Robert Hurford Hale, Sui Juris

3243 Congressional Circle

Fairfield 94534

CALIFORNIA, USA

tel: 707-426-1841

In Propria Persona

Superior Court of California

Solano County

REDWOOD PLAZA INVESTMENTS, L.P., ) Case No. FCS025327

)

) ASSIGNED FOR ALL PURPOSES TO

v. ) JUDGE SCOTT L. KAYS

) DEPARTMENT 16

)

) FILED AND SERVED UNDER PROTEST

) PURSUANT TO SPECIFIC AUTHORITIES:

PGM, INC., ) 18 U.S.C. 4 et seq.;

PETER G. MOZSARY, ) 28 U.S.C. 1746; Supremacy Clause;

ROBERT H. HALE, and ) California Business and

DOES 1 through 10. ) Professions Code, secs. 6067-6128;

) 18 U.S.C. 1341, 1964 (Civil RICO);

_________________________________) and Penal Code section 182:

)

) DEFENDANT HALE’S FIRST VERIFIED

) CRIMINAL COMPLAINT, ON INFORMATION

)

) TRIAL DATE: November 4, 2005

COMES NOW Robert H. Hale, Sui Juris, a named Defendant in the above entitled case, without waiving or conferring any jurisdiction, specifically to request that this honorable Court take mandatory judicial notice of this, DEFENDANT HALE’S VERIFIED CRIMINAL COMPLAINT, ON INFORMATION, charging the following named individuals with the corresponding criminal violations enumerated infra.

Appearing herein under protest and without prejudice to any of his Rights, Defendant Hale hereby formally charges:

Scott Lewis Kays formerly dba State Bar Number (“SBN”) #71440 with:

commission of a misdemeanor by the unauthorized practice of law and by failing to indorse and failing to exhibit the Certificate of Oath that is required to be indorsed upon a license to practice law in the State of California by sections 6067 and 6068 of the California Business and Professions Code, in violation of section 6126 of same (two counts), and in a manner that constitutes fraudulent concealment for which there is no statute of limitations;

commission of a misdemeanor by consenting to collusion with others charged herein, and deceit with the intent to deceive a Party, by failing to support the Constitution and all other laws of the United States and of the State of California, by employing means that are not consistent with the truth, and by seeking to mislead a judicial officer by an artifice or false statement of fact or law, in violation of sections 6068 and 6128 of the California Business and Professions Code (two or more counts), and in a manner that constitutes fraudulent concealment for which there is no statute of limitations; and,

commission of a misdemeanor by conspiring with others charged herein (1) to commit all of the crimes enumerated above, (2) to cheat and defraud a Person of property by means which are in themselves criminal, and to obtain money or property by false pretenses, and (3) to pervert and obstruct justice and the due administration of the laws, all in violation of California Penal Code section 182 (one or more counts), and in a manner that constitutes fraudulent concealment for which there is no statute of limitations.

George Milton Carpenter dba State Bar Number (“SBN”) #205165 with:

commission of a felony by placing in a post office, or in an authorized depository for mail, matter to be sent and delivered by the Postal Service, for the purposes of executing a scheme or artifice to defraud, and of obtaining money by means of false and fraudulent pretenses, representations or promises, after having devised or intended to devise said scheme or artifice to defraud and to obtain money by means of false and fraudulent pretenses, representations or promises, in violation of 18 U.S.C. 1341 (two or more counts);

commission of a felony by conspiring to engage in a pattern of racketeering activity as a direct result of committing two or more of the predicate acts itemized supra and at 18 U.S.C. 1961 during the preceding ten (10) calendar years, in violation of 18 U.S.C. 1962 (one or more counts);

commission of a misdemeanor by consenting to collusion and deceit with the intent to deceive a court and Party, by failing to support the Constitution and all other laws of the United States and of the State of California, by employing means that are not consistent with the truth, and by seeking to mislead a judge or other judicial officer by an artifice or false statement of fact or law, in violation of sections 6068 and 6128 of the California Business and Professions Code (two or more counts); and,

commission of a felony by conspiring with others also charged herein (1) to commit all of the crimes enumerated above, (2) to cheat and defraud a Person of property by means which are in themselves criminal, and to obtain money or property by false pretenses, and (3) to pervert and obstruct justice and the due administration of the laws, all in violation of California Penal Code section 182 (one or more counts).

Michael Joseph Cook dba State Bar Number (“SBN”) #131200 with:

Kirk Edward Giberson dba State Bar Number (“SBN”) #125155 with:

Howard Scott Nevins dba State Bar Number (“SBN”) #119366 with:

Ronald Hubert Sargis dba State Bar Number (“SBN”) #105173 with:

Martin B. Steiner dba State Bar Number (“SBN”) #109437 with:

Kenneth R. Stone dba State Bar Number (“SBN”) #67717 with:

Timothy Dale Taron dba State Bar Number (“SBN”) #72890 with:

Michael Robert Williams dba State Bar Number (“SBN”) #186079 with:

Angelo K. Tsakopoulos with:

commission of a felony by conspiring with others charged herein (1) to commit all of the crimes enumerated above, (2) to cheat and defraud a Person of property by means which are in themselves criminal, and to obtain money or property by false pretenses, and (3) to pervert and obstruct justice and the due administration of the laws, all in violation of California Penal Code section 182 (one or more counts); and,

commission of a felony by conspiring to engage in a pattern of racketeering activity as a direct result of conspiring with others charged herein to commit two or more of the predicate acts itemized supra and at 18 U.S.C. 1961 during the preceding ten (10) calendar years, in violation of 18 U.S.C. 1962 (one or more counts).

