SEARGENT HASHIM MWAMBA BOMANI vs. MAYOR ANTONIO R. VILLARAIGOS AND MICHAEL D. ANTONOVICH AND GLORIA MOLINA AND DON KNABE AND MARK RIDLEY-THOMAS AND ZEV YAROSLAVSKY

SARGEANT HASHIM MWAMBA BOMANI, IN PRO PER

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF LOS ANGELES

HASHIM BOMANI, an individual,   

Plaintiff,  

vs.

NO GOOD MAYOR

NO GOOD BITCH ASS LA MAYOR AND WILL BE A NO GOOD BITCH ASS GOVERNOR

LOS ANGELES CITY MAYOR:  ANTONIO R. VILLARAIGOSA,

   AND

THE LOS ANGELES COUNTY BOARD OF SUPERVISORS:

  MICHAEL D. ANTONOVICH,

GLORIA MOLINA, DON KNABE,

MARK RIDLEY-THOMAS,

ZEV YAROSLAVSKY,

Defendants.

COMPLAINT FOR DAMAGES, DEMAND FOR JURY TRIAL, DEFENDANTS ARE HEREBY CHARGED WITH THE FOLLOWNI CRIMES:

1. FRAUD IN VIOLATION OF CIVIL CODE SECTION 3294(3)

2. EXTORTION IN VIOLATION OF CALIFORNIA PENAL CODE 518

 3. CONSPERACY IN VIOLATION OF PENAL CODE SECTION(S) 182-185

4. CHILD ENDANGERMENT IN VIOLATION OF CALIFORNIA PENAL CODE SECTION 11164-11174.3: ARTICLE 2.5 CHILD ABUSE AND NEGLECT REPORTING ACT

 

JURY TRIAL DEMANDED

Amount Demanded Exceeds $25,000.00

Amount Demanded Exceeds $25,000.00 (Government Code § 72055.) Plaintiff HASHIM BOMANI (“Plaintiff”) complains against Defendants LOS ANGELES CITY MAYOR ANTONIO VILLARAIGOSA and LOS ANGELES COUNTY BOARD OF SUPERVISORS: MICHAEL D. ANTONOVICH, GLORIA MOLINA, DON KNABE, MARK RIDLEY-THOMAS, ZEV YAROSLAVSKY, inclusive, and each of them and demands a trial by jury of all issues and for causes of illegal action alleges:

PARTIES AND JURISDICTION

This Court is the proper court and this action is properly filed in the County of Los Angeles and in this judicial district because Defendants do business in the County of Los Angeles and because Defendants’ obligations and liability arise therein. Plaintiff HASHIM BOMANI is an individual who, at all times relevant herein, resided in the County of Los Angeles, State of California. Plaintiff is informed and believes, and thereon alleges, that Defendants LOS ANGELES CITY MAYOR ANTONIO VILLARAIGOSA and LOS ANGELES COUNTY BOARD OF SUPERVISORS: MICHAEL D. ANTONOVICH, GLORIA MOLINA, DON KNABE, MARK RIDLEY-THOMAS, ZEV YAROSLAVSKY whose headquarters at all relevant times herein was located in the City of Los Angeles, County of Los Angeles, State of California.

 

Plaintiff is informed and believes, and thereon alleges, that Defendants LOS ANGELES CITY MAYOR ANTONIO VILLARAIGOSA and LOS ANGELES COUNTY BOARD OF SUPERVISORS: MICHAEL D. ANTONOVICH, GLORIA MOLINA, DON KNABE, MARK RIDLEY-THOMAS, ZEV YAROSLAVSKY which at all times relevant herein, did and continues to do business in the City of Los Angeles, County of Los Angeles, State of California.

 

Plaintiff is informed and believes, and thereon alleges, that Defendants LOS ANGELES CITY MAYOR ANTONIO VILLARAIGOSA and LOS ANGELES COUNTY BOARD OF SUPERVISORS: MICHAEL D. ANTONOVICH, GLORIA MOLINA, DON KNABE, MARK RIDLEY-THOMAS, ZEV YAROSLAVSKY are organized under the laws of the State of California, which at all times relevant herein, did and continues to do business in the City of Los Angeles, County of Los Angeles, State of California.

