• /1 I I I Jo Paolella : 43' I Wilshire Blvd. Ste. 314 2 Lo Angeles CA 90010 Te': 323.965.7506 3 Fa:: 323.965.7508 4 ' in propria persona , I 6' I • 7 17 ll-ti-------------------l Case No.: BC 391778 Honorable Helen I. Bendix Motion to Strike COITIPlaintUnder Section 425.16 C.C.fT.; Points & Authorities; Exhibits Date: 7/22/08 Time: 9:00 a.m. Dept: 18 Plaintiff, SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES - CENTRAL DISTRICT UNLIMITED CIVIL JURISIDICTION 8 '9 Ii 10 II II I,I I' I II 12 Grogan, 13 Ii 1,1 I; 14 II vs. , 15 tsePh Paolella et al, 16' Defendant , Ii '18 Ii :: TO: THE HONORABLE JUDGE HELEN I. BENDIX OF . 19 Ii 20 DEPARTMENT 18 OF THE LOS ANGELES SUPERIOR COURT, TO THE ikAINTIFF JOHN LEO GROGAN BY HIS COUNSEL, GEORGE 21 II 22 /BALTAXE, AND TO THE OTHER DEFENDANTS. I Defendant Joseph Paolella, who represents himself in propria persona, 23 ,I I fg 8. moves the Honorable Court for an order striking the Complaint in its a;:; . :24 <0 Z ..., "" 'T, -i en 25 I pursuant to the provisions of Section 425.16 C.C.P., based on .';:!::' I z I Motion and Motion, the Points & Authorities herein, the Exhibitsrattacheds f g 261 Cll':t:-l 0- ,..•. _J hereto, and such other evidence, oral and written, as may be presented upon the :;g 27 C::' "'J \Tl . '" ". hearing of this matter. g 51 28 " <. .. ! I " .I j , ' "" <., . o ::!I' Anti-SLAPP MOTION - I
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Joseph Paolella's Motion to Strike Complaint in Grogan v ...
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I I Jo ~ph Paolella: 43' I Wilshire Blvd. Ste. 314
2 Lo Angeles CA 90010Te': 323.965.7506
3 Fa:: 323.965.7508
4 ' D~fendant in propria persona
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17 ll-ti-------------------l
Case No.: BC 391778
Honorable Helen I. Bendix
Motion to Strike COITIPlaintUnderSection 425.16 C.C.fT.; Points &Authorities; Exhibits
Date: 7/22/08Time: 9:00 a.m.Dept: 18
Plaintiff,
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF LOS ANGELES - CENTRAL DISTRICT
UNLIMITED CIVIL JURISIDICTION
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12 J,~hn Grogan,13 Ii
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14 II vs.
,15 tsePh Paolella et al,
16' Defendant
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:: TO: THE HONORABLE JUDGE HELEN I. BENDIX OF. 19 Ii
20 DEPARTMENT 18 OF THE LOS ANGELES SUPERIOR COURT, TO THE
ikAINTIFF JOHN LEO GROGAN BY HIS COUNSEL, GEORGE21 II
22 /BALTAXE, AND TO THE OTHER DEFENDANTS.
I Defendant Joseph Paolella, who represents himself in propria persona,23 ,I ~ ~ I fg 8.
moves the Honorable Court for an order striking the Complaint in its entir~t~ a;:;. :24 <0 Z ..., ""
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25 I pursuant to the provisions of Section 425.16 C.C.P., based on thi~ijqJ;i~:Uf .';:!::'I ;;:r~;;:Q z ~~
I Motion and Motion, the Points & Authorities herein, the Exhibitsrattacheds f g ~261 Cll':t:-l
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hereto, and such other evidence, oral and written, as may be presented upon the :;g~27 C::' "'J \Tl. '" ".
