9 2018. If we do not have your complete responses by that date, we will file a motion to compel
10 responses and request monetary as well as terminating sancfions from the Court." (See Bardzell
12
o
o By incoherent email correspondence also dated September 24, 2018, Plaintiff indicated:
fN
B >n 13 Thank you for news about the Request for Production of Documents and Special
L_ •— fN — vO
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Interrogatories . I appreciate but I not sure yet what I am going to . I am waiting for
V in C 14 answers from the federal authorities in this matter.
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15 I will let know . I mean fime you can entertain yourself with my affirmative defense
01 < 6 fN d
Ov OV of Judge Brett Kavanaugh. As Jeanine Pirro stated not so long ago , . UC Regent wife
H ^ \0 v ^
O ^ 2 as ov 16 Senator Feinstein's Unhinged Demon Rats attacking Judge Kavanaugh as I was
cu c attacked and wasted by her husband and other unhinged UC demon rats . Same
Vi
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18 check on 28^^ than I could buy ink for my printer and do eventually interrogatories.
(See Bardzell Decl., H 6 and Exhibit E.)
19
20
2018. (See Bardzell Decl., H 6.)
21
On October 1, 2018, Plainfiff submitted an email correspondence to Defendant stafing: " I
22
am working on the Interrogatories and other papers. Pleas give one more week to finish. Attached is
23
a part of interrogatories to show you that I am working on ." (See Bardzell Decl., TI 7 and Exhibit
24
F.) Included was a rambfing apparent partial draft response to Defendant's Special Interrogatories,
25
Set One without a verification. (See Bardzell Decl., Tl 8.)
26
B. Motion to Compel
27
Defendant was subsequently forced to file a Motion to Compel and needlessly incur the
28
{01965098.DOCX} 3 '
1 associated fees and costs. (See Bardzell Decl., Tl 8.) On November 14, 2018, the Court issued its
2 tentative mling, which later became the ruling of the Court pursuant to Local Rule 1.06. (See
3 Bardzell Deck, Tl 9, and Exhibit G). There, the Court ordered Plaintiff to provide verified responses,
4 without objections, to Defendant's form and special interrogatories (sets one) and requests for
5 producfion (set one) no later than December 12, 2018. (See Bardzell Decl., Tl 9, and Exhibit G).
6 Additionally, the Court ordered Plaintiff to pay Defendant mandatory monetary sancfions in the
7 amount of $520 by December 14, 2018 for failure to provide responses to requests for admissions.
8 (See Bardzell Deck, TI 9, and Exhibit G.)
9 Plaintiff did subsequently provide responses to the special and form interrogatories, but they
10 were largely deficient as described in the present motion. (See Bardzell Deck, TI 11-12 and Exhibits
11 H and I.)
12 C. Plaintiff Again Ignores Defendant's Meet-and-Confer Efforts
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13 In light of Plaintiffs deficient responses to form and special interrogatories, defense
'3
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enu
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oi < 0" vd vd 15 that Plaintiffs responses were deficient. (See Bardzell Decl., Tl 13 and Exhibit J.)
c 0! ON
Universi:
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- i >< 16 Plainfiff responded on January 15, 2019 by a series of argumentative and disjointed emails
Sacra
po:
FA
TE
17 which failed to address the interrogatory response deficiencies raised in Defendant's meet and
18 confer correspondence. (See Bardzell Deck, Tl 14 and Exhibits K.)
19 Plaintiff subsequently requested addifional time to respond to the meet and confer and the
20 parties agreed to extend the time for Defendant to file a mofion, if necessary, through Febmary 12,
21 2019. (See Bardzell Deck, Tl 15-17 and Exhibits L-N.)
22 By email dated January 25, 2019, Plainfiff further responded to Defendant's January 15,
23 2019 meet and confer correspondence by, in part, describing the interrogatories as harassing and
24 stating that Defendant should "File the mofion, and I , accordingly, will file the response to your
25 motion in court." (See Bardzell Deck, Tl 18 and Exhibits O.) As of the date of this Mofion, Plaintiff
26 has not provided amended responses. (See Bardzell Deck, TI 19.)
27 D. Plaintiff Failed to Pay Monetary Sanctions
28 In addition to Plaintiff willfially disregarding his discovery obligations, Plaintiff also
{01965098.DOCX) 4
1 violated the Court's previous Order by failing to fttlly pay Defendant monetary sancfions. (See
2 Bardzell Deck, Tl 9-10.) As set forth above, in its prior Order, the Court directed Plaintiff to pay
3 monetary sancfions of $520 by December 14, 2018. (See Bardzell Deck, Tl 9 and Exhibit G.)
4 Plainfiff provided checks amounting to only a small portion of the amount owed. (See Bardzell
5 Deck, Tl 10.) Defendant has not cashed such checks. (See Bardzell Deck, TI 10.) Plainfiff failed to
6 pay the required sancfion by December 14, 2018 and, to-date, Plaintiff has provided checks
7 amounting to only a small portion of the sanctions ordered by the Court. (See Bardzell Deck, TI 10.)
8 in.
9 PLAINTIFF'S RESPONSES TO SPECIAL INTERROGATORIES (SET ONE), FORM
10 INTERROGATORIES - GENERAL (SET ONE) AND FORM INTERROGATORIES -
11 EMPLOYMENT (SET ONE) ARE EVASIVE. INCOHERENT AND INCOMPLETE
o
12 A party to whom interrogatories have been propounded shall respond in writing under oath
o
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— ^ 14 being sought to be discovered, an exercise of the party's opfion to produce writings, or an objection
ov I--
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oi < 6 vd vd 15 to the particular interrogatory. (CCP § 2030.210(a).) Code ofCivil Procedure §2030.220 requires
Ov Ov
_i >< 16 that answers to interrogatories be "complete and straightforward." (CCP. §2030.220(a).) Code of
a. ta <
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17 Civil Procedure §2030.220 requires that parties produce all information "reasonably available" to
18 them in response to interrogatories. (CCP. §2030.220(a).) That obligation requires that parties
19- take all reasonable steps to investigate and obtain information responsive to the request. (CCP.
20 §2030.220(c).) If parties do not have sufficient informafion to respond to a request after making a
21 reasonable inquiry, they must state that fact in their response. (Id.) They should also detail the
22 efforts made to obtain the informafion. (Deyo v. Kilbourne (1978) 84 Cal.App.3d 771, 782-783.)
23 Parties cannot claim a lack of personal knowledge when the informafion "can be obtained from
24 sources under his control." (Id.) A party may move to compel further responses if an answer is
25 "evasive or incomplete." (CCP. §2030.300(a).)
26 Here, Plaintiff provided evasive, incomplete and incoherent responses to Defendant's
27 Form Interrogatories - General, Set One; Form Interrogatories - Employment, Set One and Special
28 Interrogatories, Set One. (See generally Defendant's Separate Statement of Disputed Discovery
{01965098.DOCX} 5
in Support of Motion to Compel ("Defendant's Separate Statemenf).)
Plaintiffs rambling and incoherent responses contain a myriad of deficiencies. Same are
set forth in greater detail in Defendant's Separate Statement. Plainfiffs responses to the form and
special interrogatories are generally deficient for the following reasons:
5 A. Plaintiff Improperly Cites External Documents
6 As set forth in greater detail in Defendant's Separate Statement, in response to
7 interrogatories, including, but not limited to, Special Interrogatories No. 2, 4, 5, 6, 9, 10, 11, 12,
8 13, 14, 17, 18, 19, 20, 21, 22, 25, 26, 27, 30, 37; and Form Interrogatories 6.4, 206.1,-206.2, and
9 207.1, Plainfiffs response cites to voluminous extemal documents and/or url addresses without
10 any specific page/line references or summary. (See Defendant's Separate Statement and Bardzell
11 Decl., Exhibits H-I.) It is not proper to answer by cifing to an extemal document. (See Deyo supra,
12 84 Cal.App.3d at 783-784 ("[I]f a question does require the responding party to make reference to
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< Q- vd ^ 1J 8.55 (C.E.B.1975); 4A Moore's Federal Pracfice (2d Ed. 1975), Secfion 33.25(1), pp. 33-131 to
w iv ^ 5:
33-132; State Road Dept. v. Florida East Coast Ry., 212 So.2d 315, 317(1) (Fla.App. 1968).)
3 Vi
17 (Further citafion omitted)). In instances where Plaintiff cites external documents, same are not
18 properly identified and summarized. (See Deyo, supra, 84 Cal.App.3d at 783-784.) Therefore,
19 these responses are improper and incomplete.
20 B. Plaintifrs Interrogatory Responses are Incomplete and In Some Instances He
21 Provided No Substantive Response Whatsoever
22 Plaintiff provided a multitude of incomplete responses, including numerous instances
23 where subparts are ignored. The following is a representafive sample of the such deficiencies: In
24 response to Form Interrogatories 6.4 and 6.5, respecfively, asking Plaintiff to idenfify
25 examinations or treatment related to his claims, and any medication, prescribed or not, as a result
26 of injuries that his' attributes to his claims, Plainfiff provides incomplete responses. (See
27 Defendant's Separate Statement and Bardzell Decl., Exhibit I.) Specifically, in response to
28 Interrogatory 6.4, Plaintiff fails to indicate the charges to date for health care services received.
{0i965098.DOCX} 6
(See Defendant's Separate Statement and Bardzell Deck, Exhibit I.) In response to Form
2 Interrogatory 6.5, Plaintiff fails to respond to subparts including (c) the date his prescription(s)
3 were prescribed orfiamished;(d) the dates you began and stopped taking it; and (e) the cost to
4 date. (See Defendant's Separate Statement and Bardzell Deck, Exhibit I.)
5 Moreover, in response to Form Interrogatories 10.1-10.3, which generally seek information
6 regarding treating physicians and treatment before and after the claims arose, Plaintiff fails to
7 identify any treating physicians or what treatment was sought beyond the facial reference to heart
8 surgery. (See Defendant's Separate Statement and Bardzell Deck, Exhibit I.) The content of the
9 response plainly calls for additional responsive information such as identifying information for the
10 doctor who performed heart surgery on Plaintiff.
11 Additionally, in response to Special Interrogatory No. 21; 23; 26; 28; 29, Plaintiffs fails to
12 provide contact information for persons he identifies as having knowledge of various protected
o
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t- 3 g _ VD
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o u 2: ^ 14 Decl., Exhibit H.) Such incomplete responses interfere with Defendant's ability to prepare its
— > U ov
aS < o""^ 15 defense including identifying potenfial witnesses.
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O Moreover, Plaintiff improperly combines numerous, responses into a single response
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17 purportedly responsive to each. (See Defendant's Separate Statement and Bardzell Decl., Exhibit I,
18 Plainfiff s Response to Form Interrogatories 2012.1-2012.7.)
That information sought by the numerous aforementioned interrogatories is within
19
20 Plaintiffs control. As such, he was required to provide it and his responses are incomplete.
Plaintiff further provides no substantive response whatsoever to the following Form
21
22 Interrogatories - General, Set One: 6.7; 9.1; 12.1; 12.4; 13.1; 13.2; 50.2; 50.3; 50.4; and 50.5; Form
23 Interrogatories - Employment, Set One: 200.6; 202.1; 202.2; 203.1; 204.1; 204.2; 204.3; 204.4;
24 204.5; 207.2; 208.2; 210.6; 215.2; and Special Interrogatory No. 24.
25 C. Plaintiff Responded "I don't know" to Some Interrogatories Without Describing
26 Efforts to Provide a Response

27 In response to Form Interrogatories 12.5; 12.6 and 12.7: Plaintiff responded: " I don't
28 know." (See Defendant's Separate Statement and Bardzell Deck, Exhibit I.) He fails to describe
{01965098.DOCX} 7
1 what search he has done to provide a response. These responses are incomplete. Similarly, in
2 response to Form Interrogatory 206.3, Plaintiff simply responds "Waszczuk is not sure what 206.3
3 asking him for[.]"(See Defendant's Separate Statement and Bardzell Deck, Exhibit I.) That is also
4 non-responsive.
5 Code of Civil Procedure §2030.220 requires that parties produce all informafion
6 "reasonably available" to them in response to interrogatories. (CCP. §2030.220(a).) That
7 obligafion requires that parties take all reasonable steps to investigate and obtain information
8 responsive to the request. (CCP. §2030.220(c).) If parties do not have sufficient information to
9 respond after making a reasonable inquiry, they must state that fact in their response. (Id.)
10 Plaintiff should be able to respond to such interrogatories as to his personal knowledge. If
11 he does not know, he has an obligation to detail the efforts made to obtain that information. (Deyo
12 supra, 84 Cal.App.3d at 782-783.)
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Defendant's Separate Statement.
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W ^v S 5; 5;
S Si g -> X 16 case and to determine the validity of plaintiffs claims. Accordingly, Defendant respectfully request
DV. 17
O an Order compelling Plaintiff to provide further verified responses to Defendant's Special
18 Interrogatories (Set One), Form Interrogatories - General (Set One), and Form Interrogatories -
19 Employment (Set One) without objecfions.
20 IV.
21 DEFENDANT IS ENTITLED TO MONETARY SANCTIONS
22 Code ofCivil Procedure § 2023.030(a) provides, in relevant part, that:
23
The court may impose a monetary sanction ordering that one engaging in the misuse
24 of the discovery process, or any attomey advising that conduct, or both pay the
reasonable expenses, including attomey's fees, incurred by anyone as a result of that
25 conduct [. . .] If a monetary sanction is authorized by any provision of this tifie, the
26 court shall impose that sanction unless it finds that the one subject to the sancfion
acted with substanfial justification or that other circumstances make the imposition
27 of the sanction unjust.
28 CCP §§ 2030.290(c) provides that a court shall impose a monetary sanction on any party
{01965Q98.DOCX} 8
who unsuccessfially opposes a motion to compel responses to interrogatories.
Pursuant to CCP §§ 2030.290(c), Defendant is enfified to an award of sancfions against
Plaintiff as a result of his failure to provide appropriate responses to Defendant's interrogatories.
Califomia Rules of Court, Rule 3.1348 authorizes an award of sanctions even when "the requested
5 discovery was provided to the moving party after the motion was filed." (C.R.C, Rule 3.1348(a).)
6 Sanctions are also available when a party misuses the discovery process. (CCP.
7 §2023.030(a); "The '[f]ail[ure] to respond... to an authorized method of discovery' and '[mjaking
8 an evasive response to discovery' are defmed as '[mjisuses of the discovery process.'" (Saxena v.
9 Goffney (2008) 159 Cal.App.4th 316, 333.)
10 The California Court of Appeal has previously addressed the increasing misuse of the
11 discovery process similar to Plaintiffs behavior:
o
12 "We are . . . aware the discovery process is subject to frequent abuse and, like a
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oo o of the day-to-day practice of law lead us to conclude this cancer is spreading and
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t- g °^ ^ over the sledge hammer."
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17 (Calcor Space Facility, Inc. v. Superior Court (1997) 53 Cal.App.4th 216, 221 (quoting Mannino v.
18 Superior Court (1983) 142 Cal.App.3d 776.))
19 Awarding sanctions is particularly appropriate in this case as this is the second time
20 Plainfiff has forced Defendant to file a Motion to Compel. Defendant filed a Motion on October
21 17, 2018 after Plaintiff completely failed respond to Defendant's discovery requests for over four
22 and a half months. Plainfiff refused to provide those responses unfil Defendant finally filed its first
23 Mofion to Compel. (Bardzell Deck, TITI 11-12.)
24 Recognizing that this Court is reluctant to award monetary sancfions unless a party
25 unsuccessfully opposes a discovery motion, Plaintiff appears to have strategically elected not to
26 oppose Defendant's prior Motion. As a result, the only sanctions this Court imposed were those
27 required under CCP. § 2033.280 relafing to Plaintiffs failure to provide responses to the
28 Requests for Admission. (See Bardzell Deck, TI 9 and Exhibit G.) That sancfions award was in the
{01965098.DOCX} 9
amount of $520, which fell well short of fully reimbursing Defendant for all the fees it had to
needlessly incur in filing a Motion to Compel Plainfiffs other responses. Even then, Plainfiff
3 failed to pay the full amount the Court ordered. (See Bardzell Deck, TjlO.)
4 Although the Court denied Defendant's previous request for sancfions in connecfion with
5 the motion to compel responses to interrogatories and request for production, the Court further
6 indicated in its Order on Defendant's previous motion to compel that "repeated conduct of failing
7 to comply with discovery obligations may lead the Court to find an abuse of the discovery process
8 and award sancfions on that basis." (See Bardzell Deck, T119, Exhibit G.)
9 Now, here we are again. Plaintiff failed to adequately respond to discovery. Defendant
10 communicated with Plainfiff multiple fimes in hopes of resolving these issues short of filing a
11 Motion to Compel. Unfortunately, Plaintiff failed to provide any further response, thereby
12 successfully forcing Defendant to again incur fees in filing this Motion.
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13 This pattem is a clear abuse of the discovery process. Therefore, Defendant respectfully
3 0 0 — VD
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14 submits that sanctions are appropriate.
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a; < o" t Defendant has incurred $4,160 in fees associated with preparing the present motion. (See
W £^ c 5; o^
Bardzell Decl., TI 20.) Defense counsel anticipates incurring an additional $1,300 in fees in the
17 event Plaintiff opposes the Mofion and a hearing is necessary. (Bardzell Deck, TI 20.) As a result.
18 Defendant respectfully requests an award of sanctions in the amount of $5,460 for the fime and
19 expense incurred by Defendant in filing this otherwise unnecessary motion.
20 V.
21 TERMINATING SANCTIONS ARE ALSO APPROPRIATE
22 The Code of Civil Procedure provides that the Court may impose sanctions on any party
23 who engages in conduct that constitutes misuse of the discovery process. (CCP § 2023.030(a).)
24 Misuses of the discovery process includes "failing to respond or to submit to an authorized method
25 of discovery" and "disobeying a court order to provide discovery." (CCP §§ 2023.010(d), (g).)
26 When a party fails to respond to an authorized method of discovery and/or fails to obey a court
27 order to provide discovery, the Court may impose, among other relief, monetary sanctions and/or
28 terminating sancfions. (CCP § 2023.030(a), (d).)
{01965098.DOCX} 10
1 Coitrts have long held that terminating sanctions are appropriate where there is a willful
2 failure to comply with court orders, and should be issued where it appears that lesser sancfions
would not bring the offending party into compliance. (R.S. Creative, Inc. v. Creative Cotton, Ltd.
1
(1999) 75 Cal.App.4th 486, 496.) Terminating sanctions are especially appropriate where a party
5 fails to respond to discovery requests and ignores court orders. (See Kahn v. Kahn (1977) 68
6 Cal.App.3d 372, 383.)
7 Terminating sanctions are appropriate in this case. Defendant initially sought terminating
sanctions against Plaintiff in connection with its previous motion to compel discovery. The Court
denied this request, providing: The Court denies Defendant's alternate requests for issue,
10 evidentiary, and/or terminating sanctions at this fime. [. . .] Here, given that this is the first order
11
with respect to the subject discovery, the drastic remedy of terminafing sancfions would be
12
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punitive." (See Bardzell Deck, Exhibit G.)
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It is evident that Plaintiffs conduct is nothing more than a delaying tactic to prevent
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W i> c 5 o^ money, and Court resources to compel Plaintiff to lifigate this case would be categorically unjust.
S gI X 16 The aforementioned conduct has also prejudiced Defendant's ability to prepare for trial and will
= " 17 interfere with the Court's ability ascertain the tmth in this case. Given that previous discovery
18 mofion practice failed to compel Plaintiff to comply with his discovery obligations, terminafing
19 sanctions are now appropriate.
20 Accordingly, Defendant requests that the Court grant terminafing sancfions and issue an
21 Order dismissing the complaint against the remaining Defendant in its entirety, with prejudice.
22 VI.
23 CONCLUSION
25 however Plaintiff has failed to provide complete verified responses to Defendant's Special
27 Employment (Set One.) Defendant is left with no opfion other than to file the instant motion. As
28 such, Defendant seeks an Order (1) compelling Plainfiff to provide further verified responses,
{01965098.DOCX} 11
without objections, to Defendant's Special Interrogatories (Set One), Form Interrogatories - General
2 (Set One) and Form Interrogatories - Employment (Set One); (2) awarding sanctions in the amount
3 of $5,460 to retum Defendant to the position it would have been had complete responses been
4 timely provided; (3) issue terminafing sanctions against Plaintiff as a result of Plainfiffs repeated
5 failure to engage in the discovery process.
6
7
Dated February 11, 2019 PORTER SCOTT
10 By
David P. E. Burkett
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22
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25
26
27
28
{01965098.DOCX} 12
Waszczuk V. Regents of the University of California, et al.
1
2
PROOF OF SERVICE
3
address is 350 University Avenue, Suite 200, Sacramento, Califomia 95825.
5
6
7 DEFENDANT'S POINTS AND AUTHORITIES IN SUPPORT OF DEFENDANT'S
MOTION TO COMPEL VERIFIED RESPONSES TO REQUESTS FOR PRODUCTION
8 OF DOCUMENTS SET ONE, SPECIAL INTERROGATORIES SET ONE, FORM
INTERROGATORIES - GENERAL SET ONE, FORM INTERROGATORIES -
9
EMPLOYMENT SET ONE; TO DEEM REQUEST FOR ADMISSIONS ADMITTED; AND
10 FOR MONETARY AND TERMINATING SANCTIONS
11 BY MAIL: I placed the envelope for collection and mailing, following our ordinary business practices. I
o
o course of business with the United States Postal Service, in a sealed envelope with postage fiilly prepaid.
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13 BY PERSONAL SERVICE: I caused such document to be personally delivered to the person(s)
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addressed below. (1) For a party represented by an attomey, delivery was made to the attomey or at the
O o" ov f ^ 14 attomey's office by leaving the documents, in an envelope or package clearly labeled to identify the
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OV attomey being served, with a receptionist or an individual in charge of the office, between the hours of
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oi < d" vd vd 15 nine in the moming and five in the evening. (2) For a party, delivery was made to the party or by leaving
tu c ov ov
OJ the documents at the party's residence with some person not younger than 18 years of age between the
f-
ct J >< 16 hours of eight in the moming and six in the evening.
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BY OVERNIGHT DELIVERY: 1 enclosed the documents in an envelope or package provided by an

o 17 ovemight delivery carrier and addressed to the person(s) listed below. I placed the envelope or package
m for collection and ovemight delivery at my office or a regularly utilized drop box of the ovemight
19 I faxed the documents to the persons at the fax numbers listed below. No error was reported by the fax
by electronic transmission, I caused the documents to be sent to the persons at the electronic notification
2.1 address listed below.
22
Jaroslaw Waszczuk
23 2216 Katzakian Way
Lodi, CA 95242
24
26 foregoing is tme and correct. Executed at Sacramento, Califomia on Febmary 11, 2019.
27
28 Wendy E. Strasser
{01965098.DOCX} 13
EXHIBIT # 12
EXHIBIT # 13
EXHIBIT # 14
•----------i44o.).._%...€r,...
• i
PORTER I SCOTT EHOCRSED
2
David P. E. Burkett, SBN 241 896 201MM20 PM22
350 University Avenue, Suite 200 U P F P11 OnN COURT OF CMIPONiA
COUNtY OF 5ACRAME0U
TEL: 916.929.1481
5 FAX: 916.927.3706
dburkett(porterscott.com
6 dbardzeIlporterscott,com
7

10
11
13
Plaintiff, MEMORANDUM OF POINTS AND
V. DEFENDANTS', MOTION TO COMPEL
15
RESPONSES TO JUDGMENT DEBTOR
16 THE REGENTS OF THE UNIVERSITY OF INTERROGATORIES AND REQUEST
CALIFORNIA, UNIVERSITY OF FOR PRODUCTION OF DOCUMENTS;
17 CALIFORNIA DAVIS HEALTH SYSTEM, AND FOR MONETARY AND
UC DAVIS MEDICAL CENTER, UC TERMINATING SANCTIONS
18
DAVIS, ANN MADDEN RICE, MIKE
19 BOYD, STEPHEN CHILCO'IlT, CHARLES Date: April 26, 2019
WITCHER, DANESHA NIcHoLS, CINDY Time: 2:00 p.m.
20 OROPEZA, BRENT SEIFERT, PATRICK Dept.: 53
21
through 50, inclusive, Complaint Filed: December 4, 2013
23 /
24
25
26
27
28
0I978654.DOCX)
MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF DEFENDANTS' MOTION TO
COMPEL RESPONSES TO JUDGMENT DEBTOR INTERROGATORIES AND REQUEST FOR
PRODUCTION OF DOCUMENTS; AND FOR MONETARY AND TERMINATING SANCTIONS
TABLE OF CONTENTS
2 Page
3
4 INTRODUCTION ..........................................
5 II STATEMENT OF FACTS AND PROCEDURAL HISTORY ...........................................1

6
A. Plaintiff Failed to Provide Timely Responses to Defendant's Form and
7 Special Interrogatories, Request for Production of Documents, and
Request for Admissions and Ignored Defendant's Related Meet-and-
8 ConferEfforts ...........................................................................................................3
9
B. Motion to Compel ....................................................................................................4
10
C. Plaintiff Failed to Pay Monetary Sanctions ..............................................................4
II
12 D. Plaintiff Again Ignores Defendant's Meet-and-Confer Efforts ................................5
0
0
13 E Second Motion to Compel ........................................................................................5
In oco
14 F. Plaintiff Further Ignores the .anti-SLAPP Defendants' Meet-and-Confer
- > C.) o Efforts Related to the Judgment Debtor Requests for Production of
<6' 15
Documents (Set One) and Judgment Debtor Interrogatories (Set One) ...................5
E-X 16
o r .
III. PLAINTIFF SHOULD BE ORDERED TO PROVIDE RESPONSES TO
0 17
In JUDGEMENT DEBTOR REQUEST FOR PRODUCTION OF DOCUMENTS
18 (SET ONE) AND JUDGMENT DEBTOR INTERROGATORIES (SET ONE).................7
19 A. Judgment Debtor Interrogatories (Set One) .............................................................7

20
B. Judgment Debtor Requests for Production of Documents (Set One) .......................8
21
IV. MONETARY SANCTIONS SHOULD BE AWARDED ...................................................9
22
V. TERMINATING SANCTIONS ARE ALSO APPROPRIATE ........................................10
23
24 IV. CONCLUSION ..................................................................................................................11
25
26
27
28
(01978654.DOCX) 1
2
State Court Cases
3
Kahn v. Kahn
4
(1977) 68 Cal.App.3d 372, 383 10
5
R.S. Creative, Inc. v. Creative Cotton, Ltd.
6 (1999) 75 Cal.App.4th 486,496 ........................................................................................10
7
Sinaiko Healthcare Consulting, Inc. v. Pacific Healthcare Consultants
8 (2007) 148 Cal.App.4tl 390,411 ........................................................................................8
9 Statutes
10
C.C.P. § 708.020 ............................................................................................................................ 7
II.
C.C.P. § 708.030 ............................................................................................................................ 7
12
C
C
13 C.C.P. § 2016.070 .......................................................................................................................... 7
I-. •S —
H at C
Oci °'Z 14 C.C.P. § 2023.010(d) ...................................................................................................................... 9
cg
_>Oac
<d\á 6
ce 15 C.C.P. § 2023.010(g) ...................................................................................................................... 9
16
H C.C.P. § 2023.030(a) ................................................................................................................ 9, 10
0
tin
17
C.C.P. § 2030.010 ..........................................................................................................................
18
19 C.C.P. § 2030.210(a) ...................................................................................................................... 7
20 C.C.P. § 2030.290(a) ...................................................................................................................... 8

21
C.C.P. § 2030.290(b) ...................................................................................................................... 8
22
C.C.P. § 2030.290(c) ...................................................................................................................... 9
23
24 C.C.P.2031.010 .......................................................................................................................... 7
25 C.C.P. § 2031.300(a) ...................................................................................................................... 8

26 C.C.P. § 2031.300(b) ...................................................................................................................... 8
27
C.C.P. § 2031.300(c) ...................................................................................................................... 9
28
Rules of Court, Rule 3.1245(b) ...................................................................................................... 8
{01978654.DOCX) ii
Defendants BOYD, CHILCOTT, NICHOLS, OROPEZA, and SEIFERT ("anti-SLAPP
2 Defendants") respectfully submit the following memorandum of points and authorities in support
3 of their motion to: (1) compel Plaintiff JAROSLAW ("JERRY") WASZCZUK's verified
4 responses to Judgment Debtor Requests for Production of Documents (Set One) and Judgment
5 Debtor Interrogatories (Set One); (2) award monetary sanctions in the amount of $4,940 to return
6 Defendants to the position they would have been had the subject judgment debtor discovery
7 responses been timely provided; (3) issue terminating sanctions against Plaintiff as a result of
8 Plaintiff's pattern of failure to engage in the discovery process.
9 1.
10
Defendants served Plaintiff with Judgment Debtor Requests for Production of Documents
12 (Set One) and Judgment Debtor Interrogatories (Set One) on October 9, 2012. Responses were due
13 on or before November 13, 2018. Plaintiff has completely failed to provide any responses and
14 same are overdue.
15 Defendants respectfully request the Court issue an Order to (1) compel Plaintiff to provide
16 verified responses to Defendants' Judgment Debtor Requests for Production of Documents (Set
17 One) and Judgment Debtor Interrogatories (Set One); and (2) issue monetary sanctions against
18 Plaintiff in the amount of $4,940 for Defendants' fees and costs incurred in bringing this motion;
19 and (3) issue the sanction of termination of the present action as a result of Plaintiffs failure to
20 provide responses to the Defendants' judgment debtor discovery.
21 H.
24 summary: Plaintiff filed the operative Second Amended Complaint ("SAC") on September 30,
26 Defendants:' (1) intentional infliction of emotional distress ("lIED"); (2) tortious interference with
28 'The First and Second Causes of Action in the Second Amended Complaint do not specifically identify Defendant UNIVERSITY
(01978654.DOCX) i
1 retaliation in violation of Government Code § 12940(a); and (4) whistleblower/uniawful retaliation
2 in violation of Government Code §§ 8547 etseq,
3 Each of these causes of action arises out of Plaintiff's employment with Defendant
4 REGENTS OF THE UNIVERSITY OF CALIFORNIA ("UNIVERSITY") at the University of
5 California at Davis Medical Center. In addition to Defendant UNIVERSITY2, these causes of
6 action were pled against Defendants ANN MADDEN RICE, MIKE BOYD, STEPHEN

9 and disciplinary actions that ultimately resulted in Plaintiff's termination of employment with the
12 SEIFERT ("anti-SLAPP Defendants") filed a Special Motion to Strike Plaintiff's causes of action
0
0
13 as pled against them. (See Declaration of Daniel Bardzell in Support of Motion to Compel
.r,OC
14 ("Bardzell Decl."), ¶ 2.) The anti-SLAPP Defendants contended that Plaintiff's causes of action
<6' 15 against them arose from protected activities pursuant to Code of Civil Procedure' § 425.16;
16 namely, their participation in the processing, investigation, hearing and deciding of complaints
0 17 filed by Plaintiff and others pursuant to the policies and procedures of the Defendant
Cr'
IS UNIVERSITY. (See Id.)

19 On April 14, 2015, the Court issued an Order granting the Special Motion to Strike finding
20 that Plaintiff failed to establish a probability of prevailing on the causes of action pled against the
21 anti-SLAPP Defendants as required by section 425.16 and entering judgment in favor of the anti-
22 SLAPP Defendants. (See Bardzell Decl., ¶ 3 and Exhibit A.)
23 Plaintiff subsequently filed a request for dismissal with prejudice of the four remaining
24 individual Defendants RICE, WITCHER, PUTNEY, and DANILIUC. (See Bardzell Decl., ¶ 4 and
25 Exhibit B.) The UNIVERSITY is the only Defendant remaining in the case.
26
27
2
See Id., lii. I.
28 Unless otherwise indicated, all further statutory references in this Motion are to the California Code of Civil
Procedure,
{01978654DOCX) 2
1 On May 11, 2015, the anti-SLAPP Defendants filed a Motion for Fees and Costs pursuant
2 to CCP § 425.16, subdivision (c) and the Court's Order dated April 14, 2015 on Defendant's
3 Special Motion to Strike. (See Bardzell Decl., ¶ 5.) The motion sought recovery of approximately
4 $33,000 in fees and costs incurred by the anti-SLAPP Defendants in connection with the Special
5 Motion to Strike. (See Bardzell Decl., Exhibit C.)
6 On June 29, 2018, the Court entered an Order granting Defendants' Motion for Fees and
7 Costs in the amount of $22,284 against Plaintiff. (See Bardzell Decl., 16 and Exhibit C.)
8 A. Plaintiff Failed to Provide Timely Responses to Defendant's Form and Special
Interrogatories, Request for Production of Documents, and Request for Admissions
9 and Ignored Defendant's Related Meet-and-Confer Efforts
12 2018. (See Bardzell Decl., ¶ 7.) By correspondence dated May 22, 2018, Plaintiff requested an
13 extension of time to respond to all such requests on the basis that he was sick. (See Bardzell Decl.,
14 ¶ 8 and Exhibit D.) Defendant's counsel responded by email correspondence dated May 23, 2018
15 granting Plaintiff an extension of time to respond until June 20, 2018. (See Id.)
16 On September 24, 2018, counsel for Defendant UNIVERSITY served a meet and confer
17 correspondence upon Plaintiff regarding the outstanding discovery responses wherein defense
18 counsel indicated: "[P]lease provide complete responses to all such outstanding requests no later
19 than September 28, 2018. If we do not have your complete responses by that date, we will file a
20 motion to compel responses and request monetary as well as terminating sanctions from the
21 Court." (See Bardzell Decl., ¶ 9 and Exhibit B.)
22
By incoherent email correspondence also dated September 24, 2018, Plaintiff indicated:
23
Interrogatories. I appreciate but I not sure yet what I am going to. I am Waiting for answers
25 from the federal authorities in this matter.
I will let know. I mean time you can entertain yourself with my affirmative defense of
26 Judge Brett Kavanaugh. As Jeanine Pirro stated not so long ago,. UC Regent wife Senator
27 Feinstein's Unhinged Demon Rats attacking Judge Kavanaugh as I was attacked and
wasted by her husband and other unhinged UC demon rats. Same people only different is
28 that I have no I penny on my account and I am for my SS check on 28Th than I could buy
ink for my printer and do eventually interrogatories.
{01978654.DOCX
3
MEMORANDUM OF POINtS AM) AUFFIORIlIES IN SUFI'ORI OF DEFLINDANIS' MOTION 10
(See Bardzell Dee!., ¶ 10 and Exhibit F.)
I
2
2018. (See Bardzell Deci., ¶ 11.)
3
On October 1, 2018, Plaintiff submitted an email correspondence to Defendant stating: "I
4
am working on the Interrogatories and Other papers. Pleas give one more week to finish. Attached
5
is a part of interrogatories to show you that I am working on." (See Bardzell Dee!., ¶ 12 and
6
7 Exhibit F.) Included was a rambling apparent partial draft response to Defendant UNIVERSITY's
8 Special Interrogatories, Set One without a verification. (See Bardzell DecI., ¶ 12.)
9 B. Motion to Compel
10 On October 17, 2018, Defendant UNIVERSITY was forced to file a Motion to Compel and
11 needlessly incur the associated fees and costs. (See Bardzell DecI., ¶ 13.) On November 14, 2018,
12 the Court issued its tentative ruling, which later became the ruling of the Court pursuant to Local
13 Rule 1.06. (See Bardzell DecI., ¶ 14, and Exhibit H.) There, the Court ordered Plaintiff to provide
14 verified responses, without objections, to Defendant's form and special interrogatories (sets one)
15 and requests for production (set one) no later than December 12, 2018. (See id.) Additionally, the
16 Court ordered Plaintiff to pay Defendant UNIVERSITY mandatory monetary sanctions in the
18 (See id.)
19 Plaintiff did subsequently provide responses to the special and form interrogatories, but
20 they were largely deficient which necessitated the filing of a second motion to compel, as
21 described infra. (See Bardzell DecI., ¶ 15.)
22 C. Plaintiff Failed to Pay Monetary Sanctions
23 In addition to Plaintiff's willful disregard of his discovery obligations, Plaintiff also
24 violated the Court's previous Order by failing to fully pay Defendant UNIVERSITY monetary
25 sanctions. (See Bardzell DecI., 114-16.) As set forth above, in its prior Order, the Court directed
26 Plaintiff to pay monetary sanctions of $520 by December 14, 2018. (See Bardzell Deci., ¶ 14 and
27 Exhibit H.) Plaintiff failed to pay the required sanction by December 14, 2018 and, to-date,
28 Plaintiff has provided checks amounting to only a portion of the sanctions ordered by the Court.
(01978654.DOCX}
4
1 (See Bardzell Deci., 114; 16.) Defendant has not cashed such checks. (See Bardzell DecI., ¶ 16)
2 D. Plaintiff Again Ignores Defendant's Meet-and-Confer Efforts
4 counsel sent Plaintiffs counsel a meet and confer correspondence on January 15, 2019, advising
5 that Plaintiff's responses were deficient. (See Bardzell DecI., 117 and Exhibit I.)
6 Plaintiff responded on January 15, 2019 by a series of argumentative and disjointed emails
8 confer correspondence. (See Bardzell Deel., ¶ 18 and Exhibits J.)
9 Plaintiff subsequently requested, and was granted, additional time to respond to-the meet
10 and confer and the parties agreed to extend the time for Defendant to file a motion, if necessary,
11 through February 12, 2019. (See Bardzell Dee!., 119 and Exhibit K.)
12 By email dated January 25, 2019, Plaintiff further responded to Defendant's January 15,
14 stating that Defendant should "File the motion, and I, accordingly, will file the response to your
15 motion in court." (See Bardzell Dccl., ¶ 20 and Exhibit L.) Plaintiff has not provided amended
16 responses.
17 E. Second Motion to Compel
18 On February 11, 2019, Defendant UNIVERSITY was forced to file a second motion to
19 compel further verified responses to form and special interrogatories and for monetary, and
20 terminating sanctions. (See Bardzell DecI., ¶ 21.) On March 12, 2019, the Court issued its tentative
21 ruling, which later became the ruling of the Court pursuant to Local Rule 1.06. (See Bardzell
22 DecI., ¶ 21 and Exhibit M.) There, the Court ordered Plaintiff to provide further verified responses
23 to Defendant's form and special interrogatories (sets one) no later than April 3, 2019. (See id.)
24 Additionally, the Court denied Defendant's request for monetary sanctions as the motion was
25 unopposed and also denied Defendant's request for terminating sanctions. (See Ed.)
26 F. Plaintiff Further Ignores the anti-SLAPP Defendants' Meet-and-Confer Efforts
27
28 The anti-SLAPP Defendants served Plaintiff with Judgment Debtor Requests for
(01978654.DOCX)

1 Production of Documents (Set One) and Judgment Debtor Interrogatories (Set One) on October 9,
2 2018. (See Bardzell Dccl., ¶ 22 and Exhibit N.) Responses were due on or befoie November 13,
3 2018. (See Bardzell DecI., ¶ 22.) Plaintiff has completely failed to provide any responses and same
4 are overdue. (See id.)
5 On January 24, 2019, counsel for Defendants served a meet and confer correspondence
6 upon Plaintiff regarding the outstanding judgment debtor discovery responses wherein defense
7 counsel indicated: "This letter serves as Defendants [..j attempt to meet and confer regarding
8 Plaintiff's outstanding responses to Defendants' Judgment Debtor Request for Production of
9 Documents, Set One and Judgment Debtor Interrogatories, Set One which were served on you on
10 October 9, 2018. Plaintiff has provided no response whatsoever. Please provide complete
11 responses by January 31, 2019 or we will file a motion to compel and seek sanctions." (See
12 Bardzell Deci., 123 and Exhibit 0.)
0
0
N
13 By email correspondence dated January 25, 2019, Plaintiff asserted, he never received a
In 0
0 t; 14 copy of the judgment debtor discovery requests and further provided: "Please send me the
15 aforementioned documents that were supposed to have been sent in October. 1 will look them over
u
o. to and respond to you with 30 days, or you may file the motion to compel if you wish." (See Bardzell
0
In
17 DecI., 124 and Exhibit P.) By email correspondence also dated January 25, 2019, the office of
C.'
18 counsel for Defendants provided Plaintiff with a further courtesy copy of Defendants' Judgment
19 Debtor Request for Production of Documents, Set One and Judgment Debtor Interrogatories, Set
20 One which were previously served on Plaintiff on October 9, 2018. (See Id.)
21 Plaintiff responded by email also dated January 25, 2019, stating: "Never got this before.
22 Have a nice weekend Ms. Strasser. I feel sorry for you that you are working for guy like Burkett or
23 Bardzell. Tell them to file motion." (See Bardzell Dccl., ¶ 25 and Exhibit Q.)
24 On February 22, 2019, counsel for Defendant served, a further meet and confer
25 correspondence upon Plaintiff, providing: "This letter serves as Defendants II. J further attempt to
26 meet and confer regarding Plaintiffs outstanding responses to Defendants' [judgment debtor'
27 discovery requests]. Plaintiff has provided no response whatsoever and responses are more than
28 three months overdue. Our previous attempts to meet and confer on this issue have been
101978654D0CX) 6
1 unsuccessful. If we do not receive complete responses by March 1, 2019, our next action will be to
2 file a motion to compel and seek sanctions." (See Bardzell Deci., 126 and Exhibit R.)
3 By email correspondence dated March 1, 2019, Plaintiff provided, in part: "I am not going
4 to quit my lawsuits voluntarily either regardless of what judges and justices from three different
5
California courts have done to me in the last four years. I did not provide the response by January
6 31, 2019 because the DEBTOR INTERROGATORIES - SET ONE TO PLAINTIFF [. . . and]
7
DEFENDANTS' REQUEST FOR PRODUCTION OF DOCUMENTS - SET ONE TO
8 PLAINTIFF [ ... ] were not sent to me on October 9, 2018 and I do not have any record of it[. . .
9
Porter Scott attorneys did not file a Motion to Compel as promised by the January 31, 2019 letter
10 nor did they formally resend the Interrogatories and Production for Documents to me with the new
11
date[. . .] If the Porter Scott attorneys want to file another Motion to Compel [. . .] I have no
12
control over it. I will not be surprised if the Motion is granted." (See Bardzell Deel., ¶ 27 and
13 Exhibit S.) Plaintiff further asserted that he provided some documents at the Judgment Debtor
14 examination in this matter. (See Id.)
15 III.
16 PLAINTIFF SHOULD BE ORDERED TO PROVIDE RESPONSES TO
JUDGMENT DEBTOR REQUEST FOR PRODUCTION OF DOCUMENTS (SET ONE)
17 AND JUDGMENT DEBTOR INTERROGATORIES (SET ONE)
18 A judgment creditor is allowed to use the following procedures provided for in the
19 Discovery Act to obtain discovery to assist in enforcing a judgment: (1) service of written
20 interrogatories to the judgment debtor under C.C.P. § 2030.010, et seq., and (2) service of a
21 document inspection demand to the judgment debtor under C.C.P. § 2031.010, et seq. (See C.C.P.
22 §§ 2016.070; 708.020; 708.030.)
23 A. Judgment Debtor Interrogatories (Set One)
26 being sought to be discovered, an exercise of the party's option to produce writings, or an
27 objection to the particular interrogatory. (C.C.P. § 2030.210(a).) If a party to whom interrogatories
28 are directed fails to serve a timely response, the party propounding the interrogatories may move
{01978654.DOCX)
7
EMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF DEFENDANTS' MOTION TO
for an order compelling response to the interrogatories. (C.C.P. § 2030.290(b).) The party also
2 waives objections to the interrogatories (including those based on privilege and work product) by
3 failing to respond by the deadline. (C.C.P. § 2030.290(a).)
4 Unlike a motion to compel further responses, a motion to compel responses is not subject
5 to a 45-day time limit, and the propounding party does not have to demonstrate either good cause
6 or that it satisfied a meet-and-confer requirement. (Sinaiko Healthcare Consulting, Inc. v, Pacific
7 Healthcare Consultants (2007) 148 Cal. App. 4th 390, 411.) A separate statement is not required
9 In our case, Defendants have not received Plaintiffs verified responses to Judgment Debtor
10 Interrogatories (Set One). (See Bardzell DecI., ¶ 28.) These interrogatories were properly served on
11 Plaintiff on October 9, 2018. (See Bardzell Deci., ¶ 22 and Exhibit N.) Responses were due on or
12 before November 13, 2018. (See id.)
13 Defendants require these discovery responses in order to enforce their judgment.
14 Accordingly, Defendants respectfully request an Order compelling Plaintiff to provide verified
15 responses to Defendants' Judgment Debtor Interrogatories (Set One) without objections.
16 B. Judgment Debtor Requests for Production of Documents (Set One)
17 If a party to whom a demand for inspection is directed fails to serve a timely response, the
18 party propounding the demand may move for an order compelling responses to the demand.
19 (C.C.P. § 2031.300(b).) In addition, a party who fails to respond waives any objections he
20 otherwise could have raised to the demand. (C.C.P. § 2031.300(a).)
21 Defendants served Plaintiff with Judgment Debtor Requests for Production of Documents
22 (Set One) and Judgment Debtor Interrogatories (Set One) on October 9, 2018. (See Bardzell Decl.,
23 ¶ 22 and Exhibit N.) Responses were due on or before November 13, 2018. (See id.) Plaintiff's
25 Therefore, Defendants respectfully request an Order compelling Plaintiff to provide
26 responses to Defendants' Judgment Debtor Request for Production of Documents (Set One),
27 without objections.
28 I/I
101978654.DOCX) 8
MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF DEFENDANTS' MOTION 1
Iv.
2 MONETARY SANCTIONS SHOULD BE AWARDED
3 Code of Civil Procedure § 2023.030(a) provides, in relevant part, that:
4
The court may impose a monetary sanction ordering that one engaging in the
5 misuse of the discovery process, or any attorney advising that conduct, or both pay
the reasonable expenses, including attorney's fees, incurred by anyone as a result of
6 that conduct [ ... ] If a monetary sanction is authorized by any provision of this
7 title, the court shall impose that sanction unless it finds that the one subject to the
sanction acted with substantial justification or that other circumstances make the
8 imposition of the sanction unjust.
9 C.C.P. §§ 2030.290(c) and 2031.300(c) provide that a court shall impose a monetary
10 sanction on any party who unsuccessfully opposes a motion to compel responses to interrogatories
11 or request for production of documents.
12 Defendants have extended Plaintiff every opportunity to avoid court intervention in this
13 matter by conducting extensive meet and confer efforts. Plaintiff has completely ignored
14 I Defendants' judgment debtor discovery requests.

15 Plaintiffs attempt to evade his obligation to provide responses to judgment debtor
16 discovery has made the current motion necessary, despite being afforded opportunities to avoid the
17 need for same.
18 To date, Defendants have incurred $3,640 in fees as a result of Plaintiff's failure to respond
19 to Judgment Debtor Requests for Production of Documents (Set One) and Judgment Debtor
20 Interrogatories (Set One). (See Bardzell DecI., ¶ 29.) Defendants anticipate incurring an additional
nI $1,300 to review Plaintiffs Opposition, prepare a reply and attend a hearing. (See Id.) Therefore,
22 sanctions are proper. Moreover, even if Plaintiff serves responses upon notice of this motion in
23 order to avoid a court order, Defendants have nevertheless been forced to incur the expense of
24 moving to compel Plaintiffs compliance with his discovery obligations, despite efforts to achieve
25 a cooperative result. As such, sanctions in the amount of $4,940 are appropriately awarded against
26 Plaintiff for the time and expense incurred by Defendants in filing this motion.
1
I-
I/I
28 I/I
0I978654.DOCX}
9
1 V
4 who engages in conduct that constitutes misuse of the discovery process. (C.C.P. § 2023.030(a).)
6 of discovery" and "disobeying a court order to provide discovery." (C.C.P. §§ 2023.010(d), (g).)
8 order to provide discovery, the Court may impose monetary sanctions, terminating sanctions, or
9 both. (CCP § 2023.030(a), (d), (g).)
10 Courts have long held that terminating sanctions are appropriate where there is a willful
11 failure to comply with court orders, and should be issued where it appears that lesser sanctions
12 would not bring the offending party into compliance. (R.S. Creative, Inc. v. Creative Cotton, Ltd
13 (1999) 75 Cal.App.4th 486, 496.) Terminating sanctions are especially appropriate where a party
15 Cal.App.3d 372, 383.)
16 Terminating sanctions are appropriate in this case. Plaintiff has failed to provide any
17 verified responses to the Defendants' written judgment debtor. discovery despite extensive meet
18 and confer efforts by Defendants. Moreover, the Court has previously granted two motions to
19 compel discovery filed by Defendant UNIVERSITY in this case. (See Bardzell Decl., 114, 21 and
20 Exhibits i-i, M.) Plaintiff has plainly not been dissuaded from his pattern of failing to engage in the
21 discovery process.
22 It is evident that Plaintiffs conduct is nothing more than a delaying tactic to prevent the
23 Defendants from engaging in judgment debtor discovery. Requiring Defendants to continue
24 wasting time, money, and Court resources to compel Plaintiff to fulfill his obligations to
25 participate in the case, including judgment enforcement process, would be categorically unjust.
26 Plaintiffs demonstrated pattern of failing to provide discovery responses has prejudiced
27 Defendants' ability to prepare for trial, as well as enforce its judgment and will interfere with the
28 Court's ability to ascertain the truth in this case. It has thus become apparent that no action will
I 978654D0CX) 10
PRODUCTION OF DOCUMENTS; AND FORMONETARY AND TERMINATING SANCTIONS
compel Plaintiff to comply with his discovery obligations, making terminating sanctions
2 appropriate.
3 Accordingly, Defendant requests that the Court grant terminating sanctions and issue an
5 VI.
6 CONCLUSION
7 Defendants have made every effort to allow for the cooperative exchange of information,
8 however Plaintiff has failed to provide verified responses to Defendants' Judgment Debtor
9 Requests for Production of Documents (Set One) and Judgment Debtor Interrogatories (Set One).
10 Defendants are left with no option other than to file the instant motion. As such, Defendants seek
11 an Order (1) compelling Plaintiff to provide verified responses, without objections, to the anti-
12 SLAPP Defendants' Judgment Debtor Requests for Production of Documents (Set One) and
0
0
13 Judgment Debtor Interrogatories (Set One); (2) awarding sanctions in the amount of $4,940 to
H
H Ct 'fl
— O
14 return Defendants to the position they would have been had respobses been timely provided; (3)
<s'a 15 issue terminating sanctions against Plaintiff as a result of Plaintiffs continuing pattern of failure to
16 engage in the discovery process.
H
0 17
In
C,
Dated March 19, 2019 PORTER SCOTT
18 A PROFESSIONAL CORPORATION I I
19
20 By MJO4b/t(2(
David P. E. Burkett
22 Attorneys for Defendant
23
24
25
26
27
28
{01978654D0CX} 11
Waszczuk v. Regents of the University of California, et at.
I
2
PROOF OF SERVICE
3
4 At the time of service, I was over 18 years of age and not a party to this action. My
business address is 350 University Avenue, Suite 200, Sacramento, California 95825.
5
6
MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF DEFENDANTS'
7 MOTION TO COMPEL RESPONSES TO JUDGMENT DEBTOR INTERROGATORIES
AND REQUEST FOR PRODUCTION OF DOCUMENTS; AND FOR MONETARY AND
8 TERMINATING SANCTIONS
BY MAIL: I placed the envelope for collection and mailing, following our ordinary business
9 practices. I am readily familiar with this business' practice for collecting and processing
correspondence for mailing. On the same day that correspondence is placed for collection and mailing,
10
it is deposited in the ordinary course of business with the United States Postal Service, in a sealed
envelope with postage hilly prepaid.
11
addressed below. (I) For a party represented by an attorney, delivery was made to the attorney or at
12
C the attorney's office by leaving the documents, in an envelope or package clearly labeled to identify
0
13 the attorney being served, with a receptionist or an individual in charge of the office, between the hours
—'0 of nine in the morning and five in the evening. (2) For a party, delivery was made to the party or by
-'Cl) In coo
Os °'2 14 leaving the documents at the party's residence with some person not younger than 18 years of age
between the hours of eight in the morning and six in the evening.
-<cc'
U a. o
0' overnight delivery carrier and addressed to the person(s) listed below. I placed the envelope or package
16 for collection and overnight delivery at my office or a regularly utilized drop box of the overnight
delivery carrier. -
Cn BY FAX TRANSMISSION: Based on an agreement of the parties to accept service by fax
0 17
In transmission, I faxed the documents to the persons at the fax numbers listed below. No error was
18 reported by the fax machine that I used. A copy of the record of the fax transmission, which I printed
out, is attached
19 BY ELECTRONIC SERVICE: Based on a court order or an agreement of the parties to accept
service by electronic transmission, I caused the documents to be sent to the persons at the electronic
20 notification address listed below.

Lodi, CA 95242
23
24
I declare under, penalty of perjury under the laws of the State of California that the
25
foregoing is true and correct. Executed at Sacramento, California on March 20, 2019.
26
27
tsser
28
{01978654.DOCX)
12
EXHIBIT # 16
MINUTE ORDER
DATE: 04/26/2019 TIME: 02:00:00 PM DEPT: 53
JUDICIAL OFFICER PRESIDING: Steven H Rodda
CLERK: E. Brown
REPORTER/ERM: V. Green CSR# 10529
BAILIFF/COURT ATTENDANT: Navi, A., R. Mays

APPEARANCES
Daniel Bardzell, counsel present for defendant
Nature of Proceeding: Motion to Compel Production of Documents
TENTATIVE RULING
Judgment Creditors Boyd, Chilcott, Nichols, Oropeza and Seifert's, ("Judgment Creditors") Motion to
Compel Responses to Judgment Debtor's Interrogatories and Judgment Debtor's Requests for
Production of Documents, for payment of Monetary Sanctions, and for Terminating Sanctions is ruled on
as follows:
On April 14, 2015, the Court granted Judgment Creditor's Special Motion to Strike plaintiff's causes of
action. The Court subsequently granted their Motion for Attorneys fees in the amount of $22,284. (Ex. C
to the Declaration of Daniel J. Bardzell)
Judgment Creditors served the instant post-judgment discovery (Ex. N) on October 9, 2018. Judgment
debtor/plaintiff failed to provide any responses to the discovery. Judgment Creditors sent a second copy
of the discovery to judgment debtor on January 25, 2019, after he contended that he never received the
first set served in October. No responses were served prior to filing this motion on March 20, 2019.
Judgment Debtor has filed an opposition contending that he has now served responses to the discovery,
attached as Exhibits 1 and 2. The points and authorities in opposition to the motion do not address the
relevant issues in this motion but consists almost entirely of matters irrelevant to the discovery at issue.
Judgment debtor opposes this "unwarranted motion to compel."
Judgment creditor's Reply contends that the discovery responses were not code compliant because
they contained objections and plaintiff has waived objections by not timely responding. The Court is not
reviewing the adequacy of the responses attached to the Opposition. However, moving parties are
entitled to a court order compelling code compliant responses to the discovery. Sinaiko Healthcare
Consulting, Inc. v Pacific Healthcare Consultants (2007) 148 Cal.App.4th 390, 404.
Judgment Debtor is ordered to serve further verified responses to the Judgment Debtor

Interrogatories and Judgment Debtor Requests for Production, as set forth in the separate statement,
without objections, on or before May 8, 2019.
Judgment debtor is also ordered to pay reasonable monetary sanctions to moving parties in the
amount of $780 (3 hrs at the hourly rate of $260), plus the $60 filing fee, for a total fee award of
$840. This opposition was filed without substantial justification and therefore, moving parties
are entitled to monetary sanctions. The monetary sanctions must be paid on or before May 27,
2019. If those sanctions are not paid by that date, moving parties may prepare a formal order on
the two sanctions awards which may thereafter be entered as a separate judgment. See
Newland v Superior Court (1995) 40 Cal.App.4th 608.
The motion for terminating sanctions is denied. The post judgment discovery at issue here was served
by judgment creditors, not Regents. Moving parties have already obtained a judgment of dismissal in
this case as well as an attorney fees award on the anti-SLAPP motion. Thus, it is unclear why they are
seeking a "terminating sanction" in this context.
Regents are not a party to the underlying discovery or this motion, and therefore the Court will not grant
a terminating sanctions as to Regents. To the extent plaintiff has not paid monetary sanctions to be paid
to Regents pursuant to prior court orders, Regents may prepare a formal order on that sanctions award
from the November 14, 2018 court order and then may enforce that award as a separate judgment
under Newland v Superior Court (1995) 40 Cal.App.4th 608.
As stated above, Plaintiff is ordered to serve verified responses to the Judgment Debtor Interrogatories
and Judgment Debtor Requests for Production, without objections, on or before May 8, 2019. Monetary
sanctions are to be paid as specified above.
notice is required.
COURT RULING
After hearing oral argument the Court affirmed its tentative ruling with the following modification:
The order for monetary sanctions was vacated.

EXHIBIT # 17
1
1 IN THE SACRAMENTO SUPERIOR COURT

2 COUNTY OF SACRAMENTO, STATE OF CALIFORNIA
3 HON. STEVEN H. RODDA, DEPARTMENT 53
4 ---oOo---
5
)
6 JAROSLAW WASZCZUK, )
)
7 Plaintiff, )
) Case No.
8 VS. ) 2013-00155479
)
9 THE REGENTS OF THE UNIVERSITY OF )
CALIFORNIA, )
10 )
Defendant. )
11 _____________________________________
12
---oOo---
13
14 REPORTER'S TRANSCRIPT OF PROCEEDINGS
15
16 APRIL 26, 2019
17 ---oOo---
18
19
20 APPEARANCES:
21 For the Plaintiff:
22 JAROSLAW WASZCZUK, In Pro Per
23
For the Defendant THE REGENTS OF THE UNIVERSITY OF
24 CALIFORNIA:
25 PORTER SCOTT
BY: DANIEL BARDZELL, Attorney at Law
26 Sacramento, California
27
28 Reported by: VERONICA A. GREEN, CSR No. 10529
SACRAMENTO OFFICIAL COURT REPORTERS 1

2
1 FRIDAY, APRIL 26, 2019

2 AFTERNOON SESSION
3 ---o0o---
4 The matter of JAROSLAW WASZCZUK versus THE
5 REGENTS OF THE UNIVERSITY OF CALIFORNIA, Defendant, case
6 number 2013-00155479, came on regularly this day before
7 the Honorable STEVEN H. RODDA, Judge of the Superior
8 Court of California, for the County of Sacramento,
9 Department 53.
10 The Plaintiff was represented by JAROSLAW
11 WASZCZUK, in pro per.
12 The Defendant, THE REGENTS OF THE UNIVERSITY OF
13 CALIFORNIA, was represented by DANIEL BARDZELL, Attorney
14 at Law.
15 The following proceedings were had:
16 ---o0o---
17 THE COURT: Waszczuk versus The Regents. Good
18 afternoon.
19 You are Mr. Waszczuk?
20 MR. WASZCZUK: Waszczuk, Jerry.
21 THE COURT: I will do my best. Sorry.
22 And your appearance, counsel?
23 MR. BARDZELL: Good afternoon, your Honor. Dan
24 Bardzell from Porter Scott representing Judgment
25 Creditors Boyd, Chilcott, Nichols, Oropeza and Seifert.
26 THE COURT: I have read what you submitted.
27 Anything in addition to what you submitted?
28 MR. WASZCZUK: I came late for court. I would

3
1 ask the Court to vacate the order and continue the

2 hearing with Judge Brown. This case is very complex.
3 It's six years old almost, and this is what I'm asking
4 for, the judge nullification, I believe.
5 THE COURT: That's right.
6 MR. WASZCZUK: And he knows the case.
7 THE COURT: I read the file.
8 MR. WASZCZUK: If we could argue about this
9 would be the best.
10 THE COURT: You are going to have to live with
11 me unless you disqualify me.
12 MR. WASZCZUK: I don't want to disqualify
13 anybody.
14 THE COURT: I'm going to hear this. This is my
15 responsibility here. I think this is pretty
16 straightforward in terms of the analysis. I know it has
17 quite a history. I'm familiar with that.
18 Your thoughts? Go ahead, tell me.
19 MR. WASZCZUK: Your Honor, I raised this issue
20 of a continuance with Judge Brown because he says second
21 time -- the second time defendant attempted to terminate
22 my lawsuit with Motion to Compel with different judge.
23 This is the reason.
24 The first time Mr. Bardzell went to -- on
25 October 3rd went to Judge Krueger and attempted to
26 terminate and got caught filing in their own department
27 the motion, then created -- I couldn't even go for a
28 hearing even.

4
1 THE COURT: Well, the puzzling part of that for

2 me is --
3 MR. WASZCZUK: It is important, your Honor.
4 THE COURT: The question is whether or not you
5 responded to the discovery requests.
6 MR. WASZCZUK: Your Honor, the discovery was
7 resolved in Department 43 on February 8th.
8 THE COURT: There was a debtor's examination,
9 right?
10 MR. WASZCZUK: Everything -- the counsel brought
11 production for documents and brought interrogatories,
12 and I answered them question by question and gave him
13 documents, everything. And everything is documented in
14 my two exhibits.
15 THE COURT: Have you filed written responses
16 besides the ones filed after this hearing?
17 MR. WASZCZUK: This is the whole point. This
18 was the conversation between me and counsel on meet and
19 confer letters. And Exhibits 3 and 4, everything is
20 there. And counsel had chance to go to a judge and
21 complain if I didn't give him anything.
22 THE COURT: That was a separate proceeding.
23 MR. WASZCZUK: He got everything. I have
24 nothing more to give him. Your Honor, I don't have
25 anything more to give him. This is the point.
26 THE COURT: Let me hear from Mr. Bardzell now.
27 MR. BARDZELL: Your Honor, we agree with the
28 Court that the debtor examination that plaintiff brought

5
1 up is a separate proceeding.
2 As we stated in our motion papers with respect
3 to this motion, we are entitled to receive timely
4 verified responses to the written debtor discovery.
5 Plaintiff failed to provide that discovery by the
6 deadline. We met and conferred. He did not serve
7 responses at the time we filed the motion. He did file
8 late responses, noncompliant, after we filed the motion.
9 And so we stand by our request.
10 THE COURT: At the debtor's examination, did you
11 ask him all of the same questions set forth in the
12 discovery requests?
13 MR. BARDZELL: We covered significant ground
14 related to the documented categories that were also
15 requested in the written discovery.
16 THE COURT: So wouldn't that just duplicate what
17 you requested in the discovery requests?
18 MR. BARDZELL: Well, at the debtor's examination
19 a number of questions were asked about his wife's
20 assets, and in that respect he was unwilling to provide
21 that information. We also served the written discovery,
22 which he did not timely respond to.
23 Additionally, at the debtor's examination there
24 was no court reporter. There was a lack of under oath
25 testimony. It was an informal proceeding.
26 THE COURT: Well, the debtor is a formal
27 proceeding, right? That's my experience.
28 MR. BARDZELL: I don't recall. I was under the

6
1 impression it was under oath. There's lack of a written

2 record of that. We still believe we are entitled to the
3 responses -- verified responses to the written
4 discovery.
5 THE COURT: Okay.
6 MR. WASZCZUK: Your Honor?
7 THE COURT: Yes.
8 MR. WASZCZUK: Your Honor, I clearly wrote and I
9 told counsel at the meeting on February 8th that I don't
10 have access to my wife's financial bank or 401 or wages
11 or anything. We keep this separate for 30 years. She
12 is in different bank. She got no even debit card. They
13 are asking me about my wife all the time. Not only they
14 were trying to provoke me before in the court, attacking
15 my wife in the court and attacking me in this court.
16 I am not going to sue my wife to give them
17 information. I gave them phone number. She is 68.
18 She's still working in Nordstrom to maintain our life.
19 The Regents, they owe me for contract
20 $1 million. The Regents contract with me, your Honor,
21 and they are talking about 22,000. And I gave them
22 Nordstrom phone number, her job. I gave them
23 everything, where she bank. If they want to go after
24 her, go for it. This is written here, your Honor.
25 THE COURT: Anything further on this? Anything
26 further you want to say?
27 MR. WASZCZUK: Because I don't have anything
28 more to give them, you know.

7
1 MR. BARDZELL: Your Honor, I just want to

2 reiterate that he did not provide written responses per
3 the deadline under the code. We believe we are entitled
4 to written responses to discovery.
5 THE COURT: Is the matter submitted for
6 decision?
7 MR. BARDZELL: Yes, your Honor.
8 THE COURT: Anything else you want to say before
9 I make a decision?
10 MR. WASZCZUK: Your Honor, I wanted to say
11 that -- I wanted to ask the Court -- I am on Social
12 Security. Those sanctions are unwarranted, your Honor.
13 I have nothing to give them anymore. And I am asking
14 the Court not to respond to them anymore for this.
15 THE COURT: Anything else?
16 MR. WASZCZUK: That is it, your Honor.
17 THE COURT: I'm going to confirm the tentative
18 ruling in this respect. You are going to be ordered --
19 you are ordered to consistently, pursuant to the
20 tentative order that I'm adopting, to provide the
21 responses. I'm going to vacate the sanctions under
22 these circumstances. The ordered sanctions as part of
23 the tentative ruling is vacated for monetary sanctions.
24 Otherwise, the tentative ruling is approved and
25 adopted in this respect. If it comes back again, Judge
26 Brown may impose the sanctions. That's up to him.
27 Thank you.
28 MR. WASZCZUK: No sanctions, your Honor?

8
1 THE COURT: Not this time.

2 MR. WASZCZUK: Okay. Thank you very much.
3 I ask your Honor, I don't have anymore -- I
4 don't need to respond anymore for them?
5 THE COURT: The order is you respond. That's
6 the order.
7 MR. WASZCZUK: What do I have to give him?
8 THE COURT: You will have to figure that out
9 yourself.
10 (Proceedings concluded.)
11 ---oOo---
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

9
1 Certificate of Certified Shorthand Reporter

2 STATE OF CALIFORNIA )
) ss.
3 COUNTY OF SACRAMENTO )
4 I, VERONICA A. GREEN, hereby certify that I am
5 an Official Certified Shorthand Reporter, and that at
6 the times and places shown, I recorded verbatim in
7 shorthand writing all of the proceedings in the
8 following described action completely and correctly, to
9 the best of my ability:
10 Court: SUPERIOR COURT OF CALIFORNIA,
11 DEPARTMENT 53
HON. STEVEN H. RODDA
12
Case: JAROSLAW WASZCZUK
13 VS.
THE REGENTS OF THE UNIVERSITY OF
14 CALIFORNIA Defendant
Case No:
15 2013-00155479
16 Date(s): APRIL 26, 2019
17
18 I further certify that my said shorthand notes
19 have been transcribed into typewriting, and that the
20 foregoing PAGES 1 to 9, inclusive, constitute an
21 accurate and complete transcript of all of my shorthand
22 writing for the dates and matter specified.
23 I further certify that I have complied with CCP
24 237(a)(2) in that all personal juror identifying
25 information have been redacted, if applicable.
26 Dated: May 31, 2019
27
______________________________________
28 VERONICA A. GREEN, CSR No. 10529

EXHIBIT # 18
TEL: 916.929.1481
5 FAX: 916.927.3706
dburkett@porterscott.com
6
dbardzelKolporterscott.com
7
8
9
Exempt From Filing Fees Pursuant to Government Code §6103
10
11
12
o JAROSLAW ("JERRY") WASZCZUK, CASE NO. 34-2013-00155479
o
B in
13
•3 a - ^14 Plaintiff, MEMORANDUM OF POINTS AND
o
u c/^c i<n a<
00 o AUTHORITIES IN SUPPORT OF
O ON Ov
15 V. DEFENDANTS' FURTHER MOTION TO
< _ COMPEL RESPONSES TO JUDGMENT
kQ
Oi.
•— IU . .
16 THE REGENTS OF THE UNIVERSITY OF DEBTOR INTERROGATORIES AND
O CALIFORNIA, UNIVERSITY OF REQUEST FOR PRODUCTION OF
(X
17 CALIFORNIA DAVIS HEALTH SYSTEM, DOCUMENTS; AND FOR MONETARY
AND TERMINATING SANCTIONS
19 BOYD, STEPHEN CHILCOTT, CHARLES Date: July 19, 2019
WITCHER, DANESHA NICHOLS, CINDY Time: 2:00 p.m.
21 PUTNEY, DORIN DANILIUC, and Does 1
through 50, inclusive. Complaint Filed: December 4, 2013
23
24
25
26
27
28
(02023105.DOCX} 1
MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF DEFENDANTS' FURTHER
MOTION TO COMPEL RESPONSES TO JUDGMENT DEBTOR INTERROGATORIES AND REQUEST
FOR PRODUCTION OF DOCUMENTS; AND FOR MONETARY AND TERMINATING SANCTIONS
1 TABLE OF CONTENTS
2 Page
3
4 I. INTRODUCTION
5 II. STATEMENT OF FACTS AND PROCEDURAL HISTORY .1
6
A. Plaintiff Failed to Provide Timely Responses to Defendant University's
7 Form and Special Interrogatories, Request for Production of Documents
and Request for Admissions Necessitating Two Motions to.Compel
8 Regarding Such Requests 3
9
B. Plaintiff Ignores the anti-SLAPP Defendants' Meet-and-Confer Efforts
10 Related to the Judgment Debtor Requests for Production of Documents
(Set One) and Judgment Debtor Interrogatories (Set One) 4
11
12 C. Anti-SLAPP Defendants File a Motion to Compel Responses Judgment
o
o Debtor Requests for Production of Documents (Set One) and Judgment
(N
13 Debtor Interrogatories (Set One) and for Terminating Sanctions 5
3
o 2: 14 D. Plaintiff Ignores the anti-SLAPP Defendants' Subsequent Meet-and-

on g < JT;
— > ri
oi. < 15 Confer Efforts Related to the Judgment Debtor Requests for Production .
C ON OS
u .. of Documents (Set One) and Judgment Debtor Interrogatories (Set One) 6
?^
o> " ^ 16,
cu 5 III. PLAINTIFF SHOULD BE ORDERED TO PROVIDE RESPONSES TO
17 JUDGMENT DEBTOR REQUESTS FOR PRODUCTION OF DOCUMENTS
18 (SET ONE) AND JUDGMENT DEBTOR INTERROGATORIES (SET ONE) 7
19 A. Judgment Debtor Interrogatories (Set One) 8

20 B. Judgment Debtor Request for Production of Documents (Set One) 9
21
IV. MONETARY SANCTIONS SHOULD BE AWARDED 10
22
23
v: TERMINATING SANCTIONS ARE ALSO APPROPRIATE ; 11
24 VI. CONCLUSION : ; 13
25
26
27
28
{02023105.DOCX) 11
1 TABLE OF AUTHORITIES
2 Page
State Court Cases
3
4 Sinaiko Healthcare Consulting, Inc. v. Pacific Healthcare Consultants
(2007) 148 Cal.App.4"^ 390, 411 8, 9
5
6 Kahn v. Kahn
(1977) 68 Cal.App.3d 372, 383 11
7
Kaiser Steel Corp. v. Westinghouse Elec. Corp.
8 55 Cal.App.3d 77, 744 8
9
10 (1999) 75 Cal.App.3d 372, 383 11
11 Zorro Inv. Co. v. Great Pacific Securities Corp.
12 (1977) 69 Cal.App.3d 907, 914 8, 10
o
o
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t— .
32 00 —
»o00 NO
h- cn
o
1^ 14 Statutes
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o^ f-^
oi < 6 Os Ov 15 Code of Civil Procedure § 425.16 2
\D NO
ON ON
^ " i-J >< 16 Code of Civil Procedure § 425.16(c) 3
a< c iaUJ <
:D cn
17
o Code of Civil Procedure § 2023.010(d) ..11
• in
m
18
Code of Civil Procedure § 2023.010(g) ; 11
19
20 Code of Civil Procedure § 2023.030(a) .......11
21 Code of Civil Procedure § 2023.030(d) 11

22 Code of Civil Procedure § 2023.030(g) 11
23
Code of Civil Procedure § 2030.010 7
24
Code of Civil Procedure § 2030.210(a) 8
25
26 Code of Civil Procedure § 2030.290(a) 8
27 Code of Civil Procedure § 2030.290(b) , 8

28 Code of Civil Procedure § 2030.290(c) ;.10
{02023105.DOCX) iii
1
Code of Civil Procedure §§ 2016.070; 708.020; 708.030 7
2
3
Code of Civil Procedure § 2031.250(1) 9
4
5 Code of Civil Procedure § 2031.300(a) 8, 9
6 Code of Civil Procedure § 2031.300(b) , , 9
7
Code of Civil Procedure § 2031.300(c) : ;.; 10
8
Govemment Code § 8547 et seq 2
9
10 Govemment Code § 12940(a) • 2
11 Rules ofCourt, mle 3.1345(b) ; 9

12
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NO NO
ON
15
(—, • - 1) 0 \ ON
IJ oo c 16
^ s iH tu
O- c S
3 cn
17
18
19
20
21
22
23
24
25
26
27
28
{02023105.DOCX} IV
1 Defendants BOYD, CHILCOTT, NICHOLS, OROPEZA, and SEIFERT ("anti-SLAPP
2 Defendants" or "Defendants") respectfully submit the following memorandimi of points and
3 authorities in support of their motion to: (1) compel Plaintiff JAROSLAW ("JERRY")
4 WASZCZUK's verified responses, without objections, to Judgment Debtor Requests for
Production of Documents (Set One) and Judgment Debtor Interrogatories (Set One); (2) award
monetary sanctions in the amount of $4,160.00 to retum Defendants to the position they would
have been had the subject judgment debtor discovery responses been timely provided; (3) issue
8 terminating sanctions against Plaintiff and in favor of Defendant REGENTS OF THE
9 UNIVERSITY OF CALIFORNIA ("UNIVERSITY") as a result of Plaintiff s pattem of failure to
11 I.
12 INTRODUCTION
o
o
fN
13 Anti-SLAPP Defendants served Plaintiff with Judgment Debtor Requests for Production of
t- 3 oo —
i n oo
t - cn ON -q-
0 u Documents (Set One) and Judgment Debtor Interrogatories (Set One) on October 9, 2018.
<• ON
^ g U ON fN
—> o ^ 5 15 Responses were due on or before November 13, 2018. Plaintiff has failed to provide verified and
ON ON
01 <
1 -J
2 UJ
^ 16 adequate responses and same are overdue.
Cu c ca u.
D Defendants respectfully request the Court issue an Order to (1) compel Plaintiff to provide
o
in 17
verified responses to the anti-SLAPP Defendants' Judgment Debtor Requests for Production of
18
Documents (Set One) and Judgment Debtor Interrogatories (Set One); (2) issue monetary sanctions
19 I
20 against Plaintiff in the amount of $4,160.00 for Defendants' fees and costs incurred in bringing this
21 motion; and (3) issue the sanction of termination of the present action as a result of Plaintiffs
.22 continuing pattem of failing to provide discovery responses.
IL
23
24
25
26
2014. Among the several claims in the SAC are four causes of action against all named
27
28
{02023105. DOCX}
1
1 Defendants:' (1) intentional infliction of emotional distress ("IIED"); (2) tortious interference with
4 in violation of Govemment Code §§ 8547 et seq.
5 Each of these causes of action arises out of Plaintiffs employment with Defendant
6 UNIVERSITY at the University of Califomia at Davis Medical Center. In addition to Defendant
7 UNIVERSITY^ these causes of action were pled against Defendants ANN MADDEN RICE,
8 MIKE BOYD, STEPHEN CHILCOTT, CHARLES WITCHER, DANESHA NICHOLS, CINDY
9 OROPEZA, BRENT SEIFERT, PATRICK PUTNEY, and DORIN DANILIUC for their
10 participation in investigations and disciplinary actions that ultimately resulted in Plaintiffs
11 termination of employment with the UNIVERSITY. The UNIVERSITY is the only Defendant
12 remaining in the case.
o
o
fN 13 On December 1, 2014, anti-SLAPP Defendants filed a Special Motion to Strike Plaintiffs
Bm
u- fN — NO
r- 3 oo 00 O
H (/2 14 causes of action as pled against them. (Declaration of Daniel Bardzell in Support of Further
0 u-o^
fN f N
01 < 6
ON ON
NO NO
15 Motion to Compel ("Bardzell Decl."), Tl 2.) The anti-SLAPP Defendants contended that Plaintiffs
U >:> cON ON
^ ^ E J ><
W <
16 causes of action against them arose from protected activities pursuant to Code of Civil Procedure-'
a. c H u.
D cn 17 § 425.16; namely, their participation in the processing, investiga:tion, hearing and deciding of
o
•n
18 complaints filed by Plaintiff and others pursuant to the policies and procedures of the Defendant
19 UNIVERSITY. (M)
/ • '. ' .
23 SLAPP Defendants. (Id. at ^ 3 and Exhibit A.)
24 ///
25
26
2 ld.,fn. 1. .
28
^ Unless otherwise indicated, all further statutory references in this Motion are to the Califomia Code of Civil
Procedure.
{02023105. DOCX} 2
2 individual Defendants RICE, WITCHER, PUTNEY, and DANILIUC. (Id. at H 4 and Exhibit B.)
3 The UNIVERSITY is the only Defendant remaining in the case.
6 Special Motion to Strike. (Id. at ^ 5.) The motion sought recovery of approximately $33,000 in fees
7 and costs incurred by the anti-SLAPP Defendants in cormection with the Special Motion to Strike.
8 (Id., Exhibit C.)
10 Costs in the amoimt of $22,284 against Plaintiff (Id. at 6 and Exhibit C.)
11 A. Plaintiff Failed to Provide Timely Responses to Defendant UNIVERSITY'S Form and
Special Interrogatories, Request for Production of Documents, and Request for
12
o Admissions, Necessitating Two Motions to Compel Regarding Such Requests
o
fN
B m
13 In the underlying lawsuit from which the anti-SLAPP Defendants have been dismissed,
L_ •= <N
r-" 3 00 — NO
H cn
O
00 o
—
14 Plaintiff has engaged in a pattem of failing to adequately and timely respond to Defendant
ON t~~
Îs fN fN
ON ON
NO NO
15 UNIVERSITY'S discovery requests which has necessitated the filing of two motions to compel
oi < 6 ON ON
j'
^ S3 1
UJ
><
<
16 discovery by Defendant UNIVERSITY on October 17, 2018 and Febmary 11, 2019, respectively.
O .2; !iH u.
D cn 17 (Bardzell Decl., H 7-12.) In its mling on Defendant UNIVERSITY'S October 17, 2018 motion to
18 compel, the Court ordered Plaintiff to provide verified responses, without objections, to
19 Defendant's form and special interrogatories (sets one) and requests for production (set one) no
20 later than December 12, 2018. (Id. at H 9 and Exhibit D.) Additionally, the Court ordered Plaintiff
21 to pay Defendant UNIVERSITY mandatory monetary sanctions in the amount of $520 by
22 December 14, 2018 for failure to provide responses to requests for admissions. (Id.)
23 Plaintiff violated the Court's order by failing to fully pay such monetary sanctions and by
24 providing only deficient responses to the special and form interrogatories which necessitated the
25 filing of a second motion to compel on Febmary 11, 2019. (Id. at T| 9-12.)
26 The Court granted Defendant UNIVERSITY'S second motion to compel and ordered
27 Plaintiff to provide further verified responses to Defendant's form and special interrogatories (sets
28 one) no later than April 3, 2019. (Id. at ^ 12 and Exhibit E.) Additionally, the Court denied
{02023105.DOCX} 3
1 Defendant's request for monetary sanctions as the motion was imopposed and also denied
2 Defendant's request for terminating sanctions, (/of.)
3 B. Plaintiff Ignores the anti-SLAPP Defendants' Meet-and-Confer Efforts Related to the
Judgment Debtor Requests for Production of Documents (Set One) and Judgment
4 Debtor Interrogatories (Set One)
5
The anfi-SLAPP Defendants served Plaintiff with Judgment Debtor Requests for
6
Production of Documents (Set One) and Judgment Debtor Interrogatories (Set One) on October 9,
7
2018. (Bardzell Decl., 13 and Exhibit F.) Responses were due on or before November 13, 2018.
8
(Id. at 13.) Plaintiff has completely failed' to provide any verified responses and same are
9
overdue. (Id.)
10
On January 24, 2019, counsel for Defendants served a meet and confer correspondence
11
upon Plaintiff regarding,the outstanding judgment debtor discovery responses wherein defense
12
o
o counsel indicated: "This letter serves as Defendants [. . .] attempt to meet and confer regarding
fN
B m
13
>
H
'= 00 — NO
CO i n 00 p ^ ^
Plaintiffs outstanding responses to Defendants' Judgment Debtor Request for Production of
o « °^ 2 p; 14 Documents, Set One and Judgment Debtor Interrogatories, Set One which were served on you on
> U ON ON . _
ai, < o so ^ 1 J
October 9, 2018. Plaintiff has provided no response whatsoever. Please provide complete
S 1 -J X 16
a- ta-
c cau H u. responses by January 31, 2019 or we will file a motion to compel and seek sanctions." (Id. at ^ 14
3 cn
o
in 17 and Exhibit G.)
18 By email correspondence dated January 25, 2019, Plaintiff asserted he never received a
19 copy of the judgment debtor discovery requests and further provided: "Please send me the
20 aforementioned documents that were supposed to have been sent in October. I will look them over
21 and respond to you with 30 days, or you may file the motion to compel if you wish." (Id. at ^ 15
22 and Exhibit H.) By email correspondence also dated January 25, 2019, the office of coimsel for
23 Defendants provided Plaintiff with a further courtesy copy of Defendants' Judgment Debtor
24 Request for Production of Documents, Set One and Judgment Debtor Interrogatories, Set One
25
26
27
/ •. •
which were previously served on Plaintiff on October 9, 2018. (/i/.)
/// ".
28
{02023105. DOCX} A

Plaintiff responded by email also dated January 25, 2019, stating: "Never got this before.
Have a nice weekend Ms. Strasser. I feel sorry for you that you are working for guy like Burkett or
Bardzell. Tell them to file motion." (Id. at 116 and Exhibit I.)
On February 22, 2019, counsel for Defendant served a further meet and confer
correspondence upon Plaintiff, providing: "This letter serves as Defendants [. . .] further attempt to
meet and confer regarding Plaintiffs outstanding responses to Defendants' [judgment debtor
discovery requests]. Plaintiff has provided no response whatsoever and responses are more than
three months overdue. Our previous attempts to meet and confer on this issue have been
unsuccessful. If we do not receive complete responses by March 1, 2019, our next action will be to
10 file a motion to compel and seek sanctions." (Id. at ^ 17 and Exhibit J.)
11 By email correspondence dated March 1, 2019, Plaintiff provided, in part; " I am not going
o
o
in
rJ
13 Califomia courts have done to me in the last four years. I did not provide the response by January
H 3 00 —
m 00
i— cn
O u ON 14 31, 2019 because the DEBTOR INTERROGATORIES - SET ONE TO PLAINTIFF [. . . and]
on g fN
<
< ri fN S 15 DEFENDANTS' REQUEST FOR PRODUCTION OF DOCUMENTS - SET ONE TO
o" ^ ON
5 ON
<U . .
6 -1 ^ 16 PLAINTIFF [. . .] were not sent to me on October 9, 2018 and I do not have any record of it[. . . .]
U.
1u
17 Porter Scott attomeys did not file a Motion to Compel as promised by the January 31, 2019 letter
19 date[. . .] If the Porter Scott attomeys want to file another Motion to Compel [. . .] I have no
20 control over it. I will not be surprised if the. Motion is granted." (Id. at T| 18 and Exhibit K.)
21 Plaintiff fiirther asserted that he provided some documents at the Judgment Debtor examination in
22 this matter. (Id.) ,
. 23 C. Anti-SLAPP Defendants File a Motion to Compel Responses Judgment Debtor

Requests for Production of Documents (Set One) and Judgment Debtor
24 Interrogatories (Set One) and For Monetary and Terminating Sanctions
25 On March 20, 2019, the anti-SLAPP Defendants filed a Mofion to Compel Responses
26 Judgment Debtor Requests for Production of Documents (Set One) and Judgment Debtor
27
Interrogatories (Set One), and for monetary and terminating sanctions. (Bardzell Deck, ^ 19.)
28
{02023105.DOCX} " ^

1 On April 15, 2019, while the anti-SLAPP Defendants' motion to compel judgment debtor
2 discovery was pending, Plaintiff served unverified, deficient responses to Defendants' Judgment
3 Debtor Requests for Production of Documents (Set One) and Judgment Debtor Interrogatories (Set
4 One). (Id. at ^ 20 and Exhibit L.)
5 'On April 25, 2019, the Court issued its tentative ruling, which later became the mling of
6 the Court pursuant to Local Rule 1.06 with a modificafion. (Id. at Tl 21.) The Court's final mling on
7 this motion rejected Plainfiffs argument in opposition that adequate responses were served
8 subsequent to the filing of the mofion and ordered Judgment Debtor "to serve further verified
9 responses to the Judgment Debtor Interrogatories and Judgment Debtor Requests for Production [.
10 , .] without objections, on or before May 8, 2019." (Id. and Exhibit M.)
11 Although the Court's tentative mling had initially also required Plaintiff "to pay reasonable
12 monetary sancfions to [the anfi-SLAPP Defendants] in the amount of $780 (3 hrs. at the hourly rate
o
o
fN 13 of $260), plus the $60 filing fee, for a total fee award of $840", this sancfions award was vacated
B m
fN — NO
H
,2 00 00 o
m 14 pursuant to the Court's final ruling. (Id.) The Court denied the anti-SLAPP Defendants further
O ON r~
fN fN
15 request for terminating sanctions related to the underlying lawsuit against the UNIVERSITY. (Id.)
îu ON ON
NO NO
ON ON
as < dJ >< 16
^ " iUi <
Plaintiff failed to serve verified responses to the Judgment Debtor Interrogatories eind
a- c «
D C/3 17 Judgment Debtor Requests for Production without objections by May 8, 2019 in violation of the
o
m
18 Court's order and such responses remain outstanding. (Id. at T| 22.)
19
D. Plaintiff Ignores the anti-SLAPP Defendants' Subsequent Meet-and-Confer Efforts
20 Related to the Judgment Debtor Requests for Production of Documents (Set One) and
21 Judgment Debtor Interrogatories (Set One)
22 On May 31, 2019, counsel for Defendants served a meet and confer correspondence upon
23 Plaintiff regarding the outstanding judgment debtor discovery responses which indicated:
24 This letter serves as Defendants MICHAEL BOYD, STEPHEN CHILCOTT, BRENT

SEIFERT, CINDY OROPEZA, and DANESHA NICHOLS ("Defendants'") attempt to
25
meet and confer regarding Plaintiffs failure to provide fiirther responses to Defendants'
26 Judgment Debtor Interrogatories - Set One and Judgement Debtor Request for Production
of Documents - Set One.
27 As provided by the Court's April 27, 2019 Minute Order following its April 26,
2019 tentative mling, Judgment Debtor/Plaintiff was ordered to "serve further verified
28
responses to the Judgment Debtor Interrogatories and Judgment Debtor Requests for
(02023105.DOCX} fi .
Production, as set forth in the separate statement, without objections, on or before May 8,
1 2019."
2 Plaintiff has failed to provide any further responses whatsoever. Please provide
complete responses immediately or we will take further action, as needed.
3
(Bardzell Deck, 123 and Exhibit N.)
4
Plainfiff responded by email dated June 1, 2019, stating, in part:
I will respond to your inquiry within a few days (most likely next week). [. . .] Your
threating letter stating "Please provide complete responses immediately or we will take
fiirther action, as needed" made me feel very uncomfortable. I received your May 31, 2019
threat of unspecified further action on the seventh anniversary of the ill-plaimed but
8 unsuccessfiil provocation to end my employment in the UC Davis Medical Center Trauma
Unit #11 by the specially assembled hit squad, which I nicknamed in the Court Documents
9
as the "Davis Death Squad." I hope that your new threat does not mean that the UCOP mob
10 led by Janet Napolitano gave the order to Porter Scott's special team to physically harm me
or my family members, taking into consideration previous Porter Scott attomeys'
11 provocations threats and 14 years of terror.
12 (Id. at H 24 and Exhibit O.)
o
o
fN
B m
13 Plaintiff further responded by email dated June 8, 2019, stating in part:
E- 3 S - NO
O cn m 00 o 14
U 1) ON •*
— m As I stated in my April 12, 2019 Opposition to Defendants' Motion to Compel and
t/2 i < ON
Oi u fN s:^ 15 Terminate Sanctions filed by you on March 20, 2019, for the Defendants' Judgment
UJ
H > ( J ON ON Debtor Interrogatories Set One and Judgment Debtor Request for Production of
oi
O <^> —o" ^ — 16 Documents Set One, and during the April 26, 2019 Court hearing with Judge Steven
&- .3 uC ON ON
5 td
17 Rodda, I have no more information to give you other than what you have received already.
D cn
o In fact, I should not give you any information in this matter, but this is a separate subject
in 18 that I wiir address after you file another Mofion to Compel or any other mofion related to
this case.
19
20 (Id. at H 25 and Exhibit P.)
21 III.
PLAINTIFF SHOULD BE ORDERED TO PROVIDE RESPONSES TO
22 JUDGMENT DEBTOR REOUEST FOR PRODUCTION OF DOCUMENTS (SET ONE)
26 interrogatories to the judgment debtor imder CC-P- § 2030.010, et seq., and (2) service of a
27 document inspecfion demand to the judgment debtor under CCP. § 2031.010, et seq. (CCP. §§
28
2016.070; 708.020; 708.030.)
{02023105.DOCX} 7
3 separately to each interrogatory by any of the following: an answer containing the informafion
4 being sought to be discovered, an exercise of the party's opfion to produce writings, or an
objection to the particular interrogatory. (CCP. § 2030.210(a).) If a party to whom interrogatories
are directed fails to serve a timely response, the party propounding the interrogatories may move
for an order compelling response to the interrogatories. (CCP. § 2030.290(b).) The party also
9 failing to respond by the deadline. (CC^P. § 2030.290(a).)
11 to a 45-day time limit, and the propoimding party does not have to demonstrate either good cause
12 or that it satisfied a meet-and-confer requirement. (Sinaiko Healthcare Consulting, Inc. v. Pacific
o
o
13 Healthcare Consultants (2007) 148 Cal.App.4th 390, 411.) A separate statement is not required
f- 3 fOO
N
—
m OO
O u ON -Sl- when no response has been provided to the request for discovery. (Rules of Court, mle 3.1345(b).)
< • ON f N
—>
ON 2 15 In our case. Defendants have not received Plaintiffs verified responses to Judgment Debtor
fN
a; < 2" )B ON
S ON
oi I- LZ ^ 16 Interrogatories (Set One). (Bardzell Deck, t 22.) These interrogatories were properly served on
y r-
o
in 17 Plaintiff on October 9, 2018. (Id. at T| 13 and Exhibit F.) Responses were due on or before
18 November 13, 2018. (M)
19 Plaintiff served imverified, deficient and late responses to Judgment Debtor Interrogatories
20 (Set One) on April 15, 2019. (Id. at 20 and Exhibit L.) Interrogatory responses served without a
21 verification are tantamount to serving no responses as all. (Zorro Inv. Co. v. Great Pacific
22 Securities Corp. (1977) 69 Cal.App.3d 907, 914 ("Untimely or unswom statements are tantamovmt
23 to no response at all[.]") citing Kaiser Steel Corp. v. Westinghouse Elec. Corp., 55 Cal.App.3d
24 737, 744.).) Plaintiffs unswom responses are wholly insufficient and constitute a complete failure
25 to respond.
26 Plaintiffs late unverified interrogatory responses are not code-compliant discovery
27 responses. Plaintiff has waived any objections to^the requests by failing to timely respond to them.
28 (Code of Civil Procedure sections 2030.290(a) [interrogatories] & 2031.300(a) [producfion
{02023105. DOCX} g
FOR PRODUCTION QF DOCUMENTS; AND FOR MONETARY AND TERMINATING SANCTIONS
1 requests].) Instead of serving responses without objections, the unverified responses contain
2 outright refusals to provide information regarding Plaintiffs wife's finances. (Bardzell Deck,
3 Exhibit L, "Response to Defendants' Judgment Debtor Rpgs #1".) Defendants are entitled to that
4 information to determine what assets Plaintiff has (whether individually or as community
5 property), so they can determine what can be collected, and how to collect it, to pay the judgments
6 that he owes in this case. Plaintiff refused that provide that information at the debtor's examination
7 (which is part of the reason why Defendants have had to file this motion not\yithstanding their
8 attempt to resolve the issues in this motion by taking discovery into Plaintiffs assets via the
9 debtor's examination). (Id.)
10 Defendants require these verified interrogatory responses in order to enforce their,
11 judgment. Accordingly, Defendants respectfiilly request a further Order compelling Plainfiff to
12 provide verified and code-compliant responses to anti-SLAPP Defendants' Judgment Debtor
o
o
fN
B m
13 Interrogatories (Set One) without objections.
U- 3 fN
r- 3 oo _ NO
t- cn 00 g
^ rn
fN
oi < 6
ON I3N 15 If a party to whom a demand for inspection is directed fails to serve a timely response, the
NO NO
ON OS
b 3 J >< 16 party propounding the demand may move for an order compelling responses to the demand.
o > sLU
H
<
ti.
D C/2
o
17 (CCP. § 2031.300(b).) The party to whom the demand for inspection is directed shall sign the
in
f^
18 response under oath unless the response contains only objections. (CCP. § 2031.250(1).) In
19 addition, a party who fails to respond waives any objecfions he otherwise could have raised to the
20 demand. (CCP. § 2031.300(a).)
21 As discussed supra, where, as here. Plaintiff has failed to provide any timely verified
22 responses, a motion to compel responses is not subject to a 45-day time limit, and the propoimding
23 party does not have to demonstrate either good cause or that it satisfied a meet-and-confer
24 requirement. (Sinaiko Healthcare Consulting, Inc., supra, 148 Cal.App.4th at 411.) A separate
25 statement is not required when no response has been provided to the request for discovery. (Rules
26 ofCourt, mle 3.1345(b).)
28 (Set One) on October 9, 2018. (Bardzell Deck, ^ 13 and Exhibit F.) Responses were due on or
{02023105.DOCX} 9
1 before November 13, 2018. (Id.) Plaintiffs responses remain overdue and outstanding. (Id. at ^ 13,
2 22.) .
3 Plainfiff served unverified, late and deficient responses to Judgment Debtor Requests for
4 Production of Documents (Set One) on April 15, 2019. (Id. at ^ 20 and Exhibit L.) As discussed
5 supra, discovery responses served without a verification are tantamount to serving no responses as
6 all. (Zorro Inv. Co., supra, 69 Cal.App.3d at 914.) Moreover, for the same reasons set forth supra
7 regarding Plaintiffs judgment debtor interrogatory responses. Plaintiffs responses to Judgment
8 Debtor Requests for Production of Documents (Set One) are not code compliant. Plaintiff s
9 imswom responses to Judgment Debtor Requests for Production of Documents (Set One) are
10 wholly insufficient and constitute a complete failure to respond.
11 Therefore, Defendants respectfiilly request an Order compelling Plainfiff to provide
12 verified responses to Defendants' Judgment Debtor Request for Production of Documents (Set
B m
13 One), without objections.
[_ - 3 rNi
— NO
H cn 5S
O 00 o 14 IV.
U
1/3
i <— ON I^'
rs f N
CtJ < Q- ON ON
W .5^ 3 NO NO
ON ON
^ " i JUJH ><•

<
U.
PH c ed
3 (/I 17
18 misuse of the discovery process, or any attomey advising that conduct, or both pay
the reasonable expenses, including attomey's fees, incurred by anyone as a result of
19 that conduct [. . .] If a monetary sanction is authorized by any provision of this
20 fitle, the court shall impose that sanction imless it finds that the one subject to the
21 imposition of the sanction imjust.
22 CCP. §§ 2030.290(c) and 2031.300(c) provide that a court shall impose a monetary
26 matter by conducting extensive meet and confer efforts. Plaintiff has ignored his obligation to
27 provide verified and adequate responses to Defendants' judgment debtor discovery requests. He
28 has further failed to comply with the Court's order compelling responses.
{02023105. DOCX}
10
2 discovery has made this second judgment debtor discovery motion necessary, despite being
3 afforded the opportunity to avoid the need for same.
4 To date. Defendants have incurred $2,860.00 in fees as a result of Plaintiffs failure to
5 respond to Judgment Debtor Requests for Production of Documents (Set One) and Judgment
6 Debtor Interrogatories (Set One) since the Court mled on Defendants' inifial mofion to compel
7 judgment debtor discovery. (Bardzell Deck, ^ 26.) Defendants anticipate incurring an additional
8 $1,300 to review Plaintiffs Opposifion, prepare a reply and attend a hearing. (Id.) Therefore,
9 sanctions are proper. Moreover, even i f Plaintiff serves verified responses upon notice of this
10 motion in order to avoid a court order. Defendants have nevertheless been forced to incur the
11 expense of moving to compel Plaintiffs compliance with his discovery obligations, despite efforts
12 to achieve a cooperative result. As such, sanctions in the amount of $4,160.00 are appropriately
o
o
fN 13 awarded against Plaintiff for thefimeand expense incurred by Defendants in filing this motion.
B m
— NO
L_ -3 fN
OO p
— m
14 V.
ON I-^
fN fN
H cn
o
ON ON
NO SO
ON ON
oi u <
O
oi
a. <C cd
D cn 17 who engages in conduct that constitutes misuse of the discovery process. (CCP. § 2023.030(a).)
o
in
19 of discovery" and "disobeying a court order to provide discovery." (CCP. §§ 2023.010(d), (g).)
22 both. (CCP § 2023.030(a), (d), (g).)
25 would not bring the offending party into compliance. (R.S. Creative, Inc. v. Creative Cotton, Ltd.
27 fails to respond to discovery requests and ignores court orders. (Kahn v. Kahn (1977) 68
28 Cal.App.3d372, 383.)
{02023105.DOCX} 11
2 verified responses to the Defendants' written judgment debtor discovery despite extensive meet
3 and confer efforts by Defendants. Moreover, the Court has previously granted a motion to compel
4 judgment debtor discovery filed by the anti-SLAPP Defendants in this case. (Bardzell Deck, ^ 21
5 and Exhibits M.) Plainfiff has completely ignored the Court's order regarding the prior judgment
6 debtor discovery motion. (Id. at ^ 22.) Plaintiff has plainly not been dissuaded from his pattem of
7 failing to engage in the discovery process.
8 Additionally, the Court has previously granted two motions to compel discovery filed by
9 Defendant UNIVERSITY in the underlying lawsuitfi"omwhich the judgment at issue arose. (Id. at
10 ^ 7-12 and Exhibits D-E.) Although these further discovery failures pertain to discovery requests
11 served by Defendant UNIVERSITY rather than the anti-SLAPP Defendants, such aggravafing
12 circumstances regarding discovery in the underlying lawsuit, when considered along with
o
o
fN
ii m
13 Plaintiffs pattern of failing to engage in the judgment enforcement discovery process, warrant the
"3 fN
t r2 00 — 5 14 remedy of terminating sanctions of the underlying lawsuit against Defendant UNIVERSITY.
t — cn in 00 o
S fN fN
^ <I o<
>
" a
^ f:i'
ON ON . ^
Plainfiffs demonstrated pattem of failing to provide discovery responses has prejudiced
U ^^11).I 5^. ,5;
I- r ^
Defendants' ability to prepare for trial by necessitafing substantial expenditures of time and money
D cn
o 17 to compel Plaintiff to both (1) comply with his discovery obligations in the underlying lawsuit; and
18 (2) fulfill his judgment debtor discovery obligations to permit the anfi-SLAPP Defendants to
19 enforce their judgment.
20 Plaintiffs enduring lack of cooperation with the discovery process - despite a total of three
21 prior discovery motions - makes it apparent that no action will compel Plaintiff to comply with his
22 discovery obligations, making terminating sanctions appropriate.
23 Accordingly, Defendants request that the Court grant terminating sanctions and issue an
24 Order dismissing the complaint against the remaining Defendant UNIVERSITY in its enfirety,
25 with prejudice.
26 ///
27 ///
28 ///
{02023105.DOCX}
12
1 VL
2 CONCLUSION
4 however Plaintiff has failed to provide verified responses to the anti-SLAPP Defendants'
,5 Judgment Debtor Requests for Production of Documents (Set One) and Judgment Debtor
6 Interrogatories (Set One). Defendants are left with no option other than to file the instant motion.
7 As such. Defendants seek an Order (1) compelling Plaintiff to provide verified responses,'without
objections, to the anti-SLAPP Defendants' Judgment Debtor Requests for Production of
Documents (Set One) and Judgment Debtor Interrogatories (Set One); (2) awarding anti-SLAPP
10 Defendants sanctions in the amount of $4,160.00 to retum them to the position they would have
11 been had responses been timely provided; (3) issue terminating sancfions against Plaintiff in favor
12 of Defendant UNIVERSITY as a result of Plaintiff s continuing pattern of failing to engage iri the
o
o
I—1
am
3 fN _
r-* 3 00 NO
E- cn m oo p
o u =^ 2: P; 14
> N j ON ON .. ^ Dated: June 12, 2019 PORTER SCOTT
< O" ^ ^ 1^
•ijj 2^ c o^ A PROFESSIONAL CORPORATION
S g g -J X 16
By.
19
20
21
22
23
24
25
26
27
28
{02023105. DOCX}
13
1
2
3 PROOF OF SERVICE
4 At the time of service, I was over 18 years of age and not a party to this acfion. My
business address is 350 University Avenue, Suite 200, Sacramento, Califomia 95825.
5
7 MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF DEFENDANTS'

MOTION TO COMPEL RESPONSES TO JUDGMENT DEBTOR INTERROGATORIES
8 AND REQUEST FOR PRODUCTION OF DOCUMENTS; AND FOR MONETARY AND
course of business with the United States Postal Service, in a sealed envelope with postage fully prepaid.
o
o addressed below. (1) For a party represented by an attomey, delivery was made to the attomey or at the
fN
^ in
13 attomey's office by leaving the documents, in an envelope or package clearly labeled to identify the
•3 S - NO attomey being served, with a receptionist or an individual in charge of the office, between the hours of nine
cn m 00 o
o «r <^ !^ 14 in the moming and five in the evening. (2) For a party, delivery was made to the party or by leaving the
u i <• Jri documents at the party's residence with some person not younger than 18 years of age between the hours
> NJ CJN
oi < o " NO NO
15 ON
of eight in the moming and six in the evening.
W C ON ON
H BY OVERNIGHT DELIVERY: I enclosed the documents in an envelope or package provided by an
ai 16 ovemight delivery carrier and addressed to the person(s) listed below. I placed the envelope or package for
O
collection and ovemight delivery at my office or a regularly, utilized drop box of the ovemight delivery
c/o 17 carrier.
BY FAX TRANSMISSION: Based on an agreement of the parties to accept service by fax transmission, I
18 faxed the documents to the persons at the fax numbers listed below. No error was reported by the fax
machine that \ used. A copy of the record of the fax transmission, which I printed out, is attached
19
BY ELECTRONIC SERVICE: Based on a court order or an agreement of the parties to accept service by
20 electronic transmission, I caused the documents to be sent to the persons at the electronic notification
address listed below. '
21
Jaroslaw Waszczuk
Lodi, CA 95242
23
24
25 I declare under penalty of perjury imder the laws of the State of Califomia that the
26 foregoing is tme and correct. Executed at Sacramento, Califomia on Jime 12, 2019.
27
28 Wendy Strasser
{02023105.DOCX}
14
EXHIBIT # 24
MINUTE ORDER
DATE: 07/19/2019 TIME: 02:00:00 PM DEPT: 53
CLERK: D. Johnson-Mellado
REPORTER/ERM: L. Gallager # 8726
BAILIFF/COURT ATTENDANT: Alvi, N., R. Mays

APPEARANCES
Dan Bardzell, Counsel for defendant
Nature of Proceeding: Motion to Compel Responses and Request for Production of Docs
TENTATIVE RULING
Compel Responses to Judgment Creditors' Interrogatories and Judgment Debtor's Requests for
as follows.
action and entered judgment in favor of Judgment Creditors. The Court subsequently granted Judgment
Creditors' Motion for Attorneys' fees in the amount of $22,284. (Bardzell Decl. ¶¶ 3, 6, Exhs. A, C.)
Judgment Creditors served the instant post-judgment discovery on October 9, 2018. (Bardzell Decl. ¶13,
Exh. F.) Judgment debtor/plaintiff failed to provide any responses to the discovery. Judgment Creditors
sent a second copy of the discovery to judgment debtor on January 25, 2019, after judgment
debtor/plaintiff contended he never received the first set served in October. (Bardzell Decl. ¶ 14, Exh. G.)
After receiving no responses, Judgment Creditors filed a motion to compel responses on March 20,
2019. On April 15, 2019, while the motion to compel was pending, judgment debtor/plaintiff served
unverified responses. (Bardzell Decl. ¶ 20, Exh. L.)
On April 26, 2019, the Court granted Judgment Creditors' motion to compel and ordered judgment
debtor/plaintiff to serve further verified responses, without objections, on or before May 8, 2019. (ROA
211.) While monetary sanctions were initially granted in the tentative ruling, after hearing at oral
argument, the Court vacated the order for monetary sanctions.
Judgment debtor/plaintiff has failed to comply with this Court order and provide any further responses.
(Bardzell Decl. ¶ 23.) Judgment Creditors have attempted to meet and confer with judgment
debtor/plaintiff, but have been unable to obtain compliance with the Court's discovery order.

Judgment Creditors now move to compel judgment debtor/plaintiff to serve further verified responses,
without objections, to Judgment Debtor Interrogatories and Judgment Debtor Requests for Production of
Documents. Judgment Creditors contend they have not received any verified responses from judgment
debtor/plaintiff and the unverified responses they have received are not code-compliant because they
contain an objection and refusal to provide the information, even though judgment debtor/plaintiff has
waived objections by not timely responding. Judgment Creditors contend the information sought is
relevant to enforce their judgment.
Judgment debtor/plaintiff has submitted points and authorities in opposition to the motion, but these do
not address the relevant issues in this motion, and consists almost entirely of matters irrelevant to the
discovery at issue.
Judgment debtor/plaintiff is again ordered to serve further verified responses to the Judgment
Debtor Interrogatories and Judgment Debtor Requests for Production, without objections, on or
before July 29, 2019.
The Court cautions judgment debtor/plaintiff that compliance with a facially valid court order is
mandatory. (See, e.g., In re Brambini (1923) 192 Cal. 19, 28-32; see also In re Berry (1968) 68
Cal.2d 137, 147.)
Judgment debtor/plaintiff is also ordered to pay reasonable monetary sanctions to moving parties in the
amount of $1,300 (5 hrs at the hourly rate of $260), plus the $60 filing fee, for a total fee award of
$1,360. This opposition was filed without substantial justification and therefore, moving parties are
entitled to monetary sanctions. The monetary sanctions must be paid on or before August 19, 2019. If
those sanctions are not paid by that date, moving parties may prepare a formal order on the two
sanctions awards which may thereafter be entered as a separate judgment. (See Newland v Superior
Court (1995) 40 Cal.App.4th 608.)
by Judgment Creditors, not The Regents of the University of California ("Regents"). Moving parties have
already obtained a judgment of dismissal in this case as well as an attorneys' fees award on the
anti-SLAPP motion. Thus, it is unclear why they are seeking a "terminating sanction" in this context.
a terminating sanction as to Regents.
Conclusion
As stated above, judgment debtor/plaintiff is again ordered to serve verified responses to the
Judgment Debtor Interrogatories and Judgment Debtor Requests for Production, without
objections, on or before July 29, 2019. Monetary sanctions are to be paid as specified above.
notice is required.
COURT RULING

The Court vacated $60 filing fee from the tentative ruling as listed below:
Judgment debtor/plaintiff is ordered to pay reasonable monetary sanctions to moving parties in the
amount of $1,300 (5 hrs at the hourly rate of $260), for a total fee award of $1,300.

EXHIBIT # 25
JAROSLAW WASZCZUK vs REGENTS OF UNIVERSITY OF CA
July 19, 2019 Page 1
·1· · · ·IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
·2· · · · · · · · ·FOR THE COUNTY OF SACRAMENTO
·3· · · · · · HON. DAVID BROWN, JUDGE, DEPARTMENT 53
·4· · · · · · · · · · · · · --oOo--
·5· JAROSLAW WASZCZUK,· · · · · · · · · )

· · · · · · · · · · · · · · · · · · · · )
·6· · · · · · · · · · · · · ·Plaintiff, )
· · · · · ·vs.· · · · · · · · · · · · · )· Number
·7· · · · · · · · · · · · · · · · · · · )2013-00155479
· · THE REGENTS OF THE UNIVERSITY OF CA,)
·8· · · · · · · · · · · · · · · · · · · )
· · · · · · · · · · · · · · · ·Defendant)
·9· · · · · · · · · · · · · · · · · · · )
· · · · · · · · · · · · · · · · · · · · )
10· · · · · · · · · · · · · · · · · · · )
· · · · · · · · · · · · · · · · · · · · )
11· · · · · · · · · · · · · · · · · · · )
· · · · · · · · · · · · · · · · · · · · )
12
· · · · · · · · · · · · · · ·--oOo--
13
· · · · · · · ·REPORTERS' TRANSCRIPT OF PROCEEDINGS
14
· · · · · · · · · · · · · · --oOo--
15
· · · · · · · · · · · · ·JULY 19, 2019
16
· · · · · · · · · · · · · · --oOo--
17
· · · · · · · · · · · · · APPEARANCES:
18
· · · · · · ·For the Plaintiff:
19
· · · · · · · JAROSLAW WASZCZUK, In Pro Per
20
21· · · · · · For the Defendant:
22· · · · · · DANIEL BARDZELL, Attorney at Law
23
24
25
26· · · · · · · · · · · · · ·--oOo--
27
28· · · · · · · · LAURI GALLAGHER, CSR No. 8726
Superior Court of the State of California

County of Sacramento 10-11-2019 8:37AM YVer1f
·1· · · · · · · · · · · JULY 19, 2019

·2· · · · · · · · · · · · · --oOo--
·3· · · · · ·THE COURT:· The matter of the Waszczuk vs. The
·4· ·Regents, Defendant, Case Number 2013-00155479, came on
·5· ·regularly this day before Honorable DAVID BROWN, Judge
·6· ·of the Superior Court of the State of California, for
·7· ·the County of Sacramento, Department 53.
·8· · · · · ·The following proceedings were then had:
·9· · · · · ·THE COURT:· Item No. 1.
10· · · · · ·MR. BARDZELL:· Daniel Bardzell from Porter
11· ·Scott, Defendants.
12· · · · · ·THE COURT:· A couple questions I have for you
13· ·first, Mr. Bardzell.· There's a 60 dollar filing fee.
14· ·Does that apply?· In other, words did you pay it?
15· · · · · ·MR. BARDZELL:· No, the Regents are exempt --
16· · · · · ·THE COURT:· This isn't the Regents.· The
17· ·motion is made as I understand on behalf of --· oh, it
18· ·is the Regents.
19· · · · · ·MR. BARDZELL:· The motion is made on behalf of
20· ·the anti-SLAPP defendants.
21· · · · · ·THE COURT:· The individuals?
22· · · · · ·MR. BARDZELL:· Correct.
23· · · · · ·THE COURT:· That's what I asked.· It says you
24· ·are counsel for the Regents.· You don't say anybody
25· ·else.
26· · · · · ·MR. BARDZELL:· I'm sorry.· The motion papers?
27· · · · · ·THE COURT:· Well, on your papers, it says you
28· ·are counsel for the Regents.· This motion is made on

·1· ·behalf of the individuals, I understand.· It is Boyd,

·2· ·Chilcott, Nichols, Oropeza and Seifert's motion to
·3· ·compel responses.· Right?
·4· · · · · ·MR. BARDZELL:· That's correct.
·5· · · · · ·THE COURT:· But you didn't caption it that
·6· ·way.· This is a post judgment request for discovery?
·7· · · · · ·MR. BARDZELL:· Correct.· That's an improper
·8· ·caption.
·9· · · · · ·THE COURT:· Does the Court allow you a 60
10· ·dollar filing fee, or did your individual defendants
11· ·pay that?
12· · · · · ·MR. BARDZELL:· My understanding is they did
13· ·not pay the filing fee.
14· · · · · ·THE COURT:· Then the Court should vacate that
15· ·piece of the sanction; correct?
16· · · · · ·MR. BARDZELL:· We would not be opposed to
17· ·vacating the filing fee.
18· · · · · ·THE COURT:· The Court will do that right now.
19· · · · · ·I have another question for you while we're
20· ·sitting here talking about this.· I looked at the
21· ·responses Mr. Waszczuk provided, which were part of
22· ·your papers, Mr. Bardzell.· It was attached, I believe,
23· ·to your declaration as exhibits -- answers to --
24· · · · · ·MR. BARDZELL:· Exhibit L.
25· · · · · ·THE COURT:· The only thing I didn't see, I
26· ·didn't see any objections at all.· All I saw was no
27· ·signature.
28· · · · · ·Is the argument that there's no verification?

