First Amended Complaint Dillon V LaFlamme

Case 8:15-cv-00339-JLS-JCG Document 15 Filed 03/26/15 Page 1 of 90 Page ID #:88
1 PATRICIA J. BARRY SBN 59116
634 S. Spring St., Ste 823
2 Los Angeles, Ca 90014
Tele. (213) 995-0734
3 Fax (213) 995-0735
pbarrylegal@gmail.com
4 Attorney for Plaintiff RUBY DILLON
on behalf of herself and her minor daughter A.D.
5 as her guardian ad litem

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UNITED STATES DISTRICT COURT

FOR CENTRAL DISTRICT OF CALIFORNIA
RUBY DILLON on behalf of herself
CASE NO. SA 15-CV-0339 DFM
and her minor daughter A.M. as her
guardian ad litem,
FIRST AMENDED COMPLAINT
FOR DAMAGES, ATTORNEY
Plaintiff,
FEES AND COSTS, AND
INJUNCTIVE RELIEF
v.
1.
42 U.S.C. Sec.1983: First
HAROLD LA FLAMME, ROBERT
Amendment - Free Speech
MUNOZ (in his individual capacity),
Retaliation and Denial of
MAHATHAP SRIKUREJA, STATE
Meaningful Access to Court;
OF CALIFORNIA, COUNTY OF
Fourth Amendment - Illegal
ORANGE, ORANGE SUPERIOR
Seizure of Child and false arrest
COURT, ROSANNE FROEBERG (in
and imprisonment; Fourteenth
her individual capacity), TONY
Amendment - Denial of Equal
RACKAUCKAS, (in his individual
Protection and of Due Process
capacity), BONNIE BREEZE (in her
(Denial of Family Rights and of
individual capacity), MAUREEN
Right to Bodily and Emotional
NAGANUMA (in her individual
Integrity)
capacity), C. J. WILKINSON (in his
individual capacity), KRISTEN
2.
42 U.S.C. Sec.1985(2):
EITNER (in her individual capacity),
Conspiracy to Deny Equal
BIRUTE BRUZAS-RANES (in her
Protection and to Violate First
individual capacity), ROBERT
Amendment - Free Speech
MUNOZ, (in his individual capacity),
Seizure of Child; Fourteenth
Amendment - Denial of Due
Process (Denial of Family
Rights and of Right to Bodily
and Emotional Integrity)
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JILL LUX (in her individual capacity) 3.

D'ALICIA MARRON-TAYLOR (in
her individual capacity), DAVID
GLIDDEN (in his individual capacity),
JENNIFER PALMQUIST (in her
individual capacity), DENISE
JOHNSON (in her individual
capacity), JESSICA CHLEBOWSKI
(in her individual capacity),THOMAS
MALABAN (in his individual capacity),
HOWARD CHANG (in his individual
capacity) , JOHN CATE, ALAN
STOKKE, MATTHEW DE ARMEY,
GRACE COLEMAN, SHERYL
EDGAR, EVA SRIKUREJA
4.
PRAVIT SRIKUREJA, ELIZABETH
RAMIREZ LOCKMER, CAROL
STEWART, PATRICIA NASH, P.A.
5.
NASH & ASSOCIATES
DOES 1 - 10,
Defendants.
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42 U.S.C. Sec.1985(3):
Conspiracy to Deny Equal
Protection Conspiracy to Deny
Equal Protection and to Violate
First Amendment - Free Speech
Seizure of Child; Fourteenth
Amendment - Denial of Due
Process (Denial of Family
Rights and of Right to Bodily
and Emotional Integrity)
42 U.S.C. Sec.1986: Action for
Neglect to Prevent Wrongs
Violence Against Women
Reauthorization Act, 42 U.S.
Code Sec.12395(b): Gender
discrimination by Recipients and
Disbursers of Federal Funds
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Monell Violation
7.
Negligence per se
8.
Breach of Fiduciary Duty
9.
Legal Malpractice
10.
False Imprisonment
11.
Child abuse
JURY DEMAND
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PLAINTIFF RUBY DILLON (Dillon) on behalf of herself and her minor

daughter A.D. as her guardian ad litem alleges for her First Amended Complaint:
INTRODUCTION
In a series of searing questions, the three judges [former Chief Judge
Kozinski, Judge Wardlaw, Judge Fletcher] expressed frustration and
anger that California state judges were not cracking down on
prosecutorial misconduct....Wardlaw, a Clinton appointee, complained
that California's courts were "condoning" prosecutorial misconduct by
upholding verdicts, a rare public criticism of her fellow judges. She
suggested that state judges, who must be approved by voters, fear
inciting the public's wrath.
...
Fletcher...observed that the state's attorney general had fought "tooth
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and nail" more than a decade ago to prevent a court from seeing a
transcript that revealed the false evidence.
U.S. Judges See 'Epidemic' of Prosecutorial Misconduct in State, Maura

Dolan, Los Angeles Times, January 31, 2015, 7:20 PM, emphasis added.
1.
The Ninth Circuit scolding of state court judges may have influenced
5 Judge Thomas Goethels, DEFENDANT ORANGE SUPERIOR COURT

6 (Court), to take a courageous step on March 12, 2015, against DEFENDANT
7 TONY RACKAUCKAS (Rackauckas) Orange County District Attorney and his
8 Office by disqualifying the Office and appointing the Attorney General to
9 prosecute the death penalty phase of a murder case. The defendant, Scott Dekraai,
10 (Dekraai) had already pled guilty to the gun massacre of Michelle Fournier
11 Dekraai (Fournier), his ex wife and the mother of their eight year old son, and
12 seven other individuals at Fourniers work place in Seal Beach. The massacre
13 occurred in October 2011.
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2.
The Ninth Circuit panel (Judges Kozinski, Fletcher, and Wardlaw),
15 was also upset with State Attorney General Kamala Harris for defending against
16 the habeas petition of Defendant Baca in the face of the prosecutors own perjury.
17 Harris backed down, agreeing that Bacas conviction could be reversed and a new
18 trial granted.
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3.
Despite what occurred in the Baca case, Harris remains tethered to a
20 corrupt system which does not work for any of us, and repeatedly causes egregious
21 harm to women and children as occurred in this case and in the Dekraai case. And
22 the lesson of the Dekraai case is that when one does not listen to the domestic
23 violence victim, as was Michelle Fournier Dekraai, Dekraais ex wife,
24 (Fournier) one risks a massacre as did occur in the Dekraai case.
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4.
Harris is wasting taxpayer dollars on an appeal defending Rackauckas
26 and not the public interest. She is unmoved by the suffering of the family
27 members and friends of the murder victims of Dekraai who want the case to
28 proceed. That Harris is so calloused about the survivors of the victims should be
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1 noted. The mass killings were motivated by Dekraais misogyny directed against
2 Fournier.
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5.
Fournier had repeatedly warned the Court about Dekraais domestic
4 violence, his instability, and his raging personality. Yet, no one at the courthouse
5 seemed to take the female victim seriously. Somehow no one in charge the
6 judges and the police forced Dekraai to surrender his weapons as automatically
7 ordered when a Domestic Violence Prevention Act (DVPA) restraining order is
8 made which, it seems, was entered in the case before Dekraai murdered eight
9 people using guns.
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6.
DEFENDANT JOHN CATE (Cate) handpicked by DEFENDANT
11 HAROLD LAFLAMME (La Flamme) to be his successor as A.D.s minors

12 counsel in Dillons custody litigation represented Fournier.
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7.
At Http://usatoday30.usatoday.com/news/nation/story/2011-10-12/
14 calif-salon-shooting/50745746/1, Cate was quoted as telling the Orange County

15 Register that when Dekraai appeared for the Review hearing "Obviously, I saw
16 no indication that he was violent, the attorney said, emphasis added.
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8.
...had been physically abusive to her during their marriage, and that in
2008 he beat his stepfather, pleaded guilty to assault and battery and
underwent a year of anger management....
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Michelle Dekraai also alleged that her ex-husband called 911 at least
once "advised that he was going to kill himself or someone else." She
wrote that he "is a diagnosed bipolar individual who has problems
with his own medication and his reaction to same, and he certainly
shouldn't be allowed to have unilateral and unfettered control of any
and all medical and psychological aspects of our son's life."
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Yet, Fournier, his client alleged in pleadings that Dekraai
9.
The murders occurred on October 12, 2011 and Michelle supposedly
had obtained a temporary restraining order on Tuesday, October 11, 2011, the day
of the hearing which was just one day before Dekraai murdered her and seven
other individuals according to one news report using guns.
http://www.cbsnews.com/news/ex-wife-of-accused-calif-salon-shooter-said-he-wa
28 s-abusive-in-court-filings/
10.
If all the above is true, Cate, the judges, and the police took no steps
2 to insure that Dekraai surrendered his weapons to the police. A DVPA restraining
3 order is only as good as its enforcement.
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11.
It is also bitterly ironic that the misogynistic murderer successfully
5 recused Rackauckas while so far Rackauckas and his office have not been held
6 accountable for what they did to Dillon and most of all, to her daughter, A.D.
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12.
It is also no coincidence that Fournier litigated her case in the same
8 court, DEFENDANT ORANGE SUPERIOR COURT (Court) as did Dillon.

9 Fournier ended up murdered and Dillons daughter, A.D., now ten years old, has
10 literally been disappeared by Court judge Glenn Salter as far as we know to
11 Napa where she is imprisoned in the home of a hostile sister-in-law of A.D.s
12 father, DEFENDANT MAHATHAP SRIKUREJA (Srikureja). This is the man
13 A.D. said was sexually abusing her.
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13.
Dekraai gets a jury trial. Dillon and A.D. do not. Instead, Dillon and
15 A.D. and mothers and children throughout the state have their destinies
16 determined by the likes of La Flamme, a minors counsel. He also misappropriates
17 federal and other public funds, earmarked for the protection children, to protect
18 batterers and pedophiles rather than the children he is representing.
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14.
On LaFlammes State Bar profile, LaFlamme does not list whether he
20 received a bachelors degree and what he majored in. He graduated from Western
21 University State College of Law. We do not know if he meets the educational
22 requirements for a minors counsel set out in Rule 5.242, CA Rules of Court.
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15.
In 2009, Barry served a bar complaint against LaFlamme on the
24 California Supreme Court Chief Justice and President of the State Bar alleging
25 that LaFlamme had covered up sexual abuse of a father in another case and
26 betrayed his young client who was alleging that her father was sexually abusing
27 her. Both individuals returned the complaint to Barry. Their inaction enabled
28 LaFlamme to continue to harm other mothers and children including Dillon and
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1 A.D.
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16.
Social workers and County Departments of Family and Social
3 Services (DCFS) also known as Child Protective Services, (CPS) are out of
4 control. For example, Los Angeles DCFS is being investigated for child
5 trafficking. Social workers terminate the rights of parents, sell their children to
6 individuals, and pocket the money for themselves. According to one recent
7 article, a DCFS Administrator, Ron Louden, may have been involved in the child
8 trafficking ring. Los Angeles Department of Children and Family Services under
9 state investigation, dweisman | March 7, 2015 | Updated: March 7, 2015 @ 3:35
10 am
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17.
The State Bar is also implicated in the statewide invidious
12 discrimination against female protective parents and their children in family and
13 juvenile courts. In September 2014, this writer filed a request with the California
14 Supreme Court to remove former San Bernardino Judge Craig Kamansky as a
15 MCLE provider, teaching, of all topics, ethics to attorneys. Barry did so, because
16 of Kamanskys notorious reputation as a pedophile. Kamansky settled a case
17 brought by Jason Bumpus in this Court for $300,000.00 who alleged that while
18 sitting as a juvenile court judge, Kamansky had made Bumpus his ward and then
19 raped and sodomized him.
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18.
This writer understands that Kamansky was willing to risk a jury trial
21 until he learned that two sisters, the Harris sisters, were prepared to testify he
22 sexually abused them also.
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19.
Kamansky also received a public reproval from the California
24 Commission on Judicial Performance for taping over a video which Bumpus

25 alleged had child porn on it.
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20.
In October 2014, California Supreme Court Chief Justice
27 Cantil-Sakauye did not just deny Barrys request, she struck it. The Chief Justice
28 has sent a message loud and clear to the mothers and children Barry represents and
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1 to Barry, that childrens lives do not matter, especially those children who are
2 sexually abused like A.D., like Bumpus, and like the Harris sisters. The justice
3 prefers to support Kamansky, the alleged pedophile. Bumpus ended up taking his
4 own life. His life definitely did not matter to the state legal establishment. The
5 only court where he received any justice was this Court.
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21.
In September 2011, the State Bar Review Court, Judges Remke,
7 Purcell, and Epstein, ruled that Attorney Gary Grants plea of guilty to possession
8 of child porn was NOT moral turpitude. He was suspended for three years, with
9 actual suspension for two years. The judges, two women and one man, appeared
10 to buy into his bogus defense of being a sex/love addict. See pp.6-7 of the ruling.
11 Sex and love were not the issue, even addiction to either or both. A crime against
12 children was.
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22.
In February 2014, the California Supreme Court surprisingly reversed
14 the Review Court and disbarred him, while retaining Kamansky who is alleged not
15 only to possess child porn like Grant, but actually sexually abused at least three, if
16 not more, children using his judicial authority to obtain custody of the children
17 for the sole purpose of sexually abusing them.
23.
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Thus, female (for the most part) protective parents and their
19 children suffering from sexual abuse do not stand a chance. It in this so-called
20 justice system in which Dillon and A.D. found themselves when Srikureja began
21 his campaign to wrest custody from Dillon so that he was free to molest A.D. at
22 his pleasure.
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24.
Although the Court awarded Dillon sole custody of A.D. when she
24 was nine months old, after Srikureja filed a motion for modification of custody in
25 2010, Dillon agreed to joint custody. A.D. then began to disclose that Srikureja
26 was sexually abusing her. A.D. reported on multiple occasions that she was being
27 sexually abused by Srikureja. A.D. exhibited physical symptoms of sexual abuse,
28 and two medical professionalsthe childs psychologist and her treating
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1 physician firmly believed that the abuse was real. And yet the court awarded
2 sole custody of A.D. to Srikureja.
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25.
This is consistent with the nation wide, state wide, county wide
4 pattern and practice of awarding custody to the alleged abuser and punishing the
5 protective parent, almost exclusively, the mother, by denying her access to the
6 child she is trying to protect and turning the child over to the abuser.
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26.
Srikureja, Srikurejas attorneys, in particular, La Flamme, notorious
8 for his betrayal of his vulnerable clients and support of abusive fathers, Srikurejas
9 close friend with a MFT license, his two sisters, nannies, a police officer, members
10 of the D.A.s office, social workers, and visitation monitors participated in a
11 conspiracy to hide and suppress all the evidence of A.D.s abuse, to insure that
12 Dillon and A.D. would not have access to each other, and Srikureja would have
13 custody of A.D. despite the fact she repeatedly disclosed that Srikureja was
14 sexually abusing her.
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27.
The conspiracy reached high places, and included DEFENDANT AL
16 STOKKE (Stokke), Srikurejas attorney and members of the District Attorneys

17 Office who took over the investigation of the sexual abuse charges.
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28.
Rackauckas and Stokke, who not only contributes but also raises
19 campaign funds for Rackauckas, have informally agreed that Stokkes clients will
20 generally not be prosecuted or they will enter into a collusive sweetheart plea
21 agreement for Stokkes clients. Srikureja also may well have donated campaign
22 funds to Rackauckas.
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29.
Srikureja abandoned A.D. in June 2013. He fled to Canada on June
24 29, 2013 one day after Tustin Police Dept informed the D.A. it was
25 recommending prosecution of Srikureja on six felony counts of sex abuse of A.D.
26 He is not a citizen of Canada but rather of Thailand. The United States will not
27 allow him to re-enter the country.
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30.
The jurists, Commissioner Wilson (Comm. Wilson), Judge James

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1 L. Waltz (J. Waltz) and Judge Glenn R. Salter (J. Salter) , assigned to the
2 family law department of Court were willing participants in this conspiracy.
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31.
The judgment of J. Waltz entered in July 2013 giving Srikureja full
4 custody and ruling that Dillon had coached A.D. to allege charges of sexual abuse
5 against Srikureja began unraveling in J. Salters courtroom. The custodial parent
6 was nowhere around and not enforcing his right of custody. There was enormous
7 negative publicity in newspapers, on T.V., on the internet, and the radio against J.
8 Salter, the court, the D.A., and LaFlamme. A review of the Robing Room ratings
9 of J. Salter are among the worst any judge has received, given what this writer has
10 reviewed, about 48 ratings, only 3 of which are positive, and the rest, extremely
11 negative and mostly about what he was doing to Dillon and A.D.
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32.
Judge Salter began to attack and threatened all those who supported
13 A.D., including Dean Tong, a former potential expert witness for Srikureja,
14 Merritt McKeon, who at one time served as Dillons appellate attorney, Allan
15 Gleisinger, who is Dillons husband, Ron Funk who took on the case in J. Salters
16 courtroom in 2014 and also filed writ petitions and briefs in the Court of Appeals,
17 and Thea Reinhart, who was A.D.s court-appointed therapist whose opinion was
18 that A.D. was credible, Dillon should have exclusive custody, and Srikureja had
19 most likely molested A.D. and should be placed in supervised visitation.
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33.
On May 7, 2014, J. Salter ordered his courtroom bailiff
21 DEFENDANT HOWARD CHANG (Chang) to falsely arrest and falsely

22 imprison Dillon on an eight year old failure- to- appear for traffic-related offenses
23 of which Dillon was unaware. For the first time since he had taken over the case,
24 and after Dillon had made numerous appearances, he claimed he did not know
25 who Dillon was and ordered her arrested.
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34.
In August 2014, J. Salter ordered A.D. to Napa County where on
27 information and belief A.D. is forced to live with a virtual stranger,

28 DEFENDANT EVA SRIKUREJA , (Eva), the wife of Srikurejas brother. She
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1 of course is not a blood relation of A.D. On information and belief, she is abusive
2 to A.D. because she, along with Srikurejas sister Pravit, refuse to accept that
3 Srikureja sexually abused A.D. and are punishing her for saying he did.
4
35.
After five years of custody litigation in Orange Superior Court, no
5 one in California has an order of custody and no one knows where A.D. is. She
6 may well be out of state or out of the country since she is not registered in any
7 school in Napa. J. Salter has disappeared A.D.
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36.
Another way that female protective parents, like Dillon, and their
9 abused children, like A.D. lose out is the court itself in which the die is cast. In
10 this case, Police officers wanted to file, or perhaps had filed, a juvenile court
11 petition. Defendant social workers, working hand in glove and at the behest of
12 LaFlamme, possibly Rackauckas office, put the kibosh on the petition - twice.
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37.
In Family Court, when a mother alleges abuse by the father of the
14 children, the mother goes on trial, not the father. The case becomes about the
15 mother reporting what her children are telling her, and not about what the father is
16 doing to the children.
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38.
In the macabre ritual which child abuse cases have become in family
18 court, the mother is labeled with the scarlet A (alienator). The accused father
19 and his supporters need only label the mother an alienator, and immediately the
20 burden shifts to the mother to prove the negative, that she is not. The father
21 generally can avoid rebutting the forensic evidence accumulating against him
22 simply by attacking the mother.
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39.
Further, as Srikureja and LaFlamme did, aided and abetted by a
24 commissioner and two judges, they simply quashed the testimony of the childs
25 medical expert and her therapist by hijacking A.D.s privilege in a patriarchal
26 twist of the law turning her privilege against her in favor of the man abusing her.
27
40.
If the defendant social workers had not been a part of the gender-
28 based conspiracy to deprive Dillon and her daughter of due process and equal
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1 protection, had a will to protect A.D., and had joined forces with the police to file
2 a petition in juvenile court, the outcome for A.D. and her mother would have been
3 the very opposite.
4
41.
Defendants forced Dillon and A.D. into the family law forum
5 knowing that civil rules of evidence apply and the focus was on Dillon, and not on
6 A.D.; whereas, dependency court has two hearsay exceptions which would have
7 allowed A.D.s out-of-court statements about sexual abuse into evidence.
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42.
Thus, the out-of-court statements of A.D. about sexual abuse most
9 likely would have been admitted because they were disclosed to police officers,
10 social workers, and health care practitioners. And the exit order back to family
11 court would have been a permanent restraining order against Srikureja, supervised
12 visitation, and sole legal and physical custody of A.D. to Dillon.
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43.
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As a nation we say we care about childrens safety and welfare. Yet,

as a society we tend to view custody as a contest between a
winner and a loser, not as a series of questions about the
conditions under which women mother, and men father, and children
grow up and about who determines these conditions.
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Our focus must shift from resolving custody by force, and in antimother ways, to a more civilized resolution of our child-care
arrangements. ....
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Public hearings on custody are urgently needed, Such hearings could

inform the public that all mothers are custodially vulnerable because
they are women; that all fathers, including incestuous [as in this
case] , violent, absent, [as in this case], passive, or helper Fathers,
can win custody, not because mothers are unfitor because fathers
are truly equal parents but because fathers are men, and that all
custodial mothers and children are impoverished against their will,
both by individual fathers and by the legislators. Mothers on Trial,
Phyllis Chesler, Preface, pp.xv-xvi.
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JURISDICTION AND VENUE
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What basic rights should every child be guaranteed by a civilized

society? Do children have the right to be mothered and fathered in
loving and non-violent ways? Are childrens needs being met by the
patriarchal family during marriage or by the patriarchal state after
divorce? ....
44.
The Court has jurisdiction over this action pursuant to 28 U. S.C.
28 Sec.1331 (federal question), 42 U.S.C. Sec. 2000d-7(a)(1) & (2) , and under 28
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1 U.S.C. Sec.1367(a) (supplemental jurisdiction based on the same core of facts on

2 which the federal claims are based). Venue lies in this district since the claims
3 arose and most of the defendants are located in the Central District of California.
PARTIES
4
5
45.
Dillon is the Mother of A.D. and currently is living in Canada. She
6 is a Canadian citizen. She resided in DEFENDANT COUNTY OF ORANGE

7 during almost all the time the acts alleged in this complaint occurred.
8
46.
A.D. is the minor daughter of Dillon and Srikureja. She is ten years
9 old and her birthdate is October 17, 2004. She is a victim of child sexual abuse by
10 Srikureja.
11
47.
La Flamme is an attorney licensed to practice in the courts of
12 California. He engaged in a conspiracy to hide and suppress the evidence of

13 Srikurejas sexual abuse of A.D., to deprive Dillon of custody of A.D., A.D. of
14 access to her Mother , and to insure custody of A.D. to Srikureja. He violated his
15 fiduciary duty to A.D. and committed legal malpractice against her. He is
16 responsible for the acts of which Dillon complains. He is a recipient of federal
17 funds and was receiving them at the time he was minors counsel for A.D.
18
48.
DEFENDANT ROBERT MUNOZ (Munoz) is a former social
19 worker employee of DEFENDANT COUNTY OF ORANGE Social Services

20 Agency, Division of Children and Family Services (DCFS). He conspired to
21 hide and suppress the evidence of sexual abuse of A.D. by Srikureja, to deprive
22 A.D. of access to her Mother, to deprive Dillon of custody of A.D., and to insure
23 that Srikureja would be awarded custody of A.D.
24
49.
Munoz engaged in felony perjury by falsifying his credentials on the
25 stand and by rendering opinions related to the custody of A.D. which were false
26 and had no factual or legal foundation, resulting in the Court awarding custody to
27 Srikureja. County terminated Munoz from employment, on information and
28 belief, because of his felony perjury in A.D.s custody case. He is sued in his
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1 individual capacity.
2
50.
Srikureja is the father of A.D., currently residing in Canada. He is a
3 citizen of Thailand. He left the U.S. on June 29, 2013 and has abandoned A. D.
4 He sexually, physically, and emotionally abused A.D. thus directly violating her
5 right to bodily and emotional integrity. He also defamed Dillon.
6
51.
California is a state and a recipient of federal funds. It is liable to
7 Dillon and A.D. for the gender discrimination and retaliation committed by the
8 other defendants resulting in deprivation of fundamental family rights and denial
9 of equal protection and due process. It is liable for aiding and abetting Srikurejas
10 violation of R.M.s right to bodily and emotional integrity by failing to insure that
11 public funds did not get into the hands of individuals like the defendant social
12 workers and LaFlamme who protect pedophiles and harm children. California is
13 liable for the public funds it paid to La Flamme, to the County, and to the Court.
14
52.
Court is a public entity created by state statute and the California
15 Constitution. It is a part of the state government. It is a recipient of federal funds.

