Robert Hurford Hale, Sui Juris
3243
Congressional Circle
Fairfield
94534
CALIFORNIA,
USA
tel: 707-426-1841
In Propria
Persona
All
Rights Reserved
Superior Court of
California
Solano County
REDWOOD
PLAZA INVESTMENTS, L.P., ) Case No. FCS025327
)
v. ) DEFENDANT HALE’S SECOND REQUEST
) FOR MANDATORY JUDICIAL NOTICE:
PGM,
INC., )
PETER
G. MOZSARY, ) Evidence
Code, section 453;
ROBERT
H. HALE, and ) California
Business and
DOES 1 through 10.
) Professions Code, secs.
6067, 6068;
---------------------------------) 18 U.S.C. 1341, 1964 (Civil
RICO).
COMES NOW Robert H. Hale, Sui Juris, a named Defendant in the above
entitled case, without waiving or conferring any jurisdiction, specifically to
request that this honorable Court take mandatory judicial notice of the fact
that, on February 3, 2005, a SECOND NOTICE AND DEMAND FOR EXHIBITION OF
CERTIFICATE was mailed via First Class United States Mail to Mr. Kirk E. Giberson, Counsel for the Plaintiff.
A true and correct copy of said SECOND NOTICE AND
DEMAND is attached hereto and incorporated by reference, as if set forth fully
here.
In reply to same, also via U.S. Mail, Mr. Giberson has refused to produce a proper license to
practice law in the State of California, which conforms fully to the
requirements imposed by sections 6067 and 6068 of the California Business and
Professions Code (“a certificate of oath shall be indorsed upon his
license”). See 18 U.S.C. 1341.
A true and copy of Mr. Giberson’s
written refusal is attached hereto and incorporated by reference, as if set
forth fully here.
Also attached is evidence that The State Bar of
California has now been served with a proper and lawful federal SUBPOENA IN A
CIVIL CASE. Said SUBPOENA commanded that
State Bar to produce certified copies of all licenses to practice law
with oaths of office indorsed thereon by all members of The State Bar of
California during the ten (10) calendar years beginning on January 1, 1994 A.D. and ending on December 31, 2003 A.D., as required by section 6067 of the
California Business and Professions Code, and as authorized by the federal
statute at 18 U.S.C. 1964(a) (Civil RICO).
On this point, see this Court’s Civil Case Cover
Sheet for the “RICO” category (item 27) over which this honorable Court does
enjoy original jurisdiction.
In particular, see also Tafflin
v. Levitt, 493 U.S. 455 (1990), and Lou v.
Belzberg, 834 F.2d 730, hn.
4 (9th Cir. 1987) (California State courts have concurrent
jurisdiction of Civil RICO claims).
Lastly, the Civil RICO statute at 18 U.S.C. 1964(c)
authorizes triple damages (3x). See Agency
Holding Corp. v. Malley-Duff & Associates,
483 U.S. 143, 151 (1987) (“the mechanism chosen to reach the objective in both
the Clayton Act and RICO is the carrot of treble damages”), and Rotella v. Wood et al., 528 U.S. 549 (2000) (“the provision for treble
damages is accordingly justified by the expected benefit of suppressing
racketeering activity, an object pursued the sooner the better”).
True and correct copies of said SUBPOENA IN A CIVIL
CASE, PROOF OF SERVICE and related documents are also attached hereto and
incorporated by reference, as if set forth fully here.
Defendant Hale is correctly informed that The State
Bar of California has now failed to comply with said SUBPOENA within the stated
deadline, and Defendant Hale now believes that The State Bar of California are
in contempt of court for their failure to comply.
Dated: February 10, 2005
Signed: /s/ Robert H. Hale
___________________________________________
Printed: Robert H. Hale, Sui Juris
I, Robert
H. Hale, Sui Juris,
hereby certify, under penalty of perjury, under the laws of the United
States of America, without the “United States” (federal government),
that I am at least 18 years of age, a Citizen of ONE OF the United States of
America, and that I personally served the following document(s):
DEFENDANT HALE’S SECOND
REQUEST
FOR MANDATORY JUDICIAL
NOTICE:
Evidence Code, section 453;
California Business and
Professions Code, secs. 6067, 6068;
18 U.S.C. 1964 (Civil RICO)
by placing one true and
correct copy of said document(s) in first class United States Mail, with
postage prepaid and properly addressed to the following:
[PLAINTIFF’S ATTORNEY]
Mr. Kirk E. Giberson
Hefner Stark & Marios
2150 River Plaza Dr. #450
Sacramento 95833
CALIFORNIA, USA
[CLERK OF COURT (2x)]
600 Union Avenue
Fairfield 94533
CALIFORNIA, USA
Dated: February 10, 2005
Signed: /s/ Robert H. Hale
___________________________________________
Printed: Robert H. Hale, Sui Juris
All Rights Reserved
without Prejudice