·1· · · · · ·MR. BARDZELL:· That's part of the argument, Your

·2· ·Honor.· I will direct you to an example of an
·3· ·objection.
·4· · · · · ·If you look at page 6 of the response to
·5· ·Judgment Debtor Request for Production of Documents.
·6· · · · · ·THE COURT:· Page 6.· Give me a moment.
·7· · · · · ·I'm starting with you because I want to make
·8· ·sure Mr. Waszczuk understands why we're doing what
·9· ·we're doing.
10· · · · · ·MR. BARDZELL:· Request for production number
11· ·21, the answer --
12· · · · · ·THE COURT:· It's protected by privileged work
13· ·product, right of privacy?
15· · · · · ·THE COURT:· And the Court had previously
16· ·ordered that the motions be granted with no objections;
17· ·correct?
18· · · · · ·MR. BARDZELL:· I don't have the ruling in
19· ·front of me.· I believe it was without objections.
20· · · · · ·THE COURT:· So if there are no objections, Mr.
21· ·Waszczuk should file amended responses without
22· ·objections.· No problem with that.
23· · · · · ·Did he provide verification because all of these
24· ·responses that I see here in Exhibit L that you
25· ·provided me include, "I declare under penalty of
26· ·perjury under the laws of the State of California that
27· ·the foregoing was true and correct."· That's an
28· ·appropriate jurat under 2015.5.· But he didn't sign it.

·1· ·Do you have a signed copy, sir?

·2· · · · · ·MR. BARDZELL:· No, I do not.
·3· · · · · ·THE COURT:· That's one of the problems that we
·4· ·have here; correct?
·5· · · · · ·MR. BARDZELL:· Correct.· He signed the
·6· ·declaration of service, but he did not sign the
·7· ·verification.
·8· · · · · ·THE COURT:· Thank you.· You have answered all
·9· ·of my questions, Mr. Bardzell.
10· · · · · · Mr. Waszczuk?
11· · · · · ·MR. WASZCZUK:· Your Honor, what I see in here,
12· ·because I don't know exactly what defendants knows.· If
13· ·Your Honor look the register of action in this
14· ·proceeding --
15· · · · · ·THE COURT:· I did.
16· · · · · ·MR. WASZCZUK:· Then since October 3rd, they
17· ·filing the motion for termination sanction.
18· · · · · ·THE COURT:· I denied that motion for
19· ·terminating sanctions.
20· · · · · ·MR. WASZCZUK:· I understand that, but Your
21· ·Honor, this is about money, not termination.
22· · · · · ·THE COURT:· If you don't do what you are
23· ·supposed to do, there may be a penalty.
24· · · · · ·MR. WASZCZUK:· I understood.
25· · · · · · THE COURT:· This is post judgment discovery,
26· ·Mr. Bardzell.· What are you terminating?· There's
27· ·already a judgment against Mr. Waszczuk.
28· · · · · ·MR. BARDZELL:· The motion is filed on behalf

·1· ·of the anti-SLAPP defendants, but we're okay with the
·2· ·tentative ruling at this point.
·3· · · · · ·THE COURT:· So he is okay with it,
·4· ·Mr. Waszczuk, but you have to provide him answers
·5· ·without objections and sign them under penalty of
·6· ·perjury.
·7· · · · · ·MR. WASZCZUK:· I need to know what they want.
·8· · · · · ·THE COURT:· You answered them.· You didn't do
·9· ·a bad job.· I read all your answers.· Most of them were
10· ·pretty good.· I would have been happy with them if I
11· ·were Mr. Bardzell, but you didn't sign them, and there
12· ·were a couple objections that were pointed out to me.
13· · · · · ·MR. WASZCZUK:· I gave Mr. Bardzell everything
14· ·on February 8th.
15· · · · · ·THE COURT:· Did you sign the answers, Mr.
16· ·Waszczuk?
17· · · · · ·MR. WASZCZUK:· Your Honor, we were in court --
18· · · · · ·THE COURT:· I don't care whether you were in
19· ·court.· Did you sign the answers?
20· · · · · ·MR. WASZCZUK:· I believe so.
21· · · · · ·THE COURT:· Do you have Exhibit L?· Do you
22· ·have a copy of his motion in front of you?· It's
23· ·Exhibit L.· It should have a little tab at the bottom.
24· · · · · ·Please show him, Mr. Bardzell.
25· · · · · ·All right.· Exhibit L.· Go to the very end of
26· ·your response to the production of documents.· Go to
27· ·page 7.
28· · · · · ·Do you see where it says submitted on

·1· ·4-12-2019?· Page 7, line 26.· Do you need assistance?

·2· · · · · ·MR. WASZCZUK:· Yes.
·3· · · · · ·THE COURT:· Please assist him.· Go to page 7
·4· ·of your responses to the request for production of
·5· ·documents.
·6· · · · · ·Do you see a signature there at all?
·7· · · · · ·MR. WASZCZUK:· No.
·8· · · · · ·THE COURT:· He needs your signature.· Do you
·9· ·see the next one right underneath it, and if you go to
10· ·the end of that one too, guess what?· No signature.
11· ·That's page 8.
12· · · · · ·MR. WASZCZUK:· Your Honor, I don't believe
13· ·what they are talking about.
14· · · · · ·THE COURT:· I can't say they are wrong when I
15· ·look at the documents they give me, and I don't see a
16· ·signature.· All you have to do is sign it.· All I want
17· ·you to do is sign it.
18· · · · · ·MR. WASZCZUK:· I can sign now.
19· · · · · ·THE COURT:· I recognize that, but I think it
20· ·would be more appropriate if you would answer it
21· ·without any objections at all.
22· · · · · ·You have to admit, Mr. Bardzell, most of these
23· ·substantive answers, "I don't own any real property."
24· ·"I don't have any jewelry."· "I don't know have any
25· ·bank accounts with X dollars in it."· "I don't own
26· ·stocks or bonds."
27· ·You said all of that, but you didn't sign it under
28· ·penalty of perjury because you didn't sign it.

·1· · · · · ·Once you sign it, that's what he needs.· These

·2· ·are civil procedures enacted by the legislature that
·3· ·you have to comply with.· At this point all have you to
·4· ·do is sign it and answer the ones that you objected to.
·5· · · · · ·MR. BARDZELL:· I would point out that the
·6· ·major concern that we have with his responses, the ones
·7· ·that refer to the assets of his spouse, contained
·8· ·outright refusals to respond.
·9· · · · · ·THE COURT:· He's going to have to do that.
10· · · · · ·Unfortunately, you are going to have to make a
11· ·good faith inquiry or say you don't know.· If you say
12· ·you don't know, I may have a right to inquire as to why
13· ·you don't know.
14· · · · · ·Under California law, your spouse's assets maybe
15· ·liable for some piece of your judgment.· Just saying, I
16· ·think they have a right ask.· You can't object to it if
17· ·you think it's bad.
18· · · · · ·MR. WASZCZUK:· I explain on February 8th to
19· ·Mr. Bardzell, he wrote production of documents. I
20· ·answered all of his questions in the court, and here is
21· ·the court order saying the examination was complete and
22· ·the parties were released.· And I asked Mr. Bardzell,
23· ·do you have any complaints, can you go to judge with
24· ·complaints, and he said no.
25· · · · · ·THE COURT:· That is the O.X.?
26· · · · · ·MR. BARDZELL:· Yes, the examination.
27· · · · · ·THE COURT:· That has nothing to do with these
28· ·responses.

·1· · · · · ·MR. WASZCZUK:· He wrote the production of

·2· ·documents, and I answered question by question to him,
·3· ·and he is repeating this.
·4· · · · · ·THE COURT:· He has a right to ask different
·5· ·things in different way.
·6· · · · · ·MR. WASZCZUK:· Why he repeating the same?
·7· · · · · ·THE COURT:· Just so you know, people can use
·8· ·different methods of discovery to try to fare out the
·9· ·same stuff.· It's not always as graceful as you would
10· ·like, but it's permitted by the code.
11· · · · · ·MR. WASZCZUK:· The Department 53 judge is more
12· ·important than judge from Department 43.
13· · · · · ·THE COURT:· I will tell the Department 43
14· ·judge that.
15· · · · · ·MR. WASZCZUK:· And then another judge decide
16· ·and everything was concluded, and then another judge do
17· ·the same stuff.
18· · · · · ·THE COURT:· I don't know who the department 43
19· ·judge is.
20· · · · · ·MR. WASZCZUK:· Judge Blizzard.
21· · · · · ·THE COURT:· I will be sure to tell him.
22· · · · · ·MR. WASZCZUK:· I gave him all information you
23· ·wanted, and I ask him in front of my witness, he was
24· ·witness, this guy.
25· · · · · ·THE COURT:· That was an order of examination.
26· ·All right.· Give me a moment.
27· · · · · ·MR. BARDZELL:· Nothing further, Your Honor.
28· · · · · ·THE COURT:· Mr. Waszczuk, you know what you

July 19, 2019 Page 10
·1· ·need to do?

·2· · · · · ·MR. WASZCZUK:· I don't know what I need to do.
·3· ·This is the problem.
·4· · · · · ·THE COURT:· You are going to have to respond
·5· ·again to these discoveries.· One is the
·6· ·interrogatories, the other is the request for
·7· ·production.· You can file the same answers, but you
·8· ·can't object or refuse to answer.
·9· · · · · ·Most of your answers are pretty good, and you
10· ·are going to have to sign it under penalty of perjury,
11· ·which you didn't do the first time.
12· · · · · ·MR. WASZCZUK:· Maybe I omitted that, Your
13· ·Honor.· Mr. Bardzell should just say, "Hey, can you
14· ·sign this?"
15· · · · · ·THE COURT:· There's a couple other things he
16· ·wants.
17· · · · · ·Make sure you sign it at least, and then he will
18· ·be back here telling me about the things you still
19· ·objected to, but I'm telling you now that the order
20· ·that I'm providing to you tells you not to object and
21· ·not to refuse to answer the few things that you refuse
22· ·to answer.
23· · · · · ·MR. WASZCZUK:· This is about to pay them legal
24· ·fees, not about discovery.· They never asked to pay --
25· ·when I sent my letter to the previous lawyer, they are
26· ·beneficiary of those legal fees awarded them.· They
27· ·don't want to do anything with those legal fees, Your
28· ·Honor.

July 19, 2019 Page 11
·1· · · · · ·The Court want to know why?· I know why.

·2· · · · · ·THE COURT:· Sure, tell me.
·3· · · · · ·MR. WASZCZUK:· My lawyer saying prior to
·4· ·Thanksgiving, I offered him $20,000 to get help with
·5· ·the case.· Then they file the SLAPP motion -- they
·6· ·crafted the SLAPP motion during Thanksgiving, and day
·7· ·after on December 2, my lawyer pull out all money from
·8· ·my accounts, from retainer accounts, everything.· They
·9· ·cleaned the accounts and because, you know, they knew
10· ·that I will not be coming back.· I was placed on the
11· ·"no fly" list.· This is what it's about, Your Honor.
12· · · · · ·THE COURT:· The Court will affirm the
13· ·tentative ruling.· Do what you need to do, Mr.
14· ·Waszczuk.
15· · · · · ·MR. WASZCZUK:· I appreciate, Your Honor, if
16· ·you cancel those sanctions.
17· · · · · ·THE COURT:· I cancelled $60.00 of them.
18· · · · · ·MR. WASZCZUK:· I'm on social security, Your
19· ·Honor.
20· · · · · ·THE COURT:· I'm not saying they can collect
21· ·them.· I'm saying that they are entitled to them
22· ·procedurally.
23· · · · · ·MR. WASZCZUK:· I don't want to file a motion
24· ·for reconsideration and go to Court of Appeal.
25· · · · · ·THE COURT:· I understand.· Thank you.
26· · · · · ·MR. WASZCZUK:· The Court harasses my old lady.
27· ·This is what it is.
28· · · · · ·(End of Proceedings.)

County of Sacramento 10-11-2019 8:37AM
July 19, 2019 Page 12
·1· · · · · ·CERTIFICATE OF OFFICIAL SHORTHAND REPORTER
·2· ·State of California· )

· · · · · · · · · · · · · )· ss.
·3· ·County of Sacramento )
·4· · · · · I, LAURI GALLAGHER, hereby certify that I am a
·5· ·Certified Shorthand Reporter and that I recorded
·6· ·verbatim in stenographic writing the proceedings had
·7· ·JULY 19, 2019, in the matter of the Waszczuk vs. The
·8· ·Regents, Case Number 2013-00155479, completely and
·9· ·correctly to the best of my ability; that I have caused
10· ·said stenographic notes to be transcribed into
11· ·typewriting, and the foregoing pages 1 through 11
12· ·constitute a complete and accurate transcript of said
13· ·stenographic notes taken at the above-mentioned
14· ·proceedings.
15· · · · · ·I further certify that I have complied with
16· ·CCP 237(a)(2) in that all personal juror identifying
17· ·information has been redacted, if applicable.
18· · · · · Dated:· October 8, 2019.
19
20
21
22· · · · · · · · · · · · · · ·LAURI GALLAGHER, CSR No. 8726
23
24· · · · · · · · · · · · · · ·--oOo--
25
26
27
28

July 19, 2019 ·Index: $20,000..faith
BROWN 2:5
$ 8 D
C
$20,000 11:4 8 7:11 Daniel 2:10
$60.00 11:17 8th 6:14 8:18 California 2:6 4:26 DAVID 2:5
8:14
day 2:5 11:6
- A cancel 11:16
Debtor 4:5
cancelled 11:17
--ooo-- 2:2 accounts 7:25 11:8,9 December 11:7
caption 3:5,8
action 5:13 decide 9:15
1 care 6:18
admit 7:22 declaration 3:23 5:6
case 2:4 11:5
1 2:9 affirm 11:12 declare 4:25
Chilcott 3:2
19 2:1 amended 4:21 Defendant 2:4
civil 8:2
answers 3:23 6:4,9,15, defendants 2:11,20
2 19 7:23 10:7,9 cleaned 11:9 3:10 5:12 6:1
anti-slapp 2:20 6:1 code 9:10 denied 5:18

2 11:7
Appeal 11:24 collect 11:20 department 2:7 9:11,
2013-00155479 2:4 12,13,18
apply 2:14 compel 3:3
2015.5 4:28 direct 4:2
argument 3:28 4:1 complaints 8:23,24
2019 2:1 discoveries 10:5
assets 8:7,14 complete 8:21
21 4:11 discovery 3:6 5:25 9:8
assist 7:3 comply 8:3
10:24
26 7:1
assistance 7:1 concern 8:6
documents 4:5 6:26
attached 3:22 concluded 9:16 7:5,15 8:19 9:2
3
awarded 10:26 contained 8:7 dollar 2:13 3:10
3rd 5:16 copy 5:1 6:22 dollars 7:25
B correct 2:22 3:4,7,15
4 4:14,17,27 5:4,5 E
back 10:18 11:10
counsel 2:24,28
4-12-2019 7:1 enacted 8:2
bad 6:9 8:17
County 2:7
43 9:12,13,18 end 6:25 7:10 11:28
bank 7:25
couple 2:12 6:12 10:15
Bardzell 2:10,13,15,19, entitled 11:21
5 court 2:3,6,9,12,16,21,
22,26 3:4,7,12,16,22,24 examination 8:21,26
4:1,10,14,18 5:2,5,9,26, 23,27 3:5,9,14,18,25
4:6,12,15,20 5:3,8,15, 9:25
53 2:7 9:11 28 6:11,13,24 7:22 8:5,
19,22,26 9:27 10:13 18,22,25 6:3,8,15,17, exempt 2:15
18,19,21 7:3,8,14,19
6 behalf 2:17,19 3:1 5:28 8:9,20,21,25,27 9:4,7, Exhibit 3:24 4:24 6:21,
13,18,21,25,28 10:4,15 23,25
beneficiary 10:26
6 4:4,6 11:1,2,12,17,20,24,25, exhibits 3:23
Blizzard 9:20 26
60 2:13 3:9 explain 8:18
bonds 7:26 crafted 11:6
7 bottom 6:23 F
Boyd 3:1
7 6:27 7:1,3 faith 8:11

July 19, 2019 ·Index: fare..reconsideration
fare 9:8 inquire 8:12 money 5:21 11:7 piece 3:15 8:15
February 6:14 8:18 inquiry 8:11 motion 2:17,19,26,28 point 6:2 8:3,5
3:2 5:17,18,28 6:22
fee 2:13 3:10,13,17 interrogatories 10:6 pointed 6:12
11:5,6,23
fees 10:24,26,27 Item 2:9 Porter 2:10
motions 4:16
file 4:21 10:7 11:5,23 post 3:6 5:25
J
filed 5:28 N pretty 6:10 10:9
filing 2:13 3:10,13,17 jewelry 7:24 previous 10:25
5:17 Nichols 3:2
job 6:9 previously 4:15
fly 11:11 number 2:4 4:10
judge 2:5 8:23 9:11,12, prior 11:3
foregoing 4:27 14,15,16,19,20
O privacy 4:13
front 4:19 6:22 9:23 judgment 3:6 4:5 5:25, privileged 4:12
27 8:15 O.X. 8:25
problem 4:22 10:3
G JULY 2:1 object 8:16 10:8,20
problems 5:3
jurat 4:28 objected 8:4 10:19
gave 6:13 9:22 procedurally 11:22
give 4:6 7:15 9:26 objection 4:3
K procedures 8:2
good 6:10 8:11 10:9 objections 3:26 4:16,
19,20,22 6:5,12 7:21 proceeding 5:14
graceful 9:9 knew 11:9
October 5:16 proceedings 2:8 11:28
granted 4:16 product 4:13
L offered 11:4
guess 7:10 production 4:5,10 6:26
omitted 10:12
guy 9:24 lady 11:26 7:4 8:19 9:1 10:7
opposed 3:16
law 8:14 property 7:23
H order 8:21 9:25 10:19
laws 4:26 protected 4:12
ordered 4:16
happy 6:10 lawyer 10:25 11:3,7 provide 4:23 6:4
Oropeza 3:2
harasses 11:26 legal 10:23,26,27 provided 3:21 4:25
outright 8:8
Hey 10:13 legislature 8:2 providing 10:20
Honor 4:2 5:11,13,21 letter 10:25 P pull 11:7

6:17 7:12 9:27 10:13,28 liable 8:15
11:11,15,19 papers 2:26,27 3:22 Q
list 11:11
Honorable 2:5 part 3:21 4:1
looked 3:20 question 3:19 9:2
parties 8:22
I questions 2:12 5:9
M pay 2:14 3:11,13 10:23, 8:20
24
important 9:12
made 2:17,19,28 penalty 4:25 5:23 6:5 R
improper 3:7
major 8:6 7:28 10:10
include 4:25 read 6:9
make 4:7 8:10 10:17 people 9:7
individual 3:10 real 7:23
matter 2:3 perjury 4:26 6:6 7:28
individuals 2:21 3:1 10:10 recognize 7:19
methods 9:8
information 9:22 permitted 9:10 reconsideration
moment 4:6 9:26
11:24

July 19, 2019 ·Index: refer..wrote
refer 8:7 starting 4:7
W
refusals 8:8 State 2:6 4:26
refuse 10:8,21 stocks 7:26 wanted 9:23
Regents 2:4,15,16,18, stuff 9:9,17 Waszczuk 2:3 3:21
24,28 4:8,21 5:10,11,16,20,
submitted 6:28
register 5:13 24,27 6:4,7,13,16,17,20
substantive 7:23 7:2,7,12,18 8:18 9:1,6,
regularly 2:5 11,15,20,22,28 10:2,12,
Superior 2:6
released 8:22 23 11:3,14,15,18,23,26
supposed 5:23
repeating 9:3,6 words 2:14
request 3:6 4:5,10 7:4 T work 4:12

10:6 wrong 7:14
respond 8:8 10:4 tab 6:23 wrote 8:19 9:1
response 4:4 6:26 talking 3:20 7:13
responses 3:3,21 telling 10:18,19

4:21,24 7:4 8:6,28 tells 10:20
retainer 11:8 tentative 6:2 11:13
ruling 4:18 6:2 11:13 terminating 5:19,26
termination 5:17,21
S
Thanksgiving 11:4,6
Sacramento 2:7 thing 3:25
sanction 3:15 5:17 things 9:5 10:15,18,21
sanctions 5:19 11:16 time 10:11
Scott 2:11 true 4:27
security 11:18
U
Seifert's 3:2
service 5:6 underneath 7:9
show 6:24 understand 2:17 3:1
sign 4:28 5:6 6:5,11,15, 5:20 11:25
19 7:16,17,18,27,28 understanding 3:12
8:1,4 10:10,14,17
understands 4:8
signature 3:27 7:6,8,
10,16 understood 5:24
signed 5:1,5
V
sir 5:1
sitting 3:20 vacate 3:14
SLAPP 11:5,6 vacating 3:17
social 11:18 verification 3:28 4:23
5:7
spouse 8:7
spouse's 8:14

EXHIBIT # 26
EXHIBIT # 27
EXHIBIT # 29
EXHIBIT # 33
Derek J. Haynes, SBN 264621
• 3 Aifianda L. Her, SBN 300268
Daniel J. Bardzell, SBN 313993
FILED/ENDORSED
Sacramento, Califomia 95825 DEC - 6 2019
5 TEL: 916.929.1481
By: E. IVIedina
FAX: 916.927.3706
6 ueputy Citm

8
9 Attorneys for Judgment Creditors/Former Defendants
MICHAEL BOYD, STEPHEN CHILCOTT, DANESHA NICHOLS, CINDY OROPEZA, and BRENT
10 SEIFERT
Exempt From.Filing Fees Pursuant to Government Code § 6103
11
13
14 JAROSLAW ("JERRY") WASZCZUK, CASENO. 34-2013-00155479
15 Plaintiff, REPLY TO UNTIMELY OPPOSITION TO

MOTION TO COMPEL RESPONSES TO
16 JUDGMENT DEBTOR
17 INTERROGATORIES AND REQUEST
THE REGENTS OF THE UNIVERSITY OF FOR PRODUCTION OF DOCUMENTS;
18 CALIFORNIA, et al., AND FOR MONETARY SANCTIONS
19 Defendants. Date: December 13, 2019
20 Time: 2:00 p.m.
Dept.: 53
21
Corhplaint Filed: December 4, ,2013
24
25
26
27
28
{02II7245.DOCX}
REPLY TO UNTIMELY OPPOSITION TO MOTION TO COMPEL RESPONSES TO JUDGMENT DEBTOR
INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS;
AND FOR MONETARY SANCTIONS
1 I.
2 INTRODUCTION
3 Judgment Creditors/Defendants have now filed three Motions to Compel Judgment
4 Debtor/Plaintiff JAROSLAW ("JERRY") WASZCZUK to provide compliant responses to Judgment
5 Debtor Interrogatories and Judgment Debtor Request for Production of Documents. All such Motions
6 have been granted, yet Judgment Debtor/Plaintiff still refuses to provide those responses. His most-
7 recent responses are identical to those this Court found deficient in ruling on the prior Motion.
8 That forced Judgment Creditors/Defendants to file the instant Motion to Compel and Request for
9 Monetary Sanctions. Judgment Debtor/Plaintiff failed to file a timely Opposition to the Motion. As a
10 result. Judgment Creditors/Defendants filed a notice of non-opposition. Thereafter, Judgment
11 Debtor/Plaintiff filed an untimely Opposition. Judgment Creditors/Defendants submit the Court should
12 disregard that Opposition as untimely. However, even i f the Court considers the Opposition, Plaintiff
13 concedes in that document that he has "no arguments" other than those the Court already rejected in
14 granting the prior Motions to Cornpel.
15 Judgment Debtor/Plaintiffs current Opposition is instead replete with incoherent and nonsensical
16 assertions that counsel for Judgment Creditors is engaging in extortion. Although unclear, it appears
17 Judgment Debtor/Plaintiffs assertions focus on an underlying Order from this Court where the Court
18 awarded Defendants the attorney's fees they incurred in successfully pursuing an Anti-SLAPP Motion.
19 Judgment Debtor/Plaintiff argues that three other lawyers from defense counsel's firm worked on that
20 motion, not the current lawyers. Judgment Debtor's email correspondence attached as Exhibit 5 to his
21 Opposition also claims that any fees that are paid must be paid to the individual Defendants who
22 prevailed on the Anti-SLAPP Motion and not to Defendant REGENTS OF THE UNIVERSITY OF
•23 CALIFORNIA (herein "REGENTS"), who paid for those fees.
24 Those arguments, however, are entirely irrelevant to the pending Motion, which merely argues
25 that Judgment Debtor/Plaintiff failed to provide adequate responses to discovery requests. Judgment
26 Debtor/Plaintiff does not dispute that issue, nor can he given the responses are identical to the ones the
27 Court previously found deficient.
28 For these reasons and the reasons set forth in Judgment Creditors' moving papers, Judgment
{02117245 DOCX) 2
1 Creditors' Motion should be granted. Judgment Creditors also respectfully request that the Court award
' 2 sanctions for Judgment Debtor's repeated abuse of the discovery process and disregard of previous court
3 orders. In addition. Judgment Creditors respectfully request the Court clarify that the REGENTS is
4 entitled to the payment of sanction awards as the REGENTS is incurring the costs associated with the
5 litigation against Judgment Debtor.
6 II.
7 JUDGMENT DEBTOR'S OPPOSITION SHOULD BE DISREGARDED BECAUSE IT WAS
8 UNTIMELY
9 Judgment Debtor's Opposition to the instant Motion was due on December 2, 2019. (Declaration of
10 Amanda L. Her [herein "Her Decl."], ^ 2.) On December 4, 2019, after no Opposition had been served or
11 even filed, Judgment Creditors filed a Reply to Plaintiffs Non-Opposition to Defendaiit's Motion to
12 Compel Responses to Judgment Debtor Interrogatories and Request for Production of Documents; and
13 for Monetary Sanctions. (Her Decl., ^ 3; Exhibit A, Reply to Plaintiffs Non-Opposition) Shortly
14 thereafter, counsel for Judgment Creditors received notification that Judgment Debtor filed an
15 Opposition. Counsel for Judgment Debtor then downloaded the relevant documents from the Court's
16 website. (Her Deck, ^ 4.) The proof of service indicated Judgment Debtor served the Opposition by mail,
17 even further delaying Judgment Creditors' receipt of Judgment Debtor's already untimely response. (Her
18 Deck, t 5.)
19 In his Opposition, Judgment Debtor completely fails to acknowledge that he failed to file a
20 timely Opposition under Code of Civil Procedure section 1005(b). He does not offer any excuse, reason,
21 or authority for his actions. As such, the Judgment Creditors respectfully request that the Court exercise
22 its authority under Califomia Rules of Court, Rule 3.1300, refuse to consider Judgment Debtor's
23 untimely Opposition, and preclude Judgment Debtor from making any oral argument. (Bozzi v.
24 Nordstrom, Inc. (2010) 186 Cal.App.4th 755, 765 [the Court properly refiased to consider plaintiffs
25 untimely papers where plaintiff did not invoke any of the available procedures to obtain a court order
26 permitting late filing].)
27 Ill
28 III
{021I7245.DOCX} 3
1 III.
2 JUDGMENT CREDITORS' MOTION SHOULD BE GRANTED BECAUSE JUDGMENT
3 DEBTOR DID NOT HAVE SUBSTANTIAL JUSTIFICATION FOR OPPOSING IT
4 Judgment Debtor offers no legal basis in his Opposition for his failure to, once again, provide
5 compliant discovery responses in a timely manner. In fact, he outright admits that he "has no fiirther
6 argument" beyond those arguments that the Court rejected in granting Judgment Creditors' earlier
7 Motions.
8 Rather than responding to the arguments Judgment Creditors set forth supporting their contention
9 that Judgment Debtor should be compelled to provide further discovery responses and that the Court
10 should award sanctions, Judgment Debtor instead makes conspiracy theory-type arguments about
11 counsel for Judgment Creditors extorting money from him.
12 As set forth in Judgment Creditors' moving papers, this is the third Motion Judgment Creditors
13 have been forced to file in attempting to collect the judgments owed in this case. This Court has now
14 ordered Judgment Debtor multiple times to serve fiarther verified responses to the Judgment Debtor
15 Interrogatories and Judgment Debtor Requests for Production without objection. {See Declaration of
16 Daniel Bardzell in Support of Further Motion to Compel [herein "Bardzell Decl."] 15, 21 and
17 Exhibits K and O attached thereto) He has not done so, choosing instead to serve verified versions of the
18 identical responses this Court previously deemed insufficient. Even more egregious is the fact that
19 Judgment Debtor acknowledged in an email that he does have responsive documents, but refused to
20 provide them except for in a face-to-face meeting.' (Bardzell Deck, t 28 and Exhibit V) Judgment
21 Creditors are not required to acquiesce to such a request. When counsel for Judgment Creditors
22 communicated as much to Judgment Debtor, he responded by urging Judgment Creditors to file the
23 instant motion—conduct that continues to violate this Court's orders. (Bardzell Decl. \ 30 and
24 Exhibit X)
25 Judgment Debtor should be sanctioned for opposing this Motion without substantial justification.
26 (Code of Civil Procedure sections 2030.290(c) [interrogatories] & 2031.300(c) [production requests].)
27
28 ' Ttiis is just another effort in Plaintiffs long-line of efforts to intimidate and threaten defense counsel, the same type of
conduct that resulted in his termination from the University.
{02117245 DOCX) ; 4
1 He has offered no legal basis for his failure to timely respond, or even for his failure to respond to the
2 numerous meet and confer attempts that Judgment Creditors have engaged in, as detailed in the moving
3 papers. Judgment Debtor's brazen defiance of multiple Court orders to serve fijrther discovery responses
4 is an unquestionable misuse of the discovery process for which monetary sanctions should be awarded.
5 (Code Civ. Proc. §§ 2023.010(g); 2023.030 (a).) Judgment Creditors request an award of $5,460.00 as
6 set forth in the moving papers.
7 IV.
8 DEFENDANT REGENTS IS ENTITLED TO PAYMENT OF SANCTIONS AWARDS
9 Judgment Debtor indicates in his Opposition and supporting exhibits that the REGENTS and
10 defense counsel are not entitled to the sanctions and fees awarded to date. (Opposition to Motion to
11 Compel Filed on October 23, 2019, pp. 4-5) In a November 21, 2019 email correspondence to counsel
12 for the REGENTS and Judgment Creditors, Judgment Debtor wrote, "As I advised you a few days ago,
13 the UC Regents should not cash the $1,300 check I sent to your office on November 18, 2019. The UC
14 Regents are not the party of the anti-SLAPP motion filed by Porter Scott's fomier attomey Michael Pott
15 on December 1, 2014." (Opposition, Exhibit 5.) Judgment Debtor goes on to offer to write individual
16 checks in the amount of $260.00 to each Judgment Creditor and insinuates he either has or will file a
17 complaint with the State Bar related to this issue.
18 Judgment Debtor has cited no legal authority for his position that the REGENTS are not entitled
19 to the sanction payment. The REGENTS has paid for the defense ofthe Judgment Creditors. (Her Decl. ^
20 6.) "A monetary sanction may be based not only on attomey's fees and costs, but also on any other
21 reasonable expenses incurred.'" {Argaman v, Ratan (1999) 73 Cal.App.4''^ 1173, 1179 [emphasis added].)
22 As the REGENTS has incurred the expense of the Special Motion to Strike and subsequent discovery
23 proceedings associated with collecting the judgment, the REGENTS is the proper recipient of the
24 sanction payments. Judgment Creditors respectfully request the Court clarify for Judgment Debtor that
25 the REGENTS is entitled to the payment of sanction awards so that Judgment Debtor does not continue
26 to use that as an excuse for not paying the amounts owed.
27
111 •
28
III
(02117245 DOCX) . ^5 ^
1 V. .
2 CONCLUSION
3 Based on the foregoing, Judgment Creditors respectfully submit that their Motion to Compel
4 Responses to Judgment Debtor Interrogatories and Requests for Production of Documents; and for
5 Monetary Sanctions should be granted.
6
7 Dated: December 6, 2019 PORTER SCOTT
A PRCIFESSIONA TION
8
9
10 )erek J. Haynes
Âmanda L. Her
Attomeys for Judgment Creditors/Former
12
Defendants
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
{02117245.DOCX}
1
2
3 PROOF OF SERVICE
.5
6 On the date below, I served the following document: REPLY TO UNTIMELY OPPOSITION
TO MOTION TO COMPEL RESPONSES TO JUDGMENT DEBTOR INTERROGATORIES
7 AND REQUEST FOR PRODUCTION OF DOCUMENTS; AND FOR MONETARY
SANCTIONS
8
9
attomey being served, with a receptionist or an individual in charge of the office, between the hours of nine
13 in the moming and five in the evening. (2) For a party, delivery was made to the party or by leaving the
documents at the party's residence with some person not younger than 18 years of age between the hours
14 of eight in the moming and six in the evening.
BY OVERNIGHT DELIVERY: I enclosed the documents in an envelope or package provided by an
15 ovemight delivery carrier and addressed to the person(s) listed below. I placed the envelope or package for
collection and ovemight delivery at my office or a regularly utilized drop box of the ovemight delivery
16 carrier.
18 BY ELECTRONIC SERVICE: Based on a court order or an agreement of the parties to accept service by
electronic transmission, I caused the documents to be sent to the persons at the electronic notification
20 JAROSLAW WASZCZUK
21 2216 KATZAKIAN WAY
LODI, CA 95242
22
23 I declare under penalty of perjury under the laws of the State of California that the foregoing is
true and correct. Executed at Sacramento, California on December 6, 2019.
24
25
Cindy A<3bndinetti
26
27
28
(02117245.DOCX)
EXHIBIT # 34
MINUTE ORDER
DATE: 12/13/2019 TIME: 02:00:00 PM DEPT: 53
CLERK: E. Brown
REPORTER/ERM:

APPEARANCES
TENTATIVE RULING
Judgment Creditors Boyd, Chilcott, Nichols, Oropeza, and Seifert (collectively, "Judgment Creditors")
Creditors' special motion to strike Plaintiff's causes of action and entered judgment in favor of Judgment
of $22,284. (See ROA 219.)
motions to compel related to the discovery on April 26, 2018, and July 19, 2019. In both rulings,
29, 2019. (Bardzell Decl. ¶ 22, Exh. P.) Counsel for Judgment Creditors sent correspondence on August
(Id. ¶ 23, Exh. Q.) The parties continued to meet and confer. Judgment Debtor served verified responses
provided responses with the only difference being that he provided a properly executed verification for
each response." (Mot. at 8, citing Bardzell Decl. ¶ 26, Exh. T.) The parties continued to meet and confer

responses, without objections, to the subject discovery.

Judgment Debtor/Plaintiff submitted a late-filed opposition to the motion but it largely does not address
the relevant issues in the motion. The opposition does include, in relevant part: "The Plaintiff has no
further argument or other arguments other than the Plaintiff already provided to the Court in his previous
opposition sand [sic] in the exhibits, attached to this opposition especially in the Plaintiff's November 18,
2019, response titled Re: Blackmail Sanctions to Porter Scott Attorney Daniel Bardzell 11/11/2019."
Judgment Creditors are entitled to the previously-ordered further Code-compliant verified responses,
without objection.
Conclusion
Judgment Debtor/Plaintiff is again ordered to serve Code-compliant further verified responses to the
Judgment Debtor Interrogatories, Set One, and Request for Production, Set One, without objections, on
or before December 23, 2019.
The Court yet again cautions Judgment Debtor/Plaintiff that compliance with a facially-valid
court order is mandatory. (See, e.g., In re Brambini (1923) 192 Cal. 19, 28-32; see also In re Berry
(1968) 68 Cal.2d 137, 147.)
Judgment Debtor/Plaintiff is also ordered to pay reasonable monetary sanctions to the moving parties in
the amount of $1,300 (5 hours at the hourly rate of $260), for the fees incurred since the Court's last
order compelling further responses to the same discovery. The opposition was filed without substantial
justification. The monetary sanctions are to be paid on or before January 13, 2019. If those sanctions
are not paid by that date, the moving parties may prepare a formal order on the sanction award, which
may thereafter entered as a separate judgment. (See Newland v. Superior Court (1995) 40 Cal.App.4th
608.)
notice is required.
COURT RULING

EXHIBIT # 35
MINUTE ORDER
DATE: 12/17/2019 TIME: 02:00:00 PM DEPT: 53
CLERK: E. Brown
REPORTER/ERM:

APPEARANCES

TENTATIVE RULING
of $22,284. (See ROA 219.)


without objection.
Conclusion
(1968) 68 Cal.2d 137, 147.)
608.)
notice is required.
COURT RULING
JAROSLAW WASZCZUK
2216 KATZAKIAN WAY
LODI, CA 95242
DANIEL J. BARDZELL
PORTER SCOTT

EXHIBIT # 36
EXHIBIT # 37
FILED/ENDORSED
TEL: 916.929.1481 By: -E. Medina
6
9
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SACRAIVIENTO
10
12
o Plaintiff, EX PARTE APPLICATION FOR LEAVE
o
13 TO EXTEND PAGE LIMIT FOR
r- 3 00 —
0\
V. DEFENDANT'S MOTION FOR
O V 14 SUMMARY JUDGMENT OR, IN THE
O 2
15 THE REGENTS OF THE UNIVERSITY OF ALTERNATIVE, SUMMARY
pi. 2 S
CALIFORNL\, UNIVERSITY OF ADJUDICATION
hi ^ 16 CALIFORNL\ DAVIS HEALTH SYSTEM,
O
a. UC DAVIS MEDICAL CENTER, UC
3 t/>
PUTNEY, DORIN DANE.IUC, and Does 1
20 through 50, inclusive. Complaint Filed: December 4, 2013
22
LL,
23
24
25
26
27
28
{0241.19S2.DOCX} 1
1 I.
3 Defendant THE REGENTS OF THE UNIVERSITY OF CALIFORNIA ("UNIVERSITY")
4 hereby submits this Ex Parte Application for permission to file a Memorandinn of Points and
5 Authorities in support of its Motion for Summary Judgment or, in the altemative. Summary
6 Adjudication in excess of twenty pages pursuant to Rules 3.1113(e) and 3.1200 et seq. of the
7 Califomia Rules of Court. Rule 3.1113(e) allows a party to apply to the court for permission to file a
10 Memorandtun of Points and Authorities exceed twenty pages to adequately address the factual and
11 legal issues presented by the motion.
12 IL
o
o
r-i
B >n 13 MEMORANDUM OF POINTS AND AUTHORITIES j
i _ •= rM
r " 3 00 — VO
r - I'l <n 00 o
O —. m 14 IN SUPPORT OF EXTENSION OF PAGE LIMIT
c^ 15
a: < d vd vd Defendant intends to move for summary judgment or, in the alternative, summary
Ov Ov
-i >< 16
l i3e(/I Wf- u.< adjudication as the following causes of action: 1) harassment in violation of FEHA and failure to
17
o prevent harassment, discrimination, and retaliation in violation of Govemment Code § 12940(a); 2)
18
whistleblower/unlawful retaliation in violation of Govemment Code § 8547; 3) retaliation under
19
Health and Safety Code § 1278.5; 4) breach of written contract; 5) wage and hour misclassification;
20
and 6) rescission-unlawful contract. (Declaration of Lindsay A. Goulding in support of Defendant's
21
ExParte Motion for Leave to File Motion for Summary Judgment that Exceeds 20 Pages ("Goulding
22
Decl. 13.) The Motion for Summary Judgment/Adjudication will necessarily require a detailed
23
24
harassment of Plaintiff fi-om 2006 to 2013, as well as the individual defenses applicable thereto.
25
26 (Id.) The circumstances surrounding die allegedly harassing conduct will also require a detailed
27 discussion regarding the nature of the conduct, the timing, and the speakers and recipients of the
28 alleged harassment. (Id.) Further, a lengthy legal analysis will be required to address Plaintiffs
{0241.1952.DOCX} 2
previous settlement agreement with Defendant. (Id.)
In order to address the lengthy facts, legal authority, and legal arguments regarding each of
3 Plaintiffs causes of action. Defendants' Memorandum of Points and Authorities in support of its
5 Defendants respectfully request that the court, pursuant to Rules 3.113(e) and 3.1200 et seq. of the
6 Califomia Rules of Court, allow it to submit a Memorandum of Points and Authorities in excess of
9 III.
10 CONCLUSION
11 For the reasons set forth above. Defendant has demonsttated good cause for an expansion
o
o
f- 3 g — VO
i- i/i 00 o
O — m 14
cC [--•
r-j <N
a: < d
O ; Ov_
vd 15 Dated April 22, 2021 PORTER SCOTT
O ov A PROFESSIONAL CORPORATION
- j >< 16
o •I "mf- u.<
3 t/i
o 17
in
18 By.
Lindsay A. Goulding
20
21
22
23
24
25
26
27
28
{02413952.DOCX}
Waszczuk V. Regents ofthe University of California, et al
1
2
3 PROOF OF SERVICE
5

8 EXCEEDS 20 PAGES
9
U course of business with the United States Postal Service, in a sealed envelope with postage fiilly prepaid.
o
13 served, with a receptionist or an individual in charge of the office, between the horns of nine in the morning
-s — VD and five in the evening. (2) For a party, delivery was made to the party or by leaving the documents at the
c/i ? ! 00 O
O — m 14 party's residence with some person not yoxmger than 18 years of age between the hours of eight in the
U ov moming and six in the evening.
!/3 5; u
ad < ^
ov Ov 15 BY OVERNIGHT DELIVERY: I enclosed the documents in an envelope or package provided by an
d ^ ^
pJ 5> c bv Ov ovemight delivery carrier and addressed to the person(s) listed below. I placed the envelope or package fbr
16 collection and ovemight delivery at my office or a regularly utilized drop box of the ovemight delivery
o li carrier.
a. 17 BY FAX TRANSMISSION: Based on an agreement of the parties to accept service by fax transmission, I
o
•n
18 machine that I used. A copy of the record of the fax transmission, which I printed out, is attached
listed below.
20
21 Jaroslaw Waszc2juk
2216Katzakian Way
22 Lodi, CA 95242
JJW1980@LrVE.COM
23
25 is tme and correct. Executed at Sacramento, Califomia on April 26, 2021.
26
27
28 Virginia Yao
{0241.1952.DOCX}
L:: U„ r;:^J
o
1
2
TEL: 916.929.1481
5 FAX: 916.927.3706
6

9
10
11 JAROSLAW (“JERRY”) WASZCZUK, CASE NO. 34-2013-00155479
12
Plaintiff, DECLARATION OF LINDSAY A.
PORTER | SCOTT
FAX: 916.927.3706
TEL: 916.929.1481
v. DEFENDANT’S EXPARTE FOR LEAVE

14 TO FILE MOTION FOR SUMMARY
15 THE REGENTS OF THE UNIVERSITY OF JUDGMENT THAT EXCEEDS 20 PAGES
CALIFORNIA, UNIVERSITY OF
UC DAVIS MEDICAL CENTER, UC
WITCHER, DANESHA NICHOLS, CINDY Amended Complaint Filed: June 16, 2014
20
21
Defendants.
22 _____________________________________/
25 and am a partner with the law firm of Porter Scott, attorneys of record for Defendant REGENTS OF
26 THE UNIVERSITY OF CALIFORNIA (“Defendant” or “UNIVERSITY”). I state the facts herein
27 of my own personal knowledge and, if called upon as a witness, I could and would competently
28 testify thereto.
{02413956.DOCX} 1
DECLARATION OF LINDSAY A. GOULDING IN SUPPORT OF DEFENDANT’S EXPARTE FOR LEAVE
8 adjudication as to the following causes of action: 3) harassment in violation of FEHA and failure to
13 necessarily require a detailed discussion of the nature of Plaintiff’s employment relationship with
PORTER | SCOTT
FAX: 916.927.3706
TEL: 916.929.1481
14 Defendant, the alleged harassment of Plaintiff from 2006 to 2013, as well as the individual defenses
15 applicable thereto. The circumstances surrounding the allegedly harassing conduct will also require
16 a detailed discussion as to the nature of the conduct, the timing, and the speakers and recipients of
17 the alleged harassment. Further, a lengthy legal analysis will be required to address Plaintiff’s
20 each of Plaintiff’s causes of action, Defendants’ Memorandum of Points and Authorities in support
22 5. I contacted Plaintiff to inform him of this Application via telephone and email on
24 of my email correspondence to Plaintiff regarding Defendant’s request to exceed the page limit.
27 L
28
Lindsay A. Goulding
{02413956.DOCX} 2
EXHIBIT
“A”
01054547.WPD
From: Virginia Yao
To: JJW1980@LIVE.COM
Cc: Lindsay A. Goulding; Tomi Aina
Date: Monday, April 26, 2021 8:59:00 AM
Attachments: image001.png
Dear Mr. Waszczuk:
This is just to confirm our conversation this morning that our office is filing an Exparte
today on the papers to request a page extension to the Motion for Summary of
Judgment that we will be filing. Thank you.
Virginia Yao
Legal Assistant to Lindsay A. Goulding
350 University Avenue | Suite 200 | Sacramento, CA 95825
T| 916.929.1481 x 331 F| 916.927.3706
www.porterscott.com
Waszczuk v. Regents of the University of California, et al.
1
2
PROOF OF SERVICE
3
5
7 DECLARATION OF LINDSAY A. GOULDING IN SUPPORT OF

DEFENDANT’S EXPARTE FOR LEAVE TO FILE
8 MOTION FOR SUMMARY JUDGMENT THAT EXCEEDS 20 PAGES
9
10 am readily familiar with this business’ practice for collecting and processing correspondence for mailing.
12 below. (1) For a party represented by an attorney, delivery was made to the attorney or at the attorney’s
office by leaving the documents, in an envelope or package clearly labeled to identify the attorney being
13 served, with a receptionist or an individual in charge of the office, between the hours of nine in the morning
PORTER | SCOTT
FAX: 916.927.3706
TEL: 916.929.1481
14 party’s residence with some person not younger than 18 years of age between the hours of eight in the
morning and six in the evening.
overnight delivery carrier and addressed to the person(s) listed below. I placed the envelope or package for
16 collection and overnight delivery at my office or a regularly utilized drop box of the overnight delivery
carrier.
listed below.
20
2216 Katzakian Way
22 Lodi, CA 95242
JJW1980@LIVE.COM
23
is true and correct. Executed at Sacramento, California on April 26, 2021.
25
26 v
27 ___________________________________
Virginia Yao
28
{02413956.DOCX} 3
TEL: 916.929.1481 Bv: D. JOHNSON-MELLADQ
5 FAX: 916.927.3706 DEPUTY CLERK
6
7 REGENTS OF THE UNrVERSITY OF CALIFORNL\
8 Exempt From Filing Fees Pursuant io Government Code § 6103
9
10
II
JAROSLAW ("JERRY") WASZCZUK, CASENO. 34-2013-00155479
12
o Plaintiff, tJatOPOOflPf^ ORDER ON
o
i i w-i
13 DEFENI^ffiST'S EX PARTE
— VO
00 o
14 APPLICATION FOR LEAVE TO
— m
EXTEND PAGE LIMIT FOR
15 THE REGENTS OF THE UNIVERSITY OF DEFENDANT'S MOTION FOR
. oi < 6
CALIFORNIA, UNIVERSITY OF SUMMARY JUDGMENT OR, IN THE
« 5; g 16 CALIFORNL\ DAVIS HEALTH SYSTEM, ALTERNATIVE, SUMMARY
o ADJUDICATION
C a
o
in DAVIS, ANN MADDEN RICE, MIKE
18 BOYD, STEPHEN CHE.COTT, CHARLES
19 OROPEZA, BRENT SEIFERT, PATRICK Complaint Filed: December 4, 2013
20 PUTNEY, DORIN DANILIUC, and Does 1 Amended Complaint Filed: June 16, 2014
through 50, inclusive. SAC Filed: September 30, 2014
21
Defendants.
22
23
24 /
25 An Ex Parte Application for an order permitting Defendant THE REGENTS OF THE

26 UNIVERSITY OF CALIFORNL\ to file a Memorandum of Points and Authorities in Support of
their Motion for Summary Judgment or, in the Altemative Summary Adjudication exceeding 20
{024^4532.DOCX} 1
, gjPROPOSED] ORDER ON DEFENDANT'S EX PARTE APPLICATION TO EXTEND PAGE

Ex Parte Application and found good cause to grant Defendant's request for a page extension.
IT IS THEREFORE ORDERED THAT Defendant THE REGENTS OF THE
UMVERSITY OF CALIFORNIA shall be permitted to file a Memorandum of Points and
Authorities in Support of its Motion for Summaiy Judgment, or in the Altemative, Summary
Adjudication in excess of 20 pages, but not to exceed 40 pages.
Dated:
APR 2 7 2021
SHAMA H. MESIWALA
10
11
12
o
o
L_ • = (N
13
— \o
,t- t/) K oo o
O !^ 14
^ i< — a. 15
vd >f>
Ov ov
w <
16
o
<n
17
m
18
19
20
21
22
23
24
25
26
27
28
{02414532.DOCX}
[PROPOSED] ORDER ON DEFENDANT'S EX PARTE APPLICATION TO EXTEND PAGE

EXHIBIT # 38
2216 Katzakian Way
Lodi, CA 95242
Phone: 209-663-2977
Fax: 209-787-3131
April 27, 2021


Oakland, CA 94607
Subject: Case No. 34-2013-00155479, Jaroslaw Waszczuk v. The Regents of the

University of California, Ann Madden Rice, Mike Boyd, Stephen Chilcott,
Charles Witcher, Danesha Nichols, Cindy Oropeza, Brent Seifert, Patrick
Putney, Dorin Daniliuc
Re: Defendants Ex Parte Application for Leave to Extend Page Limit for Defendant's
Motion For Summary Judgment or, in The Alternative, Summary
Adjudication
Dear Ms. Goulding,
Yesterday, I asked you in which Court Department you filed your Ex Parte
Application for Leave to Extend Page Limit because you did not mark on the front
page of your pleadings which Court Department or which Judge would would
-1-
unprofessional.
predecessors in this case, two former Porter Scott attorneys, David Burkett and
against the Regents of the University of California, bypassed Judge David Brown
Krueger or a stamped Order with Judge Krueger’s name.
the Burkett and Bardzell’s Notice of Motion and Motion (ATTACHMENT #1) of
Documents were filed/endorsed by the same Deputy Clerk named E. Medina.
It seems to me that history is repeating itself and that Porter Scott’s new team of
-2-
YOUR MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT

In general, as a Plaintiff, I have no problem with the Ex Parte Application for

Extension of the Page Limit. However, I took a closer look at your application to
identify your justification for the Extension of the Page Limit.
#3), which reads as follows:
Defendant intends to move for summary judgment or, in the alternative,
summary adjudication as the following causes of action:
1) harassment in violation of FEHA and failure to prevent harassment,
The above No. 1 Cause of Action in your Memorandum of Points and Authorities
is actually the THIRD CAUSE of ACTION in the SAC (Page Nos. 48–49) and
does not require an Extension of the Page Limit because the THIRD COA was
removed from the SAC in 2015 by the Anti-SLAPP Motion, C.C.P § 425.16
Chilcott, and Brent Seifert.
2) whistleblower/unlawful retaliation in violation of Government Code §
8547
The above No. 2 COA in your Memorandum of Points and Authorities is actually
-3-
the FOURTH CAUSE OF ACTION in the SAC (Page Nos. 55–57) and does not
from the SAC in 2015 by the Anti-SLAPP Motion, C.C.P. § 425.16, granted by the
Court to the Defendants, Danesha Nichols, Mike Boyd, Stephen Chilcott, and Brent
Seifert.
3) retaliation under Health and Safety Code § 1278.5
This is actually the FIFTH CAUSE OF ACTION in the SAC (Page Nos. 55–
Amended Complaint which was blocked in October 2015 to be file by Burkett ,
Bardzell and Judge David Brown’s Order
This is actually the SIXTH CAUSE OF ACTION in the SAC, and it is the
discrimination and witch hunt of March 2011–December 2012, which has caused
the University of California’s pay policies and employee classification. I was
perfectly happy with my classification and wages, but U.S Senator Feinstein’s
in the United States Court Of Appeals For The District Of Columbia Circuit
-4-
(https://www.scribd.com/document/495490868/Jaroslaw-Waszczuk-v-IRS-
DISTRICT-OF-COLUMBIA-CIRCUIT).
6) rescission – unlawful contract
This is actually the EIGHTH CAUSE OF ACTION in the SAC. Regardless
Squad.
of the Plaintiff’s employment relationship with Defendant.
employee and had a normal relationship with my employer. I was hunted down by
Parte Application.
I fail to understand why Porter Scott’s attorney is making attempts to bring back
motion granted by the Court. Previously, David Burkett brought back the four dismissed
-5-
Danesha Nichols, and Brent Seifert. Please clarify whether these individuals are
together with first four COAs. Porter Scott Attorneys once brought them back in
I noticed that in your April 26, 2021 Ex Parte Application for Leave to Extend
the Page Limit for the Defendant’s Motion For Summary Judgment or, in the
Bardzell’s and other Porter Scott’s lawyers pleadings of 2018–2020. I am quite sure
hear about this lawsuit or about Porter Scott’s Attorneys anti-SLAPP motion dirty
old wife . Your first show off in this case did not go well for you Ms. Goulding . You
are dirty and unprofessional lawyer as same as your Porter Scott’s predecessors with
J.D degree and licenses from the State Bar of California .
Sincerely,
Jaroslaw Waszczuk,
-6-
Mailing List
Re: Waszczuk v. Regents of the University of California et al.

Hon. Clerk of the Court

Department 53 – Hon. Shama H. Mesiwala

Oakland, CA 94607

Vanessa Holton – The State Bar of California Interim Executive Director

80 Howard Street
-7-
EXHIBIT # 39
AT-138/EJ-125
ATTORNEY OR PARTY WITHOUT Ar?ORNEY; STATE BAR NO.:
FOR COURT USE ONLY
NAME: Lindsay A. Gouiding, SBN 227195
FIRM NAME: Porfer Scott
STREETADDRESS: 350 Uolverslty AvBHue
CITY: Sacramento STATE: CA ZIPCODE: 95825
TELEPHONENO.: (916)929-1481 FAXNO.: (916)927-3706 FILED / ENqfORSBD
E-MAIL ADDRESS: lgouldlng@porterscott.eom, oaina@porterscott.com
ATTORNEY FOR (name): Defendants Boyd, Chilcott, Selfert, Oropeza, and Nivhols
SUPERIOR COURT OF CAUFORNIA, COUNTY OF SACRAMENTO MAY - 7 2021
MAILING ADDRESS: 720 9th Street
CITYAND ZIPCODE Sacramento 95814
BRANCH NAME:
By \ Deputy Clerk

DEFENDANT REGENTS OF THE UNIVERSITY OF CALIFORNIA, etal.
n n ENFORCEMENT OF JUDGMENT ATTACHMENT (Third Person) 34-2013-00155479
a. I I fumish information to aid in enforcement of a money judgment against you.
b. I X I answer conceming property of the judgment debtor In your possession or control or conceming a debt you owe the
judgment debtor.
c. I I answer conceming property of the defendant in your possession or control or conceming a debt you owe the defendant
DatesJULUJ * Z , ' 2 0 ^ n Time;9:00 A.M. Dept. or Div.:43 Rm.:
Address of cdwart l ' x l Is shown above | | is:
3. This order may be sen/ed by a sheriff, marshal, registered process server, or the following specially appointed person (name):
D a t e : I '-I ( »ao«24 ™ADD A. BLIZZARD

JUDGE
I X I Original judgment aeditor Q Assignee of record Plaintiff who has a right to attach order
to appear and fumish Information to aid in enforcement of the money judgment or to answer conceming property or debt.
b. I X I a third person (1) who has possession or control of property belonging to the judgment debtor or the defendant or (2) who
owes the judgment debtor or the defendant more than $250. An affidavit supporting this application under Code of Civii
The person to be examined resides or has a place of business in this county or within 150 miles of the place of examination.
I I This court Is not the court in which the money judgment is entered or (attachment bnly) the court that issued the writ of
is attached.
I declare under penalty of perjury under the laws ofthe State of Califomia that the foregoing is true and correcL
Date: April 12 2021
Olatomlwa T. Aina 1^ (Plaiemiwa J, QUm

(TYPE OR PRINT NAME) (SIGNATURE OF DECLARANT)
(Continued on reverse) Page 1 ef 2

• FForm
n t m AdopMw^landatofy
AHrmforiC Use Code of Clvll Procedure,
Judidal Council of Cabfomia
APPLICATION AND ORDER FOR §§ 491-110, 708.110, 708.120, 708.170
AT-138/EJ-12S [Ftev. Jjanuary 1, 2017] APPEARANCE AND EXAMINATION Hww.courts.ca.gov
APR 1 2 2021 (Attachment—Enforcement of Judgment)
83
. AT-138/EJ-125
' information for Judgment Creditor Regarding Service
If ybu want to be able to ask the court to enforce the order on the judgment debtor or any third party, you
nfiust have a copy of the order personally served on the judgment debtor by a sheriff, marshal, registered

NOTiCE TO JUDGMENT DEBTOR If you fall to appear at the time and place specified in this order,
order requiring you to pay the reasonable attorney fees incurred by the judgment creditor in this
proceeding.

(1) NOTICE TO PERSON SERVED If you fall to appear at the time and place specified in this order,
proceeding.
(2) NOTICE TO JUDGMENT DEBTOR The person in whose fevor the judgment was entered in this
Community property of Plaintiff/Judgment Debtor
Irina Waszczuk's employment wages
2000 Mercedes 320
served on the judgment creditor not later than three days before the date set for the examination.

may be subject to arrest and punishment for contempt of court, and the court may make an order

It is your duty to designate one or more of the following to appear and be examined: ofTicers,
directors, managing agents, or other persons who are femiliar with your property and debts.
language interpreter services are available if you ask at least 5 days before your hearing. Contact the clerk's
AT-138;EJ-125[Rev January 1,2017] APPLICATION A N D O R D E R FOR Pafle20f2

FILED/ENDORSED
TEL: 916.929.1481 By: -E. Medina
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EXHIBIT # 40
2216 Katzakian Way
Lodi, CA 95242
Phone: 209-663-2977
Fax: 209-787-3131
April 27, 2021


Oakland, CA 94607
Seifert, Patrick Putney, and Dorin Daniliuc
Dear Ms. Aina:
I am requesting that you clarify with the Court why, on April 22, 2021, at
Court documents:
• CIVIL SUBPOENA (DUCES TECUM) for Personal Appearance and

Production of Documents, Electronically Stored Information, and Things
-1-
and Trial or Hearing and Declaration Issued to IRINA WASZCZUK
EXAMINATION OF IRINA WASZCZUK. (ATTACHMENT 3)
Lodi, CA 95242.

IRENA WASZCZUK. I am sure you understand the consequences of trying to get
For the above reason alone, I am advising you to properly fill out and resubmit
JANUSZ JAROSŁAW, and my wife’s legal Polish name is IRENA WASZCZUK. We
the National -Socialists at the University of California and their servants from the law
-2-
Poland-1980-1982

Daniel Bardzell at the end of October 2019. Looking at Nancy Sheehan and Daniel
Bardzell’s email addresses on the first page of your Declaration and reading
information in the Declaration about Judgment Debtor and Mrs. Waszczuk’s health
insurance through Mrs. Waszczuk’s employment at Nordstrom that it was not difficult
My wife and I are both on Medicare Insurance and Social Security. If you need any
I found it inappropriate and upsetting because you served me Nancy Sheehan’s

old drafted court documents. Nancy Sheehan, Porter Scott’s employee of 34 years,
sheehan&pid=194994093
-3-
Nancy Sheehan’s premature death saddened me because my wife’s sister died a
few years ago of metastatic breast cancer in Poland, and Nancy Sheehan’s e-mail
after her sister’s death.

FILE APPLICATION AND ORDER FOR APPEARANCE AND
EXAMINATION
and Order for Appearance and Examination violates the statutory 45 days’ notice

Court Law Library Debtor’s Examination, which will help you properly file the
(ATTACHMENT 5).
There are two separate periods to consider when choosing your hearing date:
date California Code of Civil Procedure (CCP) § 708.110(d).
-4-
November 7, 2018, and the debtor’s examination had to be rescheduled, which

Besides mentioning Nancy Sheehan’s e-mail in your Declaration, the front
page of your Declaration contains the following statement: “Attorneys for
Defendant REGENTS OF THE UNIVERSITY OF CALIFORNIA Attorneys for
SEIFERT.”
Since Porter Scott Attorneys’ Daniel Bardzell was teamed with Nancy
Sheehan in October 2019, in their pleadings, Porter Scott Attorneys is making
WASZCZUK’S NOTICE OF OBJECTION TO THE COURT ORDER DATED
DECEMBER13 & 17, 2019 AND PLAINTIFF REQUEST FOR COURT
ORDERS MODIFCATION – RE: OPPOSITION TO JUDGMENT CREDITORS’
-5-
(ATTACHMENT 7).
and Cindy Oropeza are Defendants. See Daniel Bardzell’s November 13, 2018
letter to Clerk of the Court (Attachment 6), in which Bardzell requested that
calendar due to a violation of the statutory 45 days’ notice requirement.
Scott Attorneys have had more than one year since my last Court filing dated
December 27, 2019 to clarify with the Court why Defendants Mike Boyd, Stephen
CONCLUSION
licensed attorney by the State Bar of California, I would like to advise you to
-6-
to in addition to responding to Porter Scott Attorneys’ negligence and deception.
https://www.scribd.com/document/495490868/Jaroslaw-Waszczuk-v-IRS-
As an attorney, you are an officer of the court who took an oath to uphold the
law. I assume you take responsibility as seriously as anyone else; you must adhere to
those rules and even report attorneys or people you see violating the rules. As a State
with the clerk.
(ATTACHMENT 8).
If you read my March–May 2019 e-mail correspondences with State Bar of

California Executives, then you will understand that I am not taking Porter Scott
Attorneys’ legal gangsterism lightly.
Request-for-Review
-7-
https://www.scribd.com/document/504978933/20190329-Request-for-Review-
Additional-Information-and-Documents-Vanessa-Holton-Rachel-Grunberg
https://www.scribd.com/document/504979845/20190515-Leah-Wilson-State-Bar-
Ceo-Reimbursement
In 2019, I recovered the money stolen from me by Douglas Stein and the
money stolen in 2011 by the University of California gangsters, namely my Short
stolen from me in 2014, namely my Unemployment Insurance Benefits. However ,
federal agencies .
Finally, I am asking you to reschedule my wife’s court hearing examination

in Department 43 to June 2021. I am awaiting a second shot of the Moderna
COVID-19 vaccine. I am scheduled to be vaccinated on May 13, 2021 As we
different medications, and I am unsure of how I will be affected by the Moderna
vaccine thus I need some time for recovery from vaccine side effects if any to
-8-
If you have any questions, please do not hesitate to contact me at your
convenience.
Sincerely,
Jaroslaw Waszczuk
-9-
Mailing List


Department 43 – Hon. Thadd A. Blizzard
720 9th Street 6th Floor

Oakland, CA 94607


80 Howard Street
- 10 -
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s
£525? V_
gig M 7’ 32 2&7L/ M g‘fwf’fjff AT-138_/E._J-125
ATTORNEY OR PARTY WITHOUT ATTORNEY: STATE BAR N05 FOR COURT use ONLY
NAME:
STREET ADDRESS: 350
University Avenue
CITY: Sacramento CA Zip CODE: 95825
STATE:
TELEPHONENO.: (916) 929—1481 (916) 927-3706

FAX NO.:
E-MAILADDRESS: lgoulding@porterscott.com, oaina@porterscott.oom

ATToRNEY FOR (name): Defendants Boyd, Chilcott, Seifert, Oropeza, and Nivhols
'
SUPERIORCOURT OF CALIFORNIA, COUNTY OF SACRAMENTO

MAILING ADDREss: 720 9th Street
BRANCH NAME:
DEFENDANTREGENTS OF THE UNIVERSITYOF CALIFORNIA, et al.
APPLICATIONAND ORDER FOR APPEARANCE AND EXAMINATION VCASE NUMBER:

ENFORCEMENT OF JUDGMENT CI ATTACHMENT (Third Person) 34-2013-00155479
E] JudgmentDebtor Third Person
a. [j furnish information to aid in enforcement of a money judgment against you.
b. answer concerning property of the judgment debtor in your possession or control or concerning a debt you owe the
judgment debtor.
c. [I] answer concerning property of the defendant in your possession or control or concerning a debt you owe the defendant
Address of court (II is shown above l: is:
Date:
JUDGE
‘

‘
4. Original judgment creditor E] Assignee of record I: Plaintiff who has a right to attach order
to appear and furnish information to aid in enforcement of the money judgment or to answer concerning property or debt.
a. |:| the judgment debtor.
b. a third person (1) who has possession or control of property belonging to the judgment debtor or the defendant or (2) who
1
owes the judgment debtor or the defendant more than $250. An affidavit supporting this application under Code of Civil
6. The person to be examined resides or has a place of business in this county or within 150 miles of the place of examination.
7. I: This court is not the court in which the money judgment is entered or (attachment only) the court that issued the writ of
8. I: Thejudgment debtor has been examined within the past 120 days. An affidavit showing good cause for another examination
is attached.
Date: April 12 2021
(Waterman; Jr. (lma

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APPL'CAT'ON AND ORDER FOR §§ 491.110, 703,213,°7o£.“1'zof°7°§a.i%
,
AT~138IEJ~125 [Rev. January 1.2017] APPEARANCE AND EXAMINATION www.courrs.ca.gov
AT-138/EJ-125
”
'
the hearin and have a roof of service filed with the court.
,

NOTICE TO JUDGMENT [DEBTOR If you fail to appear at the time and place specified in this order,
order requiring you to pay the reasonable attorneyfees incurred by the judgmentcreditor in this
proceeding.
proceeding.
(2) NOTICE TO JUDGMENT DEBTOR The person in whose favor the judgmentwas entered in this
Community property of Plaintiff/JudgmentDebtor
Irina Waszczuk's employmentwages
2000 Mercedes 320
Any and all communityproperty owned by Plaintiff and Irina Waszczuk
judgment,you must file your exemption claim in writing with the court and have a copy personally
served on the judgmentcreditor not later than three days before the date set for the examination.

may be subject to arrest and punishmentfor contempt of court, and the court may make an order
requiring you to pay the reasonable attorneyfees incurred by the plaintiff in this proceeding.
APPEARANCE OF A CORPORATION,PARTNERSHIP,
;
ASSOCIATION,TRUST, OR OTHERORGANIZATION
Request for Accommodations. Assistive listening systems, computer-assisted real—time captioning, or sign
language interpreter services are availableif you ask at least 5 days before your hearing. Contact the clerk’s
office for Request for Accommodation (form MC-410). (Civil Code, § 54.8.)
'
Page2of 2
AT-138lEJ-125[Rev.January1,2017] APPLICATIONAND ORDER FOR
APPEARANCEAND EXAMINATION
‘
MC-025
_
Jaroslaw Waszczuk V. Regents of the University of California, et al. 34—2013-00155479
( This Attachment may be used with any Judicial Council form.)
16. All DOCUMENTS relating to any transfer of over $500 made to or from YOU from October 4, 2015 to
present.
17. All DOCUMENTS relating to any transfer of over $500 made to or from YOUR spouse from October 4,
2015 to present.
19. All DOCUMENTS relating to any retirement account held by YOU.
20.All DOCUMENTS relating to any retirement account held by YOUR spouse.
21. All DOCUMENTS relating to any payroll stubs indicating earnings from any employment you have
engaged in from 2016 to the present.
(If the item that this Attachment concerns is made under penalty of perjury, all statements in this Page 2 of 2
Attachment are made under penalty of perjury.)
(A dd p ages as required)
.
Fantttfazsfl4529sant“ ATTACHMENT
M0025(Rev. July 1. 20091 to Judicial Council Form
Q
. , e
'
MC-025
SHORT TITLE: CASE NUMBER
_
1. A11 DOCUMENTS sufficient to IDENTIFY YOUR current residence, including but not limited to
2.
contents therein.
9. All federal and state corporate tax returns YOU have filed from 2012 to the present. -
10. All DOCUMENTS relating to any of YOUR property held by third parties. ~
12. All DOCUMENTS relating to any benefits YOU have received or currently receive, including by not
13. All DOCUMENTS relating to any vested future interest YOU have in any property or in the payment of
any money.
(Add pages as required)
‘
Ffll'éiéi’a‘irélfifléi’ofl’égfifnoi'nife ATTACHMENT www'cw'tmm‘ca'gw
moozsrRev.July1.20091 to Judicial Council Form

EXHIBIT # 43
MINUTE ORDER
DATE: 10/28/2015 TIME: 02:00:00 PM DEPT: 53
CLERK: E. Brown
REPORTER/ERM:

APPEARANCES
Nature of Proceeding: Ruling on Submitted Matter (Motion for Automatic Stay) taken under
submission on 10/26/2015
TENTATIVE RULING
Defendants Regents of the University of California, Michael Boyd, Stephen Chilcott, Dorin Daniliuc,
Danehsa Nichols, Cindy Oropeza, Patrick Putney, Ann Madden Rice, Brent Seifert and Charles
Witcher's motion for an automatic stay pursuant to CCP § 916(a), or in the alternative for a discretionary
stay is ruled upon as follows.
In the instant matter, Plaintiff asserts four causes of action against the above ten defendants for IIED,
tortious interference with economic advantage, FEHA harassment and failure to prevent, and
whistleblower retaliation in violation of Government Code §§ 8547 et seq. Plaintiff alleges four additional
causes of action for Violation of Labor Code § 1278.5, breach of contract, wage and hour violations and
rescission against Regents. The Court granted Defendants Boyd, Chilcott, Nichols, Oropez, and
Seifert's ("Dismissed Defendants") anti-SLAPP motion and ultimately entered judgment dismissing them
from the action. Plaintiff has appealed the judgment. Defendants Regents, Rice, Witcher, Putney and
Daniliuc ("Remaining Defendants") remain in the lawsuit on the first four causes of action. Regents
remains on the other four causes of action. Remaining Defendants seek a stay of the action pending the
appeal arguing that the proceedings are subject to an automatic stay pursuant to CCP § 916(a) or
alternatively that a discretionary stay is warranted.
The perfecting of an appeal stays proceedings in the trial court upon the judgment or order appealed
from or upon the matters embraced therein or affected thereby, including enforcement of the judgment
or order, but the trial court may proceed upon any other matter embraced in the action and not affected
by the judgment or order. Code Civ Proc § 916 (a); see also Varian Medical Systems, Inc. v. Delfino
(2005) 35 Cal. 4th 180.
To be clear, CCP § 916(a) stays all further trial court proceedings "upon the matters embraced in" or
"affected" by the appeal. "In determining whether a proceeding is embraced in or affected by the
appeal, we must consider the appeal and its possible outcome in relation to the proceeding and its

possible results. '[W]hether a matter is 'embraced' in or 'affected' by a judgment [or order] within the
meaning of [section 916] depends on whether postjudgment [or postorder] proceedings on the matter
would have any effect on the 'effectiveness' of the appeal.'" (Varian Medical Systems, Inc. v. Delfino
(2005) 35 Cal.4th 180, 189 [citations omitted].) "If so, the proceedings are stayed; if not, the
proceedings are permitted." (Id.) "A trial court proceeding also affects the effectiveness of an appeal if
the possible outcomes on an appeal and the actual or possible results of the proceeding are
irreconcilable." (Id. at 190.) "The purpose of the automatic stay rule is 'to protect the appellate court's
jurisdiction by preserving the status quo until the appeal is decided. The rule prevents the trial court
from rendering an appeal futile by altering the appealed judgment or order by conducting other
proceedings that may affect it." (Dowling v. Zimmerman (2001) 85 Cal.App.4th 1400, 1428.)
Here the Court is not persuaded that Plaintiff's appeal from the order and judgment following the
Dismissed Defendants' successful anti-SLAPP motion automatically stays the entirety of the
proceedings with respect to the Remaining Defendants who themselves did not bring an anti-SLAPP
motion. No Court has held that an appeal from an order granting, as opposed to denying, an
anti-SLAPP motion divests the trial court of jurisdiction, especially as to matters related to other
defendants. Indeed, Varian held that an appeal from the denial of an anti-SLAPP motion automatically
stayed further trial court proceedings on the merits, but made clear that such an appeal does not stay
proceedings related to causes of action that were not affected by the motion. (Varian, supra, 35 Cal.4th
at 195, fn. 8 ["Such an appeal does not, however, stay proceedings relating to causes of action not
affected by the motion"].)
While it is true that Plaintiff asserted the first four causes of action against the Dismissed Defendants
and the Remaining Defendants based on allegations that each of them participated in a coordinated
campaign of unlawful conduct, only the Dismissed Defendants brought the anti-SLAPP motion.
Remaining Defendants were not parties to that motion. Remaining Defendants cite no authority for the
proposition that an automatic stay is mandated based on an appeal of the granting of other defendants'
anti-SLAPP motion simply because all are named in the same cause of action. Importantly, the conduct
of the Remaining Defendants was not at issue in the anti-SLAPP motion. They fail to articulate how a
possible outcome on appeal (e.g. a reversal of the order granting the anti-SLAPP motion and entering
judgment in the Dismissed Defendants' favor) is irreconcilable with the possible results on the same four
causes of action in these proceedings, specifically given that the conduct of the Remaining Defendants
was not addressed in those motions. Remaining Defendants complain that Plaintiff is a prolific motion
filer and there is a danger that Plaintiff will file numerous motions that will be heard and decided in the
Dismissed Defendants' absence and that if the judgment were reversed the Dismissed Defendants could
be inserted back into a case that may be significantly different. They point to the fact that Plaintiff
apparently intends to seek to file a voluminous Third Amended Complaint. But, speculation aside, this
fails to show how anything that could take place in these proceedings would render the appeal futile or
how the possible results on appeal and in these proceedings are irreconcilable. This is especially true
since Plaintiff has since dismissed Defendants Rice, Witcher, Putney and Daniliuc from the lawsuit and
the Regents is the only one of the five Remaining Defendants left in the action. Remaining Defendants
fail to articulate, for example, how it would be irreconcilable for them to be found liable on Plaintiff's
claims at trial even if the appeal affirmed the anti-SLAPP order and judgment of dismissal as to the
Dismissed Defendants.
In any event, even if it could arguably be said that there was a possibility of irreconcilable results
between the first four causes of action against the Remaining Defendants and the appeal which involved
the first four causes of action against the Dismissed Defendants, there are four other causes of action
asserted against the Regents which were not the subject of the Dismissed Defendant's anti-SLAPP
motion. Those causes of action were not implicated in any way in the anti-SLAPP motion and any
appeal related to the anti-SLAPP motion could not result in a stay of those causes of action. (Varian,
supra, 35 Cal.4th at 195, fn. 8 ["Such an appeal does not, however, stay proceedings relating to causes

of action not affected by the motion"].) Yet, Remaining Defendants seek a stay of the entire action
pursuant to CCP § 916. They did not simply seek a stay of the first four causes of action.
However, the Court does agree that a discretionary stay of the proceedings pending resolution of
Plaintiff's appeal is appropriate. "Trial courts generally have the inherent power to stay proceedings in
the interests of justice and to promote judicial efficiency." (Freiberg v. City of Mission Viejo (1995) 33
Cal.App.4th 1484, 1489.) In fact "it may be in the interests of justice to stay a trial until another party's
appeal is decided..." (Id.) This is such a case. Here the Court finds that the interests of justice support
a stay. The Court is mindful of the inefficient use of judicial resources if a stay is not issued, specifically,
in the event the judgment is reversed. Consequently, Plaintiffs would then be entitled to try the matter
again as to those defendants who should have been at the first trial. The potential inefficiencies in this
approach are too numerous to mention. Indeed, the four causes of action that are the subject of the
appeal are also asserted against the Remaining Defendants and the allegations as to all the Defendants
appear factually intertwined and likely would involve much of the same evidence and issues. There is
thus a very real possibility that in the event Dismissed Defendants were returned to this action if the
judgment on appeal is reversed, any motions and/or discovery that were conducted in their absence
would need to be repeated. In addition, while there are four other causes of action asserted against the
Regents which were not the subject of the appeal, those causes of action also likely involve similar
evidence and witnesses and allowing piecemeal litigation would not be in the interests of justice. A stay
would promote judicial efficiency.
Plaintiff's opposition fails to present any persuasive argument against a stay. Rather Plaintiff presents
arguments going to the ultimate merits of the lawsuit and apparently the appeal. Plaintiff also indicates
that he intends to file a third amended complaint in which he intends to eliminate all individual
Defendants and simply leave his two causes of action for breach of contract and violation of Health &
Safety Code § 1278.5. The Court finds that this simply confirms the propriety of a stay under the
circumstances. Indeed, if the action is not stayed and Plaintiff were permitted to file the TAC and the
judgment against the Dismissed Defendants reversed, this could lead to extreme confusion regarding
the status of the case. That is, if the judgment against the Dismissed Defendants on the second
amended complaint is reversed the Dismissed Defendants would be returned to the action. However,
the TAC referred to by Plaintiff appears to no longer include any of the causes of action asserted against
them but Plaintiff is not contending that he has abandoned his appeal. The parties and the Court would
then need to sort out what the operative pleading would be. In the interim, the parties would have
litigated only the two causes of action against the Regents in the TAC and would then have to essentially
begin again with the four causes of action against the Dismissed Defendants. A stay is appropriate in
the interests of justice and to promote judicial efficiency.
As a result, Remaining Defendants' request for a discretionary stay is granted. This action is stayed in
its entirety pending the resolution of Plaintiff's appeal.
Defendants' request for judicial notice is granted.
This minute order is effective immediately. No formal order pursuant to CRC rule 3.1312 or other notice
is required.
COURT RULING


Dated: October 28, 2015
JAROSLAW WASZCZUK
2216 KATZAKIAN WAY
LODI, CA 95242
DOUGLAS L. ROPEL
PORTER SCOTT

2 Lodi, CA 95242
Telephone: (209) 663-2977
3 Facsimile: (209) 370-8281
4
5
7 DRAFT
8

12 )
13 )
14 ) Employment:
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21 Defendant. )
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and/or abuse.
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11 California.
25 alleged herein.
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10 $70,000.00.
20 coworkers
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2 Squad.”
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from UC DAVIS.
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psychiatrists.
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patient care.
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15 years of 1991-1995.
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17 of IWC 1-89.
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Enforcement.
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Medical Center.
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cogeneration plant.
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regulations.
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13 88. It is also a question of law whether the Defendant committed

16 was being operated in violation of the federal law and regulations and could be subject to shut down
17 and personnel could face unemployment if violations were disclosed.
20 State of California Revenue and Taxation Code by engaging in commercial operation of a
21 cogeneration power plant business based on an electric power agreement with public or private utility
22 companies and made millions of dollars in profit from seventeen years of operation.
25 Internal Revenue Service’s Code Section 501(c)(3) by engaging in commercial operation of a
27 companies and made millions of dollars in profit from seventeen years of operation. An organization
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8 personnel.
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$664,275.
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9 energy sources.
20 ISO?
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2 in December 2012.
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zone.
9 inviduals from Jackson plant , and without any hesitation showed anger aimed at William
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position.
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may be required.”
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HVAC Shop
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3 Shop/HVAC.
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job description.
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1 2011.
2008 Case No. : 03-PPS-013-06107
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FAC and SAC ).
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go far.
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Connie Melendy.
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15 desires.”
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20 2004, 2005, 2006)
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overtime pay.
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$71,640/year to $76,600/year.
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1 in 2010.
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4 did not complain.
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10 The Attorney Danesha Nichol’s Deployment From The UC Davis Campus to UC Davis
11 Medical Center Human Resources Department in October 2010
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19 management, and she was very familiar with the crime that was committed in the Central Plant
20 in the period of time spanning from 1998 to 2009 and Nichols was familiar with Plaintiff’s file .
21 212. Danesha Nichols arrived at UC Davis Medical in October 2010 with the
22 title of Investigation Coordinator in similar circumstances as Stephen Chilcott in 2005 and she
23 reported directly to Director Stephen Chilcott.
24 213. As Plaintiff stated previously, the UC Davis Medical Center’s newly built
25 in 1998 Cogeneration Power Plant/Central Plant was a pride and legacy left behind for former
26
27
the Medical Board of California, Division of Medical Quality, by Governor Arnold
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4 The December 2010 Central Plant Operator Locker Burglary
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found, appropriate action will be taken.”
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unable to notice William Buckan’s accident underneath the cooling tower’s oily surface. Mike Lewis
27 Boyd.
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1
2
216. Five days after the Principal Engineer Mike Lewis issued his dramatic
3
memo about the incoming investigation to find perpetrator Central Plant Operator, Todd
4
Goerlich committed suicide. Then, the rest of the Central Plant Operators received a 12% pay
5
raise despite strict UC budget constraints and furlough in UC Campuses and no power sale
6
contract . Thereafter, everything got quiet. Nobody was questioned by an HR investigator or the
7
UC Davis Police Department about locker burglary. No more comments were made by any
8
Central Plant supervisors about Jeff Lancaster’s burglarized locker, no more dramatic memos
9
10
11
The Secret 12 % Pay Raise For Central Plant Operators –March 2011
12
13 217. Around March 5, 2011, Plaintiff somehow got into a conversation with
14 the operator from the central plant William Buckans about the December 2010 12% pay raise,
15 and Plaintiff received from Buckans a copy of the UCDMC Plant Operation and the letter from
16 maintenance manager Charles Witcher dated December 20, 2010, which confirmed a 12% pay
19
plant operators was discriminatory to other non-union employees of the UC Davis Medical
20
Center who did not get one penny in wage increase in the last three years due to strict budget
21
constraints in the whole University of California system. The disclosure about the secret pay
22
raise for small groups of employees became a subject of discussion among workers at the other
23
shops in the UC Davis Medical Center. Plaintiff confronted his shop manager Patrick Putney and
24
Plaintiff asked Putney why the HVAC shop staff did not get a pay raise. Putney’s response was
25
that he knew about the pay raise, but was told to be silent about it to avoid any turmoil among
26
the other shops’ workers. Following the discussion with Patrick Putney, Plaintiff wrote an eight-
27
page letter to the department manager about the central plant operators’ December 2010 pay
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2 wage increase.
3
4
5 in March 2011
6
7 12% pay raise for the Central Plant Operators, Department Principal Engineer Mike Lewis
8 issued a memo dated March 11, 2011, instructing Central Plant crew to do the following:
9
17 access to the Central Plant request access to the Central Plant please contact
18 Charles Witcher, Mike Lewis, or Dennis Curry for direction. Thank you.”
19
20
shift personnel.
21
The March 13, 2011, Plaintiff letter addressed to UCDMC Plant Operation and Maintenance
22
23
24
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220. A few days after Mike Lewis issued the memo about access to the Central
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2 replacement in the Central Plant in March 2007, and he did not survive hostility created by UC
3
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long Defendant’s psychological terror aimed at Plaintiff by Defendant’s agents and
11
officers .
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dollars.
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At the best of my ability to write, I will try to explain why I feel discriminated
25
and left behind like an orphan in abandoned orphanage.
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1 Last year in August 2010 after I came back to work from vacation, my
2 coworker from HVAC shop, Bill Rabidoux asked me if I will be willing to
3 work swing shift because HVAC shop manager told him that second shift
4 would be created for the Metasys System operation outside the Central Plant.
5
I responded that it would be no problem.
6
9 inside the department and he is trying to fix something that is not broken.
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11
12
Shortly after, in September 2010, I received by copy of the undated but signed
13
petition by four Central Plant operators in regards to Metasys Operation
14
15 After I read the petition and attached to the petition the wages disclosure
16 printed from the Sacramento Bee website, the first my thought was that the
17 petition is a follow up to their earlier complaint which I thought they submitted
18 in August during my vacation absence. The petition itself alleged that Metasys
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Furthermore , the individuals who signed the petition alleging (without
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23 about the cuts and possibility of big lay off in IJC system. Basically, I ignored
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Central Plant.
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Central Plant employee who took his own life. Just day or two before it
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4 experienced bully behavior toward, Rick Tunello and William Buckans and
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this petition.
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The other December 2010 story from the Central Plant is a story of the Jeff
9

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December 17, 2010
14 Central Plant
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UCDMC Human Resources department for appropriate investigation and
19
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3 Mike Lewis
Principal engineer
9 could only open somebody's locker. This whole story sound and looks like
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Dear Mr. Witcher:
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mention again his raise and again I thought that he is trying to "pull my legs"
23 raise.

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1 Position.
4 should be in the Middle Range or step with $ 71640.00 per year or $34.31/hr
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make after the December 2010 pay raise.
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23 change clothes at the winter time. I am happy for Central Plant operators
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responsibility for the operation and maintenance of the Central Plant.
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3
4 Beside the Metasys Alarms I am doing other stuff requested by Patrick Putney
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circulation normal
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In conclusion I am respectfully asking and I would appreciate if my salary will
14
17 Sincerely
19
23 observation how badly Todd Goerlich disliked Jeff Lancaster and, in particular, how different
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who provided the recommendation for Dereck Cole to be hired as an HVAC Technician by UC
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4 showed up in the Central Plant with a hand-printed copy of UC Davis Policy 1616, for the UC
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this place was and how it had contributed to an employee’s suicide.
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21 $70,000.00 to $71,600 per year.
23 224. Instead of any response to my letter from Charles Witcher in April 2011,
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daughter, whom he had brought to the shop on that day. Plaintiff told Putney that he didn’t miss
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4 from these buildings were coming to the Metasys Computer Monitoring System and Plaintiff had
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responded, “I am trying to make you perfect.” Plaintiff said ok and continued to train himself to
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17 Hospital.
23 hostility towards Plaintiff; Plaintiff became the subject of vicious attacks, including and not limited
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227. In May and June 2011, Patrick Putney turned off the lights in his office and
27
positioned himself in the chair toward Plaintiff and stalked Plaintiff for hours every day. Once in
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3 No so long prior to Putney’s behavior—in March 2011—Plaintiff was making breakfasts for
4 Putney every morning and had quite a normal relationship with him and his assistant. Dorin
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punished, as this had happened to one of his coworkers, Rick Tunello, in the central plant. Rick
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Tunello had been wrongfully accused and wrongfully convicted by Dennis Curry, and wrongfully
14

22 Curry and Witcher’s approach to resolving the dispute. The abovementioned course for supervisors
23 was hosted by UC Davis Medical Center Human Resources Executive Director Gloria Alvarado.
24
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dare to complain. One of the course’s subjects was how to convince a subordinate that he is too
27
observant to demote himself. Plaintiff responded to Ms. Alvarado self-demotion instruction and
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3 After a short discussion with Plaintiff, Ms. Alvarado changed subjects and ended instructing
4 supervisors who attended the class on how to take control of the crew by intimidation and fear.
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12 May 2011
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Charles Witcher, to clarify the issue with the missing refrigerator alarm, to discuss the unusual and
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psychotic behavior of Patrick Putney toward me, which was not limited to stalking Plaintiff from
16
24 victim of Patrick’s Putney, Dennis Curry, and Charles Witcher’s schemes and yet another
25 candidate to look for new employment. He was unspeakably victimized and asked me to represent
26
him with his complaints against Patrick Putney and Charles Witcher. Another Patrick Putney
27
victim is 72-year-old HVAC technician Richard Pawlaczyk. The Richard Pawlaczyk’s case was
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3 Patrick Putney denied Plaintiff’s access to his time cards , work orders system and to sabotage
4 Plaintiff job Putney denied Plaintiff’s access to many Metasys system future . Plaintiff failed to
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Patrick Putney. I would prefer for the situation to improve somehow and for
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everything to return to normal in the workplace .Unfortunately, it does not
14
22 Monday, and I tried to smooth out everything. I even offered him breakfast,
23 but my attempt to make peace with him did not work, and the situation still
24
does not look good.
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"unreliable alarms" in the Metasys . Without discussion, I found these unreliable
27
alarms for him. It took me almost a week to complete the task, after which Patrick
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3 communication with me, including not saying "good morning” or “bye” at the end
4 of the day. As you know, Department Head Assistant Dennis Curry came to the
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and dumped on my desk the policy and procedures for central plant operators,
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which explains how to operate the Metasys system, plus my job description.
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22 the UCDMC premises by hiding his car inside the shop and playing a little
23 "catch me if you can” game with the parking cops. On top of this, I decided to
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at the same time having the ambition to became assistant PO&M [plant
27
operation and maintenance] manager after Dennis Curry retires?”
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3 The peace, however, did not last long. Yesterday and today, Patrick started a
4 new "kids game." He turned off the light in his office, which is next to mine, and
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create a confrontation with me for any reason. I simply told him not to worry
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and that I had been reviewing and closing all of the completed work orders for
14

22 still don't understand why I got kicked out. I did not park my car without a
23 permit, and I did not do private jobs in the company shop. I just wanted a few
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supervisor is doing everything possible to make my life miserable and hellish.
27
To avoid going through this hell and finally end Patrick’s hostility, I would be
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3 Should I apologize to Patrick by saying that I have been doing a good job for
4 the past three years and don't have a history of neglecting my duties and of
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information about the Central Plant’s operation and electric power, steam, hot water, and chill
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water production.
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22 System about the Central Plant and be removed from the premises at any means. The UC Davis
23 Medical Center PO&M Department Manager was the one of four UC Davis employees who
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June 2011
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4 Regardless of the stress and feelings, in good faith and will, Plaintiff sent an email to Patrick
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Daniliuc as it was mandated by the UC Davis Policy PPSM 23.
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15 July 2011
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241. Danesha Nichols was very familiar with the previous attack against Plaintiff
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3 gross and despicable violation and breach of the Settlement-Agreement signed by Defendant.
4 242. Besides the investigation issues, Plaintiff on July 17 and July 24, 2011, sent
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243.. As a result of Plaintiff’s complaints to UC Davis Chief Counsel Steven
13
Drown about the Settlement-Agreement violations by the Defendant, the UC Davis Chief
14
19 River.
22 relationship with two UC Davis Medical Center directors, Robert Taylor and Shelton Duruisseau
23 The Daniliuc’ relation with these two directors was to provide them HVAC services in their
24
25
26
of five investigation reports written by Danesha Nichols in December 2011 and February 2012.
27
245. Plaintiff also asked Executive Director Mike Boyd, who is a listed
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3 stop the retaliation and further harassment. Plaintiff did not get a response from the HR Director,
4 but Director Mike Boyd denied Plaintiff’s request for 30 days of administrative leave. However,
5
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September 2011.
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12
illegally accessing shop computers. Bill Rabidaux’s son was a twice-convicted child
13
pornography felon on probation; he was prohibited to have a computer at home by court
14

22 when he came back to his office. When Plaintiff told Putney about it, he got upset that Kenny
23 Diede had not waited for him with information and angrily asked Kenny whose side Kenny is s
24
25
26
pornography felon accessing shop computers. Thereafter Kenny Diede had to look for a new job
27
due to harassment and intolerable working conditions, as Patrick Putney, Dorin Daniliuc, and
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3 review from his two supervisors, Patrick Putney and Dorin Daniliuc, as was mandated by the UC
4 Davis Policy PPSM 23.
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70. Annual Performance Reviews (Evaluations) are the most important documents in the
13
14
15 Rptr. 2d 83 (Cal. Ct. App. 1993).
22 premises through the false and fraudulent Workers Compensation Claim. Plaintiff refused to file
23 a false claim, but a claim was filed on Plaintiff’s behalf anyway.
24
25
26
taking into consideration that on May 31, 2012, Hugh Parker coordinated ill-minded but
27
unsuccessful provocation to kill Plaintiff or end his employment in UCDMC Trauma Unit #11 by
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3 deliberately and “professionally” damaged when Plaintiff left his office for lunch. The external
4 hard drive circuit board was literally fried, most likely by high electric current and the damage was
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12
USB-powered external hard drive (HD) had been fried/damaged by
13
somebody after I left it connected to the computer in my office and I left
14
20 burned.
22 hand. Therefore, I can only write and whine about this event. I did not take any
23 chances by remaining in my office any longer and getting electrocuted like my HD.”
24
25
26
System HR department, the UC Davis chief counsel, and the UC Davis chief compliance office
27
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4 surgery a few years ago. Plaintiff was using nine different prescription medicines to survive every
5
6
7 August 2011
8
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15
was also hoping that the UCDM HR assigned investigator, Attorney Danesha Nichols, would
16
25 pursuant to UC Davis Complaint Resolution Policy PPSM 70 and Whistleblowing Retaliation
26
27
259. The August 2, 2011 was Plaintiff’s last physical presence and last working
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4 260. On August 30, 2011, Plaintiff filed an official complaint against his
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13
employees and that the investigation would be finished in 14 days.
14
23
24 September 2011
25
26
27
unsuccessful attempt to force Plaintiff to quit his job or to participate in the investigation against
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4 Nichols to send an e-mail to Plaintiff and basically ordered Plaintiff to meet her the next day in
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265. Plaintiff was informed by the UC Davis Public Record Act office that
14

23 Defendant in FAC and SAC) to add Danesha Nichols and Charles Witcher to Plaintiff’s
24
25
26
27
Danesha Nichols, transmitting the same baseless accusation of violence and discrimination and
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4 was a only tool in the hands of HR Director Stephen Chilcott and Charles Witcher with education
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13
force me to confess to the crimes based on fabricated false and groundless
14

23 diligent way without bias, prejudice, and discrimination.”
24
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27
management capacity because it appears that your management capacity is not
28

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4 abusing not only his own subordinates but also abusing animals and members
5
6
7
8
9
mentioned above.”
10
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12
13
psychologist’s help to cope with the enormous emotional stress and anxiety in relation to
14
23 Apparently, Plaintiff physician who placed Plaintiff on stress-related sick leave stopped the
24
25
26
27
Plaintiff’s employment termination before the termination letter was sent to Plaintiff .
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4 announcement by Bill Rubidoux, the PO&M Manager Charles Witcher sent Plaintiff a letter
5
6
7
8
9
10
11
12
wrote:
13
, “By this letter, I am respectfully requesting from your office intervention to
14

23 connected to this case.
24
October 2011
25
26
27
California against UC Davis Medical Center’s two Human Resources Department Attorneys,
28

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4 behavior, conspiracy against Plaintiff, and gross misconduct. State Bar Case No. 11-31088.
5
14 unfounded accusation against me from UCDMC HR Attorneys and other individuals,”
15
16
17
18
UC Davis Campus).
19
20
e-mail letter:
21
22
23
Operation and Maintenance, Sacramento Department. In last few months I
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4 accusations and allegations for the period from
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6
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9
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11
12
13
unfounded accusations fabricated by the Defendant against Plaintiff. Captain Joyce Souza, in her
14
15 response, wrote:


24
25
26
27
Chancellor Linda Katehi; UC Davis Medical Center CEO Ann Madden Rice; UC HR Vice
28

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4 accusations against Plaintiff.
5
6
7
8
changed course and were trying to find for Plaintiff a new place to work in UCDMC. Plaintiff
9
14 intolerable.
18 child pornography felon on parole who had illegally accessed the HVAC shop computer and was
19
20
21
22
23
24
25
26
LANCASTER'S BURGALIZED LOCKER ON DECEMBER 17, 2010 AND PAY RAISE FOR
27
UCDMC CENTRAL PLANT OPERATORS ON DECEMBER 20, 2010.
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2 2010.
6
7
8
9
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12
Delmendo.
13
14
15
16
the organization and operation of the campus. With the investigation by Ms.

Sincerely,
22
25
Director Epperson”
290. On October 29, 2011Plaintiff responded to UCOP HR Director Simon’s
26
27 letter

Page 101 of 295
Director of HR Compliance
1 UNIVERSITY OF CALIFORNIA
HR-UCOP Human Resources
2 1111 Franklin St., 5th Floor
Oakland , CA 94007-1449
3
Re: Reponse To Your Letter Dated October 26, 2011-The Progress Of The
4 Investigation
5 Dear Director Simon:
6
7
It is almost one month passed by since I asked Vice President Duckett for
8
intervention in this case .
9
I would like to mention that the previous UC HR Vice President Mrs. Judith
10
Boyette , had no any problem to intervene if needed and respond personally to
11
employees complaint letters .
12
In my response to your letter I would try not to repeat what I wrote already in
13
my multi correspondence to Vice President Duckett , Mrs. Delmendo and
14
others UC Officials but at some point I have to rely on the facts of events and
15
17 It would be unnecessary to ask Vice President Duckett for intervention and
18 send the
19 Open Letter to The Honorable Members of UC Davis Ethics and Compliance

20 Risk Committee and the California State Assembly Members,and The Regents
21 Of The University of California entitled: "I FEEL LIKE A HUNTED JEW
22 DURING THE HOLOCAUST"
23 if, after my respectful request on July 13, 2011, I sent to UC Davis Medical
24 Center HR Executive Director Mr. Stephen Chilcott to intervene in the case.
25
26
would start her investigation or at least she start her investigation, after I sent a
27
lengthy letter dated July 31, 2011 to UC Davis Chief Compliance Officer Mrs.
28

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2 President.
3 Instead of the investigation, the UCDMC Plant Operation & Maintenance
4 Management with full back up and support of the UCDMC HR Department
5
6
7
8
9
10
11
12
loud voice, did not give me any choice but to evacuate myself from the shop
13
and ask my doctor for stress leave.
14

22 the stalking me, I observed that his hands are almost constantly shaking
23 especially when he got excited or mad or even for no reason.
24
25
26
Patrick Putney would turn off lights in his office and would be stalking her as
27
he stalked Waszczuk.
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3 harassed by supervisors.
4 Whether , after such complaint by female employee, Patrick Putney would be
5
6
7
8
9
10
11
12
Putney to protect stalked female employee or hunt her down for complaining
13
as it had been done to Waszczuk?
14

22 investigation is going on. The HVAC Shop social area experiencing
23 remodeling, painting and clean up. This very good and promising sign for
24
positive changes.
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26
that Charles Witcher, Patrick Putney, Dennis Curry, Danesha Nichols, Stephen
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Chilcot, Mike Garcia, Cindy Oropeza and Mike Boyd are responsible for
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3 Regents in February 2009. The Settlement Agreement had been grossly
4 violated by the above mentioned individuals and I am expecting from my
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work .
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unwarranted threats of termination of my employment by some of the above
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listed individuals.
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22 If UC won't let me go back to work as soon as possible than I respectfully
23 requesting answer ASAP what is the other option because I don't know. I have
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I appreciate your prompt response in this matter and I am awaiting for
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resolution to end this employer hostility against me .
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Sincerely,
1
Jaroslaw Waszczuk
2
3 CC: Vice President- Dwaine Duckett

Director Epperson
6 Liberty Mutual”
7 November 2011
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291. In November 2011, Plaintiff spent most of his time dealing with the
16 nonsense to accept the FMLA protection extension to stay employed without the income.
17 292. In the response letter, dated November 23, 2011, to Gina Harwood,
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Plaintiff wrote:
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effect of my health and welfare benefits makes no sense to me.
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The University is fully responsible and legally liable for my current health

Page 106 of 295
3 Records Act requests, the UC Davis chancellor requested from Danesha Nichols a confidential
4 report on Plaintiff, which was sent in November to Chancellor Linda Katehi. The exact day
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294. The premediated pepper spray attack ordered by Chancellor Katehi on November
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18, 2011, was solely used to replace UC Davis Chief of Police Annette Spicuzza with Lt. Matt
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295. On November 14, 2011, Plaintiff filed a complaint with the State of California
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Department of Insurance against the Liberty Assurance Company of Boston for denying to
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3 applying different standards of conduct than with other claimants and other University of
4 California employees, without any legitimate justification. As a result of Liberty Assurance
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other benefits.
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10 Plaintiff declined such an offer, and the case is still unresolved.
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publications “Chemical Katehi,” on November 18, 2011, ordered gas attacks against peacefully
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protesting students on the UC Davis Campus. In this way, Katehi observed and marked the 38th
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18 Polytechnic.
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27 299. Plaintiff responded to Vice Chancellor Pomeroy’s outcry with the following words:
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1 Dear Ms. Pomeroy:
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3 Can you do something about the National Socialism doctrine oriented and
4 entirely corrupted management in the UC Davis Medical Center, Plant
5 Operation and Maintenance and Human Resources Departments? The
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Principles of Community does not exist in UCDMC and it is the empty slogan.
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Your commitment to freedom of expression is also empty slogan as well. You
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and others are receiving my letters for quite long and you and others don’t care
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what the “UCDMC Gestapo” doing to me and how systematically is
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destroying my and others livelihood and life. I am sending a few letters again
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to you with hope that I will be heartened to see Ms. Pomeroy will order to
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conduct a true investigation against the corrupted individuals in both
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departments and restore a normal work environment in the UCDMC PO&M
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Department.
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17 JerryWaszczuk
18 Associate Development Engineer
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300. Shortly after Plaintiff sent his message to Vice Chancellor Pomeroy cc’d to many
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other University of California decision makers, Vice Chancellor Pomeroy was forced to resign due to
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illegal medical experiments conducted under Pomeroy’s supervision for years by two UC Davis Medical
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Center Dutch neurosurgeons, Dr. J. Paul Muizelaar and Dr. Rudolph J. Schrot, which caused
23 several patients’ deaths. So far, Plaintiff, with his words about the UC Davis Medical Center
24 National Socialism doctrine, was taking into consideration inhumane, illegal medical
25 experiments on humans in the Nazi concentration camp Auschwitz conducted on camp inmates
26 by the notorious Dr. Joseph Mengele.
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3
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access to the university e-mail, with accusations that Plaintiff was sending inappropriate content
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13 ass.”
14 303. Apparently, the UC Davis Medical Center Plant Operation and
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304. The conclusion of this chapter is that the Defendant with Liberty
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4 December 2011
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14 Danesha Nichols on December 12, 2011. Four years after this, Plaintiff is still in disbelief that it
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from sick leave unconditionally without Plaintiff’s physician’s permission and place Plaintiff on
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4 health significantly deteriorated due to the situation with Plaintiff’s employment and denial by
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private computer hard drives.
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21 Nichols.
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315. Plaintiff installed his private hard drives in the company computers as a
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4 private hard drives in two company PC computers but also purchased at his own expense a top-
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Plaintiff finally convinced two of his supervisor to bring used computers from the warehouse that
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21 his office.
23 December 22, 2011.
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person who disclosed to Plaintiff during the conversation that he had previously worked as a
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4 regretted that he got himself into this meeting because of her cover-up for management
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investigatory leave or administrative leave with pay. Plaintiff lost track of whether he was on
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January 2012
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knowledge, and for an unknown reason, from Associate Development Engineer to Programmer I,
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4 California. The Associate Development Engineer, under UC Davis Title Code 7182, was an
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2009 Settlement-Agreement, and work in a different shop.
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21 committed.
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Order.
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January 18, 2012, that Plaintiff had been de-enrolled by the Defendant from the medical, dental
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4 to quit, and asked Mr. Peklar to immediately reinstate Plaintiff’s medical Benefits. Plaintiff
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problem as well.
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HR Benefits Manager, John Peklar and requested to cancel Plaintiff’s Supplemental
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23 332. At the end of January 2012, Plaintiff learned that his long-time physician,
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28 February 2012

Page 116 of 295
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problem.
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16 of California.
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337. . Plaintiff’s meeting with HR Labor Relations Manager, Mike Garcia, took
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4 Plaintiff his annual wages in a lump sum until Plaintiff is eligible for full Social Security
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subsequently went to the EEOC’s San Francisco Office for an interview, Plaintiff was dismayed

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to Plaintiff.
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14 Plaintiff.
18 same Department in which Plaintiff worked.
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March 2012
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4 On the contrary, in July 2011, Plaintiff sent two complaint letters to UC Davis Chief Counsel
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California, behalf.
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4 Plaintiff also informed the UC Davis chief counsel that UC Davis Medical Center Plant
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from the HR side.
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21 Shop Supervisor Dorin Daniluc’s special relationship with two corrupted UC Davis Medical Center
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2 Center.
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7 May 2012
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19 May 2012 – May 7, 2012 Events

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1 at all.
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helpful.
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May 11, 2012
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Jaroslaw Waszczuk
524 Swallow Lane
14 Lodi, CA 95240
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3 action.
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19 Charles Witcher
21 Skelly Decision
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and William Buckans
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21 on May 29, 2012.
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16 trauma unit.
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leave.
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3 JUNE 2012
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electronic mail.
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18 Davis Police.

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Death Squad.”
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3 No. 11.
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work and live.
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1 call on May 31, 2012.
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15 Program.
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direct subordinate.
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March 13, 2011.
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July 2012
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2 Trauma Unit # 11.
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16 reminder.
17 Jerry”
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AUGUST 2012
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15 to Kenney Diede
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20 response:
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Department.
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17 questions.
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Relation staff.
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15 plumber.”
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Mr. Waszczuk,
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Division.
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enjoyment for life.
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12 SEPTEMBER 2012
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3 Diede wrote:
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Plaintiff.
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of employment.
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17 reason.
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20 Office)
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to Hugh Parker:
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17 2012.
20 2012, from 9 to 10 AM.
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misunderstandings.)
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Dear Charles:
8
INTRODUCTION
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17 issues.
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company premises.
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21 business.
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THE COMPLAINTS
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experience.
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Regards,
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Jaroslaw Waszczuk
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17 TO ME AND OTHERS
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15 to Suspend.
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signage.
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emergency.
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3 916-734-1555.”
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3 precautions, etc.
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13 2012.
17 OCTOBER 2012
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4 expenses.
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3 Sincerely,
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19 medicines.
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Sincerely,
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Jerry “
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will.
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13 October 1, 2012
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Dear Mr. Waszczuk:
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27 Sincerely,
28 Michael Tyler

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017-11/12
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assigned.
26 Sincerely,
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27 UCDMC premises.
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Travis,
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16 Respectfully,
17 Dereck
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3 Cole.
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NOVEMBER 2012
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No. # 11.
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16 2012 chapter.
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4 November 7, 2012.
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20 Sincerely,
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two hard drives.
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7 Squad’”
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Sincerely,
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Jaroslaw Waszczuk
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23 Squad.’”
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2012, at 9:00 A.M.
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workers.
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2 to Waszczuk:
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9 Thank you.
10 Management
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Patrick Putney.
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4 next month.
8 Sincerely,
9 Jaroslaw Waszczuk
10 Enclosed:

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Squad”
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Best Regards,
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Jerry Waszczuk
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18 DECEMBER 2012

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Dear Jerry:
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3 in US Mail today.
4 Sincerely,
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Charles Witcher
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Sincerely
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December 5, 2012
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“December 3, 2012
14 Travis Lindsey
Manager
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should be upheld.
10 Sincerely,
cc: Charles Wichter
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employment.
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Hi Gina:
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Gina”
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Policy PPSM 70.
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employment.
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Jaroslaw Waszczuk
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alleged as follows.
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7 MANAGAMENT
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Stephen Chillcot:
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4 December 5, 2012.
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16 February 2013
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Gina Harwood, SPHR
Proof of Service
Charles Witcher
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1 “CONCLUSION

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service.”
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MARCH 2015
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4 university.
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9 ‘March 7, 2013
One Shields Avenue
12 Davis, CA 95616
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Jaroslaw Waszczuk
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Dear Mr. Waszczuk:
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7 Daniel M. Dooley
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APRIL 2013
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2 on April 2, 2013
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Jaroslaw Waszczuk
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MAY 2013
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May 5, 2012
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7 4800 2nd Avenue,
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environment.”
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6 See you in court.
Jaroslaw Waszczuk
7 Enclosure:
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representation.
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operator” --

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2006-07 4/27/2007 McGRATH
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1 in 2 006 –20 08 a nd 20 11– 201 2 .
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was:
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the open market .
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17 After the Letter
21 attention from the huge profits generated by the Central Plant from electrical energy sale
22 disclosed which was disclosed by UC Davis Assistant Vice Chancellor Dr. Shelton Du ru isseau
23 in h is in te rvie w with Do nna Ramo s.
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December 1991.
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16 Operator (ISO).
V. CONCLUSION
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until year 2017.
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regulations
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The Violation and Breach of Settlement –Agreement by the Defendant in Regards to § No.
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Plaintiff observed.
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8 DATED: June 12, 2021

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10 By: _________________________
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EXHIBIT # 45
CIV-120
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address):
IN PRO PER FOR COURT USE ONLY
Jaroslaw Waszczuk; IN PRO PER
2216 Katzakian Way, Lodi CA 95242
TELEPHONE NO.; (209) 663-2977 FAXNO.; (209)370-8281 FILED
E-MAIL ADDRESS: jjw1980(g!ive.com Superior Court Of CaVifomfa,
ATTORNEY FOR (Name): JarOSlaW WaSZCZUk

STREET ADDRESS; 720 9th Street
CITY AND ZIP CODE; Sacramento 95814
BRANCH NAME; Biii , Depu^
C a s B Numbur:
PLAINTIFF/PETITIONER: Jaroslaw Waszczuk
DEFENDANT/RESPONDENT: The Rcgcnts of the University of Califomia 34-2013-0015S47S
NOTICE O F E N T R Y O F DISMISSAL AND P R O O F O F S E R V I C E CASE NUMBER;
I I Personal Injury, Property Damage, or Wrongful Death
CZH Motor Vehicle [!• Other
I I Family Law 34-2013-00155479-CU-WT-GDS
1 1 Eminent Domain
rZJ other (specify): Wrongful Termination -Employment
TO ATTORNEYS AND PARTIES WITHOUT ATTORNEYS: A dismissal was entered in this action by the cJSrlâs shown on the
Request for Dismissal. (Attach a copy completed by the clerk.)
Date:
Jaroslaw Waszczuk N
(TYPE OR PRINT NAME OF I I ATTORNEY • I • 1 PARTY VtflTHOUT ATTORNEY) |f (SIGNATURE)
PROOF OF SERVICE
1. I am over the age of 18 and not a party to this cause. My residence or business address is:
2.1 >^ I I am a resident of or employed in the county where the mailing occurred. I served a copy of the Notice of Entry of
Dismissal and Request for Dismissal by mailing them, in a sealed envelope with postage fully prepaid, as follows:
a. I I I deposited the envelope with the United States Postal Sen/ice.
1} I I I placed the envelope for collection and processing for mailing following this business's ordinary practice with
which I am readily familiar. On the same day conrespondence is placed for collection and mailing, it is deposited
in the ordinary course of business with the United States Postal Service,
c. Date of deposit: 9/30/2015 d. Place of deposit (city and state): L o d i , C A 9 5 2 4 0
e. Addressed as follows (name and address):
Douglas Repel ,350 University AvejSuite 200; Sacramento 95825
3 I I I served a copy of the Notice of Entry of Dismissal and Request for Dismissal by personally delivering copies as shown below:
a. Name of person served:
b. Address at which person served:
c. On (dafe); d. At (time):
I served a copy of the Notice of Entry of Dismissal and Request for Dismissal by electronically sen/ing copies as shown below
(complete if electronic service is used based on a court order or agreement of the parties):
b. Electronic service address of person served:
c. On (date): d. At(f/me).-
e. Electronic service address from which I served the documents:
I I Proof of electronic service is attached.
5- I—I Proof of service on additional parties is attached.
Date: September 3 0 , 2 0 1 5
Irena Waszczuk ^
(TYPE OR PRINT NAME) (SIGNATURE OF DECLARANT) Page 1 of 1
Form Adopted for Mandatory Use Code of Civil Procedure, § 581 et seq.;
Judicial Council of Califomia NOTICE OF ENTRY OF DISMISSAL Cal. Rules of Court, mle 3.1390
CIV-120 [Rev. January 1,2012] www.courts.ca.gov
AND PROOF OF SERVICE
CIV-110
ATTORNEY OR PARTY wn>IOUT ATTORNEY (Wame, State Bar number, and address)
FOR COURT USE ONLY
Jaroslaw Waszczuk ; IN PR'O PER
2216 Katzakian Way , Lodi CA 95242
TELEPHONE NO: ( 2 0 9 ) 6 6 3 - 2 9 7 7 FMtÔ. (Optional): (209)370-8281
E-MAIL ADDRESS (Optional):jjw1980@live.com
ATTORNEY FOR (Wame;: Jaroslaw
Waszczuk
STREET ADDRESS: ^ 2 0 9 t h S t r e e t OCT - 1 2015
MAILING ADDRESS 720 9th street
CITY AND ZIP CODE: Sacramento, CA 95814
BRANCH NAME: Civil By R. CASTILLO
Deputy Clerk
PLAINTIFF/PETITIONER: Jaroslaw Waszczuk; IN PRO PER
DEFENDANT/RESPONDENT: The Regents of the University of California
REQUEST FOR DISMISSAL CASE NUMBER: 34-2013-00155479
A conformed copy will not be returned by the clerk unless a method of return is provided with the document.
This form may not be used for dismissal of a derivative action or a class action or of any party or cause of action in a
class action. (Cal. Rules of Court, rules 3.760 and 3.770.)
1. TO THE CLERK: Please dismiss this action as follows:
a. (1) I • I With prejudice (2) j j Without prejudice
b. (1) CZHJ Complaint
Complaint (2) £13 Petition
(3)1 ] Cross-complaint filed by (name): on (date):
(4) I I Cross-complaint filed by (name): on (date):
(5) I I Entire action of all parties and all causes of action
(6) I • ! Other (specify):* Defendants : Charles Witcher, Ann Madden Rice, Dorin Daniliuc , Patrick Putney
2. (Complete in all cases except family law cases.)
The court I I did I «^ I did not waive court fees and costs for a party in this cas|. (This infonnation m^jylfe obtained from
the clerk. If court fees and costs were waived, the declaration on the back off/?/;
Date: September 30, 2015
J^rpglavy Wqsai?uk . . . . .
(TYPE OR PRINT NAME OF I I ATTORNEY j • | PARTY WITHOUT ATTORNEY) '(SIGNATURE)
*lf dismissal requested is of specified parties only of specified causes of action Attomey or party without attorney for:
only, or of specified cross-complaints only, so state and identify the parties, I I Plaintiff/Petitioner I *^ I Defendant/Respondent
causes of action, or cross-complaints to be dismissed.
Cross-Complainant
3. TO THE CLERK: Consent to the above dismissal is hereby given.'
Date: 9/30/2015
Jaroslaw Waszczuk
(TYPE OR PRINT NAME OF j | ATTORNEY | • | PARTY WITHOUT ATTORNEY)
' If a cross-complaint - or Response (Family Law) seeking affirmative Attomey or party without attorney for:
relief - is on file, ttie attomey for cross-complainant (respondent) must
sign this consent if required by Code of Civil Procedure section 581 (I) I I Plaintiff/Petitioner I I Defendant/Respondent
orO).
I I Cross-Complainant
(To beafmpleted by clerk) _
4. I Ir I Dismissal entered as requested on (dafej: ULI ~ I tUID
5 I I Dismissal entered on (date): as to only (name):

6. I I Dismissal not entered as requested for the following reasons (specify):
7. a. I I Attorney or party without attomey notified on (date):

b. I I Attorney or party without attorney not notified. Filing party failed to provide
I I a copy to be conformed I I means to return conformed copy
Date: OCT - 1 2015 Clerk, by , Deputy

Page 1 of 2
Form Adopted for Mandatoiy Use Code of Civil Procedure, § 581 et seq.;
Judicial Council of California EQUEST FOR DISMISSAL Gov. Code, § 68837(c); Cal. Rules of Court, rule 3.1390
CIV-110 [Rev. Jan. 1,2013] www.courts.ca.gov
CIV-110
PLAINTIFF/PETITIONER: Jaroslaw Waszczuk ; IN PRO PER CASE NUMBER:
DEFENDANT/RESPONDENT: The Regents of the University of California 34-2013-00155479
COURT'S RECOVERY OF WAIVED COURT F E E S AND COSTS

If a party whose court fees and costs were initially waived has recovered or will recover $10,000 or
more in value by way of settlement, compromise, arbitration award, mediation settlement, or other
means, the court has a statutory lien on that recovery. The court may refuse to dismiss the case until
the lien is satisfied. (Gov. Code, § 68637.)
Declaration Concerning Waived Court Fees

1. The court waived court fees and costs in this action for (name):
2. The person named in item 1 is (check one below):
a- 1 «^ I not recovering anything of value by this action.
b. I I recovering less than $10,000 in value by this action.
c. I I recovering $10,000 or more In value by this action. (If item 2c is checked, item 3 must be completed.)
3.1 I All court fees and court costs that were waived in this action have been paid to the court (check one): I I Yes No
I declare under penalty of perjury under the laws of the State of California that the information above is true afidicorrect.
(TYPE OR PRINT NAME OF | | ATTORNEY [ • | PARTY MAKING DECLARATION) (SIGNATURE)
CIV-110 [Rev. January 1,2013] Page 2 of 2

REQUEST FOR DISMISSAL
Jaroslaw Waszczuk
2216 Katzakian Way
Lodi, CA 95242
Phone: 209-663-2977
Fax: 209-370-8281
IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA,

JAROSLAW WASZCZUK COURT OF APPEAL NO. C079524
Plaintiff and Appellant Sacramento County Superior Court

No. 34-2013-34-2013-00155479
v.
Notice of Appeal Filed On June 11, 2015
THE REGENTS OF THE Remittitur Issued on January 16, 2018

UNIVERSITY OF CALIFORNIA
Plaintiff’s and Appellant Request/Motion
Defendant and Respondent et al. for Judicial Notice
TO THE PRESIDING JUSTICE OF THE THIRD DISTRICT COURT OF

APPEAL:
-1-
REQUEST- MOTION FOR JUDICIAL NOTICE

REQUEST/MOTION TO TAKE JUDICIAL NOTICE IN
SUPPORT OF THE MOTION TO RECALL THE
REMITTITUR AND REINSTATE THE APPEAL OR,
ALTERNATIVELY, MODIFY THE UNPUBLISHED
OPINION
MEMORANDUM OF POINTS AND AUTHORITIES,
DECLARATION IN SUPPORT & PROPOSED ORDER.
Under California Rules of Court Rule 8.252, Plaintiff and Appellant

Jaroslaw Waszczuk (hereafter Waszczuk, pronounced “Vashchook”) moves
this Court to take judicial notice of the 47 exhibits attached to Waszczuk’s
Motion to Recall the Remittitur and Reinstate the Appeal or, Alternatively,
Modify the 10/10/2017 unpublished opinion in Waszczuk v. Regents of
Univ. of Cal., C079524 (Cal. Ct. App. Oct. 10, 2017).
Fully 95–98% of the 46 exhibits are documents that were filed and
docketed in Sacramento County Superior Court Departments 53 and 43 in
relation to the above-captioned case, No. 34-2013-34-2013-00155479;
Jaroslaw Waszczuk v. The Regents of the University of California Ann
Madden Rice, Mike Boyd, Stephen Chilcott, Charles Witcher, Danesha
Nichols, Cindy Oropeza, Brent Seifert, Patrick Putney, and Dorin Daniliuc
and 10/10/2017 Court of Appeal, Third Appellate District (3DCA)
Waszczuk v. Regents of Univ. of Cal., C079524 (Cal. Ct. App. Oct. 10,
2017) by Waszczuk and the Defendants.
Waszczuk moves this Court to take judicial notice of the 46 exhibits

attached to Waszczuk’s Motion to Recall the Remittitur in support of his
Motion to Recall Remittitur and in connection to Defendants’ filed Motion for
Summary Judgment or, in the Alternative, Summary Adjudication filed on
May 14, 2021. The Defendants’ Motion for Summary Judgment is the last
known act perpetrated by the Defendants’ Attorneys in an attempt to terminate
-2-

Waszczuk’s lawsuit by relitigating Waszczuk’s dismissed, defective Second
Amended Complaint (SAC) causes of actions filed on 12/1/2014, the
Defendants’ anti-SLAPP motion. Since the remittitur was issued on January
16, 2018, the Defendants have notoriously and without any hesitation abused
Judges and the Court system by their behavior litigating what was already
litigated and decided by three different Courts.
EXHIBITS’ NUMBERS AND NAMES
1. Remittitur to Trial Court Clerk, dated 01/16/2018
2. 10/10/2017- 3DCA unpublished opinions in the case Waszczuk v.

