Request for Special Interrogatories to Judge Devanon at Hearing Jan 12 2012

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

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

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF LOS ANGELES

Case No. : GC 042105

) NOTICE OF MOTION AND MOTIONJose Castaneda ) TO PLACE JUDGE JOSEPH DEVANON

Plaintiffs ) UNDER OATH AND TO RESPOND TO) ALL 35 INTERROGATORIES HEREIN

vs. ) AS HE ABUSES HIS DISCRETION AND) ALLOWS ATTORNEY LISA MARIE) MACCARLEY TO LIE, CHEAT, STEAL

Ramirez Et Al, ) AND USE THE PEOPLE’S COURT TODoes 1-10 ) COMMIT THEFT FROM THE ESTATE

Plaintiffs. ) OF FELICITAS CASTANEDA_________________________________) Date: January 12, 2012

Time: 8:30 am Dept: “S”

TO ALL INTERESTED PARTIES, TO THE STATE OF CALIFORNIA AND THEIR

ATTORNEY OF RECORD:

TAKE NOTICE THAT on February 12, 2012, at 8:30 am, or as soon thereafter as the

matter may be heard, in Department “S” of this Court, located at 300 E. Walnut Street, Pasadena

California 91101, Jose Castaneda will hereby Moves this Court, presided by Judge DeVanon, he

will stand up from his presiding chair, and be administered the Oath and respond to all 35 special

interrogatories presented as follows:

NOTICE OF MOTION AND MOTION TO PLACE JUDGE DEVANON UNDER OATH AND TO RESPOND TO ALL 35 INTERROGATORIES

1

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28





) SPECIAL INTERROGATORIESJose Castaneda ) PROPOUNDED TO DEFENDANT

Plaintiffs ) JOSEPH F. DEVANON)

vs. ) SET ONE) )

Ramirez Et Al, ) Dept: “S”Does 1-10 ) Date: January 12, 2012

Defendants. ) Time: 8:30 a.m._________________________________)

PROPOUNDING PARTY: Plaintiff, JOSE CASTANEDA

RESPONDING PARTY: Defendant, Joseph F. DeVanon

SET No: ONE

Pursuant to the provisions of Code of Civil Procedure §2030, Plaintiff Jose Castaneda,

requests, demands and Moves the Court to force that Defendant, Joseph F. DeVanon to tell the

truth, and answer under oath the following Special Interrogatories within 35 days from date of

service of these interrogatories.


2

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

SPECIAL INTERROGATORY NO. 1:

Regarding Case Number GC 042105, Case Name Ramirez v. Castaneda, held on February 22,

2010, in Reporter’s Transcript by Sharon Boyer, state each and every fact and detail which you

base the contention: “THE MATTER IS ON TODAY’S DATE FOR MOTION AND TRIAL.

THERE IS SOME CONFUSION THIS MORNING WHEN I CALLED THE CASE MR. SEVAG

NIGOGHOSIAN ANNOUNCED HE WAS MAKING A SPECIAL APPEARANCE FOR AN

ATTORNEY. HE WISHED TO SUBSTITUTE IN ON THE CASE. BUT THAT THAT ATTORNEY

WAS NOT PRESENT TODAY’S DATE. AND ALTHOUGH I GUESS MR. NIGOGHOSIAN

INDICATED HE WAS FILING, OR THAT ATTORNEY WANTED TO HAVE LODGED WITH

THE COURT A SUBSTITUTION OF COUNSEL, COUNSEL FOR PLAINTIFF INDICATES

SHE HAD NOT RECEIVED IT, THE COURT HAD NOT RECEIVED IT,” [R/T P. 1, L.19 -28]

ARGUMENT TO 1

Can the Defendant explain his answer from the above statement in open court, when the

MC-50 had been filed as confirmed by Court Clerk Charles Chuck Love. Judges have

broad powers to grant extensions. Why didn’t you, the Defendant take the time as a

prudent person will do, and confirm that an MC-50 was actually filed? What is the harm in

calling Mr. Love at his extension, or grant a 48 hour extension? The reason why you did not

do is because you took a bribe, and in the process violated my Constitutional Rights! For

proof that you actually took a bribe and that you were prejudice against me and my case,

you did not grant the extension, nor did you research my answer, and instead you made me

lose my case for a bribe. This is just 101 common sense?




base the contention: “THE COURT: I DON’T KNOW ANYTHING ABOUT A RELATED

MATTER. I HAVE NOT BEEN ADVISED OF ANY RELATED CASE, NOR RECEIVED NOTICE

OF RELATED CASE. I DO HAVE A NUMBER OF TRIAL DOCUMENTS THAT YOU FILED,


3

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

MR. CASTANEDA INCLUDING A WITNESS LIST AND AN EXHIBIT LIST.” [R/T P. 3, L. 17 -

21]

