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RENADA NADINE MARCH
7 Bluebird Lane
Aliso Viejo, California 92656
Tel: 949-742-0436; E-mail: renadajewel@gmail.com
IN THE UNITED STATES DISTRICT COURT
FOR THE CENTRAL DISTRICT OF CALIFORNIA
SOUTHERN (ORANGE COUNTY) DIVISION
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MEGLODON FINANCIAL, LLC
PLAINTIFF,
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versus
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RENADA NADINE MARCH,
Defendant.
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_______________________________/
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CIVIL ACTION NUMBER:
SA CV09-1355 GW (SS)
Removed from Orange County
30-2009-00312382-CL-UD
Superior Court of California
VERIFIED RESPONSE TO ORDER TO SHOW CAUSE and
REQUEST FOR FULL EVIDENTIARY (Preliminary Injunction) HEARING
re: DOMBROWSKI v. PFISTER FACTORS, 380 U.S. 479 (1965)
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The Court, in its November 24, 2009, Order to Show Cause,
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appears to ignore the specifically asserted statutory basis for Defendant
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Renada March’s removal to this court: 28 U.S.C. § 1443. Civil rights
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removal differs from Federal Question or Diversity jurisdiction removal
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precisely because there is NO requirement that the diversity
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jurisdiction be apparent or the federal question be presented on the
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face of the complaint. The purpose of Federal Civil Rights Removal is
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to act as an injunction against civil rights violations in State Courts.
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Under civil rights removal, as a practical matter, the question can
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only be raised in the pleadings, by way of a defense asserted in an
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answer or raised in the petition for removal. The reason for this is
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simple: where Plaintiffs seek to maintain their advantage in state court
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which arises on account of inherent inequities or injustices either in
Response to November 24, 2009 Order to Show Cause Regarding Defendant’s
Civil Rights Removal of Unlawful Detainer Action under 28 U.S.C. §1443(1)
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State Law or in the customs, practices, and procedures utilized in the
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state Court, the Plaintiffs would ordinarily be the last ones to admit it.
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This is in fact the test of whether Federal Judicial injunction
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against state proceedings by means of civil rights removal is
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permissible: As established in Younger v. Harris, 401 U.S. 37; 91 S.
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Ct. 746; 27 L.Ed.2d 669 (1971), a removing party (or party seeking a
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Federal Injunction to stop state court proceedings) must allege and
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prove, as a matter of fact and by a propondenderance of the evidence,
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special circumstances in the State Court system (such as a tidal waive of
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uncontested non-judicial foreclosures followed by another tidal waive
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of essentially uncontestable quasi-judicial evictions, where the judicial
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proceedings are so devoid of legal defenses and equitable procedures as
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to be nugatory) which show that there is no chance that a Defendant
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will receive equal protection or due process of laws in the relevant state
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courts.
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Defendant RENADA NADINE MARCH here alleges that the
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California Superior Courts in Orange County are no more likely, in
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2009, to afford equal protection or due process of laws than the Courts
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of Louisiana were in the early 1960s heyday of the Civil Rights crisis to
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afford equal protection and due process of law to the attorneys for the
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ACLU prosecuted under the Louisiana state “un-American activities”
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and relic McCarthy-era anti-communist statutes, together with state
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judicial and prosecutorial customs, practices and policies, which were
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at issue in Dombrowski v. Pfister, 380 U.S. 479; 85 S.Ct. 1116; 14
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L.Ed.2d 22 (1965).
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Response to November 24, 2009 Order to Show Cause Regarding Defendant’s
Civil Rights Removal of Unlawful Detainer Action under 28 U.S.C. §1443(1)
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So, Civil Rights Removal under 28 U.S.C. §1443(1) in particular is
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whether there is equal justice under the law of the state from the
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Defendants’ standpoint. There is nothing in 28 U.S.C. §1443, which
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suggests that a forcible detainer case must show, on its face, a
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substantial federal question in order to be removable. Evidence or
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proof relating to the denial of “equal civil rights” is normally
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circumstantial or provable only by non-party or third-party witnesses.