16 It is liable to Dillon and A.D. for the gender discrimination and retaliation
17 committed by the other defendants resulting in deprivation of Dillons and A.D.s
18 fundamental family rights and denial of their right to equal protection and due
19 process. It is liable to A.D. for aiding and abetting Srikurejas violation of
20 A.D.s right to bodily and emotional integrity by failing to insure that the funds
21 did not get into the hands of individuals like LaFlamme or were used to pay for the
22 salaries of judges like J. Waltz and J. Salter.
Court is liable for the public
23 funds it paid to La Flamme.

24
53.
DEFENDANT COUNTY OF ORANGE (County) is a public entity
25 existing by reason of the constitution and laws of the State of California. Its
26 policies, customs, practices, and procedures caused the constitutional violations of
27 which Dillon and A.D. complain.
28
54.
County is also a recipient of federal funds. As such, it is also liable to

13
1 Dillon and A.D. for the gender discrimination and retaliation committed by the
2 other defendants resulting in deprivation of fundamental family rights and denial
3 of equal protection and due process. It is liable to A.D. for aiding and abetting
4 violation of A.D.s right to bodily and emotional integrity by failing to insure that
5 the funds did not get into the hands of individuals like the defendant social
6 workers and LaFlamme who support pedophiles and harm children. The County is
7 liable for the public funds it paid to La Flamme.
8
55.
DEFENDANT ROSANNE FROEBERG (Froeberg) is a deputy
9 district attorney employed in the Orange County District Attorneys Office. She
10 conspired with the other defendants to hide and suppress the evidence of sexual
11 abuse Srikureja inflicted on A.D., to deprive A.D. of access to her Mother , to
12 deprive Dillon of custody of A.D., and to insure that Srikureja would be awarded
13 custody of A.D. She took over the investigation of sexual abuse of A.D.,
14 suppressed evidence of A.D.s sexual abuse, denied Dillon access to the Countys
15 records of investigation, and falsely reported that no abuse had occurred. She
16 attempted unethical ex parte contact with J. Salter. She is sued in her individual
17 capacity.
18
56.
Rackauckas is the Orange County District Attorney. DEFENDANT
19 ALAN STOKKE and Rackauckas have had a long term personal quid pro quo
20 relationship whereby Stokke donates to Rackauckas campaigns and urges others
21 to make political donations to him in exchange for which Rackauckas will not
22 prosecute Stokkes clients or go very lightly on them.
23
57.
On information and belief, Rackauckas personally insured or
24 indirectly or directly conveyed to Froeberg that she was to close her

25 investigation of Srikureja finding no evidence of sexual abuse. Stokke was in
26 contact with Rackauckas office to insure that Srikureja and other individuals
27 recommended for prosecution by the County Sheriff Department and Tustin
28 Police Dept would not be prosecuted , namely, Defendants Edgar, Cate, Nash,
14
1 P.A. Nash & Associates , Munoz, and Coleman. He is sued in his individual
2 capacity.
3
58.
DEFENDANT BONNIE BREEZE is a police officer employed by
4 Tustin Police Dept. She suppressed evidence of A.D.s sexual abuse and testified
5 to matters for which she had no expertise in order to insure that Srikureja would be
6 awarded custody, Dillon would have custody of A.D. taken from her, and A.D.
7 would not have access to Dillon . She is sued in her individual capacity.
8
59.
DEFENDANT MAUREEN NAGANUMA (Naganuma) is a social
9 worker employed by County DCFS. She participated in a conspiracy to suppress

10 evidence of A.D.s sexual abuse and to falsify reports. She is sued in her
12
60.
DEFENDANT C. J. WILKINSON (Wilkinson) is a social worker
13 employed by County DCFS. He participated in a conspiracy to suppress evidence

14 of A.D.s sexual abuse and to falsify reports. he is sued in his individual capacity.
15
61.
DEFENDANT KRISTEN EITNER (Eitner) is a social worker
16 employed by County DCFS. She participated in a conspiracy to suppress evidence

17 of A.D.s sexual abuse and to falsify reports. She is sued in her individual
18 capacity.
19
62.
DEFENDANT BIRUTE BRUZAS-RANES (Bruzas-Ranes) is a
20 social worker employed by County DCFS. She participated in a conspiracy to

21 suppress evidence of A.D.s sexual abuse and to falsify reports. She is sued in her
23
63.
DEFENDANT JILL LUX (Lux) is a social worker employed by
24 County DCFS. She participated in a conspiracy to suppress evidence of A.D.s

25 sexual abuse and to falsify reports. She is sued in her individual capacity.
26
64.
DEFENDANT D'ALICIA MARRON-TAYLOR (Marron-Taylor) is
27 a social worker employed by County DCFS. She participated in a conspiracy to

28 suppress evidence of A.D.s sexual abuse and to falsify reports. She is sued in her
15
2
65.
DEFENDANT DAVID GLIDDEN is a social worker employed by
3 County DCFS. he participated in a conspiracy to suppress evidence of A.D.s

4 sexual abuse and to falsify reports. He is sued in his individual capacity.
5
66.
DEFENDANT JENNIFER PALMQUIST is a social worker

8 capacity.
9
67.
DEFENDANT DENISE JOHNSON is a social worker employed by
10 County DCFS. She participated in a conspiracy to suppress evidence of A.D.s

11 sexual abuse and to falsify reports. She is sued in her individual capacity.
12
68.
DEFENDANT JESSICA CHLEBOWSKI is a social worker

15 capacity.
16
69.
THOMAS MALABAN (Malaban) is a social worker employed by
17 County DCFS. He participated in a conspiracy to suppress evidence of A.D.s

18 sexual abuse and to falsify reports. He also failed to refer A.D. for a forensic
19 sexual abuse exam. He is sued in his individual capacity.
20
70.
Chang is a deputy sheriff employed by the County. He is assigned as
21 a bailiff to J. Salters courtroom at Lamoreaux Center in Orange, California. He

22 falsely arrested and had Dillon imprisoned on May 7, 2014. He is sued in his
24
71.
Cate is an attorney licensed to practice in California. Cate replaced
25 LaFlamme as minors counsel. He participated in the conspiracy to hide and

26 suppress evidence of A.D.s sexual abuse, to insure custody to Srikureja, to deny
27 his client A.D. access to her Mother. He joined with other supporters of Srikureja
28 to send A.D. to Napa where she has been held prisoner by DEFENDANT EVA
16
1 SRIKUREJA whom she barely knows. Eva is the estranged wife of

2 SRIKUREJAs brother who lost his medical license in several states. Cate
3 breached his fiduciary duty to A.D. and committed legal malpractice against her.
4 Orange County Sheriff Department recommended to the D.A. Cate be prosecuted.
5 Rackauckas declined based on his pay-to-play agreement with Stokke.
6
72.
DEFENDANT ALAN STOKKE (Stokke) is an attorney licensed to
7 practice in California. Srikureja retained him as his criminal attorney to insure that
8 Rackauckas would not prosecute him for criminal child sexual abuse. Stokkes
9 unethical relationship with Rackauckas is well documented and the subject of
10 Orange County Grand Jury Reports. He was part of the conspiracy to hide and
11 suppress evidence of A.D.s sexual abuse, to insure custody to Srikureja, to deny
12 his client A.D. access to her Mother .
13
73.
DEFENDANT MATTHEW DE ARMEY (De Armey) is an
14 attorney licensed to practice in California. Srikureja retained him as his family law
15 attorney. De Armey pushed the Court to appoint LaFlamme as minors counsel.
16 De Armey knew that LaFlamme would protect Srikureja and sacrificed the health,
17 safety, and welfare of his own client, A.D. Stokke, De Armey, and La Flamme
18 worked hand in glove to suppress all evidence of Srikurejas sexual abuse, defeat
19 Dillon and A.D. and insure that Srikureja would have custody of A.D.
20
74.
DEFENDANT GRACE COLEMAN (Coleman) is a close friend of
21 Srikureja and had lived with him for three years. She is a marriage and family
22 therapist. Coleman violated a court order by conducting therapy with A.D. in
23 which she attempted to make A.D. recant that she was sexually abused by
24 Srikureja, wrote falsified reports which she provided to De Armey who in turn
25 provided her falsified, unethical, and unauthorized reports of therapy to
26 Froeberg who used them, in part, to say that A.D. was not sexually abused.
27 Because of Stokkes and Rackauckas unethical relationship, Rackauckas declined
28 to prosecute Coleman for interference with a witness although she was
17
1 recommended for prosecution by Tustin Police Department.

2
75.
DEFENDANT EVA SRIKUREJA (Eva) is the estranged wife of
3 Srikurejas brother. She has had little contact with A.D. and yet she agreed to
4 have A.D. live with her in Napa. A.D. wants to be with her Mother . Eva has
5 kept A.D. from her Mother for over six months. Dillon has no idea what
6 condition her daughter is in, even whether she is attending school, whether she has
7 suffered any illness, or whether she is safe. Eva does not have an order of custody
8 of A.D. Orange Superior Court found her to be an unsuitable guardian for A.D.
9 and dismissed her guardianship petition. On information and belief she is abusing
10 and neglecting A.D. unless she has shipped her off somewhere else because she
11 dislikes her for reporting that Srikureja sexually abused her.
12
76.
DEFENDANT PRAVIT SRIKUREJA (Pravit) took custody of
13 A.D. without a court order and literally held her prisoner after her brother
14 Srikureja fled the country in fear he would be criminally prosecuted for sexually
15 abusing A.D. On information and belief she abused and neglected A.D. because
16 she dislikes her for reporting that Srikureja sexually abused her. She participated
17 in the conspiracy to deny custody to Dillon, deny A.D. access to her Mother , and
18 insure her absentee brother would retain custody.
19
77.
DEFENDANT ELIZABETH RAMIREZ LOCKMER (Lockmer)
20 served as a so-called nanny for A.D. She abused and neglected A.D. and filed
21 falsified declarations with the Court.
22
78.
DEFENDANT CAROL STEWART (Stewart) was employed by
23 DEFENDANT P.A. NASH & ASSOCIATES and in that capacity served as

24 visitation monitor for the visits between Dillon and A.D. Stewart falsified
25 information in her reports and defamed Dillon. She participated in the conspiracy
26 to suppress evidence of Srikurejas sexual abuse of A.D., deny custody to Dillon,
27 deny A.D. access to her Mother , and insure Srikureja would retain custody. The
28 police department recommended that she be prosecuted criminally. Rackauckas
18
1 insured she would not be prosecuted just as he insured that Srikureja, Attorney
2 Edgar, Attorney Cate, Munoz, and Coleman would not be prosecuted.
3
79.
DEFENDANT PATRICIA NASH is the owner of DEFENDANT
4 P.A. NASH & ASSOCIATES. LaFlamme handpicked her and her company to
5 serve as visitation monitor for the visits between Dillon and A.D. Stewart falsified
6 information in her reports and defamed Dillon. She participated in the conspiracy
7 to deny custody to Dillon, deny A.D. access to her Mother , and insure Srikureja
8 would retain custody. The police department recommended that she be prosecuted
9 criminally. Rackauckas insured she would not be prosecuted just as he insured
10 that Srikureja, Attorney Edgar, Attorney Cate, Munoz, and Coleman would not be
11 prosecuted.
12
80.
DEFENDANT P.A. NASH & ASSOCIATES is the company owned
13 by Nash. As such it is responsible for the acts of Nash and Stewart based on
14 respondeat superior.
15
81.
Defendants DOE 1 through DOE 10, inclusive, are sued herein under
16 fictitious names. Their true names and capacities are unknown to Dillon. When
17 their true names and capacities are ascertained, Dillon will amend this complaint
18 by inserting their true names and capacities herein. Dillon is informed and believes
19 and thereupon alleges that each of the fictitiously-named defendants is responsible
20 in some manner for the occurrences herein alleged, and that Dillons damages as
21 herein alleged were proximately caused by those defendants.
22
82.
Dillon is informed and believes and thereupon alleges that at all times
23 herein mentioned each of the defendants was the agent of each of the remaining
24 defendants, and in doing the things herein alleged, was acting within the scope of
25 his/her agency with one another.
STATEMENT OF FACTS
26
27
83.
In April 2005, Dillon left Srikureja when A.D. was 6 months old. In
28 July 2005, the Court awarded Dillon sole physical custody and Srikureja,
19
1 visitation.
2
84.
Before he filed a motion to modify custody which was in November
3 2010, Srikureja began sending bizarre texts to Dillon asking rhetorically what was
4 wrong with A.D. having sex and in what ended up to be prescient statements,
5 given his subsequent sexual abuse of A.D., that she would be having sex by the
6 time she turned seven.
7
7. Shortly after Srikureja filed his motion, Dillon and Srikureja signed a
8 stipulation providing for shared physical custody after Dillon was misled into
9 believing there had to be joint custody before a judge would order a custody
10 evaluation which she wanted. Shortly thereafter, A.D. reported incidents Dillon
11 found troubling, such as Srikureja sleeping naked in the same bed as A.D. with his
12 penis up against A.D.
13
85.
By 2011, A.D. started to show physical symptoms of abuse. On
14 February 25, 2011, A.D. informed Dillon that she had been bleeding from her
15 rectum, and Dillon observed blood on the toilet A.D. had been using. Dillon
16 immediately took A.D. to the emergency room, where doctors diagnosed A.D.
17 with three anal fissures. The treating doctor informed Dillon that he had never
18 seen three fissures so large in his seventeen years of practice, and that the fissures
19 may have been caused by non-accidental trauma.
20
86.
The incident and the doctors diagnosis were reported to CPS that
21 same day. Malaban, the CPS investigator, ultimately deemed the possibility of
22 abuse unfounded because, according to CPS personnel, six-year-old A.D. did
23 not disclose sexual abuse when interviewed. Malaban failed to refer A.D. for a
24 forensic medical exam citing "the child most likely had perinatal fissures that bled
25 from constipation and an ongoing custody battle" although an ongoing custody
26 battle cannot cause fissures in a childs rectum. Malaban was unqualified to
27 conclude that it was constipation, and squelched a referral for a forensic sex abuse
28 examination of A.D. Malaban also failed to interview collateral contacts.
20
87.
On March 1, 2011, the trial court appointed Dr. David Sheffner to
2 serve as the court-appointed child custody evaluator. Dr. Sheffner, a

3 specialist in forensic psychiatry, conducted numerous consultations with
4 Srikureja, Dillon, and A.D. over the ensuing five months.
5
88.
The Court also ordered both Dillon and Srikureja not to take A.D. to
6 therapists without an order.

7
89.
Srikureja defied the order and enlisted Coleman who has a California
8 MFT license and is Srikurejas close friend with whom he lived for three years to
9 engage in harmful, unethical, and fraudulent therapy with A.D. Coleman had 30
10 sessions with A.D. Dillon obtained six of Colemans "To Whom it May Concern"
11 letters which began in June 2011 and ended in May 2013.
12
90.
Colemans "To Whom it May Concern" letters were forwarded to
13 Stokke who provided them to Froeburg who on information and belief utilized the
14 letters in her investigation to conclude there was no or insufficient evidence to
15 prosecute Srikureja for sexual abuse of A.D. The dates of Colemans Letters
16 which Dillon was able to obtain are June 30, 2011, December 3, 2012, December
17 16, 2012, January 27, 2013, April 14, 2013, and May 30, 2013.
18
91.
Coleman claimed she was [A.D.]s therapist but had Srikureja
19 participate in the sessions, meaning that she knowingly forced the alleged victim
20 to talk about the abuse in the presence of the alleged abuser.
21
22
92.
On June 11, 2011, Coleman wrote:

--
I am writing this as an advocate for [[A.D.]]. [But the only

advocates the Court appointed for [A.D.] were LaFlamme
and Cate who ended up as advocates for Srikureja. The only
court- appointed therapist was Dr. Reinhart.]
I do not know [[A.D.]]'s mother.
I know her father, whom I have seen frequently with [A.D.],

[an underwhelming description of her relationship with
Srikureja and based on overwhelming deceit she had lived
with Srikureja for three years, whether it was sexual is not
known. She was a friend trying to get a friend out of trouble
and willing to risk her license in doing so. ]
23
24
25
26
27
28
21
93.
The letter goes on, waxing eloquent for Srikureja, turning the letter
2 into a paen to him and his fatherly abilities.