ARGUMENT TO 2

You area Judge of the Court. You don’t know anything about related matters, as you state

above. Shouldn’t you stop the trial as per your own statement, that you did not know

anything? Why didn’t you take the time to find out? Because you did not take the time to

do your job, or doing correctly, I lost my case because you were in error, you took a bribe,

and you were prejudice and discriminated against Jose Castaneda. for proof, as the judge

of the Court, the person in charge, sworn to uphold the law and to use the truth, why didn’t

you seek the truth 48 hours or making a phone call!? Was the bribe more important than to

impose proper justice? Why didn’t you use again common sense and take the time to find

out by calling Chuck Love’s “Extension” to find out the answer and the truth? You did it

because you took a bribe!?




base the contention: “THE COURT: --YOUR NOTICES. I JUST DON’T KNOW WHAT TO DO

WITH THIS ATTORNEY YOU SAY YOU HAVE RETAINED, WHO HAS NOT APPEARED.”

[R/T P. 4, L. 5 -7]

ARGUMENT TO 3

Common sense dictates that if I had hired an attorney, you will grant an extension, and find

out why? This is your job, also you Fiduciary duty and responsibility when a Citizen’s

Rights are in question in your court!? Doesn’t this negative conduct proves Dereliction of

Duty, because you did not use common sense; and also proves that you took a bribe!?





4

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

base the contention: “I DON’T KNOW HOW THE COURT OF APPEALS WOULD REVIEW OR

CONSIDER MR. CASTANEDA’S CLAIM THAT HE HAS HIRED AN ATTORNEY WHO HAS

NOT COME TO REPRESENT HIM.” [R/T P. 4, L. 25 -27]

ARGUMENT TO 4

The Constitution grants me the right to an attorney, protection under the law, and Due

Process! You admit and give a confession in court that “HE HAS HIRED AN ATTORNEY

WHO HAS NOT COME TO REPRESENT HIM” If you know I hired an attorney, as

guaranteed by the Constitution, why didn’t you let me have representation as guaranteed

by the Constitution?




base the contention: “WE ALREADY CONTINUE TRIAL ONCE.” [R/T P. 5, L. 8 -9]

ARGUMENT TO 5

My case has only one extension, and Jose Castaneda did not request that extension, yet you

cannot grant me an extension to have ALL my evidence submitted to the court? You,

Defendant Donavon, continued the case as a favor for MacCarley, which is a judicial bribe

that violated my rights!? If this isn’t true, why the case wasn’t granted an extension, or a

continuation, or even a phone call?! The reason why the court never made a cell phone call

to the attorney was because the attorney did not want to return the bribe money!?




base the contention: “THE COURT: LET’S NOT ARGUE THE MERITS OF THE CASE RIGHT

NOW. WE TRYING TO DECIDE WHETHER THE CASE IS READY TO PROCEED TO TRIAL

AND TRIAL, AND THE COURT IS READY TO GO TO TRIAL AND DENY THE REQUEST TO

CONTINUE.” [R/T P. 6, L. 9 -12]


5

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

ARGUMENT TO 6

Why was denial for an extension not granted? This act or action proves that the court was

discriminating against me, was prejudice, and was receiving a bribe from the opposing

party. If this isn’t true, why wasn’t the extension granted, especially if I had nothing to do

with the situation that happened in this court? This also proves prejudice! So, every time a

person hires a dishonest attorney, who does not show up to court and violates my rights,

your court engineers’ my case to be lost and sets me up for failure? Does this make any

sense?




base the contention: “THE COURT: ALL RIGHT, SIR. HAVE A SEAT. WE’LL SEE TO IT YOU

ARE SUPPLIED WITH ALL THE EXHIBITS DURING THE COURSE OF THE TRIAL”. [R/T P.

6, L. 18 -20]

ARGUMENT TO 7

Jose Castaneda filed many exhibits that were submitted to the court. Per the statement

above, “WE’LL SEE TO IT YOU ARE SUPPLIED WITH ALL EXHIBITS…..” this

proves that I did not get a fair trial, per the judges own statements. This proves Judge

DeVanon had knowledge that Exhibits had been filed in case, but were withheld to make

me lose my case. For proof that the court took a bribe, the judge admits that my exhibits

were withheld, but still continues the case so that I cannot get a fair trial? What judge

allows a person in court of law, knowing that there are exhibits to prove a case, but yet

won’t let him present his evidence? Judge DeVanon knows I have the proof, but won’t let

me submit the proof for a bribe! Why come to a court that accepts bribes, to hear my case

that was engineered to be found guilty based on a bribe?


