Motion to Shorten Time Form by ql9Z07o

VIEWS: 28 PAGES: 14

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3    RENADA NADINE MARCH
     7 Bluebird Lane
4    Aliso Viejo, California 92656
     Tel: 949-742-0436
5    E-mail: renadajewel@gmail.com
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                            IN THE UNITED STATES DISTRICT COURT
7                         FOR THE CENTRAL DISTRICT OF CALIFORNIA
8                           SOUTHERN (ORANGE COUNTY) DIVISION

9    MEGLODON FINANCIAL, LLC
        PLAINTIFF,                                                          CIVIL ACTION NUMBER:
10                                                                          SA CV09-1355 GW (SS)
11   versus
                                                                            Removed from Orange County
12   RENADA NADINE MARCH,                                                   30-2009-00312382-CL-UD
13       Defendant.                                                         Superior Court of California
     _______________________________/
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           MOTION FOR STAY OF REMAND [28 U.S.C. §1447(d)]
15                 Motion For Transfer to Judge Carter
16                           AND RENEWED
       REQUEST FOR FULL EVIDENTIARY (Preliminary Injunction) HEARING
17       re: DOMBROWSKI v. PFISTER FACTORS, 380 U.S. 479 (1965)
18           Comes now the Defendant, to invoke her right to secure and lay
19   the foundation for immediately review, “by appeal or otherwise” of this
20   Court’s Order of December 11, 2009, “Remanding Action to the
21   Superior Court of California for the County of Orange” as specifically
22   and specially allowed by 28 U.S.C. §1447(d) for all cases removed on
23   grounds of civil rights violations. The Court, in its December 11, 2009,
24   Order of Remand, STILL appears to ignore or disregard the factual
25   basis for Defendant Renada March’s removal to this court under 28
26   U.S.C. § 1443(1). In the Court’s footnote 1, at the bottom of page 2, the
27   Court, writes that “Dombrowski provides no basis for removal.” This
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     Motion for Stay of Remand for a Minimum of 28 Days, Transfer to Judge David O. Carter, Southern Division, and
     Renewed Dombrowski v. Pfister Motion for Evidentiary hearing for Stay of State proceedings relating to Defendant
     Renada Nadine March’s Removal under 28 U.S.C. §1443(1)
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3    is manifestly incorrect: statutory removals are treated as stays of state
4    court proceedings under the anti-injunction act, 28 USC §2283:
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             § 2283. Stay of State court proceedings
6                  A court of the United States may not grant an injunction to
             stay proceedings in a State court except as expressly authorized
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             by Act of Congress, or where necessary in aid of its jurisdiction, or
8            to protect or effectuate its judgments.
9            Dombrowski is one of a trio of cases, including Younger v. Harris,
10   401 U.S. 37; 91 S. Ct. 746; 27 L.Ed.2d 669 (1971), culminating in Mitchum
11   v. Foster, 407 U.S. 225; 92 S.Ct. 2151; 32 L.Ed.2d 705 (1972), which
12   specifically addresses the relationship between civil rights actions under 42
13   U.S.C. §1983 and the anti-injunction act:
14           It is clear from the legislative debates surrounding passage of § 1983's
             predecessor that the Act was intended to enforce the provisions of the
15           Fourteenth Amendment "against State action, . . . whether that action be
             executive, legislative, or judicial." Ex parte Virginia, 100 U.S. 339, 346
16           (emphasis supplied). Proponents of the legislation noted that state courts
             were being used to harass and injure individuals, either because the state
17           courts were powerless to stop deprivations or were in league with those who
             were bent upon abrogation of federally protected rights.