3
94.
On December 3, 2012, Coleman wrote that she and [A.D.] do not
4 discuss ... the legalities that are powerful forces that tend to eliminate or modify
5 her God-given right to spontaneity, confidence, and joy. Whatever that sentence
6 may mean, there is no question it is Coleman and Srikureja who smothered
7 [A.D.]s God-given right to spontaneity, confidence, and joy when they forced
8 [A.D.] to sit with them to discuss her sexual abuse allegations against Srikureja.
9
95.
Further, at this point, thanks to LaFlammes false allegation of
10 coaching, Judge Waltz had already placed Dillon in supervised visitation in July
11 2012, so that as of December 2012, A.D. had been in the exclusive clutches of
12 Coleman and Srikureja for five months.
13
96.
By December 16, 2012, Coleman, the unauthorized and contumacious
14 therapist was now defaming Reinhart, the authorized and legitimate court
15 appointed therapist, in her letter of same date claiming that [A.D.] had told her that
16 Reinhart told [A.D.] to keep her visit at [A.D.]s school a secret from Srikureja.
17 Reinhart was the therapist for A.D., not Coleman. Undermining Reinhart became
18 important since Reinhart had now reached the conclusion that A.D. was a victim
19 of sexual abuse.
20
97.
Coleman had good reason to rachet up the controversy. As of
21 December 2012, Tustin Police Dept had removed A.D. from her fathers custody
22 twice, on August 23, 2012, filing an affidavit of good cause that she was in danger
23 in her fathers custody and then in November 2012. On both occasions, the police
24 department had also filed juvenile court petitions, both of which were quashed by
25 social worker defendants acting in concert with LaFlamme, DeArmey, and
26 possibly, Stokke, if not Rackauckas himself or a deputy acting at his direction.
27
98.
There is no question that hundreds of thousands of dollars exchanged
28 hands from Srikureja to Stokke and DeArmey, Stokke continued to raise campaign
22
1 funds for Rackauckas, and LaFlamme misappropriated federal and other public
2 funds to protect Srikureja. LaFlamme and Srikureja probablycontributed to
3 Rackauckas campaign coffers.
4
99.
Srikureja, DeArmey, LaFlamme, and probably Stokkes only defense
5 to the growing body of evidence that Srikureja was sexually abusing A.D. was
6 that Dillon was coaching A.D. Their bias was obvious, particularly their financial
7 interest. Srikureja was paying these lawyers huge amounts of money and expected
8 results. They needed A.D. to say she was coached. Coleman came through for
9 them through her criminal interference with a witness, her deception and her
10 willingness to breach her code of ethics.
11
100. In her January 27, 2013, letter Coleman began, lightly, to state that
12 she now has learned that from A.D. that she was coached to lie about Srikureja.
13
101. Dr. Sheffner and Dr. Reinhart, the courts own experts, saw no
14 evidence of coaching. Sheffner made mandated reports on behalf of A.D. He

15 also testified that Dillon should have primary custody. Dr. Reinhart believed the
16 child and urged that Srikureja be placed in supervised visitation just as Dr.
17 Kanofsky, a gynecologist who examined A.D., had done. Both Reinhart and
18 Kanofsky made mandated reports and wrote to the Court about their concerns for
19 the safety of A.D. Twice Tustin Police Department had removed A,D. from
20 Srikureja because the officers concluded she was in danger in Srikurejas custody.
21 Tustin police officers found A.D. credible.
22
102. Coleman had to take action in the face of what the official experts and
23 the police department were saying. In her next letter dated April 14, 2013, almost
24 two years to the date that Coleman began her pernicious therapy, she ratcheted up
25 what she claimed A.D. was telling her: now the disclosures were because
26 Mommy made me do it.
27
103. Then, on May 30, 2013, Coleman made coaches out of anyone who
28 heard A.D. disclose that Srikureja was sexually abusing her - her mother, Dillons
23
1 husband Allen, Dillons friends Tanya Garrett and Sara Hill and A.D. was
2 forced to lie, be evasive and dishonest with Sheffner, Reinhart, and the police.
3 Coleman did not directly attack the official court appointees or the police; she just
4 made them dupes of the hapless little girl who was coached by so many people
5 the villains in the piece per Coleman.
6
104. Tustin Police Dept was having none of Colemans machinations.
7 Instead, a month later, Tustin P.D. recommended criminal prosecution of

8 Srikureja. They also investigated Coleman for dissuasion of a witness and
9 referred her to the D.A. for criminal prosecution. So far, Coleman has suffered no
10 consequences for her criminal and unethical actions against a vulnerable child
11 because of Rackauckas pay to play scheme.
12
105. On August 2, 2011, Dr. Sheffner released an 84-page report detailing
13 his recommendations. He recommended that Dillon be granted primary custody

14 during the school year, while Srikureja would have primary custody during the
15 summer. Dr. Sheffner concluded that [ Dillon ] was far more reasonable
16 /appropriate, . . . more flexible, manifested parental concerns, and her
17 verbalizations were more child-oriented, whereas [ Srikureja s] verbalizations
18 were more having to do with [ Dillon ]. Dr. Sheffner was especially concerned
19 with [ Srikureja s] quite prominent and chronic hostility toward [ Dillon ], and
20 his obstructionist attitude toward [A.D.] and [ Dillon s] relationship..
21
106. Dr. Sheffner briefly commented on the reports of abuse (which were
22 limited at that point) and Srikureja s counter-allegation that Dillon had coached
23 A.D. to make those reports. Dr. Sheffner could not conclude either molestation or
24 coaching had occurred, but noted that he had not received the [CPS] reports.
25
107. On January 2, 2012, CPS received a new report that A.D. may be the
26 victim of abuse. The next day, CPS conducted a CAST interview with A.D.,
27 during which A.D. stated that Srikureja had inappropriately kissed and touched
28 her, including on her genitals. CPS ultimately found these reports inconclusive.
24
1 CPS cited the on-going custody battle as a basis for questioning A.D.s claims,
2 stating that it is unclear whether or not the sexual abuse has occurred due to the
3 on-going custody battle. which does not make sense, because a custody battle
4 cannot cause sexual abuse to occur. It occurred because Srikureja was molesting
5 A.D.. The custody dispute arose because A.D.s mother sought to protect A.D.
6 which Srikureja did not like.
7
108. On January 26, 2012, CPS received another report of potential abuse,
8 this one from Dr. Myron Kanofsky, a gynecologist who had examined A.D. Dr.
9 Kanofsky not only referred his concerns to CPS, but provided a declaration to the
10 trial court stating that he was so concerned for [A.D.s] wellbeing that the court
11 should immediately suspend Srikureja s visitation rights. Dr. Kanofsky
12 explained that after examining and speaking with then-seven-year-old A.D., her
13 reports of abuse were credible, and the doctor believed they were true. Pursuant
14 to Dr. Kanofskys referral, CPS conducted a second CAST interview on January
15 30, 2012. A.D. again reported inappropriate touching by Srikureja.
16
109. On February 27, 2012, Naganuma consulted with Senior Social
17 Services Supervisor Bruzas-Ranes regarding the CAST interview "as it appeared

18 that the sexual abuse allegations could not be substantiated due to the child's
19 inconsistent statements and the possibility the child was coached". Bruzas-Ranes
20 concurred the child could be released to the father. CPS did not address the fact
21 that Dr. Kanofsky believed the allegations to be true.
22
110. In January 2012, Dillon requested that the court suspend Srikureja s
23 custody given the abuse allegations. Srikureja responded by requesting sole

24 custody pending trial, alleging that the abuse allegations were the result of
25 Dillons coaching. Commissioner Wilsonthen presiding over the caseheld
26 a hearing on February 24, 2012.
27
111. The two witnesses at the hearing were Robert Munoz, CPSs liaison
28 to the family court, and Detective Bonnie Breeze. Munoz was not involved in the
25
1 investigations but somehow got away with summarizing the CPS reports to date.
2 Breeze, who had investigated some of the abuse reports, admitted she had no
3 direct evidence of coaching. She agreed with a statement of Srikureja s counsel,
4 however, that A.D.s inability to answer certain questions was consistent with
5 coaching. Breeze had no factual basis for making this opinion nor was she
6 qualified to render such an opinion.
7
112.
Dillon called Dr. Kanofsky to testify, and Srikureja asserted the
8 doctor-patient privilege on A.D.s behalf. The court sustained the objection,

9 rejecting Dillon s claim that Srikureja had a conflict of interest in asserting the
10 objection. The court erred in allowing Srikureja the alleged perpetrator of the
11 abuseto assert the privilege to prevent Dr. Kanofsky from testifying. Conflict of
12 interest aside, California Family Code 3083 allows either custodial parent to
13 waive the childs privilege. In effect, the court allowed a privilege of the little girl
14 to be highjacked by her abuser and used for his benefit.
15
113. Besides excluding Dr. Kanofsky from testifying, Comm. Wilson
16 ignored letters from Dr. Sheffner in January and March 2012 informing her that
17 A. D. had consistently disclosed physical, sexual, and emotional abuse. She
18 asked rhetorically from the bench, What am I going to do with these letters?
19 This was the Courts expert and a mandated reporter. Yet, she did not compel the
20 Courts own expert to appear and testify on the issue of sexual abuse when he
21 could offer relevant evidence on the topic.
22
114. It did not come as any surprise that Comm. Wilson found there was
23 insufficient evidence to substantiate that A.D. was abused. The commissioner

24 then took a very dramatic step, a step which violated A.D.s right to ongoing and
25 frequent contact with her mother, and deliberately retained A.D. in a zone of
26 danger and expanded it. Comm. Wilson did not just decline to suspend
27 Srikurejas visitation, it granted him sole physical custody pending trial. The court
28 gave no reasons for this action other than finding the evidence of the abuse
26
1 allegations insufficient, having herself seen to it that she would not hear from two
2 mandated reporters on the issue, Dr. Kanofsky and Dr. Sheffner. The
3 commissioner did not address Srikurejas claim that Dillon coached A.D. but still
4 changed custody to the father. The commissioner did order therapy for A.D.
5
115.
When he learned that Dillons custody was reduced at the February
6 24, 2012 hearing Dr. Sheffner wrote the court recommending custody be switched
7 back to Dillon. In his letter dated March 9, 2012, to the court, Dr. Sheffner
8 quoted A.D.:
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
[A.D.] related 1)essentially the same statements regarding her father's

inappropriate behavior as she had related to me before; and 2)she
denied being coached ... and stated that the only adult who told her
not to tell the truth had been her father.... [A.D.] displayed a very
strong express desire, accompanied by distrust, to be reunited in her
mother's primary custody (this distress being to the point where,
as we discuss matters, she stated she wanted to speak to the
judge)." emphasis added.
116. To no avail. The letter was ignored and so was A.D. By this time it
was becoming apparent that unless the expert or witness was on board with Team
Srikureja, he or she would be ignored, glossed over, or humored even if court
appointed. Marginalization of court appointed professionals even judges -when they stand up for the child proves the deeply institutionalized and
entrenched patriarchal axioms applied to child custody cases throughout the
state courts.
117. On March 16, 2012, the court granted Srikureja s request to appoint
Minors counsel for A.D. DeArmey insisted that LaFlamme be appointed. The
Court agreed and appointed LaFlamme as A.D.s attorney. LaFlammes
appointment spelled the deathknell to A.D.s constitutional, human, and civil
rights as an abused child.
118. The conspiracy was sealed with the appointment of LaFlamme.
Neither LaFlamme nor DeArmey disclosed that DeArmey had represented
LaFlamme as his personal attorney in a private matter eight months prior. The
28
27
1 triumvirate of DeArmey, LaFlamme, and Stokke with Stokkes inside pipeline to

2 Rackauckas with huge amounts of money exchanging hands, including from the
3 public fisc to LaFlamme, guaranteed that the fix was in. A.D. did not have a
4 chance.
5
119. On June 4, 2012, Dr Sheffner wrote a letter to Judge Waltz, who had
6 replaced Commissioner Wilson following the February 2012 hearing, stating:
I am extremely concerned as to this child's welfare and my view is

she has experienced emotional deterioration since I first consulted
with a cheerful and vivacious girl I saw the spring... I fear for this
child and appealing to her attorney and the court to take immediate
action to be sure [that she gets the] professional help she so
desperately needs.
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
120. On June 11, 2012, J. Waltz called an emergency hearing for all
parties. J. Waltz stated, Mr. LaFlamme, upon getting this letter from the 730
evaluator I immediately called this hearing, what did you do? LaFlamme replied,
I sent my investigator to the childs school and she ( A. D.) said she doesnt want
to live anymore.
121.
On June 15, 2012, LaFlamme did select Dr. Thea Reinhart,
(Reinhart) a specialist in child sex abuse cases, as A.D.s therapist, of which

Dillon was unaware until later. But rather than provide therapy, LaFlamme wanted
Reinhart to indoctrinate her patient. It was his finding that A. D. was never
abused (how he knew this is not known) and Reinhart must treat A. D. to accept
this finding. LaFlamme expected brainwashing and gaslighting of the child, not
therapy. As therapy ensued Reinhart realized that A. D. was abused contrary to
LaFlammes insistence that none had occurred
122. On June, 21, 2012, Dillon filed a motion seeking modification of
custody. Dillon also requested that Dr. Sheffner be supplied CPS reports and
police records so that he could evaluate the allegations of physical, emotional and
sexual abuse. LaFlamme failed to provide Dr. Sheffner the childs CAST
interviews and police reports, although they were in LaFlammes possession. Dr.
28
28
1 Sheffner had to have those records in order to comply with Fam.C. Sec.3118(a)
2 which states in part that
The order appointing a child custody evaluator or investigator

pursuant to this section shall provide that the evaluator or investigator
have access to all juvenile court records pertaining to the child who is
the subject of the evaluation, investigation, or assessment.
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
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27
123. LaFlamme was doing everything to sabotage the custody evaluation

because it was clear that Dr. Sheffner was standing on adherence to the law and
protocol, and meeting his ethical obligations. He too had to be marginalized, if
not knocked out completely.
124. In July 2012, DeArmey requested that Dillons visitation be
monitored at all times just so LaFlamme could control A.D. and her disclosures. It
also allowed LaFlamme to hire a visitation monitor company which would do his
bidding. Dr. Kanofskys testimony having been barred, Dr. Sheffners letters and
recommendations and A.D.s repeated disclosures ignored, LaFlamme
assertedwithout support or explanationthat he believed there [was] every
possibility that [ Dillon ] was coaching the child.
125. J. Waltz granted DeArmeys request and ordered that Dillons
visitation be monitored solely on LaFlammes false and unsubstantiated allegation
of coaching, one of the two favorite mantras, besides alienator used by
abusive fathers, their attorneys, minors counsel, custody evaluators (Dr. Sheffner
an unusual exception), social workers, and judges throughout California against
female protective parents.
126. To summarize:
*
Dillon was the primary caretaker and sole custodian of A.D. from her
birth in 2004 to age 6, when in November 2010 Srikureja sought
custody and Dillon was misled into stipulating to 50/50 physical
custody. After her father had A.D. fifty percent of the time, A.D.
began to allege sex abuse by her father.
28
29
In February 2011 ER physician finds 3 fissues in A.D.s anus
after A.D reported a bloody rectum and her mother saw blood on
the toilet seat after A.D. had used the toilet. CPS finds allegation
unfounded.
evaluator.
6
7
*
*
In January 2012, A.D. reports abuse and CPS thinks it might be

because of custody battle.
10
11
In August 2011, Dr. Sheffner recommends that Dillon have primary

custody. He is not certain about sex abuse allegations.
8
9
In March 2011 Dr. Sheffner, a psychiatrist, is appointed as custody
In January 2012, Dr. Kanofsky examines A.D., concludes she is
12
victim of sexual abuse and Srikureja should be placed in
13
supervised visitation.
14
In January 2012, Comm. Wilson will not allow Dr. Kanofsky to
15
testify. But the commissioner wants to hear from Munoz, a social
16
worker, and Breeze, a Tustin police officer, both unqualified to
17
determine whether there was physical evidence consistent with sexual
18
abuse. On the basis of excluding the only medical testimony
19
available for that hearing and listening to the two unqualified
20
government employees, the commissioner gives sole physical
21
custody to the accused, the father.
22
appointed as minors counsel and J. Waltz goes along with it.
23
24
In March 2012, DeArmey conspires with LaFlamme to get him
In July 2012, LaFlamme insists that Dillon is coaching A.D. and
25
that she be placed in supervised visitation. J. Waltz gladly goes
26
along with his unsupported allegation and places Dillon in supervised
27
visitation.
28
127. Thus, a mom who had sole custody of a child from her birth to age 6
30
1 lost custody and was placed in supervised visitation within a year and a half after
2 the father filed a motion for custody only because medical doctors reported that
3 her daughter was being sexually abused. The likelihood of A.D. suffering grave
4 emotional harm due to maternal deprivation was obvious.
5
128. As alleged supra, LaFlamme had to have complete control of A.D.
6 and Dillon, besides manipulating the outcome in court with the judges as willing
7 participants. DeArmey having obtained the order of supervised visitation, La
8 Flamme personally selected Nash & Associates to monitor the visits between
9 Dillon and A.D. on or about July 20, 2012.
10
129. Despite this measure to eliminate Dillons alleged coaching, A.D.s
11 reports of abuse continued. On August 23, 2012, Dillon took A.D. to swim with
12 Dillons friend Tanya Garrett, and Garretts daughter. Stewart, LaFlammes
13 handpicked monitor, was present as well.
14
130. Outside of Dillon s presence, A.D. asked Garrett if she could tell
15 Garrett a secret, because her therapist said [she] needed to talk to a friend about
16 what is happening to [her]. A.D. then told Garrett, [w]hen I . . . see my dad I get
17 scared because he touches me on the inside and it hurts me. Garrett told A.D. to
18 repeat this statement to both Dillon and the monitor, and Dillon immediately
19 brought A.D. to the police station. CPS opened another investigation.
20
131.
Stewart called Nash who said to end the visit immediately and return
21 A.D. to her father in violation of her mandated reporting duties under the Penal
22 Code. Neither Stewart nor Nash made a mandated report. Dillon contacted
23 Newport Beach Police and an officer advised Dillon not to allow A.D. to be taken
24 to Srikureja and to bring her to Tustin Police Dept. immediately. Stewart
25 accompanied Dillon and A.D. to the Tustin Police Dept.
26
132. At the Police Department, Officer Mitchell interviewed Stewart,
27 Dillon, A.D., and Dillons driver, Michael Cooper. Stewart claimed that A.D. told
28 her in the lobby of the police department that A.D. has a secret phone to call her
31
1 mother, and her mother coached her to make the allegation. CPS jumped on the
2 secret phone coaching by Dillon to use against A.D. It was a silly allegation,
3 bordering on the absurd since by this time, A.D., was now in the complete control
4 of Srikureja, Coleman, and Lockmer, the nanny, who were all watching A.D. like a
5 hawk. Coleman was grilling her on a regular basis. LaFlamme was orchestrating
6 the debacle.
7
133. Tustin Police Officer Singleton called in the referral to the child
8 Abuse Registery. Eitner was the emergency response social worker. Officer
9 Singleton stated to Eitner that Srikureja had been touching A.D. with his hands
10 and fingers inside her private body parts and that she had seen the father's penis.
11 A.D. stated she had to sleep in her father's bed at which time he touched her
12 inappropriately and that she was forced to make videotapes. Officer Singleton
13 also said that it would be reported the father takes close-up photographs of her
14 body parts. Singleton also stated that Lockmer the nanny did not feed her enough
15 food. The officer stated A.D. is quite obviously intelligent and articulate and he
16 found her to be credible in her account and report of abuse by her father.
17
134. Eitner interviewed AD at police station at approx 11:30 pm after A.D.
18 had been sitting in the lobby of the Tustin Police Dept for almost eight hours.
19 Eitner described A.D. in her report as appearing to be awake and alert" knowing
20 full well she had to be awaken to conduct this interview.
21
135. During the interview AD reported physical and sexual abuse but
22 Eitner contacted the on-call supervisor Palmquist for consultation. Eitner told
23 Palmquist she had concerns about the child's credibility and the mother's
24 evasiveness, and the fact that the mother lost custody even though the loss of
25 custody was due to falsified testimony of Munoz and Breeze and the commissioner
26 barring Kanofsky from testifying.
27
136. Eitner cited concerns that the court did not follow Dr Sheffner's
28 recommendation that A.D. be placed back with her mother. Eitner also cited a
32
1 concern about the child not being returned to her mother, but then refused to
2 conduct an investigation, or at least speak to Dr Sheffner. Inexplicably, Eitner
3 stated that she did not feel comfortable taking A.D. into protective custody and
4 Palmquist concurred. Certainly, Eitner and Palmquist would have incurred the
5 wrath of an angry LaFlamme or possibly even Rackauckas if they had done so.
6
137. At this point Lt Tarpley stepped in and voiced his concerns that A.D.
7 had disclosed sexual abuse by her father to the social worker, his officer, and his
8 detective and vested his authority to take AD into protective custody without the
9 concurrence of the social workers(called a parachute).
10
138. On August 23, 2012, Tustin Police Department took A. D. into
11 protective custody. Officers filed a probable cause affidavit stating the reasons
12 why A. D. was in danger in Srikurejas custody. LaFlamme did not speak to the
13 detectives nor did he visit A. D. while she was at Orangewood, the Orange
14 County juvenile facility.
15
139. Despite A.D.s disclosures and the police departments conclusion
16 she was being abused by Srikureja Naganuma shockingly unfounded allegations

17 of sexual abuse. "The child has made statements alleging sexual abuse by her
18 father however the child has been found to be less than credible throughout the
19 investigation" This was a question begging, bootstrapping conclusion because
20 besides Srikureja, DeArmey, Stokke, and LaFlamme, the only other individuals
21 finding the child less than credible were the social workers following
22 LaFlammes lead and their custom and practice of unfounding allegations of
23 sexual abuse in child custody cases (where most child sexual abuse cases originate
24 since most children who suffer sexual abuse know their perpetrators). The
25 practice endures even in the face of the childs repeated disclosures with the
26 mother in supervised visitation and unable to coach.
27
140. DeArmey did his part in poisoning the well at CPS if it could be said
28 it needed poisoning. Naganuma's investigative report states in part:

33
... on August 24, 2012 intake Senior social worker Maureen

Naganuma received a telephone call from attorney Milo DeArmey...
He stated there of already been 2 cast interviews on this child.. He
stated that a social worker believed that the mother coached the child
into making the allegations... He stated that the child has been taken
to six or seven different police departments making allegations.. He
stated that the child has an attorney with Harold LaFlamme's office
and Shirley is the investigator.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
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20
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141. The only true statement DeArmey made to Naganuma was that
LaFlamme was A.D.s attorney (of sorts) and Shirley was LaFlammes
investigator. The truth is that A.D. had only been taken to one police department
which was Tustin. No social worker to date had ever stated that the mother
coached the child although bordering on it.
142. On August 24, 2012, Naganuma received a call from Sanchez.
Sanchez stated that the child has already had two CAST interviews. She stated
that the mother was found to have lied and to have coached the child. At that
point DeArmey, LaFlamme, and Sanchez had no evidence that Dillon had
coached A.D. or had lied.
143. On August 24, 2012, Naganuma contacted DeArmey. DeArmey
defamed Dillon stating that she had visits at FACES, a visitation monitoring
agency, but was kicked out which was false. He said the appointed monitor Hector
Delgadillo quit because Dillon was not complying with the exchanges. Delgadillo
tries to extort mothers forced into supervised visitation for money. He does not
follow the law by taking notes during the visits and making contemporaneous
reports, thereby allowing him to falsify reports depending on what the
unmonitored parent, the social worker, or someone like LaFlamme wants him to
report.
144. Delgadillo had extorted Dillon for $540 to monitor a ten minute
exchange whereby A.D. walked from one car to the other. He quit only when
Dillon demanded a receipt documenting this outrageous payment to him.
145. DeArmey also falsely informed Naganuma that a doctor's notes stated
28
34
1 the child was stressed from being coached. He indicated that Srikurejas criminal
2 defense attorney is Al Stokke and that Stokke instructed Srikureja, not to talk to
3 anyone. However, Srikureja was in a civil proceeding. If he chose to take the
4 Fifth it could be used against him as evidence of his guilt. Yet, Srikureja was
5 accorded all of his rights as if he were in criminal court being prosecuted;
6 whereas, Dillon and A.D. were stripped of every possible constitutional and
7 statutory right guaranteed in the family code and in federal law.
8
146. On August 27,2012 Naganuma received an email from DeArmey in
9 which he writes "the purpose of this letter is to provide you with facts and identify
10 documentation to assist you with your investigation into the allegations made by
11 [A.D.] on August 23, 2012. Naganuma apparently was impressed by the
12 information in DeArmeys unsolicited letter because she repeatedly
13 unfounded A.D.s repeated disclosures of sexual abuse. The letter was filled
14 with factual inconsistencies, lies, and libel of Dillon.
15
147.
Naganuma also did not have a problem with DeArmeys credibility
16 despite the fact that he was the attorney for the man A.D. was accusing of sexually
17 abusing her. Naganuma took no action to protect A.D. despite the mounting
18 evidence of Srikurejas sexual abuse of A.D.
19
148. On August 31, 2012, Eitner interviewed Carol Stewart the monitor.
20 Stewart confirmed the child disclosed allegations of sexual abuse by her father
21 during a monitored visit with her mother on August 23, 2012. She stated A.D. was
22 not alone with her mother anytime during the day at this visit or during the three
23 previous visits she monitored. She stated she was not aware of any coaching
24 occurring between the mother and the child on this day or previous days. Stewart
25 stated A.D. said, "when he touches me in my private parts, he puts his fingers in
26 me". Stewart said she believed that what A.D. was saying at that time was true.
27
149. Stewart also admitted that she called her employer Nash who told her
28 to end the visit and return A.D. to her nanny Lockmer. This in violation of the
35
1 Penal Code which requires that mandated reporters make a call to CPS Hotline.
2
150. After interviewing all the parties, Tustin Police Dept placed A.D. in
3 protective custody at Orangewood Juvenile Detention. On August 24, 2012,