Regents of Univ. of Cal., C079524 (Cal. Ct. App. Oct. 10, 2017)
3. 02/09/2015- Court Order granting an anti-SLAPP motion to

Defendants Mike Boyd, Stephen Chilcott, Danesha Nichols, Brent
Seifert, and Cindi Oropeza in Sacramento County Superior Court Case
No: 34-2013-4. 00155479-CU-WT-GDS Waszczuk vs. The Regents of
the University of California, Hon. David I. Brown.
4. 04//25/2018- Defendant Regents of the University of California's

Request for Production of Documents to Plaintiff, set one
Support of Defendants' Motion to Compel Verified Responses for
Monetary and Terminating Sanctions, filed in the wrong Court,
Department 54
6. 10/11/2018- Waszczuk’s letter to Court Clerk in Department 54, Re:
Defendants’ 10/03/2018 Motion to Compel, monetary, and
terminating sanctions
-3-

7. 10/31/2018- Court Order sanctioning Waszczuk with $520. Re:
Defendants’ Motion to Compel, monetary and terminating
sanctions, Hon. David I. Brown
8. 11/14/2018- Duplicative Court Order sanctioning Waszczuk with
$520. Re: Defendants’ Motion to Compel, monetary and
terminating sanctions, Hon. David I. Brown
9. 02/08/2019- Court Order Re: Hearing on Order of Examination of
Judgment Debtor (Waszczuk) in Dept. 43, Hon. Thadd A. Blizzard
10. 02/10/2019- Waszczuk’s correspondence sent to Defendants’
Attorneys Daniel Bardzell and David Burkett, Re: Appearance and
Examination on February 8, 2019 at 9:00 a.m. at Department 43.
Hon. Thadd A. Blizzard, Case No. 34-2013-00155479, Jaroslaw
Waszczuk v. The Regents of the University of California- Meeting
summary with Bardzell
Defendant's Motion to Compel Further Verified Responses to
Special Interrogatories Set One, Form Interrogatories - General Set
One, Form Interrogatories - Employment Set One, and for
12. 03/11/2019- Waszczuk’s ex parte application for an order permitting
him to file late the Plaintiff's opposition to Defendants' Motion to
Compel and for monetary and terminating sanctions
13. 03/13/2019- Order Determining Disposition of 03/11/2019 of
Waszczuk Ex Parte Application, Re: Defendants’ Motion to Compel
and for monetary and terminating sanctions
-4-

15. 04/12/2019- Waszczuk’s Opposition to the Defendants’, the Regents
of the University of California, frivolous and unwarranted Motion to
Compel for monetary and terminating sanctions
16. 04/26/2019- Court Order sanctioning Waszczuk with $1300, Hon.
Steven H. Rodda, Dept. 53, Re: Defendants’ Motion to Compel for
Hon. Steven H. Rodda, Dept. 53. Defendants’ Motion to Compel for
monetary and terminating sanctions18. 06/12/2019-
Defendants’ Attorneys Daniel Bardzell and David Burkett,
Memorandum of Points and Authorities in Support of Defendants',
Motion to Compel Responses to Judgment Debtor Interrogatories
and Request for Production of Documents, and for monetary and
terminating sanctions19. 07/05/2019- Waszczuk’s Opposition to
the 06/12/2019 Defendants’ Motion to Compel Responses to
Documents, and for monetary and terminating sanctions
20. 07/05/2019- Waszczuk’s correspondence sent to the anti-SLAPP
motion Defendants’ former Attorneys Michael Pott and Douglas
Ropel, Re: legal fees awarded to them by the June 7, 2018 Court
Order, Hon. David I. Brown, Dept. 53
21. 05/22/2019 & 06/05/2019- Waszczuk’s inquiry sent to the State of
California Controller’s Office, Re: Waszczuk’s short-term disability
-5-

benefits, which were denied by Defendants in November 2011 but
resurfaced on March 21, 2019 as unclaimed property valued at
$4,545.08.
22. 05/14/2014- State of California Employment Development
Department (EDD) notification informing Waszczuk that his
unemployment insurance benefits was reinstated after previously
being denied in 2013 by EDD, and Waszczuk’s Inquiry with EDD
dated May 25, 2014.
23. 08/08/2019- The California State Bar Decision and a copy of check
No. 01844793 in the amount of $14,500 issued to Waszczuk by the
California State Bar Client Security Fund as a reimbursement for the
retainer stolen in 2014 from Waszczuk by his attorney Douglas
Stein. See Case : In re Stein, S245982 (Cal. Mar. 1, 2018)
24. 07/19/2019- Court Order sanctioning Waszczuk with $1300. Hon.
David I. Brown, Dept. 53, Re: Defendants’ 06/12/2019 motion to
compel for monetary and terminating sanctions
Hon. David I. Brown, Dept . 53, Re: Defendants’ 06/12/2019 motion
to compel for monetary and terminating sanctions
26. 10/23/2019- Defendants’ Attorneys Daniel Bardzell and Nancy
Sheehan, Memorandum of Points and Authorities in Support of
monetary sanctions
27. 10/24/2019- Defendants’ Attorney Daniel Bardzell’s e-mail
correspondence, Re: Defendants’ (the Regents of the University of
California) settlement offer
-6-

28. 05/21/2015- Waszczuk’ Response to the Defendants’ Attorney
David Burkett’s e-mail inquiry, dated May 19, 2015—Settlement
Offer
29. 11/15/2019- Defendants’ Attorney Daniel Bardzell’s correspondence
demanding Waszczuk pay the Regents of the University of
California the anti-SLAPP motion legal fees and monetary
sanctions
30. 11/18/2019- Copy of Check No. 139 in the amount of $1300 issued
by Waszczuk to the Regents of the University of California, with
attached 07/19/2018 Court Order which sanctioned Waszczuk with
$1300, Hon. David I. Brown
31. 12/04/2019- Waszczuk’s Opposition to 10/23/2019, Defendants’
Attorneys Daniel Bardzell and Nancy Sheehan’s Motion to Compel
Responses to Judgment Debtor Interrogatories and Request for
Production of Documents; and for monetary sanctions
and Daniel Bardzell’s reply to 12/04/2019, Waszczuk’s Opposition
to 10/23/2019- Defendants’ Attorneys Daniel Bardzell and Nancy
Sheehan’s Motion to Compel Responses to Judgment Debtor
monetary sanctions
and Daniel Bardzell’s second reply to 12/04/2019, Waszczuk’s
Opposition to the 10/23/2019, Defendants’ Attorneys Daniel
Bardzell and Nancy Sheehan’s Motion to Compel Responses to
Documents, and for monetary sanctions
-7-

34. 12/13/2019- Court Order Tentative Ruling sanctioning Waszczuk
with $1300, Hon. David I. Brown, Dept. 53, Re: 10/23/2019
Defendants’ Motion to Compel and for monetary sanctions
35. 12/17/2019- Court Order affirming 12/13/2019 Tentative Ruling,
Hon. David Brown, Dept. 53, Re: 10/23/2019 Defendants’ Motion to
Compel and for monetary sanctions
36. 12/27/2019- Waszczuk’s Notice of Objection to the 12/13/2019 and
12/17/2019 Court Orders, Hon. David I. Brown, Dept. 53, Re:
10/23/2019 Defendants’ Motion to Compel and for monetary
sanctions
37. 04/26/2021- Defendants’ Ex Parte Application for Leave to Extend
Page Limit for Defendant's Motion for Summary Judgment or, in the
Alternative, Summary Adjudication filed in violation of California
Rules of Court, Rule 3.1110 (b)(1) and under false pretenses.
38. 04/27/2021- Waszczuk’s meet and confer correspondence sent to
Defendants’ Attorney Amanda Goulding, Re: 04/26/2021,
Defendants’ Ex Parte Application for Leave to Extend Page Limit
for Defendant's Motion for Summary Judgment or, in the
Alternative, Summary Adjudication
39. 04/12/2021- Application and Order for Appearance and Examination
of Irina Waszczuk filed by the new Defendants’ Attorney Olatomiwa
T. Aina in Department 43, Hon. Thadd Blizzard.
40. 04/27/21- Waszczuk’s meet and confer correspondence with
attachments sent to the Defendants’ Attorney Olatomiwa T. Aina,
Re: 04/26/2021, Re: Subpoena and Application and Order for
Appearance and Examination Case No. 34-2013-00155479,
Jaroslaw Waszczuk v. The Regents of the University of California
-8-

41. 05/14/2021- Defendants’ Memorandum of Points and Authorities in
Support of Defendants' Motion for Summary Judgment or, in the
Alternative, Summary Adjudication relitigating dismissed COA’s
from Waszczuk SAC by Defendants’ anti-SLAPP motion, granted to
them on 04/14/2015
Support of Defendant's Motion for Automatic Stay, filed pursuant to
Stay. Motion was filed by Defendants to block Waszczuk’s proposed
Third Amended Complaint (TAC).
43. 10/28/2015- Court Order granting Defendants’ Motion for
Automatic Stay, filed pursuant to C.C.P. §916(a), or in the
Alternative, Motion for a Discretionary Stay. The Court Order
blocked Waszczuk’s proposed TAC, which was never was submitted
to and reviewed by the Court, Hon. David I. Brown, Dept. 53.
44. 09/03/2015- Copy of Waszczuk’s proposed TAC sent to Defendants’
Attorney Douglas Ropel for stipulation to file, and his 09/25/2015
negative response.
45. 09/30/2015- Waszczuk’s Request for Dismissal of four individual
defendants, Charles Witcher, Ann Maiden Rice, Dorin Daniliuc, and
Patrick Putney, from the Case No. 34-2013-00155479, Jaroslaw
Waszczuk v. The Regents of the University of California et al., filed on
10/01/2015.
46. 12/04/2013- Waszczuk’s initial Wrongful Termination with six
causes of action, which included: 5. Violation and Breach of the
2009 Settlement-Agreement, 6. Violation of UC Policy PPSM
(Employee Evaluation Policy). Complaint was docketed on December 4,
-9-

2013 in Sacramento County Superior Court as Jaroslaw Waszczuk v. The
Regents of the University of California Ann Madden Rice, Mike Boyd,
Stephen Chilcott, Charles Witcher, Danesha Nichols, Cindy Oropeza,
Brent Seifert, Patrick Putney, and Dorin Daniliuc.
47. May 31, 2015 Waszczuk’s inquiry sent to the Sedgwick Insurance
Company Litigation Specialist Carmen Angeles . Re: Anti-SLAPP
Motion approved by Sedgwick CMS Representative Greer Gustayson
Superior Court of California, County of Sacramento, Case No,: 34-2013-
001555479, Jaroslaw Waszczuk v. The Regent of the University of
California, and Case No. 34-2013-80001699; Court of Appeal Case No.:
C079254. Jaroslaw Waszczuk v. California Unemployment Insurance
Appeal Board (Respondent) & The Regents of the University of California
(Real Party in Interest) —OPEN LETTER
MEMORANDUM OF POINTS AND AUTHORITIES
Under Evidence Code section 459, a Court of Appeal has the same powers
of judicial notice as the trial court (Martin v. General Finance Co. (1966)
239 Cal.App.2d 438, 442 [“The power of this court to take judicial notice is
the same as that of the trial court”]). A reviewing court may properly rely
upon judicially noticeable materials that were not before the trial court.
(Hogen v. Valley Hospital (1983) 147 Cal.App.3d 119, 125 [“this court
may take judicial notice of matters which could have been noticed by the
trial court, even where the trial court was not requested to take such
notice”]; B & P Development Corp. v. City of Saratoga (1986) 185
Cal.App.3d 949, 960 [“An appellate court is permitted to take judicial
notice of any matter specified in Evidence Code section 452, although the
trial court did not take notice of it and it is not in the record, so long as a
- 10 -

record is made of the matter and each party is afforded an opportunity to
respond to it”]).
Evidence Code section 452, subdivision (d), authorizes judicial notice of
“[r]ecords of . . . any court of this state” (Taus v. Loftus (2007) 40 Cal.4th
683, 726 [court may take judicial notice of court records in related
proceedings relevant to the questions raised on appeal].
CONCLUSION
The attached exhibits are relevant and important to determine by the Court
of Appeal scale of the Defendants abuse of the Court system and the law by
maliciously and notoriously relitigating the causes of action which they
won in the Trial Court and on appeal. Thus, the anti-SLAPP motion the
Defendants filed on December 1, 2014 was a far more grievous abuse of the
judicial system than just filing the frivolous anti-SLAPP motion. Given
their gross misconduct in the Court of law, the Court of Appeal should
grant this request/motion for Judicial Notice to Waszczuk and recall the
remittitur in this wrongful termination case, which has been pending for
almost eight years.
Respectfully submitted on June 17, 2021.
________________________________
Jaroslaw Waszczuk
Plaintiff and Appellant in Pro Per
- 11 -

DECLARATION IN SUPPORT
I, JAROSLAW WASZCZUK, Plaintiff and Appellant, (hereafter

“Waszczuk”) declare the following:
Waszczuk has been representing himself in this Court proceeding
since December 16, 2014, due to misconduct by his former attorney,
Douglas Stein, who stole Waszczuk’s retainer and failed to object in a
timely manner to Defendants’ anti-SLAPP motion after it was filed on
December 1, 2014. See: In re Stein, S245982 (Cal. Mar. 1, 2018). Stein was
disbarred in January 2020. Waszczuk initially hired Douglas Stein in
November 2013 to handle the Writ of Mandamus in Jaroslaw Jerry
Waszczuk vs. California Unemployment Insurance Appeals Board (CUIAB)
and The Regents of the University of California as a Real Party of Interest,
Case Number 34-2013-80001699-CU-WM-GDS, 3DCA Case Waszczuk v.
Cal. Unemployment Ins. Appeals Bd., C079254 (Cal. Ct. App. Dec. 27,
2018).
The Writ of Mandamus Case never should go further than to May 14, 2014
(see Exhibit 22), when Waszczuk’s initially denied unemployment benefits
were reinstated by the Employment Development Department (EDD), due
to CUIAB’s Chief Counsel Kim Steinhardt’s investigation. Waszczuk
briefed 3DCA about his stolen unemployment benefits in Appellant Reply
Brief in Waszczuk v. Cal. Unemployment Ins. Appeals Bd., C079254 (Cal.
Ct. App. Dec. 27, 2018). Apparently, his reinstated EDD unemployment
insurance benefits were intercepted in May 2014 by attorney Douglas Stein,
who was struggling with drug addiction at the time, or the Defendants’
attorneys to create greater financial hardship for Waszczuk, who had been
- 12 -

living on his Social Security income and the proceeds from a 401K plan
since June 2013.
The Defendants, the Regents of the University of California and university

employees five anti-SLAPP motion Defendants Danesha Nichols, Stephen
Chilcot, Mike Boyd, Brent Seifert, and Cindy Oropeza, are privileged to be
Exempt from Filing Fees Pursuant to Government Code §6103 and as a $40
billion annual budget exempt from federal income tax entity under Internal
Revenue Code §501(c)(3), so they can afford to relitigate endlessly and
vexatiously those matters which have already been litigated. The Regents of the
University of California can also abuse the California court system, which is
struggling financially and is overloaded with millions of cases to resolve due to
malicious and vexatious litigants like the Regents of the University of
California and paid by regents legal renegades and totally demoralized
attorneys from the Porter Scott . Waszczuk is on a fixed income of $1500
Social Security and has no other choice but to challenge these matters himself,
without any help. The Defendants’ lawyers, who were and are being paid for
their notorious abuse of the Court system on behalf of regents by Sedgwick
Insurance Company.
Waszczuk addressed the anti-SLAPP motion legal fees in his May 31,
2015 inquiry, which was sent to the Sedgwick Litigation Specialist Carmen
Angeles. In in his May 31, 2015 correspondence to Sedgwick, Waszczuk also
addressed the August 2011 workers compensation claim handled by Sedgwick
on behalf of the Regents of the University of California in which the
Defendants and Sedgwick attempted to force Waszczuk to file false Workers
Compensation Claim and to go away. Waszczuk don’t frauds and he refused to
collaborate .
- 13 -

(Exhibit # 47) Sedgwick, with whom Porter Scott’s attorneys prearranged and
approved in September 2014 an anti-SLAPP motion, paid to Porter Scott’s
attorneys anti -SLAPP motion legal fees most likely after Sedgwick’s Litigation
Specialist Carmen Angeles received Waszczuk’s May 31, 2015 inquiry, which
Waszczuk also sent by e-mail to Sedgwick's fraud special investigation unit
(SIU). Sedgwick most likely advised Porter Scott’s attorneys not to pursue the
legal fees in Court. Waszczuk addressed Sedgwick’s anti-SLAPP motion
approval to 3DCA Court in his filing on 10/25/2017 Petition for Rehearing on
page No. 31 Waszczuk v. Regents of Univ. of Cal., C079524 (Cal. Ct. App. Oct.
10, 2017).
CONCLUSION
Prior the remittitur issued by the Court of Appeal, Waszczuk briefed the
Court about his Attorney’s and the Defendants’ misconduct in his Appellant
Opening and Reply Brief in 2016, and in his Petition for Rehearing after the
unpublished opinion was issued in Waszczuk v. Regents of Univ. of Cal.,
C079524 (Cal. Ct. App. Oct. 10, 2017).
Waszczuk prepared this Request/Motion for Judicial Notice to support

his Motion to Recall Remittitur in the Waszczuk v. Regents of Univ. of Cal.,
C079524 (Cal. Ct. App. Oct. 10, 2017) himself and diligently selected the
exhibits for this motion to show to the Court of Appeal the Defendants’ and
their attorneys’ abuse of the Court system. All exhibits attached to Waszczuk’s
Motion to Recall the Remittitur and this Motion for Judicial Notice show the
Defendants and their attorneys do not care that anyone else wants to have their
day in court to be heard, but litigants like the Regents of the University of
California and their notorious attorneys from Porter Scott it make it impossible.
- 14 -

The Defendants and their attorneys from Porter Scott are vexatiously and
recklessly relitigating the dismissed causes of action from Waszczuk’s faulty
Second Amended Complaint and expect to be paid for something despite
having nothing more to litigate.
In Guess?, Inc. v. Superior Court, 79 Cal.App.4th 553 (Cal. Ct. App.

2000) the Court ruled:
“We conclude otherwise on the theory that, in litigation as in life, you can’t
have your cake and eat it too.” Citing:
Koerner v. American Express Co. (5th Cir. 1980) 615 F.2d
191, 192 [we "base our holding primarily on a principle
almost as old as flour: You cannot have you cake and eat it
too"]; Milevoi v. Alamilla (1981) 435 N.Y.S.2d 246, 248
[perhaps "the most apt description of the within case is that
`you can't have your cake and eat it too'"]; First Trust Co.
of Albany v. Dumary (1940) 23 N.Y.S.2d 532, 536 [there
"is an old maxim that, `you can't have your cake and eat it
too', and this bit of wisdom is strictly applicable to
defendant in this action"].
The Guess?, Inc. v. Superior Court case is strictly applicable to the
Defendants’ and their Attorneys’ abusive and vexatious litigation of the
matters that have already been litigated and in which they prevailed.
In light of the above-presented facts, Waszczuk’s Declaration in
Support prays that the Motion for Judicial Notice should be granted to
Waszczuk and other relief sought by him should be granted, as well and
that the remittitur should be recalled.
I make this Declaration on my own personal knowledge. If called
upon to do so, I could and would competently testify about the matters
asserted herein.
I declare under the penalty of perjury under the laws of the State of
- 15 -

California that the foregoing is true and correct and that this Declaration
was executed on the 18th day of June, 2021 at Lodi , California.
_________________________________________
Jaroslaw Waszczuk,
Plaintiff and Appellant, In Pro Per.
- 16 -


this Request /Motion for Judicial Notice including Declaration in support
of this motion contains 3448 words, based on the word- count feature of
my word-processing program.
Jaroslaw Waszczuk
_______________________
Plaintiff & Appellant, In Pro Per
- 17 -

Re: Waszczuk v. Regents of Univ. of Cal., C079524 (Cal. Ct. App. Oct. 10,
2017)
I, IRENA WASZCZUK the undersigned, declare that 1 am over 18 years of

age and not a party to the within cause; my address is 2216 Katzakian Way,
Lodi, CA. 95242. On June 18, 2021, I served a true copy of the attached
each of the following,
Request/Motion for Judicial Notice in Support of Motion to Recall
Remittitur.



350 McAllister St.

California that the foregoing is true and correct. Executed on June 18,
2021 , at Lodi CA
_____________________________________________________
IRENA WASZCZUK
- 18 -

EXHIBITS 1-47
- 19 -

EXHIBIT # 1
EXHIBIT # 2
NOT TO BE PUBLISHED

(Sacramento)
----

34201300155479CUWTGDS)
v.

CALIFORNIA et al.,

1
2
3
FACTS
4
September 30, 2014.
5
Plaintiff appeals.
DISCUSSION
I
The Allegations
6
7
8
II
The Merits
9
10
termination.”
11
prevailing.
12
(Gov. Code, § 8547.10.)
III
13
DISPOSITION
RAYE , P. J.
We concur:
NICHOLSON , J.
ROBIE , J.
14
EXHIBIT # 3
MINUTE ORDER
DATE: 02/09/2015 TIME: 09:37:00 AM DEPT: 53
CLERK: K. Pratchen
REPORTER/ERM:

EVENT TYPE: Motion to Strike (SLAPP) - Civil Law and Motion - MSA/MSJ/SLAPP
APPEARANCES
Nature of Proceeding: Ruling On Submitted Matter (Motion to Strike (SLAPP)) Taken Under
Submission 2/6/2015
TENTATIVE RULING
Defendants Michael Boyd, Stephen Chilcott, Danesha Nichols, Cindy Oropeza and Brent Seifert's
Special Motion to Strike the First through Fourth Causes of Action of Self-represented Plaintiff's Second
Amended Complaint is GRANTED.
This motion was continued to today's date to permit the self-represented plaintiff to file his own
opposition to the motion. Although no substitution of attorneys has yet been filed with the Court, the
court accepts the representation of plaintiff in his Dec. 29, 2014 Declaration in which declared that he
terminated Douglas Stein as his counsel of record on Dec. 16, 2014. A substitution of attorneys
signed by both former attorney and the plaintiff is still required to be filed with the Court by
plaintiff.
At the plaintiff's request, the Court has considered none of the papers filed by his former attorney
Douglas E. Stein in opposition to this motion. The Opposition papers filed by the self-represented
plaintiff were filed and served by US Mail on Jan. 23, 2015, instead of on Jan. 21, 2015, as ordered by
the Court. Further, the service was by US Mail, rather by personal delivery, facsimile transmission,
express mail, or other means reasonably calculated to ensure delivery to the other party or parties not
later than the close of the next business day after the time the opposing papers are filed, as required by
Code Civ. Proc. § 1005(b). Moving party has therefore been deprived of at least three business days in
which to prepare their reply.
Additionally plaintiff's opposing Memorandum of Points and Authorities exceeds the 15 page limit
provided in California Rules of Court, Rule 3.1113. Despite this failure to comply with the California
Rules of Court, the Court has read and considered the entire 34 page document. In future filings, absent
ex parte order permitting a longer memorandum, the self-represented plaintiff is admonished to abide by
the page limitations.

As noted, despite these failures to comply with the Court order and the applicable statutes, the Court has
considered plaintiff's opposition papers.
The Court declines to consider plaintiff's 17 page "Response to Defendant's Reply Brief" with attached
filed on Feb. 2, 2015, as there is no statutory right to such a supplemental brief.
At the outset, the Court would note that a self-represented party is to be treated like any other party and
is entitled to the same, but no greater consideration than other litigants and attorneys. (Williams v.
Pacific Mutual Life Ins. Co. (1986) 186 Cal. App. 3d 941, 944) Thus, as is the case with attorneys,
self-represented litigants must follow correct rules of procedure. Nwosu v. Uba (2004) 122 Cal. App. 4th
1229, 1246-1247; see also Rappleyea v. Campbell (1994) 8 Cal. 4th 975, 984.
Second Amended Complaint
Plaintiff's Second Amended Complaint sets forth eight causes of action: the 1st for intentional infliction of
emotional distress, 2nd for tortious interference with economic advantage, 3rd for harassment, failure to
prevent harassment, discrimination and retaliation under FEHA, 4th for whistleblower/unlawful
retaliation, 5th for violation of Health & Safety Code, sec. 1278.5, 6th for breach of written contract, 7th
for wage and hour violations and 8th for rescission - unlawful contract.
Moving party defendants move to specially strike the 1st through 4th causes of action, only, as each
arises out of acts in furtherance of the right of petition or free speech in connection with a public issue
and plaintiff cannot establish a likelihood of success on the merits.
Anti-SLAPP procedure
The Court must follow a "two-step process for determining whether an action is a SLAPP." Navellier v.
Sletten (2002) 29 Cal.4th 82, 88. First, whether the defendant has made a threshold prima facie
showing that the defendant's acts, of which the plaintiff complains, were ones taken in furtherance of the
defendant's constitutional rights of petition or free speech in connection with a public issue. If the court
finds that such a showing has been made, then the plaintiff will be required to demonstrate that "there is
a probability that the plaintiff will prevail on the claim." The defendant has the burden on the first issue,
the threshold issue; the plaintiff has the burden on the second issue. Kajima Engineering & Construction,
Inc. v. City of Los Angeles (2002) 95 Cal.App.4th 921, 928. "Only a cause of action that satisfies both
prongs of the anti-SLAPP statute--i.e., that arises from protected speech or petitioning and lacks even
minimal merit--is a SLAPP, subject to being stricken under the statute." Navellier v. Sletten (2002)29
Cal.4th 82, 89.
Petition or Free Speech
Code Civ. Proc. § 425.16 (e) provides: "As used in this section, "act in furtherance of a person's right of
petition or free speech under the United States or California Constitution in connection with a public
issue" includes: (1) any written or oral statement or writing made before a legislative, executive, or
judicial proceeding, or any other official proceeding authorized by law, (2) any written or oral statement
or writing made in connection with an issue under consideration or review by a legislative, executive, or
judicial body, or any other official proceeding authorized by law,..."
The California legislature enacted Code of Civil Procedure section 425.16, known as the anti-SLAPP
statute, to provide a procedural remedy to dispose of lawsuits and causes of action that are brought to
chill the valid exercise of the constitutional rights to free speech and to petition the government for

redress of grievances.(See Rusheen v Cohen (2006) 37 Cal.4th 1048, 1055-1056. These provisions
apply to SLAPP suits brought against public entities and public employees. See San Ramon Valley Fire
Prot Dist v Contra Costa County Employees' Ret Ass'n (2004) 125 Cal.App.4th 343, 353; see also City of
Cotati v. Cashman (2002) 29 Cal. 4th 69.
It is well established that the policies of Defendant University, including the Personnel Policies for Staff
Members ("PPSM") and UC Davis Policy and Procedure Manual ("PPM"), have the force and effect of
state statute. (Kim v. Regents of University of California (2000) 80 Cal.App.4th 160, 165.)
Statutory procedures qualify as official proceedings authorized by law for section 425.16 purposes.
(Vergos v. McNeal (2007) 35 Cal.App.4th 1387, 1399.) The constitutional right to petition includes the
act of seeking administrative action. (Briggs v. Eden Council for Hope & Opportunity (1999) 19 Cal.4th
115.) Investigations and investigatory reports prepared in connection with an issue under consideration
or review by an official body, such as a public entity's internal investigations, are protected activities
under the anti-SLAPP statute. (See Miller v. City of Los Angeles (2009) 169 Cal App.4th 1373, 1383;
Hansen v California Dept of Corrections and Rehabilitiation (2008) 171 Cal.App.4th 1537, 1544; Briggs v.
Eden Council for Hope & Opportunity (1999) 19 Cal. 4th 1106.)
In this case, the speech by Chilcott, Boyd, Oropeza, Seifert, and Nichols that is at issue were made in
connection with the processing, investigation, hearing and deciding the workplace complaints filed by
Plaintiff and others pursuant to University policies.
The allegations of the SAC against Nichols attack her protected participation in the official investigations.
The SAC specifically alleges Nichols' communications regarding the investigation. (SAC, paras. 70 (l),
(o), (q), (s), (x), (AA)) and her investigative conclusions (SAC para. 70 (v), (KK)). Nichols was appointed
to investigate Plaintiffs whistleblower complaints, and was also appointed to conduct an investigation
into complaints of workplace violence filed by Putney and Daniliuc. All were protected petitioning
activities.
The allegations against Boyd and Chilcott are limited to their receipt of emails from Nichols relating to
the investigations, and Chilcott's sending of an email relating to the investigation of Plaintiff (SAC, para.
70(m), (x), (AA).) The emails are protected speech in connection with an investigation process.
The allegations against Oropeza and Seifert are based upon their investigation into the emails plaintiff
sent to Nichols in April 2012. Oropeza and Seifert conducted their investigation pursuant to the
University's grievance protocol and reached conclusions documented in a report.
Boyd acted as Complaint Resolution Officer ("CRO") at Step II of the University's PPSM 70 process,
hearing and deciding Plaintiff's appeal of his termination. In Vergos, supra, 146 Cal.App.4th at
1399-1400, the Court held that defendant reviewer was entitled to the protection of the anti-SLAPP
statute for denying the grievance. Specifically, in Vergos, a state university employee pursued an
internal grievance against his supervisor for sexual harassment. In an administrative proceeding
authorized by the Regents of the University of California, the hearing officer denied the grievance. The
employee then filed a civil rights suit against the hearing officer, alleging that her decision had failed to
protect him from future harassment. (Id. at pp. 1390-1392, 1396-1397.) The hearing officer filed a
special motion to strike, contending that her communications were made in connection with an issue
under consideration in an official proceeding. (See § 425.16, subd. (e)(2).) The trial court denied the
motion. The Court of Appeal reversed because "[t]he gravamen of plaintiff's [claim] is [the hearing
officer's] communicative conduct in denying plaintiff's grievances. The hearing, processing, and
deciding of the grievances (as alleged in the complaint) are meaningless without a communication of the
adverse results." (146 Cal.App.4th at p. 1397.) Thus, Vergos recognized that the anti-SLAPP statute

applies where liability is based on protected speech. (See Id. at pp. 1397-1399)
Moving parties have established that their speech and writings are protected as made in connection with
an issue under consideration or review by an official proceeding authorized by law. The burden
therefore shifts to plaintiff to show that he will prevail.
Probability That Plaintiff Will Prevail
Plaintiff must show a likelihood of prevailing on each of the elements of his causes of action, and must
also show a likelihood of defeating any applicable affirmative defenses. (Wilcox v. Superior Court (1994)
27 Cal.App.4th 809, 820, 824; see also Paul of Council v. Hanyecz (2001) 85 Cal.App.4th 1356, 1367,
overruled on other grounds in Equilon Enterprises v. Consumer Cause, Inc. (2002) 29 Cal.4th 53, 68.)
The test to use to determine Plaintiffs probability of prevailing is similar to the standard applied to
evidentiary showings in motions for summary judgment, and the supporting facts must be demonstrated
by way of competent, admissible evidence. (Church of Scientology v. Wollersheim (1996) 42 Cal.App.4th
628, 654-655.) The difference between summary judgment and anti-SLAPP is that the burden is on the
opposing party plaintiff to show the likelihood of prevailing.
In order to establish the necessary probability of prevailing, plaintiff was required both to plead claims
that were legally sufficient, and to make a prima facie showing, by admissible evidence, of facts that
would merit a favorable judgment on those claims, assuming plaintiff's evidence were credited. The court
does not, however, weigh the parties' evidence, in terms of either credibility or persuasiveness. Rather,
the defendant's evidence is considered with a view toward whether it defeats the plaintiff's showing as a
matter of law, such as by establishing a defense or the absence of a necessary element. 1-800
Contacts, Inc. v. Steinberg (2003) 107 Cal. App. 4th 568, 584-585.
1st For Intentional Infliction of Emotional Distress
An essential element of pleading a claim for intentional infliction of emotional distress is a showing of
outrageous conduct beyond the bounds of human decency. Managing personnel is not outrageous
conduct beyond the bounds of human decency, but rather conduct essential to the welfare and
prosperity of society. A simple pleading of personnel management activity is insufficient to support a
claim of intentional infliction of emotional distress, even if improper motivation is alleged. If personnel
management decisions are improperly motivated, the remedy is a suit against the employer for
discrimination. Janken v. GM Hughes Electronics (1996) 46 Cal. App. 4th 55, 80.
What plaintiff has alleged, and what his evidence in opposition appears to support, are complaints
concerning personnel management by defendants. Pleading of personnel management activity is
"insufficient to support a claim of intentional infliction of emotional distress, even if improper motivation is
alleged." (Janken, supra.)
2nd Tortious Interference with Economic Advantage
Plaintiff's claim tortious interference with economic advantage against Defendants. An employee or
former employee cannot sue a current or former supervisor or employee for interfering with his or her
prospective economic advantage by inducing the employer to terminate the plaintiff's employment.
(Shepperd v. Freeman (1998) 67 Cal.App.4th 339, 347; Shoemaker v. Myers (1990) 52 Cal.3d 1, 24.)


3rd for Discrimination
In the third cause of action, Plaintiff alleges violation of FEHA, both Section 12940(a) which prohibits
discrimination and Section 12940(k) which addresses the failure to prevent discrimination.
These claims are not properly pleaded against the individual Defendants as individuals cannot be sued
for discrimination under the FEHA, nor can they be sued for failing to prevent discrimination, retaliation,
and harassment. (Reno v. Baird (1998) 18 Cal.4th 640, 663- 664; see, also Janken, supra, at p. 63.) In
Janken the Supreme Court noted the "fundamental distinction" between the way the FEHA treats
harassment, on the one hand--for which supervisors may be held personally liable, and discrimination on
the other hand--for which, Janken held, individuals are not personally responsible.
4th for Whistleblower/Unlawful Retaliation

Plaintiff's Fourth Cause of Action brought pursuant to Gov. Code § 8547.10 for whistleblower retaliation.
Plaintiff has not established that moving defendants' conduct was in retaliation for plaintiff's
whistleblowing.
The mere fact that Nichols, Oropeza and Seifert conducted investigations and reached conclusions with
which Plaintiff does not agree with does not establish their investigatory findings are an act of retaliation.
Nor can Boyd's decision to deny Plaintiffs grievance at the Step II level of PPSM 70 review be deemed
to be a retaliatory action. Finally, there is no allegation that Chilcott took any particular action against
Plaintiff that could be deemed to be a retaliatory action.
As a matter of law, Plaintiff has not shown that he can prevail on any of his four causes of action against
moving party defendants. Given the Court's determination the Court need not address the Regents'
other arguments based on Gov't Code 821.6. It bears noting, however, that immunity extends to
investigations even if there is a later decision not to institute administrative proceedings or to initiate a
prosecution. See Ingram v Flippo (1999) 74 Cal.App.4th 1280, 1293.
The anti-SLAPP motion is therefore granted as to moving defendants Michael Boyd, Stephen Chilcott,
Danesha Nichols, Cindy Oropeza and Brent Seifert only, as to the 1st through 4th causes of action, only.
The Discovery Stay is ordered lifted.

Prevailing defendants on a motion to strike must file a separate motion to recover their attorneys' fees
and costs.
The prevailing parties shall prepare a formal order for the Court's signature pursuant to C.R.C. 3.1312.

COURT RULING

The Court affirms the tentative ruling.

MINUTE ORDER
DATE: 04/14/2015 TIME: 02:00:00 PM DEPT: 53
CLERK: E. Brown
REPORTER/ERM:

APPEARANCES
Nature of Proceeding: Ruling on Submitted Matter (Motion for Reconsideration of the 2/9/2015
Order) taken under submission on 4/10/15
TENTATIVE RULING
Self-represented Plaintiff's Motion for Reconsideration of Order Dated Feb. 9, 2015 Anti-SLAPP Motion
is DENIED.
A self-represented party is to be treated like any other party and is entitled to the same, but no greater
consideration than other litigants and attorneys. (Williams v. Pacific Mutual Life Ins. Co. (1986) 186 Cal.
App. 3d 941, 944) Thus, as is the case with attorneys, self-represented litigants must follow correct rules
of procedure. Nwosu v. Uba (2004) 122 Cal. App. 4th 1229, 1246-1247; see also Rappleyea v. Campbell
(1994) 8 Cal. 4th 975, 984.
Plaintiff's motion for reconsideration was filed and served by US Mail on Feb. 20, 2015. No hearing date
appeared on the Motion papers. On Feb. 25, 2015, an Amended Notice of Motion reflecting the hearing
date of March 6, 2015 was filed and served by US Mail. That notice, counting backwards from March 6
to Feb. 20, allowed only 10 court days' notice instead of the required16 court days' notice, and allowed
none of the five additional calendar days for service by mail, as required by C.C.P., sec. 1005 and 12c.
The hearing date was continued to today's date at the request of the moving party.
Defendant's opposition to the motion for reconsideration objects to the untimely notice and further
asserts that moving party has failed to meet the requirements of a motion for reconsideration under
C.C.P., sec. 1008.
A motion for reconsideration must be made (i) within 10 days after service upon the party of written
notice of entry of the order and (ii) based upon new or different facts, circumstances, or law, and (iii) to
the same judge or court that made the order. C.C.P. section 1008(a). C.C.P. section 1008 is the
exclusive means for modifying, amending or revoking an order. That limitation is expressly jurisdictional.

Morite of California v. Superior Court (1993) 19 Cal. App. 4th 485, 490.
Moving party fails to base his motion for reconsideration upon any new or different facts, circumstances,
or law. Instead, plaintiff contends that the Court failed to read his opposition and attached exhibits to the
anti-SLAPP motion. Moving party contends that the Court should have accepted his supplemental brief,
which argues that the SLAPP motion violated an earlier stipulation between the parties to permit the
filing of a second amended complaint, that some unidentified new authority applies to the anti-SLAPP
motion in an unidentified manner and that the Court erred in its anti-SLAPP ruling.
None of these contentions is sufficient to satisfy the statutory requirements that the motion for
reconsideration be "based upon new or different facts, circumstances, or law."
A trial court has no jurisdiction to reconsider a prior order on the basis of different facts, circumstances
or law in the absence of a satisfactory explanation for the failure to present them earlier. Baldwin v.
Home Savings of America (1997) 59 Cal. App. 4th 1192, 1200. Further, if the plaintiff is not required to
explain the failure to earlier produce pertinent legal authority that was available, the ability of a party to
obtain reconsideration would expand in inverse relationship to his competence. Without a diligence
requirement the number of times a court could be required to reconsider its prior orders would be limited
only by the ability of the party to belatedly conjure a legal theory different from those previously rejected,
which is not much of a limitation. Baldwin v. Home Savings, supra, 59 Cal. App. 4th 1192, 1199.
The Court has read and considered plaintiff's objections to the formal order. The Court will sign the
formal order submitted on the anti-SLAPP motion.
COURT RULING
The matter was argued and submitted. The Court affirmed the tentative ruling.

Dated: April 14, 2015
JAROSLAW WASZCZUK
2216 KATZAKIAN WAY
LODI, CA 95242

DAVID P.E. BURKETT

PORTER SCOTT

OEPAR
P O R T E R I S C O T T APR 1 4 •
Douglas L. Ropel, SBN 300486
Sacramento, California 95825
TEL: 916.929.1481
FAX: 916.927.3706
dburkettfalporterscott.com
6
7
CINDY OROPEZA. PATRICK PUTNEY, ANN MADDEN RICE,
10
Exempt from Filing Fees Pursuant to Government Code § 6103
11
^ 12 SUPERIOR COURT OF CALIFORNIA, COUNTY OF SACRAMENTO
13
H 3 S _ VD
^ tn m OO ^
o 2 P; 14
> U O; Os JAROSLAW ("JERRY") WASZCZUK, CASENO. 34-2013-00155479
15
: 0\ ON
Plaintiff, ' -feROPeSBDi- ORDER GRANTING
DEFENDANTS BOYD, CHILCOTT,
3
17 NICHOLS, OROPEZA AND SEIFERT'S
SPECIAL MOTION TO STRIKE FIRST
18 THE REGENTS OF THE UNIVERSITY THROUGH FOURTH CAUSES OF
19 OF CALIFORNIA, UNIVERSIW OF ACTION OF PLAINTIFlP'S SECOND
GALIFORNL\ DAVIS HEALTH SYSTEM, AMENDED COMPLAINT
DAVIS, ANN MADDEN RICE, MIKE DATE: February 6,2015
21 BOYD, STEPHEN CHILCOTT, CHARLES TIME: 2:00 P.M.
22 WITCHER DANESHA NICHOLS. CINDY DEPT: 53
23 PUTNEY. DORIN DANILIUC, and does I
through 50. inclusive. Complaint Filed: December 12,2013
24
25 Defendants SAC Filed: September 30,2014
26
///
27
28 ///
{01362378.OOCX} 1
SEIFERT'S SPECIAL MOTION TO STRIKE FIRST THROUGH FOURTH CAOSES OF ACTION OF
1 Defendants MIKE BOYD, STEPHEN CHILCOTT, DANESHA NICHOLS, CINDY
2 OROPEZA, and BRENT SEIFERT ("Defendants") filed a Special Motion to Strike four causes of
3 action, as pleaded against them, from PlaintifTs Second Amended Complaint pursuant to Code of
4 Civil Procedure section 425.16. Specifically, Defendants brought the Motion to strike Plaintiffs
5 causes of action against them for: (1) Intentional Infliction of Emotional Distress; (2) Tortious
6 Interference with Economic Advantage; (3) Discrimination and Failure to Prevent Harassment,
7 Discrimination, and Retaliation under Government Code section 12940, subdivisions (a) and (k);
S and (4) Whistleblower Retaliation under Govemment Code section 8547 et seq.
9 On Febmary 5, 2015, the Court issued a Tentative Ruling, which is incorporated as
10 Exhibit A, granting Defendants' Motion.,; Pursuant to PlaintifPs request, the Motion was heard
11 before the Honorable Judge David I. Brown on Febmary 6, 2015. After hearing from the parties
12 and taking the matter under submission, the Court affirmed its Tentative Ruling vîth the issuance
o
o
a in 13 of a Minute Order on Febmary 9, 2015. The Court's Minute Order ruled as follows:
^ -3 (N
— \o
P eS IS» S
14 Defendants Michael Boyd, Stephen Chilcott, Danesha Nichols, Cindy
îs < o"
ai 1^
o.<=^.
!£ £
1c
1J V 'Oropeza and Brent Seifert's Special Motion to Strike the First thfough
Fourth Causes of Action of Self-represented Plaintiffs Second Amended
W >. c ^ >< 16 Complaint is GRANTED.
fell ^ 5: ,
211 17 This motion was continued to permit the self-represented plaintiff to file
o his own opposition to the motion. Although no substitution of attorneys
18 has yet beenfiledwith the Court, the Court accepts the representation of
I plaintiff in his Dec. 29, 2014 Declaration in which declared that he
19
terminated Douglas Stein as his counsel of record on Dec. 16, 2014. A
20 substitution of attorneys signed by both former attorney and the
plaintiff is still required to befiledwith the Court by piaintifT.
21
22 At the plaintiffs request, the Cpurt has considered none of the papers filed
by his former attomey Douglas E. Stein in opposition to this motion. The
23 Opposition papers filed by the self-represented plaintiff were filed and
served by US Mail on January 23, 2015, instead of on January 21,2015, as
24 ordered by the Court. Further, the service was by US Mail, rather by
25 personal delivery, facsimile transmission, express mail, or other means
reasonably calculated to ensure delivery to the other party or parties not
26 later than the close of the next business day after the time the opposing
papers are filed, as required by Code Civ. Proc. § 1005(b). Moving party
27 has therefore been deprived of at least three business days in which to
28 prepare their reply.
I0I362378.DOCX} 2_
jPROPOSEDj ORDER GRANTING DEFENDANTS BOYD, CHILCOTT, NICHOLS, OROPEZA AND
\
Additionally, plaintiff's opposing Memorandum of Points and Authorities
exceeds the 15 page limit provided in Califomia Rules of Court, Rule
2 3.1113. Despite this failure to comply with the Califomia Rules of Court, ^
the Court has read and considered the entire 34 page document. In future
3 filings, absent ex parte order pemiitting a longer memorandum, the self-
4 represented plaintiff is admonished to abide by the page limitations.
5 As noted, despite these failures to comply with the Court order and the
applicable statutes, the Court has considered plaintiffs opposition papers.
6 The Court declines to consider plaintiffs 17 page "Response to
7 Defendant's Reply Brief filed on Feb. 2, 2015, as there is no statutory
right to such a supplemental brief.
8 f
9
10 At the outset, the Court would note that a self-represented party is to be
treated like any other party and is entitled to the same, but no greater
II consideration than other litigants and attomeys. (Williams v. Pacific
Mutual Ufe Ins. Co. (1986) 186 Cal. App. 3d 941, 944) Thus, as is the
12
o case with attomeys, self-represented litigants must follow correct rules of
o
Ol
a in 13 procedure. Nwosu v. Uba (2004) 122 Cal. App. 4th 1229, 1246-1247; see
[ _
3 0 0 — >o also Rajjpleyea v. Campbell (1994) 8 Cal. 4th 975, 984.
CO V% oo O
O 6' ' t 14
O 5 < >- Second Amended Complaint
Vi g S S
> VJ ^ o> 15
^ < g
o tu <
>6 «> 16 Plaintiffs Second Amended Complaint sets forth eight causes of action:
o r- u. (1) intentionaL infliction of emotional distress; (2) tortious interference
17 with economic advantage; (3) harassment, failure to prevent harassment,
ex. discrimination and retaliation under FEHA; (4) whistleblower/unlawful
18
retaliation; (5) violation of Health & Safety Code section 1278.5; (6)
19 breach of written contract; (7) wage and hour violations; and (8) rescission
- unlawful contract.
20
21 Moving party defendants move to specially strike the 1st through 4th
causes of action, only, as each arises out of acts in furtherance of the right
22 of petition of free speech in connection with a public issue, and plaintiff
cannot establish a likelihood of success on the merits. '
23
24 Anti-SLAPP procedure
25 The Court must follow a "two-step process for determining whether an

action is a SLAPP." Navellier v. Sletien (2002)' 29 Cal.4th 82, 88. First,
26 whether the defendant has made a threshold prima facie showing that the
27 defendant's acts, of which the plaintiff complains, were ones taken in
furtherance of the defendant's constitutional rights of petition or free
28 speech in connection with a public issue. If the court finds that such a
(0I362378.DOCX)
(PROPOSEDI ORDER GRANTING DEFENDANTS BOYD, CHILCOTT, NICHOLS,' OROPEZA AND
showing has been made, then the plaintiff will be required to demonstrate
that "there'is a probability that the plaintiff will prevail on the claim." The
defendant has the burden on the first issue, the threshold issue; the
plaintiff has the burden on the second issue. Kajima Engineering
Construction. Inc. v. City of Los Angeles (2002) 95 Cal.App.4th 921, 928.
"Only a cause of action that satisfies both prongs of the anti- SLAPP
statule--i.e., that arisesfi-omprotected speech or petitioning and lacks
even minimal merit-is a SLAPP, subject to being stricken under the
statute." Navellier v., Sletten (2002)29 Cal.4th 82, 89.
6
7 Petition or Free Speech
8 Code Civ. Proc. § 425.16 (e) provides: "As used in this section, "act in
furtherance of a person'srightof petition orfi-eespeech under the United
9 States or Califomia Constitution in connection with a public issue"
10 includes: (1) any written or oral statement or writing made before a
legislative, executive, or 'judicial proceeding, or any other official
11 proceeding authorized by law, (2) any written or oral statement or writing
made in coruiection with an issue under consideration or review by a
12 legislative, executive, or judicial body, or any other official proceeding(
o
o
a in 13 authorized by law... ." ^
t_ g Ol to
P 00 ^ «S• f~
O u - " sP;
" 14 The Califomia legislature enacted Code of Civil Procedure section 425.16,
^
CO gi <
5, S M
> W o\ Icnown as the anti-SLAPP statute, to provide a procedural remedy to
OC < o" ^ 2 15 dispose of lawsuits and causes of action that, are brought to chill the valid
.— o .
16 exercise of the constitutional rights to free speech and to petition the
govemment for redress of grievances.(See Rusheen v Cohen (2006) 37
o 17 Cal.4th 1048, 1055-1056. These provisions apply to SLAPP suits brought
against public entities and public employees. See San Ramon Valley Fire
18 Prot Dist V Contra Costa County Employees' Ret Ass'n (2004) 125
19 Cal.App.4th 343, 353; see also City ofCotati v. Cashman (2002) 29 Cal.
4th 69.
20
21 It is well established that the policies of Defendant University, including
the Personnel Policies for Staff Members ("PPSM") and UC Davis Policy
22 and Procedure Manual ("PPM"), have the force and effect of state statute.
(Kim V. Regents of University of California (2000) 80 Cal.App.4th 160,
23 165.) "1
24
Statutory procedures qualify as official proceedings authorized by law for
25 section 425.16 purposes. {Vergos v. McNeal (2007) 35 Cal.App.4th 1387,
1399.) The constitutional right to petition includes the act of seeking
26 administrative action. {Briggs v. Eden Council for Hope & Opportunity
27 (1999) 19 Cal.4th 115.) Investigations and investigatory reports prepared
in connection with an issue under consideration or review by an official
28 body, such as a public entity's internal investigations, are protected
<01362378.DOCX}
activities under the anti-SLAPP statute. {See Miller v. City of Los Angeles
(2009) 169 Cal ARp.4th 1373, 1383; Hansen v California Dept of
Corrections and Rehabilitiation (2008) 171 Cal.App.4th 1537, 1544;
Briggs V. Eden Council for Hope & Opportunity (1999) 19 Cal. 4th 1106.)
In this case, the speech by Chilcott, Boyd, Oropeza, Seifert, and Nichols
that is at issue were made in cormection with the processing, investigation,
hearing and deciding the" workplace complaints filed by Plaintiff and
others pursuant to University policies.
The allegations of the SAC against Nichols attack her protected

participation in the official investigations. The SAC specifically alleges
Nichols' communications regarding the investigation. (SAC, ^ 70 (1), (o), ,
(q)> (s), (x), (AA)) and her investigative conclusions (SAC, ^ 70 (v),
(KK)). Nichols was appointed to investigate Plaintiffs whistleblower
10 complaints, and was also appointed to conduct an investigation into
complaints of workplace violencefiledby Putney and Daniliuc. All were
II protected petitioning activities.
12 The allegations against Boyd and Chilcott are limited to their receipt of
o
o
CM
lVi i n 13 emails from Nichols relating to the investigations, and Chilcott's sending
•= Ol
3 00 - <£>
C/) i n 00 O
of an email relating to the investigation of Plaintiff (SAC, ^ 70(m), (x),
o Ot ^
14 (AA).) The emails are protected speech in connection with an
u
ce: 15
LU
16 The allegations against Oropeza and Seifert are based upon their
OC 1^ 2 y <
investigation into the emails plaintiff sent to Nichols in April 2012.
o =5 W
17
OL. Oropeza and Seifert conducted dieir investigation pursuant to the
University's grievance protocol and reached conclusions documented in a
18 report.
19
Boyd acted as Complaint Resolution Officer ("CRO") at Step II of the
20 University's PPSM 70 process, hearing and deciding PlaintifPs appeal of
his termination. In Vergos, supra, 146 Cai.App.4th at 1399-1400, the
21
Court held that defendant reviewer was entitled to the protection of the
22 anti-SLAPP statute for denying the grievance.,Specifically, in Vergos, a
slate university employee pursued an intemal grievance against his
23 supervisor for sexual harassment. In an administrative proceeding
24 authorized by the Regents of the University of California, the hearing
officer denied the grievance. The employee then filed a civil rights suit
25 against the hearing officer, alleging that her decision had failed to protect
him from future harassment. (Id. at pp. 1390-1392, 1396-1397.) The
26 hearing officer filed a special motion to strike, contending that her
27 conaniunications were made in cormection with an issue under
consideration in an official proceeding. (See § 425.16, subd. (e)(2).) The
28 trial court denied the motion. The Court of Appeal reversed because "[t]he
i0136237g.DOCX>
gravamen of plaintiffs [claim] is [the hearing officer's] communicative
1 conduct in denying plaintiffs grievances. The hearing, processing, and
2 deciding of the grievances (as alleged in the complaint) are meaningless
without a communication of the adverse results." (146 Cal.App.4th at p.
3 1397.) Thus, Vergos recognized that the anti-SLAPP statute applies where
liability is based on protected speech. (See Id. at pp. 1397-1399)
4
5 Moving parties have established that their speech and writings are
protected as made in connection with an issue under consideration or
6 review by an official proceeding authorized by law. The burden therefore
7 shifts to plaintiff to show that he will prevail.
8 Probability That Plaintiff Will Prevail

9 Plaintiff must show a likelihood of prevailing on each of the elements of
10 his causes of action, and must also show a likelihood of defeating any
applicable affirmative defenses. (Wilcox v. Superior Court (1994) 27
II Cal.App.4th 809, 820, 824; see also Paul of Council v. Hanyecz (2001) 85
Cal.App.4th 1356, 1367, overmled on other grounds in Equilon
12 Enterprises v. Consumer Cause, Inc. (2002) 29 Cal.4th 53,68.) The test to
o
o
Ol
V <n 13 use to determine Plaintiffs probability of prevailing is similar to the
i_ O)
_
00
so
p
standard applied to evidentiary showings in motions for summary
Is 14 judgment, and the supporting facts must be demonstrated by way of
^fS o; o:
Ol-Ol
15
competent, admissible evidence. (Church of Scientology v. Wollersheim
tc < 6 ve ^ (1996) 42 Cal.App.4th 628, 654-655.) The difference between summary
tu >. c Ov Cv
J >< 16 judgment and anti-SLAPP is that the burden is on the opposing party
l -^ S plaintiff to show the likelihood of prevailing.
13 </i
17
In order to establish the necessary probability of prevailing, plaintiff was
18 required both to plead claims that were legally sufficient, and to make a
19 prima facie showing, by admissible evidence, of facts that would merit a
favorable judgment on those claims, assuming plaintifPs evidence were
20 credited. The court does not, however, weigh the parties' evidence, in
terms of either credibility or persuasiveness. Rather, the defendant's
21
evidence is considered with a view toward whether it defeats the plaintiffs
22 showing as a matter of law, such as by establishing a defense or the
absence of a necessary element. (1-800 Contacts, Inc. v. Steinberg (2003)
23 107 Cal. App.4th 568, 584-585.)
24
1*' For Intentional Infliction of Emotional Distress
25
An essential, element of pleading a claim for intentional infliction of
26 emotional distress is a shovnng of outrageous conduct beyond the bounds
27 of hunian decency. Managing personnel is not outrageous conduct beyond
the bounds of human decency, but rather conduct essential to the welfare
28 and prosperity of society. A simple pleading of personnel management
0
(OI362378.DOCX>
|PROPOSED| ORDER GRANTING DEFENDANTS BOYD, CHILCOTT, NICHOLS, OROPEZA AND
activity is insufficient to support a claim of intentional infliction of
1
emotional distress, even if improper motivation is alleged. If personnel
2 management decisions are improperiy motivated, the remedy is a suit
against the employer for discrimination. (Janhen v. GM Hughes
Electronics (1996) 46 Cal.App.4th 55, 80.)
What plaintiffhas alleged, and what his evidence in opposition appears to

5 support, are complaints conceming personnel management by defendants.
Pleading of personnel management activity is "insufficient to support a
6 claim of intentional infliction of emotional distress, even if improper
motivation is alleged." (Janken, 46 Cal.App.4th at p. 80.) Plaintiff has
7
failed to provide any legal authority or analysis as to why the facts before
8 the court show the likelihood of his prevailing on this cause of action.
9 2"** Tortious Interference with Economic Advantage
10
Plaintiffs claim tortious interference with economic advantage against
II Defendants. Ah employee or former emjiloyee cannot sue a current or
former supervisor or employee for interfering with his or her prospective
o
12 economic advantage by inducing the employer to terminate the plaintiff's
o
<N
13 employment. (Shepperd v. Freeman (1998) 67 Cal.App.4th 339, 347;
L,
(—
2 Ol _
-r-i oo O
Shoemaker v. Myers (1990) 52 Cal.3d 1, 24.)
14
H i6gs Plaintiff has failed to provide any legal authority or analysis as to why the
— > W ov ov
< . o vo vD
16 action. ^
in
17 3"" for Discrimination
18 In the third cause of action, Plaintiff alleges violation of the FEHA, both
19 section 12940(a), which prohibits discrimination, and Section 12940(k)
which addresses the failure to prevent discrimination.
20
These claims are not properly pleaded against the individual Defendants as
21
individuals cannot be sued for discrimination Under the FEHA, nor can
22 they be sued for failing to prevent discrimination, retaliation, and
harassment. (Reno v. Baird (1998) 18 Cal.4th 640, 663-664; see, also
23 , Janken, supra, 46 Cal.App.4th at p. 63.) In .lanken the Supreme Court
noted the "ftindamental distinction" between the way the FEHA treats
24
harassment, on the one hand—for which supervisors may be held
25 personally liable, and discrimination on the other hand~for which, Janken
held, individuals are not personally responsible.
26
27 Plaintiffhas failed to provide any legal authority or analysis as to why the
facts before the court show the likelihood of his prevailing on this cause of
28 action.
(OI36237g.DOCX}
(PROPOSED} ORDER GRANTING DEFENDANTS BOYD, CHILCOTT, NICHOLS, OROPEZA AND
4'" for Whistleblower/Unlawful Retaliation
1
Plaintiffs Fourth Cause of Action brought pursuant to Government Code

section 8547.10 for whistleblower retaliation.
Plaintiff has not established that moving defendants' conduct was in

retaliation for plaintiffs whistleblowing.
1
The mere fact that Nichols, Oropeza and Seifert conducted investigations
and reached conclusions with which Plaintiff does not agree v\dth does not
establish their investigatoryfindingsare an act of retaliation. Nor can
Boyd's decision to deny Plaintiffs grievance at the Step II level of PPSM
70 review be deemed to be a retaliatory action. Finally, there is no
allegation that Chilcott took any particular action against Plaintiff that
could be deemed to be a retaliatory action.
10
Plaintiff has failed to provide any legal authority or analysis as to why the
action.
12
o
o
Ol
13 As a matter of law. Plaintiff has not shown that he can prevail on any of
h
,
"5
- J, m
S -- )J?
~ ee 'o his four causes of action against moving party defendants. Given the
^ ( / } tn QO •
p u 2 P; 14 Court's determination the Court need not address the Regents' other
(J
> u o» o> arguments based on Govemment Code section 821.6. It bears noting,
oi < o" vb vo 15 however, that immtmity extends to investigations even if there is a later
16 decision not to institute administrative proceedings or to initiate a
prosecution. (See Ingram v Flippo (1999) 74 Cal.App.4th 1280, 1293.)
o 17
•n
The anti-SLAPP motion is therefore granted as to moving defendants
18
Michael Boyd, Stephen Chilcott, Danesha Nichols, Cindy Oropeza and
19 Brent Seifert only, as to thefirstthrough fourth causes of action.
20 The Discovery Stay is ordered lifted.

21
Prevailing defendants on a motion to strike mustfilea separate motion to
22 recover their attorneys' fees and costs.
23 The prevailing parties shall prepare a formal order for the Court's
24 signature pursuant to C.R.C. 3.1312.
25
IT IS THEREFORE ORDERED that the Special Motion to Strike the four causes of
26
action enumerated above, as pleaded against Defendants, from Plaintiff's Second Amended
Complaint is hereby GRANTED.
28
(OI36237g.DOCX) 8
IT IS FURTHER ORDERED that judgment be, and hereby is, entered in favor of
Defendants MIKE BOYD, STEPHEN CHILCOTT, DANESHA NICHOLS, CINDY OROPEZA,
and BRENT SEIFERT, and against Plaintiff JAROSLAW WASZCZUK for the four causes of
action asserted against them in the Second Amended Complaint.
5 ^ IT IS FURTHER ORDERED that Defendants are awarded their costs and the attorney's
6 fees incurred in conjunction with the Special Motion to Strike pursuant to Code ofCivil Procedure
7 section 425.16, subdivision (c)(1). Defendants shall file a separate motion to determine the
8 amount to be awarded.
9 IT IS SO ORDERED.
10 Dated: ,2015
11
12 JUDGE OF THE SUPERIOR COURT
o
Ol
13
DAVID I. BROWN
_ vo
t e« S«• S
JS APPROVED AS TO FORM AND CONTENT.
14
e«: < o"vb vo 15
UJ >. c 9\ Ov Dated: February _,2015 By.
y < 16
o s? i Jaroslaw Waszczuk, In Pro Per
3 V)
o
m
17
18
19
20
21
22
23
24
25
26
27
28
<OI36237g.DOCX)
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TEL: 916.929.1481
5 FAX: 916.927.3706 By: E, Medina
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PROOF OF SERVICE
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Jaroslaw Waszczuk
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2216 Katzakian Way
23 Lodi, CA 95242
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Wendy Strasser
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{0I892012.DOCX} II
EXHIBIT # 6
EXHIBIT # 7
MINUTE ORDER
DATE: 10/31/2018 TIME: 02:00:00 PM DEPT: 53
CLERK: E. Brown
REPORTER/ERM:

APPEARANCES
Nature of Proceeding: Motion to Compel 1) Production 2) Special 3) Form-Gen. 4) Form-Empl. 5)

Admissions
TENTATIVE RULING

No later than November 21, 2018, Plaintiff Jarolsaw Waszczuk shall serve verified responses, without

sanction is to be paid on or before December 1, 2018. If the sanction is not paid by that date, Defendant
may prepare for the Court's signature a formal order granting the sanctions, which may be enforced by a
separate judgment. (Newland v. Superior Court (1995) 40 Cal.App.4th 608, 615.)
884.)
than tactical.
deadline as part of this discovery motion.
The notice of motion provides the incorrect time and location for the hearing. This matter has been
assigned to Department 53 for law and motion purposes and Department 53 hears law and motion
matters at 2 p.m. Moving counsel is directed to immediately provide notice to Plaintiff of the correct time
and location of the hearing.
notice is required.
COURT RULING

EXHIBIT # 8
MINUTE ORDER
DATE: 11/14/2018 TIME: 02:00:00 PM DEPT: 53
CLERK: E. Brown
REPORTER/ERM:

APPEARANCES
Nature of Proceeding: Motion to Compel 1) Production 2) Special 3) Form-Gen 4) Form-Emp 5)

Admissions
TENTATIVE RULING
At the outset, the Court must point out Defendant's procedural errors that have rendered an otherwise
simple motion confusing and created unnecessary work for the Court. Defendant initially noticed this
motion for October 31, 2018 but included the incorrect law and motion department on the notice. It then
apparently filed the identical motion and noticed it for hearing on November 13 and 14 in this
department. Defendant wrote a letter to the Clerk requesting that the Clerk drop the November 13,
hearing, but never requested that the Clerk drop the October 31, 2018 hearing. (ROA 164). As a result,
the Court issued a ruling for the October 31, hearing. Subsequently, the Court received correspondence
from Defendant indicating that it believed the October 31, 2018 ruling was in error because it requested
the clerk drop that hearing. The only request received by the Clerk was the letter requesting that the
November 13, 2018 hearing be dropped. Nevertheless, despite the fact that the instant motion was
essentially filed three times for three separate hearing dates, it appears that Defendant intended to have
the matter heard on today's date. As a result, the Court vacates the ruling issued in connection
with the October 31, 2018 hearing. Though as seen below, the ruling will be essentially the same.
No later than December 12, 2018, Plaintiff Jarolsaw Waszczuk shall serve verified responses, without

sanction is to be paid on or before December 14, 2018. If the sanction is not paid by that date,
Defendant may prepare for the Court's signature a formal order granting the sanctions, which may be
enforced by a separate judgment. (Newland v. Superior Court (1995) 40 Cal.App.4th 608, 615.)
884.)
than tactical.
deadline on a hypothetical motion as part of this discovery motion.

notice is required.
COURT RULING

EXHIBIT # 9
MINUTE ORDER
DATE: 02/08/2019 TIME: 09:00:00 AM DEPT: 43
JUDICIAL OFFICER PRESIDING: Thadd A. Blizzard
CLERK: S. Newsom
REPORTER/ERM: None
BAILIFF/COURT ATTENDANT: R. Singh

EVENT ID/DOCUMENT ID: ,16681756

EVENT TYPE: Order of Examination - OX Calendar
CAUSAL DOCUMENT/DATE FILED: Order for Appearance and Examination Jaroslaw "Jerry"
Waszczuk, 12/07/2018
APPEARANCES
Dan Bardzell, counsel, present for Defendant(s).
Nature of Proceedings: Hearing on Order of Examination of Judgment Debtor
The above entitled cause came before this court for hearing on Order of Examination of Judgment
Debtor this date with the above indicated parties present.
Judgment Debtor, Jaroslaw Waszczuk was sworn and examined.

The examination was concluded and the parties were released.

EXHIBIT # 10
Jaros-Law@outlook.com
From: Jaros-Law@outlook.com
Subject: FW: Case No. 34-2013-00155479, Jaroslaw Waszczuk v. The Regents of the University of California. -
SUMMARY OF OUR MEETING IN THE COURT CAFETERIA ON FEBRUARY 8, 2019
Attachments: 00000-IN PRO PER.pdf; 0000-20190208-COURT ORDER APPEARANCE .pdf; 001-20180718- LETTTER
TO CLERK.pdf; 002-20181113- JUDGE BROWN BROWN.pdf; 003-ADM-2-2009- SETTLEMENT-
AGREEMENT (29-40).pdf; 004- REIBURSEMENT- STATE BAR.pdf; 005-20140718 LT DES to Coombs
(2).pdf; 006-20190129- SUPREME COURT CUIAB FILED.pdf; 007-12-15-2018 US TAX COURT.pdf;
FREEDOM OF SPEECH (004).jpg
From: Jaroslaw Waszczuk <jjw1980@live.com>

Sent: Sunday, February 10, 2019 3:58 PM
To: dbardzell@porterscott.com; Wendy Strasser <wstrasser@porterscott.com>; cdegroof@porterscott.com;
charles.robinson@ucop.edu; regentsoffice@ucop.edu; President@ucop.edu; 'David Burkett'
<dburkett@porterscott.com>
Cc: jregulska@ucdavis.edu; katehi@ucdavis.edu; gary.may@ucdavis.edu; Alexander.Bustamante@ucop.edu;
hexter@ucdavis.edu; Senator.Galgiani@senate.ca.gov; Erica.Myers@sen.ca.gov; judith.rosenberg@ucop.edu;
jatollefson@ucdavis.edu; wjdelmendo@ucdavis.edu; daoffice@sacda.org; sheriffcivil@sjgov.org; eversteeg@lodi.gov;
dalubarsky@ucdavis.edu; sblandford@lodi.gov; tjlindsey@UCDAVIS.EDU; whistleblower@judiciary‐rep.senate.gov;
losangeles.polishconsulate@msz.gov.pl; washington.amb@msz.gov.pl; ExecutiveDirector@calbar.ca.gov;
StateBarCourt@calbar.ca.gov; GC@calbar.ca.gov; CTC@calbar.ca.gov; antonia.darling@calbar.ca.gov;
Vanessa.Holton@calbar.ca.gov; WhistleblowerProtection@tigta.treas.gov.; Dwaine.Duckett@ucop.edu;
losangeles.legal@msz.gov.pl; ckerosky@polishconsul.com; margaritaf@auditor.ca.gov
Subject: Case No. 34‐2013‐00155479, Jaroslaw Waszczuk v. The Regents of the University of California. ‐SUMMARY OF
OUR MEETING IN THE COURT CAFETERIA ON FEBRUARY 8, 2019

2216 Katzakian Way
Lodi, CA 95242
Phone: 209-663-2977
Fax: 209-833-7080
February 10, 2019
Sent by e-mail
Daniel Bardzell, J.D.

1
Subject: Appearance and Examination on February 8, 2019 at 9:00 a.m. at Department 43. Hon. Thadd
A. Blizzard, Case No. 34-2013-00155479, Jaroslaw Waszczuk v. The Regents of the University of
California.
RE: SUMMARY OF OUR MEETING IN THE COURT CAFETERIA ON FEBRUARY 8, 2019
Dear Mr. Bardzell,
For the record, I would like to briefly summarize our meeting that took place on February 8,
2019 in the Sacramento County Superior Court Cafeteria on the sixth floor at 9:30 a.m.
I and my witness, William Buckans (UC Davis Medical Center employee), viewed the meeting
as unpleasant, provocative, and hostile. William and I noticed that you were very nervous and
uncomfortable during the meeting. At some point when you started bringing my wife and children into
the terror I have been experiencing for the last 12 years from the University of California Office of the
President (UCOP) mob, William, who was sitting at the next table, turned his chair toward you and
looked at you. You did not know that William was my former coworker from the UC Davis Medical
Center 27 MW cogeneration plant where I worked from June 1999 to April 2007. You were also
informed previously that two Porter Scott attorneys attempted to provoke me into physical
confrontation outside the court room in February 2015 and in August 2017.
From your redundant and provocative questions about my wife, children, landlord, and the
insurance on my rental house, it was not difficult to conclude that Janet Napolitano is looking to inflict
a different type of harm to me and my family than to enforce the unlawful judgment (see the Letter to
the Clerk filed on July 18, 2018 and the Letter to Judge Brown filed on November 16, 2018).
Your questions about insurance on the rental house clearly indicate that UCOP mob led by
Janet Napolitano is planning a raid on my home with involvement from the Lodi Police or San Joaquin
Sheriff’s Department to terrorize me and my family by ransacking my house to cause psychological
trauma. As you probably read in court documents, I have been terrorized and hunted like a Jew during
the holocaust by the UCOP mob since January 2007, and I don’t see it ending soon while I’m still
alive.
During our meeting on February 8, 2019, I provided you with the following documents as potential
assets:
1. A copy of the January 31, 2009 Settlement Agreement by UC Regents and myself plus the
calculated damages of approximately $1,000,000 caused by UC Regents due to breach and
violation of this Settlement Agreement (attached).
2. The March 1, 2018 copy of the California Supreme Court decision, which ordered that I be paid
back my stolen retainer money in the amount of $14,694.33 plus 10% interest that I paid to my
2
former attorney, Douglas Stein, for representation. Stein on Discipline Case No. S245982
(attached).
3. The unfinished case with Liberty Assurance Company of Boston, which is in conspiracy with
UC Regents that denied my short disability benefits in 2011. Minimum value $4,546 (attached).
4. The unfinished unemployment insurance benefits case pending in the California Supreme Court,
Waszczuk v. California Unemployment Insurance Appeal Board 3DCA Case No. C079254,
Supreme Court Case No. – Value $25,000 if prevail.
5. Whistleblower case pending in the U.S. Tax Court, Waszczuk v. United States Commissioner of
Internal Revenue Services, Docket No. 023105. The IRS whistleblower case is about an
enormous amount of unlawful power sales by regents in conspiracy with Enron and the
California Independent System Operator and related to multimillion dollars in tax fraud. Fraud
was disclosed in August 2012 by UC Davis Assistant Vice Chancellor Dr. Shelton Duruisseau
in this interview with Sac Cultural Hub (attached). http://www.sacculturalhub.com/headlines/a-
look-back
“THE BLACKSMITH WAS GUILTY, BUT THE GYPSY WAS HANGED.” - Polish
proverb
In addition, after the meeting I forwarded to you my current bank statement from Rabobank and
an e-mail from Citibank with information about the account I have no access to. I believe that the
amount of $14,694.33 plus interest for five years should cover the judgment obtained by the Court by
David Burkett in violation of California Court Rules 3.1312 b, which states:
“That the prevailing party must, upon expiration of the five-day period provided for approval,
promptly transmit the proposed order to the court together with a summary of any responses of
the other parties or a statement that no responses were received pursuant to California Rule of
Court 3.1312(b).”
Defendants’ attorney David Burkett bluntly violated the California Rule of Court 3.1312(b) and did not
transmit to the Court the PLAINTIFF’S 90-page DISAPPROVAL OF THE PROPOSED ORDER
AND JUDGMENT GRANTING LEGAL FEES AND COSTS TO DEFENDANTS IN ANTI-SLAPP
MOTION C.C.P. 425.16 (c).
2018 David Burkett’s violation of Rule 3.1312(b) is a copycat scenario of the March 2015
PLAINTIFF’S DISAPPROVAL OF THE PROPOSED ORDER AND JUDGMENT GRANTING
DEFENDANTS’ ANTI-SLAPP MOTION C.C.P. 425.16 (ROA #73).
Very truly yours,
3
____________________________
Jaroslaw Waszczuk
CC: Sacramento County Superior Court Judge Hon. Thadd Blizzard, sent by U.S. Priority Mail on
February 11, 2019.
California Senator Cathleen Galgiani
State Bar of California
Lodi Police Department (Fax)
San Joaquin County Sheriff Department (Fax )
California Governor Office Hon. Gavin Newsom (FAX)
Consulate General of Polish Republic of Poland
Attachment:
4
EXHIBIT # 11
2
350 University Avenue, Suite 200 FILED/ENDORSED
TEL: 916.929.1481 FEB I I 2019
•5 FAX: 916.927.3706
dburkett(a),pbrterscott.com By:
6 £• Medina
dbardzellfolporterscott.com ueputy ciert«
7
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THE REGENTS OF THE UNIVERSITY RESPONSES TO SPECIAL
glig^ 16 OF CALIFORNIA, UNIVERSITY OF INTERROGATORIES SET ONE, FORM
CALIFORNIA DAVIS HEALTH INTERROGATORIES - GENERAL SET
o 17 SYSTEM, UC DAVIS MEDICAL ONE, FORM INTERROGATORIES -
CENTER, UC DAVIS, ANN MADDEN EMPLOYMENT SET ONE; AND FOR
18
RICE, MIKE BOYD, STEPHEN MONETARY AND TERMINATING
19 CHILCOTT, CHARLES WITCHER, SANCTIONS
DANESHA NICHOLS, CINDY
20 OROPEZA, BRENT SEIFERT, Date: March 13,2019
21 PATRICK PUTNEY, DORIN Time: 2:00 p.m.
DANILIUC, and Does 1 through 50, Dept.: 53
22 inclusive,
23 Defendants. Amended Complaint Filed: June 16,2014
25
26
27
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(01965098.DOCX}
TABLE OF CONTENTS
1
2
Page
3
4 I. INTRODUCTION 1
5 II. STATEMENT OF FACTS AND PROCEDURAL HISTORY 2

6 A. Plaintiff Ignores Defendant's Initial Meet-and-Confer Efforts 3
7
B. Motion to Compel 3
8
C. Plaintiff Again Ignores Defendant's Meet-and-Confer Efforts 4
9
10 D. Plaintiff Failed to Pay Monetary Sanctions 4
11 III. PLAINTIFF'S RESPONSES TO SPECIAL INTERROGATORIES

(SET ONE), FORM INTERROGATORIES - GENERAL (SET ONE)
12
o AND FORM INTERROGATORIES - EMPLOYMENT (SET ONE)
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17 C. Plaintiff Responded " I don't know" to Some Interrogatories
18 Without Describing Efforts to Provide a Response 7
19
IV. DEFENDANT IS ENTITLED TO MONETARY SANCTIONS 8
20
V. TERMINATING SANCTIONS ARE ALSO APPROPRIATE 10
21
22 VI. CONCLUSION ; 11
23
24
25
26
27
28
{0196S098.DOCX}
Page
State Court Cases
Calcor Space Facility, Inc. v. Superior Court

(1997) 53 Cal.App.4"' 216, 221 9
6
Deyo V. Kilbourne
7
(1978) 84 Cal.App.3d 771, 782-783 5, 6, 8
8
Kahn v. Kahn
9 (1977) 68 Cal.App.3d 372, 383 11
10
Mannino v. Superior Court
11 (1983) 142 Cal.App.3d 776 9
12 R.S. Creative, Inc. v. Creative Cotton, Ltd.
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17 212 So.2d 315, 317(1) (Fla.App. 1968) •. 6
18 Statutes
19
Califomia Rules of Court, Rule 3.1348 , 9
20
Califomia Rules of Court, Rule 3.1348(a) 9
21
22 Code ofCivil Procedure § 2023.010(d) 10
23 Code ofCivil Procedure § 2023.010(g) '. 10

24 Code ofCivil Procedure § 2023.030(a) 8, 9, 10
25
Code ofCivil Procedure § 2023.030(d) 10
26
27 Code ofCivil Procedure § 2030.210(a) 5
28 Code ofCivil Procedure § 2030.220 5, 8
(0I965098.DOCX} iii
Code ofCivil Procedure § 2033.280 9

6
7 Govemment Code § 8547 2
8 Govemment Code § 12940(a) ; 2

9 Other Authority
10
4A Moore's Federal Practice (2d Ed. 1975)
11 Section 33.25(1), pp. 33-131- 33-132 6
12 Califomia Civil Discovery Practice, Section 8.55
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{0I96S098.DOCX}
DEFENDANT'S MEMORANDUM OF POEVTS AND AUTHORITIES IN SUPPORT OF
3 support of its motion to: (1) compel Plaintiff JAROSLAW ("JERRY") WASZCZUK to provide
4 further verified responses to Special Interrogatories (Set One), Form Interrogatories - General (Set
5 One), Form Interrogatories - Employment (Set One); (2) award monetary sanctions in the amount
6 of $5,460 to retum Defendant to the position it would have been had the subject discovery
7 responses been timely and completely provided; (3) issue terminating sanctions against Plaintiff as
8 a result of Plaintiffs repeated failure to engage in the discovery process.
9 1.
10 INTRODUCTION
11 Defendant served Plaintiff with Special Interrogatories (Set One), Form Interrogatories -
o
12 General (Set One), Form Interrogatories - Employment (Set One) on April 25, 2018'. Responses
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B -r. 13 were due on or before May 30j 2018. Defendant provided Plaintiff with an extension to June 20,
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14 2018 to provide responses to the requests. Plaintiff then failed to provide responses to any of
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18 requests for admission.
19 After the initial Motion to Compel, Plaintiff ultimately served his responses to special
20 interrogatories on October 15, 2018 and responses to form interrogatories - general and form
21 interrogatories - employment on December 13, 2019. These responses were mostly incomplete.
22 Defendant has attempted to meet-and-confer with Plaintiff regarding these deficiencies, but
23 consistent with his practice throughout this litigation, Plaintiff has refused to sufficiently and
24 coherently respond. As a result. Defendant now respectfully requests a further Order compelling
25 Plaintiff to cure the deficiencies raised in this Motion. Defendant also requests sanctions, pursuant
26 to 2030.290(c), in the amount of $5,460 for the fees and costs incurred as a result of Plaintiffs
27 continued disregard for the discovery process.
28
' Additional discovery requests outside the scope of the present motion were also served by Defendant at that time.
{01965098.DOCX} 1 ^
1 Defendant respectfully requests the Court issue an Order to (1) compel Plaintiff to provide
2 fiarther verified responses, without objection, to Defendant's Special Interrogatories (Set One),
3 Form Interrogatories - General (Set One), and Form Interrogatories - Employment (Set One); (2)
4 issue monetary sanctions against Plaintiff in the amount of $5,460 for Defendant's fees and costs
5 incurred in bringing this motion; and (3) issue the sanction of termination of the present action as a
6 result of Plaintiff s pattern of failing to comply with his discovery obligations. .
7 II.
10 summary: Plaintiff filed the operative Second Amended Complaint ("SAC") on Septehiber 30,
12 Defendants^: (1) intentional infliction of emotional distress ("IIED"); (2) tortious interference with
B "n 13 economic advantage; (3) FEHA harassment and failure to prevent harassment, discriminafion,
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o u 2: P; 14 retaliation in violation of Government Code § 12940(a); and (4) whistleblower/unlawful retaliation
< § g 15
> ^ Ov Ov in violafion of Govemment Code §§ 8547 et seq.
< o" ^
o > i e < ^" Each of these causes of action arises out of Plaintiffs employment with Defendant at the
D 00
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17 University of Califomia at Davis Medical Center. In addition to Defendant UNIVERSITY^, these
20 SEIFERT, PATRICK PUTNEY, and DORIN DANILIUC for their participation in investigafions
21 and disciplinary actions that ultimately resulted in Plainfiffs terminafion of employment with the
25 2018. (See Declarafion of Daniel Bardzell in Support of Mofion to Further Compel ("Bardzell
26 Decl."), 2 and Exhibit A.) By correspondence dated May 22, 2018, Plainfiff requested an
27
^ The First and Second Causes of Action in the Second Amended Complaint do not specifically identify Defendant UNIVERSITY
28 but do refer to employment with UC DAVIS within the cause of action.
^ S e e f n . 1.
{01965098.DOCX} 2
extension offimeto respond to all such requests on the basis that he was sick. (See Bardzell Decl., |
3 and Exhibit B.) Defendant's counsel responded by email correspondence dated May 23, 2018
granfing Plaintiff an extension of fime to respond until June 20, 2018. (See Bardzell Decl., 4 and
Exhibit C.)
5 A. Plaintiff Ignores Defendant's Initial Meet-and-Confer Efforts
6 On September 24, 2018, counsel for Defendant served a meet and confer correspondence
8 [P]lease provide complete responses to all such outstanding requests no later than September 28,
9 2018. If we do not have your complete responses by that date, we will file a motion to compel
10 responses and request monetary as well as terminating sancfions from the Court." (See Bardzell
12
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o By incoherent email correspondence also dated September 24, 2018, Plaintiff indicated:
fN
B >n 13 Thank you for news about the Request for Production of Documents and Special
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Interrogatories . I appreciate but I not sure yet what I am going to . I am waiting for
V in C 14 answers from the federal authorities in this matter.
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15 I will let know . I mean fime you can entertain yourself with my affirmative defense
01 < 6 fN d
Ov OV of Judge Brett Kavanaugh. As Jeanine Pirro stated not so long ago , . UC Regent wife
H ^ \0 v ^
O ^ 2 as ov 16 Senator Feinstein's Unhinged Demon Rats attacking Judge Kavanaugh as I was
cu c attacked and wasted by her husband and other unhinged UC demon rats . Same
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18 check on 28^^ than I could buy ink for my printer and do eventually interrogatories.
(See Bardzell Decl., H 6 and Exhibit E.)
19
20
2018. (See Bardzell Decl., H 6.)
21
On October 1, 2018, Plainfiff submitted an email correspondence to Defendant stafing: " I
22
am working on the Interrogatories and other papers. Pleas give one more week to finish. Attached is
23
a part of interrogatories to show you that I am working on ." (See Bardzell Decl., TI 7 and Exhibit
24
F.) Included was a rambfing apparent partial draft response to Defendant's Special Interrogatories,
25
Set One without a verification. (See Bardzell Decl., Tl 8.)
26
B. Motion to Compel
27
Defendant was subsequently forced to file a Motion to Compel and needlessly incur the
28
{01965098.DOCX} 3 '
1 associated fees and costs. (See Bardzell Decl., Tl 8.) On November 14, 2018, the Court issued its
2 tentative mling, which later became the ruling of the Court pursuant to Local Rule 1.06. (See
3 Bardzell Deck, Tl 9, and Exhibit G). There, the Court ordered Plaintiff to provide verified responses,
4 without objections, to Defendant's form and special interrogatories (sets one) and requests for
5 producfion (set one) no later than December 12, 2018. (See Bardzell Decl., Tl 9, and Exhibit G).
6 Additionally, the Court ordered Plaintiff to pay Defendant mandatory monetary sancfions in the
8 (See Bardzell Deck, TI 9, and Exhibit G.)
9 Plaintiff did subsequently provide responses to the special and form interrogatories, but they
10 were largely deficient as described in the present motion. (See Bardzell Deck, TI 11-12 and Exhibits
11 H and I.)
12 C. Plaintiff Again Ignores Defendant's Meet-and-Confer Efforts
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Sacra
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18 confer correspondence. (See Bardzell Deck, Tl 14 and Exhibits K.)
19 Plaintiff subsequently requested addifional time to respond to the meet and confer and the
20 parties agreed to extend the time for Defendant to file a mofion, if necessary, through Febmary 12,
21 2019. (See Bardzell Deck, Tl 15-17 and Exhibits L-N.)
22 By email dated January 25, 2019, Plainfiff further responded to Defendant's January 15,
24 stating that Defendant should "File the mofion, and I , accordingly, will file the response to your
25 motion in court." (See Bardzell Deck, Tl 18 and Exhibits O.) As of the date of this Mofion, Plaintiff
26 has not provided amended responses. (See Bardzell Deck, TI 19.)
27 D. Plaintiff Failed to Pay Monetary Sanctions
28 In addition to Plaintiff willfially disregarding his discovery obligations, Plaintiff also
{01965098.DOCX) 4
1 violated the Court's previous Order by failing to fttlly pay Defendant monetary sancfions. (See
2 Bardzell Deck, Tl 9-10.) As set forth above, in its prior Order, the Court directed Plaintiff to pay
3 monetary sancfions of $520 by December 14, 2018. (See Bardzell Deck, Tl 9 and Exhibit G.)
4 Plainfiff provided checks amounting to only a small portion of the amount owed. (See Bardzell
5 Deck, Tl 10.) Defendant has not cashed such checks. (See Bardzell Deck, TI 10.) Plainfiff failed to
6 pay the required sancfion by December 14, 2018 and, to-date, Plaintiff has provided checks
7 amounting to only a small portion of the sanctions ordered by the Court. (See Bardzell Deck, TI 10.)
8 in.
9 PLAINTIFF'S RESPONSES TO SPECIAL INTERROGATORIES (SET ONE), FORM
10 INTERROGATORIES - GENERAL (SET ONE) AND FORM INTERROGATORIES -
11 EMPLOYMENT (SET ONE) ARE EVASIVE. INCOHERENT AND INCOMPLETE
o
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oi < 6 vd vd 15 to the particular interrogatory. (CCP § 2030.210(a).) Code ofCivil Procedure §2030.220 requires
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17 Civil Procedure §2030.220 requires that parties produce all information "reasonably available" to
18 them in response to interrogatories. (CCP. §2030.220(a).) That obligation requires that parties
19- take all reasonable steps to investigate and obtain information responsive to the request. (CCP.
20 §2030.220(c).) If parties do not have sufficient informafion to respond to a request after making a
21 reasonable inquiry, they must state that fact in their response. (Id.) They should also detail the
22 efforts made to obtain the informafion. (Deyo v. Kilbourne (1978) 84 Cal.App.3d 771, 782-783.)
23 Parties cannot claim a lack of personal knowledge when the informafion "can be obtained from
24 sources under his control." (Id.) A party may move to compel further responses if an answer is
25 "evasive or incomplete." (CCP. §2030.300(a).)
26 Here, Plaintiff provided evasive, incomplete and incoherent responses to Defendant's
27 Form Interrogatories - General, Set One; Form Interrogatories - Employment, Set One and Special
28 Interrogatories, Set One. (See generally Defendant's Separate Statement of Disputed Discovery
{01965098.DOCX} 5
in Support of Motion to Compel ("Defendant's Separate Statemenf).)
Plaintiffs rambling and incoherent responses contain a myriad of deficiencies. Same are
set forth in greater detail in Defendant's Separate Statement. Plainfiffs responses to the form and
special interrogatories are generally deficient for the following reasons:
5 A. Plaintiff Improperly Cites External Documents
6 As set forth in greater detail in Defendant's Separate Statement, in response to
7 interrogatories, including, but not limited to, Special Interrogatories No. 2, 4, 5, 6, 9, 10, 11, 12,
8 13, 14, 17, 18, 19, 20, 21, 22, 25, 26, 27, 30, 37; and Form Interrogatories 6.4, 206.1,-206.2, and
9 207.1, Plainfiffs response cites to voluminous extemal documents and/or url addresses without
10 any specific page/line references or summary. (See Defendant's Separate Statement and Bardzell
11 Decl., Exhibits H-I.) It is not proper to answer by cifing to an extemal document. (See Deyo supra,
12 84 Cal.App.3d at 783-784 ("[I]f a question does require the responding party to make reference to
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o u =^ 2 P; answer is fially responsive to the question[.]" (cifing Califomia Civil Discovery Pracfice, Section
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< Q- vd ^ 1J 8.55 (C.E.B.1975); 4A Moore's Federal Pracfice (2d Ed. 1975), Secfion 33.25(1), pp. 33-131 to
w iv ^ 5:
33-132; State Road Dept. v. Florida East Coast Ry., 212 So.2d 315, 317(1) (Fla.App. 1968).)
3 Vi
17 (Further citafion omitted)). In instances where Plaintiff cites external documents, same are not
18 properly identified and summarized. (See Deyo, supra, 84 Cal.App.3d at 783-784.) Therefore,
19 these responses are improper and incomplete.
20 B. Plaintifrs Interrogatory Responses are Incomplete and In Some Instances He
21 Provided No Substantive Response Whatsoever
22 Plaintiff provided a multitude of incomplete responses, including numerous instances
23 where subparts are ignored. The following is a representafive sample of the such deficiencies: In
24 response to Form Interrogatories 6.4 and 6.5, respecfively, asking Plaintiff to idenfify
25 examinations or treatment related to his claims, and any medication, prescribed or not, as a result
26 of injuries that his' attributes to his claims, Plainfiff provides incomplete responses. (See
27 Defendant's Separate Statement and Bardzell Decl., Exhibit I.) Specifically, in response to
28 Interrogatory 6.4, Plaintiff fails to indicate the charges to date for health care services received.
{0i965098.DOCX} 6
(See Defendant's Separate Statement and Bardzell Deck, Exhibit I.) In response to Form
2 Interrogatory 6.5, Plaintiff fails to respond to subparts including (c) the date his prescription(s)
3 were prescribed orfiamished;(d) the dates you began and stopped taking it; and (e) the cost to
4 date. (See Defendant's Separate Statement and Bardzell Deck, Exhibit I.)
5 Moreover, in response to Form Interrogatories 10.1-10.3, which generally seek information
6 regarding treating physicians and treatment before and after the claims arose, Plaintiff fails to
7 identify any treating physicians or what treatment was sought beyond the facial reference to heart
8 surgery. (See Defendant's Separate Statement and Bardzell Deck, Exhibit I.) The content of the
9 response plainly calls for additional responsive information such as identifying information for the
10 doctor who performed heart surgery on Plaintiff.
11 Additionally, in response to Special Interrogatory No. 21; 23; 26; 28; 29, Plaintiffs fails to
12 provide contact information for persons he identifies as having knowledge of various protected
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t- 3 g _ VD
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o u 2: ^ 14 Decl., Exhibit H.) Such incomplete responses interfere with Defendant's ability to prepare its
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O Moreover, Plaintiff improperly combines numerous, responses into a single response
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17 purportedly responsive to each. (See Defendant's Separate Statement and Bardzell Decl., Exhibit I,
18 Plainfiff s Response to Form Interrogatories 2012.1-2012.7.)
That information sought by the numerous aforementioned interrogatories is within
19
20 Plaintiffs control. As such, he was required to provide it and his responses are incomplete.
Plaintiff further provides no substantive response whatsoever to the following Form
21
22 Interrogatories - General, Set One: 6.7; 9.1; 12.1; 12.4; 13.1; 13.2; 50.2; 50.3; 50.4; and 50.5; Form
23 Interrogatories - Employment, Set One: 200.6; 202.1; 202.2; 203.1; 204.1; 204.2; 204.3; 204.4;
24 204.5; 207.2; 208.2; 210.6; 215.2; and Special Interrogatory No. 24.
25 C. Plaintiff Responded "I don't know" to Some Interrogatories Without Describing
26 Efforts to Provide a Response

27 In response to Form Interrogatories 12.5; 12.6 and 12.7: Plaintiff responded: " I don't
28 know." (See Defendant's Separate Statement and Bardzell Deck, Exhibit I.) He fails to describe
{01965098.DOCX} 7
1 what search he has done to provide a response. These responses are incomplete. Similarly, in
2 response to Form Interrogatory 206.3, Plaintiff simply responds "Waszczuk is not sure what 206.3
3 asking him for[.]"(See Defendant's Separate Statement and Bardzell Deck, Exhibit I.) That is also
4 non-responsive.
5 Code of Civil Procedure §2030.220 requires that parties produce all informafion
6 "reasonably available" to them in response to interrogatories. (CCP. §2030.220(a).) That
7 obligafion requires that parties take all reasonable steps to investigate and obtain information
8 responsive to the request. (CCP. §2030.220(c).) If parties do not have sufficient information to
9 respond after making a reasonable inquiry, they must state that fact in their response. (Id.)
10 Plaintiff should be able to respond to such interrogatories as to his personal knowledge. If
11 he does not know, he has an obligation to detail the efforts made to obtain that information. (Deyo
12 supra, 84 Cal.App.3d at 782-783.)
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Defendant's Separate Statement.
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W ^v S 5; 5;
S Si g -> X 16 case and to determine the validity of plaintiffs claims. Accordingly, Defendant respectfully request
DV. 17
O an Order compelling Plaintiff to provide further verified responses to Defendant's Special
19 Employment (Set One) without objecfions.
20 IV.
21 DEFENDANT IS ENTITLED TO MONETARY SANCTIONS
22 Code ofCivil Procedure § 2023.030(a) provides, in relevant part, that:
23
The court may impose a monetary sanction ordering that one engaging in the misuse
24 of the discovery process, or any attomey advising that conduct, or both pay the
reasonable expenses, including attomey's fees, incurred by anyone as a result of that
25 conduct [. . .] If a monetary sanction is authorized by any provision of this tifie, the
26 court shall impose that sanction unless it finds that the one subject to the sancfion
acted with substanfial justification or that other circumstances make the imposition
27 of the sanction unjust.
28 CCP §§ 2030.290(c) provides that a court shall impose a monetary sanction on any party
{01965Q98.DOCX} 8
who unsuccessfially opposes a motion to compel responses to interrogatories.
Pursuant to CCP §§ 2030.290(c), Defendant is enfified to an award of sancfions against
Plaintiff as a result of his failure to provide appropriate responses to Defendant's interrogatories.
Califomia Rules of Court, Rule 3.1348 authorizes an award of sanctions even when "the requested
5 discovery was provided to the moving party after the motion was filed." (C.R.C, Rule 3.1348(a).)
6 Sanctions are also available when a party misuses the discovery process. (CCP.
7 §2023.030(a); "The '[f]ail[ure] to respond... to an authorized method of discovery' and '[mjaking
8 an evasive response to discovery' are defmed as '[mjisuses of the discovery process.'" (Saxena v.
9 Goffney (2008) 159 Cal.App.4th 316, 333.)
10 The California Court of Appeal has previously addressed the increasing misuse of the
11 discovery process similar to Plaintiffs behavior:
o
12 "We are . . . aware the discovery process is subject to frequent abuse and, like a
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t- g °^ ^ over the sledge hammer."
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17 (Calcor Space Facility, Inc. v. Superior Court (1997) 53 Cal.App.4th 216, 221 (quoting Mannino v.
18 Superior Court (1983) 142 Cal.App.3d 776.))
19 Awarding sanctions is particularly appropriate in this case as this is the second time
20 Plainfiff has forced Defendant to file a Motion to Compel. Defendant filed a Motion on October
21 17, 2018 after Plaintiff completely failed respond to Defendant's discovery requests for over four
22 and a half months. Plainfiff refused to provide those responses unfil Defendant finally filed its first
23 Mofion to Compel. (Bardzell Deck, TITI 11-12.)
24 Recognizing that this Court is reluctant to award monetary sancfions unless a party
25 unsuccessfully opposes a discovery motion, Plaintiff appears to have strategically elected not to
26 oppose Defendant's prior Motion. As a result, the only sanctions this Court imposed were those
27 required under CCP. § 2033.280 relafing to Plaintiffs failure to provide responses to the
28 Requests for Admission. (See Bardzell Deck, TI 9 and Exhibit G.) That sancfions award was in the
{01965098.DOCX} 9
amount of $520, which fell well short of fully reimbursing Defendant for all the fees it had to
needlessly incur in filing a Motion to Compel Plainfiffs other responses. Even then, Plainfiff
3 failed to pay the full amount the Court ordered. (See Bardzell Deck, TjlO.)
4 Although the Court denied Defendant's previous request for sancfions in connecfion with
5 the motion to compel responses to interrogatories and request for production, the Court further
6 indicated in its Order on Defendant's previous motion to compel that "repeated conduct of failing
7 to comply with discovery obligations may lead the Court to find an abuse of the discovery process
8 and award sancfions on that basis." (See Bardzell Deck, T119, Exhibit G.)
9 Now, here we are again. Plaintiff failed to adequately respond to discovery. Defendant
10 communicated with Plainfiff multiple fimes in hopes of resolving these issues short of filing a
11 Motion to Compel. Unfortunately, Plaintiff failed to provide any further response, thereby
12 successfully forcing Defendant to again incur fees in filing this Motion.
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a; < o" t Defendant has incurred $4,160 in fees associated with preparing the present motion. (See
W £^ c 5; o^
Bardzell Decl., TI 20.) Defense counsel anticipates incurring an additional $1,300 in fees in the
17 event Plaintiff opposes the Mofion and a hearing is necessary. (Bardzell Deck, TI 20.) As a result.
18 Defendant respectfully requests an award of sanctions in the amount of $5,460 for the fime and
19 expense incurred by Defendant in filing this otherwise unnecessary motion.
20 V.
23 who engages in conduct that constitutes misuse of the discovery process. (CCP § 2023.030(a).)
25 of discovery" and "disobeying a court order to provide discovery." (CCP §§ 2023.010(d), (g).)
27 order to provide discovery, the Court may impose, among other relief, monetary sanctions and/or
28 terminating sancfions. (CCP § 2023.030(a), (d).)
{01965098.DOCX} 10
1 Coitrts have long held that terminating sanctions are appropriate where there is a willful
2 failure to comply with court orders, and should be issued where it appears that lesser sancfions
would not bring the offending party into compliance. (R.S. Creative, Inc. v. Creative Cotton, Ltd.
1
(1999) 75 Cal.App.4th 486, 496.) Terminating sanctions are especially appropriate where a party
6 Cal.App.3d 372, 383.)
7 Terminating sanctions are appropriate in this case. Defendant initially sought terminating
sanctions against Plaintiff in connection with its previous motion to compel discovery. The Court
denied this request, providing: The Court denies Defendant's alternate requests for issue,
10 evidentiary, and/or terminating sanctions at this fime. [. . .] Here, given that this is the first order
11
with respect to the subject discovery, the drastic remedy of terminafing sancfions would be
12
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punitive." (See Bardzell Deck, Exhibit G.)
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It is evident that Plaintiffs conduct is nothing more than a delaying tactic to prevent
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W i> c 5 o^ money, and Court resources to compel Plaintiff to lifigate this case would be categorically unjust.
S gI X 16 The aforementioned conduct has also prejudiced Defendant's ability to prepare for trial and will
= " 17 interfere with the Court's ability ascertain the tmth in this case. Given that previous discovery
18 mofion practice failed to compel Plaintiff to comply with his discovery obligations, terminafing
19 sanctions are now appropriate.
20 Accordingly, Defendant requests that the Court grant terminafing sancfions and issue an
22 VI.
23 CONCLUSION
25 however Plaintiff has failed to provide complete verified responses to Defendant's Special
27 Employment (Set One.) Defendant is left with no opfion other than to file the instant motion. As
28 such, Defendant seeks an Order (1) compelling Plainfiff to provide further verified responses,
{01965098.DOCX} 11
without objections, to Defendant's Special Interrogatories (Set One), Form Interrogatories - General
2 (Set One) and Form Interrogatories - Employment (Set One); (2) awarding sanctions in the amount
3 of $5,460 to retum Defendant to the position it would have been had complete responses been
4 timely provided; (3) issue terminafing sanctions against Plaintiff as a result of Plainfiffs repeated
5 failure to engage in the discovery process.
6
7
Dated February 11, 2019 PORTER SCOTT
10 By
David P. E. Burkett
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22
23
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25
26
27
28
{01965098.DOCX} 12
1
2
PROOF OF SERVICE
3
5
6
7 DEFENDANT'S POINTS AND AUTHORITIES IN SUPPORT OF DEFENDANT'S
MOTION TO COMPEL VERIFIED RESPONSES TO REQUESTS FOR PRODUCTION
8 OF DOCUMENTS SET ONE, SPECIAL INTERROGATORIES SET ONE, FORM
INTERROGATORIES - GENERAL SET ONE, FORM INTERROGATORIES -
9
EMPLOYMENT SET ONE; TO DEEM REQUEST FOR ADMISSIONS ADMITTED; AND
10 FOR MONETARY AND TERMINATING SANCTIONS
o
o course of business with the United States Postal Service, in a sealed envelope with postage fiilly prepaid.
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BY OVERNIGHT DELIVERY: 1 enclosed the documents in an envelope or package provided by an

o 17 ovemight delivery carrier and addressed to the person(s) listed below. I placed the envelope or package
m for collection and ovemight delivery at my office or a regularly utilized drop box of the ovemight
19 I faxed the documents to the persons at the fax numbers listed below. No error was reported by the fax
by electronic transmission, I caused the documents to be sent to the persons at the electronic notification
2.1 address listed below.
22
Jaroslaw Waszczuk
Lodi, CA 95242
24
26 foregoing is tme and correct. Executed at Sacramento, Califomia on Febmary 11, 2019.
27
28 Wendy E. Strasser
{01965098.DOCX} 13
EXHIBIT # 12
EXHIBIT # 13
EXHIBIT # 14
•----------i44o.).._%...€r,...
• i
PORTER I SCOTT EHOCRSED
2
David P. E. Burkett, SBN 241 896 201MM20 PM22
350 University Avenue, Suite 200 U P F P11 OnN COURT OF CMIPONiA
COUNtY OF 5ACRAME0U
TEL: 916.929.1481
5 FAX: 916.927.3706
dburkett(porterscott.com
6 dbardzeIlporterscott,com
7

10
11
13
Plaintiff, MEMORANDUM OF POINTS AND
V. DEFENDANTS', MOTION TO COMPEL
15
RESPONSES TO JUDGMENT DEBTOR
16 THE REGENTS OF THE UNIVERSITY OF INTERROGATORIES AND REQUEST
CALIFORNIA, UNIVERSITY OF FOR PRODUCTION OF DOCUMENTS;
17 CALIFORNIA DAVIS HEALTH SYSTEM, AND FOR MONETARY AND
UC DAVIS MEDICAL CENTER, UC TERMINATING SANCTIONS
18
19 BOYD, STEPHEN CHILCO'IlT, CHARLES Date: April 26, 2019
WITCHER, DANESHA NIcHoLS, CINDY Time: 2:00 p.m.
21
through 50, inclusive, Complaint Filed: December 4, 2013
23 /
24
25
26
27
28
0I978654.DOCX)
TABLE OF CONTENTS
2 Page
3
4 INTRODUCTION ..........................................
5 II STATEMENT OF FACTS AND PROCEDURAL HISTORY ...........................................1

6
A. Plaintiff Failed to Provide Timely Responses to Defendant's Form and
7 Special Interrogatories, Request for Production of Documents, and
Request for Admissions and Ignored Defendant's Related Meet-and-
8 ConferEfforts ...........................................................................................................3
9
B. Motion to Compel ....................................................................................................4
10
C. Plaintiff Failed to Pay Monetary Sanctions ..............................................................4
II
12 D. Plaintiff Again Ignores Defendant's Meet-and-Confer Efforts ................................5
0
0
13 E Second Motion to Compel ........................................................................................5
In oco
14 F. Plaintiff Further Ignores the .anti-SLAPP Defendants' Meet-and-Confer
- > C.) o Efforts Related to the Judgment Debtor Requests for Production of
<6' 15
Documents (Set One) and Judgment Debtor Interrogatories (Set One) ...................5
E-X 16
o r .
III. PLAINTIFF SHOULD BE ORDERED TO PROVIDE RESPONSES TO
0 17
In JUDGEMENT DEBTOR REQUEST FOR PRODUCTION OF DOCUMENTS
18 (SET ONE) AND JUDGMENT DEBTOR INTERROGATORIES (SET ONE).................7
19 A. Judgment Debtor Interrogatories (Set One) .............................................................7

20
B. Judgment Debtor Requests for Production of Documents (Set One) .......................8
21
IV. MONETARY SANCTIONS SHOULD BE AWARDED ...................................................9
22
V. TERMINATING SANCTIONS ARE ALSO APPROPRIATE ........................................10
23
24 IV. CONCLUSION ..................................................................................................................11
25
26
27
28
(01978654.DOCX) 1
2
State Court Cases
3
Kahn v. Kahn
4
(1977) 68 Cal.App.3d 372, 383 10
5
6 (1999) 75 Cal.App.4th 486,496 ........................................................................................10
7
Sinaiko Healthcare Consulting, Inc. v. Pacific Healthcare Consultants
8 (2007) 148 Cal.App.4tl 390,411 ........................................................................................8
9 Statutes
10
C.C.P. § 708.020 ............................................................................................................................ 7
II.
C.C.P. § 708.030 ............................................................................................................................ 7
12
C
C
13 C.C.P. § 2016.070 .......................................................................................................................... 7
I-. •S —
H at C
Oci °'Z 14 C.C.P. § 2023.010(d) ...................................................................................................................... 9
cg
_>Oac
<d\á 6
ce 15 C.C.P. § 2023.010(g) ...................................................................................................................... 9
16
H C.C.P. § 2023.030(a) ................................................................................................................ 9, 10
0
tin
17
C.C.P. § 2030.010 ..........................................................................................................................
18
19 C.C.P. § 2030.210(a) ...................................................................................................................... 7
20 C.C.P. § 2030.290(a) ...................................................................................................................... 8

21
C.C.P. § 2030.290(b) ...................................................................................................................... 8
22
C.C.P. § 2030.290(c) ...................................................................................................................... 9
23
24 C.C.P.2031.010 .......................................................................................................................... 7
25 C.C.P. § 2031.300(a) ...................................................................................................................... 8

26 C.C.P. § 2031.300(b) ...................................................................................................................... 8
27
C.C.P. § 2031.300(c) ...................................................................................................................... 9
28
Rules of Court, Rule 3.1245(b) ...................................................................................................... 8
{01978654.DOCX) ii
Defendants BOYD, CHILCOTT, NICHOLS, OROPEZA, and SEIFERT ("anti-SLAPP
2 Defendants") respectfully submit the following memorandum of points and authorities in support
3 of their motion to: (1) compel Plaintiff JAROSLAW ("JERRY") WASZCZUK's verified
4 responses to Judgment Debtor Requests for Production of Documents (Set One) and Judgment
5 Debtor Interrogatories (Set One); (2) award monetary sanctions in the amount of $4,940 to return
6 Defendants to the position they would have been had the subject judgment debtor discovery
7 responses been timely provided; (3) issue terminating sanctions against Plaintiff as a result of
8 Plaintiff's pattern of failure to engage in the discovery process.
9 1.
10
Defendants served Plaintiff with Judgment Debtor Requests for Production of Documents
12 (Set One) and Judgment Debtor Interrogatories (Set One) on October 9, 2012. Responses were due
13 on or before November 13, 2018. Plaintiff has completely failed to provide any responses and
14 same are overdue.
15 Defendants respectfully request the Court issue an Order to (1) compel Plaintiff to provide
16 verified responses to Defendants' Judgment Debtor Requests for Production of Documents (Set
17 One) and Judgment Debtor Interrogatories (Set One); and (2) issue monetary sanctions against
18 Plaintiff in the amount of $4,940 for Defendants' fees and costs incurred in bringing this motion;
19 and (3) issue the sanction of termination of the present action as a result of Plaintiffs failure to
20 provide responses to the Defendants' judgment debtor discovery.
21 H.
24 summary: Plaintiff filed the operative Second Amended Complaint ("SAC") on September 30,
26 Defendants:' (1) intentional infliction of emotional distress ("lIED"); (2) tortious interference with
28 'The First and Second Causes of Action in the Second Amended Complaint do not specifically identify Defendant UNIVERSITY
(01978654.DOCX) i
1 retaliation in violation of Government Code § 12940(a); and (4) whistleblower/uniawful retaliation
2 in violation of Government Code §§ 8547 etseq,
3 Each of these causes of action arises out of Plaintiff's employment with Defendant
4 REGENTS OF THE UNIVERSITY OF CALIFORNIA ("UNIVERSITY") at the University of
5 California at Davis Medical Center. In addition to Defendant UNIVERSITY2, these causes of
6 action were pled against Defendants ANN MADDEN RICE, MIKE BOYD, STEPHEN

9 and disciplinary actions that ultimately resulted in Plaintiff's termination of employment with the
12 SEIFERT ("anti-SLAPP Defendants") filed a Special Motion to Strike Plaintiff's causes of action
0
0
13 as pled against them. (See Declaration of Daniel Bardzell in Support of Motion to Compel
.r,OC
14 ("Bardzell Decl."), ¶ 2.) The anti-SLAPP Defendants contended that Plaintiff's causes of action
<6' 15 against them arose from protected activities pursuant to Code of Civil Procedure' § 425.16;
16 namely, their participation in the processing, investigation, hearing and deciding of complaints
0 17 filed by Plaintiff and others pursuant to the policies and procedures of the Defendant
Cr'
IS UNIVERSITY. (See Id.)