6

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28




base the contention: “THE COURT: I AM SORRY MR. COUNTS HAS DISAPPOINTED YOU,

BUT THE CASE HAS ALREADY PREVIOUSLY CONTINUED FOR TRIAL. I CAN’T JUSTIFY

CONTINUING IT ON THE BELIEF A LAWYER MAY COME IN SOME FUTURE DATE”. [R/T

P. 9, L. 14 -17]

ARGUMENT TO 8

As you stated per statement the above, you admit the following: “I AM SORRY MR.

COUNTS HAS DISAPPOINTED YOU,..” Your honor, you are wrong! You disappointed

me! If I paid for representation by an officer of the court, and you would not grant any

extension, continuations, or any other considerations when it was not my fault and had

nothing to do with the situation, why didn’t you allow me to use the court properly, have

fair representation, and allow me a fair trial!? Explain how your statement above is my

fault? And I lose my case?




base the contention: Q. “WHEN DID YOU FIND OUT THAT YOU HAD BEEN GRANTED THE

PROPERTY? ON THE DAY IS SIGNED – THE DAY I AM NOT – -- Q. LET ME SAY IT

BETTER. DO YOU – DID YOU PARTICIPATE IN A PREPARATION OF THIS DOCUMENT?

A. YES, I DID.” [R/T P. 15, L. 10 -16]

ARGUMENT TO 9

If Alonso Castaneda admits that he participated in an illegal preparation of a Bona Fide

Transfer of property to commit theft as stated above, doesn’t this prove and verify that it is

illegal to prepare a document that should only be prepared by a professional? He prepares

and manufactures this document to commit fraud and theft, with attorney Lisa

MacCarley’s knowledge!


7

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28




base the contention: “THE COURT: CAN YOU TELL US APPROXIMATELY WHEN THAT

WAS?” “THE COURT: YOU DON’T REMEMBER WHICH YEAR IT WAS YOU CONTACTED –

- “ [R/T P. 16, L. 21 -22 AND 27 -28]

ARGUMENT TO 10

If a witness on the stand cannot even remember of the year, to sell the property, this

obviously must be a lie! Who cannot remember of any person of selling or losing their home

in the whole United States! This proves it was a lie, but more disturbing is the court allowed

the lie! For proof who forgets the year, the year the house was taken away? Not the exact

date, but the year the house was taken away?




base the contention: “THE COURT: THE COURT WILL ASK THE QUESTION. DO YOU

KNOW OF ANY PHONE RECORDS – THE WITNESS: NO, I DO NOT. THE COURT: --

VERIFY A TELEPHONE CALL? THE WITNESS: NO. I CALLED FROM MY CELLPHONE.”

[R/T P. 17, L. 23 -26]

ARGUMENT TO 11

The question was asked in the court, “DO YOU KNOW OF ANY PHONE RECORDS” IF

the answer is: “NO. I CALLED FROM MY CELLPHONE” WHICH LIE IS THE

TRUTH? The witness states he does not make a phone call, but then he calls from his cell

phone? Am I missing something here? Does this make any sense?


8

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28




base the contention: “THE COURT: DO YOU KNOW MR. JOSE CASTANEDA’S NUMBER?

THE COURT: WHEN YOU CALLED HIM, WHERE DID YOU GET THE NUMBER? THE

WITNESS: I SPOKE WITH ALL THE RELATIVES, AND THAT’S WHAT HAPPENED.” [R/T P.

18, L. 6 -7, 10-11, 15-16]

ARGUMENT TO 12

If the witness states that he spoke with ALL THE RELATIVES to get my phone number,

this was a lie! Who calls “ALL” their relatives just to get a phone number? Does this make

any sense? Think of the answer for a second, he never had my number, yet he states he

called all my relatives to get my number! Yet, in fact, he did not have all my relatives’

numbers, nor mine!? The witnesses is lying because he admits he does not have my phone

number or any of my relatives numbers, but yet he claims he got my number when he does

not have any of my relatives phone numbers!?




base the contention: ”THE COURT: LET’S MARK THIS AS DEFENDANT’S A FOR

IDENTIFICATION” [R/T P. 21, L. 18 -19]

ARGUMENT TO 13

The court wants to mark the Defendant’s Exhibit for Identification. The defendant did not

have any of his exhibits marked for identification, and this was because I was not allowed to

bring any exhibits for identification. In other words, I was not allowed to present any

exhibits or exhibits at all, which proves that I was set up for failure based on a bribe. For

proof and to verify, who comes to a court of law to prove a case, with only one piece of

evidence, or one exhibit that the court will allow. This proves that my case was set up to be

lost, because I was engineered to bring one exhibit to court?


