plead paper flow bk pleading paper 42 usc 1983 cramin

8/3/2019 Plead Paper Flow Bk Pleading Paper 42 USC 1983 CRAMIN

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Antoine Bacha25 AuvergneNewport Coast, CA 92657(949) 887-9073

In pro per

UNITED STATES BANKRUPTCY COURT

CENTRAL DISTRICT OF CALIFORNIA

SOUTHERN DIVISION

ANTOINE BACHA ) Case No.:)

Plaintiff, ) COMPLAINT)

Vs. ) (Damages for Deprivation) of Civil Rights)

THE CIT GROUP/CONSUMER FINANCE,INC.)a Foreign Corp.; THE CITIGROUP,INC.) DEMAND FOR JURYa Foreign Corp.; CITIMORTGAGE INC. )a Foreign Corp.; MARIX SERVICING )LLC. a Foreign LLC; ASSURED LENDER)SERVICES,INC.; PD PROPERTY )INVESTMENTS LLC; Philipe Baltazar;

)

Steven A. Silverstein; Corey S. )Cramin; and the State of California)and DOES 1-100 )

)Defendants. )

___________________________________)

COMES NOW Plaintiff, ANTOINE BACHA, In pro per, and for the

Complaint against Defendants, states as follows:

JURISDICTION AND VENUE

1. Jurisdiction of this court arises under 42 U.S.C. 1983 in

sequence and seeking damages and redress be declaratory and injunctive

relief as well as the award of fees, if any, for the deprivation,

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under color of state law, or rights guaranteed by the United States

Constitution and the First, Fifth and Fourteenth Amendments to the

United States Constitution and for related common law and statutory

claims under the laws of the Commonwealth of California. The Court

has jurisdiction over the Plaintiffs state law claims under U.S.C.

1367(a).

2. Venue is proper in the District pursuant to 28 U.S.C.

1391(b), because all of the Defendants reside or conduct business and

litigation within this judicial district and all of the claims

asserted by Plaintiffs arose within this District.

THE PARTIES

3. Plaintiff, ANTOINE BACHA is a natural person and the owner

of the real property located at 25 Auvergne, Newport Coast,

California.

4. Defendant CIT Group/Consumer Finance, Inc. is a foreign

corporation and financial institution or bank with corporate offices

in San Diego making and managing mortgages in California.5. Defendant Citigroup Inc. is a foreign corporation and

financial institution or bank with corporate offices in New York,

making and managing mortgages in California.

6. Defendant Citmortgage Inc. is a foreign corporation and

financial institution or bank with corporate offices in Missouri,

making and managing mortgages in California.

7. Defendant Philipe Baltazar is a mortgage broker, operating

in the State of California.

8. Defendant Steven A. Silverstein is a natural person and an

attorney at law in the State of California.

9. Defendant Corey S. Cramin is a natural person and a Judge in

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the Superior Court of Orange County, State of California.

10. The party or parties who make this Complaint were within

the jurisdiction of the United States of America and at all times

alleged herein. The Defendants are sued individually and officially.

FACTS COMMON TO ALL COUNTS

11. Each and every allegation set forth in each and every

averment of this Complaint is hereby incorporated by this reference in

each and every other averment and allegation of this Complaint.

12. Each plaintiff was deprived of an interest protected by the

Constitution or laws of the United States, and defendants caused any

such deprivation while acting under color of state law.

13. All acts or omissions alleged to have been engaged in by

any defendant are alleged to have been engaged in with evil motive and

intent, and in callous, reckless, and wanton disregard to the rights

of any plaintiff.

14. Defendants State of California, knowingly, or grossly

negligently, or deliberately indifferently to the constitutional

rights of persons within the jurisdiction of United States of America,

maintained or permitted an official policy or custom of permitting the

occurrence of the types of wrongs set forth herein below, and, based

on the principles set forth in Monell v. New York City Department of

Social Services 436 U.S. 658 (1978), is liable for all injuries

sustained by any plaintiff as set forth hereinbelow

THE FACTS

15. That PLAINTIFF, ANTOINE BACHA is the owner of the real

property located at 25 Auvergne, Newport Coast, California

(hereinafter Property)

