- Reply filed on March 2, 2011, for hearing to be held March 10th in Dept. 1 at 9:00 a.m. (This filing has yet to be posted electronically on the Court's website.) Now Available Here 3-10-11
- Reply In Support of Motion for Renewal of Motion to Void and Annul All Orders and Judgments, Including Those in the Contempt Proceedings in the Case Made by Judge Yaffe. [Download and Print entire ten-page document with exhibits here, or individual Exhibits #1 thru #6, below.]
Summary Headings as stated in the Reply Brief:
1. No Opposition Filed by L A County or Del Rey Shores. (If this were an appellate case, "failure to oppose a motion may be deemed a consent to the granting of the motion". Cal. Rules of Court, Rule 8.54(c).)
2. L. A.. County Did Not "Serve" Any Opposition.
Exhibit #1 Superior Court Website Case Summary #BS1094203. The "Unfiled" Del Rey Shores Opposition Did Not Contest Any of the Grounds, New Facts, Legal Significance of Such New Facts or Reasons for the Motion, Thereby Effectively Conceding to the Granting of the Motion.4. New Documents Confirm L. A. County and Del Rey Shores Commit Redevelopment Fraud From the Outset of This Case.
- A. - L. A. County Supervisors, L. A. County and the Epsteins Have Engaged in a Fraud Regarding the Del Rey Shores Redevelopment Project from the Outset.
- Exhibit #2, Letter dated 2-15-11 from Beaches & Harbors to L. A. County Board of Supervisors containing an "Adopted" stamp on the first page.
- Exhibit #4, Letter, Beaches & Harbors' response to Public Records Act Request
- B. - "Pay To Play" - All L. A. County Board of Supervisors' Approvals of the Del Rey Shores Redevelopment Were Illegal Due to the Illegal Votes of Supervisors Voting for the Project Who Had Received Contributions of $500.00 or More Within One Year of Their Votes on the Project from Epstein and the Epstein Interest.
5. California and Federal Statutory and Case Law Mandate that Judges Taking Money from a Person Appearing Before Them Lose Their Judgeships and Be Imprisoned for "Bribery" and the Violation of the "Intangible Right to Honest Services".6. Senate Bill SBX2-11, Section 5, the Retroactive Immunity Section, Does Not Protect the Judges, Government Entities, Government Officials and Employees from State Criminal Prosecution and Removal From Office for Obstruction of Justice and Federal Prosecution for Bribery. (Exhibit #6, L. A. County Auditor-Controller - Report on Judicial Benefits)7. Section 5 of Senate Bill SBX2-11 is Unconstitutional.8. The Del Rey Opposition's Argument that this Motion Is For Reconsideration Is Fraudulent, Frivolous and Totally Without Merit.REQUEST FOR JUDICIAL NOTICE: Fine respectfully requests that the Court take Judicial Notice of all exhibits to the Declaration of Richard I. Fine shown as having been obtained from Los Angeles County as official records of Los Angeles County.
IMPORTANT NOTE FOR READERS: California Senate Bill SBX2-11, which the judges use to avoid prosecution for receiving illegal county payments, provides NO immunity for "obstruction of justice" for sitting on cases while receiving money from a party to the case; Canons of Judicial Ethics offer them no safe harbor either. (See Summary Items #6 and #7.) SBX2-11 also did not amend the California Constitution, thus judges remain in violation of Article VI, Section 19, which states that judges' income is limited to that provided by the State alone (with a few minor exceptions for educators, etc.).County Redevelopment Partners
Jerry & Pat Epstein ~ Kirk & Anne Douglas
Del Rey Shores Developers