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FROM: Abdul-Jalil al-Hakim
DATE: May 1, 2019
NO PAGES: 3
RE: Bigot Brand Disparages al-Hakim Religious Practice of Islam at April 29, 2019 Hearing
“In another religion they honor people who serve like you with Sainthood!” – Economics Professor Adeel Malik,Oxford University, England and World Renowned News Expert Commentator, speaking about Abdul-Jalil and the Aaron & Margaret Wallace Foundation.
“GOD sent me an ANGEL!” – Hammer, speaking about Abdul-Jalil.
“I thank God for you and for bringing you into my life and for the ministry you have been given to help the people of God!”– Pastor L. J. Jennings, Kingdom Builders Christian Fellowship, speaking about Abdul-Jalil and AMWF
Dear Chief Justice Cantil-Sakauye, Judges Phyllis Hamilton, Jacobson, Rolefson, Carvill, Kaus, Colwell, Hayashi, Clay, Lee, Murphy, Smith, Brand, Freedman, Markman and Carvill; Alex Tse, Xavier Becerra, Ms. Henley, Mr. Finke, Mr. Hoshino and OTHERS:
Bigot Brand Disparages al-Hakim Religious Practice of Islam at April 29, 2019 Hearing
At the hearing on April 29, 2019, Brand disparaged, denigrated, and deprecated, al-Hakim and his religious practice of Islam by referring to al-Hakim’s weekly religious obligation as “I know that you say you have a religious Holiday every Tuesday and Thursday?!”.
This bigoted, ignorant, thoughtless, irresponsible, caustic remark left al-Hakim shocked, speechless and dumbfounded! al-Hakim, humiliated at the utterance finally stumbled out “I have NEVER said that I have a religious Holiday every Tuesday and Thursday!”Brand says “Well I know you have said something like that”. al-Hakim responds “I have religious obligations every Tuesday, Thursday and Friday, they are NOT Holidays”.
Irate at the fact that he MUST conform with the law to at least a minimum, Brand asks al-Hakim “when will you be available for an appearance”, wherein al-Hakim responded “the first Monday or Wednesday after June 20, 2019”. Brand states that “you will be gone for Ramadan?”and al-Hakim says “yes, I noticed you of that fact a month ago”. Brands retorts in a very snide, rude manner “I know, I was just asking”and al-Hakim responded “I was just answering”. Brand asks “when does it start?”, al-Hakim responds “Sunday”. Brand then orders the parties to appear two days later on May 1, 2019, at 9:00 a.m.
It was clear that Brand has an agenda to move the VENDETTA- TARGETED AL-HAKIM Superior Court Criminal/Civil Vexatious Entrapment Litigation Strategy to completion before al-Hakim takes retreat for Ramadan so that they can gain another uncontested appeals verdict knowing al-Hakim will NOT be able to respond before June 15, 2019!
It MUST be noted that Brand had TWO sheriff’s deputies in the wings of the jury box waiting with orders in hand!
Brand attempts to cast aspersions on al-Hakim’s religion and it’s practice as frivolous, a Frat party, or Rave, to impugn, vilify, traduce and portray al-Hakim as a carouser, party animal, nefarious hypocrite, insincere. This is perhaps the HIGHEST ranking tenet in the pillars of Islam and is mandated, commanded upon ALL muslims! al-Hakim is long established at this, over 60 years, is recognized and honored world wide for his service, is consulted and relied on for his service to the Islamic community and humanity at large!
Brand and the judges have deprive al-Hakim of certain fundamental rights including the right to freedom of religion and to free speech and the due process of law and penalize him because of his religious beliefs! requiring al-Hakim to abandon his religious beliefs and practices in order to receive benefits. discriminates against al-Hakim and Muslims violates the First Amendment’s Establishment Clause.
This divisive case highlights the vast difference between the reality and the rhetoric of religious freedom, which is often considered to be the ideal that promotes harmony and equality in the judicial system. But, history suggests that it does lead to more conflict due to the biases and prejudices of those same justices echoing the view that religious freedom brings inequality and disunity so the government and courts systematically enact mainstream practices favoring particular races and faiths for cause and preventing religious freedom and liberty!
Brands prejudice is pathological and projects a personality syndrome linked with racism as well to establish and cultivate his own race, class and religious supremacy based on favoritism towards his own perceived group, their admiration, sympathy, and trust of his ingroup, the “Courtel”.