18           As Representative Lowe stated, the "records of the [state] tribunals are
             searched in vain for evidence of effective redress [of federally
19           secured rights] . . . . What less than this [the Civil Rights Act of
             1871] will afford an adequate remedy? The Federal Government
20           cannot serve a writ of mandamus upon State Executives or upon
             State courts to compel them to protect the rights, privileges and
21           immunities of citizens . . . . The case has arisen . . . when the
             Federal Government must resort to its own agencies to carry its
22           own authority into execution. Hence this bill throws open the
             doors of the United States courts to those whose rights under the
23           Constitution are denied or impaired." Cong. Globe, 42d Cong., 1st
             Sess., 374-376 (1871). This view was echoed by Senator Osborn: "If the State
24           courts had proven themselves competent to suppress the local disorders, or
             to maintain law and order, we should not have been called upon to legislate .
25           . . . We are driven by existing facts to provide for the several states in the
             South what they have been unable to fully provide for themselves; i. e., the
26           full and complete administration of justice in the courts. And the courts with
             reference to which we legislate must be the United States courts." Id., at
27           653. And Representative Perry concluded: "Sheriffs, having eyes to see, see
             not; judges, having ears to hear, hear not; witnesses conceal the truth or
28           falsify it; grand and petit juries act as if they might be accomplices . . . . All
             the apparatus and machinery of civil government, all the processes of justice,                             2
     Motion for Stay of Remand for a Minimum of 28 Days, Transfer to Judge David O. Carter, Southern Division, and
     Renewed Dombrowski v. Pfister Motion for Evidentiary hearing for Stay of State proceedings relating to Defendant
     Renada Nadine March’s Removal under 28 U.S.C. §1443(1)
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             skulk away as if government and justice were crimes and feared detection.
3            Among the most dangerous things an injured party can do is to appeal to
             justice." Id., at App. 78.
4            Those who opposed the Act of 1871 clearly recognized that the proponents
             were extending federal power in an attempt to remedy the state courts'
5            failure to secure federal rights. The debate was not about whether the
             predecessor of § 1983 extended to actions of state courts, but whether this
6            innovation was necessary or desirable.
             This legislative history makes evident that Congress clearly conceived that it
7            was altering the relationship between the States and the Nation with respect
             to the protection of federally created rights; it was concerned that state
8            instrumentalities could not protect those rights; it realized that state officers
             might, in fact, be antipathetic to the vindication of those rights; and it
9            believed that these failings extended to the state courts.
                     Section 1983 was thus a product of a vast transformation from the
10           concepts of federalism that had prevailed in the late 18th century when the
             anti-injunction statute was enacted. The very purpose of § 1983 was to
11           interpose the federal courts between the States and the people, as guardians
             of the people's federal rights -- to protect the people from unconstitutional
12           action under color of state law, "whether that action be executive, legislative,
             or judicial." Ex parte Virginia, 100 U.S., at 346.In carrying out that purpose,
13           Congress plainly authorized the federal courts to issue injunctions in § 1983
             actions, by expressly authorizing a "suit in equity" as one of the means of
14           redress. And this Court long ago recognized that federal injunctive relief
             against a state court proceeding can in some circumstances be essential to
15           prevent great, immediate, and irreparable loss of a person's constitutional
             rights. Ex parte Young, 209 U.S. 123; cf. Truax v. Raich, 239 U.S. 33;
16           Dombrowski v. Pfister, 380 U.S. 479. For these reasons we conclude that,
             under the criteria established in our previous decisions construing the anti-
17           injunction statute, § 1983 is an Act of Congress that falls within the
             "expressly authorized" exception of that law.
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     407 U.S. 240-242, 92 S.Ct. 2161-2162, 32 L.Ed.2d 716-718 (bold added).
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              By its exhaustive review of the legislative history of 42 U.S.C. §1983,
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     Mitchum concludes unequivocally that civil rights injunctions against state
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     court proceedings ARE “expressly authorized by Act of Congress” (namely
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     §1983) and are therefore permitted under the anti-injunction act.
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     Dombrowski and Mitchum both upheld Federal Court injunctions against
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     state court proceedings on civil rights grounds, but all three cases
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     emphasized the fact-specific inquiry which a District Court should make
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     regarding the entry of an injunction against state court proceedings.
