1:4. DefendantsPrivate individuals and state action..., 1 State and Local...

2012 Thomson Reuters. No claim to original U.S. Government Works. 1

1 State and Local Government Civil Rights Liability 1:4 (2d ed.)

State and Local Government Civil Rights Liability Database updated December 2011

Ivan E. Bodensteiner; Rosalie Berger Levinson

Chapter 1. Protecting Federal Rights under Section 1983 II. Coverage

Summary

1:4. DefendantsPrivate individuals and state action requirement

In addition to creating a cause of action against government officials, it is possible to bring suit against private individuals under 1983 either because their conduct is deemed to be state action or because they have conspired with government officials. As to the first theory, because most 1983 claims assert constitutional rights that entail a state action requirement, the under the color of law issue and the state action issue often merge.1 The Supreme Court has stated that where private individuals meet the state action requirement of the Fourteenth Amendment they will be deemed to be acting under the color of state law for purposes of 1983.2 In Flagg Bros., Inc. v. Brooks,3 a creditor acting pursuant to the U.C.C. self-help provision seized the plaintiffs property allegedly in violation of the Fourteenth Amendment Due Process Clause. Although an individual exercising his rights under state law is acting under the color of state law, the Court held that there was no Fourteenth Amendment state action. Several subsequent Supreme Court decisions have further limited the concept of state action by refusing to attribute private conduct to the state despite significant government involvement with the private entity.4 This trend is reflected in several lower court opinions holding that neither state regulation nor funding of a private entity will convert its conduct into state action.5 Further, neither government approval or acquiescence in the private conduct will suffice.6

Although the Supreme Court has been generally reluctant to treat the action of private parties as that of the state for purposes of the Fourteenth Amendment, and it has been less than clear in articulating a coherent doctrine, a review of Supreme Court precedent indicates that private parties may be sued under 1983 under the following theories: (1) Joint Participation: In Lugar v. Edmondson Oil Co.,7 the Supreme Court set forth a two-part test

whereby private individuals who act in joint participation with government officials will be considered state actors.

First, the Court explained that the deprivation must be caused by the exercise of some right or privilege

created by the State or by a rule of conduct imposed by the State or by a person for whom the State is

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2012 Thomson Reuters. No claim to original U.S. Government Works. 2

responsible.8 Second, the defendant must fairly be said to be a state actor.9 As to the latter, the Court inquires into

whether the defendant has acted together with or has obtained significant aid from state officials.10 The Lugar analysis was applied in Edmonson v. Leesville Concrete Co.11 to hold that a private litigants

race-based exercise of peremptory jury challenges in a civil action constitutes governmental action. Applying the Lugar standard several lower courts have found that private individuals or entities may be

viewed as state actors because of their involvement with government officials.12 On the other hand, many federal courts applying the Lugar analysis have concluded that a defendants action

was not attributable to the state.13 In several of these cases, it was held that the private individual did not truly act in concert with government officials.

For example, the mere fact that a private citizen files a complaint with the police department or asks that an

individual be arrested does not, without more, constitute the type of concerted activity required by Lugar.14 The Supreme Court decision in NCAA v. Tarkanian lends support to this narrow approach. The fact that the

NCAA promulgated regulations governing the state universitys athletic program, investigated alleged violations on the part of the university, and concluded that the university had to suspend its basketball coach or face sanctions did not justify the state Supreme Courts conclusion that the NCAA was acting under the color of state law.15

Reasoning that the NCAA and the state university acted more like adversaries than like partners, the Court

rejected the joint participation theory.16 (2) Conspiracy: The Supreme Court has held that where private individuals enter into a conspiracy with state

officials to deprive persons of their rights, they may be joined as defendants. In fact the Court held in Dennis v. Sparks17 that a private citizen who bribes a judge may be sued under

