Welcome to my litigation files. Here, broken into Sections, I will provide a very detailed accounting of the federal and state court cases I have been pursuing in my fight to recover not only my rights as a widow to what Biker had worked so hard to accomplish in licensed cannabis, but to restore his good name as well. As you will see as you read these case files, I will make personal comments in certain links, adjacent to that link in italics, which describe my experiences at the time of that filing. I can honestly say that the state and federal courts have only served to compound the pressures on me and my family by ignoring the most basic element of my case. Criminals who do not qualify for these cannabis licenses are not, by law, allowed to use others to apply for the licenses on their behalf! There are absolute applicant disclosure laws being ignored by everyone from applicants, the lobbyists, attorneys, consultants and even yes, the judiciary! Had these laws been followed my husband would likely still be with us today because it was the criminals, who used him as a proxy on these applications that he ran afoul of when he would not relinquish the licenses over to them after he had successfully acquired them. These people demanded Biker hand over his license rights to them for no compensation whatsoever! They were stealing his dreams and everything he had worked so hard for! It’s no wonder he was stressed out! But did he commit suicide? That is not so clear cut anymore. I have a 3rd party forensics expert Scott Roder, who examined the physical evidence and he believes, with 100% certainty, that Biker did not die of a suicide. See the Roder Video. See the Roder Report.
What I want the reader to understand is that Biker’s death was the beginning of my nightmare. When I learned what these so called “partners” of his did, I sued them. That is where this section begins. The courts have refused to address my demand that they enforce the law that requires these disclosures. They ignore me and my attorney. They grant the defendants’ requests for damages with Anti-SLAPP awards. The courts are literally persecuting me for trying to get them to enforce the laws. I will be updating this page regularly to show the latest developments in these cases. While my opponents would like that I give up and just go away I will not. The law is clear. The evidence is clear. It is here for all to see.
All links are a matter of public record as conformed copies of court docket filings. I will always file them in chronological (year/month/date) order. There may be some Register of Action (ROA) for state and Electronic Case Files (ECF) for federal numbers at the back end of the link but that is the courts ordering of the documents. Any link that begins with COA means that is a Court of Appeals matter stemming from the lower court case. Any link that begins with SC means that the link is a Supreme Court matter stemming from the lower court case. When these documents are used as reference in any future litigation I must refer to the court number so the document can be authenticated by that ROA or ECF number.
Section 1: US District Court – SHERLOCK ET AL v RAZUKI ET AL, Case No. 20CV0656 JLS LL
When I decided to move forward with legal representation I decided to reach out to Attorney Andrew Flores. Andrew had already had approximately 3500 hours of research into the COTTON v GERACI case which is related to mine. Andrew knew what was happening in this sham COTTON v GERACI lawsuit. He eventually decided that when the offer came to purchase the Cotton property and take on those forces that had conspired not only against Cotton but Flores as the new property owner, he had already decided to file this federal complaint stemming from his civil rights violations. When Flores became aware of what had happened to me, Biker and our two minor sons and that many of the same defendants, both in government and private enterprise had conspired against us to rob us of our rights in the mad dash to monopolize cannabis licensing I knew that I was in good hands. Sadly, as of January 2023 I am forced to have to take my arguments up to the 9th Circuit Court of Appeals because the federal court dismissed my case for a “failure to prosecute.” Like can be seen throughout ALL my cases, both federal and state, the case dispositive issue has always been that the defendants have violated the laws and my civil rights by failing to disclose the license applicants who, because of their past criminal activities, would not have qualified for, or had been granted a cannabis license, if they had not hid behind the identity of someone, such as Biker, who did manage to get the license to operate a cannabis dispensary. The absolute irony of all of this is it is a VERY SIMPLE MATTER OF LAW that needs to be decided here and in the following state court cases but in every single instance the judges refuse to address this issue.
20/04/03: SHERLOCK ET AL v RAZUKI ET AL Complaint (ECF-1)
20/04/03: Sherlock’s Ex Parte Application for Temporary Restraining Order (TRO) (ECF-2)
20/04/03: Sherlock’s Request for Judicial Notice(RJN) iso Application for TRO (ECF-3)
20/04/06: Summons (ECF-4)
20/04/07: Judge Sammartino Recusal (ECF-5)
20/04/13: Sherlock’s Notice of Errata (ECF-6)
20/04/17: Order Transferring Case from Judge Sabraw to Judge Bashant (ECF-7)
20/04/20: Judge Bashant’s Order Denying Sherlock’s Application for TRO (ECF-8)
20/05/27: Transfer Order (ECF-9)
20/06/25: Clerks Notice to Sherlock-Petitioner (ESC-10)
20/06/25: COA Sherlock Appeal Brief of Judge Bashant’s Order Denying Sherlock’s Application for TRO (20-71813)
20/06/26: COA Denial of Sherlock Appeal (ECF-11)
20/06/30: Weinstein’s Motion to Dismiss (ECF-12)
20/06/30: Weinstein’s RJNs iso MTD (ECF-13)
20/07/01: Weinstein Withdraws ECF-13 (ECF-14)
20/07/07: Sherlock’s First Amended Complaint (ECF-15)
20/07/09: Sherlock Withdraws ECF-15 (ECF-16)
20/07/09: Sherlock’s First Amended Complaint (ECF-17)
20/07/10: Sherlock’s Amended Summons (ECF-18)
20/07/10: Ruling on Defendants MTD is Denied (ECF-19)
20/07/15: Weinstein’s Notice of Errata (ECF-20)
20/07/20: Weinstein’s Motion to Dismiss w Memorandum of Points and Authorities (ECF-21)
20/07/20: Weinstein’s RJNs w Exhibits 1-8 iso of Motion to Dismiss (ECF-21.1)
20/08/13: Sherlock’s Notice of Errata (ECF-23)
20/08/17: Weinstein’s Reply to Sherlock’s Opposition to Weinstein’s Motion to Dismiss (ECF-24)
20/09/24: Transfer Order Judge Bashant to Judge Robinson (ECF-26)
21/01/13: Wohlfeil’s Motion to Dismiss (ECF-27)
21/03/22: Order Granting Sherlock’s Filing Sur-Reply (ECF-28)
21/03/29: Sherlock’s Sur-Reply (ECF-29)
21/04/15: Wohlfiel’s Attorney Carmela Duke Reply iso Wohlfiel’s MTD (ECF-30)
21/04/21: Sherlock’s Reply in Opposition to Wohlfiel’s MTD (ECF-31)
21/04/26: Clerks Notice re Document Discrepancies (ECF-32)
21/04/26: Order Vacating Hearing (ECF-33)
21/05/07: Wohlfiel’s Supplemental Reply iso MTD (ECF-34)
22/01/03: Order of Transfer Judge Robinson to Judge Ohta (ECF-35)
22/03/23: Order Dismissing Wohlfiel and F&B (ECF-39)
22/06/21: Hearing Transcript of March 23, 2022 (ECF-42)
22/10/12: Sherlock’s Attorney Flores’s Affidavit with Exhibits (ECF-43)
22/10/12: Sherlock’s Affidavit with Exhibits (ECF-43)
22/10/13: Sherlock’s Volume I Request for Judicial Notice (RJN) iso OST (ECF-44)
22/10/13: Sherlock’s Volume II RJNs iso OST (ECF-45)
22/10/13: Sherlock’s Volume III RJN’s iso OST (ECF-46)
22/10/13: Sherlock’s Proof of Service (ECF-47)
22/11/09: Sherlock’s Response to Order to Show Cause (ECF-48)
22/11/09: Sherlock’s Exhibits to Response to Order to Show Cause (ECF-49)
22/12/09: Judge Ohta Dismisses Sherlock’s Case for Failure to Prosecute (ECF-51)
22/12/09: Dismissal Order (ECF-52)
23/01/05: Sherlock’s Notice of Appeal (ECF-53)
23/01/09: Sherlock’s Proof of Service (ECF-54)
23/01/10: APPEAL Clerks Notice (ECF-55)
23/01/10: APPEAL Time Schedule (ECF-56)
23/04/05: APPEAL ECF-9 Opening Brief Excerpts
23/04/05: APPEAL ECF-10_Opening Brief
23/05/05: APPEAL ECF-12 Wohlfeil Reply
23/05/05: APPEAL ECF-13 Wohlfeil Exhibits
23/05/05: APPEAL ECF-14 Weinstein Answering Brief
23/05/05: APPEAL ECF-15 Weinstein Exhibits
23/06/26: APPEAL ECF-26_Sherlock’s Reply
23/12/11: APPEAL ECF-35_Opinion
Section 2: BRADFORD HARCOURT ET AL v SALAM RAZUKI ET AL – PLAINTIFF-INTERVENOR: AMY SHERLOCK, Case No. 37-2017-00020661-CU-BC-CTL
Little did I know that when I started looking into the events that surrounded Biker’s death I would come to learn of a lawsuit that Biker’s old business partner, Brad Harcourt was having with several defendants who I also found out were involved with the 8863 Balboa Avenue dispensary that Biker had gotten the Conditional Use Permit (CUP) for several months prior to his “suicide.” I had come to find out that there had been a forged signature of Biker’s that, 18 days after his death, transferred his rights to the business he shared with Harcourt. I obviously wanted to intervene in this case over that information I possessed but I later came to find out that one of the defendants, Salam Razuki, who I came to believe was also an undisclosed investor in Biker’s CUP application, was indicted for conspiracy to commit murder and tried and convicted in federal court. That case stems from Razuki attempting to kidnap and murder his partner at the 8863 dispensary that Biker had originally gotten licensed! [links]
17/06/17: Original Complaint (ROA-1)
21/04/05: Sherlock’s Ex Parte Application to Intervene (ROA-431)
21/04/05: Sherlock’s Memorandum of Points and Authorities iso of Ex Parte Application to Intervene (ROA-432)
21/04/05: Sherlock’s Proposed Complaint in Intervention (ROA-433)
21/04/05: Razuki’s Opposition to Sherlock’s Ex Parte Application to Intervene (ROA-434)
21/04/05: Harcourt’s Opposition to Sherlock’s Ex Parte Application to Intervene (ROA-435)
21/04/06: Minute Order Setting Sherlock’s Application to Intervene for Hearing (ROA-436)
21/05/14: Minute Order Denying Sherlock’s Motion to Intervene (ROA-540)
23/06/29: Ex_Parte_Application_to_Advance_Hearing_on_Plaintiff (RAO-617)
23/06/29: Proposed_Order_re_Ex_Parte_Application_to_Advance (ROA-618)
23/06/29: Declaration_of_Charles_Cavanagh_in_Support_of_Ex_P_(ROA-619)
23/06/28: Notice_of_Plaintiff_San_Diego_Patients_Cooperative_(ROA-620)
23/06/28: Memorandum_of_Points_and_Authorities_re_Plaintiff_(ROA-621)
23/06/28: Declaration_of_Charles_Cavanagh_in_Support_of_Plai_(ROA-622)
23/06/28: Separate_Statement_re_Plaintiff_San_Diego_Patient_(ROA-623)
23/06/28: Proposed_Order_Granting_Plaintiff_San_Diego_Patien_(ROA-624)
Section 3: RAZUKI v MALAN ET AL, Case No. 37-2018-00034229-CU-AT-CTL
Why is this case important to me? Well it involves the 8863 property and it’s being in a receivership until the lawsuit is fully adjudicated. There is was an interlocutory appeal filed on January 11, 2019 and decided on February 24, 2021. After the appeal was settled, I filed a Motion to Intervene on April 5, 2021. Like in the Harcourt v Razuki litigation (Section 2) that request was also denied.
