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Jose Castaneda P. O. Box 947 Pasadena, CA. 91102 (626)296-9136

SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES


Case No. : GC 042105 ) Jose Castaneda ) Plaintiffs ) ) vs. ) ) ) Ramirez Et Al, ) Does 1-10 ) Plaintiffs. ) _________________________________) NOTICE OF MOTION AND MOTION TO PLACE JUDGE JOSEPH DEVANON UNDER OATH AND TO RESPOND TO ALL 35 INTERROGATORIES HEREIN AS HE ABUSES HIS DISCRETION AND ALLOWS ATTORNEY LISA MARIE MACCARLEY TO LIE, CHEAT, STEAL AND USE THE PEOPLES COURT TO COMMIT THEFT FROM THE ESTATE OF FELICITAS CASTANEDA Date: January 12, 2012 Time: 8:30 am Dept: S

TO ALL INTERESTED PARTIES, TO THE STATE OF CALIFORNIA AND THEIR ATTORNEY OF RECORD: TAKE NOTICE THAT on February 12, 2012, at 8:30 am, or as soon thereafter as the matter may be heard, in Department S of this Court, located at 300 E. Walnut Street, Pasadena California 91101, Jose Castaneda will hereby Moves this Court, presided by Judge DeVanon, he will stand up from his presiding chair, and be administered the Oath and respond to all 35 special interrogatories presented as follows:

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Jose Castaneda P. O. Box 947 Pasadena, CA. 91102 (626)296-9136

SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES


Case No. : GC 042105 ) Jose Castaneda ) Plaintiffs ) ) vs. ) ) ) Ramirez Et Al, ) Does 1-10 ) Defendants. ) _________________________________) SPECIAL INTERROGATORIES PROPOUNDED TO DEFENDANT JOSEPH F. DEVANON SET ONE Dept: S Date: January 12, 2012 Time: 8:30 a.m.

PROPOUNDING PARTY: RESPONDING PARTY: SET No:

Plaintiff, JOSE CASTANEDA Defendant, Joseph F. DeVanon ONE

Pursuant to the provisions of Code of Civil Procedure 2030, Plaintiff Jose Castaneda, requests, demands and Moves the Court to force that Defendant, Joseph F. DeVanon to tell the truth, and answer under oath the following Special Interrogatories within 35 days from date of service of these interrogatories.

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SPECIAL INTERROGATORY NO. 1: Regarding Case Number GC 042105, Case Name Ramirez v. Castaneda, held on February 22, 2010, in Reporters Transcript by Sharon Boyer, state each and every fact and detail which you base the contention: THE MATTER IS ON TODAYS DATE FOR MOTION AND TRIAL. THERE IS SOME CONFUSION THIS MORNING WHEN I CALLED THE CASE MR. SEVAG NIGOGHOSIAN ANNOUNCED HE WAS MAKING A SPECIAL APPEARANCE FOR AN ATTORNEY. HE WISHED TO SUBSTITUTE IN ON THE CASE. BUT THAT THAT ATTORNEY WAS NOT PRESENT TODAYS DATE. AND ALTHOUGH I GUESS MR. NIGOGHOSIAN INDICATED HE WAS FILING, OR THAT ATTORNEY WANTED TO HAVE LODGED WITH THE COURT A SUBSTITUTION OF COUNSEL, COUNSEL FOR PLAINTIFF INDICATES SHE HAD NOT RECEIVED IT, THE COURT HAD NOT RECEIVED IT, [R/T P. 1, L.19 -28] ARGUMENT TO 1 Can the Defendant explain his answer from the above statement in open court, when the MC-50 had been filed as confirmed by Court Clerk Charles Chuck Love. Judges have broad powers to grant extensions. Why didnt you, the Defendant take the time as a prudent person will do, and confirm that an MC-50 was actually filed? What is the harm in calling Mr. Love at his extension, or grant a 48 hour extension? The reason why you did not do is because you took a bribe, and in the process violated my Constitutional Rights! For proof that you actually took a bribe and that you were prejudice against me and my case, you did not grant the extension, nor did you research my answer, and instead you made me lose my case for a bribe. This is just 101 common sense?

SPECIAL INTERROGATORY NO. 2: Regarding Case Number GC 042105, Case Name Ramirez v. Castaneda, held on February 22, 2010, in Reporters Transcript by Sharon Boyer, state each and every fact and detail which you base the contention: THE COURT: I DONT KNOW ANYTHING ABOUT A RELATED MATTER. I HAVE NOT BEEN ADVISED OF ANY RELATED CASE, NOR RECEIVED NOTICE OF RELATED CASE. I DO HAVE A NUMBER OF TRIAL DOCUMENTS THAT YOU FILED,
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MR. CASTANEDA INCLUDING A WITNESS LIST AND AN EXHIBIT LIST. [R/T P. 3, L. 17 -21] ARGUMENT TO 2 You area Judge of the Court. You dont know anything about related matters, as you state above. Shouldnt you stop the trial as per your own statement, that you did not know anything? Why didnt you take the time to find out? Because you did not take the time to do your job, or doing correctly, I lost my case because you were in error, you took a bribe, and you were prejudice and discriminated against Jose Castaneda. for proof, as the judge of the Court, the person in charge, sworn to uphold the law and to use the truth, why didnt you seek the truth 48 hours or making a phone call!? Was the bribe more important than to impose proper justice? Why didnt you use again common sense and take the time to find out by calling Chuck Loves Extension to find out the answer and the truth? You did it because you took a bribe!?