4 Eitner conducted another CAST interview and unfounded the allegation despite
5 having the police report indicating that A.D. was credible. One of the reasons for
6 unfounding the allegation of A.D. was the secret phone allegation of Stewart.
7
151. On or about August 25, 2012, Dillon provided Eitner text messages
8 Srikureja sent Dillon in 2009 or 2010 in which he stated that there was nothing
9 wrong with A.D. having sex. She will probably be having sex by the time she was
10 seven years old. Srikureja also accused Dillon of having sex orgies at her house.
11 Dillon both faxed and emailed them to Eitner. Eitner denied receiving the text
12 messages besides unfounding A.D.s report of sexual abuse.
13
152. On August 27, 2012, CPS conducted another CAST interview with
14 A.D. A. D. told the interviewer that Srikureja had previously put his fingers
15 inside her rectum, and that Srikureja had been touching her for as long as she can
16 remember. CPS grabbed at straws to deem A.D.s claims inconclusive such as
17 whether Srikureja provided A.D. sufficient food or toys. In accordance with its
18 long-time pattern and practice, of never finding sex abuse when it originates in a
19 family law case, CPS established for reports about A.D. a screener alert stating
20 in capital letters, CUSTODY DISPUTE.
21
153. On August 28, 2012, Birute-Ranes consulted with Glidden regarding
22 releasing the child to her father. Astoundingly Glidden wrote: "Based on the lack
23 of evidence regarding abuse, it was decided that the application for petition would
24 be denied" Glidden was referring to the juvenile court petition filed by Tustin
25 Police Department on August 23, 2012.
26
154. On August 28, 2012, Dillon contacted Glidden. At that point she did
27 not know a juvenile court petition had been filed by Tustin Police Dept. Yet, CPS
28 records state Dillon learned on August 28, it was being dismissed which was
36
1 false. What Glidden did tell Dillon was that he would not be speaking with
2 Reinhart as LaFlamme claimed he held the privilege and not Reinhart as she
3 legally did, and would not release the privilege, which is nothing less than
4 covering up Srikurejas crime of sexual abuse.
5
155.
The psychoatherapist/patient privilege cited in Code of Civ Proced
6 Sec.1027 applies. It is the therapist and not the child who holds the privilege
7 because only the psychotherapist knows whether she believes 1027s criteria are
8 satisfied. People v. Caplan, 238 Cal. Rptr. 478, 486 (Ct. App. 1987). J. Waltz
9 permitted LaFlamme to invoke a privilege which [he] no longer held. Id. Only
10 Dr. Reinhart could invoke the privilege, and she had made clear that she would not
11 have because 1027s criteria were satisfied, namely, that it was in the best
12 interests of the child to disclose her statements about sexual abuse during therapy.
13
156.
Later Dillon learned from Lieut. Tarpley that it was LaFlamme who
14 took A. D. out of Orangewood and authorized that A. D. be placed back in the

15 custody and control of the alleged molester. Lieut Tarpley issued a directive to his
16 police department that no officer was to communicate with social services about
17 A.D.s case.
18
157. Dillon never learned about the secret phone allegation concocted by
19 Stewart and Nash (perhaps LaFlamme) until September 20, 2012, as far as Dillon
20 recollects. Dillon immediately contacted Lieutenant Tarpley, telling him there is
21 no secret phone. He advised her to continue the visits. Dillon did, and she also
22 began videotaping the visits.
23
158. During one visit, Dillon said to Stewart to the effect that she, Dillon,
24 was accused of having a secret phone and that she was using it to coach A.D.
25 Stewart said, isnt that ridiculous? It sounds like something out of a science
26 fiction movie. Dillon contacted Nash and recorded the conversation. Nash
27 denied any knowledge about a secret phone.
28
159. Dillon provided the videotape of her conversation with Stewart and
37
1 the recording of Nashs conversation to the Tustin police department. The police
2 department brought Nash and Stewart in for questioning. The police completed
3 the investigation. The department concluded that Nash and Stewart had lied about
4 the secret phone and had failed to make a mandated report about A.D.s disclosure
5 on August 23, 2012. The department recommended that both Stewart and Nash be
6 prosecuted for obstruction of justice and failing to make the mandated report.
7
160. The police department forwarded their 90-page investigation of
8 Stewart and Nash to the presiding judge of juvenile court, Judge Hatchimonji
9 around December 2012. Judge Hatchimonji did remove Stewart and Nash from
10 the approved provider list of visitation monitors. However, Nash & Associates is
11 now back on the approved provider list. The company, Nash, and Stewart have
12 suffered no consequences for concocting a story which gave CPS an excuse to
13 unfound the sexual abuse that A.D. had disclosed. Their false story contributed to
14 the return of A.D to Srikureja. And Stewart and Nash are back in business
15 through Orange Superior Court dealing with unsuspecting mothers forced into
16 supervised visitation because they, like Dillon, reported abuse of their children by
17 the respective fathers.
18
161. Dillon has never seen the police report on Nash and Stewart. Dillon
19 informed Judge Waltz what she knew about the report which was that Nash and
20 Stewart had lied about, and fabricated, the secret phone allegation. Dillon
21 needed the report also because when Stewart and Nash got off the case they
22 provided a letter about their resignation in which they defamed Dillon to Judge
23 Waltz sometime in November 2012.
24
162. Judge Waltz asked La Flamme about the report. LaFlamme said he
25 checked with Judge Hatchimonji and he said Judge Hatchimonji told him the
26 report does not exist. Judge Waltz turned to Dillon and told her, Sorry, Maam.
27 The report does not exist. Move on. Dillon checked again with Tustin Police
28 Dept and received confirmation that Judge Hatchimonji had indeed received the
38
1 report.
2
163. When J. Waltz recalled Munoz as his own expert witness in February
3 2013, at the custody trial, J. Waltz allowed Munoz to use the false allegation of
4 secret phone for coaching against Dillon.
5
164. J. Waltz relied in part to accuse Dillon of coaching A.D. in his
6 judgment based on Munozs inadmissible hearsay testimony about the lies of

7 Stewart and Nash. Yet, Dillon had already alerted J. Waltz there was a report
8 from Tustin Police Dept. about them. Dillon had even provided J. Waltz the
9 name of the judge, J. Hatchimonji, who had received the report. J. Waltz cared
10 not one whit to check with Judge Hatchimonji about whether the report existed,
11 and to obtain a copy of the report from either Judge Hatchimonji or Tustin P. D.
12 but chose to use the lies of Stewart and Nash against Dillon. J. Waltz did not
13 require Stewart and Nash to be present at trial so that Dillon could cross examine
14 them.
15
165. While the custody trial commenced in September 2012, the social
16 workers continued unfounding A.D.s disclosures and the findings of Tustin

17 Police Dept. On September 6, 2012, Naganuma spoke with Eitner who informed
18 Naganuma that LaFlamme did not give permission for the social worker to
19 contact Reinhart. LaFlamme was slamming all doors leading to the truth.
20
166. In September 2012, Naganuma reviewed Eitners investigative
21 narrative of her (Eitners) interview of A.D. on August 23, 2012. In the report,
22 Eitner had cut and pasted Tustin Police Officer Singleton's into her report.
23 Singleton reported that he found A.D.s disclosure of sexual abuse to be credible.
24
167. Eitner's report also documented another call by Sanchez in a
25 September 14, 2012, telephone conversation in which Sanchez defamed Dillon

26 and otherwise lied:
27
28
1.
Mothers visits were monitored by Hector Delgadillo who said

she was "too manipulative" which was untrue.
39
2.
A Dr Sarmiento stopped treating A.D. after a four hour custody
visit at her office in which paramedics and the fire department
were called to the doctors office which never happened;
3.
to no longer have any contact with D.A., also untrue.
5
6
Sanchez said the custody evaluator, Dr. Sheffner, was ordered
168. As could be expected, Naganuma unfounded the allegations of
7 sexual abuse. Eitner was more cautious -- she said the allegations were
8 inconclusive.
9
169. Like all social workers throughout California and especially in
10 Orange County, Eitner, Naganuma, and the other social worker defendants,
11 repeatedly nit-pick what a child tells them. They did not attempt to elicit a
12 genuine response from A.D. They invented tests to confuse A.D., to put her on
13 the defensive, and to intimidate her. A.D. told Dillon that they were "mean" to
14 her.
15
170. As an example of nit picking and gotcha investigation, Dillon had
16 informed Naganuma that Reinhart called her and asked if Srikureja had long
17 fingernails. Naganuma chose to engage in a phone tree game where she used
18 hearsay on top of hearsay to determine credibility. Rather than ask Reinhart
19 straight out whether she had contacted Dillon about the length of Srikurejas
20 fingernails, Naganuma asked Detective Hardacre, Tustin Police Dept, about who
21 called whom on the fingernails length.
He claimed that Reinhart denied asking
22 the mother and that Reinhart said that Dillon contacted her about the fingernails.
23
171. "Due to these inconsistencies, Naganuma is unable to substantiate the
24 allegations of sexual abuse or general neglect of the child by her father" based
25 solely on a third partys claim of who called whom about the length of fingernails
26 of the alleged perpetrator. On September 14, 2012, Naganuma closed her
27 Investigation which was approved by Birute-Ranes, since who called whom about
28 the length of Srikurejas fingernails had become the deal breaker.
40
172. Later, Dillon learned from Lieut. Tarpley and Reinhart that Reinhart
2 informed Tustin Police Dept that it was she who asked Dillon (and not the reverse)
3 about Srikurejas fingernails length. A.D. was just the length of Srikurejas
4 fingernails away from her freedom, protection, and safety, if only Naganuma had
5 asked Reinhart directly about who had called whom about them.
6
173. According to the notes of the social workers, as of September 2012,
7 the social workers were calling the file on A.D. a Z file because the "child's
8 parent may contact OC Weekly and this could possibly become a media case this
9 is a family law custody battle. The characterization, family law custody battle
10 is a worn-out cliche which has outlived its usefulness, if it ever served a useful
11 purpose. A custody battle suggests evenly-matched opponents with equal
12 chances of getting custody. Child sexual abuse is a different issue in family court
13 meaning that the accused male has a head start, and Mother and Child spend their
14 time defending themselves rather than prosecuting their mutual claim for Child
15 protection from the Accused.
16
174. Trial commenced before Judge Waltz on September 18, 2012. By this
17 time the die was cast. A commissioner had taken custody from Dillon and would
18 not allow a gynecologist who examined A.D. to testify, using A.D.s privilege for
19 the fathers benefit in a patriarchal twist of the law. Judge Waltz had already
20 placed Dillon in supervised visitation in July 2012, just because LaFlamme said
21 Dillon was coaching A.D.
22
175. By the time of trial, the E.R. physicians findings of three fissures
23 were ignored or discredited (just problems with constipation, claimed an

24 unqualified social worker). As already alleged, Comm. Wilson wrongfully
25 excluded the testimony of Dr. Kanofsky at a prior hearing, and at the trial J.
26 Waltz would not allow the testimony of Dr. Reinhart based astoundingly on
27 A.D.s privilege once more highjacked, this time by her own attorney for the
28 benefit of the perpetrator. J. Waltz forbade Dr. Sheffner to give an opinion on
41
1 whether A.D. was sexually abused.

2
176.
DeArmey and LaFlamme also tried to remove Dr. Sheffner at the
3 beginning of trial. They did not succeed. Dr. Sheffner testified that he found A.
4 D. s verbalizations of abuse to be consistent and credible, that he was sidelined
5 and prevented from doing his job, that I dont know what kind of experiment
6 this court has been conducting but it has miserably failed , and that A. D. needs
7 to be back in the primary care of her mother.
8
177. In Eitners notes dated September 7, 2012, Eitner noted that she
9 spoke with Dr. Sheffner on that date . He requested all CPS records and reports
10 but Eitner failed to provide them to him, just as LaFlamme had done. Both Eitner
11 and LaFlamme violated Fam. C. 3118 which requires that all police and CPS
12 reports be provided the custody evaluator in a sex abuse investigation. On
13 information and belief, Eitner had knowledge of Dr. Sheffners March 9, 2012,
14 letter to the Court in which he stated he believed A.D. was consistent and that
15 custody should be reversed and restored to Dillon.
16
178. On the first day of trial, the court finally acted on the longstanding
17 request of Dr. Sheffner for access to the CPS reports. On learning that a court18 appointed evaluator has a statutory right to CPS records in sexual abuse cases, J.
19 Waltaz ordered that Dr. Sheffner be provided a copy of thembut expressed no
20 misgivings that Dr. Sheffner had been denied this statutory right to that point. Nor
21 did J. Waltz express concern that Dr. Sheffner had less than 24 hours to review
22 171-pages of single-spaced CPS records before he testified the next day, calling
23 him a quick study.
24
179. Dr. Sheffner testified that No child can be coached to this extent,
25 and I have no evidence that Ruby coached A. D. in fact there is evidence to the
26 contrary. Dr. Sheffner provided his assessment based on his many consultations
27 leading up to his report, as well as his review of the CPS reports given to him the
28 prior day. Dr. Sheffner concluded that Dillon should have primary custody.
42
180. Dr. Sheffner reiterated that since his initial report, there had been a
2 very new and dramatic important happening; namely, [A.D.s] concerning

3 verbalizations of sexual abuse.
4
181. Munoz, the CPS court liaison, also testified at trial. He was allowed,
5 apparently without objection from Dillons attorneys to distill the CPS

6 reportsprepared by officials other than Munozinto a summary of twelve
7 pages of excerpts, most of it containing inadmissible hearsay by out of court
8 declarants who were not subpoened to trial so that Dillon could cross examine
9 them.
10
182. As alleged several times, LaFlamme unethically, criminally (he was
11 covering up crimes of sexual abuse of a child), wrongfully invoked a privilege he

12 could not invoke on behalf of A.D. and refused to let Reinhart testify although as
13 already alleged Reinhart holds the privilege pursuant to CCP Sec.1027, and not
14 the child. Remarkably, neither the trial court nor LaFlamme offered a word on this
15 controlling provision, even though Dillon (acting pro per) cited it multiple times
16 in her trial filings. LaFlamme also failed to make proper evidentiary objections
17 on his clients behalf.
18
183. The trial court overlooked another statute that explicitly provides an
19 exception to the psychotherapist-patient privilegeCalifornia Penal Code

20 11171.2(b). Caplan, 238 Cal. Rptr. at 485. That statute applies to information
21 reported pursuant to mandatory reporter responsibilities. It dictates that [n]either
22 the physician-patient privilege nor the psychotherapist-patient privilege applies to
23 [such] information . . . in any court proceeding. Cal. Penal Code 11171.2(b)
24 (emphasis added). Any court proceeding means just thatthe privilege does
25 not apply in any litigation for information reported pursuant to mandatory duties.
26 See Roe v. Superior Court, 280 Cal. Rptr. 380, 382-83, 387 (Ct. App. 1991); In re
27 Troy D., 263 Cal. Rptr. 869, 875 (Ct. App. 1989).
28
184. At trial LaFlamme sided with DeArmey in every objection he made

43
1 and every position taken by DeArmey. On information and belief, LaFlamme has
2 always sided with the father and his attorney in a family law case where child
3 sexual abuse was alleged and against his client, i.e., the child he is supposed to be
4 advocating for, and protecting, her best interests.
5
185. LaFlamme recommended four hours of custody per week for Dillon
6 but did not give a reason why. LaFlamme accepted Munoz as an expert when he
7 should have challenged his credentials. He knew or should have known Munoz
8 had never met any of the parties including A. D.
9
186. Dillon informed the court that she had learned LaFlamme, had an
10 undisclosed conflict of interest with DeArmey. DeArmey who had pushed for
11 LaFlamme to be appointedhad represented LaFlamme in a personal matter eight
12 months prior to being appointed, and neither had disclosed the arrangement to the
13 court. Dillon provided a court record showing DeArmeys representation of
14 LaFlamme. Dillon requested that LaFlamme be removed from the case, a request
15 she repeated in a subsequent motion. The court did not respond to this request
16 when first made, and later denied Dillon s motion without explanation.
17
187. Following testimony on November 15, 2012, the court granted a
18 second adjournment until February 25, 2013, at which time Dillon was
19 proceeding pro per. The court stated it was exercising [its] right under the code to
20 call [its] own witness, and was recalling Munoz, the CPS liaison, to serve as the
21 courts expert. J. Waltz admitted that he had discussed this matter last week
22 with Munoz, now his expert, outside the presence of the parties. This brings
23 into question J. Waltzs unethical misconduct of meeting with a witness exparte
24 whom he had decided to make his own expert.
25
188. On September 27, 2012 Eitner attended a cast interview which was
26 conducted by Adriana Ball, Social Worker and forensic interviewer. During this
27 interview A.D. stated she is deprived of food at her fathers house, her father
28 touches and kisses her private parts (vagina, anus, chest) and puts his fingers
44
1 inside her "pee and poo hole". A.D. stated it hurts inside to pee and poop and that
2 she tells Srikureja to stop but that he does not stop. A.D. also stated Lockmer
3 deprived her of food and that Srikureja tells the nannies to lie in court. A.D. told
4 Eitner her father had touched her at least 20 to 30 times and had been doing it
5 since she was a baby. Still, Eitner did not detain A.D. and remove her from
6 Srikureja. Eitner filed no juvenile court petition, and no restraining order against
7 Srikureja.
8
189. On November 2, 2012, Dr. Reinhart made a mandated report with
9 new allegations of sexual abuse of A.D., anal penetration, occurring also on

10 November 2, 2012. CPS gave Reinharts report a dispo level one which means
11 immediate response within 24 hours. Lux and Senior Supervisor Marron-Taylor
12 did nothing until November 7, 2012, when Lieut Tarpley saw the referral cross his
13 desk and he immediately sent police officers to A.D.'s school to interview A.D.
14 Her statements were sufficient for Officer Tarpley to take A. D. into protective
15 custody and file the second juvenile court petition.
16
190. On November 7, 2012, Lux and Marron-Taylor rushed to A.D.'s
17 school to interview her before the police arrived.

18
191. Lux falsified her report and violated A.D.s right to have either her
19 mother or Reinhart present while Lux questioned her. Lux stated in her report that
20 the parents were provided a civil rights pamphlet in English and were advised of
21 the child abuse laws. This never happened, at least with respect to Dillon.
22
192. Lux stated that "child was informed of the right of refusal to be
23 interviewed and was informed that the interview would take place within 30
24 minutes. The child agreed to the interview and elected to be interviewed without
25 school personnel present." This was a Fourth Amendment violation about which
26 Lux knew or should have known. Lux falsely claimed that Detective Hardacre
27 reported that no criminal charges would be filed against Srikureja. In June 2013,
28 Tustin PD would file six felony counts of child sexual abuse against him.
45
193. Lux claimed that A.D. was informed of the court date, November 8,
2 2012, at 11:05 am. A.D. was desperate to be heard by a judge because Srikureja
3 continued to abuse her, and LaFlamme was covering up for him. Lux falsely
4 stated that Child did not want to attend the hearing.
5
194. Lux consulted with Marron-Taylor and informed her of the child's
6 statements and Marron-Taylor was in agreement to give A.D. back to Srikureja.

