Motion_to_assistance_obtaining_indigent_defenseMotionCal. Super. - 4th Dist.July 11, 2018Jeffrey Howerton, Pro Se ELECTRONICALLY FILED Superior Court of California, County of San Diego 2756 Rambling Vista Road 031472019 =t 05-30-00 Ad Clerk of the Superior Court Chula Vista, CA 9191 By ‘anessa Bahena, Deputy Clerk jeffrey.howerton@gmail.com SUPERIOR COURT IN THE STATE OF CALIFORNIA IN THE COUNTY OF SAN DIEGO Younomics Private Student Loan Trust, Case No. 37-2018-00034250-CU-CL-CTL Plaintiff VS Jeffrey Howerton, Defendant Howerton’s Motion for Assistance Obtaining Indigent Defense I. Howerton’s Motion for Indigent Defense I was not informed my fee waiver was filed and accepted until recently. I have made points in my prior motions I believe important to my case but lack legal expertise to do so in my best interest by referencing relevant authority. I do not want to be a burden to the court but also believe it is in my best interest to request indigent defense for this case and connected issues concerning One Legal. I also cannot afford to ancillary costs of filing not included in court fees such as paperwork, time, or anything else related to case. Not only is Rachael Kierych and Younomics not observing fair debt collection laws, but it is important to consider that I disputed these loans and had them removed from my credit score prior to Younomics even existing and issues from initial loan holders MyRichUncle and Doral Financial are apart of this. If the court does not accept my motions to dismiss based on my own arguments then I would like them to be rearticulated referencing proper authority but also expanding scope of defense with legal expertise and knowledge. However, I also believe that I have been severely harmed by Younomics not observing fair debt collection practices and initiating this case and harms stem from prior companies also. I need assistance in quantifying time, toll and damages. I have questions I do not know the answer to, for example, I was in a CAL BAR complaint concerning Rachael Kierych prior to her initiating lawsuit and reference case at Florida Middle Bankruptcy Court, Ciprian-Escapa v. Younomics 6:16-ap-00110 and she does not mention this. She is also currently in other court cases and such as at Santa Clara Superior Court, Younomics Private Student Loan Trust vs Samuel Osazuwa and I do not know if there are patterns where predatory lending practices from My Rich Uncle, failure to observe fair debt collection laws are being compensated by Rachael Kierych and Younomics by engaging in predatory lawsuits and if there are also class action issues. I do not know how many of Younomics loan holders are from Brown University and loans also stem from MRU Holdings but I believe I could be discriminated against because they were informed of my circumstance in multiple complaints I have made and although they are not referenced in Younomics pleading I reference issues related to race, class, sexual orientation, medical issues etc. There are other cases connected to prior loan holder MRU Holdings such as at New York Southern District Court, In Re: MRU Holdings Securities Litigation, Case No. 1:09-cv-03807 and at New York Southern Bankruptcy Court, Gazes, as Ch. 7 Trustee for MRU Holdings, Inc. v. Bushley, 1:11-ap-01431. As stated, while I had disputed and removed these loans there issues still relevant to this case but I lack legal expertise to articulate argument citing legal precedent with table of authority and concerned this would be dismissed due to this as opposed to my logic lacking merit. . Furthermore, I have questions concerning groups involved in legal matters that prior I believe were connected to both theft of ip such as Copyright PAu003565217 but also targeting of my student loans such as the Weinstein Company. They are now in bankruptcy also with case at Delaware District Court, In Re: The Weinstein Company Holdings LLC, et al, Case No. 1:19-cv-00242 and do not know if there are implications. I reference there are what I believe are connected legal matters and investigations and I do not know what the impact are on my loans, servicing and now this legal case or my legal options. Beyond the New York DA which implicates the San Diego DA, there are matters connected to my tax returns at IRS and New York Department of Taxation and Finance with Deborah Liebman of the latter informing me there was an investigation. If Younomics is reporting my loans to these groups then there are issues that overlap also. I have reported issues regarding Younomics to the Chula Vista Police Department, Santa Barbara Police Department, Clovis Police Department, Clovis Unified School District (where Jon Howerton employed and