hearing of this matter. g ~ 51~;28 " ~ ~
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Anti-SLAPP MOTION - I
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I~' Ii Notice is further given that a Request for Judicial Notice will be made for
2 he: ring in conjunction with this motion of documentary evidence, i.e., the
:l ; dertsions of an Administrative Law Judge (ALJ) concerning the revocation of
4 th~ Plaintiffs Private Investigator, Private Patrol Operator, and Firearms
Q~alification licenses by the Bureau of Security & Investigative Services.:1,I
~sepH Paolella"
9 Defendant in pro per"10
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Anti-SLAPP MOTION - 2
• •Statement of Facts
Points & AuthoritiesI
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II, Defendant Joseph Paolella is an honorably retired United States Secret"
~ Se~ice Agent who guarded President Kennedy during the Cuban Missile Crisis,
5 w~ile President Kennedy made his famous Ich bin ein Berliner speech in
6' G~rmany, and who performed many other crucial and honorable activities on
7 bt alf of his country. Subsequently, Joseph Paolella became and practices as a
8 li~ensed investigator in California and Illinois, an American PolygraphI
9 A~sociation (APA) certified polygraph examiner, and a California licensedIt
10 P1vate patrol operator.
II II Plaintiff John Leo Grogan formerly held California Private Investigator
submitted to a customer at such times and in such manner as has been
16 agreed upon between the licensee and the customer. Upon demand by
17 the customer, the licensee shall not refuse to divulge to the customer
. 18 the results of an investigation if payment has been tendered for charges
, 19 levied. It is the responsibility of the licensee to provide the customer
20 with a fee schedule or a reasonable explanation of the method by
21 ,i which charges to the customer for services are to be calculated.. '
22 I Given the foregoing, no trier of fact is likely to believe a word that the
23 'rlaintiff utters. Not only is there no probability that he can prevail upon his
24 Iclaim,there is littlepossibility that he can prevail.,25 I III
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26 ! CONCLUSION
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For the foregoing reasons, this motion should be granted.
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Anti·SLAPP MOTION - II
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, 23i oseph Paolella!
24 ~n pro per
, Defendant has made the initial showing that the alleged acts andI
2, omissions complained of by the Plaintiff all arise from constitutionally protected3 :1 h d .
i s~eec an expression.
4 . Plaintiff cannot plausibly demonstrate how he is going to prevail on his
S c~aim. Even assuming that he could demonstrate that some minutae of the
6 statements attributed to the Defendant were in fact made by him or on his behalf7 ,i
and happened to be false, the Plaintiff cannot possibly demonstrate that he was"
8 damaged by them. The Plaintiff was damaged irreparably by his own conduct
9 d~d the finding of misconduct made by a California ALJ which caused those'10 'if,ifcts to be placed in the public records of the State of California. From that
,II R:oint,the Plaintiff started at the bottom and has worked his way down ever
12 since. He can never rehabilitate his reputation.,
II13 I Any measure of damages would have to be calculated in terms of negative
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14 iiaegers. Hypothetically, if the Plaintiffs reputation has been damaged, whichI
15 i~ not conceded and assumed only for the purpose of argument, then it has,I
16 ~oved from a hypothetical point of negative 10 to negative 11. It is like
I 17 J!0.ussoliniarguing that he was at least not as bad as Hitler.i
,8 \! Again, the motion should be granted and an award of attorney fees andI
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19 ~osts be made based upon a cost bill to be submitted.I
The partiesprcseu:tedoral and documantaIyevidence. Submissionaftho matterfor""decisionwasdeferred until June 3, 2002 to permit respondentto offerproof oftimcly serviceby mail of a written dammd for cross-examinationof certainwitnesses'testimonywhichcomplainantwishedto present solelyby wayof dcc:larationpursuant to GoVClllIIXmtCodeSection11514. Suchproof wasmade,thepartieswereallowedten daysin whichto object,moveto strih; or argue,andthe issueof the ~ti.ons was submittedfor decision.TheCO\lTtfi,lldsthe demandtohllvobeentimelymade in aCCQl'dancewith law, and1hereforosustainsrcspondent'sobjectionto receiptin evidenceoftb.cdec1llnltionsoffered,Exln"bit5for identification. The general issue was submitted on Junc 3. 20()2.
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1. Shc:nieMoffet, complainatlt,is theI'rognm Manager of the above-entitledButMU,and caused1I:Ieaeeusatoryplesdjngsin this matterto be filedand servedwhileactingsolelyin horofficialcapacity.
2. The Bureauhas issuedthefollowinglitelisestorespondent, whicharenow in fuUforceandeffeet:
4. Duringthe periodsoCtimospecifiedbelow,respondentacted, and/oromittedtoact, in sucha wayas to subjecthis Bureau-issuedlicensesto discipline as morefullydescribedin the Conclusionsof Lawhereinafterfollowing.
