_{CALIFORNICACTION : CORRUPTION IN CALIFORNIA STATE}

Abstract ot the complaint filed at Federal Court of San Jose (California), the 08 of December 2015). 

Involved persons: 
- Jack LADD ;

- Lyle WOLLERT ;

- James PETTIT ;

- Ryan YORK;

- Phil WOWAK;

- CJ. LUCAS;

- Cynthia VELASCO ;

- Cynthia DRAGER ;

- Bob JORGENSON ;

- GAIL LOUIS ;

- Chris BAGGALEY ;

« INTERINSURANCE EXCHANGE OF THE AUTOMOBILE CLUB » ;

- «AAA SOUTHERN CALIFORNIA» ;

- Robert T. BOUTTIER ;

- John F. BOYLE ;

- David LANG ;

- Scott KWIERAN ;

- James ROBBINS ;

- Glenn RENWICK ;

- Chuck JARRET ;

« PROGRESSIVE WEST INSURANCE COMPANY »  ;

- Tom HAINES ;

- Paul VINCENT ;

- Joseph A. FARROW ;

- « California Highway Patrol » ;

- Salvador ORTIZ ;

- Nancy FLORES ;

- Dave JONES ;

- « California Department of Insurance »;

- Jean M. SHIOMOTO ;

- « Department of Motor Vehicles of California" ;

- Edmund Gerald "Jerry" BROWN, governor of California

« State of California » ;

- Christopher APPLETON, lawyer

- Steven J. DAWSON, lawyer

- Richard S. GOWER, lawyer

- Craig MODLIN, lawyer

- Rebecca CONNOLLY. judge at Santa Cruz court

- Richard W. WIEKING, federal clerk

- Patty CROMWELL, federal clerk

- « sub »judge Edward J. DAVILA,

- federal judge Howard R. LLOYD,

STATEMENTS OF FACTS.

Preamble. The origin.

Plaintiff, Laurent GRANIER has had a car accident when driving his car, a classic british one, a 53 MG, the afternoon of the 09th of october 2014, around 3 pm, on the highway 9 in the direction from Felton to Boulder Creek. Perri Noelle MONTGOMERY arriving fast behind him in her SUBARU, was unable to stop, and even to avoid Laurent GRANIER's car, and she hit it in the right side of the back. She is 100% responsible.

Neighbors having heard the collision, went outside and called 911. Ambulance arrived first, and Police later. Because Plaintiff, Laurent GRANIER had pain in his back, left shoulder, his neck and his left bottom, he has been taken by an ambulance to the Hospital of Santa Cruz (Dominican). By this time, Police officer who did the report, called a company, « LADD's » from Felton, agreed by « AAA », to tow the two cars.

Before to be taken by the ambulance to hospital, Laurent GRANIER gave to the Police Officer a copy of his « AAA » membership (« Premier », which is the highest grade) in order to do the work under his own privilege.

Since this date and time, Jack LADD, owner of « LADD'S Auto Body & Towing », and Lyle WOLLERT, manager of « LADD'S Auto Body & Towing »  had the responsibility to keep the car for the owner, Plaintiff, who became their client.

General Environment.

For the following days, Plaintiff, Laurent GRANIER being victim, has had to manage his body pain, and his property damages, in order to avoid an increase of each of them, and the creation of new ones in his private and professional lifes, caused by all the hassle coming from the accident.

During this difficult time, Laurent GRANIER was alone, being not helped by his own insurance company, « PROGRESSIVE/DRIVE », and let alone by the insurance of the other driver, in order to settle his expenses, his losses, like an hotel because he had to stay in this area to settle the problems caused by the accident, body pain and property damages.

Yet, the day after the accident, he filed the claim to his insurance. But, he has had no help, no assistance, no advise like the simple fact how and what to do. The claim manager of « PROGRESSIVE/DRIVE » has even closed the claim about the accident.

Fortunately, his insurance agent helped Laurent GRANIER by explaining him that, as victim, and as the other person who caused the accident was identified, and insured, Plaintiff had to do everything by himself, his own insurance company having not to take care of his situation anymore. And so, Plaintiff had to contact directly the insurance of the driver who victimized him...

The following monday, having no help, no assistance from his own insurance, Plaintiff has had to get information about the other driver and her insurance, by going to Police station.

The information about the insurance company of the adverse party was noted only under the name « CAA ». In fact, it was a trickery made by this insurance company because, in addition not to be the real name, it was indeed the insurance company under « AAA SOUTHERN CALIFORNIA », the Automobile Club which is different of the one, named « AAA NORTHERN CALIFORNIA ».

For information, the driver who caused the accident, Perri Noelle MONTGOMERY, has her address in Santa Cruz, Northern California.

In fact, with only the name « CAA », which is wrong, but fake too, and not registered as is at « California Department of Insurance » (CDI), Plaintiff was lost, even not knowing who to call. His insurance agent helped him to find and to reach the company so-called « CAA ».

The first claim representative of the so-called insurance company « CAA » was disrespectful and dishonest, trying yet, in association with her internal colleague lawyer, to screw Plaintiff, using the advantage of the situation of weakness of the victim, because they wanted yet to take the car since the beginnng.

Laurent GRANIER as « AAA premier member » at « Northern California » went to the branch in Santa Cruz to get help. He got it by the assistant branch manager who called the « AAA SOUTHERN CALIFORNIA INSURANCE » and finally by the fact that the claims manager, LJ. LUCAS, took the case.

Plaintiff talked to her from the phone of this branch in Santa Cruz. In fact, it was a trap, and she was there to win time and to save money for her company, so-called « AAA SOUTHERN CALIFORNIA Insurance », and so by getting more advantage by increasing the difficulty of Plaintiff situation.

In the accident, Plaintiff's laptop was broken. Being his important tool because Laurent GRANIER is writer, author, inventor, theoretician, Master Philosopher, and so, having inside a lot of confidential and important documents, information and data, he had to repair it as soon as possible.

Laurent GRANIER got his laptop back ten days later, on monday 20th of october 2014. He paid with his own money, and sent at once the invoice to CJ. LUCAS. But, instead to be professional according her duty, to be fair and honest according that the victim has had to pay in advance expenses for which is not responsible, CJ. LUCAS did not sent the check for the money that the insurance company, whatever its real name, owed to him, yet. By the time of all the previous week, Laurent GRANIER tried to make understand to CJ. LUCAS that his MG was not a junk, even it was 61 years old, and had a great real value. She needed several days to understand that she had to send an expert to evaluate the damages and the value regarding its condition. The expert, Steve DOUGLAS, came on monday 20th of october 2014 to « LADD'S Auto Body & Towing »  in Felton.

In fact, by this time, CJ. LUCAS, Claims Manager, was building a dishonest strategy in order to screw Plaintiff.

She was insisting to ask proof of the cost of his car, while « CAA » or whatever its real name, as any insurance company has to pay victims for the replacement value, and not its cost, or its purchase price.

Before that CJ. LUCAS decided to send an expert, Laurent GRANIER sent her, pictures of his car before the accident, and after. She can check by herself that the car was in a pristine condition, fully restaured several months earlier. She asked him too, if he wanted to keep the car. Laurent GRANIER explained to her that he can not decide to keep it or not before to know its value as accidented car. Indeed, she prepared yet to screw Plaintiff. She began by saying him, later, there was « limits », meaning, about the amount of the total of his damages. Laurent GRANIER replied to her that he did not care, it was not his business, nor his problem, that he was not her client, and they have to pay the damages caused by their client. Period.

She won two days more, knowing yet the tuesday 21st of october that the car was total loss. A total loss according herself, without proof nor justification, even not the expertise she asked for. But, she waited one day more to say to Laurent GRANIER, Plaintiff, that his car was estimated at the strange and low price of $17,086.20. It was despite the fact, that two days before, Laurent GRANIER sent to CJ. LUCAS an ad about the same car, 53 MG TD, in the same condition but not the same color, for sale by a professional at $39,990.

So, since the beginning CJ. LUCAS, claims Manager at « ARCADIA CLAIMS » tried to win time, and to take advantage on the victim she was supposed to alleviate, to reduce and to erase his damages, his difficulties, his distress, his pain. Indeed, she increased the difficulty and the pains of the Plaintiff, and even she created new ones, in order to get more and more power, causing more and more damages on his life, private and professional, and so, to force him to accept the unacceptable offer of less than the half of the value of his car. She even used blackmails with the money she had to repay for the repair of the laptop, with the running storage fees, and she avoided to mention Plaintiff's expenses for the rental car, for the hotel. Her email was just a text, with no document, no expertise. Nothing real and official, but just an unprofessional, careless, provocative, disrespectful text containing this below, even not including the tax for the tow and the storage, nevertheless the fact she had to pay those expenses too :

Vehicle value $17,086.20

Tax (8.75%) $1,495.04

Prorata lic fees $172.00

Total $18,753.24

Computer $369.94

Tow and Storage $180 tow

15 days at 75 p/day $1,305.00

Total claim $20,428.18

At once, Plaintiff sent to Defendants, CJ. LUCAS and her manager, Cynthia VELASCO, several emails under the title of « Re: Claim: 011665727 FORMAL NOTICE of CRIMINAL COMPLAINT and CIVIL LAWSUIT FOR CRIMINAL OFFENSES » to ask them proofs about this fanciful estimate of his car -expertise report-, and by the same time, all legal information about the company she worked for and spoke and decided in its name, and the name of its highest responsibles. None of them replied, but CJ. LUCAS took care, to send three times the same email from a prior email, so with only the title « Claim: 011665727 », and so, in order to avoid to give to Plaintiff the proof she had received his FORMAL REQUEST. For information, copy of each FORMAL NOTICE sent by Plaintiff to CJ. LUCAS, has been sent to Cynthia VELASCO, Steve DOUGLAS, « Property Damages Appraisers, Inc. » (the company the latter works for), and Daniel WARNICK, Claims Manager at « PROGRESSIVE/DRIVE ».