18/07/10: RAZUKI v MALAN ET AL Complaint (ROA-1)
18/07/30: Gina Austin’s Declaration (ROA-55)
18/08/17: Gina Austin’s Supplemental Declaration (ROA-221)
18/09/04: Gina Austin’s Supplemental Declaration (ROA-127)
18/09/26: Gina Austin’s Declaration (ROA-167)
18/10/04: Gina Austin’s Declaration (ROA-193)
18/11/05: Gina Austin’s Declaration (ROA-252)
18/11/13: Gina Austin’s Declaration to be Relieved as Counsel (ROA-292)
19/01/11: COA CCIS v Hakim et al (D075028)
19/01/11: COA CCIS v Malan et al (D075028)
19/02/01: COA-PSF-EFS Vol 1 of 2 (D075028)
19/02/01: COA-PSF-EFS Vol 2 of 2 (D075028)
19/02/01: COA-PSF-Hakim (DO75028)
19/02/07: COA-PSF-EFS Order Deny (D075028)
19/03/08: COA 18/07/17 Hearing Reporters Appeal Transcript (RT) Vol 1 of 7 (Pgs. 1-12/Do75028)
19/03/08: COA 18/07/31 Hearing RT Vol 2 of 7 (Pgs. 201-254/D075028)
19/03/08: COA 18/08/14 Hearing RT Vol 3 of 7 (Pgs. 302-325/D075028)
19/03/08: COA 18/08/20 Hearing RT Vol 4 of 7 (Pgs. 326-443/D075028)
19/03/08: COA 18/09/07 Hearing RT Vol 5 of 7 (Pgs. 444-602/D075028)
19/03/08: COA 18/09/27 Hearing RT Vol 6 of 7 (Pgs. 603-671/D075028)
19/03/08: COA 18/11/30 Hearing RT Vol 7 of 7 (Pgs. 704-858/D075028)
19/03/19: COA EOT Request Malan et al (D075028)
19/06/24: COA Augment the Record on Appeal – Hakim et al (D075028)
19/07/02: COA Appellants Opening Brief (AOB)- Hakim et al (D075028)
19/07/03: COA Motion to File Under Seal – Malan et al (D075028)
19/07/08: COA Firm Name Correction – Malan et al (D075028)
19/07/09: COA Order Granting Sealed CIP and Oversized AOB (D075028)
19/07/09: COA Appellants Opening Brief – Malan et al (D075028)
19/07/09: COA Appellants Appendix (AA) Vol 1 of 19 (Pages 1-289/Do75028)
19/07/09: COA AA Vol 2 of 19 (Pages 290-542/D075028)
19/07/09: COA AA Vol 3 of 19 (Pages 543-816/D075028)
19/07/09: COA AA Vol 4 of 19 (Pages 817-1217/D075028)
19/07/09: COA AA Vol 5 of 19 (Pages 1218-1424/D075028)
19/07/09: COA AA Vol 6 of 19 (Pages 1425-1820/D075028)
19/07/09: COA AA Vol 7 of 19 (Pages 1821-2353/D075028)
19/07/09: COA AA Vol 8 of 19 (Pages 2354-2663/D075028)
19/07/09: COA AA Vol 9 of 19 (Pages 2664-3063/D075028)
19/07/09: COA AA Vol 10 of 19 (Pages 3064-3499/D075028)
19/07/09: COA AA Vol 11 of 19 (Pages 3500-3933/D075028)
19/07/09: COA AA Vol 12 of 19 (Pages 3934-4135/D075028)
19/07/09: COA AA Vol 13 of 19 (Pages 4136-4532/D075028)
19/07/09: COA AA Vol 14 of 19 (Pages 4533-4744/D075028)
19/07/09: COA AA Vol 15 of 19 (Pages 4745-5065/D075028)
19/07/09: COA AA Vol 16 of 19 (Pages 5066-5551/D075028)
19/07/09: COA AA Vol 17 of 19 (Pages 5552-5855/D075028)
19/07/09: COA AA Vol 18 of 19 (Pages 5856-6295/D075028)
19/07/09: COA AA Vol 19 of 19 (Pages 6296-6477/D075028)
19/07/24: COA Order Defers AUG (D075028)
19/09/09: COA Razuki EOT Request (D075028)
19/12/20: COA Respondents Brief – Razuki (D075028)
19/12/20: COA Respondents Appendix Vol 1 of 1 (D075028)
20/02/06: COA Appellants Reply Brief – Hakim et al (D075028)
20/02/14: COA Appellants Reply Brief – Malan et al (D075028)
20/09/30: COA Substitution of Attorney – Malan et al (D075028)
21/02/16: COA Opposition to Motion to Dismiss – Hakim et al (D075028)
21/02/18: COA Motion to Dismiss and Opposition Order Denied (D075028)
21/02/24: COA Opinion (D075028)
21/04/05: Sherlock’s EP Application to Intervene (ROA-1568)
21/04/05: Sherlock’s-MPAs in Support of Intervention (ROA-1569)
21/04/05: Sherlock’s Proposed Complaint in Intervention (ROA-1570)
21/04/06: Minute Order re Sherlock’s EP Hearing to Intervene (ROA-1573)
21/05/14: Oral Arguments Hearing on Sherlock’s Motion to Intervene (ROA-1710)
21/05/14: Minute Order Sherlock’s Motion to Intervene is Denied (ROA-1708)
23/03/01: Razuki Declaration (ROA-2366)
23/03/21: Malan’s Notion of Motion for Sanctions (ROA-2374)
23/03/21: Malan’s MPA iso Sanctions (ROA-2375)
23/03/21: Malan’s Declaration iso Sanctions (ROA-2376)
23/03/21: Demergian Declaration iso Sanctions (ROA-2377)
23/03/21: Malan’s RJN iso Sanctions (ROA-2378)
23/06/12: Interested Party_California_Department_of_Tax_and_Fee_Administration (ROA-2450)
23/06/16: Razuki Notice_of_Appeal_(ROA-2451)
23/06/26: Razuki Appellant_s_Notice_Designating_Record_on_Appeal_(ROA-2463)
23/07/05: G10 Creditors Opposition_Other_Opposition_Replies to TRO_(ROA-2465)
23/07/05: G-10 Gallupo Law Request_for_Judicial_Notice (ROA-2466)
23/08/10: Minute Order (ROA-2497)
23/08/24: Objection to Disbursement of Funds (ROA-2499)
23/08/24: Proof of Service (ROA-2500)
23/10/09: COA Appeal No. D075028_Sherlock’s Steering Doc
24/04/18: COA Appeal No. D075028_Sherlock ‘s Steering Doc Addendum 1
Section 4: MONTGOMERY FIELD BUSINESS CONDOMINIUMS ASSOCIATION v SAN DIEGO UNITED HOLDINGS GROUP ET AL, Case No. 37-2017-0001984-CU-CO-CTL
17/06/29: SDUHG Answer (ROA-11)
17/07/26: Atty Jaffe’s Declaration re Razuki Investments (ROA-13)
17/07/27: Atty Jaffe’s Declaration re Salam Razuki (ROA-14)
17/08/03: SDUHG’s MPAs iso Tenants Modifying the TRO (ROA-34)
17/08/03: Atty Austin’s Declaration iso SDUHG’s EP Application to Dissolve the TRO (ROA-35)
17/08/03: Morton’s Declaration iso SDUHG’s EP Application to Dissolve the TRO (ROA-36)
17/08/03: Malan’s Declaration iso SDUHG’s EP Application to Dissolve the TRO (ROA-37)
17/08/03: Michelet’s Declaration-other (ROA-38)
17/08/08: SDUHG’s RJN iso EP Application to Dissolve the TRO (ROA-41)
17/08/03: Michelet’s Declaration iso SDUHG’s EP Application to Dissolve the TRO (ROA-43)
17/08/21: SDUHG’s OPP to MFCBA’s Motion for Preliminary Injunction (ROA-85)
17/08/21: SDUHG’s RJN iso OPP to MFCBA’s Motion for PI (ROA-86)
17/08/21: Malan’s Declaration iso OPP to MFBCA’s Motion for PI (ROA-87)
17/08/21: Atty Austin’s Declaration iso OPP to MFBCA’s Motion for PI (ROA-88)
17/09/06: Malan’s Supplemental Declaration iso OPP to MFCBA’s Motion for PI (ROA-110)
17/09/06: Atty Austin’s Supplemental Declaration iso SDUHG’s OPP to MFCBA’s Motion for PI (ROA-111)
17/09/06: Atty Austin’s Supplemental Declaration iso SDUHG’s OPP to MFCBA’s Motion for PI (ROA-119)
17/09/06: Razuki’s Declaration iso OPP to MFBCA’s Motion for PI (ROA-122)
17/09/06: SDUHG’s Supplemental Brief in OPP to MFBCA’s Motion for PI (ROA-123)
17/09/07: Malan’s Supplemental Declaration iso OPP to MFCBA’s Motion for PI (ROA-117)
17/09/19: Razuki’s Answer (ROA-156)
17/10/26: Atty Austin’s Declaration with Supporting EMAIL Exhibits (ROA-178)
17/11/02: Atty Jaffe’s Declaration re the Deposition of Arthur Hopkins (ROA-198)
17/11/03: Atty Austin’s Declaration with Supporting City of San Diego Communications (ROA-204)
17/11/08: Order re Modification (no armed guards) to the PI (ROA-219)
18/02/23: Case Settlement (ROA-223)
18/03/20: MFCBA’s Notice of Lodgment iso the Court Retaining Jurisdiction (ROA-226)
18/12/14: MFCBA’s EP Application to Enforce Settlement (ROA-238)
19/01/02: Atty Leetham’s Declaration iso SDUHG’s OPP to MFCBA’s EX Application to Enforce Settlement (ROA-243)
19/01/02: Malan’s Declaration iso SDUHG’s OPP to MFCBA’s EP Application to Enforce Settlement (ROA-244)
19/01/09: Razuki’s OPP to MFCBA’s EP Application to Enter Judgment (ROA-250)
Section 5: AVAIL SHIPPING, INC. v RAZUKI INVESTMENTS ET AL, Case No. 37-2018-00022710-CU-FR-CTL
18/05/18: Avail Shipping v Razuki Investments et al (ROA-1)
18/06/27: San Diego United Holdings Group (SDUHG) Answer (ROA-16)
18/06/27: Malan’s Answer (ROA-17)
18/06/27: SDUHG’s Cross Complaint (ROA-18)
18/07/09: Razuki’s Peremptory Challenge (ROA-39)
18/07/13: Razuki’s Demurrer Notice (ROA-34)
18/08/13: Malan’s Statement of Related Case (ROA-49)
18/09/10: Razuki’s Answer to SDUHG’s Cross Complaint (ROA-56)
18/10/15: SDUHG’s MPA’s iso Motion to Consolidate (ROA-71)
18/10/15: Atty Leetham’s Declaration iso SDUHG’s Motion to Consolidate with Exhibits (ROA-72)
18/10/15: SDUHG’s Proposed Order Granting Motion to Consolidate (ROA-73)
18/11/02: Razuki’s Reply iso of the Demurrer to Complaint (ROA-77)
18/11/19: Razuki’s Answer to Complaint (ROA-88)
18/12/04: Razuki’s OPP to Malan’s Noticed Motion to Consolidate (ROA-90)
18/12/05: Sunrise Properties Answer to Verified Cross Complaint (ROA-96)
18/12/14: Minute Order (ROA-98)
18/12/21: Minute Order (ROA-106)
19/01/07: Razuki Investments Case Management Statement (ROA-109)
19/01/10: SDUHG’s Request for Dismissal without Prejudice Cross Complaint (ROA-121)
19/07/29: Razuki’s MPA’s iso OPP to Motion to Deem Plaintiff Prevailing Party (ROA-147)
19/07/29: Razuki’s Declaration in OPP to Motion to Deem Plaintiff Prevailing Party (ROA-148)
19/08/09: Minute Order (ROA-162)
19/08/15: Notice of Entry of Judgment (ROA-164)
Section 6: SHERLOCK ET AL v GERACI ET AL, CASE NO. 37-2021-00050889-CU-AT-CTL
The Defendant Parties and the Causes of Action in the state case have been expanded in this case as we learned more in the 1-1/2 years prior to filing this case of the anti-trust law violations not brought forth in the federal complaint. What is astonishing in both of these cases is that the very foundation of these complaints begins with violations of the non-disclosure laws. When one considers just how many times the courts refused to even consider these foundational arguments and instead continued the process that, as can be seen here, would require hundreds of motions, appeals and the shear waste of the courts, my time and my money, it is absolutely bewildering how this can occur in our judiciary! It’s not right and it’s not fair! I will not stop! I will keep coming!