SPECIAL INTERROGATORY NO. 3: Regarding Case Number GC 042105, Case Name Ramirez v. Castaneda, held on February 22, 2010, in Reporters Transcript by Sharon Boyer, state each and every fact and detail which you base the contention: THE COURT: --YOUR NOTICES. I JUST DONT KNOW WHAT TO DO WITH THIS ATTORNEY YOU SAY YOU HAVE RETAINED, WHO HAS NOT APPEARED. [R/T P. 4, L. 5 -7] ARGUMENT TO 3 Common sense dictates that if I had hired an attorney, you will grant an extension, and find out why? This is your job, also you Fiduciary duty and responsibility when a Citizens Rights are in question in your court!? Doesnt this negative conduct proves Dereliction of Duty, because you did not use common sense; and also proves that you took a bribe!?

SPECIAL INTERROGATORY NO. 4: Regarding Case Number GC 042105, Case Name Ramirez v. Castaneda, held on February 22, 2010, in Reporters Transcript by Sharon Boyer, state each and every fact and detail which you
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base the contention: I DONT KNOW HOW THE COURT OF APPEALS WOULD REVIEW OR CONSIDER MR. CASTANEDAS CLAIM THAT HE HAS HIRED AN ATTORNEY WHO HAS NOT COME TO REPRESENT HIM. [R/T P. 4, L. 25 -27] ARGUMENT TO 4 The Constitution grants me the right to an attorney, protection under the law, and Due Process! You admit and give a confession in court that HE HAS HIRED AN ATTORNEY WHO HAS NOT COME TO REPRESENT HIM If you know I hired an attorney, as guaranteed by the Constitution, why didnt you let me have representation as guaranteed by the Constitution?

SPECIAL INTERROGATORY NO. 5: Regarding Case Number GC 042105, Case Name Ramirez v. Castaneda, held on February 22, 2010, in Reporters Transcript by Sharon Boyer, state each and every fact and detail which you base the contention: WE ALREADY CONTINUE TRIAL ONCE. [R/T P. 5, L. 8 -9] ARGUMENT TO 5 My case has only one extension, and Jose Castaneda did not request that extension, yet you cannot grant me an extension to have ALL my evidence submitted to the court? You, Defendant Donavon, continued the case as a favor for MacCarley, which is a judicial bribe that violated my rights!? If this isnt true, why the case wasnt granted an extension, or a continuation, or even a phone call?! The reason why the court never made a cell phone call to the attorney was because the attorney did not want to return the bribe money!?

SPECIAL INTERROGATORY NO. 6: Regarding Case Number GC 042105, Case Name Ramirez v. Castaneda, held on February 22, 2010, in Reporters Transcript by Sharon Boyer, state each and every fact and detail which you base the contention: THE COURT: LETS NOT ARGUE THE MERITS OF THE CASE RIGHT NOW. WE TRYING TO DECIDE WHETHER THE CASE IS READY TO PROCEED TO TRIAL AND TRIAL, AND THE COURT IS READY TO GO TO TRIAL AND DENY THE REQUEST TO CONTINUE. [R/T P. 6, L. 9 -12]
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ARGUMENT TO 6 Why was denial for an extension not granted? This act or action proves that the court was discriminating against me, was prejudice, and was receiving a bribe from the opposing party. If this isnt true, why wasnt the extension granted, especially if I had nothing to do with the situation that happened in this court? This also proves prejudice! So, every time a person hires a dishonest attorney, who does not show up to court and violates my rights, your court engineers my case to be lost and sets me up for failure? Does this make any sense?

SPECIAL INTERROGATORY NO. 7: Regarding Case Number GC 042105, Case Name Ramirez v. Castaneda, held on February 22, 2010, in Reporters Transcript by Sharon Boyer, state each and every fact and detail which you base the contention: THE COURT: ALL RIGHT, SIR. HAVE A SEAT. WELL SEE TO IT YOU ARE SUPPLIED WITH ALL THE EXHIBITS DURING THE COURSE OF THE TRIAL. [R/T P. 6, L. 18 -20] ARGUMENT TO 7 Jose Castaneda filed many exhibits that were submitted to the court. Per the statement above, WELL SEE TO IT YOU ARE SUPPLIED WITH ALL EXHIBITS.. this proves that I did not get a fair trial, per the judges own statements. This proves Judge DeVanon had knowledge that Exhibits had been filed in case, but were withheld to make me lose my case. For proof that the court took a bribe, the judge admits that my exhibits were withheld, but still continues the case so that I cannot get a fair trial? What judge allows a person in court of law, knowing that there are exhibits to prove a case, but yet wont let him present his evidence? Judge DeVanon knows I have the proof, but wont let me submit the proof for a bribe! Why come to a court that accepts bribes, to hear my case that was engineered to be found guilty based on a bribe?