Laurent GRANIER, as yet victim, and being screwed, facing ingratitude, disrespect, dishonesty, bad faith from the representatives of the insurance company which has to pay him, decided not to give up anything anymore, and asked for all his losses.

So, in each FORMAL NOTICE, he claimed :

$40,000 for the value of his car ( few evaluations on internet give a price up to 50,000);

$5,000 for the sentimental value about the loss;

$5,000 for the additional value of his car having black original plates of State of California;

$4,400 for tax and registration;

$5,000 for his future personal expenses to find a new car like this one, expecting at least 3 months;

$5,000 to travel and to check the car before to buy it, because most of time pictures in ads are not the reality and we go for nothing;

$100 daily for the loss of pleasure to use his car because it is not a commuting car but a pleasure, what is proved by its nature, classic car, but also by the fact it is a convertible, and it is declared at his insurance as a pleasure car, so starting from the day of the accident until the day he'll find one exactly the same, condition and color;

$100 daily to rent a car until the date he'll find a new one to replace it;

$350 for the rental car of the first week ;

$1,300 for the two weeks at hotel which is not finished at the day of the complaint ;

So, a total of $72,050 for property damages and expenses, without the damages caused by their deliberate dirty and unlawful behaviour on his health, on his life and on his work.

Being CEO of a corporation in California and a Company in London, from one side, and author, inventor, theoretician, master philosopher, from another one, all those troubles, all those hassle disturbed his mind, his main tool, and so his lifes, professional and private, and so, Plaintiff was asking at least $500,000.

Plaintiff, Laurent GRANIER filed a complaint to « California Department of Insurance » (CDI) for the lacks and misconducts of some responsibles of the insurance company, self-named « AAA SOUTHERN CALIFORNIA INSURANCE ». But « CDI » did nothing, meaning did not investigate about the serious criminal offenses committed by a company under its jurisdiction and regulation, as yet, the use of a fake name, « CAA ».

Plaintiff filed the 28th of october 2014, a complaint at Superior Court of Santa Cruz, asking for a jury trial, essentially against CJ. LUCAS, Cynthia VELASCO, GAIL LOUIS, Chris BAGGALEY, «  AAA SOUTHERN CALIFORNIA Insurance », « INTERINSURANCE EXCHANGE OF THE AUTOMOBILE CLUB OF SOUTHERN CALIFORNIA », « INTERINSURANCE EXCHANGE OF THE AUTOMOBILE CLUB », «  AAA SOUTHERN CALIFORNIA », Robert T. BOUTTIER, John F. BOYLE, David LANG, Steve DOUGLAS, Dave JONES, « California Department of Insurance », Jerry BROWN, « State of California », Daniel WARNICK, about 11 cases of action.

Close Environment. First acts regardings Defendants.

Morning of the 29th of october 2014, around 9, Plaintiff went to Ladd's, to see his car. He discovered that it was not there. First, Lyle WOLLERT, manager, told him that someone picked it up the day before, saying by the « insurance company », but without mentioning its name. Plaintiff felt at once a strange problem with the responsible of this company, because his own insurance company « PROGRESSIVE » did not care about his car, and even, it has not to pick up his car without his agreement. Plaintiff asked him to give him a copy of the document from the person who took the car, as he has to ask when he releases any car. It is the Law.

He did not know, and told to Plaintiff to see with the owner, Jack LADD. Jack LADD gave indeed to Plaintiff, instead of a document given by a the so-called person who took the car, a copy of the invoice Jack LADD did himself about the tow and storage of his car, and about which it has been paid by the person who took the car. The amount was a strange higher and round price than really due, $1750,00. His explanation was unclear and nebulous. A fact more suspicious, Jack LADD laughed when Plaintiff told him he was going to sue him for his misconduct, and he just replied «  Good Luck ».

At once, Laurent GRANIER went to Sheriff's office in Felton to file a report about the theft. He was well comen, but he waited half an hour for the deputy Ryan YORK, who had to come back to the office to take his complaint. Ryan YORK is Deputy Sheriff representing Sheriff-Coroner Phil WOWAK. He asked to Laurent GRANIER, only one question about where was the car before the theft, but he seemed to have yet an idea, a position to take. He went to a room and called Jack LADD in private. Few minutes later, Ryan YORK came back and told to Laurent GRANIER that his car had been picked it up by the insurance company, a so-called « CAA » and so, declaring it was a civil case, and not a crimInal one, the car was not stolen. Indeed, Ryan YORK said everything that Jack LADD told him, even his judgement and legal advises, which is totally unlawful.

Laurent GRANIER replied that he did not agree because first, « CAA » is not an insurance company, second, his insurance company is « PROGRESSIVE » and not « CAA », and third, he never gave the authorization to anyone to pick up his car, and none had the right to take it, and so, it was not a cvil case but a criminal one, a theft. Laurent GRANIER insisted to file a report, but Ryan YORK refused, and Laurent GRANIER asked him to give him a report about his conversation with Jack LADD. He refused too.

Laurent GRANIER, yet victim of an accident, yet victim of blackmails and other criminal offenses committed by CJ.LUCAS, became a new victim of a steal, and in addition, of a corruption of the authorities to protect the criminals who victimized him. Having yet faced the corruption of the Police of Santa Cruz and even political persons of the city, as the mayor, the vice mayor, the risk manager, who protect people of the local mob, about what Plaintiff has had to file a complaint, now, facing the corruption of the County by its authority, Sheriff department, Laurent GRANIER had to file a new complaint.

As Plaintiff's car disappeared without his kowledge, his authorization, his agreement, and according the declaration and the lack of knowledge of some important facts, thanks to the dissimulation, lies, trickeries and cheating committed by Jack LADD and Lyle WOLLERT, Plaintiff was facing to consider two ways to treat this case :

If the car was considered as « picked up », so, it had to be considered as stolen before the delivery to the unknown man, so Jack LADD and Lyle WOLLERT were the author of the theft, and so, the persons following, from the unknown man to the last one getting the car, are under the offense of « receiving stolen goods » ; and if the car was considered as stolen by the unknown man, Jack LADD and Lyle WOLLERT were only his accomplices of the theft.

Plaintiff can not accept the possibility that Jack LADD and Lyle WOLLERT were only victims of a scam because they deliberately hide the identity of the person who « picked up » the car, and they did not respect their duty and their obligation to release a property under their responsibility.

So, Plaintiff understood that, in anyway, Jack LADD and Lyle WOLLERT were deeply involved in a organized gang theft, and even being the main responsible because the first act of the offense, the theft, can only happen with their help, and can not occur without their assistance.

So, Plaintiff filed a civil complaint asking for a jury trial, the 30th of october 2014 at Superior Court of Santa Cruz against Jack LADD, Lyle WOLLERT, Ryan YORK and Phil WOWAK for 6 causes of actions based on the few information he got at this time, and according for their first offenses.

Plaintiff, victim, did not mention in this complaint CJ. LUCAS nor any other name of person or company because he had not the proof that the car has been stolen by one of them, and the only ones « witnesses », Jack LADD and Lyle WOLLERT, refused to reveal the truth, because they were too, the accomplices, the partners and the first robbers. And anyway, facing their unclear explanation and their unlawful and unprofessional behaviour to release the car, Plaintiff had no clue in order not to determine that Jack LADD and Lyle WOLLERT had not kept the car for themselves.

Plaintiff filed the 30th of october 2014, a claim to his insurance company, « PROGRESSIVE », to report his car as stolen, in order to be removed as responsible of what can occur on his car, and what can be occured by it.

The friday 31st of october 2014, Plaintiff went to FBI office located in Campbell to file a report about the federal offenses committed by Jack LADD and Lyle WOLLERT against him, regarding yet the fact they had accepted to be paid by another person than the one named in their invoice, Laurent GRANIER, and worse, by an unknown and non identified person according Jack LADD. This fact is the same offense than if someone deposits money on a bank account without the authorization, nor the knowledge of his owner.

Because their office was closed on weekend, Plaintiff waited until the monday 3rd of november 2014 to go to « California Highway Patrol » located in Aptos -Santa Cruz County-, to declare his car as stolen. The officer was professional and took at once his complaint, and she called at once « DMV » to report the car as stolen.

Having still no news from « PROGRESSIVE » since he filed his claim, Plaintiff went at once to the office of his insurance agent, « D&R », to ask Shawn ROSE if he can fax to « PROGRESSIVE » a copy of the CHP report. Shawn ROSE called the claim representative, Scott KWIERAN, who wanted to talk to Plaintiff. When Laurent GRANIER took the phone, Scott KWIERAN, maliciously, asked to record the conversation, and Plaintiff agreed of course. Later, Scott KWIERAN explained he had yet recovered the car, and indeed, according only his words, but with no proof, it was not stolen but so-called « moved » by « AAA ». Plaintiff asked him a proof, a written proof of what he was saying, about his kind of « investigation », with all names of responsibles of the theft, and by the same time, remembering him the definition of a « Theft ». Scott KWIERAN refused to give any document, any proof, any testimony which can show that the author, the orderer and the organizer of the theft was indeed CJ. LUCAS, and which can put several persons in a tricky situation regarding the numerous criminal offenses they committed together, from Jack LADD and Lyle WOLLERT to the high responsibles of « AAA Southern California », and not only their kind of insurance company.

