AJ Weberman pro se
 1   318 3rd Avenue #520
     New York 10010
     Gary Kurtz pro per
 3   20335 Ventura Blvd
6. Plaintiff worked in the office of California Attorney General Evelle Younger, where he
     learned the value of int...
in Ethnoarchaeology 49, 54 (R. Gould ed. 1978)); Weberman, The Art of Garbage
     Analysis: You Are What You Throw Awa...
judgments filed pursuant to the Acts are enforceable in the same manner as judgments
     in the court where filed.
tangible asset. Plaintiff’s December 28, 2006 Declaration revealed this wherein he
     labored under the misapprehensi...
At this August 22, 2007 hearing the receiver was asked if all the URLs had been turned
     over to him. When he answer...
summary judgment hearing Defendant called Judge Kaddo’s clerk and was told that the
     motion was never received and ...
month in Orange County Superior Court. Nora, who is living with
     Kaddo's daughter, Nadia Yammine, is asking the cou...
threatening to give a police officer "a .38-[caliber] vasectomy" after he
             cited the judge for excessive us...
Kaddo: "Mr. Nora." DA Herzog: "Is there anything else that it could have meant?" Judge
     James Kaddo: "That's what I...
―James Kaddo is a Maronite Christian and chairman of the Los Angeles-based United
     American-Lebanese Committee. Alt...



 5   In 1987 Immigra...
Americans of Arab descent. However Senator James Abourezk is himself a terrorist
     sympathizer – he was willing to t...
a defendant has appeared. This is a reasonable rule because it may be necessary to
     conduct discovery to develop th...
                                        Dated this January 7, 2010

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Kurtz v. Weberman Libel Suit


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Motion in libel suit requesting that proceedings be moved to New York City where defendant resides.

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Kurtz v. Weberman Libel Suit

  1. 1. AJ Weberman pro se 1 318 3rd Avenue #520 New York 10010 2 Gary Kurtz pro per 3 20335 Ventura Blvd Suite 200 4 Woodland Hills, Calif. 5 6 Superior Court of California State of California 7 County of Los Angeles 8 ) CASE NO.: LC084486 9 Gary Kurtz, ) ) MOTION TO VACATE THE 10 Plaintiff, ) DEFAULT JUDGMENT ) vs. ) ON THE GROUNDS OF 11 ) FORUM NON CONVENIENS 12 A. J. Weberman, ) CODE OF CIVIL PROCEDURE ) SECTION 418.10 13 Defendant ) 14 15 1. Defendant is not financially able to afford to hire an attorney in California but 16 Defendant has an attorney from the Jewish Defense Organization who is willing to take the case pro bono. His name is Michael Drobinaire and he is a member of the New York 17 Bar Association. 18 2. Defendant cannot afford to travel to Los Angeles, rent a hotel, and have a taxi 19 transport Defendant to the Courthouse as Defendant does not drive. 20 3. Defendant would miss work as Defendant is employed by the Jewish Defense Organization. ATTACHMENT A is an example of the work that the Jewish Defense 21 Organization does. 22 4. Defendant has been granted a fee waiver by Judges Michael Harwin and Lisa Hart 23 Cole. ATTACHMENT B and ATTACHMENT C are copies of these fee waivers. If Defendant cannot afford filing fees how can Defendant afford to retain an attorney in 24 California? Is justice a commodity that is sold to the highest bidder? There is no court 25 appointed attorneys in a Civil Case. 26 5. The Plaintiff would have an unfair financial advantage as he is an attorney representing himself. Additionally to enforce the judgment after a sister state judgment 27 in New York would only result in Kurtz having to travel to New York to do so. 28 [Summary of pleading] - 1
  2. 2. 6. Plaintiff worked in the office of California Attorney General Evelle Younger, where he 1 learned the value of intimidating journalists who investigate him. Chief Deputy Attorney 2 General Charles A. O’Brien charged that District Attorney Evelle Younger consistently attempted to intimidate the news media when they investigated him: ―The District 3 Attorney of Los Angeles County has attempted to intimidate the news media on every occasion in which they have seriously questioned the activities of his office,‖ O’Brien 4 stated. Kurtz has practiced law in the Los Angeles vicinity for at least 30 years after 5 leaving the California State’s Attorney General’s office. He has appeared before many of the judges who will rule on my motions and has an unfair advantage because of this 6 and because Defendant is located in New York City and has not been to California 7 since 1975. 8 7. The website in question concerns judicial corruption in the Los Angeles Superior Court. It alleges that Gary Kurtz conspired with corrupt judges to fix cases involving 9 violations in Nursing Homes. Recently ABC News has exposed the fact that three 10 nursing home patients have been killed by chemical restraints.1 and it alleges that Gary Kurtz raped one of his clients when she was mentally ill. The members of the Los 11 Angeles Superior Court would be in effect investigating themselves, as Kurtz is an officer of that Court. 12 13 8. Defendant is internationally known as someone who stalks celebrities by going through their garbage. Los Angeles or Van Nys is ten miles from Hollywood so it is the 14 wrong forum for this action due to the presence of the entertainment industry’s superstars. Defendant is cited in a United States Supreme Court decision in regard to 15 the legality of searching through someone’s trash. 16 CALIFORNIA v. GREENWOOD, 486 U.S. 35 (1988) 17 486 U.S. 35 CALIFORNIA v. GREENWOOD ET AL. 18 CERTIORARI TO THE COURT OF APPEAL OF CALIFORNIA, FOURTH APPELLATE 19 DISTRICT 20 No. 86-684. 21 Argued January 11, 1988 22 Decided May 16, 1988 ―A trash bag, like any of the above-mentioned containers, "is a common repository for 23 one's personal effects" and, even more than many of them, is "therefore . . . inevitably 24 associated with the expectation of privacy." Sanders, supra, at 762 (citing Chadwick, supra, at 13). "[A]lmost every human activity ultimately manifests itself in waste products 25 . . . ." Smith v. State, 510 P.2d 793, 798 (Alaska), cert. denied, 414 U.S. 1086 (1973). See California v. Rooney, 483 U.S. 307, 320 -321, n. 3 (1987) (WHITE, J., dissenting) 26 (renowned archaeologist Emil Haury once said, "[i]f you want to know what is really 27 going on in a community, look at its garbage") (quoted by W. Rathje, Archaeological Ethnography…Because Sometimes It Is Better to Give Than to Receive, in Explorations 28 1. http://abcnews.go.com/WN/abc-world-news-deadly-chemical-restraints-kill-california/story?id=9483981 [Summary of pleading] - 2