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SPECIAL INTERROGATORY NO. 8: Regarding Case Number GC 042105, Case Name Ramirez v. Castaneda, held on February 22, 2010, in Reporters Transcript by Sharon Boyer, state each and every fact and detail which you base the contention: THE COURT: I AM SORRY MR. COUNTS HAS DISAPPOINTED YOU, BUT THE CASE HAS ALREADY PREVIOUSLY CONTINUED FOR TRIAL. I CANT JUSTIFY CONTINUING IT ON THE BELIEF A LAWYER MAY COME IN SOME FUTURE DATE. [R/T P. 9, L. 14 -17] ARGUMENT TO 8 As you stated per statement the above, you admit the following: I AM SORRY MR. COUNTS HAS DISAPPOINTED YOU,.. Your honor, you are wrong! You disappointed me! If I paid for representation by an officer of the court, and you would not grant any extension, continuations, or any other considerations when it was not my fault and had nothing to do with the situation, why didnt you allow me to use the court properly, have fair representation, and allow me a fair trial!? Explain how your statement above is my fault? And I lose my case?

SPECIAL INTERROGATORY NO. 9: Regarding Case Number GC 042105, Case Name Ramirez v. Castaneda, held on February 22, 2010, in Reporters Transcript by Sharon Boyer, state each and every fact and detail which you base the contention: Q. WHEN DID YOU FIND OUT THAT YOU HAD BEEN GRANTED THE PROPERTY? ON THE DAY IS SIGNED THE DAY I AM NOT -- Q. LET ME SAY IT BETTER. DO YOU DID YOU PARTICIPATE IN A PREPARATION OF THIS DOCUMENT? A. YES, I DID. [R/T P. 15, L. 10 -16] ARGUMENT TO 9 If Alonso Castaneda admits that he participated in an illegal preparation of a Bona Fide Transfer of property to commit theft as stated above, doesnt this prove and verify that it is illegal to prepare a document that should only be prepared by a professional? He prepares and manufactures this document to commit fraud and theft, with attorney Lisa MacCarleys knowledge!
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SPECIAL INTERROGATORY NO. 10: Regarding Case Number GC 042105, Case Name Ramirez v. Castaneda, held on February 22, 2010, in Reporters Transcript by Sharon Boyer, state each and every fact and detail which you base the contention: THE COURT: CAN YOU TELL US APPROXIMATELY WHEN THAT WAS? THE COURT: YOU DONT REMEMBER WHICH YEAR IT WAS YOU CONTACTED - [R/T P. 16, L. 21 -22 AND 27 -28] ARGUMENT TO 10 If a witness on the stand cannot even remember of the year, to sell the property, this obviously must be a lie! Who cannot remember of any person of selling or losing their home in the whole United States! This proves it was a lie, but more disturbing is the court allowed the lie! For proof who forgets the year, the year the house was taken away? Not the exact date, but the year the house was taken away?

SPECIAL INTERROGATORY NO. 11: Regarding Case Number GC 042105, Case Name Ramirez v. Castaneda, held on February 22, 2010, in Reporters Transcript by Sharon Boyer, state each and every fact and detail which you base the contention: THE COURT: THE COURT WILL ASK THE QUESTION. DO YOU KNOW OF ANY PHONE RECORDS THE WITNESS: NO, I DO NOT. THE COURT: -VERIFY A TELEPHONE CALL? THE WITNESS: NO. I CALLED FROM MY CELLPHONE. [R/T P. 17, L. 23 -26] ARGUMENT TO 11 The question was asked in the court, DO YOU KNOW OF ANY PHONE RECORDS IF the answer is: NO. I CALLED FROM MY CELLPHONE WHICH LIE IS THE TRUTH? The witness states he does not make a phone call, but then he calls from his cell phone? Am I missing something here? Does this make any sense?

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SPECIAL INTERROGATORY NO. 12: Regarding Case Number GC 042105, Case Name Ramirez v. Castaneda, held on February 22, 2010, in Reporters Transcript by Sharon Boyer, state each and every fact and detail which you base the contention: THE COURT: DO YOU KNOW MR. JOSE CASTANEDAS NUMBER? THE COURT: WHEN YOU CALLED HIM, WHERE DID YOU GET THE NUMBER? THE WITNESS: I SPOKE WITH ALL THE RELATIVES, AND THATS WHAT HAPPENED. [R/T P. 18, L. 6 -7, 10-11, 15-16] ARGUMENT TO 12 If the witness states that he spoke with ALL THE RELATIVES to get my phone number, this was a lie! Who calls ALL their relatives just to get a phone number? Does this make any sense? Think of the answer for a second, he never had my number, yet he states he called all my relatives to get my number! Yet, in fact, he did not have all my relatives numbers, nor mine!? The witnesses is lying because he admits he does not have my phone number or any of my relatives numbers, but yet he claims he got my number when he does not have any of my relatives phone numbers!?

SPECIAL INTERROGATORY NO. 13: Regarding Case Number GC 042105, Case Name Ramirez v. Castaneda, held on February 22, 2010, in Reporters Transcript by Sharon Boyer, state each and every fact and detail which you base the contention: THE COURT: LETS MARK THIS AS DEFENDANTS A FOR IDENTIFICATION [R/T P. 21, L. 18 -19] ARGUMENT TO 13 The court wants to mark the Defendants Exhibit for Identification. The defendant did not have any of his exhibits marked for identification, and this was because I was not allowed to bring any exhibits for identification. In other words, I was not allowed to present any exhibits or exhibits at all, which proves that I was set up for failure based on a bribe. For proof and to verify, who comes to a court of law to prove a case, with only one piece of evidence, or one exhibit that the court will allow. This proves that my case was set up to be lost, because I was engineered to bring one exhibit to court?