7 The petition had advanced to the point where A.D. and her parents were given a
8 time and date for a detention hearing.
9
195. Glidden was also consulted on November 2, 2012 about the referral
10 and refused to give concurrence to take A.D. into protective custody although
11 Tustin Police Dept decided to do so, for the second time.
12
196. Munoz also appears to have played a role in having A.D. returned to
13 her father and the juvenile court petition quashed in November 2012, because he
14 was listed as a collateral contact in CPS referral.
15
197. On information and belief, LaFlamme, possibly Stokke and
16 Rackauckas or Froeberg, were able to persuade Lux and Marron-Taylor to

17 withdraw the petition. They continued to leave A.D. in grave danger by allowing
18 LaFlamme to return A.D. to Srikureja who was repeatedly sexually abusing her.
19 Srikureja also now knew A.D. was continually blowing the whistle on his sexual
20 abuse. The risk of subjecting A.D. to emotional and physical, not just sexual,
21 abuse was obvious. Once more, LaFlamme did not interview A.D. while she was
22 at Orangewood.
23
198. CPS conducted another CAST interview on November 08, 2012.
24 Once more social workers failed to protect A.D. and restore custody to Dillon, her
25 protective parent.
26
199.
LaFlamme who had refused to recuse himself even after Dillon filed
27 several motions to recuse him for bias and failing to advocate for A.D. finally filed
28 a motion to be relieved in July 2013 asserting that my work is done. At the time
46
1 of trial LaFlamme agreed to stay on as the gatekeeper until A. D. turned 18. He

2 soon changed his mind when he learned Tustin P.D. wanted to interview him.
3 LaFlammes motion to be relieved was filed the day after the police sought to
4 interview both him and A. D.
5
200. The first time La Flamme even spoke to A. D. was when the Tustin
6 Police Department interviewed A.D. in July 2013 when they investigated Coleman
7 for witness intimidation. The department recommended prosecution of Coleman
8 for that crime. Once again, Rackauckas, Stokkes good friend for whom he has
9 raised so much money for his continued reelection, declined to prosecute
10 Coleman.
11
201. In February 2013, when Munoz was recalled to testify at the trial as J.
12 Waltzs handpicked expert Munoz briefly described his job functions as the
13 court liaison for CPS, and testified that he had an undergraduate degree from Cal14 State Fullerton and a masters degree in social work from the University of
15 Southern California.
16
202. In late 2014, Dillons appellate attorneys issued subpoenas to those
17 institutions. Both institutions indicated in response that there were no records

18 showing that Munoz had attended its respective institution and or been awarded
19 any degree. Munoz had committed perjury on material facts: namely, he had no
20 college training, education, or degrees required by law for custody evaluators.
21
203. At that point, the court qualified Munoz as an expert in two
22 capacities: (1) as a child custody evaluator, [but he had not conducted a child
23 custody evaluation in the case it was Dr. Sheffner who had done so.] and (2) as
24 an expert in the area of child custody investigations. [whatever that means.] The
25 court exclaimed that Munoz was well-known to the court . . . and his
26 qualifications are beyond reproach. [but he had no qualifications let alone
27 qualifications beyond reproach.]
28
204. Judge Waltzs personal vouching for a witness and his qualifications
47
1 which the judge found beyond reproach raise issues of the judges negligence
2 and/or collusion and/or subornation of perjury. His vouching for Munoz and his
3 admission that he had met exparte with Munoz, a witness, outside the
4 courtroom and outside the presence of the parties, at least outside the
5 presence of Dillon should be investigated by the Commission on Judicial
6 Performance.
7
205. J. Waltz then began serving as second chair (or, third chair after
8 DeArmey and LaFlamme) for Srikureja. He solicited Munozs personal views on

9 whether Dillon had coached A.D., even though Munozs original testimony had
10 never mentioned coaching and he had never conducted any of the CPS
11 investigations. Nor had he conducted an evaluation in accordance with Fam.
12 C. Sec.3118.
13
206. Munoz testified that on a scale of 1 to 10 on whether he believed
14 Dillon was coaching, he started off as a 4 to a 5, but had fallen to two-and-a15 half with respect to the most recent allegations, because Dillons interactions
16 with A.D. were all monitored by this point.
17
207. J. Waltz then declared that Dillon had coached and Srikureja should
18 have full custody, although he admitted that Srikureja was no great shakes as a
19 father. The judgment of custody was entered in July 2013.
20
208. It should be noted that In September 2013, an official with the Orange
21 County Social Services Agency (SSA) submitted an affidavit to the trial court
22 averring that Orange County had opened an investigation against Munoz. The
23 official explained that SSA had discovered a copy of the sealed reporters
24 transcript from the case in Munozs office, which Munoz was not authorized to
25 possess. The official then stated that SSA had opened an investigation into Munoz
26 for possible perjury . . . , as well as other possible violations of SSA policy.
27 Munoz left the employ of SSA that month.
28
209. In 2013, Reinhart made three additional mandated reports, one in

48
1 July, one in August, and again in September. Knowing LaFlamme might be off
2 the case Dr. Reinhart sent LaFlamme a detailed report and notified Dillon that
3 while she cannot disclose the content of the report she indicated to Dillon that it
4 was pertinent to custody and to ask LaFlamme to share it with the court.
5
210. On August 1, 2013, when the motion to relieve LaFlamme was heard,
6 Dillon informed the court that LaFlamme was in possession of a report from the
7 court appointed psychologist that needed to be brought to the courts attention.
8 The court inquired of LaFlamme and once more, LaFlamme suppressed vital
9 information relevant to the safety and welfare of A.D. He lied and said he had no
10 information to relay to the court .
11
211. At the hearing on his motion to be relieved as minors counsel,
12 LaFlamme also stated he spoke to Cate a month earlier and learned that Cate was
13 willing to take his place. Cate is the clone of LaFlamme, suppressing evidence
14 relevant to A.D., including Dr. Reinharts reports and keeping Reinhart from
15 testifying after he was appointed as A.D.s counsel. LaFlamme insured that A.D.
16 would continue to have her rights violated by recommending Cate as her attorney.
17
212. LaFlamme has held a monopoly contract in restraint of trade in
18 Orange Superior Court for over twenty years representing children whom he has
19 repeatedly betrayed.
For example, one superior court document showed
20 LaFlamme made almost three million dollars of federal, state, and county funds
21 between January 1 and June 30 in 2012. The bidding process is rigged so that
22 public funds designed to protect children has gotten into the wrong hands, namely,
23 LaFlammes, for years. LaFlamme has made false claims for years, stealing from
24 the taxpayer funds earmarked to protect children when LaFlamme has routinely,
25 over and over again, used the funds to protect the alleged molester and abuser.
26
213. On June 26, 2013, the Tustin Police Department recommended that
27 the District Attorney press criminal charges against Srikureja for, among other
28 charges, sexual abuse of a minor. As a friend and political fundraiser for
49
1 Rackauckas, Stokke and made sure the D.A. declined to file charges.
2
214.
Srikureja fled to Canada in June 2013 fearful he might be prosecuted
3 despite hiring Stokke. Srikureja left A.D. in the care of his sister, Pravit who was
4 temporarily visiting California from Canada. Srikureja has abandoned A.D. He
5 cannot gain entry into the United States and has never told the Court why.
6
215. Pravit did not allow A.D. to watch TV, play outside, have play dates,
7 go out on the playing field at school at lunch, withheld food, called A.D. names
8 and taunted her continuously. Reinhart was concerned about her abusive behavior
9 toward A.D. and cited her in letters she wrote to LaFlamme and Cate. Neither
10 LaFlamme nor Cate did anything about Pravits abusive behavior towards A.D.
11
216. Pravit took A.D. to therapy sessions with Coleman, knowing these
12 appointments with Coleman were in violation of a court order and furthermore

13 were designed to intimidate A.D. into recanting abuse (assuming she did). Pravit
14 schemed and planned with Coleman what to write in the To Whom it May
15 Concern letters. Pravit also wrote false declarations which were filed in court
16 and used, in part, to award sole custody to Srikureja.
17
217. On September 30, 2013, J. Salter, who had since taken over the case
18 from Judge Waltz, issued a minute order indicating that he had received an
19 improper exparte communication from the D.A.s office, specifically from
20 Froeberg on September 27, 2013.
21
218. On September 27, 2013, Froeberg emailed J. Salter ex parte (no
22 notice to Dillon) and informed him that there would be no criminal prosecution of
23 Srikureja which should not be a surprise, knowing of the unholy alliance between
24 Rackauckas and Stokke
25
From: Froeberg, Rosanne [mailto:Rosanne.Froeberg@da.ocgov.com]
26
Sent: Friday, September 27, 2013 3:28 PM
27
To: Victoria Do
28
Subject: RE: Family Law Case Number 05P000379

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I doubt he [J. Salter] will need to speak with me, but if he does
and after 345-my cell phone is 949-[ ].
Thanks,
Rosanne
Dear Judge Salter-I have been asked [by whom?] to forward the
attached memo to your attention. I supervise the OCDA's Sexual
Assault Unit and the deputies who reviewed the police reports and all
relevant materials submitted to this Office by Tustin Police
Department involving the investigation of Matthew Srikureja for
allegedly molesting a minor child. I am also very familiar with the
case and approved the decision not to file criminal charges.
Mr. Al Stokke, Attorney at Law, made a request for the memo under
the Public Records Act request, which was granted as authorized in
Government Code Section 6254.
Please let me know if I can be of further assistance. emphasis added.
219. The memo referenced in the email from Froeberg states:
TO: Sgt. Bob Wright, Tustin Police Department
September 27, 2013
FROM: Rosanne Froeberg, Assistant District Attorney, Sexual
Assault Unit
SUBJECT: Status of Criminal Investigation
This memo is to advise you that as of today the OCDA has decided
not to file criminal charges against Matthew Srikureja alleging sexual
abuse of a minor child. After 20 months of investigation and review
of all relevant documents, the decision was arrived at that there is a
lack of evidence to support the allegations and the filing of criminal
charges. emphasis added.
220. Having stepped into the shoes of an investigator, in accordance with
22 the custom and practice of Rackauckas to take over and control all investigations
23 of clients of Stokke, Froeberg explained away all the evidence of sexual abuse.
24 Froeberg was the willing dupe of DeArmey and Stokke who provided her with the
25 notoriously-unethical and falsified To Whom It May Concern Letters of
26 Coleman and a report from a potential expert witness for Srikureja, Dean Tong.
27
221. To make matters even more unethical, Froeberg also sent an email on
28 September 30, 2013, to Judge Salters courtroom clerk concerning Dillons

51
1 absolute right to her childs investigation records:

2
From: Froeberg, Rosanne [mailto:Rosanne.Froeberg@da.ocgov.com]
Sent: Monday, September 30, 2013 9:09 AM
To: Victoria Do [J. Salters courtroom clerk]
Subject: RE: Family Law Case Number 05P000379
Good morning, Victoria. Our office has received a request from Ruby
Dillon to obtain copies of all police reports as well as the CAST
interview tapes of her minor child who is subject to orders in your
court. I have heard that she was ordered in the recent past to return all
items to the Court that she obtained pursuant to the 827 request she
made earlier this year and also not to publicize confidential matters. I
am inclined to deny her request to our Office based on concerns about
violating any Court orders and also the minor child's right to
confidentiality. Would you please let me know if any orders exist
regarding the above issue and what my Office is required to do to get
a copy? Since only for informational purposes, even an uncertified
minute order will suffice. We are not able to access Family Law files
remotely.
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222. J. Salter held a hearing on October 4, 2013, regarding Froebergs
14 exparte contacts. J. Salter did chastize the District Attorney Office for Froebergs
15 exparte communications. He did not demand that Froeberg be present, and he
16 failed to issue an OSC re: sanctions against her.
17
223. J. Salter went to great pains to protect the Office. He ordered the
18 courtroom locked and barred all individuals except for courtroom staff, the two
19 deputies who showed up from the D.A.s office, the attorneys for the parties, and
20 Dillon. Barry requested that there be an open courtroom,
21
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24
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26
...[My contention is that the issues coming before Your Honor today
are issues covered by the free speech or the First Amendment of the
United States Constitution. They involve issues of public interest or a
public issue, namely corruption.... well , I' m asking that you make it
open for the sake of the public the public has a right to know how
the government is conducting its business , specifically the court
and the district attorney' s office. Those are two critical issues
that the public has a right to know about . Oct. 4, 2013 hearing
transcript, Case No. 05P00379 at 4:3-18; 5:6-11, emphasis added.
224. J. Salter stood on Fam. C. Sec.7643 at 5:12-19 which states that
27 paternity proceedings are confidential but discretionary with the court whether to
28 keep the proceeding confidential. The issue was not about the child and her
52
1 parents but about the misconduct of Froeberg in communicating exparte to the

2 court and the unethical, if not criminal, association between Stokke and
3 Rackauckas. J. Salters protection of the D.A. from public scrutiny breached his
4 fiduciary duty to the public to keep his courtroom open concerning matters
5 involving the public interest.
6
225.
Later in the hearing Barry requested that the Court issue an OSC
7 against Stokke for referral to the State Bar for encouraging the District Attorney to
8 have ex-parte communication with the court,
and it plays right into or it doesn't play, it is direct evidence of what

we have been seeing all along. We don't have a prayer with the DA's
office because Stokke runs it. Mr. Stokke says do this and that and
the other thing, they say, okay, and they've done it. Id., 25:6-16.
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226. J. Salter immediately began to backtrack and now Froeberg, Stokke,

DeArmey had, after all, not really done anything wrong.
227.
J. Salter had not only closed the courtroom but then for months
denied Dillon the transcript of the proceeding solely to protect Rackauckas and
Froeberg from public scrutiny and exposure of Rackauckas corrupt relationship
with Stokke.
228. Years ago, the Orange County Grand Jury investigated Rackauckas
and Stokkes relationship while investigating Rackauckas and the D.A.s office. It
produced a report in June 2002 of its investigation of the Office which included
but not limited to, an investigation of Rackauckas, Stokke, Arnel Management
Company, the company Stokke was representing, and its owner, George Argyros.
The two defendants were involved in a scandalous consumer fraud case involving
hundreds of tenants. Arnel was committing massive fraud with respect to security
deposits of the tenants.
Arnel Management Company (Arnel) operated apartment buildings in
Orange County and Los Angeles County for a number of years,
including between 1996 and 2001. The District Attorney's Office
commenced a consumer fraud investigation into the purported
wrongful retention of apartment tenants' security deposits by Arnel in
late 1999. The District Attorney's Office ascertained that Arnel had
53
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been a defendant in excess of 200 Small Claim filings in the County

of Orange between 1996 and 1999. George Argyros was the president
and owner of Arnel. Report, CJ-70 ....
During the investigative stage, attorney Leonard Hampel commenced
the representation of Arnel, later, in the spring of 2000, attorney Al
Stokke became involved in the case, as Mr. Hampel's co-counsel.
Id.....
Unbeknownst to DDA Brough and ADA Gannon at the time, two
meetings were held in Mr. Rackauckas' office, one on February 6,
2001, and the second on February 8, 2001, with Senior ADA
Patterson, Mr. Rackauckas, Mr. Hampel and Mr. Stokke in attendance
to negotiate terms of settlement. Except for executive management
oversight roles, neither Mr. Rackauckas nor Mr. Patterson had
experience as government lawyers in consumer fraud cases. Report,
p.CJ-71.
229. The deal that was struck by Rackauckas and Stokke apparently so
11 shocked members of the D.A.s office, that

12
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18
In early February 2001, certain unfiled, nonpublic District Attorney's

office pleadings concerning the Arnel case were leaked to the press.
Based on the leaked documents and other information, several articles
were published by The Orange County Register during the 2001 time
period of the February 6 and February 8 meetings which placed Arnel
[Stokkes client] Management's purported security deposit practices
in a poor light. A February 7, 2001 article stated that Arnel
Management Company had donated $1,000 to Mr. Rackauckas'
district attorney campaign. Apparently, because of the press articles,
the District Attorney's office received hundreds of additional
complaints from Orange County residents about Arnel. P. CJ-72.
230. Public and tenant outrage caused Rackauckas office to turn over the
19 prosecution of Arnel to the Attorney Generals Office which took the case. The
20 Attorney Generals settlement was far more protective of the tenants rights than
21 was the sweetheart deal that Stokke and Rackauckas reached.
25
231. The report goes on to discuss Stokke and Rackauckas relationship:

Relationship of DA Rackauckas to Argyros and Arnel Counsel
Mr. Alan Stokke contributed in excess of $1,000 to Mr. Rackauckas'
first campaign for district attorney. He solicited other attorneys to
donate money to Mr. Rackauckas' campaign and co-hosted a fundraiser at the Balboa Bay Club that raised in excess of $30,000 for the
campaign. Report, p.CJ -73
26
232. Not only did Stokke pour money into Rackauckas' campaign coffers,
22
23
24
27 but Argyros, the owner of Arnel, loaned hundreds of thousands of dollars to a

28 campaign to vote down Measure F. Rackauckas was a principal spokesperson for
54
1 the No on Measure F campaign. Argyros made the loan before Rackauckas and
2 Stokke worked out the agreement on Arnel. Arnel itself gave $1,000.00 to
3 Rackauckas campaign in 1998.
4
233. One of the findings of the Grand Jury at No. 5 noted that the money
5 that Stokke and Arnel had contributed to Rackauckas campaigns created an

6 appearance of impropriety, an underwhelming conclusion in view of the
7 overwhelming evidence of Rackauckas pay-to-play (or, quid pro quo)
8 arrangement he has. This pay-to-play arrangement left the (probably mostly
9 wage-earning) tenants without a remedy while benefitting the players Stokke,
10 Arnel, and Argyros who continue to grease the hand of Rackauckas with
11 campaign money. The public interest and the tenants were harmed and cheated by
12 their District Attorney.
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234. At the time that Mr. Rackauckas and Mr. Patterson took over the
settlement negotiations of the Arnel case, Mr. Rackauckas did not pay
proper attention to a possible appearance of impropriety based on
Arnel Management Company contributing $1,000 to his campaign,
Rackauckas being one of the ballot spokespersons in opposition to
Measure F, and Mr. Stokke being a significant campaign contributor
as well as co-hosting a very lucrative fund-raiser for Mr. Rackauckas.
CJ-74.
235. The Grand Jury report went on to document other serious misconduct
on the part of Rackauckas. However, the report did not change Stokkes or
Rackauckas ways of doing business. Another report of Stokkes and Rackauckas
chicanery surfaced as late as last year involving a suspicious land swap deal of the
mayor of Santa Ana, Miguel Pulido with the owner of an auto parts store whereby
Pulido made $197,000 net profit on a home he purchased from the owner of the
auto parts store when he sold it. Pulido voted to give Rupen James Akoubian, the
owner of the auto parts store, a $1.35-million no-bid city contract just over a year
after he and members of his family purchased a home in 2010 from the store
owner for $230,000 less than its fair market value, according to public records
with the City of Santa Ana.
28
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http://voiceofoc.org/2013/11/santa-ana-mayors-property-swap-raises-questi
ons/
By ADAM ELMAHREK November 14, 2013 at 2:00 PM
Pulido did not disclose the purchase of the Westminster home which was
part of a real estate swap between the Pulidos and Rupen James Akoubian,
president of NAPA Orange County Auto Parts before casting his vote on
the company's contract in December 2011.
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Nor did he report the home on his statements of economic interest, known
as Form 700s, that are required by state law.
In exchange for the home, Pulido sold Akoubian a lot that is attached to the
back of NAPA Orange County Auto Parts, which is located on First Street
in Santa Ana, just a block from the Pulido family's auto care shop. Both
transactions were for $200,000.
However, after the sale was recorded, Orange County Assessor Webster
Guillory determined that the home was not sold at fair market value and
appraised it at $430,000 based on comparable sales in the neighborhood.
Guillory appraised the lot behind the parts store at its $200,000 sale price.
Then in August 2012, Mayor Pulido's family members, including his father
and two brothers, transferred the house property solely into his name. That
same day, Pulido sold the home for $397,000 and netted a $197,000 profit.
He did not disclose the sale on a Form 700 as required by law.
....
18
While Pulido realized the windfall from the home sale, city records show
NAPA Orange County Auto Parts went from having a $50,000 annual
contract as one of many auto parts suppliers for the city's vehicle fleet to
holding a three-year, sole-source contract valued at $450,000 annually a
nine-fold increase.
19
236. Both the City Attorney and the D.A. were doing an investigation.
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20 The D.A. asked the City Attorney to hold off on releasing its investigation:
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http://blogs.ocweekly.com/navelgazing/2014/10/miguel_pulido_felon
y_investigation.php
It's all over an investigation into whether the Don Papi violated
campaign finance law when he sold a house that his family had
acquired in a property swap from a businessman who just so
happened to have business with SanTana. The city attorney
completed its investigation months ago; the DA hasn't. The city
council said they wanted to release their investigation if DA Tony
Rackauckas didn't; the DA didn't want them to.
Well, someone released the report yesterday--and it says the city
thinks Don Papi Pulido might be charged with a felony.....
237. Rackauckas so far has not taken any action against Pulido, and he let
28
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1 the statute run on misdemeanors. But Pulido did he hired Stokke and he had
2 longtime friend and political consultant make a political donation to Rackauckas:
http://voiceofoc.org/2014/09/campaign-cash-clouds-das-probe-into-sa
nta-ana-mayor/Campaign Cash Clouds DAs Probe Into Santa Ana
Mayor
By ADAM ELMAHREK September 16, 2014 at 5:17 AM
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Early this year, when it became clear that District Attorney Tony
Rackauckas would be investigating a suspicious real estate deal
between Santa Ana Mayor Miguel Pulido and a city contractor,
Rackauckas received something he'd never been given before.
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It was a campaign contribution from Dennis DeSnoo, Pulido's

longtime friend and political consultant.
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In fact, the $1,900 contribution on Jan. 22 was the first time in

nearly 10 years that DeSnoo has given to any candidate for
countywide office and the first time ever for DA, according to
Shirley Grindle, the county's campaign finance watchdog.
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Other Pulido allies giving to Rackauckas' campaign this year

include a developer and his wife, a car dealer, and the wife of a
well-healed client of the mayor's consulting business. And Al
Stokke, the criminal defense attorney Pulido hired to advise him
on the property swap issue, is also a longtime campaign
contributor to Rackauckas. emphasis added.
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All told, Rackauckas this year received $5,000 from these folks as of
this month. DeSnoo and Stokke would not comment. Others who
were reached insisted their contributions were not made on Pulido's
behalf.
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238. Many Orange County and Santa Ana residents, as well as members of
19 Santa Ana City Council, are upset about Rackauckas failure to take action against
20 Pulido:
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voiceofoc.org/2015/01/with-deadline-passed-da-mum-on-potential-ch
arge-against-pulido/
With Deadline Passed, DA Mum on Potential Charge Against Pulido
By ADAM ELMAHREK January 6, 2015 at 4:35 PM
The Orange County District Attorneys office has remained mum on
whether it was able to meet the statute of limitations deadline on a
misdemeanor charge against Santa Ana Mayor Miguel Pulido that
passed this weekend.
This means the window has potentially closed on prosecuting Pulido
for one of several crimes that a city investigative report said he might
have committed when he engaged in real estate deal with a city
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contractor.....
Former Riverside District Attorney Grover Trask authored the report

and found that the mayor structured a cover-up of his dealings with
the contractor, but left it up to the DAs office which along with
state authorities has been investigating the mayor to determine
whether Pulido willfully violated the law.
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However, while the DAs office has been silent, City Council
members and activists are expressing their suspicions that old-guard
politicians like Pulido, who have ties to District Attorney Tony
Rackauckas, are safe from prosecution.
Does it really come down to who you know for what you can get
away with? Asked Councilman David Benavides, a critic who also
ran against Pulido for mayor in 2012. It gives any taxpayer reason to
lose confidence in the system.
239. This case is no different than the Arnel and Pulido scandals. In fact,
11 the Pulido and Srikureja cases were moving along about the same time. Pulido
12 and Akoubian swapped the land and home in 2010. Srikureja filed a motion for
13 custody in 2010. Pulido awarded Akoubian the no bid exclusive city million
14 dollar plus contract in December 2011. By January 2012, Dillon had lost custody.
15 In March 2012, DeArmey convinced the court to appoint his friend LaFlamme as
16 minors counsel. By July 2012 LaFlamme had persuaded the Court without any
17 evidence to place Dillon in supervised visitation.
18
240. By 2013, if not earlier, both Pulido and Srikureja were being
19 investigated by the D.A. At the end of September 2013, Rackauckas office