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             This court has correctly identified the elements of civil rights removal
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     but failed to recognize the connection between removal and the express                                             3
     Motion for Stay of Remand for a Minimum of 28 Days, Transfer to Judge David O. Carter, Southern Division, and
     Renewed Dombrowski v. Pfister Motion for Evidentiary hearing for Stay of State proceedings relating to Defendant
     Renada Nadine March’s Removal under 28 U.S.C. §1443(1)
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3    authorization of civil rights injunctions under the Dombrowski, Younger,
4    Mitchum Triad of cases, of which Mitchum is by far the most explicit in
5    dealing with “removal” as a species of Federal stays or injunctions against
6    state court proceedings, rather than an isolated phenomenon sui generis.
7            “First it must appear that the right allegedly denied in the removal
8    petition arises under a federal law ‘providing for specific civil rights stated in
9    terms of racial equality.’’ 8:09-cv-01355-GW-SS Document 7 Filed
10   12/11/2009 Page 5 of 9 at ll. 3-8 (citations omitted). The court then misses
11   the entire basis for Defendant’s removal, however, when it writes, “She has
12   not alleged that her rights are being denied “under a federal law providing for
13   specific civil rights stated in terms of racial equality.” Document 7, supra,
14   Page 5 of 9 at ll. 20-22. This again is manifestly erroneous! On Page 3, ¶8 of
15   Renada Nadine March’s Notice of Removal, at ll. 3-10, Defendant makes
16   clear and explicit that she is removing because the State of California, Orange
17   County Superior Courts, and Steven D. Silverstein are both actively denying
18   her rights secured by 42 U.S.C. §1981, which is a statute providing for equal
19   protection under the law expressly stated in terms of racial equality:
20   § 1981. Equal rights under the law
21           (a) Statement of equal rights. All persons within the jurisdiction
22           of the United States shall have the same right in every State and
             Territory to make and enforce contracts, to sue, be parties, give
23           evidence, and to the full and equal benefit of all laws and
             proceedings for the security of persons and property as is
24           enjoyed by white citizens, and shall be subject to like
             punishment, pains, penalties, taxes, licenses, and exactions of
25           every kind, and to no other.
26           (b) "Make and enforce contracts" defined. For purposes of this
             section, the term "make and enforce contracts" includes the
27           making, performance, modification, and termination of contracts,
             and the enjoyment of all benefits, privileges, terms, and
28           conditions of the contractual relationship.
                                                                                                                        4
     Motion for Stay of Remand for a Minimum of 28 Days, Transfer to Judge David O. Carter, Southern Division, and
     Renewed Dombrowski v. Pfister Motion for Evidentiary hearing for Stay of State proceedings relating to Defendant
     Renada Nadine March’s Removal under 28 U.S.C. §1443(1)
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             (c) Protection against impairment. The rights protected by this
3            section are protected against impairment by nongovernmental
4            discrimination and impairment under color of State law.
5    Bold and Italic Emphasis added.

6            Defendant Renada Nadine March has, in fact, then, already “assert[ed],

7    as a defense to the [action], rights that are given to [her, and all defendants

8    similarly situated] by explicit statutory enactment protecting equal racial civil

9    rights.” Renada Nadine March has asserted proper statutory authority by

10   citing 42 U.S.C. §§1981-1982.

11           When Defendant wrote:
                   If, for example, previous jurisprudence on 28 U.S.C.
12           §1443(1) has limited this powerful statute to cases involving racial
13           discrimination, the Court should look to the language of the
             statute and give full force and effect to every word of the
14           congressional enactment, keeping in mind that over the thirty one
             years (since Regents of Univ. of Cal. v. Bakke, 438 U.S. 265, 57 L.