21/12/03: SHERLOCK ET AL v AUSTIN ET AL Complaint (ROA-1)
21/12/22: Sherlock’s Ex Parte Application for Temporary Restraining Order (TRO) (ROA-10)
21/12/22: Sherlock’s First Amended Complaint (FAC) (ROA-11)
22/06/07: Lake’s CMS (ROA-32)
22/06/09: Sherlock’s CMS (ROA-35)
22/06/09: Sherlock’s Proof of Service (POS) to Geraci (ROA-36)
22/06/09: Sherlock’s POS to Lake (ROA-37)
22/06/09: Sherlock’s POS to Austin Legal Group (ROA-38)
22/06/10: Minute Order (ROA-42)
22/06/16: Austin’s Motion to Strike (MTS) (ROA-45)
22/06/22: Geraci’s Attorney Crosby’s Declaration Effort to Meet and Confer (ROA-46)
22/07/08: Lake’s Notice of Demurrer (ROA-47)
22/07/08: Lake’s Attorney Hall’s Declaration iso Lake’s Request for Demurrer (ROA-48)
22/07/08: Lake’s POS to Sherlock (ROA-49)
22/02/22: Geraci’s Anti-SLAPP Motion (ROA-57)
22/07/22: Geraci’s Motion for Demurrer (ROA-66)
22/07/22: Geraci’s Memorandum of Points and Authorities iso Geraci’s MTS (ROA-58)
22/07/22: Geraci’s Proposed Order re Demurrer (ROA-66)
22/07/22: Geraci’s Notice of Lodgment re Demurrer (ROA-68)
22/07/22: Geraci’s MTS Portions of Sherlock’s FAC (ROA-69)
22/07/22: Notice of Hearing re Geraci’s Motion for Demurrer (ROA-70)
22/07/22: Geraci’s POS to Sherlock (ROA-71)
22/07/25: Sherlock’s Opposition to Austin’s MTS (ROA-72)
22/07/29: Austin’s Reply to Sherlock’s Opposition to Austin’s MTS (ROA-74)
22/08/01: Sherlock’s Notice of Errata (ROA-75)
22/08/08: Sherlock’s Request for Judicial Notice (RJN) in Opposition to Lake’s Demurrer (ROA-87)
22/08/08: Sherlock’s Opposition to Lake’s Demurrer (ROA-88)
22/08/08: McElfresh’s Request for Extension (ROA-89)
22/08/10: Sherlock’s Amendment to Complaint Naming DOE (ROA-92)
22/08/11: Tentative Ruling Granting Austin’s Anti-SLAPP Motion (ROA-91)
22/08/12: Minute Order Granting Austin’s Anti-SLAPP (ROA-94)
22/08/12: Reporters Transcript
22/08/13: Austin’s Notice of Ruling (ROA-98)
22/08/15: Lake’s Reply to Sherlock’s Opposition to Lake’s Demurrer (ROA-95)
22/08/15: Tentative Ruling of Lake’s Demurrer (ROA-97)
22/08/19: Austin’s Proposed Order Granting Anti-SLAPP (ROA-117)
22/08/19: Minute Order Modifying the Tentative Ruling on the Lake Demurrer (ROA-102)
22/08/23: COA Sherlock’s POS re Austin’s Anti-SLAPP Appeal (ROA-189)
22/08/23: COA Sherlock’s APP-002 Notice of Appeal (ROA-190)
22/09/01: Sherlock’s Notice of Appeal of Austin’s Anti-SLAPP Award (ROA-103)
22/09/01: Razuki’s Declaration of Meet and Confer (ROA-107)
22/09/01: Razuki’s POS and Request for Extension of Time (ROA-108)
22/09/07: McElfresh’s Notice of Demurrer to FAC (ROA-109)
22/09/07: McElfresh’s MPA iso Demurrer to FAC (ROA-110)
22/09/07: McElfresh’s Attorney Stewart’s Declaration iso of Demurrer to FAC (ROA-111)
22/09/07: McElfresh’s RJNs iso Demurrer to FAC (ROA-112)
22/09/07: McElfresh’s Notice of Motion and Motion to Strike (ROA-113)
22/09/07: McElfresh’s POS (ROA-114)
22/09/13: COA Sherlock’s Notice of Default re Austin’s anti-SLAPP Appeal (ROA-115)
22/09/21: Austin’s Notice of Entry of Judgment (ROA-119)
22/09/21: Austin’s Memorandum of Costs (ROA-120)
22/09/21: Austin’s Motion for Attorney Fees and Costs (ROA-121)
22/09/22: Sherlock’s Designating Record on Appeal (ROA-123)
22/09/26: Sherlock’s POS to Cure Default on Austin’s Designation of Record on Appeal (ROA-122)
22/09/28: Austin’s Designating Record on Appeal (ROA-125)
22/10/20: Tentative Ruling re Geraci’s Demurrer (ROA-150)
22/10/22: Tentative Ruling re McElfresh’s Demurrer and MTS (ROA-151)
22/10/20: Sherlock’s Opposition to Geraci’s Demurrer (ROA-152)
22/10/21: Minute Order Granting Geraci’s Demurrer (ROA-162)
22/10/21: Appointment of Official Reporter Pro Tempore (ROA-163)
22/10/26: Geraci’s Opposition to Sherlock’s EP Application to Stay (ROA-164)
22/11/01: Lake’s EP Application Dismissing Lake (ROA-185)
22/11/01: Lake’s Attorney Hall’s Declaration iso EP Application Dismissing Lake (ROA-186)
22/11/01: Lake’s Proposed Order (ROA-187)
22/11/02: Order Dismissing Lake re the Cartwright Act (ROA-192)
22/11/02: Minute Order Granting Lake’s Request to Dismiss (ROA-193)
22/11/04: Notice of Ruling re Order Dismissing Lake (ROA-214)
22/11/04: Lake’s General Denial of Sherlock’s FAC (ROA-216)
22/11/14: Lake’s Judgment for Dismissal (ROA-215)
22/11/14: Austin’s Notice of Non-Opposition for Attorney Fees (ROA-191)
22/11/17: Sherlock’s Omnibus Opposition to Geraci, Schweitzer and McElfresh MTS (ROA-195)
22/11/17: Tentative Ruling (ROA-194)
22/11/18: Minute Order (ROA-213)
22/11/21: Geraci’s Reply to Sherlock’s Opposition to MTS (ROA-196)
22/11/21: Geraci’s Reply to Sherlock’s Opposition to Geraci’s Anti-SLAPP Motion (ROA-197)
22/11/21: Geraci’s Reply to Sherlock’s Opposition to Demurrer (ROA-198)
22/11/23: McElfresh’s Reply iso Demurrer (ROA-202)
22/11/23: McElfresh’s Reply iso MTS (ROA-203)
22/11/23: McElfresh’s POS (ROA-204)
22/11/23: Lake’s Notice of Motion and Motion to Compel Discovery (ROA-205)
22/11/23: Lake’s Memorandum of Points and Authorities (MPAs) iso Motion to Compel Discovery (ROA-206)
22/11/23: Lake’s Attorney Hall’s Declaration iso Motion to Compel Discovery (ROA-207)
22/11/23: Lake’s Proposed Order Granting Monetary Sanctions (ROA-208)
22/11/30: Clerk’s Notice of Completion of Record on Appeal (ROA-218)
22/12/01: Tentative Ruling Granting Schweitzer’s Anti-SLAPP (ROA-222)
22/12/01: Tentative Ruling Sustaining McElfresh’s Demurrer (ROA-223)
22/12/01: Tentative Ruling Granting Geraci’s MTS (ROA-224)
22/12/02: Minute Order Granting Schweitzer’s MTS (ROA-229)
22/12/05: COA Sherlock’s Clerks Transcript Volume I of I
22/12/05: Geraci’s Notice of Ruling Granting Demurrer, MTS and Anti-SLAPP (ROA-230)
22/12/05: McElfresh’s Notice of Ruling Granting Demurrer and MTS (ROA-232)
22/12/05: Lake’s Notice of Entry of Judgment (ROA-234)
22/12/05: Lake’s Memorandum of Costs Summary (ROA-235)
22/12/05: Schweitzer’s Notice of Ruling Granting Anti-SLAPP (ROA-237)
22/12/09: Sherlock’s Request for Entry of Default re Razuki (ROA-240)
22/12/21: Clerks Notice to Filing Party Default re Razuki is Rejected (ROA-241)
22/12/21: Sherlock’s Notice of Confirmation of Filing (ROA-242)
22/12/21: Sherlock’s Opposition to Austin’s Request for Attorneys Fees (ROA-243)
22/12/27: Schweitzer’s Motion for Attorneys Fees (ROA-245)
22/12/27: Schweitzer’s MPA iso Motion for Attorneys Fees (ROA-246)
22/12/27: Schweitzer’s Attorney Najjar’s Declaration iso Motion for Attorneys Fees (ROA-248)
22/12/27: Schweitzer’s Notice of Lodgment iso Motion for Attorneys Fees (ROA-249)
22/12/29: Austin’s Reply to Sherlock’s Opposition to Austin’s Motion for Attorneys Fees (ROA-251)
23/01/05: Tentative Ruling Granting Austin’s Motion for Attorneys Fees (ROA-252)
23/01/06: Minute Order Modifies the Tentative Ruling (ROA-253)
23/01/09: McElfresh’s Judgment Granting Demurrer (ROA-255)
23/01/11: COA Sherlock’s Opening Brief of Austin’s Anti-SLAPP Award (D081109)
23/01/30: Sherlock’s Notice of Appeal re Schweitzer’s Anti-SLAPP Award (ROA-257)
23/01/30: Sherlock’s Notice of Appeal re Geraci’s Anti-SLAPP Award (ROA-258)
23/01/31: Sherlock’s Notice of Filing (ROA-259)
23/02/01: Sherlock’s Attorney Flores’s Declaration in Response to Lake’s Motion to Compel (ROA-260)
23/02/10: Sherlock’s Ex Parte Application for Stay (ROA-277)
23/02/10: Sherlock’s Notice of Confirmation of Filing (Part of ROA-277)
23/02/10: COA Sherlock’s Notice of Default (ROA-278)
23/02/10: Geraci’s Opposition to Sherlock’s Ex Parte Application for Stay (ROA-284)
23/02/10: Schweitzer’s Opposition to Sherlocks Ex Parte Application for Stay (ROA-285)
23/02/14: COA Austin’s Reply to Sherlock’s Opening Brief (D081109)
23/02/14: Geraci’s Notice of Entry of Judgment (ROA-279)
23/02/14: McElfresh’s Notice of Entry of Judgment (ROA-281)
23/02/14: Minute Order Takes the Sherlock Ex Parte Motion to Stay Matter Off Calendar (ROA-283)
23/02/16: Tentative Ruling re Lake’s Motion to Compel Granting in Part and Awarding Sanctions (ROA-287)
23/02/17: Geraci’s Memorandum of Costs Summary (ROA-288)
23/02/17: Lake’s Notice of Ruling Granting in Part Motion to Compel and Awarding Sanctions (ROA-289)
23/02/17: Minute Order Confirming the Tentative (ROA-293)
23/02/22: Lake’s Opposition to Sherlock’s Ex Parte Application for Stay (ROA-301)
23/02/22: Schweitzer’s Notice of Entry of Judgment (ROA-294)
23/02/22: Sherlock’s Ex Parte Application for Stay (ROA-296)
23/02/23: Minute Order Denying EP Application for Stay (ROA-305)
23/02/28: Appellant’s Notice Designating Record on Appeal_McElfresh (ROA-306)
23/02/28: Appellant’s Notice Designating Record on Appeal_Weinstein’s MTS (ROA-307)
23/03/01: Notice of Default (ROA-308)