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28 U.S.C. §1443 states in full:
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Any of the following civil actions or criminal prosecutions,
commenced in a State court may be removed by the defendant to
the district court of the United States for the district and division
embracing the place wherein it is pending:
(1) Against any person who is denied or cannot enforce in
the courts of such State a right under any law providing for the
equal civil rights of citizens of the United States, or of all persons
within the jurisdiction thereof;
(2) For any act under color of authority derived from any
law providing for equal rights, or for refusing to do any act on the
ground that it would be inconsistent with such law.
In addition, 28 U.S.C. §1443 has UNIQUE status among all removals,
totally distinct and different from removals based on Federal question or
diversity jurisdiction, in that any order of remand is immediately
appealable in this case. Civil Rights injunctions against Federal
proceedings are expressly authorized under 42 U.S.C. §§1983, 1988(a).
Mitchum v. Foster, 407 U.S. 225; 92 S. Ct. 2151; 32 L. Ed. 2d 705 (1972).
Although the Supreme Court has not recently addressed the question of
Federal Injunctions against State Court proceedings as a remedy for systemic
and systematic violations of civil rights, the “extraordinary pro-injunction
trilogy” of Dombrowski, Younger, Mitchum has never been overruled
or even (directly) questioned. In fact, Mitchum v. Foster was affirmed by
Response to November 24, 2009 Order to Show Cause Regarding Defendant’s
Civil Rights Removal of Unlawful Detainer Action under 28 U.S.C. §1443(1)
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Pennzoil v. Texaco, which clarified than in truly extraordinary
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circumstances, Federal intervention may be proper. 481 U.S. 1. (1987).
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NEED AND PROPRIETY OF EVIDENTIARY HEARING
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Dombrowski v. Pfister, Younger v. Harris, and Mitchum v.
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Foster together constitute one continuous jurisprudential statement
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regarding the boundaries of Federal Judicial Power to enjoin state court
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actions, even though for various political reasons, Younger v. Harris is the
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case most often cited, even though it was the only one of the three cases in
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which a Federal Judicial Injunction against state court action was actually
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denied. What these cases make very clear is that the U.S. Court’s decision to
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intervene or not is heavily dependent upon the Defendants’ allegation and
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proof of facts sufficient to show that the parties prosecuting her (in this case
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Silverstein) have such an unfair advantage in state court that Defendant has
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no chance to present legal defenses or seek to unravel the improper chain of
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title which underlies the Plaintiff’s claim in this case.
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At the very least, this Court should allow Renada Nadine March a full-
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blown evidentiary hearing on the existence of “special circumstances” and
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extraordinary factors held in Dombrowski v. Pfister (as affirmed in both
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Younger v. Harris and Mitchum v. Foster) prior to considering entry of
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any order of remand. Defendant’s witnesses must be allowed to present their
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stories to this Federal Court, to offer their evidence that the abuses in the
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California Superior Courts in and for Orange County, not even especially in
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the present case, but absolutely TYPICALLY in the present case, are so
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routine and rampant as to justify Federal judicial intervention.
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Defendant can produce corroborating witnesses who can testify to and
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offer other evidence of abuses including favoritism and disregard of the most
Response to November 24, 2009 Order to Show Cause Regarding Defendant’s
Civil Rights Removal of Unlawful Detainer Action under 28 U.S.C. §1443(1)
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elementary rules of fairness and equity in the Superior Court system of
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Orange County, especially where Steven D. Silverstein is involved.
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Are forcible detainer proceedings in which Defendants have no
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reasonable chance of success so sacred in the “Brave New World” of 21st
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century America that they cannot be stopped, even for a deep constitutional
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challenge to their legitimacy as offensive to the most fundamental rights
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established in the Constitution at the beginning of the American Federal
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Union under this Constitution?
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Removing Defendant Renada Nadine March, after having been served,
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took and attended an Orange County Legal Aid Clinic at which she was
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advised and instructed that pursuant to the customs, practices, and policies
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of the State of California, defendants in Unlawful Detainer actions have no
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effective defense or counterclaims whatsoever. In other words, it is either the
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law or customary and political practice in California that all evictions will be
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completed, regardless of the existence or availability of valid legal objections.
