TAITZ v DUNN - 63 - OPPOSITION FILED BY TAITZ, DR., ORLY - DisplayPdf.do.63.0

8/7/2019 TAITZ v DUNN - 63 - OPPOSITION FILED BY TAITZ, DR., ORLY - DisplayPdf.do.63.0

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) CASE NO.: 30-2010) 00381664))))))))

1 J ,~l-DR. ORLY TAITZ ESQ I PRO SE1 29839 SANTA MARGARITA PKWYRANCHO SANTA MARGARITA CA 926882 Ph 949-683-5411 fax [email protected]

CALIFORNIA SUPERIOR COURT4 ORANGE COUNTYCENTRAL JUSTICE CENTER DIVISION567 ORLY TAITZ,8 PLAINTIFF,9 VS.

10 DAMON DUNN,11 DEFENDANT1213141516

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FILEDS UP ER IO R C OU RT O f C AL IF OR NIAC OU NT Y O F O RA NG Ec eN 'fA AL J US TIC E C E NT ERM A R 0 1 2 0 1 1

M.A.NCAFlJ . : ; ; . r~ .C le rk o f th e G o ony1 ? S Y RL~

OPPOSITION TO MOTIONFOR JUDGMENT ON THEPLEADINGSDate March 14. 2011Time 2:pmDept C33Juage Hon Geoffrey T.Glass

Opposition to motion and motion for sanctions - 1
mailto:[email protected]:[email protected]


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1 Come now Dr. Or1y Taitz, ESQ, pro se, Plaintiff in this2 case, hereinafter Plaintiff, opposinq motion by the3 defendant for judgment on the pleadinqs

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8 Motion for judgment on the pleadings filed by thdefendant is not grounded in fact or law and is broughtin bad faith for purpose of harassment of theplaintiff. In his motion for judgment on the pleadingsDefendant simply misrepresents the complaint, makesnumber of fraudulent statement, claims thatcomplaint is an election contest only, while in realitthe main part of the complaint is a complaint for fraucommitted by the defendant, which includes Electionsfraud, voter fraud, nomination fraud. Defendant claimsthat the only remedy sought is an injunctive relief,even though the Plaintiff is seeking damages of over$50, 000 spent by her while running against thecandidate, who was committing fraud. AdditionallDefendant claims, that the complaint was not filetimely, even though it was in fact timely, Plaintifsought expedient handling of the case and Defendant wasthe one who opposed the expedient handling of the case.The motion 1S completely frivolous and filed .in bafaith and needs to be denied.

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1 Defendant's claim that the Plaintiff lS looking onl2 for special relief of being placed on the ballot,3 simply a fraudulent statement. The pleadings clear 14 state that the Plaintiff spent $40,000 of her own mane5 and over $10,000 of money donated by her supporters to6 run for the office of California Secretary of State.7 Plaintiff stated In the complaint that she was force8 to run against the opponent, who was committing fraud,9 as he never provided on his voter registration car

10 mandatory disclosure of his prior voter registration in11 two other states: CA and TX. Plaintiff provided the

whic12 court with an attachment to the complaint,13 contained a Defendant f s prior voter registration fro

15FL, which showed him registered as a Democrat in FL. InCA he ran in Republican primary as a Republican.Plaintiff also provided the court with a letter frothe registrar of voters from Jacksonville, Duval CountFL, which stated that Defendant contacted the registrarof voters III FL and demanded to delete from thedatabase record of his voter registration, which showehim registered as a Democrat. The registrar in Frefused to delete this information from the database,as this was a permanent record. At the same timeDefendant failed to provide this information to theRegistrar of voters in Orange County California. Theseactions on part of the Defendant, Damon Dunn, showethat he remembered that he registered in Florida as aDemocrat, he tried to delete these records, which shows

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1 a pattern of fraud and further pattern of attempte2 cover up of fraud.

the defense 1S seeking a decision on the3 While4 pleadings, the only decision that can be made, 1S that5 the defendant indeed committed fraud. The defendant6 does not provide any evidence that would contradict the7 fact that he registered in two other states and that he8 did not include this information 1n the require9 mandatory disclosure section of his voter registratio

10 card. He did not negate the fact that he contacted the11 registrar in FL and asked to delete from the data base12 his voter registration from FL. He is just saying that13 his FL registration was no longer good. His14 impossibility to vote 1n FL does not negate his frame15 of mind and actions. As such the only ruling on th16 p1eadings can be in favor of the plaintiff.1718 Wherefore the plaintiff moves this honorable court t19 1. deny the motion for judgment on the pleadings or 120 the alterna tive allow the plainti ff the leave of21 to file a first amended complaint to cure m1no22 technical errors in the complaint, that might be faun23 valid errors by the court24 2. award the plaintiffs reasonable fees for the timespent on research and drafting of this opposition25262728



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12 Orly Taitz3 29839 Santa Margarita pkwy,4 ste 100, RSM, CA 9268856 Certificate of service7 I, Orly Taitz, attest that a true and correct copy of8 the above motion was served on the defendant's attorney9 Brian Hildreth via e-mail and/or first class mail

10 and/or fax on 03.01.2011

12 Or~l'altz29839 SantaMargarita PkwyRancho SantaMargarita CA 926881314151617181920212223

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opposition to motion and motion for sanctions - 1

DR. ORLY TAITZ ESQ, PRO SE1 29839 SANTA MARGARITA PKWYRANCHO SANTA MARGARITA CA 926882 Ph 949-683-5411 fax [email protected] CALIFORNIA SUPERIOR COURTORANGE COUNTYCENTRAL JUSTICE CENTER DIVISION567 ) CASE NO.: 30-2010) 00381664)

)))))))

8ORLY TAITZ,

PLAINTIFF, Memorandum of points andauthorities in support ofOPPOSITION TO MOTIONTO DECIDE ON THEPLEADINGSDate March 14, 2011Time 2:00 PMDept C 33Judge Hon Geoffrey T.Glass

9 VS.1011 DAMON DUNN,DEFENDANT121314151617181920212223

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16 FILED pI1

2 TABLE OF CONTENTS3 SUMMARY OF THE OPPOSITION p54 A. DEFENDANT IS DEFRAUDING THE COURT BY CLAIMING THAT5 THIS ACTION IS A CONTEST ONLY p66 B DEFENDANTS CLAIM THAT THE PLAINTIFF IS SEEKING ONL7 AN INJUNCTIVE RELIEF, IS A FRAUDULENT STATEMENT p68 C ACTIONS BY THE SECRETARY OF STATE DO NOT9 EXCUSE ACTIONS BY THE DEFENDANT p8

10 D. NOMINAT ION FRAUD P 811 E EXPEDIENT RELIEF WAS TIMELY REQUESTED BY THE12 PLAINTIFF AND OPPOSED BY THE DEFENDANT. THE13 DEFENSE IS ESTOPPED FROM CLAIMING THAT THE14 EXPEDIENT RESOLUTION WAS NOT REQUESTED TIMELY.p915 F. AFFIDAVIT, VERIFYING THE COMPLAINT WAS17 G CONTESTANT REFERENCED THE ELECTIONS CONTEST18 CODE p1219 H. ELECTION CONTEST WAS FILED TIMELY p1320 I. THE FACT THAT DUN DID NOT WIN THE GENERAL21 ELECTION DOES NOT MAKE THE LEGAL ACTION AT HAN22 MOOT P1423 J PRECEDENTS BROUGHT BY THE DEFENSE REFER ONL24 TO THE ISSUE OF THE ELECTIONS CONTEST AN25 INJUNCTIVE RELIEF. THEY DO NOT RELATE TO THE26 ISSUE OF FRAUD BY THE DEFENDANT p162728



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3 THIS CASE. . . . .. .. . . . . . . . . . . . .. . . .. .. . . . . . . . . . . .P 181 K. LETTER FROM AN INVESTIGATOR TO ANOTHE2 PLAINTIFF IN A DIFFERENT CASE IS NOT RELEVANT T4 L. DECLARATORY RELIEF IS A PROPER REMEDY IF THE5 STATUTORY RELIEF IS UNAVAILABLE p186 M. DEFENSE ALLEGATIO THAT THE PLAINTIFF FAILS T7 STATE THECAUSE OF ACTION IS TOTALLY FRIVOLOUS8 AND IN BAD FAITH p199 N. WHETHER DUNN SATISFIED THE REQUIREMENTS,IS

10 MATTER TO BE ASCERTAINED DURING THE DEPOSITIONS11 AND DURING TRIAL BY THE JURY p2312 O. THE FACT THAT OTHER NOMINATORS WERE POSSIBL13 VALID DOES NOT NEGATE THE FACT THAT MR. AND MRS.14 LINTON DID NOT SIGN THE NOMINATION AND FRAUD WAS15 COMMITTED , . p2 316 P C J r DIS FRIVOLOUS p2 317 Q. 1 E I S FRIVOL0US. ..........................P 2 318 R. FACTUAL BACKGROUND BY THE DEFENSE CONTAINS19 FRAUDULENT STATEMENT REGARDING DUNN'S PRIO20 VOTER REGISTRAT I ON ................... p2 421 S. THE ONLY RULING THAT CAN BE MADE ON THE22 PLEADINGS, IS THAT THE DEFENDANT INDEE23 COMMITTED FRAUD p2524 certification 2625262728



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1 EXHIBIT 1 TRANSCRIPT OF JULY 1, 2010 TRO HEARING TAITZ2 V DUNN3 EXHIBIT 2 FILED 06.24.2010 NOTICE AND MOTION IN TAITZ4 DUNN5 EXHIBIT 3 VOTWERREGISTRATION BY DAMON DUNN67

8 TABLE OF AUTHORITIES910 I. Rideout v. City of Los Angeles (1921) 185 Cal. 426,11 430 [197 P. 741 pl012 2. Hayes v. Kirkwood (1902) 136 Cal. 396 [69 P. 30] .pl013 3.Atkinson v. Lorbeer, 111 Cal. 419, 421 [44 P. 162.plO14 4. Filarsky v Superior Court (2002) 28 Cal.4th 419 .. p1215 5. Bradley v Perrodin (2003) 106 Cal. App.4th 1153,16 1167, 131 Cal. Rptr.2d 402 ......................... p1317 CCP 438 p1218 Elections Code19 16100 p1320 16100 (b) _ oil p1321 16100 (c) p1322 13314 _ _ p1323 16161 A p1324 164 21A P1325 161011 III _ p13262728



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3 Come now Dr. Orly Taitz, ESQ, pro se, Plaintiff in this4 case, hereinafter Plaintiff, opposing motion by the5 defendant67 SUMMARY OF THE OPPOSITIONB

910 Motion for ruling on the pleadings filed by the11 defendant ~s not grounded in fact or law and is12 In bad faith for purpose of harassment of13 plaintiff. In his motion for judgment on the pleadings14 Defendant simply misrepresents the complaint, makes15 number of fraudulent statement, claims that16 complaint is an election contest only, while in realit17 the main part of the complaint is a complaint for frau18 committed by the defendant, which includes Elections19 fraud, voter fraud, nomination fraud. Defendant claims20 that the only remedy sought is an injunctive relief,21 even though the Plaintiff is seeking damages of over22 $50, 000 spent by her while running against the23 candidate, who was commit ting fraud. Additionall24 Defendant claims, that the complaint was not file25 timely, even though it was in fact timely, Plainti26 sought expedient handling of the case and Defendant was27 the one whoopposed the expedient handling of the case.28


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1 The motion 1S completely frivolous and filed in ba2 faith and needs to be denied.3 A. DEFENDANT I S DEFRAUDING THE COURT BY CLAIMING THAT4 THIS ACTION IS A CONTEST ONLY5 The Complaint clearly states that it includes multiple6 causes of action, not only elections contest. It7 clearly states that it included8 1. Fraud9 2. Elections fraud

