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EMAD G. TADROS M.D
3914 3RD Avenue
San Diego, CA 92103

EMAD G. TADROS M.D.
Plaintiff In Propria Persona

IN THE SUPERIOR COURT FOR THE STATE OF CALIFORNIA
COUNTY OF SAN DIEGO, CENTRAL JUDICIAL DISTRICT

EMAD G. TADROS, M.D,Plaintiff,
vs. STEPHEN DOYNE,Defendant.
Case No.: 37-2008-00093885-CU-BT-CTL
PETITION AND DECLARATION OF MEMBERS OF THE PUBLIC PURSUANT TO THE REASONABLE PERSON STANDARD SUPPORTING REMOVAL OF THIS CASE FROM THE COUNTY OF SAN DIEGO AS PLAINTIFF EMAD G. TADRO M.D. CANNOT OBTAIN A FAIR AND IMPARTIAL TRIAL IN THIS COUNTY OF SAN DIEGO.

All of the undersigned parties are citizens of the United States, and counties in the State of California. We voluntarily come before this court as a cognizable group, similarly situated with Dr. Tadros.
We are aware that the same issues affecting the Plaintiff have affected large numbers of other San Diego County family law litigants so similarly situated as the plaintiff. We are aware that these injured litigants are part and parcel of a collective legal wrong that was perpetrated upon an un-noticed and un-informed cognizable group of family law litigants in 730 evaluations. The cognizable group of injured litigants is easily identifiable, and can be noticed quickly and inexpensively as the San Diego County Superior Court has in its possession the name, addresses, of each and every affected litigant in the group by defendant Doyne who falsified his credentials and failed to comply with the mandatory certification via the timely mandatory forms process. The very fact that Judge Bloom refuses to certify this case as a class action suit sua sponte indicates that a fair trial and hearing cannot be had for Dr. Tadros or any members individually as the cognizable group that are similarly situated with Dr. Tadros.
We as the undersigned agree that pursuant to CCP Section 397 a change of venue must be granted as this will protect and preserve the independent judiciary: as there is reason to believe that an impartial trial cannot be had therein as this court has ignored our voices through this petition and the disqualification petition, and that Dr. Tadros has brought this action in the name of the public good.
Therefore the undersigned parties through this verified declaration under the penalty of perjury declare that they have direct and personal knowledge that Judge Bloom is prejudice and bias, that no Judge can be appointed in the County of San Diego, and this case should be removed to a fair and impartial venue, where a fair hearing on the attorney fees can be heard, and this case can move forward on the issue of the public good, which would cause to begin discovery.
We swear and affirm that the foregoing is true and correct under the penalty of perjury and under the laws of the State of California. We have read and understand the foregoing and are unanimous in our requests for a change of venue to an impartial county where this case can move forward in the name of the public good. SIGNATURES NEXT PAGE

The undersigned I support a change of venue in this case and am appalled that as a member of the public this court ignored the reasonable person standard by striking its own disqualification motion: I am a resident of the City of ________________, State of California, signed on _____________________.

Print Name:_______________________________
Sign Name: _________________________
Address: _____________________________City:___________________ CA Zip: __________


The undersigned I support a change of venue in this case and am appalled that as a member of the public this court ignored the reasonable person standard by striking its own disqualification motion: I am a resident of the City of ________________, State of California, signed on _____________________.

Print Name:_______________________________
Sign Name: _________________________
Address: _____________________________City:___________________ CA Zip: __________

DETAILED/Court Filed PETITION
IN THE SUPERIOR COURT FOR THE STATE OF CALIFORNIA
COUNTY OF SAN DIEGO, CENTRAL JUDICIAL DISTRICT

EMAD G. TADROS, M.D, Plaintiff,
vs. STEPHEN DOYNE,Defendant.
Case No.: 37-2008-00093885-CU-BT-CTL

PETITION AND DECLARATION OF MEMBERS OF THE PUBLIC PURSUANT TO THE REASONABLE PERSON STANDARD SUPPORTING REMOVAL OF THIS CASE FROM THE COUNTY OF SAN DIEGO AS PLAINTIFF EMAD G. TADRO M.D. CANNOT OBTAIN A FAIR AND IMPARTIAL TRIAL IN THIS COUNTY OF SAN DIEGO.