As Plaintiff was continuing to ask Scott KWIERAN, proof of his declaration about his wannabe recovery, the copy of the phone conversation record and to report his dicovery to police, Scott KWIERAN was continuing to do a deliberate obstruction of justice by dissimulating, erasing the proofs regarding the committed criminal and federal offenses, in order to protect the real authors, CJ. LUCAS and other hidden persons, with the active, essential and main complicity of Jack LADD and Lyle WOLLERT.

Plaintiff recalled Scott KWIERAN that first, the car had been stolen, and so, Scott KWIERAN had to call Police to come to check the vehicle to report it as recovered, and second, « PROGRESSIVE » had to pick it up in order to check if something had been stolen, damaged or changed, and so to pay for it. Scott KWIERAN refused to do his duty, as his manager, James ROBBINS who took the relay of the claim, to organize everything against his client, Plaintiff, but for all the benfits of the adverse party, by erasing all proofs of the criminal and federal offenses, and even by creating a new fake story based on lies and omissions of what happenned. Indeed, James ROBBINS tried to put all the responsibility of the theft to Plaintiff, by asking him to take his car which was, according him, 50 miles away of Santa Cruz.

In addition, nothing proved that the car has been really recovered, meaning if it was the real Plaintiff's car. And the day when the present complaint is written, Plaintiff still does not know.

Plaintiff went to « Department of Motor Vehicles », the 04th of november 2014 in order to get a document about the situation of his stolen car, and he got it.

Later, Plaintiff went to his address in Santa Cruz to pick up his mails since a while. He discovered that Jack LADD sent him a mail from SAN JOSE (!), the 31st of october 2014, containing a fake invoice, made with a computer, with no sign, asking Plaintiff to pay the tow and the storage for a total amount of $1,375.00, and attached, a letter explaining he put a lien on Plaintiff's vehicle for an invoice edited the same day, and the document about the pending lien at « DMV » registered by James PETTIT, for a vehicle under the value of $4,000.00, which is not true because Plaintiff's car, even accidented is worth than this amount.

When Plaintiff has had this mail, he understood at once, that Jack LADD was erasing all evidences about his numerous offenses, criminal and federal ones, like his real invoice of $1,750.00 written by his hand, and paid by the famous « unknown man » who « picked up » Plaintiff's car.

By all this time, Plaintiff was not sure that, indeed, Jack LADD had not stolen the car for himself, because his story with an unkown and unidentified person was very strange and unusual.

But, by the fact that Jack LADD was trying to get the ownership of Plaintiff's car by cheating and using a fake invoice, a false declaration and lies, Plaintiff understood that he was, indeed, the final material beneficiary of the theft, the car itself, when the CJ. LUCAS and her accomplices were the virtual beneficiaries, the dissimulation of the material proof, for all benefits of the insurance company and their highest responsibles.

With this letter, Plaintiff had the proof that his car had been stolen by Jack LADD, and so, Plaintiff wanted to declare to authorities the authors's name of the theft. Plaintiff was in Los Angeles since the following weekend, and so, he went to a CHP office, the one loacted at Woodland Hills.

The officer at the desk told to Plaintiff that his car was not declared as stolen, and worse, the report for which Plaintiff had the number and a copy, was erased from CHP records. The officer did not want to write a report from Plaintifff about the author's name of the theft, and just told to Laurent GRANIER to call Santa Cruz CHP office located in Aptos.

Laurent GRANIER called this CHP office in Aptos, and the officer SHARP told him that the claim representative of his insurance had called them, and asked them to erase the file about the theft, as if nothing happened. Facing Plaintiff's contesting about their misconducts, officer SHARP only replied by advising Plaintiff to call his insurance. That's it.

Plaintiff understood the reason of the corruption of the persons of this CHP, because they work more than they have the right with Ladd's towing company...

Plaintiff knew that, in any case, none officer should accept to commit the offense of erasing a file, and let alone by phone, from a guy who is not the owner, who is not the plaintiff, and without any proof as, at least, a fax letter. Normally, the officer had to ask and to advise the person who called them to call the local police where was the car, in order to make the process of recovery at the location where it was. It is the Law for any robbery, when the thing is recovered, even by its owner, anyone has first, before to touch it and to take it, to call police in order they come, check and write a report, and too, they declare to « DMV » the car as recovered. In addition, according the claim manager, James ROBBINS, and the claim representative, Scott KWIERAN, the car was at 50 miles from where it has been stolen, in another county, and so, far away from the jurisdiction of this CHP office located in Santa Cruz County.

Plaintiff saw that James ROBBINS and Scott KWIERAN, working at « PROGRESSIVE », were able to commit serious offenses by erasing all proofs of the criminals and federal offenses committed by persons they have not to take care of, so, for the benefit of the insurance company of the adverse party, and against the interest of their own client, Plaintiff himself.

« Strange?! » , «  Nonsense ?! », thought Plaintiff. Indeed, he discovered it was rather quite the opposite, because insurance companies do not care of their client, prefering to take care of the other insurance companies because they are not indeed, competitors, despite the other fields of businesses, but partners because they have to deal together all the time, for all claims, for all litigations. A kind of secret non-agression pact useful to have an easier way to deal, despite the interest of clients and victims. And, perhaps, helping to solve this tricky problem, even against the interest of their own client, Plaintiff, it can be useful for « PROGRESSIVE » to solve another case where they are at fault against « AAA ». Otherwise, Plaintiff understood that it was pretty sure that « PROGRESSIVE » commits the same bad and unlawful acts that the so-called « AAA » did against Plaintiff, as a common practice. In addition, to have this file in hands can help « PROGRESSIVE » in the future to get power on « AAA » in another tricky case where they'll have to pay.

For this reason, Plaintiff investigated and discovered the link, between « PROGRESSIVE » and the so-called « AAA » insurance, with the one of the Northern California branch. They have the same « Agent for Service », the same official registered person who represents legally each company, Nancy FLORES. Plaintiff got the reason of the collusion of both insurance companies which acted together as one against his interest, despite the essential fact that Plaintiff was only a victim.

By another way, Laurent GRANIER tried to get help from « AAA NORTHEN California », the auto club from where he is member, by denouncing the unlawful acts and professional misconducts of Jack LADD and Lyle WOLLERT, being agreed by « AAA », and for which Plaintiff had trust in them. Tom HAINES, Regional Manager Automotive Services at « AAA Northern California, Nevada & Utah », who has the responsibility to grant agreement to tow companies, claimed a fake argument to do nothing against Jack LADD and Lyle WOLLERT, despite their criminal offenses and their disrespect for their professional obligations, and so, he did nothing in order not to trouble them, and « AAA Southern California ».

Since this date, Laurent GRANIER got all proofs about all offenses, and understood all the story explaining the absurd and illogical behaviour of James ROBBINS and Scott KWIERAN, and Tom HAINES.

Statement of facts regarding the present complaint.

Plaintiff, victim of a car accident in the course of which he missed to be killed, or very seriously injured, was safe thanks to his good reflexe and his lucky star, but he lost his car, a part of data of his laptop, money, time, energy, health, and opportunities. The insurance company which had to reduce his problems, his troubles, the one of the adverse party because 100% responsible, took advantage on him by increasing them, and even by creating new ones from criminal behaviours.

By the time that Plaintiff took the ambulance to go to hospital, his car has been towed and kept by Jack LADD and Lyle WOLLERT, « AAA » agreed.

The 28th of october 2014, being victim of numerous criminal offenses like the absurd and unlawful existence of a lump sum, a fixed budget for any claim, even for victims of their clients, so for victims who are not their client, Laurent GRANIER filed a complaint against the so-called insurance company « CAA », which is indeed a fake name for « INTERINSURANCE EXCHANGE OF THE AUTOMOBILE CLUB » which is the insurance company of «AAA SOUTHERN CALIFORNIA», and against several of its responsibles, and especially against the claim manager CJ. LUCAS and her manager, Cynthia VELASCO.

CJ. LUCAS and Cynthia VELASCO knew since several days that Plaintiff was going to file a complaint against them, and they could not screw him easily, and so, they will have to pay the right price, above her unlawful lump sum.

CJ. LUCAS organized the theft of the Plaintiff's car, in measure of reprisals according her prior blackmails and for the fact to be sued, and above all, in order to erase all proofs about her criminal offenses by avoiding a counter expertise by Plaintiff of his own car, which should be harmful on three ways. First, about the property damage by the fact to be obliged to pay the real price, the replacement value of the car ; second, about the body injury by the fact to be obliged to recognize the violence of the impact and so the serious nature of the body injury, and third, about the lawsuit filed by Plaintiff, to be convicted of all criminal offenses.

To succeed in her criminal act, CJ. LUCAS has had the help, the assistance and the essential complicity of Jack LADD and Lyle WOLLERT, who are in the « AAA » family.

CJ. LUCAS ordered Jack LADD and Lyle WOLLERT to steal the car, and to deliver it to a so-called unknown, unidentifed person who picked it up.

The 28th of october 2014, the theft is committed and the stolen car is delivered to the unknown person, in exchange for an extra payment of an arranged and round amount of $1,750.00, which has been paid by the same unknown person the day where he was receiving the stolen goods, according Jack LADD's handwritten invoice edited to Plaintiff's name with a fake address (Sunnyvale).