 

Plaintiff is informed and believes, and thereon alleges, Defendants LOS ANGELES CITY MAYOR ANTONIO VILLARAIGOSA and LOS ANGELES COUNTY BOARD OF SUPERVISORS: MICHAEL D. ANTONOVICH, GLORIA MOLINA, DON KNABE, MARK RIDLEY-THOMAS, ZEV YAROSLAVSKY are individual public officials who at all relevant times herein resided in the County of Los Angeles, State of California. Whenever in this Complaint reference is made to “Defendants,” such allegations shall be deemed to mean the acts of Defendants acting individually, jointly, and/or severally.

 

Plaintiff is informed and believes and thereon alleges that each and every Defendant business/city entity had an interrelation of operations, common management, centralized control of city relations, and common stake and over-sight, creating an integrated enterprise and/or governing body.  Plaintiff is informed and believes that Defendants had uniform employment practices and policies, and that Defendants shared fiscal, physical and human resources.  At all relevant times, Defendants, including those named herein as DOE Defendants, have operated, and currently operate, as City and/or Public Officials.  Though such Defendants have multiple public, entity, official and individual personalities, there is but one public entity and this public entity has been so handled that it should respond, as a whole and jointly but severally by each of its constituent parts, for the acts committed by Defendants.  Each public/government official, individual and entity has been, and is, merely an instrument and conduit for the others in the prosecution of The City of Los Angeles, The Los Angeles County Probation Department, The County of Los Angeles Child Support Services Department, and The Los Angeles County Department of Child and Family Services.

 

Plaintiff is informed and believes and thereon alleges that under a totality of the public relationship between the parties, Defendants, including the DOE Defendants, were at all times relevant herein the Public Officials and/or Governing Entities of The City of Los Angeles.  Plaintiff is informed and believes and thereon alleges that Defendants, including but not limited to the individuals named as Doe Defendants, had the authority to over-see, investigate, supervise, hire, train, fire, and/or discipline appointees and officials of The City of Los Angeles, The Los Angeles County Probation Department, The County of Los Angeles Child Support Services Department, and The Los Angeles County Department of Child and Family Services, and had discretion to set appointees and officials salary.

 

The true names and capacities, whether individual, corporate, associate, or otherwise, of Defendants sued herein are currently unknown to Plaintiff, who therefore sues Defendants by such fictitious and/or official names. Plaintiff sues any and all of Defendant’s connections with individual Defendant’s, referred to as corporations, limited liability companies, partnerships, or other city departments and/or business entities.  Plaintiff is informed and believes, and on this basis thereon alleges, that each of the Defendants designated herein are legally responsible both directly and indirectly for the events and happenings referred to herein and caused injury and damage proximately thereby to Plaintiff and Plaintiffs Children (Hashim Domenick Bomani, age 15 and Chelsea Olivia Brooke Bomani age 5) as hereinafter alleged.  Plaintiff will seek leave of the court to amend this Complaint to reflect the true names and capacities of the Defendants designated hereinafter as DOES when the same have been finally ascertained.

FACTS COMMON TO MORE THAN ONE CAUSE OF ACTION

Plaintiff began communicating with Defendants approximately (4) four years ago by exclaiming very noticeable discrepancies in City Departments that were under Defendants over-sight and/or supervisory jurisdiction. (EXHIBIT) Under The Los Angeles City Charter, Defendant, Mayor Antonio Villaraigosa is in direct violation of Administrative Code Division 3, Article 1 § 3.3: which states,  [It shall be the duty of the Mayor to be vigilant and active in the enforcement of the ordinances of the City; to exercise a constant supervision over the acts and conduct of all officers and employees; to receive and examine into all complaints made against them for violation or neglect of duty, and certify the same to the Council or proper board, and to secure cooperation between the various departments and offices of the City.] Moreover, Defendants have directly violated EXECUTIVE DIRECTIVE NO. 1 re-issued October 20, 2005 Ethics in Government: which states, [As public servants to the residents of Los Angeles, we must commit ourselves to a standard of conduct that maintains and enhances the public’s trust in our local government. To fulfill this mandate, our individual and collective decision making processes must be based upon the highest possible ethical standards.]