NOTICE TO THE TRIER OF FACT AND ALL PARTIES OF INTEREST AND ATTORNEYS OF RECORD: The undersigned parties are completely informed of all of the facts, and conditions defined in the following text. The undersigned parties are individual members of a cognizable group that can clearly be defined as acting in the Public Good and in support of Dr. Tadros and are similarly situated with common legal inequities. The undersigned parties are the atypical reasonable person that is used and applied in the Reasonable Person Standard described in the following text.

This comprehensive comment is being filed with the court to ensure and leave no doubt that each and every undersigning party is aware of the misuse, abuses of the public trust and the appearance of legal, moral, political, and social improprieties defined herein which is only the tip of the legal iceberg that demands legal intervention in the name of the public good.
All of the undersigned parties are citizens of the United States, and live in the County of San Diego or other counties in the State of California under the penalty of perjury. We voluntarily come before the court as a cognizable group similarly situated with Dr. Tadros, requesting that this Court make an order to change venue to an impartial County, where Emad G. Tadros, M.D. can have a fair and impartial trial and hearing on the issue of attorney fees that is scheduled to be heard on July 30, 2010 at 11:00 a.m and/or that this case and action will move forward as it was brought in the name of the public good, and other similarly situated like the undersigned parties.
This is an issue that affects and violates Dr. Tadros 14th and 5th Amendments as it affects his property rights , without due process of law, especially when Dr. Tadros has brought this case and action in the name of the public good, which has been ignored by this court, with no explanations being offered, which would cause to exempt the Anti-SLAPP statutes making the order of attorney fees of $85,000 retaliatory in nature for exposing the inequities that the San Diego Court has not enforced the mandatory rules of court for nine-plus years, which was brought in the name of the public good, there can be no Anti-SLAPP action. In addition to that this court has once again demonstrated its prejudice and bias by not allowing Dr. Tadros to respond to the attorney fees, and leaving the order that Dr. Tadros failed to oppose the attorney fees, when he vehemently and repeatedly did in open court and in other pleadings.
We are absolutely appalled as members of a cognizable group similarly situated, that Dr. Tadros when he exposed the illegal acts and actions by the defendant Stephen Doyne and brought this action in the name of the public good, that is for our benefit, (the public) then when this court demands that Dr. Tadros pay Stephen Doynes attorney fees, when he has completely and totally misrepresented himself to the public while in the business of performing private child custody evaluations and teaching classes for profit, has not adhered to the California Rules of Court, which have affected the lives of numerous children and parents alike, being completely and totally disenfranchised from their children without justification in fact, law or truth.
What is most compelling is we being the voice of the public, (we are doctors, lawyers, nurses, mothers fathers and grandparents and more,) we request and require an answer from this court, why this court ignored our requests in a prior petition that was filed for cause, where the ninety-two (92) persons from the public signed a verified petition supporting an order for the removal of Judge Bloom for cause in the matter of Tadros vs. Doyne Case No. 37-2008-00093885-CU-BT-CTL. The 92 persons from the public requested for the appointment of an unbiased impartial trier of fact. This was ignored, and this court illegally proceeded to strike its own motion giving no response to the required mandatory reasonable person standard that was met by our petition.
We are now convinced more than ever, that due to the number of judges that have been compromised and tainted during the life of Tadros vs. Doyne, that Dr. Emad Tadros case must be removed from the County of San Diego because, this court:
1. has ignored our public pleas and granted an Anti-SLAPP motion when Dr. Tadros has brought same in the name of our voices, the public (that is exempt from the Anti-SLAPP) that have and continue to be ignored to the detriment of the public interest and the cause of justice. This is like saying it does not matter that Stephen Doyne has purposefully violated the Rules of Court, and misrepresented himself to the public, by receiving large sums of inflated fees in the millions of dollars each year and making the exploitation of 730 evaluations a highly profitable illegal cottage industry.
Dr. Tadros cannot get a fair trial or hearing in the County of San Diego because of the vertical integration and the appearance of impropriety, which is systemic in the San Diego Superior court system. It is well settled legal ground that all judges shall avoid any appearance of impropriety. All judges are held to the highest possible standard of moral and ethical care and or appearance of condoning, or associating with those or held in disrepute, and that are known to have caused fraud upon the court and the public at large.