The 29th of october 2014, Plaintiff discovered that his car has been stolen by going to Ladd's office, and Jack LADD gave him a copy of the paid invoice.

The 29th of october 2014, at once following his discovery, Plaintiff went to Sheriff's office in Felton, where Jack LADD and Lyle WOLLERT have their company, in order to report the theft.

Ryan YORK, deputy of the Sheriff Phil WOWAK, following the fake declarations, lies, advises and orders of Jack LADD, refused to write a report about the theft asked by Plaintiff.

The 30th of october 2014, Plaintiff filed a civil complaint against Jack LADD and Lyle WOLLERT for their first criminal offenses, and against Ryan YORK for corruption.

The 30th of october 2014, Plaintiff filed a claim to his insurance company, « PROGRESSIVE ».

The 31st of october 2014, a summons about the civil lawsuit is served to Lyle WOLLERT.

The 31st of october 2014, in order to erase his own criminal offense about the theft of Plaintiff's car, to erase his federal offense to have taken money from an unknown on the name of another one without his knowledge nor his agreement, Jack LADD started a procedure to take the official ownership of the stolen car by registering a lien on Plaintiff's car, thanks to the complicity of an agent, James PETTIT, and the ease and wrongful process offered by « DMV » to crooks who can register any lien on any car without real proof, and so, giving means to crooks strong means for blackmails.

The 31st of october 2014, a normal mail is sent from San Jose by USPS to Plaintiff by a so-called LADD which contained a letter, an invoice dated of the same day about the tow and the storarge of Plaintiff's car for a total sum of $1,375.00, and the notice of a pending lien on Plaintiff's car title, registered at « DMV » by the agent, James PETTIT.

The 03rd of november 2014, Plaintiff went to California Highway Patrol (CHP) located in Aptos – Santa Cruz County-, in order to report the theft of his car. The officer filed the report (S-326720-14) and called « DMV » to report the theft.

The 03rd of november 2014, Plaintiff went to his insurance agent in Santa Cruz, D&R, and gave to them a copy of the CHP report, asking to transmit it to « PROGRESSIVE ».

Claim representative, Scott KWIERAN revealed by phone that he found the car, but without proof, taking care to consider it as never stolen.

The 04th of november 2014, Plaintiff got from « DMV » an official document about the situation of his car reported as stolen.

Plaintiff filed online several complaints to California Department of Insurance (CDI), each of them for different criminal offenses committed by the so-called insurance company « AAA » of Southern California, which its real name is « INTERINSURANCE EXCHANGE OF THE AUTOMOBILE CLUB », but instead to investigate, this agency sent several mails to Plaintiff, with no information about each complaint, but just saying that they do not anything since Plaintiff filed a civil complaint at a court. Plaintiff was doing the job of « CDI », when offenses were criminal and so, had to be sued as is by « CDI » itself, according their official duty on insurance companies.

During several days, Scott KWIERAN and his manager, James ROBBINS tried to oblige Plaintiff to take his car from the location where it was located, according themselves only, with no proof that the car was really there, and even it was really Plaintiff's car.  

James ROBBINS and Scott KWIERAN refused, despite the numerous official formal requests from Plaintiff, to give him the proofs of the recovery of his car, and the final report about their so-called investigation, which could reveal officially the involvement and the criminal acts committed by CJ. LUCAS and several other persons.

James ROBBINS and Scott KWIERAN took care of the interest of the so-called insurance company « AAA », CJ. LUCAS, Cynthia VELASCO, Jack LADD, Lyle WOLLERT, and all persons who took part and committed criminal offenses, but did not take care at all, of the interest of their own client, Plaintiff, quite the opposite, because they caused to him more damages, property and health, committing themselves several criminal and federal offenses.

James ROBBINS and Scott KWIERAN did not call the police where the car was recovered, but the « CHP » office located in Aptos, where Plaintiff filed the report about the theft of his car.

James ROBBINS and Scott KWIERAN erased all proofs, all evidences about the criminal and federal offenses committed by Jack LADD, Lyle WOLLERT, CJ.LUCAS, and the other accomplices.

James ROBBINS and Scott KWIERAN asked to the « CHP Aptos » police officer to erase their report from their records, and to remove the car as stolen from DMV.

« CHP Aptos » Police officer erased the report « S-326720-14 » from records and removed the car as stolen from « DMV », without any official document, any proof.

« CHP Aptos » Police officer acted against the Law by the fact that it is up to the jurisdiction of the police station where the car is recovered to do the report of recovery.

« CHP Aptos » Police officer erased the criminal and federal offenses committed by Jack LADD and Lyle WOLLERT, with whom policer officers of this police station are very close, and for whom they call their tow company each time they can, and more than the Law gives them the right to do it.

Plaintiff discovered that people from the insurance company so-called « PROGRESSIVE », are using the same kind of trickery and fraud than « AAA » about the use of fake names for their companies.

Plaintiff paid indeed a company named « DRIVE », but he discovered that « DRIVE » does not exist in the record of « California Department of Insurance », and it has its address in Illinois, when about general inquiries, its address is in Ohio.

By searching in « California Department of Insurance » database, Plaintiff found « PROGRESSIVE WEST INSURANCE COMPANY ». But, this company is not a California company, and is located in Ohio. « PROGRESSIVE WEST INSURANCE COMPANY » is not registered as company in California, but has only an official declared Agent for Service named Nancy FLORES.

Plaintiff discovered the link which explains the collusion between people from « PROGRESSIVE » with people from « AAA » (by the one of Northern California branch), by the fact they have the same official declared Agent for Service, Nancy FLORES.

Plaintiff discovered that this insurance company is committing serious offenses about tax and registration, and so, he filed a complaint at « California Department of Insurance », which did nothing. Instead to investigate on the serious allegations from Plaintiff, this agency sent one letter for all of them to Plaintiff, with no information about each complaint, but just saying that they do not anything since Plaintiff filed a civil complaint at a court. Plaintiff was doing the job of « CDI », when offenses were criminal and so, had to be sued as is by « CDI » itself, according their official duty on insurance companies.

Otherwise, Plaintiff discovered that Tom HAINES, Regional Manager Automotive Services at « AAA Northern California, Nevada & Utah », who has the responsibility to grant agreement to tow companies, was protecting Jack LADD and Lyle WOLLERT by doing absolutely nothing about their criminal offenses, their professional misconducts, because they could reveal everything, everyone, and so, they could put in a tricky situation CJ. LUCAS, Cynthia VELASCO and several other persons of « AAA  Southern California », and also few otherinvolved persons.

The 11th of november 2014, Cynthia DRAGER, « AAA » claim representative about body injury, under the reponsibility of her manager, Bob Jorgenson, declared by email to Plaintiff that she was handling the property claim too. This is not an usual way, and so she was using a blackmail, associating the payment of body injury expenses under the settlement of the property damages, for which she knew a complaint was filed. Again, Plaintiff was under another double blackmail because she did not want to pay any bill about his body injuries before his total recovery, even medical ones, even the ones paid in advance by Plaintiff. Plaintiff understood that this unfair and unlawful behaviour against him, victim, was indeed a way to force victims to declare the end of their pains, of their injuries, not because they ended, but because victims needed money to pay their medical expenses, or to be repaid for their advance payment. So, Plaintiff became their « banker » by paying in advance expenses for a case where he was victim, and for which he was under the blackmail to be forced to declare as soon as he can the termination of his body injury claim, according his own financial means, and not his real recovery.

For summary of the collusion and corruption network, James ROBBINS, Scott KWIERAN and « PROGRESSIVE » are protecting and helping CJ. LUCAS and Cynthia VELASCO, and so, « AAA Southern California » and « AAA », who are protected by Jack LADD and Lyle WOLLERT ; « AAA » by its branch « AAA Northern California », « CHP Aptos » and Santa Cruz County's Sheriff are protecting Jack LADD and Lyle WOLLERT, as well they are protecting themselves reciprocally.

Each defendant did not respect the duty they have according the Law, and is fully responsible of each act committed against Plaintiff which caused to him more and new financial and health damages.

Yet victim of a car accident, Plaintiff suffered of more stress, more anxiety, more worries, which led to serious troubles in his private and professional life, missing great opportunities, delaying and/or aborting several of his projects, in process and/or in development, being inventor, master philosopher, writer, theoretician, designer, being the author of 25 patents, and around 40 copyrights.

Plaintiff has been disturbed in his mind, his main tool, by his own concrete problems caused by the insurance companies.

Plaintiff has been disturbed in his spirit by the external problems caused by the numerous criminal acts against moral sense, committed with complete impunity, against which he has had to face, as any honest man has to do, to fight, to denounce.

6. CLAIMS.

Introduction before Claims

28 U.S. Code § 1331 - Federal question : « The district courts shall have original jurisdiction of all civil actions arising under the Constitution, laws, or treaties of the United States. ».

The Origin of Federal Civil Rights Laws came from the period immediately following the Civil War. Civil Rights legislation was originally enacted by Congress, based upon its power under the Thirteenth and Fourteenth Amendments to pass laws to enforce these rights.