10 3. Voter fraud11 4. Nomination fraud12 Plaintiff plead at length the facts of these causes of13 action and assertion, that this 1S only an elections14 contest lS simply a fraudulent statement, which was15 made in bad faith without any basis of fact.16 B DEFENDANTS CLAIM THAT THE PLAINTIFF IS SEEKING ONLY17 AN INJUNCTIVE RELIEF I IS A FRAUDULENT STATEMENT18 Defendant's claim that the Plaintiff is looking onl19 for special relief of being placed on the ballot,20 simply a fraudulent statement. The pleadings clearl21 state that the Plaintiff spent $40,000 of her ownmane22 and over $10,000 of money donated by her supporters to23 run for the office of California Secretary of State.24 Plaintiff stated in the complaint that she was force25 to run against the opponent, who was committing fraud,26 as he never provided on his voter registration car27 mandatory disclosure of his prior voter registration in28 two other states! CA and TX. Plaintiff provided the



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court with an attachment to the complaint, whiccontained a Defendant's prior voter registration froFL, which showed him registered as a Democrat in FL. InCA he ran In Republican prlmary as a Republican.Plaintiff also provided the court with a letter frothe registrar of voters from Jacksonville, Duval CountFL, which stated that Defendant contacted the registraof voters in FL and demanded to delete fromdatabase record of his voter registration, which showehim registered as a Democrat. The registrar In Frefused to delete this information from the database,as this was a permanent record. At the same timeDefendant failed to provide this information to theRegistrar of voters in Orange County California. Theseactions on part of the Defendant, Damon Dunn, showethat he remembered that he registered in Florida as aDemocrat, he tried to delete these records, which showsa pattern of fraud and further pattern of attemptecover up of fraud.C ACTIONS BY THE SECRETARY OF STATE DO NOT EXCUSE THE

ACTIONS OF THE DEFENDANTDefendant lS saying that because Debra Bowen, secretarof state of CA did not make him fill out a new voteregistration card and did not remove him fromballot, somehow excuses Dunn's actions. Wrongdoing aanother party does not excuse the wrongdoing of theDefendant.

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1 Whether Secretary of state Debra Bowen acte2 negligently or in bad faith, 1S irrelevant to actions3 by the defendant. Defendant knew that he registered to4 vote 1n two other states: Texas and Florida. He kne5 that he registered previously as a Democrat. He kne6 that he 1S running in California as a Republican an7 that it is material for Republican candidates,8 Plaintiff, and voters to know, whether he registere9 before in another state and which party affiliation di

10 he claim.11 Lack of action by the Secretary of state Bowen did not12 excuse actions by Dunn.l3 D. Nomination fraud14 Plaintiff plead not only voter fraud and elections, but15 also nomination fraud. Plaintiff provided informatio16 regarding nominators Mr. and Mrs. Linton, who17 listed by Dunn as nominators f but who stated that the18 never nominated him. A TV program "Nomination Fraud"19 was created and was run on TV and Internet by T20 producer and talk show host William Wagener. Frau21 committed .in nomination, is a cause of action that was

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not resolved and which needs to be heard by the jury 0the merits.

E. EXPEDIENT RELIEF WAS TIMELY REQUESTED BY THEPLAINTIFF AND OPPOSED BY THE DEFENSE. THE DEFENSE ISESTOPPED FROM CLAI~NG THAT THE EXPEDIENT RESOLUTION

WAS NOT REQUESTED TIMELY

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lOne of the most outrageous allegations l.n the

18 Transcript of the 07.01.2011 hearing (Exhibit 1)

2 Defendant' 5 motion is a notion that the Plaintiff di3 not file her legal action timely. In reality the4 Plaintiff filed timely in June of 2010. Plaintiff5 scheduled three TRO hearings. Defendant did not show u6 on June 17 and 23rd and an order to show cause was7 scheduled by Hon Cori Cramin and the case was8 transferred to unlimited jurisdiction and a hearing was9 held on 07.01.2010 with Hon Jeffrey Glass. At

10 07.01.2011 M. Hildreth argued that there is no need to11 hold an expedited hearing prior to General election, as12 there will be a remedy of nullifying the results of the13 primary election, if it was found that fraud was14 committed by the Defendant. The fact that now the15 Defendant 1S claiming that the plaintiff did not act16 timely, shows bad faith on part of the defendant, wh17 is making a flagrantly fraudulent allegation.

19 shows f that as Taitz argued for expedited handling 020 the case, prior to the Certification of the Republican21 primary, Hildreth opposed by stating " ..' The point t22 make 1S that the elections code provides for this23 circumstance where somebody is unhappy or feels that24 the person who was elected did not deserve to be25 elected or somehow instituted fraud on the process. An26 basically what the elections code stipulates 18 that27 the certification goes forward, but that if - If the28



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1 fraud or whatever it lS proven, that a new certificate

3of election is issued. ""+++Butif Ms. Taitz is somehow able to prove up herclaim/ that a new certification of election would beissued to the, quote, unquote, winner of the primarelection. II

"...In other words, there lS no irreparable harm todaas we all sit here. And, you know, she does havelegal remedy that is adequate to her, which is provideby the elections cade" Transcript of 07.01.2010 Motionfor TRO hearing.The court itself stated II We are here on aemergency, not to get it certified. What my questiois? Why is there an emergency? If it is certified, theelections can still be annulled based on fraud."At this time the Plaintiff, Dr. Taitz is seekingexactly the remedy, that was described by the HoJeffrey Glass and by the Defense attorney himself:is seeking to annul the results of the prlmarRepublican California election based on fraud committeby the Defendant candidate Damon Dunn, who knowinglfailed to provide to the registrar and the secretary 0

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state his priorstates Texas and

voter registrationFlorida, where he

from tworegistered asDemocrat.

In his motion for judgment on the merits the Defendantmakes an outrageous statement: "Contestant had an ampletime and opportunity to seek remedy (i.e. to have her


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1 name placed on general Election ballot after the2 Primary Election and Prior to the General election.3 However, Contestant did not pursue her Election Contest

5in a timely fashion and, thus, the matter is now mootand this court no longer maintains jurisdiction"Clearly the defendant and his attorney know that thisstatement is made with malice and represent aegregious fraud on the court. Clearly they know, thatthe Plaintiff filed a timely action, served them,argued in three hearings and Mr. Hildreth, attorney fothe defendants argued that there is no reason to havean expedited hearing. This is not a differentrepresentation of a point of law, this is just aegregious fraud on the court.

F AFFIDAVIT VERIFYING THE COMPLAINT WAS FILEDDefendant states that this court does not have

jurisdiction over this case because the contestant didnot verify her contest. As stated previously, the

complaint includes multiple causes of action, not justElections contest and those causes of action of fraud,elections fraud, voter fraud, nomination fraud do not

require a verified complaint.Additionally, the contestant signed the affidavit anverified her complaint ln a signed affidavit.Plaintiff checked the docket and it shows that 006.23.2010(filed with the court on 06.24.2010) sueaffidavit was filed. Page 9, line 5-7 of the Notice ofMotion and Motion for expedited handling of the case

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16 with section 1600) as required by statute for elections17 contests.18 As previously pointed out, this complaint has multiple19 causes of action, not only elections contest. It

25 Additionally, "Notice of motion and Motion for

1 shows Attachments: Affidavit of Orly Taitz. Complaint.2 This affidavit was forwarded by the Plaintiff to the3 defendant bye-mail, fed ex, certified mail with retur4 receipt, which were attached and scanned. Plaintif5 noticed that the Affidavit was not scanned by the court6 employee in the Laguna Hills court, where the case was7 initially filed or in the Central division, where the8 case was transferred. At any rate the affidavit was9 provided and it is reflected in the pleadings.

10 G CONTESTANT REFERENCED THE ELECTIONS CONTES11 CODE12 Defendant states that this court does not have13 jurisdiction over the case due to the fact that the14 Plaintiff did not reference any section of the15 elections code contained in division 16 (commencin

20 includes the causes of action of common law fraud,21 elections fraud, voter fraud, nomination fraud. This22 court has jurisdiction to hear all of these causes of23 action, regardless of whether the elections contest lS24 even filed.26 Expedited Handling of the Case" filed on 06.24.201027 page 4 line 7 clearly recite section 16 of the28



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1 elections code it recites 16100(a), 16100 (b). 161002 (c). Exhibit 2 id3 Additionally page 4, line 20-22 id states "Based on4 16100 and 13314 Taitz can obtain injunctive relief5 and stay of certification and expedited discover6 pending of the underlining electionsresolution7 contest." Exhibit 28 Yet again on page 1 line 20-224 id sta tes "On June 17,9 2010, Plaintiff Dr. Orly Taitz, ESQ, hereinafter Taitz

10 has filed a complaint for elections contest 16100,11 16161A as well as complaint for Elections Fraud,12 Declaratory Relief againstRelief and Injunctive13 defendant Damon Dunn ... rr It clearly states sections14 16100 and 16161 and Bradley v Perrodin

App.4th 1153, 1167, 131 Cal. Rptr.2d(2003 )106 Cal.402 06.23.201015

16 brief wasand authoritiespoints andmemorandum of17 supplemental to the original brief filed on 06.17.2010.

This brief also clarifies yet again that the electionscontest is separate from other causes of action.

H ELECTION CONTEST WAS FILED TIMELYDefendant Dunn states that this court does not have

1819202122 jurisdiction, because the contest was filed pri.or to23 end of canvassing and not within 5 days shortly afte24 canvassing, however his reading of 16421 is faulty.25 Timeliness of contest provisions are part of the26 Elections Code In order to make sure that the27 candidates do not procrastinate, do not file their28 contests months after the end of the election, whic



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opposition to motion and motion for sanctions ~ 14

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would require reissuing certification of election. Fothis reason the legislature gave the candidates 5 daysafter completion of canvassing to file their contests.Taitz, who never ran for a political office before andid not know when the canva ssi.nq will be officiallover, acted with abundance of caution, she wanted tmake sure the contest will not be late, that it is in aproper court and proper jurisdiction. Indeed, thecontest originally filed in the Laguna Hills divisionwas transferred to Santa Ana division by judge CoriCramin, who initially presided over the case. Whentheresults of the election were announced on TVand newspapers, she filed her contest. At the end of theofficial canva ssi.nq the contest was in place. It wasnot late, it was not untimely. It was there, properlfiled.I. THE FACT THAT DUNN DID NOT ~N THE GENERAL ELECTION

DOES NOT ~ THE LEGAL ACTION AT HAND MOOT.

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20 general election, current case is moot. This assertion21 is without basis. The fact that Dunndid not win, does22 not mean that Taitz would not have won, if she had a23 opportunity to compete in general election.24 Additionally I as stated before, Taitz is seeking not25 only injunctive relief, but also damages for having t26 run against a candidate, who was committing fraud.27 Whether Dunn ultimately won or not, is irrelevant to28 the question of damages.


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1 Lastly, the person, who won the general election,2 Democrat Debra Bowen is leaving her office, as she is3 currently r unna.nq .in special election to replace4 Congresswoman Jane Harman, who is now leaving Congress.5 Position of the Secretary of State will be open. There6 were no other Democrats running in the Primary. If7 Taitz proves that Dunn indeed committed fraud, she8 would be the candidate with the highest number 09 votes, who garnished over half a million votes in the

10 primary.11 According to California Consti tution, the Governor 012 the state can nominate a candidate for the position 013 the Secretary of State. However, an important14 comes to the fore fron t: can Governor en] oy the fruit 015 the poisonous tree the second time around and nominate16 a random person, who did not run for office and did not17 get any votes, when there is a candidate, who ran an18 was precluded from obtaining the position by virtue 019 fraud and by virtue of negligence of current Secretar20 of State and prior Attorney General of California,21 current Governor Jerry Brown?22 During the primary both Debra Bowen and Jerry Brown,23 Attorney General of California at the time, were put 024 notice regarding fraud committed by Damon Dunn.25 complaint Tai tz included as an exhibit a letter from26 prominent law firm of Shell, Fleming and Menge 127 Florida. Attorney Danny L. Kepner sent a complaint t28 the Attorney General of California Jerry Brow



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2requesting investigation of suspected fraud.(wasprovided to the court as an Exhibit 9 of the complaint)In his letter Danny Kepner, ESQ writes "I have see(although I have not retained it) a copy of Mr.California voter registration card, on which he simplleft blank the inquiries about any prz.or registrationto vote. The state where registered and partaffiliation. Mr. Dunn was last registered in Florida,as a Democrat. Failure to answer questions like these,it seems to me, is tantamount to fraud." "In July,2009, Damon Dunn asked the election officials to removethe record of his prior registration (as a Democrat).Under Florida law such a removal was not authorized,and he was so informed. Had he been successful in hisefforts, he would have glven "cover" for hisintentional misrepresentation on his voter registratiocard. He knew he had been registered in Florida as aDemocrat, he did not want anyone else to know."J PRECEDENTS BROUGHT BY THE DEFENSE REFER ONLY TO THEISSUE OF THE ELECTIONS CONTEST AND INJUNCTIVE RELIEF.

