Plaintiff’s Statement of Undisputed Material Facts (SUFs)

For the Motion for Summary Judgement, I had to resubmit the evidence that I had already submitted in a different format. This format is easier to understand and follow. While it was tedious to put together, this format makes the evidence damning. FTB’s assorted schemes and the mechanisms of how the schemes are perpetrated are obvious, so hopefully other people can use the SUFs as a guide to find the fraud in their own records.

Unfortunately, I forgot to attach an exhibit list when I submitted it. The judge threw out all of the evidence because of no exhibit list, and I lost my case because the case didn’t stand without evidence. I asked if I could submit an exhibit list. The judge said no. I asked if I could use FTB’s evidence, as most of my evidence was the same as FTB’s. The judge said no.

Highlights of Key Information in Plaintiff’s Statement of Undisputed Material Facts (SUF)

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My Opposition to FTB’s Motion for Sanctions Dated 09-01-2021 and My Request for Sanctions

On September 1, 2021, FTB filed a Motion for Sanctions against me in a blatant attack of retaliation, harassment and obstruction of justice.

On March 7, 2021, I filed my Opposition to their Motion for Sanctions and my own request for sanctions against FTB for:

  • Violation of Code Civ. Proc., §128.5 and §128.7(b): Motion is Frivolous (page 30)
  • Violation of CA Rules of the Court 1.201: Failure to Redact Personal Information (page 32)
  • Violation of CRC 3.1348: Failure to Provide Discovery (page 39)
  • Chelsea Hubbard: Perjury, Withholding Evidence and Improper Redactions (page 40) 
  • Keith Swank: Perjury and Failure to Furnish Information (page 53)
  • Grace LeBleu: False Statements and Improper Redactions (page 59) 
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Bar Complaint Filed Against Deputy Attorney General Anna Barsegyan

On December 19, 2022, I filed a Bar Complaint against against Deputy Attorney General Anna Barsegyan where I requested that she be disbarred. Here is a quick summary of the most egregious of the allegations in the Bar Complaint. The evidence that I included to substantiate the allegations was the second Federal Criminal Complaint that I filed against her, all the evidence for the FCC, and the DOJ email chain.

I believe that Anna Barsegyan crossed the line from representing her client into actively participating in her client’s criminal cover-up. To accomplish this cover up, she used an assortment of unlawful tactics, including Harassment, Retaliation, Violation of Rights, Abuse of the Court System, and Obstruction of Justice. In doing so, she repeatedly violated the American Bar Association rules 8.4 (a), (c) and (g).

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Ten (10) Requests for 2021 Annual Taxpayer Bill of Rights Meeting

This year’s Franchise Tax Board Annual Taxpayers Bill of Rights Meeting was held online on Thursday, December 2, 2021. Here is the five-minute speech that I made.

The full video of the 1+ hour meeting is here.

FTB prefers, but does not require, that you submit the requests in writing prior to the meeting so they know what to expect. There is no limit to how long a written submission can be, so my written submission was much longer and more detailed than the speech was.

Written Version of the ATBOR Requests

November 30, 2021

Franchise Tax Board Taxpayer Advocate Office

Email: FTBAdvocate@ftb.ca.gov

Fax: (916) 843-8330

Re: Ten (10) Requests for Annual Taxpayer Bill of Rights Meeting

Hello Taxpayer Advocate Staff: 

Here are my ten (10) requests for the 2021 Annual Taxpayer Bill of Rights Meeting.

  1. Close the Loophole That Allows FTB To Evade Due Process for Implementation of Collection Tools

Require that FTB appear before a Superior Court judge to procure a proper judgment in accordance with the laws of the State of California prior to implementation of Collection tools, including wage garnishments, levies and liens. Please see email dated October 23, 2021 for details. 

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How FTB Covers Up Their Accounting Irregularities

As you all know, I filed a Motion to Compel on Specially Prepared Interrogatories, Set #1: Clarification of Policy and Procedure. I also prepared a second set of Interrogatories to address FTB’s accounting irregularities.