20 announced it was finished with its investigation and would not prosecute
21 Srikureja. Rackauckas is dragging his feet on Pulido, letting misdemeanors die
22 on the vine and refusing to charge him for felonies, hoping that the public
23 brouhaha will die down. Besides, he made $5,000.00 in 2014 for not doing
24 anything to Pulido. 2015 should certainly bring Rackauckas even more
25 donations for not doing anything to Pulido.
26
241. On October 6, 2013, during a visit with her mother, A.D. told Dillon
27 that Pravit said they were planning on taking her (A.D.) out of the country, despite
28 a court order prohibiting removal of A.D. from Orange County. Dillon
58
1 immediately contacted Orange County Sheriff Department, and sheriff personnel

2 advised Dillon to keep A.D. for the night and bring her to the courthouse the
3 following day.
4
Dillon did just that.
242. J. Salter presided over a hearing on October 9, 2013. As a sanction
5 for Dillons failure to return A.D. for that one night, Judge Salter ordered that
6 Dillon have no further visitation with [A.D.] . . . until the Court sees contrition
7 on the part of [ Dillon ] and finds reasons to restore the relationship. The courts
8 order was purportedly temporary, but has been kept in place indefinitely. J. Salter
9 punished the little girl severely. A.D., now going on 11, has not seen her mother
10 since October 9, 2013, which is 17 months.
11
243. Although Srikureja has never returned to the U. S. since he fled the
12 country in June 2013, J. Salter refuses to restore custody to Dillon. Since the
13 entry of the custody judgment, Dean Tong, the Father's own expert, signed a
14 declaration indicating he had been misled by Srikureja, DeArmey, and Stokke.
15
244. In March 2014, Petitioner filed a motion to renew several prior
16 Requests for Order. Dillons March 2014 motion was based on the Declaration
17 of Tong. .
18
245. Tong alleged that he had been led by Srikureja's attorneys to believe
19 Coleman was a court-appointed therapist, though she was not. He stated he

20 believed the materials given to him had been orchestrated to denigrate and
21 discredit the real court-appointed therapist, Reinhart. Tong alleged he had spoken
22 with Reinhart, who told him she believed the minor child was telling the truth
23 about the sexual abuse.
24
246. Besides providing Dillon a declaration describing the deception and
25 fraud Tong sent a letter to Rackauckas on February 24, 2013 in which he stated in
26 part:
27
28
The purpose of this letter is to retract my report sent to you on or

about August 21, 2013. The report was provided to AI Stokkey, Esq.,
Father's criminal defense attorney, for the purpose of Father s
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criminal defense. The retraction is necessary as I have recently been

informed and I now believe that I was misled and deceived by Father
and his defense team. My report therefore contains erroneous
conclusions, as the conclusions were based on false and misleading
information. On June 3, 2013, I was retained by Matthew Srikureja,
the father of [A.D.] , born October 17, 2004. At the time he retained
me, Matthew Srikureja had been alleged to have sexually abused
[A.D.] and was under criminal investigation for the same. Matthew
denied all allegations, and counter-alleged that Ruby Dillon, the
mother, was making false allegations for purposes of obtaining
custody. As requested by Father, I began to investigate the
circumstances of the allegations.
As part of my normal investigation in any case, and as part of the
investigation in this case, I requested Father provide me with a copy
of the case file. I knew there had been CAST interviews, and so I also
asked Father's defense team and Father to arrange an opportunity for
me to review the CAST interview tapes (there were four separate
interviews, according to Father). Despite my repeated requests made
to Mr. Srikureja and his defense attorneys, I was never provided with
this information nor was I able to review the CAST DVDs. I also
requested from Father, the discovery from the court-appointed
therapist for [A.D.] What Father provided me with was the workproduct from therapist Grace Coleman, whom Father
represented to me had been appointed by the court to provide
therapy to [A.D.]. This was false and Father knew it to be false
when he provided me Grace Coleman's work product and passed
it off as "the court appointed therapist's" file. Father had,
without permission from the court. began to send [A.D.] to Grace
Coleman for therapy. Grace Coleman's opinion was that
Matthew Srikureja did not abuse [A.D.]. Grace Coleman had
never worked with any child previously; [A.D.] was her first child
client. Therapy was didactic, and not individual, thus of limited
value to any objective investigator. To be very clear, Grace
Coleman IS not and never had been at any time the court
appointed therapist for the child, and Matthew Srikureja knew
this and intentionally misrepresented this material fact to me. As
a result of Grace Coleman's knowing participation in this
deception, Grace Coleman is being investigated by her governing
board. emphasis added.
247. Tong goes on to state later in the letter:
In late August, just as they [Srikureja, DeArmey, Stokke] [probably
through DeArmey, LaFlamme] pressed me for an advisory opinion
about the allegations. Father's defense team did finally provide me
with roughly 300 pages of discovery. I issued the report after
reviewing only this material, which I believed was all material
available. It is fair to say that I was shocked to learn in January
2014, that the court file/ discovery consists of at least 3300 pages.
It was at this time I realized the enormity of the situation: Father
and his defense team "cherry picked" documents that favored
him and made Ruby Dillon look bad; Father and his team
literally "created" a second "court-appointed therapist" when the
real court-appointed therapist's views did not support Father's
60
position, and Father purposefully omitted material relevant facts.

The materials presented to me were specifically orchestrated to
denigrate and discredit Dr. Reinhart for the purpose of discrediting
the allegations of sexual abuse, so that Father's criminal case might be
dropped. In fact, this was the result that Father obtained after
procuring my report through intentional misrepresentation of material
fact. Father Matthew Srikureja refused to heed my professional
advice to clear his name through a risk assessment/ psychosexual
battery of tests to include the AASI-3. Had he done so, and passed the
test, this would have tended to make it less likely that the allegations
of sexual abuse were true. I provided Father every opportunity to
submit to this testing but he never complied with my request.
emphasis added.
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248. Tong concluded the letter by making a plea to Rackauckas. Tong was
9 asking the impossible of Rackauckas: to choose between ethics and Stokkes

10 steady stream of campaign funds based on Rackauckas pay-to-play scheme:
I respectfully urge that your agency re-open any and all allegations
that were pending against Father, which were mitigated or dropped as
a result of my report. These allegations should be reopened and
reconsidered in full. Additional allegations against Father and his
defense team, and Grace Coleman, for deliberately providing false
information as if it were true, are appropriate in light of the
intentional deception intended to perpetrate a fraud upon the courts
and judicial system.
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249.
Based on this information from Tong, Dillon filed a request for an
evidentiary hearing in which Tong was supposed to testify. J. Salter refused to set
a date for the hearing. Just as Comm. Wilson kept Kanofsky from testifying, and
J. Waltz kept Reinhart from testifying, and sabotaged Sheffner by expecting him
to review hundreds of single- spaced CPS documents the night before he testified,
so J. Salter made sure that Tong would not testify by simply refusing to set a
hearing.
250. Dillon took the deposition of Reinhart on April 2, 2014. She testified
that she worked with LaFlamme, from the time she received the case on June 15,
2012, until August 2, 2013, when she was informed by e-mail that Cate had
substituted in as minor's counsel.
251. Reinhart expressed the opinion that Coleman, the "therapist" hired by
Father, had been coaching the minor child, against her mother. She also shared
28
61
1 her opinion that Dillon did not even have the opportunity to coach the child, due to
2 the limited time she had with her. Reinhart testified that she believes the minor
3 child has been the victim of a crime, that disclosure of her communications in
4 meeting with the minor child are in her best interests, that she passed this
5 information on to minor's counsel, and that she believes that information was not
6 passed along to the court.
7
252. Based on the information revealed at Reinhart's deposition, Dillon
8 filed a request to remove Cate as minor's counsel, on April 18, 2014, because it
9 became clear that Cate, like LaFlamme, had suppressed Reinhart's opinions about
10 the danger the minor child has been in, and withheld important information and
11 evidence from the court. J. Salter inexplicably denied the application.
12
253. On April 21, 2014, both Dillon and Cate brought ex parte
13 applications to the court. Minor's counsel brought two ex parte applications - one a
14 request for domestic violence restraining orders against Dillon, despite the fact
15 that Dillon had never committed any act defined as domestic violence in the
16 Domestic Violence Prevention Act (DVPA) or in DVPA case law.
17
254. Cate also sought to vacate the order restraining removal of the minor
18 child from Orange County, so A.D. could be made a refugee and removed against
19 her will to Napa, California, with her paternal aunt, Eva, as temporary guardian.
20
255.
Dillon also made ex parte application on April 21, 2014, requesting,
21 among other things, that custody be restored to her pursuant to Family Code
22 section 3040, since Srikureja was unable to exercise his custodial rights. J. Salter
23 denied this application, without a hearing, the denial of an evidentiary hearing
24 being a pattern in his courtroom. Family Code section 3010(b) provides that if
25 one parent is unable or refuses to take custody, or has abandoned the child, the
26 other parent is entitled to custody of the child.
27
256. J. Salter inexplicably granted temporary legal and physical custody
28 of A.D. to a complete stranger, Edgar, who was Srikureja's prior counsel in this
62
1 matter in November 2012. Edgar was a willing participant in the campaign to

2 deprive Dillon and A.D. of their family rights. She was routinely appointed as
3 minors counsel by J. Waltz who often declared the parents indigent so that public
4 funds would be misappropriated to pay Edgars attorney fees.
5
257. When J. Salter awarded custody to Edgar on April 21, 2014, he ruled
6 that the temporary order would terminate on June 23, 2014. However, he
7 terminated the appointment within four days, on April 25, 2014.
8
258. Edgar had a duty to turn down the appointment. At this point, there
9 was a conflict between A.D. and her father of which Edgar was aware since Edgar
10 knew as of November 2012 that A.D. was alleging that Srikureja was sexually
11 abusing her.
12
259. In November 2012, Edgar went so far as to slander A.D., eight years
13 old at the time, telling the court that A.D. lied about being sexually abused, (with
14 no foundation for that conclusion), she should be placed in a mental hospital and
15 given psychotropic drugs. Edgars vituperative attack on a little girl who could
16 not defend herself locking her up in an aslyum and drugging her just for
17 disclosing that Srikureja was sexually abusing her is shocking.
18
260. While it may have been grandstanding and posturing to look good to
19 her client and the court, because she was desperate for fathers like Srikureja to
20 retain her as their attorney and for continuing court appointments as minors
21 counsel, still, that Edgar would take such an extreme position against a little girl is
22 remarkable. After all, A.D.s court-appointed therapist, a gynecologist, an E.R.
23 physician, the court- appointed custody evaluator, the fathers former expert
24 witness, and several investigating police officers found A.D. credible on the sex
25 abuse charges, wanted her removed from her fathers custody, and placed with her
26 mother.
27
261. Besides defaming Daughter, Edgar also defamed Mother. She
28 testified falsely about Dillon in court on April 25 2014, reporting alleged negative
63
1 statements made by the school principal about Dillon. Later, in a deposition

2 Dillon took of the principal, the principal denied making any of those statements
3 Edgar attributed to her. But the harm had been done. So eager was J. Salter to
4 discredit Dillon and A.D. he accepted inadmissible hearsay testimony from a
5 biased and prejudiced witness to deny custody to Dillon.
6
262. Edgar also lied to J. Salter that a nanny named Blanca was caring for
7 A.D. and that A.D. was in a safe environment. Blanca had quit the week before.
8 J. Salter found that both continuing custody with the Father and granting
9 custody to Petitioner would be detrimental to the child. J. Salter never made
10 an appropriate finding, on clear and convincing evidence, consistent with Family
11 Code section 3040, of detriment to the minor child if placed in the custody of
12 Dillon.
13
263. The order filed on April 21, 2014, restrained Dillon, Srikureja, or any
14 other agents, friends, or family members to contact the minor child at school "or
15 any other place."
16
264. On April 25, 2014, the Court relieved Edgar of her status as
17 temporary custodial parent of the minor child.

18
265. The matter was then continued to May 7, 2014. Other than relieving
19 Edgar of her custody of the child, the Court made no additional orders, leaving the
20 child in the care of unspecified third parties paid for by the absent Srikureja.
21
266. Beginning in February 2013 and intensifying, J. Salter, Rackauckas,
22 LaFlamme, Stokke, and the case were receiving extremely negative publicity, on
23 television, on the internet, and on the radio. The Robing Room ratings of J. Salter
24 were very bad: approximately 48 extremely negative reviews and only three
25 favorable, most of them related to his handling of A.D.s case.
The publicity
26 included the following:

27
February 27, 2013. Fox News "allegations of molestation"
28
May 7, 2013: Fox News 11: "lawyer taking on OC child protective

64
services"
May 7, 2013: CBS News LA "attorney, OC child protective services

failed to respond to abuse charges"
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June 6, 2013: WND "Child protectors accused of destroying families:

State wide audit launched in response to dance, tales of abuse"
July 3, 2013: Fox News 11 "another complaint against children's
protective services"
October 6, 2013: safe Kids International.org "Complaint to
California CJP"
May 8 2014: Los Angeles Indymedia "The Waltz-Salter-Rackauckas
Cabal"
May 21, 2014: Voice of OC "problems in OC child welfare system
get statewide scrutiny"
June 6, 2014 State of the nation: "concerned parties still demanding
judge Glenn Salter removal for endangering [A.D.]"
June 19, 2014: Voice of OC "OC child protection agency under fire"
June 26, 2013: Dr Gina Loudin "dr Ruby Dillon does still not have
custody of her daughter after almost 18 months of fighting"
June 10, 2014: Daily Kos "concerned parties still demanding judge
grants alter removal for endangering [A.D.]"
June 14, 2014: State of the nation "[A.D.] Dylan must be saved: she
could be your child"
June 20, 2014: OC Weekly "Ruby Dillon's child custody case for
daughter she has not seen in 10 months"
June 21, 2014: Storyleak "Orange county, California places abused
child with sexually abusive parent"
June 26, 2014: Storyleak "critical piece of orange county child abuse
Court Proceedings
July 1, 2014: The peoples voice.org
"protective parents revolts against family law and justices"
July 4, 2014: News and views Riverside Superior Court and family
law Abuse. "Secrets in the orange county family law court justice
system. Judge Glenn Salter and the [A.D.] Dillon case."
July 16, 2014: www.presstv.com "screams in the dark: US courts
trafficking children-press TV"
July 25, 2014: News and views Riverside Superior Court and national
family law abuse "Judge Gllenn salter removes his problem child
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from United States. Orders [A.D.] Dylan effectively deported."
August 3. 2014: Susan Knowles "American citizen order deported

buy orange county judge"
3
4
August 9. 2014: Dave Hodges the common sense show "[A.D.] Dillon
case: what caused an expert to change his mind?"
August 19, 2014. Salter transferred case to Napa Sua sponte
August 22, 2014: before it's news "Child protective services violate
public trust: judges ruled against children's welfare"
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Jan 5, 2015 Before it's News: "Orange County CPS has facilitated
child sexual abuse"
267. J. Salter saw the case unraveling in his courtroom when he was doing
10 everything to contain the damage. He began to engage in witness intimidation and

11 threatening the licenses of the professionals representing Dillon and/or advocating
12 for A.D. being removed from Srikurejas custody.
13
268. Attorney Merritt McKeon reinstated Dillons dismissed appeal and
14 was able to obtain the trial transcripts through the transcripts reimbursement fund
15 around October 2013. McKeon continued to represent Dillon in the appellate
16 case. J. Salter threatened McKeon in another case, saying he was going to go
17 against her bar card. Because she had conducted herself competently and ethically
18 in that case where J. Salter threatened her license, McKeon and Dillon believe
19 strongly that the only reason why J. Salter threatened her was because of restoring
20 Dillons appeal and obtaining the numerous transcripts without Dillon paying for
21 them. J. Salter was probably even more incensed when he learned that the
22 distinguished international corporate law firm out of Washington, D.C., Arnold &
23 Porter is representing Dillon and A.D. on appeal.
24
269. Around May 2014 J. Salter filed an OSC against Tong threatening
25 him with contempt of court and threatening him with charges for making false(?)
26 allegations of sexual abuse or retract his declaration. Faced with contempt and
27 other charges, Tong opted for an auto da fe. He filed a declaration essentially
28 apologizing for violation of work product privileges. Tong then filed a declaration
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1 with the appellate court stating that he was intimidated by J. Salters threats and
2 that is why he filed the declaration.
3
270.
On May 7, 2014, J. Salter defamed Reinhart whose deposition had
4 been filed as an exhibit in which she stated under oath pursuant to Evidence Code
5 Sec.1027 she believed [A.D.] is under the age of 16; Reinhart had reasonable
6 cause to believe [A.D.] had been the witness of a crime; and disclosure was in the
7 best interest of the child. J. Salter stated:
8
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It also appears that Dr. Reinhart has become embroiled in the matter .
I don' t think I see her as any longer a neutral. She appears to have
become an advocate. [she was appointed as such A.D.s therapist,
and not a forensic custody evaluator] I cannot believe that she
allowed her deposition to be taken in this matter. I realize it was
done under the guardianship proceeding. A member of the press was
there, [how did he know?] and the transcript, which I have, there were
discussions in there that I think could be perceived as being in
violation of the privilege. [whose privilege? And who held it?] It's at
least tantalizing enough on the pages that I was shown. Mr . Funk
[Dillons attorney], if you were to give me a copy of the entire
transcript, at this point in time I have not seen it, I'm not sure you 've
shared a copy of the transcript with anybody else.
May 7, 2014 hearing transcript at 8:9-23, Case No. 05P000379,
Orange Superior Court.
271. On May 13, 2014, after arresting Dillon on May 7, 2014, discussed
17 infra, J. Salters abandonment of all pretense of fairness was now complete. He

18 felt there was no basis for consideration of Reinharts deposition, and that he
19 would not consider it as part of the record, nor as any portion of the exhibit,
20 declaration, or points and authorities which utilizes or makes reference to it. J.
21 Salter invited action from minor's counsel against Reinhart (her license) regarding
22 the potential violation of privilege, despite what the law states about privilege with
23 respect to a child under the age of 16 reporting sexual abuse to her therapist.
24
272. J. Salter exacted his greatest retaliation against Dillon. On May 7,
25 2014, the hearing on the domestic violence request of Cate commenced. J. Salter
26 had been doing research on Dillon outside what the parties had presented to him
27 within the four corners of the case before him. J. Salter morphed himself into a
28 prosecutor. He found that Dillon had "multiple failures to appear" on
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1 outstanding traffic violations, which took Dillon completely by surprise and ended
2 up being false.
3
273. Although there was no warrant for Dillons arrest for Dillons failure
4 to appear on two traffic violations filed eight years prior, J. Salter ordered his
5 bailiff, Chang to arrest Dillon on the eight year old misdemeanor and infraction
6 traffic violations. The misdemeanor and infraction were not committed in the
7 presence of the bailiff who was an Orange County deputy sheriff. J Salter
8 maliciously set bail at $15,000.
9
274. On May 7, 2015, J. Salter announced: I DON ' T KNOW WHO
10 THIS PERSON IS. meaning Dillon. Dillon had been appearing regularly in
11 family court since 2010 in the child custody case and had obtained an order of
12 custody in the case as early as 2005. Dillon was A.D.s mother, and she had
13 conceived her child with Srikureja.
14
275. J. Salter used Fam. C. Sec.6306(a) as a sham to do an extensive
15 search on Dillon. The code section states in part:

16
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Prior to a hearing on the issuance or denial of an order under this part,

the court shall ensure that a search is or has been conducted to
determine if the subject of the proposed order has any prior criminal
conviction for a violent felony specified in Section 667.5 of the Penal
Code or a serious felony specified in Section 1192.7 of the Penal
Code; has any misdemeanor conviction involving domestic violence,
weapons, or other violence; has any outstanding warrant; is currently
on parole or probation; has a registered firearm; or has any prior
restraining order or any violation of a prior restraining order.
276. Dillon had no such convictions nor any outstanding arrest warrant.
22 She was not on parole or probation. She did not own a registered firearm nor did
23 she have any prior restraining orders other than what J. Salter was issuing against
24 her.
25
277. J. Salters interrogation of Dillon belied his claim he did not know
26 who she was, making his interrogation hilarious were it not for it resulting in a
27 tragic and traumatic outcome for Dillon. J. Salter was foolishly contradicting
28 himself, I claim not to know who you are, but here are all the things, quite
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1 detailed, I know about you.