  3. 3. in Ethnoarchaeology 49, 54 (R. Gould ed. 1978)); Weberman, The Art of Garbage 1 Analysis: You Are What You Throw Away, 76 Esquire 113 (1971) (analyzing trash 2 of various celebrities and drawing conclusions about their private lives). A single bag of trash testifies eloquently to the eating, reading, and recreational habits of the 3 person who produced it. A search of trash, like a search of the bedroom, can relate intimate details about sexual practices, health, and personal hygiene. Like riffling 4 through desk drawers or intercepting phone calls, rummaging through trash can divulge 5 the target's financial and professional status, political affiliations and inclinations, private thoughts, personal relationships, and romantic interests. It cannot be doubted that a 6 sealed trash bag harbors telling evidence of the "intimate activity associated with the 7 `sanctity of a man's home and the privacies of life,'" which the Fourth Amendment is designed [486 U.S. 35, 51] to protect. Oliver v. United States, 466 U.S. 170, 180 (1984) 8 (quoting Boyd v. United States, 116 U.S. 616, 630 (1886)). See also United States v. Dunn, 480 U.S. 294, 300 (1987). 9 10 A.J. Weberman is mentioned in 218 books about Bob Dylan or about garbage. See ATTACHMENT D 11 In deciding if California is the proper forum to try a celebrity stalker from another state 12 who has no business dealings or residence in California and has not it should be taken 13 into account California is the State most known for Hollywood and celebrity. In the 1950’s Hollywood was at the forefront of destroying traditional American morality 14 wherein celebrities would divorce and remarry frequently. California is the State where movie stars such as Ronald Regan and Arnold Schwarzenegger have been elected 15 governor. California is the State where Michael Jackson and O.J. Simpson walked and 16 where it took two trials to convict Phil Spector. And California is the State where garbologists are hated the most. As a result Defendant has been the victim of injustice 17 after injustice by the Los Angeles Court System in the course of collection of a sister state judgment. This defendant cannot help but think that what if this kind of thing 18 carried over into criminal court and the judges and prosecutors manipulated the system 19 in capital cases? The use of DNA as evidence has proven that this has happened and destroyed people lives on numerous occasions. What has been done to me is truly 20 revolting: 21 The first instance of blatant injustice in the California Superior Court began with Case 22 No. BS081799. In this case Steve Rombom represented by Gary Kurtz attempted to collect a monetary sister state judgment against A. J. Weberman by having Superior 23 Court Commissioner Murray Gross assign all the money that was to be paid to A. J. Weberman for the rights to the award winning movie The Ballad of A. J. Weberman to 24 judgment creditor Steve Rombom and 25% of the Judgment Debtors earnings from the 25 movie to Steve Rombom in blatant violation of The CODE CALIFORNIA OF CIVIL PROCEDURE SECTION 1710.10-1710.65 which states: 26 27 1710.35. Except as otherwise provided in this chapter, a judgment entered pursuant to this chapter shall have the same effect as an original money judgment of the 28 court and may be enforced or satisfied in like manner. California courts provide that [Summary of pleading] - 3
  4. 4. judgments filed pursuant to the Acts are enforceable in the same manner as judgments 1 in the court where filed. 2 1710.25. (a) Upon the filing of the application, the clerk shall enter a judgment based 3 upon the application for the total of the following amounts as shown therein: 4 (1) The amount remaining unpaid under the sister state judgment. 5 (2) The amount of interest accrued on the sister state judgment (computed at the rate of 6 interest applicable to the judgment under the law of the sister state). 7 (3) The amount of the fee for filing the application for entry of the sister state judgment. 8 (b) Entry shall be made in the same manner as entry of an Original judgment of 9 the court. From the time of entry, interest shall accrue on the judgment so entered at 10 the rate of interest applicable to a judgment entered in this state. 11 This is from the New York State Civil Code: 12 § 48-a. Manner of collection; percentage of earnings deductible; restriction against 13 multiple deductions. Subject to subdivision two of this section, any assignment of future earnings shall be collectible from the assignor's employer at the time of each payment 14 of such earnings commencing with the first payment thereof made after the expiration of ten days from the date of filing with the employer of a true copy of such assignment, 15 authenticated by a notary public or a commissioner of deeds, together with an itemized 16 statement of the amount then due the assignee, which statement shall set forth the following information (1) the date and amount of each payment theretofore made upon 17 the indebtedness and (2) in case public filing is required, the date upon which such assignment or true copy thereof was filed with the filing officer as described in section 18 forty-seven-a, of this chapter. 19 2. The following limitations set forth in paragraphs (a), (b) and (c) of this subdivision 20 shall apply to the collection of assignments of future earnings securing or relating to any indebtedness aggregating less than one thousand dollars; 21 22 (a) the amount collectible in any month shall not exceed ten per centum of the assignor's future earnings payable in such month; 23 24 Commissioner Gross ignored the provisions of the California Code of Civil Law and deprived me of property without due process of law, because I was not convicted in 25 California under California law. SEE ATTACHMENT E 26 The next ―judge‖ Defendant encountered was Lisa Hart Cole, in Beverly Hills, 27 California. There is no worse venue in the entire universe for a garbologist than Beverly Hills, as it is filled with celebrities and those whose living depends on celebrity. This 28 action was an attempt to shut down Defendant’s website by seizing the URLs as a [Summary of pleading] - 4