15           Ed. 2d 750, 98 S. Ct. 2733 [1978]) the United States Supreme
16           Court has radically retreated from the use of racial classifications
             to limit the applications of civil rights laws. See, e.g., Grutter v.
17           Bollinger, 539 U.S. 306; 123 S. Ct. 2325; 156 L. Ed. 2d 304
18           (2003).
     in her Response to Magistrate Judge Segal’s Order to Show Cause, Defendant
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     Renda Nadine March merely argued for a COLOR BLIND APPLICATION OF
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     THE CIVIL RIGHTS LAWS.
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             Contrary to this Court’s Order of Remand in Document 7, filed
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     12/11/2009, Defendant never contended that she did not cite or was not
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     required to cite statutes such as 42 U.S.C. §§1981-1982, she merely argued,
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     consistent with the massive weight of recent Supreme Court holdings, that
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     Civil Rights laws should be enforced equally for white Caucasians as well as
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     so called “racial minorities” (and in California, the U.S. Census Bureau has
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     Motion for Stay of Remand for a Minimum of 28 Days, Transfer to Judge David O. Carter, Southern Division, and
     Renewed Dombrowski v. Pfister Motion for Evidentiary hearing for Stay of State proceedings relating to Defendant
     Renada Nadine March’s Removal under 28 U.S.C. §1443(1)
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3    already established that white Caucasians ARE a racial minority, at least in
4    this state).
5            Likewise, with regard to the second prong of civil rights removal under
6    28 U.S.C. §1443(1), the court correctly stated that “either the denial of the
7    specified right must be ‘manifest in a formal expression of state law’ or the
8    defendant must show that there is ‘an equivalent basis . . . for an equally firm
9    prediction that the defendant would be denied or cannot enforce the specified
10   federal rights in state court.” Document 7, supra, Page 5 of 9, ll. 11-15.
11           But the Court then completely ignored or disregarded Defendant’s
12   contention that California Civil Code §2924 is a formal expression of state
13   law which denies her the specific rights guaranteed to her, in terms of racial
14   equality, by both 42 U.S.C. §§1981 and 1982. Defendant’s contentions in
15   regard to California Civil Code §2924 are articulated and set out more fully in
16   the proposed class action to which she is a co-Plaintiff, namely 8:09-cv-
17   01072-DOC-Ex, which Renada Nadine March mentioned in ¶9 at ll. 11-17 on
18   page 3 of her Notice of Removal, in which paragraph she also suggested that
19   “this action, once removed, can and should be consolidated with that action,
20   assigned to Judge David O. Carter.” ¶9, ll. 15-17. Defendant is unsure why
21   this case was not transferred to Judge Carter, but here and now:
22           Defendant hereby MOVES AND REQUESTS that, for
23   purposes of the resolution of this motion and for all subsequent
24   proceedings, including Defendant’s Rule 59(e) Motion which will
25   be filed on or before the expiration of 28 days, which is to say on
26   January 8, 2010 (see 2009 Amendments to Rule 59) this case be
27   TRANSFERRED and ASSIGNED to Judge David O. Carter.
28   Christyna Lynn Gray, Defendant Renada Nadine March’s co-
                                                                                                                        6
     Motion for Stay of Remand for a Minimum of 28 Days, Transfer to Judge David O. Carter, Southern Division, and
     Renewed Dombrowski v. Pfister Motion for Evidentiary hearing for Stay of State proceedings relating to Defendant
     Renada Nadine March’s Removal under 28 U.S.C. §1443(1)
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3    Plaintiff against Silverstein et al. in 09-cv-01072-DOC, also
4    removed her Silverstein eviction proceedings to Federal Court,
5    and her case was properly transferred to Judge David O. Carter
6    (see Exhibit A).
7            This transfer should be effected not merely because this removal case
8    should not be decided separately from 09-cv-01072-DOC, because it is a
9    hardship for this Plaintiff to travel to Los Angeles. Venue more properly lies
10   in the Southern Division of the Central District of California, based in Santa
11   Ana, because all or at least a substantial part of the transactions and
12   occurrences giving rise to this cause of action took place in Orange County,
13   which is entirely within (in fact co-extensive with) the said Southern Division.