 

At all relevant times, Plaintiff communicated to Defendants that the Los Angeles County Child Support Services Department under the direction of Steven J. Golightly were engaging in noticeable fraud and corruption, by way of the utilization of dubious accounting schemes. Defendants possessed direct evidence, knowledge and awareness that The Los Angeles County Child Support Services Department were over-charging Plaintiffs child support obligation, and that both the Federal Guideline Calculation Result Summary and DissoMasters reflected serious omissions and miss-calculations. (EXHIBIT)

 

Defendants possessed direct evidence, knowledge and/or awareness that members employed by The Los Angeles County Probation Department were violating the public’s trust by blatantly disobeying court orders and withholding Plaintiffs children from Plaintiff. Moreover, Defendants possessed direct evidence, knowledge and/or awareness that members employed by the Los Angeles County Probation Department failed to comply with California Rule 14.9, and therefore, engaged in perjury by omitting assets and income on court documents. Defendants possessed direct evidence, knowledge and/or awareness that members employed by The Los Angeles County Probation Department engaged in coercion and/or deceit (EXHIBIT.)

 

At all relevant times, Defendants had direct evidence, knowledge and/or awareness that The Los Angeles County Child and Family Services under the direction of Ms. Patricia Ploahn failed to thoroughly investigate child abuse reports perpetrated upon Plaintiffs children by members employed by The Los Angeles County Probation Department. Defendants possessed direct evidence, knowledge and/or awareness that members employed by The Los Angeles County Probation Department have been in litigation for truancy related issues which reflect parenting deficits in members employed by The Los Angeles County Probation Department (EXHIBIT.)

 

Defendants possess direct evidence, knowledge and/or awareness that members employed by The Los Angeles County Probation Department have received special consideration and treatment by Defendants because of their veteran status and political ties to prominent political entities in Los Angeles County. Defendants are in direct violation of CALIFORNIA PENAL CODE § 182: which states, [(a) If two or more persons conspire: (1)To commit any crime.(2)Falsely and maliciously to indict another for any crime, or to procure another to be charged or arrested for any crime.(3)Falsely to move or maintain any suit, action, or proceeding.(4)To cheat and defraud any person of any property, by any means which are in themselves criminal, or to obtain money or property by false pretenses or by false promises with fraudulent intent not to perform those promises.(5)To commit any act injurious to the public health, to public morals, or to pervert or obstruct justice, or the due administration of the laws.(6)To commit any crime against the person of the President or Vice President of the United States, the Governor of any state or territory, any United States justice or judge, or the secretary of any of the executive departments of the United States.] They are punishable as follows: [When they conspire to commit any crime against the person of any official specified in paragraph (6), they are guilty of a felony and are punishable by imprisonment in the state prison for five, seven, or nine years. When they conspire to commit any other felony, they shall be punishable in the same manner and to the same extent as is provided for the punishment of that felony. If the felony is one for which different punishments are prescribed for different degrees, the jury or court which finds the defendant guilty thereof shall determine the degree of the felony the defendant conspired to commit. If the degree is not so determined, the punishment for conspiracy to commit the felony shall be that prescribed for the lesser degree, except in the case of conspiracy to commit murder, in which case the punishment shall be that prescribed for murder in the first degree. If the felony is conspiracy to commit two or more felonies which have different punishments and the commission of those felonies constitute but one offense of conspiracy, the penalty shall be that prescribed for the felony which has the greater maximum term. When they conspire to do an act described in paragraph (4), they shall be punishable by imprisonment in the state prison, or by imprisonment in the county jail for not more than one year, or by a fine not exceeding ten thousand dollars ($10,000), or by both that imprisonment and fine. When they conspire to do any of the other acts described in this section, they shall be punishable by imprisonment in the county jail for not more than one year, or in the state prison, or by a fine not exceeding ten thousand dollars ($10,000), or by both that imprisonment and fine. When they receive a felony conviction for conspiring to commit identity theft, as defined in Section 530.5, the court may impose a fine of up to twenty-five thousand dollars ($25,000.) All cases of conspiracy may be prosecuted and tried in the superior court of any county in which any overt act tending to affect the conspiracy shall be done. (b)Upon a trial for conspiracy, in a case where an overt act is necessary to constitute the offense, the defendant cannot be convicted unless one or more overt acts are expressly alleged in the indictment or information, nor unless one of the acts alleged is proved; but other overt acts not alleged may be given in evidence.]