And I prepared a set of documents called “Requests for Admissions” to help clarify the methods that FTB uses to cover up the assorted policy/procedure and accounting irregularities that were addressed in the Interrogatories. Here are the questions. Many of the questions refer to attached documents. Here are documents pages 1 – 18 and 19 – 35.

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FTB Is Retaliatory Harassing Me

On Sunday, August 29, 2021, I attempted to file a police report with the San Diego Police Department against two FTB staff for overcharging me interest, which is the crime of fraud. Here is the proof of fraud by Alexis Bear and by Carrey Burton-Beilby. FYI, a police report is an important first step in getting a grand jury investigation launched. As a side note, I later found out that the right venue is the FBI’s website, and I did file reports against Bear and Burton-Beilby with the FBI.

On Monday, August 30, 2021, Deputy Attorney-General Anna Barsgeyan, who is FTB’s attorney for the civil case that is pending in San Diego Superior Court, made a reservation for a Motions for Sanctions hearing in our civil case. On Wednesday, September 1, 2021, she filed her Motion, requesting that the judge stop me from gathering evidence for my federal criminal complaint and that he penalize me $8,000 as a punishment for gathering the evidence that I did. She also posted my and my husband’s full social security numbers on a public website.

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The Playbook That Government Agencies Use To Get Away With Criminal Schemes

I watched a video about a woman in Arizona (AZ) who had her children stolen by Child Protective Services (CPS).

As I watched the video, my jaw dropped as I realized that CPS in AZ used strikingly similar tactics to violate the laws as the Franchise Tax Board (FTB) in California (CA) used against me. It can’t be a coincidence that my experience was so similar to hers when it was a completely different issue, involving a completely different agency, with completely different circumstances. 

I am starting to realize that there must be a playbook of tactics that government agencies use to extract extra revenue for themselves. Obviously, the specific tactics are customized by the agencies, but the general playbook appears to be identical: 1. Lay a trap, 2. Deny due process 3. Rig the justice system and 4. Have other government agencies cover it up.

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Proof of Accounting Irregularities

As you all know, I filed a Motion to Compel on Specially Prepared Interrogatories, Set #1: Clarification of Policy and Procedure.

I also prepared and submitted to a second set of interrogatories to FTB, called Specially Prepared Interrogatories, Set #2: Accounting Irregularities. Here are the questions. Many of the questions refer to the attached evidence, and specify which page of evidence to look at. Here are evidence pages 1 – 18 and pages 19 – 36.

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My Second Motion to Compel: Clarification of FTB Policies and Procedures

*Note: This post is in the middle of being reformatted. Please excuse the odd appearance.

In this Motion to Compel, I prove that FTB committed 8 counts of perjury: three counts by Chelsea Hubbard and five counts by Keith Swank. I also laid out in detail why it appears that obfuscation and conflicting information about FTB’s policies and the laws on which these policies and procedures are based is because FTB knows these policies and procedures are unlawful. Here are pages 1 – 18, 19 – 36, 37 – 54, and 55 – 72.

The last paragraph of page 3, all of pages 4, 5 and 6, and the first paragraph of page 7 are important to read in full because they contain the overview of the assorted questionable business practices that are detailed in the rest of the document. I did not highlight those pages because every word would be highlighted! The rest of the document is repetitive and tedious, so I have highlighted the important stuff for you.

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Attorney General Lied to the Judge in Our Hearing!

The blog has been quiet lately because I’ve been so busy with the case that I haven’t had time to update the blog. On Monday, May 24, 2021, I filed another Motion to Compel Further Information, this time on Specially Prepared Interrogatories #001: Clarification of FTB’s Policies and Procedures. The Motion + exhibits was 495 pages. It’ll take me a long time to redact and upload them all, but I will get it uploaded eventually.

On May 28, 2021, there was a hearing on my first Motion to Compel Further Information for Additional Documents. In FTB’s Opposition to Motion that they filed with the court, Deputy Attorney General Anna Barsegyan made numerous deceptive and several outright false statements to the judge!

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