23/03/02: Geraci And Berry Respondent’s Notice Designating Record on Appeal (ROA-309)
23/03/02: Proof of Electronic Service (ROA-310)
23/03/06: COA Sherlock’s Reply to Austin’s Anti-SLAPP
23/03/13: Geraci and Berrys Notice of Motion for Attorneys Fees (ROA-314)
23/03/13: Geraci and Berry’s Memorandum of Points and Authorities (ROA-315)
23/03/13: Declaration by Weinstein iso Geraci and Berry’s Attorneys Fees (ROA 316)
23/03/13: Notice of Lodgment ISO Motion for Attorneys Fee’s (ROA-317)
23/03/13: Proof of Electronic Service (ROA-318)
23/03/23: COA Schweitzer’s Notice of Failure to Clear Default (ROA-319)
23/03/24: Proof_of_Service_Re_Berry_and_Geraci (ROA-320)
23/03/24: Proof_of_Service_Re_McElfresh (ROA-321)
23/03/24: Proof_of_Service_Re_Schweitzer_DBA_Techne (ROA-322)
23/03/24: DEFENDANT_STEPHEN_LAKES_OPPOSITION_TO_EX_PARTE_APP (RAO-323)
23/03/24: DECLARATION_OF_STEPHEN_LAKE_IN_SUPPORT_OF_DEFENDANT (ROA-324)
23/03/24: Proof_of_Service (ROA-325)
23/04/03: Schweitzer’s Objections_Re_Plaintiffs_Failure_to_File_Opposition_(ROA-236)
23/04/06: Tentative_Rulings_(ROA-237)
23/04/07: Minute_Order_(ROA -328)
23/04/07: Notice_of_Ruling_on_Motion_for_Attorney_Fees_Schweitzer_(ROA-329)
23/04/24: Minute_Order_(ROA-333)
23/05/24: Notice_of_Clearing_Default_(ROA-334)
23/05/26: Tentative_Rulings_(ROA-335)
23/09/11: COA Docket for Monday September 11, 2023_D10923
23/09/11: COA Oral Arguments in AUSTIN’S anti-SLAPP Ruling @ 10:09 Respondent Arguments by Atty. Annie Fraser. @ 14:30 Judge Castillo asks Fraser to describe her interpretation of Strawman. @ 17:43 Appellant Flores replies and submits.
23/09/13: COA BRIEF Sherlock Appeal SCHWEITZER
23/09/13: COA Supporting RJN’s for SCHWEITZER
23/09/18: COA – AUSTIN Unpublished Opinion Affirms Lower Court Ruling
2023 CA Rules of Court -Rule 8.1115 Citation of Opinions (b) Exceptions (1)(2) An unpublished opinion may be cited or relied on:
(1) When the opinion is relevant under the doctrines of law of the case, res judicata, or collateral estoppel; or
(2) When the opinion is relevant to a criminal or disciplinary action because it states reasons for a decision affecting the same defendant or respondent in another such action.
23/10/19: COA – MCELFRESH (respondent) Brief on Appeal_Case No. D081839
23/11/05: COA_Sherlocks-Consolidated-Reply_D081839
24/04/05: Austin’s Notice of Non-Opposition for Attorney Fees (ROA-401)
24/04/12: Notice of Ruling (ROA-400)
24/04/12: Minute Order Granting Austin’s Attorney Fees (ROA-402)
24/04/29: COA_Opinion re Schweitzer et al
24/05/09: Sherlock’s Notice of Motion (ROA-410)
24/05/09: Sherlock’s Motion to Vacate (MTV) Judgment (ROA-406)
24/05/09: Sherlock’s MTV Judgment Request for Judicial Notice (RJN) w Exhibits (ROA-410)
24/05/14: Sherlock’s MTV PRESS RELEASE (PR-1)
24/05/16: Austin’s Opposition to Sherlock’s MTV Judgment (ROA-408)
24/05/16: Austin’s RJN re Sherlocks Motion to Vacate (MTV) Judgment (ROA-409)
24/05/17: Phillip Zamora’s Affidavit iso Sherlock’s MTV (ROA-411)
24/05/17: Tiffany Knopf’s Affidavit iso Sherlock’s MTV (ROA 412)
24/05/17: Andrew Flores Amended Declaration iso Sherlock’s MTV (ROA-413)
24/05/17: Amy Sherlock Amended Declaration iso Sherlock’s MTV (ROA-414)
24/05/17: Geraci and Berry’s Declaration of Non-Opposition to Sherlock’s MTV (ROA-415)
Section 7: BECK v POINT LOMA PATIENTS CONSUMER COOPERATIVE CORPORATION ET AL (CLASS ACTION), Case No. 37-2017-00037524-CU-BT-CTL
Parties and Counsel_BECK-v-POINT-LOMA-PATIENTS-CONSUMER-COOPERATIVE-CORPORATION-ET-AL.pdf
ROA-1_10-06-17_Complaint_1679706290511.pdf
ROA-14_11-16-17_Memorandum_of_Points_and_Authorities_1679706291074.pdf
ROA-15_11-16-17_Declaration_of_William_R_Restis_1679706291136.pdf
ROA-16_11-16-17_Declaration_of_Jeffrey_R_Krinsk_1679706291308.pdf
ROA-20_12-08-17_Joint_Notice_of_Demurrer_and_Demurrer_to_Complaint_1679706291386.pdf
ROA-21_12-08-17_Request_for_Judicial_Notice_ISO_Defendants_Joint_D_1679706291449.pdf
ROA-23_12-08-17_Memorandum_of_Points_and_Authorities_in_support_of_1679706291855.pdf
ROA-24_12-22-17_JOINT_MEMORANDUM_OF_POINTS_AND_AUTHORITIES_IN_OPPO_1679706291902.pdf
ROA-26_12-22-17_OF_MATTHEW_B_DART_IN_SUPPORT_OF_DEFENDANTS_JOINT_O_1679706291980.pdf
ROA-27_12-22-17_OF_ADAM_KNOPF_IN_SUPPORT_OF_DEFENDANTS_JOINT_OPPO_1679706292042.pdf
ROA-28_12-27-17_Reply_in_support_of_motion_pursuant_to_Cal_Corp__1679706292339.pdf
ROA-34_01-05-18_Minute_Order_1679706292417.pdf
ROA-37_01-12-18_Reply_in_Support_of_Defendants_Demurrer_1679706292464.pdf
ROA-38_01-12-18_DEFENDANTS_REQUEST_FOR_JUDICIAL_NOTICE_IN_SUPPORT_1679706292558.pdf
ROA-46_01-19-18_Minute_Order_1679706292667.pdf
ROA-47_02-08-18_Defendants_Joint_Answer_1679706292714.pdf
ROA-51_02-15-18_Memorandum_of_Points_and_Authorities_1679706292777.pdf
ROA-52_02-15-18_Declaration_Other_1679706292839.pdf
ROA-55_03-01-18_Case_Management_Statement_1679706292980.pdf
ROA-58_03-01-18_Case_Management_Statement_1679706293027.pdf
ROA-59_02-13-18_Stip_and_Order_re_confidentiality_of_documents_and_1679706293089.pdf
ROA-62_03-12-18_Declaration_of_Tamara_Leetham_In_Support_Of_Opposi_1679706293246.pdf
ROA-64_03-12-18_Notice_of_Errata_Re_Declaration_of_Tamara_Leetham_1679706293371.pdf
ROA-66_03-16-18_Reply_to_Motion_to_Compel_Production_of_Class_Memb_1679706293964.pdf
ROA-77_03-16-18_Minute_Order_1679706294074.pdf
ROA-81_03-23-18_Minute_Order_1679706294121.pdf
ROA-83_03-23-18_Minute_Order_1679706294152.pdf
ROA-84_03-23-18_Notice_of_Motion_for_Judgment_on_the_Pleadings_to__1679706294199.pdf
ROA-85_03-23-18_in_Support_of_Motion_for_Judgment_on_the_Pleadings_1679706294246.pdf
ROA-86_03-23-18_Re_Motion_for_Judgment_on_the_Pleadings_to_Defend_1679706294308.pdf
ROA-88_03-26-18_Notice_of_Motion_for_Judgment_on_the_Pleadings_to__1679706294339.pdf
ROA-89_03-28-18_Declaration_of_William_R_Restis_ISO_Motion_for_Ju_1679706294480.pdf
ROA-96_04-04-18_Notice_of_Motion_for_Protective_Order_1679706294558.pdf
ROA-97_04-04-18_Declaration_of_Tamara_Leetham_in_Support_of_Joint__1679706294605.pdf
ROA-99_04-04-18_Memorandum_of_Points_and_Authorities_1679706294652.pdf
ROA-100_04-09-18_Memorandum_of_Points_and_Authorities_1679706294746.pdf
ROA-104_04-13-18_Notice_of_Lodgment_1679706294886.pdf
ROA-105_04-16-18_Ex_Parte_Application_for_Stay_1679706294933.pdf
ROA-106_04-16-18_Declaration_of_Tamara_Leetham_in_Support_of_Ex_Par_1679706295058.pdf
ROA-107_04-16-18_Memorandum_of_Points_and_Authorities_in_Support_of_1679706295121.pdf
ROA-108_04-16-18_Re_Ex_Parte_Application_1679706295167.pdf
ROA-110_04-17-18_Minute_Order_1679706295230.pdf
ROA-111_04-18-18_Notice_of_Motion_to_Compel_Plaintiff_s_Special_Int_1679706295277.pdf
ROA-112_04-18-18_Memorandum_of_Points_and_Authorities_ISO_Motion_to_1679706295324.pdf
ROA-113_04-18-18_Separate_Statement_ISO_Motion_to_Compel_Plaintiff__1679706295371.pdf
ROA-114_04-18-18_Declaration_of_William_R_Restis_ISO_Motion_to_Comp_1679706295464.pdf
ROA-115_04-18-18_Re_Motion_to_Compel_Plaintiff_s_Special_Interroga_1679706295730.pdf
ROA-117_04-18-18_Notice_of_Motion_to_Compel_Plaintiff_s_Requests_fo_1679706295792.pdf
ROA-118_04-18-18_Memorandum_of_Points_and_Authorities_ISO_Motion_to_1679706295839.pdf
ROA-119_04-18-18_Separate_Statement_ISO_Motion_to_Compel_Plaintiff__1679706295902.pdf
ROA-120_04-18-18_Declaration_of_William_R_Restis_ISO_Motion_to_Comp_1679706295964.pdf
ROA-121_04-18-18_Re_Motion_to_Compel_Plaintiff_s_Requests_for_Prod_1679706296636.pdf
ROA-123_04-23-18_Order_1679706296699.pdf
ROA-124_04-23-18_Defendants_Memorandum_Of_Points_And_Authorities_In_1679706296746.pdf
ROA-127_04-27-18_Plaintiff_s_Reply_to_Motion_for_Judgment_on_the_Pl_1679706296808.pdf
ROA-128_04-27-18_Declaration_of_William_R_Restis_ISO_Plaintiff_s_R_1679706296855.pdf
ROA-131_05-01-18_Minute_Order_1679706296917.pdf
ROA-133_04-30-18_Memorandum_of_Points_and_Authorities_in_Opposition_1679706296964.pdf
ROA-134_04-30-18_Declaration_of_Matthew_B_Dart_in_support_of_Opposi_1679706297027.pdf
ROA-135_04-26-18_Ex_Parte_Application_for_Order_to_Show_Cause_and_A_1679706297152.pdf
ROA-138_05-04-18_Minute_Order_1679706297246.pdf
ROA-139_05-07-18_DEFENDANTS_MEMORANDUM_OF_POINTS_AND_AUTHORITIES_IN_1679706297292.pdf
ROA-141_05-07-18_DECLARATION_OF_TAMARA_LEETHAM_IN_SUPPORT_OF_DEFEND_1679706297371.pdf
ROA-142_05-07-18_DEFENDANTS_MEMORANDUM_OF_POINTS_AND_AUTHORITIES_IN_1679706297449.pdf
ROA-143_05-09-18_Notice_of_Errata_1679706297605.pdf
ROA-145_05-11-18_Reply_in_Further_Support_of_Plaintiff_s_Motion_to__1679706297714.pdf
ROA-146_05-11-18_Reply_in_Further_Support_of_Plaintiff_s_Motion_to__1679706297777.pdf
ROA-148_05-11-18_Opposition_Plaintiff_s_Opposition_to_Defendants__1679706297824.pdf