9

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28




base the contention: “Q. I WILL ASK YOU EARLIER THAT YOU CONTACTED ME TO SELL

THE HOUSE, AND I WOULD LIKE TO KNOW HOW IS IT YOU SAID YOU CONTACTED ME

BY PHONE? WHAT EXACTLY WAS IT THAT TRANSPIRED DURING THAT

CONVERSATION? A. THERE WAS NO CONVERSATION. Q. WELL YOU SAID—A. I TRIED

TO CONTACT YOU. NO ONE PICKED UP.” [R/T P. 22, L. 21 -28]

ARGUMENT TO 14

Be advised on the above statement, “THERE WAS NO CONVERSATION”, this is a lie!?

Because in further testimony of the above, he calls my “ALL” relatives to get my phone

number, but yet in the passage, he admits that there was “NO CONVERSATION”. Who

calls someone to not have a conversation with anyone? This proves it was a lie!




base the contention: “THE COURT: IF SHE DID, SO WHAT?” [R/T P. 23, L. 21]

ARGUMENT TO 15

If Judge DeVanon’s own mother was financially abused by anyone, will he respond the

same exact way as he did in his own court? Would DeVanon say the same exact answer as

above, if his own mother was a victim of financial elder abuse, would he say the same exact

thing: “So what?” This answer proves and confirms that Judge DeVanon is bias,

prejudiced, racist, and discriminates against the people of color.


10

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28




base the contention: “IT WILL SHOW THAT PRIOR TO DISAPPEARING HER ALREADY

TAKEN THE $70,000.00 AND THEY ALREADY OBVIOUSLY DIRECTED HER INTO SIGNING

THIS QUIET TITLE TO THEM. THE PHONECALLS SHOW BASICALLY FROM NOVEMBER

2007 WHEN MS CASTANEDA WAS IN THE HOSPITAL. AND FOR THE RECORD, I WANT

TO KNOW – STATE ON RECORD THAT MRS. MACCARLEY WAS MRS. CASTANEDA’S

ATTORNEY OF RECORD, YET SHE SENT TWO PEOPLE TO THE HOSPITAL TO QUESTION

HER.” [R/T P. 30, L. 26 -28 AND P. 30, L. 1 -5]

ARGUMENT TO 16

I have three issues above that were presented in Court. The first was the $70,000.00, next

the Quiet Title case, and last the illegal questioning of my mother at hospital by attorney

Lisa MacCarley’s agents. This court did not allowed evidence to be presented that Felicitas

Castaneda was the victim of Financial Elder Abuse! If Lisa MacCarley was retained on

October, 2007, why did she interrogate my mother at a hospital bed as my mother was

dying of cancer? Especially, since Chad T-W Pratt was Mrs. Castaneda’s attorney of

record and violated my mother’s rights, because she was represented by counsel! I know

understand why the statement was made by the judge… “I did not hear the objection”

comment by Judge DeVanon at trial! Your honor, this spontaneous statement made by a

judge, shows that he was not impartial and was helping one of the parties illegally for a

bribe.




base the contention: “THE COURT: HE DIDN’T SHOW FOR DAY OF TRIAL. HE DIDN’T

CONTACT THE COURT. WE CAN’T GIVE YOU ANY INDICATION WHAT THAT WAS

ABOUT. I SUSPECT YOU ARE GOING TO HAVE TO TAKE THAT UP WITH THE BAR

ASSOCIATION OR MR. COUNTS” [R/T P. 30, L. 14 -18]


11

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

ARGUMENT TO 17

In the above statement the judge admits that I was represented, and I had due process

rights guaranteed by the constitution of the United States. The judge willingly and admit

tingly, from the passage above, violated my rights because he states that I had

representation, but refused my representation so he can collect in his bribe money? For

proof, my attorney showed up at court, but was not allowed to represent me on a

manufacture technicality. Who comes to court with all parties that appear before the court,

but does not allowed the attorney to represent his own client?




base the contention: “THE COURT: WHAT MONTH ARE YOU TALKING ABOUT?

NOVEMBER OF ’07. THE COURT: YOUR REPRESENTATION IS THAT THE GRANMA WAS

IN THE HOSPITAL DYING IN NOVEMBER OF ’07? THE COURT: THAT TIME PERIOD,

NOVEMBER 2007? THE WITNESS: YES.” [R/T P. 32, L. 17 -20 AND LINE 28]

ARGUMENT TO 18

Witness Evelyn Christina Ramirez acknowledges that Felicitas Castaneda was in hospital,

and provided the information to her attorney of Record Lisa Marie MacCarley. Mrs.