1983 even though in that situation the judge himself enjoyed absolute immunity from suit.18 Further, in Tower v. Glover19 it was held that although the actions of a public defender do not subject him to

liability, a public defender who conspires with state officials will be deemed to be acting under the color of law.20

Similarly, although federal officials may not be sued under 1983, federal officials acting in concert with

state authorities may be sued.21 Counsel should be cautioned that although the requirements of a conspiracy are fairly stringent, private

individuals who fit within the joint participation theory of state action may also be sued under 1983.22 Because of the overlap between the doctrines, some lower courts have narrowly construed the joint

participation theory to require a conspiratorial type of relationship between the state and the private parties.23

Others, however, have explicitly rejected the notion that evidence of a conspiracy is needed in order to sue private individuals whose conduct is deemed to be state action.24

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2012 Thomson Reuters. No claim to original U.S. Government Works. 3

(3) Compulsion or Significant Encouragement: Although, as noted, government approval or acquiescence in private conduct will not transform this conduct into state action, where the state actually compels the private party to engage in the proscribed conduct, 1983 liability will be triggered.25

(4) Government Function: The Supreme Court has held that a private party will be deemed a state actor

where it performs an exclusive, traditional public function.26 On the other hand, the Supreme Court has narrowly construed this doctrine to exclude private entities that

provide utility service,27 medical assistance,28 or education.29 Relying on the public function doctrine, lower courts have ruled that volunteer firefighters should be viewed

as state actors.30 Similarly, private parties who assist the police in carrying out their investigative functions will be bound by

constitutional norms.31 More difficult are the cases involving private entities who contract with the government to carry out official

functions. Because the government is increasingly privatizing the operation of jails and prisons, these cases are proliferating. In West v. Atkins32 the Supreme Court held that a private physician under contract with the state to provide medical services at a state hospital is acting as a state actor for purposes of 1983.

Generally, where the government contracts out official functions that implicate statutory or constitutional

duties, state action will be found.33 On the other hand, several cases have held that those who contract with the state to carry out state-sponsored

programs or to perform public functions do not necessarily become state actors for all of their conduct.34 Further, note that even where private parties are acting under the color of state law, difficult questions

remain as to whether private individuals or entities will be shielded by the defenses that protect government officials and entities.35

(5) Symbiotic Relation/Entwinement: The Supreme Court has ruled that where a private party enters into a

symbiotic relationship with the government, state action will be found. In Burton v. Wilmington Parking Authority,36 a private owner of a restaurant who leased space from a

governmental agency and who refused to serve African-Americans was held subject to suit under 1983 where both the government and the restaurant benefited from the lease arrangement.

The Court focused on the states overall relationship with the private actor and determined that the state had

insinuated itself into a position of interdependence with the private party.37 Since this 1961 case, the Supreme Court has never again relied on the symbiotic relationship doctrine to

support a finding of state action. Similarly, lower courts have consistently distinguished and narrowed Burton as a case where the government

was actually profiting from the racially discriminatory practices of the restaurant.38 Although the symbiotic relationship theory appears dead, the Supreme Court in Brentwood Academy v.

Tennessee Secondary School Athletic Association39 held that a nominally private statewide voluntary

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2012 Thomson Reuters. No claim to original U.S. Government Works. 4

association that governs sports among public and private secondary schools was a state actor because of the pervasive entwinement of public institutions and public officials.

The Court relied on several factorspublic schools predominated in the membership of the organization at

the time of the incident in question, public school officials held all slots on the governing bodies, members of the State Board of Education were assigned ex officio to serve as members of the governing bodies, and the organizations employees were eligible for membership in the state retirement system.

Further, the Court noted that there were no substantial countervailing reasons not to apply constitutional

standards to the Associations actions.40 Some lower courts have relied on Brentwoods entwinement theory to find state action.41 However, in many

cases the fact-intensive inquiry demanded by Brentwood has resulted in findings of insufficient evidence to support entwinement,42 or

(6) Judicial Intervention: In Shelley v. Kraemer43 the Supreme Court found state action where white

property owners sued in a state court to enforce a racially restrictive covenant and thus stop a sale between a willing buyer and seller.

