31 July 2014
Thonas Wong Jessica Rivas
Chief Investigator Associate County Counsel
City of Los Angeles General Litigation Division
City Hall East 648 Kenneth Hahn Hall
200 N. Main Street 500 W. Temple Street
Room 800 Los Angeles, California 90012
Los Angeles, CA 90012
Executive Offices of the Board of Supervisors
Room 383 Hall of Administration
500 West Temple Street
Los Angeles, California 90012
Re: City of Los Angeles Claim No. C15-0063
County of Los Angeles Claim No. 14-1115711*001
Thomas Wong, Jessica Rivas, and Los Angeles County Board of Supervisors,
Thank you for your letters dated July 8, 2014 (LA County), July 21, 2014 (LA County), and July 25, 2014 (City of Los Angeles).
There seems to be some confusion with respect to the various dates and time frames addressed in my original claims. I would like to reiterate the following: These claims arise from a prolonged and sustained course of conduct that involves both the City and County of Los Angeles City.
The course of conduct culminated with my false arrest and imprisonment on January 22, 2014 (Case No. 2CA0459) and LA Superior Court’s refusal to vacate a fraudulently obtained default judgment on January 17, 2014 (Case No. BC338322).
This course of conduct also relates to the fraudulent registration of a foreign restraining order with Los Angeles Superior Court (Case No. BC033717). The City and County of Los Angeles failed to verify the nature of the foreign order. It is not a domestic violence order and I received written confirmation of this fact from the Boulder Combined Court on April 10, 2014.
On June 17, 2014, after diligently pursuing the matter for nearly two years, I finally located the Court Reporter from the March 23, 2012 bail hearing (Case No. 2CA0459). I and others have repeatedly been advised, for a variety of reasons, that this transcript was unavailable. The Court Reporter is currently on vacation and will provide me with a transcript of that hearing when she returns. That transcript should successfully prove that Leonard Cohen testified (accurately, I might note) that we were in a purely business relationship and I never stole from him. His perjury with respect to the “dating relationship” was addressed during my 2012 trial in connection with the violation of the domestic violence order. When confronted, Leonard Cohen admitted changing his testimony from one hearing to the next. He was not prosecuted for perjury and DCA Streeter’s attempt to rehabilitate him was farcical.
The governments of the City and County of Los Angeles have simply assigned me a “brief intimate dating relationship” with Leonard Cohen. The fraudulently registered foreign order remains in full force and effect. That order prevents me from requesting information I require to file and/or amend federal and state tax returns and payment for work I’ve done and assets I own. Additional problems have arisen due to the fact that Internal Revenue Service views me as a partner on entities LA Superior Court has concluded is the sole property of Leonard Cohen.
The California Tort Claims Act mandates that all claims for money or damages against a public entity must be presented in writing to the entity prior to filing suit. My claims were presented in writing and were filed in a timely manner. Both the City and County of Los Angeles have acknowledged receipt of my tort claims. Federal civil rights violation claims are not subject to California’s tort claim requirements because such would violate the supremacy clause of the U.S. Constitution. Williams v. Horvath, 16 Cal.3d 834, 842 (1976).
Pursuant to government codes and regulations, the claims must be in writing and signed by the claimant. The claim must contain: information to be a sufficient claim; claimant’s name and mailing address; date, place, and circumstances of the claim; description of the injury, damage, or loss for which recovery is sought; name of any public employees causing the loss if known and an indication as to whether the claim would be made in limited jurisdiction court or not. My original claims satisfied these elements. The descriptions need not provide evidentiary detail and I have outlined the prolonged and sustained course of conduct in relatively great detail. My original claims were detailed enough to allow the City and County of Los Angeles to investigate and consider them. Furthermore, I am available to answer any questions with respect to complexities that may appear “vague.” It is my personal opinion that neither the City nor County of Los Angeles have provided an adequate explanation for the denial or insufficiency of my claims. The City and County of Los Angeles have also not explained precisely what dates they believe do not fall within the legal claim periods.
I look forward to your response.
Very truly yours,
cc: IRS, FBI, DOJ, Treasury, FTB, and Dennis Riordan, Esquire