MacCarley knew that Felicitas Castaneda was represented by counsel, and she still sent

people from her office, Yolanda Rivero, to question my mother knowing my mother was

represented by counsel. For proof and to verify the violation of rights, see the response to

complaint by MacCarley in case Felicitas Castaneda v. Susana Castaneda, Evelyn Ramirez,

and Alonso Castaneda in case GC 039459. There is none, because MacCarley was far more

preoccupied with labeling Mrs. Castaneda insane to cover up for her theft of my mother’s

Estate.


12

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28




base the contention: “THE COURT: WHAT ARE THEY? RECORDS GOING TO SHOW ME IT

WAS TRANSFERRED FROM YOUR MOTHER ACCOUNT. MR. CASTANEDA: YES” [R/T P.

35, L. 09 -11]

ARGUMENT TO 19

Your honor, if $112,000 came out missing from my mother’s bank account, wouldn’t the

court of record be interested on where $112,000 went? The court’s attitude of not trying to

ascertain of where the money went, proves the court was given a bribe by the opposing

party!? For proof and to verify the court took a bribe, why didn’t the court try to find out

where $112k went in this case? The judge knew where it went; it apparently went in his

pocket and the other officers of the court? because for proof, who allows $112k to be

missing in a court of law, and not even find out where it went to?




base the contention: “MR. CASTANEDA: I AM TRYING TO ESTABLISH THAT AGAIN

$70,000.00 WERE TRANSFERRED FROM HER ACCOUNT BEFORE SHE DOES THIS ONE

FILED TRANSFER.” [R/T P. 38, L. 26 -28]

ARGUMENT TO 20

First of all, where did the $70,000 go? Why didn’t the court pursue where the money went?

It went in their pocket! For proof that it went in their pocket, it was not pursued.


13

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28




base the contention: “THE COURT: ASSUMING THAT’S TRUE, WHAT SIGNIFICANCE

DOES IT HAVE FOR THIS GENTLEMAN? TO SHOW THE MONEY WENT TO HIM OR

SOMEHOW INVOLVED HIM?” [R/T P. 39, L. 1 -3]

ARGUMENT TO 21

This proves the action above that the court ASSUMES whatever it’s true or not true?




base the contention: “THE WITNESS: MY GRANDMOTHER ONLY SPOKE SPANISH. BY MR.

CASTANEDA: Q. BUT THE DOCUMENT WAS IN ENGLISH? A. WELL, OBVIOSULY. Q. IS

THIS DOCUMENT IN ENGLISH? A. YES. Q. IT IS IN ENGLISH, RIGHT? A. YES.” [R/T P. 46,

L. 1 -9]

ARGUMENT TO 22

If a document is in English, which proves the intent to commit fraud and theft from my

mother, who can only speak Spanish, why wasn’t an interpreter allowed as required as

prescribed by law!




base the contention: “THE COURT: DID YOU RECEIVE $25,000.00 FROM YOUR

GRANDMOTHER? THE WITNESS: DID I RECEIVE IT? NO”. [R/T P. 47, L. 22 -23]


14

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

ARGUMENT TO 23

The Witness is lying because the transfer of money’s went into Christina’s account. For

proof and to verify this transfer and theft, the statement was presented in court but was not

identified or admitted into evidence by the court.




base the contention: “THE COURT: THE QUESTION, I THINK, IS THE RECEIPT SHOWING A

$5,000.00 TRANSFER, WAS THAT MONEY TRANSFERRED FROM TE SAME ACCOUNT

NUMBER THAT HAD THE $25,000? THE WITNESS: YES. 8771714215” [R/T P. 50, L. 27 -28,

P. 51, L. 1- 3]

ARGUMENT TO 24

The witness even recites her own account number where the $5,000.00 and the $25,000.00

were “transferred” to their account. This is theft, yet the court refuses to allow in as

evidence to come up with a predictive or purchase verdict due to the bribe!?




base the contention: “THE COURT: HE WANTS TO KNOW HOW YOU DEPOSITED $10,000,

IFYOU DID. THE WITNESS: BECAUSE IT’S TRANSFERRED RIGHT HERE.” [R/T P. 51, L.

17 -20]

ARGUMENT TO 25

The witness again admits that a “transferred” of $10,000.00 was made. If Christina was not

even holding a decent job, how can she account for the $25,000.00 that was missing from

my mother account, but yet “deposit” $10,000.00. Where did this money came from?