Example: Dr. Tadros clearly explained to this court in his pleadings and proved in the name of the public good, that defendant Stephen Doyne had falsified his credentials and used those falsified credentials to defraud the public, his clients and the court causing unjust enrichment. Defendant Doyne is a supporter of Hannah's House, which is owned and operated by Susan Griffin. Susan Griffin is still paying restitution to the County of San Diego and was fined by the State for practicing psychology without a license. Ms. Griffin like defendant Doyne also misrepresented herself as being qualified as a psychologist when she was not and was found guilty of same.
At first blush it would appear that no respectable judge or attorney would associate with or be lectured to by any individual that has a reputation for dishonesty, fraud upon the public, and falsifying credentials. The reason for avoiding such people would be that it would give the appearance that any support or lectures by these individuals would be condoning and supporting the illegal behaviors of these parties.
The San Diego County Bar Association which was attended by the San Diego County Superior Court judges held a lecture entitled: Clients Behaving Badly on April 14, 2010. Surprisingly enough, one of the paid guest speakers was defendant Doyne and Ms Susan Griffin. This is obvious proof, of the vertical integration of persons with less than reputable credentials that are supported by the San Diego County Bar Association and all the judges that were in attendance, including Judge Alksne, who has participated in damage control by working with Defendant Doyne to send out notices to the harmed family law litigants, after the fact the California Rules of Court forms FL-326 and FL-327, which if these California Judicial Council forms were not required in the first instance, then Judge Alksne who was in attendance at this paid seminar and classes would not have attempted damage control by sending them out after the fact, especially after she was armed with the information and media reports that defendant Doyne had falsified his credentials deceiving the public, and because defendant Doyne had no subject matter jurisdiction because of failure to adhere to the California Rules of Court, then Judge Alksne could not after the fact give the false appearance by sending out the mandatory forms that defendant Doyne was in compliance with the mandatory rules of court, when he was not, including the San Diego Superior Court, that ignored the requirements for over 9 years more or less.
Then to add insult to injury attorney Cole Stuart who is co-founder of the Coalition for Children and Families with the plaintiff, was caused to be arrested on a trumped up bogus claim at the Bar Association meeting in the public presence of Defendant Doyne and Susan Griffin. This public organization was formed that promotes the public good and the removal of Defendant Doyne from continuing abuses of the law, violations of public trust, and the public good. The message sent by the arrest of attorney Cole is that the San Diego Judiciary will use all means possible to attempt to intimidate, harass, and shut down anyone who dares to expose illegal activities, and corruption of the law. Dr. Tadros cannot get a fair hearing in this County of San Diego.
Using the reasonable person standard it clearly indicates that this gives the appearance of impropriety and establishes by the preponderance of evidence the vertical integration of the San Diego Superior Court and the San Diego Bar Association to turn a blind eye and deaf ear to proven facts that the two individuals who were speaking at a public event, who received financial enumeration were under a cloud of suspicion for jointly and individually falsifying credentials Susan Griffin and Stephen Doyne. The reasonable person would clearly understand and feel that no family law litigant including Dr. Tadros can get a fair hearing or trial in the County of San Diego. What is also important about this issue, is this proves the commercial speech element that Judge Bloom tried to state did not apply, while ruling on factual issues, that Stephen Doyne does not hold himself out to the public, as the defendant was paid to speak at this event.
To add further proof to this claim, using the reasonable person standard that Dr. Tadros cannot and has not received a fair hearing or trial in the County of San Diego is further supported by Judge Salcido on Friday May 7, 2010 who sued the San Diego Superior Court and Judge Deddeh and filed a writ. Judge Salcido was a long time Family Law Judge. Judge Salcido contends in her complaint and suit that the judges of the entire San Diego Superior Court system routinely disregard state law when sentencing people who have pleaded guilty in domestic violence cases and are placed on probation. It is of great social, political and legal import that a sitting San Diego County Superior Court Judge finds it necessary to file suit against her boss and the Superior Court itself because it refuses, quoting Judge Salcido routinely disregard state law. There can be no doubt that Judge Salcido does not have a complete understanding of the internal workings of the San Diego Superior Court and its routinely disregarding state law, such as the mandatory law regarding 730 evaluations that Judge Alksne has caused to place a lid on, as clearly illuminated herein. Judge Salcido claimed at a news conference on the steps of the Hall of Justice in downtown San Diego Friday May 7, 2010, that she was filing a petition in the 4th District Court of