COURT DOCUMENTS*
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mAY
14, 2012
gOLINS
FILE SECOND AMENDED COMPLAINT
mARCH
23, 2012
jUDGE
fREEMAN GRANTS PLAINTIFFS MOTION TO DEEM THE CASE COMPLEX AND TRANSFER IT TO
THE COMPLEX CASE DIVISION
pLAINTIFFS CAN NOW HAVE A
SINGLE JUDGE FOR ALL PURPOSES, JUDGE MARIE WEINER
MARCH
8, 2012
jUDGE
mIRAM GRANTS GOLINS’ MOTION FOR APPOINTMENT OF THEIR APPLICANT FOR GUARDIAN AD
LITEM, NANCY DELANEY FOR NANCY GOLIN.
NANCY IS NOW OFFICIALLY IN THE CASE AFTER SIX YEARS OF OBSTRUCTION BY
DEFENDANTS TO KEEP HER OUT OF THE CASE
nO MORE NONSENSE ABOUT THE DEFENDANTS REPRESENTING
A PLAINTIFF, NANCY GOLIN
June
2, 2011
visiting Judge robert baysinger grants golins’
motion to transfer venue from santa clara county to
san mateo county, a neutral venue.
Motion was pending since 2007
nOVEMBER
30, 2010
DISMISSAL
of golins’ civil suit REVERSED ON APPEAL
IN CURRENT State ACTION!!
In a stunning reversal,
the Golins have revived their civil suit and restored their access to the trial
court!
Despite the confusion and
noise generated by the State defendants for seven years, the Court of Appeal
agreed that there was more likely than not to be merit to their case, and now
the case may move forward again, despite three years of 
languishing in the
appeals court.
Mr.
David J. Beauvais argued successfully for the family on November 18, 2010.
Golin
v. Allenby,
Sixth District Court of Appeal (No. H032619),
appeal from dismissal of state civil lawsuit on purported
“vexatious litigant” determination grounds and failure to pay $500,000 bond,
filed 2/21/08.
·
Appellants’
Opening Brief, filed September 15, 2008, by attorney David J. Beauvais,
Esq. 2008 WL 5012017
·
Appellant’s Reply Brief, filed February 6,
2009, by attorney David J. Beauvais, Esq. 2009 WL 491783
____________________________________________________________________________________________________________________________________________________
Golin v.
Allenby, et al, Civil Lawsuit for
damages and injunctive relief, Sacramento County Superior Court, , Represented by Gerard W. Wallace, Esq
SACRAMENTO
COUNTY SUPERIOR COURT: (Case No. 06-AS-01743, filed April 26, 2006)
·
Amended Complaint for damages and Injunctive Relief, filed
August 22, 2006.
·
Application of Jeffrey Golin to Appoint Elsie Y. Golin as
guardian ad litem for Nancy
Golin (approved by Judge Michael P. Kenney, August 18, 2006)
·
Opposition to County Motion to Change Venue (to Santa Clara
County), filed September 8, 2006
·
Motion to Reconsider Change of Venue, filed September 18,
2006
·
Declaration of Jeffrey Golin in Support of Motion to Reconsider
Change of Venue, filed September 18, 2006
· Declaration of John R. Lehman, in support of grant of Guardian Ad Litem powers, September 8, 2006
________________________________________________________________________________________________________________________________________________________
SANTA
CLARA COUNTY SUPERIOR COURT (Transferred
April 2007, case No. 1-07-cv-082823)
·
Motion
for Change of Venue, filed June 6, 2007.
·
Motion to Reconsider Guardian Ad
Litem, filed June 8, 2007
·
Amended
Memorandum of Points and Authorities in Support of Motion to Reconsider,
filed June 11, 2007.
·
Memorandum
of Points and Authorities in Opposition to Demurrers, Filed May, 21, 2007.
·
Objection to Taking of Judicial Notice, filed May 22, 2007.
·
Motion
of Claudia Johnson to be relieved as GAL, granted June 8, 2007
·
Challenge of
Judge Kevin Murphy, June 5, 2007.
Santa Clara County Superior Court civil lawsuit Case No. 1-07-cv-082823)
(Recused)
·
Verified
Challenge of Judge Eugene Hyman, Santa Clara County Superior Court civil
lawsuit Case No. 1-07-cv-082823) June 15, 2007. (Jeffrey
Golin)
·
Challenge
of Judge Neal A. Cabrinha, July 10, 2007 Santa
Clara County Superior Court civil lawsuit Case No. 1-07-cv-082823) (denied) (Jeffrey Golin)
·
Order of
Judge Neal A. Cabrinha August 8, 2007, declaring
bench recusal of entire Santa Clara County Court, and appointing visiting Judge
Thomas P. Breen by appointment of Judicial Counsel.