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SPECIAL INTERROGATORY NO. 14: Regarding Case Number GC 042105, Case Name Ramirez v. Castaneda, held on February 22, 2010, in Reporters Transcript by Sharon Boyer, state each and every fact and detail which you base the contention: Q. I WILL ASK YOU EARLIER THAT YOU CONTACTED ME TO SELL THE HOUSE, AND I WOULD LIKE TO KNOW HOW IS IT YOU SAID YOU CONTACTED ME BY PHONE? WHAT EXACTLY WAS IT THAT TRANSPIRED DURING THAT CONVERSATION? A. THERE WAS NO CONVERSATION. Q. WELL YOU SAIDA. I TRIED TO CONTACT YOU. NO ONE PICKED UP. [R/T P. 22, L. 21 -28] ARGUMENT TO 14 Be advised on the above statement, THERE WAS NO CONVERSATION, this is a lie!? Because in further testimony of the above, he calls my ALL relatives to get my phone number, but yet in the passage, he admits that there was NO CONVERSATION. Who calls someone to not have a conversation with anyone? This proves it was a lie!

SPECIAL INTERROGATORY NO. 15: Regarding Case Number GC 042105, Case Name Ramirez v. Castaneda, held on February 22, 2010, in Reporters Transcript by Sharon Boyer, state each and every fact and detail which you base the contention: THE COURT: IF SHE DID, SO WHAT? [R/T P. 23, L. 21] ARGUMENT TO 15 If Judge DeVanons own mother was financially abused by anyone, will he respond the same exact way as he did in his own court? Would DeVanon say the same exact answer as above, if his own mother was a victim of financial elder abuse, would he say the same exact thing: So what? This answer proves and confirms that Judge DeVanon is bias, prejudiced, racist, and discriminates against the people of color.

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SPECIAL INTERROGATORY NO. 16: Regarding Case Number GC 042105, Case Name Ramirez v. Castaneda, held on February 22, 2010, in Reporters Transcript by Sharon Boyer, state each and every fact and detail which you base the contention: IT WILL SHOW THAT PRIOR TO DISAPPEARING HER ALREADY TAKEN THE $70,000.00 AND THEY ALREADY OBVIOUSLY DIRECTED HER INTO SIGNING THIS QUIET TITLE TO THEM. THE PHONECALLS SHOW BASICALLY FROM NOVEMBER 2007 WHEN MS CASTANEDA WAS IN THE HOSPITAL. AND FOR THE RECORD, I WANT TO KNOW STATE ON RECORD THAT MRS. MACCARLEY WAS MRS. CASTANEDAS ATTORNEY OF RECORD, YET SHE SENT TWO PEOPLE TO THE HOSPITAL TO QUESTION HER. [R/T P. 30, L. 26 -28 AND P. 30, L. 1 -5] ARGUMENT TO 16 I have three issues above that were presented in Court. The first was the $70,000.00, next the Quiet Title case, and last the illegal questioning of my mother at hospital by attorney Lisa MacCarleys agents. This court did not allowed evidence to be presented that Felicitas Castaneda was the victim of Financial Elder Abuse! If Lisa MacCarley was retained on October, 2007, why did she interrogate my mother at a hospital bed as my mother was dying of cancer? Especially, since Chad T-W Pratt was Mrs. Castanedas attorney of record and violated my mothers rights, because she was represented by counsel! I know understand why the statement was made by the judge I did not hear the objection comment by Judge DeVanon at trial! Your honor, this spontaneous statement made by a judge, shows that he was not impartial and was helping one of the parties illegally for a bribe. SPECIAL INTERROGATORY NO. 17: Regarding Case Number GC 042105, Case Name Ramirez v. Castaneda, held on February 22, 2010, in Reporters Transcript by Sharon Boyer, state each and every fact and detail which you base the contention: THE COURT: HE DIDNT SHOW FOR DAY OF TRIAL. HE DIDNT CONTACT THE COURT. WE CANT GIVE YOU ANY INDICATION WHAT THAT WAS ABOUT. I SUSPECT YOU ARE GOING TO HAVE TO TAKE THAT UP WITH THE BAR ASSOCIATION OR MR. COUNTS [R/T P. 30, L. 14 -18]
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ARGUMENT TO 17 In the above statement the judge admits that I was represented, and I had due process rights guaranteed by the constitution of the United States. The judge willingly and admit tingly, from the passage above, violated my rights because he states that I had representation, but refused my representation so he can collect in his bribe money? For proof, my attorney showed up at court, but was not allowed to represent me on a manufacture technicality. Who comes to court with all parties that appear before the court, but does not allowed the attorney to represent his own client?