2
278.
Fancying himself a prosecutor, J. Salters knowledge of details of
3 Dillons life made his hostile interrogation of Dillonall the more chilling. It
4 seemed as if he had contacted Rackauckas and had asked him to pull out all the
5 stops on details of Dillons life. Dillon acknowledged many of the things J. Salter
6 knew about this person whom he was interrogating but claiming he did not know
7 who she was. This was so, because while he had initially informed Dillon she
8 could take the Fifth, he still forced her to answer his questions. J. Salter knew
9 more about Dillon than she could recollect! like the license plate of her
10 automobile.
11
279. What J. Salter established with his grilling of Dillon is that while
12 Dillon spelled her name Western style at times, Ruby Dillon, and Eastern style at
13 times, Rupindar Dillon, and that she may have fudged on her date of birth, the
14 system knew this and managed to accumulate enough information on Dillon that J.
15 Salter knew exactly who Dillon was, and then some.
16
280. Dillon er, the person J. Salter did not know was taken in
17 handcuffs from the courtroom of Lamoreaux Center and as a result was publicly
18 humiliated and defamed. She was booked into the Orange County jail, notorious
19 for its abuse and humiliation of prisoners. She was strip searched and body cavity
20 searched. Dillon was forced to shower twice - forcing her for a longer time to
21 remain in the nude in the presence of sullen, angry fully-clothed guards with guns,
22 there to remind her (and all the other prisoners) who was boss. Because of the
23 amount of bail, it took some time for Dillon to post bail and be released from jail.
24
281. In criminal court, the case was immediately dismissed, even before
25 Dillon was arraigned. Dillon, however, had to borrow money to pay a criminal
26 attorney.
27
282. Besides retaliating against McKeon, Reinhart, Tong, and Dillon, J.
28 Salter also issued an OSC re: contempt against Alan Gleisinger, who is Dillons
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1 husband, and threatened Ron Funk, Dillons family law attorney who also filed
2 writ petitions and an appeal for Dillon. J. Salter claimed that Gleisinger had done
3 something wrong because he had written on the subpoena he had served on behalf
4 of Dillon.
5
283. Funk spoke up and informed the Court he had authorized Gleisinger
6 to add the additional handwritten information on the subpoena. Then, J. Salter

7 threatened Funk.
8
284. As when entering Dantes Inferno, so when entering J. Salters
9 courtroom, all those who concluded Srikureja was sexually abusing A.D. were
10 given fair warning: All hope abandon, ye who enter here. Only those who
11 claimed that Dillon had coached A.D. or that A.D. was lying were welcomed.
12
285. With the press and the public becoming more and more upset at J.
13 Salter and the other defendants named in this lawsuit, on August 29, 2014, J.
14 Salter transferred the case to Napa County and allowed Eva, the estranged wife of
15 Srikurejas brother, to take A.D. into her home in Napa County. The Orange
16 County investigator found Eva unfit to be [A.D.]s guardian and the Orange
17 County guardianship case was dismissed.
18
286. Eva participated in the conspiracy by falsifying her application to be
19 appointed as guardian for [A.D.] She made false allegations against Dillon. She
20 has falsely imprisoned [A.D.] and has not arranged for [A.D.] to see Dillon. She
21 has hidden A.D. Eva does not have A.D. registered at any school in Napa County,
22 including the private schools.
23
287. The end result of Dillons attempt to protect A.D. in the Court for
24 almost five years has resulted in her child being disappeared. J. Salter has left the
25 child adrift with no guardian and denied her right to be with the only parent who
26 desperately wants to raise and care for her, her mother. No one knows where A.D.
27 is, and she could be out of state or out of the country, even in Thailand. This is
28 Orange Superior Courts brand of acting in the best interests of a child.
70
1 Meanwhile, Court allows J. Salter to continue as a family law judge and

2 DeArmey, Stokke, and LaFlamme have reaped enormous profit off their
3 exploitation of A.D.
4
5
EXHAUSTION OF ADMINISTRATIVE REMEDY

288. Dillon filed timely government claims with Tustin Police Department
6 and Breeze and against the County. Neither the police department nor the County
7 issued a denial of the claim. Dillon has exhausted the administrative remedy.
8 This lawsuit is timely since it was filed within two years of the filing of the two
9 government claims.
FIRST CAUSE OF ACTION
10
42 U.S.C. Sec. 1983 - First Amendment - Free Speech Retaliation and Denial
of Meaningful Access to Court; Fourth Amendment - Illegal Seizure of Child
12
and false arrest and imprisonment of Mother; Fourteenth Amendment Denial of Equal Protection and of Due Process - Denial of Family Rights and
13
of Right to Bodily and Emotional Integrity
Applies to Dillon and A.D. and to Rackauckas, Froeberg, Chang, Breeze,
14 Munoz, Naganuma, Wilkinson, Eitner, Bruzas-Ranes, Lux, Marron-Taylor,
Glidden, Palmquist, Johnson, Chlebowski, Malaban
11
15
16
17
18
19
20
21
22
23
24
25
26
27
289. Plaintiff incorporates paragraphs 1 - 289 as if fully set out in this

First Cause of Action.
290. The foregoing acts or omissions of the defendants, except for Chang,
deprived A.D. of rights, privileges, and immunities secured to her by the First
Amendment to the Constitution of the United States when she repeatedly disclosed
that Srikureja was sexually abusing her. Defendants contributed to A.D. being
made a refugee and disappeared by their retaliation.
deprived Dillon of rights, privileges, and immunities secured to her by the First
Amendment to the Constitution of the United States when she repeatedly reported
that A.D. had disclosed that Srikureja was sexually abusing her. They also
retaliated against Dillon because of the enormous negative publicity generated
against all the defendants in this case and against J. Waltz and J. Salter.
28
71
1 Defendants contributed to Dillons loss of custody and contact with her daughter
2 by their retaliation.
3
4 deprived Dillon and A.D. of rights, privileges, and immunities secured to them by
5 the First Amendment to the Constitution of the United States of meaningful access
6 to the Court.
7
293. Social worker defendants retaliated against Dillon and A.D. for their
8 free speech and denied them meaningful access to the Courts by, inter alia,
9 undermining the police officers findings and conclusions that A.D. was credible
10 and that Srikureja was sexually abusing A.D., by quashing the two juvenile court
11 petitions the police had filed, by irrationally unfounding A.D.s disclosures of
12 sexual abuse, by relying on inadmissible hearsay rather than interviewing the
13 witnesses who had direct knowledge of the events in question, by falsifying their
14 findings, and by conspiring with all the other defendants to suppress and hide
15 Srikurejas sexual abuse of A.D.
16
294. Their falsified reports and suppression of relevant evidence were then
17 used by Munoz in court to discredit A.D., Dillon, Reinhart, the E.R. physicians
18 report, Kanofsky, Sheffner, and Tustin police officers before J. Waltz, a willing
19 recipient of the fraud.
20
295. Munoz further became J. Waltzs expert when he knew he had no
21 expertise and committed perjury by claiming to have attended two colleges he had
22 never attended and claiming to have degrees he never obtained. J. Waltz may
23 have suborned this perjury. Munoz also participated in illegal exparte
24 communication with J. Waltz to the detriment of Dillon and A.D.
25
296. Rackauckas and Froeberg engaged in free speech retaliation against
26 Dillon and A.D. and denied them meaningful access to the Courts by taking over
27 the investigation of the sexual abuse charges because Tustin P.D. had repeatedly
28 concluded that Srikureja was sexually abusing A.D. and had recommended his
72
1 prosecution on six felony counts of child sexual abuse, had taken A.D. into
2 protective custody and filed a juvenile court petition twice, and had also
3 recommended prosecution of numerous individuals involved in the conspiracy
4 with Srikureja, namely, Edgar, Coleman, Nash, Stewart, and Nashs company.
5 They also ignored the Sheriff Departments recommendation of Cate for
6 prosecution.
7
297. Rackauckas and Froeberg also denied meaningful access to the Court
8 by depriving Dillon of CPS CAST interviews of A.D. Froeberg was so bold that
9 she sent an email exparte to J. Salters courtroom clerk letting her know she would
10 not provide them to Dillon, thus insuring Dillon could not prove in J. Salters
11 court how consistent and credible A.D. was in disclosing the abuse of Srikureja.
12
298. Froeberg, DeArmey, and Stokke were willing participants in the
13 conspiracy of Defendants to retaliate against Dillon and A.D. because of A.D.s

14 and Dillons free speech (A.D.s disclosing sexual abuse, Dillons reporting the
15 sexual abuse to the court and generating widespread negative publicity exposing
16 the defendants and the judges misconduct and conspiracy).
17
299. Rackauckas and Froeberg also denied meaningful access by letting J.
18 Salter know they declined prosecution of Srikureja. They suppressed evidence

19 and conducted a sham investigation based on Rackauckas pay-to-play scheme
20 whereby he and Stokke agreed that Stokkes clients would not be prosecuted or at
21 worst, a sweetheart plea agreement would be reached. Rackauckas also insured
22 that no coconspirator of Srikureja who had committed crimes would be prosecuted
23 although Tustin P.D. and the Sheriff had referred them for prosecution.
24
300. Defendant Social Workers questioning of A.D. without her mother or
25 Reinhart present violated A.D.s Fourth Amendment rights.

26
301. When Chang falsely arrested and falsely imprisoned Dillon without
27 probable cause because no misdemeanor was committed in his presence nor was
28 there an outstanding warrant for her arrest, Chang violated Dillons Fourth
73
1 Amendment rights.
2
3 deprived Dillon and A.D. of rights, privileges, and immunities secured to them
4 under the Equal Protection Clause not to be discriminated against based on
5 Dillons status as a female protective parent and A.D.s status as a female abused
6 child.
7
8 deprived Dillon and A.D. of rights, privileges, and immunities secured to them
9 under the Due Process Clause guaranteeing both of them a familial relationship,
10 one with the other, and Dillon, the right of custody to A.D.
11
304.
The foregoing acts or omissions of the defendants, except for Chang,
12 deprived A.D. of her under the Due Process Clause to emotional and bodily
13 integrity when they insured that Srikureja would retain custody of her and she
14 would be denied the care, protection, and companionship of her mother.
15
305. As a proximate result of the violation of Plaintiffs rights as listed
16 above by Defendants, Plaintiff has suffered the loss of pay and job benefits, and
17 she and A.D. have suffered humiliation, mental anguish, and severe emotional and
18 physical distress, and have been injured in mind, body, and spirit. Dillon has had
19 to retain an attorney and pay fees to prosecute this lawsuit.
20
306. The acts of Defendants were willful, wanton, malicious, and
21 oppressive, thus justifying an award of exemplary and punitive damages against

22 Defendants in an amount to be determined at trial.
SECOND CAUSE OF ACTION

42 U.S.C. Sec.1985(2):Conspiracy to Deny Equal Protection and to Violate
24 First Amendment - Free Speech Retaliation and Denial of Meaningful Access
to Court; Fourth Amendment - Illegal Seizure of Child; Fourteenth
25 Amendment - Denial of Due Process (Denial of Family Rights and of Right to
Bodily and Emotional Integrity)- applies to Dillon and A.D. and to all
26
Defendants EXCEPT Chang, California, County, and Court
23
27
307. Plaintiff incorporates paragraphs 1 - 289, 290-300, 302 - 304 as if
28 fully set out in this Second Cause of Action.

74
308. Defendants conspired for the purpose of impeding, hindering,
2 obstructing, or defeating, in any manner, the due course of justice in [California],

3 with intent to deny to [Dillon and A.D.] the equal protection of the laws, [and] to
4 injure [Dillon and A.D.] [and] [their] property for lawfully enforcing, or
5 attempting to enforce, the right of [Dillon and A.D.] to the equal protection of the
6 laws.
7
309. Nash & Associates is liable per respondeat superior. All the other
8 defendants named in this cause of action worked for the common goals of
9 suppression of evidence that Srikureja sexually abused A.D., insuring that
10 Srikureja would retain custody of A.D., that A.D. would be deprived of custody of,
11 and contact with, her daughter, and that A.D. would never see her mother again.
12
310. Srikureja, LaFlamme, DeArmey, and Stokke violated A.D.s and
13 Dillons right to free speech, denied meaningful access to the courts, discriminated
14 against them based on gender (female protective parent and abused female child),
15 denied them family rights, and denied A.D.s right to emotional and bodily.
16
311. Some examples of their bad acts include persuading the willing
17 judges to keep out all testimony of Kanofsky (Srikureja), Reinhart (LaFlamme),

18 marginalizing Sheffner by attempting to block his testimony and failing to provide
19 him CPS and police reports (Eitner and LaFlamme), defaming Dillon (LaFlamme,
20 DeArmey, LaFlammes assistant Sanchez), by repeated contacts with Rackauckas
21 and Froeberg (De Armey and Stokke, possibly LaFlamme), by undermining Tustin
22 P.D., by returning A.D. to Srikureja twice after Tustin P.D. had placed her in
23 protective custody, by hiring Nash knowing that Nash and Stewart would do his
24 bidding (LaFlamme), by suppressing all reports of Reinhart and objecting to her
25 testifying and requesting that A.D. be made a refugee and forced to live with the
26 sister-in-law of Srikureja resulting in A.D.s disappearance (Cate). DeArmey,
27 Stokke, and possibly indirectly LaFlamme misled Tong into believing, for
28 example, that Coleman was court appointed therapist for A.D., that there were
75
1 only 300 pages or so of discovery when there were several thousands, and refused
2 to provide him the CSP (CAST interviews) and Tustin P.D. police reports.
3 DeArmey and LaFlamme also made blatantly false statements about Dillon to
4 Defendant social workers. LaFlamme may have persuaded the defendant social
5 workers to quash the juvenile court petitions and to recommend the return of A.D.
6 to Srikureja.
7
312. Breeze accomplished the goals of the conspiracy by testifying to
8 opinions for which she had no foundation either in fact or in expertise. Edgar
9 accomplished the goals of the conspiracy by working with Srikureja to lie against
10 Dillon and to agree unethically with a clear conflict of interest to take custody of
11 A.D. when she was Srikurejas former attorney, and A.D. alleged that Srikureja
12 was sexually abusing her. Coleman accomplished the goals of the conspiracy by
13 working with Srikureja to force A.D. to meet with her in violation of a court order,
14 by feigning that she was a therapist for A.D., by writing falsified letters about her
15 contacts with A.D. and providing them to Froeberg via Stokke and/or DeArmey.
16 Stewart and Nash accomplished the goals of the conspiracy by working, on
17 information and belief, with LaFlamme and/or DeArmey to invent the story of the
18 secret phone resulting in defendant social workers and J. Waltz discrediting
19 Dillon and A.D., by defaming Dillon in a letter to J. Waltz, and by failing to make
20 a mandated report when A.D. disclosed sexual abuse in Stewarts presence.
21
313. Eva, Pravit, and Lockmer conspired to violate A.D.s right to bodily
22 and emotional integrity by falsely imprisoning her, by abusing and neglecting her
23 to punish her for repeatedly disclosing that Srikureja was sexually abusing her.
24 They conspired with Srikureja to write false declarations against Dillon.
25
314. Srikureja conspired with all the other defendants either directly or
26 indirectly through his attorneys, Edgar, DeArmey, Stokke, LaFlamme, and Cate, to
27 retain custody of A.D. so that he could sexually abuse her in violation of her right
28 to bodily and emotional integrity.
76
6

8 Defendants in an amount to be determined at trial. Nash & Associates is liable for
9 punitive damages per respondeat superior.
THIRD CAUSE OF ACTION

42 U.S.C. Sec.1985(3): Conspiracy to Deny Equal Protection and to Violate
11 First Amendment - Free Speech Retaliation and Denial of Meaningful Access
to Court; Fourth Amendment - Illegal Seizure of Child; Fourteenth
12 Amendment - Denial of Due Process (Denial of Family Rights and of Right to
Bodily and Emotional Integrity)
13 - Applies to Dillon and A.D. and to all and to all Defendants EXCEPT Chang,
California, County, and Court
10
14
15
16
317. Plaintiff incorporates paragraphs 1 - 289, 290-300, 302 - 304, 308314 as if fully set out in this Third Cause of Action.
318. 42 U.S.C. Sec.1985(3) states in part that
17
If two or more persons in any State or Territory conspire or go in

disguise on the highway or on the premises of another, for the
purpose of depriving, either directly or indirectly, any person or class
of persons of the equal protection of the laws, or of equal privileges
and immunities under the laws; or for the purpose of preventing or
hindering the constituted authorities of any State or Territory from
giving or securing to all persons within such State or Territory the
equal protection of the laws...
18
19
20
21
22 the individuals harmed by the conspiracy are entitled to damages.

23
319.
Nash & Associates is liable per respondeat superior. All the other
24 defendants did engage in said conspiracy and did prevent and hinder the
25 constituted authorities, namely, the Court, the District Attorneys Office, and
26 Tustin Police Dept from giving or securing to Dillon and A.D. the equal protection
27 of the laws based on their status as a female protective parent and an abused
28 female child.
77
6

10
11
12
13
14
15
16
17
18
19
20
21
FOURTH CAUSE OF ACTION

42 U.S.C. Sec.1986: Action for Neglect to Prevent Wrongs Applies to Dillon and to A.D. and to All Defendants, Except Chang, State,
Court, and County
322. Plaintiff incorporates paragraphs 1 - 289, 290, - 300, 302 - 304, 308 314, 318 - 319 as if fully set out in this Fourth Cause of Action.
323. 42 U. S.C. Sec.1986 states in part:
Every person who, having knowledge that any of the wrongs
conspired to be done, and mentioned in section 1985 of this title, are
about to be committed, and having power to prevent or aid in
preventing the commission of the same, neglects or refuses so to do,
if such wrongful act be committed, shall be liable to the party injured,
or his legal representatives, for all damages caused by such wrongful
act, which such person by reasonable diligence could have prevented;
and such damages may be recovered in an action on the case; and any
number of persons guilty of such wrongful neglect or refusal may be
joined as defendants in the action;....
324. Nash & Associates is liable per respondeat superior. Each and every
22 other defendant named in this cause of action had an affirmative obligation to

23 prevent the harm coming to Dillon and A.D. and failed to stop the commission of
24 the acts in which they all engaged. Now, A.D. has been disappeared by J. Salter,
25 and it is unknown what her condition is.
26
78
3

7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
FIFTH CAUSE OF ACTION

Violence Against Women Reauthorization Act , (VAWA) 42 U.S. Code
Sec.12395(b): Gender discrimination - Applies to Dillon and A.D. and to
California, County, Court, LaFlamme, Cate, and Nash & Associates
327.
Plaintiff incorporates paragraphs 1 - 289, 290, - 300, 302 - 304, 308 -
314, 318 - 319, 323- 324 as if fully set out in this Fifth Cause of Action.
328. 42 U.S. Code Sec.12395(b)(13)(A) states:
No person in the United States shall, on the basis of actual or
perceived race, color, religion, national origin, sex, gender identity
(as defined in paragraph 249(c)(4) of title 18), sexual orientation, or
disability, be excluded from participation in, be denied the benefits
of, or be subjected to discrimination under any program or activity
funded in whole or in part with funds made available under the
Violence Against Women Act of 1994 (title IV of Public Law
103322; 108 Stat. 1902), the Violence Against Women Act of 2000
(division B of Public Law 106386; 114 Stat. 1491), the Violence
Against Women and Department of Justice Reauthorization Act of
2005 (title IX of Public Law 109162; 119 Stat. 3080), [1] the
Violence Against Women Reauthorization Act of 2013, and any other
program or activity funded in whole or in part with funds
appropriated for grants, cooperative agreements, and other assistance
administered by the Office on Violence Against Women.
329. 42 U.S.C. Sec. 2000d-7(a) states:
(a)
General provision
(1)
A State shall not be immune under the Eleventh

Amendment of the Constitution of the United States
from suit in Federal court for a violation of section 504
of the Rehabilitation Act of 1973 [29 U.S.C. 794], title
IX of the Education Amendments of 1972 [20 U.S.C.
1681 et seq.], the Age Discrimination Act of 1975 [42
U.S.C. 6101 et seq.], title VI of the Civil Rights Act of
1964 [42 U.S.C. 2000d et seq.], or the provisions of any
other Federal statute prohibiting discrimination by
recipients of Federal financial assistance.
(2)
In a suit against a State for a violation of a statute
23
24
25
26
27
28
79
1
2
3
4
referred to in paragraph (1), remedies (including

remedies both at law and in equity) are available for such
a violation to the same extent as such remedies are
available for such a violation in the suit against any
public or private entity other than a State.
330. California, County, Court, LaFlamme, Cate, and Nash & Associates
5 receive federal funds. On information and belief, they may all receive VAWA
6 funds, either directly or indirectly. Rather than protect A.D., instead, Defendants
7 and Nash & Associates owner and employee (Nash and Stewart) have turned the
8 law on its head, perverted the purpose of the funds, and discriminated against both
9 Mother and A.D., based on their gender as female protective parent and abused
10 female child continuing into the present time in Court.
11
331. Discrimination on the basis of Mother and Daughters gender has
12 resulted in denial of Dillons and A.D.s family rights. It has also resulted in a
13 denial of A.D.s right to bodily and emotional integrity. Judge Salter has
14 disappeared A.D. making her a refugee in her own country by displacing her from
15 Orange County and hiding her from her mother. It has also resulted in denial of
16 equal protection to both Dillon and A.D. based on irrational favoritism towards the
17 perpetrator of abuse, namely, Srikureja, who is male. As a result, Dillon and A.D.
18 have had no access to each other since October 2013.
19
332. The Sheriff Department wanted Cate prosecuted for what he has done
20 to A.D., and Rackauckas and Froeberg blocked the prosecution in violation of

21 Dillons and A.D.s right not to be discriminated against on the basis of their
22 gender, among other rights.
23
28
334. The acts of LaFlamme, Cate, and Nash and Stewart were willful,
80
1 wanton, malicious, and oppressive, thus justifying an award of exemplary and