THEY DO NOT RELATE TO THE ISSUE OF FRAUD BY THEDEFENDANT.

Precedents brought talk about a garden variety ofelections challenges, such as the fact that the name 0a candidate was omitted from the ballot or supporterscampaiqninq within 100 feet from the polling place.None of the cases quoted are on point, none of therelate to the lssue of fraud, committed by the

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defendant and therefore actually support the assertionsby the Plaintiff. Rideout v. City of Los Angeles (1921)185 Cal. 426, 430 [197 P. 74]. Therein the courtstates: "It is a primary principle of law as applied toelection contests that it is the duty of the court tvalidate the election if possible. That is to say, thelection must be held valid unless plainly illegal.[Citations.] rr (See also Hayes v. Kirkwood (1902) 13Cal. 396 [69 P. 30] (irregularities result of ignorancor inadvertence; election upheld where no harm done)Here the court 1S talking about irregularities stemminfrom ignorance or inadvertence.Yet again Atkinson v. Lorbeer, 111 Cal. 419, 421 [44P. 162]: 'Of course, neither the voters nor those votefor have any control over election officers, and to setaside the vote of a precinct, when there was clearly nofraud or any mistake affecting the result, for mereirregularities occasioned by the ignorance acarelessness of election boards would, rn many cases,be a patent injustice". The courts make a cleadistinction between cases, where there were someinadvertent mistakes and cases where fraud wascommitted, as in the case at hand.K. LETTER FROM AN INVESTIGATOR TO ANOTHER PLAINTIFF IN

A DIFFERENT CASE IS NOT RELEVANT FOR THIS CASEDefendant brings forward a letter written by ainvestigator of the Secretary of State to anotherplaintiff Pamela Barnett. This letter is not relevant

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whether DunnIs registration in FL was active or not,but rather the fact that Dunn committed fraud by notdisclosing on his voter registration card the fact thathe registered in FL and TX.L. DECLARATORY RELIEF IS A PROPER REMEDY IF THE

STATUTORY RELIEF IS UNAVAILABLE.Defense is contradicting itself. Defendantbrings Filarsky v Superior court, stating thatif statutory relief is available, thandeclaratory relief will not be a proper remedy.If the court agrees with the defense and theirassertion that the statutory relief is notavailable due to any of the technical errors ordeficiencies, than declaratory relief would be aproper remedy to fall back on. This is somewhat


1 to this case and is not determinative on the issue of2 fraud. This letter only refers to Dunn's registration3 in FL. It does not relate to his registration in TX.4 Additionally, it only refers to the fact that the5 registration in FL had to be renewed by Dunn, in case6 he decides to vote in FL. At issue in this case, is not7

910111213141516171819202122 similar to quantum meruit or quantum vallebant23 In as an alternative to fall back on if the24 contract fails for one reason or another.25 As a result of the above a statement that this26 court is without jurisdiction, lS completel27 frivolous.28


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This court has jurisdiction to hear the frauclaims, that were not challenged, as well aselections contest cause of action, as challengesto this cause of action were not valid and weremade in bad faith.M. DEFENSE ALLEGATION THAT THE COMPLAINT FAILS

TO STATE THE CAUSE OF ACTION IS TOTALLYFRIVOLOUS AND IN BAD FAITH.

Defense is claiming that the Plaintiff fails to statethe cause of action. this lS a totally frivolousstatement and in bad faith. The causes of action areclearly stated and plead in full. the causes of actioinclude not only elections contest, but also common lafraud, elections fraud, voter fraud.N. WHETHER DUNN SATISFIED THE REQUIREMENTS, IS A

MATTER OF TO BE ASCERTAINDED DURING THEDEPOSITIONS AND DURING TRIAL BY THE JURY.

The defense claims that the defendant Dunn satisfiethe requirements to be on the ballot. This statement isfalse for a number of reasonsa. Plaintiff provided information of fraud committed bthe defendant. fraud invalidates registration annomination.

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b. Most of assertionshaven't been verified,defendant Dunn and hisdeposition.

made are either not true orIn part by the fact thatattorney refuse to submit to



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4 inactive voter registration in Texas in December 2001.5 (Election contest, Exh 2.) Contestant does not allege6 that Dunnwas registered to vote in Texas at any tim7 within twelve months before March 2020, when8 declared his candidacy for California secretary 09 State"

10 What Dunn offers here, is a twisted and perverte11 logic.12 First of all, inactive voter registration can simply be13 activated by one voting in that state, so the fact that14 it is inactive simply states that he did not vote for15 period of time.16 Second of all, the main point of the complaint 1S the1718192021

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1 pll line 26-28 Dunn states "contestantappears to be an investigation reportIne service stating that Dunn had an

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fact that Dunndid not makemandatory disclosure on hisvoter registration card of the fact that he registereto vote In TX and FL. It 1S irrelevant, whether hvoted In TX In the last 12 months or not. The mainpoint 1S that he concedes that he was registered in TX.He does not provide any evidence to deny his voteregistration 1n TX, therefore it is clear based on thepleadings that Dunn indeed committed fraud. Taitz wasrunning her campaign and spent over $50, 000 in totalcompeting against a candidate, who was defrauding thevoters and fellow candidates. She lS entitled todamages at the very least. The fact that the registra



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and Secretary of State were negligent and did not checthe records lS irrelevant to the fact that Dunn wascommitting fraud.Similarly, Dunn did not disclose the fact that heregistered to vote in FL. Dunn says that he was notaffiliated with another party for 12 months prior telection. Dunn wants this court to rule on thepleadings, however there lS nowhere In the pleadingsanything, stating that Dunn was not a member of anotheparty for 12 months before the election.As a matter of fact, the pleadings show his voteregistration from FL, where he is registered asDemocrat. As Dunn refused to submit to deposition anwe did not have trial yet, we do not have informatioshowing us that he severed his ties with the Democratparty. This is a disputed matter of fact, to bedetermined at trial. Even if you were to believe thathe severed his ties to the Democrat partyfit stilldoes not negate fraud, committed by Dunn III noproviding a mandatory disclosure on his voteregistration card of the fact that he registered as aDemocrat in FL.

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23 Dunn goes into a lengthy discussion, stating that Fl24 democrat party is not a California Democrat party.25 Taitz noted that the voter registration card as scanne26 by the court looks smaller than the original. Taitz27 provides as exhibit 3 actual size card.28


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1


2Paragraph 16 states; "if you registered to vote before,fill out below: first name, middle initial, last name,Previous address, where you were registeredstate zip Previous county Political party (if any)".(emphasis added). Dunn is a grown up man, a collegegraduate, who ran for second most important position lthe state. What is he saying in his pleadings? Is hesaying that he did not understand the mearn.nq of theword "State"? He did not understand the meaning of thewords "Political Party"? It did not state politicalparty of Ca. It did not state don't feel out politicalparty in FL. It clearly stated that one needsprovide the state, where he registered before and partaffiliation.Incidently, he understood the meaning of the warparty, when he marked in paragraph 14 "Republicanparty". He understood the meaning of the word state inparagraph 5. So, what happened to him, when he reacheparagraph 16? He no longer understood simple English?He suddenly suffered severe brain lnJury betweeparagraph 14 on this simple form and paragraph 16?This shows how frivolous the motion is. It shows thatthis motion was filed in bad faith to simply waste thetime of the Plaintiff and postpone the deposition.o. THE FACT THAT OTHER NOMINATORS SIGNED THE N0M7NATIONDOES NOT NEGATE THE FACT THAT MR. AND MRS. LINTON DIDNOT SIGN THE NOMINATION AND FRAUD ~S C~TTED IN

NOMINATION PROCESS.

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1 P14 'li:C Dunn states that other nominators actuall2 signed the nomination and there was no fraud there.3 First of all that 1S not evident on the pleadings.4 Additionally, even if other nominators really signe5 the nomination and fraud was not committed there,6 does not negate the fact that fraud was committed i7 relation to Mr. and Mrs Linton, who are stating that8 they did not sign the nomination.9 ~D OF THE MOTION IS TOTALLY FRIVOLOUS1Q What Dunn rs doing in paragraph 0 presents the sam11 twisted logic, whereby he simply throws out the all the12 causes of action relating to fraud, elections fraud,13 voter fraud, nomination fraud. He arbitrarily an14 unilaterally decides that the complaint will be limite15 only to the first cause of action, Elections16 and he states that elections contest includes onl17 section 16101 of the code. Yet again, the complaint18 includes multiple causes of action, not only elections19 contest, therefore the argument 1n S [ 0 1S of no value20 and frivolous.21 ~ E IS FRIVOLUS22 paragraph E is frivolous, as it simply rehashes pri.o23 paragraphs and claims that under CCP 438(c) the action24 is moot and no longer asserts the causes of action25 under which relief can be granted. As state26 previously, Taitz spent $40,000 of her own savings an27 over $10,000 donated by her supporters to run against28 the candidate I who was committing fraud. While this



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12 Defense refers In it's motion only to Dunn's

1 point might be moot for Dunn, it ls clearly not moot2 for Taitz. additionally, secretary of State of Ca has3 announced that she is running for Congress, which means4 that the position will be open. Either injunctive5 relief or award of damages or both will be proper. As6 stated previously, Dunn conveniently talks only about7 elections contest in ~E, though this complaint contains8 other causes of action, not only elections contest.9 R. FACTUAL BACKGROUND BY THE DEFENSE CONTAINS A

10 FRAUDULENT STATEMENT REGARDING DUNN'S FORMER VOTER11 REGISTRATION.

13 registraion in FL. It completely omits the fact that14 Dunn was also registered to vote in TX. All of the15 argument by the defense is related to FL only. For this16 reason alone motion cannot possibly be granted as T17 registration lS a disputed fact, that needs to18 resolved at trial. Additionally, whether Dunn committe19 fraud by not disclosing his FL registration, is to be20 determined at trial.21 S. THE ONLY RULING THAT CAN BE ~E ON THE22 PLEADINGS, IS THAT THE DEFENDANT INDEED COMMITTED

FRAUD.2324 While the defense lS seeking a decision on the2526

pleadings, the only decision that can be made, is thatthe defendant indeed committed fraud. The defendantdoes not provide any evidence that would contradict thefact that he registered in two other states and teat he

2728



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1 did not include this information In the require2 mandatory disclosure section of his voter registratio3 card. He did not negate the fact that he contacted the4 registrar In FL and asked to delete from the data base5 his voter registration from FL. He is just say i.nq that6 his FL registration was no longer good. His7 impossibility to vote In FL does not negate his frame8 of mind and actions. As such the on1y ru1ing on th9 p1eadings can be in favor of the p1aintiff.