Appeal, asking the court to order judges to impose all conditions of probation called for under state law for domestic violence offenders. Salcido said there is a pattern in the courts of not doing so. There has clearly been a pattern of the San Diego County Family Law Judges not following the law for nine years more or less, they have violated the law and the rules of court and have harmed thousands upon thousands of family law litigants by its routine disregard for state law. This is the same fundamental claim brought by Dr. Tadros in the name of the public good that is now being brought that Judges are not following the law, and Judge Salcido even stated publicly, that when she pressed this issue, she said Deddeh (her boss and presiding judge of East County) became increasingly upset with her and retaliated by ordering her to get his permission before asking clerks to make copies of some court papers, which she said limited her ability to control her court calendar. This proves beyond any doubt that the County of San Diego has lost its ability to act independently. Dr. Tadros has always stated this, supporting this change of circumstances to move this case to an impartial county where the sacred independent judiciary can be maintained, as the public good issue is adjudicated. The Framers viewed independent judges, no less than the right to a jury of one's peers, as indispensable to a fair trial. See, e.g., [128 S.Ct. 1781]United States v. Hatter, 532 U.S. 557, 568-569, 121 S.Ct. 1782, 149 L.Ed.2d 820 (2001) (discussing the Framers' overriding concern for an independent Judiciary and quoting Chief Justice Marshall's statement that the "'greatest scourge . . . ever inflicted'" "'was an ignorant, a corrupt, or a dependent Judiciary'" (quoting Proceedings and Debates of the Virginia State Convention, of 1829-1830, p. 619 (1830))). A JUDGE SHALL UPHOLD THE INTEGRITY AND INDEPENDENCE OF THE JUDICIARY. An independent and honorable judiciary is indispensable to justice in our society. A judge should participate in establishing, maintaining, and enforcing high standards of conduct, and shall personally observe those standards so that the integrity and independence of the judiciary will be preserved. The provisions of this Code are to be construed and applied to further that objective. (Cal. Code Jud. Ethics, canon 1.)
There can be no more compelling proof than that of the lawsuit that has now been brought by Judge Salcido as this supports the same type and claim that the present trier of fact refuses to acknowledge that the Anti-SLAPP must be denied because Dr. Tadros is bringing his claim like Judge Salcido in the name of the public good. It is shameful that the long history of actions against Susan Griffin, (as supported by a letter by family law employees themselves attached hereto) in spite of magazine cover stories and evidence of fraud upon the courts, and the public, including page one news stories is proof judges and law enforcement officials alike are behind the "worst interests of the child." Doyne and Susan Griffin have become a protected special class of violators in spite of magazine and newspaper headlines. When all of the elements of wrong doing and all of the appearance of impropriety are totaled up it creates prima-facie case that because of the vertical integration of defendant Doyne, Susan Griffin, San Diego County judiciary and the San Diego County Bar Association it becomes a physical and legal impossibility to get a fair hearing in the County of San Diego as there is no independent judiciary for review of Dr. Tadros claims or the claims of the cognizable group so similarly situated and undersigned herein.
The undersigned parties are personally aware that on September 4, 2009, when Judge Bloom denied Tadros motion to change venue (without prejudice) that Dr. Tadros spoke repeatedly and properly noticed Judge Bloom about his concern of his connections to the presiding Judge Alksne, Michael Roddy who is Chief Executive Officer for the San Diego Superior Courts, the defendant and others about the issue that no Judge in the County of San Diego could rule impartially because of the connection to the other judges in the entire Judiciary. The undersigned people and voices are unanimous along with the voice of Judge Salcido in their beliefs that the County of San Diego has a vested interest in political and legal self-containment of the judicial and legal ethical violations that numbers into the thousands over a 9-year period. Clearly this can no longer be ignored.
These litigants that the undersigned parties are personally aware of have suffered the same illegal inequities and gross violations of the constitutional protected rights of due process of law as defined under the 5th and 14th Amendments of the Constitution under the equal protection and due process clauses of these amendments as it relates to the 730-evaluation process as the County of San Diego Judges as supported by Judge Salcido routinely ignore state law. The undersigned parties as a cognizable group similarly situated reasonably believe beyond any doubt Dr. Tadros cannot obtain a fair and impartial hearing in the County of San Diego before Judge Bloom or any other sitting judge in the San Diego County Judiciary especially with the confirmations and revelations by Judge Salcido. This is because this case has far reaching implications. This very case has caused to expose the inequities in the County of San Diego as it relates to 730 evaluators and the failure of the County of San Diego Judiciary not to cause to cure the many litigants affected, by the complete disavowment of failure to follow, and adhere to the mandatory procedure of 730 evaluators, that are firmly secured in the California Rules of Court. This is a public issue and as the public we feel as the undersigned parties this sacred trust and the purpose of the independent judiciary has been compromised that requires a change of venue.