S. In or about~er 1997,respondent~ to serveas a qualifying managerforC,M.u-COMectionWi.1I:ICM.'sapplicationfor licensureby the Bureau,andaccepted53,000.00fromCM. for this s«vico. Respondentfailedto be availableto CM. inconnectionwith his applicationand C.M.'squestionsthereon,and misled C.M. as to thenatureoCtilechargespending againstrespondentin this case,and as to the likelihoodof earlyandfavorableresolutionof such~s.
6. WhenC.M.1hcrca.fteIhadto obtainaD~ q).Ialifyingmanager,.respondcntrepeatedlyfailed and refused to refund anypart of the53,000.00 fee he had taken.
7. Rapoudent fraudulently lIl1ddi&honcstl.yinsisted he was entitled to retain all of the53.000.00.
I] 8, Inor aboutFebruary1998,respondententeredinto a stmilsrarrangementwithoneI C.R. wherein, for a $4,000.00 cub paym<mt,tOsp01tdentagreed t fataely StIl1leIIEIdcertify, as~'. partof anapplicationto theBureauby CoR.for IiconSUl'O,tbatresplmdeftthad serwd asa..'
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"Qn81ific:dManager"for the ped'vllrlllDceofhoursrequiredfor licensureas a private .investigatoras part of respondent's"sponsorsbipprogmm".but told C.R.hewoulddo allthisfor only 52,000.00bea\1lllO he "tilced"c.It.
: 9. At II subsequent meeting,after C.ll. paidrespondent$700., respondenttold C.ll.!I . 1hatlUsworkexperiencewas, in fact,probablyinsufficitmtbut that be. respondent,would
falselycertify that C.R.hadworkedwithimfof eee year. C.R. decidednot to completethoapplicationunder respondent's"sponsQtShip."
10. Respondentclidtho abovefor thepurposeofbonetiting himself 1I1ld,by allowingc.R.to produceabe evidenceofms qualificationsfor liec::nsureas a privateinvestigator,forthepurposeQfbcnefitingC.R.
11. The conduct set out hereinaboveconstitutedfraud and dishonest conductandwasdeceitful.
12. The Bureaubasincurredreasonablecostsof investigationand prosecutionoftbismattorin the aggregatesum of$21,SI0.00.
13. Ri:spcmde.nttestified as to his opinionsregarding"sponsorship"and arguedlIiscause. His testimonywasoverbroadand.vague,and fiu1edto indicatejust whatlegalauthoritypennittedthekind of "elltDwhileyouleam" program envisionedby him.In sum.respendenrs testimonyneilher~Jained his positionnor mitigatedhis conduct.
14. .All evidenceanclllr'gllmelltteackmiby re$p011dentin his defensehasbeenconsidered.
15. All allegationscontBinedin theaceusatmypleadingsupon which no specificfuvllngshave been :madcbc::rcinabOVllhavenot beenproved by c.ompetcnt, relevantevidence,
ConcluatonsotLaw-
By reason of the foregoina findiJIgsof filet,respondent'sIieensesand permits arc. subject to discipline: pursuant to Businessand Profeuiona CQd.eaectiona490, 7561.1(&),
7561.1(b) (for violation ofBusincss and ProfessionsCoda sectiOJlll7539(a), 7561.2 and7561.4).7561.1(e)(ta1cenin conj1D1ctionwithTitle 16,CaliforniaCode ofR.e&u1ations,section660) 7561.1(8), and,7561.1(I.)(ta'ir.enin ecmjunctiCJnwith BuMess and ProfessionsCodeCodesections4SO(a)(2),7S38(b)and (e).
I The Bureau is entitled to recoveri1sreasonablecosts of investigationand prosecutionr: in thesumof$21 ,810.00pursuantto section125.3oftbc Business andProfessionsCode-
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Alllicc:nsesandpermit!hcmofore:issuedto respondentby the Bureau,togetherwithincident8lliccnsingrights,andspecificallydcscribodin Finding2 aboveatellerebyrevobd.
~dent is hereby orderedto paythe Burceu its costs of investigation andprosecutionin tile sumofS21,810.00onorbeforetbethirtiethday fuUowingthe effectivedateof thisdecision.
No applicationby respondentfor reinstatementofthc said liccnscsand permits, orforimlance of anirt;tia1Ucenseshall be grantedabsentproofofpayment of theBureau'ssaidcostsasa conditionprecedentto the tilingof suchapplicationor applications.