14           Defendant Renada Nadine March submits that careful examination of
15   the First Amended Complaint filed in 09-cv-01072-DOC will clearly show
16   that she (and her co-Plaintiffs) have made “an equally firm prediction that
17   the defendant would be [will be and is in fact being] denied or cannot enforce
18   [her] specified rights [under 42 U.S.C. §S1981-1982] in the state court [Cal.
19   Superior Court of Orange County].” Judge Wu, 8:09-cv-01355-GW-SS,
20   Document 7, Filed 12/11/2009, Page 6 of 9, ll. 2-5.
21           In light of ¶8 from page 3 of her Notice of Removal, cited above, which
22   states that “respondents always lose in Orange County Unlawful
23   detainer proceedings as a matter of statutory law, custom,
24   practice, and policy it” is simply preposterous to conclude that
25   “Defendant has neither identified a formal expression of state law that
26   manifestly denies her rights nor shown an equivalent basis for a firm
27   prediction that she will not be able to enforce her rights in the California
28   courts.” It is absolutely INCONCEIVABLE, in light of this allegation, taken
                                                                                                                        7
     Motion for Stay of Remand for a Minimum of 28 Days, Transfer to Judge David O. Carter, Southern Division, and
     Renewed Dombrowski v. Pfister Motion for Evidentiary hearing for Stay of State proceedings relating to Defendant
     Renada Nadine March’s Removal under 28 U.S.C. §1443(1)
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3    together with the allegations of the First Amended Complaint in 09-cv-
4    01072-DOC (See Exhibit B) that the Court should not see that Defendant has
5    (and her co-Plaintiffs in the related case have) in fact alleged facts suggesting,
6    if not conclusively demonstrating, that “it can be clearly predicted by reason
7    of the operation of a pervasive and explicit state or federal law that those
8    rights will inevitably be denied by the very act of bringing the defendant to
9    trial in the state court.” Document 7, Page 7, ll. 8-11.
10           If the court should find that the consistent allegation of the three
11   Plaintiffs in 09-cv-01072-DOC is insufficient to establish, at least for
12   purposes of pleading removal or other grounds for federal injunction of state
13   court proceedings, that “it can be clearly predicted” that ALL Unlawful
14   Detainer Action Defendants in Orange County, indeed in the State of
15   California, will lose, in plain denial of their explicit federally secured rights
16   under 42 U.S.C. §§1981-1982, “by the very act of bringing the defendant to
17   trial in the State Court” following any non-judicial foreclosure under
18   California Civil Code §2924, then this Court’s doubt should be resolved by
19   allowing and scheduling a full-blown evidentiary hearing regarding the
20   inevitability of eviction, no matter how outrageous the Plaintiff’s conduct, or
21   how far in disregard and derogation of all other norms of contractual or
22   consumer-protection law, because of the UNLAWFUL IMMUNITY created
23   expressly by the terms of California Civil Code §2924, which immunity is
24   nothing less than a license to lie, cheat, and defraud the homeowners and
25   mortgagors resident in this State.
26           Defendant Renada Nadine March therefore asks this Court to STAY the
27   REMAND and/or ENJOIN ANY FURTHER PROCEEDINGS against her in
28   the Superior Courts of Orange County for at least 28 days to permit her to
                                                                                                                        8
     Motion for Stay of Remand for a Minimum of 28 Days, Transfer to Judge David O. Carter, Southern Division, and
     Renewed Dombrowski v. Pfister Motion for Evidentiary hearing for Stay of State proceedings relating to Defendant
     Renada Nadine March’s Removal under 28 U.S.C. §1443(1)
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3    research, fully brief, and file her Rule 59(e) Motion to Amend or Alter
4    Judgment within the time frame provided by the December 2009
5    amendments to Rule 59 of the Federal Rules of Civil Procedure. Whatever
6    doubts the Court have should be resolved by an evidentiary hearing on the
7    model of any ordinary hearing on Preliminary Injunction, except that the
8    subject matter of this hearing should be framed by the issues and guidelines