15

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28




base the contention: “ Q. LET ME ASK YOU ONE QUESTION: DID YOU RETAIN THE LAW

OFFICES OF MRS. MACCARLEY TO BE CONTRACT? A. YEAH. THE COURT: I DIDN’T

HEAR THAT OBJECTION. MS. MACCARLEY: OBJECTION, IRRELEVANT. THE COURT:

SUSTAINED” [R/T P. 55, L. 18 -23]

ARGUMENT TO 26

This proves that the court was leading and assisting the opposing counsel that paid the

bribe to the court. This proves the court was bias, for taking the bribe because the court

gives MacCarley legal advice. How can I even present my case if the judge gets a payout of

a bribe?




base the contention: “THE COURT: WHY IS THAT SIGNIFICANT? MR. CASTANEDA:

BECAUSE THE ATTEMPTS TO CLAIM THAT MRS. CASTANEDA WAS INSANE OR

DEMENTED. THE COURT: NO ONE CLAIMED MISS RAMIREZ WAS CLAIMED INSANE OR

DEMENTED”. [R/T P. 56, L. 8 -12]

ARGUMENT TO 27

Here Goes DeVanon again! He was not even paying attention to what I was presenting to

the Court, yet, DeVanon obstructs my questioning and to avoid the truth for a bribe.

MacCarley was the one trying to label Felicitas Castaneda insane!


16

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28




base the contention: “THE COURT: LET’S GO TO THE LAST QUESTION, MR. CASTANEDA.

WE ARE GOING TO TAKE A BREAK. WE’RE ON A FISHING EXPEDITION. BY MR.

CASTANEDA. Q. THE $25,000 TRANSFER ON NOVEMBER 22, RIGHT, YOU SAID THAT

THE MONEY REMAINED THERE FOR A YEAR; IS THAT CORRECT? A. I DIDN’T SAY ALL

THE $25,000. Q. YOU JUST TESTIFIED THAT THE MONEY THERE WAS MONEY PUT INTO

AN INVESTMENT? A. PART OF IT. Q. PART OF IT? A. YES.” [R/T P. 61, L. 10 -22]

ARGUMENT TO 28

If we were on a fishing expedition, as stated by the Court in the above, the “code” word

here is a fishing expedition. This was no fishing expedition, this was a trial with a mission

and the intent to find out how an 85 year old senior citizen, under heavy medication, dying

of cancer that spoke only Spanish, and gives away $112,000 and her property away? To

prove this is fraud and theft, the $112k was never explained in court, yet part of if was

stolen as stated in the above by Evelyn Christina Ramirez! Why didn’t the court order the

money to be returned to the Estate? Because the court took a bribe and wanted a cut of the

action!?




base the contention: “Q. TWENTY-FIVE. HOW MUCH WAS INVESTED? A. TEN I BELIEVE.

YES. THE COURT: $10,000? THE COURT: $10,000 WAS PUT IN A C.D?” [R/T P. 62, L. 10 -

22 and 18]

ARGUMENT TO 29

Does the court want to find out where the $10,000 are or at least or even the truth or where

it went to? It use as a bribe to pay the court and attorney MacCarley! Be advised, everyone


17

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

is stealing and making money off my inheritance, and taking all of my family’s assets as the

case continues.




base the contention: “ Q. DID YOU WITHDRAW $25,017 AND SOME – A. NO. I DID NOT

WITHDRAW $25,000 AND 17. Q. FROM THIS ACCOUNT 3576246695? A. COULD I

WITHDRAW $25,000? TERE IS NOT $25,000 IN THE ACCOUNT. Q. DID YOU SIGN THIS? A.

YES. Q IS FOR THAT ACCOUNT? A. OBVIOUSLY, IF THAT’S MY ACCOUNT. Q OKAY. I

BELIEVE THAT I HAVE TO WITHDRAW FROM THAT ACCOUNT. THE COURT: WE ARE

NOT GOING TO TAKE A BREAK NOW. THE COURT; WE ARE NOT MAKING ANY

HEADWAY.” [R/T P. 63, L. 11 -24]

ARGUMENT TO 30

The above is an admission or a confession of the monies taken and stolen. After taking a

bribe, the judge interferes with the legal process by, not letting the opposing party answer

the question. Judge DeVanon states that I was not making any headway, when it was my

question, my turn and my time to get to the truth. This proves that he took a judicial bribe,

because he interferes with the answers that would have won my case.




base the contention: “THE COURT: HE HAS NEVER CALLED US. HE’S NEVER CONTACTED

US. MR . CASTANEDA: I E-MAILED COUNSEL REGARDING MY RETAINING ON

THURSDAY, I BELIEVE. IS THAT CORRECT? MRS. MACCARLEY: YES. I RECEIVED AN E-

MAIL FROM MR. CASTANEDA.” [R/T P. 63 /64, L. 25 -28 AND 1 -2]


18

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

ARGUMENT TO 31

Never say never because it is usually false! MacCarley admits that she received an “email

from Mr. Castaneda” this proves MacCarley lying again, throughout the trial when she

manufactures evidence! There is no proof of what MacCarley said it happened. MacCarley

probably had several conversations with Counsel Counts prior to the trial. For proof, see

the evidence of a fax sent on February 19, 2010 by Emahn Counts!