BRAND CAN NOT SERVE IN ANY CAPACITY IN ANY AL-HAKIM MATTERS!
Repression of al-Hakim and First Amendment Free Exercise of Religion
The Constitution, and The Bill of Rights guarantees that the government can never deprive people in the U.S. of certain fundamental rights including the right to freedom of religion and to free speech and the due process of law. In recognizing free exercise of religion as an unalienable right, secured its protection in the First Amendment to the Constitution to keep the government out of religion– to guarantee the separation of church and state. This fundamental freedom is a major reason why the U.S. has managed to avoid a lot of the religious conflicts that have torn so many other nations apart.
The Free Exercise Clause of the First Amendment gives you the right to worship or not as you choose. The government can’t penalize you because of your religious beliefs.
Sherbert v. Verner (1963): The Supreme Court ruled that states could not require a person to abandon their religious beliefs in order to receive benefits. Sherbert v. Verner, in which a Seventh-day Adventist was fired because she wouldn’t work on Saturdays. The state denied her jobless benefits, saying she was fired for cause. The Supreme Court ruled that disqualifying her from benefits “solely because of her refusal to accept employment in which she would have to work on Saturday contrary to her religious belief, imposes an unconstitutional burden on the free exercise of her religion.” She got her benefits.
42 U.S. Code § 2000bb – Congressional Findings and Declaration of Purposes
(a) Findings The Congress finds that—
(1) the framers of the Constitution, recognizing free exercise of religion as an unalienable right, secured its protection in the First Amendment to the Constitution;
(2) laws “neutral” toward religion may burden religious exercise as surely as laws intended to interfere with religious exercise;
(3) governments should not substantially burden religious exercise without compelling justification;
(4) in Employment Division v. Smith, 494 U.S. 872 (1990) the Supreme Court virtually eliminated the requirement that the government justify burdens on religious exercise imposed by laws neutral toward religion; and
(5) the compelling interest test as set forth in prior Federal court rulings is a workable test for striking sensible balances between religious liberty and competing prior governmental interests.
(b) PurposesThe purposes of this chapter are—
(1) to restore the compelling interest test as set forth in Sherbert v. Verner, 374 U.S. 398 (1963) and Wisconsin v. Yoder, 406 U.S. 205 (1972) and to guarantee its application in all cases where free exercise of religion is substantially burdened; and
(2) to provide a claim or defense to persons whose religious exercise is substantially burdened by government.
42 U.S. Code § 2000bb–1 – Free Exercise of Religion Protected
(a) In general
Government shall not substantially burden a person’s exercise of religion even if the burden results from a rule of general applicability, except as provided in subsection (b).
(b) Exception Government may substantially burden a person’s exercise of religion only if it demonstrates that application of the burden to the person—
(1) is in furtherance of a compelling governmental interest; and
(2) is the least restrictive means of furthering that compelling governmental interest.
(c) Judicial relief
A person whose religious exercise has been burdened in violation of this section may assert that violation as a claim or defense in a judicial proceeding and obtain appropriate relief against a government. Standing to assert a claim or defense under this section shall be governed by the general rules of standing under article III of the Constitution.
(Pub. L. 103–141, § 3, Nov. 16, 1993, 107 Stat. 1488.)
Brand Holds Proceedings in Violation of Stay Due to His Vexatious Litigant Motion
CCP 391.6 reads: “Except as provided in subdivision (b) of Section 391.3, when a motion pursuant to Section 391.1 is filed prior to trial the litigation is stayed, and the moving defendant need not plead, until 10 days after the motion shall have been denied, or if granted, until 10 days after the required security has been furnished and the moving defendant given written notice thereof. When a motion pursuant to Section 391.1 is made at any time thereafter, the litigation shall be stayed for such period after the denial of the motion or the furnishing of the required security as the court shall determine.”
Thus, this litigation is STAYED until the court issues a ruling on the merits of the motion for vexatious litigant. After the court rules on the vexatious litigant motion, the parties may pursue litigation.
Brand has attempted to hold proceedings and Defendants have filed order for an appearance and examination and a civil subpoena duces tecum and bench warrant set for April 8, 2019, before Brand when the court and defendants are aware that there is a stay in place during the pendency of a vexatious proceeding.