22 SLAPP Defendants. (See Bardzell Decl., ¶ 3 and Exhibit A.)
24 individual Defendants RICE, WITCHER, PUTNEY, and DANILIUC. (See Bardzell Decl., ¶ 4 and
25 Exhibit B.) The UNIVERSITY is the only Defendant remaining in the case.
26
27
2
See Id., lii. I.
28 Unless otherwise indicated, all further statutory references in this Motion are to the California Code of Civil
Procedure,
{01978654DOCX) 2
3 Special Motion to Strike. (See Bardzell Decl., ¶ 5.) The motion sought recovery of approximately
4 $33,000 in fees and costs incurred by the anti-SLAPP Defendants in connection with the Special
5 Motion to Strike. (See Bardzell Decl., Exhibit C.)
7 Costs in the amount of $22,284 against Plaintiff. (See Bardzell Decl., 16 and Exhibit C.)
8 A. Plaintiff Failed to Provide Timely Responses to Defendant's Form and Special
Interrogatories, Request for Production of Documents, and Request for Admissions
9 and Ignored Defendant's Related Meet-and-Confer Efforts
12 2018. (See Bardzell Decl., ¶ 7.) By correspondence dated May 22, 2018, Plaintiff requested an
13 extension of time to respond to all such requests on the basis that he was sick. (See Bardzell Decl.,
14 ¶ 8 and Exhibit D.) Defendant's counsel responded by email correspondence dated May 23, 2018
15 granting Plaintiff an extension of time to respond until June 20, 2018. (See Id.)
16 On September 24, 2018, counsel for Defendant UNIVERSITY served a meet and confer
17 correspondence upon Plaintiff regarding the outstanding discovery responses wherein defense
18 counsel indicated: "[P]lease provide complete responses to all such outstanding requests no later
19 than September 28, 2018. If we do not have your complete responses by that date, we will file a
20 motion to compel responses and request monetary as well as terminating sanctions from the
21 Court." (See Bardzell Decl., ¶ 9 and Exhibit B.)
22
By incoherent email correspondence also dated September 24, 2018, Plaintiff indicated:
23
Interrogatories. I appreciate but I not sure yet what I am going to. I am Waiting for answers
25 from the federal authorities in this matter.
I will let know. I mean time you can entertain yourself with my affirmative defense of
26 Judge Brett Kavanaugh. As Jeanine Pirro stated not so long ago,. UC Regent wife Senator
27 Feinstein's Unhinged Demon Rats attacking Judge Kavanaugh as I was attacked and
wasted by her husband and other unhinged UC demon rats. Same people only different is
28 that I have no I penny on my account and I am for my SS check on 28Th than I could buy
ink for my printer and do eventually interrogatories.
{01978654.DOCX
3
MEMORANDUM OF POINtS AM) AUFFIORIlIES IN SUFI'ORI OF DEFLINDANIS' MOTION 10
(See Bardzell Dee!., ¶ 10 and Exhibit F.)
I
2
2018. (See Bardzell Deci., ¶ 11.)
3
On October 1, 2018, Plaintiff submitted an email correspondence to Defendant stating: "I
4
am working on the Interrogatories and Other papers. Pleas give one more week to finish. Attached
5
is a part of interrogatories to show you that I am working on." (See Bardzell Dee!., ¶ 12 and
6
7 Exhibit F.) Included was a rambling apparent partial draft response to Defendant UNIVERSITY's
8 Special Interrogatories, Set One without a verification. (See Bardzell DecI., ¶ 12.)
9 B. Motion to Compel
10 On October 17, 2018, Defendant UNIVERSITY was forced to file a Motion to Compel and
11 needlessly incur the associated fees and costs. (See Bardzell DecI., ¶ 13.) On November 14, 2018,
12 the Court issued its tentative ruling, which later became the ruling of the Court pursuant to Local
13 Rule 1.06. (See Bardzell DecI., ¶ 14, and Exhibit H.) There, the Court ordered Plaintiff to provide
14 verified responses, without objections, to Defendant's form and special interrogatories (sets one)
15 and requests for production (set one) no later than December 12, 2018. (See id.) Additionally, the
16 Court ordered Plaintiff to pay Defendant UNIVERSITY mandatory monetary sanctions in the
18 (See id.)
19 Plaintiff did subsequently provide responses to the special and form interrogatories, but
20 they were largely deficient which necessitated the filing of a second motion to compel, as
21 described infra. (See Bardzell DecI., ¶ 15.)
22 C. Plaintiff Failed to Pay Monetary Sanctions
23 In addition to Plaintiff's willful disregard of his discovery obligations, Plaintiff also
24 violated the Court's previous Order by failing to fully pay Defendant UNIVERSITY monetary
25 sanctions. (See Bardzell DecI., 114-16.) As set forth above, in its prior Order, the Court directed
26 Plaintiff to pay monetary sanctions of $520 by December 14, 2018. (See Bardzell Deci., ¶ 14 and
27 Exhibit H.) Plaintiff failed to pay the required sanction by December 14, 2018 and, to-date,
28 Plaintiff has provided checks amounting to only a portion of the sanctions ordered by the Court.
(01978654.DOCX}
4
1 (See Bardzell Deci., 114; 16.) Defendant has not cashed such checks. (See Bardzell DecI., ¶ 16)
2 D. Plaintiff Again Ignores Defendant's Meet-and-Confer Efforts
4 counsel sent Plaintiffs counsel a meet and confer correspondence on January 15, 2019, advising
5 that Plaintiff's responses were deficient. (See Bardzell DecI., 117 and Exhibit I.)
6 Plaintiff responded on January 15, 2019 by a series of argumentative and disjointed emails
8 confer correspondence. (See Bardzell Deel., ¶ 18 and Exhibits J.)
9 Plaintiff subsequently requested, and was granted, additional time to respond to-the meet
10 and confer and the parties agreed to extend the time for Defendant to file a motion, if necessary,
11 through February 12, 2019. (See Bardzell Dee!., 119 and Exhibit K.)
12 By email dated January 25, 2019, Plaintiff further responded to Defendant's January 15,
14 stating that Defendant should "File the motion, and I, accordingly, will file the response to your
15 motion in court." (See Bardzell Dccl., ¶ 20 and Exhibit L.) Plaintiff has not provided amended
16 responses.
17 E. Second Motion to Compel
18 On February 11, 2019, Defendant UNIVERSITY was forced to file a second motion to
19 compel further verified responses to form and special interrogatories and for monetary, and
20 terminating sanctions. (See Bardzell DecI., ¶ 21.) On March 12, 2019, the Court issued its tentative
21 ruling, which later became the ruling of the Court pursuant to Local Rule 1.06. (See Bardzell
22 DecI., ¶ 21 and Exhibit M.) There, the Court ordered Plaintiff to provide further verified responses
23 to Defendant's form and special interrogatories (sets one) no later than April 3, 2019. (See id.)
24 Additionally, the Court denied Defendant's request for monetary sanctions as the motion was
25 unopposed and also denied Defendant's request for terminating sanctions. (See Ed.)
26 F. Plaintiff Further Ignores the anti-SLAPP Defendants' Meet-and-Confer Efforts
27
28 The anti-SLAPP Defendants served Plaintiff with Judgment Debtor Requests for
(01978654.DOCX)

1 Production of Documents (Set One) and Judgment Debtor Interrogatories (Set One) on October 9,
2 2018. (See Bardzell Dccl., ¶ 22 and Exhibit N.) Responses were due on or befoie November 13,
3 2018. (See Bardzell DecI., ¶ 22.) Plaintiff has completely failed to provide any responses and same
4 are overdue. (See id.)
5 On January 24, 2019, counsel for Defendants served a meet and confer correspondence
6 upon Plaintiff regarding the outstanding judgment debtor discovery responses wherein defense
7 counsel indicated: "This letter serves as Defendants [..j attempt to meet and confer regarding
8 Plaintiff's outstanding responses to Defendants' Judgment Debtor Request for Production of
9 Documents, Set One and Judgment Debtor Interrogatories, Set One which were served on you on
10 October 9, 2018. Plaintiff has provided no response whatsoever. Please provide complete
11 responses by January 31, 2019 or we will file a motion to compel and seek sanctions." (See
12 Bardzell Deci., 123 and Exhibit 0.)
0
0
N
13 By email correspondence dated January 25, 2019, Plaintiff asserted, he never received a
In 0
0 t; 14 copy of the judgment debtor discovery requests and further provided: "Please send me the
15 aforementioned documents that were supposed to have been sent in October. 1 will look them over
u
o. to and respond to you with 30 days, or you may file the motion to compel if you wish." (See Bardzell
0
In
17 DecI., 124 and Exhibit P.) By email correspondence also dated January 25, 2019, the office of
C.'
18 counsel for Defendants provided Plaintiff with a further courtesy copy of Defendants' Judgment
19 Debtor Request for Production of Documents, Set One and Judgment Debtor Interrogatories, Set
20 One which were previously served on Plaintiff on October 9, 2018. (See Id.)
21 Plaintiff responded by email also dated January 25, 2019, stating: "Never got this before.
22 Have a nice weekend Ms. Strasser. I feel sorry for you that you are working for guy like Burkett or
23 Bardzell. Tell them to file motion." (See Bardzell Dccl., ¶ 25 and Exhibit Q.)
24 On February 22, 2019, counsel for Defendant served, a further meet and confer
25 correspondence upon Plaintiff, providing: "This letter serves as Defendants II. J further attempt to
26 meet and confer regarding Plaintiffs outstanding responses to Defendants' [judgment debtor'
27 discovery requests]. Plaintiff has provided no response whatsoever and responses are more than
28 three months overdue. Our previous attempts to meet and confer on this issue have been
101978654D0CX) 6
1 unsuccessful. If we do not receive complete responses by March 1, 2019, our next action will be to
2 file a motion to compel and seek sanctions." (See Bardzell Deci., 126 and Exhibit R.)
3 By email correspondence dated March 1, 2019, Plaintiff provided, in part: "I am not going
5
California courts have done to me in the last four years. I did not provide the response by January
6 31, 2019 because the DEBTOR INTERROGATORIES - SET ONE TO PLAINTIFF [. . . and]
7
DEFENDANTS' REQUEST FOR PRODUCTION OF DOCUMENTS - SET ONE TO
8 PLAINTIFF [ ... ] were not sent to me on October 9, 2018 and I do not have any record of it[. . .
9
Porter Scott attorneys did not file a Motion to Compel as promised by the January 31, 2019 letter
11
date[. . .] If the Porter Scott attorneys want to file another Motion to Compel [. . .] I have no
12
control over it. I will not be surprised if the Motion is granted." (See Bardzell Deel., ¶ 27 and
13 Exhibit S.) Plaintiff further asserted that he provided some documents at the Judgment Debtor
14 examination in this matter. (See Id.)
15 III.
16 PLAINTIFF SHOULD BE ORDERED TO PROVIDE RESPONSES TO
JUDGMENT DEBTOR REQUEST FOR PRODUCTION OF DOCUMENTS (SET ONE)
20 interrogatories to the judgment debtor under C.C.P. § 2030.010, et seq., and (2) service of a
21 document inspection demand to the judgment debtor under C.C.P. § 2031.010, et seq. (See C.C.P.
22 §§ 2016.070; 708.020; 708.030.)
26 being sought to be discovered, an exercise of the party's option to produce writings, or an
27 objection to the particular interrogatory. (C.C.P. § 2030.210(a).) If a party to whom interrogatories
28 are directed fails to serve a timely response, the party propounding the interrogatories may move
{01978654.DOCX)
7
EMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF DEFENDANTS' MOTION TO
for an order compelling response to the interrogatories. (C.C.P. § 2030.290(b).) The party also
3 failing to respond by the deadline. (C.C.P. § 2030.290(a).)
5 to a 45-day time limit, and the propounding party does not have to demonstrate either good cause
6 or that it satisfied a meet-and-confer requirement. (Sinaiko Healthcare Consulting, Inc. v, Pacific
7 Healthcare Consultants (2007) 148 Cal. App. 4th 390, 411.) A separate statement is not required
9 In our case, Defendants have not received Plaintiffs verified responses to Judgment Debtor
10 Interrogatories (Set One). (See Bardzell DecI., ¶ 28.) These interrogatories were properly served on
11 Plaintiff on October 9, 2018. (See Bardzell Deci., ¶ 22 and Exhibit N.) Responses were due on or
12 before November 13, 2018. (See id.)
13 Defendants require these discovery responses in order to enforce their judgment.
14 Accordingly, Defendants respectfully request an Order compelling Plaintiff to provide verified
15 responses to Defendants' Judgment Debtor Interrogatories (Set One) without objections.
17 If a party to whom a demand for inspection is directed fails to serve a timely response, the
18 party propounding the demand may move for an order compelling responses to the demand.
19 (C.C.P. § 2031.300(b).) In addition, a party who fails to respond waives any objections he
20 otherwise could have raised to the demand. (C.C.P. § 2031.300(a).)
22 (Set One) and Judgment Debtor Interrogatories (Set One) on October 9, 2018. (See Bardzell Decl.,
23 ¶ 22 and Exhibit N.) Responses were due on or before November 13, 2018. (See id.) Plaintiff's
25 Therefore, Defendants respectfully request an Order compelling Plaintiff to provide
26 responses to Defendants' Judgment Debtor Request for Production of Documents (Set One),
27 without objections.
28 I/I
101978654.DOCX) 8
MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF DEFENDANTS' MOTION 1
Iv.
4
5 misuse of the discovery process, or any attorney advising that conduct, or both pay
the reasonable expenses, including attorney's fees, incurred by anyone as a result of
6 that conduct [ ... ] If a monetary sanction is authorized by any provision of this
7 title, the court shall impose that sanction unless it finds that the one subject to the
8 imposition of the sanction unjust.
9 C.C.P. §§ 2030.290(c) and 2031.300(c) provide that a court shall impose a monetary
13 matter by conducting extensive meet and confer efforts. Plaintiff has completely ignored
14 I Defendants' judgment debtor discovery requests.

16 discovery has made the current motion necessary, despite being afforded opportunities to avoid the
17 need for same.
18 To date, Defendants have incurred $3,640 in fees as a result of Plaintiff's failure to respond
19 to Judgment Debtor Requests for Production of Documents (Set One) and Judgment Debtor
20 Interrogatories (Set One). (See Bardzell DecI., ¶ 29.) Defendants anticipate incurring an additional
nI $1,300 to review Plaintiffs Opposition, prepare a reply and attend a hearing. (See Id.) Therefore,
22 sanctions are proper. Moreover, even if Plaintiff serves responses upon notice of this motion in
23 order to avoid a court order, Defendants have nevertheless been forced to incur the expense of
24 moving to compel Plaintiffs compliance with his discovery obligations, despite efforts to achieve
25 a cooperative result. As such, sanctions in the amount of $4,940 are appropriately awarded against
26 Plaintiff for the time and expense incurred by Defendants in filing this motion.
1
I-
I/I
28 I/I
0I978654.DOCX}
9
1 V
4 who engages in conduct that constitutes misuse of the discovery process. (C.C.P. § 2023.030(a).)
6 of discovery" and "disobeying a court order to provide discovery." (C.C.P. §§ 2023.010(d), (g).)
9 both. (CCP § 2023.030(a), (d), (g).)
12 would not bring the offending party into compliance. (R.S. Creative, Inc. v. Creative Cotton, Ltd
15 Cal.App.3d 372, 383.)
17 verified responses to the Defendants' written judgment debtor. discovery despite extensive meet
18 and confer efforts by Defendants. Moreover, the Court has previously granted two motions to
19 compel discovery filed by Defendant UNIVERSITY in this case. (See Bardzell Decl., 114, 21 and
20 Exhibits i-i, M.) Plaintiff has plainly not been dissuaded from his pattern of failing to engage in the
22 It is evident that Plaintiffs conduct is nothing more than a delaying tactic to prevent the
23 Defendants from engaging in judgment debtor discovery. Requiring Defendants to continue
24 wasting time, money, and Court resources to compel Plaintiff to fulfill his obligations to
25 participate in the case, including judgment enforcement process, would be categorically unjust.
26 Plaintiffs demonstrated pattern of failing to provide discovery responses has prejudiced
27 Defendants' ability to prepare for trial, as well as enforce its judgment and will interfere with the
28 Court's ability to ascertain the truth in this case. It has thus become apparent that no action will
I 978654D0CX) 10
PRODUCTION OF DOCUMENTS; AND FORMONETARY AND TERMINATING SANCTIONS
compel Plaintiff to comply with his discovery obligations, making terminating sanctions
2 appropriate.
3 Accordingly, Defendant requests that the Court grant terminating sanctions and issue an
5 VI.
6 CONCLUSION
8 however Plaintiff has failed to provide verified responses to Defendants' Judgment Debtor
9 Requests for Production of Documents (Set One) and Judgment Debtor Interrogatories (Set One).
10 Defendants are left with no option other than to file the instant motion. As such, Defendants seek
11 an Order (1) compelling Plaintiff to provide verified responses, without objections, to the anti-
12 SLAPP Defendants' Judgment Debtor Requests for Production of Documents (Set One) and
0
0
13 Judgment Debtor Interrogatories (Set One); (2) awarding sanctions in the amount of $4,940 to
H
H Ct 'fl
— O
14 return Defendants to the position they would have been had respobses been timely provided; (3)
<s'a 15 issue terminating sanctions against Plaintiff as a result of Plaintiffs continuing pattern of failure to
H
0 17
In
C,
Dated March 19, 2019 PORTER SCOTT
18 A PROFESSIONAL CORPORATION I I
19
20 By MJO4b/t(2(
David P. E. Burkett
23
24
25
26
27
28
{01978654D0CX} 11
Waszczuk v. Regents of the University of California, et at.
I
2
PROOF OF SERVICE
3
4 At the time of service, I was over 18 years of age and not a party to this action. My
business address is 350 University Avenue, Suite 200, Sacramento, California 95825.
5
6
MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF DEFENDANTS'
7 MOTION TO COMPEL RESPONSES TO JUDGMENT DEBTOR INTERROGATORIES
AND REQUEST FOR PRODUCTION OF DOCUMENTS; AND FOR MONETARY AND
BY MAIL: I placed the envelope for collection and mailing, following our ordinary business
9 practices. I am readily familiar with this business' practice for collecting and processing
correspondence for mailing. On the same day that correspondence is placed for collection and mailing,
10
it is deposited in the ordinary course of business with the United States Postal Service, in a sealed
envelope with postage hilly prepaid.
11
addressed below. (I) For a party represented by an attorney, delivery was made to the attorney or at
12
C the attorney's office by leaving the documents, in an envelope or package clearly labeled to identify
0
13 the attorney being served, with a receptionist or an individual in charge of the office, between the hours
—'0 of nine in the morning and five in the evening. (2) For a party, delivery was made to the party or by
-'Cl) In coo
Os °'2 14 leaving the documents at the party's residence with some person not younger than 18 years of age
between the hours of eight in the morning and six in the evening.
-<cc'
U a. o
0' overnight delivery carrier and addressed to the person(s) listed below. I placed the envelope or package
16 for collection and overnight delivery at my office or a regularly utilized drop box of the overnight
delivery carrier. -
Cn BY FAX TRANSMISSION: Based on an agreement of the parties to accept service by fax
0 17
In transmission, I faxed the documents to the persons at the fax numbers listed below. No error was
18 reported by the fax machine that I used. A copy of the record of the fax transmission, which I printed
out, is attached
19 BY ELECTRONIC SERVICE: Based on a court order or an agreement of the parties to accept
service by electronic transmission, I caused the documents to be sent to the persons at the electronic
20 notification address listed below.

Lodi, CA 95242
23
24
I declare under, penalty of perjury under the laws of the State of California that the
25
foregoing is true and correct. Executed at Sacramento, California on March 20, 2019.
26
27
tsser
28
{01978654.DOCX)
12
EXHIBIT # 16
MINUTE ORDER
DATE: 04/26/2019 TIME: 02:00:00 PM DEPT: 53
JUDICIAL OFFICER PRESIDING: Steven H Rodda
CLERK: E. Brown
REPORTER/ERM: V. Green CSR# 10529
BAILIFF/COURT ATTENDANT: Navi, A., R. Mays

APPEARANCES
Daniel Bardzell, counsel present for defendant
Nature of Proceeding: Motion to Compel Production of Documents
TENTATIVE RULING
Compel Responses to Judgment Debtor's Interrogatories and Judgment Debtor's Requests for
as follows:
action. The Court subsequently granted their Motion for Attorneys fees in the amount of $22,284. (Ex. C
to the Declaration of Daniel J. Bardzell)
Judgment Creditors served the instant post-judgment discovery (Ex. N) on October 9, 2018. Judgment
debtor/plaintiff failed to provide any responses to the discovery. Judgment Creditors sent a second copy
of the discovery to judgment debtor on January 25, 2019, after he contended that he never received the
first set served in October. No responses were served prior to filing this motion on March 20, 2019.
Judgment Debtor has filed an opposition contending that he has now served responses to the discovery,
attached as Exhibits 1 and 2. The points and authorities in opposition to the motion do not address the
relevant issues in this motion but consists almost entirely of matters irrelevant to the discovery at issue.
Judgment debtor opposes this "unwarranted motion to compel."
Judgment creditor's Reply contends that the discovery responses were not code compliant because
they contained objections and plaintiff has waived objections by not timely responding. The Court is not
reviewing the adequacy of the responses attached to the Opposition. However, moving parties are
entitled to a court order compelling code compliant responses to the discovery. Sinaiko Healthcare
Consulting, Inc. v Pacific Healthcare Consultants (2007) 148 Cal.App.4th 390, 404.
Judgment Debtor is ordered to serve further verified responses to the Judgment Debtor

Interrogatories and Judgment Debtor Requests for Production, as set forth in the separate statement,
without objections, on or before May 8, 2019.
Judgment debtor is also ordered to pay reasonable monetary sanctions to moving parties in the
amount of $780 (3 hrs at the hourly rate of $260), plus the $60 filing fee, for a total fee award of
$840. This opposition was filed without substantial justification and therefore, moving parties
are entitled to monetary sanctions. The monetary sanctions must be paid on or before May 27,
2019. If those sanctions are not paid by that date, moving parties may prepare a formal order on
the two sanctions awards which may thereafter be entered as a separate judgment. See
Newland v Superior Court (1995) 40 Cal.App.4th 608.
by judgment creditors, not Regents. Moving parties have already obtained a judgment of dismissal in
this case as well as an attorney fees award on the anti-SLAPP motion. Thus, it is unclear why they are
seeking a "terminating sanction" in this context.
a terminating sanctions as to Regents. To the extent plaintiff has not paid monetary sanctions to be paid
to Regents pursuant to prior court orders, Regents may prepare a formal order on that sanctions award
from the November 14, 2018 court order and then may enforce that award as a separate judgment
under Newland v Superior Court (1995) 40 Cal.App.4th 608.
As stated above, Plaintiff is ordered to serve verified responses to the Judgment Debtor Interrogatories
and Judgment Debtor Requests for Production, without objections, on or before May 8, 2019. Monetary
sanctions are to be paid as specified above.
notice is required.
COURT RULING
The order for monetary sanctions was vacated.

EXHIBIT # 17
1
1 IN THE SACRAMENTO SUPERIOR COURT

2 COUNTY OF SACRAMENTO, STATE OF CALIFORNIA
3 HON. STEVEN H. RODDA, DEPARTMENT 53
4 ---oOo---
5
)
6 JAROSLAW WASZCZUK, )
)
7 Plaintiff, )
) Case No.
8 VS. ) 2013-00155479
)
9 THE REGENTS OF THE UNIVERSITY OF )
CALIFORNIA, )
10 )
Defendant. )
11 _____________________________________
12
---oOo---
13
14 REPORTER'S TRANSCRIPT OF PROCEEDINGS
15
16 APRIL 26, 2019
17 ---oOo---
18
19
20 APPEARANCES:
21 For the Plaintiff:
22 JAROSLAW WASZCZUK, In Pro Per
23
For the Defendant THE REGENTS OF THE UNIVERSITY OF
24 CALIFORNIA:
25 PORTER SCOTT
BY: DANIEL BARDZELL, Attorney at Law
26 Sacramento, California
27
28 Reported by: VERONICA A. GREEN, CSR No. 10529

2
1 FRIDAY, APRIL 26, 2019

2 AFTERNOON SESSION
3 ---o0o---
4 The matter of JAROSLAW WASZCZUK versus THE
5 REGENTS OF THE UNIVERSITY OF CALIFORNIA, Defendant, case
6 number 2013-00155479, came on regularly this day before
7 the Honorable STEVEN H. RODDA, Judge of the Superior
8 Court of California, for the County of Sacramento,
9 Department 53.
10 The Plaintiff was represented by JAROSLAW
11 WASZCZUK, in pro per.
12 The Defendant, THE REGENTS OF THE UNIVERSITY OF
13 CALIFORNIA, was represented by DANIEL BARDZELL, Attorney
14 at Law.
15 The following proceedings were had:
16 ---o0o---
17 THE COURT: Waszczuk versus The Regents. Good
18 afternoon.
19 You are Mr. Waszczuk?
20 MR. WASZCZUK: Waszczuk, Jerry.
21 THE COURT: I will do my best. Sorry.
22 And your appearance, counsel?
23 MR. BARDZELL: Good afternoon, your Honor. Dan
24 Bardzell from Porter Scott representing Judgment
25 Creditors Boyd, Chilcott, Nichols, Oropeza and Seifert.
26 THE COURT: I have read what you submitted.
27 Anything in addition to what you submitted?
28 MR. WASZCZUK: I came late for court. I would

3
1 ask the Court to vacate the order and continue the

2 hearing with Judge Brown. This case is very complex.
3 It's six years old almost, and this is what I'm asking
4 for, the judge nullification, I believe.
5 THE COURT: That's right.
6 MR. WASZCZUK: And he knows the case.
7 THE COURT: I read the file.
8 MR. WASZCZUK: If we could argue about this
9 would be the best.
10 THE COURT: You are going to have to live with
11 me unless you disqualify me.
12 MR. WASZCZUK: I don't want to disqualify
13 anybody.
14 THE COURT: I'm going to hear this. This is my
15 responsibility here. I think this is pretty
16 straightforward in terms of the analysis. I know it has
17 quite a history. I'm familiar with that.
18 Your thoughts? Go ahead, tell me.
19 MR. WASZCZUK: Your Honor, I raised this issue
20 of a continuance with Judge Brown because he says second
21 time -- the second time defendant attempted to terminate
22 my lawsuit with Motion to Compel with different judge.
23 This is the reason.
24 The first time Mr. Bardzell went to -- on
25 October 3rd went to Judge Krueger and attempted to
26 terminate and got caught filing in their own department
27 the motion, then created -- I couldn't even go for a
28 hearing even.

4
1 THE COURT: Well, the puzzling part of that for

2 me is --
3 MR. WASZCZUK: It is important, your Honor.
4 THE COURT: The question is whether or not you
5 responded to the discovery requests.
6 MR. WASZCZUK: Your Honor, the discovery was
7 resolved in Department 43 on February 8th.
8 THE COURT: There was a debtor's examination,
9 right?
10 MR. WASZCZUK: Everything -- the counsel brought
11 production for documents and brought interrogatories,
12 and I answered them question by question and gave him
13 documents, everything. And everything is documented in
14 my two exhibits.
15 THE COURT: Have you filed written responses
16 besides the ones filed after this hearing?
17 MR. WASZCZUK: This is the whole point. This
18 was the conversation between me and counsel on meet and
19 confer letters. And Exhibits 3 and 4, everything is
20 there. And counsel had chance to go to a judge and
21 complain if I didn't give him anything.
22 THE COURT: That was a separate proceeding.
23 MR. WASZCZUK: He got everything. I have
24 nothing more to give him. Your Honor, I don't have
25 anything more to give him. This is the point.
26 THE COURT: Let me hear from Mr. Bardzell now.
27 MR. BARDZELL: Your Honor, we agree with the
28 Court that the debtor examination that plaintiff brought

5
1 up is a separate proceeding.
2 As we stated in our motion papers with respect
3 to this motion, we are entitled to receive timely
4 verified responses to the written debtor discovery.
5 Plaintiff failed to provide that discovery by the
6 deadline. We met and conferred. He did not serve
7 responses at the time we filed the motion. He did file
8 late responses, noncompliant, after we filed the motion.
9 And so we stand by our request.
10 THE COURT: At the debtor's examination, did you
11 ask him all of the same questions set forth in the
12 discovery requests?
13 MR. BARDZELL: We covered significant ground
14 related to the documented categories that were also
15 requested in the written discovery.
16 THE COURT: So wouldn't that just duplicate what
17 you requested in the discovery requests?
18 MR. BARDZELL: Well, at the debtor's examination
19 a number of questions were asked about his wife's
20 assets, and in that respect he was unwilling to provide
21 that information. We also served the written discovery,
22 which he did not timely respond to.
23 Additionally, at the debtor's examination there
24 was no court reporter. There was a lack of under oath
25 testimony. It was an informal proceeding.
26 THE COURT: Well, the debtor is a formal
27 proceeding, right? That's my experience.
28 MR. BARDZELL: I don't recall. I was under the

6
1 impression it was under oath. There's lack of a written

2 record of that. We still believe we are entitled to the
3 responses -- verified responses to the written
4 discovery.
5 THE COURT: Okay.
6 MR. WASZCZUK: Your Honor?
7 THE COURT: Yes.
8 MR. WASZCZUK: Your Honor, I clearly wrote and I
9 told counsel at the meeting on February 8th that I don't
10 have access to my wife's financial bank or 401 or wages
11 or anything. We keep this separate for 30 years. She
12 is in different bank. She got no even debit card. They
13 are asking me about my wife all the time. Not only they
14 were trying to provoke me before in the court, attacking
15 my wife in the court and attacking me in this court.
16 I am not going to sue my wife to give them
17 information. I gave them phone number. She is 68.
18 She's still working in Nordstrom to maintain our life.
19 The Regents, they owe me for contract
20 $1 million. The Regents contract with me, your Honor,
21 and they are talking about 22,000. And I gave them
22 Nordstrom phone number, her job. I gave them
23 everything, where she bank. If they want to go after
24 her, go for it. This is written here, your Honor.
25 THE COURT: Anything further on this? Anything
26 further you want to say?
27 MR. WASZCZUK: Because I don't have anything
28 more to give them, you know.

7
1 MR. BARDZELL: Your Honor, I just want to

2 reiterate that he did not provide written responses per
3 the deadline under the code. We believe we are entitled
4 to written responses to discovery.
5 THE COURT: Is the matter submitted for
6 decision?
7 MR. BARDZELL: Yes, your Honor.
8 THE COURT: Anything else you want to say before
9 I make a decision?
10 MR. WASZCZUK: Your Honor, I wanted to say
11 that -- I wanted to ask the Court -- I am on Social
12 Security. Those sanctions are unwarranted, your Honor.
13 I have nothing to give them anymore. And I am asking
14 the Court not to respond to them anymore for this.
15 THE COURT: Anything else?
16 MR. WASZCZUK: That is it, your Honor.
17 THE COURT: I'm going to confirm the tentative
18 ruling in this respect. You are going to be ordered --
19 you are ordered to consistently, pursuant to the
20 tentative order that I'm adopting, to provide the
21 responses. I'm going to vacate the sanctions under
22 these circumstances. The ordered sanctions as part of
23 the tentative ruling is vacated for monetary sanctions.
24 Otherwise, the tentative ruling is approved and
25 adopted in this respect. If it comes back again, Judge
26 Brown may impose the sanctions. That's up to him.
27 Thank you.
28 MR. WASZCZUK: No sanctions, your Honor?

8
1 THE COURT: Not this time.

2 MR. WASZCZUK: Okay. Thank you very much.
3 I ask your Honor, I don't have anymore -- I
4 don't need to respond anymore for them?
5 THE COURT: The order is you respond. That's
6 the order.
7 MR. WASZCZUK: What do I have to give him?
8 THE COURT: You will have to figure that out
9 yourself.
10 (Proceedings concluded.)
11 ---oOo---
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

9
1 Certificate of Certified Shorthand Reporter

2 STATE OF CALIFORNIA )
) ss.
3 COUNTY OF SACRAMENTO )
4 I, VERONICA A. GREEN, hereby certify that I am
5 an Official Certified Shorthand Reporter, and that at
6 the times and places shown, I recorded verbatim in
7 shorthand writing all of the proceedings in the
8 following described action completely and correctly, to
9 the best of my ability:
10 Court: SUPERIOR COURT OF CALIFORNIA,
11 DEPARTMENT 53
HON. STEVEN H. RODDA
12
Case: JAROSLAW WASZCZUK
13 VS.
14 CALIFORNIA Defendant
Case No:
15 2013-00155479
16 Date(s): APRIL 26, 2019
17
18 I further certify that my said shorthand notes
19 have been transcribed into typewriting, and that the
20 foregoing PAGES 1 to 9, inclusive, constitute an
21 accurate and complete transcript of all of my shorthand
22 writing for the dates and matter specified.
23 I further certify that I have complied with CCP
24 237(a)(2) in that all personal juror identifying
25 information have been redacted, if applicable.
26 Dated: May 31, 2019
27
______________________________________
28 VERONICA A. GREEN, CSR No. 10529

EXHIBIT # 18
TEL: 916.929.1481
5 FAX: 916.927.3706
dburkett@porterscott.com
6
dbardzelKolporterscott.com
7
8
9
Exempt From Filing Fees Pursuant to Government Code §6103
10
11
12
o JAROSLAW ("JERRY") WASZCZUK, CASE NO. 34-2013-00155479
o
B in
13
•3 a - ^14 Plaintiff, MEMORANDUM OF POINTS AND
o
u c/^c i<n a<
00 o AUTHORITIES IN SUPPORT OF
O ON Ov
15 V. DEFENDANTS' FURTHER MOTION TO
< _ COMPEL RESPONSES TO JUDGMENT
kQ
Oi.
•— IU . .
16 THE REGENTS OF THE UNIVERSITY OF DEBTOR INTERROGATORIES AND
O CALIFORNIA, UNIVERSITY OF REQUEST FOR PRODUCTION OF
(X
17 CALIFORNIA DAVIS HEALTH SYSTEM, DOCUMENTS; AND FOR MONETARY
AND TERMINATING SANCTIONS
19 BOYD, STEPHEN CHILCOTT, CHARLES Date: July 19, 2019
WITCHER, DANESHA NICHOLS, CINDY Time: 2:00 p.m.
21 PUTNEY, DORIN DANILIUC, and Does 1
through 50, inclusive. Complaint Filed: December 4, 2013
23
24
25
26
27
28
(02023105.DOCX} 1
1 TABLE OF CONTENTS
2 Page
3
4 I. INTRODUCTION
5 II. STATEMENT OF FACTS AND PROCEDURAL HISTORY .1
6
A. Plaintiff Failed to Provide Timely Responses to Defendant University's
7 Form and Special Interrogatories, Request for Production of Documents
and Request for Admissions Necessitating Two Motions to.Compel
8 Regarding Such Requests 3
9
B. Plaintiff Ignores the anti-SLAPP Defendants' Meet-and-Confer Efforts
10 Related to the Judgment Debtor Requests for Production of Documents
(Set One) and Judgment Debtor Interrogatories (Set One) 4
11
12 C. Anti-SLAPP Defendants File a Motion to Compel Responses Judgment
o
o Debtor Requests for Production of Documents (Set One) and Judgment
(N
13 Debtor Interrogatories (Set One) and for Terminating Sanctions 5
3
o 2: 14 D. Plaintiff Ignores the anti-SLAPP Defendants' Subsequent Meet-and-

on g < JT;
— > ri
oi. < 15 Confer Efforts Related to the Judgment Debtor Requests for Production .
C ON OS
u .. of Documents (Set One) and Judgment Debtor Interrogatories (Set One) 6
?^
o> " ^ 16,
cu 5 III. PLAINTIFF SHOULD BE ORDERED TO PROVIDE RESPONSES TO
17 JUDGMENT DEBTOR REQUESTS FOR PRODUCTION OF DOCUMENTS
18 (SET ONE) AND JUDGMENT DEBTOR INTERROGATORIES (SET ONE) 7
19 A. Judgment Debtor Interrogatories (Set One) 8

20 B. Judgment Debtor Request for Production of Documents (Set One) 9
21
IV. MONETARY SANCTIONS SHOULD BE AWARDED 10
22
23
v: TERMINATING SANCTIONS ARE ALSO APPROPRIATE ; 11
24 VI. CONCLUSION : ; 13
25
26
27
28
{02023105.DOCX) 11
1 TABLE OF AUTHORITIES
2 Page
State Court Cases
3
4 Sinaiko Healthcare Consulting, Inc. v. Pacific Healthcare Consultants
(2007) 148 Cal.App.4"^ 390, 411 8, 9
5
6 Kahn v. Kahn
(1977) 68 Cal.App.3d 372, 383 11
7
Kaiser Steel Corp. v. Westinghouse Elec. Corp.
8 55 Cal.App.3d 77, 744 8
9
10 (1999) 75 Cal.App.3d 372, 383 11
11 Zorro Inv. Co. v. Great Pacific Securities Corp.
12 (1977) 69 Cal.App.3d 907, 914 8, 10
o
o
B m 13
t— .
32 00 —
»o00 NO
h- cn
o
1^ 14 Statutes
O — m
o^ f-^
oi < 6 Os Ov 15 Code of Civil Procedure § 425.16 2
\D NO
ON ON
^ " i-J >< 16 Code of Civil Procedure § 425.16(c) 3
a< c iaUJ <
:D cn
17
o Code of Civil Procedure § 2023.010(d) ..11
• in
m
18
Code of Civil Procedure § 2023.010(g) ; 11
19
20 Code of Civil Procedure § 2023.030(a) .......11
21 Code of Civil Procedure § 2023.030(d) 11

22 Code of Civil Procedure § 2023.030(g) 11
23
24
Code of Civil Procedure § 2030.210(a) 8
25
26 Code of Civil Procedure § 2030.290(a) 8
27 Code of Civil Procedure § 2030.290(b) , 8

28 Code of Civil Procedure § 2030.290(c) ;.10
{02023105.DOCX) iii
1
Code of Civil Procedure §§ 2016.070; 708.020; 708.030 7
2
3
Code of Civil Procedure § 2031.250(1) 9
4
5 Code of Civil Procedure § 2031.300(a) 8, 9
6 Code of Civil Procedure § 2031.300(b) , , 9
7
Code of Civil Procedure § 2031.300(c) : ;.; 10
8
Govemment Code § 8547 et seq 2
9
10 Govemment Code § 12940(a) • 2
11 Rules ofCourt, mle 3.1345(b) ; 9

12
o
o
fN
a in 13
t . -q fN
P — NO
H ,2
cn o«
m oo o
O — m
14
u =^ ^
^5< ON
CeS < o
ON
NO NO
ON
15
(—, • - 1) 0 \ ON
IJ oo c 16
^ s iH tu
O- c S
3 cn
17
18
19
20
21
22
23
24
25
26
27
28
{02023105.DOCX} IV
1 Defendants BOYD, CHILCOTT, NICHOLS, OROPEZA, and SEIFERT ("anti-SLAPP
2 Defendants" or "Defendants") respectfully submit the following memorandimi of points and
3 authorities in support of their motion to: (1) compel Plaintiff JAROSLAW ("JERRY")
4 WASZCZUK's verified responses, without objections, to Judgment Debtor Requests for
Production of Documents (Set One) and Judgment Debtor Interrogatories (Set One); (2) award
monetary sanctions in the amount of $4,160.00 to retum Defendants to the position they would
have been had the subject judgment debtor discovery responses been timely provided; (3) issue
8 terminating sanctions against Plaintiff and in favor of Defendant REGENTS OF THE
9 UNIVERSITY OF CALIFORNIA ("UNIVERSITY") as a result of Plaintiff s pattem of failure to
11 I.
12 INTRODUCTION
o
o
fN
13 Anti-SLAPP Defendants served Plaintiff with Judgment Debtor Requests for Production of
t- 3 oo —
i n oo
t - cn ON -q-
0 u Documents (Set One) and Judgment Debtor Interrogatories (Set One) on October 9, 2018.
<• ON
^ g U ON fN
—> o ^ 5 15 Responses were due on or before November 13, 2018. Plaintiff has failed to provide verified and
ON ON
01 <
1 -J
2 UJ
^ 16 adequate responses and same are overdue.
Cu c ca u.
D Defendants respectfully request the Court issue an Order to (1) compel Plaintiff to provide
o
in 17
verified responses to the anti-SLAPP Defendants' Judgment Debtor Requests for Production of
18
Documents (Set One) and Judgment Debtor Interrogatories (Set One); (2) issue monetary sanctions
19 I
20 against Plaintiff in the amount of $4,160.00 for Defendants' fees and costs incurred in bringing this
21 motion; and (3) issue the sanction of termination of the present action as a result of Plaintiffs
.22 continuing pattem of failing to provide discovery responses.
IL
23
24
25
26
2014. Among the several claims in the SAC are four causes of action against all named
27
28
{02023105. DOCX}
1
1 Defendants:' (1) intentional infliction of emotional distress ("IIED"); (2) tortious interference with
4 in violation of Govemment Code §§ 8547 et seq.
5 Each of these causes of action arises out of Plaintiffs employment with Defendant
6 UNIVERSITY at the University of Califomia at Davis Medical Center. In addition to Defendant
7 UNIVERSITY^ these causes of action were pled against Defendants ANN MADDEN RICE,
8 MIKE BOYD, STEPHEN CHILCOTT, CHARLES WITCHER, DANESHA NICHOLS, CINDY
9 OROPEZA, BRENT SEIFERT, PATRICK PUTNEY, and DORIN DANILIUC for their
10 participation in investigations and disciplinary actions that ultimately resulted in Plaintiffs
11 termination of employment with the UNIVERSITY. The UNIVERSITY is the only Defendant
12 remaining in the case.
o
o
fN 13 On December 1, 2014, anti-SLAPP Defendants filed a Special Motion to Strike Plaintiffs
Bm
u- fN — NO
r- 3 oo 00 O
H (/2 14 causes of action as pled against them. (Declaration of Daniel Bardzell in Support of Further
0 u-o^
fN f N
01 < 6
ON ON
NO NO
15 Motion to Compel ("Bardzell Decl."), Tl 2.) The anti-SLAPP Defendants contended that Plaintiffs
U >:> cON ON
^ ^ E J ><
W <
16 causes of action against them arose from protected activities pursuant to Code of Civil Procedure-'
a. c H u.
D cn 17 § 425.16; namely, their participation in the processing, investiga:tion, hearing and deciding of
o
•n
18 complaints filed by Plaintiff and others pursuant to the policies and procedures of the Defendant
19 UNIVERSITY. (M)
/ • '. ' .
23 SLAPP Defendants. (Id. at ^ 3 and Exhibit A.)
24 ///
25
26
2 ld.,fn. 1. .
28
^ Unless otherwise indicated, all further statutory references in this Motion are to the Califomia Code of Civil
Procedure.
{02023105. DOCX} 2
2 individual Defendants RICE, WITCHER, PUTNEY, and DANILIUC. (Id. at H 4 and Exhibit B.)
3 The UNIVERSITY is the only Defendant remaining in the case.
6 Special Motion to Strike. (Id. at ^ 5.) The motion sought recovery of approximately $33,000 in fees
7 and costs incurred by the anti-SLAPP Defendants in cormection with the Special Motion to Strike.
8 (Id., Exhibit C.)
10 Costs in the amoimt of $22,284 against Plaintiff (Id. at 6 and Exhibit C.)
11 A. Plaintiff Failed to Provide Timely Responses to Defendant UNIVERSITY'S Form and
Special Interrogatories, Request for Production of Documents, and Request for
12
o Admissions, Necessitating Two Motions to Compel Regarding Such Requests
o
fN
B m
13 In the underlying lawsuit from which the anti-SLAPP Defendants have been dismissed,
L_ •= <N
r-" 3 00 — NO
H cn
O
00 o
—
14 Plaintiff has engaged in a pattem of failing to adequately and timely respond to Defendant
ON t~~
Îs fN fN
ON ON
NO NO
15 UNIVERSITY'S discovery requests which has necessitated the filing of two motions to compel
oi < 6 ON ON
j'
^ S3 1
UJ
><
<
16 discovery by Defendant UNIVERSITY on October 17, 2018 and Febmary 11, 2019, respectively.
O .2; !iH u.
D cn 17 (Bardzell Decl., H 7-12.) In its mling on Defendant UNIVERSITY'S October 17, 2018 motion to
18 compel, the Court ordered Plaintiff to provide verified responses, without objections, to
19 Defendant's form and special interrogatories (sets one) and requests for production (set one) no
20 later than December 12, 2018. (Id. at H 9 and Exhibit D.) Additionally, the Court ordered Plaintiff
21 to pay Defendant UNIVERSITY mandatory monetary sanctions in the amount of $520 by
22 December 14, 2018 for failure to provide responses to requests for admissions. (Id.)
23 Plaintiff violated the Court's order by failing to fully pay such monetary sanctions and by
24 providing only deficient responses to the special and form interrogatories which necessitated the
25 filing of a second motion to compel on Febmary 11, 2019. (Id. at T| 9-12.)
26 The Court granted Defendant UNIVERSITY'S second motion to compel and ordered
27 Plaintiff to provide further verified responses to Defendant's form and special interrogatories (sets
28 one) no later than April 3, 2019. (Id. at ^ 12 and Exhibit E.) Additionally, the Court denied
{02023105.DOCX} 3
1 Defendant's request for monetary sanctions as the motion was imopposed and also denied
2 Defendant's request for terminating sanctions, (/of.)
3 B. Plaintiff Ignores the anti-SLAPP Defendants' Meet-and-Confer Efforts Related to the
Judgment Debtor Requests for Production of Documents (Set One) and Judgment
4 Debtor Interrogatories (Set One)
5
The anfi-SLAPP Defendants served Plaintiff with Judgment Debtor Requests for
6
Production of Documents (Set One) and Judgment Debtor Interrogatories (Set One) on October 9,
7
2018. (Bardzell Decl., 13 and Exhibit F.) Responses were due on or before November 13, 2018.
8
(Id. at 13.) Plaintiff has completely failed' to provide any verified responses and same are
9
overdue. (Id.)
10
On January 24, 2019, counsel for Defendants served a meet and confer correspondence
11
upon Plaintiff regarding,the outstanding judgment debtor discovery responses wherein defense
12
o
o counsel indicated: "This letter serves as Defendants [. . .] attempt to meet and confer regarding
fN
B m
13
>
H
'= 00 — NO
CO i n 00 p ^ ^
Plaintiffs outstanding responses to Defendants' Judgment Debtor Request for Production of
o « °^ 2 p; 14 Documents, Set One and Judgment Debtor Interrogatories, Set One which were served on you on
> U ON ON . _
ai, < o so ^ 1 J
October 9, 2018. Plaintiff has provided no response whatsoever. Please provide complete
S 1 -J X 16
a- ta-
c cau H u. responses by January 31, 2019 or we will file a motion to compel and seek sanctions." (Id. at ^ 14
3 cn
o
in 17 and Exhibit G.)
18 By email correspondence dated January 25, 2019, Plaintiff asserted he never received a
19 copy of the judgment debtor discovery requests and further provided: "Please send me the
20 aforementioned documents that were supposed to have been sent in October. I will look them over
21 and respond to you with 30 days, or you may file the motion to compel if you wish." (Id. at ^ 15
22 and Exhibit H.) By email correspondence also dated January 25, 2019, the office of coimsel for
23 Defendants provided Plaintiff with a further courtesy copy of Defendants' Judgment Debtor
24 Request for Production of Documents, Set One and Judgment Debtor Interrogatories, Set One
25
26
27
/ •. •
which were previously served on Plaintiff on October 9, 2018. (/i/.)
/// ".
28
{02023105. DOCX} A

Plaintiff responded by email also dated January 25, 2019, stating: "Never got this before.
Have a nice weekend Ms. Strasser. I feel sorry for you that you are working for guy like Burkett or
Bardzell. Tell them to file motion." (Id. at 116 and Exhibit I.)
On February 22, 2019, counsel for Defendant served a further meet and confer
correspondence upon Plaintiff, providing: "This letter serves as Defendants [. . .] further attempt to
meet and confer regarding Plaintiffs outstanding responses to Defendants' [judgment debtor
discovery requests]. Plaintiff has provided no response whatsoever and responses are more than
three months overdue. Our previous attempts to meet and confer on this issue have been
unsuccessful. If we do not receive complete responses by March 1, 2019, our next action will be to
10 file a motion to compel and seek sanctions." (Id. at ^ 17 and Exhibit J.)
11 By email correspondence dated March 1, 2019, Plaintiff provided, in part; " I am not going
o
o
in
rJ
13 Califomia courts have done to me in the last four years. I did not provide the response by January
H 3 00 —
m 00
i— cn
O u ON 14 31, 2019 because the DEBTOR INTERROGATORIES - SET ONE TO PLAINTIFF [. . . and]
on g fN
<
< ri fN S 15 DEFENDANTS' REQUEST FOR PRODUCTION OF DOCUMENTS - SET ONE TO
o" ^ ON
5 ON
<U . .
6 -1 ^ 16 PLAINTIFF [. . .] were not sent to me on October 9, 2018 and I do not have any record of it[. . . .]
U.
1u
17 Porter Scott attomeys did not file a Motion to Compel as promised by the January 31, 2019 letter
19 date[. . .] If the Porter Scott attomeys want to file another Motion to Compel [. . .] I have no
20 control over it. I will not be surprised if the. Motion is granted." (Id. at T| 18 and Exhibit K.)
21 Plaintiff fiirther asserted that he provided some documents at the Judgment Debtor examination in
22 this matter. (Id.) ,
. 23 C. Anti-SLAPP Defendants File a Motion to Compel Responses Judgment Debtor

Requests for Production of Documents (Set One) and Judgment Debtor
24 Interrogatories (Set One) and For Monetary and Terminating Sanctions
25 On March 20, 2019, the anti-SLAPP Defendants filed a Mofion to Compel Responses
26 Judgment Debtor Requests for Production of Documents (Set One) and Judgment Debtor
27
Interrogatories (Set One), and for monetary and terminating sanctions. (Bardzell Deck, ^ 19.)
28
{02023105.DOCX} " ^

1 On April 15, 2019, while the anti-SLAPP Defendants' motion to compel judgment debtor
2 discovery was pending, Plaintiff served unverified, deficient responses to Defendants' Judgment
3 Debtor Requests for Production of Documents (Set One) and Judgment Debtor Interrogatories (Set
4 One). (Id. at ^ 20 and Exhibit L.)
5 'On April 25, 2019, the Court issued its tentative ruling, which later became the mling of
6 the Court pursuant to Local Rule 1.06 with a modificafion. (Id. at Tl 21.) The Court's final mling on
7 this motion rejected Plainfiffs argument in opposition that adequate responses were served
8 subsequent to the filing of the mofion and ordered Judgment Debtor "to serve further verified
9 responses to the Judgment Debtor Interrogatories and Judgment Debtor Requests for Production [.
10 , .] without objections, on or before May 8, 2019." (Id. and Exhibit M.)
11 Although the Court's tentative mling had initially also required Plaintiff "to pay reasonable
12 monetary sancfions to [the anfi-SLAPP Defendants] in the amount of $780 (3 hrs. at the hourly rate
o
o
fN 13 of $260), plus the $60 filing fee, for a total fee award of $840", this sancfions award was vacated
B m
fN — NO
H
,2 00 00 o
m 14 pursuant to the Court's final ruling. (Id.) The Court denied the anti-SLAPP Defendants further
O ON r~
fN fN
15 request for terminating sanctions related to the underlying lawsuit against the UNIVERSITY. (Id.)
îu ON ON
NO NO
ON ON
as < dJ >< 16
^ " iUi <
Plaintiff failed to serve verified responses to the Judgment Debtor Interrogatories eind
a- c «
D C/3 17 Judgment Debtor Requests for Production without objections by May 8, 2019 in violation of the
o
m
18 Court's order and such responses remain outstanding. (Id. at T| 22.)
19
D. Plaintiff Ignores the anti-SLAPP Defendants' Subsequent Meet-and-Confer Efforts
20 Related to the Judgment Debtor Requests for Production of Documents (Set One) and
21 Judgment Debtor Interrogatories (Set One)
22 On May 31, 2019, counsel for Defendants served a meet and confer correspondence upon
23 Plaintiff regarding the outstanding judgment debtor discovery responses which indicated:
24 This letter serves as Defendants MICHAEL BOYD, STEPHEN CHILCOTT, BRENT

SEIFERT, CINDY OROPEZA, and DANESHA NICHOLS ("Defendants'") attempt to
25
meet and confer regarding Plaintiffs failure to provide fiirther responses to Defendants'
26 Judgment Debtor Interrogatories - Set One and Judgement Debtor Request for Production
of Documents - Set One.
27 As provided by the Court's April 27, 2019 Minute Order following its April 26,
2019 tentative mling, Judgment Debtor/Plaintiff was ordered to "serve further verified
28
responses to the Judgment Debtor Interrogatories and Judgment Debtor Requests for
(02023105.DOCX} fi .
Production, as set forth in the separate statement, without objections, on or before May 8,
1 2019."
2 Plaintiff has failed to provide any further responses whatsoever. Please provide
complete responses immediately or we will take further action, as needed.
3
(Bardzell Deck, 123 and Exhibit N.)
4
Plainfiff responded by email dated June 1, 2019, stating, in part:
I will respond to your inquiry within a few days (most likely next week). [. . .] Your
threating letter stating "Please provide complete responses immediately or we will take
fiirther action, as needed" made me feel very uncomfortable. I received your May 31, 2019
threat of unspecified further action on the seventh anniversary of the ill-plaimed but
8 unsuccessfiil provocation to end my employment in the UC Davis Medical Center Trauma
Unit #11 by the specially assembled hit squad, which I nicknamed in the Court Documents
9
as the "Davis Death Squad." I hope that your new threat does not mean that the UCOP mob
10 led by Janet Napolitano gave the order to Porter Scott's special team to physically harm me
or my family members, taking into consideration previous Porter Scott attomeys'
11 provocations threats and 14 years of terror.
12 (Id. at H 24 and Exhibit O.)
o
o
fN
B m
13 Plaintiff further responded by email dated June 8, 2019, stating in part:
E- 3 S - NO
O cn m 00 o 14
U 1) ON •*
— m As I stated in my April 12, 2019 Opposition to Defendants' Motion to Compel and
t/2 i < ON
Oi u fN s:^ 15 Terminate Sanctions filed by you on March 20, 2019, for the Defendants' Judgment
UJ
H > ( J ON ON Debtor Interrogatories Set One and Judgment Debtor Request for Production of
oi
O <^> —o" ^ — 16 Documents Set One, and during the April 26, 2019 Court hearing with Judge Steven
&- .3 uC ON ON
5 td
17 Rodda, I have no more information to give you other than what you have received already.
D cn
o In fact, I should not give you any information in this matter, but this is a separate subject
in 18 that I wiir address after you file another Mofion to Compel or any other mofion related to
this case.
19
20 (Id. at H 25 and Exhibit P.)
21 III.
PLAINTIFF SHOULD BE ORDERED TO PROVIDE RESPONSES TO
22 JUDGMENT DEBTOR REOUEST FOR PRODUCTION OF DOCUMENTS (SET ONE)
26 interrogatories to the judgment debtor imder CC-P- § 2030.010, et seq., and (2) service of a
27 document inspecfion demand to the judgment debtor under CCP. § 2031.010, et seq. (CCP. §§
28
2016.070; 708.020; 708.030.)
{02023105.DOCX} 7
3 separately to each interrogatory by any of the following: an answer containing the informafion
4 being sought to be discovered, an exercise of the party's opfion to produce writings, or an
objection to the particular interrogatory. (CCP. § 2030.210(a).) If a party to whom interrogatories
are directed fails to serve a timely response, the party propounding the interrogatories may move
for an order compelling response to the interrogatories. (CCP. § 2030.290(b).) The party also
9 failing to respond by the deadline. (CC^P. § 2030.290(a).)
11 to a 45-day time limit, and the propoimding party does not have to demonstrate either good cause
12 or that it satisfied a meet-and-confer requirement. (Sinaiko Healthcare Consulting, Inc. v. Pacific
o
o
13 Healthcare Consultants (2007) 148 Cal.App.4th 390, 411.) A separate statement is not required
f- 3 fOO
N
—
m OO
O u ON -Sl- when no response has been provided to the request for discovery. (Rules of Court, mle 3.1345(b).)
< • ON f N
—>
ON 2 15 In our case. Defendants have not received Plaintiffs verified responses to Judgment Debtor
fN
a; < 2" )B ON
S ON
oi I- LZ ^ 16 Interrogatories (Set One). (Bardzell Deck, t 22.) These interrogatories were properly served on
y r-
o
in 17 Plaintiff on October 9, 2018. (Id. at T| 13 and Exhibit F.) Responses were due on or before
18 November 13, 2018. (M)
19 Plaintiff served imverified, deficient and late responses to Judgment Debtor Interrogatories
20 (Set One) on April 15, 2019. (Id. at 20 and Exhibit L.) Interrogatory responses served without a
21 verification are tantamount to serving no responses as all. (Zorro Inv. Co. v. Great Pacific
22 Securities Corp. (1977) 69 Cal.App.3d 907, 914 ("Untimely or unswom statements are tantamovmt
23 to no response at all[.]") citing Kaiser Steel Corp. v. Westinghouse Elec. Corp., 55 Cal.App.3d
24 737, 744.).) Plaintiffs unswom responses are wholly insufficient and constitute a complete failure
25 to respond.
26 Plaintiffs late unverified interrogatory responses are not code-compliant discovery
27 responses. Plaintiff has waived any objections to^the requests by failing to timely respond to them.
28 (Code of Civil Procedure sections 2030.290(a) [interrogatories] & 2031.300(a) [producfion
{02023105. DOCX} g
FOR PRODUCTION QF DOCUMENTS; AND FOR MONETARY AND TERMINATING SANCTIONS
1 requests].) Instead of serving responses without objections, the unverified responses contain
2 outright refusals to provide information regarding Plaintiffs wife's finances. (Bardzell Deck,
3 Exhibit L, "Response to Defendants' Judgment Debtor Rpgs #1".) Defendants are entitled to that
4 information to determine what assets Plaintiff has (whether individually or as community
5 property), so they can determine what can be collected, and how to collect it, to pay the judgments
6 that he owes in this case. Plaintiff refused that provide that information at the debtor's examination
7 (which is part of the reason why Defendants have had to file this motion not\yithstanding their
8 attempt to resolve the issues in this motion by taking discovery into Plaintiffs assets via the
9 debtor's examination). (Id.)
10 Defendants require these verified interrogatory responses in order to enforce their,
11 judgment. Accordingly, Defendants respectfiilly request a further Order compelling Plainfiff to
12 provide verified and code-compliant responses to anti-SLAPP Defendants' Judgment Debtor
o
o
fN
B m
13 Interrogatories (Set One) without objections.
U- 3 fN
r- 3 oo _ NO
t- cn 00 g
^ rn
fN
oi < 6
ON I3N 15 If a party to whom a demand for inspection is directed fails to serve a timely response, the
NO NO
ON OS
b 3 J >< 16 party propounding the demand may move for an order compelling responses to the demand.
o > sLU
H
<
ti.
D C/2
o
17 (CCP. § 2031.300(b).) The party to whom the demand for inspection is directed shall sign the
in
f^
18 response under oath unless the response contains only objections. (CCP. § 2031.250(1).) In
19 addition, a party who fails to respond waives any objecfions he otherwise could have raised to the
20 demand. (CCP. § 2031.300(a).)
21 As discussed supra, where, as here. Plaintiff has failed to provide any timely verified
22 responses, a motion to compel responses is not subject to a 45-day time limit, and the propoimding
23 party does not have to demonstrate either good cause or that it satisfied a meet-and-confer
24 requirement. (Sinaiko Healthcare Consulting, Inc., supra, 148 Cal.App.4th at 411.) A separate
25 statement is not required when no response has been provided to the request for discovery. (Rules
26 ofCourt, mle 3.1345(b).)
28 (Set One) on October 9, 2018. (Bardzell Deck, ^ 13 and Exhibit F.) Responses were due on or
{02023105.DOCX} 9
1 before November 13, 2018. (Id.) Plaintiffs responses remain overdue and outstanding. (Id. at ^ 13,
2 22.) .
3 Plainfiff served unverified, late and deficient responses to Judgment Debtor Requests for
4 Production of Documents (Set One) on April 15, 2019. (Id. at ^ 20 and Exhibit L.) As discussed
5 supra, discovery responses served without a verification are tantamount to serving no responses as
6 all. (Zorro Inv. Co., supra, 69 Cal.App.3d at 914.) Moreover, for the same reasons set forth supra
7 regarding Plaintiffs judgment debtor interrogatory responses. Plaintiffs responses to Judgment
8 Debtor Requests for Production of Documents (Set One) are not code compliant. Plaintiff s
9 imswom responses to Judgment Debtor Requests for Production of Documents (Set One) are
10 wholly insufficient and constitute a complete failure to respond.
11 Therefore, Defendants respectfiilly request an Order compelling Plainfiff to provide
12 verified responses to Defendants' Judgment Debtor Request for Production of Documents (Set
B m
13 One), without objections.
[_ - 3 rNi
— NO
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U
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3 (/I 17
18 misuse of the discovery process, or any attomey advising that conduct, or both pay
the reasonable expenses, including attomey's fees, incurred by anyone as a result of
19 that conduct [. . .] If a monetary sanction is authorized by any provision of this
20 fitle, the court shall impose that sanction imless it finds that the one subject to the
21 imposition of the sanction imjust.
22 CCP. §§ 2030.290(c) and 2031.300(c) provide that a court shall impose a monetary
26 matter by conducting extensive meet and confer efforts. Plaintiff has ignored his obligation to
27 provide verified and adequate responses to Defendants' judgment debtor discovery requests. He
28 has further failed to comply with the Court's order compelling responses.
{02023105. DOCX}
10
2 discovery has made this second judgment debtor discovery motion necessary, despite being
3 afforded the opportunity to avoid the need for same.
4 To date. Defendants have incurred $2,860.00 in fees as a result of Plaintiffs failure to
5 respond to Judgment Debtor Requests for Production of Documents (Set One) and Judgment
6 Debtor Interrogatories (Set One) since the Court mled on Defendants' inifial mofion to compel
7 judgment debtor discovery. (Bardzell Deck, ^ 26.) Defendants anticipate incurring an additional
8 $1,300 to review Plaintiffs Opposifion, prepare a reply and attend a hearing. (Id.) Therefore,
9 sanctions are proper. Moreover, even i f Plaintiff serves verified responses upon notice of this
10 motion in order to avoid a court order. Defendants have nevertheless been forced to incur the
11 expense of moving to compel Plaintiffs compliance with his discovery obligations, despite efforts
12 to achieve a cooperative result. As such, sanctions in the amount of $4,160.00 are appropriately
o
o
fN 13 awarded against Plaintiff for thefimeand expense incurred by Defendants in filing this motion.
B m
— NO
L_ -3 fN
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14 V.
ON I-^
fN fN
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o
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oi u <
O
oi
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D cn 17 who engages in conduct that constitutes misuse of the discovery process. (CCP. § 2023.030(a).)
o
in
19 of discovery" and "disobeying a court order to provide discovery." (CCP. §§ 2023.010(d), (g).)
22 both. (CCP § 2023.030(a), (d), (g).)
25 would not bring the offending party into compliance. (R.S. Creative, Inc. v. Creative Cotton, Ltd.
27 fails to respond to discovery requests and ignores court orders. (Kahn v. Kahn (1977) 68
28 Cal.App.3d372, 383.)
{02023105.DOCX} 11
2 verified responses to the Defendants' written judgment debtor discovery despite extensive meet
3 and confer efforts by Defendants. Moreover, the Court has previously granted a motion to compel
4 judgment debtor discovery filed by the anti-SLAPP Defendants in this case. (Bardzell Deck, ^ 21
5 and Exhibits M.) Plainfiff has completely ignored the Court's order regarding the prior judgment
6 debtor discovery motion. (Id. at ^ 22.) Plaintiff has plainly not been dissuaded from his pattem of
7 failing to engage in the discovery process.
8 Additionally, the Court has previously granted two motions to compel discovery filed by
9 Defendant UNIVERSITY in the underlying lawsuitfi"omwhich the judgment at issue arose. (Id. at
10 ^ 7-12 and Exhibits D-E.) Although these further discovery failures pertain to discovery requests
11 served by Defendant UNIVERSITY rather than the anti-SLAPP Defendants, such aggravafing
12 circumstances regarding discovery in the underlying lawsuit, when considered along with
o
o
fN
ii m
13 Plaintiffs pattern of failing to engage in the judgment enforcement discovery process, warrant the
"3 fN
t r2 00 — 5 14 remedy of terminating sanctions of the underlying lawsuit against Defendant UNIVERSITY.
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ON ON . ^
Plainfiffs demonstrated pattem of failing to provide discovery responses has prejudiced
U ^^11).I 5^. ,5;
I- r ^
Defendants' ability to prepare for trial by necessitafing substantial expenditures of time and money
D cn
o 17 to compel Plaintiff to both (1) comply with his discovery obligations in the underlying lawsuit; and
18 (2) fulfill his judgment debtor discovery obligations to permit the anfi-SLAPP Defendants to
19 enforce their judgment.
20 Plaintiffs enduring lack of cooperation with the discovery process - despite a total of three
21 prior discovery motions - makes it apparent that no action will compel Plaintiff to comply with his
22 discovery obligations, making terminating sanctions appropriate.
23 Accordingly, Defendants request that the Court grant terminating sanctions and issue an
24 Order dismissing the complaint against the remaining Defendant UNIVERSITY in its enfirety,
25 with prejudice.
26 ///
27 ///
28 ///
{02023105.DOCX}
12
1 VL
2 CONCLUSION
4 however Plaintiff has failed to provide verified responses to the anti-SLAPP Defendants'
,5 Judgment Debtor Requests for Production of Documents (Set One) and Judgment Debtor
6 Interrogatories (Set One). Defendants are left with no option other than to file the instant motion.
7 As such. Defendants seek an Order (1) compelling Plaintiff to provide verified responses,'without
objections, to the anti-SLAPP Defendants' Judgment Debtor Requests for Production of
Documents (Set One) and Judgment Debtor Interrogatories (Set One); (2) awarding anti-SLAPP
10 Defendants sanctions in the amount of $4,160.00 to retum them to the position they would have
11 been had responses been timely provided; (3) issue terminating sancfions against Plaintiff in favor
12 of Defendant UNIVERSITY as a result of Plaintiff s continuing pattern of failing to engage iri the
o
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am
3 fN _
r-* 3 00 NO
E- cn m oo p
o u =^ 2: P; 14
> N j ON ON .. ^ Dated: June 12, 2019 PORTER SCOTT
< O" ^ ^ 1^
•ijj 2^ c o^ A PROFESSIONAL CORPORATION
S g g -J X 16
By.
19
20
21
22
23
24
25
26
27
28
{02023105. DOCX}
13
1
2
3 PROOF OF SERVICE
4 At the time of service, I was over 18 years of age and not a party to this acfion. My
business address is 350 University Avenue, Suite 200, Sacramento, Califomia 95825.
5
7 MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF DEFENDANTS'

MOTION TO COMPEL RESPONSES TO JUDGMENT DEBTOR INTERROGATORIES
8 AND REQUEST FOR PRODUCTION OF DOCUMENTS; AND FOR MONETARY AND
o
o addressed below. (1) For a party represented by an attomey, delivery was made to the attomey or at the
fN
^ in
•3 S - NO attomey being served, with a receptionist or an individual in charge of the office, between the hours of nine
cn m 00 o
o «r <^ !^ 14 in the moming and five in the evening. (2) For a party, delivery was made to the party or by leaving the
u i <• Jri documents at the party's residence with some person not younger than 18 years of age between the hours
> NJ CJN
oi < o " NO NO
15 ON
of eight in the moming and six in the evening.
W C ON ON
H BY OVERNIGHT DELIVERY: I enclosed the documents in an envelope or package provided by an
ai 16 ovemight delivery carrier and addressed to the person(s) listed below. I placed the envelope or package for
O
collection and ovemight delivery at my office or a regularly, utilized drop box of the ovemight delivery
c/o 17 carrier.
machine that \ used. A copy of the record of the fax transmission, which I printed out, is attached
19
20 electronic transmission, I caused the documents to be sent to the persons at the electronic notification
address listed below. '
21
Jaroslaw Waszczuk
Lodi, CA 95242
23
24
25 I declare under penalty of perjury imder the laws of the State of Califomia that the
26 foregoing is tme and correct. Executed at Sacramento, Califomia on Jime 12, 2019.
27
28 Wendy Strasser
{02023105.DOCX}
14
EXHIBIT # 24
MINUTE ORDER
DATE: 07/19/2019 TIME: 02:00:00 PM DEPT: 53
CLERK: D. Johnson-Mellado
REPORTER/ERM: L. Gallager # 8726
BAILIFF/COURT ATTENDANT: Alvi, N., R. Mays

APPEARANCES
Dan Bardzell, Counsel for defendant
Nature of Proceeding: Motion to Compel Responses and Request for Production of Docs
TENTATIVE RULING
Compel Responses to Judgment Creditors' Interrogatories and Judgment Debtor's Requests for
as follows.
action and entered judgment in favor of Judgment Creditors. The Court subsequently granted Judgment
Creditors' Motion for Attorneys' fees in the amount of $22,284. (Bardzell Decl. ¶¶ 3, 6, Exhs. A, C.)
Judgment Creditors served the instant post-judgment discovery on October 9, 2018. (Bardzell Decl. ¶13,
Exh. F.) Judgment debtor/plaintiff failed to provide any responses to the discovery. Judgment Creditors
sent a second copy of the discovery to judgment debtor on January 25, 2019, after judgment
debtor/plaintiff contended he never received the first set served in October. (Bardzell Decl. ¶ 14, Exh. G.)
After receiving no responses, Judgment Creditors filed a motion to compel responses on March 20,
2019. On April 15, 2019, while the motion to compel was pending, judgment debtor/plaintiff served
unverified responses. (Bardzell Decl. ¶ 20, Exh. L.)
On April 26, 2019, the Court granted Judgment Creditors' motion to compel and ordered judgment
debtor/plaintiff to serve further verified responses, without objections, on or before May 8, 2019. (ROA
211.) While monetary sanctions were initially granted in the tentative ruling, after hearing at oral
argument, the Court vacated the order for monetary sanctions.
Judgment debtor/plaintiff has failed to comply with this Court order and provide any further responses.
(Bardzell Decl. ¶ 23.) Judgment Creditors have attempted to meet and confer with judgment
debtor/plaintiff, but have been unable to obtain compliance with the Court's discovery order.

Judgment Creditors now move to compel judgment debtor/plaintiff to serve further verified responses,
without objections, to Judgment Debtor Interrogatories and Judgment Debtor Requests for Production of
Documents. Judgment Creditors contend they have not received any verified responses from judgment
debtor/plaintiff and the unverified responses they have received are not code-compliant because they
contain an objection and refusal to provide the information, even though judgment debtor/plaintiff has
waived objections by not timely responding. Judgment Creditors contend the information sought is
relevant to enforce their judgment.
Judgment debtor/plaintiff has submitted points and authorities in opposition to the motion, but these do
not address the relevant issues in this motion, and consists almost entirely of matters irrelevant to the
discovery at issue.
Judgment debtor/plaintiff is again ordered to serve further verified responses to the Judgment
Debtor Interrogatories and Judgment Debtor Requests for Production, without objections, on or
before July 29, 2019.
The Court cautions judgment debtor/plaintiff that compliance with a facially valid court order is
mandatory. (See, e.g., In re Brambini (1923) 192 Cal. 19, 28-32; see also In re Berry (1968) 68
Cal.2d 137, 147.)
Judgment debtor/plaintiff is also ordered to pay reasonable monetary sanctions to moving parties in the
amount of $1,300 (5 hrs at the hourly rate of $260), plus the $60 filing fee, for a total fee award of
$1,360. This opposition was filed without substantial justification and therefore, moving parties are
entitled to monetary sanctions. The monetary sanctions must be paid on or before August 19, 2019. If
those sanctions are not paid by that date, moving parties may prepare a formal order on the two
sanctions awards which may thereafter be entered as a separate judgment. (See Newland v Superior
Court (1995) 40 Cal.App.4th 608.)
by Judgment Creditors, not The Regents of the University of California ("Regents"). Moving parties have
already obtained a judgment of dismissal in this case as well as an attorneys' fees award on the
anti-SLAPP motion. Thus, it is unclear why they are seeking a "terminating sanction" in this context.
a terminating sanction as to Regents.
Conclusion
As stated above, judgment debtor/plaintiff is again ordered to serve verified responses to the
Judgment Debtor Interrogatories and Judgment Debtor Requests for Production, without
objections, on or before July 29, 2019. Monetary sanctions are to be paid as specified above.
notice is required.
COURT RULING

The Court vacated $60 filing fee from the tentative ruling as listed below:
Judgment debtor/plaintiff is ordered to pay reasonable monetary sanctions to moving parties in the
amount of $1,300 (5 hrs at the hourly rate of $260), for a total fee award of $1,300.

EXHIBIT # 25
·1· · · ·IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
·2· · · · · · · · ·FOR THE COUNTY OF SACRAMENTO
·3· · · · · · HON. DAVID BROWN, JUDGE, DEPARTMENT 53
·4· · · · · · · · · · · · · --oOo--
·5· JAROSLAW WASZCZUK,· · · · · · · · · )

· · · · · · · · · · · · · · · · · · · · )
·6· · · · · · · · · · · · · ·Plaintiff, )
· · · · · ·vs.· · · · · · · · · · · · · )· Number
·7· · · · · · · · · · · · · · · · · · · )2013-00155479
· · THE REGENTS OF THE UNIVERSITY OF CA,)
·8· · · · · · · · · · · · · · · · · · · )
· · · · · · · · · · · · · · · ·Defendant)
·9· · · · · · · · · · · · · · · · · · · )
· · · · · · · · · · · · · · · · · · · · )
10· · · · · · · · · · · · · · · · · · · )
· · · · · · · · · · · · · · · · · · · · )
11· · · · · · · · · · · · · · · · · · · )
· · · · · · · · · · · · · · · · · · · · )
12
· · · · · · · · · · · · · · ·--oOo--
13
· · · · · · · ·REPORTERS' TRANSCRIPT OF PROCEEDINGS
14
· · · · · · · · · · · · · · --oOo--
15
· · · · · · · · · · · · ·JULY 19, 2019
16
· · · · · · · · · · · · · · --oOo--
17
· · · · · · · · · · · · · APPEARANCES:
18
· · · · · · ·For the Plaintiff:
19
· · · · · · · JAROSLAW WASZCZUK, In Pro Per
20
21· · · · · · For the Defendant:
22· · · · · · DANIEL BARDZELL, Attorney at Law
23
24
25
26· · · · · · · · · · · · · ·--oOo--
27
28· · · · · · · · LAURI GALLAGHER, CSR No. 8726

·1· · · · · · · · · · · JULY 19, 2019

·2· · · · · · · · · · · · · --oOo--
·3· · · · · ·THE COURT:· The matter of the Waszczuk vs. The
·4· ·Regents, Defendant, Case Number 2013-00155479, came on
·5· ·regularly this day before Honorable DAVID BROWN, Judge
·6· ·of the Superior Court of the State of California, for
·7· ·the County of Sacramento, Department 53.
·8· · · · · ·The following proceedings were then had:
·9· · · · · ·THE COURT:· Item No. 1.
10· · · · · ·MR. BARDZELL:· Daniel Bardzell from Porter
11· ·Scott, Defendants.
12· · · · · ·THE COURT:· A couple questions I have for you
13· ·first, Mr. Bardzell.· There's a 60 dollar filing fee.
14· ·Does that apply?· In other, words did you pay it?
15· · · · · ·MR. BARDZELL:· No, the Regents are exempt --
16· · · · · ·THE COURT:· This isn't the Regents.· The
17· ·motion is made as I understand on behalf of --· oh, it
18· ·is the Regents.
19· · · · · ·MR. BARDZELL:· The motion is made on behalf of
20· ·the anti-SLAPP defendants.
21· · · · · ·THE COURT:· The individuals?
23· · · · · ·THE COURT:· That's what I asked.· It says you
24· ·are counsel for the Regents.· You don't say anybody
25· ·else.
26· · · · · ·MR. BARDZELL:· I'm sorry.· The motion papers?
27· · · · · ·THE COURT:· Well, on your papers, it says you
28· ·are counsel for the Regents.· This motion is made on

·1· ·behalf of the individuals, I understand.· It is Boyd,

·2· ·Chilcott, Nichols, Oropeza and Seifert's motion to
·3· ·compel responses.· Right?
·4· · · · · ·MR. BARDZELL:· That's correct.
·5· · · · · ·THE COURT:· But you didn't caption it that
·6· ·way.· This is a post judgment request for discovery?
·7· · · · · ·MR. BARDZELL:· Correct.· That's an improper
·8· ·caption.
·9· · · · · ·THE COURT:· Does the Court allow you a 60
10· ·dollar filing fee, or did your individual defendants
11· ·pay that?
12· · · · · ·MR. BARDZELL:· My understanding is they did
13· ·not pay the filing fee.
14· · · · · ·THE COURT:· Then the Court should vacate that
15· ·piece of the sanction; correct?
16· · · · · ·MR. BARDZELL:· We would not be opposed to
17· ·vacating the filing fee.
18· · · · · ·THE COURT:· The Court will do that right now.
19· · · · · ·I have another question for you while we're
20· ·sitting here talking about this.· I looked at the
21· ·responses Mr. Waszczuk provided, which were part of
22· ·your papers, Mr. Bardzell.· It was attached, I believe,
23· ·to your declaration as exhibits -- answers to --
24· · · · · ·MR. BARDZELL:· Exhibit L.
25· · · · · ·THE COURT:· The only thing I didn't see, I
26· ·didn't see any objections at all.· All I saw was no
27· ·signature.
28· · · · · ·Is the argument that there's no verification?

·1· · · · · ·MR. BARDZELL:· That's part of the argument, Your

·2· ·Honor.· I will direct you to an example of an
·3· ·objection.
·4· · · · · ·If you look at page 6 of the response to
·5· ·Judgment Debtor Request for Production of Documents.
·6· · · · · ·THE COURT:· Page 6.· Give me a moment.
·7· · · · · ·I'm starting with you because I want to make
·8· ·sure Mr. Waszczuk understands why we're doing what
·9· ·we're doing.
10· · · · · ·MR. BARDZELL:· Request for production number
11· ·21, the answer --
12· · · · · ·THE COURT:· It's protected by privileged work
13· ·product, right of privacy?
15· · · · · ·THE COURT:· And the Court had previously
16· ·ordered that the motions be granted with no objections;
17· ·correct?
18· · · · · ·MR. BARDZELL:· I don't have the ruling in
19· ·front of me.· I believe it was without objections.
20· · · · · ·THE COURT:· So if there are no objections, Mr.
21· ·Waszczuk should file amended responses without
22· ·objections.· No problem with that.
23· · · · · ·Did he provide verification because all of these
24· ·responses that I see here in Exhibit L that you
25· ·provided me include, "I declare under penalty of
26· ·perjury under the laws of the State of California that
27· ·the foregoing was true and correct."· That's an
28· ·appropriate jurat under 2015.5.· But he didn't sign it.

·1· ·Do you have a signed copy, sir?

·2· · · · · ·MR. BARDZELL:· No, I do not.
·3· · · · · ·THE COURT:· That's one of the problems that we
·4· ·have here; correct?
·5· · · · · ·MR. BARDZELL:· Correct.· He signed the
·6· ·declaration of service, but he did not sign the
·7· ·verification.
·8· · · · · ·THE COURT:· Thank you.· You have answered all
·9· ·of my questions, Mr. Bardzell.
10· · · · · · Mr. Waszczuk?
11· · · · · ·MR. WASZCZUK:· Your Honor, what I see in here,
12· ·because I don't know exactly what defendants knows.· If
13· ·Your Honor look the register of action in this
14· ·proceeding --
15· · · · · ·THE COURT:· I did.
16· · · · · ·MR. WASZCZUK:· Then since October 3rd, they
17· ·filing the motion for termination sanction.
18· · · · · ·THE COURT:· I denied that motion for
19· ·terminating sanctions.
20· · · · · ·MR. WASZCZUK:· I understand that, but Your
21· ·Honor, this is about money, not termination.
22· · · · · ·THE COURT:· If you don't do what you are
23· ·supposed to do, there may be a penalty.
24· · · · · ·MR. WASZCZUK:· I understood.
25· · · · · · THE COURT:· This is post judgment discovery,
26· ·Mr. Bardzell.· What are you terminating?· There's
27· ·already a judgment against Mr. Waszczuk.
28· · · · · ·MR. BARDZELL:· The motion is filed on behalf

·1· ·of the anti-SLAPP defendants, but we're okay with the
·2· ·tentative ruling at this point.
·3· · · · · ·THE COURT:· So he is okay with it,
·4· ·Mr. Waszczuk, but you have to provide him answers
·5· ·without objections and sign them under penalty of
·6· ·perjury.
·7· · · · · ·MR. WASZCZUK:· I need to know what they want.
·8· · · · · ·THE COURT:· You answered them.· You didn't do
·9· ·a bad job.· I read all your answers.· Most of them were
10· ·pretty good.· I would have been happy with them if I
11· ·were Mr. Bardzell, but you didn't sign them, and there
12· ·were a couple objections that were pointed out to me.
13· · · · · ·MR. WASZCZUK:· I gave Mr. Bardzell everything
14· ·on February 8th.
15· · · · · ·THE COURT:· Did you sign the answers, Mr.
16· ·Waszczuk?
17· · · · · ·MR. WASZCZUK:· Your Honor, we were in court --
18· · · · · ·THE COURT:· I don't care whether you were in
19· ·court.· Did you sign the answers?
20· · · · · ·MR. WASZCZUK:· I believe so.
21· · · · · ·THE COURT:· Do you have Exhibit L?· Do you
22· ·have a copy of his motion in front of you?· It's
23· ·Exhibit L.· It should have a little tab at the bottom.
24· · · · · ·Please show him, Mr. Bardzell.
25· · · · · ·All right.· Exhibit L.· Go to the very end of
26· ·your response to the production of documents.· Go to
27· ·page 7.
28· · · · · ·Do you see where it says submitted on

·1· ·4-12-2019?· Page 7, line 26.· Do you need assistance?

·2· · · · · ·MR. WASZCZUK:· Yes.
·3· · · · · ·THE COURT:· Please assist him.· Go to page 7
·4· ·of your responses to the request for production of
·5· ·documents.
·6· · · · · ·Do you see a signature there at all?
·7· · · · · ·MR. WASZCZUK:· No.
·8· · · · · ·THE COURT:· He needs your signature.· Do you
·9· ·see the next one right underneath it, and if you go to
10· ·the end of that one too, guess what?· No signature.
11· ·That's page 8.
12· · · · · ·MR. WASZCZUK:· Your Honor, I don't believe
13· ·what they are talking about.
14· · · · · ·THE COURT:· I can't say they are wrong when I
15· ·look at the documents they give me, and I don't see a
16· ·signature.· All you have to do is sign it.· All I want
17· ·you to do is sign it.
18· · · · · ·MR. WASZCZUK:· I can sign now.
19· · · · · ·THE COURT:· I recognize that, but I think it
20· ·would be more appropriate if you would answer it
21· ·without any objections at all.
22· · · · · ·You have to admit, Mr. Bardzell, most of these
23· ·substantive answers, "I don't own any real property."
24· ·"I don't have any jewelry."· "I don't know have any
25· ·bank accounts with X dollars in it."· "I don't own
26· ·stocks or bonds."
27· ·You said all of that, but you didn't sign it under
28· ·penalty of perjury because you didn't sign it.

·1· · · · · ·Once you sign it, that's what he needs.· These

·2· ·are civil procedures enacted by the legislature that
·3· ·you have to comply with.· At this point all have you to
·4· ·do is sign it and answer the ones that you objected to.
·5· · · · · ·MR. BARDZELL:· I would point out that the
·6· ·major concern that we have with his responses, the ones
·7· ·that refer to the assets of his spouse, contained
·8· ·outright refusals to respond.
·9· · · · · ·THE COURT:· He's going to have to do that.
10· · · · · ·Unfortunately, you are going to have to make a
11· ·good faith inquiry or say you don't know.· If you say
12· ·you don't know, I may have a right to inquire as to why
13· ·you don't know.
14· · · · · ·Under California law, your spouse's assets maybe
15· ·liable for some piece of your judgment.· Just saying, I
16· ·think they have a right ask.· You can't object to it if
17· ·you think it's bad.
18· · · · · ·MR. WASZCZUK:· I explain on February 8th to
19· ·Mr. Bardzell, he wrote production of documents. I
20· ·answered all of his questions in the court, and here is
21· ·the court order saying the examination was complete and
22· ·the parties were released.· And I asked Mr. Bardzell,
23· ·do you have any complaints, can you go to judge with
24· ·complaints, and he said no.
25· · · · · ·THE COURT:· That is the O.X.?
26· · · · · ·MR. BARDZELL:· Yes, the examination.
27· · · · · ·THE COURT:· That has nothing to do with these
28· ·responses.

·1· · · · · ·MR. WASZCZUK:· He wrote the production of

·2· ·documents, and I answered question by question to him,
·3· ·and he is repeating this.
·4· · · · · ·THE COURT:· He has a right to ask different
·5· ·things in different way.
·6· · · · · ·MR. WASZCZUK:· Why he repeating the same?
·7· · · · · ·THE COURT:· Just so you know, people can use
·8· ·different methods of discovery to try to fare out the
·9· ·same stuff.· It's not always as graceful as you would
10· ·like, but it's permitted by the code.
11· · · · · ·MR. WASZCZUK:· The Department 53 judge is more
12· ·important than judge from Department 43.
13· · · · · ·THE COURT:· I will tell the Department 43
14· ·judge that.
15· · · · · ·MR. WASZCZUK:· And then another judge decide
16· ·and everything was concluded, and then another judge do
17· ·the same stuff.
18· · · · · ·THE COURT:· I don't know who the department 43
19· ·judge is.
20· · · · · ·MR. WASZCZUK:· Judge Blizzard.
21· · · · · ·THE COURT:· I will be sure to tell him.
22· · · · · ·MR. WASZCZUK:· I gave him all information you
23· ·wanted, and I ask him in front of my witness, he was
24· ·witness, this guy.
25· · · · · ·THE COURT:· That was an order of examination.
26· ·All right.· Give me a moment.
27· · · · · ·MR. BARDZELL:· Nothing further, Your Honor.
28· · · · · ·THE COURT:· Mr. Waszczuk, you know what you

July 19, 2019 Page 10
·1· ·need to do?

·2· · · · · ·MR. WASZCZUK:· I don't know what I need to do.
·3· ·This is the problem.
·4· · · · · ·THE COURT:· You are going to have to respond
·5· ·again to these discoveries.· One is the
·6· ·interrogatories, the other is the request for
·7· ·production.· You can file the same answers, but you
·8· ·can't object or refuse to answer.
·9· · · · · ·Most of your answers are pretty good, and you
10· ·are going to have to sign it under penalty of perjury,
11· ·which you didn't do the first time.
12· · · · · ·MR. WASZCZUK:· Maybe I omitted that, Your
13· ·Honor.· Mr. Bardzell should just say, "Hey, can you
14· ·sign this?"
15· · · · · ·THE COURT:· There's a couple other things he
16· ·wants.
17· · · · · ·Make sure you sign it at least, and then he will
18· ·be back here telling me about the things you still
19· ·objected to, but I'm telling you now that the order
20· ·that I'm providing to you tells you not to object and
21· ·not to refuse to answer the few things that you refuse
22· ·to answer.
23· · · · · ·MR. WASZCZUK:· This is about to pay them legal
24· ·fees, not about discovery.· They never asked to pay --
25· ·when I sent my letter to the previous lawyer, they are
26· ·beneficiary of those legal fees awarded them.· They
27· ·don't want to do anything with those legal fees, Your
28· ·Honor.

July 19, 2019 Page 11
·1· · · · · ·The Court want to know why?· I know why.

·2· · · · · ·THE COURT:· Sure, tell me.
·3· · · · · ·MR. WASZCZUK:· My lawyer saying prior to
·4· ·Thanksgiving, I offered him $20,000 to get help with
·5· ·the case.· Then they file the SLAPP motion -- they
·6· ·crafted the SLAPP motion during Thanksgiving, and day
·7· ·after on December 2, my lawyer pull out all money from
·8· ·my accounts, from retainer accounts, everything.· They
·9· ·cleaned the accounts and because, you know, they knew
10· ·that I will not be coming back.· I was placed on the
11· ·"no fly" list.· This is what it's about, Your Honor.
12· · · · · ·THE COURT:· The Court will affirm the
13· ·tentative ruling.· Do what you need to do, Mr.
14· ·Waszczuk.
15· · · · · ·MR. WASZCZUK:· I appreciate, Your Honor, if
16· ·you cancel those sanctions.
17· · · · · ·THE COURT:· I cancelled $60.00 of them.
18· · · · · ·MR. WASZCZUK:· I'm on social security, Your
19· ·Honor.
20· · · · · ·THE COURT:· I'm not saying they can collect
21· ·them.· I'm saying that they are entitled to them
22· ·procedurally.
23· · · · · ·MR. WASZCZUK:· I don't want to file a motion
24· ·for reconsideration and go to Court of Appeal.
25· · · · · ·THE COURT:· I understand.· Thank you.
26· · · · · ·MR. WASZCZUK:· The Court harasses my old lady.
27· ·This is what it is.
28· · · · · ·(End of Proceedings.)

July 19, 2019 Page 12
·1· · · · · ·CERTIFICATE OF OFFICIAL SHORTHAND REPORTER
·2· ·State of California· )

· · · · · · · · · · · · · )· ss.
·3· ·County of Sacramento )
·4· · · · · I, LAURI GALLAGHER, hereby certify that I am a
·6· ·verbatim in stenographic writing the proceedings had
·7· ·JULY 19, 2019, in the matter of the Waszczuk vs. The
·8· ·Regents, Case Number 2013-00155479, completely and
·9· ·correctly to the best of my ability; that I have caused
10· ·said stenographic notes to be transcribed into
11· ·typewriting, and the foregoing pages 1 through 11
12· ·constitute a complete and accurate transcript of said
13· ·stenographic notes taken at the above-mentioned
14· ·proceedings.
15· · · · · ·I further certify that I have complied with
16· ·CCP 237(a)(2) in that all personal juror identifying
17· ·information has been redacted, if applicable.
18· · · · · Dated:· October 8, 2019.
19
20
21
22· · · · · · · · · · · · · · ·LAURI GALLAGHER, CSR No. 8726
23
24· · · · · · · · · · · · · · ·--oOo--
25
26
27
28

July 19, 2019 ·Index: $20,000..faith
BROWN 2:5
$ 8 D
C
$20,000 11:4 8 7:11 Daniel 2:10
$60.00 11:17 8th 6:14 8:18 California 2:6 4:26 DAVID 2:5
8:14
day 2:5 11:6
- A cancel 11:16
Debtor 4:5
cancelled 11:17
--ooo-- 2:2 accounts 7:25 11:8,9 December 11:7
caption 3:5,8
action 5:13 decide 9:15
1 care 6:18
admit 7:22 declaration 3:23 5:6
case 2:4 11:5
1 2:9 affirm 11:12 declare 4:25
Chilcott 3:2
19 2:1 amended 4:21 Defendant 2:4
civil 8:2
answers 3:23 6:4,9,15, defendants 2:11,20
2 19 7:23 10:7,9 cleaned 11:9 3:10 5:12 6:1
anti-slapp 2:20 6:1 code 9:10 denied 5:18

2 11:7
Appeal 11:24 collect 11:20 department 2:7 9:11,
2013-00155479 2:4 12,13,18
apply 2:14 compel 3:3
2015.5 4:28 direct 4:2
argument 3:28 4:1 complaints 8:23,24
2019 2:1 discoveries 10:5
assets 8:7,14 complete 8:21
21 4:11 discovery 3:6 5:25 9:8
assist 7:3 comply 8:3
10:24
26 7:1
assistance 7:1 concern 8:6
documents 4:5 6:26
attached 3:22 concluded 9:16 7:5,15 8:19 9:2
3
awarded 10:26 contained 8:7 dollar 2:13 3:10
3rd 5:16 copy 5:1 6:22 dollars 7:25
B correct 2:22 3:4,7,15
4 4:14,17,27 5:4,5 E
back 10:18 11:10
counsel 2:24,28
4-12-2019 7:1 enacted 8:2
bad 6:9 8:17
County 2:7
43 9:12,13,18 end 6:25 7:10 11:28
bank 7:25
couple 2:12 6:12 10:15
Bardzell 2:10,13,15,19, entitled 11:21
5 court 2:3,6,9,12,16,21,
22,26 3:4,7,12,16,22,24 examination 8:21,26
4:1,10,14,18 5:2,5,9,26, 23,27 3:5,9,14,18,25
4:6,12,15,20 5:3,8,15, 9:25
53 2:7 9:11 28 6:11,13,24 7:22 8:5,
19,22,26 9:27 10:13 18,22,25 6:3,8,15,17, exempt 2:15
18,19,21 7:3,8,14,19
6 behalf 2:17,19 3:1 5:28 8:9,20,21,25,27 9:4,7, Exhibit 3:24 4:24 6:21,
13,18,21,25,28 10:4,15 23,25
beneficiary 10:26
6 4:4,6 11:1,2,12,17,20,24,25, exhibits 3:23
Blizzard 9:20 26
60 2:13 3:9 explain 8:18
bonds 7:26 crafted 11:6
7 bottom 6:23 F
Boyd 3:1
7 6:27 7:1,3 faith 8:11

July 19, 2019 ·Index: fare..reconsideration
fare 9:8 inquire 8:12 money 5:21 11:7 piece 3:15 8:15
February 6:14 8:18 inquiry 8:11 motion 2:17,19,26,28 point 6:2 8:3,5
3:2 5:17,18,28 6:22
fee 2:13 3:10,13,17 interrogatories 10:6 pointed 6:12
11:5,6,23
fees 10:24,26,27 Item 2:9 Porter 2:10
motions 4:16
file 4:21 10:7 11:5,23 post 3:6 5:25
J
filed 5:28 N pretty 6:10 10:9
filing 2:13 3:10,13,17 jewelry 7:24 previous 10:25
5:17 Nichols 3:2
job 6:9 previously 4:15
fly 11:11 number 2:4 4:10
judge 2:5 8:23 9:11,12, prior 11:3
foregoing 4:27 14,15,16,19,20
O privacy 4:13
front 4:19 6:22 9:23 judgment 3:6 4:5 5:25, privileged 4:12
27 8:15 O.X. 8:25
problem 4:22 10:3
G JULY 2:1 object 8:16 10:8,20
problems 5:3
jurat 4:28 objected 8:4 10:19
gave 6:13 9:22 procedurally 11:22
give 4:6 7:15 9:26 objection 4:3
K procedures 8:2
good 6:10 8:11 10:9 objections 3:26 4:16,
19,20,22 6:5,12 7:21 proceeding 5:14
graceful 9:9 knew 11:9
October 5:16 proceedings 2:8 11:28
granted 4:16 product 4:13
L offered 11:4
guess 7:10 production 4:5,10 6:26
omitted 10:12
guy 9:24 lady 11:26 7:4 8:19 9:1 10:7
opposed 3:16
law 8:14 property 7:23
H order 8:21 9:25 10:19
laws 4:26 protected 4:12
ordered 4:16
happy 6:10 lawyer 10:25 11:3,7 provide 4:23 6:4
Oropeza 3:2
harasses 11:26 legal 10:23,26,27 provided 3:21 4:25
outright 8:8
Hey 10:13 legislature 8:2 providing 10:20
Honor 4:2 5:11,13,21 letter 10:25 P pull 11:7

6:17 7:12 9:27 10:13,28 liable 8:15
11:11,15,19 papers 2:26,27 3:22 Q
list 11:11
Honorable 2:5 part 3:21 4:1
looked 3:20 question 3:19 9:2
parties 8:22
I questions 2:12 5:9
M pay 2:14 3:11,13 10:23, 8:20
24
important 9:12
made 2:17,19,28 penalty 4:25 5:23 6:5 R
improper 3:7
major 8:6 7:28 10:10
include 4:25 read 6:9
make 4:7 8:10 10:17 people 9:7
individual 3:10 real 7:23
matter 2:3 perjury 4:26 6:6 7:28
individuals 2:21 3:1 10:10 recognize 7:19
methods 9:8
information 9:22 permitted 9:10 reconsideration
moment 4:6 9:26
11:24

July 19, 2019 ·Index: refer..wrote
refer 8:7 starting 4:7
W
refusals 8:8 State 2:6 4:26
refuse 10:8,21 stocks 7:26 wanted 9:23
Regents 2:4,15,16,18, stuff 9:9,17 Waszczuk 2:3 3:21
24,28 4:8,21 5:10,11,16,20,
submitted 6:28
register 5:13 24,27 6:4,7,13,16,17,20
substantive 7:23 7:2,7,12,18 8:18 9:1,6,
regularly 2:5 11,15,20,22,28 10:2,12,
Superior 2:6
released 8:22 23 11:3,14,15,18,23,26
supposed 5:23
repeating 9:3,6 words 2:14
request 3:6 4:5,10 7:4 T work 4:12

10:6 wrong 7:14
respond 8:8 10:4 tab 6:23 wrote 8:19 9:1
response 4:4 6:26 talking 3:20 7:13
responses 3:3,21 telling 10:18,19

4:21,24 7:4 8:6,28 tells 10:20
retainer 11:8 tentative 6:2 11:13
ruling 4:18 6:2 11:13 terminating 5:19,26
termination 5:17,21
S
Thanksgiving 11:4,6
Sacramento 2:7 thing 3:25
sanction 3:15 5:17 things 9:5 10:15,18,21
sanctions 5:19 11:16 time 10:11
Scott 2:11 true 4:27
security 11:18
U
Seifert's 3:2
service 5:6 underneath 7:9
show 6:24 understand 2:17 3:1
sign 4:28 5:6 6:5,11,15, 5:20 11:25
19 7:16,17,18,27,28 understanding 3:12
8:1,4 10:10,14,17
understands 4:8
signature 3:27 7:6,8,
10,16 understood 5:24
signed 5:1,5
V
sir 5:1
sitting 3:20 vacate 3:14
SLAPP 11:5,6 vacating 3:17
social 11:18 verification 3:28 4:23
5:7
spouse 8:7
spouse's 8:14

EXHIBIT # 26
EXHIBIT # 27
EXHIBIT # 29
EXHIBIT # 33
Derek J. Haynes, SBN 264621
• 3 Aifianda L. Her, SBN 300268
Daniel J. Bardzell, SBN 313993
FILED/ENDORSED
Sacramento, Califomia 95825 DEC - 6 2019
5 TEL: 916.929.1481
By: E. IVIedina
FAX: 916.927.3706
6 ueputy Citm

8
9 Attorneys for Judgment Creditors/Former Defendants
MICHAEL BOYD, STEPHEN CHILCOTT, DANESHA NICHOLS, CINDY OROPEZA, and BRENT
10 SEIFERT
Exempt From.Filing Fees Pursuant to Government Code § 6103
11
13
14 JAROSLAW ("JERRY") WASZCZUK, CASENO. 34-2013-00155479
15 Plaintiff, REPLY TO UNTIMELY OPPOSITION TO

MOTION TO COMPEL RESPONSES TO
16 JUDGMENT DEBTOR
17 INTERROGATORIES AND REQUEST
THE REGENTS OF THE UNIVERSITY OF FOR PRODUCTION OF DOCUMENTS;
18 CALIFORNIA, et al., AND FOR MONETARY SANCTIONS
19 Defendants. Date: December 13, 2019
20 Time: 2:00 p.m.
Dept.: 53
21
Corhplaint Filed: December 4, ,2013
24
25
26
27
28
{02II7245.DOCX}
1 I.
2 INTRODUCTION
3 Judgment Creditors/Defendants have now filed three Motions to Compel Judgment
4 Debtor/Plaintiff JAROSLAW ("JERRY") WASZCZUK to provide compliant responses to Judgment
5 Debtor Interrogatories and Judgment Debtor Request for Production of Documents. All such Motions
6 have been granted, yet Judgment Debtor/Plaintiff still refuses to provide those responses. His most-
7 recent responses are identical to those this Court found deficient in ruling on the prior Motion.
8 That forced Judgment Creditors/Defendants to file the instant Motion to Compel and Request for
9 Monetary Sanctions. Judgment Debtor/Plaintiff failed to file a timely Opposition to the Motion. As a
10 result. Judgment Creditors/Defendants filed a notice of non-opposition. Thereafter, Judgment
11 Debtor/Plaintiff filed an untimely Opposition. Judgment Creditors/Defendants submit the Court should
12 disregard that Opposition as untimely. However, even i f the Court considers the Opposition, Plaintiff
13 concedes in that document that he has "no arguments" other than those the Court already rejected in
14 granting the prior Motions to Cornpel.
15 Judgment Debtor/Plaintiffs current Opposition is instead replete with incoherent and nonsensical
16 assertions that counsel for Judgment Creditors is engaging in extortion. Although unclear, it appears
17 Judgment Debtor/Plaintiffs assertions focus on an underlying Order from this Court where the Court
18 awarded Defendants the attorney's fees they incurred in successfully pursuing an Anti-SLAPP Motion.
19 Judgment Debtor/Plaintiff argues that three other lawyers from defense counsel's firm worked on that
20 motion, not the current lawyers. Judgment Debtor's email correspondence attached as Exhibit 5 to his
21 Opposition also claims that any fees that are paid must be paid to the individual Defendants who
22 prevailed on the Anti-SLAPP Motion and not to Defendant REGENTS OF THE UNIVERSITY OF
•23 CALIFORNIA (herein "REGENTS"), who paid for those fees.
24 Those arguments, however, are entirely irrelevant to the pending Motion, which merely argues
25 that Judgment Debtor/Plaintiff failed to provide adequate responses to discovery requests. Judgment
26 Debtor/Plaintiff does not dispute that issue, nor can he given the responses are identical to the ones the
27 Court previously found deficient.
28 For these reasons and the reasons set forth in Judgment Creditors' moving papers, Judgment
{02117245 DOCX) 2
1 Creditors' Motion should be granted. Judgment Creditors also respectfully request that the Court award
' 2 sanctions for Judgment Debtor's repeated abuse of the discovery process and disregard of previous court
3 orders. In addition. Judgment Creditors respectfully request the Court clarify that the REGENTS is
4 entitled to the payment of sanction awards as the REGENTS is incurring the costs associated with the
5 litigation against Judgment Debtor.
6 II.
7 JUDGMENT DEBTOR'S OPPOSITION SHOULD BE DISREGARDED BECAUSE IT WAS
8 UNTIMELY
9 Judgment Debtor's Opposition to the instant Motion was due on December 2, 2019. (Declaration of
10 Amanda L. Her [herein "Her Decl."], ^ 2.) On December 4, 2019, after no Opposition had been served or
11 even filed, Judgment Creditors filed a Reply to Plaintiffs Non-Opposition to Defendaiit's Motion to
12 Compel Responses to Judgment Debtor Interrogatories and Request for Production of Documents; and
13 for Monetary Sanctions. (Her Decl., ^ 3; Exhibit A, Reply to Plaintiffs Non-Opposition) Shortly
14 thereafter, counsel for Judgment Creditors received notification that Judgment Debtor filed an
15 Opposition. Counsel for Judgment Debtor then downloaded the relevant documents from the Court's
16 website. (Her Deck, ^ 4.) The proof of service indicated Judgment Debtor served the Opposition by mail,
17 even further delaying Judgment Creditors' receipt of Judgment Debtor's already untimely response. (Her
18 Deck, t 5.)
19 In his Opposition, Judgment Debtor completely fails to acknowledge that he failed to file a
20 timely Opposition under Code of Civil Procedure section 1005(b). He does not offer any excuse, reason,
21 or authority for his actions. As such, the Judgment Creditors respectfully request that the Court exercise
22 its authority under Califomia Rules of Court, Rule 3.1300, refuse to consider Judgment Debtor's
23 untimely Opposition, and preclude Judgment Debtor from making any oral argument. (Bozzi v.
24 Nordstrom, Inc. (2010) 186 Cal.App.4th 755, 765 [the Court properly refiased to consider plaintiffs
25 untimely papers where plaintiff did not invoke any of the available procedures to obtain a court order
26 permitting late filing].)
27 Ill
28 III
{021I7245.DOCX} 3
1 III.
2 JUDGMENT CREDITORS' MOTION SHOULD BE GRANTED BECAUSE JUDGMENT
3 DEBTOR DID NOT HAVE SUBSTANTIAL JUSTIFICATION FOR OPPOSING IT
4 Judgment Debtor offers no legal basis in his Opposition for his failure to, once again, provide
5 compliant discovery responses in a timely manner. In fact, he outright admits that he "has no fiirther
6 argument" beyond those arguments that the Court rejected in granting Judgment Creditors' earlier
7 Motions.
8 Rather than responding to the arguments Judgment Creditors set forth supporting their contention
9 that Judgment Debtor should be compelled to provide further discovery responses and that the Court
10 should award sanctions, Judgment Debtor instead makes conspiracy theory-type arguments about
11 counsel for Judgment Creditors extorting money from him.
12 As set forth in Judgment Creditors' moving papers, this is the third Motion Judgment Creditors
13 have been forced to file in attempting to collect the judgments owed in this case. This Court has now
14 ordered Judgment Debtor multiple times to serve fiarther verified responses to the Judgment Debtor
15 Interrogatories and Judgment Debtor Requests for Production without objection. {See Declaration of
16 Daniel Bardzell in Support of Further Motion to Compel [herein "Bardzell Decl."] 15, 21 and
17 Exhibits K and O attached thereto) He has not done so, choosing instead to serve verified versions of the
18 identical responses this Court previously deemed insufficient. Even more egregious is the fact that
19 Judgment Debtor acknowledged in an email that he does have responsive documents, but refused to
20 provide them except for in a face-to-face meeting.' (Bardzell Deck, t 28 and Exhibit V) Judgment
21 Creditors are not required to acquiesce to such a request. When counsel for Judgment Creditors
22 communicated as much to Judgment Debtor, he responded by urging Judgment Creditors to file the
23 instant motion—conduct that continues to violate this Court's orders. (Bardzell Decl. \ 30 and
24 Exhibit X)
25 Judgment Debtor should be sanctioned for opposing this Motion without substantial justification.
26 (Code of Civil Procedure sections 2030.290(c) [interrogatories] & 2031.300(c) [production requests].)
27
28 ' Ttiis is just another effort in Plaintiffs long-line of efforts to intimidate and threaten defense counsel, the same type of
conduct that resulted in his termination from the University.
{02117245 DOCX) ; 4
1 He has offered no legal basis for his failure to timely respond, or even for his failure to respond to the
2 numerous meet and confer attempts that Judgment Creditors have engaged in, as detailed in the moving
3 papers. Judgment Debtor's brazen defiance of multiple Court orders to serve fijrther discovery responses
4 is an unquestionable misuse of the discovery process for which monetary sanctions should be awarded.
5 (Code Civ. Proc. §§ 2023.010(g); 2023.030 (a).) Judgment Creditors request an award of $5,460.00 as
6 set forth in the moving papers.
7 IV.
8 DEFENDANT REGENTS IS ENTITLED TO PAYMENT OF SANCTIONS AWARDS
9 Judgment Debtor indicates in his Opposition and supporting exhibits that the REGENTS and
10 defense counsel are not entitled to the sanctions and fees awarded to date. (Opposition to Motion to
11 Compel Filed on October 23, 2019, pp. 4-5) In a November 21, 2019 email correspondence to counsel
12 for the REGENTS and Judgment Creditors, Judgment Debtor wrote, "As I advised you a few days ago,
13 the UC Regents should not cash the $1,300 check I sent to your office on November 18, 2019. The UC
14 Regents are not the party of the anti-SLAPP motion filed by Porter Scott's fomier attomey Michael Pott
15 on December 1, 2014." (Opposition, Exhibit 5.) Judgment Debtor goes on to offer to write individual
16 checks in the amount of $260.00 to each Judgment Creditor and insinuates he either has or will file a
17 complaint with the State Bar related to this issue.
18 Judgment Debtor has cited no legal authority for his position that the REGENTS are not entitled
19 to the sanction payment. The REGENTS has paid for the defense ofthe Judgment Creditors. (Her Decl. ^
20 6.) "A monetary sanction may be based not only on attomey's fees and costs, but also on any other
21 reasonable expenses incurred.'" {Argaman v, Ratan (1999) 73 Cal.App.4''^ 1173, 1179 [emphasis added].)
22 As the REGENTS has incurred the expense of the Special Motion to Strike and subsequent discovery
23 proceedings associated with collecting the judgment, the REGENTS is the proper recipient of the
24 sanction payments. Judgment Creditors respectfully request the Court clarify for Judgment Debtor that
25 the REGENTS is entitled to the payment of sanction awards so that Judgment Debtor does not continue
26 to use that as an excuse for not paying the amounts owed.
27
111 •
28
III
(02117245 DOCX) . ^5 ^
1 V. .
2 CONCLUSION
3 Based on the foregoing, Judgment Creditors respectfully submit that their Motion to Compel
4 Responses to Judgment Debtor Interrogatories and Requests for Production of Documents; and for
5 Monetary Sanctions should be granted.
6
7 Dated: December 6, 2019 PORTER SCOTT
A PRCIFESSIONA TION
8
9
10 )erek J. Haynes
Âmanda L. Her
Attomeys for Judgment Creditors/Former
12
Defendants
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
{02117245.DOCX}
1
2
3 PROOF OF SERVICE
.5
6 On the date below, I served the following document: REPLY TO UNTIMELY OPPOSITION
TO MOTION TO COMPEL RESPONSES TO JUDGMENT DEBTOR INTERROGATORIES
7 AND REQUEST FOR PRODUCTION OF DOCUMENTS; AND FOR MONETARY
SANCTIONS
8
9
attomey being served, with a receptionist or an individual in charge of the office, between the hours of nine
13 in the moming and five in the evening. (2) For a party, delivery was made to the party or by leaving the
documents at the party's residence with some person not younger than 18 years of age between the hours
14 of eight in the moming and six in the evening.
BY OVERNIGHT DELIVERY: I enclosed the documents in an envelope or package provided by an
15 ovemight delivery carrier and addressed to the person(s) listed below. I placed the envelope or package for
collection and ovemight delivery at my office or a regularly utilized drop box of the ovemight delivery
16 carrier.
18 BY ELECTRONIC SERVICE: Based on a court order or an agreement of the parties to accept service by
electronic transmission, I caused the documents to be sent to the persons at the electronic notification
20 JAROSLAW WASZCZUK
21 2216 KATZAKIAN WAY
LODI, CA 95242
22
23 I declare under penalty of perjury under the laws of the State of California that the foregoing is
true and correct. Executed at Sacramento, California on December 6, 2019.
24
25
Cindy A<3bndinetti
26
27
28
(02117245.DOCX)
EXHIBIT # 34
MINUTE ORDER
DATE: 12/13/2019 TIME: 02:00:00 PM DEPT: 53
CLERK: E. Brown
REPORTER/ERM:

APPEARANCES
TENTATIVE RULING
of $22,284. (See ROA 219.)


without objection.
Conclusion
(1968) 68 Cal.2d 137, 147.)
608.)
notice is required.
COURT RULING

EXHIBIT # 35
MINUTE ORDER
DATE: 12/17/2019 TIME: 02:00:00 PM DEPT: 53
CLERK: E. Brown
REPORTER/ERM:

APPEARANCES

TENTATIVE RULING
of $22,284. (See ROA 219.)


without objection.
Conclusion
(1968) 68 Cal.2d 137, 147.)
608.)
notice is required.
COURT RULING
JAROSLAW WASZCZUK
2216 KATZAKIAN WAY
LODI, CA 95242
DANIEL J. BARDZELL
PORTER SCOTT

EXHIBIT # 36
EXHIBIT # 37
FILED/ENDORSED
TEL: 916.929.1481 By: -E. Medina
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{0241.1952.DOCX} 2
9 III.
10 CONCLUSION
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18 By.
Lindsay A. Goulding
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{02413952.DOCX}
1
2
3 PROOF OF SERVICE
5

8 EXCEEDS 20 PAGES
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{0241.1952.DOCX}
L:: U„ r;:^J
o
1
2
TEL: 916.929.1481
5 FAX: 916.927.3706
6

9
10
11 JAROSLAW (“JERRY”) WASZCZUK, CASE NO. 34-2013-00155479
12
Plaintiff, DECLARATION OF LINDSAY A.
PORTER | SCOTT
FAX: 916.927.3706
TEL: 916.929.1481
v. DEFENDANT’S EXPARTE FOR LEAVE

14 TO FILE MOTION FOR SUMMARY
15 THE REGENTS OF THE UNIVERSITY OF JUDGMENT THAT EXCEEDS 20 PAGES
CALIFORNIA, UNIVERSITY OF
WITCHER, DANESHA NICHOLS, CINDY Amended Complaint Filed: June 16, 2014
20
21
Defendants.
22 _____________________________________/
25 and am a partner with the law firm of Porter Scott, attorneys of record for Defendant REGENTS OF
26 THE UNIVERSITY OF CALIFORNIA (“Defendant” or “UNIVERSITY”). I state the facts herein
27 of my own personal knowledge and, if called upon as a witness, I could and would competently
28 testify thereto.
{02413956.DOCX} 1
8 adjudication as to the following causes of action: 3) harassment in violation of FEHA and failure to
13 necessarily require a detailed discussion of the nature of Plaintiff’s employment relationship with
PORTER | SCOTT
FAX: 916.927.3706
TEL: 916.929.1481
14 Defendant, the alleged harassment of Plaintiff from 2006 to 2013, as well as the individual defenses
15 applicable thereto. The circumstances surrounding the allegedly harassing conduct will also require
16 a detailed discussion as to the nature of the conduct, the timing, and the speakers and recipients of
17 the alleged harassment. Further, a lengthy legal analysis will be required to address Plaintiff’s
20 each of Plaintiff’s causes of action, Defendants’ Memorandum of Points and Authorities in support
22 5. I contacted Plaintiff to inform him of this Application via telephone and email on
24 of my email correspondence to Plaintiff regarding Defendant’s request to exceed the page limit.
27 L
28
Lindsay A. Goulding
{02413956.DOCX} 2
EXHIBIT
“A”
01054547.WPD
From: Virginia Yao
To: JJW1980@LIVE.COM
Cc: Lindsay A. Goulding; Tomi Aina
Date: Monday, April 26, 2021 8:59:00 AM
Attachments: image001.png
Dear Mr. Waszczuk:
This is just to confirm our conversation this morning that our office is filing an Exparte
today on the papers to request a page extension to the Motion for Summary of
Judgment that we will be filing. Thank you.
Virginia Yao
Legal Assistant to Lindsay A. Goulding
350 University Avenue | Suite 200 | Sacramento, CA 95825
T| 916.929.1481 x 331 F| 916.927.3706
www.porterscott.com
Waszczuk v. Regents of the University of California, et al.
1
2
PROOF OF SERVICE
3
5
7 DECLARATION OF LINDSAY A. GOULDING IN SUPPORT OF

DEFENDANT’S EXPARTE FOR LEAVE TO FILE
8 MOTION FOR SUMMARY JUDGMENT THAT EXCEEDS 20 PAGES
9
10 am readily familiar with this business’ practice for collecting and processing correspondence for mailing.
12 below. (1) For a party represented by an attorney, delivery was made to the attorney or at the attorney’s
office by leaving the documents, in an envelope or package clearly labeled to identify the attorney being
13 served, with a receptionist or an individual in charge of the office, between the hours of nine in the morning
PORTER | SCOTT
FAX: 916.927.3706
TEL: 916.929.1481
14 party’s residence with some person not younger than 18 years of age between the hours of eight in the
morning and six in the evening.
overnight delivery carrier and addressed to the person(s) listed below. I placed the envelope or package for
16 collection and overnight delivery at my office or a regularly utilized drop box of the overnight delivery
carrier.
listed below.
20
2216 Katzakian Way
22 Lodi, CA 95242
JJW1980@LIVE.COM
23
is true and correct. Executed at Sacramento, California on April 26, 2021.
25
26 v
27 ___________________________________
Virginia Yao
28
{02413956.DOCX} 3
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Defendants.
22
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{024^4532.DOCX} 1

Dated:
APR 2 7 2021
SHAMA H. MESIWALA
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{02414532.DOCX}

EXHIBIT # 38
2216 Katzakian Way
Lodi, CA 95242
Phone: 209-663-2977
Fax: 209-787-3131
April 27, 2021


Oakland, CA 94607
Subject: Case No. 34-2013-00155479, Jaroslaw Waszczuk v. The Regents of the

University of California, Ann Madden Rice, Mike Boyd, Stephen Chilcott,
Charles Witcher, Danesha Nichols, Cindy Oropeza, Brent Seifert, Patrick
Putney, Dorin Daniliuc
Re: Defendants Ex Parte Application for Leave to Extend Page Limit for Defendant's
Motion For Summary Judgment or, in The Alternative, Summary
Adjudication
Dear Ms. Goulding,
Yesterday, I asked you in which Court Department you filed your Ex Parte
Application for Leave to Extend Page Limit because you did not mark on the front
page of your pleadings which Court Department or which Judge would would
-1-
unprofessional.
predecessors in this case, two former Porter Scott attorneys, David Burkett and
against the Regents of the University of California, bypassed Judge David Brown
Krueger or a stamped Order with Judge Krueger’s name.
the Burkett and Bardzell’s Notice of Motion and Motion (ATTACHMENT #1) of
Documents were filed/endorsed by the same Deputy Clerk named E. Medina.
It seems to me that history is repeating itself and that Porter Scott’s new team of
-2-
YOUR MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT

In general, as a Plaintiff, I have no problem with the Ex Parte Application for

Extension of the Page Limit. However, I took a closer look at your application to
identify your justification for the Extension of the Page Limit.
#3), which reads as follows:
Defendant intends to move for summary judgment or, in the alternative,
summary adjudication as the following causes of action:
1) harassment in violation of FEHA and failure to prevent harassment,
The above No. 1 Cause of Action in your Memorandum of Points and Authorities
is actually the THIRD CAUSE of ACTION in the SAC (Page Nos. 48–49) and
does not require an Extension of the Page Limit because the THIRD COA was
removed from the SAC in 2015 by the Anti-SLAPP Motion, C.C.P § 425.16
Chilcott, and Brent Seifert.
2) whistleblower/unlawful retaliation in violation of Government Code §
8547
The above No. 2 COA in your Memorandum of Points and Authorities is actually
-3-
the FOURTH CAUSE OF ACTION in the SAC (Page Nos. 55–57) and does not
from the SAC in 2015 by the Anti-SLAPP Motion, C.C.P. § 425.16, granted by the
Court to the Defendants, Danesha Nichols, Mike Boyd, Stephen Chilcott, and Brent
Seifert.
3) retaliation under Health and Safety Code § 1278.5
This is actually the FIFTH CAUSE OF ACTION in the SAC (Page Nos. 55–
Amended Complaint which was blocked in October 2015 to be file by Burkett ,
Bardzell and Judge David Brown’s Order
This is actually the SIXTH CAUSE OF ACTION in the SAC, and it is the
discrimination and witch hunt of March 2011–December 2012, which has caused
the University of California’s pay policies and employee classification. I was
perfectly happy with my classification and wages, but U.S Senator Feinstein’s
in the United States Court Of Appeals For The District Of Columbia Circuit
-4-
(https://www.scribd.com/document/495490868/Jaroslaw-Waszczuk-v-IRS-
DISTRICT-OF-COLUMBIA-CIRCUIT).
6) rescission – unlawful contract
This is actually the EIGHTH CAUSE OF ACTION in the SAC. Regardless
Squad.
of the Plaintiff’s employment relationship with Defendant.
employee and had a normal relationship with my employer. I was hunted down by
Parte Application.
I fail to understand why Porter Scott’s attorney is making attempts to bring back
motion granted by the Court. Previously, David Burkett brought back the four dismissed
-5-
Danesha Nichols, and Brent Seifert. Please clarify whether these individuals are
together with first four COAs. Porter Scott Attorneys once brought them back in
I noticed that in your April 26, 2021 Ex Parte Application for Leave to Extend
the Page Limit for the Defendant’s Motion For Summary Judgment or, in the
Bardzell’s and other Porter Scott’s lawyers pleadings of 2018–2020. I am quite sure
hear about this lawsuit or about Porter Scott’s Attorneys anti-SLAPP motion dirty
old wife . Your first show off in this case did not go well for you Ms. Goulding . You
are dirty and unprofessional lawyer as same as your Porter Scott’s predecessors with
J.D degree and licenses from the State Bar of California .
Sincerely,
Jaroslaw Waszczuk,
-6-
Mailing List

Hon. Clerk of the Court

Department 53 – Hon. Shama H. Mesiwala

Oakland, CA 94607


80 Howard Street
-7-
EXHIBIT # 39
AT-138/EJ-125
ATTORNEY OR PARTY WITHOUT Ar?ORNEY; STATE BAR NO.:
FOR COURT USE ONLY
NAME: Lindsay A. Gouiding, SBN 227195
FIRM NAME: Porfer Scott
STREETADDRESS: 350 Uolverslty AvBHue
CITY: Sacramento STATE: CA ZIPCODE: 95825
TELEPHONENO.: (916)929-1481 FAXNO.: (916)927-3706 FILED / ENqfORSBD
E-MAIL ADDRESS: lgouldlng@porterscott.eom, oaina@porterscott.com
ATTORNEY FOR (name): Defendants Boyd, Chilcott, Selfert, Oropeza, and Nivhols
SUPERIOR COURT OF CAUFORNIA, COUNTY OF SACRAMENTO MAY - 7 2021
CITYAND ZIPCODE Sacramento 95814
BRANCH NAME:
By \ Deputy Clerk

DEFENDANT REGENTS OF THE UNIVERSITY OF CALIFORNIA, etal.
n n ENFORCEMENT OF JUDGMENT ATTACHMENT (Third Person) 34-2013-00155479
a. I I fumish information to aid in enforcement of a money judgment against you.
b. I X I answer conceming property of the judgment debtor In your possession or control or conceming a debt you owe the
judgment debtor.
c. I I answer conceming property of the defendant in your possession or control or conceming a debt you owe the defendant
DatesJULUJ * Z , ' 2 0 ^ n Time;9:00 A.M. Dept. or Div.:43 Rm.:
Address of cdwart l ' x l Is shown above | | is:
3. This order may be sen/ed by a sheriff, marshal, registered process server, or the following specially appointed person (name):
D a t e : I '-I ( »ao«24 ™ADD A. BLIZZARD

JUDGE
I X I Original judgment aeditor Q Assignee of record Plaintiff who has a right to attach order
to appear and fumish Information to aid in enforcement of the money judgment or to answer conceming property or debt.
b. I X I a third person (1) who has possession or control of property belonging to the judgment debtor or the defendant or (2) who
owes the judgment debtor or the defendant more than $250. An affidavit supporting this application under Code of Civii
The person to be examined resides or has a place of business in this county or within 150 miles of the place of examination.
I I This court Is not the court in which the money judgment is entered or (attachment bnly) the court that issued the writ of
is attached.
I declare under penalty of perjury under the laws ofthe State of Califomia that the foregoing is true and correcL
Date: April 12 2021
Olatomlwa T. Aina 1^ (Plaiemiwa J, QUm

(Continued on reverse) Page 1 ef 2

• FForm
n t m AdopMw^landatofy
AHrmforiC Use Code of Clvll Procedure,
Judidal Council of Cabfomia
APPLICATION AND ORDER FOR §§ 491-110, 708.110, 708.120, 708.170
AT-138/EJ-12S [Ftev. Jjanuary 1, 2017] APPEARANCE AND EXAMINATION Hww.courts.ca.gov
APR 1 2 2021 (Attachment—Enforcement of Judgment)
83
. AT-138/EJ-125
' information for Judgment Creditor Regarding Service
If ybu want to be able to ask the court to enforce the order on the judgment debtor or any third party, you
nfiust have a copy of the order personally served on the judgment debtor by a sheriff, marshal, registered

NOTiCE TO JUDGMENT DEBTOR If you fall to appear at the time and place specified in this order,
proceeding.