The Court reasoned that the state court had interjected itself into the private dispute such that the judiciary

became the efficient, effective cause of the adverse treatment, thus subject to Fourteenth Amendment restrictions.44

Subsequent rulings have limited Shelley to its unique facts, namely judicial enforcement of racially restrictive

covenants.45

Practice Tip:

Although, as discussed earlier in this section, private individuals or entities may sometimes be sued as defendants under 1983, the rules governing liability of private entities is less certain. As discussed in 2:1 to 2:5, government officials may enjoy absolute or qualified immunity from damages. Further, as discussed in 1:6, 1:7, government entities cannot be held liable unless the injury was inflicted pursuant to a policy or custom and they are shielded from punitive damages. See 2:8. On the other hand, they do not enjoy qualified immunity. See 2:7. The Supreme Court in two cases, Wyatt v. Cole46 and Richardson v. McKnight,47 has ruled that private individuals do not enjoy the qualified immunity available to government defendants. It has not, however, provided guidance regarding private entities. Generally the lower courts have ruled that private entities are liable only if a policy or custom can be established.48 There is disagreement, however, on the immunity issue. While some courts have extended the Supreme Court rule denying municipal immunity to private entities,49 others have decided to award private defendants a good faith defense.50 There has been little discussion as to whether punitive damages should be available to private entities.51

Westlaw. 2011 Thomson Reuters. No Claim to Orig. U.S. Govt. Works.

Investigative Reporting, News, Analysis, Opinion & Satire

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Sacramento Family Court News Exclusive Investigative ReportThis investigative report is ongoing and was last updated in April, 2015.

As many of the articles on our main page reflect, Sacramento Family Law Court whistleblowers and watchdogs contend that a "cartel" of local family law attorneys receive kickbacks and other forms of preferential treatment from family court judges, administrators and employees because the lawyers are members of the Sacramento County Bar Association Family Law Section, hold the Office of Temporary Judge, and run the family court settlement conference program on behalf of the court.

The kickbacks usually consist of "rubber-stamped" court orders which are contrary to established law, and cannot be attributed to the exercise of judicial discretion. For a detailed overview of the alleged collusion between judge pro tem attorneys and family court employees and judges, we recommend our special Color of Law series of investigative reports.

The Color of Law series reports catalog some of the preferential treatment provided by family court employees and judges to SCBA Family Law Section judge pro tem lawyers. Click here to view the Color of Law series. For a list of our reports about family court temporary judges and controversies, click here.

The current day Sacramento County Family Court system and attorney operated settlement conference program was set up in 1991 by and for the lawyers of the Sacramento County Bar Association Family Law Section,

Sacramento Superior Court Temporary Judge Program Controversy

Judge Pro Tem Attorney "Cartel" Controls Court Operations, Charge Whistleblowers

Sacramento Family Court reform advocates assert that collusion between judges and local attorneys deprives financially disadvantaged, unrepresented pro per court users of their parental rights, community assets, and due process and access to the court constitutional rights.

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according to the sworn testimony of controversial family court Judge Peter J. McBrien at his 2009 Commission on Judicial Performance disciplinary proceedings. Click here to read Judge McBrien's testimony.

In his own testimony during the same proceedings, local veteran family law attorney and judge pro tem Robert J. O'Hair corroborated McBrien's testimony and attested to McBrien's character and value to Sacramento County Bar Association Family Law Section members. Click here to view this excerpt of O'Hair's testimony. To view O'Hair's complete testimony, click here.

Court watchdogs assert that the settlement conference kickback arrangement between the public court and private sector attorneys constitutes a racketeering enterprise which deprives the public of the federally protected right to honest government services.