SPECIAL INTERROGATORY NO. 18: Regarding Case Number GC 042105, Case Name Ramirez v. Castaneda, held on February 22, 2010, in Reporters Transcript by Sharon Boyer, state each and every fact and detail which you base the contention: THE COURT: WHAT MONTH ARE YOU TALKING ABOUT? NOVEMBER OF 07. THE COURT: YOUR REPRESENTATION IS THAT THE GRANMA WAS IN THE HOSPITAL DYING IN NOVEMBER OF 07? THE COURT: THAT TIME PERIOD, NOVEMBER 2007? THE WITNESS: YES. [R/T P. 32, L. 17 -20 AND LINE 28] ARGUMENT TO 18 Witness Evelyn Christina Ramirez acknowledges that Felicitas Castaneda was in hospital, and provided the information to her attorney of Record Lisa Marie MacCarley. Mrs. MacCarley knew that Felicitas Castaneda was represented by counsel, and she still sent people from her office, Yolanda Rivero, to question my mother knowing my mother was represented by counsel. For proof and to verify the violation of rights, see the response to complaint by MacCarley in case Felicitas Castaneda v. Susana Castaneda, Evelyn Ramirez, and Alonso Castaneda in case GC 039459. There is none, because MacCarley was far more preoccupied with labeling Mrs. Castaneda insane to cover up for her theft of my mothers Estate.

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SPECIAL INTERROGATORY NO. 19: Regarding Case Number GC 042105, Case Name Ramirez v. Castaneda, held on February 22, 2010, in Reporters Transcript by Sharon Boyer, state each and every fact and detail which you base the contention: THE COURT: WHAT ARE THEY? RECORDS GOING TO SHOW ME IT WAS TRANSFERRED FROM YOUR MOTHER ACCOUNT. MR. CASTANEDA: YES [R/T P. 35, L. 09 -11] ARGUMENT TO 19 Your honor, if $112,000 came out missing from my mothers bank account, wouldnt the court of record be interested on where $112,000 went? The courts attitude of not trying to ascertain of where the money went, proves the court was given a bribe by the opposing party!? For proof and to verify the court took a bribe, why didnt the court try to find out where $112k went in this case? The judge knew where it went; it apparently went in his pocket and the other officers of the court? because for proof, who allows $112k to be missing in a court of law, and not even find out where it went to?

SPECIAL INTERROGATORY NO. 20: Regarding Case Number GC 042105, Case Name Ramirez v. Castaneda, held on February 22, 2010, in Reporters Transcript by Sharon Boyer, state each and every fact and detail which you base the contention: MR. CASTANEDA: I AM TRYING TO ESTABLISH THAT AGAIN $70,000.00 WERE TRANSFERRED FROM HER ACCOUNT BEFORE SHE DOES THIS ONE FILED TRANSFER. [R/T P. 38, L. 26 -28] ARGUMENT TO 20 First of all, where did the $70,000 go? Why didnt the court pursue where the money went? It went in their pocket! For proof that it went in their pocket, it was not pursued.

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SPECIAL INTERROGATORY NO. 21: Regarding Case Number GC 042105, Case Name Ramirez v. Castaneda, held on February 22, 2010, in Reporters Transcript by Sharon Boyer, state each and every fact and detail which you base the contention: THE COURT: ASSUMING THATS TRUE, WHAT SIGNIFICANCE DOES IT HAVE FOR THIS GENTLEMAN? TO SHOW THE MONEY WENT TO HIM OR SOMEHOW INVOLVED HIM? [R/T P. 39, L. 1 -3] ARGUMENT TO 21 This proves the action above that the court ASSUMES whatever its true or not true?

SPECIAL INTERROGATORY NO. 22: Regarding Case Number GC 042105, Case Name Ramirez v. Castaneda, held on February 22, 2010, in Reporters Transcript by Sharon Boyer, state each and every fact and detail which you base the contention: THE WITNESS: MY GRANDMOTHER ONLY SPOKE SPANISH. BY MR. CASTANEDA: Q. BUT THE DOCUMENT WAS IN ENGLISH? A. WELL, OBVIOSULY. Q. IS THIS DOCUMENT IN ENGLISH? A. YES. Q. IT IS IN ENGLISH, RIGHT? A. YES. [R/T P. 46, L. 1 -9] ARGUMENT TO 22 If a document is in English, which proves the intent to commit fraud and theft from my mother, who can only speak Spanish, why wasnt an interpreter allowed as required as prescribed by law!

SPECIAL INTERROGATORY NO. 23: Regarding Case Number GC 042105, Case Name Ramirez v. Castaneda, held on February 22, 2010, in Reporters Transcript by Sharon Boyer, state each and every fact and detail which you base the contention: THE COURT: DID YOU RECEIVE $25,000.00 FROM YOUR GRANDMOTHER? THE WITNESS: DID I RECEIVE IT? NO. [R/T P. 47, L. 22 -23]

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ARGUMENT TO 23 The Witness is lying because the transfer of moneys went into Christinas account. For proof and to verify this transfer and theft, the statement was presented in court but was not identified or admitted into evidence by the court. SPECIAL INTERROGATORY NO. 24: Regarding Case Number GC 042105, Case Name Ramirez v. Castaneda, held on February 22, 2010, in Reporters Transcript by Sharon Boyer, state each and every fact and detail which you base the contention: THE COURT: THE QUESTION, I THINK, IS THE RECEIPT SHOWING A $5,000.00 TRANSFER, WAS THAT MONEY TRANSFERRED FROM TE SAME ACCOUNT NUMBER THAT HAD THE $25,000? THE WITNESS: YES. 8771714215 [R/T P. 50, L. 27 -28, P. 51, L. 1- 3] ARGUMENT TO 24 The witness even recites her own account number where the $5,000.00 and the $25,000.00 were transferred to their account. This is theft, yet the court refuses to allow in as evidence to come up with a predictive or purchase verdict due to the bribe!? SPECIAL INTERROGATORY NO. 25: Regarding Case Number GC 042105, Case Name Ramirez v. Castaneda, held on February 22, 2010, in Reporters Transcript by Sharon Boyer, state each and every fact and detail which you base the contention: THE COURT: HE WANTS TO KNOW HOW YOU DEPOSITED $10,000, IFYOU DID. THE WITNESS: BECAUSE ITS TRANSFERRED RIGHT HERE. [R/T P. 51, L. 17 -20] ARGUMENT TO 25 The witness again admits that a transferred of $10,000.00 was made. If Christina was not even holding a decent job, how can she account for the $25,000.00 that was missing from my mother account, but yet deposit $10,000.00. Where did this money came from?