(1) NOTICE TO PERSON SERVED If you fall to appear at the time and place specified in this order,
proceeding.
(2) NOTICE TO JUDGMENT DEBTOR The person in whose fevor the judgment was entered in this
Community property of Plaintiff/Judgment Debtor
Irina Waszczuk's employment wages
2000 Mercedes 320
served on the judgment creditor not later than three days before the date set for the examination.

may be subject to arrest and punishment for contempt of court, and the court may make an order

It is your duty to designate one or more of the following to appear and be examined: ofTicers,
directors, managing agents, or other persons who are femiliar with your property and debts.
language interpreter services are available if you ask at least 5 days before your hearing. Contact the clerk's
AT-138;EJ-125[Rev January 1,2017] APPLICATION A N D O R D E R FOR Pafle20f2

FILED/ENDORSED
TEL: 916.929.1481 By: -E. Medina
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{0241.1952.DOCX} 2
9 III.
10 CONCLUSION
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Lindsay A. Goulding
20
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{02413952.DOCX}
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5

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JJW1980@LrVE.COM
23
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{0241.1952.DOCX}
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{024^4532.DOCX} 1

Dated:
APR 2 7 2021
SHAMA H. MESIWALA
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{02414532.DOCX}

EXHIBIT # 40
2216 Katzakian Way
Lodi, CA 95242
Phone: 209-663-2977
Fax: 209-787-3131
April 27, 2021


Oakland, CA 94607
Seifert, Patrick Putney, and Dorin Daniliuc
Dear Ms. Aina:
I am requesting that you clarify with the Court why, on April 22, 2021, at
Court documents:
• CIVIL SUBPOENA (DUCES TECUM) for Personal Appearance and

Production of Documents, Electronically Stored Information, and Things
-1-
and Trial or Hearing and Declaration Issued to IRINA WASZCZUK
EXAMINATION OF IRINA WASZCZUK. (ATTACHMENT 3)
Lodi, CA 95242.

IRENA WASZCZUK. I am sure you understand the consequences of trying to get
For the above reason alone, I am advising you to properly fill out and resubmit
JANUSZ JAROSŁAW, and my wife’s legal Polish name is IRENA WASZCZUK. We
the National -Socialists at the University of California and their servants from the law
-2-
Poland-1980-1982

Daniel Bardzell at the end of October 2019. Looking at Nancy Sheehan and Daniel
Bardzell’s email addresses on the first page of your Declaration and reading
information in the Declaration about Judgment Debtor and Mrs. Waszczuk’s health
insurance through Mrs. Waszczuk’s employment at Nordstrom that it was not difficult
My wife and I are both on Medicare Insurance and Social Security. If you need any
I found it inappropriate and upsetting because you served me Nancy Sheehan’s

old drafted court documents. Nancy Sheehan, Porter Scott’s employee of 34 years,
sheehan&pid=194994093
-3-
Nancy Sheehan’s premature death saddened me because my wife’s sister died a
few years ago of metastatic breast cancer in Poland, and Nancy Sheehan’s e-mail
after her sister’s death.

FILE APPLICATION AND ORDER FOR APPEARANCE AND
EXAMINATION
and Order for Appearance and Examination violates the statutory 45 days’ notice

Court Law Library Debtor’s Examination, which will help you properly file the
(ATTACHMENT 5).
There are two separate periods to consider when choosing your hearing date:
date California Code of Civil Procedure (CCP) § 708.110(d).
-4-
November 7, 2018, and the debtor’s examination had to be rescheduled, which

Besides mentioning Nancy Sheehan’s e-mail in your Declaration, the front
page of your Declaration contains the following statement: “Attorneys for
Defendant REGENTS OF THE UNIVERSITY OF CALIFORNIA Attorneys for
SEIFERT.”
Since Porter Scott Attorneys’ Daniel Bardzell was teamed with Nancy
Sheehan in October 2019, in their pleadings, Porter Scott Attorneys is making
WASZCZUK’S NOTICE OF OBJECTION TO THE COURT ORDER DATED
DECEMBER13 & 17, 2019 AND PLAINTIFF REQUEST FOR COURT
ORDERS MODIFCATION – RE: OPPOSITION TO JUDGMENT CREDITORS’
-5-
(ATTACHMENT 7).
and Cindy Oropeza are Defendants. See Daniel Bardzell’s November 13, 2018
letter to Clerk of the Court (Attachment 6), in which Bardzell requested that
calendar due to a violation of the statutory 45 days’ notice requirement.
Scott Attorneys have had more than one year since my last Court filing dated
December 27, 2019 to clarify with the Court why Defendants Mike Boyd, Stephen
CONCLUSION
licensed attorney by the State Bar of California, I would like to advise you to
-6-
to in addition to responding to Porter Scott Attorneys’ negligence and deception.
https://www.scribd.com/document/495490868/Jaroslaw-Waszczuk-v-IRS-
As an attorney, you are an officer of the court who took an oath to uphold the
law. I assume you take responsibility as seriously as anyone else; you must adhere to
those rules and even report attorneys or people you see violating the rules. As a State
with the clerk.
(ATTACHMENT 8).
If you read my March–May 2019 e-mail correspondences with State Bar of

California Executives, then you will understand that I am not taking Porter Scott
Attorneys’ legal gangsterism lightly.
Request-for-Review
-7-
https://www.scribd.com/document/504978933/20190329-Request-for-Review-
Additional-Information-and-Documents-Vanessa-Holton-Rachel-Grunberg
https://www.scribd.com/document/504979845/20190515-Leah-Wilson-State-Bar-
Ceo-Reimbursement
In 2019, I recovered the money stolen from me by Douglas Stein and the
money stolen in 2011 by the University of California gangsters, namely my Short
stolen from me in 2014, namely my Unemployment Insurance Benefits. However ,
federal agencies .
Finally, I am asking you to reschedule my wife’s court hearing examination

in Department 43 to June 2021. I am awaiting a second shot of the Moderna
COVID-19 vaccine. I am scheduled to be vaccinated on May 13, 2021 As we
different medications, and I am unsure of how I will be affected by the Moderna
vaccine thus I need some time for recovery from vaccine side effects if any to
-8-
If you have any questions, please do not hesitate to contact me at your
convenience.
Sincerely,
Jaroslaw Waszczuk
-9-
Mailing List


Department 43 – Hon. Thadd A. Blizzard
720 9th Street 6th Floor

Oakland, CA 94607


80 Howard Street
- 10 -
L _
s
£525? V_
gig M 7’ 32 2&7L/ M g‘fwf’fjff AT-138_/E._J-125
ATTORNEY OR PARTY WITHOUT ATTORNEY: STATE BAR N05 FOR COURT use ONLY
NAME:
STREET ADDRESS: 350
University Avenue
CITY: Sacramento CA Zip CODE: 95825
STATE:
TELEPHONENO.: (916) 929—1481 (916) 927-3706

FAX NO.:
E-MAILADDRESS: lgoulding@porterscott.com, oaina@porterscott.oom

ATToRNEY FOR (name): Defendants Boyd, Chilcott, Seifert, Oropeza, and Nivhols
'
SUPERIORCOURT OF CALIFORNIA, COUNTY OF SACRAMENTO

MAILING ADDREss: 720 9th Street
BRANCH NAME:
DEFENDANTREGENTS OF THE UNIVERSITYOF CALIFORNIA, et al.
APPLICATIONAND ORDER FOR APPEARANCE AND EXAMINATION VCASE NUMBER:

ENFORCEMENT OF JUDGMENT CI ATTACHMENT (Third Person) 34-2013-00155479
E] JudgmentDebtor Third Person
a. [j furnish information to aid in enforcement of a money judgment against you.
b. answer concerning property of the judgment debtor in your possession or control or concerning a debt you owe the
judgment debtor.
c. [I] answer concerning property of the defendant in your possession or control or concerning a debt you owe the defendant
Address of court (II is shown above l: is:
Date:
JUDGE
‘

‘
4. Original judgment creditor E] Assignee of record I: Plaintiff who has a right to attach order
to appear and furnish information to aid in enforcement of the money judgment or to answer concerning property or debt.
a. |:| the judgment debtor.
b. a third person (1) who has possession or control of property belonging to the judgment debtor or the defendant or (2) who
1
owes the judgment debtor or the defendant more than $250. An affidavit supporting this application under Code of Civil
6. The person to be examined resides or has a place of business in this county or within 150 miles of the place of examination.
7. I: This court is not the court in which the money judgment is entered or (attachment only) the court that issued the writ of
8. I: Thejudgment debtor has been examined within the past 120 days. An affidavit showing good cause for another examination
is attached.
Date: April 12 2021
(Waterman; Jr. (lma

u -
}
\
.
ommmiwa T, Aina
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(Continued on reverse) Page 1 on

c d to 1 P d
F
£583“8§Li‘il°&“éit?§ti§use
APPL'CAT'ON AND ORDER FOR §§ 491.110, 703,213,°7o£.“1'zof°7°§a.i%
,
AT~138IEJ~125 [Rev. January 1.2017] APPEARANCE AND EXAMINATION www.courrs.ca.gov
AT-138/EJ-125
”
'
the hearin and have a roof of service filed with the court.
,

NOTICE TO JUDGMENT [DEBTOR If you fail to appear at the time and place specified in this order,
proceeding.
proceeding.
(2) NOTICE TO JUDGMENT DEBTOR The person in whose favor the judgmentwas entered in this
Community property of Plaintiff/JudgmentDebtor
Irina Waszczuk's employmentwages
2000 Mercedes 320
Any and all communityproperty owned by Plaintiff and Irina Waszczuk
judgment,you must file your exemption claim in writing with the court and have a copy personally
served on the judgmentcreditor not later than three days before the date set for the examination.

may be subject to arrest and punishmentfor contempt of court, and the court may make an order
requiring you to pay the reasonable attorneyfees incurred by the plaintiff in this proceeding.
APPEARANCE OF A CORPORATION,PARTNERSHIP,
;
ASSOCIATION,TRUST, OR OTHERORGANIZATION
Request for Accommodations. Assistive listening systems, computer-assisted real—time captioning, or sign
language interpreter services are availableif you ask at least 5 days before your hearing. Contact the clerk’s
office for Request for Accommodation (form MC-410). (Civil Code, § 54.8.)
'
Page2of 2
AT-138lEJ-125[Rev.January1,2017] APPLICATIONAND ORDER FOR
APPEARANCEAND EXAMINATION
‘
MC-025
_
Jaroslaw Waszczuk V. Regents of the University of California, et al. 34—2013-00155479
( This Attachment may be used with any Judicial Council form.)
16. All DOCUMENTS relating to any transfer of over $500 made to or from YOU from October 4, 2015 to
present.
17. All DOCUMENTS relating to any transfer of over $500 made to or from YOUR spouse from October 4,
2015 to present.
19. All DOCUMENTS relating to any retirement account held by YOU.
20.All DOCUMENTS relating to any retirement account held by YOUR spouse.
21. All DOCUMENTS relating to any payroll stubs indicating earnings from any employment you have
engaged in from 2016 to the present.
(A dd p ages as required)
.
Fantttfazsfl4529sant“ ATTACHMENT
M0025(Rev. July 1. 20091 to Judicial Council Form
Q
. , e
'
MC-025
SHORT TITLE: CASE NUMBER
_
1. A11 DOCUMENTS sufficient to IDENTIFY YOUR current residence, including but not limited to
2.
contents therein.
9. All federal and state corporate tax returns YOU have filed from 2012 to the present. -
10. All DOCUMENTS relating to any of YOUR property held by third parties. ~
12. All DOCUMENTS relating to any benefits YOU have received or currently receive, including by not
13. All DOCUMENTS relating to any vested future interest YOU have in any property or in the payment of
any money.
(Add pages as required)
‘
Ffll'éiéi’a‘irélfifléi’ofl’égfifnoi'nife ATTACHMENT www'cw'tmm‘ca'gw
moozsrRev.July1.20091 to Judicial Council Form

EXHIBIT # 43
MINUTE ORDER
DATE: 10/28/2015 TIME: 02:00:00 PM DEPT: 53
CLERK: E. Brown
REPORTER/ERM:

APPEARANCES
Nature of Proceeding: Ruling on Submitted Matter (Motion for Automatic Stay) taken under
submission on 10/26/2015
TENTATIVE RULING
Defendants Regents of the University of California, Michael Boyd, Stephen Chilcott, Dorin Daniliuc,
Danehsa Nichols, Cindy Oropeza, Patrick Putney, Ann Madden Rice, Brent Seifert and Charles
Witcher's motion for an automatic stay pursuant to CCP § 916(a), or in the alternative for a discretionary
stay is ruled upon as follows.
In the instant matter, Plaintiff asserts four causes of action against the above ten defendants for IIED,
tortious interference with economic advantage, FEHA harassment and failure to prevent, and
whistleblower retaliation in violation of Government Code §§ 8547 et seq. Plaintiff alleges four additional
causes of action for Violation of Labor Code § 1278.5, breach of contract, wage and hour violations and
rescission against Regents. The Court granted Defendants Boyd, Chilcott, Nichols, Oropez, and
Seifert's ("Dismissed Defendants") anti-SLAPP motion and ultimately entered judgment dismissing them
from the action. Plaintiff has appealed the judgment. Defendants Regents, Rice, Witcher, Putney and
Daniliuc ("Remaining Defendants") remain in the lawsuit on the first four causes of action. Regents
remains on the other four causes of action. Remaining Defendants seek a stay of the action pending the
appeal arguing that the proceedings are subject to an automatic stay pursuant to CCP § 916(a) or
alternatively that a discretionary stay is warranted.
The perfecting of an appeal stays proceedings in the trial court upon the judgment or order appealed
from or upon the matters embraced therein or affected thereby, including enforcement of the judgment
or order, but the trial court may proceed upon any other matter embraced in the action and not affected
by the judgment or order. Code Civ Proc § 916 (a); see also Varian Medical Systems, Inc. v. Delfino
(2005) 35 Cal. 4th 180.
To be clear, CCP § 916(a) stays all further trial court proceedings "upon the matters embraced in" or
"affected" by the appeal. "In determining whether a proceeding is embraced in or affected by the
appeal, we must consider the appeal and its possible outcome in relation to the proceeding and its

possible results. '[W]hether a matter is 'embraced' in or 'affected' by a judgment [or order] within the
meaning of [section 916] depends on whether postjudgment [or postorder] proceedings on the matter
would have any effect on the 'effectiveness' of the appeal.'" (Varian Medical Systems, Inc. v. Delfino
(2005) 35 Cal.4th 180, 189 [citations omitted].) "If so, the proceedings are stayed; if not, the
proceedings are permitted." (Id.) "A trial court proceeding also affects the effectiveness of an appeal if
the possible outcomes on an appeal and the actual or possible results of the proceeding are
irreconcilable." (Id. at 190.) "The purpose of the automatic stay rule is 'to protect the appellate court's
jurisdiction by preserving the status quo until the appeal is decided. The rule prevents the trial court
from rendering an appeal futile by altering the appealed judgment or order by conducting other
proceedings that may affect it." (Dowling v. Zimmerman (2001) 85 Cal.App.4th 1400, 1428.)
Here the Court is not persuaded that Plaintiff's appeal from the order and judgment following the
Dismissed Defendants' successful anti-SLAPP motion automatically stays the entirety of the
proceedings with respect to the Remaining Defendants who themselves did not bring an anti-SLAPP
motion. No Court has held that an appeal from an order granting, as opposed to denying, an
anti-SLAPP motion divests the trial court of jurisdiction, especially as to matters related to other
defendants. Indeed, Varian held that an appeal from the denial of an anti-SLAPP motion automatically
stayed further trial court proceedings on the merits, but made clear that such an appeal does not stay
proceedings related to causes of action that were not affected by the motion. (Varian, supra, 35 Cal.4th
at 195, fn. 8 ["Such an appeal does not, however, stay proceedings relating to causes of action not
affected by the motion"].)
While it is true that Plaintiff asserted the first four causes of action against the Dismissed Defendants
and the Remaining Defendants based on allegations that each of them participated in a coordinated
campaign of unlawful conduct, only the Dismissed Defendants brought the anti-SLAPP motion.
Remaining Defendants were not parties to that motion. Remaining Defendants cite no authority for the
proposition that an automatic stay is mandated based on an appeal of the granting of other defendants'
anti-SLAPP motion simply because all are named in the same cause of action. Importantly, the conduct
of the Remaining Defendants was not at issue in the anti-SLAPP motion. They fail to articulate how a
possible outcome on appeal (e.g. a reversal of the order granting the anti-SLAPP motion and entering
judgment in the Dismissed Defendants' favor) is irreconcilable with the possible results on the same four
causes of action in these proceedings, specifically given that the conduct of the Remaining Defendants
was not addressed in those motions. Remaining Defendants complain that Plaintiff is a prolific motion
filer and there is a danger that Plaintiff will file numerous motions that will be heard and decided in the
Dismissed Defendants' absence and that if the judgment were reversed the Dismissed Defendants could
be inserted back into a case that may be significantly different. They point to the fact that Plaintiff
apparently intends to seek to file a voluminous Third Amended Complaint. But, speculation aside, this
fails to show how anything that could take place in these proceedings would render the appeal futile or
how the possible results on appeal and in these proceedings are irreconcilable. This is especially true
since Plaintiff has since dismissed Defendants Rice, Witcher, Putney and Daniliuc from the lawsuit and
the Regents is the only one of the five Remaining Defendants left in the action. Remaining Defendants
fail to articulate, for example, how it would be irreconcilable for them to be found liable on Plaintiff's
claims at trial even if the appeal affirmed the anti-SLAPP order and judgment of dismissal as to the
Dismissed Defendants.
In any event, even if it could arguably be said that there was a possibility of irreconcilable results
between the first four causes of action against the Remaining Defendants and the appeal which involved
the first four causes of action against the Dismissed Defendants, there are four other causes of action
asserted against the Regents which were not the subject of the Dismissed Defendant's anti-SLAPP
motion. Those causes of action were not implicated in any way in the anti-SLAPP motion and any
appeal related to the anti-SLAPP motion could not result in a stay of those causes of action. (Varian,
supra, 35 Cal.4th at 195, fn. 8 ["Such an appeal does not, however, stay proceedings relating to causes

of action not affected by the motion"].) Yet, Remaining Defendants seek a stay of the entire action
pursuant to CCP § 916. They did not simply seek a stay of the first four causes of action.
However, the Court does agree that a discretionary stay of the proceedings pending resolution of
Plaintiff's appeal is appropriate. "Trial courts generally have the inherent power to stay proceedings in
the interests of justice and to promote judicial efficiency." (Freiberg v. City of Mission Viejo (1995) 33
Cal.App.4th 1484, 1489.) In fact "it may be in the interests of justice to stay a trial until another party's
appeal is decided..." (Id.) This is such a case. Here the Court finds that the interests of justice support
a stay. The Court is mindful of the inefficient use of judicial resources if a stay is not issued, specifically,
in the event the judgment is reversed. Consequently, Plaintiffs would then be entitled to try the matter
again as to those defendants who should have been at the first trial. The potential inefficiencies in this
approach are too numerous to mention. Indeed, the four causes of action that are the subject of the
appeal are also asserted against the Remaining Defendants and the allegations as to all the Defendants
appear factually intertwined and likely would involve much of the same evidence and issues. There is
thus a very real possibility that in the event Dismissed Defendants were returned to this action if the
judgment on appeal is reversed, any motions and/or discovery that were conducted in their absence
would need to be repeated. In addition, while there are four other causes of action asserted against the
Regents which were not the subject of the appeal, those causes of action also likely involve similar
evidence and witnesses and allowing piecemeal litigation would not be in the interests of justice. A stay
would promote judicial efficiency.
Plaintiff's opposition fails to present any persuasive argument against a stay. Rather Plaintiff presents
arguments going to the ultimate merits of the lawsuit and apparently the appeal. Plaintiff also indicates
that he intends to file a third amended complaint in which he intends to eliminate all individual
Defendants and simply leave his two causes of action for breach of contract and violation of Health &
Safety Code § 1278.5. The Court finds that this simply confirms the propriety of a stay under the
circumstances. Indeed, if the action is not stayed and Plaintiff were permitted to file the TAC and the
judgment against the Dismissed Defendants reversed, this could lead to extreme confusion regarding
the status of the case. That is, if the judgment against the Dismissed Defendants on the second
amended complaint is reversed the Dismissed Defendants would be returned to the action. However,
the TAC referred to by Plaintiff appears to no longer include any of the causes of action asserted against
them but Plaintiff is not contending that he has abandoned his appeal. The parties and the Court would
then need to sort out what the operative pleading would be. In the interim, the parties would have
litigated only the two causes of action against the Regents in the TAC and would then have to essentially
begin again with the four causes of action against the Dismissed Defendants. A stay is appropriate in
the interests of justice and to promote judicial efficiency.
As a result, Remaining Defendants' request for a discretionary stay is granted. This action is stayed in
its entirety pending the resolution of Plaintiff's appeal.
Defendants' request for judicial notice is granted.
This minute order is effective immediately. No formal order pursuant to CRC rule 3.1312 or other notice
is required.
COURT RULING


Dated: October 28, 2015
JAROSLAW WASZCZUK
2216 KATZAKIAN WAY
LODI, CA 95242
DOUGLAS L. ROPEL
PORTER SCOTT

2 Lodi, CA 95242
Telephone: (209) 663-2977
3 Facsimile: (209) 370-8281
4
5
7 DRAFT
8

12 )
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and/or abuse.
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10 $70,000.00.
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from UC DAVIS.
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patient care.
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disability.
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Medical Center.
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cogeneration plant.
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13 88. It is also a question of law whether the Defendant committed

16 was being operated in violation of the federal law and regulations and could be subject to shut down
17 and personnel could face unemployment if violations were disclosed.
20 State of California Revenue and Taxation Code by engaging in commercial operation of a
22 companies and made millions of dollars in profit from seventeen years of operation.
25 Internal Revenue Service’s Code Section 501(c)(3) by engaging in commercial operation of a
27 companies and made millions of dollars in profit from seventeen years of operation. An organization
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8 personnel.
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2008 Case No. : 03-PPS-013-06107
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Connie Melendy.
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10 The Attorney Danesha Nichol’s Deployment From The UC Davis Campus to UC Davis
11 Medical Center Human Resources Department in October 2010
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19 management, and she was very familiar with the crime that was committed in the Central Plant
20 in the period of time spanning from 1998 to 2009 and Nichols was familiar with Plaintiff’s file .
21 212. Danesha Nichols arrived at UC Davis Medical in October 2010 with the
22 title of Investigation Coordinator in similar circumstances as Stephen Chilcott in 2005 and she
23 reported directly to Director Stephen Chilcott.
24 213. As Plaintiff stated previously, the UC Davis Medical Center’s newly built
25 in 1998 Cogeneration Power Plant/Central Plant was a pride and legacy left behind for former
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4 The December 2010 Central Plant Operator Locker Burglary
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found, appropriate action will be taken.”
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unable to notice William Buckan’s accident underneath the cooling tower’s oily surface. Mike Lewis
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216. Five days after the Principal Engineer Mike Lewis issued his dramatic
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memo about the incoming investigation to find perpetrator Central Plant Operator, Todd
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Goerlich committed suicide. Then, the rest of the Central Plant Operators received a 12% pay
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raise despite strict UC budget constraints and furlough in UC Campuses and no power sale
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contract . Thereafter, everything got quiet. Nobody was questioned by an HR investigator or the
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UC Davis Police Department about locker burglary. No more comments were made by any
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Central Plant supervisors about Jeff Lancaster’s burglarized locker, no more dramatic memos
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13 217. Around March 5, 2011, Plaintiff somehow got into a conversation with
14 the operator from the central plant William Buckans about the December 2010 12% pay raise,
15 and Plaintiff received from Buckans a copy of the UCDMC Plant Operation and the letter from
16 maintenance manager Charles Witcher dated December 20, 2010, which confirmed a 12% pay
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plant operators was discriminatory to other non-union employees of the UC Davis Medical
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Center who did not get one penny in wage increase in the last three years due to strict budget
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constraints in the whole University of California system. The disclosure about the secret pay
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raise for small groups of employees became a subject of discussion among workers at the other
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shops in the UC Davis Medical Center. Plaintiff confronted his shop manager Patrick Putney and
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Plaintiff asked Putney why the HVAC shop staff did not get a pay raise. Putney’s response was
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that he knew about the pay raise, but was told to be silent about it to avoid any turmoil among
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the other shops’ workers. Following the discussion with Patrick Putney, Plaintiff wrote an eight-
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2 wage increase.
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5 in March 2011
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7 12% pay raise for the Central Plant Operators, Department Principal Engineer Mike Lewis
8 issued a memo dated March 11, 2011, instructing Central Plant crew to do the following:
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17 access to the Central Plant request access to the Central Plant please contact
18 Charles Witcher, Mike Lewis, or Dennis Curry for direction. Thank you.”
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shift personnel.
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2 replacement in the Central Plant in March 2007, and he did not survive hostility created by UC
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long Defendant’s psychological terror aimed at Plaintiff by Defendant’s agents and
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dollars.
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At the best of my ability to write, I will try to explain why I feel discriminated
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and left behind like an orphan in abandoned orphanage.
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1 Last year in August 2010 after I came back to work from vacation, my
2 coworker from HVAC shop, Bill Rabidoux asked me if I will be willing to
3 work swing shift because HVAC shop manager told him that second shift
4 would be created for the Metasys System operation outside the Central Plant.
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I responded that it would be no problem.
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9 inside the department and he is trying to fix something that is not broken.
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Shortly after, in September 2010, I received by copy of the undated but signed
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petition by four Central Plant operators in regards to Metasys Operation
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15 After I read the petition and attached to the petition the wages disclosure
16 printed from the Sacramento Bee website, the first my thought was that the
17 petition is a follow up to their earlier complaint which I thought they submitted
18 in August during my vacation absence. The petition itself alleged that Metasys
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Central Plant.
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Central Plant employee who took his own life. Just day or two before it
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4 experienced bully behavior toward, Rick Tunello and William Buckans and
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this petition.
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The other December 2010 story from the Central Plant is a story of the Jeff
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UCDMC Human Resources department for appropriate investigation and
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3 Mike Lewis
Principal engineer
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Dear Mr. Witcher:
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mention again his raise and again I thought that he is trying to "pull my legs"
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1 Position.
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make after the December 2010 pay raise.
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responsibility for the operation and maintenance of the Central Plant.
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3
4 Beside the Metasys Alarms I am doing other stuff requested by Patrick Putney
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circulation normal
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In conclusion I am respectfully asking and I would appreciate if my salary will
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17 Sincerely
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23 observation how badly Todd Goerlich disliked Jeff Lancaster and, in particular, how different
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who provided the recommendation for Dereck Cole to be hired as an HVAC Technician by UC
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4 showed up in the Central Plant with a hand-printed copy of UC Davis Policy 1616, for the UC
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this place was and how it had contributed to an employee’s suicide.
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21 $70,000.00 to $71,600 per year.
23 224. Instead of any response to my letter from Charles Witcher in April 2011,
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daughter, whom he had brought to the shop on that day. Plaintiff told Putney that he didn’t miss
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4 from these buildings were coming to the Metasys Computer Monitoring System and Plaintiff had
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responded, “I am trying to make you perfect.” Plaintiff said ok and continued to train himself to
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17 Hospital.
23 hostility towards Plaintiff; Plaintiff became the subject of vicious attacks, including and not limited
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227. In May and June 2011, Patrick Putney turned off the lights in his office and
27
positioned himself in the chair toward Plaintiff and stalked Plaintiff for hours every day. Once in
28

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3 No so long prior to Putney’s behavior—in March 2011—Plaintiff was making breakfasts for
4 Putney every morning and had quite a normal relationship with him and his assistant. Dorin
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punished, as this had happened to one of his coworkers, Rick Tunello, in the central plant. Rick
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Tunello had been wrongfully accused and wrongfully convicted by Dennis Curry, and wrongfully
14

22 Curry and Witcher’s approach to resolving the dispute. The abovementioned course for supervisors
23 was hosted by UC Davis Medical Center Human Resources Executive Director Gloria Alvarado.
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dare to complain. One of the course’s subjects was how to convince a subordinate that he is too
27
observant to demote himself. Plaintiff responded to Ms. Alvarado self-demotion instruction and
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3 After a short discussion with Plaintiff, Ms. Alvarado changed subjects and ended instructing
4 supervisors who attended the class on how to take control of the crew by intimidation and fear.
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12 May 2011
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Charles Witcher, to clarify the issue with the missing refrigerator alarm, to discuss the unusual and
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psychotic behavior of Patrick Putney toward me, which was not limited to stalking Plaintiff from
16
24 victim of Patrick’s Putney, Dennis Curry, and Charles Witcher’s schemes and yet another
25 candidate to look for new employment. He was unspeakably victimized and asked me to represent
26
him with his complaints against Patrick Putney and Charles Witcher. Another Patrick Putney
27
victim is 72-year-old HVAC technician Richard Pawlaczyk. The Richard Pawlaczyk’s case was
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3 Patrick Putney denied Plaintiff’s access to his time cards , work orders system and to sabotage
4 Plaintiff job Putney denied Plaintiff’s access to many Metasys system future . Plaintiff failed to
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Patrick Putney. I would prefer for the situation to improve somehow and for
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everything to return to normal in the workplace .Unfortunately, it does not
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22 Monday, and I tried to smooth out everything. I even offered him breakfast,
23 but my attempt to make peace with him did not work, and the situation still
24
does not look good.
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26
"unreliable alarms" in the Metasys . Without discussion, I found these unreliable
27
alarms for him. It took me almost a week to complete the task, after which Patrick
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3 communication with me, including not saying "good morning” or “bye” at the end
4 of the day. As you know, Department Head Assistant Dennis Curry came to the
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and dumped on my desk the policy and procedures for central plant operators,
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which explains how to operate the Metasys system, plus my job description.
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22 the UCDMC premises by hiding his car inside the shop and playing a little
23 "catch me if you can” game with the parking cops. On top of this, I decided to
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at the same time having the ambition to became assistant PO&M [plant
27
operation and maintenance] manager after Dennis Curry retires?”
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3 The peace, however, did not last long. Yesterday and today, Patrick started a
4 new "kids game." He turned off the light in his office, which is next to mine, and
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create a confrontation with me for any reason. I simply told him not to worry
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and that I had been reviewing and closing all of the completed work orders for
14

22 still don't understand why I got kicked out. I did not park my car without a
23 permit, and I did not do private jobs in the company shop. I just wanted a few
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supervisor is doing everything possible to make my life miserable and hellish.
27
To avoid going through this hell and finally end Patrick’s hostility, I would be
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3 Should I apologize to Patrick by saying that I have been doing a good job for
4 the past three years and don't have a history of neglecting my duties and of
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information about the Central Plant’s operation and electric power, steam, hot water, and chill
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water production.
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22 System about the Central Plant and be removed from the premises at any means. The UC Davis
23 Medical Center PO&M Department Manager was the one of four UC Davis employees who
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June 2011
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4 Regardless of the stress and feelings, in good faith and will, Plaintiff sent an email to Patrick
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Daniliuc as it was mandated by the UC Davis Policy PPSM 23.
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15 July 2011
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241. Danesha Nichols was very familiar with the previous attack against Plaintiff
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3 gross and despicable violation and breach of the Settlement-Agreement signed by Defendant.
4 242. Besides the investigation issues, Plaintiff on July 17 and July 24, 2011, sent
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243.. As a result of Plaintiff’s complaints to UC Davis Chief Counsel Steven
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Drown about the Settlement-Agreement violations by the Defendant, the UC Davis Chief
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19 River.
22 relationship with two UC Davis Medical Center directors, Robert Taylor and Shelton Duruisseau
23 The Daniliuc’ relation with these two directors was to provide them HVAC services in their
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25
26
of five investigation reports written by Danesha Nichols in December 2011 and February 2012.
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245. Plaintiff also asked Executive Director Mike Boyd, who is a listed
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3 stop the retaliation and further harassment. Plaintiff did not get a response from the HR Director,
4 but Director Mike Boyd denied Plaintiff’s request for 30 days of administrative leave. However,
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September 2011.
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illegally accessing shop computers. Bill Rabidaux’s son was a twice-convicted child
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pornography felon on probation; he was prohibited to have a computer at home by court
14

22 when he came back to his office. When Plaintiff told Putney about it, he got upset that Kenny
23 Diede had not waited for him with information and angrily asked Kenny whose side Kenny is s
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25
26
pornography felon accessing shop computers. Thereafter Kenny Diede had to look for a new job
27
due to harassment and intolerable working conditions, as Patrick Putney, Dorin Daniliuc, and
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3 review from his two supervisors, Patrick Putney and Dorin Daniliuc, as was mandated by the UC
4 Davis Policy PPSM 23.
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70. Annual Performance Reviews (Evaluations) are the most important documents in the
13
14
15 Rptr. 2d 83 (Cal. Ct. App. 1993).
22 premises through the false and fraudulent Workers Compensation Claim. Plaintiff refused to file
23 a false claim, but a claim was filed on Plaintiff’s behalf anyway.
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taking into consideration that on May 31, 2012, Hugh Parker coordinated ill-minded but
27
unsuccessful provocation to kill Plaintiff or end his employment in UCDMC Trauma Unit #11 by
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3 deliberately and “professionally” damaged when Plaintiff left his office for lunch. The external
4 hard drive circuit board was literally fried, most likely by high electric current and the damage was
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USB-powered external hard drive (HD) had been fried/damaged by
13
somebody after I left it connected to the computer in my office and I left
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20 burned.
22 hand. Therefore, I can only write and whine about this event. I did not take any
23 chances by remaining in my office any longer and getting electrocuted like my HD.”
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25
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System HR department, the UC Davis chief counsel, and the UC Davis chief compliance office
27
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4 surgery a few years ago. Plaintiff was using nine different prescription medicines to survive every
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7 August 2011
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was also hoping that the UCDM HR assigned investigator, Attorney Danesha Nichols, would
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25 pursuant to UC Davis Complaint Resolution Policy PPSM 70 and Whistleblowing Retaliation
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27
259. The August 2, 2011 was Plaintiff’s last physical presence and last working
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4 260. On August 30, 2011, Plaintiff filed an official complaint against his
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employees and that the investigation would be finished in 14 days.
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24 September 2011
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unsuccessful attempt to force Plaintiff to quit his job or to participate in the investigation against
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4 Nichols to send an e-mail to Plaintiff and basically ordered Plaintiff to meet her the next day in
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265. Plaintiff was informed by the UC Davis Public Record Act office that
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23 Defendant in FAC and SAC) to add Danesha Nichols and Charles Witcher to Plaintiff’s
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Danesha Nichols, transmitting the same baseless accusation of violence and discrimination and
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4 was a only tool in the hands of HR Director Stephen Chilcott and Charles Witcher with education
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force me to confess to the crimes based on fabricated false and groundless
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23 diligent way without bias, prejudice, and discrimination.”
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management capacity because it appears that your management capacity is not
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4 abusing not only his own subordinates but also abusing animals and members
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mentioned above.”
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psychologist’s help to cope with the enormous emotional stress and anxiety in relation to
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23 Apparently, Plaintiff physician who placed Plaintiff on stress-related sick leave stopped the
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Plaintiff’s employment termination before the termination letter was sent to Plaintiff .
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4 announcement by Bill Rubidoux, the PO&M Manager Charles Witcher sent Plaintiff a letter
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wrote:
13
, “By this letter, I am respectfully requesting from your office intervention to
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23 connected to this case.
24
October 2011
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27
California against UC Davis Medical Center’s two Human Resources Department Attorneys,
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4 behavior, conspiracy against Plaintiff, and gross misconduct. State Bar Case No. 11-31088.
5
14 unfounded accusation against me from UCDMC HR Attorneys and other individuals,”
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18
UC Davis Campus).
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e-mail letter:
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Operation and Maintenance, Sacramento Department. In last few months I
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4 accusations and allegations for the period from
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unfounded accusations fabricated by the Defendant against Plaintiff. Captain Joyce Souza, in her
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15 response, wrote:


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Chancellor Linda Katehi; UC Davis Medical Center CEO Ann Madden Rice; UC HR Vice
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4 accusations against Plaintiff.
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changed course and were trying to find for Plaintiff a new place to work in UCDMC. Plaintiff
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14 intolerable.
18 child pornography felon on parole who had illegally accessed the HVAC shop computer and was
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26
LANCASTER'S BURGALIZED LOCKER ON DECEMBER 17, 2010 AND PAY RAISE FOR
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UCDMC CENTRAL PLANT OPERATORS ON DECEMBER 20, 2010.
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2 2010.
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Delmendo.
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the organization and operation of the campus. With the investigation by Ms.

Sincerely,
22
25
Director Epperson”
290. On October 29, 2011Plaintiff responded to UCOP HR Director Simon’s
26
27 letter

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Director of HR Compliance
1 UNIVERSITY OF CALIFORNIA
HR-UCOP Human Resources
2 1111 Franklin St., 5th Floor
Oakland , CA 94007-1449
3
Re: Reponse To Your Letter Dated October 26, 2011-The Progress Of The
4 Investigation
5 Dear Director Simon:
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7
It is almost one month passed by since I asked Vice President Duckett for
8
intervention in this case .
9
I would like to mention that the previous UC HR Vice President Mrs. Judith
10
Boyette , had no any problem to intervene if needed and respond personally to
11
employees complaint letters .
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In my response to your letter I would try not to repeat what I wrote already in
13
my multi correspondence to Vice President Duckett , Mrs. Delmendo and
14
others UC Officials but at some point I have to rely on the facts of events and
15
17 It would be unnecessary to ask Vice President Duckett for intervention and
18 send the
19 Open Letter to The Honorable Members of UC Davis Ethics and Compliance

20 Risk Committee and the California State Assembly Members,and The Regents
21 Of The University of California entitled: "I FEEL LIKE A HUNTED JEW
22 DURING THE HOLOCAUST"
23 if, after my respectful request on July 13, 2011, I sent to UC Davis Medical
24 Center HR Executive Director Mr. Stephen Chilcott to intervene in the case.
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26
would start her investigation or at least she start her investigation, after I sent a
27
lengthy letter dated July 31, 2011 to UC Davis Chief Compliance Officer Mrs.
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2 President.
3 Instead of the investigation, the UCDMC Plant Operation & Maintenance
4 Management with full back up and support of the UCDMC HR Department
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loud voice, did not give me any choice but to evacuate myself from the shop
13
and ask my doctor for stress leave.
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22 the stalking me, I observed that his hands are almost constantly shaking
23 especially when he got excited or mad or even for no reason.
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Patrick Putney would turn off lights in his office and would be stalking her as
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he stalked Waszczuk.
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3 harassed by supervisors.
4 Whether , after such complaint by female employee, Patrick Putney would be
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Putney to protect stalked female employee or hunt her down for complaining
13
as it had been done to Waszczuk?
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22 investigation is going on. The HVAC Shop social area experiencing
23 remodeling, painting and clean up. This very good and promising sign for
24
positive changes.
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26
that Charles Witcher, Patrick Putney, Dennis Curry, Danesha Nichols, Stephen
27
Chilcot, Mike Garcia, Cindy Oropeza and Mike Boyd are responsible for
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3 Regents in February 2009. The Settlement Agreement had been grossly
4 violated by the above mentioned individuals and I am expecting from my
5
6
work .
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unwarranted threats of termination of my employment by some of the above
13
listed individuals.
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22 If UC won't let me go back to work as soon as possible than I respectfully
23 requesting answer ASAP what is the other option because I don't know. I have
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26
I appreciate your prompt response in this matter and I am awaiting for
27
resolution to end this employer hostility against me .
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Sincerely,
1
Jaroslaw Waszczuk
2
3 CC: Vice President- Dwaine Duckett

Director Epperson
6 Liberty Mutual”
7 November 2011
8
9
291. In November 2011, Plaintiff spent most of his time dealing with the
16 nonsense to accept the FMLA protection extension to stay employed without the income.
17 292. In the response letter, dated November 23, 2011, to Gina Harwood,
18
Plaintiff wrote:
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effect of my health and welfare benefits makes no sense to me.
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The University is fully responsible and legally liable for my current health

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3 Records Act requests, the UC Davis chancellor requested from Danesha Nichols a confidential
4 report on Plaintiff, which was sent in November to Chancellor Linda Katehi. The exact day
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294. The premediated pepper spray attack ordered by Chancellor Katehi on November
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18, 2011, was solely used to replace UC Davis Chief of Police Annette Spicuzza with Lt. Matt
14
21
295. On November 14, 2011, Plaintiff filed a complaint with the State of California
22
23
Department of Insurance against the Liberty Assurance Company of Boston for denying to
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3 applying different standards of conduct than with other claimants and other University of
4 California employees, without any legitimate justification. As a result of Liberty Assurance
5
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7
other benefits.
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9
10 Plaintiff declined such an offer, and the case is still unresolved.
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13
publications “Chemical Katehi,” on November 18, 2011, ordered gas attacks against peacefully
14
protesting students on the UC Davis Campus. In this way, Katehi observed and marked the 38th
15
18 Polytechnic.
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27 299. Plaintiff responded to Vice Chancellor Pomeroy’s outcry with the following words:
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1 Dear Ms. Pomeroy:
2
3 Can you do something about the National Socialism doctrine oriented and
4 entirely corrupted management in the UC Davis Medical Center, Plant
5 Operation and Maintenance and Human Resources Departments? The
6
Principles of Community does not exist in UCDMC and it is the empty slogan.
7
Your commitment to freedom of expression is also empty slogan as well. You
8
and others are receiving my letters for quite long and you and others don’t care
9
what the “UCDMC Gestapo” doing to me and how systematically is
10
destroying my and others livelihood and life. I am sending a few letters again
11
to you with hope that I will be heartened to see Ms. Pomeroy will order to
12
conduct a true investigation against the corrupted individuals in both
13
departments and restore a normal work environment in the UCDMC PO&M
14
Department.
15
16
17 JerryWaszczuk
18 Associate Development Engineer
19
300. Shortly after Plaintiff sent his message to Vice Chancellor Pomeroy cc’d to many
20
other University of California decision makers, Vice Chancellor Pomeroy was forced to resign due to
21
illegal medical experiments conducted under Pomeroy’s supervision for years by two UC Davis Medical
22
Center Dutch neurosurgeons, Dr. J. Paul Muizelaar and Dr. Rudolph J. Schrot, which caused
23 several patients’ deaths. So far, Plaintiff, with his words about the UC Davis Medical Center
24 National Socialism doctrine, was taking into consideration inhumane, illegal medical
25 experiments on humans in the Nazi concentration camp Auschwitz conducted on camp inmates
26 by the notorious Dr. Joseph Mengele.
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2
3
4
access to the university e-mail, with accusations that Plaintiff was sending inappropriate content
5
13 ass.”
14 303. Apparently, the UC Davis Medical Center Plant Operation and
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304. The conclusion of this chapter is that the Defendant with Liberty
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4 December 2011
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14 Danesha Nichols on December 12, 2011. Four years after this, Plaintiff is still in disbelief that it
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from sick leave unconditionally without Plaintiff’s physician’s permission and place Plaintiff on
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4 health significantly deteriorated due to the situation with Plaintiff’s employment and denial by
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private computer hard drives.
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21 Nichols.
23 hard drives Plaintiff made reference to were deployed outside of the HVAC shop due to the
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315. Plaintiff installed his private hard drives in the company computers as a
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4 private hard drives in two company PC computers but also purchased at his own expense a top-
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Plaintiff finally convinced two of his supervisor to bring used computers from the warehouse that
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21 his office.
23 December 22, 2011.
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person who disclosed to Plaintiff during the conversation that he had previously worked as a
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4 regretted that he got himself into this meeting because of her cover-up for management
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investigatory leave or administrative leave with pay. Plaintiff lost track of whether he was on
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January 2012
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knowledge, and for an unknown reason, from Associate Development Engineer to Programmer I,
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4 California. The Associate Development Engineer, under UC Davis Title Code 7182, was an
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2009 Settlement-Agreement, and work in a different shop.
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21 committed.
23 Defendant ignored the fact that according to the February 2009, the Settlement-Agreement,
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25
Order.
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January 18, 2012, that Plaintiff had been de-enrolled by the Defendant from the medical, dental
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4 to quit, and asked Mr. Peklar to immediately reinstate Plaintiff’s medical Benefits. Plaintiff
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problem as well.
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HR Benefits Manager, John Peklar and requested to cancel Plaintiff’s Supplemental
14
23 332. At the end of January 2012, Plaintiff learned that his long-time physician,
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28 February 2012

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problem.
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16 of California.
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337. . Plaintiff’s meeting with HR Labor Relations Manager, Mike Garcia, took
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4 Plaintiff his annual wages in a lump sum until Plaintiff is eligible for full Social Security
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subsequently went to the EEOC’s San Francisco Office for an interview, Plaintiff was dismayed

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to Plaintiff.
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343. Defendant were perfectly aware that Plaintiff would be outraged by any
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14 Plaintiff.
18 same Department in which Plaintiff worked.
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March 2012
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4 On the contrary, in July 2011, Plaintiff sent two complaint letters to UC Davis Chief Counsel
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California, behalf.
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4 Plaintiff also informed the UC Davis chief counsel that UC Davis Medical Center Plant
5
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from the HR side.
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21 Shop Supervisor Dorin Daniluc’s special relationship with two corrupted UC Davis Medical Center
22 directors, perhaps Robert Taylor and Shelton Duruisseau Ph.D, who besides holding director
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2 Center.
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reports.
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7 May 2012
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19 May 2012 – May 7, 2012 Events

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1 at all.
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helpful.
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May 11, 2012
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Jaroslaw Waszczuk
524 Swallow Lane
14 Lodi, CA 95240
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3 action.
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19 Charles Witcher
21 Skelly Decision
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and William Buckans
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21 on May 29, 2012.
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16 trauma unit.
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leave.
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3 JUNE 2012
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electronic mail.
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18 Davis Police.

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18 subordinate.

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Death Squad.”
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3 No. 11.
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work and live.
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1 call on May 31, 2012.
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direct subordinate.
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March 13, 2011.
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July 2012
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16 reminder.
17 Jerry”
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AUGUST 2012
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15 to Kenney Diede
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Department.
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17 questions.
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15 plumber.”
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Mr. Waszczuk,
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Division.
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enjoyment for life.
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12 SEPTEMBER 2012
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of employment.
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20 Office)
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to Hugh Parker:
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17 2012.
20 2012, from 9 to 10 AM.
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Unit.
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misunderstandings.)
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Dear Charles:
8
INTRODUCTION
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17 issues.
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company premises.
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21 business.
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THE COMPLAINTS
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experience.
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Regards,
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Jaroslaw Waszczuk
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11 Community.
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9 communications:
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15 to Suspend.
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signage.
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emergency.
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3 916-734-1555.”
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2012.
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3 precautions, etc.
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13 2012.
17 OCTOBER 2012
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4 expenses.
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Jaroslaw Waszczuk
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3 Sincerely,
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19 medicines.
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Sincerely,
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Jerry “
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will.
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13 October 1, 2012
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Dear Mr. Waszczuk:
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27 Sincerely,
28 Michael Tyler

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Dear Mr. Waszczuk:

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017-11/12
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assigned.
26 Sincerely,
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27 UCDMC premises.
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Travis,
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16 Respectfully,
17 Dereck
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3 Cole.
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NOVEMBER 2012
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No. # 11.
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16 2012 chapter.
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4 November 7, 2012.
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20 Sincerely,
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two hard drives.
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7 Squad’”
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Sincerely,
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Jaroslaw Waszczuk
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23 Squad.’”
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2012, at 9:00 A.M.
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workers.
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2 to Waszczuk:
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7 Mr. Waszczuk,
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9 Thank you.
10 Management
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Patrick Putney.
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18 fraud.
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4 next month.
8 Sincerely,
9 Jaroslaw Waszczuk
10 Enclosed:

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17 Plaintiff wrote:
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Squad”
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Best Regards,
13
Jerry Waszczuk
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17
18 DECEMBER 2012

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Dear Jerry:
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3 in US Mail today.
4 Sincerely,
5
Charles Witcher
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Sincerely
1
2 UCDHS
December 5, 2012
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“December 3, 2012
14 Travis Lindsey
Manager
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should be upheld.
10 Sincerely,
cc: Charles Wichter
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employment.
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Hi Gina:
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17 Jerry

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Gina”
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JANUARY 2013
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Policy PPSM 70.
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Resolution.
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20 service.

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employment.
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187036.
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2 came.”
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16 by the UC System

22 Policies.”
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19 Sincerely,
Jaroslaw Waszczuk
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alleged as follows.
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7 MANAGAMENT
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2 My Response :
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Stephen Chillcot:
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16 to lead.
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3 his employment.
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4 December 5, 2012.
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16 February 2013
17
19 Case No. 03-PPS-014-12/13

25

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12 Sincerely,
Gina Harwood, SPHR
Proof of Service
Charles Witcher
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1 “CONCLUSION

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service.”
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MARCH 2015
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4 university.
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9 ‘March 7, 2013
One Shields Avenue
12 Davis, CA 95616
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8 Best Regards
Jaroslaw Waszczuk
10

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Dear Mr. Waszczuk:
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Page 247 of 295
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6 Sincerely,
7 Daniel M. Dooley
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19 decision.
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APRIL 2013
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24 and others.
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26 April 3, 2013


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2 on April 2, 2013
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10 Misconduct.
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16 Best Regards,
Jaroslaw Waszczuk
18
MAY 2013
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May 5, 2012
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7 4800 2nd Avenue,
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10 Mr. Boyd:
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14 Policy.
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18 Page No. 1
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environment.”
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6 See you in court.
Jaroslaw Waszczuk
7 Enclosure:
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representation.
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operator” --

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4
2006-07 4/27/2007 McGRATH
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13 DECEMBER 2013
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March 2014
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1 in 2 006 –20 08 a nd 20 11– 201 2 .
3 Rosenberg wrote:
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was:
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the open market .
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17 After the Letter
21 attention from the huge profits generated by the Central Plant from electrical energy sale
22 disclosed which was disclosed by UC Davis Assistant Vice Chancellor Dr. Shelton Du ru isseau
23 in h is in te rvie w with Do nna Ramo s.
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25 Judge.”

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December 1991.
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termination .
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April 2014
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16 Operator (ISO).
V. CONCLUSION
17
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4 in February 2009.
5

7

17 2009.
25 $80,922.00.
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25 length herein.
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16 Plaintiff.
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19 attorney fees.
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Page 279 of 295
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5 to do.
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until year 2017.
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7 Defendant.
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Benefits.
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6 Security income.
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62.
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pay.
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8 officers.
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9 amount of $100,000.
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regulations
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The Violation and Breach of Settlement –Agreement by the Defendant in Regards to § No.
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7 and § No 8. of the settlement –agreement
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Plaintiff observed.
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8 DATED: June 12, 2021

9
10 By: _________________________
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EXHIBIT # 45
CIV-120
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address):
IN PRO PER FOR COURT USE ONLY
Jaroslaw Waszczuk; IN PRO PER
2216 Katzakian Way, Lodi CA 95242
TELEPHONE NO.; (209) 663-2977 FAXNO.; (209)370-8281 FILED
E-MAIL ADDRESS: jjw1980(g!ive.com Superior Court Of CaVifomfa,
ATTORNEY FOR (Name): JarOSlaW WaSZCZUk

STREET ADDRESS; 720 9th Street
CITY AND ZIP CODE; Sacramento 95814
BRANCH NAME; Biii , Depu^
C a s B Numbur:
PLAINTIFF/PETITIONER: Jaroslaw Waszczuk
DEFENDANT/RESPONDENT: The Rcgcnts of the University of Califomia 34-2013-0015S47S
NOTICE O F E N T R Y O F DISMISSAL AND P R O O F O F S E R V I C E CASE NUMBER;
I I Personal Injury, Property Damage, or Wrongful Death
CZH Motor Vehicle [!• Other
I I Family Law 34-2013-00155479-CU-WT-GDS
1 1 Eminent Domain
rZJ other (specify): Wrongful Termination -Employment
TO ATTORNEYS AND PARTIES WITHOUT ATTORNEYS: A dismissal was entered in this action by the cJSrlâs shown on the
Request for Dismissal. (Attach a copy completed by the clerk.)
Date:
Jaroslaw Waszczuk N
(TYPE OR PRINT NAME OF I I ATTORNEY • I • 1 PARTY VtflTHOUT ATTORNEY) |f (SIGNATURE)
PROOF OF SERVICE
1. I am over the age of 18 and not a party to this cause. My residence or business address is:
2.1 >^ I I am a resident of or employed in the county where the mailing occurred. I served a copy of the Notice of Entry of
Dismissal and Request for Dismissal by mailing them, in a sealed envelope with postage fully prepaid, as follows:
a. I I I deposited the envelope with the United States Postal Sen/ice.
1} I I I placed the envelope for collection and processing for mailing following this business's ordinary practice with
which I am readily familiar. On the same day conrespondence is placed for collection and mailing, it is deposited
in the ordinary course of business with the United States Postal Service,
c. Date of deposit: 9/30/2015 d. Place of deposit (city and state): L o d i , C A 9 5 2 4 0
e. Addressed as follows (name and address):
Douglas Repel ,350 University AvejSuite 200; Sacramento 95825
3 I I I served a copy of the Notice of Entry of Dismissal and Request for Dismissal by personally delivering copies as shown below:
b. Address at which person served:
c. On (dafe); d. At (time):
I served a copy of the Notice of Entry of Dismissal and Request for Dismissal by electronically sen/ing copies as shown below
(complete if electronic service is used based on a court order or agreement of the parties):
b. Electronic service address of person served:
c. On (date): d. At(f/me).-
e. Electronic service address from which I served the documents:
I I Proof of electronic service is attached.
5- I—I Proof of service on additional parties is attached.
Date: September 3 0 , 2 0 1 5
Irena Waszczuk ^
(TYPE OR PRINT NAME) (SIGNATURE OF DECLARANT) Page 1 of 1
Form Adopted for Mandatory Use Code of Civil Procedure, § 581 et seq.;
Judicial Council of Califomia NOTICE OF ENTRY OF DISMISSAL Cal. Rules of Court, mle 3.1390
CIV-120 [Rev. January 1,2012] www.courts.ca.gov
AND PROOF OF SERVICE
CIV-110
ATTORNEY OR PARTY wn>IOUT ATTORNEY (Wame, State Bar number, and address)
FOR COURT USE ONLY
Jaroslaw Waszczuk ; IN PR'O PER
2216 Katzakian Way , Lodi CA 95242
TELEPHONE NO: ( 2 0 9 ) 6 6 3 - 2 9 7 7 FMtÔ. (Optional): (209)370-8281
E-MAIL ADDRESS (Optional):jjw1980@live.com
ATTORNEY FOR (Wame;: Jaroslaw
Waszczuk
STREET ADDRESS: ^ 2 0 9 t h S t r e e t OCT - 1 2015
MAILING ADDRESS 720 9th street
CITY AND ZIP CODE: Sacramento, CA 95814
BRANCH NAME: Civil By R. CASTILLO
Deputy Clerk
PLAINTIFF/PETITIONER: Jaroslaw Waszczuk; IN PRO PER
DEFENDANT/RESPONDENT: The Regents of the University of California
REQUEST FOR DISMISSAL CASE NUMBER: 34-2013-00155479
A conformed copy will not be returned by the clerk unless a method of return is provided with the document.
This form may not be used for dismissal of a derivative action or a class action or of any party or cause of action in a
class action. (Cal. Rules of Court, rules 3.760 and 3.770.)
1. TO THE CLERK: Please dismiss this action as follows:
a. (1) I • I With prejudice (2) j j Without prejudice
b. (1) CZHJ Complaint
Complaint (2) £13 Petition
(3)1 ] Cross-complaint filed by (name): on (date):
(4) I I Cross-complaint filed by (name): on (date):
(5) I I Entire action of all parties and all causes of action
(6) I • ! Other (specify):* Defendants : Charles Witcher, Ann Madden Rice, Dorin Daniliuc , Patrick Putney
2. (Complete in all cases except family law cases.)
The court I I did I «^ I did not waive court fees and costs for a party in this cas|. (This infonnation m^jylfe obtained from
the clerk. If court fees and costs were waived, the declaration on the back off/?/;
Date: September 30, 2015
J^rpglavy Wqsai?uk . . . . .
(TYPE OR PRINT NAME OF I I ATTORNEY j • | PARTY WITHOUT ATTORNEY) '(SIGNATURE)
*lf dismissal requested is of specified parties only of specified causes of action Attomey or party without attorney for:
only, or of specified cross-complaints only, so state and identify the parties, I I Plaintiff/Petitioner I *^ I Defendant/Respondent
causes of action, or cross-complaints to be dismissed.
Cross-Complainant
3. TO THE CLERK: Consent to the above dismissal is hereby given.'
Date: 9/30/2015
Jaroslaw Waszczuk
(TYPE OR PRINT NAME OF j | ATTORNEY | • | PARTY WITHOUT ATTORNEY)
' If a cross-complaint - or Response (Family Law) seeking affirmative Attomey or party without attorney for:
relief - is on file, ttie attomey for cross-complainant (respondent) must
sign this consent if required by Code of Civil Procedure section 581 (I) I I Plaintiff/Petitioner I I Defendant/Respondent
orO).
I I Cross-Complainant
(To beafmpleted by clerk) _
4. I Ir I Dismissal entered as requested on (dafej: ULI ~ I tUID
5 I I Dismissal entered on (date): as to only (name):

6. I I Dismissal not entered as requested for the following reasons (specify):
7. a. I I Attorney or party without attomey notified on (date):

b. I I Attorney or party without attorney not notified. Filing party failed to provide
I I a copy to be conformed I I means to return conformed copy
Date: OCT - 1 2015 Clerk, by , Deputy

Page 1 of 2
Form Adopted for Mandatoiy Use Code of Civil Procedure, § 581 et seq.;
Judicial Council of California EQUEST FOR DISMISSAL Gov. Code, § 68837(c); Cal. Rules of Court, rule 3.1390
CIV-110 [Rev. Jan. 1,2013] www.courts.ca.gov
CIV-110
PLAINTIFF/PETITIONER: Jaroslaw Waszczuk ; IN PRO PER CASE NUMBER:
DEFENDANT/RESPONDENT: The Regents of the University of California 34-2013-00155479
COURT'S RECOVERY OF WAIVED COURT F E E S AND COSTS

If a party whose court fees and costs were initially waived has recovered or will recover $10,000 or
more in value by way of settlement, compromise, arbitration award, mediation settlement, or other
means, the court has a statutory lien on that recovery. The court may refuse to dismiss the case until
the lien is satisfied. (Gov. Code, § 68637.)
Declaration Concerning Waived Court Fees

1. The court waived court fees and costs in this action for (name):
2. The person named in item 1 is (check one below):
a- 1 «^ I not recovering anything of value by this action.
b. I I recovering less than $10,000 in value by this action.
c. I I recovering $10,000 or more In value by this action. (If item 2c is checked, item 3 must be completed.)
3.1 I All court fees and court costs that were waived in this action have been paid to the court (check one): I I Yes No
I declare under penalty of perjury under the laws of the State of California that the information above is true afidicorrect.
(TYPE OR PRINT NAME OF | | ATTORNEY [ • | PARTY MAKING DECLARATION) (SIGNATURE)
CIV-110 [Rev. January 1,2013] Page 2 of 2

REQUEST FOR DISMISSAL
EXHIBIT # 47
Jaroslaw "Jerry" Waszczuk
2216 Katzakian Way
Lodi, CA 95242
Phone: 209-339-1982
Cell: 209-663-2977
Fax:209-247-1089
E-mail: jjwl980@live.com
May 3 1, 2015
Via Fax IE-Mail/Certified US Mail
Carmen Angeles
Sedgwick-Litigation Specialist
Sedgwick Claims Management Services, Inc.
1100 Ridgway Loop Rd., Ste. 200
Memphis, TN 38120-4057
Re: Anti-SLAPP Motion approved by Sedgwick CMS Representative Greer Gustavson

Superior Court of California, County of Sacramento, Case No.: 34-2013-001555479, Jaroslaw
Waszczuk v. The Regent of the University of California, and Case No. 34-2013-80001699; Court
of Appeal Case No.: C079254. Jaroslaw Waszczuk v. California Unemployment Insurance
Appeal Board (Respondent) & The Regents of the University of California (Real Party in
Interest) -OPEN LETTER
Dear Ms. Angeles:
My name is Jaroslaw "Jerry" Waszczuk (pronounced Vashchook). I am representing myself in

pro per in the above two listed court cases against the Sedgwick's customer and my former
employer the University of California (UC) and nine individual employees of the UC Davis
Medical Center. The wrongful termination case No. 34-2013-00155479 is the main subject of
this letter.
On December 2, 2014, the UC filed a special motion to strike under the California Anti-SLAPP
Law CCP § 425.16 to strike the first four causes of actions and five individual defendants from
my second amended complaint.
The five individual defendants and UC Davis Health System (UC Davis Medical Center)
employees Human Resources Department Executive Director Stephen Chilcott, Facilities
Director Mike Boyd, HR Benefits and EOE Title IX Manager Cindi Oropeza, HR Investigator
Danesha Nichols, and HR Labor Relation Supervisor Bren Seifert became the subjects to strike
from the second amended complaint by Anti-SLAPP.
1
Letter to Sedgwick CMS -Anti-SLAPP Motion
ORIGINAL
Jaroslaw Waszczuk, In Pro Per
2216 Katzakian Way
Lodi,CA 95242
Phone: 209.663.2977
Fax: 209.787.3131
jjwl980@live.com
Bv D. JOHNSON-MELLADO
DEPUiY CLERK
6
SUPERIOR COURT OF THE STATE OF CALIFORNIA
7
FOR THE COUNTY OF SACRAMENTO
8
10 Jaroslaw Waszczuk Case No. 34-2013-00155479
11 Plaintiff
12
vs. PLAINTIFF'S PEREMPTORY CHALLENGE
13
The Regents of the University of Califomia,
(Code of Civil Procedure § 170.6)
ai
14 Ann Madden Rice, Mike Boyd, Stephen <
Chilcott, Charles Witcher, Danesha Nichols,
15 Cindy Oropeza, Brent Seifert, Patrick Putney, Hearing Date: August 4, 2021
Dorin Daniliuc, and does 1-50 Time: 1:30 p.m.
16 Dept: 53
Complaint Filed: December 4,2013
17 Amended Complaint Fiied: June 16, 2014
Defendants SAC Filed: September 30, 2014
18
19
20
21
I, Jaroslaw Waszczuk, the self-represented Plaintiff in the above-captioned case, declare as
22 follows:
23
The Honorable Shama Hakim Mesiwala, the judge before whom the Defendant's Motion for
24 Summary Judgment or, in the Alternative, the Summary Adjudication regarding the aforesaid matter
25 is pending or to whom the aforesaid motion is assigned, is prejudiced against me. Consequently, I
26 believe that I cannot have a fair and impartial hearing for this motion before this Judge.
27 //
28 //
- 1 -
PLAINTIFF'S PEREMPTORY CHALLENGE
//
I declare under the penalty of perjury under the laws of the State of Califomia that the
foregoing is true and correct and that this declaration was executed on June 28, 2021, in
Lodi, Califomia.
Jaroslaw Waszczuk
Plaintiff, In Pro Per
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
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- 2 -
Proof of Service bv US Mail, FAX and E-mail
2 Re: Case : Jaroslaw Waszczuk v. The Regents of the University of California- Case No.: 34-
2013-00155479; 3DCA Case Waszczuk v. Regents o f Univ. o f CaL, C079524 (Cal. Ct.
3
App. Oct. 10, 2017)
4
I, IRENA WASZCZUK the undersigned, declare that 1 am over 18 years of age and
5
not a party to the within cause; my address is 2216 Katzakian Way, Lodi, CA. 95242. On
6 Jime 28, 2021,1 served a true copy of the attached each ofthe following,
By placing the same copy in an envelope or envelopes addressed respectively as follows:
7 PLAINTIFF'S PEREMPTORY CHALLENGE
8
Lindsay A, Goulding by Fax 916.927.3706ande-maillgoulding@porterscott.com
9 PORTER/SCOTT LAW FIRM
10
11
Clerk ofthe Sacramento Coimty Superior Court U.S Mail
12
Department 53 - Hon. Shama Hakim Mesiwala
13 813 6th Street, 2nd Floor
14
15 Clerk of Court of Appeal, Third Appellate District U.S Mail

914 Capitol Mall
16 Sacramento, CA 95814
17
18
I declare under penalty of perjury of the laws of the State of Califomia that the
19
foregoing is true and correct. Executed on June 28, 2021 , at Lodi CA
20
21
22 IRENA WASZCZUK
23
24
25
26
27
28
- 3 -
1
10
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15
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18
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- 4 -
Ftft]'Prvmn
- 1. ' . J L_ i : !
'••^^ m muQH DROP im

^"2/JUN 28 Fn k: 13
USCA No. 20-1407 USTC No. 23105–18 W
UNITED STATES COURT OF APPEALS

FOR THE DISTRICT OF COLUMBIA CIRCUIT
333 Constitution Avenue, NW
Washington, DC 20001-2866
Jaroslaw Janusz Waszczuk

Plaintiff-Appellant
v.
Commissioner of Internal Revenue Service

Defendant-Appellee
ON APPEAL FROM THE UNITED STATES TAX COURT
APPELLANT-PETITIONER’S MOTION TO RECALL THE MANDATE,

REINSTATE THE APPEAL, AND REOPEN THE CASE
Jaroslaw Janusz Waszczuk, Per Se

2216 Katzakian Way
Lodi, CA 95242
Phone: 209-687-1180
Motion to Recall Mandate and Reinstate the Appeal

I.
INTRODUCTION
Pursuant to Federal Rule of Civil Procedure 60 (a),(b)(3)(4)(6), Appellant-
Petitioner Jaroslaw Waszczuk (pronounced “Vashchook,” hereafter “Waszczuk”),
moves this Court by this Motion to recall the Mandate issued on September 19, 2022
(EXHIBIT #1), reinstate the appeal, and reopen the case USCA No. 20-1407, which
was dismissed by the Court’s error in claiming that the Case lacks a subject matter
jurisdiction under 26 U.S.C. § 7623(b)(4).
Waszczuk’s appeal was wrongfully dismissed based on the opinion in Mandy
Mobley Li v. Comm’r of Internal Revenue, 22 F.4th 1014 (D.C. Cir. 2022), see
https://casetext.com/case/mandy-mobley-li-v-commr-of-internal-revenue, in which the
Court ruled for the dismissal of this appeal for a lack of subject matter jurisdiction
under 26 U.S.C. § 7623(b)(4) and remanded it to the Tax Court with instructions to do
the same. The Court dismissed the Li appeal due to a lack of jurisdiction after
reviewing the Cooper v. Comm’r, T.C. Memo. 2015-72 (U.S.T.C. Apr. 8, 2015),
https://casetext.com/case/cooper-v-commr-19, and Lacey v. Comm’r, 153 T.C. No.
8 (U.S.T.C. Nov. 25, 2019), https://casetext.com/case/lacey-v-commr-1. The Court
concluded that Cooper and Lacey were wrongly decided by the Tax Court, which
held that it lacked jurisdiction to hear appeals from threshold rejections of

whistleblower award requests; thus, the Li case decided the fate of the Waszczuk
appeal from the June 4, 2020 U.S. Tax Court decision, which granted the IRS
Commissioner’s Motion for Summary Judgment in Waszczuk v. Comm’r, T.C.
Memo. 2020-75 (U.S.T.C. June 4, 2020), see
https://casetext.com/case/waszczuk-v-commr.
The Commissioner informed Waszczuk yesterday that will file opposition to the
Waszczuk’s motion
II.
PROCEDURAL AND FACTUAL HISTORY OF THE CASE JAROSLAW
WASZCZUK V. COMMISSIONER OF THE INTERNAL REVENUE SERVICE,
CASE NO . USCA NO. 20-1407
A. Waszczuk’s Initial (IRS Form 2011) Claim Submitted to the IRS

Whistleblower-ICE Office
On March 23, 2016, Petitioner submitted his initial claim (No. 2016007481) for
award (IRS Form 2011) to the Whistleblower-ICE Office (WBO-ICE) in Ogden, Utah,
alleging that his former employer, the University of California’s UC Davis Medical
Center (UCDMC), located in Sacramento, California, committed tax evasion or fraud
in equaling millions of dollars due to the illegal generation and sale of electrical
energy. This was done in conspiracy with State of California government officials or
agencies, the Sacramento Municipal Utility District (SMUD), the California

Independent System Operator (CAISO), and the California Power Exchange (Cal-PX),
thus violating the Provisions of Section 501c(3) of the Internal Revenue Code of 1954.
https://www.scribd.com/document/476776874/UTC-20160323-IRS-
WHISTLEBLOWER-Claim-No-2016-00748
On August 3, 2018, Waszczuk submitted his update of the 2016 claim to the IRS
WBO. This update, instead of being included or combined with the March 23, 2016
claim, No. 2016-007481, was relabeled as Claims No. 2018-012118, 2018-012139,
2018-012141, and 2018-0121419 on August 24, 2018 which were then denied on
October 23, 2018 without any review or investigation by the WBO-ICE
B. U.S. Tax Court Petition Filed on November 21, 2018,

Jaroslaw Waszczuk v. IRS Commissioner - Docket No.23105-18W
On November 20, 2018, Waszczuk appealed the IRS WBO’s October 24, 2018
decision, which denied him a reward for reporting tens of millions of dollars of tax
EVASION AND FRAUD . In his petition, Waszczuk pointed out that he strongly
disagreed with the WBO in Ogden, Utah and that nothing was speculative in his claim.
Waszczuk was a direct witness to the unlawful generation and sale of electricity and
the millions of dollars’ worth of related tax evasion committed by the UC Regents
between June 1999 and 2012 by the unlawfully operated 27-MW cogeneration power
plant, which was built for the sole purpose of illegally selling power for millions of
dollars in tax-free profit. Waszczuk backed his claim with documents he discovered in
the Federal Energy Regulatory Commission and other sources, including direct copies
4

of reports on the unlawful power generation and sale by the UCDMC’s cogeneration
plant in violation of provisions of Section 501c(3) of the Internal Revenue Code of
1954, in addition to violations of the Public Utility Regulatory Policies Act of 1978
(PURPA) and the requirements set in 18 C.F.R. for efficiency and the use of energy
output. The plant was also falsely certified as a Qualified Facility (QF), pursuant to 18
C.F.R. § 292.20 requirements, Federal Power Act 16 U.S.C. § 824d(a), California
Public Utilities Code Section 218.5, State of California Unfair Business Competition
law, and Business and Professions Code § 17200.
On June 4, 2020, the Petitioner was served with a U.S. Tax Court Memorandum
Opinion and Order and Decision, Waszczuk v. Commissioner, T.C. Memo. 2020–75
(U.S.T.C. June 4, 2020), which was based on false pretenses and reasoning and granted
the Respondent’s Motion for Partial Summary Judgment without having an
administrative record on file, and sustaining the October 24, 2018 IRS WBO’s
decision, which denied the whistleblower award to Waszczuk.
On June 29, 2020, Waszczuk filed a Motion to Vacate or Revise the Decision
of the Memorandum Opinion and Order and Decision (UTC Rule 162) in Waszczuk
v. Commissioner, T.C. Memo. 2020–75 (U.S.T.C. June 4, 2020). The Motion was
denied by the U.S. Tax Court on June 30, 2020, see
https://www.scribd.com/document/476774356/UTC-20200629-ORDER-DENIED-
Motion-to-Vacate.
5

On July 15, 2020, Waszczuk filed a Motion for Reconsideration for Findings
or Opinion and Order and Decision (UTC Rule 161) in Waszczuk v. Commissioner,
T.C. Memo. 2020–75 (U.S.T.C. June 4, 2020). The Motion was denied by the U.S.
Tax Court on July 17, 2020.
C. Waszczuk’s October 7, 2020 Appeal filed in the U.S. Court of Appeals

for the District of Columbia Circuit
On October 7, 2020, Waszczuk filed in the U.S. Court of Appeals for the
District of Columbia Circuit a NOTICE OF APPEAL seeking a review of the
decision by the U.S. Tax Court in USTC-23105-18. The appeal was assigned USCA
Case Number: 20-1407. On June 18, 2021, the case was fully briefed.
On September 15 , 2021, the Court issued the PER CURIAM ORDER on the
court’s own motion, which informed Waszczuk that his case would be held in
abeyance pending the court’s disposition of Li v. Commissioner of Internal Revenue,
No. 20-1245 (D.C. Cir.), which raised the issue of whether the court had jurisdiction
to review the Tax Court’s order sustaining a final determination made under I.R.C.
§ 7623(a). The parties were directed by the order to file motions to govern future
proceedings within 30 days of the court’s disposition of the case unrelated to
Waszczuk’s, Li v. Commissioner of Internal Revenue, Case No. 20-1245.

On September 22, 2021, the Appellee in the Li case, the Commissioner of
the Internal Commissioner Service, represented by attorneys Bruce R. Ellissen
and Matthew S. Johnshoy from the U.S. Department of Justice, Tax Division
(DOJ) filed a reply to the Orrick, Herrington & Sutcliffe LLP attorneys’ amicus
curiae brief, repeating the conclusion from Amicus Curiae brief : “This Court
should dismiss this appeal for lack of jurisdiction based on the Tax Court's
lack of jurisdiction under § 7623(b)(4)”
On October 1, 2021, Waszczuk filed a motion to vacate the September 15, 2020
Court PER CURIAM ORDER. Waszczuk’s motion was denied on December 8,
2021.
On January 11, 2022, the Court issued an opinion on Mandy Mobley Li v. Comm’r
of Internal Revenue, 22 F.4th 1014 (D.C. Cir. 2022), in which it dismissed Li based on
an amicus brief filed by two attorneys, Robbie Manhas and Robert M. Loeb, from
Orrick, Herrington & Sutcliffe LLP (Orrick) based in San Francisco, and Li v.
Commissioner of Internal Revenue Service Case No. 20-1245 as amicus curiae. On
September 1, 2021, these attorneys filed their amicus curiae brief in the D.C. Circuit,
advising the court that it lacked jurisdiction in Li and the case must be dismissed.
The opinion in Li concluded with the words:

For the reasons set forth above, we dismiss this appeal for lack of
subject matter jurisdiction under 26 U.S.C. § 7623(b)(4). We
remand to the Tax Court with instructions to do the same.
So ordered.
On June 1, 2022, the Court PER CURIAM ORDER granted to the
Commissioner a motion to dismiss and Waszczuk’s appeal was dismissed for lack
of subject matter jurisdiction under 26 U.S.C. § 7623(b)(4), contrary to the
September 15, 2021 Court PER CURIAM ORDER stating that Waszczuk’s case be
held in abeyance pending the court’s disposition of Li v. Commissioner of Internal
Revenue, No. 20-1245 (D.C. Cir.).
On June 10, 2022, Waszczuk filed a PETITION FOR REHEARING, styled
as a notice of objection combined with a MOTION FOR RECONSIDERATION of
the June 1, 2022 Order, followed by Waszczuk’s June 12, 2020 PETITION FOR
REHEARING en banc.
On August 30, 2022, the Court denied Waszczuk’s PETITION FOR
REHEARING, MOTION FOR RECONSIDERATION & PETITION FOR
REHEARING en banc.
Amicus Curiae Attorney from Orrick ‘s Loeb’s unusual activities in the Li
v. Commissioner of Internal Revenue, No. 20-1245 (D.C. Cir.) case and his
simultaneous representation of the solar power producers Broadview Solar LLC and
Broad Reach Power in the Federal Energy Regulatory Commission (FERC) and
8

D.C. Circuit Court case Solar Energy Industries Association (“SEIA”) v. the Federal
Energy Regulatory Commission Case USCA #21-112, led me to the submission on
September 3, 2022 of the New Application for Award for Original Information
(IRS Form 211 whistleblower claim Tax Evasion and Fraud aimed at my former
employer , the University of California due to violation of exempt status IRC 501
(c) ( 3) . Purchase and resale of solar power .
https://www.scribd.com/document/600581546/09-03-2022-IRS-WBO-ICE-
FORM-211-APPLICATION-FOR-AWARD-Polish-Refugee-v-University-of-
California-White-Collar-Crime
On September 5, 2022, Waszczuk filed a MOTION TO STAY MANDATE.
On September 19, 2022, the Court denied Waszczuk’s MOTION TO STAY
MANDATE and issued a MANDATE dismissing Waszczuk’s APPEAL.
On February 1, 2023, U.S. Tax Court Chief Judge Kathleen Kerrigan issued the
following Court Order:
ORDER
In accordance with the mandate of the United States Court of
Appeals for the District of Columbia Circuit, issued September 19,
2022, it is ORDERED that this case is assigned to Judge Joseph
Robert Goeke for the purpose of conducting any further
proceedings pursuant to the above-referenced appellate mandate.
On February 2, 2023, in response the U.S. Tax Court order, Waszczuk filed a
Motion to Stay Proceedings -Re: Mandate of the United States Court of Appeals for

the District of Columbia Circuit, (USCA) Issued September 19, 2022. The motion
was denied by the U.S. Tax Court that same day. A copy of the motion was also filed
that day in the USCA.
https://www.scribd.com/document/672270388/02-02-2023-USTC-Petitioners-
Motion-to-Stay-Proceeding-Stay-of-Mandate-Case-No-23105-18-W
The Whistleblower Office in Ogden , Utah is silent and did not respond to Waszczuk
IRS 211 Form submission .
III.
ARGUMENT
A. The Court improperly and with bias and prejudice dismissed

Waszczuk’s appeal solely on the Mandy Mobley Li v. Comm’r of Internal
Revenue, 22 F.4th 1014 (D.C. Cir. 2022) Opinion, without reviewing
Waszczuk’s case.
As Waszczuk pointed out to the Court in his briefs and pleadings, this case
was dismissed based on a misleading and deceptive amicus curiae brief filed on
September 1, 2021 by Manhas and Loeb, who were serving as amicus curiae. The
brief was nothing but interference and meddling in the judicial process, which led
to the January 11, 2022 issuance by the Court an opinion in Mandy Mobley Li v.
Comm’r of Internal Revenue, 22 F.4th 1014 (D.C. Cir. 2022) that never should
have been issued and which caused the blunt dismissal under false pretenses of
Waszczuk’s case, by the June 1, 2022 Court Order which stated:
10

ORDERED that the motion to dismiss be granted and the

appeal be dismissed for lack of subject matter jurisdiction
under 26 U.S.C. § 7623(b)(4). See Li v. Comm’r of Internal
Revenue, 22 F.4th 1014, 1017 (D.C. Cii. 2022). The case is
hereby remanded to the Tax Court with instructions to do the
same.
Waszczuk’s Case, 20-1407, was dismissed when the two USCA appeals were
pending with same subject matter jurisdiction as Waszczuk’s case under 26 U.S.C.
§ 7623(b)(4). Waszczuk was consequently urging and begging the Court in his June
1, 2022 PETITION FOR REHEARING, MOTION FOR RECONSIDERATION of
his June 12, 2020 PETITION FOR REHEARING en banc and MOTION TO STAY
MANDATE filed on September 5, 2022 not to dismiss his appeal and to place it in
abeyance until Lissack v. Comm’r of Internal Revenue, No. 21-1268 and Villa-Arce
v. Comm’r of Internal Revenue, No. 22-1006 were decided.
B. Lissack v. Comm’r of Internal Revenue, No. 21-1268 (D.C. Cir. May 26,
2023) and Villa-Arce v. Comm’r of Internal Revenue, No. 22-1006 (D.C.
Cir. May 26, 2023), issued on May 26, 2023
Contrary to Li v. Comm’r of Internal Revenue, 22 F.4th 1014, 1017 (D.C. Cii.
2022), in the Lissack v. Comm’r of Internal Revenue, No. 21-1268 (D.C. Cir. May
26, 2023) opinion, the Court ruled in Discussion “A. The Tax Court had
jurisdiction” that U.S. Tax Court had and has the power to review appeals of WBO
decisions by de novo jurisdiction over the subject matter jurisdiction under 26 U.S.C.
11

§ 7623(b)(4), or in general 26 U.S.C. § 7623. The Court basically ruled that the
amicus curiae brief filed on September 1, 2021 by Manhas and Loeb and Li v.
Comm’r of Internal Revenue, 22 F.4th 1014, 1017 (D.C. Cii. 2022) were frauds
created for the sole purpose of dismissing Waszczuk’s case, which has merits quite
different the Li, Lissack, and Villa-Arce cases. Waszczuk’s case is about an
enormous multi-million-dollar tax evasion and fraud committed by a public entity
with a $40 billion annual budget, the University of California (The Regents), acting
in conspiracy and collaboration with SMUD and CAISO. Further, they disregarded
and violated the university’s tax-exempt status under IRC 501(c)(3) and the State of
California Taxation Code. The Regents, since 1998, have violated every possible
state and federal law applicable to the operation of the cogeneration plant facilities,
including but not limited to PURPA requirements set forth in 18 C.F.R.
§§292.203(b) and 292.205 for the operation, efficiency, and use of energy output,
which mandated QF status, (pursuant to 18 C.F.R. §292.20 requirements; the
Federal Power Act, 16 U.S.C. §824d(a); the California Public Utilities Code
Section 218.5; the Unfair Competition Law of California; and Business and
Professions Code §17200.
C. Why the Mandate Issued by USCA on September 19, 2022 Must be

Recalled and Waszczuk’s Appeal Must Reinstated
12

The First most important reason why the Court shall and must recall the
mandate and reinstate Waszczuk’s appeal are the opinions in Lissack v. Comm’r
of Internal Revenue, No. 21-1268 (D.C. Cir. May 26, 2023) and Villa-Arce v.
Comm’r of Internal Revenue, No. 22-1006 (D.C. Cir. May 26, 2023), issued on May
26, 2023.
Both opinions affirmed that the U.S. Tax Court had and has jurisdiction to
review WBO decisions in de novo subject matter jurisdiction under 26 U.S.C. §
7623(b)(4).; thus, USCA also has the power to do the same.
In Sargent v. Columbia Forest Products, Inc., 75 F.3d 86 (2d Cir. 1996) the
Court held:
Our power to recall a mandate is unquestioned. See generally 16

Charles A. Wright et al., Federal Practice and Procedure Section(s)
3938 (1977). The power "apparently originated in the inherent
power of all federal courts to set aside any judgment during the
term of court at which it was entered." Id. at 276. It "exists as part
of the court's power to protect the integrity of its own
processes," Zipfel v. Halliburton Co., 861 F.2d 565, 567 (9th Cir.
1988), and is analogous to the power conferred on district courts
by Fed. R. Civ. P. 60(b).
Furthermore , same opinion held :
One circumstance that may justify recall of a mandate is "[a]

supervening change in governing law that calls into serious
question the correctness of the court's judgment." McGeshick v.
Choucair, No. 92-3445, 1995 WL 738986, at *1 (7th Cir. Dec. 14,
1995); see also Bryant v. Ford Motor Co., 886 F.2d 1526 (9th Cir.
13

1989), cert. denied, 493 U.S. 1076 (1990); Zipfel, 861 F.2d at 567-
68; Davis v. Lawrence-Cedarhurst Bank, 206 F.2d 388, 389 (2d
Cir.), cert. denied, 346 U.S. 877 (1953).
In this case the law did not change . Only Amicus Curiae Brief Attorneys from
Orick’s wanted to change law because the Orick law firm notoriously represents
Waszczuk’ former employer, the University of California against the whistleblowers
. Waszczuk is curious how much The Regents paid to these two Amicus Curiae brief
attorneys Robbie Manhas and Robert M. Loeb for their criminal misconduct to
eliminate Waszczuk’ whistleblower case from USCA. Attorney Loeb involvement
in the Li case and same time his involvement in the
The Second most important reason why the Court shall and must recall the
mandate and reinstate Waszczuk’s appeal is that the June 4, 2020 U.S. Tax Court
decision that granted the IRS Commissioner’s Motion for Summary Judgment in
Waszczuk v. Comm’r, T.C. Memo. 2020-75 (U.S.T.C. June 4, 2020) was issued
under false pretenses and for the wrong reason, so it must be reviewed without bias
and prejudice against Waszczuk by the U.S.C.A, as any other appeal in U.S. Tax
Court would be. As Waszczuk explained to the Court in his pleadings, the Court
exploited the completely irrelevant to the reported tax evasion and fraud the
University of California with the phrase “Unrelated Bussiness Income” (see pp. 2,
3, 5, 12, 13; U.S.T.C. Judge Goeke’s Decision):
14

For her recommendation, the TEGE classifier (University of

California former Executive Vice President Judith Boyette)
reviewed Waszczuk whistleblower information and IRS internal
records of the three targets. The administrative record shows that
the classifier evaluated the whistleblower information and
considered the allegations. She found that the targets were filing
and reporting unrelated business income appropriately and the
IRS records showed amounts reported as unrelated business income
tax. She did not forward the 2018 Form for further investigation or
recommend that the IRS audit the targets.
In Waszczuk’s Motion to Vacate the June 4, 2020 U.S.T.C Order and
Decision, filed on June 29, 2020, he addressed more specifically the University of
California’s unrelated business income. Waszczuk has shown in his Motion to
Vacate that the WBO and Commissioner’s attorneys’ conduct was an
unconscionable plan or scheme of fraud designed to improperly influence the
court in its decision. It was similar to the conduct of Loeb and Manhas, in their
amicus curiae brief filed on September 1, 2021.
The Third most important reason why the Court shall and must recall the
mandate and reinstate Waszczuk’s appeal is that the WBO kept Waszczuk’s
whistleblower case for over two years, hidden and swept under the rug because the
Vice President of the University of California (Waszczuk’s former employer),
Judith Boyette, was appointed Secretary of the Treasury to a three-year term, from
June 2016–June 2019, https://www.hansonbridgett.com/Our-Attorneys/judith-w-
boyette to serve on the IRS Advisory Committee on Tax Exempt and Government
15

Entities (TEGE), and she made sure that Waszczuk’s whistleblower claim would not
surface. When it did surface after two 2 years and 5 months, it was instantly denied
without any review. The Commissioner’s attorneys were perfectly aware of and this
the U.S. Attorney General’s attorneys from the Tax Division and the two amicus
curiae brief attorneys knew how Waszczuk’s WBO claim had been handled and by
whom.
IV
CONCLUSION
In light of the provided facts and arguments outlined in the motion, and after viewing
the attached exhibits, the Court should grant Waszczuk’s motion to recall the
mandate and reinstate the appeal that was wrongfully dismissed with unprecedented
bias and prejudice against him.
Not so long ago Waszczuk concluded as follow his Appellant’s Reply Brief filed
on March 22, 2023 in the State of California Court of Appeal, Third Appellate
District (3DCA) in the cross- connected wrongful termination case Waszczuk v. The
Regents of the University of California Case No. C095488 :
In this, there are no winners. Waszczuk, due to The Regents’

reckless, unlawful, and merciless witch hunts, which resulted in the
termination of his employment on December 5 , 2012 at his
retirement age, has suffered enormous losses exceeding $1 million
in wages and benefits and the devastation of his life. By contrast,
The Regents, since the second witch hunt action aimed at
16

Waszczuk, from March 2011–December 2012, have lost

approximately $200 million in tax-free revenue by not selling to
SMUD surplus power from the UC Davis Medical Center’s
cogeneration plant, after being advised by some unknown
person that Waszczuk would blow the whistle on their shady
power-generation business, a topic about which Waszczuk did
not care at all or have a clue concerning in 2011–2012 when the
witch hunt began.
https://www.scribd.com/document/665932573/03-22-2023-Appellant-s-Reply-
Brief-Waszczuk-v-The-Regents-of-The-University-of-California-3DCA-Case-No-
C095488
The mentioned cross connected case is pending for 10 years and Waszczuk is not
the one who committed the crime by evading taxes. Waszczuk is a victim in this case
who got caught in the white-collar criminal’s crossfire who were fighting for
millions of tax free dollars. The Court should take this fact into consideration.
Respectfully submitted on September 19, 2023.
______________________
Jaroslaw Waszczuk, Per Se.
17

APPELLANT’S MOTION TO RECALL THE MANDATE
contains 3446 words ( less than 5200 word D.C Cir. Rule 27 (a )(2) (B)
The number of lines of monospaced type in the motion is 443
Type text here

Dated September 19, 2023 ________________________________
Jaroslaw Waszczuk, Appellant Pro Se
2216 Katzakian Way

Lodi, CA 95242
Phone: 209-687-1180
Fax: 209-425-0512
18

CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing paper APPELLANT’S MOTION

TO RECALL THE MANDATE was served electronically on September 19, 2023,
to the following recipients:
Richard L. Parker Richard.L.Parker@usdoj.gov
Antony T. Sheehan Anthony.T.Sheehan@usdoj.gov
U.S. Department of Justice

Tax Division, Appellate Section
P.O. Box 502
Washington, DC 20044
United State Tax Court

400 Second Street NW.,
Washington, DC 20217-0002
Dated: September 19, 2023
Jaroslaw Janusz Waszczuk, Appellant Pro Se

206 Katzakian Way
Lodi, CA 95242
Phone: 209.687.1180
Fax: 209.425.0512
19

USCA Case #20-1407 Document #2017907 Filed: 09/19/2023
Filed Page 21 of 25
09/19/22
Jaroslaw Janusz Waszczuk,

Petitioner
v. Docket No. 23105-18W
Document No. 63
Commissioner of Internal Revenue
Respondent
U.S.C.A for the D.C. Circuit mandate issued September 19, 2022
appeal dismissed
USCA
USCACase
Case#20-1407
#20-1407 Document
Document#2017907
#1964780 Filed:
Filed:09/19/2023
09/19/2022 Page
Page22
1 of 1
25
United States Court of Appeals

FOR THE DISTRICT OF COLUMBIA CIRCUIT
____________
No. 20-1407 September Term, 2022

USTC-23105-18 W
Filed On: September 19, 2022 [1964780]
Jaroslaw Janusz Waszczuk,
Appellant
v.
Commissioner of Internal Revenue,
Appellee
MANDATE
In accordance with the order of June 1, 2022, and pursuant to Federal Rule of
Appellate Procedure 41, this constitutes the formal mandate of this court.
FOR THE COURT:

Mark J. Langer, Clerk
BY: /s/
Daniel J. Reidy
Deputy Clerk
Link to the order filed June 1, 2022

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1- Jaroslaw Waszczuk, In Pro Per
2216 Katzakian Way
2 odi, CA 95242
3 '
hone: 209-663-2977 -^,1L E 0/ E
ax: 833-817-780
4 Email: iiwl980(g>live.com AUG 1 3 2021
5 By: '' • .AuMacias
'•Dep'uty-'Clerk
6
7 ' SUPERIOR COURT OF THE STATE OF CALIFORNIA

8 FOR THE COUNTY OF SACRAMENTO
10
11
JAROSLAW WASZCZUK, Case No. 34T2013-00155479
\2 PLAINTIFF,
VS. THE PLAFNTIFF, JAROSLAW
13' WASZCZUK'S, OPPOSITION TO THE
14 CALIFORNIA, ANN MADDEN RICE, bEFENDANTS: MOTIOfJ FOR SUMMARY
JUDGMENT OR, IN THE;ALTERNATIVE,
15 MIKE BOYD, STEPHEN CHILCpTT, SUMiClAkYAb
CHARLES WITCHER, DANESHA
16 DATE: SEPTEMBER 1, 2021
NICHOLS, CINDY OROPEZA, BRENT
17 SEIFERT, PATmCK PUTNEY, DORIN , TIME: 9:00 A . M i ^ !
DANILIUC, AND p(3ES li'50, inclusive; pEPT^TMENT:;54
18
DEFENDANTS. HON. CFIRISTOPHER E. KRUEGER
19 Complaint filed beceniber• 14, 2013
First Ajnended Complaint filed June 16, 2014
20
Second Ajiiended Complaint filed Sept. 30;
21 2014 '
22
. 23
2.4
25
26
27
28
- 1 - .
THE PLAINTIFF'S OPPOSITION TO THE DEFENDANTS' MOTION FOR SUMMARY JUDGMENT
1
TABLE OF CONTENTS
2
^ L INTRODUCTION 1
IL SUMMARY OF ARGUMENT 3
4
in. STATEMENT OF FACTS 4
^ IV. LEGAL DISCUSSION 7
^ A. The Crux of January 2007-April 2007 and April 2011 December 2012 Defendants Adverse
7 Action Against Plaintiff 7
B. Legal Standard 9
9
C. Defendant's Unlawfully Relitigate Dismissed from the Second Amendment Complaint Non
IQ Material Facts as A Material Facts Thus It Mandates Denial of its Motion 9
11 D. The Five Individual Defendants, Stephen Chilcott, Danesha Nichols , Cindy Oropeza ,Brent
Seifert and Mike Boyd II
12
12 E. The May 11 , 2012 Ten Days Suspension Without Pay Violated UC Davis Procedure 62.1
Corrective Action and Employee Performance Review (Evaluation) Policy PPSM 23 Thus
14 WasUnlawftil II
15
F. The Unlawful Termination of Plaintiff Employment with the University of California 15
16
G. The Email Dated September 26, 2012, - Destmction of Evidence by the Defendants..
17
H. Email Dated 09/26/2012 Entitled "Person Unauthorized on Property (Jaroslaw Waszczuk)''
18 Documents marked DEF RPDl 3027 and DEF RPDl 3032 and UC Davis Police Poster with
-^g the Plainfiffs photo and a description on. (EXHIBIT 25) 17
20 I. The Letter of Termination Dated December 5, 2012 19
^•^ J. The Court Has Discretion to Deny Summary. Judgment When a Material Fact Is Established
22 Solely By an Affidavit Made By a Party Who Is a Sole Witness 21
23 K. The Defendants Are Playing Race Card in the Memorandum of Points and Authorities
Memorandum of Points and Authorities in Support of Defendant's Motion for Summary
24 Judgment or, in the Alternative, Summary Adjudication 22
25
L. Defendants Arguments In Memorandum Of Points And Authorities Memorandum Of Points
26 And Authorities In Support Of Defendant's Motion For Summary Judgment Or, In The
Alternative, Summary Adjudication 25
27
M. The Defendants' Separate Statement of Undisputed Material Facts in Support of Defendants'
28
Motion For Summary Judgment or in the Alternative, Summary Adjudication 25
1
THE TRIABLE ISSUE OF MATERIAL FACTS AS TO THE CAUSE OF ACTION
2
.26
3
A. The Six Cause of Acfion T The Violation and Breach
4 Settlement Agreement signed with the Piaintiff by the Regents of the Uniyersity:bf
California or their Agents oh Regents' Behalf. .;.26
5
6 VI. CONCLUSION .27

7
8 VI. PROOF OF SERVICE BY US MAIL ...29
9
VIL INDEX OF EXHIBITS
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25^
26
27
• 28
1 T A B L E OF AUTHORITIES
3
CASES
California ex rel. Lockyer v. Dynegy, Inc., 375 F.3d 831 (9th Cir. 2004) 4
4
Gribin Von Dyl & Associates Inc. v. Kovalsky, 185 Cal.App.3d 653 (Cal. Ct. App. 1986) 7
5
Lockyer State v. All Persons, 152 Cal.App.4th 1386 (Cal. Ct. App. 2007) 8
6
Lipson V. Super. Ct. (1982) 31 Cal.3d 362, 374 9
7
Mann v. Cracchiolo (1985) 38 Cal.3d 18, 35 9
8 Aguilar, supra, 25 Cal. 4th at p. 843 9
9 Colombo v. Kinkle G055823 (Cal. App. Dist. 4, May 16, 2019) 10
10 Bucur V. Ahmad (2016) 244 Cal. App. 4th 175. 185 10
11 Forbes v. County of San Bernardino. 101 Cal.App.4th 48 (Cal. Ct. App. 2002) 16
12
Cedars-Sinai, supra, 18 Cal.4lh at pp. 7/-/3;Temple Community, supra, 20Cal.4th at pp. 474, 476-
13 477.) 16
14 Shelly V. State Personnel Board {\915), 15 Cal. 3d 194 20