16. That Defendant, PD PROPERTY INVESTMENTS LLC, by and through

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and with the assistance of DEFENDANTS, STEVEN A. SILVERSTEIN filed an

unlawful detainer matter, Case No.: 30-2011-00489164, entitled PD

PROPERTY INVESTMENTS LLC V. BACHA(hereinafter the underlying matter)

on July 2011, seeking to gain the unlawful possession of the Property

from an purported foreclosure sale that is fraudulent in that

Civil Code Section 2924. Transfer as security deemed mortgageor pledge; power of sale; requirements prior to sale; trusteeliability; evidence of compliance; privileged communications;rebuttable presumption in pertinent part provides:

(1) The trustee, mortgagee, or beneficiary, or any of theirauthorized agents shall first file for record, in the office of therecorder of each county wherein the mortgaged or trust property orsome part or parcel thereof is situated, a notice of default. That

notice of default shall include all of the following:

Civil Code Section 2924f. Sale or resale of property wherethere is a default on the obligation secured by the property; notice;contents; posting and publication; postponement for properties withfive or more multifamily units

(b)(1) Except as provided in subdivision (c), before any saleof property can be made under the power of sale contained in any deedof trust or mortgage, or any resale resulting from a rescission for afailure of consideration pursuant to subdivision (c) of Section 2924h,notice of the sale thereof shall be given by posting a written notice

of the time of sale and of the street address and the specific placeat the street address where the sale will be held, and describing theproperty to be sold, at least 20 days before the date of sale in onepublic place in the city where the property is to be sold, if theproperty is to be sold in a city, or, if not, then in one public placein the judicial district in which the property is to be sold, andpublishing a copy once a week for three consecutive calendar weeks,the first publication to be at least 20 days before the date of sale,in a newspaper of general circulation published in the city in whichthe property or some part thereof is situated, if any part thereof issituated in a city, if not, then in a newspaper of general circulationpublished in the judicial district in which the property or some partthereof is situated, or in case no newspaper of general circulation ispublished in the city or judicial district, as the case may be, in a

newspaper of general circulation published in the county in which theproperty or some part thereof is situated, or in case no newspaper ofgeneral circulation is published in the city or judicial district orcounty, as the case may be, in a newspaper of general circulationpublished in the county in this state that (A) is contiguous to thecounty in which the property or some part thereof is situated and (B)has, by comparison with all similarly contiguous counties, the highestpopulation based upon total county population as determined by themost recent federal decennial census published by the Bureau of the

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Census. A copy of the notice of sale shall also be posted in aconspicuous place on the property to be sold at least 20 days beforethe date of sale, where possible and where not restricted for anyreason. If the property is a single-family residence the posting shallbe on a door of the residence, but, if not possible or restricted,then the notice shall be posted in a conspicuous place on theproperty; however, if access is denied because a common entrance tothe property is restricted by a guard gate or similar impediment, theproperty may be posted at that guard gate or similar impediment to any

development community. Additionally, the notice of sale shall conformto the minimum requirements of Section 6043 of the Government Code and**be recorded with the county recorder of the county in which theproperty or some part thereof is situated at least 20 days prior tothe date of sale. The notice of sale shall contain the name, streetaddress in this state, which may reflect an agent of the trustee, andeither a toll-free telephone number or telephone number in this stateof the trustee, and the name of the original trustor, and also shallcontain the statement required by paragraph (3) of subdivision (c). In

addition to any other description of the property, the notice shalldescribe the property by giving its street address, if any, or othercommon designation, if any, and a county assessor's parcel number; butif the property has no street address or other common designation, thenotice shall contain a legal description of the property, the name andaddress of the beneficiary at whose request the sale is to beconducted, and a statement that directions may be obtained pursuant toa written request submitted to the beneficiary within 10 days from thefirst publication of the notice. Directions shall be deemed reasonablysufficient to locate the property if information as to the location ofthe property is given by reference to the direction and approximatedistance from the nearest crossroads, frontage road, or access road.If a legal description or a county assessor's parcel number and either

a street address or another common designation of the property isgiven, the validity of the notice and the validity of the sale shallnot be affected by the fact that the street address, other commondesignation, name and address of the beneficiary, or the directionsobtained therefrom are erroneous or that the street address, othercommon designation, name and address of the beneficiary, or directionsobtained therefrom are omitted. The term newspaper of generalcirculation, as used in this section, has the same meaning as definedin Article 1 (commencing with Section 6000) of Chapter 1 of Division 7of Title 1 of the Government Code.