Court reform and accountability advocates assert that the local family law bar - through the Family Law Executive Committee or FLEC - continues to control for the financial gain of members virtually all aspects of court operations, and have catalogued documented examples of judge pro tem attorney preferential treatment and bias against unrepresented litigants and "outsider" attorneys, including:

Divorce Corp, a documentary film that "exposes the corrupt and collusive industry of family law in the United States" was released in major U.S. cities on January 10, 2014. After a nationwide search for the most egregious examples of family court corruption, the movie's production team ultimately included four cases from Sacramento County in the film, more than any other jurisdiction. Judge pro tem attorneys Charlotte Keeley, Richard Sokol, Elaine Van Beveren and Dianne Fetzer are each accused of unethical conduct in the problem cases included in the movie. The infamous Carlsson case, featuring judge pro tem attorney Charlotte Keeley and Judge Peter McBrien is the central case profiled in the documentary, with Sacramento County portrayed as the Ground Zero of family court corruption and collusion in the U.S. Click here for our complete coverage of Divorce Corp.

Judge Thadd Blizzard issued a rubber-stamped, kickback order in November, 2013 for judge pro tem attorney Richard Sokol authorizing an illegal out-of-state move away and child abduction by Sokol's client, April Berger. The opposing counsel is an "outsider" attorney from San Francisco who was dumbfounded by the order. Click here for our exclusive report, which includes the complete court reporter transcript from the hearing. Click here for our earlier report on the unethical practice of "hometowning" and the prejudicial treatment of outsider attorneys.

Whistleblower leaked court records indicate that Sacramento Bar Association Family Law Executive Committee officer and judge pro tem attorney Paula Salinger engaged in obstruction of justice crimes against an indigent, unrepresented domestic violence victim. The victim was a witness in a criminal contempt case against a Salinger client. The circumstances surrounding the obstruction of justice incident also infer collusion between Salinger and controversial Judge Matthew J. Gary. For our complete investigative report, click here.

Two "standing orders" still in effect after being issued by Judge Roland Candee in 2006 override a California Rule of Court prohibiting temporary judges from serving in family law cases where one party is self-represented and the other party is represented by an attorney or is an attorney. The orders were renewed by Presiding Judge Laurie M. Earl in February, 2013. Click here for details.

Sacramento Family Court judges ignore state conflict of interest laws requiring them to disclose to opposing parties when a judge pro tem working as a private attorney represents a client in family court. Click here for our exclusive investigative report. Click here for a list of other conflict of interest posts.

Family court policies and procedures, including local court rules, are dictated by the SCBA Family Law Executive Committee for the financial benefit of private sector attorneys, and often disadvantage the 70 percent of court users without lawyers, according to family court watchdogs and whistleblowers. For example, in sworn testimony by Judge Peter McBrien before the Commission on Judicial Performance, McBrien described seeking and obtaining permission from FLEC to change a local rule. Click here and here.

In November, 2012 Sacramento Family Court Judge Jaime R. Roman issued a rubber-stamped, kickback order declaring a family court party a vexatious litigant and ordering him to pay $2,500 to the opposing attorney, both without holding the court hearing required by law. The opposing attorney who requested the orders is Judge Pro Tem Charlotte Keeley. The blatantly illegal orders resulted in both an unnecessary state court appeal and federal litigation, wasting scarce judicial resources and costing taxpayers significant sums. Click here for our exclusive coverage of the case.

Judge Matthew Gary used an unlawful fee waiver hearing to both obstruct an appeal of his own orders and help a client of judge pro tem attorney Paula Salinger avoid paying spousal support. Click here for our investigative report.

An unrepresented, disabled 52-year-old single mother was made homeless by an illegal child support order issued by Judge Matthew Gary for SCBA Family Law Section attorney Tim Zeff, the partner of

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temporary judge Scott Buchanan. The rubber-stamped, kickback child support order, and other proceedings in the case were so outrageous that the pro per is now represented on appeal by a team of attorneys led by legendary trial attorney James Brosnahan of global law firm Morrison & Foerster. For our exclusive, ongoing reports on the case, click here.