It should be noted by the court that the undersigned parties are aware that the same issues affecting the Plaintiff, have affected vast numbers of other San Diego County family law litigants so similarly situated as the plaintiff. The undersigned parties are aware that these injured litigants are part and parcel of a collective legal wrong that was perpetrated upon an un-noticed and un-informed cognizable group of family law litigants in 730 evaluations. The cognizable group of injured litigants is easily identifiable, and can be noticed quickly and inexpensively as the San Diego County Superior Court has in its possession the name, addresses, of each and every affected litigant in the group by defendant Doyne who falsified his credentials and failed to comply with the mandatory certification via the timely mandatory forms process. The undersigned parties are aware that there has been no notification of these easily identifiable members of the class. They were not informed that their legal rights may have been illegally impaired; and the resulting judgments of the San Diego Superior Court in 730 evaluations, may be tainted as the Superior Court Judges of San Diego routinely fail to adhere to state law, and are retaliated as supported by Judge Salcido, by Judge Deddah if they dare do - proving that an independent judiciary is non-existent in the County of San Diego Superior Courts.
The San Diego Superior Court and the Judges in the family law courts allowed this complete failure of the judicial process to continue from 2001 until October 1, 2009. The Superior Court Judges, lawyers and 730 evaluators did allow court appointed 730 psychological evaluators to make evaluation reports to the Family Law Court judges in thousands of child custody cases over a nine year period, when the evaluators had no legal standing before the court. This was because of their failure to comply with the rules of court and file the appropriate documents, which would give them standing and pre-qualification to be a 730 evaluator.
The San Diego Superior Court is now refusing to acknowledge the thousands of family law litigants whose constitutionally protected rights of due process were violated in the hope that they will drown in the legal river of time. At the same time the undersigned parties are aware that pre-notice is being given to other 730 Psychological Evaluators and Family law attorneys that CA Rules of Court and attending required mandatory CA Judicial Council Forms must be completed or no fees for services can be paid or collected. This is an admission by the San Diego Superior Court and its administration that for nine-years that it knowingly and willingly ignored the law to the detriment of the public good and the detriment of the public good in violation of the legislative intent of the law. There was an email attached to the pleading filed by Dr. Tadros to remove Judge Bloom. The undersigned parties have read this and are aware of this, and find it shocking. The legal bottom line being the San Diego Superior Court finds a legal need to inform all of the offending parties that caused the legal injury in the first instance, while remaining as quiet as a legal grave and avoid any notice to the injured family law litigants who have a need and legal right to know of the possible impairment of their legal rights to parent, and the attending costs of money being paid to psychological 730 evaluators, who had no legal standing before the court to investigate, or issue psychological custody evaluations that caused a change in child custody, visitation, child contact, and the ordering of child support, spousal support and family support in many of these cases.
The actions of Judge Salcido in bringing suit against the San Diego Superior Court system clearly defines that an individual judge such as Judge Bloom has the legal authority and judicial duty once noticed of a harm to the public good and harm caused by the 730 evaluators, lawyers and judges to declare them a class action suit that is being brought by and individual member, i.e. Dr. Tadros in the name of the public good. The very fact that Judge Bloom refuses to certify this case as a class action suit sua sponte indicates that a fair trial and hearing cannot be had for Dr. Tadros or any members individually as the cognizable group that are similarly situated with Dr. Tadros.
We are all unanimous that we are in agreement that the San Diego Superior Court has not only not noticed the affected litigants, they are not curing the inequities of the litigants that have on their own accord requested for such relief, which demonstrates a complete violation of the law proving intent and motive. Then to add insult to injury this court completely ignores that Dr. Tadros has brought this action in the name of the public good, when it knows or should know about all of these inequities as it has been informed of same.