2 punitive damages against LaFlamme, Cate, and Nash & Associates (the latter, per
3 respondeat superior) in an amount to be determined at trial.
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
SIXTH CAUSE OF ACTION

Monell violation - applies to Dillon and A.D. and to County only
335. Plaintiff incorporates paragraphs 1 - 289, 290 - 300, 302 - 304, 308 314, 318 - 319, 323- 324, 328 - 332 as if fully set out in this Sixth Cause of
Action..
336. Based on the principles set forth in Monell v. Dept. Of Social
Services, and related cases, County is liable for the injuries and damages suffered
by Dillon and A.D., because County maintains a policy, practice, custom, and
habit as follows: Social workers engage in a regular practice of denying due
process and equal protection to female protective parents and their abused
children, in favor of the male abusive parent and then suppressing evidence of the
fathers abuse and neglect as was done in this case.
337. Social workers routinely lie and commit perjury with respect to
reports they file with the Court. They routinely retaliate against parents, mostly
mothers, who speak out against DCFS corruption. They cover up evidence of
abuse and neglect with the end result that many children are severely injured and
die while in the custody of DCFS, overwhelmingly and inexcusably so. In this
case, Defendant social workers specifically suppressed the mandated reports from
Reinhart, Kanofsky, Sheffner, E.R. physician, Tustin police officers and also
quashed two juvenile court petitions filed or requested to be filed by Tustin police
officers.
338. As a matter of custom and practice, social workers routinely deprive
female protective parents and their abused children not only of protection from the
abuser but deny them equal social services. They favor the male abusive parent,
give him custody, turn the tables on the mother, gaslighting her, and accusing her
28
81
1 of making false reports of abuse when it is the social workers who are falsifying
2 reports and regularly committing perjury.
3
339.
DCFS is charged by the California Penal Code and its own statewide
4 guidelines, known as the California DSS Manual, with investigating all allegations
5 of child abuse. Penal Code 11165.9; DSS Manual 31-110 & 31-115.
6
340. Welf. & Inst. 328 also charges social workers with mandatory
7 investigative duties regarding reports of child abuse. The plain language of

8 Welfare & Institutions 16500 shows the legislatures intent to provide a legal
9 framework to protect at-risk children, as quoted in pertinent part below:
11
The legislature hereby declares its intent, in providing for this statewide
system of child welfare services, that all children entitled to be safe and free
from abuse and neglect. Welf. & Inst. 16500
12
341. The statewide DSS Manual requires that social workers conduct an
10
13 in-person investigation with all relevant children, and their custodial parents. (DSS
14 Manual 31-125.22.) Social workers are further charged with determining, based on
15 their investigations, the potential for or the existence of any condition(s) which
16 places the child, or any other child in the family or household, at risk and in need
17 of services... (DSS Manual 31-125.)
18
342. Social workers routinely, as here, falsify their reports about the
19 children instead of reporting to the court what the child is disclosing to them over
20 and over again, as occurred here. They maliciously keep the abused child(ren)
21 with the abusive parent. As a result of this practice, many children are severely
22 harmed and often are murdered by the abusive parents about whom the County
23 workers were repeatedly put on notice as occurred in this case.
24
343. As a result of the Countys deliberate indifference to the rights of
25 mothers as protective parents and the status of their children as abused children,
26 Dillon and A.D. were denied due process and equal protection because of their
27 respective statuses as a female protective parent and as a female abused child. The
28 above-described pattern and practice is the moving force behind the
82
1 constitutional violation.
2
344. Dillon and A.D. have suffered pain and mental anguish, emotional
3 and physical distress, and have been injured in mind, body, and spirit. Dillon has
4 had to retain an attorney to prosecute her rights and the rights of A.D.
SEVENTH CAUSE OF ACTION

Negligence per se- Applies to Dillon and A.D. and to County, Munoz,
6 Naganuma, Wilkinson, Eitner, Bruzas-Ranes, Luz, Marron-Taylor, Glidden,
Palmquist, Johnson, Chlebowski , Malaban
5
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
345. Plaintiff incorporates paragraphs 1 - 289, 290, - 300, 302 - 304, 308 314, 318 - 319, 323- 324, 328 - 332, 336- 343 as if fully set out in this Seventh
Cause of Action.
346. Based on the holding in C.A. v. William S. Hart Union High School
(2012) 53 Cal. 4th 861, the County is directly liable for the negligence of
supervisory personnel, some of whom have been identified in this lawsuit as
possibly Glidden, Bruzas-Ranes, and Lux, who allowed their subordinate social
workers named as defendants in this cause of action to suppress evidence, to
conduct purposely faulty and incomplete investigations, to reach conclusions
(unfounded, inconclusive) which were directly contradicted by the very
evidence they relied on for those conclusions. Discovery will conclusively
establish who of the defendant social workers were supervisors.
347. Defendant social workers named in this cause of action violated Penal
Code 11165.9; Welf. & Inst. 328 ; and DSS Manual 31-110 & 31-115 in that
under these provisions, Defendants had an affirmative obligation to conduct
meaningful investigations of the sex abuse allegations. Instead, as laid out in great
detail in this pleading, Defendants, inter alia, falsified reports, suppressed relevant
evidence, questioned A.D. in such a way as to trick her and to impose irrelevant
standards on a child designed to sabotage the interview of A.D. Defendants also
allowed repeated questioning of A.D. which in itself caused grave emotional
distress for A.D.
28
83
348. For example, Defendants accepted libelous and defamatory
2 statements against Dillon and A.D. at face value without investigation. They
3 refused to support Tustin police officers juvenile court petitions and instead
4 quashed them. They conspired with Srikureja, DeArmey, LaFlamme, possibly
5 Rackauckas and/or Froeberg to defeat Dillons efforts to protect her child. They
6 ignored or glossed over the mandated reports of the E.R. physician, of Kanofsky,
7 of Sheffner, and of Reinhart (the social workers accepted LaFlammes lies that
8 they could not interview Reinhart because he claimed he held the privilege on
9 behalf of A.D., which is such a perversion of the law that the social workers had to
10 know he was lying about the law.)
11
349. Munoz, in turn, presented the other defendant social workers
12 deficient and falsified reports of investigation to J. Waltz who was a willing

13 participant in this grand show trial. As a direct result of this misconduct, A.D.
14 and Dillon suffered grave harm and grievous injury, not the least of which was
15 that Dillon did not have custody restored to her even when Srikureja abandoned
16 A.D., and J. Salter has disappeared A.D. from Orange County. Dillon does not
17 know where A.D. is, whether she is safe, whether she is even attending school.
18
350. Dillons and A.D.s injury resulted from the kind of occurrence Penal
19 Code 11165.9; Welf. & Inst. 328 ; and DSS Manual 31-110 & 31-115 were
20 designed to prevent, and Dillon and A.D. were members of the class of persons the
21 statutes and regulation were intended to protect.
22
351. As a proximate result of the violation of Dillons and A.D.s rights as
23 listed above by Defendants, Dillon has suffered the loss of pay and job benefits,
24 and she and A.D. have suffered humiliation, mental anguish, and severe emotional
26 had to retain an attorney and pay fees to prosecute this lawsuit.
27
352. The acts of Defendants, EXCEPT COUNTY, were willful, wanton,
28 malicious, and oppressive, thus justifying an award of exemplary and punitive

84
1 damages against them in an amount to be determined at trial.
EIGHTH CAUSE OF ACTION

Breach of Fiduciary Duty- Applies to Dillon and A.D. and to Munoz,
3 Naganuma, Wilkinson, Eitner, Bruzas-Ranes, Luz, Marron-Taylor, Glidden,
Palmquist, Johnson, Chlebowski , Malaban, LaFlamme, and Cate
2
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
353. Plaintiff incorporates paragraphs 1 - 289, 290, - 300, 302 - 304, 308 314, 318 - 319, 323- 324, 328 - 332, 336- 343, 347 - 350 as if fully set out in this
Eighth Cause of Action.
354. Defendant Social Workers had a mandatory and affirmative
obligation set out in statute and regulation to conduct meaningful child abuse
investigations. Once undertaking the investigations, they also incurred a fiduciary
duty to Dillon and A.D. not to violate the statutory duty with respect to the
investigations. They breached their fiduciary duty to Dillon and A.D. for which
both Dillon and A.D. suffered grave injury and damages.
355. LaFlamme and Cate agreed to represent A.D. as her attorney. As
A.D.s attorneys, LaFlamme and Cate, owed A.D. a fiduciary duty which includes
a duty of loyalty to represent her zealously and competently and not to betray her.
As a minor, they must insure her health, safety, and welfare and advocate for her
best interests.
356. As laid out in great detail in this pleading, LaFlamme and Cate
breached the fiduciary duty repeatedly selling out their own client to protect
Srikureja, the man A.D. said was sexually abusing her. Cates misconduct was
extreme enough for Orange County Sheriff Dept to recommend that he be
prosecuted. Rackauckas and Froeberg did not prosecute Cate because of the pay
to play arrangement Rackauckas had with Stokke.
357. Has the defendants not breached their fiduciary duties to Dillon and
A.D., the outcome of the custody litigation would have been different. That is,
Dillon would have retained custody of A.D. and Srikureja would have been
prosecuted for sexual abuse of A.D., or at a minimum had his right of visitation
28
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1 curtailed or denied.
358. As a proximate result of the violation of Dillons and A.D.s rights as
3 listed above by Defendants, Dillon has suffered the loss of pay and job benefits,
4 and she and A.D. have suffered humiliation, mental anguish, and severe emotional
6 had to retain an attorney and pay fees to prosecute this lawsuit.
359. Because the breaches of fiduciary duty involved criminal misconduct
8 on the part of the defendants (cover up of Srikurejas child sexual abuse) it was
9 foreseeable that Dillon and A.D. would suffer enormous harm. Thus, the acts of
10 Defendants, were willful, wanton, malicious, and oppressive, justifying an award
11 of exemplary and punitive damages against them in an amount to be determined at
12 trial.
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
NINTH CAUSE OF ACTION

Legal Malpractice - Applies to A.D. and to LaFlamme and Cate
360. Plaintiff incorporates paragraphs 1 - 289, 290, - 300, 302 - 304, 308 314, 318 - 319, 323- 324, 328 - 332, 336- 343, 347 - 351, 355 - 357 as if fully set
out in this Ninth Cause of Action.
361. LaFlamme and Cate agreed to represent A.D. as her attorney in a
child custody case where their client repeatedly alleged that Srikureja, her father,
was sexually abusing her. LaFlamme and Cate owed a duty to use an ordinary
degree of care, skill, or knowledge expected from other attorneys under similar
circumstances. They were far, far worse than breaching their duty to use ordinary
care, skill, and knowledge. They conspired with all the other defendants to defeat
A.D. and to undermine her. LaFlamme and Cate both falsely claimed her mother
was coaching A.D. to say that Srikureja was sexually abusing her which resulted
in A.D. losing even more contact with her mother and finally all contact with her.
362. Had LaFlamme and Cate zealously and competently represented A.D.
and maintained their duty of loyalty to her, the outcome would have been the very
28
86
1 opposite. That is, Dillon would have retained custody of A.D. and Srikureja
2 would have been prosecuted for sexual abuse of A.D., or at a minimum had his
3 right of visitation curtailed or denied.
4
363. LaFlammes and Cates criminal coverup of Srikurejas sexual abuse
5 of A.D. played a substantial role in the outcome of the custody litigation Dillon
6 lost custody and J. Salter disappeared A.D. to Napa, but whereabouts are
7 unknown. A.D. is a refugee in her own country.
8
364. LaFlammes and Cates misconduct is criminal. Orange County
9 Sheriff Dept recommended prosecution of Cate. Rackauckas and Froeberg refused

10 to prosecute Cate based on the pay to play arrangement Rackauckas has with
11 Stokke.
12
365. As a proximate result of the violation of A.D.s rights as listed above
13 by Defendants, A.D. has suffered humiliation, mental anguish, and severe

14 emotional and physical distress, and have been injured in mind, body, and spirit.
15 Dillon has had to retain an attorney and pay fees to prosecute this lawsuit.
16
366. Because the legal malpractice is based on LaFlammes and Cates
17 criminal misconduct (cover up of Srikurejas child sexual abuse) it was

18 foreseeable that A.D. would suffer enormous harm. Thus, the acts of Defendants,
19 were willful, wanton, malicious, and oppressive, justifying an award of exemplary
20 and punitive damages against them in an amount to be determined at trial.
22
TENTH CAUSE OF ACTION

False Imprisonment - Applies to A.D. and to Srikureja, Eva, Pravit, and
Lockmer.
23
367. Plaintiff incorporates paragraphs 1 - 289 as if fully set out in this
21
24 Tenth Cause of Action.

25
368. Srikureja, Eva, Pravit, and Lockmer intentionally deprived A.D. of
26 her freedom of movement by use of physical barriers, possible force, threats of

27 force, or menace or fraud or unreasonable duress and the detention compelled
28 A.D. to stay in her fathers home or in a place he rented and now allegedly in the
87
1 home of Eva in Napa for some appreciable time; A. D. did not knowingly and
2 voluntarily consented and in fact, repeatedly stated she did not want to live with
3 Srikureja, Eva, or Pravit. A.D. repeatedly made it clear she wanted to be with her
4 mother; A.D. suffered considerable harm in that she was deprived of her mothers
5 companionship, love, and care and is most likely being abused and neglected at
6 this time; Defendants conduct was a substantial factor in causing R.M.s harm.
7
369. The acts of Defendants constitute false imprisonment of A.D. who
8 has been held against her will for three years and denied the right to see and be
9 with her mother. J. Salter has disappeared her allegedly to Napa with no
10 guardian, her father has abandoned her, and Dillon does not know where A.D. is
11 residing.
12
370.
A.D. has suffered extreme pain and suffering mental anguish,
13 emotional and physical distress, and have been injured in mind, body, and spirit
14 for which Defendants are liable to her in damages.
15
371. Dillon has had to retain an attorney to prosecute A.D.s rights
16
372. The acts of Defendants were willful, wanton, malicious and

18 all the defendants in an amount to be determined at trial.
20
ELEVENTH CAUSE OF ACTION

Child Abuse - Applies to A.D. and to Coleman, Srikureja, Eva, Pravit, and
Lockmer.
21
373. Plaintiff incorporates paragraphs 1 - 289 into this Eleventh Cause of
19
22 Action as if fully set out.

23
374.
Srikureja fondled, sodomized, forced A.D. to touch his penis, and
24 otherwise sexually abused A.D. He emotionally abused her by forcing her to meet
25 with Coleman and probably hit and otherwise punished her for repeatedly
26 disclosing his acts of sexual abuse against her. He abandoned her, but refused to
27 request the Court to award custody to Dillon. He paid enormous amounts of
28 money to DeArmey, Stokke, and possibly to LaFlamme to commit criminal acts
88
1 and other acts of misconduct so that he would not be prosecuted for his sexual
2 abuse against A.D.
3
375. Srikureja deprived A.D. of her mother and imprisoned her in his
4 home. He deprived A.D. of the normal activities and experiences of children,

5 guarding her every move, and directing the other defendants named in this cause
6 of action to do the same. A.D. is not registered at any school in Napa. Her
7 whereabouts are unknown.
8
376. Coleman emotionally abused A.D. by forcing her to meet with her
9 and Srikureja thirty times to discuss the sexual abuse in the presence of Srikureja
10 and to try and force her to say she was coached.
11
377.
Eva, Pravit, and Lockmer deprived A.D. of sufficient food and failed
12 to provide her nurturing, yelled at her, possibly hit her, for repeatedly disclosing
13 Srikurejas sexual abuse. They all kept her a prisoner and denied her the normal
14 activities of children, guarding her every move. On information and belief, Eva
15 does not have A.D. enrolled in any school and may have placed her in an
16 apartment by herself as she predicted she would do in her initial paperwork
17 submitted with her petition for guardianship. Despite an Orange Superior Court
18 judge finding her to be unfit to serve as a guardian, J. Salter allowed Eva to
19 remove A.D. to Napa with no guarantees in place for her health, safety, and
20 welfare. Eva has no order of custody or guardianship.
21
378. As a result of the child abuse inflicted on A.D. by Defendants, A.D.
22 has suffered extreme pain and mental anguish, emotional and physical distress,
23 and has been injured in mind, body, and spirit.
24
379. Dillon has had to retain an attorney to prosecute her daughters rights.
25
380. The acts of Defendants were willful, wanton, malicious and

27 all the defendants in an amount to be determined at trial.
28 //
89
PRAYER
1
2
WHEREFORE, Plaintiff prays for relief as follows:
1.
action, special and compensatory damages;
4
5
As to all Causes of Action and all defendants named in the causes of
2.
As to all Causes of Action, except for the Ninth and Tenth Causes of
Action, attorney fees pursuant to 42 U.S.C. Sec.1988, 42 U.S.C.
Sec.1981a( c), and CA Code of Civ. Proced. Sec.1021.5;
3.
punitive damages excluding California, Court, and County;
9
10
As to all Causes of Action, except for the Sixth Causes of Action,
4.
For such other relief as may be just and proper
11 DATED: March 26, 2015
/s
PATRICIA J. BARRY
12
JURY REQUEST
13
14
Plaintiff requests a jury trial.
15 DATED: March 26, 2015
/s
PATRICIA J. BARRY
16
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90

First Amended Complaint Dillon V LaFlamme

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First Amended Complaint Dillon V LaFlamme

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Case 8:15-cv-00339-JLS-JCG Document 15 Filed 03/26/15 Page 1 of 90 Page ID #:88

1 PATRICIA J. BARRY SBN 59116

634 S. Spring St., Ste 823

2 Los Angeles, Ca 90014

Tele. (213) 995-0734

3 Fax (213) 995-0735

4 Attorney for Plaintiff RUBY DILLON

on behalf of herself and her minor daughter A.D.

5 as her guardian ad litem

UNITED STATES DISTRICT COURT

Case 8:15-cv-00339-JLS-JCG Document 15 Filed 03/26/15 Page 2 of 90 Page ID #:89

JILL LUX (in her individual capacity) 3.

Breach of Fiduciary Duty

PLAINTIFF RUBY DILLON (Dillon) on behalf of herself and her minor

Case 8:15-cv-00339-JLS-JCG Document 15 Filed 03/26/15 Page 3 of 90 Page ID #:90

U.S. Judges See 'Epidemic' of Prosecutorial Misconduct in State, Maura

5 Judge Thomas Goethels, DEFENDANT ORANGE SUPERIOR COURT

The Ninth Circuit panel (Judges Kozinski, Fletcher, and Wardlaw),

Despite what occurred in the Baca case, Harris remains tethered to a

Harris is wasting taxpayer dollars on an appeal defending Rackauckas

Case 8:15-cv-00339-JLS-JCG Document 15 Filed 03/26/15 Page 4 of 90 Page ID #:91

Fournier had repeatedly warned the Court about Dekraais domestic

DEFENDANT JOHN CATE (Cate) handpicked by DEFENDANT

11 HAROLD LAFLAMME (La Flamme) to be his successor as A.D.s minors

14 calif-salon-shooting/50745746/1, Cate was quoted as telling the Orange County

Yet, Fournier, his client alleged in pleadings that Dekraai

The murders occurred on October 12, 2011 and Michelle supposedly

Case 8:15-cv-00339-JLS-JCG Document 15 Filed 03/26/15 Page 5 of 90 Page ID #:92

It is also bitterly ironic that the misogynistic murderer successfully

It is also no coincidence that Fournier litigated her case in the same

8 court, DEFENDANT ORANGE SUPERIOR COURT (Court) as did Dillon.

On LaFlammes State Bar profile, LaFlamme does not list whether he

In 2009, Barry served a bar complaint against LaFlamme on the

Case 8:15-cv-00339-JLS-JCG Document 15 Filed 03/26/15 Page 6 of 90 Page ID #:93

Social workers and County Departments of Family and Social

The State Bar is also implicated in the statewide invidious

Kamansky also received a public reproval from the California

24 Commission on Judicial Performance for taping over a video which Bumpus

In October 2014, California Supreme Court Chief Justice

Case 8:15-cv-00339-JLS-JCG Document 15 Filed 03/26/15 Page 7 of 90 Page ID #:94

In September 2011, the State Bar Review Court, Judges Remke,

In February 2014, the California Supreme Court surprisingly reversed

Case 8:15-cv-00339-JLS-JCG Document 15 Filed 03/26/15 Page 8 of 90 Page ID #:95

Srikureja, Srikurejas attorneys, in particular, La Flamme, notorious

The conspiracy reached high places, and included DEFENDANT AL

16 STOKKE (Stokke), Srikurejas attorney and members of the District Attorneys

Srikureja abandoned A.D. in June 2013. He fled to Canada on June

The jurists, Commissioner Wilson (Comm. Wilson), Judge James

Case 8:15-cv-00339-JLS-JCG Document 15 Filed 03/26/15 Page 9 of 90 Page ID #:96

The judgment of J. Waltz entered in July 2013 giving Srikureja full

On May 7, 2014, J. Salter ordered his courtroom bailiff

21 DEFENDANT HOWARD CHANG (Chang) to falsely arrest and falsely

In August 2014, J. Salter ordered A.D. to Napa County where on

27 information and belief A.D. is forced to live with a virtual stranger,

Case 8:15-cv-00339-JLS-JCG Document 15 Filed 03/26/15 Page 10 of 90 Page ID #:97

After five years of custody litigation in Orange Superior Court, no

In Family Court, when a mother alleges abuse by the father of the

Further, as Srikureja and LaFlamme did, aided and abetted by a

Case 8:15-cv-00339-JLS-JCG Document 15 Filed 03/26/15 Page 11 of 90 Page ID #:98

Thus, the out-of-court statements of A.D. about sexual abuse most

As a nation we say we care about childrens safety and welfare. Yet,

Public hearings on custody are urgently needed, Such hearings could

JURISDICTION AND VENUE