Defendants claim in the Background of their ex-parte application:
“The order and a civil subpoena duces tecum were served personally on the judgment debtor on February 25, 2019. The judgment debtor attempted to decline service and discarded the papers. See Exhibit 3. The judgment debtor has previously claimed a religious obligation precluding his attendance at court on days other than Mondays or Wednesdays. Wellpoint seeks an order re setting the order for appearance and examination proceeding to April 8th or 10th 2019 or the next available Monday or Wednesday as may be convenient to the court.”
Defendants claim in their ex-parte application Points and Authorities at ¶ 3:
Judgment debtor al-Hakim has been difficult to serve and even tried to refuse personal service twice in this proceeding within the last year. Bradley Dec. ~ 8 and Exhibit 3”
Defendants then claim in their ex-parte application Declaration at ¶ 5:
“The order for appearance and examination and a civil subpoena duces tecum for records was personally served on judgment debtor al-Hakim, although he attempted to refuse service and left the papers in the court’s stairwell.”
Defendants then claim in their ex-parte application Declaration at ¶ 8:
“I believe judgment debtor al-Hakim has been difficult to personally serve. Service has been a problem in this case with judgment debtor al-Hakim claiming that he does not receive documents served on him by mail (after complaining about receiving unsigned proofs of service) or even posted on the real property he used to own. I personally served judgment debtor al- Hakim with written discovery requests. He tried to refuse service. He later claimed he was not served. The process server who personally served the order for appearance and examination and civil subpoena reported similar problems with an attempt to refuse service. To maintain jurisdiction over the judgment debtor if he were to fail to appear for the continued hearing date, I ask that the court order a bench warrant but stay issuance pending the re-set hearing date.”
Defendants contention of an admitted failed attempt to serve al-Hakim with an “announced service” and leaving the alleged service “in the stairwell”. According to their proof of service, the server SCOTT M. FEELY of SWIFT ATTORNEY SERVICE admits in his attached proof:
“THE SUBJECT WAS SERVED IN THE STAIRWELL – REFUSED TO TAKE THE DOCUMENTS. THE SUBJECT DID NOT WANT TO ACCEPT, SERVER ANNOUNCED SERVICE AND DROPPED THE DOCUMENTS ON THE FLOOR OF THE STAIRWELL. THE SUBJECT WAS POSITIVELY ID’D BY JOHN BRADLEY. Attempt made by: SCOTT M. FEELY. Attempt at: ALAMEDA COUNTY SUPERlOR CT., DEPT. 511 24405 AMADOR STREET Hayward, CA 94544.”
This DOES NOT constitute proper service, quite the contrary, it’s admission of failing and refusing to do so! I was NEVER served anything, NEVER had anyone come up to me attempting to, NEVER saw anyone, and if anything occurred behind me as I went up the stairs, I NEVER looked back from the time I left the courtroom!
The imaginary service game of lies and deceit by defendants is constantly on FULL display in his racist, Islamophobic, Xenophobic specious vitriol that are NOT covered under any litigation privilege! He volleys back and forth between lying as a lawyer and lying as a debt collector, which he does all the time. He dodges back and forth claiming he served al-Hakim then admits three times in the same document that he has problems doing so and has failed to, yet asks Brand to support him with a warrant for al-Hakim’s arrest!
It should be noted by the court that the proceedings that Brand has conducted since February 28, 2019, are ALL moot as there is a stay that accompanies your now THIRD ordered vexatious litigant motion. As such al-Hakim will not be attending the proposed April 8, 2019 hearing that is subject to the stay.
Reason for Late Submission of Opposition to Vexatious Litigant OSC
Plaintiff Abdul-Jalil al-Hakim’s (Plaintiff, al-Hakim) filed Brief in Opposition to the THIRD Order to Show Cause in the Alleged Vexatious Litigant Proceeding CCP 391(b)(3) in six months. The opposition is supported by the Memorandum, al-Hakim Declaration and Appendix attached in support of the brief. The opposition was submitted the last week of the hearing not out of neglect nor al-Hakim being remise, but for two reasons:
1) a. because he waited to receive the orders from the February 25, 2019 hearings from the court on the six motions pending in the CSAA case. The six orders where served March 26, 2019, well AFTER the scheduled filing of the initial opening brief in this matter of March 21, 2019, so that they would evade being included in same,
b. and the order from the February 25, 2019 hearing, unopposed, uncontested, three times failed to appear, defaulted motion to vacate the unlawful detainer/writ of execution in the Green Key case. On April 3, April 15, and April 17, 2019, al-Hakim sent two faxes and emails each time to the court and opposing parties requesting the order from the uncontested, defaulted motion. Thats TEN REQUESTED NOTICES and it has yet to be served even though it was unopposed and thrice defaulted for failure to appear.