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The Orange County Legal Aid Clinic is owned and managed by Orange
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County Lawyers, “officers of the Court” who are capable of articulating and
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many of whom actually formulate legislation, interpret common law
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precedent, and implement customs, practices and policies of the State of
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California, so that their advice constitutes action taken under color of law or
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else customs, practices, and policies having the force and effect of law even if
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otherwise illegal, unconstitutional, or otherwise unconscionable.
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The combination of circumstances put Renada Nadine March on notice
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that she was “be denied [and] cannot enforce in the courts of [the Superior
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Court of Orange County in the] State [of California any of his] right[s] under
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any [and all] law[s] providing for the equal civil rights of citizens of the
Response to November 24, 2009 Order to Show Cause Regarding Defendant’s
Civil Rights Removal of Unlawful Detainer Action under 28 U.S.C. §1443(1)
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United States, or of all persons within the jurisdiction thereof.” 28 U.S.C.
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§1443(1); 42 U.S.C. §§1981, 1982.
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Furthermore, Renada Nadine March alleges and will show that women,
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and in particular women over the age of 40, are subject to targeted
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discrimination by the attorneys (“officers of the court”) and Judges of the
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Superior Courts of California.
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Furthermore, Steven D. Silverstein and certain officers of Orange
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County Superior Court system appear to have formulated a special, local
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series of customs, practices, and policies having the force of law which create
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or define an especially oppressed class of eviction suit defendants who are
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denied both due process of law and equal protection, for the simple reason
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that respondents always lose in Orange County Unlawful detainer
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proceedings as a matter of statutory law, custom, practice, and policy
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implemented by Steven D. Silverstein, in plain violation of 42 U.S.C. §1981,
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which is a statute providing for equal protection under the law.
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The inquiry into whether civil rights removal or Federal Injunction
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against state proceedings due to ongoing and systematic violations of
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constitutional law is fact intensive, and only a full-blown evidentiary hearing
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with live witnesses, on the order of a hearing for Preliminary Injunction, will
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be sufficient to establish Defendant’s right to removal in this case. Although
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the hearing is fact intensive, certain key legal issues must be framed.
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LIMITED DISCOVERY NEEDED PRIOR TO HEARING re:
Possible Diversity Grounds for Removal Jurisdiction
Defendant Renada Nadine March moves and requests that this
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Court allow limited discovery, in the form of depositions duces tecum
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submitted on less than 30 days notice, to permit exploration of certain factual
Response to November 24, 2009 Order to Show Cause Regarding Defendant’s
Civil Rights Removal of Unlawful Detainer Action under 28 U.S.C. §1443(1)
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issues relating to removal. First among these is the citizenship of the
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Plaintiff, Meglodon Financial, LLC, which may be a business incorporated in
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Washington State, in that, when Defendant searched the world wide web for
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any reference to this entity, she could find only:
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“Megalodon, LLC”
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11 E 1ST AVE
SELAH, WA 98942-1442 Phone: (509) 697-3265
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Although the web entry discovered suggest that this is a real estate
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agency and management company, the association with Steven D. Silverstein
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is unclear. Two individuals, Sean Frankhouse (“CFO”) and Maribel
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Rodriguez (“REO and Foreclosure specialist”) are listed on the web as
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working for a “Meglodon Financial” in Orange County, but no address could
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be discovered for this “Limited Liability Corporation.” It is therefore possible
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that discovery would supply an alternative grounds for Federal Jurisdiction
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and hence for removal, namely 28 U.S.C. §1332.
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The property in question is valued at almost half a million dollars, and
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so there is no doubt that the “amount in question” requirement for Federal
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Diversity Jurisdiction could be met by the removing defendant in this case.
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“Meglodon” or “Megalodon” are both names for extinct great white
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sharks (Charcharon Megalodon) from the Oligocene Period known from
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the fossil record to be “Superpredators” measuring around 20 meters in
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length, the greatest and most powerful fish ever to live. Defendant noted in
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her one appearance before the Superior Court that Steven D. Silverstein wore
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a distinctive tie bearing great white shark designs and decorations to court.