ROA-149_05-11-18_Declaration_of_William_R_Restis_ISO_Plaintiff_s_Op_1679706297886.pdf
ROA-152_05-18-18_Reply_to_Opposition_of_Noticed_Motion_and_Supporti_1679706297964.pdf
ROA-154_05-21-18_Notice_of_Withdrawal_of_Plaintiff_s_Requests_for_P_1679706298074.pdf
ROA-156_05-18-18_Minute_Order_1679706298136.pdf
ROA-158_05-18-18_Minute_Order_1679706298167.pdf
ROA-160_05-21-18_Minute_Order_1679706298214.pdf
ROA-163_05-24-18_Minute_Order_1679706298261.pdf
ROA-165_05-23-18_Joint_Amended_Answer_1679706298293.pdf
ROA-169_07-20-18_Notice_of_Motion_to_Quash_Subpoena_1679706298449.pdf
ROA-170_07-20-18_Defendants_Joint_Statement_of_Disputed_Matters_in_1679706298496.pdf
ROA-171_07-20-18_Declaration_of_Tamara_Leetham_in_Support_of_Defend_1679706298558.pdf
ROA-172_07-20-18_Declaration_of_Adam_Knopf_in_Support_of_Defendants_1679706298652.pdf
ROA-173_07-20-18_Memorandum_of_Points_and_Authorities_in_support_Mo_1679706298808.pdf
ROA-177_07-27-18_Notice_of_Motion_for_Defendants_Judgment_on_the_Pl_1679706298855.pdf
ROA-178_07-27-18_Memorandum_of_Points_and_Authorities_In_Support_Of_1679706298902.pdf
ROA-179_07-27-18_Declaration_Of_Tamara_M_Leetham_In_Support_Of_De_1679706298949.pdf
ROA-183_08-16-18_Minute_Order_1679706299011.pdf
ROA-185_08-13-18_Stipulation_Other_1679706299105.pdf
ROA-187_08-27-18_Notice_of_Ruling_1679706299152.pdf
ROA-188_09-06-18_Notice_to_Filing_Party_SD_1679706299214.pdf
ROA-189_09-05-18_Notice_Other_1679706299261.pdf
ROA-190_09-17-18_Notice_of_Change_of_Address_Telephone_Number_1679706299308.pdf
ROA-192_12-05-18_Notice_of_Motion_for_Preliminary_Approval_of_Class_1679706299417.pdf
ROA-193_12-05-18_Memorandum_of_Points_and_Authorities_1679706299464.pdf
ROA-194_12-05-18_Declaration_of_William_R_Restis_in_Support_of_Mot_1679706299511.pdf
ROA-195_12-05-18_Declaration_of_Adam_Knopf_in_Support_of_Motion_for_1679706299636.pdf
ROA-196_12-05-18_Proposed_Order_1679706299683.pdf
ROA-197_12-05-18_Declaration_of_Joseph_M_Fisher_in_Support_of_Moti_1679706299730.pdf
ROA-208_01-04-19_Minute_Order_1679706299808.pdf
ROA-212_02-19-19_Notice_of_Motion_Amended_Unopposed_for_Prelimina_1679706299839.pdf
ROA-213_02-19-19_Memorandum_of_Points_and_Authorities_1679706299902.pdf
ROA-214_02-19-19_Declaration_of_William_R_Restis_In_Support_of_Mot_1679706299980.pdf
ROA-216_02-19-19_Defendant_s_Statement_of_Non_Opposition_1679706300136.pdf
ROA-219_03-15-19_Minute_Order_1679706300199.pdf
ROA-224_04-03-19_Notice_of_Motion_for_Award_of_Attorney_Fees_and_Ex_1679706300230.pdf
ROA-225_04-03-19_Memorandum_of_Points_and_Authorities_in_Support_of_1679706300277.pdf
ROA-226_04-03-19_Supporting_Declaration_of_William_R_Restis_to_Not_1679706300339.pdf
ROA-227_04-03-19_Supporting_Declaration_of_Karl_Beck_to_Notice_of_M_1679706300417.pdf
ROA-229_06-07-19_Declaration_Re_Compliance_with_Class_Notice_1679706300464.pdf
ROA-230_06-07-19_Report_On_Written_Objections_Pursuant_to_Court_s_O_1679706300542.pdf
ROA-231_06-07-19_List_of_Class_Members_Submitting_Exclusion_Request_1679706300605.pdf
ROA-233_06-14-19_Notice_of_Motion_for_Approval_of_Class_Settlement_1679706300652.pdf
ROA-234_06-14-19_Memorandum_of_Points_and_Authorities_1679706300730.pdf
ROA-235_06-14-19_Judgment_1679706300792.pdf
ROA-236_06-14-19_Proposed_Order_1679706300886.pdf
ROA-240_06-28-19_Minute_Order_1679706300964.pdf
ROA-242_06-28-19_Order_After_Hearing_1679706301011.pdf
ROA-243_06-28-19_Judgment_1679706301074.pdf
ROA-245_08-24-20_Declaration_Other_1679706301136.pdf
ROA-247_12-09-20_Declaration_Other_1679706301183.pdf
Section 8: LOUIS ET AL v. AUSTIN LEGAL GROUP, KNOPF, ET AL – Case No. 37-2023-00015974-CU-CO-CTL
23/04/17: Complaint_(ROA-1)
Para 14-21: Brad Talbert acts as a RE Broker for both the buyer and the seller (Rickards). Talbert had Rickards tying up the property for 15 years or until he was 91. Rickards has no heirs.
Para 41: “…GSG backdates an assignment agreement to be in compliance with BCC… Also, GSG PL, Inc.’s tried to use a shell company, LCR 3452-3460 Hancock, LLC, that was only incorporated in Delaware on April 26, 2019, as it’s source of funds and delaying the closing of Escrow while it satisfied its third- party funder with the results of the Phase 2 soil report that could have been obtained months earlier.
Para 46-48: “GSG’s Escrow was fraudulent…Knopf and GSG have refused to supply their financial statements, as required under section 16(c) of the Lease, to Louis and Rickards, among others. Anderson (an ALG attorney) indicated by email to Louis that GSG would never disclose its financial statements, despite the clear requirements of section 16(c) of the Lease.
Para 67: “The Bureau of Cannabis Control (BCC), California sent a letter (Exhibit “H”) to the Defendant wherein it wasn’t satisfied with Defendant’s use of the term “or assignee”, and thus it didn’t consider that term to be a “simple placeholder” for use by GSGCC, GSG PL, Inc., or Knopf, so the BCC required a copy of the formal assignment of the Lease (Exhibit “B), signed on November 7, 2018, and backdated to January 1, 2018, and the BCC made clear that it considered the “or assignee”, claim to be of no consequence or effect.
Para 69: “…Plaintiff has made it clear to defendant that his property and or lease is for sale and that plaintiff’s real estate broker holds the exclusive right to sell the property and/or lease. however, defendant has failed to provide the most recent 3 years of its financial statement per §16.(c) of the lease despite receiving a written demand (exhibit “i”) and because the defendant is a potential buyer that makes its financial statements relevant to its purchase and the potential for securing backup offers that the plaintiff seeks to ensure the sale of its property in the event that escrow doesn’t close. the defendant’s bad faith was demonstrated by its presentation of a non-disclosure agreement (NDA exhibit “j”) that required a potential buyer to accept all the claims that were made in the now dismissed complaint filed by the defendant against the plaintiff. defendant refused to supply its financial statements to oak holdings with whom they were trying to negotiate a sale with leaseback to enable them to continue lease the property when they refused to comply with oak holdings NDA that required financial statements that the defendant also has repeatedly refused to provide under §16.(c) of the lease. on April 3, 2019, during a phone call, defendant’s attorney, Arden E. Anderson, told plaintiff’s attorney that GSG PL Inc. was loath to ever disclose its financial statements, well then, the defendant shouldn’t have signed a lease with that requirement which was negotiated by the real estate broker who represented them in the acquiring the lease they agreed to.”
Para 70: “Defendant’s actions have demonstrated that they will do anything to obstruct the sale of the Plaintiff’s property to a third party without regard to whether it’s consistent with the terms of the Lease and despite the Lessee’s failure to comply with the terms of the Lease ‘s §16.(c), the Estoppel provision.
Para 76: “…However, it now appears that the Buyer of the property is entity that was named as the Assignee and that’s an act by the Defendant in concert with the Buyer that’s a civil unjust enrichment / conspiracy to defraud the Defendant and delayed the closing of Escrow that resulted in the Plaintiff loss of the Time Value of Money (TVM) and an intentional infliction of emotional distress to both the Plaintiff and Plaintiff’s attorney.”
Para 80: “Defendant KNOPF’S failure to comply with many of the Lease terms as described above in sufficient detail shows a repeated pattern of the Defendant’s willful ignoring of its obligations under the Lease from its very inception on April 17, 2014, through the present and makes it abundantly obvious that the Defendant made false promises and never intended to fulfill his part of the bargain at the time he entered into the Lease.
Para 82-83: “…Also, GSG PL, Inc.’s trying to use a shell company, LCR 3452-3460 Hancock, LLC, that was only incorporated in Delaware on April 26, 2019, as it’s source of funds and delaying the closing of Escrow while it satisfied its third-party funder with the results of the Phase 2 soil report that could have been obtained months earlier. Defendant’s attorney, Arden E. Anderson, told me that GSG PL, Inc. was loath to ever disclose its financial statements, well then, the Defendant shouldn’t have signed a Lease with that requirement which was negotiated by the real estate broker who represented them in the acquiring the Lease they agreed to.