1011 Wherefore the plaintiff moves this honorable court to

1. deny the motion for judgment on the pleadings or lthe alternative allow the plaintiff the leave ofto file a first amended complaint to cure minotechnical errors in the complaint, that might be faunvalid errors by the court2. award the plaintiffs reasonable fees for the timespent on research and drafting of this opposition

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151617181920212223 Orly Taitz24 29839 Santa Margarita pkwy,25 ste 100, RSM,CA926882627 Certificate of service28



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I, Orly Taitz, attest that a true and correct copy ofthe above motion was served on the defendant's attorneyBrian Hildreth via e-mail and/or first class mailand/or fax on 03.01.2011

3

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5 orl~~-298 9 SantaMargarita PkwyRancho SantaMargarita CA 9268867

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EXHIBITEXHIBIT 1 f


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_TAITZ[l]

SUPERIOR COURT OF THE STATE OF CALIFORNIACOUNTY OF ORANGE - CENTRAL JUSTICE CENTER

DE PA RTM EN T C - 33

)))) CASE NO. 30-2010) 00381664))))DEFENDANTS, )---------------------------)

DR. ORLY TAITZ, ESQ.,PLAINTIFF,

VS.DAMON DUNN AND DOES 1 THROUGH 18.

HONORABLE GEOFFREY T. GLASS, JUDGE PRESIDINGREPORTER'S TRANSCRIPT

JULY 1, 2010

AP PE AR AN CES OF COUN SE L:F OR P LA IN TI FF : DR. ORLY TAITZATTORNEY AT LAW

BELL MC ANDREWS & HILTACHKBY: BRIAN T. HILDRETHS PE CI AL A PP EA RA NC E( BY T EL EP HO NE )CHRISTINE L. BELASCO, CSR 6189, RPR, CRROFFI CI AL COUR T R EP ORT ER

F OR D EF EN DA NT :

123

SANTA ANA, CALIFORNIA - THURSDAY, JULY 1, 2010M OR NI NG S ES SI ON

-000-page 1

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_TAITZ[I](THE FOLL OWING PROCEE DINGS WER E HAD I NO PE N C OU RT :)

6 THE COURT: TAITZ VERSUS DUNN.7 MS. TAITZ: YES. GOOD MORNING, YOUR HONOR. I AM ORLY8 TAITZ. I AM THE PLAINTIFF IN THIS CASE.9 MR. HILDRETH: YOUR HONOR, THIS IS BRIAN HILDRETH. I

10 REPRESENT MR. DUNN, AND I AM SPECIALLY APPEARING TODAY. AND11 I APPRECIATE BEING ABLE TO APPEAR VIA COURT CALL.12 THE COURT: ALL RIGHT. YOU ARE SPECIALLY APPEARING? I13 UNDERSTAND AN ANSWER -- MR. DUNN HAS FILED AN ANSWER?14 MR. HILDRETH: WE DID FILE AN ANSWER TO THE ELECTION15 CONTEST. HOWEVER, JUST BASED ON WHAT WAS SUBMITTED FOR16 TODAY, WE'RE A LITTLE UNCLEAR IF THIS IS A NEW ACTION OR17 RELATED TO THE ELECTIONS CONTEST.18 THE COURT: IT LOOKS TO ME LIKE THE SAME CASE NUMBER.19 MR. HILDRETH: OKAY. I GUESS THE ONLY OTHER REASON TO20 SPECIALLY APPEAR WOULD BE THAT THERE WAS INADEQUATE NOTICE21 FOR -- FOR THIS ACTION. WE DIDN'T RECEIVE NOTICE UNTIL22 YESTERDAY, 11:23 A.M. YEAH, YESTERDAY, 11:23, WHICH IS NOT23 THE APPR OPRIAT E AMOUN T OF TIME.24 THE COURT: THE CERTIFICATE OF SERVICE THAT YOU FILED,25 MS. TAITZ, SAYS THAT YOU SENT NOTICE ON JUNE 30 BY E-MAIL .26 BUT BECAUSE OF THE TIMEFRAME, WE REQUIRE NOTICE BY NINE

CHR ISTINE L. BE LASCO, CSR 6189, RPR, CRR

1 O'CLOCK. SO I HAVE TO KNOW EXACTLY WHEN YOU SENT THE2 E-MAIL.3 MS. TAITZ: ACTUALLY, ONLY I SENT AN E-MAIL. I CALLED4 MR. HILDRETH'S OFFICE THE DAY BEFORE ON TUESDAY --5 THE COURT: YOUR CERTIFICATE OF SERVICE SAYS YOU SENT6 IT BY E-MAIL. IF YOU DID IT IN SOME OTHER FASHION, I WOULD7 EXPECT THAT IN A DECLARATION FROM YOU. I CAN'T ACCEPT YOURPage 2

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__TAITZ[lJ8 TESTIMONY ABOUT THAT. I AM NOT HERE TO GET ANY TESTIMONY.9 THIS IS AN EX PARTE HEARING. IT IS ALL IN THE10 PAPERS. YOU HAVE TO SWEAR UNDER PENALTY OF PERJURY THAT YOU11 GAVE THEM NOTICE AND TO DO IT BY WAY OF DECLARATION. THAT'S12 ALL IN THE RULES, THE CALIFORNIA RULES OF COURT. AND I13 EXPECT YOU TO FOLLOW THEM.14 SO THAT -- THERE IS A PROBLEM WITH REGARD TO THAT.15 LET'S -- LET'S HOLD OFF ON THAT TO SEE IF THERE ARE OTHER16 ISSUES THAT WE CAN RESOLVE. BUT I -- I HAVE GOT A17 CERTIFICATE OF SERVICE. WHAT I EXPECT IS COMPLIANCE WITH18 THE RULES THAT SAY, IF YOU'RE GOING TO GIVE NOTICE, YOU GIVE19 ME A DECLARATION.20 I CALLED THEM ON JUNE 29. I TALKED TO SO AND SO.21 I TOLD THEM I WAS GOING TO BE HERE AT NINE O'CLOCK ON22 JULY 1ST. THEY SAID THEY WERE GOING TO TRY TO APPEAR BY23 PHONE. OR THEY SAID WHATEVER THEY SAID. THAT'S WHAT I24 EXPECT. WHAT I GOT WAS THAT YOU SENT A TRUE AND CORRECT25 COpy SOMETIME YESTERDAY BY E-MAIL.26 AND HE IS SAYING THAT IS NOT SUFFICIENT. AND I

CHRISTINE L. BELASCO, CSR 6189, RPR, CRR 41 WOULD HAVE TO AGREE. THAT IS NOT SUFFICIENT TO SHOW THERE2 I S NOT IC E.3456789

MS. TAITZ: THAT'S OKAY, YOUR HONOR. YOU'RE RIGHT.THE DEFENDANT'S ATTORNEYS HAVE FILED AN ANSWER TO THECOMPLAINT.

THE COURT:I NT ER RU PT Y OU . BUT -- I AM SORRY. I DON'T MEAN TOBUT FILING AN ANSWER TO THE COMPLAINT IS NOTSUFFICIENT TO MAKE THEM COME IN HERE TODAY FOR -- TO HEART HI S M OT IO N.

10 MR. HILDRETH: YOUR HONOR, I WILL SAY ALSO THAT THIS ISPage 3


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__TAITZ[I]11 THE THIRD ATTEMPT THAT PLAINTIFF HAS MADE IN AN EX PARTE12 APPLICATION. ONE HAPPENED ON JUNE 24, WHICH WAS LAST13 THURSDAY. ANOTHER HAPPENED ON THIS MONDAY, THE 28TH. AND14 WE DIDN'T RECEIVE NOTICE OF EITHER OF THOSE.15 MS. TAITZ: THEY WEREN'T THE ATTORNEYS ON THE CASE.16 MR. HILDRETH IS NOT B EI NG H ON ES T.17 THE COURT: HOLD ON A SECOND. MR. HILDRETH?18 MR. HILDRETH: YES, YOUR HONOR.19 THE COURT: I'M NOT CONCERNED ABOUT WHETHER YOU GOT20 NOTICE FOR ANY OTHER ACTIONS. ALL RIGHT? THAT -- EITHER21 YOU GOT NOTICE ON THIS ONE OR YOU DIDN'T. BUT I DO WANT TO22 SAY TO MS. TAITZ --23 MS. TAITZ: MY UNDERSTANDING WAS --24 THE COURT: I'M SORRY, MS. TAITZ. I WASN'T FINISHED25 SPEAKING. I WANTED TO TELL YOU, MS. TAITZ, THE RULES26 REGARDING EX PARTE APPLICATION ARE RULE 3.1200 AND THROUGH

CHRISTINE L. BELASCO, CSR 6189, RPR, CRR 51 3.1207. COUNSEL HAS SAID AND MR. HILDRETH HAS SAID THAT2 3.-- WELL, THAT THERE HAS BEEN A PREVIOUS APPLICATION.3 RULE 3.1202 SAYS IF AN EX PARTE APPLICATION HAS4 BEEN REFUSED IN WHOLE OR IN PART, ANY SUBSEQUENT APPLICATION5 OF THE SAME CHARACTER OR FOR THE SAME RELIEF, ALTHOUGH MADE6 UPON AN ALLEGED DIFFERENT STATE OF FACTS, MUST INCLUDE A7 FULL DISCLOSURE OF ALL PREVIOUS APPLICATIONS AND WHAT THE8 COURT DID IN THAT CASE.9 SO I AM JUST IDENTIFYING ISSUES AT THIS POINT. I10 AM NOT RESOLVING ANYTHING. BUT MR. HILDRETH SAID YOU'VE11 MADE TWO OTHER APPLICATIONS12 MS. TAITZ: MAY I RESPOND?13 THE COURT: I'M SORRY. MR. HILDRETH SAID YOU MADE TWO14 OTHER APPLICATIONS. IF YOU HAVE AND ASKED FOR THE SAME

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__TAITZ[IJ15 RELIEF YOU'RE ASKING HERE. YOU HAVE TO, BY RULE, IDENTIFY16 THEM AND DISCLOSE THEM.17 SO I NEED THAT IN YOUR PAPERS AS WELL. BECAUSE I18 NEED TO KNOW IF YOU HAVE ASKED ANOTHER COURT FOR THE SAME19 RELIEF, EVEN IF THE COURT SAID I AM NOT -- I DON'T HAVE20 JURISDICTION TO DO IT, I AM TRANSFERRING IT. IF YOU SET21 IF YOU HAVE SET ANOTHER EX PARTE MOTION TO ASK FOR THE SAME22 THING, YOU HAVE TO DISCLOSE THAT TO ME IN THE PAPERWORK.23 IT IS IN THE RULES. IT ISN'T ME. IT IS WHAT THE24 RULES SAY.25 MS. TAITZ: I UNDERSTAND. MAY I RESPOND, YOUR HONOR?26 THE COURT: ALL RIGHT.