Vergos V. McNeal, 146 Cal.App.4th 1387 (Cal. Ct. App. 2007) 20
15
Kim V. Regents of University of California [2000] 80 Cal. App. 4th 160, 165 22,25
16
Rosas V. BASF Corp . (2015) 236 Cal.App.4th 1378. 1392, 187 Cal.Rptr.3d 354 26
17
Soria v. Univision Radio L. A., Inc., 5 Cal.App.5th 570, 583 (Cal. Ct. App. 2016 26
18
Hondo Company V. Superior Court o f Los Angeles County, 67 Cal.App.4th 176, 78 Cal.Rptr.2d
19
855 (CaLApp. Dist.2 27
20 Halbert's Lumber, Inc. v. Lucky Stores, Inc., (supra, 6 Cal.App.4th at p. 1239.): 27
21
22
STATUTES
23
Government Code § 12940(A)
24
California Government Code §§ 8547 et seq 9
25 Code of Civil Procedure, Section 425.16
26 Public Ufilities Regulatory Policies Act of 1978(PURPA) 8
27 Title VI of the Civil Rights Act of 1964 8
28 Civil Code of Procedure §§ 491.110, 708.110, 708.120 8
III
1 Code Civ. Proc, § 437c, subd. (p)(2) 9
2 Code Civ. Proc, § 437c, subd. (c) 21
3 Health and Safety Code, sec. 1278.5,6 ,,.-9,26
4
Pen. Code, § 135 16
UC DAVIS PERSONNEL POLICIES FOR STAFF MEMBERS (PPSM)
5
UC Davis Corrective Action Guide, 2
6
PPSM 62 -Corrective action 2
7
Employee Performance Review (Evaluation) Policy PPSM 23 17,22,23
8
UC Davis Policy PPSM 70
9 UC Davis Policy and Procedure 380-15, 15
10 UC Davis Procedure 62.1: Corrective Action 12
11 UCDHS Discrimination 1616 Policy 12,16
12 University of California Clinical Enterprise Management Recognition Plan 2 ("Plan")
13 Personnel Policies for Staff Members 34 16
14
OTHER AUTHORITIES
15
In re Stein, S245982 (Cal. Mar. 1, 2018) 3
16
Sacramento Metropolitan Air Quality Management District (SMAQMD)
17
Sacramento Superior Court Local Rule 2.1 8
18 Weil & Brown, Cal. Practice Guide: Civil Procedure Before Trial (2013) §10:28 11
19
20
21
22
23
24
25
26
27
28
IV
1 I. INTRODUCTION
2
3
The Plaintiff, JAROSLAW WASZCZUK (hereafter, "Plainfiff), respectfully submits the following
Opposition to the Defendants' (the Regents of the University of California andfiveremaining
4
defendants: Mike Boyd, Stephen Chilcott, Danesha Nichols, Cindy Oropeza, and Brent Seifert
5
(hereafter, "Defendants")) Motion for Summary Judgment or, in the Alternative, Summary
6
Adjudication, in the Second Amended Complaint. The Plaintiffs Opposition to the Defendants'
7
Motion is based on the documents that were produced by the Defendants, in 2015 due to Plaintiffs
8 November 2014 Request for Production of Documents (SET ONE)
9 Defendants' attomey, Douglas Ropel, responded to the Plaintiffs 216 requests for the producfion
10 of documents with thousand of pages of documents some unmarked, and others marked with page
11 numbers and "DEF" or "DEF RPDl." Furthermore Plaintiff's Opposition is based on Plaintiffs
12 Responses to the Defendants' Request for Admissions (SET ONE) (EXHIBIT #1) (Pl.[s]Ex.) Resp.
to Admis.)Defendants' Exhibit C) (Defs.Exh,,) the Plaintiffs Response to the Defendants' Special
13
Interrogatories (SET ONE) Pl.[s] Resp.to Interrog. (Defendants' Exhibit E) , and the University of
14
California (UC) Davis Policies and Procedures, especially the UC Davis Corrective Acfion Guide,
15
based on UC Davis Personnel Policies for Staff Members (PPSM)
16
(https://hr.ucdavis.edu/departments/elr/policies/PPSM). specifically PPSM 62
17 (http://www.hr.ucdavis.edu/Elr/er/corrective acfion/index;html), which was disregarded and
18 despicably violated by the six remaining defendants in the lawsuit. The key target in the Plaintiffs
19 Opposition to the Defendants' Mofion was the Defendants' breach and violation of the January 30,
20 2009 Settlement-Agreement (Defs Exh. K), which is addressed in the sixth, seventh, and eighth
Causes of Action (COA) of the Plaintiffs Second Amended Complaint(SAC) Defs.Exh. A p.58-62
21
22 Compounding the wrongs already inflicted on the Plaintiff, the Defendants filed a summary
23 judgment motion that relied on omissions, half-truths, and misdirection to deflect the Court's
24
attention from the actual issues, namely, the January 30, 2009 Settlement-Agreement, and the
Plaintiff, who is entitled to protection under the law. In contrary to the Plaintiffs 195-page Plainfiffs
25
Response to the Defendants' Request for Admission (PI. [s] Resp. to Admis.) Exh,l the Defendants'
26
motion proffers a revisionist history of the events underlying this acfion. It presents "undisputed"
27
facts, which are clearly in dispute. It twists case law to suit its own purposes, and i t obfuscates
28
the truth from the Court. In so doing, the Defendants ignore the fundamental premise that
- 2 -
1 summary judgment cannot be granted when material facts are in dispute. Furthermore, the
2 Defendants' attorney, Lindsay Goulding, deceived the Court and the Plaintiff by wrongly implying,
3
on page 2 of her declarafion (Defs. Exh. B ) and in other pleadings, that the five Defendants—
Nichols, Chilcott, Oropeza, Seifert, and Boyd—were dismissed from the Plaintiffs lawsuit. In
4
fact, they are still defendants in the lawsuit. For these reasons, the motion should be denied in its
5
entirety. The Defendants' motion is fraudulent and deceitful.
6
7
II. SUMMARY OF ARGUMENT
8
9 The Defendants' summary judgment motion is, procedurally, a total fraud; it is deceitfijl and
10 ineffective. The Defendants have listed 17 "undisputed" facts that they claim are material, and they
11 repeat them for each COA. On 36 of 70 pages (pages 7^3), the Defendants vexatiously relitigate the
12
3rd and 4th COAs of the Plaintiffs SAC: (3) HARASSMENT, FAILURE TO PREVENT
HARASSMENT, DISCRIMINATION, AND RETALIATION UNDER THE FAIR
13
EMPLOYMENT AND HOUSING ACT (FEHA), GOVERNMENT CODE § 12940(A), AND (4)
14
WHISTLEBLOWER/UNLAWFUL RETALIATION, CALIFORNIA GOVERNMENT CODE §§
15
8547 et seq. These COAs were dismissed and stricken from the SAC by the Defendants' anti-SLAPP
16
motion (Code of Civil Procedure, Section 425.16) on April 14, 2015. The judgment was affirmed by
17 the Court of Appeal's Third Appellate District (3DCA) on October 10, 2017, in the unpublished
18 opinion, Waszczukv. Regents of Univ. of Cal., C079524 (Cal. Ct. App. Oct. 10, 2017).
19 Contrary to the official officially known date that the Plaintiffs employment was terminated
20 on December 5, 2012, the 60-year old Plainfiffs employment was actually terminated on August 31,
21
2011, while he was receiving medical and psychological care for the despicable and inhumane
harassment imposed on him by the remaining Defendants. (EXHIBIT #2) (Defs. Ex, 1) Pl.[s]Ex.
22
No.l - PI. [s] Resp. to Admis.No.l2 p.52
23
24 The information about the August 31, 2011 unlawful termination of the Plaintiffs employment
25 at the UC Davis Medical Center (UCDMC) was provided to the Employment Development
Department (EDD) by the UCDMC Plant Operation and Maintenance Department (PO&M)
26
administration supervisor, Phillis Reginelli, on January 4, 2013 (EXHIBIT #3). On the first page of
27
the document, Reginelli provided the date of terminafion of the Plainfiffs employment as August 31
28
2011, with his last day of work being December 5, 2012.
- 3 -
1 The Plaintiffs unemployment insurance benefits, which, in 2013, were denied by the EDD and
2 the California Unemployment Insurance Appeal Board (CUIAB), were reinstated by the EDD on
3
May 14, 2014 (EXHIBIT #4). These benefits were most likely stolen by the Plaintiffs dmg-addicted
attorney, Stein, who stole the Plaintiffs retainer and was disbarred in January 2020, for misconduct,
4
both related and unrelated to his misrepresentation of the Plaintiff {In re Stein, S245982 (Cal. Mar. 1,
5
2018) (http://iTiembers.calbar.ca.gOv/courtDocs/l 5-0-10110-2.pdf)). The Plaintiff recovered the
6
stolen retainer fee in August 2019, through the California State Bar Client Security Fund (EXHIBIT
7
#5). The short-term disability benefits, denied to the Plaintiff in November 2011, by Liberty
8 Insurance Company, in conspiracy with the Defendants, resurfaced seven years later, on March 20,
9 2019, as unclaimed property in the State of California Controller Office (EXHIBIT #6).
10 On the merits of the motion, the facts readily reflect that the Plaintiff was a highly regarded
11 worker and the most experienced power plant technician in the UCDMC 27-MW cogeneration plant
12 (see the Plaintiffs annual employee performance reviews from 1999 to 2010 (EXHIBIT #7)
13
Pl.[s]Ex. No.l - PI. [s] Resp. to Admis.No.l2 p.53 Defs. Ex. A p. 6-7 . Two last Plainfiffs
evaluations were market "Exceed Expectations" Defs[']. Ex. A p. 6 (24-28)
14
15
III. STATEMENT OF FACTS
16
17 The Plaintiff was hired by UCDMC on June 17, 1999, as a non-exempt senior power plant
mechanic or cogeneration power plant operator. His job was to maintain and operate the newly built
18
state of the art 37-MW cogeneration power plant at UCDMC, where demand for power in 1999 was
19
less than 5 M Wh. When the Plaintiff was hired by UCDMC, he carried the baggage of four pending
20
lawsuits related to his previous employment (1989-1998) with Destec Energy Inc., which was
21
renamed Dynegy Inc. in 1998. The Plaintiff was employed as an operator by Destec/Dynegy at a
22 plant similar to the UCDMC 50-MW cogeneration plant. Both plants were powered by General
23 Electric gas turbines (GT). Destec's plant was powered by an LM5000 GT, and UCDMC's plant, by
24 an LM2500 GT. Pacific Gas and Electric Company (PG&E) was the natural gas supplier for both
25 plants, enabling the powering of the GTs.
26 Former Califomia attorney general, Bill Lockyer, described the Plaintiffs former employer,
27 Dynegy Inc., as one of the "Four Horsemen of the Apocalypse who rode in from Texas and ran
roughshod over California consumers, taxpayers, and businesses." Along with Enron, El Paso Corp.,
28
- 4 -
1 and Reliant and the Regents of the University of California (EXHIBIT #8) they broke the mles and
2 violated the law (https://oag.ca.gov/news/press-releases/attomev-general-lockver-announces-460-
3 million-settlement-reliant-resolve-energv). Dynegy defrauded PG&E ratepayers of $240 million and

the State of California of $281 million {California ex rel. Lockyer v. Dynegy, Inc., 375 F.3d 831 (9th
4
Cir. 2004)). Pl.[s]Ex. No.l - PI. [s] Resp. to Admis. No.l9 p.182-193
5
6
The Plaintiff became a liability, rather than an asset, to the university. This may
7
have happened when the university learned that he had reported Dynegy's 1997, $240
8
million fraud against PG&E ratepayers due to dispute with Dynegy about $27,000 in
9
unpaid overtime due to him and approximately $3 million due to 119 other Destec/Dynegy
10 employees in California. The unpaid overtime was resolved by the Califomia Court of
11 Appeal's 3DCA in favor of the Plaintiff in a December 3, 1999 unpublished opinion in
12 Jaroslaw Waszczuk v. Destec Energy Inc., Case No. C030005. The Plaintiff represented himself on
13 the appeal, and Destec was represented by the notorious and very powerful Littler Mendelson
14
Professional Law Corporafion, based in San Francisco (EXHIBIT #9) Pl.[s]Ex. No.l - PI. [s]
Resp. to Admis. No. 12 p.73
15
Or perhaps the Plaintiff became a liability to the university after he sent a fax to
16
then-California Governor Gray Davis's office on February 14, 2001. The plant was
17
unfinished when it was commissioned, and it posed danger to Davis when he toured the plant
18
Pl.[s]Ex. No.l - PI. [s] Resp. to Admis. No. 19 p. 183-184. The Plaintiffs main concern was the
19 plant's 12.5-kV high-voltage switch gear room, which was protected from fire by a water sprinkler
20 instead of a carbon dioxide (CO2) fire protection system. Prior to the tour, the Plainfiff sent a fax to
21 the governor's office, advising him not to enter the room during the plant tour (EXHIBIT #10) (. In
22 addition to the above, the unfinished plant was discharging machine oil into the Sacramento
River via a storm drain Pl.[s]Ex. No.l PI. [s] Resp. to Admis. No.15 p.93-108 ( defective
23
cooling tower fan gear boxes) See: the Plaintiffs former coworker, UCDMC 27-MW plant
24
operator, William Buckans's whisfieblower complaint, dated August 7, 2005 (EXHIBIT #11).
25
There was a recorded incident of a ne£U"-miss injury to plant personnel after a long metal air duct
26
fell to the ground because the builder of the plant forgot to bolt the metal ducts together and
27 almost killed an operator who happened to be walking by.
28
- 5 -
1 In 2000, the Plaintiff reported the unsafe condifions at the plant to the Califomia
2 Division of Occupational Safety and Health (CAL/OSHA), after the plant manager, Tom
3
Kavanaugh, refused to take care of the safety problems, thus endangering personnel. He
threatened the Plaintiff, saying, "Somebody will give this 'Polack' a bad evaluafion and
4
will fire him." The Plaintiff was not offended, but Kavanaugh's statement terrified his coworker,
5
Eduardo Espinosa. Espinosa quit his job after he heard this (EXHIBIT #12). Pl.[s]Ex. No.l PI.
6
[s] Resp. to Admis. No.5 p.l 1
7
In fact, this "Polack" never received a bad evaluation in the course of his 12 years
8 of employment with the university, but he was subjected to two witch hunts by the
9 Defendants, and his employment was brutally terminated on August 31, 2011. Pl.[s]Ex.
10 No.7 Resp. to Admis. No.3 p.4,8,9
11
Cal/OSHA's intervention and a small citation got the attention of UCDMC's
12
leadership and forced the department management to solve some of the safety problems in
13
the plant, which injured and endangered the lives of plant personnel. The Plaintiffs action
14
also improved the working conditions of plant employees' (EXHIBIT #13).
15
UC did not care much about improved safety in the plant because in 2000 University of
16 California was not the sole owner of the plant and did not want to spend the money to
17 finish it. In 2000, UCDMC simultaneously used an old utility plant alongside the new 27-
18 MW cogeneration plant, which was commissioned in 1998 and was selling power to the
19 Sacramento Municipal Utility District (SMUD).
20
The Plaintiff did not know why he became the subject of witch hunt carried out
from January-March 2007. (Defendants' Exhibits B, F,G, H, I , and J) Pl.[s]Ex. No.l PI. [s]
21
Resp. to Admis. No.l p. 1-2; Resp. to Admis. No.3 p.4; Resp. to Admis. No.4 p.8-10
22
. The witch hunt aimed at the Plaintiff included despicable fabricated allegations
23
and accusations that resulted in the Plaintiffs abrupt removal from the UCDMC 27-MW
24
cogeneration plant on March 23, 2007 and resignment to HVAC Shop." The witch hunters
25 wanted the Plaintiff out of the UCDMC 27-MW cogeneration plant as fast as possible. The
26 Plaintiff did had a clue as to why.
27 The Plaintiff greatly improved the working conditions for the HVAC shop crew, including
28
access to work order systems, time cards, and UC Davis Policies and Procedures, by restoring an
- 6 -
1 older computers from the UCDMC warehouse and organizing their work stations. Prior to this, they
2 waited in line for a long time to get their time cards and job assignments done. Everybody
3
appreciated the Plaintiffs presence in the HVAC shop, and, if they needed help with their home or
work computers, they asked him and Plaintiff never refiised to help to anybody .
4
After the Plaintiff prevailed in the arbitrafion process against the Regents of UC in November
5
2008, he was able to return to the 27-MW cogeneration plant, but his job was already taken, and he
6
did not want to be responsible for kicking somebody out of their job.
7
8
On January 30, 2009 by signed Settlement -Agreement Plaintiff was promoted from non- exempt
cogeneration plant operator to exempt Associate Development Engineer position and permanenfiy
9
was assigned to the HVAC shop . (Defendants Exhibit K) (Pl.[s]Ex. No.3 - PI. [s] Resp. to
10
Admis. No.4 p. 10), The January 30, 2009 was breached by Defendants in 2011 & 2012 and
11
Defendants caused over $ 1,000,000 damages to Plaintiff in wages and benefits by unlawfully
12
terminating Plaintiff employment on August 31, 2011 with his last day of work being December
13 5,2012. Pl.Exh.No.5
14
15 I. LEGAL DISCUSSION
16
17
A, The Crux of January 2007-April 2007 and April 2011 December 2012 Defendants
18
Adverse Action Against Plaintiff
19 The Crux of two separate "WITCH HUNTS" aimed at The Plainfiff in 2007 and 2011-2012 is
20 laying down or are submerged in the Defendants', the Regents of the University of California
21 Request for Admission (Set One) sent to The Plainfiff on April 25, 2018, by the Defendants'
22
attorney, David Burkett. More specifically, the last Request for Admission No. 19, which states:
"ADMIT THAT YOU DID NOT LEARN OF THE ALLEGED ILLEGAL POWER SALES UNTIL
23
AFTER YOUR TERMINATION."
24
The Plaintiff provided his Response to the Defendants' Request for Admission on November
25
14, 2018 prior the scheduled Court hearing in Dept.53. However the Defendant's Attomey Lindsay
26
Goulding in her Declaration (Del Exh, B) deceptively and in bad faith did not included in her
27 Motion the Plaintiffs' Response to Defendants Request for Admission thus Plaintiff included the
28 document as a Plaintiffs Exhibit No. 1 which could easily substitute the Plaintiffs Opposition to
- 7 -
1 the Defendants for Summary Judgment. Goulding under penalty of perjury bluntly lied in her
2 11 Declaration (Defs. Exh. B) about Plainfiffs Response to Defendant's Request for Admission in
deceived and grossly prejudiced Plainfiff in Defendants Motion and deceived the Court as well
thus Defendants Motion must be denied . Gribin Von Dyl & Associates Inc. v. Kovalsky, 185
Cal.App.3d 653 (Cal. Ct. App. 1986)
In Plaintiffs Exhibit # 1 PI. [s] Resp. to Admis. No. 19 pp. 182-198 The Plainfiff answered
Defendants' Attorney David Burkett's curiosity on Novernber 14, 2018 and stated in his Admission
No. 19 response that he leamed about the unlawfial operation of the UCDMC 27 MW plant and
illegal power sale in June 5-December 2015, three years after his employment termination. Plainfiff
9 II provided infonnation to the Court about on 10/13/2015 by his Opposifion to the Defendant's
10 Motion for Automatic Stay which Defendants filed to block Plaintiff Third Amended Complaint
11 (TAG) to be filed (EXHIBIT # 14) The Sacramento Metropolitan Air Quality Management
District (SMAQMD) is responsible to permit operafion of the 27 MW cogeneration power plant
12
which beside violation of the Public Utilifies Regulatory Policies Act of 1978(PURPA) violates the
13
Title VI of the Civil Rights Act of 1964 The unnecessary pollutants discharged to the air from the
14
UCDMC 27 MW cogeneration plant inflict disparate impacts on minority populations and low-
15
income and, who are living in large numbers in close proximity to UCDMC cogeneration plant
^ ^ II Especially a minority children in particular are sensitive receptors exposed to these point sources'
17 criteria pollutants emitted 24 hours a day, 7 days a week.
18 In 2018 the Defendants' Attorney Burkett was so impatient to get an answer from The
-^g Plaintiff that, in October 2018, he bypassed Judge Brown in Department 53 and attempted to obtain
in the Court Department 54 , Hon. Christopher E. Krueger termination sanctions byfilinga motion
20
to compel for monetary and terminafing sanctions on October 3, 2018. (ROA # 150-154) Burkett
21
was caught by the Plaintiff, and his plan failed . See: Plainfiffs letter to the Clerk in Department 54
22
dated October 11, 2018. (EXHIBIT # 15) At the same time Defendants Attomey Burkett with his
23
assistant Daniel Bardzell attempted to frame Plaintiff for Bench Warrant with Judge Jennifer K.
24
Rockwell from Department 37 who signed on November 7, 2018 Application and Order for
2 5 II Appearance and Examination of Plaintiff in violation of the 45-day requirement (Civil Code of
26 Procedure §§ 491.110, 708.110, 708.120, & Sacramento Superior Court Local Rule 2.1) (ROA#
27 181)
28

1 Plaintiff responded to the Judge Rockwell's signed November 7, 2018 Application and Order for
2 Appearance and Examination with letter dated November 19, 2018. (ROA# 181)
3 The Defendants Attorneys Burkett and Bardzell an attempt in 2018 and 2019 to steal money
from Plaintiffs wife Bank Account and from her 401K using Department 54 & 37 failed. Judge
4
Rockwell and Judge Krueger who knew each other before they were appointed to the Bench by
5
working for Attorney General Bill Lockyer State v. All Persons, 152 Cal.App.4th 1386 (Cal. Ct.
6
App. 2007) did not let it happen.
7
However , after Judge David I Brown left the Department 53 and was replaced by Hon.
8 Shama Hakim Mesiwala , successor of Burkett and Bardzell, Porter Scott Shareholder Lindsay
9 Goulding resumed the criminal extortion activities in the court and 70 years old Plaintiffs wife on
10 July 2, 2021 was forced to pay $ 22,284 ransom to Lindsay Goulding not to let her break into her
11 Bank Account and 401 K account.
12
B. Legal Standard
13
A party moving for summary judgment bears the burden of showing that the causes of action
14
have no merit or that there are one or more complete defenses to them. (Code Civ. Proc, § 437c,
15
subd. (p)(2).) Summary judgment is properly granted only if the moving party's evidence establishes
16
that there is no issue of material fact to be tried. ( Lipson v. Super. Ct. (1982) 31 Cal.3d 362, 374.)
17 Once the moving party meets this burden of production, the burden shifts to the opposing party to
18 produce admissible evidence demonstrating the existence of a triable issue of material fact. {Aguilar
19 V. Atlantic Richfield Co. (2001) 25 Cal.4th 826, 849.) A judge must grant a motion for summary
20 judgment if all the papers submitted show that there is no triable issue as to any material fact and
21
that the moving party is entified to judgment as a matter of law. (Code Civ. Proc, § 437c, subd. (c);
Mann v. Cracchiolo (1985) 38 Cal.3d 18, 35.)
22
In ruling on a summary judgment mofion, the Court must consider the evidence and inferences that
23
can reasonably be drawn therefrom in the light most favorable to the opposing party. {Aguilar,
24
supra, 25 Cal. 4th at p. 843.)
25
The Defendants or Defendants legal counsels from Porter Scott law firm did not provide in the
26 their Motion any material facts which meets the burden of producfion to shift the burden to Plainfiff
27 to produce admissible evidence demonstrating existence of a triable issues of the material facts .
28
- 9 -
1 The second amended complaint (SAC) was set forth eight causes of action (COA):
2 1.) intentional infliction of emotional distress, 2.) tortious interference with economic
3 advantage, 3.) harassment, failure to prevent harassment, discrimination, and retaliation
4 under FEHA, 4.) whistleblower/unlawful retaliation Government Code § 8547 et. seq, 5.)
5 violation of Health and Safety Code, sec. 1278.5, 6.) breach of written contract, 7.) wage and
6 lour violations, and 8.) rescission - unlawful contract.
7 C. Defendant's Unlawfully Relitigate Dismissed from the Second Amandment Complaint

Non Material Facts as A Material Facts Thus It Mandates Denial of its Motion.
8
9 The 1-4 COA's were stricken from the SAC by the Defendants on April 14, 2015 by the
10 Special Motion to Strike pursuant to CCP Section 425.15 and it should be end of litigafion of these
11
dismissed COA's If the Court examine the Defendants Motion for Summary Judgment than Court
will find out that stricken COA's especially COA No.3 and No. 4 occupied between 60-70 % of
12
Defendants Arguments in the their Memorandum of Points and Authorities in Support and in
13
Separate Statement of Undisputed Material Facts . Defendants Separate Statements (DefsSS) from
14
Page 7 to 43 are stricken COA's from SAC . In the Memorandum of Points and Authorities
15
Defendants from Page page. 9 to page No .17 arguing dismissed from SAC 3'^' and 4"^ COA.
16 In Defs Exh, B , Declaration of Lindsay Goulding on Page 2 (1-10) Defendants attorney arguing 3'^'
17 and 4'*^ COA dismissed from SAC as well.
18 In addition to relitigating dismissed 3'^' and 4* COA Defendants unlawfully by Motion for
19 Summary Judgment unlawfully relitigate the January -April 2007 Defendants unlawful adverse
action aimed at Plaintiff which was resolved by November 3& 4, 2008 Arbitration hearing and the
20
January 30, 2009 Settlement Agreement which is a key Material Fact to litigate in this proceeding .
21
(Defs Exh K). See : Defendants Memorandum of Points and Authorities Page . 4(2-5);(9-12) Page 5
22
(20-28), Page 6(1-9) and Defs Exh's F,G , H, 1, J. See: Defendants Separate Statements of
23
Undisputed Facts : Pages: 2(7-25), 8(15-28),13(7-25),17(1-9),22(1 l-28),26(22-28),27(2-12),31(l-
24 28);43(l-24),48(15-28),53(25-28),54(l-15),55(10-55),56(24-28),57(l-28),59(24-28),60(I-28),
25 65(14-28) (Pl.[s]Ex. No.l - PI. [s] Resp. to Admis. No.l p.2).
26 For vexatiously relitigating stricken the COAs and resolved matters by arbitration 13 years
27 ago the Defendants should be sanctioned and admonished by the Court.
28
- 10 -
In the most recent Appellate Court Case Opinion, Colombo v. Kinkle G055823 (Cal. App.
2 Dist. 4, May 16, 2019), the Court cited Bucur v. Ahmad {20\6) 244 Cal.App. 4th 175. 185
3
concluding:
4 "Both res judicata and collateral estoppel are based on the principle that a lifigant
is only entitled to one bite at the apple. "The doctrine of res judicata, whether
5
applied as a total bar to further litigation or as collateral estoppel, "rests upon the
6 sound policy of limiting lifigation by prevenfing a party who has had one fair
adversary hearing on an issue from again drawing it into controversy and
7 subjecting the other party to further expense in its reexamination."
8 Defendant has chosen to file a Mofion for Summary Judgment with Separate Statement of
9 Undisputed Facts which simply replicates old resolved matters and stricken causes of acfion at issue
10
in this case. These Defendants supposedly undisputed material which are 14 years old slander
defacing and defaming Plaintiff facts shows Defendant's desperation and criminally minded
11
behavior
12
Therefore, this Court is within itsrightsto deny the motion in its entirety. Pursuant to Weil &
13
Brown, Cal. Practice Guide: Civil Procedure Before Trial (2013) §10:28, summary judgment must
14
be denied if a single material fact is in dispute. Because Defendant has chosen to rely on the
15 something what does not exists and nothing to do with Plainfiffs SAC and the remining four
16 COA's thus Court must deny the motion . Court must not prejudice Plaintiff in this proceeding .
17
18 D. The Five Individual Defendants , Stephen Chilcott, Danesha Nichols , Cindy Oropeza
,Brent Seifert and Mike Boyd .
19
The Motion For Summary Judgment Or, In The Alternative, Summary Adjudication was filed by
20
Counsel Lindsay Goulding only on the Regents of the University of California . The five individual
21
Defendants , Stephen Chilcott, Danesha Nichols m Cindi Oropeza , Mike Boyd and Brent Seifert
22
are not included in the motion thus Mofion must be rejected and denied Plaintiff did not dismissed
23
Chilcott, Nichols , Oropeza , Boyd and Seifert from last the four remaining COAs of Plaintiffs'
24 Second Amendment Complaint. The five individual Defendants are responsible and liable together
25 with the Regents of the University of California for monetary damages (wages and benefits) they
26 caused to Plaintiff and which are amounted in approximate $ 1, 000,000 because of Defendants
27
conspiracy with UC Regents in their reckless violation of January 30, 2009 Settlement -Agreement
to terminate Plaintiffs employment on December 7, 2012 i. The January 30, 2009 Settlement -
- 11 -
1 Agreement is enforceable only by the California Court and Plaintiff relay on Court that Justice will
2 properly serve without bias and prejudice to Plainfiff as it happened manyfimes. The Motion is a
3
total fraud and must be denied by the Court for above reason. .
4
E. The May 11, 2012 Ten Days Suspension Without Pay Violated UC Davis Procedure
5 62.1: Corrective Action and Employe Performance Review (Evaluation) Policy PPSM
6
23 Thus Was Unlawful
7
On April 13, 2012 Plaintiff being on leave since August 3, 2011 (9 months) was served by
8 Defendants a Letter of Intent to Suspend (EXHIBIT# 29) which Defendants Attomey Lindsay
9 Goulding did not include into her Motion list of exhibits.
10 Defendant's attorney did not include the April 13, 2012 Letter of Intent to Suspend because the
11 fabricate allegations and accusations were more than one year old and letter intent to suspend
12 violated UC Davis Procedure 62.1: Corrective Action and UC Davis Evaluafion Policy PPSM 23
which was strictly enforced by UC Davis Administration . Employees without annual evaluation
13
don't not work in UC Davis or University of California
14
15 An allegation was made that on March 8, 2011, April 21, 2011 and May 5,
20011 that you engaged in behavior that violated UCDHS Policy 1616 - Violence
16 and Hate Incidents in the Workplace. It was alleged that you were disruptive and
intimidating with Dorin Daniliuc when you pointed yourfingerin his face and
17
used profanity on March 8, 2011. Further, on April 21, 2011 you became
18 disruptive and intimidating with Patrick Putney during a discussion regarding your
work performance.
19
Mentioned in the letter of Intent Charles Witcher's Assistant Dennis Curry was removed
20 J
from UCDMC premises in June 2012 for making vail threats aimed at Plaintiff. Curry was direct
21
Patrick Putney and Dorin Daniliuc Superior and he a power to discipline Plaintiff in 2011 . All three
22
knew how to sell chickens and goats in the HVAC shop but they did had a clue about the UC Davis
23
Policies and Procedures which are regulates in UC system relation between employees not
24
represented union the and employer . Putney and Daniliuc were Plantiff s friends and were forced
25 by Defendants to attack Plaintiff an Plainfiff coworkers to keep their job. Pl.[s]Ex. No.l - PI. [s]
26 Resp. to Admis. No. 15 p. 115
27 The fabricated allegations were more than year old and should reflect Plaintiffs July 2010-
28 July 2011 Plaintiff Annual Performance Review (Evaluation) which Plainfiff never received for
- 12 -
1 the evaluation period of July 2010-July2011.. Plaintiff worked full evaluafion period in 2010-2011
2 Evaluations were mandated and strictly enforced by UC Davis Policy PPSM 23.
3 Prior the April 13. 2012 Letter Intent to Suspend on Febnjary 14, 2012, Plainfiffs held
meeting with HR Labor Relations Manager, Mike Garcia, to resolve the dispute informally . Meeting
4
was arranged by Defendant Cindy Oropeza . HR Manager Benefits, EEO, Resident/Fellow Program
5
IR Administrator, Title IX Officer - Sexual Harassment, Mediation Services, ASAP, Early
6
Resolution/Inclusion Pl.[s]Ex. No.l PI. [s] Resp. to Admis.No.l2 p.71-74
7
Garcia asked Plaintiff how much Plainfiff will ask, dollar-wise, to voluntarily quit his job.
8 During the discussion Plaintiff proposed that he will quit his job if Defendant will pay Plaintiff his
9 annual wages in a lump sum unfil Plaintiff would be eligible for full Social Security Benefits at age
10 66. Plaintiff Noticed^ during the meeting that Mike Garcia was stressed out; Mr. Garcia told
11 Plaintiff that he is very concerned about the whole situation, that it is very unpleasant for him to
12 deal with .
At the same time HR Manager Mike Garcia replaced HR Consultant Gina Harwood with an
13
Attorney at Law Jill Vandrviver to handle Plaintiff s case and other two employees complaints to
14
whom Plaintiff was providing representation under UC Davis Policy PPSM 70(bad evaluations and
15
letters of expectations ) . Pl.[s]Ex. No.l PI. [s] Resp. to Admis.No.15 p.89-l02
16
In April or May 2012 Plainfiff had heard from his coworkers that(friends) the carpenter
17
shop was building two extra offices on the first level of Building 68 (Department Administration
18
Building ) and Plaintiff was hoping that Defendants would eventually move Plaintiff from the HVAC
19
20
shop to Bldg. 68 and that the conflict would end. Pl.[s]Ex. No.l PI. [s] Resp. to Admis.No.l5 p.103
21 It was true . In the bulk of e-mails Plaintiff received from Defendants Attorneys in 2015 due Plainfiff
22 's Requests for Production of Documents (Set One ) Plaintiff found May 10, 2012 e-mai
23 correspondence HR Manager Mike Garcia Assistant Jill Vandeviver sent to herself with cc, to
24 Plaintiffs Department Manager Charles Witcher , Mike Garcia and Travis Lindsay with Subject :
25 Suspension which stated : (EXHIBIT # 17)
26 Also, since Jerry's job description is not yet complete, are you ok with us
sending a separate .letter once the Metasys memo goes out to all staff to then send
27
Jerry a letter with the memo and new job description?
28
- 13 -
1 With another e-mail send to Travis Lindsay (Mike Garcia Replacement) by Vandeviver at the
2 relatively same time stating : (EXHIBIT # 18)
3
Hi Travis -
We do not want to suspend Dorin (i.e. issue his letter) unfil he returns from
4 medical leave, correct?
There is also no longer an issue with regards to having Jerry coming back prior to
5
Patrick and Dorin serving their suspensions, correct?
6 Thanks,
J. Noel VanDeviver, J.D., M.P.A.Principal Employee & Labor Relations
7 Consultant
8 Both Patrick Putney and Dorin Daniliuc were two Plainfiffs supervisors and friends since
April 20 , 2007 and were victimized by Defendants as well .
9
Why they got suspended a year later together with Plaintiff if the Plaintiff was alleged
10
offender March , April and May 2011 as April 13 , 2012 Letter Intent to Suspend stated ?
11
Plaintiff received the April 13, 2012, Letter of Intent to Suspend during his absence from
12
work since August 2, 2011 and was suspended without pay for 10 days day on May 11, 2012 just
13 one day after HR Consultant Jill Noel was chatting about new Job Description for Plainfiff
14 Plaintiff by instrucfion in 5/11/2012 letter of suspension (EXHIBIT # 19)(Defs Exh. M )
15 reported himself to work on May 31, 2012. Instant to receive a new job descripfion from his
16 manager Charles Witcher and go back to work , the specially assembled UC Davis Death Squad
17
waited for Plaintiff with Supervisor of Trauma Unit # 11 Karen Kouretas ready to receive Plaintiff
and euthanize him if UC Davis Police Lt. James Barbour will not kill the provoked Plaintiff at
18
first shot. Pl.[s]Ex.No.l PI. [s] Resp. to Admis.No.l 5p. 84,89,103,103-105,107,109-112
19
Plaintiff walked out from the death trap in one piece and drove home with another letter
20
titled'"Investigatory Leave Letter" which fired Plaintiff from the job again and again. (Defs.Ex.
21
N)
22 Charles Witcher who handled the letter to Plaintiff almost got fired a few days later from his job
23 as well. Pl.[s]Ex. No.3 PI. [s] Resp. to Admis.No.l5p.89
24 The ten days suspension without pay was unlawful and also violated January 30, 2009
25
Settlement _Agreement and cost Plainfiff at least $ 3, 000 of his income thus is triable
undisputed material fact. The Defendants Motion must be denied by the Court ,
26
On May 31 , 2011 the fate of further Plaintiff's employment with university was decided
27
because Sacramento Municipal Utility District SMUD on that day signed a new unlawful power
28
purchase agreement with the Regents of the University of Califomia to buy power from UCDMC
- 14 -
1 27 MW Cogeneration Plant .(EXHIBIT #20). Since February 2009 owners of the plant lost millions
2 of dollars tax free due to lack of surplus power sale. Pl.[s]Ex. No.l PI. [s] Resp. to Admis No. 19 p.
3
193-194 The power purchase agreement became a worthless piece of paper because The Plaintiff
was not successfully eliminated (killed) by the bribed UC Davis PD Lt. James Barbour or his
4
subordinate. Pl.[s]Ex. No.l PI. [s] Resp. to Admis 15 p. 103
5
Shortly after Petitioner escaped death or UCDMC Trauma Unit # 1 1 , Plainfiff still employer
6
attempted to frame Plaintiff with Lodi Police . On June 21, 2012 disappointed UC Davis PD
7 Jennifer Garcia Sergeant #1021 informing others in e-mail that: (EXHIBIT # 21)
8
"Jerry" is clear any warrants, has no guns registered and no current dealer record of
9 sales for guns and has a negative criminal history. Lodi PD informed they have
nothing on him. jenn
10
On June 22, 2012 day after Sergeant #1021 Jeniffer Garcia announced that "Jerry " is clear
11
on any warrants and that he is not a gun dealer , UCDMC HR Consultant Gina Harwood sent to
12
Plaintiff a memo informing Plainfiff that HR Manager Mike Garcia and his assistant Jill Noel
13
Vandeviver who attempted to help find resolution with Plaintiff employment, got fired and she
14
replaced Jill Noel Vandeviver and Travis Lindsay replaced Mike Garcia as a new HR Manager .
15 (EXHIBIT # 22)
16 F. The Unlawful Termination of Plaintiff Employment with the University of California
17
On September 26, 2012, the Plaintiff received by overnight mail a Nofice of Intent to
18 Dismiss for Serious Misconduct, dated September 25, 2012 (EXHIBIT # 23). It was similar to the
19 unlawful April 13, 2012, Notice Intent to Suspend and May 11 Letter of 10 Days Suspension without
20 Pay and other documents the Plainfiff had received from UCDMC Plant Operafion and Maintenance
21
Department Manager Charles Witcher. The notice is as follows:
22 Re: Notice of Intent to Dismiss for Serious Misconduct

23
The purpose of this letter is to inform you that 1 intend to dismiss you from your
24 position as a Sr. Development Engineer in Plant Operations and Maintenance. The
reason for this action is your failure to adhere to UC Davis Policy and Procedure
25
380-15, Staff Complaints of Discrimination, UCDHS 1616, Violence and Hate
26 Incidents in the Workplace and the Principles of Community.
27 The letter also informed that Plaintiffs title was changed or Plainfiff was promoted from
Associate Development Engineer to the Senior Development Engineer and now question why
28
- 15 -
1 Plaintiff is being promoted and being fired same time. It shows that Plaintiff being discharges for
2 the different reason than alleged misconduct The Notice of Intent to Dismiss was not the new job
description that the Plaintiff should have received in May 2016 (Pl[s] Exh 30).
3
G. The email dated September 26. 2012. - Destruction of Evidence by Defendants
4
(EXHIBIT # 24).
5
The email correspondence dated September 26, 2012, between the UCDMC HR Compensation
6
Manager, her subordinates Bill Gregory and Yvette Guttierrez, and UC Davis Health System HR
7
Director Stephen Chilcott with CC HR Labor Relation Analyst Gina Harwood and HR Labor
8 Relation Manager Travis Lindsey stated the following:
9 • Bill
Can you please go into eHR as there appears to be an eval in the system with an
10
unsatisfactory rating for Jaroslaw Waszczuk employee ID 100007732. Once you located it
11 please cancel the eval totally out of the system (i.e. delete). Stevel_has indicated that he was
on leave for the majority of the review period and should not have been evaluated with an
12 unsatisfactory rating.
• Yvette
13
Can you please initiate a deferral on this employee as well, pushing the eval date out a year
14 to September 2013?
• Gina-
15 Can you advise the dept that we have done this? Steve shared with me the pending action on
this employee and that we will probably want to correct the system immediately.
16
Thanks to you all, any questions let me know
17 • Carol
18 Beside the unlawful destruction by Defendants of the Plaintiff employee record , the above e-mail
19 chat is undisputed evidence and fact that no adverse action should be taken against Plaintiff during
20 his leave of absence . If Plaintiff should not have been evaluated with an unsatisfactory rating than
21
also Plaintiff should not be suspended without pay in May 2012
In Forbes v. County of San Bernardino, 101 Cal.App.4th 48 (Cal. Ct. App. 2002) the court
22
observed:
23
24 that a number of non tort remedies already existed to deter the intentional
destruction of evidence by litigants or third parties. The court in the underlying
25 action could impose evidenfiary sanctions, such as an inference that the
unavailable evidence was unfavorable to the party who destroyed or suppressed it.
26
The victim of the spoliation similarly could be permitted to explain to the jury why
27 the evidence was not available, so that the jury would not hold against the victim
its failure to produce the evidence. The court could also impose monetary or
28 contempt sanctions on the spoliator. In addition, any person willfully
- 16 -
1 destroying evidence would incur criminal liability. (Pen. Code, § 135; Cedars-
Sinai, supra, 75 Cal.4th at pp. 11-13; Temple Community, supra, 20 Cal.4th at pp.
2 474, 476-477.)
3 It is clear and undisputed material fact that Defendants dismissed Plainfiff for other reason than
4 alleged misconduct in violation of UC Davis Procedure 62.1: Corrective Action and in violation
5 of January 30, 2009 Settlement -Agreement thus Defendants Motion for Summary Judgment must
6 be denied .
The CEMRP2, as menfioned in the email title, stands for the University of Califomia
7
Clinical Enterprise Management Recognition Plan 2 ("Plan"), which is governed by Personnel
8
Policies for Staff Members 34 (Incentive and Recognition Award Plans - Managers & Senior
9
Professionals and Professional & Support Staff).
10
https://policv.ucop.edu/_files/policies/CEMRP2-Plan.pdf
11 https://policv.ucop.edu/doc/40l0430/PPSM-34
12 The September 26, 2012, email "CEMRP2 Eligible Employees With Unsatisfactory Rating"
13 (DEF RPDl 3019,) which was provided to the Plaintiff by Defendants attorneys from Porter Scott
14 Law Corporation, is undisputable evidence that for the 2011-2012 evaluation period (July 1, 2011,
15
to June 30, 2012), the Plaintiff, as a university employee, should have received at least a "Meets
Expectation" rating in his evaluation, as mandated by the UC Davis Policy PPSM 23.
16
Additionally, for the 2011-2012 evaluation, the Plaintiff should have received a CEMRP2
17
Recognition Reward. Plaintiff should not be forced to stay on leave for one year. Plaintiff should be
18
terminated or allowed to work after he end medical leave on January 5, 2012.
19 Instead, on May 11, 2012, he received a ten-day suspension without pay and a Notice of
20 Intent to Dismiss for Serious Misconduct. Both measures were based on maliciously fabricated
21 accusations by the five listed individuals in lawsuit. During the 2011-2012 evaluafion period, the
22 Plaintiff worked only one month and three days: July 1, 2011, to August 3, 2011. For the 2010-2011
23 evaluation period, the Defendants discriminated against Plaintiff and did not provide the Plainfiff
with any employee performance review.
24
This is undisputed evidence that Plainfiff was singled out for termination for different reason
25
than misconduct thus Defendants Motion must be denied by the Court . Defendants grossly violated
26
UC Davis UC Davis Procedure 62.1: Corrective Acfion and Evaluafion Policy PEPS 23 beside
27 violating the January 30, Setfiement Agreement
28
- 17 -
1 This is a clear contradiction of the mandates outlined in UC Davis Policy PPSM 23. After
2 August 3, 2011, the Plaintiff was not allowed to return to work. On December 7, 2012, he was
3
unlawfully terminated.
On September 26, 2012, Compensafion Manager Carol Shimada explained by email that she
4
discovered a conspiracy against the Plaintiff that was perpetrated by her superior, HR Director and
5
Defendant in this lawsuit, Stephen Chilcott and Defendant Chilcot got of guard of wrongdoing. This
6
material fact alone precludes Defendants from Motion to be granted beside violation of the January
7
30, 2009 Settlement Agreement by Chilcott an his subordinates
8
9 H. Email dated 09/26/2012 entitled "Person Unauthorized on Property (Jaroslaw

Waszczuk)" Documents marked DEF RPDl 3027 and DEF RPDl 3032 a and UC Davis
10
Police Poster with the Plaintiffs photo and a description on. (EXHIBIT 25)
11
The last act inhumane treatment of Plaintiff by the Defendants which defamed and defaced
12
Plaintiffs character and character prior to the termination of the Plainfiff s employment on
13 December 7, 2012, was the September 26, 2012, distribution of a UC Davis Police poster with the
14 Plaintiffs photo and description on it. The poster was distributed around UC Davis's campuses
15 without the Plaintiffs knowledge. (Defs Exh, A3) Pl[s] Exh No. 1 Pl[s] Resp. to Admis. No. 11 p.
16 35; Admis. No. 16 p. 125; Admis. No. 17 p. 131-138, 159, 160, 162, Admis. No. 18 p. 176;
17
UCDMC HR Labor Relation Consultant Gina Harwood, who was handling Plant Operafion
18
& Maintenance Department (PO&M) labor-related matters, was shocked when she received the UC
19
Davis Police poster with the Plaintiffs photo and physical description on it. Gina Harwood had
20
known the Plaintiff for a long time. In her response to HR Labor Relation Manager Travis Lindsey,
21
she wrote about the poster, as follows:
22 Hi There:
23 This is really out of the norm to post this in the department, and 1 was not aware
24
that we were going to do this. Did we ask the police to do this? His letter stated
that he would remain on paid leave which implies the same expectations, but I am
25 a little concerned that this is being posted in the department since we have not
done this before on any other violence cases. Just want to make sure that we
26 sanctioned this before it was posted in the department because I suspect we will be
getting an email about it soon.
27
28 Gina
- 18 -
1
Travis Lindsey responded to Gina Harwood's email:
2 SENIOR LEADERSHIP ASKED STEVE TO HAVE PD TAKE THIS PRECAUTION
3
AND
WE'VE NEVER TERMINATED JW EITHER.
4 Gina Harwood thanked Travis Lindsay with words:
"OK, THANKS FOR THE INFO, WAS JUST CONCERNED BECAUSE WE HAVE NOT
5 DONE THIS BEFORE. GINA"
6 The question is why Gina Harwood became so concemed so about UC Davis PD poster
7 portraying the Plaintiff like a "Terrorist or Criminal" wanted by the FBI. She was the one who
8 conspired with another Gina—Gina Holleman and UC Davis Police Sergeant Jennifer Garcia—to
frame Plainfiff for being in trouble with Lodi Police. It did not work on July 18, 2012. Investigator
9
Gina Gaullaume-HoUeman from the UC Davis Medical Center (UCDMC) Chief Compliance Office
10
interviewed one of the Plaintiffs coworkers from the HVAC shop sent to her by Gina Harwood.
11
Gaullaume-Holleman solicited from Mark Montoya to sign an affidavit which stated that the
12
Plaintiff threatened him and is a dangerous individual. Mark Motoya was riding his bike(Harley)
13 together with Gina Harwood and UCDMC HR Workers' Compensation Manager Hugh Parker, who
14 was overseeing the May 31, 2012, provocafion to send the Plaintiff to UCDMC Trauma Unit #11.
15 What is interesting in Gina Harwood and Travis Lindsay's email chat about "Persona Non
16 Grata" UCDPD poster is Travis Lindsay's statement: "WE'VE NEVER TERMINATED JW
EITHER."
17
HR Manager Travis Lindsay was correct. The Plaintiff should have received a new job
18
description in May 2012 and returned to work as a Senior Development Engineer.
19
. New HR Manager Travis Lindsay was right that he and Charles Witcher were not the ones
20
who fired the Plaintiff. An order or recommendation to terminate Plainfiffs was sent to Defendants
21 Stephen Chilcott and Brent Seifert by Attorney Mia Belk from the UC Office of the General Counsel
22 on September 18, 2012. In March 2016, the Plaintifffileda complaint against Mia Belk and the
23 other attorneys from the UC system who were conspiring against the Plaintiff (EXHIBIT #26)
24 https://wvyw.scribd.com/document/519289966/03-23-2016-California-State-Bar-Complaint-
Against-Attorneys
25
The Plaintiffs Complaint was swept under the rug by the former California State Bar Executive
26
Director/CEO Elizabeth R. Parker , former Dean in Pacific McGeorge School of Law and
27
former CIA and NSA Counsel & Janet Napolitano's friend .
28
- 19 -
1 The facts and documents show that nobody in UC Davis or UC Davis Medical Center
2 wanted to take responsibility for the Plainfiffs harassment and termination of his employment;
3
thus, they fabricated false reports, portrayed the Plaintiff as a racist, bigot, and anti-Semite, and
sent their slander to an attorney in the UC Office of the General to make a decision for the
4
Defendants Director Mike Boyd and HR Director Defendant Stephen Chilcott and his
5
subordinates, Defendants Brent Seifert, Danesha Nichols, and Cindy Oropeza. Mia Belk never
6
contacted the Plaintiff by phone, email, or mail. She made her recommendation to fire the
7
Plaintiff and then left UC system. The Court must deny the Mofion for Summary Judgment to
8 Defendants.
9 I. The Letter of Termination Dated December 5, 2012
10 On December 5, 2012, UCDMC Plant Operation and Maintenance Department Manager
11 Charles Witcher sent an email to the Plaintiff with the attached Letter of Termination that contained
12 the same content as the September 25, 2012, Nofice Intent to Dismiss for Serious Misconduct that
the Plaintiff s job title is not Associate Development Engineer but Sr. Development Engineer. In
13
addition, the draft of the Letter of Termination was sent by Witcher to HR Manager Travis Lindsay
14
(Attomey) for approval; the approved letter was sent by Witcher to the Plaintiff (EXHIBIT # 27). In
15
2012, the base pay for an Associate Development Engineer was $71,400, and for a Sr. Development
16
Engineer, the base salary was $91,099 per year. This is almost a $20,000 difference or approximate
17 $1600/month more. The Plaintiff has provided evidence that in May 2012, management was
18 preparing a new job description for the Plaintiff and that HR Manager Travis Lindsay, who approved
19 the Letter of Termination, told his subordinate Gina Harwood that the UC Davis Medical Center had
20 nothing to do with the Plaintiffs termination of employment. See: Pl.[s] Exh. No.30 Thus, all
evidence of the Plaintiffs wrongdoing provided in this Defendants Motion are false and fabricated
21
to further harm the Plaintiff
22
The Skelly Reviewer , UC Davis Associate Vice Chancellor Allen Tollefson's decision dated
23
December 3, 2012 and Charles Witcher's Letter of Termination were just formalities. No
24
outstanding work history or performances outlined in Plaintiffs employee performance review
25
(evaluafions) were mentioned. Neither decision mentioned the February 2009 Settlement-Agreement
26 Plaintiff signed with the regents of the University of California, which guaranteed Plainfiff a job
27 with the University as the Associate Development Engineer. .
28
- 20 -
1 The Plaintiff lost his home in 2012 due to the Defendants' malice and inhumane treatment of the
2 Plaintiff, which inflicted upon him irreparable harm and caused approximate losses in the amount of
3
$1,000,000 in wages and benefits (roughly calculated)
The Defendants grossly violated Skelly:
4
In Skelly v. State Personnel Board {\975), 15 Cal. 3d 194, the California Supreme
5 Court ruled that: "as part of constitutionally guaranteed due process, public
6
employees are entitled to certain procedural safeguards before discipline which is
7 imposed on them. The consfitufionally protected liberty interests requiring Skelly
protections arise whenever the allegations against an employee are sufficiently
8 onerous to seriously impact the employee's ability to find future work in his/her
chosen career."
9
10
UC Davis Associate Vice Chancellor Allen Tollefson's together with Porter Scott Attomeys
11 Michael Pott and George Acero was a key player in the 2007 3DCA anti-SLAPP mofion case
12 Vergos V. McNeal, 146 Cal.App.4th 1387 (Cal. Ct. App. 2007) . Plainfiff addressed Mr. Tollefson
13 Porters Scott Attorneys in his March 7, 2018 open letter to UC Davis Chancellor Gary May tided:
14
DANNY GRAY'S "Me Too"— PARTS UNKNOWN (EXHIBIT # 28)
https;//vyww.scribd.com/document/390497657/SI-22-MeToo-Danny-Gray-Parts-
15
Unknown-UC-Davis
16
17
J. The Court Has Discretion to Deny Summary. Judgment When a Material Fact Is
18 Established Solely By an Affidavit Made By a Party Who Is a Sole Witnesss.
I
19 Pursuant To CCP. Section 437c, Subdivision (E):

20
21
Summary judgment may be denied in the discretion of the court, where the only
proof of a material fact offered in support of the summary judgment is an
22 affidavit or declaration made by an individual who was the sole witness to that
Fact; or where a material fact is an individual's state of mind, or lack thereof, and
23 that fact is sought to be established solely by the individual's affirmation thereof"
24
In this Motion, numerous pieces of evidence are statements submitted by Defendant's current
25
or former employees. (Defs Exh[s] B, F, G, H, Q, S, U, W, and Y) Many of these statements cannot
26
be disputed because the declarants claim to be the sole witnesses as to the facts alleged. Usually,
27
these come in the form of their "state of mind," such as their reasoning for doing (or not doing)
28 something. These are not appropriate facts upon which to base a summary judgment motion because
- 21 -
1 the juror is the ultimate decision maker as to whether the Defendant, or in this case its agents and
2 employees, are credible in these statements.
3
Because the declarants are the individuals who are alleged to have committed the egregious acts that
are the subject of this lawsuit, their statements are self-serving. At trial, a jury may reject the self-
4
serving testimony of a party to the litigation, even if uncontradicted by other testimony or evidence
5
The Declarations and Investigatory Reports provided by the Defendants' attorneys to support
6
the mofion (Defs Exh[s] B, F, G, H, Q, S, U, W, and Y) are very questionable documents and they
7
are not credible documents taking into consideration Defendant Attomey Lindsay Goulding in her
8 Declaration repeated in the Memorandum of Points and Authorities in Procedural Status Chapter on
9 Page No.2 stating that Plaintiff did not respond to Defendants Request for Admission and admitted
10 wrongdoing. Plainfiff responded to the Request for Admission did not admitted any wrongdoing
11 because was none .
12 The Defendants terminated the Plaintiff s employment six years before his retirement at age
61. This improper termination greatly affected the Plaintiffs life and livelihood and caused the
13
Plaintiff monetary losses of over $1,000,000 in wages and benefits, which is the focus of this
14
lawsuit. The Court must deny this Motion and Defendants must pay the damages to Plaintiff they
15
caused.
16
K. The Defendants Are Playing Race Card in the Memorandum of Points and
17 Authorities Memorandum of Points and Authorities in Support of Defendant's Motion
for Summary Judgment or, in the Alternative, Summary Adjudication
18
19
Ethnically, the Plaintiff is Eastern European. Besides being called "Polack" by Americans, he
20 was discriminated against by UC and was discriminated against and pre-judged in the California
21 Courts. The treatment by Polish communists was nothing compared to what the Plaintiff has
22 experienced in this country since January 2007. The Plaintiff and his family were granted political
23 asylum in the USA to protect them from government oppression. Instead, the Plaintiffs livelihood
was destroyed by the govemment of California, which violated the Plaintiffs civil and human rights
24
leaving the Plaintiff with nothing, at the age of 70. The Plaintiff is a Polish immigrant, a former anti
25
communist activist, and a political prisoner from Soviet-dominated Poland; he has legally lived in
26
the USA since November 1982 and has two Polish -Mexican grandchildren Diego Salvador
27
Waszczuk and Sophia Waszczuk. (https://www.scribd.com/document/494446114/Solidaritv-Anti-
28 Communist-Movement-Poland-1980-1982
- 22 -
1 The Defendants' attorney, desperately trying to play the race card and
2 employing despicable accusations, lied under penalty of perjury in her Declarafion (Defs. Exh, B p.
3
3) that the Plaintiff made derogatory comments in the workplace about Jewish people, African-
Americans, Hispanics, and/or homosexuals. If this was the case, then the Plainfiffs comments were
4
overlooked by the Defendants for 12 years, as the Plaintiff was receiving good annual performance
5
reviews (evaluations) from the Defendants. The last two evaluations that the Plainfiff received in
6
2010 have been highlighted (Exceed Expectation) (Defs. Exh. A pp. 5 [27-28]; 6 [1-28]).
7
The Plaintiff received the highest grade (Outstanding/Exceed Expectations) in their last two
8 evaluations for 2008-2009 and 2009-2010. The employees' performance reviews (evaluations) are
9 not the Defendants' (Danesha Nichols, Cindy Oropeza, and Brent Seifert) fabricated witch hunt
10 reports (Defs. Exh. S & X). Employees' annual performance reviews are mandated by UC Davis
11 Policy PPSM 23, which has the force and effect of state statutes (see Kim v. Regents of University of
12 California [20001 80 Cal. App. 4th 160. 165). Witch hunt reports are fabricated to hunt down
employees in the UC system who decry the UC Principles of Community as unconstitufional
13
redacted Marxist manifestos that have nothing to do with ariy principles or UC policy. These reports
14
are unlawfully used to condemn outspoken employees or whistleblowers and discipline them to curb
15
their First Amendment rights (free speech rights) and terminate them (Pl.[s]Ex. No.3 PI. [s], Resp.
16
to Admis No.3 p.5-6, Resp. to Admis No.l I p.34, Resp. to Admis No.15 p. 100, and Resp. to
17 Admis No.l7 p.l28).
18 The Plaintiff addressed anfi-Semitism in Pl.[s]Exh.l 1 pp. 29-31. UC Davis is not a particularly
19 pro-Jewish campus. A few years back, American comedian Rosanne Barr, who is Jewish and very
20 Pro-Israel, tweeted: " I hope all the "Jews leave UC Davis & it then it gets nuked!"
21
With regard to African-Americans and Hispanics, the Plaintiff wrote a letter to Defendant Cindy
Oropeza dated November 18, 2013 and tided "Letter of Expectation for Unprofessional Behavior."
22
The letter was dated October 21, 2013 and given to Frank J. Gonzales by Paint Shop Acfing
23
Superintendent Donald Whitley. It addressed racism at the UC Davis Medical Center as follows:
24
EXHIBIT # 29
25
The photos on the UC Davis Health System web page of Dr. Darin A. Latimore,
26
M.D. posing with different ethnic groups of UC Davis students is very interesting.
27 Latimore is African-American, a member of the Task Force on Diversity and
Inclusion, and associate dean for residents' and students' diversity.
28
- 23 -
1 The photos show Latimore posing with different ethnic groups of students but not
those from his racial group—African-Americans. The same can be said of
2 Duruisseau. It would probably be physically impossible for Dumisseau or
3
Latimore to assemble a group of African-Americans at UCDMC for photos. The
charts show that African-Americans and Hispanics are grossly outnumbered by
4 Whites and Asians.
5 The April 27, 2012 YouTube slide show "Welcome to Romania" was exploited by the
6
Defendants (Defs. Exh., R & S). The Plainfiff addressed and explained this in Pl.[s]Ex. No.3 PI. [s]
Resp. to Admis No.l 1 p.27, Resp. to Admis No. 14 p.75,76-77, Resp. to Admis No. 15 p.80,83,
7
Resp. to Admis No. 16 p. 125, and Resp. to Admis No.17 p. 129.
8
9 The Plaintiff was wrongfully terminated after 12 years of service to the university, and the
10 Defendants, instead of appreciating the Plaintiff, portrayed the Plainfiff as a criminal or terrorist
11 using the UC Davis police "persona non grata poster" distributed around UC Davis. It was a gross
12
and despicable violation of the January 30, 2009 Settlement Agreement that the Defendants signed
with the Plaintiff, as this violafion forced the Plaintiff to find another job in the Sacramento area.
13
If the Court examines the table of contents of the Defendants' Motion it will find that sixty
14
percent of these contents have been relitigated and dismissed by anti-SLAPP motion COAs. In
15
addition, the Defendants have incorrectly stated, from pages 9 to 17, that the Plaintiff cannot claim
16
harassment or retaliation. It has been nine years since the Plaintiff was terminated and forced to live
17 g on $1500 social security income, than despicable and inhumane treatment Plaintiff experienced
18 from the Defendants was not harassment. It was a violation of Plaintiff Human and Employee
19 rights by governmental entity corrupted regime . The Plaintiff, from 2011 to 2012, spent most of his
20 time on leave (one year and four months), staying at home and responding to the Defendants' threats
and slander thinking what next and whether he will survive another day. See Plaintiffs 10/9/2011
21
open letter to members of the UC Davis Ethics and Compliance Risk Committee, California State
22
Assembly members, and the regents of the University of Califomia titled, " I FEEL LIKE A
23
HUNTED JEW DURING THE HOLOCAUST" [EXHIBIT #30], and the Plainfiffs November
24
9, 2011 response to the 11/08/2011 letter ["Access to University Email Account" by Department
25 Manager Charies Witcher] titled, "GESTAPO ON MY ASS"[ EXHIBIT #31]).
26 Nothing has changed since October 2011. The Plaintiff sfill feels like a hunted Jew during the
27 Holocaust in occupied Poland by Nazis and is still targeted by the UCOP thugs, Porter Scott's
28 Gestapo, and Soviet Stalin era style NKVD. The Plainfiffs is not only vicfim of UCOP Gestapo
- 24 -
1 Tom Porter Scott and others like them See the links below:
2 https://www.scribd.eom/document/515312517/06-29-1918-PLANTIFF-DISAPPROVAL-OF-THE-
3 ROPOSAL-ORDER-AND-JUDGMENT
https://www.scribd.com/document/468845960/8-3-2018-Excerpt-From-the-Letter-to-FBl-
4
Sacramento-Office
5
https://www.scribd.com/document/508113551/20190729-Petifioner-s-Replv-to-Judge-
6
Armen-Order-Dated-Q7-29-2019
7
The endless investigatory leaves and suspension letters issued by the Defendants in an
attempt to force the Plaintiff to quit his job did not work. The Defendants' counsel is correct to an
10 extent in the motion that the Plaintiff cannot claim retaliation. The Defendants have nothing to
11 retaliate over because the Plaintiff did not do anything worthy of retaliation. Plaintiff did not blow
whistle on UCOP . The Defendants mercilessly and ruthlessly attacked Plaintiff to force the
12
Plaintiff to quit his job, because in 2011, they were ready to resume the unlawfiil sales of power tax
13
free to SMUD. The Plaintiff, as an assistant development engineer at UCDMC, had access to the
14
UCDMC 27 MW cogeneration plant production data via the Metasys system, and Porter Scott
15
attorneys did not like this because they wanted a share from the power sale.
16 L. Defendants Arguments In Memorandum Of Points And Authorities Memorandum Of
17
Points And Authorities In Support Of Defendant's Motion For Summary Judgment Or,
In The Alternative, Summary Adjudication
18
19
Plaintiff was on forced leave for one full year and one month with $ 10,000 loses in his
20
income because of the Defendants inhumane witch hunt which turned Plaintiffs and his family life
21 upside down. Defendants constantly was provoking Plaintiff in his own home by fabricafing
22 unfounded despicable allegations and accusafions and terminating 61 years old Plaintiff at his
23 retirement age base on UCDHS Hate Incidents in the Workplace Policy and the Principles of
24 Community. Work Place Policy is for work place not for Plaintiff home . Principles of Community
25
is not a UC Policy and has no force and effect of state statutes (see Kim v. Regents of University of
California (2000) 80 Cal. App. 4th 160. 165). Pl.[s]Ex. No.3 PI. [s] Resp. to Admis No.3p.5-6,.
26
Resp. to Admis No. 11 p.34, Resp. to Admis No. 15p. 100,. Resp. to Admis No. 17p. 128
27
28
- 25 -
1 M. The Defendants' Separate Statement of Undisputed Material Facts in Support of
Defendants' Motion For Summary Judgment or in the Alternative, Summary
2 Adjudication
3
The Defendants have repeated the same 17 supposedly "undisputed" facts in the remaining
4
four COAs of the Plaintiffs SAC, which are: 5.) violafion of Health and Safety Code, sec. 1278.5;
5
6.) breach of written contract; 7.) wage and hour violafions; and 8.) rescission - unlawful contract.
6
Given the Plaintiffs limited resources and the undue burden imposed on the Plaintiff by
7
relitigating and the redundancy of the already-litigated matters by the Defendants in the anti-SLAPP
8 motion, or resolved in 2008 and 2009 by arbitration and a Settlement Agreement, the Plaintiff is
9 requesting that the Court deny the Motion for Summary Judgement or, an Altemative, Summary
10 Adjudication to the remaining six Defendants. The Plainfiff legifimately disputes most of the 17
11
supposedly undisputed facts, thus the Motion must be denied.
IV. THE TRIABLE ISSUE OF MATERIAL FACTS AS TO THE CAUSE OF ACTION
12
13
A. The Six Cause of Action - The Violation and Breach of the January 30, 2009,
14 Settlement Agreement signed with the Plaintiff by the Regents of the University
15
of California or their Agents on Regents' Behalf.
16 On July 17 and July 24, 2011, Plaintiff sent complaints letters to UC Davis Chief CounselSteven
17 Drown and requested from him to intervene to stop Defendant Danesha Nichols and others from
18 violating the 2009 Settlement-Agreement. UC Davis Chief Counsel Steven Drown was one of four
19 UC Davis employees who had signed the 2009 Settlement on the UC Regents' behalf (EXHIBIT #
20
32 Response To Request for Admission Pl.[s]Exh., Resp. for Admis. No. 12 p p. 46-50)
On August 3, 2011, to September 1, 2011, Plaintiff was placed by his physician. Dr. Harvey
21
Hashimoto from Lodi, on work-related stress leave until September 1, 2011. Plaintiff saw a
22
psychologist to cope with the situafion and stress. Plaintiffs psychologist was Dr. Franklin Bemhoft
23
from Lodi.
24
25
The specific triable issues of material fact as to Six Cause of Action-The Violation and Breach of
26
the January 30, 2009 Settlement -Agreement are outlined in the in the Defs Exh, No. E Plainfiffs
27
28 - 26 -
1 First Amended Answers to Defendant's Regents of the University of Califomia Special
2 Interrogatories to Plaintiff Set One.
3 The Plaintiff Answer to Special Interrogatories from No.33 to No. 39, Page 44-63 are the roughly
4 calculated monetary damages amounted in approximate of $ 1,000, 000 (lost wages and benefits ,
5 home etc.) Pl.[s]Exh.l Resp. for Admis. No.9 p p. 14-16; Resp. for Admis.1 Ip.35
Summary judgment cannot be granted when the facts are susceptible to more than one reasonable
6
inference...." {Rosas v. BASF Corp . (2015) 236 Cal.App.4th 1378. 1392. 187 Cal.Rptr.3d 354.)
7
8
Soria v. Univision Radio L. A., Inc., 5 CaI.App.5th 570, 583 (Cal. Ct. App. 2016)
9 Plaintiff believe that the Court will have no problem to find in the Plaintiff's Opposition to
10
the Defendants Motion for Summary Judgment the facts which are s susceptible to more than one
reasonable inference . The other three remining COAs 5.) violation of Health and Safety Code, sec.
11
1278.5; 7.) wage and hour violations; and 8.) rescission - unlawful contract, are not applicable..
12
Plaintiff's effort to amend the SAC in 2014 and 2015 was blocked by the Court than Plaintiff does what he
13
can with SAC. .
14 It has been nearly 10 years since the Plaintiffs employment was terminated on August 31,
15 2011, followed by the attempt to assassinate the Plaintiff on May 31, 2012, in an ill-conceived
16 provocation by specially assembled thugs, which the Plaintiff refers to in documents as the UC
17 Davis Death Squad.
If the Court examines the Defendants' pleading, the Court will not find one word in any document
18
that the Plaintiff breached or violated the contract written on January 30, 2009, in which the Plaintiff
19
expressed his plan to retire from the University in 2017 at the age of 66. Contrary to the Defendants'
20
statements, the Plaintiff complained about a violation of the signed contract before his employment
21
was unfairly terminated on August 31, 2011, at age 60—six years before the Plaintiffs retirement.
22
23 V. CONCLUSION
24
25 Plaintiff had faith in the justice system and the judicial officers of the Sacramento County
26
Superior Court until he started seeing a different picture of judicial process around January 2015,
after he fired his attorney for gross misconduct in December 2014. Plaintiff hoped that Judg would
27
use common sense, seeing that Plaintiff was held hostage for more than a year on administrative
28
leave, was not given evaluations for his last two years of employment, was punished for unproved
- 27 -
Fl LED/EHDOBSI
1 Jaroslaw Waszczuk, in pro per SEP 22 2021
2216 Katzakian Way
2 Lodi, CA 95242
By: S. Khorn
3
Phone: 209-663-2977 Deputy Clerk
Fax: 209-257-8205
A Email: jjwl980@Iive.com
9
SUPERIOR COURT OF THE STATE OF CALIFORMA
FOR THE COUNTY OF SACRAMENTO
10
11
12
13 )
JAROSLAW WASZCZUK )Case No. 34-2013-00155479
14
)
15 PLAINTIFF, ) Plaintiffs DECLARATION IN SUPPORT
joF THE MEMORANDUM OF POINTS
16 VS. )AND A U T H O R I T I E S IN SUPPORT O F
17 THE UNIVERSITY OF CALIFORNIA, JTHE MOTION FOR
ANN MADDEN RICE, MIKE BOYD, )RECONSIDERATION OF ORDER
18
STEPHEN CHILCOTT, CHARLES )WHICH GRANTED TO T H E
19 WITCHER, DANESHA NICHOLS, ^DEFENDANTS T H E MOTION FOR
CINDY OROPEZA, BRENT SEIFERT, )S U M M A R Y J U D G M E N T OR, I N T H E
20 PATRICK PUTNEY, DORIN DANILIUC, {ALTERNATIVE, SUMMARY
AND DOES 1-50
21 )ADJUDICATION AND REQUEST THAT
)PLAINTIFF'S MOTION FOR
22 DEFENDANTS. I RECONSIDERATION BE TREATED AS
23 A MOTION FOR NEW TRIAL
CAL. CIV. PROC. CODE § 1008
24 DATE: OCTOBER 13,2021
25 TIME: 9:00 A.M.
DEPT: 54
26
27
HON. CHRISTOPHER E. KRUEGER
28
PLAINTIFF'S DECLARATION IN SUPPORT OF THE MEMORANDUM OF POINTS AND AUTHORITIES

MOTION FOR RECONSIDERATION
1 PLAINTIFF JAROSLAW WASZCZUK'S DECLARATION IN SUPPORT OF THE
2 MEMORANDUM OF POINTS AND AUTHORITIES
3
I, JAROSLAW WASZCZUK (Plaintiff), declare as foUows:
4
1. Since December 2014, the Plaintiffhas represented himself in pro per in the above-
5
captioned wrongful termination case against the Regents of the University of Califomia
6
("Defendants" or "Regents").
7
2. In addition to the above, the Plaintiffhas represented himself since March 23,2016 in a
8
whistleblovraig complaint related to his wrongful termmation case against the Regents. The merit of
9 the Plaintiffs whistleblower case is focused on tax evasion andfraud,amounting to millions of
10 dollars, committed by the owners of the 27-megawatt (MW) cogeneration power plant located at the
11 University of Califomia Davis Medical Center (UCDMC), in Sacramento, Califomia, resulting firom
12 the illegal production and sale of electrical power from 1998 to the present. The Plaintiffs
13
whistleblower case is currently pending in the United States Court of Appeals for the District of
Columbia Circuit, docketed as Jaroslaw Waszczuk v. Commissioner of the Internal Revenue
14
Services, Case No. 20-1407. The UCDMC 27-MW cogeneration plant was commissioned in 1998,
15
and since that time has been unlawftilly operated to produce and sell electricity in violation ofthe
16
requirements of Federal Energy Commission Regiilatory Commission (FERC) regulations, 18 C.F.R.
17
§ 292.20. Federal Power Act 16 U.S.C. § 824d(a), Califomia Public Utilities Code Section 218.5,
18 State of Califomia Unfair Business Competition law and Business and Professions Code § 17200 &
19 Califomia Commodity Law of 1990 (Corp. Code, § 29500 et seq., "CCL"), 7 U.S. Code § 6 (b) in
20 violation of section 501 (c)(3) of the Intemal Revenue Code of 1954, and the State of California's
21 Revenue and Taxation Code.
3. The Plaintiff, by representing himself in the whistleblower case in U.S. Tax Court in
22
2018, in 2019 came across former University of Califomia Office ofthe President's (UCOP) human
23
resources director. Associate Vice President Judith Boyette, who interacted with the Plaintiff when
24
he was employed as an operator ofthe UCDMC 27-MW cogeneration plant, from June 17,1999
25
through April 16,2007. In June 2016, just three months after the Plaintiff submitted his Application
26 for Award to IRS Whistleblower Office (WHO) in Ogden Utah, Boyette was appointed by the
27 Secretary of tiie Treasury to a three-year term on flie IRS Advisory Committee on Tax Exempt and
28 Govemment Entities (TEGE),fromJune 2016 - June 2019. This appointment occurred just after UC
- 2 -
1 President (the former Secretary oftiieDepartment of Homeland Security -DHS) Janet Napolitano
2 traveled to Washington, D.C. to meet with President Obama and Vice President Biden. A UC
3 Newsroom article, dated May 19,2016, shows a photo of Napolitano meeting Biden in his West
Wing office on May 18,2016 rhtti?s://www.scribd.com/document/476775292/UTC-20160518-UC-
4
President-Janet-Nat)olitano-Mects-President-Obama-Vice-President-Biden-BIDEND. In addition to
5
meeting with Obama and Biden, Napolitano met with the Secretary of Energy.
6
After Boyette was appointed to the TEGE, the Plaintiff's Whistleblower Application for
7
Reward was filed with IRS WBO en vaiushed for over two years until Plaintiff r sent an update more
than 150 pages long, in August 2018, which was completely unexpected by the IRS' WBO.
4. In August 2005, one of the Plaintiffs coworkers at the cogeneration plant submitted a
10 formal complaint, "Improper Governmental Activities," to Boyette agauist plant managers who
11 knowingly allowed a massive leak of machine oil from the defective cooling gear boxes to discharge
into Sacramento River via a storm drain. Along with his complaint, the PlaintifPs coworker stated
12
that he had severely injured his back from after slipping on the oily surface while performing
13
preventive maintenance beneath the cooling tower. He was taken by ambulance to the UCDMC's
14
ER (see Plaintiffs Exhibit No. 11, in his Opposition to Regents MSJ/MSA). The University did not
15 want to fix the hazard because a new cooling tower was under construction, but oil had been
16 discharged into the river for seven years. The Plaintiff helped his coworker with the complaint;
17 thereafter, they both became targets of a vicious, merciless retaliation campaign. In April 2007, the
18 Plaintiff was brutalized by an abrupt suspension witiiout pay and removed permanentiy from the
19 Plant, along with threats to terminate his employment.

5. Between April 2011 and May 2012, the Regents, in a copycat scenario of August 2005-
20
April 2007, attacked the Plaintiff with the clear intention of removing him from the UC Davis
21
Medical Center premises by any means necessary. The Plaintiff was removed from UCDMC
22
premises on August 31,2011 and terminated one and half years later, on December 7,2012, at the
23
age of 61 .Since December 2012, the Plaintiff and his family suffering at the hands of the Regents
24 advocates from Porter Scott law devastated his Ufe four years prior to his retirement from the
25 University.
26 6. The Plaintiff filed his wrongftil termination lawsuit on December 4,2013, and the Regents
27 and their lawyers, witii the help of tiie Court, dragged their feet, perhaps in hope thattiiePlaintiff
28 would die or leave counti7, or that UC President Napolitano would arrange to place the Plaintiff on
- 3 -
PLAINTIFF'S DECLARATION IN SUPPORT OFTHE MEMORANDUM OF POINTS AND AUTHORTTIES
1 tiie "no fly list," like a terrorist, after the Regents awardedtiiePlaintiff witii a "Persona Non Grata -
2 Most Unwanted Terrorist" UC Davis Police Poster, which was distributed around the campus. This
3
is in sharp contrast to the Al-Qaeda terrorists who were welcomed by the University and hosted for
more than one year in San Diego as they prepared for the September 11,2001 terrorist attacks on
4
U.S. soil (see https://www.scribd.com/document/510484989/Robert-Swan-Mueller-III-20Q0-2001-
5
Fortv-Billion-Fraud-Titled-Califomia-Energv-Crisis-9-11-Terrorists-Attack').
6
7. On May 14,2021, Regents' attomey Lindsay Goulding filed tiie MSJ/MSA (ROA 254-
7
258) with many Declarations in support and other pleadings. Goitiding brought witii the Regents'
MSJ/MSA documents concerning tiie 2007 Regents' attack aimed at the Plaintiff, which resulted in
his suspension and removal from the cogeneration plant. These documents included:
10 1. Exhibit G: Investigative Report, dated March 8,2007 and prepared by Bettye Andreos
2. Exhibit I : March 23,2007 correspondencefromCharles Witcher to tiie Plaintiff regarding
11 tiie Letter of Suspension and Notice of Reassignment
3. Exhibit J: April 16,2007 correspondencefromCharies Witcher to the Plaintiff regarding
12
Letter of Suspension and Notice of Reassignment
13
14
The Defendants' attorney Goulding repeated her 2007 MSJ/MSA slander witii tiie following
exhibits from tiie 2011-2012 witch hunt aimed at the Plamtiff:
15
1. Exhibit L: August 31,2011 correspondence from Charles Witcher to tiie Plaintiff regarding
16 the Notice of Investigatory Leave
2. Exhibit M : May 11,2012 correspondencefromCharles Witcher to the Plaintiff regarding
17
tiie Notice of Intent to Suspend
18 3. Exhibit N: May 31,2012 correspondencefromCharles Witcher to tiie Plauitiff placing tiie
Plaintiff on investigatory leavefromMay 31 through June 13,2012
19 4. Exhibit O: September 25,2012 correspondencefromCharles Witcher to the Plaintiff
regarding the Notice of Intent to Dismiss
20
5. Exhibit P: December 5,2012 Letter of Termination sent to the Plaintiff
21
22 8. The Plaintiff, in his preparation to object to tiie Regents' MSJ/MSA filed by Goulding on May
14,2021, took a closer look at some documents from March-April 2007 and April-May 2012,
23
which were portraymg the Regents' attempts to terminate the Plaiatiffs employment. The Regents'
24
MSJ/MSA Exhibit I: March 23,2007 Letter of Intent to Suspend and Notice of Reassignment.
25
Exhibit J: April 16,2007 Letter of Suspension and Notice of Reassignment, are ahnost identical in
26
style and form, when compared wdth the Regents' MSJ/MSA Exhibit M, May 11,2012 unsigned
27 Notice of Intent to Suspend and Plaintiff's Objection to the Regents' MSJ /MSA, Exhibit No. 16
28 Letter of Intent to Suspend.
- 4 -
1 Furthermore, in an identical situation in March-April 2007 and April-May 2012, someone
2 stopped tiie Plaintiffs employment termination. In 2007, after the Plaintiff was removedfromtiie
3
UCDMC cogeneration plant and moved to the HVAC shop, the Plaintiff received on July 25,2007 a
good evaluation for the 2006/2007 evaluation period signed by his department manager and two
4
other superintendents, who had supposedly accused the Plaintiff of misconduct Nothing was
5
mentioned intiiePlaintiffs evaluation about what was vmtten about tiie Plaintiff in the March 23,
6
2007 and April 16, 2007 Letters of Suspension and Reassignment. In May 2012, one day before the
7
Plaintiff was unlawfully suspended on May 11,2012, tiie Regents' MSJ/MSA ExhibitM tiie
UCDMC HR Labor Relations Consultant Joel Vandevier, had been e-mailing with his manager,
Travis Lindsay, about providing tiie a new job description for the Plaintiffand about the suspension
10 of two oftiiePlaintiffs supervisors, Dorin Daniliuc and Patrick Putney, not the Plaintiff (Pl. 'Objec.
11
to Regents MSJ/MSA Exh. Nos. 17 & 18).In June 2011, Vandviver was terrorized, terrified, and
fired from the job (Plaintiffs Public Record file) and replaced by Gina Harwood (Pl. 'Objec. to
12
Regents MSJ/MSA Exh. No. 22).who participated in witch hunt against Plaintiff smce June 2011.
13
14 9. The Regents' MSJ/MSA Exh. J April 16,2007 Letter of Suspension and Notice of
15 Reassignment is stamped in the top right comer with the date April 18,2007, and "No. 11610" and
16 the initials "MG" are handwritten. Most likely, these are the iiutials of Maria Garcia,fromtiieUC
Davis Health System Risk Management Department. This means that the Plaintiff was subject to
17
termination after he was abmptiy reassigned and removed from the cogeneration plant to the HVAC
18
shop. Maria Garcia was a friend of the former Porter Scott attorney George Acero. Acero, prior to
19
joining Porter Scott in 2003, was an intern in the University of Califomia's Office oftiieGeneral
20
Counsel. The above fact led the Plaintiff back to tiie August 2005 cover letter that his coworker,
21 William Buckans, sent to UC HR Vice President Boyette containing his whistleblower "Improper
22 Govemmental Activities" complaint. The letter, which the Plaintiff helped Buckans to write, stated,
23 " I am not sure if this report should be ftied with your office, but I am pretty sure that you are tiie
24 most knowledgeable person in the Office of the President about the past problems in UCDMC
Central Plant. I believe that you, as a former attomey at law and partner of the famous Pillsbury
25
Madison and Sutro law firms, have the ability to estimate the damages caused by management
26
from the Central Plant." Pilsbury and Sutro attomey and Boyette's colleague represented the
27
Plaintiffs former employer, Destec/Dynegy, against the Plaintiff in tiie overtimefraudcase. The
28
case ended in tiie Court of Appeal, Third Appellate Distiict Case No. C030005, Waszczuk v. Destec
- 5 -
PLAINTIFF'S DECLARATION IN SUPPORT OF THE MEMORANDUM OF POINTS AND AUTHORFIIES
1 Energy Inc., on December 3,1999. The Plaintiff prevailed while representing himself. This case led
2 to the disclosure of $240 million Destec fraud against Pacific Gas and Electric Company, due to tiie
3
same violation oftiierequuements of FERC regulations, 18 C.F.R. $ 292.20. Federal Power Act 16
U.S.C. § 824d(a), California Public Utilities Code Section 218.5, State ofCalifomia Unfair Busuiess
4
Competition Law, Business and Professions Code § 17200 & Califomia Commodity Law of 1990
5
{Covp. Code, § 29500 et seq., "CCL") and 7 U.S. Code § 6 (b), as UCDMC's 27-MW cogeneration
6
plant has been violating and unlawftilly generating power for tax-free profit since 1998. Most likely,
7
Boyette alerted UC General Counsel and form UC General Counsel intern Acero and his partner,
8 Michael Pott, who in 2005 represented the Regents against UCD Davis Employee Randy Vergos,
9 Case Vergos v. McNeal, 146 Cal.App,4tii 1387 (Cal. Ct. App. 2007). The Plauitiff defeated tiie
10 Regents in 2008 in arbittation; then, Acero left Porter Scott and Boyette left the UC Office of the
11 President, but Acero, Boyette, and Porter Scott did not forget fhe Plaintiff. This istiiereason why the
Plaintiff became a subject to be erasedfromthe UC Davis Medical Center premises. They all
12
learned how much money the illegally produced power by the UCDMC power plant is worth is
13
worth for them . The lives of other people are not important for organized white collar crime mob,
14
15 10. When Plaintiff on November 2,2012 received requested documents sent to hun by UC
16 Davis Information Practices Analyst Elizabet Wisnia and read some ofthe documents in most part
blacked out than on November 14,2012 Plaintiff sent the email to his son and daughter stating ;
17
From: Jerry Waszczuk <jerrywaszczuk@yahoo.com>
18 Sent: Wednesday, November 14,2012 4:59 AM
19
To: JOANNA WASZCZUK <Z3Elite@aol.com>; George Waszczuk <gwaszczuk@gmail.com>
Subject; Fw: Brief for Oral Response -Notice Intent to Dismiss. - UCDMC "HR Death Squad"
20
• Hi Kids ;
21 To make long story short. On May 31,20121 was scheduled to report to work after 10
22 months of work .
My Employer UC Davis Medical Center had a different plan for me . They just crafted quite
23 good plot to kill me or to send me to Medical Center Trauma Unit disabled or death .
It is just got discovered and I am not sure how it is going to turn out. Something is very big
24 behind this but I am not sure what is it
25
If something will happen to me then take care of mama and go to court to sue this UC. Is
over 300 K on my UC account than if something go wrong than mama will cash the money
26 and use it to get good lawyer. They got with me in war game with Police forces .
That it. If something than contact my two friends Kermy Diede 1-916-812-3408 or William
27 Buckans 1-916-541 1738
28
- 6 -
1 I am representing them and other guy against my employer in 8 different cases. They have
my file also and they are scared .
2 Other than that, I don't like to bother you. J.
3
11. George Acero must have liked the PlaintifFs comments intineDavis Vanguard h\og
4
about the UC Davis Principles of Community, as he sharedtiiemin May 2013 witii his friend at tiie
5 UC Davis Medical Center, ariskmanagement analyst named Maria Garcia, who was heavily
6 involved in the Plaintiffs employment termmation according to documents Plaintiff received in
7 2015 from former Porter Scott's Attomey Douglas Ropel and under the Provision of Public Record
8 Act. Acero also was a friend of the former California Supreme Court Justice Hon. Cmz Reynoso,
Justice Reynoso was a decent man, so it is unclear how his name was dragged into the malicious but
9
professionally orchestrated November 18,2011 pepper spray provocation to destroy tiie UC
10
Chancellor Linda Katehi, UC Davis Police Chief Annette Spicuzza, Lt John Pike, and Cpt. Joyce
11
Souza.. The Plaintiff addressed the Justice Reynoso's 2011-2012 Pepper Spray Task Force report in
12
lis March 2016 Tax Evasion and Fraud IRS Whistleblower Complaint about Violation of Section
13 501(c)(3) ofthe Intemal Revenue Code of 1954 by the Regents This Reynoso's Task Force members
14 and his pseudo investigation report desttoyed the lives of many good people, solved nothing, and
15 further concealed the uncontrolled cormption and racketeering in the UC Office ofthe President and
16 in UC Davis Campuses . Another former Supreme Justice for hire is Former Supreme Court Justice
17 Carlos Moreno. When the Plaintiff was writing his tax evasion whistleblower report in March 2016,
he thought that it was the Chancellor Katehi who gave a green light to HR Director Stephen
18
Chilcott to fire the Plaintiff in 2011 -2012 witch hunt. However, Plaintiff did his research, after the
19
Califomia most popular senator and staunch adversary ofthe UCOP mob theCalifornia Senator
20
Leland was tiirown into federal prison in March 2016 after the unsuccessful attempt to eliminate
21
him by the September 10 , 2010 natural gas pipe explosion in San Bnmo, CA The UC Davis
22 Chancellor Emeritus Larry Vanderhof and SMUD's former executive Jan Schori were appointed to
23 investigate the San Bmno explosion which killed 8 people and destroyed whole neighborhood .
24 https://www.scribd.com/document/484722125/Witch-Hunt-Auned-at-President-Donald-
Tmmp-versa-Witch-Hunt-Pemetuated-by-the-California-Political-Mob-against-Califomia-Senator-
25 Leland-Yee
26
12. At tiie same in 2016 UC President Napolitano paid $1,000,000 to two of her friends,
former federal prosecutors Malinda Haag who prosecuted Senator Yee and McGregor Scott, to
27
witch hunt and destroy chancellor Katehi thus Plaintiff looked into who and why Katehi's and Yee's
28
- 1 -
MOTION POR RECONSIDERATION
1 and other including Plaintiffs normal life and livelihood were tarnished and mercilessly and
2 rutiilessly desttoyed by tiie UCOP mob or thek evil advocates 1 namuig a few of them like Acero
3 , Pott, Burkett, Haynes , Boyette, Riordan, Goulding, Drown, Chilcott, Delmendo, Petiiilakis,
Robinson, Sheehan and many other unknown to Plaintiff. .
4
13. In 2016, Napolitano was given $175,000,000 by tiie Regents to pay a ransom, most likely
5
to Porter Scott attorneys and pay off the owners oftiieUC Davis Medical Center 27-MW
6
cogeneration plant, but she was caught by the state auditor, due to an audit requested by Senator
7 Leland Yee's friend. Assembly Member Phil Ting (Pl, [s] Exh 24) who (Federated Univ. Police
8 Officers Ass'n v. Superior Court ofAlameda Cnty., 159 Cal. Rptr. 3d 541 (Cal. Ct. App. 2013).Itdid
9 not work out and UCDMC 27 MW cogeneration plant is idlmg at house load and owner oftiieplant
10 are loosing money because Porter Scott attorney had an idea to go after Plaintiff and destroy his life .
11 The Assembly Member Phil Ting is the former Phil Ting was appointed San Francisco
Assessor-Recorder in 2005 by then-Mayor Gavin Newsom, becoming San Francisco's highest-
12
ranking Chinese-American official at the time and most likely he was a friend ofthe former Senator
13
Leland Yee or they knew each other . Assembly Ting by his profession knew what to look for.
14
Governor Newsom and two former Califomia former AG's Xavier Becerra and Kamala Harris know
15
what Janet Napolitano need $ 175,000 ,000 in 2016.
16 htii3s://www.scribd.com/document/508113551/20190729-Petitioner-s-Replv-to-Judge-
17
Armen-Order-Dated-07-29-2019https://www.scribd.com/document/508113551/20190729-
Petitioner-s-Replv-to-Judge-Armen-Qrder-Dated-07-29-2019
18 This enormous tax evasion committed by the cormpted University of Califomia
19 administtation is a classic example of underground economy sponsored by Califomia Govemment.
The undergrovmd economy hurts all CaUfomia taxpayers Approximately $8 billion m sales, use,
20
corporate, and personal taxes is owed and goes uncollected in Califomia each year.Tax revenues that
21
support govemment services such as schools public safety, hospitals, parks, and roads are lost.
22
Workers are deprived of basic employment protections. Criminals operating in tiie underground
23
economy do not comply with state tax laws and have an illegal, unfair advantage over honest
24
businesses.
25 by subjecting them to forced labor and deplorable living conditions.
26 14. The aforementioned former Porter Scott attomey, George Acero, together witii Michael
27 Pott, UC Associate Vice Chancellor Allen Tollefson, and others like Chilcott, Nichols , Boyd,
28 Seifert desttoyed tiie lives of Randy Vergos ,Vergos v. McNeal, 146 Cal.App.4tii 1387 (Cal. Ct.
- 8 -
1 App. 2007) and many otiier UC Davis employees like Nam Un Hui Nam, Un Hui Nam v. Regents oj
2 the Univ. of Cal, 1 Cal.App.5th 1176 (Cal. Ct. App. 2016) or Janet Keyzer who lobbied for Senator Leland
3 Yee' inttoduced bill protecting UC whistieblowers or Donna McDaniel who killed herself due UC
Davis Management hostility or Plaintiff Waszczuk v. Regents of Univ. of Cal, C079524 (Cal Ct.
4
App. Oct. 10, 2017) or Plamtiffs supervisors Dorin Daniliuc . Daniliuc v. Daniliuc (In re Marriage
5
ofDaniliuc), C084293 (Cal. Ct. App. July 3,2018) or Patinck Putiiey because of evil Porter Scott
6
attomey's criminally minded conduct.
7
15. UC Davis Associate Vice Chancellor Allen Tollefson was assigned as a Skelly reviewer
8
in September 2012 to review the termination of the Plaintiffs employment at the UC Davis Medical
9
Center. Tollefson was a key player in the 2007 3DCA anti-SLAPP motion case Vergos v. McNeal,
10
146 Cal. App. 4tii 1387 (Cal. Ct. App. 2007) crafted by Porter Scott Attomeys Acero and Pott to
11
desttoy Vergos and Plaintiff in 2007 and thereafter many other workers lives .
12
16. As the Plaintiff describes above, in May 2012, there were discussions between UCDMC
13
HR consultant Joel Vandeviver and HR labor relations speciaUst Travis Lindsay to provide the
14
Plaintiff with a new job description in conjunction vdth a new title. Senior Development Engineer.
15
What this obviously meant was that the Plaintiff would be retuming to work in May 2012, after the
16 Regents had tested the Plaintiff for 10 months to see whether he would blow the whistie on the
17 Regents for the unlawful operation of the cogeneration plant witiiout paying taxes on the unlawful
18 profit. The Plaintiff never had any intention of reporting the Regents, because he did not know
19 whetiier plant operations violated the law, and the Plauitiff did not care. The Plaintiff wanted to
retire from the university in 2017, but someone blackmailed the Regents in May 2012, causing
20
devastation to the Plaintiffs life and the Regents or owners ofthe cogeneration plant to lose tens of
21
millions of tax-free dollars. Many Uves were famished and devastated because Porter Scott
22
shareholders wanted to be share holders y of the profitsfromthe power sales produced by
23
UCDMC's 27-MW cogeneration plant.
24 17. In March 2018, the Plaintiff discovered that, in Febmary 2012, someone requested the
25 Court file from tiie Plaintiffs 1999 3DCA Appellate Case No. C030005 Waszczuk v. Destec, which
26 was related to the Plamtiffs former employer, Destec Energy, which was involved in a $24,000,000
27 fraud (Plaintiffs Obj. to Regents MSJ/MSA Exh, No. 9). The 3DCA Register of Action (ROA)
28
shows that die file was requested on Febmary 16,2012, eight days after the Plaintiff held a meeting
- 9 -
1 witii UCDMC HR Manager Humberto Garcia to fmd an mformal resolution to the conflict. The file
2 was retumed to 3DCA on May 22,2012, which corresponds with thetimetiiePlaintiff should have
3
returned to work. Instead, the Plaintiff was abmptiy suspended and not allowed to retum. HR
Manager Humberto Garcia and his assistant Joel Vandeviver who prepared new job description for
4
Plaintiff in May 2012 were fured on in June 2012. The Plaintifffriedto fmd out by askingtiie3DCA
5
Clerk who had requested his3 DCA court file in Febmary 2012, but this was to no avail.
6
CONCLUSION
7
Given the above material facts and events, the Plaintiff prays that the Court grant the Motion
8 for Reconsideration to Plaintiff and reverse or modify the September 1,2021 Order - decision, and
9 so allowtiiePlaintiff to amend the defective SAC filed seven years ago by the Plaintiffs former,
10 now disbarred, and drug-addicted attomey, whose actions were coerced by $340,000 from Porter
11
Scott attomeys who have cost tiieir own client tens of millions of dollars in losses by hunting down
the Plaintiff since 2005. The Regents are not fighting the Plaintiff. It is Porter Scott shareholders
12
who are fighting the Plaintiff and who have been blackmailing the Regents for the last nine years.
13
There is no other explanation for why this case is still pending after eight years and the on
14
September 1,2021 and the Court mled on September 1,2021 tiiat the Plaintiffhas no case.
15
I make tiiis Declaration based on my own personal knowledge, except forthe facts stated on
16
information and my belief as to such facts, and I believe them to be tme. If called upon to do so, I
17
could and would competentiy testify about the matters asserted herein.
18
I declare under the penalty of perjury ofthe laws ofthe State of Califomia that, to the best of
19
my knowledge, the foregoing is tme and correct and that this Declaration was executed on the
20
September 21 >20^1 in Lodi, Califomia.
21
\
22
23
24
Jaroslaw "âszczuk, Plaintiff in Pro Per
25
26
27
28
- 10 -
PLAINTIFF'S DECLARATION IN SUPPORT OFTHE MEMORANDUM OF POINTS AND AUTHORITIES
1
PROOF OF SERVICE
2 Re: Jaroslaw Waszczuk v. The Regents of the University ofCalifomia

Case No.: 34-2013-00155479
3
4
I, Irena Waszczuk the undersigned, declare that I am over 18 years of age, and I am not the party of
5
this proceeding. My address is 2216 Katzakian Way, Lodi, CA. On September 21, 2021,1 served a
6
ttue copy ofeach ofthe following: PLAINTIFF'S DECLARATION IN SUPPORT OF THE
7 MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF THE MOTION
8 FOR RECONSIDERATION OF ORDER WHICH GRANTED TO THE DEFENDANTS
9 THE MOTION FOR SUMMARY JUDGMENT OR, IN THE ALTERNATIVE, SUMMARY
10 ADJUDICATION AND REQUEST THAT PLAINTIFF'S MOTION FOR
11 RECONSIDERATION BE TREATED AS A MOTION FOR NEW TRIAL
12
Bye-mail: lgoulding(5),porteTscott.comto:
13
14
Lindsay A. Goulding
15
17 Sacramento, CA 95825
18
19 1 declare under penalty of perjury of the laws of the State of Califomia that the foregoing is tme and
correct.
20
21 Executed on September 21 2021, at Lodi, CA.
22
23
24 Irena Waszczuk
25
26
27
28
- 11 -
HOURLY CALL OPTION
POWER PURCHASE AGREEMENT
BETWEEN
THE REGENTS OF THE UNIVERSITY OF CALIFORNIA
AND
SACRAMENTO MUNICIPAL UTILITY DISTRICT

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$2111 Efranriscn, (1:3 8411328551]
(415) 557-1200
Fax (415) 557-1266
Website: http://cjp.ca.gov
September 16, 2021
Jaroslaw “Jerry” Waszczuk

2216 Katzakian Way
Lodi, CA 95242
Dear J aroslaw “Jerry” Waszczuk:
This letter is to acknowledge receipt of your recent complaint against California

judges. We appreciate your time and effort in bringing this matter to the commission’s
attention. We are presently reviewing this information and, if further information is
needed, you will be contacted. You will be advised in writing, at a later date, of the
commission’s action in this matter.
To give you some information about the process, each complaint about a judge is
voted upon by the commission. When a complaint states facts which could be
misconduct, if the facts are true and there is not another explanation for what happened,
the commission typically opens an investigation. The commission’s staff will interview
witnesses, review documents or files and conduct other investigation. If there is
sufficient evidence supporting the complaint, the judge will be contacted and asked to
respond to the allegations. The commission then reviews the available evidence, and the
judge’s response if the judge was contacted, to make a determination whether misconduct
has occurred. Misconduct must be established by clear and convincing evidence, a
higher standard than is required in civil cases but lower than in criminal cases. If the
evidence does not support a finding of misconduct, the commission will close the case.
The commission may also close the case if the misconduct was relatively minor and the
judge has acknowledged the problem and taken steps to prevent it from happening again.
If the evidence supports a finding of misconduct and the commission determines that
discipline may be appropriate, the commission may proceed to impose discipline.
It may also be helpful to explain that the Commission on Judicial Performance is

not a court. It does not have the authorityto reverse a judge’s decision, move your case
to another department or court, disqualify a judge or otherwise get involved in your case.
The commission’s role is limited to reviewing allegations of judicial misconduct. A
judge’s legal rulings and discretionary deciswn—making, without more, are not a basis for
review by the commission. Even ifajudge’s decision is later determined by an appellate
September 16, 2021
Page Two
court to be legally incorrect, that by itself is not a violation of the Code of Ethics and is
not misconduct. A judge’s legal error might be a basis for investigation by this
commission if there is sufficient evidence of bad faith, bias, abuse of authority,disregard
for fundamental rights, intentional disregard of the law or any purpose other than the
faithful discharge of judicial duty.
Lastly, our office is not able to provide legal advice. If you wish to determine
what legal avenues are available to you, you might consider contacting an attorney or
legal services provider to see if they can help you.
Very truly yours,
Michelle Kern
Secretary to Trial Counsel
Confidential under California Constitution,

Article VI, Section 18, and Commission Rule 102
Jaroslaw ‘Jerry’ Waszczuk
2216 Katzakian Way
Lodi, CA 95242
Phone: 209-687-1180
Fax: 209-729-5154
August 17, 2023
Via E-mail/Fax
Stephen D. Ruiz
Mohan Harris Ruiz LLP
1806 W Kettleman Ln, Ste L
Lodi, CA 95242-4316
Subject: The University of California’s Office of the President and its involvement in the witch
hunt and prosecution of Lodi daycare provider Dorothy Bernhoft and her husband, Lodi
psychologist Franklin O. Bernhoft, Ph.D.
Re: Superior Court of California, County of San Joaquin case People of the State of
California v. Dorothy Ann Bernhoft, Case CR-2012-4029037, LPD Case No. LP12-00795
and Superior Court of California, County of San Joaquin case Mason Metler v. Dorothy
Bernhoft, Case No. STK-CV-UPI-2013-0000327, and Chiara Calarossi v. Dorothy Bernhoft,
Case No. STK-CV-UPI-2012-0008206
Following 30 minutes of victim impact speeches, Bernhoft stood up, turned toward
the parents and denied any wrongdoing.
“I know that no harm was ever done to a child in my home,” she said while
brushing away tears. “Your children were not left in car seats or portable cribs all
day. This is simply not true.”
FRANKLIN BERNHOFT said his wife was “the most spiritual woman he knows,”
and that his wife would never hurt any children.
Dear Mr. Ruiz:

I am sorry to be bothering you by writing to you about your former clients, Dorothy
Bernhoft and her husband Dr. Franklin O. Bernhoft (the Bernhofts). However, it appears that, for
many reasons, the retaliation aimed at Dr. Bernhoft in 2011 and in 2012 by my former employer,
the University of California, and more specifically by the University of California Office of the
President (UCOP), negatively impacted my litigation against the UCOP and the Regents of the
1
Letter to Stephen D. Ruiz, Re: Psychologist Franklin O. Bernhoft, Ph.D.
University of California (The Regents), which has been pending in the California State and
Federal Courts since December 2013.
You probably would never have heard of the Bernhofts if you had not been hired or
retained by Franklin O. Bernhoft, who in August 2011 I hired to help me cope with the work-
related stress I was suffering due to a witch hunt orchestrated by the UCOP’s white collar
criminals. I was employed by the UC Davis Medical Center (UCDMC) from June 27, 1999
through December 7, 2012. You can read the full story about this in my September 3, 2022
Addendum to the Application for Award for Original Information (IRS Form 211), which I
submitted to the IRS Whistleblower Office in Ogden, Utah.
I addressed the Bernhofts in my IRS Form 211 addendum on pages 101–121,
Crime.
Almost simultaneously, on December 2 and 4, 2013, Sacramento County Superior Court Writ
of Mandamus, Case No. 34-2013-80001699, Jaroslaw Waszczuk v. California Unemployment
Insurance Appeal Board (CUIAB) and Real Party of Interest (RPii) and Sacramento Superior Court
Wrongful Termination Case No. 34-2013-00155479, Jaroslaw Waszczuk v. The Regents of the
University of California, were filed in Sacramento County Superior Court, instead of being filed in
San Joaquin County Superior Court.
I filed these lawsuits two months after Judge Morgan, from San Joaquin County Superior
Court, wrongfully sentenced Dorothy Bernhoft to four years’ probation with many conditions.
It would be a different story if I had hired a different attorney in November 2013 and if my
cases had not been filed and pursued in the wrong county, Sacramento County Superior Court,
instead of San Joaquin County Superior Court.
To make a long story short, the Bernhofts paid a heavy price because Dr. Bernhoft, as my
psychologist, sent a letter on my behalf to Liberty Life Assurance Company of Boston (Liberty) on
December 14, 2011 addressing the conspiracy in which the UCOP attorneys denied to me my Short
Term Disability Insurance benefits in November 2011 and attempted to terminate my employment in
2
December 2011 (see attached). The first attempt by the UCOP to terminate my employment was set
for September 23, 2011, but the plan was prematurely leaked to my physician from Lodi, Harvey
Hashimoto. He worked in coordination with Dr. Bernhoft to place me on work-related sick leave until
January 5, 2012.
This infuriated the UCOP, and they took action to separate me from Drs. Hashimoto and
Bernhoft. After I submitted my Short Term Disability Claim to Liberty on September 27, 2011, the
UCOP administrators conspired with a Liberty representative to remove Bernhoft and Hashimoto
from my orbit, to cancel my work stress-related sick leave, and to fire me from my job on December
12, 2011.
After Bernhoft sent his letter to Liberty on December 14, 2011, UC Senior Vice President
Daniel Dooley engaged his wife, Diana Dooley, to punish Bernhoft for his actions. Mrs. Dooley was
appointed Secretary of the California Health and Human Services Agency (CHHS), where she
oversaw 13 departments, including the California Department of Social Services (CDSS).
Prior the raid on the Bernhofts’ residence on January 31, 2012, Daniel Dooley was key player
in the November 18, 2011 pepper spray provocation on the UC Davis campus that used student
protests to remove from their posts UC Davis Chancellor Linda Katehi and three UC Davis police
officers, to whom I had complained about the witch hunt in October 2011. Katehi refused to
terminate my employment after she requested and received a report on me from the UCDMC Human
Resources Department and the UC Davis police.
At the same time, in 2012, when San Joaquin County DA Kristine Reed was prosecuting
Dorothy Bernhoft, the California Health and Human Service Agency, headed by Diana Dooley, was
used by the FBI to frame California Senator Leland Yee (Yee was also psychologist). Senator Yee
had been after the UCOP executives and The Regents since he was elected California Senator on
December 4, 2006. Yee, in his feud with the UCOP, was looking intently into where the UCOP
executives were getting millions of uncounted dollars and enormous pay raises and bonuses. On the
same day Yee was elected California Senator, December 4, 2006, the UCOP assigned a witch hunter
to frame me and fire me from my job. In 2007, I had no clue why I was being targeted, and I never
thought that my complaints about unpaid overtime made to my previous employer (prior to UCDMC)
3
would result in me being hunted down at the UCDMC, where I was hired in June 1999 as a
cogeneration power plant operator to operate and maintain a 27-MW cogeneration power plant.
Please see San Joaquin County Superior Court case Jaroslaw Waszczuk v. Destec Energy Inc., Case
No. CV000737 3DCA Case Number C030005,
https://www.scribd.com/document/489028741/February-1999-Fire-in-My-Daughter-s-Apartment-
San-Carlos-California.
In 2012, I became an object of the UCOP thugs’ vicious attacks in an attempt to frame me
with Lodi and UC Davis Police for criminal prosecution and deport me to my native country, Poland.
https://www.scribd.com/document/622340707/09-26-2012-Most-Unwanted-Poster-and-
Pepper-Spray-Settlement-Agreement
In February 2015, The Regents’ attorney from the Porter Scott law firm was making threats
in Court that he would go after my wife if I did not drop my litigation. Shortly thereafter, in the
summer of 2015 and three years after my termination of employment with the UCDMC, I found out
why I had been targeted by the UCOP since 2005 to erase me from the UC payroll and UCDMC
premises.
Another provocative and heated discussion was instigated by Sacramento County Superior Court
Judge David Brown during a Court Hearing on April 10, 2015, after which Judge Brown sent Lodi
Police to my residence.
Two years after Dorothy Bernhoft was sentenced to four years’ probation by San Joaquin
County Superior Court Judge Brett Morgan and became collateral damage due to the 2011–2012
UCOP crusade against her husband, I addressed for the first time the January 31, 2012 CDSS and
Lodi Police raid on the Bernhofts’ residence in Lodi and reason behind the witch hunt. I did this in
my proposed Third Amended Complaint (TAC) to Sacramento County Superior Court Wrongful
Termination Case No. 34-2013-00155479, Jaroslaw Waszczuk v. The Regents of the University of
California (https://www.scribd.com/document/391819456/TAC-PROPOSED-THIRD-AMENDED-
COMPLAINT-pdf).
4
At relatively the same time, in March 2016, when you stipulated the terms for a new trial in the
Bernhofts’ case, I retrieved from San Joaquin Superior Court and copied 167 pages of documents
from their cases, which included, but was not limited to:
• State of California - Health Human Services Agency California Department of Social

Services (CDSS) Community Care Licensing Division Complaint Investigation Report
dated January 31, 2012
• Legal Division CDSS filed by Attorney Cori A. Dutra, charges against Dorothy Bernhoft
In the Matter of: Dorothy Bernhoft CDSS- Case No.7012032101, filed February 2, 2012
• August 6, 2012 criminal complaint filed in San Joaquin County Superior Court against
Dorothy Bernhoft by the San Joaquin County District Attorney (DA) Deputy Kristine
Reed: The People of the State of California v. Dorothy Ann Bernhoft, Case No. CR-2012-
4029037 No. LP12-00795
It was not difficult to figure out from the fabricated counts in the criminal complaints that those
aimed at Dorothy Bernhoft coincided with the time when I retained her husband as my psychologist
(August 2011 through the CDSS and Lodi Police raid on the Bernhofts’ residence in Lodi, January
31, 2012). If the CDSS team that entered the Bernhofts’ residence on January 31, 2012 at 11:30 a.m.
had called 911 right away, Lodi Police would have supposedly witnessed Dorothy Bernhoft’s cruel
treatment and endangerment of children in her daycare center and rescued them. Had this happened,
it would have been a different story. The CDSS hit team did not even take any photos to document
Dorothy Bernhoft’s alleged crimes.
By reading the CDSS Investigation Reports, one dated January 30, 2012 and other dated
January 31, 2012, the CDSS Complaint in the Matter of Dorothy Bernhoft No. 7012032101, dated
February 2, 2012, and the San Joaquin County DA Criminal Complaint filed by Deputy DA Kristine
Reed on August 6, 2012, you can find only two specific dates on which Dorothy Bernhoft was said to
have committed her alleged crimes.
On December 20, 2011, CDSS visited the Bernhofts’ residence; thereafter, the CDDS alleged
that, on or about December 20, 2011, five infants and three preschool children were present in the
facility without an assistant. This CDSS visit occurred six days after Dorothy Bernhoft’s husband and
my psychologist at the time sent his letter to Liberty, causing the termination of my employment to
be put on hold.
5
On March 23, 2016, with more details, I further addressed the January 31, 2021 CDSS and
Lodi Police raid on the Bernhofts’ residence in my complaint to the California Commission on
Judicial Performance against Sacramento County Superior Court Judge Shelleyanne W. L. Chang,
who presided over the Writ of Mandamus, Case No. 34-2013-80001699, Jaroslaw Waszczuk v.
California Appeal Board (CUIAB) and Real Party of Interest (RPii)—The Regents of the
University of California (UC Regents), which was filed wrongfully by my (now) former attorney
Douglas Stein on December 2, 2013 in Sacramento County Superior Court, instead of in San
Joaquin County Superior Court.
https://www.scribd.com/document/665613256/03-23-2016-Commission-on-Judicial-
Performance-Complaint-Against-Sac-County-Superior-Court-Judge-Shelleyanne-Chang
Also on March 23, 2016, I submitted a complaint to the State Bar of California against 23
attorneys who, in one way or another, participated in the witch hunt and devastated my life at
retirement age. One of the attorneys in my complaint was former UC Senior Vice President
Daniel Dooley, who was behind the raid on the Bernhofts’ residence. To my complaint with
State Bar, I attached as an exhibit the complaint to the Commission on Judicial Performance
against Chang. In March 2016, I did not know yet that Diana Dooley was Daniel Dooley’s wife.
https://www.scribd.com/document/514642957/3-23-2016-Complaint-with-the-State-Bar-Case-No-
16-15525
On April 6, 2016, I sent a letter to San Joaquin County Deputy DA Kristine Reed addressing
raid on the Bernhofts’ residence with an attached copy of my March 23, 2016 complaint against
Sacramento County Superior Court Judge Shelleyanne W. L Chang
(https://www.scribd.com/document/661108401/04-06-2016-Bernhoft-s-Criminal-Case-Letter-to-San-
Joaquin-County-DA-Kristine-Reed).
Also in March 2016, I submitted a whistleblower complaint against the UC Regents for tens
of millions dollars in tax evasion and fraud due to violations of Internal Revenue Code 501 (c)(3), in
relation to the illegal power production and sale from the UCDMC’s 27-MW cogeneration plant,
where I was once employed as an operator.
The illegal power sale was the reason why the UCOP mob went after me and anyone
associated with me, including Franklin Bernhoft. For this complaint, I retained an attorney, Mark
6
Schlein, from the prestigious law firm Baum, Hedlund, Aristei & Goldman Law Corporation, based
in Los Angeles. My super lawyer did not last long. UC President Janet Napolitano (the former
Secretary of the US Department of Homeland Security) departed in June 2016, and former UC Vice
President Judith Boyette was named to the IRS Advisory Committee on Tax Exempt and
Government Entities (TEGE) to take care of my whistleblower complaint and my attorney Schlein
(see https://www.wisnerbaum.com/attorneys/mark-h-schlein/).
The June 2018 press information that California Governor Jerry Brown appointed on May 31,
2018 Diana Dooley as his executive secretary led me to information that she was Daniel Dooley's
wife. At the same time, I found that the CDSS attorney Cori A. Dutra, who filed the charges against
Dorothy Bernhoft on February 2, 2012 in CDSS Case 7012032101, was a friend of Porter Scott
attorney David Burkett, who represented The Regents in my wrongful termination and
unemployment benefits case from February 2015 through October 2019. I described in detail my
findings about the CDSS’s January 31, 2012 raid on the Bernhofts‘ residence in the PLANTIFF’S
DISAPPROVAL OF THE PROPOSAL ORDER AND JUDGMENT GRANTING LEGAL
FEES AND COST TO DEFENDANTS IN ANTI-SLAPP MOTION C.C.P 425.16 (C), filed
with the Court on July 18, 2018 (Pages 54–80,
https://www.scribd.com/document/662265631/07-18-2018-DISAPPROVAL-OF-THE-
PROPOSED-ORDER-AND-JUDGMENT).
I repeated the Bernhofts’ story in my September 3, 2022 Addendum to the Application for
Award (IRS Form 211) submitted to the IRS Whistleblower Office (see
Crime).
Thereafter, the Regents’ attorneys from Porter Scott, Davis Burkett and Daniel Bardzell,
attempted end my lawsuit via termination sanctions and to frame me for a bench warrant by
employing two different judges who were not handling or assigned to my wrongful termination case.
Burkett and Bardzell either resigned or were fired from Porter Scott at the end of 2019.
After seven years of weird litigation, on March 3, 2020, I submitted to the Court a Submission
Form to set a Trial Date on August 11 or 18, 2020, or September 28, 2020. The Court did not bother
7
to respond at all.
In my July 29, 2019 Reply to the U.S. Tax Court Order served on July 9, 2019 and
signed by Special Trial Judge Hon. Robert N. Armen, Re: Protective Order—Tax Court
Rules of Practice and Procedure Section 6103(B)(L), (2), and (3) (U.S. Tax Court Docket
No.0019) https://www.scribd.com/document/476775930/UTC-20190729-Judge-Armen-
Order-Petitioner-Objection-to-Motion-for-Protective-Order, I addressed the Bernhofts’
and others’ horrible experiences with the law and those who were subjected to witch
hunters’ terror coming from the UCOP, FBI employees, U.S. prosecutors, and judges from
various U.S. courts.
In 2021, in an ill and heinous action to end my litigation against The Regents, attorneys
from Porter Scott, in collaboration with judges and clerks from Sacramento County Superior Court
Departments 53, 54, and 43, ambushed my wife in an attempt to frame her for a bench warrant and
criminal prosecution and to clean out her life savings bank and 401(K) accounts. They stole from her
$22,284 before Judge Thadd Blizzard from Department 43 and his court clerk. I am not 100% sure
what the Porter Scott bandits had in mind in dragging my wife to court, but I was quite sure that it
was something similar to framing her for criminal prosecution, as happened to Dorothy Bernhoft in
2012 and 2013. The full story of the January 10, 2023 inquiry addressed to Secretary to Trial Counsel
State of California Michele Kem can be found here:
https://www.scribd.com/document/662320823/01-10-2023-Commission-on-Judicial-Performance-
Kem-Re-3DCA-Case-No-C095488.
The last filed court document in which I addressed the January 31, 2012 CDSS and Lodi Police raid
on the Bernhofts’ residence was my APPELLANT’S MOTION TO CONSIDER NEW
EVIDENCE ON APPEAL, which was filed on July 20, 2023 in the Court of Appeal, Third
Appellate District (3DCA) case Jaroslaw Waszczuk v . The Regents of the University of
California (The Regents), Case No. C095488 (Sacramento County Superior Court Wrongful
Termination Case Jaroslaw Waszczuk v. The Regents of the University of California Case No. 34-
2013- 00155479 filed on December 4, 2013), see
8
https://www.scribd.com/document/660982022/7-20-2023-3DCA-C095488-Waszczuk-v-the-
Regants-Motion-for-New-Evidence-on-Appeal.
I commented on the Bernhofts as follows:
On January 5, 2012, Plaintiff had been on a four-month work stress-related

sick leave but remained on the University of California payroll with an
“unspecified leave of absence” status. However, in January 2012, Plaintiff
learned he been dropped from medical, dental, and vision insurance as a UC
employee and his job title was changed without his knowledge from Associate
Development Engineer to Programmer I. He had no physician or psychologist
to take care of his health. His former physician, Dr. Harvey Hashimoto, was
scared away in November 2011, and his psychologist, Franklin O. Bernhoft,
Ph.D., who intervened with Liberty on Plaintiff’s behalf in December 2012,
paid a heavy price for his actions. Liberty’s operatives, in conspiracy with the
Regents’ attorneys from the UCOP, reopened the Plaintiff’s Short Disability
Claim, which was denied in November 2011 and attempted to lock up the
Plaintiff in a state mental facility by scheduling him for a psychiatric
evaluation on February 1, 2012, one day after California Health and Human
Services Agency and Lodi police raided Bernhoft’s residence in Lodi, CA.
Plaintiff did not attend the psychiatric evaluation. This was a copycat scenario similar to
how communists eliminated political opponents in Soviet Union and Soviet Union-
dominated countries by locking them up in mental health facilities. The Court may read
about raid on the Plaintiff’s psychologist residence in Lodi in greater detail by opening
the link below:
Crime
The 3DCA motion filed on July 20, 2023 for new evidence on appeal, in which I mentioned the raid on
the Bernhofts’ residence, was denied a few hours later on the same day by 3DCA Acting Presiding
Justice Ronald B. Robie. One day later, on July 21, 2023, I argued the C095488. Attorney Karen Bray,
from Horvitz & Levy LLP, argued the case for The Regents. One week later, almost 10 years after the
case was filed, 3DCA granted a motion for summary judgment to The Regents. I am preparing a
Petition for Rehearing and, most likely, a Petition for Review by the California Supreme Court.
9
The denial of my motion with new crucial evidence on the case by Justice Robie, who also
presided over the oral arguments, triggered this letter to let you know why the Bernhofts were
hunted down and maliciously prosecuted. The wrongful prosecution was based on false and
fabricated accusations in Criminal Court and led to the extortion of thousands of dollars from the
Bernhoft family by the Plaintiffs and Plaintiffs’ attorneys in the Civil Court’s proceedings.
Due to The Regents’ reckless, unlawful, and merciless witch hunts, which resulted in the
termination of my employment on December 5 , 2012 at retirement age, I have suffered
enormous losses exceeding $1 million in wages and benefits and the devastation of my life. By
contrast, The Regents, since the second witch hunt action aimed at me, from March 2011–
December 2012, have lost approximately $100 million in tax-free revenue by not selling to the
Sacramento Municipal Utilities District surplus power from the UCDMC’s cogeneration plant,
after being advised by some unknown person that I would blow the whistle on their shady
power-generation business, a topic about which I did not care at all or have a clue concerning in
2011–2012, when the witch hunt began. By attacking the Bernhofts, the UCOP white collar
criminals most likely thought that I had provided in 2011 to Dr. Bernhoft secrets about their tax
evasion and fraud.
As of this writing, I have faced 16 attorneys who represented or are still representing The
Regents. Some of them have died, many have left the Porter Scott law firm. Their names are in
the link below. Perhaps you have met some of them in the Sacramento Courts
(seehttps://www.scribd.com/document/662338782/01-2023-Karen-Bray-Failure-to-Fail-
Respondent-s-Brief).
After almost ten long years of litigation in the wrong County Court, it appears that the
approximately $100 million loss for The Regents is no longer an issue to continue litigating until
I drop dead. The fraud was reported to the IRS whistleblower office, and the perpetrators do not
care. It looks like the witch hunt and malicious prosecution of Dorothy Bernhoft, with the
involvement of the Dooleys and the Regents’ attorneys from Porter Scott, which almost led to
Dorothy Bernhoft’s incarceration, is an important issue in my litigation against The Regents.
The costly civil lawsuits against the Bernhofts have been based on false allegations and
accusations and fabricated reports by perpetrators They could cost the UC Regents more
10
$100,000 dollars if the truth surfaces and a lawsuit is brought against all of the perpetrators
involved in the Bernhofts' despicable and unlawful prosecution.
Filing a false criminal complaint is illegal, not a constitutionally protected exercise of the right of
petition or free speech (Lefebvre v. Lefebvre, supra, 199 Cal.App.4th at p. 706.). However , I do
not want to get deeper into state and federal laws in relation to the Bernhofts’ unlawful
prosecution and extortion of money from them based on false CDSS reports.
The question remains, Why didn’t the California Department of Social Services not call Lodi Police
until one hour after they arrived at the Bernhofts’ residence on January 31, 2012? Why didn’t
they let the Lodi Police witness the children allegedly strapped in car seats in dark rooms with
closets of unloaded stored guns next to the children? It is a mystery to me why these facts were
not noticed by Deputy DA Reed, who filed charges against Dorothy Bernhoft on March 18, 2012
totaling 35 counts.
My self-representation in pro propria persona (pro per) legal struggle in the two
Sacramento Courts, the County of Sacramento County Superior Court and the Court of
Appeal of State California Third Appellate District (3DCA), the against Regents of the
University of California, is situated similarly to litigation of the proper litigant, Allan S., in
the case Alan S. v. Superior Court (Mary T.), 172 Cal.App.4th 238 (Cal. Ct. App. 2009),
https://casetext.com/case/alan-s-v-superior-court.
I am in same situation as Allan S., representing himself playing the role of a pro per litigant
whose case, with shades of Gideon’s Trumpet, doomed from the beginning in his litigation in two
cases filed simultaneously, on December 2 & 4, 2013, in the Sacramento County Superior Court.
In an opinion issued on April 15, 2019 in the Allan S. case, the Court made reference to Anthony
Lewis’s 1964 novel, Gideon’s Trumpet, which was based on the plight of a pro per litigant, as
fully explained in Gideon v. Wainwright (1963), 372 U.S. 335 [ 9 L.Ed.2d 799, 83 S.Ct. 792].
In contrast to Allan S.’s struggle, I was doomed twice, not because, like Allen S. he could not
afford an attorney, I initially hired experienced attorneys to handle my litigation. It was only
later that I became a pro per litigant because of my attorneys’ criminal misconduct. They were
both disbarred for their misconduct . My self-representation in pro per and my struggle against
11
powerful corporations and Littler Mandelson’s attorneys in the 3DCA case Waszczuk v. Destec
Energy Inc., Case No. C030005, did not attract as much attention as Gideon did in Gideon v.
Wainwright (1963) 372 U.S. 335 [ 9 L.Ed.2d 799, 83 S.Ct. 792]. In the novel In Pro Per
https://www.scribd.com/document/662933819/IN-PRO-PER-A-Novel-by-Maurizio-Spinoza, by my
coworker from UCDMC under the pen name Maurzio Spinosa portrayed me as “Stanley
Bondarczuk.” It did not became another Gideon’s Trumpet; however, the in pro per representation in
Waszczuk v. Destec Energy Inc., Case No. C030005, and his litigation against PG&E
(https://docs.cpuc.ca.gov/published/Agenda decision/23942-04.htm) got the University of California
Office of President (UCOP) and The Regents’ attention. Since August 2005, they have employed an
army of personnel and lawyers to erase Waszczuk from the UCDMC premises UC payroll with an
attempt to assassinate him and frame him with UC Davis and City of Lodi Police for deportation to
his native country, Poland (see https://www.scribd.com/document/663081739/03-23-2016-Jaroslaw-
Waszczuk-s-Complaint-with-State-Bar-of-California-Attorneys-Misconduct).
Shortly, I will be filing another lawsuit in the Federal District Court than the Bernhoft cases
would be brought into . Just letting you know.
If you have any questions, please let me know.
Sincerely,
cc: Franklin and Dorothy Bernhoft
12
ORIGINAL APP-002
ATTORNEY OR PARTY WITHOUT ATTORNEY: STATEBARNO.: FOR COURT USE OHLY
NAME: JAROSLAW WASZCZUK - l-N PRO'PER
FIRM NAME:
STREETADDRESS: 2216 KATZAKIAN WAY
CITY: LODI STATE: OA ZIP CODE: 95242
TELEPHONE NO,: (209)687-1180 FAXNO: (209)425-0512
E-MAIL ADDRESS:
ATTORNEY FOR Inaim):
SUPERIOR COURTOF CAUFORNIA, COUNTY OF SACRAMENTO
STREET ADDRESS: 720 9th StfOet
MAILING AODRESS: 720 9th Street DEC 2 3 2021
CITY ANDZIP CODE: SACRAMENTO, CA 95814
BRANCH NAME: Civll
By: K. Michaud
PLAINTIFF/PETITIONER: J A R O a j \ W WASZCZUK Deputy Clerk
DEFENDANT/RESPONDENT The Regents of the University of Califomia
m NOTICE OF APPEAL C D CROSSAPPEAL CASE NUMBER:
(UNLIMITED CML CASE) 34-2013-00155479