I refer to and incorporate Grantor / Grantee Deed Main Index Search Results

for Antoine Bacha establishing in the record all conveyances and title documents

recorded to all properties owned by Antoine Bacha recorded in the Official Records

of Orange County, California a true and correct copy is attached hereto as Exhibit

A, and incorporated herein by this reference. I note that on Index Search

Results listed on row four with a recording date of 7/28/2009 and Document Number

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2009-00403159, is a Trustees Deed.

I refer to and incorporate Document Number 2009-00403159 recording date of

7/28/2009 a true and correct copy is attached hereto as Exhibit B, and

incorporated herein by this reference. The document is for a property with an

APN# 936-46-140

I refer to and incorporate the APN Number and Property Address from the

Treasurer Tax Collector Orange County California for APN# 936-46-140, a true and

correct copy is attached hereto as Exhibit C, and incorporated herein by this

reference.

The APN# 936-46-140 is for a property address of 8 Anjou, Newport Coast,

California.

The document is not for the Property 25 Auvergne, Newport Coast, California.

I note that on the In Index Search Results listed on row three with a

recording date of 8/7/2008 and Document Number 2008-003758, is a Notice Of Trustee

Sale.


8/7/2008 a true and correct copy is attached hereto as Exhibit C, andincorporated herein by this reference. The document is not for the Property 25

Auvergne, Newport Coast, California.

I note that on the In Index Search Results listed on row eleven with a

recording date of 12/8/2010 and Document Number 2010-00660598, is a Notice Of

Default.


12/8/2010 a true and correct copy is attached hereto as Exhibit D, and

incorporated herein by this reference. The document is on the Property 25

Auvergne, Newport Coast, California recorded by Newport Ridge Summit Homeowners

Association Inc.

There is no Notice of Sale recorded on the Property, 25 Auvergne, Newport

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Coast, California, evidencing any trustee sale.

And there is no trustee sale.

17. That Plaintiff had to file bankruptcy on September 29, 2011, seeking to

avoid losing the property through wrongful foreclosure and there is a case in

Central District Bankruptcy Court Case No. 8:11-bk-23607-ES, In re ANTOINE BACHA

18. That PLAINTIFF alleges that the loan on the subject Property was

procured by fraud.

19. That PLAINTIFF ANTOINE BACHA alleges CIT GROUP CONSUMER FINANCE, INC.

And MARIX SERVICING LLC purported to Plaintiff to commence a foreclosure sale on

the Property and the claim of default was false.

20. I refer to and incorporate the docket of Case Number 30-2011-00489164,

a true and correct copy is attached hereto as Exhibit E, and incorporated herein

by this reference.

I refer to and incorporate the Notice Of Removal, of Case Number 30-2011-

00489164 a true and correct copy is attached hereto as Exhibit F, and

incorporated herein by this reference.

Antoine Bacha filed Notice Of Removal on November 16, 2011.On January 12, and 17, 2010 Judge Corey S. Cramin, held proceedings on a

case removed to bankrupty court - under the authorization of and without a lawful

order of remand under the authorization of Federal Rules of Bankruptcy Procedure

Rule 9027 - in the conspiracy to violate Antoine Bachas constitutional rights to

due process and to engage in the theft of possession of the property.

I am now proceeding in pro per. On January 11, 2012 the attorney Jeremey

Alberts who I had substituted to proceed in pro per, informed me that PD PROPERTY

INVESTMENTS, attorney had informed him that he had set an ex parte hearing on

January 12, 2012.

On January 12, 2012 the following occurred. I read from notes and stated,

In regard to the ExParte Motion - - - What is the irreparable harm done to

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their case and provable to the court that justifies moving the date for the motionto be heard outside of normal Civil Code procedures as required under theauthorization of Rule 3.1202 Paragraph C of the California Rules Of Court? Rule3.102 Paragraph C provides an applicant must make an affirmative factual showing ina declaration containing competent testimony based on personal knowledge ofirreparable harm, immediate danger, or any other statutory basis for grantingrelief ex parte,

There is no irrepreprable harm therefore there is no reason for this to beheard before February 2, 2012. This appearance is costing everyone time and moneyand this motion is in violation of Section 128.7 of the Code of Civil ProcedureParagraph 2 that are in force and effect, the claims defenses, and other legalcontentions therein are warranted by existing law and Paragraph 3 that theallegations and other factual contentions have evidentiary support, and the Rule ofProfessional Conduct They should be sanctioned for their bad faith andunprofessional acts and ordered by Order To Show Cause Why Sanctions Should Not BeImposed Under Code of Civil Procedure Section 128.7 for the Cost of the time andexpense and to refrain from unnecessarily bringing us into the courtroom.