 

Defendants possess direct evidence, knowledge and/or awareness of members employed by The Los Angeles County Probation Department making false accusations of criminal contempt towards Plaintiff. On or about December 9, 2011 member employed by The Los Angeles County Probation Department falsely accused Plaintiff of criminal contempt in an effort to extort money’s from Plaintiff. Due to the fact that Defendants have offered no over-sight, and instead, condoned extortive behaviors by member’s Employed by The Los Angeles County Probation Department (EXHIBIT,) Defendants are both directly and indirectly in violation of CALIFORNIA PENAL CODE § 518: which states, [Extortion is the obtaining of property from another, with his consent, or the obtaining of an official act of a public officer, induced by a wrongful use of force or fear, or under color of official right.]

FIRST CAUSE OF ACTION

Fraud in Violation of California Civil Code § 3294

(Against LOS ANGELES CITY MAYOR ANTONIO VILLARAIGOSA and LOS ANGELES COUNTY BOARD OF SUPERVISORS: MICHAEL D. ANTONOVICH, GLORIA MOLINA, DON KNABE, MARK RIDLEY-THOMAS, ZEV YAROSLAVSKY)

 

As a first separate and distinct cause of action, Plaintiff complains Against LOS ANGELES CITY MAYOR ANTONIO VILLARAIGOSA and LOS ANGELES COUNTY BOARD OF SUPERVISORS: MICHAEL D. ANTONOVICH, GLORIA MOLINA, DON KNABE, MARK RIDLEY-THOMAS, ZEV YAROSLAVSKY  for a cause of action alleges:

 

This action is brought under CALIFORNIA CIVIL CODE § 3294, which states, [(a) In an action for the breach of an obligation not arising from contract, where it is proven by clear and convincing evidence that the defendant has been guilty of oppression, fraud, or malice, the plaintiff, in addition to the actual damages, may recover damages for the sake of example and by way of punishing the defendant. (3)”Fraud” means an intentional misrepresentation, deceit, or concealment of a material fact known to the defendant with the intention on the part of the defendant of thereby depriving a person of property or legal rights or otherwise causing injury.]

 

Plaintiff is informed and believes, and on this basis alleges, that Defendants committed fraud directly and/or indirectly when Defendants made the conscious choice to disregard very noticeable and/or egregious accounting schemes perpetrated by The Los Angeles County Child Support Services Department, and committed on-going fraud by shirking and/or passing-on their responsibilities and duties.

 

Plaintiff is informed and believes, and on this basis alleges that Defendants’ conduct is part of a pattern and practice of adversely treating constituents who object to, protest, or refuse to participate in Defendants’ noncompliance with federal and state ethical regulations.

 

Plaintiff is informed and believes, and on this basis alleges, that the decision to disregard Plaintiffs direct evidence, and concerns was directed and authorized by Defendants’ themselves. Defendant’s decision was willful and malicious to disregard evidence provided by Plaintiff and represented a conscious disregard for Plaintiff’s rights and well-being.

 

Plaintiff suffered damages legally caused by Defendants negation and neglect of over-sight and Departmental accountability.  Plaintiff as stated in the section below entitled “DAMAGES” which is incorporated here to the extent as if set forth here in full.