CHRISTINE L. BELASCO, CSR 6189, RPR, CRR 61 MS. TAITZ: MR. HILDRETH IS STATING THAT I MADE PRIOR2 EX PARTE APPLICATIONS AND THEY DID NOT GET PROPER NOTICE.3 IN REALITY, THEY WEREN'T ATTORNEYS ON THE RECORD. SO I4 COULD NOT NOTICE THEM BECAUSE THEY WEREN'T ATTORNEYS ON THE5 RECORD.6 MR. DUNN HAS NOT HIRED MR. HILDRETH UNTIL MONDAY.7 AND, AS A MATTER OF FACT, THEY NEVER SENT ME ANY NOTICE, OR8 THEY NEVER SENT THEIR ANSWER TO ME. I NEVER RECEIVED IT. I9 WENT TO COURT ON TUESDAY JUST BECAUSE I FOUND ON THE

10 INTERNET THEIR ANSWER, THE ANSWER WAS FILED. BUT I NEVER11 GOT THE ANSWER.12 I WAS TOLD THAT THEIR MESSENGER APPEARED IN LAGUNA13 HILLS COURTROOM MONDAY AT FOUR O'CLOCK AND WERE TOLD THE14 CASE WAS TRANSFERRED HERE. SO THEY FILED IT IN THIS -- IN15 THIS DIVISION. HOWEVER, THEY DID NOT SERVE ME, NOT BY MAIL,16 NOT BY FEDERAL EXPRESS, NOT BY ANY OTHER MEANS.17 I CAME TO THIS DIVISION, AND I -- I SPENT THE

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18 __TAITZ[l]WHOLE DAY ON TUESDAY TRYING TO FIND THEIR ANSWER BECAUSE19 THEY DID NOT SERVE ME WITH THEIR ANSWER. THERE WAS NO20 ANSWER FILED HERE. SO I ACTUALLY CALLED ANOTHER PLAINTIFF21 WHO FILED ANOTHER LAWSUIT AGAINST MR. DUNN TO GET THEIR22 P HON E N UM BE R.23 AND I CALLED THEIR LAW FIRM AND STATED ARE YOU, BY24 CHANCE. REPRESENTING MR. DUNN IN THIS CASE AS WELL? PLEASE25 CALL ME ASAP. I CALLED. I TALKED TO THEIR SECRETARY ON26 TUESDAY. THEY NEVER CALLED ME. AN E-MAIL CAME FROM THEM

CHRISTINE L. BELASCO, CSR 6189. RPR, CRR

1 FROM SOMEBODY BY THE NAME OF DIAZ.2 I HA VE A HU ND RE D T HOUSA ND E -MA IL SIN MY BOX.B Y3 CHANCE, I OPENED THIS E-MAIL FROM SOMEBODY BY THE NAME DIAZ,4 AND IT HAPPENED TO BE FROM MR. HILDRETH. I WOULDN'T HAVE5 EVEN KNOWN THAT IT WAS FROM THEM. THAT IS NOT THE WAY TO6 C ON DU CT B US IN ES S.7 THE COURT: OKAY. MS. TAITZ, WE'RE NOT HERE TO FIGURE8 OUT WHO REPRESENTS MR. DUNN. WE'RE NOT HERE TO FIGURE OUT9 WHY THEY HAVEN'T FILED AN ANSWER. WE'RE HERE BECAUSE YOU

10 FILED AN EX PARTE MOTION.11 NOW, I DON'T NEED TO HEAR ABOUT ALL OF THAT STUFF.12 I DID NOTE IN WHAT YOU JUST TOLD ME THAT YOU'REI WILL13 SAYING YOU GOT A NOTE -- AN E-MAIL FROM HILDRETH, BUT YOU14 DIDN'T -- YOU ALMOST DIDNrT OPEN IT BECAUSE YOU GET SO MANY15 THOUSANDS OF E-MAILS. YET YOUR CERTIFICATE OF SERVICE SAYS16 YOU E-MAILED IT TO THEM.17 NOW, I ASSUME THAT WHEN YOU E-MAILED IT TO THEM,18 THAT YOU ASSUMED THAT THEY WOULD OPEN IT. I THINK THEY GOT19 THE SAME RIGHT. IF THEY SEND YOU SOMETHING, THEy'RE GOING20 TO ASSUME YOU OPENED IT. NOW, THAT MAY NOT BE TRUE.21 BUT THAT IS WHY I NEED A DECLARATION FROM YOU ASPage 6

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_TAITZ[1J22 TO HOW YOU MADE SERVICE. YOU CALLED THEM UP. YOU TOLD THEM23 YOU WERE BRINGING THE EX PARTE. YOU E-MAILED THE TEXT OF24 THE EX PARTE OR WHATEVER YOU E-MAILED THE NEXT DAY. HE IS25 SAYING HE DIDN'T GET THAT UNTIL 11:31 IN THE MORNING OR26 10:31 IN THE MORNING. IT HAS TO BE BY NINE O'CLOCK.

CHRISTINE L. BELASCO, CSR 6189, RPR, eRR 81 I AM JUST IDENTIFYING THE ISSUES. BUT YOU HAVE2 NOT ADDRESSED WHAT I ASKED YOU ABOUT, WHICH IS RULE 3.12023 SAYS IF YOU HAVE MADE AN APPLICATION TO SOME OTHER JUDGE FOR4 THE SAME RELIEF, OF THE SAME CHARACTER -- OR AN APPLICATION5 OF THE SAME CHARACTER, EVEN IF THIS IS ON COMPLETELY6 DIFFERENT FACTS. I NEED TO KNOW THAT.7 AND I NEED TO KNOW WHAT THE COURT DID. BECAUSE8 THIS IS EX PARTE. THIS IS AN EMERGENCY --9 MS. TAITZ: I--10 THE COURT: I'M SORRY. IF YOU DON'T WANT ME TO FINISH11 TALKING. I WON'T. I WILL JUST RULE ON YOUR MOTION. DO YOU12 WANT TO TALK, OR DO YOU WANT ME TO TALK?13 MS. TAITZ: I AM SORRY, YOUR HONOR.14 THE COURT: OKAY. IF YOU -- I JUST NEED TO KNOW HAVE15 YOU MADE THE PREVIOUS APPLICATIONS OR NOT. AND IT SAYS IT16 IS IN THERE.17 NOW, I WILL ALSO SAY I THINK YOU HAVE "ESQ" --18 THIS IS A SIDE MATTER, NOT THAT -- MAYBE NOT -- NOT THAT19 IMPORTANT FOR THIS MOTION. BUT I JUST WANT TO MAKE SURE.20 YOU SAY "ESQ." ARE YOU A MEMBER OF THE BAR?21 MS. TAITZ: YES.22 THE COURT: THE RULES REQUIRE THAT A MEMBER OF THE BAR23 WHO SUBMITS PAPERS TO THE COURT PUT THEIR BAR NUMBER ON IT.24 THE REASON -- AND YOU CAN LOOK AT THE RULES. I DON'T KNOW

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_TAITZ[1]25 IF THEY APPLY TO ATTORNEYS REPRESENTING THEMSELVES. BUT r26 THINK THEY DO. BECAUSE THAT IS THE WAY THAT I WOULD REPORT

CHRISTINE L. BELASCO, CSR 6189, RPR, CRR 9ANY ACTIVITIES OF A BAR MEMBER TO THE STATE BAR.

SO I AM JUST SAYING THAT I -- IF YOU'RE ANATTORNEY, r NEED TO KNOW THAT YOU'RE AN ATTORNEY. AND ASTATE BAR NUMBER IS THE WAY TO DO IT. LOOK AT THE RULESWITH REGARD TO PUTTING A STATE BAR NUMBER ON THERE. IT MAYBE THAT YOU DON'T HAVE TO IF YOU'RE REPRESENTING YOURSELF.

BUT IF -- IF SOMEBODY IS REPRESENTING THEMSELF ANDTHEy'RE AN ATTORNEY, THEy'RE STILL BOUND BY THE CODES OFETHICS OF ATTORNEYS. SO THAT'S WHY WE HAVE THOSE RULES.

SO, MR. HILDRETH, YOU'RE SAYING WE GOT TO DO THISTOMORROW, OR ARE YOU WILLING TO GO AHEAD TODAY?

MR. HILDRETH: WE CAN GO FORWARD, YOUR HONOR. WE'REPREPARED TO DISCUSS THE MERITS.

THE COURT: ONE OF THE PROBLEMS, MS. TAITZ, WITH THENOTICE OF MOTION IS IT SAYS -- YOUR NOTICE OF MOTION SAYSTHERE IS GOING TO BE AN EX PARTE HEARING, AND T~EN YOU GIVEME THE MOTION AND THE POINTS AND AUTHORITIES AND EVERYTHINGELSE TOGETHER.

so r AM NOT QUITE SURE. AS I UNDERSTAND IT --WELL, YOUR PRAYER FOR RELIEF IS YOU WANT AN EXPEDITED TRIALON YOUR COMPLAINT. YOUR BASIS FOR THAT IS CODE OF CIVILPROCEDURE NUMBER 44.

YOU ALSO WANT TO PRESERVE THE STATUS QUO TO STAYTHE REGISTRATION OF VOTES BY THE COUNTY REGISTRAR PENDINGRESOLUTION OF THE TRIAL, THAT IS, SO THEY DON'T REGISTER THEVOTES, AND ALSO ISSUE A PRELIMINARY INJUNCTION, NOT EVEN A

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__TAITZ[l]T EM POR AR Y R ES TRA IN ING OR DE R, A PR EL IMI NA RY IN JU NCT IONDIRECTING THE REGISTRAR OF VOTERS -- I ASSUME THAT'S THEORANGE COUNTY REGISTRAR OF VOTERS, BUT IT DOESN'T SAY INYOUR PAPERS -- NOT TO CERTIFY THE VOTES IN THE ELECTIONIN THE PRIMARY ELECTION FOR THE SECRETARY OF STATE.

HAVE I GOT THAT RIGHT?MS. TAITZ: WELL, MOSTLY I HAVE WRITTEN DOWN REGISTRARS

IN PLURAL, MEANING ALL OF THE REGISTRARS. AND I WILL --THE COURT:M S. TA IT Z:

ALL OF THE REGISTRARS FOR ALL THE COUNTIES?I HAVE TO BECAUSE THIS IS AN ELECTION FOR

SECRETARY OF STATE AS -- I DON'T KNOW IF YOUR HONOR HAD ANOPPORTUNITY TO READ THE ACTUAL COMPLAINT AND ALL THEEXHIBITS. BUT THIS IS A COMPLAINT FOR FRAUD COMMITTED BYMR. DUNN IN HIS VOTER REGISTRATION AND NOMINATION --

THE COURT: I AM SORRY. I UNDERSTAND ALL OF THAT. BUTYOU HAVE TO ANSWER MY QUESTION. HAVE I STATED WHAT RELIEF

17 YOU WANT CORRECTLY?18 MS. TAITZ: YES. THE ONLY -- THE ONLY ISSUE IS IT IS19 NOT ONLY ORANGE COUNTY REGISTRAR. I MEAN, I CAN SEND FIRST20 TO ORANGE COUNTY REGISTRAR. BUT IT NEEDS -- I HAVE WRITTEN21 THE REGISTRARS BECAUSE I NEED TO SEND A COpy TO EVERY22 REGISTRAR, ALL OF THEM, NOW FINALIZING REGISTRATION AND23 CERTIFICATION OF VOTES IN THIS PRIMARY ELECTION.24 AND THEY NEED TO BE APPRISED OF THE FACT THAT25 THERE IS AN ISSUE, A PENDING ISSUE. AND BASED ON A26 PRECEDENT CASE OF MC KINNEY V. CITY OF SAN DIEGO WHERE A

CHRISTINE L. BELASCO, CSR 6189, RPR, CRR 111 SIMILAR STAY WAS ISSUED BY THE COURT OF APPEALS RIGHT HERE2 IN SANTA ANA IN A SIMILAR CASE OF ELECTIONS FRAUD, I AM3 ASKING FOR A STAY OF CERTIFICATION OF VOTES FOR MR. DUNN AND

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_TAITZ[l]4 STAY AND PRELIMINARY INJUNCTION PENDING RESOLUTION OF THE5 MATTER AT TRIAL.6 THE COURT: ALL RIGHT. OTHER THAN THE MC KINNEY7 CASE8 MS. TAITZ: YES.9 THE COURT: -- WHAT -- LET ME BACK UP A SECOND. YOU'RE

10 NOT -- YOU DON'T INDICATE ANYWHERE THAT ANYBODY WON THE11 ELECTION. SO YOU'RE SAYING WE'RE AT THE PROCESS WHERE THE12 ELECTION -- THE VOTES HAVE ALL BEEN CAST. BUT BEFORE WE13 KNOW THE RESULTS OF THE ELECTION, BEFORE THEy'RE OFFICIAL,14 YOU WANT ME TO STOP IT?15 MS. TAITZ: TO STAY THE CERTIFICATION, YES.16 CERTIFICATION.17 THE COURT: WELL, WHAT IF YOU WIN THE ELECTION? WHAT18 IF THE CERTIFICATION IS YOU WIN?19 MS. TAITZ: WELL, AS OF NOW, MR. DUNN HAS MORE VOTES.20 THE COURT: NO. REGISTRAR HASN'T CERTIFIED THEM. HOW21 DO WE KNOW THAT?22 MS. TAITZ: I AM GOING BY THE SEMI-OFFICIAL RESULTS23 POSTED BY THE SECRETARY OF STATE OF CALIFORNIA, DEBRA BOWEN.24 THE COURT: THAT IS NOT IN YOUR PAPERS, THAT YOU THINK25 HE HAS GOT MORE VOTES. I -- THE CLOSEST I SAW WAS IN YOUR26 COMPLAINT, YOU GOT 440,000 VOTES.