The first two of these laws were based upon the CIVIL RIGHTS ACT of 1866 (42 U.S.C.A. § 1982), which had preceded the Fourteenth Amendment. The first Civil Rights law guaranteed equal rights under the law for all people who lived within the jurisdiction of the United States. The second guaranteed each citizen an equal right to own, inherit, rent, purchase, and sell real property as well as personal property. The third original civil rights law, the Ku Klux Klan Act of 1871 (17 Stat. 13), provided citizens with the right to bring a civil action for a violation of protected rights. The fourth law made violation of such rights a criminal offense.

"Civil liberties" concern basic rights and freedoms that are guaranteed -- either explicitly identified in the Bill of Rights and the Constitution, or interpreted through the years by courts and lawmakers. Civil liberties include, Freedom of speech, the right to privacy, the right to a fair court trial.

The present complaint is about, but not limited, the following laws of United States :

18 U.S. Code § 201 - Bribery of public officials and witnesses

18 U.S. Code § 241 - Conspiracy against rights
18 U.S. Code § 242 - Deprivation of rights under color of law

18 U.S. Code § 873 – Blackmail

18 U.S. Code § 1506 - Theft or alteration of record or process; false bail

18 U.S. Code § 1510 - Obstruction of criminal investigations

18 U.S. Code § 1621 - Perjury generally

18 U.S. Code § 1623 - False declarations before grand jury or court

18 U.S. Code § 2312 - Transportation of stolen vehicles

18 U.S. Code § 2313 - Sale or receipt of stolen vehicles

18 U.S. Code § 2315 - Sale or receipt of stolen goods, securities, moneys,...

18 U.S. Code § 2321 - Trafficking in certain motor vehicles or motor vehicle parts

31 CFR 561.310 - Money laundering

36 CFR 1275.44 - Rights and privileges; right to a fair trial.

42 U.S. Code § 1981 - Equal rights under the law

42 U.S. Code § 1982 - Property rights of citizens

42 U.S. Code § 1983 - Civil action for deprivation of rights

42 U.S. Code § 1985 - Conspiracy to interfere with civil rights

42 U.S. Code § 1986 - Action for neglect to prevent
42 U.S. Code § 1995 - Criminal contempt proceedings; penalties; trial by jury

Nota Bene about 42 U.S. Code § 1982 - Property rights of citizens :

All rights about property are given to owner, by United States Law. Even it is not exactly specified, these rights include the nature associated with an ownership, as the right for an owner of his own full disposal of the property, of his own total freedom to use it, to keep it, to move it, to do everything with it. And so, a steal is violation of this fundamental right about property. If we can accept that a normal theft is under the local, state laws, because a normal theft is not targetted on the person who gets the property, but on the value of the property itself, we can not disagree that the present complaint is about a targetted theft, in order to steal an evidence from Plaintiff, to inflict stress and emotional pains on Plaintiff, to get power and obtain a negocation against Plaintiff's interest and will, to create damages on Plaintiff as a punishment, and so, the main and alone purpose of the people who have ordered and committed the theft is not about the value of the property itself, but about the owner, Plaintiff. So, this kind of theft is under the Civil Rights of 42 U.S. Code § 1982.

Nota Bene about 18 U.S. Code § 2312, 18 U.S. Code § 2313, 18 U.S. Code § 2315, 18 U.S. Code § 2321 :

If those federal laws are specifically under the condition of cross-border, we can accept that the only fact of the intentionality of criminals to do it as is, is acceptable, and so those laws apply. Indeed, the object, a collector car, is not a common car, and the trafficking of this kind of cars, and more, parts of this kind of cars, is mainly done cross-border, interstate. We can see that the real intent was to sell the car, or its parts, trough an auction house, COPART. But COPART is not a common, a normal local auction house. COPART is a nationwide company located in Dallas (Texas), selling more than 1 million cars yearly, via more than 160 physical locations across several countries. If their physical act on Plaintiff's stolen car did not yet cross any state boundary or country border, it is only because Plaintiff succeeded to stop their criminal undertaking on time. In addition, COPART does propose auction online, and so, the factor of interstate, even international, is confirmed. Otherwise, the factor about the travel of the benefit, of the money pulled out from the offense, from the theft. Companies like « AAA » and « PROGRESSIVE » are nationwide, and so, the loot, money from the object itself, and money saved from the origin of the theft (theft of evidence) is about interstate companies benefits. We can add the fact that those companies have investors who are not located in California, and making money from those unlawful practices. So, by all those points, interstate, cross-border facts are real. So, 18 U.S. Code § 2312, 18 U.S. Code § 2313, 18 U.S. Code § 2315, 18 U.S. Code § 2321 laws apply in this case about Plaintiff's complaint.

Nota Bene about the respect for United States :

1. Those Civil Rights came from the origin of the United States, not from the Constituion, but earlier, from the Declaration of Independance which was written under the universal genuine spirit of « Common Sense », thanks to Thomas PAINE, who was indeed, the real father of the text of this fundamental declaration, and even the one of Declaration of the Rights of Man and of the Citizen in France, in 1789. A important date for the United States too, for its Constitution.

2. Common Sense spirit was so influential that John Adams said, "Without the pen of the author of « Common Sense », the sword of Washington would have been raised in vain.".

3. So, anyone living in United States who acts against what « Common Sense » expresses, is guilty of felony, of a violation of the United States spirit, the one for which The United States of America has been declared and created, the one from which The Constituton has been written, and so, the one for which anyone has to respect carefully.

Nota Bene about Property Rights :

There are 3 fundamental Civil Rights : Freedom, Respect and Property.

1. Freedom is the Right to anyone to do, to go, to think as he wants and can, which is the freedom to dispose of himself, the self-determination.

2. Respect is the Right to anyone, to be considered as human being without regarding the characteristics of the body nor the mind, which are color (skin but also, hair, eyes, etc.), race, religion, origin, etc.

3. Property is the Right to anyone to get a property. This is a main right because it is the first after the consideration on person (Freedom and Respect).

Nota Bene about the Right for a fair trial and justice :

Among the fundamental Civil Rights, there is one about the right for a fair trial. If this part is about defendants prosecuted for a crime, it is under the common sense and by the « equal rights under the Law » that anyone has the right to access to the judicial system, to obtain justice, compensations for his damages, and so, to get the right for a fair trial as victim. And it is also under the common sense, that victims can obtain the infliction of a punishment to defendants who are guilty of a crime, and so, a stopping of their criminal and unlawful activity.  



To finish, and after to have shown you that none of them is respecting the Constitution of America, their own constitution, and in order to get another proof of the cheating of the sub federal judge Edward J. DAVILA, we can see that he did write a strange and unlawful decision the 28 th of september 2015, and so after several months he did absolutely nothing, but strangely the day when arrived by postal way my amendment for fraud denouncing him and his "friends", clerks. But, this amendment has been registered by the clerks two days later, the 01 of october 2015, and so after his sudden decision, always good for all defendants, always all together as one...
You can see it by the two files you can find below (in blue). 

Federal Registration     Postal Proof

The Entire Federal complaint filed the 08 12 14 in .pdf

Addition to the filed federal complaint 14 01 15 in .pdf

​Last amendment against federal clerks and judge filed 28 09 15 in .pdf

Abstract ot the complaint filed at Santa Cruz court the 15th of October 2015 . 

Involved persons: 
Scott STOCKER, manager and owner of « De Laveaga Motors Inc. »

Andrew WHITMAN, seller at « De Laveaga Motors Inc. »

Joey MOCCIA, seller at « De Laveaga Motors Inc. »

« De Laveaga Motors Inc. »,

Lynn ROBINSON, Mayor of city of Santa Cruz,

Don LANE, Vice Mayor of city of Santa Cruz,

Patty HAYMOND, Risk Manager of city of Santa Cruz,

City of SANTA CRUZ,

Nathan VASQUEZ, Police Officer at Santa Cruz Police,

Kevin VOGEL, Chief of Police of Santa Cruz,

Police of Santa Cruz,

The original case.

Plaintiff Laurent GRANIER wanted to sell his PORSCHE 911 (vin WP0CB2969LS472037) convertible of 1990. He found the dealership De Laveaga Motors Inc. located at 1215 Water St., Santa Cruz, CA 95062DE on internet, by their website http://www.delamotors.com/.

Their staff is composed by the manager and owner Scott STOCKER, and the sellers Andrew WHITMAN and Joey MOCCIA.

They were, and are, proposing to take cars under consignment, with the terms “risk free”.

According their website, letting the car for sale is “risk free”, on the “consignment page”: “Let De Laveaga Motors sell your vehicle hassle and risk free – we’ll do that as quickly as possible and for the best price! BENEFITS OF CONSIGNMENT: EXPOSURE Our showcase has 28,000 drive bys daily. Advertising includes print, internet and a national dealer and customer network. Over 80% of consigned vehicles are sold within 30 days. FINANCE The majority of cars sold are financed-we offer competitive finance and lease options to buyers. TRADES Over 70% of buyers have trade-ins. We offer competitive prices. Let De Laveaga Motors sell your vehicle hassle and risk free – we’ll do that as quickly as possible and for the best price!”

Laurent GRANIER went two times to this dealership, in order to meet the manager, so-called expert in Porsche. The 11th of august 2014, they signed an agreement to sell the car at $20.000 plus $2000 of commission. Laurent GRANIER accepted to put the price of the car below the market, in order first, to sell it quickly, and second, to do easier the task of the dealership. When they signed, Scott STOCKER maliciously kept the title of the car, and gave another paper to sign, but he did not give a double, a copy of it, like he did for the original agreement.

Laurent GRANIER discovered later that Scott STOCKER had hidden to have kept the title, and he had to go back several times, meeting the sellers Andrew WHITMAN and Joey MOCCIA, to get back, but unsuccessfully.