Para 86: “Defendant Rickards and MW, didn’t pay attorney fees when the Lessee filed a Complaint against the Plaintiff and although the Complaint was dismissed without prejudice after Escrow was opened and the lis pendens removed during the pendency of the Escrow the threat of the Defendant KNOPF refiling its Complaint was a great discouragement to prospective purchasers of Plaintiff’s property because a refiling of the Complaint would have tied the property up in litigation for years despite that Defendant was in breach of the Lease and made it very difficult to get backup offers in case the Buyer didn’t close Escrow.
Para 91: “Filing of a frivolous lawsuit by Defendants Knopf, and GSG PL, Inc. against Rickards in order to bully him into submission, and was acting in bad faith, because its options cannot be exercised while it is in default of the Lease, as described above, under §39.4(a) and its subsections. Defendant tried to force Rickards to accept his improper demands because he knew that Rickards couldn’t afford to defend the lawsuit and thereby would lose by default because he couldn’t finance a defense that was caused by the Defendant’s breach of §52. of the Lease is an intentional infliction of extreme emotional distress on Plaintiff and TPB. Defendant’s filing of its Complaint under these circumstances effectively coerced Rickards into agreeing to the sale of his property to the Defendant for less that its true worth as a legal dispensary of medical and adult recreational marijuana because, as stated above, he couldn’t afford to finance a defense of the Defendant’s Complaint because Rickards believed that agreeing to the sale was the only way for him to get the Defendant to dismiss its Complaint, so that he wouldn’t lose his rights under the Lease by default.
Para 111: “During the time the buyer needs to secure its own Conditional Use Permit (CUP). The City of San Diego’s CUPs for cannabis dispensaries are not transferable to a new buyer of a dispensary nor do they run with a dispensary property. A new owner operator needs to obtain their own CUP and new BCC permit, the new owner would enjoy the benefit of the Lease payment(s). The new application for a CUP at the property can be applied for while the dispensary is still being operated by the Defendant. After obtaining its permits to operate the dispensary, the new owner can evict the Defendant who is in a noncurable default of the Lease and the new owner could resume the operation of a dispensary on the property with a minimal disruption to its operation. In any case, since the Defendant has lost its options to renew the Lease as well as its right to occupy the property under the existing Lease that ends on April 17, 2020, that would allow the new owner to evict the Lessee and take possession of the property…”
23/04/17: CIVIL CASE COVER SHEETS (ROA-2)
23/04/17: Affidavit Other Declaration Statement (ROA-3)
23/08/14: Request for Dismissal (ROA-22)
23/10/04: Louis’s FAC ROA-28 Drops ALG, Knopf and others as defendants. No longer is self represented. He hires Robert Bryson who admits to being incompetent in this Declaration when he represented Darryl Cotton in a cannabis related case that would have seen him lose his commercial property.
Section 9: BROWN v. KNOPF ET AL
17/07/11: BROWN v. KNOPF ET AL_Complaint_(ROA-1)
Para 8: “Plaintiff is informed and believes and based thereon alleges that at all times mentioned herein there existed a unity and identity of interest and ownership between all Defendants, such that any individuality and separateness between them have ceased. Each of the defendants is the alter ego of the other in that, inter alia, each is or was composed of the same or practically the same principals, the assets of the entities have been transferred and combined between the entities, and they carry on the same business.
Para 9: “Plaintiff is also informed and believes and based thereon alleges that adherence to the fiction of the separate existence of the defendants as distinct from one another would permit an abuse of the corporate privilege and would promote injustice in that it would permit these entities to evade their legal obligations.”
Para 10: “The individual defendants, Defendants, Henkes, Knopf, and Rising are personally liable for some, or all, of the claims alleged in this Complaint…”
Para 12: “Within the four (4) years immediately preceding the filing of this Complaint and at all relevant times, Plaintiff was employed by Defendants…”
Para 44: “Defendants have also engaged in “unfair” business acts or practices in that the harm caused by Defendants’ wrongful conduct alleged above outweighs the utility of such conduct and such conduct offends public policy, is immoral, unscrupulous, unethical, deceitful and offensive, causes substantial injury to Plaintiff and provides Defendants with an unfair competitive advantage over those employers that abide by the law…”
Section 10: OMARI BOBO v. PLPCC ET AL – Case No. 37-2017-00037348-CU-PO-CTL
17/10/06: Complaint_(ROA-1)
Para 2: “If Plaintiff is a member of the “Patients’ Consumer Cooperative Corporation” (PLPCC) why hasn’t he received any dividends? Where is all the money going? And would it be illegal to buy medical marijuana through a for-profit dispensary?”
Para 3: “Plaintiff learned that the Individual Defendants personally own and control not only the PLPCC, but five Shell Companies. These Shell Companies were created by the Individual Defendants within months after the PLPCC was formed in December 2014, and as the PLPCC’s marijuana business expanded. The Shell Companies have no public or visible business presence, except at the PLPCC’s location and the mailing address listed at Defendant Henkes’ accountancy office in La Jolla California.
Para 4: “Defendant Knopf is a director, and holds the executive offices at the PLPCC and each of the Shell Companies. Defendant Henkes is an accountant. He serves as the PLPCC’s Chief Financial Officer and the Shell Companies’ agent for service. Mr. Henkes appears to represent a single enterprise – the PLPCC and the Shell Companies, since he does not visibly advertise his availability for hire.”
Para 5: “It became clear based on these facts and others described in a related class action complaint against Defendants and the Shell Companies, BECK v. POINT LOMA PATIENTS’ CONSUMER COOPERATIVE CORPORATION, et al, which Plaintiff incorporates by reference, that Defendants were and are operating an illegal for-profit medical marijuana business that violates California criminal law and puts Plaintiff in potential legal jeopardy.”
Para 31: “Despite its huge revenues relative to such a small operation, the PLPCC has never made a “patronage distribution” to Plaintiff or any other member of the PLPCC. Nor does the PLPCC seek or allow participation by Plaintiff or any other member patron in the operation or governance of the cooperative.”
Para 32: “Instead, based on the above and on information and belief, the Individual Defendants use the Shell Companies as entities contracted by the PLPCC to unlawfully divert funds out of the PLPCC. This allows the Individual Defendants to hide substantial revenues from the (illegal for-profit) sale of medical marijuana in the Shell Companies, avoid showing a profit in the cooperative itself, and avoid paying out patronage distributions.”
Para 36: “The Individual Defendants and the Shell Companies are responsible for the harm to Plaintiff because each of them agreed to conceal operation of a for-profit marijuana business.”
Para 37: “The Individual Defendants, themselves, and as owners and operators of the Shell Companies were aware of the requirements of California’s medical marijuana laws, and were in agreement with the PLPCC and each other to divert revenues from the PLPCC in a manner calculated to avoid detection of their for-profit enterprise.”
Para 42: “The Individual Defendants govern the PLPCC, as well as the Shell Companies, such that a unity of ownership exists between them. The Shell Companies and the PLPCC use the same officers and/or employees of their medical marijuana business. Thus the Shell Corporations and the PLPCC are mere conduits for the affairs of each other.”
Para 53: “Given the considerable criminal risks from engaging in illegal drug sales, Defendants’ complete disregard for the legal wellbeing of Plaintiff and other members of the PLPCCC is outrageous. Defendant’s illegal for-profit enterprise, and subsequent attempt to conceal it, is so extreme it exceeds all bounds of legal behavior tolerated by the State of California and puts Plaintiff at risk of legal jeopardy, despite his best attempts to act in compliance with the law.”
Section 11: AUSTIN v. MALAN ET AL – Case No. 37-2019-00025668-CU-BC-CTL
19/05/20: AUSTIN v. MALAN Complaint (ROA-1)
Section 12: Removed
Section 13: Grand Jury Complaints (GJC)
23/12/18: GJC-Amy Sherlock re 8863 CUP Transfers_Redacted
23/12/18: GJC-Flores re DCC Letter
23/12/18: GJC-Cotton re Peerson Recusal
23/12/18: GJC-Cotton re POS Tax Fraud
23/12/19: GJC-Cotton re 6220 Federal Brown Act Violations
23/12/19: GJC-Attorney Jacob Austin re Atty Nguyen’s “Bluffing” Email
23/12/19: GJC- Phil Zamora re Balboa_Redacted
23/12/19: GJC-Complainant Redacted Complaint re Frivolous Appeals
23/12/24: GJC-Cotton re Chris Williams Assault
23/12/24: GJC-Cotton Complaint re Terrie Best
23/12/28: GJC- Amy Sherlock re Roder_Redacted
24/01/11: GJC-Amy Sherlock re McElfresh Indictement_Redacted
24/02/08: GJC-Tiffany Knopf re HO Report_Redacted
24/02/16: GJC-Amy Sherlock re PI Report of Duane Alexander_Redacted
24/02/19: GJC-Dina Goldberg re Payoffs to Government Officials_Redacted
24/04/06: GJC-Sherlock re DSD Invoice for Project No. 368347 for a PLANNING SUBDIVISION Deposit This is an especially troublesome document because DSD invoices for $7K, then shows it was paid AFTER Biker was dead and it’s for a CUP that was awarded to Biker on 06/17/2015 but classifies the bill as a deposit for a new SUBDIVISION. The biggest takeaway I have from this is all the other shady DSD processes were done by Firouzeh Tirandazi and Edith Gutierrez. Here they have a new player for this invoice, Jacqueline Beavers who no doubt did as she was told. Proof positive that Gutierrez and Tirandazi have been involved in illegal CUP processing within the City of San Diego Development Services Department.
Section 14: Media Litigation Related
17/04/25: ESPN “Uncalculated Risks” Article re Biker Profile In this ESPN article, beginning on page 7, we are introduced to Dr. Mark Cooper, a “longtime friend” of Steve Lake, Biker’s brother-in-law and business partner, who, upon hearing of Biker’s head injuries from racing pronounced his death as “textbook CTE.” Also see Page 7 of the Armorous Report where this diagnosis is discussed and at pages 53:22-54:14, Amy Sherlock Affidavit and pages 154-168, of the Medical Examiners Report whereby the ME stated that contrary to Dr. Cooper’s assessment, Biker did not suffer from CTE.
22/07/30: Dr. Mark Cooper License to Practice Revocation Unopposed by Dr. Cooper. What happens when a high functioning academic like Dr. Cooper takes such a dramatic change in his life to acquire all these DUI’s and not seem to care about the consequences? What transpired that made him take such an abrupt turn in his life?
22/09/07: Mark-Edward-Cooper-Obituary-San-Diego-CA.pdf It was 39 days after losing his license that Mark Cooper died at the age of 57. I repeat. What happened to Mark Cooper that made his series of DUI’s and license revocation change who he was for most of his life? For that I propose we look at what may have been a long, underlying source of regret by Dr. Cooper in which he may have provided cover with his CTE diagnosis to what he came to find out was actually a murder.
23/12/28: Evidence-Room Roder Report Video Reenactment of Michael “Biker” Sherlock’s Death
23/12/28: Evidence-Room Roder Written Report re Analysis of Michael “Biker” Sherlock’s PD and ME Findings.
23/12/30: Darryl Cotton Interviews Scott Roder re Biker Sherlock findings
23/12/30: Is CTE Being Over and Misdiagnosed?