there is also a police department and Lompoc Police Department. Some involved in prior internal investigations at Chula Vista PD are no longer employed there such as Officer Lon Turner who likely maintained status as confidential employee for federal groups also but was apart of 17-0008 handled by Don Redmond and Miriam Byron regarding the New York DA flying across the country and then those records disappearing and instance where Mike and Yasmine Howerton lied and 5150°d me with PERT and the Chula Vista PD. I believe there are connected cases like at Superior Court of San Diego, Carlsbad Police Officers Association et al, v. City of Carlsbad Et al case no. 37-2019-00005450-CU-WM-CTL as it relates to disclosure of internal complaints police records pre 2019. Furthermore, there have been connected investigations such as those related to SARMS and Peptides such as North Carolina Western District Court, USA v. Marsala et al, Case No. 3:14-cr-00209 which connected to website Osta Gain/Spectrum Peptides where they sent me suspicious emails and also at Ninth Circuit U.S. Court of Appeals, Nutrition Distribution LLC v. IronMag Labs, LLC, et al, Case No. 0:19-cv-55251 or at regarding criminalization of gay people through website Rent Boy such as in Eastern District Court of New York such as United States of America, v. Jeffrey Hurant, Case No. 16-CR-45. These are groups where I have received emails during this time and there would be overlap in any discovery. The reason being is that if there are open discoveries related to proxy investigations, then it is likely I have been harmed by misuse of their open discoveries and targeting groups where I have an account in my name without considering that I have disputed and removed these loans from my credit score and also these proxy investigations used to interfere in the handling of my account servicing. Lastly I do not know if the there is a connection to my loans at US Department of Education. Just before Y ounomics sent me a request to validate my loans that I already removed, I consolidate my US Department of Education loans and now Nelnet is the holder from Account Control Technology and have yet to hear back on my borrower’s economic defense discharge. However, there were cases | believe connected such as at Third Circuit U.S. Court of Appeals, Consumer Financial Protection v. Heartland Campus Solutions ECS Case no. 0:18-cv-01516, or at United States District Court of Nebraska, Jessica Olsen v Nelnet, Case No. 4:18-cv-03081 and also consolidated case in United States Court of Federal Claims, FMS Investment Corp et al, v. United States of America and Performant Recovery, et all, Case No. 1:18-cv-00204-TCW I have had issues with other loan servicers regarding compromised service but they are through the US Department of Education. The lawsuits connect my US Department of Education loans because Account Control Technology and Transworld Systems were apart of the last case. Even though Rachael Kierych and Younomics do not reference University Accounting Service and Transworld System the case stems not long after I consolidated to Nelnet and believe stemming from groups using as a proxy to maintain favorable legal paradigms connected to ip theft. I do not know how interconnected discoveries work. Lastly, I do not know if prior legal cases I have had such as at New York Civil Court, Robert Halpern v. Jeffrey Howerton, Case No. CV-27186-13/NY an issue. I filed a NY Ist Judicial Attorney Grievance complaint after this attorney who initiated a case regarding a fee dispute, then later had his emails seemingly phished and hijacked and it seemed he did not know who I was when he responded which I felt reflective of other groups who are in fact monitoring my matters and able to intervene but it appears as if people involved in open discoveries and government investigations are doing so and would like to know what my legal options are if this true here. II. Request for Assistance Retaining Legal Aid Society of San Diego as Indigent Defense I have contacted Volunteer Lawyers of San Diego but have had issues and made CALBAR complaint and AZ Bar complaint concerning Amy Fitzpatrick. However, I would like to propose Legal Aid Society of San Diego (LASSD) because I have overlapping legal matters. I have contacted them regarding this case without response. However, they are the patient advocate and assisted me when Mike and Yasmine Howerton lied to 5150 me and I had a writ of habeus corpus with Sharp Hospital and Vladimir Khalafian. They put me in contact with Mark Saverino of Family Health Centers of San Diego. By appearances he did not take favor with Mike or Yasmine Howerton (him meeting the latter) who is