Laurent GRANIER discovered later that Scott STOCKER put the price ofr sale at $39.990, so the double of the price asked by Laurent GRANIER to sell it quickly, but worse, a price above the market, and impossible to sell.

Laurent GRANIER discovered that Scott STOCKER used plaintiff's time and money to make more money without him knowing and agreement. Worse, summer time being the best time to sell a convertible has been wasted by Scott STOCKER's dishonest behaviour.

When Laurent GRANIER wanted to have his car back, in september 2014, Andrew WHITMAN told to plaintiff that Scott STOCKER was able to buy the car, and he had just to pass by the office to take the check. In fact, it was a strategy to make lose time and energy to Laurent GRANIER because when plaintiff came to take the check, Scott STOCKER was not there to do it. Laurent GRANIER came back another time and that time, Scott STOCKER was not there and Andrew WHITMAN told to plaintiff that Scott STOCKER was not able to buy the car at this price, and if he wanted to get his car back, he has to pay $1000. As it was blackmail, robbery and scam, Laurent GRANIER refused.

Laurent GRANIER still saw the ad about his car, posted by the band Scott STOCKER, Andrew WHITMAN and Joey MOCCIA at the price of $34990 on craigslist.

Laurent GRANIER came back to the dealership twice, meeting first, the of october 2014, Andrew WHITMAN who told to plaintiff to pay $1000 to get his car back, doing unlawful withholding and using blackmail, and a second time, on monday 13th of october 2014, Scott STOCKER who was continuing to blackmail plaintiff by theatrening him to put a security bond on the title, even threatening him by wanting to hit plaintiff. Scott STOCKER stopped only when Laurent GRANIER told him he was recording. Scott STOCKER warned Plaintiff he was able to call Police. Laurent GRANIER understood that something wrong was present in this small city like corruption of authorities when a criminal dares to call the Police against his victim, or when a person is able to commit several criminal offenses with no fear of justice, and continuing to do more, being not afraid by authorities, as being sure to be protected by a kind of impunity. Something unlawful like corruption. Plaintiff has had the confirmayion of his doubts of corruption when he tried to file a criminal complaint to the Police of Santa Cruz.

In addition, following the blackmail and the threats made by Scott STOCKER on Laurent GRANIER, plaintiff went the same day, monday 13th of october 14, to Police Station of Santa Cruz to deposit a criminal complaint for blackmail, threat, scam and robbery against Scott Stocker and Andrew Whitman.

A police officer, Nathan VASQUEZ met Plaintiff with nothing in hand, no paper, no no pen, no laptop.
Nathan VASQUEZ did not care about the case, the situation of the Plaintiff, as he had yet in mind not to report it, as he knew yet it, as he had in mind to make Plaintiff give it up, as he will not write anything against the criminals, as he wanted to help the criminals by obstruction of justice. In fact, he was busy by his sticking plaster (Band-Aid) at one of his finger, telling Plaintiff he can't write anything, canning not to hold a pen...

At once, Plaintiff came to Mayor's office to warn her about corruption behaviour and obstruction of justice made by a police officer under her responsibility.

People was good at the different offices of the City Hall until the time Plaintiff wanted to file a complaint. Kristina SANTANA at the front desk refused to give him a receipt, a certificate about his filing case, what is against the Law. Otherwise, the internal affairs of the city, « Risk Management Office » takes 45 days to study each case, letting criminals to do what they want and they need.

At the end, Laurent GRANIER lost, first the opportunity to sell his car in summer, second to save money, third to get money, fourth his car and fifth the opportunity to sell his car to clients who wanted to buy it at the right price.

Additional Amendment 1

​Additional Amendment 2

​The complete complaint Filed in .pdf

Abstract ot the complaint filed at Los Angeles Court the 10th of September 2015 . 

Involved persons: 
- Cynthia HACKLER,  attorney/lawyer,
- THE STATE BAR OF CALIFORNIA,
- Luis J. RODRIGUEZ, State Bar President,

The original case.

Following an ad posted on the website « craigslist.org », Laurent GRANIER rented an apartment in-law located at 2711 Cornett Dr (in the canyon of Laurel Canyon, from Elrita Street), Los Angeles (90046), at Dean TURCHI (nickname DEANO or DINO), since the 3rd of march. The landlord lives in the main house which is attached, in fact, it is a house shared in two apartments with two separate enters, each unit having its bathroom and its kitchen.

Everything was fine. The Landlord was happy to have a quiet person, paying always on time, being flexible about nuisances caused by the landlord still working to rebuild his house, even in the night.

Laurent GRANIER left the apartment for few days, since monday 12th of may to thursday 15th, but still paid and included. Dean TURCHI used this time to work in the apartment, nevertheless paid for its rental by Laurent GRANIER. When Laurent GRANIER came back this afternoon of the 15th of may, he found his apartment wide open, even the main door, with nobody around, even not the landlord living in the attached main house. Laurent GRANIER discovered the bag he had hidden because containing confidential documents and cash, half open, moved from the hidden location, and at the view of anybody. He discovered it was missing among his cash, one bill of 500 euro and one bill of 100 euro. Laurent GRANIER sent at once a text message to Dean TURCHI to inform him of the robbery, and to get answers about the fact his apartment was left wide open. Dean TURCHI did not answered, even replied. He said later that he had to leave quickly this afternoon, (with no reason...), and so, he had forgotten to close and to lock the door of the apartment...

The day after, Dean TURCHI was upset, sending to Laurent GRANIER 16 sms, to try to oblige him to leave the appartment, nevertheless already paid in full since ten days, and for one month, so until the 7th of june. Laurent GRANIER asked him again (He asked him yet one month ago) to avoid to send him a lot of sms, but rather to send him emails, nevertheless a way already used sometimes by Dean TURCHI. He replied few hours later. His emails were strange, and Laurent GRANIER told him he wanted just to be quiet and to not be disturbed anymore, having paid, and having not the mood to discuss for nothing. Following the Dean TURCHI's email where he was reproching him a lot of fake, wrong and inapropriate things, far of a normal correspondence between landlord and tenant, but close to a dispute of a couple, Laurent GRANIER replied to him that he was not his boyfriend, meaning not gay. Dean TURCHI became angry with a more strange behaviour. Dean TURCHI opened the door of Laurent GRANIER's apartment with no authorization, he hurried into, and started to yell to him, saying a lot of stupid, irrelevant, strange, fake and wrong sentiments, and worse, accusing Laurent GRANIER of acts and behaviours in fact done by the landlord himself. Laurent GRANIER understood that something wrong happened by his kind of transfer (when a person puts and accuses another person about acts and behaviours he did himself).

Laurent GRANIER tried to talk to him quietly, but he became more upset. Laurent GRANIER left the room to go to the other one, thinking he could calm down and leave, but in fact he entered more in the appartment and continued to yell to him with these strange, unrelated, irrelevant and fake assertions.

Laurent GRANIER knew that Dean TURCHI was obsessed by a realtor in San Francisco who screwed him last year when he sold his house. According him, he tried all kinds of therapy to avoid, to quit his obsession, and one week ago, he told to Laurent GRANIER he had in mind to kill his realtor, having no other way to solve his « mind » problem. He started to become insane. He told to Laurent GRANIER that the last thing he wanted to try was a kind of yoga delivered by a weird association, and he had to start the next week, indeed the week when Laurent GRANIER came back and found his apartment wide open, his bag not anymore hidden, with missing money. Laurent GRANIER left Los Angeles for few days, and when he came back this thursday, Dean TURCHI was strangely dangerous.

So, knowing this about Dean TURCHI, who was able to have in mind to kill his realtor and who was obsessed since almost one year about him, and seeing his radical change of behaviour for a very strange one by saying fake assertions on Laurent GRANIER, which are about indeed the ones about himself, Laurent GRANIER understood that anything could happen to him. As Dean TURCHI was threatening him, he was harassing him and he was doing a violation of his appartment with verbal violence, for no reason, Laurent GRANIER prefered to leave at once, nevertheless letting his clothes and his stuff inside, still remaining officially the tenant.

Leaving this dangerous place of this friday afternoon, Laurent GRANIER sent a text message to Cynthia HACKLER, lawyer/attorney, who was working yet for Laurent GRANIER about professional documents (contract, etc.), to ask her if she was able to take the case.

Cynthia HACKLER agreed, gave few advises like to take an hotel (!), to buy clothes and everything let in the apartment, keeping all receipts.

Cynthia HACKLER proposed to Laurent GRANIER to meet her at « her » office, giving the address « 915 Mateo, Ste 201, Los Angeles, CA 90021 ».

This afternoon, Laurent GRANIER went to the Police Station, LAPD Hollywood Community Police Station located at 1358 N. Wilcox, Hollywood, CA 90028, and deposited an « investigative report ». But LAPD did nothing.

Saturday, Dean TURCHI sent to Laurent GRANIER 36 sms, several emails, and call him twice (letting me messages).


FACTS and ACTS about Cynthia HACKLER as attorney/lawyer.

Having to leave his apartment quickly, and looking for the location of the police station, Laurent GRANIER sent a text message to Cynthia HACKLER to explain her the situation. Laurent GRANIER knew Cynthia HACKLER to have hired her for business document as NDA, License contract, etc.. He met her via the website « ELANCE.COM ».