Judge pro tem attorneys Richard Sokol and Elaine Van Beveren helped conceal judge misconduct and failed to comply with Canon 3D(1) of the Code of Judicial Ethics when they were eyewitnesses to an unlawful contempt of court and resisting arrest incident in Department 121. Both Sokol and Van Beveren failed to report the misconduct of Judge Matthew Gary as required by state law. Van Beveren is an officer of the SCBA Family Law Executive Committee. Click here for our exclusive report...

...Four years later, Sokol and Van Beveren in open court disseminated demonstrably false and misleading information about the unlawful contempt of court and resisting arrest incident. The apparent objective of the judge pro tem attorneys was to discredit the victim of Gary's misconduct, trivialize the incident, and cover up their own misconduct in failing to report the judge. For our follow-up reports, click here. In 2014, a video of the illegal arrest and assault was leaked by a government whistleblower. Click here for details.

In 2008 controversial family court Judge Peter J. McBrien deprived a family court litigant of a fair trial in a case where the winning party was represented by judge pro tem attorney Charlotte Keeley. In a scathing, published opinion, the 3rd District Court of Appeal reversed in full and ordered a new trial. 6th District Court of Appeal Presiding Justice Conrad Rushing characterized McBrien's conduct in the case as a "judicial reign of terror." McBrien subsequently was disciplined by the Commission on Judicial Performance for multiple acts of misconduct in 2009. Click here to read the court of appeal decision. Click here to read the disciplinary decision issued by the CJP.

Judge pro tem attorneys Camille Hemmer, Robert O'Hair, Jerry Guthrie and Russell Carlson each testified in support of Judge Peter J. McBrien when the controversial judge was facing removal from the bench by the Commission on Judicial Performance in 2009. As a sworn temporary judges aware of McBrien's misconduct, each was required by Canon 3D(1) of the Code of Judicial Ethics to take or initiate appropriate corrective action to address McBrien's misconduct. Instead, each testified as a character witness in support of the judge. In the CJP's final disciplinary decision allowing McBrien to remain on the bench, the CJP referred specifically to the testimony as a mitigating factor that reduced McBrien's punishment. Click here. Court records indicate that Judge McBrien has not disclosed the potential conflict of interest to opposing attorneys and litigants in subsequent appearances by the attorneys in cases before the judge. Click here for SFCN coverage of conflict issues.

Judge pro tem attorneys Terri Newman, Camille Hemmer, Diane Wasznicky and Donna

Reed were involved in a proposed scheme to rig a recall election of controversial Judge Peter J. McBrien in 2008. The plan involved helping McBrien defeat the recall by electing him "Judge of the Year" before the November election. Click here for the Sacramento News and Review report.

Judge pro tem attorney Robert J. O'Hair testified as a character witness for controversial Judge Peter J. McBrien at the judge's second CJP disciplinary proceeding in 2009. Paula Salinger, an attorney at O'Hair's firm, Woodruff, O'Hair Posner & Salinger was later granted a waiver of the requirements to become a judge pro tem. A family court watchdog asserts the waiver was payback for O'Hair's testimony for McBrien. Click here to read our exclusive investigative report.

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In cases where one party is unrepresented, family court clerks and judges permit judge pro tem attorneys to file declarations which violate mandatory state court rule formatting requirements. The declarations - on blank paper and without line numbers - make it impossible for the pro per to make lawful written evidentiary objections to false and inadmissible evidence. Click here for our report documenting multiple state court rule violations in a motion filed by SCBA Family Law Section officer and temporary judge Paula Salinger. To view the pro per responsive declaration objecting to the illegal filing click here, and click here for the pro per points & authorities.