SECOND CAUSE OF ACTION

Extortion in Violation of California Penal Code § 518

(Against LOS ANGELES CITY MAYOR ANTONIO VILLARAIGOSA and LOS ANGELES COUNTY BOARD OF SUPERVISORS: MICHAEL D. ANTONOVICH, GLORIA MOLINA, DON KNABE, MARK RIDLEY-THOMAS, ZEV YAROSLAVSKY)

 

As a second separate and distinct cause of action, Plaintiff complains against LOS ANGELES CITY MAYOR ANTONIO VILLARAIGOSA and LOS ANGELES COUNTY BOARD OF SUPERVISORS: MICHAEL D. ANTONOVICH, GLORIA MOLINA, DON KNABE, MARK RIDLEY-THOMAS, ZEV YAROSLAVSKY for a cause of action alleges:

 

This action is brought under California Penal Code § 518, which states: Extortion is the obtaining of property from another, with his consent, or the obtaining of an official act of a public officer, induced by a wrongful use of force or fear, or under color of official right.

 

Plaintiff is informed and believes, and on this basis alleges, that Defendants committed extortion both directly and indirectly when Defendants offered no recourse or reprimand for false accusation of criminal contempt toward Plaintiff by members employed by The Los Angeles County Probation Department. Defendants had full knowledge of fraudulent accounting schemes utilized by The Los Angeles Child Support Services Department for the sole purpose to extort money’s from Plaintiff.

 

Plaintiff is informed and believes, and on this basis alleges, that Defendants had full knowledge of collusive and conspiracy to defraud Plaintiff by The Los Angeles County Probation Department and The Los Angeles County Child Support Services Department. Defendants are in direct violation of California Penal Code § 484, which states: [(a)Every person who shall feloniously steal, take, carry, lead, or drive away the personal property of another, or who shall fraudulently appropriate property which has been entrusted to him or her, or who shall knowingly and designedly, by any false or fraudulent representation or pretense, defraud any other person of money, labor or real or personal property, or who causes or procures others to report falsely of his or her wealth or mercantile character and by thus imposing upon any person, obtains credit and thereby fraudulently gets or obtains possession of money, or property or obtains the labor or service of another, is guilty of theft. In determining the value of the property obtained, for the purposes of this section, the reasonable and fair market value shall be the test, and in determining the value of services received the contract price shall be the test. If there be no contract price, the reasonable and going wage for the service rendered shall govern. For the purposes of this section, any false or fraudulent representation or pretense made shall be treated as continuing, so as to cover any money, property or service received as a result thereof, and the complaint, information or indictment may charge that the crime was committed on any date during the particular period in question. The hiring of any additional employee or employees without advising each of them of every labor claim due and unpaid and every judgment that the employer has been unable to meet shall be prima facie evidence of intent to defraud.]

 

Plaintiff is informed and believes, and on this basis alleges that Defendants’ conduct is part of a pattern and practice of failure to provide over-sight and ethical judgment treating Plaintiff’s evidence of fraud and corruption as illegitimate whimsicalities.

 

Plaintiff suffered damages legally caused by the collusive, conspiracy to defraud and  extortive practices perpetrated by the Defendants violation of public policy as stated in the section below entitled “DAMAGES” which is incorporated here to the extent as if set forth here in full.

THIRD CAUSE OF ACTION

Child Endangerment In Violation of California Code – Article 2.5: Child Abuse and Neglect Reporting Act § 11164. – 11174.3

 

(Against LOS ANGELES CITY MAYOR ANTONIO VILLARAIGOSA and LOS ANGELES COUNTY BOARD OF SUPERVISORS: MICHAEL D. ANTONOVICH, GLORIA MOLINA, DON KNABE, MARK RIDLEY-THOMAS, ZEV YAROSLAVSKY)