  5. 5. tangible asset. Plaintiff’s December 28, 2006 Declaration revealed this wherein he 1 labored under the misapprehension that to seize the URL would be identical to seizing 2 the actual content of the website, ―The websites at issue have value because of their age and unusual content…Obviously the defamatory information would be purged from 3 the websites before they are sold.‖ Kurtz believed the content of the webpage was somehow wedded to the URL rather than on the server. 4 5 Kurtz was able to obtain a default judgment against judgment debtor by mailing his complaint to a mail drop (See ATTACHMENT F) that Defendant visited about once 6 every six weeks rather than to my home address which was in his possession. He was 7 able to get a default judgment against me based on my not having answered the complaint within the required 30 day window as the Clerk who entered this judgment 8 was either erred or deliberately overlooked that fact that as an out of State defendant served by mail Judgment Debtor was entitled to an extra ten days to answer the 9 complaint. See Attachment G. Despite the fact that the default judgment was illegal the 10 URLs dylanology.com, garbology.com, steverombom.com, and acidtrip.com were one by one being turned over to a court appointed receiver to be sold to the highest bidder. 11 As it transpired the bidding was done by a Hong Kong firm connected to Steve Rombom. No one would want to pay $8000 for these web addresses that remain empty 12 as of today. Defendant filed a motion to vacate the Default Judgment. Lisa Hart Cole 13 opined: 14 Civil • Tentative Rulings DEPARTMENT X LAW AND MOTION RULINGS Dept. X - (310)288-1210 15 This court follows CRC 324(a)(2). The tentative ruling will not become the final ruling of 16 the court until the hearing. However, if all parties to the motion agree to submit on the tentative ruling, they may notify the court via conference call before 8:45 am the day of 17 the hearing, and the tentative ruling will become the ruling of the court. If a motion is unopposed and the moving party wishes to submit on the tentative ruling, the moving 18 party may notify the court before 8:45 am the day of the hearing, and the tentative ruling 19 will become the ruling of the court. 20 Case Number: SC092414 Hearing Date: August 21, 2007 Dept: X RAMBAM v. ENOM SC092414 21 Defendant Weberman's MOTION TO SET ASIDE THE DEFAULT AND DEFAULT 22 JUDGMENT is granted. CCP 473 is remedial in nature and must be liberally applied. Default judgments are generally disfavored, and whenever reasonably possible, cases 23 should be decided upon their merits. Finally, where a defendant seeks timely relief from 24 the judgment and has a meritorious defense, doubt, if any should be resolved in favor of the motion to set aside the judgment. Also, it should be noted that entry of the default 25 was sought one day early. The amended complaint was served on 2/10/07 (POS shows mailed copy only) and the response was due by 3/22/07 (30 days plus 10 for service 26 outside California; February has only 28 days). Default was sought and entered on 27 March 21, 2007. Question: Does the report of the receiver moot this motion? 8/21/2007 28 [Summary of pleading] - 5
  6. 6. At this August 22, 2007 hearing the receiver was asked if all the URLs had been turned 1 over to him. When he answered in the negative, rather than making her ruling final, 2 Judge Cole abruptly adjourned the Hearing. See Attachment. In the interim the remainder of the URLs was seized after which Kurtz made a motion to dismiss the case 3 against me, leaving Defendant no way to appeal. [SEE ATTACHMENT H] Defendant believes there was collusion between Judge Lisa Hart Cole and William Gary Kurtz to 4 deprive Defendant of property without due process of law or Judge just hated Defendant 5 on her own for having invented garbology. It was at this point that Defendant realized that there was no real justice in the California Civil Court system. 6 7 The next move in Rombom and Kurtz’s campaign to shut down Defendant’s website critical of them was for Kurtz to sue Defendant. But the California Court of Appeals had 8 overturned a lower court ruling and ruled that simply because an Internet website was viewable in California, this did not constitute jurisdiction for a libel suit. See 9 ATTACHMENT I. The case was assigned to Judge Michael Harwin. On September 25, 10 2009 Judge Michael Harwin, after a discussion about service, stated in open court, ―Mr. Weberman you should know that I am also admitted as an attorney in New York State 11 so if need be we will try it there.‖ Judge Harwin was serious in his tone and when Defendant asked if he was a judge in both New York State and California 12 simultaneously he told his clerk to hang up the phone. The law regarding personal 13 jurisdiction in California indicates that a defendant can file an answer, demurrer, or motion to strike without waiving the right to contest personal jurisdiction. The law does 14 not allow the defendant to ask the judge to recues himself and subsequently contest personal jurisdiction. See CA Code of Civ. Proc. Section 418.10. (e) A defendant or 15 cross-defendant may make a motion under this section and simultaneously answer, 16 demur, or move to strike the complaint or cross-complaint. 