Section 15: Exhibits
14/07/09: SAN DIEGO v MISSION VALLEY CORNERSTONE PROPERTY LLC_ COMPLAINT_ROA-1
14/08/15: SD v MVCP_ANSWER_ROA-19
15/06/05: SD v MVCP_JUDGMENT_ROA-62
14/10/15: Hearing Officer Minutes Not on the City’s Website
14/12/03: Hearing Officer Minutes Not on the City’s Website
14/12/17: Hearing Officer Minutes Not on the City’s Website
2014: PLPA 4 each Cash Payments to Biker Sherlock at pages 25, 31 and 32 totals $27,500
15/12/03: Michael Sherlock ME Report
2015: Leading Edge Real Estate (LERE) State Filings
16/03/17: Brad-Harcourt-Processes Two CUP No’s (368347 and 538985)
16/03/17: Amy Sherlock (Permit Holder) DSD_FOIA-CUP-DOCS @ 8863 Balboa Ave Licensee (Project No 467963)
17/01/18: Ninus Malan DS-191 Application of 01/18/2017 with DSD Approval on 01/30/18 (Project No. 368347)
17/06/21: STEPHEN-LAKE-ET-AL-v-COUNTY-OF-SAN-DIEGO Complaint
17/11/15: Ninus Malan (Balboa Avenue Cooperative) DSD MFG CUP @ 8859 Balboa Ave (Project No. 585435)
18/08/08: San Diego United Health Group, LLC – LLC-12 Filing
18/10/01: Voice of San Diego: Article on 8863 Balboa Ave. Dispensary Lawsuit
18/November: Mr.-Phil-Zamora-Interview-Audio-Transcript
18/November: Mr. Phil-Zamora-Interview-Audio-Recording.m4a
19/03/27: Adam Knopf Pasadena CUP This CUP, represented by HdL, has Knopf stating he has an ownership interest in Balboa Ave. @ pages 1 and 20.
19/12/30: Cotton to Sherlock Initial FB Introduction and PMs
21/03/24: Phil Rath Lobbying Report
20/01/15: Amy Sherlock to Steve Lake Texts re Cotton
19/06/06: San Diego Planning Commission Hearing – Commissioner Hofman Statement Transcript
19/06/06: San Diego Planning Commission Hearing – Commissioner Whalen Statement Transcript
19/11/01: MALAN v KATTO reply
19/12/30: Darryl Cotton introduction to Amy Sherlock FB PM’s 12/30/19 thru 03/15/20
2017-2020: Amy Sherlock and Stephen Lake Text Messages
20/02/04: Sherlock and Cotton emails to City of San Diego Mayor Faulconer
22/06/07: Blake Law Letter to Sherlock re Meet and Confer
22/06/17: Sherlock’s Reply to the Blake Law Meet and Confer Letter
22/08/15: James Bartell Lobbyist Project Comparisons and Analysis with Exhibits
22/09/20: Sherlocks-FOIA-PRA 22-4995-Request-DOCS.pdf
22/09/28: Responsive Docs 1 to PRA 22-4995_598124 Project Issues as of 03/05/2018
22/09/28: Responsive Docs 2 to PRA 22-4995_598124 Project Status as of 07/24/2019 Of note, when fees are paid the amounts are shown on the Project Status.
22/09/28: Responsive Docs 3 to PRA 22-4995_644432 Certificate of Compliance
22/09/28: Responsive Docs 4 to PRA 22-4995_644432 General Application dated 05/28/2020
22/09/28: Responsive Docs 5 to PRA 22-4995_644432 Geotechnical docs dated 12/06/2019 How is it that a Geotechnical document is submitted AFTER Project No 598124 had final approval?
22/09/28: Responsive Docs 6 to PRA 22-4995_644432 Project Issues as of 08/06/19 This is being treated as a new plan submittal.
22/09/28: Responsive Docs 7 to PRA 22-4995_644432 Project Status Report as of 07/26/2020 Of note, the Geotechnical survey that was provided under the previous responsive docs is not even listed on the Project Status or Issues Report. Also unlike Project No. 598124 the amount billed or paid on invoice 941070 is not shown.
22/10/12: Sherlock Related Cases
22/11/30: Armorous Private Investigative Report re Michael Sherlock w Exhibits
23/03/17: Mr. Phil Zamora Affidavit
23/11/13: Travis Cleveland DSD admits to Amy having been granted the CUP upon Biker’s death
23/04/19: 1215 Nutmeg HO Report No HO-23-019
23/05/22: MALAN v KATTO Opinion (D077602)
23/11/22: Questionable Cups-1215 Nutmeg
24/01/11: Attorney Flores Letter to DA Summer Stephan re Biker Sherlock’s Suicide COD
24/01/30: Cotton to Cleveland email re missing HO Minutes
24/02/25: Sherlock DEC Draft
24/02/28: REWARD POST
24/04/05: Judge Mangione Tentative Ruling re NORTH PARK TEN LLC v. CA DEPT OF TRANSPORTATION-Shall Language
24/04/09: Cotton-Razuki Cases
24/04/09: CA State Auditor Cannabis Licensing Report 2023-116
___Subsection A ___
23/01/10: Sherlock Attorney Flores’s Multiple Parties Demand Letter
23/01/17: Department of Cannabis Control (DCC) Reply to Flores’s Demand Letter
23/01/18: Flores to DCC Reply Letter
In addition to the email exchange that went on between Flores and multiple parties re the disclosure laws, which are meant to be enforced, not disregarded, by these agencies, most notably the DCC, we can see Amy Sherlock’s FOIA request to DCC re the Ramona Street property @
22-08-15-Amy-Sherlock-DCC-FOIA-request_1210-Olive-Street-Ramona_Redacted.pdf
As can be seen by the DCC reply, Amy was promised, by the unidentified staff member @ DCC, Legal Affairs Division, the requested information within 120 days. DCC has failed their ministerial duties to provide Amy with ANY of the requested information. On the other hand, we see that the DCC, Legal Affairs Division, can be quite responsive to FOIA requests when that request does not involve an attorney Andrew Flores-Amy Sherlock matter. Here, you can see how identified staff-Lullette McManus @ DCC-responds to Mr. Dan Tudor’s FOIA request within just 60 days [emphasis in orginal]. Most notable in their responses, is that the mandatory disclosure language Flores was seeking confirmation of in his correspondence with DCC, is addressed in DCC application forms. (Below both BCC and DCC are being used interchangeably)
23-03-09_Dan-Tudor-to-DCC-FOIA-request_MOM-SLO-LLC-MOM-WEHO-LLC-MOM-EC-LLC-MOM-INC.pdf
DCC Response Documents
C10-0000728-LIC_Combined_APPLIEDRedacted.pdf State BCC Notice and Request Form Submittal
Page 10: Change in Financial Interest Holders – 15023(d)
Page 16: Death, Incapacity, Receivership, Assignment of Creditors, or other Event Rendering an Owner Incapable – § 15024 (a)
Pages 20-26: requires existing and new ownership disclosures. Of particular note, on page 24, DCC has redacted the ownership percentage required for mandatory disclosure. Was this absence of the specific percentage allowed a deliberate obfuscation, as this information is published numerous places in DCC forms. On page 26, DCC has also redacted the legally mandated maximum percentage of financial interest/ownership that may be transferred WITHOUT disclosure. This can be found in an email communication that occurred with Mr. Greg Donkerbrook, in DCC’s License Modification Unit sent to MOM USA LLC Chief Legal Officer, Mr. Mark Cordona. Why did DCC redact the ownership percentage values in the documents they provided under the FOIA request when the 20% or greater value is established law under Business and Professions Code §§ 26038 and 26057?
Page 30: DCC form Section A requires ownership percentage. Section B is the Sanctions Declaration re unauthorized commercial activities.
Page 31: Mandatory Submission
“Submission of the requested information is mandatory unless otherwise noted on the application. The Bureau of Cannabis Control (Bureau) will use the provided information to determine qualification for licensure, per section 26051.5 of the Business and Professions Code and the Information Practices Act. Failure to provide any of the requested information will result in the application being deemed incomplete by the Bureau. The Bureau will also use this information to enforce licensing standards set by law and regulation, update and maintain current licensee information, and for mailing purposes.”
Financial Information
“To ensure accountability and preserve the State’s ability to adequately enforce against all responsible parties, the Bureau is authorized to collect detailed information regarding individuals with a “financial interest” in the commercial cannabis operation under section 26051.5 of the Business and Professions Code. “Persons with a financial interest” means an investment into a cannabis business, a loan provided to a cannabis business, or any other equity in a cannabis business that is not qualified as an owner. It does not include persons whose only interest in a licensee is an interest in a diversified mutual fund, blind trust, or similar instrument. The applicant must provide the following information for all non-owners with a financial interest: their name, date of birth, and type of government issued identification and identification number.”
Page 33: Public Information
“The Bureau makes every effort to protect the personal information provided by license applicants. Application information may be disclosed, however, as permitted in response to a California Public Records Act request (Government Code section 6250 et seq.), as permitted by the Information Practices Act (Civil Code section 1798 et seq.), to another government agency as required by state or federal law, in response to a court or administrative order, a subpoena, or a search warrant. Pursuant to the California Public Records Act (Title 1, Division 7, Chapter 3.5, Government Code sections 6250-6277), on request, the Bureau discloses licensee information including, but not limited to:
• Name
• Mailing address
• License number
• License status
• Original license issue date
• Last license renewal date
• License expiration date
• Disciplinary action
• Copy of license renewal applications
• Copy of license application (excluding personal information such as birth date and social security number)”
Razuki, Malan and Geraci have all admitted, UNDER OATH, to knowingly and unlawfully failing to disclose their ownership interests in numerous cannabis dispensaries. Razuki actually ACKNOWLEDGES that they engage in the strawman/”proxy” practice to own undisclosed interests in licensed cannabis businesses. This failure to fulfill these disclosure requirements, and having instead knowingly engaged in the proxy practice, means none of these individuals should be able to hold an adult-use cannabis license. Sadly, to date, neither the DCC, nor any court, has not seen fit to enforce these laws evenly. Despite both federal and state Constitutions’ mandating that all citizens receive equal protection of the law, in re: Amy Sherlock, the DCC and the California’s Judiciary have egregiously, blatantly and wrongfully, disregarded and deliberately trampled (see anti-SLAPPs) on her rights!
(See pg’s 5;22-7;8 “on paper” statements @ https://www.justice4amy.org/wp-content/uploads/2023/02/18-07-10_RAZUKI-v-MALAN-ET-AL-Complaint_ROA-1.pdf )
C10-0000952-LIC_Combined_APPLIEDRedacted.pdf Financial Information Form
C10-0001049-LIC_Combined_APPLIEDRedacted.pdf State Cannabis License Retailor Information with disclosure requirements.
C10-0001176-LIC_Combined_APPLIEDRedacted.pdf Business Formation Documents
CCL18-0002436_Combined_APPLIEDRedacted.pdf DCC Adult-Use License Checklist (CEQA is not a check listed item. Why not?)
Q: OK so Dan Tudor got a response to a FOIA request and Amy did not. Why is this dispositive information one might ask?
A: Despite the fact that there is undisputable evidence that the DCC is subject to mandatory, not permissive language. (Contrary to what attorney Gina Austin would have the courts believe on one day and not believe on an another) the language says “shall” there can be no question this is mandatory. Mr. Dan Tudor, a concerned citizen, submitted a FOIA request to determine if Mr. Helios Dayspring (a convicted felon for illegal cannabis activities) had any undisclosed interests in any of the entities listed in his request. As can be seen by the information DCC provided, Mr. Dayspring’s name appears on several of the unredacted documents. Mr. Dayspring stated in a sworn declaration, (which interestingly enough shows the unredacted ownership percentages/financial interests) for which he had provided financing to, amongst others, MOM USA LLC. Helios further, explicitly states that he had disclosed his cannabis related crimes during the application process and was denied based upon him having committed those crimes. Is there any wonder criminals like Razuki, Malan and Geraci would, knowing the purported potential consequences, would engage in the strawman/”proxy” practice to circumvent the legal requirements to even apply for such a license?