·
Supplemental Memorandum of Points and Authorities in Opposition
to County Demurrers
·
Second Supplemental Memorandum of Points and Authorities in
Opposition to County Demurrer
·
Motion to Reconsider Plaintiffs’ Denied Motion to Change Venue
·
Plaintiffs’ First Opposition Brief to Stanford Demurrer, Filed
September 10, 2007
·
Plaintiffs’ First Amended Opposition Brief to Stanford Demurrer,
Filed September 12, 2007
·
Plaintiffs’
Second Amended Opposition Brief to Stanford Demurrer, Filed September 14,
2007
·
Challenge
of Judge Hon. Thomas P. Breen, September 17, 2007. Judge Breen initially refused to recuse
himself when challenged.
·
Notice
of Disqualification of Hon. Thomas P. Breen, September 18, 2007.
·
Petition
for Writ of Mandate of Hon. Thomas P. Breen, September 21, 2007. Judge Breen recused himself.
·
Renewed
Motion for Change of Venue, October 5, 2007.
·
Supplemental
Memorandum of Points and Authorities in Opposition to SARC’s Anti-SLAPP Motion,
filed October 5, 2007. SARC’s Motion to
strike Golins’ entire case fails as a matter of law, being filed seven months
too late.
·
Plaintiffs Opposition to
City of Palo Alto’s Motion for Vexatious Litigant Determination, with
Memorandum of Points and Authorities., filed November 5, 2007.
·
Declaration of Gerard
W. Wallace, Esq., filed November 5, 2007
·
Declaration of David
J. Beauvais, Esq., filed November 5, 2007
·
Declaration
of Jeffrey R. Golin, in pro per, filed November 5, 2007
·
Amended
Joint Memorandum of Points and Authorities in Support of Elsie Golin’s Motion
to Set Aside Void Orders of Removal or GAL (CCP
§473(d), Cal. Const. Art. VI §§4, 11) Filed November 11, 2007
·
Opposition
to SARC’s Motion to Strike, as a “Sham Pleading”, filed November 13, 2007
·
Plaintiffs
Reply Brief to Attorney General’s Opposition to Renotice
of Motion to Reconsider Guardian Ad Litem Appointment for Nancy Golin with
Memorandum of Points and Authorities. Filed
November 5, 2007.
·
Declaration
of Harry V. Martin (Newspaper Publisher of Napa Sentinel in Napa, CA) in
support of challenge of Judge J. Michael Byrne for Bias (unfiled, signed December
17, 2007.) (Based on this advice,
plaintiffs had concurred on the urgent necessity to peremptorily challenge
Judge Byrne upon conferring with attorney Beauvais on his return from Argentina
vacation.) (New.)
______________________________________________________________________________________________________________________________________________________
APPEAL ON WRIT OF MANDATE FROM
DENIAL OF GAL AND VENUE RETENTION
·
Petition
for Writ of Mandate, to Third District Court of Appeal, filed
November 13, 2006, denied November 20, 2006 (no opinion). (Case No. Case No. C054107). Appealing denial of
countermotion to retain venue in Sacramento County and revocation of guardian
ad litem.
·
Petition
for Review, to California Supreme Court, filed November 30, 2006, appealing
denial of writ of mandate of Third Circuit Court of Appeal. (Case
No. S148450).
·
Petitioner’s Reply Brief in Support of Review, in response to
San Andreas Regional Center’s Answer, filed December 20, 2006. California Supreme Court denied
petition for review on January 3, 2007, ten minutes before this
reply brief was delivered by UPS, denying parents’ right to rebut the arguments
of San Andreas against review. Was
denied by Chief Justice Ronald George, on his own.
·
Amicus
Letter of National Association to Stop Guardian Abuse (NASGA) in support of
review, filed with California Supreme Court, December 8, 2006.
·
Petition for Certiorari to U.S. Supreme Court, (Golin v.
Superior Court of Sacramento County) of interlocutory decision of Sacramento
Superior Court permitting the defendants in the civil lawsuit to challenge the
plaintiffs’ choice of guardian ad litem, filed May 21, 2007, U.S. Supreme
Court Case No. 06-1562. (pending)
·
Supplemental
Brief in Support of Petition for Certiorari, (U.S. Supreme Court
Case No. 06-1562) July 7,2007 (pending)
Golin et al v Allenby et al., Section
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1983(5) Civil
Rights Lawsuit, US District Court, Northern District of California, Judge William H. Alsup,
Case No. 03-cv-04791, dismissed March 23, 2004.
·
42 USC Sect. 1983, 1985 Civil Rights Complaint, Golin v. Allenby,
October 23, 2003, by Jeffrey Golin
__________________________________________________________________________________________________________________________________________
Golin et al
v Allenby et al.,
Section 1983(5) Civil Rights Lawsuit, Appeal in Ninth Circuit US Court of
Appeals
·
Appellants' Opening Brief, December 2, 2004, by Jeffrey
Golin. 2004 WL 3155788 (9th Cir.)
(Was on Westlaw but was not found now.)
·
Appellants' Reply Brief, February 22, 2005, by Jeffrey
Golin, (was lost by court).