17 Judge Harwin knew that Defendant was a pro se Defendant was not familiar with the California Civil Code so he deliberately made this remark knowing that Defendant would 18 ask him to recues himself and therefore lose any jurisdictional motions I might file. 19 Judge Harwin also hated Defendant because of garbology. The Judge liked to hobnob with celebrities: The Beverly Hills Courier of November 7, 2008 reported, ―In a 20 neighboring booth at Spago were William Morris Agency’s legendary Norman Brokaw and wife Maggie with Superior Court Judge Michael Harwin and wife Lisa, with 21 Norman revealing that he’s been with the agency for 65 years. He’s represented top 22 Beltway politicos through the decades and superstars such as Marilyn Monroe and Bill Cosby. ―Marilyn was a lover of my cousin, Johnny Hyde… they romanced for months in 23 his nest on North Palm in Beverly Hills. ―I found Marilyn early jobs when the actors’ 24 scale was $50.‖ 25 The case was turned over to Judge Kaddo. Why should this judge be any different than any other of the Judges who had used unprincipled or illegal tactics against Defendant? 26 Defendant filed a motion to dismiss this lawsuit on the basis of jurisdiction several 27 weeks in advance of the deadline given to Defendant but forgot to set a hearing date. Defendant mailed this motion without asking for delivery confirmation as when 28 Defendant had done so in the past the court had received them. After the ex parte [Summary of pleading] - 6
  7. 7. summary judgment hearing Defendant called Judge Kaddo’s clerk and was told that the 1 motion was never received and then Defendant was told that Defendant did not set a 2 hearing date for that motion. Judge Kaddo’s clerk, knowing Defendant was a pro se defendant, did not have the decency of notifying Defendant by letter, telephone or email 3 that the motion had not been filed due to this discrepancy. During a subsequent hearing to quash the Summary Judgment of 1.5 million dollars Judge Kaddo denied Defendant’s 4 motion of the basis of Defendant having asked Judge Harwin to recues himself. 5 Suddenly it became clear to Defendant what Judge Harwin had been up to – he had set me up! Just as Judge Harwin expected, Defendant had no idea that to file a Motion for 6 Recusal would void my Jurisdiction defense. It should be noted that Defendant had filed 7 for a fee waiver which was not covered in the Statute regarding the motions Defendant is allowed to file without recognizing jurisdiction. Defendant asked Judge Kaddo what 8 Defendant was to do, Defendant had a judge that I believed hated me and I was not conversant with the intricacies of the California Civil Code nor did Defendant think 9 Judge Harwin was so unprincipled as to act in this fashion. Defendant stated to Judge 10 Kaddo, ―He tells me he is going to hang me! What am I supposed to do, go with hanging judge?‖ He responded; ―Well we don’t do those things anymore we stopped before 11 thanksgiving‖ making light of the fact that Judge Harwin had ―Oswalded‖ Defendant in order to defeat justice. It was all a big joke to the Judge. Defendant began an 12 investigation of Judge Kaddo and Defendant discovered the following: 13 JUDGE KADDO HAS TIES TO HEZB’ALLAH. 14 According to the sworn testimony of his son-in-law Judge Kaddo had ties to the 15 Lebanese terrorist group Hezb’allah, also known as The Army of God. This group has 16 thousands of Iranian missiles aimed at my country, Israel (I enjoy dual citizenship) from Judge Kaddo’s native country, Lebanon. The Hezb’allah connection first surfaced after 17 Judge Kaddo decided to take the law in his own hands. 18 MAN SEEKS COURT'S PROTECTION AFTER JUDGE'S THREAT 19 L.A. COUNTY JURIST SAID IN CHILD CUSTODY HEARING THAT 20 HE WOULD KILL HIS DAUGHTER'S BOYFRIEND. By Jean Guccione LA Times Staff Writer October 20 2002 21 22 A 41-year-old man is asking the court for protection from his girlfriend's father, a Los Angeles County Superior Court judge who 23 testified during a bitter child custody hearing that he would kill him. Judge James A. Kaddo testified in April that he would kill Fadi Nora 24 because he didn't want the man near his three young grandchildren -- 25 a remark the judge now says he regrets. "It was a stupid thing to say, but I was a grandfather in tears," said Kaddo, recounting the April 22 26 court hearing. Nora said the remark was just the latest threat that Kaddo has made against him in the last two years. In court 27 documents, Nora said he is so afraid of Kaddo that he moved to an 28 undisclosed location and quit attending services at his church. "I live under a constant threat of death," he said in a declaration filed last [Summary of pleading] - 7
  8. 8. month in Orange County Superior Court. Nora, who is living with 1 Kaddo's daughter, Nadia Yammine, is asking the court to bar Kaddo 2 from coming within 150 yards of him, his home, his car or workplace. A hearing is scheduled for Oct. 25. 3 The Los Angeles County district attorney's office declined last 4 month to file criminal charges against Kaddo, who was appointed to 5 the bench by then-Gov. George Deukmejian in 1991 and is now assigned to Van Nuys. The 68-year-old jurist's statement is not 6 considered an actual threat "because the specific intent necessary to 7 commit the crime is lacking," the district attorney's investigation concluded. "Rather, his statement appears to be an inappropriate 8 emotional response to a very charged issue." During the hearing, Kaddo urged Commissioner Ann Dobbs to deny his daughter's bid for 9 custody of her three children, now 8 to 13. He said he didn't want his 10 grandchildren near Nora, a friend of the Kaddo family for two decades until he began dating the judge's daughter. Kaddo testified that he told 11 Yammine: "I can't stand to have that psycho around my grand kids. I'm going to do what I have to do to save my grandchildren," according to 12 a transcript of the hearing. 