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SPECIAL INTERROGATORY NO. 26: Regarding Case Number GC 042105, Case Name Ramirez v. Castaneda, held on February 22, 2010, in Reporters Transcript by Sharon Boyer, state each and every fact and detail which you base the contention: Q. LET ME ASK YOU ONE QUESTION: DID YOU RETAIN THE LAW OFFICES OF MRS. MACCARLEY TO BE CONTRACT? A. YEAH. THE COURT: I DIDNT HEAR THAT OBJECTION. MS. MACCARLEY: OBJECTION, IRRELEVANT. THE COURT: SUSTAINED [R/T P. 55, L. 18 -23] ARGUMENT TO 26 This proves that the court was leading and assisting the opposing counsel that paid the bribe to the court. This proves the court was bias, for taking the bribe because the court gives MacCarley legal advice. How can I even present my case if the judge gets a payout of a bribe? SPECIAL INTERROGATORY NO. 27: Regarding Case Number GC 042105, Case Name Ramirez v. Castaneda, held on February 22, 2010, in Reporters Transcript by Sharon Boyer, state each and every fact and detail which you base the contention: THE COURT: WHY IS THAT SIGNIFICANT? MR. CASTANEDA: BECAUSE THE ATTEMPTS TO CLAIM THAT MRS. CASTANEDA WAS INSANE OR DEMENTED. THE COURT: NO ONE CLAIMED MISS RAMIREZ WAS CLAIMED INSANE OR DEMENTED. [R/T P. 56, L. 8 -12] ARGUMENT TO 27 Here Goes DeVanon again! He was not even paying attention to what I was presenting to the Court, yet, DeVanon obstructs my questioning and to avoid the truth for a bribe. MacCarley was the one trying to label Felicitas Castaneda insane!

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SPECIAL INTERROGATORY NO. 28: Regarding Case Number GC 042105, Case Name Ramirez v. Castaneda, held on February 22, 2010, in Reporters Transcript by Sharon Boyer, state each and every fact and detail which you base the contention: THE COURT: LETS GO TO THE LAST QUESTION, MR. CASTANEDA. WE ARE GOING TO TAKE A BREAK. WERE ON A FISHING EXPEDITION. BY MR. CASTANEDA. Q. THE $25,000 TRANSFER ON NOVEMBER 22, RIGHT, YOU SAID THAT THE MONEY REMAINED THERE FOR A YEAR; IS THAT CORRECT? A. I DIDNT SAY ALL THE $25,000. Q. YOU JUST TESTIFIED THAT THE MONEY THERE WAS MONEY PUT INTO AN INVESTMENT? A. PART OF IT. Q. PART OF IT? A. YES. [R/T P. 61, L. 10 -22] ARGUMENT TO 28 If we were on a fishing expedition, as stated by the Court in the above, the code word here is a fishing expedition. This was no fishing expedition, this was a trial with a mission and the intent to find out how an 85 year old senior citizen, under heavy medication, dying of cancer that spoke only Spanish, and gives away $112,000 and her property away? To prove this is fraud and theft, the $112k was never explained in court, yet part of if was stolen as stated in the above by Evelyn Christina Ramirez! Why didnt the court order the money to be returned to the Estate? Because the court took a bribe and wanted a cut of the action!?

SPECIAL INTERROGATORY NO. 29: Regarding Case Number GC 042105, Case Name Ramirez v. Castaneda, held on February 22, 2010, in Reporters Transcript by Sharon Boyer, state each and every fact and detail which you base the contention: Q. TWENTY-FIVE. HOW MUCH WAS INVESTED? A. TEN I BELIEVE. YES. THE COURT: $10,000? THE COURT: $10,000 WAS PUT IN A C.D? [R/T P. 62, L. 10 -22 and 18] ARGUMENT TO 29 Does the court want to find out where the $10,000 are or at least or even the truth or where it went to? It use as a bribe to pay the court and attorney MacCarley! Be advised, everyone

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is stealing and making money off my inheritance, and taking all of my familys assets as the case continues.

SPECIAL INTERROGATORY NO. 30: Regarding Case Number GC 042105, Case Name Ramirez v. Castaneda, held on February 22, 2010, in Reporters Transcript by Sharon Boyer, state each and every fact and detail which you base the contention: Q. DID YOU WITHDRAW $25,017 AND SOME A. NO. I DID NOT WITHDRAW $25,000 AND 17. Q. FROM THIS ACCOUNT 3576246695? A. COULD I WITHDRAW $25,000? TERE IS NOT $25,000 IN THE ACCOUNT. Q. DID YOU SIGN THIS? A. YES. Q IS FOR THAT ACCOUNT? A. OBVIOUSLY, IF THATS MY ACCOUNT. Q OKAY. I BELIEVE THAT I HAVE TO WITHDRAW FROM THAT ACCOUNT. THE COURT: WE ARE NOT GOING TO TAKE A BREAK NOW. THE COURT; WE ARE NOT MAKING ANY HEADWAY. [R/T P. 63, L. 11 -24] ARGUMENT TO 30 The above is an admission or a confession of the monies taken and stolen. After taking a bribe, the judge interferes with the legal process by, not letting the opposing party answer the question. Judge DeVanon states that I was not making any headway, when it was my question, my turn and my time to get to the truth. This proves that he took a judicial bribe, because he interferes with the answers that would have won my case.