>-
Notice: Please read Infomiation on Appea/ Procedurea for Unlimited Civil Cases (Judicial Council form
APP-001) before completing this form. Tliis form must be filed in tlie superior court, not in the Court of Appeal.
A copy of this form must also be served on the other party or parties to this appeal. You may use an
applicable Judicial Council form (such as APP-009 or APP-009E) for the proof of s«vice. When this document
has been completed and a copy served, the original may then be filed with the court wMi proof of service.
1. NOTICE IS HEREBY GIVEN that (name): Jaroslaw V\^szczuk

appeals from the fbllowing judgment or order in this case, which was entered an (date): October 28,2021
I I Judgment after jury trial
I I Judgment after court trial
I I Defiault judgment
I X I Judgment aflar an order granting a summary judgment motion
I I Judgnwnt of dismissal under Code of Civil Procedure, §§ 581d, 583.250,583.360, or 583.430
I I Judgment of dismissal after an order sustaining a demun'er
I I An order after judgment under Code of Civil Procedure, § 904.1 (a)(2l)
I I An order or judgment under Code of Civil Procedure, § 904.1 (a)(3)-(13)
I I Other (describe and specify code section that authorizes this appeal):
For cross-appeals only:

a. Date notice of appeal was filed in original appeal:
b. Date superior court derk mailed notk;e of original appeal:
c. Court of Appeal case number C/fAnown):
Date: December 23, 2021

*
Jaroslaw Waszczuk
(TYPE OR PRINT NAME) (6I0N WURE OF P.ARTY Oft ATTORNEY)
p«a»iofi
Forni Approved lor Optional Use NOTICE O F A P P E A L / C R O S S A P P E A L (UNLIIVDTED CIVIL C A S E ) Cal. Rules of Court, rule 8.100
Ojdidal Coundl of Caiilomla HMw.aoi;rfScs.go/
APP-002 [Rev. January 1.2017] (Appellate)
APP-009
PROOF OF SERVICE (Court of Appeal)
n n Mail' 1 1 Personal Service
Notice: This form may be used to provide proof that a document has been
served in a proceeding in the Court of Appeal. Please read Information
SAeet for Proof of Servtee (Court ofAppeaO (form APP-009-INFO) before
completing this form. Do not use this form for proof of electronic service.
SeeformAPP-009E.
Case Name: Jaroslaw Waszczuk v. The Regents of the Univ.of Califomia
Court of Appeal Case Number:
Supernr Court Case Number: 34-2013-00155479
1. At the time of service I was at least 18 years of age and not a party to this legal action.
2. IVIy n n reskience I I business address is ^speoiy;:
2216 Katzakian Way, Lodi, CA 95242
3. I mailed or personally delivered a copy of the fbllowing document as indk»ted below (fill in the name of tfte document you mailed or
delivered and complete eittier a orb):
Notice of Appeal from the Judgment after an order granting a summary judgment motton dated October 28, 2021
a. n n Mall. I mailed a copy of the document identified above as follows:
(1) I enclosed a copy of the document kientified above in an envelope or envelopes and
(a) n n deposited the sealed envelope(s) with the U.S. Postal Senrice, with the postage fully prepaid.
(b) I I placed the envetope(s) for collection and mailing on the date and at the place shown in items below,
following our ordinary business practk^s. I am readily familiar with this business's practice of collecting
and processing correspondence for mailing. On the same day that correspondence is placed for oollectbn
and mailing, it is deposited in the ordinary course of business with the U.S. Postal Servk», in a sealed
envelope(s) with postage fully prepaid.
(2) Date mailed: December 23, 2021
(3) The envelope was or envelopes were addressed as fbllows:

(a) Person served:
(i) Name: LINDSAY A. GOULDING
GD Address:
PORTER/SCOTT PROFESSONAL LAW CORPORATION
350 University Ave. Suite 200
(b) Person served:
(i) Name:
Cii) Address:
(c) Person served:

(i) Name:
(ii) Address:
I I Additional persons sensed are listed on the attached page (write 'APP009, item 3a' at the top <^ttiepage).
(4) I am a resident of or employed in the county where the mailing occun-ed. The document was mailed from
(city and state): Lodi, California Paaeier2
Form Approved for Optional Use PROOF OF SERVICE wwMr.oov/facaeov
JLitfdal Coundl ofCalHomla ^ A—
APP-009 [Rov. January 1.2017] (COUrt Of A p p e a l )
APP-009
Case Name: Jaroslaw Waszczuk v. The Regents ofthe Univ.oT Califomia ICourt of Appeal Case Number.
Superrar Court Case Number:

34-2013-00155479
3. b. I I Personal delivery. I personally delivered a copy of the document identified above as folk»Ms:
(1) Person served:
(a) Name:
(b) Address where delivered:
(c) Date delivered:

(d) Time delivered;
(2) Person served:

(a) Name:
(c) Date delivered:

(d) Time delivered:
(3) Person served:

(a) Name:
(c) Date delivered:

(d) Time delivered;
I I Names and addresses of additional persons served and delivery dates and times are listed on the attached page (write
'APP-009, item 3b' at the top of the page).
I declare under penalty of perjury under the laws of the State of California that the foregoing s true and correct
Date: December 23,2021 / . f
IRENA WASZCZUK
(TYPE OR PRINT NAME OF PERSON COMPLETING THIS FORM)
iSIGNATURE OF PERSON COMFLETINS THIS FORM)
APP-009 (Rev. Januafy 1.2017] PROOF OF SERVICE P«8»2of2

(Courtof Appeal)
#1
I.
t •• v.y L_/
2
Lindsay A. Goulding, SBN 22719S
Sacramento, Caiifomia 9S82S
4 lgo»ldin^(5!porterscott.com
TEL: 916.929.1481
5 FAX: 916.927.3706
6

9
10
II SUPERIOR COURT OF CALIFORNIA, COUNTY OF SACRAMENTO
12
s 13 JAROSLAW ("JERRY") WASZCZUK, CASE NO. 34-2013-00155479
t ,2 r s i
L_ ~
^ (/3 «n
2S 14
Plaintiff, ^'^•^^XeBQEOgeD] JUDGMENT
OS < 2
^5 FOLLOWING ORDER GRANTING
ov Ov DEFENDANTS' MOTION FOR
>< IA SUMMARY JUDGMENT
III I- S
3 i«
17 CALIFORNIA, UNIVERSITY OF
CALIFORNIA DAVIS HEALTH SYSTEM,
BOYD, STEPHEN CHILCOTT, CHARLES
20 WITCHER, DANESHA NICHOLS, CINDY
21 PUTNEY, DORIN DANILIUC. and Does 1
22 through 50, inclusive.
23 Defendants.
24
25
26
27
28
{02523763.POCX1
IPROPOSEDI JUDGMENT FOLLOWING ORDER GRANTING DEFENDANTS' MOTION FOR
SUMMARY JUDGMENT
1 On September 23, 2021, Judge Christopher Krueger of the above-entitled court presiding,
2 after considering the evidence and arguments of the parties, as well as oral argument following the
3 tentative ruling, granted Defendant's motion for summary judgment. A true and correct copy ofthe
4 filed Order is attached hereto as Exhibit A.
5 On October 13, 2021, Judge Krueger denied Plaintiffs motion for reconsideration from the
6 order granting the summary judgment motion.
7 IT IS HEREBY ORDERED, ADJUDGED AND DECREED that Judgment be entered in
8 favor of Defendant Regents of the University of Califomia and against Plaintiff Jaroslaw Waszczuk.
9 Defendant is entitled to costs as the prevailing party pursuant to section 1032 of the Code of Civil
10 Procedure.
11
12
13 Date: y o ».»-^6V-^
M5s S \. Chnstopher Krueger
g 3-^2:5 14
CHRISTOPHER E. KRUEGER
Approved as to form:
Jaroslaw Waszczuk
19
20
21
22
23
24
25
26
27
28
(02523763.DOCX> 1
IPROPOSEDI JUDGMENT FOLLOWING ORDER GRANTING
DEFENDANTS' MOTION FOR SUMMARY JUDGMENT '
Wasiduk V. Regents ofihe University of California, et al.
Sacramento County Superior Court. Case No. 34-2013-00155479
2
PROOF OF SERVICE
3
5
7 (PROPOSED] JUDGMENT FOLLOWING ORDER GRANTING

DEFENDANTS' MOTION FOR SUMMARY JUDGMENT
8
9 BY MAIL: 1 placed the envelope for collection and mailing, following our ordinary business practices. I
10 On the same day that correspondence is placed for colleclion and mailing, it is deposited in the ordinary
course of business with the United States Postal Service, in a sealed envelope with postaRe fiillv prepaid.
II BY PERSONAL SERVICE: 1 caused such document to be personally delivered to the person(s) addressed
below. (1) For a party represented by an attomey, delivery was made to the attorney or at the attomey's
12 office by leaving the documents, in an envelope or package clearly labeled to identily the attomey being
s 13 served, with a receptionist or an individual in charge of the office, between the hours of nine in the morning
IN
£ m
•a n party's residence with some person not younger than 18 years of age between the hours of eight in the
I/] ^
O - ^^ t
K 14 moming and six in the evening.
^ c < a< rvi
—> ^ o> BY OVERNIGHT DELIVERY: 1 enclosed the documents in an envelope or package provided by an
< g vo '£ 15
? ovemight delivery carrier and addressed to the person(s) listed below. 1 placed the envelope or package for
collection and ovemight delivery at my ofTice or a regularly utilized drop box of the ovemight delivery
c „
^ 16 carrier.
3 c/1 BY FAX TRANSMISSION: Based on an agreemeni of the parties to accept service by fax transmission, 1
S 17 faxed the documents to the persons at the fax numbers listed below. No error was reported by the fax
machine that 1 used. A copy of the record of the fax transmission, which I printed out, is attached
18 XX BY ELECTRONIC SERVICE: Based on a court order or an agreement of the parties to accept service by
electronic transmission, 1 caused the documents to be sent to the persons at the electronic notification address
19 listed below.
Lodi, CA 95242
22 J JW I980@.LIVE.COM
23
I declare under penalty of perjury under the laws of the State ofCalifomia that the foregoing
24 is true and correct. Executed at Sacramento, Califomia on October 15,2021.
25
26
27
28
Virginia Yao
{02523763.DOCX)
IPROPOSEDI JUDGMENT FOLLOWING ORDER GRANTING
DEFENDANTS' MOTION FOR SUMMARY JUDGMENT
EXHIBIT A
EXHIBIT
"A"
010S4547.WPD
» 1
1 PORTER t SCOTT
A PROFESSIONAL CORPORATION ; 1 .: • ' <. • • • ' - "•
2
3 3S0 University Avenue, Suite 200
Sacramento, Califomta 95823
4 lifiouldinî'aiportcrscott.com
TEL: 916.929.1481
5 FAX: 916.927.3706
6
8 Exempt From Filing Fees Pursuant fo Government Code § 6103
9
10
II SUPERIOR COURT OF CALIFORNIA, COUNTY OF SACRAMENTO
12
JAROSLAW ("JERRY") WASZrZUK, CASE NO: 34-2013-00155479

|3 w> S 5 S . ,
o , i * 2 p ; 14
Piaintiir, '-tPROPOfiifP) ORDER GRANTING
—.. > w ^
^ <
^
lo \o
I e
13
DEFENDANTS' MOTION FOR
v. SUMMARY JUDGMENT
e I > ?i
o 17 CALIFORNIA, UNIVERSITY OF
22 through 50, inclusive,
23
Defendants.
24
25
26 /
27
28
l02302467.tX>CX!.
•PROPOSED! ORDER GRANTING DEFENDANTS? MOTION FOR SUMMARY JUDGMENT
•1 On Septanber 1,2021, Judge Christopher Krueger ofthe above-entitled court presiding, after
2 considering tfae evidenoe and arguments ofthe paities, as well as oral argumentfollowingthe tentative
3 ruling, granted Defndants* motion for summary judgment. The reasons ofthe Court are set forth in
4 the Minute Order attached hereto as Exbibit A.
5
6 ITIS SO ORDERED.
7 CHRISTOPHER L KRUEGER
8 Date: SEP 23
Hon. Cbristoph«-Knieg«-
9
Approved as to fbnn:
10
11
13
^>J'I6
17
18
19
20
21
22
23
24
25
26
21
28
(02S0a467J)OCX) 1
[PROFOSED] ORDER GRANTING DEFENDANTS' MOTION FOR SUMMARY JUDGMENT
Waszczuk V. Regents ofthe University ofCalifomia, et al.
I Sacramento Coun^ Snperior Conrt, Case No. 34-2013-00155479
2
3 PROOF OF SERVICE
5
7 IPROPOSEDI ORDER GRANTING DEFENDANTS* MOTION FOR SUMMARY JUDGMENT
8
BY MAIL: I placed the envelope fbr collection and mdling, followinig our onfinaiy business practices. I
9 am readUy familiar wilh this budness' practice fbr collecting and processing conrespondence for mailing.
On the same day that correspondence is placed (at collection and mailing, it is defxisited in the ordinary
10 course of business with the.United States Postal Service, in a sealed envelooe with postase fully prepaid.
BY PERSONAL SERVICE: 1 caused sucb document to be personalty delivered to the person(s) addressed
11 bdow. (1) For a party lepiesented 1^ an attomey, ddiveiy was made to die attorn^ or at the atuvney's
office by leavnig tlw documents, in an envelope or pacicage clearly labeled to identiQr die attorney bdng
12 served, wilh a recqitionist or an indWidual in charge ofthe ofTice, between the hours of nine in the moming
8 and live m the evening. (2) For a party, deliveiy was made to the party or teaving the documents at tbe
13 party's residence with some person nol younger than 18 years of age between the hours of dght in the
' 9 S _ '
' M <n go : momimt and sU in the evenfaie.
i^Zfi 14 BY OVERNIGHT DELIVERY: I enclosed the documents in an envelope or package provided by an
ovemight deliveiy carrier and addressed to the peison(B) lisled below. I placed the envelope or package for
et < «rf S 13 collection and ovemight delivery at my offioe or a regularly utilized drop box ofthe ovemight deliveiy
carrier.
ma
BY FAX TRANSMISSION: Based on an agreement ofthe parties lo accept service by fax transmission, I
faxed the documents to the persons at the &x numbers listed betow. No eiror was reported by the
machine that I used. A copy of the record ofthe fax transmission, which I prmted out, is attached
XX BY ELECTRONIC SERVICE: Based on a court order or an agreement of die paities to accept service by
en electronic transmission, I caused the documents to be sent to the persons at the dectronic notiiieation addiess
18 listed below.
2216 Katzakian Way
20 Udi,CA 95242
21 JJW19gDfflLIVE.COM
22
I declare under penalty of perjury under the lavrs ofthe State of California that the foregoing
23 is true and correct. Executed at Sacramento, Califomia on September 15,2021.
24
25
26
27 Virginia Yao
28
«n$«M<7Joao
IPROPOSEDI ORDEIl GRANTING DEFENDANTS' MOTION FOR SUMMARY JUDGMENT
EXHIBIT A
EXHIBIT
"A"
0I0S4547.WPD
SUPERIOR COURT OF CAUFORNIA.
COUNtY OFSACRAMENTO
MINUTE ORDER
DATE: 09A)1/2021 TIME: 09:00:00 AM DEPT: 54
JUDICIAL OFFICER PRESIDING: Christopher Krueger
CLERK: G.Toda
REPORTER/ERM: V. Haley CSR# 10771
BAILIFF/COURT ATTENDANT: N. Alvl. T. Elder
CASE NO: 34-2013-00155479-CU-VVT-GDS CASE INIT.DATE: 12/04/2013
EVENT TYPE: Motion fbr Summary Judgment and/or Adjudication - Civil Law and Motion
MSA/MSJ/SLAPP
APPEARANCES
Jaroslaw Waszczuk, self represented Plaintiff, appeared remotely via vkJeo.
Thomas Riordan, present tor defendant The Regents of the University of California, remotely.
Nature of Proceeding: Motion for Summary Judgment and/or Adjudication
TENTATIVE RUUNG
Defendant The Regents of the University of California's ("Regents") Motion fbr Summary Judgment Is
GRANTED as follows.
Objecfions
The Court declines to rule on Regents' objections as they were not material to the Courfs consideration
of the motion. (CCP § 437c(a).) Consequently, the Court also declines to rule on PlaintifTs "Objection to
Defendants' Objections to Evidence."
PlaintifPs Failure to File Responsive Separate Statement
At the outset, tiie Court notes that a self-represented party is to be treated like any other party and is
entitied to the same, but no greater consideration than other litigants and attomeys. {Witlbms v. Pacific
Mutual Ufa /ns. Co. (1986) 186 CalApp.Sd 941, 944.) Thus, as is tiie casa witt^ attomeys,
self-represenfed litigants must follow correct rules of procedure. {Nwosu v. Uba (2004) 122 CalJ\pp.4th
1229,1246-1247; see also Rappleyaa v. Campball (1994) 8 Cal.4th 975.984.)
The opposition papers must include a separate statement responding to each of the material facts the
moving party contends to be undisputed. Each material fact must be followed by a reference to
supporting evidence. (CCP § 437c(b)(3).) The opposing part/s failure to file a responsive separate
statement may, in the court's discretion, constitute sufficient ground for granting the motion. [Ibid.) Here,
Plaintifffelledto file a responsive separate statement. Plaintiff states, "[tlhe Plaintiff legitimately disputes
most of the 17 supposedly undisputed facts, thus the Motion must be denied," (Opp. 26:10-11.)
However. Plaintiff does not directly address the materiel facts submitted by Regents and state what
evMence shows that a particular fact is disputed. For these reasons. Plaintiff has failed to show what
facts are actually disputed and the Court finds that the material fects submitted by Regents are
undisputed.
Facts
As discussed above, the Court findstiiefollowing facts submitted by Regents are undisputed.
Regents have adopted and implemented polides prohibiting harassment, discrimination, and retaliation.

CASE TITLE: Waszczuk vs. The Regents of the' CASE NO: 34-2013-0015S479-CU^^DS
University of California '
Regents also investigate and take con«ctlve action when there are reports of any such conduct.
Plaintiff was hired to work as a Power Plant Operator at the UC Davis Medical Center's Plant Operations
and Maintenance Department m 1999. Plaintiff worked in the Central Plant from 1999 until 2007. On
April 16, 2007, Plaintiff received a 3-day disciplinary suspension, and his work location was reassigned
to the HVAC/Plumbing shop after an Investigation confirmed that Plaintiff violated UC Davis Health
System Policy 1616 and the Principles of Community by creating a hostile work environment in ttie
Central Plant The discipline was based on ttie investigative detennination tiiat Plaintiff commonly used
intimidating and disrespectful language when conversing with his co-woricers; treated his supenrisors
with disrespect; and repeatedly made derogatory comments about the race, religion, ethnic baOkground,
or Other immutable characteristics of his co-workers.
Plaintiff grieved tiie (fisdplinary action. The suspension was upheld, but Plaintiff's reassignment was set
aside at an appeal hearing in 2008. On January 30, 2009, Plaintiff and Regents executed a Settlement
/Vgreement in which Plaintiff agreed to a permanent assignment In tiie HVAC/Plumbing Shop. In return.
Plaintiff was pieced in an Associate Development Engineer position. Plaintiff agreed to be classified as
an exempt employee for minimum wage and overtime purposes. Plaintiff also received $13,500 and a
salary Increase aspart of the setflement
In August 2011. Regents Initiated a new investigation into additional allegations of misconduct made
against Plaintiff. Plaintiff was accused of: (a) b^ng disruptive and intimidating towards HVAC Shop
Supervisor Patrick Putney, (b) being disruptive towards Putney again on another date, and (c) being
disruptive and intimidating towards HVAC Shop As^stant Supennsor Dorin Daniliuc by pointing his
finger in Daniliuc's face and usiiig profanl^. During tiie course of the Investigation, Regents received
additional complaints that Plaintiff made discriminatoiy comments in the workplace. In February 2012,
Regents found that (a) Plaintiff violated University policies related to violence and hate Incidents In the
woncplaca and ethnically discriminatory conduct; and (b) Plaintiff was insubordinate by continuing to
contact witnesses during an investigation after being InstrtK^ted not to contact witnesses.
On /\pril 27, 2012, Plaintiff sent an email to UC Davis Health System Investigations Coordinator
Danesha Nichols, who was the Investigator for both the allegations of misconduct made against Plaintiff,
as well as Plaintiff's own complaint of retaliatkin. The email Plaintiff sent to Nichols was titied "Welcome
to Romania" and contained a slide-show of people openly defecating in the street, and a couple having
sex In a car with a young child in the backseat watching.
On September 20, 2012, University investigators Cindy Oropeza and Brent Seifert issued an
investigation report sustaining the following allegations: (1) PlaintifTs email communications regarding
Danilluc^s national origin constitute disruptive and intimidating behavior in violation of University Policy
1616 - violence and hate incidents in the workplace; and (2) PlaintifTs email communications regarding
Daniliuc's national origin, and other employees of Romanian descent were in violation of University
Poll^ PPM 380-15 - staff complaints of discrimination.
On September 25, 2012, Plaintiff was given a Notice of Intent to Dismiss based on ttie investigating
findings issued In September 2012. Plaintiff challenged the proposed termination through the Skelly
process, but the termination was upheld effective December 7,2012. The termination letter made it clear
ttiat Plaintiff vras terminated for violating University policy, Including the Principles of Community and
xilicies prohibiting discrimination in the workplace, as detailed In the September 2012 Investigation
indings.
n March 2013, Plaintiff filed an intemal whistleblower retaliation complaint wiUi Regents alleging
larassment and refeliation culminating in his termination.
The following matters have been deemed admitted in this case (ROA 175): (1) Plaintiff was suspended
and terminated as a result of multiple violations of University policies prohibiting ethnic discrimination
and liate incidents in the woricplace; (2) the University investigated allegatk>ns against Plaintiff and tiiose
investigations confirmed that he vkilated University policies prohlbitino discrimination and hate Incidents
in the woritpteice; (3) the Unh/ersity suspended and terminated Plaintiff for those violations - not for any
discriminatory reasons; (4) Plaintiff made derogatory comments In ttie workplace about Jewish people,
African Americans, Hispantes. and/or homosexuals; (5) in April 2011, Plaintiff missed an alarm in
Metasys, the buikJing automation system, ttiat had been signaled since April 11, 2011; and (6) Plaintiff

CASE TITLErWaszczuk vs. The Regents of ttie" CASE NO: 34-20134)0155479.CU-WT.QDS
did not leam of any alleged illegal power sales until after his termination.
tn responses to special interrogatories. Plaintiff admitted he was not harassed based on a protected
status.
Procedural History
On September 30, 2014, Plaintiff filed ttie operative Second Amended Complaint ("SAC"). The SAC
alleges eight causes of action: (1) Intentional Infliction of Emotional Distress (against Defendants Rice,
Sawi, Chilcott,-Witdier, Nidiols, Oropeza. Seifert, Putney, and Daniliuc only); (2) Tortious Interference
witn Economic Advantage (against Defendants Rice, Boyd. Chilcott Witcher, Nicnols, Oropeza, Seifert,
Putney, and Daniliuc only; (3) FEHA Harassment and Failure to Prevent Harassment (against all
Defendants); (4) Whistieblower/Unlawful Retaliation (against all Defendants); (5) Retaliation in Violation
of Health & Safety Code § 1278.5 (against Regents only); (6) Breach of Written Contract (against
Regents oniy); (7) Non-Exempt Wage and Hour (against Regents only); and (8) Rescisslon-Unrawful
Contract (against Regents only).
On February 9. 2015, the Court granted an anti-SLAPP motion tiled t>y Defendants Boyd, Chilcott
Nichols, Oropeza and Seifert as to tiie first throughfourthcauses of action. (ROA 57.) No causes of
action remain agabist those defendants.
On October 1,2015, Plaintiff filed a RequestforDismissal with prejudice as to Defendants Witdier, Rice,
Daniliuc. and Putney. (ROA 109.)
Plaintiff argues In his Opposition Uiat Defendants Nichols, Chilcott, Oropeza, Serifert and Boyd are still
active defendants. Plaintiff Is Incorrect because there are no active causes of action alleged against
ttiose individual defendants. As of the filing of this motion, Regents are the only active Defendant and
the only active causes of action are thettiirdtiirougheightti causes of action.
Regents' Motion to Deem Matters Admitted
On November 14. 2016, ttie Court granted Regents' unopposed motion to compel responses and to
deem requestsforadmissions as admitted after issuing a tentetlve ruling that it would "deem matters In
the requests for admlsôn admitted as granted, unless Plaintiff Jaroslaw Waszczuk serves, "before
the hearing on the motion,." proposed responses that are in substantial compliance with CCP §
2033.220. (CCP § 2033.2B0(c).) (KOA 175 [emphases in original].) No araument was requested and the
tentative ruling was affirmed deeming those matters admitted. (ROA 175.) In his Opposition, Plaintiff
arguesttiatthe matters should not have been deemed admitted because he served responses to the
Request for Admissions on November 13, 2021, by mail. (Plaintiff's Exhibit No. 1.) However, at no point
in the past 33 months has Plaintiff filed a motion to withdraw the deemed admissions andtiierehas
been no finding that PlaintifTs 195-page response to Regents' 19 Requests for Admissions was in
substantial compliance with CCP § 2033.220. An admission cannot ba amended or withdrawn except by
leave of court after noticed motion. (CCP § 2033.300(a).) This rule equally applies to "deemed
admissions." (Wikx)X v. BlrtwhlsOa (1999) 21 Cal.4th 973.979.) Because Plaintiff did not file a motion to
wittidraw Uie deemed admissions and the Courfs order is still m effect, Uie Court will consider PlaintifTs
deemed admissions in this motion and the Court declines to consider Plaintiffs Exhibit No. 1.
Discussion
The Court must grant a motion for summary judgment if alltfiep ^ r s submitted show that there Is no
triable Issue astoany materialfeetand that the moving party is entitled to a judgment as a matter of law.
(Code Civ. Proc. §437c(c); Manti v. Cracchloto (1985) 38 Cal.3d 18, 35.) The Court must decide if a
triable issue of fed exists; if none does, andttiesole remaining issue is one of law,ttieCourt has a duty
to determine it (Pftte/man v. Paarca (1992) 6 Cal.App.4th 1436,1441; see also Se/6eif Sec. Servs., Inc.
V. Superior Court (1993) 18 Cal.App.4th 394, 404.) Summary judgment is properiy granted only if the
moving party's eviaence establishes thattiiereis no Issue of matenal fact to be tried. {Upson v. Superior
Court (1982) 31 Cal.3d 362. 374; Huynh v. IngersolhRand (1993) 16 CaI.App.4tfi 825,830; see
O'Rlordan v. Federal Kemper Ufa Assur. (2005) 36 Cal.4th 281.289.)
To underscore ttiis point in Aguilar v. AtlanOc Richfield Co. (2001) 25 Cal.4th 826, the Califomia
Supreme Court described a party's burdens on summary judgment motions as follows: "[Fjrom
commencement to conclusion, the party movingforsummary judgment bears the burden of persuaston
thatttiereIs no triable issue of materialfeetand that he is entitied to judgment as a matter of law. That

CASE TITLE:*Waszczuk vs. The Regente of the' CASE NO: 34-2013-00155479-CU-WT-6DS
is because of ttie general principle that a party who seeks a court's action In his fevor bears the burden
of persuasion thereon. There is a triable issue of material fact If, and only If, the evidence would allow a
reasonable trier offeetto find the underiyingfect In favor of the party opposing the motion in accordance
VAritti tfie appilcable standard of proof. ... [T]he isarty moving for summary judgment bears an initial
tnffden of productton to make a prima facie showing of the nonexistence of any triable issue of material
feet; if he canles his burden of production, he causes a shift, and the opposing party is then subjected to
a bunJen of production of his own to make a prima fecle showing of the existence of a triable issue of
material feet... A prima facie showing is one that is sufficient to support tiie position of the party in
question." {Id. at 850-851.) In so doing, the court must consider the evidence and inferences reasonably
drawn from the evidence .in the light mostfevorableto Uie party opposing the motion. {Id. at 843.)
Third Cause of Action for FEHA Harassment and Failure to Pravant Harassment
To prevail on a claim for harassment in violation of FEHA, a plaintiff must prove: (1) he belongs to a
rotected dass; (2) he was subjected to unwelcome harassment based on his protected stetus, (3) the
R arassment was sufficientiy severe or pervasive to alter the temns and conditions of employment to
create an abusive woridng environment, and (5) respondeat superior. (Jones v. Department of
ConecUons and RehabllitaSon (2007) 152 CalApp.4th 1367, 1377.) Etnployers cannot l>e liable for
felling to prevent harassment, discrimination or retaliation without plaintiffs first proving that ttiey suffered
underlying harassment, discrimination, or retaliation. {Kelley v. The Conco Companies (2011) 196
Cal.App.4th 191,208.)
In essence, PlaintifTs first cause of action Is based on the allegations that ftegente harassed and failed
to prevent harassment towards Plaintiff based on his Polish origin ana medical condition and
discriminated and retaliated against Plaintiff based on "national origin, ancestor, mental condition, and/or
medical condition." (SAC W 120 & 126.) Plaintiff specifically alleges that Regente, "coonilnated.
cooperated, agreed, and/or had an understanding to misuse, abuse, and/or disregard Califomia law, the
REGENTS' poiteies, and UC DAVIS' procedures to deny plaintifTs righte to return to wori(." (SAC li 120.)
Plaintiff furtiier alleges that Regente. ^Coordinated, coop^ted. agreed, and/or had an understanding to
utilize plaintifTs national origin and ancestry against him, Inter alia. Plaintiff, born and raised into
adulthood in Poland . . . ." (SAC H120.) Plaintiff also alleges ttiat Regente "knowingly Ignored PlaintifTs
culturally diverse characteristics and traits, and attempted to judge, evaluate, and critfciue Plaintiff
utilizing nan-ow, shallow, and dscriminatory standards, such as, i>ut not limited to UC DAVIS Standards
of Community." (SAC H120.)
Regente argue that Plaintiff cannot prevail on the ttiird cause of action because in verified responses to
special interrogatories. Plaintiff stated he "does not claim harassment based on his national origin or
ancestry" and tfiat "Defendant did not hunt down Plaintiff in 2006-2009 and 2011-2012 because of
Plaintiff [sic] mental or medical condition." (UMF No. 16.) Plaintiff also stated in his discovery responses
that "Defendant did not harass Plaintiff." (UMF No. 16.) Regente also aûe Plaintiff cannot prove
discrimination because Plaintiff admitted in discovery responses that Plaintiff was not suspended or
temninated because of a protected characteristic. (UMF Nos. 1, 4-9, 11-12, 14-17.) Regente further
argue that Plaintiff cannot prevail on a claim of retaliation because he was not termlnatea because he
engaged in a protected activity. (UMF Nos. 1,4-9,11-12.14-17.)
Plaintiff does not dispute this ground. In fact. Plaintiff appears to believe that tiie anti-SLAPP motion
granted as to fomier Defendante Boyd, Chilcott, Nichols, Oropeza, and Seifert disposed of the first
through fourth causes of actkin In their entirety. (See Opp. 3:11-18 ["Defendante vexatiously relitigate
ttie 3rd and 4th COAs of ttie Plaintiff's S A C . . . These C(JAS were dismissed and stricken from Uie SAC
by ttie Defendante' anti-SLAPP motion."j.) However, as discussed above in the procedural history
section, Regents were not a moving party In the anti-^LAPP motion and therefore the third and fourth
causes of action remain active against Regente. The Court finds ttiat Regente met their initial burden of
roduction to make a prima fade showing of the none)dstence of any triable issue of materisd feet
P laintiff has failed to dispute the facte presented by Regente In a separate statement or in PlaintifPs
opposition. Therefore, Plaintiff has failed to meet his burden to show the existence of a triable issue of
material fact as to whether Plaintiff was harassed, discriminated against, or retaliated against and
Regente are entitled to judgment on ttie third cause of action.
DATE: 09/01/2021 MINUTE ORDER Pafle ^

CASE TITLE:-Waszczuk vs. The Regente of the * CASE NO: 34-2013-001S5479-CUW-GDS
Univefsity of CaBfomia '
Regents also argue that ttiey are entitled to judgment on ttie tiiird cause of action because Regente had
legitimate reasons for ttie alleged actions taken against Plaintiff. The Court need not reach these
argumente because Regents have prevailed on tiieir arguments to negate PiaintifTs prima facia ease.
Fourth Cause of Aetton for Whistieblower/Unlawful Reteliation in Violation of Govemment Code 8547
et seq.
To prev^ on a daim for retaliation under Govemment Code § 8547, Plaintiff must prove: (1) he made a
protected disclosure/communication; (2) his communication demonstrated an intent to dlsdose improper
ovemmental activity or a condition ttiat could significantly threaten the health or safety of employees or
S le public; (3) lie made the disdosure in good feltti for the purpose of remedtating the health or safety
condtlon. (4) tfie University took an adverse action against him, and (5) Raintiffs protected disdosiire
was a contributing fedor In the University's decision to take the adverse action. (CACI 4601; Gov. Code
§§ 8547.2(c) &(e).)
Plaintiff alleges in his fburth cause of action ttiat he was retaliated against for hte " r ^ r t e of ttie
coordinated efforts to retaliate, harass, harm, and impose negative employment consequences, and ttie
ratification and/or complidW of officers of the UC system." (SAC H134.)
Regente argue ttiat Plaintiff tails to make a prima fade case of retaliation because he cannot satisfy his
burden to prove that his comptalnts were a contributing factor in the disdplinary actions taken against
him. Ptaintiff has admitted through discovery ttiat the University took the disciplinary actions against
Plaintiff because of Plaintiffs history of violating the University's policies, not because of any complainte
Plaintiff made. (UMF Nos. 5. 6,12.13.)
As discussed above. Plaintiff did not oppose the motion as to the fourth cause of action t>ecause of his
mistaken belief that the fourth cause of action was entirely disposed of by the anti-StAPP motion.
However, the cause of adion Is still active as to Regente and Regente have satisfied their burden of
production to make a prima fede showing of the nonexistence of any tilable issue of material fed.
Plaintiff has failed to dispute the facte presented by Regente in a separate stetement or in PtaintifTs
opposition. Therefore. Plaintiff has feiied to meet his burden to show Ufie existence of a triatde issue of
material fad as to whether his alleged complainte were a contrB>uting fedor to the disciplinary adions
teken against him by the University and Regente are entitied to judgment on the fourth cause of action.
Regente also argue they are entitied to judgment on tfie fourth cause of action because ttiey had
legitimate, non-retaliatory reasons for the adverse adions taken against Plaintiff. However, the Court
need not reach these argumente because Regente have prevailed on their argumente to negate
RainUfTs prima fede case.
Fifth Cause of Action for RBtaliation in Violation of Health & Safety Code § 1278.5
Healtti & Safety Code § 1278.5 states in relevant part: "A healttifecflityshall not discriminate or retaliate,
in any manner, against a patient employee, meiriber of the medical staff, or health care worker of the
health fecility because that person has done either of ttie fdlowing: (A) Presented a grievance,
complaint or report to the facility, to an entity or agency responsible for accrediting or evaluating ttie
fadlify, or the medical staff of the fecility, or to any other govemmental entity." Health care fadlity is
defined as a fedlity "ttiat is organized, maintained, and operated for the dtagnosis, care, prevention, and
treatment of human illness, physical or mental, induding convalescence and rehabilitation and induding
care during and after pregnancy."
To prevail on a cause of action for retaliation under Health & Safety Code § 1278.5, Plaintiff must prove:
(1) Plaintiff was an employee; (2) Plaintiff presented a grievance or comptalnt to Defendant related to ttie
quality of care, services, or conditions at Defendant's heaitti care fadlity or initiated, jiarttdpated, or
cooperated In an investigation/administrative proceeding retated to fhe quality of care, services, or
conditions at Defendanfs healtii care fedlity that was earned out by an entity or agency responsible for
acarediting or evaluating the facflity or Ks medical staff; (3) Defendant took an adverse action against
Plaintiff: and (4) PlaintifTs whistieblowing adion was a substantial motii^ting reason for the adverse
action. (CACI 4606.)
Plaintiff alleges that he was retaliated against because "of plaintiff's dlsdosures conceming ttie
defidendes and problems vnttiln the HVAC Plumbing Shop as well asttiefonetionand operation of the
Metasys alarm monitoring system. Each disdosure t>y plaintiff related to and concerned matters tiiat

CASE TITLE:*Waszczuk vs. The Regente oftiie' ' CASE NO: 34-2013-00155479-CU-WT-GDS
Universtty of California ' '
diredly impacted, or foreseeably would impact the safe and healthy conditions of ttie hospital." (SAC ^
142.)
Regents argue ttiat Plaintiff did not work at a heaHh care fadlity. Plaintiff worked at an auxiliary work
fecuity at the Centi^l Plant and later in the HVAC/Plumbing Shop. The diagnosis, care, prevention and
treatment of human illness" is not performed at either one of ttiose locations. (Witcher Ded. ^ 2.)
Regente also argue that Plaintiff cannot establish that he made a complaint regarding patient safefy or
the care provided to patiente and, even if he did. there is no evidence that sudi complainte substentially
motivated the University's disdplinary actions. (UMF Nos. 1,4-9,11-12,14-15.)
Plaintiff stetes. "Defendante' counsel is correct to an extent in the motion that Plaintiff cannot claim
retaltation. The Defendante have notiiing to retaliate over because the Plaintiff did not do anything
worthy of retaliation. Plaintiff did not blow the whistle on UCOP." (Opp. 25:9-12.) Ptaintiff later states that
"COAQ 5 . . . [is] not appilcable." (Opp. 27:10-13.) The Coutifindsthat Regents have met ttieir burden of
production to make a prima facie snowing of the nonexistence of any tilable issue of material fad. The
Court construes Plaintiff's stetement that thefifthcause of action is no longer applicable as a concession
that Regents are entlttadtojudgment on the fifth cause of adion.
Regents also aûe they are entitled to judgment on the fifth cause of action because they had
legitimate, non-retaliatory reasons for the adverse adions taken against Plaintiff. However, ttie Court
need not reach these argumente because Regente have prevailed on their argumente to negate
PlaintifTs prima facie case.
SiVth nausB ftf ArHon fnr Breach of Written Confract
To recover for breach of contrad, a plaintiff must prove the existence of a contract that plaintiff
performed ttie terms of the contract Uiat defendant breached the contrad by felling to do somettiing that
was required or by doing somettiing ttiat was prohibited by the contrad and that pTafntiff was harmed by
the defendant's breach.TAcot/sffes, Inc. v. Tripte Consbvdhn Co. (1971) 14 Cal.App.3d 887,913.)
It appears from tiie SAC tiiat the Plaintiff's breach of contrad daim is based on the 2009 Settlement
Agreement between ttte parties. Plaintiff alleges Regents breached the agreement by (1) placing Plaintiff
on leave during Investigations into his wrongdoing. (2) the University allegedly felled to provide him with
an exempt position, (3) the University allegedly breached the non-disparagement proviston, and (4)
breach of ttie implied covenant of good faith andfeirdealing. (SAC ^ 146-152.)
Regente argue Plaintiff hasfeiiedto estebllsh a breach of contrad tor the following reasons. First, there
is nettling In ttie Settlement Agreement prohibiting the University from placing Plaintiff on investigative
leave. (Defense Exhibit K.) Second, the University did place Plaintiff in an exempt positton and Plaintiff
released hisrightto purse any claims based on his classification and is estopped from bringing any such
argument (UMF Nos. 1-3.) Third, the non-disparagement dause specifically exdudes the investigations
atissue that tfie University conduded into complainte made against Plaintiff. (Defense Exhibit K, § 19
"nothing in this paragraph shall be construed either to prevent the parties from cooperating in any
hvestigation conducted by a govemmentel entity within ttie scope of its authority, or to prevent the
University from pursuing any claims that it has or may have against Mr. Waszczuk."}.) Fourth, Regente
argue tiiat all Investigations were conducted by the University in accordance with its intemal policies and
rocedures. Fifth, Regente argue that Plaintiff has admitted to engaging in the misconduct that fonned
B le basis of ttie disctollnary adion against him. (UMF Nos. 2-16.) Sixth, Regente argue the UCPD
bulletin stating Ptaintiff was not allowed on the property was issued on the day Plainta^ received the
Notice of Intent to Terminate out of concem that Plaintiff's behavior was escalating and may result in
harm to ottiers. (Witcher Decl., Ij 15. Hanvood Ded., IJ 6J
Plalnttff indudes a heading In his Opposition titled 'The sixth Cause of Adion - The Violation and Breach
of the January 30,2009 Settlement Agreement signed with the Plaintiff by the Regente of ttie University
of Califomia or their Agents on Regents' Behalf." However, PlaintifTs argument appears to focus solely
on damages and does not diredly address the arouments raised by Regente. (Opp. 26:25-27:7 ("The
specific tnable issues of materialfeetas to Six [s/cf Cause of Adion . . . are outlined in the Defense Ex.
No. E Plaintiffs First Amended Answers to . . . Special Interrogatories to Plaintiff Set One. The Plaintiff
Answer to Spedal lntem)gatory from No. 33 to No. 39, Pg. 44-63 are the roughly calculated monetary
damages amounted In approximate of $1,000,000 (lost wages and benefite, home, etc)]".) Plaintiff also

DEPT: 54 Catendar No.
CASE TITLE:'Waszczuk vs. The Regente of ttie' ' CASE NO: 34-2Q13-001S5479-CU-WT-GDS
University of Califomta • • .
cites to his proposed responses to requeste for admissions, but as discussed above those will not be
considered due to the deemed admissions. However, the Spedal Intenxigatories Identified by Plaintiff do
not raise atatableissue but Instead support Regente' argument. (See e.a. Defense Ex. b, PlaintifTs
Response to Special Interrogatory No. 34 fWaszczuck did not claimttiatHIS exempt position provkled
to HIM by 2009 Settlement-Agreement was not exempt Waszczuk's D lawyer . . . made such daim In
attempt to invalkiate 2009 Settiement-Agreemenfl) The focus of me other responses dted Is on
damages and the otiier responses do not address the argumente raised by Regente in the motion. The
CourtfindsttiatRegents have met their burden of produdion to make a prima fade showing of the
nonexistence of any triable issue of material fed. Plaintiff hasfeiiedto meet his burden to snow the
existence of a triable issue of material fad as to whether he has estatilished a prima fecie case of
breach of contrad and Regente are entitied to judgment on the sbcth cause of adion
Seventh Cause of Adion for Misdasslflcation
Ptaintiff alleges that the University misdassified him as an exempt emptoyee. (SAC ^ 156.) Regmts
argue that iâintiff hasfelledtostate a daim for misdasslflcation because he does not allege any other
wage and hour violations and because Plaintiff was properiy classified as exempt. (UMF Nos. 1-3.)
Raintiff stetes In his Opposition that "COAQ . . . 7.) wage and hour violations . . . [is] not applicable." The
Courtfindsthat Regente have metttieirburden of produdion to make a prima fade showing of the
nonexistence of any triable issue of material fad. The Court construes Raintiffs statement that the
seventh cause of action is no longer applicable as a concession that Regente are entitledtojudgment on
the seventh cause of action.
Bghth Causa of Action far Resdssion of Contrad
Plaintiff alleges that the provision, in the Settlement Agreement ttiat dedares him as an exempt
emptoyee renders the entire Settiement Agreement void as unlawful. (SAC M159-165.) Regents argue
they are entitiedtojudgment because resdssion is not a standalone cause of action {Nakash v. Superior
Court (1987) 196 Cal.App.3d 59. 69-70) and because Plaintiffs allegations are contrary to the
Setflement Agreement. (Defense Exhibit K.) Plaintiff stetes in his Opposition tfiat "COAQ . . . 8.)
resdsston unlawful contrad, ]\s\ not applicable." The Courtfindsthat Regente have met their burden of
produdion to make a prima facie showing of the nonexistence of any triable issue of material fed. The
Court constmes Plairitiffs statement that Uie eighth cause of adion is no longer applicable as a
concesston that Regente are entitiedtojudgment on the eiglitti cause of action.
PiaintifTs Sur-Reply
/VRer Regente filed their Rep y. Plaintiff filed a "Notice of Objedibn to the Defendante' Itepiy of
Memorandum of Pointe and Auhorities in Support ofttieDefendant's MotionforSummary Judgment or,
in the Altemative, Summary Adûdicatton." While titied as an objection, the Court constmesttiepleading
as a Sur-Reply because it conlains arguments In response to Regents' Reply. Plaintiff did not receive
leave of Courttofilethe Sur-Reply. Therefore, the Court will not consider the Sur-Reply.
Dispositibn
Regente' MotionforSummary Judgment is GI^NTED.
The previdling party is direded to prepare aformalorder complying with C.C.P. §437c(g) and C.R.C.
Rule 3.1312.
COURT RUUNG
The matter was argued and submitted. The Court aflimnedtiietentativeruling.

LAW AfOI-iO]!OH CHOP BOX
/CZl OCT 20 ?n I2i 20
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ATTACHMENT # 2
FW-003 Oi'der oh Court Fde WliWcir
(Suiperlor Court)
Ptfson who asked the court to waive court ftes:
® Name: JAROSLAW WASZCZUK
Street or mailing addre88:2217 KATZAKIAN WAY
Qty: LQDI . State: CA Zip; 93242
®2^ e-mail,
Lawyer, If person in 0 has one (rums, oMresa, phone number,
and State Bar number): In Pro Per
jiwl980@Iive.com, Phone: 209-663-2977; Fax: 20»787-313I
Superior Court of llfbmia. County ef
Sacramcnto
720 9th Street
A request to waive ooint fjeea was filed pn (date): 3-12-201.9 Saoaiiieato, CA9S814
(x) The court made a previous fee waivn otdo' in this case on (date):
3-13-2019
Case Number
Read thisfbrm earûtty. AU diedted beaees BI (O'e cottrt orders. 34-2013-00 153479
Case Name:
WaszcznIc y. Regents of lAiiy.of Ca]i£
Notice: The court may order you to answer questions about yourfinancesand latv order you to pay tmek dw waived
fees. If this hafêns and you do not pay, the court can make you pay thefeesand also chaige you collection fe$8. If tiiere
is a change in your financial circumstances durh^tfiiscase that increases your ability to payfeesand costs, you must
notiify the trial court withinfivedays. (Use form FW-010.) If you win youir cne, the triaLcourt miy order ê other side
to pay the fees. If you settle your civil case for $10,000 or mme, the trial court will have a lien ontiiesettlement in tiie
amount of the waivedfees.The trial court may not dismiss the case until the lien is paid.
® the
A&a reviewing yonr: • Requeit to Wetiye Court Fees
eomt Hmka AefiOowing ordm:
• Request to Watve Additional Court Fea
a. ^ The court grants your reqiuest, as follows:

( 1 ) ^ Fee Waiver. The court grants your request and waives yow courtfeesand costs Inted below. (Ctd^
Rules ofCourt, rules 3.55 and 8.818.) You do not have to pay the courtfeesfortiiefollowing:
• Filing papers in Superior Court • Qiving notice vnd certificates
• Making cfupoi and certifying copies • Semiing papers to anoUier cmirt department
• Sheri£f-*8feetogivem}tice • Court-appomtdl inteqireter in small clainn court
• Court feefor{rfione heanng
• Rqiofter's fee for attendance at hearihg or trid, if reporter provided by the ccnut
• Assessmpt for court investtgations under Probate Code se^ticm 1513,1826, or 18S1
• Preparin|,tertifyihg,copying and sendingtiieclert^'s transcript on appeal
• Holding in trust the dqiosit fat a reporter's transcript on appeal under rule .8.130 or 8.834
Making a transcript or copy of an ofificial eliectronic recording under rule 8.83 S
Additional Fee Waiver. The court grants your request and waives your additional aqicrior court fees
and costs that are checked betow. (Cal Rules of Court, rule 3.56.) You do not have to pay for tiie
checked items.
• JTuiyfeesand expeoses • Fees for a peace ofiBoer to testify in court
tJ Fees fm court-appointed exj^fts • Court-appointed mterpreterfeesfora witness
• Ottier (specify):
wwM.aii/tnwtfov
.ManastaryFatm Order on Court Fee Waiver (Superior Court) FW-403,Pa8e-lof2
BS634(»
CasA NumbjBr:
Yourname: JAROSLAW WASZCZUK 34:2013^)01155479
b. • The court d«ilesyciurfeewaivorequ^ as foUows:

WamingI If you miss the^leadline below, the court cannot process your request fbr hearbig or the .court papers
you filed wAh your original request It the papery were a notioe ofappeal, theappeal may be dismissed.
(1)D The court deniin your request because, it is innmiplBte. Youlfaye id days iAorthedeik gives notice of
tius Older (see date of service (m next page) to:
• pay your fees and co^ or
* File a new revised request that inchnles the items listed bdow (spec^ incomplete items):-
(2) Q The court denies your request becausetiie-infonnatioiiyou piovided oii the request shows that you are
not eligible fw the fee waiver you requested (specify reasons):
The court has enclosed a blank Requestfor HearingAbout Court Fee WatverOrder (Superior Couri),
fonn FW-006. You have 10 Aays after the dak givo.notice oftiiisord^ (see date of service below) to:
* Pay yolirfeesand costs infoilor the amount listed in c. below, or
• Ask fOT a hearing in iordo: to diciw the court morerinformation. (Use farm FW'006to request
hearing.)
c. • Ths court needs mon information to decide whetiier to giant your request You must go to court ontiwdate
betow. The hearing will be about (specify questiojis regarding eligibility);
• Bringtii«following proof to support your request if reasonably availabte:
.Name and address of court-if differentfiromabove:

^HearingV Date: Time:
V ° ^ J Dept: Ro(mi:
Wamlngt If item clsctwckBd, and y n j do not go to court-on your tiearing date,-the Judge will deny ybur
request to waive court feea, and you will have 10 days to pay your fees. If you miss that deadiire, the
court carmot process the cgy^^ggers ypu filed with your request, (f the papers were q nofioe of appeal,
th8Spf»alrray bedh
Date:
, ALYSdN L LEWTS
Request for Accommod istfihing systems, ctfmputer-assisted real-time ctqrtmning, or sign
m
language interpreter setv: ask attoastS days before your hearing. Centaltiieclerk's
office for Requestfar Aa I, Fom MC-410. (Civil Code, § 34.8.)
Clerk's Certificate of Service
I citify that I am not involved in this case and ^cAed^ one/- • A certificate of nuliling is attached.
• I handed a copy of this order to die party and attorn^, if any. listed in 0 and (S) attiiecourt, on the date below.
(J3*Thi8 order was mailed first dass, postage paidj totiiepatty and attorney, if any, attiieaddirases li^d in(T) and (^,
fmm(city): SlatfrtîviaoAj »Califoniia on the date bdoufT >^
Date: S^/s,/~-— ~ Clerk.>y W ^ ^ y ..Deputy
Tliis is <i Court Order.
RwBMJl«y 1.201S
Order on Court Fee Waiver (Superior Court) PW'OOS.Pa9«2of2
ATTACHMENT # 3
FW-001 Request to Waive Court Fees CONFIDENTIAL
Cterk stamps date h»e when form Is filed.
Ifyou are getting public benefits, are a low-income person, or do not have
enough income to pay for your household's basic needs and your court fees, you
may usetiiisform to ask the court to waive your court fees. The court may order
you to answo' questions about yourfinances.Ifthe court waives the fees, you
may still hsv6 to pay lata* if:
• You cannot givetiiecourt proof of your eligibility, FIS bl court name and street ad<tess:
• Yourfinancialsituation inqiroves duringtiiiscase, or Superior Court of Califomia, County of
•You settle your civil case for $10,000 or more. The trial courttiiatwaivesSaoamento
your fees will have a lien on any sudi settlement in the amount of the
waived fees and costs. The court may also diatge you any collection costs.
®1 ^ Your Information (person asking the court to waive the fees):
Name: Jaroslaw Waszczuk
Street or mailing address: 2216 Katzakian Way FIB it case numtier and name:
Citv: Lodi State: CA Zm: 95242 Case Number
Phone: 209-663-2977 C079524
® Your Job, ifyou have one Oob title): N/A
Name of onplover: Case Name:
EmploYa''s address: Wasz(suk V. Regents of Univ of Cal.
Your Lawyer, if you have one (name, firm or affiliation, address, phone number, and State Bar number):
N/A
a. The lawyer has agreed to advance all or a portion of your fees or costs (check Yesone):
• No •
b. flf yes, your lawyer must sign here) Lawyer's signature:
Ifyour lawyer is not providing legal-aid type services Ixtsed on your law incorne, you may have to go to a
hearing to e:q>lain why you are asking the court to waive the fees.
(4^ What court's fees or costs are you asking to be waived?
• SvpanotCo}sti{SeeIrformationSheetonWaiverafSuperiorCourtFeesandCosts{formFW-^
El Siq>reme Court, Court of Appeal, or Appellate Division of Siqierior Court (See Information Sheet on Waiver
of Appellate Court Fees (fonn APP-015/FW-015-INFO).)
^5^ Why are you asking the court to waive your court fees?
a. • I recMve (check all that apply; see form FfV-OOl-INFO for definitions): • Food Stamps • Supp. Sec. Inc.
S SSP • Medi-Cal • County ReUefGen. Assist • IHSS • CalWORKS or Tribal TANF • CAPI
b. G My gross monthly household income (before deductions for taxes) is lesstiianthe amount listed below. (If
you check 5b, you mustfill out 7, 8, and 9 on page 2 cf this form.)
Fanlly Sze Family Income Family Size Family Income Family Size Family Income ymore Am 6peo[4e
1 $1,341.67 3 $2,267.50 5 $3,233.34 athome, add$472.92
2 $1,814.59 4 $2,760.42 6 $3,706.25 for each extra person.
c. n I do not have enough income to pay for my household's basic needs and tfae court fees. I ask the court to:
(check one and you mustfillout page 2):
• waive all court fees and costs • waive some of tfae court fees
• let me malce payments over time
• Check here if you askedtiiecourt to waive your court fees for this case intiielast six months.
{Ifyour previous request is reasonably available, please attach it to this form and check here): •
I declare under penalty of perjury under the laws of the State of California that the information I have provided
on this form and all attachmoits is true and correct.
Date: June 17,2021 . ) /
Waszczuk
Print your name here Sign herel 1 Mi
UJdIdal Coundl ot Calllbmla. ymit.couits.ca.gov

R«vl3«d March IS, 2021, Mandatory Foim Request to Waive Court Fees FW-001, Pagel 012
Govemmsnt Code, § 68833
Cal. Rules OfCourt, odes 3.51,8.28, and 8.818
Case Number
Yourname: Jaroslaw Waszczuk C079524
Ifyou checked Sa on page 1, do not fill out t)ebw. Ifyou (decked 5b, fill out que^'ons 7, 8, and 9 only.
Ifyou checked 5c, you must M out this entire page. Ifyou need more space, attach form MC-025 or attach a
s/}eef of paper and write Financial information and your name and case m/m6er at f/?e top.
Your Money and Property

®7 J Q Check here ifyour Income changes a lotfrommonth to month.
Ifttdoes, complete the fbrm based on your average Income for
the past 12 months.
a. Cash
b. Allfinancialaccounts (List tank name and amount}:
^8J Yoiir Gross Monthly Income
^-^^ a. Ust the source and amount of any Income you get each month, (2) $
including: wages or other incomefromwork t>eror8 deductions, <3) $
spousal/bhild »jppoit, retirement, social seoirlty, dlsat>iilty, c. Cars, boats, and other vehicles
unemployment, mlPtary basic allowance for quarters (BAQ), Fair Marked How Much You
veterans payments, cflvldends. Interest, trust Income, annuities, Malce/Year Value SUII Owe
net i)udness or rental Income, reimbursement for Job-related (1) $ $
expenses, gambling or lotteiy winnings, etc.
(2) S $
(1) O) $ $
d. Real estate Fair Market How Mich You
(3) Address Value ^11 Owe
(4) (1) $ $
b. Your total monthly Income: (2) $ $
Household Income e. Other personal property (jewelry, fkimiture, ftjrs,

a. Ust the Income of all other persons living (n your home who stocks, bonds, etc.): Fair Market How Much You
depend in whole or in part on you for support, or on whom you Describe Value SUII Owe
depend in whole or In part for support. (1) S s
Gross Monthly (2) $ $
Name. Age Relationship income
®
( i ) _ _ $ Your Monthly Deductions and Expenses
(2). . $ a. Ust any payroll deductions and the monthly am«int below:
$ (1) $
$ (2) $
b. Total monthly Income of persons Aove: $_ (3) $
(4)
Total monthly Income and
b. Rent a house payment & maintenance
household Income (8b plus 9b): $_
c. Food and household supplies
d. Utilities and telephone
e. acthing
Laundry and cleaning
Mecflcai and dental expenses
insurance (iHb, heaith, accident, etc.)
School, child care
Child, spousal support (another nmniage)
Transportation, gas, auto repair and Insurance
Installment payments (tist eacti beftw):
Paid to:
(1)
(2)
0)
To list any otiier facts you want lhe court to know, such as
m. Wages/earnings withheld by court order
unusual medical e}q)enses, etc., attach fomi MC-02S or
n. Any other monthly expenses Cist eacti lalam).
attach a sheet of p^>er and write Financial Infoimation and
your name and case number at the top. Paid to: How Much?
Check here ifyou attach anoAer page. Q (1)
(2)
Inqwrtantl If your financial situation or ability to pay (3)
court fees im|voves, you must notify the court witiiin five
days on form FW-010. Total monthly expenses (edd 11a - l i n ebove): $_
RevtssdMarcn 15, 2021

Request to Waive Court Fees FW-001, Page 2 of 2
12/23/21, 8:ro AM Case Details - TrueFOing
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Case Details
\AtaSECzuk V. Regents of tlie University of Califomia et al.
C079524
CA 3rcl District Court of Appeal
Case type: aviL
jFlleto This Case (/fiilr«/create/dt)022bl2-3e47-4f49-9f70-08dM8b88c7b/4Sde4«ef-7018-4c27-l)d28-01d79bf^^^
V Case Contacts (6) whm'smvComut?

Name Roles Status Organ lutlon Email
Tellmann, Anita None Verified PorterScott atellmannSporterscottcom
Strasser, Wendy None verified PorterScott wstrBSser@iporterscott.com
Harris, Erin None Verified PorterScott eharrls@porterscottxoni
Goulding, Undsay Attomey (CA)(22719S) verified PorterScott lgouldlng@porterscotLcom
Tourtaman, Nasim None Verified PorterScott ntouriraman^porterscotLcom
Vlasicxutc Jaroslaw Prose Verified l»roPBr liwl980@llva.com Remove
Add Myself / Connected User View Participant Activity

B U M I - l m i i g e W t l n f • >fef.l«n 1 1 fii d CnntnrKiinnnft I Ti.mwnfll« I VIPIM AMllahla r m i f K I An-pwlhllltv i/Arfg»»lhntt«<
https://tfairuefaing.com/court/db022b12-3e47-4f49-9f7()-0ed648b8ac7b/case/45d84eef-701B^7-b^ 1«
12/23/21,9:00 AM Case Details - TrusFSing
V Filings (12) « Prev Page 1 of 1 Next»
FBlngNaim Fmngiype Filer . Submitter Submission Date Status
06-30-2021- letter t o 3DCA LETTER-LETTER WasKzuli, Jaroslaw (Pro Per) Jaroslaw Waszczuk 06/30/1021 at 12:31:41 PM Filed
Clerk - Order for Appearance
and Examination of Inma
WaszcEuli
20210625- Letter to 30CA LETTER - l£TTER WasKiulc, Jaroslaw (Pro Perl Jaroslaw Waszczuic 08/25/2021 at 01:56:39 PM Filed
Qerlt MOTION TO REECAU
REMrmiUR .docx
0001-06-1B-2021-C0VER REQUEST-REQUEST TO WAsiczuk, Jaroslaw (Pro Per| Jaroslaw Waszczuk 06/18/2021 at 04:30:22 PM Filed
LETTER TO THE 3DCA CLERK MODIFY OPINION
-MOTION TO RECAU
REMrrrrruR
00O2-O6-ia-2O21- MOTION REQUEST-REQUEST TO Wiasiczuli. Jaroslaw (Pro Per) Jaroslaw Waszczuli 06/18/2021 at 04:30:22 PM Filed
TO RECAU THE REMrmTUR MODIFY OPINION
OR MODIFY THE OPINION
0003-C6-18-2021-PROOF OF PROOF OF SERVICE - PROOF OF \Mszauii; Jaroslaw (Pro Per) Jaroslaw Waszczuli 08/18/2021 at 04:30:22 PM Filed
SERVICE -MOTION TO SERVICE
RECAU REMITTITUR
0004^18-2021- DEOARATION -OEaARAnON WaSKzull. Jaroslaw (Pro Per) Jaroslaw Wasiczuk 06/18/2021 at 04:30:22 PM Filed
DEOARATION IN SUPORT
MOTION TD RECAU
REMITTITUR OR MODIFY
OPPINION
0005-6-18-2021- PROOF OF PROOF OF SERVICE - PROOF OF W a o a u k , Jaroslaw (Pro Per) Jaroslaw Waszczuk 06/18/2021 at 04:30:22 PM Filed
SERVICE FOR DECLARATION SERVICE
IN SUPORT MOTION TO
RECAU REMnriTUft OR
MODIFY OPINION
000frO6-18-2021- REOUEST REQUEST-REQUEST FOR WasKZuk, Jaroslaw (Pro Per) Jaroslaw Waszczuk 08/18/2021 at 04:30:22 PM Filed
-MOTION FOR JUDICIAL JUDICIAL NOTICE (FEE
NOTICE PREVIOUSLY PWO)
0007-O6-1B-2021PROOF OF PROOF OF SERVICE - PROOF OF WasKzui^ Jaroslaw (Pro Per) Jaroslaw Wasiczuk 08/18/2021 at 04:30:22 PM Filed
SERVICE-Request fbr SERVICE
Judicial NotSce-IN SUPPORT
MOTION TO RECAU
REMrrrrruR
0008-PROPOSEO ORDER REQUEST-REQUEST FOR Wasiczuk, Jaroslaw (Pro Per) Jaroslaw Waszczuk 08/18/2021 at 04:30:22 PM Filed
FOitJUDICIAlNOTKE JUDICIAL NOnCE (WITH ONE
TIME RESPONSIVE FEE)
0002-FW-OOl Request to APPUCATiON-APPUCAnON W&SKZuli, Jaroslaw (Pro Par) Jaroslaw Wasiczuk 08/18/2021 at 04:30:22 PM Relectsd
Waive Court Fees FOR WAIVER OF nUNG FEE
TEYSTER: Your submitted filing has Iwen rejected because ttte request b unnecessary. The filing fee forthls case waspaidonJune23,2015, and there b n o requirement to payanyfiirther
filing h e .
Fee Waiver Fomn IS>_FEE_WAWER_FORM WasKuli, Jaroslaw (Pm Per| Jarostaw Waaauk 06/18/2021 at 04.3a22 PM Reiected
TEYSTER: Vbur submitted filing has been rejected because the request is unnecessary. The filing fee for titis case was paid on June 23,2015, and there b n o requirement to payanyfurther
filing fee.
6 2021-ImagBSoft Inc-Version 3.1.61.4 Contact Support I Terms of Use | View Available Courts | Accessibility (/JVccessibititv)
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AC)9 ciOLiG [^li

APP-003
ATTORNEY OR PARTY VWTHOl/T ATTORNEY STATE BAR NUMBER:
FOR COURT USE ONLY
NAME: JAROSLAW WASZCZUK -DM PRO PER
FIRM NAME:
STREET ADDRESS: 2216 K A T Z A K I A N W A Y
CTY: LODI STATE: CA ZIP CODE 95242
TELEPHONENO.: 209-687-1180 FAX NO: 209-425-0512
E-MAIL ADDRESS: ijwl980(®,live.coni
ATTORNEY FOR {name): Jaroslaw Waszczuk-Self represented
SUPERIOR COURT OF CAUFORNIA, COUNTY OF
STREET ADDRESS: 720 S>th Street
MAILING ADDRESS: 720 9 t h Street
CITY AND ZIP CODE: 9 3 g l 4
BRANCH NAME: C i v i l
PLAINTIFF/PETrnONER JAROSLAW WASZCZUK
DEFENDANT/RESPONDENT: The Regents of the University of Califomia
OTHER PARENT/PARTY:
APPELLANrS NOTICE DESIGNATING RECORD ON APPEAL SUPERIOR COURT CASE NUMBER:

34-2013-00155479
(UNLIMITED CIVIL CASE)
COURT OF APPEAL CASE NUMBER fit known):
RE: Appeal filed on (date): December 23, 2021
C095488
Notice: Please read Information on Appeal Procedures for Unlimited Civil Cases (form APP-001-INFO) before
completing this form. This form must be filed in the superior court, not in the Court of Appeal.
1. RECORD OF THE DOCUMENTS FILED IN THE SUPERIOR COURT

I choose to use thefollowingmethod of providing the Court of Appeal with a record of the documentsfiledin the superior court
(check a, b, c, or d, and fill in any required infonnation):
a. I * \ A derk's transcript under rule 8.122. (You ntust check (1) or (2) and fill out the dertf's transcript section (Hem 4) on pages
2 and 3 of this fonn.)
(1) I will pay the superior court derkforthis transcript myself when I receive the derk's estimate of the costs of this
transcript. I understand that if I do not payforthis transcript, it will not be prepared and provided to the Court of
Appeal.
(2) H I request that the derk's transcript be provided to me at no cost because I cannot afford to pay this cost. I have
submitted thefollowingdocument with this notice designating the record (check (a) or (b)):
(a) _ x j An order granting a waiver of courtfeesand costs under rules 3.50-3.58; or
(b) An application for a waiver of court fees and costs under rules 3.50-3.58. (Use Request to Waive Court Fees
(fonn FW-OOt) to prepare and file this appHcaHon.)
b. I I An appendix underrule 8.124.
c. I I The original superior court file under rule 8.128. (NOTE: Local mles in the Court of Appeal, First, Third, and Fourth
Appellate Districts, permit parties to stipulate (agree) to use the original superior court file instead of a derit's transcript;
you may select this option if your appeal is in one of these di^rids and all the parties have stipulated to use the origirtal
superior court file instead of a clerk's transcript in this case. Attach a copy of this stipulation.)
d. I I An agreed statement under rule 8.134. (You must complete item 2b(2) behjw and attach to your agreed statement copie
of all the documents that are required to be included in the dertf's transcript These documents are listed in rule 8.134(a).)
RECORD OF ORAL PROCEEDINGS IN THE SUPERIOR COURT

I choose to proceed (you must check a orb below):
a. I I WITHQUT a record of the oral proceedings (what was said at the hearing or triaO in the superior court I understand that
without a record of the oral proceedings in the superior court, the Court of Appeal will not tie able to consider what was
said during those proceedings in dedding whether an error was made in the superior court proceedings.
Pagel of 4
Fonn Approved Ibr Optional Use APPELLANTS NOTICE DESIGNATING RECORD ON APPEAL Cal. Rulesof Court, rules 3.50,
Judidal Counca of CaTifbiriia 8.121-ai24, ai28. ai30, ai34, ai37
fiPPOOa [Rev. January 1,2019] (Unlimited Civil Case) wi>w.ODUfs:ca.gov
APP-003
CASE NAME: jgroslaw Waszczuk v. The Regents oftijeUniversity of Califomia SUPBOOR COURT CASE NUMBER:
34-2013-00155479
2. b. I * I WITH the following record of the oral proceedings in the superior court (you must ctiedt (1), (2), or (3) below):
(1) I x l A reporter's transcript under rule 8.130. (You musttillout Uie reporter's transcript section (item 5) on pages 3 and 4
of this form.) I have (check all that apply):
(a) I K I Deposited with the superior court derk the approximate cost of preparing the transcript by induding the deposit
with this notice as provided in rule 8.130(b)(1).
(b) I I Attached a copy cf a Transcript Reimbursement Fund application filed under rule 8.130(c)(1).
(c) I I Attached the reporter's written waiver of a deposit under rule 8.130(b)(3)(A) for (check either (i) or (ii)):
(i) I I all of the designated proceedings.
00 I I part of the designated proceedings.
(d) I 1 Attadied a certified transcript under rule 8.130(b)(3)(C).
(2) I I An agreeti stat&nevA. (Check and complete eittter (a) or (b) below.)
(a) I I I have a t t a c h ^ an agreed statement to this notice.
(b) I I All the parties have stipulated (agreed) in writing to try to agree on a statement. (You must attach a copy of this
stipulation to this notice.) I understand that, within 40 days after I file the notice of appeal, I mustfileeither the
agreed statement or a notice indicating the parties were unable to agree on a statement and a new notice
designating the record on appeal.
(3) I I A settled statement under rule 8.137. (You must check (a), (b), or (c) betow, andtillout the settled statement
section (item 6) on page 4.)
(a) II The oral proceedings in the superior court were not reported by a court reporter.
(b) II The oral proceedings in the superior court were reported by a court reporter, but I have an order waiving fees
and costs.
(c) I I I am askingtouse a settled statementforreasons other than those listed in (a) or (b). (You must serve and file
the motion required under mle 8.137(b) at the same time that you file this fonn. You may use fonn APP-025 to
prepare the ntotion.)
R E C O R D O F AN ADMINISTRATIVE P R O C E E D I N G T O B E TRANSMITTED T O T H E C O U R T O F A P P E A L
I 1 I request that the derk transmit to the Court of Appeal under rule 8.123 the record of thefollowingadministrative proceeding
that was admitted into evidence, refused, or lodged in the superior court (give thetitieand date or dates of the administrative
proceeding):
I Title of Administrative Proceeding | | Date or Dates |
4. NOTICE DESIGNATING C L E R K ' S T R A N S C R I P T

(You must complete this section if you chedted item la above indicating that you choose to use a dertCs transcript as the record of
the documentstiledin the superior court.)
a. Required documents. The deric will automatically indude the following items in the derk's transcript, but you must provide the
date each document was filed, or if that is not available, the date the document was signed.
j Document Title and Description ~| | Date of Rllng |
(1) Notice of appeal December 23,2021
(2) Notice designating record on appeal (this document) January 25,2022
(3) Judgment or order appealed from October 28,2021-ROA# 302
(4) Notice of entry of judgment râny) October 28,2021-ROA# 303
(5) Notice of intention to move for new trial or motion to vacate the judgment, for judgment
notwithstanding the verdict, orforreconsideration of an appealed order (if any) October 22,2021ROA292-296
\ (6) Ruling on one or more of the items listed in (5) Octoberl3,2021 ROA #299
1(7) Register of actions or docket (tf any) ROA Case 34-2013-00155479
APP^xBiRev January 1,2019] A P P E L L A N T S NOTICE DESIGNATING RECORD O N A P P E A L paaeaof4
(Unlimited Chril C a s e )
APP-003
CASE MAME: Jaroslaw Waszczuk v. The Regents of the University of Califomia SUPERIOR COURT CASE NUMBER:
34-2013-00155479
4. NOTICE DESIGNATING CLERK'S TRANSCRIPT

b. Additional documents. (If you want any documents from the superior court proceeding in addition to the items listed i
above to be mduded in the deri('s transcript, you must identifytfiosedocuments here.)
I X I I request that the derk indude in the transcript thefollowingdocuments that werefiledin the superior court procee
(You must identify each document you want induded by itstitieand provide the date it wastiledor, if that is not
ava/Jabte,tiiedatetiiedocument was signed.)
I Document Title and Description "~| | Date of Filing"
(8) Complaint (Plaintiff)-ROA # 1 12/4/2013
(9) First Amended Complaint (FAC)(Plaintilf)-ROA# 8 6/16/2014
(10) Notice -Second Amended Complaint (SAC) Rejected by the Court (Plaintifi) -ROA # 18 9/10/2014
(11) Order-granting Ex-Parte Application by stipulation to file SAC filed.-ROA# 21 9/25/2014
I X I See additional pages. (Check here if you need more space to list additional documents. Ust these documents on
separate page or pages labeled "Attachment 4b, ° and start with numlter (12).)
c. Exhibits to be included in clerk's transcript

^ I request that the derk indude in the transcript thefollowingexhibits that were admitted in evidence, refosed, or l
the superior court. (For each exhibit, give the exhibit number, such as Plaintiff's #1 or Defendant's A, and a brie
description of the exhibit. Indicate whether or not the court admitted the exhibit into evidence. If the superior cou
retumed a designated exhibit to a party, the party in possession of the exhibit must (teliver it to the superior court
within 10 days after senrice of this notice designatrng the record. (Rute 8.122(a)(3).))
I Exhibit Number \[ Description | fAdmitted (Yea/No) |

(1) N/A
^2) N/A
(3) N/A
[4) N/A
ll I See additional pages. (Check here if you need more âce to list additional exhibits. Ust these exhibits on a sepa
I page or pages labeled "Attachment 4c,' and start with number (5).)
5. NOTICE DESIGNATING REPORTER'S TRANSCRIPT

Ybu must complete both a and b in this section if you checked item 2b(1) above indicating that you choose to use a repo
tiranscript as the record ofttieoral proceedings in the superior court. Please remember that you must pay fbr the cost of p
the reporter's transcript
a. Foimat of the reporter's transcript

I requ^ that the reporters provide (ched< one):
(1) I X I My copy of the reporter's transcript in electronic format
(2) I I My copy of the reporter's transcript in paper format.
(3) I I My copy of the reporter's transcript in electronic format and a second copy in paper format.
^Code Civ. Pmc., § 271.)
APP^)03[Rev.januanri,a«9i APPELLANTS NOTICE DESIGNATING RECORD ON APPEAL p^saA

(Unlimited Civil Case)
APP-003
CASE NAME: Jaroslaw Waszczuk v. TTie Regents of die University of Califomia SUPBOOR COURT CASE NUMBER:
34-2013-00155479
5. b. {Proceedings
I request that thefollowingproceedings in the superior court be induded in the reporter's transcript. (Vou must identify each
proceeding you want induded by its date, the department in which it took place, a description ofthe proceedings (fbr example,
the examination ofjurors, motions before trial, the taking of testimony, or the giving ofJury instmctions), the name ofthe court
reporter wtio recorded the proceedings (if known), and whether a certified transcript ofthe designated proceeding was
previoudy prepared.)
I Date I Department I Full/Partial Day I Description I Reporter's Name | Prev. prepared?
(1)09/01/2021 54 Partial Day Motion for Summary Judgment Tina Tavalero • Yes No
(2) • Yes • No
(3) • Yes • No
(4) • Yes • No
I I See additional pages. (Ched< here if you need more âce to list additional proceedings. Ust these exhibits on a separate
page or pages labeled "Attachment 5b," and start with number (5).)
6. NOTICE DESIGNATING P R O C E E D I N G S T O B E INCLUDED IN S E T T L E D S T A T E M E N T

(You must complete this section if you checked item 2b(3) above indurating you choose to use a settied statement.) I request
that thefollowingproceedings in the superior court be induded in the settled statement. (Vou must identify each proceeding you
want induded by its date, the department in which it took place, a description ofthe proceedings (for example, the examination
ofjurors, motions before trial, the taking of testimony, ortiiegiving ofjury instmctions), ttie name of the court reporter who
recorded the proceedings (if known), and whether a certitied transcript of the designated proceeding was previousty prepared.)
Date j Department | Full/f^rtial Day | Description Reporter's Name | Prev. prepared? |
(1) • Yes • No
1(2) • Yes • No
(3) • Yes • No
(4) • Yes • No
See additional pages. (Check here if you need more space to list additional proceedings. Ust these proceedings on a
separate page or pages labeled "Attachment 6,' and start with number (5).)
7. a. The proceedings designated in 5b or 6 indude do not indude all of the testimony in the superior court.
I If the designated proceedings DO NOT indude all of the testimony, state the points that you intend to raise on appeal. (Rule
18.130(a)(2) and mle 8.137(d)(1) provide that your appeal will be limited to these points unless ttie Court of Appeal penmits
\ otiienvise.) Points are set forth: [ | Below On a separate page labeled "Attachment 7."
Date: 01/28/2022
jaroslaw Waszczuk
(TYPE OR PRINT NAME) (SIGNATURE OF APPELLANT OR ATTORNEY)
APP-ÎOS [R0v. Jsuary 1, 2019|

A P P E L L A N T S NOTICE DESIGNATING RECORD O N A P P E A L
(Unlimited Civil Case)
ATTACHMENT NO. 4B TO THE APPELLANT'S NOTICE
DESIGNATING RECORD APPEAL SUPERIOR COURT
CASE NUMBER 34-2013-0015547
THE COURT OF APPEAL CASE NO. C095488
NO. DOCUMENT T I T L E AND DESCRIPTION DATE

(12) Ex-Parte Application (Plaintiff)- filed in Dept. 53- Hon. David I Brown
-ROA #29 12/17/2014
(13) Court Order-Disposition of Ex Parte Application- Dept. 53- Hon. David I Brown
ROA #30 12/17/2014
(14) Correspondence submitted by Plaintiff to Dept. 53- Hon. David I Brown
-ROA #3 12/24/2014
(15) Plaintiffs Ex-Parte application for postponement filed in Dept 53
Hon. David I Brown- ROA# 35 12/29/2014
(16) Court Order-Disposition of Ex Parte Application- Dept. 53- Hon. David I Brown-
ROA#37 12/30/2014
(17) Rejected substitution of attomey submitted by plaintiff to Dept. 53 -Hon. David I Brown
ROA#42 01/02/2015
(18) PlaintifTs correspondence submitted to Hon. David I Brown Dept. 53

-ROA #46 01/07/2015
(19) Rejected Substitution of Attomey submitted by Plaintiff- (ROA#47) 01/13/2015

(20) PlaintifFs Opposition to Defendants anti-SLAPP Motion - ROA#48 01/23/2015
(21) Substitution of Attomey filed by Plaintiff- in Dept. 53 Hon. David I Brown

-ROA #50 01/14/2015
(22) Defendants Objection to Evidence In Opposition to anti-SLAPP Motion filed

Dept. 53 Hon. David I Brown- ROA #51 01/29/2015
(23) Minutes finalized for Motion to Strike(SLAPP) -Dept. 53 Hon. David I Brown-
ROA#57 02/09/2015
(24) Minutes finalized for PlaintifFs Motion for Reconsideration- Dept. 53 Hon. David I
Brown-ROA#69 03/06/2015
(25) Defendants Attomey David P. E Burkett added to the case effective 03/13/2015
ROA #70 03/13/2015
RECORD ON APPEAL -ATTACHMENT 4b

(26) Minutesfinalizedfor PlaintifFs Motion to Dismiss Defendant's
Ant-SLAPP Motion- Dept. 53 Hon. David I Brown -ROA # 75 04/10/2015
(27) Court Order granting Defendants Anti -SLAPP Motion to Strike First
through Fourth Causes of ActionfiômPlaintifTs SAC - Dept. 53 Hon.
David I Brown-ROA #80 04/14/2015
(28) Plaintiffs Request for Dismissalfiledin Dept. 53- Hon. David I Brown-
ROA #109 10/01/2015
(29) Plaintiff's Notice of Entry of Dismissal filed in Dept. 53- Hon. David I Brown
ROA # 110 10/01/2015
(30) PlaintifFs Opposition to Defendants Motion For Automatic Stay or in the

Altemative for a Discretionary Stayfiledin Dept. 53- Hon. David I Brown
ROA# 111 10/13/2015
(31) 3DCA Order Denymg Petition for Rehearing (SLAPP)- ROA # 127 11/08/2017
(32) 3DCA remittitur issued, judgment is affirmed (SLAPP)- ROA #128 01/18/2018
(33) Plaintiff's correspondence (SLAPP Fees)filedin Dept. 53-Hon. David I Brown

- ROA # 135 05/25/2018
(34) Minutesfinalizedfor motion for attomey's fees (SLAPP) Dept. 53

-Hon. David I Brown- ROA #136 06/07/2018
(35) Plaintiff Motion for Reconsideration (SLAPP Fees) filed in Dept. 53-Hon. David I
Brown- ROA # 138 06/18/2018
(36) Order granting Defendant's Motion for Fees and Cost(SLAPP Motion)
filed in Dept. 53-Hon. David I Brown- ROA # 143 06/29/2018
(35) Judgment filed (SLAPP Cost and Fees)- Dept. 53-Hon. David I Brown-
ROA#144 06/29/2018
(36) Defendants Opposition to Plaintiffs Motion for Reconsideration (SLAPP Fees )
Dept. 53-Hon. David I Brown- ROA #145 07/02/2018
(37) Correspondence filed (Plaintiff) Dept. 53-Hon. David I Brown- ROA # 148... 07/18/2018
(38) Defendant's Motion to Compel and Termination Sanctions

ROA # 150,151,152,153filedby Defendants Attomeys in Dept 54.
Hon. Christopher Krueger 10/03/2018
2
RECORD ON APPEAL-ATTACHMENT 4b
(39) Defendant's Application and Order for Appearance and Examination
of Judgment Debtorfiledin Dept.37 Hon. Jentufer K. Rockwell- ROA #155
10/11/2018
(39-1) Plaintiff's unfiled letter sent on 10/11/2018 to Dept.54 Clerk -Hon. Christopher
Krueger Re: Defendants Motion to Compel and Termination Sanctionfiledin wrong
Court Dept by the Defendant's Attorneys 10/11/2018
(40 Defendant's Motion to Compelfiledin Dept. 53-Hon. David I Brown

ROA #156 10/12/2018
(41 Plaintiff's response to special interrogatories set 1filedin Dept. 53-

Hon. David I Brown ROA#162 10/15/2018
(42 Defendants Correspondence (confirming lettor-l 1/13/2018) hearing dropped

fiom calendar)in Dept 53-Hon. David I Brown- ROA # 164 10/23/2018
(43 Minutesfinalizedfor Motion to Compel- Dept 53-Hon. David I Brown -

ROA #166 10/31/2018
(44 Defendant's Application and Order for Appearance and Examination

of Judgment Debtorfiledin Dept37 Hon. Jennifer K. Rockwell- ROA # 167
10/24/2018
(45 Defendants Correspondence- Dept 53-Hon. David I Brown - ROA # 168

11/06/2018
(46; Plaintiffis Correspondence- Dept. 53-Hon. David I Brown - ROA # 169

11/06/2018
(47 Defendants Correspondence- Dept. 53-Hon. David I Brown ROA #171

11/07/2018
(48 Order for Appearance and Examination (Jaroslaw 'Jerry" Waszczuk'')-

Dept37 Hon. Jennifer K. Rockwell- ROA #172 11/072018
(49 Minutesfinalizedfor Defendant's Motion to Compel- Dept 53-

Hon. David I Brown ROA #174 11/13/2018
(50: Minutesfinalizedfor Defendant's Motion to Compel- Dept. 53-

Hon. David I Brown - ROA #175' 11/14/2018
(51 Minutesfinalizedfor Defendant's Motion to Compel Dept. 53-

Hon. David I Brown - ROA #176 11/14/2018
(52 Order for Appearance and Examination (Jaroslaw 'Jeny" Waszczuk")
o x Calendar scheduled for 12/14/2018 at 09:00 in Dept 37,
Hon. Jeimifer K. Rockwell Gordon. D. Schaber Courthouse was vacated ROA #
177 11/15/2018
(53) Defendants Correspondence (12/14/2018 Court Hearing) Dept. 53-

Hon. David I Brown -ROA#178 11/13/2018
(54) Plaintiff's 11/12/2018 correspondence addressed to Judge David Brown

Dept 53 ROA #179 11/16/2018
(55) Plaintiff's 11/14/2018 correspondence addressed to Judge David Brown

Dept 53 - ROA #180 11/21/2018
(56) Plaintiff's 11/19/2018 correspondence addressed to Judge Jeimifer K.

Rockwell Dept 37- ROA # 181 11/20/2018
(57) Defendants Application for Appearance and Examination of Judgment

Debtor (Jaroslaw 'Jerry" Waszczuk") filed in Dept.37 Hon. Jeimiffer K. Rockwell
ROA #182 11/29/2018
(58) Order for Appearance and Examination Examination-OX

(Jaroslaw 'Jerry" Waszczuk")-Dept37 Hon. Jenniffer K. Rockwell
ROA # 183 12/07/2018
(59) Order for Appearance and Examination (Jaroslaw 'Jeny" Waszczuk")

OX Calendar scheduled for 02/08/2019 at 09:00 in Dept 37 Hon. Hon. Jennifer K.
Rockwell Gordon. D. Schaber Courthouse ROA # 184 12/12/2018
(60) Court Order (Re: Unpaid Sanctions)- Hon. David I. Brown- ROA #186 01/16/2019
(61) Plaintiffs Correspondence (Re: Unpaid Sanctions ) ROA # 187 01/17/2019
(62) Notice of entry of order(Granting Defendant Regents of the University

of Califomia request for Mandatory Monetary Sanctions in Connection with it
is Motion to Deem Matters Admitted ) Hon. David I. Brown Dept 53-
ROA#188 01/25/2019
(63) Minutes Finalized for Ordo* of Examination-OX Calendar heard on

February 8,2019 in Dept 43 Hon. Thadd A. Blizzard ROA # 189 02/08/2019
(64) Plaintiff's Ex-Parte Application (to Allowfilingof Late Opposition to

Defendants Motion to Compel. Dept 53. Hon. David I. Brown -ROA # 198.. 03/11/2019
(65) Minutes Finalized Plaintiff's Ex-Parte Application (to Allowfilingof

Late Opposition to Defendants Motion to Compel. Dept 53. Hon.
David I. Brown ROA #203 03/13/2019
4
RECORD ON APPEAL ATTACHMENT 4b
(66 Minutesfinalizedfor Defendant's Motion to Compel Dept. 53 Hon. David
L Brown- ROA #204 03/13/2019
(67; Plaintiffs Opposition to Defendants Motions to Compel- Production of

Documents and Intierrogatories Dept 53 Hon. I Brown ROM 209 04/12/2019
(68 Minutesfinalizedfor Defendant's Motion to Compel Dept. 53 HorL Steven H.

Rodda-ROA #211 04/26/2019
(69 Plaintiffs Opposition to Defendants Motions to Compel Dept 53 Hon. David

I. Brown ROA #217 07/05/2019
(70: Minutesfinalizedfor Defendant's Motion to Compel Dept. 53 Hon. David

I. Brown- ROA #219 07/19/2019
(71 Plaintiffs September 26,2019 response to Defehdaiits attoiiieys Meet & Confer
Correspondence dated August 5* August 30,2019 and September 20,2019
ROA #220 09/29/2019
(72 Defendants October 23,2019 Notice of Motion and Motion to Compel

(Response to Interrogatories & Monetary Sanctions )- ROA # 222 10/23/2019
(73 Defendants Attomey Derek j . Haynes added effective 11/12/2019 ROA#228

11/12/2019
(74 Court Order (Order: re Monetary Sanctions ) filed Dept53 horL David Brown -
ROA #230 11/19/2019
(75 Plaintiff's November 18,2019 Meet and Confer correspondence with Defendant
Attorney submitteid to judge David I. Brown Dept. 53 for review and
consideration ( Re: Blackmail Sanctions ) ROA #231 11/19/2019
(76; Plaintiff's November 21,2019 Meet and Confer correspondence submitted

to Dept 53, David I. Brown for review and consideration ( Re. Porter Scott
Attomey Threatening Letters)-ROA #232 11/27/2019
(77 Plaintiffs Opposition to Judgrnent Creditors Motions to Compel and

I
Monetary Sanctions Dept 53 Hon. I Brown ROA# 235 12/04/2019
I
I
I
Defendants Reply to Plaintiff's Opposition to Noticed Motion to Compel

Dept.53 Hon. David I. Brown ROA # 236 12/06/2019
(78;
MinutesfinalizedDefendant's Motion to Compel Dept. 53 Hon. David
I. Brown ROA #243 12/17/2019
(79;
IRECORD ON APPEAL-ATTACHMENT 4b
(80) Plaintiff's Notice of Objection to the Court Order dated December 13&17
2019, Dept 53, Hon. David I . Brown ROA # 244 12/27/2019
(81) Defendant's Application and Order for Appearance and Examination

of Irina Waszczuk filed in Dept. 43 Hon. Thadd A. Blizrard ROA # 245 04/12/2021
(82) Declaration of Lindsay A. Goulding in Suuport of Defeiidant's Ex-Parte

Application for Leave to File Motion for Surmnary Judgment that Exceed
20 pagesfiledin Dept 53, Hon. Shama Hakim Mesiwala ROA # 247 04/26/2021
(83) Defendant Ex-Parte Application for Leave to File Motion for

Stmimary Judgment that Exceed 20 pagesfiledin Dept. 53, Hon. Shama
Hakim Mesiwala ROA #248 04/26/2021
(84) Order Granted; to Defendant Ex-Parte Application for Leave to File Motion
for Summary Judgment that Exceed 20 pagesfiledin Dept. 53,
Hon. Shama Hakim Mesiwala ROA # 249 04/272021
(85) Plaintiffs Response to (Defanddant Ex-Parte)filedin Dept. 53, Hon. Shama

Hakim Mesiwala ROA #250 04/28/2021
(86) Letter to Clerk-Declaration of Olatomiwa Aina in Support of Judgment

Creditors Application and Order for examination of Irina Waszczukfiledin Dept.
43 Hon. Thadd A. Blizzard ROA # 251 04/28/2021
(86) Order for Appearance and Examination (Irina Waszczuk))OX Calendar

FUed for 07/02/2021 at 09:00 in Dept 43 Hon. Thadd A. Blizzard, ROA 252
05/07/202
(87) Order for Appearance and Examination (Irina Waszczuk)filedin
Dept 43 Hon. Thadd A. Blizzard ROA # 253 05/07/2021
(88) Defendant's Motion for Sunmiaiy Judgment and/or Adjudication filed in Dept 53,
Honorable Shama Mesiwala ROA # 254 05/14/2021
(89) Defendant's Memorandtmi of Points and Authorities - Motion for Sunmiary

Judgment and/or Adjudication filed in Dept 53, Hon. Shama
Mesiwala ROA #255 05/14/2021
(90) Defendant's Statement of Undisputed Facts - Motion for Summary

Judgment and/or Adjudication filed in Dept 53, HOIL Shama
Mesiwala, ROA# 256 05/14/2021
1
{(91) Defendant's -Paper Exhibits - Motion for Sunmiaiy

I Judgment and/or Adjudicationfiledin Dept 53, Hon. Shama
i
( 6
Mesiwala, ROA #257 05/14/2021
(92) Defandant's Motion for Summary Judgment and/or Adjudication

scheduled for 08/04/2021 at 01/30/ PM in Dept 53, Hon. Shama
Mesiwala, ROA# 258 05/18/2021
(93) Declaration of Lindsay Goulding in Support of Judgment Creditors

Application and Order for Appearance and Examination of Irena
Waszczukfiledin Dept 43 Hon. Thadd A. Blizzard ROA #259 05/27/2021
(94) PlaintifFsfileda written peremptory challenge pursuant to CCP 170.6

to disqualify Hon. Shama Mesiwala ROA# 261 06/29/2021
(95) Plaintiff's Ex-Parte Application to( Continue Appearance and Examination of Irena
Waszczuk)filedin Dept 43 Hon. Thadd A. Blizzard ROA #262 06/30/2021
(96) Minutesfinalizedfor Order of Examination -OX of Irena Waszczuk

Dept 43 Hon. Thadd A. Blizzard ROA #263 07/02/2021
(97) Minutes finalized for Plaintiff'sfiledwritten peremptory challenge pursuant to CCP

170.6 to disquaUfy Hon. Shama Mesiwala ROA# 264 07/02/2021
(98) Minutes Oder finalized -Defendant's Motion for Summary Judgment (MSJ/MSA)
Court scheduled to be heard on 08/04/2021 in Dept 54. Hon. Christopher
Krueger -ROA #265 07/02/2021
(99) Plaintiff s Ex-Parte Application for Extension of Time tofile;Opposition to

Defendant MSJ/MSAfiledin Dept 54. Hon. Christopher Krueger -
ROA #267 07/09/2021
(100) Order Denying Plaintiffs Ex-Parte Application for Extension of time

tofileOpposition to Defendant's MSJ/MSA -Dept. 54 Hon. Christopher
Krueger, ROA 268 07/16/2021
(101) The Court of Appeal, Third Appellate Distiict (3DCA) Order denying Plaintiffs
Motion to Recall Remittitur in 3DCA Case No. C079524 (SLAPP Motion)
and denying Plaintiffs Request for Judicial Noticefiledin 3DCA on 08/18/2021-

ROA#270 07/19/2021
(102) Lodged in Dept 53 but unfiled copy of the Plaintiff s Motion to Recall
Remittitur and copy of the Request /Motion for Judicial Notice with
Plaintiff's Declarations in Support in 3DCA Case C079524 (SLAPP Motion).
I The above listed Dociiments with Cover Letter were submitted to Dept 53- Hon.
Shama Mesiwala by Priority U S Mail on 6/18/2021
i (Please include only one attached to the Motion EXHIBrr#44 into Clerk
7
Transcript which is Draft ofthe Plaintiffs Third Amended Complaint (TAC)
(103) Plaintiff's Ex-Parte Application for 15 days Extensiori of Time to File

Opposition to Defendant MSJ/MSA filed in Dept.54 Hon. Christopher
Krueger, ROA 271 07/23/2021
(104) Order Determining Disposition of Plaintiff's Ex-Parte Application

for 15 days Extension of Time to File Opposition to Defendant MSJ/MSA
filed in Dept54 Hon. Christopher Krueger - ROA 272 07/26/2021
(105) Notice of Change in Handling Attomeyfiledin the Dept.54 by Defendants

AttomeyfromPorter Scott Law Corp Lindsay A. Goulding -ROA #273 07/26/2021
(106) Notice that this case is reassigned from Dept.43 Hon. Thadd A. Blizzard
to Dept38 for Case Management Program -ROA #274 08/01/2021
(107) Minutes Oder finalized -Defendant's Motion for Summmy Judgment

(MSJ/MSA) Court heard on 08/04/2021 in Dept 54. Hon. George Acero
-ROA #278 08/04/2021
(108) Plaintiff's Opposition to Defendant's Motion for Summary Judgment

(MSJ/MSA)filedin Dept54 Hon. Christopher Krueger- ROA# 279 08/13/2021
(109) Plaintiff Exhibits List -Paper Exhibits - MSJ/MSAfiledin Dept 54

Hon. Christopher Krueger -ROA # 280 08/13/2021
(110) Defendant's Reply to Plaintiff's Opposition MSJ/MSA filed in Dept54

Hon. Christopher Krueger -ROA #281 08/20/2021
(111) Defendant's Objection to Plaintiffs Evidence MSJ/MSAfiledin

Dept54 Hon. Christopher Krueger -ROA #282 08/20/2021
(112) Plaintiff's Objection (to Eyidence in Opposition) MSJ/MSAfiledin

Dept54 Hon. Christopher Krueger -ROA #282 08/20/2021
(113) Plaintiffs Objection to Defendant's Objection to Evidencefiledin

Dept54 Hon. Christopher Krueger-ROA#283 08/24/2021
(114) Plaintiff's Notice of Objection to the Defendants Reply to Memorandum

of Points and Authoritiesfiledin Dept.54 Hon. Christopher
Krueger-ROM284 08/24/2021
(115) Order on the Court Fee Waiver (FW-003)Filed -granted infiill-ROA#286....08/31/2021
(116) Minutes Order Finalized for Motion for Summary Judgment and/pr Adjudication
i -Dept54 Hon. Christopher Krueger - MSJAiSA heard on 09/01/2021
) 8
at 09:00A. by Hon. Christopher Krueger - ROA # 288 09/01/2021
(117) The First Court Notice which notified Plaintiff that his Motion for Reconsideration
submitted on September 10,2021 to the Dept. 54- Hon. Hon. Christopher
Krueger was rejected bytiieCourt -ROA # 290 09/21/2021
(118) Notice-Plaintiffs Disapproval of the Defendant's Proposed Order Granting

MSJ by HOIL Christopher Krueger -Dept 54 ROA # 291 09/20/2021
(119) The Second Court Notice which notified Plaintiff that his Motion for Reconsideration
submitted on Septiember 10,2021 to the Dept. 54- Hon. Hon. Christopher
Krueger was rejected by the Court -ROA # 292.... 09/22/2021
(120) Order signed by Hon. Christopher Krueger-Dept 54 after 09/01/2021 Court

Hearing (MSJ) filed-ROA #293 09/23/2021
(121) Plaintiffs Motion for Reconsideration, (MSJ) Declaration and Memorandum

of Points and Authorities in Support of Motion filed in Dept. 54 Hon.
Christopher Krueger -ROA #294,295,296 09/23/2021
(Scheduled fortiieCourt Hearing in Dept54on 10/13/2021-ROA #297)
(122) Defendant's Opposition to the Plaintiff's Motion for Reconsideration

(MSJ) filed in Dept 54 Hon. ChristopheKrueger-ROA#298 09/29/2021
(123) Defendant's Notice of Entry of Order(MSJ) filed in Dept 54 Hon.

Christophe Kraeger-ROA#300 10/152021
(124) Signed Judgment (MSJ) by HOIL Christopher Krueger-Dept 54filed& entered

-ROA#302,303 10/28/2021
(125) Plaintiffs Notice of Appealfiled(MSJ) -ROA #304 12/23/2021
The filed Court document in the related or cross-referenced Sacraniento

Court Superior Court Case Jaroslaw Waszczuk v. Califomia Unen^loyment
Insurance Appeal Board and the Regents of the University of California as the
Real Party in Interest (RPii), Case No. 34-2013-80001699-CUWMGDS, 3DCA
Case No. 079254, the Supreme Court of California Case No. S253713 &
1S245879.
1(126) Petition for Writ of Mandate filed. Mistakenly registered under ROA# 2
I (Civil Case Cover Sheet)... 12/02/2013
i
{127) Civil Case Cover Sheetfiled.Mistakenly registered under (ROA #1)
(Petition for Writ of Mandate) 12/02/2013
(128) Case Assigned to Deptl4- Hon. Eugene L. Balonon 12/02/2013
(129) Court Order Reassigning the CasefromDept 14-Hon. Eugene L. Balonon

to Judge Shelleyahne W. L. Chang in Department 24 effective 03/21/2014
ROA #7 03/21/2014
(130) Demurrer and Declaration in Siipport filed by California Unemployment

Insurance Appeal Board (CUIAB)(Repondent) - Dept24-Hon. Shelliânne
W. L. Chang -ROA #8 & ROA #9 04/01/2014
(131) Motion -Writ of Mandate scheduled for 08/15/2014 at 10:00 A.M in Dept.24
Hon. SheUeyanne W. L. Chang -ROA # 10 04/03/2014
(132) Joinder in Motion (Demurrer)filedby the The Regents ofthe University of

California -Real Party of Interest (RPii) in D^t.24 Hon. Shelleyaime
W. L. Chang -ROA #11... 04/11/2014
(133) Correspondence (Request)filedby CUIAB Attomey Ashante Norton requesting

Demurrer removalfromthe Court Calendar. Hearing was scheduled for
08/15/2014 at 10:A.M n Dept24-Hon. SheUeyanne W. L. Chang-ROA #12 6/11/2014
(134) Motion -Writ of Mandate scheduled for 08/15/2014 at 10:00 A M in Dept.24

Hon. Shelleyarme W. L. Chang at Gordon D. Schaber Courthouse was
Vacated-ROA# 13 ...06/11/2014
(135) RPii Cyntiiia A. Vroom added totiiecase effective 06/20/2014 -R0A#16 06/20/2014
(135) Notice of Court Hearing wasfiledby Petitioner Attomey Douglas Stein

and Petition for Writ of Mandate was scheduled for hearing on 02/27/2015
at 11:00AM in Dept.24- Hon. SheUeyanne W. L. Chang at Gordon D.Schaber
Courthouse -ROA #18 and ROA # 19 07/17/2014 & 07/21/2014
(136) Petitioner's (Jaroslaw Waszczuk) Opening Brieffiledin Dept.24-Hon.