13 On cross-examination, Yammine's attorney, Wendy A. Herzog, asked 14 Kaddo what he had meant. "If it means killing him, I will do it," the judge responded. "Killing who?" Herzog asked. "Mr. Nora," Kaddo 15 answered. "Is there anything else that it could have meant?" she 16 asked. "That's what I had in mind," Kaddo said. That's where the exchange ends in the court transcript. But Nora, Yammine and Herzog 17 contend the court reporter did not capture Kaddo's final words on the subject. They assert in court documents, that Kaddo also said, "And I 18 would do it with my bare hands if I had to." Kaddo's attorney, 19 Theodore A. Cohen of Beverly Hills, denied all of the allegations against his client. He said the judge's testimony was misinterpreted. 20 "What he intended to say was that anybody would do whatever they 21 could to protect a child or grandchild," Cohen said. "He said what any 22 one of us would have said" under the same circumstances. 23 In addition to seeking a restraining order against the judge, Nora filed 24 a complaint with the state Commission on Judicial Performance, which investigates allegations of misconduct and disciplines errant judges. 25 No California judge has ever been publicly disciplined for threatening to kill another person, according to commission records. But an 26 intemperate jurist was censured for threatening to jail a telephone 27 company worker if the judge's phone service was interrupted. Another judge was removed from office for misconduct that included 28 [Summary of pleading] - 8
  9. 9. threatening to give a police officer "a .38-[caliber] vasectomy" after he 1 cited the judge for excessive use of her car horn. 2 Yammine said in a declaration that the court should take the 3 threats her father made against Nora "very, very seriously." Nora and Yammine said their dispute with Kaddo began almost two years 4 earlier, when Nora, a family friend, helped Yammine with her divorce 5 from a wealthy Lebanese businessman. Kaddo wanted Yammine to return to her husband. According to his declaration, Nora said the 6 judge showed him four tire valves a few days after the tires on his 7 Jeep were deflated in October 2000 in a secure garage, implying that the judge was responsible. 8 And a month before the heated child custody hearing, Nora said he 9 received an anonymous call from someone who told him in Lebanese 10 that "my days were numbered." 11 In court documents filed this week, Yammine accused her ex- husband of having ties to the terrorist group, Hezbollah. She said 12 her father has sided with him in an effort to fulfill his political and 13 business aspirations in his homeland. 14 Yammine also accused Kaddo of conspiring with her ex-husband to keep her children, who are U.S. citizens, in Lebanon against her 15 will. Cohen denied the allegations against his client. "The whole thing 16 is just insanity," he said, noting that a Hezbollah sympathizer would never retain a Jewish attorney to represent him. 17 Yammine signed an agreement permitting her husband to raise their 18 children in Lebanon. When she tried to have the stipulation 19 overturned, her father testified against her, and she lost. Santa Ana- based attorney Richard C. Gilbert, who is representing the couple, 20 accused the justice system of giving Kaddo special treatment because 21 he is a judge. 22 "That transcript is troubling," Gilbert said. "The commissioner [Dobbs] does not report it to the Commission on Judicial Performance 23 or the police ... Instead, she just changes the subject." Gilbert said 24 temporary restraining orders are routinely granted in heated domestic situations like these. But Nora has been unable to get such an order, 25 he said, without retaining an attorney and testifying in court with Kaddo present. "Could you imagine," Gilbert said, "what would happen 26 if Mr. Nora had threatened a Superior Court judge?" 27 During the custody hear, Judge James Kaddo testified as follows: Judge James 28 Kaddo: "If it means killing him, I will do it." DA Herzog: "Killing Who?" Judge James [Summary of pleading] - 9
  10. 10. Kaddo: "Mr. Nora." DA Herzog: "Is there anything else that it could have meant?" Judge 1 James Kaddo: "That's what I had in my mind." According to Nora’s sworn declaration, 2 Judge James Kaddo also threatened to ―get gang members that he has done favors for as a judge to harm him.‖ This indicates the Judge is corrupt and has a proclivity toward 3 violence and would associate himself with like minded people. 4 See ATTACHMENT J and see Nora V Kaddo B166045 5 6 The argument that because Cohn was Jewish Judge Kaddo could not have Hezb’allah 7 connections is fallacious. Other Jewish attorneys have represented members of Hezb’allah. Information about Mohamad Youssef Hammoud is available in a federal 8 affidavit filed in July 2000 in the U.S. District Court in Charlotte, North Carolina, based on the reports of six cooperating witnesses and five secret informants, physical 9 surveillance, financial records, and much else. Hammoud, it seems, received military 10 training in Hezb’allah camps in Lebanon and boasts of being "well-connected" to Hezb’allah leaders. One informant calls Hammoud "100 percent Hezb’allah." Another 11 thinks him dangerous because he "would likely assist in carrying out any action against United States interests" if Hezb’allah asked him to. A third says Hammoud "would not 12 hesitate" to commit a terrorist act in the United States for Hezb’allah. Hammoud was 13 represented by attorney Stanley Cohen, a Jew at least by birth.2 14 Aside from his former son-in-law who as a successful businessman in Lebanon has to deal with these murdering Islamist descendants of apes and pigs Judge Kaddo has 15 many other connections to the Hezb’allah: 16 Judge Kaddo is a leading member of the Lebanese American Foundation as is Wafa 17 Hob’allah. Hob’allah wrote, ―I have been called Ms. Hezbollah by judges in court. Sometimes, it’s an honest mistake, but you can tell when someone does it to be 18 sarcastic. That hurts. I am Lebanese, but I am really a citizen of the world. I don’t 19 present myself as a Lebanese Arab Muslim. I am a professional.