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March 5, 2010
Please provide reasonable explanations for alleged criminalities by Bank of America Corporation, the former
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Countrywide Financial Corporation, Bryan Cave, LLP, and Attorney David Pasternak - under the guise of court
actions in Samaan v Zernik (SC087400) at the Superior Court of California, County of Los Angeles.
1) The former Countrywide Financial Corporation (CFC) and its Legal Department, headed by
Sandor Samuels (today - Associate General Counsel, Bank of America Corporation) engaged in
various alleged criminalities on Dr Joseph Zernik, on the US Government, and on CFC
stockholders:
(a) Through the false and deliberately misleading underwriting of Uniform Residential Loan Applications (1003)
of Nivie Samaan, which were opined as fraud by fraud experts;
(b) Through large scale fraud on the US government by routine false underwriting and funding of extremely
unworthy Uniform Residential Loan Applications (1003) as government-backed loans, which eventually led to the
so called "sub-prime crisis";
(c) Through the repeated production, in response to legal subpoenas, of hundreds of false and deliberately
misleading banking records, as opined by fraud expert;
(d) Through false appearances of Bryan Cave, LLP, not counsel of record in the caption of Samaan v Zernik, who
repeatedly filed false and deliberately misleading, malicious motions under the caption referenced above, using a
false and deliberately misleading party designation of "Non Party";
(e) Through false appearances of Bryan Cave, LLP, not counsel of record in the caption of Samaan v Zernik, who
filed false and deliberately misleading, malicious papers on behalf of Sandor Samuels under the caption referenced
above, using a false and deliberately misleading party designation of "Interested Person";
(f) Through alleged engagement in monetary transactions in property derived from specified unlawful activity, in
collection of payments from Attorney David Pasternak, purported as sanctions..
2) Senior Management at Bank of America Corporation (BAC), including but not limited to Brian
Moynihan, engaged in alleged criminalities against Dr Joseph Zernik, against the US
Government, and against BAC Stockholders :
(a) Through refusal to take corrective actions regarding alleged criminalities perpetrated prior to July 1, 2008 by
the former CFC. after the July 1, 2008 take-over of CFC and to this date;
(b) Through permitting resumption of alleged criminalities through false appearances and false court actions by
Bryan Cave, LLP, under the caption referenced above, starting December 11, 2008;
(c) Through refusal to allow the BAC Audit Committee to review complaints filed with the Audit Committee
pursuant to Sarbanes Oxley Act (2002);
(d) Through failure to report to the BAC Audit fraud by management pursuant to Sarbanes Oxley Act(2002);
(e) Through false certifications in period reports to SEC and to stockholders pursuant to Sarbanes Oxley
Act (2002)
(f) Through alleged engagement monetary transactions in property derived from specified unlawful activity, in
collection of payments from Attorney David Pasternak, purported as sanctions.
(g) Through false and deliberately misleading response to complaint filed by Dr Joseph Zernik with Office of the
Comptroller of the Currency.
3) Bryan Cave, LLP attorneys, including but not limited to Jenna Moldawsky, John Amberg, Jeff
Modisett, engaged in alleged criminalities against Dr Joseph Zernik and against the people of
California and the United States:
(a) Through repeated false appearances and false representations under the caption referenced above;
(b) Through false and deliberately misleading conduct in court - alleged malicious court actions to obstruct and
pervert justice and facilitate fraud and extortion against Dr Joseph Zernik;
(c) Through alleged monetary transactions in property derived from specified unlawful activity with Attorney
David Pasternak.
4) David Pasternak and Pasternak, Pasternak, Patton, engaged in alleged criminalities against Dr
Joseph Zernik and against the People of California and the United States:
(a) Through false and deliberately misleading court appearances under the caption referenced above, designating
himself as "Receiver", while he had no valid and effectual appointment order as receiver;
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(b) Through affecting unlawful but credible threat of force, to drive Dr Zernik out of his own residence, to forcibly
enter the residence, to engage in fraudulent conveyance of title - as opined by fraud expert.
(c) Trough alleged monetary transactions in property derived from specified unlawful activity