II • •srl\"1E OF CAlIFO~NlA - STArt: AM) CONSUMER~"ERVJ(:~S AGa«:y AmolOSC;hw~r. ~Of
BUREAU 01' Sf.CU'RITV AND INYF.STIGAl'IVE SF.RV1CESPoslOfficelin' 9&0550
West SacramclIIo,l:,.,9519.t,;j\550(916) .122-40JJ!l
.www.dca.cn.;tl~\S
COMPLAINT mSIORY
J\IIle 14,2005
DearConsumer:
Thisis in responseto your inquiry aboutthe complaintsfiled againstthe licenseeslistedbelow.
In compliancewith the guidelinespresentedin t!le Public InfonnationAct, the InfonnaliollPracticesActandthe Departmentof ConswnerAffairsComplaintDisclosurePolicy,the followingis informationwhichis consideredpublic.
RevocationDatc:IOI2I/f)]
JohnLeoGroganSale Ownership
PI 15057Gold Star InvestigationsP.O. Box 9065CanogaPark,CA 91309
by the ALI in this case, All licensesandpermits issued to the Respondent by the
Bureau were revoked effective October 21,
2002. In addition, the Respondent was
ordered to pay the Bureau its costs of
investigation and prosecution in the sum of
21, 810.00 on or before the thirtieth day
following the effective date of the Decision.
No paymcmhas been received.
":':r.
Thisinformation reflects (ll\lyformal complaintsfiledduring thepastten- (10) yearsagainst the licensee.
Youmaywish to evaluate such other factorsas the si:zeoftbe company,the number of employees,and
lengthof time the company has been licensed.
The cIatapresented in the foregoing is not intendedto represent anyjudgment on the part of this Bureau,
Ifyouhavequestions, please contactme at (916) 445-3733.
ptc=ty, _
6A~yOllioe Technician
Enclosures
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BUREAU OF SECURITY AND INVI!:STIGATfVE SERVICES
DEPARTMENT OF CONSUMER AFFAIRS
STATE OF CALIFORNIA
In thc Matter of the Accusation against:
JOHN GROGANdba Gold Star InvestigationsP. O. Box 9065Canoga Park, CA 91309,
,Respondent.
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No lA96 9688
OAHNo, L-I99805016J
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PROPOSED DECISION
This case was tried before Paul M. Hogan, Administrative Law Judge of the Office ofAdministrative Hearings. lit Los Angeles, California. on May 24, 2002,
Glynda B. Gomez, Deputy Attorney General, represented complainant John Grogan,respondent, appeared personally without legal counsel, and participated throughout the trial.
The parties presented oral and documentary evidence. Submission of the matter fordecision was deferred until June 3. 2002 to permit respondent to offer proof of timely serviceby mail of a written delnancl for cross-examination of certain witnesses' testimony whichcomplainant wished to present solely by way of declaration pursuant to Government CodeSection 11514. 'Such proofwas madc, the parties were allowed ten days in which to object,move to strike, or argue, and the issue of the declarations was submitted for decision. Thecourt finds the demand to have been timely made ill accordance with law, and thereforesustain. respondent'. objection to receipt in evidence of the declarations offered, Exhibit 5for identification, The general issue wassubmitted on June 3, 2002
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Findings of Fact
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l. Sherrie Moffet, complainant. IS the Program Manager of the abcve-entitledBureau, and caused the accusatory pleadings in this matter to be filed and served while actingsolely in her official capacity.
2. The Bureau has issued the following licenses to respondent, which are now in fullforce and effect:
3. lhe parties have timely filed and served Oil one another all pleadings, noticesand other papers as required by law.
4. During fhe periods oftime specified below, respondent acted, and/or omitted toact, in such a way as to SUbject his Bureau-issued licenses to discipline as mere fullydescribed in the Conclusions ofl.aw hl'l'einafter follOWing.
5. ln or about December 1997, respondent agreed to serve as a qualifying managerfor CM. in connection with eM-'s application for licensure by the Bureau, and accepted$3,000.00 from eM. for this service, Respondent failed to be available to eM. inconnection with his application and C.M.'s questions thereon, andmisled C.M. as to thenature of the charges pending against respondent in this case, and as to the likelihood of earlyand favorable resolution of such charges,
6. When C.M. thereafter had to obtain a new qualifying manager, respondent'1 repeatedly failed and refused to refund any part of the $3,000,00 fee he had taken.