‖3 Hob’allah’s cousin, Hassan Hob’allah is head of the international relations section of Hizb’allah's political 20 bureau. 21 Issam Nasr’allah was master of ceremonies at an anti-Israel rally at UCLA and was 22 introduced by Judge James Kaddo, who said: "How sweet it is to hear the words that our beloved south is free again [from evil Israeli occupation].‖ Hassan Nasr’allah is 23 Secretary General of the Hezb’allah. Issam Nasr’allah is a relative and Face Book friend 24 of this terrorist. See ATTACHMENT K. Suzan Fakih is a friend of Issam Nasr’allah and she is also a Face Book friend of Zeinab Moghnieh who is related to Hezb’allah military 25 commander Imad Moghnieh killed in Damascus in February 2008. 26 In July 1985 Judge Kaddo called for the release of Hezb’allah terrorists held by the 27 Israelis. The Los Angeles Times reported: 28 2. http://www.foxnews.com/story/0,2933,244002,00.html 3. http://www.middleeastlaw.com/text/Press/LosAngelesDailyJournal.pdf [Summary of pleading] - 10
  11. 11. ―James Kaddo is a Maronite Christian and chairman of the Los Angeles-based United 1 American-Lebanese Committee. Although he is a Christian, Kaddo said he is concerned 2 that Americans are beginning to lump all things Middle East together. That's the reason he participated in a press conference held here last week by Arab-Americans calling for 3 the release of both the hostages and the prisoners held by the Israelis, he said. "The Arabs are being mistaken for the Iranians," he said, referring to the fact that one group 4 holding a few of the American hostages [the Hezb’allah] is thought to be financially 5 supported by the Iranian government. In fact, Iranians and Arabs are ethnically different, and speak different languages--Arabic and Persian. During the crisis, Kaddo said he 6 had been in contact throughout the Southland with Lebanese of many different 7 persuasions. "All of the factions have been contacting me [including the Hezb’allah] and feel we should not sit on our hands because we don't want to have Americans feel 8 that we have a loyalty problem," he said.4 9 The United American Lebanese Committee AKA The United American Lebanese Federation sponsored a speech by Jack Shaheen whose publisher is Olive Branch 10 Press. Olive Branch Press has published numerous books by David Ray Griffen who writes that the U.S. government caused or deliberately allowed the attacks of 09/11/01 11 to take place and that the collapse of the twin towers of the World Trade Center was 12 caused by a controlled demolition (bombs planted in the buildings prior to the planes striking the buildings). He hallucinates that the Pentagon was not struck by American 13 Airlines flight 77 or any commercial jet, but was hit by a guided missile and the commercial jet that crashed in Pennsylvania was hit by a heat-seeking guided missile 14 launched by the government to silence the hijackers who could have exposed 15 government complicity. Of course Bush knew in advance that the attacks would take place because after the attacks began he stayed talking to children in a classroom. 16 17 The Presbyterian Jew-hating missionizing5 Olive Branch Press also publishes the work of Phyllis Bennis. Bennis defends Iran and challenges White House concerns that Iran 18 intends to build nuclear weapons, going so far as to argue that Iranian President Mahmoud Ahmadinejad’s calls to ―wipe Israel off the map‖ were misinterpreted and that 19 really, ―the threat is the other way around‖ because Israel is pushing for a war against 20 Iran. 21 Judge Kaddo admitted that there was a question about his State Department security clearance but claimed he was granted it after a year-long investigation: ―Upon 22 completion of my Army service, I intended to go into the State Department or the 23 Foreign Service, hopefully, to serve at an American embassy in the Middle East. Unfortunately, the background check, which was mandatory—both in the United States 24 and Lebanon—took longer than expected and by the time I received clearance, I had almost finished one whole year of study at the University Of Southern California School 25 Of Law. I then decided that I might as well finish law school and, thus, gave up a career 26 in the Foreign Service.‖6 Why didn’t the Judge finish law school then go in the State Department? I believe he was never granted a security clearance. 27 4. http://articles.latimes.com/1985-07-03/news/vw-10378_1_divided-loyalty?pg=4 28 5. http://www.adl.org/PresRele/ChJew_31/4537_31.htm 6. http://www.lasuperiorcourt.org/courtnews/uploads/13200728113023gaveltogaveldiversity2006 .pdf [Summary of pleading] - 11
  12. 12. 1 2 3 JUDGE KADDO SUPPORTS THE TERRORIST GROUP THE PALESTINIAN LIBERATION FRONT (PLO). 4 5 In 1987 Immigration authorities arrested Khader Hamide and Michel Shehadeh with five other young Palestinians and a Kenyan woman--dubbed the "LA 8" by the media--on 6 charges of being affiliated with the Popular Front for the Liberation of Palestine, then 7 the second-largest faction of the terrorist Palestine Liberation Organization (PLO). The government claimed that the Popular Front for the Liberation of Palestine 8 advocated world communism, making affiliation with it a deportable offense under the McCarran-Walter Act. Attorney James Kaddo handled the case for these would be 9 terrorists and was able to get them off the hook by using the same US Constitution 10 these wannabe terrorists wished to replace with a Communist dictatorship with an Islamic tinge. Kaddo stated that Congress had passed a law that was intended to 11 ―misguide and misdirect the American people from airing views and making a lucid decision on the Middle East.