CHRISTINE L. BELASCO, CSR 6189, RPR, CRR 121 MS. TAITZ: WELL, NOW IT IS ABOUT A HALF A MILLION2 VOTES.3 THE COURT: OKAY. WELL, THAT HAS CHANGED, THEN. I4 DON'T KNOW. I DON'T KNOW. WHAT IF THE REGISTRARS WHAT5 IF, AT THE END OF THE DAY, THEY SAY YOU WIN?6 MS. TAITZ: NO, THAT IS NOT POSSIBLE.7 THE COURT: WELL, THEN, WHAT DIFFERENCE DOES IT MAKE IFpage 10


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__TAITZ[I]8 I HOLD UP THE CERTIFICATION OR NOT?9 MS. TAITZ: BECAUSE THE VOTES -- EVEN THOUGH MR. DUNN

10 GOT MORE VOTES, THOSE VOTES WERE OBTAINED BY VIRTUE OF11 FRAUD--12 THE COURT: I UNDERSTAND THAT. BUT I DON'T THINK YOU13 ANSWERED MY QUESTION. WHAT DIFFERENCE DOES IT MAKE TO YOUR14 LAWSUIT TO -- IN EITHER CASE, I HAVE TO SAY THE VOTES DIDN'T15 COUNT. SO WHETHER THE -- BECAUSE HE IS NOT ACTUALLY ELECTED16 TO AN OFFICE. ALL HE IS ENTITLED TO DO IS RUN IN THE17 G EN ER AL E LE CT IO N.18 SO I AM NOT -- IT IS NOT A QUESTION OF HIM GETTING19 AN OFFICE. IT IS HIM HAVING AN OPPORTUNITY TO RUN FOR AN20 OFFICE. AND I AM NOT SURE WHAT CHANGES IF I LET THE21 CERTIFICATION GO THROUGH?22 MS. TAITZ: IF I MAY EXPLAIN, I AM THE CONTENDER OF --23 I AM THE OPPONENT OF MR. DUNN. IF THE ELECTION IS24 CERTIFIED. THEN I WILL BE PREVENTED FROM PUTTING MY NAME ON25 THE BALLOT AS A CANDIDATE. I CANNOT PUT MY STATEMENT. I26 CANNOT PUT MY -- MY NAME WILL NOT BE ON THE BALLOT. ANDCHRISTINE L. BELASCO, CSR 6189, RPR, CRR 131 T HE RE FOR E, VOT ER S - -2 THE COURT: I AM SORRY. THEREFORE, VOTERS WILL WHAT?3 MS. TAITZ: WILL BE PREVENTED FROM VOTING IN GENERAL4 ELECTION FOR A QUALIFIED CANDIDATE, WHICH WOULD BE ME.5 THE COURT: OKAY. IF I GRANT YOUR RELIEF AND SAY TO6 ALL THE REGISTRARS IN ALL THE COUNTIES OF CALIFORNIA -- AND,7 BY THE WAY, YOU WOULD HAVE TO TELL ME. I CAN'T JUST SAY8 E VE RY R EG IS TR AR E VE RY WH ER E.9 MS. TAITZ; I WILL --

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__TAITZ[IJ11 THE REGISTRARS DO NOT COUNT THE VOTES IN THIS -- DO NOT12 CERTIFY THE VOTES IN THIS ELECTION, HOW WOULD YOU BE ABLE TO13 GO INTO THE GENERAL ELECTION? WHAT WOULD HAPPEN? THERE14 WOULD BE NO CANDIDATE, PERIOD. BECAUSE THERE IS NO -- THE15 E LE CT ION I S S US PE ND ED .16 THERE IS NO WINNER FOR THE ELECTION. AND UNTIL WE17 DECIDE -- UNTIL WE DECIDE WHETHER THE ELECTION -- WHETHER18 THE ELECTION -- THE VOTING SHOULD BE ANNULLED OR NOT. SO19 YOUR BASIS FOR SAYING YOU WANT TO HOLD UP THE REGISTRATION20 IS SO THAT THE VOTERS KNOW THAT YOU'RE GOING TO BE A21 CANDIDATE. BUT THAT WOULD NOT BE THE RELIEF. THE RELIEF IS22 NOT TO PUT YOU ON THE BALLOT.23 MS. TAITZ: BY DEFAULT, AS YOU CAN UNDERSTAND, I WILL24 BE ON THE BALLOT. BUT INDEFINITELY, SOMEBODY WHO IS A25 LIFE-LONG DEMOCRAT AND WHO GOT ON THE PRIMARY BALLOT BY26 FRAUD WILL NOT BE ON THAT BALLOT.

CHRISTINE L. BELASCO, CSR 6189, RPR, CRR 141 THE COURT: I AM SORRY. MC KINNEY DOESN'T SAY THAT.2 NEITHER DOES THE3 MS. TAITZ: ACTUALLY4 THE COURT: THE LAW WITH REGARD TO THIS IS CLEAR. IT5 IS WRONG IF I WERE TO SAY MR. DUNN -- THE VOTES FOR MR. DUNN6 DON'T COUNT. I DON'T GIVE THE ELECTION TO YOU. IT IS A NEW7 ELECTION.8 MR. HILDRETH: YOUR HONOR, MAY I SAY SOMETHING HERE?9 THE COURT: NO. HOLD ON A SECOND.

10 MR. HILDRETH: OKAY.11 MS. TAITZ: ACTUALLY, THE PRECEDING CASES OF GILMORE V.12 JORDAN AND POWER V. JORDAN AND THOSE ARE THE CASES THAT I13 QUOTED SPECIFICALLY STATED THAT THE COURT -- THE DISTRICT14 COURT WAS CORRECT IN INSTRUCTING THE REGISTRARS -- IN THATpage 12


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__TAITZ[1]15 CASE, IT WAS SAN FRANCISCO AND SAN FRANCISCO COUNTY -- NOT16 TO CERTIFY THE VOTES. AND THAT WAS FOR MR. POWER AND17 MR. GILMORE.18 THAT'S THE OPPOSITE. EXACTLY THEY WERE TOLD DON'T19 CERTIFY THE VOTES BECAUSE FRAUD WAS COMMITTED. THAT IS20 EXACTLY CASE ON POINT, AND THAT'S WHAT I AM ASKING.21 THE COURT: THAT'S 1934. AND THAT RELIES ON AN OLDER22 CASE. WHAT I AM TALKING ABOUT -- AND YOU DIDN'T CITE IT.23 IT IS A 2006 CASE. WELL, IT IS LATER THAN THAT. I WOULD24 HAVE TO REMEMBER. YOU DIDN'T CITE IT, BUT I FOUND IT IN25 CONNECTION WITH MC KINNEY. I'LL HAVE TO FIND IT FOR YOU26 LATER.

CHRISTINE L. BELASCO, CSR 6189, RPR, CRR 151 MS. TAITZ: YOUR HONOR --2 THE COURT: HOLD ON A SECOND. IT WAS THIS DISTRICT WHO3 SAID YOU DON'T GIVE THE VOTE -- YOU DON'T GIVE THE ELECTION4 TO THE RUNNERS UP. WE'VE ALREADY HAD THE VOTING. THE ISSUE5 OF THE VOTING BEING CERTIFIED, HOLDING UP THE CERTIFICATION6 DOES NOT GIVE THE ELECTION TO THE RUNNER-UP.7 MS. TAITZ: MAY I RESPOND?8 THE COURT: YEAH.9 MS. TAITZ: YOUR HONOR, I AM NOT -- I DID NOT ASK IN MY

10 PRAYER OF RELIEF FOR YOU TO CERTIFY ME AS A WINNER. I DID11 NOT ASK YOU FOR THAT. ALL I ASKED IS FOR YOU TO FOLLOW THE12 PRECEDENCE OF MC KINNEY WHERE RIGHT HERE ACROSS THE STREET,13 FOURTH--14 THE COURT: I UNDERSTAND WHAT DID IT. I UNDERSTAND THE15 CASE. NOW, LET ME TELL YOU THIS, DR. TAITZ. YOU TOLD ME16 THE VOTERS NEED TO KNOW THAT YOU'RE THE PROPER PARTY. THIS17 RELIEF THAT YOU'RE SUGGESTING YOU JUST TOLD ME WILL NOT DO

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__TAITZ[IJ18 THAT.19 MS. T AITZ; MAY r CORRECT MYSELF, YOUR HONOR? THE20 VOTERS NEED TO KNOW THAT MR. DUNN WAS NOT A PROPER PARTY,21 THAT THERE IS A PROBLEM WITH HIS -- WITH HIS CERTIFICATION.22 THE COURT: WHAT DO YOU MEAN THE VOTERS NEED TO KNOW23 THAT?24 MS. TAITZ: BECAUSE THE VOTERS WILL BE VOTING IN25 GENERAL ELECTION. I MEAN, IF THAT WOULD BE THE CASE, THEN26 ANYBODY CAN COMMIT ANY FRAUD AND NOTHING WILL BE DONE.

CHRISTINE L. BELASCO, CSR 6189, RPR, eRR 16

1 THE COURT: NO. NO. NO. YOU DON'T UNDERSTAND. WE'RE2 HERE ON AN EMERGENCY, NOT TO GET IT CERTIFIED. WHAT MY3 QUESTION IS, WHY IS THERE AN EMERGENCY? IF IT IS CERTIFIED,4 THE ELECTION CAN STILL BE ANNULLED BASED UPON FRAUD. THAT'S5 WHAT THE CASES YOU CITED TOLD ME.6 WHY DO I HAVE TO STOP THE CERTIFICATION? BECAUSE7 THE CERTIFICATION TELLS US THAT THE NUMBER OF VOTES, WHETHER8 THEy'RE COMMITTED WHETHER THEy'RE OBTAINED WITH FRAUD OR9 NOT, ARE X, Y AND Z, WHATEVER THEY ARE. AND PRESUMABLY

10 YOU'RE WILLING TO ADMIT THAT YOU HAVE LESS OF THE VOTES THAN11 HE DOES. BUT THAT'S NOT CLEAR.12 OKAY. THEY CERTIFY IT. YOU STILL HAVE YOUR CAUSE13 OF ACTION TO ANNUL IT. YOU HAVE THE SAME CAUSE OF ACTION14 THAT YOU HAVE NOW. YOUR CAUSE OF ACTION IS TO ANNUL THE15 VOTES, NOT THAT THE CERTIFICATION PROCESS IS SOMEWHAT16 INFECTED. SO WHAT I AM SAYING IS WHAT DIFFERENCE DOES IT17 MAKE IN THE LONG TERM OR EVEN IN THE NEAR SHORT TERM WHETHER18 THE VOTES ARE CERTIFIED BY THE REGISTRARS OR NOT?19 MS. TAITZ: I AM SAYING THAT THE CERTIFICATION PROCESS20 IS D EF IN ITE LY IN FE CTE D B EC AUS E I T IS D EF IN IT EL Y U ND ER MI NE D.21 IF SOMEBODY CAN GET ON THE BALLOT BY FRAUD AND BE CERTIFIED,