II ' 'I, Respondent fraudulently and dishonestly insisted he was entitled to retain all of theI $3,000.00. . •
ii 8. IIIor about February 1998, respondent entered into a similar arrangement with oneilC.R. wherein, for a $4,O,OO.OO,cashpayment, respondent agreed t falsely state and certify, asipart of'an application to the Bureau by C.R. for licensure, that respondent had served as a
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"Qualified Manager" for the performance of hours required for licensure as a privateinvestigator as part of respondent's "sponsorship program", but told CR he would do all thisfor only $2,000.00 because he "liked" c.R.
9. At a subsequent meeting, after c.R.paid respondent $700., respondent told C.R.that his ~ork experience was, in fact, probably insufficient but that he, respondent, wouldfalselycertify that c.R.had worked with im for one year. C.R. decided not to complete theapplication under respondent's "sponsorship."
10. Respondent did the above for the purpose of'bencfiting himself and, by allowingC.R. to produce false evidence of his qualifications for licensure as a private investigator, forthe purpose of benefiting c.R.
11. The conduct set out hereinabove constituted fraud and dishonest condu ..:t and wasdeceitful.
12. Thc Bureau has incurred reasonable costs of investigation and prosecution of thismatter in the aggregate sum 0£$21,810.00.
13. Respondent testified as to his opinions regarding "sponsorship" and argued hJScause. His testimony was overbroad and vague, and failed to indicate just what legalauthonty permitted the kind of "earn while you learn" program envisioned by him.In sum, respondent's testimony neither explained his position nor mitigated his conduct.
14. All evidence and argument tendered by respondent in his defense has beenconsidered.
15. All allegations contained in the accusatory pleadings upon which no specificfindings have been made hereinabove have not beenproved by competent, relevant evidence.
Conclusions of Law
By reason of the foregoing findings of fact, respondent's licenses and permits aresubject to discipline pursuant to Business and Professions Code sections 490,7561.1 (a),
i 7561.1(b) (for violation of Business and Professions Code sections 7539(a), 7561.2 and756J:4),7561.I (c)(taken in conjunctionwith Title 16, California Code of Regulations,section 660) 756 J.l (g), and 7561.1(l)(taken in conjunctionwith Business and ProfessionsCode Code sections 480(a)(2), 7538(b) and (c).
The Bureau is clltided,to recover its reasonable COstS of investigation and prosecutionillthe sum of $21,8 t D.ODpursuant to section J25.3 of the Business and Professions Code.
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All licenses and permits heretofore issuedto respondent by the Bureau, together withincidentallicensing rights, and specificallydescribed ill Finding2 above are hereby revoked,
Respondent is hereby ordered to pay the Bureau-its costs of investigation andprosecution in the sum of $21,8 \n,Ooon or before the thirtieth day following the effectivedale of this decision,
No application by respondent for reinstatement of the said licenses and permits, orfor issuance of an initial license shall be granted absent proof of payment of the Bureau's saidcosts as a conditionprecedent to the filing of such application or applications.
DEFORETHEDIRECTORDEPARTNfr,NT OF CONSUMER !\FFI\IRS
BUP--.EAUOF SECURITY AND lNVESTIOATlVE SliRVICESSTATE OF CALIFORNiA
In the Matter of .... AccusationAgainst:
JOlIN GROGANdba Gold Star InvestigationsP.O. Box 9065Canoga Park, CA 91309,
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DECISION
No. lA96 9688
OARNo L-1998050163
The attached Proposed Decision of the Administrative Law Judge is herebyadopted by the Director, Department of Consumer Affairs as his Decision in theabove-entitled matter. .
This Decision shall become effective (~\'J'L' h,;;,.cllitOe <
IT IS SO ORDERED ~i.,:::-tt'.,- ,\,:-,.- L:,-:-.~;CC 2,.
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Byrtrw ,,' /!r-l-bv--'DENISE BROWNChieE Deputy DirectorDepartment of Consumer Affairs
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DANIEL E. LUNGREN, Attorney GeneralWILLIAM L. MARCUS
Deputy Attorney GeneralState Bar ~o. 66706
300 S. Spring St., Suite 500Los Angeles eA 9001JTelephone: (213) 897-2535
5 Attorneys for complainant
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BEFORETHEBUREAUOF SECURITY AND INVESTIGATIVE SERVICES
DEPARTMENTOF CONSUMERAFFAIRSSTATE OF CALIFORNIA
9In the Mattet' of the Accusation ) CASe NO, III 96 9688
10 Against: )) ACCUSATION
1 1 JOHN GROGAN )I ' doa Gold Star Investigat10ns )
12 P.O. BOX 9065 )Canoga Park CA 91309 )
13 PI #15057 )
PPO 1110093 )
14 BAT (baton) ,1473426 )
FQ (firearm) 1/87293 )
15 )Respond en t . )
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COMPLAINANTALLEGESTHAT:
Program Manager of the Bureau of Security and Investigativer .