‖ ―Lucid decision‖ means abandon Israel and support its 12 enemies sworn to destroy it. In September 2003, after American learned what terrorism 13 was really about the government announced it would seek their deportation under the Patriot Act for distributing Palestinian magazines and raising ―humanitarian aid‖ in Los 14 Angeles more than twenty years ago. America had come to its senses that people like James Kaddo had pulled the wool over its eyes. See ATTACHMENT K2 15 16 Additional PLO connection: Judge Kaddo was close friends with Dr. Sabri El Farra who along with terrorist and murderer Yassir Arafat had organized a terrorist cell, under the 17 guise of a Palestinian Youth Movement, when both attended the same secondary school in Egypt. See ATTACHMENT L 18 19 JUDGE KADDO IS PART OF THE ARAB AMERICAN TERRORIST SUPPORT NETWORK 20 Judge Kaddo is a leading member of the Arab American Anti-Discrimination League. 21 See ATTACHMENT M In 1980, James Zogby7 joined with former Senator James 22 Abourezk to form the ADC. The ADC has 18,000 members and claims to be the largest grass roots Arab-American organization. It claims that its mission is defending the 23 political rights and promoting the cultural heritage of the more than three million 24 7. In 1984, Zogby served as deputy campaign manager for fundraising for the Reverend Jesse Jackson’s presidential 25 campaign Zogby has come to the defense of the Muslim Brethren, Hamas, and Islamic Jihad, arguing that these groups are merely ―politically‖ or ―religiously‖ opposed to the peace process. He defended the American Muslim 26 Council. James Zogby criticized President Clinton’s January 1995 executive order classifying a number of Islamist organizations as terrorist groups. Zogby rejected outright in the pages of a pro-Hamas publication, that fundraising within the Arab-American and Muslim American community is in any way connected to any Middle Eastern terrorist 27 groups ―Not enough has been done to explain Islam in the West and to deal with those passages in the Qu’ran that some in the West find troubling. One easy way to do this is to invite those who ask the questions to read the entire 28 Qu’ran and read the entire Torah and then see which is the bloodier scripture.‖ [Summary of pleading] - 12
  13. 13. Americans of Arab descent. However Senator James Abourezk is himself a terrorist 1 sympathizer – he was willing to testify for Sheik Omar Abdel Rahman8 but was 2 prevented from doing so. The Blind Sheik Rahman’s attorney, Abdeen Jabara, was honored with the James A. Kaddo Award (for furthering terrorist support groups in 3 America). The ADC is part of the Islamists ―Terror Lobby‖ and uses civil liberties issues to make it easier for Islamists to operate by lobbying against ―anti-terror‖ legislation on 4 the highest levels of government. After Islamist Umar Farouk Abdulmutallab attempted 5 to kill 300 human beings on a flight landing in Detroit the United States Government decided to screen travelers coming from Yemen, Pakistan and other terrorist breeding 6 ground with a full body search. Nawar Shora, the legal director at the American-Arab 7 Anti-Discrimination Committee, said the rule wrongly implied that all citizens of certain nations are suspect. ―I understand there needs to be additional security in light of what 8 was attempted on Christmas Day,‖ Mr. Shora said, adding that he intended to file a formal protest on Monday. ―But this is extreme and very dangerous. All of a sudden 9 people are labeled as being related to terrorism just because of the nation they are 10 from.‖ Mr. Shora is involved in an attempt to security strip America making it easier for terrorists to carry out their dastardly deeds by making it easier for terrorists to get on 11 airplanes. See ATTACHMENT N. This was not the first attempt of the ADC to facilitate the work of terrorists as they have attempted to eviscerate certain provisions of the 12 Patriot Act. See ATTACHMENT O 13 14 JUDGE KADDO IS A SUPPORTER OF JESSE JACKSON AND RALPH NADER. 15 Mr. JAMES KADDO (ATTORNEY), (Zip code: 90004) $1000 to JESSE JACKSON FOR 16 PRESIDENT '88 COMMITTEE on 05/14/88.9 Jackson called Jews ―Hymies‖10 Among 17 Jackson’s most damning quotes: that although "Zionists who have controlled American policy for decades" remain strong, the "decades of putting Israel's interests first" would 18 end once Obama became president.11 19 Judge Kaddo is part of the Arab American Lawyers Association of Southern California 20 that sponsored a speech by Ralph Nader. Lebanese American Ralph Nader stood by 21 his characterization of the White House and Congress as "puppets" of the Israeli government, in a letter sent to Anti-Defamation League national director Abraham 22 Foxman. This is not much different than the Nazis contention that America is living under a ―Zionist Occupational Government‖ or ZOG. SEE ATTACHMENT P 23 24 25 26 8. USA v Rahman Doc. Number 642 9. http://www.city-data.com/elec2/88/elec-LOS-ANGELES-CA-88-part7.html 27 10. http://www.washingtonpost.com/wp-srv/politics/special/clinton/frenzy/jackson.htm 28 11. http://www.washingtonpost.com/wp-dyn/content/article/2008/10/15/AR2008101503623.html [Summary of pleading] - 13