Cynthia HACKLER confirmed Laurent GRANIER she was able to take his case, and she started to give him few « advises ». The first one was to take a new apartment... She proposed him to meet her at her office as soon as possible, and as it was friday afternoon, for the following monday, so the 19th of may 2014. She gave him by text message, her office address « 915 Mateo, Ste 201, Los Angeles, CA 90021 ». All exchange and discussions have been done by text message. She replied to few questions as which range of price the hotel has to be chosen, and she advised to keep all invoices, all bills for all his expenses, hotel, restaurant, clothes, belongings.

In no way, in no event, under no circumstances, Cynthia HACKLER really did help Laurent GRANIER.

The apointment with her was at 1 pm. Laurent GRANIER spent all his monday morming to go to several official offices to inform, to denounce and to file complaints against Dean TURCHI about his numerous offenses. Laurent GRANIER spent a lot of time, a lot of energy, a lot of money to visit serveral offices, and most of time, being sent from one to another one. While he wasted energy and time, he asked to Cynthia HACKLER, simply the right address to file complaints to the City of Los Angeles. She replied she did not know...

He found by himself, with no advise, no help from Cynthia HACKLER, all city departments concerned by the several frauds made by Dean TURCHI, as « Los Angeles Department of Building and Safety » and « Los Angeles Housing+ community department ».

Laurent GRANIER has had to find by himself, alone. He spent so much time that he asked her to postpone their meeting few hours later this monday afternoon.

Laurent GRANIER went, tired, to the office of Cynthia HACKLER, at 915 Mateo, Ste 201, Los Angeles.

He has had to wait outside because there was no doorbell under her name, there was nothing to warn her he was there. He has had to send her a text message, and she came to open the door.

She showed the way to her office. It was an open office with no confidentiality, no privacy, shared with other people of other companies, having other activities than legal.

Laurent GRANIER found this, very strange, but at this time, it was not his main worry.

Laurent GRANIER has had to tell all the story, giving confidential informations to Cynthia HACKLER, with all this people around them.

Laurent GRANIER has clearly explained her the situation and the case, and the main problem, meaning the new insane behaviour of Dean TURCHI. Between friday and monday, Laurent GRANIER sent to Cynthia HACKLER all emails he got from Dean TURCHI, in order to be read and study by her, to find clues about his numerous serious offenses as landlord, but in order too, to prove his strange and dangerous change of behaviour. He sent her too, a summary of the facts. Laurent GRANIER discovered Cynthia HACKLER did not know the case, having not read the emails from Dean TURCHI, even not the summary memo. So, he has had to repeat her everything, and to explain all the offenses. He wanted to sue Dean TURCHI for his several serious criminal offenses. And he wanted too, to ask for a restraining order to get a kind of protection because he was a witness, and because he revealed to FBI the fact that this person had in mind the plan to kill his prior realtor in San Francisco.

So, an agreement between Laurent GRANIER and Cynthia HACKLER has been signed, and Laurent GRANIER gave to Cynthia HACKLER a check of $1500 for restrainer.

She had to write and to file a civil complaint to Superior Court, and to ask for a restraining order.

It is interesting to mention the fact that Laurent GRANIER asked for this restraining order when he deposited a complaint to LAPD, the 16th of may 2014, request which has not been followed by the officer HALLOCK. It is important to add the fact that this police officer did serious mistakes in his report, about the Laurent GRANIER's identity for whom he kept the address, the occupation, the phone number of the prior plaintiff... Otherwise, this officer never gave the copy of his report, Laurent GRANIER knowing not what he wrote exactly, and so, what is in his complaint ! Anyway, with a false address about the plaintiff, this report can not be followed.

The day following, tuesday 20th of may 2014, Laurent GRANIER asked to Cynthia HACKLER to contact LAPD Police station, to contact the Captain and/or the Watch Commander, to warn them about their serious mistakes in the report.

She did it, but she asked only for the officer having done the mistake. She has had to call three times in several days to reach him. He changed the errors, but he never sent the new and right one, and most important, he refused to take the copy of the declaration sent to FBI by Laurent GRANIER, being more complete than the one made by this officer. This officer refused to send a copy of his report.

From her side, Cynthia HACKLER did nothing else. She never asked officially by written way, the copy of the report. Cynthia HACKLER did not call and warn his superior, the Chief Commander or the Captain.

When Laurent GRANIER wanted to file a complaint against LAPD for their bad, strangely protective behaviour which indeed, would have been able to be useful against Dean TURCHI, she explained to Laurent GRANIER it should be without interest. Cynhtia HACKLER's official address is 1905 N. Wilcox Ave, and Hollywood Community Police Station is located at 1358 N. Wilcox...

Cynthia HACKLER filed the restraining order the 23rd of may 2014, so one week later the problem with Dean TURCHI. The hearing was for the 16th of june 2014.

She took time too, to write the complaint to the Superior Court, and filed it (case 14K07394) the 30th of may 2014, for a trial with jury will happen one year and a half later, the 30th of november 2015.

Just before to file it, the friday afternoon 30th of may, she sent two invoices, one about her work for Dean TURCHI lawsuits, and one about the work she did few months ago, for Laurent GRANIER's professional purposes.

These invoices contained numerous excessive claimed points, with no justification, no proof. Yet, Laurent GRANIER found strange the fact she sent simultaneously those unrelated invoices at this inopportune time.

Laurent GRANIER got the proof that Cynthia HACKLER was screwing him by her invoices, and by the same time, she was using blackmails to be paid with no disputation.

By the same time Laurent GRANIER still asked for their proof and justification, he saw she did again several serious mistakes in the complaint she had to file at the Superior Court. She even refused to change some of her errors, making it not accurate, even deceitful.

Later, he discovered she was hidding, or withholding informations and documents, like the procedure to serve notice to the defendant.

Because the numerous unsuccessful attempts to serve notice to Dean TURCHI, which led to two postponements of the restraining order hearing, Laurent GRANIER asked Cynthia HACKLER the reasons of these failures. She did not know, even asking Laurent GRANIER if he knew where he should be. Laurent GRANIER discovered she did not hire a professional to do the job, but rather, the free service of the sheriff of Beverly Hills, who is not the closest one to the defendant home.

So, Cynthia HACKLER hired a so-called professional company with a hidden owner/responsible, A&G ATTORNEY SERVICES, located at 13089 Peyton Dr Ste C-154 Chino Hills, CA 91709.

Dean TURCHI has been served notice after several attempts, the 24th of june 2014, so only one week before the hearing the 02th of july 2014.

Laurent GRANIER, having yet no doubt about the dishonesty and the bad faith of Cynthia HACKLER concerning her invoices, had yet doubts about her competence and her professional honesty. His doubts grew more, knowing time was ruling for Dean TURCHI.

Laurent GRANIER felt the confirmation of a collusion and/or a corruption by the fact that Dean TURCHI, being informed officially of a restraining order hearing two weeks before it, found quickly a lawyer (with a mexican-sounding name in Santa Monica), and by the fact that the adverse party unlike anyone in this situation, did not ask for a postpone to study the case, like they already knew it very well since a while.

With a filed criminal complaint, with a filed civil complaint concerning several serious criminal offenses, and despite the fact that a restraining order in this situation is first, useful, necessary and essential in order to protect an already victim, but also, a witness about criminal behaviours, having deposited a complaint to FBI, and second, not costly and not binding for the defendant's life if he had a normal behaviour, with the fact that his victim left his area, the judge refused to grant this kind of protection to Laurent GRANIER, who has even been sentenced to pay $500 to the person who victimized him. His doubt about a corruption network were founded, while also, Cynthia HACKLER refused to give him a copy of the judgement. So, Laurent GRANIER knew he was not granted of a protection, he knew he had to pay the adverse party, but with no proof, no official document, and so, no way to appeal.

Another proof of collusion, linked with the strangely unjust judgement, has been confirmed with the indecent, insulting and irrelevant proposal given to her by Dean TURCHI's lawyer, Rosario Perry : « Laurent GRANIER should have not to pay the $500 if he abandons his civil lawsuit », a lawsuit concerning numerous criminal offenses and its several hundreds of thousands dollars of caused damages.

And Cynthia HACKLER asked Laurent GRANIER to pay directly this lawyer, with no official document about it. Laurent GRANIER replied her she had to pay with her own money because she sabotaged the case, or at least with the money of the retainer he gave her . She never replied.

Otherwise, he tacitly fired her since a while, according her threat to stop to represent him if he did not pay her invoices with no disputation.

Indeed, like Laurent GRANIER confirmed her he was aware of her numerous professional offenses, by the fact she was screwed him since the begining, but also of the fact she deliberately sabotaged, in revenge and in retaliation, the hearing of the restraining order, like by lying to the judge she was not aware where her client was, why he was not present, and when he could come back to Los Angeles, lies sinking the restraining order decision, she wrote him she was withdrawing herself.

Laurent GRANIER was travelling since few weeks, to find peace of mind, to erase his concerns, his worries about this unjust unbelievable situation, which led to the discovery of a possible corruption and collusion.

He had not to be present for the hearing, having signed his declarations, having filed a complaint to FBI, and by the fact Cynthia HACKLER confirmed him at the beginning she represents him.

Indeed, everything was done to avoid the testimony of Laurent GRANIER because Dean TURCHI knew since april that Laurent GRANIER had to travel and to leave Los Angeles area before july, and Cynthia HACKLER asked him to be present just few days before the final hearing, despite the fact she knew her client was travelling in other states, far-off more than 1000 miles, looking for peace of mind to regain his health, in order to work on his projects (he is inventor, master philosopher, theoretician, writer, designer), and despite the fact he explained her the useless of his presence, having done and given all proofs to justify his demand.