Helios Declaration, Pg. 2;13-27 @ https://151farmers.org/wp-content/uploads/2018/04/Case-21CV-0734-Declaration_Dayspring_Megans-Organic-Market-vs-City-of-SLO.pdf
One might surmise that DCC responded to the Tudor FOIA request and not Sherlock’s request because, unlike in what has happened to Amy Sherlock in San Diego, there WAS significant media coverage surrounding these Helios’ unlawful activities. Until very recently, Amy Sherlock wanted to remain publicly silent about what had happened to her. She wanted the court documents to speak for themselves. That is no longer the case! Having exhausted all other avenues Amy is now forced to seek redress of here grievances which include now doing interviews to expose the corruption that has influenced San Diego adult-use cannabis licensing. In this link we can hear her first interview on Debbie Peterson’s Corruption Chronicles, co-hosted by Darryl Cotton, podcast series in Corruption Chronicles, Canna-Greed Series EP-1 @
Canna-Greed EP-1 with Amy Sherlock
As a former mayor of Grover Beach, CA, Debbie Peterson penned “The Happiest Corruption” as an insider expose into what takes place in local politics corruption and the cannabis pay-to-play environment that she personally witnessed during her tenure as mayor.
It is literally, in the first three pages of her book, that Ms. Peterson describes the cannabis-cabal that infiltrated her city and turned it into one where “the press and the public bought into the repeated lies of the con-men, the cabal co-opted whole city councils, county departments, and businesses with threats and promises: both of which were delivered on.” (See The Happiest Corruption @ Page 1 ¶ 4)
Which leads us back to the media coverage surrounding convicted cannabis felon, Helios Dayspring and his activities which, as it relates to Amy’s matters, show “selective processing” of the applications required to secure these adult-use cannabis licenses.
“In recent filings made as part of the litigation between his former company, Natural Healing Center, and the city of SLO, Dayspring alleged that he personally helped bankroll the city’s other two cannabis dispensaries—signing loan agreements with Megan’s Organic Market (MOM) for $800,000, and SLOCal Roots for $1 million in early 2019.” https://www.newtimesslo.com/news/dayspring-claims-he-bankrolled-other-slo-cannabis-dispensaries-companies-and-city-push-back-12792214
“Dayspring, a local marijuana mogul, transferred ownership of his retail cannabis shops to his girlfriend Valnette Garcia in 2020, before he pled guilty to tax fraud and bribery charges. In Oct. 2021, city staff canceled approval for the Natural Healing Center cannabis shop because Dayspring had not disclosed the bribery or the fraud during the application process.” https://calcoastnews.com/2023/02/judge-rejects-daysprings-pot-shop-suit-against-slo/
“As part of his plea in October 2021, Dayspring admitted to giving the late San Luis Obispo County District 3 Supervisor Adam Hill $32,000 in cash, money orders, cannabis products, and meals in exchange for votes that would favor Dayspring’s cannabis businesses. In May 2022, a judge sentenced him to 22 months in prison.” https://www.ksby.com/news/local-news/dispensary-founder-who-bribed-public-official-transferred-out-of-prison
What we are left to consider is not only how Razuki and Malan can engage in owning and operating adult-use cannabis dispensaries but how is it that the lax, or better put, “selective enforcement” of the disclosure laws, could cost Helios Dayspring licensing opportunities in SLO by admitting in the licensing application he had engaged in criminal cannabis activities and neither Razuki or Malan do not disclose Razuki having been previously sanctioned for illegal cannabis activities but, even when this information is provided to the courts and DCC, Razuki is allowed to maintain those greater than 20% interests? Indeed, after 6 years of litigation, this case is scheduled to go to a jury trial to decide which of these two criminals get Amy Sherlock’s dispensary and the profits derived from its operation.
___End Subsection A___
2005-2022: 8863 Ste E Balboa Ave Transfer History
23/03/17: Amy Sherlock’s FOIA Request to DCC re CUP Documents and Responses
23/03/17: Zamora Affidavit 23/03/17
23/03/20: Cotton Mass Email re Zamora Affidavit Antitrust Law Violations in Cannabis Licensing
23/04/11: Atty Elia Email re Razuki-Malan Motion to Dismiss
23/04/29: CA Cannabis Disclosure Regulations in 4 CCR 15003, 15004 and 15024
23/05/24: Could This Happen in La Jolla? A District 4 CUP Comparison. While investigating unusual DSD processing of other adult-use cannabis CUPs I came to find out, confirming my wildest suspicions, that DSD does not just play favorites when it came to excluding me from my rights as a licensee. What they did at the 6220 Federal Blvd. project is simply an incredible abuse of power and an outright attempt to steal Mr. Cotton’s property rights as it relates to owning one of these highly sought after CUPs. This is one powerful read that documents the unbelievable lengths DSD went to in an effort to perfect this scheme.
23/07/21: San Diego for Sale This is the cover summary for the Steering Document and CUP application spreadsheet for all cannabis licensing in the City of San Diego between 2014 and 2023.
23/07/29: 9212 Mira Este Court – A Grant Deed Analysis with Supporting Documents
23/07/31: 9350 Trade Place and Associated Entity Documents
HNHPC, Inc. v. DCC ET AL
21/09/05 HNHPC Petition for Writ of Mandamus (ROA-2)
22/03/02 Order After Hearing (ROA-68)
22/04/25 Designation of Record on Appeal (ROA-80)
23/08/02 COA Opinion Reversing Lower Court Decision (ROA-94)
HNHPC Related Cases
19/06/05 ZIMMERMAN v. CITY OF VISTA Petition_for_Writ_of_Mandate_Case No. 29400
21/08/05 ZIMMERMAN v. CITY OF VISTA Notice_of_Entry_of_Judgment_Case No. 29400
21/04/21 ZIMMERMAN v. CITY OF VISTA_Petition_for_Writ_of_Mandate_Case No. 17596
23/09/18 ZIMMERMAN v. CITY OF VISTA_Notice_of_Entry_of_Judgment_or_Order_Case No. 17596
22/03/28 CATALYST-FRESNO v CITY OF FRESNO EP APP for TRO and OSC re Preliminary Injunction
22/08/05 CATALYST-FRESNO v CITY OF FRESNO Real Parties in Interest: Authentic 559 LLC -Notice of Demurrer and MPA’s
22/03/28 CATALYST-FRESNO v. CITY-OF-FRESNO Ex Parte TRO & OSC See Pg. 10 re Tony Huang who was ineligible for a license and where “shall” is argued.
SB-643 Legislative Analysis Files (Sumner Email Chain)
23/09/21 EMAIL Attachment as 2023/02/201520160SB643_Assembly-Appropriations
23/09/21 EMAIL Attachment as 2023/02/201520160SB643_Assembly-Business-And-Professions-1
Highlighted Version of 2023/02/201520160SB643_Assembly-Business-And-Professions-1 Page 1: Summary-Establishes a comprehensive licensing and regulatory framework… Page 2: Administrative Provisions ¶¶ 1 (b)(c) and 2(a) ‘authority to issue, suspend or revoke conditional licenses…’
Page 3, ¶ 3 (d) ‘Establish procedures for the issuance…conditional licenses.’ Page 3, ¶ 3 (g) ‘Taking Action with respect to an application’ Page 3, ¶ 4 (a) ‘Procedures for the issuance…’ and ¶ 4 (e) ‘Qualifications for licensees.’
Page 4 Immunities and Exemptions ¶ 10 ‘…no longer exempts…from criminal prosecution and instead extends that criminal immunity to…’
Page 5 ¶ 15 (a)(i) ‘name the ownership interest or entities…’ and (g) ‘Provide a statement signed under penalty of perjury that the information is true.’ and ¶18 ‘Prohibits the Office from issuing a conditional license…who has been determined to have violated an applicable local ordinance, as specified.’ [This begins with PROHIBIT which is a stronger word than ‘shall’ and leaves no ambiguity as to legislative intention.] ¶ 21 ‘Requires an application for a conditional license to be denied, and a conditional license suspended or revoked, for a past felony conviction for… a felony conviction involving fraud or deceit, or any violent or serious felony conviction, as specified.’ [Razuki has been convicted in federal court for conspiracy to commit kidnapping. He should not be in front of the Sturgeon court in RAZUKI v. MALAN arguing that, as a felon, he has undisclosed ownership interests in 8863 Balboa Ave.
Page 6, ¶ 23 ‘Authorized the Chief to deny, suspend or revoke a conditional license when a conditional licensee, applicant, employee, partner, officer, or member of an entity conditionally licensed for specific reasons such as making untrue or misleading statements, engaging in conduct that constitutes fraud…’ ¶24 Sets the following as reasons a conditional license shall not be approved; (c) ‘The applicant has knowingly answered a questions falsely…’ (d) ‘the applicant, or any of its officers, directors, members, or shareholders has been sanctioned…'(e) ‘…will not violate an applicable local law or ordinance…’[Even if the local law or ordinance being broken does not give rise to local enforcement, it doesn’t mean that the issue does not violate 24 (e)]
Page 8 ¶ 41 ‘Requires the Office to delegate the authority to enforce the requirements of this part , including regulations to a local government…’
Page 9 ¶ 49 Requires a facility…to notify appropriate law enforcement authorities within 24 hours after discovering significant discrepancies…diversion, theft, loss…’
Page 14-18 ‘Resolve many of the issues…California voters made it clear…needs to be comprehensive regulation…by taking a multi-billion dollar industry with virtually no regulations and placing the entire product chain into a regulated environment…Creating a uniform policy toward all aspects of medical marijuana will be a giant step in protecting consumers but the public at large, as well as our water and environment.’
Page 21-24 POLICY ISSUES; ‘dual licensure scheme…require a licensee to verify that they are not located near schools in order to quickly weed out ineligible licensees[as defined within the code. Not just schools]… As a result there may be some inevitable confusion between the Office and local government… and trigger enforcement.
23/09/21 EMAIL Attachment as 2023/02/201520160SB643_Assembly-Business-And-Professions-2
23/09/21 EMAIL Attachment as 2023/02/201520160SB643_Assembly-Floor-Analysis-1
23/09/21 EMAIL Attachment as 2023/02/201520160SB643_Assembly-Floor-Analysis
23/09/21 EMAIL Attachment as 2023/02/201520160SB643_Assembly-Health
Duane Alexander and Prime Harvest, LLC
22/05/11: Form-1A-Prime-Harvest-Offering
22/12/02Form-1-A-A-Prime-Harvest Offering
23/01/19: Form-1-A-A-Prime-Harvest-Offering
24/02/06: INVESTIGATIVE REPORT
Sumner Email Chain referencing Flores Emails to DCC
23/01/10: Sherlock Attorney Flores’s Multiple Parties Demand Letter
23/01/17: Department of Cannabis Control (DCC) Reply to Flores’s Demand Letter
23/01/18: Flores to DCC Reply Letter
Sumner Email Chain referencing Hurtado Email Attachments
23/09/21: COA Opinion D075028_RAZUKI v. MALAN
23/09/21: COA Opinion D081109_SHERLOCK v. AUSTIN
23/09/21: COA Opinion HNHPC v. Department-of-Cannabis-Control_-94-Cal.-App.-5th-601