  14. 14. DEFENDANT HAS DUAL ISRAELI AMERICAN CITIZENSHIP AND IS ACTIVE IN 1 FIGHT AGAINST TERRORISM AS A LEADING MEMBER OF THE MILITANT 2 JEWISH DEFENSE ORGANIZATION 3 It comes as no surprise that Judge Kaddo was assigned to Defendant’s case after Judge Harwin deliberately sabotaged it by luring Defendant into making a motion for 4 recusal. Defendant is a researcher for and member of the Jewish Defense Organization 5 since its inception. The JDO has been the target of numerous actions brought about by Steve Rombom and his attorney and Plaintiff in this case William Gary Kurtz. The 6 website in question contains numerous references to the Jewish Defense Organization; 7 in fact the letter accusing Kurtz of raping a mentally ill client of his was mailed to the Jewish Defense Organization post office box. See ATTACHMENT Q. Judge Kaddo 8 knows Defendant is a Jewish militant opposed to everything he stands for. Of all the judges in Los Angeles why did a Jewish militant end up being tried by a judge who is 9 anti-Israel and who apparently has clear links to terrorist groups within Lebanon? This is 10 not a matter of Judge Kaddo being prejudice against Jews; it is a matter of Judge Kaddo having a long record of support for Palestinians and an anti-Zionist political bias. 11 As Defendant has demonstrated it is impossible for him to get fair judicial rulings in this venue and this is an additional reason Defendant’s Motion should be granted. In 12 conclusion the Los Angeles Superior Court is an improper and inconvenient venue to try 13 this case in. 14 POINTS OF LAW 15 In a recent opinion, Britton v. Dallas Airmotive, Inc. (Cal. App. - 1st Dist. [Div. 5], July 7, 16 2007) 2007 WL 1990140, the First District of the California Court of Appeal affirmed a stay of litigation on forum non conveniens grounds pending re-filing in Idaho.1 The 17 Court confirmed that, absent unreasonable delay or other prejudice to the parties, a defendant may properly bring a forum non conveniens motion pursuant to California 18 Code of Civil Procedure § 410.30 even after making a general appearance in the action. 19 Section 410.30 provides: ―(a) When a court upon motion of a party or its own motion finds that in the interest of substantial justice an action should be heard in a forum 20 outside this state, the court shall stay or dismiss the action in whole or in part on any conditions that may be just. Section 410.30 clearly authorizes a trial court to raise the 21 forum non conveniens issue at any time. Indeed, section 410.30(a) states that a trial 22 court ―shall‖ stay or dismiss the action if it finds that ―in the interest of substantial justice an action should be heard in a forum outside this state.‖ As the Court explained, 23 plaintiffs’ interpretation would lead to absurd results because ―to retain a case for the 24 entire duration of the litigation because the lack of connection to California was unclear at the outset would impair the state’s interest in avoiding burdening courts and potential 25 jurors with litigation in which the local community has little concern.‖ In sum, the Court construed sections 418.10 and 410.30 ―in harmony.‖ Read together, they provide that 26 where a defendant has not appeared, section 418.10 applies and specifies the 27 procedure for bringing a forum non conveniens motion. Section 410.30 applies after a defendant has appeared. So understood, section 418.10 provides special procedures 28 for pre-answer forum non conveniens motions but such motions are not precluded after [Summary of pleading] - 14
  15. 15. a defendant has appeared. This is a reasonable rule because it may be necessary to 1 conduct discovery to develop the factual underpinnings of a forum non conveniens 2 motion. (See, e.g., Morris v. Agfa Corp. (2006) 144 Cal. App. 4th 1452, 1462.) 3 4 5 DECLARATION OF ALAN JULES WEBERMAN 6 1. The articles and documents attached and the facts of this declaration are based on 7 my personal knowledge and if called and sworn as a witness, I could testify to the following: I am a Dylanologist, Garbologist, researcher from the Jewish Defense 8 Organization, Board Member of the Yippie Museum, an educational institution chartered 9 by the Board of Regents of New York State. I have worked a Congressional Researcher for Senator Richard Schwieker and Congressman Henry Gonzalez and served as a 10 consultant to the House Select Committee on Assassination. I am the author of My Life In Garbology, Coup D’état in America, The Dylan To English Dictionary, RightWing Bob 11 and Homothug, The Secret Life of Rudy Giuliani. The last book was removed from 12 Amazon after Rudy threatened it with a multi-million dollar lawsuit and now sells for $200 on Ebay. I am also a researcher into judicial corruption. My career in investigating 13 the Civil Court system began when I was sitting in the Courtroom of Brooklyn Supreme Court Judge Theodore Jones as a defendant when the story of Democratic boss 14 Clarence Norman having sold Civil Court judgeships broke. I overheard Judge Jones 15 react and tell his bailiff ―we were very careful.‖ Later I observed Judge Jones attend a fundraiser for Norman and discovered the two had been law partners. In the course of 16 my interaction with this Brooklyn Civil Court system two of the judges that made rulings against me, Judge Michael Garson and Victor Baron, went to prison. This lawsuit is 17 about suppressing the work of an infamous muckraking journalist and I should be given 18 every chance to fight it in New York City, even by a pro-PLO judge. 19 2. I am a resident of New York State having lived here since 1945. I am an investigative journalist who is studying the life of Steve Rombom and his attorney and business 20 associate Gary Kurtz. 21 3. The basis of the lawsuit is to prevent me from expressing my thoughts about Gary 22 Kurtz on the Internet, it is a workaround the First Amendment. As an American I am 23 sworn to uphold the constitution and insure it is not replaced with something such as Shar’ia law where one is free to do one thing, submit to the will of Allah. If what I write 24 about Kurtz was not based on documentation that he unwittingly provided along with other documentation that I swear under penalty of perjury to be authentic, he would not 25 have to spend his time trying to censor my writing through the judicial system. 26 4. I am willing to waive cross examination at any deposition Kurtz might hold in 27 California. I believe a case such as this should be resolved on its merits in a Court of Law rather than by Summary Judgment. 28 [Summary of pleading] - 15
  16. 16. 1 Dated this January 7, 2010 2 3 ________________________ AJ Weberman pro se 4 318 3rd Avenue #520 New York 10010 5 Gary Kurtz pro per 6 20335 Ventura Blvd Woodland Hills CA 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 [Summary of pleading] - 16