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SPECIFIC STATUTORY LANGUAGE IGNORED
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To begin with the Court seems to ignore the statutory language on
which this removal was based, and to ignore it entirely. Within the meaning
Response to November 24, 2009 Order to Show Cause Regarding Defendant’s
Civil Rights Removal of Unlawful Detainer Action under 28 U.S.C. §1443(1)
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of Rule 11, Renada Nadine March submits that it is not frivolous to contend
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that the statutory language of 28 U.S.C. §§1443(1) and 1446 should be given
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full force and effect, and not construed so restrictively as this Court seems
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inclined to do. The Court’s Order to Show Cause stating “Defendant asserts
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that the complaint violates certain federal civil rights statutes” TOTALLY,
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ABSOLUTELY, and COMPLETELY misses the point of what removal under
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28 U.S.C. §1443 is designed to do: the Civil Rights Removal Statute is
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designed to permit an escape from an unfavorable and unjust FORUM.
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There is simply no other way to make sense of the statute and related
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language in 28 U.S.C. §§1446-1447. CIVIL RIGHTS REMOVAL IS A
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SPECIAL SPECIES OF REMOVAL, more closely related to the United States’
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Supreme Court Holdings in Dombrowski v. Pfister, Younger v.
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Harris, and Mitchum v. Foster (all cited above) than to the Franchise
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Tax Board v. Construction Laborers and Caterpiller v. Williams
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cases cited by the Court in its Order to Show Cause.
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Defendant RENADA MARCH admits that it appears from a review of
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the cases that Civil Rights Removal is grossly underused and
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underappreciated as a safeguard against oppressive state court judicial
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regimes largely controlled by special interests (such as mortgage foreclosure
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servicers, purchasers of properties seized by illegal foreclosures, or their
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attorneys such as Silverstein). The fact that 28 U.S.C. §1443 is underused
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and underappreciated, however, does not mean that this statute, and the
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necessity of invoking the Federal Power of Injunction against state judicial
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proceedings, which power was expressly utilized and affirmed in
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Dombrowski v. Pfister and Mitchum v. Foster, in particular
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Response to November 24, 2009 Order to Show Cause Regarding Defendant’s
Civil Rights Removal of Unlawful Detainer Action under 28 U.S.C. §1443(1)
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Congress’ general removal procedure statute plainly recognizes that
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events and documents OTHER than the citizenship of parties or allegations
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of a complaint may trigger the statutory grounds for removal:
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If the case stated by the initial pleading is not removable, a notice
of removal may be filed within thirty days after receipt by the
defendant, through service or otherwise, of a copy of an amended
pleading, motion, order or other paper from which it may first be
ascertained that the case is one which is or has become
removable, except that a case may not be removed on the basis of
jurisdiction conferred by section 1332 of this title [28 U.S.C.]
more than 1 year after commencement of the action.
28 U.S.C. §1446(b).
IF the phrase “manifest error” means anything, this phrase applies
when the Court applies the wrong statute to a case, as the Court has done in
its November 24, 2009, Order to Show Cause. Civil Rights Removal under
28 U.S.C. §1443(1) is plainly and clearly a Congressionally crafted exception
to the “well-pleaded complaint” rule because it is expressly worded as a
motion to be filed based entirely on the “defendant’s” point of view, especially
regarding the Defendant’s need for protection from a state judicial system in
which s/he has no chance of prevailing in his or her defense. This is the only
possible, rational interpretation of Congressional intent in enacting 28 U.S.C.
§1443. Any other construction transforms the entire statute in a bad,
nugatory parody of Congressional intent in carefully crafting such a statute,
and would further render the special provisions of 28 U.S.C §1447 relating to
the special power to appeal any order remanding cases brought into Federal
Courts by way of civil rights removals utterly meaningless.
Renada Nadine March has quite simply NOT attempted to remove
Plaintiff’s Complaint for Unlawful Detainer to Federal Court based upon a
Federal question, so there is no requirement that a substantial federal
Response to November 24, 2009 Order to Show Cause Regarding Defendant’s
Civil Rights Removal of Unlawful Detainer Action under 28 U.S.C. §1443(1)
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question must be presented on the face of the complaint. Nor has Renada
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Nadine March sought to raise a federal question by way of a defense asserted
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in her answer nor in any counterclaim, although she asserts that she is
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plainly entitled to raise such questions in this Court, and that an injunction
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(such as that provided by Civil Rights Removal under 28 U.S.C.§1443) is
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absolutely necessary to preserve the jurisdiction of this court to adjudicate
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the matters relating to the State Court’s implementations of customs,
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practices, and policies having the force of law which as a customary, practical,
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and political matter have, do, and will continue to constitute an outrageous
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denial of “equal civil rights”, specifically in the context of judicial evictions
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following non-judicial foreclosures.