It has been clearly established that the Superior Court San Diego County Judiciary because of the failure to have the forms filed timely cannot and could not qualify the credentials of defendant Doyne not only in the Tadros case, but in the many similarly situated cases. Doyne could not be pre-qualified. This is because there is a big NOTICE on the form and stated as follows, FL-326 that Private child custody evaluators must complete this form and file it with the clerks office no later than 10 days after notification of each appointment and before beginning any work on the child custody evaluation. This is in violation of Cal. Rules of Court, rule 5.225 (k)(1)(B) because the forms were failed to be filed before beginning the evaluation. This is especially critical when Doyne has falsified credentials, and has produced such substandard poor work product that has harmed many.
The California Superior Court of San Diego County, since January 1, 2000, has failed to adhere to the mandatory law, which is neither permissive nor indulgent. The rules required are mandatory under Family Code section 3110.5, rule 5.225 of the California Rules of Court adopted on January 1, 2000, to establish the education, experience, and training requirements for child custody evaluators. The mandatory rule was amended on January 1, 2005, to further clarify the education, training, experience requirements, and certification procedures for court-appointed child custody evaluators. Why is this so critical and has affected a vast amount of litigants in the San Diego County Superior Court, that have become the targeted victims of defendant Doyne and other 730 evaluators who also continually violated the law for 9 years? This is because Doyne was never pre-qualified. This is much more critical in the family law context as judges on a regular and normal basis appoint 730 child custody evaluators as a condition on child custody, which is the fundamental right to parent, and right to free association of ones family group. This is inviolate of the law, however family law judges normally and typically rely upon experts, like Doyne to make their custody decisions. Usually if a family law litigant has a negative report, then even with cross-examination, no matter how rigorous, it is a physical and legal impossibility to change the mind of the trier of fact once he or she is in possession of the 730-child custody expert and their report. This is the seriousness of defendant Doyne, the falsification of his credentials and the complete failure to follow the law, which gives him no shield of the litigation privilege.
The undersigned parties are aware that Judge Alksne mailed out the required forms long after the fact, to all the affected litigants, with Stephen Doynes signature, as if to give the appearance that the law in the first instance was followed. This proves motive and intent of damage control. There was no notice to these affected litigants, exposed by this case, the failure of the mandatory process and that their constitutional rights have been violated and that they had a right of redress and a right to a refund of any and all fees, and other damages that resulted from these illegal acts and actions. The filing of the forms is only a part of the process, however clearly these psychological evaluations could not begin until the form was filed. This makes the appointment temporary with no litigation privilege attaching, as such time as the 730 evaluator complies with the law and agrees to be attached to that litigation by the filing of the mandatory Judicial Council Forms of acceptance of that position 10 days prior to any work starting. This is required on and in the law to satisfy the legal requirement of Notice to all litigants and acceptance of the 730-evaluator court appointment, and a declaration under the penalty of perjury that they have complied with all of the mandatory law and judicial council forms to be appointed as a 730 evaluator. Notice is an elementary element of due process of law. Unless or until these are completed this causes and creates a condition that Doyne was never appointed in any case where he failed to file the form and comply with the law.
The undersigned parties are aware that Doyne falsified his credentials and shares the same status as a house cat named Zoл. Why were the litigants not noticed? Because the court, would have to, in many of these cases, place these affected litigants back to where they were before the illegal violation of the law. This would be a legal and political embarrassment. In a word, the court is afraid that it is going to open the floodgates of litigation, proving damage control and why Tadros cannot obtain a fair hearing in the County of San Diego because of the vertical integration of all Judges that occupy that space. The failure to follow the California Rules of Court and to file the forms timely gives Doyne no standing in Tadros case or any of the other cases so similarly situated. This case has exposed these anomalies making it a physical and legal impossibility for Tadros to obtain a fair and impartial hearing or trial before Judge Bloom or any other Judge in the San Diego Superior Courts. This requires a change of venue.