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_TAITZ[I]22 THAT UNDERMINES THE WHOLE PROCESS OF CERTIFICATION.23 THE COURT: DR. TAITZ, YOU'RE NOT LISTENING TO ME. IT24 UNDERMINES THE CERTIFICATION. BUT WHAT YOU WANT TO DO IS2S SET ASIDE THE ELECTION; CORRECT? THE VOTES? ALL THE26 VOTES -- IT WAS INFECTED. WE SHOULDN'T COUNT WHAT THEY

CHRISTINE L. BELASCO, CSR 6189, RPR, CRR 171 VOTED FOR ON JUNE 9.2 WE SHOULDN'T COUNT THAT BECAUSE THEY -- HE WAS OUT3 BUYING VOTES. HE WAS GETTING ALL OF HIS FRIENDS FROM NEW4 JERSEY TO COME VOTE, WHATEVER. RIGHT? THAT'S YOUR PROBLEM;5 RIGHT? YOU WANT A NEW ELECTION; RIGHT?6 MS. TAITZ: NO. I NEVER ASKED FOR A NEW ELECTION.7 THERE WOULD NOT BE A NEED FOR A NEW ELECTION. YOUR HONOR,8 AND I AM NOT ASKING FOR YOU TO GRANT ANY FINAL RELIEF. ALL9 I AM ASKING IS JUST A TEMPORARY RELIEF OF STAYING10 CERTIFICATION. AND MAYBE WE CAN SEE WHEN TRIAL CAN BE11 SCHEDULED.12 IF IT IS SOMETHING THAT CAN BE SCHEDULED SOON13 ENOUGH, MAYBE WE CAN FIND SOME KIND OF RESOLUTION. AND14 THAT'S WHY MY FIRST PRAYER OF RELIEF WAS EXPEDITED TRIAL. I15 HAVE ALREADY FILED AN ISSUE MEMORANDUM FOR TRIAL. AND MAYBE16 WE CAN START FROM THERE AND FIND A SOLUTION TO THIS ISSUE.17 I UNDERSTAND WHAT YOU'RE SAYING, YOUR HONOR.18 LET'S FIND A SOLUTION. CLEARLY, YOU WOULDN'T WANT SOMEBODY19 COMMITTING FRAUD AND CERTIFIED AS A WINNER OF THE ELECTION.20 SO I THINK WE'RE ON THE SAME PAGE HERE. WHAT DO YOU21 SUGGEST?22 THE COURT: NO, MS. TAITZ, WE'RE NOT ON THE SAME PAGE.23 MR. HILDRETH, DO YOU WANT TO RESPOND?24 MR. HILDRETH: YES, SIR. THANK YOU, YOUR HONOR. I

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_TAITZ[I]25 GUESs t FIRST, THE POINT TO MAKE IS THAT THE ELECTIONS CODE26 PROVIDES FOR THIS CIRCUMSTANCE WHERE SOMEBODY IS UNHAPPY OR

CHRISTINE L. BELASCO, CSR 6189, RPR, CRR 181 FEELS THAT THE PERSON WHO WAS ELECTED DID NOT DESERVE TO BE2 ELECTED OR SOMEHOW INSTITUTED FRAUD INTO THE PROCESS.3 AND BASICALLY WHAT THE ELECTIONS CODE STIPULATES4 IS THAT THE CERTIFICATION GOES FORWARD, BUT THAT IF THE5 IF THE FRAUD OR WHATEVER IT IS IS PROVEN, THAT A NEW6 CERTIFICATE OF ELECTION IS ISSUED. SO THE CERTIFICATION IN7 THIS CASE CAN ABSOLUTELY GO FORWARD.8 BUT IF MS. TAITZ IS SOMEHOW ABLE TO PROVE UP HER9 CLAIMS, THAT A NEW CERTIFICATE OF ELECTION WOULD BE ISSUED

10 TO THE, QUOTE, UNQUOTE, WINNER OF THE PRIMARY ELECTION. AND11 50 THAT IS UNDER THE ELECTIONS CODE. AND I THINK BASED ON12 THAT, MS. TAITZ DOESN'T MEET THE STANDARD FOR A TRO.13 IN OTHER WORDS, THERE IS NO REPARABLE HARM TODAY14 AS WE ALL SIT HERE. AND, YOU KNOW. SHE DOES HAVE A LEGAL15 REMEDY THAT IS ADEQUATE TO HER, WHICH IS PROVIDED UNDER THE16 ELECTIONS CODE. IT IS DIVISION 16 WHICH IS ENTITLED17 "ELECTION CONTESTS."18 AND THIRD, I GUESS SHE HASN'T SHOWN A REASONABLE19 PROBABILITY OF SUCCESS ON THE MERITS OF HER UNDERLYING20 ELECTION CONTEST. SO BASED ON THOSE THREE REASONS AND BASED21 ON WHAT IS PROVIDED IN THE ELECTIONS CODE t I THINK THAT THE22 TEMPORARY RESTRAINING ORDER TODAY SHOULD BE DENIED.23 AND, IN ADDITION, I WILL SAY THAT SHE IS ASKING24 IT APPEARS THAT SHE IS ASKING MR. DUNN TO STOP TALLYING THE25 VOTES. SO WE DON'T HAVE THE REGISTRARS OF VOTERS FROM EACH26 COUNTY HERE TODAY. AND WE DON'T HAVE THE SECRETARY OF STATE

CHRISTINE L. BELASCO, CSR 6189, RPR, CRR 19page 16


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__TAITZEl]1 REPRESENTATIVES HERE TODAY. SO I AM NOT -- I AM NOT SURE2 WHAT MR.-- THE RELIEF AGAINST MR. DUNN WOULD BE. BUT WE ARE3 THE ONLY PARTY NAMED.4 THE COURT: RIGHT. WHAT ABOUT MC KINNEY? MY COMPUTER5 IS BEING WORKED ON. SO I DON'T HAVE THE CASE IN FRONT OF6 ME. BUT HER PAPERS, MS. TAITZ'S PAPERS -- DR. TAITZ SAYS7 THAT THE COURT OF APPEALS STAYED THE CERTIFICATION OF THE8 ELECTIONS RESULTS. IS THAT THE RELIEF THAT WAS GRANTED IN9 THAT CASE?

10 MR. HILDRETH: WELL, I -- I QUICKLY LOOKED AT MC KINNEY11 YESTERDAY. AND REALLY ONCE I SAW THAT, THE FACTS WERE12 ENTIRELY DIFFERENT FROM WHAT WE'RE FACING HERE TODAY. AND13 THAT IS THEY WERE ALLOWING A CANDIDATE TO APPEAR ON THE14 BALLOT THAT MAYBE SHOULD NOT HAVE BEEN ABLE TO APPEAR ON THE15 BALLOT, A WRITE-IN CANDIDATE, THAT MAYBE AFFECTED THE16 OUTCOME OF THE GENERAL ELECTION.17 SO IT WASN'T NECESSARILY ONE PERSON BRINGING AN18 ELECTION CONTEST AGAINST ANOTHER PERSON, MEANING ONE19 CANDIDATE AGAINST ANOTHER CANDIDATE. THAT IS WHY Me KINNEY20 IS A LITTLE DIFFERENT FROM WHAT WE'RE DOING HERE AND21 DIFFERENT FROM THE GARDEN-VARIETY ELECTION CONTEST22 CONTEMPLATED UNDER THE ELECTIONS CODE.23 THE COURT: RIGHT. I DO KNOW THAT THAT IS WHAT THE24 ISSUE WAS -- I KNOW, AMONG OTHER THINGS, THAT THE Me KINNEY25 CASE AND THE CASES THAT CITE IT TALK ABOUT THE EFFECT OF THE26 CERTIFICATION OR THE EFFECT OF FRAUD ON THE ELECTION.

CHRISTINE L. BELASCO, CSR 6189, RPR, CRR 201 BUT I DON'T RECALL IT BEING A STAYING OF THE2 CERTIFICATION ELECTION RESULTS OR WHY IT WAS, IN FACT, A3 STAY OF THE CERTIFICATION. I THINK MC KINNEY DID SOMETHING

page 17


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__TAITZ[lJ4 DIFFERENT THAN THAT. ALL RIGHT. OKAY.S MS. TAITZ: MIGHT I RESPOND, YOUR HONOR?6 THE COURT: HOLD ON A SECOND. ALL RIGHT. I'VE HEARD7 YOUR ARGUMENT, MS. TAITZ. 00 YOU WANT TO RESPOND TO WHAT8 MR. HILDRETH SAID?9 MS. TAITZ: ABSOLUTELY. MR. HILDRETH IS JUST SIMPLY

10 MISREPRESENTING THE LAW. IT IS ABSOLUTELY WRONG. AND AS A11 MATTER OF FACT, AS YOU STATED, YOUR HONOR, ABSOLUTELY12 CORRECTLY, IF THE LAW WOULD HAVE BEEN AS MR. HILDRETH WANTS13 IT TO BE, THEN THE -- RIGHT HERE, THE COURT OF APPEALS IN14 SANTA ANA WOULD NOT HAVE STAYED CERTIFICATION OF ELECTION.15 THAT IS EXACTLY WHAT HAPPENED IN Me KINNEY. THEY16 ISSUED A STAY. AND IF -- WE CAN COME TO A DECISION THAT17 WILL BE ABSOLUTELY OPPOSITE OF WHAT THE COURT OF APPEALS18 RIGHT HERE DID.19 THE COURT: I AM SORRY. I AM GOING TO STOP YOU. THIS20 IS AN EMERGENCY MATTER. YOU'RE NOT ENTITLED TO CONTINUE TO21 ARGUE IT. I'VE GOT ENOUGH. I UNDERSTAND THE ISSUE.22 LET ME SAY THIS: THE CERTIFICATION OF THE WINNERS23 DOES NOT CHANGE THE ISSUE. IF, IN FACT, YOUR COMPLAINT IS24 CORRECT, THEN THE RELIEF IS TO ANNUL THE ELECTION. THE25 RELIEF IS, AS I UNDERSTAND IT, NOT TO MAKE YOU THE WINNER.26 BUT EVEN IF IT WERE TO MAKE YOU THE WINNER OF THE

CHRISTINE L. BELASCO, CSR 6189, RPR, eRR 211 ELECTION, IT WOULD BE -- IT CAN STILL BE DONE EVEN AFTER THE2 CERTIFICATION. IN OTHER WORDS, IF YOU BROUGHT THIS -- WELL,3 IF YOU'RE ENTITLED TO BRING THIS LAWSUIT AFTER THE ELECTION,4 YOU'RE ENTITLED TO BRING IT AFTER THE CERTIFICATION AS WELL.S T HE CERT IFI CATI ON DOESN' T CHAN GE A NYT HING IN TE RMS6 OF THE FRAUD OR THE LAWSUIT. BECAUSE YOU'RE NOT CLAIMING7 ANY FRAUD IN THE CERTIFICATION PROCESS. WHAT YOU'REpage 18


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__TAITZ[lJ8 CLAIMING IS -- WELL, I THINK WHAT YOU'RE CLAIMING IS9 MR. DUNN SHOULD HAVE NEVER BEEN ON THE BALLOT IN THE FIRST

