33, I am De Jure, Zero tolerance for anything else: https://youtube/watch?v=zemrWBIc_hE Amendment XIV Section 1. All persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States and of the state wherein they reside. No state shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States; nor shall any state deprive any person of life, liberty, or property, without due process of law; nor deny to any person within its jurisdiction the equal protection of the laws. Section 2. Representatives shall be apportioned among the several states according to their respective numbers, counting the whole number of persons in each state, excluding Indians not taxed. But when the right to vote at any election for the choice of electors for President and Vice President of the United States, Representatives in Congress, the executive and judicial officers of a state, or the members of the legislature thereof, is denied to any of the male inhabitants of such state, being twenty-one years of age, and citizens of the United States, or in any way abridged, except for participation in rebellion, or other crime, the basis of representation therein shall be reduced in the proportion which the number of such male citizens shall bear to the whole number of male citizens twenty-one years of age in such state. ... Darren Robbins Robbins Geller Rudman & Dowd 655 West Broadway, Suite 1900 San Diego, Calif. 92101 joyb@rgrdlaw Re: Judge Quackenbush’s 05-25-12 Order - Discrimination Plumbers Union et al. v. Ambassadors Group, Inc. et al Mr. Robbins et al, I thank you and Ms. Bull for taking the risky move of illustrating before Judge Quackenbush the way the defense bar has dictated the removal of contract price obligations generally - and in class litigation specifically. This follows up on this little project of ours. The next time any judge “combines” to exact this kind of public and private damage on Lerach’s Robbins Geller or any other plaintiff’s firm, I suggest fronting this on record snippet by the defense bar’s David Noonan and his firm, verbatim: A. How do plaintiffs suggest that retailers price products? You can’t have zone pricing, you can’t have base pricing, as Mr. Stone says, you can’t match a price. Macy’s can’t match Gimbles, and Nordstrom’s can’t match Nieman Marcus. What are we talking about. Cases caution courts against becoming pricing czars. … A. There is no contract basis to suggest some obligation to have cost pricing …. There is no contract covenant to base … pricing solely on costs …. There is no basis to suggest … some certain amount over costs …. This species of price fixing securities price tag case, like all “securities price fixing” actions, falls under a defined monopoly contract model: I. Monopoly Pricing: No competition - P> MR=MC a. Cost is not a factor in pricing II. Duopoly Protocol: a. Matched/Narrow Ambit Pricing - P> MR=MC III. Cartel Strategy: a. Matched/Narrow Ambit Pricing P> TR=TC IV. Non Competitive: a. Matched Prices/Narrow Ambit - P> MR=MC V. Competitive: Matched Prices - P= TR=TC a. Prices are fixed based on a cost study, compliant with textbook contract price economics, disclosed in good faith to clients. b. The mature measure individual costs and set on price accordingly. c. In a competitive market, price is based on cost rather than on value. d. In … competitive markets price equals costs and each seller knows his costs. e. In every contract there is an implied covenant of good faith and fair dealing. f. Obligation: measure costs and set a good faith price accordingly. Only through reams of material omissions, in and out of court, does any securities price fixing case exist – and the entire defense bar knows it; it exists only through dark breach, concealment, perjury and court fraud. Next time any judge aims its filthy lip and ink at Robbins Geller, I may directly remind it of this testimony Greg Stone’s Munger Tolles and Olsen’s client swore to in a stock price linked action A. Cost pricing – a bogus program…. It … didn’t work. All defense firms know that in this strain of price lit the accused represents that it: A) will do its best to achieve defined monopoly revenues; B) will accurately report all monopoly revenues; C) will truthfully and timely apprise owners/holders of the risks involved such process; and D) will share its monopoly profits with non-staff investors. Targeting our firm only (discrimination), Quackenbush published: I. This court’s fiduciary role has caused the court to look closely at the alleged hours and rates in the claimed lodestar of the Robbins firm. II. The court determines that the maximum hourly rates for the law firm’s personnel in this case … are as follows: a. Partners: $500/hour b. Associates: $300/hour c. Paralegals: $150/hour d. Document Clerks: $0.00 (included in hourly price/overhead) III. The court has determined that claims for time spent for the work of docket [or document] clerk is not appropriately considered in setting the lodestar for attorney compensation. Such fees are part of a law firm’s normal overhead and should not be included in the lodestar calculation. IV. Statements of “Expenses” and “Disbursements” in the Declarations of attorneys Grant and Bull were not true statements of monies paid to the listed “Experts/Consultants/Investigators.” V. Included in that expense category was a pre-mediation dinner for four totaling $402, including two bottles of $70/bottle wine and a $60 tip. Darren J. Robbins and Michael J. Dowd … have acknowledged the inappropriateness of such a claim as an expense to be paid by clients. VI. While Mr. Robbins and other members of his firm may choose to fly in the first class section, it is not appropriate for the persons who suffered … losses to pay for first class transportation. VII. The court is unable to find that these “mistakes” were inadvertent …. They were, at a minimum, … reckless … or even intentionally false. VIII. Neither Ms. Bull nor the law firm has responded to the concern of the court that a pattern of conduct in such matters may exist. IX. Mr. Grant, Ms. Bull and the law firm of Robbins Geller Rudman & Dowd are formally notified that the court intends to sanction them. The attached rule based memos might aid other courts in antitrust and related price litigation matters about this defense dictated problem of ours. Meanwhile, I’ll prepare a real short money laundering case against every defense firm and judge. Kind regards, Gary Joseph Bonas II
Posted on: Mon, 24 Nov 2014 07:39:54 +0000
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