2) Due to the illegal eviction from the defaulted Green Key case, al-Hakim was forced out of his home with only two days to move and was unable to take anything! Of note is the fact he left all his personal and business computers, files that are now in the custody and control of the opposition. al-Hakim has NONE of the files he had accumulated over his life of years! Green Key has total possession and control of ALL al-Hakim’s possessions, Four times al-Hakim has demanded the return of EVERYTHING, ALL ITEMS LEFT IN THE HOUSE, WITHOUT ANY DAMAGE TO THEM! Green Key has NEVER responded to the demand. We are sure the items of interest are in the control of the courts partners, law enforcement!
This places an intolerable burden on al-Hakim and makes it impossible to present this document in a concise and cogent manner without the necessary documentary support.
Green Key Defaulted, Failure to Appear Three Times
In the Green Key Case, Brand ignored the fact al-Hakim did NOT received any response from the court to his over THIRTEEN (13) communications, contacts, documents, faxes and emails, including TWO phone calls and voicemail messages, and hand delivered the documents with a court filed letter requests to his clerks Scott Sanchez and Cynthia Trinidad over three weeks PRIOR to the January 2, 2019 and January 3, 2019, hearings to request a reservation number to file an ex-parte motion for a continuance of the hearings he was unable to attend as the court and plaintiffs are and have been aware for over 30 years that al-Hakim has religious obligations on Tuesdays and Thursdays that do not allow for his presence in court which included the hearing, and proceeded despite the notices and issued a default against al-Hakim in favor of Green Key. Judge Brand, and Colwell before him, their Department 511 clerks and court administrations continuing fraud, corruption and collusion being solely responsible for this case as filed, NOT Green Key. They have been the sole force behind moving this litigation forward for them, as Green Key has failed to appear THREE TIMES consecutively without notice nor reason submitted to the court nor al-Hakim, have not filed an opposition to the motion to vacate the default writ of execution, and have NOT been issued a default nor al-Hakim being granted his motion to vacate the default taken against him!
Brand, who admitted that the last two continuances given to Green Key had NOTHING to do with the case, attempts to sit in SOLE judgment of his, the Department 511 clerks and court administration’s OWN Continuing Fraud, Corruption and Collusion committed on HIS and their OWN part!
The last Green Key defaulted, failure to appear was at the February 25, 2019, hearing, over two months ago, yet to date Brand has NOT issued an order despite the fact they failed to appear THREE TIMES consecutively without notice, and did not file an opposition to the motion to vacate the default writ of execution! Green Key has taken complete and total custody and control of ALL al-Hakim’s entire lifetime possessions, accumulation of ALL personal, family, and business belongings, things, property, goods, personal effects, assets, chattels, movables, valuables, EVERYTHING!! Over $800,000 in value that has been destroyed by Green Key and MUST BE REPLACED!!!
THIS BEGS THE QUESTION WHY IS BRAND FAVORING THEM AND NOT ISSUING THE ORDER UNTIL HE HAS SHACKLED AL-HAKIM WITH BEING DEEMED A VEXATIOUS LITIGANT UNABLE TO PURSUE ANT LITIGATION AGAINST HIM, THEM OR ANYONE ELSE?!!!
Defendant has not met their burden to show that al-Hakim is a “vexatious litigant” Under Cal. Code of Civil Procedure section 39I(b)(2), or 391(b)(3).
This action is PURELY RETALIATORY
Judge Jeff Brand, other judges listed herein, court clerks and superior court administration, in concert with unscrupulous Federal, Sate County and local judicial, law enforcement, governmental and legal entities and agencies (“entities”) have committed over 150 violations under United States and California State Constitutions against Plaintiff Abdul-Jalil al-Hakim that have been graphically detailed and documented over 40 years! (United States Constitution Amendments I, V, VI, VIII, XIV, For Violations of the Due Process Clause of the Fourteenth Amendment Under Color Of State Law; Section 1983).