Se:-vices (hereinafter, "the Bureau" 1, and make s and files t.his
Accusation solely in her official capacity as such.
2. On or about February 19, 1988, John Leo Grogan dba
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She is Sherrie Moffet (here1natter, "Complainant"), I1 .1e
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private patrol operator license No. PPO 10093, which is currently•in full force and'effect; on or about July e, 1989, respondent,
doa proguard, was iSsued private patrol operator license No. PPO
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• •di~cipline pursuant to Business and Professions Code section
2 7561.1, for violation of section 7561.1 (b), taken in conjunction
3 with Business and Professions Code section 7539(a), and
4 7561.1(g), as follows:
5 A. In or abOut March 1996, M.P. retained respondent to
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6 perform an investigation of residential premises in Malibu,
7 California, which were jOintly owned by her and her estranged or
8 ex-husband, W.P. and to provide M.P. a written report of his
9 findings, including certain specified areas and assets. M.P.
10 paid respondent S1,OOO in advance.
B. The entry into the premises was to take place on
12 April 13, 1996. Respondent, despite- receiVing the $1,000,
13 Willfully failed and refused to make said investigation,
14 Willfully failed and refused to prepare a report for M.P., and
15 willfully failed and refused to refund all or part of the $1,000
16 received f=om M,P._
17 C. Respondent further, and without authorization from
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18 M.P. or anyone on her behalf, contacted w.P., the estranged or
19 ex-husband, about respondent's assignment from M.P., including
20 adviSing W.P. of th~ fact respondent had been retained by M.P ..
21 to conduct such an investigation of the Malibu premises.
6. Pursuant to Business and Professions Code section
23 125.3, the Bureau i~ authorized to seek and recover its costs of
24 investigation and enforcement of a case in the event that one or
25' more of the charges in an accusation are sustained following
26 hearing.
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• If • •1991, respondent, dba Gold Star Investlgations, was lssued
2 private investigator license No. PI 15057, which is currently In
3 full force and effect; on or about March 1, 1986, respondent was
4 issued baton permit No. BAT 473426, which is currently in full
5 force and effect; on or about May 29, 1985, respondent was issued
6 firearm permit NO. fQ 87293, which is currently in full force and
7 effect.
8 3. Pursuant to Bus~ness and PrOfesslons Code sectlon
9 7561,1, the Director of the Department of Consumer Affairs
10 (hereinafter, "the ui r ec tcr" 1 may discipline a license, LncLudi nq
11 a baton permit and a firearm qualification card, for violation of
12 any of the provisions of 7561.1, including, but not limited to:
13 violating any provlsion of Chapter 11.5 of Oivlslon 3 of the
14 Business and Professions Code (subsection (bll; willfully failing
15 or refusing to render to a client services or a report as agreed
Ie between the parties and for which compensation has been paid or
17 tendered in accordance with the agreement of the parties
18 ( subs ee ti on (g) 1 .
19 4. Pursuant to Business and Professions Code section
20 7539(al. a licensee or officer, director, partner, or manager of
21 a licensee may not divulge any information acquired by him 01: her
22 to any other person (e~cept persons not re~evant to this case),
23 except when at the dir"ection of the employer or client for whom
24 the information was obtained Or as required by law.
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5.. Raspondent's license as a private patrol operator
(PPO 10093) and private investigator (PI 15057) and his baton
permit (BAT 473426) and fire arm perm~t (FQ 67293) are subject to
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!JiI!i 7. The Bureau has incurred reasonaqle costs of
2 investigation and enforcement of this case 1n an amount to be
3 established according to proof at hearing.
