Escolar Documentos
Profissional Documentos
Cultura Documentos
23 page 9:20). Most notably and prejudicially, the FAC fails to identify what claims are asserted
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2
. Plaintiffs three (3) young, super-energetic, precocious and talented grandchildren from the London
25 suburbs, 2 , 6 and 8 years old, their mother and a substantial number of local girls have been here
now for over a month, descending on our Blackberry Lane property like a circus. Plaintiff has been
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the ring-master, builder, entertainment director, supervisor and general manager of bungee jumping,
27 zip-lines, Karaoke, tornado experiments, daily trips, charging electric car batteries, putting bicycle
wheels back on, darts, badminton, treasure hunts and at least 100 other things, many potentially and
28 literally dangerous. That visiting overlap with the last week of the FAC edits and continuing through
the weekend of August 20, 2017, and half of this document, has unfortunately affected the quality of
this work. With up to 15 different kids here each day, including at least two with special needs,
there has been a continuous and urgent need for a safety engineer, monitor, chaperone and dispute
manager, for MANY hours per day, all of which are very physical, difficult, but satisfying (and fun).
21 Generally, all alleged RICO enterprise defendants are now responsible for executing
all present and past RICO conspiratorial objectives, including the ongoing cover-up of the
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initial contaminating encroachment, and related subsequent wrongdoings. Philosophically,
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considering that all defendants (including the contamination ones) are presently fully
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relying on the corrupt RICO leadership attorneys to present their defense, (which includes
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additional fallacious and fraudulent arguments in their every document), plaintiff now sees
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no substantive difference between almost all causes against all 16 defendants, except for the
27 nine (9) obvious exceptions named below. In other words, the contamination and RICO
28 defendants have now mostly merged together regarding most3, but not all, of the 30 causes of
action. Culpability, deserved punishment and the degree of damages attributable to each defendant
3
The 21 merged causes of action which are now alleged against the contamination and all RICO
defendants, i.e. against all 16 so-far named defendants are: Causes 1-8; 10-14; 17-22; 25 and 28.
RAO defendants; Kishpaugh; Randall and the City of Eureka, sued, due to the alleged possible
28 wrongdoing of their former employee Davis, in contract with Olson and RAO Construction, 8 total.
The RICO defendants are: Russell Gans, John Mathson, the three RAO defendants (Olson,
Skillings and RAO Construction, now all in default); Plotz; Brisso; Gilbride; Kloeppel; The Mitchell
firm; Lawrence and Nelson, 12 total. That is a total of 16 individual defendants with four (4)
overlapping into both groups: John Mathson, Rich Olson, Kyle Skillings and RAO Construction.
10 are very highly perplexed about plaintiffs inconsistent and unintelligible discussions of who
11 the contamination and RICO defendants are and why they are all being sued in many if not
most of the causes of action. Plaintiff believes that here and in the proposed SAC, he has greatly
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simplified defendants quandary about who was being sued for what and which defendants should
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respond to which rambled and baseless assertion, by suggesting that all 16 reply to the 21
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designated above, with the nine (9) exceptions as explained on page 7 above and in the FAC and/or
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SAC. That would seem to be appropriate, unless someone can prove they are not RICO enterprise
16 members and therefore should only have to reply to the contamination allegations. Again, all this is
17 merely plaintiffs opinion, and hopefully the court will weigh-in specifically on some of these
18 issues, so that this Pro Se litigant can satisfy said court, because clearly defendants are never
19 going to be satisfied with any articulation by plaintiff of his contamination or RICO allegations.
20 m. Additionally, it would seem to be prudent for all RICO enterprise members to respond to all
21 relevant causes of action, whereas the pure contamination defendants may have potentially less
exposure initially. However, it is obviously unknowable today what financial responsibility at trial
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each defendant will have before discovery and the expected masses of perjured discovery
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responses, motion statements and declarations, which are already reaching epidemic proportions.
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For example, the comments by the City in defendants FN #6, page 9, Motion, ID are at a
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minimum intentionally deceptive and WRONG, according to plaintiffs written documents which
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are strongly believed to be accurate. Said FN #6 statements are not yet sworn or perjured but as
27 soon as the court allows discovery to begin, plaintiff has a variety of Special Interrogatories and
28 RFAs to get some of these false statements on the record as soon as possible, before defendants
decide to take a few minutes to check their facts a little bit. This issue would ordinarily be further
clarified in the next section, except that, as above, Remington needs to behave more like
fully proven to have been frivolous from its inception, although that perhaps is merely plaintiffs
subjective judgment. In other words, plaintiff rejects the notion that two prior civil actions have
10 quote at his lines 8-9, page 9, where, once again he falsely wrote ([The Ninth claim] is asserted
11 against RICO coverups, among other named defendants. Plaintiff never gets tired of considering
how Mr. Gans takes just enough of plaintiffs own words to appear sincere, ethical and plausible, but
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then juxtapositions them to make Remington look like an idiot, while Mr. Gans patiently notes
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how severely prejudiced he was by plaintiffs (unspoken, but clearly understood) pro se lunacy,
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and also KNOWS that most courts will accept his version without researching it, and sooner or later
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will (hopefully) get impatient enough with pro se Remington to kick him out of court.
16 C. Page 9:10. AS ABOVE, This is yet another intentional Gans attempt to confuse the court
17 and render plaintiffs writing absurd, utterly incomprehensible, and to infer plaintiff is an idiot that
18 does not belong in this court with real legitimate attorneys. Gans (again) writes, always
19 intentionally (as what he does is very skilled, very SMART, highly sophisticated and far-beyond
20 plaintiffs ordinary honest literary abilities): The Eleventh claim is against all contamination
21 defendants and RICO defendants cooperating in the contamination (Id at pg 19, ln 28+). That is
simply-put another intentional exceptionally false quote, rendered entirely unintelligible!