The San Diego Superior Court cannot claim ignorance as the San Diego Superior Court and its administration and all of its judges were aware and should have been aware of the legal necessity of applying the Statewide mandatory application of the approved judicial council forms and rules of court, that they were part and parcel of causing the ratification of these new rules and regulations, and applications of the required judicial council forms through notice by Michael Roddy Executive Officer of the Court, who attended all the Judicial Council Meetings, and the Judges who all had and have in their possession the Judges Bench Book. Therefore there is no judicial or legal excuse that could or would be acceptable or explained, why or how the judicial members of the family law court, and the administration was asleep on the family law bench and allowed the wholesale termination of the constitutionally protected rights of due process of law of the family law litigants. This same Superior Court system and the judges that populate these courts now attempt to disavow any responsibility and continuingly attempt to illegally inject the litigation privilege and Anti-SLAPP statutes to avoid accountability. The undersigned parties find this to be absurd.
The lack of the Superior Court following through with the injection of the rules of court and the proper and mandatory forms and Michael Roddys failure to notice the Superior Court of same, and the Presiding Judges failure to enforce the mandatory rules of court, has caused the individuals so similarly situated, proximate caused economic and loss of the constitutionally protected rights of due process of law under the equal protection clause of the 14th and 5th Amendments, by the falsified credentials and because it was clear and foreseeable that Doynes false credentials would have induced them to rely upon his expertise under and in the law, that failed to the detriment of the individual persons and cognizable group of injured persons.
It is quite simply, that the injury averred by the cognizable group proceeded directly from the falsification of credentials by Doyne and Michaels Roddys failure to notice the court of the injection of the mandatory rules and court forms on a timely basis and the failure of the Presiding Judge to enforce the rules and law and the sitting judges to follow the judges bench book, which they are all armed with. Now the Superior Court by and through Michael Roddy and others unknown and to be discovered are instructing the attorneys and Doyne to immediately fill out the forms, as stated herein, so that they can be assured that the litigation privilege will and does attach, when in fact, law and truth it does not and cannot attach after the fact, as this is plain upon the face of the California Judicial Council Form itself. This is a part of the illegal attempted damage control and giving the false appearance of mitigating the damages, while failing to inform the injured litigants that their rights were impaired, when the court is in possession of the names, telephone numbers and addresses of all the affected victims. The actors like Doyne are additionally fearful without filling out the required forms as Doyne has after the fact, that they will have to disgorge all funds received for the unqualified and second-rate reports. This could be in the millions of dollars.
We as the undersigned agree that pursuant to CCP Section 397 a change of venue must be granted as this will protect and preserve the independent judiciary: as there is reason to believe that an impartial trial cannot be had therein as this court has ignored our voices and that Dr. Tadros has brought this action in the name of the public good.
Therefore the undersigned parties through this verified declaration under the penalty of perjury declare that they have direct and personal knowledge that Judge Bloom is prejudice and bias, that no Judge can be appointed in the County of San Diego, and this case should be removed to a fair and impartial venue, where a fair hearing on the attorney fees can be heard, and this case can move forward on the issue of the public good, which would cause to begin discovery. Because this court caused to strike its own disqualification motion and did completely ignore and not respond to THE NINETY-TWO (92) MEMBERS OF THE PUBLIC demonstrates unequivocally why this change of venue must be granted and supported, as this courts rulings in and of itself went against the required standard that "(a) A judge shall be disqualified if any one or more of the following is true: * * * "(6) (A) For any reason ... (iii) A person aware of the facts might reasonably entertain a doubt that the judge would be able to be impartial.
An appearance of bias exists when a reasonable person aware of the facts of the case might harbor a doubt that the judge would be able to be impartial. (Brown, supra, 6 Cal.4th at pp. 336-337; see United Farm Workers of America v. Superior Court (1985) 170 Cal.App.3d 97, 103-104 [216 Cal.Rptr. 4].) Disqualification of a judge based on an appearance of bias is designed to protect the integrity of the legal system by promoting public confidence in an impartial judiciary. As pronounced by the California Supreme Court more than a century ago: "The trial of a case should not only be fair in fact, but it should also appear to be fair. And where the contrary appears, it shocks the judicial instinct to allow the judgment to stand." (Pratt v. Pratt (1903) 141 Cal. 247, 252.) In Johnson v. Superior Court (1958) 50 Cal.2d 693, 697, our high court again underscored the importance of the appearance of judicial neutrality, stating: "It is important, of course, not only that the integrity and fairness of the judiciary be maintained, but also that the business of the courts be conducted in such a manner as will avoid suspicion of unfairness."