4 WHEREFORE. Complainant prays that a hearing be held on
5 the matters alleged hereinabove and, following said hearing, a
6 decision issue:
7 1. Revoking or suspending private patrol operator
The 'cHawlng 15a ust of 'smoke andmirror' weosrtesthat aremaintained by John Grogan. Theirpurpose? To spread 11net acrossthe Internet In whld1 John snaresthe unsuspecting public Into hisweb of decelpt. Don't be fooled bywhat the sites say, All ROADSlEAD TO JOHN HIMSELFI You willnotice nearly all sites give you onlyone option and that 15to call oremail John at which time he WILL,In the words of one of John's oldacquaintances, attempt to "bafflt!you wfth his 'bulls_t and separateyou from your money ." There is nosubstance or truth In these sites. IfI have missed a Site, please tlIlAUIt to me for Induslon
After John's Private Investigator license was revoked in 2002, he proceededto declare himself a Polygraph Examiner, which he is not by any recognizedstandards of this profession. California, where John Grogan resides, does nothave licensing for Polygraph Examiners so there has been no legal recourseby which to regulate the fraud being perpetrated by John on the public inCalifornia and now across the nation.
The best place to start is to read the background articles detailing the proof ofthe truths just shared above. These articles appeared In The Relevant Issue, apolygraph related newsletter provided by polygraphplace.com.
This site's main goal is to inform so that people can make educated decisionson whether to do business with John Grogan, his Polygraph Examiners ofAmerica (peoa.us) or any of his state 'alliances'.
John has created an empire of one by setting up over 40 websltes thatappear legitimate, but with close observation, are revealed to all be smokeand mirrors. These websttes are designed to generate leads for John and ahandful of examiners (no more than 13 have we ever been able to find acrossthe nation) who have joined his association and/or alliances. We beueve thatseveral of these examiners don't yet know the entire story and are unwittingparticipants, while others, it seems clear have chosen to align themselveswith John even after kncwtnq the truth about him.
John has recently appeared on nationally syndicated television shows as a'polygraph examiner'. We believe the producers and examinees of theseshows had no idea who they had hIred and are victims themselves of hisfraud.
prO~ecting the Public and the Polygraph Profession from John Leo Grogan
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This webstte will be updated regularly as new Information comes to light.Thank you for your time.
Ralph HilliardThe Polygraph Placedeteetor«Ptruthaboutgrogan .ora770.794.1325
groganvsa.comvol<:epolygraph.com
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• •I:CASE NUMBERIBC 391778
oeCLARA nos OF MAILING
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I'. INStRUCTIONS: Only a person who is age 18 years or older and not a party to this action can serve document. .copies by mail. (Code Civ. Proc., § 1013a.) An unsigned copy of this Declaration of Mailing must be attached to, iand ~ailed with the copies. After the copies are deposited in the mail, the person who mailed them must fill out
and ~ign this form attached as the last page of the originals for filing. (Code Civ. Proc., § 1013(b).) WARNING:" 'Fa/S'{Ying this form can be a felony, punishable by imprisonment in state prison. (Pen. Code, §§ 118 & 126)
1. I am lmPloyed in, or a resident of, the county in which this mai;ing occurred, and not a party to this action. At the, time ~f mailing, I was at least 18 years of age or older;
2. I am ~eadily familiar with the practice at the residence or business address shown below for collection and processing OTtcorrespondence for mailing with the United States Postal Service, which causes it to be sealed and depositedwith srid Postal Service with the postage prepaid the same day it is mailed or placed for collection and processing.
3, My [] residence [Xl business address and telephone number are as follows:,ADDRESSi ITELEPHONE NUMBER
P.O. Box 433 310.294.3043I
CI11(.STA'.EE AND ZIP CODE
Torr~rce CA 90508-0433
4. I se~ed the below document(s) by [Xlpersonally sealing and mailing with postage prepaid, [Xl placing forcollebtion and mailing following ordinary business practices, true copies to the addressed as shown, on the date andat th~ place shown, in envelope(s) sealed, or to be sealed in the ordinary course of business, and addressed asfOliot S:
Geo'fge Bal taxe, Esq.158~1 Ventura Blvd. Ste 245Encino CA 91436,
1
Adrianos Facchetti, Esq.200iN Fairview StBur~ank CA 91505
DATEMAILEqJune 12, 2008
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PLACEOF MAILING(City and state)
Torrance, CA
5. Exa.cttitle(s) of document(s) served: Notice of Motion and Motion to Strike (S. 415.161
CCP) \
I declare under penalty of perjury, under the laws of the State of California, thDATED lYPE OR PRINT NAME OF PERSONWHO 010 MAILING Sl A