Family court clerks and judges allow judge pro tem attorneys to file a fabricated "Notice of Entry of Findings and Order After Hearing" in place of a mandatory Judicial Council Notice of Entry of Judgment FL-190 form. The fake form omits critical appeal rights notifications and other information included in the mandatory form. Click here for our exclusive report.

Sacramento Family Court temporary judge and family law lawyer Gary Appelblatt was charged with 13-criminal counts including sexual battery and penetration with a foreign object. The victims were clients and potential clients of the attorney. The judge pro tem ultimately pleaded no contest to four of the original 13-counts, including sexual battery, and was sentenced to 18-months in prison. Court administrators concealed from the public that Appelblatt held the Office of Temporary Judge.Click here to read our report.

Judge pro tem and SCBA Family Law Section attorney Scott Kendall was disbarred from the practice of law on Nov. 24, 2011. Kendall was disbarred for acts of moral turpitude, advising a client to violate the law, failing to perform legal services competently, and failing to keep clients informed, including not telling a client about a wage garnishment order and then withdrawing from the same case without notifying the client or obtaining court permission. Court administrators concealed from the public that Kendall held the Office of Temporary Judge. Click here to view our report.

Judge pro tem attorneys Nancy Perkovich and Jacqueline Eston in 2008 helped Donna Gary - the wife of Judge Matthew J. Gary - promote and market ClientTickler, a client management software program for attorneys. The judge reportedly has never disclosed the conflict of interest as required by the Code of Judicial Ethics. Click here for our exclusive report on the controversy.

In February, 2013 the website of family law firm Bartholomew & Wasznicky cut off the public from the only online access to The Family Law Counselor, a monthly newsletter published by the Sacramento Bar Association Family Law Section. Lawyers at the firm include judge pro tem attorneys Hal Bartholomew, Diane Wasznicky and Mary Molinaro. As SFCN has reported, articles in the newsletter often reflect an unusual, collusive relationship between SCBA attorneys and court administrators and judges. Click here for our report.

Family court reform advocates assert that judge pro tem attorneys obtain favorable court rulings on disputed issues at a statistically improbable rate. The collusion between full-time judges and judge pro tem attorneys constitutes unfair, fraudulent, and unlawful business practices, all of which are prohibited under California unfair competition laws, including Business and Professions Code 17200, reform advocates claim.

Unfair competition and the collusion between judges and judge pro tem attorneys ultimately results in unnecessary appeals burdening the appellate court system, and other, related litigation that wastes public funds, exposes taxpayers to civil liability, and squanders scarce court resources.

Watchdogs point out that the court operates what amounts to a two-track system of justice. One for judge pro tem attorneys and another for unrepresented, financially disadvantaged litigants and "outsider attorneys." Two-track systems are prohibited by the Code of Judicial Ethics, according to the Commission on Judicial Performance and the California Judicial Conduct Handbook, the gold standard reference on judge misconduct. Click here for articles about the preferential treatment given judge pro tem attorneys. Click here for examples of how pro pers are treated.

After representing a client in Sacramento Family Court, San Francisco attorney Stephen R. Gianelli wrote "this is a 'juice court' in which outside counsel have little chance of prevailing...[the] court has now abandoned even a pretense of being fair to outside counsel." Click here to read Gianelli's complete, scathing account.

The Sacramento County Bar Association Family Law Section is led by an "Executive Committee" ("FLEC") of judge pro tem attorneys composed of Chair Russell Carlson, Vice Chair Elaine Van Beveren, Treasurer Fredrick Cohen and Secretary Paula Salinger. Three of the four have been involved in legal malpractice litigation, violations of the Code of Judicial Ethics, or as a defendant in federal civil rights litigation. Click here to read SFCN profiles of the Executive Committee members. Click here for other articles about FLEC.