As a third, separate and distinct cause of action, Plaintiff complains against LOS ANGELES CITY MAYOR ANTONIO VILLARAIGOSA and LOS ANGELES COUNTY BOARD OF SUPERVISORS: MICHAEL D. ANTONOVICH, GLORIA MOLINA, DON KNABE, MARK RIDLEY-THOMAS, ZEV YAROSLAVSKY for a cause of action alleges:

 

Defendants acted intentionally and/or recklessly and subjected Plaintiffs children to severe psychological and emotional distress by doing the outrageous acts alleged to have been done by Defendants throughout this complaint, including but not limited to placing Plaintiffs children in imminent danger under The Los Angeles County Department of Children and Family Services over-seen by Patricia S. Ploehn who as of (date) has been removed from her position due to several child fatalities. Defendants are directly and/or indirectly responsible for the, over 17 deaths that occurred under Patricia S. Ploehn’s directorship. Defendants are liable for such deaths due to the fact that Defendants have total and absolute control over appointments and hiring practices at The Los Angeles County Department of Children and Family Services.

 

Defendants have direct evidence, knowledge and/or awareness of physical, mental and verbal abuse perpetrated upon Plaintiffs children by members employed by The Los Angeles County Probation Department. Defendants possess knowledge and/or awareness of members employed by The Los Angeles County Probation Department and The Los Angeles County Department of Children and Family Services compromising the health, safety and welfare of Plaintiffs children.

 

Defendants are in direct violation Child Endangerment Laws, particularly, California Code – Article 2.5: Child Abuse and Neglect Reporting Act § 11164. – 11174.3, which states, [(a) this article shall be known and may be cited as the Child Abuse and Neglect Reporting Act. (b)The intent and purpose of this article is to protect children from abuse and neglect. In any investigation of suspected child abuse or neglect, all persons participating in the investigation of the case shall consider the needs of the child victim and shall do whatever is necessary to prevent psychological harm to the child victim.]

Intentional Infliction of Emotional Distress

(Against All Defendants)

In doing the acts alleged herein, Defendants acted outrageously with the intent of causing or with reckless disregard of the probability of causing severe psychological and emotional distress to Plaintiff and Plaintiffs children.  Specifically, it was outrageous to continually ignore direct evidence showing fraud, coercion, extortion, conspiracy, and child endangerment against Plaintiff, thus making Defendants violators of California public policy after having knowledge and/or awareness of direct evidence concerning such improprieties.

 

Plaintiff suffered damages legally caused by the lack of over-sight and accountability in violation of California statues, departmental and public policy as stated in the City Charter of  the City of Los Angele and California Penal and Civil code section below entitled “DAMAGES” which is incorporated here to the extent as if set forth here in full.

DAMAGES

WHEREFORE, Plaintiff requests relief as hereinafter provided: As a legal result of the conduct by Defendants, and each of them, of which Plaintiff complains, Plaintiff suffered and continues to suffer substantial losses by-way of wage garnishments and the freezing of assets. Plaintiff was forced to file bankruptcy due to malicious and fraudulent accounting schemes by Defendants and the Los Angeles County Child Support Services Department (EXHIBIT.) Plaintiff will seek to amend this Complaint to state the amount or will proceed to proof at trial.

 

Plaintiff and Plaintiffs children suffered, and continues to suffer mental distress, abandonment, pain, suffering, and anguish as a legal and/or direct result of Defendants’ outrageous conduct, resulting in Plaintiff and Plaintiffs children being alienated from each other, as well as total blatant destruction of Plaintiffs family unit and/or family cohesion. Plaintiff experienced humiliation, depression, embarrassment, anxiety, disappointment, and worry, all of which is substantial and enduring, due to Defendants fraud and corruption which deemed Plaintiff to be a “DEAD BEAT DAD.”   Plaintiff will seek to amend this complaint to state the amount or will proceed according to proof at trial.