SIMILARLY, A COURT OF APPEAL NOTED: "[T]HE SOURCE OF JUDICIAL AUTHORITY LIES ULTIMATELY IN THE FAITH OF THE PEOPLE THAT A FAIR HEARING MAY BE HAD. JUDICIAL BEHAVIOR INIMICAL TO THAT NECESSARY PERCEPTION CAN NEVER BE COUNTENANCED AND MAY WELL PROVIDE A BASIS FOR REVERSAL . . . ." (CATCHPOLE V. BRANNON (1995) 36 CAL.APP.4TH 237, 253 [42 CAL.RPTR.2D 440].)

Clearly, the undersigned members herein, who are the people as contained in Catchpole, that are the public interest in which this case is about the public interest, which is exempt from the Anti-SLAPP action, and have brought to the attention of the County of San Diego, Judge Bloom and the Presiding Judge of this County that the handling of the 730 process, and the failure of the Superior Court of San Diego County to not notice the affected litigants, and instead send forms after the fact while practicing containment of damage control has shocked the public, and we believe unanimously as citizens of this County and members of the cognizable group that is similarly situated, that this case must be moved out of the County of San Diego, as the standard for disqualification under subdivision (a) (6) (A) (iii) of section 170.1 is objective and was completely ignored by this court. (Flier v. Superior Court (1994) 23 Cal.App.4th 165, 170 [28 Cal.Rptr.2d 383].) Thus, an award may be vacated if "... the record reveals facts which might create an impression of possible bias in the eyes of the hypothetical, reasonable person. [Citation.]" (Ceriale v. AMCO Ins. Co. (1996) 48 Cal.App.4th 500, 504 [55 Cal.Rptr.2d 685].) Actual bias is not required. (Flier v. Superior Court, supra, 23 Cal.App.4th at p. 170.) "Where the average person could well entertain doubt whether the [adjudicator] was impartial, appellate courts are not required to speculate whether the bias was actual or merely apparent, or whether the result would have been the same if the evidence had been impartially considered and the matter dispassionately decided [citations], but should reverse the judgment and remand the matter to a different [adjudicator] for a new [hearing] on all issues. [Citation.]" (Catchpole v. Brannon (1995) 36 Cal.App.4th 237, 247 [42 Cal.Rptr.2d 440], fn. omitted.) {Page 62 Cal.App.4th 724} In this case because of the vertical integration of the Judges of the San Diego County Superior Court, and that the judges routinely fail to follow state law, as verified by the Honorable Judge Salcido, then this case must not only be transferred to a new Judge for a hearing on all issues, it must be moved outside of the County of San Diego and allowed to move forward based upon the public good and to preserve the independent judiciary that has gone missing as confirmed by the Honorable Judge Salcido and the rights of the cognizable group that is similarly situated and that has a legal interest in the outcome and disposition of the Tadros vs. Doyne matter.
The facts contained in this case are clearly a public issue of great magnitude that the Superior Court of San Diego County in unison is attempting to protect, when it has been aware of the law and the California Rules of Court through its executive powers and possession of the judges bench book. This court cannot cause to protect that there was a complete judicial failure in adhering to the rule of law, which gave it no subject matter jurisdiction.
We swear and affirm that the foregoing is true and correct under the penalty of perjury and under the laws of the State of California. We have read and understand the foregoing and are unanimous in our requests for a change of venue to a fair and impartial trier of fact. We have read the verified petition and agree with it contents, on every clause, sentence and paragraph.
WE HAVE SIGNED THE FOLLOWING PETITION, AND ENCLOSED ARE FAXED SIGNATURES OR ORIGINAL SIGNATURES. IT SHOULD BE NOTED THAT ALL FAXED ORIGINAL SIGNATURES ARE AVAILAIBLE UPON REQUEST AS WELL AS ALL ADDRESSES FOR THE CITIZENS HEREIN THAT ARE AVALIABLE UPON REQUEST IF NOT SUPPLIED HEREIN. WE ARE ALL READY, WILLING AND ABLE TO TESTIFY TO THE FACTS SUBMITTED HEREIN FOR SUPPORT OF A CHANGE OF VENUE.
We swear and affirm that the foregoing is true and correct under the penalty of perjury and under the laws of the State of California. We have read and understand the foregoing and are unanimous in our requests for a change of venue to an impartial county where this case can move forward in the name of the public good. SIGNATURES NEXT PAGE

The undersigned I support a change of venue in this case and am appalled that as a member of the public this court ignored the reasonable person standard by striking its own disqualification motion: I am a resident of the City of ________________, State of California, signed on _____________________.

Print Name:_______________________________
Sign Name: _________________________
Address: _____________________________City:___________________ CA Zip: __________

The undersigned I support a change of venue in this case and am appalled that as a member of the public this court ignored the reasonable person standard by striking its own disqualification motion: I am a resident of the City of ________________, State of California, signed on _____________________.

Print Name:_______________________________
Sign Name: _________________________
Address: _____________________________City:___________________ CA Zip: __________

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