At this point the court has no subject matter jurisdiction. There is nowritten, signed order by a federal district court judge.

The article I bankruptcy judge implicitly determined that the removedadversary proceeding was a non-core matter

As a result an article I bankruptcy judge is only authorized to issueproposed findings of fact and conclusion of law as a matter for final determinationby an article III judge.

28 U.S.C. Section 157. Procedures provides:

(a) Each district court may provide that any or all cases under title 11

and any or all proceedings arising under title 11 or arising in or related to acase under title 11 shall be referred to the bankruptcy judges for the district.

(c)(1) A bankruptcy judge may hear a proceeding that is not a coreproceeding but that is otherwise related to a case under title 11. In suchproceeding, the bankruptcy judge shall submit proposed findings of fact andconclusions of law to the district court, and any final order or judgment shall beentered by the district judge after considering the bankruptcy judge's proposedfindings and conclusions and after reviewing de novo those matters to which anyparty has timely and specifically objected.

Federal Rules Of Bankruptcy Procedure Rule 9033. Review of Proposed Findingsof Fact and Conclusions of Law in Non-Core Proceedings provides

(a) Service

In non-core proceedings heard pursuant to 28 U.S.C. 157(c)(1), thebankruptcy judge shall file proposed findings of fact and conclusions of law. Theclerk shall serve forthwith copies on all parties by mail and note the date ofmailing on the docket.

Thus the order of the judge is at most a proposed finding of fact andconclusion of law for final determination by article III federal district judge.

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Therefore any order is not a final order it is only a proposed order on a non-core issue. It needs to be heard by the federal district judge to be a finalorder.

In addition the Due Process Clause of 5th, 6th and 14th Amendment of theUnited States Constitution requires Notice and a Hearing, the order to remand wasentered by Article I, Judge Erithe Smith without Notice and a Hearing. And I wasnot given notice, adequate opportunity to prepare a response, an opportunity toobject, to file pleadings and raise relevant issues, and a non arbritrarily norcapriciously decided order but one based on established facts at a hearing and inauthorization of settled law. See Williams v. Tooke, (1940) 108 F.2d 758.

In In Re Center Wholesale, Inc., 759 F.2d 1440, at page 1448, (9th CircuitCalifornia, May 10, 1985), the court held, that, a judgment is void, if the courtthat rendered judgment lacked jurisdiction of the subject matter, or of theparties, or if the court acted in a manner inconsistent with due process of law.

There is no written, signed order by a federal district court judge. Thiscourt has no subject matter jurisdiction. Ruling on this matter at this time would

not only constitute the public offense of treason but is also a violation ofconstitutional rights. This violation of law would entitle the victim to seekdamages.

The Judge stated, about not being clear on the intricacies of rules oforders and federal or bankruptcy judges. But that it did not matter to him becausehe works off of proposed orders and dockets all the time. Therefore the federaland bankruptcy rules do not apply.

While I was reading the foregoing, part challenging the validity of the exparte hearing being brought before the court The judge cut him off after twosentences. The judge told Antoine that these were not the issues that mattered.

At no time did Steven D. Silverstein state with admissible evidence thegrounds for irreparable harm.

After reading the foregoing, the judge stated that that does not apply hereand set the hearing The judge set motion to hear the MSJ on 1/19/2012 instead of2/2/2012.

On January 19, 2012 I filed a statement of disqualification after having

found, of several acts that Corey Cramin has undertaken that are in violation of

the law. I refer to and incorporate the Statement of Disqualification and

supporting evidentiary exhibits filed on January 19, 2012 a true and correct copy

is attached hereto as Exhibit G, and incorporated herein by this reference. On

January 26, 2012, Corey Cramin struck the Statement Of Disqualification. In U.S.

v. Garrudo, 869 F.Supp. 1574, 1581 (S.D.Fla.,Sep 09, 1994) court stated, It seems

clear to this court that the average person on the street will believe that if a

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federal judge is the subject of a criminal investigation, then that individual

cannot conduct trials impartially. I refer to and incorporate the Order Striking

Challenge For Cause And Verified Answer Of Judge Corey S. Cramin filed on January

26, 2012 a true and correct copy is attached hereto as Exhibit H, and

incorporated herein by this reference. At page 4, line 3 Corey Cramin, quotes

and falsely attributes as the authors statement Rothman in the California Judicial

Conduct Handbook, A judge is not disqualified simply because a participant in a

case complains to the Fair Political Practices Commission while proceedings are

pending, See Rothman, California Judicial Conduct Handbook 7.60 citing California

Judges Association, Judicial Ethics Update (2001)p.4 I refer to and incorporate

The pages from Rothman, California Judicial Conduct Handbook 7.60 a true and

correct copy is attached hereto as Exhibit I and incorporated herein by this

reference.