I believe severely abusing me while maintaining open discovery however after Mark Saverino left and transferred to Psychiatric Centers without explanation. I have CAL BAR complaint concerning Gregory Knoll and Daniel Besnson of LASSD. I contacted Volunteer Legal Services of San Diego and LASSD regarding this case but did not hear back but recently James Ruff of LASSD contacted me with grievance forms I need to fill out to make complaints concerning the Community Research Foundation’s PERT team and will also include Telecare, Sharp Hospital, Jewish Family Service of San Diego and the County of San Diego, NAMI San Diego. I need assistance contacting prior defense Alejandro Balvaneda of the County of San Diego Public Defender who represented me during my writ of habeus corpus but would not provide me information related to case and I had to make a CAL BAR complaint it appeared his County of San Diego email hijacked and communications were fraudulent also. In situation where family members are I believe maintaining open discoveries and torturing me, I am in a situation where they have been able to lie to abuse the mental health system including conveying a narrative that I have a history of mental health issues when really it is the other way around but the Community Research Foundation and Chula Vista PD have severely discriminated against me and provided them bias and favor and I live in a abusive home environment under threat of further abuse from family. I need legal assistance and would be helpful to maintain same legal team as the Patient Advocate because I have experienced severe corruption and abuse of the mental health system in San Diego County. I do not know what my options are to protect myself from abuse from family members but the circumstance has greatly added to the difficulty of this case. Furthermore, I have never been in a discovery, but I have contacted the USPTO referral service because I have invented a discovery process which includes inputting emails and message id obtained from raw data or other identifiers linked with groups in connected investigations such as (@nsa.gov into email drafts which allows for a 24/7 process that I have only experienced via groups involved in open discoveries connected to my account severely manipulating me. Meaning it is made obvious, that there is a connection to my email account and the behaviors stemming from those involved torturing me in open discoveries where I am being denied and deprived information. I believe it is an intentional means of fraud that I believe connects to ‘investigative process’ but the process I invented still valid and has major implications. It includes limits imposed on my accounts that inhibit and suppress communication. Meaning, I am being severely isolated and it affects my ability to obtain counsel. I also need to renew my copyright that I made in Joyce Howerton’s name placed in my own name. The open discoveries linked to Library of Congress and U.S Copyright Office I believe and those targeting seek to deny that i have made it and some of their plans revolved around wasting time to take advantage of my poverty, degrade my life and let expire in 2020 and infringe as if they were not aware that I made this copyright. Any project would expand beyond this including ownership but I believe there are implications to my current situation from groups involved in open discoveries. It has caused severe harm. There are also historical cases that overlap with copyright such as at Court of Appeals of California, Second District County of San Luis Obispo et al v. The Abalone Alliance et al. Case Nos. B006572, B008233. The USPTO put me in contact with California Lawyers for the Arts but I have yet to hear back from the IRS that has processed my forms to obtain legal help. These are overlapping matters and due to the connection between Younomics and my taxes any assistance with any overlapping legal help would be greatly appreciated. I have sent multiple form 911s to the IRS and New York Department of Taxation and Finance department to resolve connected issues but they never responded but once again even though I removed these loans they are likely still reporting them to the IRS and New York Department of Taxation and Finance. I have yet to fill the grievance form that James Ruff of LASSD provided me, but I am requesting assistance from the court in contacting LASSD on my behalf to assist in my defense of this case because my prior communications regarding this case ignored sent via their website. Dated this 13th day of March, 2019. pz Respectfully submitted, Jeffrey Howerton Defendant, Pro Se 2756 Rambling Vista Rd Chula Vista, CA 91915 jeffrey.howerton@gmail.com