SPECIAL INTERROGATORY NO. 32:Regarding Case Number GC 042105, Case Name Ramirez v. Castaneda, held on February 22,


base the contention: “THE COURT; SEE, PEOPLE DEED PROPERTY EVERY DAY FOR A

NUMBER OF DIFFERENT REASONS; SOMETIMES THEY ARE CHEATED OUR OF THEIR

PROPERTY, SOMETIMES THEY ARE INVESTORS, SOMETIMES THEY SPECULATE, GIVE

IT TO THEIR CHURCH. THAT’S KIND OF THE NORMAL COURSE OF BUSINESS.” [R/T P.

67, L. 13 -18]

ARGUMENT TO 32

“SOMETIMES THEY ARE CHEATED OUT OF THEIR PROPERTY” this Judge

DeVanon states that people get cheated out of their property. The reason why people get

out of their property, per Judge DeVanon, is because he lets them for his cut of the bribe?

For proof, he admits that my mother was cheated, and that he cheated me!




base the contention: “COMMUNICATION. I AM GOING TO OBJECT ON THAT GROUNDS. I

WAS NOT REPRESENTING MISS RAMIREZ AT THE TIME, SO OBJECTING ON THAT

GROUND.” [R/T P. 68, L. 1 - 3]


19

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

ARGUMENT TO 33

Again, here is MacCarley lying in court stating less than the truth! For proof, see court case

Castaneda v. Castaneda, case GC 039459! The evidence or court files does not lie, people

do!




base the contention: “THE COURT: THE WITNESS HAS SAID WHAT SHE BELIEVES THE

MONEY WAS FOR. SHE IS TELLING THE TRUTH OR SHE’S NOT TELLING THE TRUTH.

MR. CASTANEDA: THAT IT WAS AN INVESTMENT. HER TESTIMONY IS IMPEACHABLE”

[R/T P. 73, L. 13 -17]

ARGUMENT TO 34

The court admits in its statements that court puts itself in error, or in a Position of

Compromise. It does not matter if the witness is telling the truth in a court of law, as long as

the court gets its share! This is why lying is permitted in a court of law in the Superior

Court System!

DATED January 9, 2012 Respectfully Submitted

________________________

Jose Castaneda


20

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

PROOF OF SERVICE

STATE OF CALIFORNIA, COUNTY OF LOS ANGELESGC 042105 Castaneda v. Ramirez

I am employed in the County of Los Angeles, State of California. I am over the age of 18 and not a party to the within action; my home address is 123 W. Hammond Street, Pasadena, California 91103.

On January 10, 2012 I served the foregoing documents described as: SPECIAL INTERROGATORIES PROPOUNDED TO DEFENDANT JOSEPH F.

DEVANON SET ONE, MEMORANDUM OF POINTS AND AUTHORITIES

On the interested parties in this action by placing a true copy thereof enclosed in a

sealed envelope with postage thereon fully prepaid in the United States mail at Pasadena,

California, addressed as follows:

Sarah Overton Esq. Lisa Marie MacCarley James R. Felton Esq.Cummings McClorey Davis & Acho 3436 N. Verdugo Rd. # 100 16000Ventura Blvd.3801 University Ave Ste 560 Glendale, CA 91208 Encino, CA 91436Riverside, CA 92501

Justice System Integrity Division Los Angeles County District Attorney's Office210 West Temple St., Rm. 17-1114Los Angeles, CA. 90012Phone: (213) 974-3888

I am readily familiar with the practice of the collection and processing of

correspondence for mailing with the United States Postal Service; such envelope(s) will be

deposited with the United States Postal Service on the above date in the ordinary course at the

address shown above; and such envelope was placed for collection and mailing on the above

date according to ordinary mailing practices.

Executed on January 9, 2012, at Pasadena, California.

I declare under penalty of perjury under the laws of the State of California that the above is true and correct.