At p. 372. Rothman states A judge is not disqualified in a matter wherean attorney has complained to the Commission on Judicial Performance about thejudge, 285 unless the judge is actually biased against the lawyer of the party as aresult of the actions.

COUNT ONE21. At all times the rights of persons within the

jurisidiction of the United States of America under Amendment V, to

procedural and substantive due process of law was in force and effect,

including the right to notice and opportunity to be heard. The

opportunity to present evidence, before an impartial tribunal having

jurisdiction of the cause, fundamental fairness, access to the courts,

The right to be free from arbitrary and capricious acts, (Williams v.

Tooke, 108 F.2d 758 (C.C.A.5 (Tex.),Jan 09, 1940))

And any defendant who violated those Fifth Amendment rights, thereby

violated the Fourteenth Amendment to the United States Constitution,

and entitles plaintiff to recover damages pursuant to 42 U.S.C. 1983.

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Defendants conduct proximately caused harm to plaintiff.

State of California has and fosters a policy in violating the

Fourteenth Amendment right to due process and took no action to

correct it.

22. That as a direct proximate result of the acts and

ommissions of the DEFENDANTS, and each of them, PLAINTIFF has been

damaged in the amount of at least $20,000,000, according to proof at

trial.

PRAYER FOR RELIEFWHEREFORE, Plaintiffs Antoine Bacha demand and pray for judgment to be

entered in their favor and against Defendants as follows:

1. On Count I, a finding that the acts and omissions of

DEFENDANTS, and each of them, was in violation of 42. U.S.C. 1983 and

is therefore contrary to law.

2. An Entry directing DEFENDANTS, and each of them to

A. Pay $20,000,000 to Plaintiff

B. Pay interest at the statutory rate from January 31, the dateof filing of this Complaint.

3. An injunction on the continuing activities of DEFENDANTS,

THE CIT GROUP CONSUMER FINANCE INC. Steven D. Silverstan, Corey S.

Cramin. And each of them in the underlying matter.

4. Provide Plaintiffs any and all other relief that the Court

deems just and proper.

Dated: January 31, 2012

________________________________

ANTOINE BACHAPLAINTIFF, In pro per

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EXHIBIT A

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EXHIBIT B

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EXHIBIT C

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EXHIBIT D

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EXHIBIT E

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EXHIBIT F

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EXHIBIT G

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EXHIBIT H

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EXHIBIT I

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PROOF OF SERVICE

STATE OF CALIFORNIA, COUNTY OF ORANGE:

I am employed in the County of Orange, State of California.I am over the age of 18 and not a party to the within action;my address is 210 White Cape Lane, Newport Beach, CA 92656.

On November 15, 2011, I served the foregoing documentdescribed as:

NOTICE OF REMOVAL UNDER THE AUTHORIZATION OF TITLE 28 UNITEDSTATES CODE SECTION 1452, RULE 9027 OF THE FEDERAL RULES OFBANKRUPTCY PROCEDURE

on the interested parties in this action by placing truecopies thereof enclosed in (a) sealed envelope(s) addressedas follows:

Office of the United States Trustee411 West Fourth Street, Suite 9041Santa Ana, California 92701-8000

Chapter 13 Trustee, Amrane Cohen770 The City Drive South, Suite 3300

Orange, California 92868

BARRY LEE OCONNOR, ESQUIRE, STATE BAR NO. 134549BARRY LEE OCONNOR, & ASSOCIATESA PROFESSIONAL LAW CORPORATION3691 ADAMS STREETRIVERSIDE, CALIFORNIA 92504

I deposited this envelope in the United States Postal ServiceMail at Newport Beach, California. The envelope was mailedwith first class postage thereon fully prepaid.

I declare under penalty of perjury under the laws of the Stateof California that the foregoing is true and correct.

___ Carrie Strand______ ___________________________Signature

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EXHIBIT A

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plead paper flow bk pleading paper 42 usc 1983 cramin

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