·
Appellants’ Petition for Emergency Injunction, filed May 2,
2005, by Jeffrey Golin
·
Declaration of Donna Crowder, LVN, in Support of Petition for
Emergency Injunction, filed May 5, 2005
Memoriam---We were terribly saddened at the inestimable loss of Donna Crowder from Atwater, CA, who helped us in so many ways, died July 23, 2006 from a sudden recurrence of cancer, which overcame her in a very brief time, and we deeply grieve her loss. See article about Donna’s death. Her spirit, energy and dedication to taming recent oppressive incursions of overwhelming state authority into the family will live on however.
·
Declaration
of Elsie Golin, in Support of Petition for Emergency Injunction, filed May
11, 2005
·
Memorandum of
Disposition of three judge panel, affirming dismissal of District Court (Kleinfeld, Tashima, Thomas), June 22, 2005, (2005 WL
1475615 (9th Cir.(Cal.))
·
Petition for Rehearing En Banc, July 6, 2005, by Jeffrey Golin,
denied by same three judge panel without memorandum Kleinfeld, Tashima and Thomas,
August 15, 2005.
·
Memorandum of Additional Citations in Support of Rehearing En
Banc, July 13, 2005, by Jeffrey Golin.
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Golin et al v. Allenby et al, Section 1983(5) Civil Rights Lawsuit,
petition to United States Supreme Court, Case No. 05-791. Filed December 14, 2005, certiorari denied
March 27, 2006.
·
Petition for Writ of Certiorari to United States Supreme Court,
Golin v. Allenby, Docket No. 05-791, December 14, 2005, by Gerard
Wallace, Esq. (see, http://www.grandparentsrightslaw.com/gerardwallaceesq.html
) (Respondent County and Regional Center were granted 30 day continuance to
file Briefs in Opposition, and at last moment on February 22, 2006, decided to
file waivers rather than opposing briefs).
·
Supplemental Brief of
Petitioners, Golin v. Allenby, Docket No 05-791, filed February 22,
2006 (pending), by Gerard Wallace (citing intervening United
States v. Georgia, and “Tainted
Trials, Stolen Justice” Mercury News study of misconduct in Santa Clara
County Courts.
·
Petitioners’
Motion to Defer Decision, Golin v. Allenby, Docket No. 05-791, filed
March 6, 2006 (pending), by Gerard Wallace,
(parents suggest that Supreme Court defer decision until after Marshall v. Marshall (Anna Nicole Smith case) is decided,
due to convergence of issues and legal questions.)
·
Petitioners’ Second
Supplemental Brief, Golin v. Allenby,
Docket No. 05-791, submitted March 11, 2006
(pending) by Gerard Wallace, briefing by parents in response to Court’s request
on receipt of Motion to Defer, suggesting that the court consider opinion in
Marshall before deciding their case.
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Golin v. Allenby, Petition for
Certiorari to US Supreme Court from denial of writ of mandate to California
Supreme Court, No. 04-829 (cert. denied, 125 S.Ct. 1331 (2005))
·
Petition for Certiorari, filed May 23, 2004, by Jeffrey
Golin, 2004 WL 2967831
·
Supplemental Brief, filed January 24, 2005, by Jeffrey
Golin, 2004 WL 186120
===============================================================================================
Golin v.
Allenby, Petition for Certiorari to US Supreme Court for Appeal from denial
of Petition for Habeas Corpus in Ninth US Court of Appeal from denial of
Certificate of Appealability No 04-836 (cert.
denied, 125 S.Ct. 1332 (2005))
·
Petition for Certiorari, filed December 13, 2004, by Jeffrey
Golin, 2004 WL 2961083
·
Supplemental Brief, filed February
10, 2005, by Jeffrey Golin, 2004 WL
354070
·
Petition for
Rehearing, filed March 21, 2005,
by Jeffrey Golin
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In re Conservatorship of Nancy Golin,
papers filed in Santa Clara County Court in pretrial and post-trial motions,
Case No. 1-02-PR-151096.
·
Brief
in Support of Motion for Nonsuit, October 10, 2003 (during trial),
by Jeffrey Golin
·
Motion for Reconsideration for Motion for Nonsuit,
October 16, 2003 (during trial), by Jeffrey Golin
·
Post trial Affidavit of Objections to Statement
of Opinion and Motion for Rehearing
(denied), filed November 17, 2003, by Jeffrey Golin
·
Post trial Opposition to State Exparte
Motion in Support of Continued Conservatorship Pending, (denied) filed January 12, 2004, by Jeffrey Golin
·
Mother's Declaration regarding Nancy's History, by Elsie
Golin, filed March 4, 2003
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In re Conservatorship of Maria Luisa
Faustino in California Supreme Court (similarly situated case),
·
Appellate Decision Nov. 14,
2003 Sixth District Court of Appeals
·
Petition for
Review from denial of appeal in Sixth District Court of Appeals (denied), 2003 WL 23330773
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