Hon. SheUeyanne W. L. Chang 01/13/2015
(137) Substitution of Attomeyfiledby Petitioner (Jaroslaw Waszczuk) in Dept24

Hon. SheUeyanne W. L. Chang ROA #21 01/14/2015
(138) The Regents of the University of Califomia(RPii) Opposition to Petitioner

Opening Brief fUed in in Dept24 Hon. SheUeyanne W. L. Chang ROA.#23..02/02/2015
(139) Petitioner's (Jaroslaw Waszczuk) Correspondence /Complaint against RPii

attomeys addressed to Hon. SheUeyanne W. L. Chang-Dept24 .-ROA #26 02/17/2015
10
RECORD ON APPEAL -ATTACHMENT 4b
(140) Order Denying Petition for Writ of Mandate - Hon. SheUeyaime
W. L. Chang-Dept.24 -ROA # 34 03/12/2015
(141) Notice of Entry of Judgmentfiled- Hon. SheUeyanne W. L. Chang-

Dept24-ROA#4l 04/01/2015
(142) Memorandum of Costs (Summary) filed by Respondent (CUIAB) in Dept,

24- Hon. SheUeyanne W. L. Chang -ROA #42 04/14/2015
(143) Notice of Filing Notice of Appeal -3DCA -ROA #44 05/12/2015
(144) Judgment (updated witii Costs posted per memo of Costs) -ROA #45 05/19/2015
(145) Petitioner Correspondencefiledin Dept24 -ROA #56 12/06/2018
(146) 3DCA Order Denying Petition for Rehearing -3DCA Justice Blease
ROA #57 01/19/2019
(147) 3DCA Remittitiir issued, judgment is affirmed ROA #58 03/27/2019
Submitted on January 28,2022

J 3roslaw Waszczuk, In Pro Per
11
PROOF OF SERVICE BY US MAIL
Re: Jaroslaw Waszczuk v. The Regents of the University of Califomia

3DCA Case .: C095488 Trial Court Case No.: 34-2013-00155479
I, IRENA WASZCZUK the undersigned, declare that 1 am over 18 years of age

and not a party to the within cause; my address is 2216 Katzakian Way, Lodi, CA.
On January 28, 2022,1 served a original and true copy of the attached each of the
following: PLAINTIFF'S JAROSLAW WASZCZUK - APPELLANT'S
NOTICE DESIGNATING RECORD APPEAL WITH ATTACHMENT 4b
By placing the same copy in an envelope or envelopes addressed respectively as

follows:
Lindsay A. Goulding
I Sacramento, CA 95825
Clerk of Court of Appeals ( Via TruePiling )

Third Appellate District
914 Capitol Mall
I declare under penalty of perjury of the laws of the State of Califomia that
the foregoing is tme and correct. Executed on January 28, 2022, at Lodi CA
IRENA WASZCZin:
Colette M. Bruggman, Clerk
Electronically
Electronically
RECEIVED
RECEIVED
on 9/7/2023
on 9/7/2023
by D. Welton,
at 3:56:54Deputy
PM Clerk
2216 Katzakian Way

Lodi, CA 95242
Phone: 209-663-2977
Fax: 209-370-8281
September 7, 2023
Robert R. Toy
Senior Deputy
350 McAllister St.
Subject: California Supreme Court Case Jaroslaw Waszczuk v. The Regents of the
University of California, Case No. S281719
Re: Hard Copies of the Petition for Review and the Clerk’s Transcript on Appeal
Dear Mr. Toy:
I have sent eight hard copies of my coil-bound Petition for Review to the California
State Supreme Court. I could not find anyone in or around Lodi who provides Velo
binding services. The FedEx Store in Stockton used to offer this, but they have
discontinued the service due to a lack of demand; thus, I had no choice but to use a
coil binding service. Please let me know if I need to find another vendor and re-bind
and resubmit my Petition.
In addition, the Clerk’s Transcript on Appeal, which should have been submitted by
the Court of Appeal, Third Appellate District (3DCA) to the Supreme Court after the
Petition for Review, has been filed.
In 2018, I learned from the 3DCA Clerk that the 3DCA Clerk’s office normally
submits the First Volume of the Clerk’s Transcript after the Petition for Review has
been filed. This is a problem, as 3DCA and I received the CT from the Sacramento
Superior Court Appellate Department more than two months late, despite it being
certified on April 22, 2022. Not only was the CT sent more 60 days later than it
should have been, it was also incomplete. After I complained, the Trial Court sent me
the Supplemental CT Volume 1 of 1, which should have included CT Volume 1 of 13
and been provided to the Supreme Court, since I had filed a Petition for Review.
1
Petition for Review-Record on Appeal
In addition, the Trial Court, acting in a deceptive manner, sent the incomplete CT
with wrong judge’s name (David I . Brown, instead of Christopher E. Krueger) and
the wrong Defendants’ attorney’s name (Douglas Ropel, instead of Lindsay
Goulding). Judge Brown resigned from the bench in December 2022 and Ropel
stopped representing The Regents in March 2016.
On November 14, 2022, 3DCA Justice Ronald Robie issued an order stating that a
request to relabel the transcript was denied as unnecessary (Attachment #1). I believe
that it is necessary for the Supreme Court to know who caused the appeal, this
Petition for Review, and why.
On August 29, 2023, I submitted an inquiry to the 3DCA Clerk’s office (Attachment
#2) to provide to the Supreme Court a proper volume of the Clerk’s Transcript and
Supplemental Clerk’s Transcript Volume 1 of 1, which should be a part of the CT
Volume 1 of 13.
I would appreciate it if the Supreme Court’s Clerk’s office would ensure that the
3DCA Clerk’s office provides the Supreme Court with the right Clerk Transcript
volumes and that they are properly labeled.
Respectfully submitted,
________________
Plaintiff & Appellant in Pro Per
2
MAILING LIST
Re: Waszczuk v. Regents of the University of California, Supreme Court of

California Case No. S281719 , 3 DCA Case No. C095488
Sacramento County Super. Ct. No. 34201300155479CUWTGDS
Copies of this document have been sent by mail to the parties checked below unless
they were notified electronically.
Lindsay Alida Goulding Porter Scott- TrueFiling

H. Thomas Watson -TrueFiling Karen M. Bray-TrueFiling

Horvitz & Levy LLP
3601 West Olive Avenue, 8th Floor Burbank, CA 91505
The Court of Appeals, -TrueFiling

914 Capitol Mall
Hon. Michael G. Bowman, Presiding Judge

SUPERIOR COURT OF CALIFORNIA
County of Sacramento 720 9th Street
3
Andrea K. Wallin-Rohmann, Clerk
Electronically FILED on 11/14/2022 by J. Swartzendruber, Deputy
IN THE
Courtt off Appeall off thee Statee off California
IN AND FOR THE
JAROSLAW WASZCZUK,
Plaintiff and Appellant,
v.
REGENTS OF THE UNIVERSITY
OF CALIFORNIA et al.,
C095488
Sacramento County
No. 34201300155479CUWTGDS
BY THE COURT:
Appellant's motion to augment the record on appeal is granted in part and

denied in part. Appellant’s motion is granted as to the September 1, 2021 Reporter’s
Transcript. The clerk of this court is directed to file the Reporter’s Transcript attached
to this order.
Appellant’s motion to augment the record on appeal is denied as to item 102,

the motion to recall the remittitur in case number C079524 and items 126WKURXJK47.
There is no indication that the requested material was filed RUlodged in the VXSHULRU
court in this case. (Cal. Rules of Court, rule 8.155.)
Appellant’s request to relabel the transcript is denied as unnecessary.
ROBIE, Acting
Actin P.J.
--------------------------------
cc: See Mailing List

IN THE
Court of Appeal of the State of California
IN AND FOR THE
MAILING LIST

C095488
Copies of this document have been sent by mail to the parties checked below unless they were
noticed electronically. If a party does not appear on the TrueFiling Servicing Notification and is
not checked below, service was not required.
Jaroslaw Waszczuk
2216 Katzakian Way
Lodi, CA 95242
Lindsay Alida Goulding

Porter Scott
H. Thomas Watson
Horvitz & Levy LLP
3601 West Olive Avenue, 8th Floor
Burbank, CA 91505
Karen M. Bray
Horvitz & Levy LLP
Burbank, CA 91505

720 Ninth Street
JAROSLAW ("JERRY" WASZCZUK vs REGENTS OF UNIVERSITY OF CALIFORNIA
34-2013-00155479 September 1, 2021 Page 1
·1
·2
·3· · · · · ·THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
·4· · · · · · · ·IN AND FOR THE COUNTY OF SACRAMENTO
·5· · · · · · · · · · · · · ·---o0o---
·6
·7· ·JAROSLAW ("JERRY")· · · · ·)

· · ·WASZCZUK,· · · · · · · · · )
·8· · · · · · · · · · · · · · · )
· · · · · · · Plaintiff,· · · · )· No.· 34-2013-00155479
·9· · · · · · · · · · · · · · · )
· · ·vs.· · · · · · · · · · · · )
10· · · · · · · · · · · · · · · )· Dept.· 54
· · ·THE REGENTS OF THE· · · · ·)
11· ·UNIVERSITY OF CALIFORNIA,· )
· · ·UNIVERSITY OF CALIFORNIA· ·)· REPORTER'S TRANSCRIPT OF
12· ·DAVIS HEALTH SYSTEM, UC· · )· MOTION FOR SUMMARY
· · ·DAVIS MEDICAL CENTER, UC· ·)· JUDGEMENT AND/OR
13· ·DAVIS, ANN MADDEN RICE,· · )· ADJUDICATION
· · ·MIKE BOYD, STEPHEN· · · · ·)
14· ·CHILCOTT, CHARLES WITCHER, )
· · ·DANESHA NICHOLS, CINDY· · ·)
15· ·OROPEZA, BRENT SEIFERT,· · )
· · ·PATRICK PUTNEY, DORIN· · · )
16· ·DANILIUC, and Does 1· · · ·)
· · ·through 50, inclusive,· · ·)
17· · · · · · · · · · · · · · · )
· · · · · · · Defendants.· · · ·)
18· · · · · · · · · · · · · · · )
· · ·__________________________ )
19
· · · · · · · · · · · · · · ·---o0o---
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· · · · · · · · · · ·Wednesday, September 1, 2021
21
· · · · · · · · · · · · · · ·---o0o---
22
· · · · · · · · The above-entitled matter came on regularly at
23· · the date above set forth before the HON. CHRISTOPHER E.
· · · KREUGER, Judge of the Superior Court of the State of
24· · California, County of Sacramento.
25
26
27· ·Reported by:
28· ·Valerie Haley, CSR No. 10771

County of Sacramento 09-27-2022 4:44PM
34-2013-00155479 September 1, 2021 Page 2
·1· · · · · · · · · · APPEARANCES OF COUNSEL
·2· ·For the Plaintiff JAROSLAW ("JERRY") WASZCZUK:
·3· ·JAROSLAW ("JERRY") WASZCZUK, In Propria Persona

· · ·2216 Katzakian Way
·4· ·Lodi CA 95242
·5
· · ·For the Defendants The Regents of the University of
·6· ·California, et. al.:
·7· ·PORTER SCOTT

· · ·350 University Avenue, Suite 200
·8· ·Sacramento, CA 95825
· · ·By:· THOMAS L. RIORDAN
·9· ·Attorney at Law
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County of Sacramento 09-27-2022 4:44PM YVer1f
34-2013-00155479 September 1, 2021 Page 3
·1· · · · · · · · · · · · · SESSIONS
·2· ·DATE· · · · · · · · · · · · · · · · · · · · · · PAGE
·3· ·SEPTEMBER 1, 2021
·4· ·MORNING SESSION· · · · · · · · · · · · · · · · · 4

· · ·Motion for Summary Judgment and/or Adjudication 4
·5
·6
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34-2013-00155479 September 1, 2021 Page 4
·1· · · · · · · · ·WEDNESDAY, SEPTEMBER 1, 2021

·2· · · · · · · · · · · ·MORNING SESSION
·3· · · · · · · · · · · · · ---o0o---
·4· · · · · ·Proceedings in the matter of Jaroslaw ("Jerry")
·5· ·Waszczuk, Plaintiff, versus The Regents of the
·6· ·University of California, et. Al., Defendants, Case
·7· ·No. 34-2013-00155479, came on regularly before the
·8· ·Honorable Christopher E. Krueger, Judge of the
·9· ·Sacramento Superior Court, County of Sacramento, State
10· ·of California, sitting in Department 54.
11· · · · · ·The Plaintiff Jaroslaw ("Jerry") Waszczuk
12· ·appeared In Propria Persona, remotely via Zoom.
13· · · · · ·The Defendants, The Regents of the University
14· ·of California, et. Al., were represented by Thomas L.
15· ·Riordan, Attorney at Law, appearing remotely via Zoom.
16· · · · · ·The following proceedings were then had, to
17· ·wit:
18· · · · · · · · · · · · ·---o0o---
19· · · · · ·THE COURT:· Okay.· So, Mr. Waszczuk, why don't
20· ·you proceed.
21· · · · · ·MR. WASZCZUK:· Your Honor, I couldn't find
22· ·anything positive in the court decision, and that's why
23· ·I requested this hearing.· You know, it's -- the key
24· ·issue is, here, there is an agreement of 2009.· As -- as
25· ·I pointed in my opposition to summary judgment, I
26· ·basically cannot afford.
27· · · · · ·There was, you know, harassment and
28· ·discrimination and other stuff, and just, I am asking

34-2013-00155479 September 1, 2021 Page 5
·1· ·Court to enforce the settlement agreement, which is

·2· ·paragraph 20, saying that this is -- again, the -- it
·3· ·was in state of California -- interpret and enforce in
·4· ·accordance with California law.
·5· · · · · ·And other paragraph, 23rd, is Court should
·6· ·determine if this agreement is enforceable or if it's
·7· ·not.· You know, the agreement was given to me in 2009,
·8· ·the right me -- you know, job was disagreement, and I
·9· ·was expecting to retire with this agreement at 66.
10· · · · · ·And you know, and therefore -- and, you know, I
11· ·don't know if Court look at any of my exhibit because
12· ·from the -- from -- from the decision, you know, I
13· ·could -- you know, I could only determine the Court even
14· ·didn't bother to look at my exhibits.
15· · · · · ·THE COURT:· The Court looked at the records.
16· ·There's a lot here, but if there's stuff you want to
17· ·tell us about, this is your chance.
18· · · · · ·MR. WASZCZUK:· Yeah, your Honor, my Exhibit 17.
19· ·This is very short.· It was provided with -- with
20· ·production of documents by defendants.
21· · · · · ·THE COURT:· What?· What do you want to tell me
22· ·about Exhibit 17?
23· · · · · ·MR. WASZCZUK:· On May -- on May the 10, 2012,
24· ·the exhibit saying, you know, that I should -- they were
25· ·ready to give me new job description.· Defendant should
26· ·give me new job description, and basically, promoted me
27· ·to senior development engineer, which is in my
28· ·termination letter and -- and letter in the intent to

34-2013-00155479 September 1, 2021 Page 6
·1· ·terminate.· They promoted me, mean somebody stopped on

·2· ·this day, stop it, my promotion, and -- and new job
·3· ·description on May 10 -- exactly on this day, for some
·4· ·reason.· And you know, I -- I know the reason.
·5· · · · · ·And, you know, this is -- I was kept out of
·6· ·premises for one year, for over one year, your Honor. I
·7· ·was not working, you know.· And then they -- they were
·8· ·testing me -- the defendant was testing me if I would
·9· ·blow the whistle if they -- they going to sell power.
10· ·If I blow whistle, they going to, you know, sell
11· ·illegally power to SMUD, you know.· And, you know, I
12· ·didn't even care, I didn't think about, and nothing.
13· · · · · ·And they finally decided, they -- they let me
14· ·come back to work, and somebody stop it on May 10, 2012.
15· ·This is -- this clearly shows --
16· · · · · ·THE COURT:· I'm sorry, what is this May 10th,
17· ·2012, email supposed to prove or show?· I don't really
18· ·understand your point.· I'm looking at it.· I don't know
19· ·what you're talking about.
20· · · · · ·MR. WASZCZUK:· This is the correspondence
21· ·between human resources lawyer with a manager of
22· ·employer labor relation, and this email is saying
23· ·that -- also says Jerry job description is not yet
24· ·complete.· Are you okay with sending a separate letter
25· ·once the Mattisis (verbatim) memo goes out to all staff
26· ·and to Jerry, and then Jerry a letter with the memo and
27· ·new job description.
28· · · · · ·And -- and everything was put -- put in system

34-2013-00155479 September 1, 2021 Page 7
·1· ·because letter of -- letter of termination and a letter

·2· ·intent to terminate on September 25, 2012, show -- shows
·3· ·that I was promoted to the senior development engineer
·4· ·from associate development engineer.· This is $20,000
·5· ·more, your Honor.
·6· · · · · ·THE COURT:· Okay.
·7· · · · · ·MR. WASZCZUK:· And suddenly, you know, somebody
·8· ·stop the action, and they fire me for -- without cause.
·9· ·They -- they -- they fabricated the report, you know.
10· · · · · ·You know, your Honor, I would like to refer
11· ·your Honor to Defendant Exhibit A, which is -- which is
12· ·my Second Amended Complaint, to page -- to page number
13· ·six.· Because everything is -- that is in it is
14· ·negative.· Maybe Court look my evaluation first, from --
15· ·from the beginning of my employment to the end.
16· · · · · ·THE COURT:· What about it?· What exhibit are
17· ·you referring to?
18· · · · · ·MR. WASZCZUK:· I am referring to Exhibit A,
19· ·Defendant Exhibit A.
20· · · · · ·THE COURT:· A, as in Apple?
21· · · · · ·MR. WASZCZUK:· Yeah, as the apple, page number
22· ·six, which is the correspondent with my Exhibit Number 7
23· ·in my exhibit index.
24· · · · · ·THE COURT:· That is the middle of your Second
25· ·Amended Complaint; that's Exhibit A?
26· · · · · ·MR. WASZCZUK:· Yes, yes, yes, yes, your Honor.
27· ·This is most, you know, important stuff in whole
28· ·proceeding and evaluations, not some, you know, hearsay

34-2013-00155479 September 1, 2021 Page 8
·1· ·reports.· This is -- this is -- this is the University

·2· ·policy, BPM 23, which is equal to law -- you know, state
·3· ·law.
·4· · · · · ·Is doesn't correspond with, you know, to what
·5· ·Court wrote in decision.· It was nothing.· The course
·6· ·was nothing -- I was good employee.· This is evaluation
·7· ·signed by those manager -- manager who -- who sign every
·8· ·paper they gave him on me, you know.
·9· · · · · ·THE COURT:· Okay.· Page six of your Complaint
10· ·is not evidence.· I mean, it's just your Complaint.· I'm
11· ·not sure --
12· · · · · ·MR. WASZCZUK:· No, but is evidence -- evidence
13· ·is of my Exhibit Number 7.· This is correspond with my
14· ·Exhibit Number 7, all evaluations.
15· · · · · ·THE COURT:· Okay.
16· · · · · ·MR. WASZCZUK:· You cannot, you know, slander
17· ·somebody and make him righteous if it is not true, and
18· ·you give him good evaluation, your Honor.
19· · · · · ·THE COURT:· But it is possible for someone to
20· ·have good evaluations --
21· · · · · ·MR. WASZCZUK:· No, not -- your Honor --
22· · · · · ·THE COURT:· What?
23· · · · · ·MR. WASZCZUK:· You know, in -- in -- in 2007,
24· ·the guy who sign suspension letter and made me looks
25· ·like racist Nazi guard of concentration camp, and
26· ·whatever he did, and KKK, and three months later, sign
27· ·my evaluation, which was perfect.· Was the same
28· ·evaluation period.· How you could court believe even

34-2013-00155479 September 1, 2021 Page 9
·1· ·something like that, you know?

·2· · · · · ·THE COURT:· You have to get clear -- I mean,
·3· ·I'm going to give you a little more time, but you have
·4· ·to speak to what cause of action there's a disputed
·5· ·issue of fact on.· Because, like, there's a lot of this
·6· ·case that you basically didn't even oppose.· You said
·7· ·things like --
·8· · · · · ·MR. WASZCZUK:· Your Honor -- your Honor --
·9· · · · · ·THE COURT:· -- this is not really relevant, or
10· ·this is not really -- there's -- I mean, several causes
11· ·of action you've conceded, although --
12· · · · · ·MR. WASZCZUK:· Your Honor, termination is --
13· ·was based on employee's performance review.· They all
14· ·records what investigator made must be reflect employee
15· ·evaluation.· It's not -- this is -- you know, I was just
16· ·wrongfully terminated, in violation by -- you know, I
17· ·want the Court to enforce the settlement agreement. I
18· ·don't care about other stuff.
19· · · · · ·THE COURT:· All right.· Mr. Riordan, do you
20· ·have anything to submit?
21· · · · · ·MR. RIORDAN:· No, I rely on the tentative
22· ·ruling.
23· · · · · ·THE COURT:· The Court has quite a long
24· ·tentative ruling, and Court affirms the tentative
25· ·ruling.· Thank you very much.
26· · · · · ·MR. RIORDAN:· Thank you, your Honor.
27· · · · · · · · · ·(Proceedings concluded.)
28· · · · · · · · · · · · · ---o0o---

34-2013-00155479 September 1, 2021 Page 10
·1· · · · · ·CERTIFICATE OF CERTIFIED SHORTHAND REPORTER
·2
·3· ·STATE OF CALIFORNIA)

· · · · · · · · · · · · )· ss.
·4· ·COUNTY OF SACRAMENT)
·5
·6· · · · ·I, Valerie Haley, hereby certify that I am a
·8· ·verbatim in stenographic writing the proceedings had on
·9· ·Wednesday, September 1, 2021, in the matter of Jaroslaw
10· ·("Jerry") Waszczuk, Plaintiff, versus The Regents of the
11· ·University of California, et. Al., Defendant, Case No.
12· ·34-2013-00155479, completely and correctly to the best
13· ·of my ability; that I have caused said stenographic
14· ·notes to be transcribed into typewriting, and pages 1
15· ·through 10, constitute a complete and accurate
16· ·transcript of said stenographic notes taken at the
17· ·above-mentioned proceedings.
18· · · · ·I further certify that I have complied with CCP
19· ·237(a)(2) in that all personal juror identifying
20· ·information has been redacted if applicable.
21
22· ·Dated:· Monday, March 21, 2022
23
24
25
26
27· · · · · · · · · · · · ________________________
· · · · · · · · · · · · · Valerie Haley, CSR
28· · · · · · · · · · · · Certificate No.· 10771

34-2013-00155479 September 1, 2021 ·Index: "jerry..guy
case 4:6 9:6
" 6 E
chance 5:17
"jerry 4:4,11 66 5:9 Christopher 4:8 email 6:17,22
clear 9:2 employee 8:6 9:14
$ 7 Complaint 7:12,25 8:9, employee's 9:13
10
$20,000 7:4 7 7:22 8:13,14 employer 6:22
complete 6:24
employment 7:15
- A conceded 9:11
end 7:15
concentration 8:25
---o0o--- 4:3,18 9:28 accordance 5:4 enforce 5:1,3 9:17
concluded 9:27
action 7:8 9:4,11 enforceable 5:6
correspond 8:4,13
1 engineer 5:27 7:3,4
Adjudication 3:4 correspondence 6:20
affirms 9:24 equal 8:2
1 3:3 4:1 correspondent 7:22
afford 4:26 evaluation 7:14 8:6,18,
10 5:23 6:3,14 County 4:9 27,28 9:15
10th 6:16 agreement 4:24 5:1,6, court 4:9,19,22 5:1,5, evaluations 7:28 8:14,
7,9 9:17
17 5:18,22 11,13,15,21 6:16 7:6, 20
Amended 7:12,25 14,16,20,24 8:5,9,15,
19,22,28 9:2,9,17,19, evidence 8:10,12
2 and/or 3:4 23,24 exhibit 5:11,18,22,24
appeared 4:12 7:11,16,18,19,22,23,25
20 5:2 8:13,14
appearing 4:15 D
2007 8:23 exhibits 5:14
apple 7:20,21
2009 4:24 5:7 DATE 3:2
associate 7:4 expecting 5:9
2012 5:23 6:14,17 7:2 day 6:2,3
Attorney 4:15
2021 3:3 4:1 decided 6:13 F
23 8:2 B decision 4:22 5:12 8:5

fabricated 7:9
23rd 5:5 defendant 5:25 6:8
back 6:14 7:11,19 fact 9:5
25 7:2 finally 6:13
based 9:13 defendants 4:6,13
5:20 find 4:21
3 basically 4:26 5:26 9:6
Department 4:10 fire 7:8
beginning 7:15
34-2013-00155479 4:7 description 5:25,26
blow 6:9,10 6:3,23,27 G
4 bother 5:14 determine 5:6,13
BPM 8:2 gave 8:8
development 5:27 7:3,
4 3:4 4 give 5:25,26 8:18 9:3
C disagreement 5:8 good 8:6,18,20
5
California 4:6,10,14 discrimination 4:28 guard 8:25
54 4:10 5:3,4 disputed 9:4 guy 8:24
camp 8:25 documents 5:20
care 6:12 9:18

34-2013-00155479 September 1, 2021 ·Index: harassment..suspension
8:24 pointed 4:25 review 9:13
H
long 9:23 policy 8:2 righteous 8:17
harassment 4:27 looked 5:15 positive 4:22 Riordan 4:15 9:19,21,
26
hearing 4:23 lot 5:16 9:5 power 6:9,11
ruling 9:22,24,25
hearsay 7:28 premises 6:6
M
Honor 4:21 5:18 6:6 proceed 4:20
S
7:5,10,11,26 8:18,21 proceeding 7:28
made 8:24 9:14
9:8,12,26
proceedings 4:4,16 Sacramento 4:9
make 8:17
Honorable 4:8 9:27 sell 6:9,10
manager 6:21 8:7
human 6:21 production 5:20 sending 6:24
matter 4:4
promoted 5:26 6:1 7:3 senior 5:27 7:3
I Mattisis 6:25
promotion 6:2 separate 6:24
memo 6:25,26
illegally 6:11 Propria 4:12 September 3:3 4:1 7:2
middle 7:24
important 7:27 prove 6:17 SESSION 3:4 4:2
months 8:26
index 7:23 provided 5:19 SESSIONS 3:1
MORNING 3:4 4:2
intent 5:28 7:2 put 6:28 settlement 5:1 9:17
Motion 3:4
interpret 5:3 short 5:19
investigator 9:14 R
N show 6:17 7:2
issue 4:24 9:5 racist 8:25 shows 6:15 7:2
Nazi 8:25
ready 5:25 sign 8:7,24,26
J negative 7:14
reason 6:4 signed 8:7
number 7:12,21,22
Jaroslaw 4:4,11 8:13,14 records 5:15 9:14 sitting 4:10
Jerry 6:23,26 refer 7:10 slander 8:16
job 5:8,25,26 6:2,23,27 O referring 7:17,18 SMUD 6:11
Judge 4:8 reflect 9:14 speak 9:4
oppose 9:6
judgment 3:4 4:25 Regents 4:5,13 staff 6:25
opposition 4:25
regularly 4:7 state 4:9 5:3 8:2
K
P relation 6:22 stop 6:2,14 7:8
key 4:23 relevant 9:9 stopped 6:1
paper 8:8
KKK 8:26 rely 9:21 stuff 4:28 5:16 7:27
paragraph 5:2,5 9:18
Krueger 4:8 remotely 4:12,15
perfect 8:27 submit 9:20
report 7:9
performance 9:13 suddenly 7:7
L
reports 8:1
period 8:28 summary 3:4 4:25
labor 6:22 represented 4:14
Persona 4:12 Superior 4:9
law 4:15 5:4 8:2,3 requested 4:23
Plaintiff 4:5,11 supposed 6:17
lawyer 6:21 resources 6:21
point 6:18 suspension 8:24
letter 5:28 6:24,26 7:1 retire 5:9

34-2013-00155479 September 1, 2021 ·Index: system..Zoom
system 6:28
Y
T
year 6:6
talking 6:19
Z
tentative 9:21,24
terminate 6:1 7:2 Zoom 4:12,15
terminated 9:16
termination 5:28 7:1
9:12
testing 6:8
things 9:7
Thomas 4:14
time 9:3
true 8:17
understand 6:18
University 4:6,13 8:1
verbatim 6:25
versus 4:5
violation 9:16
Waszczuk 4:5,11,19,
21 5:18,23 6:20 7:7,18,
21,26 8:12,16,21,23
9:8,12
WEDNESDAY 4:1
whistle 6:9,10
wit 4:17
work 6:14
working 6:7
wrongfully 9:16
wrote 8:5

ATTACHMENT # 2
Colette M. Bruggman, Clerk Colette M. Bruggman, Clerk
Electronically RECEIVED on 8/29/2023 at 2:00:40 AM Electronically FILED on 8/29/2023 by D. Welton, Deputy Clerk
2216 Katzakian Way

Lodi, CA 95242
Phone: 209-687-1180
Fax: 209-729-5154
August 29, 2023
Colette M. Bruggman
Clerk/Executive Officer
The Court of Appeals
914 Capitol Mall
Subject: Sacramento Superior Court Wrongful Termination Case No. 34-2013-

00155479, Jaroslaw Waszczuk v. The Regents of the University of California, filed on
December 4, 2013, and
the Court of Appeal, Third Appellate District, Case No. C095488, Waszczuk v.
Regents of the University of California et al.
Re: Request for the 3DCA Clerk’s Office to transmit the Supplemental Clerk’s Transcript on
Appeal and Clerk’s Transcript Volume 1 to the Supreme Court of California in the above-
captioned Case No. C095488
Dear Ms. Bruggman:
As you are aware my Petition for Rehearing and Motion for Judicial Notice in Support,
which were permitted to be filed on August 21, 2023 per the Court order (ATTACHMENT
#A) than were denied three days later, on August 24, 2023, by another court order
(ATTACHMENT #B). The Court denied my Petition for Rehearing and Motion for Judicial
Notice on the same day that I sent to you my August 24, 2023, response to your letter of
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COLETTE M. BRUGGMAN -3DCA Clerk/Executive Officer- 3DCA Appeal Case
Record Transmission to The Supreme Court
August 22, 2023. Thus, I will shortly submit a Petition for Review to the Supreme Court of
California, pursuant to the California Rules of Court Rule 8.500.
With this inquiry, I respectfully request that after my Petition for Review is submitted to the
Supreme Court of California, the Third District Court of Appeal (3DCA) clerk’s office must
transmit to the Supreme Court the Supplemental Clerk’s Transcript (Supp. CT), Volume 1 of
1, and the Clerk’s Transcript (CT), Volume 1 of 13, docketed in 3DCA. Originally, the Supp.
CT and part of CT Volume 1 should have been produced by the trial court’s Appellate
Department and transmitted in April 2022 to 3DCA as a CT Volume 1of 13 and should
contain 300 pages.
As I learned from 3DCA Clerk Anita Kenner’s March 20, 2018, correspondence, it is
standard procedure for 3DCA to transmit only the first volume of a record to the
Supreme Court when a Petition for Review has been filed (ATTACHMENT #C).
If the CT had been produced by the trial court’s Appellate Department and certified as
requested by the January 31, 2022, APPELLANT’S NOTICE DESIGNATING RECORD
ON APPEAL (ATTACHMENT #D) and sent to me and 3DCA in April 2022, then CT
Volume 1 of 13 would have chronologically included the following 167 pages of the
documents from the Supp. CT Volume No. 1 of 1 (ATTACHMENT #D):
12/04/13 COMPLAINT, 06/16/14 FIRST AMENDED COMPLAINT, 09/10/14
NOTICE TO FILING PARTY, 09/24/14 EX PARTE APPLICATION FOR LEAVE
TO FILE and the SECOND AMENDED COMPLAINT BY STIPULATION AND
ORDER THEREON plus approximately 16 pages of Chronological Index and
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approximately 117 pages from what is now CT volume No. 1 of 13 (ATTTACHMENT
# E) which would include and not limited to :
12/17/14 PLAINTIFFS EX PARTE APPLICATION ( Douglas Stein’s Application to
continue the anti-SLAPP motion after he was dismissed from the case on 12/16/2014 for
the following reason.:
• Failure to amend defective SAC ,

• Failure to object The Regents anti-SLAPP motion ,
• For representing me with suspended attorney license
• For stealing $ 20,000 from me.
• For conspiracy with The Regents attorney Michael Pott and collusion with Judge
Davis I Brown .
12/17/14 ORDER DETERMINING DISPOSITION OF EX PARTEAPPLICATION- Order
signed by Judge David I . Brown which legitimized conspiracy concocted by Stein & Pott)
12/24/14 NOTICE TO FILING PARTY- Rejected document by the Court Clerk
12/29/14 PLAINTIFFS EX PARTE APPLICATION FOR POSTPONEMENT with exhibits
– In my 12/29/14 Ex-Parte Application I asked Judge to postpone the anti-SLAPP motion
process to give me some time to find a new attorney and amend and to correct SAC which
Stein filed on September 30, 2014 in conspiracy with The Regents attorneys Michael Pott to
end my litigations against the Regents in December 2014.
The Supp. CT Volume 1 of 1, which should have been part of CT Volume 1 of 13, were
the most important parts of this appeal.
Both Supp. CT Volume 1 of 1 and CT Volume 1 of 13 contain documents that show the
criminal and professional misconduct of my former attorney, Douglas Edward Stein, and
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the attorney for The Regents of the University of California, Michael Pott, and the judicial
misconduct by Sacramento County Superior Court Judge David I. Brown from
Department 53. They colluded in this case because Judge Brown was Stein’s long-time
friend (ATTACHMENT #G).
The detailed events presented below surrounding the RECORD ON APPEAL in this case
leave no doubt that the exclusion of the 12/04/13 COMPLAINT, 06/16/14 FIRST
AMENDED COMPLAINT, 09/10/14 NOTICE TO FILING PARTY, 09/24/14 EX PARTE
APPLICATION FOR LEAVE TO FILE and SECOND AMENDED COMPLAINT BY
STIPULATION AND ORDER THERON from the original CT Volume 1 of 13 was a
premeditated act of deception and conspiracy to deceive me and the Supreme Court of
California and to obtain the Supreme Court of California order to deny my Petition for
Review if I file it.
.
THE CASE
My wrongful termination Case No. 34-2013-00155479, Jaroslaw Waszczuk v. The Regents of
the University of California, was filed in Sacramento County Superior Court almost nine
years ago, on December 4, 2013. This occurred simultaneously with the Sacramento County
Superior Court—Writ of Mandamus, Case No. 34-2013-80001699, Jaroslaw Waszczuk v.
California Unemployment Insurance Appeal Board (CUIAB) and Real Party of Interest
(RPii)—The Reagents of the University of California (UC Regents), filed on December 2,
2013.
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In my AOB, on Page 41, I mention that, on March 3, 2020, I submitted to the Court a
Submission Form to set Trial Date on August 11 or 18 or September 28, 2020 (Attachment
#40). The Court did not bother to respond. (see AOB attachment No. 74)
The Code of Civil Procedure section 583, subdivision (b), mandates the dismissal of
actions not brought to trial within five years after a complaint is filed; however, it was not the
intention or desire of the Court or UC Regents’ attorneys to try the case.
Instead of working with me to set a court trial date, the Porter Scott attorneys waited
for Judge Brown’s resignation and ambushed my 70-year-old wife, stealing from her $22,284
up front of Judge Thadd Blizzard, of Department 43, and his Court Clerk. The rest of the
story you can read in the AOB Brief concerning why this happened and why this case is still
pending after almost nine years
THE NOTICE OF APPEAL
On December 23, 2021, I filed a Notice of Appeal concerning the October 28, 2021 Motion
of Summary Judgment signed by Sacramento County Superior Court Judge Christopher E.
Krueger, from Department 54
APPELLANT’S CIVIL APPEAL MEDIATION STATEMENT
On January 11, 2022, I filed a Civil Appeal Mediation Statement in which, under the list of
issues raised on appeal, I wrote:
I want to examine whether the Appellant was duped or deceived by his

Attorney, Douglas Stein; the Defendants' attorneys; and/or Sacramento
County Superior Court staff and judicial officers to pursue his wrongful
termination complaint, Jaroslaw Waszczuk v. Regents of the University
of California, Ann Madden Rice, Mike Boyd, Stephen Chilcott, Charles
Witcher, Danesha Nichols, Cindy Oropeza, Brent Seifert, Patrick Putney,
Dorin Daniliuc, Case No. 34-2013-34-00155479, and cross-referenced
Writ of Mandamus complaint Jaroslaw Waszczuk v. California
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Unemployment Insurance Appeal Board and the Regents of the
University of California as the Real Party in Interest (RPii), Case No. 34-
2013-8000-1699-CUWMGDS, in Sacramento County Superior Court,
instead of San Joaquin County Superior Court.
I have been living in the City of Lodi, State of California's San Joaquin County,
since 1989.
I became very suspicious in April 2021 that both of my cases, Writ of Mandamus Case No.
34-2013-80001699, Jaroslaw Waszczuk v. (CUIAB) and Real Party of Interest (RPii)—
(UC Regents), filed on December 2, 2013, and Jaroslaw Waszczuk v. Regents of the
University of California, Case No. 34-2013-34-00155479, were filed and pursued in the
wrong county’s superior court, that is, in the wrong venue. The Respondent (UC Regents)
submitted their Respondent’s Mediation Statement on January 11, 2022 .The Respondent’s
Mediation Statement was signed by Porter Scott attorney Thomas Jordan, a former 3DCA
research attorney for three years
https://apps.calbar.ca.gov/attorney/Licensee/Detail/104827, In re Riordan, 26 Cal.4th
1235 (Cal. 2002)). Thomas Riordan is not listed as a Defendant’s Attorney of Record on the
Appeal, or in the trial Court in this case. On January 27, 2022, the case was ordered not
eligible for mediation by 3DCA Justice Andrea Hoch
APPELLANT’S NOTICE DESIGNATING RECORD ON APPEAL,

FILED ON JANUARY 31, 2022
On January 31, 2022, I filed a Notice Designating Record on Appeal that included a request
to produce and transmit to 3DCA the Court Reporter’s Transcript from the September 1, 2021
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Court hearing with Sacramento County Superior Court Judge Christopher E. Krueger, of
Department 54 (Court hearing for Motion for Summary Judgment )
A CLOSER LOOK AT THE INCOMPLETE AND WRONGLY LABELED

TRANSCRIPT ON APPEAL
1) After I received on June 28, 2022 the 13 volumes of the CLERK’S TRANSCRIPT
ON APPEAL (CT), I noticed that the CT had the wrong judge’s name and wrong
attorney
2) It said “CLERK'S TRANSCRIPT ON APPEAL FROM THE JUDGMENT OF THE
SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE
COUNTY OF SACRAMENTO HON. DAVID BROWN DOUGLAS ROPEL
#300486, 350 UNIVERSITY AVE., STE 200 SACRAMENTO, CA 95825 Attorney
Defendant/Respondent,” instead of HON. CHRISTOPHER E. KRUEGER and
Defendant’s Attorneys LINDSAY GOULDING, who is The Regants Attorney of
Record on Appeal, or THOMAS RIORDAN, who attended the Motion for Summary
Judgment Court Hearing with Judge Krueger via Zoom on September 1, 2021.
3) The CT was certified on April 22, 2022 by Sacramento County Superior Court Appellate
Department CLERK KEVIN MICHAUD with his initials KM .
4) The DECLARATION OF MAILING, which should be dated and signed under penalty of
perjury by the Sacramento County Superior Court Clerk, most likely by KEVIN
MICHOUD, was left blank (undated and unsigned), rendering it basically invalid, and
it contained the wrong name of the Defendants’ attorney, Douglas Ropel, who does not
work for Porter Scott and has not represented the UC Regents since March 2016
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(https://www.littler.com/lawyer-search?lawyer_auto=ropel,
5) The CRT from the September 1, 2021 Court Hearing with Judge Krueger, which was due
to be produced and transmitted to 3DCA by May 9, 2022, was not produced and
transmitted to 3DCA at all. The NOTICE to prepare CRT by the Court Reporter stated as
follows :
Appeal from the Honorable Judge DAVID BROWN instead of Judge CHRISTOPHER
KRUEGER
PLEASE TAKE NOTICE that you and each of you are hereby directed
to commence preparation of the REPORTER'S TRANSCRIPT on
Appeal in the above-entitled action. The Appeal is to the THIRD
DISTRICT COURT OF APPEAL and the transcript is to contain the
following dates, as designated by the APPELLANT/RESPONDENT:
COURT DATES (CSR) NUMBER COURT REPORTER'S NAME
09/01/21 8923 T. Tavalero
TRANSCRIPTS ARE DUE: 05/09/22

Please read all designations as Computer-Readable format may have
been requested.
Please notify the Appeals Unit in writing before the due date if no
transcript will be filed. Requests for an extension of time from the
Third District Court of Appeal should be filed prior to the due date.
I declare under penalty of perjury that this notice was sent to the aforementioned reporters
and the Court Reporter Supervisor via interoffice Email.
Executed on: April 8, BY: Kevin M.

Deputy Clerk
The above Notice to Prepare Court Reporter Transcript was supposedly sent by Clerk
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KEVIN MICHAUD to Court Reporter TINA TAVALERO via interoffice mail with the
misleading statement that the Appeal was from Judge Brown, who resigned from
Department 53 in December 2020, and the CRT was from the September 1, 2021 hearing
with JUDGE CHRISTOPHER KRUEGER from Department 54.
On June 27–28, 2022 I learned via an e-mail chat between Executive Analyst from the
Court Reporter’s Board of California, Paula Bruning, and Sacramento County Superior
Court Reporters Valerie Haley and Tina Tavalero that Ms. Halley had not received any
appeal notice in Waszczuk v. the Regents of the University of California for the 9/1/2022
Court Hearing with Judge Krueger, but she produced the CRT for the Porter Scott
attorneys representing the UC Regents.
I examined again the April 8, 2022 Notice of Filing of Designation and Notice to
Reporters to Prepare Transcripts, which was sent by Deputy Clerk Kevin Michaud,
from Appeals Unit Room 102, under penalty of perjury, and discovered that a Notice was
sent to Ms. Tavalero with a due date to produce transcripts on appeal.
I forwarded Ms. Bruning’s e-mail to Ms. Tavalero, and Ms. Tavalero responded that she
had nothing to do with the CRT from the September 1, 2022 Court Hearing with Judge
Krueger. She stated in her email response:
I was not the court reporter for this case. My name was put on the appeal
notice by mistake. It had another court reporter's CSR No. and my name. I
checked all my notes and I was not the reporter on this. I sent a declaration to
the 3DCA stating that I was listed by mistake and I have no notes for any of the
proceedings. ( See: Tina Tavalero Declaration in the case C095488 docket)
However, in her June 28, 2012 e-mail response, Ms. Tavalero did not state
whether she ever received the April 8, 2022 Notice of Filing of Designation and Notice to
Reporters to Prepare Transcripts, sent supposedly by Deputy Clerk Kevin Michaud, nor
did she comment on whether she had informed Michaud that she had nothing to do with
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the September 1, 2021 hearing, or whether she advised Michaud that the notice had the
wrong Judge’s name on it.
How it is even possible for a Court Reporter to prepare a transcript on appeal per
notice from the Appellate Department with the wrong Judge on the notice? The above
facts of misconduct and negligence raise serious questions that should be investigated and
answered by Sacramento County Superior Court Appellate Department Clerk KEVIN
MICHAUD. This is not a trivial matter. This is an obstruction of justice and unlawful
interference with the reviewing court’s proceedings.
Who FORCED OR COERCED the preparer of the CLERK TRANSCRIPT ON
APPEAL to deliberately and with malice and premeditation mislabel the CT with the wrong
judge’s name?
More precisely, who forced the CT preparer to replace JUDGE CHRISTOPHER
KRUEGER’S name with JUDGE DAVID BROWN from Department 53, and why? Judge
David Brown resigned in December 2020 two month after Commission on Judicial
Performance launched investigation against 3DCA Presiding Justice Vance Raye. Judge
Brown had nothing to do with The Regents Motion for Summary Judgment filed on May
14, 2021, which was decided by JUDGE CHRISTOPHER KRUEGER on September 1,
2021 who to make decision used the defective Second Amended Complaint which was filed
on September 30,2014 in conspiracy with The Regents Attorney from Porter Scott and Judge
David I Brown to steal from me $ 20,000 and set me up for anti-SLAPP motion
Who forced KEVIN MICHAUD to certify the deliberately mislabeled and incomplete
CLERK TRANSCRIPT on appeal?
Who ordered KEVIN MICHAUD to withhold sending the CLERK TRANSCRIPT on
appeal to 3DCA for the next 68 days after its certification on April 22, 2022? The undated
and unsigned DECLARATION OF MAILING, which should have been signed by Michaud,
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indicates that he perhaps did not want to deal with the orchestrated fraud, deception, and
unlawful interference with the reviewing court’s proceedings, and it needs to be investigated
who is behind this crime to derail the appeal process.
The superior court clerk must "promptly mail" to the Court of Appeal notification of
the filing of a notice of appeal. (Cal. Rules of Court, rule 8.304(c)(1).) "The failure of
a court reporter or clerk to perform any duty imposed by statute or these rules that
delays the filing of the appellate record is an unlawful interference with the
reviewing court's proceedings. . . ." ( Id., rule 8.23.) People v. Grimes, 172
Cal.App.4th 121 (Cal. Ct. App. 2009)
Each item in the rules has the force of law (Carlson v. Department of Fish &
Game (1998) 68 Cal.App.4th 1268, 1272).
THE CLERK’S SUPPLEMENTAL TRANSCRIPT ON APPEAL APPLICATION

FOR EXTENSION OF TIME TO FILE BRIEF.
Due to an incomplete and deceptive record on appeal, on July 5, 2022, I submitted to

3DCA an APPLICATION FOR EXTENSION OF TIME TO FILE BRIEF. The Regents new
attorney from Horvitz & Levy LLP, Karen Bray, added her stipulation to the application with
condition, stating:
We will stipulate to a 60-day extension of time for your opening brief, so

long as any such stipulation also includes a reciprocal 60-day extension
for our respondent’s brief
The application for extension of time was granted that same day, July 5, 2022, by the Court
with Appellant’s Opening brief due October 10, 2022.
PLAINTIFF AND APPELLANT JAROSLAW WASZCZUK’S NOTICE OF

OMISSION RE: DESIGNATED RECORD ON APPEAL.
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On July 5, 2022, I also submitted to the Sacramento County Superior Court Appellate
Department a Notice or request to produce the omitted items in the Clerk’s Transcript on
Appeal and to prepare the CRT from the September 1, 2021 hearing with Judge Christopher
Krueger
VOLUME NO. 1 OF 13 OF THE CLERK TRANSCRIPT ON APPEAL AND THE NO.

1 OF 1 AS THE CLERK’S SUPPLEMENTAL TRANSCRIPT ON APPEAL
In the response to my July 5, 2022 Notice of Omission, on July 13, 2022, I received
only one volume of the CLERK’S SUPPLEMENTAL TRANSCRIPT ON APPEAL
https://www.scribd.com/document/597295235/3DCA-Clerk-s-Suplemental-Transcript-
on-Appeal-Waszczuk-v-UC-Regents-Et-Al-Case-No-C095488)
Also package included 13 pages of the new cover page with Judge CHRISTOPHER
KRUEGER’S name replacing the wrongfully labeled front page of the 13-volume Clerk’s
Transcript on Appeal, which had listed Judge DAVID BROWN’S name. I had received that
on June 28, 2022. There was no record or note from the 3DCA Clerk that the first page in the
13-volume Clerk’s Transcript on Appeal was replaced with the correct first page showing
Judge KRUEGER’S name and the The Regents attorney name, Lindsey Goulding.
The CLERK’S SUPPLEMENTAL TRANSCRIPT ON APPEAL contains the most
important Court-filed document for this Appeal, which shall be submitted to 3DCA as a
CLERK’S TRANSCRIPT ON APPEAL Volume No. 1 of 1 and which contains:
1) My (Plaintiff and Appellant’s) ORIGINAL WRONGFUL TERMINATION

COMPLAINT filed in Sacramento County Superior Court on December 4, 2014.
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2) The Defective FIRST AMENDED COMPLAINT (FAC) filed by my former
attorney, Douglas Stein with conspiracy on June 16,2014 which decimated my
original December 4, 2014 wrongful termination complaint (See Attachment 6,
Appellant’s Opening Brief (AOB) pp. 18–26). Stein was disbarred for misconduct in
January 2020 (see https://apps.calbar.ca.gov/attorney/Licensee/Detail/131248; In re
Stein, No. S245982, (Cal. Mar. 1, 2018)).
3) NOTICE OF FILING PARTY: On September 10, 2014, Court Clerk Erica

Medina rejected Stein’s defective FAC submitted without Leave of Court as an SAC
in conspiracy with Defendants’ attorney Michael Pott from Porter Scott.
4) EX PARTE APPLICATION FOR LEAVE TO FILE FAC as SECOND AMENDED

COMPLAINT (SAC) BY STIPULATION & ORDER THERON. This application was
approved by Judge DAVID BROWN, from Department 53, on September 22, 2014. Stein
and Brown were friends for 20 years.
I challenged the defective SAC filed on September 30, 2014 as invalid, as it was the same
as the First Amended Complaint (FAC), which was filed on June 16, 2014. Please see the
attached filed in the October 25, 2017 APPELLANT’S PETITION FOR REHEARING
FOR ERROR IN LAW OR PROCEDURAL PROCESS (Pages 29–34) in the 3DCA Case
Waszczuk v . the Regents of the University of California Case No. C079524 (an Anti-
SLAPP Motion, Attachment #55). The Petition for Rehearing was denied by 3DCA Chief
Justice VANCE RAYE on November 9, 2017.
The above four items were listed in the January 31, 2022 Appellant’s Notice Designating
Record on Appeal as item No. 8-1 and should be prepared by the Court Clerk and included
in the Original Clerk Transcript on Appeal as VOLUME NO. 1, not as the CLERK’s
SUPPLEMENTAL TRANSCRIPT (SuppCT) ON APPEAL.
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THE CERTIFICATION AND DECLARATION OF MAILING OF CLERK’s
SUPPLEMENTAL TRANSCRIPT (CST) ON APPEAL SIGNED BY KEVIN
MICHAUD.
Upon closer examination of the Supp.CT Vol. No. 1 of 1 which I received on July 13,
2022, I noticed that the CST was certified on July 6, 2022 by Sacramento County Superior
Court Appellate Department Court Clerk KEVIN MICHAUD, the day after I submitted my
Court Department the Notice of Omission
The Declaration of Mailing signed by MICHAUD was originally dated July 7, 2022, but this
was altered in pen and changed to July 11, 2022. The Supp.CT was filed by the 3DCA Clerk
on July 22, 2022, 16 days after the CST was certified, on July 6, 2022. The Sacramento
County Superior Court Building is located 1 mile from the 3DCA Court building. The
process on appeal was, again, deliberately delayed for at least another 14 days by the Court
staff.
The certification and Declaration of Mailing basically shows that Clerk MICHAUD
had the SuppCT prepared a long time before he received my Notice of Omission and
deliberately, and with malice to prejudice and deceive the Appellant and court, did not add
these four items to the original Clerk Transcript on Appeal as the Volume 1 of 1 of the
Clerk’s Transcript on Appeal.
X.
CLERK KEVIN MICHAUD’S DECLARATION DATED JULY 11, 2022, RE:
RECORD ON APPEAL
With the CST, I also received on July 13, 2022 Clerk MICHAUD’S Declaration dated July
11, 2022 which stated
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TO: CLERK OF THE COURT, THIRD DISTRICT COURT OF APPEAL
I, Kevin Deputy Clerk, Superior Court of California, County of
Sacramento, do declare as follows:
On July 6, 2022 Appellant filed a Notice of Omission correspondence
with the Sacramento Superior Court Appeals Unit. As to all items listed
as part of Sacramento Superior Court Case #34-2013-80001699(items
126-147), This Superior Court Case is NOT consolidated with the
current above listed case on appeal. As such, those items will not be
given. The remaining missing documents as part of the current above
listed case on appeal have been supplied in the accompanying
Supplemental Clerks Transcript on Appeal As to the Reporters
Transcript, The CSR T. Tavalero was noticed to prepare a Reporters
Transcript based on the information supplied by the appellant on their
designation. A filing party is responsible for verifying the validity of the
information on said designation prior to submission. Ms. Tavalero
supplied a declaration as having no notes for said date supplied by
appellant. Any inadequacies in the Reporters date were not properly.
As to the minor type-o's on the cover pages of the Original Clerks
Transcript; Cover pages have been supplied to swap out for all 13
volumes. Nothing was omitted.
I declare under penalty of perjury, under the laws of the State of
California, that the foregoing is true and correct.
DATED : July 11, 2022
The Declarant, Sacramento County Superior Court Appellate Department Clerk KEVIN
MICHAUD, in damage control Declaration on his own behalf or someone else’s behalf, was
playing ignorant and trying to blame me, saying that it is was my fault that the CRT from the
September 1, 2021 Court Hearing with Judge KRUEGER was not prepared and transmitted to
the 3DCA by May 9, 2022.
I do not remember how I determined that Court Reporter Tina Tavalero transcribed the
September 1, 2021 court hearing, but her name in this matter is irrelevant. It was the Clerk’s
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responsibility to find out who the Court Reporter at the hearing was, instead of issuing the
Notice of Filling of Designation/Notice to Reporters with the wrong judge’s name and wrong
party attorney’s name and then keeping the Notice to himself to obstruct justice by
deliberately delaying the appeal and unlawfully interfering with the reviewing court’s
proceedings. Hypothetically, even it had been my fault on January 31, 2022, then the CRT
should have been sent to 3DCA together with the Supp.CT Volume 1 of 1 on Appeal on July
11, 2022. This did not happen. The CRT has still not been transmitted to 3DCA at that time .
Furthermore, the APPELLANT’S NOTICE DESIGNATED RECORD ON APPEAL in
5. b. Proceedings States:
I request that the following proceedings in the superior court be included
in the reports transcript. (You must identify each proceeding you want
included by its date, the department in which it took place, a description
of the proceedings (for example, the examination of jurors, motions
before trial, the taking of testimony, or the giving of jury instructions),
the name of the court reporter who recorded the proceedings (IF
KNOWN), and whether a certified transcript of the designated
proceeding was previously prepared.)
Hypothetically, if I had not added Tavalero’s name to the APPELLANT’S NOTICE
DESIGNATED RECORD ON APPEAL because I did not know who transcribed the hearing,
Clerk MICHAUD should have ordered Court Reporter Valerie Holy to prepare a CRT for
Appeal from the September 1, 2021 Court hearing with Judge KRUEGER, or it would be the
same story as it is now.
THE STOLEN UNEMPLOYMENT INSURANCE BENEFITS -SACRAMENTO

COUNTY SUPERIOR COURT CASE #34-2013-80001699 (ITEMS 126–147)
APPELLANT’S NOTICE DESIGNATED RECORD ON APPEAL
In the first part of the Declaration, Deputy Clerk MICHAUD addressed my request to
produce the omitted records on appeal from the case cross-referenced to this appeal,
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Jaroslaw Waszczuk v. California Unemployment Insurance Appeal Board and the Regents of
the University of California as the Real Party in Interest (RPii), Case No. 34-2013-80001699-
CUWMGDS, 3DCA Case No. 079254, the Supreme Court of California Case No. S253713
& S245879, filed on December 2, 2013, ATTACHMENT NO. 4B TO THE APPELLANT’S
NOTICE DESIGNATING RECORD APPEAL (Pages 9 & 11), filed on January 31, 2022
It shows how the court record from the Sacramento Superior Court Case #34-2013-
80001699 irritates perpetrators who participated and still participate in the cover up of the
unemployment insurance benefits theft which took place in 2014 and theft was subject of
litigations in three California ‘s different court .
case is cross-referenced to this ongoing appeal and is about my unemployment
insurance benefits, which were stolen in 2014 see also -Appellant’s Opening Brief pages 15–
18.
THE CLERK’S SUPPLEMENTAL TRANSCRIPT ON APPEAL AND THE
CLERK’S TRANSCRIPT COVER PAGES WITH THE WRONG JUDGE’S
NAME AND WRONG RESPONDENT ATTORNEY
The Sacramento Superior Court Deputy Clerk from the Appeal Unit, at the end of
his July 11, 2022 Declaration, stated:
As to the minor type-o 's on the cover pages of the Original Clerks
Transcript; Cover pages have been supplied to swap out for all 13
volumes. Nothing was omitted.
These were not “minor type-o’s on the cover pages.” This was a serious and
deliberate move to mislabel 13 volumes of the Clerk’s Transcript on Appeal with
DAVID I. BROWN’S name, instead of JUDGE CHRISTOPHER KRUEGER’S
name, and listing the wrong respondent attorney, DOUGLAS ROPEL, who has been
employed for the last six years by Littler Mendelson PC, instead of Porter Scott’s
attorney, Lindsay A. Goulding.
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These “ were not “minor type-o’s on the cover pages.”. This was an deliberate
attempt to remove JUDGE CHRISTOPHER KRUEGER’S from the appeal
proceeding and blame entirely for the committed crimes the JUDGE DAVID I
BROWN who quit or was forced to quit his job in Sacramento Superior Court in
December 2020
https://cjp.ca.gov/wp-content/uploads/sites/40/2022/06/Raye_DO_Pub_Admon_6-1-
22.pdf ) and the former Porter Scott’s attorney DOUGLAS ROPEL who quit Porter
Scott in March 2016 and since then is working for Littler Mendelson .
In October 2018, The Regents attorneys from Porter Scott bypassed Judge David I
Brown and engaged two Sacramento County judges, CHRISTOPHER E. KRUEGER
AND JENNIFER K. ROCKWELL, to end my litigation via termination sanctions, an
attempt to frame me for a bench warrant and criminal prosecution, and to break into my
wife’s bank and 401(k) accounts. Judge Krueger and Judge Jennifer Rockwell, before
they were appointed to the bench they worked for California Attorney General Bill
Lockyer in the same office on State v. All Persons, 152 Cal.App.4th 1386 (Cal. Ct.App.
2007). Judge Krueger’s wife is employed in 3DCA as a senior research attorney (12CT
3361-3362).
This did not work with me in 2018–2019, so the attorneys attacked and terrorized my wife
in April–July 2021, attempting to frame her for criminal prosecution with the help of Judge
Thadd Blizzard, from Department 43, and his clerk. The ambush failed, yet they stole from
my wife more, $22,284 besides the terror she experienced in the courtroom.
Regardless, the 13 volumes of the CLERK’S TRANSCRIPT ON APPEAL were

certified on April 22, 2022 and vanished. They were not delivered to me, in Lodi, CA,
or to 3DCA for another two and half months. The question still remains, why did
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MICHAUD include the December 4, 2013 COMPLAINT; the June 16, 2014 FIRST
AMENDED COMPLAINT; the September 10, 2014 NOTICE OF FILING PARTY;
and the September 24, 2014 EX PARTE APPLICATION FOR LEAVE TO FILE
SECOND AMENDED COMPLAINT BY STIPULATION & ORDER THERON in the
CLERK’S TRANSCRIPT ON APPEAL certified on April 22, 2022, but then provided
it three months later as a CST ON APPEAL? Most likely, MICHAUD was advised that
I would not notice his malice, deception, and manipulation of the Record on Appeal.
The case also shows that 3DCA staff are going along with MICHAUD’s obstruction of
justice and his unlawful interference with the reviewing court's proceedings.
JULY 20, 2022 PLAINTIFF AND APPELLANT JAROSLAW WASZCZUK’S

SECOND NOTICE OF OMISSION RE: DESIGNATED RECORD ON APPEAL-
CAL. RULES OF COURT- RULE 8.155 (B)(1)
On July 20, 2022, I submitted to the Sacramento County Superior Court a Second Notice
of Omission: Re: Designated Record on Appeal which was filed on July 26, 2022 (ROA
# 313).
In my Second Notice of Omission, I requested, among other things, that:
1) The Sacramento County Superior Court Appeal Unit, without further delay, issue a
new Notice of Filing of Designation/Notice to Reporters for Court Reporter Valerie Haley,
who had already transcribed the September 1, 2021 Court Hearing presided over by Judge
Christopher E. Krueger (not Judge David I. Brown) and the Defendants’ attorney from the
Porter Scott law firm, Thomas L. Riordan (not Douglas Ropel or Lindsay Goulding). The
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new Notice of Filling of Designation/Notice to Reporters should resolve the problem with
the Court Reporter.
2) I pointed out that Volume 8 of 13 is completely missing, or has been omitted, in the
Chronological and Alphabetical Index for the 13-volume Clerk Transcript on Appeal and
must be corrected In response to my Second Notice of Omission, the Sacramento County
Superior Court Appellate Department Clerk KEVIN MICHAUD, in a created by him and
others CIRCUS OF DECEPTION AND DELAY, submitted to 3DCA another meaningless
declaration that stated:
TO: CLERK OF THE COURT, THIRD DISTRICT COURT OF APPEAL

I, Kevin Deputy Clerk, Superior Court of California, County of
Sacramento, do declare as follows:
On July 21, 2022 Appellant submitted a second notice of omission in
regards to the Court Reporter Transcript. As the previous declaration
stated, the CSR was noticed based on the information submitted by the
Appellant on page 4 of the filer's designation (copy included for
reference). Said CSR prepare a declaration of having no notes. It is the
responsibility of any filing party to verify the proper information is
listed on their filing document prior to filing. The Appeals Unit of the
Sacramento Superior Court does not correct any filing document..
Nothing was omitted.
I declare under penalty of perjury, under the laws of the State of
California, that the foregoing is true and correct.
DATED :July 26,2022 Kevin M
Following MICHAUD’s Declaration, 3DCA tried to run me in circles. The 3DCA responded
to my Second Notice of Omission with the Court Order dated August 11, 2022 and stamped
by 3DCA Acting Administrative Presiding Justice, Hon. RONALD B. ROBIE, stating.
BY THE COURT:
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Appellant's Second Notice of Omission in the Record on Appeal" is
treated as a motion to correct the record, and in light of the subsequent
filing of the supplemental record on appeal, the motion is denied. If there
are further corrections sought, appellant may file a motion in this court
addressing the specific corrections he seeks to have this court direct the
trial court to correct.
ROBIE, Acting P.J.
MOTION TO AUGMENT RECORD

On September 23, 2022, I filed a Motion to Augment Record on Appeal, which was
basically a redundant repetition of my two Notices of Omission, which were submitted to
Sacramento County Superior Court with not known results I am well aware that I am
being played by the staff from two Courts. This game has been going on for almost nine
years, but I am doing my best to beat the odds as a self-represented litigant for whom
English is a second language.
On September 28, 2022, the 3DCA Clerk filed my Motion to Augment Record on
Appeal after five days’ delay.
COURT REPORTER TRANSCRIPT ON APPEAL (CRT)
On September 27, 2022, four days after I submitted to 3DCA my motion to augment
record on appeal, I received from Court Reporter Valerie Haley an electronic version of the
COURT REPORTER TRANSCRIPT (CRT) from the September 1, 2021 Court Hearing with
Judge CHRISTOPHER KRUEGER from Department 53 .The CRT was provided to me via
YesLaw, which shows that the CRT from the September 1, 2021 Court hearing was uploaded
to YesLaw by Haley on March 21, 2022, but never provided to me or transmitted to 3DCA
by Clerk MICHAUD.
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I was expecting that the CRT, which was sent to me on September 27, 2022 would be
certified and transmitted to 3DCA and that I could use it for my APPELLANT OPENING
BRIEF (AOB), which was due to be filed on October 10, 2022.
For the above reason, on October 3, 2022, I submitted to 3DCA an Application for 30
days’ extension to file my AOB with a new due date of November 10, 2022 (
THE APPELLANT OPENING BRIEF (AOB) DUE OCTOBER 10, 2022
While waiting for 3DCA to grant or deny my extra 30 days’ extension of time, a request I
submitted on October 3, 2022, a request to 3DCA to rule on my motion to augment the
record on appeal submitted on September 23, 2022. I was working on my AOB due October
10, 2022. I was expecting nothing good or any good news from 3DCA staff, which as the
nine years’ record shows in two cases, has discriminated against me, blocked me from
gaining equal access to justice, and shown prejudice against me. This appeal was no
exception, and the Case No. C095488 docket alone shows in black and white how closely
3DCA staff collaborates against me with the staff in the Sacramento County Superior Court
Appellate Department and beyond.
This is a wrongful termination case and summary judgment appeal in which the
Defendants’ attorney did not provide one single piece of credible evidence to be granted a
motion for summary judgment by Judge KRUEGER, from Department 54. Judge
KRUEGER presided over this 8-year-old case for less than one month and cut me off on
the September 1, 2021 in an oral argument hearing after 5–10 minutes. He ended the
case that way because he perhaps was completely unprepared for the hearing, or perhaps
because he did not want to hear on the Zoom call about the unlawful May 31, 2012 Power
Sale Purchase Agreement between the UC Regents and Sacramento Municipal Utility District
(SMUD) from the UCDMC’s 27-MW cogeneration facility, where I was an operator working
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for UCDMC (CT Vol. 3 pp. 768-789,. Judge KRUEGER is a former Attorney General
employee, and he was fully briefed by the Porter Scott attorneys in October 2018 on what this
wrongful termination case is about and about the power sale to SMUD.
On October 10, 2022, I was struggling to finish my AOB and to send it 3DCA,
waiting until the last minute with hope that 3DCA would provide me the 30 days’ extension
of time because of the 3DCA clerk’s conflicting and unclear statement in the case docket,
which did not state whether my motion for an extension of time was filed, granted or not
granted, or rejected. I did not take any chances and submitted my AOB to 3DCA very early in
the morning on October 11, 2022, at 4:36 A.M. The AOB was written based on an incomplete
record on appeal and not knowing whether the extension of time to file the AOB had been
granted or not.
OCTOBER 7, 2022 THE REGENTS OPPOSITION TO THE SEPTEMBER 23,

2022 PLAINTIFF’S MOTION TO AUGMENT THE RECORD ON APPEAL.
On October 10, 2022, instead of receiving the extension of time to file the AOB, I
received a 3DCA e-mail notification that my AOB was due. I looked at the case docket and
noticed that, on October 7, 2022, the Defendants’ attorney filed an opposition to the my
(Plaintiff’s) September 23, 2022 motion to augment the record on appeal. The Defendants’
attorney submitted this opposition via TrueFiling on October 7, 2022 at 12:53 P.M., and the
opposition was filed on the same day by 3DCA Deputy Clerk T. Eyster . However, the
Defendants’ opposition was not served to me for five days, arriving on October 11, 2022. On
the same day, I asked the Defendants’ attorney from Horvitz-Levy, Karen Bray, via e-mail
why she had not served their opposition to my motion for five days after their opposition was
filed. On that same day, I received a response from Ms. Bray, stating:
Mr. Waszczuk,
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Attached is a copy of the opposition to motion to augment that we filed
on Friday. We attempted to serve it upon you through TrueFiling using
your registered email address, but just noticed that there was a server
error message, which we have copied below. Our understanding is that
other filings have been served upon you at this email address, so we
aren’t sure why service failed in this instance.
In her response, Ms. Bray stated that she “just noticed” there was a server error. I
responded to her that there was nothing wrong with my e-mail. I have never had a
problem submitting my documents via TrueFiling. If there was something wrong with my
e-mail, the TrueFiling Server operator would have notify me instantly that I was blocked.
By working for the UCDMC as an associate development engineer, I have backed up
servers for entire hospitals, and I do not believe that TrueFiling’s server for the entire
California Court System is less critical to protect from viruses or spam attacks than the
UCDMC hospital server, or that its and system is less sophisticated than the UCDMC
computer system was 10 years ago. Instead, I think that my documents were not being
processed by the clerks and filed for many days after being submitted via TrueFiling. I
notified the TrueFiling Service on October 11, 2022 of the problem and received a
response that there should not be any further problems. Supposedly, some spam had been
attached to my registered e-mail, which kept me from being served for five days.
However, I should also have received text messages on my phone, 209-687-1180, as
usual, which documents that something was filed, but no such messages were sent.
Furthermore, I noticed in the case’s Register of Action (ROA) on October 11, 2022,
the Defendants filed a Supplemental Proof of Service five days after the opposition was filed.
I never received from the Defendants’ attorney a copy of this supplemental proof of service. I
am not going to speculate what the Defendants’ attorneys from Porter Scott and Horvitz &
Levy were up to together with the 3DCA Clerks that kept them from providing me
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information (proof of service) that the opposition to my motion had been filed and granting
me an extension of time before my AOB was due on October 10, 2022.
OCTOBER 13, 2022 PLAINTIFF’S REPLY TO THE DEFENDANTS’

OPPOSITION TO PLAINTIFF’S MOTION FOR THE RECORD ON APPEAL
AUGMENTATION AND CORRECTION.
Being, again, manipulated and prejudiced against by the Defendants’ attorneys from
Porter Scott and Horvitz & Levy and the 3DCA Clerks, on October 13, 2022, I submitted to
3DCA via TrueFiling the Reply to the Defendants’ Opposition to Plaintiff’s Motion for the
Record on Appeal Augmentation and Correction
The reply was more of a complaint than a reply to opposition due to being subject to gross
prejudice by the Sacramento County Superior Court Appellate Department, which
deliberately delayed the processing of my appeal in a blunt approval of wrongdoing by the
3DCA staff.
On the same day, October 13, 2022, I submitted my reply to the Defendants’ opposition to
my motion, the 3DCA granted me an extension of time to file my AOB, which I had already
submitted to 3DCA on October 11, 2022 via TrueFiling. What nonsense. The extension was
granted without granting or denying my motion to augment and correct record on appeal
(another bit of nonsense).
I examined the granted Application for Extension of Time and found that the order was
stamped with 3DCA’s acting judge ROBIE’S name, but the order was not dated. It is
unknown whether the extension was granted before October 10, 2022 or three days after I
submitted my AOB
THE APPELLANT’S OPENING BRIEF

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I submitted my AOB to 3DCA via TrueFiling on October 11, 2022. After that, I sent a
letter, on October 14, 2022, to Justice ROBIE asking him to order the 3DCA Clerk to file my
AOB without any further delay. The AOB was filed on the same day, October 14, 2022
Four days later, on October 18, 2022, I received a 3DCA Court Order stamped by
Judge Robie stating:
BY THE COURT:
On the court's own motion, the October 14, 2022, filing of appellant's
opening brief on demand is ordered stricken. The clerk of this court is
directed to return the opening brief to the appellant with a letter
explaining how the brief fails to meet the requirements of the California
Rules of Court.
On the court's own motion, the October 14, 2022, filing of appellant's
reply to the respondents' opposition on demand is ordered stricken.
The California Rules of Court do not contemplate the filing of a reply to
an opposition to a motion.
The next day, on the early morning of October 19, 2022, I submitted a corrected AOB via
TrueFiling with a cover letter addressed to 3DCA Clerk/Executive Officer Andrea K.
Wallin-Rohmann, in which I stated :
Dear Ms. Wallin-Rohmann:

Per the October 18, 2022 Court Order and Court Supervising Deputy
Clerk Todd Eyster’s explanatory memo, I am resubmitting with this
letter the corrected Appellant Opening Brief (AOB), which was stricken
by the Court due to non-compliance with the following California Rules
of Court:
Rule 8.74(a) (2): I repaginated all pages of the AOB with Arabic
numerals.
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Rule 8.74(a) (8): I removed the green cover page from the AOB.
Rule 8.204(c) (1): I corrected the AOB certificate of word count which
included a typographical mistake.
Due to the required corrections, especially repagination of the all pages
with Arabic numerals, I also changed the pages numbers accordingly in
the AOB’s Table of Contents and Table of Authorities.
I appreciate the Court Order and Clerk’s clear explanation of what
needed to be corrected in the AOB to make the document compliant with
the California Rules of Court. I apologize to the Court for my mistakes.
Also, I (Plaintiff) would greatly appreciate it if the Court Clerk would
file the AOB without delay. The AOB is bookmarked by Acrobat DC
Pro and all matters in the AOB are supported by the citation of the
volume and page number of the record (Clerk Transcript) where the
matter appears (California Rules of Court, rule 8.204(a)((1)(c)).
Please let me know if the Court has any further concerns. Thank you.
Sincerely,
______________
Jaroslaw Waszczuk, Pro Se
Plaintiff & Appellant
After I submitted the corrected AOB and cover letter via TrueFiling, I expected that the Brief
would be filed without any delay. It did not happen.
On the morning October 24, 2022, I was notified by the 3DCA Clerk via e-mail and an
ROA entry that my corrected AOB submitted on October 19, 2022 had been filed. The 3DCA
Clerk in the ROA entry noticed my letter, which explained what I corrected in my brief:
“Clerk 10/24/2022 Appellant, submitted with his opening brief, that confirms he made the
corrections to his brief directed by the court.”
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I also noticed that 3DCA, by filing my AOB Brief, did not make an entry in the case ROA
showing when the Respondent Brief is due now after my AOB was filed.
THE 3DCA ORDER DATED NOVEMBER 14, 2022 -RE: AUGUMENTED RECORD
ON APPEAL
BY THE COURT:
Appellant's motion to augment the record on appeal is granted in part
and denied in part. Appellant’s motion is granted as to the September 1,
2021, Reporter’s Transcript. The clerk of this court is directed to file the
Reporter’s Transcript attached to this order.
Appellant’s motion to augment the record on appeal is denied as to item
102, the motion to recall the remittitur in case number C079524, and
items 126 through 147. There is no indication that the requested material
was filed or lodged in the superior court in this case. (Cal. Rules of
Court, rule 8.155.)
Appellant’s request to relabel the transcript is denied as unnecessary.
ROBIE, Acting P.J
The order in part was incorrect. The copy of motion to recall the remittitur in case
C079524 was submitted on June 18, 2021 to the Clerk of the Sacramento County
Superior Court Dept 53 . (Hon. Sharma H. Mesiwala ) .
Clerk of the Sacramento County Superior Court Department 53 - Hon.

Shama Hakim Mesiwala
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June 18, 2021
Subject: Case no. 34-2013-00155479, Jaroslaw Waszczuk v. The Regents
of the University of California
Re: Copy of Motion to Recall the Remittitur and copy of the Motion)
for Judicial Notice in the Waszczuk i.'. Regents of University of
California, C079524 (Cal. Ct. App. Oct. 10, 2017)
Dear Clerk:
I am a Plaintiff in the above-captioned cases. With this letter, I am
submitting to your office copies, via U.S. Priority Mail, of the Motion to
Recall the Remittitur and the Motion for Judicial Notice, along with copies
of a Declaration in Support of the Case Waszczuk v. Regents of University
of California, C079524 (Cal. Ct. App. Oct. 10, 2017).
Because the copies of the Motion to Recall the Remittitur and Motion for
Judicial Notice include the same 46 exhibits, with exception of Exhibit
47, which has been added to the Motion for Judicial Notice, please
provide to the Hon. Shama Hakim Mesiwala a copy of the Motion for
Recall the Remittitur with 46 attached exhibits and a copy of the Motion
for Judicial Notice with only Exhibit 47.
Both motions submitted to the Court of Appeal Third Appellate District are
vitally related to the Motion for Summary Judgment and or, in the
Alternative, Summary Adjudication related to the Defendants, the Regents
of the University of California, filed on May 14, 2021. The Defendants'
vexatious and notorious re-litigation over the past two years focused on the
four dismissed Causes of Action from my Second Amended Complaint by
their anti- SLAPP in 2015 triggered my Motion to Recall the Remittitur and
Motion for Judicial Notice in Appellate Court. The Defendants' Motion for
Summary Judgment and or, in the Alternative, Summary Adjudication filed
on May 14, 2021 (ROA # 254-258) is no exception and is yet another
attempt by the Defendants' attorneys from Porter Scott to extort money
from me and my wife by relitigating the matters that were dismissed by
three Courts, including the California Supreme Court.
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In addition to the above, please file for the record a copy of my Motion to
Recall Remittitur and a copy of the Motion for Judicial Notice without
exhibits (enclosed), along with this letter and attached to Meet and Confer
letter to Defense Attorney Lindsay A. Goulding
Sincerely,
Jaroslaw Waszczuk - Plaintiff in Pro Per
Enclosure:
Meet and Confer Letter to Defendants Attorney Lindsay A. Goulding with
attachment.
This very questionable 3DCA Order is merely a redacted excerpt from Horvitz & Levy LLP
attorney Karen M. Bray’s Opposition to Appellant’s Motion to Augment and Correct the Record
on Appeal.
Since March 23, 2022, Ms. Bray, together with H. Thomas Watson, has been assisting
Porter Scott attorneys LINDSEY A. GOULDING and THOMAS RIORDAN in representing
the UC Regents in this appeal. In 2021, in an ill-advised and heinous but unsuccessful act,
Goulding, acting in coordination with the judges and clerks from Sacramento County Superior
Court Departments 53, 54, and 43, ambushed my 70-year-old wife in an attempt to frame her for
a bench warrant and criminal prosecution and to steal her life savings bank and 401(K)
retirement accounts. Goulding stole from her $22,284 before Judge Thadd Blizzard and the court
clerk from Department 43.
CONCLUSION
It is all leading to the conclusion that The Regents attorneys from Porter Scott and from
Horvitz and Levy LLP in 2022 knew the result of the appeal in Case C095488 and they
made sure that the 12/04/13 COMPLAINT, 06/16/14 FIRST AMENDED COMPLAINT,
09/10/14 NOTICE TO FILING PARTY, 09/24/14 EX PARTE APPLICATION FOR
- 30 -
LEAVE TO FILE and the SECOND AMENDED COMPLAINT BY STIPULATION AND
ORDER THEREON never would be sent to the Supreme Court of California by 3DCA Clerk
Office . THE END JUSTIFIES THE MEANS
If you have any question or you would have a problem to understand some of my statements
than please do not hesitate to ask me for clarification. In my writing I rely entirely on the
proof readers
Dated August 29, 2023
Sincerely ,
____________________________________
Jaroslaw Waszczuk. In Pro Per
CC: See Mailing List
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MAILING LIST
Re: Waszczuk v. Regents of the University of California
C095488
Copies of this document have been sent by mail to the parties checked below unless they
were noticed electronically.
Lindsay Alida Goulding Porter Scott- TrueFiling
H. Thomas Watson -TrueFiling

Karen M. Bray-TrueFiling
Horvitz & Levy LLP
Burbank, CA 91505
Jorge E. Navarrete – US Mail

350 McAllister St.
Hon. Michael G. Bowman ,Presiding Judge

SUPERIOR COURT OF CALIFORNIA
County of Sacramento
720 9th Street
Michele Kem -US Mail

Secretary to Trial Counsel
State of California
Commission on Judicial Performance
455 Golden Gate Avenue, Suite 14400
- 32 -
STATE OF CALIFORNIA
BEFORE THE COMMISSION ON JUDICIAL PERFORMANCE
IN THE MATTER CONCERNING DECISION AND ORDER IMPOSING
JUSTICE VANCE W. RAYE PUBLIC ADMONISHMENT PURSUANT
TO STIPULATION
(Commission Rule 116.5)
This disciplinary matter concerns Justice Vance W. Raye of the California
Court of Appeal, Third District. On May 27, 2022, Justice Raye and his counsel,
Edith R. Matthai, Esq., entered into a stipulation with Director-Chief Counsel
Gregory Dresser, pursuant to commission rule 116.5, to resolve the pending
preliminary investigation involving Justice Raye by the imposition of a public
admonishment and the justice’s agreement to retire and not to serve in a judicial
capacity in the future. Justice Raye tendered his retirement from judicial office,
effective June 1, 2022. The commission approved the Stipulation for Discipline
by Consent on May 30, 2022, pursuant to the following terms and conditions and
stipulated facts and legal conclusions. A copy of the stipulation is attached.
TERMS AND CONDITIONS OF AGREEMENT
1. This agreement resolves the matters alleged in the commission’s
pending preliminary investigation involving Justice Vance W. Raye.
2. The commission shall issue a public admonishment based on the
agreed Stipulated Facts and Legal Conclusions set forth therein.
3. If the commission accepts this proposed disposition, the commission’s
decision and order imposing a public admonishment may articulate the reasons
for its decision and include explanatory language that the commission deems
appropriate.
4. Upon acceptance by the commission, this stipulation and the
commission’s decision and order shall be made public.
5. Justice Vance W. Raye waives any further proceedings and review in
this matter, including formal proceedings (Rules of Com. on Jud. Performance,
rule 118 et seq.) and review by the Supreme Court (Cal. Rules of Court, rule 9.60).
-1-
6. Justice Vance W. Raye shall advise the Governor of California, in
writing, of his retirement from judicial office, effective June 1, 2022.
7. If Justice Vance W. Raye does not retire as of June 1, 2022, the
commission may withdraw the public admonishment and resume the preliminary
investigation as to all of the matters in the staff inquiry and preliminary
investigation letters. Failure to comply with the terms and conditions of this
agreement may also constitute additional and independent grounds for discipline.
8. Justice Vance W. Raye has agreed not to seek or hold judicial office, or
accept a position or assignment as a judicial officer, subordinate judicial officer, or
judge pro tem with any court in the State of California, or accept a reference of
work from any California state court, at any time after June 1, 2022, except that, in
the interest of justice, to conclude matters, which have been previously assigned
to him and cannot be completed by June 1, and which would place an undue
burden on the other justices if they were reassigned. Justice Raye may also
respond to any request from the Third District for information regarding a case that
was assigned to Justice Raye before the date of his retirement.
9. If Justice Vance W. Raye attempts to serve in a judicial capacity in
violation of the foregoing paragraph, the commission may withdraw the public
admonishment and resume the preliminary investigation as to all of the matters in
the staff inquiry and preliminary investigation letters.
10. Justice Vance W. Raye agrees that the facts recited herein are true
and correct, and that the discipline to which the parties stipulate herein is
appropriate in light of those facts.
11. The commission may reject this proposed disposition and resume its
preliminary investigation. If the commission does so, nothing in this proposed
disposition will be deemed to be admitted or conceded by either party.
Accordingly, it is hereby stipulated and agreed that the commission shall
issue a public admonishment on the above Terms and Conditions of Agreement
and based on the following Stipulated Facts and Legal Conclusions.
-2-
STIPULATED FACTS AND LEGAL CONCLUSIONS
This disciplinary matter concerns Justice Vance W. Raye, the
Administrative Presiding Justice of the Third District Court of Appeal since 2010.
His current term began in 2015. Justice Raye was appointed to Sacramento
Superior Court in 1989 and as an Associate Justice on the Third District Court of
Appeal in 1991.
Justice Raye engaged in a pattern of delay in deciding around 200
appellate matters over a ten-year period.
I. PATTERN OF PERSISTENT DECISIONAL DELAY
“The failure to resolve appellate cases in an appropriately expeditious
timeframe undermines the ability of the appellate courts to efficiently manage
their publicly provided resources, demonstrate effective leadership within the
Judicial Branch and promote public confidence in the courts.” (Doerner, Model
Time Standards for State Appellate Courts (2014) p. 18.)
Under California law, judges are expected to decide matters submitted to
them within 90 days of submission and are prohibited from receiving their salaries
when they have undecided matters under submission for more than 90 days.
(Cal. Const., art. VI, § 19; Mardikian v. Commission on Judicial Performance
(1985) 40 Cal.3d 473, 477, fn. 4.) Other than the 90-day rule, there is no law or
rule that sets a specific limit on the time an appellate court takes to decide a
matter1 and, in particular, nothing that directly addresses pre-submission delay.
1
“[F]ederal courts have held that undue delay in processing an appeal
may rise to the level of a violation of due process.” (Daniel v. State (Wy. 2003) 78
P.3d 205, 218 [citations omitted].) The Tenth Circuit has enunciated a general
rule that delay in adjudicating a noncapital criminal appeal for more than two
years after filing of the notice of appeal, including more than 11 months from the
completion of briefing to the opinion’s filing, raises a rebuttable presumption of
prejudice from an ineffective appellate process. (Harris v. Champion (10th Cir.
1994) 15 F.3d 1538, 1555-1561 & fn. 11; accord, e.g., U.S. ex rel. Green v.
Washington (N.D. Ill. 1996) 917 F.Supp. 1238, 1277.) The National Center for
State Courts, along with the Court Management Committee of the Conference of
Chief Justices and the Conference of State Court Administrators determined that,
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More generally, however, the Code of Judicial Ethics requires judges to dispose
of all judicial matters fairly, promptly, and efficiently (canon 3B(8)) and to act at all
times in a manner that promotes public confidence in the integrity and impartiality
of the judiciary (canon 2A).
Appellate court cases are not “submitted” until after oral argument is heard,
or argument is waived. At the Third District, a case is not set for oral argument
until there is a full draft memorandum that at least two justices agree on. Justice
Raye did not violate the 90-day rule on any matter assigned to him. Rather, the
pre-submission decisional delay in this matter implicates the general standards of
canons 3B(8) and 2A. Justice Raye engaged in a pattern of delay in deciding a
significant number of appellate cases over a lengthy period. In particular, both with
respect to the court as a whole (in his role as presiding justice) and as to cases
assigned to him personally, he failed to encourage and adopt reasonable
procedures to ensure that priority and older cases were decided first.
The commission surveyed approximately 200 matters (as set forth in
Exhibit 1 and incorporated herein as though set forth in full) assigned to him from
2011 to 2021, in which more than one year passed between the completion of
briefing and the issuance of an opinion (or dismissal of the matter). Not every such
case warrants discipline, and whether it does depends on a number of relevant
circumstances. During the ten-year time frame examined by the commission,
Justice Raye authored opinions in over 1,200 matters, including the cases
identified in Exhibit 1. A substantial portion of those cases were decided within
one year from the completion of briefing.
in 95% of civil cases, 570 days (one year and seven months) is considered a
reasonable number of days from initial filing to issuance of an opinion. (Doerner,
supra, at p. 22.) For criminal appeals (excluding death penalty cases), a
reasonable number of days from initial filing to opinion is 600 days
(approximately one year and eight months). (Id. at p. 20.) Given the amount of
time required from initial filing to case fully briefed, to meet the 600-day target in
criminal cases, the time from a case being fully briefed to opinion would be less
than one year.
-4-
At the same time, a significant number of cases languished for years.
Justice Raye’s oldest completed case (No. C067600) had aged seven years and
nine months after being fully briefed before the parties dismissed the matter.
Two of Justice Raye’s cases were delayed between six and seven years; five
between five and six years; 17 between four and five years; 29 between three
and four years; and 45 between two and three years. Justice Raye’s oldest
pending case (No. C070732, rating of 2) is a criminal matter with youthful
offenders in which supplemental briefing was requested by the parties and
authorized by the court in January 2022 after the case had been fully briefed for
eight years and seven months.2 Justice Raye failed to prioritize efforts so that
older cases could be resolved before work began on newer ones.
The parties acknowledge that the Third District Court of Appeal has a high
volume of cases. If the reason for the delay were attributed solely to an
overburdened court, one would expect that all or virtually all of the justices of the
Court would be similarly affected, which is not the case at the Third District.
In approximately 14 to 35 percent of the cases assigned to Justice Raye
from 2001 through 2019, more than a year passed between the date the cases
were fully briefed and the date the opinions issued. In contrast to these high
levels of delay, only 7 percent of cases assigned in 2020—after an inquiry from
the commission—were unresolved more than a year after the completion of
briefing. This suggests that Justice Raye could have decided the matters in a
more timely manner. (See Mardikian, supra, at p. 482 [discipline appropriate
where delays are persistent and avoidable].) The evidence does not show that
the delay was caused by an intentional disregard of the justice’s duties. (See In
re Jensen (1978) 24 Cal.3d 72, 73 [discipline appropriate where there is a
2
The court’s managing attorney screens all appeals and numerically
ranks each chambers case according to complexity, from 1 to 5, with higher
numbers assigned to more complex cases. Most routine disposition appeals
(RDAs) and juvenile dependency cases are initially prepared by a pool of central
staff attorneys.
-5-
persistent failure to perform judicial duties, even if the failure is not an intentional
disregard of duties].)
During the relevant time period, Justice Raye was aware of his growing
backlog of cases. He received monthly reports that identified his assigned cases
and the date of each assignment. The justices in the Third District discussed the
topic of delay and the court’s “growing backlog of appeals” at several justices’
meetings and three court retreats from 2012 through 2018.
Justice Raye also did not give calendar preference to three juvenile
delinquency cases: People v. B.G. (No. C081515), People v. Q.N. (No. C064967),
and People v. C.C. (No. C087924), as provided by Welfare and Institutions Code
sections 395 and 800, subdivision (a).3 In addition, more than half of Justice
Raye’s delayed cases were matters in which the people of the state were parties.
He did not accord these matters calendar preference over civil appeals, and other
cases (excluding juvenile matters) that had been filed during the same period, as
provided by section 44 of the Code of Civil Procedure.4 Justice Raye’s failure to
provide calendar preference to juvenile and criminal cases violated his obligation
to respect the statutory language and to act at all times in a manner that promotes
public confidence in the integrity and impartiality of the judiciary (canon 2A) and to
dispose of all judicial matters fairly, promptly, and efficiently (canon 3B(8)).
3
Welfare & Institutions Code sections 395 and 800, subdivision (a) provide
calendar preference to juvenile dependency and juvenile delinquency cases over
all other cases. (Welf. & Inst. Code, §§ 395 and 800, subd. (a) [“The appeal shall
have precedence over all other cases in the court to which the appeal is taken”].)
(See also Abdullah B. v. Superior Court (1982) 135 Cal.App.3d 838, 844.)
4
After juvenile matters, section 44 of the Code of Civil Procedure
authorizes courts of appeal to provide calendar preference to criminal matters,
and then to probate and election cases. Section 44 states that appeals in
probate proceedings, contested election cases, and certain defamation cases
“shall be given preference in hearing” and “shall be placed on the calendar in the
order of their date of issue, next after cases in which the people of the state are
parties.”
-6-
Justice Raye’s conduct caused prejudice to civil litigants and criminal
defendants. Prejudice can occur in civil cases by parties suffering from
uncertainty as disputes remain unresolved, or the payments of money judgments
are delayed. In criminal cases, appellants are prejudiced if they have served all
or part of a reversed sentence, or when faded memories or lost evidence hamper
resentencing hearings or retrials. Prejudice can also manifest as “increased
anxiety, mistrust, hopelessness, fear, and depression” that “results from the very
thwarting of the hope that liberty will be restored through a right that the State
has guaranteed -- the appellate process.” (United States ex rel. Green v.
Washington, (N.D. Ill. 1996), 917 F.Supp. 1238 at pp. 1277-1278.) Known
prejudice occurred in the following six cases:
 People v. Flores (No. C066914, rating of RDA): This matter was
assigned to Justice Raye on February 23, 2012. On June 4, 2017, the
appellant’s counsel inquired about the status of the appeal. Attorney
Tutti Hacking stated that the appellant had received a six-year prison
term and had served the sentence while the appeal was pending. Ms.
Hacking wrote, “It has been over five years since this case was fully
briefed yet no decision has been rendered by the Court of Appeal. Mr.
Flores has had to continue his life with a felony conviction on his record,
and he has no other criminal record.” On August 21, 2017, Ms. Hacking
again inquired about the status of the case and complained that she had
received no response to her earlier inquiry.
 Environmental Council of Sacramento et al. v. County of Sacramento et
al. (No. C076888, rating of 4): This matter was assigned to Justice
Raye on February 26, 2015, and decided on January 30, 2020. On
May 19, 2017, all parties jointly requested that oral argument be
calendared, consistent with the calendar preference mandates of Public
Resources Code section 21167.1. The attorneys wrote, “Counsel
involved in this case are involved in other CEQA-related appeals
-7-
pending before the Court for which notifications regarding oral
argument have been received even though the briefing was completed
much later than the briefing in this matter. The absence of a final
decision in this matter creates substantial uncertainty for the parties at a
critical juncture for the long term development of the Cordova Hills
project that was approved in January, 2013.”
 Myers et al. v. Raley’s (No. C075125, rating of 3): This matter was
assigned to Justice Murray on October 31, 2014, reassigned to Justice
Raye on June 29, 2018, and decided on February 13, 2019. On
September 10, 2018, attorney Michael Righetti inquired about the
status of the appeal. He wrote, “Over the last few years, I have inquired
repeatedly about the status of the case by telephone. . . . Each time I
call, the civil clerk informs me that she will follow the required procedure
and ‘send an email to chambers’ to notify the justices that I have made
an inquiry about the case. Despite my inquires [sic], I have never
received a response from the Court — and my clients’ appeal continues
to languish. . . . A similar class action wage and hour appeal that is
pending in the Third District, in which our office is lead counsel, was set
for oral argument in July of 2018 despite having only been fully briefed
as of March of 2018. . . . Thus, it took approximately 4 months from the
full briefing for the oral argument order to issue in that case, which is
striking as compared to almost 4 years in the present case without such
an order. . . . I appreciate that there is a backlog of appeals, especially
in the Third District (this is no secret). Nevertheless, I feel it would be
remiss of me not to notify Your Honor of the situation, especially given
the angst felt by my clients as the years go by without a resolution in
this case.”
 Sacramento Municipal Utility District v. Kwan (No. C080474, rating of
2): This matter was assigned to Justice Murray on September 30, 2016,
-8-
reassigned to Justice Raye on or about January 1, 2019, and decided
May 15, 2019. On March 1, 2018, attorney Suzanne M. Nicholson
inquired about the status of this appeal. She wrote, “I understand and
appreciate the volume of cases before the court, but have never had a
case fully briefed for quite so long with no further activity. My client is
interested in reaching resolution. . .”
 People v. Johnson (No. C080001, rating of RDA): This matter was
assigned to Justice Raye on December 5, 2018, and decided on
December 1, 2020. The appeal involved a single issue — whether the
trial court improperly received evidence of a prior burglary. The
respondent conceded that the matter should be remanded to the trial
court to determine whether to exercise its discretion to strike the prior
serious felony enhancement. By the time Justice Raye issued a
decision, the appellant had already served his sentence, including the
five-year enhancement. On remand, the trial court determined that the
sentence remained as previously imposed.
Justice Raye did not minimize the impact of delay by prioritizing the
delayed matters and taking into account the effect of delay on the parties in
particular cases.
II. FAILURE TO EXERCISE ADMINISTRATIVE AND SUPERVISORY
AUTHORITY
Between January 2011 and March 2021, Justice Raye failed to properly
exercise his administrative and supervisory authority to provide a forum for the
expeditious resolution of appellate disputes. His role as administrative presiding
justice of the Third District Court of Appeal required that he advocate and
encourage reasonable procedures to ensure that priority and older cases were
decided first.
California Rules of Court, rule 10.1004 outlines the responsibilities of an
appellate presiding justice. Subsection(b) states, “The administrative presiding
-9-
justice is responsible for leading the court, establishing policies, promoting
access to justice for all members of the public, providing a forum for the fair and
expeditious resolution of disputes, and maximizing the use of judicial and other
resources.” (Italics added.) Subsection (c)(1) states, “The administrative
presiding justice has general direction and supervision of the clerk/executive
officer and all court employees except those assigned to a particular justice or
division[.]” Subsection (c)(5) states, “The administrative presiding justice
supervises the administration of the court’s day-to-day operations, including
personnel matters, but must secure the approval of a majority of the justices in
the district before implementing any change in court policies[.]”
Justice Raye was aware, throughout the time he served as the Presiding
Justice, that there were chronic delays in cases assigned to some of the other
justices on the court. From January 2011 through March 2021, the decisions in
1,861 matters were delayed for more than one year from the completion of the
briefing on the appeal; 768 of those cases were pending for more than two years
after the completion of the briefing in the case. Although Justice Raye repeatedly
discussed the issue of delay with his colleagues on the court, he did not fulfill his
administrative responsibility to propose and advocate changes to court procedure
that would ensure the prompt resolution of older cases.
The delays affected the parties to the appeals. In some cases, the appeals
became moot as a result of the passage of time. In other cases, one or more of the
parties in the case suffered adverse economic impacts from the delays. Some
defendants in criminal cases served time that would not have been served had the
appellate decision been issued at an earlier date, and others had served their full
term of probation, subject to conditions that were ultimately found to be improper.
Although Justice Raye, in 2012, circulated target standards for the timely
processing of appeals, and reaffirmed the standards in 2015 and 2018, the
standards were often excused. Although Justice Raye took various steps to
reassign cases or pause assignments to chambers that were particularly
- 10 -
backlogged, these steps did not resolve the chronic delays. Justice Raye was
aware that the steps he had taken did not resolve the backlogs and, at times,
those efforts burdened the justices on the court who had fewer older cases.
In addition to canons 3B(8) and 2A, Justice Raye’s failure to properly
exercise his administrative and supervisory authority violated canons 3C(1) (duty
to diligently discharge administrative responsibilities in a manner that promotes
public confidence in the integrity of the judiciary), 3C(2) (duty to maintain
professional competence in judicial administration, and cooperate with other
judges and court officials in the administration of court business), 3D(1) (duty to
take appropriate corrective action when there is reliable information that another
justice had violated provisions of the Code of Judicial Ethics), and 1 (duty to act
at all times in a manner that promotes public confidence in the integrity and
impartiality of the judiciary, and to establish, maintain, and enforce high
standards of conduct, and personally observe those standards so that the
integrity and independence of the judiciary is preserved).
The pattern of chronic delay, described in sections I and II above, creates
the appearance that the delay could affect adjudicative decisions, and impede or
deny meaningful appellate review.
Justice Raye’s conduct was, at a minimum, improper action within the
meaning of California Constitution, article VI, section 18(d).
The time period of the delay, and the number of delayed cases,
aggravated the conduct, described above. In mitigation, Justice Raye resolved
most of his pending aged matters promptly after contact by the commission.
Also, he has been a bench officer for more than three decades and has not been
the subject of prior discipline. Since he was appointed to the Court in 1991,
Justice Raye authored over 3,600 opinions and participated as a panel
member in over 7,000 other opinions. He issued over 1,200 opinions in the
ten-year time frame addressed in this admonishment. In further mitigation,
Justice Raye stipulated to this resolution, thereby bringing the matter to
- 11 -
conclusion and saving the commission the expenditure of further staff
resources in investigating and resolving this matter.
By signing this stipulation, in addition to consenting to discipline on the
terms set forth, Justice Raye expressly admits that the foregoing facts are
true and that he agrees with the stated legal conclusions.
DISCIPLINE
The commission found the prejudice to litigants and the significant length
of the delay in a number of Justice Raye’s cases to be aggravating factors. In
mitigation, Justice Raye has no prior discipline, after three decades of service as
a judicial officer. Justice Raye acknowledged that he was aware of his own
backlog and those of other justices. He admitted his misconduct and stipulated
to discipline. In determining to accept the Stipulation, the commission took into
consideration the justice’s agreement to retire and not serve as a judicial officer
again. The commission concluded that this resolution adequately fulfills its
mandate to protect the public from further possible misconduct and avoids the
need for further proceedings.
Commission members Hon. Michael B. Harper; Dr. Michael A. Moodian;
Hon. William S. Dato; Mr. Eduardo De La Riva; Rickey Ivie, Esq.; Ms. Kay
Cooperman Jue; Ms. Sarah Kruer Jager; Hon. Lisa B. Lench; Victor E. Salazar,
Esq.; Mr. Richard Simpson; and Ms. Beatriz E. Tapia voted to accept the
stipulation.
Date: June 1, 2022 On behalf of the
Commission on Judicial Performance,
Honorable Michael B. Harper

Chairperson
- 12 -
STATE OF CALIFORNIA
BEFORE THE COMMISSION ON JUDICIAL PERFORMANCE
IN THE MATTER CONCERNING STIPULATION FOR DISCIPLINE
JUSTICE VANCE W. RAYE BY CONSENT (Rule 116.5)
Pursuant to Rules of the Commission on Judicial Performance, rule 116.5,

Justice Vance W. Raye of the California Court of Appeal, Third District,
represented by Edith R. Matthai, and commission counsel (the “parties”) submit
this proposed disposition of the matters set forth in the commission’s staff inquiry
letter, dated November 30, 2020, preliminary investigation letter, dated
February 23, 2021, and supplemental preliminary investigation letter, dated
July 26, 2021. The parties request that the commission resolve this matter by
imposition of a public admonishment. The parties believe that the settlement
provided by this agreement is in the best interests of the commission and Justice
Raye because, among other reasons, in light of the stipulated facts and legal
conclusions, a public admonishment, along with other terms, recited herein,
adequately protects the public and will avoid the delay and expense of further
proceedings.
TERMS AND CONDITIONS OF AGREEMENT
1. This agreement resolves the matters alleged in the commission’s
pending preliminary investigation involving Justice Vance W. Raye.
2. The commission shall issue a public admonishment based on the
agreed Stipulated Facts and Legal Conclusions set forth therein.
3. If the commission accepts this proposed disposition, the commission’s
decision and order imposing a public admonishment may articulate the reasons
for its decision and include explanatory language that the commission deems
appropriate.
4. Upon acceptance by the commission, this stipulation and the
commission’s decision and order shall be made public.
-1-
5. Justice Vance W. Raye waives any further proceedings and review in
this matter, including formal proceedings (Rules of Com. on Jud. Performance,
rule 118 et seq.) and review by the Supreme Court (Cal. Rules of Court, rule 9.60).
6. Justice Vance W. Raye shall advise the Governor of California, in
writing, of his retirement from judicial office, effective June 1, 2022.
7. If Justice Vance W. Raye does not retire as of June 1, 2022, the
commission may withdraw the public admonishment and resume the preliminary
investigation as to all of the matters in the staff inquiry and preliminary
investigation letters. Failure to comply with the terms and conditions of this
agreement may also constitute additional and independent grounds for discipline.
8. Justice Vance W. Raye has agreed not to seek or hold judicial office, or
accept a position or assignment as a judicial officer, subordinate judicial officer, or
judge pro tem with any court in the State of California, or accept a reference of
work from any California state court, at any time after June 1, 2022, except that, in
the interest of justice, to conclude matters, which have been previously assigned
to him and cannot be completed by June 1, and which would place an undue
burden on the other justices if they were reassigned. Justice Raye may also
respond to any request from the Third District for information regarding a case that
was assigned to Justice Raye before the date of his retirement.
9. If Justice Vance W. Raye attempts to serve in a judicial capacity in
violation of the foregoing paragraph, the commission may withdraw the public
admonishment and resume the preliminary investigation as to all of the matters in
the staff inquiry and preliminary investigation letters.
10. Justice Vance W. Raye agrees that the facts recited herein are true
and correct, and that the discipline to which the parties stipulate herein is
appropriate in light of those facts.
11. The commission may reject this proposed disposition and resume its
preliminary investigation. If the commission does so, nothing in this proposed
disposition will be deemed to be admitted or conceded by either party.
-2-
Accordingly, it is hereby stipulated and agreed that the commission shall
issue a public admonishment on the above Terms and Conditions of Agreement
and based on the following Stipulated Facts and Legal Conclusions.
STIPULATED FACTS AND LEGAL CONCLUSIONS
This disciplinary matter concerns Justice Vance W. Raye, the
Administrative Presiding Justice of the Third District Court of Appeal since 2010.
His current term began in 2015. Justice Raye was appointed to Sacramento
Superior Court in 1989 and as an Associate Justice on the Third District Court of
Appeal in 1991.
Justice Raye engaged in a pattern of delay in deciding around 200
appellate matters over a ten-year period.
I. PATTERN OF PERSISTENT DECISIONAL DELAY
“The failure to resolve appellate cases in an appropriately expeditious
timeframe undermines the ability of the appellate courts to efficiently manage
their publicly provided resources, demonstrate effective leadership within the
Judicial Branch and promote public confidence in the courts.” (Doerner, Model
Time Standards for State Appellate Courts (2014) p. 18.)
Under California law, judges are expected to decide matters submitted to
them within 90 days of submission and are prohibited from receiving their salaries
when they have undecided matters under submission for more than 90 days.
(Cal. Const., art. VI, § 19; Mardikian v. Commission on Judicial Performance
(1985) 40 Cal.3d 473, 477, fn. 4.) Other than the 90-day rule, there is no law or
rule that sets a specific limit on the time an appellate court takes to decide a
matter1 and, in particular, nothing that directly addresses pre-submission delay.
1
“[F]ederal courts have held that undue delay in processing an appeal
may rise to the level of a violation of due process.” (Daniel v. State (Wy. 2003) 78
P.3d 205, 218 [citations omitted].) The Tenth Circuit has enunciated a general
rule that delay in adjudicating a noncapital criminal appeal for more than two
years after filing of the notice of appeal, including more than 11 months from the
completion of briefing to the opinion’s filing, raises a rebuttable presumption of
-3-
More generally, however, the Code of Judicial Ethics requires judges to dispose
of all judicial matters fairly, promptly, and efficiently (canon 3B(8)) and to act at all
of the judiciary (canon 2A).
Appellate court cases are not “submitted” until after oral argument is heard,
or argument is waived. At the Third District, a case is not set for oral argument
until there is a full draft memorandum that at least two justices agree on. Justice
Raye did not violate the 90-day rule on any matter assigned to him. Rather, the
pre-submission decisional delay in this matter implicates the general standards of
canons 3B(8) and 2A. Justice Raye engaged in a pattern of delay in deciding a
significant number of appellate cases over a lengthy period. In particular, both with
respect to the court as a whole (in his role as presiding justice) and as to cases
assigned to him personally, he failed to encourage and adopt reasonable
procedures to ensure that priority and older cases were decided first.
The commission surveyed approximately 200 matters (as set forth in
Exhibit 1 and incorporated herein as though set forth in full) assigned to him from
2011 to 2021, in which more than one year passed between the completion of
briefing and the issuance of an opinion (or dismissal of the matter). Not every such
case warrants discipline, and whether it does depends on a number of relevant
prejudice from an ineffective appellate process. (Harris v. Champion (10th Cir.

1994) 15 F.3d 1538, 1555-1561 & fn. 11; accord, e.g., U.S. ex rel. Green v.
Washington (N.D. Ill. 1996) 917 F.Supp. 1238, 1277.) The National Center for
State Courts, along with the Court Management Committee of the Conference of
Chief Justices and the Conference of State Court Administrators determined that,
in 95% of civil cases, 570 days (one year and seven months) is considered a
reasonable number of days from initial filing to issuance of an opinion. (Doerner,
supra, at p. 22.) For criminal appeals (excluding death penalty cases), a
reasonable number of days from initial filing to opinion is 600 days
(approximately one year and eight months). (Id. at p. 20.) Given the amount of
time required from initial filing to case fully briefed, to meet the 600-day target in
criminal cases, the time from a case being fully briefed to opinion would be less
than one year.
-4-
circumstances. During the ten-year time frame examined by the commission,
Justice Raye authored opinions in over 1,200 matters, including the cases
identified in Exhibit 1. A substantial portion of those cases were decided within
one year from the completion of briefing.
At the same time, a significant number of cases languished for years.
Justice Raye’s oldest completed case (No. C067600) had aged seven years and
nine months after being fully briefed before the parties dismissed the matter.
Two of Justice Raye’s cases were delayed between six and seven years; five
between five and six years; 17 between four and five years; 29 between three
and four years; and 45 between two and three years. Justice Raye’s oldest
pending case (No. C070732, rating of 2) is a criminal matter with youthful
offenders in which supplemental briefing was requested by the parties and
authorized by the court in January 2022 after the case had been fully briefed for
eight years and seven months.2 Justice Raye failed to prioritize efforts so that
older cases could be resolved before work began on newer ones.
The parties acknowledge that the Third District Court of Appeal has a high
volume of cases. If the reason for the delay were attributed solely to an
overburdened court, one would expect that all or virtually all of the justices of the
Court would be similarly affected, which is not the case at the Third District.
In approximately 14 to 35 percent of the cases assigned to Justice Raye
from 2001 through 2019, more than a year passed between the date the cases
were fully briefed and the date the opinions issued. In contrast to these high
levels of delay, only 7 percent of cases assigned in 2020—after an inquiry from
the commission—were unresolved more than a year after the completion of
briefing. This suggests that Justice Raye could have decided the matters in a
2
The court’s managing attorney screens all appeals and numerically
ranks each chambers case according to complexity, from 1 to 5, with higher
numbers assigned to more complex cases. Most routine disposition appeals
(RDAs) and juvenile dependency cases are initially prepared by a pool of central
staff attorneys.
-5-
more timely manner. (See Mardikian, supra, at p. 482 [discipline appropriate
where delays are persistent and avoidable].) The evidence does not show that
the delay was caused by an intentional disregard of the justice’s duties. (See In
re Jensen (1978) 24 Cal.3d 72, 73 [discipline appropriate where there is a
persistent failure to perform judicial duties, even if the failure is not an intentional
disregard of duties].)
During the relevant time period, Justice Raye was aware of his growing
backlog of cases. He received monthly reports that identified his assigned cases
and the date of each assignment. The justices in the Third District discussed the
topic of delay and the court’s “growing backlog of appeals” at several justices’
meetings and three court retreats from 2012 through 2018.
Justice Raye also did not give calendar preference to three juvenile
delinquency cases: People v. B.G. (No. C081515), People v. Q.N. (No.
C064967), and People v. C.C. (No. C087924), as provided by Welfare and
Institutions Code sections 395 and 800, subdivision (a).3 In addition, more than
half of Justice Raye’s delayed cases were matters in which the people of the
state were parties. He did not accord these matters calendar preference over civil
appeals, and other cases (excluding juvenile matters) that had been filed during
the same period, as provided by section 44 of the Code of Civil Procedure.4
3
Welfare & Institutions Code sections 395 and 800, subdivision (a) provide
calendar preference to juvenile dependency and juvenile delinquency cases over
all other cases. (Welf. & Inst. Code, §§ 395 and 800, subd. (a) [“The appeal shall
have precedence over all other cases in the court to which the appeal is taken”].)
(See also Abdullah B. v. Superior Court (1982) 135 Cal.App.3d 838, 844.)
4
After juvenile matters, section 44 of the Code of Civil Procedure
authorizes courts of appeal to provide calendar preference to criminal matters,
and then to probate and election cases. Section 44 states that appeals in
probate proceedings, contested election cases, and certain defamation cases
“shall be given preference in hearing” and “shall be placed on the calendar in the
order of their date of issue, next after cases in which the people of the state are
parties.”
-6-
Justice Raye’s failure to provide calendar preference to juvenile and criminal
cases violated his obligation to respect the statutory language and to act at all
of the judiciary (canon 2A) and to dispose of all judicial matters fairly, promptly,
and efficiently (canon 3B(8)).
Justice Raye’s conduct caused prejudice to civil litigants and criminal
defendants. Prejudice can occur in civil cases by parties suffering from
uncertainty as disputes remain unresolved, or the payments of money judgments
are delayed. In criminal cases, appellants are prejudiced if they have served all
or part of a reversed sentence, or when faded memories or lost evidence hamper
resentencing hearings or retrials. Prejudice can also manifest as “increased
anxiety, mistrust, hopelessness, fear, and depression” that “results from the very
thwarting of the hope that liberty will be restored through a right that the State
has guaranteed -- the appellate process.” (United States ex rel. Green v.
Washington, (N.D. Ill. 1996), 917 F.Supp. 1238 at pp. 1277-1278.) Known
prejudice occurred in the following six cases:
 People v. Flores (No. C066914, rating of RDA): This matter was
assigned to Justice Raye on February 23, 2012. On June 4, 2017, the
appellant’s counsel inquired about the status of the appeal. Attorney
Tutti Hacking stated that the appellant had received a six-year prison
term and had served the sentence while the appeal was pending. Ms.
Hacking wrote, “It has been over five years since this case was fully
briefed yet no decision has been rendered by the Court of Appeal. Mr.
Flores has had to continue his life with a felony conviction on his record,
and he has no other criminal record.” On August 21, 2017, Ms. Hacking
again inquired about the status of the case and complained that she had
received no response to her earlier inquiry.
 Environmental Council of Sacramento et al. v. County of Sacramento et
al. (No. C076888, rating of 4): This matter was assigned to Justice
-7-
Raye on February 26, 2015, and decided on January 30, 2020. On
May 19, 2017, all parties jointly requested that oral argument be
calendared, consistent with the calendar preference mandates of Public
Resources Code section 21167.1. The attorneys wrote, “Counsel
involved in this case are involved in other CEQA-related appeals
pending before the Court for which notifications regarding oral
argument have been received even though the briefing was completed
much later than the briefing in this matter. The absence of a final
decision in this matter creates substantial uncertainty for the parties at a
critical juncture for the long term development of the Cordova Hills
project that was approved in January, 2013.”
 Myers et al. v. Raley’s (No. C075125, rating of 3): This matter was
assigned to Justice Murray on October 31, 2014, reassigned to Justice
Raye on June 29, 2018, and decided on February 13, 2019. On
September 10, 2018, attorney Michael Righetti inquired about the
status of the appeal. He wrote, “Over the last few years, I have inquired
repeatedly about the status of the case by telephone. . . . Each time I
call, the civil clerk informs me that she will follow the required procedure
and ‘send an email to chambers’ to notify the justices that I have made
an inquiry about the case. Despite my inquires [sic], I have never
received a response from the Court — and my clients’ appeal continues
to languish. . . . A similar class action wage and hour appeal that is
pending in the Third District, in which our office is lead counsel, was set
for oral argument in July of 2018 despite having only been fully briefed
as of March of 2018. . . . Thus, it took approximately 4 months from the
full briefing for the oral argument order to issue in that case, which is
striking as compared to almost 4 years in the present case without such
an order. . . . I appreciate that there is a backlog of appeals, especially
in the Third District (this is no secret). Nevertheless, I feel it would be
-8-
remiss of me not to notify Your Honor of the situation, especially given
the angst felt by my clients as the years go by without a resolution in
this case.”
 Sacramento Municipal Utility District v. Kwan (No. C080474, rating of
2): This matter was assigned to Justice Murray on September 30, 2016,
reassigned to Justice Raye on or about January 1, 2019, and decided
May 15, 2019. On March 1, 2018, attorney Suzanne M. Nicholson
inquired about the status of this appeal. She wrote, “I understand and
appreciate the volume of cases before the court, but have never had a
case fully briefed for quite so long with no further activity. My client is
interested in reaching resolution. . .”
 People v. Johnson (No. C080001, rating of RDA): This matter was
assigned to Justice Raye on December 5, 2018, and decided on
December 1, 2020. The appeal involved a single issue — whether the
trial court improperly received evidence of a prior burglary. The
respondent conceded that the matter should be remanded to the trial
court to determine whether to exercise its discretion to strike the prior
serious felony enhancement. By the time Justice Raye issued a
decision, the appellant had already served his sentence, including the
five-year enhancement. On remand, the trial court determined that the
sentence remained as previously imposed.
Justice Raye did not minimize the impact of delay by prioritizing the
delayed matters and taking into account the effect of delay on the parties in
particular cases.
II. FAILURE TO EXERCISE ADMINISTRATIVE AND SUPERVISORY
AUTHORITY
Between January 2011 and March 2021, Justice Raye failed to properly
exercise his administrative and supervisory authority to provide a forum for the
expeditious resolution of appellate disputes. His role as administrative presiding
-9-
justice of the Third District Court of Appeal required that he advocate and
encourage reasonable procedures to ensure that priority and older cases were
decided first.
California Rules of Court, rule 10.1004 outlines the responsibilities of an
appellate presiding justice. Subsection(b) states, “The administrative presiding
justice is responsible for leading the court, establishing policies, promoting
access to justice for all members of the public, providing a forum for the fair and
expeditious resolution of disputes, and maximizing the use of judicial and other
resources.” (Italics added.) Subsection (c)(1) states, “The administrative
presiding justice has general direction and supervision of the clerk/executive
officer and all court employees except those assigned to a particular justice or
division[.]” Subsection (c)(5) states, “The administrative presiding justice
supervises the administration of the court’s day-to-day operations, including
personnel matters, but must secure the approval of a majority of the justices in
the district before implementing any change in court policies[.]”
Justice Raye was aware, throughout the time he served as the Presiding
Justice, that there were chronic delays in cases assigned to some of the other
justices on the court. From January 2011 through March 2021, the decisions in
1,861 matters were delayed for more than one year from the completion of the
briefing on the appeal; 768 of those cases were pending for more than two years
after the completion of the briefing in the case. Although Justice Raye repeatedly
discussed the issue of delay w

9-26-2023 - Reply To Commissioner Opposition Waszczuk v. IRS Commissioner USCA No.20-1407

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USCA Case #20-1407 Document #2019046 Filed: 09/26/2023 Page 89 of 149

The State Bar OFFICE OF CHIEF TRIAL COUNSEL

September 25, 2023

RE: Case Number: 23-O-23272 Gregory Paul Dresser

Dear Jaroslaw Waszczuk:

Thank you for your patience.

OFFICE OF CHIEF TRIAL COUNSEL/INTAKE

San Francisco Office Los Angeles Office

The State Bar OFFICE OF CHIEF TRIAL COUNSEL

September 25, 2023

RE: Case Number: 23-O-23273 Laura Ann Huggins

Dear Jaroslaw Waszczuk:

Thank you for your patience.

OFFICE OF CHIEF TRIAL COUNSEL/INTAKE

San Francisco Office Los Angeles Office

THE STATE BAR OF CALIFORNIA

SAN FRANCISCO OFFICE

ADDENDUM TO THE ATTORNEY MISCONDUCT COMPLAINT

TO THE STATE BAR OF CALIFORNIA CHIEF TRIAL COUNSEL

1. STATE BAR OF CALIFORNIA CASE NO.15-0-10110- LMA; CALIFORNIA

The case involved : My former ATTORNEY DOUGLAS EDWARD STEIN , SBN

2. WRIT OF MANDAMUS - UNEMPLOYMENT INSURANCE BENEFITS CASE

3. THE SACRAMENTO COUNTY SUPERIOR COURT WRONGFUL

Question No. 2: Does this complaint involve allegations of attorney misconduct

To the contrary, Stein was diligent and transparent—making

A. Notice of Appeal in Waszczuk v. The Regents of The University of California,

B. Proposed Third Amended Complaint (TAC) in Sacramento Superior Court

In reply, I sent to Gormley a draft of my 295-page-long TAC, which detailed and

On October 12, 2017, THE CALIFORNIA COMMISSION ON JUDICIAL

To the contrary, Stein was diligent and transparent—making

inadvertently filed during the briefest of suspensions for a minor

The California anti-SLAPP statute was intended to counter the

exercise of the constitutional rights of freedom of speech and petition for

A. Sacramento County Superior Court Judge Christopher Krueger, from Dept.

requirement (Civil Code of Procedure§§ 491.110, 708.110, 708.120, & Sacramento

After Burkett and Bardzell failed to eliminate my wrongful termination lawsuit by

A. Trial Date and Mandatory Settlement Conference Date Submission Form

JAROSLAW WASZCZUK V. THE REGENTS OF THE UNIVERSITY OF

A. After the Regents Attorneys’ Multiple Unsuccessful Attempts to end my

B. The Regents’ Attorneys Attack on my Wife in an Attempt to Break into her

• CIVIL SUBPOENA (DUCES TECUM) for Personal Appearance and Production

• DECLARATION BY OLATOMIWA T. AINA IN SUPPORT OF JUDGMENT

D. Judge Shama Hakim Mesiwala

On February 14, 2023, Judge Mesiwala was unanimously confirmed as an associate

G. Judge Shama H. Mesiwala’s Disqualification

On June 29, 2021, I filed a PEREMPTORY CHALLENGE (Code of Civil Procedure §

H. My and My Wife Irena Waszczuk’s Appearance on July 2, 2021 in

money theft from my wife .

PLEASE TAKE NOTICE that effective immediately Lindsay A.

DATE: 08/04/2021 TIME: 09:00:00 AM DEPT: 54

B. George Acero’s Interference in Waszczuk’s Employment with The University

as a communicator between attorneys and management from Human Resources, the

termination lawsuit filed by a UCDMC employee in Sacramento County Superior Court, Um

A. The court hearing

conspiracy with The Regents’ attorney.

B. The Regents’ attorney from Porter Scott, Thomas Riordan

In my reply to Kem I stated:

My inquiry with the CJP was triggered in the defense of my 70-year-old

C. The Incomplete Record on Appeal and Wrongly Labeled Clerk’s Transcript

TRANSCRIPTS ARE DUE: 05/09/22

Please read all designations as Computer-Readable format may have been

Executed on: April 8, 20 B Kevin M

B. November 10, 2022 Letter Addressed to Kem addressing Harvey’s Response,