Judge pro tem attorneys are by law required to take or initiate corrective action if they learn that another judge has violated any provision of the Code of Judicial Ethics, or if a lawyer has violated any provision of the California Rules of Professional Conduct. Family court watchdogs assert that temporary judges regularly observe unethical and unlawful conduct by family court judges and attorneys but have never taken or initiated appropriate corrective action, a violation of the judge pro tem oath of

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office. To view the applicable Code of Judicial Ethics Canons, Click here. For a Judicial Council directive about the obligation to address judicial misconduct, a critical self-policing component of the Code of Judicial Ethics, click here.

For information about the role of temporary judges in family court, click here. For official Sacramento County Superior Court information about the Temporary Judge Program click here. Using public records law, Sacramento Family Court News obtained the list of private practice attorneys who also act as judge pro tems in Sacramento Family Law Court. Each lawyer on the list below is currently a temporary judge, or was a temporary judge in 2009, 2010, 2011, 2012 or 2013. SFCN cross-checked each name on the Sacramento County judge pro tem list with California State Bar Data. The first name in each listing is the name that appears on the Sacramento County judge pro tem list, the second name, the State Bar Number (SBN), and business address are derived from the official State Bar data for each attorney. The State Bar data was obtained using the search function at the State Bar website.

For-profit, private sector lawyers who also hold the Office of Temporary Judge:

Sandy Amara, Sandra Rose Amara, SBN 166933, Law Office of Sandra Amara,1 California Street, Auburn, CA 95603.

Mark Ambrose, Mark Anthony Ambrose, SBN 141222, Law Offices of Mark A. Ambrose, 8801 Folsom Blvd. Ste. 170, Sacramento, CA 95826. Ambrose unethically advertises himself as a temporary judge.

Kathleen Amos, Kathleen Swalla Amos, SBN 112395, Attorney at Law & Mediator, 206 5th Street, Ste. 2B Galt, CA 95632.

Gary Appelblatt, Gary Michael Appelblatt, SBN 144158, 3610 American River Drive #112, Sacramento, CA 95864. Appelblatt was disbarred by the State Bar on Sept. 24, 2010 after being convicted of sexual battery against clients. Click here for our exclusive report. Appelblatt is a graduate of McGeorge School of Law.

Beth Appelsmith, Beth Marie Appelsmith, SBN 124135, 1430 Alhambra Blvd. Sacramento CA 95816.

Bunmi Awoniyi, Olubunmi Olaide Awoniyi, SBN 154183, Law Office of Bunmi Awoniyi a PC, 1610 Executive Ct. Sacramento, CA 95864. Awoniyi unethically advertises herself as a temporary judge. Awoniyi was appointed a Superior Court Judge in December 2012 and holds court in Department 120 of Sacramento Family Court.

Alexandre C. Barbera, C. Alexandre Barbera, SBN 70071,915 Highland Point Drive, Ste. 250 Roseville, CA 95678.

A number of family court whistleblowers have leaked court records indicating that judge pro tem attorneys receive from

judges kickbacks and other preferential treatment in exchange for operating the family court settlement conference program.

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RULES (4) COURTS (1) CPG FAMILY LAW (1)

CRIMINAL LAW (3) CRONYISM (2)DAVID KAZZIE (4) DEMOTION

(1) DENISE RICHARDS (1)DIANE WASZNICKY (2)DISQUALIFICATION (2)

DONALD TENN (3) DONNA GARY (2) DSM-301.7 (1)

EDITORIAL (1) EDWARD FREIDBERG (2) EFF (2)

EFFICIENCY IN GOVERNMENT AWARD (1)

ELECTIONS (1) EMILY GALLUP (3)EMPLOYEE CODE OF ETHICS

(4)

EQUAL PROTECTION (2)EUGENE L. BALONON (1)

EVIDENTIARY OBJECTIONS (2) EX PARTE (1) F4J (4)

FAMILY COURT AUDITS (1) FAMILY COURT CONDITIONS (2)FAMILY COURT MEDIA COVERAGE

(1) FAMILY COURT PROCEDURE (1) FAMILY COURT SACRAMENTO (2) FAMILY

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