9    established in Dombrowski v. Pfister, Younger v. Harris, and
10   Mitchum v. Foster, all supra.
11           The Court should find and rule that such a motion and the holding of
12   such an evidentiary hearing are uniquely proper in a case removed pursuant
13   to 28 U.S.C. §1443 as provided by 28 U.S.C. §1447(d) ascribes a very special
14   and privileged status to Civil Rights Removal:
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               (d) An order remanding a case to the State court from
16           which it was removed is not reviewable on appeal or
             otherwise, except that an order remanding a case to the
17           State court from which it was removed pursuant to
18           section 1443 of this title [28 USCS § 1443] shall be
             reviewable by appeal or otherwise.
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                      As has been argued hereinabove and throughout this Response,
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     28 U.S.C. §1443 has UNIQUE status among all removals, totally distinct and
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     different from removals based on Federal question or diversity jurisdiction,
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     in that an order of remand is immediately appealable in this case.
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     CERTIFICATE OF CONFERENCE and the Silverstein Factor
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             As required by the local rules of the Central District of California, at
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     approximately 1:43 PM on 12/17/09, Defendant Renada Nadine March spoke
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     to Attorney Steven D. Silverstein, attorney for Meglodon Financial LLC via
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     cell phone to Attorney Silverstein at 714-832-3652. It is safe to say that Mr.
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     Silverstein opposes Defendant’s Motion for Stay, in that Mr. Silverstein                                           9
     Motion for Stay of Remand for a Minimum of 28 Days, Transfer to Judge David O. Carter, Southern Division, and
     Renewed Dombrowski v. Pfister Motion for Evidentiary hearing for Stay of State proceedings relating to Defendant
     Renada Nadine March’s Removal under 28 U.S.C. §1443(1)
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3    threatened the Defendant with retaliation for her role in 09-cv-01072-DOC as
4    follows, “You’re removal was denied and I am giving you notice that
5    I am going after you. This is personal now. You have singled me
6    out and now I’m going to take you out. I’m going to be at the court
7    at 9:00 in the morning and you won’t know what hit you.”
8            By “court” Defendant presumes Silverstein meant Orange County
9    Superior Court, Laguna Hills from which this case was removed less than a
10   month ago. Defendant does not presume to know exactly what Silverstein
11   meant by the remainder of the rough language used, but the loud,
12   determined, and threatening tone and force of his voice was intimidating and
13   frankly, to this Defendant, frightening. He sounded like he intended to
14   “jump” me (violently and physically) to the point that after the call I debated
15   whether to call the Orange County Sheriff’s Department or other law
16   enforcement authorities to request “protection” or even seek a restraining
17   order. Defendant’s co-Plaintiff in 09-cv-01072-DOC, Charles Edward
18   Lincoln, has referred to Silverstein as a “pirate”, and Defendant Renada
19   Nadine March can only say that Silverstein’s telephone demeanor was at the
20   very least consistent with that description. On previous occasions, Defendant
21   has seen Silverstein wearing the insignia of great white sharks, dogs eating
22   cats, and other violent symbols. The man clearly thrives on intimidation and
23   is not afraid to suggest that he “owns” the Orange County Superior Courts
24   and boasts that he successfully evicts 100 homeowners every day.