Despite she knew she was not anymore authorized to represent Laurent GRANIER, despite she was withdrawing herself, despite the fact Dean TURCHI's case did not need any more work before more than one year, she was continuing to represent him illegally and without his agreement, by keeping in touch under hidden ways with the adverse party, having a hidden agenda in order to bill and to edit new fake and unlawful invoices.

So, using dissimulation, concealing and omission, she filed a motion (which even contains error and fake declaration) at the Superior Court for a hearing the 11th of september 2014, in order to be relieved as counsel-civil in the lawsuit against Dean TURCHI (case 14K07394). She filled the reason field of the form with a tricky cheat by declaring she wanted to keep confidential, secret her reasons, claiming code articles and even legal precedents to hide the truth. Indeed, she filled this form under fake, false and irrelevant motives, asking even the unrelated, irrelevant and nonsensical request of camera hearing to ascertain her « good faith » about the reasons of her concealing and omission. After to have vainly harassed her client to stop his lawsuits against Dean TURCHI, to have used threats to stop working and to withdraw herself, to have used blackmails, and to have sabotaged the cases to the advantage of Dean TURCHI whom she always called friendly « Dean », she was diligent to be withdrawn as soon as possible.

She even billed lately her spent time and expenses about this useless procedure she wrongly initiated against her client, still under the motive of revenge and reprisals, just two days after Laurent GRANIER sent a complaint about her numerous professional offenses to State Bar President Luis J. RODRIGUEZ (STATE BAR OF CALIFORNIA), and to ATTORNEY CLIENT MEDIATION AND ARBITRATION SERVICES at Los Angeles County Bar Association...

Unlike her action about Dean TURCHI notices, Cynthia HACKLER was very efficient and resourceful to serve notice Laurent GRANIER about her motion. She sent him two certified mails, one the 14th of july 2014 (7012 3460 0000 2935 9151) and the other one the 16th of july 2014 (7012 3460 0000 2935 9168). The first one contained only three stapled double documents about her motion to be relieved as counsel-civil. The second one contained a mix of unrelated purposes, like a letter explaining with lies about her reasons she was stopping to represent him, a new invoice with no proof of her claimed points, a « notice of client's right to fee arbitration », the same documents, some twice, than the ones of her prior certified mail, about her motion to be relieved as counsel-civil, and an official testimony, under the title of « PROOF of SERVICE ON MOTION » for the « Superior Court of CALIFORNIA », made and signed by Joel LIPMAN, swearing under penalty of perjury he was « not a party to the within action », and certifying the content of the certified mail where it was, the one of the 16th july 2014, and so, by the fact he served those documents to Laurent GRANIER by this same certified mail. His declared address was the one of the Cynthia HACKLER's non declared hidden office, at 915 Mateo St., Los Angeles.

Laurent GRANIER sent to Joel LIPMAN, the 12th of august 2014, a certified mail (7013 3020 0000 4744 0324) to ask him a confirmation of his independence facing his common address with the party, and by the same time, to demonstrate him his serious involvement for perjury in a criminal offenses case.

The certified mail returned to Laurent GRANIER with the postal service motive : « RETURN TO SENDER – ATTEMPTED – NOT KNOWN – UNABLE TO FORWARD ».

Indeed, Laurent GRANIER discovered the existence of her hidden useless and illegal work, not because she updated him about their nature, but because she billed them more and more in new unlawful invoices.

So, Laurent GRANIER sent her a certified mail (7013 3020 0000 8216 3646) to the address of her non declared hidden real office at 915 Mateo St. She received it the 30th of july 2014. The content and the purpose of his mail were to confirm her again that he constested her invoices, to ask her again proofs and justifications of her invoices, to remember her she was not in charge to represent him since a while, to notice her he was going to sue her for her numerous criminal offenses, and to give her his new address in Campbell, having left Los Angeles since his problems with Dean TURCHI, seeing that neither the authorities, nor she was going to make something to guarantee his safety.

She never replied.

She just sent an email with a « substitution of attorney-civil » form, to sign in order to relieve her from the record of the civil lawsuit, the same than the one she sent the 07th of july, but with the Laurent GRANIER's new address. And still with the same fraud about the address of the person who has to serve, her official address, with no name.

Otherwise, she never sent any real mail.

Being master philosopher, Laurent GRANIER gets an acuity to analyze, and so, to detect and to reveal corruption, and especially when it comes to a network, seeing connections between points, like a profiler. He saw the presence of the 3 common mainstreams ruling and motivating corruption in mankind, other than greed and sex, the primary one which leads to cooperation and mutual aid regarding a same nature : religious beliefs (including dogma, obedience, sectarianism, etc.), ethnicity (including race, color, geographical area origin, language, culture, citizenship, etc.), gender (including sexual orientation, body difference, etc.), profession/ occupation. In this case, he saw the Jewish link (Hackler, Lipman, Yeom), the mexican one (TURCHI's illegal worker, TURCHI's sexual partner, TURCHI's lawyer ROSARIO Perry, Hector RODRIGUEZ Inspector at Building and Safety Dept, MARIA Wood and Araceli GONZALES of Los Angeles Housing+ community department , Michael VALENZUELA of A&G ATTORNEY SERVICES, State Bar President Luis J. RODRIGUEZ), the homosexual one (Dean TURCHI, his sexual partner, and some of the aforesaid, being as is or sympathizer), and the professional one (legal, lawyer, attorney, etc.)

So, the 12th of august 2014, Laurent GRANIER sent a certified mail as formal notice to A&G ATTORNEY SERVICES (7013 3020 0000 4744 2083), Sheriff JOHN L. SCOTT (7013 3020 0000 4744 2069) and Deputy KEVIN C. CONNORS (7013 3020 0000 4744 2076) to ask them details about their work, original documents with their certification, and a testimony as they were not a party to the within actions, Dean TURCHI cases, and if they did, or not, know Dean TURCHI before, and their relationship with Cynthia HACKLER.

None of them replied, even the A&G ATTORNEY SERVICES to whom Laurent GRANIER asked the name of their hidden legal reponsibles, information they have to disclose, and even not to hide in their official document as their website. Laurent GRANIER understood that something wrongful and unlawful happened and was happening, of course, against him.

The same day of the 12th of august 2014, Laurent GRANIER sent to State Bar President Luis J. RODRIGUEZ (7013 3020 0000 4744 0300) and to ATTORNEY CLIENT MEDIATION AND ARBITRATION SERVICES at Los Angeles County Bar Association (7013 3020 0000 4744 0317), a formal notice to warn them about the numerous criminal and professional offenses commited by their member as attorney/lawyer, and to ask them if they approve her misconduct, if they are criminally co-responsible, and jointly and severally financially responsible, and tacitly if they will do something.

No one replied officially as they had to do by certified mail.

Nothing has been undertaken by those internal profession authorities to stop, or to reframe the criminal professional behaviour of their member. They did not give any real advise, any help, any assistance to Laurent GRANIER, victim of a lawyer facing those serious offenses.

Five days later the reception by State Bar President Luis J. RODRIGUEZ, and two days later the reception by ATTORNEY CLIENT MEDIATION AND ARBITRATION SERVICES, so, the 20th of august 2014, as being and knowing be under the protection of the immunity from her professional authorities, Cynthia HACKLER filed a procedure to « Small Claims Court » to be paid of her numerous unlawful invoices, all disputed by Laurent GRANIER, all of them with no proof, no justification. She used lies, fake and wrong declarations, serious omissions leading to deliberate useful misunderstandings and false understandings beneficial to her. She even included and claimed her future expenses for her initated unlawful and useless motion to be relieved.


In the end, being already victim of serious criminal offenses, being under dangerous threats by an insane person, being victim of an absolute lack of assistance and help from authorities, and in addition, being foreigner in a country which he does not know much its rules, Laurent GRANIER suffered physically and morally. Being psychologically and emotionally drained by this double injustice, and instead to have help and assistance, in order to regain peace of mind, he has had to face more troubles, more hassle, more problems, about his lawsuits against Dean TURCHI, but also, in addition, he found new ones with the person supposed to protect and to help him.

His trust has been destroyed and his situation has been made worse, having to continue his lawsuit alone, but also, to make new ones to avoid to be screwed by his lawyer who deceived him.

In addition of his loss and his health problems caused by the adverse party, Laurent GRANIER has had more damages by the fault of his lawyer who has not given him peace of mind, on the contrary. He missed an important international exhibition show in June 2014, in Las Vegas, which was useful to sell licences and softwares about one of his invention (game), a market of several millions.

He was so disturbed by the dirty and dishonest behaviours of his lawyer that he has had to travel, to try to find peace of mind. But, instead to regain it, Cynthia HACKLER was continuing to annoy him, to harass him, to cause him more and more damages.

So, in addition of this several millions dollars loss of this project which was delayed, Plaintiff was totally disturbed to continue his other one he had to launch, a new technology for movie. His project was to produce the first movie, and for that, he had to write the script. Facing all those troubles, he has had to delay this project too. He lost several months, causing few millions dollars loss and damages.

Some official persons, judges, clerks, lawyers, Commission on Judicial Performance (State Agency about lawyer misconduct...), some L.A. City agencies,  cheated and covered up all of this.

Additional Amendment 1

Additional Amendment 2

Additional Amendment 3

​The complaint filed at Los Angeles Court 10 09 14 .pdf