This PURELY RETALIATORY, unjust, illegal act of revenge, calculated to foreclose on al-Hakim’s civil rights as promised to protect those judges and these underhanded entities known and documented to have repeatedly violated the law for years and just like Brand, they have been, are and will be a defendant and witness in those expected proceedings!! This is their collective legal defense effort to eliminate any possibility of that ever happening!
Brand has a challenge matter still pending, has NOT issued a ruling in Green Key default after their failing and refusing to file an opposition to the motion to vacate the writ of execution awarded to them by default taken against al-Hakim and THREE (3) failures to appear to oppose that motion, unlawfully evicting al-Hakim from his 40 year home, thereby strategically delaying the order to avoid further evidence of fraud on the court and to defeat this alleged vexatious litigant action wherein the judges and courts have acted as defendants CSAA co-counsel and CSAA has acted as judges counsel and government agent/informant for 20 years! BRANDS ACTIONS IN THIS CASE ARE INDEFENSIBLE! THUS THIS VEXATIOUS ACTION.
Brand installed the motion practice schedule to evade evidence of fraud on the court with the long pending six (6) CSAA orders so they could not be presented in this action.
The vexatious motion was filed on February 28, 2019, with opening brief due March 22, 2019, and reply brief due April 5, 2019, and the hearing set for April 19, 2019. Brand finally issued the long pending six (6) orders on March 24, 2019; three days AFTER the submission due date for the opening brief.
al-Hakim waited to receive the orders BEFORE filing the opposition/reply brief to include the orders as further evidence of Brands fraud on the court and exposing THIS frivolous motion as his sole defense for his, the judges, and court administration continuing fraud, corruption and conspiracy.
Court Scheduled Proceedings to Take Default against al-Hakim in VENDETTA Targeting al-Hakim with their “Muslim Ban”
Brand even had the hearing set for Thursday, April 18, 2019 and then changed it to Friday, April 19, 2019, both dates that Brand knows al-Hakim will NOT be able to attend due to a 40 year religious commitments know to Brand, defendants and the court, in another effort to take a default against al-Hakim. On April 3, April 15, and today, April 17, 2019, al-Hakim sent two faxes and emails each time to the court and opposing parties announcing the fact the court has scheduled these proceedings in furtherance of their VENDETTA Targeting al-Hakim with their Muslim Ban and requesting the hearing date be changed to a Monday or Wednesday. Thats TEN REQUESTED NOTICES FOR A CONTINUANCE and they were NOT answered. Finally, later on April 17, 2019, al-Hakim received an email from the department 511 clerk stating “Abdul-Jalil – Emailing the department is not sufficient notice for a continuance. If you need help obtaining a continuance please feel free to seek counsel or contact the self help center. This email address is only for people seeking reservations.”. (see April 17, 2019 email from Dept 511 under Exhibit 1)
This response clearly establishes their intent to take a default by design! The court can not complain about the cost of litigation in al-Hakim cases when they are responsible for the constant motions to continue, when they would not address the fact THEY chose the date without any input from al-Hakim knowing that he could NOT attend and rather than make a mutual accommodation, they suggest that he seek legal aid in filing a motion to continue! A COMPLETE WASTE OF TIME AND MONEY SOLELY TO PERSECUTE AL-HAKIM AND REWARD THE COURT AND DEFENDANTS!
Brand, the judges, the court administrations, and opposing parties actions have altered the course of litigation in scheduling proceedings on dates they know plaintiff can not attend and refusing to schedule proceedings on dates that he can attend, delaying and denying reservation numbers to file motions, failing to file or respond to plaintiff’s filing of oppositions and contesting to rulings and orders, demanding documents they already have or have better access to than al-Hakim, adding and removing proceedings from the docket and register of actions without any proceedings or authority, continuing the atmosphere of intolerable TERROR in furtherance of their corruption and agenda of hate induced persecution and entrapment, with their version of the targeted “al-Hakim Muslim Ban” has irreparably and irretrievably altered the legal outcome of the proceedings herein questioned! (see VENDETTA- TARGETED AL-HAKIM “CAMPAIGN OF CALUMNY DECEIT”; and VENDETTA- TARGETED AL-HAKIM Grand, Systemic and Endemic Corruption)
VENDETTA- TARGETED AL-HAKIM “CAMPAIGN OF CALUMNY DECEIT”
al-Hakim has long been targeted by United States Attorney General’s Office- Department of Justice; Federal and California State Judges, their ruling bodies and Associations; the Alameda County Superior Court of California, United States Attorney’s Office- Northern District; United States District Court- Northern Division, Attorney General of California, Alameda County District Attorney; City of Oakland and Oakland City Attorney; Federal, State and local law enforcement; Federal, State and local politicians.