25                                           PRAYER FOR RELIEF
26           WHEREFORE THEN, additionally, Removing Respondent (Defendant)
27   Renada Nadine March prays for a 28 day extension of the time to fully and
28   completely brief and prepare her Rule 59(e) Motion, and/or for an
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     Motion for Stay of Remand for a Minimum of 28 Days, Transfer to Judge David O. Carter, Southern Division, and
     Renewed Dombrowski v. Pfister Motion for Evidentiary hearing for Stay of State proceedings relating to Defendant
     Renada Nadine March’s Removal under 28 U.S.C. §1443(1)
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3    evidentiary hearing, as previously requested on the model of a full
4    evidentiary hearing on Application for Preliminary Injunction.
5            The remand of this case, protected as it is by the special provisions of
6    28 U.S.C. §1447(d) allowing the “review[] on appeal or otherwise” of cases
7    removed pursuant to 28 U.S.C. §1443(1), is improper and should be stayed
8    pending a full briefing and submission of evidentiary proof that the California
9    Superior Courts have never denied an eviction pursuant to a foreclosure
10   under California Code of Civil Procedure 2924.
11                                                        Respectfully submitted,
12   Friday, December 18, 2009
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14                                                        By:__________________________
15                                                             RENADA NADINE MARCH,
                                                               Pro se/in propia persona
16                                                             7 Bluebird Lane
                                                               Aliso Viejo, California 92656
17                                                             Telephone: 949-742-0436
18                                                             E-mail:
                                                               renadajewel@gmail.com
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     Motion for Stay of Remand for a Minimum of 28 Days, Transfer to Judge David O. Carter, Southern Division, and
     Renewed Dombrowski v. Pfister Motion for Evidentiary hearing for Stay of State proceedings relating to Defendant
     Renada Nadine March’s Removal under 28 U.S.C. §1443(1)
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4                                       CERTIFICATE OF SERVICE
5            I the undersigned Defendant do hereby certify that I served a
6    true and correct, original signed copy of the above-and-foregoing,
7    Motion for Stay of Remand Pursuant to 28 U.S.C. §1447(d) for a
8    minimum of 28 days, Motion to Transfer to Judge David O. Carter,
9    and Renewed Dombrowski v. Pfister motion for evidentiary hearing:
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11                              Steven D. Silverstein, Attorney-at-Law
                                         Silverstein Eviction Law
12                                     14351 Redhill Ave., Suite #G
                                             Tustin, CA 92780
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     Served by the Defendant,
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                                                 Respectfully Submitted,
15   And signed, all on
16   Friday,
     December 18, 2009
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                                             By:______________________________
18                                           RENADA NADINE MARCH,
19                                           Removing pro se/in pro per
                                                       7 Bluebird Lane
20                                                     Aliso Viejo, California 92656
21                                                     Telephone: 949-742-0436
                                        E-mail: renadajewel@gmail.com
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     Motion for Stay of Remand for a Minimum of 28 Days, Transfer to Judge David O. Carter, Southern Division, and
     Renewed Dombrowski v. Pfister Motion for Evidentiary hearing for Stay of State proceedings relating to Defendant
     Renada Nadine March’s Removal under 28 U.S.C. §1443(1)
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12                                   Exhibit A:
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                                   Civil Docket in
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15                         First Newport Properties v.
16                            Christyna Lynn Gray
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                               09-cv-01389-DOC-E
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19                              transferred to Judge
20                                David O. Carter
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     Motion for Stay of Remand for a Minimum of 28 Days, Transfer to Judge David O. Carter, Southern Division, and
     Renewed Dombrowski v. Pfister Motion for Evidentiary hearing for Stay of State proceedings relating to Defendant
     Renada Nadine March’s Removal under 28 U.S.C. §1443(1)
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15                                   Exhibit B:
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                            First Amended Complaint in
18                             09-cv-01072-DOC-Ex
19                            Filed December 7, 2009
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     Motion for Stay of Remand for a Minimum of 28 Days, Transfer to Judge David O. Carter, Southern Division, and
     Renewed Dombrowski v. Pfister Motion for Evidentiary hearing for Stay of State proceedings relating to Defendant
     Renada Nadine March’s Removal under 28 U.S.C. §1443(1)

								
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