INCORPORATION OF EVIDENCE

Defendant Hale hereby incorporates by reference the entire contents of the Clerks’ dockets in the instant case, in the District Court of the United States (“DCUS”) for the Eastern Judicial District of California (Sacramento) #CIV. S-01-1480 WBS DAD PS, in the United States Court of Appeals for the Ninth Circuit #02-15269 and #02-89005, in U.S. Supreme Court #03-5070, and in San Diego Superior Court #GIC807057, as if all such contents were set forth fully here, with particular emphasis on the outstanding and lawful SUBPOENAs previously issued to Kirk Edward Giberson and to The State Bar of California; see also the following Internet resources, to conserve paper:

(PAST DUE) http://www.supremelaw.org/cc/kays/nad.oath.htm

http://www.supremelaw.org/cc/kays/executive.officer.htm

(PAST DUE) http://www.supremelaw.org/cc/statebar/

http://www.supremelaw.org/counsels.htm

http://www.supremelaw.org/rsrc/commissions/index.htm

http://www.supremelaw.org/cc/aol/index.htm

http://www.supremelaw.org/cc/aol2/index.htm

Pursuant to section 453 of the Evidence Code, mandatory judicial notice of all above Internet URLs is respectfully requested hereby. Defendant Hale offers to supply, at cost, printed hard copies of any documents listed above, upon receipt of written request for same.

AFFIDAVIT OF PROBABLE CAUSE

Defendant Hale now testifies that all certified evidentiary documents incorporated supra are true and correct, and that they do constitute probable cause formally to charge the above named individuals with the corresponding criminal violations enumerated supra.

STATEMENT OF ORIGINAL JURISDICTION

The Superior Court of California enjoys original jurisdiction pursuant to the civil RICO remedies at 18 U.S.C. 1964, and the holdings of the U.S. Supreme Court in Tafflin v. Levitt, 493 U.S. 455 (1990), and the U.S. Court of Appeals for the Ninth Circuit in Lou v. Belzberg, 834 F.2d 730, hn. 4 (9^th Cir. 1987) (California State courts have concurrent original jurisdiction of civil RICO claims).

See also Rotella v. Wood et al., 528 U.S. 549 (2000) (object of civil RICO is to turn RICO victims into prosecutors dedicated to eliminating racketeering activity) and Agency Holding Corp. v. Malley-Duff & Associates, 483 U.S. 143, 151 (1987) (RICO laws bring to bear the pressure of “private attorneys general” on a serious national problem for which public prosecutorial resources are deemed inadequate; the mechanism chosen by Congress to reach the objective in RICO cases is the carrot of treble damages).

Please note that the liberal construction rule for RICO statutes was never codified anywhere in Title 18 of the United States Code, however, even though Title 18 supra has been enacted into positive law by Act of Congress. See 84 Stat. 947, Sec. 904, October 15, 1970.

VERIFICATION

I, Robert Hurford Hale, Sui Juris, named Defendant in the above entitled action, hereby verify under penalty of perjury, under the laws of the United States of America, without the “United States” (federal government), that the above statement of facts and laws is true and correct, according to the best of My current information, knowledge, and belief, so help me God, pursuant to 28 U.S.C. 1746(1) (Constitution, Laws and Treaties of the United States are supreme Law of the Land, notwithstanding anything in the Constitutions or Laws of California to the contrary. See Supremacy Clause.)

Dated: August ____, 2005

Signed:

___________________________________________

Printed: Robert Hurford Hale, Sui Juris

Court: Solano County Superior Court

Case No. # FCS025327

Case Name: Redwood Plaza Investments, L.P. v. PGM, INC., Peter Mozsary, and Robert Hurford Hale

PROOF OF SERVICE

I am a resident of Solano County. I am employed at 2801 Waterman Blvd., Suite 240, in Fairfield 94533, CALIFORNIA, USA. I am over the age of 18 and not a party to the above–entitled action. I served the following document(s):

DEFENDANT HALE’S FIRST VERIFIED

CRIMINAL COMPLAINT, ON INFORMATION:

18 U.S.C. 4 et seq.;

28 U.S.C. 1746; Supremacy Clause;

California Business and

Professions Code, secs. 6067-6128;

18 U.S.C. 1341, 1964 (Civil RICO);

and Penal Code section 182:

by sealing one true and correct copy of said document(s) with postage prepaid, properly addressed and mailed at the United States Postal Service in Fairfield, California

[ ] by first class mail

[ ] by certified mail

[ ] by Registered Mail

to the following recipient(s):

[PLAINTIFF’S UNLICENSED ATTORNEY] [PLAINTIFF’S REGISTERED AGENT]

Mr. Kirk E. Giberson Angelo K. Tsakopoulos

Hefner Stark & Marios Agent for Service of Process

2150 River Plaza Dr. #450 7700 College Town Dr., Ste. 101

Sacramento 95833 Sacramento 95826

CALIFORNIA, USA CALIFORNIA, USA

Scott Lewis Kays Hand Delivered to:

c/o Clerk of Court Clerk of Court

600 Union Avenue 600 W. Texas Street

Fairfield 94533 Fairfield, 94533

CALIFORNIA, USA CALIFORNIA, USA

I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct and that this document was executed on:

Date: Aug. ___, 2005 Signed:

_______________________________________________

Printed: Kim Beasley