The targeting by Brand, the judges, Alameda County Superior Court Administration, Alameda County District Attorney, City of Oakland and their City Attorney, California Attorney General, Governor Jerry Brown, Senator Kamala Harris, CSAA, Wellpoint, EBMUD, AT&T, Equinix, Interserver, and others, their contractors and agents (including its attorneys), with unscrupulous judicial, law enforcement, governmental and legal entities in their VENDETTA- TARGETED AL-HAKIM PERSECUTION, “MUSLIM BAN” by ”FIXING CASES” in Furtherance of their Corruption Agenda, IS PURE RETALIATION, with an aggressive campaign of calumny deceit, encouraged opposing parties to do all that they can to cause the ruin of al-Hakim, his family, their businesses, their business, real and personal property, his community and the clients they serve. Their tactics are more extreme than muckraking or character assassination, wherein the court and opposing parties fabricate and gathered negative, embarrassing or compromising information about al-Hakim, publish and disperse that information as widely as possible.
In the legal context, Brand, the judges and court administration, CSAA, their contractors and agents (including its attorneys), with unscrupulous judicial, law enforcement, governmental and legal entities are encouraged to use the process of litigation to “harass, deny and win using all tactics””The Law can be used very easily to harass and enough harassment on someone will simply push them to the thin edge, well knowing that he is not privileged, will generally be sufficient to cause their professional if not physical death, possible to annihilate him by destroying his credibility and moral character in all contexts leaving him a social and legal “pariah” in society incapable of being associated with or represented, and utterly ruin him.
One of the many things they did to al-Hakim was to offer compensation to bribe members of his family in an effort to take his real, personal and business property from him and to cause him great pain and suffering in hopes that he would perish. Ultimately, the court and CSAA proceeded to bludgeon Mr. al-Hakim with over-burdensome litigation tactics, as well as communicating with and intimidating his partners into abandoning him, leaving al-Hakim standing alone.
The court and CSAA intimidated, coerced, bribed, and otherwise elicited perjurious, slanderous, libelous and false statements from various people about al-Hakim and implied prurient activities. What al-Hakim did not know at that time, however, was the fact that agents, informants, and contractors acted for and on behalf of Brand, the judges and court administration, CSAA, their contractors and agents (including its attorneys), with unscrupulous judicial, law enforcement, governmental and legal entities by unethical and criminal means, instigated the acts, which gave, rise to the fraudulent, corrupt orders in underlying cases.
In doing so, Brand, the judges and court administration, CSAA, their contractors and agents (including its attorneys), with unscrupulous judicial, law enforcement, governmental and legal entities actions precluded Mr. al-Hakim from ever having a fair opportunity in any of his cases, and makes it explicitly clear that he is anything but a vexatious litigant in that the unanswered challenges and orders replete with perjurious, incriminating statements were not only false but obtained through criminal conduct. In short the court instigated and committed criminal acts with these entire “illegal proceedings” solely for the purpose of the unscrupulous judicial, law enforcement, governmental and legal entities illegally utilizing the full force and resources of the government in a covert criminal undercover sting operation by fostering, fabricating and manipulating any filing, pleading, argument, facts, truth, faxes, emails, phone calls, voicemail messages, letters, hearings, request, reservation numbers, motion practice, motion titles, ex-parte applications, hearings, parties, appearances, continuances, schedules, proceedings, register of actions, Court Domainweb, statements, evidence, testimony, documents, word, inference, vague reference, or gesture that they can remotely interpret as evidence of any remote action they seek to advocate to incriminate, charge, try, convict, incarcerate and eliminate al-Hakim, that DESTROYED his legitimate suits and then sought to have Mr. al-Hakim declared a vexatious litigant for seeking relief based on those criminal and civil violations of the law! (see VENDETTA- TARGETED AL-HAKIM “CAMPAIGN OF CALUMNY DECEIT”)