SPECIAL INTERROGATORY NO. 31: Regarding Case Number GC 042105, Case Name Ramirez v. Castaneda, held on February 22, 2010, in Reporters Transcript by Sharon Boyer, state each and every fact and detail which you base the contention: THE COURT: HE HAS NEVER CALLED US. HES NEVER CONTACTED US. MR . CASTANEDA: I E-MAILED COUNSEL REGARDING MY RETAINING ON THURSDAY, I BELIEVE. IS THAT CORRECT? MRS. MACCARLEY: YES. I RECEIVED AN E-MAIL FROM MR. CASTANEDA. [R/T P. 63 /64, L. 25 -28 AND 1 -2]

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ARGUMENT TO 31 Never say never because it is usually false! MacCarley admits that she received an email from Mr. Castaneda this proves MacCarley lying again, throughout the trial when she manufactures evidence! There is no proof of what MacCarley said it happened. MacCarley probably had several conversations with Counsel Counts prior to the trial. For proof, see the evidence of a fax sent on February 19, 2010 by Emahn Counts!

SPECIAL INTERROGATORY NO. 32: Regarding Case Number GC 042105, Case Name Ramirez v. Castaneda, held on February 22, 2010, in Reporters Transcript by Sharon Boyer, state each and every fact and detail which you base the contention: THE COURT; SEE, PEOPLE DEED PROPERTY EVERY DAY FOR A NUMBER OF DIFFERENT REASONS; SOMETIMES THEY ARE CHEATED OUR OF THEIR PROPERTY, SOMETIMES THEY ARE INVESTORS, SOMETIMES THEY SPECULATE, GIVE IT TO THEIR CHURCH. THATS KIND OF THE NORMAL COURSE OF BUSINESS. [R/T P. 67, L. 13 -18] ARGUMENT TO 32 SOMETIMES THEY ARE CHEATED OUT OF THEIR PROPERTY this Judge DeVanon states that people get cheated out of their property. The reason why people get out of their property, per Judge DeVanon, is because he lets them for his cut of the bribe? For proof, he admits that my mother was cheated, and that he cheated me! SPECIAL INTERROGATORY NO. 33: Regarding Case Number GC 042105, Case Name Ramirez v. Castaneda, held on February 22, 2010, in Reporters Transcript by Sharon Boyer, state each and every fact and detail which you base the contention: COMMUNICATION. I AM GOING TO OBJECT ON THAT GROUNDS. I WAS NOT REPRESENTING MISS RAMIREZ AT THE TIME, SO OBJECTING ON THAT GROUND. [R/T P. 68, L. 1 - 3]

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ARGUMENT TO 33 Again, here is MacCarley lying in court stating less than the truth! For proof, see court case Castaneda v. Castaneda, case GC 039459! The evidence or court files does not lie, people do!

SPECIAL INTERROGATORY NO. 34: Regarding Case Number GC 042105, Case Name Ramirez v. Castaneda, held on February 22, 2010, in Reporters Transcript by Sharon Boyer, state each and every fact and detail which you base the contention: THE COURT: THE WITNESS HAS SAID WHAT SHE BELIEVES THE MONEY WAS FOR. SHE IS TELLING THE TRUTH OR SHES NOT TELLING THE TRUTH. MR. CASTANEDA: THAT IT WAS AN INVESTMENT. HER TESTIMONY IS IMPEACHABLE [R/T P. 73, L. 13 -17] ARGUMENT TO 34 The court admits in its statements that court puts itself in error, or in a Position of Compromise. It does not matter if the witness is telling the truth in a court of law, as long as the court gets its share! This is why lying is permitted in a court of law in the Superior Court System!

DATED January 9, 2012

Respectfully Submitted ________________________ Jose Castaneda

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PROOF OF SERVICE STATE OF CALIFORNIA, COUNTY OF LOS ANGELES GC 042105 Castaneda v. Ramirez I am employed in the County of Los Angeles, State of California. I am over the age of 18 and not a party to the within action; my home address is 123 W. Hammond Street, Pasadena, California 91103. On January 10, 2012 I served the foregoing documents described as: SPECIAL INTERROGATORIES PROPOUNDED TO DEFENDANT JOSEPH F. DEVANON SET ONE, MEMORANDUM OF POINTS AND AUTHORITIES On the interested parties in this action by placing a true copy thereof enclosed in a sealed envelope with postage thereon fully prepaid in the United States mail at Pasadena, California, addressed as follows:
Sarah Overton Esq. Cummings McClorey Davis & Acho 3801 University Ave Ste 560 Riverside, CA 92501 Lisa Marie MacCarley 3436 N. Verdugo Rd. # 100 Glendale, CA 91208 James R. Felton Esq. 16000Ventura Blvd. Encino, CA 91436