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The actual passage as written by plaintiff in the FAC is: ELEVENTH CAUSE OF ACTION for
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statutory contribution from all contamination defendants and RICO defendants cooperating in the
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contamination cover-up and RICO objectives, emphasis added. Note that Gans dropping of
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those last four words entirely changes the meaning of the sentence, rendering it absurd and entirely
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unintelligible in the Gans version. Since Mr. Gans is the officer of the court, it is plaintiff that
27 becomes the idiot step-child, not Gans. Plaintiff MUST highlight these fallacious frauds.
28 Further note, that in the SAC, plaintiff stopped trying to explain, qualify precisely and add
subtle meanings, regarding who these causes are against, and now (in the proposed SAC) just
alleges that Statutory Contribution (11th Claim) is against ALL defendants. Other qualifications and
25 harp on all of Gans continuous deceptive litigation practices which are obviously intentionally
intended to unethically prejudice Remington, waste his time and this courts in order to bias said court
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against the obnoxious pro se, (for writing so many pages), exactly as occurred with Judge Vadas,
27 previously. As has been partially explained previously, as best a 20-40,000 page record can be
summarized here, Judge Reinholtsen mostly ignored Gans false deceptions and DENIED at least 8-
28 10 (i.e., ALL) of his last continuous, successive requests for monetary sanctions against plaintiff in
every motion, however, eventually after almost 120-continuous three hour days of these pre-trial
skirmishes, said judge surprisingly succumbed to the false logic, fallacies and untruths which
constituted MIL #20, previously addressed at length in this court by Request for Judicial Notice. Why
that happened has been alluded to, still remains to be fully discovered and is beyond the scope here.
have been clarified and the state collateral estoppel issue has been fully repudiated, either here
or in state appellate court, there will be plenty of time to reinitiate DR140426 or more likely
11 according to all of plaintiffs present information, which is believed to be eminently reliable, and
beyond question. Remington is not going to explain what his documented facts are until the City
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has taken their current odd position in RFAs, Special Interrogatories and/or other definitive,
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supposedly accurate writings subject to Rule 11. However, at this stage, plaintiff does comment to
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the court that the City is really acting erratically, and like Mr. Nelsons attorneys appear to NOT
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take this case seriously at all, or even be willing to take just a few minutes to get their basic facts
16 straight; however, when the City files their imminent dispositive motion to quash, perhaps
17 plaintiff will present part of his information. Meanwhile, the City is progressively acting
18 increasingly suspiciously and rather than just acknowledging the simple, innocent facts, if they
19 honestly believe they are innocent. Instead they have been progressively burying themselves
20 deeper in false statements and incorrect unsubstantiable facts, when plaintiff had initially assumed
21 and written TO THEM in April-May that they could or would likely be, and probably should have
been out of the case, at least by this time. Inferentially, their attorneys are going to run-up a
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substantial legal tab before they do the obvious as suggested by plaintiff in writing, four months
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ago, including also in ECF #1.
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(e) ERROR admitted. Despite All of these new issues and objections raised by plaintiff
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herein, as above, Remington is still WRONG here overall, but innocently in part, as he was
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partially duped by Gans Courthouse saboteur, primarily, once again, or by other related factors
27 into believing that his incorrect incorporation by reference, of entire prior edited complaints as
28 factual encyclopedic references, method was correct, because it had survived in state court for
about two years. As explained, Plaintiff held that apparently erroneous view, right up until August
15, 2017 when he received ECF #54, which was very surprising. Also as explained above,
11 pleading, or in any other pleading or motion, emphasis added, thereby becoming part of the
pleading for all purposes. In the FAC, plaintiff also frequently referred to specific passages in ECF
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#1, per Rule 10 (b) without any defendants objection. As explained above, as just learned by
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plaintiff a few days ago and as undoubtably already fully understood by this court, specific topical
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references to an earlier complaint, without incorporating its entirety, are perfectly legitimate and
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proper. About 80 of those proper specific references were done initially, and have now been further
16 supplemented or checked in the proposed SAC. Obviously, those detailed references provide
17 better notice regarding the exact details of the relevant allegations, but they are not construed as
18 being legally integral to the FAC or SAC, and although part of it, rather they are mostly
19 peripheral, and therefore ancillary and potentially removable if necessary, without altering the
20 overall legal effect.
21 2. Plaintiff has seen many other references to the use of exhibits explicitly and directly
believed to be authoritative which clearly explains that ALL or portions of attached documents can
be incorporated, and conversely if they are not incorporated specifically, then they are not part of
22 towards a trial date, the faster defendants will be forced to resolve this entire situation. Ultimately,
23 defendants cannot convert their continuing nuisance and trespass, which has been fully
acknowledged as such by their own environmental experts, plus all other scientific experts in
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the case, into a simple, technical tough luck dismissal, based upon the statute of limitations,
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as they still aspire and keep attempting to do. Hopefully, all the RICO and other defendants
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will gradually learn and accept that fact sooner, instead of several years from now.
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Finally, plaintiff requests some sort of clarifying signal as to how seriously this court takes
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ethics violations and specifically, obvious, serial violations of Rule 11 (b) and CCP 128.7 (b) (1-4).
As noted above and previously, plaintiff believes that the moving RICO defendants motion writers
and effectively all attorneys involved here have been signing-onto a lot of false statements, which