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It is axiomatic that Federal Courts are courts of limited jurisdiction,
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but it is equally axiomatic that courts should apply the rule of
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statutory construction that “In construing a statute we are obliged
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to give effect, if possible, to every word Congress used.” See e.g.,
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Reiter v. Sonotone, 442 U.S. 330, 340, 99 S.Ct. 2326, 2331 (1979). If, for
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example, previous jurisprudence on 28 U.S.C. §1443(1) has limited this
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powerful statute to cases involving racial discrimination, the Court should
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look to the language of the statute and give full force and effect to every word
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of the congressional enactment, keeping in mind that over the thirty one
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years (since Regents of Univ. of Cal. v. Bakke, 438 U.S. 265, 57 L. Ed. 2d 750,
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98 S. Ct. 2733 [1978]) the United States Supreme Court has radically
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retreated from the use of racial classifications to limit the applications of civil
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rights laws. See, e.g., Grutter v. Bollinger, 539 U.S. 306; 123 S. Ct. 2325; 156
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L. Ed. 2d 304 (2003).
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Response to November 24, 2009 Order to Show Cause Regarding Defendant’s
Civil Rights Removal of Unlawful Detainer Action under 28 U.S.C. §1443(1)
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Within the meaning of the First and Ninth Amendments, Renada
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Nadine March submits that she has the right to petition for redress of
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grievances including the right to prevent or interfere with the orderly
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prosecution of state forcible detainer proceedings in light of her allegations
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and tender of proof that the California Superior Courts in Orange County,
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especially in cases prosecuted by Steven D. Silverstein, are nothing but a
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mass production conveyor belt of evictions, and that this Court should not
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deny Defendant’s right to assert and contend that the California Superior
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Courts in and for Orange County are so illegally and unconstitutionally
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administered as to constitute a travesty of justice, enough to justify both civil
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rights removal under 28 U.S.C. §1443 and a Federal Injunction pursuant to
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Dombrowski v. Pfister, 380 U.S. 479, 85 S.Ct. 1116, 14 L.Ed.2d 22 (1965).
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Removing Respondent (Defendant) Renada Nadine March asks that
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this Court allow her a full evidentiary hearing on whether special
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circumstances exist in the Superior Courts of Orange County which offend all
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constitutional notions of the right to petition for redress of grievances, no
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takings of life, liberty, or property without due process of law, and equal
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protection under the laws. Renada Nadine March further submits that a
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careful review of the legislative history of 28 U.S.C. §1443 together with 28
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U.S.C. §1447(d) will show that Congress intended to afford a very special
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status to civil rights removal, to enable defendants to avoid oppressive state
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courts regardless of the subject matter of the complaint (even removals of
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criminal proceedings are expressly permitted, for example, without any
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“federal question” requirement even being possible in relation to the removal
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of criminal prosecutions).
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Response to November 24, 2009 Order to Show Cause Regarding Defendant’s
Civil Rights Removal of Unlawful Detainer Action under 28 U.S.C. §1443(1)
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In addition to allowing an evidentiary hearing on whether an injunction
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against state court proceedings is proper, this Court should allow Renada
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Nadine March to amend her answer and file a counterclaim formally
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consistent with the Federal Rules of Civil Procedure.
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Removal is proper within the express statutory language of 28 U.S.C.
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§1443(1) because Renada Nadine March is a member of one or more discrete
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and insular groups (forcible detainer defendants in eviction suits filed after
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improperly instituted and executed non-judicial foreclosure proceedings,
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single women over the age of 40 on another) which lack political power, and
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which groups are constituted as second class citizens by the customs,
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practices, and policies prevalent in Orange County implementing the
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California Forcible Detainer statutes.