Justice System Integrity Division Los Angeles County District Attorney's Office 210 West Temple St., Rm. 17-1114 Los Angeles, CA. 90012 Phone: (213) 974-3888

I am readily familiar with the practice of the collection and processing of correspondence for mailing with the United States Postal Service; such envelope(s) will be deposited with the United States Postal Service on the above date in the ordinary course at the address shown above; and such envelope was placed for collection and mailing on the above date according to ordinary mailing practices. Executed on January 9, 2012, at Pasadena, California. I declare under penalty of perjury under the laws of the State of California that the above is true and correct. Dated: January 9, 2012 _____________________________ Armando Salgado
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Jose Castaneda P. O. Box 947 Pasadena, CA. 91102 (626)296-9136

SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES


Case No. : GC 042105 ) Jose Castaneda ) Defendant ) ) ) vs. ) ) ) Ramirez Et Al, ) Does 1-10 ) Plaintiffs. ) ) _________________________________)

MEMORANDUM OF POINTS AND AUTHORITIES SPECIAL INTERROGATORIES PROPOUNDED TO DEFENDANT JOSEPH F. DEVANON SET ONE Date: January 12, 2012 Time: 8:30 a.m. Dept. S

MEMORANDUM OF POINTS AND AUTHORITIES I


ANY PARTY MAY OBTAIN DISCOVERY WITHIN THE SCOPE DELINEATED BY SECTION 2017, AND SUBJECT TO THE RESTRICTIONS SET FORTH IN SECTION 2019, BY PROPOUNDING TO ANY OTHER PARTY TO THE ACTION OF INTERROGATORIES TO BE ANSWERED UNDER OATH. (C.C.P. 2030(a)

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II
IF A PARTY TO WHOM INTERROGATORIES WERE PROPOUNDED FAILS TO RESPOND THE PARTY PROPOUNDING INTERROGATORIES MAY MOVE FOR AN ORDER COMPELLING RESPONSES TO THE INTERROGATORIES. (C.C.P. 2030 (k), in relevant parts) Your Honor, requesting this Order! III EACH ANSWER AND RESPONSE MUST BE ASKED COMPLETE AND STRAIGHT FORWARD AS THE INFORMATION REASONABLY AVAILABLE TO THE RESPONDING PARTY PERMITS. IF AN INTERROGATORY CAN NOT BE ANSWERED COMPLETELY, IT SHALL BE ANSWERED TO THE EXTEND POSSIBLE. (C.C.P. 2030 (f)(1), emphasis added) IV A FALSE RESPONSE OR EVASIVE RESPONSE TO DISCOVERY IS GROUND FOR SANCTIONS (C.C.P. 2023 (a) (6) Requesting sanctions of $200.00 per Q for evasive response! V THE COURT SHALL IMPOSE MONETARY SANCTIONS UNDER 2023 AGAINST A PARTY, PERSON, OR ATTORNEY WHO UNSUCCESSFULLY MAKES OR OPPOSES A MOTION TO COMPEL RESPONSES TO INTERROGATORIES, UNLESS IT FINDS THAT THE ONE SUBJECT TO THE SANCTION ACTED WITH SUBSTANTIAL JUSTIFICATION OR THAT OTHER CIRCUMSTANCES MADE THE IMPOSITION OF THE SANCTION UNJUST. (C.C.P. 2030 (k), in relevant parts)

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In the Matter before the court, the Defendant was properly served with the Request for Admissions, which has been properly filed on 6/28/2011, by Plaintiff Jose Castaneda. Although, Defendant did respond to said Request for Admissions, certain responses were in fact nonresponsive, incomplete and evasive, therefore violating my rights to a fair trial. Was this action allowed for a judicial bribe, or was it an accident? Still, either way, my rights were Compromised! Plaintiff seeks further responses to Special Interrogatories as this information is relevant and pertinent to the Claim, Complaint and Charges made in the formal Lawsuit filed on 05/02/2011, that a special review should be allowed and ordered by the court for proper justice. Defendant, through and by his Counsel, has sought a blanket of immunity that the Constitution does not grant to any of its citizens, and because of corruption in our courts, no one is above the law! Specifically, officers of the Court who violate the same laws they are sworn to uphold, which demonstrates and proves the corruption in our courts today! In Fact, Counsel for Defendant has engaged in practice of copying and pasting the same answer to all different questions in a clear attempt to be evasive and to not answer truthfully, violating FullDisclosures Laws, withholding of evidence. Clearly, the Plaintiff cannot go forward to trial until the requested information is produced by the Defendant(s). In addition to compelling responses to the form interrogatories from the Defendant(s), the court should also issue monetary sanctions for reasonably compensatory fees to the Plaintiff in the sum of $1500.00 per each violation as monetary sanctions for this unreasonable failure to respond to the Request for Admissions. And, also, an Instant Judgment for this negative conduct, as criminal conduct should not be rewarded to receive Unjust Rewards. Plaintiff predicts and forecasts the Defendants Counsel will utilize the same negative tactic of delay, deny, and evasiveness with the Special Interrogatories, by not being truthful, or less than truthful with this court. We are not in the Pasadena District where Justice can take a back seat when it comes to the constitutional Rights of its citizens or litigants! DATED: January 10, 2011 Respectfully Submitted _________________________ Jose Castaneda
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