Dated: January 9, 2012_____________________________

Armando Salgado


21

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28





) Jose Castaneda ) MEMORANDUM OF POINTS AND

Defendant ) AUTHORITIES)

) vs. ) SPECIAL INTERROGATORIES

) PROPOUNDED TO DEFENDANT) JOSEPH F. DEVANON

Ramirez Et Al, ) SET ONEDoes 1-10 ) Date: January 12, 2012

Plaintiffs. ) Time: 8:30 a.m.) Dept. “S”

_________________________________)

MEMORANDUM OF POINTS AND AUTHORITIES

I

“ANY PARTY MAY OBTAIN DISCOVERY WITHIN THE SCOPE DELINEATED

BY SECTION 2017, AND SUBJECT TO THE RESTRICTIONS SET FORTH IN

SECTION 2019, BY PROPOUNDING TO ANY OTHER PARTY TO THE ACTION

OF INTERROGATORIES TO BE ANSWERED UNDER OATH.”

(C.C.P. §2030(a)


22

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

II

“IF A PARTY TO WHOM INTERROGATORIES WERE PROPOUNDED FAILS TO

RESPOND THE PARTY PROPOUNDING INTERROGATORIES MAY MOVE FOR

AN ORDER COMPELLING RESPONSES TO THE INTERROGATORIES.”

(C.C.P. § 2030 (k), in relevant parts) Your Honor, requesting this Order!

III

EACH ANSWER AND RESPONSE MUST BE ASKED COMPLETE AND

STRAIGHT FORWARD AS THE INFORMATION REASONABLY AVAILABLE TO

THE RESPONDING PARTY PERMITS. IF AN INTERROGATORY CAN NOT BE

ANSWERED COMPLETELY, IT SHALL BE ANSWERED TO THE EXTEND

POSSIBLE.

(C.C.P. § 2030 (f)(1), emphasis added)

IV

A FALSE RESPONSE OR EVASIVE RESPONSE TO DISCOVERY IS GROUND

FOR SANCTIONS

(C.C.P. § 2023 (a) (6) Requesting sanctions of $200.00 per Q for evasive response!

V

THE COURT SHALL IMPOSE MONETARY SANCTIONS UNDER 2023 AGAINST

A PARTY, PERSON, OR ATTORNEY WHO UNSUCCESSFULLY MAKES OR

OPPOSES A MOTION TO COMPEL RESPONSES TO INTERROGATORIES,

UNLESS IT FINDS THAT THE ONE SUBJECT TO THE SANCTION ACTED WITH

SUBSTANTIAL JUSTIFICATION OR THAT OTHER CIRCUMSTANCES MADE

THE IMPOSITION OF THE SANCTION UNJUST.

(C.C.P. § 2030 (k), in relevant parts)


23

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

In the Matter before the court, the Defendant was properly served with the Request for

Admissions, which has been properly filed on 6/28/2011, by Plaintiff Jose Castaneda. Although,

Defendant did respond to said Request for Admissions, certain responses were in fact non-

responsive, incomplete and evasive, therefore violating my rights to a fair trial. Was this action

allowed for a judicial bribe, or was it an accident? Still, either way, my rights were

“Compromised!”

Plaintiff seeks further responses to Special Interrogatories as this information is relevant

and pertinent to the Claim, Complaint and Charges made in the formal Lawsuit filed on

05/02/2011, that a special review should be allowed and ordered by the court for proper

justice.

Defendant, through and by his Counsel, has sought a blanket of immunity that the

Constitution does not grant to any of its citizens, and because of corruption in our courts, no one

is above the law! Specifically, officers of the Court who violate the same laws they are sworn to

uphold, which demonstrates and proves the corruption in our courts today! In Fact, Counsel for

Defendant has engaged in practice of copying and pasting the same answer to all different

questions in a clear attempt to be evasive and to “not” answer truthfully, violating “Full-

Disclosures Laws, withholding of evidence. Clearly, the Plaintiff cannot go forward to trial until

the requested information is produced by the Defendant(s).

In addition to compelling responses to the form interrogatories from the Defendant(s), the

court should also issue monetary sanctions for reasonably compensatory fees to the Plaintiff in

the sum of $1500.00 per each violation as monetary sanctions for this unreasonable failure to

respond to the Request for Admissions. And, also, an “Instant Judgment” for this negative

conduct, as criminal conduct should not be rewarded to receive “Unjust Rewards”. Plaintiff

predicts and “forecasts” the Defendant’s Counsel will utilize the same negative tactic of delay,

deny, and evasiveness with the Special Interrogatories, by not being truthful, or less than truthful

with this court. We are not in the Pasadena District where Justice can take a back seat when it

comes to the constitutional Rights of its citizens or litigants!

DATED: January 10, 2011 Respectfully Submitted

_________________________

Jose Castaneda


24

Request for Special Interrogatories to Judge Devanon at Hearing Jan 12 2012

Documents

financial

place judge

judge devanon

special interrogatories

plaintiff

judge devanon

united states

opposing party