 

At all relevant times, Defendants knew that Plaintiff was being fraudulently over-charged on Plaintiffs child support obligation, and that members employed by The Los Angeles County Probation Department and The Los Angeles Department of Children and Family Services were committing fraud, extortion, coercion, conspiracy, and child endangerment.  At all relevant times, Defendants were in a position of power over city departments under their jurisdiction, with the potential to abuse that power, which is conclusively demonstrated in direct evidence.  Both Plaintiff and Plaintiffs children were, and continue to be vulnerable because the corruption and fraud is so menacing and covertly far reaching throughout the Defendants supervisory jurisdictions. Both Plaintiff and Plaintiffs children are forced to abdicate their relative lack of power, because of Plaintiffs reliance on Defendants’ assurances and forbearance of the possibility of departmental over-sight and accountability, because Plaintiff and Plaintiff’s children have placed their trust in Defendants, because Plaintiff and Plaintiff’s children relied on the ethical and moral integrity of Defendants for departmental over-sight and/or accountability. Instead Plaintiff continues to cope with the possibility that Plaintiffs children could lose their lives, as other children have, under the poor judgment and mismanagement of The Los Angeles Department of Children and Family Services. Plaintiff continues to undergo financial distress due to fraudulent and corrupt accounting schemes perpetrated by Defendants’ Child Support Services Department. Defendants were aware of Plaintiff’s vulnerability and the reasons for it.

 

Notwithstanding such knowledge, Defendants acted oppressively and maliciously, in willful and conscious disregard of Plaintiff’s rights, and the direct evidence communicated to Defendants by Plaintiff. Defendants chose malfeasance with the intention of causing or in reckless disregard of the probability of causing injury and emotional distress to Plaintiff and Plaintiffs children.

 

Defendants were informed of the oppressive, fraudulent, and malicious conduct of City Departments, agents, and subordinates under Defendants jurisdiction, and ratified, approved, and authorized that conduct.

 

The foregoing conduct of Defendants were intentional, willful, and malicious, and was despicable conduct that subjected the Plaintiff and Plaintiffs children to a cruel and unjust hardship in conscious disregard of Plaintiff’s rights, so as to justify an award of exemplary and punitive damages in an amount to conform to proof.

 

Pursuant to California Code of Civil Procedure Section 1021.5, Plaintiff seeks recovery of his costs and attorney’s fees, as the prosecution of this action, if successful, will result in the enforcement of an important right affecting the public interest, the right to oppose unlawful conduct, fraud and corruption in the City of Los Angeles amongst City Officials without fear of retaliation or discrimination in the terms, conditions, and privileges of public citizens, the enforcement of State of California Civil and Penal Code provisions and regulations affecting public welfare.  The prosecution of this action, if successful, will confer a significant benefit on the general public, affecting the enforcement of the City Charter of the City of Los Angeles, Governmental ethics, Civic and Penal Code provisions and regulations protecting children from abuse; and citizens rights to equal protection under the law even when corruption is overtly and covertly noticeably ingrained in public office and/or officials.  In such instance, the interest of justice requires that Plaintiff’s costs and fees be paid by Defendants.

PANTHEISTIC PRECATORY PRAYER

WHEREFORE, Plaintiff prays for judgment against Defendants and each of them as follows: For an award of monetary damages for mental pain and anguish and emotional distress, according to proof; For an award of punitive damages, according to proof; For attorney’s fees and costs, pursuant to the California Code of Civil Procedure Section 1021.5; For an award of monetary damages representing compensatory damages including lost wages, earnings, retirement benefits and other employee benefits, and all sums of money, together with interest on these amounts, according to proof; For prejudgment and post-judgment interest; For attorneys’ fees, expenses and costs of suit authorized by statute; For any other relief the Court deems just and proper.

RESPECTFULLY SUBMITTED,

SEARGENT HASHIM MWAMBA BOMANI (PLAINTIFF)

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43 responses to “SEARGENT HASHIM MWAMBA BOMANI vs. MAYOR ANTONIO R. VILLARAIGOS AND MICHAEL D. ANTONOVICH AND GLORIA MOLINA AND DON KNABE AND MARK RIDLEY-THOMAS AND ZEV YAROSLAVSKY

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