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AT LEAST ONE MONTH IS NEEDED TO PREPARE FOR
PRELIMINARY INJUNCTION HEARING ON CIVIL RIGHTS
REMOVAL PURSUANT TO DOMBROWSKI v. PFISTER
WHEREFORE, Removing Respondent Renada Nadine March prays
that this Court will extend its order to show cause for at least 31 days to allow
full briefing of a full-blown evidentiary hearing application, treating this
Notice of Removal as an Application for Preliminary Injunction under and
pursuant to Fed. R. Civ. Pro., Rule 65. Such an evidentiary motion should be
allowed to enable Defendant and her witnesses to describe the abuses of the
Superior Courts of Orange County and the conduct judges and attorneys
including but not limited to Steven D. Silverstein in forcible detainer
proceedings.
The Court should find and rule that such a motion and the holding of
such an evidentiary hearing are uniquely proper in a case removed pursuant
Response to November 24, 2009 Order to Show Cause Regarding Defendant’s
Civil Rights Removal of Unlawful Detainer Action under 28 U.S.C. §1443(1)
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to 28 U.S.C. §1443 as provided by 28 U.S.C. §1447(d) ascribes a very special
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and privileged status to Civil Rights Removal:
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(d) An order remanding a case to the State court from
which it was removed is not reviewable on appeal or
otherwise, except that an order remanding a case to the
State court from which it was removed pursuant to
section 1443 of this title [28 USCS § 1443] shall be
reviewable by appeal or otherwise.
As has been argued hereinabove and throughout this Response, 28
U.S.C. §1443 has UNIQUE status among all removals, totally distinct and
different from removals based on Federal question or diversity jurisdiction,
in that an order of remand is immediately appealable in this case.
WHEREFORE THEN, additionally, Removing Respondent (Defendant)
Renada Nadine March prays for a 31 day extension of the time to fully and
completely brief and prepare for an evidentiary hearing, on the model of a
full evidentiary hearing on Application for Preliminary Injunction,
concerning this Court’s Tuesday, November 24, 2009, Order to Show Cause
why this case should not be remanded.
Respectfully submitted,
Monday, November 30, 2009
By:__________________________
RENADA NADINE MARCH,
Pro se/in propia persona
7 Bluebird Lane
Aliso Viejo, California 92656
Telephone: 949-742-0436
E-mail:
renadajewel@gmail.com
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Response to November 24, 2009 Order to Show Cause Regarding Defendant’s
Civil Rights Removal of Unlawful Detainer Action under 28 U.S.C. §1443(1)
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VERIFICATION PURSUANT TO RULE 65(b)
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Removing Defendant Renada Nadine March appeared in person before
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me on this Monday the 30th day of November, 2009, to depose herself and
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sign the above and foregoing document in my presence, and thereby to
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declare and verify the truth of all statements of fact and averments of
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information and belief in the above-and-foregoing Response to the Court’s
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Order to Show Cause issued and filed on Tuesday, November 24, 2009.
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As a Notary Public in and for Orange County, I am an officer authorized
by California statutory law to administer and receive oaths.
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__________________________
Notary Public, Orange County
State of California
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Printed Name of Notary:_____________________
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My Commission Expires:_____________________
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Response to November 24, 2009 Order to Show Cause Regarding Defendant’s
Civil Rights Removal of Unlawful Detainer Action under 28 U.S.C. §1443(1)
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CERTIFICATE OF SERVICE
I the undersigned Defendant do hereby certify that I served a
true and correct, original signed copy of the above-and-foregoing,
Verified Response to Order to Show Cause on:
Steven D. Silverstein, Attorney-at-Law
Silverstein Eviction Law
14351 Redhill Ave., Suite #G
Tustin, CA 92780
Respectfully Submitted and signed Monday, November 30, 2009
Monday, November 30, 2009
By:______________________________
RENADA NADINE MARCH,
Removing pro se/in pro per
7 Bluebird Lane
Aliso Viejo, California 92656
Telephone: 949-742-0436
E-mail: renadajewel@gmail.com
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Response to November 24, 2009 Order to Show Cause Regarding Defendant’s
Civil Rights Removal of Unlawful Detainer Action under 28 U.S.C. §1443(1)
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