10 PLACE.11 BUT YOU'RE CLAIMING FRAUD IN THE ELECTION ANYWAY.12 THERE ARE A LOT OF ISSUES AROUND THAT. BUT NONE OF THEM13 HAVE TO DO WITH WHETHER THE VOTES CAST ARE THE VOTES -- ARE14 FOR THE CANDIDATE THAT THEy'RE GOING TO CERTIFY. AND IT15 WOULD BE HELPFUL TO KNOW THAT AND NOT ASSUME -- AT LEAST FOR16 PURPOSES OF THIS MOTION, NOT ASSUME THAT MR. DUNN HAS WON17 THE ELECTION.18 IT WOULD BE NICE IF WE KNEW HE DID WIN IT.19 BECAUSE IF HE DIDN'T WIN IT, YOUR CASE CAN STILL GO FORWARD.20 BUT IT IS ONLY WITH REGARD TO DAMAGES, THAT YOU SPENT21 $40,000PURSUING SOMETHING WHO WASN'T ELIGIBLE. THAT IS ONE22 OF THE CLAIMS YOU HAVE IN THE LAWSUIT.23 BUT TO SET IT ASIDE AND SAY HE IS NOT ELIGIBLE24 AND, THEREFORE, HE IS NOT -- AND, THEREFORE, YOU SHOULD BE2S THE CANDIDATE, THAT CAN BE HANDLED AFTER CERTIFICATION. SO26 I UNDERSTAND -- I UNDERSTAND YOUR POSITION THAT MC KINNEYCHRISTINE L. BELASCO, CSR 6189, RPR, CRR 221 STAYED CERTIFICATION. WHETHER THAT IS TRUE OR NOT, I DON'T2 SEE THAT THAT IS A NECESSARY COMPONENT FOR YOU TO PURSUE3 YOUR CLAIM, A NECESSARY ISSUE.4 ALSO, I HAVE TO SAY THIS: CODE OF CIVIL PROCEDURE5 44 TALKS ABOUT APPEALS TO THE APPELLATE COURT AND TO THE6 SUPREME COURT. THEy'RE ENTITLED TO GIVE A PREFERENCE. BUT7 IT DOESN'T SAY THAT I HAVE TO GIVE A PREFERENCE. THERE IS8 NO -- CODE OF CIVIL PROCEDURE 44 DOESN'T PROVIDE FOR9 PRIORITY OF HANDLING OF ELECTION COMPLAINTS IN THE SUPERIOR

10 COURT.page 19


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11 __ TAITZ[1]THERE MAY BE OTHER SECTIONS. I TRIED TO FIND12 THEM. I COULDN'T FIND THEM. YOUR CITATION, THOUGH, TO 4413 IS FOR THE APPELLATE COURTS AND THE COURT OF APPEAL -- AND14 THE SUPREME COURT. AND I AM NOT -- THOSE RULES DON'T APPLY15 TO ME. I AM NOT THERE. THANK GOODNESS.16 SO -- AND FURTHER, I DO HAVE A PROBLEM ORDERING17 SOMEBODY NOT TO DO SOMETHING IF I DON'T HAVE JURISDICTION18 OVER THEM. YOUR LAWSUIT IS AGAINST MR. DUNN. I CAN ORDER19 HIM TO CERTIFY IT, I GUESS. BUT I AM NOT SURE THAT I CAN20 ISSUE THE ORDER YOU WANT, TO STAY THE REGISTRATION BY THE21 COUNTY REGISTRARS.22 I THINK IF I SEND AN ORDER TO THE COUNTY OF23 REGISTRARS SAYING DO NOT DO THAT, THEY WILL SAY WHO ARE YOU24 AND WHAT RIGHT DO YOU HAVE TO TELL ME WHAT NOT TO DO. AND I25 AGREE. I AM NOT SURE I HAVE ANY JURISDICTION FOR THE26 TEMPORARY RESTRAINING ORDER.

CHRISTINE L. BELASCO, CSR 6189, RPR, CRR 231 IN OTHER WORDS, YOU WANT ME TO RESTRAIN THE COUNTY2 FROM DOING SOMETHING, THE REGISTRARS OF 50 COUNTIES FROM3 DOING SOMETHING. I NEED JURISDICTION OVER THEM BEFORE I CAN4 DO THAT. SO IN LIGHT OF THAT, I AM GOING TO DENY YOUR5 EX PARTE APPLICATION. IF YOU -- THERE ARE OTHER6 ALTERNATIVES, BUT I AM DENYING THE EX PARTE APPLICATION THAT7 YOU SET FOR HEARING.8 MR. HILDRETH, WOULD YOU GIVE NOTICE OF THAT.9 MS. TAITZ: MAY I RESPOND, YOUR HONOR? YOUR HONOR, MAY

10 I RESPOND TO THIS?11 THE COURT: NO. I'VE RULED. THANK YOU VERY MUCH.12 MR. HILDRETH: THANK YOU, YOUR HONOR.1314

( PR OC EE DI NG S A DJ OU RN ED .)

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_TAITZ[l]151617181920212223242526

CHRISTINE L. BELASCO, CSR 6189, RPR, CRR

R EPORTE R' S C ER TI FI CA TE

I, CHRISTINE L. BELASCO, CSR NO. 6189, OFFICIALCOURT REPORTER, DO HEREBY CERTIFY THAT THE FOREGOINGREPORTER'S TRANSCRIPT, CONSISTING OF PAGES 2 THROUGH 23 IS AFULL, TRUE, AND CORRECT TRANSCRIPTION OF MY SHORTHAND NOTESTHEREOF, AND A FULL, TRUE AND CORRECT STATEMENT OF THEPROCEEDINGS HAD IN SAID CAUSE.

DATED AT SANTA ANA, CALIFORNIA, THIS 11TH DAY OFJANUARY, 2011.

CHRISTINE l. B ELA SCO, CS R 6189Page 21


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EXHIBITEXHIBIT 2


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DR. ORLY TAITZ ESQ. PRO SE1 29839 SANTA MARGARITA PKWYRANCHO SANTA MARGARITA CA 926882 Ph 949 -68 3-54 11 fax [email protected]

J UH 24 2 6 1 0A U \N C A RtS C N, C ltl il; 0 1 It;",

CALIFORNIA SUPERIOR COURT4 ORANGE COUNTYLAGUNA HILLS DIVISIONBy.__ ----

7 ORLY TAITZ I8 PLAINTIFF,9 - VS.

10 DAHON DUNN.11 DEFENDANT

) CASB NO.: 30-2010) 00381664)~l})}}

NOTICE OF BX PARTEMOTIONEX PARTE KOTION OFEXPEDITED BANDLING OPE LE CT ION C ON TE STCOMPLAINTMOTION FOR STAY OFCERTIFICATION OF VOTES121314 Notice of Motion Hearing.15 All parties are notified ~at aD ex parte motion hearing will h16 held on Thursday, June 24, 2010, at 9am, COURTROOMLH04 at th17 Harbor J ustice CenterJ Laguna Hills Facility 23141 Houlton PKWY,18 Loguna lULLS Ca 92653-1251.19 MOTION20 On June 17, 2010, Plaintiff Dr. Orly Taitz,ESQ hereinafter Taitz21 has filed a complaint for Elections Contest 16100 , 16161A as22 well as complaint for Elections Fraud, D ec la ra to ry R el ie f and23 Injunctive relief against Defendant Damon Dunn, seeking24 Declaratory Relief deeming defendant Dunn ineligible to serve as"25 a candidate for the position of California Secretary of state26 due to elections fraud, voter fraud, elections registration2~ fraud, nomination fraud. Defendant was served with the complaint2e

Taitz v Dunn Election Contest~ Notice of motion and Motion of Expedited handling ofthe case - 1


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1 at his residence at 3131 Michelson center 708 West, Irvine, CA: ; > . 92612.3 According to CAL CCP code 44 elections con test should be given4 preference in CA Courts. According to eEe 8800 "no candidate5 whose declaration of candidacy has been filed for any primary6 election may withdraw as a candidate at the primary election.7 Must be removed by J udi ci al o rd er ".8 Taitz and Dunn were candidates in June 8, 2010 primary election9 for CA secretary of State. Canvassing ends on July 6, 2010. Due10 to time restrains Plaintiff is seeking expedited scheduling of11 Lhe case management conf erence.12 Memorandum of pOints and Authorities

Taitz v Dunn Election Contest. Notice of motion and Motion of Expedited handling ofthe case - 2

1.3

14 In 2004 similar case of election contest of McKinney v city of15 San Diego. 21 Cal.Rptr.3d 773 (20 04)224 Cal.App.4th, the1 Governing Authority for this dispute, California Court of17 Appeals, fourth district in Santa Ana, has issued a stay of the18 c@rtification of 2004 City of San Diego Mayoral election in19 order to preserve the status quo. ~We immediately stayed the20 certification in order to maintain the status quo at least long21 enough to study the merits of the petition and receive written22 opposition. We scheduled oral argument for Friday, December 3,23 and now write in the wake of that hearing.R id24 plaintiff is seeking declaratory relief and injunction in25 certification of 20 10 Republican primary election and injunctive26 relief in blocking certification of votes for candidate Dunn due27 to fraud committed. As an opponent candidate on the ballot,28 Plaintiff Taitz has a statutory right to contest results of the


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1 election and specifically contest eligibility of her opponent2 based on CEC 1610 0, challen ging her op pon en t as an inelligible3 candidate. [I} All nonspecific statutory references in this4 opinion are to the Elections Code. Section 16100 provides:5 "Any e1ector of a county, city, or of any political subdivision6 of either may contest any election held therein, for any of the7 following causes~a n(a) That the precinct board or any member thereof was guilty of~ malconduct.10 "(b) That the person who has been declared elected to an office11 was not, at the time of the election, eligible for that office.12 u(c) That the defendant has given to any elector or member of a13 p recin ct board any bribe or reward, or has offered any bribe or14 reward for the purpose of procuring his election, or has15 committed any other offense against the elective franchise16 defined in Division 18 ( commen cin g with S ection 18000) .11 "Cd} That illegal votes were cast.18 "(e) That eligible voters who attempted to vote in accordance19 with the laws of the state were denied their right to vote.20 n(f} That the precinct board in conducting the election or in21 canvassing the returns, made errors sufficient to change the22 result of the election as to any person who has been declared23 elected.24, "{g} That there was error in the vote-counting programs or25 summation of ballot counts_"26 ~ E.g., Bradley v. Perrodin (2003) 106 Cal_ App.4th 1153,27 1167, l31 Cal.Rptr.2d 402: nWhen an otherwise successful28 candidate .._ is subsequently found to have committed an offense

Tai~z v Dunn Election Contest. Notice of motion and Motion of Expedited handling oft.he caaa - J


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or offenses against the elective franchise, her election may beannulled even if the number of unqualified voters shefraudulently registered or the number of votes she unlawfullysolicited were too few to have changed the outcome of theelection. "Taitz has a statutory right to contest Dunn's vote per CEC~6100 (aI, 16100 (b) and 16100 (c) >Additionally, as an elector Tait:z can challenge Dunn under CEC13314 +

Section 13314, subdivision (a)(1) provides that: 777*777 HAnyelector may seek a writ of mandate alleging that an error oromission has occurred, or is about to occur, in the placing ofany name on, or in the printing of, a ballot, sample ballot,voter pamphlet, or other official matter, or that any neglect ofduty has occurred, or is about to occur. 1 1 m Subdivision {aJ (2)of section 13314 provides that "A peremptory writ of mandateshall issue only upon proof of both of the following: (A) thatthe error, omission, or neglect is in violation of this[Elections] code or the ConstitutionBased on 16100 and 13314 Taitz can obtain injunctive reliefand stay o f certification and expedited discovery pendingresolution of the underlining election contest.

Prayer for relief;Wherefore: Plaintiff is seeking an order of expedited handlingof the case and setting case management conference at theearliest convenience of this Honorable Court as well as stay of

Taitz v Dunn Election Contest. Notice of motion and Motion of Expedited handling ofthe case - 4


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.1

the Case - 5

certification of votes for candidate on the ballot Damon Dunn2 in June 20 10 Republican Primary Election, pending expedited

hearing of the contest of the election and complaint on the34 merits-.5 Attachments:6 Affidavit of Orly Taitz

Complaint.78 06.23.10.9

1011 Orly Taitz

29839 santa Margaritpkwy, ste 1QO, RSM, CA 9268

1213

1415 Certificate of service16 I, Orly Taitz, attest that a true and correct copy of the above17 motion was served on the defendant on 06.23.10. bye-mail at18 [email protected] Orly'aitz29839 S an ta M ar ga ri taPkwyR an cho san ta M argaritaCA 926882324252627

28

Taitz v Dunn Election Contest, Notice ot motion and Motion of Expedited handling of


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Taitz v Dunn Election Contest. Notice of motion and MOtion of Expedited handling oftile case - 6

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